United States 

Department of 

Agriculture 

Forest 

Service 

March 2008 

Final Environmental 

Impact Statement 

Site-Specific Invasive Plant Treatments for 

Mt. Hood National Forest and Columbia 

River Gorge National Scenic Area in Oregon, 

including Forest Plan Amendment #16 

Mt. Hood National Forest and Columbia River Gorge 

National Scenic Area 

Clackamas, Hood River, Multnomah, and Wasco Counties 
Guiding Principles for Invasive Plant Treatment 

Preamble 

Invasive plants currently infest up to 13,000 acres of land on the Mt. Hood National 

Forest and the Columbia River Gorge National Scenic Area. These aggressive plants 

are spreading at the rate of 8 to 12 percent each year, and have the capacity to 

overwhelm and even wipe out native plant species. 

The USDA Forest Service proposes to control, contain, or eradicate these invasive 

plants using a variety of treatment methods. We have developed the following 

Guiding Principles to provide an overall framework for applying these treatments. 

Invasive plants are threatening healthy, native communities and function. Treatment 

of existing invasive plants and restoration of native plant communities are needed to 

meet the Forest and Scenic Area’s land management goals and objectives. We will 

effectively treat invasive plants while minimizing adverse effects of treatment. 

Guiding Principles 

• In treating invasive plants, our highest priority will be to minimize risks to 

human health; drinking water; and botanical, wildlife or aquatic species. 

• Herbicide treatments will be used when necessary and in combination with 

non-herbicide methods to increase treatment and cost effectiveness. 

• We will notify the public prior to using herbicides through announcements in 

local newspapers and by posting treatment areas at all access points. 

• This decision does not authorize aerial application of herbicides. 

• Only herbicides analyzed in this environmental impact statement (EIS) will be 

used. 

• We will employ rapid response to new invaders using treatment methods and 

guidelines established within this EIS. 

• Site restoration will be considered in invasive plant treatment prescriptions. 
Site-Specific Invasive Plant Treatments 

Site-Specific Invasive Plant Treatments for 

Mt. Hood National Forest and 

Columbia River Gorge National Scenic Area in Oregon, 

Including Forest Plan Amendment #16 

Final Environmental Impact Statement 

Clackamas, Hood River, Multnomah and Wasco Counties 

Lead Agency: USDA Forest Service 

 Responsible Official: Gary L. Larsen, Forest Supervisor 

Mt. Hood National Forest 

16400 Champion Way 

Sandy, OR 97055 

Daniel T. Harkenrider, Area Manager 

Columbia River Gorge National Scenic Area

902 Wasco Avenue 

Suite 200 

Hood River, OR 97031 

For Information and Comments: Jennie O’Connor, Invasive Plant EIS 

Mt. Hood National Forest 

16400 Champion Way 

Sandy, OR 97055 

(503) 668-1645 (phone) 

(503) 668-1413 (fax) 

jmoconnor@fs.fed.us 

1 
Final Environmental Impact Statement 

Abstract 

The Mt. Hood National Forest (Forest) and Columbia River Gorge National Scenic Area in 

Oregon (Scenic Area) are proposing invasive plant treatments on 208 sites (approximately 

13,000 acres). The purpose of this project is to eradicate, contain and control invasive plant 

infestations, to reverse the negative impacts caused by invasive plants, and to restore healthy, 

native plant communities and functions at the impacted sites in a cost-effective manner that 

meets current management direction. The establishment and spread of invasive plants can be 

slowed, with timely action. The EIS tiers to the Pacific Northwest Region Invasive Plant 

Program – Preventing and Managing Invasive Plants Record of Decision (USDA Forest 

Service, 2005b) and Final Environmental Impact Statement (USDA Forest Service, 2005a). 

Three alternatives are considered: 

• No Action Alternative (Alternative 1), 

• Proposed Action (Alternative 2), and 

• Restricted Herbicide Use Alternative (Alternative 3). 

The No Action Alternative would continue current invasive plant management occurring under 

existing NEPA documents on the Forest and Scenic Area. The Proposed Action would utilize 

integrated weed management treatments. The treatments include: 30 acres of herbicide only 

treatment; 50 acres of manual and mechanical treatments; 310 acres of herbicide plus mechanical 

treatments; 327 acres of herbicide plus manual treatments; 1510 acres of herbicide plus manual, 

mechanical, and cultural; 10,736 acres of herbicide plus manual and mechanical treatments. 

Additional acres would be added through an early detection / rapid response strategy (EDRR). 

All sites have an associated restoration strategy. The Restricted Herbicide Use Alternative 

reduces the amount of herbicide treatments, but retains manual, mechanical and cultural 

treatments on all 13,000 acres. 

Implementation of the two action alternatives is expected to reduce the rate of spread of existing 

and future infestations of invasive plants on the Forest and Scenic Area. All of the action 

alternatives would increase the cost and effectiveness of invasive plant management. All of the 

action alternatives protect human health and the environment. 

2 
Site-Specific Invasive Plant Treatments 

i 

Table of Contents 

CHAPTER 1: PURPOSE AND NEED FOR ACTION ...............................................................................1-1 

1.1. Background.............................................................................................................................1-3 

1.2. Purpose and Need for Action .................................................................................................1-5 

Desired Future Condition .............................................................................................. 1-9

1.3. Proposed Action ...................................................................................................................1-10 

1.4. Management Direction .........................................................................................................1-19 

1.5. Management Standards and Guidelines ..............................................................................1-21 

1.6. Decision Framework.............................................................................................................1-22 

1.7. Public Involvement ...............................................................................................................1-23 

1.8. Issues ...................................................................................................................................1-24 

Key Issues 

Key Issue 1 – Treatment Effectiveness .................................................................. 1-25

Key Issue 2 – Economic Efficiency......................................................................... 1-26

Key Issue 3 – Water Quality and Aquatic Organisms............................................... 1-26

Resolved Issues

Human Health and Safety..............................................................................................1-27 

Accidental Herbicide Spills.............................................................................................1-27 

No Herbicide Treatment in Municipal Watersheds ........................................................1-28 

Public Notification ................................................................................................. 1-28

Tracking Issues

Native Plant Communities ..................................................................................... 1-28

Wildlife Species .................................................................................................... 1-29

Soil Productivity.................................................................................................... 1-29

Tribal/Treaty Rights and Environmental Justice ...................................................... 1-29

Issues Outside the Scope

No Invasive Plant Treatments................................................................................ 1-30

Working on Other Ownerships............................................................................... 1-30

Implementing Invasive Plant Management ............................................................. 1-31

1.9. What is Not Included ............................................................................................................1-31 
Final Environmental Impact Statement 

CHAPTER 2: ALTERNATIVES, INCLUDING THE PROPOSED ACTION ..............................................2-1 

2.1. Alternatives Considered in Detail ...........................................................................................2-3 

2.1.1. Alternative Development Process ..........................................................................................2-3 

2.1.2. Alternative 1 – No Action Alternative......................................................................................2-9 

2.1.3. Alternative 2 – The Proposed Action....................................................................................2-18 

Treatment Methods ..............................................................................................................2-20 

Species to be Treated ..........................................................................................................2-24 

Treatment Strategies ............................................................................................................2-26 

Invasive Plant Treatment Prescriptions ........................................................................ 2-26

Site Restoration Strategies.......................................................................................... 2-31

Early Detection / Rapid Response ............................................................................... 2-32

Invasive Plant Treatment Prescription Assumptions............................................................2-38 

Forest Plan Amendment.............................................................................................. 2-39

2.1.4. Alternative 3 – Restricted Herbicide Use Alternative ...........................................................2-41 

Invasive Plant Treatment Prescriptions ........................................................................ 2-41

Invasive Plant Treatment Prescription Assumptions............................................................2-50 

2.2. Project Design Criteria for Alternatives 2 and 3 ...................................................................2-51 

2.3. Monitoring Framework for Alternatives 2 and 3....................................................................2-60 

2.4. Comparison of Alternatives ..................................................................................................2-62 

2.5. Alternatives Considered, But Dropped from Further Analysis..............................................2-66 

2.5.1. Prevention.............................................................................................................................2-66 

2.5.2. No Herbicide Use .................................................................................................................2-68 

2.5.3. No Amendment to the Mt. Hood Forest Plan .......................................................................2-69 

2.5.4. Maximize Cost Efficiency......................................................................................................2-71 

2.5.5. Maximize Worker Jobs .........................................................................................................2-71 

CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ....................3-1 

3.1. Life of the Project....................................................................................................................3-1 

3.2. General Existing Conditions ...................................................................................................3-2 

3.2.1. Treatment Area Site Descriptions...........................................................................................3-2 

3.2.2. Invasive Plant Species and Infestations.................................................................................3-3 

3.2.3. Rate of Spread and Mechanism of Invasion ..........................................................................3-6 

3.2.4. Ownership Patterns and Herbicide Use on Other Lands .......................................................3-7 

3.3. Herbicides, Adjuvants, Surfactants and Inert Ingredients ......................................................3-9 

3.3.1 Herbicide Risk Assessments.................................................................................................3-9 

3.3.2. Herbicide Toxicology Terminology ....................................................................................... 3-13 

ii 
3.3.3. Risk Reduction Framework .................................................................................................. 3-14 

3.3.4. Adjuvants, Surfactants and Inert Ingredients ....................................................................... 3-15 

3.3.5. Definitions of Chemical Types.............................................................................................. 3-15 

3.3.6. Nonylphenol Polyethoxylate (NPE) ...................................................................................... 3-15 

3.3.7. Analysis of Sufactants, Adjuvants and Inert Ingredients ...................................................... 3-16 

3.3.8. Incomplete and Unavailable Information..............................................................................3-16

3.4. Basis of Cumulative Effects Analysis ...................................................................................3-17 

3.5. Human Health and Safety ....................................................................................................3-24 

3.5.1 Introduction...........................................................................................................................3-24 

3.5.2 Existing Conditions ...............................................................................................................3-25 

3.5.3 Methodology .........................................................................................................................3-25 

3.5.4 Direct and Indirect Effects ....................................................................................................3-26 

3.5.4.1 Worker Herbicide Exposure Analysis ...............................................................3-26 

3.5.4.2 Public Herbicide Exposure Analysis – Direct Contact, Special Forest 

Products, Drinking Water, and Endocrine Disruption .......................................3-27 

3.5.5 Comparison of Risks of Human Health Effects among Alternatives Considered in Detail ..3-30 

3.5.6 Cumulative Effects................................................................................................................3-31 

3.5.7 Management Standards and Guidelines ..............................................................................3-32 

3.5.8 Incomplete and Unavailable Information..............................................................................3-33 

3.6. Botany and Treatment Effectiveness ...................................................................................3-33 

3.6.1 Existing Conditions ...............................................................................................................3-33 

3.6.2 Direct/Indirect Effects ...........................................................................................................3-35 

3.6.3 Spread of Invasive Plants to Neighboring Ownerships ........................................................3-52 

3.6.4 Cumulative Effects................................................................................................................3-53 

3.6.5 Management Standards and Guidelines ..............................................................................3-58 

3.6.6 Incomplete and Unavailable Information..............................................................................3-58 

3.7. Economic Efficiency .............................................................................................................3-59 

3.7.1 Existing Conditions ...............................................................................................................3-59 

3.7.2 Economic Analysis ...............................................................................................................3-61 

3.7.3 Jobs Created Analysis..........................................................................................................3-69 

3.7.4 Management Standards and Guidelines ..............................................................................3-71 

3.7.5 Incomplete and Unavailable Information..............................................................................3-71 

3.8. Soil Productivity ....................................................................................................................3-71 

3.8.1 Existing Conditions.........................................................................................................3-71 

3.8.2 Analysis Area, and Applicable Standards and Guidelines.............................................3-72 

3.8.3 Direct/Indirect Effects: Alternative 1 – No Action...........................................................3-73 

3.8.4 Direct/Indirect Effects: Alternatives 2 & 3 – Proposed Action and 

Restricted Herbicide Use Alternatives ...........................................................................3-77 

iii 
Final Environmental Impact Statement 

3.8.5. Alternatives Comparison................................................................................................3-85 

3.8.6 Cumulative Effects .........................................................................................................3-86 

3.8.7 Management Standards and Guidelines........................................................................3-87 

3.8.8 Incomplete and Unavailable Information .......................................................................3-87 

3.9. Water Quality........................................................................................................................3-88 

3.9.1 Existing Conditions ...............................................................................................................3-88 

3.9.2 Effects Analysis & Methodology ...........................................................................................3-93 

3.9.3 Direct/Indirect Effects ...........................................................................................................3-93 

3.9.4 Early Detection/Rapid Response .......................................................................................3-109 

3.9.5 Aquatic Conservation Strategy Objectives.........................................................................3-109 

3.9.6. Management Standards and Guidelines ............................................................................3-113 

3.9.7. Incomplete and Unavailable Information............................................................................3-113 

3.10. Aquatic Organisms and Habitat..........................................................................................3-113 

3.10.1 Existing Conditions .............................................................................................................3-113 

3.10.2. Effects Analysis ..................................................................................................................3-138 

3.10.2.1 Alternative 1 – No Action Alternative ..............................................................3-138 

3.10.2.2 Aquatic Organisms Screening and Analysis Methodology – 

Action Alternatives ..........................................................................................3-143 

3.10.2.3 Alternative 2 – Proposed Action Alternative ...................................................3-149 

3.10.2.4 Alternative 3 – Restricted Herbicide Use Alternative......................................3-163 

3.10.3 Determination of Effects Including Essential Fish Habitat..................................................3-167 

3.10.4 Management Standards and Guidelines ............................................................................3-170 

3.10.54. Incomplete and Unavailable Information..........................................................................3-170 

3.11. Wildlife ................................................................................................................................3-171 

3.11.1 Existing Conditions .............................................................................................................3-171 

3.11.2 Effects Analysis & Methodology .........................................................................................3-178 

3.11.3 Direct/Indirect Effects .........................................................................................................3-182 

3.11.4 Cumulative Effects..............................................................................................................3-190 

3.11.5 Specific Species Discussion...............................................................................................3-191 

3.11.5.1 General Overview of Herbicide Analysis by Species...................................3-191

3.11.5.2 Northern Spotted Owl (Strix occidentalis caurina): Threatened .....................3-192 

3.11.5.3 Northern Bald Eagle (Haliaeetus leucocephalus): Threatened .....................3-199 

3.11.5.4 Canada Lynx (Lynx canadensis): Threatened................................................3-201 

3.11.5.5 Larch Mountain Salamander (Plethodon larseli): Sensitive............................3-202 

3.11.5.6 Oregon Slender Salamander (Batrachoseps wrighti): Sensitive ...................3-204 

3.11.5.7 Cope’s Giant Salamander (Dicamptodon copei): Sensitive and 

Cascade Torrent Salamander (Rhyacotriton cascadae): Sensitive)...............3-206 

iv 
3.11.5.8 American Peregrine Falcon (Falco peregrinus anatum): Sensitive ................3-207 

3.11.5.9 Northern Painted Turtle (Chrysemys picta): Sensitive and Western 

Pond Turtle (Clemmys marmorata marmorata): Sensitive .............................3-208 

3.11.5.10 Horned Grebe (Podiceps auritus): Sensitive and Bufflehead 

(Bucephala albeola): Sensitive .......................................................................3-209 

3.11.5.11 Harlequin Duck (Histrionicus histrionicus): Sensitive......................................3-209 

3.11.5.12 Wolverine (Gulo gulo): Sensitive.....................................................................3-211 

3.11.5.13 Baird’s Shrew (Sorex bairdii permiliensis): Sensitive......................................3-212 

3.11.5.14 Pacific Fringe-tailed Bat (Myotis thysanodes vespertinus): Sensitive ............3-213 

3.11.5.15 Pacific Pallid Bat (Antrozous pallidus pacificus): Sensitive ............................3-214 

3.11.5.16 Fisher (Martes pennanti): Sensitive ................................................................3-216 

3.11.5.17 Crater Lake Tightcoil (Pristiloma arcticum crateris): Sensitive ......................3-217 

3.11.5.18 Dalles Sideband (Monadenia fidelis minor), Puget Oregonian (Cryptomastix 

devia), Columbia Oregonian (Cryptomastix hendersoni): Sensitive..............3-218 

3.11.6 Management Indicator Species (MIS) ................................................................................3-219 

3.11.6.1 Pileated woodpecker (Dryocopus pileatus) ....................................................3-219 

3.11.6.2 American Marten (Martes americana) ............................................................3-220 

3.11.6.3 Deer and Elk ...................................................................................................3-220 

3.11.7 Other Species of Interest – Landbirds................................................................................3-222 

3.11.8 Game Animals ....................................................................................................................3-226 

3.11.9 Oregon State Sensitive Species.........................................................................................3-226 

3.11.10 Management Standards and Guidelines ............................................................................3-227 

3.11.11 Incomplete and Unavailable Information ...........................................................................3-227

3.12. Congressionally Designated Areas and Scenery Management.........................................3-228 

3.12.1 Existing Conditions .............................................................................................................3-228 

3.12.2 Effects to Congressionally Designated Areas ....................................................................3-234 

3.12.3 Effects to Scenic Integrity...................................................................................................3-240 

3.12.4 Management Standards and Guidelines ............................................................................3-241 

3.12.5 Incomplete and Unavailable Information............................................................................3-241 

3.13. Heritage Resources............................................................................................................3-242 

3.13.1 Existing Conditions .............................................................................................................3-242 

3.13.2 Direct/Indirect Effects .........................................................................................................3-243 

3.13.3 Cumulative Effects..............................................................................................................3-244 

3.13.4 Management Standards and Guidelines ............................................................................3-245 

3.13.5 Incomplete and Unavailable Information............................................................................3-246 

3.14. Tribal Relations, Civil Rights and Environmental Justice ...................................................3-246 

3.14.1 Existing Conditions .............................................................................................................3-246 

3.14.2 Direct/Indirect Effects .........................................................................................................3-250 

v 
Final Environmental Impact Statement 

3.14.3 Early Detection/Rapid Response .......................................................................................3-253 

3.14.4 Cumulative Effects..............................................................................................................3-253 

3.14.5 Management Standards and Guidelines ............................................................................3-254 

3.14.6 Incomplete and Unavailable Information............................................................................3-254 

3.15 Specifically Requested Disclosures ...................................................................................3-254

3.15.1 Adverse Environmental Effects that Cannot be Avoided ...................................................3-254 

3.15.2 Short-term Uses and Maintenance of Long-term Productivity ...........................................3-259 

3.15.3 Irreversible or Irretrievable Commitments of Resources....................................................3-259 

3.15.4 Cumulative Effects..............................................................................................................3-260 

3.15.5 Conflicts with Plans or Policies of Other Jurisdictions .......................................................3-260 

3.15.6 Effects on Consumers, Civil Rights, Minority Groups, Women and 

Environmental Justice ......................................................................................................3-260 

3.15.7 Effects on American Indian Rights .....................................................................................3-260 

3.15.8 Prime Farmlands, Rangelands, Forestlands, or Parklands................................................3-261 

3.15.9 Wetlands and Floodplains ..................................................................................................3-261 

3.16 Forest Plan Amendment.....................................................................................................3-261 

CHAPTER 4: CONSULTATION AND COORDINATION..........................................................................4-1 

4.1 Consultation with U.S. Fish and Wildlife Service (FWS) ........................................................4-1 

4.2 Consultation with National Marine Fisheries Service (NOAA Fisheries)................................4-1 

4.3 Consultation with Oregon State Historic Preservation Office.................................................4-3 

4.4 Consultation with Tribal Governments ...................................................................................4-3 

4.5 Consultation with State and County Noxious Weed Departments.........................................4-3 

4.6 Consultation with Columbia River Gorge Commission ..........................................................4-4 

CHAPTER 5: LIST OF PREPARERS .......................................................................................................5-1 

5.1 Interdisciplinary Team Members – Core Members ................................................................5-1 

5.2 Interdisciplinary Team Members – Support Members ...........................................................5-3 

CHAPTER 6: DISTRIBUTION LIST OF DRAFT EIS................................................................................6-1 

REFERENCES ................................................................................................................ REFERENCE-1 

GLOSSARY .................................................................................................................. GLOSSARY-1 

INDEX ............................................................................................................................INDEX-1 

vi 
Appendices 

APPENDIX A Standards from Preventing and Managing Invasive Plant Record of Decision 

APPENDIX B Compliance with Mt. Hood National Forest Land and Resource Management Plan 

(1990) and Northwest Forest Plan (1994) 

APPENDIX C Columbia River Gorge National Scenic Area Management Plan – Consistency 

Determination 

APPENDIX D Prevention of Invasive Plants – A Strategic and Collaborative Effort 

APPENDIX E Pesticide – Use Proposal (FW-2100-2) 

APPENDIX F Site and Treatment Information 

APPENDIX G Common Control Measures Summary 

APPENDIX H Proposed Herbicide Use at Treatment Sites in the Proposed Action 

APPENDIX I Oregon State Class A & B Noxious Weeds 

APPENDIX J Invasive Plant Treatments by Fifth Field Watersheds 

APPENDIX K Proposed Herbicide Treatments for Alternative 3 

APPENDIX L Sample Public Norifications 

APPENDIX M Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources 

APPENDIX N Inventory and Monitoring Framework 

APPENDIX O Existing Conditions Characteristics 

APPENDIX P Ownership Patterns by Fifth Field Watershed 

APPENDIX Q Herbicide Information Summary and Project Design Criteria Crosswalk 

APPENDIX R Adjuvants and Surfactants Addressed by Bakke (2003A) 

APPENDIX S Economic Assumptions 

APPENDIX T Labor Cost, Wage Income and Potential Job Estimates 

APPENDIX U Effects on Soil Properties: Review of Proposed Herbicides 

APPENDIX V Drinking Water Protection Areas 

APPENDIX W Summary Tables of Site-Specific Herbicide Effects for Various Aquatic Species 

APPENDIX X Effects of Herbicides on Wildlife Species 

APPENDIX Y Programmatic Agreement Regarding Cultural Resources Management 

APPENDIX Z Response to Comments 

vii 
Final Environmental Impact Statement 

List of Tables 

Table 1-1: Rate of Spread for Treatment Area Acres .......................................................................1-7 

Table 1-2: Forest Plan Standards and Guidelines Discouraging or Prohibiting Pesticide Use ......1-21 

Table 2-1: Acres of Treatment from October 2003 to October 2004 (Fiscal Year 2003)................2-11 

Table 2-2: Summary of Proposed Treatment Methods...................................................................2-20 

Table 2-3: Invasive Plants Proposed for Treatment........................................................................2-24 

Table 2-4: Acres by Treatment Strategies ......................................................................................2-26 

Table 2-5: Proposed Action Summary of Treatment Methods........................................................2-27 

Table 2-6: Active Ingredients and Commercial Herbicide Names. .................................................2-28 

Table 2-7: Typical Application Rates of Various Herbicides Used in Oregon and Washington......2-30 

Table 2-8: Priorities for Treatment and Selection of Treatment Methods .......................................2-33 

Table 2-9: Total Allowable Amount of Invasive Plant Treatments Under the EDRR 

by 5th Field Watershed and Riparian Reserves. ............................................................2-36 

Table 2-10: Proposed Amendment to the Forest Plan, Under the Proposed Action ........................2-40 

Table 2-11: Description of Highest Priority Sites...............................................................................2-42 

Table 2-12: Summary of Treatment Methods for Alternative 3 – Restricted Herbicide Use.............2-42 

Table 2-13: Protection Buffer Widths for Special Status Plant Species............................................2-55 

Table 2-14: Water Protection Measures. ..........................................................................................2-56 

Table 2-15: Comparison of Herbicide Treatment Methods by Alternative. .......................................2-62 

Table 2-16: Comparison of Environmental Effects of Implementing the Alternatives in Relation 

to Purpose and Need/Desired Future Condition and Key and Tracking Issues. ...........2-63 

Table 3-1: Acres by Site Description.................................................................................................3-3 

Table 3-2: Risk Assessments for Herbicides Considered in this EIS, Including Formulations 

and Manufacturers .........................................................................................................3-10 

Table 3-3: Cumulative Effects Information......................................................................................3-18 

Table 3-4: Project Design Criteria to Minimize Exposures of Concern...........................................3-31 

Table 3-5: Number of Treatment Areas by Invasive Plant Species ................................................3-43 

Table 3-6: Treatment Areas with Special Status Plant Species......................................................3-45 

Table 3-7: Selective Herbicides Proposed for Treatment and Analyzed in EIS..............................3-48 

Table 3-8: Special Forest Products Summary for Fiscal Years 2003, 2004, and 2005..................3-60 

Table 3-9: Total Costs for Three Alternatives to Treat Inventoried Invasive Plant 

Populations in the Forest and Scenic Area....................................................................3-62 

Table 3-10: Cost Per Acre for Three Alternatives to Treat Inventoried Invasive Plant 

Populations in the Forest and Scenic Area....................................................................3-63 

Table 3-11; For Alternative 2 (The Proposed Action), Number of Years and Total Cost..................3-64 

Table 3-12: For Alternative 3 (Restricted Herbicide Use), Number of Years and Total Cost ...........3-66 

Table 3-13: Total Costs for Action Alternatives to Treat 13,000 Acres of Proposed 

Invasive Plant Populations and 17,000 EDRR Acres ....................................................3-68 

viii 
Table 3-14: Labor Cost, Wage Income, and Potential Job Estimates for Invasive Plant 

Treatments in the Forest and Scenic Area. ...................................................................3-70 

Table 3-15: Jobs Created (Equivalent to $20,000 per Year) by the Proposed Action and 

the Reduced Herbicide Use Alternatives with EDRR ....................................................3-70 

Table 3-16: Forest Plan Soil Standards. ...........................................................................................3-73 

Table 3-17: Effects of Herbicides on Soil Organisms. ......................................................................3-79 

Table 3-18: Relative Ranking of Herbicide Characteristics and Influencing Factors 

on Soil Properties...........................................................................................................3-81 

Table 3-19: Specific Cause and Effect Concerns as They Relate to Analysis Standards 

and Guidelines. ..............................................................................................................3-85 

Table 3-20: Summary of Relative Impacts to Soils by Alternative. ...................................................3-86 

Table 3-21: Proposed Invasive Plant Treatment Acres within Drinking Water Protection Areas. ....3-89 

Table 3-22: Streams on the Forest and Scenic Area That Do Not Meet Federally-approved 

State Water Quality Standards ......................................................................................3-90 

Table 3-23: Number of Acres of Invasive Plant Treatments Within Riparian Reserves Under 

the No Action Alternative (Alternative 1)........................................................................3-95 

Table 3-24: Acres of Invasive Plant Treatments Within Riparian Reserves on the Forest 

and Scenic Area for Proposed Action (Alternative 2) ....................................................3-96 

Table 3-25: Potential Pathways of Effects to Water Quality From Treatment Methods..................3-104 

Table 3-26: Ownership, Acres of Treatment Areas and Road Density in Each 5th Field 

Watershed....................................................................................................................3-106 

Table 3-27: Water Quality Indicators and Project Effects at the 5th Field Watershed Scale...........3-110 

Table 3-28: Aquatic Conservation Strategy Objectives and Water Quality Indicators....................3-111 

Table 3-29: Special Status and Other Important Aquatic Species Found in Forest and/or 

Scenic Area Streams ...................................................................................................3-115 

Table 3-30: Downstream Juvenile Migration Timing for Six Federally Listed Salmonid 

Stocks Based on Passage at Bonneville Dam.............................................................3-124 

Table 3-31: Acres Treated Within Upland Areas, Riparian Reserves, and the Aquatic Influence 

Zone in 2003 Within the Forest and Scenic Area ........................................................3-138 

Table 3-32: The Area of Proposed Treatment Methods in Riparian Reserves and the Aquatic 

Influence Zone for the Entire Forest and Scenic Area under the Proposed Action 

Alternative. ...................................................................................................................3-150 

Table 3-33. Proposed Sites Within Riparian Reserves Where the NOEC was Exceeded0 

for at Least One Herbicide for Aquatic Plants and/or Fish...........................................3-158 

Table 3-34: The Area of Proposed Treatment Methods in Riparian Reserves and the Aquatic 

Influence Zone for the Entire Forest and Scenic Area Under the Restricted 

Herbicide Use Alternative. ...........................................................................................3-164 

Table 3-35: A summary of anticipated effects for aquatic PETS species that are 

found within the Forest and Scenic Area from Alternatives 2 and 3............................3-168 

Table 3-36: Special Status/Sensitive Wildlife Species....................................................................3-172 

Table 3-37: Terrestrial Survey and Manage Species......................................................................3-176 

Table 3-38: Summary of Project Effects to Special Status Wildlife Species...................................3-183 

Table 3-39: Treatment Acre by Alternative and Spotted Owl Habitat Type ....................................3-196 

ix 
Final Environmental Impact Statement 

Table 3-40: Wild and Scenic River Segments and Acres Within the Administrative 

Boundaries of the Forest..............................................................................................3-228 

Table 3-41: Outstandingly Remarkable Values (ORV) for the Wild and Scenic Rivers 

in the Forest. ................................................................................................................3-229 

Table 3-42: Land Area and Miles of Trail in the Six Wilderness Areas that are Entirely 

or Partially in the Forest. ..............................................................................................3-230 

Table 3-43: Measurement of People Viewing Scenery in the Forest (measured in 2003) 

and Scenic Area (measured in 2000). .........................................................................3-231 

Table 3-44: Landscape Settings, Land Use Designations, and Scenic Standards for 

Invasive Plant Sites in the Scenic Area. ......................................................................3-233 

Table 3-45: Proposed Action Treatment Sites in Wild and Scenic River Corridors in 

the Forest.....................................................................................................................3-235 

Table 3-46: Restricted Herbicide Use Alternative Treatment Sites in Wild and Scenic 

River Corridors in the Forest........................................................................................3-236 

Table 3-47: List of Culturally Significant Plants...............................................................................3-242 

Table 3-48: Selected Demographic Information for Multnomah, Clackamas, Hood River, and 

Wasco Counties, Oregon.............................................................................................3-247 

Table 3-49: Adverse Effects that Cannot be Avoided .....................................................................3-255 

List of Figures 

Figure 1-1: Vicinity Map of Mt. Hood National Forest and Columbia River Gorge 

National Scenic Area........................................................................................................1-2

Figure 1-2: Diagram of Treatment Areas............................................................................................1-8 

Figure 1-3: Picture Series Illustrating Desired Future Condition at Sandy River Delta....................1-11 

Figure 1-4: Decision Key for Invasive Plant Treatments ..................................................................1-15 

Figure 2-1: Map of Proposed Treatment Areas for the Proposed Action...........................................2-2 

Figure 2-2: Proposed Action Map for Columbia River Gorge National Scenic Area..........................2-4 

Figure 2-3: Proposed Action Map for Barlow Ranger District, Mt. Hood National Forest ..................2-5 

Figure 2-4: Proposed Action Map for Clackamas River Ranger District, Mt. Hood National Forest..2-6 

Figure 2-5: Proposed Action Map for Hood River Ranger District, Mt. Hood National Forest ...........2-7 

Figure 2-6: Proposed Action Map for Zigzag Ranger District, Mt. Hood National Forest ..................2-8 

Figure 2-7: Map of Proposed Treatment Areas for the No Action Alternative..................................2-12 

Figure 2-8: No Action Altnerative Map for Columbia River Gorge National Scenic Area.................2-13 

Figure 2-9: No Action Alternative Map for Barlow Ranger District, Mt. Hood National Forest.........2-14 

Figure 2-10: No Action Alternative Map for Clackamas River Ranger District, 

Mt. Hood National Forest ...............................................................................................2-15 

Figure 2-11: No Action Alternative Map for Hood River Ranger District, Mt. Hood National Forest..2-16 

Figure 2-12: No Action Alternative Map for Zigzag Ranger District, Mt. Hood National Forest .........2-17 

Figure 2-13: Illustration of Aquatic Influence Zone.............................................................................2-19 

Figure 2-14: Map of Proposed Treatment Areas for the Restricted Herbicide Use Alternative .........2-43 

x 
Figure 2-15: Restricted Herbicide Use Altnerative Map for Columbia River Gorge 

National Scenic Area ....................................................................................................2-44 

Figure 2-16: Restricted Herbicide Use Alternative Map for Barlow Ranger District, 

Mt. Hood National Forest ...............................................................................................2-45 

Figure 2-17: Restricted Herbicide Use Alternative Map for Clackamas River Ranger District, 

Mt. Hood National Forest ...............................................................................................2-46 

Figure 2-18: Restricted Herbicide Use Alternative Map for Hood River Ranger District, 

Mt. Hood National Forest ...............................................................................................2-47 

Figure 2-19: Restricted Herbicide Use Alternative Map for Zigzag Ranger District, 

Mt. Hood National Forest ...............................................................................................2-48 

Figure 3-1: Map of Owernship Patterns in Vicinity of Mt. Hood National Forest and Columbia 

River Gorge National Scenic Area...................................................................................3-8 

Figure 3-2: Layers of Caution Integrated Into Herbicide Use...........................................................3-14 

Figure 3-3: Total costs of Alternatives to treat invasive plants in the Forest and Scenic Area in 

Oregon without Budget Constraint.................................................................................3-62 

Figure 3-4: Map of Soil Distribution and Proposed Treatment Areas...............................................3-83 

Figure 3-5 Map of Bull Trout Distribution.......................................................................................3-117 

Figure 3-6 Map of Lower and Middle Columbia River Steelhead Trout Distribution.....................3-119 

Figure 3-7 Map of Lower Columbia River and Upper Willamette River Chinook Salmon 

Distribution Map ...........................................................................................................3-121 

Figure 3-8 Map of Lower Columbia River Coho Salmon Distribution............................................3-123 

Figure 3-9 Map of Rainbow and Cutthroat Trout Distribution........................................................3-127 

Figure 3-10 Map of Pacific Lamprey Distribution ............................................................................3-129 

Figure 3-11: Map of Bull Trout Critical Habitat .................................................................................3-131 

Figure 3-12: Map of Lower and Middle Columbia River Steelhead Trout Critical Habitat................3-133 

Figure 3-13: Map of Lower Columbia River and Upper Willamette River Chinook Salmon 

Critical Habitat..............................................................................................................3-134 

xi 
Final Environmental Impact Statement 

ACRONYM LIST 

A-1 General Management Area Large Scale Agriculture (Scenic Area Designation) 

ACHP Advisory Council on Historic Preservation 

Ag Special Management Area Agriculture (Scenic Area Designation) 

AIZ Aquatic Influence Zone 

APHIS Agricultural Plant Health and Insect Service 

AQ Aquatic 

ATSDR Agency for Toxic Substances and Disease Registry 

ATV All Terrain Vehicle 

AWA Administratively Withdrawn Areas 

BA Biological Assessment 

BCF Bioconcentration Factor 

BE Biological Evaluation 

BEE Butoxyethyl Ester 

BIA U.S. Department of Interior, Bureau of Indian Affairs 

BLM U.S. Department of Interior, Bureau of Land Management 

BMP Best Management Practices 

BO Biological Opinion 

BPA Bonneville Power Administration 

C Candidate Wildlife Species 

CAS Chemical Abstract Service 

CBI Confidential Business Information 

CE Cumulative Effects 

CFR Code of Federal Regulations 

CHU Critical Habitat Unit 

CRGNSA Columbia River Gorge National Scenic Area 

CTWS Confederated Tribes of Warm Springs 

CW Coniferous Woodland (Scenic Area Designation) 

CWA Clean Water Act 

DEQ Department of Environmental Quality 

DO Dissolved Oxygen 

DPS Distinct Population Segment 

E Endangered Wildlife Species 

EA Environmental Assessment 

EDRR Early Detection / Rapid Response Strategy 

EEC Estimated Environmental Concentration 

EFH Essential Fish Habitat 

EIS Environmental Impact Statement 

EO Executive Order 

EPA U.S. Environmental Protection Agency 

ESA Endangered Species Act 

ESU Evolutionary Significant Unit 

F Special Management Area Forest (Scenic Area Designation) 

FDA U.S. Food and Drug Administration 

FEIS Final Environmental Impact Statement 

FEMAT Forest Ecosystem Management Assessment Team 

FHP Forest Health Protect 

xii 
ACRONYM LIST 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

FR Federal Register 

FSH USDA Forest Service Handbook 

FSM USDA Forest Service Manual 

FWS U.S. Department of Interior, Fish & Wildlife Services 

FY Fiscal Year 

G Grasslands (Scenic Area Designation) 

GeoBOB Geographic Biotic Observations Geodatabase 

GIS Geographic Information System 

GLEAMS Groundwater Loading Effects of Agricultural Management Systems 

GMA General Management Area (Scenic Area Designation) 

GW Gorge walls, Canyon Lands and Wildlands (Scenic Area Designation) 

h Herbicide treatment 

HQ Hazard Quotient 

HRCH Historic Columbia River Highway 

ICBEMP Interior Columbia Basin Ecosystem Management Project 

IDT Interdisciplinary Team 

ISMS Interagency Species Management System 

IWM Integrated Weed Management 

KVA Key Viewing Area 

LAA May Affect, Likely to Adversely Affect 

LFL Likely to Cause a Trend to Federal Listing or Loss of Viability 

LMS Larch Mountain Salamander 

LOAEL Lowest Observed Adverse Effect Level 

LOC Level of Concern 

LRMP Land & Resource Management Plan 

LS Landscape Setting (Scenic Area Designation) 

LSR Late-Successional Reserves 

LUD Land Use Designation 

MIIH May Impact Individuals or Habitat, but Will Not Likely Contribute towards 

Federal Listing or Lost of Viability to the Population or Species 

MIS Management Indicator Species 

mm Manual and mechanical treatments 

mmh Manual, mechanical and herbicide treatments 

MSA Magnuson-Stevens Fishery Conservation and Management Act 

MSDS Material Safety Data Sheet 

MTH Mt. Hood National Forest 

N/A (or NA) Not Available 

NAA Not Adversely Affected 

NE No Effect 

NEPA National Environmental Policy Act 

NFMA National Forest Management Act 

NHPA National Historic Preservation Act 

NI No Impact 

NIS Non-Ionic Surfactants 

NLAA May Affect, Not Likely to Adversely Affect 

NLFL May Impact Individual, but Not Likely to Cause a Trend to Federal Listing 

or Loss of Viability 

xiii 
Final Environmental Impact Statement 

ACRONYM LIST 

NMFS National Marine Fisheries Service 

NOAA U.S. Department of Commerce, National Oceanic & Atmospheric 

Administration. 

NOAEL No Observed Adverse Effect Level 

NOEC No Observable Effects Concentration 

NOEL No-Observed-Effect-Level 

NOI Notice of Intent 

NPDES National Pollutant Discharge Elimination System 

NPE Nonylphenol Polyethoxylate 

NRC National Research Council 

NRF Nesting, Roosting and Foraging Habitat 

NRIS Natural Resource Information Systems 

NTV No Toxicity Value 

NVE Not Visually Evident (Retention) 

NVUM National Visitor Use Monitoring 

NWFP Northwest Forest Plan 

NWPS National Wilderness Preservation System 

ODA Oregon Department of Agriculture 

OHD Oregon Health Division 

OHV Off-Highway Vehicles 

OPP Office of Pesticide Programs 

OR Oregon 

ORV Outstandingly Remarkable Values 

OS Special Management Area – Open Space (Scenic Area Designation) 

OS GMA General Management Area – Open Space (Scenic Area Designation) 

OSHA Occupational Health and Safety Administration 

OSS Oregon Slender Salamander 

OSU Oregon State University 

OW Oak Woodlands (Scenic Area Designation) 

P Pastoral (Scenic Area Designation) 

PAYCO Payments to Counties 

PCE Primary Constituent Elements 

PDC Project Design Criteria 

PETS Proposed, Endangered, and Threatened Species 

PIF Partners in Flight 

POEA Polyethoxylated Tallow Amine 

PPE Personal Protective Equipment 

PR Public Recreation (Scenic Area Designation) 

PVT Potential Vegetation Type 

R General Management Area – Residential (Scenic Area Designation) 

R6 USDA Forest Service, Pacific Northwest Region (Oregon and Washington) 

RB River Bottomlands (Scenic Area Designation) 

RfD Reference Dose 

ROD Record of Decision 

RR Riparian Reserve 

RR in P General Management Area – Rural Residential in Pastoral (Scenic Area 

Designation) 

RTU Ready to Use 

xiv 
ACRONYM LIST 

SC Sensitive-Critical Wildlife Species 

SERA Syracuse Environmental Research Associates, Inc. 

SHPO State Historic Preservation Office 

SMA Special Management Area (Scenic Area Designation) 

SMS Scenery Management System 

SOLI Species of Local Interest 

SRD Sandy River Delta 

SRI Soil Resource Inventory 

ssp Species 

SU Sensitive-Undetermined Wildlife Species 

SV Sensitive-Vulnerable Wildlife Species 

SWCD Soil and Water Conservation District 

SWDA Safe Drinking Water Act 

T Threatened Wildlife Species 

T,E,S&P Threatened, Endangered, Sensitive, and Proposed Species 

TCP 3,5,6-Trichloro-2-Pyridinol 

TEA Triethylamine 

TES Threatened, Endangered, or Sensitive 

TMDL Total Maximum Daily Loads 

UA Urban Area (Scenic Area Designation) 

USDA U.S. Department of Agriculture 

USDI U.S. Department of Interior 

VQO Visual Quality Objectives 

VS Visual Subordinance (Partial Retention) 

WA Washington 

WQRP Water Quality Restoration Plan 

xv 
Final Environmental Impact Statement 

MEASUREMENT ABBREVIATIONS 

a.i. Active Ingredient 

ac Acre 

cfs Cubic Feet per Second 

cm Centimeter 

dB Decibels 

dbh Diameter at Breast Height 

g Gram 

kg Kilogram 

Ko/c Organic Carbon Partition Coefficient 

L Litter 

lb ai Pounds of Active Ingredient 

LC50 Lethal Concentration, 50% Mortality 

LD50 Lethal Dose, 50% Mortality 

LD95 Lethal Dose, 95% Mortality 

m Meter 

mg Milligram 

mg/kg/day Milligrams of Agent per Kilogram of Body Weight per Day 

mg/L Milligrams per Liter 

mi/mi2 Miles per Square Mile 

mL Milliliter 

mm Millimeter 

ppm Parts per Million 

RfD Reference Dose 

xvi 
xvii 

COMMON UNIT CONVERSIONS 

To convert . . . Into . . . Multiply by . . .

Acres (ac) Hectares (ha) 0.4047 

Acres (ac) Square meters (m2) 4,047 

Atmospheres Millimeters of Mercury 760 

Centigrade (Co) Fahrenheit (Fo) 1.8C°+32 

Centimeters (cm) Inches (in) 0.3937 

Cubic Meters (m3) liters (L) 1,000 

Fahrenheit (Fo) Centigrade (Co) 0.556F°-17.8 

Feet per Second (ft/sec) Miles/Hour (mi/hr) 0.6818 

Gallons (gal) Liters (L) 3.785 

Gallons per Acre (gal/acre) Liters per Hectare (L/ha) 9.34 

Grams (g) Ounces (oz) 0.03527 

Grams (g) Pounds (oz) 0.002205 

Hectares (ha) Acres (ac) 2.471 

Hectares (ha) Square Meters (m2) 10,000 

Inches (in) Centimeters (cm) 2.540 

Kilograms (kg) Ounces, (oz) 35.274 

Kilograms (kg) Pounds (lb) 2.2046 

Kilograms per Hectare (hg/ha) Pounds per Acre (lb/acre) 0.892 

Kilometers (km) Miles (mi) 0.6214 

Liters (L) Cubic Centimeters (cm3) 1,000 

Liters (L) Gallons (gal) 0.2642 

Liters (L) Ounces, fluid (oz) 33.814 

Meters (m) Feet (ft) 3.281 

Miles (mi) Kilometers (km) 1.609 

Miles per Hour (mi/hr) Centimeter per Second (cm/sec) 44.70 

Milligrams (mg) Ounces (oz) 0.000035 

Ounces (oz) Grams (g) 28.3495 

Ounces Fluid (oz) Cubic Centimeters (cm3) 29.5735 

Ounces per Acre (oz/acre) Grams per Hectare (g/ha) 70.1 

Ounces per Acre (oz/acre) Kilograms per Hectare (kg/ha) 0.0701 

Pounds (lb) Grams (g) 453.6 

Pounds (lb) Kilograms (kg) 0.4536 

Pounds per Acre (lb/acre) Kilograms per Hectare (kg/ha) 1.121 

Pounds per Acre (lb/acre) Milligrams per Square Meter (mg/m2) 112.1 

Pounds per Acre (lb/acre) Grams per Square Centimeter (g/cm2) 11.21 

Pounds per Gallon (lb/gal) Grams per Liter (g/L) 119.8 

Square Centimeters (cm2) Square Inches (in2) 0.155 

Square Centimeters (cm2) Square Meters (m2) 0.0001 

Square Meters (m2) Square Centimeters (cm2) 10,000 

Yards (yds) Meters (m) 0.9144 

Note: All references to pounds and ounces refer to avoirdupois weights unless otherwise 

specified. 

Source: Table taken from SERA Risk Assessments (1997a, 1997b, 1999a, 1999b, 2001a, 

2001c, 2003a, 2003b, 2003c, 2003d, 2003e, 2003f). 
 
CHAPTER 1 

Purpose and Need for Action 
 
Site-Specific Invasive Plant Treatments 

CHAPTER 1: Purpose and Need 

The USDA Forest Service has prepared this Environmental Impact Statement in compliance with 

the National Environmental Policy Act (NEPA), other relevant Federal and State laws and 

regulations, including the management direction provided by the Pacific Northwest Region 

Invasive Plant Program, Preventing and Managing Invasive Plants Record of Decision (USDA 

Forest Service, 2005b) and Final Environmental Impact Statement (USDA Forest Service, 

2005a). Also, this Environmental Impact Statement (EIS) complies with the management 

direction contained in the Mt. Hood National Forest Land and Resource Management Plan 

(USDA Forest Service, 1990b) and the Columbia River Gorge National Scenic Area 

Management Plan (Columbia River Gorge Commission and USDA Forest Service, 1992; 2004). 

This EIS discloses the direct, indirect, and cumulative environmental impacts that would result 

from the alternatives, including the Proposed Action. The document is organized into six 

chapters: 

• Chapter 1. Purpose and Need for Action: This chapter includes information on the 

background of the project proposal, the purpose and need for action, the decision to be 

made, and a brief description of the Proposed Action. This section also details how the 

USDA Forest Service informed the public of the proposal and the issues identified. 

• Chapter 2. Alternatives, including the Proposed Action: This chapter provides a more 

detailed description of the Proposed Action as well as No Action and Restricted 

Herbicide Use Alternatives. The Restricted Herbicide Use Alternative was developed 

based on significant issues raised by the public and other agencies. This chapter also 

includes Project Design Criteria (PDC), and provides a summary table of the 

environmental consequences associated with each alternative. 

• Chapter 3. Affected Environment and Environmental Consequences: This chapter 

describes the existing conditions and environmental effects of implementing the Proposed 

Action or other alternatives, including the No Action Alterative. The following were 

analyzed to determine the effect of invasive plant treatment: 1) human health and safety; 

2) effectiveness of treatment; 3) botany, including sensitive plants and native plant 

communities; 4) wildlife; 5) treatment costs; 6) water quality; and 7) aquatic organisms. 

Other areas considered include effects of jobs created; special forest products; spread to 

other ownerships; soil productivity; scenic integrity heritage resources; and tribal/treaty 

rights. 

• Chapter 4. Consultation and Coordination: This chapter provides information on 

agencies consulted during the development of the environmental impact statement. 

1-1 
Final Environmental Impact Statement 

Figure 1-1. Vicinity Map of Mt. Hood National Forest and Columbia River Gorge National 

Scenic Area 

1-2 
Site-Specific Invasive Plant Treatments 

• Chapter 5. List of Preparers and Chapter 6. Distribution List of Draft EIS: These 

chapters provide a list of preparers and reviewers as well as a mailing list for the final 

EIS. 

• Appendices: The appendices provide information that supports the analyses presented in 

the EIS. 

Additional documentation, including more detailed analyses of project-area resources, may be 

found in the project planning record located at Mt. Hood National Forest Headquarters in Sandy, 

Oregon. 

1.1 Background 

This site-specific invasive plant EIS applies to the entirety of the Mt. Hood National Forest (the 

Forest) and the Columbia River Gorge National Scenic Area in Oregon (the Scenic Area), as 

illustrated in the Vicinity Map (Figure 1-1). The majority of the project area is located in 

Multnomah, Clackamas, Hood River, and Wasco counties. Small portions adjacent to the 

Willamette National Forest are in Marion and Jefferson counties. The lands of the Forest total a 

little more than one million acres, with more acreage on the westside of the Cascade Mountain 

Range. The National Forest System lands within the Scenic Area total 71,000 acres, with 

approximately 39,000 acres in Oregon. This area comprises the Project Area for this project. 

Invasive plants are defined as “non-native plants whose introduction does or is likely to cause 

economic or environmental harm or harm to human health,” based on the definition provided in 

Executive Order 13112 (http://ceq.eh.doe.gov/nepa/regs/eos/eo13112.html). Invasive plants are 

compromising our ability to manage the Forest and Scenic Area for a healthy native ecosystem. 

Invasive plants can create a host of environmental and other effects, most of which are harmful 

to native ecosystem processes, including: displacement of native plants; reduction in 

functionality of habitat and forage for wildlife and livestock; increased potential for soil erosion 

and reduced water quality; alteration of physical and biological properties of soil; loss of longterm riparian area function; loss of habitat for culturally significant plants; high cost (dollars 

spent) of controlling invasive plants; and increased cost to maintaining transportation systems 

and recreational sites. 

This EIS addresses inventoried invasive plant species as well as additional invasive plant species 

that may be treated under the Early Detection / Rapid Response strategy (discussed below). The 

invasive plant inventory on the Forest and Scenic Area analyzed in this EIS was completed in 

November 2004. The inventoried invasive plant species include: 

1-3 
Final Environmental Impact Statement 

1-4 

• Butter and eggs (Linaria vulgaris) 

• Canada thistle (Cirsium arvense) 

• Common hawkweed (Hieracium

vulgatum) 

• Common tansy (Tanacetum vulgare) 

• Diffuse knapweed (Centaurea diffusa) 

• English ivy (Hedera helix) 

• Himalayan blackberry (Rubus discolor) 

• Houndstongue (Cynoglossum officinale) 

• Knotweed species (Polygonum spp.) 

• Meadow hawkweed (Hieracium

pratense) 

• Meadow knapweed (Centaurea 

debeauxii (pratense)) 

• Orange hawkweed (Hieracium 

aurantiacum) 

• Reed canarygrass (Phalaris 

arundinacea) 

• Rush skeletonweed (Chondrilla juncea) 

• Scotch broom (Cytisus scoparius) 

• Spotted knapweed (Centaurea 

biebersteinii) 

• St. Johnswort (Hypericum perforatum) 

• Tansy ragwort (Senecio jacobaea) 

• Yellow starthistle (Centaurea

solstitialis) 

All invasive plant treatments proposed in this EIS would be implemented in conjunction with ongoing invasive plant management efforts, including biological control agents and prevention 

practices. The management efforts are summarized below and discussed in more detail in later 

sections. 

• The Oregon Department of Agriculture releases biological control agents for all land 

ownerships across the State of Oregon. The agents as well as the targeted invasive plant 

species are listed at: http://www.oregon.gov/ODA/PLANT/WEEDS/bio_targetslist.shtml. 

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

Plants standards as listed in the Record of Decision (USDA Forest Service, 2005b) 

provide new prevention standards for the Forest and Scenic Area. These prevention 

practices include cleaning heavy equipment, using weed-free straw and mulch, using 

palletized or certified weed free feed, and inspecting active gravel, fill, sand stockpiles, 

quarry sites, and borrow material. 

