Draft

Environmental 

Impact Statement

Bureau of Land Management

Oregon State Office

BLM

September 2009

Vegetation Treatments Using Herbicides

on BLM Lands in Oregon
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 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) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dear Reader: 

Attached is the Summary of the Draft Environmental Impact Statement (DEIS) for Vegetation 

Treatments Using Herbicides on BLM Lands in Oregon or the complete DEIS, depending upon which 

you requested when you asked to be on the mailing list. The Bureau of Land Management (BLM) 

prepared the DEIS to address the affects of a proposal to add additional herbicides to the ones BLM 

already uses to control noxious weeds in Oregon, and to expand the uses of those herbicides beyond 

just the control of noxious weeds. 

The 60-day comment period begins with publication of the Notice of Availability in the Federal 

Register, which is expected to occur on September 11, 2009. The comment period is expected to 

close November 10, 2009. Changes in these dates will be published on the website listed on the 

title page. The purpose of the comment period is to ensure the Final EIS includes an appropriate 

range of reasonable alternatives to the proposed action, and that the analysis of effects is complete, 

appropriately presenting and interpreting the available published information. The BLM asks that 

those submitting comments on the DEIS make them as specific as possible. 

For those of you receiving only the Summary, be aware that the information included in it is 

necessarily brief, and does not include most of the references, tables, and appendices included in the 

body of the DEIS. While you are welcome to comment on the Summary, comments about missing or 

misinterpreted technical information, alternatives that should have been considered, or other similar 

substantive comments may wish to request a copy of the full DEIS at the address listed on the title 

page, or access it online, and direct comments to sections within the DEIS. 

Reviewers should provide their comments during the comment period. This will enable the BLM to 

analyze and respond to the comments at one time and to use information acquired in the preparation 

of the Final EIS, thus avoiding undue delay in the decision-making process. Reviewers have an 

obligation to “‘structure their participation in the National Environmental Policy Act process so that 

it is meaningful and alerts the agency to the reviewer’s position and contentions.’ Vermont Yankee 

Nuclear Power Corp. v. NRDC, 435 U.S. 519, 552 (1978).” Dept. of Transportation v. Public Citizen, 

541 U.S. 752, 764 (2004). Therefore, environmental concerns that could have been raised at the draft 

stage may be forfeited if not raised until after completion of the Final EIS. Comments on the DEIS 

should be specific and should address the adequacy of the DEIS and the merits of the alternatives 

discussed (40 CFR 1503.3). 
Comments received in response to this solicitation, including names and addresses, will be considered 

part of the public record on this DEIS and are available for public inspection. Comments, including 

names and addresses, may be published as part of the Final EIS. If you wish to withhold your name 

or address from public review, or from disclosure under the Freedom of Information Act (FOIA), you 

must state this prominently at the beginning of your written comments. Additionally, pursuant to 7 

CFR 1.27(d), any person may request that submissions be withheld from the public record by showing 

how the FOIA permits such confidentiality. Persons requesting such confidentiality should be aware 

that under FOIA, confidentiality may be granted in only very limited circumstances, such as to protect 

confidential business information. The requester will be informed of the BLM decision regarding the 

request for confidentiality. Where the request is denied, the comments will be returned to the requester, 

and the requester will be notified that the comments may be resubmitted with or without name and 

address. Comments submitted anonymously will be accepted and considered. Anonymous comments 

do not create standing or a record of participation. All submissions from organizations and businesses, 

and from individuals identifying themselves as representatives or officials of organizations or business, 

will be available for public inspection in their entirety. 

For further information on this EIS, contact Todd Thomson, BLM Restoration Coordinator, P.O. Box 

2965, Portland OR 97208, or via telephone at 503 808-6326 or email the EIS Team at the address on the 

title page. 

Thank you for your interest in public land management. We look forward to receiving your comments 

on the DEIS. 

Enclosure 

1 – Draft Environmental Impact Statement and/or 

1 – Draft Environmental Impact Statement Summary 
 

 

 

 

MAIL COMMENTS TO: 

Vegetation Treatments EIS Team 

PO Box 2965 

Portland, OR 97208-2965 

orvegtreatments@blm.gov 

Vegetation Treatments Using Herbicides
 

on BLM Lands in Oregon
 

Draft Environmental Impact Statement
 

Bureau of Land Management
 

September 2009 

Responsible Official: Edward W. Shepard, Oregon/Washington Bureau of Land Management 

State Director 

Information Contact: Todd Thompson 

Restoration Coordinator 

Bureau of Land Management 

PO Box 2965 

Portland OR 97208-2965 

(503) 808-6326 

The Draft EIS is available for public review for 60 days beginning with publication of the Notice of 

Availability in the Federal Register, expected to take place on September 11, 2009. Actual publication 

date will be noted on the web site below. Assuming publication on September 11, the 60-day public 

comment period would end on November 10, 2009. 

Copies of this document are also available online at http://www.blm.gov/or/plans/vegtreatmentseis/. Printed 

copies or a CD version can be obtained by contacting the Vegetation Treatments EIS Team at the addresses above. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Notice
 

This is a Draft EIS and a public comment period will run for 60 days. Instructions for commenting, and a description 

of future appeal rights that may be forgone if you do not comment, are included in the Dear Reader letter. After the 

comment period, a Final EIS and Record of Decision will be prepared. 

The Final EIS and Record of Decision are expected to be issued about July 2010. The responsible official is the BLM 

Oregon/Washington State Director (see title page). Since this EIS is not specifically about grazing, forest management, 

or resource management planning, the appeal procedures for general public land issues will apply. Therefore, a 30-day 

appeal period will follow issuance of the Record of Decision. The Record of Decision may be issued concurrently 

with the Final EIS, and the applicable appeal procedure will be described in detail in both documents. Applicable 

regulations can be found at 43 CFR § 4.411, 43 CFR § 4.21, 43 CFR § 4.401. 

Abstract 

The BLM proposes to increase the number of herbicides available for use on BLM lands in Oregon, and to expand 

their use beyond the noxious weed management program. Noxious weeds are spreading on BLM lands at the rate of 

144,000 acres per year. The existing BLM vegetation management program (Alternative 2) is unable to effectively 

address the rate of spread or treat all species. New herbicides are available that would better control weeds, better 

meet other non-commodity vegetation management objectives, and have fewer adverse effects on humans and 

the environment. This EIS examines three alternatives that would meet the need: Alternative 3 would add seven 

herbicides west and nine herbicides east of the Cascades, to the four herbicides already being used to control noxious 

weeds. Herbicides use would be expanded to include the treatment of other invasive plants, and the treatment of 

native plants to control invasive pests and diseases; Alternative 4 would add 8 and 12 herbicides and add (to the 

uses described in Alt. 3) native vegetation control in rights-of-way, administrative sites, and recreation sites, and 

conduct wildlife habitat improvement specified in interagency conservation plans for rare species, and; Alternative 

5, would add 14 herbicides statewide to the four already being used, and expand herbicide use to include any noncommodity objective. An alternative of No Herbicide Use (Alternative 1) is also included for comparison purposes. 

The decision will hinge on which alternative best: controls noxious and other invasive weeds; protects developments 

from encroaching vegetation; maintains wildlife and other habitats; reduces fire risk; complements weed control 

work on adjacent lands; protects flora, fauna, and human health; controls exotic plant pests and diseases, and; 

minimizes treatment costs and economic losses. The analysis indicates: noxious weeds would infest 1.9 to 2.2 

million fewer acres under the Action Alternatives 3 and 4/5 respectively; that Alternative 4 and 5 would save $1 

million per year just in rights-of-way, administrative site, and recreation site vegetation management, and; under 

all alternatives and with Standard Operating Procedures and Mitigation Measures in place, risks to humans or any 

resource is generally low to negligible. Some additional potential mitigation is identified by the analysis. Potential 

additional monitoring is also identified. The preferred alternative is Alternative 4. 
 

 

 

 

 

Acronyms / Abbreviations
 

ACEC Area of Critical Environmental Concern 

AgDrift An aerial dispersal model used in pesticide registration 

a.i active ingredient 

ALS Acetolactate Synthase 

AML Appropriate Management Level 

ANSI American National Standards Institute 

ARI Aggregated Risk Index 

ATV All-Terrain Vehicle 

BA Biological Assessment 

BEA Bureau of Economic Analysis 

BEE With triclopyr, Butoxyethyl ester 

BLM Bureau of Land Management 

BO Biological Opinion 

CALPUFF An atmospheric pollution dispersion model 

CBI Confidential Business Information 

CDC Centers for Disease Control and Prevention 

CEC Cation Exchange Capacity 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CO Carbon Monoxide 

CO2 Carbon Dioxide 

CWMA Cooperative Weed Management Areas 

DEIS Draft Environmental Impact Statement 

DEQ Department of Environmental Quality 

DO Dissolved Oxygen 

DOI Department of the Interior 

EA Environmental Assessment 

EEC Estimated Exposure Concentration 

EFH Essential Fish Habitat 

EIS Environmental Impact Statement 

ENSO El Nino-Southern Oscillation 

i 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EPA Environmental Protection Agency 

ERA Ecological Risk Assessment 

ESA Endangered Species Act 

F Fahrenheit 

FIA Forest Inventory Analysis 

FIFRA Federal Insecticide, Fungicide and Rodenticide Act 

FLPMA Federal Land Policy and Management Act 

FS Forest Service 

FWS U.S. Fish and Wildlife Service 

GLEAMS Groundwater Loading Effects of Agricultural Management Systems 

HFRA Healthy Forests Restoration Act 

HHRA Human Health Risk Assessment 

HMA Herd Management Area 

HQ Hazard Quotient 

ICBEMP Interior Columbia Basin Ecosystem Management Project 

INFISH Inland Native Fish (an aquatic conservation strategy) 

ISSSSP Interagency Special Status / Sensitive Species Program 

IVM Integrated Vegetation Management 

LC50 Lethal Concentration to 50% of the Population 

LD50 Lethal Dose to 50% of the Population 

LOAEL Lowest Observed Adverse Effects Level 

LOC Level of Concern 

MCL Maximum Contaminant Levels 

MM Mitigation Measure 

MOU Memorandum of Understanding 

NAAQS National Ambient Air Quality Standards 

NCA National Conservation Area 

NCAP NW Coalition for Alternatives to Pesticides 

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act 

NCHS National Center for Health Statistics 

NCIPC National Center for Injury Prevention and Control 

NIOSH National Institute for Occupational Safety and Health 

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration

 ii 
 

 

 

 

 

 

 

 

NOAEL No Observed Adverse Effects Level 

NOX Nitrogen Oxides 

NP Nonylphenol 

NPE Nonylphenol Plyethoxylate (a surfactant) 

NRCS Natural Resources Conservation Service 

O3 Ozone 

O&C Act Oregon and California Lands Act 

ODA Oregon Department of Agriculture 

ODEQ Oregon Department of Environmental Quality 

ODF Oregon Department of Forestry 

ODFW Oregon Department of Fish and Wildlife 

OHV Off-Highway Vehicle 

ONA Outstanding Natural Area 

OSHA Occupational Safety and Health Administration 

OSU Oregon State University 

PACFISH Pacific Fish (an aquatic conservation strategy) 

PAR Pesticide Application Report 

PDO Pacific Decadal Oscillation 

PEIS 2007 Programmatic Environmental Impact Statement for 17 Western States 

PER Programmatic Environmental Report 

PFC Proper Functioning Condition 

pH Potential of Hydrogen (measure of acidity) 

PM Particulate Matter 

POEA Polyoxyethylenamine (a surfactant) 

PRPA Paleontological Resources Protection Act 

PSD Prevention of Serious Degradation 

PUR Pesticide Use Report 

PVT Potential Vegetation Type 

Nonylphenol Ethoxylate (an adjuvant) 

RED Reregistration Eligibility Decision 

RfD Reference Dose 

RMP Resource Management Plan 

RNA Research Natural Area 

ROW Right-of-Way 

RQ Risk Quotient 

iii 

R-11 
 

 

 

 

SHPO State Historic Preservation Office 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

SOP Standard Operating Procedure 

TI Toxicity Index 

TIP Tribal Implementation Plan 

TEA With triclopyr, triethyamine salt 

TEP Threatened, Endangered, or Proposed 

TMDL Total Maximum Daily Load 

TRV Toxicity Reference Value 

TSP Total Suspended Particles 

USDA U.S. Department of Agriculture 

USDI U.S. Department of the Interior 

USGS U.S. Geological Survey 

UTV Utility Vehicle 

UV Ultra-violet 

VOC Volatile Organic Compound 

VRM Visual Resource Management 

WUI Wildland-Urban Interface 

WSA Wilderness Study Area 

WSR Wild and Scenic River

 iv 
Table of Contents
 Acronyms / Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
 

Chapter 1 - Purpose and Need . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
 

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

Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
 

The Need. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
 

Proposed Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
 

Alternatives to the Proposed Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
 

The Purposes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
 

Decision to be Made . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
 

Scoping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
 

Consultation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11
 

Related Plans and Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
 

2007 National PEIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
 

Resource Management Plans. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
 

Existing and Future Project-Level Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
 

Chapter 2 - The Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
 

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet 

Elements Common to All Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
 

Applicable Lands. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
 

Legal and Policy Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
 

Standard Operating Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
 

Mitigation Measures Adopted by the Record of Decision for the PEIS . . . . . . . . . . . . . . . . . . . 16
 

The Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
 

The No Action Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only . . . . . . . . . . . . . . 17
 

The Action Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
 

Alternative 1 – No Herbicide Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
 

and Control Pests and Diseases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
 

 Invasive Weeds plus Limited Additional Uses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
 

Non-Commodity Vegetation Management Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
 

Alternatives Eliminated From Detailed Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
 

No Use of Acetolactate Synthase (ALS)-inhibiting Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . 21
 

No Aerial Application of Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
 

v 
Reduce Ground-Disturbing Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
 

Use Vinegar, Salt, and other Household Products. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
 

Increase Use of Non-Herbicide Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
 

Increase Funding to Pay for Additional Control Treatments. . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
 

Consider the Use of Different Herbicides Other than the 18 Being Considered. . . . . . . . . . . . . 23
 

Comparison of the Effects of the Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
 

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
 

Noxious Weed Spread and the Adverse Effects of Weeds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
 

Non-Herbicide Control Methods. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
 

Additional Effects by Resource . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
 

Summary of the Major Effects of Each Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
 

The Preferred Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
 

Potential Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
 

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
 

Resource Effects Section and Potential Mitigation Identified . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
 

Chapter 3 - Background and Assumptions for Effects Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
 

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
 

Background for Effects Analysis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
 

The 18 Herbicides. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
 

Assumptions and Information about Treatment Acres. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
 

Integrated Vegetation Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
 

Herbicide Treatment Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
 

Non-Herbicide Treatment Methods. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52
 

Treatment Acres, Gross Acres and Net Acres, and Pounds of Herbicides to be Applied . . . . . . 57
 

Assumptions about Application Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
 

Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
 

EPA Labels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70
 

High, Medium, and Low Risk in BLM and Forest Service Risk Assessments . . . . . . . . . . . . . . 71
 

Uncertainty in the Risk Assessment Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73
 

Use of the Risk Assessment Worksheets During Implementation. . . . . . . . . . . . . . . . . . . . . . . . 73
 

Methodology for Assessing Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73
 

Standard Operating Procedures, PEIS Mitigation Measures, Risk, and the 

Potential for Adverse Effects. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74
 

Chapter 4 - Affected Environment and Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85
 

Incomplete and Unavailable Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85
 

Accidental Spill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87
 

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
 

Oregon Department of Agriculture’s Pesticide Use Reporting System. . . . . . . . . . . . . . . . . . . . 89
 

NCAP-NMFS Settlement Agreement to Examine 37 Pesticides . . . . . . . . . . . . . . . . . . . . . . . . 90
 

 vi 
Forest Service’s Invasive Plant Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
 

Petition to Cancel all Registrations of 2,4-D. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
 

Sulfometuron Methyl Reregistration Eligibility Decision (RED). . . . . . . . . . . . . . . . . . . . . . . . 91
 

Environmental Setting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93
 

Current Climate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93
 

Biomes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95
 

Sagebrush Steppe Biome . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96
 

Eastern Forest Biome. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97
 

East Side Riparian Biome . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99
 

Siskiyou Biome . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100
 

Western Forest Biome . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101
 

Willamette Valley Biome. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103
 

Noxious Weeds and Other Invasive Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104
 

Traits of Invasive Plants. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104
 

Mechanisms of Invasion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105
 

Weed Infestations in Oregon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107
 

Noxious Weed Spread Rate by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108
 

Vegetation, Native Plants, and Plant Communities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .112
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .112
 

Susceptibility of Plant Communities to Damage from Invasive Plants. . . . . . . . . . . . . . . . . . . .113
 

Endangered, Threatened, and Bureau Sensitive Plant Species . . . . . . . . . . . . . . . . . . . . . . . . . .116
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .116
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .116
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123
 

Pests and Diseases (Sudden Oak Death). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128
 

Sudden Oak Death Characteristics and Dispersal Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128
 

Regulations and Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 130
 

Treatment History in Oregon. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 130
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131
 

Effects (to Vegetation) by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133
 

Climate Trends, Projections, and Implications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 135
 

Observed Climate Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 135
 

Climate Change Projections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 135
 

Implications of Climate Change on Invasive Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137
 

vii 
Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 138
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 138
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 140
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 142
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 142
 

Soil Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 154
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 157
 

Water Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 157
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 157
 

Flows . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 158
 

Water Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 158
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 162
 

Effects of Herbicides on Water Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 162
 

Routes for Off-Site Movement of Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 166
 

Effect of Invasive Plants on Water Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 171
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 172
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 175
 

Wetlands and Riparian Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 176
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 176
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 178
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 178
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 182
 

Fish . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 184
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 184
 

Fish and Their Habitat . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 184
 

Setting - Aquatic Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 185
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 187
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 188
 

Effects by Alternative – Non-Special Status Fish . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 198
 

Effects by Alternative – Special Status Fish . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 202
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 205
 

Wildlife Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 208
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 208
 

Wildlife Considerations by Biome. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 209

 viii 
Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 212
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 212
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 220
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 224
 

Livestock. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 224
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 224
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 226
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 226
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 231
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 234
 

Wild Horses and Burros . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 234
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 234
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 235
 

Effects Commons to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 235
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 236
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 240
 

Fire and Fuels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 240
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 240
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 241
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 242
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 243
 

Timber. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 244
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 244
 

Existing Timber Volume Production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 245
 

Invasive Plants on Timberlands. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 245
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 246
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 246
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 247
 

Cultural and Paleontological Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 248
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 248
 

Paleontological Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 249
 

Cultural Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 249
 

Traditional and Cultural Uses (American Indian Interests). . . . . . . . . . . . . . . . . . . . . . . . . . . . 249
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 250
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 251
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 252
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 256
 

Visual Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 258
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 258
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 258
 

ix 
Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 259
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 261
 

Wilderness and Other Special Areas. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 264
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 264
 

Wilderness and Wilderness Study Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 264
 

Wild, Scenic, and Recreational Rivers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 265
 

National Monuments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 265
 

National Scenic and Historic Trails. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 265
 

Areas of Critical Environmental Concern, Research Natural Areas, and Outstanding Natural 

Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 266
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 266
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 266
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 267
 

Recreation/Interpretive Sites. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 269
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 269
 

Recreation Management Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 270
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 270
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 271
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 271
 

Administrative Sites, Roads, and Rights-of-Way . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 276
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 276
 

Government Facilities and Roads . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 277
 

Rights-of-Way (ROWs). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 279
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 281
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 281
 

Social and Economic Values. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 284
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 284
 

Analysis Area. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 284
 

Population and Demographic Change . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 285
 

Economic Specialization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 286
 

Perceptions, Values, and Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 286
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 286
 

Concerns Raised During Oregon Scoping. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 287
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 288
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 289
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 293
 

Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 293
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 293
 

Population and Demographic Change . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 293

 x 
Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 295
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 296
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 297
 

Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 299
 

Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 303
 

Treated Acres and Effectively Treated Acres, by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . 303
 

Costs by Treatment Method. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 304
 

Total Cost and Cost per Effectively Treated Acre by Alternative . . . . . . . . . . . . . . . . . . . . . . . 305
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 306
 

Non-Quantified and Cumulative Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 307
 

Human Health and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 308
 

Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 308
 

Background Health Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 308
 

Risks from Diseases. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 308
 

Risks from Cancer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 308
 

Injury Risk from Using Herbicides and Non-Herbicide Treatments . . . . . . . . . . . . . . . . . . . . . 309
 

Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 310
 

Methodology for Assessing Effects. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 310
 

Effects Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 312
 

Effects by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 320
 

Critical Elements of the Human Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 324
 

Other Environmental Consequences. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 326
 

Adverse Effects Which Cannot Be Avoided . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 326
 

Relationship Between Short-Term Uses of the Human Environment and 

Maintenance of Long-term Productivity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 327
 

Irreversible or Irretrievable Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 327
 

Conflicts and Consistency with Other Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 328
 

Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 329
 

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 355
 

List of Preparers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 389
 

Distribution List . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 393
 

Appendix 1 – The PEIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 403
 

Appendix 2 - Standard Operating Procedures and Mitigation Measures from the PEIS . . . . . . . . . . . . . 405
 

Appendix 3 – Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 419
 

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 419
 

xi 
Existing Monitoring. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 419
 

Part I - Existing Monitoring. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 420
 

Part II – Potential Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 422
 

Appendix 4 – Protocol for Identifying, Evaluating, and Using New Herbicides . . . . . . . . . . . . . . . . . . . . . 425
 

Summary of 2007 ROD Appendix A – Protocol for Identifying, Evaluating, and Using 

New Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 425
 

Identification and Approval of New Herbicide Products and Technologies . . . . . . . . . . . . . . . 425
 

Determining the Need for New Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 426
 

Assessment of Hazards and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 427
 

NEPA Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 427
 

Appendix 5 – Endangered, Threatened, and Bureau Sensitive Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . 429
 

Table of Contents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 429
 

Summary of the Action Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 429
 

Summary of Applicable Standard Operating Procedures and PEIS Mitigation Measures . . . . 430
 

Consultation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 431
 

Endangered and Threatened Species in Oregon. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 431
 

Birds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 431
 

Fish . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 436
 

Invertebrates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 449
 

Mammals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 452
 

Vascular Plants. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 456
 

Appendix 6 – Summary of Existing District Resource Management Plan Direction for Noxious Weeds 485
 

Appendix 7 – Additional Information about Noxious Weeds and Other Invasive Plants . . . . . . . . . . . . . . 515
 

Oregon State Noxious Weed List . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 515
 

Common and Scientific Plant Names. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 518
 

Noxious Weed Spread Rate References and Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 524
 

Additional Information about the Ecological Damage Caused by Invasive Plants . . . . . . . . . . . . . . 528
 

Appendix 8 – Human Health and Ecological Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 533
 

Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 533
 

Appendix 9 – Additional Information About the 18 Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 537
 

Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 548
 

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Figures List 

Figure 1-1. Lands Administered by the Bureau of Land Management in Oregon . . . . . . . . . . . . . . . . . . . . . . . . 3
 

Figure 3-1. Basis for Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72
 

Figure 4-1. Average Annual Precipitation 1961-1990. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
 

Figure 4-2. Oregon Biomes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98
 

Figure 4-3 Relationship between Area Occupied by Invasive Species and Time . . . . . . . . . . . . . . . . . . . . . . 105
 

Figure 4-4. Potential Vegetation Types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .115
 

Figure 4-5. Map of Soil Orders. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 146
 

Figure 4-6. Source Water Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161
 

Figure 4-7. Population change for Oregon and counties east and west of the 

Cascades (Source: US Department of Commerce 2005) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 285
 

Table 4-36: Estimated Annual Acres of Treatments with Risk to 

Worker and Public Human Health by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 321
 

Tables List 

Table 2-1. Estimated Annual1 Herbicide Treatment Acres2 by Alternative and Treatment Objective. . . . . . . . . . 17
 

Table 2-2. Herbicides Available Under Each Alternative. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
 

Table 2-3. Projected Annual Noxious Weed Spread and Acreage Change for Each Alternative. . . . . . . . . . . . . . 26
 

Table 2-4. Noxious and Other Invasive Weed Treatment Costs by Alternative. . . . . . . . . . . . . . . . . . . . . . . . . . . 32
 

Table 2-5. Selected Parameters for Each Alternative Relevant to the Effects Comparison. . . . . . . . . . . . . . . . . . 33
 

Table 3-1. Herbicide Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
 

Table 3-2. Herbicide Application Methods on BLM Lands in Oregon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
 

Table 3-3. Estimated1 Annual Treatment Acres West/East7 of the Cascades for Each Alternative.. . . . . . . . . . . . 58
 

Table 3-4. Estimated Annual Acres Treated in Rights-of-Way, Administrative Sites, and Recreation Sites . . . . 60
 

Table 3-5. Estimated Annual Pounds of Herbicides that Would be Applied at Typical and 

Maximum Application Rates East/West of the Cascades for Each Alternative.. . . . . . . . . . . . . . . . . . 62
 

Table 3-6. 2006-2008 Pesticide Use Reports Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
 

Table 3-7. Ground and Aerial Herbicide Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
 

Table 3-8. Estimated Annual Herbicide Treatment Acres under Alternatives 3, 4, and 5 . . . . . . . . . . . . . . . . . . . 66
 

Table 3-9. Estimated Change in Native Vegetation Annual Treatment Acres . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
 

Table 3-10. Human Health and Ecological Risk Assessment Sources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69
 

Table 3-11. Herbicide Label Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 

Table 3-12. BLM-Evaluated Herbicide Risk Categories for Vegetation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75
 

Table 3-13. FS-Evaluated Herbicide Risk Categories for Vegetation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76
 

Table 3-14. BLM-Evaluated Herbicide Risk Categories for Wildlife, Fish, and Aquatic Species . . . . . . . . . . . . . 77
 

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Table 3-15. FS-Evaluated Herbicide Risk Categories for Wildlife, Fish, and Aquatic Species . . . . . . . . . . . . . . . 80
 

Table 3-16. BLM-Evaluated Herbicide Risk Categories for Workers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
 

Table 3-17. BLM-Evaluated Herbicide Risk Categories for the Public. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82
 

Table 3-18. FS-Evaluated Herbicide Risk Categories for Workers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82
 

Table 3-19. FS-Evaluated Herbicide Risk Categories for the Public . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
 

Table 3-20. BLM 1991-Evaluated Herbicide High Risk Scenarios for Workers. . . . . . . . . . . . . . . . . . . . . . . . . . . 84
 

Table 3-21. BLM 1991-Evaluated Herbicide High Risk Scenarios for the Public . . . . . . . . . . . . . . . . . . . . . . . . . 84
 

Table 4-1. 2008 Oregon-Wide Use of the 18 Herbicides Analyzed in this EIS and 

Comparison with BLM Proposed Action (Alternative 4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90
 

Table 4-2. BLM Lands by Biome . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96
 

Table 4-3. Projected Annual Acres of Effective Noxious Weed Control by Alternative . . . . . . . . . . . . . . . . . . . 110
 

Table 4-4. Projected Annual Noxious Weed Spread Rates and Acreage Changes for Each Alternative. . . . . . . 111
 

Table 4-5. Potential Vegetation Types. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 114
 

Table 4-6. Projected Noxious Weed Spread Rates and 15-Year Infested Acres for Each Alternative1

. . . . . . . 122
 

Table 4-7. Estimated Change in Native Vegetation Annual Treatment Acres by Treatment Method . . . . . . . . . 127
 

Table 4-8. Sudden Oak Death in Oregon Forests: December 31, 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131
 

Table 4-9. Primary and Secondary National Ambient Air Quality Standards (NAAQS) . . . . . . . . . . . . . . . . . . 138
 

Table 4-10. Non-Attainment and Air Quality Maintenance Areas in Oregon . . . . . . . . . . . . . . . . . . . . . . . . . . . . 139
 

Table 4-11. Mandatory Class I Areas in Oregon and Nearby in Adjoining States. . . . . . . . . . . . . . . . . . . . . . . . . 140
 

Table 4-12. Emissions from Vegetation Treatments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 143
 

Table 4-13. Soil Order Properties and Extent on BLM Lands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 147
 

Table 4-14. Selected Characteristics that Affect the Fate of Herbicides in Soils. . . . . . . . . . . . . . . . . . . . . . . . . . 151
 

Table 4-15. Miles of BLM Streams on ODEQ 303d List. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 159
 

Table 4-16. Maximum Herbicide Concentration Allowed in Potable Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 160
 

Table 4-17. Herbicide Persistence in Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 167
 

Table 4-18. Drift Distance Versus Drop Diameter (NDSU 1993) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 168
 

Table 4-19. Glyphosate Concentration in Streams 1 Hour and 24 Hours After Injection . . . . . . . . . . . . . . . . . . . 170
 

Table 4-20. Herbicide Half-Life in Anaerobic Soils. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179
 

Table 4-21. American Indian Tribes with Interests in Oregon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 250
 

Table 4-22. Vegetation Treatment Methods Contributing to Ground Disturbance . . . . . . . . . . . . . . . . . . . . . . . . 253
 

Table 4-23. Estimated Annual Treatment Acres by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 260
 

Table 4-24. Approximate Acres of Noxious Weeds Treated Annually in Special Areas . . . . . . . . . . . . . . . . . . . 267
 

Table 4-25. Approximate Acres of Other (non-noxious) Invasive Vegetation Treated 

Annually in Special Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 267
 

Table 4-26. Approximate Annual Acres of Vegetation Currently Treated Within Developed 

Recreation Sites and Hiking Trails by Treatment Method (Alternative 2 – No Action) . . . . . . . . . . 272
 

Table 4-27. Population Living Below the Poverty Level . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 295
 

Table 4-28. Racial and Ethnic Change Compared to the Total Population Change in Oregon, 

by County (1990 to 2000) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 300
 

Table 4-29. Racial and Ethnic Share of 2000 Population. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 301
 

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Table 4-30. Population Living Below the Poverty Level in Oregon, by County, Race, and Ethnicity . . . . . . . . . 302
 

Table 4-31. Estimated Annual Acres of Noxious/Invasive Weed Treatment by Alternative . . . . . . . . . . . . . . . . . 304
 

Table 4-32. Average Direct Cost of Treatment by Treatment Method, per Acre, East and 

West of the Cascades . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 305
 

Table 4-33. Annual Cost of Noxious/Invasive Weed Treatment per Alternative. . . . . . . . . . . . . . . . . . . . . . . . . . 305
 

Table 4-34. Annual Cost for ROW/Administrative Sites/Recreation Sites Treatments. . . . . . . . . . . . . . . . . . . . . 307
 

Table 4-35. Leading Causes of Death by Percentage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 309
 

Table 4-36. Estimated Annual Acres of Treatments with Risk to Worker and Public 

Human Health by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 321
 

Table A2-1. Buffer Distances to Minimize Risk to Vegetation from Off-Site Drift of . . . . . . . . . . . . . . . . . . . . . 415
 

BLM-Evaluated Herbicides. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 415
 

Table A2-2. Buffer Distances to Minimize Risk to Vegetation from Off-Site Drift of Forest . . . . . . . . . . . . . . . 416
 

Service-Evaluated Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 416
 

Table A2-3. Buffer Distances to Minimize Risk to Non Special Status Fish and Aquatic Invertebrates . . . . . . . 416
 

from Off-Site Drift of BLM-Evaluated Herbicides from Broadcast and Aerial Treatments . . . . . . . 416
 

Table A2-4. Buffer Distances to Minimize Risk to Special Status Fish and Aquatic Organisms from . . . . . . . . 417
 

Off-Site Drift of BLM-Evaluated Herbicides from Broadcast and Aerial Treatments. . . . . . . . . . . . 417
 

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

or Proposed, Oregon January 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 470
 

Table A5-2. State Director’s Special Status Species List, January 2008, Oregon BLM . . . . . . . . . . . . . . . . . . . . 472
 

Table A7-1. Oregon Noxious Weeds: Abundance and Alternative Where Effective Control 

Becomes Available - July 2009 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 515
 

Table A7-2. Common and Scientific Plant Names of Plants Potentially Requiring Management. . . . . . . . . . . . . 518
 

Table A7-3. Annual Acres of Effective Noxious Weed Control by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . 525
 

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 526
 

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

Annual Control (Difference Between Alts 2 and 1, 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 . . . . . . 527
 

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 527
 

Table A8-1. Risk Assessments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 535
 

Table A8-2. Additional Risk Assessment Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 535
 

Table A9-1. Herbicide Formulations Approved for Use on BLM Lands Nationally as of 2009 . . . . . . . . . . . . . . 537
 

Table A9-2. Target Species and Recommended Herbicide Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 542
 

xv 

 

 

Chapter 1 

Purpose and Need 

Introduction 

This Environmental Impact Statement (EIS) was prepared by the Bureau of Land Management (BLM) Oregon 

State Office to analyze, at the programmatic scale, a proposal to increase the number of herbicides1 available to 

the nine BLM districts in Oregon (Figure 1-1) for use in their existing noxious weed, invasive plant, and other 

non-commodity vegetation management programs. This EIS does not analyze any specific treatments nor will 

the decision authorize specific projects. Future vegetation control projects utilizing herbicides proposed by BLM 

districts within Oregon will be subject to site-specific analyses under the National Environmental Policy Act 

(NEPA). Those site-specific analyses will tier to this EIS and be subject to the limitations imposed by the Record 

of Decision for this EIS. This EIS does not propose the use of herbicides specifically for commodity production 

such as projects to improve timber growth or livestock forage. This EIS does not propose to amend district 

Resource Management Plans (RMPs). 

In 2007, the BLM national office completed the Vegetation Treatments Using Herbicides on Bureau of Land 

Management Lands in 17 Western States Programmatic Environmental Impact Statement (PEIS) and related 

Record of Decision, making 18 herbicides available for a full range of non-commodity vegetation treatments in 

17 western states. In western states other than Oregon, the BLM is implementing the Record of Decision for 

the PEIS by directly tiering to it at the field office level. However, the BLM in Oregon is currently unable to 

implement the 2007 Record of Decision because of a 1984 U.S. District Court injunction issued in Northwest 

Coalition for Alternatives to Pesticides, et al. v. Block, et al. (Civ. No. 82-6273-E), and modified by the court 

in November 1987 (Civ. No. 82-6272-BU). The injunction stemmed from a court decision that the BLM had 

not adequately considered, at the statewide scale, the cumulative human health effects of the herbicides being 

used at that time. The injunction permits the use of only four herbicides2

, and limits their use to the control and 

eradication of noxious weeds.3 

1 The term “herbicide” is used in this EIS to mean active ingredient (a.i.), and not trade name or formulation. 

2 2,4-D, dicamba, glyphosate, and picloram 

3 The injunction was amended June 22, 2009 to permit the use of glyphosate to kill tanoak to control Sudden Oak Death 

in 2009 and 2010, and to control European beach grass in 2009-2011 in the New River Area of Critical Environmental 

Concern that is encroaching on suitable habitat for three Federally Listed plants (US District Court 2009). 

1 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

This Oregon-wide EIS has been 

prepared primarily 1) to directly 

address the U.S. District Court’s 

concerns in a single programmatic 

document, and 2) because, unlike 

the other western states, many of 

the herbicides proposed for use 

have not been used on Oregon BLM 

lands in the past 20 years. Prior 

to the 2007 Record of Decision 

for the PEIS, western states other 

than Oregon were using up to 20 

different herbicides to meet a full 

range of vegetation management 

objectives. In those states, the 

Record of Decision removed six and 

added four for a net decrease of two 

herbicides. The action alternatives 

in this EIS would make up to 18 

herbicides available to a program currently limited to four. This EIS tiers to the PEIS and incorporates its entire 

analysis as Appendix 1. Pertinent analysis and conclusions of the PEIS are summarized into the body of this 

EIS for easier reference. This EIS also provides additional details about the proposed herbicide use (and related 

effects) in Oregon. 

This is a Draft EIS. It will be available for public review for 60 days, after which time the Final EIS will be 

prepared. The Final EIS will include specific responses to each substantive public comment, and the analysis will 

be improved by incorporating data, analysis, and ideas suggested during public review. The subsequent Record 

of Decision, expected in 2010, will be subject to a 30-day appeal period before the decision can be implemented. 

The decision-maker for this EIS will be the Oregon/Washington BLM State Director. 

Background 

The BLM manages approximately 15.7 million acres in Oregon, or about 25 percent of the land in the State. 

For the most part, these lands are either public domain lands managed under the Federal Land Policy and 

Management Act (FLPMA) or revested lands of the Oregon and California Railroad and reconveyed Coos Bay 

Wagon Road Grant Lands, specified for Department of the Interior management by the Oregon and California 

Grant Lands Act of 1937 (O&C Act). Although these two acts provide for different management priorities, 

both result in BLM providing for various land uses and outputs, and accommodating various developments for 

the public good. These include, but are not limited to, utility corridors, access roads, mining, grazing, timber 

production, recreation, and communications sites. These human uses and developments, and the vegetation 

management in support of them, have resulted in changes to native plant communities. While many of those 

vegetation changes have been intentional and beneficial, some have occurred at the expense of ecosystem health. 

These include the expansion of noxious weeds and other invasive plants and the build-up of hazardous fuels. 

Active vegetation management can mitigate some of these undesirable changes. Developments such as roads, 

utility corridors, and recreation sites also bring with them an expectation that encroaching vegetation will be 

managed to protect investments and maintain public safety. 

Terminology: 

Invasive plants (or weeds) are non-native aggressive plants with 

the potential to cause significant damage to native ecosystems and/ 

or cause significant economic losses. 

Noxious weeds are a subset of invasive plants that are county, 

state, or federally listed as injurious to public health, agriculture, 

recreation, wildlife, or any public or private property. 

Vegetation includes noxious weeds, invasive weeds, and 

introduced and native plants. 

Native vegetation includes native and desirable non-native plants. 

 2 
3

figUre 1-1. lands adminisTered by THe bUreaU of land managemenT in oregon 

3 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Numerous laws and policies direct and authorize the BLM to manage vegetation. The FLPMA and other laws 

provide a broad vegetation management mandate. The FLPMA directs the BLM to manage public lands “in a 

manner that will protect the quality of scientific, scenic, historic, ecological, environmental, air and atmospheric, 

water resources and archeological values...” (43 U.S.C. § 1701(a)(8)). In all, over 150 different authorities or 

policies direct vegetation management on lands administered by the BLM (BLM lands). Vegetation management 

can be used to improve land health and habitat, reduce fire risk, and preserve infrastructure (PEIS). 

Some Federal laws specifically direct the BLM and other agencies to aggressively manage invasive plants and 

other vegetation to improve ecosystem health and reduce fire risk. In particular, two weed control acts, the 

Carlson-Foley Act of 1968 (43 U.S.C. §§ 1241-1243) and the Plant Protection Act of 2000 (7 U.S.C. § 7702), 

authorize the BLM to manage noxious weeds and to coordinate with other Federal and State agencies in activities 

to eradicate, suppress, control, prevent, or retard the spread of any noxious weeds on Federal lands. The Federal 

Noxious Weed Act of 1974 (7 U.S.C. § 2814(a)) established and funded an undesirable plant management 

program, implemented cooperative agreements with State agencies, and established integrated management 

systems to control undesirable plant species. The Noxious Weed Control and Eradication Act of 2004 (7 U.S.C. § 

7781) established a program to provide assistance through states to eligible weed management entities to control 

or eradicate harmful, non-native weeds on public and private lands. The Public Rangelands Improvement Act 

of 1978 (43 U.S.C. § 1901(b)(2) requires the BLM to manage, maintain, and improve the condition of the public 

rangelands so that they become as productive as feasible. The Healthy Forests Restoration Act of 2003 (16 U.S.C. 

§§ 6501-6591) directs the BLM to take aggressive actions to reduce catastrophic wildfire risk on public lands, and 

places an emphasis on protecting adjacent at-risk communities. 

State and County laws also provide requirements for vegetation management. State laws require the State and 

private landowners to cooperate on noxious weed control, and give the State authority to declare noxious weed 

emergencies that require landowners to immediately control specified weeds (ORS 570-500). The Oregon 

Department of Agriculture (ODA) takes the lead in identifying and setting priorities for noxious weed control. 

The ODA coordinates closely with Federal and local entities and private landowners and often does the actual 

control work on BLM and other lands under cooperative agreements. BLM’s participation in these coordinated 

efforts helps keep weeds on BLM lands from reinvading neighboring non-BLM lands. 

Vegetation management to meet FLPMA’s public lands management policies and to satisfy the mandates of 

other laws, policy, and management plans takes place annually on thousands of acres of BLM lands in Oregon. 

While the emphasis for noxious weeds is on prevention, control measures for noxious weeds are conducted on 

22,000 acres annually using mechanical, biological, manual, fire, herbicides, and other methods (Appendix 6). 

Similarly, the BLM and/or its cooperators manage vegetation on thousands of acres per year to restore forest 

and rangeland health; provide sustainable habitat for Bureau Sensitive, Federally Listed4

, and other species of 

plants and animals; reduce the risk of wildland fire; and, provide for safe use and access to a variety of authorized 

developments. For these treatments, a full range of non-herbicide treatment methods are described in existing 

management plans, have been analyzed in existing NEPA documents, and are currently in use to achieve 

vegetation management objectives.5

 However, for herbicide use, the BLM in Oregon is limited by the 1984/87 

U.S. District Court injunction to the use of four herbicide active ingredients: 2,4-D; dicamba; glyphosate; and, 

picloram for noxious weed control only. 

4 Listed as threatened or endangered under the Endangered Species Act. 

5 Currently used non-herbicide methods are also discussed in detail in the Final Vegetation Treatments on BLM Lands in 

the 17 Western States Programmatic Environmental Report (PER), which is available on the EIS website. 

4 
Draft Environmental Impact Statement, Chapter 1: Purpose and Need 

The Need 

The ability of non-herbicide methods to effectively meet all vegetation management objectives is limited. Most 

manual and mechanical treatments are generally more expensive than the herbicide treatments, and mechanical 

treatments on sprouting woody species must be repeated regularly. Many species simply cannot be controlled 

with mechanical treatments because their roots are deep and readily re-sprout, because they are in areas where soil 

disturbance is not acceptable, access limitations prevent treatment, or they would simply reseed into mechanically 

disturbed sites. For many noxious weeds, the four herbicides currently available to the BLM in Oregon do not 

result in effective control. Invasive plants are continuing to spread at an increasing rate, and for many species, 

there is no effective means of control currently available to the BLM in Oregon. 

In spite of an aggressive vegetation management program using all available treatment methods, invasive plants 

are spreading, habitats are being degraded, and fuel buildup is increasing. About 1.2 million of the 15.7 million 

acres of BLM lands in Oregon are currently infested at some level6

 with noxious weeds, and another 5 million are 

infested with other invasive plants. They are continuing to spread at an estimated rate of 10-15 percent per year, 

increasing adverse effects to various valued resources (Appendix 7). Ecological damage from extensive noxious 

weed infestations is often permanent. Adverse effects include displacement of native plants; reduction in habitat 

and forage for wildlife and livestock; loss of threatened, endangered, and sensitive species’ habitat; increased soil 

erosion; reduced water quality; reduced soil productivity; reduced wilderness and recreation values; and, changes 

in the intensity and frequency of fires (USDA 2005). Invasive plants also spread to adjacent non-BLM lands, 

increasing control costs for affected landowners and degrading land values. 

There are also specific management situations where native vegetation is going untreated or only partially treated 

because available vegetation management methods are inefficient or costly. Vegetation encroachment along roads 

and into other developments requires more costly control measures when compared with herbicide treatments on 

adjacent ownerships. Mechanical methods can also spread invasive plants. Western juniper is encroaching into 

native shrub/grass communities, capturing available soil water, and altering soils in ways that inhibit retention 

and reestablishment of native plant communities. The plant pathogen Sudden Oak Death is getting a foothold 

in southwest Oregon, threatening to kill tanoaks and other plants in the State and leading to plant quarantines 

on a variety of nursery plants. Finally, the management of encroaching vegetation within road, power line, 

pipeline, and other rights-of-way and developments is being conducted with non-herbicide methods at a higher 

cost on BLM lands than on adjacent non-BLM lands where herbicides are available. These additional costs and 

reduced effectiveness ultimately affect utility subscribers and/or subtract from funds available for other vegetation 

treatments. 

To better meet BLM’s noxious weed and other vegetation management responsibilities, there is an underlying 

need for more effective vegetation control measures. 

Ranging from monocultures to a few plants per acre. 

5 

6
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Proposed Action 

Because all other known non-herbicide methods are available and being used to the extent practicable within 

existing funding and capabilities, the Need for more effective control measures translates to a proposal and 

alternatives to make more herbicides available for use on public lands administered by the BLM in Oregon. The 

Proposed Action7

 would make 12 herbicides available to BLM west of the Cascades and 16 herbicides available 

east of the Cascades8

 (Table 2-2 in Chapter 2) in order to better meet their noxious weed and other vegetation 

management responsibilities. These include the four currently available for noxious weed control. 

The proposed herbicides are all included within the 18 herbicides approved in 2007 for use by the BLM in the 

other 16 western states. Uses would be in compliance with the PEIS Mitigation Measures and standard operating 

procedures (SOPs) adopted for use in the 17 western states by the Record of Decision for the PEIS, as well as by 

current Department of the Interior and BLM Integrated Vegetation Management (IVM) policies and priorities. All 

herbicide uses would comply with all applicable laws and restrictions, and would only be used for the lands and 

uses for which they are labeled and registered with the State of Oregon. 

Selection of the Proposed Action would allow the BLM to choose from 12 or 16 herbicides (west and east of the 

Cascades respectively): 

•		 To treat noxious weeds and other non-native invasive plants as necessary to meet non-commodity 

Integrated Vegetation Management objectives.
 

•		 To treat any vegetation to meet safety and operation objectives in administrative sites, recreation sites, and 

rights-of-way. 

•		 To treat any vegetation as needed to control pests and diseases in State-identified quarantine areas, such as 

Sudden Oak Death in southwest Oregon. 

• To treat any vegetation to achieve habitat goals specified in approved Recovery Plans, Conservation 

Strategies, or Conservation Agreements9 for Federally Listed or Bureau Sensitive species. 

An element of all of the alternatives is the BLM’s IVM policy emphasis on prevention of noxious weeds and 

other invasive plants as the first line of defense. Under this policy, the BLM uses a variety of prevention methods 

including employee and public education, requiring weed-free seed in restoration and other revegetation projects 

(USDI 2006c), encouraging weed-free hay for use by pack stock, and cleaning project vehicles and other 

equipment before it leaves infested sites or enters uninfested sites. All BLM project proposals deemed to have a 

moderate or high risk of spreading invasive plants are required to include strategies to reduce that risk, provide for 

monitoring, and take rapid control actions if necessary. See Integrated Vegetation Management in Chapter 3 for 

additional detail. 

7 The Proposed Action is Alternative 4; see Chapter 2 for description of the alternatives. 

8 Districts west of the Cascades are Salem, Eugene, Roseburg, Coos Bay, and Medford. Districts east of the Cascades 

are Lakeview, Prineville, Burns, and Vale. 

9 Conservation Strategies and Agreements are explained in Chapter 2. 

 6 
 

Draft Environmental Impact Statement, Chapter 1: Purpose and Need 

Alternatives to the Proposed Action 

Using a broader array of herbicides would positively affect the BLM’s ability to meet its various vegetation 

management responsibilities, but could potentially expose the environment to negative effects from the herbicides 

themselves. Thus, alternatives to the proposed action seek to examine different mixes of these positive and 

negative effects by considering various numbers of herbicides and considering different mixes of management 

objectives for which these herbicides could be used. The alternatives range from no use of herbicides at all, to 

an alternative that examines the use of all 18 herbicides analyzed in the PEIS and approved for use in the other 

16 western states for all non-commodity vegetation treatment needs. Action Alternatives 3 through 5 would each 

meet the Need, and would variously meet the Purposes identified below. 

The Purposes 

The Purposes are objectives to be achieved by the proposed action and the other action alternatives. The 

Purposes include the issues identified during scoping. No alternative would meet all Purposes completely. The 

selected alternative should be the one that meets the Need and best meets the Purposes. 

1. Control invasive plant species to protect native ecosystems and the flora and fauna that depend on them. 

Although current management efforts strive to prevent the introduction of weeds and control existing infestations, 

noxious weeds continue to spread at an estimated rate of 10 to 15 percent per year on BLM lands due in part to 

limited funding and lack of effective control methods. An estimated 1.2 million acres of the 15.7 million acres 

of BLM lands in Oregon are currently infested with State-listed noxious weeds, and approximately 5 million 

more are infested with other invasive plants (mostly cheatgrass)(Appendix 7). Invasive plants crowd out native 

plants; reduce habitat and forage for wildlife (including Federally Listed and Bureau Sensitive species) and 

livestock; increase soil erosion; reduce water quality; and, alter soil chemistry and productivity. In 2009, the 

Oregon State list of noxious weeds includes 121 species (Appendix 7: Table A7-1). These are a subset of nonnative invasive plants deemed so potentially harmful that the Oregon Department of Agriculture has a program 

“to protect Oregon’s agricultural industry and natural resources by preventing and limiting the spread and impact 

of invasive exotic plant species (noxious weeds) which displace and compete with native and desirable domestic 

plant species. These invasive plants affect all Oregonians directly or indirectly through impacts on agricultural 

and forest economies and on other resources such as fish, wildlife, recreation and overall watershed health” (ODA 

2009a). 

No area of the State is immune. Noxious weeds and other invasive plants enter Wilderness Areas through 

wildlife, wild horses, livestock, wind, and on the clothing and equipment of visitors. They infest Research 

Natural Areas, Areas of Critical Environmental Concern (ACECs), and the Cascade-Siskiyou National Monument. 

Invasive plants have a direct effect on BLM programs in these areas. For example, waterfowl nesting success 

in the Warner Wetlands ACEC directly correlates with the success of dry-season perennial pepperweed control 

efforts. Restoration efforts at the West Eugene Wetlands10 are frustrated by invasive grasses. 

10 The West Eugene Wetlands comprises 3,000 acres of rare habitat, protected and restored by the West Eugene Wetlands 

Partnership, a partnership of State, Federal, and private agencies. This area is home to numerous rare and unusual 

animal species and more than 350 species of plants, some of which exist only in the Willamette Valley. This includes 

three threatened and endangered plants and one endangered animal species. 

7 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

2. Protect the safety and function of BLM and other authorized infrastructures by controlling encroaching 

vegetation. 

Human developments also create a need to manage native vegetation. Safe campground use is hampered by 

poison oak, vegetation growth along roads breaks up pavement and reduces sight distances, and vegetation 

growing into power lines, transmission towers, and other BLM-managed or authorized improvements hamper 

function and become a danger to the structures themselves. Public and private improvements bring obligations 

to provide for safe access and to protect taxpayer and cooperator investments. Currently, management of 

encroaching native vegetation on BLM lands in Oregon relies exclusively on manual, mechanical, cultural, 

and other non-herbicide control methods. These methods are often less effective and/or more costly than using 

herbicides. For example, if herbicides were available to treat cut stumps under power lines so they would not resprout, shrub species would begin to dominate the site, substantially reducing the need to do regular tree cutting 

and other vegetation control treatments. 

3. Manage native vegetation to provide sustainable habitats for wildlife, fish, and native plants, particularly 

those included in the Bureau Sensitive Species program. 

Decades of fire suppression, human uses, climate change, and other factors have altered the structure of native 

plant communities even in areas without invasive species. For example, fire suppression has resulted in a 

manyfold increase in the number of Western junipers in eastern Oregon when compared with historic levels. 

Western juniper uses soil moisture to the detriment of surrounding native plants and stream flow. Chemicals in 

the Western juniper’s dropped needles prevent many other plants from growing, resulting in increased bare ground 

and soil erosion that changes the site potential for years or decades. Even if the Western juniper is removed, the 

site may no longer support the plants that were present prior to the Western juniper expansion (Dysart et al. 2008). 

Sagebrush communities critical to the success of nesting sage grouse are being altered, reducing their value as 

nesting habitat. The use of herbicides could facilitate restoration of habitats for nesting sage grouse and other 

species. Encroachment of trees and shrubs into grassland meadows threaten Federally Listed Cook’s Lomatium. 

BLM 6840 policy and interagency Conservation Strategies and Agreements for Bureau Sensitive Species require 

the BLM to manage for sustainable habitats for Bureau Sensitive and Federally Listed species. 

4. Manage vegetation to reduce the risk that large-scale high-intensity fires will unacceptably damage 

resources and human developments. 

An unnaturally high risk of wildfire in the west is attributable to many factors, but some species of invasive plants 

have particularly exacerbated this risk. On nearly one-third of the BLM lands in Oregon today, the non-native and 

invasive annual grasses cheatgrass and medusahead have replaced or significantly encroached on native bunch 

grass plant communities (Appendix 7). Native bunchgrass communities remained relatively green throughout 

most of the summer and resisted fire. Invasive annual grasses cure earlier and burn more intensely and far more 

often than the native grasses. These fires eventually eliminate shrubs in these ecosystems. The resultant shift and 

simplification of the plant community has severely reduced the diversity of the natural flora and fauna community. 

The flammability of these altered ecosystems makes them especially hazardous in the Wildland-Urban 

Interface. Currently, the herbicides available to BLM in Oregon are not effective at controlling medusahead and 

cheatgrass,11 hampering restoration efforts and endangering human developments. 

11 Cheatgrass cannot be sprayed under current direction even if an effective herbicide were available, because it is not 

listed as a noxious weed.
 

 8 
Draft Environmental Impact Statement, Chapter 1: Purpose and Need 

5. Cooperatively control invasive plants so they do not infest or re-infest adjacent non-BLM lands. 

Neighboring landowners are negatively affected by invasive plants (including listed noxious weeds) spreading 

from BLM lands. For example, 71 percent of Malheur County is administered by the BLM. The active control 

of dozens of species of invasive and noxious plants by private landowners and County weed control personnel 

can be frustrated by seed coming from nearby uncontrolled plant populations on public lands. Productive ranches 

have been lost to invasive plants, and these losses can disrupt the viability of ranching-dependent communities. 

During scoping for this EIS, County employees, elected officials, and weed board members spoke out universally 

in favor of increased noxious weeds and other invasive plant control on BLM lands. 

Further, invasive plants are most effectively controlled by groups of landowners working in a coordinated fashion. 

Currently, County Weed Management Boards, Cooperative Weed Management Areas, Oregon Department 

of Agriculture, and others cooperate with the BLM on jointly funded integrated weed control projects. The 

effectiveness and efficiency of these projects is compromised for all concerned when the BLM cannot use the 

same tools being used by the rest of the cooperators. The problem is not just that County and State weed control 

personnel must switch to BLM-approved herbicides at the property line. Sometimes they must completely 

stop vegetation control efforts because it is often not practical to change to a different control method at each 

property line. Without the appropriate herbicides and cooperative efforts, adjacent landowners will continue to 

shoulder the burden of weed control while seed sources expand on adjacent public lands. Cooperating with other 

landowners also helps prevent the spread of weeds onto public lands. 

6. Prevent herbicide control treatments from having unacceptable adverse effects to applicators and the public, 

to desirable flora and fauna, and to soil and water. 

The use of herbicides in wildland settings is not without risk. Although many of the herbicides proposed for 

use in this EIS are less toxic than many household products, their application can put non-target plants, animals, 

applicators, and the public at risk. Additionally, there may be adverse effects to soil organisms and water. In 

general, having more herbicides available increases the likelihood of successfully controlling the target species 

while minimizing the effects to non-target plants and other species. The benefits of more options include: 1) 

reduced potential for herbicide resistance; 2) increased potential for finding an appropriate, cost-effective, sitespecific treatment; 3) more efficient application of all control methods; and, 4) use of (generally) newer, less toxic 

herbicides. These in turn lead to lower human and ecosystem risk. 

Non-herbicide treatments have risks as well. Mechanical treatments can break down soil structure, increase 

compaction, create dust, increase siltation in nearby streams, damage desirable as well as undesirable plants, and 

potentially re-create the site disturbance that facilitated the invasive plant issue in the first place. Mechanical 

methods also make noise, use fossil fuels, and raise worker safety concerns. Repeated chainsaw cutting of woody 

vegetation under power line rights-of-way, for example, can increase worker injury risk. 

7. Control plant pests and diseases by removing their native plant hosts when necessary to meet ODAidentified control objectives. 

Pests and diseases can threaten native plant species and the plant communities of which they are a part. These 

pests and diseases are most likely to take the form of insects and pathogens. If not contained, these agents can be 

spread geographically by various dispersal mechanisms as well as by human movement of plant products. Many 

of Oregon’s plants are also used by the nursery industry and transported worldwide. An uncontrolled infestation 

of a serious pest could lead to a quarantine affecting the host and related plants. When these events happen, the 

Oregon Department of Agriculture (ODA) declares it a problem and identifies control areas. Although control 

9 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

efforts typically utilize insecticides, fungicides, traps, and other non-herbicide means (which are currently 

available to BLM), sometimes control strategies include killing the host vegetation in a buffer around the pest 

population. The efficiency and success of such control can depend on herbicides. Sudden Oak Death is an 

example of such a strategy. 

Sudden Oak Death was first detected in southwest Oregon in 2001, where it was killing tanoak, and infecting 

rhododendron and evergreen huckleberry on nine sites totaling 40 acres. The ODA quarantined the area and the 

Forest Service, BLM, private forest managers, and the ODA have worked aggressively since 2001 to control this 

disease by, in part, removing host tanoak from around known infestations. This job is not as effective without 

herbicides; tanoak is a prodigious sprouter. The disease had spread to 178 acres by 2007, however specialists 

believe it can be brought under control with herbicide treatments. 

8. Minimize treatment costs and improve treatment effectiveness, so economic losses from invasive plants and 

other vegetation growth are reduced and more of the Need can be met within expected funding. 

The economic impact of invasive plants is substantial. A 2008 report prepared for the Oregon Invasive Species 

Council estimates the production losses, fire damage, and control costs for just 21 of the noxious weed species in 

Oregon to be $120 million per year, and the annual cost of invasive plants in Portland, Oregon is $10-31 million 

per year (Cusack and Harte 2008:1). A purpose is to reduce these losses. 

There are significant differences in both the cost and effectiveness of the various control methods. The 

affordability and effectiveness of hand pulling is limited to small infestations or small areas, and is only effective 

on certain species. Mobilization of heavy equipment may be more expensive than using spray equipment. 

Control of hundreds of acres of invasive grasses may be most achievable with herbicides, since ground-disturbing 

methods are often ineffective and can exacerbate the conditions that led to the problem. Finally, the use of the 

right herbicide can achieve control with one or few treatments, while some other control method may require 

annual or even multi-annual treatments. If herbicide use is avoided, it reduces the amount of control work that 

can be completed. A purpose is to improve treatment effectiveness and reduce treatments costs. There is a finite 

amount of funding available, and savings in one control area can be used in another. Often the most effective 

long-term control is a result of a combination of herbicide and non-herbicide treatments. 

Decision to be Made 

The decision to be made by the Oregon/Washington BLM State Director is whether to select the proposed action 

or another alternative, and determine if any additional mitigation or monitoring is to be applied. The decision will 

be based on the degree to which the selected alternative meets the Need and Purposes. Because of the differences 

between the alternatives, the selection will effectively determine which, if any, additional herbicides will be 

available for use by the BLM in Oregon, and what vegetation management objectives they could be used for. 

Scoping 

Scoping is the term used to identify issues, concerns, and opportunities associated with the proposed action in an 

EIS. Public involvement in the scoping process began when the Notice of Intent to prepare an Environmental 

Impact Statement (EIS) for Vegetation Treatments Using Herbicides on BLM Lands in Oregon was published 

in the Federal Register (73[121]:35408–35409) on June 23, 2008. The Notice of Intent announced this EIS 

would evaluate the effects of using up to 18 nationally approved herbicide active ingredients for treatment of 

noxious weeds; for treatment of invasive vegetation and other weeds in administrative sites, recreation sites, 

 10 
 

Draft Environmental Impact Statement, Chapter 1: Purpose and Need 

and rights-of-way; for treatment of forest pests and diseases; and to achieve non-commodity landscape health 

objectives. The Notice of Intent indicated that the EIS Team was seeking comments to help identify the relevant 

issues and environmental concerns, identify possible alternatives, and help determine the scope of this EIS. 

The Notice of Intent was also posted to the project website at www.blm.gov/or/plans/vegtreatmentseis/, and a 

press release was mailed to media outlets across the State, including print, radio, and broadcast media. At the 

same time, approximately 17,000 postcards were mailed out to individuals, groups, government agencies, and 

tribes identified from Oregon BLM district and Oregon National Forests’ “interested public” lists as potentially 

interested in this EIS. These postcards, in addition to announcing the project and asking recipients if they wished 

to be on the project mailing list, noted there would be public meetings across the State in July to solicit ideas for 

issues (identified herein as Purposes) and alternatives to consider in this EIS. 

The scoping period closed July 28, 2008. During the scoping period, the BLM held 12 public scoping meetings 

in Oregon, one at or near each of the nine BLM district Offices and in Klamath Falls, Baker City, and Portland, 

to describe the proposal and solicit ideas for issues and alternatives to be considered in this EIS. Approximately 

40 non-BLM persons attended these meetings and most contributed comments verbally. Eighty scoping “letters” 

were also received during or shortly after the scoping period via letters, postcards, email, phone calls, and via the 

comment page on the project website. These letters helped the BLM define the alternatives to be considered and 

the eight Purposes to be addressed in this EIS and used by the decision-maker. 

In addition to scoping comments, the BLM received postcards or emails from 1,200 persons or groups asking to 

be on the project mailing list. Nine agencies, including the Oregon Department of Agriculture and the Bonneville 

Power Administration, received written and phone invitations to be formal cooperators with the BLM in the 

preparation of this EIS. Although they were supportive of the proposed action, all declined. In addition, 13 

American Indian Tribes received letters explaining the project and the potential for effects to significant gathering 

areas and other resources, and extending an invitation to initiate government-to-government consultation. 

Follow-up phone calls to these tribal governments were made by the BLM districts reiterating these messages (see 

the Cultural and Paleontological Resources section in Chapter 4 for more detail about Tribes). 

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, and identified management practices to 

minimize impacts to these species and habitats. 

The FWS issued a Letter of Concurrence on September 1, 2006 that concurred that the proposed action as 

described in the PEIS and Biological Assessment, with all SOPs and PEIS Mitigation 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-specific 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 was not likely to jeopardize the continued existence of endangered and 

11 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

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 take12 identified or exempted by the Biological 

Opinion. 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 herbicide action alternatives in this EIS are the same as, or 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 species in Oregon and a list of the Bureau Sensitive species in Oregon are 

included in Appendix 5. Informal consultation with the FWS (50 CFR 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. 

Government and/or decision makers of the American Indian tribes were sent a scoping letter (Appendix A) 

seeking their input and offering the opportunity for formal government-to-government consultation for the 

preparation of this EIS. The Bureau of Indian Affairs also received the tribal scoping letter. In total 13 tribal 

scoping letters were sent and personal contact was pursued with each tribe. 

For the PEIS, the BLM consulted with the affected State Historic Preservation Offices (SHPOs) as part of Section 

106 consultation under the National Historic Preservation Act to determine how proposed vegetation treatment 

actions could impact cultural resources. Formal consultations with the Oregon SHPO and potentially affected 

Indian tribes also may be required during implementation of projects at the local level. 

Related Plans and Analyses 

Other NEPA documents integral to this EIS are described below. In addition, over 6,000 pages of detailed 

risk assessments have been prepared to evaluate the ecological and human risk for wildland use of each of 

the 18 herbicides addressed in this EIS. These risk assessments are adopted from the PEIS, the 2005 Forest 

Service Pacific Northwest Region Invasive Plant Program EIS (USDA 2005), and the 1991 FEIS for Vegetation 

Management on BLM Lands in Thirteen Western States (USDI 1991). These risk assessments are in Appendix 8 

and are further described in Chapter 3. 

2007 National PEIS 

This EIS tiers to the June 2007 Final Vegetation Treatments Using Herbicides on BLM lands in 17 Western States 

Programmatic Environmental Impact Statement (PEIS) and its September 29, 2007 Record of Decision. The 

PEIS and its Record of Decision apply to Oregon, but implementation is limited by the current U.S. District Court 

injunction. The analysis in the PEIS is fully incorporated into this EIS as Appendix 1, and major conclusions of 

that analysis are incorporated by reference (and often brought forward into the body of this EIS, particularly in 

Chapter 4, for easier reference by the reader and the decision-maker). 

12 ‘‘take’’ means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any 

such conduct. 

 12 
Draft Environmental Impact Statement, Chapter 1: Purpose and Need 

Resource Management Plans 

The public lands within the nine BLM districts in Oregon are covered by 18 Resource Management Plans (RMPs) 

and accompanying environmental impact statements. The RMPs contain direction for allocated uses, protection 

for resource values, and objectives for vegetation management. The RMPs acknowledge the problem of noxious 

weeds and contain objectives for their control (Appendix 6). However, they are not prescriptive with regards to 

control methods, tools, seasons, or other treatment parameters. The alternatives in this EIS address the herbicide 

component of these control activities. None of the alternatives in this EIS would amend any of the RMPs; they 

would only provide options to conduct activities already covered by the RMPs (Appendix 6). 

In addition to direction to control noxious weeds, RMPs contain direction for, or otherwise assume, the 

management of vegetation to control hazardous fuels; improve or maintain habitat, riparian areas, and visual 

resources; maintain rights-of-way and other infrastructure; and, to meet other objectives13. Methods described 

and/or assumed to be used to accomplish this direction include: prescribed and wildland fire for resource benefits; 

manual treatments such as grubbing or pulling; mechanical treatments such as disking, chopping, cutting, and 

blading; biological controls including directed livestock grazing and insects or pathogens; and, (in general) the use 

of herbicides. These non-herbicide methods are included in the analysis in this EIS only to the extent necessary 

to display the relative environmental differences between the proposed additional use of herbicides and the 

alternative methods currently being used. A detailed examination of non-herbicide methods is in the June 2007 

Final Vegetation Treatments on BLM Lands in 17 Western States Programmatic Environmental Report (PER), 

available on the EIS website at http://www.blm.gov/or/plans/vegtreatmentseis/. 

Seed Orchards 

In 2005, the BLM completed three Integrated Pest Management EISs covering the Tyrrell Seed Orchard on the 

Eugene District, the Horning Seed Orchard on the Salem District, and the Provolt and Sprague Seed Orchards 

on the Medford District. Those EISs propose to use several herbicides in the management of the seed orchards, 

and those EISs included detailed analyses of that proposed use, including environmental and human health risk 

assessments. Records of Decision were signed in December 2005 and February 2006. Those Records of Decision 

approved use of those herbicides pending the lifting of the 1984/87 District Court injunction. 

The herbicide use proposed by the Seed Orchard decisions is included in this EIS as part of the administrative 

site treatment acres in Alternatives 4 and 5, and the environmental effects predicted in the Seed Orchard EISs are 

included in the cumulative effects discussions in Chapter 4 of this EIS. Any meaningful differences between the 

Seed Orchard analyses and this EIS are identified in this EIS, and the Seed Orchard Records of Decision will be 

either confirmed or modified by the Record of Decision for this EIS. 

Additional herbicides made available to the BLM in Oregon by the Record of Decision for this EIS would also be 

available to the seed orchards (pending district or site-specific analysis). 

Existing and Future Project-Level Planning 

Each district has completed one or more Environmental Assessment (EA) documents describing their noxious 

weed control program. These documents are generally tiered to the 1985 Northwest Area Noxious Weed 

13 RMPs also address vegetation management for commodity production such as livestock forage production 

or timber volume growth, but the BLM is choosing not to address projects conducted specifically for 

commodity production in this EIS. 

13 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Control Program EIS and its 1987 Supplement, either directly or indirectly through their respective Resource 

Management Plans. The existing EAs for Prineville, Lakeview, and Burns also specifically tier to analysis within 

the 1991 Vegetation Treatment on BLM Lands in Thirteen Western States EIS. EA treatment plans are updated 

annually to reflect the shifting nature of noxious weed populations and the control efforts needed to contain them. 

These assessments are assumed to remain valid until superseded by analysis tiered to this EIS and its Record of 

Decision. 

This is a programmatic EIS for using herbicides as part of the non-commodity vegetation management program 

on public lands administered by the BLM in Oregon, and is intended to be applicable for approximately 10 to 

20 years. To implement the resultant decision at the project level, new site-specific environmental analyses and 

documentation tiered to this and other applicable EISs will be completed by each district. Until those site-specific 

assessments are completed, vegetation management including the use of 2,4-D, dicamba, glyphosate, or picloram, 

for noxious weed control will be governed by the existing district EAs and decision records and the documents to 

which they tier. 

 14 
15 

 

 

 

 

 

Chapter 2 

The Alternatives 

Introduction 

This Chapter presents the no action and four action alternatives. In addition to an action alternative with no 

herbicide use, the three herbicide action alternatives would: a) make varying numbers of additional herbicides1 

available as part of the BLM’s existing vegetation management program for noxious weeds, invasive plants, 

and other vegetation, and b) make those herbicides available for meeting various non-commodity vegetation 

management objectives. These action alternatives would only add herbicides to various non-herbicide 

treatment methods2 already being used in the existing integrated vegetation management programs.3 This EIS 

only identifies and analyzes non-herbicide treatments to the extent necessary to understand the trade-offs and 

cumulative effects of the proposal to add herbicides to the existing program. 

The alternatives in this EIS would only make the herbicides available for BLM district consideration. The 

alternatives do not address any site-specific proposal, and no project would go forward without additional 

site-specific analysis and decision record. However, future herbicide use levels have been estimated for each 

alternative and are presented as assumptions in Chapter 3 for effects analysis. 

Elements Common to All Alternatives 

Applicable Lands 

The alternatives in this EIS would apply to public lands administered by BLM in Oregon. They would apply 

to the BLM and to permittees, lessees, cooperators, or applicants for temporary or long-term use permits on 

these lands. 

1 The term “herbicide” is used in this EIS to mean active ingredient (a.i.), and not trade name or formulation. 

2 Currently used non-herbicide vegetation treatment methods include (but are not limited to) mechanical (e.g. mowing, 

blading, or chainsaws), manual (e.g. pulling or grubbing), fire, bio-controls (e.g. released insects or pathogens), directed 

livestock, and seeding or planting for weed control.
 

3 See Chapter 3 for complete description of integrated vegetation management (IVM) and treatment methods.
 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Legal and Policy Requirements 

Federal, State, and local laws, BLM policy, resource management plans, and all herbicide label requirements 

will be adhered to. Herbicides may be used only for the objectives and type of vegetation for which they are 

registered, as displayed on the herbicide label. The herbicides must be registered with the EPA and the State 

of Oregon. Although there are over 100 different herbicide active ingredients registered in Oregon under more 

than a thousand different trade names or formulations, the 18 herbicide active ingredients (herbicides) addressed 

in this EIS are limited to the active ingredients and formulations (brands) approved (listed for use) by the BLM 

Washington Office. Herbicides may be applied only by BLM and/or State certified pesticide applicators4

. BLM 

has a policy against using petroleum-based adjuvants (including surfactants) or other additives. 

Standard Operating Procedures 

A variety of standard operating procedures (SOPs) for herbicide use were adopted by the Record of Decision 

for the PEIS for use in the 17 western states. Those SOPs, with minor edits for clarity, are displayed in 

Appendix 2 and are made a part of all alternatives. SOPs reduce or avoid adverse effects to environmental and 

human resources from vegetation treatment activities. They are based on guidance found 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 should be considered when designing and implementing 

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

application of the SOPs unless a site-specific determination is made that their application is unnecessary to 

achieve their intended purpose or protection, or unless the parent handbook or policy direction evolves and the 

new direction would continue to provide the appropriate environmental protections. 

Mitigation Measures Adopted by the Record of Decision for the PEIS 

As with the SOPs, a variety of mitigation measures for herbicide use were adopted by the Record of Decision for 

the PEIS for use in the 17 western states. They are displayed, with minor edits for clarity, in Appendix 2 and are 

made part of all alternatives. They are generally referred to herein as PEIS Mitigation Measures to separate them 

from the potential mitigation identified at the end of some of the resources sections in Chapter 4 and summarized 

as Potential Mitigation at the end of this Chapter. Like the SOPs, application of the PEIS Mitigation Measures 

is assumed in the analysis. However, for PEIS Mitigation Measures, site-specific analysis, the use of ecological 

risk assessment worksheets, 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. 

The Alternatives 

The alternatives provide a range of both the number of herbicides to be available for use, and the areas/treatment 

objectives that they can be used for. They range from Alternative 1, which would permit no use of herbicides, 

to Alternative 5, which would permit the use of the 18 herbicides selected for use by the BLM nationally, and 

permit them to be used to achieve nearly any management objective except enhancing commodity production 

such as timber growth or livestock forage. Each alternative adds herbicides or uses when compared to the one 

preceding it. For example, all uses and herbicides permitted under Alternative 2 are included in Alternative 3, but 

Alternative 3 adds additional herbicides as well as the types of plants that may be treated. Similarly, all treatments 

4 Non-motorized application of non-restricted herbicides may be done by uncertified personnel if they are working under 

the supervision of a certified applicator. 

16 
 

Draft Environmental Impact Statement, Chapter 2: The Alternatives 

and herbicides included in Alternative 

3 are available in Alternative 4, 

but Alternative 4 adds additional 

treatment objectives when compared 

to Alternative 3. This “adding” effect 

is shown graphically in Table 2-1, 

along with the acres of herbicide 

use estimated for each alternative 

and types of plants and management 

objective they apply to. All alternatives 

exclude herbicide use specifically for 

commodity production, and Alternatives 

3 and 4 do not permit aerial application 

west of the Cascades. 

Terminology: 

Invasive plants (or weeds) are non-native aggressive plants with the 

potential to cause significant damage to native ecosystems and/or cause 

significant economic losses. 

Noxious weeds are a subset of invasive plants that are county, state, 

or federally listed as injurious to public health, agriculture, recreation, 

wildlife, or any public or private property. 

Vegetation includes noxious weeds, invasive weeds, and introduced and 

native plants. 

Native vegetation includes native and desirable non-native plants. 

Table 2-1. esTimaTed annUal1 Herbicide TreaTmenT acres2 by alTernaTive and TreaTmenT objecTive. 

Alt . 1 Alt . 2 Alt . 3 Alt . 4 Alt . 5 

Plant type Treatment Objective (No (4 (11/13 (12/16 (18 

herbicides) Herbicides) Herbicides) Herbicides) Herbicides) 

Noxious / Noxious Weeds 0 17,000 acres 

30,000 

45,000 50,000 

Invasive only Invasive Plants 0 0 

All others 

(natives and 

non-invasive 

non-natives) 

Pest and Disease Control 0 0 

ROW, admin, and recreation 0 0 0 

Habitat in Conservation 

Plans 0 0 0 

All other treatments 0 0 0 0 

1 These estimated annual acres are an average. For example, a 5,000 acres treatment that occurs once every 5 years would be displayed as 

1000 acres per year. 

2 Acres are “treatment unit” acres. However, almost all invasive weed treatments are “spot” treatments, with most spraying focused on 

individual plants. One hundred acre units with 1⁄2 acre of actual treatments are common. See Chapter 3 for more information. 

The No Action Alternative 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Continue to use only four herbicides (2,4-D, dicamba, glyphosate, and picloram; Table 2-2), and these only 

for State, Federal, or County-listed noxious weeds. 5 Use only non-herbicide methods for the management of 

(non-noxious) invasive plants and other vegetation. Aerial application would be permitted west and east of the 

Cascades. 

This alternative is presented for comparison purposes, and is not expected to meet the Need. 

The number of herbicides (four) and what they can be applied to (noxious weeds) is limited by the 1984/87 injunction. 

A June 19, 2009 court order slightly modified the injunction for 2009-2011 (see footnote in Chapter 1). 

17 

5 
 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The Action Alternatives 

Alternative 1 – No Herbicide Use 

Manage vegetation with non-herbicide methods. Non-herbicide methods include, but are not limited to, fire, 

manual, mechanical, State-approved biological control agents, directed livestock grazing, and seeding and 

planting for control of invasive vegetation. 

This alternative would not meet the Need, but is included here for the following reasons: 1) for comparison 

purposes; 2) it was suggested by numerous scoping comments; and, 3) because it is conceivable for a variety of 

legal, social, or effects reasons that it might be selected, at least in localized areas. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control 

Pests and Diseases 

Make available 11 herbicides west of the Cascades (2,4-D, clopyralid, dicamba, fluridone, glyphosate, 

hexazinone, imazapic, imazapyr, metsulfuron methyl, picloram, and triclopyr) and 13 herbicides east of the 

Cascades6

 (chlorsulfuron, sulfometuron methyl, and the 11 herbicides available west of the Cascades; Table 2-2): 

•		 To treat noxious weeds and other invasive plants as necessary to meet non-commodity IVM objectives; 

and, 

•		 To treat any vegetation, as necessary, to control pests and diseases in State-identified control areas, such as 

the one for Sudden Oak Death7

 in southwest Oregon. 

No aerial application would be permitted west of the Cascades. 

Alternative 3 Treatment Examples 

• Treatment of cheatgrass (invasive) to reduce fire risk within the Wildland-Urban Interface or to create “green” 

fuel break zones by restoring areas to perennial, more fire-resistant native or desirable non-native species. 

•		 Treatment of spotted knapweed (noxious) to improve the forage and cover for deer in their winter range. 

•		 Treatment of tanoak as needed to control Sudden Oak Death in southwest Oregon. 

•		 Treatment of medusahead (noxious) to facilitate burned area rehabilitation. 

•		 Treatment of gorse (noxious) on roadsides. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive 

Weeds plus Limited Additional Uses 

Make available 12 herbicides west of the Cascades (2,4-D, clopyralid, dicamba, diuron, fluridone, glyphosate, hexazinone, 

imazapic, imazapyr, metsulfuron methyl, picloram, and triclopyr) and 16 herbicides east of the Cascades (bromacil, 

chlorsulfuron, sulfometuron methyl, tebuthiuron, and the 12 herbicides available west of the Cascades; Table 2-2): 

6 Based on district-identified need. See the Differences in the Number of Herbicides Proposed East and West of the Cascades 

in Chapter 3. Herbicide information is on Table 3-1 in Chapter 3. District boundaries are used to separate east and west. The 

Lakeview-Medford district boundary only nominally follows the Cascade crest but these districts are wholly considered east and west 

respectively, for the purposes of the herbicide numbers and analysis in this EIS. 

7 Sudden Oak Death is the only currently known example of a treatment that would be proposed under this clause. 

18 
 

 

Draft Environmental Impact Statement, Chapter 2: The Alternatives 

• To treat noxious weeds and other invasive plants as necessary to meet non-commodity IVM objectives. 

• To treat any vegetation as needed to control pests and diseases in State-identified control areas, such as 

Sudden Oak Death in southwest Oregon. 

•		 To treat any vegetation to meet safety and operation objectives in administrative sites, recreation sites, and 

rights-of-way. 

•		 To treat any vegetation to achieve habitat goals specified in approved Recovery Plans, Conservation 

Strategies, or Conservation Agreements (collectively referred to as Conservation Strategies) for Federally 

Listed8

 or Bureau Sensitive species. 

No aerial application would be permitted west of the Cascades. 

Administrative sites, recreation sites, and rights-of-way include: 

•		 Linear utility transmission systems, including 

multi-purpose corridors; 

•		 BLM and other authorized road or railroad 

rights-of-way; 

•		 Oil and gas production or gas storage 

agreement areas and facilities;
 

•		 Geothermal, wind, or solar energy production 

areas and facilities; 

•		 Pumped storage hydro-power production areas 

and facilities9

; 

•		 BLM authorized common-material or rock 

quarry pits and storage areas (although most 

vegetation management at such sites is for 

invasive plant control) ; 

•		 Federal, State, local or tribal designated fire 

suppression equipment sites and staging areas 

including helispots; 

•		 Cell phone, microwave, and other 

transmission sites;
 

Conservation Strategies and Conservation Agreements: 

•		 BLM seed orchards and progeny test sites; 

•		 Public purpose lease areas, including 

airstrips, schools, parks, etc. ; 

•		 Interagency special management areas 

(e.g. reservoirs, military training, etc.); 

•		 Watchable Wildlife, Adventures in 

the Past, Wild Horse Herd Viewing, 

Outstanding Natural Areas and other 

BLM designated interpretive sites; 

•		 BLM offices, fire stations, and other 

facilities; 

•		 Developed campgrounds, picnic areas, 

trails, overlooks, OHV staging or parking 

areas, hang-gliding areas and boat 

facilities; and, 

•		 Other administrative and operational 

sites needed for wildfire suppression, law 

enforcement, search and rescue, inventory, 

research, resource monitoring or other 

authorized administrative uses. 

Current language at http://www.fs.fed.us/r6/sfpnw/issssp/ describes these two documents as show here. This 

language could be updated, but the types of species included are not expected to change materially. 

Conservation Strategies capture and condense all of the known information about the biology and ecology of a 

species including taxonomy, range, distribution, and habitat descriptions. They often identify important inventory, 

research, and monitoring information that may be relevant for further understanding of the species or for adaptive 

management purposes. They also provide information on how and when to manage a site. Strategies address 

8 Federally Listed means designated as threatened or endangered under the Endangered Species Act. 

9 As of July 2009, there are no approved wind, solar or pumped storage facilities on Oregon BLM lands, but such projects 

might be developed in the future. A project on the Baker Resource Area is under consideration. 

19 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

how to manage the species and/or habitat to maintain viability or persistence of the species. They describe 

how individual sites/populations should be managed, and can also identify which sites/populations are needed 

to meet the viability, persistence, or conservation goal for the species. These documents typically cover either 

a significant portion or the entire range of the species, and may be created by one field unit, one agency, or be 

interagency in nature, but agreed upon by all administrative units the Strategy covers. Conservation Strategies 

should be coordinated with BLM State/Forest Service Regional Office planning and conservation leads. 

Conservation Agreements outline procedural assurance necessary to reduce, eliminate, or mitigate specific threats. 

Agreements are usually Memorandums of Understanding agreed upon by Federal agencies (Forest Service, BLM, 

FWS, or NOAA Fisheries) and may include States and private entities. They are typically broad-scale, giving 

general guidance on how to manage for a species. The objective of Conservation Agreements is to identify 

management that will avoid a trend towards listing under the Endangered Species Act. Agreements are typically 

voluntary non-binding documents that may be cancelled at any time. 

Alternative 4 Treatment Examples: 

Consistent with IVM and other priority setting tools, and in addition to treatments permitted under Alternative 3, 

treatments under this alternative could include: 

•		 Control of alder encroaching on power lines. 

•		 Treating poison oak, poison ivy, stinging nettles, or other plants that create an unacceptable human risk in 

recreation sites such as campgrounds (normally when campgrounds are closed or access to treated areas is 

restricted). 

•		 Treatment of native sagebrush to improve sage grouse nesting/roosting habitat. 

•		 Removing Western juniper to make more water available to other native vegetation, natural wet areas 

and springs, and stream-flow in support of listed fish, when needed to meet habitat goals specified 

in an approved Recovery Plan, Conservation Strategy, or Conservation Agreement for a Threatened, 

Endangered, or Bureau Sensitive species. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet NonCommodity Vegetation Management Objectives 

Make available 18 herbicide active ingredients both east and west of the Cascades (Table 2-2) for the full range 

of non-commodity objectives and uses approved nationally in the Record of Decision for the PEIS and currently 

available for implementation on BLM lands in the 16 other western states. These uses must be permitted by the 

product label and be consistent with the product’s Oregon registration. Aerial application would be permitted 

west and east of the Cascades. 

Alternative 5 Treatment Examples: 

Consistent with IVM and other priority setting tools, and in addition to treatments permitted under Alternatives 3 

and 4, treatments under this alternative could include: 

•		 Wildland-urban interface community protection vegetation treatments that are designed to reduce the risk 

of wildfire to the community and/or its infrastructure developed collaboratively with the community. 

•		 Treatments of any vegetation as needed to restore or maintain healthy, diverse, resilient, and productive 

native plant communities. 

•		 Treatments to improve habitat for fish and wildlife. 

 20 
 

Draft Environmental Impact Statement, Chapter 2: The Alternatives 

Table 2-2. Herbicides available Under eacH alTernaTive. 

Herbicide Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 

Herbicides Currently Approved for use on BLM Lands in Oregon (for noxious weed control only) 

2, 4-D √ √ √ √ 

Dicamba √ √ √ √ 

Glyphosate √ √ √ √ 

Picloram √ √ √ √ 

Additional Herbicides Proposed for Use in One or More of the Alternatives 

Bromacil √ (E1

) √ 

Chlorsulfuron √ (E) √ (E) √ 

Clopyralid √ √ √ 

Diflufenzopyr + Dicamba √ 

Diquat √ 

Diuron √ √ 

Fluridone √ √ √ 

Hexazinone √ √ √ 

Imazapic √ √ √ 

Imazapyr √ √ √ 

Metsulfuron methyl √ √ √ 

Sulfometuron methyl √ (E) √ (E) √ 

Tebuthiuron √ (E) √ 

Triclopyr √ √ √ 

1

 Only allowed in BLM Districts east of the Cascades 

Formulations are limited to those on the BLM national list of approved herbicides. 

See The 18 Herbicides section and Table 3-1 in Chapter 3 for further information about these 18 herbicides 

Alternatives Eliminated From Detailed Study 

No Use of Acetolactate Synthase (ALS)-inhibiting Herbicides 

This alternative was suggested during scoping for this EIS. ALS-inhibitors10 work by inhibiting the enzyme 

acetolactate synthetase (ALS), resulting in inadequate supplies of the branched chain amino acids (leucine, 

isoleucine and valine). The alternative may have been suggested in part because a BLM application of 

metsulfuron methyl on a burned area in Idaho was implicated in widespread damage to adjacent private croplands 

following a dust storm (see Cumulative Effects section in Chapter 4). SOPs designed to prevent such an event are 

included in this EIS. 

An alternative with no use of ALS-inhibitors was analyzed in the PEIS, which is incorporated into this EIS as 

Appendix 1. It was not selected because these herbicides are potentially less harmful to plants, animals, and 

10 Chlorsulfuron, metsulfuron methyl, sulfometuron methyl, imazapic, and imazapyr. 

21 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

humans than other herbicide active ingredients proposed. In addition, the BLM would lose the ability to effective 

control such aggressive species as perennial pepperweed and hoary cress, and to a lesser extent saltcedar, as well 

as cheatgrass (PEIS ROD:4-11). 

ALS-inhibiting herbicides are, as a group, the least toxic herbicides to the environment and human health 

evaluated in this EIS, and some of the most problematic invasive weeds are best and most safely controlled with 

these herbicides. For example, such control would require using imazapic once, versus multiple applications 

of picloram for leafy spurge control; multiple applications of 2,4-D or triclopyr versus single applications 

of imazapyr for foliar saltcedar control; and, multiple applications of 2,4-D or dicamba versus imazapic or 

metsulfuron for perennial mustard control (PEIS: Appendix I). Excluding these five herbicides would not meet 

the Need and Purposes because of the number of weeds for which there would be no effective control, and lead to 

the use of some herbicides with higher risks to humans and/or the environment. 

No Aerial Application of Herbicides 

This alternative seeks to reduce the likelihood of inadvertent application to riparian and other non-target areas, 

and reduce risk. This alternative was considered in the PEIS and rejected because large expanses of cheatgrass 

and other weeds in remote areas or areas with rugged terrain would be difficult and cost-prohibitive to treat. Also 

using ground-based methods in rugged terrain would increase injury and herbicide exposure risks for workers 

(PEIS ROD:4-11). That said, Alternatives 3 and 4 prohibit aerial application west of the Cascades because the 

high density of streams, seeps, and other water bodies, coupled with dense vegetation, can make water difficult 

to avoid. Steep varied terrain coupled with tall vegetation (including dead trees) can force pilots to fly relatively 

high, increasing the risk of drift to water, non-target plants, and other non-target areas. Checkerboard and other 

land ownership patterns, some related to the far higher population density west of the Cascades, also tend to make 

aerial application more difficult. 

Reduce Ground-Disturbing Activities 

During scoping, several comment letters suggested that the ground disturbance created by various BLM 

management activities including Off Highway Vehicle (OHV) use and grazing were major causes of invasive 

plant spread and thus should be curtailed. All NEPA planning processes for ground disturbing projects and 

projects that have the potential to alter plant communities must include an assessment of the risk of introducing 

noxious weeds and other invasive plants. If the analysis determines there is a moderate or high risk of spread, 

the project planning must include a noxious weed risk assessment that identifies the actions managers will take 

to reduce or prevent the spread of noxious weeds, and describe the conduct of monitoring follow-up actions that 

would prevent noxious weed establishment on previously uninfested sites (USDI 1992b). The risk of various 

management activities affecting weed spread has been addressed in various higher-level analyses as well. 

While all management activities should be conducted in ways that minimize or at least balance and display the 

likelihood of environmental harm, cessation of management of activities because they have been implicated 

in weed spread is often not practical. A wide variety of management activities including grazing, timber 

harvest, mining, and public recreation are mandated by FLPMA, the O&C Act, and other policy and direction. 

Management activities are not always adverse with respect to noxious weed spread. It is in the interest of persons 

holding grazing permits, for example, to help manage their allotments to prevent their degradation by noxious 

weeds. Early-season grazing of cheatgrass can retain soil moisture and help maintain native vegetation. A 

determination of the relative contribution of all BLM land uses to the introduction and spread of noxious weeds is 

beyond the scope of this analysis, the thus the EIS does not suggest reconsideration of the level of timber harvest, 

grazing, OHV use, and other uses of BLM lands because they are implicated in invasive weed spread. 

 22 
Draft Environmental Impact Statement, Chapter 2: The Alternatives 

Use Vinegar, Salt, and other Household Products 

This alternative was suggested during scoping. There are one or more EPA-registered herbicide formulations 

that have vinegar as the active ingredient, but they are not registered with the State of Oregon, and/or they are 

not included on BLM’s list of herbicides approved for use on BLM wildlands. The limited number of registered 

target plants, lack of widespread use on non-BLM lands, and relatively little experience with environmental 

effects precludes the BLM from investing in the risk assessment process for these herbicides. The process for 

proposing, analyzing, and adopting additional herbicides is outlines in Appendix 4, and a vinegar herbicide could 

be considered in the future. 

Some other household products were not considered because Oregon State Law prohibits the use of any material 

to control, kill, limit, or repel plants or animals unless it is registered with the State as a pesticide and such use 

is consistent with the label. Certain household materials are registered pesticides. For example, Clorox Ultra is 

registered for killing the oospores of the root disease Phythophthora lateralis (Port-Orford-cedar root disease), 

and borax is registered for use on tree stumps to prevent the root disease Fomes annosus. Registration and 

rigorous analysis is required; being a food or household product is not necessarily evidence it would not have 

unacceptable adverse environmental effects. Salt, for example, is more toxic to the parts of the environment and 

to human health than some of the herbicides included the herbicide action alternatives. 

Increase Use of Non-Herbicide Methods 

This alternative proposes to meet the underlying Need for more effective vegetation control measures by 

increasing the use of non-herbicide methods such as using volunteers and hiring hand crews. This alternative 

was not considered in detail because it would not meet the Need. Reasons for this include: all effective known 

non-herbicide methods are already available to the BLM in Oregon and are being used wherever practical; some 

plant species (such as Canada Thistle and Gorse) are not effectively controlled without herbicides because small 

root parts re-sprout readily; because non-herbicide methods have site impacts such as soil disturbance and damage 

to non-target species; and, most manual treatments are expensive, and thus decrease the total work that can be 

accomplished with available funding. 

Increase Funding to Pay for Additional Control Treatments 

This alternative would accomplish the vegetation management objectives by increasing funding to pay for 

vegetation treatments with existing methods. This alternative is not considered in detail because of adverse 

environmental effects associated with the existing control methods (when compared to the herbicide action 

alternatives); because acquisition of the needed increased funding is unlikely and outside the scope of the 

analysis; and, because annual government funding fluctuations affect annual programs of work. Nothing in the 

EIS precludes the BLM from pursuing and receiving increased funding for weed control (although herbicide use 

significantly above that estimated in this analysis might require re-evaluation). The herbicide alternatives in this 

EIS would simply make additional herbicides available for district consideration and use, but would not dictate 

that use or set any minimum herbicide application acres. 

Consider the Use of Different Herbicides Other than the 18 Being Considered 

This alternative would use some of the more than 100 herbicide active ingredients registered for use in Oregon 

in more than 1,000 product formulations. This alternative was not considered because herbicides used on 

BLM lands must be approved by the BLM Washington Office, and must, by policy, be subject to detailed 

23 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

environmental and human risk assessments for wildland applications. Neither the BLM nor the EPA considers 

the EPA registration process adequate for predicting all environmental harm in wildland uses. The 18 being 

considered in this EIS are those for which the Forest Service or BLM have current risk assessments, and that 

have been analyzed in the PEIS and deemed appropriate for BLM use by the Assistant Secretary, Land and 

Mineral Management, Department of the Interior (Record of Decision for the PEIS). The process for proposing, 

evaluating, and adding additional herbicides to those approved by BLM nationally is described in Appendix 4. 

Because of the high cost of the risk assessment process, selection of ones to add includes a determination of broad 

or high-priority need. 

Comparison of the Effects of the Alternatives 

Introduction 

The following discussion summarizes the environmental consequences disclosed in detail in Chapter 4. The 

environmental consequences of the five alternatives vary because of differences in the number of herbicides 

available, the types of management activities they can be used for, and the number of acres expected to be 

managed using different methods and different herbicides. 

Herbicides can be uniquely hazardous, so particular attention has been given to analyzing the potential for adverse 

effects (risk) of each herbicide. Over six thousand pages of environmental and human risk assessments have 

been prepared (Appendix 8), and results have been synthesized into risk ratings for various scenarios representing 

possible exposures from BLM applications. “High,” “moderate,” and “low” risk ratings for each herbicide for 

various species including humans are the synthesized result of those analyses (see Chapter 3, Risk Assessments), 

and these risk ratings are displayed in the tables at the end of Chapter 3. Where these ratings are higher than 

“none,” ratings guided the development of SOPs and PEIS Mitigation Measures (Appendix 2) designed to keep 

actual exposures below what would potentially result in significant adverse effects. 

With implementation of the SOPs and PEIS Mitigation Measures, the herbicides present little risk to BLM 

wildlands in Oregon. The 18 herbicides included in this analysis are those selected and approved by the BLM 

nationally from among hundreds available, as those having the least risk to humans and the environment while 

being able to accomplish the BLM’s non-commodity vegetation management objectives. Nevertheless, the BLM 

does not want to apply herbicides without good reason. Thus, the analysis examines two other effects related to 

differences between the alternatives, the potential for adverse environmental and human health effects for using 

non-herbicide methods, and the effects of the projected spread of noxious weeds. 

To support the effects determinations, the acres to be treated with each herbicide, and with each non-herbicide 

method, were estimated for each alternative. Weed and other vegetation management specialists from the Oregon 

State Office and the nine district offices in Oregon estimated annual treatment levels for the next 10 to 20 years 

assuming current budget trends. Those totals are displayed for west and east of the Cascades (Table 3-3 in 

Chapter 3). To support effects determinations regarding the spread of noxious weeds, the analysis also estimated 

the current spread rate for noxious weeds, and determined how the different alternatives might be expected to 

change that rate. Differences are expressed as percent annual spread and total acres infested in 15 years. 

The analysis indicates that although there are some increased environmental risks associated with increases in 

the use of herbicides (substantially limited by the SOPs and PEIS Mitigation Measures), slowing the spread of 

noxious weeds more than compensates for those risks. Also having more herbicides available for use would 

increase the options for selecting the most appropriate treatment to accomplish the weed control objective while 

minimizing risk to human health and nearby non-target resources including soil and water. 

 24 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Draft Environmental Impact Statement, Chapter 2: The Alternatives 

Noxious Weed Spread and the Adverse Effects of Weeds 

The list of adverse effects of noxious weeds and other invasive plants is long and varied. For example, they 

displace native species and modify the ecosystems that depend upon them. Many lack fibrous root systems or 

adequate foliage cover so they do not protect soils from rain splash or overland flow. Many have allelopathic 

effects. Many are poisonous to wildlife, livestock, wild horses, and burros. Some invade stream banks but do 

not hold the soils, increasing siltation of spawning gravels and reducing water quality. They displace riparian 

vegetation, reducing stream shading and the deposition of microfauna and detritus into streams to support the 

food chain. They act as barriers, limiting human and wildlife passage. The invasive annual grasses increase fire 

occurrence and intensity, removing sagebrush plant communities. They make rangeland unusable, displacing 

grazing and destroying ranches. They clog waterways and shade out native aquatic vegetation. 

Noxious weeds have infested an estimated 1.2 million of the 15.7 million acres of BLM lands in Oregon, and are 

spreading at an estimated rate of 12 percent, or 144,000 acres, per year. (Another 5 million acres are infested with 

cheatgrass, an invasive weed not listed as noxious.) At this rate, noxious weeds will infest about 1/3 of the BLM 

lands in Oregon in 15 years (see Appendix 7). 

Under the No Action Alternative, Alternative 2, herbicide and non-herbicide methods can be effective on all but about 

a dozen of the 121 ODA-listed noxious weeds in Oregon (Appendix 7: Table A7-1). Treatments under this alternative 

are estimated to be 60 percent effective; that is, they control the treated weed so it does not require retreatment an 

estimated 60 percent of the time. This means 45,000 acres of annual treatments translates to 27,300 acres where the 

weed is controlled and will not spread. Since these treatments focus on new satellite populations, new weeds, newly 

infested drainages, or the edges of expanding populations where weed spread would be exponential, 27,300 acres of 

control translates to 273,000 fewer infested acres in 15 years (Denton 2009; Appendix 7). 

Effective control is estimated at 30 percent for Alternative 1, where non-herbicide methods are only effective 

against about one-third of the noxious weeds. Alternative 3 includes effective controls for all but one of the noxious 

weeds; effectiveness is estimated at 80 percent. Finally, it is estimated that the 9,300 acres of native vegetation 

control in rights-of-way, administrative sites, and recreation sites in Alternatives 4 and 5 would control or avoid 

spreading undetected noxious weeds on 25 percent of those treatments, or 2,350 acres per year. This gain includes 

consideration that roads serve as weed vectors, and recreation sites serve as gathering places for OHVs and other 

recreational vehicles and equipment that can potentially spread weeds in all parts of the State. Applying these 

calculations to each of the five alternatives results in the following 15-year weed spread parameters (Table 2-3). 

Given the “current budget trends” assumption and the entrenchment of some of the State’s noxious weeds like 

Himalayan blackberry, yellow starthistle, Canada thistle, quackgrass, field bindweed, and Scotch broom, each of 

which occupy over a million acres statewide (all ownerships), there is little expectation of eliminating all noxious 

weeds on BLM lands with these alternatives. However, since many of the more widespread weeds are being 

partially controlled with biological controls, and the alternatives would make a substantial difference in the spread 

of new weeds, the above numbers reasonably represent the relative (if not the absolute) difference between the 

alternatives. 

Any future climate-change related increases in temperature and/or CO2

 levels will favor invasive plants. Many 

invasive plants are more efficient at using increased CO2 levels than native plants. Native plant communities 

stressed or displaced by higher temperatures will be invaded by noxious weeds, much the same as they are 

following other disturbances. (See the Climate Trends, Projections, and Implications section in Chapter 4 for 

25 
 26 

more information). 

11 References are in the more detailed text in Chapter 4. 

Table 2-3. ProjecTed annUal noxioUs Weed sPread and acreage cHange for eacH alTernaTive. 

Alt . 

Gross 

Treatment 

Acres 

Treatment 

Effectiveness 

Effectively 

treated acres 

% annual 

spread in 15 

years 

Total acres 

infested in 

15 years 

15 year acre 

change from 

No Action 

Portion of 

OR BLM 

lands 

infested in 15 

years 

1 42,100 30% 12,630 14% 8,600.000 +2.7 million 1/2 

2 45,500 60% 27,300 12% 5,900,000 0 1/3 

3 58,400 80% 46,720 7% 4,000,000 -1.9 million 1/4 

4 & 5 58,400 80%1 49,070 6% 3,700,000 -2.2 million 1/5-1/4 

1

 Not including the 2,350 acres inadvertent gain from treating roadsides. 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Non-Herbicide Control Methods 

Each of the resource sections in Chapter 4 addresses the potential for adverse resource effects from the conduct of 

non-herbicide control methods. In some cases, the risks from such methods are similar to or outweigh the risks 

of using herbicides, particularly the low-risk herbicides added by Alternative 3. Most non-herbicide methods 

can disturb soils, potentially increasing stream sediment, the likelihood of erosion, and the likelihood of repeated 

invasive weed infestation. Chainsaw and certain mechanical treatments are hazardous, particularly trying to cut 

larger trees on steep slopes typical of power line rights-of-way west of the Cascades. This last treatment was 

compared with the advantage of cutting trees once, killing the sprouts by daubing the stump with herbicides, and 

converting the area to self-maintaining shrub species. Manual or machine crews can make more noise, disturb 

more wildlife, be more expensive, and require the use of more fossil fuels, potentially contributing to climate 

change. Mowing machinery (and other equipment) used along roadsides have the potential to carry noxious weed 

seeds well down the road and into other areas, even when cleaned regularly. 

Nevertheless, non-herbicide treatments can be effective at controlling about one-third of the noxious weeds (if 

populations are not large), and can avoid some of the non-target damage risks associated with herbicides. 

Additional Effects by Resource11 

Herbicides available under any of the alternatives remain available in subsequent (higher-numbered) alternatives. 

Therefore, herbicide effects attributed to, for example, Alternative 3, would apply to Alternatives 4 and 5 as well. 

Like the more detailed discussions in Chapter 4, the following discussion tends to focus only on the additional 

effects applicable to each successive alternative without repeating the previous discussions, even though they 

continue to apply. 

Vegetation, Native Plants, and Plant Communities - Herbicides are designed to kill plants, so most herbicides are 

a risk to nearby non-target plants. Bureau Sensitive and Federally Listed species require pre-project clearances 

and, for some herbicides, PEIS Mitigation Measures require substantial buffers (as necessary) to minimize risk. 

Invasive plants are by far a bigger threat to native plants than herbicides. Plant communities are already stressed 

by increasing demand for goods and services, heavy visitor use, human development, altered fire regimes and 
Draft Environmental Impact Statement, Chapter 2: The Alternatives 

increased fire intensities, climate shifts, and the rapid spread of invasive plants. Environmental changes are 

happening far more rapidly than at any previous time in the earth’s history. Exotic [non-native] plants have been 

rated as one of the six primary elements of global change (Vitousek et al. 1997). Invasive plants are displacing 

native ecosystems and converting diverse ecosystems to monocultures. Bureau Sensitive species are most 

vulnerable because their populations are small and their ecological amplitude is narrow. Sensitive species’ 

habitats and sites important to traditional American Indian uses cannot always be protected with the herbicides 

available under Alternative 2; Alternatives 3-5 have a far higher likelihood of being able to control weeds causing 

damage to such site-specific resources. As a general rule, the more herbicides available, the more likely there is 

one appropriate to the local situation. 

Pests and Diseases – The 200+ acre State-quarantined infestation of Sudden Oak Death in Curry County (SW 

Oregon, 2008) has the potential to spread throughout the coast range causing widespread ecological damage 

and more than $1 billion per year damage to Oregon’s nursery industry. An average of 13 detections per year in 

Oregon nurseries (all originating from California) now cost Oregon nurseries tens of millions of dollars per year 

to contain. Ninety percent of treatment area within the quarantine area is treated with herbicides, but BLM tries to 

control tanoak, a prolific sprouter, by cutting and burning. Alternatives 3-5 permit herbicide use for this control, 

and improving the efficacy of control efforts on the BLM portion could well decide whether the current infestation 

spreads from the quarantine area or not. There are essentially no negative environmental associated with the 250 

acres per year of herbicide applications expected to occur under Alternatives 3-5 for Sudden Oak Death. 

Air Quality – Even volatilized herbicides do not stay airborne long enough to affect air quality; issues are fugitive 

dust, equipment exhaust, and prescribed fire. Air pollution is highest with Alternative 3 with its higher level of 

burning and other non-herbicide treatments. Alternative 4 is lowest; replacement of certain roadside mowing 

reduces dust and exhaust. Native ecosystems tend to sequester more carbon than ones dominated by invasive 

plants, particularly the annual grasses. No alternative would affect any Class 1 airshed, although there could be 

short-term (1-4 hour) affects to the Klamath Falls and Lakeview Air Quality Maintenance Areas from smoke, 

dust, and exhaust, especially under Alternative 3. 

Soils – Herbicides may harm some east side biological soil crust components, and many non-herbicide treatments 

break up soil crusts. Chlorsulfuron, picloram, metsulfuron methyl, and tebuthiuron can decrease soil organism 

populations, but the effect is short-lived. The pre-emergents bromacil, tebuthiuron, and diuron can create bare soil 

and make it susceptible to erosion. However, invasive plants and non-herbicide treatments are generally worse 

for soils, permitting erosion and compaction. Soils low in organic matter and clays tend to be more permeable, a 

concern for ground-water contaminating herbicides, but their effect on such soils is neutral. Unlike the damage 

from many invasive plants, no permanent damage to soils is expected from any of the herbicides. 

Water Quality – Herbicides and silting could harm aquatic organisms including fish, and domestic uses of 

surface and groundwater. Herbicide routes to water include accidental application12, drift, overland flow during 

subsequent rainstorms, blowing dust (minor avenue) and leaching. Most likely times for water contamination 

are during application and during rains within a few days. Herbicides of concern to human and environmental 

health create more risk if applied on permeable soils, high water tables, or near water bodies. Also herbicides 

applied to roadside ditches can be quickly directed to nearby streams through road drainage structures, so normal 

buffers may not be adequate where roads are present. The three Alternative 4 herbicides, diuron, bromacil, and 

tebuthiuron, are hazardous to aquatic resources and are long lived, but their cumulative total acres is 100 west of 

the Cascades; their use is 16 percent of the total increase for rights-of-way, administrative sites, and recreation 

12 For example, Japanese knotweed grows right on the stream edge, and herbicides are considered the only effective 

removal tool. Accidental dripping into the stream is possible. 

27 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

sites under Alternative 4; and their use near water is restricted. Known groundwater contaminants13 are 2,4-D, 

dicamba, and picloram in Alternative 2, hexazinone added in Alternative 3, bromacil, diuron, and tebuthiuron 

added in Alternative 4; and diquat added in Alternative 5. Adverse effects are least likely under Alternative 3, and 

Alternative 4 is less likely to adversely affect water resources than Alternative 2. Even Alternative 4 herbicide use 

would be a small percentage of the total use in Oregon, and SOPs and PEIS Mitigation Measures applicable to all 

alternatives are designed to minimize the potential for significant adverse effects. 

Invasive plants have the potential to adversely affect water resources more than herbicides. Invasive plants can 

affect water quality by affecting bank stability, sediment, stream temperature, dissolved oxygen, and pH (USDA 

2005). Bank stability and other vegetation benefits can be reduced on weed infested sites where strong invaders 

out compete native vegetation. Weed infested soil has been shown to be more susceptible to erosion than soil 

occupied by native grass species (Lacey et al. 1989). Soil erosion in a simulated rainfall test more than doubled 

in spotted knapweed-dominated rangeland areas when compared to natural bunchgrass/forb grasslands (Lacey 

et al 1989). Cheatgrass and knapweeds can lead to shortened fire cycles followed by increased soil erosion and 

stream sedimentation. Eurasian watermilfoil multiplies rapidly and forms canopies over the native plants, literally 

choking out native plants and severely restricting recreational activities. In addition, it degrades water quality and 

fish habitat, accelerates eutrophication (over-abundance of nutrients), and lowers amounts of oxygen in the water. 

Wetlands and Riparian Areas – See effects under the Soil Resources, Vegetation, Native Plants, and Plant 

Communities and Water Resources sections. These areas are critically important, particularly east of the Cascades 

where water-related habitat is limited. They are highly susceptible to noxious weeds and other invasive plant 

invasion because of available moisture, which in turn adversely affects both aquatic and terrestrial resources 

dependent upon these areas. Some of the herbicides available under Alternative 2 (picloram and the more toxic 

formulations of glyphosate), and the three additional ones available under Alternative 4 bromacil, diuron, and 

tebuthiuron), are the most likely to adversely affect water and riparian-dependent resources. 

Fish – Most streams in Oregon contain fish, and many contain Federally Listed or Bureau Sensitive fish. Effects 

to fish involve their multiple life stages and thus the multiple habitat needs of a particular species. Potential 

effects of invasive plants include habitat and food alteration, changes to aquatic plants, reduced shading, and 

changes in vegetation dependent insects and their proximity to the water body. 

Herbicides with identified risks to fish under one or more normal use scenarios14 are: Alternative 2 – picloram and 

some formulations of glyphosate; Alternative 3 – same as Alternative 2; Alternative 4 – the two herbicides listed 

for Alternative 2 and 3 plus bromacil, diuron, and tebuthiuron (but only 100 acres total west of the Cascades), 

and; Alternative 5 – the five herbicides listed for Alternative 4 plus diquat. Some of these risks are for maximum 

application rates only, and would be avoided by applying at the typical application rate per PEIS Mitigation 

Measures. Different herbicides pose risks under different scenarios, suggesting that more herbicides would 

translate to more opportunities to select one that would accomplish the vegetation management objective and 

minimize risk. SOPs and PEIS Mitigation Measures address and reduce these risks. The analysis notes that for 

Alternatives 1 through 4, the benefits to fish from reduced weed spread under each alternative would far exceed 

the herbicide risks accrued under each of the same alternatives. 

Wildlife Resources – Risks to aquatic animals are similar to fish. For terrestrial wildlife, risk assessment scenarios 

based on high-dose testing on confined animals are unlikely with free-roaming species and herbicide spot 

treatments on invasive plants. Also, Bureau Sensitive and Federally Listed species generally require pre-treatment 

13 Herbicides that have been detected in groundwater. 

14 Drift, runoff, or direct application, but not including accidental spills
 

 28 
Draft Environmental Impact Statement, Chapter 2: The Alternatives 

clearances and buffers based on assumptions of ten times normal sensitivity levels, so treatments are unlikely to 

affect those species. Glyphosate in Alternative 2, and diuron in Alternative 4 are identified as the herbicides with 

risk under some exposure scenarios; SOPs and PEIS Mitigation Measures minimize this risk. Suppression of 

noxious weeds, and the improvements to habitat in Alternatives 4 and 5, far outweigh any potential for negative 

wildlife effects. The ability of all of the action alternatives to benefit sage grouse through the control of invasive 

annual grasses (Alternative 3), and control of sagebrush age class mixes as well as species mixes in sagebrush 

habitat (Alternatives 4 and even more under Alternative 5) are particularly beneficial because the sagebrush 

habitats are so highly impacted by invasive plants. 

Fire and Fuels – Outside of the Sagebrush Steppe Biomes and low elevations in the Siskiyou Biome (e.g. right 

around Medford), the effect of invasive plants on fuel loading is mixed and generally low with a few localized 

exceptions. Inside these biomes, however, the highly flammable invasive annual grasses have shortened the fire 

return interval from decades to a few years, substantially eliminating the relatively fire resistant native sagebrush/ 

forb plant community. Unrestored sites remain essentially unusable even for livestock grazing, and the fire hazard 

in the wildland/urban interface (WUI) is a particular concern. There is no herbicide effective on these annual 

grasses in Alternative 2, but imazapic in Alternatives 3-5 is ideally suited to the task and is estimated at 11,000 

acres annually for treating fire hazards within the WUI and other areas, preventing grass reinvasion after wildfires, 

and as a part of fire-imazapic-seeding site restoration treatments. 

Under Alternatives 4 and 5, the persistent and relatively non-selective herbicides bromacil, diuron, and 

tebuthiuron would be available east of the cascades to provide longer-term vegetation control around pump 

stations, communications sites, electricity substations, and other administrative sites to protect them from wildfire. 

Dry vegetation near east side developments can be a fire risk, and a vegetation-free buffer of even a few yards can 

protect these otherwise unprotected and unstaffed sites. Attempting to do this work with non-herbicide methods 

can create disturbances that exacerbate invasive weed problems, or require rock, pavement, or other materials that 

are both more expensive and can negatively affect the environment. 

Timber15 – Dealing with competing native vegetation has always been an expense of managing timber west of 

the Cascades. Non-herbicide site-preparation and conifer release treatments for new plantations are usually 

planned regardless of the presence of invasive plants. Invasive plants increase these costs an undetermined 

amount. Similarly, even “timber” stands are grown for multiple objectives, so the presence of other (non-conifer) 

vegetation is usual for conifer stands. While the current level of invasive plants (such as Scotch broom) certainly 

has an effect on growth, that effect has not been measured. (Effects to objectives other than timber growth are 

addressed in other sections of the EIS.) Invasive plants also increase operations cost as equipment and trucks 

often need cleaning before they can leave or enter certain sites. Alternative 3’s better control of Sudden Oak 

Death could significantly benefit future timber growth. Alternative 4’s ability to use herbicides to treat native 

vegetation along roads would be especially beneficial along the shared roads in the checkerboard ownership west 

of the Cascades because the control of unidentified invasive weeds during such treatments would reduce weed 

spread across ownerships and decrease the likelihood of timberlands from becoming infested. 

Livestock – Herbicide risk for livestock can come from direct sprays (dermal), as well as ingestion of treated 

vegetation. Herbicide risks to livestock are minimized by the nature of the proposed treatments; most are spot 

treatments on unpalatable invasive plants, or broadcast treatments on invasive plant monocultures with little or no 

grazing value. Nevertheless, herbicide applications are coordinated with grazing permit holders. When herbicide 

labels or risk assessments indicate grazing or butchering restrictions, animals are moved out of treatment units or 

15 Commodity timber and livestock production are not objectives of herbicide treatments proposed by this EIS, but the 

overall control of invasive plants and the use of herbicides could affect these resources. It is these potential effects that 

are addressed here. 

29 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

otherwise protected from exposure, usually at some cost to the permit holder. 

Of far more concern to livestock productivity is the increase in invasive plants. Invasive plants can reduce 

grazing capacity 35 to 90 percent; livestock ranches have been rendered worthless; some allotments will likely be 

at risk of closing because of weed-reduced grazing capacity within the next decade. Certain directed grazing can 

help reduce the spread of invasive plants. 

Wild Horses and Burros – Risks to wild horses and burros from herbicides are similar to those for livestock 

except that these animals range much farther in a typical day so are less likely to feed long on treated vegetation. 

Fences restrict grazing, and horses have been conditioned by capture programs to leave any area where low-flying 

helicopters are working. Horses generally avoid treated vegetation. Wild horses also tend to avoid developments, 

so treatments under Alternative 4 in rights-of-way, admin sites, and recreation sites are not likely to affect them. 

If wild horse management areas become substantially altered by invasive weeds, horses could move onto other 

areas causing grazing and other resource conflicts. Weed spread predictions that have one half, one- third, or 

even one quarter of BLM lands in Oregon infested with invasive weeds in 15 years (Alternatives 1, 2, and 3 

respectively – see Table 2-3) presage such conflicts. 

Cultural and Paleontological Resources – Prehistoric and historic sites are most at risk from mechanical damage 

from treatments or equipment, but required pre-project surveys minimize the risk. Traditional and subsistence 

gathering areas for Tribes could be adversely affected by herbicide treatments, but such areas are generally subject 

to government-to-government consultation specifically to avoid such effects. It is more likely that invasive 

plants will invade areas important to Tribes. Alternatives that are better able to efficiently control specific weeds 

while minimizing damage to non-target vegetation (those with more herbicides), would be better able to protect 

important tribal use areas being threatened by a specific invasion. Alternative 4 herbicides would increase 

exposure risks to Tribal members if they were applied to traditional use areas, but these three herbicides are nonselective pre-emergents not likely to be used in such areas. An exception might be the use of tebuthiuron at low 

rates to thin sagebrush in Alternatives 4 and 5. 

Visual Resource – Invasive weed monocultures are assumed to be less visually desirable than more diverse native 

landscapes. Invasive plant control treatments may have short-term visual effects, although the browning related to 

herbicides may be less noticeable than some ground-disturbing control methods. For example, mowing along roads 

west of the Cascades may be more visually obtrusive than herbicide sprays in some vegetation types. Long-term 

benefits of protecting native plant communities would outweigh any short-term adverse effect of herbicide treatments. 

Wilderness and Other Special Areas – Invasive weeds will probably move into these areas at slower rates than in 

the general landscape, in large part because vehicle use is usually limited. However, weed infestations that are 

established (e.g. infestations dominating camping sites along Wild and Scenic Rivers, or weeds displacing unique 

plants in the Cascade-Siskiyou National Monument), have a high potential to adversely affect the values for which 

the area was designated. Weed control treatments could adversely affect these values in the short term, but those 

effects may be justified to maintain long-term resource conditions. Native plant treatments permitted in Alternatives 

4 and 5 are less likely to happen in these areas, so the benefits of Alternatives 3, 4, and 5 are nearly equal. 

Recreation/Interpretive Sites – Invasive weed treatments are already happening in these areas, and sites treated 

with herbicides may be closed for hours to weeks after treatments to meet herbicide label and risk assessment 

requirements and/or allow native species to become reestablished. Under Alternative 3, weed treatment levels 

may go up slightly, but herbicides available are more likely to have less effect to users, decreasing area closures 

and herbicide risks. Under Alternative 4, native species like poison oak and vegetation encroaching on buildings, 

signs, campsites, roads, and other improvements could be treated with herbicides – saving money and potentially 

 30 
 

 

 

 

Draft Environmental Impact Statement, Chapter 2: The Alternatives 

generating less waste material. 

Administrative Sites, Roads, and Rights-of-Way – Meeting safety and protection requirements in these areas 

already requires non-herbicide control of native vegetation. Tractor-mounted mowers are the most common 

vegetation control along roads west of the Cascades, and chain flailers are more common east of the Cascades. 

Treatments around other sites may involve hand tools, extra site protection with rock or weed barriers, or other 

equipment. Weeds encroching into pavement edges are difficult to control without herbicides. Under Alternative 

4, herbicides would be available to do a portion of these treatments – replacing current non-herbicide treatments at 

a ratio of about 1:1. Benefits include lower cost, control of unidentified invasive weeds, and not using equipment 

prone to picking up seeds and moving them to other locations. 

Social and Economic Values – The analysis is structured around three social values identified during scoping: 

concern about weed spread from BLM lands; concern about herbicides as a threat to resource values, and; feelings 

that herbicides would provide benefits to resource values. The concerns/feelings are not mutually exclusive; 

several comment letters expressed two or even all three of these points. However, concerns about the use of 

herbicides were far more likely to be expressed by people west of the Cascades and there are a number of reasons. 

Population density is 14 times higher west of the Cascades; most of the west side is covered by domestic source 

water drainages; there are more water courses; the effects of invasive plants are less apparent to the average 

west side resident because vegetation density keeps them hidden; and fewer livelihoods are directly linked to the 

productivity of the land. These differences between the east and west side, the species of weeds themselves, the 

differences in topography and climate, and the concerns of local citizens, are the main reasons for the differences 

between the alternatives east and west of the Cascades. For example, aerial application would not be conducted 

west of the Cascades under Alternatives 3 and 4, and proposals to aerially spray would be rare under Alternatives 

2 and 5. In addition, herbicide acres treated west of the Cascades are projected to increase only 45 percent 

between Alternatives 2 and 5, while east of the Cascades, Alternative 5 acres are projected to be 310 percent more 

than Alternative 2. Also, the three Alternative 4 herbicides that are of concern to water-related resources are 

mostly available only on east of the Cascades. 

In any event, there is a high degree of agreement on both sides of the Cascades that invasive plants are a serious 

problem, and that the effects of their spread will be more harmful than the use of herbicides. However, some people 

may be less supportive of Alternatives 4 and 5 where native vegetation control is an additional focus, even though 

treatments are limited to non-commodity objectives and there are secondary invasive plant control benefits. 

Environmental Justice – There is a potential for Hispanic or other minority crews to apply some herbicides under 

some scenarios, and those crews’ access to written instructions, warning labels, or even recourse if asked to do 

something unsafe, may be limited. Also, low income people and American Indians may be more likely to be 

gathering wildland products including blackberries than the public as a whole, resulting in a higher exposure and 

risk for these groups. 

Costs – The gross cost for treating the noxious weeds and other invasive plants varies across the alternatives 

from $6.5 to $8.9 million, being more expensive if non-herbicide methods are used, and more expensive as 

total acres go up (Table 2-4). Since there is a current budget trend assumption for all alternatives, the increase 

assumes some level of additional funding would become available from cooperators, partners, or other resource 

programs as treatments become more efficient because of additional herbicides, or as herbicides become available 

for additional resource program objectives such as fuels management or rights-of-way management. When 

the effectiveness of each alternative at eliminating weeds on the treated acre is factored in, the costs become 

substantially different in favor of increased herbicide use. 

For treating vegetation in rights-of-way, administrative sites, and recreation sites, project costs are $217 per acre 

31 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table 2-4. noxioUs and oTHer invasive Weed TreaTmenT cosTs by alTernaTive 

Alt . 1 Alt . 2 Alts . 3-5 

Total project costs $7.1 million $6.5 million $8.9 million 

Gross weed treatment 

acres 

42,100 45,500 58,400 

Percent effectively treated 30 60 80 

Acres effectively treated 12,630 27,300 46,160 

Cost per effectively 

treated acre 

$565 $240 $193 

for mechanical/manual in Alternatives 1-3, and $117 per acre when done with herbicides in Alternatives 4 and 

5. Savings under Alternative 4 and 5 are $200 per road mile and just under $1 million per year total. This does 

not include the value of the 2,350 acres of additional noxious weed control estimated to be a secondary benefit of 

spraying native vegetation along roadsides and other high-use areas. 

Human Health and Safety - Nationally the BLM has selected 18 herbicides from among hundreds available, 

picking those needed to accomplish the objectives while having the least risk to humans and the environment. 

This said, the additional herbicides that would become available under Alternative 3 are generally less toxic than 

those currently being used. At typical rates, 2,4-D (Alts. 2-5), bromacil, diuron, and tebuthiuron (Alts. 3-5) are 

identified as having a generally moderate risk to the public and applicators, with risks ranging from none to high 

depending upon the exposure scenario. Diquat has a low risk in some occupational scenarios, and triclopyr, 

hexazinone, and diquat have a low risk in at least one of the accidental exposure scenarios evaluated. All six of 

these herbicides have a PEIS Mitigation Measure that prohibits application at maximum rates if feasible. 

Nearly all use of bromacil, diuron, and tebuthiuron would be east of the Cascades, and bromacil and diuron 

would be used mostly where complete vegetation control is needed, such as for reducing fire hazard in unstaffed 

communications and other non-public sites, or to keep vegetation from growing into pavement edges. Diquat is 

only available in Alternative 5 and projected use is low; it is expected to be used only where one of the other five 

available aquatic herbicides would not work. 

Bromacil, diuron, 2,4-D, and tebuthiuron have the highest health risks for workers. PEIS Mitigation Measures 

specify avoiding applying bromacil and diuron aerially. Bromacil, diuron, and tebuthiuron have the highest 

risks to the public. Diuron is a possible carcinogen. 2,4-D has possible endocrine disruption abilities in workers 

applying large amounts of 2,4-D and poses moderate to high risks to workers performing ground-based boom 

spraying. 

Summary of the Major Effects of Each Alternative 

While there is a potential for adverse resource and human health effects from various elements of the alternatives, 

the SOPs and PEIS Mitigation Measures would minimize herbicide risks to negligible levels. Even Bureau 

Sensitive and Federally Listed species were deemed not at great risk because of required pre-project clearances, 

consultation requirements, and/or additional buffer requirements. Each alternative’s projected reduction in weed 

spread more than compensates for any herbicide or non-herbicide treatment risk identified. 

The acres estimated to be treated by each herbicide or non-herbicide method under each alternative and displayed 

in Chapter 3’s Background for Effects Analysis section on Table 3-3 are integral to the following comparison of 

the major effects of each alternative. Selected parameters for the alternatives relevant to the effects comparison 32 
 

Draft Environmental Impact Statement, Chapter 2: The Alternatives 

are displayed on Table 2-5. 

Alternative 1 – No Herbicide Use . This alternative would provide effective control for about one-third of the 

noxious weed species, potentially precluding effective control around high priority Federally Listed and Bureau 

Sensitive species’ sites, traditional gathering areas, and high-public use sites where weeds could be picked up and 

transported. Control activities can be hazardous to those doing the weed treatments, result in soil disturbance 

that can lead to reinvasion, put cultural and soil resources at risk, and cost more per acre. Weed spread is 

predicted to increase under this alternative as the BLM and its neighbors become less successful. Weeds 

are projected to infest 2.7 million more acres in 15 years than under the No Action Alternative – negatively 

affecting virtually every resource from wildlife to visual quality. The human environment would suffer because 

of decreased water quality, decreased wildlife and other elements of ecological diversity, decreased access to 

natural resources because of barriers like blackberries along streams, and long-term changes including loss of 

species or populations, loss of productivity, and altered soil chemistry. Social acceptance of this alternative is 

likely to be low. Although some scoping comments expressed a desire for no herbicide use, most local user 

groups are concerned with the resource damage caused by invasive plants and are aware of the higher cost and 

lower practicality of non-herbicide control methods. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only . This alternative would provide 

effective control for all but about a dozen of the 121 noxious weed species in Oregon, but would not include tools 

effective on some invasive and noxious weeds including the invasive annual grasses. Medusahead and cheatgrass 

occupy 600,000 and 5 million acres respectively. Wildfire in these grasses would continue to convert remaining 

sagebrush habitats, decrease range carrying capacity for wildlife, wild horses, and livestock, and increase the 

risk of wildfire. The four herbicides available under this alternative generally present some risk to one or more 

elements of the environment, and many are used more than once at a site because they are not totally effective, 

compounding adverse environmental effects. Repeatedly using the same herbicides also increased the likelihood 

that weeds resistant to that herbicide will take over the site. Cooperative weed management strategies across 

ownerships would continue to be a problematic since BLM neighbors have moved on to other herbicides. High 

2,4-D use would continue to present a hazard to applicators, non-noxious invasive weeds like cheatgrass cannot 

be treated with herbicides, and noxious weeds would continue to spread at 12 percent or 144,000 acres per year 

on BLM lands in Oregon. At this rate, noxious weeds are predicted to occupy 1/3 of all BLM lands in 15 years, 

causing proportionate losses in habitat (particularly for sage grouse and other sage steppe species), wild horse and 

livestock grazing, watershed protection, recreational opportunities, and other resource uses. Social acceptance of 

this alternative would be fairly high; many persons opposed to broad herbicide use on BLM lands for commodity 

production nevertheless would view noxious weeds with concern and consider their aggressive control with 33 

Table 2-5. selecTed ParameTers for eacH alTernaTive relevanT To THe effecTs comParison. 

Parameter Alt . 1 Alt . 2 Alt . 3 Alt . 4 Alt . 5 

Number of Herbicides Available 0 4 W: 11 

E: 13 

W: 12 

E: 16 18 

Invasive Plant Herbicide Annual Treatment Acres 0 16,7002 30,300 30,300 30,300 

Invasive Plant Non-herbicide Annual Treatment Acres 42,100 28,800 28,100 28,100 28,100 

Native Plant Herbicide Annual Treatment Acres 0 0 01 15,100 20,000 

Rate of Spread at 15 years 14% 12% 7% 6% 6% 

Difference in noxious weed infested acres in15 year 

compared to the No Action Alternative 

Up 2.7 

million 0 Down 1.9 million 

Down 2.2 

million 

Down 2.2 

million 

1

 Not counting 250 acres per year pest and disease control. 

2

 Noxious weeds only. 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

herbicides necessary. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases . 

This alternative would go much of the way toward accomplishing most of the Purposes. The availability of 

seven and nine additional herbicides, west and east of the Cascades respectively would provide effective controls 

for most of the 121 noxious weed species (Appendix 7: Table A7-1). Spread would eventually be reduced to 7 

percent and infested acres in 15 years would be reduced by 1.9 million acres when compared to Alternative 2. 

The BLM would have access to most of the herbicides used by neighbors, counties, and weed control boards, 

making cooperative projects more feasible and providing an incentive for better control across all ownerships. 

Having control tools effective on most noxious weeds in Oregon increases the likelihood that weed control efforts 

to protect Bureau Sensitive plant and animal species’ habitats and traditional use areas would be successful. The 

adverse effects of noxious weeds to wildlife, water, and grazing- and recreation-dependent communities would 

all be reduced. Air quality would be most adversely affected under this alternative: the availability of imazapic 

would make prescribed burning a viable tool for restoring sage steppe habitats. Prescribed burns in annual grasses 

simply return to annual grasses unless an effective follow-up herbicide treatment and reseeding is used. 

The ability to use herbicides to help control Sudden Oak Death or other State-designated pests and diseases would 

provide the State and other cooperators a unified, potentially more successful approach to protecting ecosystems 

and the nursery industry from this pathogen. The cost per acre of effectively treated noxious weeds would be 

reduced 20 percent. The acres treated with herbicides that are a moderate risk to applicators (2,4-D) would be 

reduced by about 70 percent east of the Cascades. Potential adverse effects to fish and wildlife would be reduced 

when compared to the No Action Alternative. Social acceptance of this alternative is likely to be high; even 

persons opposed to most herbicides on publically owned wild lands view noxious weeds and other invasive plants 

as a serious problem, and most will understand the additional herbicides added under this alternative are more 

efficient and less environmentally toxic. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat invasive Weeds plus Limited 

Additional Uses . This alternative is predicted to reduce noxious weed spread to 6 percent per year and result in 

2.2 million fewer infested acres in 15 years when compared to the No Action Alternative. Herbicide use would 

reduce native vegetation control costs in rights-of-way, administrative sites, and recreation sites by nearly $1 

million per year. These treatments would slightly reduce dust and vehicle emissions, reduce the likelihood of 

occupational injuries by reducing mechanical (chainsaw etc.) treatments on steep wooded slopes, and reduce the 

adverse visual effects of mowing in some vegetation types. They would also preclude the need to separately spray 

noxious weeds along roads prior to mowing, and inadvertently control 2,350 acres per year of unidentified or lowpriority noxious weed populations along roadsides and other areas where there is a high likelihood of their being 

picked up and moved by vehicles. Alternative 4 would also provide herbicides for about 5,000 acres of habitat 

improvement for Bureau Sensitive and Federally Listed species identified in interagency Conservation Strategies, 

65 percent of which would be new opportunities currently deemed impractical without herbicides. 

Of the additional herbicides added by this alternative, bromacil, diuron, and tebuthiuron have the highest risk 

to humans, fish, and for diuron, wildlife. They are active both pre- and post-emergent, with applications being 

restricted to the eastern side of the State where they will be used to treat vegetation along roads, pipelines, pump 

stations, and other non-cropland areas. Most of the tebuthiuron would be applied to sagebrush at low rates to 

improve sage grouse habitats. PEIS Mitigation Measures restrict application to typical rate if feasible, specify 

avoiding aerial application of bromacil and diuron, and specify increased buffers on water and Federally Listed or 

Bureau Sensitive species’ habitats. Finally, the social acceptance of using any herbicides to treat native vegetation 

along public roads, where there is a perception of unguarded exposure and the possibility of direct contact or 

 34 
 

Draft Environmental Impact Statement, Chapter 2: The Alternatives 

ingestion of sprayed materials, will be less than the social acceptance for Alternative 3, at least west of the Cascades. 

Alternative 5 - Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives . This alternative would add 4,900 acres of herbicide use above what is proposed 

for Alternative 4, for any non-commodity treatment objective. Most of this increase would be for additional 

habitat improvement projects east of the Cascades. It would also make all 18 BLM-approved herbicides 

available throughout the State, with 4,000 acres of the increase split between 2,4-D and imazapic. Additional 

habitats would benefit as not all Western juniper and rabbitbrush encroachment expected to be treated under this 

alternative is within Bureau Sensitive and Federally Listed species’ habitats covered by Alternative 4. As with 

Alternative 4, social acceptance of approving herbicide use for a fairly unspecified group of projects may not be 

high, but all but 200 acres would be east of the Cascades where environmental risk is lower, the advantages more 

apparent, and the public acceptance of herbicide use is higher. 

The Preferred Alternative 

Alternative 4, the Proposed Action, is the Preferred Alternative. It reasonably meets the Need and all eight 

Purposes. Like Alternative 3, 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. The additional alternatives would also be effective against a wider array of invasive plants, 

including the invasive annual grasses medusahead and cheatgrass, as well as other weeds for which there are 

currently no effective controls available to the BLM in Oregon. The ability to treat native vegetation encroaching 

on rights-of-ways, recreation sites, and administrative sites with herbicides under Alternative 4 reduces cost 

for these regular maintenance treatments by about $1 million per year, would reduce ground disturbance that 

can encourage invasive plants, and would eradicate small undetected populations just getting established along 

roads and other public use areas. Alternative 4 would also allow the use of herbicides for improving habitat for 

Federally Listed and Bureau Sensitive species like sage grouse. 

Alternative 5 would have the same benefits as Alternative 4, plus it would make herbicides available for the 

full range of non-commodity resource management activities. Although Alternative 5 is estimated to increase 

herbicide use only an additional 10 percent from Alternative 4, and most of this increase would be expected to 

go toward additional habitat improvement projects not practical without herbicides, the open-ended nature of the 

types of projects to be conducted makes accurate effects estimation in this document more difficult, and would 

depart from the narrow program clarity and focus requested by many of the scoping comments. 

Potential Mitigation 

Introduction 

Mitigation measures avoid, minimize, rectify, reduce, or compensate for adverse environmental impacts of 

management actions (40 CFR 1508.20). NEPA implementing regulations require agencies to “Include appropriate 

mitigation measures not already included in the proposed action or alternatives” and include a discussion of 

“Means to mitigate adverse environmental impacts” (40 CFR 1502(f) and 1502.16(h)). The regulations also 

require that in the Record of Decision the Responsible Officials “State whether all practicable means to avoid or 

minimize environmental harm from the alternative selected have been adopted, and if not, why they were not” 

(40 CFR 1502.2). Consistent with those requirements, mitigation measures are identified and described here for 

all potential adverse effects identified for the proposed action. Mitigation measures do not include “don’t do” or 

35 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

“select another alternative,” as these choices are addressed by other alternatives and/or may not meet the Need and 

Purposes for the proposed action. 

The following potential mitigation measures were identified to respond to adverse effects identified in this EIS. 

If a resource section in Chapter 4 is not shown below, it means the potential for adverse effects to that resource 

were deemed negligible, or no practicable mitigation measures were identified that would mitigate the effect 

identified. The mitigation measures listed below are in addition to mitigation measures identified in the PEIS, 

adopted by the Record of Decision for the PEIS, and listed in Appendix 2 and considered a part of all of the 

herbicide alternatives. In an attempt to avoid confusion, those mitigation measures are referred to herein as PEIS 

Mitigation Measures. 

The decision-maker’s decision to reject or apply each of the following mitigation measures to the selected 

alternative will be described in the Record of Decision. The decision-maker may decline to select identified 

mitigation measures because the adverse effect it is supposed to address is acceptable in light of the potential for 

increased cost or decreased effectiveness of the selected alternative, or because the decision-maker believes other 

measures will adequately address the concern. 

Potential Monitoring, Appendix 3 - Part II of the Monitoring Appendix (Appendix 3), presents potential 

monitoring measures designed to assure smooth implementation of the program changes that might result from 

the selection of one of the herbicide action alternatives. Although no reduction in adverse effects can be attributed 

to monitoring per se, the proposals in that section should be selected or rejected in the Record of Decision at the 

same time as the potential mitigation measures. 

Resource Effects Section and Potential Mitigation Identified16 

Soils Resources 

•		 To limit the risk of erosion from either water or wind, narrow the width of treated area exposed to the 

prevailing wind direction to reduce the potential for wind erosion on soils with high wind erosion ratings 

(group 1 or 2). Narrow widths would provide filter strips closer to the affected area to capture any 

sediment derived from water erosion. 

•		 Burn smaller areas on a rotational basis rather than treating all of the area at once. If stubble vegetation 

sprouts and re-grows within two weeks of treatment, allow subsequent treating of nearby area. 

Water Resources and Quality 

•		 To protect domestic water sources, no herbicide treatments should occur within 100 feet of a well or 200 

feet of a spring used as a domestic water source. 

•		 Where diquat applications would be used on vast enough areas that de-oxygenation from plant 

decomposition would cause unacceptable effects to aquatic fauna, either 1) treated vegetation would be 

removed or 2) the area would be treated in swaths over several months time to minimize de-oxygenation 

of the water due to large rapid amounts of plant decomposition. 

•		 Avoid spraying near ditches connected to streams with Bureau Sensitive or Federally Listed species. 

16 Potential mitigation was not identified for some resources because SOPs and PEIS Mitigation Measures were adequate, 

no adverse effects were identified, or no additional mitigation was available. 

 36 
 

Draft Environmental Impact Statement, Chapter 2: The Alternatives 

Wildlife Resources 

•		 Herptile (amphibian and reptile) and mollusk mortality due to vegetation management can be minimized 

by conducting activities during the winter hibernation or estivation period. If management is to occur 

within the active season, the following approaches should be considered to minimize impacts: 

•		 Avoid control work when air temperatures are between 50-80° F and after rain or flood events, when 

herptiles (and mollusks) are most active. 

•		 Avoid herptile spring and fall migrations to and from breeding or wintering habitats. 

•		 Choose herbicides with lower risks due to ingestion in areas where ungulates are likely to congregate if 

treating native plants. 

•		 Where possible, design native vegetation treatment areas to mimic natural disturbance mosaics. 

Patchiness is usually beneficial to most wildlife, and patchiness is usually tolerated by species that prefer 

contiguous habitat. 

•		 If habitat conditions are present, but surveys or evaluations do not confirm occupancy, assume species are 

present and apply SOPs for those species. Few wildlife species are easily surveyed, many are cryptic, and 

lack of survey response does not ensure lack of presence at the site. 

•		 Choose herbicides that have the least toxic effect on the most Bureau Sensitive wildlife species when 

mitigations or herbicide selection has positive effects on some members of the wildlife community and 

negative effects on others. Consider using different treatment approaches on sites used by multiple 

species of rare17 wildlife to keep impacts to species to a minimum in at least part of the treatment area. 

Livestock 

•		 Where there is a potential for livestock consumption of treated vegetation, apply bromacil, dicamba, 

imazapyr, metsulfuron methyl, and tebuthiuron at the typical, rather than maximum, application rate to 

minimize risks to livestock. 

Wild Horses and Burros 

•		 Where there is a potential for wild horse or burro consumption of treated vegetation, apply bromacil, 

dicamba, imazapyr, and metsulfuron methyl at the typical, rather than maximum, application rate to 

minimize risks. 

•		 Do not apply 2,4-D, clopyralid, diflufenzopyr + dicamba, diuron, glyphosate, hexazinone, picloram, or 

triclopyr where wild horses have unrestricted access to treated areas. To limit adverse effects to wild 

horses and burros, particularly through the contamination of food items, treatments should not exceed 15 

percent of any HMA at any given time. 

•		 Consider reducing risks to wild horses from 2,4-D, clopyralid, diflufenzopyr + dicamba, diuron, 

glyphosate, hexazinone, picloram, or triclopyr by herding wild horses out of treatment areas. 

Socioeconomics 

•		 Require a public notification plan for all treatments where herbicide treatments have the potential to affect 

users or uses of BLM or adjacent lands. 

17 Federally Listed or Bureau Sensitive 

37 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

• For herbicides with label-specified re-entry intervals, post information at access points to recreation sites 

or other designated public use areas notifying the public of planned herbicide treatments in languages 

known to be used in communities surrounding the area to be treated. Posting should include the date(s) 

of treatment, the herbicide to be used, when it is safe to enter the area and collect resources of subsistence 

value, and a name and phone number of who to call for more information. 

•		 Consider the potential for treatments to affect communities from herbicide-contaminated resources 

originating from BLM, such as subsistence resources or water used downstream for human or agricultural 

uses. 

•		 Coordinate with and/or notify neighboring landowners who may want to, or are already treating adjacent 

lands. 

Environmental Justice 

•		 Ensure materials safety data sheets and other informational or precautionary materials are available in 

languages spoken by work crews implementing treatments. This includes but is not limited to material 

such as Occupational Safety and Health Administration standards along with agency, industry and 

manufacturers’ recommendations and Human Health SOPs and mitigation measures. 

•		 Reasonable effort must be made to fully inform these laborers in their native language. 

Human Health and Safety 

•		 Consideration should be given to herbicides other than 2,4-D; use of 2,4-D should be limited to situations 

where other herbicides are ineffective or in situations in which the risks posed by 2,4-D can be mitigated. 

•		 Do not apply triclopyr by any broadcast method. 

•		 Do not apply 2,4-D when there is a potential for picking sprayed fruit like blackberries. 

•		 If applying 2,4-D within 2-times the standard buffer widths from streams (20’ for hand, 50’ for boom, 200’ 

for aerial), monitor the water during operation and during next significant rain event if within four days 

to help ensure notification of downstream users if there is a risk, and to have documentation if effects are 

suspected. 

•		 Do not apply bromacil, diuron, or tebuthiuron when there is a potential for picking sprayed fruit. Do not 

broadcast spray onto vegetation more than a foot tall when and where public contact is likely, such as on 

tall grass or low brush around developed sites and other high use areas. 

•		 If applying 2,4-D within 2-times the standard buffer widths from streams (so 20’ for hand, 50’ for boom, 

200’ for aerial), use a drift reduction agent to help prevent 2,4-D from getting into water. 

 38 
39 

Chapter 3 

Background and Assumptions for 

Effects Analysis 

Introduction 

This EIS tiers to the 2007 national Vegetation Treatments Using Herbicides on Bureau of Land Management 

Lands in 17 Western States Programmatic Environmental Impact Statement (PEIS), which is incorporated into this 

EIS as uncirculated Appendix 1. This appendix is available online at the web addresses listed on the Appendix 1 

cover page in the appendices of this EIS, or may be obtained on compact disk or printed copy by contacting the 

EIS Team via phone, email, or U.S. post (see title page). 

The three herbicide action alternatives presented in this EIS fit completely within PEIS Alternative B (the 

alternative selected in the Record of Decision for the PEIS) in that they present the same or fewer herbicides than 

considered in Alternative B, apply them to all or fewer acres than were assumed in Alternative B, and consider 

those herbicides for all or fewer of the treatment objectives included in Alternative B. All Standard Operating 

Procedures (SOPs) included in Alternative B, as well as all PEIS Mitigation Measures, apply to these alternatives. 

Therefore, the potential for adverse human health or environmental effects resulting from actual application of 

herbicides should, at the programmatic scale, fall generally within those described in the PEIS for Alternative B. 

Apparent differences from PEIS-identified effects are generally attributable to: 1) Examination of Oregon-specific 

conditions at a finer scale than in the PEIS, and 2) Lower levels of vegetation control than assumed in the PEIS. 

Although this EIS tiers to, and incorporates, the PEIS, an attempt is made to summarize and include all parts of 

the PEIS analysis pertinent to an examination of the potential significant environmental effects of the alternatives. 

However, additional details about methodology, background material, and references remain in the PEIS, and 

readers seeking additional information are encouraged to refer to the corresponding sections in the PEIS. In each 

case, the decision about the detail to bring forward or otherwise include in this EIS was based primarily on its 

applicability to the Purposes presented in Chapter 1. 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Background for Effects Analysis 

This EIS addresses large, regional-scale trends and issues that require integrated management across broad 

landscapes. It also addresses regional-scale trends and changes in the social and economic needs of people. 

This analysis does not identify site-specific effects because projects have not been identified and because sitespecific information is not essential for determining the effects of broad-scale management direction. As noted in 

Chapters 1 and 2, site-specific issues would be addressed through NEPA analysis at the district or project level. 

The 18 Herbicides 

The 18 herbicides proposed for use in this EIS are a subset of the hundreds of herbicides registered for use in 

the U.S. They were chosen by the BLM nationally for maximum effectiveness against wildland weeds and least 

environmental and non-target species’ risks. Table 3-1 shows information about each herbicide that affects how it 

would be used. Additional information about the herbicides and the plants they control is in Appendix 9. 

Herbicides can be categorized as selective or non-selective. Selective herbicides kill only a specific type of plant. 

For example, an herbicide selective for broadleaved plants can be used to manage such species while maintaining 

desirable grass species in rangeland communities. Non-selective herbicides kill all types of plants, and thus must 

be applied only to the target species. Herbicides can be used selectively to control specific types of vegetation 

(e.g., killing invasive weeds), or non-selectively to clear all vegetation on a particular area (e.g., keeping a 

roadway clear of vegetation). 

Some herbicides are post-emergent, which means they can be used to kill existing vegetation; others are preemergent, which stops vegetation before it grows (e.g. prohibiting seeds from germinating)(Table 3-1). Resourcespecific discussions of the uses and risks associated with each herbicide are included in each of the resource 

effects sections in Chapter 4. 

Formulations (brands) and adjuvants are limited to those on the BLM national list of approved herbicides and 

adjuvants, which is reviewed and updated at least annually (see Appendix 9 for the 2009 version). This list 

identified herbicides that are known to be consistent with the formulations analyzed in the risk assessments and 

otherwise suitable for wildland use. 

Adjuvants, Impurities, and Other Ingredients 

Inert compounds (also called “other ingredients”) are those that are intentionally added to a formulation, but have 

no herbicidal activity and do not affect the herbicidal activity. These ingredients are added to the formulation to 

facilitate its handling, stability, or mixing. Relatively little toxicity information is known on inert ingredients. 

Impurities are inadvertent contaminants in the herbicide usually present as a result of the manufacturing process. 

