United States 

Department of 

Agriculture 

Forest 

Service 

Wallowa-Whitman 

National Forest Invasive 

Plants Treatment Project 

Draft Environmental 

Impact Statement 

Volume 1 

Wallowa, Union, Baker, Malheur, Umatilla, and Grant Counties in Oregon 

Adams and Nez Perce Counties in Idaho 

Photo courtesy L. Dawson

Pacific 

Northwest 

Region 

March 2009 
Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on 

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(800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer. 
Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

Invasive Plant Treatment Project 

Draft Environmental Impact Statement 

Wallowa, Union, Baker, Malheur, Umatilla, and Grant Counties in Oregon 

Adams, and Nez Perce Counties in Idaho 

Lead Agency: USDA Forest Service 

Responsible Official: Steven Ellis, Wallowa-Whitman 

 National Forest Supervisor 

Information Contact: Robert Rock, Wallowa-Whitman 

 National Forest Resource Staff Officer 

Address Comments To: INVASIVE PLANTS 

 Wallowa-Whitman National Forest 

 1550 Dewey Avenue 

 Baker City, OR 97814 

Electronic Comments Accepted: comments-pacificnorthwest-wallowa- 

 whitman@fs.fed.us 

Website http://www.fs.fed.us/r6/w-w/projects

This DEIS is made available for a 45-day Comment Period, under the provisions of the National 

Environmental Policy Act (40 CFR 1500-1508), and Notice, Comment, and Appeal Procedures for 

National Forest System Projects and Activities, (36 CFR 215). The Forest Service will accept comments 

as provided in §215.6(a) (4), beginning on the day following the date of publication of the Notice of 

Availability (NOA) in the Federal Register. In order to be considered in the Final Environmental Impact 

Statement, substantive comments must be received within the formal comment period. The official 

comment period timelines will be posted in the Federal Register, and on the Wallowa-Whitman National 

Forest’s Web site (http://www.fs.fed.us/r6/w-w/projects/). 

Comments received in response to this solicitation, including names and addresses of those who 

comment, will be considered part of the public record on this Proposed Action and will be available for 

public inspection. Comments submitted anonymously will be accepted and considered; however, those 

who only comment anonymously will not have standing to appeal the subsequent decision under 36 CFR 

Part 215. Reviewers must provide the Forest Service with their comments during the review period of 

this Draft Environmental Impact Statement. This will enable the Forest Service to analyze and respond to 

the comments at one time and to use information acquired in the preparation of the final environmental 

impact statement, 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, 553 (1978). Environmental objections that could have been raised 

at the draft stage may be waived if not raised until after completion of the final environmental impact 

statement. City of Angoon, v. Hodel (9th Circuit, 1986) and Wisconsin Heritages, Inc. v. Harris, 490 F. 

Supp. 1334, 1338 (E.D. Wis. 1980). Comments on the draft environmental impact statement should be 

specific and should address the adequacy of the statement and the merits of the alternatives discussed (40 

CFR 1503.3). 

i 
Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

Abstract 

This Draft Environmental Impact Statement (DEIS) discloses the effects of treating invasive plants on the 

Wallowa-Whitman National Forest. Invasive species were identified by the Chief of the Forest Service as 

one of the four threats to forest health (for more information sees http://www.fs.fed.us/project/fourthreats). Invasive plants are displacing native plants, destabilizing streams, reducing the quality of fish 

and wildlife habitat; and degrading natural areas. 

Strong public concern has been expressed regarding Forest Service response to invasive plants. Several 

organizations and individuals have offered to cooperate with the Forest Service in this endeavor. The 

Forest Service is responding to a crucial need for timely containment, control, or eradication of invasive 

plants, including those that are currently known and those discovered in the future. The purpose of this 

project is to treat invasive plants in a cost-effective manner that complies with environmental standards. 

Approximately 22,842 acres are currently estimated to need treatment, including but not limited to 

common bugloss, diffuse knapweed, yellow star thistle, dalmation toadflax, common cuprina, 

Mediterranean sage, leafy spurge, and rush skeletonweed. This Draft Environmental Impact Statement 

(DEIS) also analyzes the effects of treating new infestations and new invasive plant species presently 

unknown or non-existent, although discovered during the life of this project using a process called Early 

Detection Rapid Response (EDRR). This DEIS includes detailed consideration of four alternatives: 

• Alternative A, the No Action Alternative, would continue to implement treatments according to 

existing plans; no new invasive plant treatments would be approved. 

• Alternative B, the Proposed Action Alternative, would allow treatment of known inventoried 

invasive plant sites as well as re-treatment in subsequent years until a site was restored with 

desirable vegetation, as well as treatment of unknown sites that may be discovered in the future. 

Herbicide treatments would be part of the initial prescription for most sites, but the use of 

herbicides would be expected to decline in subsequent entries as populations became small 

enough to treat manually or mechanically. Ongoing inventories would confirm the location of 

specific invasive plants and effectiveness of past treatments. 

Two action alternatives were developed in response to public issues related to herbicide use: 

• Alternative C, No Broadcast Spraying in Riparian Areas, would not allow broadcast applications 

of herbicides in riparian areas; however, spot spraying or selective applications such as wiping or 

wicking of herbicides would be allowed. Except for this limitation imposed on broadcast 

spraying, the features of this alternative are the same as for Alternative B. This alternative 

addresses human health issues as well as potential impacts to non-target wildlife, plant species, 

soils, aquatic biota and riparian ecosystems. Alternative C would minimize herbicide impacts, 

while increasing treatment costs and decreasing treatment effectiveness. 

• Alternative D, No Aerial Application, would eliminate the option to aerially apply herbicides. 

This addresses the issues expressed regarding potential effects of herbicide drift to human health 

through drinking water supplies, also to non-target wildlife and plant species, soils, aquatic biota 

and riparian ecosystems, both in the areas being treated, and areas adjacent to them. Alternative D 

would minimize herbicide impacts, while increasing treatment costs and decreasing treatment 

effectiveness. Treatment of some sites would likely not occur due to inaccessibility. Except for 

this limitation imposed on aerial spraying, the features of this alternative are the same as for 

Alternative B. The Forest Service Preferred Alternative is the Proposed Action (Alternative B). 

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Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

Summary 

Land managers for the Wallowa-Whitman National Forest propose treatments to increase native 

vegetation by containing, controling, or eradicating invasive plants and restoring sites 

(seeding/mulching/planting/fertilizing). Invasive species were identified by the Chief of the Forest 

Service as one of the four threats to forest health (for more information see 

http://www.fs.fed.us/projects/four-threats). Invasive plants are displacing native plants and degrading 

natural areas, potentially destabilizing streams and reducing the quality of fish and wildlife habitat. Our 

integrated weed management program includes a) herbicide and non-herbicide treatment of existing 

infestations, b) early detection and rapid response to new infestations, c) restoration of treated sites, d) 

reducing the rate of spread of invasive plants through adopting prevention practices, and e) interagency 

and public education and coordination. 

The focus of this Draft Environmental Impact Statement (DEIS) is on the part of our program related to 

treatment of invasive plant sites on the Wallowa-Whitman National Forest. New invasive plant 

management direction has recently been approved by the Pacific Northwest (R6) Regional Forester, 

allowing for a wider range of herbicide options and specific treatment and restoration standards (USDA 

2005b, The Pacific Northwest Invasive Plant Program Record of Decision, referred to herein as the R6 

2005 ROD). 

With this project, the Forest Service is responding to the need for timely containment, control, or 

eradication of invasive plants, including those that are currently known and those discovered in the future. 

Strong public concern has been expressed regarding Forest Service response to invasive plants. Several 

organizations and individuals have offered to cooperate with the Forest Service in this endeavor. 

The purpose of this project is to treat invasive plants in a cost-effective manner that complies with the 

new management direction. Proposed treatment methods include a limited amount of aerial spraying, 

herbicide broadcast along roadsides, and spot spray and selective herbicide treatments that target 

individual invasive plants in combination with manual, mechanical and cultural (fertilization, soil 

amendments, and competitive planting) treatments. Biological control is an ongoing process. 

Treatments are proposed for existing or unpredictable new infestations including new plant species that 

currently are not found on the Forest. Project Design Features (PDFs) would be applied to new 

infestations that occur within treatment areas, or in similar sites outside treatment areas, to ensure that 

treatments are within the scope of this EIS. 

Four alternatives are considered: The No Action (also referred to as Alternative A), the Proposed Action 

(also referred to as Alternative B), and two additional action alternatives, Alternative C, which restricts 

broadcast spraying of herbicides in riparian areas, and Alternative D, which does not allow aerial spraying 

anywhere. 

In the No Action Alternative (Alternative A), no new treatments beyond those previously approved in the 

• 1992 decision implementing the Wallowa-Whitman National Forest Environmental Assessment 

for the Management of Noxious Weeds (USDA Forest Service 1992) 

• 1994 decision implementing the Wallowa-Whitman Management of Noxious Weeds 

Environmental Assessment (USDA Forest Service 1994a) 

• Hells Canyon Comprehensive Management Plan (CMP) (Forest Plan Amendment #29, USDA 

Forest Service 2003c) 

The 1994 EA, which incorporated the 1992 EA, identified 5,172 additional acres of weed infestations and 

21 invasive plant species for treatment. The Hells Canyon CMP added additional direction to evaluate the 

iii 
Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

extent of nonnative invasive plants, provided additional guidelines for the containment or control of 

aggressive weeds and implemented additional prevention guidelines to further reduce the spread of weeds 

(USDA Forest Service 2003, Appendix C, Table C-1, pages 67-68). The two EAs authorized the use of 

four herbicides; glyphosate, dicamba, picloram (with restrictions), and triclopyr during site treatment. 

Dicamba was restricted from use by the R6 2005 FEIS and will not be used in the future by the Forest. 

Alternative B proposes to satisfy the project Purpose and Need by using chemical, physical, cultural and 

biological treatment methods to control, contain, or eradicate existing or newly discovered invasive plants 

infestations. Current inventory indicates there are approximately 23,000 acres of invasive plant 

infestations on the Forest in 1,740 invasive plant sites. The thorough compilation of past infestation sites 

and the inventory that was completed in 2006, indicates that approximately 90 percent of weed 

infestations on the Forest are known, and about 10 percent are as yet undiscovered. 

Potential treatments based on existing mapped sites (see Figures 2-8) include: 

• Approximately 13,556 acres of uplands would utilize chemical ground based broadcast, spot 

spray and selective treatments 

• Approximately 3,104 acres of riparian areas would utilize chemical ground based broadcast 

treatments 

• Approximately 3,241 acres of riparian areas would utilize chemical spot spray and selective 

treatments including wicking, wiping and stem injection 

• Approximately 1,955 acres would be treated using biological methods only (upland or riparian 

areas) 

• Approximately 111 acres would be treated using manual methods only 

• Approximately 875 acres would utilize chemical aerial broadcast methods 

Total acres = 22,842 

Aerial application of the herbicides would occur in the HCNRA and La Grande District covering 

approximately 875 acres (see Figure 9). Appendix F includes maps detailing aerial application sites. 

There is concern that detrimental effects could occur from broadcast spraying herbicide chemical in 

riparian areas. Alternative C (See Chapter 2 for a full description) would not allow broadcast applications 

of herbicides in riparian areas. However, spot spraying, or selective applications like wiping, wicking, or 

injecting herbicides would be allowed. 

There is concern that aerial application of herbicides could cause detrimental effects to areas targeted, and 

to adjacent areas where chemical drift could impact non-target environments. Alternative D (See Chapter 

2 for a full description) would eliminate this concern by eliminating the option to aerially apply 

herbicides. 

The analysis in the DEIS considers a range of treatments applied to a range of conditions throughout the 

road systems and other areas that are vectors of invasive plant spread. Project Design Features (listed in 

Chapter 2) have been developed to limit the potential for adverse effects associated with treatments. 

Buffers (Tables 7, 8, 9, and 10 in Chapter 2) would limit herbicide selection and method application to 

ensure exposures are below thresholds of concern for people and the environment. 

This DEIS focuses on treatment of invasive plants and restoration of treated sites. It is tiered to the 

broader scale Pacific Northwest Region Invasive Plant Program Preventing and Managing Invasive 

Plants FEIS (USDA Forest Service 2005a), along with its accompanying Record of Decision for Invasive 

Plant Program Management (USDA Forest Service 2005b), (herein referred to as R6 2005 FEIS and R6 

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Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

v 

2005 ROD), which addresses other aspects of the invasive plant management program including 

preventing invasive plant spread during land uses and management activities. 

This project in no way attempts to diminish or modify other Wallowa-Whitman National Forest programs. 

Each Forest program is responsible to manage activities in ways that will minimize the potential for 

invasive plants to become established and spread. With this understanding it is our firm belief that the 

result of this project acting in the context of past, present, and foreseeable future actions will reduce the 

influence of invasive plant species. This would improve native plant communities, their ecologic 

functions and thereby improve overall forest health. 

Alternatives-Comparison Summary of Activities 

Table S- 1 – Alternatives Compared 

Activity Alt A Alt B Alt C Alt D 

Acres identified for treatment 5,172 22,842 22,842 22,809 

Includes EDRR for new sites (all 

methods within the scope of the project, 

except aerial). 

No Yes Yes Yes 

Percentage of sites where all effective 

methods are available 0 100 86 96 

Acres of proposed herbicide treatments 5172 20,776 20,776 19,901 

Number of herbicides available for use 2 10 10 10 

% of Total Forest Land Base Treated 

with Herbicides Apprx: 0.23% Apprx: .9% Apprx: .9% Apprx: .8% 

Maximum % of Total Forest Land Base 

treated annually <0.02% 0.32% 0.32% 0.32% 

Average Cost Per Acre $820 $307 $312 $334 

Degree to which adverse effects to 

people and the environment are 

minimized 

Minimal risks 

from project 

Minimal risks 

from project: 

Aerial and 

broadcast 

include 

inherent risks

Minimal risks 

from project: 

Broadcast in 

riparian areas 

eliminated

Minimal risks 

from project: 

Aerial treatment 

eliminated
Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

Table of Contents 

Abstract.....................................................................................................................................................ii

Summary..................................................................................................................................................iii

Alternatives-Comparison Summary of Activities.................................................................................v

Chapter 1 – Purpose and Need for Action ....................................................................................................1

1.1 Background.........................................................................................................................................1

1.2 Desired Future Conditions..................................................................................................................7

1.3 Purpose and Need ...............................................................................................................................7

1.4 Proposed Action .................................................................................................................................8

1.5 Management Direction .......................................................................................................................9

1.5.1 Regional Direction .....................................................................................................................10

1.5.2 Forest Direction .........................................................................................................................10

1.6 Decision Framework.........................................................................................................................12

1.7 Tribal Involvement ...........................................................................................................................12

1.7.1 Introduction................................................................................................................................12

1.7.2 Tribal Concerns..........................................................................................................................13

1.8 Public Involvement...........................................................................................................................14

1.8.1 Scoping ......................................................................................................................................14

1.9 Issues ................................................................................................................................................14

1.9.1 Human Health ............................................................................................................................15

1.9.2 Treatment Effectiveness:............................................................................................................15

1.9.3 Social and Economic..................................................................................................................16

1.9.4 Non-target Botanical Species and Wildlife................................................................................16

1.9.5 Soil, Water Quality, Aquatic Biota ............................................................................................17

1.9.6 Non-Significant Issues ...............................................................................................................18

1.10 What This Proposal Does Not Include ...........................................................................................19

Chapter 2 – Alternatives .............................................................................................................................21

2.1 Introduction ......................................................................................................................................21

2.2 Alternatives Considered in Detail.....................................................................................................22

2.2.1 Proposed Action and Alternative Development Process ...........................................................22

2.2.2 Alternative A - No Action..........................................................................................................24

2.2.3 Alternative B - Proposed Action................................................................................................25

2.2.4 Alternative C..............................................................................................................................77

2.2.5 Alternative D..............................................................................................................................78

2.3 Alternatives Not Considered in Detail..............................................................................................78

2.3.1 High Potential for Spread Areas or Priority 1 and 2 Species.....................................................78

2.3.2 Invasive Plants Managed through Natural Processes.................................................................79

2.3.3 No Herbicides ............................................................................................................................79

2.3.4 1994 Guidelines Applied Forest-wide .......................................................................................80

2.3.5 Restricted Use – No Herbicides in Riparian or Special Areas...................................................80

2.3.6 Deviations from Existing Approved Herbicide List ..................................................................83

2.4 Alternatives Compared .....................................................................................................................84

Chapter 3 – Affected Environment and Environmental Consequences......................................................89

3.1 Introduction ......................................................................................................................................89

3.1.1 Project Area ...............................................................................................................................89

3.1.2 Basis for Cumulative Effects Analysis ......................................................................................89

3.1.3 Life of the Project ......................................................................................................................91

3.1.4 Herbicide Risk Assessments ......................................................................................................92

3.1.5 Climate Change..........................................................................................................................93

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Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

3.1.6 Treatment Strategy, Type, and Effectiveness Common to All Alternatives ..............................95

3.2. Botany ............................................................................................................................................108

3.2.1 Introduction ..............................................................................................................................108

3.2.2 Affected Environment ..............................................................................................................109

3.2.3 Environmental Consequences ..................................................................................................124

3.3 Terrestrial Wildlife..........................................................................................................................150

3.3.1 Introduction ..............................................................................................................................150

3.3.2 Affected Environment ..............................................................................................................150

3.3.3 Alternatives Analyzed ..............................................................................................................176

3.3.4 Environmental Consequences ..................................................................................................177

3.3.5 Effects to Threatened, Endangered and Sensitive (TES) Species ............................................197

3.3.6 Effects to Sensitive Species......................................................................................................200

3.3.7 Effects to Management Indicator Species ................................................................................233

3.3.8 Effects to Other Species of Interest ..........................................................................................244

3.4 Soil and Water.................................................................................................................................247

3.4.1 Introduction ..............................................................................................................................247

3.4.2 Affected Environment ..............................................................................................................249

3.4.3 Environmental Consequences ..................................................................................................261

3.5 Aquatic Organisms and Habitat ......................................................................................................293

3.5.1 Introduction ..............................................................................................................................293

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

3.5.3 Environmental Consequences ..................................................................................................317

3.6 Recreation Resources......................................................................................................................356

3.6.1 Introduction ..............................................................................................................................356

3.6.2 Affected Environment ..............................................................................................................357

3.6.3 Environmental Consequences ..................................................................................................367

3.7 Effects of Herbicide Use on Workers and the Public......................................................................383

3.7.1 Introduction ..............................................................................................................................383

3.7.2 Affected Environment ..............................................................................................................385

3.7.3 Environmental Consequences ..................................................................................................386

3.8 Rangeland Resources ......................................................................................................................391

3.8.1 Introduction ..............................................................................................................................391

3.8.2 Affected Environment ..............................................................................................................392

3.8.3 Environmental Consequences ..................................................................................................395

3.9 Project Costs and Financial Efficiency ...........................................................................................400

3.9.1 Introduction ..............................................................................................................................400

3.9.2 Methodology ............................................................................................................................400

3.9.3 Affected Environment ..............................................................................................................402

3.9.4 Environmental Consequences ..................................................................................................405

3.10 Heritage Resources .......................................................................................................................416

3.11 Impacts to Cultural Uses and Treaty Rights..................................................................................417

3.11.1 Introduction ............................................................................................................................417

3.11.2 Affected Environment ............................................................................................................417

3.11.3 Environmental Consequences ................................................................................................418

3.12 Irreversible or Irretrievable Use of Resources ..............................................................................420

3.13 Effects of Short-term uses and Maintenance of Long-term Productivity .....................................420

3.14 Consistency with Forest Service Policies and Plans .....................................................................420

3.15 Conflicts with Other Plans ............................................................................................................421

3.16 Adverse Effects That Cannot Be Avoided ....................................................................................421

Chapter 4 – List of Preparers.....................................................................................................................423

4.1 List of Preparers ..............................................................................................................................423

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Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

4.2 Consultation with Regulatory Agencies .........................................................................................424

4.3 Consultation with Tribes ................................................................................................................424

4.4 Consultation with Counties ............................................................................................................424

4.5 Consultation with Others ................................................................................................................424

4.6 Glossary..........................................................................................................................................427

4.7 References ......................................................................................................................................444

4.8 Index ...............................................................................................................................................482

Table of Tables 

Table 1-Number of Invasive Plant sites by species identified by District on the Wallowa-Whitman NF....2

Table 2-Acres of invasive plants by species and district ..............................................................................3

Table 3-Acres of treatment methods by Ranger District ............................................................................27

Table 4-High, Typical, and Low Application Rates for Herbicides ...........................................................37

Table 5-Common Control Measures Summary - Range of Effective Treatment Options and Site-Specific 

Considerations by Target Species.......................................................................................................41

Table 6-Design features specific to the ten herbicides approved for use in Region 6, gross acres and 

percentage of known sites where each herbicide would be effective .................................................48

Table 7-Herbicide Use Buffers in Feet -Perennial and Wet Intermittent Streams -Proposed Action.........70

Table 8-Herbicide Use Buffers in Feet -Dry Intermittent Streams -Proposed Action ................................70

Table 9-Herbicide Use Buffers in Feet – Lakes and Wetlands...................................................................71

Table 10-Buffer widths required for aerial applications.............................................................................71

Table 11-Comparing acres of proposed herbicide treatment for Alternative B and “Restricted Use” 

alternative............................................................................................................................................81

Table 12-Alternatives compared by activity...............................................................................................84

Table 13-Alternative comparison relative to significant issues ..................................................................85

Table 14-Risk assessments for herbicides considered in this EIS ..............................................................92

Table 15-Summary of the influence of various factors on spray drift ......................................................101

Table 16-Treatment type, method of application and acres proposed for treatment by alternative..........103

Table 17-Herbicide formulations, invasive plant sites, total acres treated and treatment effectiveness by 

alternative..........................................................................................................................................104

Table 18-Invasive plant species sites identified on each district within the Wallowa-Whitman National 

Forest ................................................................................................................................................111

Table 19-Invasive plant species and acres by district ...............................................................................113

Table 20-Range of acreage of infested sites documented on the Wallowa-Whitman National Forest.....115

Table 21-Potential vegetation groups on the Wallowa-Whitman National Forest’s 2.3 million acres and 

their susceptibility to invasive plants................................................................................................116

Table 22-Regional sensitive plant species for the Wallowa-Whitman National Forest ...........................118

Table 23-Hells Canyon National Recreation Area - Threatened, Endangered or Proposed; Candidate, 

Sensitive, Endemic and Disjunct Species .........................................................................................120

Table 24-Invasive plant species treatment acres comparison between the No Action Alternative, Proposed 

Action Alternative, and additional action alternatives......................................................................131

Table 25-Number of SOLI within 100 feet of an invasive plant species site and proposed treatment by 

alternative..........................................................................................................................................132

Table 26-Existing Vegetation Types In Proposed Aerial Treatment Sites ...............................................136

Table 27-Invasive weeds located adjacent to National Forest System land .............................................144

Table 28-SOLI determination statements by Alternative .........................................................................146

Table 29-Federally listed or candidate species known to occur on the Wallowa-Whitman National Forest

..........................................................................................................................................................153

Table 30-Lynx Habitat types and acres of invasive plants .......................................................................154

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Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

Table 31-Suspected (S) or Documented (D) Wildlife of the Wallowa-Whitman NF on the Regional 

Forester’s Sensitive Species List (July 2004)....................................................................................155

Table 32-Bighorn sheep locations and the approximate number of acres of invasive plants....................159

Table 33-Management Indicator Species and their associated habitat for the Wallowa-Whitman NF.....171

Table 34-Elk Habitat affected by invasive plants......................................................................................172

Table 35-Priority and Unique Habitats on the Forest and the associated Focal Species...........................175

Table 36-Treatment methods by alternative..............................................................................................177

Table 37-Wildlife Determination Summary..............................................................................................195

Table 38-Water quality impaired streams within the Wallowa-Whitman National Forest on the Oregon or 

Idaho 303(d) list that have invasive plant sites within 100 feet of the stream...................................254

Table 39-Invasive Plant Acres within 100 feet of lakes and reservoirs ....................................................257

Table 40-Infested acres proposed for treatment by watershed ..................................................................258

Table 41-Herbicide Properties...................................................................................................................262

Table 42-Potential surface erosion for 2 year storm with groundcover at 10, 30 and 50 percent .............265

Table 43-Acres proposed for treatment by location and method by alternative........................................269

Table 44-Drift distance versus drop diameter ...........................................................................................277

Table 45-Potential herbicide concentrations in water for different precipitation ranges and soil types....284

Table 46-Parameters used for model by location ......................................................................................287

Table 47-GLEAMS-Driver Model results for aerial sites .........................................................................287

Table 48-Concentrations of herbicide in a small stream with a 300 foot buffer .......................................288

Table 49-Concentrations of herbicide with additional buffer widths........................................................289

Table 50-Additions to buffer widths under specified conditions (PDF-8) ................................................289

Table 51-Watersheds with largest percent of proposed treatments...........................................................291

Table 52-Fifth-field watersheds proposed for treatment in the Wallowa-Whitman National Forest........294

Table 53-Threatened, Endangered and Proposed fish species, and critical habitat...................................298

Table 54-Sensitive Species........................................................................................................................298

Table 55-Toxicity Indices for Listed Fish .................................................................................................319

Table 56-Hazard quotient values for acute exposure estimates for sensitive aquatic organisms broadcast 

spray scenarios ..................................................................................................................................321

Table 57-Potential herbicide concentrations in water for diverse precipitation ranges and soil types......330

Table 58-Herbicide treatment areas within 100 feet of streams with listed fish .......................................332

Table 59-MPI for Primary Constituent Elements Crosswalk....................................................................343

Table 60-Effects Determination for Herbicide Treatment, Non-Herbicide Treatment and EDRR...........350

Table 61-Potential effects to commercially important fish species under the proposed action ................356

Table 62-Wilderness areas and acres of invasive plants ...........................................................................359

Table 63-Wild and Scenic Rivers on the W-W National Forest and their outstandingly remarkable values

...........................................................................................................................................................360

Table 64-Wild and Scenic Rivers, designation, and acres of invasive plants ...........................................363

Table 65-Ranger District, Developed Recreation Site Name, and Acres of Proposed Treatments...........364

Table 66-Acres of invasive plants by recreation area................................................................................366

Table 67-Acres of proposed treatments in HCNRA..................................................................................369

Table 68-Acres of proposed treatment by wilderness ...............................................................................370

Table 69-Aerial application information for Hells Canyon Wilderness....................................................371

Table 70-Acres of proposed treatments by WSR name and designation ..................................................375

Table 71-Acres of proposed treatment by ranger district and site name ...................................................378

Table 72-Acres of proposed treatment by recreation area.........................................................................382

Table 73-Herbicides and potential effectiveness.......................................................................................387

Table 74-Invasive weed acres presently identified within each allotment type ........................................392

Table 75-Invasive species acres in Wallowa-Whitman National Forest grazing allotments ....................394

Table 76-Range improvements and fencelines with potential for invasive species spread on the WallowaWhitman National Forest ..................................................................................................................395

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Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

Table 77-Cumulative Effects on Grazing and Range Management within the project area.....................400

Table 78-Cost per acre of invasive species treatment methods (All costs are in 2006 dollars)................402

Table 79-Analysis Area Population by County, 2000 Census..................................................................403

Table 80-Race and Ethnicity by County, 2000 Census.............................................................................403

Table 81-Analysis Area Population below Poverty Level by Race, 2000 Census ...................................404

Table 82-Alternative A Estimated Acres by Treatment Method ..............................................................406

Table 83-Discounted costs and years to contain or control of forest-wide infestations under Alternative A 

in 2006 dollars (Shaded line represents the projected annual treatment level).................................408

Table 84-Summary of Effects by Alternative ...........................................................................................416

Table of Figures 

Figure 1 – Example Map of Proposed Invasive Plant Treatments..............................................................23

Figure 2 – Proposed invasive plant treatments for Baker Ranger District..................................................28

Figure 3 – Proposed invasive plant treatments for Wallowa Valley Ranger District .................................29

Figure 4 – Proposed invasive plant treatments for HCNRA.......................................................................30

Figure 5 – Proposed invasive plant treatments for Eagle Cap Ranger District...........................................31

Figure 6 – Proposed invasive plant treatments for La Grande Ranger District ..........................................32

Figure 7 – Proposed invasive plant treatments for Pine Ranger District ....................................................33

Figure 8 – Proposed invasive plant treatments for Unity Ranger Station...................................................34

Figure 9 – Proposed herbicide aerial application invasive plants treatments .............................................35

Figure 10 – Potential percent of acres available for use per herbicide .......................................................50

Figure 11 – Illustration of how herbicide selection and application methods in the established buffer 

widths are more limited in Aquatic Influence Zones..........................................................................72

Figure 12 – EDRR Herbicide Use Decision Tree Process..........................................................................74

Figure 13 – Acres of invasive plants over time-treatment effectiveness ....................................................83

Figure 14 – Aerial application ....................................................................................................................98

Figure 15 – Droplet size and drift distance .................................................................................................99

Figure 16 – Comparsion of estimated invasive plant spread between Alternatives A and B ...................107

Figure 17 – Starthistle on inaccessible site ...............................................................................................108

Figure 18 – Proposed Aerial site otherwise inaccessible..........................................................................136

Figure 19 – Example of spot treatment areas within RHCA, and broadcast treatment areas for diffuse 

knapweed on the Wallowa-Whitman National Forest. .....................................................................138

Figure 20 – Contract worker spraying invasive plants in wilderness from a horsepack-mounted spray 

system ...............................................................................................................................................372

x
Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

xi 

Volume II-Appendices 

Appendix A – Forest Plan 

Appendix B – Botany Resources 

Appendix C – Wildlife Resources 

Appendix D – Soil and Water Resources 

Appendix E – Aquatic Resources 

Appendix F – Aerial Guidelines 

Appendix G – Adjuvants and Surfactants 

Appendix H – Social/Economics 
Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

List of Acronyms 

APHIS Animal and Plant Health Inspection Service 

ATV All terrain vehicle 

BA Biological Assessment 

BE Biological Evaluation 

BECA Bald Eagle Consideration Area 

BEMA Bald Eagle Management Area 

BLM Bureau of Land Management 

BO Biological Opinion 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CWA Clean Water Act 

DEIS Draft Environmental Impact Statement 

DN Decision Notice 

DO Dissolved oxygen 

DPS Distinct Population Segments 

EA Environmental Assessment 

EEC Expected exposure concentration 

EDRR Early detection rapid response 

EFH Essential fish habitat 

EIS Environmental Impact Statement 

EPA Environmental Protection Agency 

ESA Endangered Species Act 

ESU Ecologically Sustainable Unit 

FDA Food and Drug Administration 

FEIS Final Environmental Impact Statement 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

FOSS Federal OSHA Safety Standard 

FS Forest Service 

FSH Forest Service Handbook 

FSM Forest Service Manual 

FWS United States Fish and Wildlife Service 

GIS Geographical Information System 

GLEAMS Groundwater Loading Affects of Agricultural Management Systems 

GPS Global positioning system 

HQ Hazard quotient 

HUC Hydrologic Unit Codes 

ICBEMP Interior Columbia Basin Ecosystem Management Project 

IDT Interdisciplinary Team 

INFISH Inland Native Fish Strategy 

IWM Integrated weed management 

LAU Lynx analysis units 

LCAS Lynx Conservation Assessment and Strategy 

LOAEL Lowest observed adverse effect level 

LOC Level of concern 

LOP Limited operating period 

LRMP Land and Resources Management Plan 

LWD Large Woody Debris 

LWM Large woody material 

MIG Minnesota IMPLAN Group 

MIS Management Indicator Species 

MPI Matrix of Pathways and Indicators 

MSA Magnuson Stevens Act 

NEPA National Environmental Policy Act 

NF National Forest 

NFMA National Forest Management Act 

NFS National Forest System 

NMFS National Marine Fisheries Service 

xii
Wallowa-Whitman Invasive Plants Treatment Project Draft Environmental Impact Statement 

xiii 

NOA Notice of Availability 

NOAEL No observed adverse effect level 

NOEC No observable effect concentration 

NOI Notice of Intent 

NPE Nonylphenol Polyethoxylate 

NVUM National Visitors Use Monitoring 

ODA Oregon Department of Agriculture 

ODEQ Oregon Department of Environmental Quality 

ODFW Oregon Department of Fish and Wildlife 

OHV Off-highway vehicles 

OR Oregon 

ORV Off-road vehicles 

PA Proposed Action 

PACFISH Pacific Native Fish Strategy 

PCE Primary Constituent Elements 

PDF Project design feature 

PETS Proposed Endangered Threatened and Sensitive 

PNV Present Net Value 

PNW Pacific Northwest 

POEA Polyoxyethylene alkylamine 

PVG Potential vegetation groups 

R6 Forest Service Region Six 

RHCA Riparian Habitat Conservation Area 

RM River mile 

RMO Riparian management objective 

ROD Record of Decision 

SERA Syracuse Environmental Research Associates, Inc 

SOLI Species of local interest 

SRI Soils Resource Inventory 

TAC Technical Advisory Committee 

TCP trichloro-2-pyridinol 

TDS Total dissolved solids 

TES Threatened, Endangered and Sensitive 

TMDL Total maximum daily load 

TNC The Nature Conservancy 

USDA United States Department of Agriculture 

USDI United States Department of Interior 

USFS United States Forest Service 

USGS United States Geological Survey 

WDFW Washington Department of Fish and Wildlife 

WSDOA Washington State Department of Agriculture 

WQMP Water Quality Management Plan 

WSR Wild and Scenic River 

Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 1 

1 

Chapter 1 – Purpose and Need for Action 

1.1 Background 

The Wallowa-Whitman National Forest, (see Vicinity Map above) located in the northeast corner 

of Oregon and west central edge of Idaho, covers 2.3 million acres. It lies within Wallowa, 

Union, Baker, Malheur, Umatilla, and Grant Counties in Oregon and Adams, and Nez Perce 

Counties in Idaho. The Forest ranges in elevation from 875 feet on the Snake River in the bottom 

of the Hells Canyon National Recreation Area to 9,845 feet in the Eagle Cap Wilderness of the 

Blue Mountains. The Forest is the largest administrative unit in the Pacific Northwest Region. 

Until recently the Forest was composed of seven ranger districts including the Hells Canyon 

National Recreation Area (HCNRA). Presently, the Baker, Unity and Pine Districts have been 

combined and are now known as the Whitman Ranger District. This document, including Table 1 

below, does not reflect this change. However, the information and project presented in this EIS is 

still considered accurate and valid; even though the program of invasive plants treatment will be 

carried out by five instead of seven administrative districts. 

The Wallowa-Whitman National Forest proposes to protect native vegetation by controling, 

containing, or eradicating invasive plants across the Forest. Nearly 23,000 acres of invasive plant 

infestations have been identified and mapped. Invasive plants are defined as “non-native plants 

whose introduction do or are likely to cause economic or environmental harm or harm to human 

health” (Executive Order13122). Dale Bosworth (then Chief of the Forest Service), declared 

invasive species as one the four main threats to ecosystem health (USDA Forest Service 2003). 

Invasive plants have the potential to displace or alter native plant communities and cause longlasting economic and ecological problems within and outside the National Forests. Invasive 

plants can increase fire hazards, degrade fish and wildlife habitat, eliminate rare and endangered 

plants, impair water quality and watershed health, and adversely affect a wide variety of other 

resource values such as scenic beauty and recreational opportunities. Their strong reproductive 

and competitive abilities and a lack of natural predators allow invasive plants to spread rapidly 

across the landscape to noninfested areas, unimpeded by ownership or administrative 

boundaries. 

An extensive inventory of invasive plant sites was completed by the Wallowa-Whitman National 

Forest in 2006. The inventory, conducted district by district, mapped sites of known invasive 

plant infestations listed in Tables 1 and 2. This inventory is a compilation that includes an 

inventory completed in 1990, an update of that inventory done for the 1992 and 1994 noxious 

weed EAs, the districts’ annual inventories since then, and a recent inventory effort to complete a 

data base of all known invasive plant sites. At present, 40 different invasive plant species are 

known to occur within the boundaries of the Forest. Species of greatest concern include common 

bugloss, knapweed, yellow star thistle, dalmation toadflax, common cuprina, Mediterranean 

sage, leafy spurge, yellow hawkweed, and rush skeleton-weed. Our ability to prevent or 

minimize the adverse impacts to native plant communities by these and other invasive plants is 

greatest if populations can be treated while they are small and in the early stages of invasion. 

Many of our current infestations occupy small areas, less than an acre. Probability of successful 

treatment is greater for small or new invasive populations and can be controlled at lower costs 

than once the infestation becomes large. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Table 1-Number of Invasive Plant sites by species identified by District on the Wallowa-Whitman NF 

Number of Invasive Plant Sites by Districts 

Scientific Name Common Name 

Baker Wallowa- Valley HCNRA Eagle Cap LaGrande Pine 

 Acroptilon repens Russian knapweed 1 3  Alopecurus myosuroides Blackgrass or slender 

meadow foxtail 1 

 Anchusa officionalis Common bugloss 1  Cardaria draba Hoarycress (Whitetop) 10 1 84 21 4 Carduus nutans Musk thistle 3  Centaurea diffusa Diffuse knapweed 23 128 47 16 108 2Centaurea maculosa Spotted knapweed 16 73 39 9 16 Centaurea species Knapweed species 1 17 1 1 Centaurea debeauxii Meadow knapweed 1 Centaurea solstitialis Yellow star thistle 3 12 136 28 Centaurea virgata Squarrose knapweed 2  Chondrilla juncea Rush skeleton-weed 34  Cirsium arvense Canada thistle 24 4 18 6 40 1 Cirsium vulgare Bull thistle 2  Convvolvulus arvensis Field bindweed  Conium maculatum Poison hemlock 2  Crupina vulgaris Common crupina 1  Cuscuta sp. Dodder 1 Cynoglossum officinale Houndstongue 13 1 1 Cytisus scoparius Scotch broom 1 1 2  Dipsacus fullonum Teasel 1  Euphorbia esula Leafy spurge 1 1 1 7 Polygonum cuspidatum Japanese knotweed 2  Hieracium caespitosum Yellow hawkweed 1 4 24  Hypericum perforatum St john's wort 32 4 1 Lepidium latifolium Pepperweed  Linaria dalmatica Dalmation toadlfax 8 60 18 1 4  Linaria sp. Toadflax species 3 2
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Number of Invasive Plant Sites by Districts 

Scientific Name Common Name 

Baker Wallowa- Valley HCNRA Eagle Cap LaGrande Pine 

 Linaria vulgaris Yellow toadflax 2 2 1  Lythrum salicaria Purple loosestrife 3  Onopordum acanthium Scotch thistle 12 37 95 5  Potentilla recta Sulphur cinquefoil 12 1 3 1Rubus discolor Himalayan blackberry 3 Salvia aethiopis and Salvia sclarea 

Mediterrenean and clary sage 

1 

 Salsola tragus Russian thistle  Senecio jacobaea Tansy ragwort 1 2 1 1 36  Senecio sp. Senecio species 3 1  Solanum elaeagnifolium silverleaf nightshade 2  Taeniatherum caputmedusae Medusahead 21  Tribulus terrestris Puncturevine 1 Totals 40 Species 163 347 525 58 277 15Table 2-Acres of invasive plants by species and district 

Acres of Invasive Plant Species by District Invasive plant 

species Baker Wallowa- Valley HCNRA Eagle Cap LaGrande Pine Unity Ac

(gro

Russian knapweed 21 5 Blackgrass or slender meadow foxtail* 0 Common bugloss* 5813 Hoarycress-White-top 104 15 556 88 476 250 Musk thistle* 2 26 Diffuse knapweed** 420 827 433 707 888 337 538 Spotted knapweed* 76 212 417 35 32 11 124 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Acres of Invasive Plant Species by District Invasive plant 

species Wallowa- Ac

Baker HCNRA Eagle Cap LaGrande Pine Unity Valley (gro

Knapweed species* 35 38 2 2 31 10 Meadow knapweed* Yellow starthistle** 10 97 868 419 572 Squarrose knapweed* 7 Rush skeleton weed* 375 15 Canada thistle 471 200 738 128 462 168 1227 Bull thistle 22 Field bindweed 3 Poison hemlock 7 1 Common crupina* 284 Dodder 7 2 Houndstongue 211 40 407 322 Scotch broom* 115 Teasel 22 8 Leafy spurge* 52 1 1 22 27 Yellow hawkweed* 7 9 St john's wort 259 213 100 32 Pepperweed* 1 Dalmation toadflax* 78 192 15 3 2 137 302 Toadflax species 4 Yellow toadflax 35 2 8 6 Purple loosestrife* 3 Scotch thistle 89 427 1194 17 21 97 Japanese knotweed* 78 Sulphur cinquefoil 81 0 10 96 Himalayan blackberry 15 Mediterranean and clary sage** 22 Russian thistle 10 Tansy ragwort 3 2 1 1 7 64 Senecio species 4 4 4
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Acres of Invasive Plant Species by District Invasive plant 

species Baker Wallowa- Valley HCNRA Eagle Cap LaGrande Pine Unity Ac

(gro

Silverleaf nightshade* 11 Medusahead 6 915 Puncturevine 12 Total 1974 2416 10811 883 2013 3309 3027 22* = Ranked as priority species 1 across all districts, ** = 85% of districts ranked as priority species 1, *** 71% of districts ranked as priority species 1. 

1Estimates of total infested acreages represent 55% for whitetop and hawkweed and 25% for all other species, common bugloss site estimated at 1,500 

2Total includes multiple species occurring on the same site; therefore acres reported here are larger than 22,842 acres infested. Rows may not add up to error.
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

The Pacific Northwest Region published the programmatic Pacific Northwest Region Invasive 

Plant Program Preventing and Managing Invasive Plants FEIS (USDA Forest Service 2005a), 

April 2005 along with its accompanying Record of Decision for Invasive Plant Program 

Management (USDA Forest Service 2005b) on October 11, 2005. This decision amended all 

Forest Plans in the Region, adding new direction for containing, controlling or eradicating 

invasive plant species using prevention practices, various mechanical and hand treatments, and 

chemical treatments. This decision allowed for the use of chemicals from an updated list of 

herbicides for effectively responding to invasive plant threats. The new herbicides offer many 

advantages over the more limited set of herbicides allowed previously, including greater 

selectivity, less harm to desired vegetation, reduced application rates, and lower toxicity to 

animals and people. The R6 2005 ROD and R6 2005 FEIS require that prior to the use of these 

new herbicides, site-specific treatment prescriptions for both new and previously analyzed 

invasive plant sites on the Forest need to be developed based on the updated herbicide tools and 

management direction. 

This EIS will focus on developing these treatment methods including the use of herbicides aimed 

at containing, controlling, or eradicating, invasive plants, and the effects of such treatments on the 

forest landscape and human environment. 

The Wallowa-Whitman National Forest has been treating invasive plants according to direction in 

the Wallowa-Whitman National Forest Environmental Assessment for the Management of 

Noxious Weeds and Forest Plan Amendment 4 (USDA Forest Service 1992) and the WallowaWhitman Management of Noxious Weeds Environmental Assessment (USDA Forest Service 

1994a ). The two EAs identified approximately 5,000 acres for treatment of 21 invasive plant 

species. These documents did not allow the Forest Service the ability to respond quickly to new 

infestations because the process only covered those sites known at that time. The two EAs 

authorized the use of four herbicides; however, one of these, dicamba, is restricted from use in 

Region 6 by the R6 2005 ROD. 

Monitoring has shown a substantial increase in invasive plant populations (USDA Forest Service 

2002). The Forest treated approximately 7,200 acres between 1997 and 2001 (USDA Forest 

Service 2004a). Though some of the initial invasive plant sites identified in the 1992 and 1994 

EAs have been successfully contained or controlled, many new sites have been identified and 

some existing sites have grown. The strategy has been labor intensive sometimes requiring 

multiple visits to sites each year, and the budget was not always adequate to extensively control 

or eradicate target infestations. The limited funds were used to control weeds along major Forest 

System roads, providing funds to cooperative weed management areas for treatment and 

monitoring. The Wallowa-Whitman National Forest has completed limited invasive plant 

treatments after fire disturbance using the Burned Area Emergency Rehabilitation (BAER) 

authority. Complete information about these treatments is available in the project record. The 

documented expansion of many infestations and identification of new invasive plant species has 

established the overall ineffectiveness of treatments under the two EAs. 

Thus, the purpose of the Proposed Action is to (1) treat and restore desirable vegetation in areas 

known to contain invasive plants, and (2) treat new infestations. This EIS analyzes the effects of a 

project proposal that would achieve those two purposes in a manner consistent with the LRMP. 

 

6
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 1 

1.2 Desired Future Conditions

Maintain or improve the diversity, function, and sustainability of desired native plant 

communities and other natural resources that can be adversely impacted by invasive plant species. 

Containment, control, or eradication strategies are applied to invasive plant infestations using 

rapid, comprehensive and effective methods for invasive plant management. 

The Forest is able to (1) implement treatment actions to contain and reduce the extent of invasive 

plants at existing inventoried sites, and (2) rapidly responds to new or expanded invasive plant 

sites as they may occur in the future. 

By treating infested areas, the spread of invasive plants onto neighboring lands is reduced or 

eliminated. The new direction in the LRMP as amended by the R6 2005 ROD allows effective 

treatments that reduce the need for repeated herbicide use and ultimately reduces reliance on 

herbicides. 

1.3 Purpose and Need 

Invasive plants pose one of the greatest ecological threats to public lands in the United States. 

Sizeable infestations can displace or alter native plant communities and cause long-lasting 

economic and ecological problems within and outside the National Forests. Weeds can spread 

rapidly across the landscape to noninfested areas, unimpeded by ownership or administrative 

boundaries, because of their strong reproductive and competitive abilities. 

Invasive plants can and do occur almost anywhere on the landscape. Common sites of infestations 

include rangelands, timber harvest areas, along roads and road rights-of-way (including 

decommissioned roads), along trail routes, at dispersed and developed recreation sites, wilderness 

areas, national recreation areas and on other disturbed sites (i.e. fires, flood events, and rock 

quarries). These invasive plants will likely continue to expand and spread every year that 

effective treatment is not applied. At some point, individual populations of invasive plants can get 

so large as to be impossible to eradicate or cost-effectively control. Botanical species of local 

interest are threatened by invasive plants at approximately 80 infested sites. Fish habitat quality is 

being degraded by invasive plants in over 5,000 acres of riparian areas. Tribal resources and 

subsistence gathering can be degraded by the invasive plants. Range land quality is being 

degraded. Wildlife habitat quality can be adversely affected as invasive plants out compete native 

plant species. Roadless, wilderness, wild and scenic rivers, research natural areas and botanical 

areas are all high priority areas for treatment due to the value of the resources at risk from 

invasive plants. 

Thus, there is a need to contain, control or eradicate nearly 23,000 acres of invasive plant 

infestations that have been inventoried and mapped on the Wallowa-Whitman National Forest. 

Further, there is a need to treat new infestations (including new species) soon after they are 

detected on the landscape so they can be controlled while they are still small. The current 

management direction does not allow for a full range of effective treatments because 1) only 20 

percent of the current infested area may be treated with herbicides and 2) the three herbicides 

available are not effective treatment for the entire invasive plants resident on the Forest. 

This EIS is being prepared to allow the Wallowa-Whitman National Forest to control invasive 

plant species across the Forest using Forest Plan direction as amended by the R6 2005 ROD. The 

purpose of the project is to bring the treatment program into compliance with the new standards 

and allow for effective treatments on all sites currently known, and those that may be detected 

7 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

during the life of the project. Initial treatments will rely heavily on herbicides, but the goal of this 

project is to eventually, as invasive plant objectives are met, reduce the use of herbicides. 

Invasive plant control is needed to maintain or improve the diversity, function, and sustainability 

of desired native plant communities and other natural resources that can be adversely impacted by 

invasive plant species. Specifically, there is an underlying need on the Forest to: (1) implement 

treatment actions and site restoration to contain, control and eradicate the extent of invasive 

plants at existing inventoried sites, and (2) rapidly respond to new or expanded invasive plant 

sites as they are detected in the future. Without action, invasive plant populations will become 

increasingly difficult and costly to control and will further degrade forest and grassland 

ecosystems. Untreated infested areas will also contribute to the spread of invasive plants onto 

neighboring lands. 

1.4 Proposed Action 

Invasive plants would be contained, controlled, or eradicated by using a variety of chemical, 

physical, biological, and cultural treatment methods. Treatments are proposed for existing 

infestations based on Common Control Measures, which include a range of effective treatments 

known for each target species detected in a 2006 inventory. About 23,000 acres are proposed for 

treatment. 

The Proposed Action would approve about 875 acres of aerial herbicide application, about 16,600 

acres of ground based applications, and about 3,200 acres of spot spraying and selective (wicking, 

wiping, stem injection) herbicide application on sites mapped in the 2006 inventory. Herbicide 

application method is based on the extent, location, type and character of an infestation. 

Herbicide application method is limited by Project Design Features that do not allow broadcast in 

certain situations (for instance immediately adjacent to streams). Herbicide application would be 

approved on about 21,000 acres; however, other non-herbicide methods could also be used in 

combination with herbicides. The priority species would vary by District and could change at a 

later time. About 2,000 acres currently are proposed for treatments that do not include 

herbicides. Cultural treatments such as competitive seeding with native grass and forbs species 

(also mulching, fertilizing) would occur in combination with other treatments as needed to 

facilitate natural plant recovery. 

In addition, the Proposed Action would approve treatment of new detections with methods and 

limitations outlined in Chapter 2. Early Detection/Rapid Response (EDRR) is proposed to 

increase effectiveness and decrease risks from treatment. New sites or species would be treated 

as part of the Forest’s annual program as long as the type of effective treatment needed for the 

new site is covered in the methods shown in Chapter 2. The Project Design Features provide 

layers of caution relative to herbicide use, including annual acreage caps, which would be applied 

to new and known sites to ensure adverse effects are minimized. 

Treatment priority is based on the historic investments made to control the species, its invasive 

nature, its location and whether it is a new species on the Forest. New species of invasive plant or 

a new invasive plant infestation may demand an immediate response using Early Detection, 

Rapid Response strategy. Proposed methods and strategies detailing how invasive plant 

infestations would be treated are in Chapter 2. 

8
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 1 

1.5 Management Direction 

This EIS process and documentation has been completed according to direction contained in the 

National Forest Management Act (NFMA), the National Environmental Policy Act (NEPA), and 

the Council on Environmental Quality regulations, Clean Water Act, and the Endangered Species 

Act. The project is consistent with all applicable Federal, State and local laws. This EIS tiers to 

the Wallowa-Whitman National Forest Land and Resource Management Plan Final 

Environmental Impact Statement and Record of Decision (USDA Forest Service 1990) and 

incorporates by reference the accompanying Land and Resource Management Plan (LRMP, also 

called the Forest Plan) (USDA Forest Service 1990), as amended by the Pacific Fish Strategy 

(PACFISH) (USDA and USDI 1995) and Inland Native Fish Strategy (INFISH) (USDA Forest 

Service 1995) where appropriate, and the R6 2005 FEIS and ROD. 

Pacific Fish Strategy (PACFISH) and Inland Native Fish Strategy (INFISH) amended the 

Wallowa-Whitman National Forest Plan in 1995 (USDA 1995). These documents established 

stream, wetland and landslide-prone area protection zones called Riparian Habitat Conservation 

Areas (RHCAs), setting standards and guidelines for managing activities that potentially affect 

conditions within the RHCAs. They also established Riparian Management Objectives (RMOs) 

that provide guidance with respect to key habitat variables. See Appendix B for a listing of the 

specific INFISH aquatic conservation strategies adopted into the Wallowa-Whitman Forest Plan. 

The Federal Noxious Weed Act of 1974, as amended (7 U.S.C 2801 et seq.) requires cooperation 

with State, local, and other Federal agencies in the application and enforcement of all laws and 

regulations relating to management and control of noxious weeds (a summary of this Act can be 

viewed at: http://ipl.unm.edu/cwl/fedbook/fedweed.html ). This Act directs the Secretary of 

Agriculture to develop and coordinate a management program for control of undesirable plants 

which are noxious, harmful, injurious, poisonous, or toxic on Federal lands under the agency’s 

jurisdiction, to establish and adequately fund the program, to complete and implement 

cooperative agreements and/or memorandums, and to establish Integrated Weed Management to 

control or contain species identified and targeted under cooperative agreements and/or 

memorandums. 

U.S. Forest Service Manual 2080 directs the Forest Service to use an integrated weed 

management approach to control and contain the spread of noxious weeds on National Forest 

System (NFS) lands and from NFS lands to adjacent lands (USDA Forest Service 1995b). 

Integrated weed management is an interdisciplinary pest management approach by which one 

selects and applies a combination of management techniques that, together, control a particular 

invasive plant species or infestation efficiently and effectively, with minimum adverse impacts to 

non-target organisms. Integrated weed management is typically species- and site-specific, and 

includes education, preventive measures, early detection of infestations through inventory and 

mapping, and combinations of treatment methods as needed to effectively control the target 

species. Forest Service Handbook (FSH) 2109.14 Pesticide Use and Coordination provides 

additional direction related to implementation of invasive plant management, and FSM 2150 

Pesticide Use and Coordination provide policy direction. 

Executive Order 13112 directs federal agencies to reduce the spread of invasive plants. Invasive 

species have been identified by the current Chief of the Forest Service as one of the four threats to 

ecosystem health. 

The Forest Service Guide to Noxious Weed Prevention Practices (USDA Forest Service 2001b) 

provides management guidance in the form of goals along with prevention practices. Forest 

9 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Service policy identifies prevention of the introduction and establishment of noxious weed 

infestations as an agency objective. This Guide provides a comprehensive directory of weed 

prevention practices for use in Forest Service planning and wildland resource management 

activities and operations. 

In October 2004, the Chief of the Forest Service released National Strategy and Implementation 

Plan for Invasive Plant Species Management (USDA Forest Service 2004c). It focuses on four 

key elements: preventing invasive species before they arrive; finding new infestations before they 

spread and become established; containing and reducing existing infestations; and rehabilitating 

and restoring native habitats and ecosystems. 

1.5.1 Regional Direction 

Up until recently, Forests in Region Six followed management direction introduced to all Land 

and Resource Management Plans in Region Six by the Record of Decision for Managing 

Competing and Unwanted Vegetation (USDA Forest Service 1988), and the subsequent Mediated 

Agreement (USDA Forest Service 1989). The 1988 ROD specified and limited the tools available 

for the treatment of competing and unwanted vegetation, but did not provide administrative 

mechanisms for adapting new technologies. Herbicides approved for use by the Forest Service at 

that time were developed before 1980. 

The Pacific Northwest Region Invasive Plant Program – Preventing and Managing Invasive 

Plants Record of Decision (USDA 2005b) supersedes direction from those documents to provide 

invasive plant management direction to Forests in Region Six. 

This EIS tiers to the R6 2005 FEIS for invasive plant treatments on the Wallowa-Whitman 

National Forest. The R6 2005 ROD added goals, objectives and standards for invasive plant 

management to the Wallowa-Whitman National Forest LRMP (See Forest Direction section) and 

replaces the requirements of the Mediated Agreement (1989) dealing with the treatment of 

invasive plants. All other vegetation management activities on the Forest will still be bound by 

the Mediated Agreement. 

1.5.2 Forest Direction 

Current management direction for the treatment of invasive plants on the Wallowa-Whitman 

National Forest is derived from the following sources: 

• The Wallowa-Whitman National Forest Land and Resource Management Plan (USDA Forest 

Service 1990) as amended by the R6 2005 ROD 

• The Wallowa-Whitman National Forest Environmental Assessment for the Management of 

Noxious Weeds and Forest Plan Amendment 4 (USDA Forest Service 1992) 

• The Wallowa-Whitman Management of Noxious Weeds Environmental Assessment (USDA 

Forest Service 1994a). 

The best available science is considered in the preparation of this EIS. However, what constitutes 

best available science might vary over time and across scientific disciplines as new science is 

brought into play. We show consideration of best available science when we insure the scientific 

integrity of the discussions and analyses in the project NEPA document. Specifically, this EIS and 

the accompanying Project Record identifies methods used, references reliable scientific sources, 

discusses responsible opposing views, and discloses incomplete and unavailable information, 

scientific uncertainty and risk (see 40 CFR 1502.9 (b), 1502.22, 1502.24). 

10
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 1 

The Project Record references all scientific information considered: papers, reports, literature 

reviews, review citations, academic peer reviews, science consistency reviews, and results of 

ground-based observations to validate best available science. In addition, this EIS incorporates (as 

per 40 CFR 1502.21) the Project Record including specialist reports and other technical 

documentation used to support the analyses and conclusions of this EIS. 

Analysis was completed for botany, hydrology, fisheries, soils, wildlife, cost effectiveness, and 

human health. Information from these reports has been summarized in Chapters 3. Separate 

biological evaluations and/or biological assessments were completed for botanical species, 

aquatic species, and terrestrial wildlife species for this analysis or as part of the consultation 

process with the National Marine Fisheries Service and the US Fish & Wildlife Service. 

Specific standards from the existing Wallowa-Whitman National Forest LRMP (Forest Plan) as 

amended by the R6 2005 ROD that apply to invasive plants treatment can be reviewed in 

Appendix A. Specific goals and objectives for invasive plants treatment added to the Forest Plan 

by the R6 2005 ROD are listed below (not all objectives within these goals relate directly to this 

project, so have been omitted). 

Goal 1 - Protect ecosystems from the impacts of invasive plants through an integrated approach 

that emphasizes prevention, early detection, and early treatment. All employees and users of the 

National Forest recognize that they play an important role in preventing and detecting invasive 

plants. 

Objective 1.4 Use an integrated approach to treating areas infested with invasive plants. Utilize 

a combination of available tools including manual, cultural, mechanical, herbicides, and 

biological control. 

Objective 1.5 Control new invasive plant infestations promptly, suppress or contain expansion 

of infestations where control is not practical, conduct follow up inspection of treated sites to 

prevent reestablishment. 

Goal 3 - Protect the health of people who work, visit, or live in or near National Forests, while 

effectively treating invasive plants. Identify, avoid, or mitigate potential human health effects 

from invasive plants and treatments. 

Objective 3.1 Avoid or minimize public exposure to herbicides, fertilizer, and smoke 

Objective 3.2 Reduce reliance on herbicide use over time in Region 6 

Goal 4 – Implement invasive plant treatment strategies that protect sensitive ecosystem 

components, and maintain biological diversity and function within ecosystems. Reduce loss or 

degradation of native habitat from invasive plants while minimizing adverse effects from 

treatment projects. 

Objective 4.1 Maintain water quality while implementing invasive plant treatments 

Objective 4.2 Protect non-target plants and animals from negative effects of both invasive 

plants and applied herbicides. Where herbicide treatment of invasive plants is necessary within 

the riparian zone, select treatment methods and chemicals so that herbicide application is 

consistent with riparian management direction contained in PACFISH, INFISH, and the Aquatic 

Conservation Strategies of the Northwest Forest Plan 

11 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Objective 4.3 Protect threatened, endangered, and sensitive species habitat threatened by 

invasive plants. Design treatment projects to protect threatened, endangered, and sensitive 

species and maintain species viability. 

1.6 Decision Framework 

The Responsible Official is the Wallowa-Whitman National Forest Supervisor, who will make the 

following decisions based on the interdisciplinary analysis: 

• Whether to select the proposed invasive plant treatments with any modifications from public 

scoping or comments or as described in an alternative 

• Which project design features are needed 

• What monitoring is required 

The Forest Supervisor will base the decision on how well the alternative meets the purpose and 

need for action, as indicated by: 

• Whether the alternative includes treatment of newly discovered infestations 

• Percentage of known treatment landbase where all effective treatments are available 

• Treatment cost and efficiency 

• The degree to which the alternative minimizes potential adverse impacts to human health and 

the environment, based on issue indicators shown below. 

• Whether the alternative will reduce herbicide use over time 

1.7 Tribal Involvement 

1.7.1 Introduction 

The proposed invasive plant treatment occurs within areas ceded to the United States government 

from the following recognized Tribes: the Confederated Tribes of the Umatilla Indian 

Reservation (CTUIR) by the TREATY WITH THE WALLA WALLA, CAYUSE, ETC., 1855; 

The Nez Perce Tribe by the TREATY WITH THE NEZ PERCE, 1855; and the Confederated 

Tribes of the Warm Springs Reservation in the TREATY WITH THE TRIBES OF MIDDLE 

OREGON, 1855. The Forest Service, through the Secretary of Agriculture, is vested with 

statutory authority and responsibility for managing the resources of the National Forests. No 

sharing of administrative or management decision-making power is held with any other entity. 

However, commensurate with authority and responsibility to manage is the obligation to consult, 

coordinate and cooperate with recognized Indian tribes in developing and planning management 

decisions for resources of National Forest System (NFS) lands that may affect tribal rights 

established by treaty or Executive Order. As a result of the treaties and Executive Orders, 

elements of Indian culture, such as tribal welfare, land, and resources were entrusted to the United 

States Government. 

The Forest Services shares in the government’s overall trust responsibility where treaty, laws, 

Executive Orders, case law or other legally defined rights apply to National Forest System (NFS) 

lands. Trust responsibilities resulting from treaties or Executive Orders dictate, in part that the 

United States Government facilitates the execution of treaty rights and traditional cultural 

practices of recognized tribes. The Forest Service assists with this shared responsibility by 

working with the tribes on a government to government basis and in a manner that attempts a 

12
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 1 

reasonable accommodation of their needs, without compromising the legal position of the Tribe 

or the Federal government. 

Tribes have expressed rights reserved in the treaties. The treaties state, “That the exclusive right 

of taking fish in the streams running through and bordering said reservation is hereby secured to 

said Indians; and at all other usual and accustomed stations, in common with citizens of the 

United States, and erecting suitable houses for curing the same; also the privilege hunting, 

gathering roots and berries, and pasturing their stock on unclaimed lands, in common with 

citizens, is secured to them.” (TREATY WITH THE TRIBES OF MIDDLE OREGON and 

TREATY WITH THE WALLA WALLA, CAYUSE, ETC. The TREATY WITH THE NEZ 

PERCE has similar language.) It is the responsibility of the Forest Service to take into account the 

cultural resources when managing the Forest’s natural resources and to address Tribal interests 

when managing and restoring habitat to support healthy, sustainable, and harvestable populations 

of culturally significant vegetative floral and faunal species. 

Utilization on NFS lands for all Federally recognized Tribes is protected by American Indian 

Religion Freedom Act, Executive Order 13007 - sacred sites, Executive Orders 13084 and 13175 

– consultation and coordination with Indian Tribal Governments, and Executive Order 12898 – 

Environmental Justice and the National Historic Preservation Act which includes protection for 

properties of traditional religious and cultural importance. 

1.7.2 Tribal Concerns 

Letters were sent to Tribal leaders of the Nez Perce, Confederated Tribes of the Umatilla Indian 

Reservation (CTUIR), and Confederate Tribes of the Warm Springs Reservation in April of 2006. 

None of the tribes responded to the letter. The Forest had meetings with various tribal resource 

staff. During these meetings the tribes were supportive of the Forest’s efforts to treat invasive 

plants and being able to use all the tools/methods described in the Proposed Action. The 

experience of the CTUIR using aerial treatments for yellow star thistle is described as successful 

when integrated with other land owners. The Nez Perce felt that biological treatments should be 

an integrated approach used on the landscape. All tribes have a concern about coordinating 

treatments with traditional gathering activities and areas. A process will be developed to notify 

each tribe when herbicides are being used as required by the Project Design Features in Chapter 

2.

Concerns voiced by the tribes include: 

• The Forest Service has Federal Trust Responsibility to take into account the Tribes’ treaty 

rights when decisions are made such that cultural practices can be exercised and treaty related 

resources are protected. Actions should not hinder the ability of the tribes to access traditional 

use areas. There is a concern that traditional use areas would not be able to continue or use of 

herbicides would contaminate traditional gathering areas. Conflicts with the timing of 

herbicide use and gathering activities would be avoided by having a method for the Forest to 

contact the tribes prior to using herbicides each year. The proposed invasive plant treatments 

do not close roads or change existing access to National Forest System lands. 

• Use of herbicides in riparian areas and its potential impact to water quality may interfere with 

recovery efforts for anadromous fish, a traditional economic resource. Protection of pristine 

riparian and upland habitat is important to the recovery of fish populations. There is support 

for the Northwest Power Planning Council’s approach to subbasin planning that focuses on 

connecting areas of high quality habitat and working toward population goals through both 

13 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

natural and hatchery populations. This concern has been incorporated into Project Design 

Features (PDFs) in Chapter 2 and effects disclosed in Chapter 3. 

• The CTUIR expresses its concern for managing resources through the cultural aspects of First 

Foods and their importance on the land that sustains their culture. First Foods – water, 

salmon, deer, cous and huckleberry – represent groupings of similar species that are served in 

their Longhouse and represents a healthy environment that is important to their cultural 

traditions. 

• The Nez Perce has focused management actions in the uplands to provide for quality habitat 

for game and cultural plant species. Biological control methods are important to them and 

they have developed insect control methods. 

Tribal concerns have been addressed in all alternatives through the use of PDFs (see Chapter 2) 

that minimize the potential for herbicide exposure. PDFs require the Forest Service to notify the 

Tribes of areas proposed for treatment each year. The Public Notification Plan requires areas 

proposed for treatment to be mapped, information shared and posted and warning signs posted at 

the locations treated with herbicides. Water quality and fisheries habitat is also protected through 

the use of PDFs that restrict herbicide use in riparian and near stream areas. The proposed 

invasive plant treatments do not close roads or change existing access to National Forest System 

lands. Herbicide treatments may cause plants to not be available for a season, depending on when 

the treatment occurs. 

Because of the PDFs, all alternative are responsive to Tribal cultural needs. The differences 

between alternatives are the amount and methods of broadcast herbicide treatments. 

1.8 Public Involvement 

1.8.1 Scoping 

Ongoing public involvement occurred throughout this NEPA process. Scoping began officially on 

April 13, 2006 when the Notice of Intent (NOI) to prepare an Environmental Impact Statement 

was published in the Federal Register Volume 71, No. 71/April 13, 2006 on pages 19162-19163. 

The scoping proposal was also posted on the Forest website at the following address: 

http://www.fs.fed.us/r6/w-w/projects/invasive-plants/index.shtml. A scoping letter, dated April 17, 

2006, was mailed to 426 individuals and organizations. The letter was signed by Forest 

Supervisor, Steve Ellis. 

1.9 Issues 

Public Issues Identified 

Twelve comment letters were received during scoping. All comments were considered, and public 

issues were identified based on these scoping comments. Many important public issues are 

addressed through the design of the Proposed Action. An example is human health, an issue of 

great public concern. All alternatives avoid the type of herbicide use associated with harmful 

exposures to workers and/or the public. The issue of human health is discussed throughout this 

document because it is of such great importance to the public, but is not the basis for alternative 

comparison because all alternatives equally address this issue. 

Some significant issues are not fully addressed by the Proposed Action and thus became the basis 

of two alternatives to the Proposed Action that are discussed in Chapter 2 of this EIS (as well as 

14
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 1 

six alternatives considered but not developed in detail). The resulting range of alternatives, 

including the No-Action Alternative, provides a broad basis for alternative comparison. 

Significant Issues 

The following section summarizes the significant issues within the following broad resource 

categories: 

• Human health 

• Treatment effectiveness 

• Social and economic 

• Non-target terrestrial plant and animal species 

• Soils, water quality and aquatic organisms 

1.9.1 Human Health 

Many people have expressed concern that exposure to herbicides may have serious human health 

consequences. People wonder if they could be sickened by brushing up against contaminated 

vegetation or eating berries, mushrooms, fish or game that may have been exposed to herbicides. 

They worry that they might drink water contaminated by herbicides. People are concerned about 

the health and safety of forest workers who are more likely to be exposed to herbicides. Some 

believe that the potential cost to human health is too high and other methods should be used to 

treat invasive plants. 

Response: All of the alternatives include layers of caution to prevent exposure to workers and the 

public. Based on scientific risk assessments for each herbicide 

(www.fs.fed.us/foresthealth/pesticides/risk_assessments), the R6 2005 FEIS found that applicator 

exposure to some herbicides could cause nausea, headache, dizziness, eye or skin irritation, 

and/or coughing. Exposure by the general public is far less likely. 

The application method and rate influences the amount of potential herbicide exposure (dose), 

which influences the likelihood that people could become sick. This project reduces the potential 

for exposure through project design features that limit the rate and method of application. In 

addition, workers would be required to adopt safety practices including signing and other public 

notification that would occur to reduce potential for inadvertent exposure to the public. An 

herbicide transportation and safety handling plan would be in place to avoid and clean up spills. 

Thus, drinking water would not be contaminated by any harmful chemicals and people are not 

likely to be exposed to any herbicide at levels considered to have negative human health 

consequences. 

Refer to section 3.7 for more information about the effects of herbicide use on workers and the 

public. 

• Unit of Measurement: 

o Character of PDFs protecting human health 

1.9.2 Treatment Effectiveness: 

Some commenters noted that limitations on the availability of treatment methods and herbicide 

options reduce the potential for invasive plants to be effectively treated. Fully integrated 

strategies are needed to effectively treat invasive weeds while minimizing effects to humans and 

15 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

the environment. Not using herbicides will result in the continued spread of invasive plants, 

resulting in the loss of ecosystem function and wildlife habitat loss. 

Response: All alternatives involve some herbicide use and include some limitations to minimize 

adverse effects to people and the environment. This is necessary to meet applicable laws, policies, 

standards and plans. 

Alternative B has the fewest limits on the use of treatment methods by allowing aerial application 

of herbicides and allowing broadcast applications where needed in riparian areas. Alternatives C 

and D limit the amount of acres that may be treated with herbicides as well as methods available 

to apply herbicide. These limitations are likely to reduce treatment cost- effectiveness. 

The alternatives differ in their potential effectiveness and are thus compared by: 

• Unit of Measurement: 

o Number of herbicide options 

o Percentage of known treatment landbase where full range of effective 

treatments are available 

o Character of limitation on integrated treatment options 

o Number of botanical species of local interest sites where threats would be 

abated 

Refer to section 3.1.6 and the Botany section in Chapter 3 for more information about treatment 

effectiveness. 

1.9.3 Social and Economic 

Cost of each treatment acre influences the number of acres that can be treated with the same total 

budget. There are also concerns that the surrounding community should be informed of activities 

and economic costs of the project. 

Response: The costs of each alternative have been estimated for a 15-year time frame. The 

alternatives differ in the average and total costs. All action alternatives incorporate Treatment 

Restoration Standard 23 from the Wallowa-Whitman Forest Plan as amended by the R6 2005 

ROD, which requires timely public notification of treatment activities. 

• Unit of Measurement: 

o Undiscounted Cost to Treat All Acres Proposed for Treatment One Time 

o Average Cost per Acre (known infestations) 

Refer to section 3.9 for more information about economics. 

1.9.4 Non-target Botanical Species and Wildlife 

There is a concern that herbicide exposure, particularly when applied through aerial or 

broadcast spraying, may harm terrestrial wildlife species and non target plants. Specifically, 

herbicide drift, primarily from broadcast and aerial applications of herbicides could cause harm 

to non-target plants and animals. 

Response: This issue is specifically addressed through adherence to the W-W Forest Plan as 

amended by the invasive plant treatment standard 19 in the R6 2005 ROD. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 1 

Project Design Features listed in chapter 2 of this EIS would be implemented to protect the 

botanical and wildlife species. The analysis in Chapter 3.2 focuses on site-specific threats to 

botanical species of local interest from invasive plants, and relative risks from treatments in the 

alternatives and how those risks are abated through PDFs. The analysis in Chapter 3.3 focuses on 

how invasive plant treatments may affect the many wildlife species of concern on the Forest. The 

PDFs would minimize the potential for herbicide exposure to non-target plants and wildlife; 

though, aerial and broadcast spraying involves inherent risks to non-target vegetation and wildlife 

that cannot be entirely discounted. However, since most ground based herbicide treatments will 

be applied using backpack sprayers, drift can be minimized. Alternatives C and D limit broadcast 

application of herbicides further reducing the potential for harm to non-target botanical species 

and wildlife. 

• Unit of Measure: 

o Character of PDFs that apply to wildlife and plants 

o Acres of broadcast application 

o Acres of aerial treatment 

Refer to sections 3.2 and 3.3 for more information about effects on non-target botanical species 

and wildlife. 

1.9.5 Soil, Water Quality, Aquatic Biota 

There is a concern that there may be potential adverse effects of herbicide treatment on soils and 

the potential for leaching into ground water. 

Response: Project Design Features have been developed in all alternatives to reduce potential 

effects from specific herbicides that can combine with soil or leach into ground water. The 

analysis addresses the potential risks of the various herbicides and the measures in place to 

minimize adverse effects. The action alternatives do not vary significantly regarding effects to 

soils and potential for herbicides to leach. 

There is a concern that there may be potential adverse effects of herbicide treatment on riparian 

areas adversely impacting water quality and aquatic ecosystems. Specifically some believe that 

application of herbicide in riparian areas could contaminate water and cause mortality to fish, 

organisms that support fish and other aquatic species. Fish and other aquatic organisms may 

also be impacted by manual and mechanical treatments, which may change dissolved oxygen 

levels, nutrients, water temperature, turbidity, fine sediment and riparian structure. 

Response: Chapter 2 describes the Project Design Features and buffers designed to avoid 

herbicide delivery to water and eliminate risk of concentrations and of concerns for water quality 

and fish, domestic water sources and other aquatic organisms. Alternatives C and D, described in 

Chapter 2, give additional protection for concerns about water, fish, and aquatic ecosystem 

exposure to chemicals. Chapter 3 explains why the potential for adverse effects is relatively low 

in all alternatives. Listed fish are protected under the standards developed by PACFISH/INFISH. 

This project would be consistent with PACFISH/INFISH standards and guidelines, and not retard 

or prevent attainment of riparian management objectives. 

However, the R6 2005 ROD acknowledges that aerial application and ground broadcast in 

riparian areas pose potentially higher risks of delivery to surface waters. This is because there is 

more potential for drift during application, applications cover more ground each day, and often 

more herbicide is applied to each acre with broadcast treatments than more selective treatments. 

17 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

This is also due to the inherent loss of operator control associated with broadcast and aerial 

treatments compared to spot and selective treatments. This is not to imply that all aerial or 

broadcast treatments involve great risk of impact to surface waters; the degree of risk is greater, 

but the intent of all treatments, including aerial and broadcast, is to minimize drift and herbicide 

contact with surface water. 

• Unit of Measure: 

o Acres of broadcast herbicide application within riparian areas 

o Acres of aerial treatment 

1.9.6 Non-Significant Issues 

The Council of Environmental Quality requires the USDA Forest Service to identify and 

eliminate from detailed study the issues that are not significant (40 CFR 1501.7). Issues may be 

eliminated from further analysis when the issue is: 

• Outside the scope of the EIS 

• Already decided by law, regulation, Forest Plan, or other higher level decision 

• Not clearly relevant to the decision to be made 

• Conjectural and not supported by good scientific or factual evidence 

The following issues fit in one or more of the non-significant categories. Issues are identified and 

an explanation of why they are not significant is given. 

Some comments suggested adding aspects of the project covered by other programs. Such 

suggestions are outside the scope of this project. An example is: 

• Roads are a major weed vector. The analysis must consider closing or revegetating unneeded 

roads. No new road should be constructed if you are serious about controlling weeds. 

Decisions to build, open, or close roads are made in the transportation management program 

and individual projects that require access. 

• There is a concern that lack of coordination with other land owners/managers will not lead to 

effective control of invasive weeds. Coordination with land owners/managers is not an issue 

that can be resolved in a site-specific invasive plant treatment project. This issue is addressed 

in the R6 2005 FEIS through programmatic objectives that are assumed to occur regardless of 

decision made under the scope of this project. 

Some comments made speculative or unsupportable claims. Because such comments are not 

supported in peer-reviewed literature, they are considered non-significant issues. Examples 

include: 

• Herbicide spraying causes all kinds of cancer 

• Herbicide spraying destroys essential ecosystem functions 

Some comments made requests that were outside the scope of the proposed project. While some 

such requests might be a good idea, they go well beyond the level of analysis NEPA requires. 

Examples include: 

• Stop all logging. Stop all grazing, which is harmful and brings in invasive weeds, as does 

logging. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 1 

19 

• Have an independent contractor study the effectiveness of past Forest Service chemical and 

non-chemical control methods in each district, including adequacy of timing and repetition of 

control methods and publicly disclose the results. 

• Do a feasibility study of the effectiveness needs for further research and logistical parameters 

for non-chemical alternative control methods for each invasive plant at issue, and make this 

available to all district offices. 

Some comments raised issues about complying with laws. These were mostly reminders to 

complete tasks that are already part of the process of completing an EIS. Examples include: 

• Impacts on non-target plants, soils, water quality, human health, wildlife and fish must be 

properly analyzed and disclosed. Cumulative effects must be disclosed. 

• The National Forest Management Act requires the Forest Service to “provide for diversity of 

plant and animal communities.” 16 U.S.C. § 1604(g)(3)(B 

• Note that pursuant to Section 7 of the ESA, the Forest Service has an independent duty to 

conserve and protect the threatened and endangered species that depend on the public lands it 

is charged with managing and ensure it does not jeopardize species or adversely modify 

critical habitat. 

• This project must comply with the Clean Water Act, which may require a NPDES permit for 

the herbicide application. 

Some commenters expressed the opinion that herbicides should be used only as a last resort when 

other methods fail. This approach was analyzed in the R6 2005 FEIS. The R6 2005 ROD stated 

that such an approach deviated from IWM principles. Rather, the R6 2005 ROD required that 

we: “select methods for ...containing and controlling noxious weeds in coordination with other 

resource management activities to achieve optimum management goals and objectives (page 6).” 

 The current program (Alternative A) addresses this concern to a degree by only allowing 

herbicide use on sites identified by the 1992 and 1994 weed program EAs. The effectiveness of 

this program will be analyzed and compared to the three action alternatives.

1.10 What This Proposal Does Not Include 

This project includes treatment of terrestrial and riparian invasive plants on the WallowaWhitman National Forest. Treatments on other lands are not included. This action does not 

include experimental trials of herbicides conducted by the U.S. Environmental Protection Agency 

(EPA) to test new products. Treatment of floating and/or submerged aquatic invasive plants is not 

included. 

The proposal assumes that invasive plant prevention measures will be applied to all land uses as 

required by the R6 2005 ROD (see Appendix 1 for prevention standards). Invasive plant 

prevention activities are incorporated into individual projects carried out under regulation and 

guidance of those individual land use programs. Invasive plant treatments may also occur in the 

context of other projects or programs such as transportation planning, timber management, 

livestock grazing, etc. Weed prevention and treatment activities are incorporated into individual 

projects carried out under regulation and guidance of those programs. 

This proposal does not include treatments or restoration actions that would result in significant 

ground disturbance. No tilling or mechanical scarification is included. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

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20
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Chapter 2 – Alternatives 

2.1 Introduction 

Chapter 2 describes and compares alternatives considered for invasive plant treatment on the 

Wallowa-Whitman National Forest in the states of Oregon and Idaho. This chapter provides a 

summary of the effects of implementing alternatives and displays how they are responsive to the 

Purpose and Need for action, and issues identified during public scoping. 

A thorough invasive plant inventory was completed in 2006; Forest staff estimate this inventory 

detected approximately 95 percent of the invasive plant infestations on the Forest (this estimate 

is based on a poll of invasive plant specialists across the Forest who have conducted inventories 

over the past 20 years over the majority of likely invasive plant sites). Based on this inventory, 

the Forest staff proposes to treat approximately 23,000 acres (1,740 individually mapped 

locations) of invasive plants with an effective, integrated combination of treatments including 

biological, physical (manual and mechanical), cultural/restoration (competitive seeding and 

planting) and chemical (herbicide) methods. The project is anticipated to last 10 to 15 years or 

until conditions substantially change. 

The invasive plant treatment sites are widely distributed across all Forest Districts and Hells 

Canyon National Recreation Area (HCNRA). Each invasive plant site has been mapped – sitespecific maps can be viewed at the Wallowa-Whitman Forest Website (www.fs.fed.us/r6/ww/projects/invasive-plants/maps/locator-map.shtml). The maps indicate the primary treatment 

method; site-specific prescriptions are integrated and include combinations of treatments such as 

herbicide application followed by manual/mechanical treatments. 

The Proposed Action also includes treatment of invasive plant sites that are presently nonexistent 

or as yet undiscovered, including new plant species that currently have not been found on the 

Forest. As described in Chapter 1, detecting and treating new infestations when they are small 

(referred to as Early Detection/Rapid Response or EDRR) increases effectiveness of the invasive 

plant program and minimizes adverse effects. Thus, the Proposed Action includes treatment of 

new detections using methods as those used on known sites. 

New sites would be subject to an implementation planning process, which is outlined later in this 

section, so that the effects of treating new sites are within the scope of the analysis in this EIS. 

This EIS evaluates four alternatives for invasive plant treatment, including No Action 

(Alternative A) and the Proposed Action (Alternative B). No Action (Alternative A) is defined as 

the treatments that would currently be approved under existing NEPA documentation for 

managing invasive plants on the Wallowa-Whitman National Forest. 

The Proposed Action and action alternatives focus on invasive plant treatments. The R6 2005 

FEIS addressed standards for invasive plant prevention that are an essential part of the invasive 

plant management program. The R6 2005 FEIS also discussed the importance of coordination of 

different land bases through weed management areas and the need for public education about 

invasive plants. The Proposed Action focuses on the part of the program related to herbicide and 

other treatments that have become available since the R6 2005 ROD was signed. The analysis 

assumes that prevention standards related to range, recreation, roads, timber and other land uses 

will be followed. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

2.2 Alternatives Considered in Detail 

2.2.1 Proposed Action and Alternative Development Process 

The process for developing the Proposed Action included determining the most effective 

treatment methods for known infested sites, characterizing the risk to people and the 

environment associated with these treatments, and developing design features that minimize 

these risks. 

Each invasive plant site in the inventory was assigned a primary treatment method (e.g. 

chemical, biological), a priority for treatment (1 through 5), and a control strategy (e.g. eradicate, 

contain). Figure 1 displays a map showing a sample of known weed infestations and proposed 

treatments. Such maps exist for all 1,740 weed sites and can be viewed at the Wallowa-Whitman 

Forest Website (www.fs.fed.us/r6/w-w/projects/invasive-plants/maps/locator-map.shtml). 

Treatment methods, priorities, strategies and design features incorporate approaches described in 

Chapters 2 and 3 of the R6 2005 FEIS. The project was also designed in accordance with USDA 

Forest Service Handbook (FSH) 2109.14 – Pesticide-Use Management and Coordination 

Handbook (USDA Forest Service 1994c). The R6 2005 FEIS described adverse effects possible 

from herbicide and other invasive plant treatments; project design features (PDFs) were 

developed to address adverse effects associated with the methods necessary to treat known 

infestations. PDFs provide a layer of caution intended to address the range of possible adverse 

effects that may occur from the range of treatment methods necessary to treat known sites.1

 

In 2008, the Proposed Action was circulated for scoping. The response to scoping from the 

public and other agencies centered on cost-efficiency, treatment effectiveness, toxicity of 

herbicides, and potential adverse effects of herbicides on people and the environment (see 

Chapter 1.9). A range of alternatives were considered to address public and interagency issues; 

two of the alternatives were brought forward for detailed analysis. Other alternatives were not 

carried forward, because they would not effectively meet the purpose and need or because they 

were similar to one of the alternatives brought forward for analysis or because they would not be 

consistent with the R6 2005 ROD. 

The R6 2005 ROD (Appendix 1) noted that broadcast application in riparian areas and aerial 

applications inherently pose higher risk to the environment. The two action alternatives 

analyzed in this document were developed to avoid these higher risks. Alternative C eliminates 

broadcast treatment in riparian areas, and Alternative D eliminates aerial treatment altogether. 

The action alternatives vary in the following ways: 

• Whether or not broadcast methods will be available within approximately 6,345 acres of 

riparian areas and wetlands 

• Whether or not aerial methods will be available anywhere in the project area 

 

1

 The treatment methods and PDFs associated with known sites would also be applied to new detections so 

that the effects of treating new detections are similar to those associated with known sites and disclosed 

herein. 

22
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

23

Figure 1 – Example Map of Proposed Invasive Plant Treatments 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

2.2.2 Alternative A - No Action 

The Wallowa-Whitman National Forest has been treating invasive plants according to 

management direction found in the following documents: 

• 1992 decision implementing the Wallowa-Whitman National Forest Environmental 

Assessment for the Management of Noxious Weeds (USDA Forest Service 1992) 

• 1994 decision implementing the Wallowa-Whitman Management of Noxious Weeds 

Environmental Assessment (USDA Forest Service 1994a) 

• Hells Canyon Comprehensive Management Plan (CMP) (Forest Plan Amendment #29, 

USDA Forest Service 2003c) 

The 1994 EA, which incorporated the 1992 EA, identified 5,172 additional acres of weed 

infestations and 21 invasive plant species for treatment. The Hells Canyon CMP added additional 

direction to evaluate the extent of nonnative invasive plants, provided additional guidelines for 

the containment or control of aggressive weeds and implemented additional prevention 

guidelines to further reduce the spread of weeds (USDA Forest Service 2003, Appendix C, Table 

C-1, pages 67-68). BAER authority following wildfires has also allowed some invasive plant 

treatment. The two EAs authorized the use of four herbicides; glyphosate, dicamba, picloram 

(with restrictions), and triclopyr for use during site treatment. Dicamba was restricted from use 

by the R6 2005 FEIS and will not be used in the future by the Forest. 

Under these documents, manual or mechanical treatments were required on a site for years prior 

to the use of herbicides (herbicide as a tool of last resort). New or unrecorded infestations or 

new species were not included for herbicide treatment; herbicides could be used solely on known 

sites. The Wallowa-Whitman National Forest has completed limited treatments of invasive 

plants with herbicides after fire disturbance using the Burned Area Emergency Rehabilitation 

(BAER) authority. Complete information about those treatments is available in the project 

record. 

The treatment approach under No Action has resulted in over 7,000 acres of herbicide 

application over more than ten years; however, has not resulted in effective invasive plant 

control. This includes retreatment of persistent populations over a span of years. Some of the 

treatments approved in existing NEPA documents have been effective; nevertheless, invasive 

plants have continued to spread throughout the Forest, resulting in the current inventory of 

23,000 acres that currently need treatment. For example, existing NEPA does not permit use of 

effective herbicides to control whitetop or perennial pepperweed. This spread would be likely to 

continue without a more integrated approach to invasive plant management throughout the 

Forest. 

Under the No Action Alternative, manual and mechanical treatment would continue to be 

allowed and some herbicide re-treatment could occur within the 5,172 acres currently approved 

for herbicide use. However, No Action would not be consistent with invasive plant management 

direction described in Chapter 1, and would not meet the purpose and need for action. No 

Action provides a baseline to compare the risks and benefits of the action alternatives. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

2.2.3 Alternative B - Proposed Action 

Alternative at a Glance 

Activity Approximate Value 

Acres identified for treatment 22,842 

Percent of Total Forest Landbase Affected by Known Sites 0.9% 

Maximum Percent of Total Forest landbase treated annually 0.32% 

Percentage of treatment sites where full range of effective treatments are 

available 100 

Number of herbicides available for use 10 

Acres of proposed herbicide treatments for known sites 20,776 

Acres identified for aerial spraying of herbicides 875 

Approximate total acres of ground based (hand or boom) broadcast 

treatments proposed for known sites* 16,660 

Acres of hand or non-aerial broadcast treatments within riparian/wetland 

areas 3,104 

Approximate total acres of spot spraying or selective (wicking, wiping, 

stem injection) herbicide application on known sites 3,241 

Number of invasive sites where methods other than herbicides would be 

effective 313 

Acres of invasive sites where treatment methods do not include 

herbicides 2,066 

EDRR includes chemical methods other than aerial Yes 

Cost estimate per effectively treated acre of known sites $307 

*Most ground-based treatments will be applied using backpack sprayers. 

Introduction 

The Proposed Action (Alternative B) would approve chemical, physical, biological and cultural 

treatment methods to eradicate, control, and contain existing or newly discovered invasive plants 

infestations. The Proposed Action includes treatment of 23,000 acres of known infestations, 

along with sites identified in the future. 

Untreated infestations would likely continue to expand at an average rate of 8 to 12 percent each 

year (R6 2005 FEIS, Asher 2005). Retreatment is often necessary to maintain the control level 

of initial treatment depending on the species, size and density of an infestation. Thus, treatments 

may be necessary over a period of 10 to 15 years to achieve control objectives on known sites. 

Each invasive plant site is assigned a treatment priority and strategy based on the invasive plant 

species and site conditions such as ease of access, land allocation, location near special areas, 

restrictions due to other sensitive resources, or the invasiveness of a plant in a specific habitat. 

Sites that are identified as high priority would typically be treated with herbicide. Once initial 

treatment is complete, future potential treatment is evaluated based on the current condition 

compared to the desired condition. Achieving desired conditions includes future reduction of 

herbicide treatment methods when site conditions favor effective non-chemical treatments. 

Strategies for known sites include eradication, control or containment of invasive plants. New 

detections would be subject to the Early Detection Rapid Response (EDRR) process described in 

this chapter. 

• Eradicate - Totally eliminate an invasive plant species from a site. This objective generally 

applies to small infestations of aggressive species such as yellow star thistle, spotted 

25
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

knapweed, leafy spurge, and hawkweed; and/or higher priority treatment areas. At some 

point, larger infestations can become impossible to eradicate. 

• Control - Reduce the size of the infestation over time; some level of infestation would be 

acceptable. This objective applies to target species such as Russian knapweed and whitetop. 

• Contain - Prevent the spread of the weed beyond the perimeter of patches or infestation 

areas mapped from current inventories. 

• Early Detection Rapid Response (EDRR) - EDRR refers to newly inventoried invasive 

plant infestations, including previously undiscovered invasive plant infestations or new 

infestations that would occur over the life of this project. Ongoing inventory and monitoring 

would look for infestations of new invasive plant species or new locations of existing weeds. 

Newly discovered infestations or sites would likely receive a high priority for treatment to 

eradicate the invasive plants while the infestation is small and easily treatable. 

EDRR is essential to effective invasive plant management. The No Action alternative described 

above is ineffective partly because it does not allow the full range of treatment options on newly 

detected sites, allowing infestations to become established over thousands of acres over the last 

15 years. Thus, the Proposed Action includes an EDRR strategy to allow treatments of new 

infestations using methods described below. 

Treatment Methods 

A range of treatment methods are proposed for the known inventory of invasive plants on the 

Wallowa-Whitman National Forest: chemical (herbicide), physical, biological, and cultural (see 

Table 16). A range of herbicide application methods are proposed including: aerial, ground 

broadcast and spot spraying, as well as selective (wicking, wiping, and stem injection). Nonherbicide methods would be used in conjunction with herbicides for some sites, and 

approximately 2,000 acres would be treated with methods other than herbicides because 

biological and/or physical treatments are expected to be effective on these sites. 

Detailed 1:24000 scale maps of all known existing treatment sites are available on the WallowaWhitman National Forest website at www.fs.fed.us/r6/w-w/projects/invasiveplants/maps/locator-map.shtml. (also see map example in figure 1) To clarify the geographic 

location of proposed treatment sites and methods, the following figures 2-8 were mapped 

showing sites and methods within each Ranger District, and Table 3 displays acres proposed for 

treatment by Ranger District. 

26
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

27

Table 3-Acres of treatment methods by Ranger District 

Ranger District 

Treatment Method 

Baker Wallowa 

Valley HCNRA Eagle Cap 

La 

Grande Pine Unity Total Acres 

Chemical 951 1,596 6,232 436 1,128 1,762 1,269 13,376 

Chemical Riparian 628 555 4,031 300 758 725 403 7,400 

Physical 1 10 70 2 3 18 7 111 

Biological 90 186 86 123 143 30 1,297 1,955 

Total 1,670 2,347 10,419 861 2,032 2,535 2,976 22,842 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

28

Figure 2 – Proposed invasive plant treatments for Baker Ranger District 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Figure 3 – Proposed invasive plant treatments for Wallowa Valley Ranger District 

29
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

30

Figure 4 – Proposed invasive plant treatments for HCNRA 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

31

Figure 5 – Proposed invasive plant treatments for Eagle Cap Ranger District
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

32

Figure 6 – Proposed invasive plant treatments for La Grande Ranger District 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

33

Figure 7 – Proposed invasive plant treatments for Pine Ranger District 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

34

Figure 8 – Proposed invasive plant treatments for Unity Ranger Station
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Figure 9 – Proposed herbicide aerial application invasive plants treatments 

Chemical Methods 

Chemical methods include use of herbicides and surfactants according to R6 2005 ROD 

standards. The effectiveness, risks and properties of the herbicides and application methods 

proposed for use vary widely. 

Ground-based or aerial application of herbicides would be used based on accessibility, 

topography, the size of treatment area and the expected efficiency and effectiveness of the 

method selected. The eventual goal is to reduce dependence on herbicide applications and 

maintain sites using non-herbicide methods. 

The following are examples of the proposed chemical methods of application: 

Spot spraying – This method targets individual plants and is usually applied with a 

backpack sprayer. Spot Spraying can also be applied using a hose off a truck-mounted or 

ATV-mounted tank, or tanks mounted on pack animals. 

Wicking – This hand method involves wiping a sponge or cloth that is saturated with 

chemical over the plant. This is used in sensitive areas, such as near water, to avoid 

getting any chemical on the soil or in contact with non-target vegetation. 

Stem injection – A hand application technique currently is being used on Japanese 

knotweed in western OR & WA. 

Approximately 9,000 acres are currently proposed to be treated with spot or selective 

methods such as those described above. 

35
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Hand broadcast – Herbicide would be applied by hand using a backpack or hand 

spreader to cover an area of ground rather than individual plants. 

Boom broadcast – This involves using a hose and nozzle from a tank mounted on a 

truck, or ATV. Herbicide is applied to cover an area of ground rather than individual 

plants. This method is used in areas where invasive plants occupy a large percentage of 

cover on the site and the area to be treated makes spot spraying impractical. 

In the Proposed Action, approximately 16,600 acres would be proposed for non-aerial 

broadcast applications. 

Aerial applications – In areas where physical features, such as topography, raise 

applicator safety concerns or where the cost of ground application is prohibitive, 

invasive plants may be treated with the use of helicopters. Aerial application of the 

herbicides would occur in the HCNRA and La Grande District covering approximately 

875 acres (see Figure 9). Appendix B includes maps detailing aerial application sites. 

All treatments would be done in accordance with USDA Forest Service policies, 

regulations, Forest Plan Standards, and product label requirements. When herbicide use 

occurs in close proximity to sensitive areas, specific design features, called Project 

Design Features (PDFs), would be applied so that vegetation treatments do not have an 

adverse impact on non-target plants or animals. PDFs are listed in this chapter in section 

2.2.3. Chemicals approved for use within or outside riparian areas are listed in the 

Pacific Northwest Region Invasive Plant Program Preventing and Managing Invasive 

Plants FEIS (USDA Forest Service 2005a) and accompanying ROD (USDA Forest 

Service 2005b). 

Herbicide formulations and mixtures can contain one or more of the following 10 active 

ingredients: chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, metsulfuron methyl, 

picloram, sethoxydim, sulfometuron methyl, and triclopyr. Additional herbicides may be added 

in the future at either the Forest Plan or project level through appropriate risk analysis and 

NEPA/ESA procedures. 

The application rates and method depend on the presence of the target species, condition of nontarget vegetation, soil type, depth to the water table, the distance to open water sources, riparian 

areas, special status plants, and requirements of the herbicide label. Applications would be 

scheduled and designed to minimize the potential impacts to non-target plants and animals (R6 

2005 FEIS, Appendix 1-5, 1-6) by applying Project Design Features. Monitoring of treated sites 

would determine what follow-up treatments would be needed if treatment methods need to be 

changed or if a more effective herbicide should be used. 

Though the invasive plant inventory was thorough, it is reasonable to assume not all invasive 

plants sites have been located and that new sites will emerge on the landscape. Therefore, 

ongoing monitoring of treated sites would also look for new infestations. Newly discovered 

infestations would likely receive a high priority for treatment under the Early Detection Rapid 

Response (EDRR) strategy. Such treatments would be done under the same guidance of the R6 

2005 ROD, other Forest Plan standards, product labels, and PDFs used for known treatment 

sites. 

Table 4 displays 10 herbicides proposed for use in the Proposed Action (PA). The range of 

application rates for each chemical was derived during the SERA Risk Assessments, which are 

36
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

the basis for the herbicides analyzed in the R6 2005 FEIS. Most of the time application rates 

would not exceed the typical rate and effects analyses assumes the typical rate; however the 

actual effective rate may vary depending on application method, target species, and Project 

Design Features (site-specific measures of protection). Broadcast applications would never 

exceed typical label rates shown in Table 4. Non-broadcast methods such as spot spraying, 

wicking, wiping or stem injection may be applied at rates greater than typical, but that would 

happen infrequently and only where necessary to be effective. 

Table 4-High, Typical, and Low Application Rates for Herbicides 

Herbicide 

Highest Application 

Rate 

Lbs. a.i./acre 

Typical 

Application Rate 

Lbs. a.i./acre 

Lowest 

Application Rate 

Lbs. a.i./acre 

Chlorsulfuron 0.25 0.056 0.0059 

Clopyralid 0.50 0.35 0.10 

Glyphosate 7.00 2.00 0.50 

Imazapic 0.19 0.130 0.031 

Imazapyr 1.25 0.45 0.03 

Metsulfuron Methyl 0.15 0.03 0.013 

Picloram 1.00 0.35 0.10 

Sethoxydim 0.38 0.30 0.094 

Sulfometuron Methyl 0.38 0.045 0.03 

Triclopyr 6.00 1.00 0.10 

Additives, Inert Ingredients, and Impurities 

Adjuvants are compounds added to the formulation to improve its performance. They can 

either enhance the activity of an herbicide’s active ingredient (activator adjuvant) or offset 

any problems associated with its application (special purpose or utility modifiers). For 

example, Surfactants are one type of adjuvant that makes the herbicide more effective by 

increasing plant absorption. PDFs have been developed to reduce potential impacts from 

adjuvants. 

Inert compounds are those that are intentionally added to a formulation, but have no 

herbicidal activity and do not affect the herbicidal activity. Inert additives facilitate the 

herbicide’s handling, stability, or mixing. 

Impurities are inadvertent contaminants in the herbicide, usually present as a result of the 

manufacturing process. 

Physical Methods 

Physical methods include manual control and hand mechanical. 

Manual Control Methods - These include non-mechanized approaches, such as hand 

pulling or using hand tools (e.g., grubbing), to remove plants or cut off seed heads. Manual 

treatments are labor intensive, effective only for relatively small accessible areas, and would 

be repeated several times throughout the growing season depending on the species. Manual 

treatments can be effective for annual and tap-rooted weeds, but are ineffective against 

perennial weeds with deep underground stems or roots, or fine rhizomes that can be easily 

broken and left behind to re-sprout. 

37
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Manual treatments are typically used to treat selected plants, small infestations, and sensitive 

areas to avoid potential toxic impacts to non-target species or water quality. Where sites are 

small or there are few individual target species, handsaws, axes, shovel, rakes, machetes, 

grubbing hoes, mattocks, brush hooks, and hand clippers may all be used to remove invasive 

plant species. Axes, shovels, grubbing hoes, and mattocks are also used to dig up and cut 

below the surface to remove the main root of plants. To meet control objectives or reduce the 

risk of activities spreading invasive plants, seed heads and flowers are removed and disposed 

of properly. Other manual methods could include mulching, hot water steaming, foaming, or 

solarization techniques such as using black plastic to cover invasive plants to shade out and 

kill pieces of roots (i.e. rhizomes). These techniques could be used where minimizing 

herbicide use is desirable such as areas with an abundance of sensitive wildlife or plant 

species. 

Mechanical Control Methods - This method uses power tools and includes such actions as 

mowing, weed whipping, road brushing, root tilling methods, or foaming, steaming, infrared 

and other techniques using heat to reduce plant cover and root vigor. Choosing the 

appropriate treatment depends on the characteristics of undesired species present (for 

example, density, stem size, brittleness, and sprouting ability); the size of the treatment area, 

seedbed preparation and revegetation; the sites location (inside or outside a riparian area); 

and soil or topographic considerations. These activities would typically occur along 

roadsides, rock sources, or other confined disturbed areas and dispersed use areas. 

Mowing and cutting would be used to reduce or remove above ground biomass. Seed heads 

and cut fragments of species capable of re-sprouting from stem or root segments would be 

collected and properly disposed of to prevent them from spreading into noninfested areas. 

Biological Methods 

Animal and Plant Health Inspection Service (APHIS) and State approved insects or plant 

pathogens that are proven natural control agents of specific weed species would be released to 

selectively suppress, inhibit, or control herbaceous and woody target species. 

The insect or plant pathogen attack and weaken targeted weed species and reduce its ability to 

compete or reproduce. Biological controls would be used when the target species occupies 

extensive portions of the landscape, other methods of control are prohibitive based on cost and 

location, and an effective biological control regime exists. Biological weed control activities 

typically include the release of parasitic and `host specific'' insects, mites, nematodes, and 

pathogens. Treatments do not eradicate the target species but rather reduce target plant densities 

and competition with desired plant species for space, water and nutrients. 

Biological control activities include collection of beetles/insects, development of colonies for 

collection, transporting, and transplanting parasitic beetles/insects, and supplemental stocking of 

populations. Bio-control agents are transported in containers that safely enclose the agent until 

release. 

In some situations, a suite of biological control agents is needed to reduce weed density to a 

desirable level. As an example; a mixture of five or more biological control agents may be 

needed to attack flower or seed heads, foliage, stems, crowns and roots all at the same time or 

during the plant’s life cycle. Typically 15 to 20 years are needed to bring about an economic 

control level. 

The treated areas would continue to be inventoried and monitored to determine the success of the 

treatments and when the released bio-control agents have reached equilibrium with the target 

38
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

species. Repeat visits may need to be made several times a season, and over a series of years to 

determine if additional releases are needed or if a different agent needs to be released. 

The use of biological treatment usually results in delayed effectiveness, often requiring 5-10 

years for successful reduction of infestations. However, the increase of native vegetation is 

simultaneously occurring that often eliminates the need for restoration. Because of this fact, it is 

the preferred method in remote areas where access is limited, and on species where bioagents are 

available and proven successful. 

Cultural Treatment Methods/Restoration 

Cultural controls are defined in the R6 2005 FEIS as: “The establishment or maintenance of 

competitive vegetation, use of fertilizing, mulching, prescribed burning, or grazing animals to 

control or eliminate invasive plants” (page 10). Any of these methods except prescribed burning 

and grazing animals may be used in this project. 

Cultural treatment methods would be used in the context of encouraging native vegetation to outcompete invasive plants. Some infestations can be treated once and some require multiple 

treatments to be effective. Mulching, seeding, planting and fertilizing the cultural treatments that 

could be integrated with chemical, physical or biological methods to encourage native plant 

growth and spread. Native seed would be used to help native species re-establish, enhance 

competition over invasive plants, and provide erosion protection. In other areas, where 30 

percent or more of the desirable vegetation exists, it may naturally replace target invasive plant 

species that have been removed. 

Typical circumstances for applying cultural/restoration treatments include: 

• Seeding will likely apply where herbicide treatments cause openings in native vegetation 

greater than: 

o .1 acres in uplands 

o .01 acres in riparian areas 

• Approved mulch may be applied when concern exists about seed predation or to retain 

soil moisture 

• Fertilization would typically accompany seeding unless concern exists that fertilization 

will stimulate invasive plants growth and dominance of a site 

Project Design Features Group P (in this section) addresses restoration for areas that are highly 

disturbed within the dry grassland habitat in Hells Canyon National Recreation Area, and for 

areas where potential re-infestation by new or nearby invasive plants threatens the introduction 

of, or existing, native vegetation as well as soils. Treatment Restoration Standards from the R6 

2005 FEIS and guidelines and techniques outlined in Guidelines for Revegetation for Invasive 

Weed Sites on National Forests and Grasslands in the Pacific Northwest (Erickson et al. 2003) 

are addressed. All PDFs are detailed later in this chapter. 

Treatment Methods NOT Included 

Additional invasive plant treatment methods exist but are not being considered for this project. 

They include: 

• Prescribed burning 

• Plowing/Tilling/Digging with Heavy Equipment 

• Grazing 

39
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

40

• Flooding/Drowning 

Projects utilizing one of these methods would be outside the scope of this EIS. 

Common Control Measures 

Table 5, Common Control Measures Summary, shows species-specific integrated control 

measures that would be applied to known invasive species on the Wallowa-Whitman National 

Forest. The table shows known acreages infested with each species, the range of effective 

treatment options, and site-specific considerations important to the final prescription. The 

priority and intensity of treatment needed varies widely based on site conditions, values at risk 

from invasion, and the range and aggressiveness of individual target species. 

This table displays the specific herbicides known to be effective for each species, along with the 

other integrated methods described above, as well as a plant specific display of Project Design 

Features, which are identified later in this Chapter. Project Design Features (PDFs) minimize the 

potential adverse impacts of invasive plants treatment. The PDFs were developed to respond to 

the site-specific resource conditions within the treatment areas. All project PDFs are introduced 

fully in the section below. 

The Common Control Measures summary table is a distillation of detailed work shown in 

Appendix B prepared by Linda Mazzu (R6 2005 FEIS), and updated by Vicky Erickson 

(Invasive Weed Specialist), Julie Laufmann (TEAMS Botanist), Gene Yates (Forest Botanist), 

with incorporated comments from M. Porter (Wallowa Resources, Enterprise, OR) D. Sharratt 

(Oregon Department of Agriculture), Pacific Northwest’s Least Wanted List: Invasive Weed 

Identification and Management, Oregon State University Extension Service, EC1563, 2003), and 

Nature Serve (www.natureserve.org). 

Adaptive management is expected to further adjust specific control measures as we learn from 

implementation. This analysis considers a wide range of treatment options applied to a wide 

range of site conditions so that practitioners are provided necessary flexibility to increase 

effectiveness of treatment, reduce cost of treatment, and minimize potential for adverse effects 

from treatment. 

Widespread species such as cheatgrass and ventenata are not shown in this table. Thousands of 

acres of common non-native plants are known on the Forest; these are not the focus of treatment 

in this document. However, some cheatgrass or ventenata sites may be treated if they are 

associated with other infestations treated within the scope of this document. Widespread invasive 

plants such as cheatgrass may be included in the treatment plan for some areas, such as 

wilderness or other natural areas. However, non-native species such as cheatgrass would not be 

considered non-target species for the purposes of protection (i.e. project design features intended 

to protect non-target plants). 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Table 5-Common Control Measures Summary - Range of Effective Treatment Options and SiteSpecific Considerations by Target Species 

Target 

Species - 

Common 

Name 

Acres 

and 

Number 

of Sites 

Range of Effective 

Treatment Options 

Site Specific 

Considerations 

Bugloss 

(ANOF) 

Anchusa 

officinalis) 

Perennial

5813 ac 

1 site 

Herbicide in combination with manual and 

mechanical. Manual/mechanical alone will not 

eradicate. Use surfactants for herbicide use to 

penetrate the hairy leaves on the plant 

1.Metsulfuron methyl 

2. Picloram 

3.Clopyralid 

4.Chlorsulfuron + Metsulfuron

. 

Cannot aerially spray 

sulfonylurea 

herbicides(as per 

Standard 16), picloram 

and clopyralid have 

mobility and soils 

restrictions 

Large site that will not be 

treated aerially due to 

lack of acceptable, 

effective herbicide 

Canada 

Thistle (CIAR) 

Cirsium 

arvense 

3395 ac 

154 

sites 

Herbicide treatment is most effective. The only 

manual technique would be hand cutting of 

flower heads, which only suppresses seed 

production. Manual Disposal: bag and remove 

flower heads form site. Mowing may be 

effective in rare cases if done monthly (this 

intensity would damage native species). 

Covering with a plastic tarp may also work for 

small infestations. 

Yearly revisits would be necessary; the 

number of which is dependent on the chemical 

used and the seedbank. Revegetate with 

desirable species in accordance with the 

Restoration Plan. 

1. Clopyralid 

2. Picloram 

3. Chlorsulfuron 

4. Aquatic labeled Glyphosate (best in 

fall) 

Biocontrols proposed for some sites. 

Cannot aerially spray 

sulfonylurea 

herbicides(as per 

Standard 16). Picloram 

and clopyralid have 

mobility and soils 

restrictions. Many sites 

have well drained or 

shallow soils where 

alternative herbicides or 

methods may be 

necessary (see Appendix 

D). 

Clary Sage 

(SASC2) and 

Mediterranean 

sage (SAAE) 

Salvia 

aethiopis 

 

Biennial

22 acres 

1 site 

Manual or mechanical removal of individual 

plants can be effective. Mowing several times 

during the growing season will prevent seed 

production, but the rosettes are low enough to 

the ground to escape most damage. Biocontrol 

available and somewhat effective. 

1 Metsulfuron methyl 

2. Chlorsulfuron 

3. Picloram 

4. Glyphosate 

Cannot aerially spray 

sulfonylureas, (as per 

Standard 16). No known 

shallow or well drained 

soil sites. 

Common 

Crupina 

284 ac 

1 site 

Manual/Mechanical - handpulling is effective 

on small infestations prior to seed set (WA 

DNR) 

 1.Clopyralid (0.13 lb ae/A) 

Sequential fall and spring applications provide 

>95 % control1 

 2.Triclopyr (.25 lb ae/A) Sequential fall 

and spring applications provide >95 % control1 

 3. Spring application of picloram 

Biological – none1 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Target Acres 

Species - Range of Effective 

Common 

Name 

and Site Specific 

Number Treatment Options Considerations 

of Sites 

Dalmatian 

Toadflax 

(LIDA) 

Linaria 

dalmatica 

And other 

Linaria sp. 

783 ac 

141 

sites 

Hand-pull or dig if populations are small or 

volunteer labor is available. 

Manual Disposal: Plants can be left on site, but 

may reduce germination of desirable species 

due to mulching effect. If plants have flower 

heads with seeds (immature as well), bag and 

remove them from site. 

-Cutting stems in spring or early summer would 

eliminate plant reproduction, but not the 

infestation. 

- These treatments may take up to ten years 

due to long term seed viability. 

- Revegetate with desirable species in 

accordance with the Restoration Plan. Plant 

communities in good condition may recover 

without replanting. 

Biocontrols available. 

 1. Metsulfuron methyl (forested sites) 

 2. Imazapic (in native grasses) 

 3. Aquatic labeled Glyphosate 

 4. Picloram 

Biocontrols proposed for 

some sites. Aquatic 

Glyphosate may be only 

option for sites near 

streams (some riparian 

sites exist). 

Picloram may be 

restricted in well drained, 

clayey and/or shallow 

soils at some sites. 

Dodder 

Cuscuta sp. 

10 acres 

2 sites 

Mechanical control by roughing out host 

sagebrush 

Field 

bindweed 

(COAR) 

Convolvulus 

arvensis 

3 acres 

1 sites 

Manual/mechanical - Hand pulling works 

easiest with wet soils and with small 

infestations. When grubbing, it is not 

necessary to remove the entire root system 

since the plant is not perennial. It is best to pull 

or grub out the plant prior to flowering.3 

 1.Picloram apply 

 bud to full bloom for best 

 control2 

 2.Glyphosate,full bloom – early seed2 

 3. Metsulfuron actively growing plants2 

No biocontrol available1 

Himalayan 

blackberry 

(RUDI)

Rubus discolor 

15 acres 

3 sites 

Manual removal works best where there is a 

large volunteer workforce. Mechanical 

removal is best used as a first step to reduce 

above ground biomass before root crown 

removal. 

 

Glyphosate, Picloram, Imazapyr or Triclopyr 

Hounds 

tongue

(CYOF) 

(Cynoglossum 

officinale) 

Biennial 

980 ac 

64 sites 

Herbicide in combination with manual 

treatments. Re-vegetate with desirable 

species. 

1. Metsulfuron methyl 

2. Chlorsulfuron 

3. Picloram 

4. Imazapic or Glyphosate 

Some known sites are in 

riparian areas. Several 

areas of well drained 

soils where herbicide 

selection may be 

restricted (see Appendix 

D). 

Six known sites are 

proposed for manual 

only. 

Japanese 78 acres Cutting in combination with herbicide is most Not in treatment 

42
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Target Acres 

Species - Range of Effective 

Common 

Name 

and Site Specific 

Number Treatment Options Considerations 

of Sites 

knotweed 

(POCU6)

Polygonum 

cuspidatum 

Perennial

2 sites effective since the manual/mechanical 

treatments will encourage the plant to send up 

new shoots. The more shoots per linear foot of 

root, the more likely you will be able to 

physically pull them out, exhaust their reserves 

or kill them with herbicide. 

Glyphosate and/or Triclopyr 

database. 

. 

Leafy Spurge

(EUES) 

Euphorbia 

esula 

Rhizomatous 

perennial 

102 ac 

12 sites 

Biocontrols available - Requires combination of 

herbicide, manual and mechanical techniques 

for successful control. Multiple entries per year 

are required. 

 1. Picloram 

2. Glyphosate or Imazapic 

All but one known site is 

riparian. Several well 

drained, excessively well 

drained, and shallow 

water table sites. Use of 

picloram may be limited 

in some areas. . 

Medusahead 

(TACA8) 

(Taeniatherum 

caputmedusae) 

Annual grass 

921 ac 

22 sites 

Repeated cutting/mowing with herbicide 

treatment is effective. Manual removal can be 

effective with small populations. A 

combination of herbicide application and 

reseeding with native grasses is considered 

highly effective. Repeated treatments may be 

needed 

Active restoration (seeding of a competitive 

desirable species) is important. Herbicide 

treatment should be done before seed 

formation or during the fall through early 

winter. 

 1. Imazapic 

 2. Sulfometuron methyl 

+Chlorsulfuron 

 3. Sulfometuron methyl 

 4. Sethoxydim 

 5. Glyphosate 

No known riparian sites. 

Several sites are well 

drained. 

Musk thistle

(CANU4) 

(Carduus 

nutans) 

Biennial 

Bull Thistle 

(CIVU)

Cirsium vulgare 

27 acres 

6 sites 

Use manual, mechanical or herbicide control or 

a combination. Biological controls may be 

helpful to suppress populations in combination 

with other methods (see Appendix E). 

 1. Picloram or Clopyralid 

 2. Metsulfuron methyl 

 3. Glyphosate 

 4. Chlorsulfuron 

Biocontrols proposed for 

some sites. No known 

riparian sites proposed 

for herbicide use. No 

sites are known to be 

well drained or shallow to 

ground water. 

Pepper weed 

(LELA2) 

(Lepedium 

latifolium) 

Perennial

1 acre 

1 site 

1. Chlorsulfuron, 

2. Metsulfuron, 

3. Glyphosate 

4. Imazapic 

5. Triclopyr may only kill top plant and 

capable of resprouting use after 

mowing to increase efficacy 

Not a riparian site or 

known to be well drained 

or shallow to ground 

water. 

43
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Target Acres 

Species - Range of Effective 

Common 

Name 

and Site Specific 

Number Treatment Options Considerations 

of Sites 

Poison 

Hemlock 

7 acres 

3 sites 

Manual/Mechanical: Handpulling when soils 

are wet can be effective on small infestations. 

Mowing at flowering stage can provide some 

control.3 Biocontrol available. 

 1.Glyphosate 0.75 ae/acre at pre-bolt 

stage2; 

 2.Metsulfuron 0.6 oz ai/acre to 

actively growing plants2;; 

Biological: None3 

Puncture vine 

(TRTE) 

(Tribulus 

terrestris) 

Annual 

12 acres 

1 site 

Manual and Mechanical control effective if 

collected prior to seed set. Biocontrol available 

 1. Chlorsulfuron 

 2. Sulfometuron methyl 

 3. Metsulfuron methyl 

 4. Glyphosate or Picloram 

Not on known shallow or 

well drained soils. 

Purple 

loosestrife 

(LYSA2) 

(Lythrum 

salicaria) 

Perennial 

3 acres 

3 sites 

Biocontrols available. 

Otherwise, combination of herbicide and 

manual/mechanical treatments. 

Glyphosate 

Rush 

Skeletonweed 

(CHJU) 

(Chondrilla 

juncea) 

Perennial

390 ac 

36 sites 

Since any mechanical damage to plants 

stimulates new growth resulting in satellite 

plants, such methods are not recommended. 

Rush skeletonweed is a deep rooted, 

rhizomatous perennial considered tolerant to 

herbicides. Therefore, an aggressive follow up 

program with repeated applications will be 

necessary. Difficult to apply because of small 

leaves. Biocontrols proposed for two sites. 

 1. Clopyralid 

 2. Picloram 

No known riparian sites. 

No known shallow or well 

drained soil sites 

Russian 

Knapweed

(ACRE3) 

(Acroptilon 

repens)

Perennial with 

adventitious 

shoots

26 acres 

4 sites 

Lasting control requires an integration of 

techniques: mechanical, manual, herbicide and 

competitive plantings. 

 

 1. Chlorsulfuron 

 2. Clopyralid 

 3. Clopyralid + Triclopyr (Redeem) 

4. Glyphosate, Imazapic, or 

Metsulfuron Methyl 

No known riparian sites. 

Russian 

thistle 

(SATR12 or 

SAIB) (Salsola 

tragus) 

Annual 

10 acres 

1 site 

 Manual or mechanical removal of plant prior 

to seed set can be effective in small 

populations. Repeat visits to areas previously 

infested likely required. 

Spot or hand broadcast with backpack sprayer 

whenever possible. Boom spray larger areas 

of dense cover, where dominant plant 

community is non-native invasives 

 1. Chlorsulfuron 

 2. Metsulfuron methyl 

 3. Glyphosate 

No known riparian sites. 

No known shallow or well 

drained soil sites. 

44
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Target Acres 

Species - Range of Effective 

Common 

Name 

and Site Specific 

Number Treatment Options Considerations 

of Sites 

Scotch Broom

(CYSC4) 

(Cytisus 

scoparius) 

Perennial 

woody shrub 

115 ac 

4 sites 

Biocontrols available. Manual treatments can 

be effective but labor intensive. 

-If herbicides are used, manual treatments 

could be used for follow-up. 

-Re-vegetate with desirable species. 

 1. Hand application of Triclopyr 

 2. Picloram 

 3. Glyphosate 

No known riparian sites. 

No known shallow or well 

drained soil sites 

Biocontrols proposed for 

one site. 

Scotch Thistle

(ONAC) 

Onopordum 

acanthium 

Biennial 

1844 ac 

157 

sites 

Cutting and mowing can be effective when 

combined with revegetation of native species. 

Repeated mowing, in combination with other 

management methods, often is necessary for 

long-term control. Manual removal is effective 

when entire aboveground plant growth is 

removed. Herbicide treatment is the most 

effective control. 

 1. Picloram or Clopyralid 

 2. Chlorsulfuron 

 3. Metsulfuron 

Some riparian sites and 

sites with shallow water 

table or well drained 

soils. Buffers and PDFs 

may reduce the 

herbicides and/or 

methods available. 

Manual treatment 

proposed for some sites 

Slender 

meadow 

foxtail 

(ALMY) 

 (Alopercurus 

myosuroides) 

Annual 

.3 acres 

1 site 

Combination of manual, mechanical and 

herbicide. 

Glyphosate or Sethoxydim 

Silverleaf 

nightshade 

(SOEL) 

(Solanum 

elaeagnifolium) 

Perennial

11 acres 

2 sites 

Manual control can be effective in small areas. 

Shade from crop canopies (60-90% cover) or 

mulching may also be an effective control tool. 

Revisits will be necessary; the number of 

which is dependent on the herbicide used and 

the seed bank. Usually required multiple 

applications. 

 1. Picloram 

 2. Triclopyr or Glyphosate 

Spotted 

knapweed

(CEBI2, 

CEMA4) 

(Centaurea 

biebersteinii) 

Diffuse 

knapweed 

(CEDI) 

(Centaurea 

diffusa) 

Meadow 

knapweed

(CEPR2, 

CEDE5, 

CENI3) 

 (Centaurea 

907 qc 

169 

sites 

4150 ac 

384 

sites 

0 acres 

1 site 

Biocontrols available for some knapweed 

species (see Appendix H R6 2005 FEIS 

Appendix H and White Paper-Spiegel, 2006) 

Herbicide with manual and mechanical 

treatment. Revegetate with desirable species, 

at high priority sites when possible. 

 1. Clopyralid, or Picloram 

 2. Glyphosate 

Several sites are within 

riparian areas or areas 

that have shallow or well 

drained soils. This 

influences the herbicide 

and method available. 

Biocontrols proposed for 

several sites. 

 

45
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Target 

Species - 

Common 

Name 

Acres 

and 

Number 

of Sites 

Range of Effective 

Treatment Options 

Site Specific 

Considerations 

debeauxii)

Squarrose 

knapweed

(CEVIS2) 

(Centaurea 

virgata) 

Knapweed 

species

(CENTA) 

Tap rooted 

Biennials, or 

Perennials 

7 acres 

2 sites 

119 ac 

25 sites 

St John’s 

Wort 

(HYPE) 

Hypericum 

perforatum

603 ac 

56 sites 

Hand pulling or digging of young plants in 

small, isolated infestations may be effective. 

Repeated treatments will be necessary 

because lateral roots can give rise to new 

plants. Pulled or dug plants must be removed 

from the area and burned to prevent vegetative 

regrowth. Mowing is ineffective, but may 

discourage the spread of the plant if done 

before seeds form. Burning may increase the 

density and vigor of this species. Biocontrols 

available. 

 1. Metsulfuron methyl 

 2. Picloram 

 3. Glyphosate 

Biocontrols proposed for 

some sites. 

Some sites are within 

riparian areas or areas 

that have shallow or well 

drained soils. This 

influences the herbicide 

and method available. 

Sulphur 

cinquefoil

(PORE5) 

(Potentilla 

recta) 

Perennial

187 ac 

34 sites 

Hand-pulling is effective on small infested 

provided the entire root is removed. Repeated 

applications are needed for the first couple of 

years to ensure re-establishment does not 

occur. 

 1. Picloram 

 2. Metsulfuron methyl (by itself not a 

particularly effective treatment) 

Several sites are within 

riparian areas or areas 

that have well drained 

soils. This influences the 

herbicide and method 

available. 

Manual treatment 

proposed for some sites. 

Tansy ragwort

(SEJA) 

(Senecio 

jacobaea) 

And other 

Senecio spp. 

Biennial or 

short-lived 

perennial 

78 acres 

49 sites 

Hand pulling is effective if done in moist soils. 

This is most effective after the population has 

been brought under control. Mowing is the 

most common technique and is effective if 

done prior to flowering. These treatments may 

take up to ten years due to long term seed 

viability. 

Biocontrols available (Appendix E). Ensure 

biological controls are present nearby or 

request their introduction. 

Revisits will be necessary; the number of 

which is dependent on the herbicide used and 

the seed bank. 

 1. Clopyralid 

 2. Chlorsulfuron 

 3. Picloram 

 4. Glyphosate 

Biocontrols proposed for 

some sites. 

 

Some riparian sites. No 

sites are known to be in 

sensitive soil areas. 

46
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Target 

Species - 

Common 

Name 

Acres 

and 

Number 

of Sites 

Range of Effective 

Treatment Options 

Site Specific 

Considerations 

Teasel (DIFU2 

or DISY) 

(Dipsascus 

fullonum) 

Biennial

30 acres 

2 sites 

 Manual and Mechanical can be effective alone 

and in combination with herbicides. 

 1. Metsulfuron methyl 

 2. Chlorsulfuron 

 3. Clopyralid or Triclopyr 

All sites are riparian, No 

known sites in areas with 

sensitive soils. 

Whitetop

(CADR) 

(Cardaria 

draba) 

Perennial 

1489 ac 

179 

sites 

Herbicide with manual treatment as a follow 

up. Revegetate with desirable species. 

 1. Chlorsulfuron 

 2. Imazapic or Metsulfuron methyl 

 3. Glyphosate 

Also: Sulfometuron methyl (not ranked) 

Several sites are within 

riparian areas or areas 

that have well drained 

soils. This influences the 

herbicide and method 

available. 

Yellow 

Hawkweed 

(HIPR) 

(Hieracium 

pratense)

16 acres 

29 sites 

Herbicide treatment is most effective. 

- Some manual removal possible for small 

infestations. 

- Manual Disposal: All plant parts should be 

removed, as new plants can bud from root, 

stolon, and rhizome fragments. 

-Covering with a plastic tarp may also work for 

small infestations. 

- Nitrogen fertilization after treatment would 

encourage native plant growth if done in the 

spring. 

- Revegetate with desirable species in 

accordance with the Restoration Plan 

1. Clopyralid 

2. Picloram 

3. Aquatic labeled Glyphosate 

All sites are riparian, 

Aquatic. 

No known sites in areas 

with sensitive soils. 

Yellow 

starthistle 

(CESO3) 

(Centaurea 

solstitialis) 

Annual 

1966 ac 

181 

sites 

Hand-pull small patches or maintenance 

programs where plants are sporadically 

located. Otherwise, mechanical treatment to 

contain and herbicides in combination with 

other methods to control or eradicate. 

-Biocontrol available (see Appendix E). 

- Revegetate high priority sites if needed with 

desirable species. 

Aerial proposed for large, remote sites. 

 1. Clopyralid or Picloram 

 2. Glyphosate 

Some riparian sites. , 

No known sites in areas 

with sensitive soils. 

 

Biocontrols prescribed for 

many sites. 

Please note: Herbicides listed in numerical order represent a preferential order; no numerical listing indicates no 

preference for control, no chemical listed indicates no information available. 

The common control measures shown above reveal that picloram, clopyralid, glyphosate and 

chlorsulfuron are the herbicides that are most often prescribed. Table 6 and Figure 10 below 

show the acreage and percentage of known sites effectively treated by each of these herbicides, 

as well as the additional six herbicides approved for use in Region 6. PDFs may impact the 

choice of herbicides via buffers and other limitations. The decision about which herbicide to use 

would be made as part of the implementation plan. Chapter 2.2.3 displays project design features 

specific to the ten herbicides approved for use in Region 6, as well as the gross acres and 

percentage of known sites where each herbicide would be effective. 

47
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Table 6-Design features specific to the ten herbicides approved for use in Region 6, gross acres and 

percentage of known sites where each herbicide would be effective 

Active 

Ingredient 

Selected 

Herbicide 

Brand 

Names 

Acres of 

known 

sites where 

this 

herbicide 

may be 

effective2 

Percentage 

of known 

sites where 

this 

herbicide 

may be 

effective 

Project Design Features Specific to the Herbicides 

Approved for Use in Region 6 

Chlorsulfuron 

(Telar, Glean, 

Corsair) 12,841 53 

Not labeled for aquatic use. No aerial application 

proposed. 

F-7 Soils evaluated prior to treatment. Treatment of 

powdery, ashy dry soil, or light sandy soil can only be 

treated if rainfall is expected within 24 hrs of treatment. 

H -5 Avoid use of chlorsulfuron on soils with high clay 

content. 

Clopyralid 

(Transline) 18,408 75 

Not labeled for aquatic use. May be aerially sprayed but 

not within 100 feet of dry streams and 300 feet of flowing 

streams. 

F-8o: Clopyralid would be broadcast or aerially applied at 

rates typical or lower application rates. 

H-4: Avoid use of clopyralid on high-porosity soils 

(coarser than loamy sand). 

J-3g: Clopyralid would not be used within 1.5 miles of 

peregrine nest more than once per year. 

Glyphosate35 

formulations, 

including 

RoundUp, 

Rodeo, 

Accord XRT, 

Aquamaster 

15,863 65 

Aquatic label available. No aerial application proposed. 

 

H-2: No broadcast of non-aquatic formulation on roads 

that have a high risk of delivery to water (generally roads 

in RHCAs). 

Imazapic 

(Plateau) 3,325 14 Not labeled for aquatic use. No aerial application 

proposed. 

Imazapyr 

(Arsenal, 

Arsenal AC, 

Chopper, 

Stalker, 

Habitat) 

15 3 

Aquatic formulation available. No aerial application 

proposed. 

 

I-6: Avoid use of imazapyr when vascular or nonvascular SOLI plant species are within 10 feet of 

saturated or wet soils at the time of herbicide application. 

F4. Do not exceed a rate of 0.70 lb active ingredient 

(a.i.)/acre with broadcast and spot applications. 

Metsulfuron 

methyl 

(Escort XP) 

11,287 46 

Not labeled for aquatic use. No aerial application 

proposed. 

F-7 Soils evaluated prior to treatment. Treatment of 

powdery, ashy dry soil, or light sandy soil can only be 

treated if rainfall is expected within 24 hrs of treatment. 

48
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Acres of Percentage Active 

Ingredient 

Selected 

Herbicide 

Brand 

Names 

known of known 

sites where sites where Project Design Features Specific to the Herbicides 

Approved for Use in Region 6 this this 

herbicide herbicide 

may be may be 

effective2 effective 

Picloram 

(Tordon K, 

Tordon 22K) 

21,406 91 

Not labeled for aquatic use. May be aerially sprayed but 

not within 100 feet of dry streams and 300 feet of flowing 

streams. 

H-2: No broadcast on roads that have a high risk of 

delivery to water (generally roads in RHCAs). 

 

F4; F-8o: Lowest effective label rates would be used and 

broadcast applications would not exceed typical label 

rates. Aerial application rates for Picloram would not 

exceed (0.25lb/ai/acre). 

H2 No use of picloram on roads within RHCAs. 

 

H-6: Avoid use of picloram on shallow or coarse soils 

(coarser than loam.) according to herbicide labels. No 

more than one application of picloram would be made 

within a two-year period. 

I-6: Do not use picloram within 10 feet of botanical SOLI 

where soils are saturated at the time of application. 

Sethoxydim 

(Poast, Poast 

Plus) 

948 4 

Not labeled for aquatic use. No aerial application 

proposed. 

H-2: No broadcast on roads that have a high risk of 

delivery to water (generally roads in RHCAs). 

Sulfometuron 

methyl 

(Oust, Oust 

XP) 2,471 10 

Not labeled for aquatic use. No aerial application 

proposed. 

F-7 Soils evaluated prior to treatment. Treatment of 

powdery, ashy dry soil, or light sandy soil can only be 

treated if rainfall is expected within 24 hrs of treatment. 

H-7: Avoid use of sulfometuron methyl on shallow or 

coarse soils (coarser than loam.) No more than one 

application of sulfometuron methyl would be made within 

a one-year period. 

O-1b: Backpack Application - Sulfometuron methyl 

application rate will not exceed 0.2 lb a.i./ac 

O-1e: Ground Boom Application - Sulfometuron methyl 

application rate will not exceed 0.12 lb a.i./ac 

Triclopyr 

(Garlon 3A, 

Garlon 4, 

Forestry 

Garlon 4, 

Pathfinder II, 

Remedy, 

Remedy 

RTU, 

Redeem 

R&P) 

3,671 15 

Aquatic labeled formulation available. No aerial or 

broadcast application proposed. 

H-2: No broadcast non-aquatic formulation on roads that 

have a high risk of delivery to water (generally roads in 

RHCAs). 

 

L-1: Triclopyr would not be applied to foliage in areas of 

known special forest products or other wild food 

collection areas. 

49
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Acres of Percentage Active 

Ingredient 

Selected 

Herbicide 

Brand 

Names 

known of known 

sites where sites where Project Design Features Specific to the Herbicides 

Approved for Use in Region 6 this this 

herbicide herbicide 

may be may be 

effective2 effective 

O1a: Triclopyr backpack application rates would be lower 

than 1.0lb a.i. per acre. 

Figure 10 – Potential percent of acres available for use per herbicide 

0

10

2 0

3 0

4 0

5 0

6 0

7 0

8 0

9 0

10 0

Potential Percent of Sites

Chlorsulfuron

Clopyralid

Glyphosate 

 Imazapic

Imazapyr

Metsulfuron methyl

Picloram

Sethoxydim

Sulfometuron methyl

Triclopyr

50
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Project Design Features 

The following Project Design Features (PDFs) minimize the potential adverse impacts of 

invasive plants treatment and provide sideboards for EDRR. The PDFs were developed to 

respond to the site-specific resource conditions within the treatment areas, including (but not 

limited to) the current invasive plant inventory, the presence of special interest species and their 

habitats, potential for herbicide delivery to water, and the social environment. Implementation 

of the PDFs would be mandatory. The analysis assumes buffers approximate horizontal (map) 

distances. 

The effectiveness of the PDFs is addressed throughout Chapter 3. In some cases, the PDFs 

eliminate an herbicide exposure of concern, for instance, limits the method or rate of herbicide 

application to avoid a specific type of exposure that risk assessments indicate is over a level of 

concern for people or the environment. In other cases, the PDFs reduce potential for herbicide 

exposure to have an effect, but do not necessarily eliminate that potential. The purpose and 

source of each PDF is provided in the list below. 

These PDFs were developed for application to new detections as well as known sites, to ensure 

that the effects of treating new sites are similar to the effects of treating existing sites. 

A-Pre-Project Planning 

A-1: Prior to treatment, confirm species/habitats of local interest, sensitive areas (e.g. streams, 

lakes, roadside treatment areas with higher potential to deliver herbicide to water, municipal 

watersheds, domestic water sources, shallow water table), recreation and administrative sites, 

and range allotments. Apply appropriate PDFs described in the following text and all that apply 

from the Regional EIS/Forest Plan. 

For EDRR sites follow the decision process (see figure 12) to determine the type and method 

of treatment and apply applicable PDFs. 

• Purpose: Ensure project is implemented appropriately. 

• Source: This approach follows several previous NEPA documents. Pre-project planning 

also discussed in the previous section. 

B-Coordination with Other Landowners and Agencies 

B-1: Work with owners and managers of neighboring lands to respond to invasive plants that 

straddle multiple ownerships. Coordinate treatments within appropriate distances based on 

invasive plant species reproductive characteristics, and current use of area. 

• Purpose: To ensure that neighbors are fully informed about nearby herbicide use and to 

increase the effectiveness of treatments on multiple ownerships 

• Source: A variable distance based on site and species specific characteristics was chosen 

because it adjusts for various conditions that exist in these areas. All PDFs related to 

riparian areas and buffer distances will be followed. 

C-To Prevent the Spread of Invasive Plants during Treatment Activities 

C-1: Ensure vehicles and equipment (including personal protective clothing) does not transport 

invasive plant materials. 

• Purpose: To meet Standards 

• Source: Wallowa-Whitman LRMP as amended by the R6 2005 ROD Standard #1 

51
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

D-Wilderness Areas2 

D-1: For EDRR in wilderness and Research Natural Areas (RNAs), invasive plants could be 

treated using non-mechanical hand methods or herbicides. Herbicide treatments may use 

application methods such as wicking, stem injection, spray bottle, hand pressurized pumps, 

battery or solar powered pumps and propellant based systems such as those that use pressurized 

carbon dioxide. 

• Purpose: To reduce the effects of invasive plant treatments on the untrammeled quality 

of wilderness character 

E-Non-herbicide Treatment Methods 

E-1: Limit the numbers of workers on any one site at any one time while treating areas within 

150 feet of creeks. 

• Purpose: To minimize trampling, protect riparian and aquatic habitats, and prevent 

potential invasive plant spread via waterway dispersal 

• Source: The distance of 150 feet was selected because it incorporates the Aquatic 

Influence Zone for fish bearing streams 

E-2: Fueling of gas-powered equipment with tanks larger than 5 gallons would not occur inside 

the RHCA unless there is no other alternative. 

• Purpose: To protect riparian and aquatic habitats 

• Source: The distance of 150 feet was selected because it incorporates the Aquatic 

Influence Zone for fish bearing streams 

F-Herbicide Application 

F-1: Herbicides would be used in accordance with label instructions, except where more 

restrictive measures are required as described below. Herbicide applications would only treat the 

minimum area necessary to meet site objectives. Herbicide formulations would be limited to 

those containing one or more of the following 10 active ingredients: chlorsulfuron, clopyralid, 

glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, sethoxydim, sulfometuron 

methyl, and triclopyr. Herbicide application methods include wicking, wiping, injection, spot, 

and broadcast, as permitted by the product label and these Project Design Features. The use of 

triclopyr is limited to spot and hand/selective methods. R-6 2005 ROD Standard 18 permits only 

the use of adjuvants reviewed in Forest Service risk assessment documents. 

• Purpose: To limit potential adverse effects on people and the environment 

• Source: W-W LRMP as amended by the R6 2005 ROD Standard 16, Pesticide Use 

Handbook 2109.14 

 

2

 Invasive plant eradication within Wilderness meets the “no impact” intent of the Wilderness Act and 

associated land use policies 

52
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

F-2: Herbicide use would comply with standards in the Forest Plan as amended by the R6 2005 

ROD, including standards on herbicide selection, restrictions on broadcast use, tank mixing, 

licensed applicators, and use of adjuvants, surfactants and other additives. 

• Purpose: To limit potential adverse effects on people and the environment 

• Source: W-W LRMP as amended by the R6 2005 ROD Treatment Standards (see 

Chapter 1) 

F-3: POEA surfactants, urea ammonium nitrate or ammonium sulfate would not be used in 

applications within 150 feet of surface water, wetlands or on roadside treatment areas having 

high potential to deliver herbicide. 

• Purpose: To protect aquatic ecosystems 

• Source: The distance of 150 feet was selected because it is wider than the largest buffer 

and incorporates the Aquatic Influence Zone for fish bearing streams. This distance is 

sufficient to avoid harm to the aquatic environment, based on risk assessments, previous 

monitoring, and studies related to chemical behavior in the environment (see Chapter 3). 

F4: Lowest effective label rates would be used. No broadcast applications of herbicide or 

surfactant will exceed typical label rates (except see aerial F-8o). NPE surfactant would not be 

ground-based broadcast at a rate greater than 0.5 lbs. a.i./ac (pounds of active ingredient per 

acre). Favor other classes of surfactants wherever they are expected to be effective. 

• Purpose: To eliminate possible herbicide or surfactant exposures of concern to human 

health, wildlife, and aquatic organisms 

• Source: Based on SERA Risk Assessment for imazapyr there would be no exposure 

concerns 

F-5: Herbicide applications would occur when wind velocity is between two and eight miles per 

hour to reduce the chance of drift. (Appendix F) During application, weather conditions would 

be monitored periodically by trained personnel. 

• Purpose: To ensure proper application of herbicide and reduce drift 

• Source: These restrictions are typical so that herbicide use is avoided during inversions 

or windy conditions 

F-6: To minimize herbicide application drift during broadcast operations, use low nozzle 

pressure; apply as a coarse spray, and use nozzles designed for herbicide application that do not 

produce a fine droplet spray, e.g., nozzle diameter to produce a median droplet diameter of 500-

800 microns. 

• Purpose: To ensure proper application of herbicide and reduce drift 

53
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

• Source: These are typical measures to reduce drift. The minimum droplet size of 500 

microns was selected because this size is modeled to eliminate adverse effects to nontarget vegetation 100 feet or further from broadcast sites (see Chapter 3 for details). 

F-7: Use of sulfonylurea herbicides (Chlorsulfuron, Sulfometuron methyl and Metsulfuron 

methyl), will require soils on site to be evaluated prior to treatment. Treatment of powdery, ashy 

dry soil, or light sandy soil can only be treated if rainfall is expected within 24 hrs of treatment. 

• Purpose: To avoid herbicide drift caused by wind erosion of dry soils containing 

sulfonylurea chemical residue 

• Source: Label advisory 

F-8 - Additional design features specific to aerial application corresponding to Appendix FAerial Spray Guidelines: 

F-8a: Aerial application of herbicide will not be used for treatment of EDRR sites. 

• Purpose: To reduce potential adverse effects to non-target species 

F-8b: Chlorsulfuron, metsulfuron methyl, sulfometuron methyl and triclopyr will not be applied 

aerially. 

• Purpose: To reduce potential adverse effects to non-target species 

• Source: W-W LRMP as amended by the R6 2005 ROD 

F-8c: Provide a minimum buffer of 300 feet for aerial application of herbicides near developed 

campgrounds, recreation residences and private land (unless otherwise authorized by adjacent 

private landowners). 

• Purpose: To minimize impacts to human health 

• Source: W-W LRMP as amended by the R6 2005 ROD 

F-8d: Prohibit aerial application of herbicides within congressionally designated municipal 

watersheds. See B2 for other developed water sources. 

• Purpose: To protect water supplies 

• Source: W-W LRMP as amended by the R6 2005 ROD 

F-8e: Effectiveness Monitoring required for “a representative sample” of treatments involving 

aerial application of herbicide. 

• Purpose: To insure impacts to non-target species are within tolerance 

• Source: Appendix I, R6 2005 FEIS 

54
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

F-8f: Herbicide buffers have been established for perennial and wet intermittent streams, dry 

streams and lakes and wetlands. These buffers are shown in the tables below. 

• Purpose: To reduce the likelihood that herbicides would enter surface water in levels of 

concern 

• Source: Buffers based on SERA risk assessments, label advice., and Berg’s 2004 study 

of broadcast drift and run off to streams; monitoring data from other herbicide 

application project 

F-8g: Buffer distances for federally listed SOLIs will follow Recovery Plan recommendations. 

