Site-Specific Environmental Assessment 

Rangeland Grasshopper and Mormon Cricket 

Suppression Program 

OREGON 

Klamath County

EA Number: OR-08-02 

Prepared by: 

Animal and Plant Health Inspection Service 

Plant Protection and Quarantine 

6135 NE 80th Avenue, Suite A-5 

Portland, Oregon 97218-4033 

February 29, 2008
Table of Contents

I. Need for Proposed Action ................................................................... 1 

 A. Purpose and Need Statement......................................................... 1 

 B. Background Discussion................................................................... 2 

 C. About This Process ......................................................................... 6 

II. Alternatives........................................................................................... 7 

 A. No Action Alternative....................................................................... 8 

 B. Insecticide Applications at Conventional Rates and Complete 

 Area Coverage Alternative .............................................................. 8 

C. Reduced Agent Area Treatments (RAATs) Alternative ................... 9 

D. Treatment Strategies ..........................................................10 

E. Oregon 2006 Survey Summary..............................................13 

III. Affected Environment ......................................................................... 15 

 A. Description of Affected Environment ............................................. 15 

 B. Site-Specific Considerations ......................................................... 17 

 1. Human Health .......................................................................... 17 

 2. Nontarget Species.................................................................... 19 

 3. Socioeconomic Issues.............................................................. 22 

 4. Cultural Resources and Events................................................ 24 

 

IV. Environmental Consequences............................................................ 24 

 A. Environmental Consequences of the Alternatives......................... 24 

 1. No Action Alternative................................................................ 24 

 2. Insecticide Applications at Conventional Rates and Complete 

 Area Coverage Alternative....................................................... 28 

 3. Reduced Agent Area Treatments (RAATs) Alternative ............ 34 

 B. Other Environmental Considerations ............................................. 40 

1. Cumulative Impacts .......................................................41 

2. Synergistic Effects .........................................................42 

3. Inert Ingredients and Metabolites ......................................42 

4. Executive Order No. 12898, Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations ..................................................................43 

5. Executive Order No. 13045, Protection of Children from 

Environmental Health Risks and Safety Risks ........................43 

6. Executive Order 13186, Responsibilities of Federal 

Agencies to Protect Migratory Birds......................................... 44 

7. Bald and Golden Eagle Protection Act ................................44 

8. Endangered Species Act ......................................................... 44 

9. Additional Protective Measures Which Are Not Included in FY 

2007 Treatment Guidelines (Appendix 1)........................... 47 

10. Monitoring................................................................................ 48 

i 
OR-08-02 

V. Literature Cited................................................................................... 48 

VI. Listing of Agencies and Persons Consulted ....................................... 52 

Appendices 

Appendix 1: APHIS Rangeland Grasshopper and Mormon Cricket Suppression 

Program FY-2008 Treatment Guidelines, USDA APHIS PPQ Western Region 

Appendix 2: Maps of Affected Environment 

 

Appendix 3: FWS/NOAA Fisheries Correspondence 

 

ii 
OR-08-02 

Site-Specific Environmental Assessment 

Rangeland Grasshopper and Mormon Cricket 

Suppression Program 

OREGON (OR-08-02) 

I. Need for Proposed Action 

A. Purpose and Need Statement 

Grasshoppers and/or Mormon crickets (hereafter referred to collectively as 

grasshoppers) have the potential for sudden and explosive population 

increases. Outbreaks are usually preceded by several years of gradual 

increases in grasshopper numbers, followed by a year in which conditions 

favor grasshopper development. Outbreaks are difficult to predict because 

they depend greatly on climatic variables that cannot be predicted. The 

intensity of grasshopper outbreaks depends largely on the rate of population 

increase the previous year and temperature and moisture conditions at the 

time of hatching and early nymphal development. 

To assist in predicting where potential grasshopper outbreaks may occur, 

the Animal and Plant Health Inspection Service (APHIS) and Oregon 

Department of Agriculture (ODA) conduct annual surveys of grasshopper 

populations in Oregon. Adult grasshopper surveys conducted by the APHIS 

and ODA during the summer of 2007 reveal areas where numbers of 

grasshoppers may be at economically damaging levels in 2008. The 2007 

Oregon Grasshopper Survey Summary included as Section II. D, and the 

Summary Map can be found in Appendix 2, Map 2. 

If outbreaks develop, contacts and coordination will be made with involved 

landowners, land managers, and federal, state, and local government 

officials. A request for APHIS assistance is voluntary. In response to 

requests from land owners/managers, APHIS would determine if an 

outbreak has reached an economically or environmentally critical level. If so, 

an appropriate treatment strategy would be developed, taking into account 

additional site specific information. 

Populations of grasshoppers that trigger the need for a suppression 

program are considered on a case-by-case basis. There is no specific 

infestation level that triggers APHIS’ participation. Participation here is 

based on the potential damage grasshoppers cause, and the benefits of 

treatments. When grasshopper numbers become extreme, their feeding on 

1
OR-08-02 

available vegetation can lead to denuded areas, thus eliminating seed 

production and increasing soil erosion. Forage and habitat for some wildlife 

species and livestock will also be reduced. Rare plants may be adversely 

impacted by severe grasshopper feeding. Benefits of controlling 

grasshopper outbreaks include increasing the forage available for wildlife 

and livestock, reduced soil erosion, protecting wildlife habitat, and 

preventing grasshoppers from becoming migratory and causing further 

damage to adjacent crops or rangeland. Some populations that may not 

cause substantial damage to native rangeland may require treatment due to 

the secondary suppression benefits resulting from the high value of adjacent 

crops, and the protection of rangeland revegetation programs. 

The goal of the proposed suppression program analyzed in this EA is to 

reduce grasshopper populations to an acceptable level in order to protect 

rangeland ecosystems and/or cropland adjacent to rangeland. 

This environmental assessment (EA) analyzes potential environmental 

consequences of the proposed action and its alternatives. This EA applies 

to proposed suppression programs that could take place from May 1 to July 

31 in Klamath County Oregon (see Appendix 2, map 1). A decision on which 

treatment strategy to use, if any, will be made by APHIS based on the 

analysis presented in this EA, the results of public involvement, and 

consultation with other state and federal agencies. Three alternates are 

analyzed here, no action, and two chemical control alternatives. A selection 

of one of the three alternatives will be made by APHIS for suppression 

programs in Eastern Oregon. 

This EA is prepared in accordance with the requirements under the National 

Environmental Policy Act of 1969 (NEPA) (42 United States Code (U.S.C.) 

§ 4321 et. seq.) and the NEPA procedural requirements promulgated by the 

Council on Environmental Quality, United States Department of Agriculture 

(USDA), and APHIS.

B. Background Discussion 

In rangeland ecosystems in the Western United States, grasshoppers are a 

natural component of the biota. Different species of grasshoppers forage on 

different preferred grasses, forbs and shrubs. They perform beneficial 

functions by recycling nutrients and serving as food for other animal 

species. They are native to Western rangelands and they have evolved to 

occupy various niches in the ecosystem. Even though these ecosystems 

have been impacted by various forms of human activity and invasion by 

foreign plant and animal species, grasshoppers are usually beneficial with 

respect to human values. 

2
OR-08-02 

Additionally, integrated pest management (IPM) systems can help hold 

grasshopper populations below economically damaging levels. 

Management tools such as mechanical control, biological control, cultural 

control, and/or selective use of chemicals can be implemented by farmers, 

ranchers and land managers to delay or avert economic grasshopper 

outbreaks. 

However, grasshopper populations can build up to levels of economic 

infestation despite even the best land management and other efforts to 

prevent outbreaks. At such a time, a rapid and effective response may be 

requested and needed to reduce the destruction of rangeland vegetation. In 

some cases, a response is also needed to prevent grasshopper migration to 

cropland adjacent to rangeland. 

APHIS conducts surveys for grasshopper populations on rangeland in the 

Western United States, provides technical assistance on grasshopper 

management to land owners/managers, and cooperatively suppresses 

grasshoppers when direct intervention is requested by a Federal land 

management agency or a State agriculture department (on behalf of a State 

agency, a local government, or a private group or individual) and deemed 

necessary. The need for rapid and effective suppression of grasshoppers 

when an outbreak occurs limits the options available to APHIS. The 

application of an insecticide within all or part of the outbreak area is the 

response available to APHIS to rapidly suppress or reduce (but not 

eradicate) grasshopper populations and effectively protect rangeland. 

In June 2002, APHIS completed an Environmental Impact Statement 

document “Rangeland Grasshopper and Mormon Cricket Suppression 

Program, Final Environmental Impact Statement, June 21, 2002” (2002 

FEIS) concerning suppression of grasshopper populations in 17 Western 

States. The 2002 FEIS describes the actions available to APHIS to reduce 

the destruction caused by grasshopper populations in the states of Arizona, 

California, Colorado, Idaho, Kansas, Montana, Nebraska, Nevada, New 

Mexico, North Dakota, Oklahoma, Oregon, South Dakota, Texas, Utah, 

Washington and Wyoming. 

APHIS’ authority for cooperation in this suppression program is based on 

Section 417 of the Plant Protection Act of 2000 (7 U.S.C. § 7717). In 

general this statute directs APHIS to control actual or potential economic 

grasshopper and Mormon cricket outbreaks on Federal, State, or private 

lands. APHIS’ participation is subject to available funds, and at the 

request of a State or Federal land manager. For the discussions in this 

EA, it is understood that no suppression programs will be undertaken by 

APHIS without both of these conditions being met. 

3
OR-08-02 

The state of Oregon has the following laws that are relevant to grasshopper 

control:

 ORS 570.305. This statute gives broad enabling authority to eradicate 

dangerous insect pests and plant diseases. It states that "the director 

[State Department of Agriculture], and the chief of the division of plant 

industry, are authorized and directed to use such methods as may be 

necessary to prevent the introduction into the state of dangerous insect 

pests and plant diseases, and to apply methods necessary to prevent 

the spread, and to establish control and accomplish the eradication of 

such pests and diseases, which may seriously endanger agricultural and 

horticultural interests of the state, which may be established or may be 

introduced, whenever in their opinion such control or eradication is 

possible and practicable." 

 ORS 634.655. This law requires that state agencies with pest control 

responsibilities follow the principles of integrated pest management 

(IPM). IPM is defined as "a coordinated decision-making and action 

process that uses the most appropriate pest control methods and 

strategy in an environmentally and economically sound manner to meet 

agency pest management objectives." 

 ORS 634, State Pesticide Control Act. This law regulates the 

formulation, distribution, storage, transportation, application and use of 

pesticides in Oregon. 

In May 2002, APHIS and the Forest Service (FS) signed a Memorandum of 

Understanding (MOU) detailing cooperative efforts between the two 

agencies on suppression of grasshoppers and Mormon crickets on national 

forest system lands (Document #02-IA-11132020-106, May 30, 2002). This 

MOU clarifies that APHIS will prepare and issue to the public site-specific 

environmental documents that evaluate potential impacts associated with 

proposed measures to suppress damaging grasshopper populations. The 

MOU also states that these documents will be prepared under the APHIS 

NEPA implementing procedures with cooperation and input from the FS. 

The MOU further states that the responsible FS official will request in writing 

the inclusion of appropriate lands in the APHIS suppression project when 

treatment on national forest land is necessary. FS will provide information 

on location of T&E species, sensitive sites, and other resource issues. The 

FS must also approve a Pesticide Use Proposal (Form FS-2100-2) for 

APHIS to treat infestations. According to the provisions of the MOU, APHIS 

can begin treatments after APHIS issues an appropriate decision document 

and FS approves the Pesticide Use Proposal. This MOU expired May 30, 

2007 and is in the process of being renewed. Until a new MOU is signed 

4
OR-08-02 

APHIS will work with the local Forest Supervisor to meet NEPA 

requirements when suppressing grasshoppers on NF lands. 

In February, 2003, APHIS and Bureau of Land Management (BLM) signed a 

MOU detailing cooperative efforts between the two agencies on suppression 

of grasshoppers and Mormon crickets on BLM managed lands, APHIS PPQ 

MOU # 03-8100-0870-MU. This MOU clarifies that APHIS will prepare and 

issue to the public site-specific environmental documents that evaluate 

potential impacts associated with proposed measures to suppress 

damaging grasshopper and Mormon cricket populations. The MOU also 

states that these documents will be prepared under the APHIS NEPA 

implementing procedures with cooperation and input from the BLM. 

The MOU further states that the responsible BLM official will request, in 

writing, the inclusion of appropriate lands in the APHIS suppression project 

when treatment on BLM managed land is necessary. BLM will provide 

information on location of T&E species, sensitive sites, and other resource 

issues. The BLM must also prepare a Pesticide Use Proposal for APHIS to 

treat infestations. According to the provisions of the MOU, APHIS can begin 

treatments after APHIS issues an appropriate decision document and BLM 

approves the Pesticide Use Proposal. This MOU expired February 27, 2008 

and is in the process of being renewed. Until a new MOU is signed APHIS 

will work with the local BLM District to meet NEPA requirements when 

suppressing grasshoppers on BLM lands. 

In June, 2004, APHIS and Bureau of Indian Affairs (BIA) signed a MOU 

detailing cooperative efforts between the two agencies on suppression of 

grasshoppers and Mormon crickets on BIA managed lands, APHIS PPQ 

MOU # 04-8100-0941-MU. This MOU clarifies that APHIS will prepare and 

issue to the public site-specific environmental documents that evaluate 

potential impacts associated with proposed measures to suppress 

damaging grasshopper and Mormon cricket populations. The MOU also 

states that these documents will be prepared under the APHIS NEPA 

implementing procedures with cooperation and input from the BIA. 

The MOU further states that the responsible BIA and tribal officials will 

request, in writing, the inclusion of appropriate lands in the APHIS 

suppression project when treatment on BIA managed land is necessary. 

Requests should include information on the location and dates of all tribal 

ceremonies and/or cultural events that will be in or near the proposed 

treatment area(s). In addition, request should include information on the 

location of any T&E species, the location and nature of any sensitive or “not 

to be treated” sites. The BIA must also prepare a Pesticide Use Proposal for 

APHIS to treat infestations. According to the provisions of the MOU, APHIS 

can begin treatments after APHIS issues an appropriate decision document 

and BIA approves the Pesticide Use Proposal. 

5
OR-08-02 

A Pesticide Use Proposal is the tracking mechanism by which pesticide use 

on federally managed land is reported to the Environmental Protection 

Agency (EPA). EPA’s role is to track use under the Federal Insecticide 

Fungicide and Rodenticide Act as amended (Public Law (P.L.) 92-516). 

Responsibility for administering the act is vested in the EPA. 

C. About This Process 

The EA process for grasshopper management is complicated by the fact 

that there is very little time between requests for treatment and the need for 

APHIS to take action with respect to those requests. Late summer and fall 

surveys help to determine general areas, among the millions of acres that 

potentially could be affected, where grasshopper infestations may occur in 

the spring. There is considerable uncertainty, however, in the forecasts, so 

that framing specific proposals for analysis under NEPA would waste limited 

resources. At the same time, the program strives to alert the public in a 

timely manner to its more concrete treatment plans and avoid or minimize 

harm to the environment in implementing those plans. Requests for 

assistance can come at any time. However, treatments will occur when 

grasshoppers can be effectively controlled, from shortly after they hatch until 

the majority has become adults. The exact timing of these events varies 

based on climate and elevation. In Oregon treatments may occur from midMay through July. 