Adjuvants are compounds added to the formulation to improve its performance. They can enhance the activity of 

an herbicide’s active ingredient (activator adjuvant) or offset any problems associated with its application (special 

 40 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

purpose or utility modifiers). Surfactants are one type of adjuvant that makes the herbicide more effective by 

increasing absorption into the plant, for example. 

Adjuvants (including surfactants) and other ingredients are not under the same registration guidelines as are 

herbicides. The EPA classifies these compounds into four lists based on the available toxicity information. If the 

compounds are not classified as toxic, then all information on them is considered proprietary and the manufacturer 

need not disclose their identity. Therefore, adjuvants and other ingredients generally do not have the same amount 

of research conducted or label disclosure on their effects as do active ingredients. In general, adjuvants compose 

a relatively small portion of the volume of herbicide applied. 

A risk assessment has only been completed for one commonly used non-ionic surfactant type, nonylphenol 

polyethoxylate (NPE) (Bakke 2003). NPE is found in these commercial surfactants at rates varying from 20 to 

80 percent. NPE is formed through the combination of ethylene oxide with nonylphenol (NP), and may contain 

small amounts of un-reacted NP. NP and NPE are weakly estrogenic in aquatic and terrestrial organisms (1000 to 

100,000 times weaker than natural estrogen). NP and NPE are not toxic to soil microbes. NP is highly toxic to 

many aquatic organisms at low concentrations (EPA 2007b). 

The adjuvant R-11 is a nonylphenol ethoxylate that is acutely toxic to aquatic life (Stark and Walthall 2003) and 

is suspected to be an endocrine-disrupting chemical (Bakke 2003). The BLM has decided to suspend the use of 

R-11 in its herbicide applications and it is not evaluated further here. 

Differences in the Number of Herbicides Proposed East and West of the Cascades 

Under Alternatives 3 and 4, districts east and west of the Cascades identified different program needs. Differences 

in the number of herbicides available on the east and west of the Cascades under these alternatives are likely 

based on differences in native vegetation types and invasive plant occurrence. 

Aerial application is prohibited under Alternatives 3 and 4 west of the Cascades due to higher population and 

stream densities. 

Provision for Adding Herbicides in the Future 

Additional herbicides beyond the 18 included in the Record of Decision for the PEIS could become available 

for BLM use in the future if: 1) they are registered by the EPA for use on one or more of the Oregon land 

types1

; 2) the BLM (nationally) determines that the benefits of use on public lands outweigh the risks to human 

health and the environment; 3) they meet the evaluation criteria to ensure that the decision to use the active 

ingredient is supported by scientific evaluation through human health and ecological risk assessments and NEPA 

documentation; and, 4) they are included in appropriate site-specific NEPA analysis. These evaluation criteria and 

how they are processed at the national level are discussed in more detail in Appendix 4. No “future” herbicide is 

assumed or analyzed in this EIS. 

Forestland; rangeland; riparian or aquatic; oil, gas, and mineral sites; rights-of-way; and, recreation and cultural sites. 

41 

1
Table 3-1. Herbicide informaTion 

Herbicide

Representative Trade Names1 Common Targets 

Selective to

Plant Types 

Pre/post 

Emergent

Point of

Application 

Types of BLM Lands Where Use is Permitted2 

Application Rate

(lbs/acre) 

Available 

under

Alternative4 

Aerial

Spray5

Allowed K 

oc 

6 

Solubility7 

(mg/l) 

SPISP II Rating8 (Leaching

Potential) 

Typical Max3 2 3 4 5 

PLP9

Leaching 

PSRP10

SolutionRunoff 

PARP11

AdsorbedParticleRunoff 

2, 4-D

Many, including Amine, Hardball,Unison, Saber, Salvo, Aqua-Kleen, andPlatoon 

Annual and biennialbroadleaf weeds.Kochia,white top, perennial pepperweed, Russian thistleand knapweed, sagebrush,rabbitbrush. 

broadleaf 

Post

Foliar 

Rng For RAq OGM ROW R&C 1 1.9 √ √ √ √ 20-100 33,900 Inter­ mediate Inter­ mediate Low 

Bromacil 

Hyvar 

Annual grasses andbroadleaf weeds.Cheatgrass,puncturevine, ragweed, wild oat, dandelion, quackgrass,wild carrot. 

no 

Pre and post

Soil OGM ROW R&C 4 12 E √ avoid 32 700 High High Inter­ mediate 

Chlorsulfuron 

Telar 

Thistles, wild carrot, giant horsetail, poison hemlock,Russian knapweed, marestail, perennial pepperweed, puncturevine, tansy ragwort, common tansy, common teasel,dalmation toadflax,yellow toadflax, whitetop,dyers woad 

broadleaf 

Pre and early

post

Soil or foliar 

RngOGM ROW R&C 0.047 0.141 E E √ 40 7,000 High High Inter­ mediate 

Clopyralid

Transline, Stinger, Spur 

Thistles, common burdock, knapweeds, yellowstarthistle, oxeye daisy, hawkweeds, prickly lettuce,dandelion, cutleaf teasel,kudzu, buffalobur 

broadleaf 

Post

Foliar 

Rng For OGM ROW R&C 0.35 1 √ √ √ 2 1,000 High Inter­ mediate Low 

Dicamba

Vanquish, Banvel, Diablo, Vision, Clarity 

Knapweeds, kochia, andthistles. 

broadleaf,

woody

plants 

Pre and post

Foliar 

RngOGMROW R&C 0.25 2 √ √ √ √ no 2 400,000 High Inter­ mediate Low 

Diflufenzopyr + Dicamba

Overdrive, Distinct 

Knapweeds, kochia, andthistles. broadleaf Post

Foliar 

RngOGM ROW R&C 

0.2625 0.35 √ no 

Diflufenzopyr no 87 5,850 Low Inter­ mediate Low 

Diquat

Reward 

Giant salvinia, hydrilla, andwatermilfoils. no 

Post

Aquatic 

RAq 1 4 √ no 1,000,000 718,000 Very Low Low High 

Diuron 

Direx, Karmex 

Annual grasses (includingbluegrass) and broadleafweeds.Lambsquarters,kochia and Russian thistle. 

annual

weeds, some 

perennials 

Pre

Soil OGM ROW R&C 6 20 √ √ avoid 480 42 Inter­ mediate High Inter­ mediate 

Fluridone

Avast!, Sonar Hydrilla and watermilfoils submersed plants Post Aquatic RAq 0.15 1.3 √ √ √ 1,000 10 Low Inter­ mediate Inter­ mediate 

Glyphosate

Many, including Rodeo, Mirage,Roundup Pro, andHoncho 

Grasses (including Italian ryegrass), sedges, broadleafweeds, and woody shrubs. 

no 

Post

Soil or foliar 

Rng For RAq OGM ROW R&C 2 7 √ √ √ √ 24,000 900,000 Very Low High High 

 42 
Herbicide

Representative Trade Names1 Common Targets 

Selective to

Plant Types 

Pre/post 

Emergent

Point of

Application 

Types of BLM Lands Where Use is Permitted2 

Application Rate

(lbs/acre) 

Available 

under

Alternative4 

Aerial

Spray5

Allowed K 

oc 

6 

Solubility7 

(mg/l) 

SPISP II Rating8 (Leaching

Potential) 

Typical Max3 2 3 4 5 

PLP9

Leaching 

PSRP10

SolutionRunoff 

PARP11

AdsorbedParticleRunoff 

Hexazinone

Velpar 

Annual and perennial grassesand broadleaf weeds, brush,and trees. 

grasses,

broadleaf,

woody

plants 

Pre and post

Soil or foliar 

Rng For OGM ROW R&C 1 8 √ √ √ 54 33,000 High High Inter­ mediate 

Imazapic

Plateau, Panoramic 

Cheatgrass, leafy spurge, medusahead, white top,dalmation toadflax andRussian knapweed. 

some

broadleaf

and grasses 

Pre and post

Soil 

Rng For OGM ROW R&C 0.0313 0.1875 √ √ √ 137 2,200 High High Inter­ mediate 

Imazapyr

Arsenal, Stalker, Habitat, Polaris 

Annual and perennialbroadleaf weeds, brush, trees.Saltcedar, Russian olive, tanoak 

no 

Pre and post

Soil or foliar 

Rng For RAq OGM ROW R&C 0.45 1.5 √ √ √ 100 >11,000 High High Inter­ mediate 

Metsulfuron methyl 

Escort, Patriot,PureStand 

Whitetop, perennial pepperweed and othermustards and biennial thistles. 

broadleaf,

woody

plants 

Post

Soil or foliar 

Rng For OGM ROW R&C 0.03 0.15 √ √ √ 35 9,500 High High Inter­ mediate 

Picloram

Triumph, OutPost, Tordon 

Perennial and woody species.Knapweeds, starthistle,thistle, bindweed,leafyspurge, rabbitbrush, rush skeletonweed, and poisonoak. 

broadleaf,

woody

plants 

Pre and post

Foliar 

Rng For OGM ROW R&C 0.4 1 √ √ √ √ 16 200,000 High High Inter­ mediate 

Sulfometuron methyl 

Oust, Spyder 

Downy brome, annual and perennial mustards, and medusahead. 

no 

Pre and post

Soil or foliar 

For 

OGM ROW R&C 0.14 0.38 E E √ no 78 70 Inter­ mediate High Low 

Tebuthiuron 

Spike 

Creosotebush and sagebrush (thinning). 

broadleaf,

woody

plants 

Pre and post

Soil 

RngOGM ROW R&C 0.5 4 E √ 80 2,500 High High Inter­ mediate 

Triclopyr

Garlon, Renovate,Element 

Saltcedar, purple loosestrife, Canada thistle, tanoak,Himalayan blackberry 

broadleaf,

woody

plants 

Post

Foliar 

Rng For RAq OGM ROW R&C 1 10 √ √ √ 20 (salt) 780 (ester) 435 High High Inter­ mediate 

1See Appendix 9 (Herbicides) for the full list of herbicide trade names allowed for use on BLM Lands in Oregon, including formulations with 2 or more active ingredients.2Rng = Rangeland For = Forest Land RAq = Riparian or Aquatic

OGM = Oils, Gas, and Mineral Sites ROW = Rights-of-Way R&C = Recreation and Cultural Sites

3Shading denotes herbicides that are limited, by PEIS Mitigation Measures, to typical application rates, where feasible.The maximum application rate for these herbicides is shown for informational purposes.4 √ indicates herbicides that would be available statewide; E indicates herbicides that would be available only to districts east of the Cascades.5Aerial spray not allowed for any districts west of the Cascades under Alternatives 3 and 4.6 K : Soil organic carbon sorption coefficient of an active ingredient in mL/g.For a given chemical, the greater the K value, the less soluble the chemical is in water and the higher affinity the chemical has for soil oc oc organic carbon.For most chemicals, a higher affinity for soil organic carbon (greater Koc) results in less mobility in soil. 7Solubility indirectly relates to runoff potential, if solubility number is low runoff potential is high8SPISP II = Soil Pesticide Interaction Screening Procedure version II, which is a NRCS model that calculates leaching potential from basic soil properties (USDA 1994b).9 PLP - Pesticide Leaching Potential indicates the tendency of a pesticide to move in solution with water and leach below the root zone.A low rating indicates minimal movement and no need for mitigation.PLP is 

calculated according to a WIN-PST algorithm, and then the resulting rating is adjusted for type of spraying being conducted.

10 PSRP - Pesticide Solution Runoff Potential indicates the tendency of a pesticide to move in surface runoff in the solution phase.A rating as calculated according to a WIN-PST algorithm indicates the potential for 

pesticide loss in solution runoff.Ratings are adjusted according to type of spraying being conducted.

11 PARP - Pesticide Adsorbed Runoff Potential indicates the tendency of a pesticide to move in surface runoff attached to soil particles.A rating as calculated according to a WIN-PST algorithm indicates potential for 

pesticide movement adsorbed to sediment.Ratings are adjusted according to type of spraying being conducted.Data source: USDA 2006b

43 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Assumptions and Information about Treatment Acres 

Integrated Vegetation Management 

Most BLM and BLM-authorized vegetation management is done by, or in support of, rangeland management, 

forest management, riparian management, wildlife and fisheries management, wildland fire management, 

and/or the maintenance of infrastructure. Types of herbicide treatments that may be conducted in support of 

these programs under one or more of the alternatives include invasive weed control, fish and wildlife habitat 

improvement, habitat improvement for Bureau Sensitive and Federally Listed species, restoration of riparian 

habitats, hazardous fuels reduction, and the control of vegetation encroachment into rights-of-way and other 

developments. The BLM’s overarching vegetation management goal is: 

Through an interdisciplinary collaborative process, plan and implement a set of actions that improve 

biological diversity and ecosystem function and which promote and maintain native plant communities that 

are resilient to disturbance and invasive species. Healthy functioning plant communities will enhance the 

ability to attain economic benefits on public lands (PEIS:2-1). 

The Federal Insecticide, Fungicide, and Rodenticide Act directs Federal agencies to use an integrated pest 

management approach to manage pests (including vegetation), stating “Integrated Pest Management is a 

sustainable approach to managing pests by combining biological, cultural, physical, and chemical tools in a way 

that minimizes economic, health, and environmental risks” (7 U.S.C. § 136r-1). 

In order to control and manage invasive and unwanted vegetation, BLM uses an integrated vegetation 

management (IVM) approach. This approach involves the use and coordination of a variety of management 

techniques that are guided by numerous BLM and Department of the Interior manuals2

. These include BLM 

Handbook H-1740-2, Integrated Vegetation Management (USDI 2008a), BLM Manual 9015, Integrated 

Weed Management (USDI 1992b); BLM Manual 9011, Chemical Pest Control, (USDI 1992c); BLM Manual 

9014 Use of Biological Control Agents of Pests on Public Lands (USDI 1990); BLM Manual 9220 Integrated 

Pest Management3 (USDI 1981); Department of the Interior Manual 517 DM 1, Pesticides, Integrated Pest 

Management Policy (USDI 2007e); and, 609 DM Weed Control Program (USDI 1995b). 

The goal of integrated vegetation management is to prevent the spread of noxious weeds and other invasive 

plants, to eradicate early-detected noxious weed species in areas where certain weeds have not yet become 

established, and to control weeds where they have become established (PEIS:2-3). It is important to understand 

the entire integrated vegetation management approach, because it is only in this context that the proposal to 

increase the number of available herbicides must be viewed. The IVM components described in this section will 

continue to apply to whichever alternative is selected. 

Planning and Analysis 

In Oregon, each BLM district prepares a planning document in compliance with the National Environmental 

Policy Act (NEPA) and BLM Manual 9015 that outlines the integrated vegetation management actions they will 

be conducting. These weed management plans place an emphasis on preventing the establishment and spread of 

2 Manuals are regularly updated so specific actions or language referenced in this section could change. It is not 

expected that the overall use of an integrated vegetation management approach would be removed. 

3 Integrated vegetation management (IVM) is a subset of integrated pest management, so for this EIS the terms are 

essentially interchangeable. 

44 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

new infestations through pre-project surveys, prevention stipulations, early detection and responding rapidly to 

new infestations. In addition to the districts’ weed management plans, during all NEPA planning processes for 

ground disturbing projects and projects that have the potential to alter plant communities, the districts are required 

to assess the risk of introducing noxious weeds.4

 If, through this analysis, it is determined that there is a moderate 

or high risk of spread, the districts are required to develop a noxious weed risk assessment that identifies actions 

to be taken to reduce or prevent the spread of noxious weeds and to conduct monitoring after the completion of 

the project to prevent noxious weed establishment on previously uninfested sites (USDI 1992b). 

In Oregon, each BLM district has also identified a natural resource specialist with responsibility for managing the 

invasive plants and implementing the district’s integrated vegetation management strategy. These specialists help 

ensure that invasive plant management issues and concerns are integrated into all of BLM’s programs, policies 

and actions. 

Prevention and Education 

One of the most important elements of the BLM’s integrated vegetation management approach is raising 

internal and external awareness of the threats of invasive and unwanted vegetation and promoting prevention 

actions. This includes conducting trainings for the public, employees, and contract personnel that teach weed 

identification, prevention, and effective control techniques. The BLM is actively involved in outreach efforts to 

raise awareness through such means as coordination and cooperation with the Oregon Department of Agriculture, 

Counties, Cooperative Weed Management Areas, the Cooperative Extension Service, and others to create and 

present educational materials, brochures, traveling weed information displays, and other education materials. 

Prevention techniques that are encouraged or required include equipment and vehicle washing, avoiding entry into 

infested areas, and using weed-free seed, hay, and other materials. Additionally, districts are directed to prepare 

Weed Prevention Schedules annually to outline weed prevention practices and responsibilities. BLM cooperates 

with the State for weed prevention and control. Prevention and early detection programs have been shown to 

have benefit-cost ratios as high as 30:1 and more (Radke and Davis 2000). 

Early Detection Rapid Response 

The BLM places a management emphasis on preventing the establishment of noxious weeds into weed-free areas. 

BLM trains employees to identify noxious weeds and to report new infestations so they can be addressed as 

quickly as possible. The objective is to prevent the weeds from becoming established and spreading. 

In areas where noxious weeds are established, the Oregon Department of Agriculture classifies them as either 

Class A or Class B, and they are managed based on that classification (USDI 1992b). Class A weeds are nonnative, have a limited distribution, and pose a serious threat to landscape function. Class A weeds receive the 

highest priority for management with the objective of complete control or eradication. Class B weeds are also 

non-native and are determined to be potentially harmful, but they may be more common in some regions of 

the State. The goal is to control the spread of Class B weeds, decrease their population size, and eliminate the 

weed if possible. 

The BLM uses this weed classification system along with the Federal Noxious Weed List (USDA 2006c) to help 

prioritize their treatments. Other factors that influence which infestations are going to receive treatment include 

the aggressiveness of the weed species, the size of the infestation, the threat it poses to the surrounding ecosystem, 

and the BLM’s potential to be effective in treating the infestation. 

Other invasive plants should also be included in this analysis, but current handbook direction does not require it. 

45 

4
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Coordination with Partners 

The BLM works closely with private landowners, County Weed Boards, watershed councils, Soil and Water 

Conservation Districts, Cooperative Weed Management Areas, State agencies and other Federal agencies in 

an effort to increase weed prevention and treatment effectiveness. These close working relationships allow 

for technology and information sharing, more accurate weed inventories, the identification of monitoring and 

research needs, more effective outreach and control treatments, and a more efficient use of limited resources in the 

management of weeds. 

State and County Level Coordination 

The BLM is required to coordinate project plans with State and local agencies under several acts, including 

the Clean Air Act, the Sikes Act, FLPMA, and Section 106 of the National Historic Preservation Act. The 

BLM coordinates closely with State resource management agencies on issues involving the management of 

public lands, the protection of fish and wildlife populations, (including Federal- and State-listed threatened and 

endangered species), noxious weeds and other invasive plants, fuels and wildland fire management, and herbicide 

application. Herbicide spills are also coordinated with State and local water quality agencies to ensure emergency 

actions and cleanup are in compliance with applicable water quality standards, and do not result in unacceptable 

surface or ground water contamination. 

Local and State agencies work closely with the BLM to manage weeds on local, State, and Federal lands, 

and often conduct weed treatments on public lands. The BLM participates in exotic plant pest councils, State 

vegetation and noxious weed management committees, State invasive species councils, County weed districts, 

and cooperative weed management areas found throughout the State. Most Oregon counties have a Weed 

Management Program and official contact person. The ODA Weed Control Program coordinates closely with the 

BLM, Forest Service, and others in the listing of noxious weeds, and serves as the primary lead in setting control 

priorities in the State. 

The Healthy Forests Restoration Act directs the Forest Service and BLM to develop an annual program of work 

for Federal land that gives priority to authorized hazardous fuel reduction projects that provide for protecting 

at risk communities or watersheds. The recommendations made by Community Wildfire Protection Plans are 

taken into account by the agencies in accordance with Healthy Forests Restoration Act, which gives priority in 

allocating funding to communities that have adopted these plans, or that have taken measures to encourage willing 

property owners to reduce fire risk on private property. 

Cooperative Weed Management Areas 

Cooperative Weed Management Areas (CWMAs) are composed of local, private, State, and Federal interests. 

CWMAs typically center on a particular watershed or similar geographic area in order to pool resources and 

management strategies in the prevention and control of weed populations. Much of the BLM’s on-the-ground 

invasive plant prevention and management is done directly or indirectly through CWMAs. The BLM participates 

in numerous CWMAs throughout Oregon. 

Treatment Methods 

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). In treating noxious 

weeds, the BLM has a variety of tools available including the use of traditional State-approved biological controls 

 46 
 

Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

(such as the use of insects, parasites, and pathogens that reduce the vigor, competitiveness and/or reproductive 

capacity of the noxious weed), the use of mechanical methods (such as hand-pulling, mowing or tilling), burning, 

seeding or planting species that compete with the weeds, and the application of herbicides. Pages 2-8 and 9 in 

the PEIS provide additional information about the evaluation process leading to the selection of a vegetation 

treatment method. 

In those instances where it is determined that the use of herbicides is the most appropriate tool to treat noxious 

weeds or other unwanted vegetation, BLM districts are required to prepare a Pesticide Use Proposal5

 and 

complete or reference the environmental analysis that analyzes the effects of the type of treatment being proposed. 

The Pesticide Use Proposal (PUP) and associated NEPA analysis document the relative merits of controlling 

the noxious weed using other methods, describes why the use of herbicides is the most appropriate treatment 

method, and, if applicable, how it will be used as part of an overall integrated vegetation management strategy 

for that site (for example – an area may be sprayed with an herbicide this year and it will be followed up with 

hand pulling of any weeds found the following growing season)(USDI 1992c). The PUP identifies and describes 

the location of the area to be treated, the target species, and the herbicide and application rate and method to be 

used, as well as describing all anticipated impacts to non-target species and susceptible areas. It also evaluates 

the relative benefits to be derived from the use of the herbicide against the potential risks posed by their use. 

Completed PUPs are submitted through the District Manager to the Oregon State Office for review and approval. 

All herbicides are applied by certified applicators. A Pesticide Application Record is completed within 24 hours 

of the application documenting environmental conditions at the time of treatment as well as actual herbicide use, 

treatment method, equipment used, and personnel present. 

Restoration 

Weed control plans should include a strategy for rehabilitating the site to prevent reoccurrence of the invasive 

plant to the greatest extent possible. Passive restoration or rehabilitation after control of small infestations 

usually involves allowing surrounding native plants to reseed or grow to reoccupy the site. Seeding or planting 

is generally an element of larger invasive weed control projects, or be used as a prevention treatment following 

disturbances where invasive plants are anticipated. The season and nature of any site disturbance associated with 

the weed control effort must be designed to favor the recovery of desirable natives, and discourage reinvasion 

with weeds. Minimizing site disturbances often associated with early-seral noxious weeds is one reason to select 

herbicide use over mechanical or other methods. 

Monitoring 

Appendix 3 describes implementation and effectiveness monitoring requirements from BLM Manual Section 

9011. Implementation monitoring may also be specified in the local Resource Management Plan and/or the 

Biological Assessment or Opinion associated with the project. Implementation monitoring may be accomplished 

by: reviewing the Pesticide Application Records (PAR) completed at the time of treatment; comparing the PAR 

with the Pesticide Use Proposal (described above) or project NEPA decision; or, reviewing the PAR to ensure 

compliance with all SOPs and mitigation measures. The PAR documents the actual rate, time, and location of 

application as well as other factors and considerations, allowing a determination of whether actual application was 

consistent with plans and requirements documented in the site-specific NEPA decision or Pesticide Use Proposal. 

The 9011 Handbook also provides technical guidance on post-treatment evaluations for pesticide applications to 

occur within two years of treatment. Effectiveness monitoring can be formal or informal and typically compares 

5 A pesticide is any substance that is used to control, prevent, destroy, repel, or mitigate a pest. This includes herbicides, 

insecticides, and fungicides. 

47 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

vegetation characteristics of a site before and after treatment. Effectiveness monitoring typically includes 

recommendations for additional monitoring and weed control actions. See Appendix 3 for additional discussion 

of existing and potential monitoring. 

Reporting 

The Pesticide Application Records for applications on BLM lands are compiled by the BLM State Office and used 

to develop State, national, and Environmental Protection Agency (EPA) summaries and reports. 

Herbicide Treatment Methods 

“Determine, for each target pest, the possible courses of action and evaluate relative merits for controlling the pest 

with the least adverse effects on the environment” 

Chemical Pest Control Handbook (BLM Manual 9011 - USDI 1992c)

 “[W]here it is determined the use of herbicides is the most effective tool choose the lowest risk, most effective 

approach that is feasible for each pest [and manage] through cost-effective means that pose the least risk to 

humans, natural and cultural resources, and the environment” 

(USDI 2007e) 

Herbicides are often the most effective control method: 

• on pure stands of a single weed where desirable and non-target plants are scarce or absent; 

• for rhizomatous weed species that would otherwise require repeated cutting or pulling for control; 

• on plants whose characteristics make them difficult or impossible to remove with non-herbicide methods6; 

•		 in areas where non-herbicide methods are cost prohibitive; 

•		 in areas where non-herbicide methods have unacceptable adverse impacts to native plants; 

•		 in areas where heavy soil disturbance is not acceptable; 

•		 for species located in remote areas or limited access where non-herbicide methods are not feasible; 

•		 in combination with other control treatments (for example, woody species like saltcedar, Russian olive, 

and Siberian elm can be controlled by cutting stems close to the ground in the fall and then spraying or 

wiping the stems with an herbicide registered for this use). 

Herbicide application methods depend upon: the treatment objective (eradication, containment, or reduction); 

accessibility, topography, and size of the treatment area; characteristics of the target species and the desired (nontarget) vegetation; location of susceptible areas and potential environmental impacts in the immediate vicinity; 

anticipated costs; equipment limitations; and meteorological and vegetative conditions of the treatment area at the 

time of treatment. 

Herbicide application schedules are designed to minimize potential impacts to non-target plants and animals, 

while meeting the objective of the vegetation treatment program. The application timing and rates depend upon 

the target species, the presence and condition of non-target vegetation, soil type, depth to the water table, presence 

of other water sources, the label requirements, health risks, and other factors. 

BLM policy states that all herbicides will be applied by certified applicators or under the direct supervision of a 

certified applicator. See Assumptions about Application Methods later in this Chapter for more information. 

6 For example, Canada thistle root fragments readily resprout. 

48 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

Herbicides can be applied with a variety of methods. Table 3-2 shows different methods, along with the percent 

that they have been used in the past. This is expected to change under the action alternatives with the addition of 

imazapic; see the Treatment Acres, Gross Acres and Net Acres, and Pounds of Herbicides to be Applied section 

later in this Chapter for more information. 

Table 3-2: Herbicide aPPlicaTion meTHods on blm lands in oregon 

Herbicide Application Method Percent of Total Use (2000-2007) 

Aerial 7% 

Helicopter 5% 

Fixed Wing 2% 

Ground Application 93% 

Back pack foliar spray 39% 

ATV / UTV / Truck off-road 33% 

ATV / UTV / Truck on an existing road 20% 

Cut stump / wick / wipe / hack and squirt 2% 

Herbicides can be applied aerially with helicopters or fixed-wing aircraft7. Operation of helicopters is more 

expensive than operation of fixed-wing aircraft, but helicopters are more maneuverable and can fly closer to 

the ground over uneven terrain. Helicopters also are more effective for treating target vegetation in areas with 

multiple vegetation types. Between 2000 and 2007, application by helicopter accounted for approximately 5 

percent of herbicide application on BLM lands in Oregon, and fixed-wing aircraft accounted for about 2 percent. 

All of these applications were east of the Cascades. 

7 Aerial application is not permitted west of the Cascades under Alternatives 3 and 4. SOPs and PEIS Mitigation 

Measures prohibit aerial application of certain herbicides like diquat. 

49 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

All other herbicide application on BLM lands in Oregon has been done by ground application. Thirty-nine 

percent of herbicides on BLM lands in Oregon are applied with a backpack foliar sprayer. This is usually done 

only in small areas, in areas inaccessible by vehicle, and in areas where weeds are scattered. A backpack sprayer 

is used because it can target specific plants, so that effects to non-target species can be kept to a minimum. 

Backpack sprayers are generally levered not motorized. 

Herbicides may also be basally 

applied with a spray bottle, wick 

(wiped on), or wand (sprayed 

on). Herbicides can be applied to 

trees around the circumference of 

the trunk on the intact bark (basal 

bark), to cuts in the trunk or stem 

(frill, or “hack and squirt”), to cut 

stems and stumps (cut stump), 

or injected into the inner bark. 

From 2000-2007, these types of 

spot treatment methods accounted 

for approximately 2 percent of 

herbicide application on BLM 

lands in Oregon. 

 50 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

The remainder (about 53 percent) of herbicide application on BLM lands in Oregon has been done with spreaders 

or hand-held sprayers attached to vehicle-mounted tanks. Spray tank sizes vary from 15-25 gallons on an allterrain vehicle (ATV) or utility vehicle (UTV), to 100 or more gallons on a truck. Using a large tank provides 

the advantage of less loading and mixing of herbicides, which, in turn, leads to less accidental spills and a more 

accurate rate of application. About three-fifths of ATV /truck applications have been done off-road with a handheld sprayer attached to a small tank, and the remaining two-fifths on an existing road, trail, or right-of-way. 

Most of these applications have been spot treatments (e.g., hand-held sprayers connected by hose to the tank); 

fewer have been done with spreaders or booms. Under Alternatives 4 and 5, there would likely be an increase in 

boom applications from an ATV or truck, and a corresponding decrease in mowing along roadways. 

51 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

An indeterminate (small) 

percentage of treatments 

might be done by horseback. 

This would likely occur 

in areas where ATV 

access was not practical 

(e.g. susceptible habitat, 

wilderness areas, areas with 

steep terrain), but where a 

larger tank size was needed. 

Non-Herbicide 

Treatment Methods 

This EIS addresses making various herbicides 

available to BLM’s existing vegetation 

management program. Non-herbicide treatments 

are already addressed in Resource Management 

Plans and related project NEPA analyses, and 

discussed in the National Vegetation Treatments 

Programmatic Environmental Report (PER). 

However, to assist in cumulative effects 

analyses, descriptions of non-herbicide treatment 

methods are included here. (Non-herbicide 

treatment acres for invasive plants are included 

on Table 3-3) 

As with herbicide application methods, the 

type of non-herbicide treatment method chosen 

depends on the treatment objective (eradication 

or reduction); accessibility, topography, and size 

of the treatment area; characteristics of the target 

species and the desired vegetation; location of 

susceptible areas and potential environmental 

impacts in the immediate vicinity; anticipated 

costs; equipment limitations; meteorological and 

vegetative conditions of the treatment area at the 

time of treatment; and, other factors. 

 52 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

This EIS defines manual methods as non-motorized; all mechanical methods include motorized equipment. 

Manual methods such as pulling, digging, and grubbing weeds, can be used to control some invasive plants, 

particularly if the population is relatively small. These techniques can be extremely specific, minimizing damage 

to desirable plants and wildlife species, but they are generally labor and time intensive. Treatments must typically 

be administered several times annually to prevent the weed from re-establishing. In the process, laborers may 

trample vegetation and disturb soil, providing prime conditions for re-invasion by the same or other invasive 

plants. Manual techniques can be effective for small infestations and/or where a large pool of labor is available. 

They can be used in combination with other techniques, for example, when shrubs are pulled and cut, and resprouts and seedlings are treated with herbicides or fire several weeks or months later (Tu et al. 2001). 

53 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Mechanical methods include weed whackers, chainsaws, chaining, blading, disking, and mowing, including flail 

mowing, and boom mowers. Some of these methods (e.g. chainsaws and weed whackers) can be more targetspecific than others; all methods share some of the drawbacks that manual methods do (need of repeat treatment, 

disturbed vegetation and soil disturbance can promote invasive weeds, disturbance to non-target species, etc). 

These methods are the typical methods currently used along rights-of-way. Mechanical treatments in rights-ofway have the potential to spread a small invasive plant infestation across many miles. 

When using mechanical and manual methods, all equipment and clothing is normally cleaned and inspected 

before being moved off-site. This lessens, but does not eliminate, the possibility of spreading the weed(s) to the 

next worksite. 

54 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

55 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Directed Livestock can reduce weed abundance at a particular site. However, grazing will rarely, if ever, 

completely eradicate invasive plants. Grazing animals may be particularly useful in areas with limited access, 

severe slopes, or where herbicides cannot be applied (e.g., near water). Animals are brought into an infested area 

at a time when they will be most likely to 

damage the invasive plants without causing 

unacceptable damage to the desirable species 

or environment. An example would be to 

time livestock grazing of cheatgrass prior 

to emergence of native grasses so the native 

grasses can grow in the absence of cheatgrass 

competition. 

Some animals do not graze uniformly, but 

can be focused in a specific area with the use 

of fences, molasses, or salt licks (Tu et al. 

2001). Targeted grazing usually does not kill 

the plants, just suppresses growth, spread, 

and reproduction. It can be used in addition 

to seeding to restore native habitat. As with 

many other treatments, directed livestock can 

be most effective when used in combination 

with other treatments. 

Biological Control (biocontrol) is the use of non-native insects, pathogens, or other organisms to feed upon, 

parasitize, or otherwise interfere with a targeted weed species. Plant-eating insects, nematodes, mites, or 

pathogens can be effective at killing or weakening weed species. They often keep the weed in balance when they 

occur in the original native community from where the weed originated. Absence of these natural community 

controls is often what allows a weed to spread and become invasive in its new habitat. Introducing control agents 

is strictly managed because they have inherent risks to the ecosystem. Most of the species used for biological 

control are host-specific and are not known to attack non-target species. Biological controls will seldom remove 

an invasive plant entirely, but can dampen its reproduction, spread and extent, and keep it in some sense of 

balance compared to other plants in that 

community. Ideally, biocontrol agents 

are host-specific and will die once they 

kill their host. However, some biocontrol 

programs have resulted in irreversible harm 

to untargeted (non-pest) organisms and 

to ecological processes (Tu et al. 2001). 

Introduced (alien) biocontrols are always 

vigorously tested by the Federal Animal 

and Plant Health Inspection Service and 

licensed by the State before use is allowed, 

to ensure that they are not likely to become 

pests themselves. 

56 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

The most effective prescription fi res for weed 

control are typically those administered just 

before flower or seed set, or at the young 

seedling/sapling stage. Like other treatments, 

timing is critical and is dependent on 

characteristics of the weed, desirable plants, 

soil moisture, and environmental conditions. 

Other treatment methods are often used in 

conjunction with fire, including the use of 

herbicides and/or seeding. In some cases, 

prescribed burns can unexpectedly promote 

an invasive, particularly when their seeds 

are adapted to fire, or when they resprout 

vigorously. Most successful weed control 

efforts using burning include native plant 

seeding and the restoration of historical 

(natural) fire regimes. 

Invasive plants often move into places where the native vegetation 

has been disturbed by vehicles, fire, grazing, herbicide treatments, 

etc. Revegetation of a disturbed site is a key component of weed 

management, particularly when a site does not have a suitable 

seed source to establish healthy functioning vegetation. Seeding 

and planting can be used to control weed problems by establishing 

the desired plant species. It is often used as a follow up to other 

treatment methods or as a preventative treatment following 

wildfire (Colorado Natural Areas Program et al 2000). 

Treatment Acres, Gross Acres and Net Acres, 

and Pounds of Herbicides to be Applied 

Treatment Acres – All Methods 

Estimates of the number of acres to be treated annually with each herbicide and non-herbicide methods under 

each alternative are displayed in Table 3-3. Estimates are shown in acres so that they can be compared to each 

other and to other non-herbicide treatments. They were developed by district experts having knowledge of local 

treatment histories and of existing and expected invasive plant and other vegetation control needs, and assuming 

current budget trends. However, as with acreage projections in the PEIS, the estimates presented in Table 3-3 

are approximate and used only as a guide for the analysis. The accuracy of estimates is limited by the uncertain 

nature of future invasive weed spread rates, and by uncertainties about future program funding and emphasis. 

Estimates for Alternatives 1 through 3 are probably more precise than those for Alternatives 4 and 5, in part 

because portions of Alternatives 4 and 5 rely on funding sources not currently directed toward invasive plant 

control. All estimates were rounded upward to help ensure future use was adequately analyzed. The estimates are 

projected to apply for the next 10 to 20 years. Actual annual treatment levels could also vary from year to year 

based on changes in program emphasis or priorities, fluctuations in annual budgets, opportunities for cost savings 

with partnerships, and the availability of external funding. 

57 
Table 3-3. esTimaTed1 annUal TreaTmenT acres WesT/easT7 of THe cascades for eacH alTernaTive. 

Herbicide 

Alt 1: No use of

herbicides 

Alt 2 (No Action): 

Use 4 herbicides to

treat noxious weeds 

Alt 3: Use 11-13 

herbicides to control

invasive weeds and

pests and diseases 

Management

objective: vegetation

treatment in ROWs,

admin. sites, and

recreation sites under 

Alt. 4 

Management

objective: vegetation

treatment for habitats

in Conservation Plans

under Alt. 4 

Alt 4: Use 11-16 

herbicides to control

invasive weeds, pests

and diseases, and meet

other management

objectives2 

Alt 5: Use 18

herbicides to control

vegetation 

Herbicides Currently Approved for use on BLM Lands in Oregon (for noxious weed control only)

2, 4-D NA W: 1800 E: 6700 W: 2100 E: 1900 W: 400 E: 900 W: 100 E: 600 W: 2400 E: 3300 W: 2500 E: 5400 

Dicamba NA W: 100 E: 4500 W: 200 E: 800 W: 100 E: 700 W: 0 E: 100 W: 200 E: 1500 W: 200 E: 1500 

Glyphosate NA W: 5200 E: 700 W: 2300 E: 400 W: 400 E: 1100 W: 200 E: 100 W: 2700 E: 1500 W: 2800 E: 1500 

Picloram NA W: 200 E: 3600 W: 400 E: 1100 W: 100 E: 600 W: 0 E: 1300 W: 500 E: 2900 W: 500 E: 2900 

Additional Herbicides Proposed for Use in One or More of the Alternatives

Bromacil NA NA NA W: NA E: 700 W: NA E: 0 W: NA E: 700 W: 100 E: 700 

Chlorsulfuron NA NA W: NA E: 3300 W: NA E: 800 W: NA E: 0 W: NA E: 4100 W: 100 E: 4100 

Clopyralid NA NA W: 300 E: 1400 W: 0 E: 600 W: 100 E: 0 W: 300 E: 2000 W: 300 E: 2000 

Diflufenzopyr+ Dicamba NA NA NA NA NA NA W: 100 E: 100 

Diquat NA NA NA NA NA NA W: 100 E: 100 

Diuron NA NA NA W: 100 E: 700 W: 0 E: 0 W: 100 E: 700 W: 100 E: 700 

Fluridone NA NA W: 200 E: 100 W: 0 E: 0 W: 0 E: 0 W: 200 E: 100 W: 200 E: 100 

Hexazinone NA NA W: 100 E: 100 W: 200 E: 100 W: 100 E: 0 W: 300 E: 100 W: 300 E: 100 

Imazapic NA NA W: 500 E: 11000 W: 100 E: 500 W: 100 E: 2300 W: 500 E: 13600 W: 500 E: 15700 Imazapyr NA NA W: 1200 E: 300 W: 400 E: 100 W: 100 E: 600 W: 1500 E: 1000 W: 1500 E: 1000 

Metsulfuronmethyl NA NA W: 500 E: 2000 W: 200 E: 800 W: 0 E: 100 W: 600 E: 2700 W: 600 E: 2700 

Sulfometuronmethyl NA NA W: NA E: 400 W: NA E: 800 W: NA E: 100 W: NA E: 1200 W: 200 E: 1200 

 58 
Herbicide 

Alt 1: No use of

herbicides 

Alt 2 (No Action): 

Use 4 herbicides to

treat noxious weeds 

Alt 3: Use 11-13 

herbicides to control

invasive weeds and

pests and diseases 

Management

objective: vegetation

treatment in ROWs,

admin. sites, and

recreation sites under 

Alt. 4 

Management

objective: vegetation

treatment for habitats

in Conservation Plans

under Alt. 4 

Alt 4: Use 11-16 

herbicides to control

invasive weeds, pests

and diseases, and meet

other management

objectives2 

Alt 5: Use 18

herbicides to control

vegetation 

Tebuthiuron NA NA NA W: NA E: 100 W: NA E: 100 W: NA E: 100 W: 100 E: 300 

Triclopyr NA NA W: 1500 E: 700 W: 500 E: 700 W: 100 E: 700 W: 1900 E: 2000 W: 2000 E: 2300 

Total Herbicide3 NA W: 7000 E: 9700 W: 8000 E: 22300 W: 1900 E: 7400 W: 200 E: 5500 W: 10000 E: 35100 W: 10200 E: 39800 

Mechanical4 W: 4100 E: 1000 W: 3300 E: 200 W: 3000 E: 200 

See Non-Invasive (Native) Vegetation Management later in this Chapter9 

Manual W: 2900 E: 600 W: 2000 E: 200 W: 2000 E: 200 

Rx Fire(Invasive Weed Control) 

W: 600

E: 3100 

W: 600

E: 5100 

W: 400

E: 12100 

Biocontrol5 W: 200 E: 200 W: 200 E: 100 W: 100 E: 100 

DirectedLivestock 

W: 100

E: 8700 

W: 100

E: 2700 

W: 100

E: 2700 

Seeding orplanting 

W: 1100

E: 20100 

W: 1300

E: 16300 

W: 1400

E: 21400 

Total Treatments3,6,8 

W: 8600

E: 33500 

W: 13400

E: 32100 

W: 14600

E: 43800

1 Numbers rounded up to the nearest 100.2 Management objectives in this case refer to vegetation treatment in ROWs, administrative sites, and recreation sites, and treatment for habitats in Conservation Plans. Alternative 4 combines Alternative 3 with 

these management objectives; however, columns may not add due to rounding, and the ability to use additional herbicides under Alternative 4 that are not available under Alternative 3.

3 Totals are not the total of the acres in the column. This is because:

• Tank mix treatments using two or more herbicides mixed together are shown as acres for each herbicide used, but the total would reflect the area of that treatment; or • Treatments could be performed on the same acre multiple times a year (e.g. spraying and then seeding), and the total just counts those acres once.

4 Non-herbicide treatments only include estimated acreage of noxious and invasive weeds. Alternatives 4 and 5 treat other native vegetation, and no attempt was made to estimate non-herbicide treatments of

other vegetation. See Trade-offs of Non-Invasive Plant Vegetation Management later in this chapter.

5 Biocontrol numbers indicate releases, not acres.6 Totals for Alternatives 1-3 are for invasive plants only.7 West of the Cascades is indicated with a W; east of the Cascades is indicated with an E.8 Acres are gross acres rather than net acres.9 Non-herbicide invasive plant treatments would continue under Alternatives 4 and 5 as described in Alternative 3. Treatments of native vegetation with herbicides would replace some non-herbicide treatments 

and this is described in the Non-Invasive (Native) Vegetation Management section later in this Chapter. 

59 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

For Alternatives 4 and 5, the number of road and power line rights-of-way miles, BLM road miles, and the 

number and nature of other BLM and cooperator developments were compiled, and existing NEPA and other 

planning documents for these developments, as well as maintenance histories and needs for these developments, 

were examined. These helped guide district estimates of acres of treatment needs for these two alternatives. 

Once treatment acres had been estimated, district experts determined which herbicides could be used for those 

treatments. For example, 700 acres of road might be treated with triclopyr, glyphosate, or 2,4-D (or a tank mix 

that would include some mixture of these three). For analysis purposes, Table 3-3 reflects this by reporting a 

weighted average of these acres under each herbicide; Table 3-4 shows the estimated range and weighted average 

of those acres. 

Table 3-4. esTimaTed annUal acres TreaTed in rigHTs-of-Way, adminisTraTive siTes, and recreaTion siTes 

Herbicide 

Management objective: 

vegetation treatment in 

ROWs, admin . sites, and 

recreation sites under Alt . 4 

(weighted average) 

Alt 4: Use 12-16 herbicides 

to control invasive weeds, 

pests and diseases, and 

meet other management 

objectives (weighted average) 

Alt 5: Use 18 herbicides to 

control vegetation (weighted 

average) 

2, 4-D 0 - 5,900 (1,300) 4,700 – 10,400 (5,700) 6,700 - 12,400 (7,900) 

Dicamba 0 – 3,800 (800) 1,100 – 4,700 (1,700) 1,100 - 4,700 (1,700) 

Glyphosate 0 – 7,100 (1,500) 3,000 – 9,700 (4,200) 3,100 - 9,800 (4,300) 

Picloram 0 – 3,200 (700) 2,800 – 5,900 (3,400) 2,800 - 5,900 (3,400) 

Bromacil 0 – 3,500 (700) 0 – 3,700 (700) 100 - 3,800 (800) 

Chlorsulfuron 0 – 4,100 (800) 3,300 – 7,400 (4,100) 3,400 - 7,500 (4,200) 

Clopyralid 0 – 3,200 (600) 1,800 – 4,800 (2,300) 1,800 - 4,800 (2,300) 

Diflufenzopyr + 

Dicamba 0 0 200 

Diquat 0 0 200 

Diuron 0 – 3,700 (800) 0 – 3,800 (800) 0 - 3,800 (800) 

Fluridone 0 300 300 

Hexazinone 0 – 1,000 (300) 300 – 1,000 (400) 300 - 1,000 (400) 

Imazapic 0 – 2,800 (600) 13,900 – 16,400 (14,100) 15,900 - 18,400 (16,200) 

Imazapyr 0 – 1,800 (500) 2,200 – 3,800 (2,500) 2,200 - 3,800 (2,500) 

Metsulfuron methyl 0 – 4,500 (1000) 2,600 – 6,800 (3,300) 2,700 - 6,900 (3,300) 

Sulfometuron methyl 0 – 3,800 (800) 500 – 4,300 (1,200) 700 - 4,500 (1,400) 

Tebuthiuron 0 - 100 (100) 100 - 700 (100) 400 - 1,000 (400) 

Triclopyr 0 – 5,000 (1200) 3,000 – 7,900 (3,900) 3,300 - 8,200 (4,300) 

Total Herbicide1 9,400 45,100 50,000 

1 Acres are gross project acres rather than net acres. 

 60 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

Gross Acres and Net Acres 

Gross acres are the area within which the plants are treated; the net acres are the actual area covered by the target 

plants where herbicide is applied. An example from Klamath Falls spot treatments reports 1,414 gross project 

acres and less than 15 net acres treated. Other treatments may have a ratio of 1:1. All herbicide application has to 

be reported as a minimum of one acre; that is, treating one plant is reported as treating one acre, treating 1⁄4 acre is 

reported as 1 acre, and treating 1 acre is reported as 1 acre. 

Examples of treatments from Pesticide Application Reports (PAR) 

Example 1: Herbicide treatments on European beachgrass following 

an 80-acre mechanical treatment (bulldozer and disc) where the 

distribution of re-sprouting beachgrass is relatively uniform across the 

treatment area (tending towards a monoculture). The PAR indicates 

that a tractor mounted 40’ boom completed the treatment in 4 hours 

and with a total of 78 acres treated. 

Gross acres = 80; Net acres = 78 

Example 2: Scotch broom along 2 miles of road where clusters of 

plants are seldom separated by more than 10 feet. The width of the 

treatment area averages 20 feet. The PAR indicated that a crew of 

three with a truck mounted tank and two hand sprayers completed 

treatment in five hours and reported two acres of treatment. 

Gross acres = 5 acres; Net acres = 2 acres 

Example 3: Medusahead rye sprouting following a late summer burn 

in a uniform pattern across the area (tending towards a monoculture, 

with an absence of desirable grasses and forbs). Fire maps indicate 

there are 8,100 acres within the 35,000-acre burn with these 

characteristics. Aerial application is selected as the most effective 

method to complete this large-scale treatment. The PAR indicates 19 

hours of airtime with total treatment acreage of 7960 acres. 

Gross acres 8100; Net acres = 7960 

Example 4: A 43-acre area has an infestation of dyer’s woad. The 

PAR states that approximately 800 plants were treated by a crew of 

three using backpack sprayers in an 8-hour period, with a total of 11 

acres treated within the treatment area. 

Gross acres = 43; Net acres 11 

Example 5: A seasonal wetland (dry) contains a 114-acre infestation of 

perennial pepperweed. The PAR indicates approximately 2,300 plants 

were treated in an 6 hour period with a spray buggy and 20’ boom, 

with a total of 37 acres treated within the infestation. 

Gross acres = 114; Net acres = 37 

61 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table 3-5. esTimaTed annUal PoUnds of Herbicides THaT WoUld be aPPlied aT TyPical and maximUm 

aPPlicaTion raTes easT/WesT of THe cascades for eacH alTernaTive. 

Herbicide lbs/acre at 

typical rate 

lbs/acre at 

maximum 

rate 

Alternative 2 Alternative 3 Alternative 4 Alternative 5 

lbs at 

typical rate 

lbs at max. 

rate 

lbs at 

typical rate 

lbs at max. 

rate 

lbs at 

typical rate 

lbs at max. 

rate 

lbs at 

typical rate 

lbs at max. 

rate 

Herbicides Currently Approved for use on BLM Lands in Oregon (for noxious weed control only) 

2, 4-D 1.0 1.91 W: 1800 

E: 6700 

W: 3420 

E: 12730 

W: 2100 

E: 1900 

W: 3990 

E: 3610 

W: 2400 

E: 3300 

W: 4560 

E: 6270 

W: 2500 

E: 5400 

W: 4750 

E: 10260 

Dicamba 0.25 2.0 W: 25 

E: 1125 

W: 200 

E: 9000 

W: 50 

E: 200 

W: 400 

E: 1600 

W: 50 

E: 375 

W: 400 

E: 3000 

W: 50 

E: 375 

W: 400 

E: 3000 

Glyphosate 2.0 7.0 W: 10400 

E: 1400 

W: 36400 

E: 4900 

W: 4600 

E: 800 

W: 16100 

E: 2800 

W: 5400 

E: 3000 

W: 18900 

E: 10500 

W: 5600 

E: 3000 

W: 19600 

E: 10500 

Picloram 0.4 1.0 W: 70 

E: 1260 

W: 200 

E: 3600 

W: 140 

E: 385 

W: 400 

E: 1100 

W: 175 

E: 1015 

W: 500 

E: 2900 

W: 175 

E: 1015 

W: 500 

E: 2900 

Additional Herbicides Proposed for Use in One or More of the Alternatives 

Bromacil 4.0 12.0 NA NA NA NA W: NA 

E: 2800 

W: NA W: 400 

E: 2800 

W: 1200 

E: 8400 E: 8400 

Chlorsulfuron 0.047 0.141 NA NA W: NA 

E: 155 

W: NA 

E: 465 

W: NA 

E: 193 

W: NA 

E: 578 

W: 5 

E: 193 

W: 14 

E: 578 

Clopyralid 0.35 1.0 NA NA W: 105 

E: 490 

W: 300 

E: 1400 

W: 105 

E: 700 

W: 300 

E: 2000 

W: 105 

E: 700 

W: 300 

E: 2000 

Diflufenzopyr + 

Dicamba 0.2625 0.35 NA NA NA NA NA NA W: 26 E: 26 

W: 35 

E: 35 

Diquat 1.0 4.0 NA NA NA NA NA NA W: 100 

E: 100 

W: 400 

E: 400 

Diuron 6.0 20.0 NA NA NA NA W: 600 

E: 4200 

W: 2000 

E: 14000 

W: 600 

E: 4200 

W: 2000 

E: 14000 

Fluridone 0.15 1.3 NA NA W: 30 

E: 15 

W: 260 

E: 130 

W: 30 

E: 15 

W: 260 

E: 130 

W: 30 

E: 15 

W: 260 

E: 130 

Hexazinone 1.0 8.0 NA NA W: 100 

E: 100 

W: 800 

E: 800 

W: 300 

E: 100 

W: 2400 

E: 800 

W: 300 

E: 100 

W: 2400 

E: 800 

Imazapic 0.0313 0.1875 NA NA W: 16 

E: 344 

W: 94 

E: 2063 

W: 16 

E: 426 

W: 94 

E: 2550 

W: 16 

E: 491 

W: 94 

E: 2944 

Imazapyr 0.45 1.5 NA NA W: 540 

E: 135 

W: 1800 

E: 450 

W: 675 

E: 450 

W: 2250 

E: 1500 

W: 675 

E: 450 

W: 2250 

E: 1500 

Metsulfuron 

methyl 0.03 0.15 NA NA W: 15 

E: 60 

W: 75 

E: 300 

W: 18 

E: 81 

W: 90 

E: 405 

W: 18 

E: 81 

W: 90 

E: 405 

Sulfometuron 

methyl 0.14 0.38 NA NA W: NA E: 56 

W: NA 

E: 152 

W: NA 

E: 168 

W: NA 

E: 456 

W: 28 

E: 168 

W: 76 

E: 456 

Tebuthiuron 0.5 4.0 NA NA NA NA W: NA 

E: 50 

W: NA W: 50 

E: 150 

W: 400 

E: 400 E: 1200 

Triclopyr 1.0 10.0 NA NA W: 1500 

E: 700 

W: 15000 

E: 7000 

W 1900 

E: 2000 

W: 19000 

E: 20000 

W: 2000 

E: 2300 

W: 20000 

E: 23000 

Estimated annual total lbs: W: 12295 

E: 10485 

W: 9196 

E: 5340 

W: 11669 

E: 18873 

W: 12678 

E: 21564 

1 Shading denotes herbicides that are limited, by PEIS Mitigation Measures, to typical application rates, where feasible. The maximum application rate for these 

herbicides is shown for informational purposes. 

 62 
 

 

Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

Pounds of Herbicide to be Applied 

BLM and Forest Service risk assessments analyze a typical rate of application and a maximum rate of application. 

Maximum rates are the pounds per acre that can be sprayed, and are defined by the EPA and printed on the 

herbicide product label. Typical rates vary by application type, and may be different for the BLM than those for 

lawn care companies or agricultural companies. These additional herbicides are often more effective at lower 

dosages; while acres of herbicides applied go up between Alternative 2 and Alternative 3, pounds of herbicides 

decrease substantially. Table 3-5 shows typical (for wildland use) and maximum rates for each herbicide, and 

the estimated annual pounds that each would total under each alternative. PEIS Mitigation measures limit use of 

some herbicides to their typical rate (where feasible) (see Table 3-5 footnote). 

Pesticide Use Reports 

The annual Pesticide Use Reports (PURs)8

 for 2006-2008, shown in Table 3-6, show actual statewide net acres, 

gross acres, and pounds of herbicides used. 

Table 3-6. 2006-2008 PesTicide Use rePorTs sUmmary 

Herbicide 

Acres Lbs of Herbicides 

Net acres Gross Acres Net as % of 

Gross 

Lbs of 

Herbicides 

Percent of 

Typical Rate 

Percent of 

Maximum Rate 

2008 

2,4-D 4,341 6,493 67% 6,812 105% 55% 

Dicamba 1,017 2,031 50% 937 185% 23% 

Glyphosate 5,248 5,290 99% 2,302 22% 6% 

Picloram 4,433 5,895 75% 2,477 105% 42% 

total 15,039 19,709 76% 12,528 

2007 

2,4-D 3,573 5,167 69% 7,737 150% 79% 

Dicamba 1,227 2,521 49% 1,264 201% 25% 

Glyphosate 2,859 2,931 98% 1,569 27% 8% 

Picloram 1,151 1,617 71% 1,118 173% 69% 

total 8,810 12,235 72% 11,688 

2006 

2,4-D 2,729 3,634 75% 6,022 166% 87% 

Dicamba 636 1,303 49% 641 197% 25% 

Glyphosate 3,038 3,075 99% 2,606 42% 12% 

Picloram 780 1,232 63% 766 156% 62% 

total 7,128 9,244 78% 10,035 

8 The PUR is the compilation of the PARs at the State level for EPA reporting. 

63 
 

 

 

 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

 64 

Pest and Disease Control in Alternative 3 

Herbicide use in Alternative 3 would be limited to noxious weeds and other invasive plants, and to an estimated 

250 acres per year to treat native vegetation in State-designated quarantine areas as necessary to stop non-native 

pests and diseases. Because these treatments are so incidental to the main theme of Alternative 3, and represent 

less than one percent of the total herbicide use proposed for Alternative 3, many references to Alternative 3 

describe it as being limited to the control of invasive plants. For example, Tables 3-8 and 3-9 in this Chapter 

show zero (0) acres of native vegetation treatments under Alternative 3, because it would only add confusion 

to the Alternatives 4 and 5 rights-of-way and other treatments being discussed in that section. Referencing 

Alternative 3 as “invasive plants only” is simply for brevity and clarity; effects discussions and other information 

about Alternative 3 include and consider the 250 acres of native vegetation also expected to be treated annually, to 

control pests and diseases. 

Assumptions about Application Methods 

Most invasive weed treatments target new species, new or small populations of existing species, and advancing 

edges of larger populations in order to keep weeds from infesting new drainages and other geographic areas (see 

Noxious Weeds and Other Invasive Plants section in Chapter 4). In addition, most weed treatments are spot 

treatments directed at specific plants, and collateral damage is limited to the immediately surrounding area, if it 

happens at all. However, some acres are so infested with weeds (particularly annual grasses such as cheatgrass 

and medusahead, or mat-forming weeds such as purple loosestrife or spotted knapweed) that they have become a 

monoculture. Monocultures are often broadcast treated with booms. 

Sites that are too heavily infested with weeds for spot treatments are rarely treated with herbicides unless there are 

broader objectives requiring an unusually large investment, such as Federally Listed or Bureau Sensitive species 

habitat, campground, designated special area, and so forth. If site management objectives make treatment of 

heavily infested sites worthwhile, those same objectives will dictate the use of selective herbicides and extra effort 

to retain native plants, and/or prompt restoration. 

Table 3-2 (Herbicide Application Methods on BLM Lands in OR) earlier in this Chapter shows types of 

application methods, and at what rate (percentage) they have been used under the current program. The use of 

additional herbicides and additional vegetation treatment as described in the action alternatives would change 

those application rates. Under Alternative 3, cheatgrass and medusahead (invasive annual grasses that have 

infested more than 5 million acres in Eastern Oregon) would often be best controlled by aircraft application on 

the acres where desirable and non-target plants are absent or sparse (e.g. after large fires where these grasses are 

expected to dominate). Vegetation surrounding the perimeter of the infestation would likely be more varied, and 

herbicide application on the perimeter would likely happen on the ground. Table 3-7 shows the expected aerial 

and ground application percentages for each alternative. 

Table 3-7 groUnd and aerial Herbicide aPPlicaTion 

Application 

Method 

Herbicide Application 

Alt 2 

Alternatives 3, 4, and 5 Alternatives 4 and 5 Alternative 5 

Imazapic treatments east of 

the Cascades (primarily for 

controlling medusahead and 

cheatgrass) 

All other 

herbicide 

treatments 

under Alt 3 

Management objective: 

vegetation treatment in ROWs, 

admin. sites, and recreation 

sites under Alt. 4 

Management objective: 

vegetation treatment for 

habitats in Conservation 

Plans under Alt. 4 

Additional 

treatments 

proposed under 

Alt 5 

Aerial1 7% 90% 7% 2% 7% 7% 

Ground 93% 10% 93% 98% 93% 93% 

1 Aerial application would be only allowed east of the Cascades under Alternatives 3 and 4. 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

Under Alternatives 2 and 3, herbicide application would happen with methods that would seek to avoid all nontarget vegetation; that is, native (non-invasive) vegetation would be avoided with the use of selective herbicides or 

selective application methods. Under Alternatives 4 and 5, some applications would be to control all vegetation 

in administrative sites and recreation sites, which would likely change application selectivity. Under power lines 

west of the Cascades, a goal is to establish low growing vegetation and to prevent tree re-sprouting. This would 

most likely be done with spot or selective treatments. However, on roads, application would likely be performed 

by a truck with a mounted sprayer, as the goal would be to remove most vegetation, including vegetation 

invading pavement edges and vegetation that limits visibility. Most treatments on administrative or recreation 

sites would be spot treatments; however, some would use application methods and herbicides that would remove 

all vegetation. Habitat improvements, allowed under Alternatives 4 and 5, would be selective in order to keep 

desired vegetation. 

Total treatment acres are similar under Alternatives 1 and 2; most acres that would be treated with herbicides 

under Alternative 2 would be treated through other methods under Alternative 1. Fire would increase by more 

than 300 percent and manual and mechanical methods would increase by about 150 percent. 

Herbicide treatment acres increase by 13,600 acres annually (nearly double the acres) between Alternatives 2 and 

3, but use of the four herbicides available under Alternative 2 would decrease 52 to 83 percent under Alternative 

3. A majority of the increase in Alternative 3 is because of the availability of imazapic, which would be used 

on 11,500 acres, primarily east of the Cascades, to control monocultures of invasive annual grasses such as 

cheatgrass and medusahead. These acres are shown as an estimated annual average; at least some of the imazapic 

use would be to prevent invasive grass reinvasion after major fires and a 50,000-acre treatment every 6 or 8 

years would be a possible scenario. It would also be used to reduce invasive grass fuels hazards in the wildlandurban interface around rural communities, and as part of a fire-imazapic-seeding restoration treatment. Only 

monocultures of invasive plants would be treated with a boom; the majority of the treatments under Alternative 

3 would be done with selective methods. Seeding and planting and prescribed fire would increase significantly 

between Alternatives 2 and 3. These acres would often be duplicative to acres of herbicide treatments and would 

be part of restoring invasive weed monocultures to native vegetation. 

Alternative 4 (the proposed action) would, in addition to invasive plant treatments, add 2,000 acres annually 

west of the Cascades and 12,800 acres annually east of the Cascades. One-third of this would be for habitat 

improvements in Conservation Strategies; the remainder would be for administrative site, right-of-way, and 

recreation site treatments. Right-of-way treatments would usually be accomplished by the permit holder (e.g., the 

power or pipeline owner). 

Alternative 5 allows the use of herbicides for any non-commodity use. The acres (200 acres annually west of 

the Cascades and 4,700 acres annually east of the Cascades) that could be treated under Alternative 5 but not 

under any other alternative are primarily additional habitat improvement projects (e.g. reducing Western juniper 

encroachment into important sagebrush habitat). 

Under all alternatives, about 50 percent of the 2,4-D acres shown on Table 3-3 would be at low doses (oz. per 

acre) in a tank mix with other herbicides. 

Non-Invasive (Native) Vegetation Management 

In addition to invasive plant treatments listed for Alternative 3 on Table 3-3 (and footnoted to apply to 

Alternatives 4 and 5 as well), Alternative 4 would permit the use of herbicides for native vegetation treatments 

for rights-of-way, administrative sites, recreation sites, and limited habitat improvement treatments. Alternative 

65 
 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

5 would allow the treatment of native vegetation to meet all non-commodity objectives. Herbicide treatments for 

native vegetation control would be 15,100 acres under Alternative 4 and 20,000 acres under Alternative 5 (see 

Table 3-8). 

No attempt was made to quantify the total acres of non-herbicide native vegetation treatments already occurring 

on BLM lands in Oregon because such treatments cover a variety of objectives, are in the magnitude of a hundred 

thousand acres per year, and are not affected by the alternatives. However, for the portion of those acres that would 

start being treated with herbicides under Alternatives 4 and 5, the following substitution assumptions would apply: 

•		 For rights-of-way, administrative sites, and recreation sites, the BLM and cooperators have been 

accomplishing needed work with non-herbicide methods. 9,300 acres proposed for herbicide use for 

these objectives under Alternatives 4 and 5 shown on Table 3-8 likely represent similar acres of nonherbicide treatments under Alternatives 1-3 but are not included on Table 3-3. For comparison purposes, 

it is assumed that 90 percent of this work is currently done mechanically; the majority of the acres are in 

road maintenance (cleared now with mowers) and power line rights-of-way (generally mowers or large 

trees cleared with chainsaws). The remaining 10 percent is accomplished manually (e.g. poison oak in 

campgrounds). 

•		 Of the acres proposed for herbicide use to accomplish habitat improvement objectives under Alternative 

4 and various non-commodity objectives under Alternative 5, about 35 percent would replace treatments 

already being done with non-herbicide methods (e.g. chaining Western juniper), and 65 percent represent 

new opportunities (habitat treatments not currently being done because of high cost, unacceptable effects, 

or logistical issues). It is assumed that treatments currently being done through mechanical and manual 

means are in about the same proportion as treatments of invasive plants under Alternative 3: 60 percent 

mechanical, and 40 percent manual. 

Table 3-9 shows the application of the above assumptions. However, because the total amount of native 

vegetation treated through non-herbicide means is unknown, the table only shows the change in how native 

vegetation is treated under each alternative. These numbers are not totals; they merely show how acreages 

increase or decrease in relation to the no-action alternative. For example, under Alternative 4, 13,000 acres of 

native vegetation east of the Cascades would be treated with herbicides. Because of this, 7,905 acres would not be 

treated mechanically and 1,520 acres would not be treated manually. Under Alternative 3, which does not allow 

the treatment of native vegetation with herbicides9

, those acres, and an unknown number of other acres, would 

continue to be treated with mechanical and manual methods. These numbers do not affect the acres of invasive 

plants treated through mechanical and manual means; invasive plant treatments in Alternative 3 are assumed to 

remain constant through Alternatives 4 and 5. 

Table 3-8: esTimaTed annUal Herbicide TreaTmenT acres Under alTernaTives 3, 4, and 5 

Method 

Invasive Plant 

Treatment1 Native Vegetation Treatment 

Alternatives 

3,4,5 Alternative 3 

Rights-of-way, 

administrative sites, and 

recreation sites 

(under Alternative 4) 

Conservation Strategies 

(under Alternative 4) 

Total 

Alternative 4 Alternative 5 

WS ES WS ES WS ES WS ES WS ES WS ES 

Herbicides 8,000 22,300 0 0 1,900 7,400 200 5,500 2,100 13,000 2,300 17,700 1

 From Table 3-4. 

9 Except for pest and disease control in State-specified quarantine areas. 

66 
 

 

Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

Table 3-9. esTimaTed cHange in naTive vegeTaTion annUal TreaTmenT acres

 Method 

Total Native 

Vegetation 

treated under 

Alternatives 1-3 

(no-action) 

Treatment of 

native vegetation 

on rights-of-way, 

administrative 

sites, and 

recreation sites 

under Alternative 

4 

Treatment of 

native vegetation 

for habitats as 

described in 

Conservation 

Strategies and 

Conservation 

Agreements under 

Alternative 4 

Total Native 

Vegetation treated 

under Alternative 

4 

Treatment of 

native vegetation 

for healthy 

ecosystems under 

Alternative 5 

Total Native 

Vegetation treated 

under Alternative 

5 

WS ES WS ES WS ES WS ES WS ES WS ES 

Herbicides 0 0 1900 7500 200 5500 2100 13000 200 4700 2300 17700 

Mechanical NA NA -1710 -6750 -42 -1155 -1752 -7905 -42 -987 -1794 -8892 

Manual NA NA -190 -750 -28 -770 -218 -1,520 -28 -658 -246 -2178 

Net change in 

total native 

vegetation 

acres treated - - 0 0 130 3575 130 3,575 130 3055 260 6630 

Applicator Certification 

Per BLM Policy, all herbicide application is carried out by certified applicators or under the direct supervision 

of a certified applicator. Certified applicators must attend pesticide training and successfully complete a 

comprehensive certification exam to receive a three-year certification. Certification is issued by the BLM’s 

Washington Office, and a roster of certified pesticide applicator personnel is maintained in the Washington Office 

(USDI 1992c). In addition, the Oregon BLM hires contractors that are certified and licensed by the Oregon 

Department of Agriculture, Pesticides Division, which requires similar training and certification. 

Risk Assessments 

Acute toxicity: The quality or potential of a substance to 

One of the Purposes identified in Chapter 1 is: 6. cause injury or illness shortly after exposure through a single 

or short-term exposure. Prevent herbicide control treatments from having 

unacceptable adverse effects to applicators and Chronic toxicity: The ability of a substance or mixture of the public, to desirable fl ora and fauna, and to substances to cause harmful effects over an extended period, 

soil and water. To help address this Purpose, this usually upon repeated or continuous exposure sometimes 

EIS relies on BLM and/or Forest Service-prepared lasting for the entire life of the exposed organism. 

human health and ecological risk assessments for 

the 18 herbicides analyzed in this EIS. These risk 

assessments are included in this EIS as Appendix 

8: Risk Assessments, and total over 6,000 pages. 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 Bureau Sensitive and Federally Listed species, from the use of the herbicides. The level of detail in the 

risk assessments for wildland use far exceeds that normally found in EPA’s registration examination. 

67 
 

 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

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. 

Risk assessments are necessarily done on a surrogate species in laboratory conditions, identified to represent 

a species group, 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 receptors10 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 (FS) for the 2005 Pacific Northwest Region Invasive Plant Program EIS (see Table 

3-10). 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, related separate 

analyses, and the EIS include analysis of degradates and other ingredients 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, adjuvants (including surfactants), 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 undertaken 

analysis to assess its impacts through risk assessments. 

When evaluating risks from the use of herbicides proposed in a NEPA planning document, reliance on EPA’s 

herbicide registration process as the sole demonstration of safety is insufficient. The U.S. Forest Service and 

BLM 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 herbicides rather than relying 

on Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) registration alone. The Courts have 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 herbicide 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 this EIS, including the high-moderate-low risk ratings shown in tables. Risk assessment 

worksheets have been, or are being, developed for each herbicide, to assist field managers in translating risks 

to project design parameters. The use of those worksheets is explained in Use of Risk Assessment Worksheets 

During Implementation later in this Chapter. 

10 An ecological entity such as a human, fish, plant, or slug. 

 68 
 

 

 

Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

Table 3-10: HUman HealTH and ecological risk assessmenT soUrces 

Herbicide 

Ecological Risk 

Assessments (ERA) 

Human Health Risk 

Assessments (HHRA) 

2007 BLM 

PEIS1 

2005 FS EIS2 

(Ecological & 

Human Health) 

2007 BLM 

PEIS1 1991 BLM EIS3 

2,4-D √4 

Bromacil √ √ 

Chlorsulfuron √ √ 

Clopyralid √ 

Dicamba √ √ 

Diquat √ √ 

Diuron √ √ 

Fluridone √ √ 

Glyphosate √ 

Hexazinone √ 

Imazapic √ √ 

Imazapyr √ 

Metsulfuron methyl √ 

Overdrive (Diflufenzopyr + 

dicamba) √ 

Diflufenzopyr √ √ 

Picloram √ 

Sulfometuron methyl √ √ 

Tebuthiuron √ √ 

Triclopyr √ 

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 The 2,4-D Risk Assessment was replaced in 2006. 

69 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

EPA Labels 

FIFRA establishes procedures for the registration, classification, and regulation of all herbicides. Before 

any herbicides may be sold legally, the EPA must register it. The EPA may classify an herbicide for general 

use if it determines that the herbicide is not likely to cause unreasonable adverse effects to applicators or the 

environment, or for restricted use if the herbicide must be applied by a certified applicator and in accordance with 

other restrictions. The herbicide label is a legal document specifying allowable uses; all applicators that apply 

herbicides on public lands (i.e., certified applicators or those directly supervised by a certified applicator) must 

comply with the application rates, uses, handling, and all other instructions on the herbicide label, and where more 

restrictive, the rates, uses, and handling instructions developed by the BLM. 

EPA herbicide registration looks at the acute toxicity of an herbicide. Acute toxicity is the most common basis 

for comparing the relative toxicities of herbicides. Acute toxicity can be measured by LD50

11. LD50 (LD = 

lethal dose) represents the amount of herbicide that results in the death of 50 percent of test species. Therefore, 

the lower the LD50, the more toxic the herbicide. Table 3-11 shows the three categories that the EPA uses for 

classifying herbicides (USDI 1992c). 

Table 3-11. Herbicide label caTegories 

Categories Signal Word Required 

on Label Oral LD50 (mg/kg) Dermal LD50 (mg/kg) 

Inhalation LD50 

(mg/kg) 

Probable Oral Lethal Dose for 

150 lb Human 

I – Highly Toxic DANGER, POISON, and skull 

and crossbones Up to and including 50 Up to and including 200 Up to and including 0.2 A few drops to a teaspoonful 

II – Moderately Toxic WARNING From 50 to 500 From 200 to 2000 From 0.2 to 2 Over one full teaspoonful to one 

ounce 

III – Slightly Toxic CAUTION From 500 to 5000 From 2000 to 20,000 From 2 to 20 Over one ounce to one pint or one 

pound. 

In addition, the EPA has established Levels of Concern (LOC) 

for herbicides, which is the dose of the herbicide above which 

effects would be expected. The LOCs are used by EPA 

for registration, and to indicate potential risk to non-target 

organisms and the need to consider regulatory action (EPA 

2007c). In the absence of information indicating otherwise, the 

LOC is generally 1/10th of the Lowest Observed Adverse Effect 

Level (LOAEL); that is, the lowest dose level where there was 

a statistically significant increase in frequency or severity of 

adverse effects12 to the test organism. In some cases, no adverse 

reaction happens at any dose (or at any reasonable dose), and 

the LOC is the No Observed Adverse Effect Level (NOAEL). 

LOCs include uncertainty factors based on the amount and 

nature of the toxicity testing on which they are based. 

11 or LC50 (lethal concentration) in the case of aquatic organisms. 

12 Lethal or sublethal. 

EPA terms 

LD50 Lethal Dose to 50% of the population 

LOC Level of Concern 

NOAEL No Observed Adverse Effect Level 

LOAEL Lowest Observed Adverse Effect Level 

BLM terms 

RQ Risk Quotient 

ECC Estimated Exposure Concentration 

TRV Toxicity Reference Value 

ARI Aggregated Risk Index 

Forest Service Terms 

HQ Hazard Quotient 

RfD Reference Dose 

TI Toxicity Index 

 70 
 

Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

High, Medium, and Low Risk in BLM and Forest Service Risk Assessments 

The risk assessments attempt to measure both acute toxicity and chronic toxicity. Chronic toxicity is difficult to 

measure, especially in humans, but shows the results of sublethal doses that could result in cumulative deposits 

that could cause long-term problems in a vital body function. There is no standard measure for chronic toxicity. 

BLM Ecological Risk Assessments 

The BLM ecological risk assessments established a Risk Quotient (RQ) for every herbicide and defined risk 

categories as follows: 

0 No Risk RQ < most conservative LOC for the species 

L Low Risk RQ = 1 to 10 times the most conservative LOC for the species 

M Moderate Risk RQ = 10 to 100 times the most conservative LOC for the species (generally equal to 

LOAEL to 10-times LOAEL) 

H High Risk RQ > 100 times the most conservative LOC for the species 

The RQ is calculated using the Estimated Exposure Concentration (EEC) and the Toxicity Reference Value 

(TRV). The EEC is the dose that an organism would be exposed to under the test scenario; e.g. consumption 

would indicate the amount of herbicide eaten on a sprayed material (a cow eating only sprayed grass for a day, for 

example), direct spray indicates that the organism was sprayed directly with a wand or was in a flight path (a nontarget plant species, for example). The TRV is the toxicity of the herbicide – usually the LOAEL or NOAEL. So, 

the RQ is the EEC divided by the TRV. An uncertainty factor can be brought in if it is thought that a species (or a 

particular individual within the species) is particularly susceptible to herbicide use, or that the single dose does not 

represent long-term exposure. 

Tank Mixes - The BLM evaluated risks from mixing two herbicides together in a tank mix. The BLM assumed 

that products in a tank mix act in an additive manner. Therefore, to simulate a tank mix of two herbicides RQs 

for those two herbicides were combined (see Appendix 8; diquat, fluridone, and tebuthiuron are not generally 

tank mixed by the BLM and were not included in the analysis). The application rates within the tank mix are not 

necessarily the same as those of each individual active ingredient applied alone. The percent of RQs exceeding 

LOCs for each of the ten BLM herbicide active ingredients was compared to the percent of RQs exceeding LOCs 

for tank mixes, to determine whether additional risks were predicted for tank mixes. 

BLM Human Health Risk Assessments 

The BLM human health risk assessments used the Aggregated Risk Index (ARI) and defined risk categories as follows: 

0 No Risk Majority of ARIs > 1 

L Low Risk Majority of ARIs < 1 but > 0.1 

M Moderate Risk Majority of ARIs < 0.1 but > 0.01 

H High Risk Majority of ARIs < 0.01 

71 
 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

ARI is a formula for combining LOCs for all exposure avenues (oral, dermal, inhalation), each with different 

uncertainty factors, and comparing them with the exposure levels that would occur in the scenarios in the risk 

assessments. ARIs less than 1 indicate a concern from at least one of the exposure avenues (EPA 2001b:51-55). 

Forest Service Risk Assessments 

The Forest Service risk assessments are very similar to the BLM’s. The Forest Service risk assessments 

established a Hazard Quotient (HQ) for every herbicide and established risk categories as follows: 

0 No Risk HQ < LOC for the species 

L Low Risk HQ = 1 to 10 times the LOC13 for the species 

M Moderate Risk HQ = 10 to 100 times the LOC for the species 

H High Risk HQ > 100 times the LOC for the species 

The HQ is calculated using the Reference Dose (RfD) and the Toxicity Index (TI). The RfD is the dose that an 

organism would be exposed to under the test scenario; the TI is the toxicity of the herbicide and the HQ is the 

RfD divided by the TI. An uncertainty factor can be brought in if it is thought that a species (or a particular 

individual within the species) is particularly susceptible to herbicide use, or that the single dose does not 

represent long-term exposure. 

Figure 3-1 shows the basis for risk assessments, 

which consists of the following parts: 

• Hazard Characterization: what are the 

dangers inherent with the herbicide? (e.g. 

endocrine disruption, cancer causing, etc.) 

• Exposure Assessment: who could come into 

contact and how much? (specific exposure 

scenarios) 

• Dose Response Assessment: how much 

is too much? At what dose are observable 

effects observed? 

• Risk Characterization: indicates whether or 

not there is a plausible basis for concern (HQ 

or RQ) 

figUre 3-1. basis for risk assessmenTs 

13 As noted in the previous discussion, LOCs are generally set at 1/10th of the LOAEL. Thus an HQ of 1 to 10 times LOC is equivalent 

to an HQ of 0 to 1 in the 2005 Forest Service Invasive Plant EIS (USDA 2005:4-73). The Forest Service EIS goes on to explain “The 

threshold is intended to help reviewers distinguish moderate risks (HQ=2 to 10 [HQ = 20-100 in this EIS]), which could in most 

cases be mitigated through exposure-reducing project design criteria from significant health risks (HQ>10 [HQ>100 in this EIS]) that 

could be difficult to mitigate if Worst-Case situations occur at the project level. For specific situations where a HQ>10 [HQ>100 in 

this EIS] is identified, the specific physiologic effect and the relationship between the NOAEL and the LOAEL may be evaluated to 

more precisely determine whether a toxic effect is actually likely to occur (Durkin, personal communication).” (USDA 2005:4-73). 

 72 
Draft Environmental Impact Statement, Chapter 3: Background and Assumptions for Effects Analysis 

The risk assessments are summarized on tables showing herbicide risk rating at maximum and typical rates to 

vegetation, wildlife, and humans, in a variety of application scenarios. Tables 3-12 and 3-13 show herbicide 

effects to vegetation, from BLM and Forest Service risk assessments respectively. Tables 3-14 and 3-15 show 

herbicide effects to wildlife, fish, and aquatic invertebrates. Tables 3-16 and 3-17 show the effects to human 

health (worker and public, respectively) from herbicides analyzed with the PEIS. Table 3-18 and 3-19 show 

worker and public scenarios for Forest Service-evaluated herbicides, and Tables 3-20 and 3-21 reflect the 1991 

BLM risk categories for the remaining worker and public human health scenarios. Further information about the 

Human Health risk assessments can be found in the Human Health and Safety section of Chapter 4. 

Uncertainty in the Risk Assessment Process 

The risk assessments conducted by the BLM and Forest Service incorporate various conservative assumptions 

to compensate for uncertainties in the risk assessment process. Within any of the steps of the human health 

risk evaluation process, assumptions were made due to a lack of absolute scientific knowledge. Some of the 

assumptions are supported by considerable scientific evidence, while others have less support. Every assumption 

introduces some degree of uncertainty into the risk evaluation process. Regulatory risk evaluation methodology 

requires that conservative assumptions be made throughout the risk assessment process to ensure that public 

health is protected. This conservatism, both in estimating exposures and in setting toxicity levels likely led to an 

exaggeration of the real risks of the vegetation management program to err on the side of protecting human health 

and other species. 

Cumulative effects of long-term use of herbicides may have different outcomes than risk assessments can 

anticipate. Although identification of adverse effects from chronic exposures is one of the parameters examined 

in the risk assessment process, it is possible there are long-term sub-lethal effects on reproductive or migratory 

behavior from low concentrations of herbicides or additives that are not documented in the risk assessments. 

Use of the Risk Assessment Worksheets During Implementation 

As noted in Appendix 2, site-specific analysis or risk assessment worksheets can be used to determine alternative 

ways to meet PEIS Mitigation Measure objectives. Risk assessment worksheets are one tool to assist in 

translating risks to project design parameters. Risk assessment worksheets have been developed for the Forest 

Service risk assessments, and are being, developed for the BLM risk assessments. The worksheets create the 

ability to do project-specific risk assessments. Individual project parameters (information about herbicide 

application, workers, fish and wildlife, and native vegetation), can be input into the worksheets, which then 

calculate RQs and HQs. The worksheets isolate the computations from the discussions of the computations, and 

are intended as a tool to make risk assessment calculations easier to understand and review, allowing for more 

project specific mitigation measures. 

Methodology for Assessing Effects 

This analysis is tiered to, and borrows analysis from, the 2007 Final Vegetation Treatments Using Herbicides of 

BLM lands in 17 Western States Programmatic Environmental Impact Statement (PEIS). In addition, information 

was used from the risk assessments (see earlier in this Chapter, Appendix 8, and Tables 3-12 through 3-21), the 

2005 Forest Service Pacific Northwest Region Invasive Plant Program EIS (USDA 2005), and other sources cited 

throughout the document. Effects consider implementation of BLM policy, SOPs, and PEIS Mitigation Measures. 

Effects in Chapter 4 consider the effects of: 

73 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

• contact or ingestion of an herbicide; 

• invasive plants; and, 

• non-herbicide treatments. 

Standard Operating Procedures, PEIS Mitigation Measures, Risk, and the Potential 

for Adverse Effects 

The BLM has a long history with herbicides. As a result, numerous handbooks and other policy materials have 

been developed governing the use of these herbicides. For the PEIS, direction from these policies was gathered 

and labeled as SOPs (see Appendix 2). Effects described in the PEIS and this EIS are predicated on application 

of the SOPs or that a site-specific determination is made that their application is unnecessary to achieve their 

intended purpose and protection. 

The PEIS examined (and the ROD selected) an alternative using 18 herbicides for a full range of non-commodity 

vegetation treatment objectives in the 17 western states. CEQ regulations require an EIS to identify mitigation 

measures for all identified adverse effects, if they are available. The various resource-specific effects sections in 

the PEIS all identify various levels of risk or adverse effects, and each section identified one or more mitigation 

measures. These were in addition to the SOPs. The Record of Decision for the PEIS adopted all of these 

mitigation measures. Like the SOPs, the PEIS Mitigation Measures are included in Appendix 2 and apply to all 

alternatives in this EIS. Since the alternatives in this EIS are subsets of the alternative selected by the Record 

of Decision for the PEIS, and all adverse effects identified by the PEIS were mitigated where practicable, there 

should be few or no adverse effects expected from implementation of any of the action alternatives in this EIS. 

That is essentially what the effects examination confirms. “Adverse effects” identified in this EIS for the use 

of herbicides are, for the most part, identifications of risks identified by the risk assessments and other literature 

without SOPs and PEIS Mitigation Measures applied. 

Potential adverse effects from the use of herbicides are, in many of the resource-specific sections in Chapter 4, 

expressed as zero or no, low, moderate, and high risk. These are quantified terms (see Risk Assessments earlier 

in this Chapter) summarizing the results of scenarios modeled by the risk assessments and summarized on Tables 

3-12 through 3-21. Where risk assessment scenarios resulted in a moderate or high risk, that risk is reported in 

Chapter 4 as a potential adverse effect, or risk. It is important to understand, however, that such risks almost 

always generated corresponding PEIS Mitigation Measures during the PEIS process (if there were not already 

SOPs designed to avoid the adverse effects). Therefore, most of the potential for adverse effects discussed in 

Chapter 4 are followed by the conclusion that implementation of the SOPs, PEIS Mitigation Measures, and 

site-specific analysis (during which the risk assessments will be specifically consulted) should make the risk of 

adverse effects negligible, de minimus, or at worst “minimized”. 

Occasionally the effects discussions will use unquantified comparison terms like less than, slightly, lower, greater, 

and so forth. These are typically relative statements within the risk assessment-defined terms of low, moderate, 

and high. 

 74 
Table 3-12. blm-evalUaTed Herbicide risk caTegories for vegeTaTion 

Application Scenario 

BROM1 CHLOR1 DICAMBA DIFLU1 DIQUAT DIURON FLUR1 IMAZ1 OVER1 SULFM1 TEBU1 

Typ 2 Max2 Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 

Direct Spray Terrestrial plants H 3 [1:1] H[1:1] H[1:1] H[1:1] H[1:1] H[1:1] M[1:1] H[1:1] H[1:1] H[1:1] M[1:1] H[1:1] NE NE L[1:1] M[1:1] M[1:1] H[1:1] 0 [1:1] L[1:1] M[1:1] H[1:1] 

Special status terrestrialplants 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] 

H

[1:1] NE NE L[1:1] M[1:1] H[1:1] H[1:1] H[1:1] H[1:1] M[1:1] H[1:1] 

Aquatic plants pond H[1:2] H[2:2] M[1:2] M[2:2] L[1:2] L[1:2] L[1:2] L[2:2] H[2:2] H[2:2] H[2:2] H[2:2] 0 [2:2] 0 [2:2] L[1:2] L[2:2] M[1:2] M[1:2] H[2:2] H[2:2] L[2:2] M[2:2] 

Aquatic plants stream H[2:2] H[2:2] M[2:2] M[2:2] L[1:2] L[1:2] L[1:2] L[1:2] H[2:2] H[2:2] H[2:2] H[2:2] 0 [2:2] 0 [2:2] L[2:2] M[2:2] M[1:2] H[1:2] H[2:2] H[2:2] M[1:2] H[1:2] 

Accidental Spill to a PondAquatic plants pond NE H[1:1] NE H[1:2] NE M[1:1] NE L[1:1] NE H[2:2] NE H[1:1] NE L[2:2] NE H[2:2] NE M[1:1] NE H[2:2] NE H[2:2] 

Off-Site DriftTerrestrial plants M[3:6] M[3:6] M[5:12] M[8:12] M[4:6] M[3:6] 0 [4:6] 0 [4:6] L [7:12] M[7:12] 0 [5:6] L[4:6] NE NE 0 [18:18] 0 [13:18] 0 [5:6] 0 [4:6] 0 [12:12] 0 [12:12] 0 [6:6] 0 [4:6] 

Special status terrestrialplants 

M

[3:6] 

H

[3:6] 

M

[7:12] 

M

[7:12] 

H

[2:6] 

H

[3:6] 

L

[3:6] 

L

[4:6] 

M

[7:12] 

M

[7:12] 

M

[3:6] 

H

[3:6] NE NE 0 [17:18] 0 [13:18] L[3:6] L[4:6] H[5:12] H[8:12] 0 [5:6] L[3:6] 

Aquatic plants pond 0 [9:12] L [7:12] 0 [24:24] 0 [24:24] 0 [9:12] 0 [8:12] 0 [12:12] 0 [12:12] NE NE L [8:12] M[6:12] NE NE 0 [36:36] 0 [34:36] 0 [12:12] 0 [12:12] L [13:24] L [12:24] 0 [12:12] 0 [12:12] 

Aquatic plants stream 0 [8:12] L [6:12] 0 [24:24] 0 [22:24] 0 [8:12] L [6:12] 0 [8:12] L [6:12] NE NE L [6:12] M[6:12] NE NE 0 [36:36] 0 [33:36] 0 [8:12] 0 [6:12] L [14:24] L [10:24] 0 [12:12] 0 [12:12] 

Surface RunoffTerrestrial plants 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] NE NE 0 [42:42] 0 [42:42] NE NE 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 0 [42:42] 

Special status terrestrialplants 

0

[39:42] 

0

[38:42] 

0

[42:42] 

0

[42:42] 

0

[42:42] 

0

[42:42] 

0

[34:42] 

0

[33:42] NE NE 0 [38:42] 0 [34:42] NE NE 0 [42:42] 0 [42:42] 0 [34:42] 0 [33:42] 0 [32:42] 0 [28:42] 0 [38:42] 0 [34:42] 

Aquatic plants pond M[70:84] H [45:84] 0 [64:84] 0 [53:84] 0 [78:84] 0 [45:84] 0 [84:84] 0 [84:84] NE NE M[50:84] H [64:84] NE NE 0 [80:84] 0 [62:84] 0 [70:84] 0 [67:84] L [42:84] L [38:84] 0 [65:84] L [55:84] 

Aquatic plants stream 0 [45:84] L [55:84] 0 [80:84] 0 [77:84] 0 [84:84] 0 [83:84] 0 [84:84] 0 [84:84] NE NE L [35:84] L [39:84] NE NE 0 [84:84] 0 [83:84] 0 [84:84] 0 [84:84] 0 [69:84] 0 [60:84] 0 [84:84] 0 [74:84] 

Wind ErosionTerrestrial plants 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] NE NE 0 [9:9] 0 [9:9] NE NE 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 

Special status terrestrialplants 

0

[9:9] 

0

[9:9] 

0

[9:9] 

0

[9:9] 

0

[9:9] 

0

[9:9] 

0

[9:9] 

0

[9:9] NE NE 0 [9:9] 0 [9:9] NE NE 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 0 [9:9] 

Aquatic plants pond NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE 

Aquatic plants stream NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE 

1 BROM = Bromacil; CHLOR = Chlorsulfuron; DIFLU = Diflufenzopyr; FLUR = Fluridone; IMAZ = Imazapic; OVER = (Diflufenzopyr + dicamba) Overdrive®; SULFM = Sulfometuron methyl; and TEBU = Tebuthiuron.2 Typ = Typical application rate; and Max = Maximum application rate.3 Risk categories: = 0 = No risk (majority of RQs < most conservative LOC for non special status species); L = Low risk (majority of RQs 1-10x most conservative LOC for non special status species); M = Moderate risk (majority of RQs 10-100x most conservative LOC 

for non special status species); H = High risk (majority of RQs >100 most conservative LOC for non special status species); and NE = Not evaluated. The Risk Category is based on the risk level of the majority of risk quotients observed in any of the scenarios for a givenexposure group and receptor type. See more information at the risk tables in Chapter 4 of the ERAs (ENSR 2005b-k) to determine the specific scenarios that result in the displayed level of risk for a given receptor group. The number in brackets represents the number ofRQs in the indicated risk category: number of scenarios evaluated. 

75 
Table 3-13. fs-evalUaTed Herbicide risk caTegories for vegeTaTion 

2,4-D Clopyralid Glyphosate1 Hexazinone Imazapyr Metsulfuron Picloram Triclopyr1 

Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 

Terrestrial PlantsDirect spray, susceptible plants NE 3 NE H H M H NE NE H H H H H H H H 

Direct spray, tolerant plants NE NE 0 L L M NE NE M M L M L M NE NE 

Off-site drift, low boom, susceptible plants 

0

[4:7] 

L

[4:7] 

L

[4:6] 

M

[3:6] 

0

[5:6] 

L

[3:6] 

L

[3:6] 

L

[4:6] 

L

[4:6] 

M

[3:6] 

L

[4:6] 

M

[4:6] 

M

[3:6] 

M

[4:6] 

L

[3:6] 

M

[3:6] 

Off-site drift, low boom, tolerant plants 

0

[7:7] 

0

[6:7] 

0

[6:6] 

0

[6:6] 

0

[6:6] 

0

[6:6] 

0

[6:6] 

0

[4:6] 

0

[6:6] 

0

[5:6] 

0

[6:6] 

0

[6:6] 

0

[6:6] 

0

[6:6] 

NE NE 

Off-site drift, aerial, susceptible plants 

0

[3:7] 

L

[3:7] 

M

[2:6] 

H

[2:6] 

L

[3:6] 

M

[2:6] 

NE NE 

M

[2:6] 

H

[2:6] 

M

[2:6] 

H

[2:6] 

L

[3:6] 

M

[3:6] 

M

[2:6] 

H

[2:6] 

Off-site drift, aerial, tolerant plants 

0

[7:7] 

0

[6:7] 

0

[6:6] 

0

[6:6] 

0

[6:6] 

0

[5:6] 

NE NE 

0

[4:6] 

0

[3:6] 

0

[5:6] 

0

[4:6] 

0

[6:6] 

0

[5:6] 

NE NE 

Surface runoff, susceptible plants 

0

[22:30] 

0

[17:30] 

0

[23:30] 

0

[22:30] 

0

[30:30] 

0

[30:30] 

NE NE 

0

[18:30] 

0

[18:30] 

0

[21:30] 

0

[18:30] 

0

[21:30] 

0

[22:30] 

M

[13:30] 

H

[13:30] 

Surface runoff, tolerant plants 

0

[30:30] 

0

[30:30] 

0

[30:30] 

0

[28:30] 

0

[30:30] 

0

[30:30] 

NE NE 

0

[30:30] 

0

[30:30] 

0

[25:30] 

0

[22:30] 

0

[30:30] 

0

[27:30] 

NE NE 

Aquatic PlantsAccidental spill, susceptible macrophytes H H H H M M NE NE H H H H 0 0 H H 

Accidental spill, susceptible algae L M L L NE NE NE NE M H M H M M H H 

Accidental spill, tolerant algae 0 0 0 0 NE NE NE NE 0 0 L M 0 0 NE NE 

Acute exposure, susceptible macrophytes L M 0 0 0 0 H H L L L L 0 L L M 

Acute exposure, susceptible algae 0 0 0 0 NE NE NE NE 0 0 0 0 0 0 NE NE 

Acute exposure, tolerant algae 0 0 0 0 NE NE NE NE 0 0 0 0 0 0 NE NE 

Chronic exposure, susceptible macrophytes 0 0 0 0 0 0 M H 0 0 0 0 0 0 0 L 

Chronic exposure, susceptible algae 0 0 0 0 NE NE NE NE 0 0 0 0 0 0 NE NE 

Chronic exposure, tolerant algae 0 0 0 0 NE NE NE NE 0 0 0 0 0 0 NE NE 

1 Risk categories for the more toxic formulations are presented here.2 Typ = Typical application rate; and Max = Maximum application rate.3 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 LOC of 1.0. If more than one scenario is involved in an exposure pathway (i.e., off-site drift and surface runoff), then the number of scenarios with the given risk category (out of the total number of evaluated scenarios) is displayed in parentheses. The reported risk category is that of the majority of the HQs for all the scenerios. As a result, risk may be higher than the reported risk category for some scenarios withineach category. For more information, see the individual Forest Service Risk Assessments. 

 76 
Table 3-14. blm-evalUaTed Herbicide risk caTegories for Wildlife, fisH, and aqUaTic sPecies 

Application Scenario 

BROM1 CHLOR1 DICAMBA DIFLU1 DIQUAT DIURON FLUR1 IMAZ1 OVER1 SULFM1 TEBU1 

Typ2 Max2 Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 

Direct SprayNon Special Status Species

Small mammal – 100% absorption 0 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Pollinating insect – 100% absorption L L 0 0 0 L 0 0 L L L M 0 0 0 0 0 0 0 0 0 0 

Small mammal – 1st order dermalabsorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Fish pond L L 0 0 0 0 0 0 L L M M 0 0 0 0 0 0 0 0 0 0 

Fish stream L M 0 0 0 0 0 0 L M H H 0 L 0 0 0 0 0 0 0 0 

Aquatic invertebrates pond 0 0 0 0 0 0 0 0 M H M H 0 L 0 0 0 0 0 0 0 L 

Aquatic invertebrates stream 0 L 0 0 0 0 0 0 H H M H 0 L 0 0 0 0 0 0 L M 

Special Status Species

Small mammal – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Pollinating insect – 100% absorption L L 0 0 L L 0 0 L M L M 0 0 0 0 0 0 0 0 L M 

Small mammal – 1st order dermalabsorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Fish pond L L 0 0 0 0 0 0 L H M H 0 M 0 0 0 0 0 0 0 0 

Fish stream M M 0 0 0 0 0 0 M M H H 0 L 0 0 0 0 0 0 0 0 

Aquatic invertebrates pond 0 0 0 0 0 0 0 0 M H M M 0 H 0 0 0 0 0 0 L L 

Aquatic invertebrates stream 0 L 0 0 0 0 0 0 H H M H 0 L 0 0 0 0 0 0 L M 

Indirect Contact with Foliage After Direct SprayNon Special Status Species

Small mammal – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Pollinating insect – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 0 L 

Small mammal – 1st order dermalabsorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Special Status Species

Small mammal – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Pollinating insect – 100% absorption 0 0 0 0 0 0 0 0 0 L 0 L 0 0 0 0 0 0 0 0 0 L 

Small mammal – 1st order dermalabsorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

77 
Application Scenario 

BROM1 CHLOR1 DICAMBA DIFLU1 DIQUAT DIURON FLUR1 IMAZ1 OVER1 SULFM1 TEBU1 

Typ2 Max2 Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 

Ingestion of Food Items Contaminated by Direct SprayNon Special Status Species

Small mammalian herbivore – acute 0 L 0 0 0 0 0 0 0 L 0 L 0 0 0 0 0 0 0 0 0 0 

Small mammalian herbivore – chronic 0 L 0 0 0 L 0 0 L M L M 0 0 0 0 0 0 0 0 0 L 

Large mammalian herbivore – acute 0 L 0 0 0 L 0 0 0 M 0 L 0 0 0 0 0 0 0 0 0 L 

Large mammalian herbivore – chronic L M 0 0 0 L 0 0 L M M H 0 0 0 0 L M 0 0 0 L 

Small avian insectivore – acute 0 0 0 0 L M 0 0 0 M 0 L 0 0 0 0 0 0 0 0 0 L 

Small avian insectivore – chronic 0 0 0 0 0 0 0 0 0 M 0 L 0 0 0 0 0 0 0 0 0 0 

Large avian herbivore – acute 0 0 0 0 0 0 0 0 0 L 0 L 0 0 0 0 0 0 0 0 0 0 

Large avian herbivore – chronic 0 L 0 0 0 0 0 0 L H 0 M 0 0 0 0 0 0 0 0 0 0 

Large mammalian carnivore – acute 0 L 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 0 0 0 0 

Large mammalian carnivore – chronic 0 0 0 0 L L 0 0 0 0 L L 0 0 0 0 0 0 0 0 0 0 

Special Status Species

Small mammalian herbivore – acute 0 L 0 0 0 L 0 0 0 L 0 L 0 0 0 0 0 0 0 0 0 M 

Small mammalian herbivore – chronic 0 L 0 0 0 L 0 0 L M L M 0 L 0 0 0 0 0 0 0 L Large mammalian herbivore – acute 0 M 0 0 0 L 0 0 L M 0 M 0 0 0 0 0 0 0 0 0 L 

Large mammalian herbivore – chronic L M 0 0 L M 0 0 L M M H 0 0 0 0 L M 0 0 0 L 

Small avian insectivore – acute 0 0 0 0 0 0 0 0 L M 0 L 0 0 0 0 0 0 0 0 0 0 

Small avian insectivore – chronic 0 0 0 0 0 0 0 0 0 M 0 L 0 0 0 0 0 0 0 0 0 0 

Large avian herbivore – acute 0 L 0 0 0 0 0 0 0 M 0 M 0 0 0 0 0 0 0 0 0 L 

Large avian herbivore – chronic 0 L 0 0 0 0 0 0 L H 0 M 0 0 0 0 0 0 0 0 0 0 

Large mammalian carnivore – acute 0 L 0 0 0 0 0 0 0 L 0 L 0 0 0 0 0 0 0 0 0 0 

Large mammalian carnivore – chronic 0 0 0 0 L L 0 0 0 0 L L 0 0 0 0 0 0 0 0 0 0 

Accidental Spill to PondNon Special Status Species

Fish pond NE M NE 0 NE 0 NE 0 NE H NE H NE M NE 0 NE 0 NE 0 NE L 

Aquatic invertebrates pond NE L NE 0 NE 0 NE 0 NE H NE H NE H NE 0 NE 0 NE 0 NE L 

Special Status Species

Fish pond NE M NE 0 NE L NE 0 NE H NE H NE M NE 0 NE 0 NE 0 NE M 

Aquatic invertebrates pond NE M NE 0 NE M NE 0 NE H NE H NE H NE 0 NE 0 NE 0 NE L 

 78 
Application Scenario 

BROM1 CHLOR1 DICAMBA DIFLU1 DIQUAT DIURON FLUR1 IMAZ1 OVER1 SULFM1 TEBU1 

Typ2 Max2 Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 

Off-Site DriftNon Special Status Species

Fish pond L L 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Fish stream L M 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Aquatic invertebrates pond 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Aquatic invertebrates stream 0 L 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Special Status Species

Fish pond 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Fish stream 0 M 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Aquatic invertebrates pond 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Aquatic invertebrates stream 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Surface RunoffNon Special Status Species

Fish pond 0 0 0 0 0 0 0 0 NE NE 0 L NE NE 0 0 0 0 0 0 0 0 

Fish stream 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Aquatic invertebrates pond 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Aquatic invertebrates stream 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Special Status Species

Fish pond 0 0 0 0 0 0 0 0 NE NE 0 L NE NE 0 0 0 0 0 0 0 0 

Fish stream 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Aquatic invertebrates pond 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

Aquatic invertebrates stream 0 0 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0 0 0 

1 BROM = Bromacil; CHLOR = Chlorsulfuron; DIFLU = Diflufenzopyr; FLUR = Fluridone; IMAZ = Imazapic; OVER = (Diflufenzopyr + dicamba) Overdrive®; SULFM = Sulfometuron methyl; and TEBU = Tebuthiuron.2 Typ = Typical application rate; and Max = Maximum application rate.3 Risk categories for non special status species: 0 = No risk (majority of RQs < most conservative LOC for non special status species); L = Low risk (majority of RQs 1-10x most conservative LOC for non special status 

species); M = Moderate risk (majority of RQs 10-100x most conservative LOC for non special status species); H = High risk (majority of RQs >100 most conservative LOC for non special status species); and NE = Not evaluated.

Risk categories for special status species: 0 = No risk (majority of RQs < most conservative LOC for special status species); L = Low risk (majority of RQs 1-10x most conservative LOC for special status species); M = 

Moderate risk (majority of RQs 10-100x most conservative LOC for special status species); H = High risk (majority of RQs >100 most conservative LOC for special status species); and NE = Not evaluated

The risk category is based on the risk level of the majority of risk quotients observed in any of the scenarios for a given exposure group and receptor type. See the risk tables in Chapter 4 of the ERAs (ENSR 2005b-k) to

determine the specific scenarios that result in the displayed level of risk for a given receptor group. 

79 
Table 3-15. fs-evalUaTed Herbicide risk caTegories for Wildlife, fisH, and aqUaTic sPecies 

2,4-D Clopyralid Glyphosate2 Hexazinone Imazapyr Metsulfuron Methyl Picloram3 Triclopyr4 

Application Scenario Typ 5 Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 

Acute/Accidental ExposuresDirect spray, small mammal, 1st order absorption L 4 L 0 0 0 0 0 L 0 0 0 0 0 0 L M 

Direct spray, small animal, 100% absorption L L L L L M L M 0 L 0 L L L L M 

Direct spray, bee, 100% absorption L L 0 L L M L M 0 L 0 0 0 L L M Consumption of contaminated fruit, small mammal M L 0 0 0 L 0 L 0 0 0 0 0 0 0 0 

Consumption of contaminated grass, large mammal M M L L L M L M 0 L 0 L L M L M 

Consumption of contaminated grass, large bird M H 0 L L L L M 0 L 0 0 0 0 L M 

Consumption of contaminated water, small mammal, spill L L 0 0 0 L 0 L 0 0 0 0 0 0 0 L 

Consumption of contaminated water, small mammal, stream 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Consumption of contaminated insects, small mammal M H L L L M 0 0 0 L 0 L L M L M 

Consumption of contaminated insects, small bird M H 0 L L M M M L L 0 0 0 0 L M 

Consumption of contaminated small mammal, predatory mammal M M 0 0 0 0 0 0 0 0 0 0 0 0 0 L 

Consumption of contaminated small mammal, predatory bird L L 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Consumption of contaminated fish, predatory bird, spill 0 0 0 0 0 0 L M 0 0 0 0 0 0 0 0 

Fish (susceptible species) – accidental spill L 6 M L L H H NE NE M H 0 L H H L/H M/H 

Fish (tolerant species) – accidental spill NE NE 0 0 H H NE NE 0 L 0 0 L L NE/NE NE/NE 

Fish (susceptible species) – acute exposure, peak EEC 0 0 0 0 M M 0 0 0 0 0 0 L L 0/M 0/H 

Fish (tolerant species) – acute exposure, peak EEC NE NE 0 0 L M 0 0 0 0 0 0 0 0 NE/NE NE/NE 

Aquatic Invertebrates – accidental spill L M L M M H NE NE 0 L 0 0 L M L/M H/H 

Aquatic Invertebrates – acute exposure, peak EEC 0 0 0 0 L L 0 0 0 0 0 0 0 0 0/L 0/M 

Chronic ExposuresConsumption of contaminated vegetation, small mammal, on- site 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Consumption of contaminated vegetation, small mammal, off- site 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Consumption of contaminated vegetation, large mammal, on- site M M 0 L 0 L L M 0 0 0 0 0 0 L M Consumption of contaminated vegetation, large mammal, off -site 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L 

Consumption of contaminated vegetation, large bird, on-site M M 0 L 0 L L M 0 0 0 0 0 L L M 

Consumption of contaminated vegetation, large bird, off-site 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Consumption of contaminated water, small mammal 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Consumption of contaminated fish, predatory bird 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Fish – chronic exposure 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0/0 0/0 

Aquatic invertebrates – chronic exposure 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0/0 0/0 

1 Risk levels are presented for the maximum application rate in aquatic applications.2 Risk levels for the more toxic glyphosate formulation are presented here.3 Susceptible and tolerant aquatic invertebrates were evaluated for picloram. Information is presented for susceptible aquatic invertebrates.4 Fist value is for triclopyr acid formulation (TEA) and second value is for triclopyr butoxythel formulation (BEE).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 warmwater fish, such as fathead minnows. 

 80 
Table 3-16. blm-evalUaTed Herbicide risk caTegories for Workers 

Receptor 

Dicamba Diflufenzopyr Diquat Fluridone Imazapic Sulfometuron Methyl 

Typ 1 Max Accid Typ Max Accid Typ Max Accid Typ Max Accid2 Typ Max Accid Typ Max Accid 

Plane - pilot NE 3 NE NE NE NE NE L M H 0 0 L-H 0 0 NE 0 0 NE 

Plane - mixer/loader NE NE NE NE NE NE M H H 0 L L-H 0 0 NE 0 0 NE 

Helicopter - pilot NE NE NE NE NE NE L M H 0 0 L-H 0 0 NE 0 0 NE 

Helicopter - mixer/loader NE NE NE NE NE NE M H H 0 L L-H 0 0 NE 0 0 NE 

Human/backpack - applicator/mixer/loader 0 0 L 0 0 NE L M H 0 0 L-H 0 0 NE 0 0 NE 

Human/horseback - applicator 0 0 L 0 0 NE L L H 0 0 L-H 0 0 NE 0 0 NE 

Human/horseback - mixer/loader 0 0 L 0 0 NE 0 L H 0 0 L-H 0 0 NE 0 0 NE 

Human/horseback - applicator/mixer/loader 0 0 L 0 0 NE L M H 0 0 L-H 0 0 NE 0 0 NE 

ATV - applicator4 0 0 L 0 0 NE 0 L H 0 0 L-H 0 0 NE 0 0 NE 

ATV - mixer/loader 0 0 L 0 0 NE 0 L H 0 0 L-H 0 0 NE 0 0 NE 

ATV - applicator/mixer/loader 0 0 L 0 0 NE 0 L H 0 0 L-H 0 0 NE 0 0 NE 

Truck - applicator4 0 0 L 0 0 NE 0 M H 0 0 L-H 0 0 NE 0 0 NE 

Truck - mixer/loader 0 0 L 0 0 NE 0 L H 0 0 L-H 0 0 NE 0 0 NE 

Truck - applicator/mixer/loader 0 0 L 0 0 NE 0 M H 0 0 L-H 0 0 NE 0 0 NE 

Boat - applicator NE NE NE NE NE NE 0 0 H 0 0 L-H NE NE NE NE NE NE 

Boat - mixer/loader NE NE NE NE NE NE 0 0 H 0 0 L-H NE NE NE NE NE NE 

Boat - applicator/mixer/loader NE NE NE NE NE NE 0 0 H 0 0 L-H NE NE NE NE NE NE 

1 Typ = Typical application rate; Max = Maximum application rate; and Accid = Accidental rate. Typical and maximum application rate categories include short-, intermediate-, and long-term exposures. Accidental scenario category includes accidents 

with herbicide mixed at both the typical and maximum application rates and with a concentrated herbicide.

2 For all worker receptors accidentally exposed to fluridone, there is low risk from exposure to solutions mixed with water to the typical application rate, moderate risk from exposure to solutions mixed with water to the maximum application rate, and 

high risk from exposure to concentrated solutions (prior to mixing with water).

3 Risk categories: 0 = No risk (majority of ARIs > 1); L = Low risk (majority of ARIs >1 but < 0.1); M = Moderate risk (majority of ARIs > 0.1 but < 0.01); H = High risk (majority of ARIs < 0.01); and NE = Not evaluated. The reported risk category 

represents the typical/most common risk level for estimated risks from various time periods. See the Vegetation Treatments Programmatic EIS Human Health Risk Assessment Final Report (ENSR 2005l) for the range of risk levels for each scenario.

4 ATV and Truck categories include spot and boom/broadcast application scenarios. 

81 
Table 3-17. blm-evalUaTed Herbicide risk caTegories for THe PUblic 

Receptor 

Dicamba Diflufenzopyr Diquat Fluridone Imazapic Sulfometuron Methyl

Typ 1 Max Accid Typ Max Accid Typ Max Accid Typ Max Accid Typ Max Accid Typ Max Accid 

Hiker/hunter (adult) 0 2 0 0 0 0 0 0 L L 0 0 0 NE NE NE NE NE NE 

Berry picker (child) 0 0 0 0 0 0 0 L L 0 0 L NE NE NE NE NE NE 

Berry picker (adult) 0 0 0 0 0 0 0 L L 0 0 0 NE NE NE NE NE NE 

Angler (adult) 0 0 0 0 0 0 0 L L 0 0 0 NE NE NE NE NE NE 

Residential – contaminated water(child) 0 0 0 0 0 0 L L M 0 0 L NE NE NE NE NE NE 

Residential – contaminated water(adult) 0 0 0 0 0 0 0 L M 0 0 L NE NE NE NE NE NE 

Native American (child) 0 0 0 0 0 0 0 L L 0 0 0 0 0 0 0 0 0 

Native American (adult) 0 0 0 0 0 0 0 L L 0 0 0 0 0 0 0 0 0 

Swimmer (child) 0 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 0 

Swimmer (adult) 0 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 0 

1 Typ = Typical application rate; Max = Maximum application rate; and Accid = Accidental rate. Typical and maximum application rate categories include short-, intermediate-, and long-term exposures. Accidental scenario category includes accidents 

with herbicide mixed at both the typical and maximum application rates and with a concentrated herbicide.

2 Risk categories: 0 = No risk (majority of ARIs > 1); L = Low risk (majority of ARIs >1 but < 0.1); M = Moderate risk (majority of ARIs > 0.1 but < 0.01); H = High risk (majority of ARIs < 0.01); and NE = Not evaluated. The reported risk category 

represents the typical/most common risk level for estimated risks from various time periods. See the Vegetation Treatments Programmatic EIS Human Health Risk Assessment Final Report (ENSR 2005l) for the range of risk levels for each scenario. 

Table 3-18. fs-evalUaTed Herbicide risk caTegories for Workers 

Treatment Method 

Risk Categories 

2,4-D1 Chlorsulfuron Clopyralid Glyphosate Hexazinone Imazapyr Metsulfuron Methyl Picloram Triclopyr1 

Typ 2 Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 

General ExposuresDirected foliar and spot treatments(backpack) L 3 M 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 L 

Broadcast ground spray (boom spray) L M 0 L 0 0 0 0 0 L 0 0 0 0 0 0 0 L 

Aerial applications (pilots and mixer/loaders) L M 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 L 

Aquatic applications NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE 

Accidental/Incidental ExposuresImmersion of hands 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Wearing contaminated gloves M M 0 0 0 0 0 0 L L 0 0 0 0 0 0 0 L 

Spill on hands 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Spill on lower legs 0 0 0 0 0 0 0 0 0 L 0 0 0 0 0 0 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. 

 82 
Table 3-19. fs-evalUaTed Herbicide risk caTegories for THe PUblic 

Treatment Method 

Hazard Quotient 

2,4-D1 Chlorsulfuron Clopyralid Glyphosate Hexazinone Imazapyr Metsulfuron Picloram Triclopyr1 

Typ 2 Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 

Acute/Accidental ExposuresDirect spray - child, entire body L 3 M 0 0 0 0 0 0 L M 0 0 0 0 0 0 0 L 

Direct spray - woman, lower legs 0 0 0 0 0 0 0 0 0 L 0 0 0 0 0 0 L M 

Dermal - contaminated vegetation, woman 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L L 

Consumption of contaminated fruit 0 L 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 L 

Consumption of contaminated water - pond,spill M H 0 0 0 L 0 L M M 0 0 0 0 0 L 0 L 

Consumption of contaminated water - stream,ambient 0 L 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 

Consumption of contaminated fish - generalpublic L L 0 0 0 0 0 0 L L 0 0 0 0 0 0 0 0 

Consumption of contaminated fish -subsistence populations L M 0 0 0 0 0 0 M M 0 0 0 0 0 0 0 0 

Chronic/Longer-term ExposuresConsumption of contaminated fruit L M 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 

Consumption of contaminated water 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Consumption of contaminated fish - generalpublic 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Consumption of contaminated fish -subsistence populations 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 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. 

83 
 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table 3-20. blm 1991-evalUaTed Herbicide HigH risk scenarios for Workers 

Treatment Method 

Bromacil Diuron Tebuthiuron 

Typ Max Accid Typ Max Accid Typ Max Accid 

Aerial pilot R,C S,R,C NA S,R S,R NA R S,R NA 

Aerial mixer-loader S,R,C S,R,C NA S,R S,R NA R S,R NA 

Aerial fuel truck operator 0 0 NA 0 S,R NA 0 S NA 

Backpack applicator 0 S,R NA S S,R NA 0 S,R NA 

Ground mechanical applicator 0 S,R NA S S,R NA 0 S,R NA 

Ground mechanical mixerloader 0 S,R NA S S,R NA 0 S,R NA 

Ground mechanical applicator/ 

mixer-loader 0 S,R NA S S,R NA 0 S,R NA 

Hand applicator 0 S,R NA S S,R NA R S,R NA 

Skin spill, concentrate NA NA S,R,C NA NA S,R NA NA 0 

Skin spill, mixture NA NA S,R,C NA NA S,R NA NA S,R 

Direct spray, person NA NA S,R NA NA S,R NA NA S,R 1 Typ = Typical application rate; Max = Maximum application rate; and Accid = Accidental application.
 2

 Risk categories: 0 = No risk; S = Systemic risk; R = Reproductive risk; C = Cancer risk; and NA = Not applicable. Marked scenarios are those that 

result in high risk under the given herbicide. High risks are defined as those exposures that may result in a margin of safety (MOS) < 100 or a cancer 

risk greater than one-in-one million. The MOS is the NOEL divided by the dose; therefore, the larger the MOS, the smaller the estimated human dose 

compared to the animal NOEL, and the lower the presumed risk to human health. 

In the earlier BLM EISs, risk estimates were presented separately for different land uses (rangeland, public domain forestland, oil and gas sites, ROW, and 

recreation and cultural sites). In this table, the scenario is marked if any of these land uses showed a high risk for the specific herbicide. 

Table 3-21. blm 1991-evalUaTed Herbicide HigH risk scenarios for THe PUblic 

Treatment Method Bromacil Diuron Tebuthiuron 

Accidental Application 

Direct spray, person S,R S,R,C S,R 

Drinking directly sprayed water 0 S,R,C R 

Eating fish from directly sprayed water S,R S,R,C 0 

Immediate reentry, hiker 0 S,C 0 

Immediate reentry, picker S,R S,R,C S,R 

Eating directly sprayed berries S,R S,R,C S,R 

Angler 0 C 0 

Nearby resident 0 C 0 

Drinking water contaminated by a jettison of mixture S,R S,R,C S,R 

Drinking water contaminated by a truck spill S,R S,R,C S,R 

Risk categories: 0 = No risk; S = Systemic; R = Reproductive; C = Cancer; and NA = Not applicable. Marked scenarios are those that result in high risk 

under the given herbicide. High risks are defined as those exposures that may result in a margin of safety (MOS) < 100 or a cancer risk greater than onein-one million. The MOS is the NOEL divided by the dose; therefore, the larger the MOS, the smaller the estimated human dose compared to the animal 

NOEL, and the lower the presumed risk to human health. 

In the earlier BLM EISs, risk estimates were presented separately for different land uses (rangeland, public domain forestland, oil and gas sites, ROW, and 

recreation and cultural sites). In this table, the scenario is marked if any of these land uses showed a high risk for the specific herbicide. 

 84 
85 

Chapter 4 

Affected Environment and 

Environmental Consequences 

In addition to considering the potential for adverse environmental effects from herbicides, the individual resource 

sections in this Chapter examine the environmental implications of the various levels of weed control that would 

be expected to be achieved by the different alternatives. To facilitate these discussions, the Noxious Weeds and 

Other Invasive Plants, Vegetation, Pest and Disease Control, and Climate Trends sections are presented first, in 

order to quantify differences between the alternatives in terms of native ecosystems protected or invasive plant 

spread reduced. In other words, the different number of herbicides available across the range of alternatives 

would result in different levels of vegetation control or site disturbances. These differences have implications to 

the subsequent resource effects discussions. 

Incomplete and Unavailable Information 

Like the PEIS, this EIS is a programmatic document that addresses the broad impacts associated with the 

proposed action and alternatives to the proposed action. Environmental impacts are assessed at a general level 

because of the broad land area analyzed in this EIS. As noted during the public scoping meeting in Portland 

on July 18, 2008 “It will be hard to evaluate non-target impacts because they usually require specifics about 

application.” Site-specific impacts will be assessed in NEPA documents prepared by local BLM offices and tiered 

to this document. 

The analyses of impacts of the use of herbicides in this EIS are based on the best and most recent information 

available. As is always the case when developing management direction for a wide range of resources, not all 

information that might be desired was available. The Council on Environmental Quality (CEQ) Regulations 

provide direction on how to proceed with the preparation of an EIS when information is incomplete or 

unavailable: 

“If the information relevant to reasonably foreseeable significant adverse impacts cannot be obtained because 

the overall costs of obtaining it are exorbitant or the means to obtain it are not known, the agency shall include 

within the environmental impact statement: 1) a statement that such information is incomplete or unavailable; 2) 

a statement of the relevance of the incomplete or unavailable information to evaluating reasonably foreseeable 

significant adverse impacts on the human environment; 3) a summary of existing credible scientific evidence 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

which is relevant to evaluating the reasonably foreseeable significant adverse impacts on the human environment; 

and 4) the agency’s evaluation of such impacts based upon theoretical approaches or research methods generally 

accepted in the scientific community. For the purposes of this section, “reasonably foreseeable” includes “impacts 

which have catastrophic consequences, even if their probability of occurrence is low, provided that the analysis of 

the impacts is supported by credible scientific evidence, is not based on pure conjecture, and is within the rule of 

reason” (40 CFR 1502.22 b). 

Addressing this last point first, it is understood that many prudent individuals view herbicides, either individually 

or in combination with other chemicals already added to the environment, as having a potential for the 

aforementioned “catastrophic consequences.” To address this concern, 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). Risk assessments have a high degree of uncertainty in interpretation and 

extrapolation of data. Risk assessments determine for a set of assumptions whether there is a basis for asserting 

that a particular adverse effect is possible. Prediction of potential toxic effects from exposure to multiple 

chemicals, natural and synthesized, necessarily involves incomplete and unavailable information regarding the 

complexity and unpredictability of potential multiple exposures. To address these uncertainties, risk assessments 

use the most conservative observed response and then apply uncertainty factors at each step. The combination 

(product) of these uncertainty factors can be in the tens of thousands in cases where test results were sparse or 

uncertain; the factors applied at each step depend on the level of confidence at that step that the results will apply 

to the full range of potentially affected individuals. Additionally, the BLM added a factor of ten when applying 

ecological risk assessment results to Bureau Sensitive or Federally Listed species, since they are by definition 

more sensitive and adverse effects could be significant. The results of the risk assessments have been quantified 

into low, moderate, and high-risk ratings representing the likelihood of adverse effects if the tested scenario is 

experienced (e.g. direct spray). However, the likelihood of experiencing an adverse effect predicted by the low, 

moderate, and high-risk ratings may be tens to thousands of times less for the average individual because of the 

uncertainty factors applied. 

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. A by-the-book aerial application of sulfometuron 

methyl was done on a 20,000-acre three-month old wildfire area in south-central Idaho in November 2001. 

Winter rains were to carry the herbicide into the soil where it would prevent cheatgrass from overtaking returning 

native plants. An unusual combination of dry winter and blinding dust storm carried herbicide-treated ash and soil 

onto adjacent farmlands, severely damaging thousands of acres of the following years’ crops. Herbicides killing 

non-target plants would be the most common unplanned effect, herbicides are designed to kill plants. Adverse 

effects to other organisms is less likely, but not impossible. The EPA’s sulfometuron methyl Reregistration 

Eligibility Decision (RED) published in 2008 includes application constraints designed specifically to avoid a 

repeat of the Idaho incident (see Cumulative Effects discussion of the sulfometuron methyl RED later in this 

Chapter). 

For other types of environmental effects, the primary effect of unavailable information is the inability to quantify 

certain impacts. Where quantification was not possible, impacts have been described in qualitative terms. A 

summary of existing credible scientific evidence that is relevant to evaluating the reasonably foreseeable adverse 

impacts on the human and socioeconomic environment (and support the BLM’s evaluation of such impacts) 

has been included in this Chapter, in Chapter 3, in the PEIS (Appendix 1 of this EIS), in other appendices that 

accompany this EIS, and in supporting documents that were prepared for the PEIS that have been included 

on the BLM website at http://www.blm.gov and on the EIS project website at http://www.blm.gov/or/plans/ 

vegtreatmentseis/. 

 86 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Knowledge is, and always will be, incomplete regarding many aspects of terrestrial and aquatic species, 

forestlands, rangelands, the economy, and society. However, central ecological, economic, and social 

relationships are well established, and a substantial amount of credible information about ecosystems in the 

project area is known. The alternatives were evaluated using the best available information. And while additional 

information may add precision to estimates or better specify relationships, new or additional information is 

unlikely to significantly change the understanding of the relationships that form the basis of the effects analysis 

presented in this Chapter. 

Locations of future projects are largely unknown, as they will be determined later in time. For this EIS analysis, 

acreage estimates have been separated between west and east of the Cascades, because both the spread of 

invasive weeds, and the likelihood of working near water and/or people, is substantially different between these 

two general areas of the State. Beyond that, local site-specific land use plans and activity plans will identify the 

priorities for each district. 

One resource for which information is incomplete or unavailable is social and economic costs of invasive 

and noxious weeds. These costs are only now being understood and quantified by economists and vegetation 

scientists at local and regional scales. Related to this problem is the uncertainty in projecting invasive weed 

spread. As noted in the Vegetation, Native Plants, and Plant Communities section, the spread of individual 

species could have, in retrospect, been reduced to one or two percent of ultimate acreages within watersheds 

or other locally defined areas if they had been controlled when populations were only a few plants or acres. 

Expecting identification of many such opportunities is reasonable; many small populations are spreading 

now because the proper herbicide is not available. Estimating the ecological value of such control efforts is 

also possible at the species and small watershed scale. However, the translation of these opportunities to an 

overall description of long-term vegetation changes for each alternative and a resultant ecological gain for each 

alternative is necessarily qualitative. 

As noted in the Air Quality section, the science is lacking to develop a complete carbon budget principally due 

to the lack of information on belowground carbon dynamics in all ecosystems and very limited information 

on aboveground carbon dynamics in rangeland ecosystems. Although carbon cannot be thoroughly analyzed, 

one of the known qualitative trade-offs are that activities that can restore healthy functioning ecosystems, 

including treatments to reduce invasive plants, tend to increase carbon sequestration. The analysis points out 

that Alternative 4’s replacement of roadside mowing with herbicide use should decrease fossil fuel use. These 

factors point to the proposed action having favorable effects on climate change and long-term air quality when 

compared to the No Action Alternative, but the difference is qualitative and likely so small as to play little role in 

influencing the choice between the alternatives. 

Accidental Spill 

Spills happen when valves fail, when vehicles or handheld equipment tips over or falls into water bodies, 

when applicators forget herbicides are present in equipment, and so forth. SOPs, job hazard analyses or risk 

management assessments, safety and handling plans, designated travel routes, mixing rules, separated equipment, 

and other processes are designed to minimize spill occurrence, but the alternatives propose to treat thousands of 

acres in an area where there are thousands of streams and lakes present. Many of the invasive plants are in the 

riparian zones or even in water, so some amount of herbicide mix gets near water. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The Fish, Wildlife Resources, Vegetation, Native Plants, and Plant Communities, and Water Resources sections 

address spill scenarios that represent worst-case potential impacts to a pond and to a stream1. The scenarios are 

a truck and a helicopter spilling entire loads (200-gallon spill and 140-gallon spill, respectively) of herbicide 

mixed for the maximum application rate into a 1⁄4 acre, 1-meter-deep pond, and into a small but perennial 

fish-bearing stream. The pond scenario is the one discussed in the PEIS Vol. II:C-22, and analysis in that 

volume examines the pond concentration against the risk assessment’s toxicity endpoints for the fish, aquatic 

invertebrates, and non-target aquatic plants. For that analysis, the concentration of herbicide in the pond water 

is based on the concentration in the spilled solution, the volume spilled, and the volume of the pond assuming 

instantaneous mixing. 

Spills directly onto soil would likely have fewer adverse effects than spills into water. Under this situation, 

the site would be assessed for a connection to ground or surface water and the soil isolated or removed. This 

type of remedial action is generally conducted by an environmental services crew contracted for such work or 

in connection with the State of Oregon Department of Environmental Quality’s (DEQ) Emergency Response 

Program. 

Spilling the contents of an application tank or helicopter load is the largest event reasonably foreseeable without 

being speculative. The potential impacts of larger spills have not been estimated. Although a larger event is 

possible, the variables of which herbicide, how much, and where, become speculative when focused to individual 

resources. Effects of a spill of normally transported and mixed quantities could vary from slight to significant 

depending upon these variables. Larger spills could include barrels of product (up to 55 gallons) dropped, 

ruptured, punctured, or even lost, with effects similar to spilling 400 gallons of mix. Herbicides could be 

deposited in waterways by a vehicle accident at a stream or river crossing, or by a mixing/drafting error although 

SOPs require mixing and loading operations to be done in areas where an accidental spill would not contaminate 

an aquatic body. Spill plans are required for all herbicide projects, are on site during operations, and include 

requirements that responsible local and State agencies are immediately notified. Clean up, mitigation, and site 

rehabilitation is required. 

In addition to the possibility of spills, there is a possibility of accidental application contrary to the prescription or 

the label. Increasing the number of herbicides might result in field offices using herbicides that are less familiar 

to them (at least in the short term), leading to errors or to applications unexpectedly damaging non-target plants. 

However, the availability of more target-specific herbicides, effective in lower quantities, would more likely have 

the opposite effect, that of reducing pounds applied and reducing less effective and repeated applications that 

attempt to control weeds for which the currently available four herbicides are less effective. Site-specific planning 

and the use of certified applicators should limit non-label applications. 

Uncertainties including spills and accidental applications are also discussed in the risk assessments for each 

herbicide (Appendix 8), and the risk levels for such events are included on risk tables applicable to the specific 

resource effects sections. 

1 Risk assessments do not evaluate stream sp[ills because the herbicide concentrations would be dependent on flow rate 

and the distance from the spill. Spills lethal in ponds would be expected to be lethal in streams for some distance. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Cumulative Impacts 

Cumulative impacts to the environment are defined in the CEQ regulations as those that result from the 

incremental effects of a proposed action when added to other past, present, and reasonably foreseeable future 

actions, regardless of which agency or person undertakes them (40 CFR 1508.7). In general, the effects of past 

actions are considered in Affected Environment discussions for each resource. In each resource section in this 

Chapter, the various types of direct and potentially cumulative effects are identified by considering the following 

possible sources of effects for each resource and for this EIS as a whole: 

1. The Proposed Action; 

2. Existing actions (already doing some of the same thing); 

3. Past actions (effects previously imparted by other actions); 

4. Other present actions (other things going on in the effects area); 

5. Reasonably foreseeable actions; and, 

6. Mitigation of adverse effects that cannot be avoided with the selected alternative. 

These types of effects are not necessarily separated or labeled in each resource effects section in this Chapter. 

Because this is a statewide programmatic document covering the estimated level of future herbicide use in Oregon 

(that will be subsequently covered by district or project site-specific NEPA documents), this entire analysis is 

itself a cumulative effects analysis. 

Past, present, and reasonably foreseeable future actions that are not directly related to the alternatives but that bear 

on the effects of the alternatives presented in this EIS are described here: 

Oregon Department of Agriculture’s Pesticide Use Reporting System 

In July 2009, the Oregon Department of Agriculture published an annual report compiling the second full year of 

reporting under Oregon’s Pesticide Use Reporting System. For non-household use pesticides, Oregon State law 

requires self-reporting. There were many problems identified in this reporting system, including: 

•		 many (if not most) businesses and commercial users2 didn’t realize that they were required to report their 

pesticide use; 

•		 there was difficulty correctly identifying the pesticide used; 

•		 funding didn’t allow the ODA to follow up on every report; and, 

•		 people were not familiar with the online reporting system, had varying computer skills, or had no online 

access. 

These errors could have caused overestimates or underestimates in the final reported numbers. In addition, these 

estimates do not include pesticides used in households, a possibly significant figure. However, applicators filed 

nearly 343,000 reports of pesticide use totaling 19,696,784 pounds of pesticides including fungicides, herbicides, 

insecticides, rodenticides, and others. This is 645 times the pounds of herbicides BLM proposes to apply under 

the proposed action. 

Twenty percent of this total was the soil fumigant metam-sodium, with most of that being applied to the farmlands 

along the Columbia River in the northern part of the State east of the Cascades. The herbicide glyphosate (the 

active ingredient in Roundup®) was reported at 1,914,143 pounds of active ingredient, or more than 3.5 million 

Includes all uses except household use. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table 4-1. 2008 oregon-Wide Use of THe 18 Herbicides analyzed in THis eis and comParison WiTH blm 

ProPosed acTion (alTernaTive 4) 

Herbicide and rank1 Lbs Reported by ODA Assumed Acres 

Statewide2 

Est . Acres under Alt 4 on 

BLM Lands 

% of OR acres that BLM 

Proposed Usage Would 

Represent 

2. Glyphosate 1,914,144 957,072 4,200 0.44% 

7. 2,4-D 778,878 778,878 5,700 0.73% 

13. Diuron 385,174 64,196 800 1.25% 

25. Triclopyr 125,542 125,542 3,900 3.11% 

31. Hexazinone 105,284 105,284 400 0.38% 

34. Dicamba 96,964 387,856 1,700 0.44% 

50. Clopyralid 48,592 138,833 2,300 1.66% 

59. Imazapyr 29,859 66,354 2,500 3.77% 

83. Sulfometuron methyl 16,866 120,470 1,200 1.00% 

99. Bromacil 11,189 2,797 700 25.02% 

Picloram 5,891 14,727 3,400 23.09% 

Metsulfuron-methyl 5,252 175,059 3,300 1.89% 

Diquat 2,334 2,334 0 0% 

Chlorsulfuron 2,006 42,685 4,100 9.61% 

Tebuthiuron 720 1,441 100 6.94% 

Imazapic 314 10,023 14,100 140.68% 

Fluridone 22 143 300 209.20% 

Diflufenzopyr + Dicamba No data No Data 0 0% 1

 Rank is only known for the herbicides included in ODA’s list of 100 most used Pesticides 

2

 Reported pounds divided by the BLM typical application rate. 

acres if the typical rate3 is assumed (ODA 2009b). Table 4-1 shows the reported pounds in Oregon for herbicides 

included in this EIS. Included are their numerical rank in the Oregon report in terms of pounds applied (if they 

were in the 100 most-used pesticides), and equivalent acres calculated from the BLM typical application rate and, 

for comparison purposes, the estimated acres of the same herbicide expected to be applied by the BLM under the 

proposed action and its percent of the 2008 Oregon total. (The BLM manages about 26 percent of the lands in 

Oregon.) Agricultural uses are included in the Oregon totals; the table does not attempt to compare like uses. 

NCAP-NMFS Settlement Agreement to Examine 37 Pesticides 

In July 2008, a settlement was reached in NW Coalition for Alternatives to Pesticides et al. v. NMFS. The 

settlement requires the National Marine Fisheries Service to both examine the impacts of 37 pesticides on 

protected salmon and steelhead, and to design measures that will minimize adverse impacts. The EPA had 

previously identified these 37 pesticides as potentially harmful to these anadromous fish. Among the pesticides 

included in this settlement are three used or proposed for use by the BLM: 2,4-D, diuron, and triclopyr BEE (a 

form of triclopyr). The BLM would comply with any mitigation and SOPs that result from these studies, which 

could include a ban on any or all of these herbicides. Table 4-1 indicates that BLM’s use of 2,4-D, diuron, and 

triclopyr would account for about 0.73, 1.25, and 3.11 percent of the total use in the State respectively, and BLM’s 

SOPs and PEIS Mitigation Measures limit effects to non-target species. BLM proposed use is not likely to 

substantially contribute to anadromous fish effects. 

3 Typical application rates for each herbicide are shown on Table 3-4. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Forest Service’s Invasive Plant Program 

The Forest Service manages about 22 percent (14.5 million acres) of the land in Oregon. The Forest Service’s 

Invasive Plant Program proposes to treat approximately 29,058 acres with herbicides in Oregon and Washington 

to control invasive plants. Herbicides available for use by the Forest Service include chlorsulfuron, clopyralid, 

glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, sulfometuron methyl, and triclopyr, all of which 

are analyzed in this EIS, and sethoxydim. The Region 6 (Forest Service in Oregon and Washington) Invasive 

Plant Program’s EIS was finished in 2005 (USDA 2005) and the Record of Decision was signed October 2005. 

Forests are in the process of completing site-specific NEPA tiered to that decision. 

Petition to Cancel all Registrations of 2,4-D 

On November 6, 2008, the Natural Resources Defense Council (NRDC) petitioned the EPA to revoke all 

tolerances4

 and cancel all registrations for 2,4-D. As a part of the petition, NRDC asserts that the Agency did 

not consider the full spectrum of potential human health effects associated with 2,4-D in connection with EPA’s 

reassessment of the existing 2,4-D tolerances, and EPA’s ecological risk assessment including: 

•		 information on the endocrine disrupting effects of 2,4-D; 

•		 information on the neurotoxicity related to 2,4-D exposure; 

•		 information that products containing 2,4-D are mutagenic; 

•		 data showing that dermal absorption of 2,4-D is enhanced by alcohol consumption, sunscreen, and DEET 

which the EPA’s exposure assessment failed to include; and, 

•		 information about adverse developmental effects at doses below those included in EPA’s risk assessment 

for exposure of infants to 2,4-D in breast milk. 

The EPA has sought comment on the petition, but a final decision has not been reached. However, EPA’s risk 

assessment of 2,4-D and findings on whether the tolerances for 2,4-D comply with the safety standards are 

contained in a June 2005 Reregistration Eligibility Decision (RED) document for 2,4-D (EPA 2005a). The BLM 

will comply with the final decision. 

Sulfometuron Methyl Reregistration Eligibility Decision (RED) 

In the November 12, 2008 Federal Register, the EPA announced that its sulfometuron methyl RED was available 

for review and comment. In the RED, the EPA proposes to: 

•		 prohibit sulfometuron methyl in counties with an annual rainfall of less than 10 inches; 

•		 prohibit use within 100 feet of water; and, 

•		 prohibit 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. A decision to adopt the proposed standards would particularly 

affect sulfometuron methyl application in Malheur County (in the Vale District) and Sherman County (in the 

Prineville District) where annual precipitation is 9.64 inches and 9.15 inches, respectively. Figure 4-1 shows 

average annual precipitation in the State. 

Tolerances are limits permitted in food or water. 

91 

4 
figUre 4-1. average annUal PreciPiTaTion 1961-1990 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Environmental Setting 

This Chapter presents information about those aspects of the human environment that are likely to be most 

directly affected by the management prescribed in the alternatives, and that will be used to determine which 

alternative meets the Need and best meets the Purposes described in Chapter 1. This Chapter presents the direct, 

indirect, and cumulative effects of management under the alternatives. The information presented in this Chapter 

forms the scientific and analytic basis for the Comparison of the Effects of the Alternatives section in Chapter 2. 

This document is a programmatic EIS, and while many of the effects are most appropriately considered at this 

scale and all effects are described in sufficient detail to facilitate a reasoned choice from among the alternatives, 

the ability to provide specific details about some effects is necessarily limited. However, the alternatives in this 

EIS do not authorize any activities. The conduct of management activities must still comply with applicable 

environmental laws at the site-specific level, which include provision for public notice, comments, appeal, and 

consideration of site-specific resources of all kinds. 

The BLM manages about 15.7 million acres in Oregon, or about 26 percent of the lands in the State. About 2.3 

million of these acres lay west of the Cascades, about 2.1 million of which was assigned to the BLM by the O&C 

Act of 1937 to be managed primarily for sustained timber production. 

Most lands east of the Cascades more closely resemble lands in other western states, and include dry forest and 

sagebrush steppe of the high desert. These lands are managed for a variety of uses including habitat, watershed 

protection, recreation, livestock grazing, and oil, gas, and mineral development. Information about these other 

uses, as well as about special lands designations, is presented in resource-specific sections in this Chapter. 

Current Climate5 

A discussion of the current climate and weather patterns in Oregon is important to the understanding of the broad 

vegetative communities (or biomes) within the State; how invasive plant trends might affect that vegetation; and, 

how expected climate change might affect invasive plant trends and thus affect the need for changes in management. 

The Pacific Ocean exerts a strong influence on the climate across Oregon, with a stronger influence west of the 

Cascades than on the eastern side. This maritime influence moderates winter minimum and summer maximum 

temperatures. The abundant moisture incorporated into the air masses that move across the Pacific is largely 

responsible for the abundant rainfall over western Oregon and at higher elevations of the eastern portion of the 

State. The occurrence of extreme low or high temperatures is generally associated with the occasional incursion 

of continental air masses. 

A series of mountain ranges affect precipitation amounts across the State. The Coast Range runs north-south 

down the full length of the State; the Cascade Range runs north-south from the Columbia River to within 50-75 

miles of the California border; and, the Blue Mountains run northeast-southwest from the Snake River to the John 

Day and Deschutes Rivers. Other mountain ranges include the Siskiyou Mountains in southwest Oregon, and 

the Steens Mountain in southeast Oregon. The mountain ranges generally increase in elevation from west to east 

and from north to south. As a result, moisture entering the State from the Pacific Ocean is progressively removed 

from the air masses as they rise, cool, and condense to cross the various ranges. Precipitation amounts are highest 

along the coast and lowest in the rain shadow of the Steens. 

 General sources for this section include Taylor and Hatton (1999), OCS (2009), and WRCC (2009). 

93 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

A maritime climate characterizes the coast and northwestern part of the State. This area has very mild winters and 

the coolest summers in the State. Temperatures have the least diurnal and annual variation along the coast. High 

temperatures rarely exceed 90° F and low temperatures rarely drop below 0° F, with average winter minimums 

mostly above 32° F. August is usually the warmest month and January the coldest month. Precipitation averages 

100-200 inches on the coast, 30-60 inches in the Willamette Valley and 80-120 inches on the western slopes of 

the Cascades. Most precipitation falls in November through March, as rain below 1300 feet elevation and snow 

above 4900 feet elevation. The 1300-4900 foot elevation band is known as the transient snow zone with winter 

precipitation falling as a mix of rain and snow. The coast is frequently cloudy or foggy throughout the year while 

clouds and fog are much less common in summer in northwest Oregon. Thunderstorms are rare, peak in May and 

are usually wet. The Columbia River pierces both the Coast and Cascade ranges, allowing some of the maritime 

influence to reach northeastern Oregon, with the influence stronger in winter than in summer. 

The more complex terrain of the Siskiyou Mountains results in less influence from the marine air, even though 

the Rogue and other rivers flow into the Pacific Ocean. As these rivers cross through the coastal part of the 

mountains, the river valleys narrow considerably, limiting the ability of the marine air to penetrate inland in 

summer. Because of this (coupled with its lower latitude), southwest Oregon has a Mediterranean-type climate. 

Summers in southwest Oregon are among the warmest in the State, although winter temperatures are generally 

mild. High temperatures commonly exceed 90° F in summer while low temperatures rarely drop below 0° F, 

although the average minimum temperature is below 32° F. July is usually the warmest month and January the 

coldest month. Precipitation amounts and timing are similar to that of northwest Oregon, although generally on 

the low end of the range. Most winter precipitation falls as rain below 1300 feet elevation and snow above 4900 

feet elevation and a mixture in the transient snow zone. Winters tend to be cloudy and summers quite sunny. 

Thunderstorms occur 12-18 times per year, peaking in August with many storms between mid-July and midSeptember producing little rain (dry thunderstorms). 

Eastern Oregon has a more continental climate similar to that of the northern Rocky Mountains in the north and 

the Great Basin in the south. The Blue Mountains limit the penetration of marine air into the southeastern part 

of the State at all times of the year. Eastern Oregon is generally higher in elevation than western Oregon, which 

tends to moderate summer temperatures somewhat but results in cold winters. Eastern Oregon has the highest 

diurnal and annual temperature variation in the State. High temperatures in summer commonly exceed 90° F 

and low winter temperatures often drop below 0° F with average minimum temperatures generally well below 

32° F. July is the warmest month in north-central and southeast Oregon while August is generally the warmest 

month in south-central and northeast Oregon. January is the coldest month. Average annual precipitation ranges 

from 5 to 30 inches with higher amounts in the higher elevations of the Steens and Blue Mountains. Most winter 

precipitation falls as snow above 4900 feet, rain below 1300 feet, and a mix of rain and snow in between. Overall, 

eastern Oregon has more sunny days throughout the year than western Oregon. Summer thunderstorms occur 12­

18 times per year, peaking in August. Storms between mid-July and mid-September tend to be dry. 

Oregon is subject to a variety of severe weather events that help set the ecological limits for various native and 

non-native plants. Among these are cold snaps, heat waves, and drought. Cold snaps tend to occur when arctic 

air moves west of the Rocky Mountains and into eastern Oregon with occasional events reaching as far as the 

Oregon coast. A cold snap occurs over a several day period, often with both daily maximum and minimum 

temperatures dropping through the period. Twenty major cold snaps have occurred in the State between 1898 and 

1999. Cold snaps may affect only a small portion of the State or the entire State. January is the most common 

month for cold snaps, followed by December and early February. 

Heat waves occur when most or all of the State lies under strong high pressure that brings descending, warming 

air and clear skies resulting in temperatures well above average for the time period affected. Occasional very 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

hot days tend to be more common than multi-day (two or more days) heat waves in western Oregon. Thirty-five 

multi-day heat waves have been documented between 1898 and 1999. In eastern Oregon, the hottest temperatures 

during heat waves typically occur in river valleys. Heat waves have occurred in every month except January, but 

the hottest temperatures and longest heat waves typically occur in June through August. 

Drought is difficult to define with much precision; identifying the beginning and end of a drought is even more 

difficult. Most commonly, drought is defined relative to its duration and impacts on agriculture or hydrology, or 

for regulatory purposes. This analysis uses hydrological, or meteorological, drought. The hydrological definition 

includes multiple time scales (seasonal, annual, and multi-year) and all aspects of water supply (precipitation, 

stream flow, groundwater, and so forth). All of Oregon is subject to seasonal drought in summer, normally 

a very dry period with high inter-annual variation in precipitation amounts across the State. For ecological 

considerations, most plant and animal species can readily survive a one-year, or annual, drought. 

Multi-year droughts can alter many ecosystem processes and lead to various changes in plant and animal 

communities. Since winter and spring precipitation dominate Oregon’s climate, below-average precipitation in 

these months has a much greater impact than below average precipitation in summer and fall. The Palmer Drought 

Severity Index, which incorporates precipitation, runoff, evaporation, and soil moisture, is the most widely used 

indicator of hydrological drought. The Index6 indicates five significant multi-year droughts have affected all or part 

of Oregon since 1900. The worst drought remains the 1928-1941 period, the Dust Bowl era, which affected the 

entire State. Eastern Oregon was affected by severe drought from 1959 to 1964 while western Oregon was affected 

from 1976 through 1981. Another statewide drought occurred from 1985 through 1994. A third statewide drought 

began in 1999 and likely ended in 2005 in western Oregon but apparently has not ended in eastern Oregon. 