No aerial application would occur within 300 feet of non-federally listed SOLIs. Spray cards to 

monitor drift can be used in conjunction with monitoring and adaptive management to adjust 

buffers if needed. 

• Purpose: To protect SOLIs and reduce non-target effects. To comply with W-W LRMP 

as amended by the R6 2005 ROD Standards 19 & 20 

• Source: Forest Service Manual 2670 and applicable federally listed recovery plans 

F-8h: Aerial spraying of invasive species will not occur in areas with 30 percent or more live 

tree canopy cover. For live tree canopy cover between 10-29 percent an on-site decision whether 

or not to aerial spray would be based on factors such as target invasive species, herbicides 

(specificity) proposed for treatment, and potential impacts to non-target tree species. 

• Purpose: To reduce potential adverse effects to non-target species 

• Source: Common measure 

F-8i: Aerial spray units (and perennial seeps, ponds, springs, and wetlands in proposed aerial 

units) will be ground-checked, flagged and marked using GPS prior to spraying to ensure only 

appropriate portions of the unit are aerially treated. A GPS system will be used in spray 

helicopters and each treatment unit mapped before the flight to ensure that only areas marked for 

treatment are treated. Plastic spray cards will be placed out to 350 feet from and perpendicular 

to perennial creeks to monitor herbicide presence. 

• Purpose: To reduce potential adverse effects to non-target species 

• Source: Common measure 

F-8j: Press releases will be submitted to local newspapers indicating potential windows of 

treatment for specific areas. Signing and on-site layout will be performed one to two weeks 

prior to actual aerial treatment. 

• Purpose: To meet Standard #23 

55
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

• Source: W-W LRMP as amended by the R6 2005 ROD Standard #23 

F-8k: Grazing permittees will be notified at annual permittee meeting that aerial application will 

be conducted. Permittee will also be notified of specific time frames in which treatment would 

occur to ensure grazing animals are removed from the area. 

• Purpose: To ensure grazing animals are not exposed to aerial herbicide applications 

F-8l: Enforceable temporary area, trail, and road closures will be used to ensure public safety 

during aerial spray operations. 

• Purpose: To meet Standard #23 

• Source: W-W LRMP as amended by the R6 2005 ROD Standard #23 

F-8m: Constant communications will be maintained between the helicopter and the project 

leader during spraying operations. Ground observers will have communication with the project 

leader. Observers will be located at various locations adjacent to the treatment area to monitor 

wind direction and speed as well as to visually monitor drift and deposition of herbicide. 

• Purpose: To prevent effects to non-target species 

F-8n: Aerial swath displacement buffers would be applied as needed as described in Table 10 

below 

• Purpose: To protect resources in the worst case scenario 

F-8o: Aerial application rates for Picloram would not exceed (0.25lb/ai/acre), and clopyralid 

would not exceed typical application rates (0.35lb ai/acre) 

• Purpose: To prevent effects to non-target species 

• Source: SERA Risk Assessments, aerial drift modeling (See Appendix B) 

G-Herbicide Transportation and Handling Safety/Spill Prevention and Containment 

Design Features for G: An Herbicide Transportation and Handling Safety/Spill Response Plan 

would be the responsibility of the herbicide applicator. At a minimum the plan would: 

-Address spill prevention and containment. 

-Estimate and limit the daily quantity of herbicides to be transported to treatment sites. 

-Require that impervious material be placed beneath mixing areas in such a manner as to 

contain small spills associated with mixing/refilling. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

-Require a spill cleanup kit be readily available for herbicide transportation, storage and 

application (minimum FOSS Spill Tote Universal or equivalent). 

-Outline reporting procedures, including reporting spills to the appropriate regulatory 

agency. 

-Ensure applicators are trained in safe handling and transportation procedures and spill 

cleanup. 

-Require that equipment used in herbicide storage, transportation and handling are 

maintained in a leak proof condition. 

-Select transportation routes to minimize exposure to traffic, domestic water sources, and 

adjacent water sources 

-Specify conditions under which guide vehicles would be required. 

-Specify mixing and loading locations away from water bodies so that accidental spills do 

not contaminate surface waters. 

-Require that spray tanks be mixed or washed further than 150 feet of surface water. 

-Ensure safe disposal of herbicide containers. 

-Identify sites that may only be reached by water travel and limit the amount of herbicide 

that may be transported by watercraft (see H12). 

• Purpose: To reduce likelihood of spills and contain any spills. 

• Source: FSH 2109.14 

H- Soils, Water and Aquatic Ecosystems 

H-1: Herbicide use buffers have been established for perennial and wet intermittent steams; dry 

streams; and lakes and wetlands. These buffers are depicted in Table 7, Table 8, and Table 9 

below. Buffers vary by herbicide ingredient and application method. Tank mixtures would apply 

the largest buffer as indicated for any of the herbicides in the mixture. 

• Purpose: To reduce likelihood that herbicides would enter surface waters in 

concentrations of concern 

• Source: Treatments within RHCAs are allowed if they meet Riparian Management 

Objectives (RMOs) including minimizing adverse effects to listed fish; therefore, buffers 

are based on label advisories, SERA risk assessments and Berg’s 2004 study of 

broadcast drift and run off to streams. Buffers are intended to demonstrate compliance 

with WAW LRMP as amended by the R6 2005 ROD Standards 19 and 20. 

H-2: No broadcast of high aquatic risk herbicides on roads that have a high risk of delivery to 

water (generally roads in RHCAs). These herbicides are picloram or non-aquatic triclopyr 

(Garlon 4), non aquatic glyphosate, and sethoxidim. 

• Purpose: To ensure high risk herbicides are not delivered to streams in concentrations 

that exceed levels of concern 

• Source: SERA Risk Assessments, R6 2005 FEIS Fisheries Biological Assessment 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

H-3: In riparian and aquatic settings, vehicles (including all terrain vehicles) used to access 

invasive plant sites for invasive plants treatment, apply foam, or for broadcast spraying would 

remain on roadways, trails, parking areas to prevent damage to riparian vegetation, soil, water 

quality and aquatic habitat. 

• Purpose: To protect riparian and aquatic habitats 

• Source: Common measure 

H-4: Avoid use of clopyralid on high-porosity soils (coarser than loamy sand). 

• Purpose: To avoid leaching/ground water contamination 

• Source: Label advisory 

H-5: Avoid use of chlorsulfuron on soils with high clay content (finer than loam). 

• Purpose: To avoid excessive herbicide runoff 

• Source: Label advisory 

H-6: Avoid use of picloram on shallow or coarse soils (coarser than loam.) according to 

herbicide labels. No more than one application of picloram would be made within a two-year 

period. 

• Purpose: To reduce the potential for picloram to enter surface and/or ground water 

and/or accumulate in the soil. Picloram has the highest potential to impact organisms in 

soil and water, and tends to be more persistent than the other herbicides. 

• Source: SERA Risk Assessment. Based on quantitative estimate of risk from worst-case 

scenario and uncertainty 

 

H-7: Avoid use of sulfometuron methyl on shallow or coarse soils (coarser than loam.) No 

more than one application of sulfometuron methyl would be made within a one-year period. 

• Purpose: To reduce the potential for sulfometuron methyl accumulation in the soil; 

sulfometuron methyl has some potential to impact soil and water organisms and is 

second most persistent. 

• Source: SERA Risk Assessments: Based on quantitative estimate of risk from worst-case 

scenario and uncertainty 

H-8: Lakes and Ponds – No more than half the perimeter or 50 percent of the vegetative cover 

within established buffers or 10 contiguous acres around a lake or pond would be treated with 

herbicides in any 30-day period. This limits area treated within riparian areas to keep refugia 

habitat for reptiles and amphibians. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

• Purpose: To reduce exposure to herbicides by providing some untreated areas for some 

organisms to use 

• Source: SERA Risk Assessments: Based on quantitative estimate of risk from worstcase scenario and uncertainty regarding effects to reptiles and amphibians 

H-9: Wetlands – Wetlands would be treated when soils are driest. If herbicide treatment is 

necessary when soils are wet, use aquatic labeled herbicides. Favor hand/selective treatment 

methods where effective and practical. No more than 10 contiguous acres or fifty percent 

individual wetland areas would be treated in any 30-day period. 

• Purpose: To reduce exposure to herbicides by providing some untreated areas for some 

organisms to use 

• Source: SERA Risk Assessments. Based on quantitative estimate of risk from worst-case 

scenario, uncertainty in effects to some organisms, and label advisories 

H-10: Foaming would only be used on invasive plants that are further than 150 feet from 

streams and other water bodies. 

• Purpose: To limit the amount of foam that may be delivered to streams and other water 

bodies 

• Source: No label regulations are associated with this naturally occurring organic 

compound. The distance of 150 feet was selected because it incorporates the Aquatic 

Influence Zone for fish bearing streams 

H-11: Herbicide use would not occur within 100 feet of wells or 200 feet of spring 

developments. For stock tanks located outside of riparian areas, use wicking, wiping or spot 

treatments within 100 feet of the watering source. 

• Purpose: Safe drinking water. Also to reduce the potential chance of herbicide delivery 

to watering systems used for grazing animals 

• Source: Label advisories and state drinking water regulations 

H-12: When chemicals need to be carried over water by boat, raft or other watercraft, herbicides 

will be carried in water tight, floatable containers. 

• Purpose: Lower the risk of herbicide being delivered to streams in concentrations that 

exceed levels of concern 

H-13: In aquatic settings, herbicide applications from water's edge to bank-full width will be 

limited to 2 acres for every 1.6 miles of stream length per 6th field HUC. Treatments above 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

bankfull, within the aquatic influence zone (riparian area), would not exceed 10 acres along any 

1.6 mile of stream length per 6th field HUC. 

• Purpose: Limits the extent of treatment from the water’s edge through the aquatic 

influence zone so that adverse effects are within the scope of analysis 

• Source: Analyses based on SERA risk assessment worksheets. Ten acres is based on 

GLEAM model factors. 

I - Vascular and Non-Vascular Plant and Fungi Species of Local Interest (SOLI) 

I-1: Botanical surveys may be necessary prior to treatment applications to identify vascular and 

non-vascular SOLI occurrence in or near areas proposed for invasive plant treatments. Lists of 

target SOLI to include in each treatment area will be developed by qualified botanical personnel 

based on the range and distribution of SOLI species and the presence of suitable SOLI habitat. If 

surveys are deemed necessary, they will be conducted within the proposed treatment area and 

immediately adjacent to the treatment area as follows: 300 to1000 feet of planned aerial 

treatments (see I-7), 100 feet of planned broadcast treatments, and 10 feet of planned spot 

treatments and/or 5 feet of planned hand herbicide treatments. 

• Purpose: To ensure SOLI are protected and surveys are conducted when appropriate 

• Source: Forest Service Manual 2670 and applicable federally listed recovery plans 

I-2: If circumstances will not permit surveys prior to treatment then all suitable SOLI habitat 

identified to occur within and around the treatment area will be managed as if the habitat were 

occupied by SOLI species. In absence of botanical surveys: no aerial herbicide treatment will 

occur within 300 to 1000 feet of SOLI habitat (see section I6), and no ground based broadcast, 

spot, or hand treatments will occur within 100 feet of SOLI habitat. 

• Purpose: To ensure SOLI are protected and surveys are conducted when appropriate 

• Source: Forest Service Manual 2670 and applicable federally listed recovery plans 

I-3: Modify treatments to protect SOLI occurrences based on their distance from the treatment 

area: 

Greater than 100 feet: All ground based treatments are permitted (see I-6 and aerial section for 

additional buffer restrictions) 100 to 10 feet: Manual and mechancial methods permitted. 

Broadcast herbicide methods permitted if SOLIs can be completely protected using a protective 

cover, otherwise use other protective measures such as low-pressure spot-spray, directed spray 

applications or hand application methods to eliminate any potential for drift. 

Less than 10 feet: No broadcast spraying is permitted. Spot treatment using hand application 

methods is permitted. For saturated or wet soils see I-6. Manual treatment methods are 

permitted. Precautions must be taken to avoid any contact with individual SOLI. 

• Purpose: To ensure SOLI are protected and surveys are conducted when appropriate 

• Source: Forest Service Manual 2670 and applicable federally listed recovery plans 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

I-4: Picloram will not be used within 50 feet of the threatened plant species Silene spaldingii 

and Mirabilis macfarlanei. 

• Purpose: To ensure protection of emerging seedlings and potential non-target plant root 

uptake due to herbicide soil persistence 

• Source: US FWS Conservation Strategy (2004). 

I-5: In the vicinity of S. spaldingii, M. mirabilis and all other SOLI, restoration and cultural 

treatments, including seeding and/or use of fertilizer, will be under the direct supervision of the 

district or forest botanist to ensure that plant communities are restored to their desired condition 

without negative impacts to existing SOLI populations or individuals. The vicinity areas will be 

evaluated on a case by case basis. 

• Purpose: To ensure soil chemistry/biology is not negatively impacted which can 

potentially alter the subsequent establishment of resident seedbank species. 

• Source: Professional judgement 

I-6: When vascular or non-vascular SOLI plant species are within 10 feet of saturated or wet 

soils at the time of herbicide application, only hand methods (wiping, stem injection, etc.) would 

be used. Avoid the use of picloram and imazapyr in this situation, and use aquatic triclopyr with 

caution as typical application rates can result in concentrations greater than estimated or 

measured “no observable effect concentration” to aquatic plants (R6 2005 FEIS, Table 4-47). 

• Purpose: To ensure SOLI are protected and surveys are conducted when appropriate 

• Source: Forest Service Manual 2670 and applicable federally listed recovery plans. 

Aerial drift buffers were derived from various scientific publications (See aerial 

application methods) 

I-7: Aerial herbicide applications will follow Recovery Plan recommendations for listed species 

(FWS). Presently, two federally listed species (Silene spaldingii and Mirabilis macfarlanei) are 

documented on the forest. Recovery plan recommend no aerial herbicide within 1000 feet of 

occurrence for S. spaldingii and not adjacent to M. macfarlanei. A 1000 foot buffer for aerial 

application will be used for both species. For non-federally listed SOLI, no aerial herbicide 

applications would occur within 300 feet of known location of SOLI and spray cards to monitor 

drift would be used to monitor drift and adjust buffers if needed (See I-8 and section F8-Aerial 

PDFs). 

• Purpose: To ensure SOLI are protected and surveys are conducted when appropriate 

• Source: Forest Service Manual 2670 and applicable federally listed recovery plans. 

Aerial drift buffers were derived from various scientific publications (See aerial 

application methods Appendix F) 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

I-8: A USDA Forest Service botanist would use monitoring results to refine buffers in order to 

adequately protect vascular and nonvascular plant species of local interest. 

• Purpose: To prevent any repeated effects to SOLI populations, thereby mitigating any 

long term effects 

• Source: Broadcast buffer sizes are based on Marrs, 1989 based on tests on vascular 

plants. Spot and hand/select buffer distances are based on reports from experienced 

applicators. Uncertainty about effects on non vascular plants would be addressed 

through monitoring (See I-9) 

I-9: The impacts of herbicide use on plant Species of Local Interest (SOLI) are uncertain, 

especially regarding lichen and bryophytes. The potential for variances in aerial drift due to 

uncontrolled weather conditions during treatment may also be uncertain. To manage this 

uncertainty, representative samples of herbicide treatment sites adjacent to vascular and nonvascular plant SOLIs would be monitored. Non-target vegetation within 1000 feet of aerial 

treatment sites, 500 feet of herbicide broadcast treatment sites and 20 feet of herbicide spot and 

hand treatment sites would be evaluated before treatment, immediately after treatment, and two 

to three months later as appropriate. Treatment buffers would be expanded if damage is found as 

indicated by: (1) Decrease in the size of the SOLI plant population, or (2) Leaf discoloration or 

chlorophyll change 

• Purpose: To prevent any repeated effects to SOLI populations, thereby mitigating any 

long term effects 

I-10: Compliance monitoring would occur before implementation to ensure that prescriptions, 

contracts and agreements integrate appropriate Project Design Features. This will be done via a 

pre-work review. 

I-11: Implementation monitoring would occur during implementation to ensure Project Design 

Features are implemented as planned. An implementation monitoring form will be used to 

document daily field conditions, activities, accomplishments and/or difficulties. Contract 

administration mechanisms would be used to correct deficiencies. Herbicide use will be reported 

as required by the Forest Service Health Pesticide Use Handbook (FSH 2109.14) 

I-12: Effectiveness monitoring would occur before, during and after treatment to determine 

whether invasive plants are being effectively controlled and to ensure non-target vegetation, 

especially native vascular and non-vascular species of local interest are adequately protected. 

• Source: Tiering to PNW ROD and PNW FEIS Appendix M: Inventory and Monitoring 

Plan Framework 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

J - Wildlife Species of Local Interest 

J-1: Bald Eagle 

J-1a: Treatment of areas within 0.25 mile, or 0.50 mile line-of-sight, of bald eagle nests would 

be timed to occur outside the nesting/fledging season of January 1 to August 31, unless treatment 

activity is within ambient levels of noise and human presence (as determined by a local 

specialist). Occupancy of nest sites (i.e. whether it is active or not) would be determined each 

year prior to treatments. 

• Purpose: To minimize disturbance to nesting bald eagles and protect eggs and nestlings 

• Source: Bald Eagle Management Guidelines for OR-WA (Anonymous); U.S. Fish and 

Wildlife Service 2003, p. 9 

J-1b: Noise-producing activity above ambient levels would not occur between October 31 and 

March 31 during early morning or late afternoon near known winter roosts and concentrated 

foraging areas. Disturbance to daytime winter foraging areas would be avoided. 

• Purpose: To minimize disturbance and reduce energy demands during stressful winter 

season 

• Source: Bald Eagle Management Guidelines for OR-WA (Anonymous); t Programmatic 

BO (U.S. Fish and Wildlife Service 2003, p. 9) 

J-2: Grey Wolf 

J-2a: Treatments within 1 mile of active wolf dens would be timed to occur outside the season 

of occupancy (April 1 through June 30) 

• Purpose: To minimize disturbance and reduce energy demands on denning wolves 

• Source: Federal Register, Vol, 68, No, 62 4(d) 

J-2b: Treatments within 0.50 mile or 0.50 mile line-of-sight of occupied rendezvous sites would 

be timed to occur outside the season of occupancy unless treatment activity is within acceptable 

ambient noise levels and human presence would not cause wolves to abandon the site (as 

determine by a local specialist) 

• Purpose: To minimize disturbance/impacts to wolves at rendezvous sights. 

• Source: Buffer is based on expected range of disturbance 

J-2c: Consultation with FWS would be reinitiated (unless determined otherwise by FWS) 

if/when wolf dens or rendezvous sites are discovered in the vicinity of treatment sites. 

J-3 Peregrine Falcon 

J-3a: Seasonal restrictions (J3-c to g) will be applied based on the spatial and temporal factors 

listed in J3-b. Restrictions would apply to all known peregrine falcon nest sites for the periods 

listed below based on the following elevations: 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Low elevation sites (1000-2000 ft 01 Jan - 01 July 

Medium elevation sites (2001 - 4000 ft) 15 Jan - 31 July 

Upper elevation sites (4001+ ft) 01 Feb - 15 Aug 

• Purpose: To reduce disturbance to nesting falcons and protect eggs and nestlings. 

Agitated parents can damage the eggs with thin shells resulting in failed reproduction for 

that nest. 

• Source: Pagel J. 2006. Peregrine falcon nest site data, 1983-2006. 

J-3b: Seasonal restrictions would be waived if the site is unoccupied or if nesting efforts fail 

and monitoring indicates no further nesting behavior. Seasonal restrictions would be extended if 

monitoring indicates late season nesting, asynchronous hatching leading to late fledging, or 

recycle behavior which indicates that late nesting and fledging would occur. The nest zones 

associated with those nest sites are described below: 

(1) Primary: average of 0.5-mile radius from the nest site. Site-specific primary nest zones 

would be determined and mapped by a local Biologist for each known nest site. 

(2) Secondary: average of 1.5- mile radius from the nest site. Site-specific secondary nest 

zones would be determined and mapped for each known nest site. 

(3) Tertiary: a three-mile radius from the nest site including all zones. The tertiary nest zones 

are not mapped; they apply to a circular area based on the three-mile radius. 

• Purpose: To reduce disturbance to nesting falcons and protect eggs and nestlings. 

Agitated parents can damage the eggs with thin shells resulting in failed reproduction for 

that nest. 

• Source: Pagel J. 2006. Peregrine falcon nest site data, 1983-2006 

J-3c: Protection of nest sites would be provided until at least two weeks after all young have 

fledged. 

• Purpose: To reduce disturbance to nesting falcons and protect eggs and nestlings. 

Agitated parents can damage the eggs with thin shells resulting in failed reproduction for 

that nest 

• Source: Pagel J. 2006. Peregrine falcon nest site data, 1983-2006 

J-3d: Invasive plant activities within the secondary nest zone requiring the use of machinery 

would be seasonally restricted. This may include activities such as mulching, chainsaws, 

vehicles (with or without boom spray equipment) or other mechanically based invasive plant 

treatment. 

• Purpose: To reduce disturbance to nesting falcons and protect eggs and nestlings. 

Agitated parents can damage the eggs with thin shells resulting in failed reproduction for 

that nest. 

• Source: Pagel J. 2006. Peregrine falcon nest site data, 1983-2006 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

J-3e: Non-mechanized or low disturbance invasive plant activities (such as spot spray, hand pull, 

etc.) within the secondary nest zone would be coordinated with the wildlife biologist on a caseby-case basis to determine potential disturbance to nesting falcons and identify mitigating 

measures, if necessary. Non-mechanized invasive plant activities such as back pack spray, 

burning, hand-pulling, lopping, and/or re-vegetation planting may be allowed within the 

secondary nest zone during the seasonal restriction period. 

• Purpose: To reduce disturbance to nesting falcons and protect eggs and nestlings. 

Agitated parents can damage the eggs with thin shells resulting in failed reproduction for 

that nest. 

• Source: Pagel J. 2006. Peregrine falcon nest site data, 1983-2006 

J-3f: All foot and vehicle entries into Primary nest zones would be seasonally prohibited except 

for the following reasons: 

(1) Biologists performing monitoring in association with the eyrie and coordinated 

with the District Biologist. 

(2) Law enforcement specialists performing associated duties with notice to the 

District Ranger. 

(3) Access for fire, search/rescue, and medical emergencies under appropriate 

authority (Forest Service line officer or designee). 

(4) Trail access, when determined by a biologist to be non-disturbing. 

(5) Other exceptions on a case-by-case basis as determined by the Deciding Official 

• Purpose: To reduce disturbance to nesting falcons and protect eggs and nestlings. 

Agitated parents can damage the eggs with thin shells resulting in failed reproduction for 

that nest. 

• Source: Pagel J. 2006. Peregrine falcon nest site data, 1983-2006 

J-3g: Picloram and clopyralid would not be used within 1.5 miles of peregrine nest more than 

once per year. 

• Purpose: To reduce exposure to hexachlorobenze, which has been found in peregrine 

falcon eggs 

• Source: Pagel J. 2006. Peregrine falcon nest site data, 1983-2006 

J-4 Painted Turtle 

J-4a: The local Forest Service Biologist will review treatment locations, timing, and methods to 

minimize adverse impacts to painted turtles PDF H10 defines herbicide treatment limitations to 

protect amphibian habitat. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

• Purpose: To minimize disturbance, trampling, and herbicide exposure to painted turtles 

• Source: David Anderson, WA Dept. of Fish and Wildlife, personal communication, 2005 

J-5 Greater Sage Grouse (If discovered and documented on the W-WNF) 

J-5a: Do not use NPE-based surfactants in areas where sage grouse may forage. 

• Purpose: To minimize exposure to disturbance, herbicides and surfactants that could 

pose a risk 

J-5b: Human activities within 0.3 mile of leks will be prohibited from the period of one hour 

before sunrise until four hours after sunrise and one hour before sunset until one hour after 

sunset from February 15 – May 15. 

• Purpose: To minimize exposure to disturbance, herbicides and surfactants that could 

pose a risk 

J-5c: Do not conduct any vegetation treatments or improvement project in breeding habitats 

from February 15 – June 30. 

• Purpose: To minimize exposure to disturbance, herbicides and surfactants that could 

pose a risk 

K-Public Notification 

K-1: The public would be notified about upcoming herbicide treatments via the local newspaper 

or individual notification, fliers, and posting signs. Forest Service and other websites may also 

be used for public notification. 

• Purpose: To reduce the risk of inadvertent public contact with herbicide 

• Source: W-W LRMP as amended by the R6 2005 ROD Standard 23 

L-Special Forest Products 

L-1: Triclopyr would not be applied to foliage in areas of known special forest products or other 

wild food collection areas. 

• Purpose: To reduce the chance that people might be exposed to harmful doses of 

triclopyr 

• Source: Appendix Q of the R6 2005 FEIS 

L-2: Special forest product gatherers would be notified about herbicide treatment areas when 

applying for their permits. Flyers indicating treatment areas may be included with the permits. 

• Purpose: To reduce the risk of inadvertent public contact with herbicide 

• Source: W-W LRMP as amended by the R6 2005 ROD Standard 23 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

M- American Indian Tribal and Treaty Rights 

M-1: American Indian tribes would be notified annually as treatments are scheduled so that 

tribal members may provide input and/or be notified prior to gathering cultural plants. 

• Purpose: To ensure that no inadvertent public contact with herbicide occurs and that 

cultural plants are fully protected. 

• Source: Government to government agreements between American Indian tribes and the 

Wallowa-Whitman National Forest 

M-2: The Forest Archaeologist will annually assess areas where mechanical treatment that could 

cause damage to cultural resources is proposed. Weed wrenching and grubbing techniques will 

not be used in known archaeological sites. Instead, treatment methods that would have no 

potential to affect cultural resources will be used. 

• Purpose: To avoid adverse impacts to cultural resources 

• Source: Common practice 

N-Rangeland Resources 

N-1: Use available administrative mechanisms to incorporate invasive plant prevention 

practices into rangeland management. Examples of administrative mechanisms include, but are 

not limited to, revising permits and grazing allotment plans, providing annual operating 

instructions, and adaptive management. Plan and implement practices in cooperation with 

grazing permit holder. 

• Purpose: To ensure proactive adaptive measures are taken to eliminate future spread of 

invasive plants 

• Source: R6 2005 FEIS Standard 6 

N-2: Permittees will be notified of annual treatment actions at the annual permittee operating 

plan meeting, and/or notified within two weeks of planned treatments of infestations greater than 

one acre in size. See PDF section K. 

• Purpose: To ensure permittee has knowledge of activities occurring within the allotment 

• Source: Common practice 

N-3: Follow most current EPA herbicide label for grazing restrictions 

• Purpose: To ensure grazing animals are not exposed to chemicals 

• Source: EPA labeling requirements 

O-Human Health (See R6 2005 FEIS, Appendix Q for more information) 

O-1: Backpack application rate for Sulfometuron methyl will not exceed 0.2 lb a.i./ac., and for 

NPE surfactant it will not exceed 1.67 lb a.i./ac 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

• Purpose: To reduce the potential of adverse effects to human health 

O-2: Spot spray application rate for Picloram will not exceed 0.35 lb a.i./ac., and for 

Sulfometuron methyl it will not exceed 0.12 lb a.i./ac 

• Purpose: To reduce the potential of adverse effects to human health 

O-3: Triclopyr application rate will not exceed 1.0 lbs a.i./ac. Use spot spraying techniques to 

further reduce dermal exposure. Favor other herbicides wherever they are expected to be 

effective 

• Purpose: To reduce the potential for adverse effects to human health from dermal contact 

or consumption of contaminated vegetation 

P-Restoration 

P-1: Long-term site strategy for highly disturbed areas that have high potential for weed 

invasion such as old fields or old homesteads, follow guidelines and techniques outlined in 

Guidelines for Revegetation for Invasive Weed Sites on National Forests and Grasslands in the 

Pacific Northwest (Erickson et al.2003) 

• Purpose: To ensure highly invisible/disturbed sites are successfully restored or 

revegetated with desirable vegetation 

• Source: Treatment Restoration Standard 12 (RFEIS) 

P-2: On dry grassland habitat below 3000 feet in the Hells Canyon National Recreation Area 

and other highly disturbed areas where live vegetative groundcover will be reduced by 70 

percent of existing vegetation by herbicide treatment, restoration and/or revegetation would 

occur following Guidelines for Revegetation for Invasive Weed Sites on National Forests and 

Grasslands in the Pacific Northwest (Erickson et al.2003) and R6 2005 FEIS standards 

• Purpose: To ensure highly invasible/disturbed sites are successfully restored or 

revegetated with desirable vegetation 

• Source: Treatment Restoration Standard 3, 12 (RFEIS), Guidelines for Revegetation for 

Invasive Weed Sites on National Forests and Grasslands in the Pacific Northwest

(Erickson et al. 2003), Water Erosion Prediction Project (WEPP) erosion data, and 

Goodwin et al. 2002 

P-3: In areas where broadcast herbicide is used to treat highly infested areas, evaluation of 

potential re-infestation by new or nearby invasives would be considered and restoration and/or 

revegetation measures would be implemented to ensure protection of native vegetation and soils. 

Also see Treatment Restoration Standard #12 in the R6 2005 FEIS and ROD. 

• Purpose: To ensure those sites are successfully restored with desirable vegetation 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

• Source: Treatment Restoration Standard 3, 12 (RFEIS), and Guidelines for Revegetation 

for Invasive Weed Sites on National Forests and Grasslands in the Pacific Northwest

(Erickson et al. 2003) 

Herbicide Use Buffers 

Herbicide treatments would become more restrictive as they occur close to water. PDFs and 

herbicide use buffers within the aquatic influence zone were developed based on label 

advisories; SERA risk assessments, and various studies of drift and runoff to streams such as 

Berg 2004. The scientific basis for establishing no treatment buffer widths is based on research 

on inherent risk of chemical contamination due to herbicide application (Moore 1975, Norris, 

Lorz and Gregory 1991, Bissin, Ice, Perrin and Bilby 1992). In general, research has 

demonstrated that the risk of aquatic organism exposure to chemical herbicides is dependient on 

three key factors including (1) chemical behavior, (2) the rate and methods of application, and 

(3) site characteristics. 

Tables 7, 8 and 9 specify buffers according to treatment methods, herbicides used, risk, and type 

of aquatic zone. Table 10 addresses buffer widths used for aerial application. Buffers identify 

distances from various water bodies where treatment activities are not allowed. 

Ephemeral streams exist in the project area. Label direction and PDFs would be followed for 

treatments along ephemeral streams. These areas flow rarely during very high water events 

when herbicide use would not likely occur. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Table 7-Herbicide Use Buffers in Feet -Perennial and Wet Intermittent Streams -Proposed Action 

Perennial and Wet Intermittent Stream 

Herbicide 

Aerial Broadcast Spot Hand/Select 

Aquatic Labeled Herbicides 

Aquatic Glyphosate Not proposed 100 Water’s edge Water’s edge 

Aquatic Triclopyr-TEA None Allowed None Allowed 15 Water’s edge 

Aquatic Imazapyr* Not proposed 100 Water’s edge Water’s edge 

Low Risk to Aquatic Organisms 

Imazapic Not proposed 100 15 Bankfull 

Clopyralid 300 100 15 Bankfull 

Metsulfuron Methyl None Allowed 100 15 Bankfull 

Moderate Risk to Aquatic Organisms 

Imazapyr Not proposed 100 50 Bankfull 

Sulfometuron Methyl Not proposed 100 50 5 

Chlorsulfuron Not proposed 100 50 Bankfull 

High Risk to Aquatic Organisms 

Triclopyr-BEE None Allowed None Allowed 150 150 

Picloram 300 100 50 50 

Sethoxydim Not proposed 100 50 50 

Glyphosate Not proposed 100 50 50 

Table 8-Herbicide Use Buffers in Feet -Dry Intermittent Streams -Proposed Action 

Dry Intermittent Stream 

Herbicide 

Aerial Broadcast Spot Hand/ 

Select 

Aquatic Labeled Herbicides 

Aquatic Glyphosate Not proposed 50 0 0 

Aquatic Triclopyr-TEA None Allowed None Allowed 0 0 

Aquatic Imazapyr* Not proposed 50 0 0 

Low Risk to Aquatic Organisms 

Imazapic Not proposed 50 0 0 

Clopyralid 100 50 0 0 

Metsulfuron Methyl None Allowed 50 0 0 

Moderate Risk to Aquatic Organisms 

Imazapyr Not proposed 50 15 Bankfull 

Sulfometuron Methyl None Allowed 50 15 Bankfull 

Chlorsulfuron None Allowed 50 15 Bankfull 

High Risk to Aquatic Organisms 

Triclopyr-BEE None Allowed None Allowed 150 150 

Picloram 100 100 50 50 

Sethoxydim Not proposed 100 50 50 

Glyphosate Not proposed 100 50 50 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Table 9-Herbicide Use Buffers in Feet – Lakes and Wetlands 

Wetlands 

Herbicide Aerial Broadcast Spot Hand/ 

Select 

Aquatic Labeled Herbicides 

Aquatic Glyphosate Not proposed 100** Water’s 

edge Water’s edge 

Aquatic Triclopyr-TEA None Allowed None 

Allowed 15 Water’s edge 

Aquatic Imazapyr* Not proposed 100** Water’s 

edge Water’s edge 

Low Aquatic Hazard Rating 

Imazapic Not proposed 100 15 High water mark 

Clopyralid 300 100 15 High water mark 

Metsulfuron Methyl Not proposed 100 15 High water mark 

Moderate Aquatic Hazard Rating 

Imazapyr Not proposed 100 50 High water mark 

Sulfometuron Methyl None Allowed 100 50 5 

Chlorsulfuron None Allowed 100 50 High water mark 

Greater Aquatic Hazard Rating 

Triclopyr-BEE None Allowed None 

Allowed 150 150 

Picloram 300 100 50 50 

Sethoxydim Not proposed 100 50 50 

Glyphosate Not proposed 100 50 50 

*Aquatic Imazapyr (Habitat) may not be used until the risk assessment (currently underway) is completed for inert 

ingredients and additives. 

** If wetland, pond or lake is dry, there is no buffer. 

Table 10-Buffer widths required for aerial applications 

Buffer width for a 25 foot 

release height, 7-8 mph winds 

Buffer width for a 35 foot 

release height, 7-8 mph winds 

Buffer width for a 50 foot 

release height, 7-8 mph winds 

Designated buffer Add 1 swath width to buffer Add 2 swath widths to buffer 

 Ensure little to no drift by applying these buffers and low drift technology (i.e. nozzle design and/or additives), as 

directed in PDFs 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Figure 11 – Illustration of how herbicide selection and application methods in the established buffer 

widths are more limited in Aquatic Influence Zones 

Figure 11 illustrates how the Aquatic Influence Zone restricts application methods and herbicides 

to only those approved for use in aquatic areas. “Aquatic Influence Zone” is not equal to the 

“buffer widths” listed in the tables above. For purposes of analysis in this EIS, the Aquatic 

Influence Zone is defined by the innermost half of the RHCA. For instance, a 300 foot RHCA 

would have an Aquatic Influence Zone of 150 feet. Establishing buffer widths reduces the 

potential for herbicides to come in contact with water via drift, leaching, and runoff at or near 

concentrations of concern. 

Early Detection and Rapid Response 

As described previously, Early Detection/Rapid Response (EDRR) is aimed at controlling new 

infestations that are small in size thus decreasing cost and the need for repeated applications. It 

is also advantangous because: 1) the precise location of individual target plants is subject to rapid 

and/or unpredictable change; and 2) presently known infestations may grow during the time it 

typically takes to complete the NEPA process. The 2006 inventory is estimated to include 95 

percent of the existing sites; however, these sites may be spreading and new sites may likely 

become established during the life of the project. The estimate of 95 percent is based on a poll of 

invasive plant specialists across the Forest who have conducted inventories over the past 20 

years in the majority of likely invasive plant sites. 

The Proposed Action would allow treatment of new detections, as long as the treatment method 

is within the scope of this EIS. Limitations associated with the PDFs would apply to new as well 

as existing sites. Invasive plant sites that are discovered subsequent to the current invasive plant 

inventory would require evaluation to determine that the invasive plants treatments and 

environmental impacts are consistent with those analyzed in this EIS. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

New sites would be treated under the auspices of this project, even if it involves a new invasive 

species, as long as the effective treatment is similar to the common control measures and 

treatment methods described previously. The exception to this is aerial treatment; no aerial 

treatment is authorized under EDRR. New sites that require aerial treatment would be subject to 

additional NEPA analysis. If a new site needs a treatment that has not been analyzed in this 

document, or if PDFs cannot be applied effectively to a new site, additional NEPA analysis 

would also be required. 

New detections are usually small in size and would likely have a higher priority for treatment. 

The annual treatment cap of 8,000 acres and life of the project treatment cap of 40,000 acres 

include EDRR as well as known sites. EDRR sites would be subject to the following herbicide 

use decision process. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

1. Is the target population associated with a size, phenology, density or distribution that warrants 

herbicide use (alone or in combination with other methods)? Consider whether or not herbicides 

are required for treatment effectiveness and/or whether or not the use of herbicides substantially 

increases cost-effectiveness of treatment? Consult common control measures. Consider whether 

volunteers may be available to reduce the cost of manual treatments. 

 

Yes (use herbicides): List potential herbicide choices and integrated prescription. Review label 

directions and project design criteria. Consider non-target vegetation surrounding treatment sites 

and use selective herbicides as appropriate. Consider soil conditions at the treatment site. Consider 

previous treatments that have occurred on the site. Were they effective? Would another herbicide 

or combination of methods be more effective? Also note that triclopyr may not be used in areas of 

known special forest product or subsistence collection. Go to 2. 

No: Use non-herbicide methods. 

2. Do the size, density and/or distribution of invasive plants warrant the broadcast application 

method? Would another herbicide besides triclopyr be effective? (Please note that triclopyr may 

not be broadcast) 

 

Yes: Is the treatment site within the aquatic influence zone and/or on a road that has high potential 

to deliver herbicide to surface waters? Is the site in a wildlife habitat that has specific restrictions to 

broadcasting? Go to 3a. 

No: Go to 3b. 

3a. Apply surface water buffers as appropriate. Is this site within an area where broadcasting is 

prohibited? 

Yes: Do not broadcast. Go to 4. 

No: Go to 3b. 

3b. Are there botanical species of local interest/suitable habitat within 100 feet of the proposed 

broadcast site? 

Yes: Survey as needed within suitable habitats. Apply botanical buffers as appropriate (see table 

25). Broadcast may still be acceptable if botanical species of local interest are covered by barrier. 

Go to 4. 

No: Broadcasting is an acceptable treatment method for herbicides except triclopyr. Use lowest 

effective label rates for each given situation. Do not exceed typical label rates. Favor other 

surfactants besides NPE and do not broadcast NPE at a rate exceeding 0.5 lbs. active ingredient per 

acre. Do not broadcast spray NPE in animal habitats (see table 35). Do not broadcast imazapyr at a 

rate greater than 0.7 lbs per acre. Consider wildlife habitats in the area and implement seasonal 

restrictions if required. 

4. Will spot and/or selective methods be reasonably effective in this situation? 

Yes: Apply spot/selective buffers and use aquatic labeled herbicides as appropriate. 

No: Seek approval for treatment through additional decision process (NEPA Section 18 or a new 

NEPA process). 

Figure 12 – EDRR Herbicide Use Decision Tree Process 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Annual Implementation Planning 

This section outlines the process for making sure the selected alternative is properly 

implemented. The method follows Integrated Weed Management principles (R6 2005 FEIS, 3-3) 

and satisfies pesticide planning requirements at FSH 2109.14. It applies to currently known and 

new sites found during ongoing monitoring (EDRR). 

1. Characterize the invasive plant infestation to be treated. This includes: 

• Map and describe the target species, density, extent, treatment strategy, and site 

conditions. 

• List any resource of concerns and determine if additional surveys are needed. 

Coordinate with resource specialists to get additional information or new information 

about specific locations. Identify and perform pre-treatment surveys for species of local 

interest and/or their habitats. 

 

2. Develop site prescriptions 

• Use Integrated Weed Management principles to identify possible effective methods of 

treatment. Non-herbicide treatments should be considered when sites are small or target 

plant densities are low, particularly after several years of herbicide treatments. Prescribe 

herbicides as needed based on the biology of the target species and size of the infestation 

(for instance, manual treatment alone cannot effectively eradicate rhizomatous species). 

Determine that the prescribed treatment is within the scope of those analyzed in the 

EIS. If treatments would not be effective once Project Design Features are applied, 

further NEPA would also be required to authorize the effective treatment. 

• Apply appropriate Project Design Features. Consider the soil texture and type and 

potential for ground water contamination to ensure that label guidance and PDFs related 

to soils are followed. Consider the presences of small unmapped small wetlands and 

ensure PDFs are appropriately applied. 

• Determine that the prescribed treatment is consistent with the ESA consultation. 

• Review compliance criteria for the Forest Plan and any other environmental standards 

indicated by the label or state regulations. Develop an Invasive Plant Prevention Plan, a 

public notification plan, and coordinate with local Tribes. 

• Complete Form FS-2100-2, Pesticide Use Proposal. This form lists treatment objectives, 

specific herbicide(s) that would be used, the rate and method of application, and Project 

Design Features that apply. Apply for any herbicide application permits when needed 

for treatments in Riparian Areas. 

• Confirm that acceptable plant or mulch materials are available for cultural 

treatments/restoration. If the prescription includes extensive site preparation, additional 

NEPA is required. 

• Coordinate with adjacent landowners, water users, agencies, and partners. 

• Apply annual caps Forest-wide, a cap for the life of the project, and an annual cap for 

riparian areas including individual watersheds. These would include: 

o A maximum of 8,000 acres per year Forest-wide 

o A maximum for the life of the project of 40,000 acres 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

o A maximum of 1,587 acres of riparian treatment per year which includes 

maximum acres of riparian treatment according to Table III-10 in the Aquatics 

ESA consultation document (USDA Forest Service 2008)*

3. Accomplishment and Compliance Monitoring 

• Develop a project work plan for herbicide use as described in FSH 2109.14.3. This plan 

presents organizational and operational details including treatment objectives, the 

equipment, materials, and supplies needed; the herbicide application method and rate; 

field crew organization and lines of responsibility, and a description of interagency 

coordination. The plan will also include a job hazard analysis to assure applicator safety. 

• Ensure contracts and agreements include appropriate prescriptions and that herbicide 

ingredients and application rates meet label requirements, Standards 16 and 18, and site 

specific Project Design Features. 

• Document and report herbicide use and certify applicator information in the National 

Pesticide Use Database, via the Forest Service Activity Tracking System (FACTS). 

• Document the implementation of the public notification plan. 

 

4. Post Treatment Monitoring 

• Post-treatment reviews would occur on a sample basis or when required by a Project 

Design Feature to determine whether treatments were effective, if damage to non-target 

species occurred, or whether or not passive restoration occurred as expected. 

• Post-treatment monitoring would also be used to detect whether Project Design Features 

were appropriately applied and effective. Contract administration and other existing 

mechanisms would be used to correct deficiencies. 

• Additional monitoring may be done consistent with the R6 2005 ROD. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

2.2.4 Alternative C 

Alternative at a Glance 

Activity Approximate Value 

Acres identified for treatment 22,842 

Percent of Total Forest Landbase Affected by Known Sites 0.9% 

Maximum percent of Total Forest landbase treated annually 0.32% 

Percentage of treatment sites where full range of effective treatments are available 86% 

Number of herbicides available for use 10 

Acres of proposed herbicide treatments for known sites 20,776 

Acres identified for aerial spraying of herbicides 875 

Approximate total acres of ground-based (hand or boom) broadcast treatments 

proposed for known sites (all in uplands) 13,556 

Acres of hand or non-aerial broadcast treatments with riparian/wetland areas 0 

Acres of spot or selective herbicide application on known sites (all in riparian areas) 6,345 

Number of invasive sites where methods other than herbicides could be effective 313 

Acres of invasive sites where methods other than herbicides could be effective 2,066 

EDRR includes chemical methods other than aerial Yes 

Average Cost per effectively treated acre $312 

Alternative C was developed to respond to concerns that detrimental effects could occur from 

broadcast spraying herbicide in riparian areas. Invasive plants have been inventoried on about 

6,300 acres within riparian area and wetlands. This alternative would not allow broadcast 

applications of herbicides in these areas. The features of this alternative are the same as 

Alternative B with the exception of the limitations imposed on broadcast spraying in riparian 

areas. New detections in riparian areas would be subject to the same limitations as the known 

sites under this alternative; therefore broadcast herbicide applications would not be allowed. 

Broadcast of herbicide in riparian areas was identified as a high risk in the R6 2005 ROD 

(Appendix 1). Alternative C avoids this higher risk, while still allowing herbicide treatment 

applications in riparian via lower risk spot spraying, wicking, foliar applications, injections, etc. 

These application methods target specific invasive plants, apply the herbicide to the plant or 

small group of plants and have little possibility of contact with other plants, animals or nonorganic matter. With this level of control specificity, potential contact with water or aquatic 

organisms from chemical drift is virtually eliminated. For these reasons, spot and selective 

application treatments were NOT considered high risk in the R6 2005 ROD. 

However, along with the lower risk, Alternative C also increases cost and reduces the potential 

for effectiveness compared to Alternative B. This is because broadcast applications are more 

cost-effective in dense and/or extensive infestations such as roadsides. 

Alternative C includes all of the PDFs and buffers associated with Alternative B; though, 

eliminates all broadcast treatments in riparian and wetland areas. These areas could still be 

treated, but fewer acres would likely be treated because of the higher average cost of spot 

spraying or selective treatments. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

2.2.5 Alternative D 

Alternative at a Glance 

Activity Approximate Value 

Acres identified for treatment 22,809 

Percent of Total Forest Landbase Affected by Known Sites 0.9% 

Percent of Total Forest landbase treated annually 0.32% 

Percentage of treatment sites where full range of effective treatments are 

available 96% 

Number of herbicides available for use 10 

Acres of proposed herbicide treatments for known sites 19,901 

Acres identified for aerial spraying of herbicides 0 

 Approximate total acres of ground-based (hand or boom) broadcast treatments 

proposed for known sites (all in uplands) 13,556 

Acres of hand or non-aerial broadcast treatments with riparian/wetland areas 3,104 

Acres of spot or selective herbicide application on known sites (all in riparian 

areas) 3,241 

Number of invasive sites where methods other than herbicides could be 

effective 341 

Acres of invasive sites where methods other than herbicides could be effective 2,908 

EDRR includes chemical methods other than aerial Yes 

Cost per effectively treated acre $334 

Alternative D was developed to respond to concerns that detrimental effects could occur from 

aerial spraying of herbicide. Alternative D is the same as the Proposed Action, except 

approximately 842 acres would be treated using methods other than aerial. About 33 acres 

would not be treated at all, because aerial is the only reasonable method for these acres. 

Aerial application of herbicide was identified as a high risk in the R6 2005 ROD (Appendix 1). 

Alternative D avoids this higher risk type of project. The benefits and risks associated with 

broadcast and other herbicide application, along with other treatments would be allowed in this 

alternative. 

However, along with the lower risk, Alternative D also increases cost and reduces the potential 

for effectiveness compared to Alternative B. This is because aerial applications are more costeffective for steep, extensive and remote infestations. 

Alternative D includes all of the PDFs and buffers associated with the Proposed Action but goes 

beyond them by eliminating all aerial spraying. With the exception of the eliminating aerial 

application of herbicide, the features of this alternative are the same as Alternative B. 

2.3 Alternatives Not Considered in Detail 

2.3.1 High Potential for Spread Areas or Priority 1 and 2 Species 

There is a concern the herbicide treatments proposed are unnecessarily extensive. By potentially 

treating so many acres for so many years, the concern is that cumulatively there would be 

detrimental environmental effects. Some of those concerned reason that many invasive plant 

sites don’t pose as serious threat to the human environment as the herbicides proposed to control 

them. To respond to this issue and reduce the amount of acres proposed for treatment an 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

alternative was developed to limit herbicide use to high priority areas only. That is, areas with 

high potential for weeds to spread, or areas with priority 1 or 2 invasive weed species. 

When it was determined that only approximately 300 acres would be dropped from herbicide 

treatment this alternative was dropped from detailed consideration because that few acres is 

insignificant compared to the approximately 20,691 acres proposed for herbicide treatment in the 

Proposed Action. 

2.3.2 Invasive Plants Managed through Natural Processes 

Some commenters believe that if National Forest use is restricted enough, natural processes will 

displace invasive plant infestations with native plant populations. Specifically, suggestion was 

made to remove livestock and ORVs from the National Forest. It was reasoned that removing 

resource uses or activities would allow native plant communities to recover where invasive 

weeds now dominate. 

National Forests exist to provide a variety of goods and services to the American people. 

National Forests are managed through many programs to provide these benefits to national forest 

visitors and users. These uses are acknowledged by the Forest Plan and are permitted uses. The 

proposed invasive plant treatment program (Alternative B) would focus on directly reducing 

weed populations, not on limiting existing national forest programs or establishing prevention 

measures for other activities (see Purpose and Need in Chapter 1). While preventative measures 

would be incorporated in this project at specific locations needed for treatment or removal of 

invasive plants, weed prevention measures for other activities will be administered through other 

programs such as livestock grazing and transportation management when those activities occur 

to meet Forest plan Standards and Guidelines for invasive plants. 

A project based on weed prevention alone would not satisfy the Purpose and Need of this project 

to contain, control or eradicate existing and future invasive plants populations. Invasive plants 

have been expanding for decades. The present weed treatment program has had some success, 

yet invasive plant populations continue to expand. It is doubtful that a passive, prevention 

program alone, would reverse this trend because the species are wide spread and occur in many 

high use areas. Furthermore, it is beyond the scope of this analysis to review actions approved 

by the Forest Plan and not limit other national forest programs benefiting forest visitors and 

users. For these reasons, this alternative was not considered in detail. 

2.3.3 No Herbicides 

Some commenters expressed the belief that herbicide use is unacceptably toxic to the human 

environment and to native ecosystems. They acknowledge that herbicides kill target weeds, but 

are concerned that containing, controlling or eradicating weeds using herbicides comes at an 

unacceptable cost to humans and the natural environment. Therefore, they propose an invasive 

plant treatment project that uses methods other than herbicides to address weed populations. 

The 1994 Environmental Assessment for the Management of Noxious Weeds (USDA Forest 

Service 1994a) and the R6 2005 FEIS considered alternatives to manage weeds without using 

herbicides. The 1994 EA considered such an alternative in detail. That alternative was rejected 

because the likelihood of controlling weeds without herbicides was low (USDA Forest Service 

1994a). The alternative that was selected allows herbicide use, but only after other methods 

prove to be ineffective. The current invasive treatment program has been based on this 

alternative. It also represents the No Action, or ‘no change from the current program’ alternative 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

(Alternative A) in this EIS. Because invasive plant populations continue to grow, this alternative 

has not contained, controlled or eradicated weeds as we now hope to do under the current 

Purpose and Need statement. Therefore another alternative proposal to treat weeds without 

herbicide applications will not be considered in detail because its ineffectiveness has been 

predicted by past analysis. 

2.3.4 1994 Guidelines Applied Forest-wide 

The current program established by an environmental assessment (EA) completed in 1994, 

allows herbicide treatment on 5,172 acres only if non-chemical treatment proved ineffective. 

Some believe that the safeguards of this program, limiting how and when herbicides can be used 

should be continued without restricting where herbicides can be used. In other words, the 

current program should be continued without limiting herbicide use to pre-designated sites. 

Instead, other features of that integrated weed management (IWM) program would limit 

herbicide treatment. 

This alternative would not take advantage of the advances made both in herbicide effectiveness 

and safety, because it would only allow two of the nine chemicals approved by the R6 2005 

FEIS. In fact, dicamba, approved for use in the 1994 EA has been removed from the list of US 

Forest Service Region 6 approved chemicals because of toxic concerns. Other limitations of this 

program would require that non-chemical treatments be used on new sites first. Herbicide 

application would only occur if non-chemical treatment proved ineffective. 

The present inventory of invasive plants suggest that the weed problem is growing, not 

shrinking. The present program has successfully addressed some weed sites. However, overall, 

the program has not been as effective because it has severely restricted the type and 

circumstances of herbicide use. Because only two herbicides would be used and because the 

present program would not likely satisfy this project’s Purpose and Need, this alternative was not 

considered in detail. 

2.3.5 Restricted Use – No Herbicides in Riparian or Special Areas 

Some members of the public expressed concern that use of herbicides in riparian areas would 

have adverse effects to aquatic species and amphibians. Further, they believe it is inappropriate 

to use herbicide in special areas such as wildernesses, wild and scenic river corridors and 

municipal watershed. Other suggestions for excluding herbicide treatments included where there 

are certain SOLI plants within 100 feet of known invasive infestations, areas where native plant 

materials are gathered for cultural purposes and where riparian or biodiverse habitats exist. 

Therefore an alternative was considered that would not allow herbicide applications in any of 

these special areas or riparian areas. Table 11 compares acres of herbicide treatment proposed 

under Alternative B to this “Restricted Use” alternative, which would not use herbicides in 

riparian or special areas. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Table 11-Comparing acres of proposed herbicide treatment for Alternative B and “Restricted Use” 

alternative 

1No action alternative includes ’92 Environmental Assessment for the Management of Noxious Weeds and the ’94 

Environmental Assessment for Management of Noxious Weeds and Forest Plan Amendment #4. 

Treatment Methods 

Alternative A 

No Action1 

Alternative B 

Proposed Action 

Restricted Use 

biological, 

Alternative 

Chemical Methods 

Upland Areas 

Ground based broadcast and spot 

(spraying)/selective (wicking, wiping, and 

stem injection) treatments 

2,5771 13,556 10,303 

Aerial Treatments 0 875 875 

Riparian Habitat Conservation Areas2 

Ground based broadcast treatment 1,9321 3,104 0 

Spot/selective treatments 

(includes: spot spraying, wicking, wiping, 

and stem injection) 

6631 3,241 0 

Upland and Riparian Habitat Conservation Areas 

Bio-Control only See note 1,955 1,955 

Manual/mechanical only 0 111 111 

Bio-control or manual/mechanical 0 0 9,598 

Total Acres Treated 5,172 22,842 22,842 

2Riparian Habitat Conservation Areas (RHCA) are, for the purposes of this exercise, 300’ on either side of perennial 

streams and 100’ on either side of intermittent streams. This is as designated under PACFISH, INFISH. 

Biocontrol note: The ’94 EA approved the use of biocontrol agents, however, all sites were analyzed for chemical 

treatments to attain highest amount of flexibility and greater invasive species control. The Forest has also released 

APHIS and State of Oregon approved biocontrol agents on approximately 2,500 acres for the control of invasive weeds 

(Yates 2007 personal communication). 

Instead of approximately 20,776 acres of predominately herbicide treatment (Alternative B), 

about 11,178 acres would be similarly treated, a reduction in herbicide treatment of about 46 

percent or 9,598 acres. The following assumptions were made to arrive at these acreages: 

• Special areas included the four wilderness areas, the wild and scenic river cooridors (both 

eligible and designated), and the two congressionally designated municipal watersheds 

• Because Alternative B (Proposed Action) would not use herbicides in municipal watersheds 

either, there is no treatment difference proposed between the two alternatives 

• Because wild and scenic corridors are 1⁄4 mile on either side of the river bank, most of the 

corridor area is in uplands. Therefore it is assumed that the weed infestations are in the 

uplands 

• The invasive plant inventory has cataloged 2,274 acres of weeds in the 221 miles of wild and 

scenic river corridor on the Forest. Wild and scenic river corridors, both eligible and 

designated, total approximately 35,360 acres. 

• Because most of the wilderness land area is uplands, it is assumed that the weeds are in the 

uplands 

• The invasive plant inventory has cataloged 979 acres of weeds in three of the four wilderness 

areas. The North Fork John Day, Baldy Creek Wilderness has no inventoried weeds at this 

time 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

• The total area of the four wilderness areas is 582,700 acres (includes semiprimitive) 

Notice in Table 11 that the total acres treated between the two alternatives remains the same 

(22,842 acres), just the methods of treatment change. It is assumed that the treatment in the early 

years of the project would heavily favor upland herbicide treatment of the high priority invasive 

plants and areas (see Appendix B for discussion of assumptions). Some manual/mechanical 

treatment would occur on high disturbance sites like trail heads. But most of the 9,598 acres 

would remain untreated, until the majority of lands available for herbicide treatment had been 

successfully treated. Using the treatment schedule (Appendix B), herbicide treatment on areas 

available for treatment would be done by about year 5 because most acres previously untreated 

and eligible for herbicide treatment would have been treated. By year 5 project strategy would 

be shifting to focus on treatment of riparian and special areas using bio-control and 

manual/mechanical methods. That is to say that while some follow-up retreatment with 

herbicides would undoubtedly continue most of the funding and treatment efforts would occur in 

riparian or special areas using non-herbicide treatment methods. 

By year 7, assuming the same annual project budget, the number of acres treated each year drops 

from about 4000 acres to about 2400 acres because the treatment cost per acre increases 

dramatically (again see Appendix B for a complete analysis discussion and display of weed 

treatments over time). Besides treating fewer acres, treatment effectiveness would drop of from 

about 80 percent (effectiveness of herbicide treatments) to about 25 percent (effectiveness of 

manual/mechanical treatments). Figure 13 displays the resultant change beginning in year 5 

from steadily reducing acres of weeds to weed increasing every year thereafter. The result is that 

by year 15 the acres of invasive plants has nearly doubled (see Appendix B for details and 

discussion of modeling limitations). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Acres of Weeds over Time under the Restricted Use 

Alternative

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

Years

Acres of Weeds

Series2

Series1

Figure 13 – Acres of invasive plants over time-treatment effectiveness 

Excluding treatment of invasive plants within 100 feet of certain SOLIs would scatter a number 

of known infestations across the landscape to be potentially ineffectively treated or untreated. 

Leaving cultural gathering areas untreated could threaten culturally important plants. Diverse 

habitat in riparian or other ares could be threatened by aggressive invasive species. Many weed 

species can displace native species. This can simplify diverse plant communities and displace 

plants important to amphibian and other aquatic species with invasive plants that may not be 

usable by animals we are trying to protect. 

Riparian and special areas have approximately 6,345 acres of invasive plants; however, their 

total land area is approximately 340,000 acres. These National Forest System lands along with 

exclusions for SOLIS and culturally important areas would be off limits for herbicide treatment 

under this alternative. Allowing for the invasive plants that are already present, these areas would 

become an unacceptable ‘safe harbor’ for invasive plants. Riparian areas are a long narrow 

network of lands across the forest. Special areas such as wilderness and wild and scenic corridors 

have large land bases. Eliminating the herbicide treatment option in riparian and special areas 

would allow invasives to persist and eventually expand throughout the forest. This is contrary to 

the Purpose and Need for the project area, to contain, control or eradicate invasive plants. 

Therefore this alternative was not considered in detail. 

2.3.6 Deviations from Existing Approved Herbicide List 

There is a concern that limiting herbicide use to the approved list provided by the R6 2005 ROD 

prevents use of effective herbicides coming on the market and future chemicals that may be 

developed during the life of this project. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

84

Therefore, an alternative was considered that would add new EPA approved herbicides that were 

not available or not analyzed at the time of the Regional assessment. 

While future improvements in herbicide products may be attractive, it is costly and time 

consuming to do a chemical assessment for each new product. This diverts funds and staff from 

the primary Purpose and Need of containing, controlling or eradicating invasive infestations. 

The current list of approved herbicides is considered safe and effective for most priority invasive 

plants in most circumstances. For these reasons this alternative was not considered in detail. 

2.4 Alternatives Compared 

Tables 12 and 13 displays information about each alternative. 

Table 12-Alternatives compared by activity 

Activity Alt A Alt B Alt C Alt D 

Acres identified for treatment 5,172 22,842 22,842 22,809 

Includes EDRR for new sites (all 

methods within the scope of the 

project, except aerial). 

No Yes Yes Yes 

Percentage of sites where all 

effective methods are available 0 100 86 96 

Acres of proposed herbicide 

treatments 5172 20,776 20,776 19,901 

Number of herbicides available for 

use 

2 10 10 10 

Percent of Total Forest Land Base 

Treated with Herbicides Apprx: 0.23% Apprx: .9% Apprx: .9% Apprx: .8% 

Percent of Total Forest Land Base 

treated annually <0.02% 0.32% 0.32% 0.32% 

Average Cost Per Acre $820 $307 $312 $334 

Degree to which adverse effects to 

people and the environment are 

minimized 

Minimal risks 

from project 

Minimal 

risks from 

project: 

Aerial and 

broadcast 

include 

inherent 

risks

Minimal risks 

from project: 

Broadcast in 

riparian areas 

eliminated

Minimal risks 

from project: 

Aerial 

treatment 

eliminated
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

Table 13-Alternative comparison relative to significant issues 

Issue 

Component 

Unit of 

Measurement 

(No Action) 

Alternative 

A 

(Proposed 

Action) 

Alternative B 

Alternative C Alternative D 

1. Human Health 

1- There is 

concern by 

members of 

the public that 

exposure to 

herbicides may 

have serious 

human health 

consequences. 

Of particular 

concern is 

toxic chemical 

exposure and 

chemical 

contamination 

of drinking 

water. 

 Character of 

PDFs that 

apply to 

Human Health 

Forest Plan standards and project design features eliminate plausible 

harmful exposure scenarios in all alternatives. The R6 2005 FEIS 

displayed herbicide exposure scenarios that could result in human 

health impacts (such as nausea, skin rash, breathing trouble) based on 

risk assessments. Worst case exposure scenarios for workers and the 

public were studied. This project does not involve any exposure 

scenarios of concern for people. 

Rates of herbicide and surfactant application are limited in the PDFs, 

which eliminate the worst-case scenarios that could hurt people. The 

only scenario of concern remaining is drinking out of a pond 

contaminated pond by a direct spill of large proportions. This is not 

likely to occur given all of the safeguards associated with the project. 

In addition, there are many PDFs related to coordination with 

landowners, tribal members, forest products gatherers, and others to 

make sure inadvertent exposures do not occur. Public notification and 

sign posting would occur (see implementation plan). 

2 – Treatment Effectiveness 

Number of 

herbicide 

options 

2 10 10 10 

Percentage of 

known sites 

where all 

effective 

treatments are 

available 

0 (does not 

include new 

herbicides) 

100 86 96 

Degree of 

limitation on 

integrated 

treatment 

options 

5172 acres 

treated 

chemically 

only after 

other 

methods 

shown to be 

ineffective. 

Very limited. 

Least limited, 

allows for aerial 

and broadcast 

treatment where 

needed 

according to 

PDFs and 

buffers. 

Second most 

limited, allows 

for aerial 

treatment of 

875 acres. No 

broadcast 

herbicide 

applications 

allowed in 

Riparian , 

which 

decreases 

costeffectiveness 

compared to 

Alternative B. 

Second least 

limited, does not 

allow effective 

aerial treatment 

on 875 acres. 

This reduces the 

cost-effective of 

this alternative 

compared to 

Alternative B. 

2 - Limitations 

on the 

availability of 

treatment 

methods and 

herbicide 

options reduce 

the potential 

for invasive 

plants to be 

effectively 

treated. 

Degree to 

which threats 

to botanical 

species of 

local interest 

are abated 

Least likely 

to abate risks 

– treatment 

approved in 

11 of 80 sites 

where 

invasives 

threaten 

species of 

concern. 

Most likely to 

abate risks – 

treatment would 

be approved in 

all 80 sites 

where invasives 

threatened 

species of 

concern. 

Same as B Same as B 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

(No Action) (Proposed Issue Unit of Alternative Action) Alternative C Alternative D Component Measurement 

A Alternative B 

3. - Economic 

Undiscounted 

Cost to Treat 

All Acres 

Proposed for 

Treatment 

One Time 

$1,485,190 $5,601,390 $5,693,200 $5,863,880 

3 - Cost of 

each treatment 

acre influences 

the number of 

acres that can 

be treated with 

the same total 

budget. 

Cost per 

Effectively 

Treated Acre 

(Currently 

Inventoried 

Infestations) 

$820 $307 $312 $334 

4 – Non-Target Species 

Character of 

PDFs that 

apply to 

wildlife and 

plants 

Herbicide 

exposure 

limited 

because 

herbicide 

treatment 

limited by 

only being 

used if nonherbicide 

treatments 

are 

ineffective; 

PDFs not 

specifically 

applied to 

this 

alternative 

PDF Groups H, I 

and J are all 

intended to 

minimize 

exposure to 

wildlife and nontarget plant 

impacts. 

In addition to 

alternative B, 

herbicide 

exposure 

further 

minimized by 

eliminating 

broadcast 

applications 

methods in 

riparian areas 

In addition to 

alternative B, 

herbicide 

exposure further 

minimized by 

eliminating aerial 

application of 

herbicides and 

the potential for 

associated drift 

Acres of 

broadcast 

spraying 5,172 17,535 14,431 

16,660 acres 

potential 

maximum of 

ground-based 

broadcast 

methods 

4 - There is a 

concern that 

herbicide 

exposure, 

particularly 

when applied 

through aerial 

or broadcast 

spraying, may 

harm terrestrial 

wildlife species 

and non target 

plants. 

Acres of 

Aerial 

Spraying 

0 875 875 0 

5 – Soil, Water Quality, Aquatic Biota 

5a-There is a 

concern that 

there may be 

potential 

adverse 

effects of 

herbicide 

treatment on 

soils and the 

potential for 

leaching into 

ground water. 

PDFs that 

apply to soils 

to minimize or 

prevent these 

impacts 

PDF group H 

includes 

restrictions 

on use of 

clopyralid, 

chlorsulfuron, 

picloram and 

sulfometuron 

methyl due to 

their potential 

to impact soil 

biology 

and/or 

leaching. 

Same as B Same as B Same as B 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

87

Issue 

Component 

Unit of 

Measurement 

(No Action) 

Alternative 

A 

(Proposed 

Action) 

Alternative B 

Alternative C Alternative D 

Acres of 

broadcast 

herbicide 

application 

within riparian 

areas 

1,932 acres 3,104 0 3,104 acres 

5b- There is a 

concern that 

there may be 

potential 

adverse 

effects of 

herbicide 

treatment on 

riparian areas 

adversely 

impacting 

water quality 

and aquatic 

ecosystems. 

Acre of aerial 

treatment 0 875 875 0 

 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 2 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

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Chapter 3 – Affected Environment and 

Environmental Consequences 

3.1 Introduction 

This chapter describes both the existing conditions of the project area, and the environmental 

effects of implementing the alternatives described in Chapter 2. Effects are defined as: 

• Adverse and/or beneficial direct effects occur at the same time and in the same general 

location as the activity causing the effects. 

• Adverse and beneficial indirect effects are those that occur at a different time or location 

from the activity causing the effects. Both types of effects are described in terms of increase 

or decreases, intensity, duration, and timing. 

• Cumulative Effects result from the incremental impacts of the Proposed Actions/alternatives 

when added to other past, present, and reasonably foreseeable actions, both on the Forest and 

Wild and Scenic River corridor as well as other adjacent federal, state, or private lands. 

Effects include ecological (such as the effects on natural resources and on the components, 

structures, and functioning of affected ecosystems), aesthetic, historic, cultural, economic, social, 

or health, whether direct, indirect, or cumulative (40 CFR 1508.7 and 1508.8). 

3.1.1 Project Area 

The Wallowa-Whitman National Forest, (see Vicinity Map) located in the northeast corner of 

Oregon and west central edge of Idaho, covers 2.3 million acres. The Forest extends to the Hells 

Canyon National Recreation Area, and encompasses four wilderness areas, and eleven wild and 

scenic rivers. It lies within Wallowa, Union, Baker, Malheur, Umatilla, and Grant Counties in 

Oregon and Adams, and Nez Perce Counties in Idaho. The Forest is located on the east edge of 

the Blue Mountains and encompasses the Elkhorn and Wallowa Mountains, and ranges in 

elevation from 875 feet on the Snake River in the bottom of the Hells Canyon National 

Recreation Area to 9,845 feet in the Eagle Cap Wilderness of the Blue Mountains. The Forest is 

the largest administrative unit in the Pacific Northwest Region. 

The Wallowa-Whitman National Forest is the home of the deepest river gorge in the nation 

(Hells Canyon), the largest wilderness area in Oregon (Eagle Cap), and hosts a portion of the 

Oregon Trail. 

3.1.2 Basis for Cumulative Effects Analysis 

Cumulative effects result from the incremental impacts of the Proposed Actions/alternatives 

when added to other past, present, and reasonably foreseeable actions, both on National Forest 

System lands and other adjacent federal, state, or private lands (40 CFR 1508.7). Cumulative 

effects related to the spread of invasive plants, and cumulative effects related to the risks 

associated with herbicide or other invasive plant treatments are considered in this Environmental 

Impact Statement (EIS). 

Activities of man and natural processes have led to the introduction, establishment and spread of 

invasive plants across the Wallowa-Whitman National Forest. The Wallowa-Whitman National 

Forest Plan was amended in October of 2005 to provide management direction aimed at 

preventing further spread of invasive plants. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

The cumulative effects analysis assumes that the prevention standards will reduce rates of 

invasive plant spread within the project area, and that treatments will reduce the density and 

extent of invasive plants further lowering the rates of spread. 

The elimination of some existing weed transport vectors will occur during the life of this project 

when the Forest Travel Management Plan is implemented as directed by the 2005 Travel 

Management Rule. Approximately 900,000 acres in the Forest are currently open for crosscountry travel at least part of the year. Under the travel management alternatives being 

formulated, this area to a large extent would become closed to cross-country travel. 

Furthermore, approximately 4000 miles of roads presently open to OHV use are proposed to be 

closed to motorized travel. The eventual decision may designate some of these roads for OHV 

use, but the final number is expected to be less than the current 4000-plus miles. The Forest 

anticipates implementing the travel management plan in 2010. Withdrawing these areas and 

roads from public travel would help reduce the spread of weeds on those lands and elsewhere on 

the Forest. 

Only the land and roads within the National Forest System would be treated in the action 

alternatives proposed by this EIS. However, Forest System land and roads are intermingled with 

other federal, state, county, and private ownerships; therefore, management activities and actions 

on neighboring lands may contribute to spread or containment of invasive plants on National 

Forest System lands, and vice versa. The effectiveness of the proposed invasive plants treatment 

project would be increased if coordination with adjacent landowners treats invasive infestation 

across land ownerships. Coordination would also tend to prevent unwanted effects such as 

duplication of treatment along a property boundary. The cumulative effects analysis assumes that 

this cooperative, coordinated effort continues for the life of this project. In addition, the 

cumulative effects analysis assumes that the release of biological control agents on National 

Forest System lands and adjacent lands by the Oregon and Idaho Departments of Agriculture, as 

analyzed by Animal Plant Health Inspection Service (APHIS), will continue to reduce the 

invasive plant infestations in Oregon and also decrease the spread of invasive plants. In addition, 

post-wildland fire recovery efforts may include invasive plant treatment. 

Herbicides are commonly applied on lands other than National Forest System lands for a variety 

of agricultural, landscaping and invasive plant management purposes. Herbicide use occurs on 

tribal lands, state and county lands, private forestry lands, rangelands, utility corridors, road 

rights-of-way, and private property. No requirement or central reporting system exists to compile 

invasive plant management information on or off National Forests in Oregon or Idaho. 

Therefore, accurate accounting of the total acreage of invasive plant treatment for all land 

ownerships is unavailable. Even the estimates provided are not to be precisely analyzed given 

the long time span and uncertain implementation schedule for this project. 

Many people express personal concern about their exposure to agricultural and industrial 

chemicals, and the cumulative effects to human and environmental health from herbicide, 

pesticide, and other chemical use in our society. The proposed use of herbicides on and off 

National Forest System lands could result in additive doses of herbicides to workers, the general 

public, non-target plant species, aquatic species, and/or wildlife species. 

For additive doses to occur, the two exposures would have to occur approximately at the same 

time, since the herbicides proposed for use are rapidly eliminated from humans and do not 

significantly bioaccumulate (R6 2005 FEIS). The application rates and extent considered in this 

EIS are unlikely to result in additive doses beyond those evaluated for chronic and acute 

exposures in the USDA Forest Service risk assessments, which formed the basis for the effects 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

91 

analysis in the Region 6 2005 FEIS. The R6 2005 FEIS, in return, served as the basis for the sitespecific effects analysis discussed in this EIS. 

The risk of adverse effects of invasive plant treatments in all action alternatives have been 

minimized by the project design features (PDFs). These limit, but not exclude, the possibility of 

cumulative adverse effects caused by treatment. The use of herbicides within the scope of this 

project is unlikely to contribute to cumulative effects beyond those described in the R6 2005 

FEIS. Herbicide persistence is managed through PDFs to avoid chemical loading in the soil over 

time at any one site. Buffers minimize risk of herbicide concentrations of concern near water. 

Specific PDFs and buffers can be reviewed in Chapter 2.2.3. 

Early detection-rapid response is part of all action alternatives, and is considered in the direct, 

indirect and cumulative effects analysis. 

Effects of treatments each year under early detection-rapid response, by definition, would not 

exceed those predicted for the most ambitious conceivable treatment scenario. This is because 

the Project Design Features do so much to control the potential for adverse effects and because if 

the most ambitious treatment scenario were implemented, the potential for spread into new areas 

would be greatly reduced. 

Natural events such as drought, weather events, wildfires, and others affect the spread of 

invasive plants. These events would have implications on where and how treatments would 

occur; however, natural events do not act cumulatively with the treatment of weeds to multiply 

possible environmental effects. Potential effects of treatments to contain, control or eradicate 

invasive plants are the focus of this analysis. 

3.1.3 Life of the Project 

This project would be implemented over several years as funding allows, until no more 

treatments were needed or until conditions otherwise changed sufficiently to warrant this EIS 

outdated. Site-specific conditions are expected to change within the life of the project; treated 

infestations would be reduced in size, untreated infestations would continue to spread, specific 

non-target plant or animal species of local interest could change, and/or new invasive plants 

could become established within the project area. The effects analysis considers a range of 

treatments applied to a range of site conditions to accommodate the uncertainty associated with 

the project implementation schedule. 

Many variables affect invasive plant treatment prescriptions, including land management 

objectives and standards related to a particular site; treatment area priority and treatment strategy 

(see Chapter 2 for more discussion about treatment areas, priorities and strategy); and landscape 

scale goals. The relative proportion and timing of integrated treatments including herbicides and 

other methods; the effectiveness of invasive plant management on neighboring lands; and 

available funding also affect the treatment that would be implemented. The analysis assumes the 

following maximums over the life of the project: 

• A maximum of 8,000 acres per year Forest-wide 

• A maximum for the life of the project of 40,000 acres 

• A maximum of 1,587 acres of riparian treatment per year which includes maximum 

acres of riparian treatment according to Table III-10 in the Aquatics ESA consultation 

document (USDA Forest Service 2008) 

Newly discovered infestations could be prioritized over existing sites. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

3.1.4 Herbicide Risk Assessments 

The effects from the use of any herbicide depends on the toxic properties (hazards) of that 

herbicide, the level of exposure to that herbicide at any given time, and the duration of that 

exposure. The R6 2005 FEIS relied on herbicide risk assessments to evaluate the potential for 

harm to non-target plants, wildlife, human health, soils and aquatic organisms from the 

herbicides considered for use on the Wallowa-Whitman National Forest. Risk assessments were 

done by Syracuse Environmental Research Associates, Inc using peer-reviewed articles from the 

open scientific literature and current EPA documents, including Confidential Business 

Information. Information from laboratory and field studies of herbicide toxicity, exposure, and 

environmental fate was used to estimate the risk of adverse effects to non-target organisms. 

Table 14 displays the risk assessments available by chemical; these may be accessed via the 

Pacific Northwest Region website at http://www.fs.fed.us/r6/invasiveplant-eis/RiskAssessments/Herbicides-Analyzed-InvPlant-EIS.htm 

Table 14-Risk assessments for herbicides considered in this EIS 

Herbicide Date Final Risk Assessment Reference 

Chlorsulfuron November 21, 2004 SERA TR 04-43-18-01c 

Clopyralid December 5, 2004 SERA TR 04 43-17-03c 

Glyphosate March 1, 2003 SERA TR 02-43-09-04a 

Imazapic December 23, 2004 SERA TR 04-43-17-04b 

Imazapyr December 18, 2004 SERA TR 04-43-17-05b 

Metsulfuron methyl December 9, 2004 SERA TR 03-43-17-01b 

Picloram June 30, 2003 SERA TR 03-43-16-01b 

Sethoxydim October 31, 2001 SERA TR 01-43-01-01c 

Sulfometuron methyl December 14, 2004 SERA TR 03-43-17-02c 

Triclopyr March 15, 2003 SERA TR 02-43-13-03b 

NPE May 2003 USDA Forest Service, R-5 

In addition to the analysis of potential hazards to human health from every herbicide active 

ingredient, Forest Service/SERA Risk Assessments evaluated available scientific studies of 

potential hazards of other substances associated with herbicide applications: impurities, 

metabolites, inert ingredients, and adjuvants. There is usually less toxicity data available for 

these substances (compared to the herbicide active ingredient) because they are not subject to the 

extensive testing that is required for the herbicide active ingredients under FIFRA (Federal 

Insecticide, Fungicide, and Rodenticide Act). 

In some cases, toxicity data on inerts and adjuvants is produced to comply with other federal 

laws that regulate non-herbicide uses of these chemicals, such as the Federal Food, Drug, and 

Cosmetic Act. Appendix G displays a list of adjuvants approved for use in this EIS. 

The risk assessments considered worst-case scenarios including accidental exposures and 

application at maximum label rates. The Project Design Features described in Chapter 2 were 

developed to abate hazards indicated by the assessments. Although the risk assessments have 

limitations (see R6 2005 FEIS pages 3-95 through 3-97), they represent the best science 

available. The risk assessment methodologies and detailed analysis is incorporated into 

references of conclusions about herbicide toxicology in this document. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

93 

Herbicide Toxicology Terminology 

The following terminology is used throughout this chapter to describe relative toxicity of 

herbicides proposed for use in the alternatives. 

Hazard Quotient (HQ) 

The Hazard Quotient is the amount of herbicide or additives to which an organism may be 

exposed over a specified period divided by that estimated daily exposure level at which no 

adverse health effects are likely to occur. An HQ less than or equal to one indicates an extremely 

low level of risk; therefore, an HQ less than or equal to one is presumed to indicate a level of 

exposure below the threshold of concern for adverse health effects.

Exposure Scenario 

Exposure scenarios consider both the toxicity of a given chemical and the mechanism by which 

an organism may encounter it. The application rate and method influences whether a person, 

animal or non-target plant could be adversely affected by exposure to a particular herbicide. 

Plausible Effects 

The analysis in Chapter 3 focuses on whether effects that are possible based on risk assessments 

are plausible, given site conditions, life history of organisms in an area, herbicide application 

methods and other Project Design Features. Project Design Features are often used to minimize 

or eliminate the plausibility of effects indicated as possible in the risk assessments. 

3.1.5 Climate Change 

Effects of Climate Change on Invasive Species 

Global climate change is predicted to alter precipitation and seasonal temperature patterns as a 

result of increased levels of atmospheric carbon dioxide (CO2) and other factors (Mote 2004). 

Most recent studies on the interaction between climate change and invasive plants conclude that 

climate change is likely to favor invasive plant species to the detriment of native plant species 

for individual ecosystems (Chornesky et al. 2005, Climate Change Science Program 2008, 

Dukes and Mooney 1999, Hellmann et al. 2008, Pyke et al. 2008). In some studies, invasive 

plant species have demonstrated increased growth rates, size, seed production, and carbon 

content in the presence of elevated CO2 levels (Rogers et al. 2008; Rogers et al. 2005; Smith et 

al. 2000; Ziska 2003). Warming climates may remove elevational barriers to invasive plant 

distribution that currently exist (Tausch 2008). 

Many invasive plants are species that can thrive in the presence of disturbance and other 

environmental stressors; they have broad climatic tolerances, large geographic ranges, and 

possess other characteristics that facilitate rapid range shifts. The predicted changes in climate 

are thought to contribute additional stressors on ecosystems, including those on National Forests, 

making them more susceptible to invasion and establishment of invasive plant species (Joyce et 

al. 2008). 

Predicted conditions may also make management of invasive species more difficult. Some 

current treatments used on invasive plants may be less effective under conditions of climate 

change scenarios and/or elevated CO2 (Hellmann et al. 2008, Pike et al. 2008, Ziska, Faulkner, 

and Lydon 2004). 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

It is more difficult to predict how climate change will affect invasive plants, and invasive plant 

management, at the local or even regional scale than are these general indications. Anticipated 

changes in the climate for the Pacific Northwest (e.g. more rain, less snow, warmer temperatures 

(Mote 2004, Mote et al. 1999, National Assessment Synthesis Team 2000)) or elevated CO2 may 

not be realized at a local area, particularly within the time frame of this analysis. Growth of 

invasive plants under elevated CO2 conditions will also be influenced by environmental 

conditions such as soil moisture, nutrient availability, and the plant community in which the 

invasive species occurs (Cipollini, Drake and Whigham 1993; Curtis, Drake, and Whigham 

1989; Dukes and Mooney 1999; Johnson et al. 1993; Taylor and Potvin 1997). The complex 

interaction of multiple and uncertain variables make site-specific predictions speculative. 

Affected Environment 

Climate change may alter the seasonal distribution of precipitation and seasonal temperature 

patterns in ways that could favor invasive species. In the West in particular, a warming climate 

may lead to an upward elevational migration of plant species. On harsher sites like lower 

elevation south slopes, climate change could favor spread of invasive plants because of stressed 

plant communities that tend to have fewer species and sparser vegetative cover. Native plant 

species may be lost from their lower-elevation limits, such as Hells Canyon National Recreation 

Area, faster than they will be able to migrate upward and establish into newly created habitat. 

While climate change is expected to favor invasive species spread in most circumstances, an 

exception might be native species that can migrate from adjacent areas or regions into locations 

where they previously were excluded by climate as the new locations become more suitable. It 

is also possible that on more productive sites, increased precipitation could favor native plant 

populations by allowing them to more completely occupy sites, making invasive plants 

establishment more difficult. 

Relevence for Environmental Consequences 

Current science is insufficient to precisely determine a cause and effect relationship between 

climate change and the Proposed Action for the project area. A general conclusion, based on the 

preponderance of current literature, suggests that “most of the important elements of global 

change are likely to increase the prevalence of biological invaders” (Dukes and Mooney 1999). 

The National Forest landscape may become more vulnerable to the establishment of invasive 

plants infestations, actual acreage affected by invasive plants could increase, and control 

strategies may become less effective. Recommended management responses to these predictions 

are early detection (resulting from regularly scheduled monitoring) followed by a rapid response 

to eradicate initial infestations (Hellmann et al. 2008, Joyce et al. 2008, Tausch 2008). 

Because Alternative A does not allow an effective ‘early detection rapid response’ strategy, it 

would be considered least effective at controlling the spread of invasive plants that may be 

encouraged by climate change factors. Given that all action alternatives include control of 

invasive plants with an ‘early detection rapid response’ component, and the large uncertainties 

regarding effects of climate change at any specific location over the time frame of this project, 

there is insufficient information to discern any meaningful differences between alternatives B, C 

and D. All actions are consistent with recommendations for management response in the face of 

potential influences of climate change on invasive plants. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

95 

3.1.6 Treatment Strategy, Type, and Effectiveness Common to All 

Alternatives 

The ability of the Forest Service to meet the purpose and need for action, achieve desired future 

conditions and contribute to cooperative efforts throughout Oregon, is directly correlated to the 

treatment strategy and effectiveness of invasive plant control and the ability of the impacted area 

to recover. Treatment strategies such as control, contain and eradicate are fully described within 

this EIS. Treatment types as described in Chapter 2 include chemical, physical, biological and 

cultural. Multiple treatment methods are possible under each treatment type such as manual, 

mechanical, broadcast herbicide etc. and are fully described in R6 2005 FEIS. Forestwide, 

treatment effectiveness typically increases with the number of treatment options available and 

the percentage of infested lands that may be treated. Applying the early detection rapid response 

process to newly discovered infestations also increases treatment effectiveness, and reduces 

potential future effects of herbicide treatment on non-target vegetation. The effectiveness of an 

alternative to treat the diverse group of invasive plants depends on the tools available within that 

alternative; limited tools equal limited treatment effectiveness. 

Strategies such as integrated weed management, cooperation with private and public landholders, 

prevention, and EDRR, apply to all action alternatives proposed in the EIS and are described in 

this section. This section also briefly describes treatment effectiveness of each treatment type 

and method proposed in this EIS (as tiered to the R6 2005 FEIS and accompanying ROD) and 

describes the resultant ability of native vegetation to recover. 

Integrated Weed Management 

All alternatives strive towards integrated treatments, such as using manual treatment as a followup to get plants missed by herbicide spraying, or using a mechanical method, such as weed 

whacking, on tall stems to reduce biomass and reduce the amount of herbicide used. Herbicide 

treatment is often followed up by manual treatment later in the season to get plants that were 

missed by the herbicide or several years later when invasive plant populations are reduced to the 

point at which they can be hand-pulled. 

Cooperation with Private and Public Landholders as well as Other Agencies 

Cooperative treatment of weeds by various land ownerships and neighboring parcels also 

contributes to optimizing effectiveness of all alternatives. Invasive plants are currently being 

treated on county and state lands and on some private lands and this work would continue 

regardless of the alternative that is selected. On-going partnerships will continue, such as Oregon 

Department of Agriculture, Tri-County Cooperative Weed Management Area, Tri-State Weed 

Management Area, Wallowa-Resources, Wallowa County Vegetation Department, The Nature 

Conservancy, Salmon River CWMA, and the Rocky Mountain Elk Foundations to name a few. 

Efforts such as these are imperative for the promotion of healthy ecosystems by reducing 

invasive plants and for promoting the economic and community benefits that healthy ecosystems 

provide. 

Prevention 

Prevention practices as outlined by the R6 2005 FEIS and adopted into the Wallowa-Whitman 

National Forest Plan are expected to reduce the spread of invasive plant species. Prevention 

methods that apply to all alternatives are listed in R6 2005 ROD (pages10-19). 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Early Detection Rapid Response (EDRR) 

Sometimes considered the “second line of defense” after prevention, EDRR is a critical 

component of any effective invasive plant species management program. A prompt and 

coordinated containment and eradication response can reduce environmental and economic 

impacts when new invasive plant infestations are detected. This action results in lower cost and 

less resource damage than implementing a long-term control program after the species is 

established. The No Action Alternative presently uses manual methods to treat new infestations, 

whereas, the proposed Alternatives B, C, and D could treat new or previously undiscovered 

infestations using the range of methods described in this EIS as directed in the decision process 

(Figure 12) and in full accordance with PDFs listed in Chapter 2 of the EIS. EDRR is considered 

to be one of the four primary elements in the Forest Service National Strategy and 

Implementation for Invasive Plant Species (USDA Forest Service 2004c) and implementation on 

any scale would lead to future protection of native plant biodiversity. However, treatment 

effectiveness for control and eradication increases with the more treatment options available. 

Manual and Mechanical Treatments 

Manual and mechanical treatments physically remove and destroy, disrupt the growth of, or 

interfere with the reproduction of invasive plants. These treatments can be accomplished by 

hand, hand tool (manual), or power tools (mechanical); and include pulling, grubbing, digging, 

hoeing, tilling, cutting, mowing, and mulching of the target plants. Thermal techniques such as 

steaming, super heated water and hot foam are also considered as viable treatments. 

Manual Methods - Manual methods can be effective on small infestations if the entire root is 

removed. With new, small infestations, hand pulling can be the easiest and quickest method. 

Even larger populations, though, can be controlled with hand pulling if the workforce is 

available. The Bradley Method is one sensible approach to manual control of invasive plants 

(Fuller and Barbe 1985). This method consists of hand weeding selected small areas of 

infestation in a specific sequence, starting with the best stands of native vegetation (those with 

the least extent of infestation) and working towards stands with the worst infestation. 

Manual methods are usually not as effective for deep-rooted or rhizomatous perennials such as 

leafy spurge where hand-pulling and hoeing often leave root fragments that can generate new 

plants. Hand-pulling or hoeing also disturbs the soil surface, which may increase susceptibility 

of a site to reinvasion by weeds (Brown et al. 2001). Manual methods are labor-intensive and 

usually ineffective for the treatment of large, well-established infestations of perennial invasive 

plants with long term viable seed such as knapweeds (Brown et al. 2001). A local effort where 

larger community support or funding for hand crews exists does show promise, if efforts can be 

sustained. Manual and mechanical methods as primary methods prior to the use of herbicides 

were shown to be only 25 percent effective on the Umatilla National Forest located adjacent to 

the Wallowa-Whitman National Forest (Erickson 2006). 

The Nature Conservancy reported success with the use of manual control (Tu et al. 2001). Hand 

pulling by volunteers has successfully controlled diffuse knapweed (Centaurea diffusa) in the 

Tom McCall Preserve in northeast Oregon. Yellow bush lupine (Lupinus arboreus) was also 

controlled in coastal dunes in California by pulling small shrubs by hand. Larger shrubs were 

cut down with an ax, and re-sprouting was uncommon (Pickart and Sawyer 1998). Hand pulling 

has also been fairly successful in the control of small infestations of thistles (Centaurea spp.), 

white and yellow clover (Melilotus officinalis), and purple loosestrife (Lythrum salicaria) at 

TNC preserves scattered across the country. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

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Manual tools such as the Weed Wrench (www.weedwrench.com) can be used on herbaceous 

plants that have a stem or bundle of stems strong enough to withstand the crush of the jaws. It 

has been used successfully to pull acacia (Acacia melanoxylon), buckthorn (Rhamnus 

cathartica), Russian olive (Elaeagnus angustifolia), multiflora rose (Rosa multiflora), willow 

(Salix spp.), tamarisk (Tamarix spp.), bush honeysuckles (Lonicera spp.), Scotch broom (Cytisus

scoparius), French broom (Genista monspessulanus), and Brazilian pepper (Schinus 

terebinthifolius) at preserves across the mainland U.S. In Hawaii, the Weed Wrench has been 

used to pull Strawberry guava (Psidium cattleianum) and small saplings of Karaka nut 

(Corynocarpus laevigatus) from the Kamakou preserve on Molokai (Hawaii) (Tu et al. 2001). 

Mechanical Methods - Mowing or cutting is more effective on tap-rooted perennials such as 

spotted knapweed compared to rhizomatous perennials (Brown et al. 2001). Cutting or mowing 

plants can reduce seed production if conducted at the right growth stage. For example, a single 

mowing at late bud growth stage can reduce the number of seeds produced on spotted knapweed 

(Watson and Renny 1974). Mowing can also weaken an invasive plant’s competitive advantage 

by depleting root carbohydrate reserves, but mowing must be conducted several times a year for 

consecutive years to reduce the competitive ability of the plant. 

Oregon Department of Agriculture staff compared mowing and pulling mature plants to no 

treatment in two western Oregon spotted knapweed infestations. They applied one treatment 

annually at the optimum time for each of four consecutive years, and concluded that neither 

method was effective in reducing population density or cover. 

They recommend consideration of pulling and mowing only where the goal is to contain spotted 

knapweed infestations or to suppress seed production (Isaacson et al. 1997 in USDA 2005a, 

Appendix J). 

Because invasive plants flower throughout the summer, it is difficult to time mechanical 

treatments to prevent flowering and seed production. Repeated mechanical treatment too early in 

the growing season can result in a low growth form that is still capable of producing flowers and 

seed (Benefield et al., 1999; Goodwin and Sheley, 2001). 

Mechanical treatments on some rhizomatous weeds, such as leafy spurge, can encourage 

sprouting and result in an increase in stem density (Goodwin and Sheley 2001). 

Thermal Techniques - Thermal techniques are being tested or used with some success 

throughout Region Six by such agencies as Oregon Department of Transportation (ODOT), the 

Nature Conservancy and the Bureau of Land Management (BLM). The Nature Conservancy (Tu 

et al. 2001) tested the Eco-Weeder, an infrared technology device that uses the combustion of 

liquid gas to reach extremely high temperatures that place intense radiation directly on weeds to 

explode plant cells. The tool could be useful for small area treatments, especially on sidewalks, 

but the effectiveness on deep-rooted plants, sedges or rhizomatous grasses may not be as high. 

The Nature Conservancy also tested hot water pressure washers. The brand tested could apply 

hot water through a pressure nozzle with a wide spray or intense stream which would act as an 

injection device for below ground portions of plants. They found it effective on seedlings and 

annual plants within reach of the washer, but the effectiveness on plants with extensive 

underground roots or rhizomes would be less. Hot foam has been tested by the Nature 

Conservancy and used by the BLM effectively on puncturevine and slender false brome. Again, 

this technique is limited to the reach of the foam generator, but is an excellent non-chemical 

method. It is effective on seedlings and annuals and can be applied under weather conditions 

including wind and light rain. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Herbicide Treatments 

The objectives of herbicide treatments are often twofold: 1) to more efficiently reduce the size 

of moderate to large infestations of invasive plants to a point at which they can be hand-pulled or 

manual or mechanical methods are ineffective due to invasive plant growth morphology, or, 2) 

more efficiently treat large expansive areas where invasive plants thrive due to the nature of the 

site. Different herbicides vary in effectiveness and length of control on different invasive plants, 

and herbicide techniques can vary in effectiveness, environmental effects, and costs. 

Herbicides vary in selectivity of control for various plant groups. Those differences in selectivity 

are the basis for developing effective plant control treatments while minimizing adverse effects 

and facilitating native plant community maintenance or restoration. 

Physical forms of herbicide vary. Some may be oil- or water-soluble molecules dissolved in 

liquid, or attached to granules for dry application to soil surface. 

Herbicides may move from their location of application through leaching, volatilization, or 

adsorption. For a complete review of all physical properties and risk assessments of herbicides 

approved for use in this EIS see Regional Invasive Plant Herbicide Information 

http://www.fs.fed.us/r6/invasiveplant-eis/Region-6-Inv-Plant-Toolbox/ (accessed 4/2007). 

Herbicides can also be applied with a variety of equipment and techniques. The techniques vary 

in effectiveness, environmental effects and costs. Aerial application of sprays or granules can be 

used for rapid broadcast coverage of large or inaccessible areas. 

In general, herbicides provide and effective method of controlling invasive plants and is 

projected to be 80 percent effective at controlling invasive plants when used with other methods 

of treatment in the region (R6 2005 FEIS). 

Just as changes in plant diversity or species composition can occur due to invasive plants, 

changes can also occur due to treatments. Short-term changes in species dominance can lead to 

long-term shifts in plant community composition and structure. Repeated treatments over time 

could favor tolerant species, which in turn could shift pollinators available to a community. 

DiTomaso (2001) points out that continuous broadcast use of one or a combination of herbicides 

will often select for herbicide tolerant plant species. When broadleaf selective herbicides are 

used, noxious annual grasses such as medusahead, cheatgrass or barbed goatgrass may become 

dominant. Population 

shifts through 

repeated use of a 

single herbicide may 

also reduce plant 

diversity and cause 

nutrient changes. 

Alternatively, plant 

diversity is reported to 

be maintained on sites 

with repeated 

applications of 

Picloram and 

Figure 14 – Aerial 

application 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

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Clopyralid for control of spotted knapweed in Montana (Rice 2000). Additionally, analyses 

based on 60 published studies of terrestrial plants and animals in temperate zone forests and 

agro-ecosystems indicate species richness and diversity of vascular plants was either unaffected 

or increased (particularly herbaceous species) in response to glyphosate (Sullivan and Sullivan 

2003). 

It is obvious there are still unanswered questions related to recovery of native vegetation after 

herbicide treatment. Project design features such as the development of a long-term site strategy, 

monitoring, and restoration would be directed towards sites that could experience repeated 

herbicide applications (i.e. areas where recovery to native vegetation may not be possible such as 

campgrounds, highly disturbed areas). It is likely that due to the nature of repeated disturbance 

activities in some areas on the forest, long-term site objectives may be focused on containment 

of these areas to prevent future spread into other areas of the forest and a fully restored native 

plant component is not attainable. In these cases, desirable vegetation that reduces the potential 

for invasive plant re-establishment and protects other resources such as soil and water is likely. 

Herbicide Application Methods 

The risk to non-target vegetation also varies with the herbicide application method. Spot and 

hand methods substantially reduce potential for impacts to non-target vegetation because there is 

reduced chance for drift. 

Drift is associated primarily with broadcast treatments and can be mitigated to some extent by 

the applicator. 

Drift can also be minimized by adjustment of numerous factors such as spray particle size, 

release height, spray pressure, nozzle size/type in addition to climatic variables such as wind 

speed, air temperature, and relative humidity. 

Impacts to these factors related to drift are summarized in Table 15. 

Figure 15 demonstrates the relationship between droplet size and buffer distance. As droplet size 

increases, the distance herbicide may travel in concentrations sufficient to harm plants decreases. 

Dr. Harold Thistle, a physical scientist 

from the USDA in Morgantown, WV, 

specializes in computer modeling of 

herbicide drift. He modeled the 

potential for glyphosate to impact nontarget vegetation from drift. The model 

predicted a 100-foot broadcast buffer 

would prevent glyphosate from harming 

plant species that are further away 

(Spray Drift Task Force 2001). 

Factors affecting droplet size are nozzle 

type, orifice size and spray angle, as well 

as spray pressure, and the physical 

properties of the spray mixture. 

Figure 15 – Droplet size and drift distance 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Wind speed restrictions also substantially contribute to a reduction in drift (Spray Drift Task 

Force, 2001). By simply changing the type of nozzle (diameter of pore size) used during 

broadcast treatments, the drift potential of herbicide can be effectively and substantially 

decreased as the droplet size forced out the nozzle is increased in size. 

Spray nozzle pressure, the amount of water applied with the herbicide, and herbicide release 

height are also controllable determinants of drift potential. Weather conditions such as wind 

speed and direction, air mass stability, temperature and humidity and herbicide volatility also 

affect drift. 

Commercial drift reduction agents are available that are designed to reduce drift beyond the 

capabilities of the determinants previously described. These products create larger and more 

cohesive droplets that are less apt to break into smaller particles as they fall through the air. They 

reduce the percentage of smaller, lighter particles that are the size most apt to drift. 

Marrs 1989 examined the distances drift affected non-target vascular plants using broadcast 

treatment methods similar to those considered in this analysis. Their observations are consistent 

with drift-deposition models in which the fallout of herbicide droplets has been measured. The 

maximum safe distance at which no lethal effects were found was 20 feet, but for most 

herbicides the distance was 7 feet. Generally, damage symptoms were found at greater distances 

than lethal effects, but in most cases there was rapid recovery by the end of the growing season. 

No effects were seen to vascular non-target vegetation further than 66 feet from the broadcast 

treatment zone. Little information is available for how drift distances may effect non-vascular 

non-target vegetation. The distance spray drift will travel can vary substantially based on wind 

speed, topography, temperature, the herbicide applied, and the vegetation present, see Figure 19. 

Drift is the most likely vector for herbicides coming in contact with water from riparian area 

treatment sites. Some locations may have some invasive plants such as reed canary grass, or 

purple loosestrife growing on streambanks above ordinary high water that would be treated with 

a spot-spray. Such areas are limited in spatial extent, and given the distance between target 

vegetation and water, it is likely that much of the herbicide will have been sprayed on to the 

plant. 

The maximum safe distance at which no impacts are found obviously is greater with aerial 

application due to the distance above the ground at which the herbicide is sprayed. Aerial 

herbicide treatments using helicopters is proposed for all herbicide application sites on the 

Wallowa-Whitman National Forest due to terrain and access issues (Pope 2006). Helicopters 

would likely apply herbicides at heights of 10 to 20 feet above the ground in most cases. In steep 

terrain, the pilot would attempt to fly up and down the slope in order to maintain an equal 

distance of the boom to the ground, typical distances above the ground in steep terrain can vary 

but generally range to 10-50 feet. 

New applicator technology also exists for more precise application with minimal drift of 

herbicide to very small areas from helicopters (spray balls). These small applicator tools are 

lowered via a boom from the helicopter and the pilot applies herbicide (by a trigger mechanism 

and pump) to approximately a 4 foot radius area two to four feet above the ground (Pope 2006). 

Because distances above the ground and boom widths are similar to ground based herbicide 

application the same buffer distances will be applied in these special case scenarios. 

All aerial applications of herbicides will comply with EPA label restrictions and advisories, 

adhere to all PNW Regional Standards, and implement buffer distances described in project 

design features for the protection of SOLI and riparian areas. Buffer widths were determined by 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

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monitoring results and modeling herbicide drift (AGDISP 2007) using worst case scenario 

application situations. Factors such as release height, wind speed/direction, droplet size, ground 

terrain, weather conditions, and nozzle type/orientation/droplet size were model input factors. 

See Appendix F for model output, monitoring studies and spray guidelines for aerial applications 

of herbicides. 

Previous aerial herbicide applications in the area indicate sensitive areas were fully protected 

using a 300 foot buffer (no aerial deposition) in a study using three commonly used helicopters, 

with various nozzle types applying picloram at a rate of 2 gallons/acre (USDA 2006c). 

Additionally, helicopter application of clopyralid and picloram to control yellow starthistle in 

Hells Canyon area in Idaho reported greater than 90 percent control and no apparent damage to 

the native grasslands following treatment (TNC 2006). This application method was reported to 

be very accurate and negligible drift was observed (Talsma 2006). Some temporary set-back of 

some arrowleaf balsamroot (Balsamorhiza sagittata) was observed, however, most plants 

recovered. Additional aerial drift tests conducted near sensitive areas (stream side and threatened 

plant species) in northern Idaho indicated that these areas were fully protected with a 50-100 foot 

buffer (Huibregtse, 2007). 

PDF Group F8 relates to aerial application. Drift would be minimized in aerial and other 

broadcast application by controlling as many of the factors in the table below as possible. 

Table 15-Summary of the influence of various factors on spray drift 

Surfactants 

Inerts, Adjuvants and Impurities - Inert compounds are those that are intentionally added to a 

formulation, but have no herbicidal activity and do not affect the herbicidal activity. Inerts are 

added to the formulation to facilitate its handling, stability, or mixing. Adjuvants are compounds 

added to the formulation to improve its performance. They can either enhance the activity of an 

herbicide’s active ingredient (activator adjuvant) or offset any problems associated with its 

application (special purpose or utility modifiers). 

Surfactants are one type of adjuvant that makes the herbicide more effective by increasing 

absorption into the plant, for example: Inerts and adjuvants, including surfactants, are not under 

the same registration guidelines as are pesticides. 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, inerts and adjuvants generally do not have the same amount of research 

Factor More Drift Less Drift 

Spray particle size Smaller Larger 

Release height Higher Lower 

Wind speed Higher Lower 

Spray pressure Higher Lower 

Nozzle size Smaller Larger 

Nozzle orientation (aircraft) Forward Backward 

Nozzle location (aircraft) Beyond 85% rotor length Less than 85% rotor length 

Air temperature Higher Lower 

Relative humidity Lower Higher 

Nozzle type Produce small droplets Produce larger droplets 

Air stability Vertical stable air Vertical movement of air 

Herbicide volatility volatile Non-volatile 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

conducted on their effects compared to active ingredients (See Appendix B of this EIS) for a 

detailed discussion of surfactants). Impurities are inadvertent contaminants in the herbicide, 

usually present as a result of the manufacturing process. 

Biological Control 

Biological control can be defined as the use of natural enemies to reduce the damage caused by 

invasive plant populations. Biocontrol is often viewed as a progressive and environmentally 

friendly way to control pest organisms because it leaves behind no chemical residues that might 

have harmful impacts on humans or other organisms, and when successful, it can provide 

essentially permanent, widespread control with a very favorable cost-benefit ratio. Biological 

control is potentially useful where: eradication is not possible, sites are too large to be sprayed 

with herbicides, and invasive plant species are so abundant that other methods would not be 

practical, or the biological control agent is effective on the target plant species and reduces or 

eliminates the need to use herbicides. The time frame for controlling invasives using biocontrols 

is very long, and agents would likely spread throughout the forest where food sources are 

available. 

Stem weevil biocontrol agents have proven very successful for Dalmation toadflax control on 

infested forest and adjacent landowership sites on the forest (Dawson 2007). Several biocontrol 

agents are available for yellow starthistle and diffuse knapweed and effectiveness appears to be 

higher when biocontrol agents work in concert. However, where fire has entered into yellow 

starthistle sites, biocontrol agents appear to be less effective, likely a result of biocontrol 

population dynamics, impacts from fire and available food source. Biocontrol agents for control 

of purple loosestrife have been released on the Idaho side of the Snake River, however, the 

fluctuating water levels have negatively affected the establishment of a productive biocontrol 

population and effectiveness is minimal (Dawson 2007). 

Bio-control agents previously released on private lands and established on the Forest will 

continue to spread to other nearby invasive sites providing a potential long-term control 

treatment. 

Cultural Treatments/Restoration 

Cultural treatments include the establishment or maintenance of competitive vegetation, use of 

fertilizing, mulching, prescribed burning, or grazing animals to control or eliminate invasive 

plants. No preseribed burning or use of grazing animals is proposed within this EIS. 

Cultural treatments proposed include seeding or planting competitive native vegetation, use of 

fertilizer, and mulching. Cultural treatments help native plants and ecosystems become more 

competitive by: 1) improving the cover density of native plants through seeding and planting; 

and 2) improving health and site conditions for existing native plant populations through 

fertilization and mulching. 

Restoration or reclamation of sites infested with invasive plants follow treatment restoration 

Standard 13 (W-W LRMP as amended by the R6 2005 ROD) and incorporate guidelines for 

revegetation of invasive weed sites and other disturbed areas on National Forests and Grasslands 

in the Pacific Northwest (Erickson et al. 2003, also Appendix B – Revegetation Guidelines). On 

degraded sites where reproducing individuals of desirable species are absent or in low 

abundance, revegetation with well adapted and native competitive grasses, forbs and legumes 

can be used to direct and accelerate plant community recovery and achieve site management 

objectives in a reasonable timeframe (Sheley et al. 1996 in Erickson et al. 2003). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

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Mulching with plastic or organic materials can be used on relatively small areas (less than 0.25 

acre). Mulching prevents seeds and seedlings from receiving sunlight necessary to survive and 

grow, and can smother some established invasive plants, but may also stunt or stop growth of 

desirable native species. Hay mulch was used in Idaho to reduce flowering of Canada thistle (Tu 

et al. 2001), but most rhizomatous perennial invasive plants cannot be controlled by this method 

or by shading because extensive root reserves allow regrowth through and around mulch or 

shade materials. 

Restoration and revegetation projects that would include ground disturbing activities such as 

disking or plowing would require additional NEPA analysis. 

Treatment Effectiveness by Alternative 

Table 16 and Table 17 were developed to compare alternatives. Alternative A, the No Action 

Alternative would continue to implement treatments according to existing plans; no new invasive 

plant treatments would be approved. Alternative B, the Proposed Action Alternative, would 

apply an initial treatment strategy and prescription, along with re-treatments in subsequent years 

if needed, until the long-term site objectives were met. This would likely include herbicides as 

part of the prescription, however, the use of herbicide is expected to decline over time as 

invasive sites are controlled, contained or eradicated. Alternative B has the all proposed 

treatment methods available for use and could apply them on the broadest array of treatment 

sites, so this alternative is considered the potentially most effective of all alternatives. The 

‘Alternatives at a Glance’ tables in sections 2.2.3, 2.2.4 and 2.2.5 estimate treatment 

effectiveness as a percentage of all treatments available compared to the proposed action. 

Alternatives C and D were developed in response to public issues related to herbicide use and the 

two alternatives vary in method of application of herbicide. Alternative C would not allow any 

broadcast application of herbicides in riparian areas, however, spot spraying or hand application 

such as wiping or wicking of herbicides would be allowed. This alternative addressed human 

health issues associated with contamination of drinking water supplies as well as potential 

impacts to non-target wildlife, plant species, soil, aquatic biota and riparian ecosystems. 

Alternative D would eliminate the option to aerially apply herbicides. This addresses issues also 

associated with drift of herbicides into drinking water supplies as well as impacts to non-target 

wildlife, plant species, soils and aquatic biota and riparian ecosystems. The Forest Service 

preferred alternative is Alternative B. For a complete discussion of alternatives see Chapter 2 of 

this EIS. 

Table 16-Treatment type, method of application and acres proposed for treatment by alternative 

Treatment Methods 

Alternative A 

No Action1 

Alternative B 

Proposed Action 

Alternative C 

No Broadcast in 

Riparian Habitat 

Conservation 

Areas 

Alternative D 

No Aerial 

Herbicide 

Chemical Methods 

Upland Areas 

Ground-based 

broadcast and spot 

treatments2 2,577 3 13,556 13,556 13,556

Aerial treatments 0 875 875 0 

Riparian Habitat Conservation Areas 

Ground-based 

broadcast treatment 1,9323 3,104 0 3,104 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Alternative C 

No Broadcast in Alternative D Alternative A Alternative B 

Treatment Methods 

No Action1 Proposed Action Riparian Habitat No Aerial 

Conservation Herbicide 

Areas 

Spot spray/selective 

treatment (including 

wicking and wiping) 

6633 3,241 6,345 3,241 

Non-Chemical Methods 

Upland Areas and Riparian Habitat Conservation Areas 

bio-control only See note 

below 1,955 1,955 2,797 

manual only6 0 111 111 111 

Total Acres Treated 5,172 22,842 22,842 22,809 

1 A designation of chemical treatment could be changed to manual, mechanical or biological treatment if, at the time of 

treatment, one of these alternative methods would be effective. A site initially treated with chemicals may be treated 

with manual or mechanical methods during follow-up treatments. 

2 Whether each site will be broadcast or spot treated will be determined locally before each field season so the acres to 

be broadcast treated and the acres to be spot treated are not known at this time. Determination of where broadcast 

versus spot treatments will occur depends on access to site, size of site, and density of weed coverage. 

3 No action alternative includes ’92 Environmental Assessment for the Management of Noxious Weeds and the ’94 

Environmental Assessment for Management of Noxious Weeds and Forest Plan Amendment #4. 

4 Acres proposed in aerial application that could be treated with ground based methods although likely to be less 

effective or more costly than those proposed in Alternative B. Approximately 33 acres would not treated due to 

inaccessibility and no other means of control i.e. biocontrol agents. 

5 Riparian Habitat Conservation Areas (RHCA) are: 300’ of perennial stream and 100’ of intermittent stream–as 

designated under PACFISH, INFISH 

6 Manual only sites will not be treated with herbicides because the desired weed management goal can be effectively 

achieved using manual methods. Such sites are typically very small or having widely scattered weeds or are in sensitive 

areas like a campground along a stream or a combination of these factors. 

Biocontrol note: the ’94 EA approved the use of biocontrol agents, however, all sites were analyzed for chemical 

treatments to attain highest amount of flexibility and greater invasive plant species control. The forest has also released 

APHIS and state of Oregon approved biocontrol agents on approximately 2,500 acres for the control of invasive weeds 

(Yates 2007). 

Table 17-Herbicide formulations, invasive plant sites, total acres treated and treatment effectiveness 

by alternative 

Measuring Factor 

Alternative A – 

No Action 

Includes ’92 EA 

and ’94 EA 

Alternative B – 

Proposed 

Action 

Alternative C 

– Restricted 

Riparian4

Alternative D 

– No Aerial 

Application of 

Herbicide 

# of herbicide formulations 

available for use 41 10 10 10 

# of invasive plant sites that 

could be treated 124 1,740 1,740 1,737 

# of invasive plant sites that 

could be treated with 

herbicides either alone or in 

combination with other 

techniques 

52 1,427 1,427 1,424 

# of invasive plant sites that 

would be treated with biocontrol or manual methods 

only 

0 313 313 341 

Total acres treated using all 

methods 5,172 total2 22,842 22,842 22,8093 

EDRR (including herbicide 

use) No Yes Yes Yes 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

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Measuring Factor 

Alternative A – 

No Action 

Includes ’92 EA 

and ’94 EA 

Alternative B – 

Proposed 

Action 

Alternative C 

– Restricted 

Riparian4

Alternative D 

– No Aerial 

Application of 

Herbicide 

Treatment Effectiveness 

Relative Ranking Low Highest High High 

% of Total Forest Landbase 

Treated with Chemicals (all 

identified acres and annually) 

0.23% 

<0.02% annually 

0.9% 

0.16% annually 

0.9% 

0.16% annually 

0.8% 

0.16% annually 

1 Four herbicides: glyphosate, dicamba, picloram (with restrictions), and triclopyr approved under ’92 EA. Dicamba, was 

restricted from use in the 2005 Regional Invasive and will not be used in the future by the forest. 

2 This acreage represent acres approved under existing NEPA documents; additional new acres are treated using 

manual and/or mechanical methods. 

3 Sites proposed for aerial herbicide application could still be treated with other methods/treatments 

(backpack/horseback sprayers, or bio-control methods) however, may be less effective. It is estimated that 33 acres 

proposed for aerial could not be treated using any other alternative methods (no bio-control available or safety concerns 

related to terrain and access for ground based applications). 

4 Riparian Habitat Conservation Areas (RHCA) as designated under PACFISH, INFISH 

Alternative A – No Action 

Under the No Action Alternative, invasive plant treatments would be limited to areas authorized 

under existing NEPA documents and new infestations would be treated with manual methods. 

Based on monitoring and increased inventory efforts forest wide, invasive plant sites have 

continued to increase over the years (Yates 2007) and, if left untreated, will continue to expand 

based on regional spread projections (Figure 16). These expanding, spreading populations would 

become increasingly more difficult and costly to control in the future and would further degrade 

native plant habitats. Invasive plants would continue to displace native plant species, reduce 

plant diversity, and serve as seed sources for distribution both on and off federal lands. 

The total number of acres approved for chemical treatments with this alternative represents only 

23 percent of existing infested acres and 0.23 percent of the entire forest land base. (Yates 

2007). Since the incorporation of the R6 2005 ROD Standards, the No Action Alternative is now 

limited to 3 herbicides (glyphosate, tryclopyr and picloram with restrictions) for use on approved 

sites (5,172 acres). Some of these herbicides may not always be the preferred herbicide for use in 

certain situations. 

For instance, picloram may pose a higher risk to the environment and non-target species due to 

higher mobility, and higher levels of HCB, compared to some of the newly approved herbicides 

approved in the regional FEIS and proposed for treatment in proposed Alternatives B, C, and D 

(Bautista 2006). Glyphosate is a non-selective herbicide, and may have the potential for 

increased impacts to non-target vegetation compared to the newly approved selective herbicides. 

The No Action Alternative provides only manual methods for EDRR strategy to treat newly 

identified infestations. Past monitoring of these treatment methods (by the forest) indicates 

limited success using these methods (Yates 2006). Repeated manual treatments may be effective 

for controlling or containing small populations of certain plants and may pose less risk to nontarget vegetation compared to herbicide treatments. However, associated labor, time and cost 

may make manual treatments less practical and effective, especially when treating large 

infestations of invasives. The absence of a more effective EDRR strategy increases the potential 

for new invasive plant infestations to establish and spread, potentially reducing native plant 

community biodiversity and affecting other ecosystem structure and functions such as plantpollinator relationships, and mycorrhizal associations. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

All remaining infested acres currently identified in addition to unknown future sites would be 

treated manually likely requiring multiple years of repeated treatment to control contain or 

eradicate. Biocontrol agents that currently are present within or adjacent to the forest could move 

onto forests lands and provide a method of treatment, however, control may take a number of 

years and control is subject to target species and appropriate biocontrol agent presence. These 

less effective methods of control would likely lead to the continued displacement of native plant 

species and the increased spread potential of invasive plants currently infesting the forest. 

Since fewer treatment and herbicide options would be available, preferred herbicides either from 

the resource protection or effectiveness standpoint may not be available. For instance, clopyralid 

on knapweeds, clorsulfuron, imazapic and metsulfuronmethyl for whitetop, and metsulfuron 

methyl for ground based applications on bugloss. Also, treatment methods do not include use of 

aerial herbicide methods which can be an effective and rapid means of controlling or eradicating 

large infestations of invasive weeds, particularly in areas that have steep slopes, rocky soils, and 

are difficult or lack access to effectively treat from the ground. 

Alternative B –Proposed Action 

Under the Proposed Action Alternative all currently mapped invasive plant species would be 

treated with the most effective treatment types and method of application to control, contain or 

eradicate invasive plants, including the 10 newly approved herbicides and surfactants approved 

in the R6 2005 ROD. 

Early detection and rapid response to newly identified infested areas would follow the 

implementation planning process (as described in Chapter 2 of this EIS) for treating invasive 

plants using all treatment methods available, except aerial application, and would comply with 

all PDFs as outlined in Chapter 2 of the EIS. No more than 8,000 acres of known and/or new 

sites would be treated annually, and no more than 40,000 acres would be treated over the life of 

the project. 

Summary of Treatment Effectiveness for Alternative B – Proposed Action Alternative 

Because more sites and acres will be approved for treatment using more effective methods, the 

Proposed Action provides the most effective means for reducing the populations of invasive 

plant species to the forest compared to the No Action Alternative. This alternative also allows the 

use of all 10 herbicides approved in the R6 2005 ROD, which facilitates more effective control 

of existing invasive plant species present on the forest at this time. EDRR using the decision 

process outlined in Figure 12 and the PDFs (both in Chapter 2) also allows for the use of these 

10 herbicides on unknown future sites while protecting forest resources which will provide a 

more effective treatment of invasive plants compared to the No Action Alternative. 

Aerial application of herbicides to proposed sites would provide the most cost efficient and 

effective method of treatment compared to the No Action Alternative and Alternative D. In this 

case, currently proposed and potential future infestation have and will undergo site specific longterm site strategy for restoring/revegetating invasive plant sites prior to treatment (W-W LRMP 

as amended by the R6 2005 ROD Standard 12). PDFs and common control measures are 

designed to protect native vegetation. Additionally, cooperation with public and private 

landholders is anticipated on presently proposed aerial sites further increasing the effectiveness 

of treatments and reducing the potential spread across adjacent ownerships. 

Estimates of invasive weed spread are projected for the No Action Alternative and the Proposed 

Action Alternative (Figure 16). These estimates are based on very broad assumptions, and 

predictions are based on currently identified areas. The assumptions for these projects include: 

106
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

107 

• No Action Alternative treatment effectiveness of 25-35 percent 

• Proposed Action Alternative treatment effectiveness of 80 percent. 

The effectiveness assumptions were applied to all 40 invasive species within presently identified 

acres, forest wide land base; with a maximum of 8,000 acres treated annually. These broad scale 

assumptions can vary based on numerous factors, such as specific geographic areas, specific 

invasive plant species characteristics, and specific treatment types and methods of applying those 

treatments. Alternatives C and D are similar to the Proposed Action Alternative and do not vary 

considerably compared to the Proposed Action projections due to the broad scale assumptions. 

Figure 16 – Comparsion of estimated invasive plant spread between Alternatives A and B 

Alternative C –No Broadcast Herbicide Treatment in Riparian Areas 

Under Alternative C all currently mapped invasive plant species would be treated the same as the 

Proposed Action; however, no broadcast treatment methods (only spot treatments) would be 

allowed in riparian areas (3,104 acres, Table 16). Within the riparian areas treatment would 

include chemical treatments such as spot spraying, wicking, wiping, and stem injection as well 

as manual and mechanical methods as dictated by site specific conditions. All PDFs would be 

implemented as outlined in Chapter 2 for riparian areas. Estimates of annual treatment acres 

would be similar to those reported in the Proposed Action. EDRR to newly identified infested 

areas would follow the decision process outlined in Figure 12 for treating invasive weeds and 

would comply with all PDFs (as outlined in Chapter 2). The elimination of ground based 

broadcast as a method of treatment in riparian areas may reduce the effectiveness of treatment in 

these areas because treatments would be directed only on existing plants and any potential new 

invasive recruits from seedbanks or other underground vegetative parts capable of establishment 

would need to be treated individually as they emerge in upcoming years. For instance, where 

0

10000

20000

30000

40000

50000

60000

70000

1994200620072008200920102011201220132014201520162017201820192020202120222023

YEAR

Acres of Invasive Species

No Action Alt

Proposed Action Alt
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

would need to be treated individually as they emerge in upcoming years. For instance, where 

diffuse knapweed is present inside RCHA boundaries the increased potential for spread from the 

less effective method of application (no broadcast) can serve as a continual propagule source in 

other areas (Figure 19). There is an increased potential for spread in riparian areas that could 

serve as a source to infest upland sites. The effectiveness of this alternative, however, would be 

significantly greater compared to the No Action Alternative because it authorizes treatment of 

many more known infestations and allows for more effective treatment of EDRR sites. 

Alternative C is similar to Alternative B. All herbicide restrictions and buffers as described in the 

PDFs remain the same as in Alternative B; except no ground based broadcast herbicide treatment 

would be allowed in RHCA areas (3,104 acres). 

Herbicide methods of treatment that reduce the potential for off site drift such as spot, wiping, or 

wicking herbicide applications as well non-herbicide methods are possible. This alternative 

would reduce the effectiveness of the treatment in RHCAs especially for species that are 

widespread and the seedbank or underground vegetative parts capable of re-establishment in 

future years is probable. Repeated treatments over multiple years would be needed to treat areas 

such as these and effective control, eradication or containment is likely questionable under 

certain circumstances. 

Alternative D –No Aerial Herbicide Treatment 

Under Alternative D all currently mapped invasive plant species would be treated the same as 

Alternative B, except no aerial treatment methods would be allowed on any proposed (875 acres) 

or future infested acres in extremely inaccessible sites that would warrant aerial application. The 

aerial site acres are yellow starthistle, (96%) so can be treated with a bio control agent; however, 

these methods have not proven to be successful over the past 6-10 years due to variable 

environmental conditions (Dawson 2007). The elimination of aerial treatment reduces treatment 

effectiveness in these areas now 

and in the future due to the 

potential inability to treat either 

from a safety standpoint, or from 

prohibitive cost associated with 

alternative methods of treatment 

(i.e. hiking in with backpack 

sprayers). 

Figure 17 – Starthistle on 

inaccessible site 

Sites that are presently proposed for 

aerial herbicide application are high 

priority, aggressive invasive plant 

species (yellow starthistle, and 

scotch thistle), and if left untreated 

are expected to increase. Appendix B includes maps detailing location of aerial application sites. 

3.2. Botany 

3.2.1 Introduction 

Proposed treatment of invasive plants would be effective in reducing threats to desirable, nontarget vegetation; however there are some risks to native plants from the treatments themselves. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

109 

This section discloses the effects of the alternatives on non-target vegetation, including SOLI 

(e.g. threatened and endangered species, Regional Forester Sensitive Species). 

3.2.2 Affected Environment 

Invasive Plants 

An invasive plant is a non-native plant whose introduction does or is likely to cause economic or 

environmental harm or harm to human health (Executive Order 13122). Invasive plants are 

distinguished from other non-native plants in their ability to spread (invade) into native 

ecosystems. Some species of invasive plants are listed by the Secretary of Agriculture or by the 

responsible State official as “noxious weeds.” This analysis includes all State-listed noxious 

weeds plus other invasive plant species that are of concern because of their impacts to ecosystem 

health. The term “invasive plants” more broadly encompasses all invasive, aggressive, or 

harmful non-indigenous plant species, whether designated noxious or not. 

Invasive plants impact the biological diversity of native plant communities by altering ecosystem 

processes and can completely displace native plant species and cause a decline in overall species 

richness. Invasive plants are highly adept at capturing available moisture and nutrients, and 

often spread quickly. Invasive plant infestations can threaten wild or domestic pollinators by 

outcompeting host plant species. 

Present levels of infestation that incorporate previously treated acres, and adjustments to data for 

past eradication of invasive plant sites indicate there are 40 different invasive plant species 

present on 1,740 sites covering approximately 22,842 acres across the 7 districts on the 

Wallowa-Whitman National Forest (Table 18 and Table 19). In some cases a single mapped site 

may contain more than one species on the same site and therefore the total acres listed by species 

may be slightly higher than acres reported here. Diffuse and spotted knapweeds and yellow 

starthistle and whitetop are four of the species with the most known sites forest-wide (Table 18). 

Annual bugloss, diffuse knapweed, Canada thistle, and yellow starthistle comprise the largest 

infested acres forest wide (Table 19). These acreages indicate the presence of the invasive plant 

species within an area and do not indicate level of infestation by percent cover. Therefore, some 

areas may be heavily infested while others may have only a few scattered invasive plants 

amongst native vegetation. Estimates of total infested acres listed in Table 19 are based on 

physiological characteristics of specific invasive plants and local knowledge of individual sites 

in the area (Dawson 2007). 

The majority of inventoried sites are less than one acre in size and 66 percent of the sites are less 

than five acres in size (Table 20). Acres of invasive plant species associated with forest roads 

including acres spreading out into areas beyond 100 feet of a road represent 20,681 acres (91% 

of the presently identified acres forest wide). This does not imply that all these infested acres are 

caused by roads, but that a forest road exists within a calculated invasive site. Acres of invasive 

within 100 feet of a road total 9,028 acres. 

Additional invasive plant sites likely exist but have not yet been detected by annual inventory 

and mapping efforts. Some species, such as cheatgrass (Bromus tectorum), North Africa grass 

(Ventenata dubia) and Russian thistle (Salsola kali) are abundant but have been given a low 

priority for treatment by the local district office due to task force and/or monetary constraints, or 

species naturalization. However, some cheatgrass or Ventenata sites may be treated if they are 

associated with other infestations treated within the scope of this document. Canada thistle 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

110

(Cirsium arvense) has been given a low priority on some districts, while others may choose to 

treat it, especially when associated with high priority target species. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Table 18-Invasive plant species sites identified on each district within the Wallowa-Whitman National Forest 

Districts and Number of Sites 

Scientific Name Common Name* 

Baker Wallowa- Valley HCNRA Eagle Cap LaGrande Pine 

 Acroptilon repens Russian knapweed 1 3  Alopecurus myosuroides Blackgrass 1  Anchusa officionalis Common bugloss 1  Cardaria draba Hoarycress (Whitetop) 10 1 84 21  Carduus nutans Musk thistle 3  Centaurea diffusa Diffuse knapweed 23 128 47 16 108 Centaurea maculosa Spotted knapweed 16 73 39 9 16 Centaurea species Knapweed species 1 17 1 1 Centaurea debeauxii Meadow knapweed 1 Centaurea solstitialis Yellow starthistle 3 12 136 28 Centaurea virgata Squarrose knapweed 2  Chondrilla juncea Rush skeleton weed 34  Cirsium arvense Canada thistle 24 4 18 6 40  Cirsium vulgare Bull thistle 2  Convvolvulus arvensis Field bindweed  Conium maculatum Poison hemlock 2  Crupina vulgaris Common crupina 1  Cuscuta sp. Dodder 1 Cynoglossum officinale Houndstongue 13 1  Cytisus scoparius Scotch broom 1 1 2  Dipsacus fullonum Teasel 1  Euphorbia esula Leafy spurge 1 1 1 7 Polygonum cuspidatum Japanese knotweed 2  Hieracium caespitosum Yellow hawkweed 1 4 24  Hypericum perforatum St john's wort 32 4  Lepidium latifolium Pepperweed  Linaria dalmatica Dalmation toadlfax 8 60 18 1 4  Linaria sp. Toadflax species 3  Linaria vulgaris Yellow toadflax 2 2 1  Lythrum salicaria Purple loosestrife 3  Onopordum acanthium Scotch thistle 12 37 95 5 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen 

Districts and Number of Sites 

Scientific Name Common Name* Wallowa- Eagle Baker HCNRA LaGrande Pine 

Valley Cap 

 Potentilla recta Sulphur cinquefoil 12 1 3 Rubus discolor Himalayan blackberry 3 Salvia aethiopis and Salvia sclarea 

Mediterrenean and clary sage 

1 

 Salsola tragus Russian thistle  Senecio jacobaea Tansy ragwort 1 2 1 1 36  Senecio sp. Senecio species 3 1  Solanum elaeagnifolium silverleaf nightshade 2  Taeniatherum caputmedusae Medusahead 21  Tribulus terrestris Puncturevine 1 Grand Totals Species and Sites

40 Species 163 347 525 58 277 

*Common names will be used throughout the remainder of this document 112
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Table 19-Invasive plant species and acres by district 

District 

Invasive plant species WallowaValley Eagle Cap 

Baker HCNRA LaGrande Pine Unity 

Russian knapweed 21.0 5.3 Blackgrass or slender meadow foxtail* 

0.3 

Common bugloss* 5812.9 Hoarycress-White-top 104.4 15.3 555.9 87.8 475.7 250.3 Musk thistle* 1.6 25.6 Diffuse knapweed** 420.2 827.4 433.2 706.6 888.1 336.7 538.1 Spotted knapweed* 75.8 212.0 417.2 34.6 31.8 11.4 123.9 Knapweed species* 35.0 37.6 2.1 2.3 31.4 10.2 Meadow knapweed* 0.0 Yellow starthistle** 9.9 96.9 868.0 419.0 572.3 Squarrose knapweed* 6.6 Rush skeleton weed* 375.1 15.3 Canada thistle 471.2 200.3 738.4 127.5 462.4 167.8 1227.4 Bull thistle 22.2 Field bindweed 3.3 Poison hemlock 6.5 0.6 Common crupina* 284.2 Dodder 7.2 2.4 Houndstongue 211.0 39.9 406.6 321.6 Scotch broom* 0.3 114.7 0.1 Teasel 22.0 8.1 Leafy spurge* 51.6 0.6 0.9 22.3 26.6 Yellow hawkweed* 0.1 6.9 9.2 St john's wort 258.5 213.1 100.4 31.5 Pepperweed* 0.7 Dalmation toadflax* 77.8 191.8 14.9 2.9 1.7 137.0 302.1 Toadflax species 3.8 Yellow toadflax 34.9 1.9 7.5 6.2 0.1 Purple loosestrife* 2.5 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen 

114

District 

Invasive plant species 

Baker Wallowa- Valley HCNRA Eagle Cap LaGrande Pine Unity 

Scotch thistle 88.9 426.8 1194.3 16.8 20.6 96.8 Japanese knotweed* 77.5 Sulphur cinquefoil 80.9 0.1 9.8 96.1 Himalayan blackberry 15.2 Mediterranean and clary sage** 

21.9 

Russian thistle 9.7 Tansy ragwort 3.0 2.4 0.9 0.5 7.4 63.9 Senecio species 4.3 4.1 Silverleaf nightshade* 10.9 Medusahead 6.0 914.7 Puncturevine 12.3 Total 1973.2 2420.2 10811.0 881.4 2013.1 3309.2 3026.3 * = Ranked as priority species 1 across all districts, ** = 85% of districts ranked as priority species 1, *** 71% of districts ranked as priority species 1. 1Estimates of total infested acreages represent 55% for whitetop and hawkweed and 25% for all other species, common bugloss site estimated at 1,500 acr2Total includes multiple species occurring on the same site; therefore acres reported here are larger than 22,802 acres infest
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 20-Range of acreage of infested sites documented on the Wallowa-Whitman National 

Forest 

Size of Infestation Number of Sites Percent of Known Sites 

Less than 1 acre 715 41.1 

1 to < 5 acres 432 24.8 

5 to < 10 acres 276 15.8 

10 to < 50 acres 241 13.8 

50 to < 100 acres 50 2.8 

100 to < 500 acres 22 1.2 

500 acres or more 4 0.2 

Total 1740 100% 

Recent Forest Service mapping efforts have also identified approximately 6,633 infested 

acres on private, state or county lands adjacent to or overlapping with forest service lands. In 

the future, these areas could be treated together as a cooperative effort to contain and control 

invasive species where invasives overlap ownership boundaries. Priorities will be set by the 

Districts on a project level basis. 

Native Vegetation 

The Wallowa-Whitman National Forest located in northeast corner of Oregon and the west 

central edge of Idaho contains a wide diversity of plant species (approximately 1,500 species) 

and communities due to varying elevation and precipitation zones that occur within eastern 

Oregon (USDA Forest Service 2007b). The 2.3 million plus acre forest lies within Wallowa, 

Union, Baker, Malheur, Umatilla, and Grant Counties in Oregon and Adams, Idaho, and Nez 

Perce Counties in Idaho. Included in this acreage are Hells Canyon National Recreation Area 

(HCNRA) (621,311 acres) and four designated wilderness areas (Eagle Cap, Hells Canyon 

Wilderness, Monument Rock, and North Fork John Day) representing approximately 26 

percent of the Wallowa-Whitman Forest. There is also nine designated wild and scenic rivers 

on the forest covering an estimated 294 miles. 

The complex geologic history of the area which included floods, volcanic eruptions, 

landslides and erosion have shaped the landscape of the forest into a unique combination of 

landforms and vegetation patterns. The unique combination of geology and topography has 

produced a distinctive, mosaic pattern of dense, heavily timbered slopes interspersed between 

open, rugged grasslands. Ecological habitats ranging from low to high elevation include: 

juniper, sagebrush, grasslands, ponderosa pine, mixed conifer, sub-alpine fir, Engelmann 

spruce, and alpine plants. Biophysical settings are aggregations of plant associations and 

represent a combination of temperature and moisture regimes for the Wallowa-Whitman 

National Forest and include those listed in Table 21. Given this combination of physiography 

and climate, habitats are highly variable and retain a legacy of botanical diversity. 

Since the time of the pioneers, movement of people into the area and the associated 

establishment of invasive weed spread vectors (highways, railroads, canoes, rafts, and other 

transportation methods) have continued to alter habitats and vegetation types across the 

landscape. For example, many areas within the forest have become permanently altered by 

cheat grass, which has become naturalized. In certain instances this permanent alteration of 

habitat has affected native vegetation and species of local interest (SOLIs) in the past (Morse 

et al. 2006). Eastside forests are more susceptible to invasive plants than other forests in the 

115 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

region (R6 2005 ROD). In general, their grasslands, riparian areas, and relatively dry, open 

forests are more susceptible to invasion than are dense moist forests and high montane areas 

(R6 2005 ROD). The grasslands, riparian areas, and relatively dry, open forests have frequent 

gaps in the plant cover, which favor invasive plant establishment. The moist forests and high 

montane areas have relatively closed plant cover or have extreme climate or soils, which are 

tolerated by fewer invasive plant species. Invasive plants tend to colonize disturbed ground 

along and around developments such as roads, highways, utility (powerline) corridors, 

recreational residences, trails, campgrounds and quarries. These are all places where native 

vegetation has been removed and disturbance has been created areas for invasive plants to 

establish. 

Plant communities can be classified by a variety of factors such as vegetation structure, site 

moisture, overstory, and understory. The R6 2005 FEIS used broad potential vegetation 

groups (PVGs) to rate the susceptibility of vegetation. Table 21 provides a summary of the 

PVGs found in the Wallowa-Whitman Forest, their susceptibility to damage from invasive 

plants, the local plant community types that correspond to these broad PVG types, and 

mapped acres of invasive plants within the plant community types. The susceptibility of plant 

communities to invasion can be influenced by many factors, including disturbance levels, 

community structure, and the biological traits of the invader species. The majority of plant 

community types found on the Wallowa-Whitman National Forest are moderately to highly 

susceptible to invasion. 

Table 21-Potential vegetation groups on the Wallowa-Whitman National Forest’s 2.3 million 

acres and their susceptibility to invasive plants 

Potential Vegetation Group Percent of Forest Susceptibility to 

Invasion1 

Infested acres 

(all species)2 

Admin 0.1 183.1 

Cold dry upland forest 16.9 Moderate 761.4 

Cold moist upland herbland 2.0 Moderate 95.2 

Cold moist shrubland 0.8 Moderate 1.5 

Dry upland forest 31.3 Moderate 8926.6 

Dry upland herbland 13.9 High 6727.3 

Dry upland shrubland 2.0 High 1150.4 

Dry upland woodland 0.6 Moderate-high 117.0 

Warm dry riparian herbland 0.1 High 12.9 

Warm riparian forest 0.1 Moderate 0.2 

Warm low dry herbland 0.0 High 76.7 

Warm riparian shrubland 0.0 Moderate 0 

Warm riparian forest 0.0 Moderate-high 167.5 

Warm riparian herbland 0.3 Moderate-high 153.6 

Moist forest 16.4 Moderate-high 1925.7 

Moist herbland 3.0 Moderate-high 1664.0 

Moist shrubland 0.8 Moderate 117.3 

Moist woodland 0.2 Moderate-high 25.4 

Nonveg 4.2 ----- 221.2 

Riparian 0.1 ----- 152.9 

Water 0.3 ----- 104 

Grand Total 100.0 222,583 

1 Susceptibility ratings (derived from R6 FEIS): High = high susceptibility to invasion. Invasive plant species invade 

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 or frequent disturbance that impacts the soil surface or 

116
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

removes the normal canopy; Low = low susceptibility to invasion. Invasive weed species does not establish 

because the cover type does not provide suitable habitat. 

2 Some mapping error due to overlap in species occurrences in duplicate potential vegetation groups in GIS 

database 

Botanical Species of Local Interest (SOLI) 

Botanical SOLI include vascular and nonvascular plant species (bryophytes and lichens) that 

are: 

• Threatened and/or endangered species (federally listed or proposed for listing under 

the Endangered Species Act- (for full analysis of effects see Biological Assessment 

for Plants) 

• Regional Forester Sensitive Species (Forest Service Manual 2670) 

• Plant species endemic to the forest 

• Special species of local interest to the forest such as disjunct species located in 

HCRNA 

The Forest Service is directed to manage habitats for all existing native and desired nonnative 

plants, fish, and wildlife species in order to maintain viable populations of such species. This 

direction comes from the Forest Service Manual section 2600 (USDA Forest Service 1995a, 

WO Amendment 2600-95-7) and stems from direction provided by the Endangered Species 

Act. Forest Service Manual (FSM) 2670.5 defines sensitive species as those plant and animal 

species identified by a Regional Forester for which population viability is a concern, as 

evidenced by significant current or predicted downward trends in population numbers, 

density, or habitat capability that would reduce a species’ existing distribution. In FSM 

2670.22, the management objective for sensitive species is, in part, to develop and implement 

management actions to ensure that species do not become threatened or endangered because 

of Forest Service actions and to maintain viable populations of all native and desired 

nonnative wildlife, fish, and plant species in habitats throughout their geographic range on 

National Forest System lands. A viable population is a population that has the estimated 

numbers and distribution of reproductive individuals to ensure the continued existence of the 

species throughout its existing range (or range required to meet recovery for listed species) 

within the planning area. 

A biological evaluation (BE) is conducted to review Forest Service programs and activities 

for possible effects on sensitive species, as required in Forest Service Manual 2672.4 (USDA 

Forest Service 1990a, 1995a) and the Wallowa-Whitman Forest Plan (USDA Forest Service 

1990). The specific requirements of a BE include a prefield review of available information 

to identify known or potentially occurring TES plant species, a field reconnaissance of the 

proposed project, and an evaluation of potential effects to TES plant species from the 

proposed project. The biological evaluation for this project is available upon request from the 

project record. 

Prefield Review 

A review of available information was completed in order to identify sensitive plant species 

known or potentially occurring in the project area. 

The following sources were consulted for the prefield review: 

• Regional Forester’s Sensitive Species List (USDA Forest Service 2004d) 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

• Oregon Natural Heritage Information Center’s (formerly the Oregon Natural Heritage 

Program) Rare, Threatened and Endangered Species List (May 2004) 

• U.S. Forest Service sensitive plant survey GIS layer and associated databases 

• U.S. Forest Service personnel (Forest Botanists and Ecologists) 

• Literature (see References). 

The following two tables list all SOLI for Wallowa-Whitman National Forest and Hells 

Canyon National Recreation Area. The two lists are separate because HCNRA administers 

part of the Payette National Forest (Region 4) and the Nez Perce National Forest (Region 1). 

Two federally listed species, MacFarlane’s four o’clock (Mirabilis macfarlanei) and

Spalding’s catchfly (Silene spaldingii) are documented on the forest and a separate biological 

assessment (BA) prepared for submission to US Fish and Wildlife service will directly assess 

the impacts of this project on these two federally listed species. 