Public input is an important part of our decision making process. On 

December 10, 2003 APHIS mailed a scoping document to individuals and 

organizations that either indicated an interest in grasshopper programs in 

the past, or APHIS felt may provide useful input in the preparation of this 

EA. This scoping letter is also available on the ODA website, 

http://www.oregon.gov/ODA/PLANT/IPPM/index.shtml. Comments are still 

being accepted and can be submitted at any time. Comments received will 

assist APHIS in preparation of this and future EA’s.

The 2002 FEIS provides a solid analytical and regulatory foundation; 

however, it may not be enough to satisfy NEPA completely for actual 

treatment proposals, and the “conventional” EA process will seldom, if ever, 

meet the program’s timeframe of need. Thus, APHIS PPQ has initiated a 

two-stage NEPA process designed to accommodate program needs and 

meet environmental safeguarding requirements. 

The first stage involves issuing an initial finding of no significant impact 

(FONSI) based on the findings of an EA. The EA and signed FONSI will be 

made available to the public with a 30 day comment period. The second 

6
OR-08-02 

stage occurs when an actual treatment program is requested by a land 

owner/manager, and involves preparing a supplement to the EA. 

For the first stage, this EA will analyze aspects of environmental quality that 

could be affected by grasshopper treatment in Klamath County, Oregon. 

The EA and FONSI will be made available to the public for a 30-day 

comment period. If comments are received during the comment period, they 

will be addressed in stage 2 of the process. 

Stage 2 will only be initiated when the program receives a treatment request 

from a landowner/manager, and it is determined that treatment is necessary 

and possible. The proposed treatment site, within the area covered under 

this EA, will be examined to determine if environmental issues exist that 

were not covered in this EA. This stage is intended mainly to insure that 

significant impacts in the specific treatment area will not occur. APHIS will 

examine all site-specific characteristics and determine a preferred 

alternative which meets program needs (see Section D, Treatment 

Strategies). Many factors are considered including type and density of 

vegetation, grasshopper species involved, terrain, life stage of the 

grasshoppers, protective measures for sensitive sites/species, costs, and 

logistics. A supplemental determination will be prepared to document this 

finding and would also address any comments received on this EA and the 

initial FONSI. Supplemental determinations prepared for specific treatment 

sites will be provided to all parties who commented on the EA and FONSI. 

There will not be a waiting period after the supplement is issued. If a 

suppression program is selected, it will be carried out within a short period 

of time, although comments may still be submitted. 

EA’s will be updated as needed. Generally for years when funding is 

available for suppression programs, they will be updated annually to reflect 

current survey information and maps. These documents and other 

grasshopper program related information can be found at the ODA, Plant 

Division website; http://www.oregon.gov/ODA/PLANT/IPPM/index.shtml. 

II. Alternatives 

The alternatives presented in the 2002 FEIS and considered for the 

proposed action in this EA are: (A) no action; (B) insecticide applications at 

conventional rates and complete area coverage, and (C) reduced agent 

area treatments (RAATS). Each of these alternatives, their control 

methods, and their potential impacts were described and analyzed in detail 

in the 2002 FEIS. Copies of the complete 2002 FEIS document are 

available for review at Animal and Plant Health Inspection Service, Plant 

Protection and Quarantine, 6135 NE 80th Avenue, Suite A-5, Portland, 

7
OR-08-02 

Oregon 97218-4033, (503) 326-2814. It is also available at the APHIS web 

site, 

http://www.aphis.usda.gov/plant_health/plant_pest_info/grasshopper/index.s

html. 

The 2002 FEIS is intended to explore and explain potential environmental 

effects associated with grasshopper suppression programs that could occur 

in 17 Western States (Arizona, California, Colorado, Idaho, Kansas, 

Montana, Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, 

Oregon, South Dakota, Texas, Utah, Washington, and Wyoming). The 

2002 FEIS outlines the importance of grasshoppers as a natural part of the 

rangeland ecosystem. However, grasshopper outbreaks can compete with 

livestock for rangeland forage and cause devastating damage to crops and 

rangeland ecosystems. Rather than opting for a specific proposed action 

from the alternatives presented, the 2002 FEIS analyzes in detail the 

environmental impacts associated with each programmatic action 

alternative related to grasshopper suppression based on new information 

and technologies. 

All insecticides used by APHIS for grasshopper suppression are used in 

accordance with all applicable product label instructions and restrictions. 

Representative product specimen labels can be accessed at the Crop Data 

Management Systems, Inc. web site at www.cdms.net/manuf/manuf.asp. 

Labels for actual products used in suppression programs will vary, 

depending on supply issues. 

All insecticide treatments conducted by APHIS would be implemented in 

accordance with the “APHIS Rangeland Grasshopper and Mormon Cricket 

Suppression Program FY-2008 Treatment Guidelines” (Treatment 

Guidelines), included as Appendix 1 to this EA. These Treatment 

Guidelines were developed by APHIS to provide established safety 

guidelines which will be employed in the 17 Western states where 

grasshopper suppression programs may occur.

A. No Action Alternative 

Under Alternative A, the no action alternative, APHIS would not fund or 

participate in any program to suppress grasshopper infestations. Under this 

alternative, APHIS may opt to provide limited technical assistance, but any 

suppression program would be implemented by a Federal land 

management agency, a State agriculture department, a local government, 

or a private group or individual. 

B. Insecticide Applications at Conventional Rates and 

Complete Area Coverage Alternative 

8
OR-08-02 

Alternative B, insecticide applications at conventional rates and complete 

area coverage, is generally the approach that APHIS has used for many 

years. Under this alternative, carbaryl, diflubenzuron (Dimilin®), or 

malathion will be employed. Carbaryl and malathion are insecticides that 

have traditionally been used by APHIS. The insect growth regulator, 

diflubenzuron, is also included in this alternative. Applications would cover 

all treatable sites within the infested area (total or blanket coverage) per 

label directions. The application rates under this alternative are as follows: 

• 16.0 fluid ounces (0.50 pound active ingredient (lb a.i.)) of carbaryl spray 

per acre, 

• 10.0 pounds (0.50 lb a.i.) of 5% carbaryl bait per acre, 

• 1.0 fluid ounce (0.016 lb a.i.) of diflubenzuron per acre, or 

• 8.0 fluid ounces (0.62 lb a.i.) of malathion per acre. 

In accordance with EPA regulations, these insecticides may be applied at 

lower rates than those listed above. Additionally, coverage may be reduced 

to less than the full area coverage, resulting in lesser effects to nontarget 

organisms. 

The potential generalized environmental effects of the application of 

carbaryl, diflubenzuron, and malathion, under this alternative are discussed 

in detail in the 2002 FEIS (Environmental Consequences of Alternative 2: 

Insecticide Applications at Conventional Rates and Complete Area 

Coverage, pp. 38-48). A description of anticipated site-specific impacts 

from this alternative may be found in Part IV of this document. 

C. Reduced Agent Area Treatments (RAATs) Alternative 

RAATs, is a recently developed grasshopper suppression method in which 

the rate of insecticide is reduced from conventional levels, and treated 

swaths are alternated with swaths that are not treated. The RAATs strategy 

relies on the effects of an insecticide to suppress grasshoppers within 

treated swaths while conserving grasshopper predators and parasites in 

swaths not treated. Carbaryl, diflubenzuron, or malathion would be 

considered under this alternative at the following application rates: 

• 8.0 fluid ounces (0.25 lb a.i.) of carbaryl spray per acre, 

• 10.0 pounds (0.20 lb a.i.) of 2 percent carbaryl bait per acre, 

• 0.75 fluid ounce (0.012 lb a.i.) of diflubenzuron per acre, or 

• 4.0 fluid ounces (0.31 lb a.i.) of malathion per acre. 

The amount of area not treated (the untreated swath) under the RAATs 

approach is not standardized. In the past, the area infested with 

grasshoppers that remains untreated has ranged from 20 to 67 percent. 

The 2002 FEIS analyzed the reduced pesticide application rates associated 

9
OR-08-02 

with the RAATs approach but assumed pesticide coverage on 100 percent 

of the area as a worst-case assumption. This assumption was made 

because there is no way to predict how much area would actually be left 

untreated as a result of the specific action requiring this EA. Rather than 

suppress grasshopper populations to the greatest extent possible, the goal 

of this alternative is to suppress grasshopper populations to a desired level. 

The amount of area not receiving pesticide may vary based on factors such 

as choice of chemical, site characteristics, grasshopper life stage, 

grasshopper density, and value of the resource being protected. 

The potential environmental effects of the application of carbaryl, 

diflubenzuron, and malathion under this alternative are discussed in detail in 

the 2002 FEIS (Environmental Consequences of Alternative 3: Reduced 

Agent Area Treatments (RAATs), pp. 49–57). A description of anticipated 

site-specific impacts from this proposed treatment may be found in Part IV 

of this document. 

D. Treatment Strategies 

The insecticides available to APHIS are diflubenzuron, carbaryl (spray and 

bait), and malathion. The decision on which insecticide to use, if any, 

depends on a variety of factors specific to a given site and situation. Each 

of these insecticides has characteristics that dictate its desirability for a 

treatment. 

Diflubenzuron is a chitin inhibitor, and only kills grasshoppers or other 

insects when they are in their immature stages. It will not kill adult 

grasshoppers. It cannot be used late in the season because the 

grasshoppers are no longer molting, and thus not susceptible. In Oregon, 

the efficacy of diflubenzuron is notably decreased by the first week of July 

because of grasshopper maturity. This material would not normally be used 

after the third week of June, for most species of grasshoppers in Oregon. 

Insects usually die seven to ten days after treatment. Diflubenzuron is 

reported to have a residual activity against grasshoppers lasting up to 28 

days. Diflubenzuron is less harmful to other insects, including pollinators, 

than the other insecticides and is essentially harmless to vertebrates. 

Diflubenzuron must be applied as a spray mixed with water and crop or 

vegetable oil. It is normally applied by air for grasshoppers on rangeland, 

but can also be applied by ground. It is the least costly option per acre 

treated. The formulation of diflubenzuron approved for use by APHIS is 

Dimilin 2L ®. 

Carbaryl bait acts faster than diflubenzuron. It kills adult and immature 

grasshoppers and other insects that feed on the bait. It has a broader 

spectrum of insecticidal activity than diflubenzuron, but the bait must be 

10
OR-08-02 

ingested to be lethal. Therefore it is preferred over carbaryl or malathion 

sprays, in areas where foraging bees are a concern. It is the most costly 

option. It can be used effectively any time during the grasshopper season. 

It can be applied by air or ground. Carbaryl bait is applied in greater mass 

than any of the other treatments (up to 10 lbs. dry material per acre) and 

creates a greater logistical problem because of the amount of material 

which must be stored, transported and applied. Carbaryl bait can be applied 

by air in some situations when and where liquid insecticides cannot. 

Although no aerial applications of any insecticide can be conducted when 

wind speeds exceed 10 mph, carbaryl bait can be applied when air 

temperatures are too high to permit effective applications of sprays. 

Additionally, when terrain is too rough to maintain flying at the low altitude 

consistent with effective spray application, bait can be applied by flying at a 

safe altitude over the ground. Thus, the window of opportunity to apply bait 

is greater than for sprays. The carbaryl bait formulations approved for use 

by APHIS include products which impregnate carbaryl into wheat bran, 

rolled whole wheat, and pellets manufactured from grape and apple pumice. 

Carbaryl spray is a broad spectrum contact insecticide that is more effective 

in cool weather than hot weather. It kills adult and immature grasshoppers 

and other insects. It has a knock-down effect intermediate between 

diflubenzuron and malathion sprays, and it has a residual activity of up to 14 

days. It is normally applied by air for grasshoppers on rangeland, but can 

also be applied by ground. It is intermediate in cost. It carries higher risk for 

nontarget species than diflubenzuron or carbaryl bait. Because of the 

residual toxicity to bees, it is not likely to be a treatment of choice in areas 

where foraging bees are a concern. The carbaryl formulation approved for 

use by APHIS is Sevin XLR Plus which uses water as the carrier. 

Malathion spray is a broad spectrum contact insecticide that is more 

effective in hot weather than cool weather. It kills adult and immature 

grasshoppers and other insects. It has an immediate knock-down effect 

and has essentially no residual activity. It is normally applied by air for 

grasshoppers on rangeland, but can also be applied by ground. It is 

intermediate in cost. It carries higher risk for nontarget species than 

diflubenzuron or carbaryl bait. The formulations of malathion approved for 

use by APHIS are Ultra Low Volume (ULV) Concentrates. They are applied 

without an additional carrier. 

Detailed information on the insecticides used by APHIS for grasshopper 

control is found in the 2002 FEIS pp 30-36. Information on surfactants or 

additives to sprays is found in the 2002 FEIS pp 36-37. 

Requests for grasshopper suppression programs may come from Federal 

land managers or Oregon Department of Agriculture, at any time. 

Complaints from public land mangers, private landowners and other 

11
OR-08-02 

persons who are threatened by grasshopper outbreaks normally come when 

the outbreak is in progress. When a complaint is received, APHIS and ODA 

then determine the need for suppression measures based on several 

factors. 

The first level of assessment is the overall grasshopper population density. 

This is determined through field survey and is expressed in grasshoppers 

per square yard. In addition to the density of grasshoppers, an assessment 

of the species composition and life stage will be made. Species without 

strong migratory habits are less of a concern to nearby croplands than those 

with strong migratory characteristics. Examples of grasshoppers with strong 

migratory habits include Mormon crickets (Anabrus spp.), Melanoplus 

sanguinipes, and Camnula pellucida. Examples of grasshoppers which are 

not highly migratory include the short-winged form of Oedaleonotus enigma, 

and Hesperotettix viridis. 

Grasshopper populations which are not likely to threaten crops or cause 

significant damage to rangeland would not be treated. 

Next, APHIS will determine, through consultation with FWS and land 

managers what protective measures, if any, will be necessary to protect 

sensitive species and/or sites. These could include T&E, candidate, and 

species of concern, critical habitats, organic crops, special sites, or other 

areas needing protection from program chemicals. The implementation of 

buffers may have an adverse impact on the efficacy of a potential program. 

A program will not be undertaken by APHIS if it is determined that protective 

measures will prevent effectively reducing grasshopper numbers to a 

desired level. 

Following a decision to conduct a treatment, the pesticide would be chosen 

according to site specific conditions. This involves many factors including 

type and density of vegetation, acceptance of bait by the grasshopper 

species involved, terrain, climatic conditions, proximity to pollinators, life 

stage of the grasshopper, importance of rapid reduction of grasshopper 

density, need for residual control, costs, and logistics. 

Because of their different modes of action, and suitability under different 

climatic conditions, the three pesticides can be sorted as follows: 

Grasshopper Life 

stage 

Weather 

conditions 

Pesticide 

Nymphs Cool and wet Diflubenzuron, 

Carbaryl 

Nymphs Hot and dry Diflubenzuron, 

Malathion 

Adults Cool and wet Carbaryl 

12
OR-08-02 

Adults Hot and dry Carbaryl, Malathion

The insecticides would be applied in swaths which have a width determined 

for each treatment device (aircraft, truck-mounted spreader, or ATVmounted spreader) and insecticide. For instance, an Ayres Turbine Thrush 

aircraft can deliver a 100 foot swath with spray, and an ATV-mounted bait 

spreader can deliver a 15 foot swath with bait. 