Two very important drivers of Oregon’s climate, particularly in winter and spring are the El Niño-Southern 

Oscillation (ENSO) and the Pacific Decadal Oscillation (PDO) (Mote et al. 2004). The cycle for ENSO is 2-7 

years and for PDO is 20-30 years. While ENSO primarily affects ocean conditions in the equatorial Pacific, PDO 

affects ocean conditions in the central and northern Pacific. Together, these two phenomena affect the strength 

and location of the Aleutian Low in winter and subsequent storm tracks. When both ENSO and PDO are in the 

same phase (cool-cool or warm-warm), the effects on Oregon’s climate are magnified; when both are in opposite 

phases (cool-warm or warm-cool) the effects are somewhat cancelled. During the warm phase of either, the 

Aleutian Low tends to deepen and cause the storm track to split around the Pacific Northwest, resulting in warm, 

dry winters. However, a moderate strength El Niño event is more likely to lead to that outcome. A strong El Niño 

event also causes the Aleutian Low to shift eastward, bringing warm, wet winters to Oregon. The wettest winters 

with the highest snowpacks tend to occur when both ENSO and PDO are in their cool phases. 

Biomes 

Because biophysical and biological characteristics vary widely on BLM lands in Oregon, it is helpful to divide 

the analysis area into smaller, more homogeneous areas for analysis. The PEIS to which this EIS tiers uses 

ecoregions adapted from Bailey (1997, 2002) to delineate areas with similar climatic conditions, geomorphology, 

and soils. These factors influence the composition and functioning of vegetative communities, and thus such 

regions can be expected to have sufficiently consistent responses in susceptibility and effects of invasive plants 

and vegetation treatments to facilitate effects presentations. 

The Palmer Drought Severity Index has numerous shortcomings in large part due to its inability to handle snow 

adequately. It remains the most widely used indicator in large part due to the length of record. The Standardized 

Precipitation Index addresses many of the shortcomings of the Palmer index and is becoming more widely used, but the 

period of record is short, only since 1993. 

95 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

 96 

For analysis in this Oregon-specific EIS, six biomes are identified in part by subdividing ecoregions used in the 

PEIS, and in part tiering to physiographic provinces used in the 1994 Northwest Forest Plan applicable primarily 

to lands near to or west of the Cascades. Five of the biomes are shown in Figure 4-2; the sixth is the East Side 

Riparian Biome, consisting of the riparian habitat that closely follows perennial and in some cases, intermittent 

streams in the dry eastern part of the State. The biomes provide a context for describing other elements of the 

affected environment later in this Chapter. However, resource these biomes are combined and/or split as needed 

to appropriately describe resource effects in this Chapter. Table 4-2 shows the amount of land managed by the 

BLM by biome. 

Table 4-2: blm lands by biome 

Biomes Acres of BLM Land % of Total BLM Land 

West of the Cascades 2,334,000 15 

Western Forest 1,482,600 9 

Willamette Valley 19,100 less than 1 

Siskiyou 832,200 5 

East of the Cascades 13,377,400 85 

Eastern Forest 1,150,700 7 

Sagebrush Steppe 11,618,500 74 

East Side Riparian 608,200 4 

The composition and distribution of plant communities in Oregon has been influenced by many factors, including 

climate, drought, fire, browsing by wildlife, domestic livestock grazing, settlement, mining, development, and 

cultivation. Other activities that have a direct or indirect effect on plant communities include logging, recreational 

activities, development of rights-of-way including road construction and maintenance. In addition, competition 

with non-native invasive plant species has resulted in the loss of native plant communities. Climate trends, 

projections, and implications are discussed later in this Chapter. 

Sagebrush Steppe Biome 

Description and trend - Plant communities occurring in this region are adapted to dry summers and cold 

winters. Elevations range between 2,500 and 8,000 feet. Precipitation ranges between 8 and 16 inches and 

occurs primarily during the winter. Three major sagebrush plant communities are generally identified: Wyoming 

big sage, mountain big sage, and low sage. An assortment of shrub species is associated with each sagebrush 

community, and understory vegetation throughout the type is typically dominated a mixture of perennial bunch 

grasses such as bluebunch wheatgrass, and forbs. These plant communities are both relatively resistant to, and 

adapted to, low intensity wildland fire, generally having a mean fire return interval of 20 to 100 years depending 

on climate and site productivity (Miller et al. 2000, Wright and Bailey 1982). In any event, recent unnaturally 

high-intensity wildfires (caused at least in part by invasive annual grasses like cheatgrass) have substantially 

reduced or removed sagebrush and its seed from burned areas, although most other shrub and understory species 

in a healthy sagebrush steppe community will reseed or resprout after fire. 

Native sagebrush plant communities benefit watersheds by providing vegetative litter, which serves as a nutrient 

source, provides soil surface protection by reducing impacts of precipitation, and traps surface water allowing 

for percolation into the soil profile. Healthy plant communities discourage encroachment of invasive plants. 

However, healthy sagebrush steppe communities are rapidly disappearing due to invasion of non-native plants 

(especially cheatgrass), high-intensity wildfires, and encroachment of Western juniper, and other disturbances. 

Sagebrush communities have been identified as one of the most threatened land types in North America, and as 

much as half of this land type has already been lost in the Great Basin (SageSTEP 2009). 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

The onset of settlement of western lands in the late 1800’s and introduction of livestock grazing on public land 

through the early 1930’s, combined with fire suppression, has greatly impacted the native plant communities in 

eastern Oregon (Miller and Wigand 1994). Largely unmanaged grazing during this time and the introduction of nonnative plant species resulted in declines of native perennial grass species and establishment of competitive (and often 

invasive) grasses. Invasive annual grasses have a competitive advantage because of their ability to utilize limited 

moisture early in the growing season, and because of their short life spans culminating in prolific seed production. 

Their rapid growth and short life spans also result in the production of fine flammable fuels that contribute to an 

increase in the spread and intensity of wildfires. Repeated wildfires result in the loss of sagebrush over large areas, 

leaving these areas dominated by invasive annual grasses. This conversion results in the loss of sagebrush obligate 

species, leading to an overall loss of species diversity. Roughly five million acres of the Sagebrush Steppe and 

Eastern Forest biomes are estimated to be occupied by invasive annual grasses (Appendix 1:3-28). 

Prior to European settlement, native Western juniper were primarily confined to rocky ridges or surfaces with 

sparse vegetation (Barney and Frischknecht 1974). The suppression of periodic fire has helped contribute to a 

four-fold expansion of Western juniper since 1930 into 6.4 million acres in eastern Oregon (Thompson 2007). 

Western juniper’s high water usage and allelopathic effects completely eliminate native perennial grass, shrubs 

and forbs, and even ponderosa pine, and create a challenging environment in which to restore native plant 

communities (Miller et al. 2005). The elimination of native plants by encroaching Western juniper results in 

increased erosion and decreased soil available for plants to reestablish. An estimated five million acres in eastern 

Oregon are currently occupied (Miller et al. 2005) with an unnaturally high population of Western juniper. 

Land ownership patterns - In the southern two-thirds of this biome, the BLM is the predominant landowner. 

Intermingled private lands are dominated by agriculture, ranching, and their associated communities. Adjacent 

ranchers often hold permits to graze livestock on BLM lands, and grazing-related infrastructure developments are 

often on BLM lands under permit. Boundaries between private and public lands are often discernable by no more 

than a fence, if at all, and vegetation migrates readily between ownerships. Successful invasive weed control 

and other vegetation management is typically a cooperative effort between private owners, weed control districts, 

weed boards, local governments, and the BLM. 

Eastern Forest Biome 

Plant communities occurring in this region are adapted to dry summers and cold winters. Elevation is between 

2,500 and 8,000 feet. Precipitation ranges between 10-27 inches and occurs primarily during the winter (Franklin 

and Dyrness 1988). Plant communities are dominated by various species of coniferous trees, with ponderosa pine 

in the lower elevations and western larch and grand fir in the higher elevations. Lodgepole pine is also present, 

particularly close to the Cascades between Highway 97 and the crest. A mixture of perennial bunch grasses 

and forbs is the most common associated vegetation. This associated vegetation also often includes sagebrush, 

bitterbrush, and various other shrubs, particularly under the more open ponderosa stands and between forested 

sites. Low flat areas often associated with water can be dominated by perennial grass/forb communities, and most 

of these are private lands dating from early homesteading. Variation in plant communities at the local scale is 

influenced by differences in soil types, moisture regimes, weather patterns, cold air drainage pockets that preclude 

successful conifer regeneration, and grazing and fire history. 

97 
figUre 4-2. oregon biomes 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Frequent natural fires historically kept the pine stands open, regenerated the lodgepole pine before it began to 

naturally decline about age 80, and kept the fir restricted to higher elevations. Recent decades of fire suppression 

coupled with harvesting of larger pines have resulted in the buildup of downed logs and limbs, and higherthan-normal stocking that includes dense understories and drought-sensitive fir. This denser forest shades out 

the shrub/forb/grass understory vegetation and otherwise changes the structure and composition of the plant 

community and its dependent wildlife. The accumulation of biomass and understory fuel ladders result in 

frequent stand replacing wildfires. These unnaturally hot fires kill most trees regardless of size, setting back 

succession and allowing invasive plants to get a foothold. Nearly 100 percent of east side pine forests have 

invasive annual grasses in the understories (Donnegan et al. 2008), but they do not materially affect the relatively 

fire resistant pines and other conifer species. 

Forest management activities are conducted to promote forest stand health and resiliency to fire, insects, and 

disease. Treatments include thinning to reduce densely canopied young forests, fuels reductions of overstocked 

stands resulting from many years of fire suppression, fire salvage to reduce fuels and capture surplus mortality, 

and/or uneven age stand management to restore pre-settlement stand conditions. During 2005 -2007, an average 

of 2.3 million board feet (MMBF) of timber was offered for harvest each year, and an average of 2.0 MMBF was 

harvested (2,450 acres per year). 

East Side Riparian Biome 

Riparian-wetland areas occupy approximately 4 percent of public land acres in eastern Oregon, but contain some 

of the most productive and highly prized resources in this part of the State. The functions of wetland and riparian 

areas include water purification, stream shading, buffering effects of flooding, stream bank stabilization, ground 

water recharge, and habitat for aquatic, semi aquatic, and terrestrial plants and animals (EPA 2005b). Riparian 

zones include the green zones along flowing water features such as rivers, streams, and creeks (Gebhardt et al. 

2005) and many standing water features such as lakes, ponds, and seeps. Ephemeral streams where water flows 

for only brief periods during storm runoff events typically do not support a full suite of riparian vegetation or 

benefits. 

Species present include but are not limited to cottonwoods, aspen, and other Populus species (often genetically 

distinct by drainage), alder, willows, dogwood, water birch, conifers, and their associated shrubs, forbs and 

grasses (although some riparian areas are characterized by grass and forb communities)(Crowe et al. 2004). This 

vegetation is immediately associated with the stream channel and associated wetlands, and typically contrasts 

starkly with the surrounding upland vegetation. 

The BLM defines Proper Functioning Condition (PFC) for wetland and riparian areas to be functional when 

adequate vegetation, landform, or large woody debris is present (Prichard et al. 1993): 

1) to support adequate vegetation, landform, or debris to dissipate energies associated with wind action, wave 

action, and overland flow from adjacent sites thereby reducing erosion and improving water quality; 

2) filter sediment and aid floodplain developments; 

3) improve floodwater retention and groundwater recharge; 

4) develop root masses that stabilize islands and shoreline features against cutting actions; 

5) restrict water percolation; 

6) develop diverse ponding characteristics to provide the habitat and the water depth, duration and temperature 

necessary for fish production, water bird breeding, and other uses; and, 

7) support greater biodiversity 

PFC assessment does not take into consideration the habitat value of the area for fish and wildlife. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The BLM in eastern Oregon administers 8,508 miles (467,840 acres) of riparian areas of which 38 percent is at 

PFC; less than 34 percent is functioning at risk; 2 percent is non-functional, and 26 percent is unknown. There are 

also 140,328 acres of wetland of which 93 percent is at PFC and the balance is unsurveyed (USDI 2007b). 

Siskiyou Biome 

Geography and Physical Environment - The Siskiyou biome encompasses the physically and biologically diverse 

Klamath Mountains in southwest Oregon. The terrain is highly dissected with elevation ranging from less than 

1,000 feet in valley bottoms to 4,000 to 6,000 feet on ridge crests, with some peaks as high as 8,000 feet. The 

region generally experiences mild wet winters with long dry hot summers, commonly referred to as a Mediterranean 

climate. The biological diversity is attributed to the varying annual precipitation amounts, elevational ranges, 

topography, the type of parent material or underlying soils, and soil moisture (Strothmann and Roy 1984). 

Vegetation communities can be separated into three main forest types: oak woodlands and savannah, mixed 

conifer/evergreen forest, and coastal forest (Agee 1993). Oak woodlands, savannahs, and shrublands typically 

occupy drier sites at lower elevations. Grass-dominated7

 savannahs may have up to 30 percent canopy cover of 

trees. Mesic (moist) oak woodlands may show greater canopy closure of California black oak or Pacific madrone, 

while drier non-clay sites show increased domination by shrubs. Common tree species include oaks (mostly black 

and white oak), Pacific madrone, and conifers (predominantly ponderosa pine and some Douglas-fir and cedars). 

The shrub layer consists of buckbrush, birch-leaf mountain-mahogany, manzanita, and poison oak. 

Mixed conifer/evergreen forests in this biome typically include an overstory of mixed conifers, with conifers 

and sclerophyllous8 broadleaved trees in the under-story. The most dominate species is Douglas-fir. Depending 

on the elevation, topography, and annual precipitation, other dominant or co-dominant species could include 

tanoak, ponderosa pine, sugar pine, and Pacific madrone. A variety of other trees may also be present including 

hardwoods such as canyon live oak, black oak, and chinquapin, and conifers such as incense-cedar in the lower 

elevations, Jeffrey pine on serpentine, western hemlock, grand fir and white fir in mid to upper elevations, PortOrford-cedar and Pacific yew on moist or coastal sites and within riparian areas, and knobcone pine on recent 

burns. Understory communities (low shrub and herb layers) are usually not well developed but can include 

poison oak, Oregon grape, California honeysuckle, vine maple, oceanspray, California hazel, and wildrose 

(Strothmann and Roy 1984). Riparian areas are similar but with an increase in hardwoods such as big leaf maple 

and dogwood. After stand-replacing fires, succession to conifers can be slow, often going through evergreen 

hardwood or dense evergreen chaparral stages first (Strothmann and Roy 1984). 

The coastal forest lies in a thin band along the coast. Mature forests are co-dominated by Sikta Spruce, western 

hemlock, and western redcedar (Agee 1993). Douglas-fir, true fire, and Port-Orford-cedar are found as secondary 

species, while red alder may dominate disturbed sites, and black cottonwood and big leaf maple can be found in 

riparian areas (Agee 1993). The understory may include salmonberry, salal, red huckleberry, and vine maple. 

Slightly more inland and on the lower drier valleys, Douglas-fir is the climax species while Pacific Silver fir 

and western hemlock occur in the higher elevations. The coastal forest shares many density and structural 

characteristics with the Western Forest Biome further north, but coastal forests in the Siskiyou Biome include 

Port-Orford-cedar, tanoak, and a few redwood. 

Disturbance trends - At most sites away from the coast, frequent low and mixed severity natural and 

anthropogenic (American Indian) fires historically played a critical role in determining species’ composition and 

7 Most commonly Roemer’s fescue and/or Idaho fescue.
 

8 Hard-leaved evergreen shrubs that are adapted to the hot summer.
 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

structure (Agee 1993). Low intensity fires in the oak woodlands, savannahs, and mixed-conifer forest controlled 

regeneration of fire-intolerant species, promoted fire-tolerant species, maintained an open forest structure, reduced 

forest biomass, decreased density-related insect and disease mortality, and helped maintain habitats for species 

that utilize open stand structure (Graham et al. 2004). Fires affected soil properties, watershed hydrology, and 

forest stand dynamics. Oak woodlands, savannahs, and the lower elevation drier mixed-conifer forests were 

burned frequently by American Indians (Agee 1993) much more so than lightning. These fires were of low 

intensity and usually of short durations, carried by surface layer fuels such as grasses, forbs, leaves and needles, 

maintaining open prairies and savannahs, and reducing the understory vegetation and surface fuels. 

In the oak woodlands, savannahs, and mixed-conifer forest, intensive fire suppression efforts in the last 60 years 

has resulted in considerable fuel accumulation in some areas, and substantial shifts in tree species’ composition 

and forest stand structure. This shift has led to increasing the density of shrubs and oaks thereby transforming the 

savanna into woodlands, and has resulted in an expansion of Douglas-fir and shrubs in the oak woodlands (Agee 

1993). Fire exclusion in the drier mixed conifer forest has contributed to an increase in understory vegetation, 

permitting vast areas to accumulate uncharacteristically high levels of ladder fuels, which contribute to an 

increased risk of high-severity, stand replacement fire (Graham et al. 2004). As a result, these changes have made 

forests more susceptible to large, high severity fires such as the 2002 Biscuit Fire, which burned over 500,000 

acres of forest. 

In the more moist coastal and higher elevation forests, fire was less frequent but typically burned at higher 

intensity resulting in a high severity fire regime and larger fires (Agee 1993, Frost and Sweeney 2000). These 

fires also resulted in patch diversity, but at a much larger scale than patches occurring in the low and mixed fire 

severity landscapes. These natural forest patches contributed to the diversity of the broader landscape (USDA, 

USDI 2007:149). Less frequent high-severity fires occurred in the forest adjacent to the coastal forests and in 

some rare cases during periods of prolonged drought in the Sikta Spruce coastal forest (Agee 1993). Wind events 

historically played a greater role in the Sikta Spruce coastal forest in creating forest openings and regeneration 

(Agee 1993). 

Land ownership and use - Land ownership patterns as well as public and commercial use in this biome 

substantially contribute to the risk of invasive plant spread. At higher elevations and in some areas nearer the 

coast, large sections of continuous public lands occur on National Forests. However, at lower elevations much 

of the land is a fragmented checkerboard pattern of lands managed by the BLM, State of Oregon, private timber 

companies, other private owners, and tribes. Home building and other development has increased urbanization 

of oak woodlands, savannahs, and lower elevation mixed conifer-forest into what is commonly referred to as 

the wildland/urban interface (WUI). This urbanization and appurtenant increase in wildland use has increased 

wildfire occurrence and off-highway vehicle and other recreational use, all of which contribute to the introduction 

and spread of invasive plants. 

Western Forest Biome 

Geography and Physical Environment - The Western Forest Biome is dominated by the coast range that 

reaches 4097 ft in elevation, and the lower elevations on the west slope of the Cascades (where BLM lands are 

generally below 4,000 ft.) Both mountain ranges are north-south trending, generally separated north of Eugene 

by the Willamette Valley (Figure 4-2). Geologic conditions in the coast range are highly variable, but typically 

comprised of older basalt and newer marine sedimentary formations. 

Most of the biome is rugged with steep canyons. Precipitation and temperature interact with physiography to 

provide the setting for hydrologic processes and disturbance events. Tributary streams are short with steep 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

gradients. The Willamette River drains the northeastern half of the biome. The remainder is drained by rivers 

flowing directly to the Pacific (Umpqua, Nestuca, etc.). Streamflow peaks are generally caused by winter rainfall 

and from spring snowmelt. 

Vegetation - Abundant precipitation and mild temperatures allow highly productive coniferous and deciduous 

forests to dominate. Complex, multi-storied evergreen forests occupy much of the region, with species’ 

composition varying by altitude and climate. At lower elevations, Douglas-fir, western hemlock, western red 

cedar, grand fir, Pacific silver fir, and Sitka spruce are the dominant conifer tree species. In the Coast Range, 

Sitka spruce dominates the immediate coast, while a mosaic of Douglas-fir, western hemlock and western red 

cedar dominate inland areas. Douglas-fir plantations of various ages up to 50 years are common and even more 

prevalent on intermingled private lands that are intensively managed. Sitka spruce/western hemlock forests occur 

where climatic conditions are dominated by maritime influence. 

Hardwood species occur sparsely throughout this type of forest and are often found in disturbed or riparian 

habitats. Hardwoods include red alder, bigleaf maple, and, on warmer drier sites, Pacific madrone and giant 

chinquapin (Franklin 1988). Understory species include salal, oceanspray, western swordfern, redwood sorrel, 

Cascade barberry, and Pacific rhododendron. Understory community composition varies with locality, but similar 

understories are found in both mature and less mature forests. 

Vegetation in pre-forest succession is heterogeneous and reflects logging, fire, and other disturbance history. 

Woodland ragwort and fireweed are common herbs that are found the first years after fire or other disturbance. 

The herb community is succeeded by shrubby species such as perennial vine maple, trailing blackberry, low 

Oregon grape, Pacific rhododendron, and various ceanothus. Diversity and biomass of herbs and shrubs declines 

once the canopy closes. 

Non-forested areas account for about four percent of this biome (105,000 acres), and include rock outcrops, cliffs, 

talus areas, grasslands, shrublands, herbaceous wetlands, vernal pools/ponds, bodies of open water (e.g., ponds, 

small lakes, reservoirs, and rivers), coastal dunes/open sand, coastal grasslands, and salt marshes. 

Riparian and wetland areas occur throughout the biome. Red alder, willow, and other broadleaf species can 

predominate on floodplains and recent mass movement (slide) areas. Although riparian areas serve as important 

habitat for some wildlife species, they are not as important to most wildlife as those east of the cascades because 

the vegetation and moisture difference from the surrounding landscape is not so pronounced. Some key 

ecological processes that shape riparian and wetland areas are tree growth and mortality (which affect stream 

shade, nutrient input, and large wood delivery), hydrology (floods and groundwater), landslides, and sediment 

routing. These factors have great influence on the ability of aquatic habitat to support fish populations (Meehan 

1991, OWEB 1999). Aquatic ecosystems in this biome are naturally dynamic, changing over time due to natural 

events as wildfires and large storms, and the subsequent floods, hillslope failures, landslides, and debris flows 

(Haynes et al. 2006, Naiman et al. 1992). 

Disturbance trends – Before the 1970s, large wood was generally considered a nuisance or hazard in streams. 

Large wood was systematically removed from streams to benefit river navigation, prevent or decrease flooding 

effects, enhance log transportation, and improve fish passage (Maser and Sedell 1994 cited in Reich et al. 2003). 

In the wetter northern portion of this biome (particularly in the coast range) high-intensity stand-replacing fires 

and/or major wind events may be separated by hundreds of years. Regular small-scale events (gap dynamics) are 

caused by insects, slides and floods (evidence of historic mass movements is ubiquitous), windthrow, and disease. 

Recent timber harvest has changed the dominant vegetation, with most harvest units having been replaced with 

even-aged stands of Douglas-fir. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

The primary natural disturbance event in the southern part of the biome is wildfire. Historically, frequent low or 

mixed-severity fires limited the expansion of less fire-tolerant species such as true firs. Recent exclusion of fire 

has resulted in expansion of these species into the surrounding ecosystems. The resultant overstocking has led to 

more insect mortality, and has increased fuels supporting a trend toward more intense fires (USDA 2005; USDA, 

USDI 2007). 

An extensive road network has contributed to an increase in slide events, wildfires, and the increasing soil and 

vegetation disturbance. These disturbance events, coupled with high human use, have introduced and spread 

invasive plants like Scotch broom, gorse, English ivy, and Himalayan blackberry to forestland. These non-native 

plants typically reduce native-plant diversity and prevent or delay the regeneration of native vegetation. 

Land ownership and use - BLM lands here are primarily used for timber production and recreation. Land 

ownership patterns as well as public and commercial use in this biome substantially contribute to the risk of 

spreading invasive plants. At higher elevations and in some areas nearer the coast, large sections of continuous 

public lands occur on National Forests. However, at lower elevations much of the land is a fragmented 

checkerboard pattern of lands managed by the BLM, State of Oregon, private timber companies, other private 

owners, and tribes. The population centers in the nearby Willamette Valley contribute to increased wildfire 

occurrence, timber harvest, off-highway vehicle and other recreational use, and grazing, all of which contribute to 

the introduction and spread of invasive plants. 

Willamette Valley Biome 

Geography and Physical Environment - The Willamette Valley Biome is a lowland approximately 150 miles 

north-to-south, and 60 miles wide. Prior to European settlement, the broad, Willamette Valley was characterized 

by rolling prairies, deciduous/coniferous forests, and extensive wetlands. Willamette Valley landforms are 

terraces and floodplains, interlaced and surrounded by rolling hills. 

Much of the Valley was once Douglas-fir, western hemlock, and western red cedar forests. Some natural forests 

remain, but most have been developed for agricultural and urban uses. Less extensive vegetation types include 

Oregon white oak woodlands (scattered stands at low elevations that were frequently burned by American Indians 

to stimulate mast production) and prairies (perennial graminoid communities that are now remnant patches). 

Deciduous shrubland, often established following fire or other disturbance, can be found scattered in coniferous 

forest areas in small to large patches. These shrublands can persist for decades or longer before succeeding to 

woodland, then forest. 

Native west side grasslands are found in dry, upland prairies and savannas or on grass- and forb-dominated cliffs, 

bluffs and balds, which often have a minor component of Oregon white oak, Douglas-fir and/or ponderosa pine. 

Moist meadows can occur in small valleys. Bunchgrasses dominate the grasslands, while a combination of sedges, 

rushes and bunchgrasses dominate natural meadowlands. Many of these have been invaded by non-native grasses. 

Disturbance trends - Conversion for urban and agricultural uses is the ultimate disturbance, because the site no 

longer returns to forest, prairies, or wetlands. The amount of conversion was substantial during settlement, but 

Oregon’s land-use system now limits such changes. Little remains of some of the native grassland communities. 

Farming, recreation, and other human activities along with a well-developed road system readily spread invasive 

plants in this biome. 

Land ownership and use - BLM lands occupy only a small portion of this biome, generally along the hilly west, south, 

and east margins. Productive soils and a temperate climate make it the most important agricultural area in Oregon. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Noxious Weeds and Other Invasive Plants 

Affected Environment 

Invasive plants (or weeds) are non-native aggressive plants with the potential to cause significant damage to 

native ecosystems and/or cause significant economic losses. They successfully compete with native plants for 

light, water, soil nutrients, and space, resulting in their dominance of the plant community and the displacement 

of native plants and the fauna that depend on them. Invasive plants can cause profound changes to native 

ecosystems including changes in seral progression, habitat, nutrient cycling, water availability, soil qualities, soil 

productivity, and fire regimes. Ecological damage from extensive noxious weed infestations is often permanent 

(Dewey 1995). The spread of invasive plants threatens the structure and function of many ecosystems worldwide 

(Higgens et al. 1996, Heywood 1989:31-34). There are estimated to be over 1,030 species of non-native plants 

in Oregon (Oregon Flora Project 2008), and 225 of them are considered invasive by the BLM in Oregon. Not all 

non-native plants are considered invasive. Indeed over 90 percent of our food crops are non-native to the United 

States. There are approximately 2,000 non-native plants estimated to be in the U.S. (OTA 1993). Eight hundred 

sixty-two (43 percent) of the non-native plants are found in the Pacific Northwest (Washington, Oregon, Idaho, 

Montana, and Wyoming) and 115 of these have been legally declared “noxious weeds” by at least one of the five 

states (Quigley and Arbelbide 1997:783-784).9 

Noxious weeds are a subset of invasive plants that are County, State, or Federally Listed as injurious to public 

health, agriculture, recreation, wildlife, or any public or private property. Noxious weeds regulated by State 

and Federal laws, such as the Federal Noxious Weed Act of 1974 and the Oregon noxious weed quarantine 

administrative rule (OAR 603-052-1200). The quarantine rule prohibits import, transport, propagation or sale 

State listed noxious weeds and plants on the Federal Noxious Weed List (7 CFR 360.200) because they are 

detrimental to agriculture, natural resources, and/or public health. These weeds choke out crops, destroy range 

and pasture lands, clog waterways, affect human and animal health, and threaten native plant communities. 

Designating additional noxious weeds is a continuous process, as additional invasive plants are recognized as a 

particular problem. The number of noxious weeds listed by the State of Oregon increased 40 percent between 

1991 and 2001. 

Traits of Invasive Plants 

Noxious weeds and other invasive plants have biological traits that enable them to colonize new areas and 

successfully compete with native species. While not all invasive plants share all of these traits, most have one 

or more that allow them to compete successfully. These traits include deep tap roots or extensive root systems; 

little surface foliage (allowing the plants to grow later in the summer than most native rangeland plants); earlier 

growth and reproduction than most natives; seeds that remain viable near the soil surface for decades; adaptations 

for spreading long and short distances; production of many seeds from one 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; and production of toxic compounds that negatively affect 

neighboring plants (USDA 2005). Once established, these species can dominate due to the absence of the insects, 

pathogens, disease, and herbivores that keep them in balance in their native ecosystems give. 

9 The number of State-listed noxious weeds has grown since these numbers were compiled in 1997. There were 121 

noxious weed species listed in Oregon by 2009 (Appendix 7: Table A7-1). 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Mechanisms of Invasion 

Invasive plants enter Oregon from other countries in shipping containers, on vehicles, on or in various products 

or packing materials, on clothing, with other plants or soil, or are brought in intentionally as ornamentals or 

to accomplish some management objective. They also enter Oregon from neighboring states, and move great 

distances within the State on off-road and other vehicles, on camping and other recreational equipment, on pack 

stock and livestock, in hay and other feed crops, on construction equipment, on the wind, on animals including 

within feces, and as intentionally moved ornamental plants or inadvertently within the soil of such plants (USDI 

1996). Infestations begin mostly on disturbed sites, such as at trailheads, along roads and trails, firebreaks 

or burned areas, landing pads, oil and gas development sites, timber harvest areas, wildlife and/or livestock 

concentration areas, and campgrounds. 

The plant invasion process occurs in three phases: introduction, establishment, and spread. Once an introduction 

occurs, a delay or lag phase often takes place while an invasive plant becomes established. The length of this 

initial phase varies, but it can last for up to 100 years (Hobbs and Humphries 1995). This phase is followed by a 

period of rapid growth that continues until the invasive species reaches the bounds of its new range (Figure 4-3, 

Mack et al. 2000). 

figUre 4-3. relaTionsHiP beTWeen area occUPied by invasive sPecies and Time. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Once an invasive plant is introduced, control programs are most effective if they identify and eradicate the 

infestation while it is still in the introduction phase. Control efforts in this phase can prevent future infestations 

on tens to hundreds of times more acres (Radke and Davis 2000:25). Regular field surveys attempt to detect as 

many populations in the introduction (or early establishment) phase as possible. Once a weed is well established, 

not only is it more numerous and likely to have contributed heavily to the soil seed bank, native plants critical to 

successful restoration on control sites may have been severely reduced or eliminated. Eradication at this point 

quickly becomes impractical. 

Maintaining cover of native plant species on public lands is critical to halting the spread of noxious weeds. In a 

45-year study of a sagebrush steppe landscape in Idaho, areas with the highest cover of native species exhibited the 

greatest resistance to invasion by cheatgrass (Anderson and Inouye 2001). Open and disturbed plant communities 

are more likely to be invaded, while undisturbed forests are less invaded (Rejmanek 1989:389-390). However, 

shifts in plant communities resulting from climate change, whether those shifts occur rapidly through increases in 

stand-replacing wildfire or more gradually through increased mortality in the native ecosystem, will favor increased 

expansion of invasive plants (see the Climate Trends, Projections, and Implications section in this Chapter). 

Natural, climate driven, or human-caused ground-disturbances increase the likelihood of invasive weeds becoming 

established. Planned BLM management activities potentially creating a moderate or high risk of establishing 

invasive plants must include a plan for their prevention, monitoring, and control (Appendix 3) (USDI 1992b). 

Weed Infestations in Oregon 

In 2007 it was estimated that noxious weeds infest 1.2 million of the 15.7 million BLM administered lands in 

Oregon, and are spreading at an annual rate of about 12 percent or 144,000 acres per year (Appendix 7). At 

this rate, acres infested10 with noxious weeds will double in about eight years. Direct control practices with and 

without herbicides are currently implemented on just over 20,000 acres per year, mostly targeted at infestations 

still in the introduction or early establishment phase where they have a disproportionately beneficial effect on the 

long-term spread rate. Without this control, the current spread rate would certainly be higher. However, certain 

weed species cannot be effectively controlled with methods or tools currently available to the BLM in Oregon. 

For about 25 species of noxious weeds already well established in the State, weed control in Oregon has included 

the release of bio-controls in the form of insects and pathogens from the weed’s native lands (OSU 2009). While 

these agents do not eliminate the weed, they often reduce its density enough to reduce ecological damage and 

allow native plants to survive. 

There are 121 species on the Oregon noxious weed list in July 2009 (Appendix 7). Six of these are estimated to 

infest more than one million acres each statewide (all ownerships): yellow starthistle, Scotch broom, Himalayan 

blackberry, quackgrass, field bindweed, and Canada thistle. Another eight are estimated to infest more than 

100,000 acres statewide: perennial pepperweed, medusahead rye, St. Johnswort, diffuse knapweed, poison 

hemlock, English ivy, bull thistle, and tansy ragwort. Oregon loses more than $83 million annually to just 21 

noxious weeds (Radke and Davis 2000). 

Additional examples include: purple loosestrife is present in 32 of Oregon’s 36 counties. One mature plant can 

produce 2.7 million seeds the size of ground pepper. It also spreads vegetatively; disturbance to underground 

10 “Infested” means anything from a single individual to a monocultures of noxious weeds, so the 1.2 million acres is gross 

acres. Radke and Davis’ (2000) examination of 21 noxious weeds in Oregon (all ownerships) suggested a gross to net ratio 

of about 5:1. Adverse effects to various resources described within this Chapter usually vary by the level of infestation. 

Nevertheless, adverse effects are proportional to the acres expected to become infested under each alternative. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

stems or roots during incomplete plant removal initiates bud growth (WA Dept of Ecology a). Spotted knapweed 

has invaded 34 of Oregon’s 36 counties. It suppresses surrounding native plants by altering soil chemistry, 

forming monocultures that have resulted in changes to elk migration routes. During a 12-year period ending in 

2001, spotted knapweed expanded 42-fold, and yellow starthistle expanded 11-fold. Blackberry infests many 

riparian areas and is beginning to occur east of the Cascades. It limits human and wildlife access to streams, 

outcompetes native riparian species, and the resultant monoculture provides poor soil cover and stream bank 

protection, resulting in increased sedimentation and damage to water quality and spawning gravels. Scotch 

broom-related reductions in timber volume within Oregon have been valued at over $47 million annually (Radke 

and Davis 2000:19-20). Yellow starthistle makes rangeland unusable, closing grazing allotments, ruining ranches, 

and displacing wildlife. Some noxious weeds like gorse, Scotch broom, and medusahead are highly flammable. 

In 1936, the town of Bandon, Oregon, was destroyed and 11 citizens killed by a fire propagated by gorse, a highly 

flammable plant introduced 70 years earlier (Simberloff 1996). This species is still being battled along the Oregon 

and California coasts. 

Other (non-noxious) invasive plants, particularly cheatgrass (Bromus tectorum) infest an additional 5 million 

acres of BLM lands in Oregon. Cheatgrass, (like noxious medusahead rye), is an invasive annual grass that 

grows, seeds, and cures early in the summer. This pattern depletes soil moisture needed by native plants, and 

results in flashy fuels that burn regularly – also eliminating native species. The seeds survive the burning, so the 

ecosystem is rapidly converted from a perennial bunchgrass/forb/shrub community relatively resistant to fire, to 

a monoculture of unpalatable11 annual grasses that burn regularly. In addition to the ecological damage, the fire 

hazard created by these grasses threatens communities and other infrastructure improvements. 

See Additional Information About the Ecological Damage Caused by Invasive Plants in Appendix 7. 

BLM cooperates with the Oregon Department of Agriculture (ODA), local weed boards, adjacent landowners, 

and others to control infestations. The State assigns noxious weeds to two lists depending upon statewide 

management objectives (Appendix 7: Table A7-1). A-list weeds are likely to occur in Oregon or do occur 

in Oregon at a low enough level that eradication is possible statewide. B-list weeds are more common and 

widespread, at least in some areas of Oregon. Additionally, a T-list includes weeds from either the A or B list for 

which the State has targeted funding. 

Environmental Consequences 

Noxious weeds and other invasive plants typically have characteristics that enhance their survival at the expense 

of native species. Their structure and development is such that they use more moisture, provide less soil 

protection, alter soil chemistry, are unpalatable to wild horses and livestock, do not support native fauna, and 

have various other negative effects on the natural or current environment. In order to help quantify these effects, 

this section attempts to estimate the differences between the alternatives in terms of how well they will or will 

not change the rate of spread of noxious weeds on BLM lands, and thus how they will affect the total acres 

infested with noxious weeds at some point in the future. The importance of these estimates cannot be overstated. 

Although the various sections in this Chapter identify some additional risk to the human environment from the 

proposal to increase the number of herbicides and the management activities they may be used for on BLM lands 

in Oregon, the environmental and even human health risks associated with the continued increase of noxious 

weeds must likewise be considered. 

11 to wildlife and livestock 

107 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

While projections of weed spread in this section are based on considerable published data, it is acknowledged 

that attempts to quantify future weed spread require many assumptions. Some of these assumptions may not be 

entirely accurate, either because management emphasis may change or because the assumptions themselves are 

simply flawed. Therefore, the projections in this section should be viewed not so much as predictions of what will 

occur over time, but as reasonable approximations of the relative differences between the alternatives. 

Efforts by academia and others to develop spread rate models for individual plants have been unsuccessful 

because of the number of variables involved and the inability to predict propagule movement by humans. 

Therefore adverse effects from individual invasive plants are described more qualitatively than quantitatively in 

this EIS. Predicting general relationships for noxious weeds as a group, however, are possible. 

Noxious Weed Spread Rate by Alternative 

The following estimates are for noxious weeds only. Invasive plants are not included because their spread rate 

was not part of most “current rate” spread estimates gleaned from several sources (Denton 2009), because control 

efforts under the alternatives are expected to be devoted primarily to noxious weeds, and because noxious weeds 

are typically the most damaging economically. There are many other invasive plants infesting Oregon that are 

also a problem on BLM lands – particularly cheatgrass. The estimates are based on acres projected to be treated 

under each of the alternatives (Table 3-3), which assume current budget trends. 

Acres of Noxious Weed Control Treatments by Alternative 

Table 3-3 in Chapter 3 shows the annual acres of herbicide and non-herbicide control treatments projected to take 

place under each of the five alternatives for the next 10 to 20 years. Under the No Action Alternative, Alternative 

2, projected (gross) treatments for the control of noxious weed and other invasive plants total 45,500 acres (Table 

4-3), of which 16,700 are expected to be done with herbicides (Table 3-3). Most or all of these treatments (and 

certainly all of the herbicide treatments) are likely to be focused on noxious weeds. 

Total (gross) control acres under Alternative 1 are projected to be 42,100 acres, none using herbicides. 

Approximately 80 percent of the herbicide treatments under of Alternative 2 would still be conducted, but with 

non-herbicide methods under Alternative 1. The remaining 20 percent would not be conducted because many 

noxious weeds are simply not effectively controlled with non-herbicide methods and because such methods 

typically cost more and are thus limited by budget constraints. 

The increase in the number of herbicides that would be available under Alternative 3 would mean additional weed 

species could be treated effectively. Weeds currently being treated with the four herbicides under Alternative 

2 could be treated more efficiently with additional herbicides, and some expensive non-herbicide treatments 

currently being done would be replaced by herbicide treatments. The annual acres of herbicide and non-herbicide 

invasive plant control treatments under Alternative 3 through 5 are projected to be 58,700 gross acres, all but 

1,000 acres of which are expected to be focused on noxious weeds.12 

Percent of Treatments that Result in “Effective Control” 

Weed control treatments are not 100 percent effective at controlling treated populations. Under any alternative, 

some level of retreatment may be necessary to achieve complete control. A five-acre treatment, for example, 

would be monitored, and a portion of the acres might require retreatment. The amount of retreatment necessary is 

12 One thousand annual treatment acres using imazapic under this alternative are expected to be used on cheatgrass, which 

is an invasive plant but not a State-listed noxious weed. Numbers used in effectiveness projections discussed in this 

section are for noxious weeds only. 

 108 
 

 

 

 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

largely a function of how likely treatments are to control the target weed on the first try. 

Alternative 1 – No Herbicide Use: Nearly two-thirds of the noxious weeds in Oregon cannot be effectively 

controlled with non-herbicide methods (Appendix 7: Table A7-1). Also, non-herbicide methods (particularly 

mechanical and directed livestock treatments) can disturb soils and lead to reinvasion, and can transport weeds 

off site. In addition, many woody species resprout if controlled with non-herbicides methods. The WallowaWhitman National Forest Invasive Plant Treatments Draft EIS (USDA 2009b:107) estimates efficiency of their 

mostly non-herbicide No Action Alternative at 25 to 35 percent. The estimated efficiency of Alternative 1 in this 

EIS is 30 percent. In other words, 30 percent of the acres treated under Alternative 1 would control the weed 

population on the treated acre. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only: The efficiency of Alternative 2 is 

limited (though not nearly as severely as Alternative 1) because only four herbicides are available. About a dozen 

noxious weeds cannot be effectively treated with these four herbicides. Treatments for these species do not 

eradicate the infestation but are often conducted anyway because they reduce vigor or retard seed development 

and thus slow the spread. The estimated efficiency of treatments under Alternative 2 is 60 percent of the total 

acres treated. In other words, 60 percent of the acres treated under Alternative 2 control the weed population on 

the treated acre. In addition, the inability to treat other invasive plants with herbicides increases the likelihood 

additional plants will become well established before they are declared noxious. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases: Under 

Alternative 3, the wider range of herbicide options would increase the effectiveness of the average treatment. 

Although some level of retreatment would still take place, the additional herbicides would substantially improve 

the chances the weed would be controlled by a treatment. Herbicides would be available that would effectively 

control all of the hundred-plus noxious weeds but one, as well as cheatgrass, and other invasive annual grasses. 

Non-herbicide methods could be more focused where they are effective, or used in conjunction with herbicides 

and thus all treatments under this alternative would be more efficient. Some new invasive weeds would be 

identified and controlled before they are listed as noxious. The estimated efficiency of this alternative is 80 

percent. 

The efficiency of the alternative translates the gross treatment acres listed on Table 3-3 to effectively treated 

acres (Table 4-3). The effectively treated acres are those that control the weeds from the site and prevent future 

weed spread. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses and Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity 

Vegetation Management Objectives: Alternatives 4 and 5 assume the same 57,700 acres of noxious weed 

treatments as Alternative 3 (and thus the same efficiency), but add 9,300 acres of herbicide use to control native 

plants encroaching on rights-of-way, administrative sites, and recreation sites (Table 3-3). These sites are 

typically managed in an early seral or disturbed condition favorable to noxious weeds. These areas are also likely 

to become infested with noxious weeds and other invasive plants since seeds are more readily transported into 

access corridors by human activity. Thus, the 9,300 acres of herbicide treatments targeted at native plants in these 

areas under Alternative 4 (and 5) are assumed to also (inadvertently) control additional noxious weeds missed 

by noxious weed control efforts under Alternative 3 because of funding limitations or incomplete inventories.13 

It is estimated 25 percent of these rights-of-way and related native vegetation treatments, or 2,350 acres, will 

unknowingly treat these noxious weeds (Table 4-3). This 25 percent estimate includes a de facto weed control 

effect from simply replacing existing mechanical vegetation controls with herbicide treatments, reducing the 

likelihood that the maintenance equipment itself will spread weeds down the road. 

13 This same 9,300 acres is treated with non-herbicide methods under Alternatives 1-3, but mowing and other general 

non-herbicide right-of-way maintenance treatments would not be expected to remove noxious weeds completely. 

109 
 

 110 

14 An unquantified number of treatment acres are also devoted to actually reducing the perimeter or larger infestations 

from priority areas. Also, an estimated 440,000 acres of biocontrols are established on BLM lands in Oregon, affecting 

about 30 well-established noxious weed species. 

15 Such control strategies have been likened to controlling spot fires out in front of a wildfire to reduce its spread rate. 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Alternative 5 adds two additional herbicides and 5,000 acres of additional non-commodity vegetation treatments 

(primarily habitat improvement), but these are not expected to substantially increase the noxious weed control 

acres from those calculated for Alternative 4. 

Effects of Early Treatments 

The 1.2 million acres of noxious weed-infested BLM lands in Oregon are estimated to be spreading at a rate of 

12 percent, or 144,000 acres, each year (Appendix 7). This spread rate is assumed to be partly a function of, or in 

equilibrium with, the current (Alternative 2) level of weed control treatments. Therefore, differences in the level 

of effective treatments between Alternative 2 and the other alternatives can be expected to result in changes to the 

12 percent current annual rate of spread. 

Alternative 3 would effectively treat 18,860 more acres each year than Alternative 2 (from Table 4-3). At a 

minimum, these acres would directly reduce the 144,000-acre annual weed spread to 125,140 acres and thus the 

spread rate to 10.5 percent. However, because BLM weed treatments under all alternatives are only a portion 

of the 144,000-acre annual weed spread, weed treatments do not target the average acres. Typical treatments 

target new species, new or small populations of existing species, and advancing edges of larger populations in 

order to keep weeds from infesting new drainages and other geographic areas (containment)14. These treatments 

effectively keep populations from moving into the establishment phase where their spread rate becomes 

exponential, and thus the treatments reduce future infested acres many times more than is represented by the 

direct acres treated. Control efforts in the introduction and early establishment phase of an invasion (Figure 4-3) 

can prevent future infestations on tens to hundreds of times more acres than are actually controlled. 

A precise relationship between control at this point and future spread reduction depends upon the species and the 

situation. Stopping a typical noxious weed from entering Oregon would be expected to have hundreds of times 

the benefit of the actual treatment acres. Numerous examples exist of a few plants, or a few acres, becoming 

hundreds and thousands in 10 to 20 years (Radke and Davis 2000:25). More likely, the invasion would be slowed 

or kept out of certain areas for years or decades. Radosevich (2007) notes, for example, attempts to reduce the 

overall (regional) spread of a noxious weed species are usually more effective if control tactics are focused on 

satellite populations originating from large patches. Radosevich also reports that Cousens and Mortimer (1995) 

and Moody and Mack (1988) suggest that the preferred containment strategy would be to remove satellite 

populations as they occur, since these populations expand more rapidly and potentially cover greater area than 

the front of a source population15. Because of this relationship, it is estimated that each acre of effective annual 

control would translate to a reduction of at least 10 times that amount of infested acres at some year in the future 

(Appendix 7, Denton 2009). 

Table 4-3. ProjecTed 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 

1 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 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

 

111 

Table 4-4. ProjecTed annUal noxioUs Weed sPread raTes and acreage cHanges for eacH alTernaTive 

Alternatives Treatment 

Effectiveness 

Effectively 

treated acres 

% annual 

spread in 15 

years 

Change in annual spread 

(acres)1 

Total acres 

infested in 

15 years2 

15 yr acre change 

from No Action 

1 30% 12,630 14% +14,670 to +146,700 8,559,713 +2.7 million 

2 (No Action) 60% 27,300 12% 0 5,864,535 0 

3 80% 46,160 7% - 18,860 to -188,600 4,008,058 -1.9 million 

4 & 53 80%4 48,510 6% -21,210 to -212,100 3,689,048 -2.2 million 

1 The effect of a change in control rate from Alternative 2 takes 15 years to be realized. Change in spread is smallest in the first year, increasing by a factor of 10 in 15 years. 

2

 May be worst case. Actual invasion would be capped by biological saturation. 

3

 Because Alternative 5 adds additional herbicides, it is more likely to effectively control noxious weeds. The amount of this difference is not quantified but is unlikely to 

lower the annual spread rate a whole percentage point. 

4

 Plus the 2,350-acre inadvertent gain from treating roadsides, administrative sites, and so forth. 

Effects of the Alternatives on Spread Rate and Infested Acres in 15 Years 

There would be a lag time before seeing the 10 times reduction. The decrease in noxious weeds the first year 

would be no more than the 18,860-acre annual effective treatment acre difference between Alternatives 2 and 3. 

The complete 10 times (188,600 acres) reduction benefit would accrue gradually as those acres are, in effect, kept 

off the establishment part of the Invasion Curve (Figure 4-3). For this analysis, the benefit has been distributed 

over a 15-year period. That is, 100 acres of effective control treatments in 2010 are assumed to have reduced 

noxious weeds by a cumulative 1000 acres by 2025. Since treatments happen annually, they cumulatively 

would reduce weed spread so that the 18,860-acre annual program would be preventing 188,600 acres of annual 

infestation by year 15. By year 15 the annual spread rate would decrease to 7 percent and 1.9 million fewer acres 

would be infested with noxious weeds when compared to the No Action Alternative (Appendix 7). 

Using the same relationships for the other alternatives, the spread rate and acres infested at 15 years is estimated 

for all alternatives (Table 4-4). 

Assumptions and calculations are explained in more detail in Appendix 7, Part II. The above estimates do not 

reflect increases in infestation rates likely to result from climate change (See the Climate Change, Projections, 

and Implications section in this Chapter). While climate change would be expected to increase the weed spread 

rate under all alternatives, it would also tend to increase the differences between the alternatives. 

None of the alternatives in this EIS are predicted, by themselves, to achieve a “no net increase” in noxious weeds 

condition because, under current budget trends and priorities, many well established infestations such as yellow 

starthistle east of the Cascades, or blackberry west of the Cascades, are not being aggressively treated by the 

State, BLM, or others. 

Neighboring land owners and other cooperators (the State Department of Agriculture, Weed Boards, etc.) 

would be affected by implementation of any of the action alternatives in ways that could affect the weed spread 

rates calculated above. With additional herbicides available to the BLM, effective control covering entire 

geographically logical control areas would be available for more weed species. Adjacent landowners will be more 

effective at controlling species of weeds the BLM has been unable to treat under the No Action Alternative. State 

and private control dollars may go further if treatments are more uniformly applied and thus more effective. 

Changes in budget, program emphasis, efficiency, and other factors could affect these estimates, but those changes 

can only be assumed to affect each of the alternatives similarly, and thus not substantially affect the relative 

difference between the alternatives. 
 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Vegetation, Native Plants, and Plant 

Communities 

Affected Environment 

This section addresses desirable vegetation, primarily native vascular plants, nonvascular plants (e.g. mosses) as 

well as lichens, fungi, and desirable non-native plants. 

The Pacific Northwest is among the more diverse regions in North America in environment and vegetation. 

Natural vegetation types vary from dense coastal forests of towering conifers through woodland and savannah 

to shrub steppe (Franklin and Dyrness 1988). The present-day composition and distribution of native flora are 

influenced by many factors including physical (e.g. climate, wind, geology, topography, elevation, latitude, slope, 

exposure), natural disturbance (e.g. wildlife use, insects, disease, fire, flood), and human management patterns 

(e.g. cultivation, development, domestic livestock grazing, fire suppression). A brief introduction to the native 

plant communities in Oregon is provided in the Biomes section earlier in this Chapter. 

Vegetation Considerations by Biome 

Sagebrush Steppe: The sagebrush steppe ecosystem is considered to be one of the most imperiled of all 

ecosystems in the United States, with less than 10 percent retaining its historical structure and composition 

(Thompson 2007). Invasive plants lead to degradation, fragmentation, and loss of sagebrush communities. 

Invasive annual grasses, particularly cheatgrass (Bromus tectorum) are perhaps the greatest threat to sagebrush 

habitat in lower elevations (Thompson 2007). Native bunchgrasses and forbs have been replaced by cheatgrass on 

millions of acres in Oregon16, which in turn fuel wildland fires, killing native sagebrush, forbs and bunchgrasses 

that are not adapted to frequent intense fire. As cheatgrass and other invasive plant infestations increase, more 

native plant species are at risk of local or regional extirpation, as few sources of native seed are maintained. 

Another serious threat to native shrubs, forbs, bunchgrasses and habitats of the sagebrush steppe is the severalfold expansion of Western juniper (Juniperus occidentalis), a native species normally restricted by fire. Western 

juniper depletes soil moisture and prevents the growth of other plants. 

Eastern Forest Biome: Native plant communities in the Eastern Forest Biome have suffered reductions in 

biodiversity and forage production due to invasive plants. Some native bunch grasses, forbs, and shrubs in this 

biome have been replaced by noxious weeds and other invasive plants such as cheatgrass, medusahead rye, 

Mediterranean sage, Scotch thistle, and knapweeds. Nearly 100 percent of forest inventory plots in this type 

showed invasive annual grasses (Donnegan et al. 2008). Ponderosa pine forests are also being threatened by the 

unnatural expansion of Western juniper at lower elevations. Juniper invasion results in reduced shrub abundance 

and reduced ground water, and contributes to loss of riparian plant species (Bedell et al. 1993). 

East Side Riparian Biome: (See the Wetlands and Riparian Areas section in this Chapter). 

Siskiyou Biome: Influenced by both the Mediterranean climate of California and the strong marine influence 

of the Pacific Northwest, as well as a combination of soil types including large area of serpentine, the Siskiyou 

Biome is one of the most botanically diverse in North America (Stein et al. 2000). Approximately 2/3 of 

the known rare plants and fungi (97 species) in western Oregon occur in the Siskiyou biome. This botanical 

16 About 5 million acres on BLM lands east of the Cascades. 

 112 
 

 

 

 

 

 

 

 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

diversity was a major reason for the creation of the Cascade Siskiyou National Monument in 2000. Unique plant 

communities in the Siskiyou biome are threatened by starthistles, knapweeds, thistles, brooms, puncture vine, 

knotweeds, Dyers woad, leafy spurge, loosestrife, false brome, yellow flag iris, and Sudden Oak Death. 

Western Forest Biome: Dense shade producing forests are the least likely areas to provide opportunities for 

sun-loving invasive plants to establish (Quigley and Arbelbide 1997); however, the introduction of shade tolerant 

weeds, as well as openings associated with disturbances, have lead to threats to native plants in this biome. 

A recent forest inventory shows 47 percent of plots in the coast range and 68 percent of plots in the western 

Cascades (all ownerships) have invasive plants present, and 6.2 percent of all plant cover in forests is easily 

identifiable non-native weeds. The inventory sample plots indicate Himalayan blackberry is the most common 

invasive plant, covering 149,000 acres of forestland (Donnegan et al. 2008b). New openings can become infested 

before native succession can occur. Scotch broom has been shown to have the greatest documented economic 

impact to native plants in Oregon, by effectively reducing tree growth and forest production (Radke and Davis 

2000). Numerous other invasive plants impact the native species in this biome including plants that thrive in 

forests, such as English ivy, false brome, and garlic mustard. In addition to forests, the Western Forest Biome 

includes diverse habitats such as sand dunes, meadows, marshes, bogs, rock outcrops and woodlands, that support 

unique native plant communities and are threatened by invasive plants. 

Willamette Valley Biome: Most native vegetation of the Willamette Valley biome has been transformed by 

cultivation, timber harvest, development, and invasive plants. With only remnant populations of native plants 

remaining, many unique Willamette Valley plant communities are imperiled. These tracts tend to be fragmented 

and degraded by invasive plants. Hedgehog dogtail grass, medusahead and various thistles are examples of invasive 

plants that have replaced native species; however, Himalayan blackberry has consumed more acres than any other 

non-native species (Donnegan et al. 2008b). Loss of native plant communities in the Willamette Valley has lead to 

the Federal listing of Kincaid’s lupine, golden Indian paintbrush and Willamette valley daisy (USDI 2008c). 

Susceptibility of Plant Communities to Damage from Invasive Plants 

The susceptibility of native plant communities to invasion by non-native species is directly associated with the 

site capacity to support various plants, disturbances or stresses, the condition of the existing plant community, 

and the biological traits of the invader (Davis et al. 2000) as well as the potential for introduction of non-native 

seed or propagules. Potential Vegetation Types (PVT) are based primarily on soil qualities, climate, aspect, and 

historic plant species. The PVTs displayed here correlate strongly with the biomes (Table 4-5) and are adapted 

from the 2005 Pacific Northwest Region Invasive Plant Program EIS. That EIS used classifications developed by 

Forest Service Ecologist Jan Henderson west of the Cascades, and potential vegetation groups developed for the 

Interior Columbia Basin Ecosystem Management Project (ICBEMP; Quigley and Arbelbide 1997). 

A major conclusion of the ICBEMP analysis was that, in general, grasslands, riparian areas, and relatively 

dry, open forests are more susceptible to invasive plants than are dense moist forests, high montane areas, and 

serpentine areas. The former have frequent gaps in the plant cover which favor establishment of most invasive 

plants, whereas the latter have relatively closed plant cover or have extreme climate or soils, which are tolerated 

by fewer species (Quigley and Arbelbide 1997). 

Table 4-5 and Figure 4-4 provide a summary of potential vegetation types found on BLM lands in Oregon, and 

their expected susceptibility to invasion by invasive plants. 

113 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table 4-5. PoTenTial vegeTaTion TyPes 

Potential 

Vegetation Type Description (Biomes) 

Percentage of 

BLM Lands 

in Oregon 

Susceptibility to 

Invasive Rating1 

Agricultural Cropland/hay/pasture (East side of the Cascades) less than 1 High 

Alpine / Cold 

Forest 

Alpine shrub-herbaceous (Sagebrush Steppe). Mountain hemlock, Pacific 

silver fir, Shasta red fir, Subalpine fir, Lodgepole pine (in the Siskiyou), 

Western white pine (primarily in the Western Forest, but also in Eastern 

Forest and Sagebrush Steppe) 

less than 1 Low 

Cool Shrub 

Characterized by mountain big sagebrush and shrubs, grasses, forbs, and 

sedges. It is limited by moisture availability due to low rainfall and/or 

shallow soils (primarily in Sagebrush Steppe. Also appears in Eastern 

Forest) 

11.2 High 

Dry Grass 

Includes native grasslands, seeded grasslands, and cropland hay pasture. 

Characterized by bunchgrasses (primarily in Sagebrush Steppe. Also appears 

in Eastern Forest) 

1.2 High 

Dry Shrub Dominated by sagebrush but bunchgrass/forbs present. At lower elevations 

than cool shrub (Sagebrush Steppe) 66 High 

East Side Dry 

Forest Douglas-fir, Ponderosa pine, Lodgepole pine (East side of the Cascades) 3.6 Moderate to High 

East Side Moist 

Forest 

Vegetation includes transitional areas between drier, lower elevation forest, 

woodland types, and higher elevation forest types in cold forests. The 

dominant overstory species found in this group include grand fir, Douglasfir, cedar, and hemlock. (Primarily in Eastern Forest. Also appears in 

Sagebrush Steppe) 

less than 1 Moderate to High 

East Side Riparian 

Shrub: mountain riparian low shrub, saltbrush riparian, willow, alder, sedge. 

Woodland: Cottonwood with willow, ponderosa pine, Douglas-fir, aspen. On 

many sites, the non-native species have become well established, commonly 

replacing native species or exerting large influences on the functional 

dynamics of existing habitats. The linear nature of the riparian corridor 

makes it highly susceptible to invasion. (East Side Riparian) 

1 High 

Serpentine Forest: Jeffrey pine, Western white pine, Port Orford Cedar. Non-Forest: 

Serpentine barrens and fens (Siskiyou) less than 1 Low 

Westside Dry 

Forest 

Similar to East Side Dry Forest. Douglas-fir, Ponderosa pine, Oregon white 

oak (Siskiyou and Western Forest) 6 High 

Westside Moist 

Forest White/Grand fir, Tanoak (Siskiyou and Western Forests) 1.9 Low 

Wet Forest Western hemlock, Sitka spruce (Western Forest) 6 Low 

Woodland 

Dominated by juniper. These sites generally have low water availability due 

to shallow soils (primarily in Sagebrush Steppe. Also appears in Eastern 

Forest) 

less than 1 Moderate to High 

Total 

100% or 

15,734,988 

acres 

1

 High = high susceptibility to invasion. Invasive plant species invades the cover type successfully and becomes dominant or co-dominant even in the 

absence of intense or frequent disturbance. 

Moderate = moderate susceptibility to invasion. Invasive plant species is a “colonizer’ that invades the cover type successfully following high intensity 

fires or frequent disturbance that impacts the soil surface or removes the normal canopy. 

Low = low susceptibility to invasion. Invasive weed species are less likely to establish because the cover type does not provide suitable habitat. 

 114 
figUre 4-4. PoTenTial vegeTaTion TyPes 

115 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Endangered, Threatened, and Bureau Sensitive Plant Species 

Species designated as Bureau Sensitive by the BLM include 1) those listed or proposed for listing as endangered 

or threatened under the Federal Endangered Species Act (ESA), and 2) species requiring special management 

consideration to promote their conservation and reduce the likelihood and need for future listing under the ESA. 

These are managed under provisions of the BLM’s Special Status Species Program (USDI 2008d). BLM policy 

objectives are: 1) to conserve and or recover Federally Listed species and the ecosystems on which they depend 

so that ESA protections are no longer needed for these species, and 2) to initiate proactive conservation measures 

that reduce or eliminate threats to Bureau Sensitive species to minimize the likelihood of and need for listing of 

these species under the ESA. BLM management activities must be conducted to minimize or eliminate threats 

affecting the status of the species or to improve the condition of the species’ habitat by ensuring that activities are 

carried out in a way that does not lead to a need to list the species under the ESA. Potentially habitat-disturbing 

projects require pre-project clearances for special status plants. Clearances can include proposed project review 

for potential habitat and/or project site surveys. 

The Oregon BLM Special Status Species list (January 2008) includes 483 vascular plants, 44 fungi, 26 lichens 

and 43 bryophytes (Appendix 5). Of these, 17 species of vascular plants are Federally Listed under the ESA as 

“threatened” or “endangered,” and require formal consultation with the FWS if proposals are likely to adversely 

affect the species. Appendix 5 includes information from the PEIS Biological Assessment for 16 of these 17 

species, as well as a list of the Bureau Sensitive Species. The summary of the 17th species, Golden paintbrush, 

was added for this analysis. 

Environmental Consequences 

The five alternatives are predicted to result in various levels of effects to desirable non-target (native and nonnative) plant species and plant communities. Those effects are presented in this section in the following three 

distinct categories: 

•		 Effects of herbicides on non-target plants - Non-target native plants can be adversely affected by 

herbicides directed at nearby invasive plants and other target vegetation.
 

•		 Effects of invasive plants on native plants - Native plants are adversely affected by infestations of invasive 

plants. The degree to which the alternatives slow the spread of invasive plants has a corresponding and 

generally proportionate beneficial effect on the retention of functional native plant communities. 

•		 Effects of non-herbicide treatments on non-target plants - Desirable or non-target native plants can be 

adversely affected by non-herbicide treatment methods directed at nearby invasive plants and other target 

vegetation. 

Effects Common to All Alternatives 

Effects of Herbicides on Non-Target Plants 

Herbicides have the potential to harm non-target plants, including plants that are culturally important and 

Federally Listed or Bureau Sensitive. Some damage to native plant species from herbicide application is probable 

despite cautious planning and implementation. Herbicide impacts to native plants depend on (but are not limited 

to) the herbicide used, its selectivity, application rate, concentration, relative toxicity to the plants in the treatment 

area, likelihood of exposure, timing and method of application, environmental conditions during application and 

plant stage of growth. Herbicides treatments impact non-target plants through direct application, overspray, off­

 116 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

site movement and/or accidental spills. Potential impacts include mortality, reduced productivity, and abnormal 

growth. Risk to off-site plants from spray drift is greater under scenarios with application from greater heights 

(i.e., aerial application) or when air temperature or movement is high. Risk to off-site plants from surface runoff 

and movement through soil (leaching) is influenced by precipitation rate and timing, soil type, and application 

area. Measures taken to limit exposure, such as selective application methods (e.g. spot spraying, or wiping), 

typical application rates-that are less than the maximum allowed on the label (Appendix 9), drift reduction agents, 

and application restrictions based on environmental conditions (wind, precipitation, temperature, etc.), reduce the 

off-target movement of herbicides. SOPs and PEIS Mitigation Measures are designed to minimize risk to nontarget species. 

Site specific project design can minimize risks to non-target plants. Design considerations include the abundance 

and distribution of invasive and native plant species, stage of growth (phenology) of plants, and the size of 

the treatment area, as well as physical features like soil moisture, presence of special status plants, timing of 

precipitation, air temperature, wind speed, and other factors. 

Certain herbicides target specific types of plants (Table 3-1), so collateral damage to non-target plants will depend 

upon their sensitivity to that herbicide. For example, dicamba targets broadleaf plants, so damage to grasses 

would not be expected during normal use. Tables 3-12 and 3-13, the risk assessments (Appendix 8), and the 

following section summarize the potential effects to plants by active ingredient. The herbicides are grouped by 

their mode of action. 

Federally Listed species as well as those designated Bureau Sensitive are more at risk from herbicides because 

their populations may be limited in geographic scope, and thus damage to individual may have population 

implications. Although the ecological risk assessment vegetation risk ratings, Tables 3-12 and 3-13, apply equally 

to all vegetation and thus do not display this increased risk, PEIS Mitigation Measures (Appendix 2) provide 

for wider buffers for Federally Listed and Bureau Sensitive species. This coupled with required clearances 

for potentially occupied habitat would make herbicide risk to Federally Listed and Bureau Sensitive species 

negligible. 

In any event, herbicides are designed to kill plants, so they will kill non-target plants if they contact them. The 

following section discussed the relative risks from drift and other avenues for contact with non-target plants17. 

Mortality or damage from such contact can be assumed. 

ALS-Inhibitors - Chlorsulfuron, metsulfuron methyl, sulfometuron methyl, imazapic, and imazapyr work by 

inhibiting the activity of an enzyme called acetolactate synthase (ALS), which is necessary for plant growth. 

These five herbicides are effective at low dosages. In some circumstances, an effective dose of this herbicides 

could be more easily moved by drift or water runoff , and could damage non-target species more readily than the 

other groups of herbicides proposed. 

Synthetic auxins - Picloram, clopyralid, triclopyr, 2,4-D, and dicamba mimic naturally occurring plant hormones 

called auxins. They kill plants by destroying tissue through uncontrolled cell division and abnormal growth. 

In the Pesticide Re-registration Fact Sheet–Picloram (1995), the EPA noted that picloram poses very substantial 

risks to non-target (broadleaf and woody) plants. The EPA also noted that picloram is highly soluble in water, 

resistant to biotic and abiotic degradation processes, and mobile under both laboratory and field conditions. 

17 However, most of the risk is within the plant group that the herbicide is effective against (e.g. broadleaf, grasses, etc. 

See Table 3-1) 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

They stated that there is a high potential to leach to groundwater in coarse textured soils with low organic 

material. Plant damage could occur from drift, runoff, and off-site where ground water is used for irrigation 

or is discharged into surface water (EPA 1995). The contribution from irrigation is considered inconsequential 

relative to off-site drift and runoff (SERA 2003b). Labeling restrictions resulting from these findings were 

implemented to reduce effects. 

Because picloram persists in soil, non-target plant roots can take up picloram (Tu et al. 2001) and could affect 

revegetation efforts. Lym et al. (1998) recommended that livestock not be transferred from treated grass areas 

onto susceptible broadleaf crop areas for 12 months or until picloram has disappeared from the soil without 

first allowing seven days of grazing on an untreated green pasture. Otherwise, cattle urine may contain enough 

picloram to injure susceptible plants. To a lesser degree, this can occur with other active ingredients such as 2,4­

D, glyphosate and imazapic. 

Clopyralid is more selective and less persistent than picloram. Clopyralid is relatively non-toxic to aquatic 

plants; however, accidental spills may result in temporary growth inhibition of aquatic plants. As with picloram, 

clopyralid has little effect on grasses and members of the mustard family. Overall effects to non-target plants 

from normal application of clopyralid are likely to be limited to susceptible plant species in or very near the 

treatment area. 

Triclopyr is a selective systemic herbicide. It is used on broadleaf and woody species. It is commonly used 

against woody species in natural areas (Tu et al. 2001). Susceptible species could be impacted by drift from 100 

feet (typical BLM application rate) to 1000 feet (maximum BLM application rate) (SERA 2003c). 

Two forms of triclopyr could be used with differing degrees of effects. Triclopyr BEE (butoxyethyl ester) is more 

toxic to plants than triclopyr TEA (triethylamine salt). The triclopyr BEE form is more apt to damage plants from 

runoff than other forms (SERA 2003c). Both forms have been found to decrease the relative long-term abundance 

and diversity of lichens and bryophytes. Newmaster et al. (1999) stated that drift from triclopyr could affect the 

sustainability of populations of lichens and bryophytes, where these ingredients reduced abundance. Typical 

application rates in aerial spraying were found to reduce abundance by 75 percent, variable by species. Colonists 

and drought-tolerant species were more resistant than the mesophytic forest species, which means that aerial 

applications of triclopyr could essentially push back the successional stage on non-vascular communities. 

Triclopyr BEE was found to inhibit growth of three types of ectomychorrhizal fungi associated with conifer 

roots at concentrations of 1,000 parts per million in laboratory experiments (Estok et al. 1989). Busse et al. 

(2003) found no inhibition of ectomychorrhizal formation in a laboratory experiment using this active ingredient. 

Newmaster et al. (1999) reported that moss and lichen abundance and richness were not or nearly not affected at 

six months, one year, or two years after treatment except when very high rates of triclopyr were used. 

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 could be more susceptible. One study determined that 2,4-D could affect three 

species of ectomychorrhizal fungi in laboratory experiments (Estok et al. 1989). 

Dicamba is a selective, systemic herbicide that can affect some annual, biennial, perennial broadleaf and woody 

species as well as annual grasses. Some tolerant plants directly sprayed at typical application rates are likely to 

be damaged. The greatest risks are associated with runoff, but are highly site specific. Wind erosion may cause 

impacts in arid regions (SERA 2004g). Drift may cause damage to susceptible species at distances less than 100 

 118 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

feet from the application site. Vaporized or volatilized dicamba can affect non-target plants. Vaporization does 

affect vegetation, but much more study in air concentration-duration relationships needs to be done to quantify 

the level of effects. Vaporization potential will be dependent on atmospheric stability and temperature. Dicamba 

vapor has been known to drift for several miles following application at high temperatures (Cox 1994). 

Photosystem Inhibitors - Bromacil, diuron, diquat, hexazinone, and tebuthiuron kill target plants by disrupting 

photosynthesis. Bromacil and diuron are non-selective, broad-spectrum systemic herbicides, which are lethal to 

all plants. Both pose a high risk to non-target species in the immediate vicinity of the treatment area. 

Hexazinone has differential toxicity to plants and is effective against woody species. It is primarily absorbed 

through the roots of the plant. 

Tebuthiuron is relatively non-selective against broadleaf plants, woody plants, and grasses. Tebuthiuron can be 

selective at low rates of application where it is used to thin sagebrush stands allowing more herbaceous species 

to thrive in the interspaces. Only the highest application rates of tebuthiuron produced an effect on non-target 

mychorrhizal fungi but there was no measurable effect of any level of tebuthiuron on germination of spores 

collected after six months (Allen and West 1993). 

Diquat will be used by BLM only on aquatic weeds. It kills the plant parts that it comes in contact with, but does 

not kill the roots, so it is effective only for single season control. It is non-selective and is used in water sources 

where few native aquatic plants are present. 

EPSP Synthase Inhibitors - Glyphosate prevents plants from synthesizing three aromatic amino acids including 

a key enzyme, EPSP (5-enolpyruvylshikimate-3-phosphate). Glyphosate is a non-selective, systemic herbicide 

that can damage all groups or families of non-target plants to varying degrees, most commonly from off-site drift. 

Plants susceptible to glyphosate can be damaged by drift up to 100 feet from the application site at the highest rate 

of application proposed. Species that are more tolerant are likely to be damaged at distances up to 25 feet (SERA 

2003a). Non-target species are not likely to be affected by runoff or absorption from soil. Glyphosate strongly 

adsorbs to soil particles, which prevents it from being taken up from the soil by plant roots (Tu et al. 2001, SERA 

2003a). 

Field studies conducted using glyphosate found no effects to plant diversity in an 11-year study on site preparation 

using herbicides, though the structural composition and perennial species presence were changed (Miller et al. 

1999). Newmaster et al. (1999) reported that moss and lichen abundance and richness were not or nearly not 

affected at six months, one year, or two years after treatment except when very high rates of glyphosate and 

triclopyr were used. 

Glyphosate was found to inhibit growth of three types of ectomychorrhizal fungi associated with conifer roots 

at concentrations of 1,000 parts per million in laboratory experiments (Estok et al. 1989). Houston et al. (1998) 

documented responses of below-ground fungal community structure (richness, diversity, composition) were 

similar in untreated and treated (with glyphosate and triclopyr) stands although total fungal abundance was not 

changed, isolation frequencies (the abundance measure used) in organic soil of two fungal species decreased when 

samples were collected two years after herbicide treatments. 

Carotene Inhibitor - Fluridone, an aquatic herbicide, kills target plants by preventing them from synthesizing 

food; however, at low concentrations native pondweeds may escape harm (Farone and McNabb 1993). It is used 

primarily to control Eurasian water milfoil (present in Oregon) and hydrilla, (which is not yet known in Oregon 

but present in surrounding states). Fluridone must remain in contact with target aquatic species for an extended 

119 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

period of time for effective control and poses only low risk from a spill at maximum application rate to plants in 

a pond. Risks to terrestrial plants could not be evaluated due to lack of toxicity testing. Off-site deposition rates 

suggest that small amounts of the herbicide would drift offsite potentially affecting terrestrial plants. 

Auxin transport inhibitor - Diflufenzopyr, acts by disrupting the delicate auxin balance needed for plant growth. 

It is selective for annual broadleaf weeds and suppression of annual grasses and perennial broadleaf weeds. 

Although diflufenzopyr is a weak herbicide, when formulated with dicamba, it can reduce the amount of herbicide 

needed from 1-4 pounds per acre of dicamba alone to .26-.35 pounds per acre of diflufenzopyr + dicamba. 

Effects of Invasive Plants on Native Plants 

Native plant communities are in dynamic balance, where plants, animals, and organisms keep each other in check. 

Each plant is part of a complex food chain; break one of the links and others are likely to be adversely affected. 

One disappearing plant can take with it up to thirty other species that depend on it, including insects, higher 

animals and even other plants (Wood 1996). Non-native plants are typically introduced into these ecosystems 

without the plants, animals, and diseases they evolved with, giving them a competitive advantage. The resulting 

invasion displaces native plants, adversely affecting the composition and structure of the plant community and 

thus the other elements of the ecosystem dependent upon it. Adverse effects begin gradually and are often well 

underway by the time the effects become apparent or significant. At that point, restoration is expensive and often 

not possible because of the loss of the supporting ecosystem components such as soil depth and water table. Once 

a threshold is exceeded, permanent loss of historical plant association and the organisms that depend on them 

occurs (Appendix 7). The impact of invasive plants 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). The fewer invasive 

plants present, the more likely it is that restoration is possible. 

Society is dependent upon native ecosystems. The ability of Oregon’s landscapes to produce goods and services 

including clean water and air is dependent upon the healthy functioning of Oregon’s native plants and ecosystems. 

Noxious weeds have infested 1.2 million acres of native ecosystems on BLM lands in Oregon, and other invasive 

plants, notably cheatgrass, have infested 5 million more, eliminating or substantially reducing the natural function 

and productivity of those lands for the foreseeable future. 

Remaining native ecosystems are currently stressed by increasing demand for goods and services, heavy visitor 

use, human development, altered fire regimes and increased fire intensities, climate shifts, and the rapid spread 

of invasive plants. Changes are happening far more rapidly than at any previous time in the earth’s history. 

Environmental changes are happening far more rapidly than at any previous time in the earth’s history. Exotic 

[non-native] plants were rated as one of the six primary elements of global change (Vitousek et al. 1997). 

Noxious weed infestations are expanding and are estimated to be infesting 144,000 additional acres each year on 

BLM lands in Oregon. 

Many invasive plants modify invaded sites, so that the site becomes inhospitable to the original plant community. 

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. Knapweeds and starthistles are known to increase sheet erosion 

and produce chemicals that prevent other species from germinating (Boersma et al. 2006). Reed canarygrass 

decreases species’ diversity, and reduces the structural complexity of the plant community through its aggressive, 

rapid growth and ability to eliminate safe sites for the establishment of native plants (Hovick and Reinartz 2007). 

Grasses in particular can limit the establishment and growth of woody species (D’Antonio and Vitousek 1992). 

Grass invasions prevent the re-establishment of forests following abandonment of agricultural and pastoral land 

(D’Antonio and Vitousek 1992). 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Most invasive plants are known for forming monocultures, but even where invasive plants do not ultimately 

dominate plant communities, they can adversely influence succession. For example, Scotch broom initially 

forms a dense canopy on harvested forest sites, shading out regenerating conifers and other plants. As the broom 

ages and the canopy opens, there is a partial recovery of ground cover, though not by all pre-existing species 

(Smith 1994). Shade tolerant Himalayan blackberry germinates under dense Scotch broom plants and frequently 

becomes dominant on those sites. Blackberry fruit is a seasonal food source for introduced starlings and rats and 

the vines shelter them from predation. Even after the blackberries overtake the Scotch broom, long-lived scotch 

broom seed remains viable for decades, ready to respond to future disturbances. 

Natural disturbances are important to ecosystem renewal, and invasive plants alter historic disturbance regimes. 

Many plant communities are adapted to fire cycles, with fires maintaining the full range of successional stages, 

species, and habitats. Invasive plants can interfere with this process by changing curing and then burning earlier 

in the season, burning more often, and burning hotter. They also directly competing with the various native plant 

seedlings that would have naturally followed the disturbance. Similarly, landslides, high flows, and stream bank 

erosion are natural processes that shape stream courses and deposit large wood in streams. When invasive plants 

prevent native plants from repopulating these disturbed sites, accelerated erosion and watershed degradation is the 

result. Even in old-growth forests where the most common natural disturbance pattern is the small gaps created as 

individual large trees die or fall, invasive plants are interfering with the reestablishment of the native hardwoods 

and conifers important to maintaining the multi-layered structure of these stands (Hobbs and Huenneke 1992.). 

Flying squirrels and other spotted owl prey species, for example, rely on the cover provided by this intermediate 

crown layer to reach and utilize the upper forest crown layer; prey species and owl numbers decrease when this 

layer is not present. This natural process is threatened by noxious weeds such as tansy ragwort, thistles, and rush 

skeletonweed, which can be spread great distances by wind, even in forestlands. Weed seeds are also carried by 

water and wildlife (Asher and Spurrier 1998). 

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. Also, desirable plants including crops on 

adjacent lands can suffer irreparable damage when uncontrolled invasive plants from BLM lands move across 

property lines. Private ranches east of the Cascades have been abandoned after native forage and croplands were 

taken over by invasive plants, and tens of thousands of dollars of effort have not been able to restore them (Asher 

and Spurrier 1998). 

Bureau Sensitive and Federally Listed species are particularly at risk from noxious weeds and other invasive 

plants. Rare species generally display narrow ecological amplitudes, keeping them geographically restricted and 

unable to compete over a wide range of site conditions. When invasive plants invade those sites, fragmentation 

of populations and extirpation often result. Although the protection of sites known to be occupied by Bureau 

Sensitive and Federally Listed is a priority for BLM weed control efforts, success of those efforts will vary 

depending upon the likelihood of those sites being invaded and whether effective weed control tools are available. 

The degree to which these effects apply to the various alternatives is primarily a function of, and directly 

proportional to, the number of acres that will become infested with weeds under each alternative. Adverse effects 

caused by weeds currently apply to the 1.2 million acres of BLM lands in Oregon currently infested with noxious 

weeds, and to more than 5 million acres infested with other invasive weeds – primarily cheatgrass. As described 

in the Noxious Weeds and Other Invasive Plants section in this Chapter, the various alternatives are predicted to 

affect the spread rate of noxious weeds and thus the acres projected to be infested in 15 years (Table 4-6). These 

projections are designed to show the relative difference between the alternatives in this EIS, and may not apply if 

funding levels or other factors change from current levels. 

121 
 

 

 122 

18 This discussion does not include the prescribed fire used on tens of thousands of acres per year to manage fuels and 

native vegetation levels. Some prescribed fires can have both objectives however, such as the spray, prescribed fire, and 

restoration scenario planned for several thousand acres per year on cheatgrass and medusahead to reduce fire hazard in 

the Wildland-Urban Interface under Alternatives 3-5 using imazapic. 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table 4-6. ProjecTed noxioUs Weed sPread raTes and 15-year infesTed acres for eacH alTernaTive1. 

Alternatives 

% annual spread of 

noxious weeds in 15 

years 

Total acres noxious 

weeds in 15 years2 

Acreage difference 

from No Action 

Proportion of BLM 

lands infested in 15 

years 

1 14% 8,559,713 2.7 million more 1/2 

2 (No Action) 12% 5,864,535 0 1/3 

3 7% 4,008,058 1.9 million less 1/4 

4 & 53 6% 3,689,048 2.1 million less 1/5-1/4 

1

 Noxious weeds currently infest 1.2 million acres of BLM lands in Oregon. 

2

 Calculated from spread rate; does not reflect the potential for biological saturation. 

3 Because Alternative 5 adds additional herbicides, it is more likely to effectively control noxious weeds. The amount of this difference is not quantified but 

is unlikely to lower the annual spread rate a whole percentage point. 

Effects of Non-Herbicide Treatments on Non-Target Plants 

Under each alternative, half or more of the invasive plant treatments are projected to be done without herbicides. 

These treatments can have less risk to non-target plants and provide effective control for about 1/3 of the noxious 

weeds in Oregon. However, non-herbicide treatments have their own set of potential environmental effects. The 

extent to which non-herbicide treatment methods directly affect native plants varies by the amount and method of 

treatment as well as the treatment timing, site conditions, and relative abundance of plants present. Minimizing 

impacts to native plants allows them to recapture the site more quickly and reduces the need for additional weed 

control treatments. 

Manual treatments tend to be selective and result in minimal damage to native plants including minor trampling, 

breakage and occasional mortality to individuals, as well as light soil disturbance that could increase the 

germination of any seeds present. Manual treatments are labor intensive and usually only practical on small areas. 

Mechanical treatments involving chainsaws or similar hand operated equipment can be focused on target plants, 

thus having similar effects as manual treatment. Mechanical treatments like mowing are typically non-selective, 

and remove or damage target and non-target plants alike. Mechanical treatments have limited use for noxious 

weed control, unless coupled with other treatments. Machinery can disturb vegetation and soil, prepare seedbeds, 

spread seeds, and increase sprouting and reproduction from root fragments. Mechanical treatments (and other 

ground-disturbing treatment such as directed livestock) can break up soils crusts. As discussed in more detail in 

the Soil Resources section in this Chapter, biological crusts provide several important functions within, and on, 

the surface of soil in arid and semiarid environments such as the Sagebrush Steppe and Eastern Forest Biomes. 

The major components of the crust are cyanobacteria, green algae, microfungi, mosses, liverworts, and lichens. 

Disturbance of crusts can come about through trampling, fire, or burial by windblown soil. 

Prescribed Fire is normally used for weed control only on heavily infested sites, because most invasive plants 

are adapted to fire and readily invade disturbed sites. Prescribed fire for weed control18 can be most effective if 

followed by herbicide treatments of new weed germinates, seeding of native species is usually required. Native 

species adapted to fire may remain, and the selection of a follow-up herbicide would be designed to minimize 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

damage to remaining native plants where possible. Adverse effects to native plants include injury, mortality, 

nutrient flush or loss of nutrients, reduced shading, and potential increases of invasive plants. 

Directed livestock grazing can effectively reduce the vigor and seed production of invasive weeds, but is not 

likely to supply long-term control. Multiple treatments from directed livestock may increase risks to native plants 

by reducing vigor and seed production of non-target species and the ground disturbance can increase the potential 

for reinvasion and damage soil crusts. Alternately, disturbance from directed grazing could provide positive 

benefits by preparing a seedbed for seeding competitive native species. 

Seeding or Planting is used to restore native vegetation or introduce desirable vegetation. The effect of these 

treatments varies from simply adding seed via aerial broadcast to destruction of existing vegetation. Typically, 

a rangeland drill is used to seed, with only minor damage to existing plants. Successful revegetation can be 

difficult on rangelands due to arid and semiarid conditions, and minimal seedbed preparation leading to increased 

competition. Native seed collected on site protects the genetic integrity of local alleles. Native seed from other 

locations could alter locally evolved adaptations; however, non-native seed may be used following NEPA analysis 

that documents the need for other than native seed (USDI 1992a), primarily to protect the soil resource and 

subsequent site potential. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

Effects of Invasive Plants on Native Plants: 

In general, the loss of native plants, and the goods and services they provide, would be proportional to the acres 

projected to become infested under this alternative. Under Alternative 1, the rate of spread of noxious weeds is 

projected to increase to 14 percent annually (up from the current 12 percent), and noxious weeds are projected to 

occupy approximately 1/2 of all BLM lands in Oregon within 15 years (Table 4-6). These numbers do not include 

the current five million acres infested with other invasive plants that would continue to spread at an increased 

rate under this alternative as well. Approximately 2/3 of the noxious weeds in Oregon cannot be effectively 

controlled with non-herbicide methods (Appendix 7: Table A7-1); therefore, native ecosystems being invaded by 

those species would suffer a higher level of infestation and resultant adverse effects than under alternatives with 

herbicide use. For example, aggressive, non-native grasses like medusahead, cheatgrass and hedgehog dogtail 

would continue to invade imperiled sagebrush and oak woodlands in the Sagebrush Steppe, Willamette Valley, 

and Siskiyou Biomes relatively unchecked, because effective treatments are not available under this alternative. 

Similarly, the Warner Wetlands and numerous riparian areas would continue to be over-run by perennial 

pepperweed, whitetop and saltcedar as effective treatments are unavailable. Japanese knotweed, Himalayan 

blackberry, and non-native grasses would continue to invade and degrade riparian areas and susceptible habitats 

like the West Eugene Wetlands. Threatened, Endangered, and Bureau Sensitive species would be particularly at 

risk because of the BLM’s inability to effectively respond to specific weed threats. 

Effect of Non-Herbicide Treatments on Non-Target Native Plants: 

Non-herbicide methods for the control of invasive plants are highest under this alternative, 42,100 acres versus 

28,800 under the No Action Alternative, as districts replace 85 percent of the Alternative 2 herbicide acres with 

non-herbicide methods. Four thousand acres of this increase would be direct seeding. Seeding with native 

species is expected to have minimal negative effect on native plant communities; however, any use of persistent 

non-native seed would likely result in permanent loss of native species in seeded areas.19 In the absence of 

19 Positive effects of direct seeding and other treatments are discussed in the previous section, Effects of Non-Herbicide 

Treatments on Non-Target Plants. 

123 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

herbicides for weed control, districts east of the Cascades would increase the use of directed livestock grazing 

by 6,000 acres over current levels controlling weeds but causing some collateral damage to native plants. 

Mechanical and manual treatment methods would also increase, 1,600 and 1,300 acres per year (59 and 46 

percent) respectively, compared to the No Action Alternative, increasing short-term damage to, and loss of, nontarget plants, especially with non-selective mechanical methods. 

The potential adverse effects of prescribed fire for weed control (e.g. loss of non-target species, site disturbance) 

would be reduced under this alternative, as the use of this method decreases 2,000 acres per year because most 

follow-up herbicides would not be available. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Effects of Herbicides on Non-Target Native Plants: 

The four herbicides available under this alternative have risks to non-target plants (Tables 3-12 and 3-13). 

Treatments to slow the spread of noxious weeds would hamper restoration of habitats if non-target plants were 

seriously damaged or destroyed. However, treatments using selective herbicides would typically have little 

risk of harming non-target plant types than non-selective herbicides. Most applications would be spot spraying 

to directly target the noxious weed plants. Since herbicide use in this alternative is limited to noxious weeds, 

broadcast applications would be limited to expanses (monocultures) of noxious weeds. Other invasive plants, like 

cheatgrass, would not be controlled with herbicides. 

Effects of Invasive Plants on Native Plants: 

In general, the loss of native plants would increase proportional to the acres projected to become infested. 

Under Alternative 2, noxious weeds are projected to continue spreading at a rate of 12 percent annually, and 

approximately 1/3 of all BLM lands in Oregon are projected to be infested within 15 years (Table 4-6). This 

does not include the current five million acres infested with other invasive plants that would continue to spread 

under this alternative. These averages would apply to most but not all plant communities. About a dozen noxious 

weeds cannot be effectively controlled with the four herbicides or the non-herbicide methods available under 

this alternative, and herbicides cannot be used on invasive plants such as cheatgrass. Most significantly, perhaps, 

the noxious weeds and other invasive annual grasses medusahead and cheatgrass would continue to spread 

unchecked, converting additional remnant sagebrush steppe, oak savannah, and other dry habitats to annual grass 

monocultures. These monocultures increase the fire hazard in many Wildland-Urban Interfaces. Restoration 

treatments of susceptible wetlands and riparian habitats are also hampered, as the four herbicides available under 

this alternative are not very effective at controlling saltcedar, watermilfoil, hydrilla, perennial pepperweed, and 

other noxious weeds occurring in these areas. Native plant communities infested with these species will suffer 

loss of native species and alteration of community function in the long term almost regardless of the level of effort 

or priority given to their conservation. Habitats of Federally Listed and Bureau Sensitive species (Appendix 5) 

would be particularly at risk from these invading non-native species because of their limited geographic range and 

narrow ecological amplitude. 

Effect of Non-Herbicide Treatments on Non-Target Native Plants: 

Effects would remain essentially unchanged from current levels, and would be as described under effects common 

to all alternatives. Treatment methods creating soil disturbance and likely to result in some mortality among 

native plants include 6,100 acres of prescribed fire, 2,800 acres of directed livestock, 3,500 acres of mechanical 

treatments (including chainsaws), 2,200 acres of manual treatments, and seeding if it relies on non-native seed. 

Since non-herbicide methods are often implemented where herbicide damage to adjacent plants or other resource 

values would be unacceptable (e.g. Bureau Sensitive plants), it is likely that collateral mechanical damage to those 

same resources from non-herbicide treatment methods would be more significant than the same level of damage 

 124 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

in an average landscape. Such effects would be unavoidable, and would be balanced with the benefits of weed 

control during NEPA analysis at the project-specific level. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Effects of Herbicides on Non-Target Native Plants: 

Herbicides would be used to control noxious weeds, invasive plants, and native plant hosts to control pests and 

diseases such as Sudden Oak Death. An additional 13,600 acres would be treated over Alternative 2, which 

includes 11,000 acres of imazapic east of the Cascades that would be used to control monocultures of invasive 

annual grasses. Imazapic has a low-to-medium risk of harming non-target plants (Table 3-12), and would be used 

in areas with little-to-no non-target plants. Acres of 2,4-D, picloram, glyphosate, and dicamba would decrease 

under this alternative compared to Alternative 2 (Table 3-3), and the additional 7 herbicides west of the Cascades 

and 9 herbicides east of the Cascades are mostly selective herbicides that would allow for more target-specific 

treatments, decreasing the risk to non-target plant types. 

Effects of Invasive Plants on Native Plants: 

In general, the loss of native plants would be proportional to the acres projected to become infested. Under 

Alternative 3, the rate of spread of noxious weeds is projected to decrease to 7 percent annually (down from the 

current 12 percent), infesting approximately 1/4 of all BLM lands in Oregon in 15 years (Table 4-6). This does 

not include the five million acres currently infested with other invasive plants that would continue to spread 

(presumably at a slightly decreased rate) under this alternative. These averages would apply to most plant 

communities, since herbicides to effectively target nearly all noxious weeds in Oregon would be available. 

With the ability to effectively control almost all noxious weeds and other invasive plants would come the ability 

to more consistently protect native plant communities in specific geographic areas such as traditional food 

gathering areas or around Federally Listed and Bureau Sensitive species. The herbicides available under this 

alternative would also make cooperative projects with adjacent landowners more feasible, resulting in better 

protection for Federally Listed and Bureau Sensitive plant communities both on and off BLM lands. 

Effect of Non-Herbicide Treatments on Non-Target Native Plants: 

The methods and acreage of non-herbicide invasive plant control treatments is similar to Alternative 2 except for a 

projected 7,000 acre increase in prescribed fire and corresponding 5,000 acre increase in seeding or planting, both 

related to the availability of imazapic for the control of medusahead rye, cheatgrass, and other invasive annual 

grasses. With imazapic, it becomes practical to restore medusahead-infested sites primarily in the Sagebrush 

Steppe Biome by burning, spraying, and seeding. One objective of some of these treatments will be to reduce 

the annual grass fire hazard adjacent to communities and other developments. Any increase in negative effects to 

non-target species (from Alternative 2) would be related to this 7,000-acre increase in burning. The combination 

of treatments would reduce the survival of native herbaceous and woody species that were not adapted to fire. 

Remnant perennial bunchgrasses and forbs would likely survive burning and spraying, benefiting from reduced 

competition and the increase in available nutrients. Additional restoration would rely on the success of seeded 

species. Sites would generally only be worse off if the seeding fails. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Effects of Herbicides on Non-Target Native Plants: 

Under Alternative 4, an additional 14,800 acres of herbicide treatments would occur when compared to 

Alternative 3. Nearly two-thirds of these additional treatments would be to treat native vegetation in rights-of125 
 

 

 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

way, administrative sites, and recreation sites. In rights-of-way, treatment is more likely to be done by boom 

spray (or similar broadcast method) rather than applying herbicides to individual plants. The risk to non-target 

native plants from direct herbicide spray is moderate to high for almost all of the herbicides available under this 

alternative (Tables 3-12 and 3-13). Some of the herbicides available are non-selective (Table 3-1), and would kill 

all inadvertently treated plants in the treatment area. Diuron, glyphosate, hexazinone, imazapyr, and tebuthiuron 

would be used statewide, and bromacil and sulfometuron methyl would only be used east of the Cascades. 

However, the use of herbicides in rights-of-way, administrative sites, and recreation sites may have negligible 

effects on native plants as these habitats are currently managed in early seral condition (primarily by mechanical 

methods). That said, early seral Bureau Sensitive and Federally Listed species that are growing on roadsides 

and similar sites because they are maintained in an early seral condition with non-herbicide treatments such as 

mowing would be at risk of damage from herbicides. Required plant surveys and other clearances would mitigate 

some but not all of this risk. 

Under this alternative, herbicides would be used on an estimated 5,700 acres annually to restore habitats as 

described in approved Recovery Plans, Conservation Strategies, or Conservation Agreements for Federally Listed 

or Bureau Sensitive species. While herbicides used could have risk to non-target plants, applications would be 

specifically designed to improve overall habitat conditions. 

The effects of herbicide treatments on noxious weeds and other invasive plants under this alternative would be the 

same as described for Alternative 3. 

Effects of Invasive Plants on Native Plants: 

In general, the loss of native plants would be proportional to the acres projected to become infested. Under 

Alternative 4, the rate of spread of noxious weeds is projected to decrease to 6 percent annually (down from the 

current 12 percent), and approximately 1/5-1/4 of all BLM lands in Oregon would be infested within 15 years (Table 

4-6). This does not include the five million acres currently infested with other invasive plants that would continue to 

spread (presumably at a slightly reduced rate) under this alternative. The additional herbicides available under this 

alternative (1 west of the Cascades; 3 east of the Cascades) are generally designed for vegetation control in rights-ofways and other developed areas. Because right-of-way treatments would inadvertently control noxious weeds and 

other invasive plants on primary spread routes, the benefit to native plant communities is higher than Alternative 3, 

with 300,000 fewer acres projected to be infested with noxious weeds in 15 years. 

Effect of Non-Herbicide Treatments on Non-Target Native Plants: 

The amount of non-herbicide treatments projected to take place for the control of invasive plants, and their 

effect on native plants, is the same as for Alternative 3. However, this alternative would also make herbicides 

available to control native vegetation along rights-of-ways, administrative sites, and recreation sites. Such 

treatments would reduce non-herbicide treatments currently being done in those areas on an acre-for-acre basis 

(see Table 4-7 below, adapted from Table 3-9 in the Non-Invasive (Native) Vegetation Management section of 

the Assumptions about Application Methods section in Chapter 3). The alternative would also make herbicides 

available for certain habitat improvements, reducing current non-herbicide treatments by about 35 percent of the 

proposed herbicide acres. The assumed net change in treatment acres when compared to Alternative 3 is shown 

in Table 4-7. 

For the rights-of-ways, administrative sites, and recreation sites, herbicide use does not reduce non-herbicide 

treatment risks to non-target plants, because current non-herbicide treatments are within the disturbed clearing 

limits for rights-of-way anyway. An exception might be thought to occur where a listed species occurs within 

one of these disturbed areas. However, such a site, if known, would be protected under all treatment scenarios, so 

there would be no effect. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

127 

20 More specifically, having more than one herbicide available to treat a specific weed species helps prevent the treated 

population from persisting in the form of a few individuals (and their progeny) that may be materially resistant to a 

particular herbicide. 

 

For identified habitat improvement treatments, the reduction in mechanical and manual treatment acres would 

reduce the likelihood of soil disturbance and related damage to existing native plants (and soil crusts) on nearly 

2,000 acres. Since these sites may not be infested with noxious weeds or other invasive plants, the likelihood 

of damage to native plants is higher; however, treatments would be designed to increase more desirable native 

species, so the short-term adverse effects should be more than compensated by long-term improvements in habitat 

and land health. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Effects of Herbicides on Non-Target Native Plants: 

The effects of this alternative to non-target native plants would be similar to the effects described under 

Alternative 4. East of the Cascades, acres of 2,4-D and imazapic (both selective herbicides) would both 

increase by 2,000 acres; however, there is low to moderate risk to desirable plants that are directly sprayed 

with imazapic, and no to low risk for off-site drift. Two additional herbicides (diflufenzopyr + dicamba and 

diquat) become available east of the Cascades and six additional herbicides (diflufenzopyr + dicamba, diquat, 

bromacil, chlorsulfuron, sulfometuron methyl, and tebuthiuron) become available west of the Cascades. All 

but sulfometuron methyl have a moderate to high risk of harming non-target vegetation when directly sprayed. 

However, given the limited number of acres that would be sprayed with these, additional effects would be limited. 

Effects of Invasive Plants on Native Plants: 

In general, the loss of native plants would be proportional to the acres projected to become infested. Like 

Alternative 4, the spread rate of noxious weeds under Alternative 5 is projected to decrease to a rate of 6 percent 

annually (from the current 12 percent), and approximately 1/5 to 1/4 of all BLM lands in Oregon would be 

infested within 15 years. This does not include the five million acres currently infested with other invasive 

plants, that would continue to spread (but presumably at some reduced rate) under this alternative. The additional 

herbicides available under this alternative (6 west of the Cascades; 2 east of the Cascades when compared with 

Alternative 4) would provide options for weed control and help prevent infestations from developing resistance to 

specific herbicides20. Nevertheless, this increase would not be expected to change the BLM’s ability to reduce the 

spread of noxious weeds and other invasive plants by a full percentage point, so the gain is not estimated. 

Table 4-7. esTimaTed cHange in naTive vegeTaTion annUal TreaTmenT acres by TreaTmenT meTHod 

Method 

Treatment of native vegetation 

on rights-of-way, administrative 

sites, and recreation sites under 

Alternative 4 

Treatment of native vegetation 

for habitats as described in 

Conservation Strategies and 

Conservation Agreements under 

Alternative 4 

Total Native Vegetation treated 

under Alternative 4 

ES WS ES ES WS ES 

Herbicides 7,500 1,900 5,500 200 13,000 2,100 

Mechanical -6,750 -1,710 -1,155 -42 -7,905 -1,752 

Manual -750 -190 -770 -28 -1,520 -218 

Net change in total 

native vegetation 

acres treated 0 0 3,575 130 3,575 130 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Effect of Non-Herbicide Treatments on Non-Target Native Plants: 

The effects of this alternative to non-target native plants is similar to those described under Alternative 4, except 

that the additional 4,900 acres of herbicide use would be expected to reduce current non-herbicide treatments by 

about 1,700 acres (Table 4-7 earlier in this Chapter). For identified habitat improvement treatments, the reduction 

in mechanical and manual treatment acres would reduce the likelihood of soil disturbance and related damage 

to existing native plants. Since these sites may not be infested with noxious weeds or other invasive plants, the 

likelihood of damage to native plants is higher; however, treatments would be designed to increase more desirable 

native species, so the short-term impact should result in long-term improvements in habitat and land health. Fuel 

reductions and other treatments could also be conducted with herbicides under this alternative, and potential 

effects to native vegetation would be a site-specific consideration. 

Pests and Diseases (Sudden Oak Death) 

Affected Environment 

The Action Alternatives, Alternatives 3 through 5, would make herbicides available to the BLM in Oregon “to 

treat any vegetation, as necessary, to control pests and diseases in State-identified control areas, such as Sudden 

Oak Death (Phytophthora ramorum) in Southwest Oregon.” The pests and diseases in these cases are not plants 

that could be eradicated with herbicides, but fungi, insects, oomycetes, and others pests and diseases infecting or 

infesting native plants. Most of the time, such pests can be directly treated with fungicides, insecticides, and other 

pesticides or with non-pesticide methods. Occasionally, as in the case of Sudden Oak Death (currently infesting 

sites in southwestern Oregon), no effective direct control method is available and the best control available 

involves removing the host plant species. Such treatments would only be applied in those areas, and for those 

species, for which the Oregon State Department of Agriculture has specified a quarantine area. Sudden Oak 

Death in Curry County is the only such area and species currently identified by the State for control. 

In contrast, for example, BLM and other land managers sometimes remove Port-Orford-cedar from roadsides 

to help prevent the spread of Port-Orford-cedar root disease. This is not a State-identified control need, and the 

alternatives do not include herbicide use for such treatments. 

Because Sudden Oak Death is the only currently known example of a treatment that would be proposed under this 

portion of these alternatives, a discussion of Sudden Oak Death is included here as both an example of, and as 

the foreseeable application of, this aspect of Alternatives 3, 4, and 5. Treatment of future infestations of different 

pathogens would require, at minimum, a determination of whether this or another EIS adequately addressed the 

potential effects of herbicides proposed for use, and would require appropriate site-specific NEPA analysis to 

address other aspects of the proposed treatment. 

Sudden Oak Death Characteristics and Dispersal Strategy 

Sudden Oak Death is caused by Phytophthora ramorum, a recently described, invasive pathogen of unknown 

origin (Rizzo et al. 2002, Ivors et al. 2004, Rizzo and Garbelotto 2003, Rizzo et al. 2005, Werres et al. 2001). 

Millions of oaks (Quercus spp.) and tanoaks have been killed by this pathogen in the forests and wildland-urban 

interface of coastal California since the disease became evident in the mid 1990s (Meentemeyer et al. 2008). By 

2004, the disease had inundated the California coastline extending 750 km [466 miles] (Meentemeyer et al. 2004). 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

The northern-most infestation in California is near Redway in southern Humboldt County. Sudden Oak Death 

was detected in Curry County in southwestern Oregon in 2001, where it was killing tanoak and infecting Pacific 

rhododendron and evergreen huckleberry (Goheen et al. 2002). The infestation remains contained to this one area 

of Oregon, although other strains of the pathogen were detected in, and eradicated from, approximately 60 Oregon 

nurseries between 2003 and 2007 (ENTRIX, Inc. 2008). 

Often referred to as “fungi,” Phytophthora species are “water molds” that are closely related to marine algae 

(Erwin and Ribeiro 1996). Favored by moist conditions, Phytophthora species include some of the world’s 

most notorious plant pathogens. Most Phytophthora species are root pathogens; however, P. ramorum 

predominantly affects aboveground plant parts such as leaves, needles, boles, green twigs, and woody stems 

(Davidson et al. 2003, Hansen et al. 2008). Over 100 plant species are known hosts including native forest 

species such as tanoak, oaks in the red oak group such as California black oak, Douglas-fir, coast redwood, Pacific 

rhododendron, evergreen huckleberry, and Pacific madrone as well as important commercial nursery species such 

as rhododendron, camellia, Pieris and laurel (USDA 2008). In Oregon, the list of native plants that have been 

found infected in the wild is much shorter; tanoak, evergreen huckleberry and Pacific rhododendron are usually 

the only infected species; occasionally Oregon myrtle and Douglas-fir have been found infected in areas with high 

inoculum levels (Hansen et al. 2008). 

P. ramorum is apparently well adapted to the mild, wet conditions of the Pacific Coast (Hansen et al. 2008). Its 

current distribution in California mirrors the range of coast redwood. In Oregon forests, the pathogen has only 

been detected within 10 miles of the Pacific Ocean in the Siskiyou Biome, where the climate is wet and mild in 

winter and warm and dry in summer with frequent fog. Oregon’s infested area falls within the Mixed-Evergreen 

Zone as defined by Franklin and Dyrness (1988). Tanoak, often with Douglas-fir, dominates the infested sites. 

Plant community associations are characteristic of the warm and wet environments of the Tanoak Series (Atzet et 

al. 1996). 

The pathogen produces small sacs (sporangia) of swimming spores (zoospores) that readily break off and can 

be spread in rain splash, drip, stem flow, and wind. Multiple generations of spores may be produced during wet 

weather periods. It also makes thick-walled resting spores (chlamydospores) in infected plant parts that allow it to 

survive heat and drought and persist for months in soil and plant debris (Hansen et al. 2008). 

In the forest, tanoak twigs and leaves are first infected in the upper crown. New growth in the spring is highly 

susceptible as are recently formed tanoak sprouts. Zoospores swim through water films on the surface of leaves 

or stems until they settle, germinate, and penetrate into the plant. New sporangia are formed on infected leaves 

and twigs in wet weather and may wash or splash down the stem. The trunk cankers that kill the tree apparently 

originate from spores washed down from above. Rhododendrons and huckleberries, and occasionally other hosts 

growing beneath or adjacent to infected trees, may be infected. 

Longer distance spread in forests is facilitated by turbulent transfer of sporangia dislodged from upper crown 

infections in clouds and wind-driven rain (Hansen et al. 2008). Most of newly infected trees are found within 

about 300 to 600 feet of previously infected trees, a pattern consistent with wind and rain dispersal. However, 

new disease sites have been detected up to 3 miles from nearest known infested areas. P. ramorum can also be 

moved over extreme long distances (continental, global scales) in infected nursery stock (Goheen et al. 2006). 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Regulations and Control 

P. ramorum is subject to both State (ORS 603-052-1230) and Federal (7 CFR 301.92) quarantine regulations that 

restrict the human-assisted movement of hosts from infested areas into disease-free areas. Fourteen contiguous 

coastal counties in California are currently under quarantine. In Oregon, a 160 square mile area in and around the 

city of Brookings in Curry County, is currently subject to quarantine regulations. 

Oregon State regulations also require eradication of the pathogen when it is found on State or private holdings. 

As a result, the Oregon Department of Agriculture (ODA) and the Oregon Department of Forestry (ODF) have 

been involved in an aggressive eradication program since 2001. The objective of the eradication program is to 

eliminate P. ramorum from all known sites and to prevent the pathogen from becoming established in native 

wildland forests by eliminating the pathogen or by eliminating the plants that carry the pathogen, at each newly 

detected infestation. This disease control program is not automatically enforced or applied to Federal lands. 

However, Federal land managers administering national forests and BLM lands in Curry County recognize that 

success of the local P. ramorum eradication effort depends on the application of control treatments across the 

landscape without regard to land ownership, and have cooperated in this effort since 2001. 

Treatment History in Oregon 

When P. ramorum was first discovered in southwest Oregon forests in 2001, there were nine infested forest 

sites ranging in size from 0.5 to 11 acres and totaling 40 acres on non-industrial private forest lands, industrial 

private forest lands, and Federal forest land administered by the BLM. A nine-square mile quarantine area was 

established around the area of infestation. P. ramorum probably was present at one forest location as early as 

1998 (Hansen et al. 2008). 

Initial eradication treatments involved cutting, piling, and burning infected plants and all nearby potentially 

infected or exposed host vegetation within a 50- to 100-foot radius buffer zone. Treatment monitoring revealed 

that the buffer area was inadequate to capture localized spread of the pathogen and that newly emerging sprouts 

from cut infested tanoaks were highly susceptible to infection and were maintaining the pathogen on infested 

sites (Hansen et al. 2008). A variety of methods to control tanoak sprouting were attempted including backpack 

spraying of new sprouts, manually cutting, piling, and burning new sprouts, and stump-top application of 

herbicides to prevent sprouting. The use of injected herbicides imazapyr or glyphosate to prevent sprouting of all 

tanoak stems one inch diameter and larger, where possible (on State, private, and national forest lands), has been 

incorporated into the preferred treatment prescription since 2003. Buffer zone treatments have been increased and 

now include an area within a 300-foot radius of known infected plants. Upon completion of tanoak removal and 

burning, most sites have been planted with non-host hardwood or conifer seedlings. 

To date, over 730 tanoaks in Curry County have been found infected since 2001 on approximately 200 acres 

(Table 4-8). Altogether, approximately 2300 acres, including approximately 200 acres of BLM land, have been 

treated (Kanaskie 2009). Since the first finding of Sudden Oak Death in Oregon in 2001, eradication of the 

disease has eliminated P. ramorum from some treatment areas, but it continues to appear in new locations in and 

near the regulated area in Curry County. In 2006 and 2007, the disease expanded considerably, probably due to 

consecutive years of unusually wet spring and early summer weather. As a result of this expansion, Oregon’s 

Curry County quarantine area was increased to 160 square miles in January 2008. Disease levels were slightly 

reduced in 2008. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

 

131 

The net effect of the Oregon eradication program has been a dramatic reduction in the rate of disease spread 

as compared to similar areas in California where there is no comprehensive control program. Phytophthora 

ramorum was detected at low levels in tanoak forests in southern Humboldt County, CA in 2001 and was 

subjected to similar environmental conditions, including moist spring and early summer weather in 2005 and 

2006. In the four-year period from 2004-2007, the cumulative estimated infested area in Humboldt County 

grew from 123 acres to approximately 4,500 acres, an increase of 3,658 percent. By comparison, aggressive 

treatment in Oregon, while not completely controlling the pathogen, has substantially slowed disease progression. 

In Oregon in 2004, 70 infested acres were detected; by 2007, this number had increased by 182 percent to 128 

infested acres. 

Environmental Consequences 

Effects Common to All Alternatives 

Like noxious weeds, negative environmental effects are predicted to result from both the spread of P. ramorum 

and its control treatments, with or without the use of herbicides. 

Effects from the Spread of P. ramorum (Sudden Oak Death) 

The spread of P. ramorum poses a potentially serious threat to forest ecosystem function, habitats, fire behavior, 

landscape aesthetics, and the horticultural and timber industries. (Goheen et al. 2006, Rizzo and Garbelotto 2003, 

Appiah et al. 2004, Hansen et al. 2008). Rizzo and Garbelotto (2003) speculate that the “broad host range of P. 

ramorum, the variability of symptoms between different hosts, and the pathogen’s aerial dispersal suggest that it 

has the potential to cause a cascade of long-term landscape changes.” In the California counties where Sudden 

Oak Death was first discovered, the disease has already adversely affected ecosystem functions, increased fire and 

safety hazards and reduced property values in developed areas (Rizzo and Garbelotto 2003, Appiah et al. 2004). 

Tanoak occurs on approximately 1 million acres in Oregon across four southwestern Counties (Curry, Coos, 

Douglas, and Josephine) with an estimated stocking of 81 trees per acre greater than 8 inches in diameter (FIA 

data). Its deep taproot and lateral root configuration contribute substantially to slope stability. It is used by a 

variety of wildlife species for cover and forage. Its acorns are considered an important winter food for deer, 

bears, rodents and several bird species. Tanoak is also a substantial component of Nesting/Roosting/Foraging 

habitat used by northern spotted owls in Southwest Oregon (USDI 2008b). A small proportion of northern spotted 

Table 4-8: sUdden oak deaTH in oregon foresTs: december 31, 2008 

Year Number of tanoaks infected 

with P. ramorum 

Number of new disease 

patches 

Area of new disease patches 

each year1 (acres) 

2001 100+ 9 36 

2002 85 12 8 

2003 49 12 12 

2004 30 9 10 

2005 49 9 18 

2006 143 36 40 

2007 160 60 54 

2008 122 63 23 1

 includes new infested sites and expansion of existing eradication sites 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

owl nests in southwestern Oregon are in tanoak trees. A substantial reduction in the tanoak component due to 

P. ramorum-caused mortality would be expected to proportionally reduce the quality and quantity of tanoak 

dominated habitat and the abundance and availability of food items for the spotted owl. Tanoak, as well as other 

species affected by P. ramorum, including evergreen huckleberry, is also considered to be of cultural importance 

to American Indians with ties to coastal environments. 

Increased spread to areas outside the current quarantine area will increase the size of the quarantine area itself. 

While tanoak is limited in range to southwest Oregon, other susceptible hosts such as Pacific rhododendron 

and evergreen huckleberry occur all along the Pacific Coast into British Columbia. Increased regulated area 

represents more restrictions on the flow of products and affects larger numbers and types of forest product users. 

Costs to affected industries include lost revenues associated with collecting and selling special forest products, 

increased manufacturing costs associated with debarking or kiln drying of logs, increased labor associated with 

removing soil and twigs from logs or other wood products, increased labor costs for sanitation measures, and costs 

associated with inspections and additional shipping documentation. Infested nurseries bear the cost of destroying 

infected plant materials and are not reimbursed for revenues lost. The implications, real or perceived, of the 

disruption and higher costs of doing business within a quarantine area can be far reaching and of international 

scope. Other countries often choose to regulate plant materials at the genus level, which would mean many 

non-host species have the potential to be regulated as well as the numerous species that are known hosts. Certain 

products may even be refused on the international market. There is also currently a perception among property 

owners that private property values are reduced inside quarantine areas. 

Nursery stock represents nearly a billion dollar industry in Oregon and is the State’s most valuable agricultural 

commodity (ENTRIX, Inc. 2008). The 2,100 registered nursery and greenhouse grower operations in Oregon 

export out of State more than 75 percent of the nursery stock produced. The total economic impact of the nursery 

and greenhouse industry in Oregon in 2002 was estimated at $1.69 billion in output, $1.04 billion in value added, 

and 21,554 jobs. The first known detection of P. ramorum-infected nursery plants in Oregon occurred in 2003. 

Six infested nurseries were found that year. Since then, in the years 2004 to 2007, there have been an average of 

approximately 13.5 nurseries infected annually (COMTF). Federal rules enacted in 2004 and updated in 2007 

require P. ramorum inspections for all nurseries shipping out of State and specific testing procedures for nurseries 

with susceptible species or in a quarantine area. Losses to the nursery industry, including those associated with lost 

market share / and reduced consumer confidence is estimated in the range of $28.16 million to $259.20 million. 

Surveys for P. ramorum are underway in forests and nurseries in other parts of North America as well as 

throughout Europe. Risk assessments indicate that large areas of oak forests in the southern Appalachian region 

of eastern North America, as well as in oak and beech forests in Europe, are at high risk for the establishment of 

the pathogen and losses associated with subsequent mortality. Potential impacts of this pathogen to ecosystem 

health and function and to economics and trade go well beyond the oak and tanoak forests of the Pacific Coast. 

Effects of Treatment 

The effect of treatment are based on the site disturbance and clearing associated with treatment of the infested 

areas, including the effects of herbicides used in those treatments. The current treatments include: 1) glyphosate 

injection (herbicide treatment) of tanoak to prevent resprouting on private and Forest Service lands only at this 

time, 2) cutting of infected host species (common examples are tanoak, rhododendron, and evergreen huckleberry) 

3) creating a buffer area, and 4) burning the cut vegetation (USDA, USDI 2008). 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

The zone of eradication includes all infected plants and those uninfected host plants in a buffer zone that extends 

out up to 300 feet from the infected plant(s). Host plant species to be treated would be determined based on host 

species affected at the site or information from recent research. Buffer zone delimitation is based on current 

understanding of short-distance spread of the pathogen. Multiple infestations within close proximity to each other 

would be buffered by up to 300 feet to create a single treatment site. Treatment sites may be smaller than 300-feet 

extensions from infected plants when adjusted for natural breaks, changes in plant community, and topography 

(USDA, USDI 2008). 

Effects (to Vegetation)21 by Alternative 

Alternative 1 – No Herbicide Use and Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Control treatments would continue as they are now; herbicides would not be used on the BLM portion of the 

infestation. Imazapyr and glyphosate would continue to be used to kill tanoaks and prevent resprouting22 on the 90 

percent of the control area that is not on BLM lands. Chainsaws and follow-up sprouting control would continue to 

be used to kill tanoak in the 10 percent of the control area on BLM lands. Because of the multicyclic nature of the 

pathogen, most sites are treated within 3 to 10 weeks of disease confirmation. However, newly emerging sprouts 

from cut tanoaks are highly susceptible to infection and are capable of maintaining the pathogen on infested sites. 

As such if they are not killed, the goal of eradicating the pathogen is not achieved. Maintenance of the pathogen on 

a given site increases the probability of spread to uninfested sites via natural or human-assisted means. 

Monitoring data from early Sudden Oak Death eradication treatments in Oregon suggests that localized spread 

(the creation of new disease centers from nearby infected plants) will occur when the pathogen remains viable 

on a site. One to two new infection centers resulted from those sites where the pathogen was known to survive. 

Manual treatment of sprouts essentially delays treatment effectiveness when compared to herbicide treatment. 

Manual treatment of sprouts is not done for some time, perhaps as long as a year after cutting, because it takes this 

long for sprouts to develop to a stage where it is practical to treat them. Multiple treatments may be necessary if 

stumps subsequently resprout. Estimated contract costs for manual treatment of tanoak sprouts is $690/acre. 

Treatments in Curry County that make use of herbicides are more effective at controlling the pathogen than the 

treatment currently used on BLM lands. 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. Therefore, 

there would be an expected increase of 15 to 30 percent in infested acres when herbicides are not used. 

These additional infested acres would be treated by removing and burning all infected tanoaks. The area affected 

by the loss of tanoak expand an estimated 15 to 30 percent faster on BLM lands than on lands where herbicides 

are part of the treatment. The area that would be disturbed by control activities and the loss of tanoak would be 

expected to similarly increase for the indefinite future. The likelihood of totally eradicating the infestation from 

Oregon, which is the goal, is substantially less than under Alternatives 3 though 5. 

21 Other resource effects from Sudden Oak Death control are included in their respective effects sections in this Chapter. 

22 Tanoak is a notoriously vigorous resprouter, quickly regenerating multiple fast-growing stems from every cut stump. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases; 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses; and, Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity 

Vegetation Management Objectives 

The herbicides imazapyr and glyphosate would be available for use in killing tanoaks and/or treating cut stumps 

within control areas on BLM lands. Under a proposed cooperative plan to step up efforts to eradicate the 

pathogen from Oregon, BLM treatments are estimated at 250 acres per year. Herbicide would be expected to be 

manually applied to frills chopped in the boles of tanoak trees, daubed or spot sprayed on cut stumps, and/or spot 

sprayed on sprouting foliage at cut stumps. If the infestation continues to spread, these acres would be expected 

to increase. 

Herbicide treatments to prevent tanoak sprouting are more effective in eliminating P. ramorum from infested sites, 

because sporangia, zoospores, and/or chlamydospores remaining on site readily reinfect the sprouts and continue 

to occupy the site and reproduce. The estimated contract costs for injected herbicide treatment of tanoak stems is 

$200/acre. 

Chainsaw control of sprouting stumps would be all but eliminated under these alternatives. Achieving the 

cooperating agencies’ goal of removing the pathogen from Oregon is far more likely; and all agencies would be 

expected to more aggressively fund and pursue that goal if it is made more achievable. Site disturbances from 

the falling, piling, and burning of tanoak would be similar to such disturbances under Alternatives 1 and 2. These 

disturbances would be less under this alternative only to the degree that the acres in need of treatment would be 

less under this alternative in the long term. 

Measures to reduce the potential effects of herbicides on fish (see Fish Section) 

In July 2008, the BLM and Forest Service prepared a Programmatic Biological Assessment for submission to the 

National Marine Fisheries Service that described the potential for 2008-2013 control efforts to affect listed Coho 

and Chinook salmon within the Southwestern Oregon Province. That Biological Assessment determined the 

following treatments and protection measures would result in no effect to Federally Listed species. 

“Where allowed and feasible, all tanoak (Lithocarpus densiflorus) and other hosts with stems meeting 

minimum requirements suitable for injection (approximately 1 inch in diameter and greater) within the 

eradication zone would be injected with the chemical aquatic-labeled glyphosate using a method referred to 

as “hack and squirt.” This method would employ a single tool that injects the herbicide directly into the stem 

with little to no chance for a spill. Once the tanoak is dead (approximately two weeks), it is cut. Only daily 

quantities of aquatic-labeled glyphosate would be transported to the project site. Aquatic-labeled glyphosate 

would not be applied if rain is likely to occur within 24 hours. Spill prevention, hauling, staging, mixing, 

loading, cleaning, application equipment, and storage requirements would be implemented. 

“An Oregon Licensed applicator with forestry, aquatic, and right-of-way categories would be utilized. All 

herbicide mixing would be done in the presence of an agency Project Inspector. Equipment cleaning and 

storage and disposal containers would follow all applicable state and Federal laws. The licensed herbicide 

applicator would prepare a written herbicide Spill Contingency Plan in advance of the actual aquatic-labeled 

glyphosate application, then submit it to the Authorized Officer prior to operations, and keep a copy with each 

crew. An agency approved Spill Containment Kit would be on-site during all stages of applications” (USDA, 

USDI 2008:20). 

These measures are consistent with the treatment expected under Alternatives 3-5. 

 134 
 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Climate Trends, Projections, and Implications 

See beginning of this Chapter for a discussion of the current climate. 

Observed Climate Trends 

Mote (2003b) documented many changes in the Pacific Northwest23 climate. Over the past 100 years, 

temperatures have increased but at slightly different rates. In the maritime climatic zone, which includes the 

coast, northwest Oregon and southwest Oregon in this study, average annual temperatures have increased 1.6° 

F while the central zone, which includes eastern Oregon, has seen average annual temperatures increase by 1.5° 

F. Increases have generally been higher at higher elevations. Temperatures have increased the most in winter 

(January-March) and least in fall (October-December), with temperatures also increasing substantially in summer 

(July-September) in the maritime climatic zone. The 1990s were the warmest decade in the 20th Century. 

Precipitation has also increased, although much less so in the maritime climatic zone. This zone includes many 

stations that show little change or slight decreases in western Oregon. Unfortunately, the data for eastern Oregon 

includes only stations in the Blue Mountains and Columbia Basin and none in central or southern Oregon. 

Overall, precipitation has increased 2-4 inches. This amount is relatively insignificant along the Oregon coast 

and northwestern Oregon but highly significant in eastern Oregon. Most of this increase occurred before 1945. 

Spring (April-June) precipitation has increased the most across the Pacific Northwest. Summer precipitation 

has increased some 70 percent in the central climatic zone, but this increase is insignificant given that summer 

precipitation is already very low in this zone. 

These observed changes in precipitation and temperature are beginning to manifest in other aspects of Oregon’s 

climate. Below 5900 feet elevation, the amount of snow on April 1, typically the peak of snow accumulation, 

has declined by as much as 60 percent since 1950, coinciding with increased temperatures and despite increased 

precipitation (Mote 2003a). Less winter precipitation is falling as snow in the Cascades and Blue Mountains 

(Knowles et al. 2006) and spring snowmelt is occurring earlier (Westerling et al. 2006). Aridity in the interior 

western United States, which includes eastern Oregon, has been increasing since 1900 (Cook et al. 2004). On a 

global basis, the number of cold days, cold nights and frost have become less frequent while the number of hot 

days, hot nights, and heat waves have become more frequent (IPCC 2007), although these trends have not been 

analyzed specifically for Oregon. 

Climate Change Projections 

The Climate Impacts Group (CIG) (2007) at the University of Washington recently released the latest projections 

for the climate of the Pacific Northwest. This forecast is based on 20 general circulation models and on two 

emissions scenarios – B1 (lower emissions) and A1B (higher emissions). By 2100, CO2

 concentrations are 

expected to range from 549 ppm under the B1 scenario to 970 ppm under the A1B scenario. These concentrations 

would be approximately 2 to 3.5 times, respectively, the pre-industrial CO2 concentration of 280 ppm. Projections 

for the resulting impact on temperature have greater certainty than for precipitation. 

In general, the climate in Oregon will be warmer, but not significantly wetter. Temperatures are expected to warm 

by 0.5° F per decade into the 2050s, with future changes depending on the emissions scenario used. Average 

23 The Pacific Northwest is defined as all of Oregon, Washington, and Idaho, southern and central British Columbia and 

part of western Montana. 

135 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

annual temperature will increase 2.2° F (1.1-3.4° F) by the 2020s, by 3.5° F (1.6-5.2° F) by the 2040s and by 5.9° 

F (2.8-9.7° F) by the 2080s relative to the 1961-1990 average. As early as the 2020s this change could be outside 

the range of variability observed in the 20th Century. All seasons will be warmer with the largest temperature 

increase in summer (June-August). 

Only small changes in precipitation are expected. The average annual precipitation could increase only 1-2 

percent (-10 percent - +20 percent). By the 2020s, winter (December-February) precipitation may increase, 

although it is more likely to increase by the 2080s. Summer precipitation is expected to decrease. 

Hydrological drought is expected to become more common due to increased temperatures and decreased 

snowpack. The Aleutian Low and storm track across the North Pacific are expected to shift north and intensify, 

likely increasing the frequency of large-scale storms and bringing more intense precipitation into the Pacific 

Northwest in winter (Leung et al. 2004, Salathé 2006). Most of this intense precipitation will fall in western 

Oregon and the Blue Mountains and most of the change is expected to occur in the second half of the 21st century 

(Salathé 2006). 

These projected trends in temperature and precipitation have implications for other aspects of climate as well. 

The observed trend for less snow in winter and earlier snowmelt will likely continue. Increasing temperatures 

indicate the transient snow zone will rise in elevation and potentially all but the highest peaks in the Cascades 

could fall within this snow zone (Leung et al. 2004). The growing season will likely shift to earlier in the year, 

although it is much less clear if the length of the growing season will increase, decrease or remain unchanged. 

The length and intensity of the summer seasonal drought will likely increase. Cold snaps will likely happen less 

often, although they may be just as severe as past cold snaps given the source of the cold air. Heat waves and 

hot extremes are very likely to become more frequent (IPCC 2007). Multi-year droughts are expected to become 

more frequent and last longer (Cook et al. 2004). Summer may have more clear days (Leung et al. 2004). 

These projections include a number of uncertainties. Generally, regional climate models can produce very 

different results from general climate models, even though the general climate models form the basis for the 

regional models. The differences arise from the generation of general climate model used as a basis, differences 

in model parameterization and differences in model resolution (Christensen et al. 2007). Ensemble modeling and 

forecasts can help reduce some of this source of uncertainty (Leung et al. 2004). High elevation terrain is not well 

represented in most models, potentially leading to an underestimation of warming at higher elevations associated 

with snow-albedo feedback (Christensen et al. 2007). How changing ocean conditions will affect ENSO and 

PDO remains unknown (Christensen et al. 2007, Climate Impacts Group 2007). Current models have not yet 

incorporated new information on the accelerating rate of atmospheric CO2

 growth (Canadell et al. 2007). Other 

events, such as the Asian dust storms, have only recently been identified as potentially impacting the climate of 

western North America (Zhang et al. 2007) so have not been adequately incorporated into climate models either. 

The alternatives themselves could affect climate change, but the differences between the alternatives are slight 

and potentially speculative. As noted in the Air Quality section, the science is lacking to develop a complete 

carbon budget principally due to the lack of information on belowground carbon dynamics in all ecosystems and 

very limited information on aboveground carbon dynamics in rangeland ecosystems. Although carbon cannot be 

thoroughly analyzed, one of the known qualitative trade-offs are that activities that can restore healthy functioning 

ecosystems, including treatments to reduce invasive plants, tend to increase carbon sequestration. Also that 

section points out that Alternative 4’s replacement of roadside mowing with herbicide use should decrease fossil 

fuel use. These factors point to the proposed action having favorable effects on climate change and long-term air 

quality when compared to the No Action Alternative, but the difference is qualitative and likely so small as to 

play little role in influencing the choice between the alternatives. 

 136 
 

 

 

 

 

 

 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Implications of Climate Change on Invasive Plants 

In response to increased temperatures, longer hotter summers, earlier snowmelt, and resultant increased 

hydrologic droughts, plants will migrate north and upslope (Tausch 2008, Middleton 2006). Existing plant 

communities likely will disappear and new plant communities will form based on differential migration rates; 

differential responses to temperature, precipitation and increasing carbon dioxide (CO2); and differential responses 

to competition (Best et al. 2007, Climate Impacts Group 2004:4). Changing weather patterns and the resultant 

shifts in plant communities will both favor invasive plants. 

Many invasive plants originate from Mediterranean climates,24 and have wide ecological amplitudes, two 

features that make them successful in Oregon and will make them more successful in the future. For example, 

many invasive plants are more likely than native plants to have a deep taproot, sparse foliage, or other 

characteristics for surviving long hydrologic droughts.25 Some species may respond more to temperature 

changes, some more to precipitation changes, and some to the joint change in temperature and precipitation 

(Climate Impacts Group 2007). 

There is also evidence that rising CO2

 can preferentially select for invasive plant communities (Ziska and George 

2004:427, Patterson 1995). The rise in CO2

 increases photosynthesis, for a “fertilizer effect.” Ziska and George 

(2004:436) found doubling CO2

 increased biomass 34 percent if moisture, nutrients, and light were not limiting. 

One of the common responses to rising CO2

 is an increase in belowground root growth relative to aboveground 

shoot growth (Ziska and George 2004:439). Thus, the CO2

 fertilizer effect favors plants with a taproot, or higher 

root/shoot ratio than other plants, both of which are often characteristic of invasive plants. 

High CO2 has altered weed herbicide resistance: Canada thistle (a species that reproduces asexually from 

belowground organs) gown at high CO2 becomes resistant to glyphosate (Ziska et al. 2004). If high CO2

 affects 

other weeds similarly (increases herbicide resistance while enhancing belowground biomass storage), those 

species will become increasingly competitive with native species and harder to kill, resulting in changes to 

communities, and thus ecosystem process. 

Also general warming and a decreased incidence of killing frosts will allow the spread of invasive plants currently 

limited by a low tolerance to freezing. Warming will allow additional invasive plants to enter Oregon. 

The shift in plant communities upslope and to the north is essentially a disturbance that makes an increasing 

number of niches available. The same characteristics that make invasive plants successful at invading other 

disturbances will likely give invasive plants an advantage during this migration. 

Other factors will exacerbate this “disturbance”: increased fire frequency and intensity; anthropogenic 

disturbances; and severe weather disturbances. For example, climate shifts will cause fuel loads to accumulate 

and dry earlier in the growing season (not counting the increased loading from drought-related mortality). Also, 

research suggests some weeds including cheatgrass grown at higher CO2 levels burns hotter, not just because of 

additional carbon storage, but because of a higher carbon ratio (Blank et al. 2006). Thus wildfires in cheatgrass 

and potentially other invasive plant-filled communities would be expected to burn hotter in the future, all else 

being equal. Hotter wildfires are more likely to remove even fire-resistant native plants, and then invasive plants 

are more likely to invade the resultant burned areas (USDA 2005:3-21). 

Anthropogenic disturbances will have the same effect, contributing to the disturbance and stress caused by the 

climate shift and creating more opportunities for invasive plants. Similarly, as native plants thin and soils become 

24 A type of climate characterized by hot, dry, sunny summers and a winter rainy season.
 

25 Long seasonal soil moisture decreases resulting from earlier snowmelt and longer, hotter dry seasons.
 

137 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

 138 

1 Annual standards are never to be exceeded. Short-term standards (those other than annual or quarterly) are not to be exceeded more than 

once per year, except for O3, PM10, and PM2.5 standards. For O3, the expected number of days with ozone levels above the standard is not 

to be exceeded more than once per calendar year. For PM10, the standard is attained when the 99th percentile concentration for the year is 

less than the standard. For PM2.5, the standard is attained when the 98th percentile concentration for the year is less than the standard. 

poorly protected, increased storm intensities are more likely to disturb soils. For each disturbance, climate 

shifts may have decreased the ability of local native plants to compete with invasive ones, or even to be used in 

subsequent restoration. 

Site-specific changes may be quite different than described above. However, a general conclusion, based on 

the preponderance of current literature, suggests, “most of the important elements of global change are likely 

to increase the prevalence of biological invaders” (Dukes and Mooney 1999:138). The temperature and CO2 

changes predicted for Oregon in the coming decades will increase the spread of invasive plants and, to some 

degree, also make them harder to control. Plants already geographically restricted and/or stressed, such as those 

rare species listed under the ESA or otherwise included in the Special Status Species Program, will become more 

vulnerable to invasive plants than they are today, because of climate change. This increased level of risk is in 

addition to the risk that will result as invasive plants occupy more acres in Oregon. 

Air Quality 

Affected Environment 

Because air pollution can directly pose health risks and cause significant welfare effects to humans, management 

and improvement of air quality in the U.S. is an important regulatory goal. The Clean Air Act, originally passed in 

1955 and amended several times since, establishes a mandate to reduce emissions of specific pollutants via uniform 

Federal standards. Under the Act, the EPA identifies criteria pollutants, sets regulatory standards for those pollutants, 

and approves State and tribal implementation plans (SIPs and TIPs). States and tribes enforce the standards set by 

EPA and can delegate that authority to local air pollution control boards. States and tribes can set more stringent 

standards than the National Ambient Air Quality Standards (NAAQS) but cannot relax standards. 

The EPA set primary and secondary NAAQS (Table 4-9). The primary NAAQS protect the health of susceptible 

individuals and the secondary NAAQS protect the general welfare of the public, including visibility in Class I 

areas (EPA 2007a). Different averaging periods are established for the criteria pollutants based on their potential 

Table 4-9. Primary and secondary naTional ambienT air qUaliTy sTandards (naaqs) 

Criteria 

Pollutant Averaging Period1 

NAAQS 

Primary Secondary 

NO2 Annual 0.053 ppm 0.053 ppm 

CO 1-hour 35 ppm --­

8-hour 9 ppm --­

PM10 24-Hour 150 μg/m3 150 μg/m3 

PM2.5 

24-hour 35 μg/m3 35 μg/m3 

Annual 15 μg/m3 15 μg/m3 

SO2 

3-hour --­ 0.5 ppm 

24-hour 0.14 ppm --­

Annual 0.03 ppm --­

Lead Quarter 1.5 μg/m3 1.5 μg/m3 

Rolling 3-month Average 0.15 μg/m3 0.15 μg/m3 

O3 8-hour 0.075 ppm 0.075 ppm 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

 

139 

health and welfare effects. The six pollutants currently regulated are sulfur dioxide (SO2), nitrogen dioxide (NO2), 

carbon monoxide (CO), ozone (O3

), lead (Pb), and particulate matter (PM). 

Particulate matter is a generic term for a broad class of chemically and physically diverse substances that exist 

as discrete particles over a wide range of sizes. For regulatory purposes, particulate matter is further classified 

by the particle’s aerodynamic diameter. PM10 includes all particulate matter with an aerodynamic diameter of 

10 microns or less and is referred to as inhalable PM. PM2.5 includes all particulate matter with an aerodynamic 

diameter of 2.5 microns or less, called fine PM, and is by definition a subset of PM10. Studies have shown more 

serious health effects associated with PM2.5; therefore, EPA promulgated more stringent standards for this class of 

particulate matter. 

All areas of the nation have been classified based on their status with regard to attaining the NAAQS. The EPA 

designates an area as being in attainment for a criteria pollutant if ambient concentrations of that pollutant are 

below the NAAQS, or being in non-attainment if criteria pollutant concentrations violate the NAAQS. Once nonattainment areas comply with the NAAQS, they are designated as maintenance areas. Areas classified as nonattainment must implement a plan to reduce ambient concentrations below the NAAQS. Areas where insufficient 

data are available to determine attainment status are designated as unclassified, and are treated as attainment areas 

for regulatory purposes. 

In general, the air quality in Oregon is good but with persistent problem areas where strong inversions tend to trap 

either CO or particulate matter at certain times of the year (Table 4-10). In mid-September 2008, EPA proposed 

listing Oakridge and Klamath Falls, Oregon and some of the area surrounding these two communities as nonattainment for PM2.5. A final decision is expected in late 2009 or early 2010. 

Visibility Protection in Mandatory Federal Class I Areas 

Visibility protection in mandatory Class I areas is the most significant aspect of the human welfare part of the 

Clean Air Act standards. The EPA promulgated the Regional Haze Rule in 1999 to further improve visibility 

mandatory Federal Class I national parks and wilderness areas. Mandatory Class I areas include national parks 

over 6000 acres in size and wilderness areas over 5000 acres in size that were in existence on August 7, 1977 

plus any subsequent additions to those areas or any wilderness areas designated as Class I in their enabling 

legislation. All areas that have not been designated Class I are designated as Class II areas. Oregon has 12 

mandatory Class I areas and potential to affect up to 5 mandatory Class I areas in adjoining states (Table 4-11). 

Oregon does not have any non-mandatory Class I areas nor are there any in close proximity to the Oregon 

border in surrounding states. 

Table 4-10. non-aTTainmenT and air qUaliTy mainTenance areas in oregon 

Pollutant Non-Attainment Maintenance 

Ozone (8-hour 

standard) None Portland Metro – service district boundary Salem – central transportation study area 

CO Salem – central transportation study area 

Grants Pass – central business district 

Klamath Falls – urban growth boundary 

Medford – urban growth boundary 

Portland Metro – service district boundary 

Eugene-Springfield – urban growth boundary 

PM10 

Eugene-Springfield – urban growth boundary 

Oakridge – urban growth boundary 

Grants Pass – urban growth boundary 

Klamath Falls – urban growth boundary 

Lakeview – urban growth boundary 

Medford-Ashland – Rogue Valley 

La Grande – urban growth boundary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table 4-11. mandaTory class i areas in oregon and nearby in adjoining sTaTes 

State Class I Area Land Manager 

Oregon 

Mt. Hood Wilderness USDA Forest Service 

Mt. Jefferson Wilderness USDA Forest Service 

Mt. Washington Wilderness USDA Forest Service 

Three Sisters Wilderness USDA Forest Service 

Crater Lake National Park USDI National Park Service 

Diamond Peak Wilderness USDA Forest Service 

Kalmiopsis Wilderness USDA Forest Service 

Mountain Lakes Wilderness USDA Forest Service 

Gearhart Mountain Wilderness USDA Forest Service 

Strawberry Mountain Wilderness USDA Forest Service 

Eagle Cap Wilderness USDA Forest Service 

Hells Canyon Wilderness USDA Forest Service 

Washington Mt. Adams Wilderness USDA Forest Service 

Goat Rocks Wilderness USDA Forest Service 

Idaho Hells Canyon Wilderness USDA Forest Service 

California Lava Beds Wilderness USDI National Park Service 

Redwood National Park USDI National Park Service 

In all mandatory Class I areas, improvement in visibility must be made every 10 years for the 20 percent most 

impaired (haziest) days, regardless of current condition, and there must be no degradation for the 20 percent best 

(clearest) days, until the national visibility goal is reached in 2064. State and tribal implementation plans (SIPs 

and TIPs) outline how reasonable progress towards this goal will be achieved and demonstrated. Section 308 of 

the Regional Haze Rule provides nationally applicable provisions of the rule in the development of SIPs and TIPs. 

Environmental Consequences 

The PEIS estimated that up to 70,280 acres of BLM-managed lands may be treated with herbicides in Oregon 

annually26, and analyzed the resultant potential adverse effects from vehicle emissions and herbicide drift on air 

quality. That analysis made emissions estimates for carbon monoxide (CO), carbon dioxide (CO2

), nitrogen oxides 

(NOx

), total suspended particulates (TSP), particulate matter 10 microns and 2.5 microns in size (PM10 and PM2.5, 

respectively) and volatile organic compounds (VOCs). Lead, ozone and sulfur oxide emissions from herbicide use 

are very low and not included in the final analysis. Volatile organic compounds are substances emitted as gases 

from a variety of solid and liquid substances, including wildland fuels as they burn and herbicides. Effects are also 

described in terms of the Prevention of Significant Deterioration (PSD) criteria, although these criteria are intended 

for use on chronic point sources of pollution and not sporadic dispersed sources. 

Although non-herbicide treatments were analyzed, these were not included in the PEIS, but were available as a 

supporting report to the PER Annual Emissions Inventory for BLM Vegetation Treatment Methods (ENSR 2005a). 

This report also details the assumptions and analysis methods used. The emissions estimates include emissions from 

internal combustion engines used in both transportation and project implementation and fugitive dust from driving 

on unpaved roads and wind erosion. In Oregon, estimated total annual emissions in the PEIS included 5 tons of 

CO, 0.57 tons of NOx

, 28.77 tons of TSP, 6.97 tons of PM10, 0.99 tons of PM2.5, and 0.34 tons of VOCs from treating 

70,280 acres annually with herbicides. Carbon dioxide emissions from treating with herbicides are zero. 

26 Alternative 5 (which is equivalent to the PEIS preferred alternative), estimated Oregon herbicide use at 50,000 acres 

per year. The proposed action (Alternative 4) would treat 45,000 acres annually. 

140 
 

 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

This air quality analysis builds on the analysis conducted for the PEIS. That analysis estimated emissions arising 

from prescribed burning; exhaust from ground vehicles used for transportation and operations, exhaust from 

chainsaws, and fugitive dust from driving on unpaved roads and from wind erosion off disturbed soils. Exhaust 

emissions did not include that from aircraft (fixed wing airplanes and helicopters). Fugitive dust emissions did 

not include that arising from actual treatment operations, such as dust kicked up by mowers and bulldozers/ 

road bladers. 

Fugitive dust have not been included in any environmental analyses conducted to date in Oregon. In large 

part, this lack is because fugitive dust from roads or land management operations has not been identified as a 

significant concern or issue by members of the public, the EPA, or the Oregon Department of Environmental 

Quality. In large part, this lack of concern is because fugitive dust from driving on unpaved roads or from land 

management operations tends to remain in close proximity to the source. The distance particles are dispersed 

depends on both particle size, how high the particles are lofted, and wind speed. Most particles generated by soil 

are 10 microns and larger and are not lofted more than a few feet, limiting their dispersion potential. Most road 

dust, for example, lands within about 10 feet of the road. (In contrast, most particles from prescribed fire are 2.5 

microns and smaller and can be lofted hundreds to thousands of feet in the convection column, allowing for long 

distance and widespread dispersion of these particles). 

At present, the only form of carbon emissions that is regulated is CO. The PEIS includes CO2

 emissions as 

well from prescribed burning and from diesel exhaust. However, neither the PEIS nor this analysis includes a 

complete carbon budget. At present, the science is lacking to develop a complete carbon budget principally due 

to the lack of information on belowground carbon dynamics in all ecosystems and very limited information on 

aboveground carbon dynamics in rangeland ecosystems. Although carbon cannot be thoroughly analyzed, one 

of the known qualitative trade-offs are that activities that can restore healthy functioning ecosystems, including 

treatments to reduce invasive plants, tend to increase carbon sequestration (Verburg et al. 2004, Bradley et al. 

2006, Prater et al. 2006). This factor may be critical in rangeland ecosystems as conversion to annual grass 

dominance results in creation of a carbon source, while shrub-steppe vegetation is a carbon sink with more carbon 

stored below-ground than above. 

All alternatives cover only the emissions from activities covered in this environmental analysis. Emissions from 

prescribed burning are the primary contributor to air quality concerns. Emissions from biocontrol, livestock and 

seeding or planting are negligible and not included. Since the analysis is based on emissions estimates used in 

the PEIS to maintain consistency and comparability, emissions from prescribed fire, mechanical, manual and 

herbicide operations include emissions from exhaust and fugitive dust, albeit incomplete estimates (see discussion 

in Incomplete and Unavailable Information earlier in this Chapter). The emissions from exhaust and fugitive dust 

were included since it was not possible to remove these elements from the data provided in the PEIS and retaining 

the emissions would maintain comparability with the national estimates for Oregon. 

The potential air quality effects of the alternatives in this analysis were determined by calculating the tons per acre 

emissions for PM10, PM2.5, CO, CO2

, NOx, SO2, and VOCs from the selected alternative in the PEIS for prescribed 

fire, mechanical, manual, and herbicide treatments. Total suspended particulates were not included in this analysis 

as these differ very little from the PM10 estimates for smoke, the most significant contributor to particulate 

emissions. Lead was also not included as lead emissions were minor or zero for the various treatment methods. 

Total emissions by pollutant for each treatment method were divided by the acres in alternative B of the PEIS to 

estimate the tons per acre of emissions. For prescribed fire, only the values from eastern Oregon were used as 

these included less smoldering combustion. This result was then multiplied by the estimated acres on Table 3-3 

for prescribed fire, mechanical, manual and herbicide treatments in each alternative. 

141 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Effects Common to All Alternatives 

Fugitive dust from driving on unpaved roads is not expected to measurably alter air quality in mandatory Class I 

areas or in air quality non-attainment or maintenance areas. The potential toxic effects of spray drift are covered 

elsewhere in this document. Effects to air quality from herbicide treatments are somewhat less than the national 

estimate as fewer acres are treated under all alternatives than were estimated in the PEIS. The highest emissions 

from manual treatments are CO, which largely comes from the exhaust of transportation vehicles, although 

manual emissions are minor relative to prescribed burning and mechanical treatments. All alternatives include a 

mix of treatment methods that are dispersed throughout the year, although lowest in winter, and across the entire 

State. Given this dispersion in time and space, it is not possible to determine if any alternative could result in a 

violation of NAAQS. 