Table 22-Regional sensitive plant species for the Wallowa-Whitman National Forest 

Species Documented or Suspected 

to Occur on Forest 

Achnatherum wallowensis D 

Allium geyeri var. geyeri D 

Arabis hastatula D 

Botrychium ascendens D 

Botrychium campestre D 

Botrychium crenulatum D 

Botrychium fenestratum D 

Botrychium lanceolatum D 

Botrychium lineare D 

Botrychium lunaria D 

Botrychium minganense D 

Botrychium montanum D 

Botrychium paradoxum D 

Botrychium pedunculosum D 

Botrychium pinnatum D 

Calochortus longebarbatus var. longebarbatus D 

Calochortus macrocarpus var. maculosus D 

Calochortus nitidus D 

Carex atrata var. atrosquama D 

Carex backii D 

Carex dioica . D 

Carex hystericina D 

Carex interior D 

Carex nardina D 

Carex norvegica D 

Carex nova D 

Carex stenophylla (C. eleocharis) D 

Castilleja fraterna D 

Castilleja rubida D 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

119 

Species Documented or Suspected 

to Occur on Forest 

Cypripedium fasciculatum D 

Erigeron disparipilus D 

Erigeron engelmannii var. davisii D 

Kobresia bellardii (K. myosuroides) D 

Kobresia simpliciuscula D 

Leptodactylon pungens ssp. hazeliae D 

Listera borealis D 

Lomatium erythrocarpum D 

Lomatium greenmanii D 

Lycopodium complanatum D 

Mimulus clivicola D 

Mimulus hymenophyllus D 

Mirabilis macfarlanei D 

Pellaea bridgesii D 

Phacelia minutissima D 

Phlox multiflora D 

Platanthera obtusata D 

Primula cusickiana D 

Rubus bartonianus D 

Salix farriae D 

Saxifraga adscendens var. oregonensis D 

Senecio dimorphophyllus D 

Silene spaldingii D 

Thalictrum alpinum var. hebetum D 

Townsendia montana D 

Townsendia parryi D 

Trifolium douglasii D 

Trollius laxus var. albiflorus D 

Carex parryana S 

Cicuta bulbifera S 

Howellia aquatilis S 

Lomatium ravenii S 

Lomatium salmoniflorum S 

Pleuropogon oregonus S 

Rorippa columbiae S 

Suksdorfia violacea S 

Thelypodium eucosmum S 

Dermatocarpon luridum S 

Leptogium burnetiae var. hirsutum S 

Leptogium cyanescens S 

Peltigera neckeri S 

Rhizomnium nudum S 

Schistostega pennata S 

Scouleria marginata S 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Documented or Suspected Species to Occur on Forest 

Tetraphis geniculata S 

Table 23-Hells Canyon National Recreation Area - Threatened, Endangered or Proposed; 

Candidate, Sensitive, Endemic and Disjunct Species 

Forest Service2 

Sensitive Species Plant Species Federal1 

Status Region 

6 

Region 

4 

Region 

1 

Doc3 Habitat* 

Threatened, Endangered, or Proposed Species 

Howellia aquatilis LT X X X R 

Mirabilis macfarlanei LT X X X X G 

Silene spaldingii LT X X X G 

Spiranthes diluvialis LT X R 

Thelypodium howellii var. 

spectabilis LT R, G 

Candidate Species 

Botrychium lineare X R, MWM 

Sensitive Species 

Adiantum aleuticum X RCB, R 

Achnatherum 

wallowaensis X X L 

Allium madidum X MWM 

Allium tolmeii var. 

persimile X X L 

Allotropa virgata X X CF 

Arabis hastatula X X RCB 

Astragalus paysonii X X CF 

Astragalus vexilliflexus 

var. vexilliflexus X G 

Blechnum spicant X CF 

Botrychium ascendens X X R, MWM 

Botrychium campestre X R, MWM 

Botrychium crenulatum X X R, MWM 

Botrychium fenestratum X R, MWM 

Botrychium lanceolatum X X R, MWM 

Botrychium lunaria X R, MWM 

Botrychium minganense X X R, MWM 

Botrychium montanum X X R, MWM 

Botrychium paradoxum X X R, MWM 

Botrychium 

pedunculosum X X R, MWM 

Botrychium pinnatum X X R, MWM 

Botrychium simplex X X R, MWM 

Bryum calobryoides X CF 

Buxbaumia aphylla X CF 

Buxbaumia piperi X CF 

Buxbaumia viridis X X CF 

Calamagrostis tweedyi X CF, G 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

121 

Forest Service2 

Sensitive Species Plant Species Federal1 

Status Region 

6 

Region 

4 

Region 

1 

Doc3 Habitat* 

Calochortus 

longebarbatus var. 

longebarbatus 

X R, MWM 

Calochortus 

macrocarpus var. 

maculosus 

X X G 

Calochortus nitidus X X X X G 

Camassia cusickii X X R 

Cardamine constancei X CF 

Carex aenea X MWM, R 

Carex atrata var. 

atrosquama X MWM, A 

Carex backii X R 

Carex buxbaumii X X MWM 

Carex dioica var. 

gynocrates X R 

Carex flava X MWM 

Carex flava var. rustica X R, MWM 

Carex hendersonii X G 

Carex hystericina X X MWM, R 

Carex interior X X MWM, R 

Carex livida X MWM 

Carex nardina X A 

Carex norvegica X A, MWM, R 

Carex nova X A, MWM 

Carex parryana X MWM 

Carex paupercula X MWM 

Carex scirpoidea var. 

stenochlaena X MWM 

Carex stenophylla X G, MWM 

Carex straminiformis X A, RCB 

Castilleja fraternal X A, RCB, MWM, R 

Castilleja rubida X RCB, A 

Ceanothus prostratus 

ssp. Prostrates X CF 

Cetraria subalpina X CF 

Chrysothamnus 

nauseosus 

X RCB 

Cicuta bulbifera X X R 

Cornus nuttallii X CF 

Crepis bakeri ssp. 

idahoensis X G 

Cypripedium 

fasciculatum X X X CF, R 

Dasynotus daubenmirei X CF 

Diphasiastrum 

complanatum = 

Lycopodium 

complanatum 

X CF, R 

Douglasia idahoensis X X CF, 

Epipactis gigantea X X X R 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Forest Service2 

Federal1 Sensitive Species Plant Species Doc3 Habitat* Status Region Region Region 

6 4 1 

Erigeron disparipilus X X L 

Erigeron engelmanni var. 

davisii X X G, RCB 

Hackelia davisii X RCB 

Halimolobos perplexa 

var. perplexa X X X X G 

Haplopappus hirtus var. 

sonchifolius X X MWM 

Haplopappus 

insecticruris X G 

Haplopappus radiatus = 

Pyrrocoma radiata X G 

Helodium blandowii X MWM 

Hookeria lucens X CF, R, 

Kobresia bellardii X A 

Kobresia simpliciuscula X MWM, R 

Leptodactylon pungens 

ssp. hazeliae X X X G, RCB 

Lewisia kelloggii X A 

Listeria borealis X CF 

Lobaria scrobiculata X RCB 

Lomatium erythrocarpum X A 

Lomatium greenmanii X A 

Lomatium ravenii X L 

Lomatium salmoniflorum X X X G 

Mimulus ampliatus X R 

Mimulus clivicola X X X X G 

Mimulus hymenophyllus X X R, RCB 

Pellaea bridgesii X RCB 

Pentagramma 

triangularis X X RCB 

Peraphyllum 

ramosissimum X G 

Phacelia minutissima X X X MWM, 

Phlox multiflora X G, RCB 

Platanthera obtusata X MWM 

Pleuropogon oregonus X R, MWM 

Primula cusickiana X X R, L 

Ranunculus oresterus X MWM 

Rhizomnium nudum X CF 

Rhynchospora alba X X MWM 

Ribes wolfii X CF 

Rorippa columbiae X R 

Rubus bartonianus X X X R, RCB 

Salix farriae X MWM, R 

Salix glauca X A 

Sanicula graveolens X G 

Saxifraga adscendens 

var. oregonensis X RCB, A 

Saxifraga bryophora var. X RCB 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

123 

Forest Service2 

Sensitive Species Plant Species Federal1 

Status Region 

6 

Region 

4 

Region 

1 

Doc3 Habitat* 

tobiasiae 

Saxifraga tolmiei var. 

ledifolia X CF, A 

Scheuchzeria palustris X MWM 

Sedum borschii X RCB 

Senecio dimorphophyllus X MWM, A 

Sphagnum mendocinum X MWM 

Stylocline filaginea X G 

Suksdorfia violacea X RCB 

Syntheris platycarpa X CF 

Thalictrum alpinum var. 

hebetum X MWM 

Thelypodium eucosmum X G 

Tofieldia glutinosa var. 

absona X MWM 

Townsendia montana X A 

Townsendia parryi X A 

Triantha occidentalis ssp. 

Brevistyla X MWM, R 

Trifolium douglassii X G, MWM 

Trifolium longipes ssp. 

multipedunculatum X G, MWM 

Trollius laxus var. 

albiflorus X X MWM, R 

Waldsteinia idahoensis X CF 

Endemic Species 

Arabis crucisetosa X MWM 

Astragalus vallaris X G 

Frasera albicaulis var 

idahoensis X G 

Lomatium rollinsii X G 

Lomatium serpentinum G 

Nemophila kirtleyi X CF 

Penstemon elegantulus X G 

Phlox colubrina X G, RCB 

Ribes cereum var. 

colubrinum X R 

Disjunct Species 

Allium geyeri var. geyeri X MWM, R 

Bupleurum americanum X A 

Carex limosa X MWM 

Cryptogramma stelleri X RCB 

Drosera anglica X MWM 

Geum rossii var. 

turbinatum X RCB 

Pediocactus simpsonii 

var. robustior X G 

Potentilla palustre X MWM 

Xerophyllum tenax X CF, A-MWM 

1. Federal Status. LT- Listed Threatened as defined by the Endangered Species Act of 1973. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

2. Region 6 Regional Forester’s Sensitive Species List. Applies to all Hells Canyon land in Oregon (June 10, 1991) 

updated by April 1999 listing. 

Region 4 Regional Forester’s Sensitive Species List. Applies to all land on the Payette National Forest in Idaho that 

is administered by the HCNRA (November 1995). 

Region 1 Regional Forester’s Sensitive Species List. Applies to all land on the Nez Perce National Forest in Idaho 

that is administered by the HCNRA (March 12, 1999). 

3. Doc - Documented in the HCNRA - Indicates that the species has been documented in the HCNRA. 

*. Habitat: A=Alpine; CF = Coniferous Forest; G = Grassland; L = Lithosol; MWM = Moist and Wet Meadows; R = 

Riparian Areas; RCB = Rock Outcrops, Cliffs, and Bluffs. 

Field Surveys 

Botanical surveys for SOLI have been conducted on the Wallowa-Whitman National Forest 

and in general were associated with proposed projects and/or focused surveys in specific 

habitats as directed by the forest botanist (Yates 2006). Survey routes and documented 

occurrences and habitats for SOLI are on file at the Wallowa-Whitman National Forest 

Supervisor’s office. Because of incomplete forest-wide surveys, some undocumented SOLI 

may exist in or near identified invasive plant sites. To determine SOLIs currently identified 

on the forest with the highest potential for invasive plant treatment effects and highest risks 

from invasive plant impacts, GIS databases and records from Wallowa-Whitman National 

Forest weed surveys over the past 20 years (Yates 2007) were used to identify SOLIs within 

100-1000 feet of identified invasive plants. Invasive plant sites were identified for SOLI as 

follows: 

• Invasive plant sites within 1000 feet of a federally listed plant species for any proposed 

treatment 

• Invasive plant sites within 300 feet of a non-federally listed plant species where aerial 

herbicide application is proposed 

• Invasive plant sites within 100 feet of non-federally listed SOLI for all ground based 

treatments 

Presently, there are 22 species of plant SOLI representing 80 individual locations within 100 

feet of an invasive plant site proposed for treatment (Table 25). No SOLI are presently 

identified within 300 feet of a proposed aerial site. No federally listed SOLI are within 1000 

feet of a proposed aerial site. 

3.2.3 Environmental Consequences 

The public has expressed concerns that there is and will continue to be a loss of vegetation 

diversity within native plant communities from the continued spread of invasive plants. The 

public has also expressed concern that the application of herbicides has the potential to 

adversely affect non-target plant species, including SOLI. 

Continued loss of vegetation diversity is addressed through the analysis of treatment 

effectiveness of Proposed Actions of reducing invasive plants. Treatment effectiveness is 

measured by the decrease or elimination of the invasive plant species and the concomitant 

recovery of the area with native or desirable vegetation. Effectiveness for all treatment 

methods were derived from a thorough review of the literature. Sources of information 

included Effects of Non-herbicidal Methods of Invasive Plant Treatments on Wildlife, Fish 

and Plants (R6 2005 FEIS, Appendix J), non-herbicidal methods and technical handbooks 

such as the Nature Conservancy Weed Control Handbook (Tu et al. 2001), county and state 

extension service or weed control board publications, peer reviewed journal articles, and 

invasive weed experts in the region. A compilation of these reviews can be found in Appendix 

A this document and Appendix N of the R6 2005 FEIS (Common Control Measures for 

Invasive Plants of the Pacific Northwest Region Draft Mazzu 2005). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Concerns related to impacts to non-target plant species including SOLI from treatments have 

been described previously within herbicide risk assessments (R6 2005 FEIS), assessments of 

herbicide best management practices (Berg 2004), a review of the literature non-herbicidal 

effects to plants (R6 2005 ROD, Appendix J), risks to pollinators of native plant communities 

(R6 2005 FEIS), and peer reviewed scientific papers. Risks to non-target species including 

SOLI are based on the combination of treatment effectiveness between alternatives and direct 

and indirect effects from proposed treatments. 

Determination of effects are based on the assumption that all PDFs as listed in Chapter 2 of 

this EIS will be implemented in accordance with all the standards outlined in the WallowWhitman National Forest LRMP as amended by the R6 2005 ROD. Treatment effects to 

native plant communities and pollinators associated with these communities is evaluated at a 

forest wide scale. Effects to individual SOLI are based on individual site occurrences, 

proposed treatment to nearby invasive plant species and overall risk of treatment 

effectiveness by alternative. 

Herbicide Effects on Plant Diversity 

Just as changes in plant diversity or species composition can occur due to invasive plants, 

changes can also occur due to treatments. Short-term changes in species dominance can lead 

to long-term shifts in plant community composition and structure. Repeated treatments over 

time could favor tolerant species, which in turn could shift pollinators available to a 

community. DiTomaso (2001) points out that continuous broadcast use of one or a 

combination of herbicides will often select for tolerant plant species. Noxious annual grasses 

such as medusahead, cheatgrass or barbed goatgrass may become dominant with a broadcast 

application of broadleaf selective herbicides. 

Population shifts through repeated use of a single herbicide may also reduce plant diversity. 

Alternatively, plant diversity is reported to be maintained on sites with repeated applications 

of picloram and chloryralid for control of spotted knapweed in Montana (Rice 2000). 

Additionally, analyses based on 60 published studies of terrestrial plants and animals in 

temperate zone forests and agro-ecosystems indicate species richness and diversity of 

vascular plants was either unaffected or increased (particularly herbaceous species) in 

response to glyphosate (Sullivan and Sullivan 2003). Project design features such as the 

development of a long-term site strategy, monitoring, and restoration would be directed 

towards sites that could experience repeated herbicide applications (i.e. areas where recovery 

to native vegetation may not be possible such as campgrounds, highly disturbed areas). It is 

likely that due to the nature of repeated disturbance activities in some areas on the forest, 

long-term site objectives may be focused on containment of these areas to prevent future 

spread into other areas of the forest. 

Herbicide treatments may impact soil biology which may in turn impact plant diversity, such 

as shifting plant composition. Effects are expected to be transitory based on the herbicide 

type and frequency applied. For a complete review of soil biological effects see the Soils 

section. It is expected that adverse effects would be minimized by adjusting herbicide use to 

avoid soil buildup and leaching to groundwater (see Hydrology section in this chapter and 

soil and water PDFs in Chapter 2). In general, most of the proposed herbicides are highly 

mobile and therefore buildup is not a concern. For immobile herbicides such as picloram 

(tordon) and glyophosate (Rodeo, Roundup), spraying frequency restrictions alleviate risk for 

soil buildup. Soil erosion from loss of vegetative cover is only a concern for monocultural 

stands of weeds. The highest erosion concern is associated with steep roadside treatment of 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

knapweeds and broadcast treatment of common crupina and whitetop monocultures on 

disturbed areas with moderate slope. Erosion risk is for 1-2 years while desired species 

revegetate. For complete analysis of herbicide effects to soils see the Soils report. 

Herbicide Effects on Fungi and Mycorrhizal Associations 

Mycorrhizae are mutualistic associations between specialized soil fungi and the roots of 

vascular plants. The fungal partners of this association come from several phyla in the fungi 

kingdom (Basidiomycetes, Ascomycetes, and Zygomycetes). Most vascular plants (95%) 

form mycorrhizae and they have been shown to be essential for maintaining plant health. 

Benefits include improved nutrient and water uptake, improved root growth, improved plant 

growth and reduced drought stress.. 

No studies investigating the relations between pesticide applications and edible forest 

mushroom production or consumption have been found (Pilz and Molina 2001). Herbicides 

are sometimes used to release newly planted conifers from competition by broadleaf trees and 

shrubs, but commercially harvested ectomycorrhizal mushrooms usually begin fruiting 5-15 

years later as the conifer stand develops, so that only persistent compounds or recent drift 

from nearby areas are potential hazards. 

Herbicide Effects on Lichen and Bryophytes 

Impact of invasive species to lichens, and bryophytes is not widely documented in the 

literature, likely due to taxonomic problems, lack of experts in this field of study, the small 

size and intermixing of taxa in the environment and the life history and variation observed 

within individual species. Impacts to lichen and bryophytes from herbicide applications are 

better documented. Glyphosate and triclopyr applications studies in the field and laboratory 

have indicated negative impacts to lichens and bryophytes and a reduction in species diversity 

(Newmaster et al. 1999). However, other studies indicate little effect on bryophytes and 

lichens in field and laboratory conditions (Atkinson et al. 1980; Balcerkiewicz and Rusińska 

1987, Bond 1976, Mabb 1989, Pihakaski and Pihahaski 1980, Ronoprawiro 1975, Rudolph 

and Samland 1985, Stjernquist 1981). Herbicide drift may impact some species because 

bryophytes and lichens receive their mineral nutrition and water from precipitation, splash 

water, or directly from the atmosphere. Physiological research is also needed to explain 

whether herbicides directly alter the physiology of bryophytes and lichens or affect their 

associated microhabitats. 

It is expected that the implementation of PDFs that outline effectiveness monitoring will not 

only adjust buffers to protect these species if negative impacts are observed, but also help fill 

information gaps for projects such as these in the future. Short term impacts could be 

expected. Long-term positive effects to habitats are expected because effective treatment of 

existing and future invasive plants would restore, protect and maintain habitats these species 

require. 

Herbicide Effects to Pollinators and Colony Collapse Disorder 

Limited research is available that addresses impacts from invasive plants on mutualistic 

relationships between plant pollinators and native plant communities. One study has indicated 

that exotic plants may compete better for native plant pollinators by producing more desirable 

nectar and therefore increasing fitness and reproductive ability of the non-native plant 

(Levine et al. 2004). Presently, little is known about native plant and native plant pollinators 

in general. Efforts to understand these interactions are just beginning to study basic aspects of 

plant-pollinator interactions for optimal management decisions to be made for conservation 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

of these interactions in natural systems (Kearns et al. 1998). It is estimated that there may be 

between 130,000 and 200,000 invertebrate and vertebrate species that regularly visit the 

flowers of higher plants, which depend on these animals to assure cross-pollination. The 

majority of flowering plants in the world (88 percent) are pollinated by beetles, followed by 

wasps (18 percent) and bees (16.6 percent of flowering plants) (Buchman and Nabhan 1996). 

In relation to treatment effectiveness, it is assumed that any treatment that reduces invasive 

plants within a native plant community will result in a positive impact on the community 

when that native plant community is restored. Very little information is available on the effect 

of herbicides on native pollinators. 

Most information is related to impacts on the non-native honey bee. It is known that 

pollinators can be directly affected by spray or indirectly when plants needed as food for 

adults or larvae are eliminated by herbicides (Shepherd et al. 2003). The only known 

quantified effects are from direct spray. The herbicides approved for use in the regional FEIS 

are not expected to have toxic effects when directly sprayed on honeybees at the typical 

Forest Service application rates. However, glyphosate may have some toxic effects if applied 

at the maximum application rate proposed by the Forest Service, and triclopyr approaches 

toxicity levels for bees but does not exceed levels considered to be toxic (SERA 2003-

glyphosate; SERA 2003-Triclopyr). 

Uncertainty exists regarding the effects of herbicides on non-target plant species and 

pollinators because native species are not the usual test species for EPA toxicity studies. The 

EPA performs studies predominantly on crop species. Boutin et al. (2004) concluded that it 

was likely that the current suite of tested species were not representative of the habitats found 

adjacent to agricultural treatment areas, and suggested the current suite of tested species 

might cause an unacceptable bias and underestimated risk. Because of the lack of studies 

available to fully assess the impacts to native pollinators, it is possible that some short term 

impacts to pollinators in localized areas could occur from herbicide treatments. Long-term 

impacts would be not be expected to occur because herbicide treatments are presently 

proposed on less than 1.6 percent of the forest landbase with the remaining forest lands 

serving as future native pollinator sources after invasive areas are restored or recovered to 

native vegetative states. 

Another concern is the contribution herbicides might have on “colony collapse disorder” 

(CCD). In 2006-2007, commercial honey bees in North America and other parts of the world 

experienced alarming declines characterized by: 

• The disappearance of adult bees from the hives, and no bees or a few dead bees near the 

hive 

• Healthy, capped brood 

• Food reserves that have not been robbed 

• Minimal evidence of wax moth or hive beetle damage; 

• A laying queen with immature bees and newly emerged attendants 

(CCD Steering Committee 2007, Winfree et al. 2007) By 2007, almost 30 percent of 

beekeepers in the United States reported losses of up to 90 percent of their colonies (CoxFoster et al. 2007; Winfree et al. 2007). Colony Collapse Disorder has not been reported in 

wild native bees (Winfree et al. 2007). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Suspected causes of colony collapse disorder include the following factors, alone or in 

combination: 1) environmental and nutritional stress; 2) new and /or re-emerging pathogens; 

3) pests that attack bees; and 4) pesticides (CCD Steering Committee 2007). Several major 

setbacks to honey bee populations over the last two decades have combined to increase stress 

on the remaining hives as they are moved and worked for their pollination services over 

longer seasons and larger geographic areas. Climate change, drought, and unseasonably cold 

weather combine to create increased stress on bee populations. Commercial bees are often fed 

high fructose corn syrup, which may contribute to some nutritional deficiencies. 

Pathogens are primary suspects because colony collapse disorder is transmissible to other 

hives through the reuse of equipment from colony collapse disorder-affected colonies. Such 

transmission can be broken by irradiation of the equipment before use (Pettis et al. 2007). The 

Varroa Mite (Shen et al. 2005) and Israeli acute paralysis virus (Cox-Foster et al. 2007, 

Kaplan 2008) are pathogens suspected of significant damage to honey bee populations. 

Herbicides, as proposed herein, have little potential of damaging commercial honey bee 

populations because bee colonies found on National Forest System lands are native wild bees, 

not commercial honey bees whose colonies are mostly on private agricultural lands. Colony 

collapse disorder has not been documented in native wild bee colonies even though herbicide 

application has been ongoing on National Forest System lands where wild colonies are found. 

There is little concern that this project could adversely affect commercial bees given that just 

1.7 percent of the Forest is expected to be treated during the life of this project, and the small 

likelihood commercial honey bees would be present at the time of application. Finally, even 

if this project included spraying private agricultural lands, (which it does not) herbicides are 

use is not among the likely causal agents of CCD. 

Invasive plant infestations that shift plant communities and adjust plant species make-up 

away from those communities where pollinators commonly associate may be the greatest 

threat to wild or domestic pollinators (J. Laufman, personal observation). 

Manual and Mechanical Effects on Non-target Plants, Native Plant 

Communities and SOLI 

Manual treatments proposed in this EIS are mostly on small patches of invasive plants on 

sites less than three acres in size. Species targeted for manual treatment methods include: 

houndstongue, scotch thistle, blackgrass, whitetop, dodder, poison hemlock, yellow 

hawkweed, silver nightshade, medusahead, and sulphur cinquefoil. 

The variation between alternatives is reflected in the number of herbicides available for use, 

the method of applying the herbicides and other available treatment methods. The following 

paragraphs provide specific information related to the effectiveness and impacts to native 

vegetation of all treatments. 

The removal of invasive plants using manual techniques (i.e. handpulling, digging with hand 

tools, clipping flower heads with hand tools) could directly affect non-target vegetation, 

including botanical SOLI in situations where the invasive plants are co-located with these 

species. Direct negative effects would be unintentional removal of flowers, fruits, or root 

systems of these species. Vigor could be reduced in individuals through reduction in 

photosynthesis or reproduction potential. Solarization coverings may have negative effects on 

soil microorganisms and non-target species’ seed viability and would not selectively allow 

other plants to grow, as would a selective hand application of an herbicide. Hot water and 

foaming treatments, shown to be effective on small areas on annual weeds and seedlings, is 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

less effective on underground roots or rhizomes, is restricted to proximity to steam generating 

equipment (i.e. roadsides), has high risks of applicator burns, and unknown impacts to soil 

microorganisms and co-located non-target species. 

These short-term impacts, if kept to a minimum in relation to population size, would be more 

than compensated by the long-term positive benefits of removal of aggressive, competitive 

invasive plants. Manual control crews could also directly impact non-target vegetation, 

including botanical SOLI through trampling of individuals or creation of erosive conditions 

within or upslope of populations. These impacts may have a more long term negative impact, 

but again if minimized, the benefit to the species would be more positive than negative. 

Indirect negative impacts from manual control could be attributed to soil disturbance and 

opening of the canopy (understory, shrub layer or overstory depending on the species). This 

could cause shifts in microsite condition such as reduction in soil moisture, disruption of 

mychorrhizal associations and cause an increase in surface temperatures. All of these indirect 

effects could lead to a shift in species composition away from the native community upon 

which listed plants depend. One possible scenario is that the removal of one invasive plant 

species would encourage another invasive to take its place through various means of 

introduction (e.g. windblown seeds, human transport, breaking dormancy of other species 

seeds). It is likely that these impacts would occur at a small scale (less than 1 acre patches or 

scattered in small patches across an area) and follow-up monitoring of the treated sites and 

additional treatments or restoration methodologies would likely reduce negative impacts. 

Positive benefits from the removal of the invasive plants overshadow the indirect negative 

impacts. Non-target vegetation, including botanical SOLI populations would be affected 

positively by providing the space for increased growth in population size. One possible 

scenario is that removal of invasive plants will encourage native seed dormant in the soil to 

germinate due to less competitive conditions. 

Dremann and Shaw (2002) documented the success of converting live oak woodland from 99 

percent exotic species cover to 85 percent native plant cover through a strategy of timed 

manual/mechanical removal that released the native seed bank. No reseeding was necessary 

Bio-control Effects on Non-target Plants, Native Plant Communities and SOLI 

The analyses for effects of biocontrol agents have already been completed under documents 

developed by Agricultural Plant Health and Insect Service (APHIS) for approval of entry of 

such organisms and are hereby incorporated by reference. 

The effects of biological agents are described in Appendix J of the R6 2005 FEIS, and direct, 

indirect and cumulative effects are negligible (e.g. unlikely to result in adverse effects to 

aquatic species (page J-24), no direct effects on wildlife (page J-19), few examples of nontarget effects (page J-16). 

Cultural Treatment Effects on Native Plant Communities 

Cultural methods of invasive plant management focus on enhancing desirable vegetation to 

minimize invasion. Common cultural treatments include planting or seeding desirable species 

to shade or out-compete invasive plants, applying fertilizer to desirable vegetation, and 

mulching. Soluble nitrogen fertilizer applied after herbicide treatment could increase the 

competitiveness of perennial grasses and beneficial forbs. This method is most effective in 

pastures or rangelands where nitrogen levels are not high enough for optimum grass 

performance (Rinella and Sheley 2002). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Undocumented future sites may also be appropriate for the use of fertilizer/soil amendments 

and competitive planting as a method of controlling invasive weeds. Some minor impacts to 

community diversity may occur from the establishment of native species that thrive in the 

modified conditions as established by the addition of soil amendments or seeding in the short 

term. No long-term impacts are expected because passive restoration techniques are designed 

to promote the establishment of desirable plant communities (USDA 2005). 

Effects by Alternative 

 Alternative A – No Action 

Native Vegetation 

Current acres approved for herbicide use would remain the same placing heavy reliance on 

manual treatments for currently identified sites and all future sites. The removal of invasive 

plants using manual techniques could directly affect native plant and plant communities. 

Direct negative effects would be unintentional removal or trampling of flowers, fruits, or root 

systems of non-target native plants, but should be minimized with properly trained crews. 

Vigor could be reduced in individuals due to repeated treatments, however, impacts would be 

short lived, not likely to last a completed growing season. 

The removal of invasive plants using manual techniques within an area could directly affect 

remaining native plant community by creating soil disturbance, and opening the canopy 

(undersotry, shrub layer or over story depending on the species), creating areas for new or 

existing invasive plants to re-establish. For instance, hand-pulling trials conducted on spotted 

knapweed in western Montana and on diffuse knapweeds in west-central Montana resulted in 

an increase in bare ground from 2.7 percent to 13.7 percent during the first year after 

treatment (Brown et al. 2001). These hand-pulling trials as were shown to reduce the 

potential for knapweed seed production by exhibiting 100 percent flower control and 56 

percent plant control (Brown et al. 2001), however, follow-up investigation on resultant 

vegetation after treatment from resident seedbanks after treatment were not reported. The 

potential for re-establishment of invasive weeds can be high after ground disturbing activity 

or a significant reduction of plant cover, especially if other invasive plant species are nearby 

or the resident seed bank contains a high proportion of invasive weed seeds. Additionally, at 

these sites, changes could occur such as reduction in soil moisture, increases in soil 

temperatures and disruptions of mycorrhizal connections. 

No impacts are anticipated from the use of biocontrol agents as a method of invasive plant 

control (See Chapter 3.2.4, and Appendix B). Herbicide use under this alternative would 

likely cause mortality to some, non-target native plants. Only three herbicides are available 

under the No Action Alternative for use on 23 percent of the currently mapped invasive plant 

species acres (0.23% of the forest landbase). Only 18 invasive plant species of the 40 

currently identified on the forest could be treated using the three herbicides presently 

approved under the no action alternative. 

Of these 18 species, six species would not be treated with the most effective herbicide 

available for use and would likely require repeated applications of a less effective herbicide to 

gain site objectives of control contain or eradicate. For example, under the No Action 

Alternative the more effective herbicides for the treatment of whitetop (clorsulfuron, 

imazapic or metsulfuron methyl) would not be available and the only choice for herbicide 

treatment would be glyphosate. Glyphosate is a broad spectrum, non-selective herbicide with 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

high potential to kill all contacted vegetation, whereas the more effective herbicides available 

are more selective with less potential to impact non-target vegetation. 

The herbicides available for use under the No Action Alternative are less effective (See 

Common Control Measures Chapter 2). The following table compares proposed treatment 

acres by species for all alternatives. Species shaded in the No Action Alternative indicate 

species not treated with the most effective herbicides based on recommendations from local 

experts. 

Table 24-Invasive plant species treatment acres comparison between the No Action Alternative, 

Proposed Action Alternative, and additional action alternatives 

No Action 

Alternative 

Alternatives B, C 

Species and D 

Acres 

Russian knapweed 20.9 26.3 

Slender Meadow Foxtail** 73.2 0.3 

Whitetop 454.9 1489.3 

Musk thistle 18.7 27.2 

Diffuse knapweed 1637.1 4150.2 

Spotted knapweed 11.8 906.7 

Knapweed species 40.3 118.7 

Yellow star thistle 64.8 1966.1 

Rush skeletonweed 318.9 390.4 

Canada thistle 1376.3 3395.0 

Leafy spurge 15.5 102.1 

St. John’s wort 86.2 543.8 

Dalmation toadflax 349.1 728.3 

Purple loosestrife 2.4 2.5 

Scotch thistle 955.2 1844.2 

Tansy ragwort 4.7 78.2 

Medusa head 25.9 920.7 

Puncture vine** 43.5 12.3 

Common bugloss 0.0 5812.9 

Squarrose knapweed 0.0 6.6 

Bull thistle 0.0 22.2 

Field bindweed 0.0 3.3 

Poison hemlock 0.0 7.1 

Common crupina 0.0 284.2 

Dodder 0.0 9.6 

Hounds tongue 0.0 979.1 

Scotch broom 0.0 115.1 

Teasel 0.0 30.1 

Yellow hawkweed 0.0 16.2 

Pepperweed 0.0 0.7 

Toadflax sp. 0.0 3.8 

Yellow toadflax 0.0 50.6 

Japanese knotweed 0.0 77.5 

Sulphur cinquefoil 0.0 187.0 

Himalayan blackberry 0.0 15.2 

Clary sage 0.0 21.9 

Russian thistle 0.0 9.7 

Senecio sp. 0.0 8.4 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

No Action Alternatives B, C 

Species Alternative and D 

Acres 

Silverleaf nightshade 0.0 10.9 

Total Acres* 5,499.4 24,434.3 

* Multiple species may occur within on the same site; therefore total acreages are slightly inflated above total on the 

ground infested acres. **Species effectively treated under the no action alternative. 

SOLI 

Direct and indirect impacts to SOLI from treating invasives with manual techniques would be 

similar to those discussed above in the native vegetation section. Impacts to SOLI could be 

unintentional removal or trampling of flowers, fruits, or root systems of non-target native 

plants, but should be minimized with properly trained crews. Vigor could be reduced in 

individuals due to repeated treatments/trampling, however, impacts would be short lived, not 

likely to last a completed growing season. Additionally, removal of invasive plants using 

manual techniques within an area could directly affect remaining native plant community by 

creating soil disturbance, and opening the canopy (understory, shrub layer or over story 

depending on the species), creating areas for new or existing invasive plants to re-establish. 

Herbicides can be used in addition to manual methods to treat invasive plant near 11 SOLI 

species (on 27 individual locations) (Table 25); therefore, this effect is likely to be minimized. 

However, on the remaining 11 SOLI (on 53 individual locations), treating invasives with 

manual methods of treatment in addition to bio-control agent availability nearby are the only 

option available. 

No impacts are anticipated form the use of biocontrol agents as a method of invasive plant 

control (see Bio-control Effects on Non-target Plants, Native Plant Communities and SOLI) 

Treating invasives with herbicide under this alternative could cause mortality to some SOLI 

from accidental spray. Less effective herbicides with little or no selectivity for target invasive 

plants could be used. In comparison to Alternatives B, C and D fewer impacts would occur 

from herbicide treatment because fewer acres of invasive sites near SOLI would be treated. 

In general, fewer impacts from herbicide treatments are expected with this alternative in 

comparison with Alternatives B, C, and D, however, invasive plants encroachment and 

impacts to habitat are expected to increase as time progresses. 

Table 25-Number of SOLI within 100 feet of an invasive plant species site and proposed 

treatment by alternative 

Alt A 

No Action Alt 

Alt B 

Proposed Action 

Alt C 

Restricted Riparian 

Alt D 

No Aerial 

Herbicide 

Application 

# of SOLI 

(and 

individual 

locations) 

within 100’ 

of Invasive 

plant 

species 

11 sp 

27 locations 

22 sp 

80 locations Same as B Same as B 

Invasive Upland Upland Upland Same as B 

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133 

Alt A 

No Action Alt 

Alt B 

Proposed Action 

Alt C 

Restricted Riparian 

Alt D 

No Aerial 

Herbicide 

Application 

plant 

species 

proposed 

treatment 

Chemical = 10 sp, 

(20 locations) 

RHCAs1

Chem spot only 7 

sp ( 11 locations) 

Aerial

None 

Chemical = 15 sp (50 loc) 

Bio-control = 2 sp (2 loc) 

Manual = 1 sp (1 loc) 

RHCAs1

Chemical (bcast and/or 

spot) = 17 sp (44 loc) 

Biocontrol =1 sp. (6 loc) 

Manual = 1 sp. (1 loc) 

Aerial

None 

Chemical = 15 sp (50 loc) 

Bio-control = 2 sp (2 loc) 

Manual = 1 sp (1 loc) 

RHCAs1

Chemical (Spot Only) = 

17 sp (44 loc) 

Biocontrol =1 sp, (6 loc) 

Manual = 1 sp, (1 loc) 

Aerial

None 

1 Riparian Habitat Conservation Areas 

Determination Statement for All SOLI: Implementation of the No Action Alternative 

would not significantly impact SOLI in the near future from invasive plant treatments; 

however, long-term effects are likely. Long-term effects to SOLI and their habitats will result 

from lower effectiveness of invasive plant treatments and continued spread into SOLI 

habitats. Each individual SOLI occurrence is evaluated for effects based on treatment and can 

be found in Appendix B. 

Impacts to Fungi, Lichens and Bryophytes 

Unknown effects from herbicide treatments are possible. Most of the nonvascular SOLI and 

other native fungi, lichen and bryophytes do not commonly occur in the disturbed areas often 

associated with invasive species. In Alternative A, less impact from herbicide would be 

possible because fewer acres would be approved for treatment. 

However, it is likely that if invasive species continue to spread across the forest as predicted 

with this alternative, habitats for these species would likely be more negatively impacted 

compared to the treatments proposed in Alternatives B, C and D. 

Impacts to pollinators 

Some impacts to pollinators may occur with the use of glyphosate if applied at the maximum 

application rate proposed by the Forest Service (SERA, 2003). Less than 0.02% of the Forest 

would be treated with herbicides annually; therefore, it is assumed that the remaining areas on 

the Forest would adequately supply areas where native plant pollinators could recover if 

impacted from herbicide treatments. 

Alternative B – Proposed Action 

Native Vegetation 

Impacts from manual and mechanical treatments would be similar to those as described in 

Alternative A. The removal of invasive plants using manual or mechanical techniques could 

directly affect native plants and plant communities. Direct negative effects would be 

unintentional removal, mowing or trampling of flowers, fruits, or root systems of native 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

plants, but should be minimal with properly trained crews. Removal, mowing or trampling of 

non-target plants could reduce native seed production, create soil disturbance, and open the 

canopy (understory, shrub layer or overstory depending on the species). However, under this 

alternative, manual and mechanical methods would typically follow herbicide or be used in 

conjunction with herbicide treatments and seldom used as a primary control method. 

Undocumented future sites may be appropriate for foaming or solorization/mulching 

techniques for invasive plant control. Such sites would be very small patches because both of 

these types of treatments are very expensive (TNC 2006). Impacts to non-target vegetation 

would be limited to the small area of treatment. Both of these treatments use heat (plastic 

mulch in solarization and steam combined with biodegradable sugar producing foam) as a 

method to kill target invasive plants and therefore kill all plants in the treated area. Such 

treatments would likely be used where there are special resource concerns or where other 

methods are ineffective. These sites would likely have higher levels of prioritization and 

monitoring and likely receive immediate revegetation and restoration methodologies. Only 

short term effects in very limited areas are expected with these treatments. 

EDRR sites may also be appropriate for the use of fertilizer/soil amendments and competitive 

planting as a cultural treatment method for controlling invasive weeds. Some minor impacts 

to community diversity may occur from the establishment of native species that thrive in the 

modified conditions as established by the addition of soil amendments or seeding in the short 

term. No long-term impacts are expected because passive restoration techniques are designed 

to promote the establishment of desirable plant communities (R6 2005 FEIS). 

Approximately 0.9 percent of the 2.3 million acres of the Wallowa-Whitman-National Forest 

are proposed for herbicide treatments in Alternative B. Maximum annual herbicide 

treatments could treat about 0.32 percent of the Forest area or approximately 8,000 acres 

annually. Over time it is expected that herbicide use would be reduced as known sites are 

effectively controlled and EDRR methodologies eradicate new invasive sites. 

This alternative has the greater potential to impact non-target plants than Alternative A. 

Because Alternative B proposed use of broadcast herbicide spraying in riparian areas it would 

likely have more negative effects to non-target riparian vegetation than Alternative C. 

Because Alternative B proposed aerial application of herbicides, it would likely have more 

negative effects on non-target plants due to chemical drift than Alternative D. The effects are 

considered short term and minor because the Regional prevention and restoration standards in 

the Forest Plan as amended by the R6 2005 ROD, the common control measures, and the 

additional protection of project design features (PDFs) are considered adequate to protect 

native plant populations. 

This alternative allows the use of several new herbicides, some of which are associated with 

hazards to non-target vegetation (R6 2005 FEIS 4-27-4-33). Alternatively, some herbicides 

allowed in the action alternatives are more specific to certain plant families which would 

reduce impacts to native vegetation in comparison to the three herbicides available in the no 

Action Alternative. In turn, the reduced impacts to non-target species would aid the recovery 

of affected native plant communities. For instance Alternative A only allows use of picloram 

and glyphosate. However, metsulfuron methyl and chlosulfuron are recommend for treating 

houndstongue compared to other herbicides, clopyralid and chlorsulfuron controls tansy 

ragwort more effectively than picloram and glyphosate, and imazapic and sulfometuron 

methyl/chlorsulfuron, sulfumetruon methyl and sethoxydim controls medusa head more 

effectively than glyphosate. Infestations of houndstongue, tansy ragwort and medusa head are 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

979; 78, and 921 acres respectively. Being more effective means reducing the number of 

applications and volume of herbicide required compared to Alternative A. Risks to non-target 

vegetation are further reduced by careful implementation of PDFs and common control 

measure notes and supplemental information provided by local experts. Although some shortterm negative effects to native vegetation likely will occur, this alternative would be more 

effective at accomplishing the projects purpose and need of containing, controlling and 

eradicating invasive plant infestations. Long term, Alternative B would likely be more 

effective at allowing native vegetation and plant communities to recover compared to 

Alternative A. 

In summary, there would likely be more risk from herbicide impacts to non-target native 

vegetation because more acres and sites would be treated compared to Alternative A. The 

annual forest-wide risk to non-target effects from herbicide use between the No Action and 

the Proposed Action is less than 0.008 percent and 0.3 percent of the Forest acres 

respectively. Although more acres may be impacted by Alternative B, in the long-term native 

plant community health will improve because existing and potential future invasive plant 

sites will be more effectively treated. 

Proposed Aerial Applications 

Invasive sites currently proposed for herbicide treatments using aerial application methods 

consist of approximately 875 acres. Additionally, invasive plants within these proposed areas 

exist in small patches across the landscape, and aerial treatments within those areas would be 

applied where sufficient invasive weed cover would warrant the need for a broadcast 

application. The use or non-use of picloram to control target invasive species and subsequent 

potential impacts to conifers should be considered (PDF F-8o). Herbicides analyzed in this 

EIS would not exceed typical application rates. 

Picloram would be applied at a less than typical application rate (0.25lb/ai/acre, PDF F-8o 

and clopyralid would not exceed typical application rates (0.35lb ai/acre) discussed in 

Chapter 2, and all buffer widths described in the PDFs would limit the drift to levels below 

quantities known to have adverse effects. Table 26 describes the areas where aerial 

application methods are currently proposed (See Figure 9 and Appendix B aerial site maps). 

For a complete description and acres of proposed aerial treatment sites, see Appendix F. 

Aerial drift modeling (AGDISP 2003) was used to develop PDF buffers to protect resources 

and predict impacts. Picloram (0.25lbs ai/acre) and clopyralid (0.35lbs ai/acre) are proposed 

for use in aerial applications to yellow star thistle and scotch thistle. Future EDRR sites will 

not use aerial as a method of application. 

Clopyralid is an extremely selective post emergent herbicide for broadleaved invasive 

species. The target families for this herbicide are Asteraceae, Fabaceae, and Solanaceae. 

Grasses are tolerant of clopyralid and conifers are not impacted. With the use of this 

herbicide, there would likely be direct negative effects to native species in target families in 

the area of application. Picloram is also a selective herbicide for the Asteraceae, Fabaceae, 

Apiaceae and Polygonaceae families with some potential affect to the Brassicaceae, 

Liliaceae, and Scrophulariaceae families. Picloram has a higher potential for run off and 

leaching (high mobility in sandy soils with low organic matter). There are additional PDFs 

that limit the use of Picloram near sensitive areas listed in Chapter 2 of this EIS. Picloram 

also has the potential to impact conifers. In areas where aerial treatments are proposed and 

small conifers are also present, such as along edges of meadows, long-term site objectives 

that are in agreement with forest management guidelines would be developed. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Table 26-Existing Vegetation Types In Proposed Aerial Treatment Sites 

Acres1 of Existing Vegetation Types Infested with Invasive plant species 

LaGrande District 

Yellow Star thistle 

Grasslands 160 

Dry Meadow with water table part of the season 31 

Forested areas including: Douglas Fir/NineBark and/or ocean spray-Grand 

Fir/Huckleberry and/or elk sedge 75 

Hells Canyon Natural Recreation Area 

Yellow Star thistle 

Grasslands 625 

Shrublands 10 

Forested areas including: Douglas fir 14 

Rocky areas 9 

Scotch Thistle 

Grasslands 23 

Shrublands 8 

Forest (hardwoods) 2 

1 Acres presented here are gross acres infested. Patches of invasive plants are dispersed within these acreages 

and it is likely that only relatively small portions of these acreages would be treated aerially. For analysis purposes, 

however, total acres were analyzed to address ‘worst-case’ scenarios. 

Site Description Summary 

Yellow star thistle and scotch thistle sites occur 

primarily in grassland, meadow or shrub land 

vegetation types (88% of mapped acres). The sites 

are located adjacent to private lands and/or found 

in remote locations within Hells Canyon Natural 

Recreation Area (Figure 18). All proposed aerial 

sites are highly inaccessible limiting the potential 

for ground based treatments. 

Figure 18 – Proposed Aerial site otherwise 

inaccessible

Picloram (0.25lb ai/acre) or clopyralid (0.35lb ai/acre) are proposed for treatment of these 

sites and would provide effective control of these two species on these sites. 

Bio-control agents are available for yellow star thistle; however, accessibility to these sites 

for release can be extremely difficult and may not prove to be the most effective method of 

treatment. 

If Alternative D (no aerial treatment) is chosen, biocontrol treatments will be implemented to 

the best extent possible on yellow star sites. 

SOLI 

Direct and indirect impacts to SOLI from manual techniques would be similar to those 

discussed above in the native vegetation section and in the No Action Alternative. Impacts to 

SOLI could be unintentional removal or trampling of flowers, fruits, or root systems of nontarget native plants, but should be minimized with properly trained crews. Vigor could be 

reduced in individuals due to repeated treatments/trampling, however, impacts would be short 

lived, and not likely to last a complete growing season. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Invasive plant sites proposed for herbicide treatments within 100 feet of botanical SOLI are 

identified in Table 25. Compared to Alternative A, the Proposed Action is associated with 

greater potential for herbicide drift, and more invasive sites would be treated near SOLI sites. 

The increased potential for exposure is mitigated by the PDFs that provide protection buffers 

and other limitations on herbicide use near botanical SOLI. 

Alternative B proposes invasive plants treatment adjacent to 22 SOLI species (80 locations). 

This would protect SOLI and their habitats more effectively than in Alternative A 

Impacts to Fungi, Lichens and Bryophytes 

Impacts of invasive species to fungi, lichens, and bryophytes, are not widely documented in 

the literature. Most of the nonvascular SOLI and other native fungi, lichen and bryophytes do 

not commonly occur in the disturbed areas often associated with invasive species. 

Bryophytes and lichens receive their mineral nutrition and water from precipitation, splash 

water, or directly from the atmosphere; therefore, it is possible that the SOLI listed in 

Appendix B as well as other native fungi, lichen, and bryophytes could be impacted by 

herbicide drift. There is a potential for more impacts from herbicides with Alternative B as 

compared to Alternative A because more acres of herbicide are proposed for treatment in 

addition to future EDRR treatments. Implementation of PDFs that outline effectiveness 

monitoring will provide additional impact information as well as adjustment of buffers to 

protect these species if negative impacts are observed. Short term impacts could be expected; 

however, long-term positive effects to habitats are expected because effective treatment of 

existing and future invasive plants would restore, protect and maintain habitats these species 

require. 

Impacts to pollinators 

Some additional impacts to pollinators from herbicide treatments could occur over and above 

those listed for Alternative A with the addition of triclopyr as a new herbicide. Risk 

assessments indicate that glyphosate may have some toxic effects if applied at the maximum 

application rate proposed by the Forest Service (SERA, 2003-glyphosate). Some shifts in 

native pollinators due to herbicide treatments may occur at some invasive plant sites that are 

more than five acres (35 % of sites), highly infested and proposed for broadcast treatment. 

The level of infestation on these larger sites is unknown. Sites could have a few invasive 

plants scattered across an area or be heavily infested. In the worst case scenario if all 35 

percent of the sites were heavily infested and broadcast sprayed, only 0.003 percent of the 

forest area where native plant pollinators occur would be impacted. Treatments proposed and 

standards approved in the R6 2005 ROD are estimated to be 80 percent effective. Impacts to 

specific sites would be short term and the ability of native pollinators to migrate into 

potentially impacted area from other nearby areas is highly probable. 

Little to no effect to pollinators is expected from manual or mechanical treatments in the long 

term. Some short-term (year of treatment) effects could occur due to the reduction of flower 

heads used as food sources for pollinators. 

Alternative C – Restricted Riparian 

This alternative is very similar to Alternative B except broadcast methods (hand broadcast 

and boom mounted sprayers on vehicles) would not be allowed in RHCAs. This alternative 

addresses concerns about the risk of herbicide delivery to water and potential impacts to fish. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Based on GIS mapping and stream buffers, an estimated 3,104 acres could not be treated 

using broadcast methods of application. 

Native Vegetation 

Direct and indirect effects to native vegetation would be very similar to those discussed in 

Alternative B. Broadcast herbicide application would not occur in the RHCAs. Spot treating 

individual invasive plants would be less effective and more costly than broadcast treatments 

especially where individuals are dispersed over a large area. Repeated treatments (within the 

same growing season or annually) for some invasive plants within the same site are probable 

to effectively treat emerging invasive plant seedlings arising from a resident seedbank. 

Invasive plants 

that span the 

designated RHCA 

buffers (that 

delineate where 

spot and 

broadcast 

treatments are 

approved) could 

likely provide 

sources for reinfestation if 

diligent spot 

treatments are not 

possible. Figure 

19 depicts where 

less effective spot 

treatments would 

be used and where 

more effective 

broadcast 

methods could be 

used. 

Figure 19 – Example of spot treatment areas within RHCA, and broadcast treatment areas for 

diffuse knapweed on the Wallowa-Whitman National Forest. 

SOLI 

Direct and indirect impacts to SOLI from manual techniques would be similar to those 

discussed above in the native vegetation section and in the No Action Alternative. Impacts to 

SOLI could be unintentional removal or trampling of flowers, fruits, or root systems of nontarget native plants, but should be minimized with properly trained crews. Vigor could be 

reduced in individuals due to repeated treatments/trampling, however, impacts would be short 

lived, not likely to last a complete growing season. 

Direct and indirect effects from treating invasive plants with herbicides near SOLI sites 

would generally be the same as those listed for Alternative B. Approximately 44 treatment 

sites (17 species) within RHCAs would not be broadcast under Alternative C. SOLI present 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

within these areas would not be susceptible to any inadvertent accidental herbicide drift that 

could be associated with broadcast treatment methods. However, the increased cost or loss of 

effectiveness from this limitation could reduce the acreage effectively treated in RHCAs, 

resulting in continued threats to riparian habitat and SOLI in these areas. 

Determination Statement for All SOLI: Implementation of Alternative C “may affect 

individuals or habitat, but will not likely contribute to a trend towards federal listing or 

loss of viability to the population or species” of all sensitive plant species analyzed in this 

document. Each individual SOLI occurrence is evaluated based on treatment proposed for 

each individual site and can be found in Appendix B. 

Impacts to Fungi, Lichens and Bryophytes 

As previously discussed impacts of invasive species to lichens, bryophytes, and fungi is not 

widely documented in the literature. Potential herbicide treatment impacts from this 

alternative would be similar to those discussed in Alternative B; however, the degree of 

impact would be lessened in the riparian areas where herbicide drift is reduced because of 

restrictions on broadcast applications. 

Impacts to pollinators 

Impacts to pollinators would be similar to those discussed in Alternative B. There would be 

an additional reduction of potential impacts due to no broadcast treatments of herbicides 

allowed in 3,104 acres within RHCAs. As previously discussed, because little is known in 

relation to native pollinators and their associated plant associations and habitats, it is not 

possible to quantitatively measure this impact. 

Alternative D – No Aerial Herbicide Application 

This alternative is very similar to Alternative B, except it does not allow aerial herbicide 

application on known sites. This alternative addresses concerns about the risk of herbicide 

drift, impacts to non-target plants, herbicide delivery to water and potential impacts to fish. 

All but 33 acres could be treated with other application methods (with less cost-effectiveness 

than aerial).. Bio-control agents could be used for yellow star thistle; although, in the past 

previous biocontrol treatments have not been successful due to frequent fire events in the area 

(Dawson 2007), and are predicted to be less effective and/or more costly than those proposed 

in Alternative B. 

Native Vegetation 

Effects would be the same as Alternative B, except that the acreage proposed for aerial 

application of herbicide would be sprayed using ground based methods (842 acres) or not 

treated with herbicide (33 acres). Efects from drift associated with aerial application would 

be elimated. Because aerial sites are often associated with limited access and higher treatment 

costs, the potential for invasive weeds to continue to spread in this remote area would be 

similar to Alterantive A. Over time, impacts to native vegetation are probable. 

SOLI 

Effects would be the same as those described in Alternative B. There are presently no nonfederally listed species that are within 300 feet, or any federally listed species within 1000 

feet of a proposed aerial treatment site. 

Determination Statement for All SOLI: Implementation of Alternative D “may affect 

individuals or habitat, but will not likely contribute to a trend towards federal listing or 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

loss of viability to the population or species” of all sensitive plant species analyzed in this 

document. Each individual SOLI occurrence is evaluated based on treatment proposed for 

each individual site and can be found in Appendix B. 

Impacts to Fungi, Lichens and Bryophytes 

As previously discussed impacts of invasive species to lichens, bryophytes, and fungi is not 

widely documented in the literature. Potential herbicide treatment impacts from this 

alternative would be similar to those discussed in Alternative B, however, the degree of 

impact would be lessened in the areas proposed for aerial application because some aerial 

locations are not accessible either due to location or safety and no herbicide would be applied 

in these areas. 

Impacts to pollinators 

Impacts to pollinators would be similar to those discussed in Alternative B. However, there 

would be less impact to pollinators because the potential for herbicide contact to pollinators 

from drift during aerial broadcast treatment would be eliminated. 

Cumulative Effects by Alternative 

Past, present and foreseeable future actions have and will continue to contribute to 

establishment of invasive weeds. The following bulleted list summarize many of the activities 

associated with invasive plant establishment and spread on forest lands and adjacent 

ownerships 

• Past invasive plant management 

• Recreational forest use 

• Other ground disturbing activities such as construction or maintenance of recreation 

sites 

• Road use 

• Fires and associated management activities 

• Logging and thinning activities 

• Agricultural crop production adjacent to forest boundaries 

• Grazing and dispersal of propagules by animals 

• Climatic events such as wind and drought are all documented to contribute to the 

spread of invasive plants 

• Wildlife dissemination of invasive plant seeds 

Present and reasonably foreseeable future actions will continue to provide opportunities for 

invasive plant species to establish. Roads will continue to be a major conduit for invasive 

plants. Forest Service projections suggest that recreation uses of National Forests will 

continue to increase. 

Other land management activities such as grazing, vegetation management, fuels 

management (Healthy Forest Initiative), wildland fire, and fire suppression will continue to 

cause ground disturbances that can contribute to the introduction, spread and establishment of 

invasive plants on National Forest System lands (USDA, 2005). 

Many of these same natural events, uses, and activities have happened, and will continue to 

happen on lands adjacent to, or in the vicinity of, the Wallowa-Whitman National Forest 

System lands. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

In addition to these above stated activities, the Wallowa-Whitman proposes a new travel 

management plan (Federal Register, Volume 72, No. 85). In this environmental impact 

statement the forest proposes to designate a portion of the National Forest roads, trails, and 

areas, open to public motor vehicle use on the Wallowa-Whitman National Forest (WWNF), 

and assign the type of use(s) and season of use allowed on each road and trail or portion 

thereof. Roads, trails and areas not selected for designation will be closed to public motor 

vehicles year round (excepting the use of over-snow vehicles). Additionally, the WallowaWhitman National Forest currently has 1,337,760 acres open to motorized cross country 

travel. These acres will be closed year round to motorized cross country travel, excluding 

over-snow vehicles. With the closure of many of these previously impacted areas infested 

with invasive plants, it is expected that over time these areas will recover and will not require 

continued treatment associated with repeated disturbance. 

Cooperation with local partners such as other federal and state land management agencies, 

local service district, tribal governments, non-profit organization cooperative weed 

management areas and interested citizens will continue. For instance, Wallowa County has an 

integrated weed management plan that comprehensively prioritizes noxious weeds based on 

morphological characteristics as well as bio-physical and topographical attributes of where 

these weeds occur. Their plan identifies management zones and a prioritization process 

providing a baseline for decision making by land managers in the area. Their approach 

combines chemical, mechanical, and cultural and biological control methods in a strategic 

fashion to minimize inputs and maximize weed control (see http://www.co.wallowa.or.us for 

more information). Other cooperating entities include Tri-county and Tri-State Weed 

Management areas, the Lower Grand Ronde Noxious Weed Program, and the Nez Perce 

Tribe. 

Cumulative Effects 

Alternative A - No Action 

The 1992 and 1995 EA/DN found that the currently approved treatments under the No Action 

Alternative would have no significant impact on non-target vegetation, including SOLI. 

However, based on the past effectiveness of treatments, combined with past natural events, 

forest uses and management activities, negative cumulative impacts are evident because 

invasive plant species continue to spread. No change in this trend would be expected in the 

foreseeable future. Therefore, continued adverse impacts from the continued spread of 

invasive species are expected under this alternative to native vegetation, including SOLI and 

their associated habitats. 

Herbicide treatments of invasive plants on lands near or adjacent o the Wallowa-Whitman 

National Forest is common for agricultural crop production, range improvement, landscape 

improvement and other reasons. Future spread of invasive species on National Forest System 

lands in the No Action alternative increases the likelihood of weeds spreading to private, 

tribal, state and other ownerships. This may increase the use of herbicides and the challenge 

of controlling, eradicating, or containing weeds on other land ownerships. 

The same is true of invasive plant management on ownerships outside the National Forest. If 

other land owners and managers do not control weeds on their lands, the challenge of 

controlling weeds increases for Wallowa-Whitman National Forest managers. 

Potential effects of herbicide treatment to non-target vegetation, including SOLI, on National 

Forest System land is relatively small as reported in the direct/indirect section above. The 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

cumulative effects of herbicide treatments on all land ownerships in and near the WallowaWhitman National Forest are somewhat unknown. 

Uncertainty exists because a comprehensive reporting system of treatment activities across all 

land ownerships does not exist. County weed boards report treatment accomplishments from 

cooperators that participate with their program; however, other treatments of unknown extent 

using unknown chemicals most likely exist. For known treatments, herbicide treatment likely 

impacts individual non-target plants sprayed. While PDFs add a measure of protection for 

SOLI on National Forest system lands, SOLI may be more vulnerable on other ownerships 

where protective measures are unknown. Overall, potential impacts are considered minor and 

short term because the great majority of area treated is known, and chemicals used, 

application rates and methods are believed to follow labeled requirements. The overall 

positive effect of killing target invasive infestations wherever they exist is a far greater, long 

term benefit to non-target plant communities, including SOLI, than the temporary damage 

that may occur to individual non-target plants. 

There is likely some damage to individual non-target plants from manual and mechanical 

treatments; although, the cumulative impacts from these treatments are considered negligible. 

The temporary and incidental effects are also considered minor because affected plants would 

likely sprout again. The benefit of invasive plant removal or reduced seed production due to 

treatment is considered a greater benefit to non-target plants than the minor damage that 

could occur to non-target individuals. While crews treating weeds on National Forest system 

lands would be trained to identify and avoid damage to SOLI, the effect on SOLI of 

manual/mechanical treatments could vary on other ownerships. 

The cumulative effects analysis assumes that the release of biological control agents on 

National Forest system lands and adjacent lands by the Oregon Department of Agriculture, as 

analyzed by Animal Plant Health Inspection Service (APHIS), will continue to reduce the 

invasive plant infestations and decrease the spread of invasive plants. It is recognized that 

biocontrol agents will likely cross land ownership boundaries. Though biocontrol agents 

could occasionally affect non-target plants, that would be considered rare and minor 

compared to the benefits of reducing the area and spread of weeds. 

In summary, while some herbicide treatments in the vicinity of the National Forest are 

unknown, most treatments are known. Overall the known potential negative effects of past, 

present and foreseeable future treatments are considered minor and short term, especially 

compared to the benefits of reducing the negative influence invasive plants have on nontarget plant communities. 

The cumulative effects of Alternative A combined with the past, present and foreseeable 

future actions listed above will likely continue the present trends on native plant 

communities. Namely: 

• Some reduction of invasive plant infestations where authorized treatments on the 

Wallowa-Whitman National Forest and other lands have occurred and would 

probably occur in the future 

• Some minor, short-term loss of native plants due to treatment of invasive plants now 

and throughout the life of this project 

• Efforts to control, contain or eradicate invasive plants in concert with other 

cooperating entities would be reduced in places where more effective treatments are 

allowable 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

• Continued growth in the number of invasive plant species and the acres infested on 

the Wallowa-Whitman National Forest and adjacent lands due to the natural and mancaused activities (listed above) that can favor invasive plants 

The effect of weather and climate can have a profound impact positively or negatively on 

invasive plants even though local conditions happen to all plant communities equally. For 

example, a drought, though causing stress to many plant species, tends to favor the spread of 

weeds because, in general, they tend to tolerate drought better than native species. Also 

natural events such as wildland fires effect invasive plant infestations and native plant 

communities. 

Alternative B - Proposed Action 

The effectiveness of the proposed invasive plants treatment project would be increased if 

there is coordination with adjacent landowners to treat invasive plants infestations across land 

ownerships. The cumulative effects analysis assumes that this cooperative, coordinated effort 

continues for the life of this project. Alternative B would more effectively control invasive 

infestations on the Forest because more acres are proposed for treatment, and the more 

efficient and cost effective treatment methods are proposed. The likely result of this would be 

improved weed control effectiveness on adjacent land ownerships. That is because aggressive 

treatments are expected to reduce invasive infestations on the National Forest, so there would 

be less weed seed and invasive plants available to spread onto neighboring lands. As the 

future spread of invasive plants on National Forest System lands decreased, so the likelihood 

of weeds spreading onto private, tribal, state and other ownerships would also decrease. Over 

time, this could reduce herbicide use on National Forest and adjacent land ownerships. 

The land uses and management activities listed at the beginning of this cumulative effects 

section would continue on National Forest and other lands, and would partially compromise 

treatment effectiveness by spreading weeds. Because many of these activities spread weed 

seed, an effective treatment program requires vigilance to successfully accomplish and 

maintain desired future conditions goals over the long term. The EDRR component of this 

alternative allows for treatment of newly discovered, future infestations on Forest System 

lands. Other landowners may or may not have the flexibility, funds or resources to address 

new infestations whenever and wherever they are found. Because the extent of future 

treatment programs on other lands is unknown, the effect this will have on weeds migrating 

onto National Forest System lands is also unknown. The effects of natural events, weather 

and climate would be similar to that listed in Alternative A. 

The cumulative effects of Alternative B combined with past, present, and foreseeable future 

actions listed above are expected to have a mixed combination of effects on the native plant 

communities of the Wallowa-Whitman National Forest. These effects include temporary loss 

of non-target native and desirable non-native plants from damage and mortality caused by 

proposed invasive plant treatments. The damage on each treatment site would be similar to 

those described for Alternative A; however, Alternative B proposes to treat many more acres, 

and therefore, more non-target plant damage and mortality is possible, especially from 

chemical spraying. Because treatments would be a very small percentage of the Forest’s total 

area, and because the losses are likely to be temporary, they are considered acceptably minor. 

In the long-term, vegetation management will favor re-establishment of native plant 

communities across ownership boundaries, especially where coordinated treatments have 

occurred. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Presently, 22 invasive weed sites proposed for treatment on the forest (approximately 6,600 

acres) are adjacent to other land ownerships (Table 27). The largest reported associated area is 

the common bugloss site located on the Hells Canyon National Recreation Area. It is likely 

that more acres are present. These acres only represent a small scale cooperative weed 

mapping projects. See Appendix B for adjacent invasive plant species acres by district. 

Table 27-Invasive weeds located adjacent to National Forest System land 

Percent of Total Invasive plant species Adjacent Infested Acres Mapped acres 

Russian knapweed 23.3 0.4 

Common bugloss 5472.9 82.5 

White-top 51.3 0.8 

Diffuse knapweed 155.6 2.3 

Spotted knapweed 81.6 1.2 

Knapweed species 76.4 1.2 

Yellow star thistle 60.7 0.9 

Rush skeleton weed 5.0 0.1 

Canada thistle 131.6 2.0 

Poison hemlock 1.4 0.0 

Common crupina 188.6 2.8 

Houndstongue 76.8 1.2 

Scotch broom 0.1 0.0 

Leafy spurge 1.9 0.0 

Yellow hawkweed 0.0 0.0 

St john's wort 103.0 1.6 

Dalmation toadflax 107.3 1.6 

Yellow toadflax 0.3 0.0 

Scotch thistle 83.5 1.3 

Sulphur cinquefoil 6.5 0.1 

Tansy ragwort 2.3 0.0 

Medusahead 3.4 0.1 

Total 6633.6 100.0 

Drift associated with herbicide treatments between Forest and non-forest lands is possible. 

Potential effects of drift from Forest Service System lands would likely be minor and 

temporary due to PDFs developed to significantly reduce impacts of all herbicides proposed. 

Potential effects from herbicide drift originating from adjacent landowner application, may be 

slightly higher because adjacent land owners are not restricted to Forest Service standards, 

approved herbicides or PDFs. 

Overall, coordinated treatment of invasive plants with adjacent landowners (see PDF B-1 in 

section 2.2.3) is essential to effectively control weeds on both sides of the boundary. 

Coordination in treatment efforts with private and state owned lands for the common bugloss 

site which at this time is the largest reported acreage adjacent is presently underway (Dawson 

2007). 

Alternative C and D 

Alternatives C and D would predictably have very similar cumulative effects as Alternative 

B. It is acknowledged that invasive treatments are somewhat different among these three 

alternatives; however, those differences become miniscule when considered in the context of 

144
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

145 

all cumulative effect factors that have, can, and will influence invasive plant infestations and 

native plant communities. 

Determination statements for all SOLI are based on the implementation of all PDFs as listed 

in Chapter 2 of this EIS, and follow all standards outlined in the Wallowa-Whitman LRMP as 

amended by the R6 2005 ROD. Effects to SOLI are based on proximity and proposed 

treatments to known invasive species sites, other occurrences of SOLI on the Forest not 

presently impacted by invasive species, and overall risk to SOLI based on treatment 

effectiveness by alternative. Table 28 displays determination statements derived from effects 

analysis for SOLI identified to be at greatest risk from all alternatives. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen 

Table 28-SOLI determination statements by Alternative 

Determination statements 

from impacts from invasi

treatments in combinatio

treatment effectivene

Number of Total number 

SOLI Invasive 

species in 

or near 

SOLI sites 

(acres of 

each 

invasive 

species)2

of SOLI 

occurrences in Invasive occurrences 

or near species on the forest 

invasive sites within GENUS SPECIES 

(total acreage mapped of SOLI (acres of SOLI 

SOLI site 

occurrence occurrence 

Alt A Alt B Alt C 

mapped in or (acres) mapped on the 

near invasive 

forest) species sites)1

Achnatherum wallowaensis 23 (389) 2 (5) CEMA (3) CEDI (6) <1 MIIH MIIH MIIH 

Allium geyeri 1 (104) 1 (104) CEDI (11) 3 MIIH MIIH MIIH 

Arabis hastatula 26 (56) 2 (3) CEDI33 (86) <1 MIIH MIIH MIIH 

Botrychium crenulatum 12 (621) 1 (<1) HYPE (7) <1 MIIH MIIH MIIH Botrychium minganense 120 (1,125) 5 (164) 

HYPE 

(7) CIAR4 

(2) 

CEDI3 

(14) 

4 MIIH MIIH MIIH 

Botrychium montanum 56 (65) 6 (13) 

HYPE 

(7) 

CIAR4 

(39) 

<1 MIIH MIIH MIIH 

Botrychium pinnatum 66 (513) 4 (0.5) 

HYPE 

(7) 

SEJA 

(<1) 

1 MIIH MIIH MIIH 

Calochortus longebarbatus 30 (763) 5 (627) CEDI3 (138) CIAR4 16 MIIH MIIH MIIH 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Determination statements 

from impacts from invasi

treatments in combinatio

treatment effectivene

GENUS SPECIES 

Total number 

of SOLI 

occurrences 

on the forest 

(total acreage 

of SOLI 

occurrence 

mapped on the 

forest) 

Number of 

SOLI 

occurrences in 

or near 

invasive sites 

(acres of SOLI 

occurrence 

mapped in or 

near invasive 

species sites)1

Invasive 

species in 

or near 

SOLI sites 

(acres of 

each 

invasive 

species)2

Invasive 

species 

within 

mapped 

SOLI site 

(acres) Alt A Alt B Alt C 

(77) 

Calochortus macrocarpus 1 (9) 1 (9) CEDI3 (4) 1 MIIH MIIH MIIH 

Carex 12 (18) 2 (1) 

CEMA4 

(1) 

CADR <1 MIIH MIIH MIIH 

hystericina 

(1) 

Carex interior 16 (11) 2 (2) CIAR4 (37) <1 MIIH MIIH MIIH 

Erigeron engelmannii 47 (2,015) 12 (726) 

CEDI3 

(23) ONAC 

(49) 

CEMA4 

(2) 

CESO3 

(45) 

41 MIIH MIIH MIIH 

Leptodactylon pungens 6 (660) 2 (10) 

CEDI3 

(11) 

CESO3 

(1) 

1 MIIH MIIH MIIH 

Mimulus clivicola 52 (2,712) 13 (1,360) 

CYOF 

(30) 

CIAR4 

(767) 

HYPE 

(206) 

CEDI3 

53 MIIH MIIH NI MIIH NI 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen 

Determination statements 

from impacts from invasi

treatments in combinatio

treatment effectivene

GENUS SPECIES 

Total number 

of SOLI 

occurrences 

on the forest 

(total acreage 

of SOLI 

occurrence 

mapped on the 

forest) 

Number of 

SOLI 

occurrences in 

or near 

invasive sites 

(acres of SOLI 

occurrence 

mapped in or 

near invasive 

species sites)1

Invasive 

species in 

or near 

SOLI sites 

(acres of 

each 

invasive 

species)2

Invasive 

species 

within 

mapped 

SOLI site 

(acres) Alt A Alt B Alt C 

(1) 

Mirabilis macfarlanei 14 (77) 2 (6) 

CESO3 

(1) 

ONAC 

(254) 

<1 LAA LAA LAA 

Phacelia minutissima 13 (500) 1 (495) CIAR4 (3) 3 MIIH MIIH MIIH 

Phlox multiflora 65 (1188) 5 (718) 

CEDI3 

(66) 

CIAR4 

(77) 

68 MIIH MIIH MIIH 

Platanthera obtusata 5 (218) 1 (214) CEMA (<1) <1 MIIH MIIH MIIH 

Primula cusickiana 67 (5,018) 5 (1,828) 

CEMA4 

(1) 

CYSC4 

(115) 

HYPE 

(176) CIAR 

(677) 

LIVU 

(1) 

46 MIIH MIIH NI MIIH NI 

Rubus bartonianus 14 (2,386) 2 251) 

CESO3 

(1) 

LIDA 

(<1) 

3 MIIH MIIH MIIH 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Determination statements 

from impacts from invasi

treatments in combinatio

treatment effectivene

GENUS SPECIES 

Total number 

of SOLI 

occurrences 

on the forest 

(total acreage 

of SOLI 

occurrence 

mapped on the 

forest) 

Number of 

SOLI 

occurrences in 

or near 

invasive sites 

(acres of SOLI 

occurrence 

mapped in or 

near invasive 

species sites)1

Invasive 

species in 

or near 

SOLI sites 

(acres of 

each 

invasive 

species)2

Invasive 

species 

within 

mapped 

SOLI site 

(acres) Alt A Alt B Alt C 

ONAC 

(17) 

CEMA4 

(3) 

Trifolium douglasii 45 (324) 5 (16) 

PORE5 

(9) CIAR4 

(77) CEDI3 

(19) 

1 MIIH MIIH MIIH 

Trollius laxus 1 (1) 1 (1) CEDI3 (85) 0 MIIH MIIH MIIH 

1Acres represent SOLI habitat associated with occurrence 2Invasive species acres represent size of infestation identified in or near SOLI occurrence or mapped habitat. Multiple species may occur on the same sit3See Appendix B, Common control measures for invasive species codes and associated names 4MIIH = May Impact Individuals or Habitat, But Will Not Likely Contribute to a Trend Towards Federal Listing or Loss of Viability for the Population or Species. LAA = Likely to Adversely Affect
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

3.3 Terrestrial Wildlife 

3.3.1 Introduction 

Invasive plant species have become established and continue to spread, posing a risk of injury 

to wildlife and causing a loss of wildlife habitat. In an effort to reduce the spread of invasive 

plants and restore native plant diversity, the Wallowa-Whitman National Forest has proposed 

to conduct invasive plants treatment projects within its administrative boundaries. Methods 

used to treat invasive plants also have the potential to adversely affect individual animals as 

well as wildlife habitat. The analysis presented in this EIS evaluates the effects on wildlife 

and wildlife habitat from proposed invasive plants treatments. 

3.3.2 Affected Environment 

Methodology 

The analysis of the wildlife resource presented here was done using a multi-scale assessment 

that includes 1) an assessment to Management Indicator Species (FSM 2620.1, 2621.4, 

2620.3), which assesses the habitat and effects to wildlife species associated with vegetation 

communities or key habitat components identified in the Forest Plan (USDA-FS 1990), 2) an 

assessment of the habitat and effects to those species considered most at risk. These include 

Federally Threatened and Endangered Species and Regionally Sensitive Species (FSM 

2670.32, 16 USC 1536), 3) an assessment of Species of Local Interest (SOLI) that are 

uncommon and/or important in ensuring that wildlife diversity is maintained, and 4) an 

assessment of priority/unique habitats and associated species identified in the Partner In 

Flight (PIF) landbird conservation plans (Altman 2000a and Altman 2000b). 

Collectively an assessment of the species/habitats identified above are used to identify the 

scope of the proposed action and alternatives, identify species most at risk, and ensue that a 

diversity of plant and animal communities are maintained across the planning area. 

Information used in this analysis includes site specific information collected during invasive 

plant inventories, forest-wide wildlife monitoring information, and GIS coverage’s and data 

sets related to wildlife habitat and site and landscape conditions. The sensitive species 

addressed in this analysis are those identified on the 2004 Regional Forester’s Sensitive 

Species list. It is recognized that this list was updated in 2008. Also because of the 

timeframes involved with project implementation (10 years), it is likely that the Forests 

sensitive species list will change again during implementation. As a result, if the pretreatment assessment (PDF A-1) identifies potential impacts to any Regionally Sensitive 

species not addressed in this analysis, potential effects would be evaluated at that time. Also 

if necessary, this analysis would be updated to incorporate any new information. 

Invasive Plants and Wildlife 

Invasive plants have adversely impacted habitat for native wildlife. Any species of wildlife 

that depends upon native understory vegetation for food, shelter, or breeding, is or can be 

adversely affected by invasive plants. Species restricted to very specific habitats, for example 

pond-dwelling amphibians, are more susceptible to adverse effects of invasive plants. 

Although it is rare, some wildlife species utilize invasive plants for food or cover. For 

example, American goldfinch (Carduelis tristis), and red-winged blackbird (Agelaius 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

phoeniceus) will utilize purple loosestrife (Kiviat 1996, Thompson, Stuckey, and Thompson 

1987), and native bighorn sheep will utilize cheatgrass (Csuti et al., 2001). While not 

preferred, it has been reported that elk, deer and rodents eat rosettes and seed heads of spotted 

knapweed. Also doves, hummingbirds, honeybees, and the endangered southwestern willow 

flycatcher (Empidonax trailii extimus) are known to use saltcedar (Barrows 1996). 

However while some species will utilize invasive plants, the few uses that they may provide 

do not outweigh the adverse impacts to an entire ecosystem (Zavaleta 2000). Displacement of 

native plant communities by non-native plants result in alterations to the structure and 

function of ecosystems and constitutes a principle mechanism for loss of biodiversity at 

regional and global scales (Lacey and Olsen 1991). Also Mills et al. (1989) and Germaine et 

al. (1998) found that native bird species diversity and density, were positively correlated with 

the volume of native vegetation, but were negatively correlated or uncorrelated with the 

volume of exotic vegetation. 

Invasive plants can adversely affect wildlife species by eliminating required habitat 

components, including surface water (Brotherson and Field 1987, Dudley 2000, Horton 

1977), reducing available forage quantity or quality (Bedunah and Carpenter 1989, Rice et al. 

1997, Trammell and Butler 1996); reducing preferred cover (Rawinski and Malecki 1984, 

Thompson et al. 1987); drastically altering habitat composition due to altered fire cycles 

(D’Antonio and Vitousek 1992, Mack 1981, Randall 1996, Whisenant 1990); and physical 

injury, such as that caused by long spines or “foxtails” (Archer 2001). 

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 Lonicera and Rhamnus shrubs 

over native trees, even though nests built in the exotic shrubs experienced significantly higher 

mortality rates. 

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). In the case of common 

burdock (Arctium minus), the prickly burs can trap bats and hummingbirds and cause direct 

mortality to individuals (Raloff 1998). Also invasive plants that grow large and dense (e.g., 

giant reed, Himalayan blackberry) can act as physical barriers to water sources and essential 

habitat (S. Bautista, personal observation). 

Habitats that become dominated by invasive plants are often not used, or used much less, by 

native and rare wildlife species. Washington Department of Fish and Wildlife (2003) 

identified noxious weeds, such as yellow star thistle and knapweed, as threats to upland game 

bird habitat. Some hunters and wildlife managers are concerned that invasive plants are 

degrading the quality of remaining habitat for deer and elk and are adversely affecting the 

animal’s distribution and hunting opportunities. Trammell and Butler (1995) found that deer, 

elk, and bison avoided sites infested with leafy spurge (Euphorbia esula). 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 (Kiviat1996, Lor 1999, Rawinski 1982, Thompson, 

Stuckey, and Thompson 1987, Weihe and Neely 1997, Weiher et al. 1996). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

In summary, invasive plants are known or suspected of causing the following effects to 

wildlife: 

• Embedded seeds in animal body parts (e.g. foxtails), or entrapment (e.g. common 

burdock) leading to injury or death 

• Scratches leading to infection 

• Alteration of habitat structure leading to habitat loss or increased chance of predation 

• Change to effective population through nutritional deficiencies or direct physical 

mortality 

• Poisoning due to direct or indirect ingestion of toxic compounds found on or in invasive 

plants 

• Altered food web, perhaps due to altered nutrient cycling 

• Source-sink population demography, with more demographic sinks than sources 

• Lack of proper forage quantity or nutritional value at critical life periods 

Threatened, Endangered and Sensitive (TES) Species 

Species discussed here include federally listed species, or species currently listed under the 

Endangered Species Act (ESA), as amended, Federal candidate species, or species currently 

being considered for listing under ESA (U.S. Fish and Wildlife Service 1996), and Sensitive 

species, or species listed on the Regional Foresters Sensitive Species List (Sensitive). These 

species are collectively referred to as TES species throughout this analysis. 

The analysis presented here provides brief general descriptions of the species’ life history, 

threats, generally recognized species protection measures and forest-status or occurrence. 

Additional detailed accounts can be found in the Biological Assessment prepared for the 

Regional Invasive Plant Program (USDA Forest Service 2005), which is incorporated by 

reference into this analysis and in the Terrestrial Wildlife Specialist Report/Biological 

Evaluation prepared for this document. These reports are available upon request from the 

Project Record at the Wallowa-Whitman National Forest Supervisor’s Office in Baker City, 

Oregon. 

Federally Listed Species 

Table 29 displays federally listed T&E species, as well as candidate species for the WallowaWhitman NF. Each species status and known occurrence on the forest are also displayed. 

There is no officially designated critical habitat for any federally listed Threatened or 

Endangered Species (16 U.S.C. 1532 (5)(A)) on the forest. 

The two candidate species found on the Wallowa Whitman National Forest, as well as the delisted bald eagle are included in the Regional Forester’s Sensitive Species (Sensitive) List, 

and are discussed under the sensitive species portion of this analysis. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 29-Federally listed or candidate species known to occur on the Wallowa-Whitman 

National Forest 

Species Scientific Name Status Presence 

Canada lynx Lynx canadensis Threatened No 

Gray wolf Canis lupus Endangered Possible 

Pacific fisher Martes pennanti Candidate No 

Columbia spotted frog Rana luteiventris Candidate Yes 

The following is a discussion of the preferred habitat for listed Threatened and Endangered 

species (Canada lynx and gray wolf), their action area status and Forest-wide habitat. The 

amount of suitable or preferred habitat currently affected by invasive plants is also identified. 

Canada lynx 

Preferred Habitat 

Lynx occur in mesic coniferous forest that have cold, snowy winters and provide a prey base 

of snowshoe hare (Lepus americanus) (Ruediger et al. 2000). Both snow conditions and 

vegetation types are important factors in defining lynx habitat. Crusting or compaction of 

snow may reduce the competitive advantage that lynx have in deep, soft snow. Primary 

vegetation that contributes to lynx habitat is subalpine fir types where lodgepole pine is a 

major seral species, generally between 4,100-6,600 feet (Ruediger et al 2000, Ruggiero et 

al.1999, and Verts and Carraway 1998). Riparian areas, aspen stands, and high-elevation 

willow communities are important lynx prey habitats and denning habitat must be in or 

adjacent to foraging habitat to be functional (Ruediger et al. 2000). Lynx seem to prefer to 

move through continuous forest, and frequently use ridges, saddles, and riparian areas. Home 

range sizes for lynx can be variable, but it appears that at least 6,400 acres of primary 

vegetation should be present to support survival and reproduction. 

Action Area Status and Habitat 

Canada lynx are thought to occur in Oregon as dispersers that have never maintained resident 

populations. They are considered an infrequent and casual visitor by the state of Oregon 

(Ruediger et al. 2000, pp. 4-7). 

To be considered “occupied” habitat, the Forest would have to have at least two verified lynx 

observations or records within the past 5 years or evidence of lynx reproduction. Winter track 

surveys for lynx and wolverine were conducted by the Forest from 1991-1994 and no 

confirmed lynx tracks were found. Hair snares were used to survey for lynx, according to the 

National Lynx Survey, during the summers of 1999-2001. There were no lynx detections 

confirmed from the survey effort. It is unknown whether lynx are currently present on the 

Forest, because there are no verified records of lynx, and there is no evidence of occupation 

or reproduction that would indicate colonization or sustained use by lynx. The WallowaWhitman National Forest has not had a verified lynx observation within the last 5 years; 

therefore, the Forest is considered “unoccupied” habitat. To be considered “occupied” 

habitat, the Forest would have to have at least two verified lynx observations or records 

within the past 5 year, or evidence of lynx reproduction. 

Lynx habitat on the Wallowa-Whitman National Forest was mapped using the vegetation and 

environmental conditions for the Northern Rocky Mountains Geographic area, and more 

153 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

specifically, the Blue Mountain Section, including NE Oregon and west-central Idaho. 

Primary vegetation was based on the direction provided in the Canada Lynx Conservation 

Assessment and Strategy (LCAS) (Ruediger et al. 2000), and follow-up guidance from the 

Forest Service Regional Office and the Lynx Biology Team. Sixth code Hydrologic Unit 

Codes (HUC), were used as the basis for delineating lynx habitat across the Forest. The 

majority of the potential lynx habitat rests on both sides of I-84 in a wide swath within the 

center of the Forest. There is also an isolated parcel of potential habitat south of Unity. 

However, the Lynx Conservation Agreement (May 2006), states that the LCAS does not 

apply to forests that are considered as having unoccupied habitat. 

Table 30 displays acres of different lynx habitat types as defined in the LCAS, and acres of 

known invasive plant sites that exist within suitable habitat. 

Table 30-Lynx Habitat types and acres of invasive plants 

Potential Lynx 

Denning 

Potential Lynx 

Forage 

Currently 

Unsuitable 

Total Potential 

Lynx Habitat 

Acres of Invasive 

Plants Within 

Potential Habitat 

287,510 129,971 73,975 602,573 706 (<1%) 

Gray Wolf 

Preferred Habitat 

Habitat preference for the gray wolf appears to be more prey dependent than cover 

dependent. The wolf is more of a habitat generalist inhabiting a variety of plant communities, 

typically containing a mix of forested and open areas with a variety of topographic features 

(NatureServe 2006, Verts and Carraway 1998, Witmer et al. 1998). Wolves prefer fairly large 

tracts of roadless country; generally avoiding areas with an open road density greater than 

one mile per square mile (Witmer et al. 1998). Gray wolves have extensive home ranges and 

both denning and rendezvous sites are often characterized by having nearby forested cover, 

remote from human disturbance (NatureServe Explorer 2006). 

Wolves are strongly territorial; defending an area of 75-150 square miles. Home range size 

and location is determined primarily by the abundance of prey, which includes primarily large 

ungulates such as elk and deer (NatureServe Explorer 2006, Verts and Carraway 1998, 

Witmer et al. 1998). Their alternate prey base typically consists of smaller mammals and 

birds, such as, beaver, ground squirrels, rabbits, and grouse (NatureServe Explorer 2006, 

Witmer et al 1998). It is not uncommon to observe wolves “mousing” in grassy meadows 

much like coyotes and red fox. 

Action Area Status and Habitat 

There have been numerous reported wolf sightings and some evidence to indicate their 

existence in this area. Also, numerous sightings have been reported in the Eagle Cap 

Wilderness. Sightings seem to indicate transient or lone individuals that are not part of a 

resident pack, and to date, there are no den or rendezvous sites known to occur on the forest 

154
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

No specific habitat was identified for wolf in this analysis since they are a wide ranging 

species that utilize a variety of habitat. However, they prefer more remote areas away from 

humans and high road densities. 

Forest Service Sensitive Species 

Species discussed here include those listed as Sensitive on the Regional Forester’s Sensitive 

Species list. The primary objectives of the Sensitive Species program are to ensure species 

diversity is maintained, and to avoid trends toward endangerment that would result in a need 

for federal listing. Species identified by the FWS as “candidates” for listing under the ESA, 

and meeting the Forest Service criteria for protection, are included on the Regional Forester’s 

Sensitive Species Lists. Also the Bald Eagle (Haliaeetus leucocephalus), which was de-listed 

as threatened in August 2008 (USDI 2007) is included on the R6 Sensitive species list. 

It should be pointed out that the Wallowa-Whitman National Forest administers the entire 

Hells Canyon Natural Resource Area (HCNRA), which includes a small portion in Idaho. 

The Idaho portion of the HCNRA includes a small number of acres in both Forest Service 

Regions 1 and 4. Both Regions have their own Regional Forester’s Sensitive Species lists. 

Many of the species on their list are the same as Region 6 or are forest dwelling species that 

would not be impacted by any of the proposed invasive plant treatments because the proposed 

treatments on the Idaho portion are all in open grassland vegetation. The one exception is 

Region 4’s Northern Ground Squirrel, which has a very limited distribution and has not been 

located anywhere in the HCNRA. 

Since none of Region 1 or 4 sensitive species will be impacted by proposed treatments, they 

will not be analyzed in this document. Appendix C contains a list of additional Regional 

Forester’s Sensitive Species. 

Terrestrial wildlife species found or suspected to occur on the Wallowa-Whitman National 

Forest that are included in the Regional Forester’s Sensitive Species List are listed in Table 

31. 

Table 31-Suspected (S) or Documented (D) Wildlife of the Wallowa-Whitman NF on the 

Regional Forester’s Sensitive Species List (July 2004) 

Common Name Scientific Name Occurrence 

Mammals 

California wolverine Gulo gulo D 

Pacific Fisher Martes pennanti S 

Rocky Mountain Bighorn Sheep Ovis canadensis canadensis D 

Spotted Bat Euderma maculatum D 

Birds 

Bald eagle Haliaeetus leucocephalus D 

American peregrine falcon Falco peregrinus anatum D 

Upland sandpiper Bartramia longicauda D 

Gray flycatcher Empidonax wrightii S 

Horned Grebe Podiceps auritus S 

Bufflehead Bucephala albeola S 

Greater Sage Grouse Centrocercus urophasianus phaios S 

Columbia Sharp-tailed Grouse Tymphanuchus phasieanellus D 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Common Name Scientific Name Occurrence 

Greater Yellowlegs Tringa melanoleuca S 

Tricolored Blackbird (OR only) Agelaius tricolor S 

Bobolink (OR only) Dolichornyx oryzivorus S 

Amphibians 

Northern Leopard frog Rana pipiens S 

Columbia spotted frog Rana luteiventris D 

Reptiles 

Painted Turtle Chrysemys picta S 

D = Documented – in the context of the Forest Service sensitive species program, an organism that has been 

verified to occur in or reside on an administrative unit. 

S = Suspected – in the context of the Forest Service sensitive species program, an organism that is thought to occur, 

or that may have suitable habitat, on Forest Service land or a particular administrative unit, but presence or 

occupation has not been verified. 

The following is a discussion of the preferred habitat for species listed in Table 32; their 

action area status and Forest-wide habitat. The amount of suitable or preferred habitat 

currently affected by invasive plants is also identified. More detailed information can be 

found in the project wildlife report available in the project record, and Appendix C of this 

document. 

California Wolverine-Documented 

Preferred Habitat 

Wolverines inhabit dense coniferous forests and use open sub-alpine forests up to and beyond 

timberline. Typically, they use high elevation alpine wilderness areas in the summer and 

montane forest habitats in the winter (Copeland 1996). They are associated with rocky 

outcrops, steep mountainous areas and transition zones between primary cover types. 

Forested riparian zones at upper elevations are likely to be important forage habitats for these 

furbearers and provide relatively safe travel corridors that allow for animals to move within 

and between watersheds. Natal denning habitat includes high elevation open rocky slopes 

(talus or boulders), that maintains a snow depth greater than 3 feet into March and April 

(Forest Service 1994). Wolverines are known to regularly avoid humans and are sensitive to 

any human related disturbance. 

The wolverine is an opportunistic scavenger, with large mammal carrion the primary food 

source year-round. Prey items also include small and medium-sized mammals, birds and their 

eggs, insects, fish, roots, berries, and carrion. While foraging, they generally avoid large open 

areas and tend to stay within forested habitat at the mid and high elevations (greater than 

4,000’) and typically travel 18-24 miles to forage/hunt (Forest Service 1994). 

Action Area Status and Habitat 

Prior to 1973, wolverines were classified as furbearers in Oregon. They are considered rare 

throughout all of Oregon, Washington, Idaho, and California, and recent sightings, tracks, and 

a road kill document their continued presence at low densities (Csuti et al. 2001). Records for 

eastern Oregon include a partial skeleton and tufts of fur found near Canyon Mountain, Grant 

County (1992), as well as tracks and a possible denning site discovered in the Strawberry 

Mountain Wilderness (1997). Tracks have also been documented in the Monument Rock 

Wilderness (1997). 

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Although there are historical records and more recent sightings from wilderness, or more 

remote high elevation areas, there are no recent verified locations or physical evidence of 

their occurrence. Also although formal track surveys for wolverine were conducted during 

the winters of 1991 through 1994, no tracks were documented. 

There are no known den sites on the Wallowa-Whitman National Forest. Due to their 

preference for high elevation remote habitat for dens, and considering this species is strongly 

associated with low levels of population density and roads (Carroll et al. 2001), the most 

likely places wolverines would be found on the Forest are wilderness and roadless areas. 

However because this species is capable of traveling long distances in a single day, it could 

occur in other areas. 

The Wallowa-Whitman NF has four wilderness areas totaling approximately 586,780 acres. 

There are approximately 979 acres known to have invasive plants within all the wilderness 

areas. Wolverine denning habitat, which tends to be above 7,000 feet, has no known invasive 

plants sites. 

Pacific Fisher-Suspected 

Preferred Habitat 

Fishers primarily use mature, closed-canopy coniferous forests with some deciduous 

component, frequently along riparian corridors. They are known to occasionally use cut-over 

areas, but this in not their optimal habitat. Fishers use a variety of resting sites such as hollow 

logs, rock piles, and snow dens, but the maternal den is almost always in a tree. The fisher is 

an opportunistic carnivore whose diet includes small rodents, rabbits, squirrels, porcupines, 

amphibians, reptiles and birds and their eggs. It also eats some carrion, fruits, and berries. 

Action Area Status and Habitat 

In April 2004, the FWS determined that federal listing for the West Coast Distinct Population 

Segment (DPS) of the fisher was “warranted, but precluded by other higher priority listing 

actions” (U.S. Fish and Wildlife Service 2004). This DPS includes Washington, Oregon, and 

California. The fisher is a FWS candidate species. 

In Oregon, the fisher apparently has been extirpated from all but two portions of its historical 

range (Aubrey and Lewis 2003) and the two known extant populations are in the 

southwestern portion of the state: one in the southern Cascade Range that was established 

through reintroductions of fishers from British Columbia and Minnesota that occurred 

between 1961 and 1981, and one in the northern Siskiyou Mountains of southwestern 

Oregon, that is presumed to be an extension of the population in northern California. 

Genetic testing has revealed the populations are isolated from each other (Aubrey et al. 

2002). The same study revealed juvenile male fishers are capable of long distance dispersal 

with one collared male relocating to the Crescent Ranger District in the summer of 1999, 

having traveled over 34 miles from point of capture on the Rogue River National Forest 

(Since the Rogue River-Siskiyou National Forest). The radio signal from this animal was lost 

in December 1999 and it is unknown if this animal is still alive on the district or if it may 

have eventually occupied a territory. 

There are no known resident populations of fisher on the Forest. Fisher were re-introduced 

onto the Forest in the 1970s, both in the Minam and in the Eagle Creek drainage outside of 

Halfway, Oregon. The re-introductions were not successful and fisher have not become 

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established. Although there is documented evidence that at least one individual fisher existed 

on the Wallowa-Whitman National Forest, there is no known or confirmed reproducing 

population. It is highly unlikely fisher are present on the Forest. If fisher were found, it/they 

would most likely be related to the Rocky Mountain population rather than the western 

Oregon population. 

Potential broad scale fisher habitat on the Forest was determined by mapping multi-storied, 

mature and old forest stands with trees and snags 15 inches in diameter at breast height (dbh) 

or larger, with a canopy closure equal to or greater than 50 percent and at 4,000 feet in 

elevation or above. No acres of juniper woodland, hot-dry ponderosa pine or whitebark pine 

habitat was calculated into the fisher habitat. Using these factors to determine potential fisher 

habitat; the action area contains approximately 174,954 acres of habitat. Of this 

approximately 941acres (close to 0.5 percent) contain known invasive plant sites, with 60 

percent of the invasive sites adjacent to roads (545 acres) and (21 acres) trails. 

Rocky Mountain Bighorn Sheep-Documented 

Preferred Habitat 

Bighorn sheep generally inhabit open areas of rocky slopes, ridges, rim rocks, cliffs, and 

canyon walls with adjacent grasslands or meadows, and few trees (Verts and Carraway 1998). 

Dense forest communities are avoided. Their primary diet consists of bunchgrass, but also 

includes significant amounts of forbs and shrubs during the growing seasons. In the winter 

and spring they will also utilize cheatgrass, which is an invasive annual plant. Use is largely 

determined by the availability of escape terrain and most bighorn sheep forage within 0.5 

mile of escape terrain and generally are not seen farther than 1.0 mile from escape cover. 

Summer range varies from subalpine meadows above 7,500 feet to canyon grasslands at 

1,000 feet. Winter range is usually below 4,500 feet. Some herds are yearlong residents on a 

given area, with little or no spatial separation of summer and winter ranges (Drewek 1970). 

Other herds migrate several miles between summer and winter range and occupy areas that 

include a variety of elevations and environmental conditions (Geist 1971). Both summer and 

winter range must provide freedom from disturbance and a proper juxtaposition of forage, 

escape terrain, and water. 

Terrain for lambing is rugged, precipitous and remote (Van Dyke et al. 1983). Such terrain 

provides pregnant ewe’s security and isolation during the lambing season. Ewes select 

rugged cliffs of at least 5 acres for lambing. Ewe-lamb groups prefer more rugged topography 

than ram groups (Valdez and Krausman 1999) and are more restricted in use of their range. 

Ram groups will range farther from escape terrain than ewe groups. 

Action Area Status and Habitat 

Rocky mountain bighorn sheep are mainly found in areas within the HCNRA and the Eagle 

Caps. Table 32 displays the eight areas bighorn sheep are found on the Forest and the number 

of acres within which invasive plants are found. The Burnt River Herd, which consists of R6 

Sensitive California bighorn sheep, resides mostly on BLM administered lands. 

Approximately 3,140 acres of the Wenaha/Haas/Cottonwood herd’s normal home range is on 

the Wallowa-Whitman National Forest, although the majority of it is on the Umatilla National 

Forest. The Wenaha/Haas/Cottonwood herd was covered in the Umatilla’s Invasive Plants 

analysis. In addition, the Black Butte/Joseph Creek bighorn sheep herd range lies directly to 

the north of the northern-most portion of the Forest. Invasive plants do not appear to be 

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currently impacting bighorn sheep habitat to any measurable degree since only a small 

portion of the bighorn sheep habitat includes invasive plants. 

Table 32-Bighorn sheep locations and the approximate number of acres of invasive plants 

Bighorn Sheep Location Approximate Acres 

Within The Area 

Acres with Invasive 

Plants 

Percent of Bighorn 

Sheep Area with 

Invasive Plants 

Bear Creek/Minam River 14,052 297 2.1% 

Burnt River (California 

bighorn sheep subspecies) 111 0 0% 

Lostine 49,085 42 <1% 

Lower Hells Canyon 68,052 1,211 1.8% 

Lower Imnaha River 46,775 580 1.2% 

Upper Hells Canyon 14,418 18 <1% 

Upper Joseph Creek 44,957 479 1% 

Spotted Bat-Documented 

Preferred Habitat 

The spotted bat has been observed in a wide variety of habitat types, from ponderosa pine 

forests to desert water holes. It is known to nest in crevices in cliffs, which may be more 

important in determining its distribution than any particular vegetation type. Spotted bats are 

solitary foragers and they primarily feed on moths. They emerge from day roosts after sunset, 

and are most active between midnight and 3:00 a.m. 

The spotted bat is considered one of the rarest mammals in North America. Surveys using 

echolocation calls are discovering that it is more common and widespread than previously 

thought. It was discovered in canyons in Owyhee County, Idaho in 1987. 

Action Area Status and Habitat 

There are two spotted bat records from eastern Oregon (neither of which are in the Tri-Forest 

area), where it is probably rare but widely distributed; however, more surveys are required to 

determine its distribution and status. The Region 6 Regional Forester’s Sensitive Species list 

shows spotted bats as documented on the Forest; however it is now thought that the 

individual was misidentified. Although at one time this species was thought to exist in the 

HCNRA, surveys have not found spotted bats on the Forest, and there is only a low 

probability that this species occurs within the action area. 

Potential habitat acres were not developed for the spotted bat, because cliff sites are not 

identified in the Forest data base and their habitat preferences are not clearly understood. 

There are approximately 221,514 acres of dry ponderosa pine forest, hot dry pine forest and 

juniper woodland, that would likely provide the most desirable habitat. Within these areas 

there are approximately 3,161 acres (1.4 percent) of known invasive plant sites. 

Bald Eagle-Documented 

Preferred Habitat 

Bald eagle populations have made substantial recoveries in recent years. Formerly listed as 

endangered in 1978, the bald eagle was down-listed to threatened status in the lower-48 states 

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in 1995. In March 1999, FWS proposed to delist the bald eagle throughout its entire range 

(Federal Register 1999). The bald eagle was delisted on August 8, 2007, and it is now a 

Region 6 sensitive species (USDI Fish and Wildlife Service 2007). 

Nesting territories are normally associated with lakes, reservoirs, rivers, or large streams 

(U.S. Fish and Wildlife Service 1986). In the Pacific Northwest recovery area (for more 

information see the Bald Eagle Recovery Plan, U.S. Fish and Wildlife Service 1986), 

preferred nesting habitat for bald eagles is predominately uneven-aged, mature coniferous 

(ponderosa pine, Douglas-fir) stands or large black cottonwood trees along a riparian corridor 

(NatureServe 2006 and USDI 1986). Adults tend to use the same breeding areas year after 

year, and often the same nest, although a breeding area may include one or more alternative 

nests (U.S. Fish and Wildlife Service, 1999). The size and shape of a defended breeding 

territory varies widely (1.6 to 13 square miles) depending upon the terrain, vegetation, food 

availability, and population density of an area (USDI 1986) 

The most common food sources for bald eagle in this region are fish, waterfowl, rabbits, and 

various types of carrion (NatureServe Explorer 2006 and USDI 1986). The main food source 

for bald eagles during the breeding season is fish; therefore, habitat of most importance 

during this period consists of areas near large bodies of water and major river systems (U.S. 

Fish and Wildlife Service, 1995). During the winter communal roosts, which generally hosts 

several eagles are established near a rich food source (high concentrations of waterfowl or 

fish) (Anthony et al. 1982). Communal winter roosts tend to be isolated from disturbance and 

offer more protection from the weather than diurnal roosts (NatureServe and USDI 1986). 

Action Area Status and Habitat 

The Wallowa-Whitman National Forest occupies the Bald Eagle Blue Mountains Recovery 

Zone 11. The main threats identified by the Recovery Plan for Zone 11 are recreation 

disturbance, commercial timber harvest, shooting, and trapping. However, since the plan’s 

approval, new habitat issues have evolved; large potential nesting or roosting trees (e.g., 

ponderosa pine and Douglas-fir) have been significantly impacted by insects, disease, 

blowdown, and wildfire. 

The Wallowa-Whitman National Forest has three known bald eagle nest sites. Two are 

located on the Whitman Ranger District including one in close proximity to Phillips Lake 

Reservoir and the other near the West Fork of the Burnt River, northwest of Unity Reservoir. 

Both are located in open ponderosa pine forest. Although nest success varies for the Phillips 

Lake nest, most years one to two young fledge each year. The Unity nest site moved a few 

times and has had less success in fledging young than the Phillips Lake nest site, but has still 

successfully fledged a number of offspring. The area surrounding the Phillips Lake nest site is 

closed year-round to motorized travel. The Unity nest site has a motorized closure from 

January 1 through August 31 each year. Nests are monitored annually and a site-specific 

management plan was developed, for both Whitman Ranger District bald eagle nest site 

areas. Each plan developed a Bald Eagle Management Area (BEMA) boundary, which is 

entirely within National Forest System lands. 

The third bald eagle nest is near the Hells Canyon Dam and is within the Hells Canyon 

National Recreation Area. It was discovered in 2005 and has successfully fledged young the 

past two seasons. There is currently no Bald Eagle Management Plan for this nest site. 

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There is one designated bald eagle winter roost site on the Forest. This winter roost is on the 

Whitman Ranger District, in close proximity to Oregon Department of Fish and Wildlife 

(ODF&W) Salmon Creek elk feeding station. The Salmon Creek Bald Eagle Winter Roost 

site is closed to motorized use from December 1 to May 1 each year. There is only one 

designated bald eagle winter roost site; however, bald eagles do roost in various other places 

on the Forest during winter months. The birds often utilize private lands in the valleys during 

the day and fly to different roost areas on the Forest in the evening. These roost sites often 

vary from year to year. Winter bird count surveys occur along the Upper Grande Rhonde 

River and the Snake River each year. Bald eagle numbers appear to be fairly small and both 

the roost and perch sites often vary somewhat from year to year. The majority of the bald 

eagle migration and winter sightings are within the Baker Valley as well as along the Grande 

Ronde and Snake Rivers. 

There are no treatments proposed near known nests or roost sites. Invasive plants do not 

threaten the bald eagle or its habitat, although disturbance of nest sites can adversely affect 

the bald eagle. The FWS has calculated some standard distances where disturbance could 

adversely affect the success of nesting bald eagles. The distances vary depending on the 

activity, topography and time of year. For specific information see the National Bald Eagle 

Guidelines (USDI FWS, 2007) 

American peregrine falcon-Documented 

Preferred Habitat 

Peregrine falcons inhabit cliffs located generally within approximately 0.5 miles of riparian 

habitat. Peregrines nest on ledges clear of rock rubble, located approximately 40 - 80 percent 

of total cliff height. Peregrines are aerial predators who feed mostly on birds. Much of the 

prey consists of species the size of pigeons and doves; however avian prey ranges in size 

from hummingbirds to Aleutian Canada geese (Pagel, unpub. data). Preferred peregrine 

falcon habitat includes various open habitats from grassland to forest in association with 

suitable nesting cliffs. The falcon often nests on ledges or holes on the face of rocky cliffs or 

crags. Ideal locations include undisturbed areas with a wide view, near water, and close to 

plentiful prey. 

Foraging habitats of woodlands, open grasslands, and bodies of water are generally 

associated with the nesting territory. Falcons are known to forage over large areas, often ten 

to fifteen miles from the eyrie. 

Peregrines lay 2-4 eggs in March-May, and commence incubation after the clutch is 

complete. Eggshell thinning induced by the metabolite of the pesticide known as DDT 

(DDE), affected populations in the Pacific Northwest and elsewhere, and residual levels of 

DDE continue to affect the reproductive success of peregrines. Reproductive failure at all 

peregrine nests has been chronic in northern CA and OR since at least 1983 due to eggshell 

thinning. 

Invasive plants do not directly affect peregrine falcons. Peregrine falcons in the Pacific 

Northwest are most affected by bioaccumulation of contaminants, and direct disturbance to 

their nesting at known or suspected nest sites; both which have caused numerous nesting 

failures during the previous 20 years of observation (Pagel unpub. data in USDA Forest 

Service 2008, Deschutes National Forest Invasive Plants Treatment EIS). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Action Area Status and Habitat 

Peregrine nest site surveys have been conducted in potential nesting habitat during the1990’s 

and suitable habitat continues to be intermittently and informally surveyed. There are 

currently four known active peregrine falcon nests on the Wallowa-Whitman National Forest. 

The Hells Canyon Dam (HCNRA), Mt. Emily (La Grande) and the Mt. Morian (Eagle Caps 

Wilderness) nests were all located in the 1990s. The Castle Ridge nest on the La Grande 

District was discovered in 2005. Since they nest on generally inaccessible cliffs, no invasive 

plants are located in known or potential peregrine falcon nesting habitat. Since peregrines are 

aerial predators who feed mostly on birds they often feed on prey many miles from their nest. 

Upland Sandpiper-Documented 

Preferred Habitat 

Upland sandpipers generally nest in extensive, open tracts of short grassland habitat, 

including native prairie, dry meadows, pastures, domestic hayfields, and short-grass savanna, 

plowed fields along highway rights-of-ways and on airfields. 

Preferred habitat includes large areas of short grass for feeding and courtship with 

interspersed or adjacent to taller grasses for nesting and brood cover. The species migrates 

along shores and mudflats, and winters in South America (NatureServe 2006). It may perch in 

coniferous trees or snags surrounding the nesting site. They will forage in open meadows for 

favorite foods, grasshoppers and crickets. They also eat ants, berries, and seeds of grasses and 

forbs (Csuti et al. 2001). 

In Oregon, the upland sandpiper nests in partly flooded meadows and grasslands, usually with 

a fringe of trees, and often in the middle of higher-elevation sagebrush communities. 

Meadows favored by this sandpiper are little grazed and have some growth of forbs. 

Action Area Status and Habitat 

Upland sandpipers are not known to occur regularly on the Wallowa-Whitman National 

Forest. A pair was documented nesting on the La Grande District towards Ukiah in the 

1990s, but they haven’t been found since. Surveys for upland sandpipers are conducted on a 

regular basis. Potential upland sandpiper habitat was queried by using all dry herbland 

(grassland) and dry shrubland that had less than 10 percent slope and was greater than 5,000 

feet in elevation. Using this broad scale analysis, there are approximately 37,514 potential 

acres of upland sandpiper habitat within the action area. Of this, approximately 330 acres 

have known invasive species infestations. However this analysis includes a much higher 

number of acres of potential habitat, since it does not specifically identify partly flooded 

meadows or grasslands or short grass. 

Gray flycatcher-Suspected 

Preferred Habitat 

Gray flycatchers are uncommon in Oregon and southern Idaho, but may be fairly common in 

specific locations (Marshall et al. 2003). They are locally fairly common in dry habitats in 

other areas of the western United States. In northern Washington the habitat used by gray 

flycatchers is fairly specific. Dry open ponderosa pine stands with extensive bitterbrush and 

bunchgrasses understory. Tree size ranges from small (6” diameter breast height) to large (40 

inches diameter breast height). In central Oregon, they are commonly found in juniper, sage, 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

and bunchgrass habitat. The common factor seems to be scattered vertical structure of 

evergreen trees over an extensive shrub and grass understory (savannah). 

They are migratory and spend winters in Arizona and Mexico, leaving breeding grounds by 

the end of September (Csuti et al. 2001). 

Gray flycatchers take insects on the wing as well as by foraging on the ground. Their diet 

includes a variety of species ranging from small beetles to butterflies. 

Action Area Status and Habitat 

Gray flycatchers have not been documented on the Forest. Since gray flycatchers are difficult 

to distinguish from the dusky flycatcher they may or may not be more widespread than is 

currently recognized. Their territory has been reported to vary from three to nine acres, and 

the home range seems to be about 10 acres (Csuti et al. 2001). Broad scale mapping of 

potential breeding gray flycatcher habitat included: all dry shrublands and ponderosa stands 

with less than 30 percent canopy closure or juniper woodlands with less than or equal to 40 

percent canopy closure. 

Using these broad parameters, a total of approximately 162,741 acres of potential gray 

flycatcher breeding habitat exist. Of this a total of approximately 2,617 acres or about 1.6 

percent of potential gray flycatcher habitat contains known infestations of invasive plant 

species. 

Horned grebe-Suspected 

Preferred Habitat 

Horned grebes breed from Alaska and northern Yukon south to eastern Oregon and Idaho. 

The species’ winter range extends along the Pacific coast from the Aleutian Islands to Baja 

California. Horned grebes rarely breed east of the Cascade Range in Oregon (Marshall 2003). 

Horned grebes prefer large areas of open water surrounded by emergent vegetation. Nesting 

habitat is found in tall vegetation in shallow water. 

The primary diet of horned grebes consists of fish and tadpoles; although it will also take 

aquatic insects, crustaceans, amphibians, mollusks, and leeches. 

Action Area Status and Habitat 

Horned grebes may migrate through the Wallowa-Whitman National Forest during October 

and November as they move to winter habitat areas, however none have been documented on 

the Forest. It is highly unlikely horned grebes breed on the Forest, although potential 

breeding habitat for horned grebes exists within lakes and larger ponds with emergent 

vegetation. 

There are a total of 193 lakes within the Forest boundary, of which 181 are on NFS lands. 

These water-bodies range in size from three-tenths of an acre to 1,747 acres (Phillips Lake). 

There are approximately 11,373 acres of water in lakes and ponds on the Forest. Of those 

acres, approximately 665 acres have mapped emergent vegetation. Less than 3 acres of 

emergent vegetation has known invasive plants. This project does not treat emergent 

vegetation. 

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Bufflehead-Suspected 

Preferred Habitat 

The bufflehead is a tree-nesting, diving duck whose population has declined throughout some 

of its range due to clear cutting, over harvest of habitat, and in some locations throughout its 

range, over-hunting (Marshall et al. 2003). It is still harvested in Washington and Oregon. 

For nesting, it uses mountain lakes surrounded by woodlands with snags (mostly aspen, but it 

will use ponderosa pine and Douglas-fir). Buffleheads are common in parts of Oregon and 

Washington during winter, but are rare during the breeding season. Most breeding occurs in 

Alaska and Canada. In Oregon, buffleheads use a high preponderance of artificial nest boxes. 

Buffleheads eat animal matter, with common diet items including aquatic insects and larvae, 

physid snails, fish and sometimes herring eggs or salmon carrion. They also eat seeds of 

aquatic plants, such as smartweed, alkali bulrush, and sago pondweed (Marshall et al. 2003). 

Action Area Status and Habitat 

No breeding has been documented in eastern Oregon and this species has not been 

documented on the Forest. However limited potential breeding habitat exists at some of the 

lakes and ponds on the Forest, where suitable nesting cavities occur. Also buffleheads have 

been found in ponds in the Baker Valley (off the Forest), when they migrate through the area 

in the spring. Consequently suitable habitat could be also be used during migration. 

Although habitat suitability would depend on the availability of snags, for the purpose of this 

analysis suitable habitat is the same as that described for the horned grebe. 

Greater Sage Grouse-Suspected 

Preferred Habitat 

Greater sage grouse (hereafter simply called sage grouse) have been extirpated in British 

Columbia and in five states (Arizona, New Mexico, Oklahoma, Kansas, and Nebraska), and 

is "at risk" in six states (Washington, California, Utah, Colorado, North Dakota, and South 

Dakota) and in the Canadian provinces of Alberta and Saskatchewan (Natureserve 2008). In 

five states (Oregon, Nevada, Idaho, Wyoming, and Montana), long-term population declines 

have averaged 30 percent since 1950. 

In Oregon, sage grouse were common to abundant in the non-forested areas east of the 

Cascades during much of the 19th century, but began to decline by the late 1890s (Crawford 

1982). By 1940, sage grouse occupied only half of their historic range in Oregon, and 

numbers declined 60 percent between the late 1950s and the early 1980s (Crawford and Lutz 

1985). The Baker Resource Area of the BLM has local sage grouse information associated 

with the Virtue Flats area; however, no sage grouse have been documented on the WallowaWhitman National Forest. The sage grouse population in northeast Oregon is thought to be 

non-migratory, but has been observed to move extensively between seasonal use areas, and 

may therefore require large areas of sagebrush habitat with sufficient suitable habitat between 

to provide connectivity (Hanf et al. 1994). 

On February 7, 2003, the FWS announced a 90-day finding on a petition to list the western 

sage grouse under the Endangered Species Act of 1973, as amended. Because there is 

insufficient evidence to indicate that the western population of sage grouse is a valid 

subspecies or a Distinct Population Segment, the FWS found that the petition does not 

present substantial scientific or commercial information indicating that listing may be 

warranted (U.S. Fish and Wildlife Service 2003). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Sage grouse breed on sites called leks (strutting grounds) in March-April. The same lek sites 

tend to be used year after year. They are established in open areas surrounded by sagebrush, 

which is used for escape and protection from predators. Habitats used by pre-laying hens are 

also part of the general breeding habitat. These areas provide forbs that are high in calcium, 

phosphorus, and protein, all of which are necessary for egg production. The condition and 

availability of these areas are thought to have a significant effect on reproductive success 

(Barnett and Crawford 1994). Most sage grouse nests are located under sagebrush plants 

(Crawford et al. 2004); however, nests have been found under other plant species (Connelly 

et al. 1991). Sage grouse nesting and early brood-rearing occurs in April-June; this is a 

critical time for sage grouse. 

Early brood-rearing generally occurs relatively close to nest sites; however, movements of 

individual broods may be highly variable (Connelly 1982). Hens with broods tend to select 

habitats having a wide diversity of plant species that tend to provide an equivalent diversity 

of insects that are important chick foods. 

Late brood-rearing occurs June-October. In June and July, as sagebrush habitats dry and 

herbaceous plants mature, hens usually move their broods to moister sites in or adjacent to 

sagebrush cover where more succulent vegetation is available (Connelly and Markham 1983, 

Connelly et al. 1988, Fischer et al. 1996b, Gates 1983). As fall progresses, sage grouse move 

towards their winter ranges and shift their diet primarily to sagebrush leaves and buds 

(Connelly et al. 1988, Connelly and Markham 1983). The exact timing of this movement 

varies; depending on the sage grouse population, geographic area, overall weather conditions, 

and snow depth. 

Sage grouse winter habitats, used in November-February, are relatively similar throughout 

most of their range. Winter habitats must provide adequate amounts of sagebrush because 

their winter diet consists almost exclusively of sagebrush (primarily leaves and buds). If snow 

covers the sagebrush, the birds move to areas where sagebrush is exposed. 

Declines in sage grouse populations have been linked to agricultural conversion, rangeland 

conversion, livestock management, wildfire, prescribed fire, fire rehabilitation, structure and 

infrastructure development, juniper expansion, and invasions of exotic species (PIF 2000, 

Blus et al. 1989; Braun 1987, Braun 1998, Byrne 2002, Connelly et al. 2000, Enyeart 1956, 

Higby 1969, Mack and Thompson l982, Pellant 1990, Peterson 1970, Quigley and Arbelbide 

1997, Swensen et al. 1987, Valentine 1990, Wisdom et al. 2000, Wright et al. 1979). 

Invasive plants can reduce native plant diversity important to sage grouse and biological 

objectives for the Shrub-Steppe habitat include maintaining sites dominated by native 

vegetation and initiating actions to prevent infestations of exotic vegetation (PIF 2000). 

Greater Sage Grouse and Sagebrush Habitat Conservation Team, consisting of state and 

federal agencies, private landowners, conservation groups and academics, was established in 

2001 to craft a comprehensive set of planning guidelines for sage grouse and sagebrush 

habitats in Oregon. Sage grouse and Sagebrush-Steppe Ecosystem Management Guidelines 

have been also been developed (USDI BLM et al. 2000). The primary goal of these 

guidelines is to maintain existing sagebrush-steppe habitats in order to sustain sage grouse 

populations and protect options for future management. 

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Action Area Status and Habitat 

Although small populations of sage grouse live in outlaying areas and surveys have been 

conducted at different times of the year, to date no sage grouse have been detected on the 

Forest. Sagebrush habitat on the south sides of Dooley and Black Mountain and near Unity 

are the most likely areas to provide habitat for sage grouse, because they are adjacent to large 

tracts of BLM land with suitable sagebrush. Isolated patches of sagebrush are not likely to 

contribute to sage grouse habitat since the birds need large acreage of fairly contiguous 

habitat to provide for all their habitat needs. There are 18 areas on the Forest that have 250 

acres of sagebrush or more. These 18 sites include eight areas with 250 to 500 acres of 

sagebrush, six with 500 to 800 acres, two with 800 to 1000 acres, and two with slightly over 

1,000 acres of sagebrush mix. Also three Forest sagebrush sites are adjacent to BLM lands 

and combined these areas may be large enough habitat to contain sage grouse. These areas 

currently contain 6 acres of invasive plants. 

Columbia Sharp-tailed Grouse-Documented 

Preferred Habitat 

The sharp-tailed grouse is found from central Alaska and the Yukon east to Hudson Bay and 

south in the Rocky Mountains to New Mexico and, in the Great Plains and Midwest, south to 

Kansas and Illinois. It has disappeared from many areas along the southern periphery of its 

range. 

Sharp-tailed grouse habitat includes grasslands, prairies, mountain meadows, and, to a certain 

extent, sagebrush or woodlands with a grass understory. This species seeks cover in brushy 

draws or riparian thickets. It uses agricultural fields, but generally disappears from land under 

cultivation. 

Young sharp-tailed grouse eat a variety of insects and a few berries. As adults, the diet is up 

to 90 percent plant material, including grain, berries from brush like serviceberry, 

chokecherry, huckleberry, wild rose. They also eat plant buds and flowers. During the 

summer, adults may eat up to 40 percent insects, but the winter food consists of berries and 

buds. 

Action Area Status and Habitat 

Sharp-tailed grouse in Oregon declined throughout most of the 20th century and vanished by 

the 1980s. They were re-introduced into Wallowa County (HCNRA) in 1992 but did not 

thrive and eventually died out. This area contains the most suitable habitat available for 

sharp-tailed grouse on the Forest. It is highly unlikely sharp-tailed grouse exist on the Forest 

or in the vicinity. 

The query that was used for sharp-tailed grouse was broad and includes all the dry herbland, 

dry shrub, moist herbaceous riparian and warm-hot riparian herbland habitat. Using this 

broad query there are approximately 477,431acres of potential sharp-tailed grouse habitat on 

the Forest, of which approximately 9,426 acres (less than one percent) have known invasive 

plant species. 

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Greater Yellowlegs-Suspected 

Preferred Habitat 

The greater yellowlegs breeds in Alaska and most of Canada, except along its southern 

border. A few pairs have been found nesting in Oregon. They winter along the U.S. coasts and 

south to the southern tip of South America. 

Greater yellowlegs prefer boggy areas where there are some coniferous trees and open water 

in close proximity. They actively hunt animal food in the water, even chasing small fish. Its 

usual diet is aquatic invertebrates, such as insects and their larvae, mollusks, crustaceans, 

worms, tadpoles, and an occasional berry (Custi et al. 2001). 

Breeding begins in late May or early June and eggs are incubated for about 23 days. Young 

are capable of first flight in about 18-20 days. 

Action Area Status and Habitat 

During migration, this species can be seen most anywhere in Oregon where there is shallow 

water for feeding. The only Oregon breeding location was found at Downy Lake, in the 

Wallowa Mountains in the 1990s. Breeding at this site has occurred at least four times, 

although has not occurred in recent years (T. Schommer, personal communication 2007). In 

winter, they are common along the coast of Oregon and locally, inland. 

There is approximately 11,373 acres of potential greater yellowlegs habitat on the Forest. Of 

this,104 acres, have known invasive plant infestations. 

Tricolored Blackbird-Suspected 

Preferred Habitat 

Tricolor blackbirds are designative restricted breeders with a distribution from southern 

Oregon south through northern Baja, California. It is rare in Oregon, and prefers to breed in 

freshwater marshes with emergent vegetation (cattails) or in thickets of willows or other 

shrubs. Although it has also been confirmed breeding in Himalayan blackberry growing in 

and around wetlands and is often found in the company of red-winged blackbirds. Tricolor 

blackbirds breed in April after migrating to Oregon breeding grounds. The nest is made up of 

plant fibers attached to emergent vegetation or secured in a thicket of shrubs (Beedy and 

Hamilton 1999). This blackbird is colonial rather than territorial, defending only a few feet 

from the nest. After breeding season, it forms large flocks. Most of Oregon's tricolored 

blackbirds winter in California (Beedy and Hamilton 1999). 

Action Area Status and Habitat 

Tri-colored blackbirds have not been documented on the Wallowa-Whitman National Forest 

or any of the adjoining Forests. Limited habitat exists in areas that have emergent vegetation, 

willows or other water-loving shrubs; however these birds have not been documented in 

northeastern Oregon. Inadequate information exists for areas with emergent vegetation, 

willows and other water-loving shrubs on the Forest, so potential acres of tricolor blackbird 

habitat were not estimated. 

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Bobolink-Suspected 

Preferred Habitat 

Bobolinks breed nearly coast to coast, from southern Canada south across the northern United 

States. It reaches the Atlantic Coast in the East, but remains east of the Cascade Mountains in 

Oregon and Washington. 

The bobolink is a bird of open prairies, grasslands, wet meadows, pastures, and grain crops. 

In Oregon, there are only a few dis-junct populations that breed in irrigated hay meadows 

fringed with willows or in wet, grassy meadows with local growths of forbs and sedges. 

Many of these areas are mowed and/or grazed, which facilitates nesting for bobolink. 

Bobolink eat grass and forb seeds as well as insects. During the breeding season more insects 

are included in the diet, especially caterpillars. 

Action Area Status and Habitat 

Bobolinks have not been documented on the Wallowa-Whitman National Forest or any of the 

adjoining Forests. Limited habitat exists in areas that have grasslands, wet meadows, willows 

or other water-loving shrubs. Bobolinks have been observed in the Bowen Valley just outside 

the Forest but not within the Forest boundaries. Estimates place the total number of bobolinks 

breeding in Oregon at less than 1,000 individuals (Csuti et al. 2001). 

Northern Leopard Frog-Suspected 

Preferred Habitat 

The most cold-adapted of all the leopard frogs, northern leopard frogs occur in a wide variety 

of habitats (springs, marshes, wet meadows, riparian areas, vegetated irrigation canals, ponds, 

and reservoirs) and requires a high degree of vegetative cover for concealment (NatureServe 

Explore 2006, McAllister et al. 1999). They are also found in grasslands, woodland, and 

forest that range high into the mountains (Stebbins 1985). They prefer quiet or slowly flowing 

waters and avoid areas without cover (McAllister et al. 1999, Csuti et al. 2001). Typically, 

they are found between 500 and 3,000 feet in elevation (Corkran and Thoms 2006). They 

breed in ponds or lake edges with fairly, dense aquatic emergent vegetation in mid spring, and 

attach their eggs to submerged vegetation well below the surface (NatureServe Explore 2006, 

Corkran and Thoms 2006). Hatchlings cling to the egg mass or nearby vegetation while 

tadpoles live in dense aquatic vegetation, and juveniles and adults live in aquatic vegetation 

and in adjacent grass, sedge, weeds or brush (Corkran and Thoms 2006). Over-wintering 

habitats are larger lakes and streams that do not freeze completely during winter (NatureServe 

Explore 2006, McAllister et al. 1999). 

Larvae eat algae, plant tissue, and other organic debris (Csuti et al. 2001). Carnivorous adults 

eat both invertebrates (spiders, insects, snails, and leeches) and vertebrates (tadpoles, small 

frogs, small snakes, and fish (McAllister et al. 1999, Csuti et al. 2001). 

This frog is known in Oregon mostly from older records and recent surveys have failed to 

find it in Oregon (Csuti et al. 2001). Corkran and Thoms (2006) stated “we were lucky 

enough to find the only northern leopard frog egg mass seen in Oregon or Washington for 

quite a few years.” Leopard frogs have not been found during any of the Forest amphibian 

surveys that have taken place. Their occurrence in the Action area is unknown but unlikely. 

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Action Area Status and Habitat 

The Wallowa-Whitman National Forest does not have GIS coverage for all manmade and 

natural ponds, reservoirs, wet meadows, and stockponds; however it does have GIS coverage 

for waterbodies and springs. Although waterbodies and springs contain only a portion of the 

potential leopard frog habitat available in the action area, it does provide a sense of what 

proportions of mapped waterbodies currently contain invasive plants. 

Forest-wide there are 181 waterbodies and 426 springs defined in the Wallowa-Whitman GIS 

coverage’s. In the model used for leopard frog potential habitat, the springs and waterbodies 

were buffered by 300 feet to the outside to capture shore habitat and buffered 25 feet to the 

inside to capture emergent vegetation habitat types. Based on these parameters, there are 

approximately 8,669 acres of potential shoreline northern leopard frog habitat, of which 

approximately 29 acres are known to contain invasive plant species. There are approximately 

2,703 acres of spring habitat, of which 76 acres (approximately 2.8 percent) have known 

invasive plants. 

Columbia Spotted Frog-Documented 

Preferred Habitat 

Columbia spotted frogs range from southeastern Alaska to central Nevada, east to 

Saskatchewan, Montana, western Wyoming, and north central Utah. The Great Basin 

Distinct Population Segment (DPS) of the Columbia spotted frog is a federal candidate for 

listing. This DPS is found in Oregon, Idaho, and Nevada. The Columbia spotted frog is 

considered a Forest Service sensitive species and has been documented on the Malheur, 

Ochoco, Umatilla, and Wallowa-Whitman National Forests. This species was once considered 

to be included in Rana pretiosa, with the Oregon spotted frog. 

The spotted frog frequents waters and associated vegetated (grassy) shorelines of ponds, 

springs, marshes, and slow-flowing streams and appears to prefer waters with a bottom layer 

of dead and decaying vegetation (NatureServe Explore 2006, Hayes et al. 1997, Csuti et al. 

2001). They occur along the grass and sedge margins of streams, lakes, ponds, springs, and 

marshes. They typically occur between 1,700 and 8,000 feet in elevation (Corkran and Thoms 

2006). The Columbia spotted frog exhibits strong fidelity to breeding sites and often deposits 

eggs in the same locations in successive years. They deposit egg masses in still, shallow 

waters atop submergent herbaceous vegetation or among clumps of herbaceous wetland 

plants. Breeding habitats include a variety of relatively exposed, shallow-water (less than 60 

centimeters), emergent wetlands such as sedge fens, riverine over-bank pools, beaver ponds, 

and the wetland fringes of ponds and small lakes. Vegetation in the breeding pools generally 

is dominated by herbaceous species such as grasses, sedges and rushes. After breeding, adults 

often disperse into adjacent wetland, riverine and lacustrine habitats. Tadpoles live in the 

warmest parts of ponds (Corkran and Thoms 2006). Froglets and adults live in well-vegetated 

ponds, marshes or slow, weedy streams that meander through meadows (Corkran and Thoms 

2006). Springs may be used as over-wintering sites for local populations of spotted frogs 

(Hayes et al. 1997). 

Larvae have a diet of algae, plant material, and other organic debris. Adults eat insects (ants, 

beetles, mosquito larvae, and grasshoppers), spiders, mollusks, tadpoles, crayfish, and slugs 

(NatureServe Explore 2006, Hayes et al. 1997, Csuti et al. 2001). Columbia spotted frogs eat 

arthropods, earthworms and other invertebrate prey. Predators of the species include mink, 

river otter, raccoon, herons, bitterns, corvids, garter snakes, dragonfly larvae, and predacious 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

diving beetles (McCallister and Leonard 1997). Environmental stressors such as pesticides, 

herbicides, fertilizers, and heavy metals may slow reactions or cause behavioral changes that 

make spotted frog tadpoles more vulnerable to predation (Lefcort et al. 1998, Rosenshield et 

al. 1999, Marco et al. 1999, Bridges 1999, Bridges and Semlitsch 2000). Threats to the 

species include mining, livestock grazing, road construction, agriculture, and direct predation 

by bullfrogs and non-native fishes (USDI 1998). 

Like all amphibians, spotted frogs absorb some of the oxygen and water they need to survive 

through their skin. There are many advantages to having permeable skin, like being able to 

breathe in and out of water. But there are disadvantages as well. In addition to oxygen and 

water, chemicals can easily penetrate the skin of an amphibian and enter its body. This is one 

of the reasons why frogs may be particularly susceptible to potential harm from herbicides 

and environmental pollutants. 

Spotted frogs are characterized by their special anatomy that allows them to live in and out of 

the water. For example, spotted frogs start as tadpoles that live in water and then transform 

into frogs that live on land. This means that they may be exposed to both aquatic and 

terrestrial pollution. These frogs are also threatened by pollutants in the environment because 

their eggs do not have a hard shell acting as a barrier between the un-hatched amphibian and 

the water that surround it. 

Action Area Status and Habitat 

Columbia spotted frogs occur in a number of locations on the Wallowa-Whitman National 

Forest. This species is often found in natural ponds and lakes, rock pits, old mining ponds, 

livestock stockponds, and slow moving streams that retain water year-round. More locations 

have been found on the south end of the Forest and most spotted frog sites found in created 

habitat such as mining ponds and small lakes. None of the known spotted frog sites have 

invasive plants directly adjacent to the site. 

Potentially suitable habitat for this species within the action area, as well as the amount of 

habitat that is known to be affected by invasive species is the same as that described above 

for the Northern Leopard Frog. 

Painted Turtle-Suspected 

Preferred Habitat 

Painted turtles are usually found below 3,500 feet in elevation (St. John 2002). This turtle 

occurs in slow moving, shallow, quiet waters, with muddy or sandy substrates with aquatic 

vegetation and basking sites (NatureServe Explore 2006, St. John 2002, Csuti et al. 2001, and 

Johnson 1995). Painted turtles are found in lakes, ponds, marshes, and slow moving streams 

located in a variety of surrounding vegetation types (St. Johns 2002). The turtle is active 

diurnally, April through October and hibernates in water in bottom mud (NatureServe Explore 

2006 and Csuti et al. 2001). They nest in soft soil in open areas up to 500 feet from water 

(NatureServe Explore 2006, St. John 2002, and Csuti et al. 2001). 

The turtle eats both plants; including algae, duckweed, bulrush, and animal matter including 

spiders, beetles, insect larvae, earthworms, crayfish, fish, frogs, and tadpoles (NatureServe 

Explore 2006, St. John 2002, and Csuti et al 2001). The young are more carnivorous, while 

the adults are more herbivorous. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Action Area Status and Habitat 

The painted turtle appears to be declining in Oregon due to lack of recruitment. Predation on 

young by introduced bullfrogs may be responsible for the decline (Csuti et al. 2001). This 

may be true for other parts of Oregon; however the Action area currently does not have any 

known bullfrog populations. Surveys for painted turtles have been sporadically conducted. 

Although potential habitat does exist for this species, there are currently no known painted 

turtle locations on the Wallowa-Whitman NF (T. Schommer, personal communication). 

Potentially suitable habitat for this species within the action area, as well as the amount of 

habitat that is known to be affected by invasive species is the same as that described above 

for the Northern Leopard Frog. 

Management Indicator Species 

Management Indicator Species (MIS) are selected species whose welfare is believed to be an 

indicator of the welfare of other species using the same habitat, or a species whose condition 

can be used to assess the impacts of management actions on a particular area (Thomas et al. 

1979). The MIS approach is used in concert with other indicators to gauge the effects of 

management on wildlife. Table 33 includes those wildlife species that were identified as MIS 

for the Wallowa-Whitman National Forest (USDA 1990). 

Table 33-Management Indicator Species and their associated habitat for the Wallowa-Whitman 

NF 

Species Habitat Types 

Rocky Mountain elk General forest habitat and winter ranges 

Pileated Woodpecker Dead/down tree habitat (mixed conifer) in mature 

and old growth stands 

Northern goshawk Mature and old growth forest stands 

Pine Marten Mature and old growth stands at high elevations 

Primary cavity excavators Dead/down tree (snag) habitat 

Rocky Mountain elk 

Preferred Habitat 

Rocky Mountain elk is an important game species on the Wallowa-Whitman National Forest 

(USDA Forest Service 1990). Elk habitat consists of a mosaic of woodland cover and open 

area. Forest habitat provides escape cover from human disturbance and predators and 

provides travel corridors between seasonal habitats (USDA NRCS 1999). Elk forage consists 

of a wide variety of grasses, forbs and woody plants, with grasses, sedges and spring forbs 

being the primary forage items in summer. As summer progresses, more forbs and woody 

material are consumed and dry grasses and browse are utilized heavily in autumn. Although 

grasses are preferred, shrub and browse species are used during the winter months (USDA 

NRCS 1999). 

In the Blue Mountains, optimum landscape level elk habitat includes a mixture of 

approximately 40 percent cover and 60 percent in forage (Thomas 1979). Proximity to cover 

is also important and for maximum use, elk forage areas should be within 600 ft. of cover, as 

use significantly declines beyond that point (Thomas 1979). The amount of canopy cover also 

affects suitability of foraging habitat and once the forest reaches or exceeds 60 percent 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

canopy closure, understory forage begins to decline rapidly. So while forested habitat 

provides some forage, forage areas include primarily natural and man-made openings, in 

close proximity to cover (Thomas 1979). 

While elk utilize a diversity of forest and non-forest conditions, preferred use areas can be 

affected by human access and disturbance (Rowland et al 2000). For example researchers 

have reported decreased use of areas adjacent to roads for distances ranging from 400 ft 

(Whitmire and Wisdom) to 1⁄2 mile (Thomas 1979). Also elk have been found to select 

habitats preferentially based on increasing distance from open roads (Rowland et al. 2000). 

Vulnerability and hunting mortality have been found to be higher in forested stands with 

greater road densities and less vegetation to provide screening (Weber et al. 2000). 

Elk require water, particularly on summer range and studies in Montana indicate elk make 

disproportionate use of areas within 1,050 feet of water (Thomas 1979). Optimum calving 

habitat for elk contains forage areas, hiding cover and thermal cover within forest stands, 

generally on slopes less than 15 percent (Thomas 1979). 

Action Area Habitat 

Because of the diversity of habitats utilized, elk were selected as an indicator of general forest 

habitat. Elk habitat, which includes a variety of forest and non-forest communities, was 

mapped as part of a cooperative effort sponsored by the Rocky Mountain Elk foundation and 

currently, over 96 percent of the action area provides elk habitat. Approximately 1 percent of 

the Forest-wide elk habitat is currently infested with invasive plants and Table 34 displays the 

amount of existing elk habitat infested by seasonal use area. The total acreage of infested 

plants that occurs along road corridors is also displayed in Table 34. 

Table 34-Elk Habitat affected by invasive plants 

Elk Habitat 

Acres of 

Suitable Habitat 

Acres of 

Infestation 

Percent of 

Habitat 

Affected 

Summer Range Only 1,603,380 8,517 0.5 

Winter Range Only 85,383 1,429 1.8 

Year-long Use 607,371 10,722 1.8 

Migration Corridor 64,6701 450 .7* 

Total Infestation 2,296,314 21,118 0.9* 

Infested Acres Along Roads 7,870 372 

 * - percent of forest-wide habitat 

 1 – Acreage also included in summer/winter range 

 2 - % of the total acres of forest-wide elk habitat infested 

Pileated woodpecker 

Preferred Habitat 

The pileated woodpecker was selected as an indicator species in the Forest Plan to represent 

dead and down tree habitat in mature and old growth mixed conifer stands. The pileated 

woodpecker is the largest woodpecker species in the western United States and nests in 

cavities of large trees or snags. It is an occupant of mature forests, relying on dead and 

decaying trees for foraging and nesting. The pileated woodpecker is fairly common 

throughout the Wallowa-Whitman National Forest in mature and late-successional mixed 

conifer forest. Pileated woodpeckers rely on large areas of unburned, mature and old-growth 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

forests for their foraging resources, because they forage primarily on ants (Hymenoptera and 

Formicidae) within softened wood (Bull and Holthausen 1992). 

Action Area Habitat 

Parameters used for mapping potential habitat for pileated woodpecker included late forest 

structure in mixed conifer stands consisting of ponderosa pine, western larch, grand fir and 

Douglas-fir, which had greater than or equal to 50 percent canopy closure and trees and snags 

that were at least 15 inches diameter breast height. Using this analysis there are 

approximately 133,318 acres of potential pileated woodpecker habitat within the action area. 

Since pileated woodpeckers utilize down logs and snags and forage on beetles and ants buried 

inside decaying wood, their habitat is not impacted by invasive plant infestations. There are 

approximately 1,177 acres (0.9 percent) of known invasive plant species infestations within 

this potential pileated woodpecker nest habitat. 

Northern Goshawk 

Preferred Habitat 

The northern goshawk was selected as an indicator species in the Forest Plan to represent 

species that require mature to over mature closed-canopy forests. The goshawk uses mature to 

over mature dense canopy forests for nesting and forested areas with open inclusions for 

foraging on birds and small mammals. Goshawks have a high fidelity to nest areas, which are 

often used more than one year, and sometimes used intermittently for decades (Reynolds et 

al. 1992, Wisdom et al. 2000). Many pairs of goshawks have two to four alternate nest areas 

within their home range. 

Goshawk nest areas typically have high tree canopy cover and a higher proportion of larger 

trees then surrounding areas. Studies suggest that dense vegetation provides relatively mild 

and stable microenvironments, as well as protection from predators. Nest areas are usually 

classified as mature and late structural forest stands (Reynolds et al. 1992, Graham and Jain 

1998). Human activity during the nesting period may cause the nest to be abandoned and 

subsequent nest failure (Reynolds et al. 1992). 

Action Area Habitat 

Parameters used for mapping potential habitat for northern goshawk included late forest 

structure in mixed conifer stands consisting of ponderosa pine, western larch, grand fir and 

Douglas-fir, which had greater than or equal to 50 percent canopy closure and trees and snags 

that were at least 15 inches diameter breast height. Using this analysis there are 

approximately 174,956 acres of potential goshawk habitat within the action area. Since 

goshawks tend to utilize dense forest with openings, their habitat is less likely to be impacted 

by invasive plant infestations however infestations may occur in nesting or foraging habitat. 

There are approximately 941 acres (0.5 percent) of known invasive plant species infestations 

within this potential northern goshawk habitat. Approximately sixty percent (566 acres) of 

those acres are adjacent to roads and trails. 

Pine marten 

Preferred Habitat 

The pine marten (aka American marten) was selected as an indicator species in the Forest 

Plan to represent complex mature and old growth stands. Preferred habitat for the marten 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

consists of higher elevation (greater than 4000 feet) stands of dense conifer and large downwood often associated with streams. Pine martens occur in dense forests containing snags and 

down logs, which provide suitable denning sites. The pine marten is most closely associated 

with heavily forested east and north-facing slopes that contain numerous windfalls (Maser 

1998). Martens spend a great deal of time in trees. They tend to avoid areas that lack 

overhead protection and the young are born in nests within hollow trees, stumps, or logs. 

They eat a variety of small mammals, particularly squirrels, as well as voles, mice, pika, and 

rabbits. Martens do not tolerate concentrated human use or habitat modification.The historical 

and current density and distribution of marten in the Forest is unknown, but they are thought 

to occur in low numbers. 

Action Area Habitat 

Multi-storied mature and old forest stands with trees and snags 15 inches in diameter at breast 

height or larger, with 50 percent canopy closure and at least 4,000 feet in elevation were used 

to determine broad-scale potential pine marten habitat. No acres of juniper woodland, hotdry ponderosa pine or whitebark pine habitat was calculated into the marten habitat. Using 

these parameters, the action area contains approximately 174,956 acres of pine marten 

habitat. Approximately 941 acres (0.5 percent) contain known invasive plant sites. 