• In addition to the regional prevention standards, the Forest and Scenic Area have local 

practices to prevent the invasion and/or spread of invasive plants. These standards 

incorporating prevention into planning, contracts and permits; utilizing weed-free plant 

material; distributing information; preventing invasive in areas with soil disturbance; and 

inspecting stockpiled gravel or rock. 
Site-Specific Invasive Plant Treatments 

Despite current invasive plant management efforts, invasive plants continue to increase and 

occupy new areas, including designated Wilderness areas. Invasive plants spread between the 

Forest, Scenic Area and neighboring areas, affecting all land ownerships. Since the spread of 

invasive plants do not respect administrative boundaries, the problems associated with invasive 

plants can spread between ownerships. When the invasive plant spread to an adjacent ownership, 

the adjacent ownership has to assume the cost and impact of addressing the problem. This is a 

particular concern in the Scenic Area where the administrative unit boundary includes several 

different ownership types including state, federal, tribal, county and private lands. 

1.2 Purpose and Need for Action 

The purpose of this project is to eradicate, control and contain invasive plant infestations, to 

reverse the negative impacts caused by the invasive plants, and to restore healthy, native plant 

communities and function at the impacted sites in a cost-effective manner that meets current 

management direction. Currently, the majority of the invasive plant problem on the Forest and 

Scenic Area cannot be effectively treated. The establishment and spread of invasive plants could 

be slowed with timely action. Without action, however, the problem could get significantly 

worse as illustrated by the following examples. 

• English ivy suffocates ground cover, smothers native plant seedlings, overwhelms shrubs 

and trees, and provides no food for native wildlife. Also, ivy is not a good ground cover 

for erosion control due to its shallow roots and waxy leaves. Forest Park in Portland, 

Oregon, the largest urban park, has become an “ivy desert.” From 1994 to 2004, the No 

Ivy League has been treating the infestations, including removing ivy from more than 

25,000 trees and 200 acres. This effort involved more than 30,000 volunteers and project 

participants and over 120,000 hours of volunteer service (No Ivy League, 2004). Despite 

these efforts, invasive plant infestations continue to be listed as one of the threats and 

issues affecting the park and requiring action by the Friends of the Forest Park website 

(2006). 

• “In 1993, Jackson county in southern Oregon, and Umatilla county in northeast Oregon 

both reported explosions of yellow starthistle with over 100,000 acres in Jackson county 

and 200,000 acres in Umatilla county. Now, a little over four years later both counties 

report that the populations have doubled! Similarly, in the U.S. Department of Interior, 

Bureau of Land Management (BLM) Cottonwood Resource Area in western Idaho, it is 

estimated that thirty percent of the BLM land is already infested with yellow starthistle” 

(Asher, 1998). Due to the spiny nature of yellow starthistle, livestock and wildlife avoid 

grazing in heavily infested areas (Weed Research Information Center, 2006). Also, the 

spiny nature can cause problems for recreationalists along trails and roads. 

1-5 
Final Environmental Impact Statement 

As the following Clackamas River Basin Watershed Council experience illustrates, timely 

treatment would prevent the formation of weed deserts, as described above, that are difficult to 

catch and nearly impossible to treat. In 2002, a team mapped over 500 patches of Japanese 

knotweed within 19 established reaches over 12 miles of river from River Mill Dam in Estacada 

downstream to the confluence of Clear Creek in Carver in the Clackamas River drainage. After 

unsuccessful invasive plant treatments on non-National Forest System lands, Metro regional 

government used a combination of stem injection and foliar herbicide application methods to 

treat over 19,000 individual knotweed stems, over 6 miles of treatment area. The evaluation of 

the injection/foliar method resulted in effective treatment of treated patches in 2003 and reduced 

the main stem knotweed by 70 percent (Clackamas River Basin Council, 2006). Successful 

treatment, such as this, is critical to reverse the negative impacts caused by the invasive plants 

and prevent the unabated spread across the Forest and Scenic Area, including ‘special places’ 

such as the Sandy River Delta, recreational residence tracts, portals to municipal watersheds 

(Bull Run, The Dalles, City of Estacada, Corbett, and Clackamas), Wilderness areas, Wild and 

Scenic River corridors, and the Rowena area. 

If the invasive plants continue to spread they would displace native plants. Invasive plants often 

become near monocultures (deserts), displacing native plants which form the basic biological 

matrix of all communities and are an important component of plant community structure. These 

deserts do not have the matrix of vertical and horizontal structure or the variety of species 

commonly found in healthy plant communities (Asher, 1998). The displacement of native plants 

reduces functionality of habitat and forage for wildlife and livestock; increases potential for soil 

erosion and reduced water quality; alters physical and biological properties of soil; reduces longterm riparian area function; degrades habitat for culturally significant plants; and increases costs 

of controlling invasive plants. Since invasive plants know no boundaries, the spread of invasive 

plants also could displace native plants on adjacent lands. Overall, these impacts can impact the 

ability of the Forest and Scenic Area to manage for healthy native ecosystems. 

In an effort to tackle the problem, an invasive plant inventory was completed in 2004, which 

surveyed about 50 percent of the areas of the Forest and Scenic Area likely to be infested with 

invasive plants (Stein, 2005). The inventory revealed that approximately 3,600 acres are infested 

with invasive plants. Realizing that some invasive plants or infested areas were missed during 

past surveys an uncertainty factor was applied to bring the estimated total infested area up to 

approximately 3,700 acres. In addition, evidence shows that the species present in the Forest and 

Scenic Area would likely expand their population at a rate of 8 to 12 percent each year (USDA 

Forest Service, 1999). To account for this growth over the life of the project (15 years), a 

“foreseeable” rate of spread of 10 percent per year was also applied to estimate the total 

foreseeable infested acres (Table 1-1), hereafter referred to as the treatment acres. 

1-6 
Site-Specific Invasive Plant Treatments 

Table 1-1: Rate of Spread for Inventoried Treatment Area Acres 

Year Acres at Start of Year 10% Rate of Spread 

1 3672 367 

2 4039 404 

3 4443 444 

4 4887 489 

5 5376 538 

6 5914 594 

7 6505 651 

8 7156 716 

9 7871 787 

10 8658 866 

11 9524 952 

12 10477 1048 

13 11524 1152 

14 12676 1268 

15 13000 

The total treatment acres were adjusted slightly to incorporate anecdotal evidence and expert 

knowledge, including delays in treatment, spread of invasive plants and other factors which 

spread plant seeds. The expansion in population size is due to plant growth as well as spread by a 

variety of vectors including wind, water, animals, and human activities where they are present. 

Also, due to the high cost of treatment, it is highly unlikely that we would be able to take action 

in all inventoried areas immediately. During the time between the inventory and treatment, plant 

populations would grow and spread. Invasive plant spread is unpredictable and over the life of 

the project, target species could spread, expanding the size of the populations and thus, the size 

of the area needing treatment. Therefore, these acres considered for treatment include the 208 

treatment areas containing known populations analyzed in this document and cover 

approximately 13,000 acres, with 11,000 acres on the Forest and 2,000 acres on the Scenic Area. 

To account for the unpredictability of growth and spread, all 13,000 acres are analyzed for 

potential treatment; however, only the acres infested at the time of treatment would treated with 

manual, mechanical, cultural (goat grazing), and herbicide methods. 

An example of an expanded treatment area is invasive plant infestations along road systems 

within the Forest and Scenic Area (Figure 1-2). The inventoried infestations are displayed as 

black circles. Since these infestations are along a road and are likely to spread via vehicular 

traffic, it is probable the infestations would continue to expand. In addition, given current budget 

levels and project timelines, the treatment area may not be treated for several years. As a result, 

individual infested areas adjacent to one another were combined to form one site, or treatment 

area, because they are likely to spread together. 

1-7 
Final Environmental Impact Statement 

1-8 

Figure 1-2: Diagram of treatment areas. 

Treatment 

Area 

Inv

Forest Service Road Vector of Spread 

asive Plant 

Infestations 

In addition to the treatment areas known to be infested with invasive plants, additional 

infestations are likely to be found. These additional infestations may be newly inventoried 

infestations or areas containing newly established invasive plant species, such as garlic mustard 

or false broom. These additional infestations pose the same threats associated with currently 

known invasive plant infestations. 

Without action, therefore, invasive plant populations would continue to spread on the Forest and 

Scenic Area, which would compromise our ability to manage the Forest and Scenic Area for 

healthy native plant communities and ecosystems and would contribute to the spread of invasive 

plants to neighboring lands. As a result, there is an underlying need on the Forest and Scenic 

Area for: 

1. Reduction of invasive plant species at the 208 known sites on the Forest and Scenic Area 

by utilizing the treatment strategies of eradicate, control, contain, and suppress (defined 

below); and 

2. Timely treatment of new/additional invasive plant sites that may be identified in the 

future through an Early Detection/Rapid Response strategy. 

Restoration of healthy, native communities and functions at sites impacted by invasive plants 

would occur as a connected action. 
Site-Specific Invasive Plant Treatments 

The treatment strategies taken from the Invasive Plant FEIS (2005a) (page 3-78) are defined as: 

• Eradicate: Attempt to totally eliminate an invasive plant species from the Forest and 

Scenic Area, recognizing that this may not actually be achieved in the short-term since 

re-establishment/re-invasion may take place initially. 

• Control: Reduce the infestation over time; some level of infestation may be acceptable. 

• Contain: Prevent the spread of the invasive plants beyond the perimeter of patches or 

infestation areas mapped from inventories as November 2004. 

• Suppress: Prevent seed production throughout the target patch and reduce the area 

coverage. Prevent the invasive species from dominating the vegetation of the area; low 

levels may be acceptable. 

Desired Future Condition 

By meeting the purpose and need for this project, the Forest and Scenic Area should be able to 

achieve the desired future condition. The desired future condition is an adaptation from USDA 

Forest Service, Invasive Plant ROD (2005a), page Appendix 1-1. 

• To retain healthy native plant communities that are diverse and resilient; 

• To restore ecosystems that are being damaged; and 

• To reduce the need for invasive plant treatment efforts. 

For example, two years ago the orange hawkweed infestation in the Mt. Hood Wilderness area 

was discovered. Over the past two years, volunteer and USDA Forest Service employees have 

pulled individual plants; however, the infestation continues to grow and continues to displace 

native ground cover in the Burnt Lake trail area. By meeting the desired future condition, the 

orange hawkweed site would be eradicated and the native plants would be restored, which would 

improve Wilderness characteristics, wildlife habitat, soil productivity, and water quality. Another 

example is the Sandy River Delta (SRD). Over 1,000 acres of the 1,500 acre area is infested with 

a wide variety of invasive plants, including Canada thistle, scotch broom, reed canarygrass, 

Himalayan blackberry, and common tansy. Given the number and extent of invasive plants, 

treatment needs to be aggressive and the proper tools need to be used. Restoring the native plant 

community would increase wildlife and aquatic habitat, improve soil productivity and water 

quality, and maintain scenic integrity. 

The desired future condition is illustrated in the following picture series (Figure 1-3) from the 

SRD. This small area in the SRD was treated using mechanical means. The new tools assessed in 

this EIS would allow the aggressive treatment of invasive plants throughout the SRD, rather than 

just within small, isolated pockets.

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Final Environmental Impact Statement 

1.3 Proposed Action 

The action proposed by the USDA Forest Service to meet the first part of the purpose and need is 

to treat the 208 treatment areas (13,000 acres) with integrated weed management (IWM) 

methods. All treatment areas are analyzed in Chapter 3. Only the area actually containing 

invasive plants would be treated in any given year. As a result, the area impacted by treatments is 

likely to be less than the total treatment acres. For example, in the SRD approximately 1000 

acres are infested with invasive plants; however, the entire SRD (approximately 1500 acres) is 

being analyzed to allow for treatment if the invasive plants spread to new areas of the SRD. 

The proposed treatment of these invasive plant sites would eradicate, control or contain invasive 

plants and restore native vegetation to discourage re-infestations. Treatment of invasive plants 

includes a combination of manual (e.g., hand pulling, cutting), mechanical (e.g., mowing, 

brushing, weed eating), cultural (goat grazing), and herbicide (e.g., broadcast spraying, spot 

spraying) treatment methods. Site-specific treatment prescriptions are based on the biology of 

particular invasive plant species, site location, size of the infestation, and proximity to water. 

Treatments would be designed to reduce the adverse effects to fish, wildlife, and sensitive plant 

species by implementing Project Design Criteria (PDC) (Section 2.2), while maximizing the 

reduction of the invasive plants targeted. PDC are a set of required, implementation measures 

applied to projects to ensure that the project is done according to environmental standards and 

adverse effects are within the scope of those predicted in this EIS. 

1-10 
Site-Specific Invasive Plant Treatments 

Figure 1-3: Picture series illustrating desired future condition at Sandy River Delta. 

1992 – USDA Forest Service acquired 

Sandy River Delta with invasive species 

1995 – Sandy River Delta 

 infested with invasive plants 

Mowing invasive plants at Sandy River Delta DESIRED FUTURE CONDITION!

In addition, the treatment prescriptions would follow IWM methods. This is a process by which 

one selects and applies a combination of management techniques (manual, mechanical, and 

herbicide for example) that, together, would control a particular invasive plant species or 

infestation efficiently and effectively, with minimum adverse impacts to non-target organisms. It 

is species-specific, site-specific and designed to be practical with minimal risk. Treatments may 

be repeated over several years and up to three times in a given year until site treatment strategies 

are met. 

The following treatment methods are shown in order of preference, assuming the methods are 

effective and practical. 

1. Non-herbicide, non-ground disturbing treatment methods , specifically manual, 

mechanical and cultural (goat grazing) treatment methods; 

1-11 
Final Environmental Impact Statement 

2. Application of herbicides via hand/selective treatment methods (e.g., stem injection or 

spot spraying); 

• Application of low toxicity herbicides, such as clopyralid, imazapic, metsulfuron 

methyl, aquatic triclopyr, or aquatic imazapyr; 

• Application of moderate toxicity herbicides, such as aquatic glyphosate, 

chlorsulfuron, imazapyr, sulfometuron methyl; and 

• Application of more toxic herbicides, such as glyphosate, triclopyr, picloram, and 

sethoxydim. 

3. Application of herbicide via broadcast spraying treatment methods. Preference for 

herbicide choice would follow the same order as the hand/selective methods. 

Although the first preference is non-herbicide, non-ground disturbing methods, this EIS focuses 

analysis on herbicide treatments. On the Forest for the past 13 years and on the Scenic Area for 

the last 10 years, the USDA Forest Service has had the ability to treat invasive plants with nonherbicide methods using existing NEPA documents. These treatment methods, however, have 

not effectively treated the invasive plant infestations on the Forest or Scenic Area. In addition, 

research and anecdotal evidence have demonstrated that herbicide treatments have been found to 

be the most effective treatment for many of the invasive plants proposed for treatment (see 

Section 3.6 – Botany and Treatment Effectiveness). 

The treatments on a total of 12,963 acres are analyzed to include herbicide treatment methods in 

combination with non-herbicide treatment methods (manual, mechanical and cultural). In the 

Forest and Scenic Area, the proposed treatments (defined in Chapter 2) include: 

• 30 acres of herbicide only treatment; 

• 50 acres of manual and mechanical only treatment; 

• 310 acres of herbicide plus mechanical treatment; 

• 327 acres of herbicide plus manual treatment; 

• 1,510 acres of herbicide plus manual, mechanical and cultural treatment, where cultural 

treatments refers to goat grazing; and 

• 10,736 acres of herbicide plus manual and mechanical treatment. 

1-12 
Site-Specific Invasive Plant Treatments 

The herbicides considered for use are: chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, 

metsulfuron methyl, picloram, sethoxydim, sulfometuron methyl, and triclopyr. The herbicides 

are proposed for each treatment area based on the information provided in Invasive Plant FEIS 

(2005a), and Common Control Measures for Invasive Plants of the Pacific Northwest Region

(Mazzu, 2005). The Common Control Measures serves as the basis for the IWM proposed 

treatments. 

In addition to the treatment methods, each treatment area has a restoration objective, which is 

part of the long-term strategy to reduce invasive plants. The restoration objectives may either be 

passive or active restoration. Passive restoration assumes the treatment area would revegetate 

from existing non-invasive vegetation without mulching, planting, or seeding. Active restoration 

is site-specific and may include seeding, planting, and/or mulching (see Section 2.1.3). 

The action proposed by the USDA Forest Service to meet the second part of the purpose and 

need includes an Early Detection / Rapid Response strategy (EDRR) that would be used to treat 

newly inventoried invasive plant sites that are unknown at this time and/or new infestations that 

become established in the future. Sites that are discovered subsequent to the last invasive plant 

inventory, completed in November 2004, would require evaluation to determine if the invasive 

plant treatments and environmental impacts are consistent with those analyzed in this EIS. If the 

sites and impacts are found to be consistent, then these new infestations could be treated without 

completing another NEPA document. 

Overall, treatment would not exceed 30,000 acres of the project area over 15 years for both 

known and future infestations. It is estimated that 50 percent of the Forest likely to be infested 

with invasive plants had been inventoried (Stein, 2005). The inventoried areas include roads, 

campgrounds, quarries, and timber sales. The inventory includes only limited forested areas, 

designated Wilderness Areas and recreational trails. Assuming that the infestations on the 

remaining 50 percent of the likely infested areas (e.g., roads and quarries) follow a similar 

pattern and assuming that the Scenic Area mirrors the Forest, only an additional 13,000 acres 

would be infested with invasive plants in the future. In order to account for the uncertainty and 

unpredictability associated with invasive plants and their treatments, the treatments acres were 

expanded by an additional 15 percent (4,000 acres): 1 percent of unexpected infestations per year 

for the life of the project. Combining the known infestations (13,000 acres), future estimate 

(13,000 acres), and expansion acres (4,000), the total landscape assessed to be treated is 30,000 

acres on the Forest and Scenic Area. 

Within this overall cap of 30,000 acres over 15 years, there are several additional treatment caps 

(limitations) to ensure the treatment does not exceed the impacts analyzed in Chapter 3. These 

caps include annual, fifth-field watershed, and riparian reserve limitations. 

• Annual cap: The annual treatments would not exceed 13,000 acres within the Forest and 

Scenic Area: these treatments would be a combination of known treatment sites and 

newly discovered newly inventoried treatment sites. This limitation was chosen because 

Chapter 3 analyzes the effects of treating 13,000 acres, so the effects are known. 

1-13 
Final Environmental Impact Statement 

• Fifth field watershed cap: Treatment would not exceed three percent per year in any one 

fifth-field watershed. If the areas of National Forest System lands within each fifth-field 

watershed are less than three percent, treatment would not exceed the amount of National 

Forest Service lands (see Table 2-9 for specifics for each watershed). This limitation was 

chosen because Chapter 3 analyzes the effects of treating three percent of some fifth-field 

watersheds, so the effects are known. 

• Riparian reserve cap: Treatment would not exceed 5,000 acres in riparian reserves each 

year. Only 40 percent of the total area treated in each fifth-field watershed could be 

located in a riparian reserve for the life of the project. 

Note: The acres treated each year would be based on the infestations and invasive plant 

budget. Acres would not be treated if invasive plants are not present. 

For each cap, each acre treated would only be counted once. For example, if a treatment area of 

100 acres is treated 3 times annually, only 100 acres would be counted towards the 13,000 acre 

annual cap. 

In addition to the caps, triggers and thresholds are designed to prescribe the potential treatment 

methods that would be effective and ensure that treatments would be consistent with those 

analyzed in this EIS. If the proposed treatments are outside these triggers and thresholds, new 

NEPA analysis and disclosure would be required. Examples include conducting invasive plant 

treatments that could not be fully mitigated using the PDC; aerial spraying herbicides; using 

prescribed burning, tilling, plowing, or cattle grazing as invasive plant treatment methods; 

treating more than the designated acres (e.g., 13,000 per year); applying herbicides not analyzed 

in EIS; or applying herbicides within Bull Run hydrologic unit. Annually, the Forest and Scenic 

Area would identify sites for potential treatment (both known and newly inventoried) and review 

the criteria for appropriateness of prescribed methods to ensure consistency and effectiveness for 

each site. All recommended treatment methods would be documented and approved by the 

appropriate responsible official(s). Section 2.1.3 and 2.1.4 contain more details on the EDRR. 

Specific invasive plant treatments for each treatment area, including those identified through 

EDRR, would be determined using the decision key outlined in Figure 1-4. This decision key 

also would be used to determine if newly identified sites are consistent with those analyzed in 

this EIS. 

1-14 
Site-Specific Invasive Plant Treatments 

Figure 1-4: Decision key for Invasive Plant Treatments, including Early Detection/Rapid 

ResponseStrategy. Modified from the Salmon-Challis National Forest Environmental 

Assessment, USDA Forest Service, 2003. 

Decision Key 

Step 1A: Determine the best treatment method based on the invasive plant species present and size of 

the infestation, using Common Control Measures (Mazzu, 2005). Determine the treatment 

strategy (eradicate, control, contain or suppress). Can the treatment strategy be achieved 

using non-herbicide, non-ground disturbing treatment methods, specially manual, mechanical 

and cultural (goat grazing) treatment methods? 

 Yes: Continue to Step 10.

 No: Continue to Step 1B. 

Step 1B: Determine the best herbicide treatment method to achieve the treatment strategy, using the 

Common Control Measures (Mazzu, 2005). Can the treatment strategy be achieved using 

treatment methods with least impacts, such as hand/selective treatment methods (e.g., stem 

injection or spot spaying)? 

 Yes: Continue to Step 1C. 

 No: Document reasons for using treatment methods with more impacts, herbicides applied 

via broadcast spraying. Continue to Step 1C. 

Step 1C: Determine the most appropriate herbicide to achieve the treatment strategy, using the 

Common Control Measures (Mazzu, 2005). Can low toxicity herbicides, such as clopyralid, 

imazapic, metsulfuron methyl, aquatic triclopyr, or aquatic imazapic, achieve the treatment 

strategy? 

 Yes: Continue to Step 2. 

 No: Continue to Step 1D. 

Step 1D: Can moderate toxicity herbicides, such as aquatic glyphosate, chlorsulfuron, imazapyr, and 

sulfometuron methyl, achieve the treatment strategy? 

 Yes: Continue to Step 2. 

 No: Use one of the more toxic herbicides, such as glyphosate, triclopyr, picloram, or 

sethoxydim, for herbicide treatment. Continue to Step 2. 

Step 2: If the treatment area was identified in the November 2004 inventory and analyzed in this EIS, 

have any site conditions changed? (See Appendices C and K) 

If the treatment area was identified through the EDRR, continue to Step 3. 

 Yes: Continue to Step 3. 

 No: Continue to Step 8. 

1-15 
Final Environmental Impact Statement 

Step 3: Is the treatment method analyzed in this EIS? 

 Yes: Continue to Step 4. 

 No: Choose another treatment method OR conduct additional NEPA on treatment methods 

(e.g., prescribed burning, aerial applications). 

Step 4: Is there an unforeseen combination of physical conditions (e.g., disturbance, distance to 

water, slope, and soils) that is not addressed in the PDC (Section 2.2 – Project Design 

Criteria)? 

 Yes: Conduct additional NEPA on proposed treatment area and treatment method OR

abandon treatment. 

 No: Continue to Step 5A. 

Step 5A: Is the site in a designated Wilderness Area? 

 Yes: Continue to Step 5B. 

 No: Continue to Step 6. 

Step 5B: If action is not taken, would the natural processes of the Wilderness Area be adversely 

affected? 

 Yes: Continue to Step 6. 

 No: Continue to Step 5C. 

Step 5C: Is there imminent risk of invasive plants spreading outside the Wilderness Area? 

 Yes: Continue to Step 6. 

 No: Monitor invasive plant infestation. 

Step 6: Are special status fish, wildlife or plant species, designated critical and essential fish habitat, 

or heritage resources present? Special status species are threatened, endangered and 

proposed species; USDA Forest Service Pacific Northwest sensitive species; management 

indicator species; Survey and Manage species; and other rare or endemic species of 

concern. This is determined using maps and/or site conditions (See Appendices C and K) 

 Yes: Use treatment methods that pose low or negligible risk to fish, wildlife and plant 

species, water, and heritage resources. Examples include use of selected herbicides 

(e.g., clopyralid, imazapic, metsulfuron methyl, aquatic triclopyr, or aquatic imazapic), 

manual or mechanical treatments, in conjunction with PDC. Continue to Step 7.

 No: Continue to Step 7. 

1-16 
Site-Specific Invasive Plant Treatments 

Step 7: Are surveys required for special status species? 

 Yes: Conduct necessary surveys. Evaluate results of surveys. If surveys illustrate a risk to 

the species surveyed, use treatment methods that pose low or negligible risk to fish, 

wildlife and plant species. Examples include use of selected herbicides (e.g., clopyralid, 

imazapic, metsulfuron methyl, aquatic triclopyr, or aquatic imazapic), manual or 

mechanical treatments, in conjunction with PDC. Continue to Step 8.

 No: Continue to Step 8. 

Step 8: Is the proposed treatment area in a municipal watershed or designated irrigation district?

 Yes: Notify the municipal watershed and irrigation districts of proposed treatments. Ensure 

all applicable, existing agreements are being implemented and followed. 

 No: Continue to Step 9. 

Step 9A: Is the proposed treatment within the designated annual treatment caps of 13,000 acres per 

year?

 Yes: Continue to Step 9B.

 No: Conduct additional NEPA on additional treatment acres OR abandon treatment. 

Step 9B: Is the proposed treatment within the allowable treatment acres in each fifth-field watershed? 

(See Table 2-9) 

 Yes: Continue to Step 9C.

 No: Conduct additional NEPA on additional treatment acres OR abandon treatment. 

Step 9C: Is the proposed treatment within the designated annual riparian reserve cap of 5,000 acres 

with only 40 percent of the total area treated in each fifth-field watershed being located in a 

riparian reserve? Is the proposed treatment within the overall cap of 40 percent of each fifthfield watershed for the life of the project? 

 Yes: Continue to Step 9D.

 No: Conduct additional NEPA on additional treatment acres OR abandon treatment. 

Step 9D: Is the proposed treatment within the overall project cap of 30,000 acres over 15 years? 

 Yes: Continue to Step 10.

 No: Conduct additional NEPA on proposed treatment area and treatment method OR

abandon treatment. 

Step 10: Document treatment methods for each treatment area. If treatment area is identified using the 

EDRR, prepare a document demonstrating how the new treatment is within the scope of the 

original NEPA decision. Post treatment sites and consistency documentation on websites, as 

specified in PDC. Continue to Step 11. 

1-17 
Final Environmental Impact Statement 

Step 11: Implement invasive plant treatment and all appropriate PDC. Is active restoration necessary? 

 Yes: Implement appropriate restoration strategies as outline in Section 2.1.3, in conjunction 

with PDC. Continue to Step 12. 

 No: Allow passive restoration to revegetate treatment site. Continue to Step 12.

Step 12: Implement monitoring framework as outlined in Section 2.3. Are invasive plants present at the 

time the treatment area is monitored? 

 Yes: Continue to Step 1.

 No: Continue to Step 13. 

Step 13: Implement monitoring framework for restoration as outlined in Section 2.3. Is the restoration 

strategy effective? 

 Yes: Healthy, native plant communities and function have been restored.

 No: Continue to Step 11. 

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Site-Specific Invasive Plant Treatments 

1.4 Management Direction 

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

National Forest Management Act (NFMA), National Environmental Policy Act (NEPA), Council 

on Environmental Quality regulations, Wilderness Act, Columbia River Gorge National Scenic 

Area Act, Clean Water Act, and Endangered Species Act. The EIS is tiered to the Mt. Hood 

National Forest Land and Resource Management Plan Final Environmental Impact Statement 

and Record of Decision, and incorporates by reference the accompanying Land and Resource 

Management Plan (1990) (also called the Forest Plan), as amended by the Northwest Forest Plan 

(1994). The Forest Plan guides all natural resource management activities and establishes 

management standards and guidelines for the Forest. It describes resource management practices, 

levels of resource production and management, and the availability and suitability of lands for 

resource management. The Northwest Forest Plan identifies land allocations and management 

direction to respond to the underlying needs of managing substantial parts of these forests for 

late-successional and old-growth conditions, for a predictable and long-term supply of timber. 

Also, the EIS is tiered (where appropriate) to the Columbia River Gorge National Scenic Area 

Management Plan (1992, 2004). The Scenic Area Management Plan includes guidelines and land 

use designations for the General Management Areas and Scenic Management Areas for scenic, 

cultural, natural and recreational resources contained on the agricultural, forest, residential and 

commercial lands found with the Congressionally designated area. The project is consistent with 

all applicable Federal, state and local laws. 

Invasive plant management direction on the Forest and Scenic Area is provided by the Invasive 

Plant ROD (2005b). This ROD releases the USDA Forest Service from direction provided by the 

1988 Environmental Impact State and 1988 Record of Decision for Competing and Unwanted 

Vegetation, and the associated 1989 Mediated Agreement for invasive plant management. The 

portions of the 1988 Record of Decision and 1989 Mediated Agreement that apply to unwanted 

native vegetation are not impacted by the new decision or this project. The new invasive plant 

direction is provided in the form of desired future condition statement, standards for the 

prevention and management of invasive plants, and inventory and monitoring framework 

(Appendix 1, Invasive Plant ROD, 2005b). The management direction includes invasive plant 

prevention and treatment/restoration standards intended to help achieve the desired future 

conditions, goals and objectives. The management direction is expected to result in decreased 

rates of spread of invasive plants, while protecting human health and the environment from the 

adverse effects of invasive plant treatments. Through this management direction, new invasive 

plant treatment tools are provided for all National Forest System lands in Oregon and 

Washington. This site-specific EIS tiers to the Invasive Plant ROD (2005b) and Invasive Plant 

FEIS (2005a) in order “to eliminate repetitive discussions of the same issues and to focus on the 

actual issues ripe for decision at each level of environmental review” (40 CFR 1520.20). 

A decision to implement Alternative 2 (the Proposed Action) or Alternative 3 (the Restricted 

Herbicide Use Alternative) would replace the management direction provided in the 

Environmental Assessment for the Management of Noxious Weeds, Mt. Hood National Forest 

(USDA Forest Service, 1993a) and the Environmental Assessment for the Application of 

Herbicides for the Control and Management of Noxious Weeds on the Barlow Ranger District, 

1-19 
Final Environmental Impact Statement 

Mt. Hood National Forest (USDA Forest Service, 1998b). The Environmental Assessment for 

the Control and Management of Noxious Weeds and Blackberries on Selected Lands within the 

Columbia River Gorge National Scenic Area (USDA Forest Service, 1996c) and 1999 

amendment remains in effect for the Washington lands in the Scenic Area. Also, this decision 

would replace direction for invasive plant treatment methods described in the Sandy River Delta 

EIS (USDA Forest Service, 1995e). Treatment methods not analyzed in this EIS (e.g., heavy 

machinery) that were analyzed in the Sandy River Delta EIS would remain in effect. Finally, the 

Environmental Impact Statement on the Transmission System Vegetation Management Program, 

Bonneville Power Administration (2001) would not be impacted by the decision resulting from 

this analysis; however, additional treatment methods, as analyzed in this EIS, could be used in 

this area. All these environmental documents are discussed in Section 2.1.2. 

The recent court case Washington Toxics Coalition, et al. vs. U.S. Environmental Protection 

Agency (Case No. C01-0132C) regarding listed salmon species and the use of pesticides does 

not impact any of the actions proposed in this EIS. The order from January 22, 2004 specifically 

excludes noxious weed programs and allows the “use of pesticides for control of state-designated 

noxious weeds as administered by public entities, when such control program implements the 

following safeguards that NMFS (National Marine Fisheries Service) routinely requires for such 

programs: 

1. Aerial application cannot occur within 100 yards of Salmon Supporting Waters; 

2. Broadcast spraying cannot occur within 20 yards of Salmon Supporting Waters or when 

wind speeds are greater than five miles per hour; 

3. Chemical spraying cannot occur within 15 feet of Salmon Supporting Waters or when 

wind speeds are greater than five miles per hour; 

4. Only those Pesticides registered by EPA under the Federal Insecticide Fungicide, and 

Rodenticide Act (“FIFRA”), 7 U.S.C. §§ 136-136(y), for aquatic application can be used 

within 15 feet of Salmon Supporting Waters; 

5. Pesticides cannot be used when precipitation is occurring or is forecast to occur within 24 

hours; 

6. All spraying operations must be overseen by a certified applicator; and 

7. For 2,4-D and triclopyr, only the amine formulations of 2,4-D and triclopyr can be used.” 

Theses safeguards are incorporated into the PDC and through consultation with regulatory 

agencies, including NMFS and U.S. Fish and Wildlife Service (Page 9-10 of Court Order, 

January 22, 2004). 

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Site-Specific Invasive Plant Treatments 

1.5 Management Standards and Guidelines 

The Invasive Plant FEIS (2005a) defines pesticide as “any substance or mixture of substances 

intended to prevent, destroy, repel, or mitigate any pest; or any substance or mixture of 

substances intended for use as a plant regulator, defoliant, or desiccant.” The Invasive Plant FEIS 

(2005a) defines an herbicide as “a chemical preparation designed to kill plants, especially weeds, 

or to otherwise inhibit their growth”. Based on these definitions, six standards and guidelines in 

the Forest Plan (Table 1-2) currently discourage or prohibit the use of pesticides, including 

herbicides, on the Forest. 

Table 1-2: Forest Plan Standards and Guidelines discouraging or prohibiting pesticide 

use. 

Standard & Guideline 1 Page # 

Water (FW-076): Potentially detrimental materials associated with management 

activities (e.g. pesticides, fertilizers, and road surface treatments) shall be 

prevented from entering water or other areas not intended for treatment. 

4-57 

Wilderness (A2-082): Pesticides use shall be prohibited. 4-142 

Outdoor Education Areas (A12-031): Herbicides should not be applied outside of 

roads rights-of-way. 4-200 

Pileated Woodpecker/Pine Marten Habitat (B5-041): Herbicides should not be 

permitted outside of road rights-of-way. 4-244 

General Riparian Area (B7-070): Application of herbicides shall be discouraged. 4-260 

Vegetation Management (A1-WR-064): Chemicals shall not be used to control 

noxious weeds in riparian areas Amendment #7 

A Forest Plan amendment of these standards and guidelines are proposed for both the Proposed 

Action and Restricted Herbicide Use Alternatives to allow for careful and targeted herbicide use 

to treat the invasive plants identified, in conjunction with the required PDC and according to the 

standards from the Invasive Plant ROD (2005b) (see Appendix A – Standards from Preventing 

and Managing Invasive Plant Record of Decision, 2005) 

 

1

 Shall is defined as: “Action is mandatory!” Should is defined as: “Action is required; however, case by case 

exceptions are acceptable if identified during interdisciplinary project planning environmental analyses. 

Exceptions are to de documents in environmental analysis (National Environmental Policy Act 1969) public 

documents.” [Page Four – 45, Forest Plan.] 

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Final Environmental Impact Statement 

In addition, sixteen Forest Plan standard and guidelines discuss pest management. Based on the 

language of the standard and guideline, the context in the Forest Plan, and definitions provided 

by the Invasive Plant FEIS (2005a) these standards and guidelines do not apply to invasive plant 

management, but do apply to pest, insect and disease management. The standards include: FW550/551, A2-112, A3-050, A3-051, A4-046, A5-040, A6-037, A7-029, A9-044, A10-030, B3-

042, B4-053, B6-041, B7-068, and EA1. This EIS does not amend any of these standards. 

The Columbia River Gorge National Scenic Area Management Plan states “County, State and 

Federal regulations . . . for pesticide use shall be followed” (page I-81). Since all actions being 

considered follow all applicable Federal, state and local laws, the EIS is consistent with the 

direction specific for the Scenic Area. 

All of the applicable standards and guidelines from the Forest Plan and Northwest Forest Plan 

that pertain to this project are contained in Appendix B; all the applicable standards from the 

Scenic Area Management Plan are contained in Appendix C. These standards and guidelines 

cover all resource areas analyzed in this EIS. In addition, all watershed assessments prepared 

using the Northwest Forest Plan were reviewed and found to be consistent with the Proposed 

Action and alternatives. 

1.6 Decision Framework 

The Forest Supervisor for the Mt. Hood National Forest and the Area Manager of the Columbia 

River Gorge National Scenic Area are the responsible officials for this EIS. Given the purpose 

and need, the responsible officials review the Proposed Action, alternatives to the Proposed 

Action, and the environmental consequences in order to make the following decisions: 

• Would this project be implemented as proposed, as modified by an alternative, or not at 

all? 

• What PDC and monitoring requirements would the USDA Forest Service apply if this 

project is implemented? 

• What amendments, if any, to the Forest Plan or the Scenic Area Management Plan as 

amended by the Invasive Plant ROD (2005b) are required to implement this project? 

Factors influencing the decision on selection of an alternative include: 

• How well the alternative meets the purpose and need for action; 

• Potential effects of treatment to the environment; and 

• Economic efficiency of treatments. 

1-22 
Site-Specific Invasive Plant Treatments 

1.7 Public Involvement 

Public involvement has occurred throughout the NEPA process. The project was included in the 

winter 2003 and spring 2005 Schedule of Proposed Actions distributed by the Forest. Two 

Notices of Intent (NOI) requesting public comment were published in the Federal Register on 

February 23, 2004 and updated on April 29, 2005. Information on the proposal was posted on a 

project website (http://www.fs.fed.us/r6/invasiveplant-eis/site-specific/MTH/), and provided via 

direct mailing to approximately 1,200 individuals, organizations, agencies, businesses, 

recreational residence owners, and local and Tribal governments. 

Due to the complexity of the Proposed Action, additional public involvement steps were taken to 

solicit public input during the analysis phases. An update letter was mailed to approximately 150 

addresses, including all respondents to both scoping letters and county noxious weed 

coordinators. Also, meetings were held with governmental agencies, tribes, and organizations to 

discuss the project in greater detail. 

The DEIS was available for public comment from May 26 to July 13, 2006. The Notice of 

Available (NOA) initiating the 45-day comment period was published in the Federal Register on 

May 26, 2006. Approximately 22 hardcopies of the documents, 191 CDs, and 977 summaries 

were either mailed or delivered to individuals, organizations, interested Tribes, and government 

agencies. All recreational residence permitees, approximately 550 people, received a summary or 

CD announcing the project. In addition, the document was made available on the Mt. Hood 

National Forest website (http://www.fs.fed.us/r6/mthood/projects/) and the project website 

(http://www.fs.fed.us/r6/invasiveplant-eis/site-specific/MTH/). Hard copies of the document 

were made available for public viewing at six USDA Forest Service offices. 

In addition, the USDA Forest Service hosted two open houses on June 8, 2006 in Hood River 

and June 19, 2006 in Sandy. Press releases announcing these meetings were distributed to local 

newspapers on May 26, June 6 and June 14, 2006. Announcements of the meetings appeared in 

the Sandy Post, Hood River News and The Oregonian. 

During the pubic comment period 25 responses were received. Resource specialist reviewed and 

responded to the comments and, in many cases, made changes to the EIS as a result. The 

comments and responses as well as all governmental agency responses (Federal, State and local) 

can be found in Appendix Z – Response to Comments. 

All mailing lists are available in the project file, located in the Mt. Hood National Forest 

Headquarters Office in Sandy, Oregon. 

1-23 
Final Environmental Impact Statement 

1.8 Issues 

NEPA directs federal agencies to focus analysis and documentation of significant issues related 

to the Proposed Action. The scoping process resulted in the identification of some potential 

issues to be addressed in the EIS. An “issue” arises from the relationships between actions 

(proposed, connected, similar, cumulative) and environmental consequences (physical, 

biological, cultural, and socioeconomic). In this EIS, issues are defined as points of discussion, 

debate, or dispute about the environmental effects of the Proposed Action. The issues are divided 

into three groups: key, resolved and tracking issues. 

Key issues are those that are within the scope of the Proposed Action and suggest the need to 

consider different actions or project design criteria. Key issues as used in this EIS are those that 

are used to formulate alternatives, affect the design of alternative components, prescribe PDC, or 

describe environmental effects. Key issues are identified as such due to their geographic 

distribution, duration of effects, intensity of interest by the public, or resource area conflict. 

Alternative 3 (Restricted Herbicide Use Alternative) was designed to address the key issues. 

Resolved issues are significant issues identified by the public that have been fully mitigated 

through the development of alternatives or PDC. As such, these issues do not have any 

measurable impacts or environmental consequences. 

Tracking issues are those that have been determined to be relevant, but are not used to formulate 

alternatives. These issues often describe minor or consistent consequences among alternatives 

considered in detail. These issues usually are addressed through adherence to standards and 

guidelines, appropriate laws and regulations, consistency with decisions made in the Invasive 

Plant ROD (2005b), or as covered by the PDC. Tracking issues are generally of interest or 

concern to the public, and are tracked throughout the document. 

In addition, issues outside the scope of this analysis were identified. The Council of 

Environmental Quality requires the USDA Forest Service to identify and eliminate from detailed 

study issues that are not significant (40 CFR 1501.7). Issues may be eliminated from further 

analysis when the issue is outside the scope of the EIS; are already decided by law, regulation, 

Forest Plan, or other higher level decision; are not clearly relevant to the decision to be made; or 

are conjectural and not supported by good scientific or factual evidence. These issues raised 

through the scoping process are discussed briefly. 

The key, resolved and tracking issues as well as issues outside the scope are listed and 

summarized below. 

1-24 
Site-Specific Invasive Plant Treatments 

Key Issues 

Key Issue 1 − Treatment Effectiveness 

Invasive plant treatments can vary in effectiveness, depending on the invasive species to be 

treated, size of the population/infestation, method of treatment, and a host of other factors 

including timing, weather, soils, and moisture. The choice of treatment methods in combination 

with other factors needs to reflect a balance between optimum effectiveness and protection of the 

desirable botanical resources. The proposed alternatives and treatment methods vary in how well 

they provide the tools to effectively treat invasive species and protect natural resources, 

including water quality, fish, wildlife, soil productivity, and native plant communities. 

Further, the presence and spread of invasive plants within the Forest and Scenic Area may affect 

the presence and spread of invasive plants on neighboring ownerships. The effectiveness of 

treatments would influence if and to what degree invasive plants might spread to other 

ownerships. 

Indicators for Comparing Alternatives 

• Treatment methods proposed 

• Acres of invasive plants treated using herbicides 

• Effectiveness of invasive plant treatments and treatment method combinations 

• Restoration potential for establishment of native plants to prevent future infestations 

• Likelihood for invasive plants to spread to adjacent ownerships

Discussion of the issues can be found in Section 3.6 – Botany and Treatment Effectiveness. 

1-25 
Final Environmental Impact Statement 

Key Issue 2 – Economic Efficiency 

Invasive plant treatments vary in cost, which affects the acreage that could be effectively treated 

each year given a set budget. The proposed treatments would be costly and fiscal resources are 

always limited. In addition to cost efficiency, the treatment methods vary in the amount of 

employment provided. Increasing the number of jobs could benefit local communities that are 

suffering from reduced employment levels. 

Indicators for Comparing Alternatives 

• Cost of treatments 

• Number of full-time jobs created (measured as $20,000 per year)

Discussion of this issue can be found in Section 3.7 – Economic Efficiency. 

Key Issue 3 – Water Quality and Aquatic Organisms 

The application of herbicides in riparian areas has the potential to contaminate water and cause 

mortality to fish and other aquatic species. Herbicides that do not directly affect fish may affect 

their food chain through lethal effects to aquatic insects, plants, or algae. Sub-lethal effects, such 

as behavior changes, could result in increased vulnerability to predators. Fish and other aquatic 

organisms may also be impacted by manual and mechanical treatments, which may change 

dissolved oxygen levels, nutrients, water temperature, turbidity, fine sediment, and riparian 

structure. 

Indicators for Comparing Alternatives 

• Acres of herbicide treatment in riparian reserves at known sites 

• Acres of herbicide treatments within aquatic influence zone at known sites 

Aquatic influence zone is the 100 feet closest to a water source. 

• Number of treatment sites with a higher risk of effects from herbicides to aquatic 

organisms 

Discussion of this issue can be found in Section 3.9 – Water Quality and Section 3.10 – Aquatic 

Organisms and Habitat. 

1-26 
Site-Specific Invasive Plant Treatments 

Resolved Issues 

Human Health and Safety 

Invasive plant treatments within the Forest and Scenic Area may result in health risks to forestry 

workers and the public, including contamination of special forest products and drinking water. 

The health and safety of forestry workers and the public may be at risk from exposure to 

herbicides. The public expressed particular concern about human health effects related to the 

toxicity of herbicides and drinking water contamination. Public concern for drinking water 

contamination is high for the Forest, since it serves as a drinking water source for a third of 

Oregonians. Implementing the PDC, as required by the alternatives, would mitigate any possible 

impacts to human health and safety. 

Additional information is available in Section 3.5 – Human Health and Safety. 

Accidental Herbicide Spills 

Accidental spills may cause serious harm to human health and the environment. Accidental spills 

are an inherent risk of using herbicides. Herbicide spills are not an intended action associated 

with invasive plant management. The PDC discussed in Section 2.2 include measures to prevent 

accidental spills as well as response measures to reduce the impacts of a spill. The PDC require a 

pre-operation briefing, herbicide emergency spill response plan, mixing locations, transportation, 

and public notification. Examples include: 

• A pre-operations briefing would be required annually and documented prior to treatment. 

The briefing would include safety issues, location, timing, treatment methods, herbicides 

approved for use, PDC, and other pertinent topics. 

• Applicators would have an Herbicide Emergency Spill Response Plan, approved by the 

USDA Forest Service, on-site during operations. 

• Spray tanks would not be washed or rinsed within 150 feet of any live water. 

• No more than daily use quantities of herbicide would be transported to the project site. 

• Signs notifying the public of herbicide treatments would be placed at access points to 

treatment areas prior to initiating treatment, a minimum of one week in advance of 

herbicide treatment. 

Additional information is available in Section 2.2 – Project Design Criteria. 

1-27 
Final Environmental Impact Statement 

No Herbicide Treatment in Municipal Watersheds 

Applying herbicides to invasive plants located within municipal watersheds, especially the Bull 

Run Watershed, may degrade drinking water. Existing Forest Plan standards and guidelines, and 

the Restricted Herbicide Use Alternative (Alternative 3) address this concern. Effects of 

proposed treatments to drinking water and water quality within municipal watershed are 

analyzed through the three alternatives considered. 

• No treatment areas are proposed within the Bull Run watershed (physical drainage) 

where the drinking water source is located. The Forest Plan standard (D-021) stating that 

“chemical insecticides and herbicides shall be prohibited within the Bull Run physical 

drainage” would remain in effect without any changes. 

• Six treatment areas are located in part of The Dalles Municipal Watershed. Five of these 

treatment areas are on the road system adjacent to the watershed and one site is located 

entirely within the watershed. None of these treatment areas are proposed for herbicide 

treatments under Alternative 3. 

Additional information is available in Section 3.5 – Human Health and Safety and Section 3.9 – 

Water Quality. 

Public Notification 

The application of herbicides raises many public concerns; informing the public of invasive plant 

treatments would help alleviate some concerns. Information regarding location, time, and 

treatment method/type should be provided before treatments begin. Public notification is a 

required component of the PDC. 

Additional information is available in Section 2.2 – Project Design Criteria. 

Tracking Issues 

Native Plant Communities 

Invasive plant treatments, especially herbicides may harm non-target plants, including culturally 

significant and special status species (USDA Forest Service Pacific Northwest sensitive plants, 

Survey and Manage plant species, federally listed plant species, and plants endemic to the Forest 

and Scenic Area). Different herbicides have varying degrees of potency and selectivity (e.g., 

some herbicides affect certain plant families more readily than others), and application methods 

vary in the potential for off-site drift. As invasive plants decrease, native plants are expected to 

benefit through increased habitat. 

Discussion of this issue can be found in Section 3.6 – Botany and Treatment Effectiveness. 

1-28 
Site-Specific Invasive Plant Treatments 

Wildlife Species 

The use of herbicides to treat invasive plants, if used in the certain habitats, could harm a variety 

of wildlife species. Late successional, wetland, talus, and aquatic habitats have special status 

species that may be affected by herbicides. Certain herbicides have the potential, for example, to 

affect the vital organs of some wildlife species, change body weight, reduce the number of 

healthy offspring, increase susceptibility to predation, or cause direct mortality. Wildlife, 

especially birds and mammals, may ingest vegetation or insects that have been sprayed with 

some herbicides and potentially experience these types of effects. Amphibians have semipermeable skin that can absorb chemicals that affect them, but herbicide effects to amphibians 

have not been thoroughly tested. Aquatic life stages of amphibians are susceptible to chemicals, 

but very little information has been documented on the effects of herbicides. 

Discussion of this issue can be found in Section 3.11 – Wildlife. 

Soil Productivity 

Healthy soil organisms are fundamental to the ability of soil to provide water and nutrients to 

plants. All herbicides potentially can affect soil microorganisms. Manual and mechanical 

treatments may cause soil disturbance and/or erosion. Due to these potential impacts and the 

removal of vegetation, slope stability may be impacted. 

Discussion of this issue can be found in Section 3.8 – Soils Productivity. 

Tribal/Treaty Rights and Environmental Justice 

Protecting and maintaining traditional uses of plants, animals, fish, and water rights on tribal 

reservation lands and the treaty rights of American Indian Tribes is a trust responsibility of the 

Federal Government. The Confederated Tribes of Warm Springs have rights outside the bounds 

of their Indian reservation on ceded as well as usual and accustomed sites on the Forest. Invasive 

plant treatments have varying impacts to culturally significant plants, which include 

huckleberries (Vaccinium membranaceum), blue camas (Camassia species), and possibly 

bitterroot (Lewisia rediviva) for the Confederated Tribes of Warm Springs, Yakama Nation, 

Confederated Tribes of the Grand Ronde, Nez Perce Tribe, and Confederate Tribes of the 

Umatilla Indian Reservation. 

Executive Order 12898 (1994) requires federal agencies to identify and address adverse effects 

to human health and the environment that may disproportionately impact minority and lowincome people. Also, the Executive Order directs agencies to consider patterns of subsistence 

hunting and fishing when an agency action may affect fish and wildlife. Asian, Hispanic, and 

Native American communities may be impacted by invasive plant treatments. 

Discussion of this issue can be found in Section 3.14 – Tribal Relations, Civil Rights and 

Environmental Justice. 

1-29 
Final Environmental Impact Statement 

Issues Outside the Scope 

No Invasive Plant Treatments 

Some members of the public stated that the USDA Forest Service should not treat invasive 

plants. The best approach for addressing invasive plant infestations is to eliminate human 

disturbance, including logging, grazing and the related road building, ground disturbance and 

increased vehicular traffic. To address the problem, the members of the public suggested 

suspending logging projects until a comprehensive EIS is completed that fully addresses the 

existing problem and ‘root causes.’ 

This issue is outside the scope because prevention was an alternative considered, but eliminated 

from detailed study (see Section 2.5). Prevention is an important component of invasive plant 

management and an integral part to implementing successful treatments. Both the Forest and 

Scenic Area are implementing new prevention standards and guidelines through the adoption of 

the Invasive Plant ROD (2005b), which took effect in March 2006. Also, both the Forest and 

Scenic Area have local prevention standards contained in Appendix D. Despite the importance of 

prevention, prevention alone does not meet the purpose and need of timely treatment of known 

infestations or timely treatment of new/additional invasive plant sites, and therefore is outside the 

scope of this EIS. 