Insecticide Applications at Conventional Rates and Complete Area 

Coverage Alternative utilizes the approach of spacing the centerline of 

adjacent swaths one swath-width apart. RAATS utilizes variable spacing of 

the swaths. The distance between treated swaths may vary based on 

factors such as vegetation density, grasshopper population pressure and 

value of the resource being protected. Due to the short residual action of 

malathion, the untreated area will be minimal, and the untreated swath will 

not exceed 20 feet. For carbaryl and diflubenzuron, which have longer 

residual activity, the percent of the area left untreated can be greater. 

Untreated swaths can be up to 100 feet. In some situations, such as when 

grasshopper densities are extreme, late instars are present, or vegetation is 

dense it may be determined to reduce the size of the untreated swaths to 

increase effectiveness. 

E. Oregon 2007 Survey Summary 

The 2007 Oregon grasshopper survey season, conducted by ODA in 

cooperation with USDA APHIS PPQ, started on May 15 and ended on 

September 6. Adult survey data recorded levels of 8 grasshoppers per 

square yard and higher on 798,358 acres (2005: 64,751 acres, 2006: 

97,399 acres) in 13 (2005: 9, 2006: 14) counties of eastern Oregon. In 

2007, a total of 1585 (2005: 859 and 2006: 1368) sites were visited of which 

706 were nymphal and 870 adult survey sites. 

The counties with the highest infestation levels were Baker with 335,589 

acres, Union with 154,170 acres, Wallowa with 83,603 acres, Grant with 

76,667 acres, Wheeler with 55,142 acres, Malheur with 40,736 acres, 

Umatilla with 31,324 acres, Jefferson with 7,185 acres, Morrow with 4,610 

acres, and Gilliam with 5,186 acres. Areas with significant infestations of 

more than 10,000 acres were located around Haines (319,000 acres) in 

Baker County, Elgin (117,300 acres), La Grande (10,070 acres), Union 

(12,230 acres), and Medical Springs (14,570 acres) in Union County, 

Enterprise (25,840 acres), Imnaha (17,280 acres), and Elk Mountains 

(17,710 acres) in Wallowa County, Flowers Gulch (68,870 acres) in Grant 

County, Fossil South/Salmon Fork (48,710 acres) in Wheeler County, 

Moores Hollow (23,600 acres), Clevenger Butte (10,240 acres) in Malheur 

County, and Echo (11,880 acres) in Umatilla County. 

13
OR-08-02 

Like in recent years, infestations in the Klamath Marsh National Wildlife 

Refuge, Klamath County, were again relatively low. Although the traditional 

Camnula egg bed areas at Sagebrush Point and at the Lane Ranch were 

not flooded like in 2006, only a few egg beds showed economic infestations. 

At the end of May, intensive nymphal surveys were conducted also 

including adjacent private rangeland. Following a public information 

meeting, 17 acres of Camnula pellucida egg beds were treated with Dimilin 

applying 50% RAATs for ATV, protecting 34 acres. Post treatment counts 

showed an average of 94% control. Adult surveys at the end of August did 

not show any economic levels in the Klamath marsh and adjacent private 

rangeland. 

Following last year’s grasshopper treatment program on more than 20,000 

acres of private rangeland in the Fort Klamath area, Klamath County, no 

grasshopper activity was recorded this year on treated areas. However, 

economic infestation of Camnula pellucida were recorded on about 1,724 

acres of non treated areas. 

This year has seen a large buildup of grasshoppers in Northeastern 

Oregon. At the beginning of June, 2007 high numbers of grasshoppers were 

reported in the Haines area. Surveys recorded economic infestations of 

grasshoppers, predominately Camnula pellucida, stretching from Elgin in 

Union County, Enterprise in Wallowa County to Baker City in Baker County. 

Almost 600,000 acres of mostly private rangeland were infested with up to 

74 grasshoppers per square yard! (see attached map 2) 

In Haines, Baker County, ODA provided technical assistance to a private 

rancher against a grasshopper outbreak of Melanoplus bivitattus and 

Camnula pellucida on about 176 acres of rangeland in June. The landowner 

chose to apply Malathion ULV by ground. However, the fields were reinfested later in the summer by predominately Camnula pellucida from 

neighboring non-treated fields. 

The last major grasshopper outbreak in Baker County was in 1986. 

Records of historical outbreaks date back to 1954 when more than 15,000 

acres south of Halfway were heavily infested with grasshoppers. In that 

same year, over 4,000 acres were infested northeast of Enterprise in 

Wallowa County. Grasshopper outbreaks on range and cropland in 

Wallowa, Union and Baker counties were treated with aerial applications of 

Malathion in 1969, 1972, 1974, 1979, 1980, 1985 and 1986 totaling more 

than 632,000 acres (see attached map 3). 

Adult grasshopper survey in other areas of eastern Oregon showed 

economic levels in Gilliam, Grant, Jefferson, Klamath, Malheur, Morrow, 

Umatilla, and Wheeler counties. Most infestations were observed on private 

rangeland with levels ranging between 8 and 50 grasshoppers per square 

yard. The dominant species in these counties were Melanoplus 

femurrubrum, M. sanguinipes, M. packardii, Oedaleonotus enigma and 

Aulocara elliotti. 

Mormon crickets, Anabrus simplex, were recorded in areas south of 

Arlington (5,359 acres), Gilliam County, for the third year in row, and also 

14
OR-08-02 

near Jordan Valley (3,935 acres), and Jackson Summit (2,267 acres) in 

Malheur County. Landowners in Jordan Valley using Carbaryl bait 

conducted treatment against Mormon cricket. A large area of Mormon 

crickets on BLM land in nearby Owyhee County, Idaho, was successfully 

treated with Dimilin by APHIS’ Idaho Office this year. 

Table 1 (also see accompanying maps) represents an estimate of the 

acreages with economic levels of grasshopper infestations (>8 

grasshoppers per square yard) based on the 2007 adult survey results. We 

cannot accurately predict where grasshopper outbreaks will occur because 

they depend greatly on climatic conditions at the time of hatch and early 

development, variables that cannot be accurately predicted. However, the 

areas of economic grasshoppers in 2007 serve as indicators of potential 

problem areas for 2008, and should be closely monitored in early spring of 

2008. 

We cannot accurately predict where grasshopper outbreaks will occur 

because they depend greatly on climatic conditions at the time of hatch and 

early development, variables that cannot be accurately predicted. However, 

the areas of economic grasshoppers in 2006 serve as indicators of potential 

problem areas for 2007, and should be closely monitored in early spring of 

2007. See Appendix 2, Map 2 for a visual summary of these survey results. 

III. Affected Environment 

A. Description of Affected Environment 

The proposed suppression program area included in this EA encompasses 

rangeland in Klamath County Oregon (see Appendix 2, map 1). This county 

is situated in the southwest corner of Oregon east of the Cascade Range. 

The total area is 6135 square miles (3,926,400 acres) (Bradbury 2001). 

Generally, it is not possible to predict the precise locations where 

grasshopper outbreaks will occur in any given year. However, ODA has 

compiled historical annual survey data from 1953-2003. The result is a map 

showing areas where grasshoppers have historically been an economic 

problem in Oregon (see Appendix 2, Map 3). The areas of economic 

outbreaks are very consistent. This extensive historical data, allows us to 

make the assumption that it is unlikely that economic outbreaks will occur in 

areas other than those with historical infestations, as indicated in Map 3 

(Appendix 2). Although this assessment covers all the rangeland in Klamath 

County, our attention to the affected environment will concentrate on the 

areas of historical grasshopper outbreaks indicated in Map 3.

Eastern Oregon can be divided into six “level three” ecoregions based on 

similarities in geography, climate, and plant and animal communities (see 

15
OR-08-02 

Appendix 2, map 4) (Meacham et. al. 2001). The main feature that these 

ecoregions share is the dry climate created by rain shadow effect of the 

Cascade Range. 

The rangeland areas of Klamath County lie entirely within the Eastern 

Cascades Slopes and Foothills ecoregion. This zone is characterized by 

vegetation that creates a transition from the higher elevation, moister forests 

of the Cascades on the West to the lower elevation, drier areas dominated 

by shrubs and grassland on the east. Open forests of ponderosa and 

lodgepole pine predominate in this ecoregion. The vegetation is drought 

adapted and susceptible to wildfire. Volcanic cones and buttes are common 

in much of the region. 

The average January temperature in Klamath County is 29.8° F, and the 

average July temperature is 68.0° F. Annual precipitation is 14.31′′

(Bradbury 2001). 

The Klamath River Basin watershed or drainage covers most of Klamath 

County. It drains directly into the Pacific Ocean. Major sub-drainages in this 

system are the Lost River, Williamson River, Sprague River, Upper Klamath 

Lake, and Upper Klamath River. Many manmade reservoirs have been 

constructed for irrigation, flood control, and power generation. Gerber is a 

large reservoir in Klamath County. Smaller reservoirs include J.C. Boyle, 

Willow Valley, and Whiteline. Crater Lake occupies the caldera of Mount 

Mazama and is the deepest Lake in North America. It contains the largest 

volume of water of any lake in Oregon. Several other high mountain lakes 

occur in Klamath County such as Odell, Crescent, Davis, and Lake of the 

Woods. Klamath Lake has the largest surface area of any lake in Oregon. 

Other lower elevation bodies of water in the county include Agency Lake, 

Swan Lake, Aspen Lake, and the Klamath Marsh. (Meacham et. al. 2001). 

The area contains many smaller bodies of water, including springs. Springs 

are often unconnected to stream systems or other water bodies. Due to lack 

of connectivity, biota found at spring can be endemic. 

Grassland, shrubland, and woodlands are present across the general area. 

Grasshopper treatments would occur only in grass and shrublands, not in 

forests. 

The rangelands are utilized for cattle and sheep grazing. They provide 

habitat for native and introduced game and non-game animal species. They 

are in an accelerated state of ecological change due to invasion by exotic 

plant species, changes in fire patterns, and intervention by humans. 

Elevation and topography within the overall area vary considerably. 

Elevation is generally high from 8926 foot Mt. Scott to 4105 feet at Klamath 

16
OR-08-02 

Falls. Treatments would occur primarily on flatlands, foothills, and areas 

adjacent to cropland. Some treatments may occur on areas of rangeland 

where critical forage or revegetation projects are threatened. Most 

suppression treatments would occur at elevations below 6000 feet. 

Up to 100 species of grasshoppers may occur within the proposed 

suppression area. Of these, no more than ten species have been known to 

reach outbreak status and threaten crops and/or valuable range resources 

in Oregon during the past five decades. The widespread grasshopper 

outbreaks of the mid-1980s were comprised primarily of the Melanopli 

group. Localized outbreaks in the 1990s and early 2000s have included 

mainly Camnula pellucida. 

It is anticipated that potential treatments requests in 2007 for Klamath 

County would be most likely for Camnula pellucida. Oregon’s list of the ten 

most economic grasshopper species also includes Ageneotettix deorum, 

Aulocara elliotti, Hesperotettix viridis, Melanopus bivittatus, M. foedus, M. 

sanguinipes, M. femurrubrum, M. packardi, Oedaleonotus enigma, as well 

as Anabrus spp. 

B. Site-Specific Considerations

1. Human Health 

The population of Klamath County in 2000 was 63,775 (Meacham et. al.

2001). Major cities include Klamath Falls (19,060), Merrill (850), Chiloquin 

(795), Malin (760), Bonanza (380) (Bradbury 2001). 

The suppression program would be conducted on rangelands that are not 

normally inhabited by humans. Agriculture is a primary economic factor for 

the area and human habitation is widely scattered throughout the region, 

mainly on the edges of the rangeland. Most habitation is comprised of 

single-family farm or ranch houses, but some rangeland areas may have 

suburban developments or “ranchettes” nearby. Average population density 

in rural areas of eastern Oregon is 3.6 persons per square mile. 

Schools are located in most of the cities and towns. Since treatments are 

conducted in rural rangeland, no impact to these facilities is expected. 

Recreationists may use the rangelands for hiking, camping, bird watching, 

hunting, falconry or other uses. In the event a rural school house, inhabited 

dwelling, or recreational facility is encountered, mitigation measures in the 

Treatment Guidelines (Appendix 1) will be implemented, and no adverse 

impacts are expected.

Human health may be affected by the proposed actions. However, potential 

exposures to the general public from traditional application rates are 

infrequent and of low magnitude. These low exposures to the public pose no 

17
OR-08-02 

risk of direct toxicity, carcinogenicity, neurotoxicity, genotoxicity, 

reproductive toxicity, or developmental toxicity. Program use of carbaryl, 

malathion, and diflubenzuron has occurred in many past programs, and no 

adverse health effects have been reported. 

Children and persons with sensitivity to chemicals are those most likely to 

experience any negative effects. These individuals will be advised to avoid 

treatment areas at the time of application until the insecticide has time to dry 

on the treated vegetation.

Those most at risk during operations would be persons actually mixing or 

applying chemicals. These individuals will be advised to avoid treatment 

areas at the time of application until the insecticide has time to dry on the 

treated vegetation.

a. Executive Order No. 12898, Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations 

Executive Order (E.O.) 12898, Federal Actions To Address Environmental 

Justice in Minority Populations and Low-Income Populations, was signed by 

President Clinton on February 11, 1994 (59 Federal Register (FR) 7269). 

This E.O. requires each Federal agency 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 lowincome populations. Consistent with this E.O., APHIS will consider the 

potential for disproportionately high and adverse human health or 

environmental effects on minority populations and low-income populations 

for any of its actions related to grasshopper suppression programs. 

Population makeup in Klamath County (U.S. Census Bureau 2000) is 87.3% 

White. Hispanic or Latino of any race is the next most numerous group 

comprising 7.8%. Other identifiable groups include Black or African 

American 0.6%, American Indian and Alaska Native 4.1 %, Asian 0.8%, and 

Native Hawaiian and Other Pacific Islander 0.1%. Hispanic workers are 

often engaged in the production and processing of crops. 

American Indians of the Klamath Tribes, made up of the Klamath, Modoc 

and the Yahooskin band of Paiute Indians, reside in Klamath County. 

Although they do not currently have a reservation, they retain traditional 

water, hunting, and fishing rights to former reservations lands, 

approximately 1.8 million acres in the northern half of the county. 

The number of persons in Klamath County below the poverty level in 1999 

was 16.8% (U.S. Census Bureau 2000). Median household was $31,537 in 

18
OR-08-02 

1999. Oregon and US figures for persons below poverty are 11.6%, 12.4%; 

the median household incomes are $40,916, $41,994; and the per capita 

incomes are $20,940, $21,587. 

b. Executive Order No. 13045, Protection of Children from 

Environmental Health Risks and Safety Risks 

Recognition of the increased scientific knowledge about the environmental 

health risks and safety risks associated with hazardous substance 

exposures to children brought about legislation and other requirements to 

protect the health and safety of children. On April 21, 1997, President 

Clinton signed E.O. 13045, Protection of Children from Environmental 

Health Risks and Safety Risks (62 FR 19885). This E.O. requires each 

Federal agency, consistent with its mission, to identify and assess 

environmental health risks and safety risks that may disproportionately 

affect children and to ensure that its policies, programs, activities, and 

standards address disproportionate risks to children that result from 

environmental health risks or safety risks. APHIS has developed agency 

guidance for its programs to follow to ensure the protection of children 

(USDA, APHIS, 1999). 

In 2000 the population under 18 years of age in Klamath County was 

25.8%. This compares with 24.7 % for the entire state of Oregon and 

25.7% for the US (U.S. Census Bureau 2000). 