Prescribed burning, 80 to 97 percent of which would be in eastern Oregon in this analysis, would most likely take 

place in late summer or early fall so that the follow-up seeding would have the advantage of winter precipitation 

to enhance germination and establishment. Direct effects to air quality from burning annual grasses are of very 

short duration due to the lack of smoldering. Emissions are quickly dispersed and diluted, therefore, are not 

expected to impair visibility in any mandatory Class 1 areas. There is some potential for short-term (1-4 hours, 

depending on individual treatment unit size) adverse effects to the Klamath Falls and Lakeview air quality 

maintenance areas since both communities are located at or near the bottom of a basin where air flow out of the 

basin is restricted during inversions and on very cold days. Potential air quality effects will also be analyzed as 

part of project-specific environmental analysis and BLM policy requires that all prescribed fire burn plans address 

smoke management, regardless of location. Oregon State law prohibits the regulation of rangeland burning under 

the State smoke management rules; nonetheless, most BLM districts voluntarily comply with the Oregon Smoke 

Management Plan. 

Table 4-12 summarizes the expected emissions by alternative; these estimates are based on those in the PEIS. 

Alternative 3 has the highest emissions of all pollutants. In comparison with statewide emissions for Oregon 

from 2002, the latest year for which data are available (EPA 2007d), the particulate emissions for Alternative 3 are 

0.2% of the 2002 statewide emissions. Carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), and 

Volatile Organic Compound (VOCs) emissions in Alternative 3 are <0.1% of 2002 statewide emissions. All other 

alternatives would result in fewer emissions. No statewide data are available for carbon dioxide, however, the 

relative proportion is likely similar to the criteria pollutants. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

This alternative has the highest emissions from mechanical treatments, the lowest from prescribed fire, and 

no emissions from herbicide treatments. Particulate emissions are the second highest of all the alternatives. 

Particulate emissions are highest in the mechanical treatments largely due to fugitive dust and diesel exhaust. CO 

and CO2

 emissions are the lowest of all the alternatives. Prescribed burning is responsible for the bulk of the CO 

and CO2

 emissions, although diesel emissions under mechanical treatments account for nearly 500 tons per year 

of CO2

 emissions. Fewer acres are treated using prescribed fire than in the No Action alternative since prescribed 

fire for weed control is normally used in conjunction with some herbicide applications; if the herbicide is not 

used, there is no need to burn. Mechanical treatments partially replace some of the prescribed burning that would 

have occurred under the No Action alternative. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Table 4-12. emissions from vegeTaTion TreaTmenTs 

Emissions from herbicide treatment only 

Pollutant 

Total Emissions (tons) 

PEIS Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 

PM10 6.97 0 1.66 3.00 4.47 4.96 

PM2.5 0.99 0 0.24 0.43 0.64 0.70 

CO 5.00 0 1.11 2.02 3.00 3.33 

NO x 0.57 0 0.13 0.23 0.34 0.38 

VOCs 0.34 0 0.08 0.14 0.21 0.23 

Emissions from prescribed fire, mechanical and manual treatments 

Pollutant 

Total Emissions (tons) 

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 

PM10 936.46 884.48 981.78 378.42 378.42 

PM2.5 406.00 401.39 495.95 254.00 254.00 

CO 509.46 757.04 1,635.59 1,633.50 1,633.50 

CO2 12,312.90 18,660.42 40,392.59 40,058.75 40,058.75 

NO x 33.13 42.62 79.12 70.12 70.12 

SO2 6.99 10.22 21.47 20.87 20.87 

VOCs 46.65 66.86 141.90 141.17 141.17 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Emissions from this alternative provide the main baseline against which the other alternatives are compared. 

Prescribed burning is the main source of CO, CO2, NOx, SO2, and VOC emissions. Mechanical treatments are 

the main source of PM and PM emissions, largely due to mechanical treatments of road rights-of-way and 10 2.5

habitat improvement/ecosystem restoration treatments. Manual treatments and herbicide application result in few 

emissions of the pollutants analyzed. This level of emissions would continue if none of the action alternatives are 

selected. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

This alternative has the highest emissions of all pollutants analyzed. Under this alternative, the use of imazapic 

is expected to increase the use of prescribed fire by an estimated 6,800 acres. Prescribed fire would be used as 

preparation treatment, primarily in eastern Oregon, in a three-step treatment regimen for controlling invasive 

annual grasses. However, mechanical methods are still used to treat an estimated 9,300 acres of roadways and 

11,395 acres of other vegetation. As a result, emissions of particulate matter, CO and CO2

 are the highest due to 

the large increase in prescribed burning and only minor decreases in mechanical treatments over the No Action 

alternative. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

In this alternative, the number of acres treated using prescribed fire and manual methods are the same as 

in Alternative 3. However, the number of acres treated mechanically declines as herbicide treatments are 

substituted. As a result, the fugitive dust and exhaust-related emissions decline substantially, particularly PM10, 

PM , and CO relative to the emissions in Alternative 3. The emissions of PM and PM in this alternative 2.5 2 10 2.5

are the lowest of the five. Carbon monoxide, CO2, NOx, SO2, and VOC emissions are only slightly less than 

Alternative 3, largely because prescribed fire is the primary source of these pollutants. 

143 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

The effects of Alternative 5 are very similar to Alternative 4. Emissions are increased slightly over Alternative 

4 due to the inclusion of an additional 4900 acres of herbicide treatments for habitat improvement/ecosystem 

restoration. Otherwise, emissions from prescribed fire, mechanical and manual methods are the same as 

alternative 4. 

Soil Resources 

Affected Environment 

Soil is a dynamic medium consisting of varying levels of sand, silt and clay particles, organic matter, and 

soil organisms, both large and small (e.g. earthworms, bacteria and fungi). Soil functions to hold nitrogen, 

phosphorus, and herbicides in place, keep them out of surface water, and deliver nutrients and water to plants, 

as they need them. Soil filters, buffers, degrades, immobilizes, and detoxifies organic and inorganic materials, 

including herbicides, other manufactured products, and materials from atmospheric deposition (USDA 1997). 

Soil texture (the proportional amount of sand, silt, and clay constituents) and organic matter affect the movement 

of water and herbicides into and through a given soil. Coarser texture soils (those with high amounts of sand) 

allow faster movement of water into and through them compared to fine textured (clay) soils. Clay textured soils 

have higher rates of surface runoff than sandy soils. Silty or clay textured soils and those with high levels of 

organic matter have greater surface areas that can absorb and hold greater amounts of herbicides when compared 

to coarse textured soils. Organic matter and clay particles have different positive and negative charges (cation 

exchange capacity, CEC) that provide the adsorbing mechanism. The bond between the herbicide and particle can 

be lost if other mechanisms within the soil are great enough to break the bond. 

The USDA National Resources Conservation Service (NRCS) differentiates soils by diagnostic horizons27 (layers) 

or features that reflect soil-forming processes. On BLM lands in Oregon there are four major and five minor 

soil orders (Figure 4-5). Each of the biomes may contain several or all of the soil orders as a result of various 

combinations of local soil forming factors. The four major soil orders (based on abundance in Oregon) are:28 

Aridisols are soils found east of the Cascades (primarily in the Sagebrush Steppe biome) that have developed 

under low moisture regimes. Above ground vegetation is sparse; thus organic matter accumulations are low (less 

than 2 percent), and the ability of these soils to filter, store and process herbicides is limited to the upper soil 

layers. Herbicide degradation by sunlight (photo degradation) would be high but biological degradation would be 

low unless adequate moisture for processing by organisms was present. 

Mollisols are productive soils rich in organic matter from the dense root systems of prairie grasses. They cover 

27 Soil horizons, ordered from top to bottom include: the O horizon (organic matter); the A horizon (surface soil); the B 

horizon (subsoil); and, the C horizon (substratum). 

28 Soil Order Generalities for State of Oregon, summarized from USDA (1999) and USDA (2006a). Major/minor split 

based simply on abundance on BLM lands in Oregon. 

 144 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

much of the Eastern Forest and Sagebrush Steppe biomes and are also found in the Willamette Valley and 

Southern Siskiyou Mountains. Their origin from windblown or weathered basalt parent materials allows some 

to be prone to wind erosion if not stabilized by growing vegetation. Their high organic matter content (Table 

4-13) binds herbicides and provides degradation by soil organisms, helping reduce the risk of groundwater 

contamination. 

Inceptisols are generally young mineral soils with high infiltration rates and low amounts of clay. Herbicide 

transport to lower depths of soil and groundwater or streams would occur if it were not already tied to vegetation 

or organic matter at the surface. They often support coniferous and deciduous forests as well as rangeland 

vegetation, and are found primarily in the Western Forest and Willamette Valley biomes with a small percentage 

in the Siskiyou biome. 

Entisols occur in areas of recently deposited parent materials or in areas where erosion or deposition rates are 

faster than the rate of soil development, such as dunes, steep slopes, and flood plains. These soils are sandy in all 

layers, and are subject to wind erosion if vegetation is lacking. Most occur east of the Cascades. 

The five minor (less abundant) Soil Orders are: 

Ultisols support forest vegetation in the Willamette Valley and Siskiyou Biomes. They have properties that allow 

processing and storage of herbicides such as high amounts of clay, organic matter, and good drainage. 

Andisols formed on volcanic ejecta and have a high natural productivity. They are prominent in the Cascades with 

minor occurrence in the Blue Mountains. The ability of these soils to process (that is, to bind, degrade, and store) 

herbicides is high, as moisture, plant growth, and binding sites would be high in the silt portion of most soils. 

Vertisols have high clay content, pronounced changes in volume with moisture changes, cracks that open and 

close periodically, and evidence of soil movement. Vertisols are problematic for herbicide application due to the 

cracking and movement, but may bind herbicides due to high clay contents. 

Alfisols are developed in semiarid to moist areas where weathering has leached clay minerals and other 

constituents out of the surface layer and into the subsoil, where they can hold and supply moisture and nutrients to 

plants. 

Spodosols are soils with a B (subsoil) horizon consisting of an accumulation of black or reddish materials 

that have a high CEC, important for binding herbicides within the soil. These sandy soils have good drainage 

properties along with high organic matter contents that tend to bind and process herbicides well. These are found 

primarily on the forested coastal lands and beach areas of the BLM west of the Cascades. They are also the prime 

areas for growing cranberries on the coast. 

Organic Matter - On any soil, the amount of organic matter is key to maintaining structure, allowing water and air 

to infiltrate to low depths, and providing a source of energy to microbial communities. Many herbicides readily 

bind to organic matter. Organic matter levels greater than 2.5 to 3 percent may tie up soil-applied herbicides prior 

to them being delivered to the plant. Some labels recommend increasing the amount of herbicide to the maximum 

rate in these situations. Soil orders found in the west side of the State, such as Inceptisols, Spodosols and Ultisols, 

contain considerably more organic matter than the Mollisols or Aridisols of the east side. 

145 
figUre 4-5. maP of soil orders 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Table 4-13. soil order ProPerTies and exTenT on blm lands 

Soil Order 

Estimated Acres on 

BLM lands

 (% of total) 

Average 

Percent 

Organic 

Matter1 

Average 

Percent 

Clay1 

Average T 

Factor 

(Tons/Ac/Yr 

of Soil Loss 

Allowed) 

Average Wind 

Erosion Group 

Rating 

(1= High, 8=Low 3) 

Range { } 

Average 

Water 

Erosion 

Risk Rating 

KFactor 

(L<M<H) 

Average pH 

value (range) 

Major Orders 

Aridisols 6,913,000 (43.9) 1.67 18.2 2.7 (1-5) 5.59 {0-8} .31 (M) 7.47 (6.8 – 8.5) 

Mollisols 5,051,000 (32.1) 2.92 21.0 2.9 (1-5) 6.46 {1-8} .25 (M) 6.86 (5.4 – 9.0) 

Inceptisols 1,401,000 (8.9) 6.14 21.7 3.0 (2-5) 6.8 {4.1-8} .22 (M) 5.88 (4.5 – 8.8) 

Entisols 1,055,000 (6.7) 2.23 18.5 4.4 (2-5) 4.95 {3-8} .31 (M) 7.63 (5.1 – 9.0) 

Minor Orders 

Ultisols 523,000 (3.3) 4.68 27.7 3.5 (2-5) 6.88 {6-8} .26 (M) 5.66 (5.4 – 6.4) 

Andisols 297,000 (1.9) 6.04 16.9 3.0 (2-5) 5.69 {2-7} .22 (M) 5.72 (4.4 – 7.3) 

Vertisols 181,000 (1.1) 5.62 34.1 4.6 (2-5) 7.68 {6-8} .23 (M) 7.05 (6.5 – 7.6) 

Alfisols 66,000 (0.4) 3.37 15.6 3.3 (3-5) 4.85 {3-7} .18 (L) 6.02 (5.9 – 7.0) 

Spodosols 12,000 (0.1) 7.28 14.8 4.8 (3-5) 6.2 {6-8} .30 (M) 5.06 (5.0 – 5.2) 

Unknown 233,000 (1.5) -­ -­ -­ -­ -­

1 Average Organic Material and Clay contents derived from A horizon for all soils within the order, not the entire profile 

2 TFactor: Tolerable amount of soil loss (tons per acre per year) prior to reduced productivity
 3 Wind Erosion Groups rate the tons per acre soil loss potential for wind erosion on 70 percent-plus unvegetated soil. Ratings are: 1 = 160-310 per tons/
 

acre/year; 2 = 134 tons; 3 and 4= 86 tons; 5 = 56 tons, 6 = 48 tons; 7 = 38 tons; and, 8=0 tons (USDA 1999a)
 4 KFactor Erosion Risk Rating: Low- .05 to .2, Med .21 to .40, Hi .41+. Erosion factor K appears in the Universal Soil Loss Equation (Wischmeier and 

Smith 1978) as a relative index of susceptibility of bare, cultivated soil to particle detachment and transport by rainfall.
 

(Data derived from USDA 2009a) 

Clay has more surface area per volume and provides binding sites for herbicides and water, supporting herbicide 

breakdown by micro-organisms (see below). However, as the percentage of clay in a given soil increases the 

potential for compaction and increased runoff also increases. If the soil becomes nearly all clay, as in the case of 

Vertisols, seasonal drying and wetting can produce wide deep cracks in the soil and herbicides can end up going 

deep into the soil and not necessarily on the weeds they are intended to remove. 

Erosion Risk - Soils are rated by NRCS for a tolerable amount of loss before productivity is reduced. For 

example, Aridisols and Mollisols can lose less than 3 tons of soil per acre per year before their long-term 

productivity would be reduced (see T-Factor, Table 4-13). At the same time, these soils have fairly low wind 

erosion rates (5.5 to 6.5 tons/ac/yr) if 70 percent of their surface becomes exposed. Since many invasive weeds 

provide poor soil cover, and weed treatments (particularly prescribed fire or the use of persistent pre-emergent 

herbicides) can leave soils exposed, the NRCS rating provides an indicator of certain types of risks. In addition 

to the potential for productivity loss through wind or raindrop erosion, erosion can move herbicides off site if they 

are attached to soil particles. 

Biological Crusts provide important functions within, and on the surface of, the soil, such as improving soil 

stability and reducing erosion, fixing atmospheric nitrogen, and contributing nutrients for plants. Crusts are made 

up of organisms living at the surface of soils in semiarid and arid environments such as those in the Sagebrush 

Steppe and Eastern Forest biomes. The major components of the crust are cyanobacteria, green algae, microfungi, 

mosses, liverworts, and lichens. These crusts can cover up to 70 percent of the soil spaces not occupied by 

vascular plants in arid regions. The Aridisols have this important soil covering and protection mechanism. 

147 
 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Macro and Micro-Organisms are extremely important to proper functioning soil processes. Fungi and bacteria 

micro-organisms convert complex organic compounds (including herbicides) into simpler ones that can be used 

by other plants and organisms for growth. The macro-organisms such as insects, worms, arthropods, and even 

burrowing animals mix the upper organic matter into the lower soil level for processing by the micro-organisms 

found between soil particles. Soil temperature, moisture levels, and type of vegetation all affect the presence and 

activity of soil organisms (USDA 2004). 

Environmental Consequences 

Soil has the capacity to filter, buffer, degrade, immobilize, and detoxify herbicides. Soil properties that 

specifically bind herbicides or water to surfaces of the soil or organic matter are crucial to the soil’s ability to 

detoxify herbicides. The three most important soil properties are soil clay content, organic matter content, and 

the acidic or alkaline nature (pH) of the soil. These govern the ability of a soil to provide an environment for 

organisms and water to filter, buffer, degrade, or otherwise store or breakdown the various herbicides. Changes to 

soil properties because of non-herbicide or herbicide treatments, or noxious weeds, is considered an adverse effect 

on soil function. 

Effects Common to All Alternatives 

Biological Crusts - Disturbance of soil crusts results in decreased soil organism diversity, nutrient cycling, soil 

stability, and organic matter. Crust disturbance can come about through trampling, fire, or burial by windblown 

soil. Invasive weeds generally establish themselves on the areas where crusts have been broken and soil is 

exposed, either by mechanical or animal disturbance or possibly an erosional event that buries them. It is possible 

that some29 herbicides could reduce the individual components of the crust and thus affect their ability to function 

as soil protection and cycling mechanisms. 

Macro and Micro-Organisms - Herbicides probably affect few soil organisms directly (USDA 2004). However, 

there is only limited research on the toxicity of many herbicides to most soil organisms. Of the 18 herbicides 

proposed for use in one or more of the alternatives, four (chlorsulfuron, picloram, metsulfuron methyl and 

tebuthiuron) have some effect on soil organisms, generally reducing but not eliminating local populations for a 

limited period of time30. Eight herbicides (2,4,D, clopyralid, dicamba, diuron, fluridone, glyphosate, sulfometuron 

methyl, and triclopyr) have no or slight adverse effect on soil organisms, with some showing increases after 

herbicide treatments. There are no known studies for effects from imazapic to soil organisms. Very little if any 

study of soil organisms has been conducted on six herbicides (bromacil, diflufenzopyr, diquat, hexazinone, and 

imazapyr). Of the studies that have been conducted, effects have been demonstrated but at application rates many 

times higher than the typical rates proposed for use on Oregon BLM lands, or the decrease in soil organisms is 

temporary. Populations have increased in some situations. 

If herbicides reduce macro and micro-organism, herbicides will persist in the soil longer as other means (e.g. 

29 Various studies have been done on individual algae species present in soil crusts; however, only a handful of the studies 

focused on herbicides that the BLM is proposing, and of those, results were variable. Positive, neutral, and negative 

effects were attributed to 2,4-D; positive and negative effects were attributed to diuron and diquat; neutral and negative 

effects were attributed to picloram; negative effects were attributed to bromacil; and, positive effects were attributed to 

2,4-D + picloram (Metting 1981). Metting cites several authors in who caution against extrapolating this information to 

the field. 

30 This lasts for anywhere from a few days to three weeks. Population levels can be reduced for up to two months if rates 

exceed typical field application rate or if coupled with secondary applications of a second herbicide. 

 148 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

hydrolysis) may become the primary breakdown mechanism. Also, if noxious weeds have changed the soil 

chemical or moisture contents in a manner that changes the variety or overall amount of these organisms, 

herbicide persistence may be extended. Finally, disturbance from mechanical treatments or animal traffic 

particularly on wet soils, could compact the surface layer to a point that these organisms would lose their ability to 

degrade the applied herbicides. 

Erosion and Compaction are closely related. Compaction decreases soil pore space and increases soil density, 

decreasing productivity and reducing the ability of the soil to infiltrate water. Without the infiltration of water into 

the soil, soil organisms or water bound to soil particles cannot interact with the herbicides to break them down. 

Decreased infiltration means more water running across the surface, eroding soils (particularly those particles 

loosened by raindrop impact) and potentially moving herbicides off site. Traffic on the surface, be it wheeled 

or tracked vehicles, animals, or human feet can cause compaction as well as disturbance of the soil. Bare or 

compacted soils can be colonized by noxious weeds more readily than native plants, as weeds tend to be more 

adapted to establishing on such altered sites. 

Vegetation is the most significant factor in controlling erosion because it intercepts precipitation, reduces rainfall 

impact, restricts overland flow, and improves infiltration. Noxious weed infestations have been shown to increase 

soil erosion in comparison to soil occupied by native grass species (Lacey et al. 1989). Weeds have less capacity 

to dissipate the kinetic energy of rainfall, overland flow, and wind that causes soil erosion, when compared to the 

native species on the site (Torri and Borelli 2000, Fryrear 2000). 

East of the Cascades, wind is the primary element of erosion. Wind can remove soil particles under certain 

conditions of low vegetative cover, dry soil, high percentage of fine clays, and sufficient wind velocity. While 

wind erosion on rangelands is difficult to quantify, the presence of natural vegetation and soil crusts on most 

rangelands is generally sufficient to keep wind erosion from becoming a serious problem. Erosion selectively 

removes organic matter and the finer-sized soil particles that store nutrients for plant use, leaving behind soil 

with a reduced capacity to supply nutrients (Brady and Weil 1999). Herbicides bound to soil particles can be 

transported off-site by blowing soils, negatively affecting non-target areas. 

Parameters that Affect the Fate of Herbicides in Soils – The ability of soils to hold and breakdown herbicides 

is affected by soil biological processes (organisms and plant uptake), physical parameters (adsorption, photo 

degradation, volatilization, hydrolysis, and leaching), and physical parameters (climate and vegetation cover). 

Characteristics of the 18 herbicides that influence the effectiveness of these parameters and processes are shown 

on Tables 4-14 and 3-1. 

The rate at which a herbicide degrades is expressed as the half-life. The half-life is the amount of time it takes 

for half of the herbicide to be converted into other chemical components, or its concentration is half of its initial 

level. The half-life of an herbicide can be affected by its formulation, soil type, and environmental conditions 

(e.g., temperature, moisture). The fate of the herbicide before it degrades is affected by plant uptake, soil 

sorption, leaching, and volatilization. 

Plant uptake is outside the scope of this discussion (see the Vegetation, Native Plants, and Plant Communities 

section earlier in this Chapter) and volatilization occurs when the herbicide releases into the air. Leaching is 

caused by movement in water, which is effected by how tightly the herbicide is bound to the soil particles. 

Herbicides degrade or break down into elements such as carbon, oxygen, hydrogen, and nitrogen. Some may 

form intermediate compounds. On the plant or soil surface, primary breakdown is by photolysis or volatilization. 

In the soil, micro-organisms metabolize the herbicide, it is broken down by water (hydrolysis), or it is moved 

through the soil in water-leaching. 

149 
 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The ability of a soil to bind to an herbicide (while it breaks down) is based on its adsorption affinity. Herbicides vary 

in how tightly they are adsorbed to soil particles. K oc measures the affinity for herbicides to “sorb” to organic carbon. 

The higher the Koc value, the stronger the tendency for the herbicide to attach to, and potentially move with, the soil. 

The K value listed in the table below is a measure of the number of milliliters of the individual herbicide that can oc 

be bound by one gram of organic matter. Herbicide K oc values greater than 1,000 ml/g indicate strong adsorption to 

soil whereas low K oc values (less than 500) tend to allow movement with water more so than movement adsorbed to 

sediment. Off-site movement is also affected by the formulation of the herbicide, soil properties, rate and method of 

application, frequency and timing of rainfall or irrigation, and depth to ground water. 

Herbicides can be either selective or non-selective. Selective herbicides remove only specified types of plants 

such as broadleaf, grasses, or a subset of those. Spot treatments with any herbicide, or broadcast treatments using 

selective herbicides, will retain some degree of cover and root masses on the site, reducing or preventing the 

potential for surface erosion. Herbicides can also be applied directly to the soil, usually decreasing the risk of 

drift (when compared with foliar sprays) and more quickly binding the herbicide to soil particles. Generally, the 

soil-applied herbicides included in this EIS are relatively persistent. They are applied before vegetation sprouts 

out of the ground (a pre-emergent herbicide), 

Soil/herbicide interaction parameters are included on Table 4-14 as well, and are described in the table footnotes. 

Additional Information about the Fate and Effects of Herbicides 

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 slower in acidic soils. Temperature affects degradation as well, with slower bread-down 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 micro-organisms 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 micro-organisms (Bovey 2001). 

Bromacil is a applied to soil where it binds, or adsorbs, only slightly to soil particles, is soluble in water, and is 

moderately to highly persistent. Its half-life is about 60 days, but may be as much as 8 months in aerobic soils 

(Wauchope et al. 1992). Soil persistence is longer in soils with high organic matter (National Library of Medicine 

2002, Extoxnet 1993). Leaching is dependent on the soil type and the amount of rainfall or irrigation water. The 

potential for bromacil to leach and contaminate groundwater is greatest in sandy soils. In normal soils, it can 

be expected to leach to a depth of 2 to 3 feet (National Library of Medicine 2002). There is limited research on 

the toxicity to most soil organisms. However, one soil bacterial isolate that can biodegrade bromacil has been 

identified (Chaudhry and Cortez 1988). 

Chlorsulfuron degrades in acidic soil by hydrolysis, but is relatively stable in neutral soil. As with most 

biodegradation rates, the higher the ph, the slower the herbicide breaks down. The higher the temperature, soil 

moisture organic matter content and microbial biomass, the faster it breaks down. Chlorsulfuron is only mildly 

toxic to terrestrial micro-organisms and effects are short term (transient) (SERA 2004a). 

The herbicide can remain active for more than a year. Sarmah et al. (1999) observed that the rate of chlorsulfuron 

degradation in alkaline subsoils was slow. They concluded that under conditions conducive to leaching in alkaline 

 150 
 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Table 4-14. selecTed cHaracTerisTics THaT affecT THe faTe of Herbicides in soils 

Herbicide Half-life in 

Soils (days) 

Fate in Soils 

(Persistence Rating2

 based on half-life) 

2,4-D 10 Rapid microbial degradation 1-4 weeks (Not Persistent) 

Bromacil 60 but may 

be up to 240 

Degrades with biological activity in anaerobic soil but slow in aerobic soil (Moderately to 

Persistent) 

Chlorsulfuron 40 Relatively rapid degradation by microbial and chemical actions, trace amounts have extreme 

bioactivity (Moderately Persistent) 

Clopyralid 40 Biodegradation is rapid in soil, reducing the potential for leaching or runoff. Possible release 

herbicide from decaying plants with uptake by other plants(Moderately persistent) 

Dicamba 14 Mobile in soil but easily degraded bymicrobes(Non-Persistent) 

Diflufenzopyr 2 to 14 Biodegradation, photolysis, and hydrolysis are the primary mechanisms that remove diflufenzopyr 

(Non-Persistent) 

Diquat 1,000 Quickly and irreversibly adsorbed to soil colloids, thus no soil activity(Very Persistent) 

Diuron 90 Microbial degradation generally only one season (Moderately Persistent) 

Fluridone 21 Adsorption increases with clay content, organic matter, cation exchange capacity, and decreasing 

pH (Non-Persistent) 

Glyphosate 47 Tightly adsorbed and rapidly degraded by microbes, thus no soil activity (Moderately Persistent) 

Hexazinone 90 Organic matter does not affect adsorption. Relatively low affinity for soil particles, dissolves in 

soil water. Bio-degradation is an importation fate (Moderate to Persistent) 

Imazapic 120 to 140 Primarily bio-degradation. Sorption to soil increases with decreasing pH and increasing organic 

matter and clay content (Persistent) 

Imazapyr 25 to 141 Adsorption is affected by aluminum and iron in soil more than by clay and organic matter, subject 

to microbial degradation except in cool temperatures (Moderate to Persistent) 

Metsulfuron 

methyl 30 Hydrolysis and microbial degradation, with the latter being the only major pathway in alkaline soils (Non-Persistent) 

Picloram 20-300 Very slow microbial degradation and some photolysis. Persistent for a year or more (Moderate to 

Persistent) 

Sulfometuron 

methyl 20 Relatively rapid microbial and chemical degradation. Trace amounts have extreme bioactivity 

(Non-Persistent) 

Tebuthiuron 360 Microbial degradation (Very Persistent) 

Triclopyr 46 Degradation primarily through microbial metabolism, photolysis, and hydrolysis. As plants die, 

release of triclopyr can occur and can then be taken up by other plants. (Moderately Persistent) 

1 K oc: Soil organic carbon sorption coefficient of an active ingredient in mL/g. For a given chemical, the greater the Koc value, the less soluble the chemical 

is in water and the higher affinity the chemical has for soil organic carbon. For most chemicals, a higher affinity for soil organic carbon (greater Koc) 

results in less mobility in soil 

2 Persistence based on half-life in soils, 3 categories: non persistent -- less than 30 days; moderately persistent -- 30 to 100 days; and persistent -- greater 

than 100 days (Extoxnet PIP) 

3 SPISP II = Soil Pesticide Interaction Screening Procedure version II, which is a NRCS model that calculates leaching potential from basic soil properties 

(USDA 1994b). 

4 PLP - Pesticide Leaching Potential indicates the tendency of a pesticide to move in solution with water and leach below the root zone. A low rating 

indicates minimal movement and no need for mitigation. PLP is calculated according to a WIN-PST algorithm, and then the resulting rating is adjusted 

for type of spraying being conducted. 

5 PSRP - Pesticide Solution Runoff Potential indicates the tendency of a pesticide to move in surface runoff in the solution phase. A rating as calculated 

according to a WIN-PST algorithm indicates the potential for pesticide loss in solution runoff. Ratings are adjusted according to type of spraying being 

conducted. 

6 PARP - Pesticide Adsorbed Runoff Potential indicates the tendency of a pesticide to move in surface runoff attached to soil particles. A rating as 

calculated according to a WIN-PST algorithm indicates potential for pesticide movement adsorbed to sediment. Ratings are adjusted according to type of 

spraying being conducted. 

Data source: Vogue et al. (1994), USDA (1997), Wauchope et al. (1992) 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

systems, prolonged persistence of chlorsulfuron in the soil profile is possible. It is likely that in some soils 

dissipation rates could be slower than the reported average, including arid soils with high pH and low organic 

matter. Such longevity could occur on the slightly (pH 7.4-7.9) and moderately (pH 7.9- 9.4) alkaline soils within 

the Aridisols, Mollisols, Inceptisols and Entisols soil orders. 

Clopyralid is unstable in soil and is considered moderately persistent based on its half-life. It will leach under 

favorable conditions such as 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. 

Diuron is a highly persistent herbicide with low to moderate mobility in soil, depending upon the level of organic 

matter available for it to adhere to. Decomposition is principally through biodegradation and occurs in both 

anaerobic and aerobic conditions. As degradation occurs, the breakdown product 3,4-DCA also persists and 

exhibits higher toxicity to some receptors31. Waterfleas are negatively affected but it is unknown if it affects soil 

crustaceans. Bacteria and fungi have been found to degrade this herbicide and population levels within the soil 

may increase. Thus, effects to them may be positively correlated. One study found adverse effects on bacteria 

diversity at concentrations of 25 mg/L and diversity seemed to decrease in soil treated with diuron (Giacomazzi 

and Cochet 2004). 

Dicamba is moderately persistent in soil. The half-life of dicamba in soil is typically 1 to 4 weeks. Under 

conditions suitable for rapid metabolism, the half-life is less than 2 weeks. Metabolism by soil micro-organisms 

is the major pathway of loss under most soil conditions. The rate of biodegradation increases with temperature 

and increasing soil moisture, and tends to be faster when soil is slightly acidic. When soil moisture increases 

above 50 percent, the rate of biodegradation declines. Dicamba slowly breaks down in sunlight. Volatilization 

from soil surfaces is probably not significant, but some volatilization may occur from plant surfaces. It is stable 

to water and other chemicals in the soil. Dicamba does not bind to soil particles and is highly soluble in water. It 

is therefore highly mobile in the soil and may contaminate groundwater. In humid areas, dicamba will be leached 

from the soil in 3-12 weeks (Howard 1991). The breakdown product is 3,6-dichlorosalicylic acid that is adsorbed 

strongly to soils but is moderately toxic to earthworms (IUPAC 2009). 

Diflufenzopyr - Biodegradation, photo-degradation, and hydrolysis are the primary mechanisms that remove 

diflufenzopyr from soil. It is not considered persistent. Diflufenzopyr appears to be soluble enough that transport 

in surface runoff is possible, especially in neutral to alkaline soils. 

Diquat is readily adsorbed to clay soil surfaces, becoming effectively immobilized by soils with high clay content. 

Diquat is resistant to anaerobic and aerobic biodegradation, possibly in part because it adsorbs so well to soil 

particles. It is considered a highly persistent herbicide with a half-life of 3 years or longer. 

Fluridone adsorption to soil increases with clay content, organic matter content, cation exchange capacity, surface 

area of sediment particles within the water column, and decreasing pH. Fluridone can persist on dry soils longer and 

may last up to a year, making it a moderately persistent herbicide. Volatilization can occur slowly on wet soils but 

not dry ones. No toxicity to earthworms was found when tested with rates up to 1,000 times the typical use rate. 

Glyphosate binds tightly to soil particles. This binding increases with increasing clay content, organic matter and 

decreasing soil pH. Glyphosate is biodegraded by soil organisms and many use it as a source of carbon. There is 

little information indicating that it is harmful to soil micro-organisms and may benefit some (Busse et al. 2004). 

31 An ecological entity such as a human, fish, plant, or slug. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Hexazinone has a low affinity for soil particles and dissolves in soil water. It has a low to moderate persistence 

based on a 90-day half-life. Soil organic matter does not affect adsorption. Soil organisms do not appear to 

be affected by hexazinone (based on soil respiration and nitrogen cycles) when applied at the recommended 

application rate, and the capacity for beneficial mycorrhizal fungi to infect conifer seedling was unaffected (Busse 

et al. 2004). 

Imazapic is moderately persistent in soils and has not been found to move laterally with surface water. Most 

imazapic is lost through biodegradation. Sorption to soil increases with decreasing pH and increasing organic 

matter and clay content. Little is known concerning the effects of imazapic on soil organisms or processes. 

Imazapyr does not readily bind to mineral soils, but is likely to bind relatively strongly to organic soil. Imazapyr 

may persist in soil for a prolonged period in relatively arid regions, and does not bind tightly to alkaline soils with 

low organic matter. Thus, the potential for longer-term effects on soil organisms exists but little is known if the 

effects would be positive or not. (SERA 2004d). Imazapyr can “leak” from treated plants into the soil, where it 

remains active and can kill non-target plants (Tu et al. 2001). 

Metsulfuron methyl has the principal modes of degradation of hydrolysis and microbial degradation, with the 

latter being the only major pathway in alkaline soils (Sarmah et al. 1998). Degradation rates are affected by soil 

temperature, moisture content, and soil pH. The herbicide will degrade faster under acidic conditions, and in 

soils with higher moisture content and higher temperature (Meister 1992). Half-lives in acidic or neutral soils 

vary from 5 to 190 days (Sarmah and Sabadie 2002, SERA 2004e). In alkaline soils, adsorption is very low and 

leaching potential is high. This is likely to result in increased persistence in alkaline soils such as the Aridisols, 

Mollisols or Entisols. 

At surface application rates of 0.04 to 0.067 lb/ac (between typical and maximum rates), decreases in soil 

bacteria were apparent for 3 days but reversed completely after 9 days. Biodegradation of metsulfuron methyl 

increased as soil moisture increased from 20 percent to 80 percent of field capacity, and half-life increased when 

temperature was raised from 20° to 30°C (Ismail and Azlizan 2002). 

Picloram is broken down primarily through photolysis and biodegradation mechanisms of dissipation (USDA 

2000b). Picloram adsorbs to clay particles and organic matter, but if the soil contains little clay or organic matter, 

picloram is easily moved by water. Picloram has been reported to remain active in soil at levels toxic to some 

plants for more than 1 year at typical application rates (SERA 2003b). The half-life of picloram in soil is reported 

to vary from 1 month under favorable environmental conditions to more than 4 years in arid regions (USDA 

2000b). Picloram can be persistent in plants. When plant parts containing picloram degrade, they may release it 

into the soil, where it can kill other plants. 

The persistence of picloram in soil is dependent on soil moisture and temperature; warm and moist soils degrade 

this herbicide readily. Picloram dissipates most slowly when soils are alkaline, fine textured, and low in organic 

matter. Picloram degrades more rapidly under anaerobic than aerobic conditions and at lower application rates 

(USDA 2000b). There does not appear to be a defined threshold for picloram toxicity to soil micro-organisms 

(SERA 2003b). 

Sulfometuron methyl is broken down through hydrolysis and biodegradation. The half-life is short; the herbicide 

has a low persistence in the soil. It moves readily though coarse textured soils such as sand and sandy loams. Little 

is known about the effects to soil organisms; however, Busse et al. (2004) demonstrated that this herbicide does not 

alter the capability of mycorrhizal fungi to infect roots even at concentration detrimental to seedling growth. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Triclopyr is manufactured in two forms: a triethyamine salt (TEA) and a butoxyethyl ester (BEE). Both forms 

degrade to triclopyr acid in soil. Degradation occurs primarily through microbial metabolism, but photolysis 

and hydrolysis can be important. Therefore, in general, moist soils with high organic matter content support the 

highest rates of metabolism. Johnson et al. (1995) found that microbial degradation of triclopyr was significantly 

higher in moist versus dry soils, and at 30oC versus 15oC. 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). Triclopyr can be persistent in plants and when they 

die, release of triclopyr can kill other plants. 

Tebuthiuron is resistant to abiotic degradation and biodegradation. Its field half-life ranges from 2 weeks to over 

33 months making it a highly persistent herbicide. It has a low adsorption affinity to soil, with some adsorption 

occurring as organic matter and clay content increase. It is mobile in soil and has been detected in groundwater. 

Soil organisms (mycorrhizal spore density) have been reduced initially after applications in Utah under a soft 

brome vegetation type (Allen and West 1993). However, Mostafa and Helling (2003) found no affect to such 

spores 6 months after herbicide application. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

Under Alternative 1, weeds on approximately 42,000 acres would be controlled through manual and mechanical 

means, with prescribed fire, directed livestock, biocontrol, and seeding and planting the methods of choice. All 

but biocontrol can be mildly to intensively site disturbing. Site productivity would be reduced where erosion 

and compaction occur, particularly on the Vertisols, Ultisols, and Inceptisols. Wind erosion on excessively bared 

soil orders that have low T Factor ratings such as the Aridisols and Mollisols could result in the loss of valuable 

surface nutrients, organic matter, and overall productivity. The bare soil would also be prone to re-colonization 

from remaining seed or nearby weeds not eliminated by the treatment. 

Directed livestock (three times higher under this alternatives than under any other), and mechanical treatments 

(1,600 to 2,000 acres higher than other alternatives) can compact the soil where repeated passes of machines and 

animals occur on overly moist or wet soils (e.g. the wetter riparian areas, upslope early in the spring, or immediately 

after intense thunderstorms). As discussed earlier in this section, compaction directly degrades soils, inhibits plant 

growth, and decreased infiltration which leads to overland water flow and related erosion. Not all mechanical 

treatments would expose soil to erosion processes; chainsaw use is included in these acres for example. 

The use of fire as a treatment method is expected to be reduced by 2,000 acres (35 percent) compared to the Noaction Alternative, which would reduce the number of burned acres. However, without follow-up herbicides, 

success of subsequent seeding will be variable and weed effects to soils could continue. Adverse soil effects 

directly from the burning would be limited, as controlled burning of weed sites is normally done at lower 

intensities than most wildfires. Lower intensity fires leave more of the existing organic matter in place and avoid 

deep heating of the soil that may kill micro-organisms and reduce site productivity. 

Fewer weed acres would be treated under this alternative, and it is predicted that treatments under this alternative 

would be 30 percent effective. Implications to soils include the need to retreat about 70 percent of treatment 

areas, compounding adverse effects of treatments, and weeds would spread at a faster than current rate. Noxious 

weed spread is projected to increase at 14 percent per year under this alternative, and infest 2.7 million more acres 

in 15 years than under Alternative 2 (Table 4-4 in the Noxious Weeds and Other Invasive Plants section in this 

Chapter). On these acres, invasive plants would continue to alter vegetation types and organic matter levels (both 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

on and within the soil). Weeds can out-compete native vegetation and lead to increased soil exposure; resultant 

increased erosion would remove soil and nutrients. Changes to the type and abundance of various soil microorganisms because of lower organic matter contents would be expected to hinder processing and storage of water 

or cycling organic matter into nutrients for plant growth. Weeds can out-compete native species in part because 

they have high nutrient uptake rates and can deplete soil nutrients to very low levels, especially in cases where 

weed species initiate spring growth prior to native species and exploit nutrient and water resources before native 

species are actively growing (Olson 1999).32 Any of these changes would result in less productive lands for native 

vegetation and reduce the potential for restoring the original vegetation community, often permanently. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Under this alternative, noxious weeds would be treated on approximately 45,500 acres; 16,700 acres (37 percent) 

with herbicides. The acres treated with herbicides would reduce the number of acres treated by directed livestock, 

mechanical, or manual removal, but not by use of fire, in comparison to Alternative 1. The lowered level of 

disturbance would benefit soils; reducing soil disturbance would reduce adverse effects to soil functions when 

compared with Alternative 1. 

Treatments baring soils could result in wind and rain erosion. However, the vast majority (93 percent) of 

treatments between 2000 and 2007 have been applied with ground-based equipment or with the use of backpack 

sprayers, trucks, or ATVs off road. These traditionally have been spot treatments that do not completely remove 

vegetation from extensive areas at any one time. Even the remaining 7 percent that has been applied aerially 

is usually done with selective herbicides designed to retain the native plant component of the infested area, 

providing some protection from either wind or rain erosion. 

Picloram has a 90 day half life (Table 4-14), but may remain active in soil at levels toxic to some broadleaf plants 

for about one year at typical application rates (Extoxnet PIP). 2,4-D, dicamba, and glyphosate have half-lives 

between 10 and 50 days in the soil. Picloram is the only herbicide under this alternative that is documented 

to effect soil organisms in a negative way (USDA 2005:4-110). 2,4-D may increase bacteria that degrade the 

herbicide (Oh and Tuovinen 1991cited in Tu et al. 2001). Busse et al. (2004) determined that both direct and 

indirect soil microbial characteristics in the top 4 inches of soil were generally unchanged after 9 to 13 years of 

continuous vegetation control by glyphosate. Thus, soil quality would not be degraded using these herbicides to 

control noxious weeds under this alternative. 

The highest risk of herbicide movement under this alternative would be for dicamba or picloram used on Alfisols, 

Entisols, Spodosols and Andisols or other orders with sandy soil textures or low amounts of organic matter. 

Under these conditions, these herbicides are easily moved by water both laterally and vertically through surface 

runoff or leaching respectively. It is generally accepted that 2,4-D is rapidly inactivated in moist soil; however, its 

persistence is largely dependent on pH. 

The use of prescribed fire for weed control would increase 2,000 acres compared to Alternative 1, increasing the 

erosion risk for temporarily bared soils. Follow-up use of glyphosate33 could extend the time the soil would be 

bare, increasing the risk of erosion, notably from wind since these treatments are generally done on porous soils 

on gentle terrain east of the Cascades. 

32 For example, leafy spurge displaces native vegetation in prairie habitats through shading and usurping available water and nutrients. 

Leafy spurge also secretes toxins that prevent the growth of other plants near it. Once present, this aggressive invader can completely 

overtake large areas of open land. 

33 Glyphosate can be effective on some annual grasses, but PEIS Mitigation Measures limits use on rangeland to spot treatments. 

155 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

This alternative is projected to result in about 5.8 million acres, or one-third, of the BLM lands in Oregon 

being infested with noxious weeds in 15 years, and at least an additional five million acres being infested with 

cheatgrass. The negative effects of these weeds to soils (see Alternative 1) would far exceed the negative effects 

likely from any of the weed control treatments envisioned under this alternative. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Adverse effects from herbicides proposed for Alternative 3 are expected to be slightly more than or equal to 

those from the four herbicides in Alternative 2; applied pounds of herbicide would be down 30 to 50 percent and 

available herbicides include herbicides that are less toxic to slightly toxic to soil organisms. Any additional risk 

would be related to herbicides with the longest persistence rate or herbicides that can become mobile after use. 

The proposed 11,500 acres of imazapic and 1,500 acres of imazapyr may adversely affect soil functions compared 

to herbicides used in Alternative 2, because of their unknown impact to soil organisms, their mobility, and their 

ability to release from plant material and kill other vegetation. Imazapic on medusahead has an advantage over 

the currently used glyphosate, because it is more selective for invasive annual grasses, thus retaining remaining 

ground cover of shrubs and perennial annual grasses that help protect soils. 

West of the Cascades, a minor reduction (100-300 acres) in mechanical and fire treatments will occur in this 

alternative when compared to Alternative 2. Planting treatments increase by 100 acres and manual treatments 

remain the same. Thus, no change in risk between Alternatives 2 and 3 is expected. 

East of the Cascades, the 7,000-acre increase in prescribed fire under this alternative, when compared to the No 

Action Alternative, would increase the risk of wind and water erosion until these areas supported vegetation 

capable of anchoring the top surface of the soil from the effects of wind and water removal (one to two growing 

seasons). Using mechanical means (range drills) for a portion of the additional 5,000 acres seeding or planting 

would increase soil disturbance as well. However, this increase would be minor as soil SOPs and PEIS Mitigation 

Measures would minimize adverse effects of soil disturbance. If aerial seeding is used, that increased risk of soil 

disturbance would not occur (although aerial seeding may not be as effective). 

The projected reduction of weed-infested acres by 1.9 million acres in 15 years compared to the No-Action 

Alternative would provide benefits to soils that would more than offset the soils risks described here. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Effects described for Alternative 3 also apply to this alternative with the following exceptions. Herbicide treated 

acres would increase about 50 percent when compared with Alternative 3, although most of those acres would 

be along rights-of-way and around administrative and recreation sites. Increased risks would be incurred from 

the use of bromacil, diuron, and tebuthiuron because these herbicides persist longer, have greater risk of runoff, 

and are non-selective when compared to other proposed herbicides in Alternative 3. The effect to soil resources 

would include a greater area of exposure (thus possible erosion) and longer residence time of the herbicide in the 

soil, which would thus reduce biological organisms and their nutrient cycling processes. Some of these effects 

would be resolved once native vegetation returns to the sites in the next several growing seasons, although some 

disturbed sites would be maintained in a somewhat vegetation free state, to protect adjacent structures and other 

improvements. If similar acreage was treated with non-herbicide methods to remove the vegetation, it would 

involve mechanical equipment and expose soil to erosion and compaction risks that would be greater than 

herbicide risk. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

This alternative is projected to prevent noxious weed infestations on an additional 2.2 million acres when 

compared to the no-action alternative, resulting in proportional benefits to soils. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Effects under this alternative would be similar to those for Alternative 4. An additional 5,000 acres would be 

treated with herbicides, mostly as habitat improvement treatments having little or no effect on soils, as they would 

occur on the drier eastside Aridisols or Mollisols. The availability of all 18 herbicides would include minor 

additional use (0-200 acres) of most herbicides. Effects from diquat and diflufenzopyr + dicamba would be minor 

considering the limited use proposed. The increased use of imazapic by 2,000 acres would slightly elevate risks 

to soils but not the increased use of 2,4,D. 

Cumulative Effects 

In general, declines in soil productivity are directly associated with greater loss of soil through erosion and 

displacement, loss of soil organic matter, changes in vegetation composition, removal of whole trees and 

branches, and increases in bulk density from compaction. SOPs and PEIS Mitigation Measures (Appendix 2) 

would prevent soil productivity loss, and any degradation of soils from the herbicide applications proposed in this 

EIS would be de minimus in the context of other planned Federal, State, or private management actions in the 

analysis area (see Table 4-1). 

Water Resources 

Affected Environment 

Water resources are classified as surface water or groundwater. Surface water resources include rivers, streams, 

lakes, ponds, reservoirs, and wetlands. The major river system in Oregon is the Columbia with the main 

tributaries of the Willamette River in the west, the Deschutes and Snake River to the center and east. The 

Klamath River flows from southern Oregon into northern California. The west side of the Coast Range and 

southwestern Oregon has many short steep streams that drain directly to the Pacific Ocean. Southeastern Oregon 

has some closed basins that do not drain into any external system. 

Groundwater occurrences are of two types: unconfined shallow aquifers within unconsolidated sediments and 

deeper aquifers with a confining layer above (USGS 1994). 

Aquatic Conservation Strategy standards and guidelines for Riparian Reserves have been included in all 

resource management plans through the Northwest Forest Plan (USDA, USDI 1994) west of the Cascades and 

at Klamath Falls. Resource Management Plans east of the Cascades and outside of Klamath Falls include their 

own riparian management direction and best management practices to protect and improve water quality and 

riparian function. Each district follows INFISH (USDA 1995b) direction wherever bull trout or its designated 

Critical Habitat are present, and each follows PACFISH (USDA, USDI 1995) direction wherever Federally 

Listed anadromous salmonids are present. Standards and guidelines in the PACFISH and INFISH strategies are 

designed to provide for the attainment of riparian management objectives, which improves and protects riparian 

areas and water quality. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Flows 

There are 6,728 miles of perennial stream and 13,679 miles of intermittent streams on BLM land in western 

Oregon and 2,453 miles of perennial and 33,835 miles of intermittent streams on BLM land in eastern Oregon. 

In general, the high flows are found in western Oregon from October through May with highest flows likely 

from winter rains. In eastern Oregon, highest flows are found in the spring from snowmelt. In both areas, rare 

peak flows occur with a rain-on-snow event at low to mid-elevations. Low flows occur in the summer when 

precipitation is low and water withdrawals (generally for irrigation) are at their highest. The timing, magnitude, 

duration, and spatial distribution of peak flows helps create and sustain riparian and aquatic habitat (USDA et al. 

1993). 

Water Quality 

Water quality standards are established to protect beneficial uses of the State’s waters. Beneficial uses are 

assigned by basin in the Oregon Administrative Rules for water quality. For the State of Oregon, beneficial uses 

include (ODEQ 2009): 

• domestic water supply 

• fishing 

• industrial water supply 

• boating 

• irrigation 

• water contact recreation 

• livestock watering 

• aesthetic quality 

• fish and aquatic life 

• hydropower 

• wildlife and hunting 

• commercial navigation and transportation 

For streams on BLM lands, fish and other aquatic life is the most common beneficial use, although BLM-origin 

waters also supply water districts and private residences. 

303d Streams 

Section 303d of the Clean Water Act requires that states develop a list of water bodies that do not meet water 

quality standards and submit the list for approval to the EPA. The Oregon Department of Environmental Quality 

(ODEQ) developed its most current 303(d) list in 2004/2006. 

By direction of the Federal Clean Water Act, where water quality is limited, the ODEQ develops Total Maximum 

Daily Load (TMDL) plans to improve water quality and to support the beneficial uses of water. The BLM is 

recognized as a designated management agency for implementing the Clean Water Act (as amended) on BLM 

administered lands within the TMDL management plan. The BLM provides information, analysis, and sitespecific planning efforts to support State processes to protect and restore water quality. Pollutant standards not 

being met on one or more BLM steams are: 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

 

159 

Temperature 

Temperature is the most widespread water quality impairment on BLM land (Table 4-15). Well-shaded streams 

often have cooler stream temperatures due to reduced input of solar energy (Brown et al. 1969, Beschta et al. 

1987, Holaday 1992, Lee et al. 2004). Conditions that can produce highly shaded streams include: 

• Riparian areas with fully developed vegetative cover over the channel 

• Deep narrow channels with overhanging banks 

• Streambeds, banks, and floodplains that capture bed load and woody debris, providing channel cover and 

groundwater interaction. 

High solar path and air temperatures coinciding with low rainfall and low stream flow during the summer months 

are key factors causing elevated stream temperatures within the analysis area. South-facing aspects and lower 

elevations tend to create drier and hotter conditions, which serve to further elevate temperatures. 

Dissolved Oxygen 

High loading of organic matter and nutrients, combined with sediment and increased water temperature can 

deplete dissolved oxygen in small streams (Wringler and Hall 1975). Growth of algae with associated fluctuations 

in night and day respiration can lower dissolved oxygen at night. This process is limited to low-gradient streams 

with high algae growth. The ability of water to hold oxygen decreases with increased water temperature, altitude, 

or dissolved solids. 

Bacteria 

Bacteria occurs naturally in water, with sources often associated with the aquatic and terrestrial biotic populations. 

Land management introduction of bacteria has common sources linked to recreation and livestock grazing. 

Concentrated uses by humans and livestock in the riparian and channels can elevate bacteria population presenting 

risk to downstream uses such as domestic water consumption and recreation. 

Sediment 

Landslides and roads are the most common route for sediments to enter streams. Fine-grained sediments 

associated with roads that cross or parallel streams are the greatest management related problem for water 

quality. Roads may divert water and sediment from natural paths directly to a stream depending on road ditch line 

connection to streams, number of relief culverts, and number of stream crossings (Wemple et al. 2001). 

Table 4-15. miles of blm sTreams on odeq 303d lisT 

ODEQ 303d listed pollutant Miles of impaired streams on BLM 

Temperature 1711 

Dissolved oxygen 206 

Bacteria 64 

Sediment 61 

Metals 50 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

 160 

Metals 

Metals (including copper, lead, mercury, nickel, silver, and zinc) are most common around mining, agriculture, 

and natural sources found in certain rock types. Mercury is the most common metal of concern. 

Source Water Protection 

The 1996 Safe Drinking Water Act amendments require the identification and management of source water 

protection areas for public water systems (Figure 4-6). States are required to develop source water assessments 

for public drinking water supplies including both surface and groundwater sources. These watersheds are usually 

in rural settings and do not involve industrial contaminant sources. 

In addition to public water systems, private residences sometimes use springs and streams on adjacent BLM land 

for domestic water supplies. 

The EPA has set a maximum concentration for specific herbicides in potable water (Table 4-16; EPA 2009c). At 

this time, no maximum concentrations for potable water have been set for the other herbicides. 

Groundwater 

Groundwater is commonly available from shallow wells in unconsolidated aquifers that consist primarily of sand 

and gravel but contain variable quantities of clay and silt. Many large-yield public-supply and irrigation wells, 

and thousands of domestic wells, access these types of aquifers, generally in areas of privately owned land. In 

many places, deeper wells produce water from underlying volcanic rocks, usually basalt (USGS 1994). 

Groundwater can recharge through rain or snow or along losing reaches of streams.34 There are also more 

localized areas where groundwater lies above the regional ground water table due to a lens of impermeable rock 

or soil. These often discharge as seeps or springs on a hillside (OWRD 2003). 

Susceptibility of aquifers to contamination relates to geology, depth to groundwater, infiltration rates, and 

solubility of contaminants. The shallow unconfined aquifers are at greater risk from surface contamination due 

to rapid infiltration from the surface to the water table. The Willamette Valley, Snake River Basin, and Columbia 

Plateau all have elevated levels of nitrates and pesticides in groundwater (Eldridge 2004). 

34 Segments where water seeps out of the stream and into the ground water, as opposed to segments where seeps and 

springs contribute to stream flow. 

Table 4-16. maximUm Herbicide concenTraTion alloWed in PoTable WaTer 

Herbicide Potable water standards (ug/l) 

2,4-D 70 

glyphosate 700 

picloram 500 

diquat 20 

bromacil 0.90 

hexazinone 210 
figUre 4-6. soUrce WaTer ProTecTion 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Environmental Consequences 

A primary issue for this analysis is the potential for herbicides to enter streams and impact water quality for 

aquatic species and domestic water sources. Surface and ground waters on and adjacent to BLM lands are 

susceptible to contamination from herbicide applications through direct application, drift, spill, leaching, washing 

(erosion, overland flows), or the deposition of treated soils or vegetation matter into waters. The likelihood 

and significance of this contamination is influenced by the herbicide, adjuvants, temperature, wind, method of 

application, soils, rainfall, water use, and other factors. 

Effects of Herbicides on Water Resources 

Herbicides used for both Aquatic and Terrestrial Vegetation Control 

2,4-D: Some salt forms of 2,4-D is registered for use in aquatic systems. 2,4-D is a known groundwater 

contaminant although potential for leaching into groundwater is moderate by its being bound to organic matter 

and its half-life is short. Concentrations of up to 61 mg/L 2,4-D 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 prairie, 2,4-D was 

detected in 7 percent of 27 samples (Wood and Anthony 1997). 

Diquat would be applied to remove emergent, floating, or submerged aquatic vegetation. In aquatic systems, 

diquat (ionic) adsorbs to sediment, suspended solids, and aquatic vegetation, and becomes immobilized 

(Simsiman and Chesters 1976). Thus, diquat is ineffective in turbid waters. Loss of diquat from aquatic systems, 

both through photolysis and biodegradation, is possible, but only when the herbicide is not adsorbed to solid 

surfaces. When adsorbed, the herbicide is protected from biodegradation and photolysis (Howard 1991). Aquatic 

half-lives of 1 to 2 days have been reported for diquat, as a result of sorption onto particulates and sediments 

(National Library of Medicine 2002). Diquat is a known groundwater contaminant35. It has a moderate potential 

to leach into the groundwater. 

Fluridone would be applied to ponds, lakes, canals, and reservoirs, but has limited use in flowing water because 

it works through contact maintained over several weeks. Water quality is not degraded when fluridone is used at 

a concentration of less than 20 ppb, and it is generally considered safe to use in areas where swimming or fishing 

occur (WA Dept of Ecology 2002). Whole-lake treatments using fluridone are possible because the herbicide does 

not cause a rapid plant kill, which would otherwise result in oxygen-depleted water and reduced water quality. 

Photodegradation in aquatic systems is an important loss pathway for fluridone (British Crop Protection Council 

and The Royal Society of Chemistry 1994). Fluridone is stable to hydrolysis, volatilizes slowly from water, and 

adsorbs to suspended solids and sediments (EPA 1986, Lyman et al. 1990, Tomlin 1994, MacKay et al. 1997, 

ENSR 2005g). Fluridone has low potential to leach to groundwater and is not known to contaminate groundwater. 

It does have high potential to be transported in surface runoff. 

35 Has been detected in groundwater. Does not necessarily mean levels have exceeded any established health standard or 

allowance. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Glyphosate, which is registered for aquatic use, would be applied to wetland and emergent aquatic vegetation. 

Strong adsorption to soil particles and organic matter slows microbial degradation, allowing glyphosate to persist 

in aquatic environments in bottom sediments (half-life of 12 days to 10 weeks)(Goldsborough and Brown 1993, 

Extension Toxicology Network 1996a, all cited in Tu et al. 2001). 

While glyphosate is very water soluble it is unlikely to enter waters through surface runoff or subsurface flow 

because it binds strongly to soils, except when the soil itself is washed away by runoff; even then, it remains 

bound to soil particles and generally unavailable (Rueppel et al. 1977, Malik et al. 1989, all cited in Tu et al. 

2001). More recent studies found solution-phase glyphosate in 36 percent of 154 stream samples, while its 

degradation product, aminomethylphosphonic acid, was detected in 69 percent of the samples. 

Glyphosate may stimulate algal growth at low concentration; Austin et al. (1991) have suggested that this could 

contribute to eutrophication of waterways. 

Some glyphosate formulations contain polyethoxylated tallow amine (POEA) surfactant, which is substantially 

more toxic to aquatic species than glyphosate or other surfactants that may be used with glyphosate (SERA 

2003a). In the risk assessment, the toxicity of glyphosate is characterized based on the use of POEA surfactant, 

either in the formulation or added as an adjuvant in a tank mixture (SERA 2003a). 

Imazapyr is registered for use in aquatic systems, including brackish and coastal waters, to control emergent, 

floating, and/or riparian and wetland plants. Imazapyr is water soluble and potentially mobile (SERA 2004d). 

Imazapyr is rapidly degraded by sunlight in aquatic solutions, with a half-life of approximately 2 days that 

decreases with increasing pH (Mallipudi et al. 1991, Mangels 1991, all cited in Tu et al. 2001). Imazapyr does not 

appear to degrade in anaerobic systems, such as wetland soil or lake or pond sentiments, and will bind strongly to 

peat (American Cyanamid 1986). 

In their literature review of imazapyr, Tu et al. (2001) found no reports of imazapyr contamination in water 

despite its potential for mobility. It is not known to be a groundwater contaminant. Battaglin et al. (2000) stated 

that little is known about its occurrence, fate, or transport in surface water or groundwater. In one study, imazapyr 

(from terrestrial applications) was detected in 4 percent of the 133 samples taken from streams, but was not 

detected in reservoirs or groundwater. 

Triclopyr: The two forms of triclopyr, a triethyamine salt and a BEE, behave very differently in water. Both forms 

are used to control woody riparian vegetation. However, only the triethylamine salt form of triclopyr is registered 

for use for selective control of floating, immersed, and submersed aquatic plants. Both forms readily degrade to 

the acid form, which is the active form in plants. No adverse effects on water quality were observed following 

triclopyr triethyamine salt applications in two studies of whole-pond applications in closed systems (no water 

exchange; Petty et al. 2001). 

The triethyamine salt form of triclopyr is soluble in water and photodegrades in several hours with adequate 

sunlight. The rate of degradation in water is generally dependent on water temperature, pH, and sediment content. 

The BEE form (terrestrial use only, not registered for aquatic application) is not water-soluble and can partition 

into organic materials and be transported to sediments, where it is persistent. Alternatively, bound ester forms can 

degrade through hydrolysis or photolysis to triclopyr acid (Smith 1976 cited in Tu et al. 2001), which will diffuse 

into the water column and continue to degrade (Tu et al. 2001). 

163 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Herbicides Used for Terrestrial Vegetation Control 

Bromacil is mobile in soil and is a known groundwater contaminant. It can be persistent in most aquatic 

environments because it is stable to hydrolysis, and photodegradation occurs rapidly only under alkaline 

conditions (ENSR 2005b). The environmental hazards section of current product labels includes a groundwater 

advisory warning users not to apply bromacil in areas with permeable soils in order to protect water quality. 

Biodegradation is a major loss mechanism in aerobic and anaerobic aquatic systems. Bromacil is not expected to 

partition to suspend particles or sediments in aquatic systems, but will remain dissolved in the water column and 

has a high potential to leach into the groundwater. 

Chlorsulfuron is persistent and mobile in some soils. In aquatic environments, the environmental fate of 

chlorsulfuron is related to pH and temperature. Hydrolysis rates are fastest in acidic waters and slower in more 

alkaline systems (Sarmah and Sabadie 2002). As hydrolysis rates drop, biodegradation becomes the mechanism 

affecting the breakdown of chlorsulfuron. Aquatic dissipation half-lives from 24 days to more than 365 days have 

been reported (ENSR 2005c), with a shorter time reported for flooded soil (47 to 86 days) than anaerobic aquatic 

systems (109 to 263 days; SERA 2004a). Chlorsulfuron is not known to be a groundwater contaminant, but has a 

high potential to leach into the groundwater. 

Clopyralid does not appear to bind tightly to soil and will leach under favorable conditions (SERA 2004b). 

However, leaching and subsequent contamination of groundwater appear to be minimal, which is consistent with 

a short-term monitoring study of clopyralid in surface water after an aerial application (Rice et al. 1997a cited 

in SERA 2004b). Clopyralid is not known to be a common groundwater contaminant, and no major off-site 

movement has been documented. Clopyralid does not bind with suspended particles in water; biodegradation 

in aquatic sediments is the main pathway for dissipation. The average half-life of clopyralid in water has been 

measured at 9 and 22 days (Dow AgroSciences 1998). 

Dicamba: Because dicamba is mobile in soil, terrestrial application of this herbicide can result in groundwater 

and surface water contamination. Biodegradation is the major mechanism for dicamba degradation in water. 

Dicamba is a known groundwater contaminant, and has a high potential to leach into groundwater. The EPA has 

set health advisory concentration levels for dicamba (e.g. 300 μg/L for 1-day exposures), but has not set maximum 

concentration limits for potable water. A regional study of pesticides in shallow groundwater in Delaware, 

Maryland, and Virginia detected dicamba in groundwater at low concentrations, generally less than 3 μg/L (ppb) 

(Koterba et al. 1993). 

Diflufenzopyr appears to be soluble, with transportation from surface runoff following application, particularly 

when diflufenzopyr is applied on soils with neutral to alkaline pH. However, based upon proposed uses, fate 

characteristics, and model predictions, the EPA does not expect diflufenzopyr to occur in drinking water in 

significant quantities (EPA 1999). Diflufenzopyr is not a known groundwater contaminant. 

Biodegradation, photolysis, and hydrolysis are important mechanisms in removing diflufenzopyr from aquatic 

systems. Its half-life is less than 1 month, with hydrolysis and photolysis rates higher in acidic environments. 

The aquatic dissipation half-life for diflufenzopyr is 25 to 26 days in aerobic and 20 days in anaerobic conditions. 

Diflufenzopyr’s expected half-life in small ponds is estimated at 24 days. These factors suggest that diflufenzopyr 

would be removed from an aquatic environment relatively rapidly if contamination occurred (EPA 1999). 

Diuron is a known surface water and groundwater contaminant. The U.S. Geological Survey (USGS) National 

Ambient Water Quality Assessment Program analyzed pesticide occurrence and concentrations for major aquifers 

and shallow groundwater in agricultural areas and found diuron in 71 percent of 2,608 samples (Thurman et 

 164 
 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

al. 1999). The maximum concentration of diuron was 0.34 ppb (μg/L). The EPA recently placed diuron on the 

drinking water contaminant candidate list36 (EPA 2008). 

In aquatic systems, biodegradation and photodegradation appear to be the primary loss mechanisms for diuron. 

An aquatic biodegradation half-life of 33 days has been reported for aerobic systems. Aquatic dissipation halflives have been reported ranging from 3 to 10 days in anaerobic pond sediment to 177 days in a drainage ditch. 

Diuron is stable to hydrolysis and is unlikely to volatilize from aquatic systems (EPA 2001a). Diuron is expected 

to adsorb to suspended solids and sediments (National Library of Medicine 2002). 

At a poorly drained field site along an intermittent stream in Oregon, diuron and its transformation product, 

DCPMU (3-(3,4-dichlorophenyl)-1-methyl-urea), were detected in the stream at a maximum concentration of 

28 μg/L, and were detected in shallow groundwater immediately adjacent to a tributary stream at 2 to 13 μg/L. 

Movement through soil transported the herbicide and its metabolite to the stream, while surface runoff removed 

less than 1 percent of the applied herbicide (Field et al. 2003). 

Hexazinone and its degradates persist, are highly mobile, and are readily washed into surface waters. Hexazinone 

has been identified as a groundwater contaminant in seven states. The EPA requires a groundwater advisory on 

all product labels stating that hexazinone must not be used on permeable soils. In areas where irrigation water is 

contaminated with hexazinone or where groundwater discharges to surface water, hexazinone residues in water 

could pose a threat to plants. 

In surface water, hexazinone resists photodegradation (Neary et al. 1983 cited in Tu et al. 2001). Hexazinone 

does not bind strongly to particulates or sediments. The main method of degradation is by micro-organisms in 

soils. The average half-life of hexazinone in soils and water is 90 days (Tu et al. 2001). Hexazinone has been 

detected in streams near terrestrial application sites up to 30 days after treatment, and reported in runoff up to 6 

months post-treatment in a forestry dissipation study (Neary and Michael 1996; Michael et al. 1999). Neary et al. 

(1984, 1993, all cited in Tu et al. 2001) concluded that hexazinone was diluted in the mainstream flow to very low 

concentrations in forested watersheds. 

Imazapic: In aquatic systems, imazapic rapidly photodegrades, with a half-life of 1 to 2 days (Tu et al. 2001). 

Since aerobic biodegradation occurs in soils, aerobic biodegradation is likely important in aquatic systems. 

Aquatic dissipation half-lives have been reported from 30 days (water column) to 6.7 years in anaerobic 

sediments (SERA 2004c). Little is known about the occurrence, fate, or transport of imazapic in surface water or 

groundwater (Battaglin et al. 2000). However, according to the herbicide label for Plateau, in which imazapic is 

the active ingredient, it is believed to be a groundwater contaminant (BASF 2004). 

Metsulfuron methyl is stable to hydrolysis at neutral and alkaline pHs and has a half-life of 3 weeks in acidic 

systems (Extoxnet 1996b). The persistence of metsulfuron methyl (initial concentration 10 μg/L) was investigated 

using in situ enclosures in a woodland/boreal forest lake, and the half-life was estimated at approximately 29 days 

(Thompson et al. 1992). Metsulfuron methyl is not known to be a groundwater contaminant, although it has a 

high potential to leach into the groundwater. 

Picloram can move off site through surface or subsurface runoff, and has been detected in the groundwater of 

11 states (Howard 1991). Picloram does not bind strongly with soil particles and is not degraded rapidly in the 

environment (Tu et al. 2001). Concentrations in runoff have been reported to be great enough to damage crops, 

and could cause damage to certain submerged aquatic plants (Forsyth et al. 1997 cited in Tu et al. 2001). 

36 The other 17 herbicides discussed in this EIS are not on this list. 

165 
 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Picloram may degrade through photolysis, especially in non-turbid and moving water. Woodburn et al. (1989) 

found that the half-life of picloram in water was 2 to 3 days (cited in Tu et al. 2001) but the EPA reported it stable 

to hydrolysis and unlikely to degrade in ground water, even over several years (EPA 1995). Maximum picloram 

runoff generally occurs following the first significant rainfall, after which runoff concentrations drop to levels that 

persist up to 2 years post-application (Scifres et al. 1971, Johnsen 1980, Mayeux et al. 1984, Michael et al. 1989, 

all cited in Tu et al. 2001). 

Sulfometuron methyl degrades quickly by hydrolysis in acidic water, but is stable in neutral water. Biodegradation 

and photolysis are major loss pathways in aquatic systems, where hydrolysis rates generally are slow. Aquatic 

dissipation half-lives are estimated at 1 to 3 days to 2 months in aerobic systems, and several months in anaerobic 

sediments (Extoxnet 1996c). Sulfometuron methyl is not known to be a groundwater contaminant. In one surface 

water study, sulfometuron was detected in 2 percent of 133 samples taken from streams. 

Tebuthiuron persists in the environment and has been found as a groundwater contaminant. It has a low sorption 

to soil. In a study of 71 streams, it was detected in 16 percent of 134 samples but not detected in groundwater 

(Battaglin et al. 2001). Tebuthiuron degrades slowly in aquatic systems. 

Routes for Off-Site Movement of Herbicides 

Run-off, Drift, Direct Application, and Leaching 

The major routes for herbicide contamination of water are runoff from a large rainstorm soon after application, drift 

into streams from spraying, direct application, and leaching through soil into shallow ground water or into a stream. 

Run-off 

Monitoring studies and fate and transport research often find low, but detectable levels of herbicides concurrent 

with or immediately after (1) herbicide application and (2) the first or the first few rain-induced runoff events after 

application (Berg 2004:3)37. 

Berg reported that herbicide applied in or along dry ephemeral or intermittent stream channels may enter streams 

through run-off if a large rainstorm occurred soon after treatment. This risk is minimized if intermittent and 

ephemeral channels are buffered. If a large rainstorm occurs after herbicide application, sediment contaminated 

by herbicide could be carried into streams. As most herbicide application occurs in the spring through the fall, 

during the dryer season, the probability of a large rainstorm soon after application of herbicides is low at any 

particular site. 

Berg’s (2004) compilation of monitoring studies on herbicide treatments with various buffer widths showed that 

any buffer helps lower the concentration of herbicide in streams adjacent to treatment areas. In California buffers 

between 25 and 200 feet generally resulted in no detectable concentrations of herbicide in monitored streams with 

detection limits of 1-3 mg/m3

 (ppb) (Berg 2004). 

In South Carolina, ground applications of the herbicides imazapyr, picloram and triclopyr had no detectable 

concentrations of herbicide in monitored streams with buffers of 30 meters (~100 feet) (USDA 2003a). No 

detection limits were given. 

37 Many or all of the referenced studies were broadcast forest and rangeland treatments, and they were not randomly selected. The point 

of the reference is not that herbicides “often” enter streams, but to identify the two most likely times of that entry if it is to occur at all. 

 166 
 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

The USGS in partnership with the Oregon Department of Transportation studied runoff of herbicides along roads 

(similar to treatment of native vegetation that would be permitted under Alternatives 4 and 5) (Wood 2001). The 

study was conducted on runoff associated with several herbicides (Krovar (diuron and bromacil), sulfometuron 

methyl, and glyphosate) along a road in western Oregon simulating rainfall at 1/3 inches an hour at 1, 7 and 14 

days after treatment. Samples were collected at the shoulder of the road had concentrations of 372-6132 μg/l of 

diuron the first day after application and from 23 to 28 μg/l 2 weeks later. Concentrations of glyphosate were 

similar at 323-736ug/l the first day after application and 16-41 μg/l 2 weeks after application. Sulfometuron 

methyl had the lowest concentration consistent with the lower application rate. Concentrations ranged from 

119-253 the day after application and from 10-15ug/l 2 weeks later. In the fall, the road was again sprayed and 

the ditch line of the road was checked during natural rainstorms for three months. Sulfometuron methyl was 

found in concentrations of 0.1 to 1ug/l along the shoulder and from 0.3 to 0.1 μg/l in the ditch line but was below 

detectable limits in the stream. Glyphosate was not found at the shoulder, ditch line, or stream. This study 

indicates that the greatest risk of herbicides moving off site is from large storms soon after herbicide application. 

In addition, this study also indicates that diuron and sulfometuron methyl may persist in the environment as they 

were above detectable limits along the shoulder of the road the entire duration (three months) of the study. 

SOPs require a minimum 10-foot stream buffer for hand treatments of upland labeled herbicides near a stream, 

25-foot buffer for broadcast spray from a truck, and 100-foot buffer for aerial applications, to minimize movement 

of herbicide into water (Appendix 2, Wetland and Riparian Areas). 

A summary of selected herbicide parameters affecting the potential for off-site movement is presented in Table 

3-1. Herbicide persistence in water is presented on Table 4-17. Persistence (longevity in the environment), 

soil adsorption (how well it binds to soils) and solubility (how well it dissolves in water) are three properties of 

herbicides that affect their likelihood to move offsite. 

Table 4-17. Herbicide PersisTence in WaTer 

Persistence 

Aquatic Use Herbicides 

2,4-D Moderate 

Diquat High 

Fluridone Low 

Glyphosate Moderate 

Imazapyr Moderate 

Triclopyr TEA Moderate 

Terrestrial Use Herbicides 

Bromacil Moderate 

Chlorsulfuron Moderate 

Clopyralid Moderate 

Dicamba Moderate 

Diflufenzopyr Low 

Diuron Moderate 

Hexazinone High 

Imazapic High 

Metsulfuron methyl Moderate 

Picloram Moderate 

Sulfometuron methyl Low 

Tebuthiuron High 

Triclopyr BEE Moderate 

Source: Vogue et al. (1994) 167 
 168 

38 Such an application would be rare under alternatives examined in this EIS. The alternatives do not include treatments 

with commodity production objectives. 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Drift 

Soil Erosion 

Wind erosion can carry herbicide to streams on soil particles. Soil movement is heavily dependent on wind speed, 

topography, and surface cover on the soil. To estimate potential transport by wind erosion, the risk assessments 

used average soil losses ranging from 1 to 10 tons per hectare per year. For a given herbicide, model-estimated 

transport by wind erosion was far less than off site movement of herbicide associated with surface runoff on clay 

soils, and similar to off-site losses associated with drift at a distance of 500 feet or more from the application site. 

Movement of herbicides from wind erosion would be expected to be minimal in western Oregon due to the dense 

groundcover and more limited treatment sites. It would be expected to be more important in drier areas east of the 

Cascades in larger treatment areas. See Soil Resources for additional discussion of wind erosion risks. 

Aerial Application 

Aerial application is the least targeted type of application and is the method of application for approximately 7 

percent of the herbicide used on BLM land in Oregon (see the Herbicide Treatment Methods section in Chapter 

3). Drift from aerial applications is the process most likely to result in herbicides getting onto non-target areas 

such as stream channels. This is primarily dependent upon the elevation of the spray nozzle, droplet size and air 

movement. The smaller the droplet, the longer it stays suspended and the farther it can travel. 

Spray drift can be reduced by increasing droplet size since wind will move large droplets less than small droplets 

(Table 4-18). Droplet size can be increased by: 1) reducing spray pressure; 2) increasing nozzle orifice size; 3) 

using special drift reduction nozzles; 4) using additives that increase spray viscosity; and, 5) using rearward nozzle 

orientation in aircraft. 

Commercial drift reduction agents are available that are designed to reduce drift beyond the capabilities of the 

determinants described above. These products create larger and more cohesive droplets that are less apt to break 

into small particles as they fall through the air. They reduce the percentage of smaller, lighter particles, which are 

most apt to drift. SOPs for air quality provide techniques for controlling drift, including specifying selection of 

equipment that produces 200-800-micron diameter droplets. 

The Washington State Department of Ecology and Oregon Department of Forestry have monitored aerial application 

of herbicides in forest settings38. The purpose of both studies was to look at the effectiveness of buffers protecting 

water quality in streams within herbicide treatment areas. The Washington study looked at many factors in addition 

to stream buffers that affected the concentration of herbicides in streams within treatment areas. 

Table 4-18. drifT disTance versUs droP diameTer (ndsU 1993) 

Droplet 

Diameter 

(microns) 

Type of Droplet Airborne Time Lateral Distance Traveled in 10 foot 

height & 3 mph wind speed 

5 Fog 66 minutes 3 miles 

20 Very Fine Spray 4.2 minutes 1,100 feet 

100 Fine Spray 10 seconds 44 feet 

240 Medium Spray 6 seconds 28 feet 

400 Coarse Spray 2 seconds 8.5 feet 

1,000 Fine Rain 1 second 4.7 feet 
 

 

 

 

 

 

 

 

 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

The Washington study collected herbicide samples at 7 sites on small streams (Rashan and Graber 1993). 

Buffers were 50 feet on flowing streams and no buffers on small stream channels assumed to be dry. Peak 

herbicide concentrations ranged between 0.2 and 7.55 μg/l. Maximum 24 hour averages were between 0.13 and 

3.25 μg/l. Runoff samples collected at four sites 2 to 24 days after application had concentrations between 0.17 

and 2.49 μg/l. 

The Washington study attributed the majority of herbicide introduction in buffered streams to swath displacement, 

drift, and secondary contribution from overspray of small stream channels mistakenly assumed to be dry. This 

study recommended buffers of between 15 to 25 meters (45-75 feet) for upwind streams and 75 to 90 meters (225­

270 feet) for streams downwind of applications. 

The State of Oregon requires buffers of 60 feet for aerial application of herbicides near fish bearing streams or 

streams used for domestic water supplies. For the Oregon study, two streams outside this category also received 

60-foot buffers (actual on the ground buffers ranged from 60 to 100 feet). Most of the samples (21 sites, and 105 

post spray samples) had a detection limit of 1 μg/l. None of these samples had concentrations at detectable limits. 

Five sites (25 samples) had detection limits of 0.04 to 0.5 μg/l. Most samples were still below detectable limits, 

but 7 of the 25 samples tested between 0.9 and 0.56 μg/l (Dent and Robben 2000). 

All aerial applications of herbicides will comply with EPA label restrictions and State regulations. SOPs 

applicable to all alternatives (Appendix 2, Wetland and Riparian Areas) require a minimum of 100-foot stream 

buffers for aerial sprays to reduce drift to streams. 

Direct Application 

Spray Monitoring 

Washington State monitoring reports were looked at for 2003-2006 (WA Dept of Ecology 2003-2006). Many 

sites showed no detection after spraying. The site with the highest detection was a small pond where 1/3 acres 

of parrot’s feather was sprayed with glyphosate. The results were 343 μg/l one hour after treatment and 53ug/l 

24 hours later. This is under the threshold for glyphosate in potable water and under the 500ug/l used for acute 

toxicity index for fish. 

Lakes, Reservoirs, and Wetlands 

Herbicides affect lakes and wetlands differently than streams. Dilution by flow or tributary inflow is generally 

less effective in lakes. Dilution is partially a function of lake size, but dilution could be rapid in small lakes in 

rare instances where they have large water contributing areas. Decreases in herbicide concentration in lakes, 

ponds, and other lentic water bodies are largely a function of chemical and biological degradation processes rather 

than of dilution. Evaporation of water from a lake’s surface can concentrate chemical constituents. As vegetation 

within water dies, the oxygen level within the lake can decrease. 

Injection Monitoring 

Knotweed stem-injection sites were also monitored by Washington States Department of Ecology. Three sites 

had no detectable concentrations in the water one hour or 24 hours after injection. The two sites with detectable 

concentrations were under the threshold for potable water (Table 4-19). 

Accidental Spill 

Concentrations of herbicides in streams as a result of an accidental spill depend on the rate of application and the 

streams’ ratio of surface area to volume. The persistence of the herbicide in water depends on the length of stream 

where the accidental spill took place, velocity of stream flow, and hydrologic characteristics of the stream channel. 

The concentration of herbicides would decrease rapidly down-stream because of dilution and interactions with 

169 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

 170 

physical and biological properties of the stream system (Norris et al. 1991). An herbicide transportation and handling 

plan is required for all herbicide control projects. This plan would address spill prevention and containment. 

Leaching 

Groundwater 

Groundwater contaminated from surface water treatments is generally minimal for many herbicides because 

decomposition of herbicide by microbial action and other processes is quicker than the time taken for herbicideladen water to move from surface waters to groundwater (Berg 2004). Travel time to groundwater decreases 

as the depth to groundwater decreases, and generally, the depth to groundwater is least in spring and greatest in 

late summer. If spring rains come shortly after herbicide application and the water table is close to the surface, a 

greater potential for groundwater contamination exists (Mahler et al. 2002). 

The shallower the depth to groundwater, the less soil there will be to act as a filter and the less chance for 

degradation or adsorption of herbicides (Berg 2004). In humid regions, groundwater may be only a few feet 

below the surface of the soil. If rainfall is high and soils are permeable, water carrying dissolved herbicides 

may take only a few days to percolate downward to groundwater. In arid regions, groundwater may lie several 

hundred feet below the soil surface, and leaching of herbicides to groundwater may be a much slower process 

(Alabama Cooperative Extension 1999 cited in Berg 2004). 

Lakes Reservoirs and Wetlands 

Herbicides affect lakes and wetlands differently than streams. Dilution by flow or tributary inflow is generally 

less effective in lakes. Dilution is partially a function of lake size, but dilution could be rapid in small lakes in 

rare instances where they have large water contributing areas. Decreases in herbicide concentration in lakes, 

ponds, and other lentic water bodies are largely a function of chemical and biological degradation processes rather 

than of dilution. Evaporation of water from a lake’s surface can concentrate herbicide constituents. As vegetation 

within water dies, the oxygen level within the lake can decrease. 

Accidental Spill 

Concentrations of herbicides in streams as a result of an accidental spill depend on the rate of application and the 

streams’ ratio of surface area to volume. The persistence of the herbicide in water depends on the length of stream 

where the accidental spill took place, velocity of stream flow, and hydrologic characteristics of the stream channel. 

The concentration of herbicides would decrease rapidly down-stream because of dilution and interactions with 

physical and biological properties of the stream system (Norris et al. 1991). An herbicide transportation and 

handling plan is a project requirement. This plan would address spill prevention and containment. 

Table 4-19. glyPHosaTe concenTraTion in sTreams 1 HoUr and 24 HoUrs afTer injecTion 

Year 1 hour (ug/l) 24 hour (ug/l) 

2004 50 10 

2005 12.1 3.8 

2005 ND ND 

2006 ND ND 

2006 ND ND 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Effect of Invasive Plants on Water Resources 

Invasive plants can create or exacerbate conditions that reduce water quality. Reed canarygrass is a common 

invader of wetlands and riparian areas. Purple loosestrife is another species that occupies stream banks, canals, 

and shallow ponds. Many other species can occupy either riparian or upland habitat. For example, herb Robert, 

Himalayan blackberry and scotch broom can all occupy either upland or riparian habitat. Many invasive plants 

grow quickly and densely allowing them to out-compete native vegetation. Invasive plants are difficult to control 

in riparian areas as they thrive in the moist environment. Invasive plants can affect water quality by affecting 

bank stability, sediment, stream temperature, dissolved oxygen, and pH (USDA 2005). See the Wetland and 

Riparian Areas section for additional discussion. 

Japanese knotweed is one of the invasive plants that has the potential to affect stream functioning. Japanese 

Knotweed is a creeping perennial that grows in the spring and summer and dies back with the first hard frost. 

Knotweed resprouts following cutting, mowing, and digging. Japanese knotweed has poor bank holding capacity, 

which leads to more bank erosion and sedimentation of streams in high winter flows (USDA 2005). While 

knotweed may provide some shade, native streamside hardwoods and conifers are much taller and provide 

more dense shade, so knotweed-dominated areas may be associated with higher water temperatures than areas 

with native forest communities. Knotweed spreads rapidly in flood prone areas such as the Pacific Northwest. 

Knotweeds tolerate a wide variety of substrates from cobbles to fine soils (Tu and Soll 2004). 

Upland invasive plants are also found along streams where they can colonize a range of sites. Himalayan 

blackberry is the most widespread and economically disruptive of all the noxious weeds in western Oregon 

(ODA 2008). It aggressively displaces native plant species and dominates lower elevation riparian habitats. Like 

knotweed, it has poor bank-holding capacity, leading to erosion and altered stream channel morphology. 

Total vegetative cover can be reduced on weed-infested sites where strong invaders outcompete native vegetation. 

Diffuse and spotted knapweeds are found along many eastern Oregon streams. Weed infested soil has been shown 

to be more susceptible to erosion than soil occupied by native grass species (Lacey et al. 1989). Soil erosion in 

a simulated rainfall test more than doubled in spotted knapweed-dominated rangeland areas when compared to 

natural bunchgrass/forb grasslands (Lacey et al. 1989). 

Eastern Oregon is losing shrubland due to expansion of Western juniper. The integrity and extent of riparian 

vegetation have changed and been fragmented in response to forest conversion and disturbance (Miller et al. 

2005). Western juniper removes water from most of the soil profile, decreasing discharge to streams. Reducing 

Western juniper cover has been shown to increase understory vegetation has been shown to increase understory 

vegetation and infiltration and reduce erosion (Miller et al. 2005, Pierson et al. 2007, Peterson and Stringham). 

Medusahead, knapweeds, and cheatgrass can lead to shortened fire cycles followed by increased soil erosion and 

stream sedimentation. 

In addition to the aquatic emergent species discussed above, lakes and wetlands may have invasive submerged 

species such as Eurasian watermilfoil. These species are becoming common invaders of aquatic ecosystems, 

outcompeting native vegetation. For example, Eurasian watermilfoil was introduced to Oregon coastal lakes 

about 40 years ago (PSU 2000). Eurasian watermilfoil multiplies rapidly and forms canopies over the native 

plants, literally choking out native plants and severely restricting recreational activities. In addition, it degrades 

water quality and fish habitat, accelerates eutrophication (over-abundance of nutrients), and lowers amounts of 

oxygen in the water. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Effects by Alternative 

Alternative 1 – No Herbicide Use 

This alternative does not use herbicides and therefore would not have the potential to contaminate water with 

herbicides39. Many treatments would occur by other methods: primarily fire, livestock, mechanical, or manual 

treatments (Chapter 3). Fire without herbicides generally needs to be used several years in a row to be effective 

(Tu et al. 2001). Use of fire has potential for increased sediment input to streams depending on if large storms 

occur before other vegetation becomes established. Directed livestock has potential for localized effects to water 

quality if used near a stream. The effects would be increased fecal coliform and increased fine sediment. Effects 

could potentially include trampling of banks affecting the width to depth ratio of the stream. Effectiveness of 

these treatments depends on the species being treated, the timing of treatment, and the size of the infestation. This 

alternative uses directed livestock on 8,800 acres, a threefold increase from the No Action Alternative. Manual 

treatments can be effective for small infestations of non-rhizomatous species. When near streams, pulling weeds 

could increase sediment input to streams when compared to the No Action Alternative. 

Many non-herbicide treatments are not effective with many of the invasive plants. Certain species such as 

knotweeds are not controllable without herbicides. Knotweeds have roots and rhizomes with depths of up to 7 

feet and spread of more than 20 feet from the parent plants (Boersma et al. 2006). Knotweeds are found most 

thickly in western Oregon but are present in small areas eastern Oregon also. 

Invasive plants are typically less effective at maintaining stable stream banks than native plant species. Most 

invasive plants also provide less stream shading than native hardwoods and conifers. Invasive plants are expected 

to spread at the fastest rate (14 percent), and ultimately infest more acres, under this alternative. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

The four herbicides used under this alternative include three known groundwater contaminants: picloram, dicamba 

and 2,4-D. Picloram is a high-risk herbicide for aquatic resources but is preferred in many situations because it is 

a selective herbicide that represses reestablishment of target invasive plants. Some of the invasive plants found 

in Oregon are not effectively controlled by the four herbicides available. For example, the four herbicides are 

ineffective at treating saltcedar (Appendix 7: Table A7-1). 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). 

While glyphosate is available to treat emergent species such as knotweeds and reed canarygrass, no herbicides 

are available to treat submerged plants such as Eurasian watermilfoils and hydrilla. These plants degrade water 

quality by eutropification that can lead lower oxygen levels in the water. Noxious weeds are expected to continue 

to spread at approximately 12 percent per year under this alternative, and infest about 1/3 of BLM lands in 15 

years. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

This alternative would use herbicides on an additional 13,600 acres, (mostly east of the Cascades), but because 

the additional herbicides are effective at smaller doses, total pounds of herbicide would go down 30-50 percent. 

Use of the four herbicides presently used would go down as other herbicides were used instead. For example, 

clopyralid (low risk to aquatic ecosystems) can frequently be substituted for the use of picloram. However, the 

39 BLM waters could still be affected by herbicide use on adjacent lands. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

greater number of acres treated increases exposure, adding risk of both surface and groundwater contamination by 

herbicides. SOPs require that areas with shallow groundwater and areas of groundwater-surface water interaction 

be identified to reduce impacts to groundwater from the application of herbicides. 

Three of the additional herbicides in this alternative40 would be used to treat aquatic emergent or submergent 

plants giving this alternative greater potential to treat invasive aquatic plant species than Alternatives 1 and 2. The 

1.9 million fewer infested acres in 15 years than Alternative 2 translates to fewer degraded stream banks, riparian 

areas, and watersheds. 

Effects of Riparian and Aquatic Treatments 

Restoring native plants would improve riparian stability where invasive plants like Himalayan blackberries and 

knotweeds have colonized along stream channels and out-competed native species. However, invasive plants 

removal could exacerbate stream instability as well as remove stream shading; these effects could last until the 

native vegetation replaced the treated vegetation; planting is often used to shorten this time. BLM policy requires 

restoration plans under site-specific analysis to account for these effects, and prescribe mulching, seeding, and 

planting as needed to revegetate riparian and other treated areas (USDI 2008a:52). Speeding restoration of such 

management-exposed stream banks with willow planting or other measures is common BLM practice. 

Imazapyr has an aquatic formulation that is frequently used to control knotweeds and saltcedar. Triclopyr is 

used to control broadleaf species and saltcedar in riparian areas. Removing invasive riparian and aquatic plants 

can result in improved water quality where blooms of invasive plants lead to low dissolved oxygen, and where 

invasive plants within riparian areas have lead to increased erosion and sedimentation. Monitoring data for 

emergent treatments show that the amount of herbicide entering water from treatments is generally below levels 

of concern (LOC) for potentially exposed aquatic organisms. 

Fluridone is an aquatic herbicide available to control submerged aquatics including Eurasian watermilfoils and 

hydrilla. This herbicide can only be used in still waters such as ponds and lakes. It is proposed for 100 acres east 

of the Cascades and 200 west of the Cascades. In Washington, it is considered effective at controlling Eurasian 

water milfoil without impacting drinking water quality or recreation (WA Dept of Ecology 2002). Fluridone 

is slow acting and is used at low concentrations on both submergent and emergent plants. As the plants die off 

slowly, there is not a large concentration of decaying organic matter added to the water at one time so it is less 

likely to deoxygenate the water than other aquatic herbicides. 

There is low risk to drinking water from treatment with imazapyr, glyphosate, or fluridone even in the case of 

accidental spills. Triclopyr and 2,4-D applications are considered moderate to high risk for drinking water (see 

Human Health and Safety section in this Chapter). 

Effects of Upland Treatments 

The potential for impacts from herbicide drift would be reduced by the SOP requiring a minimum 10-foot groundbased, 25-foot ground-vehicle and 100 foot aerial buffers between treatment areas and water bodies. Buffers that 

are more precise would be developed using the ecological risk assessments for project level analysis. Parameters 

to be considered include the herbicide physical properties and off-site movement potential shown on Table 4-17. 

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. SOPs such 

40 Fluridone, imazapyr, and triclopyr 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

as stream buffers reduce potential impacts to water quality from herbicide applications but do not specifically 

address ditches. Overall exposure would be increased under this alternative compared to Alternative 2 because 

more acres would be treated, but the pounds would be lower, especially for those herbicides of highest concern to 

water quality. 

This alternative would add about 7,000 acres of additional prescribed fire treatments to the 5,100 acres found 

under Alternative 2, increasing the potential for storms to deliver sediments to streams. These treatments are 

in a dryer part of Oregon where many stream channels run seasonally, so few perennial streams are likely to be 

adversely effected by treatments. Where perennial streams are affected, those effects would be temporary; longterm effects would be positive as vegetation provides riparian shading and reduces runoff and erosion. 

Local and temporary increases in stream flows could occur in areas where large acreages of a monoculture such as 

cheatgrass, medusahead, starthistle, or knapweed would be treated with herbicides or prescribed fire. This would 

typically last one season or until native or desirable vegetation became reestablished. 

Hexazinone is only proposed for 200 acres but is persistent and mobile. It has been reported in runoff up to six 

months post treatment (Tu et al. 2001). Hexazinone is considered a high risk for groundwater contamination. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Alternative 4 would treat the same noxious weeds as Alternative 3 and would add treatments of native vegetation on 

rights-of-way, admin and recreation sites, and habitat restoration specified in Conservation Plans. This alternative 

would permit the use of more types of herbicides and would be expected to treat more acres with herbicides and use 

more pounds of herbicides. The additional acres treated would increase the risk of contamination of human water 

sources. The three added herbicides (bromacil, diuron, and tebuthiuron) are all known groundwater contaminants. 

The same SOPs discussed under Alternative 3 would be used to minimize risks. 

Effects of Riparian and Aquatic Treatments 

Riparian and aquatic treatments have the same advantages and risks as discussed under Alternative 3. 

Effects of Upland Treatments 

The treatment of invasive plants has the same advantages and risks as Alternative 3. The treatment of native 

vegetation adds treatment of 13,000 acres east of the Cascades and 2,100 acres west of the Cascades. This 

alternative would treat more rights-of-way, replacing mowing in an assumed 1 to 1 ratio. As more roads and 

rights-of-way (and thus more ditch lines) are treated, there is more potential for herbicide to enter water. Buffers 

would apply at stream crossings to minimize the amount of herbicide entering streams. The added herbicides, 

bromacil, diuron, and tebuthiuron, are commonly used for control of vegetation along roads and rights-of-way. 

These are all persistent and mobile herbicides. SOPs include buffers to minimize impacts to water quality and the 

requirement under site-specific project to minimize impacts to water quality. 

Where Western juniper is removed as part of a Conservation Plan treatment, there is a potential to increase stream 

flows, benefiting aquatic organisms and increasing riparian vegetation. Improved riparian condition improves 

resiliency to storm events. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Alternative 5 would make 18 herbicides available for a full range of non-commodity objectives. The effects 

would be about the same as those discussed under Alternative 4 except as follows. Approximately 5,000 more 

acres would be treated with herbicides, with most of the increase used for habitat improvement east of the 

Cascades. This alternative adds diquat for treatment of aquatic plants. This alternative lowers the noxious weed 

spread rate to 6 percent, the same as Alternative 4. The additional acres treated would slightly increase the risk 

of contamination of human water sources but most of the risk is expected east of the Cascades. SOPs discussed 

under Alternative 3 are used under this alternative also to minimize risk to human water sources. 

Effects of Riparian and Aquatic Treatments 

Effects of treatment of emergent and aquatic invasive plants would be similar to Alternatives 4 with the addition 

of one aquatic herbicide. Diquat is a known groundwater contaminant and has a maximum concentration level of 

0.20ug/l for potable water. Diquat is an aquatic herbicide with potential to deoxygenate water if large areas are 

treated due to plant decomposition. However, only 100 acres of treatment are proposed with this herbicide east 

and west of the Cascades. This is 0.25 percent of treatments east of the Cascades and 1 percent of treatments west 

of the Cascades. This herbicide is proposed for use in large part because it is the only herbicide available to BLM 

that will control giant salvinia. Giant salvinia is not known to occur in Oregon at this time, and current climate 

conditions in Oregon appear to be outside of its ecological amplitude. 

Effects of Upland Treatments 

The higher number of acres treated would add to the risk of herbicide impacting water quality although due 

to SOPs such as stream buffers, the risk is minimized. Most of the 5,000 additional treatment acres under this 

alternative would be upland treatments, and could use any of the 18 herbicides registered for terrestrial use. 

Additional acres of Western juniper treatment are likely to be controlled under this alternative as a habitat 

improvement treatment, with a potential for localized increases in flow where large acreages are treated within a 

single drainage. 

Cumulative Effects 

Herbicide use occurs on other Federal, State, and County lands, private forestry lands, rangeland, agricultural 

land, utility corridors, and road rights-of-way. Table 4-1 compares the pounds of each herbicide projected to 

be applied under the BLM proposed action with the amount of those herbicides used statewide. The use of 

herbicides by BLM is usually a small amount of the total use in any large watershed given the mixed ownerships 

(see also Table 4-1). The BLM’s contribution to downstream effects is minimized with SOP implementation such 

as required buffer widths and limits on application methods. In addition, many of the added herbicides pose fewer 

risks to humans, fish, and wildlife than those available under the No Action Alternative or being used on nonFederal lands. 

Treatment of invasive plants can improve water quality where riparian function improves. Alternative 3-5 target 

the same acres of invasive plants while Alternatives 4-5 treat additional undesirable vegetation (and inadvertently 

control additional noxious weeds; see the Noxious Weeds and other Invasive Plants section earlier in this 

Chapter). With additional acres treated, particularly along roads, there is more potential for off-site movement of 

herbicide to effect water quality. 

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Wetlands and Riparian Areas 

Affected Environment 

Wetlands are generally defined as areas inundated or saturated by surface water or groundwater at a frequency 

and duration sufficient to support, and under normal circumstances do support, a prevalence of vegetation that is 

typically adapted for life in saturated soil. Wetlands include bogs, marshes, wet meadows, estuaries, and swamps. 

To be designated as a wetland, the 1987 U.S. Army Corps of Engineers Wetland Delineation Manual requires: 

•		 The substrate is predominately undrained hydric soil, or the soil possesses characteristics that are 

associated with reducing soil conditions;
 

•		 The area is inundated either permanently or periodically at a mean water depth of less than 6.6 feet or the 

soil is saturated to the surface at some time during the growing season of the prevalent vegetation; and, 

•		 The land supports predominately hydrophytes. Hydrophytes are macrophytic plants with the ability to 

grow in water or on a substrate that is at least periodically deficient in oxygen (anaerobic) as a result of 

excessive water content and depleted soil oxygen levels (Environmental Laboratory 1987). 

In Oregon, the BLM manages 153,814 acres of wetlands; over half of the BLM wetlands found in the lower 48 

states and about one percent of the BLM lands in Oregon. Ninety-three percent are considered to be functioning 

properly; the remaining seven percent have not been inventoried (USDI 2007b). The BLM defines properly 

functioning wetlands as those that (Prichard et al. 2003): 

1)	 support adequate vegetation, landform, or debris to dissipate energies associated with wind action, wave 

action, and overland flow from adjacent sites, thereby reducing erosion and improving water quality; 

2)	 filter sediment and aid floodplain development; 

3)	 improve floodwater retention and groundwater recharge; 

4)	 develop root masses that stabilize islands and shoreline features against cutting action; 

5)	 restrict water percolation; 

6)	 develop diverse ponding characteristics to provide the habitat and the water depth, duration, and 

temperature necessary for fish production, water bird breeding, and other uses; and, 

7)	 support greater biodiversity. 

Wetlands partially on BLM lands range from coastal estuaries to isolated marshes within the Sagebrush Steppe 

Biome experiencing less than ten inches of precipitation per year. 

Riparian Areas occur adjacent to streams and rivers and are directly influenced by water. A riparian community 

is characterized by certain types of vegetation, soils, hydrology, and fauna and requires free or unbound water or 

conditions more moist than that normally found in the area. 

BLM lands in Oregon contain just over 8,000 acres of riparian areas, with 38 percent functioning properly, 34 

percent functioning at risk, 2 percent non-functional, and 26 percent uninventoried (USDI 2007b:Table 2-2). The 

benefits of these areas far exceed their relatively small acreage. The functions of wetland and riparian areas include 

water purification, stream shading, flood attenuation, shoreline stabilization, groundwater recharge, and habitat for 

aquatic, semi aquatic, and terrestrial plants and animals (Lewis et al. 2003). In semi-arid areas east of the Cascades, 

even intermittent streams provide opportunities for increased native vegetation and the associated benefits. 

As indicated in the East Side Riparian Biome section earlier in this Chapter (and applicable to drier parts of 

Oregon west of the Cascades as well, such as in the Siskiyou Biome), there are physical, chemical, and biological 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

linkages or interrelationships that are unique to wetland and riparian areas east of the Cascades and in the 

Siskiyou Biome. Soils within riparian areas typically contain more organic matter, clay particles, and of course 

moisture than adjacent uplands, generally allowing them to hold and process herbicides more efficiently than 

upland soils. Organic matter in riparian soils can also help promote water quality benefits such as denitrification 

(EPA 2005c). Riparian vegetation is typically more diverse and more abundant than, and is easily distinguished 

from, that in adjacent uplands. Topography helps accentuate a rapid decline in soil moisture as one moves away 

from most streams. 

Unlike the moist Western Forest Biome where plant production may not change significantly from riparian 

to upland, the limited availability of water in the remainder of the State causes native plant production to be 

concentrated in and around wetland and riparian areas. Probably the most important characteristic of semiarid wetlands and their buffers is the increased diversity and productivity of native deciduous trees and shrubs 

as compared to surrounding semi-arid grasslands (City of Boulder 2007). Riparian areas tend to be one of 

the few locations in semi-arid landscapes that possess dense, multilayered vegetation including trees, shrubs, 

and herbaceous species which provide important cover for terrestrial wildlife. Abundant leaf litter from the 

cottonwoods and other woody species provides food for aquatic insects. Cottonwoods and other riparian trees 

shade streams and provide large woody debris that dissipates stream energy and supplies cover for fish. 

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. Remnant native Willamette Prairie vegetation including 

seven species listed under the ESA (6 plants and 1 butterfly) is threatened by invasive plants in the West Eugene 

Wetlands. Non-herbicide methods of control are relatively ineffective against invasive plants in wetlands in part 

because of difficulty working effectively on wet and saturated soils. 

All wetlands and riparian areas are susceptible to invasive plants. High flow events as well as fire, wind, and 

human activities create disturbances invasive plants can exploit. Birds, recreationists, stream flow, wind, and 

other vectors readily supply the seed. Aquatic invasive plants such as reed canary grass, purple loosestrife, 

saltcedar, and Japanese knotweed grow in water or along banks, displace native plants, and adversely affect 

all riparian functions (see Water Resources). Japanese knotweed has poor bank holding capacity, which leads 

to more bank erosion and sedimentation of streams in high winter flows (USDA 2005). While knotweed may 

provide some shade, native streamside hardwoods are much taller and provide more dense shade, so knotweeddominated areas may be associated with higher water temperatures than areas with native forest communities. 

Knotweed spreads rapidly downstream in flood prone areas such as the Pacific Northwest. Knotweeds tolerate a 

wide variety of substrates from cobbles to rich soils (Tu and Soll 2004). 

Purple loosestrife is an aggressive invasive plant that outcompetes native vegetation and forms monocultures in 

the infested wetlands. It grows quickly and spreads by roots, stem fragments, or seeds (Boersma et al. 2006:76). 

On smaller streams, purple loosestrife can increase fine sediment deposition, smothering spawning gravels and 

decreasing channel capacity (USDA 2005). 

Reed canarygrass is extremely aggressive and often forms persistent, monocultures in wetlands and riparian areas. 

Infestations threaten the diversity of these areas, since the plant chokes out native plants and grows too densely to 

provide adequate cover for small mammals and waterfowl. Where the reed canarygrass grows in water, it can slow 

the movement of water carrying sediment and lead to increased siltation along drainage ditches and streams. Salmon 

spawning streams can have the gravels covered with silt and no longer be suitable for spawning. Once established, 

reed canarygrass is difficult to control because it spreads rapidly by rhizomes (WA Dept of Ecology b). 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Upland species are also found along streams where they can colonize a range of sites. Himalayan blackberry is 

the most widespread and economically disruptive of all the noxious weeds in western Oregon. It aggressively 

displaces native plant species and dominates riparian habitats (ODA 2008). Himalayan blackberry loses its leaves 

in the winter and the bare canes do not protect stream banks from rain-splash or high flow erosion in the same 

manner as native trees or wetland vegetation. The shallow root system does not protect the banks from being 

undercut. Once undercut, the banks collapse under the weight of the brambles; widening the channel. Steep 

banks, high erosion rates, and dense summer shade from the blackberry thickets make it more difficult for native 

vegetation to re-colonize the exposed banks (OSU 2006). 

Eastern Oregon has experienced a recent five-fold spread of native Western juniper that has adversely affected 

riparian areas by decreasing groundwater available to small and intermittent streams. Stream flows have 

decreased and many riparian miles have been lost in the past 50 years due to the additional water used by 

encroaching Western junipers. Removal of these Western junipers has been the focus of several projects in the 

Prineville area as a means to return streams to their historic flows. 

Environmental Consequences 

Wetland and riparian area species and function can potentially be adversely affected by herbicide use, by nonherbicide invasive weed control measures, and by the increase of noxious weeds and other invasive plants. As 

with the other resources discussed in this Chapter, the various alternatives can potentially increase the risk in one 

or more of these categories while decreasing the risk in other(s). 

Effects Common to All Alternatives 

Fate of Herbicides in Wetlands and Riparian Areas 

Herbicide drift, runoff, soil erosion, or ground water leaching could impact wetlands and riparian areas. The 

risk would be related to the amount, selectivity, persistence of the herbicide, application methods, timing of 

the application in relation to climatic conditions, and the plant species present. Accidental spills or unintended 

applications to wetlands and riparian areas would be the greatest risk and have the most impact. Herbicides 

dissipate in wetlands and riparian areas by water transport, chemical or biological degradation, and adsorption and 

immobilization in soils. Herbicides applied upland and adjacent to wetlands but moving into the wetland may 

experience increased persistence and degradation times compared to those expected in the upland area. Soil and 

water properties in wetlands or riparian areas differ from upland areas and thus the capacity to adsorb, transport, 

and transform herbicides may be affected. Soil temperatures, amount of organic matter and degree of saturation 

may change duration and storage of herbicides. Soil pH and level of oxygen present in a soil may increase 

or decrease degradation of herbicides. Generally, anaerobic degradation processes are much slower than the 

degradation processes in well-drained soils where oxygen is present (Table 4-20). 

Herbicides Used for Both Aquatic and Terrestrial Vegetation Control 

Six herbicides are registered for aquatic use by the EPA and approved for such use by the BLM nationally: 2,4-D 

(salt forms, not esters), diquat, fluridone, glyphosate, imazapyr, and triclopyr. Cautions for each herbicide vary in 

the aquatic environment. 

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 2005, 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 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Table 4-20. Herbicide Half-life in anaerobic soils 

Proposed Herbicide Half life in Anaerobic Soil (days) 

2,4-D 333 

Bromacil 144-198 

Chlorsulfuron 109-263 

Clopyralid >1000 

Dicamba Not Determined 

Diflufenzopyr 20 

Diquat >1,000 

Diuron 5-100 

Fluridone 4-270 

Glyphosate 12-70 

Hexazinone 30-180 

Imazapic >1000 

Imazapyr >500 

Metsulfuron methyl 338 

Picloram >500 

Sulfometuron methyl 60 

Tebuthiuron Not Determined 

Triclopyr TEA <1 

NS, S = non-selective or selective NA= Not Applicable NE= Not evaluated
 

If Not Evaluated (NE) then label requirements apply.
 

Solubility indirectly relates to runoff potential, if solubility number is low runoff potential is high
 

Buffer evaluated for normal low boom, 20-foot high/backpack, typical rate, spray application method, or aerial application. Buffer distances are the 

smallest modeled distance at which no risk was predicted.
 1 From ERAs
 

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). 

Diquat is used in ponds, lakes, canals, and reservoirs where no non-target species are present. It is a non-specific 

herbicide that kills plants on contact but does not kill roots, so it is used for single season control of submerged 

aquatic plants. It is persistent in the environment (up to 3 years) but is quickly adsorbed to soils and sediments, 

immobilizing it and rendering it unlikely to contaminate leachate or runoff. It is not used to treat large areas at 

one time, because decomposition of treated plants may deoxygenate water, potentially resulting in negative affects 

to aquatic fauna. 

Fluridone is a non-selective, slow-acting herbicide used in low concentrations to control submerged and 

emergent vegetation in ponds or reservoirs, lakes and canals where long-term contact with the target plants can be 

maintained to achieve control (not flowing waters). It photo-degrades, volatilizes slowly from water, and adsorbs 

to suspended solids and sediments. 

Glyphosate would be used along shorelines and banks to control grasses, herbaceous plants and some broadleaf 

trees and shrubs, and is approved for emergent aquatic vegetation in wetlands and estuaries. It may move into 

surface water with eroded soil particles (although it is unlikely it will dislodge from the particles and become 

active) where it rapidly dissipates from surface water by biodegradation and adsorption. Freshwater aquatic 

macrophytes and algae are reported to be susceptible to low amounts (20mg/l concentrations). 

Imazapyr is approved for wetlands, riparian areas, brackish (salty) and coastal waters. Used on saltcedar, 

cordgrass, reed canarygrass, phragmites, and waterlily, it may also remove non-target vegetation. Residual soil 

contamination with imazapyr could be prolonged in some areas, possibly resulting in substantial inhibition of 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

plant growth (SERA 2004d). Imazapyr is not likely to degrade in anaerobic soils or sediments, and has been 

shown to strongly bind to peat (American Cyanamid 1986, SERA 2004d). 

Triclopyr generally controls woody species in an upland environment but can be used in wetlands and riparian 

areas that go dry for part of the year. It can also be used for spot treatment of Eurasian water milfoil at low 

application rates, and purple loosestrife in riparian areas, as it does not damage native grasses and sedges. Only 

the TEA (acid) form is approved for selective control of submersed aquatic vegetation. Triclopyr BEE (ester 

form) is hazardous to aquatic life forms in maximum concentrations or spill situations where runoff to open water 

may occur. 

Herbicides Used For Terrestrial Vegetation Control 

Other herbicides may be used on or near intermittent streams during the dry season, or would be used to control 

vegetation outside of riparian areas using buffer widths applicable to the herbicide being used. However, 

non-target wetland and riparian areas could be exposed to herbicides through a variety of routes, including 

accidental spills or direct spray, local spray drift from adjacent target areas, surface water runoff, and soil erosion 

(Karthikeyan et al. 2003). Risks to wetland and riparian non-target species would depend on a number of factors, 

including the amount, selectivity, and persistence of the herbicide used; the application method used; the timing 

of the application; and the plant species present. Risks to wetlands and riparian areas from surface runoff would 

be influenced by precipitation rates, soil types, and proximity to the application area. Some herbicides (e.g., 

sulfometuron methyl) that adsorb readily onto clay soil particles could be carried off site in runoff situations, 

increasing their risk of affecting vegetation in wetlands and riparian areas. 

Unintentional applications can have severe negative impacts on wetland and riparian systems. In particular, 

accidental spills near wetland and riparian areas could be particularly damaging to wetland and riparian 

vegetation. Spray drift can also degrade water quality in wetland and riparian areas and could damage non-target 

vegetation. 

Bromacil is not selective, and accidental exposure could injure riparian shade trees and other desirable non-target 

wetland and riparian vegetation. Bromacil is mobile and has the ability to persist in wetland environments. 

Chlorsulfuron is effective at low concentrations and is prone to leaching. Hydrolysis rates are the fastest in acidic 

waters and are slower as the pH rises (Sarmah and Sabadie 2002). When hydrolysis rates drop, biodegradation 

becomes the primary loss mechanism. Strek (1998a, b) studied the dissipation of chlorsulfuron in an anaerobic 

sediment/water system; biodegradation progressed much more slowly than in aerobic soil systems, with a half-life 

greater than 365 days. 

Clopyralid is relatively non-toxic to aquatic plants. Overall, effects to non-target wetland and riparian vegetation 

from normal application of clopyralid are likely to be limited to susceptible plant species in or very near the 

treatment area, and could be avoided by maintaining an adequate buffer between the treatment area and wetland 

and riparian areas (SERA 2004b). Clopyralid is not likely to affect aquatic plants via off-site drift or surface 

runoff pathways unless spilled. 

Dicamba direct spray and accidental spill risk assessment scenarios pose a moderate to high risk to both terrestrial 

and aquatic plants. In water, biodegradation is the major mechanism for dicamba degradation. Dicamba is mobile 

in soils and is therefore likely to reach surface water and groundwater. The rates of dicamba degradation were 

generally more rapid in the surface than in the subsurface soil microcosms. The study indicated that some riparian 

wetland soils possess limited potential to degrade dicamba (Pavel et al. 1999). 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Diflufenzopyr is not approved for the treatment of aquatic plants, but poses a low risk to riparian species and 

aquatic plants via off-site drift. 

Diuron under risk assessment accidental direct spray and spill scenarios is a high risk to aquatic plants. Off-site 

drift typically poses low to moderate risk to aquatic plants, provided the ecological risk assessment-recommended 

900-foot buffer is used (ENSR 2005f). (Diuron use west of the Cascades is expected to be low and limited to 

specialized circumstances.) 

Hexazinone exposure poses a moderate to high risk for aquatic plants from acute and chronic exposures at both 

the typical and maximum application rates. Aquatic algal species are also susceptible to hexazinone exposure. It 

is also likely that aquatic macrophytes are susceptible, based on the effects of hexazinone on algae and terrestrial 

plants (SERA 1997). 

Imazapic risk to aquatic plants from accidental spills of imazapic is moderate to high at the maximum application 

rate and low to moderate at the typical application rate (there is no acute risk to aquatic plants in standing water at 

the typical application rate). Aquatic plants are generally not at risk from off-site drift of imazapic, except when 

applied aerially at the maximum application rate with a buffer of 100 feet or less. Imazapic rapidly degrades 

through photodegradation in aquatic systems (SERA 2004c). 

Metsulfuron methyl poses a low risk to aquatic macrophytes from acute exposure at upper exposure limits (SERA 

2004e). Metsulfuron methyl is stable to hydrolysis at neutral and alkaline pHs. Larsen and Aamand (2001) 

evaluated biodegradation of metsulfuron methyl (25 μg/L) under anaerobic and aerobic conditions in sandy 

sediments; the herbicide did not biodegrade under any of these conditions. 

Picloram toxicity to aquatic plants varies substantially among different species. There is low risk to susceptible 

aquatic macrophytes from acute exposure to picloram at the maximum application rate. Because picloram does 

not bind strongly to soil particles and is not rapidly degraded in the environment, it has a high potential for being 

transported to wetland and riparian areas. 

Sulfometuron methyl poses a high risk to aquatic plants from accidental direct spray and spills, and a high 

risk to susceptible and aquatic plants from drift. It poses a low risk to terrestrial plants from drift. Aquatic 

plants in standing water are typically at low to moderate risk for adverse effects from surface runoff scenarios. 

Sulfometuron methyl should not be applied during high winds, as drift could cause extensive damage to 

vegetation at a substantial distance from the application site. 

Tebuthiuron poses a high risk of adverse effects to aquatic plants under risk assessment spill scenarios, and 

potentially a high risk for adverse effects from direct spray scenarios. Aquatic plants are not at risk for adverse 

effects under scenarios involving off-site drift of tebuthiuron; however, surface runoff typically poses a risk to 

submerged aquatic plants for herbicide treatments at the maximum application rate, and at the typical application 

rate in sandy soils. Tebuthiuron is resistant to hydrolysis and photolysis in aquatic systems; however, some 

photodegradation has been reported at alkaline conditions (pH=9), and tebuthiuron is expected to biodegrade 

slowly in aquatic systems. 

Noxious Weeds and other Invasive Plant Effects – For terrestrial weeds, the various levels of weed control 

predicted to be achieved by each alternative (Table 4-4 in the Noxious Weeds and Other Invasive Plants section 

in this Chapter) will variously reduce or limit weed-induced changes to wetland and riparian vegetation, soil 

water content, and erosion in wetlands and riparian areas adjacent to streams. Removing species like blackberry, 

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saltcedar, or even Western juniper upslope will allow native species to recolonize the near stream-bank or uplands. 

Native wetland and riparian species are adapted to the unique relationship of inundation of plants or soil by water 

for various portions of the year and respond well or survive such inundations. Restoration or maintenance of 

upslope native vegetation in Western juniper encroachment areas would allow water to return to the groundwater 

system and contribute to seasonal or perennial flows, helping maintain and/or restore riparian areas. 

For aquatic weeds, six herbicides are registered for use in aquatic environments, and each is effective on specific 

weeds. Glyphosate may be used along shorelines for species such as purple loosestrife, reed canarygrass, giant 

reed, and cattail, as well as for floating aquatic species such as waterlily. It is also used to control grasses, 

herbaceous plants, and some broadleaf trees and shrubs in riparian areas. Imazapyr is used to treat emergent and 

floating plants as well as saltcedar. It is used on cordgrass, reed canarygrass, and floating plants such as waterlily. 

Triclopyr can be effective as a spot treatment for Eurasian watermilfoil because it is relatively selective for this 

species at low application rates. It can also be used to treat purple loosestrife, as it does not damage native grasses 

and sedges. Fluridone, 2,4-D, and diquat are effective treatments for Eurasian watermilfoil, and diquat also 

controls water-thyme, water hyacinth, and is the only herbicide available for giant salvinia, which is not known to 

be in the State of Oregon at this time. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

Directed livestock use would be expected to increase 6,000 acres east of the Cascades, when compared to the 

No Action Alternative, and some portion of this increase could occur within riparian and wetland areas. If 

so, directed livestock trampling on wet soils could cause soil compaction and a breakdown of soil aggregates, 

with a resultant loss of soil porosity, air and water movement, and increased density that increases resistance to 

infiltration. Increased compaction and disturbance within the wetlands could increase sediment being delivered to 

the stream or water body network. Using mechanical equipment would cause the same effects as livestock. 

Mechanical treatments using chainsaws and weed whackers, and manual pulling, could result in cut or pulled 

plants covering the treatment area and making erosion less likely after treatment, although weeds that produce 

vegetatively or that are approaching seed set are normally bagged and removed. 

There would be no effective control available for about 2/3 of the noxious weeds (Appendix 7: Table A7-1), 

and non-herbicide control treatments are generally difficult to implement in riparian areas. Specific weeds in 

riparian areas such as blackberry, Japanese knotweed, and reed canary grass would continue to spread essentially 

unchecked. The noxious weed spread rate would be expected to increase to 14 percent, increasing the likelihood 

of weeds infesting susceptible riparian habitats. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Of the four herbicides available under this alternative, most riparian and wetland treatments would be done using aquatic 

formulations of 2,4-D or glyphosate. 2,4-D has moderate to high risks of negatively affecting non-target vegetation, 

water quality, fish, and wildlife habitats in certain scenarios. Glyphosate has moderate risks under several of the same 

ecological risk assessment exposure scenarios41 (see respective sections in this Chapter). The rapid decay of these 

herbicides particularly in wetland soils that have high organic matter, high pH, and slow or no water movement during 

application, limits the impacts to root tips and aquatic life forms that are found in this environment (Voth et al. 2006). 

41 And high risk to vegetation, and to fish under spill scenarios. 

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For non-herbicide treatments, effects from directed livestock would be expected to decrease about 2/3 when 

compared to Alternative 1. Manual and mechanical effects would continue at similar rates. 

Control methods including four herbicides would be available under this alternative to effectively control all but 

about a dozen of the noxious weeds, although these dozen include hydrilla, creeping yellow cress, waterweed, 

saltcedar, watermilfoil, perennial pepperweed, and other riparian pests. Weeds would be expected to continue 

spreading at about 12 percent per year, and infest 1/3 of the BLM lands in Oregon in 15 years. Since wetlands 

and riparian areas provide favorable invasive weed habitat, it is expected they would become similarly infested. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

The additional seven to nine herbicides available under this alternative (when compared to the four available 

under Alternative 2) would permit substitution of lower risk herbicides that would be effective at lower rates. 

2,4-D and glyphosate projected annual acres would decrease by more than half when compared to Alternative 2, 

while the replacement herbicides trigger very few ecological risk assessment moderate risks for fish or wildlife, 

and only one high (fluridone at maximum rates creates a high risk to Bureau Sensitive and Federally Listed fish; 

Tables 3-14 and 3-15). Moderate risks are limited to fluridone at maximum application rate for fishpond, and 

hexazinone at typical and maximum rates for several categories of wildlife. Projected use of these two herbicides 

statewide is 500 acres per year total, with all hexazinone use expected to be outside of riparian areas. 

Effects of non-herbicide treatments would be about that same as described under Alternative 2 with the possible 

exception of the effects of prescribed fire for weed control. The 7,000 additional acres for such treatment, all east 

of the Cascades, would most likely be outside of riparian areas. Burning could release ash and other nutrients 

that could blow or be washed to nearby water, but the amount of material released from burning invasive annual 

grasses would not be expected to noticeably affect riparian areas. 

Nearly all 100-plus noxious weeds in Oregon could be effectively controlled with the tools and herbicides that 

would be available under this alternative. Further, the projected reduction of the noxious weed spread rate to 

seven percent would reduce the occurrence of new infestations by 40 percent when compared to the No Action 

Alternative. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Most of the effects expected under this alternative would be similar to Alternative 3. Use rates for several 

herbicides would go up compared to Alternative 3. While most pose low risk to riparian and wetland values, 

2,4-D and glyphosate use would increase above current use levels (Table 3-3). As noted under Alternative 2, 

2,4-D has moderate to high risks of negatively affecting non-target vegetation, water quality, fish, and wildlife in 

certain scenarios, and glyphosate has moderate risks under several of the same scenarios. The addition of diuron 

statewide, and tebuthiuron and bromacil east of the Cascades could also increase risks to riparian habitats, as all 

three additional herbicides are known groundwater contaminants. Bromacil and diuron pose a moderate risk to 

non-target plants and to various categories of aquatic and terrestrial fish and wildlife from off-site drift. 

The decrease in noxious weed spread rate to about one-half of its current rate would benefit riparian areas and 

wetlands by proportionately decreasing the likelihood of future infestations. Statewide, 2.2 million fewer BLM 

acres are expected to be infested with noxious weeds in 15 years when compared with the No Action Alternative, 

with a proportionate decrease of 22,000 acres within the wetland and riparian areas. 

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Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

This alternative is substantially the same as Alternative 4 with respect to riparian and wetlands, except for the 

availability of diquat. Diquat is added to this alternative for giant salvinia and as a substitute for fluridone if a site 

becomes resistant or some other factor prohibits that use. Two hundred acres are projected for analysis purposes. 

Diquat would only be used in water by BLM (although it is EPA registered for some terrestrial uses). It is a 

known groundwater contaminant and considered a high hazard to fish, aquatic invertebrates, and large birds, and a 

moderate risk to various other wildlife groups and non-target plants (it does not usually kill roots). 

Fish 

Affected Environment 

Fish are an important cultural, economic, and recreational resource on public lands in Oregon. Declining 

populations of fish have been a management concern. A number of species or stocks have special management 

status as Federally Listed or as Bureau Sensitive. There is additional detail about these species or populations 

(stocks) in Appendix 5. The PACFISH (USDA, USDI 2005) and INFISH (USDA 1995b) amendments to resource 

management plans in 1995 east of the Cascades, and the Aquatic Conservation Strategy standards and guidelines 

for Riparian Reserves as part of the Northwest Forest Plan (USDA, USDI 1994) west of the Cascades respond to 

concerns for the continued existence of a number of species. 

The Magnuson-Stevens Fishery Conservation Act requires the identification of habitat “essential” to conserve and 

enhance Federal fishery resources that are commercially fished. Essential Fish Habitat (EFH) is defined as those 

waters and substrate necessary for spawning, breeding, feeding, or growth to maturity (50 CFR 600.10). EFH is 

located on portions of seven of the nine BLM districts in Oregon. EFH for Chinook and Coho salmon includes 

all streams, lakes, ponds, wetlands tributaries and other water bodies currently viable and most of the habitat 

historically accessible to these fish (Pacific Fishery Management Council 2004). 

The BLM in Oregon administers lands directly affecting approximately 4,586 miles of fish-bearing streams 

and over 277,946 acres of reservoirs and natural lakes. Fish habitats range from small isolated desert springs 

in southeast Oregon to large inland and coastal rivers, such as the Columbia, Rogue, and Umpqua and their 

tributaries. 

Fish and Their Habitat 

The most significant group of native fishes found in Oregon, in terms of their ecological, cultural, and commercial 

importance, is the salmonid family. All members of this group, which includes salmon, trout, char, and whitefish, 

require relatively pristine, cold freshwater habitats during part or all of their life cycles. Therefore, they are heavily 

dependent on the conditions of the surrounding forests and rangelands to ensure their survival (Meehan 1991). 

Salmonid productivity within a freshwater system is dependent on the underlying stream productivity during the 

period of use by salmonids during their life cycle. Five general factors determine the suitability of aquatic habitat 

for salmonids: flow regime, water quality, habitat structure, food (energy) source, and biotic interactions. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

All salmonids require suitable habitat for spawning, incubation, and rearing. Generally, adult salmon require 

spawning gravel (less than 2 inches in diameter) and overhead stream bank or vegetative cover from predation. 

Eggs and newly hatched salmon (alevins) require stable gravel, cool (less than 57° F), and highly oxygenated 

water (Meehan 1991). Bull trout, which tend to spend most, if not all of their life in inland waters, require water 

less than 42° F for spawning and rearing of newly hatched young. Salmonids prefer cold water, and temperatures 

above 77° F are lethal to most species in this family (Meehan and Bjornn 1991). 

Migrant salmonids pass through several distinct habitats while traveling to and from feeding or breeding habitats, 

utilizing the full extent of the watershed. The importance of each habitat type differs by species. Chinook 

salmon, for example, spawn in the mainstem of a river. Upon emerging from the gravel, individuals either 

start their migration to the sea within their first year (ocean-type) or mature within rivers for 2 to 3 years before 

migrating to sea (stream-type). In contrast, resident trout populations, such as rainbow, bull, and cutthroat trout, 

may spend their life (5 to 6 years) in various freshwater systems, including small streams or lakes, and do not 

migrate to the sea (Meehan and Bjornn 1991). 

Various fish species have been introduced into aquatic systems throughout the Oregon. Most of the nonnative species have been introduced to promote sport-fishing opportunities. Some were introduced illegally. 

Introduced salmonids (such as brook, brown, lake, and hatchery-raised rainbow trout), centrarchids (such as 

bass and sunfish), and percids (such as walleye) now support many, if not most, of the non-native sport fishing 

opportunities within these regions (Mills 1994). 

Setting - Aquatic Systems 

Due to the topographical, geological, vegetative, and climatic variation across the analysis area, considerable 

variation in aquatic systems exists. Five general settings for aquatic systems present on BLM lands within 

Oregon are discussed below. 

The aquatic community consists of macrophytes (large aquatic plants) and phytoplankton (free-floating algae), 

macroinvertebrates (aquatic insects and clams), fish, birds, and mammals (such as muskrats and otters). All of 

these organisms are interrelated in the aquatic community through the food chain. Organisms that play a role 

in the aquatic community require a certain set of physical and chemical conditions to exist, such as nutrient 

requirements, oxygen, light, and space. 

Aquatic food chains are dependent on primary production as a source of energy within the ecosystem. For aquatic 

systems, primary production can occur in the water or out of the water in riparian areas. Numerous invertebrate 

species feed directly on primary producers through feeding functions such as grazing, scraping, shredding, and 

collecting. Other invertebrate and fish species feed on these invertebrates, which then become food for fish or 

other predators. 

Great Basin 

A portion of the western Great Basin is found in south-central Oregon and covers most of Lake and Harney 

counties. Streams in this area never reach the ocean, but are instead confined, typically resulting in terminal lakes, 

marshes, or sinks that are saline (Moyle 1976). The fish in this area are adapted to extreme conditions, and many 

have limited or very limited ranges. Trout are found in both lakes and streams at all elevations within the basin 

in Oregon (ODFW 2005), with chubs and suckers found in isolated lower reaches. Several of these are Federally 

Listed (see Appendix 5). 

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The most significant problem facing the low elevation (desert) fish is the limited water supply. Many desert fishes 

have a tenuous hold on survival under natural conditions, occurring only in the few permanent springs, rivers, and 

lakes, and their existence has been placed in doubt by human activities (Deacon and Williams 1991). 

Coast Range River Systems 

Coast range river systems are relatively short systems, with a high drainage density and flowing directly into the 

Pacific Ocean. Annual precipitation levels are high, with frequent high water events occurring throughout fall, 

winter, and spring seasons. Summer flows are provided by subsurface storage and thunderstorm events. Native 

fish species typically present include sculpin, coastal cutthroat trout, Coho salmon, Chinook salmon, chum 

salmon, rainbow trout, steelhead, southern green sturgeon, lamprey, and a few minnow and sucker species. As 

in all stream systems throughout the region, complex life history assemblages are often present for salmonid 

and lamprey species, including resident, fluvial, and anadromous life history strategies. Juvenile anadromous 

salmonids rear in fresh water for a few months to more than two years, depending on species and adult migration 

timing. Non-native species sometimes present include striped bass, smallmouth bass, and American shad. 

Coastal aquatic food chains are generally more detritus based42 than inland systems. 

Several fish stocks in this area are Federally Listed (Appendix 5). Factors negatively affecting fish habitat include 

forest management, agriculture and livestock management, dams and barriers, urban and industrial development, 

mining, and estuary degradation. 

Cascade Mountain River Systems 

Cascade Mountain river systems are generally longer than coast range systems, with a moderate to high drainage 

density, and may drain directly into the Pacific Ocean or to the Willamette or Columbia Rivers. Rivers found in 

this region include in part the Klamath, upper Rogue, upper Umpqua, McKenzie, Sandy, and upper Deschutes. 

Annual precipitation levels are moderately high, but vary considerably, depending on elevation and season. 

Summer flows are provided by snowmelt, subsurface storage, and thunderstorm events. At higher elevations, 

above migration barriers, native fish species typically present include coastal cutthroat trout, rainbow trout, 

sculpin, and dace. Bull trout43 are also present in some locations. Below migration barriers, Coho salmon, 

Chinook salmon, and steelhead are generally present, and some minnow and sucker species are occasionally 

present. Other less common native fish species are also present. Non-native fish species often include brook 

trout and, occasionally, brown trout. Food chains are more detritus based at higher elevations, with increasing 

contributions from primary production44 within the stream occurring at lower elevations. 

Several fish species or stocks in this area are listed as threatened (Appendix 5). Contributing factors are similar 

to factors negatively affecting fish habitat within the Coast Range River System but also include hybridization, 

ocean conditions, potential overfishing, and other factors. 

42 Small streams are often shaded from direct sunlight, inhibiting primary production from algae or macrophytes. 

Bacteria and fungus decompose the leaves and wood entering the stream from the forest, and in turn are eaten by 

shredder organisms. The smaller particles (detritus) shredded by the insects, and also their feces, in turn become food 

for other organisms downstream. 

43 Bull trout, Salvelinus confluentus, is a char of the family Salmonidae and native to northwestern North America. It was 

historically part of the “Dolly Varden” (S. malma), but was re-classified as a separate species in 1980. 

44 Primary productivity is the process by which organisms (autotrophs) make their own food from inorganic sources using 

solar energy to carry out metabolic processes and build cellular material. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Eastside Rangeland Stream Systems 

Stream systems occurring on rangelands east of the Cascade Mountains are long and widely spaced. The vast 

majority drain into the Columbia River, and a few drain into the Snake River and Great Basin. Major rivers in 

this area include the lower Deschutes, lower John Day, and Owyhee. The climate is generally arid, and annual 

runoff patterns tend to be dominated by annual spring snowmelt. Many headwater channels are located in isolated 

mountain ranges. Summer flows are provided by snowmelt, subsurface storage, and thunderstorm events. Native 

fish species are generally rainbow trout, steelhead, Chinook salmon, bull trout, and several minnow and sucker 

species. Catfish and other less common native fish species are also present. Non-native fish species often include 

smallmouth bass and sunfish. Primary production is important to the food chain in these stream systems. 

As with other stream systems in the State, several species/stocks are listed as threatened under the ESA (see 

Appendix 5). Threats include hydropower development, water withdrawals, irrigation diversions, siltation, and 

pollution, commercial and sport harvest, predators and altered predator dynamics, degraded riparian and instream 

habitat, water temperature, influences of hatchery fish, and non-point source pollution. 

Eastside Mountain Stream Systems 

Eastside mountain streams occur in mountain ranges east of the Cascade Mountains and include the upper 

Deschutes, John Day, and Walla Walla rivers. They are generally either the headwaters of eastside rangeland 

stream systems, or flow directly into the Columbia River system. Most precipitation occurs during the winter 

months as snow, and annual runoff generally follows a classic snowmelt pattern. Native fish species are generally 

rainbow trout and steelhead, but Chinook salmon, bull trout, and a few minnow and sucker species may also be 

present. Many Bureau Sensitive and Federally Listed fish species found in this region (see Appendix 5) are also 

found in the Rangeland Stream Systems and are partially dependent on conditions in both areas. Food chains are 

similar to those found in the Cascade Mountains, but may have a higher primary productivity component. 

Environmental Consequences 

Effects to fish can come from the vegetation treatments proposed under the alternatives, and from the differences 

in future levels of invasive plants predicted for those alternatives. Although the fish species considered in this 

document have a variety of different habitat requirements and different abilities to tolerate changes to those 

habitats, there are some broad effects that treatments would be likely to have on all aquatic habitats and species. 

In general, any activity with the potential to alter aquatic habitats or water quality would also have the potential to 

affect fish found in those habitats. 

Invasive plants or vegetation treatments may affect habitat important to one or more specific fish life history 

requirements. For instance, the spawning, rearing, and feeding requirements of a particular fish species may be 

different and specific within that species’ habitat. Therefore, effects must consider multiple life stages and thus 

the multiple habitat needs of a particular species. 

All else being equal, the potential to adversely affect fish species that are narrowly endemic would be greater than 

the potential to affect species that are more broad ranging. SOPs require vegetation treatments to be fine-tuned at 

the site-specific level to ensure that these narrow endemics are not negatively affected. 

In general, the alternatives proposed in this analysis would be expected to have short-term negative and long-term 

beneficial effects on aquatic habitats. With the SOPs and project-selected mitigation measures, it is anticipated 

that negative effects would be minimized. Most herbicide uses proposed by the alternatives, those reducing the 

effects of invasive plants or improving habitat, would have long-term beneficial effects on fish and their habitats. 

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Effects Common to All Alternatives 

The intensity and extent of treatment effects to fish and their habitat will vary, depending on several factors 

including the amount of area treated; soil type, proximity of the treatment to water, hydrologic regime and 

weather conditions during and after treatment; temperature, channel morphology and large woody debris; and 

biota present in surface water. 

Herbicide Effects 

The potential for effects on fish as a result of herbicide treatments would vary by the extent and method of 

treatment and herbicide used. Herbicides could enter water bodies and come into contact with fish or elements of 

the food chain on which they depend through drift, runoff, leaching, wind transport, accidental spills, and direct 

spraying. Potential impacts include mortality, reduced productivity, abnormal growth, and alteration of critical 

habitat. In general, risk to fish from spray drift is greater with narrower buffer zones, greater application rates, 

and greater application heights (i.e., aerial application or ground application with a high boom). Risk to fish 

from surface runoff is influenced by precipitation rate, soil type, groundwater depth, and application area. There 

would be a risk to fish associated with most accidental exposure scenarios (i.e., direct spray or spill into a water 

body). Persistent herbicides (e.g., sulfometuron methyl) adsorbed to soil particles could also be carried off-site by 

water, affecting fish in nearby aquatic areas.45 Application rate was a major factor in determining risk, with higher 

application rates more likely to pose a risk to fish under the various exposure scenarios. 

Herbicides may be toxic to aquatic plants and invertebrates, thus indirectly affecting fish by reducing primary 

production or the trophic structure of invertebrate communities. Low concentrations of herbicides can affect 

benthic46 algae communities (McCain et al. 2000). The variation in toxicity to aquatic organisms between 

different formulations for the same herbicide can be substantial (SERA, 2003a). In addition, timing of application 

can result in different effects. For example, a springtime application of glyphosate at recommended rates in a 

lake ecosystem, where dissolved oxygen levels are low or water temperatures are elevated, could be hazardous to 

young fish because decaying plants could lower dissolved oxygen levels (Folmar et al. 1979). 

All of the herbicides pose some risk to non-target terrestrial and aquatic plants, and damage to riparian and 

aquatic plants may affect fish. The sections on Vegetation, Native Plants, and Plant Communities and Wetland 

and Riparian Areas in this Chapter discuss these risks, as well as herbicide application practices that can be used 

to reduce risk. Species that depend on non-target plant species for habitat, cover, and/or food may be indirectly 

impacted by a possible reduction in terrestrial or aquatic vegetation. For example, accidental direct spray, offsite drift, and surface runoff may negatively impact terrestrial and aquatic plants, reducing the cover and food 

available to fish within the stream. 

Endocrine disrupters: Recent information has highlighted the potential for certain synthetic and natural chemicals 

to affect endocrine glands, hormones, and hormone receptors (endocrine system) (CIS 2009). EPA has just begun 

evaluating chemicals for this potential effect. Of the herbicides analyzed in this EIS, only 2,4-D is on the EPA 

Tier 1 priority list for evaluation (EPA 2009b). The EPA reports effects of endocrine disruption in animals that 

“include abnormal thyroid function and development in fish and birds; decreased fertility in shellfish, fish, birds, 

and mammals; decreased hatching success in fish, birds, and reptiles; demasculinization and feminization of 

fish, birds, reptiles, and mammals; defeminization and masculinization of gastropods, fish, and birds; decreased 

45 ecological risk assessments predicted no or low (diuron) risk to fish as a result of wind transport of herbicides on soil 

particles under all evaluated scenarios. 

46 Benthic: Of or relating to or happening on the bottom under a body of water. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

offspring survival; and alteration of immune and behavioral function in birds and mammals.” Triclopyr and 

glyphosate have been evaluated for endocrine disrupting effects, and the weight of evidence indicates that these 

herbicides cause no specific toxic effects on endocrine function (SERA 2002). 

Exposure Scenarios 

Water Contamination from Drift 

Herbicide drift is one of the mechanisms of herbicide movement when applied as a spray. Drift or offtarget movement can result in unintended injury to native plant species, contamination of surface waters, and 

contamination of ecologically susceptible areas. Drift occurs when fine droplets of liquid herbicide become 

windborne and are transported to adjacent areas. It is a physical process that depends on droplet size, weather, 

and topography rather than specific properties of an herbicide. The herbicide droplets can be subsequently 

deposited on surface waters that either contain aquatic species or serve as runoff conduits to water containing 

aquatic species. Risk assessments predicted off-site drift and resulting water body (pond and stream) 

concentrations using the computer model AgDrift. 

Drift studies typically focus on broadcast treatments using boom or aerial application. Drift associated with 

backpack (directed foliar applications) is likely to be comparatively low although studies quantitatively assessing 

drift after backpack applications were not found. Application pressure, nozzle size, nozzle type, spray angle, 

and spray volume are all factors in determining droplet size. The risk of off-site effects from spray applications 

(aerial, boom, and backpack) would most likely be related to drift. PEIS Mitigation Measures and SOPs 

applicable under all alternatives would reduce the risk of surface water contamination from spray drift. For 

example, one SOP requires the use of spray equipment delivering 200- to 800-micron diameter droplets. A 200 

micron droplet would be expected to drift about 30 feet if dropped from an altitude of 10 feet in a 3 mile-per-hour 

wind (see Water Resources section, Table 4-18). 

In certain situations, contamination of susceptible areas, wetlands, and open waters may occur during aerial 

spraying. Two herbicides included in Alternatives 3, 4, and 5 (chlorsulfuron and metsulfuron methyl) are 

of particular concern in drift situations because of the higher potential for impacts to non-target vegetation, 

which can affect fish habitat and food. The risk of direct mortality from these two herbicides is low. However, 

Alternatives 3 and 4 would not permit aerial application of any herbicide west of the Cascades, and chlorsulfuron 

aerial applications are limited by the SOPs to the typical rate. Sulfometuron methyl would also be a drift concern 

to non-target vegetation, but SOPs preclude any aerial application and it is not available west of the Cascades 

until Alternative 5. Alternative 2 does not allow the use of chlorsulfuron, metsulfuron methyl, and sulfometuron 

methyl. 

Water Contamination from Runoff, Leaching, and Percolation 

All herbicides can potentially enter streams and other water bodies through water transported by runoff, leaching, 

or percolation. Rain events could transport herbicides to waterways, and convey them to aquatic species’ habitat. 

Soil type and herbicide stability, solubility, and toxicity can determine the extent to which an herbicide will 

migrate and impact surface waters and groundwater. For example, picloram is highly soluble and readily leaches 

through sandy soil. It is also resistant to biotic and abiotic degradation processes, and can move from target 

plants, through roots, down into the soil, and into nearby non-target plants. Although relatively non-toxic to 

humans and other terrestrial species, picloram is moderately to slightly toxic to fish.47 SOPs and PEIS Mitigation 

Measures (Appendix 2) would help protect riparian vegetation when using picloram by requiring appropriate 

47 Rainbow trout had a picloram related 96-hour LC50 of 19.3 mg/l, while it was 6.3 mg/l for the technical material in 

channel catfish (Walker and Keith 1992). 

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treatment buffers. Glyphosate and 2,4-D, though very soluble, bind well with organic matter in soils. Glyphosate 

is not easily leached; 2,4-D leaching potential is considered moderate. All of the herbicides proposed for use 

under all of the alternatives are susceptible to transport in surface runoff, especially if applications are followed 

immediately by high rainfall events. However, SOPs preclude most applications if rain is imminent. 

Exposure to herbicides is plausible for fish under each alternative where herbicides are proposed for use. 

Alternative 5 poses the highest likelihood of exposing fish to herbicides, and Alternative 2 has the lowest (of 

the herbicide alternatives) likelihood of exposure. Actual effects will vary depending on the herbicides used, 

site-specific conditions, and the design of the project. Appropriate project design and application of SOPs will 

minimize or avoid exposure of fish to herbicides under all herbicide alternatives. 

Water Contamination from Accidental Spills 

The most common reason for fish-kills due to herbicide application is from the accidental entry of the herbicide 

into a stream or pond or the indirect effect of lowered dissolved oxygen (DO) in the water resulting from plant 

kill and resultant decay. Fish populations can withstand the everyday fluctuations of DO but many types of fish 

cannot tolerate prolonged periods of low DO. When large amounts of aquatic plants are killed by an herbicide 

application the decaying vegetation and lack of oxygen production may cause DO to become so low that fish 

cannot survive in the water and a fish-kill occurs. If an herbicide that is effective on higher plants and not 

phytoplankton is used, the potential for a fish-kill can be minimized because phytoplankton will continue to 

produce oxygen. Also, the likelihood of fish-kills is less in cooler water because it can hold more oxygen than 

warm water. 

The risk to fish from spill scenarios in a small pond or small stream are addressed in the ecological risk 

assessments and displayed on the risk tables. Adverse effects to fish decrease with distance downstream or away 

from the spill site because of mixing. 

Effects of BLM-Evaluated Herbicides 

As described under Risk Assessments in Chapter 3 and Appendix 8, BLM or Forest Service risk assessments are 

available for the following herbicides. For fish, the essential biological requirements (i.e., survival, growth, and 

reproduction) are the attributes to be protected from herbicide exposure. Ecological risk assessment endpoints, for 

the most part, reflect direct effects of an herbicide on fish, but indirect effects were also considered. The measures 

of effect associated with the assessment endpoints generally consisted of acute and chronic toxicity data (from 

herbicide registration documents and from the available scientific literature) for the most appropriate surrogate 

species.48 Resultant benchmarks are referred to as toxicity reference values (TRVs). 

Exposure scenarios for risk reporting were selected based on actual BLM herbicide usage under a variety of 

conditions. The exposure scenarios considered are shown on Table 3-14. 

A major potential problem associated with herbicide use is off-site drift to non-target resources. Herbicides 

drifting off site may eventually reach water bodies and contaminate fish. The AgDrift computer model was used 

to estimate off-site herbicide transport due to spray drift. The GLEAMS computer model was used to estimate 

off-site transport of herbicides in surface runoff and root zone groundwater transport. The CALPUFF computer 

model was used to predict the transport and deposition of herbicides sorbed (i.e., reversibly or temporarily 

attached) to wind-blown dust. Each model simulation was approached with the intent of estimating the maximum 

herbicide exposure concentration that could result from the given exposure scenario. 