Approximately 60 percent of those sites are adjacent to roads (545 acres) and (21 acres) trails. 

Cavity Excavators 

Preferred Habitat 

A large number of species rely on cavities in trees for shelter and nesting. Primary cavity 

excavators include 16 species of birds with potentially suitable habitat on the WallowaWhitman National Forest. These species include Lewis' woodpecker, Williamson’s sapsucker, 

red-naped sapsucker, downy woodpecker, hairy woodpecker, white-headed woodpecker, 

three-toed woodpecker, black-backed woodpecker, northern flicker, pleated woodpecker, 

black-capped chickadee, mountain chickadee, chestnut-backed chickadee, red-breasted 

nuthatch, white-breasted nuthatch, and pygmy nuthatch (Johnson and O’Neil 2001,Thomas 

1979). Habitat for primary cavity excavators includes dead trees in various size and decay 

classes with coniferous and hardwood vegetation and a variety of structural stages (ibid). This 

group of primary cavity excavators is considered one management indicator in the Forest 

Plan and represents a vast array of vertebrate species that depend upon dead trees and down 

logs for reproduction and/or foraging (USDA 1990). 

Secondary cavity users such as owls, bluebirds, and flying squirrels may use cavities created 

by primary cavity users for denning, roosting, and/or nesting. By addressing available habitat 

for primary cavity excavators, it is expected that habitat for secondary cavity users will be 

provided (USDA 1990). 

Action Area Habitat 

Because primary cavity nesting species utilize a wide variety of snag species and size classes, 

virtually all forested land or approximately 70% of the action area provides potentially 

suitable habitat. Although invasive plant infestations occur within forested habitat, they are 

not adversely affecting habitat for cavity nesting species. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Species of Interest 

Landbirds (migratory birds) 

Landbirds include neo-tropical migratory birds that have been defined as those species that 

regularly breed in continental North America and winter south of the Tropic of Cancer, 

typically in Central and South America and the Caribbean. Landbirds are defined as all birds 

except loons, grebes, seabirds, waterfowl, long-legged waders, shorebirds, gulls, terns, alcids, 

cranes, and rails. Widespread declines in populations of many landbirds have intensified 

interest in avian conservation and resulted in policy direction to evaluate the impact of 

proposed activities on the nesting habitats of these species. 

The North American Breeding Bird Survey Program found that 75 percent of forest dwelling 

migrants in eastern North America declined in population during the 1980s (Robbins et. al. 

1989). Potential causes of these declines are numerous and diverse, and may involve 

corridors and stopover sites, or a combination of these factors (Sherry and Holmes 1992). 

Related to these potential causes is the problem of nest parasitism by the brown-headed 

cowbird, populations of which have expanded significantly in the last few decades due 

primarily to human-induced changes in the landscape (Ehrlich et al. 1988). One hundred 

sixty two species of landbirds breed in Oregon and Washington including common passerine 

songbirds, hawks, and owls (Andelman & Stock 1994). 

Landbirds occur in a wide variety of habitat types including early and late-seral forests (Finch 

& Stangel 1992). In the relatively arid western United States, however, densities of neotropical migrants are highest in riparian areas, with coniferous forests being the second-most 

used habitat by this assemblage of species (Saab and Rich 1997). 

Focal Species 

In 2000, Partners in flight released conservation strategies for landbirds in Oregon and 

Washington (Altman 2000, Altman 2000a, and Altman 2000b). These documents identified 

1) priority habitats, or habitats most important to landbirds within the region, 2) focal species, 

or species most highly associated with priority habitats and their attributes, and 3) 

conservation recommendations to achieve desired objectives. Table 35 identifies the priority 

habitat, habitat attribute and focal species identified in these plans that occur on the Forest. 

Unique habitats, as well as the amount of action area habitat affected by invasive plants are 

also displayed. 

Table 35-Priority and Unique Habitats on the Forest and the associated Focal Species 

Priority Habitat Habitat Attribute Focal Species 

Percent of 

Action 

Area 

Priority Habitat 

Dry Forest 

Old forest-large patches 

Grassy openings-dense thickets 

Open understory-regeneration 

Burned old forest 

White-headed 

woodpecker 

Flammulated owl 

Chipping sparrow 

Lewis’ woodpecker 

49 

Mesic Mixed Conifer 

Large snags 

Multi-layered, structurally diverse 

Canopy foliage cover 

Vaux’s swift 

Townsend’s solitare 

Varied thrush 

27 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Percent of 

Priority Habitat Habitat Attribute Focal Species Action 

Area 

Dense shrub layer 

Fire edges and openings 

MacGillivray’s warbler 

Olive-sided flycatcher 

Riparian 

woodland/shrub 

Large snags 

Canopy foliage cover 

Understory cover 

Dense shrub patches 

Lewis’ woodpecker 

Red-eyed vireo 

Veery 

Willow flycatcher 

<1 

Unique Habitats 

Subalpine forest Patches Hermit thrush 2 

Mountain meadows Mesic and dry conditions Upland sandpiper 15 

Steppe shrublands Patches Vesper sparrow 2 

Aspen Large trees/snags with 

regeneration Red-naped sapsucker <1 

Alpine Patches Gray-crowned rosy finch 2 

Large-scale declines in open park-like dry forests with large trees and snags have led to 

population declines of the white-headed woodpecker, flammulated owl, white-breasted 

nuthatch, pygmy nuthatch, Williamson’s sapsucker, and Lewis' woodpecker. These bird 

species have likely suffered some of the greatest population declines and range retractions 

(Altman 2000). Local overstory nesting species and foliage or crown feeders may include the 

pine siskin, golden-crowned kinglet, mountain chickadee, hermit thrush, ruby-crowned 

kinglet, yellow-rumped warbler, and western tanager. 

Riparian woodland and shrub habitats are typified by the presence of hardwood tree and 

shrub species, along with associated wetland herbaceous species. Water is an important 

component of these habitats, whether it is in the form of standing wetlands, springs, seeps, or 

flowing water (streams). Riparian vegetation is particularly important to neo-tropical 

migratory songbirds (Sallabanks et al. 2001). Although these habitats generally comprise only 

a small portion of the landscape, they usually have a disproportionately high level of avian 

diversity and density when compared to surrounding upland habitats. 

All three plans (Altman 2000, Altman 2000a and Altman 2000b) identify invasion by exotic 

plants as an important issue adversely affecting landbird populations. Conservation strategies 

include reducing impacts to sensitive habitat from invasive plants, as well as minimizing the 

potential for herbicides to adversely effect non-target species. 

3.3.3 Alternatives Analyzed 

Treatments proposed under each of the alternatives can be found in Table 36, whereas a 

summary of how well each alternative responds to the significant issues can be found in Table 

13 in Chapter 2. Throughout this analysis Alternative A is referred to as the No Action 

alternative, whereas Alternatives B, C and D are often referred to as the action alternatives. 

Differences between these alternatives in terms of their effects on wildlife are discussed in 

detail in the Environmental Consequences section. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 36-Treatment methods by alternative 

Treatment 

Methods 

Alternative A 

No Action1 

Alternative B 

Proposed 

Action 

Alternative C 

No Broadcast in 

Riparian Habitat 

Conservation 

Areas 

Alternative D 

No Aerial 

Herbicide 

Chemical Methods 

Upland Areas 

Ground-based 

broadcast and 

spot treatments2 

2,5773 13,556 13,556 13,556 

Aerial treatments 0 875 875 0 

Riparian Habitat Conservation Areas 

Ground-based 

broadcast 

treatment 

1,9323 3,104 0 3,104 

Spot 

spray/selective 

treatment 

(including wicking 

and wiping) 

6633 3,241 6,345 3,241 

Non-Chemical Methods 

Upland Areas and Riparian Habitat Conservation Areas 

bio-control only See note below 1,955 1,955 2,797 

manual only6 0 111 111 111 

Total Acres 

Treated 5,172 22,842 22,842 22,809 

1 A designation of chemical treatment could be changed to manual, mechanical or biological treatment if, at the time 

of treatment, one of these alternative methods would be effective. A site initially treated with chemicals may be 

treated with manual or mechanical methods during follow-up treatments. 

2 Whether each site will be broadcast or spot treated will be determined locally before each field season so the acres 

to be broadcast treated and the acres to be spot treated are not known at this time. Determination of where 

broadcast versus spot treatments will occur depends on access to site, size of site, and density of weed coverage. 

3 No action alternative includes ’92 Environmental Assessment for the Management of Noxious Weeds and the ’94 

Environmental Assessment for Management of Noxious Weeds and Forest Plan Amendment #4. 

4 Acres proposed in aerial application that could be treated with ground based methods although likely to be less 

effective or more costly than those proposed in Alternative B. Approximately 33 acres would not treated due to 

inaccessibility and no other means of control i.e. biocontrol agents. 

5 Riparian Habitat Conservation Areas (RHCA) are: 300’ of perennial stream and 100’ of intermittent stream–as 

designated under PACFISH, INFISH 

6 Manual only sites will not be treated with herbicides because the desired weed management goal can be 

effectively achieved using manual methods. Such sites are typically very small or having widely scattered weeds or 

are in sensitive areas like a campground along a stream or a combination of these factors. 

Biocontrol note: the ’94 EA approved the use of biocontrol agents, however, all sites were analyzed for chemical 

treatments to attain highest amount of flexibility and greater invasive plant species control. The forest has also 

released APHIS and state of Oregon approved biocontrol agents on approximately 2,500 acres for the control of 

invasive weeds (Yates 2007). 

3.3.4 Environmental Consequences 

Methodology 

The appropriate methodology and level of analysis needed to determine effects to the wildlife 

resource are influenced by a number of variables including the presence of species or habitat, 

the scope and nature of activities associated with the proposed action and alternatives and the 

potential risks that could ultimately result in adverse effects. The multi-scale analysis used in 

this assessment includes the following: 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Site-level Assessment – This was started very early in the planning process and involved an 

evaluation of individual sites currently affected by invasive plants. Sites at this scale vary 

from less than one acre to several hundred acres in size. This assessment was used to identify 

wildlife habitat affected by invasive plants, as well as the invasive plant species involved and 

relative risk to wildlife habitat. This assessment was also used to identify unique or 

specialized habitats that need to be protected and to identify site specific mitigation measures 

or Project Design Features (PDFs) identified in Chapter 2. 

Site-level assessment also occurs during implementation (PDF A-1) and would; 1) identify 

species/habitats of local interest or concern that need to be protected, 2) identify the 

appropriate treatment method, and 3) ensure that all applicable mitigation measures (PDFs) 

are implemented to reduce effects. This level of assessment also involves implementation of 

species/habitat monitoring necessary to ensure that impacts to non-target species from 

proposed aerial broadcast treatments (PDF F-8e) are within acceptable tolerances. 

Landscape level Assessment – Landscape level effects were assessed by evaluating effects 

and changes in habitat on NFS lands within the project area (the Wallowa-Whitman National 

Forest). This level of assessment uses GIS information, as well as Forest-wide wildlife 

monitoring and observation data to assess landscape level effects to wildlife including; total 

acres of suitable habitat affected, the distribution of infestation/treatment areas, proximity of 

affected habitat to roads, riparian areas or other physical or vegetative features that would 

affect wildlife use of treatment areas, and effects to occupied or key habitats. 

The wildlife analysis is broken down into two sections. The Wildlife Effect Section includes 

an assessment of the effects of invasive plant treatments on wildlife, an analysis of the effects 

associated with herbicide exposure and risk, cumulative effect considerations, and an analysis 

of how the alternatives identified in Table 36 affect wildlife and wildlife habitat. The Species 

Analysis Section evaluates direct, indirect and cumulative effects of proposed actions on T& 

E, sensitive species, Forest MIS and species/habitats of local interest. 

Collectively the information provided in these two sections evaluate anticipated effects of the 

proposed alternatives on wildlife, assess the effects to the different habitats across the action 

area (MIS species), and ensure that regulatory direction related to wildlife is met. 

Wildlife Effects Section 

Direct and Indirect Effects 

Effects of invasive plant treatment methods to wildlife were evaluated and discussed in detail 

in the R6 2005 FEIS, the corresponding Biological Assessment (USDA Forest Service 

2005b), project files, FS/SERA risk assessments (SERA 2001, 2003a-d, 2004a-e), the Effects 

of Non-herbicidal Methods of Invasive Plant Treatment on Wildlife, Fish and Plants (USDAFS 2005?), Source and Effectiveness of Project Design Features/Criteria for Herbicide Use in 

Invasive Plant Treatment Projects Forest Service Region Six (USDA-FS 2008) and Appendix 

C (Wildlife) of this EIS. These documents also provide detailed information on herbicide 

toxicity and risk and the effects evaluation presented here relies heavily on these documents, 

which are incorporated by reference into this analysis. 

Results of numerous field studies indicate that the likelihood for direct effects to wildlife 

from herbicide use is low (e.g., Marshall & Vandruff 2002, Dabbert et al. 1997, Fagerstone et 

al. 1977, Rice et al. 1997, Sullivan et al. 1998a, Cole et al. 1997, Cole et al. 1998, Johnson 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

and Hansen 1969, Nolte and Fulbright 1997, McMurray et al. 1993a, McMurray et. al. 

1993b). However the use of herbicides to treat invasive plants does have the potential to harm 

free-ranging wildlife. Adverse effects to wildlife from manual and mechanical invasive plant 

treatments are also possible (USDA-FS 2005b). Consequently, effects to wildlife and wildlife 

habitat will be evaluated by looking at potential risks from proposed treatments, as well as 

effects from invasive plant infestation. 

Many site specific concerns related to potential effects of proposed treatment on non-target 

wildlife were addressed during the development of Project PDFs, which are identified in 

Chapter 2 of this document and are discussed throughout this analysis. It is important to note 

that while potential effects or “risks” to wildlife are discussed throughout this analysis, the 

anticipated effects of treatments proposed under the action alternatives are based on 

implementation of PDFs, which are designed in part to avoid or reduce the likelihood of 

adverse effects from herbicide use by limiting the herbicide rate, application method, timing 

or formulation used in proximity to wildlife or terrestrial and aquatic habitat (USDA Forest 

Service 2008) 

General Effects and Considerations (Alternatives A through D) 

Infestation Size 

Potential effects to wildlife vary depending on the species and extent of infestation, as well as 

the amount of native vegetation remaining within infested areas. For example, while 

treatment of larger infestations may create more disturbances for longer periods than small 

infestations, potential effects to wildlife would be reduced, because the presence of native 

wildlife in these areas is greatly reduced in comparison to native habitat (Duncan and Clark, 

2005). Conversely moderately infested areas may pose a greater risk to wildlife because these 

areas continue to support suitable habitat and are more likely to contain native wildlife. Small 

infestations would be expected to pose the least risk to wildlife because of the small amount 

of habitat affected and considering PDFs are in place to protect sensitive areas (e.g. wetlands) 

and occupied habitat of TES species. 

The size range of infested sites is displayed in Table 20. Of the currently infested sites within 

the action area 65percent are currently less than one acre in size, 15 percent are less than 10 

acres, 14 percent are between 10 and 50 acres in size, and only approximately 6 percent are 

greater than 50 acres. 

Infestation Location 

The effects of the invasive plant treatment also depend partly on the locations of existing and 

future invasive plant infestations. For example treatments of infestations along disturbed 

roadsides would likely have fewer effects, because these areas do not provide essential 

wildlife habitat and consist of long, narrow areas spread over large distances (USDA 2005a 

Appendix J p. J-17). Conversely, treatments within wilderness or remote areas would pose a 

greater risk to species sensitive to disturbance. Similarly because riparian areas often receive 

a disproportionate amount of wildlife use and can contain sensitive or important habitats (e.g. 

wetlands), potential impacts in these areas from treatment would likely be greater than many 

upland sites. All alternatives include PDFs to reduce potential impacts within riparian and/or 

sensitive wildlife habitats. 

Potential effects to wildlife are also affected by the amount of habitat affected by invasive 

plants/treatment within a species home range or territory. For example species with small 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

home ranges and less mobile species may be at greater risk, if a large portion of their daily or 

seasonal use area is affected by invasive plants/treatment. Conversely risks would be less for 

species with large home ranges or species that forage or travel over large areas, because 

invasive plants/treatment would affect less of their available daily/seasonal habitat. 

Table 41 displays the distribution of invasive plant treatments by watershed (5th level HUC). 

Although up to 22,842 acres are proposed for treatment, existing infestations and treatments 

are spread out across 53 watersheds. While the size of individual watershed varies, only three 

would have one percent or more of the watershed affected by treatment, whereas 50 

watersheds have less than one percent proposed for treatment. Implications on wildlife are 

that due to the widely scattered nature of proposed treatments and considering only a small 

amount of any affected watershed would be treated, adverse effects would generally be 

reduced, particularly for widely ranging species. 

Proximity of Suitable Habitat to Treatment Sites 

Potential adverse effects to wildlife are determined largely by the potential exposure to 

treatment. Because most invasive species are shade intolerant, the majority of treatments 

occur in openings, early structural habitat or in forested habitat with a relatively open canopy. 

Consequently species that occur primarily in mature forest are less likely to be affected by 

treatment to invasive plants. Conversely, species that prefer or require relatively open 

habitats preferred by most invasive plants are more likely to be adversely affected by both 

plant infestation and treatment. This is discussed in more detail under the individual species 

analysis. 

Invasive Plant Treatment Methods Effects to Wildlife (Alternatives A through D) 

A description of the invasive plant treatments can be found in Chapter 2 and the following is 

a discussion of the direct effects associated with proposed treatments on wildlife. Because 

indirect effects to wildlife habitat are a function of the type and amount of treatment 

proposed, indirect effects are discussed under the alternative analysis. 

Manual 

Manual methods are labor-intensive and usually ineffective for the treatment of large, wellestablished infestations of perennial invasive plants with long term viable seed such as 

knapweeds (Brown et al. 2001). Manual treatments can result in trampling of non-target 

plants (habitat) and animals and create bare ground. The degree of threat and effect from 

manual treatments depends on the number of workers present and the size of the area being 

treated. Because manual techniques are slower than mechanical or chemical methods, the 

duration of disturbance may be longer in the treatment area. However the slower pace of 

work allows animals in the area to leave and reduces the risk of direct harm from trampling. 

Bare ground is likely to be patchy in distribution with this method and less likely to interfere 

with animal movement or dispersal. 

Mechanical 

Mechanical methods generate more noise than other treatments, except for aerial applications, 

and have a higher likelihood of disturbing species that are secretive or sensitive to noise. For 

several species loud and sudden noises above background or ambient levels (those above 92 

dB) can cause disturbance that might flush a bird off the nest or abort a feeding attempt. 

Based on interviews with State and County weed control operators, the vehicles used to spray 

roadside vegetation with herbicides do not make noise as loud as logging trucks or large 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

delivery trucks and are therefore within the background noise level for open roads. Other 

mechanical devises proposed for use on invasive plants include brushing machines, mowers, 

chainsaws, and string trimmers. These tools have the potential to create noise above 

background levels that may disturb some wildlife. Because disturbance related effects would 

only occur during treatment, effects to wildlife would be short-term in nature (generally 1 to 

2 days). 

Because some mechanical treatments may crush small mammals, reptiles, amphibians, or 

eggs of ground-nesting birds, potential mortality to less mobile species/nests is greater than 

manual treatment. Hand-held mechanical equipment, like chainsaws and string trimmers, can 

be used very selectively on target plants and may be less likely than larger equipment to 

directly harm wildlife. Use of vehicle-mounted mechanical equipment (mowers, or hammer 

flails etc.) is much less selective and more likely to directly harm small wildlife species. 

Vehicle-mounted equipment is most often applied to monocultures of invasive plants on 

gentle slopes or road verges, and even though those areas do not provide preferred or suitable 

habitat for most native wildlife, adverse effects from disturbance or crushing are still 

possible. 

Mechanical treatments may produce more bare ground, reducing cover, exposing more soil to 

erosion, potentially disrupting dispersal or foraging patterns of small animals, and possibly 

exposing some to increased predation as a result of decreased cover. Although with 

implementation of site restoration treatments described below, any loss of cover would be 

short-term (1 growing season). 

Biological 

Biological control is proposed on sites are either too large to be sprayed with herbicides, 

where the invasive plant species is so abundant that other methods would not be practical, or 

where the biological control agent is effective on the target plant species and treatment can 

reduce or eliminate the need to use herbicides. 

Effects during the use or treatment of biological controls would be similar to that described 

above under manual treatment. Although some bio control agents available can have adverse 

effects to non-target wildlife, only APHIS and State-approved biological control agents would 

be used. Also agents demonstrated to have direct negative impacts on non-target organisms 

would not be released. As a result other than effects associated with treatment, there are no 

adverse effects related to biological control to wildlife anticipated under any alternative. 

Cultural/Restoration 

Restoration or reclamation of sites infested with invasive plants follow treatment restoration 

standard 13 (WW LRMP as amended by the R6 2005 ROD) and incorporate guidelines for 

revegetation of invasive weed sites and other disturbed areas on National Forests and 

Grasslands in the Pacific Northwest (Erickson et al. 2003, also Appendix B – Revegetation 

Guidelines) On degraded sites where reproducing individuals of desirable species are absent 

or in low abundance, revegetation with well adapted and native competitive grasses, forbs 

and legumes can be used to direct and accelerate plant community recovery and restore native 

wildlife habitat conditions. Restoration and revegetation projects that would include ground 

disturbing activities such as disking or plowing would require additional NEPA analysis on a 

site specific level. 

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Herbicide Application 

Herbicides would be used in accordance with label instructions, except where more restrictive 

measures are required. Also herbicide applications would only treat the minimum area 

necessary to meet site objectives (F-1). For example, larger infestations that cannot be 

effectively treated using manual or mechanical treatments or because biological control is not 

feasible, would be treated with herbicides. Also, for some plant species manual or mechanical 

treatments are ineffective due to plant morphology and initial control would require the use of 

herbicides. In many cases herbicides would only be used to reduce infestations to the point 

that they can be effectively controlled with other methods. Consequently herbicide 

application would decline over time, because infestations would be adequately reduced to 

allow for control with non-chemical methods. 

Herbicide treatment methods are described in Chapter 2. Methods of ground-based or aerial 

application of herbicides would be used based on accessibility, topography, the size of 

treatment area and the expected efficiency and effectiveness of the method selected. 

Application methods include wicking, wiping, stem injection, spot spraying, hand broadcast, 

or boom broadcast. Wicking, wiping, and stem injection are done by hand and spot spraying 

can be done by hand or using a hose off a vehicle or pack animal mounted tank. All of these 

treatment methods target individual plants. These activities can result in short-term 

disturbance and possible mortality during treatment; however, spot and hand treatments are 

explicitly not considered high risk (USDA Forest Service 2008) and therefore reduce 

potential for exposure of non-target wildlife to herbicides. 

Hand and boom broadcast techniques cover an area of ground rather than individual plants. 

Hand broadcast is done using a backpack sprayer or hand spreader, whereas boom broadcast 

uses a hose and nozzle from a tank mounted on a truck, all terrain vehicle (ATV), or pack 

animal. Boom broadcast is used in areas where invasive plants cover on the site makes spot 

spraying impractical. Both treatment activities can result in disturbance or mortality during 

treatment; although potential for mortality of less mobile species or destruction of eggs and 

nests are greater using the mechanized equipment associated with the boom broadcast 

technique. 

Aerial applications (Alternatives B and C only) occur in areas where physical features, such 

as topography, raise applicator safety concerns or where cost of ground application is 

prohibitive. In these areas invasive plants may be treated with the use of helicopters. 

Although potential for mortality is reduced, noise related disturbance would be greater. Also 

because application can cover large areas, potential wildlife exposure to herbicides is greater, 

although PDFs F-8a through F-8o were developed to minimize potential effects to non-target 

species. All aerial broadcast projects also require effectiveness monitoring, to ensure that 

impacts are within acceptable tolerance. 

Early Detection Rapid Response (EDRR) 

EDRR is designed to be aggressive in the control of invasive plants. This is necessary to 

ensure success in managing and controlling the spread of these highly competitive and easily 

established plants. 

The treatment of newly found sites adds additional risk factors to wildlife just by adding 

additional exposure areas. This also expands the treatment into areas that may not have been 

originally anticipated. However, the decision process identified in Chapter 2 would be used 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

with each new infestation site to determine treatment. In addition, the PDFs have been set up 

to provide layers of caution so that even if the exact locations are not known, the potential for 

adverse effects are minimized. The limitation on treatment type (no herbicide use), and the 

addition of PDFs, buffers and treatment limits (i.e. leaving stream corridors untreated) all 

work together to provide sideboards to deal with the uncertainty of treating new sites (USDA 

Forest Servoce 2008). 

The management direction included in all alternatives as well as the environmental conditions 

and animal behavior would tend to minimize actual impacts for EDRR. At the project scale, 

choices could be made to avoid situations that could cause harm to wildlife. For example, 

certain herbicides could be avoided in specific areas or times of the year where/when species 

that utilize grass such as amphibians may be at risk, or more specific application methods 

could be used. These factors would be evaluated during the pre-treatment assessment (PDF 

A-1) and this assessment in combination with implementation of PDFs that restrict herbicide 

use and methods would greatly reduce potential impacts to wildlife. 

Treatment Effects Summary 

Effects of invasive plant treatment methods to wildlife were evaluated and discussed in detail 

in the R6 2005 FEIS, Appendix P, the corresponding Biological Assessment (USFS 2005d), 

project files, and SERA risk assessments (2001, 2003, 2004). The effects of non-herbicide 

treatments are disclosed in Appendix J of the R6 2005 FEIS. The analysis presented in these 

documents indicates that disturbance from manual and mechanical treatment pose greater 

risks to terrestrial wildlife species of local interest than herbicide use. While all alternatives 

would result in disturbance and possible mortality to less mobile species, disturbance would 

be short-term and implementation of PDFs would reduce potential mortality and herbicide 

exposure to non-target wildlife. 

Herbicide Effects (Alternatives A through D) 

Background 

Effects of herbicide application presented here rely heavily on the Invasive Plants R6 2005 

FEIS, which is incorporated by reference into this analysis. This document, in combination 

with Appendix C of this EIS provides detailed information related to herbicide risks, 

exposure scenarios and effects from proposed herbicide application.The invasive plant 

treatments proposed were designed to reduce or eliminate adverse effects to wildlife under all 

alternatives; however, short-term, minor adverse effects (See individual species discussions) 

could occur under any alternative from the herbicide treatment methods. 

When considering the effects of herbicides on wildlife species, it is important to remember 

these herbicides are designed to affect plants at relatively low rates, while much higher rates 

would be required to kill animals. It is also important to note that plants have metabolic 

systems that do not exist in animals. It is these metabolic systems at which the herbicides are 

targeted. Michael (2002) explained it well when he said, “All chemicals, natural or manmade, are toxic at some level of exposure. The difference between acute and chronic toxicity 

versus the no observed effect level (NOEL) is primarily a function of the amount of exposure 

in a unit of time and the mode of action of the chemical. 

While results of numerous field studies indicate the likelihood for direct adverse effects to 

wildlife from herbicide use is low (e.g., Marshall & Vandruff 2002, Dabbert et al. 1997, 

Fagerstone et al. 1977, Rice et al. 1997, Sullivan et al. 1998a, Cole et al. 1997, Cole et al. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

1998, Johnson and Hansen 1969, Nolte and Fulbright 1997, McMurray et al. 1993a, 

McMurray et. al. 1993b), the use of herbicides to treat invasive plant does have the potential 

to harm free-ranging wildlife (USDA 2005c p. 1-11). For example, certain herbicides can 

affect the vital organs of some wildlife species, change body weight, reduce the number of 

healthy offspring, increase susceptibility to predation, or cause direct mortality. 

Herbicides may also cause some malformations or mortality to amphibians that have been 

exposed to herbicides or surfactants in water (Relyea 2005). In addition, herbicides contain 

impurities and additives, and produce metabolites that could be toxic to wildlife. A metabolite 

of triclopyr, 3, 56-trichloro-2-pyridinol (TCP), is toxic to animals. The impurity 

hexachlorobenzene, found in picloram and clopyralid, is carcinogenic and surfactants added 

to herbicides could substantially increase toxicity to aquatic species, like amphibians. The 

likelihood that wildlife would be exposed to levels of herbicides that would result in adverse 

effects are discussed below under herbicide toxicity and risk. 

Herbicide Toxicity and Wildlife Risk 

Potential toxicity risk from herbicide exposure was determined using data and methods 

outlined in the SERA risk assessments (2001, 2003, and 2004), Tables 5 and 6 in Appendix P, 

and the Wildlife Biological Assessment (USDA 2005c pp. 24 – 27). Collectively these 

assessments list the toxicity indices used as the thresholds for potential adverse effects from 

each herbicide. A quantitative estimate of dose using a “worst case” scenario was compared 

to these toxicity indices. If a dose exceeded a toxicity index, then it was determined to have 

potential for an adverse effect (see Appendix C). 

Application rates are the amount of herbicide applied during treatment in pounds per acre and 

are displayed in Table 4. While these vary by herbicide/surfactant, many of the PDFs were 

specifically designed to ensure that any application rates used were below levels that would 

result in an exposure of a non-target species that exceeded the NOAEL. For example, NPE 

surfactant exceeded the toxicity index for some acute exposures at the typical application 

rate. As a result, PDFs require that NPE only be applied at levels well below the typical 

application rate. Similarly, triclopyr exceeded the acute toxicity index of some species at 

typical application rates if broadcast sprayed. As a result, the R6 2005 FEIS restricts the use 

of triclopyr to spot spray and selective techniques only. Consequently, even though some 

herbicides/surfactants resulted in adverse effects during the exposure scenario, 

implementation of PDFs (See Chapter 2) reduces the potential for non-target wildlife to 

receive a toxic dose of herbicide/surfactant. Appendix C provides a detailed summary of 

anticipated effects on wildlife from proposed herbicides and includes risk assessment 

summaries and exposure scenarios at typical and high application rates. 

The risk assessments prepared by SERA (2001, 2003, and 2004) contains the detailed 

analysis of the potential effects of each herbicide. Portions of the risk assessments pertaining 

to terrestrial wildlife are summarized in USDA Forest Service 2005d, Appendix B. This 

summary contains a detailed description of factors influencing exposure and dose, use of 

surrogate species for toxicity data, field studies, and analysis results for each individual 

herbicide. Refer to this summary, found in Appendix C of this document, for more 

information on analysis methods used to determine the potential effects to wildlife. 

Risk Summary 

Of the herbicides/surfactants proposed for treatment, triclopyr has the highest potential to 

adversely affect wildlife. Clorsulfuron, imazapic, imazapyr, and metsulfuron methyl do not 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

appear to pose any plausible risk to terrestrial wildlife at either the typical or highest 

application rates. Clopyralid and glyphosate, applied at typical application rate have little 

potential to adversely affect birds or mammals. An exception might be insectivorous birds 

that experience chronic exposures of glyphosate. At typical application rates NPE surfactant 

exceeded the acute toxicity index for a small mammal, large mammal and large bird that 

consumed contaminated vegetation, and a small mammal and small bird that consume 

contaminated insects. 

When an herbicide does pose plausible risk, it is consistently insectivorous and grass-eating 

animals that are most likely to receive doses above the toxicity index. Amphibians appear to 

be at higher risk of adverse effects due to their permeable skin and aquatic or semi-aquatic 

life history, although data is very limited or lacking on potential adverse effects of herbicides 

to reptiles and amphibians. There is some data to suggest that amphibians may be as sensitive 

to herbicides as fish (Berrill et al. 1994, Berrill et al. 1997, Perkins et al. 2000), so for the 

purpose of this analysis, herbicides that pose potential risk to federally listed fish (as 

determined by the quantitative estimates from exposure scenarios) will also be considered to 

pose a risk to amphibians. 

Direct spray of mammals is a concern only for NPE surfactants at the typical application rate. 

Fish-eating birds do not receive a dose above the toxicity index for any herbicide or 

application rate. Consumption of contaminated water, even as the result of an accidental spill, 

results in doses well below the toxicity index for all herbicides. Although chronic toxicity 

data on birds is often limited, birds are less sensitive than mammals to acute exposures of the 

herbicides proposed. 

Incomplete and Unavailable Information 

Research has not been conducted on the effects of these herbicides to most free-ranging 

wildlife species, so the relevant data to specifically evaluate effects to different wildlife 

species is incomplete or unavailable. Specific, relevant data that are lacking include: 

• For several herbicide/species group combinations, both NOAEL and LOAEL values have 

not been determined. 

• There is insufficient data to assess risk of chronic exposures for a large grass-eating bird 

or small insect-eating birds and mammals. 

• The toxicity of the herbicides to amphibians, reptiles, terrestrial invertebrates, birds, and 

other animals found in Region Six is either unknown or limited, and cannot be fully 

characterized with the available data on surrogate species. 

• Analysis of effects for any project involving herbicide use relies upon extrapolations 

from laboratory animals to free-ranging wildlife and controlled conditions to the natural 

environment. 

• There are less data available for birds than mammals, so mammal toxicity values must be 

used in bird exposure scenarios for some of the herbicides considered in this EIS. 

Limitations not withstanding, a substantial amount of scientific data on the toxicity of these 

herbicides to birds and mammals, and some amphibians and invertebrates exist. The data are 

generated by manufacturers to meet EPA regulations before an herbicide may be registered 

for use, and by independent researchers that have published findings in peer-reviewed 

literature. So while some data is lacking, adequate information exists to assess potential 

impacts of the herbicides proposed on wildlife. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Toxicity Summary and Assumptions 

The results of the herbicide analysis indicate that birds or mammals that eat vegetation 

(primarily grass) that has been sprayed with herbicide have relatively greater risk for adverse 

effects because herbicide residue is higher on grass than it is on other herbaceous vegetation 

or seeds (Kenaga 1973, Fletcher et al. 1994; Pfleeger et al. 1996). 

• Exposure scenarios do not account for factors such as timing and method of application, 

animal behavior and feeding strategies, seasonal presence or absence within a treatment 

area, or implementation of Project Design Features and therefore exaggerate risk when 

compared to actual applications proposed in this EIS. 

• At proposed application rates the herbicides proposed for use in this document were 

determined to have minimal impacts to wildlife species in the analysis conducted for the 

R6 2005 FEIS (USDA 2005c p. 4-42). For typical application rates and exposures to 

birds and mammals, only broadcast application of triclopyr and NPE surfactants 

produced doses that exceeded acute toxicity indices to wildlife, fish or amphibians. 

However PDFs require that NPE surfactants only be applied at 0.5 pounds of active 

ingredient per acre, which is well below the application rates used in the exposure 

scenarios and triclopyr is restricted to selective methods only. As a result the potential for 

adverse effects to wildlife from herbicide exposure are effectively reduced 

• Aquatic organisms such as frogs would have the same sensitivity to herbicides as fish. 

• All herbicides are excreted rapidly (often within 24-48 hours) and do not bio-accumulate. 

Cumulative Effects 

Potential cumulative effects to wildlife are assessed for each of the alternatives evaluated in 

the FEIS (Alternative Effects below), as well as for the individual species evaluated. For 

species with small home ranges and limited ability to disperse, cumulative effects are 

evaluated within the affected watershed (See species analysis section). However for species 

that are highly mobile or migratory species, the cumulative effects analysis area includes all 

lands within the Wallowa-Whitman proclamation boundary. This area was selected for 

analysis because it contains a diversity of habitat conditions, is large enough to assess species 

with large home ranges as well as migratory species, and would allow for assessment of 

potential impacts on other ownerships. The following assumptions and land use 

considerations were used in the cumulative effect analysis for wildlife. 

• Herbicides are commonly applied on lands other than National Forest System lands for a 

variety of agricultural, landscaping and invasive plant management purposes. Herbicide 

use occurs on tribal lands, state and county lands, private forestry lands, rangelands, 

utility corridors, road rights-of-way, and private property. However there is no central 

source for compiling invasive plant management information off National Forests within 

the State or by water basin, nor is there a requirement for private or corporate land 

owners, or counties to report invasive plant treatment information. As a result an 

accurate accounting of the total acreage of invasive plant treatment for all land 

ownerships is unavailable. 

• Since wildlife move and migrate, some species could be exposed to herbicides on 

adjacent lands or along their migration routes. Species could be exposed to the same 

herbicide on multiple ownerships, or a combination of different herbicides. Wildlife could 

also be exposed to other chemicals, such as insecticides, rodenticides, fungicides, and 

others. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

• Past, present and foreseeable future actions (See Chapater 2) have and will continue to 

contribute to the establishment of invasive weeds. Recreational activity on NFS land is 

expected to increase and on-going activities across all ownerships would continue to 

cause ground disturbances that can contribute to the introduction, spread and 

establishment of invasive plants on NFS lands (USDA, 2005). Wallowa County has an 

active program to treat invasive plants and requires private property owners to control 

invasive plants on their property. 

• Only three watersheds have more than one percent of their total acreage proposed for 

chemical treatment. They are the Middle Imnaha River, the Snake River/Temperance 

Creek and South Fork Burnt RiverWatersheds. Most of the treatment in the Middle 

Imnaha River is the common bugloss site (5500 acres) that would be treated (broadcast 

application of herbicide) the same year the private land would be treated. Also due to 

steep terrain and difficult access, it is likely some of this acreage may not be treated. 

• The herbicides proposed for use a do not significantly bio-accumulate (R6 2005 FEIS). 

For additive doses to occur, two exposures would have to occur at approximately at the 

same time. The application rates and extent considered in this EIS are unlikely to result 

in additive doses beyond those evaluated for chronic and acute exposures in the USDA 

Forest Service risk assessments, which formed the basis for the effects analysis in the 

Region 6 2005 FEIS. 

• Herbicide persistence is managed through PDFs (See Chapter 2) to reduce impacts to 

non-target species and minimize risk of herbicide concentrations of concern near water. 

Effects of treatments each year under early detection-rapid response, by definition, would 

not exceed those predicted for the most ambitious conceivable treatment scenario. This is 

because the PDFs do so much to control the potential for adverse effects and because if 

the most ambitious treatment scenario were implemented, the potential for spread into 

new areas would be greatly reduced. 

• PDFs add a measure of protection for non-target wildlife and SOLI on NFS lands; though 

wildlife may be more vulnerable on other ownerships where protective measures are 

unknown. Potential herbicide treatments that could affect non-target wildlife on NFS 

lands would only occur on a relatively small area (<1% of the analysis area). As a result 

and considering that all herbicides used are excreted within 48 hours, and that 

implementation of PDFs that restrict herbicide use and methods would reduce potential 

for herbicide exposure to non-target wildlife (USDA Forest Service 2008), it is unlikely 

that any proposed treatments would measurably contribute to any other activities on 

private land that would result in significant effects to wildlife. Further, the overall 

positive effect of killing target invasive infestations and maintaining native 

diversity/habitat is far greater than anticipated impacts to non-target wildlife 

Alternative Effects 

Chapter 2 of the EIS provides a detailed description of each of the alternatives considered. 

The following is a summary of the proposed treatments and treatment effectiveness of the no 

action (Alternative A) and action (Alternatives B, C and D) alternatives related to wildlife. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Alternative A - No Action 

Direct Effects 

Alternative A would continue to implement treatments under the existing decisions from the 

Wallowa-Whitman National Forest 1994 Environmental Assessment for the Treatment of 

Noxious Weeds and no new invasive plant treatments would be approved. 

Under this alternative, approximately 23 percent of existing invasive plant infestations would 

be treated. All remaining infested acres currently identified in addition to unknown future 

sites would be treated manually, before herbicides could be used. This would likely require 

multiple years of repeated treatment and associated disturbance to wildlife (described above) 

to achieve control. However because fewer acres are proposed for treatment, this alternative 

would result in less risk of adverse effects to wildlife associated with treatment or herbicide 

exposure. 

Since incorporation of the R6 2005 ROD standards, the no action alternative is now limited to 

three herbicides (glyphosate, triclopyr and picloram with restrictions). Triclopyr has the 

greatest risk to terrestrial wildlife. Plausible scenarios indicate risk to amphibians, deer and 

elk, migratory birds, and small insect eating mammals. However these scenarios assume that 

triclopyr is broadcast sprayed and restrictions under the 1994 EA would limit the use of 

triclopyr and reduce potential impacts to wildlife from herbicide exposure. 

The herbicide effects analysis indicated that glyphosate has the greatest potential for harmful 

doses to amphibians. The surfactant found in some glyphosate formulations is particularly 

toxic to aquatic species. However management direction in this alternative severely restricts 

herbicide use in aquatic amphibian habitat, making this scenario less likely to occur. 

Since fewer treatment and herbicide options would be available, “lower risk” herbicides 

would not be available. For example, chlorsulfuron, clopyralid, imazapic, imazapyr, 

sulfometuron methyl and sethoxydim pose fewer risks to wildlife (See Table 27) and can be 

effectively used to control many of the invasive plant species that currently occur on the 

Forest. Because these are not approved for use under this alternative, herbicides with higher 

risk to non-target wildlife such as triclopyr, glyphosate and picloram would have to be used. 

Invasive plant treatments will not alter native habitat structure or composition for terrestrial 

wildlife species, including MIS, TES, or the Partners in Flight strategy for landbirds (Altman 

2000). In some cases, removal of invasive plants could cause a localized decrease in the 

amount of vegetative cover provided. However due to the scattered nature of the invasive 

plant infestations, the amount of cover lost would be small and of limited extent. Unlike other 

management activities, such as grazing or timber harvest, invasive plant treatments do not 

reduce habitat available to native wildlife. Likewise, prey availability would not be reduced 

because invasive plants are located in relatively small patches, or along narrow road 

corridors, within and adjacent to the much larger natural habitats in which the prey reside. 

Indirect Effects (Treatment Effectiveness) 

Under the No Action approximately 23 percent of existing invasive plant infestations would 

be treated. Also this alternative provides only manual methods for EDRR strategy to treat 

newly identified infestations. Past monitoring of these treatment methods (Yates 2006) 

indicates that these methods may be effective for controlling small populations of certain 

plants and may pose less risk to non-target wildlife compared to herbicide treatments. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Conversely the absence of a more effective EDRR strategy increases potential for new 

invasive plant infestations to establish and spread. Because all remaining infested acres in 

addition to any new sites would be treated manually, multiple years of repeated re-treatment 

would likely be necessary to contain or eradicate infestations. 

Alternative A does not approve the use of biocontrol. Biocontrol agents that currently are 

present within or adjacent to the forest could move onto forests lands and provide some level 

of control, however, it would likely take a number of years and control is subject to target 

species and appropriate biocontrol agent presence. These less effective methods of control 

would likely lead to the continued displacement of native plant species and the increased 

spread potential of invasive plants currently infesting the forest. 

Because this alternative fails to treat 77 percent of existing infestations, limits EDRR 

treatments to less effective manual methods, and would not propose use of more effective 

herbicides, it is estimated that treatment would only be approximately 25 percent to 35 

percent effective. Roads would continue to act as vectors that facilitate the spread of invasive 

plants. Consequently under this alternative, invasive plants would continue to spread across 

the Forest (See Figure 16) and reduce native plant diversity, reducing wildlife forage and 

cover within the affected watersheds. 

Because invasive plants would continue to increase under this alternative, adverse effects to 

wildlife habitat would be greatest for early successional species and species that utilize 

grasslands, meadows, riparian habitat or open canopy mature forest susceptible to invasive 

plant infestations. 

Cumulative Effects 

This alternative is covered under previous NEPA projects. Treatments would occur on an 

extremely small percentage of any watersheds in the action area. Due to the small amount of 

acreage proposed for treatment, short-term nature of effects and considering that treatments 

would be spread out over 33 watersheds, Alternative A would not measurably contribute to 

any other past, current or reasonably foreseeable future activity that may be impacting 

wildlife and there are no significant cumulative impacts to wildlife anticipated. 

Alternative B - Proposed Action 

Direct Effects 

Treatments proposed under this alternative are displayed in Table 36. Under this alternative 

all currently mapped invasive plant species would be treated with the most effective treatment 

types and methods necessary to control, contain or eradicate invasive plants, including the 10 

newly approved herbicides and surfactants approved in the R6 2005 FEIS. 

A total of 13,556 acres of upland habitat would be treated under this alternative using a 

combination of manual, mechanical or chemical treatments, 111 acres would be treated using 

only manual methods and 1,955 acres would be treated using bio-control. Effects of manual, 

mechanical and bio-control treatments are the same as described above under treatment 

effects. 

Herbicides proposed under this alternative include chlorsulfuron, clopyralid, glyphosate, 

imazapic, imazapyr, metsulfuron methyl, picloram, sethoxydim, sulfometuron methyl, and 

triclopyr. A total of 3,241 acres of riparian habitat would be treated using spot techniques 

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only. Spot spray and selective treatments are explicitly not considered high risk (USDA-FS 

2005); therefore, potential for adverse effects from herbicide exposure would be greatly 

reduced on this acreage. Relative risk of these herbicides to non-target wildlife from 

broadcast applications of herbicides is displayed in Table 37 and discussed above under 

herbicide toxicity and risk. As described previously, PDFs identified in Chapter 2 were 

specifically designed to reduce potential for adverse effects associated with herbicide 

exposure. The following is a summary of possible adverse effects from broadcast application 

of herbicides under this alternative, as well as specific PDFs and their anticipated 

effectiveness at reducing effects to non-target wildlife: 

Prior to treatment, species/habitats of local interest will be confirmed to determine the type 

and method of treatment (A-1). This assessment will ensure that applicable PDFs are 

implemented, identify any known risks to species or habitats of local interest and modify 

treatment methods/timing if necessary to reduce potential risks to these species/habitats. 

No broadcast application of herbicide or surfactant will exceed typical label rates (F-4). At 

typical application rates proposed only triclopyr and NPE surfactant resulted in an acute 

exposure that exceeded the reported NOAEL, whereas triclopyr also resulted in possible 

chronic exposures to large mammals and birds and small carnivorous mammals. However 

these scenarios assume broadcast application and implementation of (F-1) restricts the use of 

triclopyr to spot spray and selective techniques only. Also NPE would not be broadcast at a 

rate greater than 0.5 lbs of active ingredient per acre (F-4) (which is well below typical 

application rates). As a result implementation of these PDFs would effectively reduce the 

possibility that any terrestrial wildlife species would receive an acute toxic dose of 

herbicide/surfactant, or a chronic dose of triclopyr or NPE. 

Although data is lacking, if effects are assumed by comparing acute dose vs. chronic 

NOAEL, at typical application rates chronic exposures to insectivorous birds and mammals 

identified in the SERA risk assessments are possible for clopyralid, glyphosate, picloram, 

sethoxydim and sulformeturon methyl; however this is a conservative approach that will 

likely over-estimate risk. Exposure scenarios do not account for factors such as timing and 

method of application, animal behavior and feeding strategies or implementation of PDFs and 

therefore exaggerate risk when compared to actual applications proposed in this EIS. For 

example, in addition to PDFs described above, herbicide applications would only occur on 

the minimum area necessary (F-1) and potential impacts are further reduced by PDFs that are 

designed to reduce drift during treatment including; 1) avoiding herbicide applications during 

inversions or windy conditions (F-5), 2) restricting use of sulfonylurea herbicides 

(chlorsulfuron, sulfometuron methyl and metsulfuron methyl on dry or sandy soils (F-7) and 

3) using only low nozzle pressure and a coarse spray during application (F-6). Research has 

shown that by simply changing the type of nozzle (diameter of pore size) used during 

broadcast treatments, the drift potential of herbicide can be effectively and substantially 

decreased (USDA Forest Service 2008). Additionally, the herbicides do not bio-accumulate 

and most breakdown fairly quickly. Consequently an individual would have to encounter 

recently contaminated vegetation for 90 days under most circumstances to actually receive 

chronic doses modeled in the risk assessment. Exposure is further reduced considering that 

(1) invasive plants do not provide preferred habitat/forage, (2) that only 1% of the analysis 

area is proposed for treatment and that treatment areas are widely scattered and interspersed 

with pockets of un-treated suitable habitat (3) that the physical disturbance associated with 

treatment would likely scare off birds or mammals in the area and (4) that foliar interception 

would prevent many insects from being contaminated. Collectively for these reasons, it is 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

highly unlikely that chronic exposures to herbicides would occur from proposed application 

of any herbicide under this alternative. 

A total of 875 acres are proposed for aerial application of herbicides under this alternative. 

Because aerial treatment increases the potential for herbicide exposure, particularly for 

insectivorous or grass eating birds and mammals, in addition to application restrictions 

described previously, several PDFs are in place to reduce potential adverse effects to nontarget species from aerial application of herbicides including; 1) aerial application would not 

be used for EDRR treatments (F-8a), 2) chlorsulfuron, methsufuron methyl, sulfometuron 

methyl and triclopyr will not be applied aerially (F-8b) and aerial application rates of 

Picloram would only be applied at levels below typical application rates (F-8o), 3) buffer 

distances for federally listed SOLIs will follow Recovery Plan recommendations and no 

aerial application will occur within 300 feet of non-federally listed SOLIs (F-8g), 4) aerial 

spray units will adhere to aquatic habitat buffers (F-8f) and aerial swath displacement buffers 

would be applied as needed (F-8n), 5) aerial spraying would not occur in areas with 30 

percent or more live tree cover and spraying in areas between 10 and 29% canopy cover 

would require an on-site decision (F-8h), 6) aerial spray units will be ground checked, GPS’d 

prior to spraying and a GPS system will be used in spray helicopters to ensure that only areas 

targeted are treated (F-8i). Also, constant communication will be maintained between the 

helicopter and ground observers to monitor drift and deposition of herbicide (F-8m) and 7) all 

projects involving aerial application will implement effectiveness monitoring to ensure 

impacts to non-target species are within acceptable tolerance (F-8e). 

Potential impacts from aerial spraying to wildlife are further reduced by the fact that all but 

32 acres would occur on sites that are infested with yellow star-thistle. This species is 

aggressive and can form dense near-monotypic infestations (Ditomaso 2006); therefore, it can 

greatly reduce native plant diversity. As a result, it is unlikely that any species would be 

utilizing these areas for forage or cover or be exposed to toxic levels of herbicide. Prior to 

treatment, all currently proposed and potential future infestation will undergo a site specific 

long-term strategy for restoring/revegetating invasive plant treatments (USDA Forest Service 

1990 as amended by the R6 2005 ROD). Also cooperation with public and private 

landholders is anticipated on presently proposed aerial sites, which would further increase the 

effectiveness of treatments and reduce the potential spread across adjacent ownerships. 

Collectively for these reasons and with implementation of the above PDFs, potential adverse 

impacts to wildlife from aerial spraying would be greatly reduced and the potential for 

adverse effects associated with aerial application of herbicides is low. 

A total of 3,104 acres of broadcast application of herbicides within riparian areas would occur 

under this alternative and potential exists for herbicide exposure to riparian dependent 

wildlife, amphibians and the aquatic resource. However; 1) herbicide use buffers (F-3, H-1, 

H-2, H-3, H-8, H-10 through H-12) virtually eliminate the potential for herbicide to be 

delivered to streams in concentration of concern (USDA Forest Service 2008), 2) herbicide 

restrictions on certain soil types (H-4 through H-7) reduce potential for run off and leaching, 

3) restrictions on extent of treatment in a given site condition (i.e. aquatic influence zone, H-9 

and H-13) ensure that herbicides would not be delivered in amounts greater than the SERA 

risk assessment scenarios and reduce potential of harm to amphibians (USDA Forest Service 

2008) and riparian dependent wildlife, and 4) spills are extremely unlikely to occur given the 

many safety precautions in place (Bulkin, personal communication). As a result and based on 

monitoring of similar treatments (Berg 2004), implementation of these PDFs would ensure 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

that adverse effects to fish, amphibians and the aquatic resource are avoided (USDA Forest 

Service 2008). 

EDRR to newly identified infested areas would follow the decision process (as described in 

Figure 12 of Chapter 2) for treating invasive weeds. Over time it is expected that herbicide 

use would be reduced as known sites are effectively controlled and EDRR methodologies 

eradicate new invasive sites. Maximum annual treatment including known sites and new sites 

is 8,000 acres. 

Most invasive plant infestations occur in open areas; therefore, potential effects to species 

that utilize forested areas are minor. Conversely, the largest amount of treatment is proposed 

in non-forest, early-successional habitat and open canopy forested habitats and species that 

utilize these habitats are at greater risk from treatment/herbicide exposure. The use of 

herbicides represents potential risks to wildlife; however in practice, PDFs described above as 

well as the environmental conditions and animal behavior greatly reduce actual impacts. 

In summary, Alternative B represents more than a four-fold increase in acres of potential 

herbicide treatment compared to Alternative A. Also, due to proposed aerial application and 

broadcast application within riparian areas, potential for herbicide exposure would be greatest 

under this alternative. However taken together, implementation of the PDFs described above 

eliminate potential for adverse effects to species of local interest (USDA-FS 2008) and 

effectively reduce potential risks to non-target wildlife and the aquatic resource. As a result 

and considering the small amount of habitat (1% of the Forest) and scattered nature of 

treatments (spread out over 53 watersheds (5th level HUC), 8,000 acres per year represents a 

negligible risk to wildlife. 

Indirect Effects 

Although there may be localized, short-term effects to habitat due to proposed treatments 

(See treatment effects), like Alternative A, invasive plant treatments are not expected to alter 

the structure or compositions of wildlife habitat. Indirect effects under this alternative are 

primarily related to control of invasive plants and restoration of wildlife habitat. 

It is estimated that treatments proposed under this alternative would be approximately 90 

percent effective at controlling invasive plants. Alternative B provides the most effective 

means for reducing invasive plant species on the Forest, because more sites and acres will be 

approved for treatment using more effective methods. As a result, the proposed action would 

be expected to rehabilitate the greatest amount of wildlife habitat.This rehabilitation would 

restore native vegetation and preferred wildlife cover and forage, and result in the long-term 

maintenance of native plant and wildlife habitat diversity across the Forest. 

Cumulative Effects 

The cumulative effects analysis area and potential cumulative effects to wildlife are described 

above. As described, proposed herbicide treatments on other lands within the cumulative 

effect analysis area will increase the likelihood for herbicide exposure to highly mobile 

wildlife. 

• Although data is lacking that would permit any quantitative estimates of cumulative 

exposure or risk, treatments proposed under this alternative would affect less than 1 

percent of the analysis area. Consequently the additive effects from herbicide exposure 

are not likely to occur, or would be minimal. As a result, and based on the above analysis 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

for this alternative, cumulative effects considerations identified above and the following 

rationale, implementation of Alternative B, would not measurably contribute to any other 

past, present or reasonably foreseeable future activity that would result in significant 

effects to wildlife. 

• Less than 1 percent of the analysis area would be affected by treatment; sites would be 

widely scattered across 53 watersheds. Consequently, unaffected habitat would be widely 

available within all affected watersheds, reducing the likelihood that wildlife would be 

adversely impacted. 

• The herbicides proposed for use a do not significantly bio-accumulate (R6 2005 FEIS). 

For additive doses to occur, two exposures would have to occur at approximately the 

same time (24-48 hours). The application rates and extent considered in this EIS are 

unlikely to result in additive doses beyond those evaluated for chronic and acute 

exposures in the USDA Forest Service risk assessments, which formed the basis for the 

effects analysis in the R6 2005 FEIS. 

• With implementation of PDFs, potential for herbicide exposure to wildlife is greatly 

reduced. 

• Adverse effects anticipated would be offset by the long-term benefits of maintaining 

wildlife habitat and native plant species diversity. 

Alternative C 

Direct and Indirect Effects 

Under Alternative C all currently mapped invasive plant species would be treated the same as 

the proposed action; however, no broadcast treatment methods would occur in riparian areas 

(3,104 acres, Table 36). Treatment within these areas would include chemical treatments such 

as spot, wicking and wiping, as well as manual and mechanical methods. This would reduce 

the potential riparian dependent wildlife to be exposed to herbicides. Although disturbance in 

these areas may increase due to the longer period of time necessary for application, the 

manual methods used would decrease the likelihood of mortality to less mobile species/nests. 

Direct effects to wildlife on 13,556 acres proposed for ground based treatment on upland 

sites, 875 acres proposed for aerial treatment, 111 acres proposed for manual only treatment 

and 1,955 acres of bio-control would be similar to those described under Alternative B. 

Because the same acreage is proposed for treatment, estimates of annual treatment acres 

would also be similar and as described under Alternative B, implementation of PDFs would 

be expected to protect SOLI and reduce impacts to non-target wildlife. 

EDRR to newly identified areas would occur and follow the decision process in Chapter 2. 

However under this alternative future treatment within riparian areas would not include 

broadcast application of herbicides and potential of herbicide exposure from future treatments 

within riparian areas would be reduced under this alternative. 

The elimination of ground based broadcast treatment within riparian areas may reduce the 

effectiveness of treatment in some areas because treatments would be directed only on 

existing plants. As a result, any potential new invasive recruits from seedbanks or other 

underground parts would need to be treated as they emerge in future years. Repeated 

treatments over multiple years would be needed to treat these areas and effective control, 

eradication or containment is likely questionable under certain circumstances. Consequently 

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there may be increased potential for spread in riparian and adjacent upland areas from some 

sites. 

Although this alternative may reduce treatment effectiveness of some riparian treatments, all 

riparian sites would be treated and the overall effectiveness of Alternative C is similar to 

Alternative B. As a result, implementation of this alternative would restore native vegetation 

and preferred wildlife cover and forage on sites affected by invasive plants and result in the 

long-term maintenance of native plant and wildlife diversity across the Forest. 

Cumulative Effects 

Although risks to some wildlife would be reduced within riparian areas, cumulative effects 

under Alternative C would be the same as those described under Alternative B and 

implementation of Alternative C would not measurably contribute to any other past, current 

or reasonably foreseeable future activity that would result in significant effects to wildlife. 

Alternative D 

Direct and Indirect Effects 

Under Alternative D all currently mapped invasive plant species would be treated the same as 

Alternative B, except no aerial treatment methods would be allowed on any proposed or 

future infested acres. Direct effects to wildlife on 13,556 acres proposed for ground based 

treatment on upland sites, 3,104 acres of riparian broadcast chemical, spot herbicide, manual 

and mechanical treatment, 3,241 acres of riparian chemical spot treatment only, and 111 acres 

proposed for manual only treatment would be similar to those described under Alternative B. 

Although there is a small reduction in total acres treated, estimates of annual treatment acres 

would also be similar and as described under Alternative B, implementation of PDFs would 

be expected to protect SOLI and reduce impacts to non-target wildlife. 

Under this alternative 875 acres proposed for aerial spraying would be treated using biocontrols. Of this acreage, 96 percent is infested with yellow starthistle and over the past 6-10 

years, success of bio control methods on this species has been variable and adequate control 

has not occurred on all sites (D’Antonio 2007). Also some future sites would likely go 

untreated due to safety concerns and/or access. As a result and considering that sites 

proposed for aerial application contain high priority, aggressive invasive plant species 

(yellow starthistle, and scotch thistle), it is possible that invasive plants would continue to 

increase in these areas. 

This alternative would reduce the likelihood that species that utilize steep, rugged terrain and 

open grassland would be adversely affected by herbicide treatment. This alternative would 

reduce treatment effectiveness in these areas; however, the overall effectiveness of 

Alternative D is similar to Alternative B and significantly greater than that of Alternative A. 

As a result, implementation of this alternative would restore native vegetation and preferred 

wildlife cover and forage on sites affected by invasive plants and result in the long-term 

maintenance of native plant and wildlife diversity across the Forest. 

Cumulative Effects 

Although risks to wildlife would be reduced somewhat because no aerial treatment would 

occur, cumulative effects under Alternative D would be the same as those described under 

Alternative B and implementation of Alternative D would not measurably contribute to any 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

other past, current or reasonably foreseeable future activity that would result in significant 

effects to wildlife. 

Species Analysis Section 

This section provides an analysis of the alternative effects on TES, MIS, and species/habitats 

of local interest. Nine species including the Canada lynx, Pacific fisher, horned grebe, 

bufflehead, greater yellowlegs, upland sandpiper, tricolored blackbird, bobolink and northern 

leopard frog have not been recently documented on the Forest (See Affected Environment 

Section) or will not occur within treatment areas. As a result, there are no effects to these 

species under any alternative and they will not be discussed further in this analysis. 

Additional information on these species is provided in the wildlife report. 

Species and anticipated effects considered in this analysis are summarized in Table 37. Based 

on the analysis provided, all species and habitats evaluated also include a final determination 

related to potential impacts (TES species), anticipated effects to local populations and 

distribution on the Forest (MIS and SOLI), or effects to priority and unique habitats 

(identified in Altman 2000). These determinations, as well as the rationale used to make the 

final determination are summarized in Table 37. 

Table 37-Wildlife Determination Summary 

Species/Habitat Determination 

All Alternatives 

Rationale 

Threatened and Endangered Species 

Canada lynx No Effect Forest is unoccupied habitat. Not present in 

treatment areas. 

Gray wolf NLAA1 

Wolves are extremely rare; PDFs minimize potential 

for disturbance and exposure to herbicides. Habitat 

for prey maintained.3 

Sensitive Species 

California wolverine No Impact 

Not likely to be present in treatment areas. PDFs 

and foraging behavior minimize potential for 

adverse effects from herbicide exposure and 

disturbance. 

Pacific Fisher No Impact No recent documentation on the forest. Not present 

in treatment areas. 

Rocky Mountain 

Bighorn Sheep MINL2 

Small amount of suitable habitat proposed for 

treatment. Short-term disturbance possible. PDFs 

minimize potential for adverse impacts from 

herbicide exposure. Maintenance of foraging 

habitat3. 

Spotted Bat No Impact 

PDFs and foraging behavior effectively eliminate 

potential for adverse effects from herbicides. No 

treatment effects anticipated. Foraging habitat 

maintained3 

Horned grebe In Impact No documented breeding. Not present in treatment 

areas. 

Bufflehead No Impact No documented breeding. Not present in treatment 

areas. 

Bald eagle MINL2 

No nest habitat adversely affected. PDFs minimize 

potential for adverse effects to roosting and 

foraging birds from herbicide exposure and 

disturbance. 

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Determination Species/Habitat Rationale 

All Alternatives 

American peregrine 

falcon MINL2 

No nest habitat adversely affected. PDFs minimize 

potential for adverse effects to foraging birds from 

herbicide exposure and disturbance. 

Greater sage grouse No Impact 

No documentation on the forest and not likely to be 

present in treatment areas. Small amount of 

suitable habitat proposed for treatment. PDFs 

minimize potential impacts to nesting and foraging 

birds and herbicide exposure. Preferred 

cover/forage maintained. 3 

Columbia sharp-tailed 

grouse No Impact 

Not documented on the forest and unlikely to occur 

within treatment areas. PDFs minimize potential 

impacts from herbicide exposure, disturbance and 

mortality. Small amount of suitable habitat proposed 

for treatment. Preferred cover/forage improved. 3 

Greater yellowlegs No Impact No documented breeding on the forest. Not present 

in treatment areas. 

Upland sandpiper No Impact No documentation on the forest. Not present in 

treatment areas. 

Gray flycatcher MINL2 

Small amount of suitable habitat proposed for 

treatment. PDFs minimize potential for adverse 

effects from herbicide exposure, disturbance and 

mortality. 

Tricolored blackbird No Impact No documentation on the forest. Not present in 

treatment areas. 

Bobolink No Impact No documentation on the forest. Not present in 

treatment areas. 

Northern Leopard frog No Impact No documentation on the forest. Not present in 

treatment areas. 

Columbia spotted frog MINL2 

No occupied habitat affected. Small amount of 

suitable habitat proposed for treatment. PDFs 

minimize potential for adverse effects from 

herbicide exposure and disturbance/mortality. 

Riparian/wetland habitat improved. 3 

Painted Turtle No Impact 

No documentation on the forest and unlikely to 

occur within treatment areas. Small amount of 

suitable habitat proposed for treatment. PDFs 

minimize potential for adverse effects from 

herbicide exposure and disturbance/mortality. 

Riparian/breeding habitat maintained. 3 

Management Indicator Species 

Rocky mountain elk 

No effects to local 

populations; 

Distribution and use 

of the Forest 

maintained. 

Short-term disturbance; implementation of PDFs 

and widely scattered nature of treatment areas 

make adverse effects associated with herbicide 

exposure unlikely; long-term maintenance of 

suitable habitat3 

Northern goshawk 

Pileated Woodpecker 

No effects to local 

populations; 

Distribution and use 

of the Forest 

maintained. 

No treatments proposed within preferred nest 

habitat. Short-term disturbance to foraging birds. 

PDFs, habitat requirements and foraging behavior 

minimize potential for adverse effects from 

herbicide exposure. 

Cavity Excavators 

No effects to local 

populations; 

Distribution and use 

of the Forest 

maintained. 

Small amount of habitat proposed for treatment. 

Short-term disturbance possible. PDFs, habitat 

requirements and foraging behavior minimize 

potential for adverse effects. 

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197 

Species/Habitat Determination 

All Alternatives 

Rationale 

Pine Marten 

No effects to local 

populations; 

Distribution and use 

of the Forest 

maintained. 

Not likely to be in treatment areas. Short-term 

disturbance possible. PDFs and foraging behavior 

minimize potential for adverse effects. 

Landbirds and Partner In Flight Habitat 

Landbirds 

No effects to local 

populations or 

distribution across the 

Forest. 

Scattered treatment areas, small amount of 

treatment within any single vegetative community 

and PDFs reduce risks and minimize potential for 

herbicide exposure. 

Dry Forest, Riparian 

woodland/shrub, 

Steppe Shrubland, 

mountain meadow 

Ecological community 

and habitat for 

associated species 

maintained or 

improved. 

Treatments would reduce invasive plants and 

maintain native plant and wildlife diversity. 3 

Mesic Mixed Conifer, 

subalpine forest, 

aspen, alpine 

No change to the 

ecological community 

or associated wildlife. 

Invasive plants do not threaten this community and 

little or no treatments are proposed. 

1 – NLAA - Not Likely To Adversely Affect 

2 – MINL - May Impact Individuals or Habitat, but Not Likely to cause a trend in federal listing or a loss of viability. 

3 – Maintenance/Improvement would only occur under the Action Alternatives 

3.3.5 Effects to Threatened, Endangered and Sensitive (TES) 

Species 

Gray Wolf 

Table 36 displays the treatment method and the acreage proposed for treatment under each of 

the alternatives. While occasional wolf sightings have been reported, there are no known 

established packs and no den or rendezvous sites on the Forest. Consequently suitable habitat 

consists of foraging and dispersal habitat, which is widespread across the Forest. 

Effects of treatments, biological control, EDRR, and herbicide application/exposure are 

discussed under the Wildlife Effect Section. The following discusses alternative effects 

specific to the gray wolf. 

Direct Effects of Treatments 

Alternatives A through D 

Direct effects from invasive plant treatment include disturbance caused by noise, aircraft, 

people and vehicles, which are activities common to manual and mechanical methods. These 

activities could potentially disturb gray wolves. However, invasive plant projects involve 

very short-term disturbance with few people and might only be repeated once in the same 

growing season. Also all sites would be evaluated prior to treatment (A-1) and if it is 

determined that wolves could be present, treatment methods/timing would be modified to 

avoid possible adverse effects. As a result the potential for disturbance is remote. 

Currently wolves may be transient within the action area and are unlikely to encounter any 

individual project. Although wolves will travel over large distances, they are most likely to 

occur in wilderness and roadless areas, away from human disturbance. These areas tend to 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

have minimal invasive plant infestations so the likelihood of disturbance would be remote. 

The life history traits of the species, current literature, existing guidelines, and expert opinion 

of biologists familiar with the species (Gaines, pers. comm.; Naney, pers. comm.) indicate 

that the level of disturbance expected from any invasive plant project is not likely to 

adversely disturb the gray wolf. In addition PDF (J2a-c) restricts activities in close proximity 

to known denning or rendezvous sites, should a pack become established on the Forest. 

Herbicides 

Alternatives A though D 

Exposure scenarios used to analyze potential effects from herbicides are discussed in 

“Summary of Herbicide Effects to Wildlife” Appendix P, and in R6 2005 FEIS, Appendix P 

and discussed above. Small mammals are not the typical prey item for wolves. Nonetheless, 

the scenario in which a medium-sized canid eats small mammals that have been directly 

sprayed was used to evaluate a general risk to carnivores from herbicide use. At typical and 

highest application rates, the estimated doses from the exposure scenario are all less than the 

reported NOAELs for all herbicides except triclopyr. However these scenarios are based on 

broadcast application that would directly spray an entire day’s diet of small mammals. 

Because PDFs restrict the use of triclopyr to spot spray and selective application techniques, 

there are no adverse impacts to gray wolves from the use of triclopyr anticipated under any 

alternative. At the highest application rate, NPE exceeded the toxicity index for chronic 

exposure. However PDF F-4 requires that NPE only be broadcast sprayed at levels below 

typical application rates and no adverse impacts from this surfactant are anticipated. 

Alternative B 

Under Alternative B a total of 22,842 acres of potentially suitable foraging/dispersal habitat 

could be treated, including 875 acres of aerial spraying and 3,104 acres of riparian habitat that 

could be broadcast sprayed. Because this alternative would treat the largest amount of 

suitable habitat and because treatment involves aerial application of herbicides, as well as 

broadcast application of herbicides within riparian habitat, the potential for herbicide 

exposure to the gray wolf (described above) would be greatest under this alternative. 

However, because of the small amount of suitable habitat proposed for treatment (<1%), the 

infrequent occurrence of this species and with implementation of PDFs, it is unlikely that 

adverse effects associated with herbicide exposure would occur to the gray wolf. 

Alternatives C and D 

Treatments proposed under Alternative C and the associated effects (described above) would 

be similar to Alternative B, except that herbicide application within riparian areas would be 

restricted to selective techniques only. Any treatment in these areas (selective or broadcast) 

would result in disturbance to wolves if they were present during treatment. However because 

wolves would utilize riparian corridors for dispersal and foraging, potential for herbicide 

exposure under this alternative would be reduced on 3,104 acres. 

Treatments proposed under Alternative D and the associated effects (described above) would 

be similar to Alternative B, except that no aerial application of herbicides would occur. Sites 

proposed for aerial application typically occur in steep, rugged terrain that would provide 

suitable dispersal/foraging habitat for wolves. Any treatment in these areas (aerial or ground 

based) would result in disturbance to wolves if they were present during treatment. However 

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because these sites would be treated using bio-control methods, potential for herbicide 

exposure would be reduced on this acreage. 

Early Detection Rapid Response 

Alternatives A through D 

Although treatment method would vary (See Alternative Comparison above), future 

treatments to new infestations could occur within suitable gray wolf habitat under these 

alternatives. If this occurs, additional disturbance (All alternatives) and/or herbicide exposure 

(Alternatives B, C and D only) could occur. Future herbicide treatments would use the same 

herbicides and comply with the same PDFs/management restrictions as currently proposed 

treatments, or if necessary in a new NEPA document. Consequently effects from future 

treatment under EDRR are the same as described for current infestations and it is unlikely 

adverse effects would occur under any alternative. 

Indirect Effects 

Alternative A 

Not all sites currently infested with invasive plants would be treated under this alternative. 

Also EDRR treatment is restricted to less effective manual treatments. While this would help 

to contain invasive plants in some locations, invasive plants would continue to expand in 

untreated areas. As a result and considering that more effective herbicides are not approved 

for treatment, invasive plants would continue to reduce habitat for deer and elk (wolf prey) 

within affected watersheds. 

Alternative B through D 

These alternatives will treat similar acreages of existing invasive weed infestation and include 

herbicides during EDRR to control future infestations. Although herbicides would not be 

applied aerially under Alternative D, or broadcast sprayed within riparian areas under 

Alternative C, control between alternatives would be similar. As a result all three alternatives 

are expected to reduce invasive weed infestation across the Forest and maintain wolf foraging 

habitat. 

Cumulative Effects 

Alternatives A through D 

Anticipated cumulative effects to wildlife are discussed above and include possible exposure 

to herbicides and on-going land uses on other ownerships and continued disturbance 

associated with recreation and other forest uses on NFS lands. As wolves move into Oregon, 

they will be subject to the same pressures and conflicts with humans that occur in Idaho, 

Wyoming and Montana. The projected increases in population for Oregon will likely increase 

recreation on the National Forests. This could increase human disturbance and potential 

sources of mortality to wolves. Also because wolves travel large distances, it is possible that 

they would be exposed to herbicides on other ownerships. However as described above under 

the cumulative effect section, proposed herbicides do not bio-accumulate and it is unlikely 

that additive doses beyond those evaluated would occur. Also over 99% of the suitable wolf 

habitat on the Forest would be left un-treated. As a result and considering that 

implementation of PDFs would greatly reduce potential impacts from treatment and herbicide 

exposure, implementation of any of the alternatives evaluated would not measurably 

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contribute to any other past, current or reasonably foreseeable future activity that would result 

in significant effects to the gray wolf. 

Summary of Effects and Determination for the Gray Wolf 

Alternative A 

This alternative would not reduce invasive plants within suitable gray wolf foraging habitat. 

Proposed treatments could result in short-term disturbance to wolves that may be near a site 

during treatment. However, 99 percent of the forest would be unaffected and management 

restrictions would reduce the likelihood of adverse effects associated with herbicide 

treatment. As a result implementation of Alternative A may affect, but is not likely to 

adversely affect the gray wolf. 

Alternatives B through D 

Treatments under all alternatives have the potential to result in short-term disturbance to the 

gray wolf. While potential exposure of the gray wolf to herbicide varies by alternative, due to 

the infrequent occurrence of this species on the Forest and considering it would likely avoid 

areas proposed for treatment, the risk of herbicide exposure is remote under all alternatives. 

Also due to the pre-treatment assessment (A-1) and with restrictions to treatments near den or 

rendezvous sites (J-2), it is unlikely wolves would be adversely affected by proposed 

treatments under any alternative. As a result and based on the above analysis and the 

following rationale, implementation of Alternatives B through D may affect, but are not 

likely to adversely affect the gray wolf. 

• The R6 2005 FEIS prevention standards will help to protect foraging habitat of their prey 

from invasive plants 

• Distribution of gray wolves within the infested areas would likely be very limited, and 

sporadic, so the opportunity for wolves to be in or near treatment areas is remote. 

• Disturbance from invasive plant treatment projects is low level, short duration, and 

infrequent. While disturbance could occur, wolves are uncommon on the Forest and it is 

unlikely that disturbance would be of a magnitude or intensity that would result in 

adverse effects. 

• It is unlikely that doses of any herbicides from proposed treatments would exceed the 

reported NOAEL. 

3.3.6 Effects to Sensitive Species 

California Wolverine 

As described under the Affected Environment Section, California wolverine is not currently 

known to occur on the Forest; however, a number of unconfirmed sightings have occurred. 

The Forest contains 586,780 acres of preferred remote wilderness habitat including 979 acres 

that are infested with invasive plants. As a result, effects of proposed treatments on the 

California wolverine were evaluated. 

Most of the existing wilderness areas containing invasive plants would be treated under 

Alternatives B through D, whereas no treatments within wilderness would occur under 

Alternative A. 

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Effects of treatment, biological control, site restoration/re-vegetation, EDRR and herbicide 

application/exposure are discussed under the Wildlife Effect Section. The following discusses 

alternative effects specific to the California wolverine. 

Direct Effects of Treatments 

Alternatives A through D 

Direct effects from invasive plant treatment are discussed under the Wildlife Effect Section 

and include short-term disturbance caused by noise, people and vehicles. However the 

wolverine is often characterized as a wilderness species whose persistence is linked to the 

presence of large areas of low human population density. Also this species has not been 

documented on the forest and if it occurs would occur in vary low numbers. As a result it is 

unlikely they would occur within treatment areas and no adverse effects are anticipated. 

Herbicides 

Alternatives A through D 

Although wolverine often utilize big game carrion, the potential for exposure of wolverine to 

herbicides was evaluated using the scenario in which an individual would consume an entire 

days diet of prey that has been directly sprayed on 50 percent of its body surface. At typical 

application rates there are no herbicides that exceeded the toxicity index for an acute 

exposure to carnivorous mammal. At the highest application rate triclopyr can result in a 

chronic exposure and worst-case exposure for this species (carnivorous mammal in Appendix 

B) exceeds the toxicity index from ingesting prey that has been sprayed with triclopyr or 

NPE. However these scenarios are based on broadcast application and under the action 

alternatives use of triclopyr is restricted to spot spray and selective techniques only (F1). 

Also NPE would only be broadcast at a rate well below the typical application rate (F4). 

Potential for exposure of wolverines to be exposed to herbicides is further reduced by the fact 

that they prefer forested areas that are less likely to contain invasive plants, avoid areas of 

human activity and if they occur at all, would occur in very low numbers. As a result potential 

for herbicide exposure is greatly reduced. 

Alternatives B and D 

There is no aerial application proposed within wilderness areas under Alternative D. Because 

these areas would be preferred by wolverine, there is little difference between these 

alternatives. A total of 979 acres of potentially suitable foraging/dispersal habitat could be 

treated, including 703 acres of riparian habitat that could be broadcast sprayed. Because these 

alternatives would use broadcast application of herbicides within riparian habitat, the 

potential for herbicide exposure to the California wolverine (described above) would be 

greatest under these alternatives. 

Alternatives C 

Treatments proposed under Alternative C and the associated effects (described above) would 

be similar to those under Alternatives B and D, except that herbicide application within 

riparian areas would be restricted to selective techniques only. Any treatment in these areas 

(selective or broadcast) would result in disturbance to wolverine if they were present during 

treatment. Also because wolverine would utilize riparian corridors for dispersal and foraging, 

potential for herbicide exposure under this alternative would be reduced on 979 acres. 

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Early Detection Rapid Response 

Alternatives A through D 

Although treatment method would vary (See Alternative Comparison above), future 

treatments to new infestations could occur within suitable wolverine habitat under these 

alternatives. If this occurs, additional disturbance (All alternatives) and/or herbicide exposure 

(Alternatives B, C and D only) could occur. Future herbicide treatments would use the same 

herbicides and comply with the same PDFs/management restrictions as currently proposed 

treatments, or if necessary in a new NEPA document. Consequently effects from future 

treatment under EDRR are the same as described for current infestations and it is unlikely 

adverse effects from future treatment would occur under any alternative. 

Indirect Effects 

Alternative A 

Alternative A treats fewer acres of existing invasive plant infestation Forest-wide, fails to 

control existing infestations in wilderness, restricts chemical control to only three herbicides 

(See Chapter 2) and would not use herbicides to more effectively control future infestations. 

Collectively for these reasons over the long-term, invasive plants would continue to increase 

under this alternative. Effects to wolverine include a possible localized reduction in native 

plant diversity and habitat for wolverine prey (small mammals and big game carrion) within 

affected areas 

Alternative B through D 

Because approximately the same acreage of existing infestations would be treated, invasive 

plant control would be similar. While broadcast spraying would not be used in riparian areas 

under Alternative C, invasive plants would still be treated. All alternatives also include EDRR 

treatments to control future infestations. 

Because of reduced costs (i.e. greater acreage treated) and more effective treatment methods, 

Alternatives B and D are expected to be most effective at containing or eradicating existing 

and future invasive plant infestations within riparian areas. However all alternatives would 

reduce existing and control future infestations. As a result all three alternatives are expected 

to reduce invasive weed infestation across the Forest and maintain wolverine foraging habitat 

within areas affected by invasive plants. 

Cumulative Effects 

Alternatives A through D 

Anticipated cumulative effects to wildlife are discussed above and include possible exposure 

to herbicides and on-going land uses on other ownerships and continued disturbance 

associated with use of NFS lands. Winter recreation and hiking in particular have the 

potential to disturb wolverines because these uses can occur in preferred remote habitat. 

However at this time wolverines have not been detected on the Forest. 

Although extremely unlikely, the proposed use of herbicides on and off National Forest 

System lands could result in additive doses of herbicides to wide ranging highly mobile 

species such as the wolverine. However as described above under the cumulative effect 

section, proposed herbicides do not bio-accumulate and it is unlikely that additive doses 

beyond those evaluated would occur. As a result and considering that over 99% of preferred 

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wilderness habitat would be unaffected, that this species currently does not occur on the 

forest or any future occurrence would involve very low numbers and that PDFs effectively 

reduce the likelihood that adverse effects from herbicide exposure would occur, 

implementation of any of the alternatives evaluated would not measurably contribute to any 

other past, current or reasonably foreseeable future activity that would result in significant 

effects to the California wolverine. 

Summary of Effects and Determination for California Wolverine 

Alternative A 

This alternative would not reduce invasive plants within suitable California wolverine habitat. 

However this species does not currently occur on the Forest and if it does would occur in very 

low numbers. Also there are no treatments proposed within preferred wilderness habitat and 

it is unlikely that this species would occur within treatment areas. As a result implementation 

of Alternative A would have No Impact on the California wolverine. 

Alternatives B through D 

California wolverine does not currently occur on the Forest. If they are discovered on the 

Forest in the future, proposed treatments could result in disturbance or exposure to herbicides 

or surfactants. However the likelihood of adverse effects is remote. Also these alternatives 

would reduce invasive plant infestations within preferred wilderness habitat and maintain 

native plant diversity and wolverine foraging habitat. As a result and based on the above 

analysis and the following rationale, implementation of Alternatives B through D would have 

No Impact on the California Wolverine. 

• The California wolverine is not recently documented on the forest, and if it is found in 

the future would occur in very low numbers. Also potential den habitat and over 99 

percent of preferred wilderness habitat would be unaffected under all alternatives. As a 

result and considering that this species avoids areas with human activity, it is unlikely 

that an individual would occur within a treatment area. 

• Use of typical application rates and implementation of PDFs that restrict use of high and 

moderate risk herbicides would reduce potential adverse effects associated with herbicide 

exposure. As a result, and considering this species forages over large areas, it would not 

be exposed to toxic levels of herbicides and there are no adverse effects from herbicide 

exposure anticipated. 

Bighorn Sheep 

Table 37 displays the treatment method and amount proposed under each of the alternatives. 

Of the 237,450 acres of suitable habitat within the action area, 2,627 are currently infested 

with invasive plants. All of this acreage would be treated under the action alternatives, 

whereas Alternative A would treat approximately 600 acres. 

Effects of treatments, biological control, site restoration/re-vegetation, EDRR and herbicide 

application/exposure are discussed under the Wildlife Effect Section. The following effects 

are specific to the bighorn sheep. 

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Direct Effects of Treatments 

Alternatives A through D 

Effects of treatment are discussed under the Wildlife Effect Section and potential effects of 

invasive plant treatment methods on bighorn sheep include disturbance caused by noise, 

people and vehicles. Manual control is proposed on approximately 50 acres under all 

alternatives, whereas mechanical/herbicide treatments would occur on 2,583 acres or 94 

percent of the acreage proposed for treatment under the action alternatives and approximately 

550 acres under Alternative A. Approximately 24 percent (623 acres) of the bighorn sheep 

habitat with invasive plants is adjacent to roads and trails, where they would be fairly 

accustomed to human disturbance and noise. While these activities could potentially disturb 

bighorn, disturbance would be limited to a few days during treatment. Also, 1 percent of the 

suitable habitat is proposed for treatment; therefore, unaffected habitat which could be used 

for any displaced animals is widely available. Thus, the amount of disturbance would vary 

somewhat by treatment (See Wildlife Effect Section); nevertheless, disturbance associated 

with all treatments would be short-term in nature (a few days) and of limited extent (i.e. 

localized). 

Herbicides 

Alternatives A through D 

The potential effects from herbicides are summarized under the Wildlife Effect Section and 

discussed in detail in Appendix C. If broadcast sprayed at the typical application rate, use of 

triclopyr or NPE can result in a dose that exceeds the toxicity index for large herbivorous 

mammals consuming contaminated vegetation. However triclopyr is restricted to spot spray 

and selective techniques only (F-1) and NPE would only be applied at a rate well below the 

typical application rate (F-4). While glyphosate and sulfometuron methyl exceeded the 

toxicity index at the highest application rate, PDF F-4 requires that the broadcast application 

of herbicides not exceed typical application rates. As a result implementation of these PDFs 

would effectively reduce the likelihood that bighorn would be exposed to toxic levels of 

herbicide. 

Potential for herbicide exposure is also affected by the likelihood that bighorn would forage 

within treatment areas, or the likelihood that preferred forage would be exposed. Much of the 

bighorn sheep summer range is in the higher elevation habitat, which currently has less 

invasive plant sites. Also although some areas are occupied year-round, known infestations 

currently occur primarily in winter range, reducing potential conflicts with summer/fall 

invasive treatments. Further cheatgrass, which is considered an invasive plant and is utilized 

by bighorn sheep is not targeted for treatment. Finally, due to the widespread availability of 

un-treated suitable habitat (>=98% of available habitat) within all management units, and 

considering that the pre-treatment assessment (A-1) would likely reduce potential for conflict, 

it is unlikely that sheep would be in the area at the time of treatment or consume a large part 

of their diet from vegetation that had been sprayed with herbicide. 

Alternative A 

Less than one half of one percent of the suitable bighorn habitat would be treated with 

approved herbicides under this alternative. Because this alternative only applies herbicides if 

other methods have proven ineffective and because it treats the fewest acres, potential for 

herbicide exposure is lowest under this alternative. 

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Alternative B 

Under Alternative B a total of 2,627 acres of suitable bighorn habitat would be treated. 

Approximately 692 acres of this is proposed for aerial spraying including 503 acres in the 

Lower Hells Canyon unit, 86 acres in the Lower Imnaha River unit, and 103 acres in Upper 

Joseph Creek. Disturbance may be reduced somewhat due to shorter application time, 

however, aerial application would apply herbicides to larger areas and greater amounts of 

non-target vegetation may be sprayed. This would potentially increase the risk that bighorn 

would consume contaminated vegetation. Conversely, all but 32 acres of proposed aerial 

spraying would occur on sites that are infested with yellow star-thistle. This species is 

aggressive and can form dense near-monotypic infestations (Ditomaso J.M. 2006) that greatly 

reduce native plant diversity. As a result, it is unlikely that bighorn would be foraging in 

these areas. Additionally PDFs F-8a through F-8o, restrict the use of chlorsulfuron, 

metsulfuron methyl and sulfometuron methyl during aerial application, restrict application 

rates for picloram and clopyralid, prevent spraying within sites that have 30 percent or more 

live tree canopy, require on-site inspection for areas that have between 10 and 29 percent 

cover, and require constant communication between the helicopter and ground observers. 

Collectively these PDFs would reduce the potential for vegetation to be sprayed with levels 

of herbicide that would result in a toxic dose to bighorn sheep and reduce the likelihood that 

an animal would be directly sprayed during implementation. 

Broadcast applications of herbicide could occur within approximately 1,400 acres of suitable 

bighorn riparian habitat, therefore, potential for exposure of bighorn to herbicides would be 

greater on this acreage. Three herd units would have riparian treatments on greater than 100 

acres and these areas are scattered and interspersed with unaffected habitat, reducing 

likelihood that an individual would consume all of their daily diet from contaminated 

vegetation. 

Alternatives C 

Treatments proposed under Alternative C and the associated effects (described above) would 

be similar to those under Alternative B, except that herbicide application within riparian areas 

would be restricted to spot spray and selective techniques only (1400 acres). Potential for 

herbicide exposure to bighorn would be reduced on this acreage because less non-target 

vegetation would be sprayed. 

Alternative D 

Treatments proposed under Alternative D and the associated effects (described above) would 

be similar to Alternative B, except that no aerial application of herbicides would occur. These 

sites would be treated using bio-control methods; therefore, potential for herbicide exposure 

would be reduced on this acreage (875 acres). This reduces risks somewhat on these sites 

from that of Alternatives B and C; however, these sites consist primarily of yellow star thistle, 

they are less likely to be utilized by bighorn. 

A total of 875 acres of suitable bighorn habitat would be treated using aerial techniques 

described in the Wildlife Effects Section. 

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Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new invasive plant infestations could occur within suitable bighorn 

habitat under these alternatives, although treatment method would vary (See Alternative 

Comparison above). If this occurs, additional disturbance (all alternatives) and herbicide 

exposure (Alternatives B, C and D only) could occur. Future herbicide treatments would use 

the same herbicides and comply with the same PDFs and management restrictions as 

currently proposed treatments, or if necessary in a new NEPA document. Consequently, 

effects from future treatment to bighorn under EDRR are the same as those described for 

current infestations and it is unlikely adverse effects would occur under any alternative. 

Indirect Effects 

Alternative A 

Not all suitable habitat currently infested with invasive plants would be treated under this 

alternative. Also EDRR treatment is restricted to less effective manual treatments. This would 

help to contain invasive plants in some locations; however, invasive plants would continue to 

expand in untreated areas. As a result, and considering that more effective herbicides are not 

approved for treatment, invasive plants would continue to reduce bighorn sheep foraging 

habitat. 

Alternatives B through D 

Approximately the same acreage of existing infestations would be treated; therefore, invasive 

plant control would be similar. Broadcast spraying would not be used in riparian areas under 

Alternative C, and aerial spraying would not be used in Alternative D; nevertheless, invasive 

plants would still be treated. All alternatives also include EDRR treatments to control future 

infestations. 

Alternative B is expected to be most effective at containing or eradicating existing and future 

invasive plant infestations within bighorn sheep habitat because of reduced costs (i.e. greater 

acreage treated) and more effective treatment methods. However, all alternatives would 

reduce existing as well as control new infestations. Effects under all alternatives to bighorn 

sheep would be the long-term maintenance of suitable foraging habitat across the Forest. 

Cumulative Effects 

Alternatives A through D 

Anticipated cumulative effects are described under the Wildlife Effect Section. Anticipated 

cumulative effects include possible exposure to herbicides and disturbance from on-going 

land uses on other ownerships, as well as continued disturbance associated with use of 

National Forest System lands, because use of the forest by bighorn occurs on multiple 

ownerships. Requirement for steep, rugged inaccessible terrain include primarily dispersed 

recreational use in more remote areas, including Wilderness. The proposed use of herbicides 

on and off National Forest System lands could result in additive doses of herbicides to 

bighorn. Although for this to occur, the two exposures would have to occur approximately at 

the same time (24-48 hours). This is unlikely since the herbicides proposed are rapidly 

eliminated do not significantly bio-accumulate (R6 2005 FEIS). Also the application rates and 

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extent considered in this EIS are unlikely to result in additive doses beyond those evaluated 

for chronic and acute exposures in the USDA Forest Service risk assessments. 

The risk of exposure to herbicide/treatments is further reduced by the fact that 98 percent or 

more of all bighorn sheep herd units would be unaffected, that treatment in many areas would 

likely occur when bighorn are not present, and that implementation of PDFs would greatly 

reduce the potential for adverse effects associated with herbicide exposure and treatment. As 

a result, and considering that the long-term restoration/maintenance of suitable bighorn sheep 

habitat outweighs any anticipated adverse effects, none of the alternatives would measurably 

contribute to any other past, current or reasonably foreseeable future activity that may be 

impacting this species and there are no significant cumulative effects anticipated. 

Summery of Effects and Determination for Bighorn Sheep 

Alternative A 

This alternative would not reduce all invasive plants within suitable bighorn sheep habitat, 

and invasive plants would continue to expand within untreated watersheds. Proposed 

treatments could result in short-term disturbance and herbicide exposure to bighorn. 

However, 99 percent or more of suitable bighorn habitat would be unaffected and 

management restrictions on herbicide use would reduce the likelihood of adverse effects 

associated with herbicide exposure. As a result implementation of Alternative A may impact 

individuals or habitat, but will not likely contribute to a trend towards federal listing or 

cause a loss of viability for Rocky Mountain bighorn sheep. 

Alternatives B through D 

Treatments proposed under these alternatives could result in short-term disturbance and 

herbicide exposure to bighorn sheep. However all alternatives would result in the long-term 

maintenance of bighorn foraging habitat across the Forest. As a result and based on the above 

analysis and the following rationale, implementation of Alternatives B through D may 

impact individuals or habitat, but will not likely contribute to a trend towards federal 

listing or cause a loss of viability for Rocky Mountain bighorn sheep. 

• Only 1 percent of suitable bighorn habitat would be affected and because of the 

widespread availability of suitable habitat within all affected watersheds, it is unlikely 

that bighorn would occur within treatment areas. 

• Treatments areas are widely scattered and use of typical application rates and 

implementation of PDFs that restrict use of high and moderate risk herbicides would 

effectively reduce potential adverse effects associated with herbicide exposure. 

• Much of the broadcast and aerial application of herbicides would occur in large 

infestations of invasive plants, which would not provide desired forage and would not 

likely be utilized by bighorn. 

• Prior to treatment localized habitat/species concerns would be assessed (A-1). If bighorn 

are known to be in the area, treatment methods/timing would be adjusted if necessary to 

reduce impacts. Additionally monitoring would be conducted to ensure non-target 

vegetation and wildlife are adequately protected from aerial spraying (F-8e). 

Spotted Bat 

As described under the Affected Environment Section, the spotted bat is not currently known 

to occur on the Forest. However, the Forest contains approximately 221,514 acres of suitable 

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habitat, including approximately 3,161 acres that are infested with invasive plants. Effects of 

proposed treatments on this species were evaluated because it is possible that they could 

become established during project implementation. 

Table 37 displays the treatment method and amount proposed under each of the alternatives. 

Alternative A would treat approximately 500 acres or 20 percent of existing infestations, 

whereas Alternatives B through D would treat all currently infested acres (3,161). Effects of 

treatments, biological control, EDRR, and herbicide application are discussed under the 

Wildlife Effect Section. The following effects are specific to the spotted bat. 

Direct Effects of Treatments 

Alternatives A through D 

Direct effects to roosting bats would not occur because no trees would be removed during any 

treatments. Additionally, no disturbance to foraging bats is anticipated because treatments 

occur during the day. As a result, there are no direct effects from treatment anticipated under 

any alternative. 

Herbicides 

Alternatives A through D 

All alternatives include the use of herbicides; therefore, potential adverse effects from 

herbicide exposure could occur. Bats forage over relatively large areas catching insects 

(primarily moths) in flight or by gleaning from vegetation. As a result, there is the possibility 

that insects (moths in particular) could be contaminated by herbicides and ingested by bats. 

Of the herbicides/surfactants proposed, only NPE could result in an acute dose that exceeds 

the reported NOAEL. However, NPE would only be applied at a rate well below the typical 

application rate (F-4) used in the exposure scenario. To receive this dose, the bat would have 

to consume nothing but contaminated insects for an entire nights feeding. Given that bats 

forage over large areas, this is not considered a plausible scenario. 

Data is lacking on risk from chronic exposure to contaminated insects. However, bats are not 

likely to forage exclusively within treated areas over a 90-day period (the chronic exposure), 

so there does not appear to be a plausible risk from chronic exposure. In addition, roosting 

bats would not be directly exposed to herbicides or surfactants because the bats roost in 

crevices well above ground level during the day. 

In summary, although exposure of herbicides to bats would be reduced under Alternative A 

(fewer acres treated), Alternative C (no broadcast application in riparian areas) and 

Alternative D (no aerial application), with implementation of PDFs and considering bats 

foraging behavior, it is not anticipated that a spotted bat would be exposed to levels of any 

herbicide or surfactant that would exceed the reported NOAEL under any alternative. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new infestations could occur within suitable spotted bat habitat under 

these alternatives; although treatment method would vary (See Alternative Comparison 

above). If this occurs, additional disturbance (all alternatives) and herbicide exposure 

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(Alternatives B, C and D only) could occur. Future treatments would use the same herbicides 

and comply with the same PDFs as existing treatments; therefore, any potential effects from 

future treatment would be similar to those analyzed above. As a result, there are no adverse 

effects to spotted bat anticipated from future EDRR treatments. 

Indirect Effects 

Alternative A 

A total of 591 acres or approximately 20 percent of preferred spotted bat habitat would be 

treated under this alternative. Treatments proposed under Alternative A would reduce invasive 

weed infestations on the sites treated; although, over 80 percent of existing infestations within 

suitable spotted bat habitat would go un-treated. Alternative A also restricts chemical control 

to only three herbicides (See Chapter 2) and would not use herbicides to more effectively 

control future infestations. Collectively for these reasons, over the long-term invasive plants 

would continue to increase under this alternative. Effects to the spotted bat include a possible 

localized reduction in native plant/insect diversity (foraging habitat) within affected 

watersheds. 

Alternatives B through D 

Invasive plant control would be similar because approximately the same acreage of existing 

infestations would be treated. Broadcast spraying would not be used in riparian areas under 

Alternative C, and aerial spraying would not be used in Alternative D; however, existing and 

future invasive plants infestations would still be treated. Also, all alternatives include a wide 

range of EDRR treatments to control future infestations. 

Alternative B is expected to be most effective at containing or eradicating existing and future 

invasive plant infestations within spotted bat habitat because of reduced costs (i.e. greater 

acreage treated) and more effective treatment methods. However all alternatives would 

reduce existing and control new infestations and effects under all alternatives would be the 

long-term maintenance of native plant diversity and spotted bat foraging habitat. 

Cumulative Effects 

Alternatives A through D 

Potential cumulative effects were described under the Wildlife Effect Section. The spotted bat 

forages over large areas; therefore, potential cumulative effects include possible herbicide 

exposure on other ownerships, which could result in additive doses of herbicides. However, 

as described above, it is unlikely that that they would consume enough contaminated insects 

to be exposed to a toxic dose of herbicides. As a result, implementation of any of the 

alternatives evaluated would not measurably contribute to any other past, present or 

reasonably foreseeable future activity that would result in significant effects to the spotted 

bat. 

Summery of Effects and Determination for the Spotted Bat 

Alternative A 

While this alternative would not reduce invasive plants within suitable spotted bat habitat, 

there are no adverse effects anticipated and there are no adverse effects to the spotted bat 

from treatments or herbicide exposure anticipated. As a result there are no adverse effects 

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from treatments anticipated and implementation of Alternative A would have No Impact on 

the spotted bat. 

Alternatives B through D 

All alternatives would improve spotted bat foraging habitat. While effects of treatment could 

occur, there are no adverse effects anticipated and based on the above analysis and the 

following rationale, implementation of these alternatives would have No Impact on the 

spotted bat. 

• The spotted bat does not currently occur on the Forest and any future occurrence would 

involve very low numbers. Also less than 1 percent of the suitable spotted bat habitat 

would be treated and it is unlikely that they would occur within a treatment area. 

• There are no disturbance/mortality related effects to roosting or foraging bats anticipated. 

Also with implementation of PDFs and considering this species foraging behavior, 

spotted bats would not be exposed to levels of herbicide that would result in adverse 

(exceeded the reported NOAEL) effects. 

Bald Eagle 

As described under the Affected Environment Section, invasive plants are no considered a 

threat to the bald eagle or its habitat. However invasive plant treatment could result in 

adverse effects to this species. 

Table 37 displays the treatment method and amount proposed under each of the alternatives. 

Effects of treatments, biological control, site restoration/re-vegetation, EDRR and herbicide 

application/exposure are discussed under the Wildlife Effect Section. The following effects 

are specific to the bald eagle. 

Direct Effects of Treatments 

Alternatives A through D 

Potential effects of invasive plant treatment methods on bald eagles are associated with 

disturbance that may occur to nesting eagles. This could cause the birds to leave nests, or 

stay away from the nest long enough to have detrimental effects to eggs or young (USDI 

1986). Short-term disturbance can also occur to roosting and foraging eagles. 

At this time, no bald eagle nests occur within 0.50 miles of any proposed treatment areas, so 

existing nests would be unaffected under all alternatives. Additionally, PDFs (J-1) were 

developed for the action alternatives specifically to reduce potential effects to the bald eagle 

should new nests become established and would ensure that no treatment would occur near 

eagle nests during the nesting/fledgling season (January 1 to August 31), near occupied 

winter roosts, or concentrated foraging areas (J1b). Treatments would not involve removal of 

roost trees, there are no treatments proposed near winter concentration areas or known roosts 

and PDFs (J1a & 1b) would place seasonal treatment restrictions around occupied nests if 

new nest locations are discovered in the future. Consequently with implementation of these 

PDFs, there are no direct effects to the bald eagle from treatment application under any action 

alternative. 

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Herbicides 

Alternatives A through D 

None of the herbicides proposed for use in this EIS or NPE surfactants applied at typical 

application rates pose a risk to bald eagles. The potential for the herbicides to adversely affect 

bald eagles was determined using quantitative estimates of exposure from worst-case 

scenarios. Exposure scenarios used to analyze potential effects from herbicides are discussed 

in R6 2005 FEIS Appendix P, p. 24-27. The results of these exposure scenarios indicate that 

no herbicide or NPE surfactant proposed for use poses any plausible risk to birds from eating 

contaminated fish. All expected doses to fish-eating birds for all herbicides and NPE are well 

below any known NOAEL (see Appendix C). No ground applications of herbicide would 

reach the upper canopies of mature trees/snags where bald eagles nest and with 

implementation of PDFs (J-1), bald eagles are not likely to be directly sprayed, or encounter 

vegetation that has been directly sprayed. 

Early Detection Rapid Response 

Alternatives A through D 

Although treatment method would vary (See Alternative Comparison above), future 

treatments to new invasive plant infestations could affect the bald eagle. However 

implementation of PDFs would eliminate potential impacts to nesting, roosting and foraging 

birds. As a result no adverse effects to the bald eagle are anticipated from future treatment of 

invasive plants. 

Indirect Effects 

Alternatives A through D 

There are currently no invasive plant infestations affecting bald eagle nesting, foraging, or 

roosting habitat. Consequently there are no indirect effects to bald eagle habitat under any 

alternative. 

Cumulative Effects 

Alternatives A through D 

Anticipated cumulative effects are described under the Wildlife Effect Section. As described, 

herbicides are commonly applied on lands other than National Forest system lands for a 

variety of agricultural, landscaping and invasive plant management purposes. Herbicide use 

occurs on tribal lands, state and county lands, private forestry lands, rangelands, utility 

corridors, road rights-of-way, and private property. 

Because eagles have been documented traveling between NFS lands and other ownerships, 

the proposed use of herbicides under these alternatives could result in additive doses of 

herbicides to any eagles exposed to herbicides on other ownerships. Although for this to 

occur, the two exposures would have to occur at approximately the same time. This is 

unlikely since the herbicides proposed are rapidly eliminated and do not significantly bioaccumulate (R6 2005 FEIS). Also the application rates and extent considered in this EIS are 

unlikely to result in additive doses beyond those evaluated discussed in this EIS. As a result 

and considering that the risk of adverse effects from proposed treatment have been effectively 

eliminated though implementation of PDFs, no alternative would measurably contribute to 

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any other past, current or reasonably foreseeable future activity that would result in 

significant effects to the bald eagle. 

Summary of Effects and Determination for the Bald Eagle 

Alternatives A through D 

Although there is a remote possibility that a foraging/roosting bird could be disturbed during 

treatment, with implementation of PDFs that prevent treatment near occupied nest and winter 

roost habitat there are no adverse effects to nesting birds anticipated. As a result and based on 

the above analysis and the following rationale, implementation of Alternatives A through D 

May Impact Individuals or habitat, but would not likely contribute towards a trend in 

federal listing or cause a loss of viability to the bald eagle: 

• There are no bald eagle nest locations within 1⁄2 mile of proposed treatment areas and no 

known winter roost areas affected. 

• Implementation of Project Design Features (J1a and 1b) would ensure that concentrated 

foraging areas, existing winter roosts and future nesting/roosting areas would be 

protected and minimize potential adverse effects from treatment. 

• Studies have shown that even if a bald eagle fed for a lifetime upon fresh-water fish that 

had been contaminated by an accidental spill of herbicide, they would not receive a dose 

that exceeds any known NOAEL. Consequently adverse effects to bald eagles from 

herbicide exposure are not plausible. 

American peregrine falcon 

Peregrine falcon habitat is not being adversely affected by invasive plants and there are no 

invasive plant treatments proposed near any known nests. However this species could forage 

on prey (birds) that have been adversely affected or new nests could become established near 

invasive plant sites. As a result potential for adverse effects to the peregrine falcon could 

occur from proposed treatments. 

Table 36 displays the treatment method and amount proposed under each of the alternatives. 

Effects of treatments, biological control, site restoration/re-vegetation, EDRR and herbicide 

application/exposure are discussed under the Wildlife Effect Section. The following effects 

are specific to the peregrine falcon. 

Direct Effects of Treatments 

Alternatives A through D 

Potential effects of invasive plant treatment methods were described in the Wildlife Effect 

Section and direct effects to the peregrine falcon include disturbance caused by noise, people 

and vehicles associated with proposed treatments. Currently no peregrine falcon nest sites 

occur within 1.5 miles of any proposed treatment area. Additionally, implementation of 

PDFs (J3) will ensure that no treatment would occur near any new nests established (J3a 

through J3f). Although potential exists for treatments to result in short-term disturbance to 

foraging birds, due to the small amount of habitat proposed for treatment the possibility of 

disturbance is low and with implementation of PDFs there are no adverse effects to nest 

habitat anticipated under any alternative. 

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Herbicides 

Alternatives A through D 

There is no quantitative scenario for a predatory bird that eats primarily other birds, such as 

the peregrine falcon, so the “fish-eating bird” scenario and the “mammal-eating bird” were 

used as surrogate scenarios. No herbicide or NPE dose exceeded the toxicity indices for fisheating birds even in a “worst case” scenario. Under the small mammal eating bird scenario, 

no herbicides or surfactants exceed the toxicity index at typical application rates. At the 

highest application rates, NPE, glyphosate and sulfometuron methyl exceeded the reported 

NOAEL. However PDFs restrict the use of glyphosate and sulfometuron methyl to typical 

application rates and restrict NPE to 0.5 lbs active ingredient per acre (less than typical 

application rate). Consequently there are no adverse effects from proposed 

herbicides/surfactants anticipated under any alternative. 

Potential impacts to this species are further reduced by the fact that this species forages over 

large areas, effectively eliminating the possibility that all or most of its prey would be 

contaminated and that a falcon would be exposed to toxic levels of herbicides/surfactants. 

No aerial spraying would occur in close proximity to any of the known nest sites 

(Alternatives B and C) and broadcast spraying in riparian habitat (Alternatives B and D) 

would not impact peregrine falcon nest sites. Also peregrine falcons do not forage exclusively 

within riparian areas and potential for herbicide exposure would be similar under all 

alternatives. 

Early Detection Rapid Response 

Alternatives A through D 

Although treatment method would vary (See Alternative Comparison above), future 

treatments to new invasive plant infestations could affect this species. However 

implementation of PDFs and the peregrine falcons foraging behavior would eliminate 

potential impacts to nesting or foraging birds. As a result there are no adverse effects to the 

peregrine falcon anticipated from future EDRR treatments. 

Indirect Effects 

Alternatives A through D 

Because invasive plants do not occupy preferred peregrine falcon habitat, there are no 

indirect effects to falcon habitat anticipated under any alternative. 

Cumulative Effects 

Alternatives A through D 

As described under the Wildlife Effect Section, anticipated cumulative effects to wide 

ranging species such as the peregrine falcon could include possible exposure herbicides and 

disturbance from on-going land uses on other ownerships, as well as continued disturbance 

associated with use of NFS lands. However, as described above under the Wildlife Effect 

Section, proposed herbicides do not bio-accumulate and it is unlikely that additive doses 

beyond those evaluated would occur. As a result, and considering that existing and future 

nests would not be affected by treatment (J-J3a through J3d), that there are no chronic or 

acute effects to a predatory bird from proposed herbicides or surfactants at the typical 

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application rates proposed (F1 and F-4), and that1percent of the analysis area is proposed for 

treatment, implementation of Alternatives A through D would not contribute to any other past, 

current or reasonably foreseeable future activity that would result in significant effects to the 

peregrine falcon. 

Summary of Effects and Determination for the Peregrine Falcon 

Alternatives A through D 

There are four known peregrine falcon nests on the Forest. There could be minor effects to 

foraging peregrine falcon from treatments. However no alternative would alter or disturb nest 

habitat. As a result and based on the above analysis and the following rationale, 

implementation of Alternatives A through D may impact individuals or habitat, but will 

not likely contribute to a trend towards federal listing or cause a loss of viability to the 

peregrine falcon. 

• There are no nests located near any proposed treatment sites and PDFs are in place to 

protect existing and new nests from future treatment. 

• There are no chronic or acute effects to a predatory bird from proposed herbicides or 

surfactants at the typical application rates proposed and with restrictions to moderate and 

high risk herbicides. As a result and considering the peregrine falcons foraging behavior 

(i.e. forage over large areas), there are no adverse effects from herbicide exposure 

anticipated under any alternative. 

Greater Sage Grouse 

As described under the Affected Environment Section, greater sage grouse are not currently 

known to occur on the Forest. However the Forest contains scattered patches of suitable 

habitat, and there is a relative large block of suitable habitat on adjacent BLM land. It is 

possible that they could become established during project implementation; therefore, effects 

of proposed treatments on this species were evaluated. 

Currently three patches of suitable sage grouse habitat have a total of six acres of invasive 

plants. Table 36 displays the treatment method and amount proposed under each of the 

alternatives. There was no suitable greater sage grouse habitat identified in riparian areas. As 

a result and considering that no aerial spraying of suitable habitat is proposed, there is little 

difference between the action alternatives. 

Effects of treatments, biological control, EDRR, and herbicide application are discussed 

under the Wildlife Effect Section. The following effects are specific to the greater sage 

grouse. 

Direct Effects of Treatments 

Alternative A 

There are no direct effects to sage grouse under this alternative because there are no 

treatments proposed within suitable sage grouse habitat. 

Alternatives B through D 

Effects of treatment were discussed previously under the Wildlife Effect Section and direct 

effects to sage grouse include disturbance and possible nest mortality during implementation 

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of proposed treatments. However, sage grouse have not been documented on the Forest and 

due to the scattered nature of suitable habitat; potential or occupancy is considered low. 

Additionally project design features are in place (J5b and J5c) to minimize disturbance 

around breeding sites. Further, the pre-treatment assessment (A-1) would identify concerns 

should sage grouse become established and the timing and method of treatment would be 

modified if necessary to reduce or eliminate impacts. Potential impacts are further reduced by 

because six acres of suitable sage grouse habitat are currently proposed for treatment. There 

are no adverse effects to nesting grouse anticipated, and any adverse effects to this species 

from treatment would be limited to short-term disturbance to foraging birds. 

Herbicides 

Alternative A 

Because there is no suitable habitat proposed for treatment and considering that treatment of 

future sites would only use manual methods, there are no risks of herbicide exposure under 

this alternative. 

Alternatives B through D 

The potential effects from herbicides are summarized under the Wildlife Effect Section, and 

discussed in detail in Appendix C. Sage grouse are large vegetation-eating birds, so a scenario 

was used that estimated herbicide exposure for a large bird eating contaminated vegetation. 

Also because sage grouse chicks depend heavily on insects, estimated doses for small birds 

consuming contaminated insects was also evaluated. 

At typical application rates for adult birds, only triclopyr (if broadcast sprayed) and NPE 

surfactants exceeded acute (100% of the daily diet consists of contaminated forage) toxicity 

thresholds (see Appendix P of R6 2005 FEIS) for adult birds. However, as described under 

the Wildlife Effect Section, application of triclopyr is restricted to spot spray and selective 

techniques only (F-1), NPE would be broadcast sprayed at levels below the typical 

application rate (F-4) and no broadcast application of herbicide would exceed typical 

application rates. As a result, the potential for adult or young sage grouse to be exposed to 

toxic levels of herbicides are greatly reduced. 

The following considerations would further reduce the possibility that sage grouse would 

receive toxic doses of herbicides/surfactants; (1) Due to the small amount of infestation that 

currently exists within suitable habitat, it is unlikely that large infestations of invasive plants 

requiring broadcast applications of herbicides would be needed, (2) Because it is a nonselective herbicide, glyphosate is seldom used in dry habitats, (3) triclopyr is used on invasive 

woody vegetation like blackberries and Scotch broom, neither of which are present in sage 

grouse habitat and if they were, sage grouse would be unlikely to forage exclusively on or 

near these plants, (4) in order to receive a chronic dose of herbicides at typical application 

rates, birds would have to consume nothing but contaminated forage for 90 days. This 

scenario is highly unlikely considering that invasive plants do not provide preferred forage 

and only a small amount of suitable habitat would be treated. Also foliar interception would 

reduce the actual amount of sprayed on many insects present. 

In summary, no impacts to sage grouse are predicted with any alternative, because their 

presence has not been established on the Forest and only six acres of suitable habitat are 

proposed for treatment. If sage grouse are discovered on the Forest, project PDFs (F-1, F-4, J5a to J-5c) effectively minimize risk to sage grouse from exposure to herbicides or 

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surfactants. As a result it is unlikely that adverse effects associated with herbicides would 

occur under any alternative. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new infestations could occur within suitable sage grouse habitat under 

these alternatives; although treatment method would vary (See Alternative Comparison 

above). If this occurs, additional disturbance (all alternatives) and herbicide exposure 

(Alternatives B, C and D only) could occur. Future herbicide treatments would use the same 

herbicides and comply with the same PDFs and management restrictions as currently 

proposed treatments, or if necessary in a new NEPA document. Consequently, effects from 

future treatment to sage grouse under EDRR are the same as those described for current 

infestations and it is unlikely adverse effects would occur under any alternative. 

Indirect Effects 

Alternatives A through D 

There would be little indirect effects to sage grouse habitat from existing infestations under 

any alternative because only six acres of invasive plants would be treated within suitable sage 

grouse habitat. Treatment of future sites could occur under all alternatives; however, the 

action alternatives would be more effective at controlling future infestations of invasive 

plants and maintaining sage grouse habitat. 

Cumulative Effects 

Alternatives A through D 

Anticipated cumulative effects are discussed under the Wildlife Effect Section. Although not 

documented on the Forest, suitable habitat exists on National Forest System lands as well as 

adjacent BLM lands. The proposed use of herbicides on BLM land could result in additive 

doses of herbicides to sage grouse if a bird was also exposed to herbicides on National Forest 

System lands. Although for this to occur, the two exposures would have to occur at 

approximately the same time (24-48 hours). This is unlikely since this species is not 

documented on the forest and PDFs are in place to reduce impacts to breeding (J-5b & J-5c) 

and foraging (J-5a) birds should they become established. Potential effects would be further 

reduced due to coordination between Forest Service and BLM. Also the application rates and 

extent considered in this EIS are unlikely to result in additive doses beyond those evaluated. 

As a result, and considering that EDRR treatments would maintain native plant diversity and 

suitable sage grouse habitat on any areas affected by invasive plants in the future, none of the 

alternatives would measurably contribute to any other past, current or reasonably foreseeable 

future activity that may be impacting this species and there are no significant cumulative 

effects anticipated. 

Summary of Effects and Determination for the Greater Sage Grouse 

Alternative A 

This alternative would not reduce invasive plants within suitable greater sage grouse habitat. 

However greater sage grouse do not currently occur on the Forest and because treatment of 

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future sites is not expected to result in adverse impacts, implementation of Alternative A 

would have No Impact on the greater sage grouse. 

Alternatives B through D 

Greater Sage Grouse do not currently occur on the Forest and there are no adverse effects 

from proposed treatments under any alternative. As a result and based on the above analysis 

and the following rationale, implementation of Alternatives B through D will have No 

Impact on the greater sage grouse. 

• This species does not currently occur on the forest and there are six acres of suitable 

habitat proposed for treatment. Typical application rates and PDFs that restrict use of 

moderate and high risk herbicides effectively minimize risk to sage grouse from 

disturbance or exposure to herbicides or surfactants, should they become established in 

the future. 

• Prior to treatment, localized habitat and species concerns would be assessed to determine 

the appropriate type and method of treatment necessary to minimize potential effects. 

• Existing and future invasive plant infestations would be controlled, contained or 

eradicated and native plant diversity and preferred sage grouse cover and forage 

conditions would be maintained within affected watersheds. 

Sharp-tailed Grouse 

Sharp-tailed grouse are not currently known to occur on the Forest; although historical use 

(1990s) did occur, and suitable habitat exists on 477,431 acres across the Forest. Effects of 

proposed treatments on this species were evaluated because it is possible that they could 

become established during project implementation. 

Slightly less than 2 percent (9,426 acres) of the Forest-wide suitable habitat have invasive 

plants. Alternative A would treat approximately 2000 acres or 21 percent of existing 

infestations, whereas Alternatives B, C and D would treat all existing infestations. 

Effects of treatments, biological control, EDRR, and herbicide application/exposure are 

discussed under the Wildlife Effect Section. The following effects are specific to sharp-tailed 

grouse. 

Direct Effects of Treatment 

Alternatives A through D 

Effects of treatment were discussed previously under the Wildlife Effect Section and direct 

effects to sharp-tailed grouse include disturbance during implementation of proposed 

treatments. The length and type of disturbance would vary by treatment method, and any 

disturbance is expected to be short-term in nature. Most treatment sites are widely scattered 

and interspersed with unaffected suitable habitat; therefore, grouse would move out of the 

area during treatment. As a result any disturbance would be short term and of limited (i.e. 

localized) extent. 

Sharp-tail nest on the ground; therefore, potential also exists to have nests crushed or 

trampled, which could result in mortality and/or reduced reproductive success. As described 

under the Wildlife Effect Section, the likelihood of nest mortality varies depending on the 

treatment method. Alternative A treats the fewest acres of sharp-tail habitat and treatment of 

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future sites and is restricted to manual methods; therefore, potential for nest mortality would 

be lowest under this alternative. Repeated treatment would be necessary on some sites; 

however potential nest mortality from manual treatment would still be low. 

Alternatives B through D would treat the largest acreage of suitable sharp-tailed grouse 

habitat, as well as treat more sites with mechanical methods; therefore, potential for nest 

mortality exists under these alternatives. However, the small amount of suitable habitat 

proposed for treatment (2% or less under all alternatives), and considering that this species 

has not been recently documented and if it occurs would occur at very low numbers, ensures 

the likelihood is low that a nesting bird would occur within a treatment site. Potential for 

mortality is further reduced by the fact much of the broadcast applications would occur in 

areas that are dominated by invasive plants, which would not likely be utilized by sharp-tail. 

Also, if sharp-tail actually occurred within a treatment site, the pre-treatment assessment (A1) would ensure that treatment methods or timing would be adjusted, if necessary, to reduce 

or eliminate adverse effects. While potential for mortality exists, implementation of PDFs, 

combined with the small amount of suitable habitat proposed for treatment would effectively 

eliminate the likelihood that treatment related mortality would occur. 

Herbicides 

Alternative A 

Approximately 21 percent of the suitable sharp-tailed grouse habitat would be treated with 

approved herbicides under this alternative. Of this, up to 1643 acres could be treated using 

chemical treatments. Potential for herbicide exposure is lowest under this alternative because 

this alternative only applies herbicides if other methods have proven ineffective, and it treats 

the fewest acres. 

Alternatives B through D 

Under these alternatives up to 7,720 acres of chemical treatments could occur within suitable 

sharp-tailed grouse habitat. The potential effects from herbicides are summarized in the 

Wildlife Effect Section and are discussed in detail in Appendix C. Plant material can make up 

to 90 percent of an adult sharp-tailed grouse diet, including grains and berries. As a result, the 

potential for sharp-tailed grouse to receive a toxic dose of herbicides was evaluated under the 

scenario of large herbaceous bird consuming contaminated vegetation. Sharp-tailed chicks 

depend heavily on insects; therefore, estimated doses for small birds consuming contaminated 

insects were also used. 

Potential effects of herbicide exposure to sharp-tailed grouse are similar to those described 

for the sage grouse. At typical application rates for adult birds, only triclopyr (if broadcast 

sprayed) and NPE surfactants exceeded acute (100% of the daily diet consists of 

contaminated forage) toxicity thresholds (see Appendix P of R6 2005 FEIS) for adult birds at 

typical application rates. However, as described under the Wildlife Effect Section, application 

of triclopyr is restricted to spot spray and selective techniques only (F-1) and NPE would be 

broadcast sprayed at levels below the typical application rate (F-4). As a result, it is not 

anticipated that adult or young sharp-tailed grouse would be exposed to toxic levels of 

herbicides are greatly reduced. 

Additionally in order for a bird to receive a chronic dose of herbicides, its entire diet must 

consist of contaminated insects or vegetation for 90 days. This is highly unlikely considering 

that herbicides do not bioaccumulate and most break down fairly quickly in the environment. 

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Potential for exposure is further reduced considering that; 1) sharp-tailed grouse are not 

known to forage within areas dominated by invasive plants, 2) that only patches of invasive 

plants would be treated and these would be interspersed with unaffected suitable habitat, 3) 

that the physical disturbance associated with treatment would likely to scare off birds, and 4) 

that foliar interception would reduce the actual amount of sprayed on many insects present. 

Collectively for these reasons, as well as implementation of PDFs that restrict application 

rates and use of high and moderate risk herbicides and require that the presence of SOLI such 

as sharp-tail be confirmed prior to treatment, it is unlikely that broadcast application of 

herbicides would result in a bird being exposed to toxic levels of herbicide. 

Alternative B 

Under Alternative B a total of 9,426 acres of suitable sharp-tailed grouse habitat would be 

treated including 2,590 acres of riparian habitat and 862 acres of aerial spraying. The 

potential for herbicide exposure to sharp-tailed grouse would be greatest under this 

alternative because it would treat the largest amount of suitable habitat and because treatment 

involves aerial application as well as broadcast application within riparian areas. 

Herbicide buffers would restrict broadcast application of surfactant and herbicides within 150 

feet of all streams, waterbodies, and wetlands; however, broadcast application of herbicides 

could occur within riparian areas outside these buffers on approximately 1300 acres. 

Potential for herbicide exposure would be greater on this acreage because sharp tails are 

known to utilize riparian areas for cover. However, PDFs that restrict application rates and 

timing, minimize drift, maintain un-treated areas along streams and waterbodies and require 

that the presence of SOLI such as sharp-tail be confirmed prior to treatment would effectively 

reduce the likelihood of adverse effects associated with treatment or herbicide exposure 

within riparian areas. 

Herbicides would be aerially applied on 862 acres of suitable sharp-tailed grouse habitat 

under this alternative. As described under the Wildlife Effect Section, greater amounts of nontarget vegetation/insects would be contaminated because aerial application would apply 

herbicides to larger areas. This would increase the risk that a bird could consume 

contaminated vegetation/insects. All but 32 acres of proposed aerial spraying would occur on 

sites that are infested with yellow star-thistle. This species is aggressive and can form near 

monotypic infestations (Ditomaso 2006), which can greatly reduce native plant diversity. As a 

result, it is unlikely that sharp-tailed grouse would be utilizing these areas. Additionally, use 

of typical application rates and PDFs that restrict use of high and moderate risk herbicides 

further reduce the likelihood that a bird would be exposed to toxic levels of herbicide from 

aerial treatment. 

Alternative C 

Treatments proposed under Alternative C and the associated effects (described above) would 

be similar to Alternative B, except that herbicide application within riparian areas would be 

restricted to spot spray and selective techniques. These treatments are not considered high 

risk (USDA-FS 2005 ROD); therefore, potential for herbicide exposure would be reduced on 

approximately 1300 acres from that of Alternatives B and D. 

Alternative D 

Treatments proposed under Alternative D and the associated effects would be similar to 

Alternative B, except that no aerial application of herbicides would occur. These sites would 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

be treated using biocontrol methods; therefore, potential for herbicide exposure would be 

reduced on 862 acres of habitat. This reduces risks somewhat from that of Alternatives B and 

C, however, these sites consist primarily of yellow star thistle and are less likely to be used by 

sharp-tail and risks of herbicide exposure are similar to those of Alternatives B and C. 

In summary, by limiting application of triclopyr to spot spray and selective methods only (F1), requiring that NPE only be applied at levels less than typical application rates (F-4), 

limiting application of all herbicides to typical application rates (F-4), and requiring pretreatment assessment to confirm SOLI (A-1), PDFs are expected to effectively reduce 

potential for birds to be exposed to toxic levels of herbicides and reduce the possibility that 

treatments would occur within occupied habitat. As a result, and due to the small amount of 

suitable habitat likely affected by EDRR treatments, and considering this species has not been 

recently documented on the forest, it is not anticipated that adverse effects to this species 

would occur under any alternative. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new infestations could occur within suitable sharp-tailed grouse habitat 

under these alternatives, although treatment method would vary (See Alternative Comparison 

above). If this occurs, additional disturbance (all alternatives) and/or herbicide exposure 

(Alternatives B, C and D only) could occur. Future herbicide treatments would use the same 

herbicides and comply with the same PDFs and management restrictions as currently 

proposed treatments, or if necessary in a new NEPA document. Consequently, effects from 

future treatment under EDRR are the same as described for current infestations and it is 

unlikely adverse effects would occur from these treatments under any alternative. 

Indirect Effects 

Alternative A 

This alternative would reduce invasive plant infestations within suitable sharp-tail habitat; 

however, treatment effectiveness is low. It is likely future areas would become established on 

many sites because some areas currently infested would go untreated and because EDRR is 

limited to manual treatments only. Collectively for these reasons, invasive plants would 

continue to spread and native plant diversity and sharp-tail grouse habitat would decline 

within affected areas. 

Alternatives B through D 

All action alternatives would reduce existing infestations of invasive plants within suitable 

sharp-tailed grouse habitat and allow for control of future infestations. Alternative B is 

expected to be most effective at controlling invasive plants because of reduced costs (i.e. 

greater acreage treated) and more effective treatment methods. However, all of these action 

alternatives would reduce existing infestations, control new infestations, and result in the 

long-term maintenance of suitable sharp-tailed grouse habitat. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Cumulative Effects 

Alternatives A through D 

Anticipated cumulative effects are discussed under the Wildlife Effect Section. Sharp-tailed 

grouse are not documented on the forest; though suitable habitat exists and it is possible that 

birds could occur at very low numbers. The proposed use of herbicides on other ownerships 

could result in additive doses of herbicides to sharp-tail if a bird was exposed to herbicides on 

National Forest System lands. The two exposures would have to occur at approximately the 

same time (24-48 hours). This is unlikely since this species is not documented on the forest 

and PDFs are in place to minimize the likelihood that a bird would be exposed to toxic levels 

of herbicide and identify occupied sites prior to treatment. The herbicides proposed are 

rapidly eliminated and do not significantly bio-accumulate (R6 2005 FEIS). The application 

rates and extent considered in this EIS are unlikely to result in additive doses beyond those 

evaluated for chronic and acute exposures in the USDA Forest Service risk assessments. As a 

result, and considering that less than 2 percent of the forest-wide habitat is proposed for 

treatment and that the long-term restoration and maintenance of suitable sharp-tailed grouse 

habitat outweighs any anticipated adverse effects, none of the alternatives would measurably 

contribute to past, present or reasonably foreseeable future activity that may be impacting this 

species and there are no significant cumulative effects anticipated. 

Summary of Effects and Determination for the Sharp-tailed Grouse 

Alternative A 

Existing infestations would continue to expand and suitable habitat would be reduced within 

the affected watersheds because 75 percent of the suitable sharp-tailed grouse habitat that is 

currently infested with invasive plants would go un-treated. However, this species is not 

currently documented on the forest; therefore implementation of Alternative A would have 

No Impact on sharp-tailed grouse. 

Alternatives B through D 

Sharp-tailed grouse do not currently occur on the Forest. If this species were documented in 

the future, treatment timing and application would be modified if necessary to eliminate 

potential adverse effects. All action alternatives would reduce existing and control new 

invasive plant infestations within suitable sharp-tailed grouse habitat. As a result and based 

on the above analysis and the following rationale, implementation of Alternatives B through 

D would have No Impact on the sharp-tailed grouse. 

• This species is not currently documented. Also less than 2 percent of the suitable grouse 

habitat would be treated and it is not expected that sharp-tailed grouse would occur 

within treatment areas. 

• Project PDFs that restrict application rates and timing, minimize drift, maintain untreated areas along streams and waterbodies and require that the presence of SOLI such 

as sharp-tail be confirmed prior to treatment would effectively reduce potential adverse 

effects to sharp-tailed grouse. 

• Proposed treatments would result in the long-term maintenance of suitable sharp-tail 

grouse habitat. 

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Gray Flycatcher 

A total of approximately 162,741 acres of potential gray flycatcher breeding habitat exist 

Forest-wide. Of this, approximately 2,617 acres or about 1.6 percent of potential gray 

flycatcher habitat contains known infestations of invasive plant species. All currently infested 

acres would be treated under the action alternatives, whereas Alternative A would treat 

approximately 20 percent of existing infestations. This flycatcher is not documented on the 

forest, and is difficult to identify; therefore, it is possible that it could occur in low numbers. 

As a result effects to this species were evaluated. 

Effects of treatments, biological control, EDRR, and herbicide exposure are discussed under 

the Wildlife Effect Section. The following effects are specific to the gray flycatcher. 

Direct Effects of Treatment 

Alternatives A through D 

Effects of treatment were discussed previously under the Wildlife Effect Section and direct 

effects to gray flycatchers include disturbance during implementation of proposed treatments. 

Disturbance is expected to be short-term in nature; although the length and type of 

disturbance would vary by treatment method. Most treatment sites are widely scattered and 

interspersed with unaffected suitable habitat, therefore, the birds would move out of the area 

during treatment. As a result, any disturbance would be short term and of limited (i.e. 

localized) extent. Gray flycatchers nest in trees, and there is no mortality from trampling 

anticipated. 

Herbicides 

Alternatives A though D 

Effects from herbicide exposure were evaluated using the insectivorous bird scenario. The 

bird is assumed to feed exclusively on contaminated insects for the entire day’s diet. There is 

no chronic dose estimate because there is no data on long-term herbicide residue on insects. 

At typical application rates only triclopyr (if broadcast sprayed) and NPE surfactants 

exceeded acute (100% of the daily diet consists of contaminated forage) toxicity thresholds 

(see Appendix P of R6 2005 FEIS) for small insectivorous birds. However implementation of 

PDFs would limit the use of triclopyr to spot spray and selective methods only (F-1), NPE 

would only be applied at levels well below the typical application rate (F-4) and these PDFs 

would greatly reduce the likelihood that a bird would be exposed to toxic levels of herbicide. 

This species has a small home range and territory (<10 acres); therefore, it is possible that an 

individual bird could consume insects primarily from an area that had been treated with 

herbicides. However, any exposure that did occur would be limited to the individual bird 

whose territory included the treatment site. These species select sites with vertical structure or 

multiple vegetative layers; therefore foliage would intercept much of the herbicide and it is 

unlikely that a bird would consume its entire diet of contaminated insects. Additionally use 

of typical application rates and PDFs that restrict use of high and moderate risk herbicides 

greatly reduce the potential for a bird to be exposed to toxic levels of herbicide. As a result 

and considering that less than 2 percent of the suitable habitat is proposed for treatment, the 

likelihood that a bird would be in a treatment unit and consume its entire diet of contaminated 

insects is remote. 

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Alternative A 

Alternative A would pose the least risk from herbicide exposure and disturbance during 

treatment due to the fewer number of acres treated and considering EDRR is limited to 

manual treatments only. 

Alternatives B 

Under Alternative B a total of 2,617 acres of suitable gray flycatcher habitat could be treated, 

including 291 acres of aerial spraying and 621 acres of riparian habitat that could be 

broadcast sprayed. Potential for herbicide exposure to the gray flycatcher would be greatest 

under this alternative because the largest amount of suitable habitat would be treated and 

treatment involves aerial application of herbicides, as well as broadcast application of 

herbicides within riparian habitat. All but 32 acres of the areas proposed for aerial application 

would occur on sites infested with yellow star thistle. This species can form near monotypic 

stands; therefore it is unlikely that it would be utilized for foraging and no adverse effects 

from herbicide exposure are anticipated. 

Alternative C 

Treatments proposed under Alternative C and the associated effects (described above) would 

be similar to Alternative B, except that herbicide application within riparian areas would be 

restricted to spot spray and selective techniques only. This would reduce herbicide exposure 

somewhat; however, selective treatment within riparian habitat would not appreciably reduce 

risks and potential effects from herbicide exposure for this species because the gray 

flycatcher is not a riparian species. Effects would be similar to those of Alternatives B and D. 

Alternative D 

Treatments proposed under Alternative D and the associated effects would be similar to 

Alternative B, except that no aerial application of herbicides would occur. Potential for 

herbicide exposure would be reduced on 291 acres because these sites would be treated using 

biocontrols. This reduces risks somewhat from that of Alternatives B and C. However, these 

sites consist primarily of yellow starthistle and are less likely to be used for foraging by gray 

flycatchers; therefore, risks of herbicide exposure are similar to those of Alternatives B and 

C. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new infestations could occur within suitable gray flycatcher habitat 

under these alternatives, although treatment method would vary (see alternative comparison 

above). If this occurs, additional disturbance (all alternatives) and/or herbicide exposure 

(alternatives B, C and D only) could occur. Potential effects from future treatment would be 

similar to those analyzed above because future treatments would use the same herbicides and 

comply with the same PDFs as existing treatments. Consequently it is unlikely adverse 

effects would occur under any alternative. 

Indirect Effects 

Alternative A 

This alternative would reduce invasive plant infestations within suitable gray flycatcher 

habitat; however treatment effectiveness is low. Some of the currently infested areas would 

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go untreated; therefore, invasive plants would continue to spread and native plant diversity 

and suitable gray flycatcher habitat would decline within affected areas. 

Alternatives B through D 

These alternatives allow approximately the same acreage of existing infestations treatment; 

therefore, invasive plant control would be similar. Broadcast spraying would not be used in 

riparian areas under Alternative C, and aerial spraying would not be used in Alternative D; 

however, invasive plants would still be treated. All alternatives also include EDRR treatments 

to control future infestations. 

Alternative B is expected to be most effective at containing, controlling, or eradicating 

existing and future invasive plant infestations within gray flycatcher habitat because of 

reduced costs (i.e. greater acreage treated) and more effective treatment methods. However, 

all alternatives would reduce existing infestations and control new infestations. Effects under 

all alternatives would be the maintenance of native plant diversity and associated gray 

flycatcher nesting/foraging habitat. 

Cumulative Effects 

Alternatives A through D 

It is unlikely that a bird would be exposed to herbicides on other ownerships because of this 

species’ small home range, and considering treatment would not occur during migration.The 

gray flycatcher would likely respond favorably to any activities that result in restoration of 

pinion-juniper/sagebrush habitat (Natureserve 2006), and treatments proposed under the 

action alternatives would help maintain suitable habitat over the long-term. In addition, 

treatments are proposed on less than 2 percent of the Forest-wide habitat and potential for 

adverse effects from herbicide exposure are effectively reduced by PDFs that require only 

typical application rates be used and restrict use of high and moderate risk herbicides; 

therefore, none of the proposed alternatives would measurably contribute to other past, 

present or reasonably foreseeable future activity that may be impacting this species. 

Summary of Effects and Determination for Gray Flycatcher 

Alternative A 

This alternative would not reduce invasive plants within suitable gray flycatcher habitat. 

Also, proposed treatments could result in short-term disturbance and herbicide exposure to 

birds. However, over 99 percent of the suitable gray flycatcher habitat would be unaffected 

and management restrictions would apply, thereby reducing the likelihood of adverse effects 

associated with herbicide exposure. As a result, implementation of Alternative A may impact 

individuals or habitat, but will not likely contribute to a trend towards federal listing or 

cause a loss of viability for the gray flycatcher. 

Alternatives B through D 

Treatments proposed under these alternatives could result in short-term disturbance or 

exposure to herbicides and surfactants. However, all alternatives would maintain or restore 

suitable gray flycatcher habitat within areas affected by invasive plants. As a result, and based 

on the above analysis and the following rationale, implementation of Alternatives B, C and D 

may impact individuals or habitat, but will not likely contribute to a trend towards 

federal listing or cause a loss of viability for the gray flycatcher. 

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• Typical application rates, project PDFs that restrict use of moderate and high risk 

herbicides, and gray flycatcher foraging techniques (forages in areas where canopy would 

reduce contamination) would effectively minimize risk to gray flycatcher from exposure 

to herbicides or surfactants. 

• Over 98 percent of suitable gray flycatcher habitat would be unaffected by treatment and 

the possibility that a bird would occur within a treatment unit is low. 

• Aerial broadcast application of herbicides would occur largely in areas with larger 

invasive plant infestations, which would less likely be selected for nesting or foraging 

habitat. 

• Proposed treatments would result in the long-term maintenance of gray flycatcher habitat. 

Columbia Spotted Frog 

The occurrence of these two species across the Forest varies, though both species occupy 

similar habitat and have similar life history requirements. As a result, the Columbia spotted 

frog and northern leopard frog will be evaluated together. 

Although suitable habitat exists, the northern leopard frog has not been documented on the 

Forest. The Columbia spotted frog occurs in a number of locations on the Wallowa-Whitman 

National Forest and is often found in lakes, ponds, and slow moving perennial streams. 

Currently, none of the locations where the Columbia frog is known to occur contain invasive 

plants. Due to the small size and scattered nature of suitable habitat, it is not known exactly 

how much of the suitable habitat for theses species is currently infested with invasive plants. 

However of the 8,669 acres of shoreline habitat and 2,703 acres of spring habitat, 29 acres 

and 76 acres respectively have known invasive plants. 

All of the currently infested acreage would be treated under Alternatives B through D, 

whereas no spring or shoreline habitat would be treated under Alternative A. Also no 

emergent vegetation would be treated under any of the alternatives considered in this EIS. 

Effects of treatments, biological control, EDRR, and herbicide exposure are discussed under 

the Wildlife Effects Section. The following effects are specific to the northern leopard frog 

and Columbia spotted frog. 

Direct Effects of Treatments 

Alternative A 

Because there are no invasive weed treatments proposed within suitable habitat under 

Alternative A, there are no direct effects anticipated. 

Alternatives B through D 

no emergent vegetation or areas of known occupied habitat would be treated; although all 

alternatives would treat 105 acres of invasive plants within suitable habitat. Both species are 

restricted to aquatic habitat during the breeding season; however, implementation of 

treatment buffers ensures that adult frogs, eggs and larvae are not likely to be disturbed by 

invasive plant treatments during this period. After breeding Columbia spotted frogs will 

disperse into adjacent wetland and riparian habitat. Adults and juveniles would be susceptible 

to trampling and/or disturbance from treatment at that time. The probability that this would 

actually occur is low because the frogs are less likely to inhabit areas infested with invasive 

plants and they tend to jump back into the water whenever they detect disturbance close by. 

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While Alternatives B, C and D would all treat similar acreages of existing and future 

infestations, disturbance and potential nest mortality would vary somewhat. Under 

Alternative C a larger acreage of riparian habitat would be treated with manual methods. 

Although disturbance would increase due to the longer treatment period required (See general 

discussion of treatments), potential for mortality would be reduced. Conversely due to the 

greater acreage of mechanical treatments, Alternatives B and D would likely result in a 

shorter disturbance period, but increase the risk of mortality. 

All alternatives could result in potential disturbance and/or mortality associated with 

proposed invasive plants treatments. However, the northern leopard frog does not currently 

occur on the Forest and considering sites where the Columbia spotted frog are known to 

occur are not currently infested with invasive plants, potential for adverse effects from 

proposed treatments is remote under all alternatives. Also, a pre-treatment assessment (A-1) 

would identify any new sites where the Columbia frog is documented, and treatment methods 

and timing would be adjusted to avoid adverse effects. 

Herbicides 

Alternatives B through D 

Toxicity data for amphibians is much more limited than that available for mammals or birds. 

Appendix P of the R6 2005 FEIS summarized available data on effects of herbicide to 

amphibians and this discussion is incorporated by reference into this analysis. The data on 

amphibians for most herbicides are not sufficient to conduct quantitative estimates of 

exposure. The Forest Service/SERA Risk Assessments use information from the literature, 

when available, and the calculated concentrations of herbicide in water from runoff or 

accidental spill to determine risk to amphibians. For glyphosate and sulfometuron methyl 

there was sufficient data to do a quantitative evaluation of exposure and risk. However when 

data on amphibians was not available, fish were used as a surrogate species (US Forest 

Service 2005). 

Although data is insufficient to evaluate risk of sub-lethal effects, results of the analysis 

indicate that the following herbicides pose a low risk of mortality to amphibians: 

chlorsulfuron, clopyralid, imazapic, imazapyr, metsulfuron methyl, and picloram. The Poast® 

formulation of sethoxydim is much more toxic to aquatic species than is technical grade 

sethoxydim. However use of Poast® is unlikely to result in concentrations in the water that 

would result in toxic effects to aquatic species (SERA 2001).Additionally, implementation of 

herbicide use buffers (described below), effectively eliminate the possibility that a frog would 

be exposed to toxic levels of herbicide.. 

Formulations of glyphosate that contain POEA surfactant are much more toxic to aquatic 

organisms than aquatic-labeled formulations, which do not contain POEA. At the typical 

application rate, concentrations in the water for acute and chronic exposures were well below 

any reported LC 50 for either version of glyphosate, with the exception of one study by Smith 

(2001). The Smith study is not consistent with other reported studies on glyphosate and so 

was not used to establish the threshold of concern for aquatic species in the Glyphosate Risk 

Assessment (SERA 2003 Glyphosate).At the highest application rate, some formulations of 

glyphosate that contain POEA could be lethal to amphibians if runoff from the treatment site 

were to occur (SERA, 2003-glyphosate). However herbicide use buffers (F-3, H-1, H-2, H-3, 

H-8, H-10 through H-12) virtually eliminate the potential for herbicide to be delivered to 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

streams in concentration of concern (USDA FS 2008), and spills are extremely unlikely to 

occur given the many safety precautions in place (S. Bulkin personal communication). 