2. Nontarget Species 

Grasslands, open forest, shrub/brush lands, and their associated wetlands 

are the most likely to be involved in a grasshopper control program. These 

lands host a variety of wildlife species including terrestrial vertebrate and 

invertebrate animals (including grasshopper species which are not 

threatening valuable resources), aquatic organisms, and terrestrial plants 

(both native and introduced). The proposed actions could take place in 

areas that contain suitable habitat (see Appendix 2, Map 3). 

Invertebrate organisms of special interest include biocontrol insects and 

pollinators. Land managers and others have released and managed 

biocontrol agents including insects and pathogens on many species of 

invasive plants within and near the suppression program area. These 

biocontrol agents are important in decreasing the overall population or the 

rate of reproduction of some species of undesirable rangeland plants, 

especially exotic invasive weeds. 

Pollinators occur within and near the suppression program area. Pollinators 

include managed exotic and native insect species such as honey bees, 

leafcutter bees, and alkali bees which are commercially valuable for 

19
OR-08-02 

agriculture. Other species of insects and animals pollinate native and exotic 

plants and are necessary for the survival of some species. 

Vertebrates occurring in the area include highly visible introduced and 

native mammalian species such as cattle, sheep, horses, mule deer, elk, 

pronghorn, and coyotes as well as smaller animals like rabbits, mice, 

gophers and bats. Birds comprise a large portion of the vertebrate species 

complex, and they also include exotic and native species. Some exotic 

game birds, like pheasant and partridge, have been deliberately introduced 

into the area, and other species such as starlings and pigeons have spread 

from other loci of introduction. Sage-obligate bird species, typified by sage 

grouse, are present in this area. Various reptiles and amphibians are also 

present. Many of the herbivorous vertebrate species compete with some 

species of grasshoppers for forage, while other species utilize grasshoppers 

and other insects as a food source. There is special concern about the role 

of grasshoppers as a food source for sage grouse, sharp-tail grouse, and 

other bird species. 

The proposed suppression area contains a vast variety of terrestrial 

invertebrates, primarily insects and other arthropods. They include species 

which compete with grasshoppers and some which prey on grasshoppers. 

In turn, some species of grasshoppers may prey opportunistically on other 

invertebrates. 

Aquatic organisms within the suppression area include plants and 

vertebrate and invertebrate animals. Some species of fish utilize 

grasshoppers as a significant food source during some parts of the year. 

Springs are of special concern since they are often unconnected to stream 

systems or other water bodies. Due to lack of connectivity, biota found at 

springs can be endemic, and therefore particularly sensitive. Even if species 

at a particular spring are found elsewhere, the lack of connectivity to other 

populations would slow or prevent recolonization, especially for aquatic 

invertebrates that do not have a winged adult life stage. 

A diverse complement of terrestrial plants occurs within the proposed 

suppression area. Many such as Canada thistle, Mediterranean sage, 

spotted and diffuse knapweed, and yellow starthistle, are considered as 

invasive weeds. Native plants such as sagebrushes, bitterbrush, and 

various grasses provide forage and shelter for animal species and help 

stabilize the soil against erosion. 

Biological soil crusts, also known as cryptogamic, microbiotic, cryptobiotic, 

and microphytic crusts, occur within the proposed suppression area. 

Biological soil crusts are formed by living organisms and their by-products, 

creating a crust of soil particles bound together by organic materials. Crusts 

20
OR-08-02 

are predominantly composed of cyanobacteria (formerly blue-green algae), 

green and brown algae, mosses, and lichens. Liverworts, fungi, and 

bacteria can also be important components. Crusts contribute to a number 

of functions in the environment. Because they are concentrated in the top 1 

to 4 mm of soil, they primarily affect processes that occur at the land surface 

or soil-air interface. These include soil stability and erosion, atmospheric Nfixation, nutrient contributions to plants, soil-plant-water relations, infiltration, 

seedling germination, and plant growth. 

The proposed action could cause changes that may affect the behavior or 

physiological processes of some federally listed Threatened, Endangered, 

or Proposed species. The following table shows the federally listed species 

found in the Klamath County, and if any critical habitat (CH) is assigned or 

proposed (PCH). Critical habitat is a specific geographic area essential to 

the conservation of a T&E species which may require special protection. 

Table 1. Federally listed Threatened (T) and Endangered (E) species 

Common Name Scientific Name Status

Mammals

Canada Lynx Lynx Canadensis T 

Fish

Bull Trout (Klamath Basin 

population) 

Salvelinus confluentus T (PCH) 

Lost River Sucker Deltistes luxatus E (PCH) 

Shortnose Sucker Chasmistes brevirostris E (PCH) 

Birds

Northern Spotted Owl Strix occidentalis caurina T (CH) 

Plants

Applegate’s Milk-vetch Salvelinus confluentus E 

Candidate species have no protection under the ESA, but their conservation 

status is of special concern to FWS and they are candidates for listing as 

threatened or endangered. Candidate species that occur in Klamath County 

include fisher, Martes pennanti, Oregon spotted frog, Rana pretiosa, yellowbilled cuckoo, Coccyzus americanus, and the Mardon skipper (butterfly), 

Polites mardon. 

Many other species are accorded special status by federal land managers 

or by the State of Oregon. Data about these species are available from the 

21
OR-08-02 

respective land managers or at Oregon Department of Fish & Wildlife 

website, http://www.dfw.state.or.us/wildlife/pdf/sensitive_species.pdf. 

a. Bald and Golden Eagle Protection Act 

The Eagle Act (16 U.S.C. 668-668c), enacted in 1940, and amended 

several times since then, prohibits anyone, without a permit issued by the 

Secretary of the Interior, from “taking” bald eagles, including their parts, 

nests, or eggs. The Act provides criminal and civil penalties for persons who 

“take, possess, sell, purchase, barter, offer to sell, purchase or barter, 

transport, export or import, at any time or any manner, any bald eagle ... [or 

any golden eagle], alive or dead, or any part, nest, or egg thereof.” The Act 

defines “take” as “pursue, shoot, shoot at, poison, wound, kill, capture, trap, 

collect, molest or disturb.” “Disturb’’ means: "Disturb means to agitate or 

bother a bald or golden eagle to a degree that causes, or is likely to cause, 

based on the best scientific information available, 1) injury to an eagle, 2) a 

decrease in its productivity, by substantially interfering with normal breeding, 

feeding, or sheltering behavior, or 3) nest abandonment, by substantially 

interfering with normal breeding, feeding, or sheltering behavior." In addition 

to immediate impacts, this definition also covers impacts that result from 

human-induced alterations initiated around a previously used nest site 

during a time when eagles are not present, if, upon the eagles return, such 

alterations agitate or bother an eagle to a degree that injures an eagle or 

substantially interferes with normal breeding, feeding, or sheltering habits 

and causes, or is likely to cause, a loss of productivity or nest abandonment. 

Both bald and golden eagles are known to reside in the area covered under 

this EA. 

3. Socioeconomic Issues 

Agriculture is an important part of the area’s economy and landscape. 

Approximately 18% of Klamath County is used for cropland or rangeland 

(Meacham et. al. 2001). Croplands are concentrated on irrigated land 

surrounding Klamath Lake, the Klamath irrigation project south and east of 

Klamath Falls, and other small, scattered pockets of mainly irrigated 

cropland in arable valleys. Livestock enterprises include rangeland grazing 

by cattle, sheep, and horses; feedlots for beef, and concentrated dairy 

operations. Livestock inventory on January 1, 2002 included total cattle 

(97,000), beef cows (49,000), dairy cattle (4700), and sheep (4000). Barley, 

oats, alfalfa, hay, and potatoes are important crop here. Gross farm and 

ranch sales for Klamath County in 2001 were $115.7 million. Crops 

accounted for $40.6 million and animal products $75.1 million (ODA 2002). 

Acreage in organic production is increasing in the area. There was 17,208 

acres registered in organic production in Klamath County in 2002. 

22
OR-08-02 

Beekeepers maintain hives to produce honey and other bee products on 

land which is included in the proposed treatment area as well as on land 

located near the proposed treatment area. Alfalfa and seed crops rely on 

pollination from bees which may live or forage on or near proposed 

suppression areas. 

Other important industries for this area are forest products, tourism and 

recreation (Bradbury 2001). 

Much of the land here is publicly owned. The area contains parts the 

Fremont-Winema National Forest administered by USDA Forest Service. 

USDI Fish and Wildlife Service administers the Klamath Marsh, Bear Valley, 

Lower and Upper Klamath National Wildlife Refuges. The USDI Bureau of 

Land Management administers much of the public rangeland and is the 

major landowner in the southeast and south-central part of Oregon. More 

than half the public forest and rangeland is leased for grazing (Meacham et. 

al. 2001). The remainder is either not farmable or set aside as protected 

areas. 

This area also contains many parks, wilderness areas, public forests, and 

wilderness studies area administered by state or local governments. The 

Department of Interior, National Park Service administers Crater Lake 

National Park. Oregon Parks Department administers Collier Memorial State 

Park, Jackson F. Kimball State Park, and OC&E Woods Line State Trail. 

There may also be areas of rangeland habitat considered as “sensitive 

areas” for the survival of non-listed species of concern. 

The general public uses rangelands in the proposed suppression area for a 

variety of recreational purposes including hiking; camping; wildlife, bird, and 

insect collecting and watching; hunting; falconry; shooting; plant collecting; 

rock and fossil collecting; artifact collecting; sightseeing; and dumping. 

Members of the general public traverse rangelands in or near the proposed 

suppression area by various means including on foot, horseback, all terrain 

vehicles, bicycles, motorcycles, four-wheel drive vehicles, snowmobiles, and 

aircraft. 

Artificial surfaces in or near the proposed suppression area include the walls 

and roofs of buildings, painted finishes on automobiles, trailers, recreational 

vehicles, and road signs. See 2002 FEIS pp 71-72 

The land most likely to be involved in a grasshopper suppression program 

would include active or idle rangeland, Conservation Reserve Program 

(CRP) land, and some cropland. Areas where grasshoppers have 

historically been an economic problem in Oregon are summarized in 

Appendix 2, Map 3. 

23
OR-08-02 

4. Cultural Resources and Events 

Cultural and historical sites include locations and artifacts associated with 

Native Americans, explorers, pioneers, religious groups and developers. 

Native American petroglyphs have been discovered in several areas within 

the proposed suppression area. Artifacts from knapping (stone tool making) 

occur within the proposed suppression area. Museums, displays and 

structures associated with mining, logging, and irrigation development exist 

in areas near the proposed suppression area. 

IV. Environmental Consequences 

A. Environmental Consequences of the Alternatives 

 

Each alternative described in this EA potentially has adverse environmental 

effects. The general environmental impacts of each alternative are 

discussed in detail in the 2002 FEIS. The specific impacts of the 

alternatives are highly dependent upon the particular action and location of 

infestation. The principal concerns associated with the alternatives that 

include insecticide application are: (1) the potential effects of the three 

pesticide options on human health (including subpopulations that might be 

at increased risk); and (2) impacts of pesticides on nontarget organisms 

(including threatened and endangered species). Assessments of the 

relative risk of each pesticide option are discussed in detail in the 2002 FEIS 

document. 

Site-specific environmental consequences of the alternatives are discussed 

in this section. 

1. No Action Alternative 

Under this alternative, APHIS would not fund or participate in any program 

to suppress grasshoppers. If APHIS does not participate in any 

grasshopper suppression program, Federal land management agencies, 

State agriculture departments, local governments, or private groups or 

individuals, may not effectively combat outbreaks in a coordinated effort. In 

these situations, grasshopper outbreaks could develop and spread 

unimpeded. 

Human health

There would be no exposure to the public from program chemicals under 

this alternative. However, without APHIS participation, local governments, or 

private groups or individuals may attempt to conduct widespread 

grasshopper programs. It is possible that a large amount of insecticides, 

24
OR-08-02 

including those with a greater risk to human health, could be applied, 

reapplied, and perhaps misapplied in an effort to suppress or even locally 

eradicate grasshopper populations. Such a scenario could lead to greater 

human exposure to a wider array of chemicals. 

Some stakeholders have indicated that they are opposed to any treatments 

on public rangelands because they believe treatments would disrupt 

ecosystems. The anxiety levels of these stakeholders may be reduced if 

APHIS does not suppress grasshopper outbreaks. 

Uncontrolled grasshopper outbreaks can have direct and indirect effects on 

the human population that depends on the crops and forage consumed by 

grasshoppers. When grasshopper populations reach outbreak levels they 

become migratory in nature, seeking out new areas of vegetation to feed on. 

Significant crop losses may occur when grasshopper migrate from 

rangeland to cropland. Additional inputs of insecticides, potentially more 

harmful than program chemicals, may be required to protect crops. This 

would result in increased exposure of farm workers to insecticides. 

The anxiety level of persons experiencing losses to crops and rangeland 

forage may increase if no action is taken to control grasshopper outbreaks. 

Non-target species

An abundant supply of grasshoppers and other insects would be available 

as a food source for insectivorous animals. This includes birds and other 

animals which have been accorded sensitive species status by land 

managers and others. 

Grasshoppers in unsuppressed outbreaks would consume agricultural and 

nonagricultural plants. The damage caused by grasshopper outbreaks 

could also pose a risk to rare, threatened, or endangered plants that often 

have a low number of individuals and limited distribution. Plants can be 

killed or weakened by grasshopper feeding. Some grasshoppers feed on 

seeds, so future generations of plants could be threatened. 

Loss of plant cover would occur due to consumption by grasshoppers. 

Nesting and cover habitat may be degraded for birds and other wildlife. The 

herbaceous under story is important to nesting success by sage grouse 

(Connelly, et. al. 1994). 

Rangeland which has been severely grazed by grasshoppers is more 

susceptible to invasion by nonnative plant species. Plant cover may protect 

the soil from the drying effects of the sun. The plant root systems which 

hold the soil in place may be weakened, leading to increased rates of 

erosion. Continued livestock grazing on grasshopper impacted lands will 

25
OR-08-02 

compound the effects to vegetation, soils, and water quality negatively 

impacting non-target species. 

If APHIS does not participate in any grasshopper suppression programs, 

local governments, or private groups or individuals may attempt to conduct 

widespread grasshopper programs. Without the technical assistance and 

program coordination that APHIS can provide to grasshopper programs, it is 

possible that a large amount of insecticides, including those APHIS 

considers too environmentally harsh, could be applied, reapplied, and 

perhaps misapplied in an effort to suppress or even locally eradicate 

grasshopper populations. It is not possible to accurately predict the 

environmental consequences of the No Action alternative to non-target 

organisms because the type and amount of insecticides that could be used 

in this scenario are unknown. 

Rangeland fires may be set by persons who desire suppression of the 

grasshoppers. Action of this type has not been documented, but individuals 

have threatened to set fires to destroy grasshopper outbreaks that are not 

controlled. 

Socioeconomic issues

If left untreated, there is the risk that grasshopper outbreaks on rangeland 

would decrease the availability of forage for cattle and sheep. If sheep and 

cattle grazing become unprofitable, there may be disproportionate impact on 

the sheepherding and cattle raising professions. Livestock must compete 

with grasshoppers for available forage leading to monetary losses due to 

supplemental feed programs, the need to move stock to unaffected areas, 

and/or sell livestock prematurely. It will affect other ranchers by increasing 

demand, and consequently, cost for hay and/or pasture. This will have a 

beneficial effect on those providing the hay or range, and a negative impact 

on other ranchers who use these same resources. Continued grazing on 

impacted lands will compound the effects to vegetation, resulting in longerterm impacts on grazing forage production on these lands. The lack of 

treatment could result in the eventual magnification of grasshopper 

problems resulting in increased suppression efforts, increased suppression 

costs and the expansion of suppression needs onto lands where options are 

limited. 