48 e.g., bluegill sunfish for warm water species and rainbow trout for coldwater species. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Bromacil is a non-selective, broad-spectrum, systemic herbicide that can be persistent in aquatic systems. It is 

not registered for use in riparian and aquatic systems. Bromacil does not tend to bioconcentrate appreciably in 

fish tissue. Bromacil poses a low to moderate risk to fish in streams and ponds under typical and accidental direct 

spray and spill scenarios. 

Off-site drift of bromacil generally does not pose a risk to fish in streams or ponds (Table 3-14). Surface runoff 

poses no risks to fish in streams, but could pose a low acute and chronic risk to fish in ponds (there is a low 

chronic risk associated with the typical application rate, in watersheds with sand or loam soils and 10 to 50 inches 

per year of precipitation). Because bromacil has a higher affinity for water than organic carbon, it is likely to run 

off from soils into water bodies. Because of the non-selective nature of bromacil and its likelihood for runoff, it is 

not normally applied near water bodies, especially ponds. 

Chlorsulfuron is a selective, ALS-inhibitor herbicide. It is not registered for use in aquatic systems. 

Chlorsulfuron’s physical and chemical properties suggest that it is highly soluble in water, and is likely to remain 

dissolved in water and runoff from soils into water bodies. In addition, this herbicide has a long half-life in 

ponds, but is not likely to bioconcentrate in aquatic wildlife. However, none of the evaluated scenarios, including 

accidental direct spray and spill of chlorsulfuron, pose any risk to fish in streams and ponds. 

Dicamba is not registered for use in aquatic environments. The ecological risk assessment analysis shows that 

accidental direct spray and spill scenarios do not pose a risk to fish. Off-site drift and surface runoff of dicamba 

also present no risk to fish. 

Diflufenzopyr is a selective, systematic post-emergence herbicide active ingredient. It is not registered for use in 

aquatic environments. The physical and chemical properties of diflufenzopyr suggest that this herbicide would 

be removed from an aquatic environment relatively rapidly following contamination and would not appreciably 

bioconcentrate in fish tissue. The ecological risk assessment shows that diflufenzopyr does not pose a risk to fish 

under any of the ecological risk assessment scenarios. 

Diquat is a non-selective, contact herbicide the BLM proposes to use diquat to control aquatic plants.49 Plant 

species controlled using diquat include Eurasian watermilfoil, water-thyme, water hyacinth, and giant salvinia. 

One study reported the likelihood of bioconcentration in aquatic species, but other studies suggest that diquat’s 

bioconcentration potential is minimal (Howard 1991, Petit et al. 1995, MacKay et al. 1997). An accidental spill 

of diquat would pose a high risk to fish. Direct spray of diquat to ponds, as would occur with typical aquatic 

applications, would pose a low risk to fish (Table 3-14). Direct spray to streams, which are not typical application 

sites, would pose a low risk to fish. Because diquat is an aquatic herbicide, risk to aquatic organisms via off-site 

drift and surface runoff scenarios was not evaluated. 

Given the short-term risks of diquat to fish, this herbicide is used on a restricted basis, and then only in ponds 

that support very few native aquatic species because they are dominated by invasive plants or contain species not 

effectively controlled with other herbicides. Other aquatic herbicides evaluated in this EIS, fluridone, 2,4-D, and 

imazapyr also pose relatively low risk to fish and would be used instead of diquat when native aquatic species are 

present, as appropriate. 

Diuron is a broad-spectrum herbicide with a relatively short half-life and little to no impact on measured water 

49 Diquat is also registered for certain terrestrial uses, but BLM does not propose non-aquatic use. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

quality variables (Perschbaucher et al. 2004). It would not be used in riparian or aquatic habitats. Previous 

studies suggest that diuron tends to remain in the soil rather than moving into groundwater or running off into 

water bodies (Mueller-Warrant and Griffith 2005). 

Diuron has a low to moderate tendency to bioaccumulate in aquatic organisms (National Library of Medicine 

2002). Accidental direct spray and spill scenarios pose a moderate to high risk to fish (Table 3-14). When applied 

at the typical or maximum application rate, off-site drift of diuron poses no to low risk to fish. At the maximum 

application rate, off-site drift of diuron poses low risk to fish in streams and ponds under most application 

scenarios with a buffer distance of 100 feet or less. According to the ecological risk assessment, surface runoff 

poses low risk to fish in ponds in the majority of scenarios. Surface runoff also poses a low risk to fish in streams 

in watersheds with at least 25 inches of rain per year (mostly at the maximum application rate). In all cases, 

effects would be less likely in watersheds with loam soils. 

Fluridone is a slow-acting, broad-spectrum aquatic herbicide that can be used selectively for management of 

aquatic species, including water-thyme and Eurasian watermilfoil. As fluridone is relatively non-persistent, it is 

not expected to affect water quality for a substantial period of time (Muir et al. 1980). 

Fluridone has little tendency to bioaccumulate in fish (Washington Department of Health 2000). An accidental 

spill of fluridone poses moderate to high risk to fish. Direct spray of fluridone over a pond (normal application) at 

the maximum application rate poses a low risk to fish. Accidental direct spray of fluridone over a stream (aquatic 

herbicides are not typically applied to streams) at the maximum application rate poses no or low risk to fish. 

Because fluridone is an aquatic herbicide, off-site drift and surface runoff scenarios were not evaluated. 

Imazapic, an ALS-inhibitor, is a selective, systemic herbicide. It would not be used for treatment of aquatic 

vegetation, but could be used in riparian areas. Leafy spurge and the perennial mustards would be target species. 

The average half-life for imazapic in a pond is 30 days, and this herbicide has little tendency to bioaccumulate in 

fish (Barker et al. 1998). According to the manufacturer’s label, imazapic has a high runoff potential from soils 

for several months or more after application. Accidental direct spray and spill scenarios generally pose no risk to 

fish when imazapic is applied at either the typical or maximum application rate. Risk assessments show fish are 

not at risk from off-site drift or surface runoff of imazapic. 

Diflufenzopyr + dicamba is a selective, systematic herbicide, with low residence times in water bodies and a low 

bioconcentration potential (National Library of Medicine 2002). Diflufenzopyr + dicamba application does not 

pose a risk to fish under any application scenario (also see toxicity studies under dicamba and diflufenzopyr). 

Sulfometuron methyl, an ALS-inhibitor, is a broad-spectrum, pre- and post-emergent herbicide. It is not approved 

for use in aquatic systems, but could be used to treat perennial pepperweed, hoary cress, and other weeds 

associated with riparian systems if the application was made far enough from water to ensure that the active 

ingredient did not get into the water. Sulfometuron methyl has a relatively low residence time in aquatic systems, 

and bioaccumulation in aquatic organisms has not been detected (Extoxnet 1996c). 

According to ecological risk assessments, there would be no risks to fish associated with the use of sulfometuron 

methyl under any of the evaluated scenarios. Therefore, if herbicide treatments are needed in riparian areas, 

sulfometuron methyl may be able to effectively target nuisance plants without negative impacts to fish. 

Tebuthiuron is a relatively non-selective herbicide absorbed by plant roots through the soil. Tebuthiuron has little 

tendency to bioaccumulate in aquatic organisms (National Library of Medicine 2002), but may have a moderate 

residence time in water bodies (over 1 year in anaerobic conditions). 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Under an accidental spill scenario, tebuthiuron would pose a low risk to fish in ponds. Fish are not at risk from 

accidental direct spray, off-site drift, and surface runoff. 

Effects of Forest Service-Evaluated Herbicides 

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 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. 

Clopyralid is a selective herbicide most effectively used post-emergence for the control of broadleaf weeds. It 

is not registered for aquatic vegetation treatment, but can be used in riparian areas if the application does not 

impact standing water. Clopyralid is used to treat teasel, common cocklebur, and several species of thistles 

and knapweeds that could be found in riparian areas. Based on limited acute bioassays, clopyralid appears to 

be relatively non-toxic to fish. The Risk Assessment only predicted risks to aquatic organisms associated with 

accidental spill scenarios, with low risk to fish for the typical and maximum application rates. 

Glyphosate is a non-selective systemic aquatic herbicide. It can be applied as a broadcast, spot, stem injection, or 

wipe application, and is effective in controlling purple loosestrife, cattail, and in some situations, saltcedar. In general, 

glyphosate is very immobile in soil, being readily adsorbed by soil particles and subject to microbial degradation 

(Norris et al. 1991). This immobility reduces the potential for glyphosate to enter water bodies during runoff. 

Based on bioassays, technical grade glyphosate is classified as non-toxic to practically non-toxic in freshwater 

fishes (EPA 1993). Some formulations are more toxic to fish than technical grade glyphosate. At the typical 

application rate, the less toxic formulation of glyphosate poses little risk to fish, except under accidental spill 

scenarios, for which there is a low to moderate risk to fish. At the typical application rate, the more toxic 

formulation of glyphosate poses a high risk to fish under accidental spill scenarios, and a low risk under routine 

acute exposure scenarios (moderate risk to susceptible fish species). At the maximum application rate, the less 

toxic formulation of glyphosate poses a low risk to fish under acute exposure scenarios. Accidental spills for 

the maximum application rate pose moderate to high risk to fish. At this same application rate, the more toxic 

formulation of glyphosate poses a high risk to fish under accidental spill scenarios, and moderate risk to fish under 

acute exposure scenarios. Based on these data, the USEPA classified glyphosate formulation as moderately toxic 

to practically non-toxic to freshwater fishes (SERA 2003a). 

Hexazinone - According to ecological risk assessments, there is no risk to fish in ponds or streams associated with 

any exposure scenario for hexazinone (accidental spill scenarios were not modeled). 

Bioassays on the active ingredient hexazinone and commercial formulations that include hexazinone indicate that 

commercial formulations are substantially less toxic than the active ingredient alone, even when exposures are 

normalized for hexazinone levels (Wan et al. 1988). 

Imazapyr is an ALS-inhibiting herbicide used in the control of a variety of grasses, broadleaf weeds, vines, brush 

species, and aquatic vegetation. It is effective in the control of saltcedar, which dominates many riparian systems 

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in the West. Imazapyr is relatively non-toxic to fish (SERA 2004d). At the typical and maximum application 

rates, imazapyr poses no risk to fish in streams or ponds under acute and chronic exposure scenarios. For the 

typical application rate, moderate risk is predicted for susceptible fish species for accidental spill scenarios, and 

for the maximum application rate, high risk to susceptible fish and low risk to tolerant fish are predicted for 

accidental spill scenarios. 

Metsulfuron methyl is a selective ALS-inhibiting herbicide used pre- and post-emergence in the control of many 

annual and perennial weeds and woody plants. It is not registered for use in aquatic situations, but can be applied 

in riparian areas if the herbicide does not come into contact with water (SERA 2004e). Overall, metsulfuron 

methyl appears to have a very low potential to cause any adverse effects in aquatic animals. According to 

the ecological risk assessments, metsulfuron methyl poses almost no risk to fish in streams and ponds under 

accidental, acute, and chronic exposure scenarios involving application of typical and maximum rates (although 

an accidental spill at the maximum application rate poses a low risk to susceptible fish species). 

Values from 96-hour LC50 values for acute toxicity in bluegill sunfish and rainbow trout ranged from 

approximately 150 mg/L to 1,000 mg/L for both species (SERA 2004e). In rainbow trout, signs of sublethal 

toxicity include erratic swimming behavior, lethargy, and color change at concentrations around 100 mg/L, with 

a no observable effects concentration (NOEC) of 10 mg/L (SERA 2004e). One investigation did not observe any 

effects on rainbow trout hatching, larval survival, or larval growth over a 90-day exposure period, at a NOEC of 

up to 4.5 mg/L (Kreamer 1996 cited in SERA 2004e). The NOEC of 10 mg/L for sublethal effects in rainbow 

trout is approximately 100 times more susceptible than bluegill sunfish that has a NOEC of 1,000 mg/L. 

Picloram acts as a plant growth regulator. It would not be used to control aquatic vegetation. The acute and 

chronic toxicity of picloram has been assayed in various species of fish. Based on studies, the USEPA classified 

picloram acid as moderately toxic to freshwater fish (SERA 2003b). 

According to the ecological risk assessments, when applied at either the typical or the maximum application 

rate, picloram poses low risk to susceptible fish species under acute exposure scenarios. Under accidental spill 

scenarios, risks to susceptible fish are high; risks to tolerant fish are low (for both application rates). 

Triclopyr is a selective, systemic herbicide used on broadleaf and woody species, including woody species found 

in riparian and aquatic areas, such as saltcedar, willows, and purple loosestrife. Commercial formulations of 

triclopyr may contain the acid form (TEA) or the BEE form; these triclopyr derivatives are evaluated separately 

in the Forest Service risk assessment. The risk characterizations for aquatic animals differ for triclopyr TEA and 

triclopyr BEE. When applied at the typical or maximum application rate, triclopyr TEA poses no risk to fish in 

streams or ponds under acute and chronic exposure scenarios. Under an accidental spill scenario, there would be 

low risk to fish. When applied at the typical rate, triclopyr BEE would pose a moderate risk to fish under acute 

exposure scenarios, and a high risk to fish under a scenario involving an accidental spill into a stream or pond. 

Triclopyr acid would pose a moderate risk to fish under an accidental spill scenario involving the maximum 

application rate. Triclopyr BEE would pose a high risk to fish under acute exposure scenarios at the maximum 

rate, and high risk to fish as a result of an accidental spill into a stream or pond. 

Some effects may be anticipated for fish under certain conditions. While there is a major difference in the 

potential hazards posed by triclopyr TEA forms (which are registered for aquatic use) and triclopyr BEE forms 

(which are not registered for aquatic use) to fish, there are no significant differences among species in terms of 

sensitivity to the various agents. Sublethal effects of triclopyr BEE on salmonids occur at concentrations between 

0.32 and 0.43 mg/L, where fish were lethargic, while behavioral changes to triclopyr TEA would occur at 200 

mg/L. Subchronic toxicity in fathead minnows (at the embryo-larval stages) was observed when the fish were 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

subjected to 140 mg/L of triclopyr TEA for 28 days (Mayes et al. 1984, Mayes 1990, all cited in SERA 2003c). 

This study found that survival of these minnows was greatly reduced at this toxicity level. 

Although triclopyr BEE is more toxic than triclopyr TEA, the risk of triclopyr BEE to fish is low, as this form will 

rapidly hydrolyze to triclopyr acid, lowering risk to fish. 

Summary of Herbicide Effects 

The risk characterization process of the ecological risk assessment suggested that chlorsulfuron, dicamba, 

diflufenzopyr, diflufenzopyr + dicamba, and sulfometuron methyl are very safe to fish, as there is no risk 

associated with use of these herbicides under any of the evaluated scenarios, including accidental direct spray 

or spill. In addition, imazapic does not pose a risk to fish, except when directly sprayed over a stream at the 

maximum application rate. There is no risk to fish associated with off-site drift of bromacil or tebuthiuron. Under 

surface runoff scenarios, diuron can present a moderate to high risk to fish if applied at the maximum application 

rate. The risks to fish associated with application of aquatic herbicides to ponds and streams is greater for 

diquat than for fluridone, which when applied at the typical application rate only poses a risk in streams (aquatic 

herbicides are not typically applied to streams; therefore, this is an accidental scenario). 

The ALS-inhibiting herbicides evaluated in this EIS are chlorsulfuron, imazapic, imazapyr, metsulfuron methyl, 

and sulfometuron methyl (all terrestrial herbicides). These herbicides are considered to be highly potent to 

plants and are applied at low application rates because only small concentrations are necessary to damage plants. 

However, the process they inhibit is unique to plants. There is low risk associated with direct spray of imazapic 

or imazapyr at the maximum application rate. However, this risk is similar to or less than risks associated with 

the other evaluated herbicides, and could be avoided by applying at the typical application rate. Their very low 

typical rates could mean there is less risk of off-site transport associated with their use. 

Adjuvants, Degradates, Inert Ingredients, and Tank Mixes 

Adjuvants - The BLM reviewed toxicity data for adjuvants, such as surfactants and anti-foam agents, 

to assess risks to fish. In addition, the GLEAMS model was used to evaluate the risks associated with 

polyoxyethylenamine (POEA), a surfactant found in some glyphosate formulations that is more toxic to fish than 

glyphosate itself. This adjuvant is of greatest concern in terms of potential effects to fish. Using the GLEAMS 

model, the BLM predicted the portion of an adjuvant that would potentially reach an adjacent water body via 

surface runoff. 

Based on GLEAMS modeling for POEA, risks to aquatic organisms were not predicted for the majority of pond and 

stream scenarios involving exposure to this adjuvant. However, risks were predicted (using the most conservative 

acute endangered species LOC) for applications at a distance of 0 feet from the water body. This scenario, which 

essentially assumes a direct application to the water body with no dilution or drift, is highly conservative and highly 

unlikely under BLM application practices. Risks to Bureau Sensitive and Federally Listed aquatic organisms in 

streams and ponds were also predicted for aerial applications of POEA at the maximum rate at a distance of 100 

feet from the water body. However, it is unlikely that the BLM would apply glyphosate formulations containing 

POEA in an area known to contain Bureau Sensitive and Federally Listed aquatic species. Because of a lack of 

physical chemical property information, POEA was not modeled for leaching properties and runoff to water bodies. 

Therefore, there is some uncertainty associated with risk to fish from this exposure. 

Degradates - 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 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

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. The BLM conducted a detailed analysis of degradates for herbicides proposed 

for use under the herbicide treatment program. Several databases, including USEPA’s ECOTOX database (EPA 

2009a), were searched, and relevant aquatic toxicity data for degradates were identified and considered in the risk 

assessments (Appendix 8). 

In most cases, predicted risks to fish from degradates would likely be less than risks from the active ingredients 

diquat, diuron, imazapyr, and metsulfuron methyl predicted in ecological risk assessments. For some degradates 

associated with 2,4-D, diuron, fluridone, and triclopyr, selected aquatic species may be more susceptible to the 

degradate than to the active ingredient. These findings should be considered in the context of herbicide use 

practices, the concentration of degradate relative to the parent compound, the process of degradate production, 

and the body of available toxicity data. For instance, in most cases, the increased toxicity of the degradate may be 

offset by the fact that only a minute amount of the degradate is produced, which would likely disperse rapidly in 

an active aquatic system. 

Other Ingredients - Relatively little toxicity information was found on inert ingredients during preparation of the 

BLM ecological risk assessments. 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 ten herbicides examined. However, some of the inerts, particularly the EPA List 3 compounds (inert ingredients 

of unknown toxicity) and unlisted compounds, may potentially be moderately to highly toxic to aquatic species 

(based on information in Material Safety Data Sheets or published data). 

Based on GLEAMS modeling of a generalized inert compound in a “base case” watershed, concentrations of 

inert ingredients exceeded concentrations of herbicide active ingredients under all stream and pond scenarios. 

In general, greater exposure concentrations of inerts occurred under higher application rates, exceeding 1 mg/L 

for the maximum pond application scenario. These results suggest that inerts associated with the application of 

herbicides may contribute to acute toxicity to fish if they reach the aquatic environment. However, given the lack 

of specific inert toxicity data, this statement may overestimate their 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. SOPs and PEIS Mitigation Measures should make adverse effects to 

fish negligible. 

Tank Mixes - Risk assessment analysis of tank mixes indicates that risks to fish vary by tank mix. The risks to fish 

associated with applications of tank mixes of bromacil plus sulfometuron methyl, and diflufenzopyr + dicamba is 

no greater than those associated with applications of bromacil, imazapic, or diflufenzopyr alone. Risks to fish for 

a tank mix of chlorsulfuron and diuron are greater than those for chlorsulfuron (but not diuron) alone, and risks 

for a tank mix of sulfometuron methyl and bromacil are greater than for bromacil applied alone. 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. 

Invasive Plant Effects 

Riparian systems are being invaded by non-native species, which are generally detrimental to native aquatic 

species. Potential adverse effects to aquatic species are also described in part under the Water Resources and 

Wetlands and Riparian Areas sections in this Chapter. Invasive plants are generally less efficient at holding soil 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

in place, and cause water-quality problems. Whenever the water quality of a fish-bearing stream is affected, so 

are fish. Specifically, fish are affected by turbidity, sedimentation, loss of large organic debris, loss of shading 

(and associated temperature increases), and exposure to hazardous substances. Erosion increases turbidity and 

sedimentation that can reduce fish feeding success. Severe cases of sedimentation can keep fry (early-stage fish) 

from emerging, or fill in or reduce the deeper pools preferred by fish, especially trout. 

In riparian areas, invasive plants (e.g., Himalayan blackberries, reed canary grass, saltcedar, Japanese knotweed) 

often support fewer native insects than native plant species, which could affect food availability for insectivorous 

fish species, such as salmonids. The replacement of native riparian plant species with an invasive plants may 

adversely affect stream morphology (including shading and instream habitat characteristics), bank erosion, and 

flow levels. Invasive plants break down the complex natural vegetative physical structure and interfere with 

natural processes. 

Problematic invasive plants that would be treated by the BLM using herbicides include water-thyme and Eurasian 

watermilfoils, which are found in ponds, lakes, and streams; and perennial pepperweed, saltcedar, knapweed, 

and thistles, which are found in riparian habitats. These species displace native vegetation and decrease species’ 

diversity. Dense concentrations of aquatic plants can reduce light penetration and lower the concentration of 

dissolved oxygen in the water and can upset the balance of the fish community by providing too much cover 

for small fish (Payne and Copes 1986). Many invasive riparian plants form monocultures that crowd out more 

desirable native plant species. 

Treatments that reduce or slow the spread of noxious weeds and other invasive plants would decrease the 

incidence of these adverse effects. Alternative 2 is predicted to result in about 1/3 of BLM lands in Oregon 

becoming infested with noxious weeds in 15 years, with Alternative 3 about 1/4, and Alternative 4 closer to 1/5th. 

These proportions would be expected to apply or be similar for riparian areas; weeds could spread even faster in 

these areas because of flood disturbances, water transport, and affinity of many plants for wetter areas. 

Non-Herbicide Treatments Effects 

Manual and Mechanical Treatments - Certain manual and mechanical treatments within riparian areas that 

disturb soil, such as grubbing and pulling, carried out over a large area, may lead to increased erosion and stream 

sedimentation. Resultant sedimentation may adversely affect fish by covering eggs or spawning gravels, reducing 

prey availability, or directly harming fish gills, reducing stream carrying capacity for fish. However, the risk of 

harm to aquatic ecosystems due to fine sediment production from manual treatment or use of motorized hand 

tools is low, and short-term, resulting in effects likely to be localized and minor. However, depending on the 

scale of treatment, pulling significant numbers of large plants or treating large riparian areas with motorized hand 

tools may moderately increase the risk to fish. Cut vegetation not in danger of contributing invasive plant seeds 

or sprouting matter to the site (including any cut non-target vegetation) left on the treatment site can reduce the 

potential for erosion and subsequent sediment delivery to streams or other water bodies. 

The risk of harm to fish from use of wheeled or tracked machinery will vary, depending on the extent of treatment 

area and proximity to aquatic environments; vehicle tracks can compact soils and divert waters. Fish are temporarily 

affected when water is affected by turbidity, sedimentation, and local increases in surface water runoff. However, 

all wheeled equipment (including OHVs containing spray mix and other herbicide application equipment) would 

normally be kept well away from riparian areas to minimize aquatic effects and the risk of water-affecting spills. 

Some kinds of equipment, such as walking brush-cutters, are designed to minimize ground disturbance. 

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Power-tool use near water can potentially cause water contamination with minor amounts of chainsaw oil or 

minor fuel spill. An oil skim on water, while highly unlikely, can deplete oxygen levels and cause fish kills. This 

effect is more likely for fish living in ponds than for fish living in rivers or streams, since the flow of water in 

streams would move and disperse small amounts of oil. 

Directed Livestock - The use of livestock to control invasive plants requires a highly specialized operation, often 

involving animals that are “trained” to forage on the target plant, and usually involving temporary fencing to 

keep the animals within the target area. The livestock species, grazing intensity, and management of the grazing 

animals used to treat invasive plants are different from grazing for livestock production. Also, the specific 

use of livestock in this type of control effort has not been utilized extensively in riparian areas or near aquatic 

ecosystems. Current techniques for using directed livestock as an invasive plant treatment tool are not likely to 

have adverse effects on riparian areas and aquatic environments. 

Prescribed Fire for Weed Control - The risk of harm to fish from prescribed fire for weed control depends on fire 

intensity, timing, and land form, among other factors. Prescribed burning has the potential to bare large areas 

of soil, and thus increase both surface erosion and sedimentation of streams. Heavy runoff from burned areas 

can increase water pH, indirectly affecting aquatic biota. Site-specific implementation of the SOP and PEIS 

Mitigation Measure buffers and other measures, as well as the ESA National Fire Plan Consultation Process, 

would prevent this method from being used where significant adverse stream effects would occur (NFP 2005). 

Biological Controls and Seeding/Planting - No adverse effects to fish are anticipated from either of these nonherbicide processes. 

Effects by Alternative – Non-Special Status Fish 

Alternative 1 – No Herbicide Use 

Under Alternative 1, no herbicides are proposed for use and therefore fish would not be affected by BLMapplied herbicides.50 Effects could stem from other vegetation treatment methods however. Ecosystem benefits 

resulting from vegetation treatment would be reduced under this alternative when compared to the No Action 

Alternative, in part because about 2/3 of the noxious weeds cannot be effectively controlled without the use of 

herbicides. Treatment methods, such as mechanical methods and prescribed fire can result in soil disturbance and 

sedimentation in aquatic bodies, and retreatment in the same areas is more likely because a single treatment is less 

likely to adequately achieve control. 

Specifically, it is often difficult to control or eradicate some species, such as aquatic species and those that 

resprout from rhizomes, by means other than herbicide application. For example, Eurasian watermilfoil forms a 

dense mat that crowds out native aquatic plants and degrades fish habitat (Bossard et al. 2000), and in some cases 

herbicide treatments, including the use of 2,4-D, diquat, and fluridone, are more effective than other treatments, 

such as mechanical harvesters that tend to fragment and spread the weed. The only alternatives to herbicide 

treatment of submersed vegetation are mechanical or manual removal; water drawdown on controlled reservoirs, 

lakes, and ponds; and flooding with salt or brackish water. These treatments generally are not as effective as 

herbicide treatments at controlling many invasive aquatic plants (Aquatic Ecosystem Restoration Foundation 

2004). Alternative 1 would be more likely to leave some invasive aquatic plants largely uncontrolled, potentially 

resulting in displaced native species and degraded and reduced fish habitat. 

50 There would still be herbicides in the system, even on BLM lands, because of herbicide use on adjacent lands. 

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Non-herbicidal treatments are generally less effective than herbicides on many terrestrial riparian species as 

well. Knotweed is not controllable without using herbicides because the plant has roots and rhizomes that extend 

to depths of up to seven feet and spread out over distances of 20 feet or more. Bennett (2009) after reviewing 

several methods used to eliminate blackberries found that without the use of herbicides, projects were generally 

not successful at eradication nor cost effective. 

Under this alternative, without the use of herbicides, noxious weed populations are projected to increase 14 

percent per year and occupy 2.7 million more acres of BLM lands in 15 years than the No Action Alternative. 

The spread of invasive and noxious plant populations would cause further damage to susceptible native plant 

communities, including riparian communities that directly or indirectly provide habitat for fish. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Effects to fish would be similar to those that are presently occurring. About a dozen noxious weed species are 

not susceptible to the four herbicides available under this alternative, and herbicides cannot be used to treat nonnoxious invasive plants. 

Herbicide Effects 

Based on Forest Service ecological risk assessments, chronic (long-term) and acute (short-term) exposures 

modeled for all herbicides in this alternative except acute exposure for glyphosate did not exceed the NOEC for 

any fish. For glyphosate, the ecological risk assessment modeling predicted low to moderate risks from acute 

exposures at typical and maximum application rates. 

It is unlikely that the use of herbicides proposed in this alternative would cause fish kills at the concentrations 

likely to occur in water. Mortality to fish is also not expected or likely from operational use, because dilution, 

degradation, adsorption, and other factors reduce the amount of herbicide that could enter a water body. In rare 

circumstances, high concentrations of herbicides could wash into streams from rainfalls shortly after herbicide 

application along road ditches or other surfaces that rapidly generate overland flows, or as a result of an accidental 

spill. In such instances, localized fish kills are plausible in small tributary streams or small enclosed water bodies 

where contaminated flows would not be readily diluted. 

Invasive Plant Effects 

Noxious weeds would be expected to continue spreading at about 12 percent per year on BLM lands in Oregon. 

In addition, the inability to treat other non-noxious invasive plants with herbicides increases the likelihood 

additional plants will become well established before they are declared noxious. The spread of invasive and 

noxious plant populations at current rates would continue to cause damage to native plant communities, including 

riparian communities, which directly or indirectly provide habitat for fish. The continued spread of invasive plant 

populations will have harmful effects on fish. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Herbicide Effects 

Based on ecological risk assessments, chronic (long-term) and acute (short-term) exposures modeled for 

chlorsulfuron, clopyralid, fluridone, hexazinone, imazapic, metsulfuron methyl, and sulfometuron methyl 

(herbicides added by this alternative to the four discussed in Alternative 2) did not exceed the NOEC for any 

fish (Table 3-14 and Table 3-15). Two herbicides in this alternative and not included in Alternative 2, imazapyr 

and triclopyr, were found to have high risk under certain scenarios. Imazapyr was found to have high risk for 

susceptible (coldwater) fish in an accidental spill scenario at the maximum exposure. Modeling for triclopyr 

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found a high risk to susceptible (coldwater) fish in the accidental spill scenario at both the typical and maximum 

application rates, and a high risk for susceptible (coldwater) fish in the acute exposure scenario. 

Based on the results of the ecological risk assessments, it is unlikely the fish species would be harmed by 

herbicide use proposed in this alternative. 

As this alternative proposes to treat 13,600 more acres than Alternative 2, it could potentially result in greater 

exposure to fish. However, 12,600 acres of this increase will occur in eastern Oregon uplands generally away 

from streams. Also, the BLM’s ability to use up to nine additional herbicides (see Table 3-3), and thus reduce the 

total pounds of herbicide applied by 30 to 50 percent, would reduce risks to fish when compared to the No Action 

Alternative. For example, fluridone shows no risks to fish at typical application rates and could replace other 

aquatic herbicides currently used by the BLM on public lands. Also, the use of glyphosate would decrease more 

than 50 percent under this alternative. 

Imazapic, chlorsulfuron, clopyralid, and metsulfuron methyl would primarily be used east of the Cascades, but 

could still provide benefits greater than those under the No Action Alternative. These herbicides could be used to 

control biennial thistles, annual and perennial mustards, knapweeds, starthistle, knapweeds, and cheatgrass. These 

invasive plant species degrade riparian and upland habitats and can contribute to shortened fire cycles, followed 

by soil erosion and sedimentation. 

Under accidental direct spray, spill, and off-site drift scenarios modeled in the ecological risk assessment, 

imazapic presents a very low or no risks to fish, similar to chlorsulfuron, and sulfometuron methyl but lower than 

the risks associated with other herbicides currently being used. 

Ecological risk assessments for chlorsulfuron, dicamba, imazapic and sulfometuron methyl predict no risk to 

fish from direct spray, off-site drift, surface runoff, or accidental spill to a pond (Table 4-17). For the surface 

runoff scenarios, risks to fish were not predicted for chlorsulfuron, fluridone, imazapic, and sulfometuron methyl. 

Glyphosate and triclopyr do present risk to fish under some application scenarios. Each of the four currently 

available and nine additional herbicides that would be available under this alternative has different properties (e.g., 

mode of action), different suggested uses, and is most effective/least risky in different scenarios. This suggests that 

the more herbicides available for use, the more opportunities there would be to select one or more during projectlevel design that would present the least risk to fish while accomplishing the specific weed control objective. 

Fluridone is an aquatic herbicide that would be available under this alternative to control submerged aquatics 

including Eurasian watermilfoils and hydrilla. The fluridone ecological RA (Table 3-15) predicts no risk to fish 

from direct spray in a pond (fluridone is not used in streams). However, the ecological risk assessment predicts 

risk to fish may occur when fluridone is spilled directly into a pond. Fluridone is slow acting and is used at 

low concentrations on both submergent and emergent plants. As the plants die off slowly, there is not a large 

concentration of decaying organic matter added to the water at one time so it is less likely to deoxygenate the 

water and kill fish than other aquatic herbicides. 

It is very unlikely that implementation of aquatic vegetation control under this alternative will result in a fish-kill. 

Fish have avoidance mechanisms and are mobile allowing them to move to other parts of a lake or stream in order 

to avoid adverse conditions. However, under certain circumstances such as an accidental spill in an enclosed 

water body or small fish-bearing stream, fish-kills could occur. 

The effects of using glyphosate for control of Sudden Oak Death are expected to be de minimus because the BA 

specifies use of the less toxic form and specifies other project design criteria protective to fish (see the Pest and 

Diseases section earlier in this Chapter). 

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Invasive Plant Effects 

Under this alternative, the noxious weed spread rate is projected to be reduced to 7 percent per year, and noxious 

weeds are projected to infest 1.9 million fewer acres of BLM lands in 15 years than the No Action Alternative. 

Although Alternative 3 would prevent more invasive plant infestations, their continued spread would continue to 

damage native plant communities, including riparian communities that directly or indirectly provide habitat for 

fish. This continued, albeit reduced, spread will have harmful effects on fish. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

This alternative could result in potential adverse effects to fish. However, acute (short-term) herbicide exposures 

to aquatic organism are not likely to result in harm under foreseeable conditions, and the expected reductions in 

adverse fish effects from the additional control of invasive plants exceeds the potential herbicide risk to fish. 

Herbicide Effects 

Based on ecological risk assessments, bromacil, diuron, and tebuthiuron51 modeling predicted risks to fish 

in certain scenarios (Tables 3-14 and 3-15). Bromacil has a low or moderate risk at typical and maximum 

application rates for most scenarios modeled with the exception that it had no risk to fish in the surface runoff 

scenario for a pond or stream. Diuron has high or moderate risk to fish in most scenarios modeled. No and low 

risk to fish from diuron was found for the off-site drift or surface runoff scenarios. For tebuthiuron, no risks to 

fish were recorded except for low risk during an accidental spill to pond at maximum application rate. The use 

of these materials along rights-of-way could pose additional exposure opportunities for fish as roadside ditches 

and unobserved culverts and seeps could lead to nearby streams, particularly if materials are not well bound by 

the onset of the next precipitation event. However, little use of these materials is proposed west of the Cascades 

where these conditions are most likely to be encountered. 

Other herbicide use would increase as well. The acres of 2,4-D, glyphosate, and picloram would approach 

current (Alternative 2) levels, as these material would be used to treat native vegetation along rights-of-way and 

in habitat improvement areas. The risk to fish from herbicides would be higher under this alternative than under 

Alternatives 2 and 3 because of additional acres treated, additional pounds used, and use of boom spraying along 

roads. The improved effectiveness of this alternative at slowing noxious weeds would more than compensate for 

this risk, and SOPs and PEIS Mitigation Measures (Appendix 2) would minimize it. 

Invasive Plant Effects 

Under this alternative, the noxious weed spread rate is projected to decrease to 6 percent per year, and noxious 

weeds are projected to infest 2.2 million fewer acres in 15 years than under the No Action Alternative. Although 

invasive plants would continue to spread under Alternative 4, that spread would be minimized and native riparian 

communities that directly or indirectly provide habitat for fish would be more likely to remain uninfested. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Herbicide Effects 

As this alternative proposes to treat slightly more acres and use more herbicides than Alternative 4, there is a 

slightly greater potential for negative effects to fish. Based on ecological risk assessments, diquat has a moderate 

risk to fish from direct spray to a stream at maximum application rates, and high risk for the accidental spill to 

51 These are the three additional herbicides that would become available under this alternative, in addition to those 

discussed under Alternatives 2 and 3.
 

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pond scenario. However, diquat is an aquatic herbicide so it is not used where fish kill must be avoided. The 

ecological risk assessment for diflufenzopyr + dicamba found no risks to fish in any of the scenarios modeled. 

Although the effects to fish in this alternative are very similar to Alternative 4, this alternative would result in the 

highest likelihood of adverse effects to fish because it proposes the most treatments (300 percent more acreage 

than would be treated with herbicides under the No Action Alternative, and 30 to 70 percent more pounds using 

the typical and maximum application rates respectively). However, based on the results of the ecological risk 

assessments, it is unlikely the fish species would be harmed by the herbicide use proposed in this alternative. 

Invasive Plant Effects 

The spread of invasive plants and its effects on fish habitat would be essentially the same as under Alternative 4. 

Effects by Alternative – Special Status Fish 

There are potential risks to Bureau Sensitive and Federally Listed fish species (managed under the Special Status 

Species program, and referred to as special status fish). Although the predicted risks for adverse health effects to 

individual fish are the same as those predicted for non-special status fish, the associated population-and specieslevel effects would be much greater for many special status fish species because of their limited/fragmented 

distribution and limited population size. Risks to special status fish would be minimized by following SOPs and 

PEIS Mitigation Measures including those specific to special status fish, and following the BLM’s special status 

species policies. 

The invasion and spread of non-native plant species into aquatic and riparian habitats may affect certain 

populations of special status fish. An overview of the ways in which non-native aquatic and riparian plants may 

affect aquatic habitats is presented earlier in this section. Numerous listed fish are threatened by the changes in 

water quality and flow which may result from weed infestations. Salmon, for example, require a high level of 

dissolved oxygen, which is reduced when aquatic weeds such as Eurasian watermilfoil and water-thyme invade an 

aquatic system. A decrease in dissolved oxygen associated with the encroachment/excessive growth of vegetation 

has also been listed as a threat to the Foskett specked dace in south-central Oregon (USFWS 1985). For species 

such as these, herbicide treatments to reduce coverage of non-native plant species in aquatic and riparian habitats 

would likely improve habitat over the long term. 

Numerous special status fish, however, are most threatened by changes in water levels and quality associated 

with development, upslope land use practices, and groundwater pumping, and the expansion of non-native fish 

populations. For most fish, invasions of non-native plant species into riparian and aquatic habitats have not been 

listed in Conservation Strategies and other documents as threats to the species’ survival. For these fish, health 

risks and increased inputs of chemicals into the water associated with herbicide spraying could outweigh any 

habitat improvements resulting from minimized weed infestations. In addition, some herbicide treatments could 

have short-term adverse effects on special status fish by killing non-target native vegetation and reducing the 

overall cover of riparian vegetation that regulates water temperature through shading. 

Adverse effects to water quality from the spread of invasive plants vary by alternative as described earlier in this 

section. Damage to watersheds, streambanks, and riparian areas by invasive plants is more significant for special 

status fish because populations are already weakened or stressed. 

A more conservative LOC of 0.05 was used to determine risks to special status fish. The potential effects of 

herbicides on special status fish could be greater than the effects on non-special status fish and other aquatic 

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organisms (an LOC of 0.1 was used for non-special status species), as shown in Tables 3-N and 3-O.52 Aquatic 

herbicides with the greatest likelihood of impacting special status fish during a normal application to an aquatic 

habitat include diquat and the more toxic formulation of glyphosate. Normal aquatic applications of 2,4-D and 

imazapyr would not pose a risk to special status fish. 

Terrestrial herbicides with the greatest likelihood of impacting special status fish as a result of a spill, drift, 

accidental direct spray into an aquatic habitat, or surface runoff are diuron, picloram, and the more toxic 

formulation of glyphosate. According to ecological risk assessments, there would be no risks to fish associated 

with chlorsulfuron, dicamba, diflufenzopyr, imazapic, diflufenzopyr + dicamba, or sulfometuron methyl. 

Alternative 1: No Herbicide Use 

There would be no impacts from herbicide exposure from BLM vegetation treatments. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Control of weed infestations in aquatic and riparian areas would be less extensive under this alternative than under 

the other herbicide-use alternatives. Therefore, the degree of benefit to special status fish, particularly species 

that are currently threatened by infestations of non-native plants, would likely be lower than under the other 

herbicide use alternatives. However, short-term adverse impacts to habitats that support special status fish (such 

as increased water temperatures) would be lower as well. The degree of benefits versus impacts to these habitats 

from treatments would largely depend on where the treatments occurred. 

Considering acreage alone, it is likely that special status fish would be exposed to herbicides far less under this 

alternative than under the other herbicide-use alternatives (Alternatives 3, 4, and 5). However, mitigation would 

be required to protect these species and their habitat from harm under all alternatives, which should minimize 

differences in risk to special status species. 

Under this alternative, 2,4- D, glyphosate, and picloram could be used in aquatic and riparian habitats. The 

herbicide not registered for aquatic use (i.e., dicamba) could also be used in riparian areas, provided the herbicide 

did not contact the water. Of these herbicides, only glyphosate is likely to pose toxicological risks to special 

status fish during a normal application, but only if the more toxic formulation is used, or the less toxic formulation 

is applied at the maximum application rate. In all areas with special status fish, typical rate application of the 

less toxic aquatic form of glyphosate is normally specified. Although there would be risks to fish in accidental 

spill scenarios, continuing to use these herbicides to treat riparian and aquatic vegetation would pose a low risk to 

special status fish. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

The greater number of acres expected to be treated in aquatic and riparian habitats than under Alternative 2 could 

potentially result in greater impacts to special status fish. However, risk from normal use would remain minimal, 

provided glyphosate only the less toxic formulation of glyphosate was applied at typical application rates. The 

availability of additional herbicides, include five registered for aquatic or riparian use, could reduce risks to 

fish. For example, fluridone shows no risks to fish at typical application rates and could replace other aquatic 

herbicides currently used by the BLM on public lands and would pose no to moderate risks to fish depending on 

52 Risks for BLM-evaluated herbicides, Table 3-14, were calculated with a lower LOC as described. For FS-evaluated 

herbicides, the “susceptible” category was used as a proxy for special status fish. 

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the application rate and type of aquatic habitat. Chlorsulfuron, dicamba, imazapic, or sulfometuron methyl pose 

no risk to fish. Therefore, these herbicides would provide the BLM with increased safe options for treating near 

special status fish. 

Acute (short term) herbicide exposures to special status fish are not likely to result in harm under foreseeable 

conditions under this alternative. Since more terrestrial herbicides would be used under this alternative, risks 

associated with accidental spill of those herbicides in or near a water body, and accidental direct spray into a water 

body, would be greater than under the other alternatives. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

This alternative includes the use of 2,4-D, dicamba, glyphosate, picloram, bromacil, chlorsulfuron, clopyralid, 

diuron, fluridone, hexazinone, imazapic, imazapyr, metsulfuron methyl, sulfometuron methyl, tebuthiuron (east of 

the Cascades only only), and triclopyr. As this alternative proposes to treat more acres and use more herbicides, 

there are greater positive and negative effects to special status fish. 

The herbicides used in riparian and aquatic areas to treat invasive vegetation, as well as the quantity of herbicides 

used and the methods of application, would not be substantially different than for Alternative 3. Risks to special 

status fish from these herbicides and uses would remain minimal, provided glyphosate was only applied at typical 

application rates, and only the less toxic formulation was used. However, since additional, generally more toxic 

herbicides would be made available for native vegetation treatments (albeit away from water bodies), risks 

associated with accidental spill of those herbicides in or near a water body, and accidental direct spray into a water 

body, would also be greater than under the other alternatives. 

Roads often parallel streams or have multiple stream crossings. Roads often act as extensions of stream networks 

with roadside ditches sometimes having low but measurable concentrations months after treatment (Wood 

2001). Herbicides used along road rights-of-way could reach streams even when buffers to the actual stream are 

applied. Picloram and the more toxic formulations of glyphosate are the biggest risks. Having a greater number 

of herbicides from which to choose, and recognition of this issue during project design, including consideration of 

special status species and the application of SOPs and PEIS Mitigation Measures, would reduce potential impacts 

to water quality from herbicide applications. 

Acute (short term) herbicide exposures to aquatic organism are not likely to result in harm under foreseeable 

conditions, and the expected reductions in adverse fish effects from the additional control of invasive plants 

exceeds the potential risk to fish from the proposed herbicide applications 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Based on acreage, this alternative would entail the greatest amount of herbicide exposure to special status fish. 

Although a slightly greater amount of herbicides would be used in aquatic and riparian habitats than under the 

other alternatives (most additional treatments under Alternatives 4 and 5 would be outside of riparian areas), 

risks to special status fish from their normal use would remain minimal, provided glyphosate was only applied at 

typical application rates, and only the less toxic formulation was used. However, since more terrestrial herbicides 

would be used under this alternative as well, risks associated with accidental spill of those herbicides in or near a 

water body, and accidental direct spray into a water body, would also be greater than under the other alternatives. 

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Diquat would become available under this alternative. Diquat would likely be used only where the other five 

aquatic herbicides would not accomplish weed control objectives, specifically giant salvinia if it were to be found 

on BLM lands in Oregon. Direct would pose low to high risks to fish during a normal application, depending on 

the application rate and type of aquatic habitat. Use of diquat in place of safer aquatic herbicides would likely 

increase the incidence of adverse health effects to aquatic organisms per area treated. diflufenzopyr + dicamba, 

which also becomes available under this alternative, poses no risk to fish. 

Acute (short term) herbicide exposures to aquatic organism are not likely to result in harm under foreseeable 

conditions. 

Cumulative Effects 

Existing Controls 

A number of Federal, State, local, and tribal resource management and monitoring programs have been 

established to protect environmental resources and, in cases where there is existing environmental impairment, to 

effect restoration. The assessment of cumulative impacts recognizes the existence of these programs and assumes 

that the mandate under which each program was established will continue. The cumulative effects analysis 

assumes in part that these programs effectively avoid or mitigate the environmental impacts that they are designed 

to address. 

Fish as an Indicator of Ecosystem Health 

Fish, the dominant aquatic vertebrate in the analysis area, constitute a key component of aquatic systems on public 

lands in Oregon. Fish are a critical resource to humans and as such have influenced the development, status, 

and success of social and economic systems in Oregon. Aquatic organisms such as insects and other aquatic 

invertebrates provide food for fish. The health of fish and other aquatic organisms is often indicative of the 

health of the watershed. Fish and other aquatic organisms are often more susceptible than humans and wildlife to 

herbicides and other chemicals in their environment, and thus can be an indicator of the water quality standards. 

Today, the rapid expansion of invasive plants across public lands is a threat to ecosystem health and one of the 

greatest challenges in ecosystem management. 

Past Effects and Their Accumulation 

Cumulative impacts to fish and the lakes, ponds, wetlands, and riparian areas that provide habitat for fish on 

public lands and throughout Oregon have occurred from human-caused disturbance factors, including natural 

resource extraction, recreation, fire exclusion, construction of roads, dams, and hydropower facilities, agriculture, 

and urbanization. In addition to these and natural disturbances, use of wetland and riparian areas by livestock and 

wild horses has degraded habitat values. Water withdrawal from ditches and diversions have impacted fish habitat 

on public and other lands. Overfishing has been blamed for the declines in some fish populations (USDA, USDI 

2000a). The introduction of non-native game fish has also impacted some native fish populations. 

BLM surveys show that about 50 percent of inventoried riparian habitat on BLM lands in Oregon lack 

characteristics necessary for “proper” functioning condition (see Wetlands and Riparian Areas section). Proper 

functioning riparian areas have the necessary physical and structural components to dissipate stream energy 

associated with high water flows, as well as conditions that support a diverse and healthy population of fish and 

other aquatic organisms. 

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The permitting process and the regulatory environment for protecting fish have improved over time and are 

generally effective. Proper construction and placement of bridges and culverts have greatly reduced adverse 

effects but have not eliminated them. Little is known about the effects of water withdrawals from lakes on fish. 

Some fish have been harmed or killed during water extraction, but these numbers have been small and have 

not accumulated (USDI 2005d). The rate of loss of wetland and riparian areas has slowed with the passage of 

Federal, State, and local regulations that strive to protect wetland and riparian habitat. There has been some 

improvement in the functional quality of wetland and riparian areas on public lands in Oregon, a trend that is 

likely to continue. 

During the early years of the BLM, most resource conservation and management was focused on upland sites. 

An increased emphasis on wetland and riparian habitat protection began in the 1960s. In the 1970s, FLPMA was 

passed (1976) and the BLM began preparing land use plans to better manage natural resources on public lands. 

Land use plans set goals and objectives for natural resource management and identify priority watersheds on 

which to focus restoration efforts. In addition, the BLM is assessing the condition of wetland and riparian areas, 

and conducting restoration efforts in areas that are less than proper functioning. 

Past weed control efforts by the BLM, other Federal and State agencies, private landowners, and/or businesses 

(particularly the agricultural industry) have resulted in the application of thousands of tons of herbicides and other 

pesticides to the environment (see Table 4-1). As discussed earlier in this section, some of these herbicides break 

down relatively quickly in the environment or are not harmful to aquatic organisms at typical application rates. 

However, some herbicides are harmful to aquatic organisms, and may persist in the environment for many months. 

Invasive Plants 

The spread of invasive plant species is one factor that degrades habitat for aquatic organisms. Within riparian 

shrublands, there has been extensive conversion to areas dominated by exotic grasses and forbs. This conversion 

has made these areas more susceptible to fire (which further degrades the resource) and reduced their value to 

aquatic organisms (USDA, USDI 2000a). BLM efforts to restore watersheds including managing and controlling 

noxious weeds and other invasive vegetation would help to reduce erosion and sedimentation and restore native 

plant communities. Restoration of native vegetation should improve riparian habitat and moderate stream 

temperatures and water flows. In addition, the ability of the BLM in Oregon to use aquatic herbicides to control 

aquatic weeds would benefit lakes and ponds and the aquatic organisms that use these habitats. 

Streams cross multiple jurisdictions, including private land, along their entire course. In many cases the condition 

of the stream habitat off of public lands and on private or other jurisdiction lands is unknown and could be of 

lower quality. Dams and other diversions found in the Columbia River and most other major rivers in Oregon 

also limit access to upriver habitats and alter occupied habitats for certain anadromous fish and other species. 

Thus, restoration of native vegetation and natural ecosystems may be most immediately beneficial to resident fish 

rather than migratory fish that travel off of public lands to meet part of their life requisites (USDA, USDI 2000a). 

Contribution of Alternatives to Cumulative Effects 

Although herbicide treatments can lead to the harm or even death of fish and aquatic organisms, application of 

herbicides under Alternatives 2, 3, 4, and 5 are not expected to result in significant mortality to fish. However, 

while the amount of herbicides expected to reach water are expected to be very low under these alternatives, and 

site-specific treatment design and required ESA Consultation will attempt to prevent adverse effects to Federally 

Listed species, the BLM cannot conclude with certainty that herbicides could not potentially reach fish-bearing 

streams and cause adverse effects. 

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Most studies of herbicide effects on fish observe the effect of short-period exposure to high concentrations 

of herbicides, rather than the low concentrations over an extended period more likely to be found in streams, 

lakes, and ponds. Therefore, chronic effects to fish would not be readily apparent. There is also potential for 

an accidental spill or inadvertent improper use of herbicides to result in the contamination of water, thereby 

adversely affecting fish. 

However, the adverse effect of invasive plants is apparent and growing rapidly. Based on the number of acres 

treated, short-term adverse impacts and long-term improvements to the health and productivity of fish would 

be greatest under the Preferred Alternative, and least under Alternative 1. The number of acres treated under 

Alternatives 4 and 5 and their associated short and long-term effects would be similar, while Alternative 3 would 

treat fewer acres than the Proposed Action but probably has the lowest likelihood of adverse effects to fish. Most 

treatments under the Proposed Action would occur on uplands, but fish would also benefit from upland treatments 

located near aquatic habitats. 

Herbicide use already occurs on BLM and other Federal, State, and County lands, private forestry lands, 

rangeland, agricultural land, utility corridors, and road rights-of-way. Table 4-1 shows a comparison of the 

pounds of herbicides projected to be used under Alternative 4, the Proposed Action, with the pounds of those same 

herbicides used on all ownerships statewide in 2008. The proposed use of herbicides by BLM is a small amount 

of the total use in the State or even any large watershed, given the mixed ownership. This use, conducted under 

the SOPs and PEIS Mitigation Measures, and following site-specific NEPA analysis and appropriate consultation, 

is unlikely to contribute substantially to downstream effects. 

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Wildlife Resources 

Affected Environment 

This section addresses the amphibians, birds, mammals, mollusks, aquatic and terrestrial invertebrates, and 

reptiles found on BLM lands in Oregon, collectively called wildlife.53 Over 700 species have been documented 

in the State (all ownerships) including 31 amphibians, 478 birds, 139 mammals, 35 reptiles, and an uncountable 

number of invertebrates (Johnson and O’Neil 2001:2). In addition to resident wildlife, the Pacific Flyway54, 

covering much of Oregon, serves migratory birds. Federally Listed and Bureau Sensitive species receive special 

protection during management activities as needed (Appendix 5). For the BLM in Oregon, these include 13 

amphibians, 45 birds, 24 mammals, 2 reptiles, and more than 60 invertebrates (mollusks, arthropods, etc.). 

Birds, particularly migratory birds, have experienced precipitous declines since European settlement due to 

multiple causes including habitat loss, over-utilization, and more recently, changes to natural disturbance patterns 

(Hunter et al. 2001, USDI 2008e). Invasive plants (and animals) contribute to their decline. Migratory birds 

are also subject to the Migratory Bird Treaty Act, which provides non-mandatory guidelines when projects may 

impact populations or their habitats. BLM management under this Act focuses primarily on long-term habitat 

conditions (USDI 2009b). 

Oregon BLM supports a rich assemblage of mammals. They include big game species such as big horn sheep, 

elk, deer, pronghorn, black bear, cougars, coyotes, and many small-to-medium sized mammals such as mustelids 

(weasels, fishers, martens, skunks), rodents (squirrels, mice, rats, shrews, rabbits) and bats. Mammal populations 

and distributions in Oregon have been influenced by management variety of anthropogenic and natural habitat 

alterations. Mammals that are adaptable and tolerant of human activities, such as coyotes, have increased in 

number and distribution. Those that are restricted to unique habitats (such as big horned sheep or pronghorn) 

have decreased 

Invertebrate biodiversity and habitat relationships are poorly researched (Wilson 1992). Lattin (1993) estimates 

that 6,000 arthropod species may be found in Pacific Northwest old growth forests. Over 3,400 different species 

are known from a single 6,400 ha site in Oregon, but information on them is rudimentary. There are three 

invertebrates in Oregon listed under the ESA (Appendix 5). Also, see discussion of micro-organisms in Soil 

Resources section in this Chapter. 

The Oregon Special Status Species Program list, which includes all Bureau Sensitive and Federally Listed species 

currently includes 14 Lepidoptera. Remaining populations of these rare butterflies and moths are in fragmented 

remnants of habitat, and population size is very low in most occupied locations (Schultz, 2001, Stoner and Joern 

2004). The adult stage is very short; the entire nectaring period of a small population of some butterflies can be 

less than 10 days. However, individuals of larger populations generally mature at different times, which extends 

that population’s nectaring season. The history of other life phases and their habitat relationships are less known. 

Some, but not all, Lepidoptera are affiliated with specific native plants. 

Adult honeybees are used as a surrogate for invertebrates in risk assessments. Exotic (non-native) bees have been 

53 Fish may also be considered wildlife, but they are covered in a separate section. 

54 The Pacific Flyway is a major north-south route of travel for migratory birds in the Americas, extending from Alaska 

to Patagonia. Every year, migratory birds travel some or all of this distance both in spring and in fall, following food 

sources, heading to breeding grounds, or travelling to overwintering sites. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

shown to favor exotic plant species, and can differentially allow the exotic vegetation to compete against native 

plants (Goulson 2003). There are more than 3500 species of native solitary bees in the North America, and many 

more invertebrate native pollinators that can be influenced by weeds and weed treatments (Greer 1999). The 

balance of invertebrates (predators, herbivores, and nectar-feeders) can be disturbed if too much of one group of 

plants (for instance, broad-leafed or flowering forbs) are removed during their life cycle or native invertebrates 

may be replaced by non-native species if the spread of invasive plants is not controlled. 

Mollusks are prey for birds and small mammals (Dunk et al. 2004) and serve other important ecological functions 

by breaking down vegetative litter. From a global conservation perspective, mollusks represent 20 percent of all 

threatened animals, and 37 percent of known animal extinctions since 1600 A.D. (Seddon 1998 cited in Dunk et 

al. 2004). Approximately 69 percent of freshwater mussels in North America are extinct, imperiled, or vulnerable 

to extinction (Stein et al. 2002). Most Oregon mollusks are food generalists, and do not seem to be affiliated 

with unique plant types (Duncan, N. pers. comm.). They are active and most vulnerable during wet times of the 

year. Snails and slugs have moist skin that can make them more susceptible to toxic qualities of water-dissolved 

chemicals. Some herbicides have low toxicity to mollusks. 

BLM lands in Oregon support both terrestrial and aquatic forms of amphibians (frogs and salamanders), which are 

moist-skinned cold-blooded animals that breathe through their skin. Diverse habitats on BLM lands in Oregon 

also support a wide variety of reptiles (snakes, turtles, and lizards). Like amphibians, they are cold-blooded 

animals, but unlike amphibians, have scaly skin and are more tied to terrestrial habitats such as rock outcrops. 

Reptiles and amphibians are collectively called “herptiles”. 

There are several weeds thought to adversely affect herptiles including Eurasian watermilfoil, purple loosestrife, 

saltcedar, and cheatgrass (Pilliod and Wind 2008). None of the herptiles are currently listed under the ESA. 

Habitat connectivity among populations is a concern for all the herptiles (Pilliod and Wind 2008). Restricting 

management activities around water offers some protection for the species that use riparian or water habitats, but 

both reptiles and amphibians move well away from waterways during their life cycle. (Not all herptiles are water 

associated.) Amphibian declines have received more attention in terms of research and publicity, but Gibbons 

et al. (2000) suggests reptiles may be exhibiting declines that are even more precipitous. Both are adversely 

impacted by invasive plants (including invasive fauna as well as weeds) (Hinton and Scott 1990 cited in Gibbons 

et al. 2000), and are also vulnerable to the treatments to control weeds. Reptiles, particularly the Bureau Sensitive 

painted turtle and western pond turtle, have long seasonal metamorphosis periods when they are particularly 

susceptible to all types of management activities. 

The natural environment is in constant change due to natural events: seasonal and temporal climate, successional 

development, fire, wind, drought, flood, insect, and disease. Nearly all Oregon native wildlife is dependent 

upon some mosaic of habitat created and maintained by those natural disturbances. Anthropomorphic (human) 

activities have complicated the disturbance pattern and brought irreversible changes to the natural environment. 

Humans have introduced non-native plants and animals—including both beneficial and invasive plants. 

Wildlife Considerations by Biome 

Sagebrush Steppe 

BLM lands currently account for 70 percent of the remaining sage grouse habitat in Oregon (Hagen 2005). The 

sagebrush ecosystem throughout the Great Basin has been described as one of the most endangered in the United 

States (Noss et al. 1995). Several authors identify invasive plants as one risk factor (Wisdom et al. 2005:6). 

Connelly et al. (2004) reported 31 percent of original sage grouse habitat has been converted to areas dominated 

by invasive cheatgrass, medusahead, knapweed, and yellow starthistle. 

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In a central Nevada study, Wisdom et al. (2005) documented 26 bird species and 28 mammals that use sagebrush 

lands for cover and food. Vander Haegen et al. (2001) concluded that 49 of the 103 species (44 birds, 26 

mammals, 20 reptiles, 9 amphibians) in the sagebrush biome may be sagebrush obligates. Amphibian species 

richness and density in sagebrush ecosystems is low due to dry conditions and lack of open water. Vander Haegen 

et al. (2001:239) documented that sites dominated by native plants have more closely associated wildlife habitat 

relationships than those dominated by exotics. 

Many high desert species time their activities to avoid climatic extremes to allow them to capitalize on spotty 

resources such as food or water when they are available. During times of scarce resources or harsh weather, 

species such as marmots, pygmy rabbits, ground squirrels, and burrowing owls may burrow or estivate. They can 

be especially vulnerable to herbicide exposure if limited food or water is contaminated during their metabolically 

active period when they are ingesting large amounts of food or water in a short time. 

Sagebrush habitats dominated by cheatgrass or medusahead monocultures do not provide usable habitat for sage 

grouse and other sagebrush related species. Rowland et al. (2005) evaluated 40 vertebrate species in the Great 

Basin and Nevada for risk to displacement from cheatgrass by using risk models and quantifying habitat for those 

species. They described 36 percent of habitat at high risk and 25 percent at moderate risk of displacement from 

cheatgrass (Rowland et al. 2005:156). All but five of those species occur on BLM lands in Oregon (although the 

Oregon percentages of habitats at risk would be different). Spotted knapweed and many other noxious weeds also 

degrade wildlife habitat in the sagebrush biome. The increase in invasive annual grasses has increased wildfire 

risk as compared to the native shrubland. Rabbitbrush can sprout after a fire that would kill sagebrush (Hammond 

1995 cited in Montana FWP 2008), causing rabbitbrush to be more prevalent than would be found in a healthy 

sagebrush community. Western junipers have increased in sagebrush-dominated communities at higher elevations 

to further degrade sage grouse (Hagen 2005) and mule deer habitat (Clements and Young 1997). A diverse mosaic 

of different sagebrush species and other shrubs is described for healthy sagebrush systems (Rowland 2004). 

Eastern Forest 

Wildlife communities are relatively unstudied in the eastern forests, as compared to coastal west side forests, 

or east side riparian communities, and much of the limited research has focused on ungulates (Sallabanks et al. 

2001). Wildlife habitat matrices (Johnson and O’Neil 2001) identify 287 vertebrate species associated with (but 

not necessarily obligates of) east side interior forests and woodlands, which is fewer species than riparian or west 

side forests, but more species than those associated with alpine/subalpine habitats. The eastern dry forest hosts 

over a dozen amphibians, 130 birds, 80 mammals, and 20 reptiles. The majority of birds in the Eastern Forest 

biome are foliage-gleaners that glean insects and fruit from vegetation—not from the ground (Sallabanks et al. 

2001). Herbivory (domestic and wild ungulates) has influenced the understory vegetation in eastern dry forests 

by suppressing shrub canopies and biomass accumulation, particularly through selective suppression of N-fixing 

plants (Sallabanks et al. 2001). 

East Side Riparian 

This biome is specific to the east side in this EIS, but many of the riparian relationships remain true in west 

side riparian habitats as well. Riparian areas are diversity “hotspots,” supporting some of the richest species 

assemblages of any habitat association (Kauffman et al. 2001). Riparian zones are critical wildlife habitats in the 

high desert of southeast Oregon (Thomas 1979), and the Blue Mountains (Thomas 1979). Thomas identified 285 

of the 378 terrestrial vertebrate species in the Blue Mountains use or are directly associated with riparian habitats. 

Over 80 bird species were documented in a 1.5-mile stream reach in northeast Oregon (Kauffman et al. 1982). 

Kauffman et al. (2001) reported 319 of 593 (53 percent) of wildlife species in Oregon and Washington were 

riparian associates, including many wildlife species included on the Bureau Sensitive and Federally Listed list. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Siskiyou 

This biome has a diversity of wildlife and habitats not usually found in such a limited area. ODFW (2005) 

identifies the Siskiyou mixed conifer forests and woodlands as the most diverse forest habitats in Oregon. The 

Klamath Mountains are considered to be a herptile “hotspot” by Bury and Pearl (1999), supporting 38 native 

species of amphibians and reptiles...higher than any similar-sized mountain range in the Pacific Northwest 

(Olson et al. 2001). Sixty- five Bureau Sensitive and Federally Listed species are documented or suspected in the 

Siskiyou Biome. The highest avian species richness west of the Cascade crest in Oregon and Washington occurs 

in the Klamath Mountains (Ralph et al. 1991). The Klamath-Siskiyou ecoregion is an area of “extraordinary 

biodiversity,” rated “among the world’s most outstanding temperate coniferous forests (DellaSala et al. 1999). 

They analyzed 2,377 terrestrial animals (including snails, butterflies, birds, mammals, reptiles and amphibians), 

and 168 or 7 percent were found nowhere else. 

Western Forest (including riparian) 

More than 300 vertebrate species are associated with the structurally diverse Oregon western forest biome, 

making it one of the most species-rich areas in Oregon (Olson et al. 2001). Amphibians make up approximately 

13 percent of the total wildlife species in the montane region (which includes the Willamette Valley and Siskiyou 

Biomes in this EIS) (Olson et al. 2001). Mollusks (snails and slugs) are abundant in number and diversity in the 

moist habitats of the western forest biome. 

Road density is high, and most BLM lands are in a checkerboard ownership pattern interspersed with private 

industrial lands or rural residential. The patchiness that results from land use and ownership patterns has 

fragmented older forests which serve as habitat for species such as the Pacific-slope flycatcher, varied thrush 

and Vaux’s swifts (Brown 1985), but this fragmentation also provides edge and structural diversity for many 

other wildlife species such as willow flycatchers, white-crowned sparrows, song sparrows and spotted towhees. 

Microhabitats in the lush moist vegetation next to water support many forest riparian species (bats, shrew, marten, 

waterfowl, and amphibians). 

The checkerboard ownership, intensive land use, and extensive road network increases the risk of invasive plant 

establishment. Some weeds such as Himalayan blackberry and Scotch broom dominate large portions of the 

western forest landscape. The large amount of water close to human activity also facilitates introduction of water 

weeds such as purple loosestrife and yellow-flag iris threaten the viability of the many aquatic species in this 

biome. 

Willamette Valley 

Less than one percent of the BLM lands in Oregon are in this biome, but nearby BLM lands in the Western Forest 

Biome can be similar to this biome. Habitat connectivity is one of the greatest concerns for wildlife associated 

with the Willamette Valley, and isolated populations of many rare species remain. Invasive plants are a primary 

factor adversely affecting survival of isolated populations of rare wildlife in the Willamette Valley. 

Oak Habitats 

There are oak woodland components in all of the biomes in western Oregon. Oak habitats are important habitat 

to many Oregon wildlife species. The ODFW has recognized the importance of this habitat in its Conservation 

Strategy (ODFW 2005). Oaks are important to wood ducks, band-tailed pigeons, California quail, varied 

thrush, jays, Lewis and acorn woodpeckers, black bear, squirrels, mice, raccoons, and deer (ODFW 2005). Oak 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

habitats generally have open grass-dominated understories and most have been degraded by annual grasses and 

exotic shrubs to varying degrees. Oaks also have shallow root systems, making them vulnerable to mechanical 

disturbance. Non-native species can suppress the seedlings of oaks, pines and other native species (Polster 2004). 

Environmental Consequences 

The likelihood of significant adverse effects to wildlife from contact with the herbicide uses proposed in the 

action alternatives is negligible at the population scale. The herbicides are formulated to affect plants, and have 

been selected to have some of the lowest (or no) demonstrable wildlife toxicity of licensed herbicides, do not 

bioaccumulate in wildlife, and are quickly degraded in wildland settings. The EPA manual summarizes “Many 

modern herbicides kill weeds selectively by impairing metabolic processes that are unique to plant life. For this 

reason, their systemic toxicities in mammals are generally low. The water-soluble herbicides are not retained in 

body tissues for long periods, as were the old lipophilic organochlorine insecticides such as DDT.” 

Risk assessments (Chapter 3 and Appendix 8) indicating medium or high risk to wildlife are universally from 

exposure scenarios not likely to occur during normal applications under the action alternatives, either because 

SOPs and other measures the likelihood of contacting individual animals with the tested doses is low or because 

suitable habitat will be evaluated and known populations of rare (and thus more susceptible) species would be 

identified and specifically avoided. 

Requirements for site-specific pre-project clearances for Bureau Sensitive and Federally Listed also helps prevent 

adverse effects to rare species, providing habitat and/or occupancy information to project planners so protection 

measures can be prescribed. Local biologists would use herbicide risk assessments that consider Bureau Sensitive 

and Federally Listed species to be 10-times more susceptible to herbicides than other wildlife, to help choose 

herbicides with lesser toxic risk to that particular class of rare species or choose more selective application 

methods to avoid or reduce herbicide contact. 

Four categories of potential effects are addressed in this section; a) the potential for adverse health effects from 

the herbicides, b) effects of habitat change either from the spread of invasive plants, or c) as collateral damage 

from the weed treatments, and d) disruption effects (noise and other disturbances) from the vegetation treatments. 

The responses of wildlife species and wildlife communities to habitat changes and to disturbance can be variable, 

complex, interactive, and difficult to accurately predict. 

Effects Common to All Alternatives 

Effects from direct contact or ingestion of herbicides 

Herbicides have the potential to directly harm wildlife individuals, populations, or species (USDA 2005) through 

toxic reactions. Terrestrial animals might be exposed to any applied herbicide from direct spray, the ingestion 

of contaminated material (vegetation, prey species, or water), or indirect contact with contaminated vegetation. 

Aquatic animals can be exposed to the six herbicides approved for aquatic use (2,4-D, diquat, fluridone, 

glyphosate, imazapyr and triclopyr), and from off-site drift or run-off from terrestrial herbicides. 

Toxic effects can include death, damage to organs, changes to body weight or growth rates, reduced reproduction, 

reduced survival of offspring, increased risk of predation, and behavioral (sublethal) changes that reduce fitness. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

In practice, most BLM weed treatment would be specifically targeted at weeds through direct spray, hack and 

squirt, or at native vegetation along rights-of-way through boom applications, and not applied to extensive acreage 

across all occupied wildlife habitat. It is likely that larger animals and birds would avoid the treatment area 

during treatment because of noise and activity. Animals that temporarily leave the treatment area have reduced 

risk of directly ingesting the herbicide while grooming, or from ingesting herbicides on vegetation or prey (insects 

or other animals that were directly sprayed), because most of the herbicides proposed in this EIS have a very short 

active period where wildlife toxicity could occur. The few studies of herbicides on mollusks indicate they have 

relatively high resistance to toxic effects of herbicides in the environment, although their moist skin facilitates 

exposure to herbicides in soil and water. 

SOP buffers on wetlands and riparian habitats can reduce risks to herptiles in their aquatic form, but may not be 

large enough to protect herptiles from exposure when they are in terrestrial habitats. Turtles and frogs use upland 

habitat several hundred feet or more from water at certain times of their lives (Bishop and Pettit 1992 cited in 

Govindarajulu 2008). Aquatic animals in water are more vulnerable to exposure from herbicides used for aquatic 

vegetation than terrestrial species because they are less likely to find untreated alternate habitat for refugia, 

although species vary significantly in their susceptibility. 

There are some sessile animals, such as mollusks and other invertebrates, ground-dwelling mammals, or prefledgling birds that could be restricted to the treatment area. These organisms could be adversely affected by 

broad scale treatments using herbicides with moderate to high toxicity. 

Accidental exposure from off-site drift or spill is also possible. Spill scenarios are included in the risk ratings. 

Herbicides can be absorbed by plants (and biodegraded in the plant’s processing of the herbicide), are degraded 

by micro-organisms fairly rapidly, can be degraded by UV exposure, or are diluted and broken-down into nontoxic by-products by contact with water or air. Some of the active mechanisms of herbicides are affected by 

temperature as well. Some herbicides have strong affinity to soil particles, which can further reduce active 

herbicide contact with wildlife (see Soils Resources section). 

ALS-inhibitors: ALS-inhibitors (including chlorsulfuron, imazapic, imazapyr, metsulfuron methyl, sulfometuron 

methyl all of which are included in Alternatives 3, 4, and 5) work by inhibiting a biological pathway that exists 

only in plants and not in animals, thus making the ALS-inhibitors among the safest herbicides for wildlife (CIS 

2009). 

Endocrine disrupters: Recent information has highlighted the potential for certain synthetic and natural chemicals 

to affect endocrine glands, hormones, and hormone receptors (endocrine system) (CIS 2009). EPA has just begun 

evaluating chemicals for this potential effect. Of the herbicides analyzed in this EIS, only 2,4-D is on the EPA 

Tier 1 priority list for evaluation (EPA 2009b). The EPA reports effects of endocrine disruption in animals that 

“include abnormal thyroid function and development in fish and birds; decreased fertility in shellfish, fish, birds, 

and mammals; decreased hatching success in fish, birds, and reptiles; demasculinization and feminization of 

fish, birds, reptiles, and mammals; defeminization and masculinization of gastropods, fish, and birds; decreased 

offspring survival; and alteration of immune and behavioral function in birds and mammals.” Of the herbicides 

analyzed, 2,4-D and NPE surfactants have been identified as potentially having estrogenic effects (USGS 1998, 

Bakke 2003). Triclopyr and glyphosate have been evaluated for endocrine disrupting effects, and the weight 

of evidence indicates that these herbicides cause no specific toxic effects on endocrine function (SERA 2002). 

Sulfometuron methyl can cause malformations in amphibians (SERA 2004f), but whether the malformations are 

caused by endocrine disruption, cellular toxicity, or other pathway has not been reported. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

2,4-D is a possible endocrine disrupter (see Endocrine Disrupters) and is one of the more toxic herbicides for 

wildlife 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 sublethal 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. 

Dicamba: No adverse effects on mammals are plausible for either acute or chronic exposures of dicamba. At the 

highest tested rate, there are adverse reproductive effects possible for acute scenarios consuming contaminated 

vegetation. There is little basis for asserting that adverse effects in aquatic animals is plausible. Limited studies 

on dicamba suggest it is practically non-toxic to amphibians and honeybees. Amphibians are as tolerant as the 

fish to the acute toxicity of dicamba and aquatic invertebrate appear to be somewhat more susceptible to dicamba 

than fish or amphibians. Dicamba has no adverse effects on birds for acute or chronic exposures, although highest 

tested application rates had possible adverse reproductive concerns for acute scenarios involving birds consuming 

contaminated vegetation or contaminated insects (SERA 2004g). 

Glyphosate is a low toxicity herbicide, widely used for terrestrial applications and is also approved for aquatic 

use. Toxicity to most wildlife groups is very low, so much so that NOAEL levels are used because the LD50 

were not found at high doses in many cases. Observed effects had to do with reduced feeding efficiency and 

reduced weight gain. Glyphosate adheres to soil and is degraded by soil bacteria and does not bioaccumulate. (1) 

technical grade (pure) glyphosate is much less toxic than some of the commercial formulations; (2) commercial 

glyphosate formulations with the surfactant polyoxyethyleneamine (POEA) are similar in toxicity to the surfactant 

POEA alone; (3) glyphosate herbicide formulations, such as Rodeo®, that are formulated without a surfactant are 

much less toxic than formulations with the surfactant POEA; 4) glyphosate herbicides with alternative surfactants 

would be much less toxic to frogs than Roundup Original/Vision® (Mann and Bidwell 1999, Perkins et al. 2000, 

Edginton et al. 2004a, Howe et al. 2004, all cited in Govindarajulu 2008). These studies support the conclusion 

that the toxic effect of POEA-containing glyphosate herbicides is due to POEA rather than to the active 

glyphosate ingredient. Ephemeral wetlands important to amphibians may not be protected by standard buffers 

(Govindarajulu 2008). 

Picloram: Studies on birds, bees, and snails generally support picloram as relatively nontoxic to terrestrial 

animals. The few field studies indicated no change to mammal or avian diversity following picloram treatment. 

Variations in different exposure assessments have little impact to risk through ingestion, grooming or direct 

contact. Maximum rates have higher risk to mammals due to contaminated grass or insects. No information was 

found in the literature about picloram’s effect on reptiles (SERA 2003b). 

Bromacil is an herbicide often used where maintenance of bare ground is desired. It poses a low toxicity hazard 

to terrestrial mammals, birds, and honeybees. It poses zero to low toxicity risk to mammals that ingest treated 

vegetation over time under plausible treatment scenarios, assuming they remain in the treatment area, and 

alternate food is unavailable. BLM’s application scenario reduces the risks of herbivore ingestion. There is 

practically no risk to invertebrates (ENSR 2005b). 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Chlorsulfuron is an ALS-inhibitor; a group of herbicides that has the lowest risk to all groups of wildlife of 

the herbicides evaluated. All likely application scenarios are below the LOC’s for wildlife groups under tested 

scenarios, even under spill or off-site drift scenarios. It is unlikely to cause any adverse effect on aquatic animals 

(Table 3-14). No studies on amphibians or reptiles were found (SERA 2004a). 

Clopyralid is useful in treating starthistle, thistles, and knapweeds, which are noted as damaging to wildlife 

habitat. Clopyralid is unlikely to pose risk to terrestrial mammals. All of the estimated mammalian acute 

exposures are below the acute NOEL; mammalian chronic exposures are below the chronic NOEL. It is relatively 

“harmless” to earthworms (Dow AgroSciences 1998) and 14 of17 insect parasites and predatory mites (Hassan 

et al. 1994 cited in SERA 2004b). There was no mortality to bees at relatively high doses. Four of 18 direct 

spray scenarios resulted in exposure levels below the estimated NOEL. Large and small birds have some risk 

of ingestion of contaminated food but hazard quotients are below the level of concern for all exposure scenarios. 

No studies on amphibians/reptiles were found. Clopyralid is one of the herbicides with lower toxic risks (SERA 

2004b). 

Diflufenzopyr + dicamba – Diflufenzopyr has slightly more toxic impacts to wildlife than dicamba based on 

evaluations in ecological risk assessment. The mixture has a moderate residual effect that could impact insects 

and mammals through ingestion but insect lethal effects are unlikely. It is practically non-toxic to aquatic 

invertebrates and has low toxicity to honeybees. Risk Quotients for terrestrial wildlife were all below the most 

conservative LOC of 0.1 (acute endangered species), indicating that accidental direct spray impacts are not likely 

to pose a risk to terrestrial animals. The mixture is practically non-toxic to birds, but there are some concerns 

for ingestion of contaminated thistle or knapweed manifesting in reproductive effects at high application rates. 

There are chronic and acute ingestion concerns for mammals as well (Table 3-14). Aquatic invertebrates are more 

susceptible to dicamba than fish. One study on dicamba indicates it is practically non-toxic to amphibians (ENSR 

2005d, i). 

Diquat is approved for aquatic use and is one of the more toxic herbicides evaluated in this EIS. It is moderately 

toxic to mammals through dermal contact and ingestion. The risks are greater for large mammals and large avian 

herbivores compared to smaller animals and birds, particularly with maximum application rates (Table 3-14). 

There are high risks to aquatic species sprayed with diquat. There are moderate-high risks identified for aquatic 

invertebrates at typical and maximum rates, and low toxicity to terrestrial invertebrates. Diquat is one of two 

herbicides evaluated in this EIS with high ratings at both typical and maximum rates for Bureau Sensitive and 

Federally Listed species, partly related to aquatic exposure scenarios (ENSR 2005e). 

Diuron is approved for ditch banks, but will not be used in riparian areas. It has a low to moderate tendency 

to bio-accumulate (Extoxnet 1996a). It has been rated as a surface water and groundwater contaminant (Table 

3-14). Acute direct spray risks on food were low for most mammal scenarios, but exceeded the LOC for all 

scenarios at the maximum rate. The maximum rate may adversely affect birds. Diuron has low to moderate risks 

to pollinators at typical rates and applications and moderate to high risk for aquatic invertebrates. Direct spray 

of diuron at the maximum rate may have adverse effects to insects but scenarios may overestimate risk to insects. 

Reptiles were found to be less susceptible than birds to cholinesterase inhibitors. Diuron was listed as a risk in all 

Bureau Sensitive wildlife groupings (ENSR 2005f). 

Fluridone is used for submerged weeds that threaten aquatic wildlife such as watermilfoils. It has a low tendency 

to bioaccumulate (in fish). Fluridone exhibits low toxicity to most terrestrial mammals and small mammals may 

be more susceptible than large. Acute oral exposure of fluridone is practically non-toxic to birds and practically 

non-toxic to honeybees. One of the aquatic herbicides with the highest risk factors, but at typical rate is less toxic 

to fish and aquatic organisms than diquat, and very low risk to other wildlife forms (Table 3-14). Application 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

timing could avoid most susceptible (water-associated) stages of amphibian development, if this information is 

available for resident herptiles at the treatment site (ENSR 2005g). 

Hexazinone: The commercial formulas are less toxic than hexazinone by itself and the liquid form is more toxic 

than granular. For granular formulations, none of the hazard quotients for mammals exceed a level of concern 

even at the highest application rate. For liquid formulations of hexazinone, hazard quotients exceed the level 

of concern at all application rates and all of the scenarios involving residue rates for contaminated vegetation or 

insects (Fletcher et al. 1994). Hexazinone and its degradates are persistent and highly mobile and hexazinone 

has been identified as a groundwater contaminate in some states. Bullfrogs were slightly more susceptible to 

behavioral change (diminished response to prodding) than leopard frogs over a 9-day study but amphibian studies 

were not adequate to determine the LD50. Hexazinone poses zero to moderate risk to mammals for ingestion under 

both acute and chronic scenarios (Table 3-15). Birds are more tolerant than mammals (SERA 2005c). 

Imazapic is an ALS-inhibitor that rapidly metabolizes and does not bioaccumulate. It is effective against 

medusahead, leafy spurge, and cheatgrass, which adversely affect wildlife habitat. Imazapic is not highly toxic 

to most terrestrial animals. Mammals are more susceptible during pregnancy and larger mammals are more 

susceptible than small mammals. Imazapic has low toxicity to honeybees. No adverse short-term exposure risks 

to birds were noted for imazapic, but some chronic growth reduction was noted. None of the risk ratings for 

Bureau Sensitive or non-Sensitive show any ratings that exceed the LOC. Imazapic is one of the lowest toxic 

risks to wildlife of herbicides evaluated in this EIS along with other ALS-Inhibitors (SERA 2004c). 

Imazapyr is approved for aquatic use and is an ALS-inhibitor. There was no bioconcentration in aquatic Daphnia 

and toxicity is apparently low. There is a lack of information on dose levels that demonstrate harm to mammals, 

amphibians, or birds. Effects of field studies (Brookes et al. 1995) suggest observed changes to birds and 

mammals following treatment are habitat related, and not do to toxic effects. Imazapyr is one of the least toxic 

aquatic herbicides evaluated (except for accidental spill for susceptible fish). Imazapyr is only slightly more toxic 

than the other ALS-inhibitors, all of which are the least toxic of any of the herbicides evaluated (SERA 2004d). 

Metsulfuron methyl is an ALS-inhibitor that does not appear to bioaccumulate. Metsulfuron methyl can be 

effective for invasive weeds that are unsusceptible to other herbicides. None of the acute or chronic exposure 

scenarios exceeded the LOC at the typical rate, and few exceeded LOC at maximum rate. Metsulfuron methyl 

has very low toxicity to birds for direct spray and consumption; no mortality of acute spray on honeybees; and, 

aquatic invertebrates do not appear to be susceptible. One study on Rove beetle indicated reduced egg hatching. 

Daphnia are relatively tolerant. Like other ALS-inhibitors, it is one of the least toxic of herbicides evaluated 

(SERA 2004e). 

Sulfometuron methyl is an ALS-inhibitor and a possible endocrine-disrupter. Sulfometuron methyl could be 

used to control weeds in riparian areas when no water exposure is likely. It is highly toxic to aquatic plants. 

The ecological risk assessments indicated no risks to aquatic invertebrates from any scenario. All ratings for 

all scenarios indicate no rating that exceeded the LOC, although it may be moderately toxic to amphibians. 

Sulfometuron methyl has the lowest risk to all groups of wildlife of the herbicides evaluated (with other ALSinhibitors). Site-specific evaluations prior to treatment could reduce potential risks to amphibians possibly 

occurring in riparian treatment areas (SERA 2004f). 

Tebuthiuron: Direct spray of tebuthiuron at the typical rate is not likely to pose risks to small mammals, although 

there are some risks to birds at typical and maximum rates—primarily due to ingestion of contaminated food. It 

has low acute toxicity to insects and direct spray is not a concern to aquatic invertebrates. Off-site drift issues 

related to tebuthiuron are unlikely to affect aquatic wildlife, but accidental spray exceeded LOC for aquatic invert 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

risk in ponds or streams. At low rates, tebuthiuron can help restore ecological mosaics in sagebrush ecosystems 

important to sage grouse and pygmy rabbits (Crawford et al. 2004, ENSR 2005k). 

Triclopyr is approved for aquatic use and can be used on saltcedar, watermilfoil, and purple loosestrife, all 

species known to adversely affect wildlife habitat. Some have proposed that it may be endocrine disruptor but 

studies indicate otherwise. Triclopyr, as triethylamine (TEA) salt and butoxyethyl ester (BEE), is covered in the 

risk assessments. Some formulations of the TEA salt of triclopyr have been labeled for aquatic weed control. 

Triclopyr TEA is less toxic to wildlife than triclopyr BEE. The additive TCP has about the same toxicity as 

triclopyr. At the upper range of exposures, hazard quotients exceed the LOC for large mammals, but average 

hazard quotients do not exceed the LOC for any exposure scenario. Triclopyr acid is practically non-toxic to 

slightly toxic to birds, and triclopyr TEA and triclopyr BEE are practically non-toxic to birds. Consumption of 

treated vegetation (and insects) is the greatest concern for birds or mammals. Of aquatic-approved herbicides 

evaluated in this EIS, triclopyr risk is about average. Using less toxic formulas reduces risk (SERA 2003c). 

Habitat change resulting from invasive plants 

Loss and degradation of habitat is the primary cause of native wildlife population declines. Native bird diversity 

has been positively correlated with native plant diversity (by volume), but had no or negative correlation with 

exotic vegetation (Mills et al. 1989, Germaine et al. 1998). Wilcove et al. (1998) documented that invasive 

species have adversely impacted approximately 46 percent of the plants and animals Federally Listed as 

endangered species (USDA 2003b). Severe weed infestations can cause declines in native diversity, habitat 

quality, and ecosystem function (Asher 2000, Lacey and Olsen 1991). Russian knapweed infestations resulted 

in severe reductions of kangaroo rat and ground squirrel populations in Wyoming (Johnson et al. 1994). Spotted 

knapweed invasion was found to reduce available elk winter forage 50 to 90 percent (Duncan 1997). Herbivores 

avoided leafy spurge (Trammell and Butler 1995). The thorns and seedpods of many invasive plants can kill or 

injure wildlife (Archer 2001). Bats and hummingbirds have been killed by entrapment on burdock seedheads 

(burrs) (Raloff 1998). 

Weeds can particularly devastate riparian wildlife habitat. Thompson et al. (1987) found that muskrats and longbilled marsh wrens leave marshes infested by purple loosestrife. Mammal, reptile, and amphibian populations 

were reduced when habitat was invaded by weeds (Duncan et al. 2004). Saltcedar reduced habitat for some birds, 

reptiles and mammals (Zavaleta 2000) but more human-communal species such as crows, magpies and mourning 

doves were more common in saltcedar sites (Harmon 2008). Non-native weeds can choke out native species and 

fill-in open water areas to adversely impact amphibians, which prefer a proportion of open water in their habitat 

(Brotherson and Field, 1987, Dudley 2000, Horton, 1977). Haycock (1999) reported that Oregon spotted frog 

populations are threatened by the invasion of reed canary grass that reduces open-water habitat in their shallow 

marsh habitats. 

Some wildlife apparently benefit from, or at least tolerate, invasive plants, but invasive plants seldom provide 

wildlife the same food and cover quality as native species. American goldfinch and red-winged blackbird utilize 

purple loosestrife (Kiviat 1996, Thompson et al. 1987); non-native chukar and native bighorn sheep will utilize 

cheatgrass early in the spring (Csuti et al. 1997), and; elk, deer and rodents eat rosettes and seed heads of spotted 

knapweed and dandelion. Forage quality is reduced in weedy habitats (Bedunah and Carpenter 1989, Rice et al. 

1997b, Trammell and Butler 1995), and functional cover for many species of wildlife is reduced. The few uses 

that an invasive plant may provide do not outweigh the adverse impacts to an entire ecosystem (Zavaleta 2000). 

Recruitment and survival of juvenile sage grouse (Bureau Sensitive) is considered to be positively correlated 

to the historic amount, distribution and pattern of sagebrush habitat (Connelly et al. 2004), which is negatively 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

affected by the increase in invasive annual grasses (Hagen 2005, Wisdom et al. 2005) and the increase in Western 

juniper expansion (Hagen 2005, Wisdom et al. 2005, Suring et al. 2005). The increase in Western juniper 

increases perches for predatory birds, which increases predation (lethal population impacts) on sage grouse. 

Annual invasive grasses increase fire frequency beyond the historic fire interval and often results in an annual 

grass/fire system that prevents sagebrush reestablishment. This changes disturbance patterns, which lowers 

the fitness of most of the native sagebrush wildlife species such as sage grouse, pygmy rabbits, and Brewer’s 

sparrows (all Bureau Sensitive), and increases chronic lethal impacts on those species. 

Western pond turtles (Bureau Sensitive) require bare, sandy soil near water to dig nests in which to deposit 

eggs. The eggs need the thermo-regulation of the non-vegetated soil to mature. Purple loosestrife, Himalayan 

blackberry, and other noxious weeds can quickly overtake bare soil in riparian areas, changing the solar regulation 

processes. Turtles are forced to lay eggs that don’t mature, move further from riparian areas (increasing 

predation), or fail to nest at all (Hays et al. 1999). 

Leafy spurge invades grasslands and changes the vegetative structure. Changes are beneficial for western 

meadowlarks but adverse for savannah and grasshopper sparrows (Scheiman et al. 2003). 

Some invasive plants (such as knapweed) contain chemical compounds that make the plant unpalatable 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). Invasive plants can act as a population sink by attracting a species and then exposing them to increased 

mortality or failed reproduction (Chew 1981). For example, Schmidt and Whelan (1999) reported that native 

birds increased their use of exotic honeysuckle and buckbrush shrubs over native trees, even though nests built in 

the exotic shrubs experienced significantly higher mortality rates. 

Maintenance or improvement of conditions and processes found in healthy native ecosystems would have 

beneficial long-term effects to the native wildlife that are associated with that ecosystem, particularly rare species. 

Alternatives that protect or restore the greatest number of acres of native vegetation (see Table 4-4 in the Noxious 

Weeds and Other Invasive Plants section) would have correspondingly greater benefits to wildlife populations, 

particularly when SOPs and other mitigations reduce or avoid short-term adverse effects. 

Habitat Change Resulting from Vegetation Treatments 

As noted in the previous section, while native wildlife may be found using invasive plants, they are seldom 

dependent upon them and would typically fair far better with native plants. Heavily used invasive plants such 

as blackberries are still more detrimental to native wildlife habitat than the benefits they provide, and some of 

the species benefitting from invasive plants are actually exotics such as starlings. There is potential for localized 

adverse effects to wildlife habitat from weed control treatments resulting from the collateral damage to native 

species. The potential for such habitat changes to adversely affect species would depend upon the vegetation 

species affected, the percent of native vegetation within the home range/population of a species that is affected, 

the importance of that vegetation to the resident wildlife, and the availability of unaffected vegetation in the 

treatment area. 

As noted in Chapter 3, 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. Under alternatives 1-3, 

treatments are directed at noxious weeds and other invasive plants. The objective of those treatments is to remove 

weeds and restore native vegetation. Both damage to native vegetation and unnecessary site disturbance (which 

would favor reinvasion by the invasive plant) is avoided because they typically exacerbate the weed problem 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Most weed treatments are spot treatments directed at specific plants, and collateral damage to native habitats is 

insignificant or limited to the immediately surrounding area. By design, the BLM uses non-herbicide methods 

with care, or uses the smallest amount of herbicide that will kill the weed, so that the risk of additional mortality 

is low. The Vegetation, Native Plants, and Plant Communities section in this Chapter notes that the risk to nontarget plants from herbicide treatments is less under the action alternatives than under the No Action Alternative. 

Some habitats are so infested with weeds they offer little suitable habitat for native wildlife. Sites that are too 

heavily infested with weeds for spot treatments, but retaining enough native vegetation to serve as important 

habitat for native wildlife species, would be rarely treated unless there are broader objectives requiring an 

unusually large investment, such as Bureau Sensitive species’ habitat or special use areas. 

Behavioral Disturbance to Wildlife in or Near the Treatment Areas 

Both herbicide and non-herbicide treatments have the potential to disturb wildlife. Whether disturbance disrupts 

normal behavior to the extent survival of adults is impaired or reproduction compromised depends on the 

intensity of disturbance, extent of habitat affected, duration of the activity, and whether the activity occurs during 

vulnerable time such as when the animal is restricted to a nest, breeding area, or winter range. If an animal is 

frightened from its habitat, displacement away from habitat can be as short as a few hours or as much as several 

days. Disturbance can be most significant for rare species such as the pygmy rabbit, because small effects to 

individuals can impact already reduced populations in fragmented habitat. 

Vehicle Use: Up to 33 percent of herbicide application is anticipated from vehicles (ATV/Trucks) off roads 

(Chapter 3), and 20 percent is predicted on existing roads. OHVs are used almost exclusively to carry mix tanks 

for individuals on foot to spot-spray target weeds. The vehicles themselves travel slowly to avoid accidents 

and spills, and this reduces the potential for adverse effects when compared to other types of vehicle effects. 

Equipment (e.g. mowers) and vehicles leaving roads can also hit or injure ground nesting birds, amphibians, 

reptiles, invertebrates and small mammals and their nests, particularly sessile mollusks or wildlife like grouse that 

“hide and cower.” Vehicles can break down pygmy rabbit “tunnels” through the sagebrush making the rabbits 

more vulnerable to predation. Raptors and corvids have learned to follow human pathways and predate on ground 

nesting birds, causing increased mortality. OHV/s or small crews of individuals doing spot-treatments would 

likely be negligible to most common wildlife. Bureau Sensitive and Federally Listed -required clearances would 

identify the crucial habitats of rare species so potential disturbance /disruption to those areas could be avoided, at 

least during the most vulnerable periods of the year. 

Manual/Mechanical/mowing/planting treatments may involve chainsaws and motorized equipment that have the 

potential to disturb or disrupt species during vulnerable life stages. Manual treatments are more likely to require 

repeated treatments (and additional risk of disturbance). Mowing/chaining, plowing have disruption potential 

due to noise, and also could kill or injure sessile or slow-moving wildlife such as mollusks, worms or non-flying 

insects, newly-born young, or immobile life forms such as eggs that are in the direct path of ground-disturbing 

machinery. The extent of direct injury is dependent on the duration of the disturbance, the footprint of the grounddisturbing/habitat changing treatment, time of year of the activity, the density and vulnerability of native wildlife 

in the treatment area, and acres affected. 

Directed livestock has some potential for disturbance because the activity is intensive and highly focused. 

Directed livestock grazing would likely occur in areas where weed density has already severely degraded native 

wildlife habitat. Disturbance to native wildlife would be insignificant and short-term. 

Biological controls would have negligible disturbance effects limited to dispersing insects and monitoring. 

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Prescribed Fire for Weed Control – Most native wildlife populations have adaptive mechanisms that facilitate 

their resilience to natural disturbances. Russell et al. (1999) summarized the literature on herptile (and other 

wildlife) responses to fire and noted that most wildlife can avoid harm by leaving the treatment area or by 

burrowing. Although there is potential for some harm or mortality during vulnerable periods (snake skinshedding was mentioned), they cite Means and Campbell (1981) “it is illogical that animals associated with fire 

vegetation are not themselves at least behaviorally adapted to resist mortality by fire” and cite Lyon et al. (1978), 

Wood (1981): “high levels of fire-induced mortality also appear to be uncommon in many species of birds and 

mammals.” Prescribed fire, which often occurs earlier in the season or during wetter times of the year than 

wildfire, might occur when species are more vulnerable such as during breeding seasons and thus might have 

more potential to kill or injure eggs, young or immobile species within hot-spots in the treatment area. 

Herbicide application has disturbance potential. Foot traffic of backpack sprayers or daubing herbicide is similar 

to foot traffic disturbance from manual methods (hand pulling), in that crews work slowly and affected wildlife 

have time to move out of the way (USDA 2005). Power sprayers and motorized equipment could be considered 

equally disturbing as chainsaws, although crews might move through an area more quickly. The disturbance 

from boom-sprayers is similar to vehicle and OHV effects, but boom sprays would generally be used only along 

roads and other rights-of-way. Aerial applications can cover large areas and be highly intense, but disturbance at 

any one area is of short-duration. Wildlife varies in their sensitivity to over-flight disturbance, but most response 

would be indirect and related to wildlife leaving cover or food for various periods of time. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

Disturbance Effects 

Alternative 1 would result in a net decrease of 3,400 acres of habitat treated annually compared to the No 

Action Alternative, so the potential of short-term impacts to wildlife in the treatment area would decrease. No 

herbicide impacts would result to wildlife from BLM activities under this alternative. Compared to the No Action 

Alternative, the 1,600-acre increase in mechanical treatments, particularly those with ground-disturbing potential 

such as plowing/disking or chaining, would have greater disturbance potential to native wildlife in the treatment 

area than in the other alternatives. Some sites would be disturbed several times to meet the same weed treatments 

result, since the effectiveness of this alternative is predicted at 30 percent. 

Invasive Plant Effects 

Because non-herbicide methods are not particularly effective at controlling about 2/3 of the noxious weeds in 

Oregon (Appendix 7: Table A7-1), Alternative 1 would reduce opportunities to control several weed groups that 

adversely affect wildlife habitat. These groups include the annual grasses which have severely impacted the 

sagebrush ecosystem (sage grouse, pygmy rabbits), Oak Woodlands (Columbia white tail deer, other ungulates, 

upland game birds), and the Siskiyou Biome (Mardon skipper). Alternative 1 would also preclude the use of 

pre-emergent herbicides that can be effective in restoring wet meadow habitats, where soil or ground-disturbing 

effects would preclude plowing/disking, or where such post-treatment herbicide treatments are needed after 

mechanical treatments to prevent new (or different) weed invasion. Limiting tools in restoration activities 

could result in important wildlife habitat not being treated because successful native habitat restoration could 

not be assured. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Herbicide and Non-Herbicide Treatment Effects 

The four herbicides available under this alternative include two of the six herbicides proposed in this EIS that 

have high risk ratings to wildlife: glyphosate and 2,4-D. 2,4-D may disrupt endocrine function. The current 12 

percent rate of spread increases the number of acres that may be exposed to increased disturbance resulting from 

treatments and a higher chance of adverse exposure to herbicides from treatments. The use of broad-spectrum 

herbicides like glyphosate increases the risk of damage to non-target vegetation important to wildlife. Glyphosate 

and 2,4-D are the only herbicide under Alternative 2 authorized for aquatic weeds, and each has the possibility of 

adverse impacts to amphibians. 

Invasive Plant Effects 

The inability to control invasive weeds that are not yet listed as noxious increases the chance that new invasive 

plants might become well established prior to being controlled. Habitats are more difficult to protect. In addition, 

none of the herbicides under Alternative 2 are selective against annual grasses, so medusahead and cheatgrass 

would continue to degrade sage grouse and other habitats. Approximately 1/3 of the BLM lands in Oregon are 

projected to be infested with noxious weeds in 15 years, with a corresponding decrease in their value to wildlife. 

Restoration and recovery for rare species could be deterred when invasive plants invade their habitat. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Herbicide Effects 

The wider choice of herbicides available under this alternative would increase the likelihood that a more targetspecific herbicide could be used to reduce collateral damage in or near the treatment area. Alternative 3 includes 

the use of three herbicides that had risk levels below the Level of Concern (LOC) for all evaluated wildlife under 

all scenarios: chlorsulfuron, imazapic and sulfometuron methyl. 

Alternative 3 adds three more herbicides approved for use in aquatic habitats, facilitating the selection of 

herbicides with less toxic effects to aquatic wildlife. The likelihood of having an herbicide that will safely treat 

invasive plants in habitats of rare species would be substantially increased under this alternative. The addition 

of imazapyr as an aquatic herbicide allows use of an herbicide with zero risk to aquatic invertebrates at typical 

application levels (Table 3-15). It provides alternatives to glyphosate where there may be amphibian concerns. 

Invasive Plant Effects 

More habitat would be protected under this alternative and more weeds could be curtailed before they become 

established, compared to the No Action Alternative; noxious weeds are projected to infest 1.9 million fewer acres 

in 15 years. Alternative 3 also would extend herbicide treatments to invasive plants not yet listed as noxious 

weeds. Sagebrush Steppe Biome wildlife will benefit from imazapic to control cheatgrass and medusahead; 

none of the treatment measures or herbicides available in Alternatives 1 and 2 are as effective at controlling these 

invasive annual grasses. Tebuthiuron could help restore essential sagebrush mosaic seral patterns. The additional 

herbicides expand IVM options, such as combining herbicides following burns to reduce the chance of target 

weeds from re-establishing, or other weeds from invading the burn site. 

Disturbance Effects 

Additional herbicides provide managers with more flexibility to tailor treatments to benefit wildlife by allowing 

use of herbicides with wider seasonal windows (making avoidance of susceptible wildlife periods more feasible), 

and facilitating greater opportunities to implement IVM strategies that combine herbicides and non-herbicide 

treatments to more specifically meet ecological goals. Herbicides have lower ground-disturbing effects, so there 

would be less chance of disturbance to micro sites for mollusks, reptiles, birds, and invertebrates. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Sudden Oak Death 

Under Alternative 3, treating Sudden Oak Death-infested native habitat with herbicides could reduce, but not 

avoid, the adverse effects to wildlife caused by treating Sudden Oak Death. Sudden Oak Death occurs in late 

seral coniferous forests in western Oregon that is also essential habitat for the listed marbled murrelet and 

northern spotted owl. The non-herbicide treatment for Sudden Oak Death includes cutting of infested plants and 

susceptible plant species, and repeated burning (USDA, USDI 2008). The intensive and repeated treatment for 

Sudden Oak Death under non-herbicide methods has adverse disturbance effects on both of these species. The 

loss of vegetation and habitat inherent to Sudden Oak Death treatment cannot be avoided, but repeated mechanical 

and permanent ground disturbance related to treatment of Sudden Oak Death areas could be reduced with the 

use of herbicides, and the higher likelihood of control will benefit wildlife. Many of the host species affected by 

Sudden Oak Death are also important for wildlife forage and structure. See the Pests and Diseases section for 

more details about Sudden Oak Death. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Effects include all those described for Alternative 3 plus the following. 

Effects of Herbicides 

Many of the Conservation Strategies identify weeds and habitat degradation as a factor contributing to the rare 

status of the species. The ability to use herbicides for certain habitat improvements would increase the number of 

acres treated for wildlife recovery. For example, low-dose application of tebuthiuron can be an effective herbicide 

to help restore sagebrush mosaics in sage grouse restoration (Olson and Whitson 2002, Johnson et al. 1996). 

Herbicides as a restoration tool for wildlife habitat can reduce or avoid the adverse effects associated with fire or 

mechanical methods. 

Alternative 4 would also make herbicides available to treat rights-of-way, administrative sites, and recreation 

sites. Treating native vegetation on these sites would increase the risk of herbicides on plants being ingested by 

wildlife. Diuron, bromacil, and tebuthiuron become available under this alternative, although diuron and bromacil 

are normally applied to very low growing vegetation where the maintenance of bare ground is the objective. 

Diuron has a higher risk than some of the herbicides available under Alternatives 2 and 3, primarily for ingestion 

situations for mammals, but it also has lower risk for birds at the typical rate than some of those same herbicides. 

Bromacil is one of the herbicides with lowest risk to invertebrates, and is one of the least impactful of herbicides 

that have risks for Bureau Sensitive and Federally Listed Species. Ingestion for most wildlife is unlikely 

because bromacil will be used as a pre-emergent herbicide. Tebuthiuron has no more than low rating for typical 

application rates in all exposure scenarios including those to Bureau Sensitive and Federally Listed Species. 

Some animals, like deer, will seek out openings, such as rights-of-way because they provide lower growing 

succulent plants. Bears and other large mammals often use road or power line rights-of-way for travel because 

the reduced vegetation is easier to navigate, and raptors will often hunt along the openings. Exposure through 

ingestion of herbicide-contaminated forage is increased if diuron is applied to forage vegetation in these areas. 

Effects of Invasive Plants 

Wildlife habitat would benefit from the reduced spread of noxious weeds and other invasive plants; noxious weeds 

are projected to infest 300,000 fewer acres in 15 years under Alternative 4 than under Alternative 3. 

Effects of Treatment 

Herbicides are projected to be used on 9,300 acres to meet native vegetation control objectives in and adjacent 

to rights-of-way and other developments. These objectives are currently being met with other non-herbicide 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

methods. Roadsides would most likely be sprayed with low booms nozzles fixed to vehicles on the road; power 

line and other linear rights-of-way could be treated similarly using existing access roads, and in some instances 

east of the Cascades, aerial application could be used. Disturbance effects to wildlife are low at many of these 

sites because the development often displaces animals that are susceptible to noise and activity away from these 

areas, limiting their exposure, or they become habituated to it. In any event, herbicide application activities would 

be no more disturbing than current non-herbicide treatments. 

Continued maintenance of early seral vegetation under power lines can be beneficial to some species. A 

symposium of papers evaluating rights-of-way across the United States and Canada included several studies 

where rare species used or even benefitted from right-of-way habitat and vegetative treatments (including 

herbicide treatments) on those areas (Goodrich-Mahoney et al. 2000). Wildlife could be adversely affected by 

herbicides and/or habitat change if and when these sites are treated, but it is the maintenance of current conditions 

that keeps the habitat from being lost to natural succession. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Effects include all those described for Alternative 4 plus the following. 

Effects of Herbicides 

The moderate residual effect of diflufenzopyr + dicamba could impact insects and mammals in treatment area 

because of proposed use in forest and rangeland situations. Diquat is one of the most hazardous herbicides for 

wildlife proposed in any of the alternatives, but use is limited to aquatic applications where it could be needed 

to control giant salvinia if it were to enter Oregon, or as a back-up for one of the other aquatic herbicides if they 

were to become ineffective. The presence of desirable aquatic wildlife would be considered at the site-specific 

level. In the case of both herbicides, the proposed use is low. 

Effects of Treatments 

Approximately 5,000 additional acres would be treated under Alternative 5, and these could be for a full range 

of non-commodity vegetation management objectives, although most would go to additional wildlife habitat 

improvement treatments not included in Alternative 4. Native vegetation such as rabbitbrush and Western juniper 

could be treated in this scenario, for example, to help restore native sagebrush habitats. 

Alternative 5 has the greatest opportunity for wildlife habitat improvement treatments, and potentially the greatest 

positive effects to wildlife. Re-establishing ecosystems to be sustainable under fire disturbance could have 

long-term benefits to the wildlife populations in those ecosystems. Wildlife habitat improvement treatments 

that restore complex mosaic shrub/forb/bunchgrass communities would generally be beneficial to sagebrushdependent wildlife (Crawford et al. 2004). Any adverse effects would be considered at the site-specific level. 

There could be potential short-term impacts from the treatment of native shrubs such as rabbitbrush, which can 

be locally important to pollinators (Stephen, B. pers. comm.), or to herbivores where in the late season more 

palatable vegetation is unavailable (Clements and Young 1997). Treatments designed to reduce fire risk may have 

short-term adverse impacts to wildlife. Vegetation changes that are sufficient to reduce fire risks can be more 

extensive and intensive than weed treatments, and thereby have a greater chance of reducing native vegetation 

important to local wildlife for the short-term. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Cumulative Effects 

Native wildlife in Oregon has been influenced by dozens of stressors since the onset of European settlement. 

Habitat continues to be lost to a plethora of natural and anthropogenic disturbances that have resulted in highly 

fragmented habitat for most wildlife species and lower population levels from many. Wildlife that prefer or 

tolerate human activities and habitat changes such as coyotes and ravens have increased, often outcompeting 

less adaptable wildlife. Invasive plants and animals reduce native wildlife survival and contribute to unhealthy 

ecological systems, unbalanced communities, and decreased connectivity. 

Use of herbicides, fungicides, fertilizers, and insecticides contribute to the landscape levels of chemicals in the 

environment (Table 4-1). Some of the more toxic (generally non-BLM) chemicals can accumulate in wildlife 

over the long-term (Belden et al. 2006). Several other herbicides such as alachlor, diquat, glyphosate, picloram, 

and 2,4-D also have been detected in surface and ground water, and the EPA has assigned MCLs to all of them 

(Stevenson et al. 1997). Field studies of herbicide effects are few and some unforeseen risks may exist (Blus 

and Henny 1997). There is a chance of additive chemical reactions in downstream waterways from combining 

off-site herbicides from BLM projects with run-off from more dangerous insecticides used in intermingled private 

agricultural lands. BLM reduces this risk as much as possible by using targeted application methods, herbicides 

with low persistence and low toxicity, and establishing buffers around susceptible areas. 

BLM lands make up 26 percent of the lands in Oregon, a high percentage of the habitat for native wildlife 

remaining in Oregon, and 70 percent of the remaining Oregon sage grouse habitat (Hagen 2005). The addition 

of more tools to control weeds under any of the action alternatives would improve opportunities to work 

cooperatively across multiple ownerships in more effective ways. Neighbors may be more inclined to treat 

weeds adjacent to BLM if the BLM lands were also treated and were not a source population for reintroduction 

of noxious weeds. Weed treatment partnerships would be more effective, as they have a greater likelihood of 

treating problems within logical control areas. 

The Proposed Action (Alternative 4) is projected to result in 2.2 million fewer acres of noxious weeds over the 

No Action Alternative. When used in conformance with the SOPs and PEIS Mitigation Measures, and after 

site-specific NEPA analysis, the herbicide risks to wildlife appear to be much less than the documented effects 

of additional infestations of invasive plants. Although use of some of these herbicides may pose some risk to 

individuals within a wildlife population in some isolated cases, a reduction or slowing of invasive plants at this 

magnitude will benefit wildlife populations and vegetation community health on a landscape scale. 

Livestock 

Affected Environment 

Approximately 14 million acres of public lands in Oregon are open to livestock grazing, with use levels 

established in land use or resource management plans and administered through the issuance of grazing permits/ 

leases. The majority of the grazing permits issued by the BLM involve grazing by cattle, with fewer and smaller 

grazing permits for other kinds of livestock (primarily sheep and horses). 

The BLM conducts grazing management practices through BLM Manual Handbook H-4120-1 (Grazing 

Management; USDI 1984a). Management of livestock grazing is authorized and enforced through both permits 

and leases. The grazing permit establishes the allotment(s) to be used, the total amount of use, the number and 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

kind of livestock, and the season of use. Term grazing permits/leases may also contain terms and conditions as 

appropriate to achieve management and resource condition objectives. Allotment management plans further 

outline how livestock grazing is to be managed to meet multiple-use, sustained yield, and other needs and 

objectives, as identified in the land use plans. 

Rangeland Health Standards and Guidelines for Livestock Grazing Management for Oregon and Washington 

were approved by the Secretary of the Interior in August 1997 (USDI 1997). The standards are expressions of the 

physical and biological condition or degree of function necessary to sustain rangeland ecosystems. The standards, 

designed to comply with 43 CFR 4180, direct management toward the maintenance and restoration of physical 

function and biological health of rangeland ecosystems. The five standards are: 

1) watersheds are in or making significant progress towards properly functioning physical condition in 

uplands areas; 

2) watersheds are in or making significant progress towards properly functioning physical condition in 

wetland-riparian areas; 

3) ecological processes including the hydrologic cycle, nutrient cycle, and energy flow are maintained; 

4) water quality complies with State water quality standards; and, 

5) significant progress is being made toward restoring or maintaining habitats for all Bureau Sensitive 

and Federally Listed. 

Reviews of rangeland health standards are often conducted when grazing permits or leases expire, particularly 

when those permits or leases are within Clean Water Act section 303d-listed streams or Essential Fish Habitat 

watersheds. 

Public lands provide an important source of forage for many ranches, especially during spring and summer 

months, allowing for private lands to be devoted to the production of feed sources and resources to sustain 

operations the remainder of the year. Grazing on these lands helps support the agricultural component of many 

communities scattered throughout the west. As of February 2009, the total number of grazing permits/leases 

in Oregon was 1,286, with a total of 1,022,645 Animal Unit Months (AUMs) authorized (USDI 2009a). Most 

grazing is east of the Cascades. Authorized livestock grazing west of the Cascades is limited to portions of 

Josephine and Jackson Counties. The 88 grazing leases in these two counties have a composite authorized 

or allowable use of up to 15,220 animal unit months (AUM) on an estimated 329,995 acres. Actual livestock 

AUM use west of the Cascades is generally far less due to variations in individual operator preferences, seasonal 

availability of forage, and other factors. Some leases are inactive and others are planned to be phased out over 

time (i.e. 49,423 acres, 2,714 AUMS, and 11 grazing leases in the Cascade Siskiyou National Monument in 

Josephine County). 

Livestock consume annual and perennial native and introduced grass species, and seasonally utilize forbs and 

some shrubs. Healthy plant communities support current livestock grazing levels. Invasive plants reduce 

available desirable forage for livestock, degrade plant community health, and result in reduced capacity to sustain 

existing grazing levels. A combination of invasive plants and shorter fire return intervals55 can further limit forage 

use from year-round to seasonal, or to none at all. 

Some grazing permit holders are seeking, or have, organic certification. Herbicide use within these allotments 

could conflict with this objective. 

55 Reference is to the cycle of invasive annual grasses like cheatgrass, and their effect of substantially shortening natural 

fire return intervals at the expense of native (and more palatable) vegetation. 

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Environmental Consequences 

This section addresses the reasonably foreseeable effects of the alternatives on livestock grazing on BLM lands in 

Oregon. The effects of the alternatives on other ecological functions of rangelands are described in other sections 

in this Chapter. It is recognized that all alternatives exclude herbicide use specifically for commodity production. 

That means that herbicide use proposals will not, either as an objective or as an evaluation criterion, have a 

site-specific grazing production purpose. Noxious weed, and pest and disease, treatments are driven instead by 

weed control objectives including stopping new weeds from getting a foothold, preventing existing weeds from 

spreading to new areas, protecting or restoring susceptible areas such as Bureau Sensitive species’ habitats, and 

preventing weeds from spreading to adjacent non-BLM lands. Such treatments could occur in grazing areas 

in part because invasive plants can occur anywhere, and in part because disturbed sites are favored by most 

noxious weeds and other invasive plants, and livestock can serve as a vector. However, such treatments would be 

distinguishable from those specifically designed to protect or improve grazing because they would not be focused 

on grazing allotments while permitting weed populations nearby to flourish or spread. 

Nevertheless, noxious weed control efforts are going to affect future grazing numbers, much the same way control 

efforts will affect such things as water quality, and visual resources. Economic effects, including those resulting 

from lost productivity on grazing lands within the State are one criterion the State uses when considering whether 

to designate non-native plants as noxious weeds. To the degree BLM noxious weed treatments contribute to 

the control and elimination of weeds the State and neighboring landowners have identified as needing control, 

Chapter 1’s Purpose number 5 of cooperatively controlling invasive plants so they do not infest or reinfest 

adjacent non-BLM lands, will be furthered. 

Effects to livestock from the proposed action or one of the other action alternatives could result from direct or 

indirect contact with the herbicides, indirectly from inadvertent reductions in forage amount and preferred forage 

type, and from the reduction of noxious weeds and restoration of native vegetation. 

Effects Common to All Alternatives 

Effects of Herbicides on Livestock 

The extent of direct and indirect impacts to livestock from herbicides would vary by the application method, 

herbicide used, physical features of the terrain including the presence of forage, and the weather conditions 

at the time of application. Possible adverse direct effects to individual animals include death, damage to vital 

organs, change in body weight, decreases in healthy offspring, and increased susceptibility to predation. The 

impacts of herbicide use on individual livestock would depend directly on the sensitivity of each species to the 

particular herbicides used, how the individual animal was exposed to the herbicide, and indirectly to the degree 

to which a species or individual is positively or negatively affected by changes in rangeland conditions, including 

forage quality and availability. Livestock would have a greater chance of being adversely impacted by herbicide 

use if the pasture or use area was partially or completely sprayed because they would have greater exposure to 

herbicides through direct contact with the herbicide upon application or indirect contact via dermal contact with 

vegetation or ingestion of vegetation. 

When herbicide labels prohibit grazing, or risks are otherwise anticipated, exposure is typically reduced by 

the removal of livestock during vegetation treatments, scheduling treatments when livestock are not present, 

temporarily fencing the treated area, or herding the livestock away from the treatment area and shutting off 

water or using other techniques to keep them away. However, the grazing permit holder would be adversely 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

affected in the short term as a result of the area being temporarily unavailable for grazing purposes. Additionally, 

in the short term, there could be impacts to the sale and consumption of livestock as a result of mandatory 

restrictions (quarantine) associated with the use of herbicides. During the interim period, the permit holder 

may incur additional costs for replacement forage and/or a loss of income. Livestock may experience greater 

impacts in systems where herbicide transport is more likely, such as areas where herbicides are aerially sprayed 

adjacent to rangeland, dry areas with high winds, or areas where rainfall is high and soils are porous; however, 

these scenarios have not been modeled. The degree of interception by vegetation, which depends on site and 

application characteristics, would also affect direct spray impacts. 

The impacts of herbicide use on livestock would be site and application specific, and as such, site assessments 

would have to be performed, using available impact information, to determine an herbicide use strategy that 

would minimize impacts to livestock. 

Effects of BLM-Evaluated Herbicides 

According to BLM risk assessments, herbicide exposure scenarios of direct spray, spill, and indirect contact 

with foliage after direct spray do not pose a risk to small mammals (large mammals were not modeled, but 

have a smaller surface area to body weight ratio, so are less likely to be impacted by these scenarios than small 

mammals; Table 3-14). Several herbicides do pose a risk to large mammalian herbivores under a scenario of 

ingestion of food items contaminated by direct spray, and these are presented below. The receptor chosen for the 

large mammalian herbivore was a 154-pound mule deer. 

Bromacil does not present a risk to small mammals via direct spray or indirect contact with foliage after direct 

spray (Table 3-14; ENSR 2005b). These scenarios are very conservative because they assume 100 percent 

absorption and because small mammals have a relatively large surface area for absorption of herbicide. 

Therefore, it is unlikely that bromacil would affect larger livestock under these scenarios. Low chronic risk for 

large mammal ingestion at the typical rate, and low acute and moderate chronic risks for ingestion scenarios 

at the maximum application rate suggest direct spray of bromacil onto rangeland could pose a risk to livestock 

consuming sprayed vegetation, particularly if applied over large areas. However, bromacil is a non-selective 

herbicide that is not registered for application on rangelands or other livestock grazing areas where some 

vegetative cover is desired, suggesting that under typical use bromacil would not impact livestock. Any risk 

would come from off-site transport of bromacil to livestock grazing areas or treatment of vegetation in accessible 

rights-of-way. Use of bromacil in spot applications or over small areas is not likely to impact livestock. Based on 

label directions, there are no restrictions on livestock use of treated areas. 

Chlorsulfuron risk quotients for mammal receptors for all modeled scenarios were below the conservative LOC of 

0.1, indicating that direct spray and ingestion of sprayed vegetation is not likely to pose a risk to livestock (Table 

3-14; ENSR 2005c). Based on label directions, there are no restrictions on livestock use of treated areas. 

Dicamba: The ingestion of food items contaminated by direct spray of dicamba at the maximum application 

rate would pose a low acute and chronic risk to large mammalian herbivores (Table 3-14). Because dicamba 

is proposed for use in rangelands and forestlands and does have moderate residual activity, livestock may be at 

risk, particularly if it is sprayed throughout the range area. Based on label directions, there are no restrictions on 

livestock use of treated areas, other than for lactating animals. 

Diflufenzopyr is not proposed for use alone. Risk quotients for terrestrial animals were all below the most 

conservative LOC of 0.1, indicating that direct spray of diflufenzopyr is not likely to pose a risk to livestock 

(Table 3-14; ENSR 2005d). Based on label directions, there are no restrictions on livestock use of treated areas. 

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Diquat: Low chronic risks for ingestion scenarios at typical rates, and low to moderate chronic and acute risks at 

maximum rate (Table 3-14; ENSR 2005e) suggest that livestock could be at risk from the short- and long-term 

consumption of vegetation contaminated by diquat. However, use on BLM lands would be limited to aquatic 

applications; diquat is not registered for rangelands. Thus, the likelihood of exposure of livestock to diquat is 

minimal. Livestock that feed exclusively in riparian areas where drift might be present on riparian grasses, and/ 

or drink water from ponds treated with diquat, are potentially at risk. However, labels require livestock to be 

removed from areas with such exposures. 

Diuron: There were no acute risks but low to moderate chronic risk if food was directly sprayed at the typical 

application rate; there would be low acute risk and moderate to high chronic risk if food was sprayed at the 

maximum application rate (Table 3-14; ENSR 2005f). However, because diuron is a non-selective herbicide not 

likely to be broadcast where vegetation is desired, and not registered for use on rangelands, exposure to livestock 

would be limited. Any exposure would likely be limited to rights-of-way use, off-site drift, or surface runoff. 

Based on label directions, there are no restrictions on livestock use of treated areas. 

Fluridone: Risk quotients for large terrestrial animals were below the most conservative LOC of 0.1 for all 

scenarios (Table 3-14; ENSR 2005g). These results indicate that accidental direct spray or drift of this aquatic 

herbicide would be unlikely to pose a risk to livestock. 

Imazapic: Risk quotients for terrestrial animals were all below the most conservative LOC of 0.1, indicating that 

direct spray or drift of imazapic would be unlikely to pose a risk to livestock (Table 3-14; ENSR 2005h). Based 

on label directions, there are no restrictions on livestock use of treated areas. 

Dicamba + diflufenzopyr poses a low chronic risk to large mammalian herbivores that consume plants 

contaminated by direct spray at the typical application rate and a moderate risk for ingestion scenarios involving 

direct spray at the maximum application rate (Table 3-14; ENSR 2005i). Because it is proposed for use in 

rangelands and has moderate residual activity, livestock may be at risk from the application of this herbicide, 

particularly if it is sprayed throughout the range area. Based on label directions, there are no restrictions on 

livestock use of treated areas. 

Sulfometuron methyl: This herbicide is relatively non-selective and would be used on rights-of-way, but it is not 

registered for sites that are grazed. Risk quotients for terrestrial animals were all below the most conservative 

LOC of 0.1, indicating that direct spray or drift of sulfometuron methyl would be unlikely to pose a risk to 

livestock (Table 3-14; ENSR 2005j). 

Tebuthiuron: For large mammalian herbivores ingesting food items contaminated by tebuthiuron, there would 

be a low acute and chronic risk if the food was directly sprayed at the maximum application rate (Table 3-14; 

ENSR 2005k). The strength of this herbicide is its use as a habitat modifier in the BLM shrub reduction program; 

it is relatively non-selective but does not tend to harm grasses present. Therefore, impacts to livestock would 

be unlikely with intended use of this herbicide. According to the label for at least one formulation which has 

tebuthiuron as an active ingredient, if a treated area is to be used for haying or grazing, no more than 5 pounds per 

acre of formulation should be applied, and the product should not be applied more than once per year. 

Effects of Forest Service-evaluated Herbicides 

Risk information for the following eight herbicides is taken from ecological risk assessments (RAs) completed 

by the Forest Service prior to BLM’s completion of the PEIS. As part of its risk assessments, the Forest Service 

developed worksheets (SERA 2005b), which allowed the BLM to assess the risks of the herbicides using its own 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

maximum application rates and LOCs (rather than the Forest Service rates and LOCs), and to parallel the BLM 

risk assessment process as much as possible. However, modeled risk scenarios for terrestrial animals may be 

different from those used for the BLM-evaluated herbicides, depending on the specificity of available toxicity 

data. The assessment of impacts below is presented using the Forest Service upper estimates of Hazard Quotients 

(HQ), to maximize the conservatism of the assessment. In addition, it should be noted that the HQs developed 

by the Forest Service (as well as the BLM) are already conservative for many reasons (e.g., assumption of 100 

percent dermal absorption, assumption of 100 percent of diet contaminated, use of most sensitive values for 

exposure and dose/response assessments). Referenced risk quotients are displayed on Table 3-15. 

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. 

Clopyralid: Large mammals face low acute risks from direct spray and from consumption of contaminated 

grass at the typical and maximum application rates. The maximum application rate also poses a low chronic 

risk to large mammals consuming on-site contaminated vegetation. All risks identified fall within the lowest 

risk category; adverse effects to livestock are unlikely with expected exposure scenarios. According to label 

directions, there are no restrictions on grazing or hay harvest following application at labeled rates, but livestock 

should not be transferred from treated grazing areas to susceptible broadleaf crop areas without first allowing for 7 

days of grazing on untreated pasture. 

Glyphosate presents a low to moderate acute risk to livestock under several of the direct spray, ingestion, and spill 

scenarios, and a low chronic risk for large mammals for consumption of on-site contaminated vegetation under 

the maximum rate (SERA 2003a). Ingestion of treated grasses could represent a risk, but glyphosate is nonselective and kills grass, suggesting that spot applications in rangeland would be the most appropriate use of this 

herbicide (although risk could occur if invasive grasses were treated when they were young and palatable). Spot 

applications would reduce risks associated with consumption of contaminated vegetation, as fewer non-target 

areas would be impacted by direct spray or spray drift. Based on label directions, there are no restrictions on 

livestock use of treated areas. 

Hexazinone: Applications of hexazinone at the typical and maximum application rates would pose a low to 

moderate acute risk to livestock under several exposure scenarios, and a low to moderate chronic risk to large 

mammals under the on-site consumption of contaminated vegetation scenario at typical and maximum rates 

respectively (SERA 1997). According to label directions, livestock should not be grazed, nor forage or hay cut, 

on treated areas for 60 days after application. 

Imazapyr applications at the typical application rate should not pose a risk to livestock (SERA 2004d). The 

maximum application rate, however, would pose a low risk under the direct spray of a small animal and 

consumption of contaminated vegetation by large mammal scenarios. Imazapyr is not registered for use in 

rangelands; therefore, it is unlikely that impacts via direct spray or consumption of contaminated vegetation 

would occur. Based on label directions, there are no restrictions on livestock use of treated areas. 

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Metsulfuron methyl applications at the typical application rate should not pose a risk to livestock (SERA 

2004e). Applications at the maximum application rate pose a low acute risk to small animals under scenarios 

involving 100 percent absorption of direct spray and to large mammals under scenarios involving consumption 

of contaminated vegetation. Metsulfuron methyl is registered for use in rangeland, but impacts to livestock 

are unlikely if the typical application rate is used. However, a supplemental label restricts the application on 

rangelands to 0.06 ounces active ingredient (a.i.) per acre. 

Picloram poses a low to moderate risk for applications at the typical and maximum application rates for 100 

percent absorption of direct spray by a small animal and acute exposure through consumption of contaminated 

vegetation by a large mammal (SERA 2003b). Picloram is registered for use in rangeland, and can be applied 

over large areas heavily infested with weeds, as its primary targets are broadleaf and woody species. Therefore, 

it might be used to manage certain broadleaved plants without impacting native or desirable grasses, but with the 

potential to expose livestock. Picloram has a number of restrictions on use in areas grazed by livestock or used 

for cutting hay. In general, livestock should not be grazed on treated areas, nor should hay be cut, for 2 weeks 

after treatment. 

Triclopyr presents low to moderate risk to livestock under several acute, and two chronic, scenarios, particularly 

through the consumption of contaminated vegetation (SERA 2003c). Because risk categories were determined 

using calculated HQs for the two evaluated forms of triclopyr (triclopyr acid and triclopyr BEE) are the same, 

no differentiation is made between these two forms in this section. Triclopyr can be used in rangelands to 

selectively manage woody species without impacting native or desirable grasses, so broadcast treatments could 

create exposure scenarios if livestock are not removed or the treatment area is limited in scope. There are few 

grazing restrictions for triclopyr, except for lactating dairy cattle. Hay should not be harvested within 14 days of 

application. Although cattle can graze at any time, they would be removed from treated areas at least 3 days prior 

to slaughter. 

Effects of Treatments on Forage 

Possible adverse indirect effects from increasing herbicide use include reductions in forage amount and preferred 

forage type. However, analysis displayed in the Vegetation, Native Plants, and Plant Communities section in this 

Chapter indicates the risk to non-target plants is generally low and not dissimilar to the risk from non-herbicide 

treatments. Also, as discussed in the application assumptions in Chapter 3, broadcast treatments of invasive plants 

generally occur only with selective herbicides or in areas where invasive plants have essentially eliminated the 

native species. In any event, range conditions would generally benefit from the control of invasive plants, and any 

adverse native vegetation changes would begin to disappear within one to two growing seasons after treatment. 

Effects of Noxious Weeds on Livestock 

The spread of invasive plant populations would likely have harmful effects on livestock. Many studies and 

repeated landowner experiences show that weeds commonly reduce livestock carrying capacity from thirty-five 

percent to ninety percent (Hilken 1980, USDA 1994a). Yellow starthistle forms solid stands that dramatically 

reduce forage for livestock and wildlife. This species causes a fatal neurological disorder (chewing disease) when 

ingested by horses (USDA 2005:3-9). 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. 1997a). Rangeland 

that contains excessive or unpalatable brush cover is less useful for grazing and has reduced carrying capacity for 

domestic livestock. Similarly, capacity for cattle grazing decreases proportionately with loss of forage caused by 

weed infestation. Economic returns in terms of improved grazing value typically exceed herbicide treatment costs 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

on lands where herbicides are used to control weeds (Olson 1999). In addition, some noxious weeds are toxic to 

livestock including common tansy, leafy spurge, Russian knapweed, common St. Johnswort, tansymustard, and 

yellow starthistle. 

Treatments that maintain or reduce the cover of noxious weeds and restore native vegetation on grazed lands 

would benefit livestock by increasing (or at least slowing the decline of) the number of acres available for grazing 

and the quality of forage. Improvement or decline in range condition from invasive weeds would be proportional 

to the acres projected to become infested over time. The differences between the alternatives could be expected to 

have differing effects on grazing capacity over the long term. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

Under Alternative 1, livestock would not be affected by BLM herbicide use. Primary impacts would stem from 

other vegetation treatment methods and/or from the spread of noxious weeds and other invasive plants. 

Effects of Invasive Plants 

The potential is greatest under this alternative for the continued spread of invasive plants that would replace native 

plant communities that livestock depend on for forage. Invasive plants are projected to occupy 2.2 million more 

acres in 15 years under this alternative than under the No Action Alternative, damaging native plant communities 

including rangeland communities that provide forage for livestock. Other factors can exacerbate these effects on 

particular acres. Only about 1/3 of noxious weeds can be effectively controlled using non-herbicide methods. For 

example, it is often difficult to eradicate some species (e.g., resprouting shrubs or invasive annual grasses) by nonherbicide methods. Also, non-herbicide methods can be impractical over large areas or in some situations because 

of cost, time, or public concerns. Large-scale non-herbicide treatments can adversely affect native plants, soils 

and other resources, and lead to a higher likelihood of reinvasion than spot or selective herbicide treatments. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Effects of Herbicides 

Although herbicides would be applied to fewer acres under this alternative than under any of the action 

alternatives, the potential toxicity of the four herbicides available under this alternative keep this alternative from 

being considered the safest for livestock. As noted under Effects Common to All Alternatives above, 2,4-D and 

glyphosate present risks to mammals from direct spray and from consumption of contaminated grass at the typical 

and maximum application rates. Inadvertent spraying of grass and other forage near treated invasive weeds, as 

well as drift and other avenues, could result in exposure. Picloram also presents low to moderate risks under 

some exposure scenarios, and dicamba presents a low risk under some food contamination scenarios. 

Effects of Invasive Plants 

Under the No Action Alternative, native plant communities would continue to be impacted by cheatgrass and 

medusahead spread, decreasing plant diversity, habitat quality, and productivity thereby reducing forage for 

livestock and wildlife. Medusahead rye is a noxious weed infesting an estimated 600,000 acres of BLM lands in 

Oregon; it is considered non-forage for livestock as high silica content and other attributes render it unpalatable. 

The invasive cheatgrass infests another 5 million acres and except for a very few weeks early in the season, is 

similarly unpalatable. The frequency and intensity of wildland fire would increase as native plant communities 

continue to become more infested with these two invasive annual grasses. Noxious weeds would continue to 

expand at their current rate, and are projected to infest about 1/3 of the BLM lands in Oregon in 15 years. 

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Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Effects of Herbicides 

Although the acres projected to be treated with herbicides nearly double when compared to the No Action 

Alternative, total pounds of herbicides applied would decrease 30 to 50 percent for the typical and maximum 

rate respectively. Use of the four herbicides available under Alternative 2 would decrease by 60 to 80 percent, 

and herbicides generally less toxic to livestock would be used. For example, approximately 1/3 of the projected 

herbicide use under this alternative would be with imazapic, an herbicide with no measured risk to livestock under 

any of the exposure scenarios, and for which no grazing label restrictions apply. Similarly (from Effects Common 

above): 

• Chlorsulfuron, fluridone, and sulfometuron methyl risk quotients were all below the most conservative 

LOC indicating that direct spray would not likely pose a risk; and, 

•		 Imazapyr and metsulfuron methyl under typical application rates had no risk to livestock predicted under 

any scenario. 

For the other two herbicides available under this alternative, hexazinone presents a low to moderate risk for some 

scenarios, but it is typically utilized for treatment of woody species and is semi-selective with spot application, so 

risk to livestock under normal applications may be lower than those predicted by the risk assessment. Triclopyr 

presents low risk through consumption of contaminated vegetation at the typical rate and moderate risk at the 

maximum rate. It is utilized in rangelands due to selectivity for woody species, and has low residual activity. 

The reduced application rates and prohibition of using aerial applications west of the Cascades would 

substantially reduce the impacts of off-site drift to livestock, an exposure scenario that is not specifically modeled 

for the BLM herbicides. (Consumption of contaminated vegetation off-site was modeled for most of the Forest 

Service herbicides, with no risk demonstrated to livestock for any of these herbicides, except triclopyr when 

applied at the maximum application rate.) The increased number of herbicides available under this alternative 

would lower risk to livestock because more choices would be available to meet site-specific concerns including 

the presence of livestock. 

Effects of Invasive Plants

 Noxious weeds are projected to infest 1.9 million fewer acres under this alternative than under the No Action 

Alternative. The option to use more selective and effective herbicides for noxious weed control would assist in 

the eradication of new infestations on BLM lands and also slow the spread of larger noxious weed infestations 

from public land into non-Federal commercial rangelands. Alternative 3 would provide herbicides that could 

be used to control invasive annual grasses such as cheatgrass and medusahead, which have displaced native 

grassland communities and negatively impacted livestock grazing patterns, seasons of use, and overall operations. 

This would indirectly help control other invasive plants that are either the result of large grass-related fires, or that 

are otherwise fire dependent and out-compete native vegetation in establishing dominance in fire-disturbed sites. 

The lack of an aerial spray option west of the Cascades could result in large areas of rangeland remaining 

untreated, which could negatively impact livestock habitat and forage in these areas over the long term. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Effects described for Alternative 3 would also apply to Alternative 4. Additional effects are described below. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Effects of Herbicides 

This alternative is projected to increase acres treated with herbicides by 2.7 times when compared with the No 

Action Alternative, but increase the pounds of herbicides used only 23 to 63 percent (for the typical and maximum 

rate respectively). Much of the increase is from three herbicides not registered for use on rangeland and new to 

this alternative for vegetation control in rights-of-way and other developments. Bromacil, diuron, and tebuthiuron 

are relatively long-lasting non-selective pre-emergent herbicides that would be used for complete vegetation 

control in and near developments where vegetation is already being kept at a minimum to protect the investment 

and function of the developments. Treatment of recreation and administrative sites under this alternative would 

have little or no impact on livestock since they have limited or no access to these sites, but treatments on unfenced 

rights-of-way and other developments could result in livestock exposure. None of the three additional herbicides 

represent a risk to livestock from direct spray or dermal contact with treated vegetation. Ingestion of treated 

foliage does present risk however; tebuthiuron presents a low risk from mammal ingestion scenarios when applied 

at the maximum rate, and bromacil presents low to moderate risk, and diuron presents low to high risks, under 

several of the ingested vegetation scenarios. 

There would also be an increase in acres treated with most of the other Alternative 3 herbicides (when compared 

to Alternative 3) along rights-of-way where native vegetation control would better meet maintenance objectives 

(see Administrative Sites, Roads, and Rights-of-Way in this Chapter). Use of the four Alternative 2 herbicides 

would remain lower than under Alternative 2. 

Wildlife habitat improvement treatments to meet goals specified in Conservation Strategies (e.g. tebuthiuron 

applications to thin sagebrush) could pose a risk to livestock; such risks will be considered at the site-specific 

scale. The availability of 12 to 16 herbicides would provide options for reducing this risk, since about half of the 

herbicides available have little or no identified risk to livestock. Tebuthiuron in particular is expected to be used 

in low doses to effect structural changes in sagebrush, but such doses present no identified risk to livestock. 

Forage and the Effects of Invasive Plants 

The small areas subject to total vegetation removal, such as around administrative sites and communications 

facilities, should have little to no effect on the availability of livestock forage. These areas are already low in 

forage production, as they are currently subject to manual or mechanical cutting. In addition, livestock may 

already be excluded by fences. Range conditions would benefit from additional control of noxious weeds. 

Inadvertent control of noxious weeds during herbicide rights-of-way treatments are projected to reduce the acres 

infested with noxious weeds in 15 years another 300,000 acres when compared to Alternative 3. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Effects described for Alternative 4 would also apply to Alternative 5. Additional effects are described below. 

Effects of Herbicides 

It is estimated that an additional 5,000 acres would be treated with herbicides under this alternative when 

compared to Alternative 4, with 2,4-D and imazapic estimated to each account for 35 percent of the increase. 

Treatments would be primarily for wildlife habitat improvement; although a variety of non-commodity resource 

management objectives may be accomplished. Potential livestock exposure would be greatest under this 

alternative. Imazapic presents no identified risk to livestock, but 2,4-D presents risks to mammals from direct 

spray and from consumption of contaminated grass at the typical and maximum application rates. 

The two additional herbicides available under this alternative are projected to each be used on 200 acres annually. 

Diflufenzopyr+ dicamba risk quotients are all below the most conservative LOC indicating direct spray would 

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not pose a risk to livestock. Consumption of vegetation contaminated by direct spray of diquat at the typical rate 

poses low chronic risk and moderate acute and chronic at the maximum application rate; therefore livestock, could 

be at risk from short and long-term consumption of contaminated forage. However, because this is an aquatic 

herbicide that is not proposed for use in terrestrial areas, and because the label requires exclusion of livestock, the 

likelihood of livestock exposures is minimal. There is a concern for livestock feeding in wetland-riparian areas 

where the herbicide would be utilized; risk could be reduced through herding or fencing animals out of treatment 

areas until the herbicide has dissipated. 

Forage and the Effects of Invasive Plants 

Because Alternative 5 involves the most treatment acres, it could also have the greatest short-term adverse impact 

on livestock grazing operations through temporary closures, although wildlife habitat improvement treatments 

might similarly benefit livestock. Benefits to livestock from the control of noxious weeds and other invasive 

plants would be similar to those described for Alternative 4. 

Cumulative Effects 

Loss of native vegetation and declining ecosystem health on public lands due to noxious weeds and other invasive 

vegetation56 has contributed to reductions in the ability of public lands to support livestock grazing. Livestock 

grazing itself has caused some of these changes. The increased demand for multiple uses on public lands has 

further affected vegetative communities, impacting the land’s ability to support current levels of livestock use. 

Restoring ecosystem processes and rangeland health by reducing invasive plant spread helps create and/or 

maintain plant communities resistant to disturbance and capable of producing livestock forage. However, even 

with treatment, noxious weeds and other invasive plants would continue to spread. The BLM would continue to 

modify grazing to attain rangeland health standards. 

Proposed herbicide use on BLM lands would be a small portion of the existing pesticide use statewide (Table 

4-1). Further, one objective of the proposed action is to make the same herbicides available as are being used on 

adjacent non-Federal lands. In general, herbicide effects to water and other BLM resources will be cumulative to 

effects from non-BLM uses. 

Wild Horses and Burros 

Affected Environment 

The BLM manages wild horses and burros on public land through the Wild Free-Roaming Horse and Burro Act of 

1971. Wild horses and burros are managed on 18 Herd Management Areas (HMAs) covering 2.6 million acres of 

BLM lands and another 134,000 acres of National Forest, the majority of which is in Harney, Lake, and Malheur 

counties. The Act mandates that wild horses and burros can only be managed in areas where they were found in 

1971. Public lands inhabited by wild horses or burros are closed to grazing under permit or lease by domestic 

horses and burros, but are otherwise open to (and mostly covered by) permits and leases for other livestock 

grazing. Public lands are the primary source of forage for wild horses in eastern Oregon. Typically, the BLM 

does not feed or water the animals, but does intervene during extreme drought, fire, or freezing weather, and may 

relocate animals or remove them from the range during extreme conditions 

56 And their effect on fire regimes. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Each HMA has an Appropriate Management Level (AML), which is an estimate of the number of wild horses 

and burros that public lands can support while maintaining a thriving natural ecological balance. The combined 

AMLs for the 18 HMAs in Oregon is 1,340 to 2,655 animals. Wild horse herds grow at an average rate of 20 

percent annually. Animals that exceed the AML or that stray onto non-designated public and/or private lands are 

removed (USDI 2007a). As of 2008, wild horse and burro numbers were estimated to be 3,605 animals (about 30 

of which were burros), and the AML was being exceeded in 10 of the 18 HMAs. Excess animals damage range 

conditions, adversely affecting other commodity and non-commodity resource values and generally increasing the 

likelihood of invasive plant establishment. Herd sizes are managed primarily by periodically gathering surplus 

animals. Fertility control is also being used in some HMAs as a means to reduce the population growth rate. In 

FY 2008, 225 wild horses were adopted in Oregon. The main holding facility for wild horses in Oregon is located 

in Harney County just west of Burns, Oregon. The facility serves as a short term holding area prior to distribution 

to other states for adoption, and includes a public viewing area. Wild horses and burros in Oregon represent about 

5 percent of the total population on BLM lands in ten western states, with the highest numbers being in Nevada 

(46 percent) and Wyoming (13 percent). 

Environmental Consequences 

The proposed increase in the number of herbicides available and the types of vegetation management activities 

they could be used for could affect wild horses through direct and indirect exposure to herbicides that could harm 

their health, or through temporary decreases in amount of food available. However, any of the action alternatives 

would be expected to improve (or at least slow the decline of) the amount and quality of forage available, 

potentially increasing the carrying capacity of the HMAs and reducing other resource conflicts. 

Effects Commons to All Alternatives 

In addition to the following discussions, effects described in the Livestock section would generally apply to wild 

horses and burros. 

Herbicide Effects 

The extent of direct and indirect effects to wild horses or burros would vary by the amount of herbicide placed on 

vegetation that is used as forage (which is affected by the formulation and the extent and method of treatment), the 

toxicity or the herbicide, physical features of the terrain, weather conditions, and the time of year (e.g., newborn 

foals and burros would be susceptible during foaling season, with March through June being a critical period). 

Potential adverse direct effects to individual animals as a result of exposure to herbicides include death, damage 

to vital organs, change in body weight, decreases in healthy offspring, and increased susceptibility to predation. 

Wild horses and burros would have a greater chance of exposure to herbicides—either via direct contact with the 

herbicide upon application or indirect contact via dermal contact with vegetation or ingestion of vegetation—if 

their range extent was partially or completely sprayed. However, these animals are wide ranging, and HMAs are 

often larger than 30,000 to 40,000 acres for Oregon herd areas. Most treatments would be less than 200 acres, 

treat only the invasive plant portion of the vegetation, or be on recently burned areas (e.g. imazapic on newly 

burned areas to control invasive annual grasses). 

Wild horses or burros may also experience greater impacts under conditions where herbicide drift is more likely, 

such as in areas where herbicides are aerially sprayed adjacent to herd management areas, dry areas with high 

winds, or areas with extensive rainfall and porous soils. The BLM and Forest Service risk assessments suggested 

several possible common scenarios where herbicides could affect wild horses (ENSR 2005b-k, SERA 2005a). 

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Wild horses consume large quantities of grass and are thus at relatively greater risk for harm than smaller wildlife 

or wildlife that feed on other herbaceous vegetation, seeds, or fruits, which may have less herbicide residue than 

grass (Fletcher et al. 1994), at least where broad-scale applications of selective herbicides have been made on 

invasive plants over natural grasses, but 100 percent grass grazing scenarios were specifically modeled in the 

risk assessments. However, reaching ecological risk assessment-identified risk levels may be unlikely unless the 

animal forages exclusively within the treatment area for an entire day. 

Herbicide exposure to wild horses and burros would also be limited in the following two scenarios. Areas that are 

fenced are generally not accessible to wild horses and burros. Also, any aerial application would cause wild horses 

to disperse from the immediate area of application for unspecified periods of time unless a sole water source is in the 

general areas. Population management generally consists of aerial census and use of helicopters for gather/removal 

operations, so wild horses have a flight response when aircraft come in close proximity to the herds. 

The discussion of the individual herbicides in the Livestock section also applies to wild horses and burros. 

Forage, Invasive Plant, and Other Effects 

Adverse indirect effects could include reductions in preferred forage or forage amount. Forage reduction or 

disturbance (particularly aerial) may cause wild horses to move out of herd management areas and onto lands that 

are not legally designated for wild horse and burro management where there may be competition for forage with 

domestic livestock. 

Many HMAs are currently above AMLs. Noxious weed infestations can greatly reduce the land’s carrying 

capacity for wild horses, which tend to avoid weeds that have low palatability from defenses such as toxins, 

spines, and/or distasteful compounds (DiTomaso et al. 2006). In addition, some noxious weeds (e.g., horsetail, 

wild mustard, poison hemlock, tansy ragwort, yellow star thistle, and common St. Johnswort) are poisonous to 

horses. Grazing can be an effective means of managing certain invasive plants in HMAs. However, if vegetation 

is overgrazed (e.g. as a result of horses in excess of the AML), direct invasive plant control treatments such as 

those involving the use of herbicides may be required to return vegetation to a more desirable composition that 

can be maintained by grazing. Successful weed removal would directly benefit wild horses and burros over the 

long term. 