NPE-based surfactants are known to cause adverse effects to aquatic organisms. A 

quantitative risk assessment for NPE was conducted by Bakke (2003), which included risks 

to aquatic organisms. Estimated concentrations from the operational scenario analyzed (10 

acres of broadcast spray immediately adjacent to water) produced exposures 15-30 times 

lower than the level of concern from all NPE related compounds. Overspray or accidental 

spills could produce concentrations of NPE that could adversely affect amphibians, 

particularly in small stagnant ponds (USDA-FS 2005); although, under normal operations use 

of NPE is not likely to adversely affect amphibians (S. Bulkin personal communication). 

Further, implementation of aquatic buffers (described below) would effectively eliminate 

potential for either species to be exposed to toxic levels of herbicide/surfactant within 

breeding habitat. 

Triclopyr comes in two forms; triclopyr BEE and triclopyr TEA. Triclopyr BEE is much more 

toxic to aquatic organisms than is triclopyr TEA. Triclopyr use at the highest application rate 

could adversely affect responsiveness of tadpoles, subjecting them to increased risk of 

predation. Although some exposure could occur with spot spray or selective applications of 

triclopyr TEA (allowed up to 15 feet of perennial streams, lakes and ponds), spot spray or 

selective applications of Triclopyr BEE are prohibited within 150 feet of perennial and 

intermitted (wet or dry) streams, lakes and wetlands. Also at typical application rates, neither 

version is likely to result in adverse effects to amphibians, using a sub-lethal effect for 

tadpole responsiveness as a threshold of concern. 

Adult frogs could also be dermally exposed to herbicides as they move through treated 

vegetation or soil. There is insufficient data to quantify a dose received from dermal exposure 

to contaminated vegetation or soil, but it is likely to be much less than if the frog was in 

contaminated water and could easily absorb the solution through its skin. There is insufficient data to quantify dose received from dermal exposure to contaminated vegetation. 

However, for the purpose of this analysis, it is assumed that that risk exposure to 

contaminated water adequately assesses risk from all types of herbicide exposure for 

amphibians. Additionally, herbicide use buffers (F-3, H-1, H-2, H-3, H-8, H-10 through H12) that restrict broadcast application of herbicides within breeding habitat and require that 

unsprayed areas provide refugia for amphibians living in a discrete pond, lake or wetland (H9 and H-13), further reduce the likelihood that a frog would be receive toxic levels of 

herbicide through dermal exposure. 

In summary, the actual likelihood of exposing amphibians depends on the application 

method, habitat treated, and season of application. Although potential for exposure to toxic 

levels of herbicides exist, adverse effects to amphibians are greatly reduced by PDFs that 

restrict herbicide application rates, restrict use of high and moderate risk herbicides, and 

require herbicide buffers. More specifically, 1) herbicide use buffers (F-3, H-1, H-2, H-3, H8, H-10 through H-12) virtually eliminate the potential for herbicide to be delivered to 

streams in concentration of concern (USDA-FS 2008?), 2) herbicide restrictions on certain 

soil types (H-4 through H-7) reduce potential for run off and leaching, 3) restrictions on 

extent of treatment in a given site condition (i.e. aquatic influence zone, H-9 and H-13) 

ensure that herbicides would not be delivered in amounts greater than the SERA risk 

assessment scenarios and that unsprayed areas provide refugia for amphibians living in a 

discrete pond, lake or wetland (USDA-FS 2008), and 4) spills are extremely unlikely to occur 

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given the many safety precautions in place (Bilkin personal communication). As a result and 

based on monitoring of similar treatments (Berg 2004), implementation of these PDFs would 

ensure that adverse effects to fish, amphibians and the aquatic resource are avoided (USDAFS 2008?). Finally, prior to any treatment the pre-field assessment (A-1) would confirm the 

presence of SOLI including the Columbia spotted frog and adjust application timing/methods 

or herbicide formulation if necessary to reduce impacts. Collectively for these reasons and 

considering that no occupied sites and only 105 acres of suitable habitat are proposed for 

treatment, it is unlikely that the Columbia spotted frog would be exposed to toxic levels of 

herbicide under any alternative. 

Alternatives B and D 

PDFs under all action alternatives would prevent aerial and broadcast application of 

herbicides within 100 feet of breeding habitat (e.g. streams, lakes and wetlands). Also 

because all herbicides would be restricted to spot spray or selective methods within aquatic 

buffers, and considering that herbicides and surfactants that pose the greatest risk can not be 

applied within 150 feet of suitable habitat, there is very little difference between these 

alternatives in terms of effects to breeding habitat. These alternatives would use broadcast 

application of herbicides within riparian areas outside of these buffers and the potential for 

herbicide exposure would increase if a frog moved outside of the herbicide buffers. However, 

this species would not likely be found within areas dominated by invasive plants that may be 

targeted for broadcast application. Also there are no occupied sites proposed for treatment and 

the pre-field assessment (A-1) would identify if a treatment site was occupied and adjust 

treatment methods, timing or formulation of herbicides if necessary to reduce impacts. 

Consequently and considering that implementation of PDFs (described above) effectively 

reduce the likelihood that this species would be exposed to toxic levels of herbicide, it is not 

anticipated that broadcast treatments proposed outside aquatic buffers under these alternatives 

would result in adverse effects from herbicide exposure to the Columbia spotted frog. 

Alternative C 

Although all alternatives restrict broadcast application within 100 feet of water, some 

broadcast application within riparian areas would occur under Alternatives B and D. This 

species is strongly associated with riparian areas, and considering application of herbicides 

within riparian areas is restricted to spot spray or selective techniques only under Alternative 

C, potential for herbicide exposure (particularly dermal exposure) to Columbia spotted frogs 

would be reduced under this alternative, from that of Alternatives B and D. Similarly, 

because riparian areas would be treated manually, potential for mortality would also be 

reduced. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new infestations could occur within suitable for either species under 

these alternatives; although treatment method would vary (See Alternative Comparison 

above). If this occurs, additional disturbance (all alternatives) or herbicide exposure 

(Alternatives B, C and D only) could occur. Future herbicide treatments would use the same 

herbicides and comply with the same PDFs and management restrictions as currently 

proposed treatments, or if necessary in a new NEPA document. Consequently, effects from 

future treatment under EDRR are the same as described for current infestations and the 

potential for adverse effects is low under all alternatives. 

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Indirect Effects 

Alternative A 

This alternative would reduce invasive plant infestations within suitable northern leopard and 

Columbia spotted frog habitat; however, treatment effectiveness is low. Additionally, some 

areas currently infested would go untreated and because EDRR is limited to manual 

treatments only, it is likely future areas would become established on many sites. 

Collectively for these reasons, invasive plants would continue to spread and native plant 

diversity and suitable habitat for the Columbia spotted frog would decline within affected 

areas. 

Alternatives B through D 

Under these alternatives, approximately the same acreage of existing infestations within 

suitable habitat would be treated, and due to similar herbicide restrictions to stream and 

aquatic habitat, control of invasive plants within breeding habitat would be similar. 

Additionally all treatments include the use of EDRR, so some control of future infestations 

would occur under all alternatives. As a result, all alternatives would reduce existing 

infestations, control new infestations and result in the long-term maintenance of suitable 

habitat for both the northern leopard and Columbia spotted frog. 

Cumulative Effects 

Alternatives A through D 

These species could be exposed to disturbance or mortality from other activities such as 

grazing, road maintenance or recreation that may be occurring within suitable breeding 

habitat. The Columbia spotted frog would not be expected to widely disperse during a single 

season; therefore, it is unlikely an individual would be exposed to other applications of 

herbicides. This species is strongly aquatic and it is unlikely it would occur in patches of 

upland invasive plants. Additionally, invasive treatments are of such low magnitude (105 

aces), short duration and low intensity that no significant effects would occur. Also with 

implementation of PDFs (described above), herbicides proposed for use have a low likelihood 

of causing adverse effects to spotted frogs. As a result, considering there is no occupied 

habitat proposed for treatment, none of the proposed alternatives would measurably 

contribute to any other past, present or reasonably foreseeable future activity and result in 

significant impacts to this species. 

Summary of Effects and Determination for the Columbia Spotted Frog. 

Alternative A 

No treatments are proposed within suitable habitat; therefore, invasive plants would continue 

to expand in suitable breeding and upland Columbia spotted frog habitat. Although the 

probability is low, potential exists for proposed treatments of future sites to result in adverse 

effects to this species. As a result, implementation of Alternative A may impact individuals 

or habitat, but will not likely contribute to a trend towards federal listing or cause a loss 

of viability for Colombia spotted frog. 

Alternatives B through D 

All alternatives would reduce existing and future invasive plant infestations within suitable 

habitat; however treatment could result in adverse effects. As a result, and based on the 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

above analysis and the following rationale, implementation of Alternatives B, C and D may 

impact individuals or habitat, but will not likely contribute to a trend towards federal 

listing or cause a loss of viability for the Columbia spotted frog. 

• There is no occupied Columbia spotted frog habitat proposed for treatment. As a result 

and considering the small amount of habitat proposed for treatment (105 acres) and that 

an existing PDF (A-1) requires that the presence of SOLI species be confirmed prior to 

treatment, it is unlikely that the Columbia spotted frog would occur within a treatment 

site. 

• PDFs which restrict herbicide application rate and use, prevent high risk treatments 

(USDA-FS 2005) within breeding habitat, minimize the likelihood for herbicide exposure 

and limit the extent of treatment within suitable breeding habitat, effectively reduce the 

potential for adverse effects from treatment and exposure to herbicides/surfactants. 

• Proposed treatments would result in the long-term maintenance of native plant diversity 

within suitable breeding habitat for both the Columbia spotted frog.. Also the benefits of 

preventing the future loss of suitable habitat due to invasive plants, outweighs any 

anticipated adverse effects. 

Painted Turtle 

The painted turtle is not documented on the Forest; however, potential habitat exists on 

approximately 8,669 acres. This species has been documented within affected watersheds 

(Natureserve 2008). Twenty nine acres of the existing waterbody and shoreline habitat are 

proposed for treatment under the action alternatives. No treatments would occur within 

suitable habitat under Alternative A. 

Effects of treatments, biological control, EDRR, and herbicide exposure are discussed under 

the Wildlife Effect Section. The following effects are specific to the painted turtle. 

Direct Effects of Treatments 

Alternative A 

This species has not been documented on the Forest, and considering that there are no 

treatments proposed within suitable habitat, there are no direct effects anticipated. 

Alternatives B through D 

Effects of treatments are discussed under the Wildlife Effect Section and any ground based 

treatment could result in short-term disturbance to the painted turtle. In addition, ground 

based mechanical treatments could result in mortality under any of the alternatives. Because 

alternative C would reduce the acreage treated with mechanical treatments within any 

riparian habitat that occurred outside aquatic treatment buffers, the potential for mortality 

resulting from treatment would be reduced somewhat under this alternative. However, PDF J4 requires that the local biologist review all areas proposed for treatment to ensure that known 

painted turtle locations are identified and that treatment timing, methods, or herbicide 

formulations can be adjusted if necessary to reduce impacts. As a result, the likelihood of 

adverse treatment related effects is low under all alternatives. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Herbicides 

Alternatives B through D 

Very little research has been done on the effects of herbicides to reptiles. Hall (1980) stated 

that reptiles are apparently less sensitive than fish and the FS/SERA risk assessments use 

amphibians and/or fish as surrogates for reptiles. While there is no data on the toxicity of 

herbicides to reptiles, amphibians and fish have very permeable skin, more so than reptiles, so 

they are more likely to absorb contaminants from their environment. As a result, potential 

effects to the painted turtle would be similar to those described above under the Columbia 

spotted frog and bald eagle. 

Many reptile species would likely be under some cover during the day, when herbicides may 

be applied. But diurnal reptiles such as the painted turtle could conceivably be sprayed during 

applications, as well as be exposed through contact with contaminated vegetation and soil or 

ingestion of contaminated prey. The actual likelihood of exposing painted turtles depends on 

the application method, size of treatment area, habitat treated, and season of application. 

Because aquatic buffers restrict the use of herbicides within painted turtle breeding habitat to 

spot spray and selective methods only, potential risks to this species from herbicide exposure 

are reduced under all alternatives. Alternative C does not allow broadcast application of 

herbicides within riparian areas outside of these buffers; therefore, potential risks to painted 

turtles dispersing or foraging outside of these buffers would be reduced under this alternative. 

In addition to PDFs that restrict herbicide use/treatment within aquatic habitats, PDF J-5 

requires that the local biologist review treatment locations, timing and methods if necessary 

to minimize adverse impacts to this species. As a result, and considering the small amount of 

suitable habitat proposed for treatment (29 acres) it is unlikely that a painted turtle would 

occur within a treatment area, or be exposed to toxic levels of herbicides under any 

alternative. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new infestations could occur within suitable painted turtle habitat under 

these alternatives, although treatment method would vary (See Alternative Comparison 

above). If this occurs, additional disturbance (all alternatives) or herbicide exposure 

(Alternatives B, C and D only) could occur. Future herbicide treatments would use the same 

herbicides and comply with the same PDFs and management restrictions as currently 

proposed treatments, or if necessary in a new NEPA document. Consequently, effects from 

future treatment under EDRR are the same as described for current infestations and the 

potential for adverse effects is low under all alternatives. 

Indirect Effects 

Alternative A 

No infestations within suitable habitat would be treated, and considering that treatment of 

future sites would be restricted to less effective methods, it is likely that invasive plants 

would spread. If this occurs, native plant diversity and potentially suitable painted turtle 

habitat could be reduced within affected areas. 

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Alternatives B through D 

Under the action alternatives all currently infested suitable habitat would be treated and 

EDRR treatments would be expected to control future infestations. Because herbicide buffers 

restrict the use of aerial application near ponds, lakes and wetlands and considering PDFs 

require that only spot or hand treatments occur within 100 feet of lakes or wetlands, there is 

virtually no difference between alternatives in terms of treatment effectiveness or invasive 

plant control. 

Cumulative Effects 

Alternatives A through D 

Potential cumulative effects to wildlife are discussed under the Wildlife Effect Section. 

Because of the painted turtle’s small home range, it is highly unlikely that any turtles affected 

by proposed activities would be adversely affected by treatments on other ownerships. As a 

result, and with implementation of PDFs to minimize direct effects from treatment, and 

considering only 29 acres of suitable wetland/shoreline habitat would be affected by 

treatment, none of the alternatives would measurably contribute to any other past, present or 

reasonably foreseeable future activity that may be impacting this species and no significant 

cumulative effects are anticipated. 

Summary of Effects and Determination for the Painted Turtle 

Alternative A 

No treatment is proposed within suitable habitat; therefore, invasive plants would continue to 

expand in suitable breeding, foraging and dispersal habitat. Although the probability is low, 

potential exists for proposed EDRR treatments to result in adverse effects to the painted turtle 

if it becomes established on the forest during project implementation. This species has not 

been documented on the forest and considering the small amount of suitable habitat proposed 

for treatment, implementation of Alternative A will have No Impact on the painted turtle.. 

Alternatives B through D 

All alternatives would reduce existing and future invasive plant infestations within suitable 

habitat. Also this species has not been documented on the forest. As a result and based on 

the above analysis and the following rationale, implementation of Alternatives B, C and D 

will have No Impact on the painted turtle. 

• This species has not been documented on the forest. As a result and considering the small 

amount of suitable habitat proposed for treatment (29 acres) and considering PDFs 

require that all sites proposed for treatment be assessed by a local biologist, it is unlikely 

that a painted turtle would occur within a treatment site. 

• Project Design Features that require typical application rates, restrict use of high and 

moderate risk herbicides and require herbicide buffers within suitable breeding habitat, 

effectively reduce the possibility that an individual would be exposed to toxic levels of 

herbicide. 

• Proposed treatments would result in the long-term maintenance of native plant diversity 

within suitable breeding and foraging habitat for the painted turtle. Also the benefits of 

preventing the future loss of suitable habitat due to invasive plants, outweighs any 

anticipated adverse effects.

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3.3.7 Effects to Management Indicator Species 

The purpose of this section is to evaluate and disclose the impacts of the Wallowa-Whitman 

National Forest Invasive Plants Treatment Project on Management Indicator Species (MIS). 

Management indicator species are used in concert with other indicators to gauge the effects of 

management on wildlife habitat.In general, the MIS approach is used to reduce the 

complexity of discussing all wildlife species on the Forest, because MIS represent groups of 

wildlife associated with similar vegetative communities or key habitat components. 

Evaluating the effects of management practices on these species and their habitat also 

displays the effects of alternatives on the ecological communities they represent and helps to 

ensure that biodiversity is maintained. Species identified in the Wallowa-Whitman National 

Forest Land and Resource Management Plan (Forest Plan) (USDA 1990) as MIS includes 

elk, northern goshawk, pileated woodpecker, primary cavity excavators, and American pine 

marten. The following is a discussion of the effects of proposed treatments on these species. 

Rocky Mountain Elk 

Over 95 percent of the Forest provides suitable elk habitat and elk winter and summer range. 

The acreages of invasive plant infestations within suitable habitat are displayed in Table 34. 

Approximately 22,800 acres are proposed for treatment under the action alternatives (Alt. B 

through D) and approximately 5,400 acres would be treated under the no action alternative 

(Alt. A). 

Direct Effects of Treatments 

Alternatives A through D 

Effects of treatments are discussed under the Wildlife Effect Section and include disturbance 

associated with proposed treatments. Less than 1 percent of the total suitable elk habitat on 

the forest is proposed for treatment, and the possibility that elk would be in the treatment area 

is low. However, any animals on-site during treatment would be displaced from the area. The 

length of time they would be displaced would vary by treatment (See Wildlife Effect 

Section); however, any disturbance and displacement would be short term (a few days). Also, 

over 98 percent of all affected watersheds would not be treated, and elk could easily move 

into other areas where suitable forage and cover are available. Consequently, proposed 

treatments would not result in any long-term negative effects for this wide-ranging species. 

There would be no treatment related mortality because elk are highly mobile. None of the 

critical elk calving areas identified by the Forest or Rocky Mountain Elk Foundation are 

proposed for treatment 

Herbicides 

Alternatives A through D 

Mammals that eat vegetation (primarily grass) that has been sprayed with herbicide have 

relatively greater risk for adverse effects because herbicide residue is higher on grass than it 

is on other herbaceous vegetation or seeds (Kenaga, 1973; Fletcher et al. 1994; Pfleeger et al. 

1996). As a result the grazing and browsing habits of elk make it possible for them to walk 

through or consume vegetation that has been sprayed with herbicide. 

At typical application rates only NPE (acute exposure) and triclopyr (chronic exposure) 

exceeded the toxicity dose for large herbaceous mammals consuming contaminated 

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vegetation. However, implementation of PDFs restrict the use of triclopyr to spot spray and 

selective methods only (F-1), and require that NPE surfactant would not be ground based 

broadcast at a rate greater than 0.5 lbs. active ingredient per acre (F-4), which is only 30 

percent of the typical application rate used in the exposure scenario. Although triclopyr is 

approved for use (with restrictions) under Alternative A, NPE would not be applied under this 

alternative, whereas both triclopyr and NPE surfactants would be used under the action 

alternatives. 

In order for an animal to receive an acute dose, it would have to consume nothing but 

contaminated vegetation for its entire day’s diet, whereas it would have to consume 

contaminated vegetation for 90 days to receive a chronic dose. Elk forage selectively and 

often will return to the same areas repeatedly; therefore, they are at risk from possible chronic 

exposure. However, implementation of the above PDFs would greatly reduce the likelihood 

that elk would receive toxic doses that occurred in the exposure scenarios. Additionally the 

following considerations would also be expected to reduce the likelihood that elk would 

receive adverse effects from herbicide exposure: 

• Many broadcast applications of herbicides would occur on large infestations because they 

cannot be controlled effectively using other methods. Invasive plants can greatly reduce 

native plant diversity and areas of large infestations are not likely to contain preferred 

forage species. Also, when considering that elk are sensitive to human-related disturbance 

(Thomas 1979), the possibility that an animal would move into an area infested with 

invasive plants to select forage that would likely be available in undisturbed areas is 

extremely remote. 

• Approximately 23,000 acres of suitable elk habitat are proposed for treatment, which is 

scattered across 53 watersheds. Of the affected watersheds (See Table 41), 50 have less 

than 1 percent of the watershed acreage proposed for treatment and very little suitable 

habitat would be affected within any watershed. Additionally use of typical application 

rates and PDFs that restrict use of high and moderate risk herbicides and provide for 

herbicide buffers and un-treated areas along streams and riparian areas, effectively reduce 

the likelihood that an individual would be exposed to toxic levels of herbicide. As a result 

and considering that only 1 percent of the forest-wide suitable habitat is proposed for 

treatment, and that elk forage over large areas and do not prefer to forage within areas 

dominated by invasive plants, it is unlikely that elk would either consume all of their 

daily vegetation from a treatment area, or forage within treatment areas for 90 days (i.e. 

exceed acute or chronic NOAEL). 

• Approximately 50 percent of the elk habitat proposed for treatment occurs within 200 

feet of road and most of these treatment areas occur as narrow linear strips along the road 

row. Elk are known to forage along roads; although it is unlikely they would forage 

exclusively along these narrow corridors, particularly if they are infested with invasive 

plants. Additionally, elk avoid areas with open roads (Thomas 1979); therefore, many of 

these treatment areas would not provide preferred foraging habitat. 

In summary, use of triclopyr is restricted under Alternative A and PDFs for the action 

alternatives would ensure that triclopyr would not be broadcast sprayed, and that NPE 

surfactants would only be applied at levels well below typical application rates. As a result, it 

is unlikely that elk would be exposed to toxic levels of herbicide under any alternative 

considering, in addition, that less than 1 percent of suitable habitat would be affected, and elk 

would avoid many of the roadside areas proposed for treatment, and that many areas 

proposed for broadcast treatment would contain little preferred forage. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Alternative A 

Approximately 31 percent of existing invasive plant sites would be treated under this 

alternative. While this alternative would not apply NPE surfactants, tryclopyr, glyphosate 

and picloram could be used with restrictions. Although the potential exists, based on the 

analysis presented above, it is unlikely that elk would receive toxic doses of herbicides under 

this alternative. 

Alternative B 

Under Alternative B a total of 22,842 acres would be treated, including 13,566 acres of 

broadcast and spot spray/selective treatments and 875 acres of aerial spraying in upland areas, 

3,104 acres of ground based broadcast treatment and 3,241 acres of spot spray/selective 

treatments in RHCAs, 1,955 acres of biocontrol only and 111 acres of manual treatment only 

in uplands or RHCAs. 

Herbicide buffers would restrict broadcast application of surfactant and herbicides within 150 

ft of all streams, waterbodies and wetlands; however, broadcast application of herbicides 

could occur within riparian areas outside these buffers. Elk make disproportionate use of 

areas within 1,050 feet of water (Thomas 1979), and broadcast application of herbicides 

could occur within riparian areas; therefore, potential for herbicide exposure within these 

areas would likely be greater than the adjacent uplands. This would vary depending on the 

availability of cover, which ultimately determines use of an area by elk (Thomas 1979). Also, 

many of these riparian areas are along open road corridors which would less likely be used, 

and larger infestations would not provide preferred foraging habitat. 

Herbicides would be aerially applied on 875 acres under this alternative. As described under 

the Wildlife Effect Section, because aerial application would apply herbicides to larger areas, 

greater amounts of non-target vegetation could be contaminated, potentially increasing the 

risk that elk would consume contaminated vegetation. All but 32 acres of proposed aerial 

spraying would occur on sites that are infested with yellow star-thistle. This species is 

aggressive, and can form dense near-monotypic infestations (Ditomaso J.M. 2006), which can 

greatly reduce native plant diversity. As a result, it is unlikely that elk would be foraging in 

these areas. Additionally PDFs F-8a through F-8o: 

• Restrict the use of chlorsulfuron, metsulfuron methyl and sulfometuron during aerial 

application 

• Restrict application rates for picloram and clopyralid 

• Prevent spraying within sites that have 30 percent or more live tree canopy 

• Require on-site inspection for areas that have between 10 and 29 percent cover 

• Require constant communication between the helicopter and ground observers 

Collectively these PDFs would reduce the potential for vegetation to be sprayed with levels 

of herbicide that would result in a toxic dose to elk, and reduce the likelihood that an animal 

would be directly sprayed during implementation. 

Alternative C 

Treatments proposed under Alternative C and the associated effects (described above) would 

be similar to Alternative B, except that herbicide application within riparian areas would be 

restricted to spot spray and selective techniques only. This would reduce the potential for 

herbicide exposure on the 3,104 acres of riparian habitat that could be broadcast sprayed 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

under Alternatives B and D. As a result, and because elk prefer to forage within riparian 

areas, this alternative would result in the least risk of herbicide exposure to elk of all the 

action alternatives. 

Alternative D 

Treatments proposed under Alternative D and the associated effects (described above) would 

be similar to Alternative B, except that no aerial application of herbicides would occur. 

Because these sites would be treated using bio-control methods, potential for herbicide 

exposure would be reduced on this acreage (875 acres). Although this reduces risks 

somewhat on these sites from that of Alternatives B and C, because these sites consist 

primarily of yellow star thistle, they are less likely to be utilized by elk. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new invasive plant infestations could occur within suitable elk habitat 

under these alternatives, although treatment method would vary (See Alternative Comparison 

above). If this occurs, additional disturbance (all alternatives) and herbicide exposure 

(Alternatives B, C and D only) could occur. Future herbicide treatments would use the same 

herbicides and comply with the same PDFs and management restrictions as currently 

proposed treatments, or if necessary in a new NEPA document. Consequently, effects from 

future treatment to elk under EDRR are the same as those described for current 

infestations,and it is unlikely that adverse effects would occur under any alternative. 

Indirect Effects 

Alternatives A through D 

The same factors that put elk at greater risk from herbicide exposure (i.e. forage primarily in 

open areas with grasses and forbs) also result in a greater risk to this species from the loss of 

habitat due to invasive plants. This is because invasive plants out compete and replace native 

forage species used by ungulates such as elk. Also, habitats that become dominated by 

invasive plants are often not used or used much less by native and rare wildlife species and a 

decrease in available foraging habitat for elk and other big game is possible (Rice et al. 

1997). Invasive plants may also contribute to changes in elk distributions and densities 

(Bedunah and Carpenter 1989; Rice et al.1997; in USDA Forest Service 2005). Also some 

hunters and wildlife managers are concerned that invasive plants are degrading the quality of 

remaining habitat for deer and elk and are adversely affecting the animal’s distribution and 

hunting opportunities. 

Invasive plants can reduce the ability of an area to support deer and elk (Rice et al. 1997), and 

considering that invasive plants have been increasing on the Forest and are expected to 

continue to increase in the future (See Figure 16), the potential exists for elk to experience a 

long-term loss habitat. The following is a discussion of how effectively the alternatives 

evaluated address this concern. 

Alternative A 

Over 75 percent of the existing invasive plant infestations within suitable elk habitat would 

not be treated under this alternative. Also, EDRR is limited to manual treatments only. While 

this would help to contain invasive plants in some locations, they would continue to expand 

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on sites where plant morphology or size of the infestation makes manual treatment 

ineffective. As a result, and considering that more effective herbicides are not approved for 

treatment, invasive plants would continue to expand within affected watersheds and result in 

the long-term loss of elk foraging habitat. Although Forest-wide elk distribution would 

remain relatively unchanged, there might be localized shifts in elk use within some 

watersheds. 

Alternatives B through D 

Approximately the same acreage of existing infestations would be treated and invasive plant 

control would be similar. Broadcast spraying would not be used in riparian areas under 

Alternative C, and aerial spraying would not be used in Alternative D; however, existing and 

future invasive plants infestations would still be treated. All alternatives include a wide range 

of EDRR treatments to control future infestations. 

Alternative B is expected to be most effective at containing or eradicating existing and future 

invasive plant infestations within elk habitat because of reduced costs (i.e. greater acreage 

treated) and more effective treatment methods. However, all alternatives would reduce 

existing and control new infestations, and effects under all alternatives would be the longterm maintenance of native plant diversity, elk foraging habitat and distribution and use of the 

Forest by elk. 

Cumulative Effects 

Alternatives A through D 

Cumulative effects considerations are discussed under the Wildlife Effect Section. use of the 

forest by elk occurs on multiple ownerships; therefore, anticipated cumulative effects include 

possible exposure to herbicides and disturbance from on-going land uses on other 

ownerships, as well as continued disturbance associated with use of National Forest System 

lands. The proposed use of herbicides on and off National Forest System lands could also 

result in additive doses of herbicides to elk. For this to occur, the two exposures would have 

to occur at approximately the same time. This is unlikely since the herbicides proposed are 

rapidly eliminated and do not significantly bio-accumulate (R6 2005 FEIS). Also with 

implementation of PDFs that restrict herbicide application and use, provide herbicide buffers 

along streams, waterbodies and riparian areas, minimize drift from broadcast and aerial 

application, require monitoring during all aerial application, and require pre-treatment 

assessment to confirm species/habitats of local interest. 

The risk of exposure to herbicide/treatments is further reduced by the fact that 99% of the 

Forest-wide habitat would be unaffected by treatment, that many areas proposed for treatment 

do not provide preferred forage, and that many of the sites treated occur along open roads 

which are less likely to be used by elk. As a result, and considering that the long-term 

improvement in elk foraging habitat outweighs anticipated adverse effects, none of the 

alternatives would measurably contribute to any other past, current or reasonably foreseeable 

future activity that may be impacting this species and there are no significant cumulative 

effects anticipated. 

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Summary of Effects and Determination for Elk 

Alternative A 

Proposed treatments could result in short-term disturbance and herbicide exposure to elk; 

though over 99 percent of the Forest-wide habitat would be unaffected and management 

restrictions would reduce the likelihood of adverse effects associated with herbicide exposure. 

As a result, there are no effects that would be expected to alter local populations of elk. 

However, 75 percent of existing invasive plant infestations would not be treated and 

treatments approved under this alternative would not be expected to be effective on many 

future sites where invasive plants become established. As a result there might be some 

localized changes in elk distribution and use within affected watersheds. 

Alternatives B through D 

Treatments proposed under these alternatives could result in disturbance and herbicide 

exposure to elk; however, all alternatives would result in the long-term maintenance of elk 

foraging habitat across the Forest. Also, although adverse impacts are possible, based on the 

above analysis and the following rationale, there are no effects that would alter local 

populations or adversely affect distribution and use of the Forest by elk. 

• Ninety nine percent or more of the Forest-wide suitable elk habitat would be unaffected. 

Many of the treatments would occur along open road corridors that are avoided by elk. 

• Much of the broadcast/aerial application of herbicides would occur in large infestations 

of invasive plants, which would not provide desired forage and would not likely be 

utilized by elk. 

• With implementation of PDFs that restrict herbicide application and use, provide 

herbicide buffers along streams, waterbodies and riparian areas, minimize drift from 

broadcast and aerial application, require monitoring during all aerial application, and 

require pre-treatment assessment to confirm species/habitats of local interest, potential 

adverse effects associated with herbicide exposure are greatly reduced. 

• If left untreated, potential exists for invasive plants to result in a long-term loss of elk 

foraging habitat. These alternatives would result in the long-term maintenance of elk 

habitat across the Forest, and benefits of invasive plant control resulting under these 

alternatives would outweigh any anticipated adverse effects associated with treatment. 

Northern goshawk 

The home range of the northern goshawk includes a diversity of successional stages; 

however, this species is closely tied to mature late-successional forest with closed canopies 

(>40%) and complex stand structure (multiple canopy layers and dead wood) (Reynolds et al. 

1992). As a result, there are no treatments proposed within preferred goshawk nest habitat. 

Treatments may occur within foraging habitat or in close proximity of suitable nest habitat. 

As a result, proposed treatments could potentially adversely affect this species. 

Direct Effects 

Alternatives A through D 

Treatment effects are discussed under the Wildlife Effect Section. Because there are no 

treatments proposed within preferred nest habitat, there are no adverse effects to nesting birds 

under any alternative. The pre-treatment assessment (A-1) would identify any treatment areas 

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near active nests and treatment timing would be adjusted to avoid impacts. Goshawk forage 

in a wide variety of forest structural stages, as well as small openings; therefore, it is possible 

that foraging birds could be affected by treatments. If this occurs, there would be short-term 

disturbance until the birds moved out of the area; however any effect would be of limited 

extent since unaffected foraging habitat is widely available. 

This species is highly mobile and primarily occurs within closed canopy forested habitat; 

therefore, it would not be directly sprayed. However, goshawks are classified as prey 

generalists (Squires and Reynolds 1997) and typically forage on a suite of 8–15 species 

including a variety of small mammals and birds (Reynolds et al. 1992). As a result, there is a 

possibility that a bird could forage on prey that had been exposed to herbicides and potential 

effects to this species were evaluated by looking at the predatory bird scenario. At the typical 

application rate, no herbicide or surfactant exceeded the lowest reported NOAEL for a 

predatory bird consuming small mammals. Also, PDFs that restrict use of high and moderate 

risk herbicides, prevent aerial application from occurring within forested areas preferred for 

nesting and foraging, and require pre-treatment assessment to confirm species/habitats of 

local interest, collectively would reduce impacts to non-target wildlife such as the northern 

goshawk. Further, preferred forest habitat where most prey would be taken would not be 

sprayed, and the northern goshawk forages over a large area and would not consume all of its 

daily diet from contaminated prey. Collectively for these reasons, the likelihood that a bird 

would receive a toxic dose of herbicides is not considered plausible. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new invasive plant infestations could occur within suitable northern 

goshawk foraging habitat under these alternatives, although treatment method would vary 

(See Alternative Comparison above). If this occurs, additional disturbance (all alternatives) 

and herbicide exposure (Alternatives B, C and D only) could occur. Future herbicide 

treatments would use the same herbicides and comply with the same PDFs and management 

restrictions as currently proposed treatments, or if necessary in a new NEPA document. 

Consequently, effects from future treatments under EDRR are the same as those described for 

current infestations, and adverse effects related to herbicide exposure/treatment would not be 

expected to occur under any alternative. 

Indirect Effects 

Alternatives A through D 

Invasive plants generally do not occur within closed canopy forest preferred by this species; 

therefore, they are not adversely affecting northern goshawk habitat and there are no indirect 

effects to goshawk habitat anticipated under any alternative. 

Cumulative Effects 

Alternatives A through D 

Cumulative effect considerations are discussed under the Wildlife Effect Section. goshawk 

forage over large areas; therefore, anticipated cumulative effects include possible exposure 

herbicides and disturbance from on-going land uses on other ownerships, as well as continued 

disturbance associated with use of National Forest System lands. However, preferred nest 

habitat would be unaffected and only a small amount of dispersal and foraging habitat would 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

be affected (<1% of the forest) by treatment. As a result, and considering that PDFs that 

restrict herbicide use and application and this species foraging behavior effectively reduce the 

possibility of a bird being exposed to toxic levels of herbicides, none of the alternatives 

would measurably contribute to any other past, current or reasonably foreseeable future 

activity that may be impacting this species and there are no significant cumulative effects 

anticipated. 

Summary of Effects and Determination for Northern Goshawk 

Alternatives A through D 

Potential exists for the northern goshawk to be adversely affected by proposed treatments, 

though preferred forested habitat would be unaffected and this species would not be exposed 

to toxic levels of herbicides. As a result, effects would be short term and of limited extent. 

Also, there are no adverse effects related to reproduction or recruitment. Consequently, there 

would be no effects to local populations and distribution, and use of the Forest by this species 

would remain unchanged. 

Pileated Woodpecker and Cavity Excavators 

These species utilize similar habitat and all prefer or require snags and dead and downed 

woody debris, although preferred habitat varies; therefore, they are evaluated together. 

Suitable habitat for all species occurs largely within forested stands, although some species 

such as the mountain bluebird utilize openings or savannas. Also, while forested stands are 

preferred, some species such as the pileated woodpecker will forage in stands with as little as 

10 percent forested cover (Samson 2006). Consequently, suitable habitat for the pileated 

woodpecker as well as many other cavity excavators could occur within treatment areas. 

Direct Effects 

Alternatives A through D 

There are no direct effects to nests or young which have not fledged because all species nest 

in cavities. It is possible that adults could be disturbed for a short period during nesting, but it 

is unlikely they would leave the nest cavity long enough to result in mortality. Also, foraging 

birds disturbed would move into unaffected suitable habitat. Considering the small amount of 

suitable habitat affected, any disturbance related effects would be minor and of limited extent. 

The diet of some species includes vegetative material (e.g. seeds); nevertheless, all species 

utilize insects as their primary food source. Some species (e.g. Lewis’ woodpecker, northern 

flicker, mountain bluebird) may feed on the ground or in low shrubs that may have been 

affected by treatment; however, most insects utilized by these species occur within dead 

wood, under bark, or are taken from areas that would not be exposed to herbicides. 

Additionally use of typical application rates and implementation of PDFs that restrict use of 

high and moderate risk herbicides, prevent aerial application from occurring over 

predominately forested habitat, and prevent broadcast application along streams and riparian 

corridors, further reduce the potential for adverse effects from herbicide exposure. 

Collectively for these reasons and considering that most preferred forested habitat would be 

unaffected, it is not expected that the pileated woodpecker or any cavity excavator would be 

exposed to toxic levels of herbicide under any alternative. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new invasive plant infestations could occur within suitable habitat for the 

pileated woodpecker and other cavity nesting species; although treatment method would vary 

(See Alternative Comparison above). If this occurs, additional disturbance (all alternatives) 

and herbicide exposure (Alternatives B, C and D only) could occur. Future herbicide 

treatments would use the same herbicides and comply with the same PDFs and management 

restrictions as currently proposed treatments, or if necessary in a new NEPA document. 

Consequently, effects from future treatment under EDRR are the same as those described for 

current infestations and it is unlikely that adverse effects would occur under any alternative. 

Indirect Effects 

Alternatives A through D 

Some species utilize insects associated with shrubs or herbaceous vegetation that could be 

affected by invasive plants; however, these communities make up a minor component of the 

habitat for cavity nesting species. Overall, invasive plants do not adversely affect habitat for 

these species. As a result indirect effects to habitat are minor under all alternatives. 

Cumulative Effects 

Alternatives A through D 

Proposed treatments may result in short-term disturbance during treatment; although suitable 

habitat for these species would remain unchanged and there are no long-term adverse effects 

to the pileated woodpecker or any cavity excavating species anticipated. Short-term impacts 

to these species may occur; and would be of limited (localized) extent, though none of the 

alternatives add to any other past, present or reasonably foreseeable future activity that may 

be impacting these species and there are no significant cumulative effects anticipated. 

Summary of Effects and Determination for Cavity Excavating Species 

Alternatives A through D 

Potential exists for the pileated woodpecker and other cavity excavating species to be 

adversely affected by proposed treatments; although preferred forested habitat (e.g snags) 

would be unaffected and no long-term effects are anticipated. 

Aerial spraying would not occur over forest canopy. Most of the acres to be aerial sprayed 

are in more open areas. The above ground location of cavity nests is above the point where 

broadcast herbicides would be applied. The down wood used for nesting is not usually 

located along roads, which is where much of the treatments are located. As a result, there are 

no effects to local populations and distribution and use of the forest by these species would 

remain unchanged. 

American Marten 

Pine marten prefer mature and old growth forest with multiple canopy layers and large 

amounts of snags and downed woody debris. As a result, preferred habitat is largely 

unaffected by invasive plants or proposed treatments. However, some sites have canopy gaps 

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large enough for invasive plants to become established, and of the 174,956 acres of forestwide suitable habitat 941 acres contain invasive plants. 

There is no suitable marten habitat proposed for aerial spraying and less than 10 acres occur 

within riparian areas. As a result there is little difference between alternatives in terms of 

treatment; although less than 20 percent of existing infestations would be treated under 

Alternative A. 

Direct Effects of Treatments 

Alternatives A through D 

Direct effects from invasive plant treatments are discussed under the Wildlife Effect Section. 

Invasive plant treatment sites do not occur within preferred marten habitat because marten are 

closely associated with heavily forested areas and tend to avoid areas that lack overhead 

cover. However, invasive plant infestations that occur along disturbed roadsides or forested 

areas used during foraging and dispersal by this species could be directly affected by 

proposed treatments. 

Effects of treatments are discussed under the Wildlife Effect Section. However due the small 

and scattered nature of treatment areas, any animal disturbed would move into unaffected 

habitat. As a result any effects would be short term and localized. 

Herbicides 

Alternatives A through D 

Treatments are not proposed in preferred habitat; therefore, potential for exposure to 

herbicides is low. However, an individual could move through an area that has been sprayed 

and come into direct contact with herbicides or ingest contaminated prey. At typical 

application rates there are no herbicides that exceeded the toxicity index for an acute 

exposure to carnivorous mammal and only triclopyr could result in possible chronic effects if 

broadcast sprayed. However, with implementation of PDF F-1 triclopyr is restricted to 

selective treatment only. Potential for exposure of marten to herbicides is further reduced by 

the fact that marten prefer forested areas that are less likely to contain invasive plants, that 

less than 1 percent of the forest-wide suitable habitat is proposed for treatment and that they 

forage over large areas and would not consume all of their diet from contaminated prey. As 

result there are no adverse effects from herbicide exposure anticipated under any alternative. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new invasive plant infestations could occur within suitable habitat 

marten habitat, although treatment method would vary (See Alternative Comparison above). 

If this occurs, additional disturbance (all alternatives) and herbicide exposure (Alternatives B, 

C and D only) could occur. However, future herbicide treatments would use the same 

herbicides and comply with the same PDFs and management restrictions as currently 

proposed treatments, or if necessary in a new NEPA document. Consequently, effects from 

future treatment under EDRR are the same as those described for current infestations and no 

long-term adverse effect would occur under any alternative. 

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Indirect Effects 

Alternative A 

Alternative A treats fewer acres of existing invasive plant infestation Forest-wide, restricts 

chemical control to only three herbicides (See Chapter 2) and would not use herbicides to 

more effectively control future infestations. Collectively for these reasons, invasive plants 

would continue to increase. This could result in a localized decrease in habitat for some prey; 

however, because preferred closed canopy habitat would not likely become infested with 

invasive plants, any effects to marten habitat would be minor. 

Alternatives B through D 

All alternatives would reduce existing and control new infestations within suitable marten 

habitat. Closed canopy forest is not affected by invasive plants; therefore, there would be 

little change in preferred marten habitat under any alternative. Alternatives B through D 

would control or contain invasive plants within foraging and dispersal habitat. Effects to 

marten would be the maintenance of native plant diversity and habitat for prey species within 

the affected watersheds. 

Cumulative Effects 

Alternatives A through D 

Anticipated cumulative effects to wildlife are discussed under the Wildlife Effect Section and 

include possible exposure to herbicides and on-going land uses on other ownerships and 

continued disturbance associated with use of National Forest System lands. The proposed use 

of herbicides on and off National Forest System lands could result in additive doses of 

herbicides to marten. Although for this to occur, the two exposures would have to occur 

approximately at the same time. This is unlikely since the herbicides proposed are rapidly 

eliminated and do not significantly bio-accumulate (R6 2005 FEIS). Also, the application 

rates and extent considered in this EIS are unlikely to result in additive doses beyond those 

evaluated for chronic and acute exposures in the USDA Forest Service risk assessments. 

The risk of exposure to herbicide is further reduced by the fact that preferred closed canopy 

marten habitat is less likely to be affected by invasive plants. marten could be adversely 

affected by other activities on National Forest System lands as well as other ownerships; 

though due to the small amount of suitable habitat proposed for treatment (< 1% of the 

Forest), and considering that suitable habitat on other lands would not likely be treated with 

herbicides, none of the alternatives would contribute to any other past current or reasonably 

foreseeable future activity that may be impacting these species and there are no significant 

cumulative effects anticipated. 

Summary of Effects and Determination to Marten 

Alternatives A through D 

Potential for adverse effects to marten exists under all alternatives; though based on the 

analysis described above and the following rationale, effects would be short-term. Also, there 

are no adverse effects related to reproduction or recruitment of local populations. 

Distribution and use of the Forest by pine marten would remain unchanged. 

• Over 99% of the forest-wide pine marten habitat would be unaffected under all 

alternatives and it is unlikely that an animal would occur within a treatment site 

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• Use of typical application rates and implementation of PDFs that restrict use of high 

and moderate risk herbicides would effectively reduce any potential adverse effects 

associated with herbicide exposure. 

3.3.8 Effects to Other Species of Interest 

Landbirds/Focal Species 

Landbirds, focal species, and priority and unique habitats of local interest were identified in 

the Affected Environment Section of this analysis (Also See Table 33). Potential effects vary 

greatly by species. For species that utilize primarily closed canopy forests there would be few 

if any adverse effects because these areas are generally not infested with invasive plants and 

would less likely be proposed for treatment. Also, potential effects to cavity nesting species 

were described above. As a result the evaluation presented here will focus on species that 

occupy habitats at risk from invasive plant infestations including openings and early 

successional habitat, as well as priority and unique habitats at risk such as dry forest, riparian 

woodland and mountain meadow, and steppe shrublands. 

Direct Effects 

Alternatives A through D 

General effects of treatment methods were described under the Wildlife Effect Section. Any 

species occupying a site during treatment would be disturbed from equipment or human 

activity on the site. For species that nest in trees effects would be limited largely to shortterm disturbance, whereas nest and egg mortality could occur for species that nest on the 

ground or in low growing shrubs. Treatment areas are small and widely scattered and 

considering the small acreage of potentially suitable habitat proposed for treatment, potential 

risks of mortality would be low and of limited extent (i.e. localized). 

The diet of many species includes herbaceous material; nevertheless, all species forage on 

insects and effects from herbicide exposure are evaluated under the insectivorous bird 

scenario. At typical application rates only NPE surfactant and triclopyr if broadcast sprayed 

exceeded acute (100% of the daily diet consists of contaminated forage) toxicity thresholds 

(see Appendix P of R6 2005 FEIS) for small insectivorous birds. Implementation of PDFs 

would limit the use of triclopyr to spot spray and selective methods only (F-1). NPE would 

only be applied at levels well below the typical application rate (F-4). 

Risks of herbicide exposure would be greater for species with small territories, if most of 

their territory occurred within a treatment area; however treatment areas are widely scattered. 

Foliage would intercept much of the herbicide applied, reducing the likelihood that a bird 

would consume its entire diet of contaminated insects. So while the possibility exists, 

considering the small amount of any community proposed for treatment and considering that 

many areas proposed for broadcast treatment would not provide preferred habitat, the 

likelihood that a bird’s entire territory would occur within a treatment unit, and that it would 

be exposed to toxic levels of herbicides is low. 

Alternative A 

Alternative A would pose the least risk from herbicide exposure and disturbance during 

treatment due to the fewer number of acres treated and considering EDRR treatments are 

limited to manual methods. 

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Alternative B 

Under Alternative B a total of 22,842 acres would be treated, including 875 acres of aerial 

spraying and 3,105 acres of riparian habitat that could be broadcast sprayed. This alternative 

would treat the largest acreage, and because treatment involves aerial application of 

herbicides as well as broadcast application of herbicides within riparian habitat, the potential 

for herbicide exposure to landbirds in general, as well as riparian focal species would be 

greatest under this alternative. All but 32 acres of the areas proposed for aerial application 

would occur on sites infested with yellow starthistle. This species can form near monotypic 

stands; therefore, it is unlikely that these areas would be utilized for foraging, reducing the 

potential for adverse effects from herbicide exposure. 

Alternative C 

Treatments proposed under Alternative C and the associated effects (described above) would 

be similar to Alternative B, except that herbicide application within riparian areas would be 

restricted to spot spray and selective techniques only. As a result, potential risks of herbicide 

exposure are reduced for riparian dependent species. Also because this alternative controls 

invasive plants as well as reduces the potential for exposure to riparian focal species, this 

alternative best meets the conservation strategy identified for riparian woodland and shrub 

habitat identified in Altman (2006). 

Alternative D 

Treatments proposed under Alternative D and the associated effects would be similar to 

Alternative B, except that no aerial application of herbicides would occur. These sites would 

be treated using bio-control methods; therefore, potential for herbicide exposure would be 

reduced for species that utilize the steep and relatively rugged areas on this acreage. These 

areas are largely infested with yellow starthistle; therefore, they do not provide preferred 

foraging habitat. 

Early Detection Rapid Response 

Alternatives A through D 

Future treatments to new invasive plant infestations could occur within suitable landbird 

habitat susceptible to invasive plants, although treatment method would vary (See Alternative 

Comparison above). If this occurs, additional disturbance mortality (all alternatives) or 

herbicide exposure (Alternatives B, C and D only) could occur. However, future herbicide 

treatments would use the same herbicides and comply with the same PDFs and management 

restrictions as currently proposed treatments, or if necessary in a new NEPA document. 

Consequently, effects from future treatment under EDRR are the same as those described for 

current infestations, and it is unlikely that adverse effects would occur under any alternative. 

Indirect Effects 

Alternative A 

This alternative would reduce 23 percent of existing invasive plant infestations; therefore, 

treatment effectiveness is low. Some areas currently infested would go untreated, and 

because EDRR is limited to manual treatments only, it is likely future areas would become 

established on many sites. Collectively for these reasons, invasive plants would continue to 

spread and native plant diversity and suitable habitat for landbirds would be reduced on sites 

susceptible to invasive plants. 

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Alternatives B through D 

The effectiveness of some treatments would vary somewhat because approximately the same 

acreage of existing infestations would be treated; therefore, control of existing infestations 

would be similar. Additionally, all treatments include the use of EDRR, so some control of 

future infestations would occur under all alternatives. As a result, all alternatives would result 

in the long-term maintenance of priority and unique habitat susceptible to invasive plant 

infestations, as well as maintain native plant diversity and migratory bird habitat across the 

Forest. 

Cumulative Effects 

Alternatives A through D 

Anticipated cumulative effects are discussed under the Wildlife Effect Section. Because of 

the small home range for most species during the breeding season when invasive plant 

treatments would occur, it is unlikely that the same birds affected by treatment, would be 

exposed to herbicide application or other sources of disturbance on other ownerships. 

Although additional effects could occur from other land uses on NFS lands such as opening 

maintenance/burning or grazing or timber harvest. While all alternatives would result in some 

level of risk from possible herbicide exposure, short-term disturbance, or nest mortality, due 

to the small amount of any vegetative community proposed for treatment, as well as the 

widespread nature of treatment sites, any adverse effects are of limited extent. Also habitat for 

most species would be unaffected. As a result, and considering that the proposed treatments 

would reduce impacts to native plant diversity and suitable landbird habitat, none of the 

proposed alternatives would measurably contribute to any other past, present or reasonably 

foreseeable future activity that may be impacting these species and there are no significant 

cumulative effects anticipated. 

Summary of Effects and Determination for Landbirds, Focal Species and Priority or 

Unique Habitats 

Mesic mixed conifer, subalpine forest, aspen and alpine communities are generally not 

threatened by invasive plants, and there would be little change in these communities or the 

species that depend on them under any alternative. However, dry forest, riparian woodland 

shrub, mountain meadow, and steppe shrublands are being adversely affected by invasive 

plants. The following determinations pertain to these habitats and their associated species, as 

well as landbirds occupying other vegetative communities proposed for treatment. 

Alternative A 

Treatments proposed under this alternative could adversely affect landbirds and focal species 

of the affected communities; however, potential effects would be localized and there are no 

changes to populations or diversity anticipated. Not all areas currently infested with invasive 

plants would be treated, and future treatments are not approved; therefore, invasive plant 

populations would continue to reduce native plant diversity and landbird habitat. Forest-wide 

distribution and use for affected landbirds and focal species would be relatively un-changed 

over the long term; however, there would be a reduction in habitat for these species within 

affected watersheds. 

Alternatives B through D 

Potential exists for landbirds and focal species that occupy communities susceptible to 

invasive plants to be adversely affected by proposed treatments based on the analysis 

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presented above; although the likelihood of adverse effects is low. As a result, and 

considering the small acreage proposed for treatment, there are no adverse effects to 

populations of landbirds or focal species anticipated. Additionally, these alternatives would 

restore areas currently affected by invasive plants and prevent the spread of future 

infestations. Consequently, implementation of these alternatives would result in the long-term 

maintenance and improvement of the dry forest, riparian woodland shrub, mountain meadow 

and steppe shrublands communities, as well as forest and non-forested landbird habitat that 

are susceptible to invasive plants. 

3.4 Soil and Water 

3.4.1 Introduction 

The effect of invasive plant treatments on soil and water is a primary public issue. 

Specifically, there is concern that herbicide treatment may have the potential to adversely 

affect soils, water quality, and aquatic ecosystems. 

While other types of treatments are analyzed, the primary focus of this section is the effect of 

herbicide treatments on soil and water resources. Project Design Features were developed to 

minimize the effects of invasive plant treatments on these resources. Predictions on risk to 

subsurface and surface water resources used the SERA risk assessments in the context of 

modeling with local soil and rainfall conditions. Risk was evaluated using the Groundwater 

Loading Effects of Agricultural Management Systems (GLEAMS) modeling for each of the 

ten herbicides permitted for use in the Wallowa-Whitman Forest Plan as amended by the R6 

2005 ROD. 

Impacts related to soils were evaluated based on soil drainage characteristics, the ability of 

soils to bind herbicides, and the relative impact on soil organisms. 

Special consideration was given to areas that have high leaching potential and high potential 

rainfall runoff such as clay soils. Appendix D lists the inventoried invasive plant sites located 

on well drained soils, clays, and shallow water tables. 

Project Area 

The project area for direct and indirect effects for water resources is the Wallowa-Whitman 

National Forest and lands administered by the Forest (approximately 2.39 million acres). 

Cumulative effects analysis is on the basis of all 5th field watersheds within WallowaWhitman National Forest System lands. Approximately 38 percent of the total area of these 

watersheds is National Forest System lands. 

The project area for soils is the weed infested sites currently under consideration for 

treatment. Invasive plants currently occur on approximately 22,842 acres of the WallowaWhitman National Forest. 

Methodology for Analysis 

This analysis is tiered to the 2005 R6 Invasive Plant FEIS 2005. A primary focus of the sitespecific analysis was developing Project Design Features to insure compliance with standards 

introduced by Region 6 as well as Wallowa-Whitman National Forest Plan standards and 

guidelines. Information used to develop criteria to minimize effects from treatment included 

properties of herbicides from SERA risk assessments, properties of soils in relation to 

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herbicide properties, proximity of treatment sites to streams, stream/road connectivity and 

acres of proposed treatment for each 5th field watershed. To compare alternatives, the acres 

treated by non-herbicide and herbicide methods were compared within each alternative. For 

each 5th field watershed, the number of acres of aerial treatment, broadcast treatment (both 

boom and hand broadcast) versus hand and spot treatment within the RHCA was compared 

by alternative. 

Herbicide degradation in the environment is tied strongly to soils. The analysis focuses on 

herbicide application since this is the highest risk of the Proposed Actions. Main topics 

compared across the alternatives are (1) the risks to soil biology, (2) soil and water 

interactions and (3) vegetation cover and soil erosion. 

The FS contracts with Syracuse Environmental Research Associates, Inc. (SERA) to conduct 

human health and ecological risk assessments for herbicides that may be proposed for use on 

National Forest System lands. The information contained in this report, and in the EIS, relies 

on these Risk Assessments. Herbicide effects to stream aquatic resources were analyzed in 

risk assessments for each of the 10 herbicides included in the Proposed Action. The risk 

assessments considered worst-case scenarios including accidental exposures and application 

at maximum reported rates. 

The R6 2005 FEIS added a margin of safety to the SERA Risk Assessments by lowering 

acceptable thresholds of herbicide exposure to account for increased protection needed for 

federally listed species (US EPA 2004). Although the risk assessments have limitations (see 

R6 2005 FEIS pages 3-95 through 3-97), they represent the best science available. 

The GLEAMS model (Groundwater Loading Effects of Agricultural Management Systems), 

which is a model that examines the fate of herbicides in various soils under a variety of 

environmental conditions. This is a well validated model for herbicide transport and 

represents the best science available at this time. This model was used for all the Forest 

Service SERA risk assessments. 

The SERA Risk Assessment analysis takes the herbicide concentration provided by GLEAMS 

and uses them in a dilution model for a stream or pond to get the water contamination rates 

for specific scenarios. 

The Risk Assessment model assumes broadcast treatment along a small perennial stream. 

The model ran a 10 acre square field as well as a treatment area modeled as 50 feet wide and 

1.6 miles long (10 acres). The herbicide concentration was very similar for both scenarios. 

Modeling 10 acres along a stream would over estimate herbicide in streams on the Forest as 

no broadcast is proposed within 100 feet of a perennial or flowing intermittent stream or 50 

feet of a dry intermittent stream (Table 7, and Table 8). However, many treatment areas are 

larger than 10 acres. In steeper areas, the model may underestimate the herbicide delivery as 

it assumes a 10 percent slope, although much of the Forest has a steeper slope. The model 

also assumes even rainfall every ten days. 

To model site specific treatment areas for this project, two methods based on the GLEAMS 

model were used. The first was a modification of the spreadsheets used in the SERA risk 

assessments. For two roadside treatment sites the spreadsheets developed for the SERA Risk 

Assessments were modified for type of herbicide, herbicide application rates, soil texture and 

rainfall conditions found at treatment sites on Forest. These were run for the specific 

herbicides to be used at these sites to estimate the potential herbicide concentrations in 

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streams after treatment. When specific treatment areas parameters were rerun in the 

worksheets for this project the upper limit of rain was set at 75 inches a year to model a 2 

inches of precipitation in 24 hour event. While the parameters do not always accurately 

reflect parameters at treatment sites, using this approach is considered conservative because 

while in actuality the infestations are scattered and broadcast application is not allowed along 

streams, they are modeled as continuous broadcast next to a stream. 

For two larger aerial sites the GLEAMS-Driver was used to model the site because this model 

allows the user to input more site specific data such as slopes and treatment acres in addition 

to the herbicide application rate, soil type and rainfall. 

For aerial application the model AGDISP was also used to model direct drift from aerial 

application of herbicide into streams for the worst case scenario allowed under the PDFs of 

this project. 

Past monitoring studies of herbicide use in forested areas were used to create PDFs, 

particularly stream buffers, near water resources to protect streams from adverse effects from 

treatments. 

3.4.2 Affected Environment 

Climate 

Elevations range from 875 feet in Hells Canyon, to 9,845 feet in the Eagle Cap Wilderness. 

Precipitation on the Forest ranges from approximately 8 inches at low elevations to over 80 

inches at the highest elevations. Sites infested with invasive plants grow in areas where the 

precipitations range from 8 to 70 inches, with most sites receiving between 12 and 44 inches 

of annual precipitation. 

Geology 

The geology of the Blue Mountains is complex. It consists of older (preTriasic) oceanic 

volcanic and sedimentary rocks scraped off against what was the continental margin about 

200 million years ago. In the Wallowa Mountains a granitic pluton intruded these older rocks 

about 150 million years ago. Recent volcanism layered the valleys with ash and mud flows in 

the Eocene (roughly 20-30 m.y.a.), followed by basalt lava flows (Columbia River basalts) in 

the Miocene (from 2-22 m.y.a.) (Thayer and Brown 1966a, 1966b). 

The older rocks are faulted, folded and in some areas metamorphosed. Many of the river 

valleys within the mountains were created by glaciation. The larger valleys including the 

valley where the town of La Grande is found was created by faulting. 

Hells Canyon was created when a lake upstream of what is now Hells Canyon cut through a 

spillway and overtime created the canyon (Alt and Hyndman 1978). 

Existing Condition for Soils 

The Wallowa-Whitman National Forest has complex soils that developed on lower elevation 

Columbian basalt flows or steep sided, classic dome shaped granitic mountains such as the 

Blue Mountains and the Wallowas. Roughly 80 percent of the forest occurs on igneous rock. 

The geology has strong influences on topography and vegetation that dictate soil formation. 

Soils are supplemented from volcanic ash that leads to siltloam topsoils. 

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The geology controls much of the larger scale topography of the Wallowa-Whitman National 

Forest. Steep topography occurs along the Snake River gorge and along glacial carved 

mountains. The Snake River gorge has low elevation and thus dryland vegetation. Soils are 

limited on these steep areas by erosion and dry conditions. Shallow topography on the basalt 

flows also support dryland vegetation, though with increasing forest species as elevation 

increases. Mesic forest occurs on north aspects and on upper elevation basalt flows and on 

mountain slopes. 

Most of the Forest soils derived from volcanic, sedimentary or metasedimentary rocks have 

fine to medium textures. The pyroclastic rocks found in the southern part of the Forest are 

also fine textured. Granitic rocks such as the granodiorite found in the central Wallowa 

Mountains, on the Elkhorn Ridge and in the Seven Devil Mountains of Idaho are coarser 

textured. Volcanic ash, deposited as a result of volcanic eruptions on Mount Mazama and 

Glacier Peak more than 6000 years ago, still influences soils of the Forest. This ash, which is 

capable of absorbing and holding large quantities of water, has contributed positively to the 

productivity of most sites where it is found (USDA Forest Service 1990). 

Weeds spread quickly onto dryland forest and grassland soils with the highest rates of spread 

into disturbed areas. 

Where soils are poor native vegetation has a difficult time competing with fast growing 

invasive weeds (Sutherland 2004). Poor soil conditions also occur on dry southfacing slopes 

with shallow soils and low available moisture. Disturbed areas have the highest invasive 

potential with impaired soils that favor opportunistic vegetation. Weed spread is typically 

highest along roads, within old agricultural fields such as on the mid-level benches and river 

terraces in Hells Canyon. Weed spread is also common within grazing allotments, past burns, 

and within timber harvest areas. 

Weed treatments are limited by soils where slopes are steep, or by soil texture. Steep rugged 

areas in Hells Canyon are difficult to access and therefore limit lower risk herbicide treatment 

methods such as spot spraying. 

Soil buildup of herbicide is more common with clay soils whereas soil leaching of herbicide 

into groundwater is prone to well drained sandy soils. Soils within the project that may have 

buildup or runoff issues due to high clays include basalt derived soils and old landslide 

deposits. Soils with high infiltration rates include sandy loam and sand textured soils along 

drainages or bottomlands. 

Soil Conditions within Treatment Areas 

Currently, weeds are mapped on the Wallowa-Whitman National Forest for 22,842 acres, 

approximately 1 percent of the total Forest acreage. The majority of infested sites identified 

for treatment under this analysis are along roads, quarries, trails and recreation sites. Many of 

the weed infestations occur where old homesteads and ranches exist along the Imnaha River 

and Snake River in Hells Canyon. These areas have the highest disturbed soil conditions 

along with the greatest exposure to traffic, which promotes the introduction and spread of 

invasive plants. 

Soils have reduced properties in these areas as a result of soil displacement, and/or altered 

soil structure and porosity as a result of compacted mineral soil. In general, conditions 

affecting vegetative growth such as available moisture holding capacities and soil porosity are 

likely to have been altered with the loss of mineral organics and forest floor litter/duff layers. 

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As many invasive plants prefer disturbed sites, this creates conditions in which invasive plant 

species are able to out-compete native species. 

Infested sites not along roads can include burned areas and streamside areas that act as a 

corridor for movement of plants downstream. Burned areas lack plant cover, generally 

include disturbances from heavy equipment creating fire breaks, and can have changed soil 

properties due to soil heating, as well as higher nutrient levels for opportunistic vegetation to 

exploit. Where streams have acted as a corridor for movement of invasive plants 

downstream, soils are fairly undisturbed, though less developed from recent deposition. 

Treatment areas not along roads can include areas burned by fires and areas where streams 

have acted as a corridor for movement of plants downstream. Where streams have acted as a 

corridor for movement of invasive plants downstream, soils are fairly undisturbed. 

Effect of Invasive Plants on Soils 

Invasive plants can affect soils by changing soil properties such as pH, nutrient cycling and 

microbe composition or activity. The alteration of nutrient availability below ground can 

shift conditions to favor invasive plants. The long-term effects of these changes are not 

known. 

Soil Biology - Invasive plants may invade disturbed areas and lead to long term changes in 

the plant/soil community. The ability of non-natives to move into a site may be from an 

absence of soil pathogens conditioned to the invading species (Callaway et al. 2004). Also, 

the presence of non-native plants can lead to changes in the mycorrhizal fungus community 

that native species depend on (ibid). These species mediated changes can alter the below 

ground nutrient regime to favor the invader (Huenneke 1990, Vinton and Burke 1995, Norton 

et al. 2004), and could increase the difficulty of re-establishing native vegetation after the 

invasive plants are removed. 

Plant and soil communities more resistant to invasive plants are where water and nutrients are 

scarce (Bashkin et al. 2003, Herron et al. 2001). Within dry shrubland and grassland systems 

where biotic crusts are abundant, cheatgrass growth can be limited (Gelbard and Belnap 

2003). Gundale et al. (2008) showed how cheatgrass was more abundant where soil nitrogen 

and water availability was higher. Cheatgrass ringed ponderosa pine and Douglas-fir in an 

open woodland, but was sparse in the dry grassland interspaces. Similarly, more complete 

use of soil and water resources by plants and soil can lower invasive potential (Levine and 

D’Antonio 1999). Pokorney et al (2005) refines this to state an invasive species can have less 

potential where plant communities have similar species. 

In contrast, where soils are productive with large nutrient pools, invasive weeds are 

exceptional at exploiting resources. This is the case for “strong invaders” such spotted 

knapweed and cheatgrass (Ortega and Pearson 2005). Invasive plants directly limit or 

augment nutrient availability by out-competing native species for limited soil resources. 

Weeds have high nutrient uptake rates and can deplete soil nutrients to very low levels, 

especially in cases where weed species germinate prior to native species and exploit nutrient 

and water resources before native species are actively growing (Olson 1999). Once more, 

Bashkin et al. (2003) found that in the arid environment of Escalante National Park, invasion 

by weeds was tied to areas with high available nutrients nitrogen and phosphorus. Thus, the 

more productive soils on the benchlands and footslopes of Hells Canyon may have the 

greatest incursion of invasive plants given the combination of more productive soils and past 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

disturbance. Similar results were found with cheatgrass along tree fringes (Gundale et al. 

2008). 

Once established, weeds can influence the soil nutrient environment to favor their reestablishment. Cheatgrass, an annual grass, can alter nutrient cycles away from conditions to 

which native species have adapted (Norton et al. 2004). Specific changes to soil nutrient 

regimes are associated with large spotted knapweed infestations (Lejeune and Seastedt 2001). 

Some invasive plants are allelopathic to other plants, and produce secondary compounds that 

directly impact the soil microbial community (Bais et al 2003). These changes will affect the 

soil food web and nutrient cycling, and may have impacts on the native plant community. 

Spotted knapweed displaces native vegetation by exuding the phytotoxin, catekin, from its 

roots (ibid). Similarly, Burke et al. (1998) showed the influence of different plant groups on 

available mineral nutrients. With weed invasions, a shift occurs from perennial grasses to 

forbs and/or annual grasses, with an accompanying shift in the timing and amount of nutrients 

(Burke et al. 1998, Hooper and Vitousek 1998). 

Soil and Groundwater – The rate and volume of water infiltration can be reduced on weed 

infested sites due to reduced cover (DiTomaso 2000, Olson 1999a). Significantly greater 

surface water runoff, indicating less infiltration, was measured from spotted knapweed 

dominated sites compared to adjacent native grass dominated sites (Lacey et al. 1989). These 

changes may occur as a site shifts from bunchgrass dominated vegetation to individual 

stemmed forb vegetation as found with spotted knapweed (Lacey et al. 1989). Compaction 

present in many weed infested sites also reduces infiltration rates. 

Vegetative Cover and Soil Erosion- Total vegetative cover can be reduced on weed infested 

sites where strong invaders out compete native vegetation. 

The presence of strong invaders such as spotted knapweed can lower the prevalence of native 

perennial forbs and grasses (Ortega and Pearson 2005). In heavily invested sites by single 

stemmed invasives, this shift in plant function al type leads to more exposed mineral soil on 

the surface with higher evaporation (Lacey et al. 1989, Burke et al. 2005, Olson 1999). 

Soil water stored deeper in the soil profile may also be depleted more rapidly on sites where 

vegetative cover provided by weeds is dense and associated transpiration rates are high 

(Olson 1999). 

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). In the Wallowa-Whitman National Forest, the 

highest potential for soil erosion would occur on disturbed sites such as old homesteads with 

old cultivated lands, or where heavy grazing has occurred. 

The mid elevation benches and river terraces in Hells Canyon National Recreation Area has a 

high amount of historic disturbance. The historic disturbance has left residual impacts that 

have higher bare soil and plant groups that offer less erosion protection. The ecology plots 

within the Hells Canyon area indicate dry grasslands in good condition range from 3-15 

percent bare ground (Johnson and Swanson 2005). Increase of exotic annual grasses and 

forbs is accompanied by increases in bare soil from 15 to more than 25 percent (Ibid). The 

main difference between annual and perennial grasslands is the reduction in groundcover 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

associated with single stemmed annual grasses, much like the transition from perennial 

bunchgrasses to more forbs. Vegetative groundcover protects soils from wind and water 

erosion along with raindrop splash effects (Elliot 1999). A certain level of bare soil exists in 

the moderate condition perennial bunchgrass communities since not all interspaces are 

vegetated. Also, remnant soil compaction from past cultivation and heavy grazing can reduce 

infiltration thereby increasing erosive overland runoff. 

Existing Condition for Water Resources 

Water quality and riparian condition are the two elements potentially affected by invasive 

plant treatments. The 22,842 acres of invasive plants identified for treatment are scattered 

across the Forest in 53 5th field watersheds. Of these, 6,345 acres (28 %) are within 

PACFISH/INFISH defined Riparian Habitat Conservation Areas (RHCAs). 

Water Quality (Temperature and Sediment) 

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. 

Beneficial uses include: 

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 

When a water quality standard is established, the first step is to identify the beneficial uses 

sensitive to the parameter. Then criteria are established based on the levels needed to protect 

the sensitive beneficial uses. 

Section 303d of the Clean Water Act requires that states develop a list of waterbodies that do 

not meet standards and submit the list for approval to the US Environmental Protection 

Agency (EPA). Oregon developed its most current 303(d) list in 2004/2006 and Idaho 

developed their list in 2002. These water quality limited streams and the parameters they are 

listed for are shown in Table 38. 

Temperature is the most widespread water quality impairment followed by sediment. High 

temperatures coinciding with low rainfall and low stream flow during the summer months 

cause stream water temperatures within the area to increase to high levels. South-facing 

aspects and lower elevations tend to create drier and hotter conditions, which serve to further 

elevate temperatures under these conditions. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

Table 38-Water quality impaired streams within the Wallowa-Whitman National Forest on the 

Oregon or Idaho 303(d) list that have invasive plant sites within 100 feet of the stream 

Stream Parameter 1 Parameter 2 

Acres of Infestation within 

100 feet of listed segment 

of stream 

Auburn Creek Temperature 11.5 

Bear Creek Temperature 0.9 

Chesnimnus Creek Temperature 5.7 

Crazyman Creek Temperature 5.8 

Crow Creek Temperature 0.5 

Dry Creek Temperature 11.2 

Freezeout Creek Temperature 1.0 

Grande Ronde River Temperature 7.6 

Granite Creek Temperature 17.0 

Gumboot Creek Temperature 43.3 

Imnaha River Temperature 68.7 

Joseph Creek Temperature 0.3 

Little Sheep Creek Temperature 0.7 

Minam River Temperature 3.0 

Mud Creek Temperature 8.1 

Pine Creek Temperature 0.1 

Sawmill Creek Temperature 31.3 

Wallupa Creek Temperature 4.1 

Wildcat Creek Temperature 10.4 

Snake River Temperature Mercury 17.2 

Total treatment acres along 303d listed segments of 

streams 248.5 

*Acres of invasive plants proposed for treatment to contain, control or eradicate the target species 

By direction of the Clean Water Act, where water quality is limited, state agencies develop 

Total Maximum Daily Load (TMDL) plans to improve water quality and to support the 

beneficial uses of water. For water quality limited streams on National Forest System lands, 

the USDA Forest Service provides information, analysis, and site-specific planning efforts to 

support state processes to protect and restore water quality. 

Two TMDLs have been completed for streams partially located on the Forest. The TMDLs 

were developed on a subbasin level, not for individual streams. They are for the Snake RiverHells Canyon Subbasin and the Upper Grande Ronde River Sub-Basin. 

For the Snake River both Oregon and Idaho worked on the document using the larger 303d 

list from Idaho. Within this subbasin, all designated beneficial uses and the following listed 

pollutants have been addressed by the TMDL: bacteria, nutrients, nuisance algae, dissolved 

oxygen, pesticides, pH, sediment, temperature, and total dissolved gas. The document 

recommends that the segment addressed by this TMDL be delisted for bacteria and pH. The 

mercury TMDL has been postponed due to a lack of water column data. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

State of Oregon completed the Upper Grande Ronde River Sub-Basin Total Maximum Daily 

Load and Water Quality Management Plan (WQMP) in December 1999. The document 

established water quality goals for the streams of the Upper Grande Ronde. The TMDL 

analysis assigned pollutant loads for water temperature and the WQMP established water 

quality goals to meet the TMDL, and removes streams from impairment listing (303d). No 

TMDL for sediment was developed in the Upper Grande Ronde Sub-basin. The state 

determined that, “the load allocations provided to address temperature, pH, and dissolved 

oxygen standard violations, coupled with ongoing efforts by the U.S. Forest Service (USFS) 

to reduce loads from roads and other sources, will be adequate to address sedimentation and 

turbidity concerns in the Upper Grande Ronde Sub-Basin.” To insure that sediment standards 

are met, long-term monitoring is ongoing. 

State of Oregon is currently working on the Lower Grande Ronde River Sub-Basin Total 

Maximum Daily Load TMDL) and Water Quality Management Plan (WQMP). The document 

will establish water quality goals for the streams of the Lower Grande Ronde. 

Geology and stream type play an important role in determining sediment sources, and the fate 

of sediment entering streams. The majority of perennial and intermittent streams across the 

Forest, have moderate to high gradients, therefore they tend to transport rather than store 

sediment. In general, these stream types are not susceptible to fine sediment accumulations. 

Lower gradient (less than 2 percent) response reaches occur in the main valleys of larger 

streams. Low gradient meadow systems in the higher elevations are also areas of sediment 

accumulation. 

Bacteria may be a concern in localized areas with heavy recreation use and heavy grazing 

pressure. The ability of water to hold oxygen decreases with increased water temperature, 

altitude, or dissolved solids (TDS). Dissolved oxygen (DO) can be lowered by high stream 

temperatures, bacteria blooms, and decaying vegetation in water, although no streams on the 

Forest are listed for low DO. 

Effect of Invasive Plants on Water Quality 

Stable banks tend to provide more shade which helps reduce water temperature. While 

invasive plants may provide some shade they are replacing native forbs and grasses that are 

better bank stabilizers and promote narrower-deeper channels. Such channels have healthier 

temperature gradients than wide, shallow streams. 

There are 77.5 acres of Japanese knotweed along the Snake River (55 acres within RHCAs), 

and has poor bank holding capacity, which leads to more bank erosion and sedimentation of 

streams in high winter flows (USDA Forest Service, 2005a). While knotweed may provide 

some shade, native streamside hardwoods 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. While the known extent of knotweed is small at this time, 

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 Sol, 2004). 

Purple loosestrife is an aggressive invasive plant species that out competes native vegetation 

and forms a monoculture. It grows quickly and spreads by roots, stem fragments or seeds 

(ibid). On smaller streams purple loosestrife can increase fine sediment deposition, 

smothering spawning gravels and decreasing channel capacity (R6 2005 FEIS). 

255 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

While the other invasive plant species found on the Forest are primarily upland species, they 

can colonize a range of sites and are present within many RHCAs. 

One of the more prevalent species on the Forest and within RHCAs is knapweed. Diffuse 

and spotted knapweed is found along many streams in the Forest. Lacey et al. (1989) 

reported higher runoff and sediment yield on sites dominated by knapweed versus sites 

dominated by native grasses. 

Without treatment, all of these species are expected to continue to spread. Where they spread, 

banks could become less stable, leading to changes in suspended sediment and substrate 

character and embeddedness. 

Channel Morphology and Riparian Condition 

Riparian shrubs are lacking on many Forest streams. There is over utilization of riparian 

vegetation in some areas by domestic livestock and wildlife. Large wood is lacking in many 

streams on the Wallowa-Whitman National Forest, particularly where roads parallel streams. 

However, in recent years degraded riparian areas have been improved to provide for ripariandependent resources. These improvements have resulted from better control and 

administration of livestock use in riparian areas, reduced timber harvest in forested riparian 

areas, and more roads being closed or obliterated. 

Native riparian vegetation plays a key role in forming aquatic habitat for fish and other 

aquatic species. Roots help stabilize stream banks, preventing accelerated bank erosion and 

providing for the formation of undercut banks, important cover for juvenile and adult fish. 

Riparian vegetation also provides large and small wood to streams, adding to habitat 

complexity and providing cover and food sources for aquatic organisms. Aquatic ecosystems 

have evolved with certain vegetation types; invasive plants do not necessarily provide similar 

habitat. Japanese knotweed has poor bank holding capacity, which leads to more bank erosion 

and sedimentation of streams in high winter flows (USDA Forest Service 2005a). Knotweeds 

tolerate a wide variety of substrates from cobbles to fine soils (Tu and Sol, 2004). 

Lakes and Reservoirs 

There are many lakes and small waterbodies on the Forest. Phillips Lake and Wallowa Lake 

are the largest at 1,748 acres and 1,687 acres respectively. The smallest waterbodies are less 

then an acre. Lakes are popular for recreation, and so are at risk from invasive plants brought 

in by visitors. They are also at risk from invasive plants such as knotweeds that colonize 

areas downstream of the original infestation along streams. 

There are 13 acres identified at five sites for treatment within 100 feet of lakes, reservoirs and 

ponds (Table 39). All invasive plants identified are upland species with infestations starting 

along roads in recreation areas. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

257 

Table 39-Invasive Plant Acres within 100 feet of lakes and reservoirs 

Waterbody 

Name 

Waterbody size 

(Acres) Invasive Plant Species Found Acres Infested 

Goose Lake 2.40 

hoarycress wtop, canadian thistle, 

sulphur cinquefoil, medusa 

head* 

6.10 

Phillips Lake 1,748.00 diffuse knapweed 0.70 

Le Grande Reservoir 35.20 Canadian thistle 2.50 

Balm Creek Reservoir 88.00 diffuse knapweed, hoarycress 

whitetop* 0.50 

Clear Creek Reservoir 38.30 Canadian thistle 3.10 

Total 12.90 

*Overlapping infestations at the same site 

Municipal Watersheds and Domestic Water Supplies 

The legally designated municipal water supplies in the project area are the Baker Municipal 

Watershed and the La Grande Municipal Watershed (although the city is not currently 

drawing water from this watershed). No invasive plant treatment sites are within the Baker 

Watershed, therefore no treatments of any kind are proposed. No chemical treatments are 

proposed within the La Grande Watershed. Biological controls are being used to treat the less 

than three acres of Canada thistle mapped within the La Grande Municipal Watershed. 

Several other communities rely on the Forest for municipal water. For instance, the 

Community of Sumpter obtains its water from the McCully Fork of the Powder River, 

Granite from a spring located on National Forest land, and Union utilizes water from 

Catherine Creek. No chemical treatments are proposed along Catherine Creek. In addition, 

Wallowa and Joseph receive all or part of their domestic water supplies from streams 

originating on National Forest System land. The City of Halfway possesses a special use 

permit for use of Leep Springs as a domestic source, although it currently is not using this 

supply (USDA Forest Service 1990). McCully Fork has invasive plant sites identified for 

Scotch thistle, diffuse knapweed, Dalmatian toadflax, and St Johnswort. These sites are along 

the roads paralleling the stream. See Appendix D for a more complete listing of cities and 

towns that receive municipal water supplies from Wallowa-Whitman National Forest lands. 

There are also wells and springs used for domestic water at campgrounds and private water 

rights on isolated springs on the Forest. The National Forest has 1,462 identified water uses in 

its most recent water uses inventory. The inventory includes 14 Forest Service campgrounds 

and 2 picnic areas with piped-in water. Two uses for irrigation (pastures) have been identified. 

The remaining 1,431 uses are associated with stock watering (USDA Forest Service 1990). 

The listing of municipal water supply sources for campgrounds and pinic areas are listed in 

Appendix D. 

Infestations by Watershed 

Most of the 5th field watersheds have less than 1 percent of the Forest land identified as 

infested with invasive plants (Table 40). The watersheds with the largest infestations are the 

Middle Imnaha River with almost 7 percent infested, Snake River/Temperance Creek with 

1.9 percent infested and South Fork Burnt River with 1.7 percent infested. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen 

Table 40-Infested acres proposed for treatment by watershed 

Fifth Filed Watershed Name Watershed HUC Number Watershed Acres Infested Acres Proposed for Treatment Percent Watershed Treated 

Bear Creek 1706010504 46,300 400 0.86% Big Creek 1705020307 54,896 92 0.17% Birch Creek 1707010306 182,206 6 <0.01% Burnt River-Auburn Creek 1705020205 60,006 295 0.49% Burnt River-Big Creek 1705020204 94,102 20 0.02% Burnt River-Burnt River Canyon 1705020206 54,081 63 0.12% Camp Creek 1705020203 51,954 275 0.53% Chesnimnus Creek 1706010604 122,765 398 0.32% Eagle Creek 1705020310 123,643 846 0.68% Grande Ronde River-Beaver Creek 1706010403 131,649 338 0.26% Grande Ronde River-Five Points Creek 1706010404 87,632 49 0.06% Grande Ronde River-Indian Creek 1706010409 96,033 26 0.03% Grande Ronde River-Mud Creek 1706010602 154,202 653 0.42% Granite Creek 1707020202 94,513 411 0.43% Ladd Creek 1706010406 59,542 53 0.09% Little Malheur River 1705011612 86,434 3 <0.01% Lostine River 1706010502 58,035 142 0.24% Lower Big Sheep Creek 1706010204 129,726 182 0.14% Lower Catherine Creek 1706010407 83,128 419 0.50% Lower Imnaha River 1706010205 147,024 436 0.30% Lower Joseph Creek 1706010606 104,789 450 0.43% Lower Powder River 1705020311 61,488 16 0.03% Lower Wallowa River 1706010506 110,422 198 0.18% McKay Creek 1707010305 127,200 62 0.05% Meadow Creek 1706010402 116,100 459 0.40% 258
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Fifth Filed Watershed Name Watershed HUC Number Watershed Acres Infested Acres Proposed for Treatment Percent Watershed Treated 

Middle Imnaha River 1706010202 87,983 5,879 6.68% Middle Wallowa River 1706010503 85,060 9 0.01% Minam River 1706010505 152,910 115 0.08% North Fork Burnt River 1705020201 124,147 1,171 0.94% North Powder River 1705020305 74,553 144 0.19% Pine Creek 1705020106 193,640 794 0.41% Powder River-Baldock Slough 1705020303 72,489 50 0.07% Powder River-Rock Creek 1705020304 120,776 75 0.06% Powder River-Ruckles Creek 1705020308 166,729 1,327 0.80% Powder River-Sutton Creek 1705020302 115,886 274 0.24% Powder River-Wolf Creek 1705020306 109,371 58 0.05% Snake River-Cherry Creek 1706010301 88,100 333 0.38% Snake River-Granite Creek 1706010101 127,510 100 0.08% Snake River-Indian Creek 1705020107 117,761 50 0.04% Snake River-Temperance Creek 1706010102 115,290 2,142 1.86% Snake River-Wolf Creek 1706010103 103,723 365 0.35% South Fork Burnt River 1705020202 75,183 1,281 1.70% South Willow Creek 1705011901 65,950 49 0.07% Upper Big Sheep Creek 1706010203 89,359 341 0.38% Upper Camas Creek 1707020205 104,623 32 0.03% Upper Catherine Creek 1706010405 116,931 19 0.02% Upper Grande Ronde River 1706010401 133,776 330 0.25% Upper Imnaha River 1706010201 90,349 686 0.76% Upper Joseph Creek 1706010605 125,191 421 0.34% Upper North Fork John Day River 1707020201 71,525 30 0.04% Upper Powder River 1705020301 105,509 461 0.44% 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen 

260

Fifth Filed Watershed Name Watershed HUC Number Watershed Acres Infested Acres Proposed for Treatment Percent Watershed Treated 

Upper Wallowa River 1706010501 157,943 7 <0.01% Willow Creek 1706010408 53,565 5 0.01%  Totals 5,483,703 22,840 0.42%  *Total for watershed differs by 2 acres from proposed action table due to rounding differences in GIS. RHCA number includes chemical treatment, biocon

treatments. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Invasive Plants within RHCAs 

All of the invasive plants listed in treatment areas are found within RHCAs as well as in uplands. 

Most the invasive plant species found within the RHCAs originate from disturbed sites. 

Perennial bugloss at 1256 acres, diffuse knapweed at 1214 acres and Canada thistle at 1155 acres 

are most prevalent with the RHCA. 

Both Canada thistle and diffuse knapweed are commonly found in open disturbed areas along 

roads or in areas frequented by cattle. Perennial bugloss was originally planted at an old 

homestead and has since spread through the valley along the Imnaha River. Once established any 

of these species can begin to invade undisturbed sites. Many other species found within the 

RHCAs are of concern. In particular medusa head, leafy spurge and yellow star thistle are 

aggressive spreaders. White top forms a monoculture and may spread rapidly under moist 

conditions (Botany Section). 

Of the 6,345 acres infested with invasive plants within PACFISH/INFISH Riparian Habitat 

Conservation Areas (RHCAs) only Japanese knotweed and purple loosestrife are specifically 

riparian species. There are approximately 77 acres of Japanese knotweed (54 acres within 

RHCAs) and 2.5 acres of purple loosestrife (0.4 acres within RHCAs) found along the Snake 

River and tributaries to the river. 

While knotweed has only been recognized as a major problem for the last five years in the 

Pacific Northwest, it is documented as a major invasive plant in the British Isle and many other 

areas in the U.S. For example, in the eastern United States Japanese knotweed has been found 

along the banks of the Ohio and Allegheny Rivers and in islands of these rivers where it occupies 

hundreds of acres of wetlands, stream banks and hillsides (U.Gergia 2005). 

Purple loosestrife is on the Nature Conservancies list of worst invasive plant species (Steinn and 

Flack, eds, 1996). Purple loosestrife, nicknamed the purple plague, is another aggressive 

invasive plant species that out competes native vegetation and forms a monoculture. It grows 

quickly and spreads by roots, stem fragments or seeds (ibid). On smaller streams purple 

loosestrife can increase fine sediment deposition, smother spawning gravels and decrease 

channel capacity (USDA Forest Service 2005a). 

3.4.3 Environmental Consequences 

Introduction 

With the exception of aerial spraying herbicides, all alternatives, including the No Action 

Alternative, allow similar methods of treating invasive plants. Alternative B has the most 

aggressive management using herbicides. Alternative C omits broadcast spraying in RHCAs. 

Alternative D omits aerial herbicide application. In addition, all the action alternatives include 

an early detection rapid response (EDRR) process to address new or unknown infestations over 

the next 10 to 15 years. Project Design Features such as riparian buffers, frequency of 

application limitations, and herbicide limitations specific to soil type, lower the risk of chemical 

contamination to RHCAs. These protective measures would work equally well for EDRR sites 

that would be identified in the future. It is important to acknowledge that aerial and ground 

broadcast methods have higher risk for unknown variables such as wind drift and rainfall 

intensity. No herbicide application would occur within municipal watersheds or on domestic 

water supplies under any alternative. Water contamination risk from herbicide drift, runoff or 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

leaching is low based on evaluation of herbicide application in the Risk Assessments and added 

herbicide restrictions. 

No long term impacts to soils are expected at the Forest scale, although some adverse effects 

from these actions are unavoidable. Adverse impacts include local effects on some groups of 

micro-organisms that may be temporarily sensitive to picloram (Tordon), sulfometuron methyl 

(Oust), and triclopyr (Garlon, Access). 

The following sections discuss the general effects of manual, mechanical and herbicide 

treatments on soil and water resources. Specific differences in alternatives are detailed after the 

general discussion. 

Soils 

The following table summarizes the herbicides available for treatment with regard to soil. 

Table 41-Herbicide Properties 

Herbicide Toxicity to 

Soil Microbes 

Potential 

Mobility1 

Water 

Solubility1 

Degradation 

path and 

half life2 

Activation 

Mechanism2 

Chlorsulfuron Low 

High 

Very high 

in clay 

soils 

Very High Hydrolysis 

37-168 days 

Acetolactate synthesis 

inhibitor (Selective: 

controls broadleaves 

and some grasses) 

Clopyralid Low 

Very high 

especially 

in sandy 

soils 

High 

Soil 

microbes 

14 to 29 

days 

Plant growth regulator 

(Very selective to 

broadleaves; post 

emergent) 

Glyphosate Low Low Very High 

Soil 

microbes 

30 to 60 

days 

Inhibits 3 amino acids 

and protein synthesis 

(Non-selective; quickly 

absorbed by leaves 

with rapid movement 

through plant; no root 

absorption) 

Imazapic No info 

Medium 

(Lower 

with 

increased 

organic 

Matter) 

Very High 

Soil 

microbes 

113 days 

acetolactate synthesis 

inhibitor (Uptake by 

roots & leaves; active 

in soil as preemergent) 

Imazapyr 

Slight at high 

application 

rates. 

Medium 

(low 

Organic 

Matter and 

high pH 

raise 

mobility) 

Very High 

Soil 

microbes 

30 to 365 

days 

acetolactate synthesis 

inhibitor (Uptake by 

roots & leaves; active 

in soil as preemergent) 

Metsulfuron 

methyl 

At high 

application 

rates short-term 

decrease for a 

few days but 

reversed 

quickly. 

Very High High 

Slow 

microbial 

degradation 

at high pH, 

fast at low 

pH 

Up to 120 

days 

acetolactate synthesis 

inhibitor (Potent 

herbicide; uptake by 

roots & leaves) 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

263 

Herbicide Toxicity to 

Soil Microbes 

Potential 

Mobility1 

Water 

Solubility1 

Degradation 

path and 

half life2 

Activation 

Mechanism2 

Picloram 

Toxic to some 

soil organisms, 

even at low 

levels. 

Very High Very High 

Slow 

microbial 

90 days 

Plant growth regulator 

(Selective: rate and 

season dependant; 

pre-emergent and soil 

active) 

Sethoxydim Low 

Medium 

(Organic 

Matter 

decreases) 

Very High 

Rapid 

microbial 

5 to 25 

Inhibits acetyl coenzyme (ACE) 

(Systemic that is 

absorbed rapidly by 

foliage and roots. 

Sulfometuron 

methyl 

Toxic to soil 

organisms. Soil 

residues may 

alter 

composition of 

soil 

microorganisms 

High Medium 

Soil 

microbes 

10 to 100 

days 

Acetolactate synthesis 

inhibitor (Nonselective pre and post 

emergent - uptake by 

roots & leaves. Potent 

herbicide) 

Triclopyr 

Inhibits algae at 

low rates Toxic 

to fungi at high 

rates. 

Very High Medium 

Soil 

microbes 

46 days 

Plant growth regulator 

(Absorbed thru roots, 

foliage and green 

bark) 

1 Mobility and water solubility categories are general breakdowns and not a definitive classification taken from the R6 

2005 FEIS 

2 Deschutes, Ochoco and Crooked River National Grasslands Invasive Plant EIS Soils Report, (Sussmann 2006) 

 Data compiled from the R6 2005 RODand The Nature Conservancy Weed Control Methods Handbook (Tu et al. 2001) 

Vegetation Cover and Erosion 

The treatment of sites with herbicides could also indirectly affect soil productivity in the short 

term by changing the vegetative cover on the surface and the annual input of organic matter into 

the soil. These effects would occur on heavily infested sites with invasive plants that are moving 

toward monocultures, including those with hawkweed and whitetop. 

Chemically treated plants would die and become incorporated into the soil as organic matter 

during the first years following treatment. Annual input in subsequent years would be contingent 

on the amount of regrowth of non-target plants. If native populations were less than 30 percent 

vegetative canopy cover, native or naturalized species would be reseeded under all action 

alternatives. The 30 percent threshold canopy cover is based on recommendations from the 

Montana State Extension Service (Goodwin et al. 2002). 

Herbicides would impact plant canopy cover greatest where broadcast spraying is planned. The 

overall risk for soil erosion is low, although erosion risk would increase on moderately steep 

slopes with fine textured soils. Erosion risk would be short term, within 1 to 2 years. 

Monoculture stands of target weeds such as whitetop and meadow hawkweed would have the 

highest mortality rates and thus have the greatest bare soil available to erosive waterflows and 

wind. Other target weeds such as the knapweeds, medusahead, and starthistle may also have 

monoculture stands. 

Rugged steep slopes such as in Hells Canyon are not expected to have high erosion risk. 

Observations by The Nature Conservancy on aerial sprayed lands adjacent to the WallowaWhitman National Forest indicate dry grasslands on rugged steep slopes rebound readily after 

herbicide treatment (Talsma et al 2006, unpublished). Possibly, the lack of disturbance on the 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statemen Chapter 3 

264

steep slopes creates a higher level of residual grassland for regrowth after treatment. In contrast, 

the moderate slope areas would have the greatest erosion potential since these areas have past 

disturbance coupled with finer soil texture and enough slope to drive erosive overland water 

flows. 

Erosion hazard was evaluated for the broadcast spraying sites greater than 50 acres where 

erosion potential would be highest (Table 42). Physiographic data on slope, slope length, soils, 

vegetation type along with the type of herbicide treatment and target invasive was combined to 

model erosion risk. The Water Erosion Prediction Model (USDA Forest Service 2007) was used 

to generate data on soil erosion in tons/acre, using local climate information and the site 

physiographic data. The WEPP model has limitations with an error rate of +/- 50 percent; 

however, this model does provide a great context for erosion that integrates hillslope processes 

and local climate. The gross values are sufficient given the large forest-wide scale for this EIS. 

Erosion risk would be short term from herbicide treatment and generally less than 1 ton/acre 

using a 2 year storm event, such as a summer thunderstorm. These results assume that at least 50 

percent of the ground cover would remain following spraying. Where large monotypic 

infestations occur, erosion may be up to 4 tons/acre, assuming groundcover is reduced to 30 

percent. These estimates are based on the an average of 25 percent reduction in plant cover for 

most of the target weeds after treatment, and up to 55 percent for monotypic stands such as 

whitetop and meadow hawkweed (Dawson 2007, personal communication). 

Erosion potential where annual grasses are treated may be slightly higher since the groundcover 

would be less effective at slowing erosive overland waterflows given the very fine plant litter. 

Of the sites evaluated, most had moderate risk for soil erosion after herbicide treatment (Table 

42). These included hillside areas adjacent to old ranches or road corridors. Higher risk was 

associated with common crupina and whitetop on moderate to steep slope near ranches in 

addition to diffuse knapweed along roads with steep cutslopes. 

Scotch thistle has low risk soil erosion since it occurs in smaller aggregations and therefore less 

groundcover would be lost. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 42-Potential surface erosion for 2 year storm with groundcover at 10, 30 and 50 percent NXWD_TAG Acres Noxious Weed Veg-type Slope Erosion Hazard 

6160400092 5808 common bugloss (Anchusa arvensis) Dry Forest 0 to 50 % Moderate 6160700061 914 medusahead (Taeniatherum caput-medusae) Dry Forest 30 to 60 % Moderate 6160400075 677 Canada thistle (Cirsium arvense) Moist Forest 60 to 90 % Moderate 6160200301 284 common crupina (Crupina vulgaris) Dry NonForest 60 to 90 % High 6160400295 340 hoarycress, whitetop (Cardaria draba) Dry NonForest 0 to 30 % High 6160400046 254 Scotch thistle (Onopordum acanthium) Dry NonForest 15 to 50 % Low 6160400007 232 spotted knapweed (Centaurea maculosa) Moist NonForest 0 to 15 % Moderate 6160500003 187 Diffuse knapweed (Centaurea diffusa) Moist Forest 30 to 60 % Moderate 6160500026 161 Diffuse knapweed (Centaurea diffusa) Moist Forest 60 to 90 % High 6160400319 154 Scotch thistle (Onopordum acanthium) Dry Forest 30 to 60 % Moderate Hillside6160700160 78 Dalmation toadflax (Linaria dalmatica) Moist NonForest 10 to 90 % High R6160600183 134 Diffuse knapweed (Centaurea diffusa) Dry Forest 30 to 60 % Moderate 6160600191 103 Canada thistle (Cirsium arvense) Moist Forest 30 to 60 % Moderate 6160900096 95 Hoarycress, whitetop (Cardaria draba) Moist Forest 30 to 60 % Moderate 6160700156 90 Canada thistle (Cirsium arvense) Moist Forest 0 to 30 % Moderate 6160100006 88 Canada thistle (Cirsium arvense) Dry Forest 30 to 60 % Moderate 6160500004 87 Diffuse knapweed (Centaurea diffusa) Moist Forest 30 to 60 % Moderate 6160600015 85 Diffuse knapweed (Centaurea diffusa) Moist Forest 0 to 30 % Moderate 6160700010 75 Diffuse knapweed (Centaurea diffusa) Moist Forest 30 to 60 % Moderate 6160400314 15 Scotch thistle (Onopordum acanthium) Dry NonForest 60 to 90 % Low 6160100085 60 Sulphur cinquefoil (Potentilla recta) Dry Forest 30 to 60 % Moderate 6160200025 58 Scotch thistle (Onopordum acanthium) Dry NonForest 60 to 90 % Low 6160100125 54 Houndstongue (Cynoglossum officinale) Dry Forest 30 to 60 % Moderate 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Summary of Soil Concerns with Specific Herbicides and Project Design Features 

Clopyralid has high potential mobility in sandy soils. To minimize movement of clopyralid 

through soils into groundwater, clopyralid would not be used on high-porosity soils (more than 

20 percent coarse fragments or coarser texture than loamy sand) (Herbicide Label Advisory). 

Since Chlorsulfuron does not adhere to clay particles, chlorsulfuron would be avoided on soils 

with high clay content (finer than loam) to limit herbicide movement (Herbicide Label 

Advisory). 

Picloram and sulfometuron methyl have high persistence in soil and groundwater. To avoid soil 

buildup and contamination of groundwater, herbicide frequency is limited to once every year at 

any specific site for sulfometuron methyl (SERA 2004) and once every two years for picloram 

(SERA 2003). 

Picloram has very high mobility and longer persistence, and thus has risk for contaminating 

groundwater (SERA 2003). To avoid this threat, picloram would not be used on coarse-textured 

soils with a high water table. 

After herbicide treatment, a greater than 70 percent reduction in existing live basal plant cover 

indicates active restoration is needed (Goodwin et al. 2002). Restoration measures listed in 

Erickson et al. (2003) are recommended. 

Risk for replacement of a target invasive weed with another invasive would be evaluated prior to 

broadcast herbicide treatment in accordance with long term site planning (Standards 3 & 12, WW LRMP as amended by the R6 2005 ROD). 

Historically disturbed areas such as old ranches and homestead areas have shifted plant/soil 

ecology. Therefore, emphasize long term site planning for these sites (Standards 3 & 12, W-W 

LRMP as amended by the R6 2005 ROD) using active restoration measures listed in Erickson et 

al (2005). 

General Effects of Manual and Mechanical Treatment 

Manual and mechanical treatments are proposed under all alternatives. The overall impacts of 

these activities are low. Manuel methods would decrease ground cover temporarily leading to 

incremental effects from erosion or slight decreases in soil moisture from groundcover 

reductions. Mechanical methods would not lead to adverse effects on soils since soil organic 

matter would be supplemented from cut vegetative material and off road vehicle use would be 

limited. 

Mechanical treatment would include mowing or use of foaming or steaming machines on and off 

roads. Compaction of soil is avoided by restricting all vehicles to the road prism except for 

ATVs. ATVs have low tire pressure and thus would not have measurable impacts on soils when 

used judiciously. 

General Effect of Biological Control 

Biological control can be defined as the use of natural enemies to reduce the damage caused by 

invasive plant populations. The primary effect from biological controls is standing dead plants. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

General Effects of Cultural Treatments 

The cultural treatments descriptions and effects are the same as those described under ‘cultural 

treatments’ in Section 3.4.3 above. No effects to groundwater are expected due to cultural 

treatments. Typically, fertilizers would remain high in the soil horizons and quickly be utilized 

by plants on site. Cultural treatments would tend to have a positive effect on vegetative cover by 

seeding or planting additional native plants and/or stimulating existing native plants. 

General Effects of Herbicides on Soils 

Herbicide treatments would have some effect on soil biology, though effects would be transitory 

based on the herbicide type and frequency applied. Also, soil biology may be changed by 

shifting plant composition to favor grasses. Adverse effects would be minimized by adjusting 

herbicide use to avoid soil buildup and leaching to groundwater (also see Hydrology section). In 

general, most of the proposed herbicides are highly mobile and therefore buildup is not a 

concern. For immobile herbicides such as picloram (tordon) and glyophosate (Rodeo, 

Roundup), spraying frequency restrictions alleviate risk for soil buildup. Soil erosion from loss 

of vegetative cover is only a concern for monocultural stands of weeds. 

The highest erosion concern is associated with steep roadside treatment of knapweeds and 

broadcast treatment of common crupina and whitetop monocultures on disturbed areas with 

moderate slope. Erosion risk is for 1-2 years while desired species revegetate. 

Herbicide Effects to Soil Biology 

Overall, the proposed herbicide types and application rates are low enough to facilitate decay by 

soil microbes. The proposed herbicide usage would have a low risk for soils since the bulk of 

treatments focus on roads and rock quarries where soils are unproductive and soil communities 

are uniform. Adverse effects may occur where diverse native grasslands are treated with 

nonselective herbicides and broadcast methods. These impacts are related to the short term loss 

of non-target broadleaf forbs that support diverse soil communities. Soil attributes at greatest 

risk from chemicals include damage to soil organisms and erosion from removal of ground cover 

that affects the soil growing environment (also see native plant community discussion in the 

botany section). 

Herbicide persistence in soil is largely controlled by biologic decay. Most of the proposed 

chemicals are decayed primarily by soil microbes. Only Chlorsulfuron is primarily degraded 

through hydrolysis. In the short term, chemicals can adversely affect microbial growth for 1 day 

to 1 week depending on the chemical used (see Table 41). Results from field and laboratory 

testing are mixed since soil conditions are highly variable. In general, herbicides are decayed 

and therefore effects are reduced when microbial metabolic rates highest. These conditions are 

when adequate warmth, moisture and microbial substrate is abundant such as during spring. 

The low application rates and type of herbicides proposed in general have a low impact on soil 

organisms. However, Picloram (Tordon) is known to affect soil organisms at the approved 

application rates (SERA 2004). At high rates, sulfometuron methyl (Oust) and triclopyr (Garlon, 

Access) can affect soil microbes. Sulfometuron methyl can inhibit soil microbial growth. 

Tryclopyr may adversely affect some fungi and algae. Effects are short term and transitory since 

effects decrease with time. 

Functional groups of microbes that have similar metabolic pathways as the target weeds would 

be most sensitive to the herbicides. However, collective adverse effects of the proposed 

herbicides on soil microbes are hard to predict, given the diversity of the soil community and 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

varying resistance to the particular herbicides. For example, some laboratory studies found 

glyphosate adversely impacted several types of microbes, although populations rebounded 

quickly (Tu et al. 2001). Similarly, Busse et al (2001) found no long-term impact on microbial 

communities when using glyphosate on ponderosa pine plantations. 

Ultimately, soil microbes degrade herbicide by using the herbicides as growth substrate, 

cometabolizing, polymerizating, accumulating or altering the chemical structure by influencing 

the pH of the soil environment (Bollag and Liu 1990). The residency times shown in Table 41 

are a gross collective function of average soil types, application timing and frequency, and 

finally the unique chemical structure. Of the herbicides, Imazapr has the longest halflife at 1 

year, while Sethoxydim has a comparatively rapid half life from 5 to 25 days. As stated above, 

favorable microbial growth conditions will speed herbicide degradation. 

Of the ten herbicides proposed for use, picloram and sulfometuron methyl pose risks to soil 

microorganisms and are most persistent in the soil. 

To protect soil organisms and therefore protect soil productivity, sulfometuron methyl would 

only be used once a year at any specific site to avoid accumulating herbicides in the soils. 

Picloram could only be used once every two years to protect soil productivity and avoid 

accumulation in the soils of this persistent herbicide. 

The other herbicides have a small to no effect on soil microorganisms at normal application rates 

and could potentially be used three times on the same area in one year. More than likely, if an 

area was broadcast sprayed once, subsequent treatments would consist of spot spraying to treat 

missed areas, to treat areas where seeds have germinated since the last spraying, or to treat the 

small areas where invasives were damaged but are resprouting. 

Soil and Groundwater 

The persistence of herbicides is affected by the herbicide solubility and absorbance in soil. 

Herbicides with high water solubility may have a low risk for buildup in soil, but may have a 

higher risk for leaching into groundwater. Herbicides will persist in finer textured soils such as 

clay loams compared to very well drained sandy soils. These sandy soils can transmit highly 

mobile herbicides to shallow groundwater. Herbicide persistence in soil also varies according to 

specific degradation rates. For example, clopyralid has at least three times faster degradation rate 

than picloram (Table 41). 

The primary herbicide routes in soil are leaching, hydrolysis, and adsorption/desorption onto soil 

particles, and biological degradation. Soil characteristics affect the herbicide residency time 

through drainage and adsorptive capacities. Highly drained soils have greater propensity to 

transfer herbicides to groundwater stores. Organic rich soils and finer texture soils have higher 

adsorption potential for holding herbicides. Herbicides will vary in the degradation potential 

based on their chemical structure and the biologic potential of the soil. 

General characteristics for the proposed herbicides are displayed in Table 41. Many of the 

proposed herbicides are highly soluble in water (Table 41). Solubility is often taken as an 

indicator of the mobility of the chemical in soils. However, glyphosate, while having a high 

solubility, also binds tightly with soil particles and thereby has low mobility. Herbicides with 

high mobility potential and long half-lives have a greater potential for leaching into near surface 

ground water. 

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Herbicide properties displayed in Table 41 were used to form Project Design Features to 

minimize adverse effects from the use of herbicides to soil. A coarse filter analysis was done to 

identify sites where soil characteristics would not be appropriate for application of picloram, 

clopyralid and sulfometuron methyl, and chlorsulfuron herbicides (see PDFs H4-H7 in Table 6). 

Sites were characterized with soil data from the recently completed portions of the Terrestrial 

Ecosystem Unit Inventory, as of June 2008. This survey covers roughly two-thirds of the 

identified treatment sites and does not extend into the remote Hell’s Canyon Area. Herbicides 

picloram and sulfometuron methyl were eliminated from treatment options where sites had a 

high risk for leaching. Clopyralid has slightly less risk for leaching, and thus was only 

eliminated where soils had extremely well drained conditions. Chlorsulfuron was eliminated for 

fine grained, clay soils, where runoff and wind translocation risk is high. Affected sites are listed 

in Appendix D. 

Comparison of Alternatives 

Tradeoffs exist amongst the No Action Alternative and the action alternatives. The No Action 

Alternative continues the more conservative approach to treating invasive weeds. Advantages are 

more restricted herbicide use because of less acres being treated to limit nontarget effects on soil 

biology; however, there is increasing impacts to native plant communities as these invasive 

species spread. The action alternatives have much more aggressive means for slowing the spread 

of invasives (see botany section), but have short-term increased reliance on herbicides (Table 

43). Project design features would lower the risk of herbicide impacts to soils by limiting the use 

of certain herbicides, application rates, and/or application methods so that known risks are 

avoided or minimized. Given the low potential for adverse impacts at the site scale, the limited 

extent of treatment, and the layers of caution provided by the PDFs, the project is unlikely to 

have more than a negligible impact on soils. Aerial applications associated with Alternative B 

and C have the greatest risk for herbicide drift to non-target vegetation and thus soil biology. 

Table 43-Acres proposed for treatment by location and method by alternative 

Treatment 

Methods 

Alternative A 

No Action1 

Alternative B 

Proposed Action 

Alternative C 

No Broadcast in 

Riparian Habitat 

Conservation 

Areas 

Alternative D 

No Aerial 

Herbicide 

Chemical Methods 

Upland Areas 

Ground-based 

broadcast and 

spot treatments2 

2,577 13,556 13,556 13,556 

Aerial treatments 0 875 875 0 

Riparian Habitat Conservation Areas 

Ground-based 

broadcast 

treatment 

1,9323 3,104 0 3,104 

Spot 

spray/selective 

treatment 

(including wicking 

and wiping) 

6633 3,241 6,345 3,241 

Non-Chemical Methods 

Upland Areas and Riparian Habitat Conservation Areas 

bio-control only See note below 1,955 1,955 2,797 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Alternative C 

No Broadcast in Alternative D 

Treatment Alternative A Alternative B 

Methods No Action1 Proposed Action Riparian Habitat No Aerial 

Conservation Herbicide 

Areas 

manual only6 0 111 111 111 

Total Acres 5,172 22,842 22,842 22,809 

1 A designation of chemical treatment could be changed to manual, mechanical or biological treatment if, at the time of 

treatment, one of these alternative methods would be effective. A site initially treated with chemicals may be treated 

with manual or mechanical methods during follow-up treatments. 

2 Whether each site will be broadcast or spot treated will be determined locally before each field season so the acres to 

be broadcast treated and the acres to be spot treated are not known at this time. Determination of where broadcast 

versus spot treatments will occur depends on access to site, size of site, and density of weed coverage. 

3 No action alternative includes ’92 Environmental Assessment for the Management of Noxious Weeds and the ’94 

Environmental Assessment for Management of Noxious Weeds and Forest Plan Amendment #4. 

4 Acres proposed in aerial application that could be treated with ground based methods although likely to be less 

effective or more costly than those proposed in Alternative B. Approximately 33 acres would not treated due to 

inaccessibility and no other means of control i.e. biocontrol agents. 

5 Riparian Habitat Conservation Areas (RHCA) are: 300’ of perennial stream and 100’ of intermittent stream–as 

designated under PACFISH, INFISH 

6 Manual only sites will not be treated with herbicides because the desired weed management goal can be effectively 

achieved using manual methods. Such sites are typically very small or having widely scattered weeds or are in sensitive 

areas like a campground along a stream or a combination of these factors. 

Biocontrol note: the ’94 EA approved the use of biocontrol agents, however, all sites were analyzed for chemical 

treatments to attain highest amount of flexibility and greater invasive plant species control. The forest has also released 

APHIS and state of Oregon approved biocontrol agents on approximately 2,500 acres for the control of invasive weeds 

(Yates 2007). 

Alternative A – No Action 

Direct and Indirect Effects to Soils 

Manual, Mechanical, Cultural and Biological treatments would continue under the existing 

decisions from the Wallowa-Whitman National Forest Environmental Assessment for the 

Treatment of Noxious Weeds (USDA Forest Service 1994). Manual treatment (weed pulling) 

may occur along any roadsides. These treatments would continue but the acreage treated is 

limited by the high cost per acre. Under this alternative less than 23 percent of known sites 

would be treated with herbicide, leaving a heavy reliance on manual treatments. Repeated 

manual treatments may be effective for controlling or containing small populations of certain 

plants and may pose less risk to non-target vegetation compared to herbicide treatments. 

However, associated labor, time and cost may make manual treatments less practical and 

effective, especially when treating large infestations of invasive plants. 

Alternative A, the No Action Alternative, would continue the use of glyphosate, picloram and 

triclopyr on up to 5,172 acres a year on 124 sites. There could be a short-term (1 to 2 years) 

reduction in soil cover for the areas treated. This localized reduction in cover would increase 

treated areas vulnerability to soil erosion on moderate sloped areas. The effects would be 

minimal given the poor quality of groundcover provided by the invasive species proposed for 

treatment. These effects would last approximately one season until vegetation re-establishes. 

The No Action Alternative treats only invasive plant sites identified at the time of the project, 

and does not leave a mechanism to treat new inventoried sites, or future inventoried sites. 

Therefore, it is expected that invasive plants would continue to spread, increasing the number of 

acres negatively affected by invasive plants. 

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Adverse tradeoffs with Alternative A, in this case the risk of non-treatment, would be highest for 

noxious weeds that establish monoculture stands within native communities. Tradeoffs are 

weighed by comparing spread rate versus the impact from treatment (D’Antonio et al. 2004), 

especially in regards to affecting nontarget plant species where a target weed species may be 

replaced by another invasive weed such as cheatgrass (see Ortega 2005). 

Though most of the current infestations are associated with disturbed areas such as old 

homesteads or along road corridors, the very high spread rates realized in the past ten years 

suggests that many of the intact native plant communities are vulnerable to noxious weed spread 

(see Botany report). Whitetop and meadow hawkweed have particularly widespread invasibility 

that extends into the timberlands where current plant/soil regime could be shifted to greater forb 

dominance. For dry grasslands, the annual grasses cheatgrass and medusahead have high 

invasive potential; in particular, medusahead favors heavy clay soils found on Hells Canyon 

river terraces (Talsma 2006 personal communication). More ubiquitous is the risk for the 

knapweeds and starthistle (Centaurea sp.) spreading into dry grassland leading to plant/soil 

changes. Tyser and Key (1988) documented spotted knapweed spread into relatively undisturbed 

grassland in Glacier National Park. 

The risk for not treating highly disturbed sites is not as critical since prior disturbance has offset 

soil community structure to favor fast growing species as demonstrated with old field succession 

studies (Paschke et al. 2000). Forest standards 12 and 13 (W-W LRMP as amended by the R6 

2005 ROD) would be used to establish long term strategies for controlling invasives where 

treatments are applied. However, these areas remain a source for noxious weeds to spread to 

other areas. 

Cumulative Effects 

This alternative is covered under previous NEPA projects. Treatments would occur on an 

extremely small percentage of any watersheds in the project area. Direct and indirect effects are 

so insignificant and temporary that treatment under No Action could not plausibly contribute to 

significant cumulative effects. 

Alternative B – Proposed Action 

Direct and Indirect Effects to Soils 

Effect of mechanical and manual treatments would be very low and similar to those discussed 

under general effects and under Alternative A. While the relative amounts of manual and 

mechanical treatments vary between the alternatives, these differences would not be measurable. 

Alternative B has the highest risk to soils associated with herbicide treatment, while having the 

most aggressive means for curtailing the negative effects of noxious weed spread on 

soil/communities. Alternative B and all action alternatives have measures for early detection and 

rapid response for unknown invasive populations. Herbicide treatments are proposed for up to 

19,173 of the total 22,842 acres inhabited by invasive plants. Only 3-5 thousand acres of 

treatment are expected to occur in any one year due to budget constraints. Aerial and groundbased broadcast treatment has more potential to adversely affect nontarget vegetation and soils. 

The tradeoffs depend on the treatment type, vegetation and slope with effects grouped according 

to aerial treatment, highly disturbed areas and low to moderate sloped dryland grassland and 

forest. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Negative effects of herbicide treatments would be transient and adversely effect soil biota for 

less than one year, though plant/soil community structure may be affected. Approximately 4000 

acres would have high risk for changes in soils community after treatment-mostly low to 

moderate sloped dry grassland areas with some disturbance occurred. Risks for soil community 

changes after treatment are low for high trafficked areas (11,753 acres) and on steep, rugged 

ground. Plant/soil communities in high trafficked areas are already in a disturbed state and the 

steep rugged ground (3,870 of 6,771 acres) has greater resilience. 

Alternative B would have short term erosion risk where large monocultures of weeds would be 

treated on moderately steep slopes. These include stands of whitetop, common crupina, and steep 

roadside knapweed occurrences. Smaller stands of treated annual grass may have slightly higher 

erosion risk from finer vegetation litter. Erosion risk would decline as non-target vegetation reestablishes. 

Aerial Treatments 

Though considered high risk, the aerial treatments may have less adverse effects since much of 

the treatment occurs in steep, rugged country where remnant grassland species are available for 

revegetation. Monitoring of aerial treatment of starthistle in Hells Canyon steep areas found no 

apparent adverse effects to native grassland and only temporary decreased growth of arrowleaf 

balsamroot, a forb found to be sensitive to picloram treatments (Talsma et al. 2005, unpublished 

document, Ortega et al. 2005). The planned aerial treatments on the Wallowa-Whitman occur in 

similar areas including steep grassland terrain in Hells Canyon National Recreation Area. The 

aerial sites proposed for treatment are infested with yellow starthistle and scotch thistle. These 

sites occur primarily in grassland, meadow or shrub land vegetation types (88% of mapped 

acres). The sites tend to be isolated with steep slopes. The risk for affecting nontarget plants/soils 

remain within the first year for the lower sloped areas planned for treatment where residual 

disturbance has affected the current soils/vegetation community. The risks are associated with 

other invasive plants moving in after treatment such as cheatgrass and medusahead. Mitigations 

address these risks calling for long term site planning and assessing the current regrowth 

potential for active restoration. Of the two herbicides planned for aerial applications (picloram 

and clopyralid), clopyralid would have the least impact on non-target species. Picloram can 

affect seedling conifer growth with subsequent impacts on plant functional groups and associated 

soil communities (SERA 2003).

Highly disturbed Areas 

The proposed treatment of herbicide along high traffic areas would not adversely affect soils. 

These high traffic areas include road corridors or where high disturbance occurs such as 

trailheads, stock yards or old agricultural areas since vegetation is disturbed such as old harvest 

areas. Soil communities are largely uniform and disturbance oriented; therefore, impacts are not 

anticipated. Approximately, 11,753 acres is planned for herbicide treatment along these 

travelways. Herbicide application is planned at regular intervals due to the sustained risk. 

Low Sloped Dryland Grassland and Forest 

Where native communities are largely intact the tradeoff of risk to soils from herbicide 

application versus invasive weed spread is less apparent. 

Habitats that may be affected are the highly invasible dry grassland. Using the WallowaWhitman National Forest Landtype Association mapping (Sasich 2006) and planned treatment, 

roughly 1,680 acres could have broadcast spraying on low to moderate sloped dry grassland or 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

dry forest. The mixed conifer and shrubland types may not have the same level of risk due to 

less species rich communities. 

For dry grassland communities on moderately productive soils, broadcast herbicide application 

has higher risks associated with the elimination of non-target species. The herbicide treatment 

would target the knapweeds and star thistle, medusa head, and Scotch thistle. The impact of the 

treatments may lead to short term reductions in native grassland forbs (Pokorny et al 2004) with 

some transitory effects on soil biota. Ortega et al (2005) showed sustained losses of arrowleaf 

balsaroot and other native forbs over three years of monitoring in fescue grassland in Montana. 

In addition, treatment can lead to invasion by other exotic species. Ortega et al. (2005) has 

preliminary findings with winter range restoration that suggest cheatgrass is increasing in 

response to spraying for spotted knapweed. To minimize this risk, the project design features 

specify long term site planning prior to herbicide treatment to weigh invasibility and evaluate 

restoration needs (also see W-W LRMP as amended by R6 2005 ROD Standards 12 and 13). 

Early Detection Rapid Response 

Early Detection Rapid Response (EDRR) is part of all the action alternatives. Under this 

approach new or currently unknown infestations may be treated using the range of methods 

proposed in this environmental impact statement on sites similar to those presently proposed for 

treatment. Project design features would constrain treatment methods according to site specific 

conditions to minimize impacts. However, aerial applications have added risk over ground based 

methods for adversely affecting nontarget plants and soil (R6 2005 ROD). Aerial application 

would have the greatest risk where intact low to moderate sloped dry grasslands exist. 

Cumulative Effects 

Most of the 10 herbicides used under this alternative would have short term transient effects on 

soil biota. Picloram and sulfometuron methyl have the highest risk for affecting soil organisms 

with repeated treatment at typical application rates. These herbicides have half-lives of 90 days 

and 10-100 days (see Table 41) depending on soil conditions. Project design features limit use of 

sulfometuron methyl to once a year and picloram to once every two years at specific treatment 

sites to minimize soil buildup of herbicides and thus lower risk for long term effects. 

Alternative C – No Broadcast within Riparian Conservation Habitat Areas 

Direct and Indirect Effects to Soils 

The effects of this alternative are the same as Alternative B except herbicide treatment in 

Riparian Habitat Conservation Areas (RHCA) is limited to spot treatment only. Alternative C 

would elimination broadcast herbicide treatment for 3,104 acres and therefore lessens risk of 

herbicide leaching to groundwater. For Alternative B and D, project design features address this 

risk by excluding highly mobile picloram and clopyralid the inventoried invasive plant sites that 

have sandy or excessively well-drained soils and shallow water tables. 

Alternative C would be nearly as effective in reducing the negative effects of invasive weeds 

changing soil communities with the same amount of acreage planned for treatment as Alternative 

B. The spot spraying identified in Alternative C may be slightly less effective reducing spread 

within RHCAs. Risks to soil biota and surface erosion are similar to Alternative B. 

The eliminated broadcast spraying occurs on highly disturbed areas along roads and high traffic 

areas, where soils communities would not be changed. This alternative carries the same risk as 

all action alternatives with EDRR planned. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Cumulative Effects 

Cumulative effects are the same as discussed under Alternative B. 

Alternative D – No Aerial Application 

Direct and Indirect Effects to Soils 

The effect of this alternative would be the same as for Alternative B except aerial treatment 

would not occur. This alternative would be less effective at addressing invasive weed impacts on 

soils in the rugged steep areas of Hells Canyon due to lack of access for groundbased herbicide 

application. Roughly, 822 acres would be added to biocontrol treatments and the balance of the 

875 acres planned for aerial in Alternative B would likely be untreated. Since most of the acres 

of the dropped aerial treatment would be in steep areas where negative impacts on soils are not 

anticipated, Alternative C would not likely show improved effects on soils. Risks to soil biota 

and for surface erosion are similar to Alternative B. This alternative carries the same risk as all 

action alternatives with EDRR planned. 

Cumulative Effects 

Cumulative effects are the same as discussed under Alternative B. 

Water 

In the Forest there are approximately 6,345 acres of invasive plants within treatment areas in 

RHCAs. Of these 38 are to be treated with manual control, and 6307 acres would be treated by 

manual, mechanical or chemical treatment, depending on site conditions. The RHCAs would be 

excluded from aerial treatment and would need to be treated by groundbased methods or not at 

all. These acres are scattered across the Forest within 53 different 5th field watersheds. The 

largest acreage of invasive plants within RHCAs in a single 5th field watershed is approximately 

1,273 acres within the common bugloss site, which is a 5,813 acre treatment area in Middle 

Imnaha River Watershed. There are approximatel 393 acres of RHCAs included within 

biological control areas. 

General Effects of Manual and Mechanical Treatment 

Mechanical treatments except for mowing would take place away from water. Mowing would 

occur only along established roads. Manual effects are generally cutting, digging or pulling 

weeds. If seeds are present the weeds are bagged and taken off site. As only small sites would be 

treated with manual treatments loss of soil cover would be very small. However there could be 

small localized areas of erosion and subsequent sediment input to the stream. These effects 

would be transitory and too small to measure. Pulling weeds along stream banks could also 

destabilize the banks in highly localized areas. These small treated areas are expected to 

revegetate within a season. As most of the treatments areas are previously disturbed roadways 

and trails, it is unlikely that the small additional ground disturbance would be a significant 

change from the existing condition. Modification of surface ground cover can change the timing 

of run-off but given the small areas of treatment, any changes would be transitory and too small 

to measure. 

General Effect of Biological Control 

Biological control can be defined as the use of natural enemies to reduce the damage caused by 

invasive plant populations. Biocontrol is often viewed as a progressive and an environmentally 

friendly method to control pest organisms because it leaves behind no chemical residues that 

might have harmful impacts on humans or other organisms. When successful, it can provide 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

essentially permanent, widespread control with a very favorable cost-benefit ratio. For example, 

bio-control releases on yellow starthistle and diffuse knapweed have shown positive control 

results on Walla Walla District in the past (Mitchell 2006). 

Bio-control agents previously released and established on the Forest will continue to spread to 

other nearby invasive sites providing a potential long-term control treatment. The primary effect 

from biological controls is standing dead plants. There would be small unmeasurable changes to 

soil or water resources from any biological control considered on the Forest. 

General Effects of Cultural Treatments 

Cultural treatments proposed for this project include seeding and planting native species, and 

mulching and fertilizing. Of these, only fertilizing has the possibility of introducing foreign 

material into streams, water bodies or ground water. Application of fertilizer is easy to control; 

therefore, would not likely be inadvertently introduced into surface water bodies. There exists a 

remote possibility that fertilizer applied on sites with well drained to excessively well-drained 

soils could leach into ground water, which may result in dissolved minerals, particularly nitrigen, 

in the ground water. Fertilizers would be applied only on seeded areas where a general herbicide 

has killed most ground vegetation; therefore, the likelihood of fertilizer minerals entering the 

groundwater often enough to cause significant contamination are remote. That is, the likelihood 

of seeding large acreages of well-drained to excessively well-drained soils is considered remote.

General Effects of Herbicide Treatments 

None of the alternatives have the potential to influence stream flow and channel morphology due 

to the small portion of any watershed that would be treated. 

Treating invasive plants would improve riparian stability where invasive plants have colonized 

along stream channels and out-competed native species. All invasive plant treatments carry some 

risk that removing invasive plants could exacerbate stream instability; however, the restoration 

plan accounts for these areas and prescribes mulching, seeding and planting as needed to 

revegetated riparian and other treated areas to minimize impacts from treatments. 

A primary issue for this analysis is the potential for herbicides to enter streams and impact 

domestic water sources and/or aquatic organisms. This section describes how Project Design 

Features minimize the possibility that herbicides would enter water and impact water quality. 

Based on the R6 2005 FEIS, herbicides were grouped by their potential to harm aquatic 

resources. The herbicides of lower concern for aquatic resources are: clopyralid, imazapic, and 

metsulfuron methyl. The herbicides of moderate concern for aquatic resources are: chlorsulfuron, 

imazapyr, sulfometuron methyl. The herbicides of greatest concern are: non-aqueous glyphosate, 

triclopyr, picloram, and sethoxydim. The aquatic formulations of glyphosate, triclopyr, and 

imazapyr may have more adverse effect effects to aquatic resources than the low concern 

herbicides but are licensed for use near or in water. Streamside buffers vary depending on the 

level of concern. 

Drift, Run-off and Leaching 

The routes for herbicide to contaminate water are; direct application, drift into streams from 

spraying, runoff from a large rain storm soon after application, and leaching through soil into 

shallow ground water or into a stream. This section addresses each of these delivery routes. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

No direct application of herbicide to water is proposed in any alternative. No emergent plants 

would be treated under any alternative. 

Effects from drift, runoff and leaching were considered in the herbicide risk assessments, 

prepared for the R6 2005 FEIS, assuming broadcast treatments occurring directly adjacent to 

streams. The Groundwater Loading Effects of Agricultural Management Systems (GLEAMS) 

model was used to estimate the amount of herbicide that may potentially reach a reference 

stream via runoff, drift and leaching in a 96 hour period, assuming broadcast treatments on a 50-

foot strip along about 1.6 miles of perennial stream. SERA risk assessments evaluated the 

hazards associated with each herbicide based on the concentrations of herbicide predicted by the 

GLEAMS model using these parameters. 

To avoid any adverse effects to streams, PDFs were developed to give added protection to 

streams and to minimize herbicide concentrations in streams. The GLEAMS modeling likely 

overestimates the herbicide concentrations that would plausibly enter streams from this project, 

primarily because broadcast treatments (used in the model) are prohibited within 100 feet of all 

perennial streams in all alternatives. Spot treatments using herbicides of higher concern to 

aquatic organisms along streams would also be buffered. Hand and spot treatments are inherently 

far less likely to deliver herbicide to water because the herbicide is applied to individual plants, 

so drift, runoff and leaching are greatly minimized. Small amounts of some herbicides can translocate from the plant to the soil or an adjacent plant, but the concentrations of herbicide that may 

be delivered to streams from this mechanism is much less than GLEAMS predictions which 

models broadcast spraying of herbicide next to the stream with no buffer between the spraying 

and the stream. 

Monitoring Studies 

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 had no detectable 

concentrations of herbicide in monitored streams with detection limits of 1-3 mg/m3 (ibid). 

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 

(comparable to 100 feet) (USDA Forest Service 2003a, Appendix B). No detection limits were 

given. 

The USGS in partnership with the Oregon Department of Transportation studied runoff of 

herbicides along roads (Wood 2001). The study was conducted on runoff associated with several 

herbicides (including 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 and found concentrations of several hundred 

ppb of sulfometuron-methyl and nearly 1,000 ppb of glyphosate that could potentially leave the 

road shoulder. 

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 1 parts 

per billion (ppb) along the shoulder and from 0.3 to 0.1 ppb 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 sulfometuron methyl may 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

persist in the environment as it was detectable along the shoulder of the road (but not in the 

stream) the entire duration (three months) of the study. 

Berg reported that herbicide applied in or along dry ephemeral or intermittent stream channels 

may enter streams through run-off if a large post-treatment rainstorm occurred soon after 

treatment. 

This risk is minimized if intermittent and ephemeral channels are buffered as would occur under 

the action alternatives (ibid.). 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. 

Aerial Application 

Wind drift is the mechanism most likely to carry herbicide to nontarget 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 44). Droplet size can be increased by: 1) reducing spray pressure; 2) 

increasing nozzle orifice size; 3) using special drift reduction nozzles; 4) 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. 

Table 44-Drift distance versus drop diameter 

Droplet Diameter 

(microns) Type of Droplet 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 

 Source http://www.ag.ndsu.edu/pubs/plantsci/weeds/a657w.htm #factors available in project record 

Washington State Department of Ecology and Oregon Department of Forestry have monitored 

aerial application of herbicides in forest settings. 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. 

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 

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assumed to be dry. Peak herbicide concentrations ranged between 0.2 and 7.55 ug/l (same as 

7.55 parts per trillion). Maximum 24 hour averages were between 0.13 and 3.25 ug/l. 

Runoff samples collected at 4 sites 2 to 24 days after application had concentrations between 

0.17 and 2.49 ug/l. 

Oregon requires buffers of 60 feet for aerial application of herbicides near fish bearing streams 

or streams used for domestic water supplies. Two streams outside this category also received 60 

foot buffers (actual on the ground buffers ranged from 60 to 100 feet). 

For the Oregon study most of the samples (21 sites, and 105 post spray samples) had a detection 

limit of 1 ug/l. None of these samples had concentrations at detectable limits. 

Five sites (25 samples) had detection limits of 0.04 to 0.5 ug/l. Most samples were still below 

detectable limits, but 7 of the 25 samples tested between 0.9 and 0.56 ug/l (Dent and Robben 

2000). 

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 applications and 75 to 90 meters (225-270 feet) for streams downwind of 

applications. 

The Lolo National Forest and the Bitterroot National Forest have both used drift cards and 

collected water quality samples in areas where aerial application of herbicides was used. Buffers 

of 150-300 feet were used for streams on the Lolo and 300 foot buffers were used on the 

Bitterroot. On the Lolo the water quality samples were all below the detection limit of 1 part per 

10 billion. Of the 35 drift cards 1 showed herbicide near a stream. When herbicide was next 

applied to that site the buffers were adjusted and no herbicide was found on the drift cards. 

On the Bitterroot water quality samples were collected at two sites herbicide treatment areas with 

300 foot stream buffers in 2005. Drift cards were placed at set intervals across the buffer, 

between the stream and the marked line. Results from the lab indicated herbicide detection as 

“below detection limit” for all tested chemicals in all samples. No herbicides used in the 

spraying operation were detected in the water samples. All drift cards were visually scanned for 

droplet presence. No cards were found with visible droplets after the spray treatments. More 

information on the Lolo and Bitterroot studies are available in the Botany Report for this project 

available in the project record. 

All aerial applications of herbicides will comply with EPA label restrictions and state 

regulations. Using the recommendations above, the following PDFs were developed to minimize 

potential impacts to water. E-2 requires that fueling occurs outside the RHCA where ever 

possible. F-5 requires that herbicide applications occur when winds are between 2 and 8 miles 

per hour. F-6 requires coarse droplet size to minimize drift. F-8i requires that aerial units be 

ground checked and water features marked and buffered before application. Buffers of 300 feet 

are required on perennial or wet intermittent streams and wetlands, and 100 feet buffers are 

required on dry channels. 

Accidental Spill 

Concentrations of herbicides in the water 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 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

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). 

Accidental spills are not considered within the scope of the project. Project design features 

would reduce the potential for spills to occur, and if an accident were to occur, minimizes the 

magnitude and intensity of impacts. An herbicide transportation and handling plan is a project 

requirement. This plan would address spill prevention and containment. 

Lakes 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 with 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. 

Some invasive plants may grow in wetlands or near lakes and reservoirs. PDFs require that only 

spot or hand treatments occur within 100 feet of lakes or wetlands. A large rain event after 

treatment could carry herbicide into water resulting in minor amounts of herbicide contacting 

surface water. Different herbicides degrade at different rates, therefore the length of time 

herbicide is available for transport at any site depends on the herbicide used, application rates, 

local weather, and soil types. See Table 41 – Herbicide Properties for more details. Only small 

acreages of treatment have been identified at any site near a waterbody. Only upland species 

have been identified at these sites. 

To minimize risk to wetlands no more than 10 acres or half of a wetland would be treated in any 

30-day period. There is no treatment of emergent vegetation proposed under any alternative; 

therefore the wetland would be dry at time of treatment. 

The design features for wetlands limit the area treated at one time for two reasons: 

1. To lower the amount of herbicide near the water body at one time and give time for 

the herbicide to degrade. Many of the herbicides degrade quickly in soils high in 

organics. 

2. Treating only half a wetland at a time provides refugia for aquatic organisms in other 

parts of the wetland. 

Small, unmapped ponds found during implementation planning would have the same PDFs on 

herbicide use within 100 feet of the pond. 

Municipal Watersheds and Domestic Water Supplies 

No herbicide application is proposed within municipal watersheds under any alternative. 

Biological control is being used for Canada thistle within the La Grande Municipal Watershed. 

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Other water supplies such as wells or springs at campgrounds would be buffered from herbicide 

application to protect water quality. PDF H-11- Herbicide use would not occur within 100 feet of 

wells or 200 feet of spring developments. 

Comparison of Alternatives 

See Table 44 to compare treatment methods and acres proposed for treatment for each 

alternative. Chapter 2 of the EIS offers a more detailed alternative comparison. 

Alternative A – No Action 

Direct and Indirect Effects 

In the No Action Alternative management of invasive plants would be applied using decisions 

made from the Wallowa-Whitman National Forest 1994 Environmental Assessment for the 

Treatment of Noxious Weeds. Since the incorporation of the Regional guidelines into all Region 6 

Forest plans, the No Action Alternative is now limited to three herbicides (glyphosate, triclopyr 

and picloram with restrictions) for use on approved sites (5,172 acres) approximately 23 percent 

of known sites. Biocontrol agents have been released on approximately 2,500 acres in the past. 

Broadcast application could take place on up to 1,932 acres within RHCAs under this alternative 

and could be used for spot application on up to 663 acres. Only three herbicides are available for 

use under this alternative. Picloram, a high risk herbicide for aquatic resources, is still preferred 

in many situations because it is a selective herbicide which kills only certain plants and has a 

residual effect to suppress reestablishment of target invasive species. Triclopyr is selective for 

woody and broadleaf vegetation. Glyphosate, the third choice, is nonspecific and kills all 

vegetation. However, glyphosate is less mobile than picloram or triclopyr and therefore less 

likely to move from the applied site into water. 

There would be heavy reliance on manual treatments to treat any new invasive plant sites. Past 

monitoring of these treatment methods (by the forest) indicates limited success using these 

methods (Yates 2006). Manual treatments near streams could increase sediment input to streams. 

However, due to expenses associated with manual treatments, most sites would not be treated 

under this alternative allowing invasive plants to continue to spread. This would increase the 

number of acres negatively affected by invasive plants. These effects are described above in the 

Affected Environment section of this report. 

Invasive plants would continue to grow on sites where treatment is currently not authorized by a 

NEPA analysis, approximately 17,670 acres, (77%) of known infested acres. Invasive plants are 

often less effective for stream bank stabilization than deeper rooted native plant species. Most 

invasive plants also provide less stream-shading than native hardwoods and conifers. 

Cumulative Effect 

This alternative is covered by Decisions from the 1994 EA. Treatments would occur on an 

extremely small percentage of any watersheds in the project area. Direct and indirect effects are 

so unmeasurable and temporary that treatment under No Action does not contribute to significant 

cumulative effects. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Alternative B – Proposed Action 

Direct and Indirect Effects 

Up to 6,345 acres of treatment could take place in RHCAs including 6,307 acres proposed for 

chemical treatment as the first choice and 38 acres proposed for manual treatment.as the first 

choice. 

Almost 50 percent could be broadcast sprayed with the other 50 percent treated by spot or hand 

methods. In reality, most of these areas have only discontinuous infestations of invasive plants 

estimated at 25 percent of the treatment area. 

None of the treatments are extensive enough under any alternative to effect peak flows, low 

flows or water yield. Methods used for treatment would have negligible effect on water 

infiltration into soil and associated surface runoff. Only the bugloss site in the Middle Imanaha 

Watershed has more than 2 percent of the watershed proposed for treatment and most have less 

than 1 percent of the watershed proposed for treatment (Table 40). This amount of vegetation 

change is too small to show effects to flows from treatment. The common bugloss site, which 

would treat up to 1500 acres scattered across the 5813 acre site, would use types of herbicides 

that target broadleaf plants, leaving the majority of the area vegetated with grasses. Therefore, 

even the large common bugloss site would show no changes in flow. 

Generally, small areas would be treated along streams. The majority of the sites (41%) are less 

than 1 acre (Table 40). Slightly over 1 percent range from 100 to 500 acres and 0.2 percent of the 

sites (4 sites total) are greater than 500 acres. As most invasive plants provide little shade, 

removal of these plants is unlikely to have any measurable effect to stream temperature. 

As these methods target individual plants, the risk from spot or hand application of herbicides to 

native riparian vegetation is small. Where taller native shrubs replace the shorter invasive plants, 

shading of streams would contribute to reduced temperatures on some streams. Where passive 

restoration occurred native vegetation would slowly become reestablished. Where restoration is 

applied, reestablishment of native vegetation could occur more quickly, within a few years. 

Manual and Mechanical 

Only 111 acres of manual treatments over 145 sites are planned with this project. This includes 

38 acres of manual treatment over 94 sites within RHCAs. The largest manual treatment sites are 

2.6 acres of treatment of scotch thistle along the East Fork Fence Creek, 1.8 acres of medusahead 

on Spring Creek and 1.7 acres of hoarycress white top on an unnamed stream in the Lower 

Imnaha Watershed. As the sites are scattered across the Forest only localized effects would be 

expected, lasting only one season until vegetation reestablished. 

Where manual methods remove invasive plants near streams there could be minor loss of ground 

cover and soil disturbance leading to erosion and a minor localized increase in fine sediments 

particularly if vegetation is removed from stream banks. This increase would only last a season 

or two until vegetation became re-established and is not considered significant. Many treatment 

sites are small and would reseed naturally with existing native vegetation. Where restoration is 

applied, sites lacking native vegetation seed source to ensure revegetation occurs and erosion 

would be controlled. Mechanical treatment is primarily mowing and would occur along roads. 

This would have negligible effect on stream functioning. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Non-Aerial Treatment 

Project Design Features minimize the chance of herbicides reaching streams through drift, 

runoff, or leaching into soils. Buffer widths vary depending on label requirements, aquatic risk 

ranking (established in the R6 2005 FEIS) and application method. For example within 100 feet 

of perennial streams no broadcast treatments would occur. PDFs and label requirements prohibit 

use of the more mobile herbicides on shallow soils. This would protect groundwater, particularly 

in areas where shallow soils cover fractured bedrock. 

Boom or hand broadcast treatments within RHCAs have different buffer widths depending on 

each herbicide’s risk to aquatic organisms. Within 100 feet of streams no broadcast would occur. 

Herbicides considered high risk to aquatic organisms would not be applied using any method 

within 15 feet of ditches that feed streams, or 50 to 100 feet from intermittent streams, even 

when ditches or intermittent streams are dry. These buffers are considered adequate to minimize 

herbicide concentrations in water because, buffer studies in forested areas (Berg 2005) show that 

buffers greater than 25 feet commonly lower herbicide concentrations below any threshold of 

concern and often below detectable limits. 

Glyphosate and imazapyr are the only herbicides used for spot spraying up to waters edge along 

perennial channels. Glyphosate is highly water soluble but because it adheres tightly to soils is 

unlikely to be carried into a stream unless the soil particle is carried into the stream. This is 

unlikely to happen during the late spring or summer when herbicides would be applied because 

there is less rain in the summer and more vegetation growth to hold soil particles in place. If 

glyphosate is carried into a stream by runoff, it preferentially stays with the soil over partitioning 

into water. Imazapyr is only moderately water soluble and forest field studies have not found it 

very mobile in soils (SERA 1999) 

Herbicides entering surface water through surface runoff are also expected to be minimal, since 

targeted spot spraying techniques or hand application techniques would be used to apply 

herbicide within 100 feet of surface water. This would minimize the amount of herbicide 

reaching the ground surface as well as minimize the potential for herbicide drift. No herbicides 

considered high risk to aquatic resources would be broadcast within 100 feet of streams and none 

would be spot sprayed within 50 feet of streams (Table 7 and Table 8). Further, PDF H-13 

restricts treatments above bankfull, within the aquatic influence zone to not exceed 10 acres 

along any 1.6 mile of a stream, per 6th-field HUC and treatments between water’s edge to 

bankfull width will be limited to 2 acres for every 1.6 miles of stream length per 6th field HUC. 