Further, suspending or discontinuing other land management activities, such as timber harvest, 

grazing allotments, and related activities, is outside the scope of this Proposed Action, which 

focuses exclusively on invasive plant management. These activities are analyzed in other NEPA 

documents, which are available at: http://www.fs.fed.us/r6/mthood/projects/ and 

http://www.fs.fed.us/r6/columbia/forest/projects/. 

Working on Other Ownerships 

Some members of the public suggested that the USDA Forest Service obtain the ability to 

coordinate with and assist in funding invasive plant management on private adjacent lands. 

While cooperating with adjacent landowners on mutual interest actions and/or sharing 

information is valuable, this issue is outside the scope of this project because the purpose of the 

project is to reverse the negative impacts caused by invasive plants and restore healthy, native 

communities and function at the impacted treatment sites in a cost-effective manner that meets 

current management direction. In order to achieve this purpose, the EIS analyzes and addresses 

the underlying need for action on the Forest and Scenic Area. Working on other ownerships, 

therefore, does not meet the purpose and need, and is outside the scope of the Proposed Action. 

1-30 
Site-Specific Invasive Plant Treatments 

1-31 

Implementing Invasive Plant Management 

Some members of the public suggested that the USDA Forest Service have a budget adequate to 

control the spread of invasive plants. The budget would be supplemented by developing 

partnerships and using volunteers or other workforces. Partners and volunteer groups would 

provide assistance and expertise in the management and treatment of invasive plants. 

This issue is outside the scope of this project because funding and implementation methods for 

invasive plant management on the Forest and Scenic Area would vary each year as budget levels 

change, information and knowledge concerning invasive plants improves, and invasive plant 

infestations are reduced. The specifics of implementation would be decided through regular 

management practices at the Forest and Scenic Area, with annual recommendations developed 

by appropriately trained and skilled staff. Often, these recommendations and considerations 

include the establishment of partnerships. The specific details of funding and implementation 

practices, therefore, are not addressed through NEPA and are outside the scope of this EIS. 

1.9 What is Not Included 

This action addresses the treatment of invasive plants on the Forest and Scenic Area. It does not 

address the prevention of invasive plant infestations. Prevention is addressed through the 

adoption of the standards and guidelines presented in the Invasive Plant FEIS (2005a), national 

and regional direction, best management practices for invasive plants developed by the Forest 

and Scenic Area, and provisions in separate environmental documents and contracts. See 

Appendix A – Standards from Preventing and Managing Invasive Plant Record of Decision, 

2005. Also, see Appendix D – Prevention of Invasive Plants - A Strategic Collaborative Effort 

for Mt. Hood National Forest and the Columbia Gorge National Scenic Area in Oregon. 

Additionally, this action does not include the following. 

• Invasive plants floating or submerged in water: Aquatic invasive plant species are 

currently being addressed through other federal actions in cooperation with the states. 

• Biological control agents: These agents have already been analyzed by the U.S. 

Department of Agriculture, Agricultural Plant Health and Insect Service (APHIS). The 

environmental documents are available at: 

http://www.aphis.usda.gov/ppq/weeds/enviro2.html The Oregon Department of 

Agriculture releases biological control agents for all land ownerships across the State of 

Oregon. 

• Experimental trials of herbicides conducted by the U.S. Environmental Protection 

Agency (EPA) to test new products. 

• Aerial herbicide applications or prescribed fire treatment methods. 
 
CHAPTER 2 

Alternatives, Including the Proposed Action 
 
Site-Specific Invasive Plant Treatments

CHAPTER 2: Alternatives, Including the Proposed Action 

Chapter 2 describes and compares the alternatives considered for invasive plant treatment within 

the Mt. Hood National Forest (the Forest) and the Columbia River Gorge National Scenic Area 

in Oregon (the Scenic Area). A description and map are provided for each. Also, this section 

presents the alternatives in comparative form, defining the differences between each alternative 

and providing a basis for choice among options for the Responsible Officials and the public. 

The alternatives described in Chapter 2 are derived from a detailed project database, based on 

invasive plant inventories from November 2004. The proposed treatment areas cover 

approximately 13,000 acres in Multnomah, Hood River, Wasco, Clackamas, Jefferson, and 

Marion counties (See Figure 2-1). This represents 1.1 percent of the National Forest System 

lands within the Forest and Scenic Area. Approximately 11,000 acres are located within the 

Forest and 2,000 acres within the Scenic Area. The Forest acres are distributed on all four ranger 

districts, including 2,444 acres on Barlow Ranger District, 5,596 acres on Hood River Ranger 

District; 1,270 acres on Clackamas River Ranger District; and 1,868 acres on the Zigzag Ranger 

District (See Figures 2-2 to 2-6: Maps of Proposed Treatment Areas for the Proposed Action on 

the Scenic Area and each District). The treatment areas are located in a variety of site types: 63 

percent in disturbed areas (roads, quarries, utility corridors), 20 percent in recreational sites 

(developed campgrounds, permit areas, recreational residences), 17 percent in forested/natural 

areas (clearings, flood plains, meadows, forested sites, plantations), and less than 1 percent in 

administrative sites. 

Treatment methods (herbicide and non-herbicide) and site treatment strategies are identified 

based on the location, extent and biology of existing invasive plant species. Treatment methods 

were developed using Common Control Measures Invasive Plants of the Pacific Northwest 

Region (Mazzu, 2005) and in accordance with USDA Forest Service Handbook (FSH) 2109.14 – 

Pesticide-Use Management and Coordination Handbook (USDA Forest Service, 1994c). 

Treatment priorities, methods, and strategies are tiered to the Pacific Northwest Region Invasive 

Plant Program – Preventing and Managing Invasive Plants Final Environmental Impact 

Statement (Invasive Plant FEIS) (USDA Forest Service, 2005a). A primary focus of the sitespecific analysis is development of treatment prescriptions that comply with the invasive plant 

treatment standards adopted by the Pacific Northwest Region of the USDA Forest Service. All 

herbicide treatments require the completion of the Pesticide-Use Proposal Form FS-2100-2 

(Appendix E) to document decisions to use pesticides on National Forest System lands. All 

recommended treatment methods would be documented and approved by the appropriate 

responsible official(s). More information on how the treatments methods were chosen and the 

required steps to treat invasive plants each year is contained in the following sections. 

2-1 
Final Environmental Impact Statement 

Figure 2-1. Map of Proposed Treatment Areas for the Proposed Action. 

2-2 
Site-Specific Invasive Plant Treatments

2.1 Alternatives Considered in Detail 

2.1.1 Alternative Development Process 

The interdisciplinary team (IDT), including the Responsible Officials, followed the USDA 

Forest Service handbook (1909.15) for developing and considering alternatives. Alternatives 

were developed to meet the purpose and need and to respond to public issues, while effectively 

treating invasive plants and restoring native ecosystems. 

The USDA Forest Service developed three alternatives: No Action (Alternative 1), Proposed 

Action (Alternative 2), and Restricted Herbicide Use (Alternative 3) alternatives. The No Action 

(Alternative 1), defined as treatments that are currently approved under existing NEPA decisions, 

was compared to the need for action as documented in the database. Within both the Forest and 

Scenic Area, existing treatment methods, specifically manual and mechanical methods, have not 

effectively treated the invasive plant infestations within the Forest and Scenic Area. For this 

reason, the focus of this EIS is on the use of new herbicides and treatment methods that became 

available through the Pacific Northwest Region Invasive Plant Program – Preventing and 

Managing Invasive Plants Record of Decision (Invasive Plant ROD) in 2005 (USDA Forest 

Service, 2005b). 

Public and interagency issues centered on treatment effectiveness, cost efficiency, herbicide 

toxicity, and potential adverse effects of using herbicides. The Restricted Herbicide Use 

Alternative varies in the amount of herbicide used and the amount of herbicide applied using 

broadcast application methods, based on the following concepts: 

1. Invasive plants would be treated by manual, mechanical, cultural (goat grazing), or 

herbicide methods. The effectiveness of the treatment would vary based on the invasive 

plant species present and the treatment method chosen. Herbicide treatment may be the 

only cost effective way of effectively treating large, continuous infestations. 

Additionally, herbicide treatment may be the most effective for some species. 

2. Herbicide treatments, particularly broadcast application methods, have greater inherent 

risk of adverse effects from herbicide drift or delivery to water. 

The IDT identified six potential discrepancies between the effective treatment options needed to 

address the existing infestations and existing management direction in the Forest Plan (see 

Section 1.5 – Forest Plan Standards and Guidelines). 

Some alternatives that would resolve public concerns were eliminated from detailed study 

because they do not meet the purpose and need for action. The eliminated alternatives include: 

prevention only and no herbicide use. These are discussed in Chapter 2, Section 2.5. 

2-3 
Final Environmental Impact Statement 

Figure 2.2 Proposed Action Map for Columbia River Gorge National Scenic Area 

2-4 
Site-Specific Invasive Plant Treatments

Figure 2-3. Proposed Action Map for Barlow Ranger District, Mt. Hood National Forest 

2-5 
Final Environmental Impact Statement 

Figure 2-4. Proposed Action Map for Clackamas River Ranger District, Mt. Hood National 

Forest 

2-6 
Site-Specific Invasive Plant Treatments

Figure 2-5. Proposed Action Map for Hood River Ranger District, Mt. Hood National 

Forest 

2-7 
Final Environmental Impact Statement 

Figure 2-6. Proposed Action Map for Zigzag Ranger District, Mt. Hood National Forest 

2-8 
Site-Specific Invasive Plant Treatments

2.1.2. Alternative 1 – No Action Alternative 

Current direction for the management of invasive plants occurs through individual NEPA 

documents tiered to the 1988 Environmental Impact Statement and 1988 Record of Decision for 

Competing and Unwanted Vegetation and the associated 1989 Mediated Agreement. These 

individual NEPA documents include: the Environmental Assessment (EA) for the Management 

of Noxious Weeds, Mt. Hood National Forest (1993); the Environmental Assessment for the 

Control and Management of Noxious Weeds and Blackberries on Selected Lands within the 

Columbia River Gorge National Scenic Area (1996); the Environmental Assessment for the 

Application of Herbicides for the Control and Management of Noxious Weeds on the Barlow 

Ranger District, Mt. Hood National Forest (1998); and the Big Eddy-Ostrander Transmission 

Corridor Supplemental Analysis to Transmission System Vegetation Management Program, 

Final Environmental Impact Statement Bonneville Power Administration (BPA) (2001). 

• The Management of Noxious Weeds EA (USDA Forest Service, 1993a) allows the Forest 

to manage noxious weeds using a full range of treatment methods, including herbicide 

use in combination with other treatment methods. Herbicides are used only as a last resort 

when other methods are ineffective. This EA allows treatment of nine diffuse knapweed, 

spotted knapweed, and tansy ragwort sites on the Barlow, Bear Springs, Clackamas, 

Estacada, and Zigzag Ranger Districts using an integrated weed management program. 

Three herbicides are approved for use: picloram (Tordon 22K), glyphosate (Rodeo), and 

triclopyr (Garlon 3A). Herbicide application is applied directly to target plants only, 

using backpack or motorized sprayers with hand-held nozzles or hand wiping. Herbicide 

treatments can occur on approximately 5 acres. Other treatment methods include manual 

controls and re-vegetation. 

• The EA for the Control and Management of Noxious Weeds and Blackberries on 

Selected Lands within the Columbia River Gorge National Scenic Area (USDA Forest 

Service, 1996c) and a 1999 amendment permits invasive plant control of 324 acres 

targeting 42 specific sites within the Scenic Area. Target invasive plant species include 

knapweed, Canada thistle, bull thistle, reed canarygrass, Himalayan blackberry, 

houndstongue, and others. Approximately 100 acres are on the Oregon side of the 

Columbia River. In addition to this EA, other NEPA documents incorporate invasive 

plant management and permit additional acres to be treated. On the Oregon side of the 

Scenic Area, this includes 1500 acres in the Sandy River Delta (SRD), which is an active 

restoration site heavily infested with reed canarygrass, thistles, blackberry, and tansy. On 

all these sites, triclopyr (Garlon 3A), glyphosate (Roundup), and picloram (except at 

SRD) can be used. Four sites are treated mechanically with mowing, and two sites are 

treated by hand pulling. Through these decisions, the Scenic Area can treat up to 1,600 

acres with herbicide treatments. 

2-9 
Final Environmental Impact Statement 

• The Application of Herbicides for the Control and Management of Noxious Weeds EA 

on the Barlow Ranger District (USDA Forest Service, 1998b) allows the use of 

herbicides as part of the integrated noxious weed management program. The herbicides 

are picloram and triclopyr in the formulations Tordon 22K and Garlon 3A. The invasive 

plant species targeted for treatment are houndstongue, diffuse knapweed, spotted 

knapweed, meadow knapweed, tansy ragwort, yellow toadflax, and Dalmatian toadflax. 

Ground-based herbicide treatments are used to augment manual, mechanical and 

biological treatment methods where these methods have proven ineffective or 

uneconomical. Herbicide applications are done using spot spray or broadcast (boom) 

spray methods. All proposed treatment sites are disturbed areas, such as roads, roadsides, 

administrative sites, old clearcuts, and power line corridors, along with some sites 

occurring in riparian reserves within the White River watershed. The District treats up to 

350 acres annually. 

• Big Eddy-Ostrander Transmission Corridor supplemental analysis to Transmission 

System Vegetation Management Program EIS prepared by BPA (2001) in cooperation 

with the USDA Forest Service addresses remedial vegetation maintenance of the Big 

Eddy-Ostrander transmission line right-of-way on the Forest1

. The project removes 

unwanted vegetation within the transmission line right-of-way. Unwanted vegetation is 

defined as trees or shrubs that could impede operation and maintenance of the 

transmission line, or plant species occurring within the right-of-way that are designated 

as noxious by the State of Oregon. Unwanted vegetation is removed by manual, 

mechanical and herbicide means. Herbicide use is limited to picloram, triclopyr, 

glyphosate, dicamba, or a combination of these herbicides, and all applications are 

ground-based (non-aerial herbicide applications). Through this decision, the Forest can 

treat approximately 295 acres with herbicide treatments. 

As approved by these NEPA decisions, invasive plants can be treated through a variety of 

methods on a total of 2,250 acres; 650 acres on the Forest and 1,600 acres on the Scenic Area. In 

the Forest and Scenic Area, most of the invasive plant treatments currently using herbicides are 

carried out through agreements with the county noxious weed control boards (Hood River and 

Wasco Counties) or Oregon Department of Agriculture. For larger restoration projects in the 

Scenic Area, such as the Sandy River Delta, invasive plant infestations are treated with 

herbicides by contractors with licensed pesticide applicators. Treatments within the Big EddyOstrander transmission line right-of-way on the Forest are administered by BPA. Manual and 

mechanical treatments on both units are completed by USDA Forest Service crews, through the 

above referenced agreements, or through partnerships and volunteers. 

2-10 

 

1

 In June 2005, additional supplemental analysis was completed for the Big-Eddy Ostrander Transmission Corridor 

by BPA. This expanded the described project from Multnomah County (Zigzag Ranger District) to Hood River 

County (Hood River Ranger District) in order to include the entire transmission corridor. To date, no invasive plant 

treatments have occurred to include the entire transmission corridor. To date, no invasive plant treatments have 

occurred on National Forest System lands in the Hood River portion of the transmission corridor. Since no 

treatments have been completed to date, the No Action Alternative remains unchanged. 
Site-Specific Invasive Plant Treatments

Under the No Action Alternative, the Forest and Scenic Area would continue to treat invasive 

plant species as authorized under these existing NEPA documents. Approximately 1,235 acres 

(Table 2-1) were treated in fiscal year 2003, including 600 acres of herbicide treatments; 450 

acres on the Forest and 150 acres on the Scenic Area. The remaining 635 acres were treated with 

manual and mechanical treatment methods. On the Forest, approximately 40 acres in the BPA 

utility corridor received multiple herbicide treatments; the remaining 410 acres of herbicide 

treatments were treated only once. In the Scenic Area, approximately 130 acres in the Sandy 

River Delta received multiple herbicide treatments; the remaining acres of herbicide treatments 

were treated only once. The No Action Alternative map shows the Forest and Scenic Area lands 

that have been treated with herbicides since 1999 (Figure 2-7 – Map of No Action Alternative). 

Treatment areas on the Scenic Area and each District are displayed on Figures 2-8 through 2-12; 

these maps illustrate all areas that have been treated with herbicides from 1999 to 2003 by 

District. As illustrated by the maps, herbicide treatments for invasive plants have occurred within 

the Scenic Area as well as the Barlow, Clackamas River and Zigzag Ranger Districts: no 

herbicide treatments have occurred within the Hood River Ranger District. Details on the areas 

treated each year are available from the Forest and Scenic Area staff responsible for overseeing 

invasive plant management. 

Treatment effectiveness varies based on the species treated and treatment method. The herbicide 

treatments are estimated to be 75 to 80 percent effective, and the manual and mechanical 

+number of infested acres and available funding. Although the number of acres varies, these 

acres are indicative of the number of acres and types of treatments applied each year on the 

Forest and Scenic Area. The fiscal year 2003 acres are used in Chapter 3 for analysis of the No 

Action Alternative. 

Table 2-1: Acres of Treatment from October 2003 to October 2004 (Fiscal Year 2003). 

These acres are approved for treatment under current NEPA documents on the Forest and 

Scenic Area. 

Mt. Hood 

National Forest 

(acres) 

Columbia River Gorge 

National Scenic Area 

(acres) 

Total 

(acres) 

Herbicide Treatments 450 150 600 

Broadcast Spraying 285 130 415 

Spot Spraying 165 20 185 

Mechanical Treatments 10 500 510 

Manual Treatments 100 25 125 

TOTAL 560 675 1,235 

2-11 
Final Environmental Impact Statement 

Figure 2-7. Map of Proposed Treatment Areas for the No Action Alternative 

2-12 
Site-Specific Invasive Plant Treatments

Figure 2-8. No Action Alternative Map for Columbia River Gorge National Scenic Area 

2-13 
Final Environmental Impact Statement 

Figure 2-9. No Action Alternative Map for Barlow Ranger District, Mt. Hood National 

Forest 

2-14 
Site-Specific Invasive Plant Treatments

Figure 2-10. No Action Alternative Map for Clackamas River Ranger District, Mt. Hood 

National Forest 

2-15 
Final Environmental Impact Statement 

Figure 2-11. No Action Alternative Map for Hood River Ranger District, Mt. Hood National 

Forest 

2-16 
Site-Specific Invasive Plant Treatments

Figure 2-12. No Action Alternative Map for Zigzag Ranger District, Mt. Hood National 

Forest 

2-17 
Final Environmental Impact Statement 

2.1.3. Alternative 2 – The Proposed Action 

The Proposed Action would implement invasive plant treatments across approximately 13,000 

acres within the Forest and Scenic Area over approximately the next 10 to 15 years (See Figure 

2-1 – Map of Proposed Treatment Areas for the Proposed Action). An invasive plant inventory 

was completed in 2004, which surveyed about 50 percent of the areas within the Forest and 

Scenic Area likely to be infested with invasive plants (Stein, 2005). The inventory revealed that 

approximately 3,600 acres are infested with invasive plants (1,700 acres on the Forest and 1,900 

acres on the Scenic Area). With the realization that some invasive plants or infested areas were 

missed during past surveys, an uncertainty factor was applied to bring the estimated total infested 

area up to approximately 3,700. 

The total treatment acres were adjusted slightly to incorporate anecdotal evidence and expert 

knowledge, including delays in treatment, spread of invasive plants and other factors that spread 

plant seeds. Evidence shows that the invasive plant species present in the Forest and Scenic Area 

would likely expand their populations at a rate of 8 to 12 percent each year (USDA Forest 

Service, 1999). The expansion in population size includes plant growth as well as spread by a 

variety of vectors including wind, water, animals, and human activities where they are present. 

Also, due to the high cost of treatment, it is highly unlikely that we would be able to take action 

in all inventoried areas immediately. During the time between the inventory and treatment, plant 

populations would grow and spread. To account for this growth over the life of the project (15 

years), a “foreseeable” rate of spread of 10 percent per year was also applied to estimate the total 

foreseeable infested acres 15 years from now (Table 1-1), hereafter referred to as the treatment 

acres. 

Many treatment areas contain an aquatic influence zone. An aquatic influence zone is the land 

adjacent to perennial and intermittent streams, rivers, ponds, lakes, springs, and wetlands that has 

a direct or potentially direct influence on the water body and its function where herbicides may 

enter surface waters. This zone has a default width of 100 feet, given the understanding that in 

some areas it may be wider pending a site-specific review. The aquatic influence zone is 

illustrated in Figure 2-13. 

The treatments would be adjusted to meet specific Project Design Criteria (PDC), the purpose of 

which is to reduce or eliminate the potential impacts (Detailed in Section 2.2). PDC are a set of 

required implementation design criteria applied to projects to ensure that the project is done 

according to environmental standards and adverse effects are within the scope of those predicted 

in this EIS. 

2-18 
Site-Specific Invasive Plant Treatments

Although all treatment areas are analyzed by resource area in Chapter 3 – Affected Environment 

and Environmental Consequences, only areas actually containing invasive plants would be 

treated in any given year. As a result, the area impacted is likely to be less than the estimated 

treatment acres (13,000 acres). The estimated treatment areas represent the worse-case scenario 

of invasive plants spreading rapidly without treatment; the worse-case scenario is described in 

the Invasive Plant Treatment Prescription Assumptions sections. For example, in the Sandy 

River Delta (SRD) approximately 1000 acres are infested with invasive plants. Treatment area 

#22-01, however, contains the entire SRD (approximately 1500 acres), and the effects of 

treatment methods are analyzed by each resource area over the entire treatment area. This 

approach would allow treatment across the entire SRD if the spread of invasive plants to new, 

uninfested areas of the SRD or if new invasive plant species infest the SRD. Regardless of the 

area analyzed, only the infested acres within the SRD would be treated. 

The treatment methods, species, treatment strategies, treatment prescriptions, assumptions, site 

restoration strategies, Forest Plan amendments, and Early Detection / Rapid Response strategy 

(EDRR) components of the Proposed Action are each described more completely below. 

Figure 2-13. Illustration of Aquatic Influence Zone 

2-19 
Final Environmental Impact Statement 

Treatment Methods 

Proposed treatment methods include hand pulling, cutting, mowing, hand/selective herbicide 

applications, stem injection, spot herbicide spraying, broadcast herbicide spraying, and goat 

grazing. These treatment methods are summarized in Table 2-2. The timing for herbicide 

treatments would be dependent on the species as well as wind and rain restrictions, which vary 

by herbicide. 

Table 2-2: Summary of Proposed Treatment Methods. The effectiveness of these treatment 

methods are discussed in Section 3.6 – Botany and Treatment Effectiveness. 

Method Description 

Manual Methods 

Hand pulling Pulling or uprooting plants can be effective against some shrubs, tree 

saplings, and herbaceous invasive plants. Annuals and tap-rooted plants are 

particularly susceptible to control by hand pulling. It is not as effective against 

many perennial invasive plants with deep underground stems and roots that 

are often left behind to re-sprout. 

The advantages of pulling include its small ecological impact, minimal damage 

to neighboring plants, and low (or no) cost for equipment or supplies. The key 

to effective hand pulling is to remove as much of the root as possible while 

minimizing soil disturbance. For many species, any root fragments left behind 

have the potential to re-sprout, and pulling is not effective on plants with deep 

and/or easily broken roots. 

Pulling Using Tools Most plant-pulling tools are designed to grip the plant stem and provide the 

leverage necessary to pull its roots out. Tools vary in their size, weight, and 

the size of the invasive plant they can extract. The Root Talon is inexpensive 

and lightweight, but may not be as durable or effective as the all-steel Weed 

Wrench, which is available in a variety of sizes. Both tools can be 

cumbersome and difficult to carry to remote sites. Both work best on firm 

ground as opposed to soft, sandy, or muddy substrates. 

Clipping “Clipping” means to cut or remove seed heads and/or fruiting bodies to 

prevent germination. This method is labor-intensive and effective for small and 

spotty infestations. 

Clipping and pulling “Clipping and pulling” means cutting a portion of the invasive plant stem and 

pulling it from its substrate, generally the bole of a tree. This method is laborintensive, but can be effective for larger infestations. 

Stabbing Some plants can be killed by severing or injuring (stabbing) the carbohydrate 

storage structure at the base of the plant. Depending on the species, this 

structure may be a root corm, storage rhizome (tuber), or taproot. These 

organs are generally located at the base of the stem and under the soil. 

Cutting off access to these storage structures can help “starve” or greatly 

weaken some species. 

2-20 
Site-Specific Invasive Plant Treatments

Method Description 

Mechanical Methods 

Mowing, cutting, 

brushing, trimming, 

weed eating 

Mowing and cutting can reduce seed production and restrict invasive plant 

growth, especially in annuals cut before they flower and set seed. Some 

species however, re-sprout vigorously when cut, replacing one or a few stems 

with many that can quickly flower and set seed. 

These treatments are used as primary treatments to remove aboveground 

biomass in combination with herbicide treatments to prevent resprouting, or as 

follow up treatments to treat target plants missed by initial herbicide use. Also, 

mowing and cutting can be used, in conjunction with herbicide treatments, to 

reduce vegetative materials and to promote vigorous growth in order to 

decrease the amount of herbicide application needed, and to increase 

herbicide effectiveness. 

Cultural Methods 

Grazing goats Grazing could either promote or reduce invasive plant abundance at a 

particular site. When grazing treatments are combined with other control 

techniques, such as herbicides, severe infestations could be reduced and 

small infestations may be eliminated. Grazing animals may be particularly 

useful in areas where herbicides cannot be applied (e.g., near water) or are 

prohibitively expensive (e.g., large infestations). Animals also could be used 

as part of a restoration program by breaking up the soil and incorporating in 

seeds of desirable native plants. 

Goats prefer broadleaf herbs and have been used to control leafy spurge 

(Euphorbia esula), Russian knapweed (Acroptilon repens), and toadflax 

(Linaria spp.). These animals appear to be able to neutralize the 

phytochemicals toxic to other animals that are present in these and other 

forbs. Goats could control woody species because they climb and stand on 

their hind legs, and browse on vegetation other animals cannot reach. (Tu et 

al., 2001) 

Herbicide Methods 

Hand/Selective Treatment of individual plants to avoid spraying other desirable plants. There 

is a low likelihood of drift or delivery of herbicides away from treatment sites. 

This method is used in sensitive areas, such as near water, to avoid getting 

any herbicide on the soil or in the water. Hand/Selective methods could be 

done under more variable conditions than spot spraying or broadcast spraying 

(Tu et al., 2001). Specific methods include: 

a. Wicking and Wiping - Involves using a sponge or wick on a long handle to 

wipe herbicide onto foliage and stems. Use of a wick eliminates the 

possibility of spray drift or droplets falling on non-target plants. Herbicide 

can drip or dribble from some wicks. 

b. Foliar Application - These methods apply herbicide directly to the leaves 

and stems of a plant. An adjuvant or surfactant is often needed to enable 

the herbicide to penetrate the plant cuticle, a thick, waxy layer present on 

leaves and stems of most plants. There are several types of foliar 

application tools available. 

2-21 
Final Environmental Impact Statement 

Method Description 

c. Basal Bark - This method applies a 6 to 12 inch band of herbicide around 

the circumference of the trunk of the target plant, approximately one foot 

above ground. The width of the sprayed band depends on the size of the 

plant and the species’ susceptibility to the herbicide. The herbicide can be 

applied with a backpack sprayer, hand-held bottle, or wick. 

d. Frill or Hack and Squirt - The frill method, also called the “hack and squirt” 

treatment, is often used to treat woody species with large, thick trunks. The 

tree is cut using a sharp knife, saw, or ax, or drilled with a power drill or 

other device. Herbicide is then immediately applied to the cut with a 

backpack sprayer, squirt bottle, syringe, or similar equipment. 

e. Stem Injection - Herbicides can be injected into herbaceous stems using a 

needle and syringe. Herbicide pellets can also be injected into the trunk of 

a tree using a specialized tool. 

f. Cut-stump - This method is often used on woody species that normally resprout after being cut. Cut down the tree or shrub, and immediately spray or 

squirt herbicide on the exposed cambium (living inner bark) of the stump. 

The herbicide must be applied to the entire inner bark (cambium) within 

minutes after the trunk is cut. The outer bark and heartwood do not need to 

be treated since these tissues are not alive, although they support and 

protect the tree’s living tissues. The cut stump treatment allows for a great 

deal of control over the site of herbicide application, and therefore, has a 

low probability of affecting non-target species or contaminating the 

environment. It also requires only a small amount of herbicide to be 

effective. 

Spot Spraying Spot applicators spray herbicide directly onto small patches or individual target 

plants only and avoid spraying other desirable plants. These applicators range 

from motorized rigs with spray hoses to backpack sprayers, to hand-pumped 

spray or squirt bottles, which can target very small plants or parts of plants. 

Broadcast (Boom) 

Spraying 

A boom, a long horizontal tube with multiple spray heads, may be mounted or 

attached to a tractor, ATV (all terrain vehicle) or other vehicle. The boom is then 

carried above the invasive plants while spraying herbicide, allowing large areas to 

be treated rapidly with each sweep of the boom. Offsite movement due to 

vaporization or drift and possible treatment of non-target plants can be of concern 

when using this method. 

The herbicide is carried in a tank and reaches the nozzles via tubing. All 

herbicides are metered out from the nozzles in a controlled manner. The nozzle 

controls the droplet size, the area (or cone) being covered by the herbicide and it 

could be turned on/off with ease. Some nozzles could rotate. All this flexibility 

permits the operator to carefully apply herbicide at specific rates over specific 

areas. Many of the new boom spray operations have very sophisticated electronic 

monitoring that delivers exact amounts of herbicides and keeps records on rates 

and areas covered. Offsite movement due to drift and possible treatment of nontarget plants could be of concern when using this method. 

Not all broadcast methods include a boom; boom-less nozzles are currently in use 

that can reduce the risk of non-target effects. Backpacks may also be used as a 

broadcast tool, if not directed at individual plants.

2-22 
Site-Specific Invasive Plant Treatments

Herbicide treatments would be limited to the ten herbicides that were approved for use under the 

Invasive Plant ROD (2005b). These herbicides are chlorsulfuron, clopyralid, glyphosate, 

imazapic, imazapyr, metsulfuron methyl, picloram, sethoxydim, sulfometuron methyl, and 

triclopyr. The following treatment methods are shown in order of preference, assuming the 

methods are effective, practical and cost-effective. 

1. Non-herbicide, non-ground disturbing treatment methods, specifically manual, 

mechanical and cultural (goat grazing) treatment methods; 

2. Application of herbicides via hand/selective treatment methods (e.g., stem injection or 

spot spraying); 

• Application of low toxicity herbicides, such as clopyralid, imazapic, metsulfuron 

methyl, aquatic triclopyr, or aquatic imazapyr; 

• Application of moderate toxicity herbicides, such as aquatic glyphosate, 

chlorsulfuron, imazapyr, sulfometuron methyl; and 

• Application of more toxic herbicides, such as glyphosate, triclopyr, picloram, and 

sethoxydim. 

3. Application of herbicide via broadcast spraying treatment methods. Preference for 

herbicide choice would follow the same order as the hand/selective methods. 

Although the first preference is non-herbicide, non-ground disturbing methods, this EIS focuses 

on herbicide treatments. On the Forest for the past 13 years and on the Scenic Area for the last 10 

years, the USDA Forest Service has had the ability to treat invasive plants with non-herbicide 

methods using existing NEPA documents. These treatment methods, however, have not 

effectively treated the invasive plant infestations on the Forest or Scenic Area. In addition, 

research and anecdotal evidence have demonstrated that herbicide treatments have been found to 

be the most effective treatment for many of the invasive plants proposed for treatment (see 

Section 3.6 – Botany and Treatment Effectiveness). The treatment preferences would be 

followed in the Early Detection / Rapid Response strategy (EDRR) (discussed below). 

Prescriptions follow these preferences and integrated weed management (IWM) approach to 

achieve effective and practical treatment methods for each site. No single management technique 

is perfect for all invasive plant control situations. Multiple management actions are required for 

effective control. The strategy of using an integrated selection of management techniques has 

been developed for use in a variety of “pest” control situations, including plant pests or invasive 

plants. IWM is an approach for selecting methods for preventing, containing, and controlling 

invasive plant in coordination with other resource management activities to achieve optimum 

management goals and objectives. This approach uses a combination of treatment methods that, 

taken together, would control a particular invasive plant species or infestation efficiently and 

effectively, with minimum adverse impacts to non-target organisms. IWM seeks to combine two 

or more treatment methods that would interact to provide better control than any one of the 

2-23 
Final Environmental Impact Statement 

actions might provide alone. The IWM approach contrasts with the traditional approach of using 

a single control action, such as applying herbicides, to treat all invasive plant problems. 

Herbicides are one useful technique, but they are not the only method to control invasive plants 

and may not always be the most effective. IWM is species-specific, tailored to exploit the 

weaknesses of a particular invasive plant species, site-specific, and designed to be practical with 

minimal risk to the organisms and their habitats (Colorado Natural Areas Program, 2000). 

IWM requires an ecologically based, interdisciplinary approach. Selection of treatment methods 

is based on information such as the biology of particular invasive plant species, site location, 

proximity to water, and size of the infestation. Multiple entries (up to three times per year) may 

be required to appropriately treat the invasive plant species and meet the treatment strategies for 

each treatment area (discussed below). Additionally, the prescription combinations often have a 

temporal aspect: invasive target species may be treated with herbicide initially, then with manual 

or mechanical follow-up as needed. Treatments may be repeated as needed on an annual basis. 

Similarly, the herbicide used at a treatment area may change over time as the mixture of invasive 

plants present and/or site conditions change. 

Species to be Treated 

A total of 19 invasive plant species are proposed for treatment based on current inventories 

(November 2004). Additional species are known to be present on lands adjacent to or near the 

Forest and Scenic Area: some of these species are listed in Table 2-3. Several of these species 

may already be present within the Forest or Scenic Area, but were not identified during the last 

inventory. More invasive plant species may be detected on the Forest and Scenic Area in the 

future. Any invasive plant species may be treated under the EDRR and is not limited to these 

species. 

Table 2-3: Invasive Plants Proposed for Treatment. Invasive plants proposed for treatment 

based on current inventory (November 2004), and other invasive plant species likely to be 

present or in close proximity to the Forest or Scenic Area. The species not yet present may be 

treated under the EDRR. 

Common Name Scientific Name Symbol 

Inventoried Species 

(November 2004) 

Butter and eggs Linaria vulgaris LIVU2 Yes 

Canada thistle Cirsium arvense CIAR4 Yes 

Common hawkweed Hieracium vulgatum HIVU Yes 

Common tansy Tanacetum vulgare TAVU Yes 

Diffuse knapweed Centaurea diffusa CEDI3 Yes 

English ivy Hedera helix HEHE Yes 

Himalayan blackberry Rubus discolor RUDI2 Yes 

Houndstongue Cynoglossum officinale CYOF Yes 

Japanese knotweed Polygonum cuspidatum POCU6 Yes 

Meadow hawkweed Hieracium pratense HIPR Yes 

Meadow knapweed Centaurea debeauxii (pratense) CEPR2 Yes 

2-24 
Site-Specific Invasive Plant Treatments

2-25 

Common Name Scientific Name 

Inventoried Species 

Symbol (November 2004) 

Orange hawkweed Hieracium aurantiacum HIAU Yes 

Reed canarygrass Phalaris arundinacea PHAR3 Yes 

Rush skeletonweed Chondrilla juncea CHJU Yes 

Scotch broom Cytisus scoparius CYSC4 Yes 

Spotted knapweed Centaurea biebersteinii CEBI2 Yes 

St. Johnswort Hypericum perforatum HYPE Yes 

Tansy ragwort Senecio jacobaea SEJA Yes 

Yellow starthistle Centaurea solstitialis CESO3 Yes 

Bohemian knotweed Polygonum bohemicum POBO10 No 

Cutleaf blackberry Rubus laciniatus RULA No 

Dyer’s woad Isatis tinctoria ISTI No 

False broom Brachypodium sylvaticum BRSY No 

Garlic mustard Alliaria petiolata ALPE4 No 

Giant knotweed Polygonum sachalinense POSA4 No 

Herb Robert Geranium robertianum GERO No 

Himalayan knotweed Polygonum polystachyum POPO5 No 

Leafy spurge Euphorbia esula EUES No 

Mediterranean sage Salvia aethiopis SAAE No 

Medusahead rye Taeniatherum caput-medusae TACA8 No 

Musk thistle Carduus nutans CANU4 No 

Perennial peavine Lathyrus latifolius LALA4 No 

Perennial pepperweed Lepidium latifolium LELA2 No 

Policeman’s helmet Impatiens glandulifera IMGL No 

Puncturevine Tribulus terrestris TRTE No 

Purple loosestrife Lythrum salicaria LYSA2 No 

Russian knapweed Acroptilon repens ACRE No 

Scotch thistle Onopordum acanthium ONAC No 

Shining geranium Geranium lucidum GELU No 

Squarrosa knapweed Centaurea virgata CEVI8 No 

Water hemlock Cicuta maculata CIMA2 No 

Whitetop Cardaria draba CADR No 
Final Environmental Impact Statement 

Treatment Strategies 

Based on the species present as well as site-specific conditions, such as ease of access, land 

allocation, location near special areas, restrictions due to other sensitive resources, or 

invasiveness of the plant in a specific habitat, each species in a treatment area is assigned a 

treatment strategy. The treatment strategies are defined in Section 1.2 – Purpose and Need for 

Action. 

Treatment areas containing species with defined treatment strategies of eradicate and control 

would receive more intensive treatments than the other treatment strategies. Table 2-4 

summarizes the acres under each treatment strategy for the Forest and Scenic Area. This EIS 

focuses on eliminating and controlling invasive plant species in order to stop the spread of 

invasive plants and restore healthy, native plant communities. The contain and suppress 

strategies focus on large areas infested with invasive plants; these areas are likely to never be 

completely “weed-free”. Since this EIS focuses on significantly reducing or eliminating invasive 

plants at the treatments sites, the strategies of contain and suppress are not prevalent. The 

treatment strategy can be dependent on either the site-specific objectives or the invasive plant 

species present. 

Table 2-4: Acres by Treatment Strategies. Treatment strategies vary by species, so one 

treatment area may have multiple treatment strategies based on the invasive plant species 

present. The calculations use the primary treatment strategy for each treatment area. Treat 

strategies were developed by the noxious weed coordinators in conjunction with other 

specialists on the IDT.

Unit Eradicate Control Contain Suppress 

Scenic Area 85 1682 20 0 

Forest 5349 5828 0 0 

Total 5434 7510 20 0 

Invasive Plant Treatment Prescriptions 

After determining the appropriate treatment strategy, a prescription for the treatment is 

developed for each treatment area. The treatments would occur over approximately 10 to 15 

years. The invasive plant treatment prescriptions follow the IWM approach described in the 

previous section. All herbicide treatments require the completion of the Pesticide-Use Proposal 

Form FS-2100-2 (Appendix E) to document decision to use pesticides on National Forest System 

lands. All recommended treatment methods would be documented and approved by the 

appropriate responsible official(s) (see Figure 1-4). 

2-26 
Site-Specific Invasive Plant Treatments

The overall treatment methods (e.g., manual, mechanical, cultural (goat grazing), or herbicide) 

and specific treatment methods by treatment type (e.g., hand pulling, mowing) are identified by 

treatment area in Appendix F –Site and Treatment Information. The treatment area locations are 

illustrated in Figures 2-2 to 2-6: Maps of Proposed Treatment Areas for the Proposed Action on 

the Scenic Area and each District. The proposed invasive plant prescriptions in Appendix G 

follow those described in Common Control Measures for Invasive Plants of the Pacific 

Northwest Region (Mazzu, 2005). Appendix G summarizes the treatment prescriptions proposed 

for the target invasive plant species in, or in close proximity to, the Forest and Scenic Area. The 

complete document, including more detailed descriptions of the prescriptions and prescriptions 

for additional species is available as Appendix N in the Invasive Plant FEIS (2005a) at 

http://www.fs.fed.us/r6/invasiveplant-eis/FEIS.htm. Table 2-5 displays the acres to be treated 

and treatment methods within the Forest and Scenic Area. 

Table 2-5: Proposed Action Summary of Treatment Methods. Note: Only infested acres 

would be treated with herbicides, rather than the entire area being analyzed. 

Overall Treatment Acres Percent of Total 

Herbicide 30 0.2% 

Herbicide plus Manual 327 2.5% 

Herbicide plus Manual & Mechanical 10736 82.8% 

Herbicide plus Manual, Mechanical & Cultural 

(Goat Grazing) 1,510 11.6% 

Herbicide plus Mechanical 310 2.4% 

Manual and Mechanical 50 0.4% 

Total 12,963 100.0% 

Again, although the first preference is non-herbicide, non-ground disturbing methods, this EIS 

focuses on herbicide treatments. On the Forest for the past 13 years and on the Scenic Area for 

the last 10 years, the USDA Forest Service has had the ability to treat invasive plants with single 

or a combination of non-herbicide methods (manual and mechanical primarily) using existing 

NEPA documents. These treatment methods, however, have not effectively treated the invasive 

plant infestations within the Forest or Scenic Area. 

The remaining discussion in this section focuses on new herbicides and herbicide methods that 

became available through the Invasive Plant FEIS (2005a). Section 3.4 – Basis for Effects 

Analysis contains more information on the properties and effects of herbicides. The prescriptions 

contain ten herbicides as approved in the Invasive Plant ROD (2005b) and analyzed in the 

Invasive Plant FEIS (2005a). The active ingredients and commercial names of the herbicides are 

summarized in Table 2-6. 

2-27 
Final Environmental Impact Statement 

Table 2-6: Active Ingredients and Commercial Herbicide Names. Active ingredient analyzed 

in Invasive Plant FEIS (2005a) and commercial herbicide names analyzed in the USDA Forest 

Service risk assessments (http://www.fs.fed.us/foresthealth/pesticide/risk.shtml). These 

herbicides are included in this EIS and analyzed in Chapter 3. 2

Herbicide/Selected 

Brand Names/Action Properties 

General Uses/Known 

to be Effective on: 

Chlorsulfuron 

(Telar, Glean, Corsair) 

Interferes with enzyme 

acetolactate synthase with rapid 

cessation of cell division and 

plant growth in shoots and 

roots. 

Glean – Selective pre-emergent 

or early post-emergent 

Telar – Selective pre- and postemergent. 

Both are for many annual, 

biennial and perennial broadleaf 

species. 

Safe for most perennial grasses 

and conifers. Some soil residue. 

Use at very low rates on annual, 

biennial and perennial species; 

especially dalmatian toadflax, 

houndstongue and perennial 

pepperweed. 

Clopyralid 

(Transline) 

Mimics natural plant hormones. 

A highly translocated, selective 

herbicide active primarily through 

foliage of broadleaf species. 

Little effect on grasses. 

Particularly effective on 

Asteraceae, Fabaceae, 

Polygonaceae, and Solanaceae

plant species. Some species 

include knapweeds, yellow 

starthistle, Canada thistle, and 

hawkweeds. Provides control of 

new germinants for one to two 

growing seasons. 

Glyphosate 

(35 formulations, including 

RoundUp, Rodeo, Accord, 

Aquamaster) 

Herbicide use restricted. 

Inhibits three amino acids and 

protein synthesis. 

A broad-spectrum, non-selective, 

translocated herbicide with no 

apparent soil activity. 

Adheres to soil, which lessens or 

retards leaching or uptake by 

non-targets. 

Low-volume applications are 

most effective. Translocates to 

roots and rhizomes of perennials. 

While considered non-selective, 

sensitivities do vary depending 

on species. Main control for 

purple loosestrife, herb Robert, 

English ivy, and reed 

canarygrass. Aquatic labeled 

formulations could be used near 

water. 

 

2-28 

• 2 The USDA Forest Service is not endorsing any commercial herbicides for use on National Forest System lands. These are the 

products analyzed in the risk assessment prepared by SERA.
Site-Specific Invasive Plant Treatments

2-29 

Herbicide/Selected 

Brand Names/Action 

General Uses/Known 

Properties to be Effective on: 

Imazapic 

(Plateau) 

Inhibits the plant enzyme 

acetolactate, which prevents 

protein synthesis. 

Used for the control of some 

broadleaf plants and some 

grasses. 

Use at low rates could control 

leafy spurge, cheatgrass, 

medusa head rye, toadflaxes, 

and houndstongue 

Imazapyr 3

(Arsenal, Chopper, Stalker, 

Habitat) 

Herbicide use restricted. 

Inhibits the plant enzyme 

acetolactate, which prevents 

protein synthesis. 

Broad-spectrum, non-selective, 

pre- and post-emergent for 

annual and perennial grasses 

and broadleaved species. 

Most effective as a postemergent. Has been used on 

cheatgrass, whitetop, perennial 

pepperweed, knotweed species, 

dyers woad, tamarisk, woody 

species, and spartina. Aquatic 

labeled formulations could be 

used near water. 

Metsulfuron methyl 

(Escort) 

Inhibits acetolactate synthesis, 

protein synthesis inhibitor, 

blocking the formation of amino 

acids. 

Used for the control of many 

broadleaf and woody species. 

Most susceptible crop species in 

the Lily family (i.e., onions, 

Allium). 

Safest sulfonylurea around nontarget grasses. 

Use at low rates to control such 

species as houndstongue, sulfur 

cinquefoil and perennial 

pepperweed. 

Picloram 

(Tordon K, Tordon 22K) 

Herbicide use restricted. 

Mimics natural plant hormones. 

Selective, systemic for many 

annual and perennial broadleaf 

herbs and woody plants. 

Use at low rates to control such 

species as knapweeds, Canada 

thistle, yellow starthistle, 

houndstongue, toadflaxes, sulfur 

cinquefoil, and hawkweeds. 

Provides control of new 

germinants for two to three 

growing seasons. 

Sethoxydim 

(Poast, Poast Plus) 

Herbicide use restricted. 

Inhibits acetyl co-enzyme, a key 

step for synthesis of fatty acids. 

A selective, post-emergent grass 

herbicide. 

Controls many annual and 

perennial grasses such as 

cheatgrass. 

 

• 3 Herbicide has formulations registered by EPA for aquatic use, meaning it is approved for application to emerged, 

submerged or floating aquatic vegetation, including invasive plants and brush in standing water or on backs and 

shores of these aquatic sites. 
Final Environmental Impact Statement 

2-30 

Herbicide/Selected 

Brand Names/Action 

General Uses/Known 

Properties to be Effective on: 

Sulfometuron methyl 

(Oust, Oust XP) 

Herbicide use restricted. 

Inhibits acetolactate synthase, a 

key step in branch chain amino 

acid synthesis. 

Broad-spectrum, pre- and postemergent herbicide for both 

broadleaf species and grasses. 

Used at low rates as a preemergent along roadsides. 

Known to be effective on reed 

canarygrass. (but not labeled for 

aquatic use) cheatgrass, 

medusahead. 

Triclopyr 

(Garlon 3A, Garlon 4, Forestry 

Garlon 4, Pathfinder II, 

Remedy, Remedy RTU, 

Redeem R&P) 

Herbicide use restricted. 

Mimics natural plant hormones. 

A growth regulating, selective, 

systemic herbicide for control of 

woody and broadleaf perennial 

invasive plants. 

Little or no impact on grasses. 

Not proposed for broadcast 

application under the Proposed 

Action. Effective for many woody 

species such as, scotch broom 

and blackberry. Also, effective on 

English ivy and knotweed 

species. Amine formulation may 

be used near water 

Information adapted from the Invasive Plant FEIS (2005a), Table 3-13, Page 3-91 to 3-92. Risk 

information found in SERA Herbicide Risk Assessments (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 

2004c, 2004d, 2004e, 2004f) for each active ingredient. Information on species effectiveness in Tu et al. 

(2001) or from product labels. 

Several herbicides have restrictions based on the known impacts; these restrictions are detailed in 

the PDC (Section 2.2) and Invasive Plant ROD (2005b) standards contained in Appendix A. The 

prescribed herbicide treatments are required to be applied at typical application rates (Table 2-7). 

Table 2-7: Typical Application Rates of Various Herbicides Used in Oregon and 

Washington (Taken from Invasive Plant FEIS (2005a), page 4-2). Clackamas, Multnomah, 

Hood River, and Wasco counties, and Oregon Department of Agriculture use these application 

rates in all cases, except Imazapyr. Hood River county typical application rate for Imazapyr is 

0.7 lb ai/ac. (lb ai = pounds of active ingredient; ac = acre). 

Herbicide Rate-Typical lb ai/ac 

Chlorsulfuron 0.056 

Clopyralid 0.35 

Glyphosate 2 

Imazapic 0.1 

Imazapyr 0.45 (0.70) 

Metsulfuron methyl 0.03 

Picloram 0.35 

Sethozydim 0.3 

Sulfometuron methyl 0.045 

Triclopyr 1.0 

Nonylphenol polyethoxylate (NPE) 1.67 

Source: The National Center for Food and Agricultural Policy Agricultural 

Pesticide Use Database for 1997. Washington DC. 1998. 
Site-Specific Invasive Plant Treatments

Many of the prescriptions listed in Appendix G – Common Control Measures Summary have 

more than one effective herbicide listed. Risk assessments for these herbicides are available online at http://www.fs.fed.us/foresthealth/pesticide/risk.shtml and some herbicide labels are 

available at http://www.fs.fed.us/foresthealth/pesticide/labels.shtml. The herbicide or mixture of 

herbicides used would depend on the invasive plants present, the biology and ecology of 

particular invasive plant species, site location, proximity to water, and size of the infestation. 

Since these factors may change over time, the effects analysis described in Chapter 3 analyzes 

the impacts of using all possible herbicides that are effective in each treatment area. Appendix H 

– Proposed Herbicide Use at Sites in the Proposed Action lists the potential herbicides by 

treatment site for the Proposed Action. 

Site Restoration Strategies 

Each treatment area has a site restoration strategy, which is part of the long-term objective to 

reduce invasive plants. The restoration strategy may either be passive or active restoration. 

Passive restoration assumes the treatment area would re-vegetate from existing vegetation 

without mulching, planting, or seeding. Passive restoration may be appropriate where treated 

sites leave only small gaps of bare ground and native vegetation on site would provide an 

adequate seed source to fill in such gaps. Active restoration is site-specific and may include 

seeding, planting, and/or mulching. It is assumed that all priority 1 and 2 (discussed below) 

treatment areas would need active restoration to meet the treatment strategies (e.g., eradicate or 

control); it is assumed that passive restoration would be acceptable at all other treatment areas to 

meet the treatment strategy (e.g., contain or suppress). These assumptions would be validated 

and specific restoration needs would be decided after the initial treatment occurs and the 

effectiveness would be determined. Each treatment area has an associated restoration strategy, 

which is listed in Appendix F. 

Promoting the establishment of desirable plant communities through the manipulation of species 

composition, plant density, and growth rate is a critical component of invasive plant management 

(Masters et al., 1996; Masters and Shelly, 2001; Brooks et al., 2004). Three components of 

succession could be manipulated: site availability, species availability, and species performance 

(Cox and Anderson, 2004). Although single control tactics, such as treatment with herbicides, 

may eliminate or suppress invasive species in the short-term, the resulting gaps and bare soil 

create niches that are conducive to further invasion by the same or other undesirable plant 

species. On degraded sites where desirable species are absent or in low abundance, re-vegetation 

with competitive grasses, forbs and legumes may be necessary to direct and accelerate plant 

community recovery, and achieve site-management objectives in a reasonable timeframe (USDA 

Forest Service, 2005a). 