Treatments that reduce the risk of atypically frequent or high-intensity wildfire would also benefit wild horses. 

Rangeland weeds that increase the risk of high-intensity wildfire include cheatgrass, medusahead, diffuse 

knapweed, and perennial pepperweed. Uncontrolled, high intensity wildfires can remove forage from large tracts 

of rangeland, reducing its suitability for wild horse and burro grazing. In some instances, BLM has gathered all 

wild horses in those areas and placed them in temporary holding until resource restoration objectives were met, 

and then returned the horses to those areas. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

Wild horses and burros would not be affected by BLM herbicide use. However, this alternative would be 

expected to have the greatest continued spread of invasive plants that would replace native plant communities that 

wild horses and burros depend on as forage. Non-herbicide treatments would be effective on smaller areas for 

some species, but ineffective on other species that can only be controlled with herbicides alone or in combination 

with other methods. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Invasive Plant Effects 

Without the use of herbicides, invasive plant infestations are projected to continue to spread, probably at 

increasing rates. The increase of invasive plant populations would cause further damage to susceptible native 

plant communities, including rangeland communities that provide forage for wild horses, particularly in situations 

where other treatment methods would not be effective or feasible (e.g., large tracts of rangeland or grassland 

dominated by invasive, re-sprouting shrubs; or areas without enough fine fuels to carry prescribed fires). The 

spread of invasive plant populations would be expected to have harmful effects on wild horses; the capacity for 

wild horse grazing decreases proportionately with loss of forage caused by weed infestations. Noxious weeds that 

are toxic to wild horses, including common tansy, leafy spurge, Russian knapweed, common St. Johnswort, and 

yellow starthistle, would increase, further reducing forage and herd viability. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Herbicide Effects 

Impacts to wild horses or burros (positive and negative) would be similar in nature to those that have occurred 

in the past 18 years. Although herbicides would be applied to fewer acres under this alternative than under any 

of the action alternatives, the potential toxicity of the four herbicides available under this alternative keep this 

alternative from being considered the safest for wild horses and burros. 2,4-D and glyphosate present risks to 

mammals from direct spray and from consumption of contaminated grass at the typical and maximum application 

rates. Inadvertent spraying of grass and other forage near treated invasive weeds, as well as drift and other 

avenues, could result in exposure. Picloram also presents low to moderate risks under some exposure scenarios, 

and dicamba presents a low risk under some food contamination scenarios. Picloram’s primary targets are 

broadleaf and woody species, so it is used to target species infesting native or desirable grass species without 

affecting the grass. Grazing of these sprayed grasses by horses could result in exposure. Risks are reduced when 

herbicides take effect and the target vegetation become less palatable. 

Invasive Plant Effects 

Under the No Action Alternative, native plant communities would continue to be impacted by cheatgrass and 

medusahead spread, decreasing plant diversity, habitat quality, and productivity thereby reducing forage for wild 

horses and burros. Medusahead rye is a noxious weed infesting an estimated 600,000 acres of BLM lands in 

Oregon; it is considered poor forage as high silica content and other attributes render it unpalatable. The invasive 

cheatgrass infests another 5 million acres and except for a very few weeks early in the season, is similarly 

unpalatable. The frequency and intensity of wildland fire would increase as native plant communities become 

more infested with these two invasive annual grasses. Noxious weeds would continue to expand at their current 

rate, and are projected to infest about 1/3 of the BLM lands in Oregon in 15 years. Given the rate of new weed 

infestations and spread of historical weeds, some HMAs could be functionally lost to wild horses grazing use in 

the next ten years. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Herbicide Effects 

Under this alternative, total pounds of herbicides applied would decrease 30 to 50 percent for the typical and 

maximum rate respectively, when compared to Alternative 2. Also, use of the four herbicides available under 

Alternative 2 would decrease by 60 to 80 percent, and herbicides generally less toxic to wild horses and burros 

would be used. For example, approximately 1/3 of the projected herbicide use under this alternative would be 

with imazapic, an herbicide with no measured risk to wild horses under any of the exposure scenarios. Similarly, 

• Chlorsulfuron, fluridone, and sulfometuron methyl risk quotients were all below the most conservative 

LOC indicating that direct spray would not likely pose a risk; and, 

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•		 Imazapyr and metsulfuron methyl under typical application rates had no risk to wild horses predicted 

under any scenario, and imazapyr is not registered for rangeland application and therefore it would be 

unlikely that wild horses would either eat contaminated vegetation or come in direct contact with it. 

For the other two herbicides available under this alternative, hexazinone presents a low to moderate risk for some 

scenarios, but it is typically utilized for treatment of woody species and is semi-selective with spot application, 

so risk to wild horses and burros under normal applications may be lower than those predicted by the risk 

assessment. Triclopyr presents low risk through consumption of contaminated vegetation at the typical rate and 

moderate risk at the maximum rate. It is utilized in rangelands due to selectivity for woody species, and has low 

residual activity. 

The increased number of herbicides available under this alternative would lower risk to wild horses and burros because 

more choices would be available to meet site-specific concerns including the presence of wild horses and burros. 

Invasive Plant Effects 

Noxious weeds are projected to infest 1.9 million fewer acres on BLM lands statewide under this alternative than 

under the No Action Alternative, proportionately benefitting the 2.6 million acres of BLM HMAs. The option 

to use more selective and effective herbicides for noxious weed control would assist in the eradication of new 

infestations on BLM lands. Alternative 3 would provide herbicides (particularly imazapic, with no rated risk 

to wild horses) to control of invasive annual grasses such as cheatgrass and medusahead, which have displaced 

native grassland communities and changed wild horse and burro grazing patterns, seasons of use and overall herd 

behavior. This would indirectly help control other invasive plants that are either the result of large grass-related 

fires, or that are otherwise fire dependent and out-compete native vegetation in establishing dominance in firedisturbed sites. Although this would not necessarily restore native grasslands and result in increases in available 

forage for wild horses, it would reduce the spread of invasive plants. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Effects described for Alternative 3 would also apply to Alternative 4. Additional effects are described below. 

Herbicides Effects 

This alternative adds three herbicides for vegetation control in rights-of-way and other developments. Bromacil, 

diuron, and tebuthiuron are relatively long-lasting non-selective pre-emergent herbicides that would be used for 

complete vegetation control in and near developments where vegetation is already being kept at a minimum to 

protect the investment and function of the developments. They are not registered for use on rangeland. Treatment 

of recreation and administrative sites under this alternative would have little or no impact on wild horses and 

burros since access is often limited and human activity would be avoided. However, drift and treatments 

of unfenced rights-of-way and other developments could result in exposure. None of these three additional 

herbicides represent a risk to wild horses from direct spray or dermal contact with treated vegetation. Ingestion of 

treated foliage does present risk however; tebuthiuron presents a low risk from mammal ingestion scenarios when 

applied at the maximum rate, and bromacil presents low to moderate risk and diuron presents low to high risks 

under several of the ingested vegetation scenarios. 

There would also be an increase in acres treated with most of the other Alternative 3 herbicides (when compared 

to Alternative 3) both along rights-of-way where selective vegetation control would better meet maintenance 

objectives (see Administrative Sites, Roads, and Rights-of-Way in this Chapter). Use of the four Alternative 2 

herbicides would remain lower than under Alternative 2. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Habitat improvement treatments to meet goals specified in Conservation Strategies could pose a risk to wild 

horses; such risks will be considered at the site-specific scale. Some of these treatments would be done aerially, 

which would cause horses to leave the area. The availability of 12 to 16 herbicides would provide options for 

reducing risk, since about half of the herbicides available have little or no identified risk to horses. Tebuthiuron in 

particular is expected to be used in low doses to effect structural changes in sage brush, but such doses present no 

identified risk to horses. 

Invasive Plant Effects 

The small areas subject to total vegetation removal, such as around administrative sites and communications 

facilities, should have no effect on the availability of forage. These areas are already low in forage production, 

and horses and burros do not typically forage close to developments. Range conditions would benefit from 

additional control of noxious weeds. Inadvertent control of noxious weeds during herbicide rights-of-way 

treatments are projected to reduce the acres infested with noxious weeds in 15 years another 300,000 acres when 

compared to Alternative 3 (see the Noxious Weeds and Other Invasive Plants section). 

The ability to use herbicides for certain habitat improvement projects would reduce the adverse effects of current 

non-herbicide methods including the risk of escaped wildlife improvement prescribed fires. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Effects described for Alternative 4 would also apply to Alternative 5. Additional effects are described below. 

Herbicide Effects 

It is estimated that approximately 5,000 additional acres would be treated with herbicides under this alternative 

when compared to Alternative 4, with 2,4-D and imazapic estimated to each account for 40 percent of the 

increase. Treatments would be primarily for habitat improvement, although a variety of non-commodity resource 

management objectives may be accomplished, and a portion of these projects would be in HMAs. Potential wild 

horse exposure would be greatest under this alternative. Imazapic presents no identified risk to wild horses and 

burros, but 2,4-D presents risks to mammals from direct spray and from consumption of contaminated grass at the 

typical and maximum application rates. 

The two additional herbicides are available under this alternative, and are projected to each be used on 200 acres 

annually. Diflufenzopyr + dicamba risk quotients are all below the most conservative LOC indicating direct 

spray would not pose a risk to wild horses. Consumption of vegetation contaminated by diquat direct spray at the 

typical rate poses low chronic risk and moderate acute and chronic risk at the maximum application rate, therefore 

wild horses and burros could be at risk from short and long-term consumption of contaminated forage. However, 

because this is an aquatic herbicide that is not proposed for use in terrestrial areas, the likelihood of wild horse and 

burro exposure is minimal. There is a concern for horses feeding in wetland-riparian areas where the herbicide 

would be utilized; this risk could be reduced by herding animals out of treatment areas. 

Invasive Plant Effects 

Benefits to wild horses from the control of noxious weeds and other invasive plants would be similar to those 

described for Alternative 4. Although this program component would not necessarily restore native grasslands 

and result in increases in available forage for wild horses and burros, it is likely that it would reduce the spread of 

invasive plants, particularly onto non-Federal grazing lands. Wild horses and burros would be expected to benefit 

from a portion of habitat improvement projects expected to be conducted under this alternative. 

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Cumulative Effects 

Loss of native vegetation and declining ecosystem health on public lands due to noxious weeds and other invasive 

vegetation57 has contributed to reductions in the ability of public lands to support wild horses and burros. The 

wild horses and burros themselves have caused some of these changes. The increased demand for multiple uses 

on public lands has further affected vegetative communities, affecting the land’s ability to sustain current levels 

of wild horse use. Restoring ecosystem processes and balancing wild horse use and rangeland health reduces 

invasive plant spread and helps create and/or maintain plant communities resistant to disturbance. However, 

even with treatment, noxious weeds and other invasive plants would continue to spread. BLM would continue to 

manage wild horses within AMLs to attain rangeland health standards. 

Proposed herbicide use on BLM lands would be a small portion of the existing pesticide use statewide (Table 

4-1). Further, one objective of the proposed action is to make the same herbicides available as are being used on 

adjacent non-Federal lands. In general, herbicide effects to water and other BLM resources will be cumulative to 

effects from non-BLM uses. 

Fire and Fuels 

Affected Environment 

With the exception of cheatgrass, medusahead, and other invasive annual grasses (primarily in the Sagebrush 

Steppe Biome), the effects of invasive plants on fire frequency and intensity are mixed and generally subdued. 

The potential effects of invasive plants on fire regimes and fire behavior is largely dependent on the structure 

and characteristics (flammability) of the plants themselves, and their indirect effect of altering the abundance 

and arrangement of native plant fuels. Invasive plants may reduce fuels in ways that suppress the spread of fire 

in ecosystems where fire is desirable; or may increase hazardous fuels in ways that increase fire intensity or 

frequency in ecosystems where it is not (Brooks et al. 2004). 

In western Oregon’s grasslands and oak woodlands, natural58 fire frequency, fire line intensities, and fire spread 

are reduced when non-native forbs (such as spotted knapweed and yellow starthistle) become the dominate 

species. Similarly, these fire characteristics decrease the when non-native perennials Scotch broom and 

Himalayan blackberry are present in forest openings, riparian areas, recreational sites, and along roadsides. 

Plant characteristics such as coarser stems, higher fuel moisture content, reduced fuel continuity, and decreased 

ignitability reduce fire behavior and allow for quicker initial containment of fires by suppression resources. 

Perennial grasses such as reed canarygrass found in western Oregon wetland prairies tend to increase fuel loading, 

increasing fire intensities and spread. These changes are localized. 

Invasive plants in the Western Forest Biome are generally neither flammable nor continuous enough to constitute 

a major fuel hazard or to have significantly altered the fire regime. Exceptions exist: gorse is credited with having 

contributed to a fatal wildfire burning downtown Bandon in 1936 (Simberloff 1996) for example, and reducing 

fire risk may occasionally be a weed treatment objective in this biome, but these exceptions are not particularly 

significant to the differences between the alternatives in this EIS. 

57 And their effect on fire regimes.
	

58 “Natural” in this context includes pre-European anthropogenic fires.
	

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

In the Siskiyou, Willamette Valley, and Eastern Forest Biomes, a historic fire return internal of less than 10 years 

was common on many sites and helped maintain oak savannahs and open pine stands. Invasion by non-native 

annual grasses has not substantially changed these fires except perhaps to increase their intensity in the most open 

areas at the lowest elevations (Medford area for example). While the diversity of these ecosystems is certainly 

threatened by the dominance of the invasive plants and by increased wildfire intensity as well, there is not a 

substantial increase in the fire danger or change in the long-term fire regime attributable to the invasive plants 

themselves in these vegetation types. Control of invasive plants in these plant communities to reduce wildfire risk 

is not a need identified in this EIS. 

In the Sagebrush Steppe Biome invasive annual grasses have not just increased fuel loading, they have become 

sufficiently established to create a self-sustaining cheatgrass-wildfire regime. Plant invasions that alter fire 

regimes typically do so by altering more than one fuel or fire regime property (Brooks et al. 2004). When 

an invasive plant with a different fire regime is established enough to dominate the landscape, its intrinsic 

characteristics and effects on native plants combine to alter fuel properties sufficiently to shift the historic fire 

regime outside of the reference range of variation. If the new fire regime favors the dominance of the invasive 

plants causing new fuel conditions and negatively affecting native species, an invasive plant/fire regime cycle 

becomes established (Zouhar et al. 2008). 

Native sagebrush plant communities in the Sagebrush Steppe Biome were historically made up of sagebrush, 

separated by relatively native forbs and bunchgrasses that retained moisture long into the dry summer season 

and existed in discontinuous bunches, often separated by areas of soil crust (see Soil Resources section in this 

Chapter). Natural fire return intervals in this type were 32 to 70 years (Quigley and Arbelbide 1997:797). In the 

past 130 years, large areas of these sagebrush communities have experienced a total vegetation conversion to 

fire-prone invasive annual grasses, which has converted vast landscapes of native sagebrush steppe to non-native 

annual grasslands (Menakis et al. 2003). The noxious weed medusahead and invasive cheatgrass infest over 5 

million acres on BLM lands in eastern Oregon. Effects in the Eastern Forest Biome are not as severe. However, 

in the Sagebrush Steppe Biome, these grasses can increase horizontal fuel continuity and create a fuel bed more 

conducive to ignition and spread, and have been shown to increase fire frequency and size as well as expand the 

seasonal window of burning (Zouhar et al. 2008). The invasion of non-native annual grasses, such as cheatgrass 

and medusahead rye has increased fuel continuity across large areas of contiguous landscape, supporting more 

frequent and hotter fast-moving fires that are initially difficult to contain and result in large landscape fires. 

Environmental Consequences 

The BLM treats hazardous fuels using a variety of non-herbicide methods on tens of thousands of acres per year 

in Oregon. A full discussion of that program is outside the scope of this analysis; the portion of such treatments 

potentially done with herbicides is small, on the order of 1 to 5 percent. Currently allowed herbicide treatment of 

noxious weeds (Alternative 2) could have a fuels treatment objective, but the four herbicides currently available 

are not capable of controlling the most pressing case of the invasive annual grasses in the Sagebrush Steppe 

Biome and elsewhere. Alternatives 3-5 would add imazapic and other herbicides capable of treating this fuels 

problem. Herbicide treatments of native vegetation to meet fuels reduction objectives would be permitted under 

Alternative 5, but is unlikely to occur. 

Herbicides would be used as part of an integrated vegetation management approach. Treatment goals would 

include reducing fire behavior characteristics to protect resource values and to increase firefighter and public 

safety, and restoring fire adapted ecosystems or fire regimes through the modification of vegetation (fuels) 

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structure and composition. Herbicides would be used to help achieve these goals in a number of different ways: 

•		 As a standalone treatment or in combination of 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 follow up, or maintenance, treatments to mechanical or prescribed fire treatments. 

•		 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. 

Fuel Treatment Program - Prescribed fires and other fuels treatments create disturbances that can be exploited 

by noxious weeds and other invasive plants. Similarly, wildfire suppression techniques can introduce or spread 

invasive plants. The potential for various BLM activities to spread noxious weeds is outside the scope of this 

analysis; these are ongoing programs already covered by Integrated Vegetation Management policies designed 

to prevent and control 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 (USDI 1992b, Appendix 3 of this EIS). The degree to which these and other 

ongoing management practices might contribute to the spread of invasive plants is considered in the spread rate 

analysis in the Noxious Weeds and Other Invasive Plants section earlier in this Chapter. 

Effects Common to All Alternatives 

In western Oregon under all alternatives, localized weed treatments would occasionally have a fuels reduction 

co-objective. More likely, weed treatments would occur as a secondary maintenance treatment or as a preventive 

measure in areas previously treated for hazardous fuels within the WUI, or to reduce invasions of particularly 

flammable species along roadsides or within recreational sites and areas of special concern like the CascadeSiskiyou National Monument. 

In eastern Oregon, there would be a focus on fuels reduction and restoration of large grass-invaded areas to reduce 

severe fire behavior by restoring natural fire adapted ecosystems. Treatments that would help with the reduction 

of fire would include fuel breaks within the WUI or through the center of large infested areas to help support 

suppression efforts. 

The effects of herbicides either as a standalone treatment or with prescribed fire, manual or mechanical treatments 

to reduce fire behavior characteristics are generally localized to the areas treated. Under each of the alternatives, 

proposed weed treatment acres are only a small portion of the identified infested areas, and would have little to 

no effect on the estimated acre annual spread rate. Typical treatments are likely to be focused on new or small 

populations of existing species, advancing edges of larger populations, or the use of a brown stripping technique 

within or adjacent to WUI or large infested areas. 

The most significant parameters for comparing the alternatives is the net change in plant communities dominated 

by invasive annual grasses, and the ability to remove and restore those plant communities to protect high interest 

areas such as the WUI. As discussed in the Noxious Weeds and Other Invasive Plants section earlier in this 

Chapter, the alternatives would variously slow the spread of noxious weeds statewide. Cheatgrass, however, 

is not part of the weed spread rate calculations because it is widespread and not listed as noxious. Also, the 

difficulty in effectively eradicating the noxious weed medusahead is given, in that section, as a reason for 

pessimism in the calculations. Therefore, the 4 million acre difference in predicted noxious weed infested 

acres between Alternatives 1 and 5 in 15 years (Table 4-4) could overstate the relative differences between the 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

alternatives for fire risk; the invasive annual grass spread rate may not be significantly affected by the various 

alternatives. The primary difference between the alternatives would be the ability to reduce fuels and/or restore 

more fire-resistant ecosystems on specific sites of interest. 

Effects by Alternative 

Alternative 1 – No Herbicide Use and Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Under Alternative 1 and 2, manual treatments would be the most effective treatment in removing annual grasses. 

The reduction of non-native annual grasses through mechanical and prescribed burning would be limited, 

however, and dependent on the current condition of the fire regime prior to treatment, the intensity, severity, 

size, and seasonality of a fuel treatment, and site factors such as, topography, soil characteristics, and weather 

conditions (Zouhar et al. 2008). Mechanical methods could create non-vegetated or brown stripping (removal of 

vegetation) in the WUI when opportunities to use prescribed fire are limited. These areas would likely require 

annual maintenance or retreatment to remain effective in reducing the fire risk to communities. This cost is likely 

to keep treatments small in scale, providing protection to limited areas of the WUI. 

Prescribed burning can be used to suppress invasive annual grasses in the short term. However, sagebrush steppe 

is very susceptible to reestablishment and increases in abundance of annual non-native grasses after prescribed 

burning unless the site initially had a sufficient component of native perennials (Zouhar et al. 2008). If a wildfire 

initially promoted non-native and invasive plants, then using prescribed fire alone to reduce the invasion is 

not likely to be effective. Fire is sometimes more effective when used in combination with other treatments 

(Zouhar et al. 2008). For example, burning cheatgrass and medusahead is most useful as a seedbed preparation 

technique if followed by immediate seeding of desirable species. These areas need to be planted within a year 

of the burning or they can become reinvaded (Zouhar et al. 2008). Under Alternative 2, annual retreatment with 

herbicides could be utilized to maintain mechanical non-vegetated or brown stripping breaks, reducing the cost of 

maintaining these areas, and increasing their effectiveness at reducing fires. 

The reduction of fire behavior characteristics (rate of spread, fire line intensities) under Alternative 1 and 2 would 

be relatively labor-intensive, and benefits would be localized to the area treated. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Herbicides that would become available under this alternative include pre-emergents (e.g. imazapic) that would 

control invasive annual grasses including cheatgrass and medusahead, making a combination prescribed fireherbicide-seeding treatment effective at removing these grasses and restoring native plants. This treatment could 

be used to meet a variety or restoration objectives but significant to this discussion, the treatment would reduce 

the risk of fast-moving intense grass-fueled fires when applied to meet fuel reduction objectives within the WUI. 

Herbicides would also increase the effectiveness of greenstripping – a proactive technique to reduce the 

magnitude of the cheatgrass-wildfire cycle by growing fire-resistant vegetation at strategic locations in order 

to slow or stop the spread of wildfires (Quigley and Arbelbide 1997:801), and would increase the likelihood of 

successfully working with adjacent landowners on fuel breaks and related treatments. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

The effects described for Alternative 3 would also apply to Alternative 4. Alternative 4 would also permit the use 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

of herbicides for the control of native plants around administrative sites. Objectives for vegetation treatments 

around administrative sites such as communications sites and other remote structures include keeping wildfire 

from entering the developed area of the site and destroying structures and other improvements. The use of 

persistent pre-emergent non-selective herbicides such as diuron for these treatments would likely be more 

effective than regular non-herbicide treatments, because better long-term control would be achieved. 

Other herbicide treatments permitted under Alternative 4 including treatments along rights-of-ways would 

probably be neutral regarding their effect on wildfire. For example, it is not clear that sprayed vegetation would 

be any more or less flammable than mown vegetation. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

In addition to all treatments permitted under Alternative 4, Alternative 5 would make herbicides available for any 

non-commodity vegetation treatment. In unusual circumstances, this might include treatments of native plants to 

reduce fuel loading. 

Timber 

Affected Environment 

This section addresses the reasonably foreseeable effects of the alternatives on timber volume production from 

BLM lands in Oregon. The effects of the alternatives on the broad ecological function of forests are included in 

the Vegetation, Native Plants, and Plant Communities section elsewhere in this Chapter. 

All alternatives exclude herbicide use specifically for commodity production. That means that herbicide use 

proposals will not, either as an objective or as an evaluation criterion, have a site-specific timber volume 

production purpose. The noxious weeds and other invasive plants and pest control portion of the alternatives 

focus on stopping new weeds from getting a foothold, preventing existing weeds from spreading to new areas, and 

protecting or restoring susceptible areas such as Bureau Sensitive species’ habitats. Such treatments could occur 

in recently harvested timber sale units in part because any area is susceptible to invasion, and in part, because 

site disturbances and increased sunlight to the ground increases the likelihood of infestation. However, such 

treatments would be distinguishable from timber volume-related treatments because they would not be focused, 

say, on past or potential timber sale units while permitting weed populations nearby to flourish or spread. 

Weed control efforts have the potential to affect future timber growth, much the same way control efforts 

will affect water quality, visual resources, and so forth. Economic effects, including those resulting from lost 

productivity on forestlands within the State are one criterion the State uses when considering whether to designate 

non-native plants as noxious weeds. The alternatives propose to control Sudden Oak Death, for example, 

even though the objective of that control is both environmental and economic (with respect to the potential for 

protection of timber volume, nursery sales, and other commodity production). And to the degree BLM noxious 

weed treatments contribute to the control and elimination of weeds the State and neighboring landowners have 

identified as needing control, the Purpose (Chapter 1) of cooperatively controlling invasive plants so they do not 

infest or reinfest adjacent non-BLM lands, will be furthered. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Existing Timber Volume Production 

East Side Dry Forests and Other Woodlands 

On most BLM forests east of Highway 97 in central Oregon, forest management activities are conducted to 

promote forest stand health and resiliency to fire, insects, and disease. Treatments include thinning to reduce 

densely canopied young forests, fuels reductions of densely stocked stands resulting from many years of fire 

suppression, fire salvage to reduce fuels and capture surplus mortality after wildfires, and/or uneven age stand 

management to restore pre-settlement stand conditions. While an average of four million board feet (MMBF) per 

year has recently been harvested in the Eastern Forest Biome (two from the portion of the Klamath Falls Resource 

Area east of Highway 97 and two from all other), timber volume production per se is not an objective of these 

treatments. 

Similarly, some of the RMPs include management prescriptions and allowable commercial forest product sales 

from woodlands, specifically Western juniper. 

While the presence of invasive plants certainly affects the health and function of these dry forests and may change 

the need for stand treatments using timber sales, those effects are more appropriately addressed in the Vegetation, 

Native Plants, and Plant Communities section in this Chapter. 

Western Oregon Including O&C Lands 

Under the six Resource Management Plans (RMPs) adopted in 1995 for BLM districts west of the Cascades, and 

that portion of the Klamath Falls Resource Area west of Highway 97, 607,600 acres59 (about 28 percent of the 

area’s 2.2 million acres of forested lands) are managed for regularly scheduled timber harvest totaling slightly 

over 200 MMBF per year. The remaining forested areas is managed primarily as Late-Successional Reserves, 

Riparian Reserves that produce some timber when thinning and other treatments are needed to achieve those 

area’s specific management objectives. 

Invasive Plants on Timberlands 

A recent compilation of invasive plant information from permanent inventory plots spread across all forestlands in 

Oregon found invasive plants60 made up 6 percent of the crown cover in Oregon forests, and more than 17 percent 

in seedling/sapling stands less than 5 inches dbh. The percentage of inventory plots with one or more invasive 

plants present ranged from 100 percent in the Blue Mountains to 47 percent in the Coast Range (Donnegan et al. 

2008:63-64). Cheatgrass was the most common invasive plant in Oregon forestlands (all ownerships) at 196,000 

acres, and Himalayan blackberry was second at 149,000 acres (all ownerships). Himalayan blackberry is the most 

common invasive plant in western Oregon. A 2008 compilation by the BLM reported 130 invasive plants and 61 

noxious weeds on BLM lands west of the Cascades and the Klamath Falls Resource Area, with the highest density 

on the Medford District. 

59 These are the lands suitable for regularly scheduled timber harvest in the Matrix and Adaptive Management Area land 

use allocations. Various standards and guidelines applicable to these lands reduce actual acres treated. 

60 The “invasive plant” definition used in the Donnegan report is different than used elsewhere in this EIS. Donnegan et 

al. (2008) considered all species not native to the U.S. and readily recognizable to a trained inventory crew. Thus, it 

includes some species not considered invasive in this EIS, like foxglove, but misses less common noxious weeds. The 

overall numbers are probably reasonably comparable with other numbers in this EIS. 

245 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The BLM manages 12.3 percent of Oregon’s forestlands (Donnegan et al. 2008:19). Because BLM forests are 

typically low elevation, and are arranged in a checkerboard pattern with other forestlands and share a common 

road system, the invasive plant percentages included in or inferred from Donnegan et al. (2008) would be 

expected to apply or even under-report conditions on BLM lands.61 

Environmental Consequences 

This section addresses the effect of the alternatives on timber production, even though the alternatives do not 

include the use of herbicides specifically for commodity production including timber volume. 

Effects Common to All Alternatives 

Effects of Herbicide and Non-herbicide Treatment Methods 

The effects of invasive plant treatments themselves, whether accomplished with herbicide or non-herbicide 

methods, are expected to be negligible. Treatments for noxious weeds and other invasive plants are generally 

focused on specific plants, and collateral damage to crop trees is rare. Aerial application, for example, would not 

occur west of the Cascades under Alternatives 3 or 4, and would occur only rarely if at all under Alternatives 2 

or 5. Equipment used to pull larger plants such as Scotch broom can damage or uproot individual conifers, but 

individual tree mortality in timber production plantations is common and usually does not noticeably reduce longterm production unless the site is only marginally stocked. The same damage could occur during spot herbicide 

treatments, and treatments would be designed to avoid damage to non-target plants including conifers. The 

likelihood of damage from herbicide and non-herbicide weed control treatments would decrease as trees get older. 

If there are effects to timber production, they would likely be positive “release” type effects as invasive plants 

competing with desirable conifers are removed. 

Effects of Invasive Plants 

Adverse effects from invasive plants effects on the reforestation and early growth phase of forest plantations. 

Invasive grasses like false brome use early season soil moisture and reduce first year seedling survival. Most 

invasive plants are early seral species, although large species like Himalayan blackberry and Scotch broom will 

remain in the stand for decades, impacting growth and complicating cultural work such as young-stand thinning. 

Pole-size and larger stands typically shade out early seral invasive plants, and those that are left would likely 

use only a small percentage of site resources. Few if any invasive plants have been reported altering forest soils 

sufficiently to retard reforestation and growth, at least west of the Cascades. Long-lived seeds such as those 

from Scotch broom would typically lay dormant under such conditions, and not germinate unless an opening was 

created or the stand was regenerated again. Scotch broom has been identified as the noxious weed causing the 

highest productivity losses of any of Oregon’s noxious weeds, at $47 million annually (Radke and Davis 2000:19­

20). 

Invasive plants reduce timber growth as well, but the effect is not as pronounced as it is on adjacent private 

61 Donnegan et al. (2008) numbers would be expected to under-report low elevation checkerboard forests and over-report 

higher elevation more consolidated National Forests because most common invasive weeds favor temperate climates 

and harvest-related disturbances. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

commercial forestlands where rapid growth is the primary objective. In western Oregon, native plants 

quickly reestablish in timber harvest sites and contribute to stand diversity, helping stands to meet a variety of 

management objectives in exchange for some timber volume growth. Invasive plants such as Scotch broom are 

even more efficient than native plants at populating recently harvested sites and being competitive with desired 

conifers. Certainly this results in decreased growth, but the effects are gradual; current culturing methods are 

already dealing with some level of invasive plants. Yield predictions are based in part on the performance of 

existing stands, and quantifying the growth loss from the current or future percentage of invasive plants has not 

been done.. 

In addition to some level of growth loss, any area with noxious weeds is more expensive to manage if for no other 

reason than because mitigation measures must be taken to prevent off-site movement. For example, a requirement 

can be added to the sale contract that equipment be cleaned before it is moved from one area to another. In 

general, risks from harvest activities 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 (USDI 1992b). 

There are other potential effects that are detrimental to timber production. Some invasive plants such as 

Portuguese broom invade and grow faster and more competitively than most native species, and additional 

“release” treatments may be needed to keep the plantations healthy, thereby increasing costs. Some have 

particularly long-lived seeds that are quick to invade disturbed sites (although the seeds of some native brush 

species like manzanita are similarly long-lived). Some have allelopathic influences that poison the soil or 

otherwise slow regeneration and tree seedling growth. Some, such as gorse, create a spiny thicket that foresters 

cannot work in, and that equipment might inadvertently move to other areas. Also, some regeneration treatments 

(and natural small gap dynamics taking place in areas managed for old-growth and natural processes) rely on 

natural seeding by conifers, and aggressive invasive plants could lower success in these cases, or create a need 

to do more expensive and potentially more ground-disturbing site preparation. Invasive plants can also limit the 

growth of native species important to soil nutrients in the long term, such as the nitrogen fixing characteristics of 

alder, lupines, and ceanothus. 

As described in the Noxious Weeds and Other Invasive Plants section earlier in this Chapter, the action 

alternatives are predicted to slow the spread of noxious weed from a current 12, to 7 and 6 percent annually for 

Alternatives 3 and 4/5 respectively. These reductions would correspondingly reduce the potential for the adverse 

effects listed above. 

Effects by Alternative 

Alternative 1 – No Herbicide Use and Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Continuation of the current (Alternative 2) or even accelerated (Alternative 1) weed spread rate is predicted to 

result in one-third or more of BLM lands in Oregon infested with noxious weeds in 15 years. While infestation 

rates in the forested lands in western Oregon may lag behind this statewide projection to a degree (Denton 2009), 

problematic weeds such as Scotch Broom, Himalayan blackberry, gorse, yellow starthistle, and others could 

become ubiquitous in the not-too-distant future at this level of control. Decreased growth, increased costs, and 

long-term site productivity losses are likely. 

With management responsibility for about ten percent of the current State-designated Sudden Oak Death 

quarantine area in southwestern Oregon, Alternatives 1 and 2 would keep the BLM as the only landowner not 

247 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

using herbicides to control the native host plants. Pathologists predict that the likelihood of eventual control in 

that area is being compromised by this limitation. If Sudden Oak Death escapes that current quarantine area and 

becomes widespread, the growth of certain hardwoods and even Douglas-fir will be negatively affected. See 

Pests and Diseases in this Chapter for more information. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

The additional herbicides available under this alternative would reduce the likelihood of collateral damage to nontarget plants including those being grown for timber. The addition of pests and diseases as an allowable control 

objective would allow the BLM to more aggressively treat its portion of the Sudden Oak Death State quarantine 

area (or any future area designated by the State as a quarantine area), significantly increasing the likelihood of 

eventual containment and control of Sudden Oak Death in Oregon. 

The reduction in the spread rate for noxious weeds predicted for this alternative from 12 to 7 percent could 

significantly delay or prevent the adverse effects of noxious weeds on many timber sites. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses and Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity 

Vegetation Management Objectives 

Because of its checkerboard ownership, the BLM shares a road system with other landowners. This road system 

is particularly susceptible to infestation by invasive plants. The current system of spot-spraying noxious weeds 

and then returning to mow encroaching native vegetation is not only inefficient, it risks missing noxious weeds 

that can then be spread by the mowing equipment or spread onto the road where it can be spread by other traffic. 

It is perhaps here as much as anywhere that the additional 25 percent gain in noxious weed control from using 

herbicides to control native roadside vegetation would apply, decreasing overall weed spread to six percent and 

proportionately benefitting the timber resource for BLM (and adjacent non-Federal timberlands). 

Cultural and Paleontological Resources 

Affected Environment 

In the 1960’s, passage of the National Historic Preservation Act (1966) and NEPA (1969) lead to increased 

awareness of the cultural and scientific value of cultural resources and slowed inadvertent loss of those resources 

on public lands. With requirements to inventory and evaluate cultural properties for eligibility to the National 

Register of Historic Places, previously undocumented cultural resources were identified often in response to 

proposed developments or other Federal undertakings. The Archaeological Resources Protection Act of 1979 

provided additional protections for cultural resources on public and tribal lands. In 1990, passage of the Native 

American Graves Protection and Repatriation Act provided protection of American Indian human remains, sacred 

objects and associated funerary objects on Federal and tribal lands. The Paleontological Resources Protection Act 

(PRPA) was signed into law as part of the Omnibus Public Lands Management Act of 2009. Federal agencies are 

required to protect and manage paleontological resources using scientific principles and expertise. In addition, 

the Federal Land Management and Policy Act (FLPMA) of 1976 authorizes the Federal agency to protect public 

resources including those with scientific values. These resources include fossilized paleontological specimens 

on Federal lands. In addition, FLPMA directs the BLM to protect the quality of historical resources and 

archaeological values. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Paleontological Resources 

As a natural heritage resource, fossil localities must be considered in developing land use management decisions. 

The fossil record in the western U.S. includes almost all of the geologic periods from the Cambrian (500+ million 

years ago) to the Holocene (about 10,000-12,000 years ago to present). Many of the fossil deposits contain 

specimens of national and international importance and were first made known to the scientific world from 

deposits found in the western U.S.. 

The BLM manages fossils under the general guidance of the PRPA, FLPMA, and NEPA to promote their use in 

research, education, and recreation. The BLM manages 15.7 million acres of public land in Oregon. Nearly 300 

paleontological localities have been identified on BLM administered land in the State. The fossil record extending 

as early as 100 to 200 million years ago includes some of the richest Paleogene /Neogene (65 million to 1.8 

million years ago) plant and animal fossil localities in the world (USDI 1999:45). Exposures of nearly continuous 

datable geologic sequences offer unique opportunities for scientists to study and understand changing ecology, 

geologic structure, and mammalian evolution. 

Cultural Resources 

Cultural resources include archaeological, historic, or architectural sites, structures, or places with historically 

significant values and uses, and may include locations (sites or places) of traditional cultural or religious 

importance to specific social or cultural groups. Cultural resources are managed according to their relative 

importance, to protect historically and culturally significant resources from inadvertent loss, destruction, or 

impairment, and to encourage and accommodate the appropriate uses of these resources through planning and 

public participation. 

The cultural heritage for public lands administered by the BLM in Oregon extends back 11,000 to 13,000 years 

before the present. The increased number and variety of known cultural properties through time is attributed 

in part to preservation and discovery of cultural materials and to population growth including European and 

Euroamerican exploration and immigration into the Northwest by the early nineteenth century. Cultural sites 

include geological landmarks with American Indian cultural and historical significance, American Indian activity 

sites such as campsites, fish traps, shelters, trails, and pictographs, and Euro-American settlement sites including 

trestles, shipwrecks, buildings, wagon roads, river fords, and mines. Approximately 1.5 million acres of BLM 

administered lands in Oregon have been inventoried for cultural resources and more than 12,000 sites have been 

recorded. 

Traditional and Cultural Uses (American Indian Interests) 

Some Pacific Northwest Indian tribes have reservation lands held in trust status by the Secretary of the Interior. 

However, of the tribes with interests within the State of Oregon some also have treaty reserved, or Executive 

Order rights upon unoccupied Federal lands outside the bounds of their respective Indian reservations. These 

rights include fishing, hunting, gathering, trapping, and the right to graze domestic livestock. There are also tribes 

without specific off-reservation reserved rights who continue to gather natural resources for traditional or cultural 

purposes (Table 4-21). 

The areas of interest to American Indian tribes with off-reservation rights are the lands ceded to the U.S., often 

referred to as “ceded lands.” Historically, some of these lands were occupied by a single specific tribe or band, 

while others were used by several tribes or band. These ceded lands include most of the Federal lands managed 

by the BLM within the State of Oregon. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

 250 

Protecting and maintaining plants, animals, fish, and water quality on these lands is an important responsibility of 

the Federal Government. As a land management agency, the BLM has a responsibility to ensure that meaningful 

government-to-government consultation is conducted with Federally recognized tribes to discuss and consider the 

effect that any proposed action may have on treaty rights and resources. 

Invasive plants interfere with reserved treaty rights of American Indian tribes of the Pacific Northwest. Invasive 

plants crowd out plants traditionally gathered for food, dress, or ceremonial purposes and can influence wildlife 

and fish behavior. 

Environmental Consequences 

Paleontological and cultural resources are nonrenewable, and any damage or displacement from their 

natural context is often irreparable and cumulative. Although fossil resources and many cultural 

resources are often protected from impacts by overlying sediments and deposits, once eroded or otherwise 

physically exposed, the potential for adverse effects greatly increases. All treatment alternatives include 

treatment methods that could impact cultural resources through ground disturbance, increased erosion, 

or thermal alteration. Adverse effects can also result from the herbicide mixes themselves, and from 

invasive plants. Similarly, tribal traditional and cultural use areas can be adversely affected by activities 

conducted under each of the activities, and from increases in invasive plants. Effects would be most 

likely to occur if the these resources were not recognized and marked for avoidance by required predisturbance surveys during the identification or implementation phases or if the project could not be 

re-designed to avoid these resources. In those instances, incidental or inadvertent discovery or impacts 

to sites could occur but measures to document or recover the data from those sites would mitigate those 

effects to some extent. 

In any case, most vegetation treatment options involving ground-disturbing activities would likely 

disturb only the upper few inches of sediments and in many cases would be confined to roads, trails, or 

access routes. Treatment methods causing erosion or soil disturbance could cause indirect impacts to 

Table 4-21. american indian Tribes WiTH inTeresTs in oregon 

Tribe Off-Reservation Rights 

Klamath Tribes √ 

Confederated Tribes of the Umatilla Indian Reservation √ 

Confederated Tribes of the Warm Springs Reservation of Oregon √ 

Nez Perce Tribe √ 

Confederated Tribes and Bands of the Yakama Nation √ 

Confederated Tribes of the Colville Reservation √ 

Shoshone-Bannock Tribes of the Fort Hall Reservation √ 

Shoshone-Paiute Tribes of the Duck Valley Reservation √ 

Fort McDermitt Paiute and Shoshone Tribes √ 

Burns Paiute 

Confederated Tribes of the Coos, Lower Umpqua and Siuslaw Indians of Oregon 

Coquille Indian Tribes 

Cow Creek Band of Umpqua Tribe of Indians 

Confederated Tribes of the Grand Ronde Community of Oregon 

Confederated Tribes of Siletz Indians of Oregon 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

these resources but these effects are expected to be minimal. Potential effects would be reduced by predisturbance review and inventory of treatment areas to reduce inadvertent or incidental impacts to cultural 

resources. Consequently, cumulative loss of paleontological, cultural, and tribal use resources on public 

lands due to the proposed vegetation treatment alternatives is expected to be negligible. 

Effects Common to All Alternatives 

Paleontological Resources 

The effect of vegetation treatments on fossil material would vary with respect to fossil type, minerals, 

degree of fossilization, and exposure. Damage to fossil materials, if present, would likely result if 

wheeled equipment used to apply herbicides, or other mechanical methods, or prescribed fire, impacted 

the site directly, exposed it by causing erosion, or created tracks or other access later traveled by 

recreational OHVs. The degree of those effects to fossil resources would depend on the attributes of the 

fossil material, whether the fossil is buried or exposed, and the method of herbicide application. Methods 

involving the use of off-road vehicles could crush fossil material exposed on the surface or increase 

erosion in the fossil localities. 

With the exception of some fire or mechanical vegetation treatment methods, impacts to fossil resources 

are unlikely to be substantial. Application of herbicides by wheeled vehicles may crush or displace some 

fossils exposed at or near ground surface. 

Indirect impacts can result from activities that contribute to erosion of fossil bearing sediments that lead to 

exposure of fossils and subsequent discovery as well as advance deterioration or loss of the resource. Direct 

impacts can result from activities that cause ground disturbance or direct harm to the resource. Proposed nonherbicide vegetation treatments including mechanical methods or prescribed fire can produce direct harm through 

crushing or indirect effects from increased erosion or other soil disturbances to fossil resources on more than 

15,000 acres in the next 15 years under the herbicide treatment alternatives. 

Cultural Resources 

The effect of vegetation treatments on cultural resources depends on the treatment method and the herbicides 

applied. Some herbicide applications can increase soil acidity, which can advance artifact deterioration. Exposure 

of artifacts or other archaeological resources to herbicides is expected to be minimal; however, herbicides 

containing alkyl, biphenyl, or other compounds that contain C12 and C14 could contaminate carbon samples from 

exposed cultural materials commonly used for dating (Fink and Zietz 1996:473). In addition, the herbicide can 

impact surfaces of masonry structures, pictographs, or petroglyph panels if not removed soon after exposure. 

Cultural resources are distributed unevenly over the landscape. Areas with high probability for sites associated 

with pre-contact or historic use are generally predictable but locations of specific sites or subsurface cultural 

resources are generally unknown without inventory. Numerous cultural resources have been identified but 

many more remain unknown until either exposed by erosion or identified by inventory and excavation. 

Cultural resources often occur on or near the ground surface and can be easily impacted or damaged by ground 

disturbing activities. The more surface disturbance that occurs, the greater the potential for cultural resource site 

disturbance. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Traditional and Cultural Uses 

None of the alternatives would change, restrict, or abrogate treaty reserved or Executive Order rights. However, 

implementation of the Action Alternatives may affect food or other natural resources on which the tribes depend. 

Herbicides can harm plants used by American Indians and can affect the health of the people who gather, handle 

or ingest recently treated plants, fish or other animals contaminated by the herbicides. Since traditionally gathered 

plants and animals may occur near vegetation treatment areas, drift from herbicide treatments may occur in areas 

utilized by American Indians. 

In some instances, plants traditionally used by American Indians for subsistence, religious or other uses may 

not be avoided by vegetation treatments. Whether the plants are affected due to the treatment method selected 

or the objectives of the treatment (i.e., Western juniper control) or through incidental contamination from drift, 

some traditional use plants may be negatively affected. Herbicide residue left on plants, in the water or other 

food sources could result in health risks through ingestion, contact, or other exposure to the herbicides from the 

herbicide treatments. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

There would be no risk of BLM authorized herbicide treatments drifting onto non-target plants of historical 

importance or of traditional value to American Indian people, and no risk of exposure through contact or ingestion. 

Invasive Plants 

This alternative is predicted to increase the spread rate of noxious weeds and other invasive plants and result in 

2.7 million more acres infested with noxious weeds in 15 years than the No Action Alternative. Also, 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 is reduced. Weeds and other invasive 

vegetation would continue to displace native species that are desirable to traditional American Indian activities, 

and would adversely affect the quality forage and cover for wildlife utilized by tribes (see Wildlife Resources 

section in this Chapter). Gathering areas for cultural plants, first foods and medicinal plants would be adversely 

impacted. Cultural features, historical and traditional use areas would also be impacted forcing traditional users 

to seek other, non-traditional areas. The spread of invasive plants from BLM lands to Tribal lands would impact 

existing uses and Tribal interests. 

Noxious weed invasion would increase risks to paleontological and cultural resources through increased erosion, 

reduced shading, changes in soil pH, and other environmental changes. 

Site Disturbance 

In this alternative, 8800 acres of directed livestock, 3700 acres of prescribed fire for weed control, and 5100 acres 

of mechanical treatments would be expected, all of which have a higher risk of impacting sites through ground 

disturbance than most herbicide application methods (Table 4-22). Although fewer acres would be treated for 

weeds in this alternative than under Alternative 2, the number of acres to be treated by directed livestock and 

mechanical methods (and thus potentially resulting in site disturbance) would increase. While this acreage is 

only slightly higher overall than under Alternative 2, the number of acres that would be disturbed by the most 

impacting mechanical treatments and directed livestock, would be significantly greater (31 percent and 68 percent 

respectively) than under Alternative 2. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

 

253 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Herbicides 

Under the No Action Alternative, the BLM would continue to use the four herbicides that were approved for use 

under earlier BLM vegetation treatment RODs: 2,4-D, dicamba, glyphosate, and picloram. The risk to human health 

associated with use of glyphosate, picloram, and dicamba at typical application rates is low, and low to moderate for 

2,4-D. For American Indians gathering traditional resources, exposure to herbicides would be expected to be lower 

than under the other herbicide treatment alternatives because fewer acres would be treated, however the high number 

of acres of 2,4-D in this alternative could result in inadvertent contact and risk to these users. 

Invasive Plants 

Noxious weed treatments under this alternative are predicted to be twice as effective at eliminating weed populations 

as methods available under Alternative 1 (see Noxious Weeds and other Invasive Plants section earlier in this 

Chapter). However, noxious weeds would be expected to continue spreading at their current 12 percent rate and 

infest approximately 1/3 of all BLM lands in Oregon in 15 years. This continued spread of noxious weeds would 

proportionately negatively affect traditional gathering areas as native vegetation is displaced by weeds. 

Site Disturbance 

Adverse effects from non-herbicide treatment methods (directed livestock, mechanical, and prescribed fire) 

would be reduced when compared to Alternative 1. Approximately 2800 acres of directed livestock, 5700 acres 

of fire treatments, and 3500 acres of mechanical treatments would be expected, all of which have a higher risk 

of impacting sites through ground disturbance than most herbicide application methods (Table 4-22). In this 

alternative, 5567 acres of herbicide application by OHV is estimated. Treatments using OHV’s pose a risk of 

disturbance to paleontological resources and cultural resources, but the risk is less than with the above nonherbicide methods. 

For paleontological and cultural resources, prescribed fires of low severity would be expected to result in fewer 

impacts to artifacts or other archaeological resources. Impacts from broadcast seeding would be negligible but 

disturbances from drill seeding could result in additional adverse effects. 

Table 4-22. vegeTaTion TreaTmenT meTHods conTribUTing To groUnd disTUrbance 

Method 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 

Invasive Invasive Invasive 

Invasive & 

wildlife Rights-of-way 

Invasive & all 

other Rights-of-way 

Herbicides 

Applied by 

OHV1 0 5567 10100 11900 0 13533 0 

Mechanical 

Methods 5100 3500 3200 20032 -84603 9744 -84605 

Fire 3700 5700 12500 12500 12500 

Livestock 8800 2800 2800 2800 2800 

Total acres 17600 17567 28600 20743 21347 

1: 33 percent of total herbicides sprayed 

2: 3200 acres of invasive plant treatment minus 1197 acres of wildlife treatments that were being done mechanically that is now being done with herbicides 

3: 8460 acres of ROW work that was being done mechanically that is now being done with herbicides 

4: 3200 minus 2226 acres of wildlife treatments that were being done mechanically that is now being done with herbicides 

5: 3: 8460 acres of ROW work that was being done mechanically that is now being done with herbicides 
 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Herbicides 

Under this alternative, glyphosate would be applied to fewer acres statewide and 2,4-D, dicamba, and picloram 

would be used to treat fewer acres east of the Cascades, than under the No Action Alternative. While herbicide 

exposure for American Indians utilizing vegetal resources in treatment areas would be expected to increase as 

more areas are treated with herbicides, most of the herbicides proposed are of lower risk to human health at 

typical application rates. Also, the reduction in the acres for use of 2,4-D and exclusion of aerial spraying west of 

the Cascades would reduce potential health risks in Alternative 3, although aerial spraying would be uncommon in 

known American Indian plant collection and use areas under all treatment alternatives. 

Invasive Plants 

The additional treatment acres estimated for this alternative and the increased effectiveness of those treatments 

because of the wider array of herbicides available would be expected to slow weed spread to 7 percent annually and 

results in 1.9 million fewer acres infested in 15 years. Reducing the spread of noxious weeds could benefit traditional 

gathering areas as displacement of native vegetation by weeds is slowed. Having herbicides capable of effectively 

controlling nearly all of the noxious weeds and other invasive plants currently known to be in Oregon would allow 

targeting of specific weeds creating specific resource problems, such as infesting susceptible or important use areas. 

Site Disturbance 

In this alternative, 10,100 acres would be treated with herbicides by OHV. Approximately 2800 acres of directed 

livestock, 12,500 acres of fire treatments, and 3200 acres of mechanical treatments would be authorized, all of 

which have a higher risk of impacting sites through ground disturbance than most herbicide application methods 

(Table 4-22). A total of 28,600 acres would be treated by methods that may result in impacts to cultural and 

paleontological resources by ground disturbance, the most acres of all five alternatives. The number of acres 

proposed for treatment potentially resulting in disturbance to cultural and paleontological sites is approximately 

39 percent higher than under Alternatives 1 or 2. 

The number of acres treated by prescribed fire east of the Cascades, and acres of seeding and planting would 

increase in this alternative. Following prescribed fire treatment, hunting and plant gathering pursuits would be 

temporarily limited and possibly shifted to other areas during recovery. Fire treatments would be used primarily 

for invasive plant control where target plants are resistant to fire or are absent or sparse in the treatment area. 

Therefore, impacts to plants of traditional value or to sites would be limited. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

About two thirds of the increased number of acres treated in this alternative address management 

objectives for controlling non-invasive vegetation in rights-of-way, recreation sites, and administrative 

sites. While acres of herbicide treatments would increase in those areas, a corresponding reduction in 

non-herbicide treatments would result. 

Herbicides 

Six herbicides (2,4-D, glyphosate, picloram, and imazapic, metsulfuron methyl, and triclopyr) would be 

used for more than 75 percent of herbicide treatments in this alternative. 

The risk to human health associated with use of glyphosate, picloram, imazapic, metsulfuron methyl, 

and triclopyr at typical application rates is low or zero. Risks to human health are low to moderate for 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

2,4-D under some scenarios, but the herbicide would be reduced to ounces per acre would be used in 

tank mixes for approximately 50 percent of the acres projected. Bromacil and diuron would be added 

by this alternative and have high health risks to some humans, but these herbicides would be used for 

bare-ground adjacent to roads and other developments, not on previously undeveloped areas or areas 

traditionally used for tribal gathering. The broader mix of herbicides would increase the options for 

appropriately managing vegetation while minimizing the risk to humans including American Indians 

gathering traditional resources near the treatment areas. 

The increased number of acres treated with herbicides would result in slightly more acres temporarily 

closed to traditional hunting and plant gathering following herbicide treatments than Alternative 3. Most 

of the increased acres are for rights-of-way and other developments, but about 5,700 acres are projected 

for habitat treatments. 

Invasive Plants 

Although treatments targeting invasive plants are assumed to be the same under this alternative as under 

Alternative 3, inadvertent control of invasive plants along roadsides while controlling encroaching native 

would further reduce the spread of noxious weeds. Weed spread is projected to be reduced to 6 percent, 

and there would be 300,000 fewer infested acres in 15 years when compared to Alternative 3. Despite 

the short-term effects and/or area closures resulting from herbicide treatments, the long-term objective of 

reducing the spread of noxious weeds would benefit traditional gathering areas as displacement of native 

vegetation by weeds is slowed. 

Many designated wild and scenic rivers and some Areas of Critical Environmental Concern (ACECs) 

contain cultural sites and other tribal use areas, and these areas are often crossed by utility lines or 

pipelines or include roads and railroads where right-of-way vegetation treatments with herbicides could 

be expanded. The inadvertent control of noxious weeds by the herbicide use proposed could potentially 

decrease the spread of noxious weeds and other invasive plants into or within culturally significant areas. 

Site Disturbance 

Under the preferred alternative, 11,900 acres would be treated with herbicides by OHV. Approximately 2800 

acres of directed livestock, 12,500 acres of fire treatments, and 2003 acres of mechanical treatments would be 

expected, all of which have a higher risk of impacting sites through ground disturbance than most herbicide 

application methods (Table 4-22). A total of 20,743 acres would be treated by methods that may result in impacts 

to cultural and paleontological resources by ground disturbance, approximately 27 percent lower than Alternative 

3, but 15 percent higher than under Alternatives 1 or 2. Herbicide treatments of rights-of-way, recreation sites, 

and administrative sites would be unlikely to impact cultural and paleontological resources. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Herbicides 

In addition to the herbicides identified in Alternative 4, two additional herbicides, diquat and 

diflufenzopyr +dicamba, would be available under Alternative 5, and bromacil, chlorsulfuron, 

sulfometuron methyl, and tebuthiuron would be authorized west of the Cascades. Also all herbicides 

could be used for other non-commodity objectives, although most of the increased acreage in this 

alternative would likely go toward habitat improvements not included in Alternative 4. 

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This alternative would have the greatest short-term impact on traditional gathering areas, primarily by 

resulting in the temporary closure of more lands. Along with these closures, opportunities for collection 

of plant materials would likely be reduced more than under other alternatives. Although only a small 

portion of the acres treated using herbicides would occur in known culturally significant areas, more acres 

and areas would be treated under this alternative than the other alternatives. 

Diquat, bromacil, and diuron pose the most severe human health risks and would increase risk to 

American Indian health if herbicides were ingested from plants that were collected in the treatment areas 

under this alternative. However, diquat would be used as an aquatic herbicide, and bromacil and diuron 

use would be along roadsides and around other developments, so they should not pose a significant risk. 

Invasive Plants 

As with Alternative 4, weed spread is projected to be reduced to 6 percent, and there would be 300,000 

fewer infested acres in 15 years when compared to Alternative 3. Despite the short-term effects and/or 

area closures resulting from herbicide treatments, the long-term objective of reducing the spread of noxious 

weeds would benefit traditional gathering areas as displacement of native vegetation by weeds is slowed. 

Site Disturbance 

In Alternative 5, 13,533 acres would be treated with herbicides by OHVs. Approximately 2800 acres 

of directed livestock, 12,500 acres of fire treatments, and 974 acres of mechanical treatments would 

be expected, all of which have a higher risk of impacting sites through ground disturbance than most 

herbicide application methods (Table 4-22). The acres of vegetation control potentially resulting in 

disturbance to sites is greater under this alternative (21,347) than the Proposed Action, Alternative 4 

(20,743). 

Cumulative Effects 

Paleontological resources (fossils) are nonrenewable and once damaged or displaced from their natural context, 

the damage is often irreparable and cumulative. Although about 300 fossil localities have been identified on BLM 

administered lands in Oregon, the location of fossils is predictable only to a limited extent. The locations of many 

paleontological resources remain unknown. 

Past effects result from natural erosion as well as purposeful and inadvertent damage from public land uses. 

Scientific research as well as “collectors’ have contributed to past destruction, removal and displacement of fossil 

resources. Prior to the 1970’s, inadvertent damage resulting from various land development and management 

activities occurred. With increased awareness of the scientific value of the resource, and development of 

regulations requiring inventory and prohibiting unauthorized removal of scientifically important and unique fossil 

resources, the cumulative loss of paleontological resources has slowed. 

Cultural resources including archaeological and historic sites and materials and properties of traditional cultural 

and religious importance are vulnerable to cumulative effects from a variety of activities. Archaeological sites 

can be impacted by erosion, construction, looting, excavation, and activities that alter or destroy features or 

remove artifacts or other cultural materials from their depositional context. Cultural properties including sites of 

the built environment, and properties of traditional importance, hunting and fishing sites, graves, and religious or 

ceremonial sites may lose their integrity and cultural significance when they are degraded as a result of natural or 

human caused disturbance processes or when access to the properties is lost so that the people who value them 

can no longer access them resulting in the loss of people’s connection to those places over time. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Numerous processes including deposition, erosion, re-use and deterioration has affected artifacts and other 

cultural materials through time. As natural processes destroyed, deformed, or re-deposited cultural materials and 

as peoples reused found objects or features, the nature of sites and other cultural resources have been affected. As 

Euro-American settlement advanced into the region, American Indian peoples were displaced and sites were often 

further altered, damaged, or destroyed. As Euro-American settlements advanced, land disturbances largely from 

grazing, timber harvest and mineral exploration and extraction resulted in wide scale impact and loss to cultural 

properties and life ways. 

Cumulative impacts to paleontological and cultural resources from vegetation treatments would be least under 

the No Action Alternative and greatest under Alternative 3 due to the number of acres that could be impacted 

by ground disturbing activities (Table 4-22). The remaining alternatives would be intermediate between these 

two alternatives. Most vegetation treatment options involving ground-disturbing activities likely would disturb 

only the upper few inches of sediments and in many cases would be confined to roads, trails, or access routes. 

Treatment methods causing erosion or soil disturbance could cause indirect impacts to paleontological resources 

but these effects would be minimal. Potential effects would be reduced by pre-disturbance surveys and inventory 

of treatment areas to identify fossil resources, and by designing treatments to avoid impacts to paleontological 

resources. Consequently, cumulative loss of paleontological and cultural resources on public lands due to the 

proposed vegetation treatment alternatives is expected to be negligible. 

Tribal uses are adversely affected by the spread of noxious weeds and displacement of plants and animals of 

traditional importance. Ground disturbing activities including resource extraction, grazing, motorized vehicles, 

and other land disturbing activities increase impact to cultural resources. Proposed vegetation treatments that 

increase the number of acres to control the spread of noxious weeds and non-invasive vegetation can result in 

short-term impacts by temporarily limiting access to traditional resources by American Indian tribes but long-term 

benefits for improved habitats and plant communities can also be realized. The cumulative impacts to cultural 

resources from the proposed vegetation treatments would be least under the No Action Alternative and greatest 

under Alternative 3 based on the number of acres that could be impacted by ground disturbing activities. The 

remaining alternatives would be intermediate between these two alternatives. Prescribed fire and mechanical 

treatment methods would be anticipated to have the greatest short-term impacts to wildlife and habitats. Acres 

treated using mechanical methods would be the lowest in Alternative 4 and Alternative 5. Acres to be treated by 

prescribed fire would be similar in Alternative 3, Alternative 4, and Alternative 5 and each would treat more acres 

for east of the Cascades and fewer acres west of the Cascades than under Alternatives 1 or 2. 

Alternative 5 would authorize the greatest number of acres of vegetation treatment with short-term impacts 

resulting from temporary closure of treatment areas and long-term benefits from more effective and efficient 

weed treatments, and could result in the greatest risk to American Indian health from exposure or ingestion of 

herbicides. Alternative 1 would have the least risk to American Indian health from herbicide treatments but would 

be least effective controlling vegetation and plants of value to American Indian tribes. 

Completion of cultural resource reviews, inventories and consultation with American Indian tribes in areas likely 

to include cultural resources and traditional cultural values prior to vegetation treatments would reduce potential 

effects to cultural resources under all alternatives. Pre-disturbance site identification methods and avoidance 

or other protection methods would reduce the chance that significant cultural resources would be impacted and 

would result in negligible cumulative impacts to cultural resources. 

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Visual Resources 

Affected Environment 

The public lands administered by the BLM in Oregon contain many outstanding scenic landscapes. Vast areas 

of forested land, grassland, shrubland, canyon land, and mountain ranges provide scenic views to recreationists, 

visitors, adjacent landowners, and those just passing through. Activities occurring on these lands, such as the 

treatment of invasive plants and other vegetation, have the potential to impact scenic values. 

The BLM uses a system called VRM (Visual Resource Management; Manual 8400) to systematically identify 

and evaluate scenic values to determine the appropriate level of scenery management (USDI 1984b). The BLM 

Visual Resource Inventory Handbook (Handbook 8410-1; USDI 1986a) sets forth the procedures for inventorying 

scenic values and establishing VRM objectives, referred to as Management Classes. These ratings are then used 

during the land use planning process and considered along with other resource objectives to determine final 

VRM objectives, or classes. BLM policy requires that every acre of BLM land be inventoried and assigned a 

VRM class ranging from Class I to Class IV. After VRM classes have been established, BLM policy requires all 

management activities to be designed to meet the assigned class objectives. Class IV allows for the most visual 

change to the existing landscape, while Class I allows the least. In Oregon, there are approximately 2.7 million 

acres in VRM Class I and approximately 750,000 acres in VRM Class II. There are several SOPs that apply to 

reducing the visual impact of herbicide and other treatments such as designing treatments in Class I and Class II 

VRM areas so they do not attract attention of the casual viewer (Appendix 2). 

In Oregon, it is estimated that 1.2 million acres of BLM administered lands in Oregon are infested with noxious 

weeds and another 5 million are infested with other invasive plants, increasing at a rate of 12 percent per year (see 

Noxious Weeds and other Invasive Plants section in this Chapter). In these infested areas, the native vegetation 

has been replaced, dominated, or significantly altered by one or more invasive plants, leaving the areas in an 

unnatural state that are assumed in this analysis to be visually degraded. The BLM uses guidance found in the 

Visual Resource Contrast Rating Handbook (Handbook 8431-1; USDI 1986b) to make such determinations 

of landscape quality and character. The handbook provides an objective and consistent method for describing 

landscape character, evaluating visual effects of activities, and developing mitigation to meet VRM objectives. 

The contrast rating process involves describing the landscape in the context of the basic environmental design 

elements and features that comprise it. The elements of form, line, color, and texture are used when describing 

and evaluating landscapes. Activities or modifications in a landscape that repeat these elements are considered to 

be in harmony with their surroundings. Modifications that contrast with their surroundings are considered not in 

harmony with their surroundings. 

Environmental Consequences 

The visual effects of vegetation treatments are dependent on a variety of factors including the existing visual 

condition of the area, the method of treatment used, the time of year the treatment is conducted and the size of 

the area treated. The use of herbicides have the short-term effect of creating browned and dead vegetation with 

the long-term effect of reducing the spread of the targeted species and therefore improving the overall health and 

visual quality of the landscape. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Effects Common to All Alternatives 

Effects of Invasive Plants 

Based on principles outlined in BLM’s Visual Resource Contrast Rating Handbook (USDI 1986b), this EIS makes 

the assumption that diverse, native-dominated communities are more visually appealing than plant communities 

that have been overtaken by monocultures of weeds or other undesired species62. The weed spread rate analysis 

in the Noxious Weeds and Other Invasive Plants section in this Chapter determined that for every acre of weeds 

effectively treated (eradicated), 10 fewer acres are infested 15 years from now, providing a corresponding benefit 

to visual resources. 

Effects of Treatments 

Conversely, it is also recognized that all methods of invasive plant treatments have the potential to impact visual 

resources in the short term (1-3 years). The alternatives in this EIS propose differing types and amounts of 

invasive plant control and, therefore, the visual impacts of these alternatives also differ. In Oregon, there are 

approximately 2.7 million acres in VRM Class I and approximately 1.1 million acres in VRM Class II. Of these 

acres, 0.6 million acres are outside of Wilderness and Wilderness Study Areas, Wild and Scenic Rivers, National 

Monuments, Areas of Critical Environmental Concern, Outstanding Natural Areas, Steens Mountain Cooperative 

Management and Protection Area, and Research Natural Areas and similarly designated areas where following the 

underlying direction for the area would automatically achieve the VRM objectives. 

Mechanical treatments such as mowing and the use of chainsaws have the short-term visual effect of cut and 

browned vegetation and stumps. Blading and disking produces the visual effect of tilled and disturbed soil in 

the short term. The use of these mechanical methods usually occurs on an annual basis and therefore this visual 

effect is cyclical in nature with no long-term change in the visual quality of the treatment area. The mechanical 

portion of the non-herbicide treatment acres for each alternative in all VRM classes are listed below. As noted 

on the table, no attempt has been made to quantify the tens of thousands of acres of native vegetation treatments 

currently being done by the BLM in Oregon for all resource objectives. However, for Alternatives 4 and 5, 

herbicide use would replace approximately 9,657 and 10,686 acres of mechanical treatments respectively, so 

these are shown as negative numbers, or reductions, in the amount of mechanical treatments currently being done 

(Table 4-23). 

Manual methods of treatment such as pulling, digging and grubbing weeds focus on the removal of only the 

unwanted vegetation and therefore there is very little short-term visual impact from this activity, although there is 

the potential for some trampling of native vegetation and soil disturbance to occur (see Table 4-23). 

Prescribed fire treatments result in a short-term visual effect of a burned-over, charred and blackened landscape. 

Prescribed fire as a weed control treatment is applied where invasive plants dominate the landscape, and thus few 

native species would be lost as a result of the treatment. These treatments are typically followed by reseeding the 

area with native vegetation, which results in new growth in the next growing season, with the long-term positive 

effect of creating a native species-dominated vegetation landscape (see Table 4-23). 

The use of directed livestock for weed control (such as the use of grazing goats to treat invasive vegetation) 

results in the visual effect of a grazed area with limited short-term visual impact (see Table 4-23). 

62 It is acknowledged that the yellow flowers of Scotch broom, gorse, and other weeds can be visually appealing to many 

people, and the effects described in this section might also be considered from that standpoint. 

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 260 

Effects from biological agent releases such as insects, pathogens, or other organisms to feed upon the targeted 

weed species occur gradually and are thus almost imperceptible as their impact on the invasive plant may occur 

over an entire growing season or several growing seasons. Over the long term, their removal of the targeted 

invasive vegetation will result in a more native dominated system that is visually appealing (see Table 4-23). 

The visual effects of using herbicides to treat invasive vegetation vary depending on which herbicide is applied 

and how it is applied (Chapter 3). Where herbicides are applied directly to the invasive plant using a backpack 

sprayer or wicking method, the short-term visual impact is from browned and dead vegetation mixed with 

green, native vegetation and therefore the impact is not very dramatic or easily discernable. 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. For invasive weed treatments, such treatments are usually restricted to areas where invasive 

weeds dominate the landscape and natives are either resistant to the treatment being applied, or the treatment is 

in conjunction with seeding native species or equivalent restoration treatment. In eastern Oregon, there are also 

opportunities to treat an area after a wildfire to prevent the introduction of such invasive plants as cheatgrass and 

medusahead. In these situations, the visual quality of the area has already been diminished by the wildfire and 

the application of the herbicide after such an event does not further degrade the visual character of the area. For 

example, Approximately 11,500 of the 13,600 acre projected herbicide use increase between Alternatives 2 and 3 

would be imazapic applied aerially areas east of the Cascades heavily infested with invasive annual grasses such 

as cheatgrass and medusahead, and most of these treatments follow wild or prescribed fire (see Table 4-23). 

Also, 9,300 acres of the additional herbicide acres between Alternative 3 and 4 are non-selective treatments along 

rights-of-ways and similar safety and maintenance treatments. However, all of these (and a portion of other 

treatments proposed under this alternative) replace non-herbicide methods currently taking place. Nearly 80 

percent of the expected herbicide increase between Alternatives 3 and 4, and 75 percent of the increase between 

Alternatives 3 and 5, replace right-of-way, administrative site, recreation site, and habitat improvement projects 

already being done with non-herbicide methods (see negative numbers under Alternatives 4 and 5 above), and 

therefore may be neutral or even beneficial to visual resources (see Table 4-23). 

Table 4-23. esTimaTed annUal TreaTmenT acres by alTernaTive 

Alt . 1 Alt . 2 Alt . 3 Alt . 4 Alt . 5 

Mechanical 

Invasive Vegetation 5,100 3,500 3,200 3,200 3,200 

Native Vegetation Unknown1 Unknown1 Unknown1 -9,6572 -10,6862 

Manual 

Invasive Vegetation 3,500 2,200 2,200 2,200 2,200 

Native Vegetation Unknown1 Unknown1 Unknown1 -1,9082 -2,5942 

Prescribed Fire 

Invasive Vegetation 3,700 5,700 12,500 12,500 12,500 

Directed Livestock 

Invasive Vegetation 8,800 2,800 2,800 2,800 3,000 

Bio-control 

Invasive Vegetation 400 300 200 200 200 

Herbicide 

Invasive and Native 

Vegetation 

NA 16,700 30,300 45,100 50,000 

1

No attempt was made to calculate the mechanical treatments for Alternatives 1-3 but it is assumed to be a very high number on the magnitude of a 100,000 acres. 

2

See Assumptions discussion in Chapter 3 for a more detailed discussion of these changes in acres treated using mechanical methods. 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

The greater the area of vegetation treatment, the greater the visual impact is likely to be. The effects of treatments 

over a large portion of the landscape are more likely to be observed by people than the effects of small-scale 

treatments. However, since areas receiving large-scale treatments are most likely to be degraded lands of low 

to moderate scenic quality, the visual impact from treatment would be minimized and there would likely be an 

improvement in the scenic quality of the land over the long term. 

Color contrasts caused by vegetation removal would be most apparent in areas dominated by green and/or 

flowering vegetation and by large plants, such as Western juniper. The visual impacts would be heightened if 

the herbicides also prevented the manifestation of seasonal changes in vegetation, such as spring flowers and/ 

or fall color. However, the brown colors associated with vegetation treatments would be least noticeable during 

the late fall and the winter, when they would blend more naturally with surrounding colors, than in the spring and 

summer, when the green colors of new growth are more likely to be present. Impacts to visual resources from 

even the most broad-scale herbicide treatments would begin to disappear within one to two growing seasons 

in most landscapes. The regrowth of vegetation on the site would eliminate much of the stark appearance of a 

cleared area. Over the long term, vegetation treatments would be expected to improve visual resources on public 

lands as natural color and form are maintained and/or restored. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

Effects of Invasive Plants 

Loss of natural color and form are projected to occur on an additional 2.7 million acres infested with noxious 

weeds in 15 years when compared to the No Action Alternative (see Table 4-4 in the Noxious Weeds and Other 

Invasive Plants section in this Chapter). 

Effects of Treatments 

Potential negative effects to the visual resource that would occur as a result of Alternative 1 are associated with 

the mechanical, manual, prescribed fire, biological control and directed livestock treatment methods proposed by 

the alternative. Under this alternative, these non-herbicide methods of treatment are expected to be conducted on 

more than 20,000 acres. Compared to Alternative 2 (No Action), this is an approximate 50 percent increase in 

these methods, but a 16,700-acre decrease in the use of herbicides, resulting in an overall increase in short-term 

negative effects. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Effects of Invasive Plants 

Under this alternative, the number of infested acres partially or wholly replacing more visually desirable native 

plant communities (see Effects Common to All Alternatives, above) is projected to reach 5.9 million acres over a 

15 year period, or about 1/3 or all BLM lands in Oregon, with an annual rate of spread of 12 percent (Table 4-4). 

Effects of Treatments 

Potential negative effects that would occur as a result of implementation of the No Action Alternative are 

associated with the mechanical, manual, prescribed fire, biological control, directed livestock, and herbicide 

treatment methods proposed by the alternative. Under this alternative, herbicides can only be used to treat 

noxious weeds, and the annual herbicide treatment levels are projected to be 16,700 acres. The predominant 

visual effect of treatments are associated with the use of backpack foliar sprayers and hand held sprayers attached 

to a small tank on an ATV/UTV or truck. Only the noxious weeds in the treatment area would be sprayed, 

creating a mosaic visual effect with only the noxious weeds in the treatment area turning brown and dying. 

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The remaining herbicide acres would be treated with aerial applications (7 percent). The visual effect of these 

treatments involves the browning and die-off of larger swaths of vegetation. These types of broadcast applications 

occur where a significant portion of the area is already infested and therefore already exhibits a diminished 

visual quality. In general, herbicide treatments would have short-term negative effects (first year following 

treatment) and long-term positive effects on visual resources by allowing for the protection and/or return of native 

vegetation. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Effects of Invasive Plants 

Under this alternative, the number of infested acres partially or wholly replacing more visually desirable native 

plant communities (see Effects Common to All Alternatives, above) is projected to be 1.9 million acres less than 

under the No Action Alternative in 15 years, and be spreading 5 percent slower (7 percent versus 12 percent). 

Effects of Treatments 

Negative visual effects from implementation of Alternative 3 would be associated with the mechanical, manual, 

prescribed fire, biological control, directed livestock, and herbicide treatment methods proposed by the alternative. 

Under this alternative, with the broader array of herbicides available and the ability to treat invasive vegetation 

and control pests and diseases in addition to noxious weeds, there is an increase in the total acres treated with 

herbicides when compared to Alternative 2 (30,300 acres compared to 16,700 acres). There is also a 7,000-acre 

increase in the use of prescribed fire. The mechanical treatments would be slightly less (3,200 acres compared 

to 3,500 acres) as would be the use of biocontrol methods (200 acres compared to 300). Both Alternative 2 and 

Alternative 3 estimate the same amount of directed livestock use (2,800 acres). 

Under this alternative, the use of currently available herbicides (2,4-D, dicamba, glyphosate, and picloram) 

is reduced while other herbicides would be used. It is estimated that approximately 18,800 of the herbicide 

treatment acres would be treated using directed foliar spray (spot treatments) and cut stump/wick/wipe/hack and 

squirt methods, while 11,500 would be treated using imazapic aerially following prescribed fires or wildfires. The 

visual effect on the 18,800 acres would similar to Alternative 2, involving the browning and die-off of the noxious 

weed, invasive weed, or pest and disease host (e.g. tanoak trees in Curry County) creating a mosaic visual effect. 

This visual effect would be short-term with the long-term effect of promoting native vegetation and reducing the 

spread of the targeted species. 

In those situations where imazapic is used following wildfires or prescribed fires, either a wildfire has occurred 

and the visual quality of the area has already been degraded as a result of the wildfire, or the entire area was 

already degraded by the establishment of invasive grasses and a prescribed fire was conducted. The subsequent 

application of herbicides will have no additional visual impact other than the long-term benefit of preventing the 

resurgence of invasive plants and allowing the area to return to a state where native vegetation dominates. This 

use of imazapic following wild and prescribed fires in eastern Oregon represents 85 percent of the 13,600 acres 

of increase in herbicide use between Alternative 2, No Action, and Alternative 3. The actual increase in spot 

treatments on all other species is projected to be 2,100 acres net. 

In general, herbicide treatments would have short-term negative effects (first year following treatment) and longterm positive effects on visual resources by facilitating the return of native vegetation. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Effects of Invasive Plants 

Under this alternative, the number of infested acres partially or wholly replacing more visually desirable native 

plant communities (see Effects Common to All Alternatives, above) is projected to be 2.2 million acres less than 

under the No Action Alternative in 15 years, and noxious weed spread would be reduced to an annual rate of 6 

percent, or about half the current rate. 

Effects of Treatments 

The visual effects of Alternative 4 are associated with the mechanical, manual, prescribed fire, biological control, 

directed livestock, and herbicide treatment methods proposed by the alternative. Under this alternative, with the 

broader array of herbicides available and the ability to treat invasive vegetation, pests and diseases, vegetation 

in rights-of-way, administrative sites, recreation sites, and habitats in Conservation Plans in addition to noxious 

weeds, the acres treated with herbicides is estimated at 45,100 acres. This is a 28,400-acre increase compared to 

Alternative 2 – No Action. The visual effects associated with the treatment of noxious weeds, invasive weeds and 

pests and diseases are the same as noted under Alternative 3. 

Under this alternative 9,300 acres of rights-of-way, administrative sites, and recreation sites would also be treated 

using herbicides. In some right-of-way areas, such as under power lines, the application of herbicides will most 

likely involve the use of a selective herbicide, which will result in a mosaic visual effect that would replace the 

visual effect of mechanically treating these areas with such things as a mower or chainsaw. Along road edges 

and around many administrative sites, a broad-spectrum pre-emergent herbicide would be used to remove most 

vegetation to prevent damage to improvements and limit the risk of wildfire encroaching on communication and 

other developed sites. In those areas where herbicides would be used in other administrative sites and recreation 

sites the primary application method would be backpack application of the herbicide to the targeted vegetation 

such as blackberry bushes, resulting in the visual effect of intermittent browned and dead vegetation in the area in 

the short term. 

Under this alternative, 5,700 acres would also be used for habitat improvement projects identified in Conservation 

Plans. For example, this type of herbicide use is proposed for treatment of Western juniper and sagebrush to 

improve habitat conditions for sage grouse in eastern Oregon. Western juniper and sagebrush are currently treated 

using mechanical methods (chainsaw/mowing) to achieve these habitat objectives. All but 200 acres of these 

treatments are expected to be east of the Cascades (Table 3-3). The visual effect of these herbicide treatments 

would depend on the size of the treatment area and the application method selected, but would result in increased 

browned and dead vegetation in the short-term. 

In general, the herbicide treatments proposed under this alternative would have short-term visual effects (first year 

following treatment) with the long-term visual effect of returning the treated area to one dominated by a diverse 

array of native vegetation, and preventing (or slowing) a decline in visual quality caused by future infestations. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Effects of Invasive Plants 

As with Alternative 5, the number of infested acres partially or wholly replacing more visually desirable native plant 

communities (see Effects Common to All Alternatives, above) is projected to be 2.2 million acres less than under the 

No Action Alternative in 15 years, and noxious weed spread would be reduced to an annual rate of 6 percent. 

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Effects of Treatments 

The visual impacts of Alternative 5 are associated with the mechanical, manual, prescribed fire, biological 

control, directed livestock, and herbicide treatment methods proposed by the alternative. This alternative expands 

upon the use of herbicides proposed in Alternative 4 by 4,900 acres to include treating vegetation to meet noncommodity management objectives such as treating native vegetation to promote habitat for elk and white tailed 

deer. With the exception of this additional 4,900 acres, all of the visual effects for this alternative would be the 

same as described for Alternative 4. (Like Alternative 4, the mechanical, manual, prescribed fire, biological 

control, and directed livestock treatments are the same as those estimated for Alternative 3). 

On the 4,900 acres where additional herbicide treatments are estimated to occur, the visual effects would depend 

on the size of the treatment area and the application method selected, but would result in increased browned 

and dead vegetation in the short-term with the long-term visual effect of creating a healthy native vegetative 

community. Some portion of these treatments would be replacing treatments currently being done with nonherbicide methods. 

Wilderness and Other Special Areas 

Affected Environment 

In Oregon, BLM lands include Wilderness and Wilderness Study Areas; National Wild and Scenic Rivers; 

National Monuments and National Conservation Areas; National Scenic and Historic Trails; Areas of Critical 

Environmental Concern (ACEC); Research Natural Areas; and Outstanding Natural Areas. Special management 

applies within these areas, with the intent to preserve, protect, and evaluate these significant components of our 

national heritage. Most special areas are either designated by an Act of Congress or Presidential Proclamation, 

or are created under BLM administrative procedures. With the exception of Wilderness Areas and Wilderness 

Study Areas, there are no specific restrictions on vegetation treatments in these special areas. However, activities 

that have the potential to degrade the quality, character, and integrity of these lands are prohibited. The unique 

characteristics of these special areas would be considered during planning for vegetation treatment activities. 

Wilderness and Wilderness Study Areas 

The BLM manages eight Wilderness Areas in Oregon encompassing over 247,000 acres. The recently enacted 

Omnibus Public Land Management Act of 2009 added four new wilderness areas on BLM land, including Soda 

Mountain in the Cascade-Siskiyou National Monument, the Badlands just east of Bend, Oregon, Spring Basin 

on the John Day River, and a portion of the Lower White River Wilderness on Mt. Hood. Wilderness Areas are 

designated by Congress as areas “where the earth and its community of life are untrammeled by man, where man 

himself is a visitor who does not remain” (Wilderness Act of 1964). Consisting of areas generally 5,000 acres or 

larger, Wilderness Areas also offer outstanding opportunities for solitude or a primitive and unconfined type of 

recreation. These areas may also contain ecological, geological, or other features that have scientific, scenic, or 

historical value. In Oregon, the BLM also manages 87 Wilderness Study Areas (WSAs) encompassing 2.6 million 

acres. While Congress considers whether to designate a WSA as permanent wilderness, the BLM manages the 

area to prevent impairment of its suitability for wilderness designation. 

Vegetation treatments used in wilderness and wilderness study areas follow the guidance contained in 43 CFR 6300 

(Wilderness Management; Federal Register 2000), and in the Management of Designated Wilderness Areas Handbook 

H-8560-1 (USDI 1988b), and the Interim Management Policy for Lands under Wilderness Review Handbook 

H-8550-1 (USDI 1995a). The guidance for these areas includes the following direction regarding noxious weeds: 

 264 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

•		 Noxious weeds may be controlled by grubbing or with herbicides when they threaten lands outside 

wilderness or are spreading within the wilderness, provided the control can be done without serious 

impacts on wilderness values and treatments are necessary to maintain the natural ecological balances. 

•		 Plant control must be approved for native plants when needed to maintain livestock grazing operations 

where practiced prior to the designation of wilderness. 

•		 Reseeding may be done by hand or aerial methods to restore natural vegetation. 

In addition to designated wilderness and WSAs, BLM maintains inventories of public lands found to possess 

wilderness characteristics since completion of the original inventories in the late 1970s and early 1980s. To date, 

those inventory updates have found approximately 26,000 acres in western Oregon and approximately 225,000 

acres in eastern Oregon outside of designated wilderness and WSAs that meet the minimum criteria for wilderness 

character. There are no specific management restrictions associated with these areas, unless a land use plan has 

specifically allocated these areas for protection of their wilderness character. Regardless, management activities 

proposed in these areas must be analyzed for impacts to the area’s wilderness character, and reasonable mitigation 

opportunities will be considered. 

Wild, Scenic, and Recreational Rivers 

National Wild and Scenic Rivers (WSRs) are rivers (or river sections) designated by Congress or the Secretary 

of the Interior, under the authority of the Wild and Scenic Rivers Act of 1968, to protect and enhance remarkable 

scenic, recreational, geologic, fish and wildlife, historic, cultural, or other similar values and to preserve the 

river in its free-flowing condition. The law recognizes three classes of rivers—wild, scenic, and recreational. 

Wild rivers are free of impoundments and generally inaccessible except by trail, with watersheds or shorelines 

essentially primitive and water unpolluted. Scenic rivers are free of impoundments with shorelines or watersheds 

largely undeveloped, but accessible in places by roads. Recreational rivers are readily accessible by road or 

railroad, may have some development along their shoreline, and/or may have undergone some impoundment or 

diversion in the past. In Oregon, the BLM manages all or portions of 25 rivers totaling more than 800 miles as 

part of the National WSR System. 

National Monuments 

National Monuments are established by Act of Congress or by Presidential Proclamation under the authority of 

the Antiquities Act. National Conservation Areas (NCAs) are designated by Congress. Oregon BLM manages 

one National Monument (Cascade-Siskiyou National Monument) totaling nearly 54,000 acres in the Medford 

District. There are no NCAs per se on BLM-administered lands in Oregon, but the Steens Mountain Cooperative 

Management and Protection Area (428,000 acres) in the Burns District, and the Yaquina Head Outstanding 

Natural Area in the Salem District (100 acres), fall under the NCA category due to their similar Congressional 

designation origins. 

National Scenic and Historic Trails 

Congress, under the National Trails System Act of 1968, designates areas as National Scenic and Historic Trails. 

National Scenic Trails offer maximum outdoor recreation potential and provide enjoyment of the various qualities 

(scenic, historical, natural, and cultural) of the areas through which these trails pass. National Historic Trails 

are extended trails that follow as closely as possible, on Federal land, the original trails or routes of travel with 

national historical significance. Designation identifies and protects historic routes and their historic remnants and 

artifacts for public use and enjoyment. A designated trail must meet certain criteria, including having a significant 

265 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

potential for public recreational use or interest based on historical interpretation and appreciation. In Oregon, 

BLM manages approximately 50 miles of National Scenic and Historic Trails (41 miles of the Pacific Crest 

National Scenic Trail, 8 miles of the Oregon National Historic Trail, and about 3⁄4-miles of the California National 

Historic Trail). 

Areas of Critical Environmental Concern, Research Natural Areas, and 

Outstanding Natural Areas 

In Oregon there are 207 ACECs totaling 826,138 acres. The BLM uses the ACEC designation to highlight 

public land areas where special management attention is necessary to protect and prevent irreparable damage to 

important historical, cultural, and scenic values; fish or wildlife resources; or other natural systems or processes. 

The ACEC designation may also be used to protect human life and safety from natural hazards. The BLM 

identifies, evaluates, and designates ACECs through its resource management planning process. Management 

prescriptions are set forth in approved RMPs and plan amendments. More detailed activity plans for ACECs may 

be prepared where circumstances warrant. 

In Oregon, there are 82 Research Natural Areas (RNAs) encompassing 197,520 acres. RNAs are areas that are 

permanently protected from resource extraction and other forms of active management. They are a scientifically 

classified system of naturally occurring ecosystems for the purposes of scientific study and education and for 

protection of biological diversity. RNAs are managed to maintain the natural features for which they were 

established and to maintain natural processes. 

Outstanding Natural Areas (ONAs) are areas that have unique scenic, scientific, educational, and recreational 

values. Recreation activities center on those that foster education and interpretation of the ONA’s unique 

resources. In Oregon, there are nine ONAs encompassing 17,885 acres. 

Environmental Consequences 

Due to the unique nature of wilderness and other special areas, limited vegetation management occurs in these 

areas. However, the BLM does control invasive and noxious weeds when they threaten lands outside the area or 

are spreading within the area itself and can be controlled. Any treatments that take place in wilderness and other 

special areas need to conform to the management prescriptions for that area and any activity that has the potential 

to degrade the quality, character, and integrity of these protected lands are prohibited. Treatment methods have 

the potential to directly and indirectly affect wilderness and other special areas such as the potential effects of 

disturbed soil (from such actions as grubbing), and the potential to impact native, non-target vegetation with the 

use of herbicides. Although it is permissible in special or emergency cases, mechanical methods of treatment are 

rarely utilized in wilderness areas due to their potential for disturbance and adherence to the principle of avoiding 

use of mechanized equipment in wilderness areas. 

Effects Common to All Alternatives 

In general, herbicide treatments in wilderness and other special areas would have short-term and usually 

negligible negative effects and long-term positive effects on wilderness and special status area values and 

surrounding areas. In wilderness areas and WSAs, only treatments that improve the natural condition of these 

and surrounding areas would be allowed. In Wild and Scenic Rivers, only treatments that protect and enhance 

the outstanding and remarkable values identified in the legislation establishing each river are permitted within a 

1⁄4-mile buffer along the river (Appendix 2). Therefore, long-term effects, if treatments were successful, would be 

 266 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

 

 

267 

beneficial. The net effect of treatments on wilderness and other special areas would depend on whether the end 

condition of the treatment site (considering both long-term benefits and short-term impacts) was an improvement 

in the characteristics of the area. In almost every case (e.g., eradication of a small population of an incipient pest), 

vegetative communities in the treatment area would quickly recover, and the overall effect would be positive. In 

rare cases (e.g., repeated access to a site in order to meet off-site control objectives), the impacts of the treatment 

to the wilderness character or river values of the site could outweigh the potential long-term benefits to the special 

area. The short-term effects of vegetation treatments in other special areas would typically be less significant 

than those in wilderness areas and wild sections of WSRs, as human activities and influences are not necessarily 

incompatible with their unique qualities. However, all treatments would have the potential to alter these unique 

qualities, as well as to provide long-term benefits by controlling weeds. 

In addition to the full range of integrated vegetation management techniques such as prevention and early 

detection common to all alternatives (see Integrated Vegetation Management in Chapter 3), the SOPs common to 

all alternatives help minimize the potential for adverse effects to wilderness and other special areas (Appendix 2). 

In areas found to possess wilderness character outside of designated wilderness and WSAs, vegetation treatments 

could impair their wilderness values to varying degrees depending on the type and purpose of treatments. For 

areas with wilderness character specifically protected under a land use plan decision, effects to wilderness 

character would be similar to those effects described above for wilderness and WSAs. In other areas with 

wilderness character, treatments designed to improve ecological conditions would have impacts similar to 

protected areas, while some other treatments may more permanently affect wilderness values where treatments 

are not designed to return the area to a natural appearance. In all cases, site-specific impact analyses will be 

conducted as actual treatments are proposed, and possible mitigation measures will be considered. 

Effects by Alternative 

For context, and as a point of reference for assessing the potential effects of each of the alternatives, the 

approximate annual acres of noxious weeds currently being treated within each of the special area designations by 

treatment method are shown on Table 4-24. The annual acres of other invasive weeds currently being treated in 

these areas are shown on Table 4-25. 

Table 4-24. aPProximaTe acres of noxioUs Weeds TreaTed annUally in sPecial areas 

Method Wilderness 

Wilderness 

Study Areas 

National 

Monuments 

National 

Conservation 

Areas ONAs RNAs ACECs 

Wild and 

Scenic 

Rivers Total 

Herbicides1 26 160 600 1400 180 27 74 237 2,704 

Manual 12 7 50 2 175 22 34 275 577 

Mechanical 130 30 105 265 

Biocontrol 10 4 1 10 80 105 1

 Herbicides limited to 2,4-D, Dicamba, Glyphosate, and Picloram 

Table 4-25. aPProximaTe acres of oTHer (non-noxioUs) invasive vegeTaTion TreaTed annUally in sPecial areas 

Method Wilderness 

Wilderness 

Study Areas 

National 

Monuments 

National 

Conservation 

Areas ONAs RNAs ACECs 

Wild and 

Scenic 

Rivers Total 

Manual 10 25 1 21 7 64 

Mechanical 5 3 5 13 

Biocontrol 5 5 
 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Alternative 1 – No Herbicide Use 

The manual, mechanical, and biological treatments conducted under this alternative would have minimal temporary 

impacts (such as soil disturbance from grubbing) and the long-term benefit of controlling the spread of noxious 

weeds and their effects on the values that the special designations are intended to preserve. The BLM currently treats 

approximately 950 acres of noxious weeds in special areas using these methods (Table 4-24), without compromising 

area objectives. Weeds within and adjacent to special areas that can only be effectively treated with herbicides (2/3 

of the noxious weeds species, see Appendix 7: Table A7-1) are not likely to be eradicated with these treatments. 

These species would threaten the special values of these important areas over the long term. 

It is projected that this alternative would result in an additional 2.7 million acres of BLM lands infested with 

noxious weeds in 15 years (see Table 4-4 in the Noxious Weeds and other Invasive Plants section in this Chapter) 

when compared with Alternative 2, No Action. This additional spread would negatively impact special areas. 

This adverse effect would occur even if weed treatments were a priority in these areas, because increases in weeds 

in surrounding areas would increase the likelihood that special areas would become infested in spite of treatments. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Herbicide and non-herbicide treatments would have minimal temporary impacts (such as soil disturbance from 

grubbing) with the long-term benefit of controlling the spread of noxious weeds and their effects on the values 

that the special area designations are intended to preserve. The BLM currently treats approximately 950 acres of 

noxious weeds in special areas using manual, mechanical, and biological methods and approximately 2,700 acres 

of noxious weeds using herbicides (Table 4-24) without compromising area objectives. These treatments have the 

long-term benefit of reducing noxious weeds within the special area and preventing them from spreading beyond 

the special area. 

Under Alternative 2, the BLM is limited to the use of four active herbicide ingredients: dicamba, picloram, 2,4-D, 

and glyphosate. The dozen noxious weeds that can only be effectively controlled using other active herbicide 

ingredients (Appendix 7: Table A7-1) are not likely to be effectively controlled under this alternative. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

All treatments in these areas would have minimal temporary impacts (such as browned vegetation from herbicide 

treatment and soil disturbance from grubbing) with the long-term benefit of providing better control of the spread 

of noxious weeds and their effects on the values that the special designations are intended to preserve than the No 

Action Alternative. 

With a broader array of herbicides available under this alternative, the BLM would have the opportunity to 

substitute more effective and/or selective herbicides for those currently being used in special areas. This would 

result in a reduction in short-term effects to non-target species in these special areas because treatments would 

be more effective and thus less likely to need repeating, and the additional herbicides generally require lower 

quantities to be effective. This broader array of herbicides also allows for the use of an herbicide to treat weeds 

that currently go untreated due to a lack of effective control. As a result, there would likely be an increase in acres 

of special areas treated under this alternative. There would be short-term effects from the herbicide treatments 

conducted under this alternative (such as the browning of the targeted vegetation) and a long-term benefit of better 

reducing the rate of weed spread within these special areas when compared with the No Action Alternative. 

Under this alternative, the number of acres infested with noxious weeds on BLM lands in Oregon is projected to 

be 1.9 million acres less than under the No Action Alternative in 15 years, and be spreading at a rate of 7 percent 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

(compared to 12 percent for the No Action Alternative). This reduced rate of spread and the ability to utilize 

herbicides that are more target-specific and require lower doses when compared to the No Action Alternative 

would result in less short-term disturbance (from both spraying and non-herbicide methods) to non-target species, 

as well as increased long-term benefits to native vegetative communities in these special areas. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

The effects to wilderness and other special areas associated with the treatment of noxious weeds, invasive weeds, 

and pests and diseases are the same as noted under Alternative 3 except that the broader array of herbicides 

available results in an even slower weed spread (6 percent annually, half of current rate and more acres 

protected) which will benefit all BLM administered lands, including special areas. Under Alternative 4, there 

is the additional opportunity to use herbicides to treat native vegetation in an effort to achieve goals specified in 

approved Recovery Plans, Conservation Strategies, or Conservation Agreements for Federally Listed or Bureau 

Sensitive species and to meet safety and operation objectives in administrative sites, recreation sites, and rightsof-way. Should any of these treatment opportunities present themselves in a specially designated area, the 

treatment would need to be consistent with, and conform to, the special requirements and management objectives 

for that area, and treatments having the potential to negatively impact the unique values of the special area over 

the long term would be unlikely. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

The effects to wilderness and other special areas under this alternative would be the same as those for Alternative 

4 except as follows. Alternative 5 expands the opportunity to treat native vegetation provided under Alternative 

4 to include any treatment that meets non-commodity management objectives (e.g., treating native vegetation to 

promote native plant communities, reduce the risk of wildfire and improve fish and wildlife habitat). Should any 

of these treatment opportunities present themselves in a specially designated area, the treatment would need to be 

consistent with, and conform to, the special requirements and management objectives for that area. Treatments 

that had the potential to negatively impact the unique values of the special area over the long term would be 

unlikely. The amount of difference between Alternative 4 and 5 is not quantified, but is not likely to reduce the 

annual spread rate an entire percentage point. 

Recreation/Interpretive Sites 

Affected Environment 

Public lands in Oregon provide visitors with a wide range of recreational opportunities, including hiking, fishing, 

camping, horseback riding, hunting, cross-country skiing, boating, hang gliding, OHV driving, mountain biking, 

birding, viewing scenery, and visiting natural and cultural heritage sites. Recreation settings include evergreen 

forests, high deserts, lava flows, rugged river canyons, coastal headlands, and whitewater rapids (USDI 2007d). 

Combining these natural wonders with the multitude of cultural destinations such as historic trails and archaeological 

sites makes Oregon public lands some of the most diverse and exciting in the United States (USDI 2007d). In Fiscal 

Year 2007, there were 8,337,627 recreation visits to BLM public lands and waters in Oregon (USDI 2007d). 

The presence of noxious, invasive, and undesirable vegetation (such as poison oak) has the potential to negatively 

affect the recreational experience of visitors to public lands. At the same time, recreational pursuits themselves 

269 
 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

have the potential to inadvertently introduce these forms of vegetation to public lands. A key component of 

BLM’s integrated vegetation management strategy is raising public awareness of the threats of noxious weeds 

and other invasive plants and including prevention techniques on such things as maps, brochures, informational 

kiosks, and interpretive signage at trailheads. 

Following is an overview of the primary ways in which BLM classifies the recreation opportunities found on 

BLM public lands and the types of vegetation treatments associated with those classifications. 

Recreation Management Categories 

Dispersed Sites 

The majority of BLM lands in Oregon are managed to accommodate multiple uses including many forms of dispersed 

recreation (e.g., horseback riding, hiking, nature viewing, and hunting), with basic access to these lands provided, 

and general information such as maps and brochures available, to recreationists. Visitors generally have the freedom 

of recreational choice with minimal regulatory constraints. Vegetation treatments occurring in these areas would be 

designed to meet the various vegetation objectives outlined in the Resource Management Plan for the area. 

Some areas such as Wild and Scenic Rivers, parts of the National Trail System, and Wilderness Areas have 

restrictions or special emphases that may limit or focus the types of recreation taking place. Vegetation 

management in these areas is more likely to be directed at the recreation-oriented designation, and require 

selective vegetation treatments to protect visitors from hazards and/or adverse effects associated with certain 

plants in order to maintain and protect the special and unique features of the area. 

Developed Sites 

The other significant components of BLM’s recreation program are developed recreation sites, designated trails, 

and interpretive facilities. In Oregon, there are 30 developed campgrounds, 35 developed picnic areas, 31 

developed recreation trails, 8 off-highway-vehicle (OHV) sites with staging and parking areas, 2 hang gliding 

sites, 47 “Watchable Wildlife” viewing/interpretive sites, 17 “Adventures in the Past” cultural interpretive sites, 2 

wild horse viewing sites and 15 Backcountry Byways totaling 876 miles. The level of development varies widely 

among these different sites and designated areas, but in general, the vegetative management objectives focus on 

protecting visitors from hazards and/or adverse affects associated with certain plants and involves the control 

of noxious weeds and other invasive plants. Removal of undesirable vegetation such as poison oak to protect 

visitors, maintain the appearance and function of the site, and prevent the degradation of BLM improvements 

(such as buildings and parking lots) also takes place in developed recreation sites. 

Environmental Consequences 

Recreationists involved in both dispersed recreation activities (such as hunting, horseback riding and fishing) as 

well as those that visit developed recreation sites (such as campgrounds and hiking trails) have the potential to 

unwittingly transport undesirable weed seeds to public lands through such things as their vehicles, their clothing, 

and the use of weed infested feed for their horse or burro. Since recreation sites and recreational activities can be 

a gateway for weeds, the BLM emphasizes prevention and education to help reduce the risk of weed spread and 

also works diligently to eradicate weeds as soon as they are discovered through a variety of treatment methods 

including manual, mechanical, and biological methods and the use of herbicides. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Effective treatment of noxious, invasive and undesirable vegetation not only helps prevent the spread of these 

species on public lands it also enhances the recreational experience and opportunities of public land visitors. 

Noxious weeds crowd out native vegetation, altering the natural landscape and diminishing the visual appeal of 

such recreational pursuits as hiking and nature viewing. 

Effects Common to All Alternatives 

Vegetation 

A site that is dominated by noxious weeds would diminish the habitat for native fish and wildlife species which 

in turn diminishes the opportunities for those who enjoy such pursuits as wildlife viewing, fishing, and hunting. 

Certain types of vegetation are also injurious to humans such as yellow starthistle (noxious weed) and poison oak 

(native vegetation). The dominance and spread of noxious weeds such as Himalayan blackberry can also limit 

recreation access to such things as campgrounds, trails, and rivers. Weedy landscapes would also be esthetically 

less pleasing, discouraging recreational use and causing recreationists to go elsewhere. 

Vegetation Treatments 

Control treatments for invasive and unwanted vegetation also have an effect on recreation. For example, the noise 

associated with mechanical methods of treatment may adversely impact the recreational experience of a public 

land visitor as can closures that occur to allow the activity to take place. With the use of herbicides, there would 

also be closure effects. Generally, access is restricted for a few hours or days, depending on the requirements on 

the herbicide label, but there is the potential for a closure to last at least one full growing season or longer to allow 

native vegetation to recover following treatment. During site closures, signs would be posted stating the herbicide 

used, the date of application, and a contact number for more information, and remain in place for a period of 

at least 2 weeks following treatment. The longer a site is closed, the greater the adverse effect to recreationists 

in terms of lost use days, particularly at sites that experience a higher volume of visitors. Dead and browned 

vegetation from herbicide treatments could also temporarily reduce recreational potential until vegetation 

recovered. Herbicide treatments could also pose some health risks to recreational users (see Human Health and 

Safety section). Unintended effects of herbicides on non-target plants, animals, and water could also impact 

recreation activities (e.g., hiking, plant collecting, hunting, and fishing). The risks to non-target species from use 

of the 18 herbicides are discussed in the Vegetation, Native Plants, and Plant Communities, Fish, and Wildlife 

Resources sections. 

Overall, vegetation treatments would have short-term negative effects and long-term positive effects on 

recreation. Prevention/removal of noxious weeds and other invasive plants would maintain/return public lands to 

a more “natural” or “desirable” condition, which hikers and nature enthusiasts would likely value over degraded 

lands. In addition, the increased aesthetic value of protected or restored sites would benefit most recreational 

users. In some instances, treated sites could become more desirable as destinations for outdoor activities, making 

them more popular to recreational users. Treatment of sites to protect or restore native vegetation would enhance 

fish and wildlife habitat, to the benefit of hunters, birdwatchers, and other users of these resources. 

Effects by Alternative 

Noxious weeds and other invasive plants negatively affect all recreationists regardless of the type of recreation 

they are involved in. As noted above, negative effects range from changes in visual quality, to displacement of 

native flora and fauna, to actual human injury from nettles and other plant defenses. Noxious weeds are projected 

to continue to spread on BLM lands in Oregon under all alternatives, but the rate of spread and thus the number 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

 272 

of acres infested in the next 15 years varies by alternative (Table 4-4). To the degree the alternatives would 

change that level of infestation, the negative effects to recreationists would be proportionately affected. The types 

and amount of vegetative treatments utilized under the different alternatives to address noxious, invasive, and 

unwanted vegetation would also affect recreationists and recreational opportunities on public lands. 

The following discussion of recreation effects by alternative highlights the degree to which the alternatives: 

• Effect dispersed recreation occurring on most BLM lands; and 

• Effect recreation in developed recreation sites. 

To provide context for this discussion, Table 4-26 provides approximate annual acres of vegetation treated within 

developed recreation sites and hiking trails by treatment method under existing conditions (Alternative 2 – No Action). 

(Currently, and under Alternative 2 – No Action, the BLM can only treat officially designated noxious weeds with 

herbicides, and is limited to the use of four herbicide active ingredients: dicamba, picloram, 2,4-D and glyphosate.) 

Alternative 1 – No Herbicide Use 

Dispersed Recreation 

Effects of Noxious Weeds and Other Invasive Plants: Under this alternative, an additional 2.7 million acres of 

public lands are projected to be infested with noxious weeds, and the rate of weed spread is estimated to be 14 

percent per year instead of 12 percent, when compared to the No Action Alternative. As the presence of noxious 

weeds increases in dispersed recreation areas, their recreation potential decreases. Resultant adverse effects 

would be as described under Effects Common to All Alternatives; weed-caused reductions to fish and wildlife 

would diminish wildlife viewing, fishing, and hunting; weeds would limit access and cause injuries, and weeds 

would generally lower the esthetic value of the recreational experiences – all proportional to the number of acres 

infested under this alternative. 

Effects of Treatments: The nearly 50 percent increase in mechanical treatments projected under this alternative, 

when compared to the No Action Alternative, would have the effect of such things as noise from the use of 

chainsaws and potential area closures for public safety during actual work. The effects on dispersed recreation 

would be short-term in nature. There are no anticipated short-term effects to dispersed recreation from the other 

Table 4-26. aPProximaTe annUal acres of vegeTaTion cUrrenTly TreaTed WiTHin develoPed recreaTion 

siTes and Hiking Trails by TreaTmenT meTHod (alTernaTive 2 – no acTion) 

Method 

Watchable 

Wildlife 

Viewing 

Wild 

Horse 

Viewing 

Developed 

Campgrounds 

Developed 

Picnic 

Areas 

Boat 

Ramps 

OHV 

Staging / 

Parking 

Areas 

Hang 

Gliding 

Sites 

Developed 

Hiking 

Trails Total 

Acres of Noxious Weed Treatment – Alternative 2 – No Action 

Herbicides 1 207 8 37 30 57 340 

Manual 10 360 32 17 19 1 74 513 

Mechanical 22 15 13 15 1 30 96 

Biocontrol 5 1 1 7 

Acres of Invasive Plant Treatment – Alternative 2 – No Action 

Manual 46 23 9 7 1 54 140 

Mechanical 100 4 170 21 11 10 1 33 250 

Acres of Native Vegetation Treatment – Alternative 2 – No Action 

Manual 4 45 25 9 5 1 58 147 

Mechanical 2 218 10 9 6 1 32 278 
 

 

 

 

 

 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

forms of treatment available under this alternative (manual, biocontrol, and livestock). Prescribed fire effects to 

users (smoke, area closures) would be less under this alternative than under No Action. 

Developed Recreation 

Effects of Noxious Weeds and Other Invasive Plants: Without herbicides, noxious weeds would be more likely to 

infest developed sites than under the No Action Alternative (Table 4-4). Further, about 2/3 of the noxious weeds 

in Oregon cannot be effectively controlled with non-herbicide methods (Appendix 7: Table A7-1), so some weeds 

would not be effectively controlled at all. Either these acres would be treated using another, potentially less 

effective, form of treatment or these areas would go untreated. The resulting presence and spread of noxious weeds 

in these areas would diminish the recreation potential of the site over the long-term, and could lead to site closures. 

Effects of Treatments - Under Alternative 1, most of the 340 acres of noxious weeds currently treated annually 

in developed sites with herbicides would be attempted with non-herbicide treatments, even if they were known 

to be less effective. Disturbance impacts and risks to user publics are probably lower with these treatments 

than with herbicides (in part, because herbicide uses can result in seasonal or area closures), although such a 

generality would not apply in all cases. Also, the BLM already treats approximately 513 acres of noxious weeds 

in developed recreation sites using manual methods, approximately 96 acres using mechanical methods, and 

approximately 7 acres using biological methods (Table 4-26). The BLM also treats up to 100 acres of invasive 

plants and approximately 400 acres of native vegetation (including poison oak) in developed sites annually with 

non-herbicide methods (Table 4-26). The mechanical and manual methods of control would result in short-term 

effects to recreationists (noise from the use of mechanical equipment and potential access restrictions while the 

weeds are mowed, cut, or pulled). However, most of these effects are happening currently, and the net effect of 

increasing non-herbicide treatments and decreasing herbicide treatments would likely be a reduction of adverse 

effects to user publics. (There are no anticipated short-term effects associated with the use of biological controls 

to developed recreation.) 

For both dispersed and developed recreation, the lack of herbicide use under this alternative eliminates any 

potential for accidental exposure to herbicides by recreationists. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Dispersed Recreation 

Effects of Noxious Weeds and Other Invasive Plants - Under this alternative, the rate of weed spread would be 

expected to remain at 12 percent per year and noxious weeds are projected to infest about 1/3 of all BLM lands in 

Oregon in 15 years. As discussed under Alternative 1, the presence of noxious weeds has the potential to effect 

recreation in dispersed areas and therefore, the degree to which each alternative reduces the threat of noxious 

weeds results in a benefit to dispersed recreation activities. 

Effects of Treatments - The use of herbicides under this alternative would result in temporary use restrictions 

that could affect dispersed recreation. These restrictions would typically last 24 hours but could be as long as 

one to two years to allow for native vegetation to become established. The use of herbicides also results in 

dead and browned vegetation that might result in short-term visual impacts that adversely affect the recreational 

opportunities of a treatment area. The use of herbicides under this alternative could also result in accidental 

exposure to the herbicide by recreationists (see the Human Health and Safety section). 

The effects of mechanical, manual, fire, biocontrol, and livestock treatments under this alternative are essentially 

the same as those for Alternative 1. 

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Developed Recreation
 

Effects of Noxious Weeds and Other Invasive Plants - Developed sites would be affected by the current weed 

spread rate; the potential for weeds to invade developed sites would continue to increase exponentially as 

surrounding landscapes become infested. However, this alternative provides effective treatment methods for all 

but about a dozen of Oregon’s noxious weeds, so noxious weed control efforts focused on weeds in developed 

sites would generally be successful.
 

Effects of Treatments - Under Alternative 2, most noxious weed control in developed recreation sites occurs using 

manual methods (approximately 513 acres). Approximately 340 acres would be treated using herbicides, 96 

acres using mechanical methods and approximately 7 acres would be treated using biocontrols (Table 4-26). The 

mechanical and manual methods of control would result in short-term effects to recreationists (noise from the 

use of mechanical equipment and potential access restrictions while the weeds are manually pulled or grubbed). 

There are no anticipated short-term effects associated with the use of biological controls to developed recreation. 

The effects of treating noxious weeds with herbicides under this alternative includes temporary closure of the site 

or trail in accordance with the herbicide label instructions, the presence of browned and dead vegetation after the 

treatment, and the potential for accidental exposure to the herbicide by recreationists (see the Human Health and 

Safety section for more information).
 

Like Alternative 1, all treatment of invasive and unwanted native vegetation consists of manual and mechanical 

treatments (Table 4-26) and the effects of these treatments under this alternative would be the same as under Alternative 1.
 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Dispersed Recreation 

Effects of Noxious Weeds and Other Invasive Plants - Under this alternative, the rate of weed spread would 

decrease to an estimated 7 percent per year compared to 12 percent under the No Action Alternative. Under 

Alternative 3, 1.9 million fewer acres are projected to become infested in 15 years than under the No Action 

Alternative. As discussed under Alternative 1, the presence of noxious weeds has the potential to effect recreation 

in dispersed areas and therefore, the degree to which each alternative reduces the threat of noxious weeds results 

in a benefit to dispersed recreation activities. Additional benefits beyond the reduced spread rate include: 1. The 

broader array of herbicides available allows for the treatment of those noxious weeds that can only be effectively 

controlled using one of the herbicides available under this alternative and therefore the reduction of those weeds 

will improve the health and ultimately the recreation potential of those areas; and, 2. Invasive (non-noxious) 

vegetation could be treated using herbicides. Treating areas after a wildfire to prevent the establishment of 

invasive plants such as cheatgrass and medusahead will help ensure that those areas support native vegetation as 

they recover and this in turn will help those areas support recreational opportunities and activities. 

Effects of Treatments - The effects to dispersed recreation from all methods of treatment would be essentially 

the same as described under Alternative 2 except that the additional herbicides (above the four available under 

the No Action Alternative 2) would often allow the use of an herbicide that is more target specific and generally 

less toxic to humans, and more effective in lower doses, thereby reducing the impacts of herbicide use on the 

recreational resource and reducing the chance for accidental exposure to recreationists. Also, the use of herbicides 

to treat invasive vegetation would likely result in additional closures and additional acres of browned and dead 

vegetation, both of which can impact recreation opportunities and experiences. 

Developed Recreation 

Effects of Noxious Weeds and Other Invasive Plants - The effects of treating noxious weeds in developed 

recreation sites and trails would likely be very similar to effects listed under Alternative 2 (No Action) with 

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several exceptions. The ability to treat the dozen noxious weeds that cannot be effectively treated under the 

No Action Alternative could help prevent those species from adversely affecting developed recreation sites and 

trails. Also as with dispersed recreation under this alternative, the availability of more effective herbicides has the 

potential to improve treatment effectiveness. However, with a broader array of herbicides available, an herbicide 

may be used in place of mechanical and manual treatments if it is thought to be a more effective method of 

treating a noxious weed in the developed recreation site or trail. 

Effects of Treatments - As noted under dispersed recreation discussion, this alternative could result in the use of 

herbicides to treat invasive vegetation in developed recreation sites and trails. Currently, 140 acres of invasive 

vegetation are being treated using manual methods and 250 acres are being treated using mechanical methods in 

developed recreation sites and trails. With the opportunity to use herbicides, some of these acres would likely be 

treated using herbicides and it is also likely that additional acres, that currently go untreated due to a lack of an 

effective method, would be treated using herbicides under this alternative. The effects of the additional herbicide 

use would be short-term recreation effects such as those associated with closures, browned vegetation, and 

potential for accidental exposure to herbicides. The availability of additional herbicides would reduce the amount 

needed (per acre), the need for retreatment, and the effects to non-target vegetation. It is anticipated that manual 

method of treatment would continue to be the primary form of treatment of noxious weeds in recreation sites, and 

that the acres treated and the associated effects from both manual and mechanical methods would be very similar 

to those under Alternative 2. 

As under Alternative 1 and 2, unwanted native vegetation would continue to be treated using manual and 

mechanical methods, and therefore the effects of those treatments would be essentially the same as described for 

those alternatives. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

The effects to both developed and dispersed recreation under Alternative 4 are very similar to those found under 

Alternative 3 with the following exceptions. 

Dispersed Recreation 

Alternative 4 allows for the use of a slightly broader array of herbicides, which would provide the BLM with 

greater flexibility in the treatment of both noxious weeds and other invasive plants, weeds and as a result there 

may be additional acres treated both dispersed and developed recreation sites and trails. This would result in 

additional short-term closures of these areas, the presence of browned and dead vegetation, and an increased risk 

of accidental exposure to herbicides all of which potentially detract from the recreation experience and recreation 

resources. However, the long-term benefit from this broader array of herbicides would result in an estimated 

annual rate of noxious weed spread of 6 percent (which is lower than the 7 percent estimated for Alternative 3), 

and 2.2 million fewer acres infested in 15 years on BLM lands in Oregon when compared to Alternative 2. The 

maintenance of healthy, native, and diverse vegetative communities that result from this lower rate of weed spread 

benefits recreation resources over the long-term. 

Unlike Alternative 3, Alternative 4 also allows for the treatment of native vegetation with herbicides in an 

effort to improve habitat for Federally Listed species. These types of treatments could benefit dispersed 

recreation opportunities such as wildlife viewing, hiking, and hunting by promoting more natural conditions for 

plants and wildlife. 

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Developed Recreation 

The other primary difference in recreation effects when comparing Alternatives 3 and 4 involves the ability to 

treat native vegetation in developed recreation sites such as poison oak using herbicides. These treatments would 

increase the effects of short-term area closure, the presence of browned and dead vegetation and an increased risk 

of accidental exposure to herbicides. The ability to treat unwanted native vegetation would result in short and 

long-term benefits to the recreation site and trail by improving access, protecting BLM improvements (signage, 

restrooms, parking lots), and reducing the chance of recreationists being exposed to injurious native vegetation 

such as poison oak. With the ability to use herbicides to treat native vegetation in developed recreation sites there 

would be a corresponding reduction in the amount of manual and mechanical treatments and therefore the effects 

from those activities would be reduced. Also, the use of herbicides once may decrease the number of treatments 

that need to take place when using mechanical and manual methods. 

It is anticipated that the additional treatment methods proposed under this alternative would also help reduce 

the threat of noxious weeds and provide long-term benefits to both dispersed recreation activities and developed 

recreation sites. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

The effects to both developed and dispersed recreation under Alternative 5 would be the same as described for 

Alternative 4 with the following exceptions. 

Alternative 5 permits the use of herbicides for general habitat improvement, fuels treatments, and other noncommodity vegetation management. An additional 4,900 acres of herbicide treatments are expected to occur 

under this alternative. These types of treatments could have additional short-term negative impacts to dispersed 

recreationists from site closures, and long-term benefits from improved wildlife viewing, hiking, and hunting from 

improved conditions for plants and wildlife. 

Alternative 5 also allows for the use of a slightly broader array of herbicides when compared to Alternative 

4. This would provide the BLM with greater flexibility in the treatment of noxious, invasive, and unwanted 

vegetation and may result in different herbicides being applied in dispersed and developed recreation sites and 

trails. However, the overall acres of noxious weeds and other invasive plants treated would be about the same as 

under Alternative 4, so changes in effects to recreationists would be negligible. 

Administrative Sites, Roads, and Rights-of-Way
 

Affected Environment 

This section addresses vegetation management around administrative sites63, roads, and rights-of-way (referred 

to herein as “developments”) for the purposes of maintaining and protecting infrastructure developments and 

providing for their safe and efficient designed use. Developments addressed here include those owned and 

managed by the BLM, as well as those owned and managed by private individuals, companies, districts, city/ 

county/state governments, and other Federal agencies and occupying BLM lands under permit or other written 

63 Administrative sites include various developed recreation sites, which are discussed in additional detail in the 

Recreation/Interpretive Sites section in this Chapter. 

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agreement. They include but are not limited to: 

•		 Linear utility transmission systems and pipelines, including multi-purpose corridors; 

•		 Road or railroad rights-of-way; 

•		 Oil and gas production or gas storage agreement areas and facilities; 

•		 Geothermal, wind, or solar energy production areas and facilities; 

•		 Pumped storage hydro-power production areas and facilities64; 

•		 Common-material or rock quarry pits and storage areas (primarily to ensure invasive weeds are not spread 

with the material); 

•		 Federal, State, local or tribal designated fire suppression equipment sites and staging areas including 

helispots; 

•		 Cell phone, microwave, and other communication sites; 

•		 BLM seed orchards and progeny test sites; 

•		 Public purpose lease areas, including airstrips, schools, parks, etc. ; 

•		 Interagency special management areas (e.g. reservoirs, military training, etc.); 

•		 Watchable Wildlife, Adventures in the Past, Wild Horse Herd Viewing, Outstanding Natural Areas and 

other BLM designated interpretive sites; 

•		 BLM offices, fire stations, and other facilities; 

•		 Developed campgrounds, picnic areas, trails, overlooks, OHV play staging or parking areas, hang-gliding 

areas and boat facilities; and, 

•		 Other administrative and operational sites needed for wildfire suppression, law enforcement, search and 

rescue, inventory, research, resource monitoring or other authorized administrative uses. 

Vegetation is currently managed around and/or within these sites to prevent undesirable plant species from 

growing into, against, or through developments such as buildings, power lines, and roads; to reduce fuels so 

wildfire will not damage developments such as microwave towers and transformer stations; to reduce fuels so 

fires starting within the developments do not escape onto surrounding wildlands; to remove vegetation interfering 

with road sight distances or the safe use of developed recreation sites; and, to facilitate their designed use such 

culturing activities needed to establish, maintain, and access trees within seed orchards or progeny test sites. In 

general, this vegetation management 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 an approved method for vegetation management in or around these sites. 

The following categories of developments are helpful to this analysis. 

Government Facilities and Roads 

The BLM operates or oversees operation of diverse facilities on public lands.65 These include: 

•		 Designated BLM road systems, rock quarries or pits and bulk material or equipment storage sites; 

•		 Buildings, administrative sites and other government facilities, including leased sites and BLM (sole use) 

communication facilities, remote weather stations, water wells, etc.; 

64 As of July 2009, there are no approved wind, solar, or pumped storage facilities on Oregon BLM lands, but such 

projects might be developed in the future. A proposal may be approved on the Baker Resource Area later in the 

summer. 

65 Some BLM roads and other developments not on BLM lands are also included in this discussion. 

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• Seed orchards and progeny test sites or cottonwood gallery production sites. 

Construction and operations disturbance can often introduce noxious weeds and other invasive vegetation to 

facility sites and roads. However, most vegetation management at facilities focuses on controlling vegetation that 

can pose a health, safety, or fire hazard, contaminate materials, or interfere with site operations. 

Government Roads, Quarries, Rock Pits, Bulk Material, and Equipment Storage Sites - There are approximately 

23,000 miles of BLM managed roads in Oregon including mainline, collector and administrative roads and spurs 

(USDI 2007d). All components are managed to meet transportation system objectives, including maintaining roadside 

vegetation to minimize wildfire hazards, optimize driver line-of sight for safe operations and provide access to various 

informational signs or kiosks. In addition, there are non-system roads, ways, and user-created access routes, which 

are normally not subject to routine annual maintenance. Generally only noxious weed and other invasive plant 

management is anticipated for non-system roads. 

BLM road systems require substantial quantities of “pit-run” or unprocessed rock material and crushed and graded rock 

to surface, maintain, and stabilize roads and related structures. BLM also provides nearby owners and State and local 

governments with common material to minimize overall road system management costs and increase efficiency and 

safety of travel. In some instances, material is stockpiled or pre-positioned for future use. It is estimated there are 300 

rock pits or quarries and an additional 300 material stockpile or other road-system related storage sites. These sites are 

usually maintained free of most vegetation to enhance site operations and safety and to minimize the production and 

distribution of invasive weed seeds from the quarry, pit, or storage site to the road system. 

Buildings, Administrative Sites, and Other Government Facilities - These include seasonal fire stations, BLM 

managed airstrips and helipads, corrals, water source developments, sanitary systems, BLM-only communication 

sites, and remote automated weather stations. Small radio repeater stations are often required to extend the “line 

of sight” for radio transmissions into remote and rugged terrain. Often these facilities are co-located with other 

BLM structures or sites managed in common with other low power communication systems, such as Rural Fire 

Districts, County Sheriffs, Oregon State Police, etc. 

Public Purpose (R&PP) Leases and Jointly Managed BLM Managed Lands – About 40 parcels totaling over 

7,000 acres are under long-term lease or cooperative management agreements to local governments. These 

include parks, schools, solid waste transfer stations, and highway equipment maintenance or bulk materials 

storage. They also include airport buffer zones or options for future site expansion that do not require active 

vegetative management at this time. BLM also jointly manages lands with other Federal agencies, including dams 

and recreation areas around reservoirs managed with the Corps of Engineers, and training areas and radar sites 

managed with the Department of Defense. It is possible the Oregon Air National Guard, the Air Force, and some 

Oregon County Sheriff’s departments have pre-identified road junctions or other suitable locations for medicalevacuation landing sites, especially in areas with frequent search and rescue operations. 

Seed Orchards and Progeny Test Sites - The Oregon BLM manages four seed orchards in Clackamas, Lane, 

Jackson, and Josephine Counties. The seed orchards provide genetically improved Douglas-fir and sugar pine 

seed and seedlings for reforestation and a variety of land management activities. Additionally, the orchards are 

involved in cooperative agreements with private timber companies and nurseries to provide seed in return for 

commensurate payment for operational and management costs. All have current NEPA analysis and management 

plan/RODs (USDI 2005a, b, c, 2006a, b) with identified needs and opportunities for the use of up to five 

herbicides66 to control unwanted vegetation inside fenced, access-controlled, posted sites. The Forest Service 

66 dicamba, glyphosate, picloram, hexazinone, and triclopyr 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Dorena Genetics Resource Center is also on BLM lands and has an existing NEPA document addressing the use 

of glyphosate (USDA 1995a). In addition there are hundreds of progeny test sites; the Forest Service manages 

a seed orchard on BLM lands in Coos County, and the Prineville District manages a cottonwood “gallery” for 

production of riparian restoration seedling production. 

Rights-of-Way (ROWs) 

Under FLPMA and the Mineral Leasing Act provisions, the BLM issues right-of-way grants to authorize the 

construction, operation, and maintenance of a wide range of projects on public lands. These include petroleum 

and natural gas pipelines, electrical transmission lines, telecommunications lines, energy development and 

distribution facilities, water facilities, (non-BLM) communication sites, and roads. Rights-of-way are issued for 

short-term use of public lands or in perpetuity. Right-of-way grants generally include provisions that authorize 

the holder to manage vegetation within and adjacent to the rights-of-way using methods approved by the BLM. 

Provisions also require adherence to applicable State and Federal laws and regulations concerning the use of 

herbicides and other pesticides. Prior to the use of such substances on or near the right-of-way, grantees are 

required to complete a written plan for approval by the BLM that specifies the type and quantity of material to be 

used, the pest to be controlled, the method of application, and other information as the BLM may require. All use 

of such substances on or near the right-of-way shall be in accordance with the approved plan. 

The scope and intensity of vegetation management treatments within rights-of-way are operationally specific and 

highly variable, and various vegetation management methods are used. Currently on non-BLM managed lands 

in Oregon, pre-emergence or post-emergence herbicides can be applied to prevent or control young emerging 

and existing vegetation. Mechanical methods, such as mowing, are also used on all ownerships to eliminate 

undesirable vegetation. In certain situations, livestock are used to selectively remove undesirable plant species, in 

a targeted approach. Both native and invasive vegetation can interfere with right-of-way site access and facility 

maintenance, interfere with electric power flow, and pose safety problems for workers and other users of the rightof-way. The development and maintenance of rights-of-way has significant impacts on vegetation. Maintenance 

of most rights-of-way in early seral vegetation exacerbates the potential for invasive plants; the relatively open 

nature of rights-of-way make them attractive to many recreationists including OHV enthusiasts, horseback riders, 

and hikers who can spread these plants within and away from the right-of-way. 

Permits or memorandums of understanding (MOUs) specify expectations and responsibilities for vegetation 

management. For example, the Federal government’s 2006 MOU with Edison Electric Institute regarding its 

transmission lines specifies reducing soil erosion and water quality impacts within the right-of-way by using best 

management practices; reducing the risk to human health, natural resources, and the environment by promoting 

the use of integrated vegetation management for maintaining vegetation near transmission and distribution lines; 

manage rights-of-way to maintain habitat and protect Federally Listed species; reduce the introduction and control 

the spread of invasive plants or noxious weeds; and, prevent wildfires (Edison Electric Institute et al. 2006). 

Vegetation management along many power line rights-of-way and other developments is addressed by existing, 

cooperatively written NEPA documents, and herbicide use proposed in those documents or their decision records 

is included on Table 3-3 for Alternatives 4 and 5. 

Petroleum and Natural Gas Leases, Pipelines, Access and Related Facilities – Natural gas pipeline and associated 

underground facilities are operated and maintained in accordance with 49 CFR 192, Transportation of Natural 

and other Gas by Pipeline: Minimum Federal Safety Standards, as required by the Department of Transportation. 

The only producing natural gas or petroleum field in Oregon is the Mist Field, located in Columbia and Clatsop 

Counties. This field is also used for seasonal underground storage of off-site-produced natural gas under a 

Federal gas storage agreement. Portions of major (10 inches or larger diameter) petroleum or natural gas regional 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

transportation pipelines cross BLM managed lands in Oregon, and can require vegetation control on a corridor 50 

feet wide. Vegetation along the permanent pipeline right-of-way is periodically maintained by mowing or cutting. 

Vegetation maintenance is a required periodic use of the federal lands crossed by the pipeline, and is included 

in the terms and conditions of the right-of-way grant. Generally, herbicides would not be used except for select 

treatment of nuisance vegetation or select use within above-ground facilities. No herbicides are used without 

the consent of the land-managing agency. Vegetation maintenance is conducted every 3-to-5 years, depending 

on vegetation growth rates. However, to facilitate periodic corrosion and leak surveys, a corridor not exceeding 

10 feet in width, centered over the pipeline may be maintained in a herbaceous state by annual maintenance if 

required. In addition, access routes and related facilities for monitoring, control, pumping, or compression may 

entail additional acreage. Generally, these related facilities would be fenced and devoid of any vegetation to 

reduce operational or fire safety risks. Current vegetation management, exclusive of noxious weed control, is 

limited to non-herbicide methods. 

Geothermal Energy Leases, Energy Generation, and Transmission - There are no producing geothermal energy 

leases on BLM managed lands in Oregon, although there are geothermal leases primarily in Deschutes and 

Klamath Counties. Geothermal energy conversion to electric power would require on-site development of 

pipelines, generation and other facilities, electric sub-stations and transmission lines. 

Railroads – Railroad rights-of-way cross BLM managed lands primarily in Baker, Deschutes, Douglas, 

Tillamook, and Union Counties. Rights-of-way also include maintenance access routes and related facilities for 

system monitoring, control, or material storage (often fenced). Generally, facilities are maintained devoid of any 

vegetation to reduce operational or fire safety risks. 

Electric and Telecommunications Transmission Lines – About 4,000 miles of electric transmission lines cross 

BLM-managed lands in Oregon. Major transmission systems are considered any line energized to 69 kilovolts 

or more and are generally designated as utility corridors through BLMs land use planning process. The interstate 

electric transmission system includes numerous lines that are operated at 230, 360, 500, or 750 kilovolts and 

require cleared rights-of way 200 feet wide and greater. Vegetation management standards are included in 

American National Standards Institute (ANSI) Standards A300-2001, Tree Care Operations – Tree, shrub and 

Other Woody Plant Maintenance – Standard Practices, and the conduct of vegetation control is covered in part by 

ANSI Z133.1-1994 for Tree Care Operations – Pruning, Trimming, Repairing, Maintaining, and Removing Trees, 

and Cutting Brush – Safety Requirements (Edison Electric Institute et al. 2006). Smaller local lines or distribution 

lines frequently cross BLM lands and are often associated with public roads and co-located with communications 

lines. Communication lines include metallic wire and fiber-optic cable telephone lines. Fiber-optic cables may be 

co-located on high-voltage towers or poles or buried in conduits parallel to power lines, railroads, or road rightsof-way. Transmission system maintenance access routes and related facilities for system monitoring, control, or 

voltage regulation or distribution sub-stations may entail additional acreage. Generally, these related facilities 

would be fenced and devoid of any vegetation to reduce operational or fire safety risks. 

Communication Sites - There are about one hundred authorized communication sites on BLM managed lands 

in Oregon, averaging about two acres per site. Some have vegetation management objectives covering as much 

as 200 acres to maintain line-of-sight for both radio and microwave technologies. Most sites are located on 

exposed ridgelines or other high topographic features and may be naturally devoid of deeper soils and taller or 

faster growing vegetation. Site maintenance access routes and related facilities for system monitoring, control 

or emergency operation fuel storage may entail additional acreage. Generally, these related facilities would be 

fenced and devoid of any vegetation to reduce operational or fire safety risks. 

Renewable Wind, Solar and Hydro Energy Generation and Transmission Facilities - There are no commercial 

operating wind or solar energy facilities on BLM lands in Oregon at this time. However, the BLM’s national EIS/ 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Record of Decision projected a long-term wind energy lease and development potential of 9,700 acres of BLM 

managed lands, of which ten percent or approximately 970 acres could be directly affected by access roads, tower 

sites and related ancillary land uses requiring regular vegetation treatments (USDI 2005e). Oregon’s currently 

untapped solar resources are significant with two-thirds of Oregon receiving as much or more annual radiation 

than Florida. The Oregon Department of Energy’s 2005 Renewable Energy Action Plan notes 100 megawattrange solar thermal electric facilities may be the preferred option for central solar power generating facilities in 

the future (ODEQ 2005:27). A University of Oregon Solar Radiation Monitoring Laboratory 2004 Solar Resource 

GIS Data Base report shows Lake, Harney, and Malheur Counties to have the highest levels of solar radiation 

in the State (SRML 2004:1). Various other energy proposals have been made, notably pumped storage power 

generation in Klamath County, and herbicide use may be considered in related future NEPA documents. 

Environmental Consequences 

This section addresses management of vegetation to maintain developments on BLM lands and provide for their 

safe use. Management of native vegetation to accomplish these objectives is already occurring in and around 

most or all administrative and developed recreation sites, roads, and rights-of-way (collectively referred to here 

as developments) using a variety of non-herbicide treatment methods such as mowing, flailing, tilling, hoeing, 

scraping, pulling, prescribed fire, directed livestock, hot water, covering, and others. Alternative 4 proposes to 

add herbicides to the methods available for these treatments. 

Effects by Alternative 

West of the Cascades, up to fifty percent of rights-of-way and other developments require native vegetation 

control each year depending upon the nature of the development and its level of use, with some portions of heavily 

used system roads getting vegetation treatment at least annually. Total native vegetation control in and around 

administrative sites, roads, and rights-of-way is estimated to be 10,000 to 15,000 acres per year.67 East of the 

Cascades, although gross acres of developments are four to five times what they are west of the Cascades, the need 

for annual maintenance is much lower and the annual vegetation control need is also estimated to be 10,000 to 

15,000 acres per year. 

Alternative 1 – No Herbicide Use; Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only; 

and, Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Under Alternatives 1 through 3, all management of native vegetation in and around developments would continue 

using non-herbicide methods. These methods include mowing, flailing, tilling, roller/crushing, hoeing, scraping, 

pulling, prescribed fire, directed livestock, covering, propane (or other fuel) burning, hot foam or steam, and other 

methods. Objectives of these treatments include: 

•		 protect developments from damage from plants such trees growing into wires or rubbing on buildings, and 

plants growing through pavements; 

•		 reduce flammable vegetation near developments, particularly those in remote areas such as microwave 

towers, to reduce the risk of damage from wildfire; 

•		 reduce flammable vegetation along roads and around drilling and other work sites to prevent sparks and 

other ignition sources from starting a wildfire; 

•		 remove vegetation interfering with road sight distances; 

•		 remove vegetation interfering with safe use of developed recreation sites such as poison oak; and, 

67 This work is so functionalized and spread across so many development owners that a more precise estimate would be difficult. The 

estimate is offered here only to provide a rough context for the Alternatives 4 and 5 proposed use of herbicides. 

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•		 to otherwise conduct the management the site is designed for, such as conducting culturing activities needed 

to establish, maintain, and access trees within seed orchards or progeny test sites. 

Where vegetation resprouts, treatments may need to be repeated two or three times per season. 

Under Alternative 1, all vegetation management needs in and around developments would be conducted with 

non-herbicide methods. Under Alternative 2, four herbicides would be available for treating noxious weeds only. 

Only an incidental portion of the above treatments would involve noxious weeds, so the use of herbicides under 

Alternative 2 would do very little to change the conduct or effectiveness of these treatments. In fact, it is common 

practice in some areas to treat noxious weeds along roadsides with herbicides, and then mow or otherwise treat the 

native vegetation on the same site. Under Alternative 3, more herbicides would be available, but their use would 

be limited to noxious weeds and other invasive plants. Along roads and around other developments where invasive 

plants such as cheatgrass create a fuels hazard, some fire protection objectives could be met with herbicides because 

invasive plants could be controlled with herbicides. 

Accomplishing this work without herbicides is practical; it has been done at least since 1984. As discussed in other 

sections of this EIS, however, there are drawbacks when compared to herbicide use. These drawbacks most notably 

include high cost and the higher likelihood that mowing and crushing equipment would spread invasive plants down 

the road and from site to site much more so than would spray equipment. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses and Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity 

Vegetation Management Objectives 

Alternatives 4 and 5 would make herbicides available to meet a portion of the vegetation management objectives in 

and around developments (see list under Alternatives 1 through 3, above). Herbicide use would replace, on a one-toone basis, acres currently treated with non-herbicide methods (Chapter 3). West of the Cascades, selective herbicides 

are generally used. For example, except for a couple of feet immediately adjacent to the pavement edge, roadside 

treatments west of the Cascades generally seek to reduce woody vegetation while maintaining roadside grasses and 

forbs in roadside drainage ditches to prevent erosion. East of the Cascades, one of several persistent pre-emergent 

herbicides may be used (Table 3-3) because the risk of erosion in the ditches is lower while the risk of a wildfire being 

started on a roadside is considerably higher, making complete clearing for 10 to 20 feet more desirable. 

Herbicides would be considered where they have operational advantages over non-herbicide treatments. For 

example, vegetation under power lines west of the Cascades can be converted to shrubs and forbs by chainsaw 

cutting trees and following with stump-applied herbicide treatments to keep them from resprouting. Herbicides 

would also facilitate the removal of low-growing vegetation without the damage to compacted fills and shoulders 

that could result from blading or other treatments. Also, as noted in the Noxious Weeds and Other Invasive Plants 

section in this Chapter, herbicides are likely to do less site disturbance, reducing the likelihood of infestation by 

invasive plants. Other potential advantages (and disadvantages) of using herbicides in rights-of-way, administrative 

sites, and recreation sites are discussed in other sections within this Chapter and include: 

•		 Herbicide use would reduce mowing and other potentially more visually disturbing treatments (see Visual 

Resources section). 

•		 Herbicide vegetation control would be less expensive than corresponding non-herbicide treatments (see 

Costs section). This is particularly true for owners of pipelines, transmission lines, and other linear 

developments where the owners are already using herbicides on non-BLM portions of the route. 

•		 On many sites, herbicide treatments can be safer for workers than the corresponding use of mechanical 

equipment like repeated use of chainsaws (see Human Health and Safety section). 

•		 Herbicide use on native vegetation would inadvertently kill noxious weeds not identified and controlled 

by noxious weed control crews, which is particularly important because roads are dispersal corridors for 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

noxious weeds, and access roads under power lines often attract OHV use, which is implicated in noxious 

weed spread (see Noxious Weeds and Other Invasive Plants section). 

•		 Because OHVs use power line and other access roads, herbicide exposure could increase for this user group. 

•		 Herbicide equipment would be less likely to move noxious weed seeds to other sites than other control 

methods (see Noxious Weeds and Other Invasive Plants section). These last two points are projected 

to inadvertently68 reduce noxious weed infestations by 300,000 acres over 15 years when compared to 

Alternative 3. 

•		 Herbicides would be less likely to start fires than most mechanical control treatments, particularly 

chainsaws. 

The potential for positive and negative effects to soils, wildlife, water, wetlands and riparian areas, human health, 

public perception (socioecomonic), and native plants are discussed in those sections. For example, roadsides 

include ditches and culverts that lead to streams. The potential for roadside sprays to enter those streams is 

considered in the Water Resources section. Similarly, the general application of herbicides to roadsides is 

considered by many publics to result in an unknown and unacceptable potential exposure to the humans (see Social 

and Economic Values and Human Health and Safety sections). 

SOPs, site-specific NEPA analysis, licensed applicators, and other restrictions would apply to all herbicide 

applications. For example, herbicides are not applied aerially over power lines because drift could not be adequately 

controlled while flying that high (although they may be applied by flying under power lines). In addition, stream 

and Bureau Sensitive species’ buffers suggested in the PEIS Mitigation Measures and finalized at the project level 

must be adhered to. Herbicide use in and around developments including those occupying BLM lands under permit 

or other agreement is subject to BLM approval. 

Seed Orchards and Progeny Test Sites – Herbicide use at the Horning, Tyrrell, Provolt, and Sprague Seed Orchards 

was proposed and examined in detail in a 2005 Integrated Pest Management EIS, and that use was subsequently 

approved in December 2005/2006 Records of Decision pending the lifting of the 1984/87 District Court Injunction. 

Five herbicides69 are proposed to be used in combination with non-herbicide methods for the control of noxious 

weeds, woody brush, and other vegetation along fence lines, roads, administrative buildings, buffer areas, competing 

vegetation around orchard trees, and for site preparation when establishing new seedlings. Herbicides would replace 

some of the work currently done with non-herbicide methods. For example, manual vegetation control along fence 

lines at the Tyrrell Seed Orchard is currently scheduled about every three years, and requires about 21 days for a 

10-person inmate crew to complete. An herbicide application covering the area would take 1-person a single day. 

This alternative also includes the use of glyphosate (and future site-evaluated herbicides) at the Forest Service 

Dorena Genetic Resource Center for noxious weeds, woody brush and vegetation along fence lines, roads and 

administrative buildings, and competing vegetation around orchard trees. The cottonwood gallery site at Prineville 

may need incidental herbicide use for vegetation maintenance. 

In general, herbicides are not required for vegetation control on the hundreds of first generation progeny sites; 

measurements are nearly completed and most are being managed as part of the surrounding forestland. However, 

Salem and Eugene BLM each have a 10-acre second-generation Douglas-fir site planted in 2001, and Coos Bay 

BLM has two 13-acre Douglas-fir sites planted in 2002. Control of selected brush and weed species on the Salem 

and Eugene sites may be beneficial for maintenance, but only minimal herbicide use is planned. Herbicides are not 

expected to be required on the Coos Bay sites. Proposed herbicide use in seed orchards and progeny sites totaling 

about 100 acres per year is included on Table 3-3, and the potential for adverse effects to water and other resources 

is addressed in those sections of this EIS. 

68 Inadvertently, because noxious weed control is not the stated objective of the native vegetation control treatments that 

would take place under Alternatives 4 and 5. 

69 dicamba, glyphosate, picloram, hexazinone, and triclopyr 283 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Social and Economic Values 

Affected Environment 

Use of resources and recreational visitation on BLM lands generates employment and income in the surrounding 

communities and counties. Revenues generated from these uses are returned to the counties and Federal treasury, 

or are used to fund additional activities to accomplish land management objectives. Similarly, resources flowing 

from BLM lands including water, fish, wildlife, and clean air affect surrounding communities and off-site 

resources. Additionally, less desirable elements like wildfire and invasive weeds can also affect surrounding 

communities. Herbicide use and other vegetation treatment methods on BLM lands affect these area resources 

and opportunities, and thus affect the adjacent communities. 

Analysis Area 

For this analysis, four economic areas from the U.S. Bureau of Economic Analysis (BEA)70 are used to divide 

the State into two broad areas composed of counties that fall on the east and west sides of the Cascade mountain 

range. Social and economic characteristics of Oregon make this division appropriate. The Interior Columbia Basin 

Ecosystem Management Project (ICBEMP) used the BEA’s economic areas for regional analysis (USDA 1998). 

These economic areas represent the relevant regional markets for labor, products, and information and are mainly 

determined by commuting patterns. This delineates local labor markets and also serves as a proxy for local markets 

where businesses in the areas sell their products (Johnson and Kort 2004). Four of these economic areas make up 

most of Oregon; west of the Cascades the Portland-Vancouver and Eugene-Springfield economic areas, and the 

Bend-Prineville and Pendleton-Hermiston economic areas are located east of the Cascades. While Curry, Klamath 

and Malheur counties make up portions of other economic areas, they can reasonably be considered as integrated 

with adjacent economic areas in Oregon for this analysis. Two analysis areas, one for each side of the cascades, 

logically combine economic areas, correspond to district boundaries, and separate areas with significantly different 

ecological settings, issues, and primary resource management objectives. Scoping comments, population density 

differences, and other factors also make this grouping appropriate from a social perspective. 

In the western half of the State, residents are likely to identify and place value in a variety of traditions, cultures, and 

ways-of-life within both urban and rural areas. Communities in the growing urban centers of the Willamette Valley 

and SW Oregon value public land for recreational, commodity, and non-commodity uses. Outside of these urban 

areas agricultural traditions are valued and a part of the culture of many Oregonians. In more rural areas of the 

Cascade Mountain foothills, the Coast Range and along the coast, timber, and fishing traditions are valued culturally. 

In the eastern half of the State, residents also identify and place value in a variety of traditions, cultures, and waysof-life within the growing urban areas and steadfast rural communities. Along the Columbia Plateau residents 

identify with farming traditions more than grazing or timber. In the Northeastern portion of the State residents are 

outdoor-oriented in work and play which remains a key value in local communities and an amenity that attracts 

newcomers. Grazing and timber traditions are also a source of cultural identity in this area (JKA 2006). As noted 

above, pockets of growing urban areas also exist throughout Oregon’s east side where residents identify and place 

value in a variety of cultures. Regardless of whether a community is west or east side or can be classified as 

urban or rural, Oregonians value natural resources and the outdoors at some level. Whether through traditional 

70 The Bureau of Economic Analysis (BEA) is an agency in the United States Department of Commerce that provides 

important economic statistics including the gross domestic product of the United States. Its stated mission is to 

“promote a better understanding of the U.S. economy by providing the most timely, relevant, and accurate economic 

data in an objective and cost-effective manner.” 

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figUre 4-7. PoPUlaTion cHange for oregon and coUnTies easT and WesT of THe cascades 

285 

(soUrce: Us deParTmenT of commerce 2005) 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

industry, recreation, or with a preservation ethic, communities see the landscape as an important part of what it 

means to be an Oregonian. 

Population and Demographic Change 

In 2005, the State of Oregon had a total population of 3,629,959 people with 3,148,960 (85 percent) and 480,999 

(15 percent) west and east of the Cascades respectively. Population growth from 1970 to 2005 on both sides of 

the Cascades was faster than the 45 percent national average. Over this period, the State population grew by 72.4 

percent west of the Cascades and 75.7 percent east of the Cascades (Figure 4-7). 

Oregon had an overall population density of 38 people per square mile in 2005. Population density within Oregon 

varies widely, with the lowest county population density at 0.7 people per square mile in Harney County and the 

highest county population density at 1,560 people per square mile in Multnomah County. 