Some streams within road corridors have treatment areas that parallel both the road and the 

stream with many continuous acres of treatment within the aquatic influence zone. In reality 

these areas have invasive plants scattered among other vegetation along the stream. To model a 

worst case scenario a few of these areas with the highest proposed treatment acres were modeled 

for site specific soil types and rainfall with the SERA worksheet. In addition, two hypothetical 

treatment areas were modeled for 75 inches of rain fall to simulate a 2 inch in 24 hour storm. 

These hypothetical sites were modeled with sandy soil and clay soil; the soil types most likely to 

allow runoff into the stream. Only aquatic glyphosate and aquatic imazapyr were modeled with 

the high rainfall and sandy soil as clopyralid is not allowed for use on sandy soil according to 

project PDFs. 

Specific sites 

Some streams within road corridors have treatment areas that parallel both the road and the 

stream with many continuous acres of treatment within the aquatic influence zone. In reality 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

these areas have invasive plants scattered among other vegetation along the stream. To model a 

worst case scenario a few of these areas were modeled for site specific soil types and rainfall 

with the SERA spreadsheet. 

Gumboot Creek and an unnamed tributary have 99 acres within treatment areas within 100 feet 

of the streams. The treatment area is along 6.5 miles of Road S39 which is entirely within the 

RHCA and much of the time within 100 feet of the stream. The invasive plants within these areas 

are spotted knapweed and Canada thistle. In reality less than 25 percent of the treatment area is 

infested with the invasive species, which is approximately 25 acres scattered over about 6.5 

miles. Broadcast spraying could occur in the outer part of the RHCA but only spot and hand 

treatments could occur within 100 feet of the stream. 

North Pine Creek and tributaries have approximately 110 acres within treatment areas within 100 

feet of the streams. With an average infestation of 25 percent of the site there would be about 27 

acres of actual infestation along approximately 12.5 miles of road. The treatment areas are along 

Road S39 and parallel North Pine Creek. The invasive plants to be treated include hoary cress 

whitetop, diffuse knapweed, and Canada thistle and St. Johns wort. Part of the St. Johnswort 

would be treated with biocontrol. 

The two sites discussed were chosen for site specific modeling using the SERA worksheet. 

These sites were chosen because they have the most treatment within the RHCA and because 

they have higher rainfall than many of the sites at lower elevation. The amount of herbicide that 

runs off is highly dependent on rainfall and soil type. All the broadcast sites along streams are 

also along roads. 

Roads are highly disturbed areas with compacted soils and tend to have higher runoff than 

undisturbed sites. Herbicides were run with the soil type where they would have the most runoff. 

The herbicides chosen to model were the two allowed for spot spraying up to waters edge and 

clopyralid, a highly effective herbicide for the species to be treated. 

The application scenario analyzed in each SERA worksheet assumed the following site 

conditions and application methods for herbicide application: 

• Herbicide was evenly-applied by broadcast application right up to the water’s edge. 

• Herbicide was applied to a site with a 10 percent slope 

• The stream that the herbicide values are predicted for has a flow of 1.8 cubic feet per 

second (cfs). This equates to a stream approximately 6.6 feet wide and 1 foot deep. 

• The application block is 10 acres in size and configured in a rectangle that is 50 feet 

wide by 8,672 feet long along the stream and all herbicides are assumed to drain from 

the block to a single location and emptying into the water body at that point. 

These site conditions cannot be changed. The variables that can be changed are rainfall, soil and 

herbicide amount used per acre. For these sites typical application rates were used, the rainfall at 

the highest elevation along the stream and the hypothetical streams used a rainfall which would 

give 2 inches of precipitation within 24 hours, which is a large storm for this area. As the 

treatments are not continuous but are scattered along miles of road, the model would be 

considered conservative and would overestimate potential herbicide concentrations. 

The result of this analysis shown in Table 45 below indicates all Hazard Quotient (HQ) values 

were well below 1; therefore, no levels of concern were exceeded for sensitive fish under these 

scenarios. The R6 2005 FEIS notes that as HQ increases above 1, the margins of safety decrease. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 45-Potential herbicide concentrations in water for different precipitation ranges and soil types 

Herbicide/ 

location 

Annual 

Precipitation 

(inches)/ 

(Modeled 

Precipitation) 

Peak Water 

Contamination 

Rate (mg/L per 

lb/acre) 

Maximum 

Concentratio

n in water 

(dose) (mg/L) 

Toxicity 

Index for 

Listed Fish 

(mg/L) 

Hazard 

Quotients 

(sensitive fish) 

Glyphosate (2 lbs/acre) 

North Pine 

Creek 40 0.038 0.076 0.5 0.15 

Gumboot 

Creek 50 0.056 0.112 0.5 0.23 

Hypothetical 

creek-sand (75) 0.099 0.198 0.5 0.40 

Hypothetical 

creek-clay (75) 0.036 0.072 0.5 0.14 

Imazapyr (0.45 lbs/acre) 

North Pine 

Creek 40 0.0004 0.00019 0.135 0.0014 

Gumboot 

Creek 50 .0006 0.00028 0.135 0.0021 

Hypothetical 

creek-sand (75) .00023 0.00010 0.135 0.00077 

Hypothetical 

creek-clay (75) .00096 0.00043 0.135 0.0032 

Clopyralid (0.35 lbs/acre) 

North Pine 

Creek 40 0.0096 0.0034 5.15 0.00065 

Gumboot 

Creek 50 0.0106 0.0037 5.15 0.00072 

Hypothetical 

creek-sand (75) 0.031 Not used on sandy soils Under PDFs 

Hypothetical 

creek-clay (75) 0.0105 0.0037 5.15 0.00074 

Common bugloss in the HCNR along the Imnaha River 

The largest treatment area is 5,813 acres for common bugloss along the Imnaha River. This area 

is a mixture of private and Forest land with most Forest controlled land in the uplands. The 

private property owner would aerial spray common bugloss on infested areas within the 5500 

acres of private land, probably using metsulfuron methyl. As metsulfuron methyl is not allowed 

for aerial spraying on Forest land in Region 6, the Forest controlled area would be treated using 

biocontrol and ground based methods. Metsulfuron methyl is a highly effective herbicide and 

low application rates are effective (typical rate of 0.03 lbs/acre). This lowers the amount of 

herbicide available for movement offsite compared to less effective herbicides with higher 

application rates. 

Estimates of acreage infested on Forest Service System land is approximately 1500 acres. These 

acres are scattered across the 5,808-acre site. Herbicides for use with backpack sprayers would 

likely be metsulfuron methyl or chlorsulfuron + metsulfuron methyl. Up to 25 percent (375 

acres) of the acres would not be treated because the infestations are on rimrock in areas too steep 

to access. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

If bugloss is found growing below bankfull, aquatic glyphosate or aquatic imazapyr would be 

used. The dead plants would also be left on site contributing to ground cover. Erosion and 

associated sediment delivery to streams would be negligible. 

Riparian Invasive Plant Species 

There are 77.5 acres of Japanese knotweed within treatment areas, 54.6 within RHCAs. In 

reality, these sites are a mixture of invasives with less than 20 acres estimated to be infested with 

Japanese knotweed. There are two sites presently identified. One site is along the confluence of 

Somers Creek and the Snake River on the west side of the Snake. This site is on 10-50 percent 

slopes in a narrower part of the Canyon. The knotweeds are in a treatment site that also contains 

yellow star thistle and scotch thistle that is approximately 64 acres, 

The other knotweed site is along Kurry Creek and the east side of the Snake River. This site is 

generally at less than 10 percent slope in the valley bottom. This site also contains purple 

loosestrife, puncture vine and yellow star thistle. The site is about 15 acres. 

The knotweed sites are the only sites to be treated by stem injection. Stem injection has a higher 

rate of success with knotweed compared to foliar application with fewer applications needed to 

eradicate the plants. It would be used on knotweeds with stalks greater than 0.5 inches thick. 

The smaller stalks are too small for injection and would be spot sprayed or wiped with herbicide. 

Where stem injection is used there would be no chance of drift. Small amounts of herbicide 

could be translocated to the soil from the plant roots. Glyphosate preferentially attaches to soil 

and is unlikely to enter water in appreciable amounts. 

Purple loosestrife is found at two small treatment sites along the Snake River totally about 2.5 

acres. It is estimated that there is 0.6 acres within the treatment areas infested at this time. 

Biocontrols have been tried but have not been effective at these sites. Glyphosate would be the 

herbicide of choice either spot sprayed or by cutting the stems and painting them with herbicide. 

As stated above glyphosate preferentially attaches to soil particles and in this low rainfall area is 

unlikely to enter water in appreciable amounts. 

Domestic Water Supplies 

Water sources, including those in campgrounds, recreational homes, and individual special use 

permit would be protected by PDF-H-11, which requires that herbicide use would not occur 

within 100 feet of wells or 200 feet of spring developments. There are 2.5 acres of Canada thistle 

identified for biological control on Beaver Creek in the La Grande Municipal watershed. There 

are no sites identified within the Baker Municipal Watershed. 

Roaded Areas 

There are 693 miles of road within treatment areas. Of these, 297 miles (43%) are within 

RHCAs and proposed for chemical treatments. Roads and their associated ditchlines are often 

connected to streams and during storm events can carry herbicide to streams; however, much of 

the Wallowa-Whitman National Forest System roads comply with regional road standards in that 

drainage structures are in place that divert runoff away from streams. Still, some roads with 

connected ditchlines are within RHCAs. Under this alternative, broadcast application of 

herbicides (both boom and hand) are allowed within the outer part of the RHCA. To minimize 

risk to aquatic resources, PDF H-2 requires that no high aquatic risk herbicides would be 

broadcast along roads that have a high risk of delivery to water (generally roads in RHCAs). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Therefore, for the 297 miles of road identified within RHCAs, picloram, non-aquatic triclopyr 

(Garlon 4), non-aquatic glyphosate, and sethoxidim would not be used. Though the probability 

of a large rain storm happening after application is low at any particular site, this additional 

protection measure would ensure that high risk herbicides are not delivered to streams in 

concentrations that exceed levels of concern. 

Aerial application 

Aerial application is proposed for 875 acres with 609 acres in the Hells Canyon Natural 

Resource Area and 266 acres in the La Grande District. The 83 acres within RHCAs would not 

be aerial sprayed but would be treated with other groundbased methods or left untreated. 

Other Aerial Sites 

Yellow starthistle-La Grande District - Yellow star thistle (266 acres) in eleven separate 

polygons ranging in size from 75 acres to less than 5 acres, would be treated in the La Grande 

District in the Lower Catherine Creek watershed. This area is just above private near the Forest 

boundary. One hundred and ninety-one acres are shown as grasslands and meadows and 75 acres 

as forested. The rainfall is between 28-44 inches with most of the site receiving between 32-36 

inches of rain a year. 

Scotch thistle-Hells Canyon - There are about 32 acres of scotch thistle in 3 scattered sites 

along the Snake River proposed for aerial spray. The rainfall averages 14-18 inches a year at 

these sites. 

Yellow starthistle-Hells Canyon - There are 658 acres of yellow starthistle in the HCNR in sites 

on the west side of the Snake River. There are 17 sites ranging in size from less than an acre near 

Experiment Creek to almost 250 acres near Lookout Creek. The average rainfall varies between 

12 and 20 inches depending on elevation. 

Picloram and clopyralid would be the most effective herbicides for the sites described above. To 

protect water quality, no aerial application would occur within RHCAs and all perennial streams 

would be buffered by 300 feet from herbicide application. Intermittent channels would be 

buffered by 100 feet from herbicide application. This would lower the risk from direct drift into 

water. 

The GLEAMS-Driver was used to model herbicide concentrations in water at two sites. The 

modeled sites are the 75 acres of treatment on Boswell Creek in the La Grande District and the 

259 acre site near Lookout Creek in Hells Canyon. The La Grande and Hells Canyon sites were 

modeled with the steeper slopes found at the sites and a very small stream with a flow of only 

0.3 cfs. The average rainfall used for all the sites was the highest rainfall for the area (Table 46). 

GLEAMS-Driver program operates as an interface for conducting GLEAMS runs and using the 

results of these runs to estimate exposures levels of herbicides to both adjacent fields and bodies 

of water (Durkin and Knisel, 2007) GLEAMS-Driver User Guide. This model allows exposure 

assessments based on site-specific parameters such as weather patterns, soil types, and physical 

characteristics of the site such as acres, slope and cover percent. See the GLEAMS-Driver User 

Guide for more details. The modeled parameters are in Table 46 below. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 46-Parameters used for model by location 

Location 

Site Characteristics 

La Grande Hells Canyon 

treatment acres 75 249 

site acres 75 249 

precipitation 40 18 

type of site agricultural field agricultural field 

application rate 0.25/0.35 0.25/0.35 

surface type meadow meadow 

initial cover 60% 40% 

soil type loam loam 

soil depth inches 16 12 

slope 50% 55% 

stream flow rate 0.3 cfs 0.3cfs 

stream width meters 2 2 

*higher application rate due to herbicide loss in field above treatment area along river 

Results of the GLEAMS-Driver model 

Both sites were under a Hazard Quotient (HQ) of one for clopyralid and are well below 

thresholds of concern for fish. For picloram, the Hells Canyon site had a HQ greater than one at 

the maximum concentration but was under one for the lower modeled concentration (Table 47). 

Neither the La Grande nor the Hells Canyon site has listed fish directly adjacent to the treatment 

area. For the Hells Canyon site, listed fish are found approximately 1.5 miles downstream in the 

Snake River. It is expected that the herbicide concentration would be lower downstream due to 

dilution. Untreated areas would help dilute herbicide in the stream by an unknown amount. 

Table 47-GLEAMS-Driver Model results for aerial sites 

Herbicide/ 

location 

Annual 

Precipitation 

(inches)/ 

(Modeled 

Precipitation) 

Range of 

Concentration in water 

(dose) (mg/L) 

Toxicity Index 

for Listed Fish 

(mg/L) 

Range Hazard 

Quotients for 

Listed Fish 

Clopyralid (0.35 lbs/acre) 

LaGrande 40 0.012-0.904 5 0.002-0.18 

Hells Canyon 18 0.005-0.137 5 0.001-0.03 

Picloram (0.25lbs/acre) 

La Grande 40 0.018-0.029 0.04 0.45-0.73 

Hells Canyon 18 0.026-0.05 0.04 0.65-1.25 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

AGDISP (AGricultural DISPersal) Model 

Given the soil protection provided by non-target vegetation, erosion and associated sediment 

delivery to streams would be minor and short-term (1 to 2 years). Of more concern from aerial 

application is water contamination from drift. 

AGDISP was first developed by NASA, improved by the USDA Forest Service and 

implemented by the Spray Drift Task Force and the U.S. Environmental Protection Agency into a 

regulatory version (Teske et al.2003). Harold Thistle, an expert on the use of this model, 

collaborated with this project to set-up the parameters for the model. 

Site specific conditions for aerial application of the Wallowa-Whitman National Forest were 

modeled. In general, for aerial application at these sites, the helicopter would be flown at 10 to 

25 feet off the ground when spraying grasslands. However, there are sections of the treatment 

areas with some tree cover and steeper slopes. For safety reasons the pilot may need to fly higher 

when near trees. The higher release heights are a concern as more drift could occur with a higher 

release height. 

Spray application height, wind speed and droplet size are the three most significant factors 

impacting drift distance and the potential to affect non-target areas. To model worst case 

scenarios, cross wind speed and droplet size were kept at the highest wind speed allowed (8mph) 

and a coarse spray droplet size (500 μm) commonly used for aerial application of herbicides and 

the smallest droplet size allowed in this project (PDF F-6). Three release heights were modeled 

for the largest aerial site. See Appendix F for more details on aerial modeling. 

The first run was for open grassland with a spray height of 25 feet and the following runs were 

with a spray height of 35 and 50 feet respectively with the other conditions remaining the same. 

Conditions 

• Eight mile an hour cross-winds toward the stream 

• Median droplet size is approximately 500 microns 

• Release height 25, 35 and 50 feet off the ground 

Results 

As expected, drift became greater as the release height increased. For a small stream (flow rate 

of 0.7cfs) directly downwind of the spray area, with a 300 foot buffer from the last swath, with 

no interception from vegetation (ground cover 1 foot tall) the amount of deposition to the stream 

is in the parts per billion and under any threshold of concern. 

Table 48-Concentrations of herbicide in a small stream with a 300 foot buffer 

Spray Height with 300’ Buffer Concentrations of Clopyralid (ppb) Concentrations of Picloram (ppb) 

25 feet 1.5 0.9 

35 feet 5.1 3.2 

50 feet 19.1 11.9 

 

However, the purpose of this project is to treat invasive terrestrial plants, and avoid herbicides 

getting in streams or other sensitive areas. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Therefore, to minimize offsite deposition to sensitive areas such as streams or non-target 

vegetation, speciel of local interest (SOLIs), or other sensitive areas, under the worst case 

scenario conditions the following design features would be used to lower drift 

To minimize drift off site two options could be used: (1) List conditions where an increased 

buffer width is required (Table 50), (2) If low drift technology ie nozzle design and/or additives 

that maximize deposition to the intended target and minimized drift into non-target and sensitive 

areas as directed in PDFs. This lowers the amount of herbicide that could potentially drift into 

water by less than half at the 50 foot release height (Table 49).

Table 49-Concentrations of herbicide with additional buffer widths 

Release Height with Additional 

Buffer Widths 

Size of Additional 

Buffer Widths 

Concentrations of 

Clopyralid (ppb) 

Concentrations 

of Picloram (ppb) 

25 feet 0 feet 1.5 0.9 

35 feet 60 feet 3.0 1.8 

50 feet 120 feet 7.3 4.5 

Either method would increase the effectiveness of the buffer for sensitive areas and streams. 

Drift cards would be used to track the effectiveness of the buffers. 

Table 50-Additions to buffer widths under specified conditions (PDF-8) 

25 foot release height 

at 7-8 mph 

35 foot release height 

at 7-8 mph 

50 feet release height at 

7-8 mph 

Buffer width Designated buffer Add 1 swath widths to 

buffer 

Add 2 swath widths to 

buffer 

Buffer width Designated buffer Add 2 swath widths to 

buffer 

Add 3 swath widths to 

buffer 

Use low drift technology ie nozzle design and/or additives that ensure little to no drift into stream buffers or sensitive 

areas as directed in PDFs. 

Water contamination from aerial herbicide drift is a large concern. The following Project Design 

Features are included to address this concern by minimizing risk for aerial herbicide drift and 

contamination to waterways: 

• E-2 requires that aircraft fueling occurs outside RHCAs. 

• F-5 requires that herbicide applications occur when winds are between 2 and 8 miles per 

hour. 

• F-6 requires coarse droplet size to minimize drift. 

• F-8f and Table 7, Table 8, and Table 9 - Buffers of 300 feet are required on perennial or wet 

intermittent streams and wetlands, and 100 feet buffers are required on dry channels. 

• F-8i requires that aerial units be ground checked and water features marked and buffered 

before application. 

• F-8n and Table 10 - Additional buffers or drift reduction methods are required in winds over 

5 mph with flight heights over 30 feet. (Also shown in Table 50 above). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Based on buffer effectiveness documented by Rashin and Graber (1993) and Dent and Robben 

(2000) concentrations of herbicides reaching streams are expected to be well below 

concentrations of concern to beneficial uses. Spray cards would be used to track the effectiveness 

of the stream buffers. 

Lakes, Wetlands and Floodplains 

There are approximately 13 acres of treatment proposed within 100 feet of lakes or reservoirs on 

the Forest. The invasive plants to be treated are diffuse knapweed, Canada thistle, medusa head, 

sulphur cinquefoil and hoarycress white top. Treatments are proposed near five waterbodies, 

generally at campgrounds near lakes or reservoirs. 

Most of these treatment acres are at Goose Lake which has approximately 6.1 acres of chemical 

treatment of a variety of species proposed around the 2.4 acre lake. As it is estimated that at most 

treatment sites the infestation is presently 25 percent infested, this is approximately 1.5 acres of 

actual treatment. PDF H-8 requires that no more than half the perimeter or 50 percent of the 

vegetative cover or 10 contiguous acres around a lake or pond would be treated with herbicides 

in any 30-day period. This is to reduce exposure to herbicides for organisms by providing some 

untreated areas as refugia. Buffers listed in Table 6 minimize the potential for herbicides to move 

into surface water. Given these PDFs, treatments are unlikely to affect functioning of wetlands 

around waterbodies or to contribute to significant adverse effect on beneficial uses. 

The most effective herbicides for the species listed above are clopyralid, picloram, metsulfuron 

methyl, chlorsulfuron and glyphosate (best in the fall). 

Within 100 feet of the lake, no broadcast applications would occur. Picloram and chlorsulfuron 

could only be spot sprayed to within 50 feet of the lake. Clopyralid (considered low aquatic risk) 

could be spot sprayed to within 15 feet of the high water mark of the lake. Aquatic glyphosate 

and aquatic imazapyr could be spot sprayed up to the edge of the water. These specific protection 

measures would make adverse effect to beneficial uses of the lake unlikely. To control the 

infestation the treatments would continue over several years, with fewer acres needing treatment 

each year. 

Early Detection Rapid Response 

Early Detection Rapid Response (EDRR) is part of all the action alternatives. Under this 

approach new or currently unknown infestations may be treated using the range of ground based 

methods analyzed in the Wallowa-Whitman Invasive Plant FEIS, on sites similar to those 

presently proposed for treatment. PDFs limit types of treatments and types of herbicides by 

aquatic risk within RHCAs and would minimize the risk of treating these new or undiscovered 

infestations. 

Aerial application of herbicides would not occur under EDRR. If treatment sites or types of 

treatment were not within the range of ground based methods discussed above, then additional 

analysis would occur under another NEPA document. Examples would be use of different 

herbicides than the ten discussed in this document or treatment of emergent vegetation. 

Cumulative Effects 

Only the land and roads within the National Forest System would be treated in the action 

alternatives proposed by this EIS. The Forest, however, is intermingled with other federal, state, 

county, and private ownerships. Management activities and actions on neighboring lands may 

290
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

contribute to spread or containment of invasive plants on National Forest System lands, and vice 

versa. 

Wallowa County has an active program to treat invasive plants and require private property 

owners to control invasive plants on their property. The largest acreage to be treated on private 

land is next to the common bugloss site (5,500acres). 

Herbicides are commonly applied on lands other than National Forest System lands for a variety 

of agricultural and landscaping purposes. Herbicide use occurs on tribal lands, state and county 

lands, private forestry lands, rangelands, utility corridors, road rights-of-way, and private 

property. The Oregon Legistature adopted a Pesticide Use Reporting Sysem which includes 

reporting non- home use herbicides in 1999. However, no funding was available for 

implementation until recently. Potentially data on 2007 use will be available sometime in 2008. 

Presently, accurate accounting of the total acreage of invasive plant treatment for all land 

ownerships is unavailable. The risk of adverse effects of invasive plant treatments have been 

minimized by the project design features (PDFs). These limit the possibility of cumulative 

effects of treatment by minimizing direct and indirect effects. 

Only two watersheds have more than 1 percent of the watershed with potential chemical 

treatment areas. They are the Middle Imnaha River and the Snake River/Temperance Creek 

Watershed. Most of the treatment in the Middle Imnaha River is the common bugloss site that 

would be treated the same year the private land would be treated. 

Table 51-Watersheds with largest percent of proposed treatments 

Watershed Proposed Treatment 

Name 

BIOCONTROL 

ACRES 

CHEMICAL 

ACRES 

MANUAL 

ACRES 

Total 

Acres 

% 

Watershed 

Treated 

% 

Watershed 

Chemically 

Treated % 

MIDDLE IMNAHA RIVER 0.0 5877 2.0 5879 6.7 6.7 

SNAKE 

RIVER/TEMPERANCE 

CREEK 

34.4 1905.0 1.3 2142 1.9 1.8 

SOUTH FORK BURNT 

RIVER 917.5 357.0 6.6 1281 1.7 0.5 

POWDER 

RIVER/RUCKLES CREEK 1.6 1320.7 4.7 1327 0.8 0.8 

NORTH FORK BURNT 

RIVER 161.5 1009.5 0.0 1171 0.9 0.8 

UPPER IMNAHA RIVER 0.0 686.0 0.0 686 0.8 0.8 

BEAR CREEK 72.8 325.6 1.6 400 0.9 0.7 

EAGLE CREEK 12.5 824.3 9.2 846 0.7 0.7 

BURNT RIVER/AUBURN 

CREEK 0.0 295.0 0.0 295 0.5 0.5 

If the whole acreage at the common bugloss site was treated in one year, over 12% of the 

watershed would be treated. However it is estimated by Forest personnel that less than 1500 

acres scattered across the larger treatment area would be treated at the bugloss site on Forest 

land. If the 1500 acres was doubled to take private land into account 3.4% of the watershed 

291 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

would be treated. Private landowners would use methylsulfuron methyl aerially as their first 

choice to treat acres infested with bugloss. 

The Forest would use methysulfuron methyl with ground based methods as the first choice of 

treatment. This is a highly effective herbicide with low application rates and a low toxicity to 

fish. 

Given the low application rates (typical rate of 0.03 lbs/acre), low toxicity value and scattered 

nature of the treatments, it is unlikely to have cumulative effects to the watershed 

For the Snake River/Temperance Creek Watershed the treatment acres include hand treatment 

along the Snake River as well as aerial treatment in the uplands. PDFs were developed to 

minimize risk of herbicide application to water at treatment sites. Given the PDFs as well as the 

scattered distribution of the treatments and the low rainfall available to transport herbicide off 

site, it is unlikely that treatments would have a cumulative effect for this watershed. 

Alternative C – No Broadcast within Riparian Habitat Conservation Areas 

Direct and Indirect Effects 

The effects from treatments under this alternative are the same as for Alternative B except for the 

3,104 acres within the RHCAs available for broadcast of herbicides. Potentially these areas 

would be treated with mechanical or manual methods, and spot spray or selective methods. As 

the main methods are mowing and cutting or pulling weeds, and the areas to be treated are 

between 100 and 300 feet from a stream, effects from treatment on streams would be 

unmeasurable. If these acres were treated with herbicide then spot or hand methods of 

application would be used under Alternative C. 

Spot spraying is more targeted to specific plants; therefore, there would be less chance of 

herbicide in contact with soil and available for runoff into streams. There would be less nontarget 

vegetation removed so more groundcover would be available in these areas lowering the 

potential for sediment delivery to streams. 

Cumulative Effects 

The cumulative effects are the same as those discussed under Alternative B 

Alternative D – No Aerial Application 

Direct and Indirect Effects 

The effects from treatment under this alternative are the same as for Alternative B except for 875 

acres proposed for aerial application. Some of these acres would need to be treated by other 

methods such as ground broadcast or spot treatment but 33 acres would not be treated at all 

because they are only accessible by air. Under this alternative there would be lower risk of 

herbicide contaminating water due to drift. 

Cumulative Effects 

The cumulative effects are the same as discussed under Alternative B. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

293 

3.5 Aquatic Organisms and Habitat 

3.5.1 Introduction 

Invasive plants are displacing native plants, and have the potential to destabilize streams, 

reducing the quality of fish and wildlife habitat and degrading natural areas in the WallowaWhitman National Forest. 

Invasive plants found growing adjacent to or within aquatic influence areas can invade, occupy, 

and dominate riparian areas and indirectly impact aquatic ecosystems and fish habitat. 

Invasive plants can change stand structure and alter future inputs of wood and leaves that 

provide the basic foundation of the aquatic ecosystem food webs. Native vegetation growth may 

change as a result of infestation, and the type and quality of litter fall, and quality of organic 

matter may decline, which can alter or degrade habitat for aquatic organisms. 

Under the Proposed Action, infested areas would be treated with an initial prescription and 

retreated in subsequent years until the site was restored with desirable vegetation. Herbicide 

treatments would be part of the initial prescription for most sites; however, use of herbicides 

would be expected to decline in subsequent entries as a result of effective treatment. Ongoing 

inventories would confirm the location of specific invasive plants and effectiveness of past 

treatments. Treatment prescriptions would be strict enough to ensure that adverse effects are 

minimized, while flexible enough to adapt to changing conditions over time. 

The DEIS has been prepared to consider the site-specific environmental consequences of treating 

invasive plants over the next 5 to 15 years (until invasive plant objectives are met or until 

changed conditions or new information warrants the need for a new decision). This EIS is tiered 

to a broader scale analysis--the Pacific Northwest Region Invasive Plant Program – Preventing 

and Managing Invasive Plants (USDA 2005a). 

The R6 2005 FEIS culminated in a Record of Decision (R6 2005 ROD) (USDA 2005b,), which 

added management direction relative to invasive plants to the Wallowa-Whitman National Forest 

Plan. The management direction applied to the broader Forest invasive plant program, 

establishing goals, objectives and standards for public education and coordination, prevention of 

the spread of invasive plants during land uses and activities, reducing reliance on herbicides over 

time, and treatment and restoration. 

Methodology for Analysis 

This analysis is tiered to the R6 2005 ROD and uses the GLEAMS model for evaluating the 

impacts of management decisions. The analysis methodology and modeling is described in 

section 3.4.1 of the Soil and Water section. 

3.5.2 Affected Environment 

Watershed Condition 

The project analysis includes the Wallowa-Whitman National Forest. Table 52 displays the 

relative distribution of the invasive plants proposed for treatment at the 5th field watershed scale. 

The Middle Imnaha River watershed has the greatest proportion of infested acres being proposed 

for treatment (about 6.7 percent). 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Table 52-Fifth-field watersheds proposed for treatment in the Wallowa-Whitman National Forest 

Fifth Field 

Watershed Name*** HUC Acres Treatment Acres 

Percent 

Watershed 

Proposed for 

Treatment 

Acres Proposed 

for Treatment in 

RHCAs* 

Th

Enda

Sen

P

BEAR CREEK 1706010504 46,300 400 0.86 115 SRBIG CREEK 1705020307 54,896 92 0.17 51 BIRCH CREEK 1707010306 182,205 6 0.00 0 MBURNT RIVER/AUBURN CREEK 1705020205 60,006 295 0.49 164 BURNT RIVER/BIG CREEK 1705020204 94,102 20 0.02 1 BURNT RIVER/CANYON 1705020206 54,081 63 0.12 4 CAMP CREEK 1705020203 51,954 275 0.53 65 CHESNIMNUS CREEK 1706010604 122,764 398 0.32 66 EAGLE CREEK 1705020310 123,643 846 0.68 164 GRANDE RONDE RIVER/BEAVER CREEK 1706010403 131,648 338 0.26 91 SRGRANDE RONDE RIVER/FIVE POINTS CREEK 

1706010404 87,632 49 0.06 6 S

GRANDE RONDE RIVER/INDIAN CREEK 1706010409 96,033 26 0.03 13 SGRANDE RONDE RIVER/MUD CREEK 1706010602 154,202 653 0.42 49 SGRANITE CREEK 1707020202 94,513 411 0.43 156 MCCLADD CREEK 1706010406 83,953 53 0.06 34 LITTLE MALHEUR RIVER 1705011612 86,434 3 0.00 0 LOSTINE RIVER 1706010502 58,035 142 0.24 28 SRLOWER BIG SHEEP CREEK 1706010204 129,726 182 0.14 125 SRLOWER CATHERINE 1706010407 83,128 419 0.50 42 SR294
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Fifth Field 

Watershed Name*** HUC Acres Treatment Acres 

Percent 

Watershed 

Proposed for 

Treatment 

Acres Proposed 

for Treatment in 

RHCAs* 

Th

Enda

Sen

P

CREEK LOWER IMNAHA RIVER 1706010205 147,024 436 0.30 156 SRLOWER JOSEPH CREEK 1706010606 104,789 450 0.43 75 LOWER POWDER RIVER 1705020311 61,488 16 0.03 0 LOWER WALLOWA RIVER 1706010506 110,421 198 0.18 85 SRMCKAY CREEK 1707010305 127,200 62 0.05 0 MEADOW CREEK 1706010402 116,100 459 0.40 225 SMIDDLE IMNAHA RIVER 1706010202 87,982 5879 6.68 1250 SRMIDDLE WALLOWA RIVER 1706010503 85,060 9 0.01 4 SMINAM RIVER 1706010505 152,909 115 0.08 60 SRNORTH FORK BURNT RIVER 1705020201 124,147 1171 0.94 229 NORTH POWDER RIVER 1705020305 74,553 144 0.19 38 PINE CREEK 1705020106 193,640 794 0.41 339 POWDER RIVER/BALDOCK SLOUGH 1705020303 72,489 50 0.07 22 POWDER RIVER/ROCK CREEK 1705020304 120,776 75 0.06 25 POWDER RIVER/RUCKLES CREEK 1705020308 166,729 1327 0.80 497 POWDER RIVER/SUTTON CREEK 1705020302 115,885 274 0.24 92 POWDER RIVER/WOLF CREEK 1705020306 109,371 58 0.05 11 SNAKE RIVER/CHERRY CREEK 1706010301 88,100 333 0.38 117 SRSNAKE RIVER/GRANITE CREEK 1706010101 127,509 100 0.08 25 SRC
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

296

Fifth Field 

Watershed Name*** HUC Acres Treatment Acres 

Percent 

Watershed 

Proposed for 

Treatment 

Acres Proposed 

for Treatment in 

RHCAs* 

Th

Enda

Sen

P

SNAKE RIVER/INDIAN CREEK 1705020107 117,760 50 0.04 7 SNAKE RIVER/TEMPERANCE CREEK 

1706010102 115,289 2142 1.86 740 SR

SNAKE RIVER/WOLF CREEK 1706010103 103723 365 0.35 116 SSOUTH FORK BURNT RIVER 1705020202 75,183 1281 1.70 75 SOUTH WILLOW CREEK 1705011901 65,950 49 0.07 4 UPPER BIG SHEEP CREEK 1706010203 89,358 341 0.38 174 SRUPPER CAMAS CREEK 1707020205 104,623 32 0.03 0 MCUPPER CATHERINE CREEK 1706010405 9,2520 19 0.02 4 SRUPPER GRANDE RONDE RIVER 1706010401 133,776 330 0.25 187 SRUPPER IMNAHA RIVER 1706010201 90,349 686 0.76 332 SRUPPER JOSEPH CREEK 1706010605 125,191 421 0.34 120 UPPER NORTH FORK JOHN DAY RIVER 1707020201 71,525 30 0.04 2 MCCUPPER POWDER RIVER 1705020301 105,509 461 0.44 154 UPPER WALLOWA RIVER 1706010501 157,943 7 0.00 6 SRWILLOW CREEK 1706010408 53,565 5 0.01 0 Grand Total 22,840 6345 *Riparian Habitat Conservation Areas (RHCA) are based on designated PACFISH buffers as delineated in GIS. Total for watershed differs by 3 acres froto rounding differences in GIS. RHCA number includes chemical treatment, biocontrol and mechanical or hand treatments. 

 **SRC=Snake River Chinook, MCC=Middle Columbia Chinook, SRS=Snake River Steelhead, MCS=Middle Columbia Steelhead, BT= Bull Trou WCT=Westslope Cutthroat Trout, MS=Margined Sculpin NF=No TES Fish Present ***Watersheds are displayed even if only a portion occurs o
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Roads Having High Potential for Herbicide Delivery 

Roads are the primary vector for invasive plants to enter the Forest. Native soil has been 

removed along roads, and fill and surfacing have been placed within the road prism. Ditches 

have been compacted, allowing them to deliver run-off to streams, which may include herbicides 

used in broadcast treatments along the roads. Road cutbanks can be a combination of disturbed 

soil and exposed bedrock. 

The R6 2005 FEIS describes roadside ditches as an herbicide delivery mechanism; potentially 

posing a high risk of herbicides reaching concentrations of concern for listed aquatic species. 

Ditches function as an extension of the stream network. Roadside ditches can act as delivery 

routes or intermittent streams during high rainfalls, or as settling ponds following high rainfall 

events. Because the Proposed Action includes treatment of road prisms with herbicides, the 

concern for herbicides being indirectly delivered to waterbodies containing aquatic species via 

roadside ditchlines was addressed by identifying roads that have a high potential for herbicide 

delivery. 

To reduce the potential for herbicides to come in contact with water via runoff at or near 

concentrations of concern, the following restrictions would apply to treatments along roads 

having high potential for herbicide delivery (see Appendix E): 

• No broadcasting of any herbicide 

• No use of picloram or non-aquatic triclopyr 

• Only spot or hand select methods of aquatic labeled herbicides or low risk herbides (as 

defined in this document) would be applied within 15 feet of wet roadside ditches 

• Apply appropriate buffer widths to road sections that cross streams (refer to buffer 

tables) 

For this project, roads considered most hydrologically connected were those located within 100 

feet of Class 1 and 2 streams (as defined by PACFISH). An estimated 56.57 miles of roads 

considered high risk for potential herbicide delivery are proposed for herbicide treatment (Listed 

in Appendix E). Nearly all watersheds on the Forest have roads that have a high risk of herbicide 

delivery; invasive plants are widely scattered along these roads. Roadside treatment areas 

include compacted ditch lines, disturbed soil and thin soils near exposed bedrock. Due to the 

extensive reworking of properties of soils along roads, the Soil Resource Inventory (SRI) may be 

misleading for roadside treatment areas. As roads and ditchlines are compacted, roadside soils 

are assumed to function with a high runoff rate. Therefore, those roads that have a high potential 

for herbicide delivery would not be treated by broadcast applications. See Appendix E for a list 

of roads with treatments proposed within 100 feet of a fish-bearing stream. 

Threatened, Endangered and Sensitive Fish Species and Habitat 

This section discusses Threatened, Endangered and Sensitive fish species and their habitat on the 

Wallowa-Whitman National Forest. 

The Wallowa-Whitman National Forest Federally Listed fish species as well as species listed on 

the Region 6 Sensitive Species list are found in Table 53 and Table 54. Steelhead, Chinook, and 

chum, are under the jurisdiction of NOAA Fisheries, and bull trout under US Fish and Wildlife 

Service. 

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Table 53-Threatened, Endangered and Proposed fish species, and critical habitat 

Species Status Listing Status Critical 

Habitat 

Snake River Basin DPS Threatened 

Listed on 

8/18/97; 

(62 FR 43937) 

Status 

Reaffirmed 

6/28/05; 

(70 FR 37160) 

09/02/05; 

70 FR 52630 

Steelhead 

(Oncorhynchus 

mykiss)

Middle Columbia River DPS Threatened 

Listed on 

3/25/99; 

(64 FR 14517) 

Status 

Reaffirmed 

6/28/05; 

(70 FR 37160) 

09/02/05; 

70 FR 52630 

Snake River Spring/Summer 

Run ESU Threatened 

Listed on 

4/22/92; 

(57 FR 14653) 

Status 

Reaffirmed 

6/28/05; 

(70 FR 37160) 

10/25/99; 

64 FR 57399 

Chinook 

Salmon 

(Oncorynchus 

tshawytscha) 

Snake River Fall Run ESU Threatened 

Listed on 

6/3/92; 

(57 FR 23458) 

Status 

Reaffirmed 

6/28/05; 

(70 FR 37160) 

12/28/93; 

58 FR 68543 

Bull Trout 

(Salvelinus 

confluentus)

Columbia River DPS Threatened 

Listed on 

6/10/98; 

(63 FR 31647) 

10/06/04; 

69 FR 59996 

Bliss Rapid Snail 

(Taylorconcha serpenticola) Threatened 

Listed on 

12/14/92; 

(57 FR 59244) 

None 

Table 54-Sensitive Species 

Species Designation 

Redband Trout (Oncorynchus mykiss gairdneri) Sensitive/MIS 

Westslope Cutthroat Trout (Oncorhynchus clarkii 

lewisi) Sensitive/MIS 

MIS = Management Indicator Species - The Wallowa-Whitman Forest Plan specifies the use of Management Indicator 

Species (MIS) to evaluate the effects of proposed management activities upon fish and wildlife habitat (USDA 1990). The 

basic concept of Management Indicator Species is the selection of certain species found in specific habitat types to 

represent the habitat needs of a larger group of species requiring similar habitats. 

For purposes of addressing federally listed fish species under the jurisdiction of NOAA Fisheries 

within the context of their status and life history, only brief summaries from various sources are 

presented in this document. Additional information related to brief life history information and 

status of populations at the ESU or DPS scale can be found in the following sources: 

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• Regional Invasive Plant EIS Fisheries Biological Assessment, Environmental Baseline, 

• NMFS Federal Register documents (http://www.nwr.noaa.gov/ESA-SalmonListings/Salmon-Populations/Index.cfm), 

Snake River (SR) spring/summer run Chinook salmon (Threatened) 

Listing History 

The Snake River spring/summer chinook salmon Evolutionarily Significant Unit (ESU) extends 

into the Wallowa-Whitman and Umatilla National Forests in Oregon. The Snake River 

spring/summer chinook salmon ESU, listed as threatened on April 22, 1992 (57 FR 14653), 

includes all natural-origin populations in the Tucannon, Grande Ronde, Imnaha, and Salmon 

Rivers. This ESU includes production areas that are characterized by spring-timed returns, 

summer-timed returns, and combinations from the two adult timing patterns. Runs classified as 

spring chinook are counted at Bonneville Dam beginning in early March and ending the first 

week of June; runs classified as summer chinook return to the Columbia River from June 

through August. Returning fish hold in deep mainstem and tributary pools until late summer, 

when they emigrate up into tributary areas and spawn. In general, spring type chinook tend to 

spawn in higher elevation reaches of major Snake River tributaries in mid- through late August, 

and summer run Snake River chinook spawn approximately one month later than spring-run fish. 

Recovery planning for Snake River spring/summer chinook is ongoing, and recovery planning 

status can be reviewed online at: http://research.nwfsc.noaa.gov/trt/trt_columbia.htm 

Critical Habitat 

Critical habitat was designated for Snake River spring/summer chinook salmon on December 28, 

1993 (58 FR 68543). Critical habitat is designated to include river and tributary reaches 

presently or historically accessible (except reaches above impassable natural falls, and Dworshak 

and Hells Canyon Dams) to Snake River spring/summer chinook salmon in the Snake River 

basin. Migratory habitat in the Columbia River mainstem from the mouth to the Snake River 

confluence is also included. Essential habitat consists of four components: spawning and 

juvenile rearing, juvenile migration, areas for growth and development to adulthood, and adult 

migration corridors. Essential features of migration corridors are further defined as: substrate, 

water quality, water quantity, water velocity, cover/shelter, food (juveniles only), riparian 

vegetation, space, and safe passage conditions. 

Life History 

The Snake River spring/summer chinook ESU includes current runs to the Tucannon River, the 

Grand Ronde River system, the Imnaha River and the Salmon River (Matthews and Waples 

1991). 

Spring and summer chinook from the Snake River basin exhibit stream type life history 

characteristics (Healey, 1983). Most SR spring/summer chinook salmon enter individual 

subbasins from May through September. Eggs are deposited in late summer and early fall, 

incubate over the following winter and hatch in late winter/early spring of the following year. 

Juvenile SR spring/summer chinook salmon emerge from spawning gravels from February 

through June (Peery and Bjornn 1991). Typically, after rearing in their nursery streams for about 

1 year, smolts begin migrating seaward in April and May (Bugert et al. 1990, Cannamela, 1992). 

Depending on the tributary and the specific habitat conditions, juveniles may migrate extensively 

from natal reaches into alternative summer rearing and/or overwintering areas. 

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After reaching the mouth of the Columbia River, spring/summer chinook salmon probably 

inhabit nearshore areas before beginning their northeast Pacific Ocean migration. Snake River 

spring/summer chinook return from the ocean to spawn primarily as 4 and 5 year old fish, after 2 

to 3 years in the ocean. A small fraction of the fish return as 3-year-old ‘jacks’, heavily 

predominated by males. 

Many of the Snake River tributaries used by spring and summer chinook runs exhibit two major 

features: extensive meanders through high elevation meadowlands and relatively steep lower 

sections joining the drainages to the mainstem Salmon (Matthews and Waples, 1991). The 

combination of relatively high summer temperatures and the upland meadow habitat creates the 

potential for high juvenile salmonid productivity. Historically, the Salmon River system may 

have supported more than 40 percent of the total return of spring and summer chinook to the 

Columbia system (e.g., Fulton 1968) 

Action Area Information 

Imnaha sub-basin, approximately 70 percent of which is within Wallowa-Whitman National 

Forest, has 5 major streams that contain more than five miles of anadromous fish habitat inside 

the National Forest land, including Imnaha River, Big Sheep Cr., Grouse Cr., Horse Cr., and 

Lightning Cr. Imnaha River holds roughly 45 miles of anadromous fish habitat inside National 

Forest System land. 

Lower Grande Ronde River sub-basin, approximately 25 percent of which is within WallowaWhitman National Forest has 12 major streams that contain anadromous fish habitat inside the 

W-W National Forest land, including Grande Ronde River, Butte Cr., Joseph Cr., Elk Cr., Swamp 

Cr., Davis Cr., Cottonwood Cr., Peavine Cr., Mud Cr., McAllister Cr., Tope Cr., and Wildcat Cr. 

Joseph Cr. holds roughly 26 miles of anadromous fish habitat inside Wallowa-Whitman National 

Forest land. 

Lower Snake/Asotin sub-basin (with only 70 percent as part of the ESU area, approximately 20 

percent of which is within Wallowa-Whitman National Forest) holds roughly 12 miles of 

anadromous fish habitat inside Wallowa-Whitman National Forest land. 

Hells Canyon, approximately 70 percent of which is within Wallowa-Whitman National Forest, 

has 1 major stream, Snake River, which contains more than five miles of anadromous fish habitat 

inside the National Forest land. Snake River holds roughly 53 miles of anadromous fish habitat 

inside National Forest System land. 

Upper Grande Ronde River sub-basin, approximately 30 percent of which is within WallowaWhitman National Forest has 13 major streams that contain anadromous fish habitat inside the 

National Forest land, including Grande Ronde River, Meadow Creek, Burnt Corral Creek, 

McCoy Creek, Fly Creek, NF Cathrine Creek, Indian Creek, Spring Creek, Five Points Creek, 

Sheep Creek, Clear Creek, Beaver Creek and Limber Jim Creek. Grande Ronde River holds 

roughly 22 miles of anadromous fish habitat inside Wallowa-Whitman National Forest System 

land. 

Wallowa River sub-basin, approximately 50 percent of which is within Wallowa-Whitman 

National Forest, has 4 major streams that contain more than five miles of anadromous fish 

habitat inside the National Forest land, including Minam River, Little Minam River, Lostine 

River, and Bear Cr. Minam River holds roughly 33 miles of anadromous fish habitat inside 

National Forest System land. 

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Snake River (SR) fall-run Chinook salmon (Threatened) 

Listing History 

The Snake River fall Chinook ESU extends into the Wallowa-Whitman and Umatilla National 

Forests. The Snake River fall chinook salmon ESU, listed as threatened on April 22, 1992, (57 

FR 14653), includes all natural populations of fall chinook salmon in the mainstem Snake River 

below Hells Canyon Dam, and the Tucannon, Palouse (to Palouse Falls), Grande Ronde, Imnaha, 

Salmon, and Clearwater Rivers. Fall chinook from the Lyons Ferry Hatchery are included in the 

ESU but are not listed. Recovery planning for Snake River fall chinook is ongoing, and recovery 

planning status can be reviewed online at: http://research.nwfsc.noaa.gov/trt/trt_columbia.htm 

Critical Habitat 

Critical habitat was designated for Snake River fall chinook salmon on December 28, 1993, (58 

FR 68543). Critical habitat for the listed ESU is designated to include river reaches presently or 

historically accessible (except reaches above impassable natural falls, and Dworshak and Hells 

Canyon Dams) to Snake River fall chinook salmon in the Columbia River from it’s mouth 

upstream to the confluence of the Columbia and Snake Rivers; all Snake River reaches from the 

confluence of the Columbia River, upstream to Hells Canyon Dam; 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; the North Fork 

Clearwater River from its confluence with the Clearwater River upstream to Dworshak Dam. 

Essential habitat consists of four components: spawning and juvenile rearing, juvenile migration, 

areas for growth and development to adulthood, and adult migration corridors. Essential features 

of migration corridors are further defined as: substrate, water quality, water quantity, water 

velocity, cover/shelter, food (juveniles only), riparian vegetation, space, and safe passage 

conditions. 

Life History 

Snake River fall chinook spawn above Lower Granite Dam in the mainstem Snake River, and in 

the lower reaches of major tributaries entering below Hells Canyon Dam. Adult fall chinook 

enter the Columbia River in July and August. The Snake River component of the fall chinook 

run migrates past the Lower Snake river mainstem dams in September and October. Spawning 

occurs from October through November. Juveniles emerge from the gravels in March and April 

of the following year. Downstream migration generally begins within several weeks of 

emergence (Becker, 1970, Allen and Meekin, 1973), and juveniles rear in backwaters and 

shallow water areas through mid-summer before smolting and migrating to the ocean—thus they 

exhibit an ocean-type juvenile history. Once in the ocean, they spend 1 to 4 years (though usually 

3 years) before beginning their spawning migration. Fall returns in the Snake River system are 

typically dominated by 4-year-old fish. 

Fall chinook returns to the Snake River generally declined through the first half of this century 

(Irving and Bjornn 1991). In spite of the declines, the Snake River basin remained the largest 

single natural production area for fall chinook in the Columbia drainage into the early 1960s 

(Fulton 1968). Spawning and rearing habitat for Snake River fall chinook was significantly 

reduced by the construction of a series of Snake River mainstem dams. Historically, the primary 

spawning fall chinook spawning areas were located on the upper mainstem Snake River. 

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Currently, natural spawning is limited to the area from the upper end of Lower Granite Reservoir 

to Hells Canyon dam and the lower reaches of the Imnaha, Grande Ronde, Clearwater and 

Tucannon Rivers. 

Action Area Information 

Imnaha sub-basin, approximately 70 percent of which is within Wallowa-Whitman National 

Forest, has 5 major streams that contain more than five miles of anadromous fish habitat inside 

the National Forest land, including Imnaha River, Big Sheep Cr., Grouse Cr., Horse Cr., and 

Lightning Cr. Imnaha River holds roughly 45 miles of anadromous fish habitat inside National 

Forest System land. 

Lower Grande Ronde River sub-basin, approximately 25 percent of which is within WallowaWhitman National Forest has 12 major streams that contain anadromous fish habitat inside the 

W-W National Forest land, including Grande Ronde River, Butte Cr., Joseph Cr., Elk Cr., Swamp 

Cr., Davis Cr., Cottonwood Cr., Peavine Cr., Mud Cr., McAllister Cr., Tope Cr., and Wildcat Cr. 

Joseph Cr. holds roughly 26 miles of anadromous fish habitat inside Wallowa-Whitman National 

Forest System land. 

Lower Snake/Asotin sub-basin (with only 70 percent as part of the ESU area, approximately 20 

percent of which is within Wallowa-Whitman National Forest) holds roughly 12 miles of 

anadromous fish habitat inside Wallowa-Whitman National Forest System land. 

Hells Canyon, approximately 70 percent of which is within Wallowa-Whitman National Forest, 

has 1 major stream, Snake River, which contains more than five miles of anadromous fish habitat 

inside the National Forest land. Snake River holds roughly 53 miles of anadromous fish habitat 

inside National Forest System land. 

Middle Columbia River (MCR) steelhead (Threatened) 

Listing History 

Wallowa-Whitman, Umatilla, Malheur, Ochoco, Mt. Hood, and Wenatchee National Forests are 

located within the Middle Columbia River Steelhead ESU in Oregon and Washington. The 

Middle Columbia River steelhead ESU was listed as threatened on March 25, 1999 (64 FR 

14517). The Middle Columbia River ESU encompasses Columbia River basin and tributaries 

upstream from and exclusive of the Wind River in Washington and the Hood River in Oregon, to 

and including the Yakima River in Washington. Recovery planning for Middle Columbia River 

steelhead is ongoing, and recovery planning status can be reviewed online at: 

http://research.nwfsc.noaa.gov/trt/trt_columbia.htm 

Critical Habitat 

Critical habitat was designated for Middle Columbia River steelhead on September 2, 2005 (70 

FR 52630). NMFS designates critical habitat based on physical and biological features that are 

essential to the listed species. Essential features of designated critical habitat are: (1) substrate, 

(2) water quality, (3) water quantity, (4)water temperature, (5) water velocity, (6) cover/shelter, 

(7) food for juveniles, (8) riparian vegetation, (9) space, and (10) safe passage conditions (50 

CFR 226.212). The three freshwater primary constituent elements of critical habitat are: 

Freshwater spawning sites with water quantity and quality conditions and substrate supporting 

spawning, incubation and larval development; 

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Freshwater rearing sites with water quantity and floodplain connectivity to form and maintain 

physical habitat conditions and support juvenile growth and mobility; water quality and 

forage supporting juvenile development; and natural cover such as shade, submerged and 

overhanging large wood, log jams and beaver dams, aquatic vegetation, large rocks and 

boulders, side channels, and undercut banks; 

Freshwater migration corridors free of obstruction with water quantity and quality conditions and 

natural cover such as submerged and overhanging large wood, aquatic vegetation, large 

rocks and boulders, side channels, and undercut banks supporting juvenile and adult mobility 

and survival. 

Recent designated critical habitat on the Wallowa-Whitman National Forest includes the stream 

channels in each designated reach, and a lateral extent as defined by the ordinary high water line 

(Sept. 2, 2005; 70 FR 52629). The primary constituent elements essential for conservation of 

listed ESUs are those sites and habitat components that support one or more fish life stages, 

including freshwater spawning sites, freshwater rearing sites, and freshwater migration corridors. 

The main 5th field watersheds on Wallowa-Whitman National Forest with designated critical 

habitat are the Granite Creek, McKay Creek, Upper Camas Creek, and Upper North Fork John 

Day River watersheds. 

Life History 

Major drainages in this ESU are the Deschutes, John Day, Umatilla, Walla-Walla, Yakima, and 

Klickitat river systems. Almost all steelhead populations within this ESU are summer-run fish, 

the exceptions being winter-run components returning to the Klickitat and Fifteen Mile Creek 

watersheds. A balance between 1- and 2-year-old smolt emigrants characterizes most of the 

populations within this ESU. Adults return after 1 or 2 years at sea. 

Most fish in this ESU smolt at two years and spend one to two years in salt water before reentering fresh water, where they may remain up to a year before spawning. Age-2-ocean 

steelhead dominate the summer steelhead run in the Klickitat River, whereas most other rivers 

with summer steelhead produce about equal numbers of both age-1- and 2-ocean fish. Juvenile 

life stages (i.e., eggs, alevins, fry, and parr) inhabit freshwater/riverine areas throughout the 

range of the ESU. Parr usually undergo a smolt transformation as 2-year-olds, at which time they 

migrate to the ocean. Subadults and adults forage in coastal and offshore waters of the North 

Pacific prior to returning to spawn in their natal streams. A non-anadromous form of O. mykiss 

(redband trout) co-occurs with the anadromous form in this ESU, and juvenile life stages of the 

two forms can be very difficult to differentiate. In addition, hatchery steelhead are also 

distributed within the range of this ESU. 

Recent estimates of the proportion of natural spawners of hatchery origin range from low 

(Yakima, Walla Walla, and John Day Rivers) to moderate (Umatilla and Deschutes Rivers). Most 

hatchery production in this ESU is derived primarily from within-basin stocks. 

Action Area Information 

North Fork John Day Sub-basin, approximately 10 percent of which is within Wallowa-Whitman 

National Forest, has 11 major streams that contain more than five miles of anadromous fish 

habitat inside the National Forest land, including NF John Day River, Wilson Cr., Skookum Cr., 

Mallory Cr., Camas Cr., Granite Cr., Clear Cr., Olive Cr., Lake Cr., Crane Cr., and Big Cr. NF 

John Day River holds roughly 10 miles of anadromous fish habitat inside Wallowa-Whitman 

Forest System land. 

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Snake River Basin (SRB) Steelhead (Threatened) 

Listing History 

Wallowa-Whitman and Umatilla National Forests are located within the Snake River Basin 

Steelhead ESU inside Oregon and Washington. The Snake River steelhead ESU, listed as 

threatened on August 18, 1997 (62 FR 43937), includes all natural-origin populations of 

steelhead in the Snake River basin of southeast Washington, northeast Oregon, and Idaho. None 

of the hatchery stocks in the Snake River basin are listed, but several are included in the ESU. 

Recovery planning for Snake River steelhead is ongoing, and recovery planning status can be 

reviewed online at: http://research.nwfsc.noaa.gov/trt/trt_columbia.htm 

Critical Habitat 

Critical habitat was designated for Snake River steelhead on September 2, 2005 (70 FR 52630). 

NMFS designates critical habitat based on physical and biological features that are essential to 

the listed species. Essential features of designated critical habitat are: (1) substrate, (2) water 

quality, (3) water quantity, (4)water temperature, (5) water velocity, (6) cover/shelter, (7) food 

for juveniles, (8) riparian vegetation, (9) space, and (10) safe passage conditions (50 CFR 

226.212). The three freshwater primary constituent elements of critical habitat are: 

Freshwater spawning sites with water quantity and quality conditions and substrate supporting 

spawning, incubation and larval development; 

Freshwater rearing sites with water quantity and floodplain connectivity to form and maintain 

physical habitat conditions and support juvenile growth and mobility; water quality and 

forage supporting juvenile development; and natural cover such as shade, submerged and 

overhanging large wood, log jams and beaver dams, aquatic vegetation, large rocks and 

boulders, side channels, and undercut banks; 

Freshwater migration corridors free of obstruction with water quantity and quality conditions and 

natural cover such as submerged and overhanging large wood, aquatic vegetation, large 

rocks and boulders, side channels, and undercut banks supporting juvenile and adult mobility 

and survival. 

Recent designated critical habitat on the Wallowa-Whitman National Forest includes the stream 

channels in each designated reach, and a lateral extent as defined by the ordinary high water line 

(Sept. 2, 2005; 70 FR 52629). The primary constituent elements essential for conservation of 

listed ESUs are those sites and habitat components that support one or more fish life stages, 

including freshwater spawning sites, freshwater rearing sites, and freshwater migration corridors. 

The 5th field watersheds on Wallowa-Whitman National Forest with designated critical habitat 

are the Bear Creek, Chesnimnus Creek, Grande Ronde River – Beaver Creek, Grande Ronde 

River – Five Points Creek, Grande Ronde River – Grossman Creek, Grande Ronde River – 

Indian Creek, Grande Ronde River – Mud Creek, Ladd Creek, Lostine Creek, Lower Big Sheep 

Creek, Lower Catherine Creek, Lower Imnaha River, Lower Joseph Creek, Lower Wallowa 

River, Meadow Creek, Middle Imnaha River, Minam River, Rapid River, Snake River – Cherry 

Creek, Snake River – Granite Creek, Snake River – Temperance Creek, Snake River – Wolf 

Creek, Upper Big Sheep Creek, Upper Catherine Creek, Upper Grande Ronde River, Upper 

Imnaha River, Upper Joseph Creek and Upper Wallowa River watersheds. 

Life History 

The Snake River historically supported more than 55 percent of total natural-origin production of 

steelhead in the Columbia River Basin. 

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It now has approximately 63 percent of the basin’s natural production potential (Mealy, 1997). 

The Snake River steelhead ESU is distributed throughout the Snake River drainage system, 

including tributaries in southwest Washington, eastern Oregon and north/central Idaho (NMFS, 

1997a). 

Snake River steelhead migrate a substantial distance from the ocean (up to 1,500 km) and use 

high elevation tributaries (typically 1,000-2,000 m above sea level) for spawning and juvenile 

rearing. Snake River steelhead occupy habitat that is considerably warmer and drier (on an 

annual basis) than other steelhead ESUs. Snake River basin steelhead are generally classified as 

summer run, based on their adult run timing patterns. Summer steelhead enter the Columbia 

River from late June to October. After holding over the winter, summer steelhead spawn during 

the following spring (March to May). Managers classify up-river summer steelhead runs into to 

groups based primarily on ocean age and adult size upon return to the Columbia River. A-run 

steelhead are predominately age-1 ocean fish while B-run steelhead are larger, predominated by 

age-2 ocean fish. 

With one exception (the Tucannon River production area), the tributary habitat used by Snake 

River steelhead ESU is above Lower Granite Dam. Major groupings of populations and/or 

subpopulations can be found in (1) the Grande Ronde River system; (2) the Imnaha River 

drainage; (3) the Clearwater River drainages; (4) the South Fork Salmon River; (5) the smaller 

mainstem tributaries before the confluence of the mainstem; (6) the Middle Fork salmon 

production areas, (7) the Lemhi and Pahsimeroi valley production areas and (8) upper Salmon 

River tributaries. 

The A-run populations are found in the tributaries to the lower Clearwater River, the upper 

Salmon River and its tributaries, the lower Salmon River and its tributaries, the Grand Ronde 

River, Imnaha River, and possibly the Snake River’s mainstem tributaries below Hells Canyon 

Dam. B-run steelhead occupy four major subbasins, including two on the Clearwater River 

(Lochsa and Selway) and two on the Salmon River (Middle Fork and South Fork); areas that are 

for the most part not occupied by A-run steelhead. Some natural B-run steelhead are also 

produced in parts of the mainstem Clearwater and its major tributaries. There are alternative 

escapement objectives of 10,000 (Columbia River Fisheries Management Plan) and 31,400 

(Idaho) for B-run steelhead. B-run steelhead, therefore, represent at least 1/3 and as much as 3/5 

of the production capacity of the ESU. 

B-run steelhead are distinguished from the A-run component by their unique life history 

characteristics. B-run steelhead were traditionally distinguished as larger fish with a later run 

timing. The recent review by the U.S. v. Oregon Technical Advisory Committee (TAC), a group 

that monitors adult salmon and steelhead escapement in the Snake River Basin, indicated that 

different populations of steelhead do have different size structures, with populations dominated 

by larger fish (i.e., greater than 77.5 cm) occurring in the traditionally defined B-run basins. 

Larger fish occur in other populations throughout the basin, but at much lower rates. Evidence 

suggests that fish returning to the Middle Fork Salmon River and Little Salmon River have a 

more equal distribution of large and small fish. B-run steelhead also are generally older. A-run 

steelhead are predominately 1-ocean fish, whereas most B-run steelhead generally spend 2 or 

more years in the ocean before spawning. The differences in ocean age are primarily responsible 

for the differences in the size of A- and B-run steelhead. However, B-run steelhead are also 

thought to be larger at any given age than A-run fish. 

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This may be due, at least in part, to the fact that B-run steelhead leave the ocean later in the year 

than A-run steelhead and thus have an extra month or more of ocean residence when growth 

rates are thought to be greatest. 

Action Area Information 

Imnaha sub-basin, approximately 70 percent of which is within Wallowa-Whitman National 

Forest, has 5 major streams that contain more than five miles of anadromous fish habitat inside 

the National Forest land, including Imnaha River, Big Sheep Cr., Grouse Cr., Horse Cr., and 

Lightning Cr. Imnaha River holds roughly 45 miles of anadromous fish habitat inside National 

Forest System lands. 

Lower Grande Ronde River sub-basin, approximately 25 percent of which is within WallowaWhitman National Forest has 12 major streams that contain anadromous fish habitat inside the 

National Forest land, including Grande Ronde River, Butte Cr., Joseph Cr., Elk Cr., Swamp Cr., 

Davis Cr., Cottonwood Cr., Peavine Cr., Mud Cr., McAllister Cr., Tope Cr., and Wildcat Cr. 

Joseph Cr. Holds roughly 26 miles of anadromous fish habitat inside Wallowa-Whitman National 

Forest System land. 

Lower Snake/Asotin sub-basin (with only 70 percent as part of the ESU area, approximately 30 

percent of which is within Umatilla National Forest) has 1 major stream that contains 

anadromous fish habitat inside the National Forest land. Snake River holds roughly 12 miles of 

anadromous fish habitat on Wallowa-Whitman National Forest System land. 

Hells Canyon sub-basin, approximately 70 percent of which is within Wallowa-Whitman 

National Forest, has 1 stream, Snake River, which contains more than five miles of anadromous 

fish habitat inside the National Forest System land; Snake River holds roughly 53 miles of 

anadromous fish habitat inside National Forest System land. 

Upper Grande Ronde River sub-basin, approximately 30 percent of which is within WallowaWhitman National Forest, has 13 major streams that contain more than five miles of anadromous 

fish habitat inside National Forest System land, including Grande Ronde River, Meadow Cr., 

Burnt Corral Cr., McCoy Cr., Fly Cr., NF Cathrine Cr., SF Cathrine Cr., Indian Cr., Five Points 

Cr., Sheep Cr., Clear Cr., Beaver Cr. and Limber Jim Cr. Grande Ronde River holds roughly 22 

miles of anadromous fish habitat inside Wallowa-Whitman National Forest System land. 

Wallowa River sub-basin, approximately 50 percent of which is within Wallowa-Whitman 

National Forest, has 4 major streams that contain more than five miles of anadromous fish 

habitat inside the National Forest System land, including Minam River, Little Minam River, 

Lostine River, and Bear Cr. Minam River holding roughly 33 miles of anadromous fish habitat 

inside National Forest System land. 

Columbia River Bull Trout 

This section is taken directly out of the R6 2005 FEIS Fish Biological Assessment (BA) (USDA 

Forest Service 2005c) so as not to recreate information. 

The FWS BOs for the FS LRMPs as amended by the NWFP and the FS LRMPs as amended by 

the PACFISH and INFISH provided a general description of the status of bull trout in the NWFP 

(USDI, 1998 and USDI, 2004). The draft Bull Trout Recovery Plan provides information on the 

distribution and abundance of bull trout in all Distinct Population Segments (DPS) in the 

conterminous United States, and offers the most recent status information for the species by 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

recovery unit (USDI, 2002). Of the 23 recovery units for bull trout, 16 extend into National 

Forest System lands. Chapters 2, 5 to 14, and 20 to 24 of the Draft Recovery Plans describe the 

current distribution and abundance of the recovery units considered in this BA. Reasons for 

decline for each recovery unit are identified within the draft Bull Trout Recovery Plan. 

Detailed accounts of life history, taxonomy and behavior can be found in the final rule listing the 

Columbia River and Klamath River populations of bull trout as threatened (USFWS, 1998b), and 

in the determination of threatened status for bull trout in the conterminous United States 

(USFWS, 1999a) for Coastal-Puget Sound, and the Status of Oregon’s bull trout; distribution, 

life history, limiting factors, management considerations, and status (Buchanan et al., 1997). 

The FWS has draft recovery plans for the Columbia River and Klamath River DPSs (USFWS 

2002a) and the Coastal-Puget Sound DPS (USFWS 2004a). Through these efforts, the FWS has 

converted bull trout subpopulations into “core areas.” Core areas represent a combination of 

habitat that provides all elements for the long-term security of bull trout and the presence of bull 

trout inhabiting core habitat. Thus, core areas form the basis on which to gauge recovery within a 

recovery unit. Thus, a core area, by definition, is considered habitat occupied by bull trout and 

serves as a biologically discrete unit upon which to base bull trout recovery. Within core areas, 

groups of bull trout or local populations which spawn in various tributaries are generally 

characterized by relatively small amounts of genetic diversity within a tributary, but high levels 

of genetic divergence between tributaries (Chapter 1, recovery plan). Individual local 

populations may come and go or expand and contract over time, but the focus of the draft 

recovery plan is maintaining all existing core areas. 

Critical Habitat 

Critical habitat was designated by the FWS for the Columbia River DPS bull trout on October 6, 

2004 (69 FR 59996) (USFWS 2004b). Lands not designated as critical habitat for Columbia 

River Basin bull trout include those that do not meet the requirement of needing special 

management or protection and are excluded due to the exercise of the Secretary of Interior’s 

Authority under section 4(b)(2) of the ESA. 

On September 21, 2004, the FWS designated 2,812 km (1,748 mi) of streams and 24,781 ha 

(61,235 ac) of lakes in Oregon, Idaho, and Washington as critical habitat for bull trout. Within 

the Columbia River Basin, 1,136 km (706 mi) of streams in Oregon and 1,186 km (737 mi) of 

streams in Washington were designated as critical habitat (USFWS 2004b). 

The FWS determined that PACFISH, INFISH, the Interior Columbia Basin Ecosystem 

Management Project (ICBMP) strategy, and the Northwest Forest Plan (NWFP) Aquatic 

Conservation Strategy (ACS) provide conservation, adequate protection and special management 

for the PCEs essential for bull trout. Protection is at least comparable to designating critical 

habitat. As a result, those lands are not being designated critical habitat as they do not meet the 

statutory definition. In many specific ways these plans are superior to a designation in that they 

require enhancement and restoration of habitat, acts not required by the designation. 

Life History and Habitat Description 

Biology 

Bull trout exhibit both resident and migratory life-history strategies (Rieman and McIntyre 

1993). Resident bull trout complete their entire life cycle in the tributary (or nearby) streams in 

which they spawn and rear. 

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Migratory bull trout spawn in tributary streams where juvenile fish rear one to four years before 

migrating to either a lake (adfluvial form), river (fluvial form) (Fraley and Shepard1989, Goetz 

1989), or in certain coastal areas, to saltwater (anadromous) (Cavender 1978; McPhail and 

Baxter 1996; WDFW et al., 1997). Resident and migratory life-history forms may be found 

together but it is unknown if they represent a single population or separate populations (Rieman 

and McIntyre 1993). Either form may give rise to offspring exhibiting either resident or 

migratory behavior (Rieman and McIntyre 1993). The multiple life-history strategies found in 

bull trout populations represent important diversity (both spatial and genetic) that help protect 

these populations from environmental stochasticity. 

The size and age of bull trout at maturity depends upon the life-history strategy and habitat 

limitations. Resident fish tend to be smaller than migratory fish at maturity and produce fewer 

eggs (Fraley and Shepard 1989; Goetz, 1989). Resident adults usually range from 150 to 300 

millimeters (6 to 12 inches) total length (TL). Migratory adults however, having lived for 

several years in larger rivers or lakes and feeding on other fish, grow to a much larger size and 

commonly reach 600 millimeters (24 inches) TL or more (Pratt 1985; Goetz 1989). 

The largest verified bull trout was a 14.6-kilogram (32-pound) adfluvial fish caught in Lake Pend 

Oreille, Idaho, in 1949 (Simpson and Wallace 1982). Size differs little between life-history 

forms during their first years of life in headwater streams, but diverges as migratory fish move 

into larger and more productive waters (Rieman and McIntyre 1993). 

Ratliff (1992) reported that bull trout under 100 mm (4 inches) in length were generally only 

found in the vicinity of spawning areas, and that fish over 100 mm were found downstream in 

larger channels and reservoirs in the Metolius River Basin. Juvenile migrants in the Umatilla 

River were primarily 100-200 mm long (4 to 8 inches) in the spring and 200-300 mm long (8 to 

12 inches) in October (Buchanan et al., 1997). The age at migration for juveniles is variable. 

Ratliff (1992) reported that most juveniles reached a size to migrate downstream at age 2, with 

some at ages 1 and 3 years. Pratt (1992) had similar findings for age-at-migration of juvenile bull 

trout from tributaries of the Flathead River. The seasonal timing of juvenile downstream 

migration appears similarly variable. 

Bull trout normally reach sexual maturity in 4 to 7 years and may live longer than 12 years. The 

species is iteroparous (i.e., can spawn multiple times in their lifetime) and adults may spawn 

each year or in alternate years (Batt 1996). Repeat-spawning frequency and post-spawning 

mortality are not well documented (Leathe and Graham 1982; Fraley and Shepard 1989; Pratt 

1992; Rieman and McIntyre 1996) but post-spawn survival rates are believed to be high. 

Bull trout typically spawn from late August to November during periods of decreasing water 

temperatures (below 9 degrees Celsius/48 degrees Fahrenheit). Redds are often constructed in 

stream reaches fed by springs or near other sources of cold groundwater (Goetz 1989; Pratt 

1992; Rieman and McIntyre 1996). Migratory bull trout frequently begin spawning migrations 

as early as April and have been known to move upstream as far as 250 kilometers (km) (155 

miles) to spawning grounds in Montana (Fraley and Shepard 1989; Swanberg 1997). In Idaho, 

bull trout moved 109 km (67.5 miles) from Arrowrock Reservoir to spawning areas in the 

headwaters of the Boise River (Flatter 1998). In the Blackfoot River, Montana, bull trout began 

spring spawning migrations in response to increasing temperatures (Swanberg, 1997). 

Depending on water temperature, egg incubation is normally 100 to 145 days (Pratt 1992), and 

after hatching, juveniles remain in the substrate. Time from egg deposition to emergence of fry 

may surpass 220 days. Fry normally emerge from early April through May, depending on water 

temperatures and increasing stream flows (Pratt 1992; Ratliff and Howell 1992). 

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Bull trout are opportunistic feeders, with food habits primarily a function of size and life-history 

strategy. 

Resident and juvenile migratory bull trout prey on terrestrial and aquatic insects, macrozooplankton, and small fish (Boag 1987; Goetz 1989; Donald and Alger 1993). Adult migratory 

bull trout feed on various fish species (Leathe and Graham 1982; Fraley and Shepard 1989; 

Brown 1992; Donald and Alger 1993). In coastal areas of western Washington, bull trout feed 

on Pacific herring (Clupea pallasi), Pacific sand lance (Ammodytes hexapterus), and surf smelt 

(Hypomesus pretiosus) in the ocean (WDFW et al., 1997). 

Habitat Affinities 

Bull trout have more specific habitat requirements than most other salmonids (Rieman and 

McIntyre 1993). Habitat components that influence the species’ distribution and abundance 

include water temperature, cover, channel form and stability, valley form, spawning and rearing 

substrate, and availability of migratory corridors (Fraley and Shepard, 1989; Goetz 1989; 

Hoelscher and Bjornn 1989; Sedell and Everest 1991; Howell and Buchanan 1992; Pratt 1992; 

Rieman and McIntyre 1993, 1995; Rich 1996; Watson and Hillman 1997). 

Watson and Hillman (1997) concluded that watersheds must have specific physical 

characteristics to provide the habitat requirements necessary for bull trout to successfully spawn 

and rear and that these specific characteristics are not necessarily present throughout these 

watersheds. Because bull trout exhibit a patchy distribution, even in pristine habitats (Rieman 

and McIntyre 1993), individuals of this species should not be expected to simultaneously occupy 

all available habitats (Rieman et al., 1997). 

Bull trout are found primarily in cold streams, although individual fish are found in larger, 

warmer river systems throughout the Columbia River Basin (Fraley and Shepard 1989; Rieman 

and McIntyre 1993, 1995; Buchanan et al. 1997; Rieman et al., 1997). Water temperature above 

15 degrees Celsius (59 degrees Fahrenheit) is believed to limit bull trout distribution, a limitation 

that may partially explain the patchy distribution within a watershed (Fraley and Shepard 1989; 

Rieman and McIntyre 1995). 

Spawning areas are often associated with cold-water springs, groundwater infiltration, and the 

streams with the coldest summer water temperatures in a given watershed (Pratt 1992; Rieman 

and McIntyre 1993; Rieman et al., 1997; Baxter et al., 1999). Water temperatures during 

spawning generally range from 5 to 9 degrees Celsius (41 to 48 degrees Fahrenheit) (Goetz 

1989). The requirement for cold water during egg incubation has generally limited the spawning 

distribution of bull trout to high elevations in areas where the summer climate is warm. Rieman 

and McIntyre (1995) found in the Boise River Basin that no juvenile bull trout were present in 

streams below 1613 m (5000 feet). Similarly, in the Sprague River Basin of south-central 

Oregon, Ziller (1992) found in four streams with bull trout that “numbers of bull trout increased 

and numbers of other trout species decreased as elevation increased. In those streams, bull trout 

were only found at elevations above 1774 m [5500 feet].” 

All life-history stages of bull trout are associated with complex forms of cover, including large 

woody debris, undercut banks, boulders, and pools (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). Jakober (1995) observed bull trout 

overwintering in deep beaver ponds or pools containing large woody debris in the Bitterroot 

River drainage, Montana, and suggested that, because of the need to avoid anchor ice in order to 

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survive, suitable winter habitat may be more restricted than summer habitat. Maintaining bull 

trout habitat requires stability of stream channels and of flow (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. For example, altered stream flow in the fall may disrupt bull trout 

during the spawning period, and channel instability may decrease survival of eggs and young 

juveniles in the gravel from winter through spring (Fraley and Shepard 1989; Pratt 1992; Pratt 

and Huston 1993). 

Preferred bull trout spawning habitat consists of low-gradient stream reaches with loose, clean 

gravel (Fraley and Shepard 1989). In the Swan River, Montana, abundance of bull trout redds 

was positively correlated with the extent of bounded alluvial valley reaches, which are likely 

areas of groundwater to surface water exchange (Baxter et al., 1999). Survival of bull trout 

embryos planted in stream areas of groundwater upwelling used by bull trout for spawning were 

significantly higher than embryos planted in areas of surface-water recharge not used by bull 

trout for spawning (Baxter and McPhail 1999). Pratt (1992) indicated that increases in fine 

sediment reduce egg survival and emergence. 

Migratory corridors link seasonal habitats for all bull trout life-history forms. For example, in 

Montana, migratory bull trout make extensive migrations in the Flathead River system (Fraley 

and Shepard 1989), and resident bull trout in tributaries of the Bitterroot River move 

downstream to overwinter in tributary pools (Jakober 1995). The ability to migrate is important 

to the persistence of bull trout (Rieman and McIntyre 1993; M. Gilpin, in litt., 1997; Rieman et 

al., 1997). Migrations facilitate gene flow among local populations when individuals from 

different local populations interbreed, or stray, to non-natal streams. Local bull trout populations 

that are extirpated by catastrophic events may also become re-established by migrants. 

Action Area Information 

Bull trout are found in the following fifth field and sixth field watersheds on the WallowaWhitman National Forest: 

• Bear Creek (Upper Bear Creek and Lower Bear Creek), 

• Grande Ronde River – Beaver Creek (Grande Ronde River Coleman Ridge and Lower 

Beaver Creek), 

• Grande Ronde River – Five Points Creek (Grande Ronde River – Wright Slough and Grande 

Ronde River – Haywire Canyon), 

• Grande Ronde River – Grossman Creek (Grande Ronde River – Slickman Creek, Grande 

Ronde River – Bear Creek and Grande Ronde River – Clear Creek), 

• Grande Ronde River – Indian Creek (Grande Ronde River – Arnolds Loup Res, Lower 

Indian Creek and Upper Indian Creek), 

• Grande Ronde River – Mud Creek (Grande Ronde River – Mile 50), 

• Granite Creek (Lower Granite Creek, Upper Granite Creek and Clear Creek), 

• Lostine River (Lostine R – Silver Creek and Lostine R – Lake Creek), 

• Lower Big Sheep Creek (Big Sheep Creek – Lower Little Sheep Creek, Middle Little Sheep 

Creek and Upper Little Sheep Creek), 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

• Lower Catherine Creek (Catherine Creek – Hamilton Rd, Catherine Creek – Conley L and 

Catherine Creek – McAllister Slough), 

• Lower Imnaha River (Imnaha R – Thorn Creek, Imnaha R – Fence Creek and Imnaha R – 

Bear Creek), 

• Lower Wallowa River (Wallowa R – Fisher Creek, Wallowa R – Water Canyon and Dear 

Creek), 

• Middle Imnaha River (Imnaha R – Deer Creek, Imnaha R – Chalk Creek and Imnaha R – 

Summit Creek), 

• Minam River (Lower Minam R, Minam R – Trout Creek, Minam R – Chaparral Creek, Little 

Minam, North Minam, Minam R – China Gap Creek and Upper Minam), 

• North Powder River (Upper Anothony R and Upper North Powder R), 

• Pine Creek (Lake Fork Creek, Clear Creek, Upper Pine Creek and East Pine Creek), 

• Powder River – Rock Creek (Muddy Creek, Lower Salmon Creek and Upper Salmon 

Creek), 

• Rapid River (Lower Rapid R, West Fork Rapid R, Rapid R – Copper Creek and Upper Rapid 

River), 

• Snake River(SR) – Cherry Creek (SR – Corral Creek, SR – Cache Creek and SR – Jim 

Creek) 

• Snake River – Granite Creek (Sheep Creek, SR – Sluice Bar, Granite Creek and SR – Butte 

Creek), 

• Snake River – Indian Creek (SR – Hells Canyon Dam, SR – McGraw Creek, Indian Creek, 

SR – Homestead Creek and SR – Oxbow Dam), 

• Snake River – Temperance Creek (Getta Creek, SR – Sommers Creek, SR – Big Canyon 

Dam, SR – Kurry Creek, SR – Corral Creek, SR – Salt Creek and SR – Sand Creek), 

• Snake River – Wolf Creek (SR – Dug Bar, SR – Dry Creek and SR – Eureka Bar), 

• Upper Big Sheep Creek (Big Sheep Creek – Steer Creek, Big Sheep Creek –Marr Creek, Big 

Sheep Creek –Carroll Creek, Big Sheep Creek –Tyee Creek, Upper Big Sheep Creek and 

Lick Creek), 

• Upper Catherine Creek (Catherine Creek – Brinker Creek, NF Catherine Creek, SF 

Catherine Creek and Catherine Creek – Milk Creek), 

• Upper Grande Ronde River (Grande Ronde River – Warm Springs Creek, Lower Fly Creek, 

Limber Jim Creek, Little Fly Creek, Grande Ronde River –Meadowbrook Creek, Chicken 

Creek and Grande Ronde River –Tanner Gulch), 

• Upper Imnaha River (Imnaha R – Crazyman Creek, Imnaha River – Dry Creek, NF Imnaha 

River, SF Imnaha River and Imnaha River – Rock Creek), 

• Upper North Fork John Day River (Trail Creek, NFJDR – Baldy Creek, NFJDR – Crane 

Creek and NFJD River – Onion Creek), 

• Upper Powder River (Cracker Creek and Deer Creek), 

• Upper Wallowa River (Wallowa River – Wallawa Lake and Hurricane Creek). 

Snake River Sockeye Salmon (Endangered) 

Listing History 

The Wallowa-Whitman National Forest is not contained within the Snake River sockeye ESU, 

which is located in Southwest Idaho. However, the Snake River sockeye salmon does use 

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Columbia River and Snake River within Oregon and Washington as a migration corridor to get to 

and leave from their ESU area in Idaho. The only extant population of the anadromous form of 

Snake River sockeye is the Redfish Lake population. 

The Snake River sockeye salmon ESU was listed as endangered on November 20, 1991, (56 FR 

58619) and includes populations of sockeye salmon from the Snake River basin, Idaho (extant 

populations occur in the Salmon River subbasin). Under NOAA Fisheries’ interim policy on 

artificial propagation (58 FR 17573), the progeny of fish from a listed population that are 

propagated artificially are considered part of the listed species and are protected under ESA. 

Thus, although not specifically designated in the 1991 listing, Snake River sockeye salmon 

produced in the captive broodstock program are included in the listed ESU. 

Critical Habitat 

Designated critical habitat (58 FR 68543, December 28, 1993) extends from the mouth of the 

Columbia River upstream to the Snake River confluence, up the Snake River to the Salmon 

River confluence, and up the Salmon River mainstem and tributaries to the five lakes still 

accessible (Stanley, Redfish, Yellow Belly, Pettit, and Alturas), and includes the lakes and their 

inlet creeks. Essential habitat consists of four components: spawning and juvenile rearing, 

juvenile migration, areas for growth and development to adulthood, and adult migration 

corridors. Essential features of migration corridors are further defined as: substrate, water 

quality, water quantity, water velocity, cover/shelter, food (juveniles only), riparian vegetation, 

space, and safe passage conditions. Adult Snake River sockeye salmon enter the Columbia River 

in late spring and early summer and reach the spawning lakes in late summer and early fall. 

Smolts begin emigration in April, and are present in the Columbia River estuary through the 

early summer months. 

The critical habitat designation identifies those physical and biological features of the habitat 

that are essential to the conservation of the species and that may require special management 

consideration or protections. Essential feature of the juvenile mitigation corridors include 

adequate: 1) substrate; 2) water quality; 3) water quantity; 4) water temperature; 5) water 

velocity; 6) cover/shelter 7) food; 8) riparian vegetation; 9) space; and safe passage conditions. 

The adult migration corridors are the same areas included in the juvenile migration corridors. 

Essential features would include those in juvenile migration corridors, excluding adequate food. 

Riparian Zones (Aquaitc Influence Zones) 

In the Columbia River Basin, critical habitat includes the water, waterway bottom, and the 

adjacent riparian zone. Biophysical characteristics and processes that create riparian zones vary 

considerably throughout the range of listed Snake River salmon. Critical habitat designation (58 

FR 68545, December 28, 1993) references the interagency Forests Ecosystem Management 

Assessment Team (FEMAT) report (1993) stating riparian zones consist of “areas where the 

vegetation complex and microclimate conditions are products of the combined presence and 

influence of perennial as well as intermittent water associated high water table, and soils that 

exhibit some wetness characteristics”. 

Life History 

Sockeye salmon occur in two forms: the anadromous sockeye and the nonanadromous kokanee. 

Kokanee originated as residual sockeye that did not emigrate to the ocean or undergo 

smoltification (Meehan and Bjornn 1991). Kokanee spend their entire lives in the lake 

environment, although some can produce anadromous offspring. In the case of Snake River 

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sockeye, adults typically enter fresh water during June and July. Arrival at Redfish Lake, which 

now supports the only remaining run of Snake River sockeye salmon, peaks in August, and 

spawning occurs primarily in October (Bjornn et al. 1968). Eggs hatch in the spring between 80 

and 140 days after spawning. Fry remain in the gravel for 3 to 5 weeks, emerge from April 

through May, and move immediately into the lake. Once there, juveniles feed on plankton for 1 

to 3 years before they migrate to the ocean (Bell 1986). Migrants leave Redfish Lake during late 

April through May (Bjornn et al. 1968) and travel almost 900 miles to the Pacific Ocean. Smolts 

reaching the ocean remain inshore or within the influence of the Columbia River plume during 

the early summer months. Later, they migrate through the northeast Pacific Ocean (Hart 1973, 

Hartt and Dell 1986). Snake River sockeye salmon spend 2 to 3 years in the Pacific Ocean and 

return in their fourth or fifth year of life. 

Population Trends 

In the 2003 status review update, NOAA Fisheries modified previous approaches to ESU risk 

assessment to incorporate VSP criteria (McElhany et al., 2000): abundance, growth 

rate/productivity, spatial structure, and diversity. The current condition (NOAA Fisheries, 2003) 

of SR sockeye is summarized below: 

Abundance: 

• Sixteen naturally produced adults in the last decade 

• Captive broodstock program initiated in 1991 has provided temporary rescue from 

extinction 

 

Productivity: 

• Return of 257 hatchery adults in 2000, while hatchery returns in 2000 and 2001 

averaged about 25 

• Natural population trends are not encouraging 

Spatial Structure: 

• Historically occurred in 4 lakes within the Stanley Basin, and up to 3 additional lakes 

across Snake River drainage 

• Redfish Lake is the only extant population 

Diversity: 

• Residual-type sockeye in Redfish Lake 

• Possible remnant gene pools in Stanley and Petit Lakes 

Escapement of sockeye salmon to the Snake River has declined dramatically in the last several 

decades, primarily because the construction of hydropower dams made it difficult for sockeye 

salmon to have access to traditional spawning areas (Gustafson et al.1997). Adult counts at Ice 

Harbor Dam declined from 3,170 in 1965 to zero in 1990 (ODFW and WDFW 1999). The Idaho 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Department of Fish and Game (IDFG) counted adults at a weir in Redfish Lake Creek from 1954 

through 1966; adult counts dropped from 4,361 in 1955 to fewer than 500 after 1957 (Bjornn et 

al. 1968). A total of 16 wild sockeye salmon returned to Redfish Lake between 1991 and 1999. 

During 1999, seven hatchery-produced, age-3 adults returned to the Sawtooth Hatchery. Three of 

these adults were released to spawn naturally, and four were taken into the IDFG captive 

broodstock program. In 2000, 257 hatchery-produced, age-4 sockeye salmon returned to the 

Stanley basin (weirs at the Sawtooth Hatchery and Redfish Lake Creek). Adults numbering 243 

were handled and redistributed to Redfish (120), Alturas (52), and Pettit (28) lakes, with the 

remaining 43 adults incorporated into the IDFG captive broodstock program. In 2001, 36 adult 

sockeye were counted at Lower Granite Dam (FPC, 2002). 

Low numbers of adult Snake River sockeye salmon preclude a quantitative analysis of the status 

of this ESU. However, NOAA Fisheries considers the status of this ESU to be dire under any 

criteria because only16 wild and 264 hatchery-produced adult sockeye returned to the Stanley 

basin between 1990 and 2000, and although 257 hatchery adults returned in 2000, only 26 

hatchery adults returned in 2001 and 22 in 2002. 

Sockeye survival from smolt to adult has declined by an estimated 74-81 percent since the early 

1960s, correlated with hydropower development. NOAA Fisheries has not estimated the risk of 

absolute extinction for the Snake River sockeye salmon (though the estimates were made for the 

other listed species, see below) because this ESU is currently at extremely low abundances and 

maintained through a captive broodstock program (McClure et al. 2000). 

Threats 

Snake River sockeye salmon have declined dramatically as a result of fishery management 

policy, overharvest, hydropower-caused mortality, and irrigation water withdrawals. 

Distribution within the Project Area 

The only extant population of anadromous Snake River sockeye salmon is the Redfish Lake 

population. Migratory habitat in the Snake River is within the project area: lthough the project 

area for this BA is outside the Snake River Sockeye ESU. Sockeye salmon pass Bonneville Dam 

from June 1 to July 31, and Lower Granite Dam from June 25 to August 30, on their almost 900-

mile migration to spawning grounds of the upper Salmon River. 

Bliss Rapids Snail 

A Bliss Rapids snail population occurs about 7 miles downstream from Hells Canyon Dam 

(USDA Forest Service 2005c), which is within the Wallowa-Whitman National Forest. 

Detailed accounts of the taxonomy, life history and behavior of the Bliss Rapids snail can be 

found in the final rule designating the species as threatened (U.S. Fish and Wildlife Service, 

1992) and in the final recovery plan (U.S. Fish and Wildlife Service 1995). 

Life History and Habitat Description 

The Bliss Rapids snail (Taylorconcha serpenticola) is a “living fossil; a relict from ancient 

lakes.” The Bliss Rapids snail is a survivor of the Pliocene (Blancan) Lake Idaho, which covered 

much of southern Idaho (Taylor 1988). The species is considered an annual species with an 

average longevity of one year. Bliss Rapids snail experience a die-off of older adults during the 

late winter-early spring season following reproduction. 

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The Bliss Rapids snail was first collected live and recognized as a new taxon in 1959 (Taylor 

1982), but has not yet been described in the literature. This snail is 2.0-2.5 mm (0.8-.10 in) long, 

with three whorls, and is roughly ovoid in shape. There are two color variants or morphs in the 

Bliss Rapids snail, the colorless or “pale” form and the orange-red or “orange” form. The pale 

morph is slightly smaller with rounded whorls and more melanin pigment on the body (Frest and 

Johannes 1992). This snail occurs on stable, cobble-boulder substratum only in flowing waters in 

the free-flowing reaches of mainstem Snake River and also in a few spring alcove habitats in the 

Hagerman Valley. The species does not burrow in sediments and normally avoids surfaces with 

attached plants. Known river populations (or colonies) of the Bliss Rapids snail occurs only in 

areas associated with spring influences or rapids edge environments and tend to flank shorelines. 

They are found at varying depths if dissolved oxygen and temperature requirements persist and 

are found in shallow (<1.0 cm (0.4 in) permanent cold springs (Frest and Johannes, 1992). The 

species is considered moderately photophobic and resides on the lateral sides and undersides of 

rocks during daylight (Bowler 1990). The snail will migrate to graze on aufwuchs (or perilithon) 

on the uppermost surfaces of rocks nocturnally. The species can be locally quite abundant, and it 

is especially abundant on smooth rock surfaces with common encrusting red algae. 

Reproduction in the Bliss Rapids snail varies according to habitat; occurring October-February 

in mainstem Snake River colonies and February-May in large-spring colonies. Egg laying occurs 

within two months of reproduction and eggs appear to hatch within one month. Adult snails 

exhibit a strong seasonal die-off after reproduction. Turnover appears more pronounced in 

mainstem river colonies, possibly due to environmental stress (Frest and Johannes 1992). 

Ecologically, this species requires cold, clean, well-oxygenated flowing water of low turbidity. 

The species prefer gravel to boulder size substratum. It has an affinity to habitat usually 

associated with spring or spring-like river habitats. For example, the Bliss Rapids snail can be 

found in small, shallow springs or large, deep spring outflows. In the mainstem river, they are 

found in areas of the river not subject to daily or seasonal fluctuations. It does not tolerate 

whitewater areas with rapid flow. 

Action Area Information 

The Bliss Rapids snail occurs in the Snake River where it flows through the Wallowa-Whitman 

National Forest. Collections made in September 2004 by Dr. Hershler of the Smithsonian, an 

expert in spring snail identification, have tentatively identified Bliss Rapids snail occurrence in 

the mainstem of the Snake River from Hells Canyon Dam downstream to the confluence of the 

Snake and Salmon Rivers (USDA Forest Service 2005c.).The Wallowa-Whitman National Forest 

includes Hells Canyon Dam and the Snake River downstream for 35 miles. Dr. Hershler found 

about 30 colonies in the mainstem of the Snake River, but none in the tributaries within Hells 

Canyon, including the Imnaha River (USDA Forest Service 2005c). Status and threats are as 

described above for the species. 

Redband Trout (Sensitive) 

Inland redband trout are the same species as steelhead (O. mykiss) and juveniles cannot be 

distinguished phenotypicaly. Isolated populations of O. mykiss above longstanding natural 

passage barriers (and barring hatchery introductions) may be reasonably assumed to be resident 

redbands. 

Redband trout are sensitive to changes in water quality and habitat. Redband trout of interior 

Oregon basins are believed to be best adapted to cold ( less than 21° C), clean water, but a few 

Great Basin populations possess a hereditary basis to function at high temperatures (Behnke 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

1992). Adult redband trout are generally associated with pool habitats, although various life 

stages require a wide array of habitats for rearing, hiding, feeding, and resting. Pool habitat is 

important refugia during low water periods. 

Spawning success decreases as fine sediment increases. The quantity and quality of pool and 

interstitial habitat also decrease as fine sediment increases. Other important habitat features 

include healthy riparian vegetation, undercut banks, and LWD (large woody debris). 

Spawning occurs during the spring, generally from March to June. Redds tend to be located 

where velocity, depth and bottom configuration induce water flow through the stream substrate, 

generally in gravels at the tailouts of pools. Water temperatures influence emergence of fry, 

which is typically from June through July. 

Action Area Information 

Redband trout are widely distributed across Oregon east of the Cascade Mountains. According to 

the Wallowa-Whitman Forest GIS data, redband trout are found within the analysis area in the 

Granite Creek, Upper Camas Creek and North Fork John Day River watersheds, but are assumed 

to be much more widely distributed 

Westslope Cutthroat Trout (Sensitive) 

Westslope cutthroat trout inhabit small mountain streams, main rivers, and large natural lakes. 

They require cool, clean, well-oxygenated water and prefer large pools and slow velocity areas. 

Juveniles of migratory populations may spend 1-4 years in their natal streams, and then move 

(usually in spring or early summer, and/or in fall in some systems) to a main river or lake where 

they remain until they spawn (Spahr et al. 1991, Rieman and McIntyre 1995). Many fry disperse 

downstream after emergence (Rieman and McIntyre 1995). Juveniles tend to overwinter in 

interstitial spaces in the substrate. Larger individuals congregate in pools in winter. 

Westslope cutthroat trout spawn in small tributary streams on clean gravel substrate where mean 

water depth is 17-20 cm and mean water velocity is 0.3-0.4 m/sec. They tend to spawn in natal 

stream (see McIntyre and Rieman 1995). Adfluvial populations live in large lakes in the upper 

Columbia drainage and spawn in lake tributaries. Fluvial populations live and grow in rivers and 

spawn in tributaries. Resident populations complete the entire life history in tributaries. All three 

life-history forms may occur in a single basin (McIntyre and Rieman 1995). Migrants may 

spawn in the lower reaches of the same streams used by resident fishes. Maturing adfluvial fishes 

move into the vicinity of tributaries in fall and winter and remain there until they begin to 

migrate upstream in spring. Of migratory spawners, some remain in tributaries during summer 

months but most return to the main river or lake soon after spawning (Behnke 1992). 

Westslope cutthroat trout are native to the upper Missouri River drainage in Montana, extreme 

northwestern Wyoming, and southern Alberta; the Salmon, Clearwater, and Spokane (including 

the Coeur d'Alene and St. Joe drainages) river drainages in Idaho; and the Clark Fork and 

Kootenai river drainages in Idaho, Montana, and British Columbia (Spahr et al. 1991); also 

westward to the Cascade Mountains as disjunct populations, for example, in the Lake Chelan 

drainage in Washington, the John Day River drainage in Oregon (where limited hybridization 

with redband trout apparently has occurred), and elsewhere in mid-Columbia tributaries (Behnke 

1992), including the Methow, Entiat, and Wenatchee river Basins in Washington (McIntyre and 

Rieman 1995). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Action Area Information 

According to Wallowa-Whitman Forest GIS data, westslope cutthroat trout occur within the 

analysis area in the Rapid River and Snake River – Granite Creek watersheds. 

3.5.3 Environmental Consequences 

This section discusses the general effects of herbicide use for invasive plant treatments to fish 

and other aquatic organisms as well as the specific effects of the No Action and Action 

Alternatives. Much of the effects discussion is incorporated from Risk Assessments and the 

Fisheries BA completed for the R6 2005 FEIS and associated documents. 

General Effects of Herbicide Use for Invasive Plant Treatments 

Fish and other aquatic organisms have the potential to be adversely affected by contact with 

concentrations of herbicide that exceed levels of concern in water. For example, herbicides 

applied near a stream could inadvertently contact aquatic invertebrates that rely on terrestrial 

plants to fulfill their life cycle and thus reduce the availability of food for fish. Herbicides can 

alter the structure and biological processes of both terrestrial and aquatic ecosystems; these 

effects of herbicides may have more profound influences on communities of fish and other 

aquatic organisms than direct lethal or sublethal toxic effects (Norris et al. 1991). Herbicides 

used for aquatic invasive plant control have been shown to affect aquatic ecosystem components, 

however concentration of herbicides coming in contact with water following land-base 

treatments are unlikely to be great enough to cause such changes (ibid). Since this project does 

not include treatment of invasive plants, effects from aquatic invasive plant control are not a 

concern. 

Sublethal effects can include changes in behaviors or body functions that are not directly lethal 

to the aquatic species, but could have consequences to reproduction, juvenile to adult survival, or 

other important components to health and fitness of the species. Or, sublethal effects could result 

from effects to habitat or food supply. 

Residues in food from direct spraying are not likely to occur since herbicides would not be 

applied to emergent aquatic vegetation. Drift from herbicides used on terrestrial vegetation may 

affect aquatic vegetation at low concentrations, however they show little tendency to 

bioaccumulate and are likely to be rapidly excreted by organisms as exposure decreases (ibid). 

Therefore, while the herbicides considered for use in this project may kill individual aquatic 

plants, aquatic habitats and the food chain would not be adversely impacted because the amount 

of herbicide that could be delivered is relatively low in comparison with levels of concern from 

SERA Assessments and the duration to which any non-target organism (including aquatic plants) 

would be exposed is very short-lived and impacts to aquatic plants would be very localized. 

The application rate and method, along with the behavior of the herbicide in the environment, 

influence the amount and length of time an herbicide persists in water, sediment, or food sources. 

Once in contact, the herbicide must be taken up by the organism and moved to the site of 

biochemical action where the chemical must be present in an active form at a concentration high 

enough to cause a biological effect (ibid). 

Herbicides vary in their environmental activity and physical form. Some may be oil- or watersoluble molecules dissolved in liquids, or attached to granules for dry application to soil surface. 

Herbicides may move from their location of application through leaching (dissolved in water as 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

it moves through soil), volatilization (moving through air as a dissolved gas), or adsorption 

(attached by molecular electrical charges to soil particles that are moved by wind or water). 

In soil and water, herbicides may persist or decompose by sunlight, microorganisms, or other 

environmental factors. Soil properties, rainfall patterns, slope, and vegetative cover greatly 

influence the likelihood that an herbicide will move off-site, once applied. 

In combination with other site and biological factors, these characteristics influence both the 

probability of meeting site-specific goals for invasive plant control, and the potential of 

impacting non-target components of the environment. 

The effects from the use of any herbicide depends on the toxic properties (hazards) of that 

herbicide, the level of exposure to that herbicide at any given time, and the duration of that 

exposure. Risk to aquatic organisms can be reduced by choosing herbicides with lower potential 

for toxic effects when exposure may occur. Exposure of federally listed fish to herbicides can be 

greatly reduced or increased depending on site-specific implementation techniques and timing 

used in herbicide application projects. Exposure can be reduced by such methods as streamside 

buffer zones, timing applications to avoid sensitive seasons, varying application methods used, 

and combining herbicide treatments with non-herbicide treatments to reduce overall use. Project 

Design Features included in the Proposed Action are expected to minimize potential exposures to 

federally listed fish. 

The hazards associated with each herbicide active and inert ingredients, impurity or metabolite 

was determined by a thorough review of available toxicological studies. For a background 

discussion of all toxicological tests and endpoints considered in Forest Service Risk 

Assessments, refer to SERA 2001. 

Herbicides are not pure compounds and they contain the active ingredient, impurities, adjuvants, 

inert ingredients, and may also contain surfactants. The effects of inert ingredients, adjuvants, 

impurities, and surfactants to wildlife (includes fish) are discussed first, followed by a discussion 

of the effects of the active ingredients. 

The movement, persistence, and fate of an herbicide in the environment determine the likelihood 

and the nature of the exposure fish and other aquatic organisms will receive. Stream and lake 

sediments may be contaminated with herbicides by deposition of soils carrying adsorbed 

herbicides from the land or by adsorption of herbicides from the water (Norris et al. 1991). 

Persistence of the herbicide is the predominant factor affecting its presence in the soil. Stream 

and lake sediments may be contaminated with herbicides by deposition of soils carrying 

adsorbed herbicides from the land or by adsorption of herbicides from the water (Norris et al. 

1991). 

Effects of Active Ingredients in Herbicide to Aquatic Organisms 

The most sensitive effect from the most sensitive species tested was used to determine the 

toxicity indices for each herbicide. Quantitative estimates of dose from each exposure scenario 

were compared to the corresponding toxicity index to determine the potential for adverse effect. 

Doses below the toxicity indices resulted in discountable effects. Table 55 lists the toxicity 

indices for fish used for the R6 2005 FEIS BA (USDA Forest Service 2005c). Values in bold are 

the values used to assess risk to fish from acute exposures. 

Indices represent the most sensitive endpoint from the most sensitive species for which adequate 

data are available. Numbers in bold indicate the toxicity index used in calculating the hazard 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

quotient for exposures to listed fish. Generally, the lowest toxicity index available for the species 

most sensitive to effects was used. Measured chronic data (NOEC) was used when they were 

lower than 1/20th of an acute LC50 because they account for at least some sublethal effects, and 

doses that are protective in chronic exposures are more certain to be protective in acute 

exposures. 

Table 55-Toxicity Indices for Listed Fish 

Herbicide Duration Endpoint Dose Species Effect Noted at 

LOAEL 

Acute NOEC 

2 mg/L

(1/20th of 

LC50) 

Brown trout LC50 at 40 mg/L 

Chlorsulfuron 

Chronic NOEC1 3.2 mg/L Brown trout rainbow trout length 

affected at 66mg/L 

Acute NOEC 

5 mg/L 

(1/20th of 

LC50) 

Rainbow 

trout LC50 at 103 mg/L Clopyralid 

Chronic none available 

Acute NOEC 0.5 mg/L

(1/20th/LC50) 

Rainbow 

trout LC50 at 10 mg/L 

Glyphosate (no 

surfactant) Chronic NOEC 2.57 mg/L2 Rainbow 

trout 

Life-cycle study in 

minnows; LOAEL not 

given 

Acute NOEC 

0.065 mg/L 

(1/20th of 

LC50) 

Rainbow 

trout 

LC50 at 1.3 mg/L for 

fingerlings (surfactant 

formulation) Glyphosate 

with POEA 

surfactant Chronic NOEC 0.36 mg/L salmonids 

estimated from full lifecycle study of minnows 

(surfactant formulation) 

Acute NOEC 100 mg/L all fish 

at 100 mg/L, no 

statistically sig. 

mortality Imazapic 

Chronic NOEC 100 mg/L fathead 

minnow 

No treatment related 

effects to hatch or 

growth 

Acute NOEC 

5 mg/L

(1/20th 

LC50) 

trout, catfish, 

bluegill 

LC50 at 110-180 mg/L 

for North American 

species Imazapyr 

Chronic NOEC 43.1 mg/L Rainbow 

“nearly significant” 

effects on early life 

stages at 92.4 mg/L 

Acute NOEC 10 mg/L Rainbow lethargy, erratic 

Metsulfuron swimming at 100 mg/L 

methyl Chronic NOEC 4.5 mg/L Rainbow standard length effects 

at 8 mg/L 

Acute NOEC 0.04 mg/L 

(1/20th LC50) 

Cutthroat 

trout LC50 at 0.80 mg/L 

Picloram 

Chronic NOEC 0.55 mg/L Rainbow 

trout 

body weigh and length 

of fry reduced at 0.88 

mg/L 

Acute NOEC 0.06 mg/L 

(1/20th LC50) 

Rainbow 

trout 

LC50 of Poast at 1.2 

Sethoxydim mg/L 

Chronic NOEC none available 

Sulfometuron 

methyl Acute NOEC 7.3 mg/L Fathead 

minnow 

No signs of toxicity at 

highest doses tested 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Effect Noted at Herbicide Duration Endpoint Dose Species LOAEL 

Chronic NOEC 1.17 mg/L Fathead 

minnow 

No effects on hatch, 

survival or growth at 

highest doses tested 

Acute NOEC 0.26 mg/L 

(1/20th LC50) 

Chum 

salmon LC50 at 5.3 mg/L3 

Triclopyr acid 

Chronic NOEC 104 mg/L Fathead 

minnow 

Reduced survival of 

embryo/larval stages at 

140 mg/L 

Acute 0.012 mg/L Bluegill 

sunfish LC50 at 0.25 mg/L 

Triclopyr BEE 

Chronic4 NOEC 104 mg/L Fathead 

minnow 

Reduced survival of 

embryo/larval stages at 

140 mg/L 

Acute5 NOEC 0.2 mg/L 

(1/20th LC50) 

fathead 

minnow, 

rainbow trout 

NPE LC50 at 4.0 mg/L 

Surfactants 

Chronic6 NOEC 1.0 mg/L trout no LOEL given 

1 Chronic value for brown trout (sensitive sp.) was estimated using relative potency in acute and chronic values for 

rainbow trout, and the acute value for brown trout. 

2 Estimated from minnow chronic NOEC using the relative potency factor method (SERA Glyphosate 2003). 

3 Using Wan et al. (1989) value for lethal dose. 

4 Chronic and subchronic data for triclopyr are limited to triclopyr TEA. No data is available for triclopyr BEE. 

5 Exposure includes small percentage of NP and NP1-2E (Bakke, 2003). 

6 Chronic exposure is from degredates NP1EC and NP2EC, because NPE breaks down rapidly and NPEC’s are more 

persistent (Bakke, 2003). 

NOEC = No Observable Effect Concentration 

LOEAL – Lowest Observed Adverse Effect Level 

Results of the exposure scenarios as applied to listed fish on the Wallowa-Whitman National 

Forest are displayed below in Table 56. The R6 2005 FEIS Fish BA displayed the results by 

placing stars (*) and diamonds (♦) where there was an exceedence in the level of concern (LOC). 

For purposes of this BE the table of stars and diamonds has been modified to show the hazard 

quotients (HQ) value in order to exemplify the magnitude of difference between typical and high 

application rates, and aquatic and non-aquatic formulations. Where there is a “—” and no 

number means that there was no exceedence in level of concern (LOC). The LOC exceedence 

occurs when the HQ value exceeds 1. Exceedences in LOC indicate occasions where the 

expected exposure concentration (EEC) is greater than the no observable effect concentration 

(NOEC) value used for that aquatic species group, which may lead to an indirect effect to listed 

aquatic species if conditions were similar to what was modeled in the SERA risk assessments. 

To calculate a HQ, simply take the ratio of EEC/NOEC values. Toxicity indices used in the R6 

2005 FEIS for aquatic organisms are NOEC values, refer to table above. Two types of indirect 

effects are possible, those toxic to the listed aquatic species, and those mediated by toxic effects 

to an ecosystem component that is part of the Primary Constituent Elements (PCE) or associated 

essential habitat features. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 56-Hazard quotient values for acute exposure estimates for sensitive aquatic organisms 

broadcast spray scenarios 

Aquatic 

Species 

Group 

Application 

Rate 

Chlorsulfuron 

Clopyralid 

Glyphosate w/o 

surfactant* 

Glyphosate with 

surfactant 

Imazapic 

Imazapyr* 

Metsulfuron Methyl 

Picloram 

Sethoxydim 

Sulfometron Methyl 

Triclopyr TEA* 

Triclopyr BEE 

NPE surfactant 

Fish 

High -- -- 6 43 -- -- -- 5 3 -- 15 125 -- 

Typical -- -- 2 12 -- -- -- 2 2.5 -- 1.5 13 -- 

Aquatic 

invertebrates 

 

High 

-- -- -- 2.5 -- -- -- -- -- -- -- 1.8 -- 

Typical 

-- -- -- -- -- -- -- -- -- -- -- -- -- 

Algae 

High 5 -- -- 3.1 -- 5 -- -- -- 3 9.5 214 -- 

Typical -- -- -- -- -- 2 -- -- -- -- -- 21 -- 

Aquatic 

macrophytes 

 

High 

1064 -- -- -- 1.4 8 9 2 -- 36 9.5 214 -- 

Typical 234 -- -- -- -- 3 2 -- 4 21 

‘--’ Predicted concentrations less than or equal to the estimated or measured ‘no observable effect concentration’ at both 

typical and high application rates. 

‘*’ Aquatic formulations analyzed in the R6 2005 FEIS 

The exposure scenarios do not account for factors such as timing of application, animal behavior 

and feeding strategies, animal presence within a treatment area, or other relevant factors such as 

site-specific conditions. However, the SERA risk assessments do represent a worst-case scenario 

that is a good benchmark for assessing true concerns with actual application. Results of triclopyr 

exposures take into account the strict limitations on use identified in the forest plan standards, 

which makes the exposure scenarios implausible or impossible. 

Table 56 displays the results of exposure if all “worst-case” conditions reflected in the scenario 

occur, which is highly unlikely for Wallowa-Whitman National Forest. 

In Appendix E, the Chronic and Acute Exposures section focuses on the probability and 

magnitude of acute exposures from herbicide treatments based on results from the SERA risk 

assessments. It also contains a summary of herbicide characteristics in soil in order to gain a 

better understanding of the probability of adverse effects to aquatic organisms should the 

herbicide come in contact with water. 

Effects of Surfactants 

Appendix 3c of the SERA 2003 risk assessment summarizes the available ecological information 

from all of the Material Safety Data Sheets (MSD’s) for the formulations that are labeled for 

forestry applications. It is apparent that these formulations fall into relatively clear groups. The 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

most toxic formulations appear to be Credit Systemic, Credit, Glyfos, Glyphosate, glyphosate 

Original, Prosecutor Plus Tracker, Razor SPI, Razor, Roundup Original, Roundup Pro 

Concentrate, and Roundup UltraMax (®). 

It may be presumed that these formulations contain the most toxic surfactants. Other 

formulations such as Aqua Neat, Aquamaster, Debit TMF, Eagre, Foresters’ Non-Selective 

Herbicide, Glyphosate VMF, and Roundup Custom (®) are much less acutely toxic. See the BE 

for this EIS (available upon request from the Wallowa-Whitman National Forest) for more 

details about surfactants. 

For the SERA 2003 risk assessment, the uncertainties involving the presence or absence of a 

surfactant and the possibly differing effects of using various surfactants cannot be resolved with 

certainty. The R6 2005 FEIS addresses this uncertainty through Standard #18. 

Effects of the Alternatives 

Alternative A – No Action 

Direct and Indirect Effects 

Manual, mechanical, cultural and biological treatments would continue under the management 

direction of existing decisions. Under this alternative less than 23 percent of known sites would 

be treated with herbicide, leaving a heavy reliance on manual treatments, which in many cases is 

cost prohibitive. Repeated manual treatments may effectively control small, isolated populations 

of certain plants, however associated labor, time and cost may make manual treatments less 

practical and effective, especially when treating large infestations. 

The decision made in the EA from1994 allows use of glyphosate and picloram and triclopyr on 

up to 5,172 acres per year on 124 sites. 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 species. Glyphosate is nonspecific and kills all vegetation. 

According to the soil and water analysis for this EIS, there could be a short-term reduction in soil 

cover for the areas treated. This localized reduction in cover would increase treated areas 

vulnerability to soil erosion. The effects would be minimal given the small amount of land 

treated, especially within Aquatic Influence Zones, and the scattered nature of the treatments. 

These effects would last approximately one season until vegetation became re-established. Most 

invasive plants provide less stream-shading than native hardwoods and conifers and less bank 

stabilization than deeper rooted native vegetation. 

Invasive plants would continue to grow on sites where treatment is currently not authorized by a 

NEPA analysis. There is no mechanism in Alternative A that allows for Early Detection Rapid 

Response (EDRR). No broadcast application takes place within RHCAs under the No Action 

Alternative so there is little chance of herbicide drift into streams. 

Cumulative Effects 

This alternative is covered under the The 1994 Wallowa-Whitman Management of Noxious 

Weeds Environmental Assessment (USDA Forest Service 1994a). Treatments would occur on an 

extremely small percentage of any watersheds in the project area. Direct and indirect effects are 

so insignificant and temporary that treatment under No Action could not plausibly contribute to 

significant cumulative effects. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Alternative B – Proposed Action 

Direct and Indirect Effects 

Non-herbicide Treatment Methods 

All invasive plant treatments can result in some erosion, stream sedimentation, and disturbance 

to aquatic organisms if carried out over a large enough area. Sedimentation can cover eggs or 

spawning gravels, reduce prey availability, and harm fish gills. Soil can also become compacted 

and prevent the establishment of native vegetative cover. All invasive plant treatments can 

reduce insect biomass, which would result in a decrease in the supply of food for fish and other 

aquatic organism. Reductions in cover, shade, and sources of food from riparian vegetation could 

result from herbicide deposition in a streamside zone (Norris et al. 1991). 

Riparian vegetation affects habitat structure in several important ways. Roots of riparian 

vegetation hold soil, which stabilizes banks, prevents addition of soil run-off to water bodies 

with subsequent increases in turbidity or filling substrate interstices, and helps to create 

overhanging banks. Riparian and emergent aquatic vegetation can provide hiding cover or refuge 

for fish and other aquatic organisms where native plants have been replaced. 

Manual, Mechanical, Site Restoration and Revegetation Methods 

Manual and mechanical treatments related to the Proposed Action are described as methods that 

may include brush cutters, or other machinery with various types of blades to remove plants. 

Manual methods include the use of hand-operated tools (e.g., axes, brush hooks, hoes, shovels, 

hand clippers) to dig up and remove noxious species (USDI 2003). 

Direct and indirect effects of manual and mechanical treatments were analyzed in the R6 2005 

FEIS (Appendix J). Public scoping issues about these treatments were not raised. Manual 

treatments, such as lopping or shearing, cause an input of organic material (dead roots) into the 

soil. As the roots are broken down in the soil food web, nutrients will be released. Rainfall may 

cause these nutrients to be lost to surface runoff or to groundwater. Bare soils combined with 

high nutrient levels provide ideal conditions for the establishment of many invasive species. In 

lower intensity infestations, non-target vegetation could provide erosion control as well as a seed 

source for establishing native vegetation. In areas with larger amounts of bare soil, PDFs require 

restoration activities to reestablish native vegetation. The intent is to re-establish competitive 

local, native vegetation post-treatment in areas of bare ground. 

The presence of people or crews with hand-held tools along streambanks could lead to localized, 

sediment/turbidity to fish habitat because of trampling, soil sloughing due to stepping on banks 

and removal of invasive plant roots. However, amounts of potential localized sediment/turbidity 

would be negligible because the invasive plant populations on the Wallowa-Whitman National 

Forest are not extensive enough to result in significant sediment/turbidity and emergent 

vegetation will not be treated. Effective invasive plant treatment and restoration of treated sites 

would improve the function of riparian areas and lead to improved fish habitat conditions. 

The Proposed Action would benefit aquatic ecosystems to the extent they effectively restore 

riparian habitats, especially habitats adjacent to fish bearing streams. The impacts of invasive 

plants on these habitats can last decades, while the impacts of treatment tend to be short term. 

Passive and active restoration would accelerate native vegetative recovery in treated sites. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Removal of plant roots along a streambank will cause some ground disturbance and may 

introduce some sediment to streams. For example, weed wrenching of scotch broom may loosen 

soil and cause minor amounts of erosion for approximately one season until vegetation was 

reestablished. These minor amounts of erosion would be negligible once contact with water is 

made. Under the Proposed Action, significant removal of riparian invasive species would not 

occur because of the proposed use of herbicides reducing the potential for significant soil 

disturbance. 

Using mowing equipment on existing roads is not expected to impact soils. Soil compaction 

eliminates soil pores and so reduces water infiltration, aeration, and the ability of plants to root 

effectively. However, the limited amount of mechanical treatment proposed eliminates risk of 

extensive soil impacts. 

While the relative amounts of manual and mechanical treatments vary, the differences in terms of 

effects from such treatments are negligible. Other mechanical treatments, such as the use of 

motorized hand tools, are expected to have effects similar to manual treatments. 

Turbidity and Sediment 

Manual, mechanical, and restoration treatment activities that incorporate substantial grounddisturbing activities in riparian areas may lead to increased erosion and stream sedimentation. 

Persistence of increased turbidity depends on the size of the suspended particle and velocity of 

the water. Impacts related to fine sediment depends on the amount of fine sediment introduced 

and the holding capacity of the surface water. Increased turbidity can reduce feeding ability or 

gill function in some fish species and fine sediments can cover eggs or spawning gravels. 

Effects to listed aquatic species will vary with the proximity of the species and their habitat to 

the treatment area, the sensitivity of the listed species to turbidity and fine sediment, and the size 

of the area treated. 

Manual, mechanical, and restoration treatments include activities such as hand pulling, mowing, 

brushing, seeding, and planting. Manual treatments within 100 feet of streams with listed species 

would occur along Bear Creek (0.86 acres), Imnaha River (0.67 acres), Horse Creek (0.38 acres) 

and Joseph Creek (0.7 acres). The amount of sediment created by these non-herbicide treatments 

is anticipated to be insignificant because the methods of treatments do not include ground 

disturbing activities by heavy equipment and the treatment areas are so small. Ground disturbing 

activities by hand pulling and planting will cover a relatively small area and any sediment 

created at these sites would be quickly dispersed in the large volume of water. 

Temperature 

Aquatic species have specific needs in terms of water temperature. Increasing water temperature 

may decrease the dissolved oxygen in water which may affect metabolism and food 

requirements. Many factors influence water temperature including shade, discharge, channel 

morphology, air temperature, topography, stream aspect, and interactions with ground water. 

Shade is the factor that has the potential to be impacted by non-herbicide treatments. 

Manual, mechanical, and restoration treatments of some invasive plant species (such as 

knotweed) may decrease riparian vegetative shading in some areas, thereby increasing the 

amount of solar radiation striking the water. This may result in a warming effect but many other 

factors in addition to shade affect water temperature. A significant amount of vegetation would 

need to be removed to change water temperature in the stream, and shade would have to be 

provided only by the invasive plant removed. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

The only known treatment sites that may remove invasive vegetation directly adjacent to water 

are along Bear Creek (0.86 acres), Imnaha River (0.67 acres), Horse Creek (0.38 acres) and 

Joseph Creek (0.7 acres). The amount of vegetation that will be removed at these sites is not 

enough to measurably impact stream temperature and therefore listed fish will not be exposed to 

the effects of increased stream temperature from treatments at either site. 

Herbicide Treatments 

Broadcast and spot-spraying herbicide may result in some minor amounts of herbicide coming in 

contact with water where there may be fish present, however; the likelihood of the amount being 

at a level of concern is low. The Project Design Features (PDFs) and Buffers (See Chapter 2 of 

the EIS) minimize or eliminate the potential for any herbicide to reach a threshold of concern for 

listed and sensitive fish species. The Proposed Action would not apply herbicides directly to any 

stream for purposes of treating aquatic weeds that are floating or submerged in any situation 

There are no sites with emergent vegetation proposed for treatment, therefore the potential for 

high concentrations causing acute toxicity effects is extremely remote. 

An accidental spill could result in concentrations of herbicides that could harm aquatic 

organisms. The Proposed Action includes Project Design Features that would reduce the 

likelihood and impact of a spill. The Proposed Action allows only certified applicators that have 

gone through various courses and training to properly use herbicides in a safe manner. 

Buffers act as a safety zone to limit the potential for herbicides coming in contact with water at 

concentrations of concern for aquatic resources through leaching, run-off, or drift. The buffers 

included in the Proposed Action become more restrictive within Aquatic Influence Zones, 

especially when water is present. PDFs and buffers were developed based on label advisories, 

SERA “worst case” risk assessments, previous Section 7 Consultation for the R6 2005 FEIS, 

Neil Berg’s 2004 study of broadcast drift and run off to streams, as well as monitoring data from 

other herbicide applications projects. 

No broadcast applications of herbicides would occur within 100 feet of perennial and wet 

intermittent streams, lakes, or wetlands, or on roads that have a high potential for herbicide 

delivery. The majority of herbicides have 50-foot buffers for spot treatments, except for low risk 

and aquatic labeled herbicides. Spot applications of aquatic labeled formulations of glyphosate 

and imazapyr may be used up to the water’s edge or within 15 feet of isolated standing water 

present in roadside ditches that are outside the stream buffer. Spot applications of aquatic 

labeled triclopyr may not be used within 15 feet of perennial and wet intermittent streams or 

other waterbodies. 

The Proposed Action limits broadcast applications of herbicides to the following situations: 

• Outside established buffers for aquatic influence zones along perennial/intermittent 

streams and other waterbodies. Buffers differ by chemical, based on risk factors (see 

Tables 7-10 for buffers). 

• Outside established buffers when water is present within roadside ditches 

• On roads that do not have a high potential for herbicide delivery 

Analysis of the Effects 

Herbicide applications may occur near streams utilized by ESA listed fish species found in the 

project area. Physiological responses from exposure to herbicides proposed for use are probably 

similar between bull trout, salmon and steelhead. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Higher Risk Treatment Scenarios on the Willowa-Whitman National Forest 

Higher risk treatment scenarios are defined as situations where herbicide exposure could exceed 

a level of concern for listed fish. Higher risk treatment scenerios also include aerial application 

of herbicide. Many treatment areas on Wallowa-Whitman National Forest are within riparian 

areas and along roads with potential to deliver herbicide to streams. As discussed previously, 

broadcast treatments would not occur within 100 feet of a wet stream or 50 feet of a dry stream. 

The treatment methods and herbicides proposed for use within the Aquatic Influence Zone are 

far less likely to deliver herbicide at levels of concern than broadcasting. Results from the risk 

assessments far overestimate the amount of herbicide likely to enter surface waters for proposed 

treatments because actual treatments will not broadcast spray 10 acres immediately adjacent to 

streams and the Proposed Action contains PDFs that restrict application methods and rates near 

water. For more information about how risks are abated see the PDFs outlined in Chapter 2. 

Analysis of Higher Risk Scenario 1 

The following streams contain at least ten acres of estimated treatment within the Aquatic 

Influence Zones. In most cases, the existing treatment sites were found to be small and scattered 

throughout the watersheds. The PDFs and buffers appear to sufficiently reduce risks to a low 

level, even if all these treatments were to occur simultaneously (unlikely). Refer to Table 49 for a 

complete listing of federally listed fish. 

Little Bear Creek - Approximately 22 acres of treatment lie with the aquatic influence zone of 

Little Bear Creek. Many roads along this creek are associated with high risk for delivery of 

herbicide to streams, with specific PDFs applying. Federally listed fish within the Little Bear 

Creek subwatershed include Snake River Steelhead, Snake Rriver Chinook Salmon and Bull 

Trout, however, only bull trout is present at the actual site proposed for herbicide treatment. 

Grande Ronde River - Approximately 12 acres of treatment lie within the aquatic influence 

zone. One small section of road along this river is associated with high risk for delivery of 

herbicides to streams. Federally listed fish include Snake River Steelhead, Snake River Chinook 

Salmon and Bull Trout. 

Bull Run Creek - Approximately 31 acres of treatment lie within the aquatic influence zone. 

Many roads along this creek are associated with high risk for delivery of herbicides to streams, 

with specific PDFs applying. Federally listed fish include Middle Columbia Steelhead. 

Granite Creek - Approximately 11 acres of treatment lie within the aquatic influence zone. 

Three roads along this creek are associated with high risk for delivery of herbicides to streams, 

with specific PDFs applying. Federally listed fish include Middle Columbia Steelhead. 

Unnamed Tributary to Little Sheep Creek - Approximately 59 acres of treatment lie within 

the aquatic influence zone. Two roads along this creek are associated with high risk for delivery 

of herbicides to streams, with specific PDFs applying. Federally listed fish include Snake River 

Steelhead. 

Imnaha River - Approximately 38 acres of treatment lie within the aquatic influence zone. 

Many roads within this watershed are associated with high risk for delivery of herbicides to 

streams, with specific PDFs applying. Federally listed fish include Snake River Steelhead, Snake 

Rriver Chinook Salmon and Bull Trout. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Sage Creek - Approximately 14 acres of treatment lie within the aquatic influence zone. One 

road along this creek is associated with high risk for delivery of herbicides to streams, with 

specific PDFs applying. Federally listed fish include Snake River Steelhead. 

Burnt Corral Creek - Approximately 14 acres of treatment lie within the aquatic influence 

zone. Two roads along this creek are associated with high risk for delivery of herbicides to 

streams, with specific PDFs applying. Federally listed fish include Snake River Steelhead. 

Minam River - Approximately 13 acres of treatment lie within the aquatic influence zone. No 

roads along this river are associated with high risk for delivery of herbicides to streams. 

Federally listed fish include Snake River Steelhead, Snake River Chinook Salmon and Bull 

Trout. 

Pine Creek - Approximately 15 acres of treatment lie within the aquatic influence zone. One 

small segment of road along this stream is associated with high risk for delivery of herbicides to 

streams, with specific PDFs applying. Federally listed fish include Bull Trout. 

Kirkwood Creek - Approximately 13 acres of treatment lie within the aquatic influence zone. 

One road along this creek is associated with high risk for delivery of herbicides to streams, with 

specific PDFs applying. Federally listed fish include Snake River Chinook Salmon. 

Somers Creek - Approximately 20 acres of treatment lie within the aquatic influence zone. No 

roads along this creek are associated with high risk for delivery of herbicides to streams. 

Federally listed fish include Snake River Steelhead and Bull Trout. 

Big Sheep Creek - Approximately 28 acres of treatment lie within the aquatic influence zone. 

Two roads along this creek are associated with high risk for delivery of herbicides to streams, 

with specific PDFs applying. Federally listed fish include Snake River Steelhead, Snake River 

Chinook Salmon and Bull Trout. 

Squaw Creek – Approximately 13 acres of treatment lie within the aquatic influence zone. No 

roads along this creek are associated with high risk for delivery of herbicides to streams. 

Federally listed fish include Snake River Steelhead. 

Grande Ronde River - Approximately 63 acres of treatment lie within the aquatic influence 

zone. Many roads within this watershed are associated with high risk for delivery of herbicides 

to streams, with specific PDFs applying. Federally listed fish include Snake River Steelhead, 

Snake River Chinook Salmon and Bull Trout. 

Gumboot Creek - Approximately 32 acres of treatment lie within the aquatic influence zone. 

One road along this creek is associated with high risk for delivery of herbicides to streams, with 

specific PDFs applying. Federally listed fish include Snake River Steelhead. 

Sumac Creek - Approximately 38 acres of treatment lie within the aquatic influence zone. One 

road along this creek is associated with high risk for delivery of herbicides to streams, with 

specific PDFs applying. Federally listed fish include Snake River Steelhead. 

Analysis of Higher Risk Scenario 2 

Aerial application is proposed in several 6th field watersheds; 

Snake River - Cache Creek - Approximately 78 acres are estimated for treatment within this 

watershed, however none of these acres are within the aquatic influence zone. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Specific PDFs apply to aerial treatments, including no application within 300 feet of fish-bearing 

streams. This watershed includes Snake River steelhead, Snake River Chinook salmon and bull 

trout. 

Cook Creek - Approximately 25 acres are estimated for treatment within this watershed. 

Specific PDFs apply to aerial treatments, including no application with 300 feet of fish-bearing 

streams. This watershed includes Snake River steelhead, Snake River Chinook salmon and bull 

trout. 

Imnaha River - Thorn Creek - Approximately 58 acres are estimated for treatment within this 

watershed, however, none of these acres are within the aquatic influence zone. Each treatment 

site is more than a mile from the nearest fish-bearing stream. Specific PDFs apply to aerial 

treatments, including no application with 300 feet of fish-bearing streams. This watershed 

includes Snake River steelhead, Snake River Chinook salmon and bull trout. 

Snake River - Dug Bar - Approximately 28 acres are estimated for treatment within this 

watershed, however, none of these acres are within the aquatic influence zone. Specific PDFs 

apply to aerial treatments, including no application with 300 feet of fish-bearing streams. This 

watershed includes Snake River steelhead, Snake River Chinook salmon and bull trout. 

Snake River -Dry Creek - Approximately 13 acres are estimated for treatment within this 

watershed, however, none of these acres are within the aquatic influence zone. Both treatment 

sites are more than a mile from the nearest fish-bearing stream. Specific PDFs apply to aerial 

treatments, including no application with 300 feet of fish-bearing streams. This watershed 

includes Snake River steelhead, Snake River Chinook salmon and bull trout. 

Catherine Creek - Conley Lake - Approximately 266 acres are estimated for treatment within 

this watershed, however, none of these acres are within the aquatic influence zone. Each 

treatment site is more than a mile from the nearest fish-bearing stream. Specific PDFs apply to 

aerial treatments, including no application with 300 feet of fish-bearing streams. This watershed 

includes Snake River steelhead, Snake River Chinook salmon and bull trout. 

SERA Risk Assessment Worksheets 

Some streams within road corridors have treatment areas that parallel both the road and the 

stream with many continuous acres of treatment within the aquatic influence zone. In reality 

these areas have invasive plants scattered among other vegetation along the stream. To model a 

worst case scenario a few of these areas with the highest proposed treatment acres were modeled 

for site specific soil types and rainfall with the SERA worksheet. In addition, two hypothetical 

treatment areas were modeled for 75 inches of rain fall to simulate a 2 inch in 24 hour storm. 

These hypothetical sites were modeled with sandy soil and clay soil, the soil types most likely to 

allow runoff into the stream. Only aquatic glyphosate and aquatic imazapyr were modeled with 

the high rainfall and sandy soil as clopyralid is not allowed for use on sandy soil under project 

PDFs. 

Specific Sites Modeled – Non-Aerial 

Gumboot Creek and an unnamed tributary have 99 acres within treatment areas within 100 feet 

of the streams. The treatment area is along 6.5 miles of road 39 which is entirely within the 

RHCA. Much of the road is within 100 feet of the stream. The invasive plants within these areas 

are spotted knapweed and Canada thistle. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

In reality less than 25 percent of the treatment area is infested with the invasive species, which is 

approximately 25 acres scattered over about 6.5 miles. Broadcast spraying could occur in the 

outer part of the RHCA but only spot and hand treatments could occur within 100 feet of the 

stream. 

North Pine Creek and tributaries have approximately 110 acres within treatment areas within 100 

feet of the streams. With an average infestation of 25 percent of the site there would be about 27 

acres of actual infestation along approximately 12.5 miles of road. The treatment areas are along 

road S39 and parallel North Pine Creek. The invasive plants to be treated include hoary cress 

whitetop, diffuse knapweed, Canada thistle, and St. Johns wort. Part of the St. Johns wort would 

be treated with biocontrol. 

The two sites discussed were chosen for site specific modeling using the SERA worksheet. 

These sites were chosen because they have the most treatment within the RHCA and because 

they have higher rainfall than many of the sites at lower elevation. The amount of herbicide that 

runs off is highly dependent on rainfall and soil type. All the broadcast sites along streams are 

also along roads. Roads are highly disturbed areas with compacted soils and tend to have higher 

runoff than undisturbed sites. Herbicides were run with the soil type where they would have the 

most runoff. The herbicides chosen to model were the two allowed for spot spraying up to waters 

edge and clopyralid, a highly effective herbicide for the species to be treated. 

The application scenario analyzed in each SERA worksheet assumed the following site 

conditions and application methods for herbicide application: 

• Herbicide was evenly-applied by broadcast application right up to the water’s edge. 

• Herbicide was applied to a site with a 10 percent slope. 

• The stream that the herbicide values are predicted for has a flow of 1.8 cubic feet per second 

(cfs). This equates to a stream approximately 6.6 feet wide and 1 foot deep. 

• The application block is 10 acres in size and configured in a rectangle that is 50 feet wide by 

8,672 feet long along the stream and all herbicides are assumed to drain from the block to a 

single location and emptying into the water body at that point. 

These site conditions cannot be changed. The variables that can be changed are rainfall, soil and 

herbicide amount used per acre. 

For these sites typical application rates were used, the rainfall at the highest elevation along the 

stream and the hypothetical streams used a rainfall which would give 2 inches of precipitation 

within 24 hours, which is a large storm for this area. As the treatments are not continuous but are 

scattered along miles of road, the model would be considered conservative and would 

overestimate potential herbicide concentrations. 

The results of this analysis shown in Table 57 below indicates all HQ values were well below 1, 

therefore, no levels of concern were exceeded for sensitive fish under these scenarios. The R6 

2005 FEIS notes that as HQ increases above 1, the margins of safety decrease. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 57-Potential herbicide concentrations in water for diverse precipitation ranges and soil types 

Herbicide/ 

location 

Annual 

Precipitation 

(inches) / 

(Modeled 

Precipitation) 

Peak Water 

Contamination 

Rate (mg/L 

per lb/acre) 

Maximum 

Concentration 

in water 

(dose) (mg/L) 

Toxicity 

Index for 

Listed Fish 

(mg/L) 

Hazard 

Quotients 

(sensitive fish) 

Glyphosate (2 lbs/acre) 

North Pine 

Creek 40 0.038 0.076 0.5 0.15 

Gumboot 

Creek 50 0.056 0.112 0.5 0.23 

Hypothetical 

creek-sand (75) 0.099 0.198 0.5 0.40 

Hypothetical 

creek-clay (75) 0.036 0.072 0.5 0.14 

Imazapyr (0.45 lbs/acre) 

North Pine 

Creek 40 0.0004 0.00019 0.135 0.0014 

Gumboot 

Creek 50 .0006 0.00028 0.135 0.0021 

Hypothetical 

creek-sand (75) .00023 0.00010 0.135 0.00077 

Hypothetical 

creek-clay (75) .00096 0.00043 0.135 0.0032 

Chlopyralid (1 lbs/acre) 

North Pine 

Creek 40 0.0096 0.0034 5.15 0.00065 

Gumboot 

Creek 50 0.0106 0.0037 5.15 0.00072 

Hypothetical 

creek-sand (75) 0.031 Not used on sandy soils under project PDFs 

Hypothetical 

creek-clay (75) 0.0105 0.0037 5.15 0.00074 

Aerial Herbicide Treatments 

Aerial application is proposed for 875 acres on the Wallowa-Whitman National Forest. The risk 

for affecting nontarget plants/soils remain within the first year for the lower sloped areas planned 

for treatment where residual disturbance has affected the current soils/vegetation community. 

The risks are associated with other invasive plants moving in after treatment such as cheatgrass 

and medusahead. Mitigations address these risks calling for long term site planning and 

assessing the current regrowth potential for active restoration. Of the two herbicides planned for 

aerial applications (picloram and clopyralid), clopyralid would have the least impact on nontarget species. Picloram can affect seedling conifer growth with subsequent impacts on plant 

functional groups and associated soil communities (SERA 2003). 

The GLEAMS-Driver was used to model herbicide concentrations in water at two sites; the 75 

acre site on Boswell Creek in the La Grande District, and the 249 acre site near Lookout Creek 

in Hells Canyon. The La Grande and Hells Canyon sites were modeled with the steeper slopes 

found at the sites and a very small stream with a flow of only 0.3 cfs. The average rainfall used 

for all the sites was the highest rainfall for the area. See the Hydrology section for more 

information on the GLEAMS-Driver, and the parameters used for modeling. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Results 

Both sites were under a Hazard Quotient (HQ) of 1 for clopyralid and are well below thresholds 

of concern for fish. 

For picloram, both the La Grande site and the Hells Canyon site had a HQ of over 1 at the 

maximum concentration but were below one at the minimum modeled concentration (See Table 

16 in Hydrology Report). Neither site has listed fish directly adjacent to the treatment area but 

both treatment areas have listed fish downstream. Untreated areas would help dilute the 

concentrations of herbicide in the stream, but by how much is unknown. 

Accidental Spill 

Accidental spills are not considered within the scope of the project. Project Design Features 

would reduce the potential for spills to occur, and if an accident were to occur, minimizes the 

magnitude and intensity of impacts. An herbicide transportation and handling plan is a project 

requirement. This plan would address spill prevention and containment. 

EDRR 

Early Detection Rapid Response (EDRR) is part of all the action alternatives. Under this 

approach new or currently unknown infestations may be treated using the range of methods 

proposed in this environmental impact statement on sites similar to those presently proposed for 

treatment. Project design features would constrain treatment methods according to site specific 

conditions to minimize impacts. Aerial application of herbicides would not be allowed under 

EDRR. If treatment sites or types of treatment were not within the range of ground based 

methods discussed above, then additional analysis would occur under another NEPA document. 

Proximity of Streams to Treatment Areas 

Many of the treatment areas are on or near roads that cross either perennial or intermittent 

streams on Wallowa-Whitman National Forest. For the purpose of analyzing close proximity of 

treatment areas to listed fish, streams containing listed fish that flow through treatment areas 

were identified, and a width of 100ft from the stream up into the riparian area was used to 

identify treatment areas that may be located immediately adjacent to a stream (i.e., up to 

bankfull) with listed fish. There are a total of 167 treatment areas identified that include areas 

within 100 ft of streams with ESA listed fish (Table 58). 

Many mainstem rivers, such as Grande Ronde River and Imnaha River serve as migration 

corridors to pacific salmon and bull trout. Tributaries to these mainstem rivers provide spawning 

and rearing habitat. For fall Chinook, juveniles will not typically be found in freshwater on 

Wallowa-Whitman National Forest because they migrate to salt water immediately upon 

emergence. Most of the spawning and rearing for bull trout occurs in the headwaters, and 

typically in the lower reaches only adults can be found. Herbicide application is expected to 

occur on the streambanks in close proximity to rearing and migration habitat within the streams 

listed in Table 58; however no treatments would occur below the ordinary high water mark. 

Spring chinook salmon may occasionally utilize some of these stream reaches for spawning. 