Unchecked movement of grasshopper outbreaks into crops would result in 

crop loss and additional expenditures for insecticidal control in the crop 

fields. Organic farmers may suffer significant losses if grasshopper 

outbreaks are not controlled on rangeland and migrate to organic cropland. 

Some organic farmers were forced to abandon their organic farming 

enterprise in Camas County, Idaho in 2000 due to invasion of grasshoppers 

from rangeland into organic alfalfa fields. 

26
OR-08-02 

It has been suggested that rather than treat grasshopper outbreaks, the 

federal government should compensate farmers for losses they incur. In 

cases where grasshoppers migrate from rangeland onto high value 

cropland, USDA Risk Management Agency (RMA) currently offers multiperil 

crop insurance (Sec. 501 7 USC 1501) which may compensate for losses 

due to insects if the policy holder utilizes appropriate pest control measures, 

but those measures fail. Forage is not a covered crop under this program. 

Normally, this payment is based on the failure of pest control spray 

practices due to untimely rainfall or some other natural event. 

USDA Farm Service Agency (FSA) offers the Noninsured Crop Disaster 

Assistance Program (NAP) (7 CFR 1437.4) which provides financial 

assistance to eligible producers affected by natural disasters. Forage is 

considered a noninsured crop. To be eligible a natural disaster must result 

from a condition related to damaging weather or adverse natural 

occurrence, such as excessive heat, disease, or insect infestation. Normally 

grasshopper damage would not qualify for this program. However, the local 

FSA Office may make a determination that a grasshopper outbreak is a 

direct result of drought conditions that exist at the time. This program 

requires pre-enrollment, annual production reporting, and meeting a loss 

threshold. 

The Grassland Reserve Program (GRP) is a new USDA FSA program 

designed to reward good range stewardship. This program is for working 

range, not set aside. In other words livestock numbers would be reduced, 

but not eliminated. A landowner must apply to enroll his rangeland in this 

program. Due a limited pool of money, selection criteria ensure only the 

highest priority areas are protected. The program offers landowners the 

option to grant an easement or enter into a long-term agreement to preserve 

and protect the ecological benefits of eligible land in exchange for annual 

rental payments. 

Skold and Davis (1995) proposed a rangeland grasshopper insurance 

program. No authority currently exists for such a program. 

APHIS has no control over these programs. Since they may provide an 

option for growers affected by grasshoppers, the local FSA and RMA 

manager will be invited to public meetings when a suppression program is 

being planned to explain these programs. 

Cultural resources and events

Grasshoppers were a significant source of protein for indigenous North 

American people. They are no longer used as a human food source except 

as a novelty or recreational experience. They are used for fish bait, and 

selection of the No Action alternative would result in their abundant 

availability for these purposes. 

27
OR-08-02 

Grasshopper populations at outbreak levels on rangeland would decrease 

the recreational satisfaction of some people utilizing rangeland resources, 

primarily those who do not like insects. Conversely, grasshopper 

populations at outbreak levels would increase the recreational satisfaction of 

those who enjoy spectacular biological phenomena. 

2. Insecticide Applications at Conventional Rates and Complete Area 

Coverage Alternative 

Under Alternative 2, APHIS would participate in grasshopper programs with 

the option of using one of the insecticides carbaryl, diflubenzuron, or 

malathion, depending upon the various factors related to the grasshopper 

outbreak and the site-specific characteristics. The use of an insecticide 

would occur at the conventional rates. With only rare exceptions, APHIS 

would apply a single treatment in an outbreak year that would blanket 

affected rangeland areas in an attempt to suppress grasshopper outbreak 

populations by a range of 35 to 98 percent, depending upon the insecticide 

used. See 2002 EIS pp. 38-48 for general consequences. 

Carbaryl

Carbaryl is of moderate acute oral toxicity to humans. The mode of toxic 

action of carbaryl occurs through inhibition of acetylcholinesterase (AChE) 

function in the nervous system. This inhibition is reversible over time if 

exposure to carbaryl ceases. The Environmental Protection Agency (EPA) 

has classified carbaryl as a possible human carcinogen (EPA, 1993). 

However, it is not considered to pose any mutagenic or genotoxic risk. 

Potential exposures to the general public from conventional application 

rates are infrequent and of low magnitude. These low exposures to the 

public pose no risk of direct toxicity, carcinogenicity, neurotoxicity, 

genotoxicity, reproductive toxicity, or developmental toxicity. The potential 

for adverse effects to workers are negligible if proper safety procedures are 

followed, including wearing the required protective clothing. Carbaryl has 

been used routinely in other programs with no reports of adverse health 

effects. Therefore, routine safety precautions are expected to provide 

adequate worker health protection. 

Carbaryl is of moderate acute oral toxicity to mammals (McEwen et al., 

1996a). Carbaryl applied at Alternative 2 rates is unlikely to be directly toxic 

to upland birds, mammals, or reptiles. Field studies have shown that 

carbaryl applied as either ultra-low-volume (ULV) spray or bait at Alternative 

2 rates posed little risk to killdeer (McEwen et al., 1996a), vesper sparrows 

(McEwen et al., 1996a; Adam et al., 1994), or golden eagles (McEwen et 

al., 1996b) in the treatment areas. AChE inhibition at 40 to 60 percent can 

affect coordination, behavior, and foraging ability in vertebrates. Multi-year 

28
OR-08-02 

studies conducted at several grasshopper treatment areas have shown 

AChE inhibition at levels of no more that 40 percent with most at less than 

20 percent (McEwen et al., 1996a). Carbaryl is not subject to significant 

bioaccumulation due to its low water solubility and low octanol-water 

partition coefficient (Dobroski et al., 1985). 

Carbaryl will most likely affect nontarget insects that are exposed to ULV 

carbaryl spray or that consume carbaryl bait within the grasshopper 

treatment area. Field studies have shown that affected insect populations 

can recover rapidly and generally have suffered no long-term effects, 

including some insects that are particularly sensitive to carbaryl, such as 

bees (Catangui et al., 1996). The use of carbaryl in bait form generally has 

considerable environmental advantages over liquid insecticide applications: 

bait is easier than liquid spray applications to direct toward the target area, 

bait is more specific to grasshoppers, and bait affects fewer nontarget 

organisms than sprays (Quinn, 1996). 

Operational procedures are in place to prevent carbaryl from entering water. 

However, should carbaryl enter water, there is the potential to affect the 

aquatic invertebrate assemblage, especially amphipods. Field studies with 

carbaryl concluded that there was no biologically significant effect on 

aquatic resources, although invertebrate downstream drift increased for a 

short period after treatment due to toxic effects (Beyers et al., 1995). 

Carbaryl is moderately toxic to most fish (Mayer and Ellersieck, 1986). 

Diflubenzuron 

The acute oral toxicity of diflubenzuron formulations to humans ranges from 

very slight to slight. The most sensitive indicator of exposure and effects of 

diflubenzuron in humans is the formation of methemoglobin from 

hemoglobin (a compound in blood responsible for the transport of oxygen) 

in blood. 

Potential exposures to the general public from Alternative 2 application rates 

are infrequent and of low magnitude. These low exposures to the public 

pose no risk of methemoglobinemia (a condition where the heme iron in 

blood is chemically oxidized and lacks the ability to properly transport 

oxygen), direct toxicity, neurotoxicity, genotoxicity, reproductive toxicity, or 

developmental toxicity. Potential worker exposures are higher than the 

general public but are not expected to pose any risk of adverse health 

effects. 

Because diflubenzuron is a chitin inhibitor that disrupts insects from forming 

their exoskeleton, organisms without a chitinous exoskeleton, such as 

mammals, fish, and plants are largely unaffected by diflubenzuron. In 

addition, adult insects, including wild and cultivated bees, would be mostly 

unaffected by diflubenzuron applications (Schroeder et al., 1980; Emmett 

29
OR-08-02 

and Archer, 1980). Among birds, nestling growth rates, behavior data, and 

survival of wild American kestrels in diflubenzuron treated areas showed no 

significant differences among kestrels in treated areas and untreated areas 

(McEwen et al., 1996b). The acute oral toxicity of diflubenzuron to 

mammals ranges from very slight to slight. Little, if any, bioaccumulation of 

diflubenzuron would be expected (Opdycke et al., 1982). 

Diflubenzuron is most likely to affect immature terrestrial insects and early 

life stages of aquatic invertebrates (Eisler, 2000). While this would reduce 

the prey base within the treatment area for organisms that feed on insects, 

adult insects, including grasshoppers, would remain available as prey items. 

Many of the aquatic organisms most susceptible to diflubenzuron are 

marine organisms that would not be exposed to rangeland treatments. 

Freshwater invertebrate populations would be reduced if exposed to 

diflubenzuron, but these decreases would be expected to be temporary 

given the rapid regeneration time of many aquatic invertebrates. 

Malathion

Malathion is of slight acute oral toxicity to humans. The mode of toxic action 

of malathion occurs through inhibition of AChE function in the nervous 

system. Unlike carbaryl, AChE inhibition from malathion is not readily 

reversible over time if exposure ceases. However, strong inhibition of AChE 

from malathion occurs only when chemical oxidation results in formation of 

the metabolite malaoxon. Human metabolism of malathion favors 

hydroxylation and seldom produces much malaoxon. 

Potential exposures to the general public from conventional application 

rates are infrequent and of low magnitude. These low exposures to the 

public pose no risk of direct toxicity, neurotoxicity, genotoxicity, reproductive 

toxicity, or developmental toxicity. Potential worker exposures are higher, 

but still have little potential for adverse health effects except under 

accidental scenarios. Malathion has been used routinely in other programs 

with no reports of adverse health effects. Therefore, routine safety 

precautions are expected to continue to provide adequate protection of 

worker health. 

EPA has recently reviewed the potential for carcinogenic effects from 

malathion. EPA’s classification describes malathion as having suggestive 

evidence of carcinogenicity, but not sufficient to assess human carcinogenic 

potential (EPA, 2000). This indicates that any carcinogenic potential of 

malathion cannot be quantified based upon EPA’s weight of evidence 

determination in this classification. The low exposures to malathion from 

program applications would not be expected to pose carcinogenic risks to 

workers or the general public. 

30
OR-08-02 

Malathion is of slight acute oral toxicity to mammals. There is little 

possibility of toxicity-induced mortality of upland birds, mammals, or reptiles, 

and no direct toxic effects have been observed in field studies. Malathion is 

not directly toxic to vertebrates at the concentrations used for grasshopper 

suppression, but it may be possible that sublethal effects to nervous system 

functions caused by AChE inhibition may lead directly to decreased survival. 

AChE inhibition at 40 to 60 percent affects coordination, behavior, and 

foraging ability in vertebrates. Multi-year studies at several grasshopper 

treatment areas have shown AChE inhibition at levels of no more than 40 

percent with most at less than 20 percent (McEwen et al., 1996a). Field 

studies of birds within malathion treatment areas showed that, in general, 

the total number of birds and bird reproduction were not different from 

untreated areas (McEwen et al., 1996a). Malathion does not bioaccumulate 

(HSDB, 1990; Tsuda et al., 1989). 

Malathion will most likely affect nontarget insects within a treatment area. 

Large reductions in some insect populations would be expected after a 

malathion treatment under Alternative 2. While the number of insects would 

be diminished, there would be some insects remaining. The remaining 

insects would be available prey items for insectivorous organisms, and 

those insects with short generation times may soon increase. 

Malathion is highly toxic to some fish and aquatic invertebrates. Operational 

procedures are in place to prevent malathion from entering water. 

Therefore, malathion concentrations in water, as a result of grasshopper 

treatments, is not expected to present a risk to aquatic organisms, 

especially those organisms with short generation times. 

The implementation of pesticide label instructions and restrictions and the 

APHIS treatment guidelines will reduce potential impacts from the program 

use of insecticides (see Appendix 1, Treatment Guidelines). 

Human Health

Human exposure to program insecticides could occur. Exposures and 

effects are discussed in the 2002 FEIS pp. 39-40, 43, and 46-47. Personnel 

working on the suppression program would be exposed during handling, 

loading and application of the insecticides. Potential exposure of the 

general public would be infrequent and of low magnitude. Implementation 

of the Operational Procedures (Appendix 1) would minimize public exposure 

and protect workers from harmful exposure. Individuals with 

hypersensitivity to the insecticides, carriers, and adjuvants might be 

affected. APHIS will seek lists of hypersensitive individuals from state and 

county health departments and would contact persons who reside near 

proposed treatment areas prior to treatment. Hypersensitive individuals 

would be advised to avoid treatment areas and the areas surrounding them. 

31
OR-08-02 

Many persons are opposed to any treatments on public rangelands because 

they believe treatments would disrupt ecosystems. The anxiety levels of 

these stakeholders may be increased. Conversely, the anxiety level of 

persons whose livelihoods are being protected by treatments of 

grasshoppers, typically originating from public lands, would decrease. 

Pesticide spills could expose individuals to excessive levels of insecticide. 

APHIS maintains spill kits and insures that program personnel are familiar 

with procedures to mitigate effects associated with a spill. 

Non-target species

Exposure to program insecticides could occur. Exposures and effects on 

representative species in each non-target group are discussed in the 2002 

FEIS Appendix B and part V. C. pp. 39-48. 

Under this alternative grasshopper feeding damage would be reduced to 

rangeland plants, including desirable and undesirable plants, and to crops 

adjacent to rangeland. Reduction of the grasshopper feeding damage may 

be viewed as having both negative and positive impacts. Population 

densities of some nontarget insects and other arthropods would be reduced. 

Food sources for some insectivorous animal species would be reduced. 

Nontarget plant and animal species would be exposed to insecticides. 

Nontarget insect species which would be put at risk by treatments under this 

alternative include non-native biological control agents and pollinators. Any 

chemical applied to control grasshoppers has the potential to cause adverse 

impacts to biological control agents that been released by government 

agencies or private individuals to control noxious weeds or arthropod pests. 

APHIS will consult with land managers to determine the location and status 

of biological control agent populations and would select treatment options 

(including buffering areas) which minimize negative impacts on the 

populations. 

Managed pollinators include native leafcutter and alkali bees, and nonnative honeybee. Honeybees are found throughout and near the proposed 

suppression area. Malathion and carbaryl sprays are very toxic to bees. 

Leafcutter and alkali bees may be found in the proposed treatment area, but 

are usually encountered in crop areas adjacent to the rangeland. APHIS will 

conduct surveys and consult with landowners to determine if managed 

pollinators are in or near proposed treatment areas. Measures to protect 

bees are in the Operational Guidelines (Appendix 1). 

Unmanaged native pollinators include a vast array of insects and other 

animals. In general, the insect fauna within this group is more susceptible 

to malathion and carbaryl sprays than to the other treatment options. To 

maximize the protection of these organisms, APHIS would select 

32
OR-08-02 

diflubenzuron spray or carbaryl bait whenever they would be efficacious to 

control grasshopper outbreaks. 

This alternative may result in the reduction of insects as a food source for 

rangeland insectivores, such as sage grouse and sharptail grouse chicks. 

The use of the insecticides (diflubenzuron and carbaryl bait) which are more 

selective for grasshoppers than for most other species leaves alternative 

insect fauna for foraging insectivores (Paige and Ritter 1999). Because 

APHIS would only treat significant outbreak populations, numbers of 

grasshoppers surviving the treatment can provide ample nourishment for 

the insectivores. Additionally, Martin et. al. (2000) and Howe, et. al. (2000) 

found that grassland and shrub steppe bird species were able to make 

adaptive changes when insecticidal spray reduced the numbers and 

changed the composition of insect prey species. 