The selection of appropriate species for re-vegetation is dependent on a number of factors, 

including treatment strategies and site characteristics such as soil texture, 

precipitation/temperature regimes and shade conditions. Seed availability and cost, ease of 

establishment, seed production, and competitive ability are also important considerations (USDA 

Forest Service, 2005a). 

2-31 
Final Environmental Impact Statement 

For this project, active restoration would include minimum site preparation with a hand rake (or 

similar tool that would not penetrate the ground more than 1 to 2 inches) and hand shovel. Native 

grass seeds (or other species identified for the restoration) would be broadcast or applied with 

mulch (hydro-seeding). Weed-free straw or other mulching may be applied. If any shrubs or trees 

are identified as part of the restoration, these would be planted using a hand shovel with 

minimum soil disturbance (using bare-rooted 12 inch stock). Each of these components of active 

restoration would be applied as necessary based on the site conditions at the treatment area. 

Early Detection/Rapid Response Strategy 

EDRR refers to treatments of newly inventoried invasive plant infestations, including previously 

undiscovered invasive plant infestations or new infestations that would occur over the next 15 

years. Treatments may occur in all land allocations within the Forest and Scenic Area, and may 

include invasive species that are not analyzed in this EIS. Although species may not be analyzed 

in the EIS, the site and environmental impacts from treatment methods have been analyzed. 

The EDRR is based on the premise that the impacts of similar treatments are predictable, even 

though the precise location or timing of the treatment may be unpredictable. This strategy is 

needed because: 1) the precise location of individual target plants is subject to rapid and/or 

unpredictable change; and 2) infestations may grow during the time it typically takes to prepare 

NEPA documentation from start to finish (6 to 12 months). Invasive plant sites that are 

discovered subsequent to the last invasive plant inventory, completed in November 2004, would 

require evaluation to determine that the invasive plants treatments and environmental impacts are 

consistent with those analyzed in this EIS. If the sites and impacts are found to be consistent, 

then these new infestations could be treated under this NEPA document. Consistency would be 

determined using the model presented in Figure 1-4, and approved by the appropriate responsible 

official (Forest Supervisor or Area Manager). All herbicide treatments require the completion of 

the Pesticide-Use Proposal Form FS-2100-2 (Appendix E) to document decision to use pesticides 

on National Forest System lands. 

The EDRR would enable smaller invasive plant populations to be treated, increasing treatment 

effectiveness and success because more treatment options exist for smaller target populations, 

and the cost and adverse impacts of treatments are less if invasive plant populations are treated 

when small. Also, the EDRR would allow rapid response when newly inventoried populations 

are discovered to prevent the further spread of the invasive plant and reduce the impacts from the 

invasive plant. 

Triggers and thresholds are designed to prescribe the potential treatment methods that would be 

effective and ensure that treatments would be consistent with those analyzed in this EIS, as 

detailed in Figure 1-4. If the proposed treatments are outside these triggers and thresholds, new 

NEPA analysis and disclosure would be required. Examples of when new NEPA would be 

required include: conducting invasive plant treatments that could not be fully mitigated using the 

PDC; aerial spraying herbicides; using prescribed burning, tilling, plowing, or cattle grazing as 

invasive plant treatment methods; treating more than the designated acres (e.g., 13,000 per year); 

applying herbicides not analyzed in EIS; or applying herbicides within Bull Run hydrologic unit. 

2-32 
Site-Specific Invasive Plant Treatments

Annually, the Forest and Scenic Area would identify sites for potential treatment (both known 

and univentoried) and review the criteria for appropriateness of prescribed methods to ensure 

consistency and effectiveness for each site. All recommended treatment methods would be 

documented and approved by the appropriate responsible official(s). 

Treatments would be developed for new infestations based on the size of the invasive plant 

infestations, their priority for treatment and proximity to other infestations. Priorities would be 

evaluated and established each year, based on the criteria discussed in Table 2-8. The priorities 

are adapted from the Invasive Plant FEIS (2005a). The treatment methods/choices are changed to 

reflect those analyzed in this EIS and roadsides are a higher priority because these areas are the 

most frequently impacted on the Forest and Scenic Area. New invasive plant infestations may 

have a higher treatment priority than currently known sites. The Forest and Scenic Area would 

screen the new sites and prepare a file document demonstrating how the new treatment is within 

the scope of the original NEPA decision and demonstrating how the EDRR is being met and 

followed. All PDC must be applied to any invasive plant treatment, including the public 

notification process. 

Table 2-8: Priorities for Treatment and Selection of Treatment Methods for invasive plant 

treatment areas. This prioritization system was adapted from Table 3-12 (page 3-79) of the 

Invasive Plant FEIS (2005a).

Priority Description 

Treatment – Choice Based on 

Site-Specific Conditions 

Highest 

Priority for 

Treatment 

• Eradication of new species (focus on 

aggressive species with potential for 

significant ecological impact including 

but not limited to State-listed high 

priority invasive plants (noxious 

weeds); See Appendix I) 

• New infestations (e.g., populations in 

areas not yet infested; “spot fires”; any 

State, Forest or Scenic Area priority 

species). 

• Active restoration sites where invasive 

plant control is essential for successful 

restoration. 

• Manual/mechanical treatment on 

isolated plants or small populations. 

• Remove seed heads. This is an 

interim measure if cost/staff is an 

issue. 

• Herbicide treatment if 

manual/mechanical is known to be 

ineffective or population too large. 

• Seed and/or mulch to restore 

treated areas; use native species 

when possible. 

• If active restoration is necessary, 

seed to restore treated areas; use 

native species when possible. 

2-33 
Final Environmental Impact Statement 

2-34 

Priority 

Treatment – Choice Based on 

Description Site-Specific Conditions 

Second 

Priority of 

Treatment 

• Areas of concern such as: 

– Areas of high traffic and sources of 

infestation (e.g., parking lots, 

trailheads, horse camps, gravel 

pits) 

– Areas of special concerns: (e.g., 

botanical areas, wilderness, 

research natural areas, adjacent 

boundaries/access with national 

parks). 

– Riparian corridors where high 

threat species such as knotweeds 

occur. 

• Manual/mechanical treatment on 

isolated plants or small populations 

in spread zones. 

• Herbicide treatment if 

manual/mechanical is known to be 

ineffective or population too large. 

• Seed and/or mulch to restore 

treated areas; use native species 

when possible. 

Third Priority 

of Treatment 

• Containment of existing large 

infestations (e.g., focusing on Statelisted highest priority species or 

Forest/Scenic Area priority species). 

Focus on boundaries of infestation. 

• Roadsides; focus first on access points 

leading to areas of concern. 

• Mechanical treatment 

• Goat grazing, cultural treatment 

• Herbicide treatments 

Fourth Priority 

of Treatment 

• Control of existing large infestations 

(e.g., State-listed and Forest/Scenic 

Area second priority species) 

• Mechanical treatment 

• Goat grazing, cultural treatment 

• Herbicide treatments along 

perimeters 

Fifth Priority of 

Treatment 

• Suppression of existing large 

infestations when eradication/control or 

containment is not possible. 

• Mechanical treatment 

• Goat grazing, cultural treatment 

• Herbicide treatments along 

perimeters 

Overall, treatment would not exceed 30,000 acres of the project area landscape over 15 years for 

both known and future infestations. It is estimated that 50 percent of the Forest likely to be 

infested with invasive plants had been inventoried (Stein, 2005). The inventoried areas include 

roads, campgrounds, quarries, and timber sales. The inventory includes only limited forested 

areas, designated Wilderness Areas, and recreational trails. Assuming that the infestations on the 

remaining 50 percent of the likely infested areas (e.g., roads and quarries) follow a similar 

pattern, and assuming that the Scenic Area mirrors the Forest, only an additional 13,000 acres 

would be infested with invasive plants in the future. In order to account for the uncertainty and 

unpredictability associated with invasive plants and their treatments, the treatments acres were 

expanded by an additional 15 percent (4,000 acres): 1 percent of unexpected infestations per year 

for the life of the project. Combining the known infestations (13,000 acres), future estimate 

(13,000 acres), and expansion acres (4,000), the total area assessed to be treated is 30,000 acres 

on the Forest and Scenic Area. 
Site-Specific Invasive Plant Treatments

Within this overall cap of 30,000 acres over 15 years, there are several additional treatment caps 

(limitations) to ensure the treatment does not exceed the impacts analyzed in Chapter 3. These 

limitations include annual, fifth-field watershed, and riparian reserve caps. 

• Annual cap: The annual treatments would not exceed 13,000 acres within the Forest and 

Scenic Area. These treatments would be a combination of known treatment sites and 

newly inventoried treatment sites. This limitation was chosen because Chapter 3 analyzes 

the effects of treating 13,000 acres, so the effects are known and inform the decision. 

• Fifth field watershed cap: Treatment could not exceed three percent per year in any one 

fifth-field watershed. If the areas of National Forest System lands within each fifth-field 

watershed are less than three percent, treatment would not exceed the amount of National 

Forest Service lands (see Table 2-9 for specifics for each watershed). 

• Riparian reserve cap: Treatment would not exceed 5,000 acres in riparian reserves each 

year. Only 40 percent of the total area treated in each fifth-field watershed could be 

located in a riparian reserve for the life of the project. 

Appendix J details treatment acres by fifth-field watershed and riparian reserve acres. Also, the 

applicable watershed assessments (Table 2-9) contain applicable management direction that is 

considered when developing treatments. 

For each cap, each acre treated would only be counted once. For example, if a treatment area of 

100 acres is treated 3 times annually, only 100 acres would be counted towards the 13,000 acre 

annual cap. The acres treated each year would be based on the infestations and invasive plant 

budget. Acres would not be treated if invasive plants are not present. 

2-35 
Final Environmental Impact Statement 

2-36 

Table 2-9: Total allowable amount of invasive plant treatments under the EDRR by fifth-field watershed areserves. 

Fifth-field Number 

Fifth-field Watershed Name Applicable Watershed Assessment(s) * 

Total 

Acres 

Forest 

Service 

Lands in 

Watershed

Maxim

Ac

Treated 

Year 

1707010502 Fifteenmile Creek Mile Creeks (USDA Forest Service, 1994b) 157,238 17,580 4,1707010503 Fivemile Creek Mile Creeks (USDA Forest Service, 1994b) 78,191 18,557 2,1707010504 Middle Columbia/ 

Mill Creek 

Mill Creek (USDA Forest Service, 2000a) 130,698 15,965 3,

1707010505 Mosier Creek Mosier (Wasco County SWCD, 2002) ** 42,424 1,446 1,1707010506 East Fork Hood 

River 

East Fork Hood River & Middle Fork Hood River (USDA Forest Service, 1996b) 

100,953 68,419 3,

1707010507 West Fork Hood 

River 

West Fork of Hood River (USDA Forest Service, 1996h) 

65,466 42,863 1,

1707010508 Lower Hood River Hood River (Hood River SWCD, 1999) 51,289 3,274 1,1707010512 Middle Columbia/ 

Grays Creek 

Hood River (Hood River SWCD, 1999) 92,723 27,924 2,

1707010513 Middle Columbia/ 

Eagle Creek 

Columbia River Tributaries East (USDA Forest Service, 1998a) 

84,495 46,506 2,

1707030603 Upper Deschutes 

River 

144,429 716 

1707030604 Mill Creek Olallie Lake (USDA Forest Service, 1997b) 69,023 3,181 2,1707030605 Beaver Creek 106,742 1,312 1,1707030606 Warm Springs River 170,502 10,135 5,1707030607 Middle Deschutes 

River 

White River (USDA Forest Service, 1995g) 195,385 2,874 2,

1707030609 Tygh Creek White River (USDA Forest Service, 1995g) 81,558 41,637 2,1707030610 White River White River (USDA Forest Service, 1995g) 176,272 105,185 5,1708000101 Salmon River Salmon River (USDA Forest Service, 1995d) 73,716 67,920 2,1708000102 Zigzag River Zigzag (USDA Forest Service, 1995h) 37,764 36,502 1,1708000103 Upper Sandy River Upper Sandy (USDA Forest Service, 1996g) 34,201 30,722 1,1708000104 Middle Sandy River Upper Sandy (USDA Forest Service, 1996g) 40,957 6,572 1,1708000105 Bull Run River Bull Run River (USDA Forest Service, 1997a) 88,985 78,651 2,1708000107 Columbia Gorge 

Tributaries 

Columbia River Tributaries East (USDA Forest Service, 1998a) 

103,926 40,404 3,
Site-Specific In

2-37 

Fifth-field Number 

Fifth-field Watershed Name Applicable Watershed Assessment(s) * 

Total 

Acres 

Forest 

Service 

Lands in 

Watershed

Maxim

Ac

Treated 

Year 

1708000108 Lower Sandy River Oregon Columbia River Tributaries West 

(USDA Forest Service, 1999a) 

47,155 3,188 1,

1709000502 North Fork 

Breitenbush River 

69,418 68,509 2,

1709000505 Little North Santiam 

River 

Collawash/Hot Springs (USDA Forest Service, 1995a) 

72,408 36,189 1,

1709000905 Upper Molalla River South Fork Clackamas River (USDA Forest 

Service, 1997c) 

129,260 2,520 2,

1709000906 Lower Molalla River 92,582 231 1709001101 Collawash River Collawash/Hot Springs (USDA Forest Service, 

1995a) 

97,421 96,559 2,

1709001102 Upper Clackamas 

River 

Upper Clackamas River (USDA Forest Service, 1995f) 

100,497 94,781 3,

1709001103 Oak Grove Fork 

Clackamas River 

Clackamas River - Oak Grove Fork (USDA Forest Service, 1996a) 

90,542 79,256 2,

1709001104 Middle Clackamas 

River 

Fish Creek (USDA Forest Service, 1994a), Lower Clackamas River (USDA Forest Service, 1996d), North Fork Clackamas River (USDA Forest Service, 1996e), Roaring River (USDA Forest Service, 1996f), South Fork Clackamas River (USDA Forest Service, 1997c) 

138,507 124,903 4,

1709001105 Eagle Creek Eagle Creek (USDA Forest Service, 1995b) 57,611 16,912 1,1709001106 Lower Clackamas 

River 

Lower Clackamas River (USDA Forest Service, 1996d) 

117,661 1,623 1,

Note: Fifth-field watersheds shaded in gray do not have any known invasive plant treatment areas.* Watershed Assessments prepared by the Mt. Hood National Forest are available at: http://www.fs.fed.us/r6/mthood/publication

watershed assessments, however, were prepared by Mt. Hood National Forest. * Mosier Watershed Assessment is available at: http://www.wasco.oacd.org/MosierWatershedAssessment.pdf

*** Maximum acres treated per year are 3% of the total fifth-field watershed acres or all Forest Service lands within the fifth-field amount is less than 3%. **** Maximum riparian reserve acres treated for the life of the project is 40% of the annual area that could be treated each year watershed. 
Final Environmental Impact Statement 

2-38 

Invasive Plant Treatment Prescriptions Assumptions 

The analysis of the Proposed Action in Chapter 3 is based on the assumption that none of the 

treatments would be considered 100 percent effective after the initial entry. While initial entries 

in year one are estimated to eliminate up to 80 percent of the invasive plants, maintenance entries 

would be required in either year one or in subsequent years. The effectiveness estimate is based 

on the species proposed for treatment in conjunction with the treatment methods proposed; the 

effectiveness is not based on the specific areas being proposed for treatment. The Forest and 

Scenic Area botanists made this estimate using information for noxious weed program managers 

at the State and County agencies. 

The number of invasive plants would decrease with each maintenance entry; however, the 

remaining invasive plants may be spread over the entire treatment area. This would require the 

entire treatment area to be treated again, but significantly less herbicides and/or non-herbicide 

treatments would be needed on the maintenance entries. The number and timing of maintenance 

entries would be dependent on the treatment strategies, treatment priority, invasive plant species 

present, site-specific conditions, and success of initial and subsequent treatments. The priority 1 

and 2 treatment areas may receive up to three herbicide treatments per year for three years. 

Based on the PDC detailed in Section 2-2, broadcast spraying would occur once per year; 

triclopyr can never be broadcast sprayed; and picloram and clopyralid would only be used once 

per year at any site regardless of the treatment prescription or strategy. 

Given the variability of IWM and treatment effectiveness, several assumptions were made about 

the treatment prescriptions for analysis purposes. These assumptions follow. 

• PDC are a mandatory component of each alternative. PDC would be applied effectively 

and would accomplish the necessary and desired outcome. 

• 80 percent effectiveness is assumed at each treatment area after each year. For example, 

if 1000 acres are treated in year 1 and the treatment is 80 percent effective, only 20 

percent of the invasive plants would remain in year 2. The remaining invasive plants in 

year 2, however, may be spread over the entire treatment area. As a result, the entire 

treatment area would be treated again in year 2, but significantly less herbicides and/or 

non-herbicide treatments would be needed. 

• Treatments would be required for a minimum of 5 years. Although the invasive plants 

may be removed from the sites prior to 5 years, the worse-case scenario is analyzed. 

• All potential herbicides would be analyzed at each treatment area. Herbicides would be 

applied at the typical application rate (see Table 2-7). 
Site-Specific Invasive Plant Treatments

• Priority 1 and 2 sites with treatment strategies of eradicate and contain receive the most 

intense treatments. This includes up to three herbicide treatments per year for three years 

as considered appropriate based on factors, such as species, location, and length of 

growing season. Priority 3, 4 and 5 sites would only receive one herbicide treatment per 

year, but this may require more years of treatments. 

• No herbicides would be applied directly to water. 

• Treatments would not be carried out if they are not needed. Only infested areas would be 

treated. 

These assumptions allow the analysis to identify the impacts and effects under the worse-case 

scenario. 

Forest Plan Amendment 

The Invasive Plant FEIS (2005a) and Invasive Plant ROD (2005b) provide new Forest Plan 

direction designed to make new practices, technologies, and chemical formulations of herbicides 

available for use to facilitate the reduction in the extent and rate of spread of invasive plants, and 

to help prevent new infestations. The new direction includes desired future condition statement; 

goals and objectives statements; standards for preventing the introduction, establishment, and 

spread of invasive plants; standards for invasive plant treatment and site restoration; and an 

inventory and monitoring framework. This direction is detailed in Appendix 1 of the Invasive 

Plant ROD (2005b). In addition, the Invasive Plant FEIS (2005a) and Invasive Plant ROD 

(2005b) update all standards referencing previous regional management direction. 

Under the existing Forest Plan, six standards and guidelines discourage or prohibit the use of 

pesticides, including herbicides, on the Forest. These standards and guidelines were not amended 

under the new management direction provided by the Invasive Plant ROD (2005b). As a result, 

this EIS proposes to amend these six standards and guidelines (See Table 2-10) to allow, where 

appropriate, careful and targeted herbicide use to treat invasive plants according to the standards 

in the Invasive Plant ROD (USDA Forest Service, 2005b). This would be Amendment #16 to the 

Mt. Hood Land and Resource Management Plan (Forest Plan). 

2-39 
Final Environmental Impact Statement 

Table 2-10: Proposed Amendment to the Forest Plan under the Proposed Action. 

Suggested changes are italic or strikethrough print. 

Standard & Guideline 

Page # in 

Forest Plan 

Water (FW-076a): Potentially detrimental materials associated with management 

activities (e.g., pesticides, fertilizers, and road surface treatments) shall be 

prevented from entering water or other areas not intended for treatment, except 

for invasive plant treatments as specified in Standard FW-076b. 

4-57 

Water (FW-076b): Potentially detrimental materials associated with invasive plant 

treatments should management activities (e.g., pesticides, fertilizers, and road 

surface treatments) shall be prevented from entering water or other areas not 

intended for treatment, according to standards in the Pacific Northwest Region: 

Preventing and Managing Invasive Plants Record of Decision (2005). 

4-57 

Wilderness (A2-082): Pesticides use shall be prohibited, except for herbicides 

used to treat invasive plants according to standards in the Pacific Northwest 

Region: Preventing and Managing Invasive Plants Record of Decision (2005). 4-142 

Outdoor Education Areas (A12-031): Herbicides should not be applied outside of 

roads rights-of-way, except for herbicides used to treat invasive plants according 

to standards in the Pacific Northwest Region: Preventing and Managing Invasive 

Plants Record of Decision (2005). 

4-200 

Pileated Woodpecker/Pine Marten Habitat (B5-041): Herbicides should not be 

permitted outside of road rights-of-way, except for herbicides used to treat 

invasive plants according to standards in the Pacific Northwest Region: 

Preventing and Managing Invasive Plants Record of Decision (2005). 

4-244 

General Riparian Area (B7-070): Application of herbicides shall be discouraged,

except for herbicides used to treat invasive plants according to standards in the 

Pacific Northwest Region: Preventing and Managing Invasive Plants Record of 

Decision (2005). 

4-260 

Vegetation Management (A1-WR-064): Chemicals shall not be used to control 

noxious weeds in riparian areas, except for herbicides used to treat invasive 

plants according to standards in the Pacific Northwest Region: Preventing and 

Managing Invasive Plants Record of Decision (2005). 

Amendment #7 

2-40 
Site-Specific Invasive Plant Treatments

2.1.4. Alternative 3 – Restricted Herbicide Use Alternative 

The Restricted Herbicide Use Alternative (Alternative 3) modifies the Proposed Action to reduce 

the amount of herbicides applied. Only 4,047 acres would be treated using herbicide treatments 

under this alternative, compared to 13,000 acres under Alternative 2. These treatment areas were 

chosen because they are the highest priority sites, as defined by Table 2-8. Highest priority sites 

emphasis the eradication of new species, new infestations, or active restoration sites. Currently, 

the Forest and Scenic Area are focusing on the eradication of 5 new species: orange hawkweed 

(HIAU), common hawkweed (HIVU), meadow hawkweed (HIPR), butter and eggs (LIVU2), 

and Japanese knotweed (POCU6). Often these high priority species are only most effectively 

treated with herbicides, as discussed in Section 3.6 – Botany and Treatment Effectiveness. The 

new infestations may be very common invasive plants species threatening to invade new areas or 

forested areas. Lastly, two active restoration sites are included in this project. 

Alternative 3 was designed to address the public concern related to the quantity of herbicides 

used while treating the highest priority species. Also, this alternative allows the responsible 

officials to evaluate the impacts that the quantity of herbicides has on human health and the 

environment in the Forest and Scenic Area. 

Invasive Plant Treatment Prescriptions 

The same 13,000 acres within the Forest and Scenic Area would be treated under Alternative 3 

using IWM treatment methods. Only the highest priority sites (defined in Table 2-8) would be 

treated with herbicide treatments. The map of proposed treatment areas for the Restricted 

Herbicide Use Alternative illustrates the high priority sites (See Figure 2-14). Forty-three 

treatment areas (4,047 acres) have been identified for herbicide treatments: see Table 2-11 for a 

brief description of the highest priority sites. The invasive plant treatment prescriptions for the 

remaining 165 treatment areas would follow those listed under Alternative 2 for manual, 

mechanical and cultural (goat grazing) treatments (See Appendix F – Site and Treatment 

Information). Table 2-12 displays the total acres to be treated and treatment methods within the 

Forest and Scenic Area. Figures 2-15 through 2-19 illustrate the proposed treatment areas on the 

Scenic Area and each District under Alternative 3. 

2-41 
Final Environmental Impact Statement 

Table 2-11: Description of Highest Priority Sites. All these sites are priority 1 sites, as defined 

by Table 2-8. These sites would be treated with herbicide treatments under Alternative 3. 

Treatment ID Priority Description Acres 

# Treatment 

Areas 

69-006 Eradication of new species – Meadow 

hawkweed (HIPR) sites 

0.1 1 

66-047 Eradication of new species – Yellow 

star thistle (CESO3) sites 

7 1 

61-050 Spot infestation in new geographic 

area – Houndstongue (CYOF) on 

Barlow Ranger District 

112 1 

69-026 Spot infestation in New Area – Scotch 

broom (CYSC4) on Zigzag Ranger 

District 

1 1 

65-002, 69-008 Eradication of new species – Several 

hawkweed species at site 

1129 2 

65-046, 69-003 Eradication of new species – Common 

hawkweed (HIVU) sites 

53 2 

22-01, 22-08 Active Restoration Site – Sandy River 

Delta and East Pit Quarry Restoration 

1524 2 

61-022, 65-016, 66-041, 66-059, 

66-081, 66-082, 66-083, 66-084 

Eradication of new species – Butter 

and eggs (LIVU2) sites 

272 8 

66-001, 66-003, 66-004, 66-005, 

66-006, 66-007, 66-016, 69-027, 

69-028, 69-030 

Eradication of new species – Orange 

hawkweed (HIAU) sites 

936 10 

65-005, 65-006, 65-008, 65-009, 

65-011, 65-019, 65-021, 69-002, 

69-010, 69-011, 69-012, 69-013, 

69-014, 69-015, 69-029 

Eradication of new species – 

Japanese knotweed (POCU6) sites 

12 15 

Total 4046 43 

Table 2-12: Summary of Treatment Methods for Alternative 3 – Restricted Herbicide Use. 

Overall Treatment Acres Percent of Total

Herbicide * 12 0.1%

Herbicide plus Manual * 112 0.9%

Herbicide plus Manual and Mechanical * 2,207 17.1%

Herbicide plus Manual, Mechanical and Cultural (Goat Grazing) * 1,500 11.6%

Herbicide plus Mechanical * 217 1.7%

Manual 242 1.9%

Manual and Mechanical 8,572 66.1%

Manual, Mechanical, and Cultural (Goat Grazing) 10

Mechanical 93 0.7%

Total 12,965 100.0%

* High priority treatment areas only. 

2-42 
Site-Specific Invasive Plant Treatments

Figure 2-14. Map of Proposed Treatment Areas for the Restricted Herbicide Use 

Alternative 

2-43 
Final Environmental Impact Statement 

Figure 2-15. Restricted Herbicide Use Alternative Map for Columbia River Gorge National 

Scenic Area 

2-44 
Site-Specific Invasive Plant Treatments

Figure 2-16. Restricted Herbicide Use Alternative Map for Barlow Ranger District, 

Mt. Hood National Forest 

2-45 
Final Environmental Impact Statement 

Figure 2-17. Restricted Herbicide Use Alternative Map for Clackamas River Ranger 

District, Mt. Hood National Forest 

2-46 
Site-Specific Invasive Plant Treatments

Figure 2-18. Restricted Herbicide Use Alternative Map for Hood River Ranger District, 

Mt. Hood National Forest 

2-47 
Final Environmental Impact Statement 

Figure 2-19. Restricted Herbicide Use Alternative Map for Zigzag Ranger District, 

Mt. Hood National Forest 

2-48 
Site-Specific Invasive Plant Treatments

Only three treatment areas have broadcast herbicide application methods prescribed: Sandy 

River Delta restoration site (#22-01), Lolo Pass utility corridor and road (#66-016), and westside 

of the BPA power line (#66-007); see Figure 2-14 for locations. Broadcast spraying is being 

proposed to meet the purpose and need at these sites, given the size of the infestation and the 

treatment strategy. 

• Sandy River Delta restoration site (#22-01). The primary focus of this treatment area is to 

restore native vegetation. The infestation occurs within a 1,500-acre area and includes at 

least 5 invasive plant species. The treatment strategies for this site vary from contain to 

suppress given its size. 

• Lolo Pass utility corridor (#66-016). The primary focus of this treatment area is to stop 

the spread of orange hawkweed from spreading into the adjacent forested areas or nonfederal lands. The infestation occurs within a 79-acre area. The treatment area contains 

three species with treatment strategies of eradicate or control. 

• BPA power line (#66-077). Similarly to the Lolo Pass utility corridor, the primary focus 

of this treatment area is to stop the spread of orange hawkweed from spreading into the 

adjacent forested areas or non-federal lands. The infestation occurs within a 449-acre area 

and is currently being treated on the Zigzag Ranger District. Treatment is not occurring 

on the Hood River Ranger District. The treatment area contains only orange hawkweed, 

which has a treatment strategy of eradicate. 

These three sites total 2,028 acres. PDC F.1. limits the area next to a stream that can be treated 

using broadcast application methods. This PDC decreases the treatment area of these three sites 

to 1,866 acres. This represents 46 percent of the acres proposed for treatment under this 

alternative. The remaining 2,181 acres would be treated using selective/hand, stem injection or 

spot spraying herbicide treatment methods. The potential herbicides by treatment sites for this 

alternative are listed in Appendix K – Treatment and Proposed Herbicide Information for 

Alternative 3. 

All other components of Alternative 2 apply to this alternative as well, including invasive plant 

species, treatment strategies, common control measures, herbicide active ingredients and 

application rates, and site restoration techniques. The same proposed Forest Plan amendment 

would apply to Alternative 3, regardless of whether herbicide use is currently being proposed in 

these areas in order to allow action under the EDRR. 

The premise and intent of the EDRR remains the same under Alternative 3. The annual treatments 

would not exceed 13,000 acres within the Forest and Scenic Area: these treatments would be a 

combination of known treatment sites and newly inventoried treatment sites. Within these 13,000 

acres that would be treated annually, the treatments areas located in riparian reserves would not 

exceed 5,000 acres. Further, the acres of treatment would be capped within each fifth-field 

watershed and riparian reserve: treatment would not exceed three percent per year in any one 

fifth-field watershed per year, and treatment in riparian reserves would not exceed 40 percent of 

the potential treatment in each fifth field watershed for the life of the project (see Table 2-9). 

2-49 
Final Environmental Impact Statement 

If the acres of National Forest System lands within each fifth-field watershed are less than three 

percent, the amount of National Forest System lands would not be exceeded. All acres treated 

under this EIS would not exceed 30,000 acres. Under Alternative 3, herbicide treatments would be 

limited to the highest priority sites as outlined in Table 2-8. As a result, significantly less herbicide 

would be used under the EDRR for Alternative 3. All other sites would be treated using manual, 

mechanical and cultural (goat gazing) methods as proposed in the description of this alternative. 

Invasive Plant Treatment Prescriptions Assumptions 

Similar to Alternative 2, the assumption is that none of the treatments would be a 100 percent 

effective after the initial entry. The initial treatments on the highest priority sites are estimated to 

eliminate up to 80 percent of the invasive plants. It is estimated, however, that the initial 

treatments on the remaining 8,917 acres would be less effective. The effectiveness would drop 

because these acres would be treated by mechanical, manual, and/or cultural (goat grazing) 

treatments which are less effective than herbicide applications for many of the invasive plants 

present within the Forest and Scenic Area. These methods are less effective for a variety of 

reasons including the following. 

• Hand pulling often does not remove the roots of plants which could then resprout; 

• Mechanical treatments only cut the plants down and do not kill or remove any plants; and 

• Areas have to be repeatedly treated because more plants are missed using manual and 

mechanical methods, compared to herbicide methods. 

More information on treatment effectiveness is available in Section 3.6 – Botany and Treatment 

Effectiveness. For these reasons, it is estimated that the effectiveness for these acres would only 

be 50 percent and that more maintenance entries would be required over subsequent years. 

Regardless of the effectiveness, maintenance entries would be required, and the number and 

timing of the entries would be dependent on the treatment strategies, treatment priority, invasive 

plant species present, and site-specific conditions. The overall effectiveness for this alternative is 

estimated to be 60 percent. 

The effectiveness estimates are based on the species proposed for treatment in conjunction with 

the treatment methods proposed; the effectiveness is not based on the specific areas being 

proposed for treatment. The Forest and Scenic Area botanists made this estimate using 

information for noxious weed program managers at the State and County agencies, as well as 

their experience treating invasive plants on the Forest and Scenic Area. 

All other assumptions related to timing, herbicides, priorities, treatments, and PDC presented in 

the Alternative 2 discussion apply to this alternative as well. 

2-50 
Site-Specific Invasive Plant Treatments

2.2 Project Design Criteria for Alternatives 2 and 3 

Project design criteria (PDC) were developed to reduce or eliminate potential impacts the various 

treatments may cause. PDC define a set of conditions or requirements that an activity must meet 

to avoid or minimize potential effects on sensitive resources. All PDC are required for both 

Alternatives 2 and 3. PDC are not optional and are incorporated in the effects analysis.4

A. Herbicide Applications 

A.1. Herbicides would be used in accordance with label instructions, except where more 

restrictive measures are required as described below. 

A.2. Herbicide use would comply with standards in the Pacific Northwest Regional Invasive 

Plant Program – Preventing and Managing Invasive Plants FEIS (2005a), including 

standards on herbicide selection, broadcast use of some herbicides, tank mixing, 

licensed applicators, and use of adjuvants, surfactants and other additives. All the 

standards are included in Appendix A. 

A.3. Spray equipment would be calibrated prior to seasonal start-up and periodically 

throughout the season to assure accuracy in applications. Spray tanks would not be 

washed or rinsed within 150-feet of any live water. All herbicide containers and rinse 

water would be disposed of in a manner that would not cause contamination of waters. 

A.4. No more than daily use quantities of herbicides would be transported to the project 

site. 

A.5. Equipment used for transportation, storage, or application of herbicides would be 

maintained in a leak-proof condition. 

A.6. Favor transportation routes with less traffic and are not adjacent to water. 

A.7. Mixtures of herbicide formulations containing 3 or less active ingredients may be 

applied where the sum of all individual Hazard Quotients (HQ) for the relevant 

application scenarios is less than 1.0. No herbicide mixing would be allowed within 

150-feet of any live waters. Impervious material, such as a bucket, would be placed 

beneath mixing areas in such a manner as to contain any spills associated with 

mixing/refilling. 

 

4

 Some of the requirements from the herbicide labels and standards in the Invasive Plant ROD (2005b) are repeated 

in the PDC for emphasize. All labels and Invasive Plant ROD standards need to be consulted before invasive plant 

treatments occur. 

2-51 
Final Environmental Impact Statement 

A.8. Herbicide applications would not exceed the typical application rates specified in 

Table 2-7. 

A.9. Broadcast spray with NPE surfactant would be applied at a rate not to exceed 0.5 lb 

ai/acre. 

B. Field Operations 

B.1. A pre-operations briefing would be required annually prior to treatment between a 

USDA Forest Service project coordinator knowledgeable about invasive plant 

treatments and the lead contractor or employee who would be implementing the 

treatment. This session would be documented, and would serve to brief spray 

personnel on the location of sensitive resources (streams, lakes, wetlands, sensitive 

plants) and to review all operational details. The briefing would include safety issues, 

location, timing, treatment method, herbicides approved for use, PDC, and other 

pertinent topics. More briefings would be conducted as necessary to ensure that the 

invasive plant treatments and all PDC are implemented correctly. 

B.2. Applicators would have an Herbicide Transportation, Handling, and Emergency Spill 

Response Plan, approved by the USDA Forest Service, on-site during treatments. The 

plan would identify reporting procedures, project safety planning, methods to clean up 

accidental spills, including reporting spills to the appropriate regulatory agency, and 

information regarding a spill kit contents and location. 

B.3. Off-road vehicles used for treatment of invasive plants would remain on roadways, 

trails, parking areas, or authorized areas to prevent damage to vegetation and/or soil, 

and potential degradation of water quality and aquatic habitat. 

B.4. No motor vehicles, motorized equipment, or any form of mechanical transport would 

be used in a designated Wilderness area to treat or monitor invasive plants. No 

equipment would be cached within a designated Wilderness area. 

B.5. Equipment used in off-road operations for invasive plant treatment activities would be 

properly cleaned prior to entering National Forest System land and upon leaving 

infested sites. 

B.6. For small quantities (5 gallons or less) fueling of gas-powered machinery would not 

occur within 25-feet of any live waters to maintain water quality. All other fueling 

must occur a minimum of 150-feet from any live waters. All specific details regarding 

this item would be contained in a spill plan that would be approved by the USDA 

Forest Service prior to yearly herbicide application. 

2-52 
Site-Specific Invasive Plant Treatments

B.7. Spray tanks would not be washed or rinsed within 150-feet of any running or standing 

water. All herbicide containers and rinse water would be disposed of in a manner that 

would not cause contamination to water. 

B.8. Some sites may only be reached by water travel. Typically, an inflatable kayak would 

be used, but rubber rafts or drift boats may occasionally be used. The following 

measures would be used to prevent a spill during water transport. 

B.8.a. No more than 2.5 gallons of herbicide would be transported per kayak, and 

typically it would be one gallon or less. If a raft is used, no more than 5 gallons 

would be transported on the raft. 

B.8.b. Herbicide would be carried in 1 gallon or smaller plastic containers. The 

containers would be wrapped in plastic bags and then sealed in a dry bag. The 

dry bag would be secured to the watercraft. 

B.9. Personnel applying herbicide by hand or with a backpack sprayer or personnel 

manually pulling or grubbing invasive plants would avoid, to the extent possible, 

standing or walking in wetted streams or other areas of running water. 

C. Requirements for Wind Speeds, Drift and Precipitation 

C.1. No herbicide applications would occur when wind velocity is greater than 10 mph. 

Broadcast application would not occur at wind speeds less than 2 mph. For picloram, 

the maximum wind velocity is 8 mph. 

C.2. To minimize herbicide application drift, use low nozzle pressure, apply as a coarse 

spray, and use nozzles designed for herbicide application that do not produce a fine 

droplet spray. 

C.3. No herbicide application would occur if precipitation is occurring or is imminent 

within 24 hours. 

D. Public Health and Safety 

D.1. Workers would use appropriate personal protective clothing and equipment at all times 

during application. Traffic control and signing during invasive plant treatment 

operations would be used as necessary to ensure safety of workers and the public. 

D.2. Signs notifying the public of herbicide treatments would be placed at access points to 

treatment areas prior to initiating treatment, a minimum of one week in advance of 

herbicide treatment. Signs would be removed no sooner than two weeks following 

application. Signs would list herbicides to be used, application dates, and name and 

phone number of a local contact. 

2-53 
Final Environmental Impact Statement 

D.3. Public announcement of proposed annual program of herbicide applications would be 

published in the local papers at least one month in advance of herbicide application 

(See Appendix L – Sample Public Notifications). Notifications would categorize 

treatment sites by those identified in this analysis and those identified under the Early 

Detection / Rapid Response strategy (EDRR). 

D.4. All treatment sites would be posted on the Mt. Hood National Forest 

(http://www.fs.fed.us/r6/mthood/) and Columbia River Gorge National Scenic Area 

(http://www.fs.fed.us/r6/columbia/forest/) websites. The treatment sites would be 

categorized by those identified in this analysis and those identified under the EDRR. 

The websites also would include the consistency review documentation for sites 

identified under EDRR or information on how to obtain the documentation 

D.5. Applicants of special forest products would receive notification of areas to be treated 

with triclopyr at the time of permit issuance. 

D.6. Pertinent administrative sites and developed campgrounds would be posted, barricaded 

with use caution tape, or closed in advance of herbicide application (normally 15 days) 

to ensure that no inadvertent public contact with herbicide occurs. 

D.7. Avoid any herbicide application within 600-feet of a drinking water intake on surface 

water. Notification of a landowner or other pertinent water district personnel would 

take place when herbicides are used within 1000-feet (slope distance) of a known 

water intake. Herbicides would not be applied within 100-feet of the eight mapped 

springs that are used for drinking water on the Clackamas River Ranger District. 

E. Special Status Plants (federally listed or proposed species, USDA Forest Service Pacific 

Northwest Region sensitive species, Survey and Manage species, and endemic species, 

including vascular plants, bryophytes, lichens, and fungi) 

E.1. Protection buffer widths for special status plant species are given below in Table 2-13. 

Treatments would be stipulated as shown in the table. Whenever possible herbicide 

would be applied that are selective for invasive plants in treatment areas containing 

special status species. 

2-54 
Site-Specific Invasive Plant Treatments

Table 2-13. Protection Buffer Widths for Special Status Plant Species 

Greater than 100 ft. 100 ft to 10 ft. Less than 10 ft. 

• All treatments are permitted • All treatments, except 

broadcast spraying, are 

permitted. 

• Broadcast spraying is 

permitted when special 

status plant species are 

shielded with a protective 

barrier. 

• No broadcast spraying 

• Spot treatment is 

permitted when special 

status plant species are 

shielded with protective 

barrier. Spot treatment 

includes backpack spray 

and hand application of 

herbicides. 

• Hand application of 

herbicide and/or manual 

treatment permitted 

without protective 

shielding. 

• Under saturated or wet 

soil conditions are present 

at the time of treatment, 

only hand application of 

herbicide is permitted. 

Note: For treatment sites with the epiphytic special-status species, such as the lichen Methuselah’s 

Beard, within 10-feet of an invasive plant, application of herbicides by hand/selective treatment 

methods is advised, unless invasive plant populations in the area are simply too large to treat 

effectively by hand. Epiphytic lichen and bryophyte species cannot be shielded from herbicide spray 

or mist as can terrestrial species. Also, these species are more vulnerable since they absorb 

moisture and nutrients directly from the atmosphere. 

E.2. For Areas where broadcast application of herbicides is to occur, surveys would be 

completed for the area within 100-feet from the treatment area prior to broadcast 

application, if (1) the area has not already been surveyed for special status plant 

species and (2) the area contains likely habitat for any of these species. 

E.3. For all other treatments (e.g., spot spray, manual, mechanical) surveys would be 

completed to identify all special status plant species within 10-feet of the treatment 

areas. 

E.4. Adaptive management would be used to refine (extend or reduce) buffer sizes in order 

to adequately protect special status plant species from herbicide treatments. 

E.5. When applying herbicides, reduce further invasive plant infestation at the treated site 

by protecting non-target vegetation, whenever possible, in order to minimize the 

creation of exposed ground and the potential for re-infestation. 

2-55 
Final Environmental Impact Statement 

E.6. Only a portion (e.g., less than one third) of each of the seven identified treatment areas 

containing pale blue-eyed grass, adder’s-tongue, Watson’s desert-parsley and 

Methuselah’s Beard should be treated each year during the first one to three treatment 

years in order to assess treatment effectiveness and survival of these special status 

plant species. If it is determined that these special status plant species are harmed or 

killed resulting in concerns about the survival of the population, then treatments would 

need to be reassessed and modified or an alternate treatment plan devised. 

F. Water Quality and Aquatic Organisms 

F.1. Comply with herbicide application buffers in Table 2-14. For road ditch lines 

hydrologically connected (ditch line flows directly into surface water) to water bodies: 

F.1.a. Spot or hand application is required in sections of wet ditch lines (water is 

present in ditch line or ditch line is moist). 

F.1.b. For dry ditch lines, use only clopyralid, metsulfuron methyl, aquatic 

glyphosate, aquatic triclopyr, and aquatic imazapyr. 

Table 2-14. Water Protection Measures. Aquatic influence zones for all related herbicide 

applications. Distances shown in the table represent the closest horizontal distance in feet 

(measured from bankfull flow for streams and waters edge for lakes, ponds, and wetlands) that 

a particular herbicide or application method can be used next to specific water bodies. 

Perennial Stream or 

“Live Stream” 

Intermittent Stream or 

 “Dry Stream” Lake, Pond or Wetland 

Herbicide 

Broadcast 

Spray 

(feet) 

Spot 

Spray 

(feet) 

Hand 

Application 

(feet) 

Broadcast 

Spray 

(feet) 

Spot 

Spray 

(feet) 

Hand 

Application 

(feet) 

Broadcast 

Spray 

(feet) 

Spot 

Spray 

(feet) 

Hand 

Application 

(feet) 

Clopyralid 100 15 BF 50 BF BF 100 15 WE 

Chlorsulfuron 100 15 BF 50 15 BF 100 15 WE 

Aquatic 

glyphosate 100 BF 0* WE 50 BF 0* BF 100 WE 0* WE 

Glyphosate 100 50 50 100 50 50 100 50 50 

Imazapic 100 15 BF 50 15 BF 100 15 WE 

Aquatic 

imazapyr 100 BF 0*,WE 50 BF 0* BF 100 WE 0* WE 

Imazapyr 100 15 BF 50 15 BF 100 15 WE 

Metsulfuron 

methyl 100 15 BF 50 BF BF 100 WE WE 

Picloram 100 50 50 100 50 50 100 50 50 

Sethoxydim 100 50 50 100 50 50 100 50 50 

Sulfometuron 

methyl 100 15 BF 50 15 BF 100 15 WE 

Aquatic 

triclopyr-TEA2 N/A3 15 0*,WE N/A3 15 0* BF N/A3 15 0* WE 

Triclopyr-BEE2 N/A3 150 150 N/A3 150 150 N/A3 150 150 1

 BF = Bankfull, WE = Water’s edge, 0* = Hand application of this herbicide is allowed within the wetted perimeter for treatment of 

knotweed species only 

2

 Triclopyr-TEA in active ingredient in Garlon 3A. Triclopyr-BEE is active ingredient in Garlon 4. 3

 Broadcast spraying of Triclopyr is not being considered in this EIS as a result of the impacts detailed in the Regional Invasive Plant EIS 

2-56 
Site-Specific Invasive Plant Treatments

F.2. Do not use NPE surfactant types within 25-feet of perennial streams, wetlands, lakes, 

ponds or in road ditches that are hydrologically connected to water bodies. The NPE 

surfactant ‘R-11’ is not permitted in any circumstances. 

F.3. All wetland treatments (manual, mechanical, cultural, and/or herbicide) should occur 

during times of the year when soils are driest. If herbicide treatment is necessary when 

soils are wet, use aquatic formulations or low aquatic risk herbicides (clopyralid, 

imazapic, metsulfuron methyl, aquatic triclopyr, aquatic imazapyr, aquatic glyphosate, 

chlorsulfuron, imazapyr, or sulfometuron methyl). 

F.4. Follow Oregon Department of Fish and Wildlife Guidelines for Timing of In-Water 

Work Periods (Appendix M) that applies to portions of the project that falls below the 

ordinary high water mark (e.g., bankfull). 

G. Soils 

G.1. Use only aquatic formulations or low aquatic risk herbicides where there is a high 

water table. 

G.2. Do not use chlorsulfuron on soils with high clay content. 

G.3. Do not use picloram or sulfometuron methyl on soils with high clay content (pH 

greater than 6.9), or coarse (texture coarser than loam and/or coarse fragment content 

greater than 20 percent) on shallow, unproductive or acidic soils. 

G.4. No more than one application of picloram or sulfometuron methyl would occur on a 

given area in a calendar year to reduce potential for accumulation in soil, except to 

treat areas missed during the initial application. 

G.5. Ground-based mechanized equipment would not be allowed within 25-feet of streams, 

ponds, or wetlands, except where existing trails/roads cross streams and the 

trail/roadside is the treatment area. 

G.6. Use erosion control measures (e.g., silt fence, native grass seeding) where devegetation may result in delivery of sediment to adjacent surface water. The Forest and 

Scenic Area would utilize appropriately skilled and knowledgeable individuals to assist 

in evaluation of sites to determine if erosion control treatment is necessary and the type 

of treatment needed to stabilize soils. 

2-57 
Final Environmental Impact Statement 

H. Wildlife 

H.1. Treatment of areas within 0.25-mile, or 0.50-mile line-of-sight of a bald eagle nest site 

would be timed to occur outside the nesting season of January 1 to August 31, unless 

treatment activity is within ambient noise levels and levels of human presence. 

Ambient noise levels would be defined as less than 92 decibels measured from the 

noise source to a quarter mile. 

H.2. No areas within 100-feet of a spring or seep would be sprayed with an herbicide 

without appropriate surveys conducted for sensitive salamanders or mollusks by 

qualified, knowledgeable individuals. 

H.3. No broadcast spraying within 100-yards of rocky or talus areas from June 1 to 

September 30 without surveying for Larch Mountain Salamanders (LMS). During 

unusually dry periods, this season may be extended if a specialist knowledgeable of 

LMS requirements feels that it is too dry for LMS to be above ground. During dry 

periods, LMS live underground and would not come into direct contact with 

herbicides. 

I. Site Restoration 

I.1. Treatment areas would be assessed to determine if restoration is necessary and by what 

materials. Restoration would be considered for any site within the treatment area with 

soil disturbance or vegetative density low enough to allow re-infestation or 

introduction of other invasive plants, to control erosion, and/or to provide rooting 

strength for slope stability. 

I.2. Revegetation seed mixes would be designed on a site-specific basis to consider 

objectives and conditions at each potential revegetation site. Native species would be 

used in seed mixes, unless unavailable, and shall be in compliance with Regional, 

Forest, and Scenic Area native plant policies. Desirable non-native species may be 

used when: 1) needed in emergency conditions to protect basic resource values (e.g., 

soil stability, water quality and to help prevent the establishment of invasive species); 

and 2) as an interim, non-persistent measure designed to aid in the re-establishment of 

native plants. All plant species used on the National Forest System lands would 

comply with USDA Forest Service policy regarding source and type of plant materials 

used in seeding projects. Under no circumstances would undesirable plants be used. 

2-58 
Site-Specific Invasive Plant Treatments

J. Implementation 

J.1. Develop an annual treatment and restoration plan that identifies treatment sites. The 

treatment sites would include known and undiscovered invasive plant infestations. The 

plan would be developed through an interdisciplinary approach by individuals skilled 

in natural resource sciences and approved by the appropriate responsible official(s). 

J.2. The annual treatment and restoration plan would be reviewed for heritage resources 

interests, including but not limited to review by appropriate Tribal Governments 

depending on the treatment site locations. The review would determine if there is any 

new information that should be considered prior to application to protect heritage 

resources and culturally significant sites. The Forest and Scenic Area would ensure 

that archaeological sites are not impacted by any proposal to utilize a weed wrench. 

J.3. Should any historic or prehistoric cultural resources be uncovered during project 

activities, the applicant shall cease work and immediately notify the Forest Service. 

The Forest Service will follow-up with the appropriate federal, state, local, and tribal 

government offices. 

J.4. The Forest and Scenic Area would screen the new sites identified under the EDRR and 

prepare a document demonstrating how the new treatment is within the scope of the 

original NEPA decision. These documents would be available to the public. 

J.5. The total acreage treated annually would not exceed 13,000 acres. Treatment would 

not exceed three percent per year in any one fifth-field watershed, as defined by Table 

2-9. Treatment would not exceed 40 percent of riparian reserve in each fifth-field 

watershed for the life of the project. Treatment would not exceed 5,000 acres per year 

in riparian reserves. 

J.6. Acres treated would not exceed 30,000 acres over 15 years. 

2-59 
Final Environmental Impact Statement 

2.3 Monitoring Framework for Alternatives 2 and 3 

The monitoring framework for the Proposed Action (Alternative 2) and Restricted Herbicide Use 

Alternative (Alternative 3) is comprised of the framework presented in the Invasive Plant ROD 

(2005b) in combination with the Forest Plan monitoring strategy. The Forest and Scenic Area are 

required to implement the Inventory and Monitoring Framework as amended by the Regional 

Forester this is presented in the Invasive Plant ROD (2005b) and included as Appendix N in this 

document. This framework describes the monitoring needed to assure the desired future 

condition and treatment strategies are achieved. The framework includes implementation / 

compliance and effectiveness monitoring components. Some components of the framework are 

outlined below. 

Implementation/Compliance Monitoring 

• Develop a project work plan for herbicide use. 

• Ensure contracts and agreements include appropriate prescriptions and that herbicide 

ingredients and application rates meet label requirements, Invasive Plant ROD Standards 

(2005b), and PDC (Section 2.2).

• Document and report herbicide use and certified applicator information in the pesticide 

use database, as required by USDA Forest Service regulations (Appendix E; Appendix 

N). 

Effectiveness Monitoring 

• Implementation monitoring would occur to ensure PDC are implemented as planned. 

Post-treatment reviews would occur on a sample basis to determine whether treatments 

were effective and whether or not passive/active restoration occurred as expected. 

• Post-treatment monitoring would be used to detect whether PDC were appropriately 

applied. 

• Contract administration and other existing mechanisms would be used to correct 

deficiencies. 

• Herbicide use would be reported as required by USDA Forest Service regulations 

(Appendix E; Appendix N). 