Steelhead and Chinook share a majority of the rivers, while other fish are limited on habitat 

based on their ability to access tributaries or quality of habitat available. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 58-Herbicide treatment areas within 100 feet of streams with listed fish 

Fifth Field 

Watershed Name Stream Name Site ID Acres 

Listed Fish 

Species* present 

within Stream 

Little Bear Creek 415 21.79 BT 

1372 1.89 SRC, SRS, BT 

1425 0.13 SRC, SRS, BT 

1424 0.34 SRC, SRS, BT 

Bear Creek Bear Creek 

1426 0.07 SRC, SRS, BT 

1198 5.07 SRS 

1193 0.03 SRS 

759 1.97 SRS 

1087 0.20 SRS 

1083 0.02 SRS 

Chesnimnus Creek 

1082 0.10 SRS 

Unnamed Trib to 

South Fork 

Chesnimnus Creek 

759 0.11 SRS 

Devils Run Creek 1068 0.51 SRS 

Chesnimnus Creek 

West Fork Peavine 

Creek 302 3.15 SRS 

Beaver Creek 1153 0.38 SRS 

428 5.49 SRC, SRS, BT 

1415 6.34 SRC, SRS, BT Grande Ronde 

River 

1144 0.43 SRC, SRS, BT 

1234 0.89 SRS 

1177 0.01 SRS 

1326 0.06 SRS 

1236 0.09 SRS 

429 0.76 SRS 

South Fork Spring 

Creek 

1235 0.02 SRS 

Grande Ronde 

River/Beaver Creek 

Spring Creek 429 0.74 SRS 

Grande Ronde 

River/Indian Creek 

North Fork Clark 

Creek 1135 3.20 SRS 

1501 8.36 SRS 

Mud Creek 1468 0.14 SRS 

1073 0.01 SRS 

Grande Ronde 

River/Mud Creek 

Wildcat Creek 1070 9.12 SRS 

1452 0.51 MCS, RT Olive Creek 1179 1.82 MCS, RT 

1419 2.31 MCS Beaver Creek 1420 5.02 MCS 

745 0.65 RT 

1364 26.85 MCS, RT 

1453 2.38 MCS, RT Bull Run Creek 

1454 0.67 MCS, RT 

1453 4.69 MCS, RT 

Granite Creek 1365 3.76 MCS, RT 

1191 2.22 MCS, RT 

Granite Creek 

Boulder Creek 1453 0.19 MCS, RT 

1397 0.02 SRC, SRS, RT Lostine Creek Lostine Creek 1227 0.08 SRC, SRS, RT 

Lower Big Sheep Little Sheep Creek 1205 0.05 SRS, BT 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Site ID Fifth Field 

Watershed Name Stream Name Acres 

Listed Fish 

Species* present 

within Stream 

Unnamed Trib to 839 1.16 BT 

Little Sheep Creek 1196 0.01 BT 

Unnamed Trib to 1090 13.64 SRS 

Little Sheep Creek 1499 44.87 SRS 

Unnamed Trib to 

Little Sheep Creek 1500 2.59 SRS 

Creek 

Canal Creek 1071 0.45 SRS 

Horse Creek 1225 0.54 SRC, SRS 

1219 1.06 SRC, SRS Cow Creek 1220 0.32 SRC, SRS 

Lightning Creek 1219 6.67 SRC, SRS 

1222 0.05 SRC, SRS, BT 

1221 0.10 SRC, SRS, BT 

1010 0.01 SRC, SRS, BT 

1004 0.04 SRC, SRS, BT 

1219 1.58 SRC, SRS, BT 

1394 5.06 SRC, SRS, BT 

Lower Imnaha River 

Imnaha River 

1095 3.11 SRC, SRS, BT 

1527 0.01 SRS 

1104 0.50 SRS 

1103 0.35 SRS Lower Joseph Creek Horse Creek 

1523 0.41 SRS 

414 3.01 SRS, BT Deer Creek Lower Wallowa River 418 2.17 SRS, BT 

Sage Creek 418 13.52 SRS 

Burnt Corral Creek 1376 13.61 SRS 

1578 0.06 SRS Meadow Creek 763 2.34 SRS 

425 0.07 SRS McCoy Creek 423 1.57 SRS 

Meadow Creek 

Unnamed Trib to 

Meadow Creek 455 0.84 SRS 

Middle Imnaha River Freezeout Creek 1568 0.43 SRS 

1127 0.26 SRC, SRS, BT 

1126 5.53 SRC, SRS, BT 

1124 6.09 SRC, SRS, BT Minam River 

1123 1.16 SRC, SRS, BT 

Minam River 

Little Minam River 1429 0.01 SRC, SRS 

Anthony Creek 743 1.07 BT 

North Powder River North Fork Anthony 

Creek 852 0.80 BT 

East Pine Creek 1491 2.89 BT 

East Fork Pine 1479 2.02 BT 

Creek 1386 2.96 BT 

1479 14.63 BT Pine Creek 1450 3.10 BT 

Pine Creek 

Middle Fork Pine 

Creek 1450 0.01 BT 

Snake River 937 0.05 SRC, SRS, BT 

Cook Creek 1096 0.39 SRS 

Snake River/Cherry 

Creek 

Cache Creek 1101 0.51 SRS 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Site ID Acres 

Listed Fish 

Species* present 

within Stream 

Fifth Field 

Watershed Name Stream Name 

1517 0.27 SRS 

1264 0.41 SRS 

1098 0.43 SRS 

1512 1.12 SRS 

Snake River/Granite Hells Canyon Creek 1217 0.92 SRS 

Creek Bernard Creek 1540 0.76 SRS 

1348 0.38 SRC, SRS, BT 

Snake River 942 0.12 SRC, SRS, BT 

1303 0.01 SRC, SRS, BT 

Temperance Creek 927 1.93 SRS 

Salt Creek 1538 0.67 BT 

975 0.31 SRS 

1547 0.10 SRS 

1307 12.74 SRS Kirkwood Creek 

1371 0.03 SRS 

989 0.81 BT 

1310 0.25 BT 

1546 0.95 BT Kurry Creek 

1544 1.04 BT 

1254 0.63 SRS, BT West Creek 1321 0.63 SRS, BT 

Snake 

River/Temperance 

Creek 

Somers Creek 1535 20.11 SRS, BT 

Imnaha River 1095 0.64 SRC, SRS, BT 

1095 0.004 SRC, SRS, BT Snake River/Wolf 

Creek Snake River 1298 0.13 SRC, SRS, BT 

1370 3.26 SRC, SRS, BT Lick Creek 1369 2.24 SRC, SRS, BT 

839 1.13 SRC, SRS, BT 

1489 0.06 SRC, SRS, BT 

1507 0.55 SRC, SRS, BT 

1506 9.40 SRC, SRS, BT 

1505 2.70 SRC, SRS, BT 

1504 6.26 SRC, SRS, BT 

Big Sheep Creek 

1502 7.39 SRC, SRS, BT 

Upper Big Sheep 

Creek 

Squaw Creek 1503 12.64 SRS 

South Fork 1141 0.77 SRC, SRS, BT 

Catherine Creek 1575 0.60 SRC, SRS, BT Upper Catherine 

Creek 

Pole Creek 1574 0.05 SRS, BT 

Sheep Creek 1380 2.79 SRC, SRS 

West Chicken 

Creek 1374 0.09 SRC, SRS 

1572 0.08 SRC, SRS 

1137 61.66 SRC, SRS, BT 

768 0.07 SRC, SRS, BT 

Grande Ronde 

River 

1417 0.69 SRC, SRS, BT 

Limber Jim Creek 1240 0.05 SRC, SRS, BT 

Upper Grande 

Ronde River 

Fly Creek 1377 0.32 SRS, BT 

1109 0.01 SRC, SRS, BT 

1370 14.05 SRC, SRS, BT 

Upper Imnaha River Imnaha River 

1108 0.21 SRC, SRS, BT 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Site ID Acres 

Listed Fish 

Species* present 

within Stream 

Fifth Field 

Watershed Name Stream Name 

1209 0.13 SRC, SRS, BT 

1106 0.05 SRC, SRS, BT 

1206 12.66 SRC, SRS, BT 

1105 0.13 SRC, SRS, BT 

1207 0.28 SRC, SRS, BT 

Skookum Creek 1370 0.55 SRS 

Dry Creek 1370 6.19 SRS 

North Fork Imnaha 

River 1476 0.02 BT 

Gumboot Creek 1206 32.29 SRS 

Mahogany Creek 1206 0.49 SRS 

Crazyman Creek 1206 4.39 SRC, SRS 

Elk Creek 759 1.99 SRS 

Unnamed Trib to 

Elk Creek 1066 0.95 SRS 

Little Elk Creek 1075 1.11 SRS 

Swamp Creek 1511 0.73 SRS 

1203 0.01 SRS Sumac Creek 1202 37.51 SRS 

1192 0.03 SRS 

1510 0.59 SRS 

1089 0.42 SRS 

Upper Joseph Creek 

Cougar Creek 

1088 0.20 SRS 

Upper Powder River Lake Creek 1392 0.29 BT 

1232 0.02 BT 

1230 0.93 BT 

1229 0.58 BT Upper Wallowa River Hurricane Creek 

1373 0.53 BT 

*SNS = Snake River Steelhead, SNC = Snake River Chinook Salmon, MCS = Middle Columbia Steelhead, MCC = 

Middle Columbia Chinook Salmon, BT = Bull Trout 

Probability of Herbicide Exposure (increased chemical contaminants) 

The probability that an ESA listed fish will be exposed to non aquatic formulations of herbicide 

is very low. The probability of being exposed to the aquatic formulation of triclopyr is also very 

low. However, there is a possibility of being exposed to aquatic formulations of glyphosate and 

imazapyr but the probability of being exposed at levels of concern is very low. Glyphosate and 

imazapyr have a low propensity for leaching, but can enter water by other means such as 

overspray, drift, or erosion of contaminated soil. This probability is discussed by potential 

exposure vector below: 

Water contamination from hand/select methods: The probability of hand-select methods 

resulting in herbicides coming in contact with water is low. 

The plant begins to take in the herbicide immediately after it is applied directly to a leaf or stem 

with the use of approved binding surfactants. Overland transport to the water column from stem 

injections is unlikely because the injected herbicide is contained within the plant stem. Transfer 

through the stem to the roots might allow some herbicide to enter the soil, but it is likely to 

adhere to soil particles or is degraded by soil microbes before leaching into the ground water. In 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

addition, other general protection measures of the applicators themselves result in a very low risk 

of water contamination. 

Water contamination from drift: The ability to contaminate water varies with the herbicide 

application method. For example, spot and hand application methods substantially reduce the 

potential for loss of non-target vegetation because there is little potential for drift. Drift is most 

associated with broadcast treatments and can be mitigated to some extent by the applicator. 

Droplet size is key to drift as larger droplets are heavier and therefore less affected by wind and 

evaporation. 

Label restrictions, restrictions on application rate, type of herbicide, application method 

restrictions, buffers, and the use of a surfactant all factor in to limiting the potential amount of 

drift. In addition, roads that have a high potential for herbicide delivery have been identified and 

have added restrictions, such as no broadcasting. Since there will be no herbicide applied directly 

to the water column for purposes of treating submerged or emergent vegetation the probability of 

even fine droplets coming in contact with water is low. 

Water contamination from contaminated soil: Riparian treatments are limited in spatial 

extent, and given the restrictions noted above, it is likely that much of the herbicide will have 

either adhered to the soil or broken down not being available for transport into the water. See 

previous sections for more information on herbicide properties. The probability of water 

contamination from contaminated soil is low. 

Water contamination from an accidental spill: Concentrations of herbicides in the water 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). Project Design Features would reduce the potential for spills to occur, and if an 

accident were to occur, minimize the magnitude and intensity of impacts. An herbicide 

transportation and handling plan is a project requirement. This plan would address spill 

prevention and containment. 

Water contamination from aerial spray: Concentrations of herbicide in the water as a result of 

aerial spray depend on the herbicide used and the concentration at which it is applied. According 

to GLEAMS-Driver modeling, chlopyrilid is not likely to reach water at a concentration that 

would negatively affect water quality. However, application of picloram at its highest 

concentration may reach water at concentrations toxic to listed fish. Concentrations would likely 

dilute before reaching downstream fish habitat, however, it is unknown by how much. 

Extensive monitoring of herbicide application using similar treatment methods has occurred over 

the last few years in NW Oregon and Western Washington. 

All personnel applying the herbicides are well trained and licensed. No accidental spills have 

been reported. The risk of an accidental spill under the Proposed Action is extremely low. 

Probability of exposure to aquatic organisms: The probability of localized effects to 

individual aquatic plants is low since no treatments are proposed within the bankfull channel. 

Spot applications of aquatic formulations of glyphosate and imazapyr on streamside vegetation 

are not likely to result in harmful amounts coming in contact with water and harming fish, 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

invertebrates, and algae. The use of glyphosate will not be applied directly to water for weed 

control, but if it does enter the water it is bound tightly to dissolved and suspended particles and 

to bottom sediments and becomes inactive. The probability of exposure to aquatic organisms is 

non-existent. 

Direct Mortality due to Trampling: The project does not propose treatments on emergent 

vegetation that would require applicators to enter the water, therefore the risk of disturbing 

spawning adults or stepping on redds is very low. 

Magnitude of the Effect 

The severity and intensity of herbicides coming in contact with streams containing ESA listed 

fish is variable due to different application techniques and specific herbicide properties. The 

severity and intensity of the effect will depend on the size of stream, type of waterbody, 

herbicide type and its properties. Any treatment of emergent vegetation proposed in the future 

would require additional NEPA anlaysis. 

Hand/select Methods: The magnitude of hand-select methods resulting in water contamination 

is discountable because the application will be directed to a leaf or stem, and the herbicide and 

surfactant will quickly bind to the plant material. The magnitude is predicted to be extremely low 

from any droplets that come in contact with water. 

Drift: Drift is the most likely vector for herbicides coming in contact with water from 

treatments within RHCAs. However, the magnitude of drift compared to an aerial application or 

broadcast application, such as what was analyzed above in the SERA risk assessment 

worksheets, immediately adjacent to a stream is extremely low. Label restrictions, restrictions on 

application rate, type of herbicide, application method restrictions, buffers, and the use of a 

surfactant all factor in to limiting the potential amount of drift. In addition, roads that have a high 

potential for herbicide delivery have been identified and have added restrictions, such as no 

broadcasting. The magnitude of drift is expected to be very low. 

Contaminated soil: Riparian treatments are limited in spatial extent, and given the restrictions 

on methods and type of herbicide, it is likely that much of the herbicide will have either adhered 

to the soil or broken down not being available for transport into the water. The intent of the 

Proposed Action is to apply herbicide to a plant, not to the soil. Any amount of herbicide that 

would indirectly come in contact with the soil as a result of drift or droplets is expected to be 

insignificant; therefore the magnitude of contaminated soil would be low. 

Accidental spill: The probability of an accidental spill for this project is very low. If a spill were 

to occur, the magnitude is limited by Project Design Features, where only daily use quantities of 

herbicides will be transported to the project site, transport via watercraft will require extra 

precautions, impervious material will be placed over mixing areas in such a manner as to contain 

any spills associated with mixing/refilling, and the requirement that a spill kit will be on site 

during all herbicide application. 

Aquatic Organisms: The potential to reach toxicity levels for each trophic level under spot and 

hand/select applications with glyphosate and imazapyr is low. Localized effects would not 

disrupt aquatic ecosystem function of the aquatic food web because spot applications of aquatic 

formulations of glyphosate and imazapyr are not likely to result in harmful amounts coming in 

contact with water and harming fish, invertebrates, and algae. However, some aquatic plants 

could be damaged if enough herbicide comes in contact with the aquatic plant. 

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It is believed that the magnitude of effect to fish as a result of local aquatic plant mortality is 

extremely low because there will not be enough herbicide coming in contact with water to result 

in extensive aquatic plant mortality. 

Trampling: The probability of stepping on a redd while wading across a stream to access either 

the opposite streambank is low. Should an individual wade across a stream and accidentally step 

on a redd, then there is the possibility of impacting individual eggs in the gravel. The magnitude 

of effect from accidentally stepping on a redd is limited to the amount of eggs in the gravel that 

are impacted from the actual weight of the person and disturbance to the redd itself (i.e., shifting 

of the gravel, etc), thus leading to a negative impact to individual egg(s). An egg can be 

dislodged and eaten by a predator, or smashed between gravel or amongst other eggs, which can 

impede successful development of eggs. Although there are few scenerios where workers would 

need to cross a live stream, each egg has the potential to contribute to the overall success of a 

returning population, therefore, the magnitude of effect from accidentally stepping on a redd is 

high. (Magnitude is high) 

Distribution: Refer to Table 54 for a list of treatment sites within aquatic influence zones. 

Effects, if they occur, would be limited in scope and widely scattered due to the patchy nature of 

the infestations. The distribution of effects will be small and scattered throughout WallowaWhitman National Forest. 

Frequency: The proposed treatments would occur over the next 15 year period and the acreage 

treated is expected to decline as long as funding is available and patches are eradicated. The 

programmatic nature of the Proposed Action is the treatment of future unknown infestations. It is 

expected that the frequency of herbicide use will be low given that treatment of invasive plants is 

an art composed of integrated methods (i.e., mix of non-herbicide and herbicide methods) to 

facilitate effectiveness. 

Duration: Any herbicides coming in contact with water are expected to be short-term events that 

subside quickly due to the stream volumes moving through the area (pulse effect). Herbicides 

coming in contact with smaller streams containing extensive riparian infestations are a higher 

risk because of the need for simultaneous treatment and lower volumes of water. Given the 

properties of glyphosate and imazapyr, it is unlikely that these two active ingredients would 

persist long enough in the environment to adversely affect ESA fish. A simultaneous treatment is 

believed to be a short-term event whose effects subside immediately because of the herbicide 

properties and factors that push a concentration up would be off-set by those that push the 

concentration down. 

Timing: Most of the treatments would likely occur in the summer when eggs of all the listed 

species would not be in the gravel and only rearing life stages are present. However, there is a 

potential for some treatments to occur in fall or spring when chinook salmon or steelhead may be 

spawning adjacent to treatment sites. There is also the potential for some treatments to occur in 

late summer or early fall when bull trout are spawning. 

Since no treatments are proposed below bankfull, there is a low probability of accidentally 

stepping on a redd and displacing spawning fish. 

Summary of Effects to the Chemical Contamination Indicator 

Treatment of bankside vegetation with aquatic formulations of glyphosate and imazapyr may 

lead to some minor amounts of herbicide droplets coming in contact with water. Fish may be 

exposed to these minor amounts of herbicide in smaller streams, especially when treatment needs 

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to take place during spawning activities. The need to treat during spawning or accidentally 

stepping on a redd is limited in spatial and temporal extent. Fish in the mainstem of rivers and 

streams may not be exposed because of the river’s large flow and density of fish during time of 

treatment. Smaller streams however, do not have as much flow and may not dilute herbicides as 

quickly. Fish in smaller streams tend to be juveniles and fry, and are also lower in density, thus 

lowering the potential for exposure. Although there is a probability for herbicide to come in 

contact with water in proximity to ESA fish, the magnitude of the effect from the amount of 

herbicide ESA fish are exposed to is low. The magnitude of effect from disturbance to 

breeding/spawning and/or accidentally stepping on a redd is also low, since no emergent 

vegetation is proposed for treatment. 

Restrictions on method, type, and location serve to limit the potential amount of herbicides that 

may come in contact with water where fish or other aquatic organisms are present, even if an 

unexpected storm occurred shortly after treatment. The amount of herbicide that would be 

available for runoff, leaching and/or drift is necessarily limited by restrictions on broadcast use. 

Spot and hand/select treatments do not have high potential to deliver herbicide because the 

treatments are directed at target vegetation and herbicide is quickly taken up by the plant. 

The likelihood of meeting or exceeding levels of concern for fish using non-aerial methods is 

low because: herbicide use in the aquatic influence zone is limited to typical application rates, 

application methods are restricted to spot or hand/select, buffers are required for broadcast 

applications and other methods, Project Design Features would be in affect, and the low potential 

for herbicides proposed for use near water to move through soils. 

Sediment/turbidity 

The presence of people or crews with spot spray or hand/select tools along streambanks could 

lead to localized, sediment/turbidity to fish habitat because of trampling and soil sloughing due 

to stepping on banks. However, amounts of potential localized sediment/turbidity would be 

negligible because the invasive plant populations on the Wallowa-Whitman National Forest are 

not extensive enough to result in significant sediment/turbidity. Effective invasive plant 

treatment and restoration of treated sites would improve the function of riparian areas and lead to 

improved fish habitat conditions. 

Under the Proposed Action, significant removal of riparian invasive species would not occur 

because of the proposed use of herbicides reducing the potential for significant soil disturbance. 

While the relative amounts of spot and hand/select methods vary, the differences in terms of 

effects from such treatments are negligible. 

Proximity 

The amount of sediment created by herbicide treatments is anticipated to be insignificant 

because the methods of treatments do not include ground disturbing activities by heavy 

equipment. There will be no ground disturbing activities associated with spot or hand/select 

methods. 

Probability and Magnitude 

There is a possibility that some minor bank erosion may occur in locations where invasive plants 

have taken over a streambank, especially in smaller streams. For example, killing knapweed with 

an herbicide would devegetate a portion of the streambank and result in a loss of roots that help 

to hold soil particles together. This may expose streambanks at higher flows and result in some 

erosion. The total spatial extent of heavy infestations along streambanks within the action area is 

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low. The amount of sediment released into any particular stream reach would depend on how 

extensive a particular invasive plant patch is and how close the invasive plant is to the actual 

wetted perimeter of the channel. Exposed streambanks are expected to revegetate during the 

spring/summer following treatment. In addition, site restoration and revegetation methods 

preclude erosion as a result of herbicide treatment. It is expected that most patches would be 

relatively small and any erosion negligible. 

The probability of sedimentation and turbidity as a result of herbicide treatments is extremely 

low; therefore, the magnitude of effect to listed fish and/or critical habitat is low. See Effects 

from Non-Herbicide Treatment Methods. 

GLEAMS Model Estimates for Blue Mountains Ecotype 

The R6 2005 FEIS Fisheries BA considered whether ecosystem conditions associated with a 

variety of bioregions (ecotypes) might affect herbicide concentrations/hazards predicted using 

the GLEAMS model. The BA found that risk assessment modeling tends to estimate water 

contamination rates adequately for undisturbed forested vegetation types within the Blue 

Mountains ecotype (Wallowa-Whitman National Forest fits this ecotype). Modeling an 

agricultural field would more adequately model the other vegetation types and would tend to 

underestimate water contamination rates in these circumstances. At higher stream flows (larger 

stream channels or wet season flow conditions), risk assessment model predictions tend to 

overestimate the herbicide concentration in most local streams. For smaller streams, other factors 

considered have a more pronounced effect than for larger streams. 

Based on the modification of the SERA GLEAMS stream herbicide concentration predictions by 

local factors in the Canyon Creek area, results in the R6 2005 FEIS identified the potential for 

increase in concern with picloram, glyphosate, and triclopyr for fish. There was also an increase 

in concern for aquatic macrophytes with chlorsulfuron, glyphosate, imazapic, metsulfuron 

methyl, triclopyr and picloram; for invertebrates with glyphosate and triclopyr, and for aquatic 

plants with chlorsulfuron, glyphosate (with surfactant only), metsulfuron methyl, picloram and 

triclopyr. The R6 2005 Record of Decision (ROD) specifically limited triclopyr to spot and hand 

methods (no broadcast of triclopyr allowed as per standard 16) to avoid scenarios of concern 

related to triclopyr. 

In general, situations that increased concern for potential effects to aquatic species from the level 

of risk stated in the SERA risk assessments occurred for smaller stream channels with steeper 

side slopes, with risk increasing at higher altitudes. Conversely, risk lower than that stated in the 

risk assessments was identified for larger stream channels at lower altitude, and possibly in 

smaller stream channels with sideslopes less than 10 percent. 

Slopes in the Canyon Creek watershed are generally the 10 percent modeled, and herbicide 

delivery to streams could be expected to increase significantly. Local soil types do not appear to 

markedly change expected herbicide delivery for most herbicides likely to be applied in the 

watershed, except in disturbed areas using highly soluble herbicides that do not bind well with 

soil particles, such as picloram and chlorsulfuron. 

Because all of the action alternatives avoid broadcasting within 50 feet of any stream (wet or 

dry), the GLEAMS model would still overestimate the amount of herbicide that would enter 

water, because: 

• Spot and selective methods would only be used within 100 feet of wet streams and 50 

feet of dry streams. These methods substantially reduce potential for off site impacts, 

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drift, and other herbicide delivery mechanisms to water (runoff, leaching). Applicators 

can immediately respond to site conditions to ensure PDFs are followed as planned. 

• The model does not account for vegetation uptake of herbicide (the entire label rate is 

assumed to be subject to run off). The herbicides allowed for use within the Aquatic 

Influence Zone are rapidly taken up by plants and/or bind to soil and would not be 

available for runoff soon after application. 

• PDFs do not allow broadcast on roads with high potential to deliver herbicide, which 

also significantly reduces the potential for herbicides to reach streams in concentrations 

predicted by the GLEAMS model scenarios. 

Previous Monitoring Studies 

Berg (2004) compiled monitoring results for broadcast herbicide treatments given various 

buffers along waterbodies. The results showed that any buffer helps lower the concentration of 

herbicide in streams adjacent to treatment areas. In California, when buffers between 25 and 200 

feet were used, herbicides were not detected in monitored streams (detection limits of 1to 3 

mg/m3) (ibid). 

In South Carolina, buffers of 30 meters (comparable to 100 feet) during ground applications of 

the herbicides imazapyr, picloram and triclopyr resulted in no detectable concentrations of 

herbicide in monitored streams (USDA Forest Service 2003a, Appendix B). No detection limits 

were given. 

Even smaller buffers have successfully protected water quality. For example, where imazapyr 

was aerial sprayed without a buffer, the stream concentration was 680 mg/ml. With a 15-meter 

buffer, the concentration was below detectable limits (Berg 2004). No detection limits were 

given. 

Berg collected samples of several herbicides (including sulfometuron methyl and glyphosate) 

following roadside application one, seven and fourteen days after treatment. Rainfall of one-third 

inch occurred throughout the period. Berg detected concentrations of sulfometuron-methyl and 

glyphosate along road shoulders through the period. In the fall the road was again sprayed, and 

the ditch line of the road was checked during rainstorms for three months. Sulfometuron-methyl 

was detected along the shoulder in the ditch line, but was below detectable limits in the nearby 

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 sulfometuron methyl may 

persist in the environment as it was detectable along the shoulder of the road (but not in the 

stream) the entire duration (three months) of the study. 

Berg also reported that herbicide applied in or along dry ephemeral or intermittent stream 

channels may enter streams through run-off if a large post-treatment rainstorm occurred soon 

after treatment. This risk is minimized if intermittent and ephemeral channels are buffered (ibid.) 

as would occur under the Proposed Action. If a large rainstorm occurs sediment contaminated by 

herbicide could be carried into streams. 

Project Design Features require no forecast rain for 24 hours after application to allow the 

herbicide to adhere to the plant, give time for the plant to uptake the herbicide and to minimize 

risk of herbicide being washed from the plant. 

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Dry sediment contaminated by herbicide could plausibly be carried by wind and enter a stream 

or water body. This is an unlikely scenario as most of the forest is heavily vegetated so there is 

less bare soil for movement by wind. 

Designated Critical Habitat 

Invasive plant treatment would have many beneficial effects on critical habitat for federally 

listed fish species. In the long-term, treatment of invasive weeds on the Wallowa-Whitman 

National Forest would increase native vegetation growth and successional patterns leading to 

cover and food. Thus, it improves essential habitat features for federally listed fish species. 

Potential downstream effects to critical habitat for listed fish are not likely given the PDFs that 

limit the potential for herbicide concentrations coming in contact with water where fish are 

present. Information here complements the analysis provided for non-herbicide treatment 

methods. 

In 1996, NMFS developed a methodology for making ESA determinations for individual or 

grouped activities at the watershed scale, termed the “Habitat Approach”. A Matrix of Pathways 

and Indicators (MPI) was recommended under the Habitat Approach to assist with analyzing 

effects to listed species. The MPI has been used by the Wallowa-Whitman National Forest in 

previous years to analyze project effects on listed fish species. When using the MPI, project 

effects to the Pathways (significant pathways by which actions can have potential effects on 

anadromous salmonids and their habitats) and Indicators (numeric ratings or narrative 

descriptors for each Pathway) are used to determine whether Proposed Actions would damage 

habitat or retard the progress of habitat recovering towards properly functioning condition. These 

effects are analyzed at the sixth field watershed level 

The Sept. 2, 2005 designated critical habitat Primary Constituent Elements (PCEs) pertinent for 

analysis on the Wallowa-Whitman National Forest’s freshwater habitats include spawning sites, 

rearing sites, and migration corridors. The Habitat Approach’s Matrix of Pathways (MPI) has 

numerous habitat-associated Indicators that closely “cross-walk” with the PCEs of the Sept 2, 

2005 designated critical habitat. Table 59 displays a “cross-walk” between the MPI Indicators 

and PCEs used to assess effects on designated critical habitat. 

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Table 59-MPI for Primary Constituent Elements Crosswalk 

Primary Constituent Elements Matrix of Pathways and Indicators 

Spawning Habitat, as defined by water quality, 

water quantity, substrate 

Water Quality: Temperature, Suspended Sediment, 

Substrate, Chemical Contaminants and Nutrients 

Flow/Hydrology: Change in Peak/Base flows 

Habitat Elements: Substrate/Embeddedness 

Rearing as defined by adequate water quantity 

and floodplain connectivity 

Channel Conditions and Dynamics: Floodplain 

connectivity 

Flow/Hydrology: Change in Peak/Base flow 

Rearing as defined by adequate water quality 

and forage 

Water Quality: Temperature, Substrate 

Habitat Elements: Large Woody Debris, Pool 

Frequency and Quality, Off-channel Habitat 

Rearing as defined by adequate natural cover 

Habitat Elements: Large Woody Debris, Pool 

Frequency and Quality, Large Pools, Off-channel 

Habitat 

Migration as defined by habitat free of artificial 

obstructions, and adequate water quality, water 

quantity, and natural cover 

Habitat Access: Physical Barriers 

Water Quality: Temperature 

Flow/Hydrology: Change in Peak/Base flow 

Habitat Elements: Large Woody Debris, Pool 

Frequency and Quality, Large Pools 

The following is an analysis of the effects on Primary Constituent Elements of the Sept. 2, 2005 

designated critical habitat, as determined via analysis of MPI indicators. Please refer to the 

hydrology analysis for effects on Riparian Condition and Water Quality, Lakes, Wetlands and 

Floodplains. 

Habitat Indicator Effects 

Pathway: Water Quality 

Indicator: Temperature 

PCE Crosswalk: Spawning, Rearing, Migration habitat PCEs 

Stream temperature is controlled by many variables at each site. These include topographic 

shading, stream orientation, channel morphology, discharge, air temperature, and interactions 

with ground water, none of which would be influenced by invasive plant treatments. Treatment 

of invasive plants using integrated methods, specifically herbicides, along small streams may 

increase solar radiation at a localized level (i.e. on a small portion of a stream) if invasive plants 

are the only source of shade. Where invasive plants provide the only source of shade on small 

streams, removing 100 percent of the shade producing cover can change forest floor 

microclimates and water temperature at the localized level. However, the precise effects to water 

temperature from treating invasive plants would depend on the size of the stream, how close to 

the stream a treatment site is, how much is treated along the stream, and what vegetation is 

currently available to shade the stream. Removal of invasive plants from the banks of small, 

intermittent streams would not affect temperature because they are dry during the hottest time of 

the year, relative size of the infestation is small within context of the watershed, and more than 

likely there is overstory canopy present. Conditions would have to mimic post wildfire in order 

to impact stream temperatures. 

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On larger perennial streams, a significant amount of vegetation would need to be removed to 

change water temperature and shade would have to be provided only by the invasive plant 

removed – a situation that is not likely on the Willowa-Whitman National Forest. 

One reason treatment of invasive plants is being proposed is to recover vegetation structure and, 

in time, provide more stream shade with the establishment of native coniferous and deciduous 

trees. The PDFs prohibit broadcast applications within 100 feet. of wet perennial and intermittent 

waterbodies, and along roads that have a high likelihood of transporting herbicides to streams to 

prevent any potential adverse affects to stream channels or water quality conditions. This PDF 

will protect overhanging vegetation and smaller trees that are currently providing shade closest 

to the stream and other waterbodies. The treatment of invasive plants outside of the 100-foot 

buffer should have no affect on stream temperature because it is unlikely that vegetation growing 

100 feet from the stream is providing enough shade to influence water temperature. 

The US Environmental Protection Agency under the Clean Water Act (CWA) of 1972 requires 

States to set water quality standards to support the beneficial uses of water. The Act also requires 

states to identify the status of all waters and prioritize water bodies whose water quality is 

limited or impaired. 

For water quality limited streams on National Forest System lands, the Forest Service provides 

information, analysis, and site-specific planning efforts to support state processes to protect and 

restore water quality. The Regional Pacific Northwest Region Invasive Plan EIS and the 

Wallowa-Whitman National Forest Plan both include standards and guidelines and other 

management measures designed to protect and improve water quality. 

This project adheres to all of the above protection measures and adds site specific design criteria 

to further protect water quality, meeting the requirements of the Clean Water Act. 

There are 20 streams in the Wallowa-Whitman Invasivive Plants treatment area on the 303d list. 

All are listed for temperature. 

Pathway: Water Quality 

Indicator: Sediment/Turbidity 

PCE Crosswalk: Spawning habitat PCEs 

Herbicide treatment methods that would be utilized within the Aquatic Influence Zone include 

spot-spray and hand applications. These treatment types are unlikely to produce sediment 

because very little ground disturbance would take place. Manual and mechanical treatments are 

also unlikely to contribute sediment. Manual labor such as hand pulling may result in localized 

soil disturbance, but increases of sediment to streams would likely be undetectable. Not all 

vegetation in a treated area would be pulled or removed, so some ground cover plants would 

remain. Not all sediment from pulling weeds along roads would reach a stream because many 

relief culverts intercept ditch flow and drain it on to the forest floor away from streams. 

Handpulling is very labor intensive and costly. Thus, few acres per year could be treated using 

this technique across a watershed. When compared to the total acres within a watershed, projectrelated soil disturbance from handpulling would be negligible. Utilizing a combination of 

manual, mechanical and herbicide treatments, rather than manual alone, would limit the potential 

for excessive trampling of streambanks. 

Pathway: Water Quality 

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Indicator: Chemical Contaminants/Nutrients 

PCE Crosswalk: Spawning habitat PCEs 

The most likely route for herbicide delivery to water is potential runoff from a large rain storm 

soon after application, especially from treated roadside ditches as well as drift from aerial 

spraying. Project Design Features were designed to control drift and overspray of headwater 

streams, including no fueling within RHCAs, herbicide applications when winds are between 2 

and 8 miles per hour, requiring coarse droplet size to minimize drift and aerial units must be 

ground checked and water features marked and buffered before application. Buffers of 300 feet 

are required on perennial or wet intermittent streams and wetlands, and 100 feet buffers are 

required on dry channels. Based on buffer effectiveness documented by Rashin and Graber 

(1993) and Dent and Robben (2000) concentration of herbicides reaching streams is expected to 

be well below concentrations of concern to beneficial uses. 

Boom or hand broadcast treatments within Aquatic Influence Zones would be limited to 

herbicides posing low levels of concern for aquatic organisms. Herbicides considered high risk 

to aquatic organisms would not be applied using any method within 15 feet of ditches that feed 

streams, or 50 to 100 feet from intermittent streams, even when ditches or intermittent streams 

are dry. These buffers are considered adequate to minimize herbicide concentrations in water 

because, buffer studies in forested areas (Berg 2005) show that buffers greater than 25 feet 

commonly lower herbicide concentrations below any threshold of concern and often below 

detectable limits. 

Glyphosate and imazapyr are the only herbicides used for spot spraying at the water’s edge along 

perennial channels. Glyphosate is highly water soluble, but because it adheres tightly to soils is 

unlikely to be carried into a stream unless the soil particle is carried into the stream. 

This is unlikely to happen during the late spring or summer when herbicides would be applied 

because there is less rain in the summer and more vegetation growth to hold soil particles in 

place. Imazapyr is only moderately water soluble and forest field studies have not found it very 

mobile in soils. 

Herbicides entering surface water through surface runoff are also expected to be minimal, since 

targeted spot spraying techniques would be used to apply herbicide within 100 feet of surface 

water. This would minimize the amount of herbicide reaching the ground surface as well as 

minimize the potential for herbicide drift. No herbicides considered high risk to aquatic 

resources would be broadcast within 100 feet of streams and none would be spot sprayed within 

50 feet of streams. Aerial treatments are proposed more than 1.5 miles upstream of critical 

habitat. However, since modeling indicated an HQ value higher than 1 at the Hells Canyon site 

with the use of picloram, and it is unknown what the dilution factor would be by the time it 

reaches critical habitat, the project may negatively impact critical habitat. 

Pathway: Channel Condition & Dynamics 

Indicator: Floodplain Connectivity 

PCE Crosswalk: Rearing habitat PCE 

Some invasive plant treatments can have positive effects on floodplains and streambanks when 

infestations of invasive plants on valley bottom areas are removed. Valley-bottom infestations 

often encroach on floodplains where road-related and recreational activities have led to the 

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establishment of invasive plant populations. Removal of such infestations is expected to benefit 

aquatic and terrestrial communities in the long term by increasing floodplain area available for 

nutrient, sediment and large wood storage, and flood flow refugia. There is no risk of negatively 

impacting channel condition and dynamics as a result of treating invasive plants. 

Pathway: Habitat Access 

Indicator: Physical Barriers 

PCE Crosswalk: Migration habitat PCE 

Invasive plant treatments will not create physical barriers or otherwise degrade access to aquatic 

habitat. 

Pathway: Habitat Elements 

Indicator: Substrate/Sediment 

PCE Crosswalk: Spawning, Rearing habitat PCEs 

Invasive plant treatments are not expected to affect substrate composition. All PDFs that 

minimize sediment would be implemented, such as no heavy equipment within riparian areas. 

These practices would reduce, but not eliminate sediment. Some sediment may enter stream 

channels as a result of extensive manual labor and could result in exposed soils. The amount of 

sediment that enters a stream is expected to be small, infrequent, of short duration, and at a 

localized level. Localized increases in fine sediment in gravels or along channel margins may be 

seen at the immediate treatment site. However, substrate quality would not decrease over time 

because treatment of invasive plants would not result in a chronic sediment source. Diffuse and 

spotted knapweed are found along many streams in the Forest. 

Lacey et al. (1989) reported higher runoff and sediment yield on sites dominated by knapweed 

versus sites dominated by native grasses. Therefore, treatment of invasive plants and the 

subsequent reestablishment of native vegetation would provide long-term benefit to sediment 

levels in aquatic habitat. 

Pathway: Habitat Elements 

Indicator: Large Woody Debris, and Pool Area, Quality and Frequency 

PCE Crosswalk: Spawning habitat PCE 

Treatment of invasive plants would not impact pool area, quality and frequency. Treatment of 

invasive plants in RHCAs would not impact current wood debris in streams. The PDF that 

establishes a 100 ft buffer for broadcast applications provides protection to the recruitment of 

conifer seedlings within riparian areas which will sustain channel and habitat features in the 

future. Controlling invasive plants would allow for reestablishment of native vegetation, 

allowing riparian stands over time to develop larger recruitment trees, increasing the size and 

quantity of inchannel debris. The use of spot-spray applications of aquatic glyphosate and 

aquatic imazapyr may result in some minor non-target vegetation impact because of drift. 

However, the amount necessary to drift into the entire riparian area and kill trees is not possible 

with spot-spray applications. 

Pathway: Flow/Hydrology 

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Indicator: Change in Peak/Base Flows 

PCE Crosswalk: Spawning, Rearing, Migration habitat PCEs 

None of the treatments are extensive enough under any alternative to effect peak flows, low 

flows or water yield. Methods used for treatment would have negligible effect on water 

infiltration into soil and associated surface runoff. No 5th field watershed has more than 7 

percent proposed for treatment and most have less than one percent. This amount is much too 

small an area to show effects to flows from treatment. 

Cumulative Effects 

Cumulative effects include the effects of future State, tribal, local or private actions that are 

reasonably certain to occur within the action area of the Federal action subject to consultations 

(50 CFR 402.02). The “reasonably certain to occur” clause is a key factor in assessing and 

applying cumulative effects and indicates, for example, actions that are permitted, imminent, 

have an obligation of venture, or have initiated contracts (U.S. Fish and Wildlife Service and 

National Marine Fisheries Service, 1998). Past and present impacts of non-Federal actions are 

part of the environmental baseline. 

Only the land and roads within the National Forest System would be treated in the action 

alternatives proposed by this EIS. The Forest, however, is intermingled with other federal, state, 

county, and private ownerships. Management activities and actions on neighboring lands may 

contribute to spread or containment of invasive plants on National Forest system lands, and vice 

versa. Wallowa County has an active program to treat invasive plants and require private 

property owners to control invasive plants on their property. The largest acreage to be treated on 

private land is next to the common bugloss site (5500acres). 

Herbicides are commonly applied on lands other than National Forest System lands for a variety 

of agricultural and landscaping purposes. Herbicide use occurs on tribal lands, state and county 

lands, private forestry lands, rangelands, utility corridors, road rights-of-way, and private 

property. 

Only two watersheds have more than 1 percent of the watershed within chemical treatment areas. 

They are the Middle Imnaha River and the Snake River/Temperance Creek Watershed. Most of 

the treatment in the Middle Imnaha River is the common bugloss site that would be treated the 

same year the private land would be treated. 

If the whole acreage at the common bugloss site was treated in one year, over 12 percent of the 

watershed would be treated. However it is estimated by Forest personnel that less than 1500 

acres scattered across the larger treatment area would be treated at the bugloss site on Forest 

land. If the 1500 acres was doubled to take private land into account 3.4 percent of the watershed 

would be treated. Private landowners would use methylsulfuron methyl aerially as their first 

choice to treat acres infested with bugloss. The Forest would use methysulfuron methyl with 

ground based methods as the first choice of treatment. This is a highly effective herbicide with 

low application rates and a low toxicity to fish. Given the low application rates (typical rate of 

0.03 lbs/acre), low toxicity value and scattered nature of the treatments, it is unlikely to have 

cumulative effects to the watershed 

For the Snake River/Temperance Creek Watershed the treatment acres include hand treatment 

along the Snake River as well as aerial treatment in the uplands. PDFs were developed to 

minimize risk of herbicide application to water at treatment sites. Given the PDFs as well as the 

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scattered distribution of the treatments and the low rainfall available to transport herbicide off 

site, it is unlikely that treatments would have a cumulative effect for this watershed (Thornton 

2007). 

Even though it is unlikely that effects from proposed treatments would approach a threshold of 

concern, given the results of the GLEAMS-Driver modeling and the possibility that picloram 

may be used in concentrations that could affect downstream fish the Proposed Action may 

contribute to significant cumulative effects. 

Alternative C – No Broadcast within Riparian Habitat Conservation Areas 

(RHCAs) 

Direct and Indirect Effects 

The effects from treatments under this alternative are analogous to those of Alternative B except 

no broadcast would occur within RHCAs. Alternative B proposes 3,104 acres of broadcast 

within the RHCAs. Potentially these areas would be treated with mechanical or manual methods 

under Alternative C. Not broadcasting herbicides within RHCAs would reduce the potential for 

contamination of water; however, utilizing manual and mechanical methods within these 

treatment areas could increase risk of sediment delivery to streams. As the main methods are 

mowing and cutting or pulling weeds, and the areas to be treated are between 100 and 300 feet 

from a stream, effects from manual and mechanical treatment on streams would be negligible. 

These areas could also potentially be treated with herbicides using spot or hand methods of 

application. Spot spraying is more targeted to specific plants; therefore less non-target vegetation 

would be removed resulting in more groundcover. Retaining as much groundcover as possible 

would lower the potential for sediment delivery to streams. Spot spraying also reduces the 

amount of herbicide that comes in contact with soil resulting in less herbicide available for 

runoff into streams. 

Cumulative Effects 

The cumulative effects are the same as those discussed under Alternative B 

Alternative D – No Aerial Application of Herbicide 

Direct and Indirect Effects 

The effects from treatments under this alternative are analogous to those of Alternative B except 

no aerial application of herbicides would occur. Alternative B proposes 875 acres of aerial 

application. These acres would need to be treated by other methods. Under this alternative there 

would be a lower risk of herbicide contaminating water due to drift, however many of these 

areas are in remote locations where manual and mechanical treatments would not be feasible due 

to cost or safety. In those areas no treatment would occur and invasive plants would be allowed 

to spread. Since the adverse affects attributed to Alternative B are from the use of picloram in 

aerial treatments and Alternative D does not propose the use of aerial applications, this 

alternative may affect, but is not likely to adversely affect listed species. 

Cumulative Effects 

The cumulative effects for non-aerial treatments are the same as discussed under Alternative B. 

Since no aerial treatments are proposed for Alternative D, it is unlikely that Alternative D would 

contribute to significant cumulative effects. 

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Effects Determinations 

The effects determinations below are based on effects that have a reasonable probability of 

occurring due to invasive plant treatments within the action area, and conducted according to the 

Standards in the R6 FEIS and Project Design Features in the action alternatives. 

The potential for sublethal effects to fish from herbicide exposure was considered and addressed 

in the R6 2005 FEIS. Because there is insufficient data on the herbicides included in the action 

alternatives to conclude that there may or may not be sublethal effects, the 1/20th of the NOEC 

values were used in the SERA risk assessments to account for the potential of sub-lethal effects 

from those herbicides that could potentially reach streams with listed and sensitive fish. The lack 

of information on sub-lethal effects did not affect our ability to make determinations of effects to 

listed species because of the degree of risk for herbicides coming in contact with water at levels 

of concern. 

Effects from the action alternatives are expected to vary because of proximity to water, species 

occurrence, life stage present, and herbicide properties. Some treatments completely outside of 

the aquatic influence zone with no mechanism for herbicide delivery fall under a “no effect” 

determination. However, spot treatments up to the water’s edge and along intermittent streams 

have the potential to deliver aquatic glyphosate and aquatic imazapyr to water. These treatments 

are not likely to adversely affect fish and their habitat because treatments have been designed to 

minimize introduction of herbicide into aquatic habitats as well as avoid substantial amounts of 

sedimentation. Toxic levels of herbicides are unlikely to enter streams or lakes due to the ability 

to alter application methods and distance from water, timing, active ingredients and 

formulations, and other project design features. Effects to immediate streamside cover cannot be 

avoided and there may be small droplets of aquatic glyphosate and aquatic imazapyr coming in 

contact with water. For example, treatment of riparian species growing along the streambank 

(above ordinary high water) may result in insignificant amounts of aquatic glyphosate and 

aquatic imazapyr in water 24 hours after treatment. Any treatment method, could introduce 

minor amounts of sediment and/or herbicide into adjoining waters as result of spot/hand 

applications, manual/mechanical plant removal, stream bank trampling, and planting. Effects 

from these activities are expected to be insignificant and therefore, discountable. 

Aerial treatments proposed within Hells Canyon may include picloram. Modeling with 

GLEAMS-Driver inicates the use of picloram at the maximum concentration may reach a hazard 

quotient (HQ) greater than 1. Although herbicide concentrations would dilute downstream, it is 

unknown how much. Therefore, unless aerial treatments are restricted to Clopyralid, or picloram 

is used at its lowest concentration, the project may have adverse effects to steelhead, salmon and 

bull trout populations directly downstream of the treatment site. 

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Herbicide Treatment, Non-Herbicide Treatment and EDRR 

Table 60-Effects Determination for Herbicide Treatment, Non-Herbicide Treatment and EDRR 

Species Status Alternative A Alternative B Alternative C Alternative D 

Snake River 

Basin Steelhead Threatened MA-NLAA MA-LAA MA-LAA MA-NLAA 

Middle Columbia 

River Steelhead Threatened MA-NLAA MA-LAA MA-LAA MA-NLAA 

Snake River 

Spring/Summer 

Run Chinook 

Salmon 

Threatened MA-NLAA MA-LAA MA-LAA MA-NLAA 

Snake River Fall 

Run Chinook 

Salmon 

Threatened MA-NLAA MA-LAA MA-LAA MA-NLAA 

Columbia River 

Bull Trout Threatened MA-NLAA MA-LAA MA-LAA MA-NLAA 

Snake River 

Sockeye Salmon Endangered MA-NLAA MA-LAA MA-LAA MA-NLAA 

Bliss Rapids Snail Threatened MA-NLAA MA-NLAA MA-NLAA MA-NLAA 

Redband Trout Sensitive MII MII MII MII 

Westslope 

Cutthroat Trout Sensitive MII MII MII MII 

NE=No Effect; MA-NLAA = May Affect, Not Likely to Adversely Affect; MA-LAA = May Affect, Likely to Adversely Affect 

NI = No Impact; MII = May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, 

nor cause a trend toward federal listing; LRLV = likely to result in a loss of viability in the planning area, or in a trend 

toward federal listing. 

Rationale for Determination 

• Assumptions used for analyzing the worst case situations on W-W National Forest are 

beyond the Proposed Action (PDFs and buffers) and ground conditions on W-W National 

Forest, thus grossly overestimating potential exposures. 

• Invasive plant treatments (herbicide and non-herbicide) and site preparation for revegetation 

can result in insignificant amounts of localized sediment due to trampling and removal of 

plant roots. 

• Some herbicides could be introduced into the water indirectly from spot-spray and may 

impact aquatic plants at the immediate site. However, it is unlikely that a significant amount 

of aquatic plants would be adversely affected to the degree of impacting an entire food chain 

in the aquatic ecosystem and indirectly harming a fish. 

• Within the aquatic influence zone, aquatic formulations of glyphosate or imazapyr would be 

spot sprayed on plants, and could be indirectly delivered to water. However, spot 

applications reduce the potential to reach any expected exposure concentration of concern. 

• Invasive plant treatments could temporarily reduce streamside vegetation (albeit non-native 

and low quality) that provides cover for fish. However, it is unlikely that removal of 

invasive plants providing cover along streams containing federally listed fish would lead to 

significant losses of cover. Removal would be localized (plants surrounding target plant) 

and overhead story would still provide cover via shade and future input of woody material. 

• The potential for non-aquatic formulations of herbicide coming in contact with water is very 

low under the Proposed Action. 

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• Biological controls will not influence any of the pathways for effects to federally listed fish 

or their habitat. 

• Project design features significantly reduce the potential for herbicides coming in contact 

with water where there are federally listed fish present. If any were to come in contact with 

water the amounts would be far below levels of concern and potentially not at detectable 

levels. 

• Localized effects from invasive plant treatments will be insignificant and discountable, yet 

still allow for restoration of important native riparian habitat. 

• Water flow in streams quickly dilutes herbicide, reducing the potential for herbicide 

exposure, and dissipates any sedimentation as a result of invasive plant treatments and 

revegetation. 

• Transitory water quality impact, if any, would be limited to the point of contact with water 

and not an entire stream reach. 

• No emergent vegetation is proposed for treatment. 

• EDRR does not include aerial herbicide application. 

• Exposure of Bliss rapids snail to herbicide or sediment is likely to be very localized and 

occur in a short pulse, due to the large volume and rapid flow of their habitat which would 

rapidly dilute herbicide and move sediment. 

• Aerial treatments proposed within Hells Canyon may include picloram. Modelling with 

GLEAMS-Driver inicates the use of picloram at the maximum concentration may reach a 

hazard quotient (HQ) greater than 1. Although herbicide concentrations would dilute 

downstream, it is unknown how much. Therefore, unless aerial treatments are restricted to 

clopyralid, or picloram is used at its lowest concentration, Alternatives B and C may have 

adverse effects to steelhead, salmon and bull trout populations directly downstream of the 

treatment site. 

Determination for Critical Habitat 

Under existing Forest Service standards and guidelines, projects implemented under the 

Proposed Action cannot have a negative impact, in the long term, on riparian-dependent 

resources or ecological processes in RHCAs at the watershed scale. Each project must maintain 

or restore the physical and biological processes required by riparian dependent-resources at the 

watershed scale or broader to comply with PACFISH and INFISH. 

The potential, site-specific effects from implementation of the action alternatives on critical 

habitat was evaluated when addressing effects to Riparian Condition and Water Quality, Lakes, 

Wetland, and Floodplains (in Hydrology section). 

The implementation of PDFs in the Proposed Action will reduce adverse affects to listed species’ 

habitats during herbicide and non-herbicide treatment methods to a minimum, as discussed 

below and throughout this DEIS. 

Water Quality Indicators: Changes in water temperature resulting from herbicide use to 

control invasive plants would be negligible to non-existent. Invasive plants provide little to no 

shade to streams, and the risk for adverse affects to native vegetation is low with backpack or 

hand operated sprayers. Removal of solid vegetation stands by herbicide treatment may result in 

short-term, insignificant increases in surface erosion that will diminish as vegetation reestablishes treated areas. No large-scale changes in land cover conversions or stand structure 

(e.g. timber to grass) will result from chemical invasive plant control as proposed in this project. 

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Herbicide treatment of invasive plants by broadcast and spot spraying is expected to result in a 

low risk of water contamination because of standards in the R6 2005 FEIS, with additional PDFs 

in the Proposed Action. Site-specific soil characteristics, proximity to surface water and local 

water table depth were used to determine herbicide formulation, size of buffers, and application 

method and timing. Only those herbicides registered for aquatic use are allowed near streams or 

surface water with limitation on application and timing. However, the use of picloram in aerial 

treatments may result in concentrations of herbicide that may affect listed species and their 

critical habitat. 

Habitat Access Indicators: Implementation of the Proposed Action would not create physical 

barriers to listed aquatic species. 

Habitat Element Indicators: Implementation of the Proposed Action would not significantly 

affect substrate, large woody debris, pool quality, off-channel habitat, and refugia at the 

watershed scale. Large trees that provide shade and large wood would not be impacted by the 

use of herbicides as proposed under the Proposed Action. 

Channel Condition Indicators: Implementation of the Proposed Action would result in 

reduction of invasive plants within riparian areas and along streambanks. Any impacts to 

streambank stability are expected to be localized, of low intensity and duration, and not 

significantly affecting fish habitat. Reduction of invasive plants along streambanks and riparian 

areas will benefit native plant species and result in improved streambank stability and riparian 

condition in the long-term. 

Flow/Hydrology Indicators: Implementation of the Proposed Action is expected to result in no 

measurable effect to peak/base flow or water yield of watersheds. 

Watershed Condition Indicators: No new roads or watershed scale disturbances are expected 

to result from the use of herbicides to treat invasive plants. 

Reduction of invasive plants in riparian areas, wetlands, and streams and subsequent increases in 

desirable vegetation will result in improved watershed conditions. The effect determination for 

proposed critical habitat of Columbia River Bull Trout, Snake River Spring/Summer Run 

Chinook Salmon, Snake River Fall Run Chinook Salmon, Snake River Basin Steelhead, and 

Middle Columbia River Steelhead is “may affect, likely to adversely affect” for Alternatives 

B and C, and “may affect, not likely to adversely affect” for Alternatives A and D. These 

determinations are based on potential effects to the primary constituent elements, including the 

following: 

• Although, invasive plant treatment projects may be conducted in close proximity to 

designated critical habitat, the potential to impact most of the PCEs at significant levels is 

very low. However, the use of picloram in aerial treatments in Alternatives B and C may 

increase the chemical contamination of waters within designated critical habitat. 

• Invasive plant treatment projects are not expected to create sediment that may adversely 

affect embeddedness and availability of suitable substrate in localized areas. 

Invasive plant treatments are not expected to create significant amounts of sediment leading to 

direct or indirect adverse effects to habitat. Any increase in sediment would be localized given 

that herbicides would be used as opposed to heavy machinery. Manual and mechanical removal 

is not expected to create measurable amounts of sediment. Invasive plant treatments conducted 

in critical habitat would help to restore or maintain the native riparian vegetation that is essential 

to maintaining the primary constituent elements of the critical habitat in the long-term. 

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Conclusion 

The R6 2005 FEIS and Fisheries Biological Assessment analyzed the risk of herbicide use to 

aquatic plants, algae, macroinvertebrates and fish, including listed species. The analysis relied on 

SERA Risk Assessments (1997a, 1997b, 1999a, 1999b, 2001a, 2001c, 2003a, 2003b, 2003c, 

2003d, 2003e, 2003f) to determine effects to fish and other aquatic organisms if herbicide is 

delivered to streams and other water bodies. The Project Design Features (PDFs) listed in 

Chapter 1 were developed to avoid scenarios of concern to fish species of local interest 

considering the R6 2005 FEIS analysis and local conditions. These restrictions go beyond label 

requirements by limiting the amount and type of herbicide that may be used adjacent to 

waterbodies or along roads with high potential to deliver herbicide to streams and other water 

bodies. The only herbicides proposed for use where there is a likelihood of indirect delivery to 

water are aquatic formulations of glyphosate, imazapyr, and triclopyr. Refer to Table 7, Table 8, 

and Table 9 for buffers and acceptable use of herbicides adjacent to waterbodies. For example, 

spot applications within 15 feet of streams are limited to the aquatic formulations of glyphosate 

and imazapyr. 

Herbicides can disappear from treated water by dilution, adsorption to bottom sediments, 

volatilization, and absorption by plants and animals or by dissipation. Dissipation refers to the 

breaking down of an herbicide into simpler chemical compounds. Herbicides can dissipate by 

photolysis (broken down by light), hydrolysis, microbial degradation, or metabolism by plants 

and animals. Both dissipation and disappearance are important considerations to the fate of 

herbicides in the environment because even if dissipation is slow, disappearance due to processes 

such as adsorption to bottom sediments makes a herbicide biologically unavailable. For 

example, glyphosate is not applied directly to water for weed control, but when it does enter the 

water it is bound tightly to dissolved and suspended particles and to bottom sediments and 

becomes inactive, posing a very low risk to fish, the aquatic food web, and critical habitat. 

The likelihood that fish or other aquatic organisms may be impacted under the worst-case 

scenarios analyzed for the Proposed Action is very low in most cases. Any use of herbicide in 

Aquatic Influence Zones or along roads with high potential to deliver herbicides is associated 

with some risk; however the degree of risk is low given the Project Design Features for the 

Proposed Action. The use of aerial treatment methods utilizing picloram does increase risk of 

exposure for listed fish species. Although listed fish and critical habitat are more than 1.5 miles 

downstream of the proposed treatment sites, the dilution factor is unknown; therefore the 

exposure concentration is unknown. 

Adverse effects to fish under the worst case scenarios for broadcast and spot treatments are not 

likely to occur because any herbicide or sediment that came in contact with water, regardless of 

the amount, would be quickly washed downstream and diluted. Based on the R6 2005 FEIS, the 

potential to reach levels of concern for invertebrates and aquatic plants is expected to be low and 

herbicides coming in contact with water as a result of the Proposed Action would more than 

likely be insignificant. Therefore, impacts to the aquatic food web are not likely and therefore, 

indirect effects to fish are discountable. 

 Project Design Features minimize and avoid concentrations of herbicide exceeding a level of 

concern coming in contact with fish and other aquatic organisms because: 

• Established buffers along perennial and intermittent streams greatly reduce the potential for 

drift of herbicide to surface waters; 

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• No broadcasting of herbicides are allowed along roads that have a high potential for 

herbicide delivery, thereby significantly reducing the potential amount of herbicides 

delivered to streams via road-side ditches; 

• Broadcast spray of triclopyr is prohibited, thereby greatly reducing risk of triclopyr coming 

in contact with surface waters; 

• With the eliminated potential for concern for increased risk to aquatic species, the potential 

for effects to the aquatic food web is greatly reduced. 

The potential for herbicides to enter streams in concentrations that are near or exceed thresholds 

of concern for federally listed fish and impacting aquatic ecosystems is very low for broadcast 

and spot treatments. Therefore, the degree of risk for these treatment methods is low and 

discountable. However, aerial treatment may result in some degree of risk. Whether known sites 

or new sites are treated following the Proposed Action, it is unlikely that the Forest will reach the 

most ambitious conceivable treatment scenario identified in the Proposed Action. In addition, the 

PDFs are likely to minimize or eliminate the risk of adverse affects. 

Magnuson-Stevens Fishery Conservation and Management Act 

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (Public Law 104-267), established procedures designed to 

identify, conserve, and enhance essential fish habitat (EFH) for those species regulated under a 

Federal fisheries management plan. 

Essential Fish Habitat is defined in the Act as “those waters and substrate necessary to fish for 

spawning, breeding, feeding, or growth to maturity.” Essential Fish Habitat includes all 

freshwater streams accessible to anadromous fish (Chinook, coho, and pink salmon), marine 

waters, and inter-tidal habitats. The objective of this EFH assessment is to determine whether or 

not the Proposed Action “may adversely affect” designated EFH for relevant commercially, 

federally-managed fisheries species within the Proposed Action area. 

Wallowa-Whitman National Forest may incorporate an EFH assessment into the analysis for this 

EIS pursuant to 40 CFR section 1500. NEPA and ESA documents prepared by the WallowaWhitman National Forest should contain sufficient information to satisfy the requirements in 50 

CFR 600.920(g) for EFH assessments and must clearly be identified as an EFH assessment. 

Identification of EFH 

Pursuant to the MSA the Pacific Fisheries Management Council (PFMC) has designated EFH for 

federally managed fisheries within the waters of Washington, Oregon, and California. 

Designated EFH for groundfish and coastal pelagic species encompasses all waters from the 

mean high water line, and upriver extent of saltwater intrusion in river mouths, along the coasts 

of Washington, Oregon and California, seaward to the boundary of the U.S. exclusive economic 

zone (370.4 km) (PFMC, 2004, 1998). 

Freshwater EFH for Pacific salmon includes all those streams, lakes, ponds, wetlands, and other 

water bodies currently, or historically accessible to salmon in Washington, Oregon, Idaho, and 

California, except areas upstream of certain impassable artificial barriers (as identified by the 

PFMC, 2003), and longstanding, naturally-impassable barriers (i.e., natural waterfalls in 

existence for several hundred years) (PFMC, 2003). 

In estuarine and marine areas, designated salmon EFH extends from the nearshore and tidal 

submerged environments within state territorial waters out to the full extent of the exclusive 

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economic zone (370.4 km) offshore of Washington, Oregon, and California north of Point 

Conception to the Canadian border (PFMC, 2003). 

Detailed descriptions and identifications of EFH are contained in the fishery management plans 

for groundfish (PFMC 2004), coastal pelagic species (PFMC 1998), and Pacific salmon (PFMC, 

2003). 

The geographic extent of EFH on Wallowa-Whitman National Forest is specifically defined as 

all currently viable waters and most of the habitat historically accessible to Chinook salmon 

within the watersheds identified in Table 10. Salmon EFH excludes areas upstream of 

longstanding naturally impassible barriers (i.e., natural waterfalls in existence for several 

hundred years). Salmon EFH includes aquatic areas above all artificial barriers. 

Effects of the Proposed Action 

The MSA defines adverse effects as any impact, which reduces the quality and/or quantity of 

Essential Fish Habitat. Non-herbicide treatment methods would have very localized effects to 

soil at the project scale. Herbicide treatment methods may result in insignificant amounts of 

herbicides coming in contact with water as a result of drift and runoff from roadside ditches. 

Effects from both non-herbicide and herbicide treatment methods would not impact those waters 

necessary for spawning, breeding, feeding, or growth to maturity because there is no treatment of 

emergent or submerged invasive plants and the predicted amount of herbicide coming in contact 

with water is well below levels of concern. As discussed above in the Effects Analysis section 

Chinook salmon may be adversely affected because: 

• The quantity of EFH will not be reduced 

• The quality of EFH may be degraded from aerial application of picloram 

Conservation measures and management alternatives are listed in the Pacific Coast Salmonid 

Plan that help conserve and enhance salmon EFH. These measures should be applied unless 

more specific or different measures based on the best and most current scientific information are 

developed prior to, or during, the EFH consultation process and communicated to the appropriate 

agency. The PDFs in the Proposed Action are more detailed measures and should take the place 

of ones listed in the Pacific Coast Salmonid Plan. However, there may be conservation measures 

that are different and complement the PDFs. 

As described in detail in the Effects Analysis section of this BE, the exclusion of heavy 

machinery from the Proposed Action will not result in impacts to sediment and cover. The use of 

non-herbicide methods as described in the Proposed Action is not expected to reduce the quality 

and/or quantity of EFH. The use of herbicide treatments as described in the Proposed Action and 

analyzed in the Biological Evaluation for this project may reduce the quality and/or quantity of 

EFH. 

Conclusion 

The Proposed Action may adversely affect EFH for Pacific salmon species listed in Table 61. 

The Proposed Action is expected to improve long-term essential fish habitat conditions in 

locations currently infested with invasive plants. 

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Table 61-Potential effects to commercially important fish species under the proposed action 

Species Magnuson-Stevens EFH Determination 

Snake River Spring/Summer Run Chinook Salmon Adverse Effect 

Snake River Fall Run Chinook Salmon Adverse Effect 

3.6 Recreation Resources 

3.6.1 Introduction 

This report will describe the affected environment and analyze the effects of the proposed project 

and alternatives on the recreation resource and congressionally designated areas. The analysis 

will evaluate the impacts of invasive plant treatment methods on recreation relating to the 

general forest area, developed recreation sites and trails. Congressionally designated areas 

include wild and scenic rivers (WSR), wilderness, and national recreation areas (NRA). The 

effects on the outstandingly remarkable values, water quality and free flowing characteristics of 

designated and eligible wild and scenic rivers, and the effects on wilderness character will be 

evaluated; effects on recreation resource values of the NRA will be addressed. Invasive plant 

treatment methods are described in detail in Chapter 2 of the Draft Environmental Impact 

Statement (DEIS). 

Recreational activities are influenced by and have influence on the rate and degree of invasive 

plant spread. Recreationists move in and out of the forest setting, inadvertently transporting 

seeds and propagating plant parts. Heavy use areas such as trailheads, parking lots and portions 

of riparian areas can be denuded of their native vegetation from dispersed use, creating prime 

environment for invasive plants to become established. Recreation users can also unknowingly 

spread invasive plant seeds and propagating parts across and between landscapes. The most 

likely vectors of invasive plant spread are roads, trails and riparian corridors (R6 2005 FEIS). 

Invasive plants can detract from the desirability of using recreation sites and participating in 

certain recreational activities. For example, stiff plant stalks, thorns, sharp bristles, and allergies 

created by invasive plants can prevent humans from walking, sitting, setting up camp, and 

finding a place to fish or tie up a raft (R6 2005 FEIS). 

According to the National Visitor Use Monitoring (NVUM) study, recreation use on the 

Wallowa-Whitman National Forest for fiscal year 2003 was estimated at 565,681 visits (USDA 

Forest Service 2004a). The top primary activities according to the NVUM study conducted on 

the Wallowa-Whitman were viewing wildlife, viewing natural features, hike/walking, relaxing, 

driving for pleasure and hunting. Overall use on the forest is considered light to moderate. Big 

game hunting is very popular forest-wide. Recreation use associated with hunting such as offhighway vehicle (OHV) use, dispersed camping, wilderness and back country access using pack 

stock all increase substantially during the big game hunting seasons. 

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3.6.2 Affected Environment 

Congressionally Designated Areas 

National Recreation Areas (NRA) 

There are approximately 7,350 acres of invasive plants identified within the Hells Canyon 

National Recreation Area (HCNRA), not including wilderness or WSR corridor acres. Invasive 

weeds are found primarily along forest roads within the HCNRA, near popular destination sites 

such as Pittsburg Landing, dispersed sites and along trails. 

Dispersed recreation sites are typically along roads and have developed due to repeated use by 

recreationists. These site types are not usually inventoried, signed, or have any other use 

controls associated with them other than access. Repeated use by recreationists can create the 

conditions that favor invasive plant establishment and spread. Overall incidence of summer 

dispersed camping is low to moderate. Dispersed camping during the hunting season would be 

considered high with camps occurring along many roads. Many hunter campsites have been used 

by the same hunting group year after year. 

The Wallowa-Whitman National Forest Access and Travel Management Plan closed the HCNRA 

yearlong to motorized vehicles except where specifically provided for on designated roads and in 

certain areas. All other areas in the HCNRA contain travel restrictions or are closed yearlong. 

Motorized driving in these areas is limited to a 300-foot corridor on each side of designated open 

routes for dispersed camping. Some of these areas further prohibit motorized access with 

seasonal road closures during the fall big-game hunting seasons to reduce wildlife disturbance, 

provide non-motorized hunting, and protect fragile soils (USDA Forest Service 2003c). Invasive 

plant spread associated with motorized use would be limited to roads open to such use. 

Non-motorized trail types include pack and saddle trails and hiking trails. Pack and saddle trails 

and the feed, straw and disturbance associated with such use can facilitate the establishment and 

spread of invasive plants. Mountain bikes are commonly used on trails outside wilderness. 

Mountain bikes can be vectors of invasive plant spread. 

There is an infestation of common bugloss that begins near Winston Creek and extends 

downstream to High Camp Creek along the Imnaha WSR. This invasive plant area includes 

approximately 5,813 acres and encompasses 12.5 miles of the Imnaha WSR river corridor. 

Private lands adjacent to this site are also infested. The level of infestation within these areas is 

variable with the most heavily infested areas occurring in the river bottoms and meadows and 

decreasing in elevational gain along the terraced areas. 

Wilderness 

There are four designated Wilderness areas on the Wallowa-Whitman National Forest; Hells 

Canyon, Eagle Cap, Monument Rock, and the Baldy Creek Unit of North Fork John Day. 

Invasive weeds are present in Hells Canyon, Eagle Cap and Monument Rock Wilderness in 

varying degrees. There are no weeds present in the North Fork John Day Baldy Creek Unit at 

this time. Invasive plants within wilderness are typically found at trailheads, along trails, 

riparian areas and near popular dispersed camping sites. Invasive plant infestations within 

wilderness are minor compared to the general forest acres. Infestations outside wilderness 

boundaries have the potential to spread into wilderness and threaten wilderness values. 

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Invasive plants have adverse effects on wilderness character. They can disrupt natural processes. 

Invasive plants may alter natural plant communities, interact in unknown ways with native 

wildlife species, and alter ecological processes such as plant community dynamics and 

disturbance processes such as fire. This potential change in ecological condition can threaten the 

natural integrity of the wilderness and the values for which it was designated. The presence of 

invasive weeds is typically a result of human use. Weed infestations are typically associated with 

human activities such as grazing, pack stock use, trails; activities that create disturbed conditions 

that allow weeds to establish. 

The R6 2005 FEIS identified wilderness as an area of special concern and it is in the highest 

priority treatment category. The Wallowa-Whitman LRMP as amended by the R6 2005 ROD 

approves herbicide use as a potential tool in designated wilderness throughout the region. 

The R6 2005 ROD also amended all forest plans in the region to require use of certified weedfree feed for all pack and saddle stock used on National Forest System lands. As of January 

2007, certified weed-free feed or pelletized feed is required in all wilderness and wilderness 

trailheads on National Forest System lands in the Pacific Northwest Region. This will help 

prevent further introduction of invasive weeds into the wilderness through stock feed. This 

requirement is being phased in to allow recreationists time to adjust to the change and due to 

lack of available weed-free hay certification programs in Washington and a limited program in 

Oregon. 

Hells Canyon Wilderness Area 

Hells Canyon Wilderness (HCW) located in parts of Oregon and Idaho was classified wilderness 

with the establishment of the Hells Canyon National Recreation Area in 1975. Additional acres 

were added as part of the Oregon Wilderness Act of 1984 resulting in a total of 214,994 

wilderness acres. The Hells Canyon National Recreation Area Comprehensive Management 

Plan (CMP) provides direction for management of the Hells Canyon Wilderness area. 

HCW is a diverse area with elevations that range from 1,400 to 9300 ft. It is characterized by 

steep rugged terrain with slopes in excess of 60 percent. The dominant vegetation is native 

bunchgrasses and shrubs with timbered drainages. The Snake River WSR corridor extends 

approximately 1⁄4 mile inland to the wilderness boundary. From here the terrain rises sharply in 

elevation and consists of numerous rock rims. Mid slope, approximately 3000 ft., the country 

levels out into grassland benches. This is where the majority of historic ranching is evident. The 

slope continues rising sharply from this point to the canyon ridgetop. The area offers year round 

recreational opportunities at the lower elevations, however access is limited. The majority of use 

is located within the adjacent Wild and Scenic Snake River corridor. 

The Oregon side of HCW consists of over 200 miles of trail. The trails follow the topography of 

the land and the majority of the trails were originally established during the homestead era. Due 

to limited visitation the majority of these trails are not maintained. The area offers limited access 

which is logistically challenging. There are no mountain lakes or sub alpine vegetation that 

draws the typical wilderness visitor. The majority of use occurs during fall hunting season. 

There is also spring time use since the area opens up prior to other alpine wilderness areas. 

Spring use consists of trailhead camps with day trips into the wilderness; and an occasional pack 

trip traveling throughout a section of the wilderness. It is common to spend a week in HCW and 

not encounter other visitors. 

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There are approximately 795 acres of invasive plant infestations identified within the Hells 

Canyon Wilderness. The largest concentrations of invasive plants identified within the 

wilderness are located near Lookout Creek and Lone Pine Creek, approximately 10 miles 

downstream from Pittsburg Landing. These infestation sites consist of several large blocks 

which occur on very steep terrain. Invasive plants are also located along Forest Trails # 1727, 

1774, 1706, 1734, 1707, 1735, 1726, 1751 and 1778. 

Eagle Cap Wilderness 

The Eagle Cap Wilderness is the most heavily used wilderness in northeastern Oregon. There 

are over 47 trailheads and 500 miles of trail. 

There are approximately 182 acres of invasive plants identified within the Eagle Cap wilderness. 

Invasive plant sites are primarily located along the Minam River and Forest Trails # 1673, 1901 

and 1653. 

Monument Rock Wilderness Area 

The Monument Rock Wilderness is the smallest wilderness on the forest. There are two acres of 

invasive plants identified within this wilderness. These acres are located near the Table Rock 

Trailhead. Invasive weed sites have been identified north of the wilderness boundary, outside the 

wilderness. 

Table 62-Wilderness areas and acres of invasive plants 

Wilderness Name 

and Acres 

Acres of 

Invasive Plants 

Hells Canyon 214,994 795 

Eagle Cap 350,461 182 

Monument Rock 7,030 2 

Total Acres 586,779 979 

 Wild and Scenic Rivers 

Segments of the Eagle Creek, Imnaha, Joseph Creek, Lostine River, Minam River, North Powder 

River and Snake River have been designated as part of the National Wild and Scenic River 

System (national system). Big Sheep Creek, East Eagle Creek, Swamp Creek and the Upper 

Grande Ronde River are identified as eligible rivers and streams. The river management corridor 

typically extends one quarter mile from the riverbank on each side of the designated segment or 

official and eligible rivers. The presence of invasive species along the river corridor can detract 

from the aesthetic and recreational opportunities, and impact the values for which the river has 

been designated. Acres in national system and eligible river corridors that occur in wilderness 

would be subject to laws, standards and project design features pertaining to wilderness. The 

following table lists each river that has been impacted by invasive plants and the outstandingly 

remarkable values for which it was designated. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 63-Wild and Scenic Rivers on the W-W National Forest and their outstandingly remarkable 

values 

Wild and Scenic Rivers on the Wallowa-Whitman National Forest 

River Name 

Wild 

(mi.) 

Scenic 

(mi.) 

Recreation 

(mi.) Outstandingly Remarkable Values 

Eagle Creek 4.0 6.0 17.0 Scenery, Recreation, Geology/Paleontology, 

Fisheries, Historic Cultural Resources 

Grande Ronde 

River 17.4 1.5 Scenery, Recreation, Fisheries, Wildlife 

Imnaha River 15.0 4.0 58 

Scenery, Recreation, Fisheries, Wildlife, 

Historic/Prehistoric, Vegetation/botanical, and 

Traditional values/Lifestyle adaptation 

Joseph Creek 8.6 Scenery, Recreation, Geologic, Fish And Water 

Quality, Wildlife, Cultural Resources 

Lostine River 5.0 11.0 Scenery, Recreation, Fisheries, Wildlife, 

Vegetation/Botany 

Minam River 39.0 Scenery, Recreation, Geology, Fisheries, and 

Wildlife 

Snake River 32.5 34.4 Scenery, Recreation, Historic/Prehistoric Cultural 

Resources, Botanical, Wildlife, Geology 

North Fork John 

Day 4.0 Scenery, Recreation, Fisheries, Wildlife, Cultural 

Resources 

Big Sheep 

(Eligible) 9.5 38.5 Recreation, fisheries, Cultural/Prehistoric 

East Eagle 

Creek (Eligible) 9.0 2.0 4.5 

Scenery, Recreation, Fisheries, Hydrological, 

Geological, Cultural/Historic 

Swamp Creek 

(Eligible) 8.5 9.5 Fisheries, Wildlife, Cultural/Historic 

Upper Grande 

Ronde (Eligible) 11.0 19.0 Recreation, Fisheries, Wildlife, Cultural/Historic 

Snake WSR 

The Snake River is designated as Wild from Hells Canyon Dam to Upper Pittsburg Landing, 

approximately 32.5 miles. The Wild segment lies within the Hells Canyon Wilderness area from 

its beginning at Hells Canyon Dam until approximately Willow Creek Rapids. At that point the 

wilderness area lies west of the river corridor and the Wild segment of the Snake River continues 

in the HCNRA until Upper Pittsburg Landing. Invasive plant sites within the Wild segment are 

minor within the wilderness area. 

From Willow Creek Rapids to Upper Pittsburg Landing, invasive plant sites are more extensive 

and associated with access sites and ranches. There are approximately 489 acres of invasive 

plants identified within the wild segment. 

The Snake River is designated as Scenic for an additional 34.4 miles downstream from Upper 

Pittsburg Landing to just above Cougar Rapids. There are approximately 291 acres of invasive 

plants identified within the Scenic segment of the river. The largest infestation sites are near Dug 

Bar, Pittsburg Landing and the confluence with the Salmon River. 

Use on the river is heavy during the summer season with jet boats, rafters and kayakers running 

the river. River use is managed under a permit system on both the wild and scenic sections. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Fishing is very popular. Use in the fall is associated with boat-in hunting and would be 

considered moderate. 

Eagle Creek WSR 

Eagle Creek has Wild, Scenic and Recreation designations on the W-W National Forest. The 

Wild segment is within the Eagle Cap Wilderness area. Use along this segment is typically by 

foot or horseback along several trails that access the area. There are no invasive plants identified 

in the Wild segment of the river. The Recreation section follows Forest Road 7700 from the 

wilderness boundary to Martin Bridge.The last 1.5 miles of river from FR 7735 to the forest 

boundary is also classified as Recreation. Use along both these segments consists of dispersed 

camping along the road during summer, with use increasing during big game hunting season. 

There are approximately 71 acres of invasive plants identified within the recreation segments of 

the river. The invasive plants are predominantly associated with the road right of way within the 

managed river corridor. 

The Scenic section is un-roaded except for Forest Road 7015 and 7735 near Martin Bridge. The 

Scenic section runs from Martin Bridge to Forest Road 7735 near Eagle Forks Campground. 

There are approximately 64 acres in invasive plants identified within the Scenic segment. These 

acres are predominantly associated with the road right of way within the managed river corridor. 

Imnaha WSR 

The Imnaha River is designated Wild, Recreation and Scenic along its entire length; from the 

headwaters in the Eagle Cap Wilderness to its confluence with the Snake River. The area is 

known for its scenery, water quality, and wide variety of recreation opportunities—fishing, 

camping, hiking, mountain biking, hunting, sightseeing, scenery, and provision of critical habitat 

for threatened chinook salmon and bull trout. 

The Wild segment is located in the Eagle Cap Wilderness and is accessible by pack stock or foot 

along the Trail #1816. There are no invasive plants identified within this segment. 

The Recreation segment begins outside the wilderness at Indian Crossing Campground and 

continues for 58 miles to just above the confluence with the Snake River. From Crazyman Creek, 

downstream to Cow Creek Bridge, the river bed and bank are primarily on private land. 

Invasive plant sites have been identified along FR 3960 and Forest Road 3955 within the river 

corridor until Crazyman Creek. These plant sites are associated with the road right of way. 

There is a large infestation of common bugloss (5,813 acres) that begins near Winston Creek and 

extends downstream to High Camp Creek along the Imnaha River within the recreation WSR 

corridor and extending into the HCNRA. 

Approximately 870 acres of the 5808 acre site are within the designated WSR corridor. 

Recreational use on this stretch of river is primarily sightseeing from along County Road 727. 

The remaining acres in the Recreation segment are relatively small and associated with access 

and developments. 

The Scenic segment begins at Cow Creek Bridge and continues for approximately 4 miles to the 

confluence with the Snake River. Approximately 22 acres of invasive plants have been 

identified, primarily within the riparian area of the river. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Joseph Creek WSR 

Joseph Creek is designated as Wild for approximately 8.6 miles, from Joseph Creek Ranch to the 

forest boundary. The area is steep and fairly inaccessible. Recreational opportunities include 

kayaking, mountain biking, hiking, horseback riding, and big game hunting. 

There are 46 acres of invasive plants identified within the corridor. These acres are part of a 

larger invasive plant population area that overlaps the river corridor boundary. The Joseph 

Canyon Viewpoint is near the invasive plant site. 

Lostine WSR 

The Lostine River is designated Wild in the headwaters area of the Eagle Cap Wilderness. There 

are no invasive plants identified within the wild segment. The Recreation segment is also located 

partially in the Eagle Cap Wilderness except for the Forest Road 8250 road corridor that has 

been excluded from wilderness designation. Approximately 30 acres of invasive plant have been 

identified within the recreation river corridor. These acres of invasive plants are associated with 

the Forest Road 8250 road corridor. 

Minam WSR 

The Minam River is designated as Wild from its headwaters at Eagle Cap Lake to the Eagle Cap 

Wilderness boundary. The area is heavily used for hunting, fishing, backpacking, horse packing, 

and other recreational activities. There are 89 acres of invasive plants identified within the 

corridor and they are primarily associated with Trail #1673. 

East Eagle Creek (Eligible) 

East Eagle Creek has been allocated into Wild, Scenic and Recreation segments in the WallowaWhitman Land and Resource Management Plan (forest plan). There are 12 acres total of invasive 

plants identified within the eligible river corridor. The wild segment is within the Eagle Cap 

Wilderness. There is one acre of invasive plants identified on the edge of the wilderness 

boundary, eight acres in the Recreation segment and three acres in the Scenic segment. These 

acres are located along the right of way of Forest Road 7745. 

Big Sheep Creek (Eligible) 

Big Sheep Creek has been allocated into a Recreation river for 38.5 miles and Wild for 9.5 miles 

in the forest plan. The wild segment lies within the Eagle Cap Wilderness. The recreation 

segment begins at the wilderness boundary and ends at its confluence with the Imnaha River. 

The river provides high quality recreation opportunities year-round along its middle and upper 

reaches. There are no invasive plants within the wild segment of the river. There are 

approximately 130 acres of invasive weeds along the Recreation segment. These acres are 

primarily associated with Forest Road 3940, Forest Trails # 1800 and 1819, Forest Highway 39 

and riparian areas. 

Swamp Creek (Eligible) 

Swamp Creek has been allocated into a Recreation river for 9.5 miles from the forest boundary 

to Swamp Creek Cow Camp at Forest Trail #1658 in the forest plan. The next 8.5 miles are 

allocated as Wild from Forest Trail #1658 downstream to its confluence with Joseph Creek. 

There are 2 acres of invasive weeds in the recreation segment associated with Forest Highway 

46. There are 11 acres of invasive weeds in the wild segment. These acres are associated with 

Forest Trail #1678. 

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Upper Grande Ronde (Eligible) 

The Upper Grande Ronde is allocated as a Wild river beginning at its headwaters and 

downstream 11 miles and Recreation from that point downstream an additional 19 miles to the 

forest boundary in the forest plan. The river provides a wide variety of recreational opportunities 

and is a popular destination area. Use along the river during the fall big game hunting season is 

considered very high. There are no invasive weeds in the wild segment. There are 148 acres of 

invasive weeds within the recreation segment. These acres are primarily associated with the road 

right of way along Forest Highway 51. 

Table 64-Wild and Scenic Rivers, designation, and acres of invasive plants 

NA indicates that the designation doesn’t apply to the river. ** Denotes that portions of the wild segment lie within 

wilderness. Acres in WSR corridors that occur in wilderness would be subject to laws, standards and project design 

features pertaining to wilderness. 

Acres of Invasive Plants by River and Designation 

River Name Wild Scenic Recreation Total Acres of Invasive Plants 

Eagle Creek 0 64 71 135 

Imnaha River 0 22 870 892 

Joseph Creek 46 NA NA 46 

Lostine River 0 NA 30 30 

Minam River **88 NA NA 88 

Snake River **490 290 NA 780 

Big Sheep 

(Eligible) 0 NA 130 130 

East Eagle Creek 

(Eligible) **1 3 8 12 

Swamp Creek 

(Eligible) 11 NA 2 13 

Upper Grande 

Ronde (Eligible) 0 NA 148 148 

Grand Totals 636 379 1259 2274 

Developed Recreation Sites 

Invasive plants are found in 76 out of 126 developed recreation facilities on the WallowaWhitman National Forest. Invasive plants have been identified within the managed use area of 

these sites. These sites include campgrounds, trailheads, winter sports areas, cabin rentals, 

interpretive sites and organizational camps. Many of the invasive plant sites are small. They 

range from less than one acre to approximately 7 acres. 

Use in developed campgrounds, trailheads, and rental cabins would be considered light to 

moderate during the summer season. Use increases significantly during Memorial Day, July 4th 

and Labor Day weekends and would be considered relatively heavy. Use of developed sites 

typically drops off after Labor Day. Light use of developed campgrounds does occur in 

conjunction with hunting season. Use of trail heads increases with hunters packing into 

wilderness and back country areas. 

The following table shows developed recreation sites by ranger district, site name and acres to be 

treated by treatment type. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 65-Ranger District, Developed Recreation Site Name, and Acres of Proposed Treatments 

Ranger District and 

Site Name 

Acres of 

Invasive Plants 

Anthony Lakes Alpine Ski Area 3.0 

Baker Valley Overlook 0.6 

Blue Springs Snow Park 1.0 

Deer Creek Campground 2.7 

Forest Practices Interpretive Site 1.3 

Gold Center Spring Day Use Area 1.5 

Grand Ronde Snow Park 0.7 

Marble Creek Picnic Area 3.2 

Mason Dam Boat Launch 0.7 

Mason Dam Picnic Area 4.5 

Mason Dam Viewpoint 1.2 

McCully Forks Campground 5.1 

Mud Lake Campground 3.0 

Powder River Trailhead 3.6 

Southwest Shore Campground 0.6 

Baker 

Van Patten Lake Trailhead 0.3 

Total 33.0 

Bear Wallow Trailhead 1.3 

Boundary Campground 0.4 

Cougar Ridge Trailhead 1.3 

Irondyke Forest Campground 0.6 

Eagle Cap 

Pole Bridge Picnic Area 0.1 

Total 3.7 

Blackhorse Campground 0.4 

Buck Creek NRA Trailhead 0.4 

Buckhorn Tower/Overlook 2.6 

Cache Creek Ranch Interpretive Site 1.1 

Circle C Ranch Admin. Site 3.5 

Copper Creek Private Resort 2.1 

Coverdale Campground 0.5 

Cow Creek Trailhead 0.5 

Dug Bar Boat Launch/Trailhead 4.3 

Evergreen Campground 0.6 

Gumboot Creek Fish Interpretive Site 1.4 

Hat Point Day Use Area 7.3 

Hells Canyon Creek Boat Launch 5.0 

Hidden Campground 0.4 

Imnaha River Fish Weir 1.3 

Indian Crossing Trailhead 3.1 

Kirkwood Ranch Interpretive Site 1.3 

Lake Fork Campground 4.5 

Lake Fork Creek Trailhead 1.1 

Lick Creek Campground 3.4 

Mountain Chief Mine Tunnel 0.3 

North Pine Roadside Rest Stop 1.3 

Ollokot Campground 0.7 

P.O. Saddle Trailhead 0.3 

Hells Canyon NRA 

Pittsburg Campground 2.0 

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365 

Ranger District and 

Site Name 

Acres of 

Invasive Plants 

Pittsburg Landing 1.8 

Pittsburg Rock Art Interpretive Site 5.3 

Sacajawea Camp 5.7 

Snake River Trailhead 6.5 

Upper Crazyman Trailhead 0.5 

Upper Pittsburg Landing 0.2 

Total 69.4 

Bird Track Interpretive Trailhead 6.0 

Bird Track Springs Campground 0.1 

Blue Springs Recreation Residences 0.1 

Catherine Summit Snow Park 0.1 

Frog Heaven Forest Camp 5.2 

Main Eagle Trailhead 1.1 

Moss Springs Guard Station 0.1 

North Fork Catherine Group Camp 0.2 

Park Saddle Trailhead 1.0 

River Campground 0.3 

Sand Pass Trailhead 0.1 

Spool Cart Campground 2.2 

La Grande 

Spring Creek Bunny Hill 1.0 

Total 17.5 

Halfway Picnic Area 3.6 

Martin Bridge Trailhead 0.6 

McBride Campground 0.7 

Pine 

Tamarack Campground 0.5 

Total 5.4 

Antlers Guard Station 3.9 

Blue Springs Snow Park 0.4 

Long Creek Forest Camp 2.0 Unity 

Mammoth Spring Campground 1.4 

Total 7.7 

Chico Trailhead 0.8 

Wallowa-Valley Salt Creek Summit Snow Park 0.5 

Tenderfoot Trailhead 0.2 

Total 1.5 

Grand Totals 138.2 

General Forest Area 

The general forest area, for the sake of this writing, is considered all areas not within a 

developed recreation site boundary, designated wilderness and wild and scenic river corridors. 

The majority of invasive plant sites within the general forest area occur along roads. 

Roads and trails are considered to be high spread potential areas and high priority for treatment. 

The forest currently has one of the largest road systems in the Forest Service with 9,291 miles of 

inventoried roads. Recreational access to the forest is the predominant use of the transportation 

system. Driving for pleasure is a primary use of the forest (USDA Forest Service 2004a). 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

There are approximately 1752 miles of non-motorized trails on the forest and approximately 220 

miles of designated OHV/motorcycle trail on the Forest. Forest roads are open to OHV use with 

the exception of paved roads and double lane gravel roads. 

Non-motorized trail types include pack and saddle trails, hiking trails and cross-country ski 

trails. Pack and saddle trails and the feed, straw and disturbance associated with such use can 

facilitate the establishment and spread of invasive plants. Cross-country ski trails receive little 

use during the snow-free season. Mountain bikes are commonly used on trails outside 

wilderness. Mountain bikes can be vectors of invasive plant spread. 

Motorized trails include off-highway vehicles (OHV) motorcycle and snowmobile trails. OHV 

trails and “cross country” use can create the conditions that are favorable for invasive plant 

establishment and subsequent spread by vehicle use (Lacey et al. 1997). Snowmobile trails are 

typically on roads that are not plowed during winter seasons. Use of OHVs on the forest is 

moderate with use increasing forest-wide during big game hunting season. 

Dispersed recreation sites are typically along roads and have developed due to repeated use by 

recreationists. These site types are not usually inventoried, signed, or have any other use controls 

associated with them other than access. Repeated use by recreationists can create the conditions 

that favor invasive plant establishment and spread. Overall incidence of summer dispersed 

camping is moderate, and is associated with OHV riding and river use. Dispersed camping 

during the hunting season would be considered high with camps occurring along many roads. 

Many hunter campsites have been used by the same hunting group year after year. 

Big game hunting is a major use of the general forest area during the fall months. Dispersed 

camping, and OHV use for accessing remote hunting areas, scouting for game, and game 

retrieval increase substantially during big game hunting season. 

Mushroom and berry picking and gathering of other forest products for consumptive and nonconsumptive use is a popular activity throughout the forest. These activities are typically 

associated with roads for access reasons; however the activity usually occurs outside the 

immediate road right of way. 

Approximately 12,101 acres of invasive plants have been identified in the general forest area. 

The general forest acres are derived from the total acres proposed for treatment (22,842 acres) 

minus the acres within the boundaries of congressionally designated areas and developed 

recreation sites.The following table summarizes acres of invasive plant treatments by recreation 

area. 

Table 66-Acres of invasive plants by recreation area 

Recreation Area Acres of Invasive Plants 

Wilderness 979 

WSR 2,274 

HCNRA 7,350 

Developed Recreation 138 

General Forest Area 12,101 

Grand Total 22,842 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

3.6.3 Environmental Consequences 

Effects to Recreation for Alternative A - No Action Alternative 

Under this alternative, approximately 5,172 acres of invasive plants forest-wide would continue 

to be treated as authorized under existing decision documents (USDA Forest Service 1992, 

1994a, 2003c). This document allows for limited use of herbicides and has proven ineffective in 

controlling the spread of invasive plants (see Botany Report). New infestations of invasive plants 

can be treated using mechanical and manual methods under this alternative; however, 

mechanical and manual methods have also proven to be ineffective in controlling the spread of 

invasive plants. 

This alternative does not allow for early detection rapid response as a treatment strategy for 

newly identified invasive plant infestations. The absence of this treatment strategy would 

increase the potential for new invasive plant infestations to establish and spread. 

Effects Common to Recreation for all Action Alternatives 

Direct and Indirect Effects 

Visitors may notice invasive plant treatments when traveling through the forest by car, OHV, 

foot, pack stock or water craft. How noticeable the treatment is depends on the size of the 

invasive plant site being treated and the type of treatment being used. 

Chemical application methods vary from individual plant application to broadcast spraying. 

Wicking and stem injection treat individual plants and only target plants would be affected. Spot 

spraying would target individual plants but overspray may affect adjacent vegetation. Broadcast 

spraying would treat an area and all plants within the site would be affected. Broadcast 

application could include hand spreading and spraying from vehicle mounted tanks. Individual 

plant application would use less chemical agent overall. Visitors that are concerned about 

exposure to herbicides may be more accepting of individual plant application methods, 

especially in high use areas and areas for gathering berries and mushrooms. Chemical treatments 

would leave dead vegetation that would be noticeable for several days to several weeks. 

Individual plant treatments would be less noticeable than broadcast treatments overall. These 

effects would be of short duration, typically one growing season. 

Physical treatments include manual and hand mechanical treatments. Manual treatments may 

show signs of disturbed earth from digging or grubbing out root systems. Hand mechanical 

treatments may leave evidence of cut vegetation due to mowing, weed whipping, roadside 

brushing. 

These effects are commonly seen by the visitor on and off the forest and are not expected to 

detract from their overall recreation experience in the general forest areas (not wilderness or 

WSR). These effects would be of short duration, typically one growing season. 

Biocontrol measures would not be noticeable to the casual forest visitor. Introduced biocontrol 

agents are typically insects that target certain plant and their life cycles. This method of control is 

used to reduce high densities of invasive plant population. It is a long term method of treatment 

that does not eradicate the invasive plant, but instead keeps the population in check so that native 

species can compete. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Eradicating invasive plants can make areas more desirable for recreation. Invasive plants that 

have characteristics such as thorns, bristles, stiff plant stalks and chemical irritants would be 

treated, making areas more inviting to recreationists. Recreationists may appreciate a more 

natural landscape with intact native vegetation. 

Early Detection Rapid Response (EDRR) is a treatment strategy that allows managers to rapidly 

respond to new or expanding invasive plant sites. The treatment decision process (Chapter 2,

Figure 12) provides a decision process for determining treatment methods for invasive plant 

sites. Areas treated under EDRR would be subject to all regional and forest standards. Effects to 

recreation would be similar to those described above and within the categories described below. 

All sites and areas that are treated with herbicides would be posted to inform forest visitors what 

herbicide was used, when it was applied and how long the herbicide would persist in the area 

before breaking down. Visitors would be able to make informed decisions concerning their 

comfort level with recreating in an area where herbicides have been recently applied. 

People may decide not to recreate in areas where herbicides have been applied. The greatest 

impact to visitors would be if they were not aware that herbicides had been applied in their 

destination recreation area. The Wallowa Whitman LRMP as amended by Standard 23 of the R6 

2005 ROD provides for public notification through various media, but it is impossible to contact 

all potential visitors prior to them arriving on the forest. Posting signs at key access points would 

alert visitors to the presence of herbicides; however notification upon arrival may disrupt a 

visitor’s plans and activities. Similar recreational opportunities exist across the forest so a visitor 

would be able to find a substitute place to recreate. This may provide an opportunity for forest 

visitors to explore new areas. 

Effects on Congressionally Designated Areas 

Alternative A - No Action 

Approximately 1,188 acres of invasive plants within the HCNRA that are currently approved for 

treatment would continue to receive treatment, leaving approximately 6,162 acres treated using 

hand treatment methods only or not treated at all. 

Under this alternative, approximately 270 acres within wilderness currently approved for 

treatments would continue to receive treatments. Invasive plants have spread substantially 

beyond these sites. Without treatment of new invasive plant sites, populations that have become 

established within wilderness would continue to spread. By not aggressively treating weeds, 

wilderness character would remain “untrammeled” and free from human manipulation; however, 

the spread of invasive plants may change the character of the ecosystem such that they threaten 

the apparent naturalness and natural integrity of the wilderness. 

Approximately 1,057 acres within WSR corridors would continue to be treated under this 

alternative. Invasive plants have spread beyond these sites. Invasive plants can detract from the 

outstandingly remarkable values for which the WSRs were designated. These include scenery, 

recreation, fisheries, wildlife, botanical, ecological, cultural and geological values. Refer to their 

respective reports for detailed descriptions of impacts invasive plants have on these resources. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Alternative B - Proposed Action 

National Recreation Areas – Hells Canyon NRA 

Approximately 7,350 acres of known invasive plants are proposed to be treated within the 

HCNRA (not including wilderness or WSR acres). These acres occur along roads, rangelands, 

dispersed camping areas as well as forest and grass lands. Approximately 7083 acres would be 

treated with ground-based application of herbicides. Additionally, 166 acres would be treated 

with herbicides using aerial application methods. There are 44 acres proposed for biocontrol and 

57 acres proposed to be treated using manual methods. 

The forest visitor is most likely to encounter invasive plant treatments while traveling through an 

area on roads. They may notice dead vegetation, signs informing visitors that an area has been 

treated with herbicides or people with equipment applying herbicides. 

Visitors gathering mushrooms, berries and other forest products may be displaced to areas where 

herbicides have not been applied. Refer to the Pacific Northwest Region Final Environmental 

Impact Statement, Preventing and Managing Invasive Weeds, (USDA Forest Service 2005) for 

discussion of human health and safety regarding exposure to herbicides. 

The public would be notified about upcoming herbicide treatments via the local newspaper or 

individual notification, fliers, and posting signs. Forest Service and other websites may also be 

used for public notification.Trails # 1732, 1744 and 1754 would be closed temporarily during the 

aerial operations. The area and trails would be closed to public access only during the aerial 

application operations. This impact would be short term. Effects of ground based herbicide 

application and other treatment methods would be similar to those described as common to 

recreation for all action alternatives. 

Table 67-Acres of proposed treatments in HCNRA 

Hells Canyon NRA Acres of Proposed Treatments 

Biocontrol Chemical Chemical Aerial Manual Total 

44 7083 166 57 7350 

Wilderness 

To best preserve the wilderness resource, alternatives will be evaluated for their potential effects 

on the four qualities of wilderness character: Untrammeled, natural, undeveloped, and 

outstanding opportunities for solitude or a primitive and unconfined type of recreation. The 

untrammeled quality is the extent to which wilderness ecosystems remain free from modern 

human manipulation. Natural integrity is the extent to which long-term ecological processes are 

intact and operating. The undeveloped quality is a measure of how natural the environment 

appears and how free it is from any structures or developments. The outstanding opportunities 

for solitude or a primitive and unconfined type of recreation are subjective values defined as 

isolation from the sights, sounds and presence of others, and the developments and activities of 

people. Primitive recreation opportunities are those that allow the recreationists to use 

backcountry skills, knowledge and abilities that do not rely on developed facilities, mechanical 

transport or motorized equipment. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Invasive Plant Treatment and Transport Methods in Wilderness 

Approximately 874 acres of 979 acres are proposed to be treated with herbicides in wilderness. 

Of the 874 acres of herbicide treatment, 526 acres are proposed for aerial application and 348 

acres are proposed for ground-based herbicide application. The remaining treatments proposed 

are 100 acres of biocontrol and 5 acres of manual treatment. The following table shows the acres 

of treatment by treatment type for each wilderness. 

Table 68-Acres of proposed treatment by wilderness 

Acres of Proposed Treatments Wilderness Name 

and Acres Biocontrol Chemical Chemical 

Aerial 

Manual Total 

Hells 

Canyon 214,994 0 265 526 4 795 

Eagle Cap 350,461 100 81 0 1 182 

Monument 

Rock 7,030 0 2 0 0 2 

Total Acres 586,779 100 348 526 5 979 

Use of herbicides is estimated to be 80 percent effective in reducing invasive plants with one 

treatment application (see Botany Report). Treatment is most effective when herbicides are 

applied during the active growing season of the plant, typically May through July. Areas may be 

treated one to two times per year during the growing season to meet the objective to effectively 

control, contain or eliminate the invasive species at that site. Where continued disturbance occurs 

such as at trailheads and popular campsites annual treatments may be necessary to prevent the 

re-establishment of invasive plants and subsequent spread. 

Aerial Application of Herbicide in Hells Canyon Wilderness 

Minimum Requirement Analysis is a documented process that the Forest Service uses to assess 

the appropriateness of all actions affecting wilderness. This concept is intended to minimize 

impacts on wilderness values and resources. Decision makers may authorize generally prohibited 

activities or uses listed in Section 4(c) of the Wilderness Act if they are deemed necessary to 

meet the minimum requirements for the administration of the area as wilderness and where those 

methods are determined to be the ‘minimum tool’ for the project. 

A Minimum Tool Analysis has been completed for invasive plants treatment in Hells Canyon 

Wilderness and is included in Appendix A. Aerial application of herbicides by helicopter was 

identified as the minimum tool necessary to treat 526 acres of yellow star thistle (Centaurea 

solstitialis L. – CESO3) on 10 different sites. All other invasive plant sites in Hells Canyon, 

Eagle Cap and Monument Rock wildernesses would be treated using ground-based herbicide 

application methods or hand treatment methods. 

Split by the Snake River, the Hells Canyon Wilderness straddles the Idaho and Oregon state 

boundary. Treatment areas are within approximately 1.5 miles of the Snake River. 

The noise from jet boats is audible within wilderness. There are no treatments proposed in the 

Idaho portion of the wilderness. 

Aerial application of herbicides would be accomplished using helicopters. Helicopters landings 

would not occur in wilderness. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Activities to support aerial treatments would occur outside wilderness. Helicopters typically fly 

100 feet or less above ground level during herbicide application. Herbicide is applied at a rate of 

2 gallons of herbicide/water mixture per acre. Helicopters can carry 70-80 gallons of water and 

herbicide mix, treating approximately 35 acres per load. Each load takes approximately 15 

minutes to deliver. Given the application rate of 35 acres treated every 15 minutes, aerial 

application of herbicides would take approximately 3 hours and 48 minutes to deliver to 526 

acres. The following table summarizes the invasive plant site, acres to be treated, estimated time 

to apply herbicides per site and general location of the site within wilderness. Refer to Appendix 

F for detailed aerial spray guidelines, herbicide drift model results, and project implementation 

information. 

Table 69-Aerial application information for Hells Canyon Wilderness 

Aerial Application Sites in Hells Canyon Wilderness 

Site ID Number Acres 

Est. Appl. 

Time 

(Minutes) 

Location/Adjacent Recreation Features 

06160400210 4 4 min. 

Across Snake River from Dug Bar. East 4 acres outside 

wilderness boundary. Trail # 1774 follows east edge. 

West 4 acres in wilderness. 

06160400212 11 5 min. T28N R3W Sec. 28, between Birch Creek and Fence Gulch. 

No recreation features adjacent. 

06160400222 9 5 min. T28N R3W Sec. 33. Upper reaches of Dug Creek. 

No recreation features adjacent. 

06160400088 7 4 min. T27N R2W Sec. 15. Near Bob Creek. 

No recreation features adjacent. 

06160400441 6 3 min. T27N R2W Sec. 15. Near upper reaches of Bob Creek. 

No recreation features adjacent. 

06160400442 51 22 min. T27N R2W Sections 22, 23. Near upper reaches of 

Lonepine Creek. Trail #1736 within 300 meters. 

06160400443 108 45 min. T27N R2W Section 22. Along north fork of Lookout Creek. 

Trail #1701 runs through western edge of treatment area. 

06160400444 34 15 min. T27N R2W Section 22. Along headwaters of Lookout 

Creek. Trail #1701 within 300 meters. 

06160400445 259 111 min. 

T27N R2W Sections 21, 22, 27. Along Lookout Creek. 

Trail #1701 runs through western edge. Trail #1735 runs 

through the eastern edge of treatment area. 

06160400448 37 15 min. 

T27N R2W Sections 27, 34. Near Tryon Creek and Tryon 

Creek Ranch. Trail #1735 runs through south end. Trail 

#1699 junction within 300 meters. 

Totals 526 

ac. 

229 min. Approximately 3 hours 48 minutes of aerial application 

time within wilderness. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Ground-based Treatment Methods in Wilderness 

Ground-based treatment methods that may be utilized include non-mechanical hand treatments 

such as hand pulling or use of hand tools for cutting, digging and grubbing. Herbicide 

treatments may use application methods such as wicking, stem injection, spray bottle, hand 

pressurized pumps, battery or solar powered pumps and propellant based systems such as those 

that use pressurized carbon dioxide. Power tools such as trimmers would not be used. Gaspowered, motorized pumps are not proposed as an application method in wilderness including 

under the EDRR strategy. 

Wicking, stem injection, 

pressurized carbon dioxide 

and hand pressurized pumps 

are non-motorized 

application methods and are 

considered acceptable

herbicide application 

methods within wilderness 

without further analysis of 

the Wilderness Act’s 

prohibitions on use of 

d 

ese 

k 

es 

 quiet and 

r a 

ined 

ation in 

ntract worker spraying invasive plants in wilderness from a horsepack-mounted 

spray system 

 people to carry out invasive 

plant treatments is not proposed under any alternative or EDRR. 

motorized equipment. 

Battery or solar powere

pumps are considered 

motorized equipment. Th

devices are used to apply 

herbicides from horsebac

mounted spray systems. 

Solar panels and/or batteri

to operate pumps may be 

evident on pack stock. These 

types of pumps are

would not impact 

opportunities for solitude o

primitive and unconf

type of recre

wilderness. 

Figure 20 – Co

Methods to transport people and supplies to carry out invasive plant treatments include nonmechanized methods considered acceptable within wilderness including backpack and pack 

stock use. These types of traditional transport methods used within wilderness do not require 

additional analysis of the Wilderness Act’s prohibitions on using mechanical transport. Use of 

helicopters or other mechanized methods to transport supplies and

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Biocontrol Treatments in Wilderness 

Biological control agents may be introduced into wilderness to control invasive plant 

populations. 

All biocontrol measures would be subject to the W-W LRMP as amended by the R6 2005 ROD 

Standard 14 - Use only APHIS and State-approved biological control agents. Agents 

demonstrated to have direct negative impacts on non-target organisms would not be released. 

Biological control agents would be used in areas where access or safety reasons limit other 

treatment options. 

Effects on Wilderness Character 

Untrammeled 

Treatment of invasive weed infestations within wilderness can be viewed as human 

manipulation. Evidence of human manipulation can detract from the “untrammeled” feel of 

wilderness. There will be short-term evidence of weed treatments including dead or wilting 

plants and areas of disturbed soils where plants have been pulled up or grubbed out. Where 

plants are dead or dying, some people may recognize that herbicides were sprayed. Aerial sites 

would be larger and more evident to visitors where they occur near trails and in viewsheds. 

These effects may not appear natural to the forest visitor. Hikers and pack stock users are 

typically traveling at a slow pace and these changes may be noticeable. Biocontrol measures 

would be not be noticeable to the casual visitor and would not affect the apparent naturalness of 

the area. 

The amount of area proposed to be treated in wilderness is very small; approximately 979 acres 

of 586,779 acres in wilderness on the forest. Effects would be localized to the treatment areas 

and effects to the wilderness ecosystem are limited to these treatment areas. Regional standards 

and project design features are in place to protect ecological resources including non-target 

botanical species, water, soils, fisheries and wildlife. Refer to the botany, hydrology, soils, 

fisheries and wildlife reports for details concerning the effects of invasive plants and the effects 

of invasive plant treatments on these resources. 

Natural 

Aggressive treatment of weeds in the wilderness would improve natural integrity. Invasive weed 

treatments would decrease establishment and expansion of invasive species in wilderness areas, 

and allow native vegetation and ecological processes to continue. Apparent naturalness of 

treated areas will improve as the evidence of invasive plants decreases and they are replaced 

with native vegetation. 

Introduction of biological control agents to control invasive plants is considered a human 

intervention within wilderness. However; the biological control agents only directly affect the 

invasive plant host species. Invasive plants directly affect native plant communities, wildlife 

populations, apparent naturalness and other attributes of the ecosystem. Biological control agents 

are not visible to the casual visitor. 

Early Detection/Rapid Response treatment strategy would allow managers to treat infestations 

within wilderness quickly while the infestation is still small. This strategy would reduce the 

opportunity for the spread of invasive plants within wilderness, protecting the natural integrity or 

the wilderness. In addition, treating areas while small will reduce the visual effects of treatments. 

Impacts to apparent naturalness would be less. 

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Undeveloped 

No new developments, facilities, or structures are proposed by any alternatives. There would be 

no impact to the undeveloped quality of wilderness. 

Outstanding Opportunities for Solitude or a Primitive and Unconfined Type of Recreation 

Aerial application of herbicides would have short-term adverse impacts to wilderness solitude. 

The actual time estimated to apply the herbicides is approximately 4 hours for the 526 acres 

proposed. Due to additional flight time for travel between units, refueling and reloading the 

aircraft and working within optimal application windows, it is estimated that aerial application 

would impact wilderness solitude for 1-2 days per application. 

Trails # 1701, 1735A, and 1774 within HCW, adjacent to aerial sites, would be closed for public 

safety prior to treatment. These areas would be closed to visitors for the short term, lasting until 

application of herbicides was completed. 

Forest visitors may encounter workers applying herbicides using hand sprayers, backpack or 

horseback sprayers in the wilderness. The sounds from battery/solar electric pumps would be 

localized to the treatment area and would not disrupt entire watersheds. Visitors may also 

encounter workers digging, grubbing or pulling invasive plants. These encounters may affect 

some people’s sense of remoteness and their opportunity for solitude. This effect would be short 

term, typically one to several days, and backcountry crews treating weeds would be small 

(typically 1-4 people). Duration of effects would depend on size of invasive plants site being 

treated. Effects on visitor’s wilderness experience can be minimized through public notification 

and treating areas during low visitor use periods. 

Some visitors may appreciate encountering people working with pack stock in the wilderness. 

“Packing in” is a traditional skill that many people associate with wilderness use. 

Early Detection Rapid Response treatment strategy would allow managers to treat invasive 

plants while the infestation is still small. Treatment methods and duration would be less intrusive 

to the forest visitor if areas are treated when small. Less time would be necessary for workers to 

be in an area, reducing the opportunity for forest visitors to encounter work crews. New 

infestations would be treated 1-2 times per year until the invasive weeds were eliminated. Under 

EDRR, treatment methods would be limited to non-mechanical hand treatments and groundbased herbicide application methods as described. 

Wilderness trailheads would be posted, informing visitors that herbicides have been or will be 

sprayed in the area. This may cause the visitor to recreate elsewhere, reducing their opportunity 

to engage in wilderness recreation. Invasive plant treatments overall would not detract from the 

opportunity for primitive recreation. Effects would be the same under Early Detection Rapid 

Response treatment strategy. 

Wild and Scenic Rivers 

The presence of invasive plants and treatments of them may impact the outstandingly remarkable 

values for which the rivers were designated or deemed eligible. Outstandingly remarkable values 

may include scenery, recreation, geology, fisheries, wildlife, botany/ecology, historic or cultural 

resources. Recreation is identified as an outstandingly remarkable value for all rivers in the 

project area except Swamp Creek. All outstandingly remarkable values are identified in Table 63. 

Effects of invasive plants and invasive plant treatments on resource values other than recreation 

are covered in their respective resource section. 

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Forest Plan and regional standards as well as project design features are in place for herbicide 

use near water to protect water quality. Refer to Chapter 3.4 of this DEIS for detailed 

information concerning these resources. 

Visitors may notice dead vegetation due to herbicide application when floating rivers. Effects to 

these rivers and the outstandingly remarkable value of recreation would be similar to those 

effects common to recreation for all action alternatives. 

Early Detection Rapid Response treatment strategy would allow managers to treat infestations 

within WSR corridors quickly while the infestation is still small. 

This strategy would reduce the opportunity for the spread of invasive plants within WSR 

corridors, protecting the outstandingly remarkable values for which they were designated or 

deemed eligible. 

Approximately 2,177 acres would be treated with herbicides in WSR corridors. The majority of 

these; 1,148 acres, occur in riparian areas. There are 1,029 acres proposed in upland sites, 

including 527 acres proposed for aerial application. The aerial application acres are part of the 

large bugloss site that occurs along the Imnaha River. Approximately 84 acres would be treated 

with biocontrol measures and 13 acres would be treated manually. 

Table 70-Acres of proposed treatments by WSR name and designation 

Acres of Proposed Treatments 

WSR 

Biocontrol Chemical Chemical 

Riparian Manual Total 

Recreation 0 63 8 0 71 

Eagle Creek Scenic 0 53 11 0 64 

Wild 0 0 0 0 0 

Total 0 116 19 0 135 

Recreation 0 550 313 7 870 

Imnaha River Scenic 0 3 18 1 22 

Wild 0 0 0 0 0 

Total 0 553 331 8 892 

Lostine River (Total) Recreation 22 0 8 0 30 

Scenic 20 167 98 5 290 

Snake River 

Wild 22 93 375 0 490 

Total 42 260 473 5 780 

Joseph Creek (Total) Wild 0 46 0 0 46 

Minam River (Total) Wild 19 0 69 0 88 

Big Sheep 

(Eligible) (Total) Recreation 0 27 103 0 130 

Recreation 0 8 0 0 8 

Scenic 0 3 0 0 3 East Eagle Creek 

(Eligible) 

Wild 1 0 0 0 1 

Total 1 11 0 0 12 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Acres of Proposed Treatments 

WSR 

Chemical Biocontrol Chemical Manual Total Riparian 

Swamp Creek Recreation 0 2 0 0 2 

(Eligible) Wild 0 0 11 0 11 

Total 0 2 11 0 13 

Upper Grand Ronde 

(Eligible) (Total) Recreation 0 14 134 0 148 

Grand Totals 84 1029 1148 13 2274 

Alternative C - Restricted Use – No Broadcast Herbicide Application in Riparian 

Under this alternative, ground-based and aerial broadcast herbicide application methods would 

not be used. By using methods other than broadcast spraying, less herbicide would be used 

overall. 

Individual plants would be targeted and resulting dead vegetation would be less noticeable. 

Potential for impacts to non-target plants would be reduced, reducing the effects on untrammeled 

and natural wilderness character qualities. 

Application of herbicide to individual plants is typically more work intensive. There may be 

more workers in the wilderness for more days than if broadcast methods were used. Visitors may 

feel a loss of solitude due to the presence of workers in the wilderness. 

Impacts to WSR and the outstandingly remarkable values of fisheries, botany, ecology and 

wildlife would be reduced by eliminating broadcast spraying in riparian areas. Potential impacts 

to non-target plants, delivery of herbicides to water and subsequent impacts on fish would be 

reduced. Refer to the respective resource reports for details about this alternative. 

By using methods other than broadcast spraying, less herbicide would be used overall. 

Individual plants would be targeted and resulting dead vegetation would be less noticeable to 

forest visitors. Impacts to recreation as an outstandingly remarkable value of WSR’s would be 

the same as those common to recreation for all action alternatives. 

Alternative D - No Aerial Application 

Hells Canyon National Recreation Area 

Approximately 166 acres of invasive plants within the HCNRA would not be treated using aerial 

application methods. These acres would be treated with herbicides using ground based methods 

or not at all.

Wilderness 

Under this alternative, 526 acres of invasive weeds, primarily yellow star thistle would not be 

treated by aerial application within Hells Canyon wilderness. Due to the steep terrain and 

difficult access to these areas, the alternate treatment would be to release biocontrol agents near 

the sites with the idea that they would migrate to the host plants. Biocontrol agents are generally 

less effective than herbicide use. Biocontrol agents have had mixed success in the Hells Canyon 

area due to site conditions such as lack of moisture, soil types and recurring fire. 

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It is estimated that biocontrol would be much less effective in controlling spread of yellow star 

thistle in these areas (see Botany Report). 

Apparent naturalness of wilderness would be reduced due to the use of less effective biocontrol 

treatments of invasive plants. The opportunity for invasive plant populations to spread from 

these sites is greater than with herbicide use. Native vegetation ecological processes may be 

impacted due to continued presence and spread of invasive plants. 

Impacts to wilderness solitude would be much less than if aerial application were utilized. 

Visitors would not be impacted by low level flights. Release of biocontrol agents is not intrusive 

and would not be noticed by the casual visitor. 

 Wild and Scenic Rivers 

There are no acres of invasive plants proposed for treatment using aerial application.This 

alternative would have the same effect as those described in the Proposed Action. 

Effects on Developed Recreation Sites 

Alternative A – No Action 

Approximately 63 acres of invasive plants in 45 developed recreation sites would continue to be 

treated under current decision documents. New invasive plant infestations would become 

established and spread. Developed sites are considered high spread potential sites. Humans, the 

vehicles they use, pets and pack stock, associated with developed recreation sites would continue 

to be vectors spreading invasive plants and propagating plant parts. 

Effects Common to all Action Alternatives 

Many campgrounds, rental cabins, trailheads and picnic site are destination recreation sites. 

Recreation visitors that have made plans to use a certain facility may find that herbicides have 

been applied within or near the site. Recreationists may choose to recreate elsewhere due to the 

presence of herbicides. 

Alternative B - Proposed Action 

Approximately 138 acres in 76 out of 126 developed recreation sites would be treated with 

herbicides. If all developed recreation sites were treated at the same time, recreationists that do 

not want to be exposed to herbicides would have limited choices of facilities to use. This 

scenario is not likely as different weed species require treatments at different times of the year, 

program priorities and budget constraints. 

Aerial application of herbicides would not have a direct impact to developed recreation sites. 

There are no invasive plant sites currently identified adjacent or near any developed recreation 

facility that would require aerial application of herbicides. The W-W LRMP as amended by the 

R6 2005 ROD Standard 21 prohibits aerial application of herbicides within 300 feet of a 

developed recreation facility. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 71-Acres of proposed treatment by ranger district and site name 

Acres of Proposed Treatments Ranger District and 

Site Name Biocontrol Chemical Chemical 

Riparian Total 

Anthony Lakes 

Alpine Ski Area 3.0 3.0 

Baker Valley 

Overlook 0.6 0.6 

Blue Springs Snow 

Park 1.0 1.0 

Deer Creek 

Campground 2.7 2.7 

Forest Practices 

Interpretive Site 1.3 1.3 

Gold Center Spring 

Day Use Area 1.5 1.5 

Grand Ronde Snow 

Park 0.7 0.7 

Marble Creek 

Picnic Area 0.3 2.9 3.2 

Mason Dam Boat 

Launch 0.7 0.7 

Mason Dam Picnic 

Area 1.7 2.8 4.5 

Mason Dam 

Viewpoint 1.2 1.2 

McCully Forks 

Campground 5.1 5.1 

Mud Lake 

Campground 3.0 3.0 

Powder River 

Trailhead 1.1 2.5 3.6 

Southwest Shore 

Campground 0.6 0.6 

Baker 

Van Patten Lake 

Trailhead 0.3 0.3 

Total 0 15.7 17.3 33.0 

Bear Wallow 

Trailhead 1.3 1.3 

Boundary 

Campground 0.4 0.4 

Cougar Ridge 

Trailhead 1.3 1.3 

Irondyke Forest 

Campground 0.6 0.6 

Eagle Cap 

Pole Bridge Picnic 

Area 0.1 0.1 

Total 0.6 2.6 0.5 3.7 

Blackhorse 

Campground 0.4 0.4 

Buck Creek NRA 

Trailhead 0.4 0.4 

Buckhorn 

Tower/Overlook 2.6 2.6 

Hells Canyon 

NRA 

Cache Creek 0.2 0.9 1.1 

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379 

Acres of Proposed Treatments Ranger District and 

Site Name Biocontrol Chemical Chemical 

Riparian Total 

Ranch Interpretive 

Site 

Circle C Ranch 

Admin. Site 3.5 3.5 

Copper Creek 

Private Resort 2.1 2.1 

Coverdale 

Campground 0.5 0.5 

Cow Creek 

Trailhead 0.5 0.5 

Dug Bar Boat 

Launch/Trailhead 0.3 4.0 4.3 

Evergreen 

Campground 0.6 0.6 

Gumboot Creek 

Fish Interpretive 

Site 

1.4 1.4 

Hat Point Day Use 

Area 6.8 0.5 7.3 

Hells Canyon 

Creek Boat Launch 5.0 5.0 

Hidden 

Campground 0.4 0.4 

Imnaha River Fish 

Weir 1.3 1.3 

Indian Crossing 

Trailhead 3.1 3.1 

Kirkwood Ranch 

Interpretive Site 1.3 1.3 

Lake Fork 

Campground 4.5 4.5 

Lake Fork Creek 

Trailhead 1.1 1.1 

Lick Creek 

Campground 3.4 3.4 

Mountain Chief 

Mine Tunnel 0.3 0.3 

North Pine 

Roadside Rest 

Stop 

1.3 1.3 

Ollokot 

Campground 0.7 0.7 

P.O. Saddle 

Trailhead 0.3 0.3 

Pittsburg 

Campground 2.0 2.0 

Pittsburg Landing 1.8 1.8 

Pittsburg Rock Art 

Interpretive Site 5.3 5.3 

Sacajawea Camp 5.6 0.1 5.7 

Snake River 

Trailhead 6.5 6.5 

Upper Crazyman 0.5 0.5 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Acres of Proposed Treatments Ranger District and 

Chemical 

Riparian 

Site Name Biocontrol Chemical Total 

Trailhead 

Upper Pittsburg 

Landing 0.2 0.2 

Total 12.9 29.7 26.8 69.4 

Bird Track 

Interpretive 

Trailhead 

6.0 6.0 

Bird Track Springs 

Campground 0.1 0.1 

Blue Springs 

Recreation 

Residences 

0.1 0.1 

Catherine Summit 

Snow Park 0.1 0.1 

Frog Heaven 

Forest Camp 5.2 5.2 

Main Eagle 

Trailhead 1.1 1.1 

Moss Springs 

Guard Station 0.1 0.1 

North Fork 

Catherine Group 

Camp 

0.2 0.2 

Park Saddle 

Trailhead 0.9 0.1 1.0 

River Campground 0.3 0.3 

Sand Pass 

Trailhead 0.1 0.1 

Spool Cart 

Campground 2.2 2.2 

La Grande 

Spring Creek 

Bunny Hill 1.0 1.0 

Total 5.2 8.2 4.1 17.5 

Halfway Picnic 

Area 3.6 3.6 

Martin Bridge 

Trailhead 0.5 0.1 0.6 

McBride 

Campground 0.7 0.7 

Pine 

Tamarack 

Campground 0.3 0.2 0.5 

Total 1.5 3.9 5.4 

Antlers Guard 

Station 3.9 3.9 

Blue Springs Snow 

Park 0.4 0.4 

Long Creek Forest 

Camp 2.0 2.0 

Unity 

Mammoth Spring 

Campground 1.4 1.4 

Total 0.4 7.3 7.7 

Wallowa- Chico Trailhead 0.8 0.8 

Valley Salt Creek Summit 0.5 0.5 

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Acres of Proposed Treatments Ranger District and 

Chemical 

Riparian 

Site Name Biocontrol Chemical Total 

Snow Park 

Tenderfoot 

Trailhead 0.2 0.2 

Total 1.5 1.5 

Grand Totals 18.7 59.6 59.9 138.2 

Alternative C - No Broadcast Application in Riparian Habitat Conservation Areas 

This alternative would have the same effects as the Proposed Action; however, invasive plants 

within riparian zones would receive an individual plant type application of herbicide or an 

alternate treatment type. Overall, less herbicide would be used by targeting individual plants. 

There would be less chance for herbicide to drift to the areas commonly used by visitors such as 

picnic tables, campsites, water sources and bathroom facilities. 

Alternative D - No Aerial Application 

There are no aerial treatments are proposed in or adjacent to developed recreation sites. This 

alternative would have the same effect as those described in the Proposed Action. 

Effects on General Forest Area 

Alternative A - No Action 

Of 22,842 acres of known invasive plants, only 5,172 acres would be treated. The remaining 

acres could be treated by manual methods. Manual treatments are less practical and effective for 

treating large infestations. Invasive plants would be expected to continue to spread throughout 

the forest. 

Effects Common to all Action Alternatives 

Direct and Indirect Effects 

Approximately 12,101 acres of the general forest area would be treated for invasive plants. 

These acres occur along roads, trails, quarries, rangelands, parking areas and dispersed sites as 

well as forest lands. Approximately 10,352 acres would be treated with herbicides. These acres 

are not associated with developed recreation facilities, wilderness, wild and scenic rivers or 

national recreation areas. 

The forest visitor is most likely to encounter invasive plant treatments while traveling through an 

area on a forest road. They may notice dead vegetation, signs informing visitors that an area has 

been treated with herbicides or people with equipment applying herbicides. 

Non-motorized trail users such as hikers and pack stock users are typically traveling at a slow 

pace and dead vegetation immediately adjacent to trails would be noticeable. Non-motorized 

trails users may be more likely to come in contact with vegetation treated with herbicides by 

walking along recently treated trail areas. 

Motorized trail users will also notice dead vegetation but should pass through an area faster than 

non-motorized users. Motorized trail users would be less likely to come in contact with 

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vegetation treated with herbicides as the trail tread is maintained to a width that accommodates 

the motorized vehicle. 

Visitors gathering mushrooms, berries and other forest products may be displaced to areas where 

herbicides have not been applied. Refer to the Pacific Northwest Region Final Environmental 

Impact Statement, Preventing and Managing Invasive Weeds, 2005 for discussion of human 

health and safety regarding exposure to herbicides. 

Trailheads would be posted alerting recreationists to the fact that herbicides have been applied to 

vegetation along the trail. This may cause recreationists to choose to recreate elsewhere, 

regardless of the trail type. All other indirect effects would be similar to those described as 

common to recreation for all action alternatives. 

Alternative B - Proposed Action 

Approximately 266 acres of aerial application of herbicide are proposed within the general 

forest. These areas would be closed to the public during aerial operations and posted to inform 

visitors that herbicides have been applied. There are no trails or facilities near these sites. The 

general forest area would be closed to public access only during the aerial application operations. 

This impact would be short term. 

Other effects would be similar to those described as common to recreation for all action 

alternatives. 

Table 72-Acres of proposed treatment by recreation area 

Acres of Proposed Treatment 

Recreation Area 

Biocontrol Chemical Chemical Aerial Manual Total 

HCNRA 44 7083 166 57 7350 

Wilderness 100 348 526 5 979 

WSR 84 2177 0 13 2274 

Developed Recreation 18 120 0 0 138 

General Forest Area 1709 10086 266 40 12101 

Grand Totals 1955 19814 *875 115 22,842 

*Note that approximately 83 acres within proposed aerial sites cannot be treated due to riparian buffer restrictions and 

would need alternative treatments (i.e ground based treatments: chemical, biological, physical). 

Alternative C - Restricted Use – No Broadcast Herbicide Application in Riparian 

This alternative would have the same effects as the Proposed Action, however; invasive plants 

that are proposed for chemical treatment in riparian areas would be treated with non-broadcast 

herbicide methods or an alternate treatment type. 

Alternative D - No Aerial Application 

This alternative would have the same effects as the Proposed Action, however; approximately 

266 acres of invasive plants identified for aerial application of herbicide would receive an 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

alternate form of broadcast herbicide application, biocontrol measures if they are available for 

the species involved or receive a combination of various treatment methods that would be 

applicable to the site. Depending on site conditions, biocontrol measures may be less effective 

(see Botany report). 

Cumulative Effects 

The cumulative effects discussion considers past, present and reasonably foreseeable actions that 

occur within the analysis area. These actions include existing, ongoing and planned vegetation 

management, grazing and recreation activities. 

The cumulative effects analysis area for the recreation resource is the Wallowa-Whitman 

National Forest and other public lands within and adjacent to the forest boundary. Recreationists 

move between public lands regardless of managing agency for recreation purposes. 

Short term effects are associated with invasive plant treatment methods, especially use of 

herbicides, and the impact they have on the recreationist’s desire to recreate in an area. Long 

term effects are related to the presence of invasive plants and how they may alter the natural 

environment or detract from the desirability of using recreation sites and participating in certain 

recreational activities. 

The effects to recreation associated with invasive plant treatments are short term. It is unlikely 

that all recreation facilities, trails, wilderness areas or WSR’s would be treated at the same time. 

Recreationists that are displaced due to their concern about herbicide exposure can recreate in 

alternate facilities or other areas. Similar recreation opportunities would be available that have 

not been treated with herbicides. 

Compliance with the Forest Plan and Other Regulatory Direction 

The alternatives analyzed comply with the management direction for recreation provided in the 

Wallowa-Whitman Land and Resource Management Plan and federal regulations and policies 

concerning the recreation resource. 

3.7 Effects of Herbicide Use on Workers and the Public 

3.7.1 Introduction 

This section focuses on the health effects to workers and the public if herbicide treatments are 

applied to invasive plants as proposed in the alternatives. The R6 2005 FEIS and its Appendix Q: 

Human Health Risk Assessment detailed the potential for health effects from the use of the 

herbicides proposed for this project. Herbicide active ingredients, metabolites, inert ingredients, 

and adjuvants and people with particular herbicide sensitivity were addressed. The R6 2005 

ROD adopted standards to minimize herbicide exposures of concern to workers and the public 

based on the human health risk assessments. Herbicides are an important component of the 

integrated weed management methods needed to meet the purpose and need for this project. 

Site-specific PDFs were developed to minimize or eliminate exposures of concern to workers 

and the public, plausible given the regional standards. The PDFs require that herbicides and 

surfactants are used in rates low enough, or that methods are selective enough, to avoid 

exposures of concern to workers and the public. 

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Many people expressed concerns about the effects of herbicides on human health in their 

response to scoping. People wondered if they could be sickened by brushing up against 

contaminated vegetation, or by eating berries, mushrooms, fish or game that may have been 

exposed to herbicides. They worried that they might drink water contaminated by herbicides. 

People expressed concern about the health and safety of forest workers who are more likely to be 

exposed to herbicides. Some believe that the potential cost to human health is too high and other 

methods should be used to treat invasive plants. 

Workers and the public may be exposed to herbicides used to treat invasive plants under all 

alternatives in this project; however, no exposures exceeding a threshold of concern are 

predicted. This conclusion is based on facts about the chemistry of the herbicides considered for 

use, and the mechanisms by which exposures of concern might occur. Scientific risk assessments 

do not indicate that any person would be adversely affected in any way by these herbicides used 

in the manner proposed for this project. This applies to all alternatives. 

The R6 2005 FEIS evaluated human health risks from herbicide and non-herbicide invasive plant 

treatment methods. Hazards normally encountered while working in the woods (strains, sprains, 

falls, etc) are possible for herbicide and non-herbicide invasive plant treatment operations. Such 

hazards are mitigated through worker compliance with occupational health and safety standards 

and are not a key issue for this project-level analysis. 

The human health hazards associated with each herbicide active ingredient were evaluated and 

estimated by a thorough review of available toxicological studies. Possible health effects may 

include short-term and long-term adverse effects. Short-term effects may include: nausea, 

headache, dizziness, eye or skin irritation, and coughing. Long-term effects may include: cancer; 

reproductive, endocrine, immunologic, and neurologic effects, and genetic mutations. 

Estimates of potential health risks for each herbicide as proposed for use in each alternative are 

based on herbicide risk assessments prepared for the Forest Service by Syracuse Environmental 

Research Associates (SERA). Forest Service/SERA risk assessments use peer-reviewed articles 

from the open scientific literature and current EPA documents, including Confidential Business 

Information. Specific methods used in preparing the Forest Service/SERA herbicide risk 

assessments are described in SERA, 2001. The risk assessment for the adjuvant NPE 

(nonylphenol polyethoxylate) was conducted and documented by David Bakke, Forest Service 

Pesticide-Use Specialist, consistent with the assumptions, methodologies, and protocols 

developed by SERA. The NPE Risk Assessment (Bakke, 2003), was peer-reviewed by SERA 

toxicologists and other Forest Service and independent experts; it is included in the “Forest 

Service/SERA herbicide risk assessments” used throughout this EIS. 

The toxicological database for each herbicide was reviewed for acute, subchronic, and chronic 

effects in laboratory animal studies. Judgments about the potential hazards of herbicides to 

humans are necessarily based in large part on the results of toxicity tests on laboratory animals. 

Information on actual human poisoning incidents and effects on human populations supplements 

the laboratory animal test results, where such information is available. For a background 

discussion of all toxicological tests and endpoints considered in Forest Service Risk 

Assessments, refer to SERA, 2001. Additional SERA references are in Section 3.1.5. 

Herbicide formulations may contain additional compounds besides the herbicide active 

ingredient; these are termed impurities or inert ingredients. Other additives, called adjuvants and 

surfactants, may be mixed with the diluted formulation before spraying to either enhance the 

herbicide activity or to modify undesirable properties of the spray mixture. Additionally, when 

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organisms in the environment internalize chemical herbicide formulation in their physiologic 

systems, they may transform them into other compounds called metabolites. Of these categories 

of substances, only the NPE group of surfactants has been tested and data produced that identify 

specific and quantifiable hazards to human health (Bakke, 2004). 

The following terminology describes relative toxicity of herbicides proposed for use. 

Exposure Scenario: The way a person may be exposed to herbicide active ingredients or 

additives. How much herbicide a person may be exposed to is influenced by the application 

rate and method. 

Threshold of Concern: A level of exposure below which the potential for adverse effects 

to a person is low. This level was made more conservative in the R6 2005 FEIS to add a 

margin of safety to the risk assessment process. 

Hazard Quotient (HQ): The amount of herbicide or additives to which a person may be 

exposed over a specified period, divided by the estimated daily exposure level at which no 

adverse health effects are likely to occur. An HQ less than or equal to one indicates an 

extremely low level of risk; therefore, an HQ less than or equal to one is presumed to 

indicate a level of exposure below the threshold of concern for adverse health effects. 

All alternatives are designed to limit exposures to herbicides by workers and the public to levels 

below a hazard quotient of 1, meaning that adverse health effects are unlikely to occur. This is 

done by limiting the potential for exposure so that it is below a threshold of concern, based on 

the risk assessment information. Even with a hazard quotient of less than 1, a person could still 

become sick. Some people may be particularly sensitive to individual chemicals and affected at 

very low doses. 

People live near, spend time in, work in, drink water from, and depend on the forest and forest 

products from the Wallowa-Whitman National Forest. Thus, while the likelihood of harmful 

exposure is very low, there remains high concern about the impact of herbicide use to public and 

worker health. 

3.7.2 Affected Environment 

Infested sites are scattered and occupy less than three percent of National Forest System lands; 

however they transcend forest boundaries onto other privately owned land. Therefore, invasive 

plant treatments are implemented in partnership with the local counties, and at times other 

partners. Municipal watersheds, dispersed and developed recreation areas (trailheads, 

campgrounds, picnic areas, recreation sites, work centers, etc), and special forest product 

collection areas are currently near invasive plant sites. Municipal watersheds are described in 

Chapter 3.4. Recreation areas are described in Chapter 3.6. 

Special forest products such as blackberries, huckleberries, salal, bear grass, mushrooms and 

herbs are gathered for personal use and commercial sale. People who harvest special forest 

products may have more contact with sprayed vegetation than other forest visitors. People who 

gather special forest products tend to be ethnically diverse. A recent unpublished study of 

commercial permit holders demonstrated that the largest ethnic groups involved with forest 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

product gathering are Hispanics and Southeast Asians (Khmer, Khmer Krom, Laotian and 

Vietnamese). 

Crews often come from the communities located near the National Forest. Herbicide applicators 

are required to be licensed and well-trained in safe handling and application practices. 

Environmental Justice and Disproportionate Effects 

The R6 2005 FEIS found that some minority groups may be disproportionately exposed to 

herbicides, either because they are disproportionately represented in the pool of likely forest 

workers, or they are disproportionately represented in the pool of special forest product or 

subsistence gatherers. The R6 2005 FEIS suggested that Hispanic forest workers and American 

Indians may be minority groups that could be disproportionately affected by herbicide use. 

Hispanic and non-Hispanic herbicide applicators would be more likely to be exposed to 

herbicides than other people. Contractors for the Forest and/or County would likely apply 

herbicide treatments. County invasive plant control departments do not indicate that they employ 

any specific population group that could be disproportionately affected during invasive plant 

treatments. 

Regardless, effects to all county or contract employees engaged in invasive plant control would 

be negligible due to Project Design Features and compliance with occupational health and safety 

standards. 

People of Hispanic and Southeast Asian (Khmer, Khmer Krom, Laotian and Vietnamese) descent 

are minority groups that tend to gather mushrooms; however, no mushrooms are target species 

and Project Design Features are in place to protect fungi. Whenever herbicide treatment is going 

to happen, the Forest will notify tribes, plant collectors and the general public with media 

postings, handouts attached to permits, annual tribal contacts and on-the-ground signing. 

Information about invasive plant treatments would be added to existing multi-lingual mushroom 

gathering permit material to eliminate inadvertent exposures if appropriate. Some areas may be 

closed to gathering following treatment to avoid exposures. Even given plausible inadvertent 

exposures, the HQ values would not exceed the threshold of concern. 

3.7.3 Environmental Consequences 

Alternative A - No Action 

The herbicides and herbicide applications approved in No Action were previously analyzed in 

the 1995 EA. No significant potential risks to health for workers or the public were associated 

with the 1995 project. See the Environmental Justice section in Chapter 3.9.4 for more 

discussion regarding adverse impacts from No Action. 

Action Alternatives 

All three action alternatives allow for the use of ten herbicides according to label requirements, 

LRMP standards and PDFs. As shown in Chapter 2, some herbicides are more likely to be used, 

based on the range of herbicides that can effectively treat existing known sites. 

Table 73 below shows the relative likelihood that certain herbicides may be used. Please note 

that in some cases, more than one herbicide may be effective, so the acreage shown is far more 

than would actually be treated by any one of these herbicides but provides the basis for the 

relative likelihood that each may be used. The analyses of effects to human health are based on 

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387 

8,000 acres per year being treated over a ten to fifteen year period. This is more than double the 

budget estimate so is likely to be a high estimate of acres treated. Because each application of 

herbicide would be designed as low risk (HQ less than 1), the extent of treatment in a given year 

has little influence on the actual risk to human health3

. However, the more acres treated, the 

greater the potential for accidental exposure, such as a worker accidentally spilling a small 

amount of herbicide on a bare hand. Such exposures are expected to be rare and small scale, 

based on past experience with similar projects (Rochelle Desser, personal communication, 

2008). The herbicide risk assessments assume worst case exposure scenarios such as direct 

contact with herbicides by a member of the public or a worker. Even with direct contact, risks 

from this project would be relatively low (activity associated with an HQ less than 1 as modeled 

in herbicide risk assessments). 

Table 73-Herbicides and potential effectiveness 

Active Ingredient 

Selected Herbicide Brand Names 

Acres of known sites where 

this herbicide may be 

effective 

Percentage of known sites 

where this herbicide may be 

effective 

Chlorsulfuron 

(Telar, Glean, Corsair) 12,841 53 

Clopyralid 

(Transline) 18,408 75 

Glyphosate35 formulations, 

including RoundUp, Rodeo, Accord 

XRT, Aquamaster 

15,863 65 

Imazapic 

(Plateau) 3,325 14 

Imazapyr 

(Arsenal, Arsenal AC, Chopper, 

Stalker, Habitat) 

15 3 

Metsulfuron methyl 

(Escort XP) 11,287 46 

Picloram 

(Tordon K, Tordon 22K) 21,406 91 

Sethoxydim 

(Poast, Poast Plus) 948 4 

Sulfometuron methyl 

(Oust, Oust XP) 2,471 10 

Triclopyr 

(Garlon 3A, Garlon 4, Forestry 

Garlon 4, Pathfinder II, Remedy, 

Remedy RTU, Redeem R&P) 

3,671 15 

Worker Exposure to Herbicides 

Applicator exposure to herbicides is influenced by the application rate selected for the herbicide; 

the number of hours worked per day; the acres treated per hour; and variability in human dermal 

 

3

 Triclopyr is associated with some exposure scenarios where the HQ is greater than one for herbicide use 

allowed under all alternatives (based on worst case modeling in the risk assessments). Triclopyr is one of 

the least likely herbicides to be used and PDFs have been specifically proposed to minimize the risk of 

exposures over a level of concern. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

absorption rates. In routine broadcast and spot applications, workers may contact and internalize 

herbicides mainly through exposed skin, but aso through the mouth, nose or lungs. Contact with 

herbicide formulations may irritate eyes or skin. 

Appendix Q: Human Health Risk Assessment in the R6 2005 FEIS displayed risks for typical 

and maximum label rates under a range of conditions. Four potential exposure levels were 

evaluated for workers, ranging from predicted average exposure (typical application rate-typical 

exposure variables) to a worst-case predicted exposure (maximum application rate-maximum 

exposure variables). 

Accidental worker exposures are most likely to involve splashing a solution of herbicides into 

the eyes or on the skin. Two general types of exposure were modeled: one involving direct 

contact with a solution of the herbicide and another associated with accidental spills of the 

herbicide concentrate onto the surface of the skin. For this risk assessment, two exposure 

scenarios are developed for each of the two types of dermal exposure, and the estimated 

absorbed dose for each scenario is expressed in units of mg chemical/kg body weight. 