There would be a temporary decrease in insect biodiversity within treatment 

areas. Malathion and carbaryl sprays would decrease the biodiversity more 

than diflubenzuron spray and carbaryl bait treatments. 

The program chemicals have no phytotoxicity to most plants when applied 

at label rates. The chemicals act quickly to reduce grasshopper infestations, 

thus minimizing damage to vegetation from grasshopper foraging. Chemical 

controls have the potential for indirect affects on plants that depend on 

certain insects (bees and ants), for pollination and seed dispersal. These 

insects’ numbers may be depressed by chemical control. The effect on 

plants by a control program will be less than the loss of growth and seed 

production caused by the total elimination of most vegetation by 

grasshoppers during an outbreak. 

Impacts to non-target species from livestock grazing is unlikely to be 

affected by this alternative. 

Pesticide spills could expose wildlife to excessive levels of insecticide. 

APHIS maintains spill kits and insures that program personnel are familiar 

with procedures to mitigate effects associated with a spill. 

 

Negative impacts to nontarget organisms would be minimized by the 

implementation of the Treatment Guidelines (Appendix 1). 

Socioeconomic issues

A discussion of the socioeconomic impacts of grasshopper treatments are 

discussed on pages 61-74 of the 2002 FEIS. 

Under this alternative, there is a reduced risk that grasshopper outbreaks on 

rangeland would decrease the availability of forage for cattle and sheep. 

There is also a reduced risk of unchecked movement of grasshopper 

33
OR-08-02 

outbreaks into crops resulting in crop loss and additional expenditures for 

insecticidal control in the crop fields. 

Organic farmers face less risk of significant losses from grasshopper 

outbreaks on rangeland which could emigrate to organic cropland. 

However, organic farmers would be put at increased risk of contamination 

from spray originating from grasshopper suppression programs. APHIS will 

procure a listing of certified organic growers and determine buffers needed 

to protect organic farm operations. 

Air pollutants will be produced by fuel combustion in airplanes, vehicles, and 

machinery used in grasshopper control activities. Allowable emission levels 

and concentrations are enforced by state air control agencies. The amounts 

of these pollutants are not expected to exceed the normal background 

levels, and should have a negligible temporary effect on air quality. 

Increases in ozone concentration from the volatilization of pesticides and 

carriers are also expected to be negligible. The chemicals approved for use 

have low vapor pressure and are essentially nonvolatile. 

Negative socioeconomic impacts would be minimized by the implementation 

of the Treatment Guidelines (Appendix 1). 

Cultural resources and events

The availability of grasshoppers for fish bait and other human uses would be 

reduced from outbreak levels to more normal levels. Persons using 

rangelands for recreation would respond to grasshoppers as they do under 

normal conditions versus under outbreak conditions. 

If Native American tribal lands will be involved in a program area, tribes will 

be consulted. Tribal representatives will have the opportunity to identify any 

cultural sites, such as native plants use areas, which might be impacted. 

Consultation will allow for mitigation of impacts to these sites. 

Artificial surfaces

Malathion and carbaryl spray can damage some painted surfaces. 

Automotive and sign finishes are susceptible to damage, and their owners 

could suffer economic loss repairing cosmetic damage. Public notice of 

malathion and carbaryl spray programs will include a warning about how to 

avoid potential damage. APHIS will consult with land managers if malathion 

or carbaryl spray was going to be used so they could elect to cover or 

remove signs during treatment. APHIS will consult with land managers to 

ensure that Native American petroglyphs are excluded from spray areas. 

3. Reduced Area Agent Treatments (RAATs) Alternative 

34
OR-08-02 

Under Alternative 3, one of the insecticides carbaryl, diflubenzuron, or 

malathion would be used at a reduced rate and over reduced areas of 

coverage. Rarely would APHIS apply more than a single treatment to an 

area per year. The maximum insecticide application rate under the RAATs 

strategy is reduced 50 percent from the conventional rates for carbaryl and 

malathion and 25 percent from the Alternative 2 rate for diflubenzuron. 

Although this strategy involves leaving variable amounts of land not directly 

treated, the risk assessment conducted for the 2002 EIS assumed 100 

percent area coverage because not all possible scenarios could be 

analyzed. However, when utilized in grasshopper suppression, the amount 

of untreated area in RAATs often ranges from 20 to 67 percent of the total 

infested area but can be adjusted to meet site-specific needs. 

Carbaryl

Potential exposures to the general public and workers from RAATs 

application rates are lower than those from conventional application rates, 

and adverse effects decrease commensurately with decreased magnitude 

of exposure. These low exposures to the public pose no risk of direct 

toxicity, carcinogenicity, neurotoxicity, genotoxicity, reproductive toxicity, or 

developmental toxicity. The potential for adverse effects to workers is 

negligible if proper safety procedures are followed, including wearing the 

required protective clothing. Routine safety precautions are expected to 

provide adequate protection of worker health at the lower application rates 

under RAATs. 

Carbaryl will most likely affect nontarget insects that are exposed to liquid 

carbaryl or that consume carbaryl bait. While carbaryl applied at a RAATs 

rate will reduce susceptible insect populations, the decrease will be less 

than under conventional rates. Carbaryl ULV applications applied in 

alternate swaths have been shown to affect terrestrial arthropods less than 

malathion applied in a similar fashion. 

Direct toxicity of carbaryl to birds, mammals, and reptiles is unlikely in 

swaths treated with carbaryl under a RAATs approach. Carbaryl bait also 

has minimal potential for direct effects on birds and mammals. Field studies 

indicated that bee populations did not decline after carbaryl bait treatments, 

and American kestrels were unaffected by bait applications made at a 

RAATs rate. Using alternating swaths will furthermore reduce adverse 

effects because organisms that are in untreated swaths will be mostly 

unexposed to carbaryl. 

Operational procedures are in place to prevent carbaryl from entering water. 

Carbaryl applied at a RAATs rate has the potential to affect invertebrates in 

aquatic ecosystems. However, these affects would be less than effects 

expected under Alternative 2. Fish are not likely to be affected at any 

concentrations that could be expected under this Alternative. 

35
OR-08-02 

Diflubenzuron

Potential exposures and adverse effects to the general public and workers 

from RAATs application rates are commensurately less than conventional 

application rates. These low exposures to the public pose no risk of 

methemoglobinemia, direct toxicity, neurotoxicity, genotoxicity, reproductive 

toxicity, or developmental toxicity. Potential worker exposures pose 

negligible risk of adverse health effects. 

Because diflubenzuron is a chitin inhibitor that disrupts insects from forming 

their exoskeleton, organisms without a chitinous exoskeleton, such as 

mammals, fish, and plants are largely unaffected by diflubenzuron. 

Diflubenzuron exposures at Alternative 3 rates are not hazardous to 

terrestrial mammals, birds, and other vertebrates. Insects in untreated 

swaths would have little to no exposure, and adult insects in the treated 

swaths are not susceptible to diflubenzuron’s mode of action. The indirect 

effects to insectivores would be negligible as not all insects in the treatment 

area will be affected by diflubenzuron. 

Diflubenzuron is most likely to affect immature terrestrial insects and, if it 

enters water, will affect early life stages of aquatic invertebrates. While 

diflubenzuron would reduce insects within the treatment area, insects in 

untreated swaths would have little to no exposure. Many of the aquatic 

organisms most susceptible to diflubenzuron are marine organisms that 

would not be exposed to rangeland treatments. Freshwater invertebrate 

populations would be reduced if exposed to diflubenzuron, but these 

decreases may be temporary given the rapid regeneration time of many 

aquatic invertebrates. 

Malathion

Potential exposures to the general public and workers from RAATs 

application rates are of a commensurately lower magnitude than 

conventional rates. These low exposures to the public pose no risk of direct 

toxicity, neurotoxicity, genotoxicity, reproductive toxicity, or developmental 

toxicity. 

Potential risks to workers are negligible if proper safety procedures are 

adhered to, including the use of required protective clothing. Malathion has 

been used routinely in other programs with no reports of adverse health 

effects. The low exposures to malathion from program applications are not 

expected to pose any carcinogenic risks to workers or the general public. 

Malathion applied at a RAATs rate will cause mortalities to susceptible 

insects. Organisms in untreated areas will be mostly unaffected. Field 

applications of malathion at a RAATs rate and applied in alternate swaths 

resulted in less reduction in nontarget organisms than would occur in 

36
OR-08-02 

blanket treatments. Birds in RAATs areas were not substantially affected. 

Operational procedures are in place to prevent malathion from entering 

water. Implementing RAATs method will further reduce the risk to aquatic 

invertebrates. Any losses would soon be compensated for by the surviving 

organisms given the rapid generation time of most aquatic invertebrates and 

the rapid degradation of malathion in most water bodies. 

The implementation of pesticide label instructions and restrictions and the 

APHIS treatment guidelines will reduce potential impacts from the program 

use of insecticides (see Appendix 1, Treatment Guidelines). 

Human health

Human exposure to insecticides could occur. Exposures and effects are 

discussed in the 2002 FEIS pp. 50, 52, and 55. Personnel working on the 

suppression program would be exposed during handling, loading and 

application of the insecticides. Potential exposure of the general public 

would be infrequent and of low magnitude. Potential for exposure would be 

less than under the Insecticide Applications at Conventional Rates 

Alternative. Implementation of the Operational Procedures (Appendix 1) 

would minimize public exposure and protect workers from harmful exposure. 

Individuals with hypersensitivity to the insecticides, carriers, and adjuvants 

might be affected. APHIS will seek lists of hypersensitive individuals from 

state and county health departments and would contact persons who reside 

near proposed treatment areas prior to treatment. Hypersensitive 

individuals would be advised to avoid treatment areas and the areas 

surrounding them. 

Many persons are opposed to any treatments on public rangelands because 

they believe treatments will disrupt ecosystems. The anxiety levels of these 

stakeholders may be increased, but perhaps not to the same level as would 

result from implementation of Insecticide Applications at Conventional Rates 

Alternative. The anxiety level of persons whose livelihood is being protected 

by treatments will decrease. 

 

Pesticide spills could expose individuals to excessive levels of insecticide. 

APHIS maintains spill kits and insures that program personnel are familiar 

with procedures to mitigate effects associated with a spill. 

Non-target species 

Exposure to program insecticides would occur. Exposures and effects on 

representative species in each non-target group are discussed in the 2002 

FEIS Appendix B and part V. C. pp. 50-57. 

Under this alternative grasshopper feeding damage would be reduced to 

rangeland plants, including desirable and undesirable plants, and to crops 

adjacent to rangeland. Reduction of the grasshopper feeding damage may 

37
OR-08-02 

be viewed as having both negative and positive impacts. Population 

densities of some nontarget insects and other arthropods would be reduced. 

Food sources for some insectivorous animal species would be reduced. 

Nontarget plant and animal species would be exposed to insecticides. The 

general level of reduction in feeding damage, nontarget population 

densities, food sources, and insecticide exposure would be somewhat less 

than under Insecticide Applications at Conventional Rates Alternative. 

Nontarget insect species which would be put at risk by treatments under this 

alternative include non-native biological control agents and pollinators. The 

level of risk would be somewhat less than under Insecticide Applications at 

Conventional Rates Alternative. Any chemical applied to control 

grasshoppers has the potential to cause adverse impacts to biological 

control agents that been released by government agencies or private 

individuals to control noxious weeds or arthropod pests. APHIS will consult 

with land managers to determine the location and status of biological control 

agent populations and would select treatment options (including buffering 

areas) which minimize negative impacts on the populations. 

Managed pollinators include native leafcutter and alkali bees, and nonnative honeybee. Honeybees are found throughout and near the proposed 

suppression area. Malathion and carbaryl sprays are very toxic to bees. 

Leafcutter and alkali bees may be found in the proposed treatment area, but 

are usually encountered in crop areas adjacent to the rangeland. APHIS will 

conduct surveys and consult with landowners to determine if managed 

pollinators are in or near proposed treatment areas. Measures to protect 

bees are in the Operational Guidelines (Appendix 1). The risk to managed 

pollinators would be similar to the risk under Insecticide Applications at 

Conventional Rates Alternative. 

Unmanaged native pollinators include a vast array of insects and other 

animals. In general, the insect fauna within this group is more susceptible 

to malathion and carbaryl sprays than to the other treatment options. To 

maximize the protection of these organisms, APHIS would select 

diflubenzuron spray or carbaryl bait whenever they would be efficacious to 

control grasshopper outbreaks. The risk to unmanaged native pollinators 

would be somewhat less than the risk under Insecticide Applications at 

Conventional Rates Alternative. 

This alternative may result in the reduction of insects as a food source for 

rangeland insectivores, such as sage grouse and sharptail grouse chicks. 

The reduction in rates and coverage along with the use of the insecticides 

(diflubenzuron and carbaryl bait) which are more selective for grasshoppers 

than for most other species leaves alternative insect fauna for foraging 

insectivores (Paige and Ritter 1999). Because APHIS would only treat 

significant outbreak populations, numbers of grasshoppers surviving the 

38
OR-08-02 

treatment can provide ample nourishment for the insectivores. Additionally, 

Martin et. al. (2000) and Howe, et. al. (2000) found that grassland and shrub 

steppe bird species were able to make adaptive changes when insecticidal 

spray reduced the numbers and changed the composition of insect prey 

species. Reduction in prey available to insectivores would be significantly 

less than under Insecticide Applications at Conventional Rates Alternative. 

There would be a temporary decrease in insect biodiversity within treatment 

areas. Although, significantly less than under Insecticide Applications at 

Conventional Rates Alternative. Malathion and carbaryl sprays would 

decrease the biodiversity more than diflubenzuron spray and carbaryl bait 

treatments. 

Impacts to non-target species from livestock grazing is unlikely to be 

affected by this alternative. 

Pesticide spills could expose wildlife to excessive levels of insecticide. 

APHIS maintains spill kits and insures that program personnel are familiar 

with procedures to mitigate effects associated with a spill. The risk of 

pesticide spills is roughly equivalent to the risk under the Conventional 

Rates Alternative. 

 

Negative impacts to nontarget organisms would be minimized by the 

implementation of the Treatment Guidelines (Appendix 1). 

Socioeconomic issues

A discussion of the socioeconomic impacts of grasshopper treatments are 

discussed on pages 61-74 of the 2002 FEIS. 

Under this alternative, there is a reduced risk that grasshopper outbreaks on 

rangeland would decrease the availability of forage for cattle and sheep. 

There is also a reduced risk of unchecked movement of grasshopper 

outbreaks into crops resulting in crop loss and additional expenditures for 

insecticidal control in the crop fields. The risk of grasshopper damage is 

somewhat higher than under the Conventional Rates Alternative. Because 

of reduced insecticidal rates and coverage, the RAATS Alternative requires 

ideal treatment conditions to effectively suppress an outbreak. 

Organic farmers face less risk of significant losses from grasshopper 

outbreaks on rangeland which could migrate to organic cropland. The risk 

of grasshopper damage is somewhat higher than under the Conventional 

Rates Alternative. Organic farmers would be put at increased risk of 

contamination from spray originating from grasshopper suppression 

programs. This risk is somewhat less than under the Conventional Rates 

Alternative because less insecticide is applied in a treatment area. APHIS 

39
OR-08-02 

will procure a listing of certified organic growers and determine buffers 

needed to protect organic farm operations. 