• Re-treatment and active restoration prescriptions would be developed based on posttreatment results. Changes in treatment methods would occur based on effectiveness of 

treating the invasive plant infestations. For example, an invasive plant population treated 

with a broadcast herbicide may be retreated with a spot spray or hand pulled, once the 

size of the infestation is reduced. 

2-60 
Site-Specific Invasive Plant Treatments

This monitoring requirements would be accomplished using skilled USDA Forest Service 

employees or through partnership with the herbicide applicators, such as the counties and/or 

Oregon Department of Agriculture. Currently, the herbicide applicators complete an herbicide 

treatment and monitoring record that documents the site treated, treatment methods, herbicide 

used, and method of application as well as a monitoring record. The monitoring records require a 

follow-up visit and an assessment of effects on non-target species. Similar records may be 

developed in the future to meet the monitoring needs. 

Additional monitoring would be completed as part of the Forest Plan Monitoring strategy and 

other required monitoring processes. The annual Mt. Hood Forest Plan Monitoring Report 

addresses the following questions related to invasive plants: 

• Are known untreated invasive plant sites continuing to spread? Are new infestations 

occurring? 

• Are prevention standards to reduce the risk of invasive plant establishment being 

implemented for all ground-disturbing activities? 

• Do herbicide treatments for invasive plants follow standards and guidelines set in the 

Invasive Plant FEIS (2005a)? 

Monitoring identified as “essential” would occur if the project is implemented. The essential 

monitoring would be identified during the implementation phase. Other monitoring would be 

completed as funding permits. Monitoring requirements would be increased if implementation or 

effectiveness problems result. 

2-61 
Final Environmental Impact Statement 

2.4 Comparison of Alternatives 

This section provides a summary of the effects of implementing each alternative. Information in 

the tables focuses on treatment activities and effects where different levels of effects could be 

distinguished quantitatively or qualitatively among alternatives. Table 2-15 summarizes the 

alternatives by treatment methods. Table 2-16 compares the environmental effects of 

implementing the alternatives by key and tracking issues. 

Table 2-15: Comparison of Treatment Methods by Alternative. The Proposed Action 

includes primarily broadcast spraying herbicide treatment methods. In contrast, the Restricted 

Herbicide Use Alternative includes primarily non-herbicide treatment methods, and favors 

hand/selective herbicide. 

Broadcast (Boom) 

Herbicide 

Treatments 

Hand/Selective 

Herbicide 

Treatments Only 

Non-Herbicide 

Treatment 

Methods 

Total 

Acres 

 Acres Percent Acres Percent Acres Percent Acres 

No Action 415 33% 185 15% 635 51% 1235

Proposed Action 

(Alternative 2) 10,220 79% 2,694 21% 50 1% 12,964

Restricted Herbicide 

Use (Alternative 3) 1,460 11% 2,586 20% 8,917 69% 12,964

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Site-Specific Invasive Plant Treatments

Table 2-16: Comparison of Environmental Effects of Implementing the Alternatives in 

Relation to Purpose and Need/Desired Future Condition, and Key and Tracking Issues. 

Component 

Alternative 1 

No Action 

Alternative 2 

Proposed Action 

Alternative 3 

Reduced Herbicide 

Use Alternative 

Purpose and Need/Desired Future Condition Component 

Overall acres treated 

(Acres of herbicide 

treatments) 

1,235 acres per year 

(600 acres per year) 

12,964 acres per year 

(12,914 acres per year) 

12,964 acres per year 

(4,047 acres per year) 

Ability to restore 

healthy, native 

communities and 

function at existing sites 

The Forest and Scenic 

Area treated 1,235 

acres in fiscal year 

2003. NEPA decisions 

enable the Forest and 

Scenic Area to treat 

2,250 acres each year. 

Invasive plants continue 

to spread at a rate of 10 

percent per year, which 

degrades native 

communities and 

function. 

Most likely to restore 

healthy, native 

communities and 

functions through the 

reduction of invasive 

plants and through sitespecific restoration. 

Most effective and 

timely at reducing the 

infestations and 

presence of invasive 

plants. Implements the 

most effective 

treatments as 

prescribed by the 

Common Control 

Measures (Appendix G). 

Less likely to restore 

healthy, native 

communities and 

functions. Less effective 

at reducing the 

infestations and 

presence of invasive 

plants due to decreased 

use of the most effective 

treatments, as 

prescribed by the 

Common Control 

Measures (Appendix G).

Ability to treat new/ 

additional invasive plant 

sites that may be 

identified in the future 

No EDRR EDRR allows for the 

treatment of 30,000 

acres. Treated acres 

would be a mixture of 

inventoried (November 

2004) and currently 

unknown sites. 

EDRR allows for the 

treatment of 30,000 

acres. Only priority 1 

sites as defined in Table 

2-8 would be treated 

with herbicides. Treated 

acres would be a 

mixture of inventoried 

(November 2004) and 

currently unknown sites.

Annual treatment caps 

under EDRR 

N/A 13,000 acres within the 

Forest and Scenic Area 

3 percent per year in 

any one fifth-field 

watershed 

5,000 acres in riparian 

reserve 

13,000 acres within the 

Forest and Scenic Area 

3 percent per year in 

any one fifth-field 

watershed 

5,000 acres in riparian 

reserve 

Overall treatment cap 

under EDRR 

N/A 30,000 acres over 15 

years 

40 percent of riparian 

reserves in each fifthfield watershed 

30,000 acres over 15 

years 

40 percent of riparian 

reserves in each fifthfield watershed 

2-63 
Final Environmental Impact Statement 

2-64 

Component 

Alternative 1 

No Action 

Alternative 3 

Alternative 2 Reduced Herbicide 

Proposed Action Use Alternative 

Acres of Restoration Unknown. 

Restoration occurs at 

selective sites, including 

Sandy River Delta and 

East Pit Quarry on the 

Scenic Area. 

Active: 7,277 acres 

Passive: 5,687 acres 

Active restoration is 

planned for all priority 1 

and 2 sites. Restoration 

would not begin until the 

invasive plants have 

been significantly 

reduced at the sites. 

Active: 7,227 acres 

Passive: 5,737 acres 

Active restoration is 

planned for all priority 1 

and 2 sites Restoration 

would not begin until the 

invasive plants have 

been significantly 

reduced at the sites. 

Key Issues 1 – Treatment Effectiveness 

Treatment methods 

proposed 

Manual, mechanical, and 

herbicide treatments 

Manual, mechanical, 

cultural (goat grazing), 

and herbicide treatments 

Manual, mechanical, 

cultural (goat grazing), 

and herbicide treatments 

Acres of invasive plants 

treated using herbicides 

1,235 acres 12,914 acres 4,047 acres 

Effectiveness of invasive 

plant treatments and 

treatment method 

combinations 

Estimated 60 percent 

overall effectiveness for 

1,235 acres, which 

covers 0.1 percent of the 

Forest and Scenic Area. 

Estimated 80 percent 

overall effectiveness for 

13,000 acres, which 

covers 1.1 percent of the 

Forest and Scenic Area. 

Estimated 60 percent 

overall effectiveness for 

13,000 acres, which 

covers 1.1 percent of the 

Forest and Scenic Area. 

Likelihood for invasive 

plants to spread to 

adjacent ownerships 

Most likely to spread to 

adjacent lands because 

treats the fewest acres 

(1,235 acres) effectively 

(60 percent). 

Least likely to spread to 

adjacent lands because 

treats 13,000 acres 

effectively (80 percent). 

Less likely to spread to 

adjacent lands because 

treats 13,000 acres 

relatively effectively (60 

percent). 

Key Issue 2 –Economic Efficiency 

Cost of treatments $1.3 million $4.3 million $7.3 million 

Number of full-time jobs 

created ($20,000 per 

year) 

38 jobs 94 jobs 159 jobs 

Key Issue 3 – Aquatic Organisms and Water Quality 

Acres of herbicide 

treatment in riparian 

reserves at known sites 

287 acres 

(2003) 

5,026 acres 2,450 acres 

Acres of herbicide 

treatment within aquatic 

influence zone at known 

sites 

130 acres 

(2003) 

2,114 acres 919 acres 

Number of treatment 

sites with higher risk of 

effects from herbicides 

to aquatic organisms 

Unknown 19 sites 8 sites 

Tracking Issues 

Risk to native plant 

communities 

Loss of non-target plants 

and habitat through the 

continual spread of 

invasive plants. 

Short-term loss of nontarget plants through 

treatments. Long-term gain 

of additional habitat and 

restored healthy, native 

function. 

Short-term loss of nontarget plants through 

treatments. Long-term gain 

of additional habitat and 

restored healthy, native 

function. 
Site-Specific Invasive Plant Treatments

2-65 

Component 

Alternative 1 

No Action 

Alternative 3 

Alternative 2 Reduced Herbicide 

Proposed Action Use Alternative 

Herbicide risk on 

special status plant 

species 

Unknown sites 

PDC inconsistent across 

existing NEPA 

documents. 

13 treatment areas 

containing special status 

species. 

PDC reduce risk to 

special status plant 

species. 

13 treatment areas 

containing special status 

species. 

PDC reduce risk to 

special status plant 

species. 

Acres of treatment that 

bisect or traverse areas 

of late successional 

habitat where potential 

exposure to herbicides 

could occur for special 

status wildlife species 

1,235 acres 2,373 acres 528 acres 

Total number of acres of 

wildlife habitat benefited 

by removal of invasive 

plants to restore native 

vegetation 

1,235 acres 13,000 acres 13,000 acres 

Effects of treatment 

methods on soil 

organisms and soils 

productivity 

1,235 acres impacted; 

600 acres of herbicide 

treatment 

13,000 acres impacted; 

12,914 acres of 

herbicide treatment 

13,000 acres impacted; 

4,047 acres of herbicide 

treatment 

Herbicide risk on 

culturally significant 

plants 

Unknown 

PDC inconsistent across 

existing NEPA 

documents. 

8 culturally significant 

plant sites 

PDC reduce risk to 

plants. 

8 culturally significant 

plant sites 

PDC reduce risk to 

plants. 

Effects of treatments on 

tribal communities 

Reduce culturally 

significant plants 

because invasive plant 

occupying potential 

habitat 

Long-term gain for 

culturally significant 

plants by treating 

invasive plants and 

restoring native plants 

Long-term gain for 

culturally significant 

plants by treating 

invasive plants and 

restoring native plants 

Effects of treatments on 

special forest products 

No change to current 

special forest products 

collection practices. 

Herbicides may cause a 

short-term loss of 

special forest products, 

which would impact the 

Hispanic and Asian 

communities the most. 

Herbicides may cause a 

short-term loss of 

special forest products, 

which would impact the 

Hispanic and Asian 

communities the most 

Acres of herbicide 

treatment in designated 

wilderness areas 

0 acres 15.3 acres in Mt. Hood 

Wilderness Area 

15.3 acres in Mt. Hood 

Wilderness Area 

Acres of herbicide 

treatment in Wild and 

Scenic River corridor 

0 acres 1465,3 acres in 

Clackamas, Roaring, 

Salmon, Sandy and 

White River Wild and 

Scenic River corridors 

330.7 acres in 

Clackamas, Roaring, 

and Sandy River Wild 

and Scenic River 

corridors 
Final Environmental Impact Statement 

2.5 Alternatives Considered, But Dropped from Further Analysis 

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all 

reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that 

were not developed in detail (40 CFR 1502.14). Public comments received in response to the 

Proposed Action provided suggestions for alternative methods for achieving the purpose and 

need. Some of these alternatives may have been outside the scope of this EIS, not met the 

purpose and need for action, not reasonably feasible or viable, duplicative of the alternatives 

considered in detail, or were determined to cause unnecessary environmental harm. Five 

alternatives were considered, but eliminated from detailed consideration for reasons summarized 

below. 

2.5.1 Prevention 

Some public comments suggested that the Forest and Scenic Area take no or limited action to 

treat invasive plants, but rather increase efforts to prevent the introduction of invasive plants and 

prevent the further spread of invasive plants. 

This approach would not meet the purpose and underlying need for action. The purpose and need 

for this EIS includes timely treatment of specific invasive plants species identified at sites to 

meet the site treatment strategies (eradicate, control, contain, or suppress) and of new/additional 

invasive plant sites that may be identified in the future. Scientific literature supports timely and 

appropriate treatment of invasive plants and active restoration of native plant communities as 

important tools for effective IWM (See Invasive Plant FEIS (2005a) and Chapter 3). Many of the 

invasive plants proposed for treatment are most effectively controlled with herbicide methods, 

making non-herbicide methods ineffective and unsuccessful (see discussion under No Herbicide 

Alternative below and Section 3.6 – Botany and Treatment Effectiveness). Since the purpose and 

need for action focus on the treatment components of IWM, prevention is outside the scope of 

this EIS. 

Although prevention does not meet the purpose and need, it is an important component of 

invasive plant management and integral to implementing successful treatments. The Forest and 

Scenic Area have a set of prevention standards that are incorporated into management activities 

on both units (See Appendix D). In addition, both the Forest and Scenic Area are implementing 

new prevention standards and guidelines through the adoption of the Invasive Plant ROD 

(2005b), which includes goals, objectives, and standards emphasizing prevention and early 

detection. Goal 1 (Appendix 1-1) in the Invasive Plant ROD (2005b) states: “Protect ecosystems 

from the impacts of invasive plants through an integrated approach that emphasizes prevention, 

early detection, and early treatment.” Goal 2 states: “Minimize the creation of conditions that 

favor invasive plant introduction, establishment and spread during land management actions and 

land use activities. Continually review and adjust land management practices to help reduce the 

creation of conditions that favor invasive plant communities.” See Appendix 1-1 to 1-6 of the 

Invasive Plant ROD (2005b) for specifics. 

2-66 
Site-Specific Invasive Plant Treatments

The prevention standards for the Forest and Scenic Area address the risk of ground-disturbing 

management activities spreading invasive plants within the administrative boundaries of the 

National Forest System as well as to adjacent landowners. These standards include the following. 

• Conduct a risk assessment for invasive plants in NEPA planning as well as routine 

maintenance activities, documenting occurrence where it exists and incorporating 

appropriate prevention and/or treatment measures for the activity proposed 

• Require appropriate contracts and permits to specify the cleaning of ‘off-road’ equipment 

prior to the arrival at a job site, and/or before leaving a invasive plant infested area to 

reduce the risk of carrying and spreading weeds and seeds of invasive plants (e.g., timber 

sales, road decommissioning or maintenance, natural resource restoration activities, etc.) 

• Where feasible and available, utilize weed-free plant materials (such as weed-free straw, 

etc.) for re-vegetation activities, erosion control, and/or wildlife forage enhancement. 

Communicate with state and county agencies and plant growers re: availability of weedfree plant material sources 

• Ensure that areas of soil disturbance re-vegetate promptly to minimize the risk of 

invasion of undesirable plants 

• Inspect stockpiled gravel or rock, and on-Forest rock quarries and borrow pits for 

invasive plants, and if special status species are present, treat area before material from 

the area is used on the Forest 

• In range administration annual operating plans, specify appropriate actions and practices 

to minimize the invasion and/or spread of invasive plants 

Currently, these standards are incorporated into the NEPA and other planning processes, timber 

contacts and grazing permits on the Forest and Scenic Area. In addition, per the Invasive Plant 

ROD (2005b) Standard 1, “Prevention of invasive plant introduction, establishment and spread 

will be addressed in watershed analysis; roads analysis; fire and fuels management plans, Burned 

Area Emergency Recovery Plans; emergency wildland fire situation analysis; wildland fire 

implementation plans; grazing allotment management plans, recreation management plans, 

vegetation management plans, and other land management assessments.” The Invasive Plant 

ROD (2005b) standards also direct the Forest and Scenic Area to consider invasive plants in the 

implementation of ground-disturbing management activities, including timber harvests, fuels 

treatments, fire suppression, fire rehabilitation, grazing, road maintenance, quarry sites, and 

recreational activities. Therefore, site-specific consideration of prevention standards are 

considered and analyzed through other projects and processes. 

2-67 
Final Environmental Impact Statement 

2.5.2 No Herbicide Use 

Additional public comments suggested that the Forest and Scenic Area consider a no herbicide 

use alternative. This approach would not meet the purpose and underlying need for action. The 

purpose and need for this EIS includes timely treatment of specific invasive plants species 

identified at sites to meet the site treatment strategies (eradicate, control, contain, or suppress) 

and of new/additional invasive plant sites that may be identified in the future. Scientific literature 

supports timely and appropriate treatment of invasive plants, including herbicide treatments and 

active restoration of native plant communities as important tools for effective IWM (See 

Invasive Plant FEIS (2005a) and Section 3.6 – Botany and Treatment Effectiveness). Many of 

the invasive plants proposed for treatment are most effectively controlled with herbicide 

methods, making non-herbicide methods ineffective and unsuccessful. 

The issue of scale needs to be considered when planning treatments of invasive species. 

Populations of certain invasive species would only be effectively controlled with herbicides. At 

present, the only method to control large populations of knotweed species is with repeated 

application of herbicides (Seiger, 1991). Additionally, large-scale infestations of invasive plants 

threatening to invade the Forest and Scenic Area would only be treated effectively using 

herbicides. For example, the potential for large-scale restoration of wildlands infested with 

quackgrass is probably low to moderately low, unless the infested area is tilled, treated with 

herbicide, and reseeded, or unless large-scale, resource-intensive prescribed burn programs, 

coupled with herbicide and other restoration programs are implemented (Batcher, 2002). 

The best control of perennial pepperweed seems to be from the use of herbicides (Morisawa, 

1999). Renz (2000) states that many control methods are ineffective against perennial 

pepperweed or would only be used in specific areas. The only non-herbicide control method 

effective against large populations is long-term flooding, but it is not known if plants would reestablish if the flooding regime is removed from these areas. Lyons (1998) states that the most 

successful control efforts for whitetop combine several management practices, such as herbicide 

application and physical removal by hoeing or tilling followed by competitive species plantings 

(USDA Forest Service, 2005a). 

2-68 
Site-Specific Invasive Plant Treatments

For many invasive plants, manual and mechanical treatment is difficult and often ineffective 

regardless of the size of the population. Examples include knotweed species (Japanese, 

Bohemian, Giant, and Himalayan), hawkweed species (orange, meadow or yellow, and 

common), yellow star thistle, and knapweed species (meadow and diffuse). Manual treatment is 

not recommended for knotweed species because digging out rhizomes, in addition to being 

extremely labor-intensive, tends to spread rhizome fragments, which would product new plants. 

Some authorities do not recommend manual or mechanical treatment of hawkweeds because 

disturbance to the plant would stimulate the growth of new plants from fragmented roots, 

stolons, and rhizomes and redistribute the plants, increasing their rate of spread (Montana State 

University, 2006). Although manual and mechanical treatments may be effective for yellow star 

thistle, plants would survive if leaves and buds are still attached at the base of the plant, even if a 

fragment of a stem less than 2 inches in length is left behind. Further, yellow star thistle plants 

are capable of producing 50 to 100 million seeds per acre and the seeds are spread through wind 

dispersal, which makes manual and mechanical treatments more difficult. Manual treatment for 

meadow knapweed is difficult due to the species’ tough perennial root crown, and repeated 

mechanical treatment of diffuse knapweed may increase populations by spreading seeds (See 

Section 3.6 – Botany and Treatment Effectiveness for more details). 

The most effective treatment for each of these invasive plant species as well as the other species 

analyzed in this EIS is IWM, which includes manual, mechanical, cultural (goat grazing), and 

herbicide treatments. IWM allows for appropriate tool and methods to be used based on the size 

and location of the invasive plant population as well as the surrounding conditions. Through this 

EIS, the Forest and Scenic Area would be able to consider different treatment methods and 

herbicides with distinct properties that better address the balance of effective control of invasive 

plants and protection of the environment. The most effective IWM methods are summarized in 

Appendix G – Common Control Measures Summary. 

2.5.3 No Amendment to the Mt. Hood Forest Plan 

Based on comments, the interdisciplinary team considered an alternative that would not amend 

the Forest Plan. Current Forest Plan standards and guidelines do not allow or discourage 

herbicide treatments in general riparian areas, the White River Wild & Scenic River corridor, 

designated Wilderness Areas, Northern Spotted Owl habitat, and Pileated Woodpecker/Pine 

Martine habitat. No herbicide treatments in these areas were considered in the No Action 

Alternative (Alternative 1) or Restricted Herbicide Use (Alternative 3), alternatives or no 

treatment was determined to cause unnecessary environmental harm. The reasons for eliminating 

this alternative from detailed analysis are discussed by Forest Plan standard: 

• Forest Plan Standard FW-076 prohibits detrimental materials associated with management 

activities, including herbicides, from entering water or other areas not intended for treatment. 

Invasive plant treatments are meeting this standard under the No Action Alternative 

(Alternative 1). Additionally, invasive plants may decrease water quality because invasive 

plants are often less effective for stream bank stabilization and provides less stream shading 

(See Section 3.9 – Water Quality). As a result, invasive plants may cause unnecessary 

environmental harm to the water resources. 

2-69 
Final Environmental Impact Statement 

• Forest Plan Standard A2-082 prohibits pesticide use in designated Wilderness Areas. This 

standard is addressed through the No Action Alternative (Alternative 1). Additionally, 

ecosystem level impacts of invasive plants may put wilderness characteristics at risk if the 

infestations are not treated quickly and effectively. Currently, three hawkweed sites are 

located in the Mt. Hood Wilderness. As discussed under the no herbicide use alternative that 

was eliminated, hawkweed species are most effectively treated using herbicides. To maintain 

wilderness character and prevent the further spread of invasive plants within Wilderness 

Areas herbicide treatments should be considered (see Section 3.12 – Congressionally 

Designated Areas and Scenery Management). Eliminating herbicide use in designated 

Wilderness Areas may cause unnecessary environmental harm to the natural conditions. 

• Forest Plan Standards B5-041 does not permit herbicides to be used outside road rights-ofway in Pileated Woodpecker/Pine Martin habitat. These standards are addressed under the 

No Action Alternative (Alternative 1) under which invasive plant treatments are meeting this 

standard. Fifty percent of the treatment areas are within road prisms or adjacent disturbed 

areas, as permitted by this standard. Of the remaining 50 percent, invasive plants may alter 

the ecosystem character upon which these species depend, causing unnecessary 

environmental harm to habitat conditions (see Section 3-11 – Wildlife). Further, the PDC are 

designed to minimize the effects to wildlife species and their habitat. 

• Forest Plan Standard A12-031 does not permit herbicides to be used outside road rights-of –

way in Outdoor Education Area. This standard is addressed under the No Action Alternative 

(Alternative 1) under which invasive plant treatments are meeting this standard. This 

standard covers one small portion of the Forest, where no treatments are currently proposed. 

If a future infestation was discovered, it would need to be determined to be consistent with 

the analysis using the EDRR. As such, the potential effects would be considered through this 

process. 

• Forest Plan Standard B7-070 discourages the application of herbicides in general riparian 

areas. This standard is addressed through the No Action Alternative (Alternative 1). 

Herbicide treatments are part of IWM approach which considers a combination of manual, 

mechanical, cultural (goat grazing), and herbicide treatments. Herbicide treatments are never 

considered in isolation and precautions are taken to ensure that uninfested riparian areas are 

protected and infested riparian areas are restored. Also, the PDC and aquatic influence zone 

are designed to discourage herbicide use in the general riparian areas. 

2-70 
Site-Specific Invasive Plant Treatments

2-71 

• Forest Plan Amendment #7 prohibits herbicides in the White River Wild & Scenic River 

Corridor. This standard is addressed through the No Action Alternative (Alternative 1) under 

which invasive plant treatments are meeting this standard. The White River was designated 

as a Wild & Scenic River to preserve the outstanding remarkable values or opportunities in 

the river corridor, including the botany/ecology values. Invasive plants and their potential 

spread threaten the outstanding remarkable values; therefore, no herbicide treatments may 

cause unnecessary environmental harm to the corridor. Further, the PDC offer protection to 

special status botanical, wildlife, and aquatic species as well as other ecological values 

associated with these corridors. Further, the aquatic influence zones are designed to 

discourage herbicide use in the general riparian areas and protect water quality. 

2.5.4 Maximize Cost Efficiency 

Public comments suggested that invasive plant treatments should be designed to maximize cost 

efficiency. Assuming that herbicide treatments are the least expensive, compared to the 

mechanical and manual treatment methods, this alternative is duplicative of the Proposed Action 

(Alternative 2). Alternative 2 only includes six sites that do not include an herbicide treatment 

method in the treatment area prescription (See Section 3.7 – Economic Efficiency). 

2.5.5 Maximize Worker Jobs 

Additional public comments suggested that the invasive plant treatments should be designed to 

maximize worker jobs. Assuming that manual and mechanical treatments create more jobs than 

herbicide treatments, this alternative is duplicative of the Restricted Herbicide Use Alternative 

(Alternative 3). Under Alternative 3, only high priority treatment areas are treated with 

herbicides (43 sites). The remaining 165 treatment areas are treated using manual and 

mechanical treatments, which may maximize worker jobs (See Section 3.7 – Economic 

Efficiency). 
 
CHAPTER 3 

Affected Environment and 

Environmental Consequences 
 
Site-Specific Invasive Plant Treatments 

3-1

CHAPTER 3: Affected Environment and Environmental 

Consequences 

Chapter 3 of this EIS summarizes the physical, biological, social, and economic environments of 

the affected project area (existing conditions) and the potential changes to those environments 

due to implementation of the alternatives discussed in Chapter 2 (alternatives). It also presents 

the scientific and analytical basis for the comparison of alternatives presented. For ease in 

presentation and comparison, discussions are separated into individual resource areas, including 

human health and safety, botany, economic efficiency, soil productivity, water quality, aquatic 

organisms and habitat, wildlife, congressionally designated areas, and heritage resources. 

The focus of the analysis disclosed in each section is on the effects of the No Action and action 

alternatives on the issues described in Section 1.8. Effects are defined as: 

• Effects: Adverse and/or beneficial direct effects occur at the same time and in the same 

general location as the activity causing the effects. Adverse and beneficial indirect effects 

are those that occur at a different time or location from the activity causing the effects. 

Both types of effects are described in terms of magnitude, intensity, duration, and timing. 

• Cumulative Effects: These result from the incremental impacts of the proposed 

actions/alternatives when added to other past, present, and reasonably foreseeable 

actions, both on the Forest and Scenic Area as well as other adjacent federal, state, or 

private lands. 

Effects include ecological (i.e., the effects on natural resources and on the components, 

structures, and functioning of affected ecosystems), aesthetic, historic, cultural, economic, social, 

or health, whether direct, indirect, or cumulative (40 CFR 1508.7 and 1508.8). 

3.1. Life of the Project 

This project would be implemented over five to 15 years as funding allows. Site-specific 

conditions are expected to change within this timeframe: treated infestations would be reduced in 

size, untreated infestations are likely to spread, specific non-target plant or animal species of 

local interest may change, and/or new invasive plants may become established within the project 

area. The effects analysis considers a range of possible treatments at each treatment site based on 

the invasive plant species present as well as a range of site conditions in order to accommodate 

the uncertainty associated with the project implementation scheduled, including the Early 

Detection/Rapid Response strategy (EDRR). 
Final Environmental Impact Statement 

3-2

Three variables would contribute to the effectiveness of the invasive plant treatments and 

reductions in infested acres: treatment prescriptions and strategies; the effectiveness of invasive 

plant management on neighboring lands; and available funding. The treatment prescriptions at 

each site are not intended to be binding, but treatments would be selected from the range 

analyzed in order to most effectively treat the invasive plants based on the variables influencing 

the effectiveness. Annual treatment prescriptions would be based on information gathered 

through inventory and monitoring. The highest priority areas would be treated first, and newly 

discovered infestations may be prioritized over existing sites. Treatment methods would be 

chosen using the process described in Figure 1-4. 

3.2. General Existing Conditions 

The project area encompasses 1.1 million acres of the Mt. Hood National Forest (Forest) and 

292,500 acres of the Columbia River Gorge National Scenic Area (Scenic Area). The treatment 

sites represent one percent of the total acreage on the Forest and Scenic Area. Seven sites (1,787 

acres) are located on the Scenic Area and the remaining sites are located on the Forest. Sixty-two 

percent of these sites are located on the eastside of the Forest on the Barlow (2,444 acres) and 

Hood River (5,596 acres) ranger districts, and twenty-four percent of the sites are on the westside 

on the Clackamas River (1,270 acres) and Zigzag (1,868 acres) ranger districts. These sites are 

located in Hood River, Clackamas, Multnomah, and Wasco counties. 

3.2.1. Treatment Area Site Descriptions 

The treatment sites are located in a variety of land allocations and land types. Some infestations 

are located in congressionally designated areas, including the Mt. Hood Wilderness Area (three 

sites) and all Wild and Scenic River Corridors. The Scenic Area contains some sites that were 

previously cultivated for agriculture which are being restored. Approximately 122 acres in seven 

treatment areas are located within inventoried roadless areas. This includes 33 acres in Big Bend 

Lake, 77 acres in Mt. Hood Additions, and 12 acres in Wind Creek. The invasive plant 

treatments do not propose changing any road conditions within the project area. 

The majority of treatment sites are located along roads and adjacent to disturbed areas (50 

percent). Other dominant treatment sites are located at or along restoration sites (13 percent), 

recreation residences (nine percent), utility corridors (seven percent) and quarries (five percent) 

(Table 3-1). The remaining treatment sites include administrative sites, campgrounds, clearings, 

corrals, hiking trails, harvest units, lakes, landings, ski areas, meadows, and stream-sides. The 

restoration sites are all located on the Scenic Area. As these site descriptions indicate, the human 

contributions to invasive plant infestations can be significant. In addition, many of these treatment 

areas are located within the aquatic influence zone or riparian reserves (see Sections 3.9 and 3.10). 

The aquatic influence zone is land adjacent to perennial and intermittent streams, rivers, ponds, 

lakes, springs, and wetlands that has a direct or potentially direct influence on the water body and 

its function where herbicides may enter surface waters. Riparian reserves are areas along live and 

intermittent streams, wetlands, ponds, lakes, and unstable and potentially unstable areas where 

riparian-dependent resources receive primary emphasis. Also, special forest products and 

culturally significant plants could potentially be harvested and collected at these sites as well. 
Site-Specific Invasive Plant Treatments 

3-3

Table 3–1: Acres by Site Description. Approximately 62% of the sites are disturbed areas 

(roads, quarries, utility corridors), 20% are recreational sites (developed campgrounds, permit 

areas, recreational residences), 17% are natural/forested areas (clearing, flood plains, 

meadows, forested sites, plantations), and <1% are administrative sites. 

Site Description Acres Percent 

Developed Campground 168.8 1% 

Major Resort/Permit Site 363.3 3% 

Quarry 624.7 5% 

Utility Corridors 863.2 7% 

Recreational trails 963.1 7% 

Recreational Residence & Adjacent Areas, including Roads 1,163.6 9% 

Scenic Area Restoration Sites 1,640.0 13% 

Road and Adjacent Disturbed Area 6,526.8 50% 

Total 12,313.5 95% 

Since treatment sites are located across the Forest as well as the Scenic Area, site conditions vary 

greatly. Annual precipitation varies from 10 to 120 inches per year across at the treatment sites, 

primarily in the winter months. The minimum distance to water ranges from zero to over 2,000 

feet, with the majority of sites ranging from zero to 100 feet (66 percent). The categories of 

water located within 100 feet of these sites include streams, ponds, wetlands, ditches, springs, 

and rivers. The average percent slope ranges from zero to 62 percent. The average elevation 

ranges from 25 to 5,400 feet. The general vegetation type, flora, and fauna present at the 

treatment sites vary across the sites. More information about the existing conditions at each site 

can be found in Appendix O. 

3.2.2. Invasive Plant Species and Infestations 

Each of the treatment sites has invasive plants present that threaten healthy, native communities 

and function. At least 19 species have been inventoried by USDA Forest Service botanist and 

noxious weed specialists on the Forest and Scenic Area using inventory and mapping protocols 

established by the USDA Forest Service under the NRIS Terra Invasive Plant database (USDA 

Forest Service, 2002). It is likely additional species are present on the Forest and Scenic Area, 

but have not yet been discovered. 

The invasive plants found most frequently in the treatment sites are: diffuse knapweed (33 percent), 

orange hawkweed (15 percent), spotted knapweed (14 percent), tansy ragwort (13 percent), 

Himalayan blackberry (12 percent), houndstongue (seven percent), and butter and eggs (two 

percent). 
Final Environmental Impact Statement 

3-4

The most common invasive plants are not necessarily the species of most concern, which have 

significant ecological consequences and often are difficult to eradicate or control (see Section 3.6 

for more details). The species of most concern are: butter and eggs, knotweed species, common 

hawkweed, meadow hawkweed, orange hawkweed, and yellow star thistle. These species are 

starting to spread within the Forest and Scenic Area; however, these species are present only in 

small infestations at the present so they can be treated and eradicated from the Forest and Scenic 

Area if prompt action is taken. Description of species of most concern follows. 

• Butter and eggs (Linaria vulgaris): This perennial species, also commonly known as 

yellow toadflax, typically becomes established in disturbed areas, such as along roads, in 

quarries, in floodplains, and in overgrazed rangelands. This species is a native of Eurasia 

and was introduced as an ornamental. Its bright yellow flowers with orange throat and 

spur is attractive. With its extensive root system, this plant could become very aggressive 

displacing native plants and could be difficult to control. 

This invasive plant is spread along road-sides, presumably by seed mixed with gravel. 

The predominant method of dispersal is by wind; the seeds are adapted for wind dispersal 

with papery circular wings. The other important dispersal mechanism is through 

underground rhizomes which leads to large, dense populations which tend to take over a 

site. Typically, one finds a single plant initially, followed by an increasing number of 

plants nearby rapidly forming a dense population. As the seed heads increase, new 

outlying populations begin to appear down-wind. A mature plant could produce over half 

million seeds. 

A similar species, Dalmatian toadflax (Linaria dalmatica), is similar and equally 

problematic. 

• Knotweed species: Japanese knotweed (Polygonum cuspidatum) is currently reported on 

only five National Forests in the Pacific Northwest Region. The difficulty of control and 

the high potential for spread is of concern. Similar species of concern that have the 

potential to invade the Forest and Scenic Area include giant knotweed (Polygonum

sachalinense) and Himalayan knotweed (Polygonum polystachyum). 

Japanese knotweed is native to eastern Asia and was introduced from Japan as an 

ornamental garden plant in the late 1800s. It is now widely distributed in much of the 

eastern United States, and occurs in coastal areas of Oregon and Washington. Japanese 

knotweed is a riparian species that spreads quickly to form dense tall thickets that shade 

out other species and prevent regeneration of native plants. It reduces species diversity 

and damages wildlife habitat (Seiger, 1991). Japanese knotweed poses a significant threat 

to riparian areas where it could survive severe floods and is able to rapidly colonize 

scoured shores and islands (Alien Plant Working Group, 2004). Once established, 

populations are extremely persistent. 
Site-Specific Invasive Plant Treatments 

3-5

Rhizomes could regenerate from small fragments. Dispersal could occur naturally when 

rhizome fragments are washed downstream and deposited on banks, or more commonly, 

when humans transport soil as fill dirt. Monitoring for the introduction of Japanese 

knotweed and manually removing the entire plant could prevent establishment. Repeated 

cutting may control a few individual plants, but the only known method to control larger 

stands is with repeated application of herbicides (Seiger, 1991). Innovative herbicide 

applications such as stem injection are being used with success and could mitigate effects 

to non-target species (Soll, 2004; USDA Forest Service, 2005a). 

• Common hawkweed (Hieracium vulgatum), Meadow hawkweed (Hieracium 

pratense) and Orange hawkweed (Hieracium aurantiacum): The hawkweeds resemble 

some of our native species, but they come from Eurasia. These invasive species are found 

along road-sides, trails, meadows, and other disturbed sites. The hawkweeds are 

perennial with a fibrous root system, milky juice, and the leaves are largely basal. The 

flowers are variously colored in yellow and red-orange on stems about 12 inches tall. 

They tend to colonize moist meadow sites or are found in areas with higher rainfall.

While these species had been rather local in distribution, they have expanded their range 

dramatically in recent years, infesting some sensitive habitats. One population is known 

in the Mt. Hood Wilderness Area where it has begun to displace native grasses. Early 

detection and control of new infestations is important in keeping these species from 

infesting additional sensitive habitats. At lower elevations, these species have become 

increasingly widespread along highways and other roads where control is becoming more 

difficult. 

The hawkweeds reproduce by seeds, stolons, and rhizomes. Extensive stolons create 

dense mats of hawkweed plants that could eliminate other native flora. It is this tendency 

that makes this plant very difficult to control and of great concern. 

• Yellow starthistle (Centaurea solstitialis): Occurrence of yellow starthistle is reported 

on eight forests in the region, and is rapidly expanding in eastern Oregon. Yellow 

starthistle is a winter annual that could form dense impenetrable stands that displace 

desirable vegetation. This species was introduced into North America as a seed 

contaminant in Chilean-grown alfalfa seed sometime after 1849 (DiTomaso, 2001). In the 

past 40 years it has spread exponentially throughout the west.

Yellow starthistle is best adapted to open grasslands with deep well-drained soils and 

annual precipitation between 10 and 60 inches, but competes successfully in a wide range 

of habitats (DiTomaso, 2001). It favors sites originally dominated by perennial grasses, 

primarily bluebunch wheatgrass (Psuedoroegneria spicata), Idaho fescue (Festuca 

idahoensis), and Sandberg bluegrass (Poa secunda) (Sheley and Petroff, 1999). 

Yellow starthistle displaces native plant communities and reduces plant diversity. It 

forms solid stands that dramatically reduce forage production for livestock and wildlife. 

This species causes a fatal neurological disorder when ingested by horses called 

“chewing disease” (Sheley and Petroff, 1999; USDA Forest Service, 2005a). 
Final Environmental Impact Statement 

3-6

3.2.3. Rate of Spread and Mechanism of Invasion 

Invasive plant populations increase in acreage at an estimated rate of eight to 12 percent per year 

on National Forest System lands in the United States (USDA Forest Service, 1999b), which 

means the invasive plant infestations could continue to spread on the Forest and Scenic Area and 

on adjacent federal, tribal, county, and state lands. Most of the invasive plant infestations (94 

percent of inventoried acreage) are in disturbed areas. The presence of invasive plants is not a 

new phenomenon. The geographic scope, frequency, and the number of species involved, 

however, have grown enormously as a direct consequence of expanding transport and commerce, 

especially in the past 200 years. Invasion occurs when invasive plant species are transported to 

new, often distant places where they proliferate, spread, and persist. For example, some invasive 

plants have been accidentally introduced to this country as contaminants among crop seed, 

ballast in cargo ships, or on other vessels (Mack et al., 2000). The rapid rate of human expansion 

accounts for a majority of the long-distance dispersal of newly invading species (Grime, 2001; 

USDA Forest Service, 2005a). 

Purposeful and accidental introductions have occurred for centuries, but major introductions 

have occurred most rapidly over the past century. Introductions of invasive plants for forage (i.e., 

contaminated livestock feed), ornamental landscaping, road and dune stabilization, and erosion 

control have occurred throughout National Forest System lands and adjacent lands in Oregon and 

Washington. Most invasive plants have been introduced for horticultural use by nurseries, 

botanical gardens, and individuals (Reichard and White, 2001). Commercial landscape nurseries 

in Oregon and Washington sell, or once sold, exotic species for domestic landscaping that later 

were found to be invasive (e.g., English ivy, butterfly bush, pampas grass, purple loosestrife). 

These have spread to federal lands (Whitson, 2001). Invasive plant species have been used in 

seed mixes on National Forest System lands for erosion control, bank stabilization, and burned 

area rehabilitation (USDA Forest Service, 2005a). 

The mechanisms of spread for invasive plants include natural vectors such as birds, insects, or 

wildlife, and natural forces, such as water and wind. Wind and water in particular, are major 

natural dispersal agents. Disturbance-based vectors are also mechanisms of spread for invasive 

plants. Invasion and dominance by invasive plants is highly correlated with soil disturbance, but 

are not limited to disturbed areas (Cox, 1999). Invasive plants readily invade, occupy and 

dominate conifer plantations, road prisms, trails and trailheads, mined sites, gravel pits, river 

corridors, wildlife wallows and bedding areas, and rangelands. Many invasive species could also 

establish in naturally occurring small openings. Natural and human induced small-scale and 

large-scale disturbance create safe sites for invasive plant establishment, and in areas where 

desirable species are not available to occupy these sites, invasive species could dominate (USDA 

Forest Service, 2005a). 
Site-Specific Invasive Plant Treatments 

3-7

Ground-disturbing activities on the Forest and Scenic Area include timber harvesting, 

recreational uses, road building and maintenance, fire suppression activities, grazing, and 

mining. All of these management activities can alter native plant communities and function, and 

provide the opportunity for invasive plants to become established and spread, as described in 

Section 3.1 of the Invasive Plant FEIS (2005a). Many of these activities have contributed to the 

current invasive plant infestations present on the Forest and Scenic Area, and would continue to 

contribute to the spread of invasive plants. Prevention standards, specifically the Invasive Plant 

ROD (2005b) standards (Appendix A) and local prevention standards (Appendix D) are an 

integral component to reduce the spread and establishment of invasive plant species. 

In order to acknowledge the role of management activities, rate of spread was incorporated into 

the treatment areas (see Table 1-1) as well as in the treatment caps (see Section 1.3 – Proposed 

Action).The overall treatment cap is 30,000 acres. This includes the known infested treatment 

areas (13,000 acres), newly inventoried suspected infested areas (13,000 acres), and a one 

percent rate of unexpected infestations per year for the life of the project, which includes 

spreading invasive plants through management activities (4,000 acres). For more details, see 

Section 2.1.3, Subsection Early Detection/Rapid Response strategy. 

3.2.4. Ownership Patterns and Herbicide Use on Other Lands 

Ownership patterns within the boundaries of the Forest and Scenic Area are predominately 

National Forest System lands (90 percent). All fifth-field watersheds containing treatment areas 

have mixed ownership patterns (Appendix P). The Beaver Creek, Lower Clackamas River, 

Middle Deschutes River, Lower Hood River, and Lower Sandy River watersheds have the 

highest percentage of other ownerships within watersheds on the Forest and Scenic Area (See 

Figure 3-1 Map of Ownership Patterns). Two of these watersheds are located on both the Forest 

and Scenic Area – Lower Hood River and Lower Sandy. 

Limited information on invasive plant treatments and herbicide use are known on the other 

ownership lands in all watersheds. As the mixed ownership indicates, invasive plants could 

spread from the Forest and Scenic Area to other ownerships and vice versa very easily, which 

would continue to contribute to the problem of invasive plants. This is the predominant concern 

in the watersheds located on the Scenic Area, where the ownership is the most mixed: these 

include the Lower Sandy River, Columbia River Gorge Tributaries, Middle Columbia/Eagle 

Creek, Middle Columbia/Grays Creek, and Middle Columbia/Mill Creek watersheds. 

Five fifth-field watersheds (Upper Clackamas River, Oak Grove Fork Clackamas River, White 

River, Beaver Creek, and Middle Deschutes River watersheds) contain tribal lands on the Warm 

Springs Reservation. The Confederated Tribes of Warm Springs and Bureau of Indian Affairs 

released a Vegetation Management Noxious Weed Control Plan and Assessment (2005) that 

proposes manual, mechanical, biological, prescribed burning, and herbicide treatments. The plan 

is designed to treat and control invasive plants on the reservation over the next five years. 

Estimated amount of herbicide use and acres of invasive plant treatments on the tribal lands are 

not available. 
Final Environmental Impact Statement 

3-8

Figure 3-1. Ownership Patterns in Vicinity of Mt. Hood National Forest and Columbia 

River Gorge National Scenic Area. 
Site-Specific Invasive Plant Treatments 

3-9

In addition to the tribal lands, the Oregon Department of Agriculture (ODA) and counties have 

active invasive plant programs. In 2005, ODA applied 15 gallons and 49 pounds of active 

ingredient of herbicides proposed for use in Multnomah and Clackamas counties; Multnomah 

County applied 439 gallons; Clackamas County applied 1,010 gallons and 119 pounds of active 

ingredients; and Hood River County applied 182 gallons. In addition to herbicide treatments, 

ODA and the counties use approximately one pint of surfactant per gallon of concentrate 

herbicide (Forney, 2006). Finally, ODA and the counties apply manual, mechanical and cultural 

treatments on their lands. Also, an orchardist estimated the herbicide use in Hood River County 

on private orchards to be 3,000 gallons per year. The estimate is based on the assumption that 

there are two applications of herbicide on orchards per year and that 1 to 1.5 gallons of herbicide 

are applied per acre over 15,000 acres. 

3.3. Herbicides, Adjuvants, Surfactants and Inert Ingredients 

The effects from the use of any herbicide or additive depends on the toxic properties (hazards) of 

that chemical, the level of exposure to that chemical at any given time, and the duration of that 

exposure. The Invasive Plant FEIS (2005a) used the herbicide risk assessments displayed in 

Table 3-2 to evaluate the potential for harm to non-target plants, wildlife, human health, soils and 

aquatic organisms from the herbicides considered for use in this EIS. This section summarizes 

the known information about herbicides and additives; discusses the risk reduction approach 

incorporated in the action alternatives and applied in the analysis of environmental impacts; and 

discloses the uncertainties associated with herbicides and additives. Appendix Q – Herbicide 

Information Summary and PDC Crosswalk summarizes herbicide characteristics, basic hazard 

identification, risk characterization, label restrictions and information, and PDC. 

3.3.1. Herbicide Risk Assessments 

Risk assessments were completed by Syracuse Environmental Research Associates, Inc (SERA) 

using peer-reviewed articles from the open scientific literature and current U.S. Environmental 

Protection Agency (EPA) documents, including Confidential Business Information. Information 

from laboratory and field studies of herbicide toxicity, exposure, and environmental fate was 

used to estimate the risk of adverse effects to non-target organisms. 

The risk assessments considered worst-case scenarios including accidental exposures and 

application at maximum label rates. The risk assessments represent the best science available. 

The Invasive Plant FEIS (2005a) added a margin of safety to the SERA Risk Assessments 

(2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) by making the 

thresholds of concern substantially smaller to account for increased caution to federally listed 

wildlife and fish species. The adjustments varied based on the herbicide and species being 

analyzed. These adjustments followed the Environmental Protection Agency protocol (EPA, 

2004) described in the Invasive Plant FEIS (2005a). 
Final Environmental Impact Statement 

3-10

Table 3-2: Risk Assessments for Herbicides Considered in this EIS, including formulations and manufactassessments are available at: http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/Herbicides-Analyzed-In

Herbicide Name Formulations Manufacturer Date Final Risk Asse

Telar® DF Dupont 

Chlorsulfuron Glean Dupont 

Corsair TM Riverdale 

November 21, 2004 SERA TR 0

Clopyralid Transline Dow AgroSciences December 5, 2004 SERA TR 0

Accord SP Dow AgroSciences Aqua Neat Riverdale Aquamaster Monsanto Cornerstone Labeled for aquatic use Agrilliance Credit Nufarm Credit Systemic Nufarm Debit TMF Nufarm Eagre Aquatic herbicide Griffin Foresters Non-Selective Herbicide Labeled for aquatic use

Riverdale 

Glyfos Cheminova Glyfos Aquatic herbicide Cheminova Glyfos Pro No Surfactant Needed Labeled for aquatic use

Cheminova 

Glyfos X-TRA Cheminova Glyphomax Dow AgroSciences Glyphomax Plus Dow AgroSciences Glyphosate DuPont Glyphosate Original Griffin Glyphosate VMF DuPont Glypro Dow AgroSciences Glypro Plus Dow AgroSciences 

Glyphosate 

Honcho Monsanto 

March 1, 2003 SERA TR 0
Site-Specific 

3-11

Herbicide Name Formulations Manufacturer Date Final Risk Asse

Mirage UAP Prosecutor Lesco Prosecutor Plus Tracker Lesco Rattler Helena Chemical Co. Razor Riverdale Razor SPI Riverdale Rodeo Dow AgroSciences Roundup CUSTOM Labeled for aquatic use Monsanto Roundup ORIGINAL Monsanto Roundup PRO Monsanto Roundup PRO Concentrate Monsanto Roundup ProDry Monsanto Roundup UltraDry Monsanto 

Roundup ULTRA MAX Monsanto 

Plateau 

Registration transferred to: BASF (C&P Press 2003; BASF 2000, 2001) (Developed by: American Cyanamid (1998c, 2000)) Imazapic 

Plateau DG. 

Registration transferred to: BASF (C&P Press 2003; BASF 2000, 2001) (Developed by: American Cyanamid (1998c, 2000)) 

December 23, 2004 SERA TR 0

Arsenal 

Supplied by: BASF (Produced by: American Cyanamid) 

Imazapyr 

Arsenal AC 

Supplied by: BASF (Produced by: American Cyanamid) 

December 18, 2004 SERA TR 0
Final Environmental Impact Statement 

3-12

Herbicide Name Formulations Manufacturer Date Final Risk Asse

Chopper 

Supplied by: BASF (Produced by: American Cyanamid) 

Stalker 

Supplied by: BASF (Produced by: American Cyanamid) 

Habitat BASF 

Metsulfuron methyl Escort XP DuPont December 9, 2004 SERA TR 0

Tordon K Dow AgroSciences June 30, 2003 SERA TR 0

Picloram Tordon 22K Dow AgroSciencesSethoxydim Poast BASF October 31, 2001 SERA TR 0

Oust DuPont December 14, 2004 SERA TR 0

Sulfometuron methyl Oust XP ® DuPont 

Forestry Garlon 4 Specialty Herbicide Dow AgroSciences Garlon 4 Specialty Herbicide Dow AgroSciences Garlon 3A Dow AgroSciences Pathfinder II Specialty HerbicideLabeled for aquatic use 

Dow AgroSciences 

Remedy RTU. Dow AgroSciences 

Triclopyr 

Renovate 3 (a.k.a. Triclopyr TEA) 

SePRO Corporation (Appears to be identical to Garlon 3A) 

March 15, 2003 SERA TR 0

NPE (nonylphenol polyethoxylate) 

R-11® Wilbur-Ellis Company May 2003 (October 2003) USDA Fore

In addition to the analysis of potential hazards to human health from the active ingredients in herbicides, the SER(2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) evaluated available scientific studies oother substances associated with herbicide applications: impurities, metabolites, inert ingredients, and adjuvants. 

toxicity data available for these substances (compared to the active ingredients) because they are not subject to this required for the active ingredients under FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act). 
Site-Specific Invasive Plant Treatments 

3-13

3.3.2. Herbicide Toxicology Terminology 

The following terminology is used throughout this chapter to describe relative toxicity of herbicides 

proposed for use in the alternatives. 

• Aquatic Label: Some herbicides are labeled for direct application in water. While no direct 

application would occur in any alternative for this project, treatment of emergent invasives 

in standing water or dry stream beds may involve use of such formulations to meet label 

requirements. Aquatic labeled herbicides are not necessarily less hazardous to aquatic 

organisms than other herbicides, but have been more extensively tested. Aquatic labeled 

herbicides would not be favored over effective non-aquatic labeled herbicides that pose 

lower risk to aquatic organisms, assuming compliance with label advisories (see Section 

3.10). 

• Bioaccumulation: The increase in concentration of a substance in living organisms as they 

take in contaminated air, water, or food because the substance is very slowly metabolized or 

excreted (often concentrating in the body fat.) 

• Exposure Scenario: The mechanism (e.g., dermal, ingestion) by which an organism (e.g., 

person, animal, fish) may be exposed to herbicides or additives. The application rate and 

method influences the amount of herbicide to which an organism may be exposed. 