Population density does not indicate if the people living in the area are in more urban or rural areas. The U.S. 

Census Bureau classifies urban areas and their populations. In the year 2000, populations in counties west of 

the Cascades were 82 percent urban and 18 percent rural. Of the 82 percent, 65 percent were classified as being 

inside urban areas while the remaining 17 percent were inside urban clusters (census blocks that have a population 

density of at least 1,000 people per square mile and surrounding census blocks have an overall density of at least 

500 people per square mile), demonstrating a predominantly urban population. 

East of the Cascades, populations were 58 percent urban and 42 percent rural. Of the 58 percent classified as 

urban only 13 percent were actually classified as being inside urban areas while the remaining 45 percent were 

inside urban clusters, demonstrating the east side contains pockets of urban populations (US Census Bureau 

2000a) across a predominantly rural landscape. 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Economic Specialization 

It is expected that communities that are particularly dependent on a single, resource-dependent industry would 

be more susceptible to the differences between the alternatives than other communities. In particular, ranching 

and recreation-dependent communities may be more affected than more diversified communities. Rural county 

population change, the development of rural recreation, and the development of retirement-destination areas are 

all related to natural amenities (Knapp and Graves 1989, Clark and Hunter 1992, Treyz et al. 1993, Mueser and 

Graves 1995, McGranahan 1999, Lewis et al. 2002). Many of the natural amenities in the area are managed by 

the BLM and thus, may indirectly contribute to specialization in rural areas. For example, elk hunting on BLM 

lands in the fall provides a significant injection of external dollars in some rural areas of Oregon. 

Perceptions, Values, and Concerns 

Oregonians’ awareness of the threat posed by invasive species to the landscape, and consequently to their values 

traditions, cultures, and ways-of-life, is increasing. Scoping for this EIS indicated a broad level of support for 

controlling invasive species on public lands. In 2002, the Oregon Invasive Species Council was created by the 

State Legislature and began working to raise public awareness of Oregon’s invasive species. One of the actions 

taken by the council was the creation of a hotline to ensure that the public could help in reporting of new exotics 

and invasive plants. Since its inception, the number of calls has increased each year (Statesman Journal 2007) 

indicating a potential increase in awareness and community engagement. 

The effects of Federal land management actions are likely to be most critical to small, rural communities (USDA 

2000a:5). Consequently, geographically defined communities are an important and relevant level for social 

assessment. Not all social scientists agree however, that the geographically based community is always the 

appropriate level of analysis. FEMAT (USDA et al. 1993:VII-35) makes the point that this view “only refers to 

physical or political boundaries and not to the relationships among people who reside within such boundaries.” 

Communities of interest transcend physical or political boundaries and can also be used to examine effects to 

rural communities. Communities of interest bring together stakeholders from different backgrounds to solve 

problems of common concern (Fischer 2001:4). Brown and Duguid (1991) describe communities of interest as 

“communities-of-communities.” They provide unique opportunities to explore the linkages between people and 

public land that may transcend the geographically defined community. 

The Environmental Consequences section identifies scoping-defined groupings based on perceptions, values, and 

concerns that address both communities of place and communities of interest as they relate to the Alternatives. 

Environmental Consequences 

Invasive plants affect BLM and surrounding lands in a variety of negative ways. Infestations can reduce 

recreational land values, and the spiny species can cause human health problems (DiTomaso 2000). For 

example, hunters and bird dogs are reluctant to use land infested with thistles, and weeds diminish the enjoyment 

of recreationists along trails and near campgrounds. Float boaters similarly have difficulty finding suitable 

campsites, and fishing along stream banks is often impossible because of the pain inflicted by thistles (Asher 

and Spurrier 1998). 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. 

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Similarly, the Livestock section in this Chapter identifies reductions in livestock carrying capacity of thirty-five to 

ninety percent from weed infestation. 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. In addition to impacts on forage for livestock, invasive plants have impacts on other commodity 

uses of BLM lands. West of the Cascades, scotch broom partially hampers reforestation efforts and reduces 

growth rates of surviving trees on some timber harvest units (Asher and Spurrier 1998). 

Management of invasive plants affects the goods, services, and uses provided by BLM lands. The analysis 

of social and economic effects considers market and non-market related values as well as effects to program 

areas and users of public lands. Direct and indirect effects to programs and BLM users are examined for each 

alternative in the context of community perceptions, values, and concerns. 

Concerns Raised During Oregon Scoping 

Many if not most of the comments received during the scoping period for this EIS in July 2008 reflect the 

perceptions, values and concerns of individuals, geographic communities, and communities of interest throughout 

Oregon. People’s feelings and ideas about herbicides are complex. The variety and detail of scoping comments 

is summarized here into three general categories that are subsequently examined across the range of alternatives. 

The categories are not intended to label individuals as the comments from single individuals often fell into more 

than one of these categories. 

The Spread of Invasive Plants from Adjacent BLM Lands 

Scoping comments described adverse effects from the spread of invasive plants from BLM to adjacent lands. 

Comments suggested BLM’s fragmented ownership pattern and large number of acres (more than 75 percent 

of some counties east of the Cascades) creates more edge and greater potential for invasive plants spread onto 

private, residential, urban, agricultural or other land uses. The inability of BLM to effectively control numerous 

specific weed species such as medusahead and perennial pepperweed jeopardizes cooperative weed management 

efforts as other partners are using more recently-available herbicides. This was the most frequent comment raised 

east of the Cascades. 

Concerns over the spread of invasive weeds from BLM lands are often founded in the reality of economic losses 

seen in communities often close to BLM lands. In 1988, a 1,300-acre ranch in Klamath County was abandoned 

and then auctioned for about ten percent of its original value due to a leafy spurge infestation (Asher and 

Spurrier 1998). Production losses, fire damage and control costs associated with 21 invasive plants in Oregon 

were estimated at $120 million per year in 2007 dollars. Potential nursery production losses and control costs 

if Sudden Oak Death continues to spread in Oregon were estimated at $79 to $304 million per year in 2007 

dollars. In addition, the complete removal of invasive plants and revegetation with native species in the city of 

Portland was estimated at $10 to $31 million per year in 2007 dollars (Cusack and Harte 2008). While total costs 

attributable to invasive plant spread from BLM lands are not available, these examples give perspective on the 

extent of potential losses statewide. Costs from noxious weed and other invasive plant spread from BLM lands 

would be borne by communities and land owners adjacent to BLM. 

Herbicide as a Threat to Resource Values and Human Health 

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, threatened, endangered, and 

sensitive species. Others suggested herbicides would destroy beneficial species which help control invasive 

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plants. Concerns about the persistence of herbicides in soils and their threat to air and water quality were 

noted. Particular concern was expressed about bioaccumulation and the threat herbicides pose to biodiversity 

and ecosystem function. Several comments identified threats to resource values off BLM lands from off-site 

movement of herbicides; agricultural crops and other non-target species were mentioned. Other comments made 

the case that the use of aerial application and boom broadcast spraying methods increased the likelihood of harm 

to these resource values. Many of these comments reflect the interests of communities who value non-commodity 

uses of BLM. 

In addition to concerns about adverse ecosystem effects of herbicides, comments reflected 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. Particular comments 

made the case aerial application and boom broadcast spraying methods were a threat to human health. Other 

comments noted that children, elderly, and others with special medical conditions have an increased vulnerability 

to herbicide treatment. Bioaccumulation and cumulative exposure to pesticides and other contaminants from all 

sources was stated as a concern. 

Herbicide as a Benefit to Resource Values 

Many comments stated that proper herbicide use could enhance, protect, and maintain resource values. These 

comments made the case that herbicides can be used to maintain and restore habitats and biodiversity on BLM 

lands, including in special management areas. Others said herbicide treatments would decrease the threat of noxious 

weeds and other and invasive plants to commodity and human uses such as livestock grazing recreation use. Others 

stated that additional herbicides, and aerial application methods, are essential to ensure efficient and effective 

treatment of invasive plants and allow BLM to enhance, protect, and maintain resource values at lower cost. 

These and related comments identified a range of commodity and non-commodity resource values important to 

quality of life need to be protected. They noted that assigning and 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. Non-market values can be 

particularly difficult to quantify because they include existence, bequest, and option values. Existence values are 

the amount society is willing to pay to guarantee that an asset simply exists, while option and bequest values are 

societies’ willingness to pay to preserve the opportunity for future use and for future generations 

In their report to the Oregon Invasive Species Council, Cusack and Harte note that while there have been 

many studies on the impacts of invasive species in localized settings, few take into account non-use 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 appropriate below. These values are also discussed in other sections of this EIS. 

Effects Common to All Alternatives 

Invasive weeds on BLM lands and the activities proposed under the alternatives can affect the public in several 

different ways including: 

•		 Management activities such as those involving timber, vegetation, public access, grazing, recreation, 

mining, fire, and fuels management are made more expensive by the need to incorporate weed prevention 

techniques such as equipment cleaning, avoidance, seasonal restrictions, mitigation, and monitoring; 

•		 Physical and esthetic impediments to land use created by the invasive plants themselves; 

•		 Area or facility closures, or herbicide exposures, related to vegetation treatments themselves; 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

• Degradation of resources flowing from BLM lands such as water or wildlife; 

• The spread of invasive weeds to non-BLM lands; and, 

• Infestation-related resource displacement resulting in commodity, non-commodity, and non-market losses. 

Conversely, 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. Non-market 

values such as improved recreation opportunities, reductions in wildfire risk, more efficient management of 

rights-of-way, and habitat improvements would benefit the economies of communities, dependent on recreational 

opportunities and natural amenities. 

Economic Losses 

Economic losses are not particularly quantifiable for BLM lands with existing information. BLM lands share 

a State-wide problem that no central source exists for compiling invasive plant infestation and treatment 

information within Oregon, and there is no requirement for county, private, or corporate landowners to report 

invasive plant information Despite limited reporting on weed locations, maps of the reported distribution of 

noxious weed species is available on a species-by-species basis online at www.weedmapper.org. The 1.2 million 

acre estimate for noxious weeds was compiled by the nine BLM district weed coordinators based on district maps 

and records, and from a special report, and includes about 600,000 acres just of medusahead. 

Oregon-wide information compiled for the Oregon Department of Agriculture by Radke and Davis (2000) 

is illustrative of the issues on BLM lands, since BLM manages 26 percent of Oregon and 12.3 percent of its 

forestlands. Their report includes: 

“A preliminary analysis of the economic impact in personal income of the 12 worst noxious weeds in 

Oregon estimated the foregone income to Oregon of these weeds to be $67 million annually (Radtke 1999)”, 

And

 “In Oregon... tansy ragwort, is known to have caused annual losses on the order of $6 million. Economic 

Containment programs so far have kept tansy ragwort from becoming an economic problem in eastern 

Oregon. There is a real threat for this noxious weed to expand into rangelands of eastern Oregon. The 

potential loss to agriculture and supporting industries for such on invasion could be $10 million in total 

personal income or 400 annual jobs.” 

Effects by Alternative 

The Spread of Invasive Plants from Adjacent BLM Lands 

Neighboring private and public lands would be adversely affected by the spread of invasive plants from BLM 

lands. Land values could be reduced, forage and other vegetation values would be harmed, and weed control 

costs for neighboring land owners or other administrative agencies (Federal, State, and local governments) would 

increase. The magnitude of these effects would be directly related to the success of the selected alternative in 

slowing noxious weed spread and decreasing future infested acres. 

Alternative 1 – No Herbicide Use 

The spread of invasive plants from BLM lands would be highest under Alternative 1, where weed spread would 

increase to a predicted 14 percent annually, and an estimated 1/2 of BLM lands in Oregon would be infested with 

noxious weeds in 15 years (Table 4-4). Further, the BLM would be without effective control methods for about 

2/3 of the noxious weed in Oregon (Appendix 7: Table A7-1), so eradication of specific weed populations about to 

spread to new or susceptible areas would often be ineffective. 

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Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Under Alternative 2, noxious weeds would be expected to continue expanding at the current 12 percent per year, 

and about 1/3 of the 15.7 million BLM acres in Oregon are projected to become infested in 15 years (Table 4-4). 

Since treatment acres would remain at current levels, future costs to neighboring private and public lands would 

continue to escalate along current trends as the scope and size of the problem continued to grow. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Under Alternative 3, future costs to neighboring private and public lands would decrease (from the No Action 

Alternative). Herbicides would be available to treat 99 percent of the noxious weeds, and cooperative control 

efforts could take place on BLM lands because most of the herbicides already being used by these groups on 

adjacent lands would be available. The BLM would be perceived as a more equal partner in weed control 

efforts with the means to use a wider range of herbicides. Also, some east side and possibly Siskiyou Biome 

communities would benefit from decreased fire risk associated with additional treatments with imazapic to reduce 

annual grasses. Wildland fire-related costs in these communities (such as property loss, and lost revenues) could 

be reduced as a result of the additional 11 to 13,000 acres of invasive grass treatments east of the Cascades. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses and Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity 

Vegetation Management Objectives 

Under Alternatives 4 and 5, adverse effects to neighboring private, residential, urban, and other land uses adjacent 

to BLM lands would benefit from the overall reduction in noxious weeds of 2.2 million acres in 15 years when 

compared to the No Action Alternative (Table 4-4). Benefits to adjacent landowners would particularly accrue 

from the roadside herbicide treatments indirectly reducing noxious weeds and other and invasive plants in 

locations where they are most likely to be spread to their lands. 

Herbicide as a Threat to Resource Values and Human Health 

Many comments stated invasive plant control did not justify the adverse effects to non-target plants, wildlife, 

water quality and other resources values from herbicide treatment.. Particular concern was expressed about 

the use of methods such as aerial application and boom broadcast spraying methods. Aside from Alternative 1 

where no herbicides would be used at all, this perception would be least under Alternative 2 and to some degree 

3, because herbicide use would be limited to the control of invasive plants. A certain segment of the comments 

expressed concerns that herbicides would unacceptably damage non-target plants and other wildland resources 

also acknowledged that invasive weed spread damages these same resources as well. Alternative 2 may be more 

acceptable because of the fewer acres treated with herbicides (Table 3-3), but Alternative 3 would use 30 to 

50 percent fewer total pounds (Table 3-5) and provide more herbicides to accomplish control objectives while 

minimizing environmental risk. 

A related concern under is potential threats to human health from herbicide use and its method of application. In 

addition to users of BLM lands and resources, comments identified applicators as being among those most likely 

to be exposed to herbicides. Concerns were not limited to exposure from direct application; concerns have been 

expressed over the potential for accumulation and cumulative effects, and from contamination of ground and 

surface waters that are used for consumption. Because concerns about herbicide effects on the environment and 

human health are primarily tied to the acres of use, concern is likely to remain lower under Alternative 2, the No 

Action Alternative than under any of the action alternatives. 

Under Alternative 3, concerns about the use of herbicides would likely intensify because of an 81 percent increase 

in projected herbicide treatment acres, an increase in the number of herbicides available, and the addition of 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

non-noxious invasive plants to the list of species that could be sprayed. However, while an 81 percent overall 

increase over the No Action Alternative is projected, concerns may be limited because only a 14 percent increase 

is anticipated west of the Cascades where population densities are the greatest. Increased use on the west site is 

limited by a slightly lower incidence of invasive plants, by the presence of more (and often difficult to detect) 

watercourses, by topography, and by population densities and public concerns. The 14 percent acreage increase 

would be considered by a portion of this concern group as worthwhile because it would control additional weed 

species and Sudden Oak Death, because total pounds of herbicide to be applied would decrease 30 to 50 percent, 

and because there would be no aerial applications permitted west of the Cascades. As with Alternative 2, SOPs 

and PEIS Mitigation Measures would reduce risks to human health and wildland resources. 

The Human Health and Safety section in this Chapter concludes that the additional herbicides available under 

Alternative 3, on average and perhaps in total, present less risk to human health than the four currently used 

herbicides. Use of 2,4-D is projected to decrease by 2/3 compared with Alternative 2. Despite the adoption of 

these SOPs and the decreased risk associated with these additional herbicides, perceived risk to human health 

would remain and likely be greater than under the No Action alternative, because 13,600 more acres would be 

treated. 

Under Alternative 4, concerns about resource damage and human health risk from the use of herbicides are likely 

to intensify significantly with the addition of herbicides to annually treat nearly 15,000 acres of native vegetation 

along rights-of-ways, administrative sites, recreation sites, and certain habitats. Public comments reflected 

concern that herbicide treatments along roadsides could have unintended consequences on human health and nontarget food or water sources. Comments expressed concern that they would be unknowingly exposed by traveling 

on BLM roads and utilizing roadside resources. They also point out that this work is taking place now simply 

at higher cost. Aside from using herbicides at all, spraying roadsides is probably the biggest concern with this 

group. This alternative is rated in the Human Health and Safety section in this Chapter as having a slightly higher 

potential for health risk than Alternative 3. Thus, perceptions of herbicide as a threat to resource values, human 

health, and quality of life would remain and likely intensify given the availability of additional herbicides and 

treatment of 14,800 additional acres (Table 4-33). 

Under Alternative 5, concerns about resource damage and human health risks from the use of herbicides would be 

greater than under Alternative 4 because the additional 5,000 acres of projected use is more open-ended in terms 

of its objective, need, and location. Further, 50,000 total acres of herbicide use annually will simply seem too 

high for many people in this group, regardless of the objective. It is nearly three times the No Action Alternative 

and nearly four times use levels in recent years. This alternative would also permit aerial applications west of the 

Cascades, although such use would be rare (something less than one project annually). Finally, this alternative 

would raise the number of herbicides available to 18, although actual treatment acres for some of the additional 

herbicides would be low. 

It would help those with concerns about Alternative 5 that most of the increased use (when compared to 

Alternative 4) would be east of the Cascades, and that most would likely be for additional habitat treatments 

such as the reduction of rabbitbrush and Western juniper currently at unnaturally high levels because of years 

of fire exclusion. These individuals and groups will also be eased by the fact that the 18 herbicides that would 

be available under this alternative have been analyzed and chosen by the BLM nationally as those that are the 

safest and most appropriate for BLM wildland use, from among over a hundred herbicides registered for use in 

Oregon. These herbicides, and this alternative, are what is currently available to BLM in the other 16 western 

states. Nevertheless, the potential for adverse effects to human health and wildland resources could be perceived 

as greater under Alternative 5 than for the other alternatives. The analysis in this EIS judged this alternative to 

have the greatest overall risk to human health of the five alternatives in this EIS, thus the perceptions of herbicide 

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as a threat to resource values and human health would be the greatest under this alternative, with its availability of 

additional herbicides, additional management objectives, and 5,000 additional acres treated. 

Herbicide as a Benefit to Resource Values 

Many comments stated that proper herbicide use could enhance, protect and maintain resource values. While 

effective invasive plant treatment without herbicide use could be maintained in some areas under Alternative 1, 

the 14 percent noxious weed spread rate and 8.6 million acres infested in 15 years would be perceived as more 

adverse than the other alternatives by these stakeholders. Those who hold commodity, non-commodity, and 

non-market values of BLM lands and perceive herbicide use as an effective means to protect these values would 

be troubled by accelerated decline in resource conditions and biodiversity as a result of increases in the rate of 

spread. Given the largest costs per acre of treatment (Costs section) and the labor-intensive nature of limited 

treatment options, individuals and groups interested in reducing costs to protect resource values would likely 

perceive reduced treatment effectiveness as an inefficient means of controlling invasive plants. 

Alternative 2, the No-Action Alternative, would be perceived as an improvement over Alternative 1. However, 

many stakeholders would perceive the current spread of noxious weeds and other invasive plants as an adverse 

effect. Since more effective controls are available to other agencies and landowners in Oregon and even to BLM 

in the other 16 western states. Those who hold value commodity, non-commodity, and non-market values of 

BLM lands and perceive herbicide use as an effective means to maintain those values, would see the continued, 

and to them unnecessary, decline in resource conditions and biodiversity as an inappropriate way to manage the 

BLM’s public resources. 

Alternative 3 would be perceived as a substantial improvement to those seeing herbicides as an efficient and 

effective way to benefit resource values. Additional herbicide treatments of noxious weeds and other invasive 

plants under this alternative would be perceived as improving ecosystem health, thus improving the quality of 

market and non-market values. In addition to reducing weed infestation by an estimated 1.9 million acres in 15 

years, unquantifiable benefits would accrue from being able to treat weeds as aggressively as adjacent landowners. 

Important native species and biological diversity within scenic areas, scenic byways, wild and scenic rivers, 

wilderness areas, and ACECs would be better maintained; recreation and/or educational values of these areas 

would be enhanced. Given the smaller cost per acre of treatment than Alternatives 1 and 2, individuals and groups 

interested in reducing costs to protect resource values, would likely perceive this alternative as a more efficient 

means of controlling invasive plants. 

Alternative 4 would be perceived as providing additional resource benefits with the additional 300,000-acre 

reduction in weed-infested acres in 15 years and a decrease in the rate of noxious weed spread from 7 to 6 percent. 

Individuals and groups who associate an improvement in commodity uses with herbicide use would likely 

perceive little change from herbicide treatment of rights-of-way because the work is taking place now, without 

herbicides. The increase in treatments for wildlife objectives would also be perceived as beneficial by those 

interested in commodity, non-commodity, and non-market values. 

Alternative 5 would be perceived as contributing additional benefits associated with the annual treatment of 

approximately 5,000 additional acres, almost all of which would be habitat improvements east of the Cascades. 

Individuals and groups identified above would associate some additional benefits to their non-commodity and 

non-market values associated with these habitat improvements. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Cumulative Effects 

Historically, trade and migration routes from Europe to the New World were the major pathways of invasive 

species to the Unites States. Changing world markets have made Oregon a more important U.S. port increasing 

Oregon’s susceptibility to invasive species (Statesman Journal 2007). In addition, the economy can be affected by 

a variety of factors including population growth, changes in interest rates, location of new industries, recession, 

growth of new sectors, tax policy, State economic policy, etc. which are influenced by regional and world 

market factors. When compared to these kinds of variables, the projected effect of noxious weeds and other 

invasive plants on BLM resources in Oregon has a relatively small if any effect on regional economic conditions. 

However when combined with the spread of noxious weeds and other invasive plants that would occur off of 

BLM, effects on the regional economic conditions could occur. Also the, rate of weed spread estimated to occur 

under Alternatives 1 and 2 would have cumulative adverse effects on weed suppression costs on and off BLM 

lands within the State. While the ability to treat existing noxious weeds and other invasive plants will improve as 

more herbicides are made available, market forces of an ever-changing world economy make cooperative efforts 

across agencies, community, and cultural boundaries critically important. 

Although private land owners and Federal, State, and local governments administering lands adjacent to the BLM 

will continue invasive plant treatment activities, implementation of Alternatives 1 and 2 would contribute to 

increased occurrence of weeds throughout Oregon relative to the Action Alternatives. The resulting decrease in 

biological diversity and reduction in economic and social returns would adversely impact all stakeholders. For 

example, the threat to the agricultural based economy of the region posed by invasive plants would be aggravated 

by spread from BLM lands, thereby adversely impacting the continuation of agricultural associated lifestyles and 

customs. Costs incurred by adjacent land ownerships would likely continue to increase as a result of increased 

spread from BLM lands. 

Environmental Justice 

Affected Environment 

Environmental justice refers to the fair treatment and meaningful involvement of people of all races, cultures, 

and incomes with respect to the development, implementation, and enforcement of environmental laws, 

regulations, programs, and policies. Executive Order 12898 requires Federal agencies to “identify and address the 

disproportionately high and adverse human health or environmental effects of its programs, policies, and activities 

on minority populations and low-income populations.” Thus, the concentrations of low income and minority 

groups, as well as trends in ethnic and racial composition of Oregon, are relevant to this analysis. 

Population and Demographic Change 

For the State of Oregon, the percentage of the total population identified as white, African American, and 

American Indian or Alaska Natives declined between 1990 and 2000. The percentage of Asian, Native Hawaiian, 

those persons identifying with some other race alone71, and Hispanics increased over this period (Table 4-28). 

Within individual counties: 

71 Persons identifying with a single other racial group other than white, African American, American Indian or Alaska 

Native, Native Hawaiian and Other Pacific Islander, and Asian groups. 

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•		 The percentage of total population identified as white decreased between 1990 and 2000 within all 

counties in Oregon. 

•		 The largest increases in non-white racial groups were: 

•		 Malheur County where those identified as African American increased as a percentage of total population 

by 1.2 percent; 

•		 Klamath County American Indians and Alaska Natives increased by 1.7 percent; 

•		 Multnomah County Asians increased by 2.8 percent, and; 

•		 Morrow County those identifying with some other race increased by 11.1 percent. 

•		 Individual county percentages higher than the percentage in their respective east and west side analysis 

areas indicate where higher concentrations of minorities may exist: 

•		 On the east-side, all counties exceed the analysis area percentage for at least one minority group except 

Baker, Crook, Deschutes, Gilliam, Wallowa and Wheeler counties, and; 

•		 West of the Cascades, all counties exceed the analysis area percentage for at least one minority group 

except Clackamas, Clatsop, and Tillamook counties (Table 4-29). 

Race and ethnicity are broken out separately since Hispanics can be of any race. Between 1990 and 2000, the 

percentage of the total Oregon population of Hispanic origin increased by 4.1 percent (from 3.9 to 8 percent). 

Population numbers and the percentage of total population increased in all counties except Gilliam and Wallowa. 

The Hispanic populations of the east side and west side of Oregon increased by 3.9 percent and by 4.1 percent, 

respectively. 

According to the Council on Environmental Quality’s Environmental Justice Guidelines for NEPA (CEQ 1997) 

“minority populations should be identified where either: (a) the minority population of the affected area exceeds 

50 percent or (b) the minority population percentage of the affected area is meaningfully greater than the minority 

population percentage in the general population or other appropriate unit of geographic analysis.....a minority 

population also exists if there is more than one minority group present and the minority percentage, as calculated 

by aggregating all minority persons, meets one of the above stated thresholds.” The discussion above and Table 

4-29 shows the percentage of those identifying with some other race71 or Hispanics was greater in many Oregon 

counties than the total percentage on the east or west side. The concentration of minority populations within 

counties “meaningfully” greater than east and west side populations suggests they likely exist within smaller 

geographies. Thus, the U.S. Census data suggest minority populations within the analysis area likely meet the 

CEQ’s Environmental Justice criterion. 

In addition to race, concentrations of low income people and trends in the change of the population defined 

as low income are pertinent to the examination of Environmental Justice considerations. Between 1989 and 

1999 the percentage of the Oregon population living below the Federally defined poverty level increased 

in nine counties, only two of which were west of the Cascades; Washington and Marion counties (Table 

4-27). Sherman County (east of the Cascades) saw the largest percentage increase, while Washington 

County increased most in absolute terms by 12,377 (less than 1 percent change). 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. In 1999, 26 counties had higher percentages of their 

populations living below the poverty level than the State percentage, 11 west of the Cascades and 15 east of the 

Cascades (Table 4-27) (US Census Bureau 2000b). 

CEQ guidance on identifying low-income populations states “agencies may consider as a community either a group 

of individuals living in geographic proximity to one another, or a set of individuals (such as migrant workers or 

American Indians), where either type of group experiences common conditions of environmental exposure or effect.” 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Table 4-27. PoPUlaTion living beloW THe PoverTy level 

1989 1999 change 

change in 

number of 

low income 

1989 1999 change 

change in 

number of 

low income 

OREGON 12.4% 11.6% -0.8% 43873 OREGON 12.4% 11.6% -0.8% 43873 

WEST-SIDE EAST-SIDE 

Benton * 15.5% 14.6% -1.0% 660 Baker * 14.7% 14.7% 0.0% 218 

Clackamas 6.9% 6.6% -0.4% 2866 Crook 11.1% 11.3% 0.2% 591 

Clatsop * 14.4% 13.2% -1.2% -102 Deschutes 10.9% 9.3% -1.6% 2513 

Columbia 10.2% 9.1% -1.2% 97 Gilliam 11.9% 9.1% -2.8% -31 

Coos * 16.5% 15.0% -1.4% -484 Grant * 12.7% 13.7% 1.0% 86 

Curry * 12.4% 12.2% -0.1% 185 Harney * 10.6% 11.8% 1.2% 137 

Douglas * 14.9% 13.1% -1.7% -829 Hood River * 15.7% 14.2% -1.4% 235 

Jackson * 13.2% 12.5% -0.7% 3344 Jefferson * 18.6% 14.6% -4.0% 244 

Josephine * 18.3% 15.0% -3.3% -68 Klamath * 16.7% 16.8% 0.0% 1021 

Lane * 14.5% 14.4% -0.1% 5585 Lake * 13.9% 16.1% 2.2% 192 

Lincoln * 14.4% 13.9% -0.5% 560 Malheur * 19.3% 18.6% -0.7% 320 

Linn 13.5% 11.4% -2.1% -560 Morrow * 15.1% 14.8% -0.3% 476 

Marion * 13.2% 13.5% 0.3% 8466 Sherman * 9.9% 14.6% 4.7% 90 

Multnomah * 13.1% 12.7% -0.5% 6826 Umatilla * 16.5% 12.7% -3.9% -895 

Polk 13.6% 11.5% -2.1% 468 Union * 15.8% 13.8% -2.0% -346 

Tillamook 15.0% 11.4% -3.6% -450 Wallowa * 15.8% 14.0% -1.8% -76 

Washington 6.6% 7.4% 0.8% 12377 Wasco * 13.4% 12.9% -0.5% 172 

Yamhill 11.7% 9.2% -2.6% 37 Wheeler * 20.9% 15.6% -5.3% -52 

West-side totals 12.1% 11.4% -0.7% 38978 East-side totals 14.8% 13.1% -1.6% 4895

 (* County percent of population greater than the state in 1999. Sources: US Census Bureau 2000a, b) 

Examining both the racial and ethnic composition of poverty (Table 4-30), it is apparent that poverty levels 

amongst minority populations are greater than among white populations in all Oregon counties. In all counties 

except Clackamas and Curry counties, the percentage of at least one minority group was greater than its respective 

east and west side aggregated percentage in 1999, indicating concentrations of low income minorities exist 

throughout the State and likely meet the CEQ’s Environmental Justice Criterion for poverty discussed above. In 

Lane County, the percentage of people living below the poverty level exceeds the State and west side percentages 

for all minorities and Hispanics (Table 4-30). 

Environmental Consequences 

According to the description of the affected environment, minority and low income populations, as defined by 

CEQ, are likely present in Oregon. The presence of minority groups, low income, and American Indian tribes 

is relevant to the analysis because they may be disproportionately affected by the alternatives. These groups are 

often at a disproportionate risk compared to the general Oregon population, since they often participate in special 

uses on BLM lands. These uses include gathering food, cultural material, floral material, and other products either 

for personal or commercial use. Disproportionate risk to these groups could also result from participation in weed 

and other vegetation control work with herbicide and non-herbicide methods as part of a contract work crew. 

Identification of minority populations and low-income populations primarily requires an analysis of trends and 

current populations of minorities and people living below the poverty level from U.S. Census data. Effects to 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

resources important to minorities or persons living below the poverty level are one concern. The other is that 

work crews implementing weed control activities having a higher percentage of minorities and lower income 

groups could be subject to adverse effects of herbicide and non-herbicide treatments. 

The potential for effects to non-target plants and animals that might be used by minority and other groups was 

determined from those respective sections elsewhere in this Chapter. To consider potential effects to work 

crews, BLM districts provided estimates of the percentage of non-herbicide and herbicide treatments that would 

be accomplished by contract work crews for the control of noxious weeds and other invasive plants under 

Alternatives 1-3. The rights-of-way and related treatments portion of Alternatives 4 and 5 was assumed to be 

mostly accomplished by employees of the persons owning the developments on those rights-of-ways. Thus those 

employees would be using equipment, and little to no disproportionate representation is expected. 

Effects Common to All Alternatives 

Work Crew Exposure 

The racial composition of work crews implementing treatment activities are expected to be generally similar 

to that of the analysis area population, with potential for slightly higher percentages of minorities and lower 

income groups. Scoping suggested minority laborers who may know little English, may not be able to read 

product labels, may not have prior awareness of the health risk of using herbicides, may not be in a position to 

seek redress for being put in illegal or unsafe situations by their employers, and/or may not be able to access 

workmen’s compensation or other health care, may be at greater risk by working on herbicide application crews. 

Such a situation is conceivable, but should be considerably mitigated by current requirements that all contract 

crew members be State certified as, at minimum, Trainees. The test for a Trainee permit examines knowledge of 

applicable laws and safe handling procedures. There is a potential for disproportionate representation of minority 

and low income groups in work crews implementing herbicide treatments. To some degree this suggests that 

alternatives that allow herbicide use could pose an adverse risk to these groups. This risk increases with the 

amount of acres treated with herbicides under each alternative (Table 3-3), and the toxicity of those herbicides to 

humans. However, there are also risks associated with non-herbicide methods as well. For example, a reduction 

in chainsaw exposure is one factor favoring the use of herbicides in some rights-of-way. 

Invasive Plant Effects 

American Indian and other racial, ethnic, or low-income backgrounds participating in subsistence or cultural 

uses on BLM lands may be disproportionately affected by the spread of noxious weeds and other invasive 

plants. Populations of native plant species used for cultural purposes such as food, medicine, dress, basketry, or 

ceremonial activities are likely to be reduced as a result of invasive plant spread. These groups would be forced 

to seek these resources in other areas, or the resources would become less available. Some invasive plants like 

blackberries have collectable value, but such species are over-represented and spreading at the expense of native 

species. Although some culturally significant historic American Indian gathering areas may be relatively higher 

priority for weed control treatments, most areas would be expected to become infested at the same rate as BLM 

lands in general. Noxious weeds are projected to infest (be present on) approximately 1/2, 1/3, 1/4, and 2/9 of the 

BLM lands in Oregon and be spreading at a rate of 14, 12, 7 and 6 percent in 15 years for Alternatives 1, 2, 3 and 

4/5 respectively under a current budget trends scenario (Table 4-4). 

User Group Exposure 

The same user groups that would be adversely affected by the displacement of native species by invasive plants 

could also be affected by herbicide residues or area closures associated with herbicide use under the various 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

alternatives. Treatment areas would normally be posted on site, depending upon the label and an analysis of 

the risk, but that would not necessarily prevent all contact or ingestion. Also site-specific planning on proposed 

treatments would include consultation with tribes, and potential mitigations to protect and preserve those 

resources for the people that use them. The BLM may opt to use manual and mechanical treatments in traditional 

use areas and herbicides outside of those areas. 

Effects by Alternative 

Alternative 1 – No Herbicide Use 

Work Crew Exposure 

An estimated 28,600 acres of manual and mechanical treatments would be performed by contract crews. Work 

crews may experience injury during manual and mechanical treatments, such as chainsaw injuries cutting 

hardwood trees on steep hillsides under power lines. Exposure to cutting and grubbing tool injuries would 

be comparable to those experienced by fire crews. The is no potential for human exposure to BLM-applied 

herbicides under this alternative due to the absence of herbicide treatments. 

Invasive Plant Effects 

Under Alternative 1, noxious weeds are projected to infest 8.6 million acres in 15 years, or about 1/2 of all 

BLM lands in Oregon. Other invasive plants would cover millions of additional acres. Native plants important 

for cultural uses could potentially be crowded out of some areas forcing American Indian users to seek these 

resources in other areas or discontinue traditional uses. Populations of culturally important plants could decrease 

to the point of being insufficient to support traditional use. Visitors from other racial, ethnic, or low-income 

backgrounds participating in subsistence or cultural uses may also be impacted. Areas important to these 

visitors for mushroom gathering, berry picking, greenery or floral materials collection or other activities could be 

adversely impacted by the spread of invasive plants. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Work Crew Exposure 

An estimated 20,600 acres of manual and mechanical treatments would be performed by contract crews, exposing 

workers to tool and other injuries. Also approximately 15,300 acres of noxious weeds would be treated with 

herbicides by certified or licensed contract crews under this alternative. Of the four herbicides available under 

this alternative, 2,4-D has low to moderate risk from direct contact under all application methods, and dicamba 

presents a low risk to applicators from direct contact with spills. 

Invasive Plant Effects 

Under Alternative 2, noxious weeds are projected to infest 5.9 million acres in 15 years, or about 1/3 of all BLM 

lands in Oregon. Other invasive plants would cover millions of additional acres. Native plants important for 

cultural uses could be crowded out of some areas forcing American Indian users to seek these resources in other 

areas or discontinue traditional uses. Populations of culturally important plants could decrease to the point 

of being insufficient to support traditional use. Visitors from other racial, ethnic, or low-income backgrounds 

participating in subsistence or cultural uses may also be impacted. Areas important to these visitors for mushroom 

gathering, berry picking, greenery collection or other activities could be adversely impacted by the spread of 

invasive plants. 

User Group Exposure 

An estimated 16,700 acres would be treated with herbicides under this alternative. American Indian and visitors 

from other racial, ethnic, or low-income backgrounds participating in subsistence or cultural uses could be 

adversely affected by herbicide exposure, or by inadvertent effects to non-target culturally important plants, or to 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

wildlife species of value to these groups. However, treatment design would attempt to minimize exposure of nontarget food and water sources. In addition, SOPs require consultation with tribes to locate any areas of vegetation 

that are significant to the tribes and that might be affected by herbicide treatments. Despite these measures, the 

potential for disproportionate or adverse impacts to minority or low-income work crews would still exist. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Work Crew Exposure 

An estimated 17,100 acres of manual and mechanical treatments would be performed by contract crews, exposing 

workers to tool and other injuries. Also approximately 27,000 acres of noxious weeds would be treated with 

herbicide by contract crews under this alternative. Eleven or 13 herbicides would be available, providing project 

planners with opportunities to select safer herbicides that are used at lower rates than under Alternative 2. Use of 

2,4-D and dicamba would be lower than under Alternative 2, but hexazinone, triclopyr, and chlorsulfuron present 

a low to moderate risk under at least one worker exposure scenario. 

Invasive Plant Effects 

Under Alternative 3, noxious weeds are projected to infest 4.0 million acres in 15 years, or about 1/4 of all 

BLM lands in Oregon. Other invasive plants would cover millions of additional acres. Native plants important 

for cultural uses could potentially be crowded out of some areas forcing American Indian users to seek these 

resources in other areas or discontinue traditional uses. Populations of culturally important plants could decrease 

to the point of being insufficient to support traditional use. Visitors from other racial, ethnic, or low-income 

backgrounds participating in subsistence or cultural uses may also be impacted. Areas important to these visitors 

for mushroom gathering, berry picking, greenery collection or other activities could be adversely impacted by the 

spread of invasive plants. 

User Group Exposure 

An estimated 30,300 acres would be treated with herbicide under this alternative, an increase of 13,600 acres 

when compared to the No Action Alternative. American Indian and visitors from other racial, ethnic, or lowincome backgrounds participating in subsistence or cultural uses could be adversely affected by herbicide 

exposure, or by inadvertent effects to non-target culturally important plants, or to wildlife species of value to these 

groups. However, treatment design would attempt to minimize exposure of non-target food and water sources. In 

addition, SOPs require consultation with tribes to locate any areas of vegetation that are significant to the tribes 

and that might be affected by herbicide treatments. Despite these measures, the potential for disproportionate or 

adverse impacts to minority or low-income work crews would still exist. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

Work Crew Exposure 

Work crews may experience injury during manual and mechanical treatments, with risks expected to be similar 

to those described for Alternative 3. Contract treatments are projected to increase less than 5,000 acres from 

Alternative 3. 

Invasive Plant Effects 

Under Alternative 4, noxious weeds are projected to infest 3.7 million acres in 15 years, or about 2/9 of all 

BLM lands in Oregon. Other invasive plants would cover millions of additional acres. Native plants important 

for cultural uses could potentially be crowded out of some areas forcing American Indian users to seek these 

resources in other areas or discontinue traditional uses. Populations of culturally important plants could decrease 

to the point of being insufficient to support traditional use. Visitors from other racial, ethnic, or low-income 

backgrounds participating in subsistence or cultural uses may also be impacted. Areas important to these visitors 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

for mushroom gathering, berry picking, greenery collection or other activities could be adversely impacted by the 

spread of invasive plants. 

User Group Exposure 

An estimated 45,100 acres would be treated with herbicides under this alternative, an increase of 14,800 acres 

from Alternative 3. Approximately 2/3 of the increase would be spraying native plants along roads, rights-ofways, and other developments. To the degree some user groups collect products within a few feet of the road 

edge, as might occur with blackberries for example, exposure would be increased. Also, unlike alternatives 1-3, 

native species would be deliberately targeted along rights-of-way and near other developments, and in certain 

habitat treatment areas, increasing the potential to affect plants and other products utilized by underrepresented 

groups. 

As with Alternatives 2 and 3, however, treatment design would attempt to minimize exposure of non-target food 

and water sources. In addition, SOPs require consultation with tribes to locate any areas of vegetation that are 

significant to the tribes and that might be affected by herbicide treatments. Despite these measures, the potential 

for disproportionate or adverse impacts to minority or low-income work crews would still exist. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

Work Crew Exposure 

Work crews may experience injury during manual and mechanical treatments, with risks expected to be similar 

to those described for Alternative 3. Contract herbicide treatments could increase as much as 8 to 9,000 acres 

compared to Alternative 3, but the type of exposure would be similar. 

Invasive Plant Effects 

Effects from invasive plants would be essentially the same as described for Alternative 4. 

User Group Exposure 

Alternative 5 would increase herbicide treatments about 5,000 acres when compared to Alternative 4, with the 

increase primarily applying to treatment of native plants for habitat improvement and other non-commodity 

treatments. The risk to plants and other resources used by American Indian and other under-represented groups on 

a per-acre basis would be higher than Alternatives 1-3, because treatments would target native plants. Inadvertent 

treatment of areas not identified as important to other racial, ethnic, or low-income backgrounds participating in 

subsistence or cultural uses would be highest under this alternative. 

However, treatment design would attempt to minimize exposure of non-target food and water sources. Habitat or 

fuels treatments under this alternative would normally target areas where total vegetation, or a specific species, 

has become over-abundant. In addition, SOPs require consultation with tribes to locate any areas of vegetation 

that are significant to the tribes and that might be affected by herbicide treatments. Despite these measures, the 

potential for disproportionate or adverse impacts to minority or low-income work crews would still exist. 

Cumulative Effects 

With growing populations of minority (Table 4-28) and low income populations (Table 4-27) throughout the State, 

the cumulative effects on Environmental Justice are relevant. As Hispanic, American Indian, and other minority 

or low income populations continue to grow, the likelihood of these groups using public lands is likely to increase. 

Combined with increasing levels of treatment, the possibility increases that effects associated with vegetation 

treatments would disproportionately affect these minority populations. These combined trends illustrate the 

importance of site-specific consideration of the potential to affect under-represented groups, and American Indian 

consultation, conducted during planning for future herbicide treatment projects. 

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Table 4-28. racial and eTHnic cHange comPared To THe ToTal PoPUlaTion cHange in oregon, by coUnTy 

(1990 To 2000) 

White alone 

Black or 

African 

American 

alone 

American Indian 

and Alaska 

Native alone 

Asian 

alone 

Native Hawaiian 

and Other Pacific 

Islander alone 

Some other 

race alone Hispanic* 

OREGON -6.4% 0.0% -0.2% 0.7% 0.0% 2.5% 4.1% 

WEST-SIDE COUNTIES 

Benton -2.9% 0.1% -0.2% -1.2% 0.0% 1.0% 2.5% 

Clackamas -5.3% 0.3% -0.1% 0.8% 0.1% 1.5% 2.5% 

Clatsop -3.9% 0.4% -0.2% 0.0% 0.0% 0.9% 2.4% 

Columbia -2.5% 0.2% -0.2% -0.4% 0.0% 0.2% 0.3% 

Coos -4.1% 0.0% -0.2% -0.3% 0.0% 0.7% 0.8% 

Curry -3.1% 0.1% -0.7% 0.5% -0.1% 0.6% 1.7% 

Douglas -2.9% 0.0% -0.2% 0.0% -0.2% 0.3% 0.6% 

Jackson -4.0% 0.2% -0.6% -0.1% 0.1% 1.3% 2.6% 

Josephine -3.2% 0.0% -0.3% 0.1% 0.0% 0.5% 1.4% 

Lane -4.9% 0.0% 0.0% 0.1% 0.0% 1.2% 2.0% 

Lincoln -5.6% 0.1% 0.2% 0.1% 0.0% 1.5% 3.0% 

Linn -4.0% 0.0% 0.1% 0.1% 0.1% 1.0% 1.8% 

Marion -9.8% 0.0% -0.2% 0.1% 0.1% 6.4% 9.6% 

Multnomah -8.2% -0.6% -0.2% 1.3% 0.1% 3.1% 4.5% 

Polk -3.9% -0.1% 0.0% 0.1% 0.1% 1.0% 3.3% 

Tillamook -3.0% -0.2% -0.8% 0.1% 0.0% 1.3% 3.5% 

Washington -10.0% 0.4% 0.0% 2.8% 0.1% 3.4% 6.5% 

Yamhill -5.2% 0.0% -0.3% 0.1% -0.1% 2.8% 4.0% 

West-side Totals -6.5% -0.1% -0.2% 0.8% 0.1% 2.5% 4.1% 

EASTSIDE COUNTIES 

Baker -2.4% 0.1% -0.1% 0.2% 0.1% 0.5% 0.1% 

Crook -4.3% 0.0% -0.4% 0.2% 0.0% 3.2% 3.1% 

Deschutes -2.8% 0.1% -0.4% 0.0% -0.1% 1.1% 1.8% 

Gilliam -2.0% 0.1% 0.5% -0.4% 0.0% 1.0% -1.0% 

Grant -1.6% 0.0% -0.2% -0.1% 0.0% 0.0% 0.4% 

Harney -4.3% 0.1% 0.1% 0.2% 0.1% -0.2% 1.4% 

Hood River -11.9% 0.0% -1.0% -0.1% -0.1% 10.5% 9.4% 

Jefferson -5.7% -0.1% -4.2% 0.2% 0.0% 6.4% 7.2% 

Klamath -5.3% -0.2% 0.1% 0.3% 0.1% 1.4% 2.6% 

Lake -4.6% -0.2% 1.7% 0.2% -0.5% 0.7% 1.2% 

Malheur -5.7% 1.2% -0.1% -1.3% 0.0% 3.0% 5.4% 

Morrow -14.3% 0.1% 0.5% 0.2% -0.1% 11.1% 13.4% 

Sherman -5.9% 0.6% 1.3% 0.5% 0.0% 0.8% 3.2% 

Umatilla -7.0% 0.4% -0.1% 0.0% 0.0% 4.6% 7.4% 

Union -2.4% 0.1% -0.5% 0.1% 0.1% 1.0% 0.8% 

Wallowa -1.2% 0.0% -0.1% -0.3% 0.0% 0.1% -0.8% 

Wasco -6.2% 0.0% -0.2% 0.3% -0.3% 3.6% 4.2% 

Wheeler -4.2% 0.1% 0.1% -0.1% 0.0% 1.7% 2.2% 

Eastside Totals -5.1% 0.1% -0.4% 0.0% 0.0% 2.9% 3.9%

 (*Hispanics or Latinos may be of any race. Sources: US Census Bureau 2000a) 

 300 
 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Table 4-29. racial and eTHnic sHare of 2000 PoPUlaTion 

White alone 

Black or 

African 

American 

alone 

American Indian 

and Alaska 

Native alone 

Asian 

alone 

Native Hawaiian 

and Other Pacific 

Islander alone 

Some other 

race alone Hispanic* 

OREGON 86.4% 1.6% 1.3% 2.9% 0.2% 4.3% 8.0% 

WEST-SIDE COUNTIES 

Benton 89.0% 1.0% 0.7% 4.3% 0.1% 1.8% 4.6% 

Clackamas 91.2% 0.6% 0.6% 2.4% 0.2% 2.3% 5.0% 

Clatsop 92.5% 0.7% 0.9% 1.0% 0.2% 1.8% 4.6% 

Columbia 94.2% 0.3% 1.3% 0.5% 0.1% 0.9% 2.3% 

Coos 91.5% 0.2% 2.6% 0.5% 0.1% 1.2% 3.2% 

Curry 93.0% 0.1% 2.4% 0.8% 0.0% 1.0% 3.3% 

Douglas 93.7% 0.2% 1.6% 0.6% 0.0% 0.9% 2.8% 

Jackson 91.6% 0.4% 1.1% 0.8% 0.2% 2.9% 6.7% 

Josephine 93.7% 0.2% 1.3% 0.5% 0.0% 1.3% 4.2% 

Lane 90.5% 0.8% 1.1% 1.9% 0.2% 2.0% 4.5% 

Lincoln 90.3% 0.2% 2.7% 0.7% 0.3% 1.9% 4.7% 

Linn 93.0% 0.2% 1.4% 0.8% 0.2% 1.8% 4.1% 

Marion 81.7% 0.9% 1.3% 1.7% 0.3% 10.6% 17.2% 

Multnomah 79.0% 5.4% 1.0% 5.6% 0.4% 4.1% 7.5% 

Polk 89.3% 0.3% 1.6% 1.2% 0.2% 4.5% 8.8% 

Tillamook 94.4% 0.2% 0.5% 0.5% 0.1% 1.7% 5.1% 

Washington 82.0% 1.0% 0.7% 6.7% 0.3% 5.9% 11.1% 

Yamhill 89.2% 0.7% 1.2% 1.0% 0.1% 5.1% 10.6% 

West-side Totals 86.3% 1.7% 1.1% 3.2% 0.2% 4.0% 7.7% 

EASTSIDE COUNTIES 

Baker 96.0% 0.3% 0.7% 0.5% 0.1% 0.7% 1.9% 

Crook 92.5% 0.0% 1.7% 0.3% 0.0% 4.0% 5.6% 

Deschutes 94.8% 0.2% 0.9% 0.5% 0.1% 1.5% 3.8% 

Gilliam 96.8% 0.1% 1.0% 0.3% 0.0% 1.0% 1.4% 

Grant 95.8% 0.0% 1.3% 0.1% 0.0% 0.9% 2.7% 

Harney 90.3% 0.1% 3.6% 0.8% 0.2% 1.0% 4.5% 

Hood River 78.7% 0.2% 0.9% 1.4% 0.1% 16.2% 25.1% 

Jefferson 68.7% 0.1% 15.3% 0.6% 0.1% 11.9% 17.6% 

Klamath 87.2% 0.5% 4.1% 0.7% 0.2% 3.6% 7.8% 

Lake 90.5% 0.0% 3.2% 0.7% 0.1% 2.8% 4.9% 

Malheur 75.7% 1.4% 0.9% 1.6% 0.1% 17.4% 25.7% 

Morrow 75.0% 0.2% 1.7% 0.5% 0.0% 20.2% 24.4% 

Sherman 92.5% 0.6% 2.1% 0.7% 0.0% 1.3% 4.7% 

Umatilla 82.0% 1.0% 3.2% 0.7% 0.1% 10.9% 16.1% 

Union 94.5% 0.5% 0.6% 0.9% 0.6% 1.5% 2.3% 

Wallowa 97.8% 0.0% 0.4% 0.0% 0.1% 0.2% 0.7% 

Wasco 86.4% 0.4% 3.5% 0.9% 0.1% 5.9% 9.3% 

Wheeler 95.2% 0.1% 0.5% 0.0% 0.0% 1.7% 3.4% 

East-side Totals 87.1% 0.5% 2.7% 0.7% 0.1% 6.5% 10.5% 

(*Hispanics or Latinos may be of any race. Sources: US Census Bureau 2000a) 

301 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table 4-30. PoPUlaTion living beloW THe PoverTy level in oregon, by coUnTy, race, and eTHniciTy 

White 

Black or 

African 

American 

American 

Indian & 

Alaska Native 

Asian 

Native Hawaiian 

& Other pacific 

Islander 

Some Other 

Race 

Hispanic 

or Latino* 

OREGON 10% 24% 22% 12% 18% 27% 25% 

WESTSIDE COUNTIES 

Benton 13% 24% 15% 38% 11% 21% 25% 

Clackamas 6% 10% 9% 5% 16% 26% 21% 

Clatsop 12% 52% 19% 15% 22% 48% 45% 

Columbia 8% 15% 17% 11% 15% 35% 26% 

Coos 14% 29% 25% 17% 39% 14% 22% 

Curry 12% 0% 15% 1% 0% 3% 7% 

Douglas 13% 12% 18% 11% 17% 32% 28% 

Jackson 12% 24% 20% 18% 10% 29% 26% 

Josephine 14% 13% 25% 14% 13% 27% 24% 

Lane 13% 26% 24% 31% 26% 28% 27% 

Lincoln 13% 16% 30% 12% 21% 35% 29% 

Linn 11% 19% 20% 9% 3% 30% 26% 

Marion 11% 31% 19% 13% 30% 27% 27% 

Multnomah 10% 26% 22% 13% 14% 30% 26% 

Polk 10% 31% 22% 14% 4% 27% 29% 

Tillamook 11% 77% 13% 16% 0% 32% 39% 

Washington 6% 11% 11% 8% 21% 24% 21% 

Yamhill 8% 6% 6% 18% 3% 21% 20% 

West-Side Totals 10% 24% 19% 13% 18% 27% 25% 

EASTSIDE COUNTIES 

Baker 14% 7% 40% 17% 100% 33% 29% 

Crook 10% 0% 32% 0% NA 34% 37% 

Deschutes 9% 42% 26% 10% 0% 24% 20% 

Gilliam 9% 0% 0% 0% NA 47% 35% 

Grant 13% NA 27% 0% 0% 44% 24% 

Harney 10% 0% 36% 10% 42% 24% 22% 

Hood River 12% 0% 14% 9% 0% 28% 34% 

Jefferson 10% 0% 32% 0% 0% 19% 22% 

Klamath 15% 17% 40% 11% 3% 37% 32% 

Lake 15% NA 28% 0% 25% 32% 30% 

Malheur 16% 47% 39% 4% 72% 30% 28% 

Morrow 11% 41% 15% 20% 0% 27% 27% 

Sherman 14% 0% 20% 21% NA 73% 39% 

Umatilla 10% 33% 21% 6% 29% 25% 23% 

Union 13% 24% 21% 16% 35% 18% 24% 

Wallowa 14% NA 15% 0% 100% 0% 33% 

Wasco 11% 9% 24% 11% 33% 21% 25% 

Wheeler 14% 0% 0% NA NA 56% 60% 

East-side Totals 11% 27% 30% 9% 22% 27% 27% 

(*Hispanics or Latinos may be of any race. NA indicates counties contained no population of that minority. 

Sources: US Census Bureau 2000a) 

 302 
 

 

 

 

 

 

 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Costs 

This section examines the direct costs of implementing the various alternatives. Examined for each alternative are 

total direct costs, direct costs per effectively treated acre, and cost savings (where applicable) from substituting 

one treatment method for another for activities that must be conducted regardless of the alternative selected. 

BLM funding is finite; funds spent in one place usually means less funding is available to be spent elsewhere. No 

attempt is made to estimate the cost/benefit of these potential alternative uses for funds. 

Costs are arguably not a potential effect on the human environment and thus the section is not necessarily 

required by NEPA. However, in this case, it furthers NEPA objectives to display the factors that will be used by 

the decision-maker to select from among the alternatives, and cost-effectiveness is thus identified as a Purpose 

in Chapter 1. BLM planning policy specifies that management actions having a high likelihood of improving 

resource conditions for relatively small expenditures of time and money should receive relatively higher priority 

(USDI 2005f:34). This section helps furthers these decision-making objectives. 

This section does not assign a dollar value to resources impacted by invasive weeds. It is difficult to assess the 

monetary value for many of the resource values obtained from public lands. The various degrees of infestation 

would add complexity to those estimates. However, the various resource-specific sections in this Chapter describe 

the negative effects in qualitative terms. Invasive weeds increase management costs, decrease resource values and 

outputs, and exacerbate the effects of natural and human-caused resource disturbances. See Cumulative Effects at 

the end of this section for further discussion. 

Treated Acres and Effectively Treated Acres, by Alternative 

Treated Acres 

An estimate of the acres of noxious weeds and other invasive plants that would be treated annually with each 

herbicide and each non-herbicide treatment method, for each alternative, is presented in Table 3-3. Also included are 

estimated acres of rights-of-way/recreation site/administrative site herbicide treatments, and habitat and other noncommodity vegetation treatments that would occur with herbicides if herbicides were available for those purposes 

(Alternatives 4 and/or 5). Table 3-3 acres are a compilation of estimates made by the nine BLM districts in Oregon 

using a “current budget trends” assumption, and represent an estimated average annual treatment level for the next 

10 to 15 years. Table 3-3 acres applicable to this cost analysis are summarized in Table 4-31 below, for reference. 

Actual annual treatment levels could vary based on changes in program emphasis or priorities, fluctuations in 

annual budgets, opportunities for cost savings with partnerships, and the availability of external funding. Since 

project related actions may be implemented through cooperative agreements, multiple partners may bear these 

costs. State and local governments, adjacent land owners, Cooperative Weed Management Areas, interest groups, 

and right-of-way and other permit holders will contribute to or fully fund some vegetation treatments, especially 

where those parties own, or have interests in, a potentially affected area or development. Although a rough 

estimate of the percentage of each vegetation treatment category to be accomplished by Federal versus nonFederal work forces is possible (to identify BLM’s portion of the work), especially for rights-of-way and related 

work in Alternatives 4 and 5, such a breakdown is not necessarily relevant to comparing the alternatives, since 

most costs are ultimately borne by (and benefits accrue to) a general cross section of the public72. Therefore, 

the estimated costs and benefits of all herbicide uses on BLM lands that would occur under each alternative are 

reported together and not allocated between partners (Table 4-31). 

72 Most rights-of-way treatments, for example, would be done by the State, counties, or utility companies and costs are 

borne by taxpayers or ratepayers. 303 
 

 304 

73 Not being able to kill the weed does not mean the treatments are a waste of time. Treatments may prevent seed 

production or other spread, and thus meet objectives of containing infestations and preventing spread. 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Effectively Treated Acres 

The Noxious Weeds and other Invasive Plants section in this Chapter explains that invasive weed control 

treatments are not 100 percent effective at controlling invasive weed populations on the first try. Under each 

alternative, some level of retreatment would be necessary to achieve complete control. A five-acre treatment, for 

example, would be monitored to detect additional or remaining plants, and some portion of those acres would 

likely require retreatment. The amount of retreatment necessary is a function of how effective the prior treatment 

is. For Alternative 1, for example, nearly two-thirds of the noxious weeds in Oregon cannot be effectively 

controlled with non-herbicide methods. Further, non-herbicide methods (particularly mechanical and directed 

livestock treatments) often disturb soils leading to reinvasion, and plants are more likely to be moved off site. 

Also, mechanical treatments of re-sprouting woody species may temporarily reduce the vigor of these species, but 

not kill the weed.73 

“Effective” treatments for each alternative are the portion of the treatments that successfully control the invasive 

weeds on the treated site and thus prevent future weed spread. The percentage of treatments meeting this 

definition varies by alternative and is estimated to be 30, 60, and 80 percent of the total weed treatments for 

Alternatives 1, 2, and 3-5 respectively (Table 4-31). It is most appropriate to look at cost per effectively treated 

acres, because the overarching objective is to control weeds and prevent their spread. The efficacy of herbicide 

treatments for objectives other than control of invasive plants under Alternatives 4 and 5 is assumed to be 

effective, since complete plant removal is not the objective. 

Table 4-31. esTimaTed annUal acres of noxioUs/invasive Weed TreaTmenT by alTernaTive 

Method Alt . 1 Alt . 2 Alts . 3-51 

Invasive with non-herbicide methods 42,100 28,800 28,100 

Invasive with herbicide methods - 16,700 30,300 

Total Treated 42,100 45.500 58,400 

Percent Effective2 30 % 60 % 80 % 

Total Treated Effectively 12,630 27,300 46,1603 

1 The noxious/invasive weed portions of Alternatives 3 through 5 are the same. 

2

 From the Noxious Weeds and other Invasive Plants section in this chapter. 3

 Does not include 2,350 acres of noxious weeds inadvertently killed by right-of-way treatments of native plants in Alternatives 4 and 5 and not included in 

invasive weed cost per acre calculations. 

Costs by Treatment Method 

Direct project-level costs were provided by each of the nine BLM districts for herbicide treatments and for 

non-herbicide methods. Costs include equipment, materials, wages, and contract costs; they do not include 

program planning (e.g. NEPA) or overhead. Costs on the east and west sides of the Cascades are averaged 

separately because there are substantial differences between the two areas in terms of factors that affect costs, 

like topography, size and density of vegetation, and moisture regime. The acreage-weighted averages of these 

estimates are shown in Table 4-32. Costs are not discounted since all costs are annual averages in 2008 dollars, 

and apply to all years. Providing a discounted total of all costs over the next 10 or 15 years would not change the 

relative difference between the alternatives. 
 

 

 

 

 

 

 

 

 

 

Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Herbicide application costs were averaged even though the cost of the herbicides themselves varies. The 

potential difference the additional calculations would have made was not judged to be significant to a reasonable 

comparison of the alternatives. 

Table 4-32. average direcT cosT of TreaTmenT by TreaTmenT meTHod, Per acre, easT and WesT of THe cascades 

Method Cost per acre 

Non-herbicide 

Mechanical East-side $222 

West-side $225 

Manual East-side $90 

West-side $345 

Prescribed Fire for Weed Control East-side $48 

West-side $340 

Directed Livestock East-side $250 

West-side $284 

Seeding of Planting East-side $108 

West-side $199 

Herbicides: Noxious & Invasive Weeds 

Herbicide Application East-side $118 

West-side $107 

Herbicides: ROWs & Wildlife/Other 

Herbicide Application East-side $118 

West-side $107 

Total Cost and Cost per Effectively Treated Acre by Alternative 

The noxious weed and other invasive plant control treatment acres are predicted to increase under alternatives making 

more herbicides available, e.g. Alternative 3 would treat more acres than Alternative 2, and Alternative 2 would treat 

more acres than Alternative 1. This increase is primarily because 1) the additional herbicides provide tools to control 

weeds not presently treated or at least not treated effectively, 2) the additional herbicides make control treatments 

more efficient and therefore more treatments can be done within existing funding, and 3) approving herbicides 

currently used on adjacent non-BLM lands would encourage cooperative weed management across ownerships. 

Total costs increase as successive alternatives treat more acres. However, the cost per effectively treated acre 

decreases as the effectiveness of the alternatives increases (Table 4-33). This decrease is wholly related to the 

increased efficiency of having more control tools available. 

Table 4-33. annUal cosT of noxioUs/invasive Weed TreaTmenT Per alTernaTive 

Method Alt . 1 Alt . 2 Alts . 3-51 

Non-Herbicide 

East-side Total Cost $4,769,567 $2,741,639 $3,627,714 

West-side Total Cost $2,371,941 $1,921,718 $1,806,178 

Herbicide 

East-side Total Cost $1,141,903 $2,625,201 

West-side Total Cost $746,200 $852,800 

Total cost $7,141,508 $6,551,460 $8,911,892 

Cost per acre effectively treated $565 $240 $193 

1 The noxious/invasive weed portions of Alternatives 3 through 5 are the same. 

305 
 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Effects by Alternative 

Alternative 1 – No Herbicide Use 

The annual cost of implementing treatments is greater than Alternative 2 (in spite of fewer acres treated), but less 

than all other alternatives at a total of $7,141,508 in 2008 dollars (Table 4-34). Despite the relatively lower cost 

of treatment, the cost per acre treated effectively is the highest of all alternatives at $565 per acre (Table 4-33). 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

The annual cost of implementing treatments is $6,551,460 in 2008 dollars, the least of all alternatives. Costs of 

herbicide treatment for invasive plants are less than the cost of herbicide treatments under the action alternatives 

for both the east and west-sides. However, reduced effectiveness of treatment makes the treatment cost per acre 

higher than the action alternatives, at $240 per acre (Table 4-33). 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

The annual cost of implementing treatments is more than Alternative 1 and the No Action Alternative at 

$8,911,892 in 2008 dollars. However, increased effectiveness of treatment makes the treatment cost per acre 

lower than all other alternatives at $193 (Table 4-33). 

Although indirect benefits of each alternative are qualitatively discussed at the end of this section, it should be 

noted that an effect specific to this alternative would be the ability to control invasive annual grasses, potentially 

reducing the risk of wildfire adjacent to communities (the wildland-urban interface) east of the Cascades. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses and Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity 

Vegetation Management Objectives 

The effects and costs for Alternative 3 apply equally to the noxious weeds and other invasive plant treatment 

portion of Alternatives 4 and 5 as well. However, Alternative 4 would also make herbicides available for treating 

native vegetation interfering with (encroaching on) the safety and function of rights-of-way, administrative sites, 

and recreation sites (9,300 acres), and for certain habitat treatments (5,700 acres). Alternative 5 would include 

all of the treatments in Alternative 4, and would add about 4,900 more acres of herbicide treatments for habitat 

improvement and other non-commodity vegetation management. Only these additional uses are discussed here. 

Rights-of-Way, Administrative Sites, and Recreation Sites 

For controlling native vegetation affecting the safety and function of rights-of-way, administrative sites, and 

recreation sites, agencies and partners are currently accomplishing needed native vegetation control work with 

non-herbicide methods. The 9,300 acres proposed for herbicide use for these objectives under Alternatives 4 and 

5 (Table 3-3) thus represent a corresponding number of acres of non-herbicide treatments already taking place.74 

(The remainder of annual vegetation treatment needs along rights-of-way and other developments would continue 

to be accomplished with non-herbicide methods.) For cost comparison purposes, 10 percent of the herbicide 

treatments are assumed to replace existing manual treatments, while 90 percent are assumed to replace existing 

mechanical methods. Using herbicides to meet the annual vegetation control needs on 9,300 acres of rights-ofway, roads, and around other developments would save nearly $1 million per year (Table 4-34). 

74 These current ROW and other sites non-herbicide native vegetation treatments are not displayed on Tables 3-3 or 4-31 

to avoid confusion with the non-herbicide noxious weed/invasive plant control treatments 

 306 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

 

307 

Habitat and Other Non-Commodity Objectives 

Of the acres proposed for herbicide use to accomplish habitat improvement objectives under Alternative 4 (5,700 

acres), and wildlife and other non-commodity objectives under Alternative 5 (an additional 4,900 acres), about 35 

percent are already being done with non-herbicide methods and 65 percent represents new opportunities because 

of the availability of herbicides. The 35 percent already being done with non-herbicide methods costs about $217 

per acre. Doing these same treatments with herbicides would cost an average of $117 per acre. The availability 

of herbicides would lead to the accomplishment of nearly three-times more acres in part because of the reduced 

cost, but in part because many needed treatments cannot be accomplished with non-herbicide methods because 

they would be too labor intensive, difficulties in targeting the correct plant species or age group, or would cause 

site disturbances that would negate all or part of the treatment objective. 

Alternative 4 would make herbicides available to treat any vegetation to achieve habitat goals specified in 

approved Recovery Plans, Conservation Strategies, or Conservation Agreements for listed Federally Listed or 

Bureau Sensitive species. The 5,700 acres of treatments proposed in Alternative 4 to meet this objective would 

cost $668,800 if accomplished with herbicides. No corresponding non-herbicide cost is calculated because the 

same acres would not be attempted with non-herbicide methods. 

In addition to the habitat treatments described for Alternative 4, Alternative 5 would make herbicides available 

for the full range of non-commodity objectives and uses approved nationally in the Record of Decision for the 

PEIS. Districts indicated most additional treatments under this alternative would be thinning Western juniper and 

sagebrush for habitat improvement, or possibly treating fuels east of the Cascades, although other non-commodity 

uses are possible. The additional 4,900 acres projected to be treated to meet these objectives under Alternative 5 

would cost $574,700 if accomplished with herbicides. No corresponding non-herbicide cost is calculated because 

the same acres would not be attempted with non-herbicide methods. 

Non-Quantified and Cumulative Effects 

Management of invasive plants affects the goods, services, and uses provided by BLM land and the costs of 

managing those lands. Increased operating costs due to invasive plant management may result in direct or indirect 

transfer of costs to land management programs or users of BLM lands. Noxious weed and other invasive plant 

management may compete with other important land management needs, resulting in cost tradeoffs; management 

of timber, vegetation, roads, public access, grazing, recreation, habitat, minerals, and fire may be affected by cost 

increases or loss of opportunity due to invasive plant management. Invasive plant and other treatments would 

result in improvements in the condition of BLM resources and would lead to increases in commodity and noncommodity values. Treatments would also increase the quantity and quality of wildlife forage, reduce fire hazard, 

and reduce other negative effects from noxious weed and other and invasive plant spread. Improved recreation 

opportunities, reductions in risk of wildfires, improvements of rights-of-way, and habitat improvements would 

benefit the economies of rural communities, which are often dependent on recreational opportunities and other 

natural resource-based businesses. 

Table 4-34. annUal cosT for roW/adminisTraTive siTes/recreaTion siTes TreaTmenTs. 

Alts 1-3 (Non-herbicide) Alts 4 and 5 (Herbicide) 

Treatments for ROW/admin sites/recreation site objectives 

east side cost $1,566,188 $882,915 

west side cost $449,752 $202,540 

Total cost $2,015,940 $1,085,455 

Acres 9,300 9,300 

Average Cost per Acre $217 $117 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Human Health and Safety 

Affected Environment 

Background Health Risks 

People living in Oregon are exposed to a variety of risks common to the U.S. as a whole, including automobile 

accidents and other injuries; contaminants in the air, water, soil, and food; smoking, alcohol and various diseases. 

Risks to workers may differ from those facing the public, depending on the nature of a person’s work. Some of 

these risks may be quantified, but a lack of data allows for only a qualitative description of certain risks. Human 

Health information was obtained from the Centers for Disease Control and Prevention (CDC), the National 

Center for Injury Prevention and Control (NCIPC), the National Center for Health Statistics (NCHS), the National 

Institute for Occupational Safety and Health (NIOSH), and the Bureau of Labor Statistics. 

Risks from Diseases 

Disease Incidence 

Despite the difficulties in establishing correlations between work conditions and disease, only certain illnesses 

have been linked to occupational hazards. For example, asbestosis and lung cancer among insulation and 

shipyard workers has been linked to their exposure to asbestos (NTP 2009). Pneumoconiosis among coal miners 

has been correlated with the inhalation of coal dust. Occupational exposures to some metals, dusts, and trace 

elements, carbon monoxide, carbon disulfide, halogenated hydrocarbons, nitroglycerin, and nitrates can result 

in increased incidence of cardiovascular disease. Neurotoxic disorders can arise from exposure to a wide range 

of chemicals, including some pesticides.75 Dermatological conditions like contact dermatitis, infection, trauma, 

cancer, vitiligo, urticaria, and chloracne have a high occurrence in the agricultural, forestry, and fishing industries. 

Injury and Disease Mortality 

Mortality rates for Oregon compared with national statistics are listed in Table 4-35. The five most common 

causes of death in the U.S., as well as in Oregon, are heart disease, cancer, cerebrovascular disease (stroke), 

respiratory disease, and accidents. Oregon has lower than average mortality rates for cancer, heart disease, and 

injuries and higher incidence for stroke and respiratory disease. 

Risks from Cancer 

Cancer Incidence 

Nationwide, the chance of developing some form of cancer during one’s lifetime is estimated to be about one 

in three (NCI 2005). There are many causes of cancer development, including genetic, viral, and occupational 

exposure to carcinogens, environmental contaminants, and substances in food. In the U.S., one-third of all 

cancers are attributed to tobacco smoking. Work-related cancers are estimated to account for 4 percent to 20 

percent of all malignancies. It is difficult to quantify the information because of the long time intervals between 

exposure and diagnosis, personal behavior patterns, job changes, and exposure to other carcinogens. The NIOSH 

75 Pesticides include insecticides, rodenticides, fungicides, herbicides, and other “pest” control materials. 

 308 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

 

309 

has reported that approximately 20,000 cancer deaths and 40,000 new cases of cancer each year in the U.S. are 

attributable to occupational hazards. Millions of U.S. workers are exposed to substances that have tested as 

carcinogens in animal studies (NIOSH 2009b). 

Cancer Mortality 

Cancer accounted for 23 percent of all deaths in Oregon in 2003. Nationwide, cancer accounts for approximately 

24 percent of all fatalities (NCHS 2007). Generally, males have higher rates of cancer mortality than females, and 

African Americans have higher rates than Caucasians. 

Table 4-35. leading caUses of deaTH by PercenTage 

Oregon U .S . 

Cancer 23.4 24.3 

Heart Disease 22.7 27.2 

Cerebrovascular Disease 8.3 5.0 

Chronic Lower Respiratory Disease 5.9 5.0 

Accidents 4.5 6.1 

Oregon numbers are from DHS (2002); U.S. numbers are from NCHS (2007). 

Injury Risk from Using Herbicides and Non-Herbicide Treatments 

Manual and mechanical treatments can present health hazards to forestry workers. Adverse weather and terrain 

commonly create unfavorable working conditions and increased hazards. Hazards associated with adverse 

weather conditions include extreme heat and cold, which can be exacerbated by very dry and very wet conditions. 

Other hazards include falling objects (especially when cutting trees), tripping or slipping on hazards on the 

ground, protruding objects such as branches and twigs, poisonous plants and insects, and dangerous wildlife. 

Tools and equipment present inherent hazards, such as sharp edges on the tools themselves, and the hazardous 

nature of fuels and lubricants used in mechanized equipment. Manual and mechanical methods present potential 

ergonomic hazards related to lifting and carrying equipment, and when pulling vegetation. 

Injuries can vary from minor cuts, sprains, bruises, and abrasions to major arterial bleeding, compound bone 

fractures, serious brain concussions, and death. Workers are subject to heat-related illness or hypothermia 

when working in extreme weather conditions, and may incur musculo-skeletal injuries related to improper body 

mechanics. 

Equipment operators could be injured from improperly operating the equipment or losing control of equipment on 

steep or slippery terrain. Operators and nearby workers can also suffer hearing damage. Nearby workers and the 

public can be struck by flying debris around some machinery. 

The potential for hazard exposure (risk of injuries) is exacerbated when workers are fatigued, poorly trained, 

poorly supervised, or do not follow established safety practices. Appropriate training, together with monitoring 

and intervention to correct unsafe practices, would minimize risk of worker injury and illness. Compliance 

with Occupational Safety and Health Administration (OSHA) standards, along with agency, industry, and 

manufacturers’ recommendations reduces the potential exposure and risk of injury to workers. Members of the 

public are usually not at risk from manual and mechanical methods unless they are too close to machinery that is 

producing flying debris during treatment. 
 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Statistics on injuries from herbicide application, mechanical treatment, and prescribed fire are sparse. Workrelated pilot fatalities in agriculture have a fatality rate of 70 per 100,000, third highest in the United States far 

exceeding the overall occupational fatality rate of 4 per 100,000. Only timber cutters and fishing industries have 

higher rates and these workers have fatality rates eight times the average worker rate (CDC 2004, USBLS 2008). 

Agriculture and forestry activities have among the highest injury rates (USBLS 2008). Use of chainsaws and 

mowers in mechanical treatments can lead to injuries. Likewise, prescribed fire presents hazards from inhaling 

particulates. Fatalities have been caused by prescribed fire (NIOSH 2009a). 

Use of all terrain vehicles (ATVs) for herbicide application and prescribed fire has also caused injuries and 

fatalities. In response to this, BLM has conducted research to evaluate the type of vehicle, load size, slope, and to 

establish policy and training to make ATV application safer (Morin 2008). This research has been used by OSHA, 

the Consumer Product Safety Commission, and the EPA to promulgate regulations for ATV use. 

Injuries from vegetation treatment are related to the percentage of acres treated by method. For instance, under 

the No Action Alternative (Alternative 2), 2 percent of acres treated are aerial application of herbicide and 32 

percent are ground application. Twelve percent of acres treated are manual or mechanical treatment and another 

12 percent of acres are treated by prescribed fire. The remaining acres are treated with bio-control, directed 

livestock, or seeding and planting. 

No injuries to herbicide applicators from herbicide exposure have been recorded during the past five years on 

BLM lands in Oregon (Thompson, T. pers. comm.) 

Environmental Consequences 

Herbicides are formulated to affect plant growth; some mimic plant hormones (auxins), others affect 

photosynthesis, amino acid, or lipid synthesis, or disrupt plant cell membranes. While they are selective for 

plants and among plants, they have the potential to affect human health if used improperly. The use of herbicides 

under a variety of application methods, as proposed in this EIS, involves potential risk or the perception of 

risk to workers and members of the public living or engaging in activities in or near herbicide treatment areas. 

Therefore, risk assessments were conducted to evaluate potential human health risks that could result from 

herbicide exposure both during and after treatment of public lands. See Chapter 3 and Tables 3-16 through 3-21 

for more explanation of the process and a summary of the risk ratings under various exposure scenarios. 

Methodology for Assessing Effects 

For the PEIS, the BLM completed risk assessments to evaluate potential risks to human health from exposure 

to the following six active ingredients: dicamba, diflufenzopyr, diquat, fluridone, imazapic, and sulfometuron 

methyl. Diflufenzopyr was assessed only in formulation with dicamba. The remaining 12 active ingredients 

addressed in this EIS were evaluated in other risk assessments. The BLM relied on risk assessments prepared in 

recent years by the Forest Service to evaluate the risks to human health associated with nine active ingredients 

(2,4-D, chlorsulfuron, clopyralid, glyphosate, hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr). 

For bromacil, diuron, and tebuthiuron, the BLM relied on information provided in an earlier BLM vegetation 

treatment EIS (USDI 1991), confirmed with a literature search for the PEIS. 

The following sections briefly discuss the risk assessment methods used by the BLM in the current assessment, the 

risk assessment methods used by Forest Service, and the methods used by BLM in the earlier EISs. More detailed 

information on the methodology used to evaluate risks, and the risk assessments themselves, are in Appendix 8. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

BLM Human Health Risk Assessment Methodology (2007) 

For dicamba, diflufenzopyr, diquat, fluridone, imazapic, and sulfometuron methyl, the PEIS followed the four-step 

risk assessment model identified by the National Academy of Sciences (NAS 1983). These steps are: 1) hazard 

identification; 2) dose response assessment; 3) exposure assessment; and, 4) risk characterization. The outcome of 

each of these steps is discussed below. The PEIS used herbicide toxicity factors from EPA that included system, 

neurologic, reproductive, and endocrine disrupting, and other endpoints. 

An exposure assessment was conducted to predict the magnitude and frequency of potential human exposure 

to the herbicides under consideration. Both worker and public (adult and children) exposures were evaluated. 

Exposures were evaluated for applications using the maximum application rate designated by the herbicide label, 

and applications using a typical application rate that was defined by BLM. 

Workers include those that mix, load, and apply herbicides and operate transport vehicles, recognizing that in 

some cases workers would perform multiple tasks, increasing his or her exposure. Both routine-use and accidental 

exposure scenarios were included in the worker evaluation. For the routine-use exposure scenario, the exposure 

assumptions were derived using information from the Pesticide Handlers Exposure Database, which is a generic 

database containing empirical dermal and inhalation exposure data for workers mixing, loading, or applying 

pesticides (EPA 1998). Accidental exposures for workers could occur via spills or direct spray onto a worker. 

Two types of public use exposure scenarios are addressed: 

•		 Potential exposure by the public during routine use of public lands to herbicide active ingredient(s) that 

have drifted outside of the area of application. 

•		 Accidental scenarios where the public prematurely enters a sprayed area (a reentry scenario), is sprayed 

directly, or contacts water bodies that have accidentally been sprayed directly or into which an herbicide 

active ingredient has been spilled. 

Based on consideration of potential public uses of BLM lands, and consistent with the 1991 Vegetation Treatment 

on BLM Lands in Thirteen Western States FEIS (USDI 1991), receptors (people exposed) evaluated included 1) 

hiker/hunter; 2) berry picker - child and adult; 3) angler; 4) swimmer - child and adult; 5) nearby resident - child 

and adult; and 6) American Indian - child and adult. It is assumed that the public could be exposed through one or 

more of the following exposure pathways: 1) dermal (skin) contact with spray; 2) dermal contact with foliage; 3) 

dermal contact with water while swimming; 4) ingestion of drinking water or incidental ingestion of water while 

swimming; 5) ingestion of berries; and, 6) ingestion of fish. 

AgDrift, a computer model sponsored by EPA and industry, was utilized to evaluate the off-site deposition 

of herbicides (SDTF 2003). The GLEAMS model was used to simulate surface runoff of the three terrestrial 

herbicides (see Appendix 8). 

Forest Service Human Health Risk Assessment Methodology 

The Forest Service risk assessment methodology (used for 2,4-D, chlorsulfuron, clopyralid, glyphosate, 

hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr) was similar to that used by the BLM. In the 

exposure assessment phase, the Forest Service developed general and accidental exposure scenarios for workers 

expected to be handling the herbicides and for the public who could be inadvertently exposed to herbicides. 

General exposure for workers included exposure via directed foliar, broadcast ground, and broadcast aerial 

applications. Accidental exposure scenarios for workers included immersion or contaminated clothing and spills. 

Exposure scenarios for the public included: 1) direct spray; 2) dermal exposure from contaminated vegetation; 3) 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

consumption of contaminated water; 4) acute exposure via spills; 5) consumption of contaminated fish; and, 6) 

consumption of contaminated vegetation. 

The risk characterization process then compared the exposure assessment to the dose response assessment to 

determine a hazard quotient (HQ) for a specific exposure scenario. HQs were calculated by dividing the exposure 

level determined in the PEIS by the toxicity factor. A higher HQ indicates that the exposure level exceeds the 

toxicity factor. 

BLM Human Health Risk Assessment Methodology (1991) and Toxicology Literature Review 

Human health risk assessments for bromacil, diuron and tebuthiuron were conducted by the BLM for an earlier 

vegetation treatment EIS (USDI 1991). Literature reviews and evaluations were conducted for the period 1991 

to 1998 to assess whether toxicity data reported since the 1991 EIS would indicate that a new risk assessment 

should be conducted (e.g., if the new toxicity data suggested greater risks to humans) (McMullin and Thomas 

2000). Bromacil, diuron, and tebuthiuron did not have recent toxicity data suggesting additional risks to humans; 

therefore, the human health risks of these herbicides are reported using results from the earlier EIS. 

Uncertainty in the Risk Assessment Process 

The risk assessments conducted by the BLM and Forest Service incorporate varying conservative assumptions 

to compensate for uncertainties in the risk assessment process. Within any of the steps of the human health 

risk evaluation process, assumptions must be made due to a lack of absolute scientific knowledge. Some of the 

assumptions are supported by considerable scientific evidence, while others have less support. Every assumption 

introduces some degree of uncertainty into the risk evaluation process. Regulatory risk evaluation methodology 

requires that conservative assumptions be made throughout the risk assessment process to ensure that public 

health is protected. This conservatism, both in estimating exposures and in setting toxicity levels likely led to an 

exaggeration of the real risks of the vegetation management program to ensure any uncertainty was interpreted on 

the side of protecting human health. 

Effects Common to All Alternatives 

Human Health Risks Associated with Herbicides Evaluated in the 2007 BLM PEIS 

Tables 3-16 and 3-17 present summaries of the level of risk that workers and the public would face during 

the application of a given herbicide, for both maximum and typical application rate scenarios. Aggregated 

Risk Indices (ARIs) (see Chapter 3) are partitioned into no, low, moderate, and high levels of risk for ease of 

comparison. These designations are strictly for comparison purposes, and do not imply actual risks to people 

because SOPs, PEIS Mitigation Measures, site-specific mitigation, and actual application and exposure scenarios 

would lessen exposures from risk assessment levels. 

Dicamba applications present low risk to workers during accidental scenarios. Dicamba may results in reversible 

eye irritation and severe skin irritation. Risk to aerial and boat workers were not evaluated because dicamba is not 

applied aerially nor to aquatic sites. There is no measureable risk from dicamba under any of the public exposure 

scenarios. 

Diflufenzopyr: For workers, routine use ARIs were calculated for inhalation exposures under both typical and 

maximum application rate scenarios. No dermal toxicity values are available for diflufenzopyr, which, based on 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

laboratory data, is not expected to be toxic through the dermal route. Routine use ARIs are greater than 1 under 

both the typical and maximum application rate scenarios, indicating no exceedance of the EPA’s LOC (see Risk 

Assessments, Chapter 3). Because the accidental worker scenarios all assume dermal exposure and diflufenzopyr 

does not have a short-term dermal NOAEL, an accidental scenario ARI was not calculated. 

For the public, routine use scenario ARIs are greater than 1 under both the typical and maximum application 

rate scenarios for the public, indicating no LOC. Under the accidental scenario, it is assumed that the public is 

exposed directly to maximum herbicide application rates via dermal contact, incidental ingestion of water while 

swimming, or dietary exposure pathways at the maximum application rate. All accidental scenario ARIs are 

greater than 1, indicating risks are below the LOC. 

These results indicate that exposures to diflufenzopyr are not expected to exceed the EPA’s LOC for worker or the 

public under the scenarios evaluated. Risk to aerial and boat workers were not evaluated because diflufenzopyr is 

not applied aerially nor to aquatic sites. Risk to workers for accidental spill was not evaluated because there is no 

toxicity factor for oral exposure. 

Diquat: PEIS Mitigation Measures (Appendix 2) limit the use of diquat to aquatic treatments, and to typical 

application rates where feasible. At the typical application rate, diquat presents a low to moderate risk to some 

workers (all backpack and horseback applicators),76 and a low risk to child residents. When diquat is applied at 

the maximum application rate, there is low to high risk to workers (except boat applicators) and the public (except 

swimmers). Diquat poses a high risk to workers and a low to moderate risk to the public under all accidental 

scenarios. Diquat causes moderate acute dermal effects and reversible eye irritation. 

Fluridone: PEIS Mitigation Measures (Appendix 2) limit the use of fluridone to typical application rates, 

where feasible. Fluridone does not pose a risk to workers or the public when applied at the typical application 

rate. When fluridone is applied at the maximum application rate, there is low risk to aerial mixer/loaders. For 

accidental scenarios, fluridone poses a low to high risk to all workers, and a low risk to children and resident 

publics. Fluridone causes reversible eye irritation. 

Imazapic applications do not present risk to any the public or workers when applied in routine use situations 

at either the typical or maximum application rate. Accidental scenarios involving dermal contact with direct 

spray or vegetation or dietary exposure were not calculated because imazapic has not been shown to have acute 

dietary or dermal effects in hazard analyses conducted by the EPA (ENSR 2005l). Accidental scenarios involving 

dermal contact with a sprayed water body or a water body into which herbicide is spilled do not result in risk to 

swimmers. Risk to workers for accidental spill and to several public scenarios was not evaluated because there is 

no toxicity factor for oral exposure. 

Sulfometuron methyl applications do not present risk to human health when applied in routine use situations at 

either the typical or maximum application rate. Accidental scenarios involving dermal contact with direct spray 

or vegetation or dietary exposure were not calculated because sulfometuron methyl has not been shown to have 

acute dietary or dermal effects in hazard analyses conducted by the EPA (ENSR 2005l). Accidental scenarios 

involving dermal contact with a sprayed water body or a water body into which sulfometuron methyl is spilled do 

not present a risk to swimmers. Risk to workers for accidental spill and most public scenarios were not evaluated 

because there is no toxicity factor for oral exposure. The EPA has not developed any acute toxicity categories for 

sulfometuron methyl. 

76 Risks to aircraft loaders is also displayed in Chapter 3, but SOPs preclude aerial application of diquat. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Human Health Risks Associated with Herbicides Evaluated in the 2005 Forest Service EIS77 

Tables 3-18 and 4-19 present summaries of the level of risk that workers and the public would face during the 

application of a given herbicide, for both maximum and typical application rate scenarios. The Forest Service risk 

assessments presented the risk results as HQs, which were used to designate a risk level as no, low, moderate or 

high, for ease of comparison. 

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 of time. 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). 

In April 2009, the EPA released a final list of 67 pesticides that will be tested for potential to cause endocrine 

disruption. Glyphosate and 2,4-D are the only herbicides considered for use that are included in the EPA 

Endocrine Disruptor Screening Program (Federal Register 2009). 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 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 2004c), the EPA concluded that there is not sufficient evidence that 2,4-D is an endocrine 

disrupting chemical. 

Chlorsulfuron: For both workers and the public, most exposures to chlorsulfuron at the typical or maximum 

application rate would not pose a risk (SERA 2004a). Ground broadcast applications at the maximum application 

rate would pose a low risk to workers. 

Eye and/or skin irritation are likely to be the only overt effects of mishandling chlorsulfuron. Following industrial 

hygiene practices during the handling of the chlorsulfuron would eliminate or minimize these effects. 

Clopyralid: There are no risks to the public or workers associated with most of the anticipated typical and 

accidental exposure scenarios for clopyralid. Irritation and damage to the skin and eyes can result from direct 

exposure to relatively high levels of clopyralid; this is likely to be the only overt effect as a consequence of 

mishandling clopyralid (SERA 2004b). Children face low risk from consumption of water contaminated by an 

accidental spill. 

The human health risks of hexachlorobenzene and pentachlorobenzene were also analyzed in the Forest Service 

Human Health RA, as technical grade clopyralid may be contaminated with these chemicals. Hexachlorobenzene 

77 The 2,4-D risk assessment was updated in 2006. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

was evaluated for potential carcinogenicity. Based on the levels of contamination of technical grade clopyralid 

with hexachlorobenzene and pentachlorobenzene, and the relative potencies of these compounds compared to 

clopyralid, this contamination is not significant in terms of potential systemic toxic effects. In addition, the 

contamination of clopyralid with hexachlorobenzene does not appear to present any substantial cancer risk above 

the Forest Service cancer risk LOC of 1 in 1 million. 

Glyphosate: For both workers and members of the public, there are no risks associated with nearly all exposures 

to glyphosate at the typical or maximum application rate (SERA 2003a). The risk assessment calculated no 

risk for all but one of the tested scenarios. There is low risk to children in the public associated with accidental 

exposure to glyphosate consumption of contaminated water after an herbicide spill into a small pond. 

Endocrine disruption and glyphosate was studied by SERA in 2002. SERA reported, “Three specific tests on 

the potential effects of glyphosate on the endocrine system have been conducted and all of these tests reported 

no effects. The conclusion that glyphosate is not an endocrine disruptor is reinforced by epidemiological 

studies that have examined relationships between occupational farm exposures to glyphosate formulations and 

risk of spontaneous miscarriage, fecundity, sperm quality, and serum reproductive hormone concentrations... 

the approach taken in the SERA risk assessment is highly conservative and no recent information has been 

encountered suggesting that this risk assessment is not adequately protective of any reproductive effects that 

might be associated with glyphosate exposure.” 

Hexazinone: PEIS Mitigation Measures (Appendix 2) limit the use of hexazinone to typical application rates, 

where feasible, in addition to not allowing the application of hexazinone with an over-the-shoulder broadcast 

applicator. At typical and maximum application rates, all worker groups exposed to hexazinone may face risks, 

with the highest risks predicted for workers using an over-the-shoulder broadcast applicator (SERA 1997). 

Worker exposure is likely to exceed exposures that would generally be regarded as acceptable, if workers do 

not follow prudent handling practices that would minimize exposure. Workers exposed to hexazinone via direct 

and broadcast ground spray and aerial applications at the maximum application rate are at low risk. There 

would be a low risk associated with accidental exposure to hexazinone mixed for the maximum application rate 

via contaminated gloves (also low risk at the typical application rate) and via spills on lower legs. The most 

likely effects include irritation to the eyes, respiratory tract, and skin. Even under the most extreme exposure 

scenarios, outward toxic effects are not likely to be observed; however, the upper estimates of exposure levels 

could be associated with subclinical (non-symptomatic) effects and possible reproductive effects. In some 

accidental exposure scenarios, members of the public may face risks from exposure to hexazinone. At the typical 

application rate, there is low to moderate risk to the public associated with exposure to hexazinone under the 

following scenarios: direct spray of the entire body, acute consumption of water contaminated by a spill, and acute 

consumption of contaminated fish by the public and subsistence populations. For application at the maximum 

rate, the risks to the public associated with the above scenarios are low to moderate. The following additional 

scenarios pose a low risk: direct spray of the lower legs, acute and chronic consumption of fruit, and consumption 

of stream water contaminated by runoff or percolation. 

Imazapyr: Most exposures to imazapyr at either the typical or the maximum application rate do not present a risk 

to either workers or members of the public, suggesting that workers and the public would generally not be at any 

substantial risk from longer-term exposure to imazapyr even at the upper range of the application rate considered 

in the risk assessment (SERA 2004d). Eye irritation is likely to be the only overt effect as a consequence of 

mishandling imazapyr. This effect can be minimized or avoided by prudent industrial hygiene practices during 

the handling of the compound. 

Metsulfuron methyl: Typical exposures to metsulfuron methyl at the typical or maximum application rates do 

not present a risk to workers or the public (SERA 2004e). For workers, there is no risk associated with acute or 

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chronic exposure scenarios, even at the upper ranges of estimated dose. For members of the public, no risks were 

predicted for any of the exposure scenarios. From a practical perspective, eye and skin irritation are likely to be 

the only overt effects of mishandling metsulfuron methyl. These effects can be minimized or avoided by prudent 

industrial hygiene practices during the handling of this compound. 

Picloram: Typical exposures to picloram at either the typical or maximum application rates present few risks to 

workers or the public (SERA 2003b). For workers, no risks were predicted even at the upper ranges of exposure. 

For members of the public, no risks were predicted except for the consumption of water by a child following an 

accidental spill of a large amount of picloram into a very small pond, which presents a low risk. From a practical 

perspective, eye irritation and skin sensitization are likely to be the only overt effects as a consequence of 

mishandling picloram. Based on the standard assumptions used in this and other Forest Service risk assessments, 

the contamination of picloram with hexachlorobenzene does not appear to present a substantial cancer risk, even 

at the upper ranges of plausible exposure. 

Triclopyr: PEIS Mitigation Measures (Appendix 2) limit the use of triclopyr to typical application rates, where 

feasible. Workers face low risk from directed and broadcast ground spray and aerial applications at the upper 

ranges of exposures for both evaluated forms of triclopyr (triclopyr acid and triclopyr BEE), at the maximum 

application rate (SERA 2003c). At the maximum application rate, workers face low risk from accidental 

exposure to contaminated gloves (1-hour duration). Thus, for workers who may apply triclopyr repeatedly over 

a period of several weeks or longer, it is important to ensure that work practices involve reasonably protective 

procedures to avoid the upper extremes of potential exposure. At higher application rates, measures that limit 

exposure should be developed on a case-by-case basis depending on the application rate and method. There 

is low to moderate risk to the public from triclopyr applications under several acute or accidental scenarios: 

1) direct spray to the entire body; 2) direct spray to the lower legs; 3) dermal contact with contaminated 

vegetation; 4) acute consumption of contaminated fruit (maximum application rate only); and 5) acute 

consumption of pond water contaminated by a spill. 

Human Health Risks Associated with Herbicides Evaluated in the 1991 BLM EIS 

The human health risks of bromacil, diuron, and tebuthiuron were evaluated in an earlier BLM vegetation 

treatment EIS. These herbicides were not reevaluated because a literature review and evaluation showed that 

most toxicity values for these herbicides reported in more recent studies were not substantially lower (i.e., present 

more risk) than the values used to assess risks to human health in the 1991 EIS (McMullin and Thomas 2000). 

Tables 3-20 and 3-21 present summaries of the risks to workers and the public associated with these herbicides. 

Bromacil: PEIS Mitigation Measures (Appendix 2) limit the use of bromacil to typical application rates, where 

feasible. According to the 1991 EIS, there would be a risk to workers associated with several exposure scenarios 

involving typical bromacil application practices. Pilots and aerial mixer-loaders face a risk for systemic, 

reproductive, and cancer effects from typical and maximum exposures to bromacil. Backpack and hand 

applicators and ground applicators, mixer-loaders, and applicator/mixer-loaders are also at risk for systemic and 

reproductive effects from maximum exposures. Risks for systemic, reproductive, and cancer effects to workers 

and the public are associated with accidental scenarios of spill to skin (concentrate and mixture), direct spray (no 

cancer risk), consumption of fish from a directly sprayed water body (no cancer risk), consumption of directly 

sprayed berries (no cancer risk), and drinking from water contaminated by a truck spill or a jettison of mixture 

(no cancer risk). The cancer slope factor for bromacil used in the Human Health Risk Assessment was the one 

available from the EPA at the time of the 1991 EIS. However, in its most recent review of bromacil, the EPA did 

not provide a cancer slope factor (EPA 1996), therefore bromacil is likely not carcinogenic. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Diuron: PEIS Mitigation Measures (Appendix 2) limit the use of diuron to typical application rates, where 

feasible. According to the 1991 EIS, there are risks to workers and the public associated with both routine and 

accidental exposures to diuron. Aerial application poses a risk to most evaluated the public for systemic effects 

from worst-case exposures (e.g., direct exposure of hikers, berry pickers, anglers, and nearby residents; spray drift 

to skin; vegetation contact by berry pickers; consumption of contaminated drinking water and fish). Berry pickers 

also face a risk for systemic effects from worst-case direct exposure and contact with vegetation scenarios. In 

aerial application scenarios, pilots and mixer-loaders are at risk for systemic and reproductive effects under both 

typical and worst-case exposures, and fuel-truck operators are at risk for systemic and reproductive effects under 

worst-case exposures. In addition, backpack and hand applicators and ground applicators, mixer-loaders, and 

applicator-mixer-loaders are at risk for systemic and reproductive effects for typical (systemic only) and worstcase exposures. There are also risks to workers and the public for systemic and reproductive effects associated 

with accidental exposures of spill to skin (herbicide concentrate and mixture), direct spray, drinking, or eating 

fish from a directly sprayed water body, or immediate reentry into a sprayed area by a berry picker. Diuron is a 

suspected carcinogen, and possible endocrine disruptor. 

Tebuthiuron: PEIS Mitigation Measures (Appendix 2) limit the use of tebuthiuron to typical application rates, 

where feasible. According to the 1991 EIS, tebuthiuron poses health risks to workers under various application 

scenarios. Typical and worst-case aerial application exposure to tebuthiuron could result in systemic and 

reproductive effects to pilots and to mixer-loaders (no systemic risk at typical exposures). Fuel-truck operators 

could experience systemic effects from worst-case exposure to tebuthiuron during aerial application. Backpack 

applicators face systemic and reproductive risks from maximum exposures to tebuthiuron. For workers using 

ground mechanical equipment, there are systemic and reproductive risks to applicators, mixer-loaders, and 

applicator/mixer-loaders associated with worst-case exposures to tebuthiuron. Hand applicators are at risk from 

typical (reproductive effects) and worst-case (systemic and reproductive effects) exposures. Several accidental 

scenarios also pose a risk for systemic and reproductive effects to workers and the public: 1) spill of herbicide 

mixture to skin; 2) direct spray to person; 3) drinking directly sprayed water (reproductive only); 4) immediate 

reentry of a berry picker into a sprayed area; 5) consumption of directly sprayed berries; and 6) consumption of 

water contaminated by a jettison of mixture or by a truck spill. 

Potential Endocrine Disrupting Chemicals 

According to the World Health Organization (2002), endocrine disrupters have been defined as exogenous 

substances that alter function(s) of the endocrine system and consequently cause adverse health effects in an 

intact organism or its progeny, or in (sub) populations. Endocrine disrupters interfere with the functioning of the 

endocrine system, in at least three possible ways: 

•		 By mimicking the action of a naturally-produced hormone, such as estrogen or testosterone, and thereby 

setting off similar chemical reactions in the body; 

•		 by blocking the receptors in cells receiving the hormones (hormone receptors), thereby preventing the 

action of normal hormones; or, 

•		 by affecting the synthesis, transport, metabolism, and excretion of hormones, thus altering the 

concentrations of natural hormones. 

During the toxicity review for the Human Health and ecological risk assessments, no endocrine disrupting 

effects were noted. However, an extensive literature search revealed that diuron and 2,4-D are listed by the 

European Commission Directorate-General for the Environment (2000) as Category 2 chemicals, meaning that 

there is evidence of the potential for the listed chemical to cause endocrine disruption. Diuron only appeared 

on a single list, so there is some uncertainty within the scientific community about this herbicide’s status as an 

endocrine disruptor. 

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In the Human Health Risk Assessment conducted to support the reregistration of 2,4-D (EPA 2004c), the EPA 

concluded that there is not sufficient evidence that 2,4-D is an endocrine disrupting chemical. The EPA did not 

conduct the human health risk assessment using endocrine disruption endpoints. Since the current studies that 

showed evidence of endocrine effects were tested using doses above renal saturation, the EPA recommended 

formal testing of 2,4-D for endocrine endpoints. However, there is no standard protocol for determination of 

endocrine effects of chemicals. 

Adjuvants 

Various sources of toxicity data (Muller 1980, Lewis 1991, Dorn et al. 1997, Wong et al. 1997) suggest that, for 

herbicides with high application rates, adjuvants have the potential to cause acute, and potentially chronic, adverse 

effects to aquatic species. Adjuvants and degradates were examined in the PEIS. 

The adjuvant POEA was present in the formulations of glyphosate examined in the risk assessments but is not 

present in all formulations. Glyphosate with POEA is potentially toxic to fish (discussed in the Fish section), but 

there is no evidence humans approach LOCs under any exposure scenario. 

The adjuvant R-11 is a nonylphenol ethoxylate that is acutely toxic to aquatic life (Stark and Walthall 2003) and 

is suspected to be an endocrine-disrupting chemical (Bakke 2003). The BLM has decided to suspend the use of 

R-11 in its herbicide applications. 

Human Health Risks by Application Method 

Air: Aerial applications of herbicides generally pose a greater risk due to off-site drift than ground applications, 

as herbicides applied at greater distances from the ground are able to drift farther from the target application area. 

Therefore, risks to the public recreating or living near an application area would extend out greater distances 

if the herbicide was applied aerially than if it was applied by a ground application method. The BLM does not 

apply dicamba, sulfometuron methyl, or diflufenzopyr by air. SOPs specify avoiding applying bromacil or diuron 

aerially, and limiting aerial application of chlorsulfuron and metsulfuron methyl to areas with difficult land access. 

Ground applications typically pose a lower risk to off-site humans than aerial applications because they are less 

likely to be exposed to spray drift. Similarly, 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 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 diquat and 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, but those applying diquat at the typical application rate by ATV or truck would not be at 

risk. In contrast, chlorsulfuron does not pose a risk to workers involved with aerial applications, but does pose a risk 

to workers conducting ground broadcast applications at the highest application rate. Exposure to hexazinone and 

triclopyr at the maximum rate has low risk to backpack and ground boom sprayers. 

Typical Application Rate 

PEIS Mitigation Measures limit the use of the following herbicides to the typical application rate, where 

feasible.78 Diquat is not applied to BLM lands aerially, and poses a low risk at typical rates under some worker 

78 SOPs specify typical rate, where feasible, for 2,4-D, bromacil, diquat, diuron, fluridone, hexazinone, tebuthiuron, and 

triclopyr to reduce the risk to occupational and public receptors (Appendix 2). 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

and public exposure scenarios. 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. Bromacil, diuron, hexazinone, 

triclopyr, and tebuthiuron also pose a risk to the public and workers when applied at the typical application 

rate. None of the other herbicides pose a risk to people when applied at the typical application rate (Tables 3-16 

through 3-21 and Table 4-36). 

Maximum Application Rate 

At the maximum application rate, more herbicides, in a greater number of exposure scenarios, have greater 

potential to affect human health. Fluridone, chlorsulfuron, clopyralid, glyphosate, picloram, and triclopyr do not 

pose a risk when applied at the typical application rate, but do pose a risk under one or more exposure scenarios 

when applied at the maximum application rate. Clopyralid, glyphosate, and picloram pose a low risk under 

the accidental scenario involving consumption of water from a small pond that has experienced a recent spill 

of herbicides mixed for the maximum application rate, which is a very unlikely scenario. In addition, a greater 

number of exposure scenarios have health risks from herbicide applications at the maximum application rate. 

Dicamba, diflufenzopyr, imazapic, imazapyr, metsulfuron methyl, and sulfometuron methyl do not pose a risk to 

any humans when applied at the maximum (or typical) application rate. 

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 SOPs. However, they are included on Table 4-36, Estimated Annual Acres of Treatments with Risk to 

Human Health. 

Human Health Risks 

Worker: 2,4-D, bromacil, diquat, diuron, and tebuthiuron pose risks to workers when applied at both typical 

and maximum application rates. Diuron poses a risk to most workers at the typical application rate. For 2,4-D, 

diquat, bromacil, and tebuthiuron, people working with aerial applications would be at low to moderate risk, even 

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. In addition, there are potential cancer risks to mixer/loaders of diuron. Mixer/ 

loaders working with aerial applications of fluridone are at low risk, and those working with bromacil, diuron, and 

tebuthiuron are at high risk when applying those herbicides at the typical and maximum application rates. 

Ground broadcast applicators are at risk from applying diuron at the typical application rate, and bromacil, 

chlorsulfuron, and tebuthiuron at the maximum application rate. All workers are at risk from applying 

hexazinone, tebuthiuron, and triclopyr at the maximum application rate. The rest of the scenarios of potential 

exposure to workers were not predicted. Workers involved in the aerial application of herbicides appear to be at 

greater risk than are other workers; however, the application method that creates the most risk to workers appears 

to depend on the herbicide, so application methods for each herbicide should be carefully evaluated with respect 

to potential human health risks. 

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. The public does not appear to be at risk from chlorsulfuron, dicamba, 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

diflufenzopyr, imazapic, imazapyr, metsulfuron methyl, or sulfometuron methyl applications (accidental scenarios 

were not evaluated for imazapic and sulfometuron methyl because these herbicides are not toxic through shortterm exposure for specific exposure routes). Diquat application at the typical application rate poses a low risk to 

children. At the maximum application rate, diquat poses a low to moderate risk to the public, except swimmers.79 

Under maximum application rates or accidental exposures, diuron poses a risk to the public under all treatment 

scenarios. In addition, 2,4-D, bromacil, clopyralid, diuron, fluridone, glyphosate, hexazinone, picloram, 

tebuthiuron, and triclopyr pose 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). For most herbicides 

(except diquat), risk to the public can be minimized or avoided by using the typical application rate, including 

other proposed mitigations, and following SOPs that greatly reduce the likelihood of accidents. 

Summary of Highest Human Health Risks 

Bromacil, diuron, diquat, and tebuthiuron have the highest health risks for workers. PEIS Mitigation Measures 

specify avoiding applying bromacil and diuron aerially. Bromacil, diuron, and tebuthiuron have the highest risks 

to some of the public. Diuron is a suspected carcinogen (ENSR 2005f). 2,4-D has possible endocrine disruption 

abilities in workers applying large amounts of 2,4-D and poses moderate to high risks to workers performing 

ground-based boom spraying. 

Cumulative Human Health Risks 

The human health risks from both herbicide and non-herbicide vegetation treatments are not unlike a host of other 

occupational risks throughout the west, as this section point out. The pounds of herbicide expected to be applied 

under the proposed action (Table 3-5) are less than two-tenths of one percent of the total pounds of herbicide 

applied in Oregon in 2008 (Cumulative Effects section near the start of Chapter 4). Other cumulative effects are 

described within this section. 

Effects by Alternative 

SOPs and PEIS Mitigation Measures are assumed to be observed. As described in the Affected Environment 

section, there is injury/fatality risks associated with prescribed fire and manual and mechanical vegetation control 

as well as with herbicides. Aerial spraying is hazardous to pilots, but the hours worked in aerial spraying are far 

less than hours worked for ground applications per acre. 

Because mechanical methods in Oregon often involve timber cutting (the most dangerous occupation of all), 

mechanical and fire methods are generally believed to be more hazardous to workers than use of herbicides. 

The criteria used in this section, and in Table 4-36, are: (1) relative risk of injury and disease between herbicide 

use and non-herbicide vegetation controls (e.g. mechanical and prescribed fire), (2) relative toxicity of herbicides, 

(3) acres treated, (4) mode of treatment (aerial versus ground application), and (5) population density. 

Alternative 1 – No Herbicide Use 

Alternative 1 would exclude human health risk associated with herbicide applications; risk to human health would 

be entirely from non-herbicide vegetation controls. 

79 SOPs preclude using diquat at maximum rate, or using aerial application. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Table 4-36: esTimaTed annUal acres of TreaTmenTs WiTH risk To Worker and PUblic HUman HealTH by 

alTernaTive 

West of the Cascades (population density: 1 person every 6.7 acres) 

Herbicide / 

Method Risk Rating 2 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 

2, 4-D M 1800 2100 2400 2500 

Diuron1 M 100 100 

Bromacil1 M 100 

Tebuthiuron1 M 100 

Total Moderate Risk Acres 0 1800 2100 2500 2800 

Hexazinone L 100 300 300 

Triclopyr L 1500 1900 2000 

Diquat L 100 

Total Low Risk Acres 0 0 1600 2200 2400 

Total No Risk Acres (Herbicides) 0 5500 5600 6500 7000 

Mechanical 4100 3300 3000 1,248 1,206 

Fire 600 600 400 400 400 

Total non-herbicide 4700 3900 3400 1648 1606 

East of the Cascades (population density: 1 person every 95.3 acres) 

Herbicide / 

Method Risk Rating 2 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 

2, 4-D M 6700 1900 3300 5400 

Diuron1 M 700 700 

Bromacil1 M 700 700 

Tebuthiuron1 M 100 300 

Total Moderate Risk Acres 0 6700 1900 4800 7100 

Hexazinone L 100 100 100 

Triclopyr L 700 2000 2300 

Diquat L 100 

Total Low Risk Acres 0 0 800 2100 2500 

Total No Risk Acres (Herbicides) 0 8800 20800 30600 32800 

Mechanical 1000 200 200 -7,705 -8,692 

Fire 3100 5100 12100 12100 12100 

Total non-herbicide 4100 5300 12300 4395 3408 

1

Mitigation measures adopted in the Record of Decision of the PEIS prohibit aerial application of this herbicide. Aerial application of herbicides is not 

allowed on west of the Cascades under Alternatives 3 and 4.
 2 All exposure scenarios, typical rate, from Tables 3-17 through 3-22.
 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

On the west side of the Cascades, invasive plants would be treated with mechanical methods and fire on 4,700 

acres, which is more than under any other alternative. Hence, risk from non-herbicide methods would be higher 

than under any other alternative. 

On the east side of the Cascades, acres treated with mechanical and fire account for 4,100 acres. This is less than 

most other alternatives. 

Alternative 2 (No Action) – Use 4 Herbicides to Treat Noxious Weeds Only 

Under Alternative 2, there would be human health risk from the application of 2,4-D. 2,4-D poses a moderate risk 

to workers and the public, which makes it one of the highest risk herbicides being proposed under any alternative. 

The other three herbicides proposed under this alternative are in the no risk category. 

On the west side of the Cascades, 1,800 acres of 2,4-D would be applied, which is less than under any other 

alternative (and hence less risk) except Alternative 1. Mechanical and fire treatments would happen on 3,900 

acres, which is less than Alternative 1, but more than under any other alternative (and hence more risk). 

East of the Cascades, 8,800 acres of 2,4-D would be applied. This is more 2,4-D than under any other alternative, 

and human health risk from herbicide use is higher than under most of the other alternatives. Mechanical and fire 

treatments would be the second highest of the alternatives (and hence the second highest risk). 

Aerial application of herbicides would account for 7 percent of the application, and almost all would occur east of 

the Cascades. 

Alternative 3 – Use 11 (W) or 13 (E) Herbicides to Treat Invasive Weeds and Control Pests and Diseases 

Under Alternative 3, triclopyr and hexazinone, which have a risk category of low, become available. 

West of the Cascades, the use of 2,4-D would increase slightly, which, along with 1500 acres of triclopyr and 

100 acres of hexazinone, makes this alternative slightly higher risk from herbicides than Alternative 2. Aerial 

application would not be allowed. Acres treated with mechanical and fires decrease, which would decrease risk 

from non-herbicide methods. 

East of the Cascades, the use of 2,4-D would drop 70 percent with addition of herbicides categorized as no risk. 

Imazapic is likely to be applied aerially for 90 percent of the imazapic acres, but imazapic has a risk category of 

no risk, and would be applied in areas with low population. Aerial methods will be used to apply 7 percent of the 

other herbicides. Risk from herbicides would be lower than under any other alternative. However, mechanical 

and fire methods are expected to increase significantly, and risks from non-herbicide methods would be higher 

than under any other alternative. 

Alternative 4 (Proposed Action) – Use 12 (W) or 16 (E) Herbicides to Treat Invasive Weeds plus Limited 

Additional Uses 

West of the Cascades, under Alternative 4, diuron, which is assigned a risk category of moderate, becomes 

available. The use of 2,4-D would increase slightly, which, along with 100 acres of diuron, makes this alternative 

slightly higher risk from herbicides than Alternative 2. Aerial application would not be allowed. Mechanical 

acres drop slightly, which would slightly decrease risk from non-herbicide methods. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

East of the Cascades, the use of 2,4-D would increase (but still be half of the Alternative 2 acres), and additional 

moderate risk herbicides would be available, which would more than double the use of moderate risk herbicides 

(when compared to Alternative 3). In addition, the low risk triclopyr acres would increase to 2000. Imazapic 

would be applied aerially for 90 percent of the imazapic acres, but imazapic has a risk category of no risk, and 

would be applied in areas with low population. Aerial methods would be used to apply 2-7 percent of the other 

herbicides. Under this alternative, rights-of-way, administrative sites, and recreation sites can be sprayed to control 

native vegetation, and this could have less selective treatments than under Alternatives 2 and 3. However, risk from 

herbicides would be still be lower than Alternative 2. Mechanical methods are expected to decrease significantly, 

and risks from non-herbicide methods would be lower than under Alternative 2 and 3, and similar to Alternative 1. 

Alternative 5 – Use 18 Herbicides to Treat Invasive Weeds and Meet Non-Commodity Vegetation 

Management Objectives 

West of the Cascades, under Alternative 5, the low and moderately rated bromacil, tebuthiuron, and diquat become 

available. The use of 2,4-D would increase slightly, which, along with 100 acres each of moderate risk bromacil 

and tebuthiuron, 2400 acres of low risk triclopyr, hexazinone, and diquat, makes this alternative higher risk from 

herbicides than Alternative 2. Aerial application would be allowed, but would be rare. Mechanical acres drop 

slightly, which would decrease risk from non-herbicide methods slightly. 

East of the Cascades, the use of 2,4-D would increase, and additional low risk herbicides would become available 

and the herbicide risk from the alternative would be the highest of the five alternatives. Imazapic would be 

applied aerially for 90 percent of the imazapic acres, but imazapic has a risk category of no risk, and would be 

applied in areas with low population. Aerial methods will be used to apply 2-7 percent of the other herbicides. 

Mechanical methods are expected to continue to decrease, and risks from non-herbicide methods would be lowest 

under this alternative. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Critical Elements of the Human Environment
 

Air Quality Air Quality is addressed in the Air Quality section.
 

American Indian American Indian religious concerns are addressed in the Paleontological and 

Religious Concerns Cultural Resources section.
 

Areas of Critical Areas of critical environmental concern are addressed in the Wilderness and Other 

Environmental Special Areas section.
 

Concern [ACECs]
 

Cultural Resources Cultural resources are addressed in the Paleontological and Cultural Resources
 

section. 

Energy Executive Order 13212 provides that agencies shall expedite review and...take 

action to expedite...projects that will increase the production, transmission, or 

conservation of energy. BLM Instruction Memorandum OR-2002-081 requires 

NEPA documents to contain information from which the BLM can later complete 

a Statement of Adverse Energy Impacts. Alternatives 1 could increase the 

maintenance costs for transmission wires or pipes, buried or not. Alternatives 4 and 

5 would reduce maintenance costs by making herbicides available to treat native 

vegetation within rights-of-ways. 

Environmental Environmental Justice is addressed in the Environmental Justice section. 

Justice 

Prime Farmlands 

or Unique Land 

Characteristics 

Prime farmlands and other unique Federal land characteristics are required to 

be identified and restored as part of the Surface Mining and Reclamation Act of 

1977. Any surface coal mining operations would fall under the requirements of the 

selected alternative. There are no BLM lands requiring restoration under this act. 

Floodplains Executive Order 11988, as amended, requires agencies to determine if a proposed 

action will occur in a floodplain and if the action will significantly affect the quality 

of the human environment. The objective of the law is to avoid adverse impacts 

associated with occupancy and modification of floodplains and to avoid floodplain 

development. The action alternatives themselves do not authorize any actions; only 

add tools for the control of invasive plants. By improving the control of invasive 

plants, the action alternatives could positively affect floodplains in ways that 

significantly affect the quality of the human environment. The potential effects of 

the alternatives on water flows that could affect floodplains are addressed in detail in 

the Wetlands and Riparian Areas and Water Resources sections. 

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Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

Invasive Species EO 13112 requires the prevention of introduction of invasive species and to provide 

for their control and to minimize their economic, ecological, and human health 

impacts. The Need to which this EIS responds is, in part, to be able to better meet 

BLM’s noxious weed responsibilities, and Alternatives 3-5 seek to more efficiently 

reduce the spread of noxious weeds and other invasive plants. 

Invasive and Nonnative Species 

The Lacey Act of 1981, as amended, makes it unlawful to import, export, sell, 

acquire, or purchase fish, wildlife, or plants. None of the alternatives propose such 

activities. 

Noxious Weeds The Federal Noxious Weed Act of 1974, as amended, requires carrying out 

operations or measures to eradicate, suppress, control, or prevent or retard the 

spread of any noxious weed. Alternative 3 and portions of Alternative 4 and 5 are 

specifically designed to further the objectives of this Act. 

Threatened or Federally Listed and Bureau Sensitive species of wildlife and plants are addressed in 

Endangered Species the Vegetation, Native Plants, and Plant Communities, Fish, and Wildlife Resources 

sections, and in Appendix 5, and in additional detail in the Biological Assessment of 

the PEIS which is incorporated in this EIS. There are several listed fish, plants, and 

terrestrial animals within the analysis area that could potentially be affected, usually 

positively at least in the long term. 

Wastes, Hazardous The Resource Conservation and Recovery Act of 1976 and the Comprehensive 

or Solid	 Environmental Response, Compensation, and Liability Act of 1980 are laws that 

regulate hazardous waste that endangers public health or the environment. The 

alternatives propose the use of herbicides, some of which may not be applied, may 

become outdated, and may require disposal in Class I dumps. Every effort is made 

to avoid this action. Empty containers will be triple rinsed and disposed of in 

approved dumps. 

Water Quality, The Water Resource section addresses water quality and conformance with State 

Drinking or Ground water quality standards. 

Wetlands/Riparian Executive Order 11990 requires Federal agencies to avoid destruction or 

Zones modifications of wetlands and to avoid undertaking or providing assistance for 

new construction located in wetlands. The alternatives themselves only authorize 

consideration of additional herbicides for the control of noxious weeds and other 

invasive plants in wetlands and riparian areas. These measures do not destroy, 

modify, or undertake/assist new construction located in wetlands. The action 

alternatives could variously benefit wetlands. 

Wild and Scenic Wild and scenic rivers are discussed in the Recreation / Interpretive Sites and the 

Rivers Wilderness and Other Special Areas sections. 

Wilderness	 Wilderness and wilderness study areas are discussed in the Wilderness and Other 

Special Areas section. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Other Environmental Consequences 

Consistent with the mandates of FLPMA and other laws and policies, the BLM and/or its cooperators manage 

vegetation on thousands of acres per year to restore forest and rangeland health; provide sustainable habitat for 

Bureau Sensitive, Federally Listed, and other species of plants and animals; reduce the risk of wildland fire; and, 

provide for safe use and access to a variety of authorized developments. For these treatments, a full range of nonherbicide treatment methods have been analyzed in existing resource management plan (RMP) or program NEPA 

documents, and are currently in use to achieve vegetation management objectives. A portion of the vegetation 

management program is focused on the control on noxious weeds, and the tools used for the noxious weed portion 

of the program currently include the use of four herbicides. RMP direction directing the control of noxious 

weeds is compiled for reference in Appendix 6. It is in this context that the alternatives examined in this EIS are 

presented. The proposal is to increase the number of herbicides available to the nine BLM districts in Oregon 

for use in their existing vegetation management programs. No additional types of work would be added by the 

action alternatives. Efficiency and quantity of vegetation management may go up as a result of selection of one of 

the action alternatives, but those effects would be within the scope of existing plans. No effects from any of the 

action alternatives, beyond those addressed within this Chapter, are anticipated. 

This EIS is programmatic; individual NEPA examinations will be made at the district and/or project scale to 

examine the potential for site-specific adverse effects. 

The Council on Environmental Quality regulations require that the discussion of environmental consequences 

include 

 . . . any adverse environmental effects which cannot be avoided should the proposal be implemented, the 

relationship between short-term uses of man’s environment and the maintenance and enhancement of longterm productivity, and any irreversible or irretrievable commitments of resources which would be involved 

in the proposal should it be implemented (40 CFR 1502.16). 

Adverse Effects Which Cannot Be Avoided 

An agency does not have to avoid adverse effects, but must identify and disclose any adverse environmental, 

social, and economic effects in the impact statement. This EIS attempts to describe all identifiable adverse effects 

caused by the alternatives herein. Adverse effects which cannot be avoided include the likely continued spread 

of some species of noxious weed and other invasive plants at some level. The action alternatives are predicted 

to slow, but not eliminate, the adverse effects of this spread.80 For some or possibly all areas, the benefits of the 

alternatives in terms of preventing infestations of some noxious weeds, or restoring native plant communities 

infested by them, may be transitory. 

There is also a low potential that the herbicide use proposed would contribute to the cumulative effect of 

herbicides, other pesticides, and other pollutants in some of Oregon’s waters. This EIS displays, in Chapter 3, 

the amount of each herbicide that would be used under the proposed action in the context of the total amount of 

those herbicides used statewide. The BLM could conceivably contribute to the amount of any of those herbicides 

that are found, for example, in the waters of the State. However, it is far more likely that because application 

80 Using “current budget trends” and the spread rates calculated in the Noxious Weeds and Other Invasive Plants section. 

The predicted spread rates could be incorrect, program emphasis may change, biocontrols may reduce the effect of 

weeds, and other factors outside the scope of this analysis may contribute to changes in weed spread rates in the future. 

 326 
Draft Environmental Impact Statement, Chapter 4: Affected Environmental and Environmental Consequences 

rates, streamside buffer distances, and other SOPs and PEIS Mitigation Measures, the percent applied with ground 

methods, the presence of environmental factors that will help hold and break down those herbicides, are all more 

positive than State-average applications (many of which are on agricultural lands), the BLM’s contribution to 

detectable off-site herbicide accumulations should be negligible. 

SOPs and PEIS Mitigation Measures, as well as potential mitigation measures listed in Chapter 2, should make 

the likelihood of adverse effects low. In any event, those likelihoods are described in their respective sections. 

The possible adverse effects include health effects to persons applying herbicides, particularly via spills and 

other accidents. Although no toxicity accident has been documented on BLM lands in Oregon in at least five 

years, they have certainly occurred in other states and could occur in Oregon in the future. Following prescribed 

procedures however, there is no evidence injury levels would significantly exceed those expected for industrial 

type work, or exceed those that would occur if the work were to be accomplished with non-herbicide methods. 

Relationship Between Short-Term Uses of the Human Environment and 

Maintenance of Long-term Productivity 

The proposed action is not an extraction or development. The action alternatives would help slow the spread of 

noxious weeds and other invasive plants, improve habitat, and make native vegetation control more effective and 

efficient (and potentially less impacting) than currently-used methods. The Soil Resources section in this Chapter 

concludes that the herbicides proposed would not have permanent effects on the soil. Some of the herbicides are 

known ground-water contaminants, and PEIS Mitigation Measures are offered to reduce the likelihood of BLM 

applications polluting water. 

Long-term productivity will be affected by noxious weeds, however, either by their displacement of native plant 

communities or by their allelopathic effects on soil, so native species are displaced. These effects can last for 

years or decades. The degree to which noxious weeds remain uncontrolled will affect long-term productivity. 

Irreversible or Irretrievable Impacts 

Irreversible refers to a loss of nonrenewable resources, such as mineral extraction, heritage (cultural) resources, 

or to those factors which are renewable over long time-spans, such as soil productivity. Irretrievable commitment 

applies to losses that are temporary, such as loss of forage production in an area being used as a ski run or use of 

renewable natural resources. 

The proposed action is not an extraction or development. The potential for damage to, or loss of, non-renewable 

cultural resources is addressed in this EIS. That portion of the analysis concluded that with required pre-project 

clearances and surveys in likely paleontological and historic areas, the likelihood of damaging sites during 

herbicide treatments was negligible. 

The spread of invasive weeds will likely cause irreversible and irretrievable impacts on many BLM sites in 

Oregon. Adverse and potentially long-term effects of noxious weed spread are documented in the analysis and 

include reductions in soil quality and wildlife habitat carrying capacity, reduced livestock and wild horse carrying 

capacity, and decreased water quality. The action alternatives would reduce, not exacerbate, these effects. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Conflicts and Consistency with Other Plans 

The CEQ regulations (40 CFR 1502.16) require a discussion of 

. . . possible conflicts between the proposed action and the objectives of Federal, regional, State, and local 

(and in the case of a reservation, Indian tribe) land use plans, policies and controls for the area concerned. 

This EIS does not propose to amend resource management plans. It examines a proposal to make additional 

herbicides available to existing vegetation management programs. Their actual use would be considered at the 

site-specific scale, and need to be consistent with the management objectives for special management areas and 

other statute and RMP-designated direction. Use would be consistent with requirements and objectives stated in 

RMPS (Appendix 6). 

Herbicide use would be consistent with EPA and Oregon State Department of Agriculture registration. Use 

potentially conflicting with reserved treaty rights of American Indian tribes would be subject to government-togovernment consultation. Having additional herbicides, however, would facilitate efforts to protect these areas 

from noxious weeds and other invasive plants. 

The Forest Service in Region 6 (Oregon and Washington) adopted an invasive plant control strategy in 2005 

involving the use of ten herbicides (USDA 2005). It is likely the two agencies would cooperate where logical control 

areas cross administrative boundaries. The two agencies already share analyses, personnel, and other information. 

By their stated standards, Alternatives 4 and 5 would specifically facilitate, not conflict with, habitat management 

needs described in FWS Recovery Plans and interagency Conservation Strategies for Sensitive Species (Chapter 2). 

The availability of imazapic under Alternatives 3-5 would facilitate the reduction of fire-prone invasive annual grasses 

in the wildland-urban interface east of the Cascades and in the Siskiyou Biome, furthering the objectives of the 2000 

National Fire Plan (USDA, USDI 2000b). 

Lane County is currently under a commissioner-imposed indefinite moratorium on roadside spraying on County 

rights-of-way, regardless of the objective. Since the County would have the vegetation maintenance responsibilities 

on county roads, this moratorium should not affect the roadside spraying proposed in Alternative 4. However, some 

county roads cross BLM lands, and depending upon the nature of the rights-of-way agreement, this moratorium may 

limit the ability of BLM to spot spray noxious weeds within those rights-of-way. 

 328 
 

Draft Environmental Impact Statement: Glossary 

Glossary 

Abiotic: Not involving living organisms. 

Absorption: The process by which a chemical or other substance is able to pass through body membranes and enter an 

organism. 

Acid soil or acidic soil: A soil material having a pH of less than 7.0. 

Active ingredient (a .i .): The ingredient in an herbicide that prevents, destroys, repels, desiccates, or otherwise controls 

the target plant. 

Acute adverse effect level: The level at which a substance can cause adverse effects within a short time of dosing or 

exposure. 

Acute effect: An adverse effect on any living organism in which symptoms develop rapidly and often subside after the 

exposure stops. 

Acute exposure: A single exposure or multiple brief exposures occurring within a short time (e.g., 24 hours or less in 

humans). The classification of multiple brief exposures as “acute” is dependent on the life span of the organism. 

Acute toxicity: The quality or potential of a substance to cause injury or illness shortly after exposure through a single 

or short-term exposure. 

Adaptive management: A system of management practices based on clearly identified outcomes, monitoring to 

determine if management actions are meeting outcomes, and if not, facilitating management changes that will best 

ensure that outcomes are met or reevaluated. 

Additive: A substance added to another in relatively small amounts to impart or improve desirable properties or 

suppress undesirable properties. 

Additive effect: A situation in which combined effects of exposure to two chemicals simultaneously is equal to the 

sum of the effect of exposure to each chemical given alone. 

Adjuvant: A chemical that is added to the pesticide formulation to enhance the toxicity of the active ingredient or to 

make the active ingredient easier to handle. 

Administrative site: A reservation of public land for use as a site for a public buildings or other administrative 

facility. Administrative sites are generally withdrawn from public entry or mining claims and also include any Federal 

lands that have been dedicated to a specified public purpose. On BLM managed lands in Oregon, administrative sites 

include, but are not limited to; seasonal fire stations, wild horse corrals, rock quarries and bulk material and equipment 

storage sites, seed orchards and related progeny test sites, other developed or improved sites for vegetative propagation, 

BLM managed airstrips and helipads, BLM range improvements and water source developments, sanitary systems, 

BLM communication sites, remote automated weather stations, etc. 

Adsorption: 1) The adhesion of substances to the surface of solids or liquids. 2) The attraction of ions of compounds 

to the surface of solids or liquids. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Adverse impact: An impact that causes harm or an undesirable result. 

Aerobic: Life or processes that require, or are not destroyed by, the presence of oxygen (Also see anaerobic).
 

Affected environment: Existing biological, physical, social, and economic conditions of an area subject to change, 

both directly and indirectly, as the result of a proposed human action.
 

Air pollutant: Any substance in the air that could, if in high enough concentration, harm humans, animals, vegetation, 

or material. Air pollutants may include almost any natural or artificial matter capable of being airborne in the form of 

solid particles, liquid droplets, gases, or a combination of these. 

Air quality: The composition of air with respect to quantities of pollution therein. Used most frequently in connection 

with “standards” of maximum acceptable pollutant concentrations. 

Algae: Simple plants containing chlorophyll. Many are microscopic, but under conditions favorable for their growth, 

they can grow in colonies and produce mats and similar nuisance masses.
 

Alien species: Any species, including its seed, eggs, spores, or other biological material capable of propagating that 

species that is not native to the ecosystem under consideration. Also referred to as non-natives, or exotics.
 

Allelopathic or allelopathy: Suppression of growth of a plant by a toxin released from a nearby plant of the same or 

another species. 

Allotment (grazing): Area designated for the use of a certain number and kind of livestock for a prescribed period of 

time. 

Alluvium: General term for clay, silt, sand, or gravel deposited in the bed of a stream during relatively recent geologic 

time as a result of stream action. 

Alternative: In an EIS, one of a number of possible options for responding to the purpose and need for action. 

Ambient air: Any unconfined portion of the atmosphere; open air, surrounding air, or “outdoor air.” 

Amphibian: Any of a class of cold-blooded vertebrates (including frogs, toads, or salamanders) intermediate in many 

characteristics between fishes and reptiles and having gilled aquatic larvae and air-breathing adults. 

Amplitude: See ecological amplitude. 

Anadromous fish: Fish that mature in the sea and swim up freshwater rivers and streams to spawn. Examples include 

salmon, steelhead, and sea-run cutthroat trout. 

Anaerobic: Life or processes, such as the breakdown of organic contaminants by microorganisms, which take place 

without oxygen. 

Animal unit (AU): A standardized unit of measurement for range livestock that is equivalent to one cow, one horse, 

five sheep, five goats, or four reindeer, all over six months of age. 

Animal unit month (AUM): The amount of feed or forage required by one animal unit grazing on a pasture for one 

month. 

Anions: Negatively charged ions in solution e.g., hydroxyl or OH–ion. 

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Draft Environmental Impact Statement: Glossary 

Annual (plant): A plant whose life cycle is completed in one year or season. 

Anthropogenic: Caused or produced by humans.
 

Antifoaming agent: A type of adjuvant added to a commercial pesticide that prevents the formation of foam. 

Aquatic: Growing, living in, frequenting, or taking place in water; used to indicate habitat, vegetation, or wildlife in 

freshwater. 

Aquifer: Rock or rock formations (often sand, gravel, sandstone, or limestone) that contain or carry groundwater and 

act as water reservoirs. 

Area of Critical Environmental Concern (ACEC): An area within public lands that requires special management 

attention to protect and prevent irreparable damage to important historic, cultural, or scenic values; fish and wildlife 

resources; other natural systems or processes; or to protect life or provide safety from natural hazards. 

Areal: Of or relating to or involving an area.
 

Arid: A term applied to regions or climates where lack of moisture severely limits growth and production of 

vegetation. The limits of precipitation vary considerably according to temperature conditions. 

Arthropods: Invertebrates belonging to the largest animal phylum (more than 800,000 species) including crustaceans, 

insects, centipedes, and arachnids. Characterized by a segmented body, jointed appendages, and an exoskeleton 

composed of chitin. 

Attainment area: A geographic area that is in compliance with the National Ambient Air Quality Standards. An area 

considered to have air quality as good as or better than the National Ambient Air Quality Standards as defined in the 

Clean Air Act. 

Auxin: A class of substances that in minute amounts regulate or modify the growth of plants, esp. root formation, bud 

growth, and fruit and leaf drop.
 

Back Country Byways: Roads designated to complement the National Scenic Byway program, featuring waterfalls, 

geology, glaciers, and rivers. 

Basal application: In pesticides, the placing of an herbicide on stems or trunks of plants just above the soil line.
 

Base: Substances that (usually) liberate OH anions when dissolved in water and weaken a strong acid.
 

Bedload: Rocks, pebbles, and other material in regular contact with the streambed but being moved along by it. 

Includes material moving only part of the time, as well as material rolling, sliding, etc.
 

Benthic: Of or relating to or happening on the bottom under a body of water.
 

Binder: A material used to bind together two or more other materials in mixtures. 

Bioaccumulation: The process of a plant or animal selectively taking in or storing a persistent substance. Over time, a 

higher concentration of the substance is found in the organism than in the organism’s environment. 

Biodegradation: Process of decomposition by microorganisms or other natural environmental factors. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Biodiversity: The variety of life and its processes, including all life forms from one-celled organisms to complex 

organisms such as insects, plants, birds, reptiles, fish, other animals; and the processes, pathways, and cycles that link 

such organisms into natural communities. 

Biological assessment (BA): A document prepared by or under the direction of a federal agency. A BA addresses 

Federally Listed, species proposed for listing, and designated and proposed critical habitat that may be present in the 

action area, and evaluates the potential effects of the action on such species and habitat. 

Biological control: The use of non-native agents including invertebrate parasites and predators (usually insects, mites, 

and nematodes), and plant pathogens to reduce populations of invasive plants. 

Biological crust: Thin crust of living organisms on or just below the soil surface; composed of lichens, mosses, algae, 

fungi, cyanobacteria, and bacteria. Biological crusts are typically found in arid areas. 

Boom (herbicide spray): A tubular metal device that conducts an herbicide mixture from a tank to a series of spray 

nozzles. Usually mounted to a truck, or behind a tractor or all-terrain vehicle. 

Brackish: Saline water whose salt concentration is between that of freshwater and seawater (ranging from 0.5 to 30 

parts per thousand). 

Broadcast application: An application of an herbicide that uniformly covers an entire area. 

Bryophytes: Plants of the phylum Bryophyta, including mosses, liverworts, and hornworts; characterized by the lack 

of true roots, stems, and leaves. 

Buffer: A solution or liquid whose chemical makeup is such that it minimizes changes in pH when acids or bases are 

added to it; a space or distance left between the application and a non-target area; a strip of vegetation that is left or 

managed to reduce the impact that a treatment or action on one area might have on another area. 

Bunchgrass: A grass having the characteristic growth habit of forming a round clump; lacking stolons or rhizomes. 

Bureau Sensitive: Species designated by the state director as requiring special management consideration to 

promote their conservation and reduce the likelihood and need for future listing under the ESA. All Federal 

candidate species, proposed species, and delisted species in the 5 years following delisting are conserved as 

Bureau sensitive species, in addition to species designated by the State Director. (see also Sensitive species.) 

California Puff (CALPUFF): CALPUFF is an advanced non-steady-state meteorological and air quality modeling 

system adopted by the U.S. Environmental Protection Agency as the preferred model for assessing long range transport 

of pollutants and their impacts involving complex meteorological conditions. 

Carcinogen: A chemical capable of causing cancer. 

Carnivore: An animal that feeds on other animals, especially the flesh-eating mammals. 

Carrier: A non-pesticide substance added to a commercial pesticide formulation to make it easier to handle or apply. 

Carrying capacity: The maximum population of a particular species that a particular area can support without 

hindering future generations’ ability to maintain the same population. 

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Draft Environmental Impact Statement: Glossary 

Cascades: A mountain range in Oregon. As used in the EIS, the Cascade crest until, at the south end of the state, 

the crest meets the Klamath County line. Then follow that line west and then south to the state line, so that the entire 

Klamath Falls Resource Area is considered east of the Cascades, and the entire Medford District is considered west of 

the Cascades. 

Cation: Positively charged ions in a solution. 

Cation exchange capacity (CEC): The capacity of soil to hold nutrients for plant use. Specifically, CEC is the 

amount of negative charges available on clay and humus to hold positively charged ions. Effective cation exchange 

capacity (ECEC) is reported for acid soils (pH<5). Expressed as centimoles of charge per kilogram of soil (cmolc/kg). 

Chaining: Woody vegetation control that is accomplished by hooking a large anchor chain between two bulldozers, 

or one bulldozer and a weight; as the bulldozers move through the vegetation, the vegetation is broken or uprooted. 

Chaining kills a large percentage of the woody vegetation, and is often followed a year or two later by burning and/or 

seeding. 

Chloracne: An acne-like skin disorder caused by prolonged exposure to chlorinated hydrocarbons. 

Cholinesterase: An enzyme found in animals that regulates nerve impulses. Cholinesterase inhibition is associated 

with a variety of acute symptoms such as nausea, vomiting, blurred vision, stomach cramps, and rapid heart rate, 

paralysis, convulsions, and death. 

Chemical degradation: The breakdown of a chemical substance into simpler components through chemical reactions. 

Chronic exposure: Exposures that extend over a long period. Chronic exposure studies are used to evaluate the 

carcinogenic potential of chemicals and other long-term health effects. 

Chronic toxicity: The ability of a substance or mixture of substances to cause harmful effects over an extended period, 

usually upon repeated or continuous exposure sometimes lasting for the entire life of the exposed organism. 

Cisco: Salmonid fish of the genus Coregonus that differs from other members of the genus in having upper and lower 

jaws of approximately equal length and high gillraker counts. 

Class I area: Under the 1977 Clean Air Act amendments, all international parks, parks larger than 6,000 acres, 

and national wilderness areas larger than 5,000 acres that existed on August 7, 1977. This class provides the most 

protection to pristine lands by severely limiting the amount of additional air pollution that can be added to these areas. 

Clay: In soil, particles smaller than .002 mm in diameter. 

Climate: The composite or generally prevailing weather conditions of a region throughout the year, averaged over a 

series of years. 

Code of Federal Regulations (CFR): A codification of the general and permanent rules published in the Federal 

Register by the executive departments and agencies of the federal government. 

Confidential business information (CBI): Information submitted to EPA by a pesticide registrant to fulfill 

requirements for pesticide registration that contains trade secrets or commercial or financial information that has been 

claimed as confidential by its source. EPA has special procedures for handling such information. 

Conservation Strategy: See Chapter 2, Alternative 4 or http://www.fs.fed.us/r6/sfpnw/issssp. Recovery Plans, 

Conservation Strategies, and Conservation Plans are collectively referred to as Conservation Strategies. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Consultation: Exchange of information and interactive discussion; usually refers to consultation mandated by statute 

or regulation that has prescribed parties, procedures, and timelines (e.g. Consultation under National Environmental 

Policy Act or Section 7 of the Endangered Species Act, or Consultation with tribes). 

Control: Eradicating, suppressing, or reducing vegetation; a population that is not exposed to the potentially toxic 

agent in toxicology or epidemiology studies. 

Cooperator: Leasees, permittees, and others with authorized uses or occupancy on BLM lands. 

Council on Environmental Quality (CEQ): An advisory council to the President of the United States established 

by the National Environmental Policy Act of 1969. It reviews federal programs for their effect on the environment, 

conducts environmental studies, and advises the President on environmental matters. 

Cover: 1) Trees, shrubs, rocks, or other landscape features that allow an animal to partly or fully conceal itself. 2) The 

area of ground covered by plants of one or more species, usually expressed as a percent of the ground surface. 

Criteria pollutants: Air pollutants designated by the U.S. Environmental Protection Agency as potentially harmful and 

for which ambient air quality standards have been set to protect the public health and welfare. The criteria pollutants 

are carbon monoxide, sulfur dioxide, particulate matter, nitrogen dioxide, ozone, hydrocarbons, and lead. 

Critical habitat: 1) Specific areas within a species’ habitat that are critically important to its life functions; an area 

designated by the FWS under rule-making as being critical to the needs of a federally listed species, and which then 

carries special protection and consultation requirements. 

Cultural resources: Nonrenewable evidence of human occupation or activity as seen in any area, site, building, 

structure, artifact, ruin, object, work of art, architecture, or natural feature, which was important in human history at the 

national, state, or local level. 

Cumulative effect: The effects that results from identified actions when they are added to other past, present, and 

reasonably foreseeable future actions regardless of who undertakes such other actions. Cumulative effects can result 

from individually minor but collectively significant actions taking place over a period of time. 

DBH: See diameter at breast height. 

Degradation: Physical or biological breakdown of a complex compound into simpler compounds. 

De minimus: Latin for “of minimum importance” or “trifling.” Essentially it refers to something or a difference that is 

so little, small, minuscule, or tiny that it is not worth considering. 

Density: The number of individuals per a given unit area. 

Detritus: Matter produced by the decay or disintegration of an organic substance. 

Diameter at breast height: The diameter of the stem of a tree measured at 4.5 feet above the ground on the uphill 

side. 

Diluent: An inert diluting agent added to a commercial pesticide formulation that decreases the viscosity of the 

formula. 

Dilution: The act of mixing or thinning, and therefore decreasing a certain strength or concentration. 

 334 
 

 

Draft Environmental Impact Statement: Glossary 

Direct effects: Effects on the environment that are caused by the action and occur at the same time and place. 

Directed livestock: The careful application of grazing or browsing prescriptions (i.e., specified grazing intensities, 

seasons, frequencies, livestock species, and degrees of selectivity) to achieve natural resource objectives. Livestock 

production is a secondary or nonobjective when using prescribed grazing as a natural resource management tool. 

Disseminule: A reproductive plant part, such as a seed, fruit, or spore that is modified for dispersal. 

Dispersant: A type of inert ingredient added to an herbicide formulation that reduces the cohesive attraction between 

like particles. 

Dispersion: The act of distributing or separating into lower concentrations or less dense units. 

Disturbance: Events that alter the structure, composition, or function of terrestrial or aquatic habitats. Natural 

disturbances include, among others, drought, floods, wind, fires, wildlife grazing, and insects and pathogens. Humancaused disturbances include actions such as timber harvest, livestock grazing, roads, and the introduction of exotic 

species; also, noise or visual distractions that may displace or otherwise adversely affect wildlife. 

Dominant: A group of plants that by their collective size, mass, or number exerts a primary influence onto other 

ecosystem components; a tree whose canopy is above surrounding trees of the same age. 

Dose: The amount of chemical administered or received by an organism, generally at a given point in time. 

Dose-response: Changes in toxicological responses of an individual (such as alterations in severity of symptoms) or 

populations (such as alterations in incidence) that are related to changes in the dose of any given substance. 

Draft environmental impact statement (DEIS): The draft statement of the environmental effects of a federal action, 

which is required under Section 102 of the National Environmental Policy Act, and released to the public and other 

agencies for comment and review. 

Drift: That part of a sprayed herbicide that is moved from the target area by wind while it is still airborne. 

EC50: A concentration in air or in water that causes 50% inhibition of growth. 

EC : A concentration in air or water that causes complete inhibition of growth. 100

Ecological amplitude: The breadth of the biological and environmental requirements of a species such as temperature, 

moisture, soil types, hosts, and vegetation community characteristics. 

Ecosystem: Includes all the organisms of an area, their environment, and the linkages or interactions among them; 

all parts of an ecosystem are interrelated. The fundamental unit in ecology, containing both organisms and abiotic 

environments, each influencing the properties of the other. 

Effect: Environmental change resulting from a proposed action. Direct effects are caused by the action and occur 

at the same time and place, while indirect effects are caused by the action but are later in time, further removed in 

distance, or secondary. Effect and impact are synonymous as used in this document. 

Encroaching vegetation: Any plants growing too closely into a roadway and hampering access or visibility (safety) 

or cracking pavement; growing into power lines or structures and endangering them; growing into campgrounds and 

preventing use or diminishing enjoyment; and so forth. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Endangered species: Any species listed under the Endangered Species Act as being in danger of extinction throughout 

all or a significant portion of its range. 

Endangered Species Act (ESA): A law passed in 1973 to conserve species of wildlife and plants determined by the 

Director of the Fish and Wildlife Service or the NOAA Fisheries to be endangered or threatened with extinction in all 

or a significant portion of its range. Among other measures, ESA requires all federal agencies to conserve these species 

and consult with the Fish and Wildlife Service or NOAA Fisheries on federal actions that may affect these species or 

their designated critical habitat. 

Endemic species: A species that is naturally unique to a specific locality. 

Endocrine: Referring to several glands in higher animals that secrete hormones. 

Environment: 1) The physical conditions that exist within an area (e.g., the area that may be affected by a proposed 

project), including land, air, water, minerals, flora, fauna, ambient noise, and objects of historical or aesthetic 

significance. 2) The sum of all external conditions that affect an organism to influence its development or existence. 