Exposure scenarios involving direct contact with herbicide solutions are characterized by 

immersing unprotected hands for 1 minute or wearing contaminated gloves for 1 hour. While it is 

unlikely that workers would immerse their hands in herbicide solutions, the contamination of 

gloves or other clothing is possible. For these exposure scenarios, the key element is the 

assumption that wearing gloves saturated with a chemical solution is equivalent to immersing the 

hands in a solution. 

In either case, the concentration of the chemical in solution that is in contact with the surface of 

the skin and the resulting dermal absorption rate are essentially constant. Exposure scenarios 

involving chemical spills onto the skin are characterized by a spill onto the lower legs as well as 

a spill on to the hands. In these scenarios, it is assumed that a solution of the chemical is spilled 

on to a given surface area of skin and that a certain amount of the chemical adheres to the skin. 

The ten herbicides proposed for use under the action alternatives, used at rates and methods 

consistent with PDFs, have little potential to harm a worker or a member of the public. In most 

cases, even when maximum rates and exposures were considered, HQ values were below the 

threshold of concern (HQ values ranged from 0.01 to 1). 

There are two exceptions to this finding in Appendix Q of the R6 2005 FEIS: the herbicide 

triclopyr and the surfactant NPE. Even at typical rates, there is potential for a worker to be 

exposed to herbicide over a threshold of concern from spot spraying triclopyr, especially the 

Garlon 4 formulation. Broadcast of the surfactant NPE at typical rates may also result in worker 

exposure over a level of concern. 

PDFs eliminate this exposure scenario by favoring use of Garlon 3A, minimizing application 

rates of all triclopyr formulations, and following safe work practices and label advisories. Far 

less than 1 percent of the Forest would be treated annually. 

Public Exposure to Herbicides 

The general public would not be exposed to harmful levels of any herbicides used in the 

implementation of this project. R6 2005 FEIS Appendix Q considered the plausible direct, acute 

and chronic exposures from herbicide ingredients. The Forest Service/SERA risk assessments 

considered acute exposures and longer-term or chronic exposures. 

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Acute exposures assume that a person has contact with the herbicide either during or shortly 

after an application. Specific scenarios estimate herbicide doses received from direct spray, from 

dermal contact with sprayed vegetation, or from consumption of contaminated fruit, water or 

fish. Direct spray scenarios assume that a naked child is completely covered with herbicide 

during a broadcast ground herbicide application. The assumption of 100 percent body coverage 

with herbicide is much greater than would plausibly happen in a real-world accidental overspray. 

An additional set of scenarios are included involving a young woman who is accidentally 

sprayed over the feet and legs. Detailed summaries of the public exposure scenarios can be 

found in Forest Service/SERA Risk Assessments. 

Risk assessments indicate there is a potential for harm to a woman or child directly sprayed with 

triclopyr. There is virtually no chance of a person being directly sprayed given spot and 

hand/select methods considered for this project. 

Exposures exceeding a level of concern also could occur if a person accidentally contacts 

vegetation spot-sprayed with triclopyr (Garlon 4). Direct contact is implausible because of the 

high degree of operator control inherent in spot spraying. In addition, the use of Garlon 4 is 

further limited by the PDFs (there would be no use of Garlon 4 would be allowed within 150 feet 

of any water body or stream channel; Garlon 4 would be avoided in special forest product 

gathering areas, campgrounds, or administrative sites). Forest product gathering areas, 

campgrounds and administrative sites may be closed immediately after Garlon 3 application to 

prevent accidental exposures. 

An analysis was also conducted to determine whether people could be sickened from eating fish, 

berries, or mushrooms (etc) exposed to herbicide. Several exposure scenarios for recreational 

and subsistence fish consumption were considered in the SERA Risk Assessments; none are near 

any herbicide exposure level of concern. Fish contamination is unlikely given the Project 

Design Features that reduce potential herbicide delivery to water. 

The R6 2005 FEIS and Appendix Q disclosed exposure scenarios for both short term and chronic 

consumption of contaminated berries. These scenarios also approximate the effects of eating 

other contaminated products, such as mushrooms (Durkin and Durkin 2005).” Of the ten 

herbicides considered in this project, triclopyr was the single herbicide with exposure scenarios 

exceeding a level of concern if berries or mushrooms containing herbicide residue were 

consumed. To respond to this concern, PDFs limit the application methods and rate of 

application for triclopyr and NPE. Special forest product gathering areas may be closed to public 

use immediately after triclopyr application and NPE application to avoid inadvertent exposure. 

Restricting the application rate, method and location of use of Garlon 4 and NPE would reduce 

the potential exposure in all alternatives to below a threshold of concern. 

People who harvest and consume special forest products may be exposed through directly 

handling contaminated plant material, then chewing or eating it. Such doses would be additive, 

but are still unlikely to exceed a threshold of concern (see Cumulative Effects, below). 

Acute longer-term or chronic exposures from direct contact or consumption of water following 

herbicide application were also evaluated in the R6 2005 FEIS. Risks from two hypothetical 

drinking water sources were evaluated: 1) a stream, contaminated with herbicide residues by 

runoff or leaching from an adjacent herbicide application; and 2) a pond, into which the contents 

of a 200-gallon tanker truck that contains herbicide solution is spilled. The only herbicide 

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scenarios of concern would involve a person drinking from a pond contaminated by a spill of a 

large tank of herbicide solution. 

The risk of a major accidental spill is not linked in a cause-and-effect relationship to how much 

treatment of invasive plants is projected for a particular herbicide; a spill is a random event. A 

spill could happen whenever a tank truck involved in an herbicide operation passes a body of 

water. 

The potential risk of human health effects from large herbicide spills into drinking water are 

mitigated by Project Design Features that require an Herbicide Transportation and Handling Plan 

be developed as part of all project safety planning, with detailed spill prevention and remediation 

measures to be adopted. 

Cumulative Effects 

Cumulative Effects of All Alternatives 

Workers and the public may be exposed to the herbicides used to treat invasive plants under all 

alternatives in this project. However, exposures exceeding a threshold of concern are not likely 

to occur. This conclusion is based on facts about the chemistry of the herbicides considered for 

use and the mechanisms by which exposures of concern might occur. 

The proposed use of herbicides in all alternatives could result in multiple or additive doses of the 

same or different herbicides to workers or the general public. People could conceivably be 

exposed to herbicides in more than one place on the Forest, or elsewhere. However, the 

herbicides proposed for use do not bioaccumulate in humans and are rapidly eliminated from the 

body. Thus, chronic exposures are not likely to add up in the body. In addition, the extent of 

treatment is limited to far less than one percent of the Forest, widely distributed. This reduces 

the potential for repeated exposures to any member of the general public. 

Chronic (daily over a period of time) worker exposure was considered in SERA Risk 

Assessments; no chronic exposures reach a level of concern. Chronic public exposure was also 

assessed, including repeated drinking of contaminated water, repeated consumption of 

contaminated berries, and repeated consumption of contaminated fish. No chronic exposure 

scenarios were over a level of concern for the public. 

A person could be exposed to herbicides by more than one scenario; for instance, a person 

handling, and then consuming sprayed berries. The cumulative impact of such cases may be 

quantitatively characterized by adding the HQs for each exposure scenario. Using glyphosate as 

an example, the typical levels of exposure for a woman being directly sprayed on the lower legs, 

staying in contact with contaminated vegetation, eating contaminated fruit, and consuming 

contaminated fish leads to a combined (acute) HQ of 0.012. Similarly, for all of the chronic 

glyphosate exposure scenarios, the addition of all possible pathways lead to HQs that are two 

orders of magnitude less than 1, indicating an acceptable level of cumulative risk even with 

multiple exposure scenarios. 

Even if a herbicide with a greater hazard quotient than glyphosate was used, berry harvesting 

(dermal exposure) and the subsequent eating (oral exposure) would allow the body to metabolize 

some of the initial dose before receiving the second dose, thus reducing the cumulative dose. 

These factors make the risk implausible that a combined dose would exceed the threshold of 

concern. 

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The R6 FEIS considered the potential for synergistic effects of exposure to two or more 

chemicals: “Combinations of chemicals in low doses (less than one tenth of Rf ) have rarely 

demonstrated synergistic effects. Review of the scientific literature on toxicological effects and 

toxicological interactions of agricultural chemicals indicate that exposure to a mixture of 

pesticides is more likely to lead to additive rather than synergistic effects (ATSDR, 2004; 

U.S.EPA/ORD, 2000). Based on the limited data available on chemical combinations involving 

the twelve herbicides considered in this EIS, it is possible, but unlikely, that synergistic effects 

could occur as a result of exposure to the herbicides considered in this analysis. Synergistic or 

additive effects, if any, are expected to be insignificant” (USFS 2005a, p. 4-3). 

Herbicides are sometimes used in combination with additives such as surfactants. NPE 

surfactant has been associated with human health risks at certain exposure levels. NPE has 

estrogen-like properties, although they are much weaker (1,000 to 100,000 times weaker) than 

natural estrogen. NPE is widely used and present in personal care products (moisturizers, 

deodorants, perfumes, shampoos, and soaps) and detergents. Animal studies suggest that acute 

exposures at high levels may cause subclinical effects to the liver or kidneys. 

The risk analysis for NPE (Bakke 2004) found that typical backpack application of herbicide 

containing NPE surfactant at typical exposures and a rate of 1.67 lbs/acre would add 0.1 to the 

cumulative HQ for these types of chemicals. For the public, values ranged between 0.00001 

(eating contaminated fish) to 0.2 (consuming a pound of berries at typical exposures). These are 

relatively small increases in hazard and do not significantly increase the potential for cumulative 

effects from use of NPE surfactant and herbicides. 

3.8 Rangeland Resources 

3.8.1 Introduction 

A large proportion of the Wallowa-Whitman National Forest (85%) is appropriated into range 

allotments. Many of the currently documented invasive plant sites (99%) are therefore also 

located within these allotments. Numerous factors contribute to the establishment and spread of 

invasive species, one of which can be ungulate grazing and browsing. This concern is addressed 

in the allotment management planning process. The purpose of this project is to begin 

containing, controlling or eradicating invasive plant species within the direction found in the 

record of decision signed for the Pacific Northwest Regional Invasive Plant Program. 

All action alternatives require incorporation of invasive plant prevention practices (R6 2005 

ROD) in annual operating instructions and/or allotment management plans. Impacts to livestock 

operations will be isolated and limited in scale because most invasive plant populations are 

relatively small in size and represent less than 1.1% of the total grazing allotment areas forestwide. 

Domestic and wild grazing animals contribute to invasive plant establishment and spread 

through selective eating, redistribution of invasive plant seeds in scat, skin, fur and/or hooves, 

and soil disturbance creating conditions favorable for seed germination. Historically, several 

intentional and unintentional introductions of invasive plants into native plant communities have 

been associated with livestock management, resulting in widespread invasions (Baker 1974; 

Sheley and Petroff 1999). Healthy and vigorous vegetation capable of resisting weed invasion is 

possible through proper grazing methods (Sheley, et al., 1996). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

3.8.2 Affected Environment 

Presently 85 percent of the Wallowa-Whitman National Forest is appropriated into cattle grazing 

range allotments (1,956,536 acres, based on INFRA data located at the Wallowa-Whitman 

National Forest Supervisors Office). There are 151 allotments (designated active, vacant, and 

closed) in which 99 percent of the invasive species sites (1715 of the 1740) are located. These 

sites represent approximately 96 percent of the infested acres forest wide (21,957 acres of the 

total 22,802 infested acres forest wide). Allotment acres, and invasive weeds identified within 

allotments are presented in Table 74. 

Table 74-Invasive weed acres presently identified within each allotment type 

Allotment Use Allotment acres Invasive weed 

acres 

Percent of 

Allotment acreage 

occupied by 

Invasive Plants 

Percent of Total 

Forest Land base 

infested with 

Invasive Plants 

Active 1,276,465 16,207 1.3 0.7 

Closed 264,339 2,955 1.1 0.1 

Vacant 415,732 2,795 0.7 0.1 

Total 1,956,536 21,957 3.1 0.9 

Common bugloss, diffuse knapweed, Canada thistle, yellow starthistle, scotch thistle and 

whitetop are invasive species that are most prevalent in the allotments forest-wide (Table 70). 

The invasive weed acres are reported as gross acres infested where invasive species are often 

scattered within a site.The common bugloss site is one large infested site located along the 

Imnaha River spread across 13 allotments. The level of infestation within forest service land 

ownership boundaries is variable with the most heavily infested areas occurring in the river 

bottoms and meadows and decreasing in elevational gain along the terraced areas. Bugloss is 

concentrated into clumps throughout the landscape with unaffected acres between the bugloss 

clumps. Private lands adjacent to this site are also infested with bugloss. 

Diffuse knapweed and Canada thistle are commonly found on roads and other disturbed areas 

within allotments. Yellow starthistle sites are found in large acreages within HCNRA in hot dry 

grassland habitats 

Some of the largest yellow starthistle infestations are located in the Canyon (closed allotment), 

Rhodes Creek and Lone Pine allotments west of the Snake River in HCNRA, in the Indian Creek 

allotment bordering private and state lands on the LaGrande District, and bordering both sides of 

Cottonwood creek in the Goosecreek allotment on the Whitman District. 

Scotch thistle is commonly associated with roads, and disturbance throughout the forest with 

higher concentrations in the Tope Creek and Bear Gulch allotments (Wallowa Valley District) 

and near streams (intermittent and perennial) throughout allotments in the HCNRA. Whitetop is 

also commonly associated with disturbance areas, roads, and streams and other disturbed areas. 

Some of the higher concentrations are located in the Dodson-Haas allotment bisected by the 

Imnaha River and the Big Canyon vacant allotment east of the Snake River both within the 

HCNRA. 

Dispersal vectors for diffuse knapweed, Canada thistle. yellow starthistle, scotch thistle and 

whitetop is primarily by wind (Miller et al 2006, CWMA 2007), however, these seeds and seed 

of other invasives present in the forest allotments can also be spread via vehicles, water transport 

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and animals (fur, hooves, and gastrointestinal ingestion and redistribution). In many instances 

cattle and other browsers will avoid areas invasive weeds are prevalent in large monocultures, 

and move to areas where there is desirable forage. In areas where invasive species are 

interspersed with desirable forage, it is likely that seed would either attach to fur or mud on 

hooves or even ingested and dispersed in feces. Some weed seeds are destroyed within the 

gastrointestinal tract; however, leafy spurge and spotted knapweed seeds can pass thru sheep, 

goats, and mule deer and some of the seeds still remain viable (Lacey et al. 1992). Leafy spurge 

seed was shown to be viable in feces 10 days post ingestion by mule deer. Long-lived seeds and 

hard seeded species of dicots and grasses consumed by grazers have been reported to survive 

passage thru gastrointestinal tracts of cows and grizzly bears (not know to exist on the forest) 

(Janzen 1984). It is suggested that land managers control movement of domestic ruminants and 

these animals should not be moved from infested areas to un-infested areas where viable seed is 

present on the stems. Another management strategy is to confine animals to a dry lot for 5 to 10 

days to allow any viable weed seeds to pass to ensure no further dispersal of invasive seed is 

possible (Sheley and Petroff 1999). 

Infestation sites range in size from one plant to numerous plants scattered over large acreages. 

The majority of inventoried sites are less than one acre in size and 66 percent of the sites are less 

than five acres in size (see Botany report for full description of site size, species compositions, 

and estimated levels of infestation). Acres of invasive species associated with forest roads 

including acres spreading out into areas beyond 100 feet of a road represent 20, 681 acres (91% 

of the presently identified acres forest wide). This does not implicitly imply that all these 

infested acres are caused by roads, but that a forest road exists within a calculated invasive site. 

Acres of invasive species within 100 feet of a road total 9,028 acres. Additionally, cattle often 

exhibit trailing behavior along fence lines that can result in disturbed areas for invasive species 

to establish. Estimates (of a worst case scenario) of fence lines with potential trailing impacts 

from cattle is suggested to be approximately 50% of fence lines in allotments forest-wide (M. 

Bulthuis, personal communication). This estimate would suggest that there is approximately 

2,348 additional acres where invasive species could establish. Presently, there are over 100 

invasive weed sites (representing approximately 79 acres) near fences (10 foot fence line 

corridor) located within the allotments on the Wallowa-Whitman National Forest (Table 75) 

(Wallowa-Whitman National Forest Geographical Information System (GIS) database 05/07). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 75-Invasive species acres in Wallowa-Whitman National Forest grazing allotments 

Invasive Species1 Estimates of Total Acres infested within 

Allotments2 

Common bugloss 5728.0 

Diffuse knapweed 3663.4 

Canada thistle 3181.0 

Yellow starthistle 1957.8 

Scotch thistle 1768.9 

Whitetop 1402.8 

Medusahead 893.8 

Houndstongue 858.3 

Spotted knapweed 808.2 

Dalmation toadflax 606.2 

St. John’s wort 405.6 

Rush skeletonweed 390.2 

Common crupina 284.2 

Sulphur cinquefoil 166.8 

Scotch broom 115.1 

Leafy spurge 100.2 

Knapweed species 83.7 

Tansy ragwort 75.2 

Yellow toadflax 47.3 

Russian knapweed 26.3 

Bull thistle 22.2 

Clary sage 21.9 

Musk thistle 21.5 

Yellow hawkweed 16.2 

Puncture fine 12.3 

Silverleaf nightshade 10.9 

Russian thistle 9.7 

Senecio species 8.4 

Teasel 8.1 

Dodder 7.2 

Poison hemlock 7.1 

Squarrose knapweed 6.6 

Toadflax species 3.8 

Field bindweed 3.3 

Purple loosestrife 2.5 

Dodder 2.4 

Pepperweed 0.7 

CYANO 0.6 

Meadow knapweed < 0.5 

Total Acres2 22,727 

1 For Scientific names see botany report 

2 Multiple species can occur on a site therefore some overlap in total gross acres may occur 

These acreages are gross acres where areas are delineated by the outer perimeter of the weed infestation and may 

contain significant areas that are not currently occupied by weeds. 

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Table 76-Range improvements and fencelines with potential for invasive species spread on the 

Wallowa-Whitman National Forest 

Range Improvement 

Number of 

improvements 

in active 

allotments 

Acres of 

high 

spread 

potential 

Water systems(spring, metal trough or tank with concrete bottom) 110 sites 110 

Handling Facility 1 lot 1 

Fences for Resource protection not associated with pasture boundary 160 miles 194 

Fence lines 3867 miles 2,3481 

Actual miles of fenceline and acres of invasive plants within 10 feet of 

fenceline 65 miles 79 

These acreages are gross acres where areas are delineated by the outer perimeter of the weed infestation and may 

contain significant areas that are not currently occupied by weeds. 

1 Based on 10’ wide path along 50% of fencelines in active allotments 

3.8.3 Environmental Consequences 

Direct and Indirect Effects 

This section will present the direct and indirect effects analysis for range resources. Issues 

presented during public scoping and effects related to range resources will be presented by 

alternative. 

A number of comments received during the scoping process suggested that the Forest Service 

consider prohibiting major land-use activities on National Forests that are associated with 

invasive weed spread including the elimination of livestock grazing. Elimination of these 

multiple-use activities is outside the scope of this EIS and is inconsistent with current laws 

governing the management of National Forest system lands. The action being considered is 

whether to treat invasive species and if so to what degree. 

The R6 2005 FEIS amended the existing Forest Plan, therefore, all action alternatives require 

incorporation of invasive plant prevention practices in annual operating instructions/plans and 

allotment management plans. The incorporation of these prevention practices are expected to 

reduce environmental impacts of cattle grazing forest wide. Ultimately, invasive plant prevention 

practices may result in some reduction to livestock grazing, but prevention of invasive plants is 

only one of several resource protection measures that reduce grazing such as range condition, 

stream protection, and endangered species management. For complete discussion of these 

practices in relation to range resources see the R6 2005 FEIS, Chapter 3. The effects analysis 

described in this document analyze the effects of the alternatives on grazing allotment permittees 

and range resources. As Project Design Features prevention standard #1 states, adjustments 

suggested to protect range resources will be addressed through existing administrative 

mechanisms such as grazing annual operating instructions and grazing permits. Suggestions to 

address invasive plants or potential introduction may include: 

• Changes in livestock movement patterns that require additional labor or may reduce 

AUMs for certain allotments 

• Alterations to season of use (length, turn-on, turn-off, etc.) and intensity of use that 

could reduce outputs and could include resting of pastures resulting in reduction of 

livestock use and output 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

• Passive restoration of native plant communities, which could require allotment resting 

for one to two seasons potentially reducing livestock use and output. In some cases 

fencing can be used to mitigate impacts 

• Delayed reintroduction of livestock following wildfires resulting in reduced livestock 

use and outputs over time 

An actual reduction in Animal Unit Month (AUM) attributed to invasive plant management 

cannot be quantified at the project scale due to unavailable data, variability between allotments, 

and the ongoing process of Allotment Management Plan revision. 

 Alternative A - No Action 

This alternative is legally required and forms the basis for comparison against the action 

alternatives. Under this alternative, there would be no change in current management direction 

or in the level of ongoing management activities. Currently, approximately 5,103 acres in 

grazing allotments are approved for treatment under the existing 1992 and 1994 Environmental 

Assessment. 

Invasive plants are currently damaging the ecological integrity of lands within and outside these 

allotments. Despite management direction in the ‘92 and ‘94 EA, invasive plants continue to 

increase and occupy previously uninfested areas. Invasive plants spread at a rate of 8-12 percent 

annually (R6 2005 FEIS) within National Forest System lands and neighboring areas, affecting 

all land ownerships. See existing condition section in the Botany report for estimates of invasive 

species growth forest wide based on current treatment effectiveness. As the current conditions 

change, and as invasive species continue to spread via common dispersal methods, management 

activities such as livestock grazing will be affected. Livestock and management actions 

associated with herding livestock have the potential to spread invasive species. The public could 

put more pressure on public land managers to implement more restrictive grazing strategies as 

the spread of invasive species becomes more widespread. 

Under current, allowable treatments, invasive weeds would likely continue to displace palatable 

native vegetation and could reduce forage on grazing allotments. Activities within allotments 

will continue to serve as seed dispersal vectors as these invasive species sites continue to grow. 

As described in the treatment effectiveness section of the botany report, loss of native plant 

communities may continue to occur as invasive weeds occupy and out-compete native species. 

Once invasive species begin to dominate these communities, a loss of species diversity, 

composition, and ecosystem function could occur. Invasive species would likely continue to 

spread into areas that are not currently infested. Established invasives would likely serve as seed 

sources for other areas of the Forest and nearby or adjacent other Federal, State or private lands 

Toxic species such as Canada thistle and leafy spurge would continue to increase under the No 

Action Alternative. Most of the Canada thistle is along roadsides and grazing animals would 

likely avoid these areas in search of more palatable forage elsewhere. Leafy spurge is present in 

very small patches (~1-2 acre areas, 100 acres forest-wide) located in numerous allotments forest 

wide. Due to the small sized patches, it is likely cattle will avoid these areas and no impacts to 

cattle from toxic properties from either of these two species will occur with this alternative. 

This alternative will not meet the desired future condition from the R6 2005 FEIS: “to retain 

healthy native plant communities that are diverse and resilient, and restore ecosystems that are 

being damaged, and to provide high quality habitat for native organisms throughout the forest, 

and assure that invasive plants do not jeopardize the ability of the forest to provide goods and 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

services communities expect.” Invasive species would continue to spread as documented from 

past inventories compared to the current inventories. 

Alternative B - Proposed Action 

The Proposed Action addresses problems posed by invasive plants that compromise our ability to 

manage native ecosystems on the Forest. New management direction and tools made available 

for use in Region 6 will be utilized. Analysis will tier to the R6 2005 FEIS, including the use of 

the newly approved herbicides as described in the document. There is a need to reduce the extent 

of specific invasive plant infestations at identified sites, and to protect uninfested areas through 

early detection rapid response from future establishment. 

Long-term effects of invasive weed treatments on the 124 active grazing allotments 

(approximately 16,200 acres) would be the retention of currently available forage, reduction in 

spread from existing and unknown future sites, and recovery of native vegetation in areas 

currently impacted by invasives. The maximum treatment rate is 8,000 acres per year and 

treatment sites will be prioritized at each individual district level. Livestock management 

activities that could be implemented on allotments with invasive plants include: change in timing 

and duration of grazing, change in distribution of livestock use, and requirements to only use 

weed free hay during potential quarantine periods. Operators may experience a slight loss of 

grazing opportunity however, many of the grazing strategies within allotments have deferred 

rotations and by focusing invasive weed treatments to the pastures during the resting phase 

would avoid most all potential impacts to operators. 

Some herbicides have label use restrictions that will be followed with reference to livestock 

grazing and/or slaughtering (see Table 7 in the Range Report) post herbicide treatment and 

subsequent exposure. As mentioned previously, treating pastures that are currently in rest due to 

grazing management rotations would eliminate any potential effects. If movement of livestock is 

not possible and pastures or allotments require treatment while animals are present all label use 

restrictions will be followed in addition to PDFs that require permittee notification prior to any 

proposed aerial application. In addition timely notification and coordination should occur during 

annual operating instruction/plan meetings (R6 2005 ROD). For aerial herbicide application 

within allotments, permittees would be notified of proposed expected timeframes for treatment 

to allow the option to remove animals. No adverse effects to large mammals was found from 

direct spray of herbicides that could be applied aerially even at the highest expected rates (R6 

2005 FEIS SERA Risk Assessment-Effects to Wildlife), and only typical application rates as 

described in Chapter 2 of this EIS is proposed for aerial application of herbicides. There are 

presently approximately 873 acres proposed for aerial application of herbicides within grazing 

allotments. PDFs that limit aerial applications in certain areas (i.e. proximity to streams) would 

decrease these proposed initial areas. Additionally, these proposed acres represent worst case 

scenario and actual treated areas would likely be much lower that currently mapped areas (see 

Botany report description of aerial sites). Most aerial sites are located in steep terrain with 

limited access areas where livestock generally do not prefer; however, PDFs would provide 

additional protection in the event stay grazing animals were present in areas. 

Under the Proposed Action it is acknowledged that more chemicals would be used in the 

environment while effectively treating invasive species compared to the No Action Alternative 

(See Table 16). 

The potential for a spill to occur during herbicide operations would be greater than under the No 

Action Alternative based on the additional number of acres that would be treated. Minimal to no 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

effects are anticipated to grazers or operators due to strict adherence to label handling directions 

and spill containment protocols in the unlikely event of a spill. 

There has been a concern that livestock grazing is a major cause of non-native plant invasions 

(Belsky and Gelbard 2000) and that removal of livestock would reduce one of the causes of 

invasive species spread. No manipulative studies with appropriate treatments and controls have 

rigorously tested this hypothesis. Additionally, no known manipulative experiments of grazing 

effects of wild ungulates on non-native plant species dynamics have been done (Parks et al. 

2005). Scientific support is growing for the hypothesis that large herbivores facilitate the 

invasion and establishment of non-native plants, however, substantial controversy exists about 

the specific process in time and space and the associated predictions of effects. 

Under this alternative treatment of invasive species including eradication at some locations, 

would allow grazing activities to remain much as they are under current conditions and would 

meet the desired future conditions within the project area. Additional benefits to this alternative 

would be the reduction of potential spread of invasive species into uninfested disturbed areas 

such as fencelines. Also, early detection and response for any newly established invasive species 

would occur. Compared to the No Action Alternative the impacts, especially long-term impacts, 

to permittees would potentially be reduced, because native and desirable non-native vegetation 

would increase. The treatment of existing and future documented sites under this alternative 

would positively affect range resources. 

Alternative C – No Broadcast Herbicide Application in Riparian Areas 

Alternative C proposes to meet the same objectives as stated in the Proposed Action, but intends 

to minimize impacts from chemical use in riparian areas. Specifically, this alternative does not 

allow broadcast herbicide treatments within riparian areas thereby reducing potential detrimental 

effects to aquatic and riparian ecosystems (reduced application of herbicides and less drift 

potential compared to Alternative B). For a full description of this alternative see Chapter 2 of 

the EIS and the Botany Report. This alternative would not allow broadcast as a method of 

herbicide treatment in approximately 2,500 riparian acres in allotments. This does not imply that 

all of the acres could or would be treated with broadcast methods, just that any invasive species 

that are presently known to occur or could occur in the future could only be treated with manual 

spot treatments and in accordance with all PDFs related to riparian areas listed in Chapter 2 of 

the EIS. Impacts to livestock and operators would be similar to those described in Alternative B. 

The potential for exposure of livestock and livestock managers will be slightly decreased as less 

chemical will be used within riparian areas. 

Alternative D - No Aerial Herbicide Application 

Under this alternative, most of the proposed aerial acres that would not be treated aerially would 

be treated with other methods however, may not be as effective at reducing invasive weeds (see 

Botany report for full description of alternative treatments proposed and areas not treated). It is 

expected that no impacts to forage availability will occur because the areas that would not be 

treated are generally in very steep terrain that most livestock would avoid. 

By not aerially treating, the potential for exposure to livestock and livestock managers will be 

reduced. Other benefits of this alternative would be the same as Alternative B. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Cumulative Effects 

This section will present cumulative effects analysis for range resources. The cumulative effects 

analysis area will be defined, the list of past, ongoing and reasonably foreseeable future actions 

will be disclosed, and the cumulative effects will be estimated. 

The cumulative effects spatial analysis area is the Wallowa-Whitman National Forest and nearby 

adjacent private, state and other federal lands. The time frame of the analyses includes the past 

20 years and the next 15 years which is expected to be the life expectancy of this document. 

Invasive species have been present and programs existed on the forest for the past 20 years; 

however, most Land and Resource Management Plans done in the late 1980s and early 1990s did 

not recognize specific details of the ecologic implications of invasive plants. 

Past, Present and Reasonably Foreseeable Future Actions 

Past management activities on the Forest in combination with the conservative approach to 

controlling invasive weeds has resulted in an increase in infested acres and impacts to ecosystem 

integrity. Various activities such as recreational use, road use, fire and its associated management 

activities, other management activities, grazing, and climatic events such as drought are all 

documented to contribute to the potential for invasive species to establish. All of these activities 

have contributed to the increase in invasive species establishment within the Wallowa-Whitman 

National Forest. 

Present and reasonably foreseeable future actions will continue to provide opportunities for 

invasive species to establish. The R6 2005 FEIS estimates that invasive species will continue to 

spread at a rate of 8-12 percent annually. Expected treatment effectiveness of all methods 

approved within the R6 2005 FEIS including the site specific treatment methods evaluated in 

Alternatives B, C, and D would increase treatment effectiveness to 80 percent compared to the 

35 percent effectiveness presently reported (see Botany report). For a full discussion of direct 

indirect and cumulative effects to native vegetation that is tightly linked to grazing see effects 

analysis in the Botany report. 

Roads will continue to be a major conduit for invasive plants. Forest Service projections suggest 

that recreation uses of National Forests will continue to increase, and other land management 

and use activities such as grazing, vegetation management, fuels management (Healthy Fuels 

Initiative), and fire suppression will continue to cause ground disturbances and contribute to the 

introduction, spread and establishment of invasive plants on National Forest System lands (R6 

2005 FEIS ). Land uses and development on lands adjacent to or outside National Forest 

boundaries will likely continue to contribute to the potential for invasive species to be distributed 

in the forest. For example, the use of invasive plants by landowners for landscaping, while small 

individually, can collectively result in significant impacts, especially along riparian corridors (R6 

2005 FEIS). 

Cumulative effects to grazing and range management of this project by alternative are listed in 

Table 77. Cumulative effects are expected to be positive for Alternatives B, C and D because 

more aggressive treatments combined with Early Detection Rapid Response activities and 

cooperative efforts with other federal, state and private landowners will reduce the potential for 

additional spread and loss of available forage. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Table 77-Cumulative Effects on Grazing and Range Management within the project area 

Alternative Effects on Grazing and Range Management 

Alternative A 

No Action 

Over time infested areas will continue to increase and forage plants will be 

reduced through displacement and reduced ecosystem health. As conditions 

change over time within the allotments, livestock use will likely be reduced thru 

additional NEPA allotment analysis to prevent the further spread of invasive 

species. 

Alternative B 

Proposed Action 

Some short –term limitations on livestock grazing may occur. As implementation 

of the proposed action occurs, it is expected that increased retention of desirable 

species, vegetation density, and plant vigor of desired native vegetation will 

increase and/or improve. 

Alternative C 

Riparian Restrictions Same as the Proposed Action. 

Alterntaive D 

No Aerial Herbicide 

Application 

Same as the Proposed Action. 

 

Irreversible and Irretrievable Commitment of Resources 

Implementing Alternative B, with appropriate environmental protection would not result in 

irreversible or irretrievable loss of range resources. Implementing Alternative A (No Action) 

would likely result in eventual irreversible impacts on grazing resources as weeds would 

continue to spread and invade in and around the proposed treatment areas. Implementing 

Alternative C&D would likely result in eventual irreversible impacts on grazing resources as 

weeds would continue to spread and invade in and around the proposed treatment areas that are 

treated with methods not as effective as those proposed in Alternative B, however, at a much 

lower level of loss compared to Alternative A (No Action). 

3.9 Project Costs and Financial Efficiency 

3.9.1 Introduction 

The following section documents the analysis of the effects of a proposal designed to control, 

contain, or eradicate invasive plants on approximately 22,842 acres of National Forest System 

lands administered by the Wallowa-Whitman National Forest. The impact of invasive plants is 

many and varied. They can poison livestock and pets, contribute to increased fire hazards, 

compete with desirable plants, reduce the suitability of wildlife habitats, and change the nature 

and composition of plant communities. A 2000 report by The Research Group estimated the cost 

of controlling these invaders, which impacts both private and public budgets. It is estimated that 

21 of the 99 weeds listed as noxious in Oregon reduced the State’s total personal income by 

about $83 million.This equated to approximately 3,329 annual jobs lost to Oregon’s economy. It 

was estimated that these 21 species cost the citizens of Oregon a total of about $100 million per 

year. The effect of all 99 noxious weeds is likely significantly greater (The Research Group 

2000). 

3.9.2 Methodology 

The analysis area is the ten counties most directly influenced by the Wallowa-Whitman National 

Forest, Wallowa, Union, Baker, Malheur, Umatilla, and Grant Counties in Oregon and Adams, 

Idaho, and Nez Perce Counties in Idaho. The time frame used for the analysis of direct, indirect, 

and induced economic effects is approximately 15 years. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

This is the estimated period of time required to contain or control existing invasive plant 

populations at the anticipated rate of annual treatment. 

Projected Costs 

In order to compare the alternatives, implementation costs were estimated based on a uniform set 

of assumptions. Regardless of which alternative is selected, costs will vary from year to year 

based on factors such as annual budget allocations, the annual operating plan, the conditions 

present in the sites scheduled for treatment, opportunities for cost savings afforded by 

partnerships with Forest stakeholders, and the availability of external funding. 

Many variables affect the cost of treatment activities, including: treatment methods (e.g., 

mechanical, manual, herbicide, etc.); method of herbicide application (e.g., aerial, broadcast 

spraying, spot application, etc.); species, and site conditions. Many of the sites to be treated are 

likely to require repeated entries; the phenology of individual invasive species and the 

effectiveness of a given treatment influence the number of entries that may be required. It is 

expected that in some cases, multiple treatment methods may be employed on the same site. For 

example, a site with multiple species may be treated with spot application of herbicide to address 

one species, and physical treatments, such as hand pulling to address other species. In some 

cases a combination of treatment options are proposed, such as manual, mechanical, and/or 

herbicide. On these acres, one treatment method may be utilized initially, with another method 

used for follow-up treatments, such as herbicide treatments applied in year one followed by 

manual treatments in year two. 

Treatment effectiveness under Alternative A was estimated at 25 percent of acres treated based 

on forest management experience utilizing the current treatment strategy (Laufmann 2007). For 

the purposes of the economic analysis, 25 percent effectiveness was assumed in order to analyze 

the worst case scenario. Treatment effectiveness under the action alternatives was estimated at 

80 percent of acres treated based on commercially acceptable standards. 

The following assumptions were used to arrive at this cost estimate for each alternative. 

• The average efficacy of the more limited suite of treatment methods available under the 

No Action Alternative (Alternative A) was estimated at 25 percent based on an 

assessment of the effectiveness of past treatment activities on the Forest. 

• Average efficacy of the suite of treatment methods available for use under the action 

alternatives (Alternatives B, C, and D) was assumed to be 80 percent based on 

commercially acceptable standards. 

• The weeds that survive the first round of treatments are retreated in the next and 

succeeding years, with the same rate of efficacy. 

• Under Alternative A, the application of treatment methods on acres identified for 

treatment using manual, mechanical, and/or herbicide is approximated based on the 

three-year average. From 2003 through 2005, 31 percent of treatments utilized manual 

and mechanical methods and 69 percent utilized herbicide ground applications. 

• Under Alternatives B, C, and D, acres identified for treatment using manual, mechanical, 

and/or herbicide were projected to be treated primarily with herbicides initially and as 

population size is decreased, manual and mechanical methods would be used. Treatment 

costs per acre were estimated based on an assumption of 90 percent herbicide and 10 

percent manual or mechanical (see Table 78). 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

• Costs per acre for treatment activities are estimated using regional averages adjusted for 

local costs variances and are displayed in Table 78: 

• The costs of monitoring the effectiveness of treatments are assumed to be conducted by 

Forest Service personnel in the year following treatment. 

• Historically, treatment costs within the Hells Canyon National Recreation Area 

(HRCNRA) have been higher due to the nature of the terrain to be treated. Therefore 

higher costs per acre for some treatment methods were used to estimate the cost of 

proposed treatments within the HCNRA. These cost estimates are based on the Forest 

Service’s past experience with contracting for these services in the HCNRA and are 

displayed in Table 78. 

Table 78-Cost per acre of invasive species treatment methods (All costs are in 2006 dollars) 

Treatment Method Cost per Acre 

Manual/Mechanical Treatments (all areas) $340 

Biological Treatments (all areas) $70 

Aerial Herbicide Treatments (all areas) $42 

Ground Broadcast and Spot Herbicide Treatments (Avg.) 

 Hells Canyon National Recreation Area 

 Remainder of Forest 

$310 

$100 

Ground Spot Herbicide Treatments only 

 Hells Canyon National Recreation Area 

 Remainder of Forest 

$350 

$125 

Manual/Mechanical and/or Herbicide Treatments – Alternatives B, C, and D 

 Hells Canyon National Recreation Area 

 Remainder of Forest $313 

$124 

Manual/Mechanical and/or Herbicide Treatments – Alternatives A* 

 Hells Canyon National Recreation Area 

 Remainder of Forest $319 

$175 

Inventory and Monitoring (all areas) $47 

These costs represent estimated open market costs and do not necessarily equate to actual Forest 

Service expenditures. In some cases, actual Forest Service costs per acre may be lowered 

through the use of Forest Service crews, cooperative agreements, partnerships, and external 

funding. The use of these alternative approaches can only be determined on a case by case basis, 

taking into consideration the areas and species to be treated from year to year. It is not possible 

to accurately anticipate the scale of cost savings that may be achieved. Use of the costs listed 

above provides a “worst case” scenario that allows for a consistent, relative comparison of costs 

between the alternatives. 

3.9.3 Affected Environment 

The impact of invasive plants is many and varied. They can poison livestock and pets, contribute 

to increased fire hazards, compete with desirable plants, reduce the suitability of wildlife 

habitats, and change the nature and composition of plant communities. The cost of controlling 

these invaders impacts both private and public budgets. A report prepared for the Oregon 

Department of Agriculture by The Research Group in 2000, estimated that 21 of the 99 weeds 

listed as noxious in Oregon reduced the State’s total personal income by about $83 million. It 

was estimated that these 21 species cost the citizens of Oregon a total of about $100 million per 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

year at that time. The effect of all 99 noxious weeds was likely significantly greater (The 

Research Group 2000). This analysis addresses the treatment of 22,842 acres of invasive plant 

species on the Wallowa-Whitman National Forest. Ten species present on the Forest were 

included in the Oregon study. 

The Wallowa-Whitman National Forest lies in the northeastern corner of Oregon and the west 

central edge of Idaho. The Forest is located on the east edge of the Blue Mountains and 

encompasses the Elkhorn and Wallowa Mountains. The Forest extends to the Hells Canyon 

National Recreation Area, and encompasses four wilderness areas totaling over 600,000 acres, 

and eleven wild and scenic rivers. The Wallowa-Whitman National Forest is the home of the 

deepest river gorge in the nation (Hells Canyon), the largest wilderness area in Oregon (Eagle 

Cap), has one of the top snowmobile areas in the nation, and hosts a portion of the Oregon Trail. 

The population of the counties in the analysis area is displayed in Table 79 (US Census Bureau 

2000). 

Table 79-Analysis Area Population by County, 2000 Census 

Location Population 

Baker County, OR 16,741 

Grant County, OR 7,935 

Malheur County, OR 31,615 

Umatilla County, OR 70,548 

Union County, OR 24,530 

Wallowa County, OR 7,226 

Adams County, ID 3,476 

Idaho County, ID 15,511 

Nez Perce County, ID 37,410 

Total Analysis Area Population 214,992 

 

As displayed in Table 80, the majority of analysis area residents (84.4 percent) are White, 

followed by Hispanic or Latino (10.1 percent), and American Indian (2.5 percent) (US Census 

Bureau 2000). 

Table 80-Race and Ethnicity by County, 2000 Census 

Location White 

Black 

or 

African 

Am. 

Am. 

Indian 

or 

Alaska 

Native 

Asian 

Native 

Hawaiian 

& Other 

Pacific 

Islander 

Some 

Other 

Race 

Two 

or 

More 

Races 

Hispanic 

or 

Latino* 

Baker County, 

OR 95.7% 0.2% 1.1% 0.4% 0.0% 0.1% 1.7% 2.3% 

Grant County, 

OR 94.6% 0.1% 1.6% 0.2% 0.0% 0.1% 1.4% 2.1% 

Maheur County, 

OR 68.8% 1.2% 0.9% 1.9% 0.1% 0.1% 1.5% 25.6% 

Umatilla County, 

OR 77.5% 0.8% 3.2% 0.7% 0.1% 0.2% 1.5% 16.1% 

Union County, 

OR 93.1% 0.5% 0.8% 0.8% 0.6% 0.4% 1.4% 2.4% 

Wallowa County, 95.7% 0.0% 0.7% 0.2% 0.0% 0.1% 1.4% 1.7% 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Am. Native Black Two 

Location White or 

African 

Am. 

Indian 

or 

Alaska 

Native 

Asian 

Hawaiian Some Hispanic or & Other 

Pacific 

Islander 

Other or More Race Latino* Races 

OR 

Adams County, 

ID 95.5% 0.1% 1.4% 0.1% 0.0% 0.5% 0.9% 1.6% 

 Idaho County, 

ID 93.4% 0.1% 2.9% 0.2% 0.0% 0.3% 1.6% 1.6% 

Nez Perce 

County, ID 90.6% 0.3% 5.1% 0.7% 0.1% 0.1% 1.4% 1.9% 

Analysis Area 84.4% 0.6% 2.5% 0.8% 0.1% 0.2% 1.4% 10.1% 

* Hispanic or Latino persons may be of any race. 

Per capita incomes in the counties of the analysis area range from a low of $13,895 in Malheur 

County, OR to a high of $18,544 in Nez Perce County, ID. The 2000 per capita income for 

Oregon and Idaho were $20,940 and $17,841 respectively. The percentage of the analysis area 

population with incomes below poverty level is displayed by race in Table 81. Poverty levels are 

highest among minority populations. 

Table 81-Analysis Area Population below Poverty Level by Race, 2000 Census 

Race/Ethnicity Percentage Below Poverty Level 

White 12.6% 

Black or African American 32.8% 

American Indian & Alaska Native 24.7% 

Asian 12.3% 

Native Hawaiian & Other Pacific Islander 45.5% 

Some Other Race 26.5% 

Two or More Races 21.4% 

Hispanic or Latino* 25.3% 

*Those of Hispanic or Latino origin may be of any race. 

Although many members of the public desire commodity uses of the National Forest, 

increasingly, forest users are placing a greater importance on non-commodity values such as the 

aesthetic, recreational, and spiritual aspects of the forest. Visual resource qualities not only 

attract visitors, but are appreciated by local residents as an aesthetic value that enhances the local 

lifestyle and culture. Likewise, the recreation opportunities afforded by the National Forest 

attract visitors and residents. A variety of special places such as scenic areas, scenic byways, 

wild and scenic rivers, wilderness areas, and research natural areas contribute to the educational, 

interpretive, and other recreational experiences available within the Wallowa-Whitman National 

Forest (USDA Forest Service 2004a). These opportunities contribute to the desirability of the 

area as a place to live and also attract visitors who support the local tourism industry. 

Invasive species are threatening native plant communities throughout the forest. Currently, it is 

estimated that there are 22,842 acres of invasive plant infestations within the Wallowa-Whitman 

National Forest. Noxious weed infestations are of concern to both those who seek commodities 

and those who seek non-commodity uses. Both groups desire a healthy ecosystem. However, 

some members of the public believe that the use of herbicides presents an unacceptable risk to 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

the health of non-target native plants, wildlife, and humans. Concern has also been expressed 

that the use of herbicides is too costly. 

Tribal Interests 

The Wallowa-Whitman National Forest maintains government to government relations with 

numerous American Indian tribes who have treaty reserved or Executive Order rights on the 

Forest. These rights include fishing, hunting, gathering, and trapping. The tribes with rights on 

the Wallowa-Whitman National Forest include: 

• Confederated Tribes of the Umatilla Indian Reservation, 

• Confederated Tribes of the Warm Springs, 

• Nez Perce Tribe, 

• Confederated Tribes and Bands of the Yakama Indian Nation of the Yakama Reservation, 

• The Burns Paiute Tribe, 

• Shoshone-Bannock, Shoshone-Paiute Tribes of the Duck Valley Reservation, 

• Fort McDermitt Paiute and Shoshone Tribes, 

• Fort Bidwell Indian Community of Paiute Indians, 

• Klamath Tribes, and the 

• Joseph Band of Nez Perce-Colville Confederated Tribes (USDA Forest Service 2004a). 

Tribal members utilize native plant species for a variety of cultural uses such as food, medicine, 

dress, basketry, or ceremonial purposes. Wildlife and fish are harvested for subsistence and 

traditional cultural uses. Invasive plants may interfere with rights granted to Native American 

Tribes. Invasive plants can crowd out plants traditionally gathered and can impact wildlife and 

fish. Additionally, the potential for human health impacts through contact with or consumption 

of plants and animals exposed to herbicides as a result of treatment activities are a concern. 

There is also a potential for treatment activities to impact traditional cultural properties or grave 

sites. 

Jobs and Income 

The jobs and income generated by businesses that provide invasive plant treatment services is 

another effect of invasive plants. Such businesses employ people to provide the appropriate 

level of service needed to meet demand. The services or output produced and the employment 

required to produce that level of output are the direct effects of that business on the economy. In 

order to produce the output included in the direct effects, the businesses providing invasive plant 

treatments must purchase supplies and services from other industries. The output and 

employment stimulated in other industries by these purchases are indirect effects. In addition to 

the direct and indirect effects, induced effects represent the output and employment stimulated 

throughout the local economy as a result of the expenditure of new household income generated 

by direct and indirect employment. 

3.9.4 Environmental Consequences 

Alternative A – No Action 

The Wallowa-Whitman National Forest has been treating invasive plants under direction found 

in the 1992 decision implementing the Wallowa-Whitman National Forest Environmental 

Assessment for the Management of Noxious Weeds and Forest Plan Amendment 4 and a 1994 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Wallowa-Whitman Management of Noxious Weed Environmental Analysis. This program would 

continue under the No Action Alternative. The 1992 EA implemented an integrated weed 

management program that identified containment, control, or eradication management strategies 

and outlined manual, mechanical, cultural, biological, and chemical treatments. This program 

outlined prevention and early detection management direction. Several sites were identified for 

treatment. 

The 1994 EA incorporated the 1992 EA and identified additional weed infestations for treatment. 

In the two EAs, approximately 5,172 acres were identified for treatment of 21 species. Of the 

inventoried acres, approximately 2,368 acres are located within the HCNRA. Estimated acres by 

treatment method are displayed in Table 82. 

Table 82-Alternative A Estimated Acres by Treatment Method 

Treatment Methods Acres 

Chemical Upland Areas (broadcast and/or spot) 2,577 

Chemical (aerial) 0 

Chemical in RHCA (ground-based broadcast treatments) 1,932 

Chemical in RHCA (spot only – includes wicking and wiping), manual, 

and/or mechanical 663 

Bio-control only See note below 

Manual only 0 

Total Acres to be Treated 5,172 

Bio-control: The ’94 EA’ approved the use of biocontol agents; however, all sites were analyzed for chemical treatments 

to attain the highest amount of flexibility and greater invasive species control. The forest has released APHIS and State 

of Oregon approved biocontrol agents on approximately 2,500 acres for the control of invasive plants (Yates 2007). 

Direct and Indirect Effects of Alternative A 

Under this alternative, invasive treatment activities would continue to utilize the approach 

authorized under the 1992 and 1994 decisions for the management of noxious weeds. Ten years 

of monitoring has shown a substantial increase in invasive plant populations. Though some of 

the initial invasive plant sites identified in these EAs were successfully contained or controlled, 

new sites have been identified and many existing sites have grown. This along with the 

identification of new species and an increase of invasive plant introductions has limited the 

application and effectiveness of the two EAs. 

Treatments would be applied to 5,172 acres analyzed in the 1992 and 1994 decisions. Past 

experience with these treatment methods has resulted in a rate of effectiveness of approximately 

25 to 35 percent (Laufmann 2006). This is due to the limited choice of herbicides and the 

limited project area that does not include the majority of current sites.The potential for spread 

from these areas would remain unchanged from the existing condition. Additionally, the 

remaining inventoried acres of invasive species would go untreated and would likely continue to 

spread at an estimated rate of 8 to 10 percent per year. 

Those opposed to the use of herbicides due to concerns about impacts to non-target native plant 

communities, wildlife, and human health would favor this alternative over the action alternatives 

due to the lower levels of chemical use. However, many stakeholders would perceive an adverse 

effect under this alternative. Those who value commodity values and uses of the Forest would 

see a continue decline in resource conditions and biodiversity as invasive species continue to 

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spread. Likewise, those who place a higher worth on non-commodity resources would also see a 

decline in the values they seek. Forage production on Forest rangelands would be reduced, 

adversely impacting habitat capability to support wildlife as well as reducing forage available for 

domestic livestock. In a report to the Governor of Idaho Weed Summit in 1998, Jerry Asher and 

Carol Spurrier of the Bureau of Land Management cite numerous studies that found that 

populations of native wildlife species declined as habitats became dominated by non-native plant 

species (Asher and Spurrier, 1998). Scenic areas, scenic byways, wild and scenic rivers, 

wilderness areas, and research natural areas are adversely affected as invasive species spread, 

resulting in the loss of native species and biological diversity. These impacts may reduce the 

recreational and/or educational value of these areas to some visitors. In severe cases, some users 

may relocate their activities to other areas of the forest or to other public lands (Asher and 

Spurrier 1998). 

Neighboring private and public lands would be adversely impacted as invasive species 

populations spread from the Wallowa-Whitman National Forest. Land values may be reduced 

and costs to control infestations for neighboring land owners or administrative agencies (federal, 

state, and local governments) would be increased. 

American Indian Tribes with interests in the Wallowa-Whitman National Forest would be 

adversely impacted. Populations of native plant species used for cultural purposes such as food, 

medicine, dress, basketry, or ceremonial activities may be reduced as a result of the spread of 

invasive species. The spread of invasive species from the Forest to Tribal trust lands would 

adversely impact Tribal interests. In the long-term, invasive species populations may threaten 

traditional gathering areas. The potential for the exposure of tribal members to herbicides is 

lowest under this alternative. No adverse human health impacts are anticipated. 

Economic Effects 

Assumptions used for the development of cost estimates are described under “Methodology” 

above. 

The undiscounted cost of implementing treatments on all proposed acres one time in one year is 

estimated at $1,485,190 in 2006 dollars. This estimate includes inventory and monitoring costs. 

It is estimated that treatments would be effective on 25 percent of treated acres. The average cost 

per effectively treated acre is the highest under this alternative at an estimated $820 per acre. 

Discounted costs at various levels of annual treatment are provided in Table 83 below. A variety 

of annual treatment levels were analyzed in order to assess potential treatment levels should 

future budgets change. In the case of the No Action Alternative, annual treatments were 

estimated at 4,000 acres. At this level of treatment, the net annual equivalent cost is estimated at 

$279,540. Because treatments would be limited to the 5,172 acres analyzed in the 1992 and 1994 

EAs, other inventoried infestations would remain untreated and would continue to spread. 

Therefore the existing invasive plant populations on the Forest would never be contained or 

controlled under this alternative. Future costs to contain or control the growing population of 

invasive species would continue to escalate as the scope and size of the problem continues to 

grow. 

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Table 83-Discounted costs and years to contain or control of forest-wide infestations under 

Alternative A in 2006 dollars (Shaded line represents the projected annual treatment level) 

Years to Contain or Control1 Inventoried Infestations and 

Total Discounted Cost 

Average Rate of Spread = 10 Percent of Untreated Areas 

and 5 Percent of Treated Areas 

Annual Acres 

Treated 

Estimated Net 

Annual Equivalent 

Cost 

Years 

Cost 

($1000s) 

2,500 $264,150 Would not achieve Unlimited 

3,000 $264,720 Would not achieve Unlimited 

4,000 $279,540 Would not achieve Unlimited 

5,172 $289,430 Would not achieve Unlimited 

1 For the purposes of analysis, projections assumed 25 percent effectiveness of treatments, a 10 percent rate of spread 

from untreated acres, and a 5 percent rate of spread from treated acres. Infestations were considered controlled when 

projections for remaining inventoried acres reached 0 acres. 

2 Using the assumptions regarding treatment effectiveness and rate of spread described earlier under “Methodology” it 

was estimated that the acres approved for treatment under the 1992 and 1994 EAs would be controlled in 22 years at a 

total discounted cost of $4,042,285 at projected annual treatment levels. However, remaining inventoried sites would 

not be treated and would continue to spread. As a result, potential costs to contain or control would continue to grow 

until future containment action is initiated. 

Some annual costs may be covered through external funding sources, which historically have 

averaged approximately 5 percent of the forest program. Approximately half of these acres have 

been funded through the use of Title II funding, which at the time of this writing had terminated 

as of the end of 2006. An extension was proposed in the President’s budget package and has also 

been proposed by Congress, but has not yet been passed or signed into law. If Title II funding is 

not extended by Congress, this additional funding would be lost. 

Without treatment, the remaining inventoried infestations (17,670 acres) would likely spread at 

an estimated annual rate of 8 to 12 percent (R6 2005 FEIS). At an average of 10 percent 

annually, within 20 years infested acres would likely exceed 110,000 acres or more than 480 

percent of the currently affected acres. As the scope and size of the infestation continues to grow, 

future costs to contain or control invasive species would continue to escalate. 

Economic benefits and costs difficult to quantify include: 

• Maintenance of biodiversity on those acres successfully treated 

• Loss of biodiversity on those acres not treated or on which treatments are ineffective 

• Reduced forage for wildlife as well as domestic cattle grazing as a result of the spread of 

invasive species 

• Spread to adjacent lands as discussed above 

• Increased future costs to the Forest Service to treat invasive species infestations that 

have continued to spread unchecked 

Other potential costs and benefits under this alternative are discussed in detail in specialist 

reports for other affected resources. 

Environmental Justice 

Alternative A was assessed to determine whether there would be a disproportionately adverse 

impact to minority or low-income populations in accordance with Executive Order 12898 

(President 1994). No concerns relative to disparate impacts to minority or low income 

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populations were identified through scoping. However, American Indian tribes may be 

disproportionately affected because they are dependent on native plants for cultural and 

traditional uses. The racial composition of work crews implementing treatment activities are 

expected to be generally similar to that of the analysis area population, with a potential for a 

slightly higher percentage of minorities. Work crews may experience injury during manual 

treatments or may be exposed to chemical treatments. 

The National Visitor Use Monitoring survey asked visitors to categorized themselves into one of 

seven race/ethnicity categories. The 2004 report for the Wallowa-Whitman indicated that of 

Forest visitors sampled from October 2002 through September 2003, 97.4 percent were white. 

Approximately 0.6 percent of visitors sampled were Native American, 4.0 percent was Asian, 3.6 

percent was Hispanic or Latino, and 2.1 percent was Pacific Islander (USDA Forest Service 

2004a). 

Native American plant areas are likely at greater risk due to the spread of invasive species under 

Alternative A than under other alternatives. 

Native plants important for cultural uses could potentially be crowded out of some areas forcing 

Native American users to seek these resources in other areas of the forest or on other land 

ownerships. Populations of culturally important plants could be decreased to the point of being 

insufficient to meet demand. 

Visitors from other racial or ethnic backgrounds or low income visitors seeking to supplement 

family incomes may also be impacted. Areas important to these visitors for mushroom gathering, 

berry picking, or other gathering activities could be adversely impacted by the spread of invasive 

species. 

The potential for human exposure to herbicides is lowest under this alternative for all user 

groups due to the limitations on the implementation of chemical treatment activities. However, 

annual herbicide treatments over the last four years have averaged approximately 2,650 acres 

annually, including the re-treatment of some acres. Similar treatments would continue under 

Alternative A. These acres of treatment represent approximately 0.1 percent of the National 

Forest System lands administered by the Wallowa-Whitman National Forest. Herbicide 

application methods would be selected to not only maximize effective results, but to minimize 

movement offsite in soil, water, or wind. 

The R6 2005 ROD amended the Wallowa-Whitman Forest Plan to incorporate standards for the 

implementation of herbicide treatment activities. The R6 2005 FEIS and the accompanying ROD 

found that the potential for adverse human health and safety impacts from herbicide use would 

be adequately resolved through adherence these standards. Additionally, the R6 2005 ROD 

amended the Wallowa-Whitman Forest Plan to incorporate requirements to ensure timely public 

notification and that signs are posted to inform the public and forest workers of herbicide 

application dates and the name of herbicides used. If requested, individuals may be notified in 

advance of spray dates. These measures would provide visitors who wish to avoid any potential 

for herbicide exposure with the information they need to do so. 

Worker exposure to herbicides and risks associated with physical treatment methods would be 

minimized through strict adherence to health and safety requirements for all workers. 

Application of any herbicides to treat invasive plants would be performed or directly supervised 

by a State or Federally licensed applicator. Herbicide transportation and handling safety plan 

would be developed and implemented for all treatment activities. 

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Based on the above analysis, no disproportionate adverse impacts to minority or low income 

groups are anticipated under this alternative. 

Cumulative Effects of Alternative A 

Although private land owners and federal, state, and local governments administering lands 

adjacent to the Forest will continue invasive plant treatment activities, implementation of 

Alternative A would contribute to increased occurrence and spread of infestations on these lands. 

Untreated infestations on the Forest would lead to a long-term decline in the health and 

sustainability of native plant communities. The resulting decrease in biological diversity and 

reduction in the economic and social returns natural plant communities provide adversely 

impacts all stakeholders. The threat to the agricultural based economy of the region posed by 

invasive species would aggravated by spread from National Forest System lands, thereby 

adversely impacting the continuation of the associated lifestyles and customs. Costs incurred by 

adjoining land ownerships to treat invasive plant infestations would likely continue to escalate as 

a result of the increasing likelihood and scale of the spread of these species from untreated areas 

of the Wallowa-Whitman National Forest. Additionally, deferring the treatment of invasive plant 

populations would result in increased future costs to the Forest Service and thus to tax payers to 

treat larger, more widespread populations that would continue to develop over time. 

Alternative B – Proposed Action 

Alternative B proposes to control, contain, or eradicate invasive plants on existing sites or newly 

discovered infestations. Various types of treatments would be used including the use of 

herbicides, physical, and biological methods. Treatments are proposed for existing or new 

infestations including new plant species that currently are not found on the Forest. The preferred 

treatment method would be determined using a decision matrix based on local (District) priority 

plant species and site location, and input from local weed managers. Species priority and 

treatment response is based on: 

• The previous and ongoing efforts made to control the species 

• The invasive nature of the species 

• Newly detected infestations 

Current inventory indicates there are approximately 22,842 acres of invasive plant infestations 

on the Forest. Of these, approximately 10,419 acres are located within the HCNRA. 

The actual locations of treatments can be anywhere on the landscape, including rangelands, 

timber harvest areas, along roads and road rights-of-way (including decommissioned roads), 

along trail routes, at dispersed and developed recreation sites, and on other disturbed sites (for 

example: fires, flood events, and rock sources). Treatments may include seeding with desirable 

grass and forb species to assist site rehabilitation. Restoration treatments requiring ground 

disturbing activities would necessitate additional site specific analysis. 

Under this alternative, invasive treatment activities would include herbicides, physical (hand 

pulling, hand tools, and mechanical treatments), and biological methods. Herbicides utilized 

would be those approved for use in the R6 2005 ROD. These include herbicide formulations 

containing one or more of the following ten active ingredients: chlorsulfuron, clopyralid, 

glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, sethoxydim, sulfometuron 

methyl, and triclopyr. All herbicide application methods are allowed including wicking, wiping, 

injection, spot, broadcast, and aerial as permitted by the product label. However, chlorsulfuron, 

metsulfuron methyl, and sulfometuron methyl may not be applied aerially, and triclopyr may not 

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be applied using any broadcast method. Additional herbicides and herbicide mixtures may be 

added in the future at either the Forest Plan or project level through appropriate risk analysis and 

NEPA/ESA procedures. 

Treatment effectiveness under this alternative would be expected to approach 80 percent or 

higher. As infestations are effectively treated, management would be initiated on new acres each 

year. Herbicides could potentially be applied to approximately 20,776 acres, or approximately 1 

percent of National Forest System lands administered by the Wallowa-Whitman National Forest. 

High use areas would be posted in advance of herbicide application or closed. Areas of potential 

conflict would be marked on the ground or otherwise posted with the date of treatments, the 

herbicide used, and when the areas are expected to be clear of herbicide residue. 

Many stakeholders would perceive beneficial effects under this alternative. Treatments of 

invasive species are expected to be considerably more effective than has been experienced under 

the existing program (No Action Alternative). Commodity values and uses of the Forest would 

benefit from improved resource conditions and biodiversity as invasive species are effectively 

treated. Likewise, users of non-commodity resources would also see an improvement in the 

values they seek. Forage production on Forest rangelands would be maintained and gradually 

increased as the occurrence of invasive species is reduced. Habitat capability to support wildlife 

and provide forage for domestic livestock would gradually improve following implementation of 

this alternative. The important native species and biological diversity within scenic areas, scenic 

byways, wild and scenic rivers, wilderness areas, and research natural areas would be maintained 

and improved as implementation progresses. The recreational and/or educational values of these 

areas would be maintained or improved. 

Neighboring private and public lands would be benefited because the likelihood for spread of 

invasive species from the Wallowa-Whitman National Forest would be reduced. The potential 

for adverse impacts to land values as a result of infestations of invasive species would be 

reduced and costs to control infestations for neighboring land owners or administrative agencies 

(federal, state, and local governments) would likely decrease over time with the reduced 

potential for spread from National Forest System lands. 

The potential for adverse impacts to populations of native plant species used for cultural 

purposes such as food, medicine, dress, basketry, or ceremonial activities as a result of the spread 

of invasive species would be reduced through implementation of Alternative B. The potential for 

spread of invasive species from the Forest to Tribal trust lands would be reduced. 

The potential for the exposure of tribal members to herbicides is highest under this alternative. 

However, per the analysis and findings of the R6 2005 FEIS as discussed above, no adverse 

human health impacts are anticipated. Nonetheless, perceptions of the potential for harmful 

effects would likely persist for some individuals. Public notification prior to implementation of 

treatment activities and posting of signs with the dates of treatment and herbicides used would 

aid members of the public to avoid herbicide exposure. 

Economic Effects 

The undiscounted cost of implementing treatments on all proposed acres one time in one year is 

estimated at $5,601,390 in 2006 dollars. This estimate includes inventory and monitoring costs. 

At an estimated rate of effectiveness of 80 percent of treated acres, the average cost per 

effectively treated acre is an approximately $307 per acre under this alternative. The represents 

the lowest per acre cost of all alternatives considered. 

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Early detection, rapid response (EDRR) would be utilized to address new infestations of 

currently occurring species or new species at an estimated average cost of $260 per effectively 

treated acre. All treatment methods proposed and analyzed through the EIS would be utilized for 

EDRR with the exception of aerial spraying, which would not be allowed. Implementation of 

EDRR would reduce future costs and environmental impacts by eliminating or controlling new 

infestations before they could become established. 

Economic benefits and costs difficult to quantify include maintenance and improvement of 

biodiversity, improved forage for wildlife and dometic cattle grazing, and previention of spread 

to adjacent lands. Other potential benefits and costs under this alternative are discussed in detail 

in the specialist reports for other affected resources. 

Environmental Justice 

Alternative B was assessed to determine whether there would be a disproportionately adverse 

impact to minority or low-income populations in accordance with Executive Order 12898 

(President 1994). Although minorities make-up a large percentage of the population within the 

analysis area, the percentage of minority persons is not large enough for the population of the 

analysis area to be consider a “minority population,” nor is the percentage of minorities in the 

analysis area “meaningfully greater than the minority population percentage in the general 

population” of the State. No concerns relative to disparate impacts to minority or low income 

populations were identified through scoping. 

The 2004 report for National Visitor Use Monitoring Results (NVUM) for the WallowaWhitman estimated that approximately 566,000 people visit the Wallowa-Whitman National 

Forest annually, plus or minus 18.7 percent at the 80 percent confidence interval. Of the Forest 

visitors sampled from October 2002 through September 2003, 97.4 percent were white. 

Approximately 0.6 percent of visitors sampled were Native American, 4.0 percent were Asian, 

3.6 percent were Hispanic or Latino, and 2.1 percent were Pacific Islander (USDA Forest 

Service 2004a). Of these minority groups, Native American visitors, through their gathering and 

use of culturally important plants, may have the greatest potential to be impacted by herbicide 

applications. However visitors from other racial or ethnic backgrounds or low income visitors 

seeking to supplement family incomes, also engage in mushroom gathering, berry picking, or 

other gathering activities on the Wallowa-Whitman National Forest. 

The NVUM survey results indicated that of those surveyed, approximately 15.7 percent of 

recreation users indicated that they participate in gathering forest products, 16.1 percent engage 

in fishing, and 28.1 percent participate in hunting activities at some time during the year. These 

numbers may undercount actual forest product users as some visitors may not consider these 

uses as recreational, and therefore may not have participated in the survey. 

Risk to Native American cultural plant gathering areas and other forest product gathering sites as 

a result of the spread of invasive species is lowest under Alternative B. The higher rate of 

effective containment, control, or eradication of invasive species anticipated under this 

alternative would help to protect native plant areas important to Native Americans and other 

visitors by reducing the encroachment of invasive species. There is concern that herbicides 

treatments could adversely impact non-target, culturally important plants, or wildlife species. 

Treatments applied to each site would consider the minimization of exposure to non-target 

species through such means as the method of herbicide application and timing. The R6 2005 

FEIS and accompanying ROD found that the potential for herbicides to harm non-target plants, 

plant pollinators, or terrestrial and aquatic wildlife were likely to be resolved by adherence to the 

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standards incorporated in the Wallowa-Whitman Forest Plan through that decision. In addition, 

site specific project design features would be in place at the time of treatment to further reduce 

potential for harm to non-target species. 

The racial composition of work crews implementing treatment activities is expected to be 

generally similar to that of the analysis area population, with a potential for a slightly higher 

percentage of minorities. Work crews may experience injury during manual treatments or may be 

exposed to chemical treatments. Worker exposure to herbicides and risks associated with 

physical treatment methods would be minimized through strict adherence to health and safety 

requirements for all workers. Application of any herbicides to treat invasive plants would be 

carried out or directly supervised by a State or Federally Licensed Applicator. Herbicide 

transportation and handling safety plan would be developed and implemented for all treatment 

activities. 

Based on the above analysis no disproportionate adverse impacts to minority or low income 

groups are anticipated under this alternative. 

Cumulative Effects of Alternative B 

Many factors in the public and private sectors at the local, regional, national, and even global 

level interact and combine to both positively and negatively impact the level of jobs and income 

supported within the analysis area economy. The jobs and income potentially supported through 

implementation of this alternative would contribute a greater amount to positively impact the 

cumulative effect of this dynamic and inter-related system of economic influences than would 

Alternative A. However, due to the complexity of economic systems, the net cumulative effect 

can not be determined. 

Alternative B would contribute to efforts by private land owners and federal, state, and local 

governments administering lands adjacent to the Forest to reduce the occurrence and spread of 

invasive species on these lands. Treatment of infestations on the Forest would lead to long-term 

improvements in the health and sustainability of native plant communities. Maintenance or 

improvements in biological diversity would contribute to economic and social returns provided 

by natural plant communities benefiting all stakeholders. The threat to the agricultural based 

economy of the region posed by invasive species would be reduced though implementation of 

this alternative, thereby promoting the continuation of the associated lifestyles and customs. 

Costs incurred by adjoining land ownerships to treat invasive plant infestations would likely be 

reduced in the long-term as a result of the reduced likelihood and scale of the spread of invasive 

species from National Forest System lands. 

Effective treatment of invasive plant populations would result in decreased future costs to the 

Forest Service and thus to tax payers as the occurrence of invasive species is reduced and 

controlled over time. 

Alternative C – No Broadcast Application in Riparian Habitat Conservation Areas 

Direct and indirect effects resulting from the implementation of Alternative C would be the same 

as described above under Alternative B, except as noted below. 

Perceptions of the potential for harm to non-target plant species, wildlife, water quality and 

human health may be slightly lower than would occur under Alternative B among some members 

of the public due to the use of more selective herbicide application methods within riparian 

areas. However, as is true of Alternative B, a limited number of herbicides have been approved 

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for use in the R6 2005 FEIS, which found that the potential for harm to non-target plants, plant 

pollinators, wildlife, and human health and safety would be adequately resolved by adherence to 

the standards incorporated in the Wallowa-Whitman Forest Plan through amendment by the R6 

2005 ROD. The findings of that analysis are incorporated by reference. As under Alternative B, 

perceptions of the potential for harm would be likely to persist among many members of the 

public. 

Economic Effects 

The undiscounted cost of implementing treatments on all affected acres one time is estimated at 

$5,693,200 in 2006 dollars. This estimate includes inventory and monitoring costs. Assuming 

an estimated rate of effectiveness of 80 percent of treated acres, the average cost per effectively 

treated acre is $312 under Alternative C. 

Early detection, rapid response (EDRR) would be utilized to address new infestations of 

currently occurring species or new species at an estimated cost of $265 per effectively treated 

acre. Only methods proposed and analyzed through the EIS would be utilized, however aerial 

treatment methods would not be utilized to for EDRR treatments. Implementation of EDRR 

would reduce future costs and environmental impacts by eliminating or controlling new 

infestations before they can become established. 

Economic benefits and costs difficult to quantify include maintenance and improvement of 

biodiversity, improved forage for wildlife and dometic cattle grazing, and previention of spread 

to adjacent lands. Other potential benefits and costs under this alternative are discussed in detail 

in the specialist reports for other affected resources. 

Environmental Justice 

Alternative C was assessed to determine whether there would be a disproportionately adverse 

impact to minority or low-income populations in accordance with Executive Order 12898 

(President 1994). Effects under this alternative are the same as described above under Alternative 

B. 

Based on the above analysis no disproportionate adverse impacts to minority or low income 

groups are anticipated under this alternative. 

Cumulative Effects of Alternative C 

Cumulative effect under Alternative C would be the same as described above under Alternative 

B. 

Alternative D – No Aerial Application 

Direct and indirect effects resulting from the implementation of Alternative D would be the same 

as described above under Alternative B, except as noted below. 

Perceptions of the potential for harm to non-target plant species, wildlife, and human health may 

be lower than under Alternatives B and C among some members of the public due to the 

elimination of aerial herbicide applications and the reduced number of acres to be treated with 

chemicals. 

Due to the elimination of aerial application as a method of treatment, some difficult to access 

sites would not be treated due to safety issues and/or costs associated with alternative methods. 

Some areas that are difficult to access may also be dropped to a lower priority for treatment due 

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to cost factors. These sites are estimated to total approximately 875 acres. There is a higher risk 

of the loss of native species and the continued spread of invasive species within, and from 

remote, difficult to access locations under Alternative D than would occur under Alternatives B 

and C. 

Over the long-term, additional treatment efforts may be required around the borders of these sites 

to ensure infestations are contained and do not spread to other areas of the Forest or to 

neighboring lands. 

Economic Effects 

The undiscounted cost of implementing treatments on all affected acres one time in one year is 

estimated at $5,863,880 in 2006 dollars. This estimate includes inventory and monitoring costs. 

At the estimated rate of effectiveness of 80 percent of treated acres, the average cost per 

effectively treated acre is $334 under Alternative D. The reason the average cost is higher than 

Alternative D is because aerial application costs less per acre than the other methods. This 

represents highest effective cost per acre of the action alternatives, but is considerably lower than 

Alternative A. 

EDRR would be utilized to address new infestations of currently occurring species or new 

species at an estimated average cost of $275 per effectively treated acre. Only methods proposed 

and analyzed through the EIS would be utilized. Implementation of EDRR would reduce future 

costs and environmental impacts by eliminating or controlling new infestations before they can 

become established. 

Economic benefits and costs difficult to quantify include maintenance and improvement of 

biodiversity, improved forage for wildlife and dometic cattle grazing, and previention of spread 

to adjacent lands. Other potential benefits and costs under this alternative are discussed in detail 

in the specialist reports for other affected resources. 

Environmental Justice 

Alternative D was assessed to determine whether there would be a disproportionately adverse 

impact to minority or low-income populations in accordance with Executive Order 12898 

(President 1994). Effects under this alternative are the same as described above under Alternative 

B. 

Based on the above analysis no disproportionate adverse impacts to minority or low income 

groups are anticipated under this alternative. 

Cumulative Effects of Alternative D 

Cumulative effect under Alternative D would be the same as described above under Alternative 

B. 

Summary of Effects 

The effects of all alternatives are displayed in Table 88 below. Although the cost of treating all 

acres proposed for treatment one time under the action alternatives is much higher than under the 

no action alternative, the average cost per effectively treated acre under the action alternatives is 

much lower, ranging from 29 to 40 percent of the cost per acre under Alternative A. Based on 

past experience under the strategy proposed in Alternative A, treatments are expected to be only 

25 to 35 percent effective, thereby requiring a much higher level of repeat treatments and 

expenditure of funds to achieve containment or control. Additionally, Alternative A would leave 

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approximately 77 percent of the currently inventoried acres of infestation untreated. These 

untreated acres would continue to spread resulting in an increasingly rapid decline in resource 

conditions and biodiversity across the forest and on neighboring lands. Commodity and noncommodity values would continue to decline at ever increasing rates as more and more native 

species succumb to invasive species. Future efforts to treat invasive species would require 

increasingly aggressive measures in order to achieve containment or control. The potential costs 

and socio-economic effects of these future efforts would continue to escalate until action is taken 

to successfully arrest the spread of these species. 

The programs of treatment proposed under Alternatives B, C, and D, are projected to result in 

declining populations of invasive species, allowing the biodiversity of native species to be 

maintained and enhanced. The adverse economic effects of non-native invasive species would be 

contained and reduced as the treatment programs proposed reduce the occurrence of these 

species. 

Table 84-Summary of Effects by Alternative 

Indicator Alternative A Alternative B Alternative C Alternative D 

Undiscounted Cost to Treat All 

Acres Proposed for Treatment 

One Time 

$1,485,190 $5,601,390 $5,693,200 $5,863,880 

Cost per Effectively Treated Acre 

(Currently Inventoried 

Infestations) 

$820 $307 $312 $334 

3.10 Heritage Resources 

Section 106 of the National Historic Preservation Act (NHPA) requires Federal agencies to 

consider the potential effects their undertakings may have on historic properties. The definition 

of undertaking encompasses all agency decision-making actions including the approval of land 

management plans such as the Wallowa-Whitman National Forest Invasive Plants Treatment 

Draft Environmental Impact Statement (DEIS). The NHPA also compels agencies to consult 

tribes in determining whether the undertaking has potential to pose an effect on historic 

properties. Government-to government tribal consultation has been initialized for the Invasive 

Plant Treatment Plan and will be on-going during project implementation. Under the 

Programmatic Agreements among the United States Department of Agriculture Forest Service 

Pacific Northwest Region (Region 6), the Advisory Council on Historic Preservation, and the 

Oregon (signed June 2004) State Historical Preservation Officer Regarding Cultural Resource 

Management, yearly Section 106 review of proposed treatments will take place to determine if 

any protection measures are necessary. Tribes will be notified of annual treatments areas, as 

stated in PDF M-1, in Chapter 2. A no effect determination has been made for the Invasive Plant 

Treatment DEIS. Documentation to this affect will be forwarded to the Oregon SHPO, in 

compliance with the National Historic Preservation Act of 1966 (as amended), and the Oregon 

Programmatic Agreement. 

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3.11 Impacts to Cultural Uses and Treaty Rights 

3.11.1 Introduction 

The following is a summary of information provided by the tribes on their internet sites and/or 

taken from information and maps prepared for the Interior Columbia Basin project. The intent of 

the section is to characterize use and interests of the lands managed by the National Forest and in 

no way is intended to indicate differences between tribal use and culture. 

3.11.2 Affected Environment 

Confederated Tribes of the Umatilla Indian Reservation: The Cayuse (Weyiiletpuu), Walla Walla 

(Waluulapan), and Umatilla (Imatalamlama) tribes make up the members of this reservation. 

Their reservation lands are adjacent to the Wallowa-Whitman and the Umatilla National Forests 

and the city of Pendleton, Oregon. Their interest area includes the Malheur River and Malheur 

and Harney Lakes to the south, the Grande Ronde and lower Snake River in the east and north, 

the Yakima, John Day, and Umatilla Rivers and the Columbia River from Vantage, Washington, 

to west of the Dalles, Oregon. Important rivers for fisheries include the Grande Ronde, Imnaha, 

John Day, Tucannon, Walla Walla, Wallowa, Touchet, Umatilla, Columbia, and Minam along 

with their tributaries. The Tribe has been active with salmon restoration in the Umatilla and 

Walla Walla Rivers. They have worked locally with several agencies to return water to these two 

streams in order to maintain migratory routes. 

Confederated Tribes of the Warm Springs Reservation: The Wasco Bands, the Warm Springs 

Bands and the Northern Paiutes are members of the reservation. Their area of interest includes 

Malheur and Harney Lakes in the southeast to the headwaters of the Deschutes River in the 

southwest, crossing Mount Hood to west of Portland, Oregon and along the Columbia River to 

the mouth of the Snake River along with the John Day system. There are historic family 

connections with the Umatillas and since the co-location of other tribes to the reservation, other 

family connections have developed. Important streams are the Columbia, Crooked, Deschutes, 

Hood, and John Day River and Fifteen Mile Creek. Their Treaty ceded the majority of the John 

Day system to the United States. 

Nimi'ipuu (Nez Perce): Their treaty established a reservation for the Nez Perce tribe. The 

reservation is located along the Clearwater River, east of Lewiston Idaho. Their area of interest 

includes lands east of the Snake River as far north as Coeur d’Alene, Idaho. It extends westward 

including the Snake and Palouse Rivers and the Columbia to The Dalles. To the south it includes 

the North Fork of the John Day to the confluence of the Malheur and Snake Rivers. Important 

streams include the Clearwater, Grande Ronde, Imnaha, Powder, Rapid, Salmon, Lower Snake, 

Lochsa, Selway, and Columbia Rivers. 

Deep canyons were the traditional Nez Perce lands. They traveled with the seasons relying on 

the rivers, mountains and prairies for sustenance. In early spring, the women traveled to the 

lower valleys to dig root crops and the men traveled to the Snake and Columbia rivers to 

intercept the early salmon runs. In mid-summer all the people of the village moved to higher 

mountainous areas setting up temporary camps to gather later root crops, fish the streams, and 

hunt big game. By late fall they settled back into their traditional villages along the Snake, 

Clearwater, and Salmon rivers. Salmon and other fish, game, dried roots and berries provided 

winter foods. 

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The basic roots gathered for winter storage include camas bulb (kehmmes), bitterroot (thleetahn), khouse (qawas), wild carrot (tsa-weetkh), wild potato (keh-keet), and other root crops. 

Fruit collected includes service berries, gooseberries, hawthorn berries, thorn berries, 

huckleberries, currants, elderberries, chokecherries, blackberries, raspberries, and wild 

strawberries. Other food gathered includes pine nuts, sunflower seeds, and black moss. 

3.11.3 Environmental Consequences 

Impacts Common to all Alternatives 

Direct and Indirect Effects 

Access: Access to National Forest Systems lands would not be impacted by invasive plant 

treatments. The Forest’s Access and Travel Management Plan would not be changed. If an open 

road or a road permitted for Off Highway Vehicle (OHV) use needs to be closed as part of the 

effective treatment prescription, a separate analysis would be completed. The proposed invasive 

plant treatments would not impact access to the forest to exercise treaty rights. 

Gathering: (Also see the botany report) When herbicides are used as the selected treatment 

method, individual tribal members may shift to other locations for gathering cultural plants. 

Early involvement with the Tribes prior to treatment would allow a schedule to be developed so 

that gathering could occur prior to treatments or in the case of huckleberries, early enough prior 

to fruit setting so any residual herbicides would be gone. Most treatments (72 percent of the 

acres) would occur within 20 feet of a road, disturbed site, or other high use area; occasionally 

treatments would extend to 100 feet. The areas adjacent to these high use areas do not provide 

quality habitat for cultural plants and can be easily avoided during gathering. Areas receiving 

herbicide treatments will be posted with warning signs. Herbicide treatments adjacent to high use 

areas would have low impacts on the gathering of cultural plants, and to the quantity or quality 

of the plants collected since the treatment areas can be avoided. 

The most extensive invasive plant sites beyond the high use areas have yellowstar thistle. These 

sites are located in dry grasslands or moist meadows that are potential habitat for cous and 

camas. Biological control methods are the primary treatment method and would not impact 

cultural plants or their use. High densities of yellowstar thistle displace native plants and likely 

would not be strongholds of cultural use plants; these areas are not likely to be used for 

gathering. Controlling the spread of yellowstar thistle would preserve native plant habitat and 

reduced yellowstar densities would allow native plants to recover. 

If herbicides are used to treat yellowstar thistle, there is an increased possibility of herbicide 

contact with cultural plants. This can be reduced by the application method. If the site is located 

in a traditional use area, the treatment could be designed around the target and cultural plant life 

cycles. If effective, spot treatments could be used; however, the density of yellowstar thistle 

would normally require broadcast treatments. Since cous and camas normally go dormant 

between mid July and August on the Forest (depends on elevation and year) it would be possible 

to treat after the cultural plants are dormant and/or in the fall as yellowstar thistle germinate. 

A mixture of methods could be used as well depending on the size of the invasive plant site. For 

knapweeds growing with lomatiums (cous), it would be possible to pull the knapweed to delay 

the rosette stage until after the lomatiums are dormant to follow up with herbicide at a later visit. 

This could be used around rock sources, particularly when other cultural gatherings are planned 

for the area in early summer. 

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In the higher elevations where huckleberries are found, the vast majority of invasive plants are 

associated with roads. Very few invasive plants would be found off the roads because forest 

cover and herbaceous plants would inhibit invasive plant growth. Any areas treated with 

herbicide would be posted. Since treatments would be along the road edges and surface, contact 

with herbicide can be avoided by moving further from the road. 

Invasive plant treatments are not expected to impact the gathering of plants, roots, or berries. 

When herbicides are used, the areas can be avoided. The area treated would be largest the first 

year with follow-up treatments in later years either covering fewer acres or using non-herbicide 

methods. Displacement of tribal members would very depending on the success of treatments 

and the amount of time needed to control or eradicate the target species. Since the treatment is 

mainly associated with roads and other high use areas, impacts to gathering will be low. 

Approximately 10 percent of the total acres proposed for herbicide treatment are distant to roads 

meaning that very little of the Forest landscape outside of high use areas would be impacted by 

treatments. Informing the tribes of proposed treatments each year would help avoid conflicts and 

allow the Forest and Tribe to work together if restoration is necessary due to invasive plants 

displacing cultural plants. 

Fish habitat and water quality: Impacts to fisheries habitat are analyzed in the Fisheries 

Report. The Project Design Features are expected to keep herbicides levels well below levels of 

concern for fish reproduction or human use. The low levels of herbicide used in riparian areas 

are not expected to concentrate in fish or create health issues. The Project Design Features would 

limit activities along stream banks when fish are spawning. Areas of high quality riparian habitat 

are distant from roads and contain very few sites. These areas would not have any measurable 

impacts from herbicide use and would continue to function as strongholds for recovery efforts. 

Hunting: Impacts to big game are disclosed in the Wildlife Report. Big game or birds are not 

expected to bioconcentrate herbicides. With the majority of treatments near roads, the potential 

use of forage treated with herbicide is low. 

During the time of treatments, animals would disperse due to the workers being present and 

noise of equipment. The activity is short duration and would not impact hunting or the 

populations of game species. 

Cumulative Effects 

Other than harassing of fish or game from other resource management actions or recreational 

uses when they occur at the same time as treatment, there would be few cumulative effects 

expected with other ongoing or reasonable foreseeable future actions. Each action would have its 

own prevention plan that would reduce the risk for spread of invasive plants. There is a low 

likelihood of these actions causing a need for additional invasive plant treatments. 

Other than prescribed fire, very few ground disturbing actions are proposed in the 

meadow/grassland habitats away from roads. Forest harvest activities would retain cover. 

Grazing may increase the spread of local invasive plants however allotment management plans 

reduce this risk by requiring the permittee to inventory and report any new invasive plant sites 

and taking measures to reduce the risk of carrying invasive plants onto the forest when they turn 

out in the spring. In some allotments pastures have been closed until the invasive plants can be 

controlled. These activities will likely cause new invasive plant sites to appear in areas of high 

use, but the amount is likely much less than five percent of the current inventory over the next 

ten to fifteen years. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 3 

Impacts Associated with Alternative C 

Direct, Indirect and Cumulative Impacts: Alternative C does not use broadcast spray methods 

in riparian areas. There would be a slight reduction in the amount of herbicide used near streams 

but would not be measurable. 

More care would be taken to make sure herbicides are applied directly on the target species; 

however, when target species densities are high, the amount of chemical needed would be similar 

to broadcast treatments. See the fisheries and water quality reports. 

Impacts Associated with Alternative D 

Direct, Indirect and Cumulative Impacts: The alternative does not use aerial application 

methods on 675 acres. There would be little differences in the amount of chemical used when 

hand treatments are used. Herbicide moving off site by aerial drift would be reduced but 

inconsequential because Project Design Features already reduce the risk of drift reaching riparian 

areas. The majority of the sites receiving aerial treatments are small (See map in Appendix B); 

however, one is approximately 300 acres. Impacts to wildlife that continue to use the 300 acre 

site after treatments would not change. Hand treatments could break up the site into smaller 

treatment units, but would extend the amount of time animals are exposed to herbicide. Even 

with the animals being exposed to chemicals, 300 acres is a small part of their utilizable range 

which reduces the amount of time animals spend in the area. The site is also remote (this is why 

the site was proposed for aerial treatment) and not likely to be used for gathering or hunting. 

3.12 Irreversible or Irretrievable Use of Resources 

No irreversible or irretrievable uses of resources are associated with the Proposed Action of this 

project. This project restores native vegetation in areas where non-native plants have been 

introduced. Herbicide treatments in accordance with the alternatives would have relatively shortlived impacts; effects on non-target species would be minimized through the implementation of 

Forest Plan Standards and Project Design Features disclosed in Section 2.2.3. Such effects would 

not be permanent. 

The No Action Alternative is a continuation of the present invasive plant treatment program. To 

date while some locations have succeeded in controlling weeds, overall the presence and effect 

of weeds has spread. In time this could have irreversible/irretrievable effects on range resources, 

range ecology and the management of programs dependent on range. 

3.13 Effects of Short-term uses and Maintenance of Longterm Productivity 

Positive effects on site productivity would be expected as native vegetation is restored. Some 

herbicides have potential to reduce soil productivity; Project Design Features are intended to 

avoid use of such herbicides where soil productivity may be threatened. 

3.14 Consistency with Forest Service Policies and Plans 

The proposed project is consistent with all Forest Service policies and existing plans. The laws 

and policies applicable to this project are listed in Section 1.5 of this DEIS. Policy consistency 

includes following the Forest Plan (1990) as amended by PACFISH/INFISH (1995) and the 

Regional Invasive Plant Program FEIS (2005). 

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421 

This latter document details regional policies applicable to all Forests from Forest Service 

Manual (FSM 2080) and past regional invasive plan program documents. These are discussed in 

Sections 2.3, 2.4 and 2.5 in the R6 2005 FEIS. 

3.15 Conflicts with Other Plans 

No conflicts with existing plans have been noted. 

3.16 Adverse Effects That Cannot Be Avoided 

Most of the important issues are resolved through adherence to Project Design Features that 

minimize or eliminate the potential for adverse effects. However, some adverse effects are 

inherent to invasive plant treatments and cannot be avoided. These include: 

• Taxpayers will likely be responsible for the costs of some if not all the treatments 

• Herbicide toxicity exceeding thresholds of concern are unlikely but possible given an 

herbicide spill 

• Minor to moderate physical injuries due to forestry work are possible 

• Local effects on some groups of soil micro-organisms that may be temporarily sensitive 

to certain herbicide chemicals 

• Some common non-target plants are likely to be killed by their close proximity to 

treatments. This is most likely with broadcast herbicide treatments and less likely (but 

possible) for all other treatment methods. The adverse effects of the invasive plants 

themselves far outweigh the potential for adverse effects of treatment 
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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 4 

Chapter 4 – List of Preparers 

4.1 List of Preparers 

The following people were the primary authors of this EIS. 

Vince Archer 

US Forest Service TEAMS Enterprise Unit 

B.S. Physical Science, M.S. Soils 

Soil Scientist 

Barbara A. F. Ott 

US Forest Service TEAMS Enterprise Unit 

M.S. Management, B.A. Business 

Administration 

Social Scientist 

Sandy Caveny 

US Forest Service TEAMS Enterprise Unit 

B.S Forest Management 

Recreation Specialist 

Janice Schultz 

US Forest Service TEAMS Enterprise Unit 

Writer/Editor – Project Record 

Allison Kuehl 

US Forest Service TEAMS Enterprise Unit 

M.S. Range Management, B.S. Wildlife 

Wildlife Biologist 

Carol Thornton 

US Forest Service TEAMS Enterprise Unit 

B.S. Geology, M.S. Hydrology/Hydrogeology 

Hydrologist 

Julie Laufman 

US Forest Service TEAMS Enterprise Unit 

PhD. Rangeland Ecosystem Science 

Botanist 

Chris Tootell 

US Forest Service TEAMS Enterprise Unit 

B.S. Natural Resources Conservation 

MS Forest Science 

Interdisciplinary Team Leader – NEPA 

Bill Overland 

US Forest Service TEAMS Enterprise Unit 

B.S. Forestry and Natural Resources 

GIS

Tiffany Vandosall 

US Forest Service TEAMS Enterprise Unit 

B.S. Biology and Chemistry 

M.S. Aquatic Ecology 

Fisheries Biologist 

Scott Reitz 

US Forest Service TEAMS Enterprise Unit 

A.A Natural Resources and Conservation 

B.S. Wildlife Sciences 

Certified Wildlife Biologist 

Rochelle Desser 

US Forest Service TEAMS Enterprise Unit 

A.A. Geo-technology 

Regional Oversite 

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Chapter 4 

4.2 Consultation with Regulatory Agencies 

The Forest Service has initiated consultation with the US Fish and Wildlife Service and NOAA 

Fisheries regarding potential adverse effects on Endangered Species. The consultation is tiered to 

programmatic consultation at the Regional Scale. 

A Biological Assessment will be prepared for the Preferred Alternative. A Record of Decision 

will not be signed prior to receiving a Letter of Concurrence from the regulatory agencies 

supporting determinations of Not Likely to Adversely Affect and/or they issue a Biological 

Opinion describing terms and conditions associated with a determination of Likely to Adversely 

Affect. 

4.3 Consultation with Tribes 

Letters were sent to Tribal leaders of the Nez Perce, Confederate Tribes of the Umatilla Indian 

Reservation (CTUIR), and Confederate Tribes of the Warm Springs Reservation in April of 

2006. None of tribes responded to the letter. The Forest had meetings with various tribal 

resource staff. During these meetings the tribes were supportive of the Forest’s efforts to treat 

invasive plants and being able to use all the tools/methods described in the Proposed Action. 

The experience of the CTUIR using aerial treatments for yellowstar thistle is decribed as 

successful when intergrated with other land owners. The Nez Perce felt that biological treatments 

should be an intergrated approach used on the landscape. All tribes have a concern about 

coordinating herbicide treatments with traditional gathering activities and areas. A process will 

be developed for notifying each tribe when herbicides are being used as required by the Project 

Design Features in Chapter 2. 

4.4 Consultation with Counties 

The Forest Service has worked closely with the County Weed Boards. County staff have 

presented information to the Forest Service (Available in the Project Record) and participated in 

field visits. The Counties often implement projects for the Forest Service and other land 

managers in the area and fully support this project. 

4.5 Consultation with Others 

Many people within and outside the Forest Service helped the team develop and analyze the 

project. Managers and specialists from the National Forest reviewed analysis documentation and 

suggested changes. 

Public scoping has occurred on this project since 2006. The public has been apprised of project 

progress through the newspaper, direct mailings, Notices of Intent published in the Federal 

Register in 2006, the Forest Schedule of Proposed Actions, informal meetings and discussions, 

and other media. 

Many organizations and individuals have expressed interest in the project; everyone who 

commented during scoping was offered a hard copy or CD containing the DEIS and Appendices. 

The full DEIS and Appendices is also available electronically by website: 

http://www.fs.fed.us/w-w/projects/ or on request (see cover page for more information to request 

a CD or hard copy). 

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Hard copies are available for review at Forest Service offices throughout the area. The DEIS has 

been sent to the Environmental Protection Agency (who commented during scoping) and other 

federal and state agencies. The following is a list of individuals, tribal governments, government 

officials, county programs, and individual organizations to whom this DEIS was sent: 

Individuals 

Andrew and Mercedes Hansen Kent Weaver 

Dorene McCarthy Lawson Denny 

Fred and Anna May Warnock Lyle and Margaret Defrees 

Gene Walker Michael Riggs 

Greg K. Johnson Michael D. Rutherford 

Jacob and Wendy Bingham Neal J. and Anna Dow 

Jeanne M. Rachau Robert E. and Edna Loftus 

Jeff Dawson Rod George 

Jennifer Schemm Spencer Scott Lewis 

Joann Anderson Teddy and Virginia Daggett 

Jon Croghan Thomas Thomayer 

Kathryn M. Krieger Willard A. Godfrey 

Ken Witty William and Donna Tsiatsos 

Kenneth Grant 

Tribes 

Confederated Tribes of the Umatilla Indian Reservation 

Honorable Antone Minthorn, Chairman Board of Trustees 

Eric Quaempts, Natural Resources Director 

Nez Perce Tribe 

Honorable Sam Penney, Chairman Nez Perce Tribal Executive Committee 

Brooklyn Baptiste, Chairman Natural Resources Subcommittee 

Government Officials 

U.S. Representative Bill Sahli, Todd Snodderly Field Representative 

U.S. Representative Greg Walden, Colby Marshall Field Representative 

U.S. Senator Gordon Smith, Larry Bartee Field Representative 

U.S. Senator Larry Craig, Jeff Sayre Regional Director 

U.S. Senator Mike Crapo, Mitch Silvers Regional Director 

U.S. Senator Ron Wyden, Kathleen Cathey Field Representative 

Counties 

Adams County Commissioners 

Adams County Weed Control, Ray McKinney 

Baker County Commissioners 

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426

Baker County Weed Coordinator, Arnie Grammon 

Idaho County Commissioners 

Idaho County Weed Management, Carl Crabtree 

Nez Perce County Commissioners 

Nez Perce County Weed Control, Hugh Jacobs 

Union County Commissioners 

Union County Weed Control, Gary Dade 

Wallowa County Commissioners 

Wallowa County Weed Coordinator, Allen Schnetzky 

Individual Organizations 

Bell Family Partners, 

Blue Mountain Biodiversity Project, Karen Coulter 

Blue Mountain Forum, Jennie Tucker 

Bruno Ranch, Maria Bruno 

Eastern Oregon All Terrain Vehicle Association, Tim Mahan 

Eastern Oregon Mining Association, Ed Hardt 

Flying O Cattle Company, Janet Delong 

Grande Ronde Model Watershed Program, Jeff Oveson 

Hells Canyon Preservation Council, Greg Dyson 

Hurricane Creek Grange #608 

Noxious Weed Management Coordinator, Don Sharrat 

Oregon Hunters Association, Charlie Brinton 

Oregon Sportsmen Halfway Chapter, Marion Crow 

Oregon Wild, Doug Heiken 

Pacific Northwest 4-Wheel Drive Association, Art Waugh 

Rock’n “J” Properties 

Rocky Mountain Elk Foundation, Steve Martin 

Sams Orchard, Dan Sams 

Sierra Club, Asante Riverwind 

The Wilderness Society, Brad Brooks 

Tri-County Cooperative Weed Management, Gary Winans 

Upper Burnt River Weed Control District, Ross Shumway 

VFW Auxiliary, Agnes Roberts 

Wallowa Resources, Nils Christoffersen 

Wallowa Valley Trail Riders Association, Randall & Velma Parmelee 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 4 

4.6 Glossary 

Active ingredient (a.i.) - In any pesticide product, the component (a chemical or biological 

substance) that kills or otherwise controls the target pests - Pesticides are regulated primarily on 

the basis of active ingredients. The remaining ingredients are called “inerts.” 

Acute effect - An adverse effect on any living organism in which severe 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 

dependant on the life span of the organism. (See also, chronic exposure and cumulative 

exposure.) 

Acute toxicity - Any harmful effect produced in an organism through an acute exposure to one 

or more chemicals. 

Adaptation - Changes in an organism's physiological structure or function or habits that allow it 

to survive in new surroundings. 

Adapted - How well organisms are physiologically or structurally suited for survival, growth, 

and resistance to pests and diseases in a particular environment. 

Additive effect - A situation in which the combined effects of exposure to two chemicals 

simultaneously is equal to the sum of the effect of exposure to each chemical given alone. The 

effect most commonly observed when an organism is exposed to two chemicals together is an 

additive effect. 

Adaptive management - A continuing process of action-based planning, monitoring, 

researching, evaluating, and adjusting with the objective of improving implementation and 

achieving the goals of the standards and guidelines 

Adjuvant(s) - Chemicals that are added to pesticide products to enhance the toxicity of the 

active ingredient or to make the active ingredient easier to handle or mix. 

Administratively Withdrawn Areas (AWA) - Areas removed from the suitable timber base 

through agency direction and land management plans. 

Adsorption - The tendency of one chemical to adhere to another material such as soil. 

Aerobic - Life or processes that require, or are not destroyed by, the presence of oxygen. (See 

also, 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. 

Agent - Any substance, force, radiation, organism, or influence that affects the body. The effects 

may be beneficial or injurious. 

Agency for Toxic Substances and Disease Registry (ATSDR) - Federal agency within the 

Public Health Service charged with carrying out the health-related analyses under 

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Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and 

Superfund Amendments and Reauthorization Act (SARA). 

Alien species - “With respect to a particular ecosystem, any species, including its seeds, eggs, 

spores, or other biological material capable of propagating that species, that is not native to that 

ecosystem” (Executive Order 13122, 2/3/99). (See also, invasive, noxious, and weed species.) 

Allelopathy - The suppression of growth of one plant species due to the release of toxic 

substances by another plant. 

Alluvial - Relating to clay, silt, sand, gravel, or similar detrital material deposited by flowing 

water. Alluvial deposits may occur after a heavy rain storm. 

Ambient - Usual or surrounding conditions. 

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. 

Anadromous - Fish that spend their adult life in the sea but swim upriver to fresh water 

spawning grounds to reproduce. 

Anaerobic - Life or process that occurs in, or is not destroyed by, the absence of oxygen. (See 

also, aerobic.) 

Anions - Negatively charged ions in solution e.g., hydroxyl or OH- ion. (See also, cations.) 

Annual - A plant that endures for not more than a year. A plant which completes its entire life 

cycle from germinating seedling to seed production and death within a year. 

Annuity - Payment or receipt of a series of equal amounts at stated intervals for a specified 

number of time periods. An “annuity due” is a series of equal value outputs or inputs occurring 

for N equal time periods with “payments” made at the beginning of each period. 

Anoxia - Literally, "without oxygen.” A deficiency of oxygen reaching the tissues of the body 

especially of such severity as to result in permanent damage. 

Aquatic Influence Zone – The inner half of a Riparian Reserve. 

Aqueous - Describes a water-based solution or suspension. 

Aquifer - An underground geological formation, or group of formations, containing usable 

amounts of groundwater that can supply wells and springs. 

Arid - A terrestrial region lacking moisture, or a climate in which the rainfall is not sufficient to 

support the growth of most vegetation. 

Background level - In pollution, the level of pollutants commonly present in ambient media (air, 

water, soil.) 

Bacteria - Microscopic living organisms that metabolize organic matter in soil, water, or other 

environmental media. Some bacteria can also cause human, animal and plant health problems. 

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Basal application - In pesticides, the spreading of a chemical on stems or trunks of plants just 

above the soil line. 

Base - Substances that (usually) liberate hydroxyl (OH-) anions when dissolved in water and 

weaken a strong acid. 

Benchmark - A dose associated with a defined effect level or designated as a no effect level. 

Benthic region - The bottom layer of a body of water. 

Benthos - The plants and animals that inhabit the bottom layer of a water body. 

Best Management Practices (BMP) - A practice or combination of practices determined by a 

state or an agency to be the most effective and practical means (technological, economic, and 

institutional) of controlling point and non-point source pollutants at levels compatible with 

environmental quality. 

Bioaccumulation - The increase in concentration of a substance in living organisms as they take 

in contaminated air, water, or food because the substance is very slowly metabolized or excreted 

(often concentrating in the body fat.) 

Bioassay - (1) To measure the effect of a substance, factor, or condition using living organisms. 

(2) A test to determine the toxicity of an agent to an organism. 

Bioconcentration - The accumulation of a chemical in tissues of a fish or other organism to 

levels greater than in the surrounding water or environment. 

Bioconcentration Factor (BCF) - The concentration of a compound in an aquatic organism 

divided by the concentration in the ambient water of the organism. 

Biodegradability - Susceptibility of a substance to decomposition by microorganisms; 

specifically, the rate at which compounds may be chemically broken down by bacteria and/or 

natural environmental factors. 

Biodiversity or biological diversity - The diversity of living things (species) and of life patterns 

and processes (ecosystem structures and functions). Includes genetic diversity, ecosystem 

diversity, landscape and regional diversity, and biosphere diversity. 

Biological control - The use of natural enemies, including invertebrate parasites and predators 

(usually insects, mites, and nematodes,) and plant pathogens to reduce populations of nonnative, 

invasive plants. 

Biological magnification - The process whereby certain substances such as pesticides or heavy 

metals increase in concentration as they move up the food chain. 

Biologically sensitive - A term used to identify a group of individuals who, because of their 

developmental stage or some other biological condition, are more susceptible than the general 

population to a chemical or biological agent in the environment. 

Biomass - The amount of living matter. 

Biota or Biome - All living organisms of a region or system. 

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Body Burden - The amount of a chemical stored in the body at a given time, especially a 

potential toxin in the body as the result of exposure. 

Broadcast application - Herbicide treatment method generally used along roads; boom truck 

spray is directed at target species. Broadcast methods are used for larger infestations where spot 

treatments would not be effective. 

Bryophytes - Plants of the phylum Bryophyta, including mosses, liverworts, and hornworts; 

characterized by the lack of true roots, stems, and leaves. 

Buffer Zone - A strip of untreated land that separates a waterway or other environmentally 

sensitive area from an area being treated with pesticides. 

Candidate species - Those plant and animal species that, in the opinion of the Fish and Wildlife 

Service (FWS) or National Oceanic and Atmospheric Administration (NOAA) Fisheries, may 

qualify for listing as “endangered” or “threatened.” The FWS recognizes two categories of 

candidates. Category 1 candidates are taxa for which the FWS has on file sufficient information 

to support proposals for listing. Category 2 candidates are taxa for which information available 

to the FWS indicates that proposing to list is possibly appropriate, but for which sufficient data 

are not currently available to support proposed rules. 

Capillary fringe - The zone above the water table within which the soil or rock is saturated by 

water under less than atmospheric pressure. 

Carcinogen - A chemical capable of inducing cancer. 

Carrier - A non-pesticidal substance added to a commercial pesticide formulation to make it 

easier to handle or apply. 

Chemical Abstracts Service (CAS) Registry Number - An assigned number used to identify a 

chemical. Chemical Abstracts Service is an organization that indexes information published in 

Chemical Abstracts by the American Chemical Society and that provides index guides to help 

locate information about particular substances in the abstracts. Sequentially assigned CAS 

numbers identify specific chemicals. The numbers have no chemical significance. The CAS 

number is a concise, unique means of chemical identification. 

Cations - Positively charged ions in a solution. (See also, anion.) 

Characteristic Landscape - The naturally established landscape within a scene or scenes being 

viewed. 

Chemical Control - The use of naturally derived or synthetic chemicals called herbicides to 

eliminate or control the growth of invasive plants. 

Chronic exposure - Exposures that extend over the average lifetime or for a significant fraction 

of the lifetime of the species (for a rat, chronic exposure is typically about two years). Chronic 

exposure studies are used to evaluate the carcinogenic potential of chemicals and other long-term 

health effects. (See also, acute and cumulative exposure.) 

Chronic Reference Dose (RfD) - An estimate of a lifetime daily exposure level (in mg/kg/day) 

for the human population, including sensitive subpopulations, that is likely to be without an 

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appreciable risk of deleterious effects. Chronic RfDs are specifically developed to be protective 

for long-term exposure to a compound (seven years to lifetime.) 

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 

Code of Federal Regulations (CFR) - Document that codifies all rules of the executive 

departments and agencies of the federal government. It is divided into fifty volumes, known as 

titles. Title 40 of the CFR (referenced as 40 CFR) lists all environmental regulations, including 

regulations for EPA pesticide programs (40 CFR Parts 150-189). 

Competitive seeding - Treatment method; most effective after weed populations have been 

reduced by other control actions. 

Congressionally Designated Areas - Areas that require Congressional enactment for their 

establishment, such as National Parks, Wild and Scenic Rivers, National Recreation Areas, 

National Monuments, and Wilderness. Also referred to as Congressional Reserves. Includes 

similar areas established by Executive Order, such as National Monuments. 

Conifer - An order of the Gymnospermae, comprising a wide range of trees and a few shrubs, 

mostly evergreens that bear cones and have needle-shaped or scale-like leaves. Conifer timber is 

commercially identified as softwood. 

Connected actions - Exposure to other chemical and biological agents, in addition to exposure 

to a specific pesticide formulation in a field application to control pest organisms. 

Contaminants - For chemicals, impurities present in a commercial grade chemical. For 

biological agents, other agents that may be present in a commercial product. 

Control - Means, as appropriate, eradicating, suppressing, reducing, or managing invasive plant 

species populations, preventing spread of invasive plants from areas where they are present, and 

taking steps such as restoration of native plant species and habitats to reduce the effects of 

invasive plants and to prevent further invasions (Executive Order 13122, 2/3/99). 

Cultural control - The establishment or maintenance of competitive vegetation, use of 

fertilizing, mulching, prescribed burning, or grazing animals to control or eliminate invasive 

plants. Prescribed burning and grazing animals are cultural control treatments that would not be 

utilized under this project; nor are they covered under this EIS. 

Cumulative Effect (CE) - The impact on the environment that results from the incremental 

impact of the action when added to other past, present, and reasonably foreseeable future 

actions—regardless of what agency (federal or non-federal) or person undertakes such other 

actions. Cumulative impacts can result from individually minor, but collectively significant, 

actions taking place over a period of time (40 CFR 1508.7). 

Cumulative exposure - Exposure resulting from one or more activities that are repeated over a 

period of time. (See also, acute and chronic exposure.) 

Detritus - Loose fragments, particles, or grains formed by the disintegration of organic matter or 

rocks. 

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Discount - In economics, discounting is the process of carrying an end value backward in time 

at compound interest. 

Distance Zones - Landscape areas denoted by specified distances from the observer. Used as a 

frame of reference in which to discuss landscape attributes or the scenic effect of human 

activities in a landscape. 

Disturbance - An effect of a planned human management activity, or unplanned native or exotic 

agent or event that changes the state of a landscape element, landscape pattern, or regional 

composition. 

Dosage/Dose - (1) The actual quantity of a chemical administered to an organism or to which it 

is exposed. (2) The amount of a substance that reaches a specific tissue (e.g. the liver). (3) The 

amount of a substance available for interaction with metabolic processes after crossing the outer 

boundary of an organism. 

Dose Rate - In exposure assessment, dose per time unit (e.g. mg/day); also called dosage. 

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. 

Drift - The portion of a sprayed chemical that is moved by wind off of a target site. 

Emergent Vegetation - Plants growing out of or standing in water, in contrast to “submerged 

aquatic vegetation (SAV),” which grows entirely underneath the waters’ surface. 

Endangered Species - Any species listed in the Federal Register 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 U.S. 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 - A species or other taxonomic group that is restricted to a particular geographic region 

due to factors such as isolation or response to soil or climatic conditions. (Compare to 

“Indigenous” and “Native.”) 

Environmental justice - Executive Order 12898 of February 11, 1994 requires federal agencies, 

to the greatest extent practicable and permitted by law, to make achieving environmental justice 

part of its mission by identifying and addressing, as appropriate, disproportionately high and 

adverse human health or environmental effects of its programs, policies, and activities on 

minority populations and low-income populations in the United States and its territories and 

possessions, the District of Columbia, the Commonwealth of Puerto Rico, and the 

commonwealth of the Mariana Islands. 

Exposure assessment - The process of estimating the amount of contact with a chemical or 

biological agent that an individual or a population of organisms will receive from a pesticide 

application conducted under specific, stated circumstances. 

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Exotic – Non-native species; introduced from elsewhere, but not completely naturalized. (See 

also alien and introduced species.) 

Extirpate - To destroy completely; wipe out. 

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. 

Fauna - The animals of a specified region or time. 

Federally listed species - Formally listed as a threatened or endangered species under the 

Endangered Species Act. Designations are made by the Fish and Wildlife Service or the National 

Marine Fisheries Service. 

Federal Insecticide and Rodenticide Act (FIFRA) Pesticide Ingredient - An ingredient of a 

pesticide that must be registered with EPA under the Federal Insecticide, Fungicide, and 

Rodenticide Act. Products making pesticide claims must submit required information to EPA to 

register under FIFRA and may be subject to labeling and use requirements. 

Fertilization - Treatment method involving adding of nutrients, which could improve the 

success of desirable species; may be limited, depending on species/soil characteristics. 

Flora - Plant life, especially all the plants found in a particular country, region, or time regarded 

as a group. Also, a systematic set of descriptions of all the plants of a particular place or time. 

Foaming - Hot foam is a mechanical method that is effective on seedlings and annuals and can 

be applied under certain weather conditions, including wind and light rain. 

Food chain - A hierarchical sequence of organisms, each of which feeds on the next, lower 

member of the sequence 

Forage - Food for animals. In this document, term applies to both availability of plant material 

for wildlife and domestic livestock. 

Formulation - A commercial preparation of a chemical including any inerts and/or 

contaminants. 

Fungi - Molds, mildews, yeasts, mushrooms, and puffballs, a group of organisms that lack 

chlorophyll and therefore are not photosynthetic. They are usually non-mobile, filamentous, and 

multi-cellular. 

Game fish - Species like trout, salmon, or bass, caught for sport. Many of them show more 

sensitivity to environmental change than non-game fish. 

Grazing animals - Treatment method which requires matching the invasive plant species with 

the appropriate grazer for best success. 

Groundwater Loading Effects of Agricultural Management Systems (GLEAMS) – A model 

which displays herbicide concentrations in streams under a variety of conditions. 

Groundwater - The supply of fresh water found beneath the Earth's surface, usually in aquifers, 

which often supply wells and springs. 

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Habitat - The place where a population (e.g., human, animal, plant, microorganism) lives and its 

surroundings, both living and non-living. 

Halftime or half-life - The time required for the concentration of the chemical to decrease by 

one-half. 

Hand/Selective application - Herbicide treatment of individual plants through wicking, wiping, 

injecting stems, etc., with low likelihood of drift or delivery of herbicides away from treatment 

sites. This method ensures no herbicide directly contacts soil. 

Hand-pulling/Grubbing - Treatment method which is labor-intensive but effective on single 

plants or on small, low-density infestations. 

Hazard Quotient (HQ) - The Hazard Quotient is the amount of herbicide or additives to which 

an organism may be exposed over a specified period, divided by the estimated daily exposure 

level at which no adverse health effects are likely to occur. An HQ less than or equal to one 

indicates an extremely low level of risk; therefore, an HQ less than or equal to one is presumed 

to indicate a level of exposure below the threshold of concern for adverse health effects. 

Hazard identification - The process of identifying the array of potential effects that an agent 

may induce in an exposed of humans or other organisms. 

Herbaceous - A plant that does not develop persistent woody tissue above the ground (annual, 

biennial, or perennial.) Herbaceous vegetation includes grasses and grass-like vegetation, and 

broadleaved forbs. 

Herbicide - A chemical preparation designed to kill plants, especially weeds, or to otherwise 

inhibit their growth. 

Humus - Organic portion of the soil remaining after prolonged microbial decomposition. 

Tribal and Treaty Rights - Native American treaty and other rights or interests recognized by 

treaties, statutes, laws, executive orders, or other government action, or federal court decisions. 

Indian Tribe - Any American Indian or Alaska Native tribe, band, nation, pueblo,community, 

rancheria, colony, or group meeting the provisions of the Code of Federal Regulations Title 25, 

Section 83.7 (25 FR 83.7), or those recognized in statutes or treaties with the United States. 

Indigenous - An indigenous species is any which were or are native or inherent to an area. (See 

also, native.) 

Inerts - Anything other than the active ingredient in a pesticide product; not having pesticide 

properties. 

Infested area - A contiguous area of land occupied by, in this case, invasive plant species. An 

infested area of land is defined by drawing a line around the actual perimeter of the infestation as 

defined by the canopy cover of the plants, excluding areas not infested. Generally, the smallest 

area of infestation mapped will be 1/10th (0.10) of an acre or 0.04 hectares. 

Integrated Weed Management (IWM) - An interdisciplinary weed management approach for 

selecting methods for preventing, containing, and controlling noxious weeds in coordination 

with other resource management activities to achieve optimum management goals and objectives 

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Interdisciplinary Team (IDT) - A group of individuals with varying areas of specialty 

assembled to solve a problem or perform a task. The team is assembled out of recognition that no 

one scientific discipline is sufficiently broad enough to adequately analyze the problem and 

propose action. 

Introduced species - An alien or exotic species that has been intentionally or unintentionally 

released into an area as a result of human activity. (See also exotic, invasive, and noxious.) 

Introduction - “The intentional or unintentional escape, release, dissemination, or placement of 

a species into an ecosystem as a result of human activity” (Executive Order 13122, 2/3/99). 

Invasive plant species - An alien plant species whose introduction does or is likely to cause 

economic or environmental harm or harm to human health (Executive Order 13122, 2/3/99) (See 

also exotic and introduced species) 

Irreversible effect - Effect characterized by the inability of the body to partially or fully repair 

injury caused by a toxic agent. 

Irritant - Non-corrosive material that causes a reversible inflammatory effect on living tissue by 

chemical action at the site of contact as a function of concentration or duration of exposure. 

LC50 (Lethal Concentration50) - A calculated concentration of a chemical in air or water to 

which exposure for a specific length of time is expected to cause death in 50 percent of a defined 

experimental animal population. 

LD50 (Lethal Dose50) - The dose of a chemical calculated to cause death in 50 percent of a 

defined experimental animal population over a specified observation period. The observation 

period is typically 14 days. 

Label - All printed material attached to, or part of, the pesticide container. 

Land allocation - Commitment of a given area of land or a resource to one or more specific uses 

(e.g. wilderness). In the Northwest Forest Plan, one of the seven allocations of Congressionally 

Withdrawn Areas, Late-Successional Reserves, Adaptive Management Areas, Managed LateSuccessional Areas, Administratively Withdrawn Areas, Riparian Reserves, or Matrix. 

Landscape - An area composed of interacting ecosystems that are repeated because of geology, 

land form, soils, climate, biota, and human influences throughout the area. Landscapes are 

generally of a size, shape, and pattern which is determined by interacting ecosystems. 

Landscape Character - Particular attributes, qualities, and traits of a landscape that give it an 

image and make it identifiable or unique. 

Landscape Setting - The context and environment in which a landscape is set; a landscape 

backdrop. It is the combination of land use, landform, and vegetation patterns that distinguish an 

area in appearance and character from other areas. 

Leachate - Water that collects chemicals as it trickles through soil or other porous media 

containing the chemicals. 

Leaching - The process by which chemicals on or in soil or other porous media are dissolved 

and carried away by water, or are moved into a lower layer of soil. 

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Level of Concern (LOC) - The concentration in media or some other estimate of exposure 

above which there may be effects. 

Lichens - Complex thallophytic plants comprised of an alga and a fungus growing in symbiotic 

association on a solid surface (such as a rock.) 

Littoral zone - (1) That portion of a body of fresh water extending from the shoreline lakeward 

to the limit of occupancy of rooted plants. (2) The strip of land along the shoreline between the 

high and low water levels. 

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. 

Manual Control - The use of any non-mechanized approach to control or eliminate invasive 

plants (i.e. hand-pulling, grubbing) 

Material Safety Data Sheet (MSDS) - A compilation of information required under the OSHA 

Communication Standard on the identity of hazardous chemicals, health and physical hazards, 

exposure limits, and precautions. 

Mechanical Control - The use of any mechanized approach to control or eliminate invasive 

plants (i.e. mowing, weed whipping, hot foam.) 

Microorganisms - A generic term for all organisms consisting only of a single cell, such as 

bacteria, viruses, protozoa and some fungi. 

Minimum tool - Use of a weed treatment alternative that would accomplish management 

objectives and have the least impact on resources 

Modification - A visual quality objective meaning human activities may dominate the 

characteristic landscape but must, at the same time, utilize naturally established form, line, color, 

and texture. It should appear as a natural occurrence when viewed in foreground or 

middleground. 

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 National Forest 

System land include snails, slugs, and clams. 

Monitoring - A process of collecting information to evaluate if objectives and anticipated or 

assumed results of a management plan are being realized or if implementation is proceeding as 

planned. 

Morbidity - Rate of disease, injury or illness. 

Mowing - Invasive plant treatment method which is limited to level/gently-sloping smoothsurface terrain. Treatment timing is critical, and must be conducted for several consecutive 

years. 

National Environmental Policy Act (NEPA) - An Act passed in 1969 to declare a national 

policy that encourages productive and enjoyable harmony between humankind and the 

environment, promotes efforts that prevent or eliminate damage to the environment and 

biosphere, stimulates the health and welfare of humanity, enriches the understanding of the 

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ecological systems and natural resources important to the nation, and establishes a Council on 

Environmental Quality. 

National Forest Management Act (NFMA) - A law passed in 1976 as an amendment to the 

Forest and Rangeland Renewable Resources Planning Act, requiring preparation of Forest Plans 

and the preparation of regulations to guide that development. 

National Marine Fisheries Service (NMFS) - The federal agency that is the listing authority for 

marine mammals and anadromous fish under the ESA. 

National Pollutant Discharge Elimination System (NPDES) - As authorized by the Clean 

Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program 

controls water pollution by regulating point sources that discharge pollutants into waters of the 

United States. Point sources are discrete conveyances such as pipes or man-made ditches. 

Individual homes that are connected to a municipal system, use a septic system, or do not have a 

surface discharge do not need an NPDES permit; however, industrial, municipal, and other 

facilities must obtain permits if their discharges go directly to surface waters. 

National Visitor Use Monitoring (NVUM) - A permanent, ongoing sampling system which 

measures national forest visitor demographics, experiences, preferences, and impressions. A 

stratified random sample is done for 25% of the National Forest system each year according to a 

national research protocol. NVUM responds to the need to better understand the use and 

importance of, and satisfaction with, national forest system recreation opportunities. 

National Wilderness Preservation System (NWPS) - The Wilderness Act of 1964 established 

the national Wilderness Preservation System to ensure that certain federally owned areas in the 

United States would be preserved and protected in their natural condition. The Act defines a 

wilderness area, in part, as an area which generally appears to have been affected primarily by 

the forces of nature, with the imprint of man’s work substantially unnoticeable. Areas included 

in the system are administered for the use and enjoyment of the American people in such manner 

as to leave them unimpaired for future use and enjoyment as wilderness. 

Native species - With respect to a particular ecosystem, a species that, other than as a result of 

an introduction, historically occurred or currently occurs in that ecosystem (Executive Order 

13122, 2/3/99). 

Naturalized - Applied to a species that originally was imported from another country but that 

now behaves like a native in that it maintains itself without further human intervention and has 

invaded native populations. 

Non-local native - This term has two meanings: (1) a population of a native plant species which 

does not occur naturally in the local ecosystem and/or (2) plant material of a native species that 

does not originate from genetically local sources. 

Non-target species - Any plant or animal that is not the intended organism to be controlled by a 

pesticide treatment. 

No-Observed-Adverse-Effect level (NOAEL) - Exposure level at which there are no 

statistically or biological significant differences in the frequency or severity of any adverse effect 

in the exposed or control populations 

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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 in the exposed or 

control populations. 

Not Likely to Adversely Affect (NLAA) - Determinations are applied to those species that had 

very little habitat on National Forests in Region Six, were not in habitats susceptible to invasive 

plants, or were known to tolerate herbicide treatments without effects. 

Noxious weed - “Any living stage (including but not limited to, seeds and reproductive parts) of 

any parasitic or other plant of a kind, or subdivision of a kind, which is of foreign origin, is new 

to or not widely prevalent in the United States, and can directly or indirectly injure crops, other 

useful plants, livestock, or poultry or other interests of agriculture, including irrigation, or 

navigation or the fish and wildlife resources of the United States or the public health” (Public 

Law 93-629, January 3, 1975, Federal Noxious Weed Act of 1974). 

Outstandingly Remarkable Value (ORV) - A characteristic of rivers or sections of rivers in the 

national Wild and Scenic River System. In order for a river to be included in the system, it must 

possess at least one “outstandingly remarkable” value, such as scenic, recreational, geologic, 

fish, wildlife, historic, cultural, or other similar features. ORV’s are values or opportunities in a 

river corridor which are directly related to the river and which are rare, unique, or exemplary 

from a regional or national perspective. 

Partial Retention - A visual quality objective which in general means human activities may be 

evident but must remain subordinate to the characteristic landscape. 

Pathogen - A living organism, typically a bacteria or virus, that causes adverse effects in another 

organism. 

Percolation - Downward flow or filtering of water through pores or spaces in rock or soil. 

Perennial - A plant species having a life span of more than two years. 

Periphyton - Microscopic plants and animals that are firmly attached to solid surfaces under 

water such as rocks, logs, pilings and other structures. 

Persistence - Refers to the length of time a compound, once introduced into the environment, 

stays there. 

Personal Protective Equipment (PPE) - Clothing and equipment worn by pesticide mixers, 

loaders and applicators and re-entry workers, hazmat emergency responders, workers cleaning 

up Superfund sites, et. al., which is worn to reduce their exposure to potentially hazardous 

chemicals and other pollutants. 

Pest - An insect, rodent, nematode, fungus, weed or other form of terrestrial or aquatic plant or 

animal life that is classified as undesirable because it is injurious to health or the environment. 

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, etc. 

Pesticide tolerance - The amount of pesticide residue allowed by law to remain in or on a 

harvested crop. 

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pH - The negative log of the hydrogen ion concentration. A high pH (greater than seven) is 

alkaline or basic and a low pH (less than seven) is acidic. 

Population - A group of individuals of the same species in an area. 

Population at Risk - A population subgroup that is more likely to be exposed to a chemical, or 

is more sensitive to the chemical, than is the general population. 

Porosity - Degree to which soil, gravel, sediment, or rock is permeated with pores or cavities 

through which water or air can move. 

Potable Water - Water that is considered safe for drinking and cooking. 

Project Design Features (PDF) - A set of implementation Design Features/features applied to 

projects to ensure that the project is done according to environmental standards and adverse 

effects are within the scope of those predicted in this Environmental Impact Statement. 

Proposed species - Any plant or animal species that is proposed by the Fish and Wildlife Service 

or NOAA Fisheries in a Federal Register notice to be listed as threatened or endangered. 

Potential Vegetation Type (PVT) - The term Potential Vegetation Type is used to represent the 

combination of species that could occupy the site in the absence of disturbance. 

Protozoa - Single-celled, microorganisms without cell walls containing visibly evident nuclei 

and organelles. Most protozoa are free-living although many are parasitic. 

Recreational Rivers - A classification within the national Wild and Scenic River System. 

Recreational rivers are those rivers, or sections of rivers, that are readily accessible by road or 

railroad, that may have some development along their shorelines, and that may have undergone 

some impoundment or diversion in the past. 

Reference Dose (RfD) - The RfD is a numerical estimate of a daily exposure to the human 

population, including sensitive subgroups such as children, that is not likely to cause harmful 

effects during a lifetime. RfDs are generally used for health effects that are thought to have a 

threshold or minimum dose for producing effects. 

Registered Pesticides - Pesticide products which have been approved for the uses listed on the 

label. 

Registration - Formal licensing with EPA of a new pesticide before it can be sold or distributed. 

Under the Federal Insecticide, Fungicide, and Rodenticide Act, EPA is responsible for 

registration (pre-market licensing) of pesticides on the basis of data demonstrating no 

unreasonable adverse effects on human health or the environment when applied according to 

approved label directions. 

Restoration - Ecological restoration is the process of assisting the recovery and management of 

ecological integrity. Ecological integrity includes a critical range of variability in biodiversity, 

ecological processes and structures, regional and historical context, and sustainable cultural 

practices. 

Retention - A visual quality objective which in general means human activities are not evident 

to the casual forest visitor. 

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Revegetation - The re-establishment of plants on a site - The term does not imply native or 

nonnative; does not imply that the site can ever support any other types of plants or species and 

is not at all concerned with how the site ‘functions’ as an ecosystem. 

Riparian Area - A geographic area containing an aquatic ecosystem and adjacent upland areas 

that directly affect it. 

Riparian Reserves - Areas along live and intermittent streams, wetlands, ponds, lakes, and 

unstable and potentially unstable areas where riparian-dependent resources receive primary 

emphasis. Riparian Reserves are important to the terrestrial ecosystem as well, serving as 

dispersal habitat for certain terrestrial species. 

Risk Assessment - An analytic process that is firmly based on scientific considerations, but also 

requires judgments to be made when the available information is incomplete. These judgments 

inevitably draw on both scientific and policy considerations. 

Risk - The chance of an adverse or undesirable effect, often measured as a percentage. 

Risk assessment - The qualitative and quantitative evaluation performed in an effort to estimate 

the risk posed to human health and/or the environment by the presence or potential presence 

and/or use of specific chemical or biological agents. 

Saturated zone - A subsurface area in which all pores and cracks are filled with water under 

pressure equal to or greater than that of the atmosphere. 

Scenery Management - The art and science of arranging, planning, and designing landscape 

attributes relative to the appearance of places and expanses in outdoor settings. 

Scenic - Of or relating to landscape scenery; pertaining to natural or natural-appearing scenery; 

constituting or affording pleasant views of natural landscape attributes or positive cultural 

elements. 

Scenic Rivers - A classification within the national Wild and Scenic River System. Scenic rivers 

are those rivers, or sections of rivers, that are free of impoundments, with shorelines or 

watersheds still largely primitive and shorelines largely undeveloped, but accessible in places by 

roads. 

Seen Area - The total landscape area observed based upon landform screening. Seen-areas may 

be divided into zones of immediate foreground, foreground, middleground, and background. 

Some landscapes are seldom seen by the public. 

Sensitive species - Species identified by the Regional Forester for which population variability 

is a concern, as evidenced by significant current or predicted downward trend in population 

numbers or density; or significant current or predicted downward trends in habitat capability that 

would reduce a species existing distribution. 

Species of Local Interest (SOLI) - Threatened, endangered and proposed species; Regional 

Forester’s Sensitive species, management indicator species, and other rare or endemic species of 

concern. 

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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.” (Executive Order 13122, 2/3/99). 

Spot application - Herbicide treatment involving use of a backpack sprayer or other means. 

Application is aimed at specific target species, with methods of prevention (such as barriers,) to 

control damage to non-target species. 

Standards and guidelines - The rules and limits governing actions, as well as the principles 

specifying the environmental conditions or levels to be achieved and maintained 

Sub-chronic exposure - An exposure duration that can last for different periods of time (5 to 90 

days), with 90 days being the most common test duration for mammals. The sub-chronic study is 

usually performed in two species (rat and dog) by the route of intended use or exposure. 

Sub-chronic toxicity - The ability of one or more substances to cause effects over periods from 

about 90 days but substantially less than the lifetime of the exposed organism. Sub-chronic 

toxicity only applies to relatively long-lived organisms such as mammals. 

Submerged Aquatic Vegetation (SAV) - Vegetation that lives at or below the water surface; an 

important habitat for young fish and other aquatic organisms. In contrast to “emergent 

vegetation,” which is growing out of or standing in water. 

Substrate - With reference to enzymes, the chemical that the enzyme acts upon 

Surface water - All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, 

impoundments, seas, estuaries, etc.) and all springs, wells, or other collectors which are directly 

influenced by surface water. 

Surfactant - A surface active agent; usually an organic compound whose molecules contain a 

hydrophilic group at one end and a lipophilic group at the other. Promotes solubility of a 

chemical, or lathering, or reduces surface tension of a solution. 

Synergistic effect - Situation in which the combined effects of exposure to two chemicals 

simultaneously is much greater than the sum of the effect of exposure to each chemical given 

alone. 

Take - "The term 'take' means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or 

collect, or to attempt to engage in any such conduct." (Title 16, Chapter 35, Section 1532, 

Endangered Species Act of 1973) 

Threatened species - Plant or animal species likely to become endangered throughout all, or a 

significant portion of, its range within the foreseeable future. A plant or animal identified and 

defined in accordance with the 1973 Endangered Species Act and published in the Federal 

Register. 

Threshold - The maximum dose or concentration level of a chemical or biological agent that 

will not cause an effect in the organism. 

Tolerances - Permissible residue levels for pesticides in raw agricultural produce and processed 

foods. Whenever a pesticide is registered for use on a food or a feed crop, a tolerance (or 

exemption from the tolerance requirement) must be established. EPA establishes the tolerance 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement 

Chapter 4 

levels, which are enforced by the Food and Drug Administration and the Department of 

Agriculture. 

Toxicity - The inherent ability of an agent to affect living organisms adversely. Toxicity is the 

degree to which a substance or mixture of substances can harm humans or animals. 

Toxicology - The study of the nature, effects, and detection of poisons in living organisms. Also, 

substances that are otherwise harmless but prove toxic under particular conditions. The basic 

assumption of toxicology is that there is a relationship among the dose (amount), the 

concentration at the affected site, and the resulting effects. 

Treatment Area - An infested area where weeds have been treated or retreated by an acceptable 

method for the specific objective of controlling their spread or reducing their density. 

U.S. Fish and Wildlife Service (US FWS) - The federal agency that is the listing authority for 

species other than marine mammals and anadromous fish under the ESA. 

U.S. Forest Service (USDA FS or USFS) - The federal agency responsible for management of 

the Nation’s National Forest system lands. 

Variety Class - A particular level of visual variety or diversity of landscape character. 

Viability - Ability of a wildlife or plant population to maintain sufficient size to persist over time 

in spite of normal fluctuations in numbers, usually expressed as a probability of maintaining a 

specific population for a specified period. 

Viable Population - A wildlife or plant population that contains an adequate number of 

reproductive individuals appropriately distributed on the planning area to ensure the long-term 

existence of the species. 

Viewshed - Total visible area from a single observer position, or the total visible area from 

multiple observer position. Viewsheds are accumulated seen-areas from highways, trails, 

campgrounds, towns, cities, or other viewer locations. Examples are corridor, feature, or basin 

viewsheds. 

Visual Quality Objective - A desired level of excellence based on physical and sociological 

characteristics of an area. Refers to degree of acceptable alteration of the characteristic 

landscape. 

Well-distributed - Distribution sufficient to permit normal biological function and species 

interactions, considering life history characteristics of the species and the habitats for which it is 

specifically adapted. 

Wetland - An area that is regularly saturated by surface or ground water and subsequently is 

characterized by a prevalence of vegetation that is adapted for life in saturated soil conditions. 

Examples include swamps, bogs, fens, marshes, and estuaries. 

Wild and Scenic River System - The Wild and Scenic Rivers Act of 1968 established a system 

of selected rivers in the United States, which possess outstandingly remarkable values, to be 

preserved in free-flowing condition. Within the national system of rivers, three classifications 

define the general character of designated rivers: Wild, Scenic, and Recreational. 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 4 

443 

Classifications reflect levels of development and natural conditions along a stretch of river. 

Classifications are used to help develop management goals for the river. 

Wilderness - Areas designated by Congressional action under the 1964 Wilderness Act. 

Wilderness is defined as undeveloped federal land retaining its primeval character and influence 

without permanent improvements or human habitation. Wilderness areas are protected and 

managed to preserve their natural conditions, which generally appear to have been affected 

primarily by the forces of nature with the imprint of human activity substantially unnoticeable; 

have outstanding opportunities for solitude or for a primitive and confined type of recreation; 

include at least 5,000 acres, or are of sufficient size to make practical their preservation, 

enjoyment, and use in an unimpaired condition; and may contain features of scientific, 

educational, scenic, or historical value as well as ecological and geologic interest. 

Wild Rivers - A classification within the national Wild and Scenic River System. Wild rivers 

are those rivers, or sections of rivers that are free of impoundments and generally inaccessible 

except by trail, with watersheds or shorelines essentially primitive and waters unpolluted. 
Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 4 

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4.8 Index 

A

Alternatives 

Alternative A, 21, 24, 80, 81, 85, 104, 130, 133, 

135, 137, 142, 143, 270, 271, 280, 322, 350, 

367, 368, 377, 381, 396, 400, 401, 405, 406, 

408, 409, 410, 413, 415, 416 

Alternative B, 16, 21, 25, 78, 79, 80, 81, 85, 104, 

108, 133, 134, 135, 137, 138, 139, 140, 143, 

144, 146, 261, 269, 271, 272, 273, 274, 281, 

292, 323, 348, 350, 369, 377, 382, 397, 398, 

400, 410, 411, 412, 413, 414, 415, 416 

Alternative C, 77, 85, 104, 134, 137, 139, 144, 261, 

273, 274, 292, 348, 350, 376, 381, 382, 398, 

400, 413, 414, 416, 420 

Alternative D, 22, 78, 85, 104, 108, 134, 139, 261, 

274, 292, 348, 350, 376, 381, 382, 398, 414, 

415, 416, 420 

No Action, 21, 24, 79, 81, 85, 104, 130, 131, 132, 

133, 136, 138, 141, 261, 269, 270, 271, 280, 

317, 322, 367, 368, 377, 381, 396, 397, 398, 

400, 401, 405, 406, 407, 410, 411, 420 

preferred alternative, 424 

proposed action, i, xiii, 8, 13, 14, 21, 25, 36, 70, 79, 

81, 85, 89, 104, 131, 132, 133, 135, 143, 248, 

271, 281, 293, 297, 323, 325, 326, 351, 352, 

354, 355, 369, 377, 381, 382, 397, 398, 400, 

420, 424 

amphibians, 58, 59, 80, 156, 451, 454, 463 

aquatic species, 11, 17, 80, 83, 90, 129, 256, 297, 317, 

320, 324, 340, 352, 354 

C

Clean Water Act, xii, 9, 19, 253, 254, 344, 437 

consultation, 63, 325, 424, 474 

critical habitat, 19, 298, 299, 301, 302, 303, 304, 307, 

340, 342, 343, 345, 351, 352, 353, 361, 432, 478 

cultural resources, 13, 67, 374 

E

economics, xi, 432 

Endangered Species Act, xii, 9, 19, 36, 117, 123, 

299, 307, 325, 331, 335, 337, 338, 339, 342, 354, 

411, 432, 433, 437, 441, 442, 474 

Environmental Justice, 13, 408, 412, 414, 415, 432, 

462 

erosion, 39, 68, 115, 248, 250, 252, 255, 256, 263, 

264, 265, 266, 270, 272, 273, 274, 281, 285, 288, 

322, 323, 324, 335, 339, 351 

Essential Fish Habitat, xii, 354, 355, 356, 474 

H

habitat

critical habitat, 19, 298, 299, 301, 302, 303, 304, 

307, 340, 342, 343, 345, 351, 352, 353, 361, 

432, 478 

Essential Fish Habitat, xii, 354, 355, 356, 474 

wildlife, 472, 479 

heritage resources, 13, 67, 374 

I

issues, 14, 15, 18, 19, 21, 22, 78, 100, 247, 250, 275, 

323, 395, 414, 419, 421, 424, 445, 481 

M

Management Indicator Species, xii, 298, 440 

N

National Forest Management Act, xii, 9, 19, 437 

National Historic Preservation Act, 13, 416 

P

Proposed action, 81, 124, 248, 260, 296, 318, 323, 

324, 336, 337, 338, 339, 341, 342, 348, 350, 353, 

354, 356, 400, 424 

public involvement, 14 

Purpose and need, 95, 135 

R

range allotments, 391, 392 

riparian, 11, 13, 14, 16, 17, 18, 36, 38, 51, 52, 58, 59, 

60, 77, 80, 82, 83, 86, 87, 100, 116, 134, 139, 253, 

256, 261, 275, 281, 293, 299, 301, 302, 304, 316, 

323, 324, 326, 331, 338, 339, 346, 349, 351, 352, 

356, 357, 361, 362, 375, 376, 381, 382, 398, 399, 

413, 419, 420, 440, 472 

Riparian Habitat Conservation Areas (RHCAs), 

xiii, 52, 57, 72, 81, 137, 138, 139, 248, 253, 255, 

256, 258, 260, 261, 273, 274, 278, 280, 281, 282, 

283, 285, 286, 289, 290, 292, 294, 296, 322, 328, 

329, 345, 346, 348, 351, 406 

road, 140, 265, 297, 361, 362 

S

sediment, 17, 253, 254, 255, 256, 261, 274, 277, 280, 

285, 288, 292, 310, 316, 317, 323, 324, 339, 340, 

341, 342, 343, 344, 346, 348, 349, 350, 351, 352, 

353, 355, 439 

sera, xiii, 53, 55, 57, 58, 59, 60, 69, 92, 127, 133, 

137, 247, 248, 266, 272, 276, 282, 283, 317, 318, 

320, 321, 322, 325, 328, 329, 330, 337, 340, 349, 

353, 397, 467, 468, 469 

soil

compaction, 253, 324 

erosion, 39, 68, 115, 248, 250, 252, 255, 256, 263, 

264, 265, 266, 270, 272, 273, 274, 281, 285, 

288, 322, 323, 324, 335, 339, 351 

nutrients, 17, 38, 109, 251, 252, 254, 323, 343, 

345, 433, 444 

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Wallowa-Whitman National Forest Invasive Plants Treatment Draft Environmental Impact Statement Chapter 4 

SOLI, 60, 62, 63, 117, 440 

stream flow, 253, 275, 279, 287, 308, 310, 336, 340 

W

water quality, 1, 11, 13, 14, 15, 17, 38, 58, 247, 253, 

254, 255, 275, 277, 278, 280, 286, 299, 301, 302, 

303, 304, 315, 336, 341, 343, 344, 351, 356, 361, 

375, 413, 419, 420 

watershed, 257, 258, 274, 281, 285, 291, 292, 293, 

294, 332, 347, 352 

wetlands, 53, 55, 57, 59, 71, 77, 261, 278, 279, 289, 

290, 325, 343, 345, 351, 352, 354, 440, 442, 480 

Wild and Scenic Rivers, 80, 81, 89, 115, 356, 359, 

360, 365, 374, 377, 381, 403, 404, 407, 411, 431, 

442 

wildlife, 11, 16 

amphibians, 65, 83, 428, 447 

aquatic species, 11, 17, 80, 83, 90, 129, 256, 297, 

317, 320, 324, 340, 352, 354 

federally listed, 55, 60, 61, 117, 118, 124, 248, 298, 

318, 326, 327, 342, 350, 351, 354, 433 

Management Indicator Species, xii, 298, 440 

sensitive, 12, 117, 318, 440 

483