• Hazard Quotient (HQ): The HQ is the amount of herbicide or additives to which an 

organism may be exposed divided by the Threshold of Concern. An HQ less than or equal 

to 1 indicates an extremely low level of risk. 

• Lowest-Observed-Adverse-Effect Level (LOAEL): The lowest dose of a chemical in a 

study, or group of studies, that produces statistically or biologically significant increases in 

frequency or severity of adverse effects between the exposed and control populations. 

• No Observable Adverse Effect Level (NOAEL): Exposure level at which there are no 

statistically or biological significant differences in the frequency or severity of any adverse 

effect in the exposed or control populations. 

• No Observed Effect Concentration (NOEC): Synonymous with NOEL. 

• No Observed Effect Level (NOEL): Exposure level at which there are no statistically or 

biological significant differences in the frequency or severity of any effect in the exposed or 

control populations. 

• Reference Dose (RfD): The RfD is a numerical estimate of a daily exposure to the human 

population, including sensitive subgroups such as children, that is not likely to cause 

harmful effects during a lifetime. RfDs are generally used for health effects that are thought 

to have a threshold or minimum dose for producing effects. 
Final Envi

3-14

ronmental Impact Statement 

• Threshold of Concern: A level of exposure below which there is a low potential for 

adverse effects to an organism. This level was made more conservative in the Invasive Plant 

FEIS (2005a) to add a margin of safety to the risk assessment process. 

3.3.3. Risk Reduction Framework 

Figure 3-2 displays the layers of caution that are integrated into herbicide use in the USDA Forest 

Service, Pacific Northwest Region. First, label requirements, federal and state laws, and the EPA 

approval process provide an initial level of caution regarding herbicide use. Next, the SERA Risk 

Assessments (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) disclosed 

hazards associated with worst-case herbicide conditions (maximum exposure allowed by the label). 

The Invasive Plant FEIS (2005a) included an additional margin of safety by reducing the level 

herbicide exposure considered to be of concern to fish and wildlife. These adjustments followed the 

Environmental Protection Agency protocol (EPA, 2004) described in the Invasive Plant FEIS 

(2005a). The Invasive Plant ROD (2005b) adopted standards to minimize or eliminate risks to 

people and the environment. This EIS is designed to comply with the Invasive Plant ROD standards 

(2005b). Finally, the PDC further reduce the risks associated with herbicide treatments by 

eliminating or minimizing as much as possible the impacts to the environment. 

3.3.4. 

Figure 3-2: Risk Reduction Framework. Figure 3.2 Layers of Caution Intergrated into Herbicide Use 

REGION SIX RISK REDUCTION METHODS — 

LAYERS OF CAUTION INTEGRATED INTO HERBICIDE USE 
Site-Specific Invasive Plant Treatments 

3-15

Adjuvants, Surfactants and Inert Ingredients 

Information on adjuvants and surfactants is taken from Analysis of Issues Surrounding the Use of 

Spray Adjuvants with Herbicides (Bakke, 2003a), Human and Ecological Risk Assessment of 

Nonylphenol Polyethoxylate-based (NPE) Surfactants in Forest Service Herbicide Applications 

(Bakke, 2003b), and Invasive Plant FEIS (2005a). Refer to Appendix R for a list of adjuvants, and 

surfactants addressed by Bakke (2003a). 

3.3.5. Definitions of Chemical Types 

• Adjuvants: Adjuvants are spraying solution additives that are mixed with an herbicide 

solution to improve performance of the spray mixture. Adjuvants could either enhance 

activity of an herbicide’s active ingredient (activator adjuvant) or offset any problems 

associated with spray application, such as adverse water quality or wind (special purpose or 

utility modifiers). Activator adjuvants include surfactants, wetting agents, sticker-spreaders, 

and penetrants (Bakke, 2003a). 

Adjuvants are not under the same registration guidelines as pesticides. The EPA does not 

register or approve the labeling of spray adjuvants. All adjuvants are generally field tested 

by the manufacturer with several different herbicides against many invasive plants and 

under different environments (Bakke, 2003a). 

• Surfactants: Surfactants, or “surface-acting agents”, are a broad category of chemicals that 

are added to herbicides in order to facilitate and enhance their absorbing, emulsifying, 

dispersing, spreading, sticking, wetting, or penetrating properties. Surfactants are most often 

used with herbicides to help it spread over and penetrate the waxy cuticle (outer layer) of a 

leaf or to penetrate through the small hairs present on the leaf surface. 

Most surfactants used with herbicides are “non-ionic”, which means they have no electrical 

charge and are compatible with most pesticides. There are cationic (positive charge) and 

anionic (negative charge) surfactants, but they are not as commonly used, with the 

exception of the cationic surfactant in the Roundup formulation of glyphosate. Surfactants 

have the physical characteristics of both oil and water. 

• Inert Ingredients: Identified inert ingredients found in herbicide formulations include 

some relatively innocuous substances, such as distilled water. Effects of inert ingredients 

are included in the risk assessment for specific herbicide formulations (Invasive Plant FEIS, 

2005a). 

3.3.6. Nonylphenol Polyethoxylate (NPE) 

The primary ingredient in many of the non-ionic surfactants used by the USDA Forest Service 

when applying herbicides is a compound known as nonylphenol polyethoxylate (NPE). A separate 

risk assessment (Bakke, 2003b) for NPE surfactants was completed because concerns have been 

expressed about toxicity of the chemical components and breakdown products of NPE surfactants. 
Final Environmental Impact Statement 

3-16

NPE surfactants are appropriate for some applications where the herbicide label requires the 

addition of a surfactant. NPE surfactants may also improve efficacy in other herbicide applications 

where addition of a surfactant is optional. In some, but not all of these situations, there are 

alternative surfactants that would be effective that do not contain NPE (Invasive Plant FEIS, 

2005a). 

The typical application rate of NPE for USDA Forest Service, Pacific Northwest Region is 1.67 

pounds per acre (Invasive Plant FEIS, 2005a). It is estimated that Oregon Department of 

Agriculture as well as Multnomah, Clackamas, Hood River, and Wasco counties use approximately 

one pint of surfactant per gallon of concentrate herbicide (Forney, 2006). 

3.3.7. Analysis of Adjuvants, Surfactants and Inert Ingredients 

The EIS does not estimate the number of acres treated with surfactants, adjuvants or inert 

ingredients for each alternative because only limited information is available on these chemicals. 

Additionally, various herbicides potentially could be used at any treatment area, so the adjuvant, 

surfactants and inert ingredients used may vary. Each resource area evaluated the effects of these 

chemicals using the information available (see following sections). 

Standard #18 from the Invasive Plant ROD (2005b) is designed to avoid, eliminate, or minimize 

potential effects from implementing herbicide-related treatments. Standard 18 states: “Use only 

adjuvants (e.g. surfactants, dyes) and inert ingredients reviewed in Forest Service hazard and risk 

assessment documents such as SERA, 1997a, 1997b; Bakke, 2003b.” Also, PDC F.2. restricts the 

use of NPE near perennial streams, wetlands, lakes, ponds or in road ditches that are hydrologically 

connected to water bodies, and PDC A.9. limits broadcast spraying of NPE surfactant to less than 

0.5 lb a.i./acre. 

Surfactants that meet Standard 18 are addressed in various risk assessments by SERA and others 

(Bakke, 2003b; SERA 1997a, 1997b, 2003b, 2003d) and include NPE-based surfactants, POEA 

(polyethoxylated tallow amine), Agri-Dex, LI-700, R-11, Latron AG-98, AG surfactants in 

Glyphosate, and Polyglycol 26-2 in Picloram. Other adjuvants/surfactants addressed by Bakke 

(2003a) are listed in Appendix R. 

3.3.8. Incomplete and Unavailable Information 

Risk assessments have a high degree of uncertainty in interpretation and extrapolation of data. 

Uncertainty may result from a study design, questions asked (and questions avoided), data 

collection, data interpretation, and extreme variability associated with aggregate effects of natural 

and synthesized chemicals on organisms, including humans, and with ecological relationships. Due 

to data gaps, assessments rely heavily on extrapolation from laboratory animal tests (2005a). 

Regardless of disadvantages and limitations of ecological and human health risk assessments, risk 

assessments can determine (given a particular set of assumptions) whether there is a basis for 

asserting that a particular adverse effect is possible. The bottom line for all risk analyses is that 

absolute safety can never be proven and the absence of risk can never be guaranteed (SERA, 2001). 
Site-Specific Invasive Plant Treatments 

3-17

Further, a risk assessment has only been completed on one surfactant type (NPE) (Bakke, 2003b). 

Limited information on other surfactants, adjuvants, and inert ingredients is available in Bakke 

(2003a) and various risk assessments. Since risk assessments have not been completed for the 

surfactants, adjuvants and inert ingredients, information regarding the toxicity and effects of these 

chemicals is largely unavailable. 

For risk assessments considering adjuvants, surfactants and inert ingredients in herbicide mixtures, 

the information within the risk assessment may not be complete. SERA (2001b) discusses how the 

risk assessments apply generally accepted scientific and regulatory methodologies to encompass 

these uncertainties in predictions of risk. SERA risk assessments identify and evaluate incomplete 

and unavailable information that is potentially relevant to human health and ecological risks. Each 

risk assessment identifies and evaluates missing information for that particular herbicide and its 

relevance to risk estimate. Such missing information may involve any of the three elements needed 

for risk assessments: hazard, exposure, or dose-response relationships. A peer-review panel of 

subject matter experts reviewed the assumptions, methodologies and analysis of significance of any 

such missing information. SERA addresses and incorporates the findings of this peer review in its 

final herbicide risk assessment. 

3.4. Basis of Cumulative Effects Analysis 

Cumulative effects result from the incremental impacts of any alternative when added to other past, 

present and reasonably foreseeable actions, both on the Forest and Scenic Area and other adjacent 

federal, state or private lands (40 CFR 1508.7). The cumulative effects considered in this EIS are 

related to the risks to the environment and human health associated with herbicides or other 

invasive plant treatments. Table 3-3 defines the baseline, spatial scale, temportal scale, applicable 

PDC, and desired condition that serve as the basis for cumulative effects analysis for each resource 

area. 

Additionally, where appropriate, the potential for synergistic effects (where exposure to a 

combination of two or more chemicals could result in impacts that are greater than the sum of the 

effects of each chemical alone) were considered. Combinations of herbicides in low doses (less 

than one-tenth of the reference dose (RfD) have rarely demonstrated synergistic effects. Review of 

the scientific literature on toxicological effects and toxicological interactions of agricultural 

herbicides indicate that exposure to a mixture of pesticides is more likely to lead to additive rather 

than synergistic effects (ATSDR, 2004). Based on the limited data available on herbicide 

combinations involving the 10 herbicides considered in this EIS, it is possible, but unlikely, that 

synergistic effects could occur as a result of exposure to the herbicides considered in this analysis. 

Synergistic or additive effects, if any, are expected to be insignificant. More information on this 

topic is included in Section 3.5 – Human Health and Safety. 
Final Environmental Impact Statement 

3-18

Table 3-3: Cumulative Effects Information. Includes baseline conditions, spatial scale and temporal scale, for hand treatment effectiveness; economic efficiency; soil productivity; water quality; aquatic organisms and habitat; a

areas.

Resource Area 

Baseline (Existing Condition) Spatial Scale Temporal Scale 

Applicable Project Design Criteria 

Summary of Effects 

Human Health Section 3.5 

No known threats to human health from current and past invasive plant treatments, including herbicide use. 

Direct and indirect effects are limited to the immediate area (within 100-feet) from application site. 

People may be exposed to herbicides in a chronic manner (e.g., applicators) or through multiple exposure mechanisms, such as breath, skin, and ingestion of contaminated meat, mushrooms or fruit. 

D.1 – Personal Protective Equipment D.2 thru D.6 – Notification D.7 – Drinking water Intake 

No acute or chronexposures of concern. PDC increase the margof safety to reducpotential exposur

Botany Section 3.6 

No known threats from current or past invasive plant treatments, including herbicide use, to special status botanical species. Invasive plants threaten native plant communities and special status species. 

Direct and indirect effects to native plant communities are analyzed at regional scale, which includes Oregon and Washington States. Direct and indirect effects to special status species are analyzed at the treatment area scale. 

The life of the project is 5 to 15 years; the analysis assumes 15 years. 

E.1 thru E.4 – Botanical Buffers E.5. – Preventing Reinfestation E.6. – Sample Sites 

PDC, including thbotanical buffers, reduce the risk to non-target vegetation. Bufferwould be increase or other changes made if non-targeeffects are noted beyond the expected area. 
Site-Specific 

3-19

Resource Area 

Baseline (Existing Condition) Spatial Scale Temporal Scale 

Applicable Project Design Criteria 

Summary of Effects 

Economic Efficiency Section 3.7 

Some cost-effective treatment options (primarily herbicide treatments) are not available under the No Action Alternative. Invasive plants have an enormous economic impact on Oregon’s economy and natural resources. 

Direct and indirect effects are analyzed at regional scale, which includes Oregon and Washington States. 

The life of the project is 5 to 15 years; the analysis assumes 15 years. 

No specific PDC. The treatment co

per acre varies fro$194 for the No Action Alternative $541 for the Restricted Herbicide Use Alternative. The Proposed Action would cost $324 pacre. 

Soil Productivity Section 3.8 

The soils in the proposed treatment areas are of relatively low fertility and once disturbed tend to be invaded by invasive plant species. No evidence that invasive plant treatments have resulted in loss of soil productivity. Invasive plant threaten to change soil characteristics over time, including erosion hazard and soil organisms. 

Direct and indirect effects are analyzed at the treatment area scale within the Forest and Scenic Area. 

The life of the project is 5 to 15 years; the analysis assumes 15 years. 

G.1 thru G.4 – Herbicide Application G.5 – Equipment G.6 – Erosion Control Devices I.1 and I.2 – Site Restoration 

PDC minimize or eliminate risk to sproductivity. The project would not contribute to significant cumulative effects at any scale. 
Final Environmental Impact Statement 

3-20

Resource Area 

Baseline (Existing Condition) Spatial Scale Temporal Scale 

Applicable Project Design Criteria 

Summary of Effects 

Water Quality Section 3.9 

No evidence that pat or existing invasive plant treatment, including herbicide use, has resulted in a loss of water quality. Invasive plants may result in loss of functional riparian communities, loss of rooting strength and protection against erosion, decreasing slope stability and increasing sediment introduction into streams, and impacts on water quality. 

Direct and indirect effects are analyzed at 5th field 

watershed scale. Additional considerations are discussed within the aquatic influence zone and riparian reserves. An aquatic influence zone is land adjacent to perennial and intermittent streams, rivers, ponds, lakes, springs, and wetlands that have a direct or potentially direct influence on the water body and its function where herbicides may enter surface waters; this zone has a default width of 100 feet. 

The life of the project is 5 to 15 years; the analysis assumes 15 years. 

B.6, B.7 and B.9 – Treatments near Water B.8 – Water Travel F.1 – Buffers F.2 – Surfactants F.3 – Wetlands F.4 – In-Water Guidelines 

PDC, including aquatic buffers, minimize or eliminate risk to water quality, including drinking water and beneficuses, at any scale
Site-Specific 

3-21

Resource Area 

Baseline (Existing Condition) Spatial Scale Temporal Scale 

Applicable Project Design Criteria 

Summary of Effects 

Aquatic Organisms and Habitat Section 3.10 

There are over 1,600 miles of fish-bearing streams on the Forest, with approximately 300 miles supporting anadromous populations of salmon and steelhead. In the Scenic Area, there are 60 miles of fish bearing stream, with 17 miles supporting anadromous species. All these miles of streams have riparian habitat that might be impacted by invasive plants. No evidence that past invasive plant treatments, including herbicides, have harmed aquatic ecosystem. 

Direct and indirect effects are analyzed at 5th field 

watershed scale. Additional considerations are discussed within the aquatic influence zone and riparian reserves. An aquatic influence zone is land adjacent to perennial and intermittent streams, rivers, ponds, lakes, springs, and wetlands that have a direct or potentially direct influence on the water body and its function where herbicides may enter surface waters; this zone has a default width of 100 feet. 

The life of the project is 5 to 15 years; the analysis assumes 15 years. 

F.1 – Buffers F.2 – Surfactants F.4 – In-Water Guidelines 

Persistent herbicides posing risks to aquatic organisms would not be used in the aquatic influence zone. PDC, including the aquatic buffers, minimize or eliminate risk to aquatic organismand habitat at any scale. 
Final Environmental Impact Statement 

3-22

Resource Area 

Baseline (Existing Condition) Spatial Scale Temporal Scale 

Applicable Project Design Criteria 

Summary of Effects 

Wildlife Section 3.11 

Wildlife specials status species, including Pacific Northwest Regional Forester’s sensitive species, survey and manage species, Forest Plan management indicator species, and landbirds listed as Partners in Flight focal species, occur within or travel through the proposed treatment areas. Northern Spotted Owl and Northern Bald Eagle are threatened wildlife species. No evidence that past invasive plant treatments, including herbicides, have harmed wildlife species. 

Direct and indirect effects are analyzed at the Forest and Scenic Area scale. 

The life of the project is 5 to 15 years; the analysis assumes 15 years. 

H.1 – Bald Eagle H.2 – Salamanders and mollusks H.3 – Larch Mountain Salamanders 

PDC minimize or eliminate risk to wildlife species at all scales. 
Site-Specific Invasive Plant Treatments 

3-23

The risk of adverse effects of invasive plant treatments in all action alternatives has been 

minimized or eliminated by the PDC described in Section 2.2. This limits, but does not exclude, 

the likelihood of cumulative adverse effects from treatment. The proposed use of herbicides on 

and off the Forest and Scenic Area could result in additive doses of herbicides to workers, the 

general public, non-target plant species, aquatic species, and/or wildlife species. For additive 

doses to occur, the two exposures would have to occur closely together in time, since the 

herbicides proposed for use are rapidly eliminated from humans and do not significantly 

bioaccumulate (Invasive Plant FEIS, 2005a). The application rates and extent considered in this 

EIS are unlikely to result in additive doses beyond those evaluated for chronic and acute 

exposures in the USDA Forest Service risk assessments, which formed the basis for the effects 

analysis in the Invasive Plant FEIS (2005a). The Invasive Plant FEIS (2005a), in return, served 

as the basis for the site-specific effects analysis discussed in this EIS. 

Herbicides are commonly applied on lands other than the Forest and Scenic Area for a variety of 

agricultural, landscaping and invasive plant management purposes. Herbicide use occurs on 

tribal lands, state and county lands, private forestry lands, rangelands, utility corridors, road 

rights-of-way, and private property. No central source exists for compiling invasive plant 

management information off National Forests System lands within Oregon. There is no 

requirement for private or corporate land owners, or counties to report invasive plant treatment 

information, thus an accurate accounting of the total acreage of invasive plant treatment for all 

land ownerships is unavailable. 

Only the land and roads within the National Forest System would be treated in the action 

alternatives. The Forest and especially Scenic Area, however, are intermingled with other 

federal, state, county, and private ownerships as discussed in Section 3.2.4 and Appendix M. 

Management activities and actions on neighboring lands may contribute to spread or containment 

of invasive plants on the Forest and Scenic Area and vice versa. The effectiveness of the 

proposed invasive plant treatments would be increased if adjacent landowners were also treating 

invasive plant infestations. Many adjacent land owners are taking action to decrease the spread 

of invasive plants (see Section 3.2.4 – Ownership Patterns and Herbicide Use on Other Lands). 

The cumulative effects analysis assumes that adjacent lands are effectively treated in cooperation 

with this project, which would decrease the spread of invasive plants on adjacent lands. In 

addition, the cumulative effects analysis assumes the release of biological control agents on the 

Forest and Scenic Area and adjacent lands by the Oregon Department of Agriculture, as analyzed 

by APHIS, would continue to reduce the invasive plant infestations in Oregon and decrease the 

spread of invasive plants. 
Final Environmental Impact Statement 

3-24

Although it is difficult to estimate, the Invasive Plant FEIS (2005a) estimated that invasive plant 

control occurs on over 1.25 million acres in Oregon and Washington and greater than 90 percent 

of this control is through the use of herbicides. Even the highest use estimates of herbicide use on 

the National Forest System lands would amount to less than three percent of the estimated total 

acres treated with herbicides in Oregon and Washington (page 4-1, Invasive Plant FEIS, 2005a). 

Although limited information is available, complete information is not available to estimates for 

the area adjacent to the Forest and Scenic Area. This information is considered in the cumulative 

effects analysis for each resource area in conjunction with the herbicide use information 

presented in Section 3.2.4 – Ownership Patters and Herbicide Use on Other Lands. 

Further, the cumulative effects analysis assumes that the Invasive Plant ROD (2005b) prevention 

standards (Appendix A) and the Forest and Scenic Area prevention standards (Appendix D) are 

properly implemented and effective. The prevention standards will be monitored as required by 

the Invasive Plant ROD (2005b). This analysis assumes that the monitoring would effectively 

identify where the prevention standards are not working, and the prevention standards would be 

adapted as needed. 

Finally, the analysis assumes other planning projects, as required by Invasive Plant ROD (2005b) 

Standard 1, are considering the impacts on the establishment and spread of invasive plants. 

Specifically, Standard 1 requires all watershed analysis, roads analysis, fire and fuels 

management plans, Burned Area Emergency Recovery Plans, emergency wildland fire situation 

analysis, wildland fire implementation plans, grazing allotment management plans, recreation 

management plans, vegetation management plans, and other land management assessments to 

consider invasive plant prevention. 

3.5. Human Health and Safety 

3.5.1. Introduction 

This section focuses on the health effects to workers and the public if herbicides are used as 

proposed in the alternatives. The Invasive Plant FEIS (2005a) and its Appendix Q: Human 

Health Risk Assessment detailed the potential for health effects from the use of the herbicides 

proposed for this project. Herbicide active ingredients, metabolites, inert ingredients, and 

adjuvants and people with particular herbicide sensitivity were addressed. The Invasive Plant 

ROD (2005b) adopted standards to minimize herbicide exposures of concern to workers and the 

public based on the human health risk assessments. Herbicides are an important component of 

the integrated weed management methods needed to meet the purpose and need for this project. 

Site-specific PDC were developed to further minimize or eliminate exposures of concern to 

workers and the public plausible given the regional standards. The PDC ensure that herbicides 

and surfactants are used in rates low enough, or methods selective enough, to avoid exposures of 

concern. 
Site-Specific Invasive Plant Treatments 

3-25

The Invasive Plant FEIS (2005a) evaluated human health risks from herbicide and non-herbicide 

invasive plant treatment methods. Hazards normally encountered while working in the woods 

(strains, sprains, falls, etc) are possible during herbicide and non-herbicide invasive plant 

treatment operations. Such hazards are mitigated through worker compliance with occupational 

health and safety standards and, as such, are not analyzed again here. 

Many people express concern about the effects of herbicides on human heath. Workers and the 

public may be exposed to herbicides used to treat invasive plants under all alternatives in this 

project; however, no exposures exceeding a threshold of concern are predicted. This conclusion 

is based on facts about chemistry of the herbicides considered for use and the mechanisms by 

which exposures of concern might occur. Scientific risk assessments do not indicate that any 

person would be adversely affected in any way by these herbicides used in the manner proposed 

for this project. This applies to all alternatives. More information on municipal watershed is 

available in Section 3.9 – Water Quality and more information on special forest products is 

available in Section 3.14 – Tribal Relations, Civil Rights and Environmental Justice. 

3.5.2. Existing Conditions 

Many people live near, spend time, work in, drink water from, or depend on forest products from 

the Forest and Scenic Area. Municipal watersheds, dispersed and developed recreation areas 

(trailheads, campgrounds, picnic areas, recreation sites, boat ramps, ski areas, work centers, etc) 

and special forest product collection areas currently occur in the vicinity of invasive plant sites. 

3.5.3. Methodology 

The following section tiers to the Invasive Plant FEIS (2005a), which relied on professional risk 

assessments completed by Syracuse Environmental Research Associates, Inc (SERA 2001b, 

2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f). SERA based the assessments 

on peer-reviewed articles from the open scientific literature and current EPA documents, 

including Confidential Business Information. The risk assessments were done according to 

protocols that are accepted by the scientific community (NRC, 1983; EPA, 1987). 

The basis for risk assessments consists of the following parts: 

• Hazard Characterization: What are the dangers inherent with the chemical? 

• Exposure Assessment: Who gets what and how much? 

• Dose Response Assessment: How much is too much? 

• Risk Characterization: Indicates whether or not there is a plausible basis for concern. 

The integration of the exposure rate and dose response assessments characterize the risk for a 

particular herbicide. For example, the inherent hazard of the chemical (known to cause liver 

damage) may be discounted if the exposure and dose are below a no observable adverse effect 

level (NOAEL) and no liver damage results. 
Final Environmental Impact Statement 

3-26

Herbicide formulations may contain additional compounds besides the herbicide active 

ingredient; these are termed impurities or inert ingredients. Other additives, called adjuvants and 

surfactants, may be mixed with the diluted formulation before spraying to either enhance the 

herbicide activity or to modify undesirable properties of the spray mixture. Additionally, when 

organisms in the environment internalize chemical herbicide formulation in their physiologic 

systems, they may transform them into other compounds called metabolites. Of these categories 

of substances, only the NPE group of surfactants has been tested and data produced that identify 

specific and quantifiable hazards to human health (Bakke, 2004). See Section 3.3 – Herbicides, 

Adjuvants, Surfactants and Inert Ingredients for more information on these chemicals. 

The following terminology is used throughout this section and proceeding sections to describe 

relative toxicity of herbicides proposed for use in the alternatives. 

• Exposure Scenario: The mechanism by which a person may be exposed to herbicides 

active ingredients or additives. The application rate and method influences the amount of 

herbicide to which an organism may be exposed. 

• Threshold of Concern: A level of exposure below which there is a low potential for 

adverse effects to an organism. This level was made more conservative in the Invasive 

Plant FEIS (2005a) to add a margin of safety to the risk assessment process. 

• Hazard Quotient (HQ): The Hazard Quotient (HQ) is the amount of herbicide or 

additives to which an organism may be exposed divided by the exposure threshold of 

concern. An HQ less than or equal to 1 is indicates an extremely low level of risk. A HQ 

below 1 indicates a level below a threshold of concern. Invasive plant treatments pose 

potential risks to human health. This section focuses on plausible effects to people from 

herbicide exposure through direct contact, drinking contaminated water, and/or eating 

contaminated food (fish, berries, and mushrooms). 

3.5.4. Direct and Indirect Effects 

3.5.4.1. Worker Herbicide Exposure Analysis 

Herbicide applicators are more likely than the general public to be exposed to herbicides. Worker 

exposure is influenced by the application rate selected for the herbicide; the number of hours 

worked per day; the acres treated per hour; and variability in human dermal absorption rates. 

Appendix Q: Human Health Risk Assessment in the Invasive Plant FEIS (2005a) displayed HQ 

values for typical and maximum label rates under a range of conditions. Four potential exposure 

levels were evaluated for workers, ranging from predicted average exposure (typical application 

rate-typical exposure variables) to a worst-case predicted exposure (maximum application ratemaximum exposure variables). 

In routine broadcast and spot applications, workers may contact and internalize herbicides 

mainly through exposed skin, but also through the mouth, nose or lungs. Contact with herbicide 

formulations may irritate eyes or skin. 
Site-Specific Invasive Plant Treatments 

3-27

The ten herbicides proposed for use under Alternatives 2 and 3, used at rates and methods 

consistent with PDC, have little potential to harm a human being. Appendix Q of the Invasive 

Plant FEIS (2005a) lists the HQ values for all herbicides considered for this project. In most 

cases, even when maximum rates and exposures are considered, HQ values were below the 

threshold of concern (HQ values ranged from 0.01 to 1). 

Risk assessments indicate concern for worker exposure to triclopyr, especially the Garlon 4 

formulation. This is one reason why broadcast application of triclopyr is not allowed under 

Invasive Plant ROD (2005b) Standard 16. Despite this limitation, a potential worst-case scenario 

exists exceeding a level of concern for workers given a backpack (spot) application of the Garlon 

4 formulation of triclopyr. PDC eliminate this scenario by favoring use of Garlon 3A, 

minimizing application rates of all triclopyr formulations, and following safe work practices and 

label advisories. 

For all other herbicides and surfactants, the amount of plausible worker exposure is below levels 

of concern for all application methods, including broadcast. PDC for all action alternatives 

reduce both the application rate and the quantity of drift if triclopyr and/or NPE are used. 

Broadcast of triclopyr is not permitted in any situation (as per the Invasive Plant ROD (2006b), 

and non-NPE surfactants would always be favored where effective. 

Chronic (daily over a period of time) worker exposure also was considered in SERA Risk 

Assessments (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f). Chronic 

exposures do not amount to levels of concern because the herbicide ingredients are water-soluble 

and are not retained in the body (they are rapidly eliminated). 

3.5.4.2. Public Herbicide Exposure Analysis – Direct Contact, Special Forest Products, 

Drinking Water, and Endocrine Disruption 

The general public would not be exposed to substantial levels of any herbicides used in the 

implementation of this project. Appendix Q of the Invasive Plant FEIS (2005a) considered 

plausible direct, acute and chronic exposures from herbicide ingredients. Few plausible scenarios 

exist that exceed even the most conservative threshold of concern for public health and safety. 

Appendix Q shows Risk Assessment results assuming a human being contacts sprayed 

vegetation or herbicide or consumes sprayed vegetation, contaminated water, and/or fish. 

Direct Contact 

There is virtually no chance of a person being directly sprayed given broadcast, spot and 

hand/select methods considered for this project. A person could brush up against sprayed 

vegetation soon after herbicide is applied. Such contact is unlikely because public exposure 

would be discouraged during and after herbicide application. For all herbicides, except triclopyr, 

even if a person were directly sprayed with herbicide applied at typical broadcast rates, chemical 

exposure would not exceed a level of concern. 
Final Environmental Impact Statement 

3-28

Exposures exceeding a conservative level of concern could occur if a person accidentally 

contacts vegetation spot-sprayed with triclopyr (especially Garlon 4). Such contact, however, is 

implausible because no broadcast spraying with triclopyr would occur under any alternative, as 

per Standard 16 in the Invasive Plant ROD (2005b). 

The use of Garlon 4 is further limited by the PDC (for instance, no use of Garlon 4 would be 

allowed within 150 feet of any water body or stream channel; Garlon 4 would be avoided in 

special forest product gathering areas, campgrounds, or administrative sites). Gathering areas, 

campgrounds and administrative sites may be closed immediately after triclopyr application to 

eliminate accidental exposures. 

Eating Contaminated Special Forest Products 

The public may be exposed to herbicide if they eat contaminated fish, berries or mushrooms, etc. 

Members of the public could eat invasive blackberries that have been sprayed; however, the 

target vegetation would quickly be browned and unappetizing. Non-target, native berries or 

mushrooms may be affected by drift or runoff. Several exposure scenarios for recreational and 

subsistence fish consumption were considered in the SERA Risk Assessments; none are near any 

herbicide exposure level of concern. Fish contamination is unlikely given the PDC that reduce 

potential herbicide delivery to water. 

The Invasive Plant FEIS (2005a) considered exposure scenarios for both short term and chronic 

consumption of contaminated berries. The herbicide dose from eating a quantity of mushrooms 

would be greater than for the same quantity of berries (Durkin and Durkin, 2005). The dose, 

however, would be less than the dose from a dermal contact with sprayed vegetation scenario 

and thus, below the threshold of concern (HQ <1). 

Appendix Q (USDA Forest Service, 2005a) displayed the exposure scenarios and HQ values 

associated with eating berries or other herbicide contact. Of the ten herbicides considered in this 

project, triclopyr remains the single herbicide with exposure scenarios exceeding a level of 

concern if berries or mushrooms containing herbicide residue are consumed. The PDC limit the 

application methods and rate of application for triclopyr, especially Garlon 4, addresses this 

concern. In addition, under worst-case scenarios and maximum label rates, exposure to NPE 

surfactant also may exceed a level of concern. Thus PDC limit the rate of NPE that may be 

applied. Special forest product gathering areas may be closed to public use immediately after 

triclopyr application to avoid inadvertent exposure. 

People who both harvest and consume special forest products may be exposed both through 

handling contaminated plant material and chewing or eating it. Chewing and eating contaminated 

plant material cause different exposure and dose patterns. Such doses would be additive, but are 

unlikely to exceed a threshold of concern (see cumulative effects discussion below). 
Site-Specific Invasive Plant Treatments 

3-29

Drinking Contaminated Water 

Acute exposures and longer-term or chronic exposures from direct contact or consumption of 

water, fruit or fish following herbicide application were evaluated in the Invasive Plant FEIS 

(2005a). Risks from two hypothetical drinking water sources were evaluated: 1) a stream, into 

which herbicide residues have contaminated by runoff or leaching from an adjacent herbicide 

application; and 2) a pond, into which the contents of a 200-gallon tanker truck that contains 

herbicide solution is spilled. 

The only herbicide scenarios of concern would involve a person drinking from a pond 

contaminated by a spill of a large tank of herbicide solution. The risk of a major accidental spill 

is not linked in a cause-and-effect relationship to how much treatment of invasive plants is 

projected for a particular herbicide; a spill is a random event. A spill could happen whenever a 

tank truck involved in an herbicide operation passes a body of water. The potential risk of human 

health effects from large herbicide spills into drinking water are mitigated by PDC that require 

an Herbicide Transportation and Handling Plan be developed as part of all project safety 

planning, with detailed spill prevention and remediation measures to be adopted. 

Endocrine Disruption 

In 2007, the Environmental Protection Agency released a draft list of 73 pesticides, based on the 

high potential for human exposure that will be tested for potential to cause endocrine disruption. 

Glyphosate is the only herbicide considered for use on the Forest and Scenic Area that is 

included in the EPA testing. Endocrine disruption and glyphosate was studied by SERA in 2002 

(SERA 2002), and considered in the Invasive Plant FEIS (2005a) and Appendix Q of that 

document. 

SERA reported: “Three specific tests on the potential effects of glyphosate on the endocrine 

system have been conducted and all of these tests reported no effects. The conclusion that 

glyphosate is not an endocrine disruptor is reinforced by epidemiological studies that have 

examined relationships between occupational farm exposures to glyphosate formulations and risk 

of spontaneous miscarriage, fecundity, sperm quality, and serum reproductive hormone 

concentrations... the approach taken in the SERA risk assessment used by the Forest Service is 

highly conservative and no recent information has been encountered suggesting that this risk 

assessment is not adequately protective of any reproductive effects that might be associated with 

glyphosate exposure.” 
Final Environmental Impact Statement 

3-30

3.5.5. Comparison of Risks of Human Health Effects among Alternatives 

Considered In Detail 

The expected array of potential treatment methods for every site is displayed in Appendices G – 

Site and Treatment Information and H – Proposed Herbicide Use at Sites in the Proposed Action. 

Alternative 1 – No Action Alternative 

The No Action Alternative (Alternative 1) continues current invasive plant management 

programs occurring under existing NEPA. The amount and proportion of invasive plant 

treatments by manual, mechanical, cultural, and herbicide treatment methods would remain 

approximately constant to recent historic practices. All herbicide applications for invasive plant 

treatments considered in No Action were previously analyzed and found to pose no significant 

potential risks to health for workers or the public as proposed, including relevant PDC identified 

in the associated Environmental Assessments and Environmental Impact Statement. 

Alternative 2 – Proposed Action 

No individual worker or public exposures of concern are predicted in Alternative 2. PDC, 

including limitations on herbicide use in Aquatic Influence Zones and limitations on application 

rate of some herbicide ingredients, eliminate plausible exposures of concern. No adverse effects 

to public drinking water supplies or health and safety are predicted. Table 3-4 below summarizes 

how PDC minimize exposures of concern. 

Since the EDRR would apply PDC as appropriate, the effects would be similar to those discussed 

here for Alternative 2. 
Site-Specific Invasive Plant Treatments 

3-31

Alternative 3 – Restricted Herbicide Use 

No individual worker or public exposures of concern are predicted in Alternative 3. As in 

Alternative 2, PDC eliminate any plausible herbicide exposures of concern. No adverse effects to 

public drinking water supplies or health and safety are predicted. Since the EDRR would apply 

PDC as appropriate, the effects would be similar to those discussed here for Alternative 3. 

Table 3-4: Project Design Criteria to Minimize Exposures of Concern. 

Project Design Criteria to Minimize Exposures of Concern 

Workers Typical application rates of herbicides (PDC A.8. and A.9); limitations on 

broadcast of triclopyr as per Invasive Plant ROD Standard 16 (2005b). Wearing 

personal protective equipment (PDC D.1.). 

Public Typical application rates of herbicides (PDC A.8. and A.9); limitations on 

broadcast of triclopyr as per Invasive Plant ROD Standard 16 (2005b). These 

limitations reduce risks to the general public, even considering multiple 

exposures. 

Special Forest 

Projects 

Typical application rates of herbicides (PDC A.8. and A.9); posting areas (PDC 

D.2.), supplying information to public (PDC D.3.); Using flagging to mark treated 

areas (PDC D.6). Detectable impacts are implausible except in the event of an 

unpredictable exposure. Even multiple exposures (eating contaminated fish, 

drinking contaminated water, skin irritation) would not result in exposure levels of 

concern. 

Drinking Water Typical application rates of herbicides (PDC A.8. and A.9); Transportation and 

Handling Safety Plan and Spill Plan (PDC B.3.). Detectable impacts are 

implausible except in the event of a spill. 

3.5.6. Cumulative Effects 

While workers, and the public, may be exposed to herbicides within and outside the Forest and 

Scenic Area, multiple exposures do not necessarily equate to cumulative adverse effects. The 

herbicides proposed for use are water-soluble, are rapidly eliminated from humans and do not 

concentrate in fatty tissues and do not significantly bioaccumulate (2005a). Further, the PDC 

limit the mechanisms by which workers and the public may be exposed to herbicides. The PDC 

were developed considering the risks and properties of the herbicides proposed for use. The PDC 

ensure that chronic (long-term) and acute (short-term) herbicide exposures would not exceed 

thresholds of concern and sufficiently minimize risks to compensate for uncertainty about the 

impacts of herbicide use on neighboring lands. 
Final Environmental Impact Statement 

3-32

 

Cumulative effects were analyzed in the Invasive Plant FEIS (2005a) and are briefly summarized 

below. 

A person could be exposed to herbicide repeatedly over the course of their lifetime and exposure 

may occur any place that herbicides are used. Appendix Q (USDA Forest Service, 2005a) 

evaluated chronic exposure scenarios, including repeated drinking of contaminated water, 

repeated consumption of contaminated berries, and repeated consumption of contaminated fish 

over a 90 day period. The HQ values for chronic exposures of all herbicides considered for this 

project are below 1. 

A person could be exposed to herbicides by more than one scenario, for instance, a person 

handling, and then consuming sprayed berries. The cumulative impact of such cases may be 

quantitatively characterized by adding the HQ values for each individual exposure scenario. An 

example of this scenario was considered for this cumulative effects analysis: the scenario 

assumes glyphosate contacts a person’s bare skin (HQ for dermal exposure is less than 0.01)1

, 

and that person immediately eats contaminated berries and fish (HQ values for oral exposure are 

less than 0.01). Even if these three exposures occurred simultaneously, the combined HQ values 

are still far below a threshold of concern (HQ < 1). 

Some of the herbicides considered for use in this project have HQ values greater than 

glyphosate; however, the combined HQ values for dermal and oral exposure are still likely to be 

very low. The body would metabolize some of the initial dose before receiving the second dose, 

thus reducing the cumulative dose. The risk of adverse effects to human health is low because 

the herbicides proposed for this project are water-soluble, are quickly eliminated from the body, 

and do not bioaccumulate. All alternatives comply with standards, policies and laws aimed at 

protecting worker safety and public health. 

3.5.7. Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action 

and Restricted Herbicide Use Alternatives are consistent with all relevant standards and 

guidelines, when the proposed amendments are incorporated. The Forest Plan amendments are 

discussed in Section 3.16. 

1

 See Appendix Q of the Invasive Plant FEIS (2005a) for details about each scenario. 
Site-Specific Invasive Plant Treatments 

3-33

3.5.8. Incomplete or Unavailable Information 

SERA Risk Assessments (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 

2004f) identify and evaluate incomplete and unavailable information that is potentially relevant 

to human health effects resulting from herbicide use in the alternatives. Information is 

necessarily incomplete on potential toxic doses of most herbicides in human, and on the variation 

in dose-response among individuals in the human population. Preparation of Environmental 

Documentation of Risk Assessments (SERA, 2001a) discusses the generally accepted scientific 

and regulatory methodologies to encompass these uncertainties in predictions of risk. 

3.6. Botany and Treatment Effectiveness 

3.6.1. Existing Conditions 

An invasive plant can be defined as “a species that demonstrates rapid growth and spread, 

invades habitats, and displaces other species. Species that are prolific seed producers, have high 

seed germination rates, [are] easily propagated asexually by root or stem fragments, and/or 

rapidly mature predispose a plant to being an invasive...Alien species that are predisposed to 

invasiveness have the added advantage of being relatively free from predators (herbivores, 

parasites, and disease) and can, therefore, expend more energy for growth and reproduction” 

(NCRS, 1999). “Invasive weeds are plants that have been introduced into an environment outside 

of their native range. In their new environment, they have few or no natural enemies to limit their 

reproduction and spread (Anonymous, 2002). Invasive weeds affect us all—farmers, 

homeowners, taxpayers, consumers, and tourists” (OSU Extension Service, 2003). Usually, 

invasive plants are non-native (exotic) species although in some instances even native species 

may become invasive or expansive due to changes (e.g., fire suppression, nutrient 

enrichment/pollution) introduced in their environment. From a broad ecological standpoint, 

invasive plants alter native plant communities and ecosystems, cause a loss in biological 

diversity of plants and animals (loss of habitat and food), lead to ecosystem-level changes that 

affect soil and water, and at the landscape scale can even displace entire native communities with 

monocultures (e.g., yellow star thistle, gorse, cheatgrass, medusahead rye). 

Invasive plants affect a variety of native plant communities that occur within the Forest and 

Scenic Area. Native plant communities on the west side of the crest of the Cascade Range, for 

the most part, consist of dense, moist forests of western hemlock (Tsuga heterophylla), Douglasfir (Pseudotsuga menziesii), Pacific silver fir (Abies amabilis), western red cedar (Thuja plicata), 

and mountain hemlock (Tsuga mertensiana). On a broad scale, the diversity of forested plant 

communities in the western and eastern Cascade Range can be grouped into a handful of major 

vegetation zones that are determined largely by environmental gradients in temperature and 

moisture (i.e., climate) resulting from elevation change and maritime influence. Each vegetation 

zone is named after the dominant reproducing tree species for that zone. On the westside, for 

example, the western hemlock zone dominates lower elevations--less than 2,000 to 3,000 feet. 
Final Environmental Impact Statement 

3-34

Above roughly 3,000 to 4,500 feet in elevation, occupying a cooler and moister climate, lies the 

Pacific silver fir zone. Above this zone at still higher elevations, roughly 4,500 to 6,000 feet, lies 

the mountain hemlock zone. And above this zone lies the subalpine and alpine zones with 

subalpine fir (Abies lasiocarpa), whitebark pine (Pinus albicaulis), and treeless environments 

above timberline. 

The same dominant vegetation zones occur as well on the east side of the crest of the Cascade 

Range within the Forest and Scenic Area, but because annual precipitation declines dramatically 

on the east side due to a strong rain-shadow effect, and temperature variation increases due to the 

greater influence of continental climatic patterns, a drier and cooler climate results in the 

replacement of Pacific silver fir with lodgepole pine (Pinus contorta), western larch (Larix 

occidentalis), and Engelmann spruce (Picea engelmannii) at higher elevations and vegetation 

zones at lower elevations being dominated by grand fir (Abies grandis) and ponderosa pine 

(Pinus ponderosa) instead of western hemlock (Halverson et al., 1986; Topik et al., 1988). 

Vegetation on the east side varies more than that on the west side ranging from dry, open 

ponderosa pine-Oregon white oak (Quercus garryana) savannahs to dense mixed stands of grand 

fir, Douglas-fir, Engelmann spruce, western larch, lodgepole pine, and other conifers. 

Invasive plants tend to colonize disturbed ground, including roadsides, utility (powerline) 

corridors, quarries, landings, recreational residences, trails, and campgrounds where vegetation 

has been removed and growing space for plants adapted to disturbance has been created, but also 

can invade undisturbed habitats. Eastside forests are more susceptible to invasive plants. A major 

conclusion of the ICBEMP (Interior Columbia Basin Ecosystem Management Project) analysis 

(2000) was that, in general, grasslands, riparian areas, and relatively dry, open forests are more 

susceptible to invasion than dense moist forests and high montane areas since the former have 

frequent gaps in plant cover, which favor invasive plant establishment, whereas the latter have 

relatively closed plant cover or have extreme climate or soils, which are tolerated by fewer 

invasive plant species (USDA Forest Service, 2005a). 

Invasive plants are present within the Forest and Scenic Area and pose a threat to native plant 

communities and rare plant species included on the Pacific Northwest Sensitive Species List 

(USDA Forest Service), Survey and Manage plant species (Northwest Forest Plan), federally 

listed plant species (U.S. Fish and Wildlife Service), local endemic plant species and species 

defined as sensitive by the Scenic Area Management Plan. In this document, all are referred to 

simply as special status plants. Roads are conduits for the spread of invasive plants, providing 

vectors for dispersal (e.g., seeds and vegetative reproductive parts of plants attached to vehicles) 

and disturbed ground for invasive plant colonization and establishment. Timber harvest, 

livestock grazing, road building, and other ground-disturbing management activities occurring on 

the Forest and Scenic Area all contribute to the establishment and spread of invasive plants. 
Site-Specific Invasive Plant Treatments 

3-35

3.6.2. Direct/Indirect Effects 

The impacts of this project on special status plants and non-target plants are discussed below. 

Additional information is available in Botany Biological Evaluation and Specialist Report. 

Alternative 1 – No Action Alternative 

Under the No Action Alternative, the Forest treats 100 acres manually and 10 acres mechanically 

and the Scenic Area treats 25 acres manually and 500 acres mechanically on an annual basis. 

These 635 acres comprise only a fraction of the estimated number of acres of land containing 

invasive plants within the Forest and Scenic Area. Small infestations of some invasive plants 

could be treated effectively by manual or mechanical methods [See Mazzu (2005)]. Moderate to 

large infestations of invasive plants, however, are difficult to treat manually or mechanically 

because of treatments needing to be repeated over many years, the high likelihood of plants 

reproducing from vegetative parts (e.g., rhizomes, root fragments, stolons), and dormant seeds 

remaining viable in soils for many years (e.g., 75 to 80 years for Scotch broom). Also, treating 

moderate to large infestations requires labor-intensive efforts of large workforces. 

Examples of small infestations that could be treated effectively by manual or mechanical 

methods include the following with important caveats: 

• Canada thistle (perennial) can be killed by smothering plants with boards, sheet metal, tar 

paper, black plastic, or other means; however, the plant produces rhizomes (underground 

stems) that persist despite smothering or conscientious hand pulling, making even small 

populations (a few plants) of Canada thistle difficult to treat effectively except with 

herbicides. 

• Small patches of yellow starthistle (annual) could be hand pulled, if all aboveground stem 

material and roots are removed. New plants can sprout, however, from seeds stored in the 

seedbank. 

• As with yellow starthistle, small populations of spotted knapweed (biennial or short-lived 

perennial) can be removed by digging up plants, as long as the entire root crown is 

completely removed. 

• Diffuse knapweed (biennial or short-lived perennial) can be hand pulled successfully if 

done before seed set, and if done several times in one year during its growing season 

treating the rosette, immature, and mature plant stages. 

• Populations of houndstongue (biennial or short-lived perennial) can be reduced up to 85 

percent with hand pulling, if roots are completely removed. Severing the root crown 1 to 

2 inches below the soil surface and removing top growth could be effective with small 

populations when done before flowering. New plants can sprout, however, from seeds 

stored in the seedbank. 
Final Environmental Impact Statement 

3-36

• Small infestations of invasive hawkweeds (fibrous-rooted perennial) can be effectively 

treated by digging out all of the rosette, rhizomes, and roots of the plant. Some 

authorities, however, consider manual treatment to be ineffective and do not recommend 

it because hawkweeds can reproduce from root or rhizome fragments. 

• Small populations of St. Johnswort (taprooted perennial) may be treated effectively by 

hand pulling or digging of young plants, but repeated treatments are necessary because 

new plants can grow from the “runner” root system (lateral roots). Plants can also sprout 

from seed. Biocontrol agents (introduced beetles) may be the best way to treat St. 

Johnswort. 

• Tansy ragwort (biennial or short-lived perennial) can be treated effectively by hand 

pulling or mowing small populations. The perennial form of this plant often has large 

woody rootstocks and more than one flowering stem, complicating removal. Seeds could 

also remain viable in the soil for many years. 

Generally, species that are annuals or biennials can be effectively treated manually if the 

populations are small and/or if there are not too many populations. It is important to remove 

most of the root and not break off the plant at the soil surface since it can resprout and still 

flower later in the season (e.g., dandelions). Herbicide treatment is recommended for perennial 

species, especially those with rhizomes and/or creeping root systems like Canada thistle and 

leafy spurge. For many invasive plants, including those listed above, effective manual or 

mechanical treatment is difficult regardless of the size of the population. For example, manual 

treatment is not recommended for invasive knotweed species because digging out its rhizomes, 

in addition to being extremely labor-intensive, tends to spread rhizome fragments, which could 

produce new plants. Meadow knapweed is difficult to pull out because of its tough perennial root 

crown. Himalayan blackberry could be dug out but requires removal of the massive root crown 

and a large workforce to do it. 

Treatment Effectiveness 

Under the No Action Alternative, it is highly likely that the majority of invasive plant 

populations within the Forest and Scenic Area would continue to expand, spread, and become 

increasingly more difficult and costly to control in the future. As one example, highly invasive 

species such as Japanese, giant, and Himalayan knotweed threaten riparian areas within the 

Forest and Scenic Area. Knotweed species tend to grow in moist sites, such as stream sides, 

riverbanks, wetlands, river deltas, and ditches along roads. Species reproduce by extensive 

rhizomes, which could reach 50 to 65 feet in length, and disperse when rhizome fragments are 

washed downstream. Rhizomes could regenerate even if buried up to 3 feet deep and have been 

observed growing through two inches of asphalt (Mazzu, 2005). Knotweeds, if unchecked, could 

rapidly take over stream and river corridors, resulting in a loss of native riparian vegetation, such 

as willows (Salix spp.) and red alder (Alnus rubra), and biological diversity. 
Site-Specific Invasive Plant Treatments 

3-37

Dramatic takeovers of native plant communities along stream and river corridors by knotweed 

species have already occurred in northwestern Oregon (Soll, 2004b). Knotweed canes (woody 

stems) could be cut by hand (manually) or with a machine (mechanically) to set the plant back 

and curtail the spread of individuals and populations; however, these resilient plants grow back 

quickly after cutting (within weeks). To eliminate knotweed plants manually or mechanically, 

the entire plant must be carefully dug up and removed without leaving any rhizome fragments. 

Otherwise, the plant could survive, regenerate, and eventually reproduce. Large populations of 

knotweed species have invaded reaches along the Sandy River and its tributaries and are being 

treated by The Nature Conservancy outside the Forest and Scenic Area. 

Manual or mechanical treatment of knotweeds, except perhaps for a few individual plants, is a 

losing proposition because of their ability to reproduce from root fragments left in the soil or 

washed downstream. Thus far, the most practical and effective way to treat knotweed species is 

with aquatic glyphosate, an herbicide designed for use in streamside and riverside habitats 

because it strongly adsorbs to soil particles and has a low potential of leaching into groundwater 

systems (USDA Forest Service, 2005a). The Nature Conservancy has been treating knotweeds 

with aquatic glyphosate, to which a small amount of triclopyr has been added, along river 

corridors in northwest Oregon with some proven success for several years now (Soll, 2004b). 