Air pollutants will be produced by fuel combustion in airplanes, vehicles, and 

machinery used in grasshopper control activities. Allowable emission levels 

and concentrations are enforced by state air control agencies. The amounts 

of these pollutants are not expected to exceed the normal background 

levels, and should have a negligible temporary effect on air quality. The 

effects on air quality will be roughly equivalent to the risk under the 

Conventional Rates Alternative. 

Increases in ozone concentration from the volatilization of pesticides and 

carriers are also expected to be negligible. The chemicals approved for use 

have low vapor pressure and are essentially nonvolatile. 

Negative socioeconomic impacts would be minimized by the implementation 

of the Treatment Guidelines (Appendix 1). 

Cultural resources and events

The availability of grasshoppers for fish bait and other human uses would be 

reduced from outbreak levels to more normal levels. The availability of 

grasshoppers would be somewhat greater than under Insecticide 

Applications at Conventional Rates Alternative. Persons using rangelands 

for recreation would respond to grasshoppers as they do under normal 

conditions versus under outbreak conditions. 

If Native American tribal lands will be involved in a program area, tribes will 

be consulted. Tribal representatives will have the opportunity to identify any 

cultural sites, such as native plants use areas, which might be impacted. 

Consultation will allow for mitigation of impacts to these sites, which will be 

roughly equivalent to the impact under the Conventional Rates Alternative. 

Artificial surfaces

Malathion and carbaryl spray can damage some painted surfaces. 

Automotive and sign finishes are susceptible to damage, and their owners 

could suffer economic loss repairing cosmetic damage. Public notice of 

malathion and carbaryl spray programs will include a warning about how to 

avoid potential damage. APHIS will consult with land managers if malathion 

or carbaryl spray was going to be used so they could elect to cover or 

remove signs during treatment. APHIS will consult with land managers to 

insure that Native American petroglyphs are excluded from spray areas. 

Probability of damage to artificial surfaces would be less in the RAATS 

Alternative than in the Conventional Rates Alternative. 

 

B. Other Environmental Considerations 

40
OR-08-02 

1. Cumulative Impacts 

 

Cumulative impact, as defined in the CEQ NEPA implementing regulations 

(40 CFR § 1508.7) “is the impact on the environment which results from the 

incremental impact of the action when added to the past, present, and 

reasonably foreseeable future actions regardless of what agency (Federal 

or non-Federal) or person undertakes such actions. Cumulative impacts 

can result from individually minor but collectively significant actions taking 

place over a period of time. The pesticide used and type of application will 

influence overall impacts. 

Depending on the specific exposure scenario and the nature of the available 

data, the consequences of cumulative exposures are assessed in a variety 

of ways in the 2002 FEIS. 

Some individuals may be exposed to more than one treatment type, either 

in their job as applicators or because they frequent areas where different 

types of treatment are applied. Such exposures are considered connected 

actions, that is, one or more actions that an individual may take that could 

affect the individual’s risk to the insecticides used to suppress 

grasshoppers. In addition, all individuals are exposed to a multitude of 

chemicals and biological organisms every day in foods, medicines, 

household products, and other environmental chemicals. 

Under APHIS programs, rangeland areas normally are only treated one time 

per season to suppress grasshopper populations. Label restrictions and 

cost share constraints limit projects to one treatment. If used, periodic 

treatments may have a longer term impact, since the exposure period is 

longer. However, the pesticides used breakdown relatively quickly in the 

environment and biological populations are quick to recover. 

Use of pesticides by land managers for other pest control operations (e.g.. 

noxious weed control or mosquito control) in rangeland areas receiving 

grasshopper treatments may result in cumulative impacts. Such a scenario 

is unlikely due to differing application areas and modes of action. APHIS will 

consult with land managers to determine if herbicides or insecticides have 

been utilized within the past year on any proposed spray area within the 

proposed suppression area. APHIS will not apply any insecticide in a 

manner that conflicts with EPA requirements regarding multiple treatments 

or to an area known to have been treated recently with a pesticide known to 

have harmful cumulative effects with carbaryl, diflubenzuron or malathion. 

Cumulative effects are not expected to significantly affect human health or 

the environment in program areas. Residues of the pesticides used are not 

expected to persist in the environment from year to year. If analysis of a 

41
OR-08-02 

proposed control area identifies potential cumulative impacts, these impacts 

will be further described in a supplement to this EA. 

2. Synergistic Effects 

There may be situations where it is appropriate to use one insecticide or 

formulation in one part of a treatment area and a different insecticide or 

formulation in another part of that same treatment area with all applications 

conducted according to the label directions. For example, ultra-low-volume 

(ULV) malathion may be used over the majority of a treatment area, but 

areas of special consideration may be treated with carbaryl bait. Should 

these situations occur, no area would be treated with more than one 

insecticide, except for minor overlap in the border area, and there would be 

no mixing or combination of insecticides. 

APHIS will not apply any insecticide in a manner that conflicts with EPA 

requirements regarding multiple treatments or to an area known to have 

been treated recently with a pesticide known to have synergistic effects with 

carbaryl, diflubenzuron or malathion. If analysis of a proposed control area 

identifies potential synergistic effects, these effects will be further described 

in a supplement to this EA. 

Diflubenzuron

Diflubenzuron is only reported to be synergistic with the defoliant DEF. 

Because the defoliant is unlikely to be applied concurrently with 

grasshopper suppression treatments, there is minimal risk of synergistic 

effects (2002 FEIS p B-16). 

Carbaryl

The only studies of chemical interactions with carbaryl indicate that toxicity 

of organophosphates combined with carbaryl is additive not synergistic 

(2002 FEIS p B-13). 

Malathion

Although the toxicity of malathion may be potentiated by some other 

organophosphates and carbamates, it is impossible to predict multiple 

exposures and synergism from applications not related to this program. 

Organophosphate insecticides are routinely used in mosquito control 

programs and on crops in some areas near proposed treatment areas. 

There is some potential for synergistic effects resulting from the combination 

of malathion and inadvertent simultaneous pesticide application by the 

public; however, notification of residents adjacent to treatment areas about 

program treatments helps to minimize this risk. (2002 FEIS p B-21). 

3. Inert Ingredients and Metabolites 

42
OR-08-02 

A full discussion of inert ingredients and metabolites is found in the 2002 

FEIS pp B-12, B-15, and B-20. 

4. Executive Order No. 12898, Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations 

Consistent with Executive Order No. 12898, consideration has been made 

to the potential for disproportionately high and adverse human health or 

environmental effects on any minority and low-income populations. 

Although specific data are not available, observations indicate that 

Hispanics and Asians are the minority groups which would be most 

impacted by the suppression programs because of their involvement in 

agricultural production systems. 

No Action Alternative may cause low income and minority farm workers to 

be exposed to additional insecticides applied to cropland. No Action 

Alternative may increase costs of operation for low income and minority 

farm operators. 

Insecticide Applications at Conventional or RAAT Rate Alternative would be 

expected to have no disproportionate impact on minority or low income 

populations. 

Human health effects on individuals with poor nutritional status are analyzed 

in the 2002 EIS pp B-24, B-27, and B-28. 

5. Executive Order No. 13045, Protection of Children from 

Environmental Health Risks and Safety Risks 

Consistent with Executive Order No. 13045, APHIS has considered the 

potential for disproportional high and adverse environmental health and 

safety risks to children. 

The human health risk assessment for the 2002 FEIS analyzed the effects 

of exposure to children from the three insecticides. Based on review of the 

insecticides and their use in the grasshopper program, the risk assessment 

concluded that the likelihood of children being exposed to insecticides is 

very slight and that no disproportionate adverse effects to children are 

anticipated over the negligible effects to the general population. Treatments 

are primarily conducted on open rangelands where children would not be 

expected to be present during treatment or enter should there be any 

restricted entry period after treatment. No urban areas or schools would be 

subject to treatment under the proposed action. 

43
OR-08-02 

The potential for impacts of pesticides on children would be minimized by 

the implementation of the Operating Procedures (Appendix 1). 

6. Executive Order 13186, Responsibilities of Federal Agencies to 

Protect Migratory Birds 

In accordance with various environmental statutes, APHIS routinely 

conducts programs in a manner that minimizes impact to the environment, 

including any impact to migratory birds. In January 2001, President Clinton 

signed Executive Order 13186 to ensure that all government programs 

protect migratory birds to the extent practicable. To further its purposes, 

this Executive Order requires each agency with a potential to impact 

migratory birds to enter into an MOU with FWS. In compliance with the 

Executive Order, APHIS is currently working with FWS to develop such an 

MOU. 

7. Bald and Golden Eagle Protection Act 

On June 28, 2007 the Interior Department took the American bald eagle off 

the Endangered Species List. The bald eagle will still be protected by the 

Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act. 

The Bald Eagle Protection Act prohibits the take, transport, sale, barter, 

trade, import and export, and possession of eagles, making it illegal for 

anyone to collect eagles and eagle parts, nests, or eggs without a permit. 

As listed in the National Bald Eagle Management Guidelines (USFWS, May 

2007) the following mitigation measures will be followed when practical, 

unless the land managing agency requires more strict measures. 

Under Category G, Helicopters and fixed-wing aircraft will not be used within 

1000 feet of an active nest during the breeding season. No buffer is 

necessary around nest sites outside the breeding season. 

In addition, Category A (Agriculture) and Category D (Off Road Vehicle Use) 

both provide the same guidance for use of ATV's or trucks. No buffer is 

necessary around nest sites outside the breeding season. During the 

breeding season if the activity will not be visible from the nest, off-road 

vehicles will not be operated within 330 feet of the nest. If the activity will be 

visible from the nest, off-road vehicles will not be operated within 660 feet of 

the nest. 

8. Endangered Species Act 

Policies and procedures for protecting endangered and threatened species 

of wildlife and plants were established by the Endangered Species Act 

(ESA) of 1973, as amended (16 United States Code (U.S.C.)  1531 et 

seq.). The ESA is designed to ensure the protection of Endangered and 

44
OR-08-02 

Threatened species and the habitats upon which they depend for survival. 

Regulations implementing the provisions of the ESA have been issued. In 

accordance with Section 7 of the ESA, consultation is to be conducted for 

any action authorized, funded, or carried out by a Federal agency that may 

affect listed endangered or threatened species or their habitats. APHIS also 

includes proposed species in their consultations. Consultations are 

conducted with Fish and Wildlife Service (FWS), Department of Interior, for 

terrestrial species and most freshwater aquatic species, and with NOAA 

Fisheries, U.S. Department of Commerce, for marine and anadromous 

species.

The most recent national biological opinion (BO) on the grasshopper 

program issued by FWS was issued in October 3, 1995. APHIS prepared a 

national biological assessment (BA) for the 1998 program, but no BO was 

issued because control programs were not anticipated that year. In 

February 2005 APHIS presented a Programmatic Biological Assessment 

(BA), along with a threat matrix, for all listed species, to FWS for comment. 

FWS responded in June 2005 with a request for more information on toxicity 

data, buffer models, and long-term effects from these programs. Although 

this National Consultation is proceeding, a Programmatic Biological Opinion 

will not likely be issued in time for grasshopper/Mormon cricket suppression 

programs in 2008. In order to comply with section 7 requirements APHIS will 

conduct informal consultations with FWS, and NOAA Fisheries, locally. The 

1995 BO and 1998 BA will be used as a basis for these local consultations 

and are incorporated into this EA by reference. Locally, a BA was completed 

to address effects to Oregon Threatened and Endangered (T & E) species 

listed since the 1995 BO, to include protective measures for the use of 

diflubenzuron, a chemical alternative not consider in the 1995 BO, and to 

include mitigation measures for the RAAT methodology, also not considered 

in the 1995 BO. This local BA is incorporated into this EA by reference. 

APHIS has initiated informal consultation with FWS, Oregon State Office 

and Klamath Falls Office. In the past, concurrence letters were received 

annually from FWS for 2003-2007. Informal consultation for 2008 is 

currently ongoing to arrive at an effects determination for each listed 

species and corresponding critical habitat which occur in the proposed 

suppression (action) area of Oregon. Where it is determined that the action 

may affect a listed species or its habitat, the BA specifies mitigation 

measures that are designed to reduce the potential effects to the point 

where they are not likely to adversely affect the listed species or its habitat.

These consultations will result in concurrences to APHIS’ effects 

determinations in the BA. The BA, FWS letters of concurrence and other 

ESA related correspondence are (will be) included in Appendix 3, and can 

also be found online at the ODA, Plant Division website; 

http://www.oregon.gov/ODA/PLANT/IPPM/index.shtml.

45
OR-08-02 

There are no anadromous fishes requiring consultation with NOAA Fisheries 

listed in Klamath County. 

The following table is a summary of protection measures developed for 

federally listed species that may be associated with grasshopper 

suppression programs in Klamath County, Oregon. These measures were 

agreed to by APHIS through Formal Section 7 Consultation with the US Fish 

and Wildlife Service and found in the 1995 FWS Biological Opinion (BO), or 

through local informal consultation with FWS for the use of diflubenzuron, 

the RAAT methodology, and species listed since the 1995 national BO. 

Protection measures required for a “not likely to adversely affect” 

determination, and findings of “no effect,” previously approved by FWS, are 

referenced by the date of the biological opinion (ex. FWS mm/dd/yy). 

Measures developed between APHIS and FWS during local consultation 

are referenced by year (ex. FWS 2004). This document also updates these 

references by using information provided by FWS to include current 

nomenclature and changes in listing status. 

Table 2 Current and Proposed Protection Measures and 

Determinations to Protect Threatened (T) or Endangered (E) 

Species

Name, 

Species, and 

Status, 

Determination Protective 

Measures from 

1995 Biological 

Opinion

Proposed Protective 

Measures for Oregon

Mammals

Canada Lynx 

(T) 

Lynx Canadensis 

No Effect Listed since 1995 Known ranges and travel 

corridors in Oregon will not 

be treated. No Effect. 

(FWS March 20, 2007, 

pending for 2008) 

Birds

Northern 

spotted owl (T) 

Strix occidentalis 

caurin 

No effect Occurs primarily in 

old growth forest and 

not in rangeland. 

(FWS 08/03/91) 

Known ranges in Oregon 

will not be treated. No 

effect. (FWS March 20, 

2007, pending for 2008)

Fish

Bull trout (T) 

Salvelinus 

confluentus 

NLAA Listed since 1995 

Lost River 

sucker (E) 

Deltistes luxatus 

NLAA Buffers around areas 

of occurrence of 0.5 

mile for the use of 

malathion and 0.25 

The proposed action 

includes a protective (no 

application of pesticides, 

bait and liquid) buffer from 

the edge of the stream or 

water body containing 

standing or flowing water 

46
OR-08-02 

Shortnose 

sucker (E) 

Chasmiste 

brevirostris 

NLAA mile for the use of 

aerially applied 

carbaryl. Within the 

buffers, only carbaryl 

bait will be used. 

(FWS 07/26/88) 

at the time of application, 

out to 0.5 mile for aerial 

application of pesticides 

diflubenzuron, carbaryl, 

and malathion; and 500 

feet for ground application. 

The buffers will apply to 

habitats occupied by these 

species or adjacent 

aquatic habitat designated 

as critical habitat for the 

listed species. (FWS March 

20, 2007, pending for 2008)

Plants

Applegate’s 

milk-vetch (E)

Astragalus 

applegatei 

NLAA Aerial applications of 

ULV (spray) 

pesticides will not be 

used within 3 miles of 

these species 

occupied habitats. 