Environmental assessment (EA): A concise public document that serves to document an examination of the 

potential environmental effects of a proposed project, and from that, examination documents whether to prepare an 

environmental impact statement or a finding of no significant impact. 

Environmental impact statement (EIS): A document required by the National Environmental Policy Act to display 

the significant environmental effects that may occur as a result of a federally proposed action or action on federal 

lands, and to document the examination by the responsible federal agency of consideration of a reasonable range of 

alternatives to achieve the same purpose, in order to help facilitate federal decision-making that minimizes unnecessary 

adverse environmental effects. 

Environmental justice: Equal protection from environmental hazards for individuals, groups, or communities 

regardless of race, ethnicity, or economic status. This applies to the development, implementation, and enforcement of 

environmental laws, regulations, and policies, and implies that no population of people should be forced to shoulder a 

disproportionate share of negative environmental impacts of pollution or environmental hazard due to a lack of political 

or economic strength. 

Epidemiology study: A study of human population or human populations. In toxicology, a study which examines the 

relationship of exposures to one or more potentially toxic agents to adverse health effects in human populations. 

Eradication: Removal or elimination of a population. 

Erosion: The wearing away of the land surface by running water, wind, ice, gravity, or other geological activities. 

Essential fish habitat (EFH): Waters and substrate necessary to fish for spawning, breeding, feeding, or growth to 

maturity. 

Eutrophication: Excessive nutrients in a lake or other body of water, usually caused by runoff of nutrients (animal 

waste, fertilizers, sewage) from the land, which causes a dense growth of plant life; the decomposition of the plants 

depletes the supply of oxygen, leading to the death of animal life. 

Evapotranspiration: The process of transferring moisture from the earth to the atmosphere by evaporation of water 

and transpiration from plants. 

 336 
Draft Environmental Impact Statement: Glossary 

Exotic species: Includes species introduced into an area; non-native species.
 

Extirpate: The elimination of a species from a particular area.
 

Extrapolation: The use of a model to make estimates of values of a variable in an unobserved interval from values 

within an already observed interval.
 

°F: Degrees Fahrenheit. 

Fate: The course of an applied herbicide in an ecosystem or biological system, including metabolism, microbial 

degradation, leaching, and photodecomposition. 

Fauna: The vertebrate and invertebrate animals of the area or region. 

Feasible: Capable of being accomplished in a successful manner within a reasonable period of time, taking into 

account economic, environmental, legal, social, and technological factors. 

Federally Listed: Species listed as threatened or endangered under the Endangered Species Act.
 

Final Environmental Impact Statement (Final EIS): A revision of the Draft Environmental Impact Statement based 

on public and agency comments on the draft; the document upon which a Record of Decision is based. 

Fire dependent: A plant or ecosystem evolving under periodic perturbations by fire and that consequently depends on 

periodic fires for normal function. 

Fire intolerant: Species of plants that do not grow well with, or die from, the effects of too much fire. 

Fire return interval: The average time between fires in a given area. 

Fire tolerant: Species of plants that can withstand a certain frequency and intensity of fire. 

Fire use: The combination of prescribed fire and wildland fire use for resource benefit to meet resource objectives.
	

First order dermal absorption: Absorption of a material (herbicide) that occurs over 24 hours. 

Fishery: The act, process, occupation, or season of taking an aquatic species. 

Flora: Plant life, especially all the plants found in a particular country, region, or time regarded as a group; a 

systematic set of descriptions of all the plants of a particular place or time.
 

Fluvial: Of or relating to or happening in a river.
 

Forage: Vegetation eaten by animals, especially grazing and browsing animals. 

Forb: Small broad-leafed plant; broad-leaved herb other than a grass, especially one growing in a field, prairie, or 

meadow. 

Forestland: Land where the potential natural plant community contains 10% or more tree canopy cover. 

Formulation: The commercial mixture of an herbicide that includes both the active and inactive (inert) ingredients. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Fragmentation (habitat): The breaking-up of a habitat or cover type into smaller, disconnected parcels.
 

Fuel (fire): Dry, dead parts of trees, shrubs, and other vegetation that can burn readily. 

Fungi: Molds, mildews, yeasts, mushrooms, and puffballs, a group of organisms that lack chlorophyll and therefore 

are not photosynthetic. 

Gravel: In soil, particle sizes between 2 and 64 mm in diameter.
 

Gross infested area or treatment area: An area of land occupied by one or more invasive plant species; the area of 

land defined by drawing a line around the general perimeter of the infestation, not the canopy cover of the plants; the 

gross area of a logical treatment unit. May contain significant parcels of land that are not occupied by the weed. 

Groundwater: Subsurface water that is in the zone of saturation; the top surface of the groundwater is the “water 

table”; source of water for wells, seeps, and springs. 

Groundwater Contaminant: Chemical detected in ground waters. Does not necessarily infer levels are toxic or 

harmful. 

Habitat: The natural environment of a plant or animal, including all biotic, climatic, and soil conditions, or other 

environmental influences affecting living conditions; the place where an organism lives. 

Half life: The amount of time required for half of a compound to degrade. 

Hazardous fuels: Living and dead and decaying vegetation that form a special threat of ignition and resistance to 

control. 

Hazard quotient (HQ): The ratio of the estimated level of exposure to a substance from a specific substance from 

a specific pesticide application to the reference dose (RfD) for that substance, or to some other index of acceptable 

exposure or toxicity. An HQ less than or equal to 1 is presumed to indicate an acceptably low level of risk for that 

specific application. Analogous to BLM risk quotient. 

Herbaceous: Non-woody plants that include grasses, grass-like plants, and forbs. 

Herbicide: A pesticide used to control, suppress, or kill vegetation, or severely interrupt normal growth processes. 

Herbicide resistance: Naturally occurring heritable characteristics that allow individual weeds to survive and 

reproduce, producing a population, over time, in which the majority of the plants of the weed species have the resistant 

characteristics. 

Herbivore: An animal that feeds on plants. 

Herd management areas (HMAs): Areas established for wild and free-roaming horses and burros through the land 

use planning process. The Wild Free-roaming Horse and Burro Act of 1971 requires that wild free-roaming horses and 

burros be considered for management where they were found at the time Congress passed the Act. The BLM initially 

identified 264 areas in the western U.S. as herd management areas. 

Herptiles, herps, herpetofauna: Reptiles and amphibians. 

Historic Trail: See national historic trails. 

 338 
 

 

Draft Environmental Impact Statement: Glossary 

Home range: The area around an animal’s established home that is visited during the animal’s normal activities. 

Hydric soil: A soil that formed under conditions of saturation, flooding, or ponding long enough during the growing 

season to develop anaerobic conditions in the upper part. 

Hydrologic: The properties, distribution, and effects of water on the earth’s surface, in the soil and underlying rocks, 

and in the atmosphere.
 

Hydrologic cycle (water cycle): The ecological cycle that moves water from the air by precipitation to the earth and 

returns it to the atmosphere; includes evaporation, run-off, infiltration, percolation, storage, and transpiration. 

Hydrolysis (chemical): Decomposition or alteration of a chemical substance by water. 

Impermeable: Cannot be penetrated. 

Indigenous: Living or occurring naturally in an area; native, endemic people, flora, or fauna. 

Indirect effects: Effects that are caused by an action, but are later in time or farther removed in distance. 

Inert ingredient(s): Those ingredients that are added to the commercial product (formulation) and are not herbicidally 

active. Also called other ingredients.
 

Infested: An area having one or more of the subject invasive species – either plants or plant pathogens. Infested areas 

are not necessarily 100 percent infested. 

Infested Area: See gross infested area. 

Infiltration: The movement of water through soil pores and spaces. 

Insolation: Solar radiation received at the earth’s surface.
 

Integrated vegetation management (IVM): A long-standing, science-based, decision-making process that identifies 

and reduces risks from vegetation and vegetation management related strategies. It coordinates the use of vegetation 

biology, environmental information, and available technology to prevent unacceptable levels of damage by the most 

economical means, while posing the least possible risk to people, property, resources, and the environment. IVM 

provides an effective strategy for managing vegetation in all arenas from developed agricultural, residential, and public 

areas to wild lands. IVM serves as an umbrella to provide an effective, all encompassing, low-risk approach to manage 

problem vegetation. A sustainable approach to managing vegetation by combining biological, cultural, physical, and 

chemical tools in a way that minimizes economic, health, and environmental risks. 

Interagency special status/sensitive species program (ISSSSP): The BLM and FS shared program to coordinate 

record keeping and other management of the Bureau Special Status and Forest Service Sensitive species programs. 

Also, see special status species. 

Intermittent stream: A stream that flows only a certain times of the year when it receives water from other streams or 

from surface sources such as melting snow. 

Interpretive facilities: Developed sites designed primarily to educate and provide safe access for resource 

observation, such as Adventures in the Past, Watchable Wildlife, wild horse viewing, and geologic interpretation sites. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Introduced species: An alien or exotic (non-native) species that has been intentionally or unintentionally released into 

an area as a result of human activity. 

Invasive plants (or weeds): A non-native aggressive plants with the potential to cause significant damage to native 

ecosystems and/or cause significant economic losses. This Oregon EIS definition differs from the PEIS definition by not 

including species native to the ecosystem under consideration. 

Invertebrate: Small animals that lack a backbone or spinal column, e.g. spiders, insects, and worms. 

Irretrievable commitment: A term that applies to losses of production or commitment of renewable natural resources. 

For example, while an area is used as a ski area, some or all of the potential timber production there is “irretrievably” 

lost. If the ski area closes, timber production could resume; therefore, the loss of timber production during the time the 

area is devoted to skiing is irretrievable, but not irreversible, because it is possible for timber production to resume if 

the area is no longer used as a ski area. 

Irreversible commitment: A term that applies to non-renewable resources, such as minerals and archaeological sites. 

Losses of these resources cannot be reversed. Irreversible effects can also refer to the effects of actions on resources 

that can be renewed only after a very long period of time, such as the loss of soil productivity. 

Issue: A matter of controversy, dispute, or general concern over resource management activities or land uses. 

Koc: Organic carbon-water partition coefficient. 

Label: All printed material attached to or part of the pesticide container, and which contains instructions for the legal 

application of the pesticide. 

Landscape: All the natural features such as grasslands, hills, forest, and water, which distinguish one part of the 

earth’s surface from another part; usually that portion of land that the eye can comprehend in a single view, including 

all of its natural characteristics. 

Large woody debris: Pieces of woody material derived from tree limbs, boles, and roots in various stages of decay, 

generally having a diameter of at least 3 inches and a length greater than 3 feet; pieces of wood that are of a large 

enough size to affect stream channel morphology. 

LC50 : (median lethal concentration): A concentration of a chemical in air or water to which exposure for a specific 

length of time is expected to cause death in 50% of a defined experimental animal population. 

LD50 : (median lethal dose): The dose of a chemical calculated to cause death in 50% of a defined experimental 

animal population over a specified observation period. The observation period is typically 14 days. 

Leaching: The movement of chemicals through the soil by water; may also refer to the movement of herbicides out of 

leaves, stems, or roots into the air or soil. 

Lek: A traditional place where males (esp. sage grouse) assemble during the mating season and engage in competitive 

displays that attract females. 

Lentic: Pertaining to or living in still water. 

Level of concern (LOC): The concentration or other estimate of exposure above which there may be effects. 

 340 
Draft Environmental Impact Statement: Glossary 

Lichens: Organisms made up of specific algae and fungi, forming identifiable crusts on soil, rocks, tree, bark, and 

other surfaces. Lichens are primary producers in ecosystems. They contribute living material and nutrients, enrich 

the soil and increase soil moisture-holding capacity, and serve as food sources for certain animals. Lichens are slow 

growing and sensitive to chemical and physical disturbances. 

Listed species: Formally listed as a threatened or endangered species under the ESA. Designations are made by the 

FWS or NMFS. 

Litter: The uppermost layer of organic debris on the soil surface, which is essentially the freshly fallen or slightly 

decomposed vegetation material such as stems, leaves, twigs, and fruits. 

Long-term: Generally refers to a period longer than 10 years, but it depends upon the context. 

Lowest observed adverse effect level (LOAEL): The lowest dose of a chemical in a study, or group of studies, 

that produces statistically or biologically significant increases in frequency or severity of adverse effects between the 

exposed and control populations. 

Lymph: A clear fluid containing white blood cells. Lymph circulates throughout the lymphatic system, removing 

bacteria and certain proteins from body tissue. It also is responsible for transporting fat from the small intestine and 

supplying mature lymphocytes to the blood. 

Lymphatic: Pertaining to lymph, a lymph vessel, or a lymph node. 

Macrophyte: A plant, especially a marine or aquatic plant, large enough to be visible to the naked eye. 

Malignant: Cancerous. 

Marsh: A type of wetland that does not accumulate appreciable peat deposits and is dominated by herbaceous 

vegetation. Marshes may be either fresh or saltwater, tidal or nontidal. 

Mast: Nuts or fruits of trees and shrubs, such as beechnuts, acorns, and berries, which accumulate on the forest floor, 

providing forage for animals. 

Material safety data sheet (MSDS): A compilation of information required under the Occupational Safety and Health 

Administration Communication Standard on the identity of hazardous chemicals, health and physical hazards, exposure 

limits, and precautions. 

Maximum application rate: The maximum application rate included on the label of the formulated product. For 

example, Plateau, the formulated product that has imazapic as its active ingredient, the label states that no more than 

12.0 fluid ounces of product are to be applied on a per acre basis. According to the label there are two pounds of 

imazapic acid equivalent in a gallon of formulated product, so the maximum amount of active ingredient that may be 

applied is 0.1875 lb. a.i./acre. 

Mechanical control: The use of any mechanized approach to control or eliminate invasive plants (i.e. mowing, weed 

whipping, or cutting with a chainsaw). 

Mediterranean climate: A type of climate characterized by hot, dry, sunny summers and a winter rainy season. 

Mesic: Of, characterized by, or adapted to a moderately moist habitat. 

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Metabolism: The sum of the chemical reactions occurring within a cell or a whole organism; includes the energyreleasing breakdown of molecules (catabolism) and the synthesis of new molecules (anabolism). 

Microbial degradation: The breakdown of a chemical substance into simpler components by bacteria or other 

microorganisms. 

Micron: The millionth part of a meter. There are 10,000 microns in a centimeter. 

Minimize: Apply best available technology, management practices, and scientific knowledge to reduce the magnitude, 

extent, and/or duration of something. 

Mitigation: Actions that would: 1) avoid an impact altogether by not taking a certain action or parts of an action; 

2) minimize an impact by limiting the degree or magnitude of the action and its implementation; 3) rectify an impact 

by repairing, rehabilitating, or restoring the affected environment; 4) reduce or eliminate an impact over time by 

preserving and maintaining operations during the life of the action; and, 5) compensate for an impact by replacing or 

providing substitute resources or environments. 

Mollusks: Invertebrate animals (such as slugs, snails, clams, or squids) that have a soft unsegmented body usually 

enclosed in a calcareous shell; representatives found on BLM lands include snails, slugs, and clams. 

Monitoring: The orderly collection, analysis, and interpretation of resource data to evaluate progress toward meeting 

management objectives. 

Montane forests: The lower vegetation belt on mountains. 

Monument: See national monument. 

Morbidity: Rate of disease, injury, or illness. 

Motility: Capability of motion. 

Multiple uses: A combination diverse resource uses that takes into account the long-term needs of future generations 

for renewable and nonrenewable resources. These may include recreation, grazing, timber, minerals, watershed, 

wildlife, and fish, along with natural scenic, scientific, and historical values. 

Mutagenic: Capable of inducing mutation or increasing its rate. 

National ambient air quality standards (NAAQS): Standards set by the U.S. Environmental Protection Agency for 

the maximum levels of pollutants that can exist in the outdoor air without unacceptable effects on human health or the 

public welfare. 

National conservation areas: Areas designated by Congress their natural, recreational, cultural, wildlife, aquatic, 

archeological, paleontological, historical, educational, and/or scientific resources and values, that are managed for the 

areas long-term conservation, protection, enhancement, and use. 

National Environmental Policy Act (NEPA): An act of Congress passed in 1969, declaring a national policy to 

encourage productive and enjoyable harmony between people and the environment, to promote efforts that will prevent 

or eliminate damage to the environment and the biosphere and stimulate the health and welfare of people, and to enrich 

the understanding of the ecological systems and natural resources important to the nation, among other purposes. 

 342 
Draft Environmental Impact Statement: Glossary 

National Historic Trails: Trails established to identify and protect historic routes; they follow as closely as possible 

the original trails or routes of travel of national historic significance. 

National Landscape Conservation System (NLCS): A single system that encompasses some of the BLM’s premier 

land designations such as wilderness, wild and scenic rivers, national scenic and historic trails, national monuments, 

and other designations. 

National Monument: An area designated to protect objects of scientific and historic interest by public proclamation 

of the President under the Antiquities Act of 1906, or by the Congress for historic landmarks, historic and prehistoric 

structures, or other objects of historic or scientific interest situated upon the public lands; designation also provides for 

the management of these features and values. 

National Recreation Area: An area designated by Congress to assure the conservation and protection of natural, 

scenic, historic, pastoral, and fish and wildlife values and to provide for the enhancement of recreational values. 

National Recreation Trails: Trails established administratively by the Secretary of the Interior to provide for a variety 

of outdoor recreation uses in or reasonably close to urban areas. They often serve as connecting links between the 

National Historic Trails and National Scenic Trails. 

National Scenic Trails: Trails established by an Act of Congress that are intended to provide for maximum outdoor 

recreation potential and for the conservation and enjoyment of nationally significant scenic, historical, natural, and 

cultural qualities of the areas through which these trails pass. 

Native species: Species that historically occurred or currently occur in a particular ecosystem and were not introduced. 

Naturalized: An exotic species that now behaves like a native in that it maintains itself without further human 

intervention and is regionally widespread leading many to believe it is native. 

Neurotoxins: Materials that affect nerve cells and may produce muscular, emotional, or behavioral abnormalities, 

impaired or abnormal motion, and other physiologic changes. 

Neutral: In pH terms, 7; neither acid nor basic. 

Neutral soil: A soil in which the surface horizon is neither acid nor alkaline in reaction; soils with pH 6.5 to 7.5. 

Neutralizer: A type of inert ingredient added to an herbicide that modifies the effect of, or counteracts the properties 

of, something within the herbicide or spray solution. 

No action alternative: The most likely condition to exist in the future if current management direction were to 

continue unchanged. 

No observed adverse effect level (NOAEL): The exposure level at which there are no statistically or biological 

significant differences in the frequency or severity of any adverse effect between the exposed and control populations. 

No observed effect level (NOEL): Exposure level at which there are no statistically or biological significant 

differences in the frequency or severity of any effect between the exposed and control populations. 

Non-selective herbicide: An herbicide that is generally toxic to plants without regard to species or group. 

Non-target: Any organism that is not the objective of a control treatment. 

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Noxious weed: A subset of invasive plants that are county, state, or federally listed as injurious to public health, 

agriculture, recreation, wildlife, or any public or private property 

Nutrient cycle: Ecological processes in which nutrients and elements such as carbon, phosphorous, nitrogen, and 

others, circulate among animals, plants, soils, and air. 

O&C lands: Public lands granted to the Oregon and California Railroad Company and subsequently revested to the 

United States. O&C lands are only in Oregon, and most are managed by the BLM. 

Objective: A concise, time-specific statement of measurable planned results that respond to pre-established goals. 

An objective forms the basis for further planning to define the precise steps to be taken and the resources to be used to 

achieve identified goals. 

Obligate, as in obligate species: Required; also, exhibited by, all members of a species without exception. 

Off-highway vehicle (OHV): Any motorized track or wheeled vehicle designed for cross-country travel over natural 

terrain. 

Omnivore: An animal that eats a combination of meat and vegetation. 

Option values: Societies willingness to pay to preserve future options.
 

Oregon and California lands: Public lands in Western Oregon that were granted to the Oregon Central Railroad 

companies (later the Oregon and California Railroad Company) to aid in the construction of railroads, but that were 

later forfeited and returned to the federal government by revestment of title. 

Organic matter: Plant and animal material that is in the process of decomposing.
 

Paleontological resources: A work of nature consisting of or containing evidence of extinct multicellular beings and 

includes those works or classes of works of nature designated by the regulations as paleontological resources. 

Paleontology: A science dealing with the life of past geological periods as known from fossil remains.
 

Parent material: The unconsolidated and more or less chemically weathered mineral or organic matter from which 

the soil has developed by pedogenic processes. 

Particulate matter (PM): A complex mixture consisting of varying combinations of dry solid fragments, solid 

cores with liquid coatings, and small droplets of liquid. These tiny particles vary greatly in shape, size, and chemical 

composition, and can be made up of many different materials such as metals, soot, soil, and dust. 

Particulates: Solid particles or liquid droplets suspended or carried in the air. 

Pathogen: An agent such as a fungus, virus, or bacterium that causes disease. 

Perennial: A plant with a life cycle lasting more than two years; a stream that flows year round.
	

Permit: A revocable authorization to use public land for a specified purpose. 

Persistence: The length of time a compound, once introduced into the environment, stays there. 

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Draft Environmental Impact Statement: Glossary 

Pesticide: Any substance used for controlling, preventing, destroying, repelling, or mitigating any pest. Includes 

fungicides, herbicides, fumigants, insecticides, nematicides, rodenticides, desiccants, defoliants, plant growth 

regulators, and so forth. Any material used in this manner is a pesticide and must be registered as such, even if it has 

other non-pesticide uses. 

Petroglyph: An image recorded on stone, usually by prehistoric peoples, by means of carving, pecking, or otherwise 

incised on natural rock surfaces. 

Pictograph: A symbol that represents an object or a concept by illustration. 

pH: A measure of how acidic or alkaline (basic) a solution is on a scale of 0 to 14 with 0 being very acidic, 14 being 

very alkaline, and 7 being neutral. The abbreviation stands for the potential of hydrogen. 

Photodegradation: The photochemical transformation of a molecule into lower molecular weight fragments, usually 

in an oxidation process. This term is widely used in the destruction (oxidation) of pollutants by ultraviolet-based 

processes. 

Photolysis: Chemical decomposition induced by light or other radiant energy. 

Phytotoxicity: The ability of a material such as a pesticide or fertilizer to cause injury to plants. 

Piscivore: Animal that feeds on fish. 

Plant: Any of various photosynthetic, eukaryotic (meaning an organism with cells having a distinct nucleus), 

multicellular organisms of the kingdom Plantae characteristically producing embryos, containing chloroplasts, having 

cellulose cell walls, and lacking the power of locomotion. For purposes of this EIS, the term “plant” does not include 

fungi. 

Plant community: A vegetation complex, unique in its combination of plants, which occurs in particular locations 

under particular influences. A plant community is a reflection of integrated environmental influences on the site, such 

as soils, temperature, elevation, solar radiation, slope aspect, and precipitation. 

Playas: Flat land surfaces underlain by fine sediment or evaporate minerals deposited from a shallow lake on the floor 

of a topographic depression. 

PM : Fine particulates that measure 2.5 microns in diameter or less. 2 .5

PM10: Particulate matter that measures 10 microns in diameter or less. 

Porosity: The ratio of the volume of void space in a material (e.g., sedimentary rock or sediments) to the volume of its 

mass. 

Post-emergent (herbicide): Herbicide used to kill weeds after they have germinated and are growing. 

Potable water: Water that is considered safe for drinking and cooking.
 

Potential vegetation type: The combination of species that could occupy the site in the absence of disturbance. 

Predator: An animal that exists by preying on other animals. 

Pre-emergent (herbicide): A soil applied herbicide used to keep seeds from germinating.
 

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Preferred alternative: The alternative identified in an EIS as best resolving the problems identified in the purpose and 

need. 

Prescribed fire: A wildland fire that burns under specified conditions and in predetermined area, to produce the fire 

behavior and fire characteristics required to attain resource management objectives. 

Prevention: To detect and ameliorate conditions that cause or favor the introduction, establishment, or spread of 

invasive organisms or conditions. 

Prevention of significant deterioration (PSD): A U.S. Environmental Protection Agency program in which state and/ 

or federal permits are required in order to restrict emissions from new or modified sources in places where air quality 

already meets or exceeds primary and secondary ambient air quality standards. 

Primary productivity: The process by which organisms make their own food from inorganic sources. The majority 

of primary producers are terrestrial plants and microbial life, such as algae. These organisms are known as autotrophs, 

since they can use inorganic substrates and solar energy to carry out metabolic processes and build cellular material. 

Primary productivity due to photosynthesis is commonly measured by quantifying oxygen production or CO2 

assimilation. 

Productivity: The innate capacity of an environment to support plant and animal life over time. Plant productivity is 

the rate of plant production within a given period of time. 

Productive soil: Soil with the capacity of a soil to produce plant growth, due to the soil’s chemical, physical, and 

biological properties. 

Programmatic EIS: An EIS that examines the area-wide effects of a proposal to adopt area-wide direction. 

Progeny test site: A test area for evaluating parent seed trees by comparing the growth of their offspring seedlings. 

Propagule: A structure such as a cutting, a seed, or a spore, that can produce a plant. 

Proper functioning condition: The condition of riparian and wetland areas when adequate vegetation, landform, or 

large woody debris are present to dissipate stream energy associated with high water flows. This reduces erosion and 

improves water quality; filters sediment, captures bedload, and aids in floodplain development; improves floodwater 

retention and groundwater recharge; develops root masses that stabilize streambacks against cutting; develops diverse 

ponding and channel characteristics to provide habitat and water depth, duration, and temperature necessary for fish 

production, avian breeding habitat, and other uses; and supports greater biodiversity. 

Proposed action: A proposal by a federal agency to authorize, recommend, or implement an action. 

Proposed threatened or endangered species: Plant or animal species proposed by the U.S. Fish & Wildlife Service 

to be biologically appropriate for listing as threatened or endangered and that is published in the Federal Register. It is 

not a final designation. Proposed species are, at minimum, managed as Bureau Sensitive until a decision is made about 

federal listing. 

Public domain lands: One category of public lands that have never left federal ownership (as opposed say, to the 

O&C lands); also, lands in federal ownership that were obtained by the government in exchange for public domain 

lands or for timber on public domain lands. 

Public lands: Any land and interest in land owned by the United States that are administered by the Secretary of the 

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Draft Environmental Impact Statement: Glossary 

Interior through the BLM, without regard to how the United States acquired ownership, except for 1) lands located 

on the Outer Continental Shelf, and 2) lands held for the benefit of American Indians, Aleuts, and Eskimos. Includes 

public domain and acquired lands. 

Public scoping: See scoping. 

Pumped storage hydro-power: A high and low lake system connected by pump/turbines that can generate electricity 

from falling water during high electrical use periods, and then reverse to pump the water back up using alternative 

sources of electricity during low electrical use periods, such as at night. 

Qualitative: Traits or characteristics that relate to quality and cannot be readily measured with numbers or for which 

the numbers are unknown and would be difficult to obtain with any precision. 

Quantitative: Traits or characteristics that can be measured with numbers. 

Rangeland: Land on which the native vegetation is predominantly grasses, grass-like plants, forbs, or shrubs; not 

forests. 

Raptor: Bird of prey; includes eagles, hawks, falcons, and owls. 

Ratepayer: A utility subscriber whose monthly bill goes in part to (and is thus affected by) maintaining the generating 

and/or distribution system across public lands, be it power or phone lines, pipe lines, cell phone towers, wind mills, etc. 

Receptor: An ecological entitysuch as a person, fish, plant, or slug exposed to a stressor such as an herbicide dose. 

Record of decision (ROD): A document separate from, but associated with, an EIS, which states the decision, 

describes why it was selected from among the alternatives, specifies which is environmentally preferable alternative, 

and states whether all practicable means to avoid environmental harm from the alternative have been adopted, and if 

not, why not. 

Recovery plan: A plan for the conservation and survival of an endangered or threatened species listed under the 

Endangered Species Act. The plan’s purpose is to improve (recover) the status of the species so it no longer needs 

Federal Listing. 

Recreation Area: See national recreation area. 

Recreation Trails: See national recreation trails. 

Reducing or reduced soil conditions: Conditions that deplete or remove oxygen and where anaerobic processes 

dominate. 

Reference dose (RfD): An estimate of a daily oral exposure to the human population (including sensitive subgroups) 

that is likely to not result in an appreciable risk of deleterious effects during a lifetime. It is derived from the noobserved-adverse-effect-level, the lowest-observed-adverse-effect-level, or a benchmark dose. Uncertainty factors are 

applied when developing the reference dose so the RfD incorporates additional protection to account for the range of 

uncertainties in the data used. 

Registered herbicide: All herbicides sold or distributed in the United States must be registered by the U.S. 

Environmental Protection Agency. Registration requires scientific studies showing that the material can be used 

without posing unreasonable risks to people or the environment. 

Research natural areas (RNAs): Parts of a national network of reserved areas under various ownerships, containing 347 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

important ecological and scientific values and are managed for minimum human disturbance. They are established and 

managed to protect ecological processes, conserve biological diversity, and provide opportunities for observation for 

research and education. 

Resident fish: Fish that spend their entire life in freshwater (e.g., bull trout) on or near a specific location. 

Residue: Herbicide or its metabolites remaining in or on soil, water, plants, animals, or surfaces. 

Resilience: The ability of a system to respond to disturbances without long-term adverse effects to the functioning of 

the system; the ability of a community to respond to externally induced changes such as larger economic forces. 

Resource management plan (RMP): A plan for a BLM district or portion of a district that provides for public land 

use. The Plan must observe the principles of multiple use and sustained yield, use an interdisciplinary approach, give 

priority to the designation and protection of areas of critical environmental concern, consider present and future uses, 

consider scarcity of the values involved, and appropriately integrate with other federal plans and pollution control laws. 

Restoration: Actions taken to move a degraded ecosystem back toward desired, healthy, and functioning conditions 

and processes. 

Revegetation: Establishing or re-establishing desirable plants where desirable plants are absent or of inadequate 

density, either by controlling site conditions (including the suppression of unwanted competition) so existing vegetation 

can reseed and spread, or by direct seeding or transplanting. 

Right-of-way (ROW): A permit or an easement that authorizes the use of lands for certain specified purposes, such as 

the construction of forest access roads, gas pipelines, or power lines. 

Rill erosion: An erosion process in which many small channels a few centimeters deep are formed. It occurs mainly 

on recently denuded soils. 

Riparian area: Those terrestrial areas where the vegetation complex and microclimate conditions are products of the 

combined presence and influence of perennial and/or intermittent water, associated high water tables, and soils that 

exhibit some wetness characteristics. Normally used to refer to the zone within which plants grow rooted in the water 

table of these rivers, streams, lakes, ponds, reservoirs, springs, marshes, seeps, bogs, and wet meadows. 

Risk: The likelihood that a given exposure to an item or substance (e.g. herbicide dose) will produce illness or injury. 

Risk assessment: The process of gathering data and making assumptions to estimate short- and long-term harmful 

effects to human health or elements of the environment from particular products or activities. See Appendix 8. 

Risk quotient (RQ): The Estimated Environmental Concentration (EEC), as calculated through computer modeling, 

divided by the LD50 (lethal dose where 50% of test population dies) or LC 50 (lethal concentration for aquatic 

forms, where 50% of the test population dies). RQs were developed to provide a more realistic scenario of herbicide 

exposure. Even so, results assume 100 percent exposure and animals confined to the treatment area. For species that 

are at all mobile, such exposures are unlikely from the applications proposed by the action alternatives. Analogous to 

Hazard Quotient. An RQ less than or equal to 1 is presumed to indicate an acceptably low level of risk for a specific 

application. 

Risk quotient: The lowest reported acute statistical endpoint (e.g. NOAEL, LOEAL) or Toxicity reference value 

(TRV) divided by the estimated exposure concentration (ECC). See Chapter 3, High, Medium, and Low Risk in BLM 

and FS Risk Assessments. 

Runoff: Overland flow; that part of precipitation, as well as any other flow contributions that does not soak into soil or 348 
Draft Environmental Impact Statement: Glossary 

stay held on the site for evaporation or transpiration, but runs into streams. 

Salmonids: Fishes of the family Salmonidae, including salmon, trout, chars, whitefish, ciscoes, and grayling. 

Sand: In soil, particles .05 to 2 mm in diameter. 

Savannah: Areas with canopy cover (generally dominated by oaks) less than 30 percent, and grass dominated 

understory. 

Scenic trails: See national scenic trails. 

Sclerophyllous: Hard-leaved evergreen shrubs that are adapted to hot summers. 

Scoping: A process at the beginning of a NEPA analysis whereby the public is asked to provide oral or written 

comments about the scope of the analysis and the range of alternatives, to help ensure the analysis appropriately 

addresses potential effects on individuals, communities, and the environment. 

Sediments: Unweathered geologic materials generally laid down by or within water bodies; the rocks, sand, mud, silt, 

and clay at the bottom and along the edge of lakes, streams, and oceans. 

Sedimentation: The process of forming or depositing sediment; letting solids settle out of wastewater by gravity 

during treatment. 

Seed orchard: A plantation of clones or seedlings from selected trees; isolated to reduce pollination from outside 

sources; weeded of undesirables; and cultured for early and abundant production of seed. 

Selective herbicide: A chemical designed to affect only certain groups or types of plants, leaving other tolerant plants 

unharmed. 

Semi-arid: Moderately dry; region or climate where moisture is normally greater than under arid conditions, but still 

limits the production of vegetation. 

Sensitive species (Bureau Sensitive): Native species designated by the state director as sensitive because they are 

found on BLM-administered lands for which the BLM has the capability to significantly affect the conservation status 

of the species through management, and either: 1. There is information that a species has recently undergone, is 

undergoing, or is predicted to undergo a downward trend such that the viability of the species or a distinct population 

segment of the species is at risk across all or a significant portion of the species range, or 2. The species depends 

on ecological refugia or specialized or unique habitats on BLM-administered lands, and there is evidence that such 

areas are threatened with alteration such that the continued viability of the species in that area would be at risk (USDI 

2008d). See also Bureau Sensitive. 

Seral: Pertaining to the sequence of ecological communities successively occupying an area from the initial stage to 

the climax. 

Sheet erosion: The removal of a fairly uniform layer of soil from the land surface by runoff water. 

Short-term effects: Effects occurring during or shortly after project implementation and normally ceasing or 

recovering within hours to weeks, depending upon the resource. 

Shrub steppe vegetation: See Sagebrush Steppe Biome description near the beginning of Chapter 4. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Significant: The description of an impact that exceeds a certain threshold level. Requires consideration of both 

context and intensity. The significance of an action must be analyzed in several contexts, such as society as a whole, 

and the affected region, interests, and locality. Intensity refers to the severity of effects, which should be weighed along 

with the likelihood of its occurrence. Determination of significance for effects is a management decision considering 

multiple factors, and not one made by technical specialists to indicate the quantity of effects are above or below some 

level.
 

Silt: In soil, particles between .002 and .05 mm in diameter.
 

Socioeconomic: Pertaining to, or signifying the combination or interaction of social and economic factors. 

Soil compaction: The compression of the soil profile from surface pressure, resulting in reduced air space, lower water 

holding capacity, and decreased plant root penetrability. 

Soil horizon: A layer of soil material approximately parallel to the land surface that differs from adjacent genetically 

related layers in physical, chemical, and biological properties. 

Special status species: Federally Listed threatened, endangered, proposed, or candidate species, and species managed 

as sensitive species by the BLM. 

Species: A group of organisms all of which have a high degree of physical and genetic similarity, generally interbreed 

only among themselves, and show persistent differences from members of allied groups of organisms.
 

Spot treatment: An application of an herbicide to a small selected area such as an individual plant, as opposed to a 

broadcast application. 

Stabilizer: A type of inert ingredient added to a commercial pesticide that makes the mixture more stable. 

Stand: A group of trees, shrubs, or grasses in a specific area that is sufficiently alike in composition, age, arrangement, 

and condition so as to be distinguishable from the vegetation in adjoining areas. 

Standard operating procedures (SOPs): Procedures that would be followed by the BLM to ensure that risks to 

human health and the environment from treatment actions were kept to a minimum. See Appendix 2. 

Step-down: The process of applying broad-scale science findings and land use decisions to site-specific areas using a 

hierarchical approach of understanding current resource conditions, risks, and opportunities. 

Stressor: Any event or situation that precipitates a change. 

Subalpine: A terrestrial community that generally is found in higher elevation harsher environments than the montane 

terrestrial community. Subalpine communities are generally colder than montane and support a unique clustering of 

plant and wildlife species. 

Subchronic toxicity: The ability of the substance to cause effects for more than one year but less than the lifetime of 

the exposed organism. 

Subchronic: The effects observed from doses that are of intermediate duration, usually 90 days. 

Subsistence: Customary and traditional uses of wild renewable resources (plants and animals) for food, shelter, fuel, 

 350 
 

 

Draft Environmental Impact Statement: Glossary 

clothing, tools, etc. 

Substantive: Possessing substance; having practical importance, value, or effect. 

Succession: The change in structure and composition of plant and animal communities over time. Usually used to 

describe the advancement of a younger, pioneering community to an older differing in species age, composition, and 

processes, and thus may be reset by fire or other disturbance. 

Surface water: Water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, impoundments, seas, 

estuaries, etc.) and all springs, wells, or other collectors that are directly influenced by surface water. 

Surfactant: A material that improves the emulsifying, dispersing, spreading, wetting, droplet size, or other surfacemodifying properties of liquids. 

Surrogate: A substitute or stand-in. 

Synergistic: A type of cumulative effect where total effect is greater than the sum of the effects taken independently. 

Tank mixture: The mixture of two or more compatible herbicides in a spray tank in order to apply them 

simultaneously. 

Target species: A species (in this EIS, a plant species) that is a target or goal of a treatment or control effort. 

Teratogenic: Causing structural defects that affect the development of an organism; causing birth defects. 

Terrestrial: Of or relating to the earth, soil, or land; inhabiting the earth or land. 

Threatened species: A plant or animal species federally listed as threatened under the Endangered Species Act, and 

status defined as likely to become an endangered species throughout all or a significant portion of its range within the 

foreseeable future. 

Threshold: A dose or exposure below which there is no apparent or measurable adverse effect. 

Tier: Incorporating by reference the analyses in an EIS or similar document of a broader scope. For example, BLM 

field offices could prepare environmental assessments for local projects that tier to this EIS. 

Tolerable soil loss: The maximum annual amount of soil which can be removed before the long-term natural soil 

productivity is adversely affected.
 

Tolerances: EPA limits on the amount of a pesticide permitted in foods or drinking water.
 

Total suspended particles (TSP): A method of monitoring airborne particulate matter by total weight. 

Toxicity: A characteristic of a substance that makes it injurious. 

Toxicity reference value (TRV): A quantitative benchmark. For each herbicide, receptor, and route of exposure, the 

lowest reported acute statistical endpoint was selected as the Acute TRV.
 

Traditional use areas (Native American plant gathering): Areas where tribes continue to gather plant materials for 

food, basketry, and other traditional uses. These may or may not be treaty reserved rights and/or areas. 

Transpiration: Water loss from plants during photosynthesis. 351 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Treaty resources: Resources for which one or more tribes have treaty rights. An exhaustive list does not exist, 

because American Indian tribes maintain confidentiality for names of medicines or spiritual plants and other natural 

resources. 

Treaty rights: Tribal rights or interests reserved in treaties, by American Indian tribes for the use and benefit of their 

members. The uses include such activities as described in the respective treaty document. Only Congress may abolish 

or modify treaties or treaty rights. 

Tribe: Term used to designate any American Indian band, nation, or other organized group or community, which is 

recognized as eligible for the special programs and services provided by the U.S. to American Indians because of their 

status as Indians. 

Trophic: Of or pertaining to nutrition; concerned in nutritive processes. 

Trust land: Any land in collective tribal holding or individual ownership for which the Secretary of the Interior has 

a continuing responsibility to manage in a manner to benefit the respective tribe or individual. The most common 

example is forested acres on a reservation. Some Trust lands were set aside as compensation for claims made against 

the Government; most of which are off-reservation. 

Typical rate or typical application rate: One of two application rates considered in many Risk Analyses (the other 

being Maximum Rate); a rate based upon a general summary of actual applications that have been made of the different 

formulations of a particular active ingredient on BLM lands. Under some situations, this value may be higher or 

lower than what is going to be applied for a specific job. The rate of application of any pesticide is based upon several 

factors, including, but not limited to, the species to be controlled, the environment for which the application is to be 

made, the timing of the application, and other factors. For example, a typical rate of application for imazapic is about 

2.0 fluid ounces of Plateau, which, when taking into the concentration of the formulated product (2.0 pounds acid 

equivalent/per gallon) equates to 0.0313 lb. a.e./acre. It is known that 2.0 fluid ounces of Plateau will achieve a specific 

level of control under a specific set of conditions. Rates around 4.0 to 6.0 fluid ounces of imazapic appear to be the 

more common range for activity, based on the experience of researchers, for downy brome. The rate is based upon 

what is identified as what is normally considered for application under a normal condition. See Background for Effects 

Analysis in Chapter 3 for table of amounts of a.e./acre. 

Uncertainty factor: A multiplier used in risk assessments to compensate for unknown risks due to limitations in 

the research . 

Understory: Plants that grow beneath the canopy of other plants. Usually refers to grasses, forbs, and low shrubs 

under a tree or shrub canopy. 

Upland: The portion of the landscape above the valley floor or stream. 

Urticaria: A transient condition of the skin usually caused by an allergic reaction, characterized by pale or reddened 

irregular, elevated patches and severe itching; hives. 

Utility corridor: A linear strip of land identified for the present or future location of utility lines. 

Vascular plants: Plants that have specialized tissues that conduct nutrients, water, and sugars along with other 

specialized parts such as roots, stems, and reproductive structures. Vascular plants include flowering plants, ferns, 

shrubs, grasses, and trees. 

Vertebrate: An animal with a backbone, such as fish, amphibians, reptiles, birds, and mammals. 

 352 
Draft Environmental Impact Statement: Glossary 

Visual resources: The visible physical features of a landscape. 

Vitiligo: A skin disorder characterized by smooth, white patches on various parts of the body, caused by the loss of the 

natural pigment. 

Volatilization: The conversion of a solid or liquid into a gas or vapor; evaporation of herbicide before they are bound 

to a plant or ground. 

Water quality: The interaction between various parameters that determines the usability or non-usability of water 

for on-site and downstream uses. Major parameters that affect water quality include temperature, turbidity, suspended 

sediment, conductivity, dissolved oxygen, pH, specific ions, discharge, and fecal coliform. 

Watershed: The region draining into a river, stream, or body of water. 

Weed: A plant considered undesirable and that interferes with management objectives for a given area at a given point 

in time. 

Wetlands: Those areas that are inundated or saturated by surface water or groundwater at a frequency and duration 

sufficient to support, and that under normal circumstance do support, a prevalence of vegetation typically adapted for 

life in saturated soil conditions. Wetlands include habitats such as swamps, marshes, and bogs. 

Wild and scenic rivers: Rivers designated in the National Wild and Scenic Rivers System that are classified in one 

of three categories (wild, scenic, or recreational), depending on the extent of development and accessibility along each 

section. In addition to being free flowing, these rivers and their immediate environments must possess at least one 

outstandingly remarkable value: scenic, recreational, geologic, fish and wildlife, historical, cultural, or other similar 

values. 

Wilderness: Land designated by Congress as a component of the National Wilderness Preservation System. 

Characteristics qualifying an area for wilderness are: 1) naturalness - lands that are natural and primarily affected 

by the forces of nature; 2) roadless and having at least 5,000 acres of contiguous public lands; and 3) outstanding 

opportunities for solitude or primitive and unconfined, non-motorized types of recreation. In addition, areas may 

contain “supplemental values,” consisting of ecological, geological, or other features of scientific, educational, scenic, 

or historical importance. 

Wilderness study area: An area managed so as not to impair its suitability as wilderness, while Congress determines 

whether to designate it as wilderness. 

Wildfire: An unwanted wildland fire. 

Wildland fires: Fires occurring on wildlands, regardless of ignition source, damages, or benefits, and including 

wildfire and prescribed fire. 

Wildland urban interface (WUI): An area where structures and other human development intermingle with 

undeveloped wildlands or vegetative fuels. 

Woodland: Areas with oak or other hardwoods occupying greater than 30 percent canopy cover, generally forming 

only an open canopy with the intervening area being occupied by lower vegetation, commonly grass. 

Xeric: Very dry region or climate; tolerating or adapted to dry conditions (e.g. desert). 

353 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

 354
 
 

 

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Draft Environmental Impact Statement: List of Preparers 

List of Preparers 

Cathi Bailey – Outdoor Recreation Planner and Program Lead for Recreation, Visual Resources, and Wild and Scenic 

Rivers. Cathi has a B.S. in Wildland Recreation Management from the University of Idaho. She has worked for federal land 

and water management agencies for 22 years in California, Wyoming, and Oregon. Cathi has held positions as an Outdoor 

Recreation Planner, Natural Resource Specialist, Interdisciplinary Program Coordinator, and Environmental Specialist. 

Richard Bailey – Archeologist/Cultural Heritage Program Manager. Richard received a B.S. in Sociology/ 

Anthropology from Montana State University and a M.A. in Anthropology from Washington State University. 

He has worked for archaeological contracting firms and universities including the Washington Archaeological 

Research Center at Washington State University. He has worked with the Spokane District BLM since 1993 

and is currently the District Archaeologist. His professional research interests include ethno-botany, lithics, and 

historic preservation. 

Michael Crawford – Seed Orchard Program Manager. Mike has a B.S. in Forest Science from The 

Pennsylvania State University. Mike has worked for the BLM orchard program for 11 years. He also spent 8 

years working as a forester/silviculturist for the U.S. Forest Service and 6 years as a forester/research assistant for 

Oregon State University. Mike has been involved with work in orchard management, operational reforestation/ 

regeneration, and reforestation research. 

Christine Denton - Database Coordinator – Writer/Editor. Christi graduated from Mills College with a B.A. in 

2000, and got a graduate degree from CCMIX in France in 2004. She worked as a database engineer for several 

software companies in the San Francisco Bay Area, and then as an administrator and logistician for NGOs and 

other non-profits. She was the writer/editor - database coordinator on the Survey and Manage SEIS Team (2007). 

She is currently the owner of an environmental company that prepares NEPA documents. 

Ken Denton – Team Leader. Ken has a B.S. in Natural Resources from Humboldt State. He was with the Forest 

Service for 34 years until 2004, working in silviculture and planning in California, Idaho, and Oregon. He served 

most recently on the interdisciplinary teams for the Forest Service EIS for the northern spotted owl (1992), 

the Northwest Forest Plan SEIS (1994), the Survey and Manage SEISs (2000, 2004), and was Team Leader 

for the Port-Orford-cedar SEIS (2004) and Survey and Manage SEIS (2007). He is currently a partner in an 

environmental company that prepares NEPA documents. 

Al Doelker - Fisheries Biologist. Al received a B.S. in Fisheries Biology from Humboldt State University. After 

seasonal employment with the BLM, U.S. Forest Service, and Army Corps of Engineers, he worked for a private 

salmon hatchery in Oregon. He has worked for the BLM since 1990, working in Arizona and Oregon. He has 

most recently been involved with broad scale aquatic and riparian monitoring and analysis, application of aquatic 

conservation strategies, database development, Endangered Species Act consultation, and compliance with the 

Clean Water Act. 

Henry Eichman – Economist. Henry received a B.A. in Biology from Colorado College and a M.S. in 

Agricultural and Resource Economics from Oregon State University. He held positions as a biological technician 

for the Colorado Department of Wildlife, the US Forest Service Rocky Mountain Research Station, and the 

Rio Grande National Forest, and in 2006 began providing the BLM with social and economic support for site 

specific and programmatic planning efforts in Montana, New Mexico, Oregon, North Dakota, and South Dakota. 

Henry works for the Forest Service and provides social and economic support for Forest Service planning efforts 

throughout the nation. 

Louisa Evers – Fire Ecologist. Louisa received a B.S. in Forestry from the University of Tennessee and an M.S. 

in Forest Resources Management from the University of Idaho. Louisa has 28 years of experience in wildland 

fire and 20 years as a fuels specialist and fire ecologist in the Northern Rockies, Pacific Northwest, Great Basin, 

389 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

and Southwest for both the Forest Service and BLM. She currently has responsibilities in fire ecology, NEPA, 

monitoring, fire behavior, managing wildfires for resource benefits, and climate change. 

Karl Ford – Toxicologist. Karl has a Ph.D in Environmental Health from Colorado State University. He 

worked for several national environmental consulting firms in toxicology and hazardous waste and served on 

the faculty at California State University Northridge. For the past 17 years, he has served as BLM’s toxicologist 

and remediation advisor throughout the 12 western states, including serving as an advisor in toxicology and risk 

assessment for the PEIS 2003-2007, and instructing Certified Pest Management class. 

Maya Fuller – Public Affairs Specialist. Maya has a B.A. from the University of Oregon and a Masters of 

Public Administration from Portland State University. Maya develops and coordinates public outreach efforts 

and manages high profile issues for the BLM. Her primary functions are problem solving and issue resolution, 

information sharing, reporting, and media relations. 

Ellen Michaels Goheen - Plant Pathologist. Ellen received her B.S. in Forestry from the University of Montana 

and M.S. in Plant Pathology from Washington State University. She has worked on the Forest Health Protection 

staff of the Forest Service since 1983. She is the lead plant pathologist for the Pacific Northwest Region’s Sudden 

Oak Death program. 

Gary R . Harris - Tribal Relations. Gary graduated from Southern Illinois University with a B.S. in Forestry in 

1979, and received a Certificate from the U.S. Department of Defense Information Officer School at Ft. Mead, 

Maryland. He has worked for the Forest Service on four national forests and two regional offices as a forestry 

technician, forester, forest plan writer-editor, GIS coordinator, ranger district management assistant, district 

ranger, and regional legislative affairs program manager. He is currently the Tribal Relations Staff for both the 

USDA Forest Service R6 Regional Forester and USDI Bureau of Land Management Oregon/Washington State 

Director. 

Robert G . Hopper - Rangeland Management Specialist and Wild Horses and Burro Program Lead. Robert 

obtained a B.S. in Range Management from Washington State University. He has served in his current position in 

the Oregon State Office since January 2007. He has held positions with the BLM in Nevada and Oregon as a soil 

scientist, range management specialist, supervisory rangeland management specialist and a supervisory natural 

resource specialist. He tasks include fire restoration, prescribed fire planning and implementation, grazing permit 

renewals and administration, and wild horse and burro management. 

Carole Jorgensen – Wildlife Biologist. Carole received a B.S. from the University of Montana. She worked for 

three years with the US Fish and Wildlife Service before working for the BLM in Eugene, Rawlins, Prineville, 

Lakeview, a detail in the Washington DC office, and now as District Wildlife Biologist in Medford BLM. She is a 

member of several professional societies. Her primary professional interests include ecological relationships, rare 

species management, carnivore biology—particularly bears, and public land management. 

Brenda Lincoln Wojtanik – Program Analyst. Brenda received a B.A. in Political Science from the State 

University of New York at Albany and an M.S. in Environmental Science from the State University of New York, 

College of Environmental Science and Forestry. Brenda has worked as a public affairs specialist with the BLM 

Oregon State Office and as the Deputy Communications Team Leader for the Interior Columbia Basin Ecosystem 

Management Project. She currently provides project support to the Vegetation Treatments Using Herbicides on 

BLM Lands in Oregon EIS team. 

Jerry Magee –Wilderness and National Landscape Conservation System Program Lead. Jerry has a B.S. in 

Environmental Planning & Management from the University of California, Davis, and a Master of Environmental 

Law and Policy from Vermont Law School. He has worked for the BLM since 1976 beginning as Outdoor 

Recreation Planner and Wilderness Specialist, and since severing on various EIS teams and in NEPA and 

environmental planning jobs at district or state offices in California and Oregon, with details to the Washington 

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Draft Environmental Impact Statement: List of Preparers 

Office and to the Department of the Interior. He is currently the Wilderness and National Landscape Conservation 

System Program Lead in the BLM state office in Oregon. 

Leanne Mruzik - Fuels Management Specialist. Leanne completed the Technical Fire Management (TFM) 

program accredited through Colorado State University in 2000. Leanne began her career in fire in 1987, and 

continued working seasonally with the Forest Service on the Klamath and Shasta-Trinity National Forest in 

California until 1996. In 1997, Leanne joined the BLM on the Medford District as a fuels management specialist 

and eventually becoming the fuels program lead for the Butte Falls Resource Area, until being hired into her 

position at the State Office as the Fuels Management Program Lead for Oregon and Washington in 2008. Leanne 

has been involved with watershed analysis, environmental analysis, planning and implementation of a complex 

integrated fuels management program, restoration projects, and community education and outreach projects 

related to fire and fuels. 

Adrienne Pilmanis - Botanist. Adrienne has a BS in Biology from the University of Colorado, an MS in Botany 

from Duke University. She started working in ecology and botany in the early 1990’s doing seasonal ecological 

studies on the Nevada Test Site. She spent several years doing advanced academic research before joining the 

Oregon State office of BLM as the Regional Data Steward for the Special Status Species Program in 2005, and 

is now the Botany Lead at the BLM Wyoming State Office. Adrienne’s research included spatial analysis of soil 

and vegetation heterogeneity in disturbed Chihuahuan desert, nitrogen cycling under simulated global change 

scenarios in Colorado Plateau grasslands, and Holocene vegetation and fire history in northwestern Ontario. . 

Jeff Rose - BLM Eastern Oregon Sagebrush Conservation Coordinator. Jeff has a MS in Rangeland Resources 

from Oregon State University. Beginning in 1986, he has served as a Range Conservationist for the Confederated 

Tribes of Warm Springs, Research Associated for the Eastern Oregon Agricultural Research Center in Burns, 

OR, and as a Fire Ecologist for the Burns District of the Bureau of Land Management. Jeff has authored or 

coauthored 15 journal articles relating to ecology and management of western juniper woodlands and sagebrush 

steppe habitats. In his current position, Jeff works with BLM districts in Oregon to coordinate restoration and 

conservation activities concentrating on sagebrush and western juniper habitats. 

Jeanne M . Standley – Botanist and Weed Coordinator. Jeanne has a B.S in Rangeland Resources at Oregon 

State University. She began her federal career with the Soil Conservation Service in eastern Oregon in 1983. 

She worked seasonally for the Extension Service in Roseburg as a Forestry technician and as a botanist for the 

USFS in Glide, OR, and joined the BLM in 1986. Jeanne served as the district weed coordinator and botanist in 

Roseburg, and as the state program lead for several programs in Alaska including Forestry, Botany, Range, and 

Weeds, as well as co-leading a team to implement Burned Area Emergency Stabilization and Rehabilitation on 6.4 

million acres. She is the weed coordinator with the Coos Bay District, and a member of the EIS core team. 

Dale A . Stewart – Soil Scientist. Dale obtained a B.S in Forestry and a M.S. in Biological Sciences from 

Michigan Technological University. He worked for the United States Forest Service on the Fremont National 

Forest in Oregon and the Ouachita National Forest in western Arkansas. He has worked for the BLM, Coos 

Bay District since 1986 in forest management as a timber sale administrator and planner, silviculturist, and since 

1994, as the district soil scientist. He has been involved in watershed analysis, environmental analysis, and 

implementation of forest management activities and restoration projects such as road decommissioning, culvert 

replacements and sediment control 

Eric Stone - Program Analyst, Planning and NEPA. Eric obtained a B.S. in Forestry from the University of 

Connecticut and a M.S. in Forest Management from Oregon State University. He is currently employed as a 

consultant with the Oregon State Office, BLM in Portland Oregon. Before retiring from the BLM, he had held 

positions as a field forester, natural resource specialist, environmental coordinator, regional planner and program 

analyst from 1969-2004. He was involved at the State Office level in all land use planning and major activity 

plans in Oregon/Washington from 1980-2004. He has previously worked in the BLM Salem District and Eastern 

States and Montana State Offices. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Todd Thompson – Natural Resource Specialist – Restoration Coordinator and Vegetation Treatments EIS Team 

Project Manager. Todd has a B.S. in Wildlife Resources from the University of Idaho in Moscow. He worked 

for the Idaho Fish & Game as a Wildlife Technician before joining the BLM in Spokane where he was the 

Border Resource Area Wildlife Biologist and in 1996 became District Fish, Wildlife & Botany Program lead. 

. Before managing the EIS Team, he was primarily involved in partner-based habitat restoration and vegetation 

management projects including a number of shrub-steppe and riparian/aquatic projects located throughout eastern 

Washington and northern Idaho. 

Carol Thornton – Hydrologist. Carol has a B.S. in Geology from the University of Oregon and a M.S. in 

Hydrology from the University of Nevada Reno. She worked for BLM for two years as a hydrologist and then 

went to work in 2002 for the Forest Service as a member of TEAMS, an enterprise unit. Her work takes her to 

projects throughout the west and occasionally to the eastern U.S. NEPA projects include timber sales, salvage 

sales, and other invasive plant EIS’s. Non-NEPA projects have included stream surveys and watershed analysis. 

Brian J . Watts - Fire Ecologist. Brian has a B.S. in Rangeland Management from Oregon State University. 

Brian has worked in both Range Management and Fire Management since 1992 with both the United States 

Forest Service and BLM in Oregon, Idaho, Nevada, and New Mexico. He is currently Fire Ecologist with the 

Bureau of Land Management on the Vale District in eastern Oregon. 

Special Acknowledgments 

Jerry Asher - Retired BLM special assistant to the State Director for noxious and other invasive weeds. Thanks for the 

references, leads, review of working papers, and review of the EIS. 

Program and other specialists in the BLM Oregon State Office for contributing technical information to a section, 

or contributing to other aspects of the document preparation: Paul Fyfield (cartography); Craig Ducey (GIS); David 

Garcia (typesetting and document layout); Jeannette Griese (timber); John Styduhar (rights-of-way); Don Ehrich 

(administrative sites); Chris Knauf (OHVs); Janell Addison (administrative support); Joan Seevers (Research 

Natural Areas); Steve Bulkin (Human Health); David Garcia and Shelly York (document preparation and printing). 

BLM District Weed Coordinators: Dan Tippy, Lynn Silva, Mike Woods, Lesley Richman, Erin McConnell, Molly 

Boyter, Claire Hibler, Nancy Sawtelle, Susan Carter, Mark Mousseaux, Glen Harkleroad, Brennan Hauk, Jeanne 

Standley 

Steering Committee: 

Mike Mottice (Deputy State Director to May 2009), Mike Haske (Deputy State Director since May 2009), Miles Brown 

(Branch Chief, Rangeland Resource, Recreation, and Wilderness), Dave Henderson (District Manager, Vale), Mark 

Johnson, EIS Steering Committee President (District Manager, Coos Bay) 

About 30 internal reviewers and the members of the Southeast Oregon Resource Advisory Council and the John Day/ 

Snake Resource Advisory Council for their pre-publication review. 

Rochelle Desser, Doug Daoust, Shawna Bautista, Cathy Selby, and other members of the Forest Service Invasive 

Plant EIS Team. 

Susan Hale and the members of the public who participated in scoping in July 2008. 

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Draft Environmental Impact Statement: Distribution List 

Distribution List
 

Elected Officials
	

Governor Ted Kulongoski 

U .S Senators 

Ron Wyden 

Jeff Merkley 

U .S . Representatives 

David Wu 

Greg Walden 

Earl Blumenauer 

Peter DeFazio 

Kurt Schrader 

Oregon State Senators 

Jason Atkinson 

Alan Bates 

Suzanne Bonamici 

Brian Boquist 

Ginny Burdick 

Margaret Carter 

Peter Courtney 

Richard Devlin 

Jackie Dingfelder 

Ted Ferrioli 

Larry George 

Fred Girod 

Mark Hass 

Ken Jacobsen 

Betsy Johnson 

Jeff Kruse 

Rick Metsger 

Laurie Monnes Anderson 

Rod Monroe 

Bill Morrisette 

Frank Morse 

David Nelson 

Floyd Prozanski 

Diane Rosenbaum 

Bruce Starr 

Chris Telfer 

Joanne Verger 

Vicki Walker 

Doug Whitsett 

Jackie Winters 

Oregon State 

Representatives 

Jules Bailey 

Jeff Barker 

Phil Barnhart 

Brent Barton 

Cliff Bentz 

Vicki Berger 

Elizabeth Beyer 

Deborah Boone 

Scott Bruun 

Peter Buckley 

Kevin Cameron 

Ben Cannon 

Brian Clem 

Jean Cowan 

Michael Dembrow 

Chris Edwards 

David Edwards 

Sal Esquivel 

Tim Freeman 

Larry Galizio 

Bill Garrard 

Chris Garrett 

Sara Gelser 

Vic Gilliam 

George Gilman 

Mitch Greenlick 

Bruce Hanna 

Chris Harker 

Paul Holvey 

John Huffman 

Dave Hunt 

Bob Jenson 

Nick Kahl 

Bill Kennemer 

Betty Komp 

Tina Kotek 

Wayne Krieger 

Greg Matthews 

Ron Maurer 

Nancy Nathanson 

Mary Nolan 

Andy Olson 

Tobias Read 

Dennis Richardson 

Chuck Riley 

Arnie Roblan 

Mike Schaufler 

Chip Shields 

Greg Smith 

Jefferson Smith 

Sherrie Sprenger 

Judy Stiegler 

Kim Thatcher 

Jim Thompson 

Carolyn Tomei 

Suzanne VanOrman 

Jim Weidner 

Gene Whisnant 

Matt Wingard 

Brad Witt 

Washington State 

Senators 

Ken Jacobsen 

County Commissioners 

Lane County Commissioner 

Faye Stewart 

Lincoln County 

Commissioners 

Stevens County 

Commissioners 

Tillamook County 

Commissioner Charles 

Hurliman 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Federal Agencies 

Environmental Protection Agency 

Region 10 

Department of Agriculture 

Forest Service 

Region 6 

Bend/Fort Rock Ranger District 

Modoc National Forest 

Ochoco National Forest 

Wallowa-Whitman National Forest 

Winema National Forest 

PNW Research Station 

Natural Resource Conservation Service 

Department of Commerce 

NOAA Fisheries 

Department of Defense 

US Army Corps of Engineers 

Department of Energy 

Bonneville Power Administration 

Department of the Interior 

Bureau of Indian Affairs 

Bureau of Land Management 

Washington Office
	

California State Office
	

Colorado State Office
	

Idaho State Office
	

Montana State Office
	

Nevada State Office
	

Oregon State Office 

Arcata Office 

Baker Office 

Burns Office 

Coos Bay Office 

Eugene Office 

Grants Pass Office 

Klamath Falls Resource Area 

Lakeview Office 

Medford Office 

Prineville Office 

Roseburg Office 

Salem Office 

Tillamook Office 

Vale Office 

Lake Havasu (AZ) Office 

Snake Resource Advisory Committee 

Southeast Oregon Resource Advisory Committee 

Bureau of Reclamation 

Fish and Wildlife Service 

Bend Field Office 

Ecological Services Program 

Eagle Creek National Fish Hatchery 

Klamath Basin National Wildlife Refuge 

National Park Service 

Whitman Mission National Historic Site 

USGS Research 

Department of Justice 

Bureau of Alcohol, Tobacco, Firearms and Explosives 

State, County, and Local Governments
 

Idaho 

Deptartment of Lands 

Oregon 

Department of Agriculture

 Noxious Weed Control 

Department of Environmental Quality 

Department of Fish and Wildlife 

Department of Forestry 

Department of State Lands 

Research Reserve South Slough NERR 

Department of Transportation 

District 11E 

Parks and Recreation Department 

Water Resources Department 

Soil and Water Conservation Districts 

Crook County SWCD 

Douglas SWCD
 

East Multnomah SWCD
 

Josephine County SWCD
 

Marion SWCD
 

Polk SWCD
 

Sherman County SWCD
 

Tualatin SWCD
 

Upper Willamette SWCD
 

West Multnomah SWCD
 

Watershed Councils 

Columbia Slough Watershed Council 

Gilliam-East John Day Watershed Council 

Harney County Watershed Council 

Lower Columbia River Watershed Council 

Tualatin River Watershed Council 

North Fork John Day Watershed Council 

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Draft Environmental Impact Statement: Distribution List 

Mid John Day & Bridge Creek Watershed 

Councils
 

McKenzie River Watershed Council 

Malheur Watershed Council 

Counties 

Association of O & C Counties 

Benton County 

Coos County 

Curry County 

Deschutes County

 Sheriff’s Posse 

Douglas County Land Dept 

Garfield County Noxious Weed Control Board 

Gilliam County Road Department 

Harney County 

Court 

CWMA 

Hood River County 

Jackson County Roads and Parks 

Josephine County 

OSU Extension Office 

Parks 

Klamath County 

Weed Supervisor
 

Planning Department
 

Lane County 

Public Works 

Council of Governments 

Lincoln County Road Dept. 

Linn County Road Department 

Malheur County Weed Control 

Marion County Public Works 

Polk County Public Works 

Sherman County Assessor 

Umatilla County 

Wallowa County 

American Indian Tribes and Nations 

Burns Paiute Tribe 

Confederated Tribes of Siletz Indians 

Confederated Tribes of the Colville Reservation 

Confederated Tribes of the Coos, Lower Umpqua and 

Siuslaw Indians 

Confederated Tribes of the Grand Ronde Community of Oregon 

Confederated Tribes of the Umatilla Indian Reservation 

Coquille Tribe 

Cow Creek Band of Umpqua Tribes of Indians 

Wasco County Weed Department 

Yamhill County Sheriff Crabtree 

Cities and Communities 

Applegate Fire Plan 

Canyon City Watermaster Office 

Corbett Water Dist 

Cottage Grove 

Eugene 

Water & Electric Board 

Hillsboro - Water 

Jordon Valley Cooperative Weed Management 

Area 

Lacomb Irrigation District 

Medford Water Commission 

Mt Hood Community Planning Organization 

North Unit Irrigation District 

Oxbow Park 

Port of Coquille River 

Redmond 

Tumalo Irrigation Dist 

Water Resources Section: Public Works 

Department 

Washington 

City Of Ilwaco 

Washington Department of Fish and Wildlife 

WSDOT Southwestern Region 

County Weed Boards 

Klickitat County Noxious Weed Control 

Board 

Lewis County Noxious Weed Control 

Board 

Pend Oreille County Weed Board 

Snohomish County Noxious Weed Control 

Board 

Yakima County Noxious Weed Board 

Fort Bidwell Indian Community 

Fort McDermitt Tribe 

Klamath Tribes 

Latgawa Native American Indian Tribe 

Nez Perce Tribe 

Siletz Tribe 

Warm Springs Reservation 

Yakama Tribe 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Businesses 

ABC Tree Farms 

Al Peirce Co 

Arrowhead Timber Company 

Babylon Computer 

Barnes Cattle Company 

BASF Corporation 

Benton Rock Products 

Big Wind Oregon LLC 

Boise Cascade Co 

Box R Water Analysis Lab 

Buckhorn Ranch 

C&D Lumber Company 

Capital Press 

Central Lincoln People’s Utility District 

Chevron Pipe Line Co 

Coast Range Conifers LLC 

Comfort Control Heating 

Consumers Power Inc. 

Coos County Sheep Company 

Crook Timberlands LLC 

Crump Ranch 

Curtis Wicks Contracting 

Custom Installation 

Davidson Industries Inc 

Devil’s Canyon Ranch 

Douglas Electric Coop 

Douglas Timber Operators 

Dow AgroSciences 

DuPont Crop Protection 

Ed Garrett Ranch, Inc 

Emigrant Creek Ranch 

ENSR International 

EP Minerals LLC 

Ferris Creek Ranch 

Ferris Nursery 

Flying Buffalo Ranches 

Forest Capital Partners 

Freres Timber Inc 

Georgia Pacific LP 

Giustina Land & Timber Co 

Giustina Resources 

Greyskull Enterprise, LLC 

Habitat Creations 

Haglund Kelley 

Healy Ranch 

HGJ Livestock 

High Desert Museum 

High Heaven Timberlands 

Hollingsworth Tree Farms LLC 

Idaho Power 

Indian Hill, LLC 

Inshallah Ranch Inc. 

Jacobs Ranch 

James Matteri & Sons 

Jerry & Linda Miller Ranch LLC 

JKs Rough String Ranch 

JWTR LLC 

Lane Electric Coop 

Loghouse Plants 

Lone Rock Timber Management 

Company 

Mackenzie Ranch 

McMinnville Water and Light 

MBM Group 

McDade Ranch 

Miller Ranch 

Morgan Woods 

Mortimore Corporation 

Ochoco Valley Ranch 

Optasite Towers LLC 

Oregon - Idaho Utilities 

Oregon End Ranch 

Oregon Safe Tree, Inc. 

Overland Ranch 

Owyhee Grazing Association, LLC 

Pacific Analytics 

Panhandle Spray Service 

Pesticide Research Institute 

PFC Properties 

Plum Creek Timber Company 

Portland General Electric 

Pryor Land And Livestock 

Inc. 

Rashford Tree Farm 

Raven Research 

Resource Management 

Services 

River Run Ranch 

River Trips Unlimited 

Rosboro, LLC 

Roseburg Forest Products 

Roseburg Resources 

Company 

Roxy Ann Gem and Mineral / 

Crater Rock Museum 

Sainte Partners II, L.P. 

Scientific Ecological Services 

Seneca Jones Timber Co 

Seneca Sawmill Company 

Silvies Valley Ranch LLC 

Sno-Peak Nobles 

Spirit Lake Industrial Park 

Starfire Lumber Company 

Stimson Lumber Company 

Stuntzner Engineering 

The Final Edition / Mt. 

Family Calendar 

Timber Products Company 

Tree Top Ranches 

Tri-Creek Ranch 

TtEC 

Up the Creek Ranch 

URS Corporation 

Westfall Ranches 

Weyerhaeuser Company 

Whitewater Ranch 

Wild and Scenic Nursery 

William Smith Properties 

Willow-Witt Ranch 

YJ Ranch 

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Draft Environmental Impact Statement: Distribution List 

Other Organizations 

American Forest Resource Council 

Archaeological Society of Central Oregon (ASCO) 

Associated Oregon Loggers 

Audubon Society of Portland 

Back Country Horsemen and Oregon Equestrian Trails 

Blue Mountains Biodiversity Project and League of 

Wilderness Defenders 

Blue Ribbon Coalition 

Canaries Who Sing, Gaia Vision, Coast Range Guardians, 

and Citizens Environmental Protection Alliance 

Cascade Geographic Society 

Cascadia Wildlands Project 

Cascadia’s Ecosystem Advocates 

Central Oregon Shooting Sports Association 

Citizens for Florence 

Citizens Interested In Bull Run 

Corkscrew Trail 

Crescent Water Association 

Deer Ck Valley Natural Resources Conservation Assn 

Defenders of Wildlife 

Deschutes Land Trust 

Ecola Creek Awareness Project 

Fir Point Bible Conference 

Forestry Action Committee 

Greater Greenwater Gateway Committee 

Hells Canyon Preservation Council 

Hugo Neighborhood Assoc. & Historical Society 

Institute for Culture and Ecology 

International Society for the Protection of Mustangs and 

Burros 

Izaak Walton League of America 

John Day Basin Trust 

Kettle Range Conservation Group 

Klamath Forest Alliance 

Klamath Siskiyou Wildlands Center 

Kootenai Environmental Alliance 

Lane County Audubon Society 

Legacy Lands Project 

Lick Creek Road Association 

Lincoln County Mycological Society 

Lyons Gulch P O A 

Motorcycle Riders Association 

North American Butterfly Association 

Northcoast Environmental Center 

Northwest Coalition for Alternatives to Pesticides 

Northwest Environmental Defense Center 

OHA Harney County Chapter 

Oregon Cattlemen’s Association 

Oregon Council Trout Unlimited 

Oregon Environmental Council 

Oregon Grotto 

Oregon Hunters Association 

Oregon Natural Desert Association 

Oregon Recreation Coalition 

Oregon State Snowmobile Association 

Oregon Toxics Alliance 

Oregon Wild 

Oregonians for Food and Shelter 

Pacific Biodiversity Institute 

Pacific Northwest 4 Wheel Drive Association 

Pacific Rivers Council 

Parsnip Peak Grazing Association 

Partnership for the Umpqua Rivers 

Pitchfork Rebellion 

Plas Newydd 

Redmond Oregon Hunters Association 

Rocky Mountain Elk Foundation 

Rockydale Neighborhood Association 

Rogue Snowmobilers 

Sagebrush Sea Campaign 

Selkirk Conservation Alliance 

Sierra Club 

Siskiyou Project 

SOLV 

Somerset Hills III HOA 

Southeast Oregon Resource Advisory Council 

Sunriver Owners Association 

The Nature Conservancy 

TraditionalMountaineering.org 

Umpqua Valley Audubon Society 

Umpqua Watersheds, Inc. 

Western Watersheds Projects 

Wilderness Watch 

Wildlife Forever 

Willamette Agate and Mineral Society 

Willamette Valley Grotto 

WOPR & Beyond Coalition 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Libraries, Schools, and Universities 

Ashland Public Library Forest Engineering Department 

Corvallis- Benton County Public Library Klamath Basin Research and Extension Center 

Dallas Public Library Library 

Douglas County Library System Rangeland Ecology and Management 

Eagle Point Public Library Rogue Community College 

Klamath County Library Ruch Public Library 

Lake County Library South Lane School District 4553 

Lewis and Clark College Southern Oregon University 

Lewis and Clark Law School: Boley Law Library Springfield Public Library 

University of Washington: Natural Sciences Library Thomas Creek Library 

Oregon State University University of Minnesota: Forestry Library 

Agricultural Program University of Notre Dame 

Columbia Basin Agricultural Research Center University of Oregon Library 

Department of Crop & Soil Science USDA National Agricultural Library 

Extension Service - Pendleton 

Media 

Argus Observer (Ontario) 

Eugene Weekly 

KLCC Radio (Eugene) 

News-Register (McMinnville) 

Individuals 

Sandra Ackley Dan and Theresa Bastian Robert and Connie Boronda 

John and Judy Ahmann James Batdorff Gert Borschowa 

Diane Albino Kevin and Heidi Bauer Lynn Bowers 

John Albisu Ted J Bauer Melvin E Boyles 

Ken and Jan Alexander Kenneth F Baumann N Bradley 

Nancy Ames Gus Beall P Bradley 

Dale Anderson 

Steve Anderson 

Mickey Bellman 

Jim Bender 

Thomas A Branciforte 

Christopher Bratt 

Terry and Candice Anderson Linda Bentz Peter A Bray 

Judith Ano 

S B Anpu 

Karl G Anuta 

Dick Artley 

Jerry Asher 

Stephen D Auerbach 

Peter Bergin 

Roy Beyer 

Joanne Bigman 

Rex Billingsley 

Kathleen Bishop 

K E Black 

Chris J and Lisa Brehmer 

Charles Bridges 

Katharine Brigham 

Jon and Jean Bright 

Alan Brooks 

D Brown 

James W Ayling 

Darrel Bagley 

James Baird 

Jack Baker 

Foy T Blackburn 

Larry Blank 

Wayne Blaylock 

David Bohn 

Jack Brown 

Marcia Brown 

Thom Bruce 

Lee Brumble 

Edwin Ball Sam Booher Paul and Christy Bryan 

Sterl and Ux Bare Fred Borngasser Kathy Buckles 

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Draft Environmental Impact Statement: Distribution List 

Carl E and Elaine Budlong 

Frank Buell 

Mimi Bulkley 

John Bullock 

Glen Bundy 

Ken and Bernie Burkholder 

Bruce M Burnett 

Kandy Burns 

Henry J Cadwell Jr 

Terry Cain 

David Calahan 

Meg Campbell 

B Cannady 

Jim Cant 

Jane Capizzi 

Randolph S Carey Jr 

George E Carlon 

Craig Carlton - Cederglen 

Jay B Carr 

Marvin and Edie Casey 

Donald Cavaletto 

Les Chapman 

Mel Chase 

Susan Chauncey 

Merry J Christiansen 

Christopher Christie 

Paul H Christman 

Jane Civiletti 

Barry Clock 

Grant Combs 

David Cook 

John W Cook 

Robert J Corbari 

Randy Cottrell 

Arthur Coulton 

Clayton M and Marilyn Couture 

William Cowan 

Patrick Craig 

Sandra and Stephen Cramer 

Harlan Crawford 

Dan and Laury Cron 

Monty Crum 

Barbara Cunningham 

Arleen Curths 

Wanda Custance 

Laura A Dahl 

Ken Dalton 

Dan Daltoso 

Ruth Danielsen 

Charles Davis 

Deniece Davis 

Leontyne Davis 

Mike Davis 

Robert B Davis 

Bruce Dawley 

Fred A Dayton Jr 

Dr Paul M Deauville 

Virginia and Don Debusk 

Art Decker 

Susanna DeFazio 

Gary and Marjorie Defenbaugh 

Ted E Deford 

John DeGroot 

Susan Delles 

Sam Dement 

Kenneth E Denton 

Dorothy Detsch 

Ed Dierling 

John B Dimick 

Shauna Dingus 

Mary P Dorroh 

Sage and Lynne Dorsey 

Patricia Downing 

Fred and Joy Doyle 

Malcolm Drake 

Randell Drake 

Ray Drayton 

Bernard G Duberow 

Agnes K Duncan 

David J Duncan 

Nancy Duran 

Keith Easterday 

Francis Eatherington 

Charles K Eckels Jr 

Burt and Linda Eikleberry 

Rob Ellington 

Lavon Elliott 

Maurice Ellsworth 

John Elzey 

Stephen Eraker 

Joann Ernst 

Mildred Eshelby 

Steve Everidge and Jeri Keatley 

Bruce Farmer 

Joan Faulkner 

James M Fenton 

Robert A Ferreira 

Jim Fety 

Jean Findley 

Richard Fleming 

Bryan Flora 

Ivan Forbes 

Michael Fornalski 

Greg and Rana Foster 

Rana Foster 

Mark Freeman 

P Freimuth 

Shirley Froyd 

George Fuller 

Richard G Furrer 

John and Robin Gage 

Dean Gaiser 

Scott Gall 

Dr John L Gardiner 

Teresa Gardner 

Cindy and Bruce Gates 

John Geddie 

Ed Gibson 

Wayne Giesy 

James R Gilbert 

Kent Gill 

Suzi and Bob Given 

Janet Glassberg 

Richard Goble 

Nabha Goldfeder 

Christine Golightly 

Daniel Gonzalez 

Ken Goodpaster 

Michael Graham 

Peter Graham 

Ron Greb 

Griffin Green 

Probyn Gregory 

Ron L Gregory 

George Grier 

Glen Griffith 

Tom Gritzka 

G R Grovt 

George R Gruning 

Robert Gunther 

Clifton Guyton 

H. Elizabeth Gwynn and Lynda 

Blumenthal 

Bob Hagerty 

Bill Hall 

Don Hamann 

Liz Hampton 

Susan and Edward Hanscom 

Bruce Hansen 

Anne Hanson 

Amy Harlib 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Barry Harper 

Eva Harris 

Dennis Harrison 

Steve Hart 

Tyrell Hart 

Cate Hartzell 

Mark and Tammy Hastings 

Richard Heaney 

Dick Hebert 

Morgan Heckman 

Dan H Heierman 

Delbert Heller 

Jerry Hendrickson 

Paul Henion 

Joe Henry 

P Sydney Herbert 

Hollis Herrell 

Gregory Hickey 

Don Higby 

Roxy Hiils 

Gretchen Hillard 

Duane Hinkley 

Tom Hoesly 

David Hoffman 

Mike and Connie Hoffstetter 

Jim Hogan 

Charles Holley 

Elvera Holtz 

Kathy Horn 

Harold Hotchkiss 

Charles G Hoyle 

Yvonne Hurst 

Loretta Huston 

George Ice 

Juliet P Imes 

Jim Ince 

Cheryl Ingersoll and Tyler Groo 

Charles E Ireland Jr 

Eric Jacobs 

William Jameson 

Carol Jaquet 

Leonard Jennsen 

Carol Jensen 

Douglas E Johnson 

Kenneth Johnson 

Paul S Johnson 

Helen Jones 

Scott Jones 

Maureen Joplin 

Anthony Joyce 

Tim Kaiser 

David Kaspar 

Charles J Keegan 

Michael Keerins 

James C Keesey 

Paul Keller 

Barbara Kelley 

Alex Kendrick 

Eldon Kent 

Al Kernagis 

Kammy Kern-Korot 

Greg Kimball 

Margaret Kimble 

Bob Kindschy 

Robert King 

Jeff Kipilman 

Monty Kizer 

Basey Klopp 

Rick L Klumph 

Loren G Knight 

John Koenig and Deborah Toobert 

Mike Konovalov 

Perry L Krieger 

Steve Kriegh 

James and Catherine Krois 

Mary Ann Kruse 

Eugene Kunze and Christine Denton 

John Kunze 

Amber Kurt 

John La Plante 

Gerard Labrecque 

Jim and Rochelle Lake 

Sylvia Lakey 

Dennis Lambert 

Barbara Lane 

Jonathan I Lange 

Pat Larson 

Russell and Gail Larson 

Terry Larson Sr. 

Darrell Leach 

Frank Lehram 

Sheila Lemons 

Jim Lemos 

Johnathan Lenann 

Patricia and Maciej Lesiecki 

Michael A Letendre 

Joe Levesqul 

Kathy Levy 

Bill Lewey 

Daniel H Lichtenwald 

Robert Lindsay 

Lori Linehan 

Gary Lisman 

Ronald and Claudia Little 

Olson Lloyd 

Phil Loe 

Geren and June Long 

Frank D Lospalluto 

Joseph T Low 

Jack Luce 

Louise Luce 

Cathy Lucero 

Bill Luckey 

Paul Luehrmann 

Debbie Lukas 

Sandra Lyon 

Jeff Mach 

Suzanna Mack 

Dr Eugene I Majerowicz 

Ray and Beverly Major 

Clifford Mann 

Ken Mantel 

Susan E Markley 

Albert Marra 

D D Mascall 

Charles and Christopher Mason 

James Mast 

Bill Mathison 

Liz Matteson 

Tara Mattis 

Randy Matzek 

Roger Maulding 

Darrell and Connie May 

David McAllister 

Tom McAllister 

Kevin McBirney 

Amy McCall 

Bert L McCormack 

C McCue 

Bonnie McDroe 

Mike and Victoria McKinney 

Jennifer McKinnis 

Richard McLead 

Fergus and Marion Mclean 

Phil Meglasson 

Michael S Meredith 

Edward M Merriman 

Warren Merz 

Jason Messerle 

Gary Messinger 

 400 
Draft Environmental Impact Statement: Distribution List 

Bill Meyer 

Diane Meyer 

Lee Meyer 

Cynthia Miani 

William Michel 

Dave Mickey 

David Mildrexler 

Bonnie Miller 

Gregory S Miller 

Hubert Miller 

Kenny C Miller 

Pat and Naida Miller 

Ron Miller 

Ronald W Miller 

Russell L Miller 

Sara Miller 

Anne Millhollen 

Don Minore 

Russ Minten 

Ed Miranda, Jr 

Albert Mitchell 

Anne Mitchell 

Bryce Mitchell 

J Mitchell 

Frederick Mittleman 

Mary Moffat 

Clifton K Molatore 

G L Monahan 

William Mondale 

David Monett 

Monty Montgomery 

Julia Mooney 

James F Moore 

Raymond J Morris 

Sharon Morris 

C A Morrison and Pamela 

Schrimps 

Chris Morstad 

Orval P Mose 

Douglass Moser 

Lola Moulton 

Kenneth B Mueller 

Dr Fraser J Muirhead 

Robert Mullong 

Daniel Murphy 

R E Myer 

Leo Naapi 

Richard Nauman 

Paul E Neal 

Jan Nelson 

Leon C Neuschwander 

Nancy Nichols 

Louise Nicholson 

Scott Nilholson 

Dave Noble 

Peter Norman 

Steven Novotny 

David B Now 

Tom Nygren 

Donald Oakes 

Gregg Oelker 

Conan Oharrow 

Doug Oien 

Jim Olney 

Regan Olson 

Ludwig Opfermann 

Lynn Ortwein 

Larry Orzechowski 

David Owen 

Michelle Owen 

Cheryl Owens 

Lawrence Pagen 

B Palmer 

George L Palmer 

Wallace N Parrish 

Paul and Kathy Patrick 

Craig Patterson 

Derek Patterson 

Frederick M Patton 

H D Patton Jr 

Warren H Paulat 

Grafton Pauls 

E T Paulus 

Wade R Peerman 

Michele Penner 

Barbara Pereina 

George and Mary Perez 

Laura Perrigan 

Gary D Peterson 

Leonard P and Ada Peterson 

William Pettit 

Glenda Phillips 

Stuart Phillips 

Bill Philp 

Darrell R Pieper 

Jonathan Pincus 

Dick Posekany 

Jim and Nancy Prince 

Ron Quant 

Joseph Patrick Quinn 

Paul D Quinn 

James Ragan 

Edward L Ramsay 

Roth and Cherri Randall 

Philip Ratcliff 

Ina Marie Raymond 

Russell Reade 

Gary Reeser 

Kathy Reid 

Kari Rein 

Ulrich Richard 

Len Richardson 

Richard W and Joan Rickard 

Virginia Ricketts 

Joe Rickner 

Kenneth Rieck 

Lyle Rilling 

Laura R Rini 

Denise Ripellino 

Scott Ritner 

Victor and Martha Robert 

Harold Robertson 

Richard Robinson and Dorthy 

Robinson-Foldes 

Robert Rock 

Nancy Roeder 

M Maggie Rogers 

Justin and Lisa Rohde 

Naomi Rowden 

Tim Rozewski 

Reed D Russell 

Anton and Donna Rustand 

Zola Ryan 

B Sachau 

Ron Sadler 

John Saemann 

Paul Safady 

Gerald Sagert 

J K Sandt 

P Saraceno 

Don Sargent 

Roger and Ellen Savage 

Kurt A and Kathryn Saylor 

Mike Schauther 

William Scheufele 

Earl Schlegel 

Kurt Schmidt 

Tom Schmidt 

Edward Schoor 

David Schorran 

Alan Schroeder 

401 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Carl H Schwarzenberg 

Larry Scofield 

Gordon Scott 

Henry Scott 

John and Delores Scott 

Lloyd Seely 

M L Sells 

Steve Sewell 

Jim Shake 

Lynn Sharp 

Kathleen M Shayler 

Roger Sheley 

Terry Sherman 

Robert Shimane 

Jack Shipley 

Ron Short 

J L Shultz 

Terry Simpson and Jayne Goodwin 

Charles Sliger 

Dennis R Smith 

Jack G Smith 

Judy Smith 

Larry Smith 

Robert Smith 

S K Smith 

Tony S Smith 

Walter Smith 

Paul Smoland 

Stuart Smythe 

John Snelling 

Sandra Soho 

Tanya Sommer 

Don Southern 

Frank Spiecker 

Vaughn Spiker 

Bobby Stafford 

John Stahl 

Heather Stein 

Steven Steinhauer 

Ted Stevens 

W Rex Stevens 

Joanne and Kenneth Stevenson 

John L Stoddart 

Kindler Stout 

Sally Streeter 

Don Stroeber 

Ed Styskel 

Debra Sullivan 

John Sundquist 

Pete Swensen 

Al Swisher 

Charles C Tandy 

George and Rebecca Taylor 

Lois Taylor 

Judith A Templeton 

Karen Theodure 

Robert Thies 

Harley D Thom 

Ambers Thornburgh 

Marlene Thorp 

Gilbert J Ticoulat 

Ruth Tiger 

Paul Tipton 

Avery Gary Tittle 

Debby Todd 

Viggo Toftemark 

Billy and Dora Toman 

Doris and Norm Tonseth 

John R Townes 

Rudy Trevino 

Vicki Tripoli 

John Turner 

David Tvedt 

Dee Tvedt 

Larry Ulrich 

Gary Van Cleef 

Jan Van Dusen 

Charles Van Lear 

Roberta Vandehey 

Suzanne Vandeneynde 

Floyd Vandervelden 

Cathy Verret 

Fern L Vikerts 

Chuck Volz 

Lauria Wadsworth 

David H Wagner 

James Wagner 

John and Janet Walker 

Michael Walker 

Thomas Walker 

James J Walters 

Anita and John Ward 

Tom Ward 

Thomas Ware 

T D Warrick 

Linda Watts 

Della Webb 

R Weeks and G Griggs 

Clint and Cathy Wentz 

Gerald West 

Frank G White 

Robert White 

John Whitehead 

Benjamin Whitney 

Susan Whitney-Kurtz 

H Wick 

Ken Wienke 

Carol Wilcox 

David and Kathy Wilder 

Glenna Wilder 

George Wilkinson 

James Wilkinson 

Bruce D and Christine Williams 

Matt Williams 

Mitch Williams 

Robert J Williams 

Mike Wills 

Brian Wilson 

Carol L Wilson 

Mouna Wilson 

Edward Winter 

Jay and Mary Ann Wisman 

Jane and George Withers 

Donald and Deborah Withrow 

Laurie Woodard 

Corry Wright 

L K Wright 

Rick Yaw and Diane Orrell 

Jack Young 

Berta Youtie 

Jackie Yow 

Richard Zentzis 

George Ziermann 

Gloria Ziller 

 402 
 

 

Draft 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), 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 EIS team 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 

Dear Reader Letter 

a. Title Page - Abstract 

b. Executive Summary 

c. Table of Contents 

d. 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 

e. 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 

f. List of Acronyms 

g. Programmatic Report Covers 

403 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Programmatic EIS Vol . 2 

Programmatic EIS Cover Pages and Table of Contents (TOC) 

i. Vol. 2 Title Page 

ii. Vol. 2 TOC 

a. 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 

b. 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 

d. Vol. 3 Programmatic EIS Report Covers 

Final Biological Assessment 

a. Biological Assessment 

b. Final BA Report Cover 

c. Map 

 404 
Draft Environmental Impact Statement: Appendix 2 

Appendix 2 - Standard Operating 

Procedures and Mitigation Measures 

from the PEIS 

Introduction 

The following Standard Operating Procedures (SOPs) and Mitigation Measures (MM) have been adopted from 

the Record of Decision for the PEIS. Minor edits have been made to some SOPs and MMs to clarify intent. BLM 

field offices would tailor these SOPs and MMs based on local conditions and the habitat needs of the particular 

threatened and endangered species that could be affected by the treatments (PEIS ROD Appendix C:22). 

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. The list is not all encompassing, but 

is designed to give an overview of practices that should 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 SOPs, 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 SOP 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 Ecological Risk Assessments (ERA) Worksheets (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. 

Although not displayed here, SOPs 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; USDI 1992c); and manuals 1112 (Safety; USDI 2000), 9011 

(Chemical Pest Control), 9012 (Expenditure of Rangeland Insect Pest Control Funds), 9015 (Integrated Weed 

Management; USDI 2008f), and 9220 (Integrated Pest Management; USDI 1981). (SOP) 

405 
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 seeds. (SOP) 

 406 
Draft Environmental Impact Statement: Appendix 2 

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

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) 

407 
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 criteria to minimize impacts to water bodies. (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 USEPA 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) 

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) 

 408 
 

 

 

Draft Environmental Impact Statement: Appendix 2 

•		 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. (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) 

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. (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) 

409 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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. (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 1) (MM) 

Threatened, Endangered, and Sensitive Species 

See Manual 6840 (Special Status Species) 

•		 Provide clearances for special status species before treating an area as required by ISSSSP 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) 

 410 
Draft Environmental Impact Statement: Appendix 2 

•		 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) 

•		 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) 

411 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

•		 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 shortterm 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)
 

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 stray 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)
 

 412 
Draft Environmental Impact Statement: Appendix 2 

•		 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 

ground-based 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) 

•		 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) 

413 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

•		 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. 

•		 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) 

 414 
 

 

Draft Environmental Impact Statement: Appendix 2 

TABLE a2-1. bUffer disTances To minimize risk To vegeTaTion from off-siTe drifT of 

blm-evalUaTed Herbicides 

Application 

Scenario BROM1 CHLR1 DICM1 DIFLU1 DIQT1 DIUR1 FLUR1 IMAZ1 OVER1 SULF1 TEBU1 

Buffer Distance (feet) from Non-target Aquatic Plants 

Typical Application Rate 

Aerial 

Low Boom2 

High Boom2 

NA 

100 

900 

0 

0 

0 

NA 

0 

0 

NA 

100 

900 

NE 

NE 

NE 

NA 

900 

1,000 

NE 

NE 

NE 

0 

0 

0 

NA 

100 

900 

1,300 

900 

900 

NE 

0 

0 

Maximum Application Rate 

Aerial 

Low Boom2 

High Boom2 

NA 

900 

900 

300 

0 

0 

NA 

0 

0 

NA 

900 

900 

NE 

NE 

NE 

NA 

1,000 

1,000 

NE 

NE 

NE 

300 

0 

0 

NA 

900 

900 

1,500 

900 

900 

NE 

0 

0 

Buffer Distance (feet) from Non-target Terrestrial Plants 

Typical Application Rate 

Aerial 

Low Boom2 

High Boom2 

NA 

950 

950 

1,350 

900 

900 

NA 

1,000 

1,000 

NA 

100 

100 

1,200 

100 

900 

NA 

0 

100 

NE 

NE 

NE 

0 

0 

0 

NA 

0 

100 

0 

0 

0 

NE 

0 

0 

Maximum Application Rate 

Aerial 

Low Boom2 

High Boom2 

NA 

1,000 

1,000 

1,350 

1,000 

1,000 

NA 

1,050 

1,050 

NA 

100 

100 

1,200 

900 

900 

NA 

200 

500 

NE 

NE 

NE 

900 

0 

0 

NA 

100 

100 

0 

0 

0 

NE 

50 

50 

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

Typical Application Rate 

Aerial 

Low Boom2 

High Boom2 

NA 

1,200 

1,200 

1,400 

1,000 

1,000 

NA 

1,050 

1,050 

NA 

100 

900 

1,200 

900 

900 

NA 

1,000 

1,000 

NE 

NE 

NE 

0 

0 

0 

NA 

100 

900 

1,500 

1,100 

1,000 

NE 

0 

50 

Maximum Application Rate 

Aerial 

Low Boom2 

High Boom2 

NA 

1,200 

1,200 

1,400 

1,050 

1,000 

NA 

1,050 

1,050 

NA 

900 

900 

1,200 

1,000 

1,000 

NA 

1,000 

1,000 

NE 

NE 

NE 

900 

0 

0 

NA 

900 

900 

1,500 

1,100 

1,000 

NE 

100 

500 

1 BROM = Bromacil; CHLR = Chlorsulfuron; DICM = Dicamba; DIFLU = Diflufenzopyr; DIQT = Diquat; DIUR = Diuron; FLUR = Fluridone; IMAZ = 

Imazapic; OVER = 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.
 

415 
 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Table a2-2. bUffer disTances To minimize risk To vegeTaTion from off-siTe drifT of foresT 

service-evalUaTed Herbicides 

Application 

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

Buffer Distance (feet) from Susceptible Plants1 

Typical Application Rate 

Aerial 

Low Boom 

NE 

NE 

900 

900 

300 

50 

300 

NE 

900 

900 

900 

900 

>900 

>900 

500 

300 

Maximum Application Rate 

Aerial 

Low Boom 

NE 

NE 

1,000 

1,000 

300 

300 

900 

NE 

>900 

>900 

>900 

>900 

>900 

>900 

>900 

>900 

Buffer Distance (feet) from Tolerant Terrestrial Plants 

Typical Application Rate 

Aerial 

Low Boom 

NE 

NE 

0 

0 

25 

25 

NE 

0 

100 

25 

50 

25 

25 

25 

NE 

NE 

Maximum Application Rate 

Aerial 

Low Boom 

NE 

NE 

25 

25 

50 

25 

NE 

100 

300 

50 

100 

25 

50 

25 

NE 

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
 

Table a2-3. bUffer disTances To minimize risk To non sPecial sTaTUs fisH and aqUaTic inverTebraTes 

from off-siTe drifT of blm-evalUaTed Herbicides from broadcasT and aerial TreaTmenTs 

Application 

Scenario BROM1 CHLR DICA DIFLU 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 NA NA 0 NA 0 NA 

Low boom 0 0 0 0 NA 0 NA 0 0 0 0 

High boom 0 0 0 0 NA 0 NA 0 0 0 0 

Maximum Application Rate 

Aerial NA 0 NA NA NA NA NA 0 NA 0 NA 

Low boom 0 0 0 0 NA 100 NA 0 0 0 0 

High boom 0 0 0 0 NA 100 NA 0 0 0 0 

1 BROM = Bromacil; CHLR = Chlorsulfuron; DICA = Dicamba; DIFLU = Diflufenzopyr; DIQT = Diquat; DIUR = Diuron; FLUR = Fluridone; IMAZ = 

Imazapic; OVER = 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. 

 416 
 

 

 

Draft Environmental Impact Statement: Appendix 2 

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 DICA DIFLU 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 NA NA 0 NA 0 NA 

Low boom 0 0 0 0 NA 0 NA 0 0 0 0 

High boom 0 0 0 0 NA 100 NA 0 0 0 0 

Maximum Application Rate 

Aerial NA 0 NA NA NA NA NA 0 NA 0 NA 

Low boom 0 0 0 0 NA 100 NA 0 0 0 0 

High boom 0 0 0 0 NA 900 NA 0 0 0 0 

1 BROM = Bromacil; CHLR = Chlorsulfuron; DICA = Dicamba; DIFLU = Diflufenzopyr; DIQT = Diquat; DIUR = Diuron; FLUR = Fluridone; IMAZ = 

Imazapic; OVER = 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. 

417 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

418
 
Draft Environmental Impact Statement: Appendix 3 

Appendix 3 – Monitoring 

Introduction 

Existing Monitoring 

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 (RMP), 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-three years. Examples include seedling survival exams, and follow-up monitoring of invasive 

plant populations. Evaluations of the appropriateness and effectiveness of the overall RMP direction are done 

periodically, usually every five years, to determine if RMP direction is meeting overall goals. 

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

the RMPs. 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. 

Potential Monitoring 

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 the use of “new” herbicides about 

which weed specialists are not as familiar. Part II of this appendix lists treatment 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 sitespecific NEPA. 

419 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 regulations of 43 Code of Federal Regulations (CFR) 1610 .4-9 require that 

land use plans establish 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 then completed within twenty four hours. 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. 

 420 
Draft Environmental Impact Statement: Appendix 3 

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 (PEIS ROD 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 

associated with the project may be accomplished by: reviewing the Pesticide Application Records (PAR) 

completed at the time of treatment; comparing the PAR 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 SOPs and mitigation measures are taken into account. Review of the PARs can determine whether 

actual application was consistent with plans and requirements documented in the site-specific NEPA decision or 

Pesticide Use Proposal. Pesticide Application Records are used to develop annual state summaries of herbicide 

use for BLM (PEIS ROD 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 (PEIS ROD App. D). 

Adaptive management strategies require implementation monitoring to determine whether we followed the 

plan and obtained the expected results. Monitoring also ensures that vegetation treatment SOPs and mitigation 

measures are adopted and implemented appropriately and determined to be effective (PEIS ROD: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 

421 
 

 

 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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? (PEIS 

ROD App D) 

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, would be 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 1992c:Chapter 2. IV. B). 

There might also be a need to determine if the standards and protection 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. 

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” 

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Draft Environmental Impact Statement: Appendix 3 

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. 

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. 

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 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, some number (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 SOPs 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 RAC, County Weed Board, County Board of Supervisors, or ODA Invasive Plant or Pesticide 

Enforcement Division, and; a line officer or District Weed Coordinator or State Office Restoration Program lead 

from a different district or the State Office. 

Monitoring Specific Concerns Identified in the EIS 

The above random sample project monitoring does 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 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 1992c), in Chapter 1. I. E, 

Chemical Residue Monitoring, for when toxic materials are introduced near sensitive areas such as residences or 

domestic water supplies. Suggested monitoring points include air, vegetation, soil, and water. Although existing 

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

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Draft 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 non-commodity vegetation 

management programs. These herbicides were analyzed in the 2007 PEIS and approved for use in the 17 western 

states by the 2007 Record of Decision (ROD).1 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 ROD 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 by themselves. However, the BLM in Oregon may help identify future herbicide active 

ingredients needed, and propose them to the National Office under this protocol. 

The national 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 Washington Office, requires that the herbicide active 

ingredient have completed USEPA FIFRA registration and be labeled for use on the site type proposed, and 

requires National Environmental Policy Act (NEPA) compliance. The BLM Washington Office would take the 

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

Summary of 2007 ROD Appendix A – Protocol for Identifying, 

Evaluating, and Using New Herbicides 

The U.S. Department of the Interior Bureau of Land Management (USDI 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 

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. 

1 As described in Chapter 1, this EIS is being prepared in spite of the 2007 decision for 17 western states, in order to 

separately address a 1984/87 Oregon-specific court injunction, and to address the potentially significant change in the 

Oregon program of going from 4 to as many as 18 herbicides. 

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Bureau of Land Management 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 Washington Office after an initial 

evaluation of U.S. EPA Federal Insecticide, Fungicide and Rodenticide Act (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 National 

Environmental Policy Act (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 Washington 

D.C. office with annual statewide pesticide use reports. Proposed herbicide active ingredients must already have 

a completed USEPA FIFRA registration in place, and be labeled for use on the site proposed (e.g. rangeland, 

pasture, non-cropland, 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. 

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Draft Environmental Impact Statement: Appendix 4 

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 office in Washington D.C. 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 Code of Federal Regulations [CFR] 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 USEPA-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 USEPA’s peer review process (USEPA 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. 

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 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 exclusions2

 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 EA and Finding of No Significant Impact (FONSI) for such approval. This is not to say 

a particular project involving the use of herbicides could not be assessed with an EA 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 CFR 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 CFR 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 USFWS and NMFS as required 

under Section 7 of the ESA. 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 (BA) 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. 

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. 

2 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 CFR 1508.4). 

428 
 

 

 

Draft Environmental Impact Statement: Appendix 5 

Appendix 5 – Endangered, Threatened, 

and Bureau Sensitive Species 

This appendix addresses Federally-Listed and other Bureau Sensitive species. 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. Oregon-specific information about the effects of the alternatives is 

presented in Chapter 4. 

Table of Contents 

Summary of the Action Alternatives...................................................................................................................... 429
 

Summary of Applicable Standard Operating Procedures and Mitigation Measures ............................................. 430
 

Endangered and Threatened Species in Oregon .................................................................................................... 431
 

Birds.......................................................................................................................................................... 431
 

Fish............................................................................................................................................................ 436
 

Invertebrates.............................................................................................................................................. 449
 

Mammals .................................................................................................................................................. 452
 

Vascular Plants.......................................................................................................................................... 456 

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

Endangered, or Proposed, Oregon January 2008................................................................................................... 470 

Table A5-2. State Director’s Special Status Species List, January 2008, Oregon BLM ...................................... 472 

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 non-commodity 

vegetation management program. Action Alternatives 3 and 4 in the Oregon EIS are subsets of that alternative, 

using fewer herbicides and restricting their use to particular plants of management objectives as described below. 

Alternative 5 would essentially adopt the selected PEIS alternative. (Alternative 1 is also an action alternative, 

but it proposes no use of herbicides.) 

The PEIS is the Final Vegetation Management Using Herbicides on Bureau of Land Management Lands in 17 Western 

States Programmatic Environmental Impact Statement, June 2007. 

429 

1 
 

 

 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 ESA, and that there will be 

compliance with all Federal laws during implementation of the project. Since the PEIS is programmatic in nature, it 

does not authorize a specific commitment of resources. Therefore, any proposed site-specific 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 7 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 

quarantine areas. 

Alternative 4, the proposed action, would add 8 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 Plans or Conservation Agreements. 

Alternative 5 would add 14 herbicides to the 4 already being used, and make them available for any non-commodity 

vegetation management treatment. 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 one action 

alternative that would cease the use of herbicides completely (Alternative 1) is in Chapter 2. 

Summary of Applicable Standard Operating Procedures and PEIS Mitigation 

Measures 

Standard operating procedures (SOPs) 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. SOPs 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 should 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 SOPS or that a site-specific determination is made that their application is 

unnecessary to achieve their intended purpose or protection. As with the corresponding protective measures listed 

in the Biological Opinion, BLM field offices would tailor these national [SOPs] 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 p. 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 SOPs. Like the SOPs, application of the mitigation measures is assumed in the analysis. However, for 

PEIS mitigation measures, site-specific analysis, the use of ERA Worksheets, or the evolution of these measures 

into similar handbood direction is permitted to identify alternative ways to achieve the expected protections. 

 430 
 

 

Draft Environmental Impact Statement: Appendix 5 

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 ESA (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 SOPs and PEIS Mitigation 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-specific 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 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 take2

 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 

four action alternatives in this EIS are the same as, or 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 species in Oregon and a list of the Bureau Sensitive species in Oregon are included in Appendix 

5. Informal consultation with the FWS (50 CFR 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. 

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 

2 ‘‘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 

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. 

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. 

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 

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Draft Environmental Impact Statement: Appendix 5 

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 

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 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

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 

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Draft Environmental Impact Statement: Appendix 5 

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. 

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. 

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 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

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). 

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). 

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Draft Environmental Impact Statement: Appendix 5 

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. 

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 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

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 

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Draft Environmental Impact Statement: Appendix 5 

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 

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, 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

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). 

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Draft Environmental Impact Statement: Appendix 5 

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 

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. 

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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 

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. 

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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). 

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). 

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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. 

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. 

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Draft Environmental Impact Statement: Appendix 5 

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 

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 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

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 

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Draft Environmental Impact Statement: Appendix 5 

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). Like other dace populations, it is likely that the 

Foskett speckled dace requires some kind of hard substrate for egg deposition (Moyle 1976). 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, 

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 reference for this section is: USFWS. 1999h. Determination of Threatened Status for Bull Trout 

in the Coterminous United States Final Rule. Federal Register 64(210):58909-58933. 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 Field Office, Boise, Idaho. 

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 southcentral 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 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

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. 

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Draft Environmental Impact Statement: Appendix 5 

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. 

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 

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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. 

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. 

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Draft Environmental Impact Statement: Appendix 5 

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. 

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 

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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. 

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 

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 

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Draft Environmental Impact Statement: Appendix 5 

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. 

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 

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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. 

The Columbian white-tailed deer was Federally Listed as endangered on March 11, 1967. On May 11, 1999, the 

USFWS proposed to delist the Douglas County subpopulation. 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. 

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, 

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Draft Environmental Impact Statement: Appendix 5 

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. 

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). 

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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 

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. 

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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 

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. 

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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 

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 

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Draft Environmental Impact Statement: Appendix 5 

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. 

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. 

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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 

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). 

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Draft Environmental Impact Statement: Appendix 5 

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 

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. 

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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 

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 

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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. 

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 

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. 

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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. 

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 

 464 
Draft Environmental Impact Statement: Appendix 5 

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. 

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. 

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Vegetation Treatments Using Herbicides on BLM Lands in 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 

(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. 

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Draft Environmental Impact Statement: Appendix 5 

Also, 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. 

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. 

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. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

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. 

 468 
Draft Environmental Impact Statement: Appendix 5 

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). 

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 

469 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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. 

Table a5-1. sTaTe direcTor’s sPecial sTaTUs sPecies lisT – federally THreaTened, endangered, or 

ProPosed, oregon janUary 2008 

Scientific Name Common Name Listed Critical Habitat Recovery Plan 

Birds 

Endangered 

Pelecanus occidentalis 

californicus 

California brown pelican 1970 None Final 1983 

Threatened 

Brachyramphus marmoratus Marbled murrelet 1992 Designated 1996 Final 1997 

Charadrius alexandrinus nivosus Western snowy plover 

(Pacific Coastal population) 

1993 Designated 2005 Final 2007 

Strix occidentalis caurina Northern spotted owl 1990 Designated 1992 Draft 2007 

Fish 

Endangered 

Catostomus microps Modoc sucker 1985 Designated 1985 None 

Chasmistes brevirostris Shortnose sucker 1988 Proposed 1994 Final 1993 

Deltistes luxatus Lost river sucker 1988 Proposed 1994 Final 1993 

Gila boraxobius Borax lake chub 1980 Final 1982 Final 1987 

Oncorhynchus 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 1998 

Gila bicolor ssp. Hutton tui chub 1985 None Final 1998 

Oncorhynchus clarki henshawi Lahontan cutthroat trout 1970 None Final 1995 

Oncorhynchus kisutch Coho 

salmon 

(Lower Columbia River) 2005 None None 

(Northern CA / Southern Oregon 

Coast) 

1997 Designated 1999 None 

 470 
Draft Environmental Impact Statement: Appendix 5 

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 1998 

Salvelinus 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 

Invertebrates 

Endangered 

Plebejus icarioides fenderi Fender’s blue butterfly 2000 Proposed 2005 None 

Threatened 

Branchinecta lynchi Vernal pool fairy shrimp 1994 Designated 2003 Final 2005 

Speyeria zerene hippolyta Oregon silverspot butterfly 1980 Designated 1980 Final 2001 

Mammals 

Endangered 

Canis lupus Gray wolf 2003 None in OR or 

WA 

Final 1987 

Odocoileus virginianus leucurus Columbian white-tailed deer 

(Columbia River population) 

1967 None Final 1983 

Threatened 

Lynx canadensis Canada lynx 2000 Designated 2006 None 

Vascular Plants 

Endangered 

Arabis macdonaldiana Macdonald’s rock-cress 1978 None Final 1984 

Arenaria paludicola Marsh sandwort 1993 None Final 1998 

Astragalus applegatei Applegate’s milk-vetch 1993 None Final 1998 

Erigeron decumbens var. 

decumbens 

Willamette valley daisy 2000 Proposed 2005 None 

Fritillaria gentneri Gentner’s fritillary 1999 None Final 2003 

Lilium occidentale Western lily 1994 None Final 1998 

Limnanthes floccosa ssp. 

grandiflora 

Large-flowered wooly meadowfoam 2002 None Draft 2006 

Lomatium bradshawii Bradshaw’s desertparsley 1988 None Final 1993 

Lomatium cookii Cook’s lomatium 2002 None Draft 2006 

Plagiobothrys hirtus Rough popcorn flower 2001 None Final 2003 

Stephanomeria malheurensis Malheur wire-lettuce 1982 Final 1982 Final 1991 

Threatened 

Castilleja levisecta Golden paintbrush 1997 None Final 2000 

Howellia aquatilis Water howellia 1994 None Draft 1996 

Lupinus sulphureus ssp. kincaidii Kincaid’s lupine 2000 Designated 2006 None 

Mirabilis macfarlanei Macfarlane’s four o’clock 1979 None Final 2000 

Sidalcea nelsoniana Nelson’s checkermallow 1993 None Final 1998 

Silene spaldingii Spalding’s catchfly 2001 None Final 2007 

Thelypodium howellii ssp. 

spectabilis 

Howell’s spectacular thelypody 1999 None Final 2002 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Table a5-2. sTaTe direcTor’s sPecial sTaTUs sPecies lisT, 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 

 472 
Draft 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 

473 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

 474 
Draft 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 

Botrychium paradoxum Twin-spiked moonwart 

475 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

Carex vernacula Native sedge 

 476 
Draft Environmental Impact Statement: Appendix 5 

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 

Erigeron oreganus Oregon daisy 

477 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

Lathyrus holochlorus Thin-leaved peavine 

 478 
Draft Environmental Impact Statement: Appendix 5 

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 

Penstemon peckii Peck’s penstemon 

479 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

Sidalcea malviflora ssp. patula Coast checker bloom 

 480 
Draft Environmental Impact Statement: Appendix 5 

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 

Herbertus aduncus Liverwort 

481 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

Phaeocollybia californica 

 482 
Draft Environmental Impact Statement: Appendix 5 

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 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

484
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Draft 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. 

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. 

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. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 Centaurea jacea x nigra
 

tansy ragwort Senecio jacobaeae
 

Canada thistle Cirsium arvense 

St.-Johns-wort Hypericum perforatum
 

Scotch broom Cytisus scoparius
 

French broom Cytisus monspessulanus
 

gorse Ulex europaeus
 

diffuse knapweed Centaurea diffusa
 

spotted knapweed Centaurea maculosa
 

purple loosestrite Lythrum salicaria
 

puncture vine Tribulus terrestris
 

bull thistle Cirsium vulgare
 

distaff thistle Carthamus lanatus
 

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 

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.
 

 486 
Draft Environmental Impact Statement: Appendix 6 

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. 

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. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 Scientific Name 

Rush skeleton weed Chondrilla juncea 

Tansy ragwort Senecio jacobaea 

Yellow star thistle Centaurea solstitialis 

Scotch broom Cytisus scoparius 

Puncturevine Tribulus terrestiris 

Canada thistle Cirsium arvense 

Leafy spurge Euphorbia esula 

Diffuse knapweed Centaurea diffusa 

Purple loosestrife 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. 

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. 

 488 
Draft Environmental Impact Statement: Appendix 6 

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 Scientific Name
	

Purple loosestrife Lythrum salicaria
 

Gorse Ulex europaeus
 

Scotch broom Cytisus scoparius
 

French broom Genista monospessulana
 

Yellow starthistle Centaurea solstitalis
 

Tansy ragwort Senecio jacobaea
 

Maltgrass Nardus stricta
 

Thistles 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. 

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. 

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Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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. 

 490 
Draft 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? 

 492 
Draft 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. 

 494 
Draft 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. 

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 

495 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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. 

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 

 496 
Draft Environmental Impact Statement: Appendix 6 

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. 

•		 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). 497 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

•		 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. 

•		 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. 

 498 
 

 

 

 

 

 

 

 

 

Draft Environmental Impact Statement: Appendix 6 

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. 

499 
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. 

 500 
Draft Environmental Impact Statement: Appendix 6 

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). 

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. 

501 
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. 

 502 
Draft Environmental Impact Statement: Appendix 6 

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. 

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. 

503 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 

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. 

 504 
Draft Environmental Impact Statement: Appendix 6 

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. 

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 

505 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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. 

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. 

 506 
Draft Environmental Impact Statement: Appendix 6 

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). 

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 

507 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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. 

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 na­

 508 
 

 

 

 

 

 

 

Draft Environmental Impact Statement: Appendix 6 

tive 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 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, re509 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

duce 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. 

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. 

 510 
 

 

 

 

Draft Environmental Impact Statement: Appendix 6 

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). 

511 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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. 

 512 
Draft Environmental Impact Statement: Appendix 6 

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. 

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. 

513 
figUre a6-1. resoUrce managemenT Plan areas

figUre a6-1. resoUrce managemenT Plan areas 

514
 
 

 

Draft Environmental Impact Statement: Appendix 7 

Appendix 7 – Additional Information 

about Noxious Weeds and Other 

Invasive Plants 

Table of Contents
 

Oregon State Noxious Weed List........................................................................................................................... 515
 

Common and Scientific Plant Names .................................................................................................................... 518
 

Noxious Weed Spread Rate References and Calculations ..................................................................................... 524
 

Additional Information about the Ecological Damage Caused by Invasive Plants............................................... 528
 

Oregon State Noxious Weed List 

Table a7-1. oregon noxioUs Weeds: abUndance and alTernaTive WHere effecTive conTrol becomes 

available - jUly 2009 

Alternative where 

effective control is 

available1 Common Name 

Noxious State 

List 

Abundance 

Category2 

Number of OR counties where weed 

is abundant 

has limited 

distribution 

is not known 

to occur 

13 Starthistle, Iberian A A 0 1 36 

13 

Thistle, Taurian or bull 

cottonthistle A A 0 1 36 

13 Thistle, Plumeless A A 0 2 35 

13 Thistle, Wooly distaff A A 0 3 34 

13 Yellow floating heart A A 0 3 34 

13 Starthistle, Purple A A 0 1 26 

13 Thistle, Smooth distaff A N 0 0 37 

13 Lepyrodiclis A N 

13 Policemans helmet B A 0 6 31 

13 Dyers woad B A 0 9 28 

13 Velvetleaf B A 0 11 26 

13 Thistle, Scotch B A 15 4 18 

13 Teasel, cutleaf B B 0 2 35 

13 Broom, Portugese B B 1 1 35 

13 Halogeton B B 1 2 33 

13 Cocklebur, spiny B B 1 10 26 

13 Thistle, Slender flowered B B 5 6 26 

13 Buffalobur B B 0 15 22 

13 Spanish heath B C 3 3 31 

13 Broom, French B C 2 5 30 

13 Ragweed B C 3 7 27 

13 Thistle, Italian B C 3 6 27 

13 

Jubata grass (Purple Pampas 

grass) B C 2 9 26 

13 Mediterranean sage B C 2 9 26 

13 Thistle, Musk B C 4 10 23 

13 Spurge laurel B C 3 12 22 

515 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Alternative where 

effective control is 

available1 Common Name 

Noxious State 

List 

Abundance 

Category2 

Number of OR counties where weed 

is abundant 

has limited 

distribution 

is not known 

to occur 

13 Thistle, Milk B C 11 5 21 

13 Houndstongue B C 9 10 18 

13 Puncturevine B C 18 9 10 

13 English Ivy B D 19 0 18 

13 Tansy ragwort B D 21 11 5 

13 Knapweed, Diffuse B D 12 21 4 

13 Thistle, Bull B D 37 0 0 

13 Starthistle, Yellow B E 12 14 11 

13 Broom, Scotch B E 21 10 6 

13 Flowering rush B E 37 0 0 

13 Geranium, Herb Robert B 

13 Geranium, Shiny leaf B 

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 

2 Matgrass A A 0 1 36 

2 Spurge, Myrtle A A 0 1 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 0 1 36 

2 Common reed A 

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 

 516 
 

 

Draft Environmental Impact Statement: Appendix 7 

Alternative where 

effective control is 

available1 Common Name 

Noxious State 

List 

Abundance 

Category2 

Number of OR counties where weed 

is abundant 

has limited 

distribution 

is not known 

to occur 

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 

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 Wild proso millet 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 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 

None Small broomrape B A 0 7 30 

None Dodder B C 13 12 12 

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 Alternative 1 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. 

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 Effective on small or new infestations – Manual/mechanical methods kill plants. Not feasible on larger or more established infestations. 

517 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Common and Scientific Plant Names 

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 

 518 
Draft Environmental Impact Statement: Appendix 7 

Common Name Scientific Name Duration1 

Growth 

Form Family Vegetation Type 

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 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 

519 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Common Name Scientific Name Duration1 

Growth 

Form Family Vegetation Type 

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 

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 Noxious Weed 

 520 
Draft Environmental Impact Statement: Appendix 7 

Common Name Scientific Name Duration1 

Growth 

Form Family Vegetation Type 

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 caputmedusae 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 

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 

521 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Common Name Scientific Name Duration1 

Growth 

Form Family Vegetation Type 

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 

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 

 522 
 

Draft Environmental Impact Statement: Appendix 7 

Common Name Scientific Name Duration1 

Growth 

Form Family Vegetation Type 

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 

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 Noxious Weed 

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 

1 A = Annual B = Biennial P = Perennial 

523 
 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 Dewy 2005, 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 1999b). 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. 

•		 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 mid1800s 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 get rolling 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. 

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. 

 524 

1 
 

 

Draft Environmental Impact Statement: Appendix 7 

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; 

certain windborne species don’t travel well on steeper more vegetated areas; and so forth. Using the high end of 

the FS’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 A7-3, 4, and 5 below. 

The BLM Western Oregon Plan Revision (WOPR) FEIS (USDI 2008a) 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 amount to as much as 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 (See discussion in the Noxious Weeds and Other Invasive Plants section of 

Chapter 4. Gross treatment acres are from DEIS Table 3-4.) 

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 

1 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 

525 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

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 7-2). 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 S growth curve, 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 7-3). 

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 

Alternative 1 Spread Rate 

The decrease in effective treatments under Alternative 1 when compared to No Action Alternative 2 is 14,670 

acres. Implementation of Alternative 1 is predicted to 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 7-4). 

The weed spread rate under Alternative 1 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. 

 526 
 

 

 

 

 

Draft Environmental Impact Statement: Appendix 7 

Table a7-5. Weed sPread of 12% increased by 10 Times THe 14,670 acres less effecTive annUal 

conTrol (difference beTWeen alTs 2 and 1, 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 

Alternative 1 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 7-5). 

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 

527 
 

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: 

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) 

 528 
 

 

 

Draft 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). 

529 
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. 1997b). 

 530 
Draft 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) 

531 
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 

1998) 

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 in Oregon and Idaho. 

 532 
 

 

 

 

 

 

Draft 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 DEIS is: 6. Prevent herbicide control treatments from having 

unacceptable adverse effects to applicators and the public, to desirable flora and fauna, and to soil 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 EIS Team. 

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 

1 An ecological entity such as a human, fish, plant, or slug. 

533 
 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

exorbitant. To the degree a toxic substance is known to pose a significant human or ecological risk, the BLM has 

undertaken analysis to assess its impacts through risk assessments. 

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. The Courts have 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. Risk assessment worksheets have been, or are being, developed for each herbicide, 

to assist field managers in translating risks to project design parameters. The use of those worksheets is explained 

in Chapter 3, Use of ERA Worksheets 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 accesses at the above website as well. 

 534 
 

 

 

 

Draft 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) 

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 

Bromacil x x x x x x x 

Chlorsulfuron x x x x x x x 

Clopyralid x 

Dicamba 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 

Hexazinone x 

Imazapic x x x x x x x x x x x x 

Imazapyr x 

Metsulfuron methyl x 

Overdrive x x x x x 

Diflufenzopyr x x x x x x x x x x x x 

Picloram x 

Sulfometuron methyl x x x x x x x x x x x x 

Tebuthiuron x x x x x x 

Triclopyr 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 

535 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

536
 
 

 

Draft Environmental Impact Statement: Appendix 9 

Appendix 9 – Additional Information 

About the 18 Herbicides 

Table A9-1 shows herbicide trade names that could be approved (depending on the alternative selected) for use on 

BLM lands in Oregon in 2009. 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 A9-2 shows which herbicides are recommended for what species. 

Table a9-1. Herbicide formUlaTions aPProved for Use on blm lands naTionally as of 2009 

Active Ingredient Trade Name Manufacturer EPA Reg . Number 

Bromacil Hyvar X DuPont 352-287 

Bromacil Hyvar XL DuPont 352-346 

Bromacil + Diuron Kroval I DF DuPont 352-505 

Bromacil + Diuron Weed Blast Res. Weed Cont. Loveland Products Inc. 34704-576 

Bromacil + Diuron DiBro 2+2 Nufarm Americas Inc. 228-227 

Bromacil + Diuron DiBro 4+2 Nufarm Americas Inc. 228-386 

Bromacil + Diuron Weed Blast 4G SSI Maxim 34913-19 

Chlorsulfuron Telar DF DuPont 352-522 

Chlorsulfuron Telar XP DuPont 352-654 

Clopyralid Spur Albaugh, Inc. 42750-89 

Clopyralid Pyramid R&P Albaugh, Inc. 42750-94 

Clopyralid Clopyralid 3 Alligare, LLC 42750-94-81927 

Clopyralid Stinger Dow AgroSciences 62719-73 

Clopyralid Transline Dow AgroSciences 62719-259 

Clopyralid + 2,4-D Curtail Dow AgroSciences 62719-48 

Clopyralid + 2,4-D Commando Albaugh, Inc. 42750-92 

2,4-D Agrisolution 2,4-D LV6 Agriliance, L.L.C. 1381-101 

2,4-D Agrisolution 2,4-D Amine 4 Agriliance, L.L.C. 1381-103 

2,4-D Agrisolution 2,4-D LV4 Agriliance, L.L.C. 1381-102 

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 Solve 2,4-D Albaugh, Inc./Agri Star 42750-22 

2,4-D 2,4-D LV 6 Albaugh, Inc./Agri Star 42750-20 

2,4-D Five Star Albaugh, Inc./Agri Star 42750-49 

2,4-D D-638 Albaugh, Inc./Agri Star 42750-36 

2,4-D Opti-Amine Helena Chem. Co. 5905-501 

2,4-D Barrage HF Helena 5905-529 

2,4-D HardBall Helena 5905-549 

2,4-D Unison Helena 5905-542 

2,4-D Clean Amine Loveland Products Inc. 34704-120 

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 Saber Loveland Products Inc. 34704-803 

2,4-D Salvo Loveland Products Inc. 34704-609 

2,4-D Aqua-Kleen NuFarm Americas Inc. 71368-4 

537 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Active Ingredient Trade Name Manufacturer EPA Reg . Number 

2,4-D Esteron 99C NuFarm Americas Inc. 62719-9-71368 

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 Formula 40 Nufarm Americas Inc. 228-357 

2,4-D 2,4-D LV 6 Ester Nufarm Americas Inc. 228-95 

2,4-D Platoon Nufarm Americas Inc. 228-145 

2,4-D WEEDstroy AM-40 Nufarm Americas Inc. 228-145 

2,4-D Hi-Dep PBI Gordon Corp. 2217-703 

2,4-D Clean Crop Low Vol 6 Ester UAP-Platte Chem. Co. 34704-125 

2,4-D Salvo LV Ester UAP-Platte Chem. Co. 34704-609 

2,4-D 2,4-D 4# Amine Weed Killer UAP-Platte Chem. Co. 34704-120 

2,4-D Clean Crop LV-4 ES UAP-Platte Chem. Co. 34704-124 

2,4-D Savage DF UAP-Platte Chem. Co. 34704-606 

2,4-D Amine 4 Wilbur-Ellis Co. 2935-512 

2,4-D Lo Vol-6 Ester Wilbur-Ellis Co. 228-95-2935 

2,4-D Agrisolution 2,4-D LV6 Winflied Solutions, LLC 1381-101 

2,4-D Agrisolution 2,4-D Amine 4 Winfield Solutions, LLC 1381-103 

2,4-D Agrisolution 2,4-D LV4 Winfield Solutions, LLC 1381-102 

Dicamba Dicamba DMA Albaugh, Inc./Agri Star 42750-40 

Dicamba Vision Albaugh, Inc. 42750-98 

Dicamba Banvel Arysta LifeScience N.A. Corp. 66330-276 

Dicamba Clarity BASF Ag. Products 7969-137 

Dicamba Rifle Loveland Products Inc. 34704-861 

Dicamba Banvel Micro Flo Company 51036-289 

Dicamba Diablo Nufarm Americas Inc. 228-379 

Dicamba Vanquish Herbicide Nufarm Americas Inc. 228-397 

Dicamba Vanquish Syngenta 100-884 

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 Weedmaster BASF Ag. Products 7969-133 

Dicamba + 2,4-D Rifle-D Loveland Products Inc. 34704-869 

Dicamba + 2,4-D KambaMaster Nufarm Americas Inc. 71368-34 

Dicamba + 2,4-D Veteran 720 Nufarm Americas Inc. 228-295 

Dicamba + Diflufenzopyr Distinct BASF Ag. Products 7969-150 

Dicamba + Diflufenzopyr Overdrive BASF Ag. Products 7969-150 

Diquat Reward Syngenta Crop Prot., Inc. 100-1091 

Diuron Diuron 80DF Agriliance, L.L.C. 9779-318 

Diuron Karmex DF DuPont 352-692 

Diuron Karmex XP DuPont 352-692 

Diuron Karmex IWC DuPont 352-692 

Diuron Direx 4L DuPont 352-678 

Diuron Direx 80DF Griffin Company 1812-362 

Diuron Direx 4L Griffin Company 1812-257 

Diuron Diuron 4L Loveland Products Inc. 34704-854 

Diuron Diuron 80 WDG Loveland Products Inc. 34704-648 

Diuron Diuron 4L Makteshim Agan of N.A. 66222-54 

Diuron Diuron 80WDG UAP-Platte Chem. Co. 34704-648 

Diuron Vegetation Man. Diuron 80 DF Vegetation Man., LLC 66222-51-74477 

 538 
Draft Environmental Impact Statement: Appendix 9 

Active Ingredient Trade Name Manufacturer EPA Reg . Number 

Diuron Diuron 80DF Winfield Solutions, LLC 9779-318 

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 Aqua Star Albaugh, Inc./Agri Star 42750-59 

Glyphosate Forest Star Albaugh, Inc./Agri Star 42570-61 

Glyphosate Gly Star Original Albaugh, Inc./Agri Star 42750-60 

Glyphosate Gly Star Plus Albaugh, Inc./Agri Star 42750-61 

Glyphosate Gly Star Pro Albaugh, Inc./Agri Star 42750-61 

Glyphosate Glyphosate 4 PLUS Alligare, LLC 81927-9 

Glyphosate Glyfos Cheminova 4787-31 

Glyphosate Glyfos PRO Cheminova 67760-57 

Glyphosate Glyfos Aquatic Cheminova 4787-34 

Glyphosate ClearOut 41 Chem. Prod. Tech., LLC 70829-2 

Glyphosate ClearOut 41 Plus Chem. Prod. Tech., LLC 70829-3 

Glyphosate Accord Concentrate Dow AgroSciences 62719-324 

Glyphosate Accord SP Dow AgroSciences 62719-322 

Glyphosate Accord XRT Dow AgroSciences 62719-517 

Glyphosate Glypro Dow AgroSciences 62719-324 

Glyphosate Glypro Plus Dow AgroSciences 62719-322 

Glyphosate Rodeo Dow AgroSciences 62719-324 

Glyphosate Mirage Loveland Products Inc. 34704-889 

Glyphosate Mirage Plus Loveland Products Inc. 34704-890 

Glyphosate Aquamaster Monsanto 524-343 

Glyphosate Roundup Original Monsanto 524-445 

Glyphosate Roundup Original II Monsanto 524-454 

Glyphosate Honcho Monsanto 524-445 

Glyphosate Honcho Plus Monsanto 524-454 

Glyphosate Roundup PRO Monsanto 524-475 

Glyphosate Roundup PRO Concentrate Monsanto 524-529 

Glyphosate Roundup PRO Dry Monsanto 524-505 

Glyphosate GlyphoMate 41 PBI Gordon Corp. 2217-847 

Glyphosate Aqua Neat Nufarm Americas Inc. 228-365 

Glyphosate Foresters Nufarm Americas Inc. 228-381 

Glyphosate Razor Nufarm Americas Inc. 228-366 

Glyphosate Razor Pro Nufarm Americas Inc. 228-366 

Glyphosate AquaPro Aquatic Herbicide SePRO Corporation 62719-324-67690 

Glyphosate Rattler Setre (Helena) 524-445-5905 

Glyphosate Buccaneer Tenkoz 55467-10 

Glyphosate Buccaneer Plus Tenkoz 55467-9 

Glyphosate Mirage Herbicide UAP-Platte Chem. Co. 524-445-34704 

Glyphosate Mirage Plus Herbicide UAP-Platte Chem. Co. 524-454-34704 

Glyphosate Glyphosate 4 Vegetation Man., LLC 73220-6-74477 

Glyphosate + 2,4-D Landmaster BW Albaugh, Inc./Agri Star 42570-62 

Glyphosate + 2,4-D Campaign Monsanto 524-351 

Glyphosate + 2,4-D Landmaster BW Monsanto 524-351 

Glyphosate + Dicamba Fallowmaster Monsanto 524-507 

Hexazinone Velpar ULW DuPont 352-450 

539 
 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Active Ingredient Trade Name Manufacturer EPA Reg . Number 

Hexazinone Velpar L DuPont 352-392 

Hexazinone Velpar DF DuPont 352-581 

Hexazinone + Sulfometuron 

methyl Westar DuPont Crop Protection 352-626 

Imazapic Plateau BASF 241-365 

Imazapic Panoramic 2SL Alligare, LLC 66222-141-81927 

Imazapic + Glyphosate Journey BASF 241-417 

Imazapyr Arsenal Railroad Herbicide BASF 241-273 

Imazapyr Chopper BASF 241-296 

Imazapyr Arsenal Applicators Conc. BASF 241-299 

Imazapyr Arsenal BASF 241-346 

Imazapyr Arsenal PowerLine BASF 241-431 

Imazapyr Stalker BASF 241-398 

Imazapyr Habitat BASF 241-426 

Imazapyr Imazapyr E-Pro 2 - VM & Etigra, LLC 81959-8 

Imazapyr Aquatic Herbicide 

Imazapyr Imazapyr E-Pro 4 - Forestry Etigra, LLC 81959-9 

Imazapyr 

Imazapyr E-Pro 2E - Site Prep 

& Basal Etigra, LLC 81959-7 

Imazapyr Polaris RR Nufarm Americas Inc. 241-273-228 

Imazapyr Polaris SP Nufarm Americas Inc. 241-296-228 

Imazapyr Polaris AC Nufarm Americas Inc. 241-299-228 

Imazapyr Polaris AQ Nufarm Americas Inc. 241-426-228 

Imazapyr Polaris Herbicide Nufarm Americas Inc. 241-346-228 

Imazapyr SSI Maxim Arsenal 0.5G SSI Maxim Co., Inc. 34913-23 

Imazapyr Ecomazapyr 2 SL Vegetation Man., LLC 74477-6 

Imazapyr Imazapyr 2 SL Vegetation Man., LLC 74477-4 

Imazapyr Imazapyr 4 SL Vegetation Man., LLC 74477-5 

Imazapyr + Diuron Mojave 70 EG Alligare, LLC 74477-9-81927 

Imazapyr + Diuron Sahara DG BASF 241-372 

Imazapyr + Diuron Imazuron E-Pro Etigra, LLC 79676-54 

Imazapyr + Diuron SSI Maxim Topsite 2.5G SSI Maxim Co., Inc. 34913-22 

Imazapyr + Metsulfuron methyl Lineage Clearstand DuPont 352-766 

Metsulfuron methyl Escort DF DuPont 352-439 

Metsulfuron methyl Escort XP DuPont 352-439 

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 Metsulfuron Methyl DF Vegetation Man., L.L.C. 74477-2 

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 Triumph 22K Albaugh, Inc. 42750-79 

Picloram Picloram K Alligare, LLC 42750-81-81927 

Picloram Picloram 22K Alligare, LLC 42750-79-81927 

Picloram OutPost 22K Dow AgroSciences 62719-6 

Picloram Tordon K Dow AgroSciences 62719-17 

 540 
Draft Environmental Impact Statement: Appendix 9 

Active Ingredient Trade Name Manufacturer EPA Reg . Number 

Picloram Tordon 22K Dow AgroSciences 62719-6 

Picloram + 2,4-D Tordon 101M Dow AgroSciences 62719-5 

Picloram + 2,4-D Tordon 101 R Forestry Dow AgroSciences 62719-31 

Picloram + 2,4-D Tordon RTU Dow AgroSciences 62719-31 

Picloram + 2,4-D Grazon P+D Dow AgroSciences 62719-182 

Picloram + 2,4-D HiredHand P+D Dow AgroSciences 62719-182 

Picloram + 2,4-D Pathway Dow AgroSciences 62719-31 

Sulfometuron methyl Oust XP DuPont 352-601 

Sulfometuron methyl SFM E-Pro 75EG Etigra, LLC 79676-16 

Sulfometuron methyl Spyder Nufarm Americas Inc. 228-408 

Sulfometuron methyl SFM 75 Vegetation Man., L.L.C. 72167-11-74477 

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 Triclopyr 4EC Alligare, LLC 72167-53-74477 

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 Remedy Ultra Dow AgroSciences 62719-552 

Triclopyr Pathfinder II Dow AgroSciences 62719-176 

Triclopyr Tahoe 3A Nufarm Americas Inc. 228-384 

Triclopyr Tahoe 3A Nufarm Americas Inc. 228-518 

Triclopyr Tahoe 4E Nufarm Americas Inc. 228-385 

Triclopyr Renovate 3 SePRO Corporation 62719-37-67690 

Triclopyr Renovate OTF SePRO Corporation 67690-42 

Triclopyr Ecotriclopyr 3 SL Vegetation Man., LLC 72167-49-74477 

Triclopyr Triclopyr 3 SL Vegetation Man., LLC 72167-49-74477 

Triclopyr + 2,4-D Crossbow Dow AgroSciences 62719-260 

Triclopyr + Clopyralid Redeem R&P Dow AgroSciences 62719-337 

541 
 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Table a9-2. TargeT sPecies and recommended Herbicide conTrols 

Non-herbicide 

methods 

effective 

Alternative 

where 

recommended 

herbicide 

available1 Common Name 

2,4-DBromacilChlorsulfuronClopyralidDicambaDifl ufenzopyr+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 √ √ 

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 

 542 
 

 

 

 

Draft Environmental Impact Statement: Appendix 9 

Non-herbicide 

methods 

effective 

Alternative 

where 

recommended 

herbicide 

available1 Common Name 

2,4-DBromacilChlorsulfuronClopyralidDicambaD i fl u f e n z o p y r +DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr 

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 K n a p w e e d , D i f f u s e √ 2 √ 2 √ 

No 2 K n a p w e e d , M e a d o w √ √ √ 3 √ √ √ 2 √ 

No 2 K n a p w e e d , R u s s i a n √ √ √ 

No 2 K n a p w e e d , s p o t t e d √ √ √ 2 

No 2 K n a p w e e d , S q u a r r o s e √ √ 3 √ √ √ √ 

No 2 K n o t w e e d , G i a n t √ √ √ √ √ 

No 2 K n o t w e e d , H i m a l a y a n √ √ √ √ √ 

No 2 K n o t w e e d , J a p a n e s e √ √ √ √ √ 

No 2 K o c h i a √ 2 √ √ √ 

No 2 K u d z u √ √ 

Yes5 None Lepyrodiclis 

No 2 L e s s e r c e l a d i n e o r fi g b u t t e r c u p √ 

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 √ √ 

No 2 Paterson’s curse √ √ √ √ √ 

No 3 Perennial peavine √ 

No 3 Perennial pepperweed √ √ 

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 √ 

543 
 

 

 

 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Non-herbicide 

methods 

effective 

Alternative 

where 

recommended 

herbicide 

available1 Common Name 

2,4-DBromacilChlorsulfuronClopyralidDicambaDifl ufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr 

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 √ √ √ 

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 Wild proso millet √ √ √ 

No 2 Yellow Flag Iris √ √ √ √ √ 

Yes 2 Yellow floating heart √ √ 

No 3 Yellow nutsedge √ 

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 √ √ √ √ 

 544 
 

 

 

 

 

 

Draft Environmental Impact Statement: Appendix 9 

Non-herbicide 

methods 

effective 

Alternative 

where 

recommended 

herbicide 

available1 Common Name 

2,4-DBromacilChlorsulfuronClopyralidDicambaD i fl u f e n z o p y r +DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr 

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 √ √ 

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 Feverfew √ √ √ √ √ 

Yes 3 Field mustard √ √ √ 

No 3 Field sowthistle √ √ √ 

Yes 3 

G a r d e n c o r n fl o w e r o r b a c h e l o r 

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 √ √ √ 

545 
 

 

 

 

 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Non-herbicide 

methods 

effective 

Alternative 

where 

recommended 

herbicide 

available1 Common Name 

2,4-DBromacilChlorsulfuronClopyralidDicambaDifl ufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr 

No 3 Knotweed, Bohemian √ √ √ √ 

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 √ √ 

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 √ √ 

Yes 3 Wild safflower √ √ 

No 3 Yellow glandweed √ √ √ √ √ 

 546 
 

 

 

 

 

 

 

 

 

 

 

Draft Environmental Impact Statement: Appendix 9 

Non-herbicide 

methods 

effective 

Alternative 

where 

recommended 

herbicide 

available1 Common Name 

2,4-DBromacilChlorsulfuronClopyralidDicambaDifl ufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr 

Native Vegetation 

No 4 Alder √ √ √ 

No 4 Big leaf maple √ √ 

Yes 4 Big sagebrush √ √ √ √ 

Yes 4 Conifers √ √ √ 

No 4 Evergreen huckleberry 

No 4 Grasses √ √ √ √ 

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 Determined based on herbicides recommended by the Pacific Northwest Weed Management Handbook (OSU 2008), internet sources or comparison of similar species. 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. Not feasible on larger or more established infestations.
 6 Larger infestations require repeat visits for effective control –Manual/mechanical kill most plants, sprouts or germinating seeds require additional treatment. 

7 Some cropping systems and fallow are effective. These techniques are not likely to be compatible with wildland management.
 

547 
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Index 

2,4-D ........................................................... 32, 35, 38, 42, 58, 75-83, 90, 91, 118, 150, 151, 162, 178, 193, 214, 229, 314, 321
 

Acronyms...................................................................................................................................................................................... i
 

Adjuvant..................................................................................................................................................................... 40, 195, 318
 

Administrative sites ........................................................................................................................................19, 31, 65, 276-283
 

ALS-inhibitor..................................................................................................................................................... 21, 117, 195, 213
 

Application methods ............................................................................................................................................................ 48, 64
 

Biological Control................................................................................................................................................ 56, 59, 219, 260
 

Bromacil.................................................................. 32, 34, 42, 58, 75-84, 90, 119, 150, 151, 164, 180, 191, 214, 227, 316, 321
 

Chlorsulfuron ......................................................................................42, 58, 75-83, 90, 150, 151, 164, 180, 191, 215, 227, 314
 

Clopyralid ................................................................................... 42, 58, 75-83, 90, 118, 151, 152, 164, 180, 193, 215, 229, 314
 

Conservation Agreement............................................................................................................................................................ 19
 

Conservation Strategy................................................................................................................................................................ 19
 

Consultation ................................................................................................................................................................11, 250, 411
 

Dicamba ...................................................................................... 42, 58, 75-83, 90, 118, 151, 152, 164, 180, 191, 214, 227, 312
 

Dicamba+Diflufenzopyr .............................................42, 58, 75-83, 90, 120, 151, 152, 164, 181, 191, 192, 215, 227, 228, 312
 

Diquat.................................................................................. 42, 58, 75-83, 90, 119, 151, 152, 162, 179, 191, 215, 228, 313, 321
 

Directed Livestock....................................................................................................................... 56, 59, 123, 198, 219, 259, 305
 

Diuron ..................................................................... 32, 34, 42, 58, 75-84, 90, 119, 151, 152, 164, 181, 191, 215, 228, 317, 321
 

East/West of the Cascades.................................................................................................................................................... 18, 41
 

Endangered Species ..........................................................................................................................202, 208, 325, 410, 429-471
 

Endocrine Disrupter........................................................................................................................................... 32, 188, 213, 317
 

Fluridone..................................................................................... 42, 58, 75-83, 90, 119, 151, 152, 162, 179, 192, 215, 228, 313
 

Glyphosate .......................................................................... 42, 58, 75-83, 90, 119, 134, 151, 152, 163, 179, 193, 214, 229, 315
 

Hexazinone ......................................................................... 43, 58, 75-83, 90, 119, 151, 153, 165, 181, 193, 216, 229, 315, 321
 

Imazapic........................................................................................35, 43, 58, 75-83, 90, 151, 153, 165, 181, 192, 216, 228, 313
 

Imazapyr .....................................................................................43, 58, 75-83, 90, 134, 151, 153, 163, 179, 193, 216, 229, 315
 

Integrated Vegetation Management ....................................................................................................................................... 6, 44
 

Manual method ...................................................................................................................... 26, 53, 59, 122, 197, 219, 259, 305
 

Maximum application rates................................................................................................................................................ 62, 319
 

Mechanical method........................................................................................................ 26, 54, 59, 122, 197, 219, 259, 305, 321
 

Metsulfuron methyl.............................................................................43, 58, 75-83, 90, 151, 153, 165, 181, 194, 216, 230, 315
 

Mitigation Measures ................................................................................................................16, 24, 32, 34, 35-38, 74, 405-417
 

Monitoring ............................................................................................................................................................36, 47, 419-423
 

Noxious Weeds ......................................................... 4, 5, 7, 25, 104-111, 120, 181, 217, 230, 246-247, 287, 515-517, 524-532
 

Picloram ..............................................................................................43, 58, 75-83, 90, 151, 153, 165, 181, 194, 214, 230, 316
 

Potential vegetation........................................................................................................................................................... 113-115
 

Prescribed Fire ............................................................................................................. 57, 59, 122, 198, 220, 243, 259, 305, 321
 

Risk Assessment..............................................................................................................24, 67-73, 75-84, 86, 310-312, 533-535
 

Recreation sites .......................................................................................................................................19, 30, 65, 269-276, 413
 

Rights-of-Way.........................................................................................................................................19, 31, 65, 276-283, 414
 

Scoping .......................................................................................................................................................................10, 286-288
 

Seed orchard............................................................................................................................................................... 13, 278, 283
 

Sensitive Species..................................................................................................18, 121, 202-205, 208, 410, 415-417, 429, 472
 

Spill....................................................................................................................................................................75-83, 87-88, 319
 

Spread rate .....................................................................................................................................25, 33, 108-111, 122, 524-527
 

Standard Operating Procedures.................................................................................................................16, 24, 32, 74, 405-417
 

Sulfometuron methyl ....................................................................43, 58, 75-83, 90, 91, 151, 153, 166, 181, 192, 216, 228, 313
 

Tebuthiuron ............................................................. 32, 34, 43, 59, 75-84, 90, 119, 151, 154, 166, 181, 192, 216, 228, 317, 321
 

Treatment methods................................................................................................................................................................48-67
 

Triclopyr.............................................................................. 43, 59, 75-83, 90, 118, 151, 154, 163, 180, 194, 217, 230, 316, 321
 

Typical application rates .................................................................................................................................................... 62, 318
 

 548 

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OFFICIAL BUSINESS _____________ Portland, Oregon 97204333 SW 1st Avenue Bureau of Land ManagementUnited States Department of the Interior PRIORITY MAIL

Bureau of Land Management

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Permit No. G-76

BLM/OR/WA/AE-09/070+1792 
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Bureau of Land Management - Oregon State Office Vegetation Treatments Draft Environmental Impact Statement - September 2009