Some foliar spraying is done as follow-up treatment, but for the most part the herbicide is not 

sprayed on the plants but injected by hand with heavy-duty syringes into the plants’ cane-like 

stems. Successive years of treatment are needed to kill the plants. Under the No Action 

Alternative, knotweed populations would continue to increase and become more difficult to treat. 

Also, highly invasive are the non-native hawkweeds (orange, meadow or yellow, and common) 

in the genus Hieracium. They could rapidly colonize and spread across upland landscapes, 

especially disturbed areas. Hawkweeds are found in the BPA powerline transmission corridor 

along USDA Forest Service Road 18 and Lolo Pass on the Zigzag Ranger District, and they 

threaten to spread beyond the power corridor. Recently, scattered populations of orange 

hawkweed were found in a meadow complex along a trail in the Mt. Hood Wilderness Area. The 

population is about two acres in size. A field crew of three to five people worked for several days 

in the area this past summer (2005) digging out plants and removing them from the site. The 

consensus of the crew, after surveying the area that they had treated, was that they were only 

able to make small inroads on the population and that more time than they had available would 

be needed to manually control and contain the population. Since orange hawkweed can 

reproduce vegetatively by stolons and rhizomes as well as from seed, even a small piece of root 

or rhizome left in the soil after manual or mechanical treatment may develop into a new plant. 
Final Environmental Impact Statement 

3-38

Some authorities do not recommend manual or mechanical treatment of hawkweeds because 

disturbance to the plant could stimulate the growth of new plants from fragmented roots, stolons, 

and rhizomes and redistribute the plants, increasing their rate of spread (Montana State 

University Extension Service, 2006). Herbicide application is currently the most effective way to 

treat orange hawkweed and other invasive non-native hawkweeds, control populations, and 

contain their spread. Under the No Action Alternative, hawkweeds would be difficult to control 

and contain without herbicides because of their ability to reproduce by seed or vegetatively (by 

rhizomes and stolons), effective manual treatment is difficult for moderate to large populations, 

and both manual and mechanical treatment may stimulate the growth of new plants from 

fragments of roots, stolons, and rhizomes. 

Knapweeds are also highly invasive, but unlike knotweeds and hawkweeds reproduce entirely by 

seed. Knapweeds within the Forest and Scenic Area include spotted, diffuse, and meadow 

knapweed. They produce abundant seed that can remain viable for many years in the soil. Seeds 

can be dispersed up to three feet from plants and much farther when attached to vehicles and 

trains (Mazzu, 2005). Manual treatment (hand pulling) could be effective for small populations 

of spotted and diffuse knapweed, but manual treatment for meadow knapweed is difficult due to 

the species’ tough perennial root crown. Repeated mechanical treatment (mowing) of spotted 

knapweed and meadow knapweed could be moderately effective, but mechanical treatment may 

actually increase populations of diffuse knapweed. Cultural treatments have been effective in 

controlling knapweeds: for example, grazing and plowing have proven to be effective in 

controlling spotted knapweed, but grazing is not an effective control method for diffuse 

knapweed because it is unpalatable and its spines could injure livestock. 

Under the No Action Alternative, manual treatment may control small populations of spotted and 

diffuse knapweed, but mechanical treatment is not effective for diffuse knapweed and could have 

the unintended effect of spreading the plant. Herbicides are not permitted to be used on 

hawkweeds within the Forest or Scenic Area. Herbicides are being used to treat hawkweeds on 

private land adjacent to the Forest (Lolo Pass and nearby BPA power transmission corridor). The 

hawkweed populations on private land have spread from about one-quarter acre in size to about 

1,000 acres that include national forest land in the last 10 to 15 years (Forney, 2006). Without the 

option of herbicides, moderate to large populations of hawkweeds, such as those at Lolo Pass, 

would be difficult to control and contain. As a result, the likelihood is high that populations of 

hawkweed would increase in number and size across the landscape over time under the No 

Action Alternative. 
Site-Specific Invasive Plant Treatments 

3-39

Butter and eggs, or yellow toad flax, tends to occur sporadically within the Forest and Scenic 

Area in disturbed habitat (e.g., roadsides) and drier habitats such as eastside forests and 

rangeland. Plants can produce a taproot as deep as three feet in the soil, and horizontal roots may 

grow to several feet long and develop adventitious buds that can form independent plants. Once 

established, the species can suppress other vegetation by intense competition for limited soil 

moisture. Seeds can remain dormant in the soil for up to ten years. According to some 

authorities, repeated manual treatments (hand pulling) could be effective and cutting the plant in 

the spring or early summer is proposed as an effective way to eliminate plant reproduction; 

however, others discourage manual treatment because of the ability of the plant to reproduce 

vegetatively and spread from rhizomes (Fissell, 2006). Mechanical treatment (mowing) could 

reduce plant populations but is only a temporary solution because it does not reduce rhizome 

growth (Mazzu, 2005). Herbicides are not permitted for the control and containment of butter 

and eggs under the No Action Alternative. Under the No Action Alternative, small populations 

of this plant (containing only a few individuals) may be possible to control or contain by manual 

or mechanical treatment; but moderate to large populations of butter and eggs would be difficult 

to control or contain without herbicide treatment and, therefore, could be expected to persist. 

Without effective treatment, populations of butter and eggs would likely increase in number and 

size across the landscape over time. 

Infestations of yellow starthistle, another highly invasive plant species, are capable of producing 

50 to 100 million seeds per acre. Manual removal is effective for small populations of yellow 

starthistle; however, plants could survive even if a fragment of stem less than 2 inches in length 

is left behind if leaves and buds are still attached at the base of the plant. Mechanical treatment 

(tillage or mowing) could control yellow starthistle but timing is important (Mazzu, 2005). Early 

summer tillage would control yellow starthistle provided that shoots are detached from the roots. 

Mowing, if done before viable seed production, could be effective, but mowing during the early 

growth stages of yellow starthistle could result in increased light penetration and rapid regrowth 

of the plant. Under the No Action Alternative, yellow starthistle may be controllable manually or 

mechanically at the present time because of the small number and size of known populations 

within the Forest and Scenic Area, and if new populations are detected and treated early. 
Final Environmental Impact Statement 

3-40

Effects on Native Plant Communities 

Invasive plant infestations could displace native plants, including special status plants (USDA 

Forest Service, Pacific Northwest Sensitive species; Survey and Manage species; federally listed 

or proposed endangered, threatened, and sensitive species; local endemic species; and plants 

listed as sensitive by the Scenic Area Management Plant) as well as alter or even displace native 

plant communities. Displacement of native plant communities by non-native plants results in 

alterations to the structure and function of ecosystems (MacDonald et al., 1991), and constitutes 

a principal mechanism for loss of native biological diversity at regional and global scales (Lacey 

and Olsen, 1991; Johnson et al., 1994; USDA Forest Service, 2005a). A healthy native plant 

community, which consists of a diverse assemblage of plant species that have evolved together 

in place over thousands of years (probably 4,000 to 5,000 years since the mid-Holocene), 

provides important ecosystem functions or services: for example, creation of habitats and 

microenvironments to which native plants, including special status plants, are adapted; creation 

and maintenance of important structural components in forests (e.g., downed wood, decaying 

logs, and snags); maintenance of critical soil flora and fauna for important belowground 

processes such as decomposition, nutrient cycling, and symbioses (e.g., mycorrhizal associations 

between the fine roots of trees and fungi); maintenance of hydrologic functions such as the 

interception of atmospheric moisture and its storage; and prevention of erosion through the 

stabilization of soils. For more information on mycorrhizal fungi, see page 3-30 in the Invasive 

Plant FEIS (2005a). 

Invasive plant infestations upset ecosystem balances that have evolved over time in native plant 

communities and set in motion changes that compromise and degrade healthy native ecosystems. 

As stated in the Invasive Plant FEIS (2005a), “invasive plants have cascading effects on 

ecosystems and affect significant chemical, physical, and biological components and processes 

(e.g., nutrient cycling, erosion, species competition)” (page 3-27). Table 3-5 in Invasive Plant 

FEIS (2005a) provides a more substantial list of effects of invasive plants on ecosystems. A 

severe invasive plant infestation could displace an entire native plant community (e.g., a westside 

riparian plant community replaced by knotweed or an eastside sagebrush and bunchgrass 

community replaced by yellow starthistle) with dramatic negative repercussions for native plant 

and wildlife species that are dependent on the environment created by a community of native 

plants. A major conclusion of the ICBEMP analysis was that grasslands, riparian areas, and 

relatively dry, open forests are more susceptible to invasion than are dense moist forests and high 

montane areas since the former have frequent gaps in plant cover, which favor invasive plant 

establishment, whereas the latter have relatively closed plant cover or have extreme climate or 

soils, which are tolerated by fewer invasive plant species (USDA Forest Service, 2005a). 

Alterations of native plant communities in such environments by an invasive plant infestation 

could affect an ecosystem at all levels of organization, producing dramatic changes in vegetation 

across the landscape with repercussions for natural resource uses such as watershed 

management, timber harvest, livestock grazing, and recreation. 
Site-Specific Invasive Plant Treatments 

3-41

Although there is a need to treat invasive plants in order to maintain native plant communities, 

likewise the treatments have the potential to shift species composition and reduce diversity of 

native plant communities as less herbicide-tolerant species are replaced by more herbicidetolerant species. For example, certain herbicides and the methods by which they are applied 

could also harm plant pollinators. If a reduction or shift in pollinator species occurs, changes to 

plant species composition or diversity could follow (USDA Forest Service, 2005a). There is also 

the risk, however minimized by PDC, that individuals within populations of special status plants 

may be harmed, weakened, or killed from herbicide application (e.g., from overspray, drift, 

surface runoff, root translocation, or applicator error). Manual or mechanical treatment likewise 

could result in changes in the composition, structure, and diversity of a plant community by 

creating available growing space or opportunities for those native plant species that are better 

adapted to exploit ground disturbance and could outcompete other native species. 

Summary of Effects 

Effects under the No Action Alternative can be summarized as follows: 

• Manual and mechanical treatment of invasive plants is allowed and would continue 

within the Forest and Scenic Area. These treatment methods could be limited in their 

effectiveness as far as controlling or containing invasive plant populations, especially 

large populations and those species that could reproduce vegetatively from rhizomes, 

stolons, or root fragments (e.g., hawkweeds, knotweeds, butter and eggs). All invasive 

plant species are expected to expand and spread with the limited use of herbicides. 

• Limited use of herbicides would continue within the Forest and Scenic Area, resulting in 

limited effectiveness in the treatment of existing and new invasive plant populations. 

• With limited use of herbicides under the No Action Alternative, it could be expected that 

existing, especially difficult-to-control, invasive plant populations would continue to 

expand and spread. 

• New sites of invasive plants are likely to expand unchecked, potentially threatening 

native plants and plant communities. The current limited treatment options of invasive 

plants within the Forest and Scenic Area would likely lead to biologically significant 

negative effects on native plants and plant communities. 
Final Environmental Impact Statement 

3-42

• The No Action Alternative provides for no EDRR to treat newly inventoried infestations 

of invasive plants that were not identified or specified in existing NEPA documents (e.g., 

knotweed species, garlic mustard, policeman’s helmet, herb Robert). At least 24 invasive 

plant species (Table 2-3) are suspected to have the potential to occur or spread within the 

Forest and Scenic Area, which could not be treated under this alternative. The absence of 

an EDRR mechanism in the No Action Alternative would greatly increase the potential 

for new invasive plant infestations to establish and spread, which in the case of highly 

invasive plant species (e.g., knotweeds, hawkweeds, garlic mustard) could be 

ecologically far-reaching because of their potential to radically alter native plant 

communities and ecosystem structure and functions (e.g., energy flow, distribution of 

biomass, plant-animal interactions, decomposition, nutrient cycling, mycorrhizal 

associations, hydrology, etc.). 

Under the No Action Alternative, which precludes the option of expanding the current limited 

use of herbicides within the Forest and Scenic Area to treat invasive plants, existing populations 

of invasive species that are difficult to treat manually or mechanically would likely continue to 

persist, expand, and spread. Additionally, new populations would establish, expand, and spread. 

Infestations of invasive plants would continue to displace native plant species, including special 

status plants, and thereby lower native biological diversity; alter the composition and structure of 

native plant communities; reduce wildlife habitat, forage quality, substrates for nonvascular 

plants (bryophytes and lichens), and hosts for beneficial mycorrhizal fungi; and lead to increased 

soil erosion and changes in hydrology (water uptake, storage, and regulation). Invasive plants 

also alter natural fire regimes by effecting changes in the composition and structure of native 

plant communities, in many cases thereby increasing fire frequency and intensity in eastside 

forests and rangelands, resulting in a loss of recreational and economic opportunities as native 

vegetation is altered or lost. 

Alternative 2 – The Proposed Action 

The Proposed Action proposes to treat 208 areas (about 13,000 acres) containing invasive plants 

with a combination of manual, mechanical, cultural, and herbicide treatments. Table 3-5 lists the 

number of treatment areas for each invasive plant species analyzed in the EIS. Sites have been 

prioritized following Table 2-8. Priority 1 sites include: (1) sites currently occupied by knotweed 

species, hawkweed species, butter and eggs, and yellow starthistle; (2) new infestations of 

invasive plant species (e.g., new populations in areas not yet infested); and (3) active restoration 

sites where invasive plant control is essential. Within the Forest and Scenic Area, knotweed 

species are present in 15 of the proposed treatment areas; hawkweed species in 20 of the 

proposed treatment areas (12 orange hawkweed, five common hawkweed, and three meadow 

hawkweed); butter and eggs in nine of the proposed treatment areas; and yellow starthistle in one 

of the proposed treatment areas. Although knapweed sites are not considered a high priority for 

treatment under the Proposed Action (in earlier management plans they were considered a 

priority west of the Cascade Range), knapweeds are present in 156 of the proposed treatment 

areas within the Forest and Scenic Area (105 diffuse knapweed, 37 spotted knapweed, and 14 

meadow knapweed). 
Site-Specific Invasive Plant Treatments 

3-43

Table 3-5: Number of Treatment Areas by Invasive Plant Species. Many treatment areas 

contain more than one invasive plant species, so the total number of sites adds up to more than 

208 treatment areas. 

Invasive Plant Species Treatment Areas 

Estimated 

Acres 

High Priority 

Species/Site? 

Butter and eggs (LIVU2) 9 232.5 Yes 

Canada thistle (CIAR4) 5 5.4 

Common hawkweed (HIVU) 5 95.9 Yes 

Common tansy (TAVU) 1 --- 

Diffuse knapweed (CEDI3) 105 4,416 

English ivy (HEHE) 12 7.1 

Himalayan blackberry (RUDI2) 6 1,613 

Houndstongue (CYOF) 43 853.8 

Japanese knotweed (POCU6) 15 12 Yes 

Orange hawkweed (HIAU) 12 1,709 Yes 

Meadow hawkweed (HIPR) 3 61.6 Yes 

Meadow knapweed (CEPR2) 14 79 

Reed canarygrass (PHAR3) 3 18.7 

Rush skeletonweed (CHJU) 1 --- 

Scotch broom (CYSC4) 13 237.1 

Spotted knapweed (CEBI2) 37 1,918 

St. Johnswort (HYPE) 1 --- 

Tansy ragwort (SEJA) 32 1,699 

Yellow starthistle (CESO3) 1 7.1 Yes 

Note: Acreage estimates for common tansy, rush skeletonweed, and St. Johnswort are not available. 

Under the Proposed Action, ten herbicides analyzed in the Invasive Plant FEIS (2005a) would be 

available to more effectively control invasive plant infestations, as discussed under treatment 

effectiveness for the No Action Alternative. 

Treatment Effectiveness 

As advanced through integrated weed management, a combination of invasive plant treatments, 

including herbicides, is considered more effective for moderate to large populations than using a 

single method. Repeated manual treatments may be effective for controlling and containing some 

invasive species, but for highly invasive species and for larger populations, herbicide treatment 

may be the most effective and practical means. Manual or mechanical treatments are ineffective 

and often highly difficult for moderate to large populations of invasive plants that could 

reproduce by seed or vegetatively by stolons (e.g., hawkweed species), rhizomes (e.g., 

hawkweed species), or root fragments (e.g., invasive knotweed species). 
Final Environmental Impact Statement 

3-44

Anecdotal evidence and experience quickly demonstrates how challenging and time-consuming 

it could be to dig entire plants out of the ground without disturbing the plants in the process. 

Disturbing the plants or failing to remove the entire plant could leave stolons, rhizomes, or root 

fragments behind from which the plants could reproduce. These challenges increase when 

dealing with moderate to large populations. 

Herbicides are often the only known effective way to control, contain, or eradicate invasive plant 

species that could reproduce from vegetative fragments. For example, herbicide treatment with 

aquatic glyphosate is the only effective way to treat all but small populations of knotweed 

species due to their ability to produce extensive rhizomes that could reach 50 to 65 feet in length 

and to reproduce from root fragments. Without the option to treat infestations of invasive plants 

with a combination of techniques that include herbicide treatment, existing populations of highly 

invasive plant species are difficult to treat manually, mechanically or culturally. As a result, 

infestations would continue to expand and new populations would become established across the 

landscape, reducing or displacing native vegetation, habitat for wildlife, and forage for native 

ungulates and grazing livestock. 

Special Status Plants 

Special status is an umbrella term referring to all plant species that have recognized legal or 

administrative status because of conservation concerns. They include plants on the Regional 

Forester’s Sensitive Species List (USDA Forest Service Pacific Northwest, Region 6), Survey 

and Manage species (Northwest Forest Plan), federally listed and proposed species (U.S. Fish 

and Wildlife Service), local endemics (plants that occur only within the Forest or Scenic Area), 

and species defined as sensitive by the Scenic Area Management Plan. In 2004, 80 fungi, 

lichens, and bryophytes were added to the Regional Forester’s Sensitive Species list. Seventy 

plant species on the Regional Forester’s Sensitive Species list are documented or suspected to 

occur within the Forest and Scenic Area (32 vascular plants, 19 fungi, 15 lichens, and 4 

bryophytes). Eight of those species have been identified in 13 of the 208 areas proposed for 

treatment in the Proposed Action (See Table 3-6). Six of the 13 areas are on the Clackamas River 

Ranger District containing 1 coldwater corydalis (Corydalis aquae-gelidae) site; 1 pale blueeyed grass (Sisyrinchium sarmentosum) site; 2 adder’s-tongue (Ophioglossum pusillum) sites; 

and 3 Methuselah’s Beard (Usnea longissima) sites. Five of the 13 areas are on the Hood River 

Ranger District containing 4 elegant rockcress (Arabis sparsiflora var. sparsiflora) sites and 2 

Watson’s desert-parsley (Lomatium watsonii) sites. And two of the 13 areas are in the Scenic 

Area containing 1 white fairypoppy (Meconella oregana) site and 1 Barrett’s beardtongue 

(Penstemon barrettiae) site. Finally, one treatment area in the Scenic Area contains a local 

endemic plant species (i.e., known only to occur in the Scenic Area): Hood River milkvetch 

(Astragagalus hoodinanus). Coldwater corydalis and Methuselah’s Beard are both USDA Forest 

Service, Pacific Northwest Sensitive species and Survey and Manage species. No federally listed 

plant species are in any of the treatment areas. 
Site-Specific Invasive Plant Treatments 

3-45

Table 3-6: Treatment Areas with Special Status Plants. 

Treatment 

ID 

Site 

Description District Acres 

Special Status 

Plants Present 

Invasive Plant 

Threats 

66-074 Road Hood River 109.0 Elegant rockcress 

(Arabis sparsiflora var. 

sparsiflora) 

Knapweeds and 

tansy ragwort 

66-042 Quarry Hood River 2.8 Elegant rockcress 

(Arabis sparsiflora var. 

sparsiflora) 

Knapweeds and 

tansy ragwort 

65-038 Utility 

corridor 

Hood River 262.0 Elegant rockcress 

(Arabis sparsiflora var. 

sparsiflora), Watson’s 

desert-parsley 

(Lomatium watsonii) 

Knapweeds and 

tansy ragwort 

65-035 Utility 

corridor 

Hood River 6.9 Watson’s desert-parsley 

(Lomatium watsonii) 

Knapweeds 

65-033 Opening Hood River 17.3 Elegant rockcress 

(Arabis sparsiflora var. 

sparsiflora) 

Knapweeds and 

tansy ragwort 

65-027 Small basin 

with 

seasonal 

pond along 

road 

Clackamas 

River 

0.7 Adder’s tongue 

(Ophioglossum pusillum) 

Canada thistle 

69-027 Road Clackamas 

River 

31.5 Methuselah’s Beard 

(Usnea longissima) 

Scotch broom, 

blackberry, 

hawkweed, 

knapweed, and ivy 

65-026 Meadow Clackamas 

River 

4.7 Pale blue-eyed grass 

(Sisyrinchium 

sarmentosum), Adder’s 

tongue (Ophioglossum 

pusillum) 

Canada thistle 

65-023 Road Clackamas 

River 

416.0 Coldwater corydalis 

(Corydalis aquae-gelidae) 

Knapweeds 

65-020 Road Clackamas 

River 

69.2 Methuselah’s Beard 

(Usnea longissima) 

Scotch broom, 

blackberry, 

hawkweed, 

knapweed, and ivy 

65-002 Road Clackamas 

River 

41.9 Methuselah’s Beard 

(Usnea longissima) 

Scotch broom, 

blackberry, 

hawkweed, 

knapweed, and ivy 

22-11 Forested Site Scenic Area 85.0 White fairypoppy 

(Meconella oregana), 

Hood River milkvetch 

(Astragalus hoodianus) 

diffuse knapweed 

and houndstongue 

22-08 Quarry Scenic Area 24.0 Barrett’s beardtongue 

(Penstemon barrettiae) 

diffuse knapweed 

and Himalayan 

blackberry 
Final Environmental Impact Statement 

3-46

The number of individuals for each of these plant species of concern in a treatment area varies 

from few (<20) to many (several hundred). Both diffuse and spotted knapweeds are proposed for 

treatment in the area containing coldwater corydalis. Canada thistle threatens the pale blue-eyed 

grass and adder’s-tongue populations. Spotted, diffuse, and meadow knapweed and tansy 

ragwort threaten the elegant rockcress plants. Spotted and diffuse knapweeds threaten the 

Watson’s desert-parsley plants. The treatment areas with Methuselah’s Beard contain numerous 

invasive species: Scotch broom, Himalayan blackberry, orange hawkweed, meadow hawkweed, 

diffuse knapweed, spotted knapweed, and English ivy. Diffuse knapweed and houndstongue 

threaten the white fairypoppy and Hood River milkvetch populations. And diffuse knapweed and 

Himalayan blackberry threaten the Barrett’s beardtongue site. In many cases, invasive plant 

species are interspersed with the special status plants. For example, Canada thistle plants are 

scattered throughout the proposed treatment areas containing pale blue-eyed grass and adder’stongue, encroaching on and threatening to displace each special status plant species. Because 

Canada thistle is rhizomatous, hand pulling it may harm pale blue-eyed grass and adder’stongue. Additionally, hand pulling is usually ineffective when treating rhizomatous plants such 

as Canada thistle. 

Repeated manual treatments may be effective for controlling or containing small populations of 

certain invasive plants in treatment areas and may pose less risk to special status plants compared 

to herbicide treatments. Associated labor, time, and cost may make manual treatments less 

practical and effective, especially when treating large infestations of invasive plants. Use of 

herbicides may occasionally harm, weaken, or kill individual special status plants in the short 

term, but it is expected that populations would not be jeopardized and would make a full 

recovery from inadvertent damage caused by herbicide use. Despite the risk of harming, 

weakening, or killing individual special status plants with herbicide treatments, “invasive plant 

treatments are more likely to benefit listed plant species” (USDA Forest Service, 2005a) than 

cause them harm in the long term because, without the availability of herbicides as a treatment 

option, invasive plants have the potential to overrun and displace special status plants. 

Concerns have been raised about drift from triclopyr and glyphosate decreasing the 

sustainability, relative long-term abundance, and diversity of lichens and bryophytes (Newmaster 

et al., 1999; USDA Forest Service, 2005a). Lichens and bryophytes lack roots and instead obtain 

moisture and nutrients directly from the atmosphere; therefore, they are particularly sensitive and 

vulnerable to aerosols and contaminants in the atmosphere such as herbicide mist. The lichen, 

Methuselah’s Beard (Usnea longissima), on both the USDA Forest Service, Pacific Northwest 

Region Sensitive Species and Survey & Manage lists, would be highly vulnerable to direct 

herbicide spray or to the fine mist drift from herbicides applied in its vicinity because of its large 

surface area. It is an extremely long pendant lichen (up to several feet in length) that hangs from 

tree branches reminiscent of tinsel on a Christmas tree. Epiphytes (plants that grow on other 

plants), such as Methuselah’s Beard, would be especially vulnerable to direct application or drift 

from broadcast herbicide applications. Terrestrial (ground-dwelling) special status plants, on the 

other hand, would be protected through selective herbicide treatments and shielding. To prevent 

exposure of Methuselah’s Beard to herbicide overspray and drift in identified treatment areas 

along Highway 224 near Lazy Bend Campground (Clackamas River Ranger District) and any 

future treated areas, invasive plants would be manually or mechanically treated first followed by 
Site-Specific Invasive Plant Treatments 

3-47

manual application (hand wiping, painting, or wicking) of herbicides. Low-to-the-ground spot 

spraying of herbicides would be permitted if invasive plant populations are too large to treat 

effectively with hand application of herbicides. 

Recommended treatments (manual, mechanical, or herbicide, or a combination thereof) have 

been made for all of the identified 208 treatment areas (See Appendices B and D). Herbicides 

could harm, weaken, or kill special status plants as well as invasive plants. A number of 

measures would be taken to protect special status plants in the 13 identified treatment areas; 

these are listed under the PDC in Section 2.1, Subsection E, Special Status Plants. Even with 

these PDC, there is some risk that special status plants may be harmed, weakened, or killed by 

herbicides (e.g., through root translocation or surface runoff); however, this risk can be 

minimized by following the precautionary methods described in the PDC. 

Manual, mechanical, cultural, and herbicide treatments entail some risk to native plants and plant 

communities. Any species along roadsides or where activities occur that disturb native plant 

communities would be threatened by not only invasive plants, but by invasive plant treatments 

(USDA Forest Service, 2005a). Are populations of special status plants more at risk by treating 

or not treating invasive plants with herbicides? The risk of harming, weakening, or killing special 

status plants through the application of herbicides must be weighed against the risk of special 

status plants, native plants, and native plant communities being lost in areas because invasive 

plants have been left untreated or treated ineffectively. Not having the option of using herbicides 

to treat areas containing both invasive plants and special status plants would likely result in a 

reduction or loss of those special status plant populations as they are likely to eventually be 

overrun and displaced by invasive species. For example, treatments sites with pal blue-eyed 

grass and adder’s-tongue may be overrun by Canada thistle. 

Effects on Native Plant Communities 

Some of the herbicides proposed for treating invasive plants are selective for particular kinds of 

plants (e.g., dicots versus monocots). See Table 3-13, page 3-91 in the Invasive Plant FEIS 

(2005a) for more details. Dicots include broadleaved and woody plant species. Broadleaved 

refers to plants having broad leaves as opposed to those having needle-like or scale-like leaves 

(e.g., conifers). Monocots include grasses, sedges, rushes, lilies, irises, and orchids. The ability to 

damage or kill only certain plant species or families but not others makes an herbicide selective. 

Selective herbicides analyzed in the Invasive Plant FEIS (2005a) include chlorsulfuron, 

clopyralid, picloram, and sethoxydim (Table 3-7). The other six proposed herbicides analyzed in 

the Invasive Plant FEIS (2005a) are non-selective. The ability to damage a broad spectrum of 

plant species, families, or groups makes an herbicide non-selective (USDA Forest Service, 

2005a). Since herbicides are designed to kill plants, native (non-target) plants and special status 

plants are vulnerable. Picloram, one of the more persistent herbicides, could move readily to 

non-target native plants through root translocation (movement of an herbicide from one plant to 

another across root surfaces) or surface runoff (Invasive Plant FEIS, 2005a). Due to its toxic 

persistence in soils and potential to spread to non-target plants, the potential impacts of picloram 

should be considered thoroughly before prescribing its application. 
Final Environmental Impact Statement 

3-48

Table 3-7: Selective Herbicides Proposed for Treatment and Analyzed in EIS. 

Selective Herbicides Targeted Plant Groups/Families Targeted Invasive Species 

Chlorsulfuron Broadleaved Plants many species 

Clopyralid Asteraceae, Fabaceae, Polygonaceae

hawkweeds, knapweeds, 

knotweeds, tansy ragwort, 

yellow starthistle 

Picloram Broadleaved and Woody Plants many species 

Sethoxydim Annual and Perennial Grasses many species 

NOTE: Information from Pacific Northwest Weed Management Handbook (William et al., 2004). 

PDC included in the Proposed Action would reduce risks to special status plants (e.g., spot rather 

than broadcast spraying of invasive plant species, hand application of herbicides, shielding of 

special status plants with plastic or some other protective sheet). Many native plants in treatment 

areas, however, could be killed with the potential for short-term or even longer-term changes in 

the composition of native plant communities. It is expected, however, that native plants would 

return to occupy growing space released by killed plants. Active restoration in priority 1 (high 

priority) and priority 2 sites, such as seeding with native or non-native, non-invasive grass 

species or planting with native trees, shrubs, or herbs, would insure that the released growing 

space is occupied by native species and not allowed to be re-colonized by invasive plants. Active 

restoration for such sites is critical for success in managing and preventing invasive plant 

infestations; otherwise, released growing space following treatment is likely to be re-invaded by 

invasive plants. 

Some species of fungi, lichens, and bryophytes and their communities could be negatively 

affected by at least two herbicides (triclopyr and glyphosate). Fungi could be negatively affected 

by herbicides known to affect soil mycorrhizae (sulfometuron methyl, picloram, glyphosate, 

triclopyr), but studies are laboratory-based and their results are difficult to extrapolate to field 

situations. Species of fungi associated with late-successional forest ecosystems are not highly 

susceptible to invasion and would not contain the vegetation communities most likely to be 

treated by broadcast application of herbicides (USDA Forest Service, 2005a). For a more 

detailed discussion, see Chapter 4.3 in the Invasive Plant FEIS (2005a) or Section 3.8 – Soil 

Productivity. Since fungi bioaccumulate heavy metals and other contaminants/toxins in the soil, 

the public, including mushroom gatherers, would be alerted before areas are treated through 

public notices (e.g., newspapers, posted signs). For a detailed discussion of effects of herbicide 

treatment on fungi and associated human health concerns, see 3.5 – Human Health and Safety. 
Site-Specific Invasive Plant Treatments 

3-49

Manual or mechanical treatment of invasive plant infestations could also negatively affect native 

plants and plant communities. Direct effects would be unintentional removal or trampling of 

flowers, fruits, or root systems of native plants (USDA Forest Service, 2005a). Other direct effects 

would be reduced plant vigor due to plants being damaged, reduced native seed production, soil 

disturbance, and canopy removal (understory, shrub layer, or overstory depending on the species). 

Indirect effects brought about by these direct effects could include microsite shifts such as 

reduction in productivity, reduction in soil moisture, disruption of mycorrhizal connections, and 

increase in soil temperature (USDA Forest Service, 2005a). These effects could produce a shift in 

species composition further away from a native community, and the removal of one invasive 

species could encourage another invasive species to take its place via windborne seeds or human 

transport (USDA Forest Service, 2005a). The best way to counter against such direct and indirect 

effects is active restoration. Passive restoration is a reasonable expectation for some sites, such as 

those with small populations of invasive plants in less disturbed habitat, such as moist, westside 

forests with largely intact native plant communities; however, active restoration provides the best 

means for preventing re-invasion (re-infestation) by an invasive plant. Active restoration is 

particularly effective at sites with large populations of invasive plants, highly disturbed ground, 

and drier eastside habitats where there is more rangeland, forests are more open, and more 

unoccupied growing space is available for plants to colonize. 

Despite the potential for negative effects from manual or mechanical treatment described above, 

the consensus is that the effects of not treating invasive plants far outweigh the potential adverse 

effects of these treatments on native plants and plant communities. Without treatment, invasive 

plant infestations would increase and spread, displacing native plants and plant communities. 

Early Detection/Rapid Response Strategy 

The Proposed Action includes an EDRR (Section 2.1.3) for promptly treating newly inventoried 

infestations of invasive plant species. Candidate species that are currently known in the Portland 

area and may occur within the Forest and Scenic Area, now or in the future, would include such 

species as garlic mustard, false brome, shining geranium, herb Robert, and policeman’s helmet. 

See Table 2-3 for a list of the 24 invasive plant species, including those above, that could be 

treated under the EDRR. The reproductive ecology and the effectiveness of 

treatment/management options, including recommended herbicides, for each of the 23 candidate 

species are summarized in Appendix G – Common Control Measures Summary. 

The EDRR would allow effective treatment if nearby invasive plants infest the Forest or Scenic 

Area. As an example, policeman’s helmet has been found growing along Bear Creek along 

Highway 26 near the Zigzag Ranger District office and in a stream/drainage channel at The 

Resort at The Mountain golf course in the nearby community of Welches. If these infestations 

spread to the Forest or Scenic Area, they could be treated promptly using this mechanism. 
Final Environmental Impact Statement 

3-50

Under the Proposed Action, new infestations would be treated and, most likely, many with 

herbicides. The Proposed Action poses a greater risk of harming, weakening, or killing special 

status plants in the short term than does the No Action Alternative, which under current EA 

direction allows for the continuation of limited herbicide treatment; however, in the long term 

special status plants have a better chance of survival under the Proposed Action because without 

effective treatment, as under the No Action Alternative, special status plants in identified 

treatment as well as future EDRR areas are expected to be overrun and displaced by invasive 

plant species. The likelihood of harming, weakening, or killing special status plants, however, 

should be low to very low under the Proposed Action. The reasons are that (1) the majority of 

invasive plant populations are found where moderate to severe ground disturbance has occurred 

(e.g., road corridors, quarries, trails, clearcuts, human residences); (2) generally, special status 

plants are not found in areas where moderate to severe ground disturbance has occurred; and (3) 

the PDC designed for the Proposed Action (e.g., spot spraying, hand application of herbicides, 

shielding) would protect special status plants, if found in a treatment area. Translocation of 

herbicides (e.g., glyphosate, picloram) across root systems in the soil from target to non-target 

plants, including special status plants, and runoff from rain (e.g., a thunderstorm) carrying 

herbicide from target to non-target plants are risks associated with successive herbicide 

treatments over a five-year period, as proposed under the Proposed Action. Again, for reasons 

stated above, however, the risk of harming, weakening, or killing special status plants should be 

reasonably low. 

Summary of Effects 

Effects under Alternative 2 – The Proposed Action can be summarized as follows: 

• A toolbox of ten herbicides, which have been analyzed in the Invasive Plant FEIS 

(2005a), would be available to more effectively control invasive plant infestations that 

potentially threaten native plants and plant communities, including special status plants. 

• The ten herbicides analyzed for use have been determined to pose a low risk to all fauna 

and four of the herbicides are more selective as to which plants they target. 

• The size and rate of spread of invasive plant populations on 13,000 acres within the 

Forest and Scenic Area in the 208 identified treatment areas would be controlled or 

contained with treatments rather than left ineffectively treated or to spread under the No 

Action Alternative. 
Site-Specific Invasive Plant Treatments 

3-51

• The expanded use of herbicides under the Proposed Action would increase the potential 

for negative effects on non-target plant species, including special status plants: there may 

be inadvertent harming, weakening, or killing of individual special status plants in the 

short term with herbicide treatment. In the long term, however, affected populations of 

special status plants would benefit from treatment in not being overrun or displaced by 

invasive plants. Without treatment, conversely, special status plants can be expected to be 

overrun and displaced by invasive plants over time. PDC would reduce the potential for 

short-term adverse effects on native plants and plant communities, including special 

status plants. For example, where an invasive plant species is to be treated within 5 feet 

of a special status plant, the invasive plant should be either manually treated or herbicide 

application would be applied by hand (e.g., wiping, wicking, painting, injection). 

• Only 13 of the 208 areas identified for treatment contain special status plants. 

• The inclusion of EDRR would provide for prompt treatment of new sites of invasive 

plant species not included in the current EIS (e.g., policeman’s helmet, garlic mustard, 

herb Robert) and aid in eliminating populations before they become larger and more 

difficult to treat, requiring more extensive and costly control measures later. 

Alternative 3 – Restricted Use Herbicide Alternative 

Under Alternative 3, which restricts herbicide use and broadcast spraying, the spread of invasive 

plants would be checked through eradication, control, or containment more than under the No Action 

Alternative but less so than under Alternative 2 (The Proposed Action). Forty-three treatment areas 

totaling 4,047 acres would be treated with herbicides, roughly 31 percent of the 13,000 acres 

proposed under Alternative 2. Herbicides would only be permitted in high priority treatment areas. 

In treatment areas where a combination of treatments, including herbicides, would be allowed, 

there is a greater likelihood that invasive plants could be treated effectively. Conversely, in 

treatment areas where herbicide treatment is prohibited and invasive plants, instead, would be 

treated manually, mechanically, or culturally, large populations of invasive plants and those 

species that are difficult to treat effectively without herbicides are expected to persist and 

increase over time. Special status plants, the pale blue-eyed grass and adder’s-tongue sites (65-

026 and 65-027), for example, are expected to be overrun and displaced by Canada thistle, which 

threatens both sites. 

Summary 

The Restricted Herbicide Use Alternative is similar to the Proposed Action except for the 

following: 

• Some invasive plant infestations would be uncontrollable, resulting in adverse effects on 

native plants and plant communities, including special status plants. 
Final Environmental Impact Statement 

3-52

• Forty-three treatment areas totaling 4,047 acres (roughly 31 percent) of the 13,000 acres 

proposed for herbicide treatment under the Proposed Action would be treated under the 

Restricted Use Alternative. 

• Restricted herbicide use would reduce the potential of short-term negative effects from 

herbicide treatments, specifically broadcast herbicide applications, on non-target species.

3.6.3. Spread of Invasive Plants to Neighboring Ownerships 

The Forest and Scenic Area are intermingled with other federal, state, county, and private 

ownerships. An issue was raised about the spread of invasive plants from the Forest and Scenic 

Area to adjacent ownerships. 

Currently, under the No Action Alternative, about 1,235 acres of Forest and Scenic Area are 

being treated for invasive plants annually. This number of acres is less than 10 percent of the 

estimated 13,000 acres that are either occupied or immediately threatened by invasive species. 

Seeds from invasive plants in the Forest may end up on other ownerships. The opposite is also 

true: seeds from invasive plants on other ownerships end up in the Forest. The considerable 

number of untreated acres in the Forest does not imply that there is a net transport of invasive 

plant seeds from federal to non-federal lands. The activities, conditions, and vectors that 

determine spread are dynamic and variable. There is no quantitative measure of the net flow of 

plant materials across ownership boundaries. 

The proliferation of invasive plants is caused by several factors. Robust seed production, seed 

dispersal mechanisms (light and feathery, sticky, or burr-like seeds), and the presence of 

conditions favorable to seed dispersal influence the spread of invasive plants. Natural vectors 

such as humans or animals, or natural forces, such as wind and water, spread invasive plant 

seeds. Increasing public mobility and access to remote areas of the landscape facilitate seed 

dispersal. Land management activities that scarify soil or accelerate erosion enhance the 

germination of invasive plants. These factors play out in difficult to quantify ways throughout 

the landscape without regard to land ownership. See Section 3.2.4 for more details. 

Factors that reduce the spread of invasive plants include prevention and treatment actions, the 

number of acres treated, and the prioritization of treatment areas. 

Due to the diversity of invasive plants affecting the Forest and Scenic Area, the effectiveness of 

each alternative is directly related to the variety of treatment tools. Given limited treatment 

budgets, deciding what and where treatments should occur first is a crucial step in the invasive 

plant management program. Without prioritization, funding may be spent on species or sites that 

pose lower threats. Adjacency to private or other public ownerships may be one criterion to set 

priorities for treatment. This criterion, however, should be considered in the context of all factors 

contributing to plant spread, the effects of different plant species in the landscape, and economic 

considerations. 
Site-Specific Invasive Plant Treatments 

3-53

Using the most viable treatment options available (combined with regional prevention standards) 

would most effectively reduce infestations and rates of spread. Some of the invasive plant 

species present in the Forest and Scenic Area are not controlled well by manual or mechanical 

treatments (see Section 3.5 – Botany and Treatment Effectiveness). Herbicide choice is the 

primary variable among the alternatives that would determine potential effectiveness. Because 

the Proposed Action prescribes broader use of herbicides that control the widest variety of 

species, it is probably the most effective in reducing the spread to adjacent ownerships. As 

invasive plant populations are reduced, there would be fewer seeds produced and the spread of 

invasive species would be diminished. Aggressive implementation and proper treatment area 

prioritization, however, are equally important in this regard. The No Action Alternative is the 

least comprehensive, least integrated approach to preventing spread to adjacent lands. The 

Restricted Herbicide Use Alternative, which relies more on manual and mechanical treatment 

methods, would produce better results than the No Action Alternative, but would not be as 

effective as the Proposed Action. 

The EDRR treatment of newly discovered invasive plants is the most successful, cost effective, 

and least environmentally damaging control strategy (ODA, 2001). There is a short time period 

suitable for eradication and containment of new invasive plant populations. Unchecked, new 

populations become long-term management problems and sources of seed to spread off federal 

lands. 

Both the Proposed Action and the Restricted Herbicide Use Alternative have an EDRR. The 

Proposed Action, however, would control some plant species more effectively, because of more 

permissive use of herbicides. The Restricted Herbicide Use Alternative would control new 

populations less effectively due to its heavier reliance on manual and mechanical treatment 

methods. Without an EDRR, the No Action Alternative would not treat newly detected 

populations. 

3.6.4. Cumulative Effects 

Common to all three alternatives is the cumulative effect of increased disturbance and recreation 

over time within the Forest and Scenic Area, driven by increasing human population growth and 

pressure. This translates into an expected increase in the spread of invasive plants over time, 

since the human and vehicular vectors would continue to increase. 

Alternative 1 – No Action Alternative 

Under the No Action Alternative, the likelihood is high, if not certain, that invasive plant 

infestations would persist, expand, and spread over time within the Forest and Scenic Area. New 

infestations could be expected to continue to occur over time. Other invasive plant species, not 

currently known to be within the Forest and Scenic Area, would become established. Native 

plants, including special status plants, may be lost as native plant communities are negatively 

altered or displaced. Ecosystem structure and functions, which include the many biogeochemical 

processes that maintain healthy and diverse forested and rangeland plant communities, would be 

negatively affected. High priority invasive plant sites would continue to increase in size over time. 
Final Environmental Impact Statement 

3-54

Examples include the following: 

• Increasingly more riparian corridors would come under threat of knotweed infestations 

since herbicide treatment with stem injected glyphosate is the only proven way to control 

this highly invasive knotweed species. Except perhaps in the case of very small 

populations (containing only a few individuals), manual treatment of knotweed species is 

ineffective. Manual treatment may actually be a drawback since it could facilitate the 

spread of knotweed species because of its ability to regenerate and reproduce from root 

fragments. 

• Hawkweed infestations could be expected to spread. The three known orange hawkweed 

populations in the Mt. Hood Wilderness Area (totaling 15.3 acres in size) would be 

difficult to control and contain without the option of using herbicides since manual 

control (hand pulling) has proven to be difficult and of limited effectiveness. New 

infestations of orange hawkweed could be expected to spread to meadows and other 

wilderness areas. 

Butter and eggs, yellow starthistle, knapweeds, and many other invasive plant species would 

continue to spread. Without an EDRR to respond to newly inventoried infestations of invasive 

plants (e.g., policeman’s helmet, false brome, garlic mustard), there would be no way to act 

promptly in the future and eradicate these populations before they expand, spread, and become 

increasingly more difficult and costly to treat. Due to the limited use of herbicides currently 

being applied within the Forest and Scenic Area, there would be less potential risk for negative 

effects on fungi (including mycorrhizal fungi), lichens, and bryophytes. 

Ground- and habitat-disturbing forest management activities, over time (10, 20, 30+ years 

hence), would continue to create opportunities for invasive plants to establish and spread. 

Management activities include timber harvest, increased visitor and recreational use, road 

building, road decommissioning, rock excavation at quarries, maintenance and improvement of 

existing facilities, and construction of new facilities. Demands on the Forest and Scenic Area are 

likely to continue to increase over the course of time as a result of steady human population 

growth in the Portland-Vancouver metropolitan area and surrounding areas. Spread of invasive 

plants from adjacent private lands onto the Forest and Scenic Area can be expected. Without 

effective treatment, invasive plant populations are highly likely to increase within the Forest and 

the Scenic Area over time, altering and degrading increasingly more native plant communities 

and thereby negatively affecting many ecosystem services and values, such as clean air and 

water, wildlife and plant diversity, forest and soil health, recreational opportunities, and scenic 

(viewshed) quality. All of these ecosystem services and values would become increasingly more 

valuable to society over time with the expansion of the greater Portland metropolitan area. 
Site-Specific Invasive Plant Treatments 

3-55

Alternative 2 – The Proposed Action 

Under the Proposed Action, expanded use of herbicides to treat invasive plants may harm or kill 

non-target plants. Herbicide treatments have the potential to harm, weaken, or kill special status 

plants. For example, more persistent herbicides, such as picloram, could move readily to nontarget plants through root translocation or runoff (USDA Forest Service, 2005). Special status 

plants, if exposed to herbicide applications, would be at greater risk of being harmed or killed. 

A treatment schedule for persistent infestations that may require herbicide application for three 

to five years would increase the potential for non-target plants being negatively affected 

(harmed, weakened, or killed) by herbicides. Many of the invasive plant populations in the 208 

treatment areas could require successive years of herbicide application to be effectively treated 

depending on the extent and severity of the infestation and how invasive plant populations 

respond to a given treatment. 

Non-target plants in the sunflower (Asteraceae), legume (Fabaceae), or mustard (Brassicaceae) 

families may be the most sensitive to herbicide treatment. Species in the lily family (Liliaceae) 

may be more sensitive to some of the sulfonylurea herbicides (USDA Forest Service, 2005). 

Potential adverse effects on mycorrhizal fungi, which are beneficial to Pacific Northwest 

conifers and other native plant species and increase the productivity of forest communities, could 

occur in treatment areas where herbicides are used. Bryophytes and lichens (e.g., Methuselah’s 

Beard) in treatment areas or nearby could be negatively affected by direct exposure to herbicide 

spray or from drift because they lack roots and, instead, absorb water and nutrients directly from 

the atmosphere. PDC would require protection (hand application of herbicide(s), spot spraying, 

or physical shielding) of special status plants in the treatment areas where they occur with some 

exceptions. Only 13 of the 208 treatment areas identified and analyzed in the EIS contain special 

status plants; thus, adverse effects on special status plants would be low and PDC would reduce 

potential harmful effects. 

Manual and mechanical treatments could also harm native plants as well as special status plants. 

PDC included in Alternatives 2 and 3 would reduce these risks and minimize harm. Manual and 

mechanical treatments could also alter the composition and structure of native plant 

communities, as released growing space previously occupied by invasive plants is made 

available. Certain native plants would be able to outcompete other native plants for this growing 

space. The growing space could also be re-invaded by invasive plant species. Active restoration 

for priority 1 (high priority) and priority 2 sites would help in preventing re-invasion (reinfestation) of invasive plants following treatment. 
Final Environmental Impact Statement 

3-56

With the passing of time (3 to 10 years or longer), the cumulative effects of not treating invasive 

plants would be biologically significant and outweigh most concerns about effects on non-target 

plants and native plant communities, including special status plants. For example, knotweed 

species are an example of a highly invasive plant that is already present within the Forest and 

Scenic Area and spreading rapidly in riparian zones in stream and river corridors. Without 

additional treatment options (herbicide use), populations of invasive plants, including knotweed 

species, are expected to continue to expand in size, increase in number, and spread elsewhere, 

displacing native plants and plant communities, including special status plants and, in the 

process, degrading native ecosystems. By allowing the present situation of ineffective prevention 

and management of invasive plants within the Forest and Scenic Area to continue, any treatment 

efforts in the future would become increasingly more difficult and costly. Overall, manual, 

mechanical, cultural, and herbicide treatments would have an insignificant biological effect as far 

as harming native plants and plant communities as well as special status plants if the project is 

implemented with the appropriate PDC. Treatments could be expected to benefit native plants 

and plant communities and special status plants by restoring native habitats and plant 

communities. 

As with the No Action Alternative, ground-disturbing management activities and use, over time 

(10, 20, 30+ years hence) would continue to create opportunities for invasive plants to establish 

and spread. Management activities include, but are not limited to, timber harvest, road traffic 

from visitor and recreational use, road building, road decommissioning, rock excavation at 

quarries, maintenance and improvement of existing facilities, and construction of new facilities. 

Demands on the Forest and Scenic Area are likely to continue to increase over the course of time 

as a result of steady human population growth in the Portland-Vancouver metropolitan area and 

surrounding areas. Under the Proposed Action, however, more effective treatment of invasive 

plants would begin with approximately 13,000 acres identified for treatment. The amount of 

treated acres and the addition of the EDRR for treating new invasive plant populations would 

contribute towards controlling and containing existing populations and checking the 

establishment of new invasive plant populations within the Forest and the Scenic Area. 

Expansion of herbicide treatment method(s) would protect native plant communities as well as 

ecosystem services and values from degradation resulting from invasive plant infestations. 

Alternative 3 – Restricted Herbicide Use Alternative 

Harming, weakening or killing of non-target plant species would be greatly reduced under this 

alternative since only 4,047 acres, compared to 13,000 acres under Alternative 2 (The Proposed 

Action), would be treated with herbicides, and broadcast spraying would only be allowed in three 

treatment areas (the Sandy River Delta, Lolo Pass utility road and corridor, and west side of the 

BPA power line corridor). Yet populations of invasive plants on the other 8,953 acres of the 

13,000 inventoried acres, which contain invasive plants that would be treated only manually, 

mechanically, or culturally, can be expected to persist and expand over time. Non-herbicide 

treatments are effective against only small populations of certain invasive plant species. 
Site-Specific Invasive Plant Treatments 

3-57

Similar to the Proposed Action, the EDRR for treating new invasive plants and new infestations 

not inventoried in this EIS would greatly increase the ability to control and contain existing 

populations and to respond quickly to new infestations. Restricting broadcast spraying to three 

treatment areas would reduce effective treatment of existing and new invasive plant infestations 

compared to the Proposed Action. Invasive plant infestations would be more challenging (timeconsuming and labor-intensive) to treat with spot (backpack) spraying and hand/selective 

application (hand wiping, wicking, painting, injection) of herbicides. 

Similar trends in human population growth in the greater Portland metropolitan area with 

steadily increasing demands on the natural resources provided by the Forest and Scenic Area 

could be expected, as described under the No Action and Proposed Action Alternatives. The 

Restricted Herbicide Use Alternative would be expected to be more effective than the No Action 

Alternative, but less effective than the Proposed Action in treating invasive plants and 

maintaining native plant communities and the ecosystem services provided by healthy 

functioning forests and rangelands within the Forest and Scenic Area. 

Spread of Invasive Plants to Neighboring Ownerships 

The most effective means of combating invasive plants is a comprehensive landscape treatment 

strategy that integrates and coordinates the treatment actions of all affected and potentially 

affected land owners (GAO, 2005). Such a strategy, however, is beyond the scope of this project. 