Within the 3 mile 

buffer, only carbaryl 

bait will be used. 

(FWS 09/24/92, 

06/01/87) 

Aerial applications of liquid 

pesticides will not be used 

within 3 miles of these 

species occupied habitats. 

Within the 3 mile buffer, 

only carbaryl bait will be 

used. No ground bait 

application within 50 feet of 

known locations or critical 

habitat. (FWS March 20, 

2007, pending for 2008)

9. Additional Protective Measures Which Are Not Included in FY 2007 

Treatment Guidelines (Appendix 1) 

• APHIS will perform on-site examination of proposed suppression spray 

areas to determine the presence of water (defined in Appendix 1). 

• Biological control release sites will be considered on an individual basis in 

consultation with the land manager to determine which insecticides might be 

used and/or how much buffer space should be allowed. 

• APHIS will obtain a listing of certified organic growers and determine 

buffers needed to protect organic farm operations on an individual basis. 

• Prior to making a final decision on whether to treat and which method to 

use, APHIS will request the land manager to provide information on the 

existence and location of any sensitive areas or species of concern. FWS 

will be contacted to determine the location of any listed or proposed T&E 

species. The appropriate mitigation measures will be applied. When treating 

state or federal land, APHIS will consider requests of the land manager with 

47
OR-08-02 

respect to candidate species, non-listed species of concern, critical habitats, 

and other areas of concern. 

10. Monitoring 

APHIS has developed an Environmental Monitoring Plan (EMP) for the 

2008 Rangeland Grasshopper and Mormon Cricket Suppression Program. 

This document was prepared by the APHIS Environmental Monitoring 

Team, and is incorporated in this EA by reference. 

Monitoring involves the evaluation of various aspects of the grasshopper 

suppression programs. There are three aspects of the programs that may 

be monitored. The first is the efficacy of the treatment. APHIS will 

determine how effective the application of an insecticide has been in 

suppressing the grasshopper population within a treatment area and will 

report the results in a Work Achievement Report to the Western Region and 

the land manager. 

The second area included in monitoring is safety. This includes ensuring 

the safety of the program personnel through medical monitoring conducted 

specifically to determine risks of a hazardous material. (APHIS Safety and 

Health Manual (USDA, APHIS, 2004). 

The third area of monitoring is environmental monitoring. APHIS Directive 

5640.1 commits APHIS to a policy of monitoring the effects of Federal 

programs on the environment. Environmental monitoring includes such 

activities as checking to make sure the insecticides are applied in 

accordance with the labels, and that sensitive sites and organisms are 

protected. The environmental monitoring recommended for grasshopper 

suppression programs involves monitoring sensitive sites such as bodies of 

water used for human consumption or recreation, or which have wildlife 

value, habitats of T&E species, habitats of other sensitive wildlife species, 

edible crops, and any sites for which the public has expressed concern or 

where humans might congregate (e.g., schools, parks, hospitals). 

The need for specific environmental monitoring on any suppression 

programs in Oregon will be based upon APHIS current policy (EMP), 

consultation with land managers, and consideration of sensitive areas for 

T&E or other species of concern. 

V. Literature Cited 

48
OR-08-02 

Adams, J.S., Knight, R.L., McEwen, L.C., and George, T.L., 1994. Survival and 

growth of nestling vesper sparrow exposed to experimental food reductions. 

The Condor 96:739–748. 

Beyers, D.W., Farmer, M.S., and Sikoski, P.J., 1995. Effects of rangeland aerial 

application of Sevin-4-Oil® on fish and aquatic invertebrate drift in the Little 

Missouri River, North Dakota. Archives of Environmental Contamination and 

Toxicology 28:27–34. 

Bradbury, Bill. 2001. Oregon Blue Book 2001-2002. Oregon Secretary of State, 

Portland, Oregon. 465pp. 

Catangui, M.A., Fuller, B.W., and Walz, A.W., 1996. Impact of Dimilin® on 

nontarget arthropods and its efficacy against rangeland grasshoppers. In 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

1996. Grasshopper Integrated Pest Management User Handbook, Tech. Bul. 

No. 1809. Sec. VII.3. Washington, DC. 

Connelly, J. W. 1994. Sage Grouse Ecology. Proj. no. W-160-R-21, Completion 

Report Idaho Department of Fish and Game. 90pp. 

Dobroski, C.J., O'Neill, E.J., Donohue, J.M., and Curley, W.H., 1985. Carbaryl: a 

profile of its behavior in the environment. Roy F. Weston, Inc., West Chester, 

PA, and V.J. Ciccone and Associates, Inc., Woodbridge, VA. 

Eisler, R., 2000. Handbook of chemical risk assessment: health hazards to 

humans, plants, and animals. Lewis Publishers, New York. 

Emmett, B.J., and Archer, B.M, 1980. The toxicity of diflubenzuron to honey bee 

(Apis melifera L.) Colonies in apple orchards. Plant Pathology 29:637–183. 

EPA – see U.S. Environmental Protection Agency 

Hazardous Substances Database, 1990. On-line database. National Library of 

Medicine, Bethesda, MD. 

Howe, Frank P., et al. 2000. Diet Switching and Food Delivery by Shrubsteppe 

 Passerines in Response to an Experimental Reduction in Food. Western 

 North American Naturalist 60:139-154. 

HSDB – see Hazardous Substances Database 

Martin, Pamela A., et al. 2000. Effects of Two Grasshopper Control Insecticides 

on Food Resources and Reproductive Success of Two Species of Grassland 

Songbirds. Environmental Toxicology and Chemistry Vol. 19. No. 12: 2987-

2996. 

49
OR-08-02 

Mayer, F.L., Jr, and Ellersieck, M.C., 1986. Manual of acute toxicity: 

interpretation and data base for 410 chemicals and 66 species of freshwater 

animals. Resource Publication 160. Department of the Interior, Fish and 

Wildlife Service, Washington, DC. 

McEwen, L.C., Althouse, C.M., and Peterson, B.E., 1996a. Direct and indirect 

effects of grasshopper integrated pest management (GHIPM) chemicals and 

biologicals on nontarget animal life. In U.S. Department of Agriculture, 

Animal and Plant Health Inspection Service, 1996. Grasshopper Integrated 

Pest Management User Handbook, Tech. Bul. No. 1809. Sec. III.2. 

Washington, DC. 

McEwen, L.C., Petersen, B.E., and Althouse, C.M., 1996b. Bioindicator species 

for evaluating potential effects of pesticides on threatened and endangered 

wildlife. In U.S. Department of Agriculture, Animal and Plant Health 

Inspection Service, 1996. Grasshopper Integrated Pest Management User 

Handbook, Tech. Bul. No. 1809. Sec. III.7. Washington, DC. 

Meacham, J.E., E. B. Steiner, et. al.. 2001. Atlas of Oregon, Second Edition. 

University of Oregon Press, UO Infographics Lab, Department of Geology. 

Eugene, Oregon. CD-ROM. 

Oregon Department of Agriculture and USDA, National Agricultural Statistics 

Service. 2002. 2001-2002 Oregon Agriculture and Fisheries Statistics. 80pp. 

Opdycke, J.C., Miller, R.W., and Menzer, R.E., 1982. Metabolism and fate of 

diflubenzuron in swine. Journal of Agricultural Food and Chemistry 30:1223–

1227. 

Paige, Christine & Ritter, Sharon A. 1999. Birds in a Sagebrush Sea: Managing 

 Sagebrush Habitats for Bird Communities. Partners in Flight, Western 

Working Group. 

Quinn, M.A., 1996. Impact of control programs on nontarget arthropods. In U.S. 

Department of Agriculture, Animal and Plant Health Inspection Service, 1996. 

Grasshopper Integrated Pest Management User Handbook, Tech. Bul. No. 

1809. Sec. III.3. Washington, DC. 

Schroeder, W.J., Sutton, R.A., and Beavers, L.B., 1980. Diaprepes abbreviatus: 

Fate of diflubenzuron and effect on nontarget pest and beneficial species 

after application to citrus for weevil control. J. Econ. Entomol. 73:637–638. 

Skold, M.D. and Davis, R.M., 1995. A Rangeland Grasshopper Insurance 

Program. Journal of Agricultural and Resource Economics. 20(1):1-10. 

50
OR-08-02 

Tsuda, T., Aoki, S., Kojima, M., and Harada, H., 1989. Bioconcentration and 

excretion of diazinon, IBP, malathion, and fenitrothion by willow shiner. 

Toxicology and Environmental Chemistry 24:185–190. 

USDA – see U.S. Department of Agriculture 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

2004. Safety and Health Manual. Safety, Health, and Environmental Staff, 

Riverdale, MD. June 30, 2004. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

2002. Rangeland Grasshopper and Mormon Cricket Suppression Final 

Environmental Impact Statement. October 15, 2002. [online] available: 

http://www.aphis.usda.gov/plant_health/plant_pest_info/grasshopper/index.sh

tml. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

2008. APHIS Rangeland Grasshopper/Mormon Cricket Suppression Program 

Aerial Application Statement of Work. January 2008 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

2008. Site-Specific Environmental Assessment, Rangeland and Mormon 

Cricket Suppression Program, Oregon, No. OR-08-01. February 25, 2008. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

1998. Biological Assessment for Rangeland Grasshopper Cooperative 

Management Program. April 28, 1998. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

2008. 2008 Biological Assessment – Fish & Wildlife Service for USDA APHIS 

Rangeland Grasshopper/Mormon Cricket Suppression Programs in Oregon. 

February, 2008. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

2006. 2006 Biological Assessment for Rangeland Grasshopper/Mormon 

Cricket Suppression Programs in Oregon – NOAA Fisheries. March 9, 2006. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

2008. Environmental Monitoring Plan 2008 Rangeland and Mormon Cricket 

Suppression Program. January 2008. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

1999. APHIS Directive 5600.3, Evaluating APHIS programs and activities for 

ensuring protection of children from environmental health risks and safety 

risks. September 3, 1999. U.S. Department of Agriculture, Animal and Plant 

51
OR-08-02 

Health Inspection Service, Riverdale, MD. [online] available: 

http://www.aphis.usda.gov/library/directives. 

U.S. Environmental Protection Agency, 1993. Carcinogenicity peer review of 

carbaryl, 1–napthyl n–methylcarbamate. MRID 421889—01, 02. 

Memorandum from Ray Landolt, Toxicological Branch II, October 7, 1993, 35 

pp 

U.S. Environmental Protection Agency, 2000. Cancer Assessment Document 

#2. Evaluation of the carcinogenic potential of malathion. Report of the 12 

April 2000 meeting and its 29 attachments. April 28, 2000. U.S. 

Environmental Protection Agency, Washington, DC. 

U.S. Department of Interior, Fish and Wildlife Service, 1995. Biological Opinion 

for Rangeland Grasshopper Cooperative Management Program. July 21, 

1995. Ladd, Wilber N. Jr., Acting Regional Director, FWS Region 6. 

U.S. Department of Interior , Fish and Wildlife Service, 2007. National Bald Eagle 

Management Guidelines. U.S. Department of Interior, Fish and wildlife Service. 

May 2007. [online] available: 

http://www.fws.gov/migratorybirds/issues/BaldEagle/NationalBaldEagleManagem

entGuidelines.pdf

VI. Listing of Agencies and Persons Consulted 

McMaster, Kemper, State Supervisor, Oregon Fish and Wildlife Office, US Fish 

and Wildlife Service, 2600 SE 98th Ave., Portland, OR 97266 

Gilbert, Nancy, Field Supervisor, Bend Fish and Wildlife Office, US Fish and 

Wildlife Service, 20310 Empire Ave., Suite A100, Bend, OR 97701 

Buerger, Theodore, Manager, Environmental Contaminants Division, Oregon 

Fish and Wildlife Office, US Fish and Wildlife Service, 2600 SE 98th Ave., 

Portland, OR 97266 

Murray, Eric, Biologist, LaGrande Field Office, NOAA Fisheries, 3502 Highway 

30, LaGrande, OR 97850 

Ford, Walter, Refuge Manager, Klamath Basin National Wildlife Refuges, H.C. 

63, Box 303, Chiloquin, OR 97624. 

Hawkes, Tony, Environmental Contaminants Specialist, US Fish and Wildlife 

Service, 6610 Washburn Way, Klamath Falls, OR 97603 

52
OR-08-02 

Mullis, Curtis, Field Supervisor, Klamath Fish and Wildlife Office, US Fish and 

Wildlife Service, 6610 Washburn Way, Klamath Falls, OR 97603-9365 

Murray, Eric, Fisheries Biologist, LaGrande Field Office, NOAA Fisheries, 3502 

Highway 30, LaGrande, OR 97850 

Jackson, Dick, Entomologist, Oregon Department of Agriculture, PO Box 723, 

Hermiston, OR 97838 

Johnson, Kathleen, Plant Pest and Disease Supervisor, Oregon Department of 

Agriculture, 635 NE Capitol, Salem, OR 97301-2532 

Tehan, Mike, Branch Chief, Oregon Habitat Division, NOAA Fisheries, 525 NE 

Oregon, Suite 500, Portland, OR 97323 

Brown, Miles, Natural Resource Specialist, Oregon State Office, Bureau of Land 

Management, 333 SW 1st Avenue, Portland, Oregon 97204 

Hilken, Thomas and Randy Eyre, Rangeland Management Specialist, Vale 

District Office, Bureau of Land Management, 100 Oregon Street, Vale, OR 

97918 

Rassussen, Tom, Resource Area Manager, Lakeview District Office, Bureau of 

Land Management, HC 10 Box 337, 1301 South G St., Lakeview, OR 97630 

Richman, Leslie, Rangeland Management Specialist, Burns District Office, 

Bureau of Land Management, 28910 Hwy 20 West, Hines, Oregon 97738 

Rogg, Helmuth, Entomologist, Oregon Department of Agriculture, 10507 N. 

McAllister, LaGrande, OR 97850 

Thomas, Larry, Environment Protection Specialist, Prineville District Office, 

Bureau of Land Management, P. O. Box 550 - 3050 NE Third, Prineville, OR 

97754 

Meyer, Ralph, County Executive Director, USDA, Farm Service Agency, 256 

Warner Milne Road, Oregon City, OR 97045 

Bearden, David A., Deputy Director, Spokane Regional Office, USDA Risk 

Management Agency, 112 N University Rd, Suite 205, Spokane, WA 99206 

Pontes, Lena, Farm Program Coordinator, Oregon Tilth, 470 Lancaster Drive NE, 

Salem, OR 97301 

Tweten, Randy, Eastern Oregon Team Leader, NOAA Fisheries, 3502 Hwy 30, 

LaGrande, OR 97850 

53
OR-08-02 

Sam Johnson, IPM Coordinator, U.S. Fish and Wildlife Service, 9317 Highway 

99, Suite D, Vancouver, WA 98665 

Simmons, Jennifer, County Executive Director, USDA Farm Service Agency, 

Klamath Falls, OR 

Weist, Randy, Range Management Specialist, Rangeland Manager, Division of 

State Lands, State of Oregon, 20300 Empire Avenue, Suite 1, Bend, OR 

97701 

Laye, Doug, Fish and Wildlife Biologist, Klamath Fish and Wildlife Office, US Fish 

and Wildlife Service, 6610 Washburn Way, Klamath Falls, OR 97603-9365 

Dyer, Thomas H., District Manager, Burns District Office, USDI Bureau of Land 

Management, 28910 Hwy 20 West, Hines, OR 97738 

54