The USDA Forest Service estimates that invasive plant control occurs on over 1,250,000 acres in 

Oregon and Washington (Invasive Plant FEIS, 2005a). No central source exists for compiling 

invasive plant management information on lands intermingled with the Forest and Scenic Area. 

There is no requirement for private or corporate land owners to report invasive plant treatment 

information. Counties and the State of Oregon keep records of herbicide application. For 

example, records indicate that Clackamas County, Oregon, treated approximately 2,893 acres 

with five different herbicide formulations in 2004. There is, however, no comprehensive 

database for tracking herbicide treatment activity. Therefore, an accurate accounting of the total 

acreage of invasive plant treatment for all land ownerships is not available. 

For all alternatives, present and reasonably foreseeable future actions would continue to cause 

ground disturbance on a landscape scale, resulting in the introduction and spread of invasive 

plants. Roads would continue to be a major conduit for invasive plants. National recreation 

studies as well as local trends indicate that recreation uses within the Forest and Scenic Area 

would continue to increase (Cordell, 1999). Other land management and use activities such as 

grazing, vegetation management, fuels management, and fire suppression would continue to 

cause ground disturbance and contribute to the introduction, spread, and establishment of 

invasive plants within the Forest and Scenic Area as well as on adjacent ownerships. 

Some land uses and development on lands near the Forest and Scenic Area would likely continue 

to decrease effectiveness of USDA Forest Service, state, county, and private invasive plant 

management. For example, the use of invasive plants by landowners for landscaping, while small 

individually, can collectively result in significant impacts, especially along riparian corridors. 
Final Environmental Impact Statement 

3-58

Positive cumulative effects could occur as the Forest efforts are combined with other Bureau of 

Land Management, State of Oregon, county, and private landowner efforts, reducing the rate of 

spread on a regional level. Oregon Department of Agriculture (ODA), for example, is a leader in 

early detection and rapid response, with up to 20 ongoing or proposed programs at a state or 

regional level. Also, the Invasive Plant ROD (2005b) contains seven standards to help prevent 

the spread of invasive plants. 

As noted earlier in this document, ODA and Oregon Counties currently spend more than four 

million dollars annually to manage invasive plants. A January, 2001 report entitled Oregon 

Noxious Weed Strategic Plan recommends that this spending be increased by an additional 

5.2 million dollars annually from state and local sources. The same report recommends that 

spending by all federal agencies in Oregon be increased by 7.2 million dollars per year to 

adequately implement invasive plant control programs on federal lands in Oregon (ODA, 2001). 

3.6.5. Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action 

and Restricted Herbicide Use Alternatives are consistent with all relevant standards and 

guidelines, when the proposed amendments are incorporated. The Forest Plan amendments are 

discussed in Section 3.16. 

3.6.6. Incomplete and Unavailable Information 

Studies are not available regarding the effects of herbicide on native non-target species. The EPA 

performs studies predominantly on crop species rater than native species. Bountin et al. (2004) 

concluded that it is likely that species tested were not representative of the habitats found 

adjacent to agricultural treatment areas; thus risk to native species may be underestimated. 

Herbicide effects to native species can be extrapolated from the risk assessments or herbicide 

labels. This information would be used to comply with Invasive Plant ROD (2005b) standard 19, 

which directs that site-specific information, including potential effects of specific herbicides on 

non-target species, be considered when making a decision to use herbicides. 
CHAPTER 3 

Affected Environment and 

Environmental Consequences 
Site-Specific Invasive Plant Treatments 

3-59

3.7. Economic Efficiency 

3.7.1. Existing Conditions 

Economic Impacts of Invasive Plants 

Invasive plants (noxious weeds) have an enormous impact on Oregon’s economy and natural 

resources. In 1999, Oregon Department of Agriculture (ODA) partnered with Oregon State 

University (OSU) to study the economic impacts of 21 of the 99 invasive plants listed in Oregon 

as noxious (See Appendix I – Oregon State Class A & B Noxious Weeds). Existing populations 

of these 21 species presently reduce Oregon’s total personal income by about 83 million dollar, 

the equivalent of 3,329 annual jobs lost to Oregon’s economy from the production foregone by 

the presence of these invasive plants. The continued expansion of these species could further 

reduce Oregon’s personal income by another 54 million dollar, the equivalent of another 2,143 

jobs lost. The total economic loss is much higher. The study estimated that the existing 

populations and potential expansion of these 21 species cost 100 million dollar annually in lost 

economic value. This is equivalent to an asset value of about one billion dollars lost. In other 

words, the value of Oregon’s resources is reduced by approximately one billion dollars because 

of these weeds (The Research Group, 2000). Of the 21 invasive plants highlighted for economic 

evaluation by ODA and OSU, seven of the species are present in the Forest and Scenic Area and 

are targets of this proposal: tansy ragwort, spotted knapweed, diffuse knapweed, yellow 

starthistle, Scotch broom, rush skeletonweed, and orange hawkweed. 

By out-competing and displacing economically valuable native plants, invasive plants deprive 

the marketplace of an important product and affect employment. The region’s non-timber forest 

product industry was estimated to have a value of more than $190 million in 1992 (Oregon 

Public Broadcasting, 2005). Schlosser and Blatner (1994) estimated that special forest products 

contribute $200 million or more annually to the Pacific Northwest (Idaho, Oregon, Washington) 

economy, much of it from the western parts of Oregon and Washington. The largest component 

is floral greens and Christmas ornamental products with a wholesale value in 1988 estimated to 

be $130 million. The portion of this total value attributed to wild edible mushrooms in 1992 was 

estimated to be $20.3 million (Hansis, 1998). The value of exported wild mushrooms, mostly to 

Germany and Japan, is estimated to be $6 million annually (Oregon Public Broadcasting, 2005). 

This economic overview is relevant to the project analysis because non-timber forest products 

harvested from the Forest are part of a regional economic engine. 

Table 3-8 displays the number and cost of special forest product permits sold by the Mt. Hood 

National Forest for fiscal years 2003, 2004, and 2005 (federal fiscal year = October 1 through 

September 30). The table does not include free-use permits. Many free, personal-use mushroom 

permits are issued each year. 
Final Environmental Impact Statement 

3-60

Table 3-8: Special Forest Products Summary for the Forest – Fiscal Years 2003, 2004, and 

2005. 

FY 2003 FY 2004 FY 2005 

Product 

Permits 

Issued 

Cost of 

Permits 

Permits 

Issued 

Cost of 

Permits 

Permits 

Issued 

Cost of 

Permits 

Beargrass 746 $20,970.00 761 $24,006.00 727 $23,575.00

Boughs 35 $56,257.17 25 $76,870.43 21 $42,460.00

Cones 2 $40.00 0 $0.00 2 $40.00

Firewood 2016 $49,110.00 1735 $42,760.00 1342 $30,240.00

Medicinal 3 $95.00 5 $110.00 2 $57.00

Mushrooms 91 $1,884.00 546 $14,150.00 187 $4,111.34

Poles 10 $395.37 14 $613.02 11 $951.18

Posts/Rails 3 $53.05 1 $22.80 0 $0.00

Salal/Forest Greens 36 $956.29 61 $2,705.00 41 $1,210.00

Shakebolts 10 $2,361.21 6 $745.83 6 $1,246.00

Stems 11 $227.23 6 $14,454.00 7 $179.08

Transplants 11 $1,517.90 2 $221.25 5 $480.96

Christmas Trees 5878 $29,747.00 4726 $24,137.00 6064 $28,029.50

Total 8852 $163,614.22 7888 $200,795.33 8415 $132,580.06

 

Employment 

Unemployment rates in the state of Oregon have fluctuated considerably during the past several 

years. Also, they have been higher than the national average. According to the U.S. Department 

of Labor Bureau of Labor Statistics (2005), Oregon’s seasonally adjusted unemployment rate 

(preliminary) in August 2005 was 6.7 percent. The preliminary, non-seasonally adjusted rate was 

6.3 percent. For the Portland metropolitan area, the preliminary, non-seasonally adjusted rate was 

6.2 percent. 

In a 2000 report, the Oregon Department of Agriculture estimated that current invasive plant 

infestations reduce the total personal income of Oregonians by about 83 million dollars (The 

Research Group, 2000). This is equivalent to 3,329 annual jobs lost to Oregon’s economy from 

foregone production. Furthermore, the continued spread of only six major invasive plant species 

could potentially reduce Oregon’s personal income by another 54 million dollars and reduce 

annual jobs by another 2,143. 
Site-Specific Invasive Plant Treatments 

3-61

3.7.2. Economic Analysis 

Management of invasive plants is costly, and fiscal resources are limited. Users of National 

Forest System lands would pay some of the cost either directly or indirectly. Also, invasive plant 

management would compete with other land management needs, resulting in opportunity-cost 

tradeoffs. Two models were used to compare the alternatives economically. First, the total cost 

of treating all acres in each of the alternative (including No Action Alternative) was estimated 

based on the treatment prescriptions described in Appendix S. Second, a menu of costs was 

developed for the Proposed Action and Reduced Herbicide Use Alternatives which shows how 

much it would cost and how long it would take to treat all inventoried acres depending on how 

many acres are treated each year. The number of full-time jobs created is also analyzed. 

Total Cost Analysis 

The costs of the No Action, Proposed Action and Restricted Herbicide Use Alternatives are first 

analyzed assuming all proposed treatments begin in year one. The costs for the Proposed Action 

and Reduced Herbicide Use Alternative are based on an aggressive five-year program to treat 

13,000 acres. Appendix S – Economic Assumptions contains the treatment regime prescriptions 

for all areas, which are the basis for this analysis, and the assumptions used in their development. 

This calculation does not include an economic estimate of potential benefits from reducing or 

eliminating invasive plants. Costs for the EDRR of the Proposed Action and the Restricted 

Herbicide Use Alternative are also not included here. The total costs of the two action 

alternatives are compared to the cost of the No Action Alternative, which assumes only one year 

of treatment for every area (See Appendix S). It is important to note that the No Action 

Alternative would treat fewer acres than either of the two action alternatives. 

Some treatment costs are based on figures in the Invasive Plant FEIS (2005a) (Pages 4-94 to 4-

96). Other treatment costs are empirically derived from recent invasive plant management 

contracts for the Forest. Herbicide costs not derived from either of these two sources are 

calculated from data obtained from the 2005 North Dakota Weed Control Guide (Zollinger, 

2005). The Quick-Silver Program is used to determine the present value of costs. The analysis 

uses a real discount rate of 4 percent, a rate typically used for ecological investments. The 

analysis is repeated using a zero percent and a 7 percent real discount rate to test whether the 

analysis is sensitive to the discount rate. A real discount rate means inflation is not factored into 

the calculation. The quantitative results of the analysis are shown in Table 3-9 comparing the 

discounted cash flows (4% and 7% discount rates) to an undiscounted cash flow (0% discount 

rate). The sensitivity analysis shows that the interest rate used for discounting has no effect on 

the ranking of alternatives based on cost. 
Final Environmental Impact Statement 

3-62

Table 3-9: Total costs for three alternatives to treat inventoried invasive plant 

populations in the Forest and the Scenic Area calculated using no discount rate, 4% 

discount rate, and 7% discount rate. 

Discount Rate 

Alternative 1 – No 

Action 

Alternative 2 – 

Proposed Action 

Alternative 3 – Restricted 

Herbicide Use 

0% 1,271,180 4,329,004 7,317,382 

4% 1,214,095 4,241,724 7,174,985 

7% 1,175,828 4,180,827 7,076,245 

In the total cost analysis, the No Action Alternative would treat 1,235 acres and would cost 

roughly 1.2 million dollars (4% discount rate). Both action alternatives would treat 13,000 acres. 

The Restricted Herbicide Use Alternative would be the most expensive, costing nearly 7.2 

million dollars (4% discount rate). The Proposed Action would cost about 4.2 million dollars 

(4% discount rate), which is 60 percent of the cost of the Restricted Herbicide Use Alternative 

(See Figure 3-3). This difference is attributed to the lower cost of herbicide treatment (compared 

to manual and mechanical costs) and to the greater assumed effectiveness of herbicide treatments 

(80 percent for the Proposed Action compared to 60 percent for the Restricted Herbicide Use 

Alternative). 

Figure 3-3: Total costs of Alternatives to treat invasive plants in the Forest and Scenic 

Area in Oregon without budget constraint. 

Alternative 2 Alternative 3 Alternative 1

$8,000,000

$7,000,000

$6,000,000

$5,000,000

$4,000,000

$3,000,000

$2,000,000

$1,000,000

$0

Total Costs (not discounted)

The average annual treatment cost per acre for each alternative was calculated (See Table 3-10). 

The No Action Alternative has the lowest per acre cost since it lacks the 5-year integrated 

treatment strategy of the two action alternatives. All areas included in the No Action Alternative 

would be treated for only one year; most acres would be treated only once. 
Site-Specific Invasive Plant Treatments 

3-63

Table 3-10: Cost per acre for three alternatives to treat inventoried invasive plant 

populations in the Forest and Scenic Area. 

Alternative 1 – 

No Action 

Alternative 2 – 

Proposed Action 

Alternative 3 – 

Restricted Herbicide Use 

$193.48 $324.25 $540.94 

Presently, the average annual cost per acre for the No Action Alternative is 193 dollars. The 

Proposed Action would increase average annual treatment cost per acre to 324 dollars; and the 

Restricted Herbicide Use Alternative would have an average annual per acre cost of 541 dollars. 

If the current invasive plant budget for the analysis area were held constant at roughly 200,000 

dollars per year, then the number of acres that could be treated annually in the Proposed Action 

would be reduced by 51 percent. For the Restricted Herbicide Use Alternative, the number of 

acres treated annually would be reduced by 70 percent. The treatment regimes prescribed in both 

the Proposed Action and Reduced Herbicide Use Alternative would be expected to more 

effectively manage invasive plants than No Action, justifying the higher cost per acre. However, 

without a substantial increase in appropriated funding, the Forest and Scenic Area may be faced 

with a protracted treatment program regardless of whether the treatment emphasis is herbicides, 

manual, mechanical or cultural. 

Variable Budget Analysis 

Since budgets are limited, the data are also analyzed to show the treatment costs for the Proposed 

Action and Reduced Herbicide Use Alternative for various annual treatment levels and several 

hypothetical rates of the invasive plant spread. Tables 3-11 and 3-12 display the number of years 

it would take and the costs to treat the proposed 13,000 acres for various annual treatment 

regimes (i.e. the number of acres treated each year). The following examples illustrate the use of 

Table 3-11 for the Proposed Action (Table 3-12 is interpreted similarly for the Restricted 

Herbicide Use Alternative). These are only examples, not management preferences: 

• If 2,000 acres are treated each year, the annual cost would be $648,000. If untreated 

invasive plants continue spreading at an annual rate of 8 percent per year, then known 

populations of invasive plants would not be fully controlled for 16 years at a total cost of 

$7,937,700. 

• If annual treatment budgets are $486,000 per year, then only 1,500 acres could be treated 

annually. If untreated invasive plants continue spreading at an annual rate of 10 percent, 

then it would take 48 years to control known populations of invasive plants at a total cost 

of $21,505,310. 

• If the current annual treatment budget of approximately $200,000 per year for the 

analysis area continues unchanged and untreated areas continue spreading at an annual 

rate of 8 percent, then the current populations of invasive plants would never be fully 

controlled. Treatments would fall behind the rate of spread. 
Final Environmental Impact Statement 

3-64

Some general conclusions that apply to both the Proposed Action and the Restricted Herbicide 

Use Alternative can be drawn from Tables 3-11 and 3-12. For any given hypothetical invasive 

plant spread rate, increasing the number of annual treatment acres would decrease the total cost 

of the project. The deviations from this regression are due to the discrete nature of the “years” 

factor; that is, calculations used the number of years as whole numbers disregarding fractions of 

years. Not surprisingly, at higher rates of invasive plant spread, the total cost of the project and 

the number of years to control inventoried areas would increase for any fixed number of annual 

treatment acres. 

The variable budget analysis shows that the Proposed Action would cost between 6.2 and 21.5 

million dollars. The Restricted Herbicide Use Alternative would cost between 14.2 and 47.9 

million dollars. The Proposed Action would take from 8 to 48 years to control the known 

populations of invasive plants; the Restricted Herbicide Use Alternative would take from 9 to 48 

years. For any given treatment regime (acres treated per year) and assumed rate of invasive plant 

spread, the cost of the Restricted Herbicide Use Alternative would cost between 2.1 and 5.2 

times more than the Proposed Action. To illustrate, if 5,000 acres were treated each year, and it 

were assumed that invasive plants spread 10 percent each year, then it would cost 2.1 times more 

to implement the Reduced Herbicide Use Alternative than the Proposed Action. If 2,000 acres 

were treated each year, and it were assumed that invasive plants spread 10 percent each year, 

then it would cost 5.2 times more to implement the Reduced Herbicide Use Alternative than the 

Proposed Action. All other treatment regimes fall between these two extremes. 

Table 3-11: For Alternative 2 (The Proposed Action), number of years and total cost to 

control 13,000 acres of invasive plants at various annual rates of plant spread and annual 

treatment regimes for the Forest and Scenic Area. Assumes the average annual treatment 

cost for the Proposed Action per acre is $324. Years are N+4 (see notes below). Costs are 

undiscounted cash flows. For more explanation about this table, see Appendix S – Economic 

Assumptions. 

No. Years to Control and Total Cost (M$) at Various Annual 

Rates of Invasive Plant Spread (%) 

8% 10% 12% 

Annual 

Treatment 

Acres 

Cost (M$) 

Per Year Yrs. Total Cost Yrs. Total Cost Yrs. Total Cost 

500 $162.00 Never N.A. Never N.A. Never N.A. 

1,000 $324.00 Never N.A. Never N.A. Never N.A. 

1,500 $486.00 25 $10,327.31 48 $21,505.31 Never N.A. 

2,000 $648.00 16 $7,937.74 18 $9,233.74 22 $11,825.87 

2,500 $810.00 13 $7,492.18 13 $7,492.18 15 $9,112.35 

3,000 $972.00 11 $7,046.61 11 $7,046.61 12 $8,018.80 

3,500 $1,134.00 10 $7,087.05 10 $7,087.05 10 $7,087.05 

4,000 $1,296.00 9 $6,803.48 9 $6,803.48 9 $6,803.48 

4,500 $1,458.00 8 $6,195.92 8 $6,195.92 8 $6,195.92 

5,000 $1,620.00 8 $6,884.35 8 $6,884.35 8 $6,884.35 
Site-Specific Invasive Plant Treatments 

3-65

Table 3-11 Notes: 

• Annual Treatment Acres – Each treatment regime analyzed (row of data in Table 3-11) 

assumes five years of integrated treatments for every area of inventoried invasive plants. 

To simulate the effectiveness of treatment, the acres in each treatment area are reduced 

by 80 percent per year for years 2 through 5. Treatment is assumed to be accomplished at 

the end of year 5. Because each area is treated for five years, the numbers of “new” acres 

treated in years 2 through N are reduced by 20 percent in order to maintain a fixed budget 

for each treatment regime. For more explanation, see Appendix S – Economic 

Assumptions. 

• Cost (M$) Per Year - Values are in thousand dollars. The amount represents the fixed 

average annual cost (budget) for the treatment regime. It is calculated by multiplying the 

annual treatment acres by $324 (the average, annual per-acre treatment cost). 

• Years – The value is determined by performing “annuity due” calculations (advance 

payment annuity) using the following parameters: i = invasive plant spread rate (%); 

PMT = “new” acres treated in years 2 through N; present value = 13,000; future value = 

0. The annuity calculation solved for N, the number of years during which new areas 

would receive initial treatments. In the table, N is increased by 4 years to account for the 

full 5-year treatment regime (N+4). 

• Total Cost – Values are in thousand dollars. The amount represents the undiscounted sum 

of treatment costs (cash flow) for N+4 years. 

• Rates of Spread – For the limited budget analysis, it is assumed that once treatment is 

begun on any acre of invasive plants, its spread is halted on that acre. However, since not 

all acres are treated in year 1 (and some acres would not be treated initially until Year N), 

invasive plants on those acres would continue to spread at some rate. The table displays 

the number of years it would take to control the current inventoried areas at several 

hypothetical annual rates of spread (8, 10, and 12 percent). 
Final Environmental Impact Statement 

3-66

Table 3-12: For Alternative 3 (Restricted Herbicide Use), number of years and total cost 

to control 13,000 acres of invasive plants at various annual rates of plant spread and 

annual treatment regimes for the Forest and Scenic Area. Assumes the average annual 

treatment cost for the Proposed Action per acre = $541. Years = N+4 (see notes below). Costs 

are undiscounted cash flows. For more explanation about this table, see Appendix S – 

Economic Assumptions. 

No. Years to Control and Total Cost (M$) at Various Annual 

Rates of Invasive Plant Spread (%) 

8% 10% 12% 

Annual 

Treatment 

Acres 

Cost (M$) 

Per Year Yrs. Total Cost Yrs. Total Cost Yrs. Total Cost 

500 $270.50 Never N.A. Never N.A. Never N.A. 

1,000 $541.00 Never N.A. Never N.A. Never N.A. 

1,500 $811.50 Never N.A. Never N.A. Never N.A. 

2,000 $1,082.00 25 $22,992.07 48 $47,878.07 Never N.A. 

2,500 $1,352.50 17 $17,920.08 20 $21,977.58 27 $31,986.08 

3,000 $1,623.00 14 $16,635.10 15 $18,258.10 17 $22,153.30 

3,500 $1,893.50 12 $15,620.62 13 $17,514.12 14 $22,058.51 

4,000 $2,164.00 11 $15,688.13 11 $15,688.13 12 $18,717.74 

4,500 $2,434.50 10 $15,214.65 10 $15,214.65 10 $15,214.65 

5,000 $2,705.00 9 $14,200.17 9 $14,200.17 9 $14,200.17 

Table 3-12 Notes: 

• Annual Treatment Acres – Each treatment regime analyzed (row of data in Table 3-12) 

assumes five years of integrated treatments for every area of inventoried invasive plants. 

To simulate the effectiveness of treatment, the acres in each treatment area are reduced 

by 60 percent per year for years 2 through 5. Treatment is assumed to be accomplished at 

the end of year 5. Because each area is treated for five years, the numbers of “new” acres 

treated in years 2 through N are reduced by 40 percent in order to maintain a fixed budget 

for each treatment regime. For more explanation, see Appendix S – Economic Analysis. 

• Cost (M$) Per Year - Values are in thousand dollars. The amount represents the fixed 

average annual cost (budget) for the treatment regime. It is calculated by multiplying the 

annual treatment acres by $541 (the average, annual per-acre treatment cost). 

• Years – The value is determined by performing “annuity due” calculations (advance 

payment annuity) using the following parameters: i = invasive plant spread rate (%); 

PMT = “new” acres treated in years 2 through N; present value = 13,000; future value = 

0. The annuity calculation solved for N, the number of years during which new areas 

would receive initial treatments. In the table, N is increased by 4 years to account for the 

full 5-year treatment regime (N+4). 
Site-Specific Invasive Plant Treatments 

3-67

• Total Cost – Values are in thousand dollars. The amount represents the undiscounted sum 

of treatment costs (cash flow) for N+4 years. 

• Rates of Spread – For the limited budget analysis, it is assumed that once treatment is 

begun on any acre of invasive plants, its spread is halted on that acre. However, since not 

all acres are treated in Year 1 (and some acres would not be treated initially until Year 

N), invasive plants on those acres would continue to spread at some rate. The table 

displays the number of years it would take to control the current inventoried areas at 

several hypothetical annual rates of spread (8, 10, and 12 percent). 

Comparison of the Total Cost and Variable Budget Analyses 

The total cost analysis indicates that the Restricted Herbicide Use Alternative would cost about 

1.7 times more than the Proposed Action (see Table 3-9). The variable budget analysis more 

realistically shows that the Restricted Herbicide Use Alternative would cost between 2.1 and 5.2 

times more than the Proposed Action (see Tables 3-11 and 3-12), depending upon the treatment 

regime (acres treated each year) and rate of spread. In every case, the higher total cost results in 

the variable budget analysis for both action alternatives are attributed to invasive plant spread. 

By delaying treatment, there would be more acres to treat. Because undiscounted cash flows 

were used in the variable budget analysis, the time value of money was not a factor in the 

increased cost. 

To illustrate this point for the Proposed Action, if annual funding for treatment were set at 1.6 

million dollars, the variable budget analysis (Table 3-11) shows that it would take eight years to 

treat all 13,000 acres. If annual funding for treatment were set at 0.5 million dollars, the variable 

budget analysis (Table 3-11) then shows that it would take between 25 and 48 years to treat all 

13,000 acres, depending upon the rate of invasive plant spread. By comparison, the total cost 

analysis (Table 3-9, undiscounted) shows that it would take about 4.3 million dollars up front to 

treat all 13,000 acres in five years. 

To illustrate the point for the Restricted Herbicide Use Alternative, if annual funding for 

treatment were set at 1.6 million dollars, the variable budget analysis (Table 3-11) shows that it 

would take between 14 and 17 years to treat all 13,000 acres, depending upon the rate of invasive 

plant spread. If annual funding for treatment were set at 0.5 million dollars, the variable budget 

analysis (Table 3-12) then shows that inventoried invasive plants might never be fully managed. 

Treatments would fall behind the rate of spread. By comparison, the total cost analysis (Table 3-

9, undiscounted) shows that it would take about 7.3 million dollars up front to treat all 13,000 

acres in five years. 
Final Environmental Impact Statement 

3-68

Early Detection/Rapid Response Strategy 

If new invasive plant populations are detected, the cost per acre for treatment would generally be 

the same as for proposed treatment areas. If new populations or new species are discovered while 

the infested areas are still small; however, the areas might be controlled with aggressive 

treatments in one year. In that case, treatment cost would be less because it would not take five 

years of integrated treatments to fully manage the areas. For small, newly-established 

populations in the Proposed Action, (using only year one treatment costs and the cost for 

inventory/monitoring and restoration) the average cost per acre would be $256. This compares to 

the average annual cost of $324 per acre to treat inventoried areas. For the Restricted Herbicide 

Use Alternative, the year one treatment regime applied to small, newly-established areas would 

cost an average of $410 per acre compared to $541 per acre to treat inventoried areas. There is 

no EDRR in the No Action Alternative. 

The cost of treating 30,000 acres of invasive plants was estimated based on these per acre cost 

assumptions. The 30,000 acre figure includes 17,000 acres of EDRR treatment acres (the most 

that would be treated in this project) added to the 13,000 proposed treatment acres in both action 

alternatives. The cost was estimated for both newly-discovered, small populations ($256/acre 

and $410/acre for the Proposed Action and Reduced Herbicide Use Alternative, respectively). It 

was also estimated for newly-discovered, large populations ($324/acre and $541/acre for the 

Proposed Action and Reduced Herbicide Use Alternative, respectively). The results of these 

calculations, shown in Table 3-13, indicates that rapid response to new invasive plant 

populations would not change the ranking of the alternatives relative to cost.. 

Table 3-13: Total costs for action alternatives to treat 13,000 acres of proposed invasive 

plant populations and 17,000 EDRR acres assuming both large and small newlydiscovered invasive plant populations in the Forest and the Scenic Area (assumes 4% 

discount rate). 

EDRR Scenario 

Alternative 2 – 

Proposed Action 

Alternative 3 – 

Restricted Herbicide Use 

Small newly-discovered populations. 8,593,724 14,144,985 

Large newly-discovered populations. 9,720,000 16,230,000 

Cumulative Effects 

The Chief of the USDA Forest Service calls invasive plants one of the four chief threats to 

National Forest System lands. As such, the USDA Forest Service is planning aggressive 

programs to treat invasive plants nationwide. Many forests, such as those in the Intermountain 

West, currently have more serious invasive plant problems than the Forest and Scenic Area. 
Site-Specific Invasive Plant Treatments 

3-69

The cumulative economic effect of this widespread and serious problem would be intense 

competition for limited funds at all governmental levels. The USDA Forest Service currently 

spends roughly 4.8 million dollars annually treating about 25,000 acres of invasive plants on 

National Forests in the Pacific Northwest (2005a). The competition among National Forests for 

limited appropriated federal funds for treatment programs would likely be great. Likewise, 

potential partner agencies in county and state government may be overwhelmed with requests for 

funding assistance. The total cost of all such programs has not been quantified since most forests 

have not yet solidified plans for their newest treatment programs. Nevertheless, funding would 

likely be a major limiting factor in the effective implementation of aggressive invasive plant 

treatment decisions throughout the Pacific Northwest. 

Oregon Department of Agriculture and Oregon Counties currently spend more than four million 

dollars annually to manage invasive plants. A January, 2001 report entitled Oregon Noxious 

Weed Strategic Plan recommends that this spending be increased by an additional 5.2 million 

dollars annually from state and local sources. The same report recommends that spending by all 

federal agencies in Oregon be increased by 7.2 million dollars per year to adequately implement 

invasive plant control programs on federal lands in Oregon (ODA, 2001). 

Currently, the average, annual cost per acre for treating invasive plants in the Pacific Northwest 

is $195 (2005a). The average cost per-acre cost to treat invasive plants for both the Proposed 

Action and the Reduced Herbicide Use Alternative is considerably higher than the current 

regional average. It is reasonable to assume that when other forests solidify their treatment plans, 

their average per-acre costs may also exceed the current average. 

As the demand for treatment services rapidly increases, and overwhelms the supply of available 

treatment providers, supply and demand suggests that there would likely be a short-term increase 

in treatment costs until more providers become available. 

3.7.3. Jobs Created Analysis 

The Restricted Herbicide Use Alternative would create the equivalent of about 159 jobs. This 

alternative would create the most jobs because of its greater use of manual and mechanical 

treatment methods and because of a higher level of site restoration (see Appendix T which 

displays the job estimate calculation). Also, the Restricted Herbicide Use Alternative minimizes 

the use of truck mounted application of herbicides relying instead on more labor-intensive hand 

applications. 

The Proposed Action would create the equivalent of about 94 jobs. The predominant herbicide 

application method in this alternative is broadcast herbicide applications methods (e.g., truck or 

ATV mounted boom), a less labor-intensive method. Also, there are fewer acres of site 

restoration. 

The No Action Alternative would create the equivalent of about 38 jobs. This smaller number is 

chiefly due to fewer acres being treated. 
Final Environmental Impact Statement 

3-70

Table 3-14 compares the cost of labor, wage income, and number of jobs created by the three 

alternatives. All job estimates use a ratio of one job equals $20,000 in wage income per year. 

Although actual annual wage income per job varies, this ratio provides a constant index for the 

evaluation of alternatives. As described in Section 3.7.1, most of the jobs created are low-wage, 

physically-demanding work, typical of manual agriculture and forestry jobs. They are seasonal 

positions with little, if any, job security. Few workers expect to earn $20,000 per year at these 

jobs, so the actual number of jobs created may be higher. 

Table 3-14: Labor Cost, Wage Income, and Potential Job Estimates for Invasive Plant 

Treatments in the Forest and Scenic Area. 

Alternative Labor Cost Wage Income Jobs @$20k/Year 

No Action $960,680 $768,544 38 

Proposed Action $2,352,572 $1,882,058 94 

Reduced Herbicide Use $3,982,469 $3,185,975 159 

Early Detection/Rapid Response Strategy 

On average, the treatments prescribed in the Proposed Action would create the equivalent of one 

$20,000/year job for every 138.3 acres treated. For the Restricted Herbicide Use Alternative, the 

equivalent of one $20,000/year job would be created for every 81.8 acres treated. Table 3-15 

shows the number of jobs that might be created by treating 30,000 acres of invasive plants: the 

13,000 treatment acres in the Proposed Action and in the Reduced Herbicide Use Alternative 

plus the maximum EDRR of 17,000 acres. The calculations assume that newly-discovered 

populations are large and require the same aggressive treatment prescription described in 

Appendix S. If newly-discovered populations are small, and treatment is less complex, then 

fewer jobs would be created. There is no EDRR in the No Action Alternative. 

Table 3-15: Jobs created (equivalent to $20,000 per year) by the Proposed Action and the 

Reduced Herbicide Use Alternatives with EDRR for the Forest and Scenic Area. Assumes 

the maximum EDRR = 17,000 acres and newly-discovered invasive plant populations are large. 

Alternative Jobs/Acres Treated Ratio Jobs @$20k/Year 

Proposed Action 1/138.3 217 

Reduced Herbicide Use 1/81.8 367 
Site-Specific Invasive Plant Treatments 

3-71

Cumulative Effects 

Government officials estimate that invasive plant control occurs on over 1,250,000 acres in 

Oregon and Washington, and more than 90 percent of this control is through the use of 

herbicides (based on informal discussions with state and county agriculture and noxious weed 

personnel). These data suggests that the broader regional treatment program looks more like the 

Proposed Action than the Restricted Herbicide Use Alternative. If this is true, then invasive plant 

control in the region creates roughly 8,038 jobs annually (applying the average of one $20,000 

job equivalent for every 138.3 acres treated). If the treatment regimes throughout the region 

mimic the Restricted Herbicide Use Alternative (average of one $20,000 job equivalent for every 

81.8 acres treated), then about 15,281 jobs would be created annually. 

3.7.4. Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action 

and Restricted Herbicide Use Alternatives are consistent with all relevant standards and 

guidelines, when the proposed amendments are incorporated. The Forest Plan amendments are 

discussed in Section 3.16. 

3.7.5. Incomplete and Unavailable Information 

The magnitude of funding needs for treating invasive plants Region-wide has not been quantified 

since most National Forests have not yet solidified plans for their newest treatment programs. 

No data is available to ascertain the economic value of special forest products harvested from the 

Forest or Scenic Area. 

3.8. Soil Productivity 

3.8.1. Existing Conditions 

Soils across the analysis area are quite variable, each with numerous management ratings such as 

erosion risk, compaction hazard, etc. Management ratings logically follow the variability of the 

soils themselves, with some soils mapped with a high erosion risk, others with low, and many in 

between. Although ratings are an adequate analysis tool, in actuality almost any soil regardless of 

rating can become highly erosive under the right (or wrong) circumstances. Low erosion risk 

soils that are compacted and bare can become highly erosive on even the slightest slope. 

Conversely, highly erosive soils, such as the volcanic ash derived ones on the Forest, are stable 

for decades because of sufficient protective groundcover (tree needles, leaves, wood, etc.). 

Generally, the soils in the proposed treatment areas on the Forest and Scenic Area are of 

relatively low fertility and once disturbed tend to be invaded by plant species that tolerate low 

fertility sites, especially the invasive plant species listed in Table 2-3. 
Final Environmental Impact Statement 

3-72

 The most productive areas of a given ecotype tend to be riparian zones because of water 

availability and naturally common accumulation of soil organic matter, and this holds true across 

the Forest and Scenic Area. As illustrated on the proposed treatment areas map (Figure 2-1), 

there are numerous riparian areas as well as uplands that have been impacted by the invasion of 

non-native plants. Although they provide some groundcover, many invasive plants generally 

tend not to have a desirable fibrous root system found in most native grasses and forbs. Fibrous 

root systems tend to provide more effective erosion control compared to tap-rooted plants, such 

as knapweed species. The major exception to this is knotweed species, which produces an 

extremely fibrous, difficult to eradicate root system. For this EIS the main soil resource concerns 

are effects on erosion, impacts to soil biology, and potential for herbicides to leach through the 

soil profile and into groundwater. 

The productivity and health of the plant community depends on the maintenance of healthy soils. 

Regional soil productivity protection standards were originally implemented in 1976 and have 

been revised several times since then (Pacific Northwest Region Monitoring and Evaluation 

Report, 2001). Areas of reduced soil productivity, which are the result of past land management 

activities and subsequent invasion of non-native plants have been identified and restoration 

projects are being proposed and implemented. Restoring ecological function to soil systems 

affected by invasive plants are high priority. Due to soil restoration activities, the productive 

potential of soils on the Forest and Scenic Area are improving in small specific locations. 

However, overall productivity is threatened in increasingly large areas because of the rapid 

upward trend and potential for increasing spread of invasive plants. 

3.8.2. Analysis Area, and Applicable Standards and Guidelines 

The analysis area for soils in this EIS is the Forest and Scenic Area boundaries. No soil specific 

standards are in place for the Scenic Area, so the Forest Plan standards and guidelines will apply 

for this analysis. A relative comparison of alternatives will be conducted using two Forest Plan 

standards (Table 3-16) and risk of herbicide leaching as guidance to address specific concerns 

and as a basis for risk of subsequent impacts such as sedimentation, impacts to aquatic 

organisms, etc. 

• Erosion Hazard: Two possible impacts stemming directly from soil erosion are runoff 

that carries herbicide with it into watercourses, and runoff from bare areas carrying 

sediment that impact watercourses. This hazard rating is based upon bare surface soils 

coupled with a particular soils’ texture, slope, etc. 

• Soil Biology: Poor or non-functioning soil biological systems may lead to difficulties in 

revegetation efforts, or decline in existing desirable vegetation. In and of itself, soil 

biology is extremely difficult to evaluate because of infinitely complex interactions 

occurring between organisms and their physical (soil) environment, including soil 

physical and chemical characteristics. It is assumed that soil biological systems would 

properly function given certain habitat components are present, such as non-compacted 

soils, appropriate levels of organic matter, and types of native vegetation under which the 

soil developed. 
Site-Specific Invasive Plant Treatments 

3-73

• Leaching Risk: No Forest Plan standards directly address this concern. However, using 

a combination of soil and herbicide characteristics with existing scientific studies there is 

sufficient information to compare this risk by the type of herbicide proposed. There are 

two aspects regarding leaching and herbicides – the potential to contaminate groundwater 

(i.e. wells), and the potential to contaminate surface water through groundwater 

movement into streams, springs, etc. 

Table 3-16: Forest Plan Soil Standards guiding the soils analysis. 

FW – 025 

(Page 4-49) 

In the first year following surface disturbing activities, the percent effective 

groundcover by soil erosion hazard class should achieve at least the following 

levels: 

Soil Erosion Hazard Class Effective Groundcover 

Low to Moderate 60% 

Severe 75% 

Very Severe 85% 

FW – 032 

(Page 4-50) 

Favorable habitat conditions for soil organisms should be maintained for short 

and long-term soil productivity 

Leach Risk A relative rating is located in the body of this section 

This analysis is risk-based. It is not meant to be interpreted that ‘more soil erosion would occur’ 

with a particular alternative versus another, but the relative risk of erosion occurring may be 

higher with one alternative versus another. 

3.8.3. Direct/Indirect Effects: Alternative 1 – No Action 

This section examines the effects that invasive plants have on soils, not effects from any of the 

proposed treatments. The majority of the following information in this section comes from the 

Invasive Plant FEIS (2005a), and illustrates the risk of negative soil impacts that could be 

expected from the No Action Alternative. 

Invasive plants could have negative effects on soil properties. Invasive plants may increase the 

proportion of bare ground, increase or decrease the amount of organic matter in the soil, deplete 

the soil of nutrients or enrich the soil with certain nutrients, change fire frequency, and produce 

toxic herbicides that affect soil organisms. Some of these changes may be difficult to reverse and 

could lead to long-term soil degradation and difficulty in re-establishing native vegetation. 
Final Environmental Impact Statement 

3-74

• Soil Moisture: Knapweed species are widespread on the eastern half of the Forest and 

Scenic Area in dryer ecotypes. Lacey, Marlow and Lane (1989) found that rangelands 

infested with spotted knapweed had more bare ground than natural bunchgrass/forb 

grasslands. In a simulated rainfall test, they found that soil erosion more than doubled in 

knapweed-dominated areas when compared to uninfested areas. They also found 

significantly lower infiltration rates in the knapweed sites. Even modest losses of the soil 

surface could have large impacts on soil functioning, since most of the biologically active 

organic matter is concentrated in the top 1 to 4 inches of soil. Soil erosion also has 

negative impacts on water quality in associated aquatic systems and the reduction of 

infiltration decreases groundwater recharge. 

Tyser (1992) also observed low canopy cover of native forbs and low cryptogam cover in 

stands invaded by spotted knapweed. Any increase in bare ground caused by invasive 

plants could have negative effects on soil moisture content. During rainfall events, more 

rain runs off as surface flow. In dry periods, soil is directly exposed to solar radiation and 

dries out faster. A dry soil surface hinders seedling establishment and would negatively 

impact plants with surface root systems, such as many native grasses. Exposure of the 

soil surface causes soil temperatures to be more extreme, due to solar heating during the 

day and greater radiative cooling at night. These extreme temperatures make seedling 

establishment more difficult and may affect soil organisms (Sheley and Petroff, 1999). 

There are small patches of soil crusts present on the very southeast corner of the Forest in 

the vicinity of Rock Creek. These very small areas have survived the invasion of invasive 

plants (knapweed primarily), heavy off-highway vehicle use, and grazing. It is likely 

these areas were more extensive before these disturbances occurred. Although there is no 

specific monitoring as to the actual amount and trend of soil crusts, it is a logical 

assumption that these areas are declining and would continue to do so given the 

continuous impacts that occur in the area on annual basis. 

• Soil Nutrients and Nutrient Cycling: One function of soil is the cycling of nutrients 

from dead organic matter into forms that are available to plants. This nutrient cycling is 

essential for the health and productivity of the ecosystem. Nutrient cycling is a complex 

process that depends on a multi-level food web that is specific to the site. Biota involved 

in nutrient cycling includes bacteria, actinomycetes, fungi (pathogenic, saprobic, and 

mycorrhizal), amoebas, and a wide range of invertebrates. Since this entire system is 

powered by root exudates and decomposing vegetation from the plant community, 

changes in plant communities caused by non-native invasion could have large effects on 

the soil food web (Hobbie, 1992; Van der Putten, 1997). 

A study that compared soil organisms in native grasslands in a natural state and after 

invasion by cheat grass (Bromus tectorum, also found on the eastern side of the Forest 

and Scenic Area), found that the cheat grass caused changes in most levels of the soil 

food web (Belnap and Phillips, 2001). Although it is difficult to predict the specific 

effects of these changes, it is important to recognize that any change in the soil food web 

has the potential to interfere with critical nutrient cycling processes and to threaten the 

long-term integrity of the ecosystem. 
Site-Specific Invasive Plant Treatments 

3-75

A study found pronounced differences in soil properties when soil under exotic 

understory plants was compared to soil under native shrubs (Ehrenfeld, et al., 2001). Soil 

pH was significantly higher under the exotic plants, as was extractable nitrate. Net 

nitrogen mineralization was also higher under the exotic plants, indicating changes in the 

composition or activity of soil microbes caused by the invasive plants. Over time, these 

changes may have effects on the ecosystem as a whole. Many invasive plants establish 

more readily on sites with high nutrient availability. Invasive plants that increase the 

availability of nitrate in the soil may be promoting conditions that favor their own 

expansion at the expense of native plants that tolerate low nutrient levels. For example, 

increases in soil nutrient levels have been shown to favor the invasion and success of 

non-native species in a serpentine soil ecosystem where resources were limited 

(Huenneke, et al., 1990). 

On the other hand, many non-native species deplete soil nutrients. Spotted knapweed has 

been implicated in reducing available potassium and nitrogen (Harvey and Nowierski, 

1989). A reduction in soil nutrient levels makes it difficult for native plants to compete 

with the invasive plants, and probably also affects the soil biotic community. The longterm effects of these changes are not known. 

• Soil Organisms: Some invasive plants are allelopathic to other plants, and may produce 

secondary compounds that affect soil organisms. If an invasive plant produces a 

secondary compound, the population of soil microbes that could metabolize this 

compound would increase, while the populations of other microbes would decrease 

(Sheley and Petroff, 1999). These changes would affect the soil food web and nutrient 

cycling, and may have impacts on the native plant community. 

One group of soil organisms that is of particular concern is mycorrhizal fungi. These 

fungi form a mutualistic relationship with plants in nearly all ecosystems and are critical 

in supplying water and nutrients to plants, as well as protection from root pathogens. 

Mycorrhizal fungi also play an important role in creating soil structure, particularly in 

young or poorly developed soils. Mycorrhizal fungi could produce more than 600 feet of 

hyphae per gram of forest soil. This mass of hyphae binds soil particles together, 

stabilizing the soil system. Mycorrhizal fungi also produce polysaccharides that bind soil 

particles into aggregates. These aggregates increase the water holding capacity of the soil, 

improve oxygen penetration into the soil, and provide microsites for the normal 

development of communities of bacteria, actinomycetes, and amoebas. Mycorrhizal fungi 

appear to mediate the transfer of sugars and nutrients from one plant to another. This 

function may be important in maintaining diversity in the plant community and in the 

recovery of the plant community after disturbance. The fruiting bodies produced by some 

mycorrhizal fungi are an important food source for a variety of animals, from 

invertebrates to large mammals. More than 70 percent of the diet of some small 

mammals, including the northern flying squirrel, consists of fruiting bodies of 

mycorrhizal fungi. 
Final Environmental Impact Statement 

3-76

Research on the impact of invasive plants on mycorrhizal fungi is lacking, but since 

plants and mycorrhizal fungi are strongly dependent on each other, it seems likely that 

drastic changes in the plant community caused by the invasion of non-natives would be 

accompanied by changes in the mycorrhizal fungus community. Sylvia and Jarstfer 

(1997) compared the mycorrhizal status of young slash pines (Pinus elliottii var. elliottii) 

in plots with invasive plants and plots that were kept invasive plant free with herbicide 

treatment. After 3 years, the number of pine root tips colonized by mycorrhizal fungi was 

75 percent lower in the invasive plant plots than the invasive plant free plots. In addition, 

the species distribution of the mycorrhizal fungi associated with the trees had changed. 

In the Sylvia and Jarstfer (1997) study, the invasive plants were associated with different 

fungi than the trees. It is likely that competition from these introduced fungi caused the 

decrease in the fungi associated with the trees. If mycorrhizal fungi associated with 

invasive plants successfully compete with native fungi a redistribution of soil resources in 

favor of the invasive plant would occur. In addition, species of mycorrhizal fungi 

associated with native plants may be lost from the area of infestation. It may then be 

difficult to re-establish native vegetation on the site after the invasive plants are removed. 

Researchers have found that specific “helper” bacteria in the soil promote the 

establishment of mycorrhizae and mycelial growth of mycorrhizal fungi (Garbaye and 

Bowen, 1989). Although little is known about the ecological requirements of these 

organisms, invasive plants may not support the helper bacteria employed by native plants 

and fungi. 

Conclusion - Alternative 1 

• Erosion Hazard: A chronic, slow increase in exposure of bare soil and associated soil 

erosion risk is expected with this alternative as native vegetative cover is replaced by the 

poor cover provided by many invasive plants. Although this alternative employs the same 

types of control measures as the other alternatives, they are inadequate to keep up with 

the rate and spread of invasive plants. 

• Soil Biology: Without treatment, invasive plant infestations are likely to cause significant 

changes to the physical, chemical, and biological properties of soils where the infestation 

occurs. In some cases, it may be difficult to reverse these changes and restore normal soil 

functions. This legacy of disrupted soil function may increase the effort required to 

restore native vegetation long after invasive plants are removed. Therefore, it is a more 

desirable situation to keep native plants on site so that natural interactions can occur 

within soil chemical, physical and biological processes. 

• Leaching Risk: The risk of leaching would remain unchanged, assuming existing 

environmental documents and identified PDC for current herbicide applications are 

followed. 
Site-Specific Invasive Plant Treatments 

3-77

In summary, evidence and observation show invasive plants can degrade existing non-disturbed 

sites; keep disturbed, degraded sites in poor condition; or occupy disturbed sites on a temporary 

basis and eventually get pushed out by native vegetation. In many cases, the problem is not 

necessarily the invasive plant itself, but the soil disturbance that allows invasive plants into a site 

to begin with, which makes EDRR an important tool to treat new sites as they occur. 

3.8.4. Direct and Indirect Effects: Alternatives 2 & 3 – Proposed Action and 

Restricted Herbicide Use Alternatives 

Manual Treatment 

Removal of plant roots would break mycorrhizal hyphae in the soil and probably cause a 

transient reduction of mycorrhizal function. Studies on crop plants have shown that leaving an 

undisturbed mycorrhizal network in the soil after harvest (e.g. zero-till agriculture) significantly 

increases the nutrient uptake of the subsequent crop (Evans and Miller, 1988 and 1990). 

Establishment of native plants may be more successful on undisturbed soil. 

In lower intensity infestations, non-target vegetation could provide erosion control. Manual 

treatments, such as lopping or shearing, that remove the aerial parts of invasive plants would 

cause an input of organic material (dead roots) into the soil. As the roots are broken down in the 

soil food web, nutrients would be released. 

The risk of harm to soils from manual treatment is low. 

Mechanical Treatment 

Using mowing equipment on existing roads is not expected to impact soils. Mowing equipment 

used off established roads has the potential to compact soil. Soil compaction eliminates soil 

pores, and reduces water infiltration, aeration, and the ability of plants to root effectively. Due to 

the limited amount of mechanical treatment proposed, this is not expected to create significant 

soil impacts. Other mechanical treatments, such as the use of motorized hand tools, are expected 

to have effects similar to manual treatments. 

Cultural Treatment 

In this proposal, goats would be used to control blackberry in the Sandy River Delta. No adverse 

soil impacts are foreseen due to the highly resilient nature of this area, especially considering the 

substantial disturbance history. 

Herbicide Treatments 

The effect of an herbicide treatment on the soil depends on the particular characteristics of the 

herbicide used, how it is applied, and soil physical, chemical and biological conditions. 
Final Environmental Impact Statement 

3-78

• Erosion Hazard: Mt. Hood Forest Plan FW-025 – Effective Groundcover: On sites 

where effective groundcover levels are below the standard, vegetation must be 

established quickly on sites where invasive plants have been removed to minimize the 

erosion hazard. In some cases, meeting this Standard is the responsibility of the project 

that is actually causing the disturbance. All alternatives rely on different combinations of 

the proposed treatment methods. The Proposed Action and Restricted Herbicide Use 

Alternatives are beneficial to soils, since these alternatives have flexibility in treatment 

methods, which allows effective treatments and prevents further spread and subsequent 

degradation of soils due to the presence of invasive plants. These degraded conditions are 

described above in the Alternative 1 – No Action Alternative section and include: loss of 

soil, drying of soil, changes in soil chemistry, changes in soil biota, and changes in 

nutrient cycling processes. In general, alternatives (No Action and Restricted Herbicide 

Use Alternatives) that would restrict treatment result in fewer acres of invasive plants 

being successfully treated. Areas infested with invasive plants would continue to remain 

in a degraded condition. 

Further, many of the proposed herbicides are identified as a risk for runoff in clay soils. 

In the analysis area east of the Cascade crest, exposed clay surface soils are uncommon 

and occur in some roadcuts or wet meadow areas where no application or very restrictive 

PDC would apply. Therefore, the risk of runoff is very low east of the Cascades. West of 

the Cascades, clay subsoils are commonly exposed in roadcuts, so the risk of runoff 

would be higher. However, the overall risk of runoff from a clay surface in either 

scenario is still quite low given the PDC for weather conditions, time of year sprayed, 

and other surface covering materials such as rock and organic matter that slow down 

runoff. 

• Soil Biology: Mt. Hood Forest Plan FW-032 – Soil Organisms: Soil organisms are 

important to the human environment because they could affect soil productivity. None of 

the herbicides under consideration has notable effects to overall long term soil 

productivity or permanent impairment of soil ecosystems. In addition, the other treatment 

methods (cultural, manual, and mechanical) are much more unlikely to incur detrimental 

soil impacts of any substantial size. Information about specific herbicide effects to each 

of the myriad of soil organisms is scarce. For example, one study may examine the use 

and effect of a particular herbicide on soil bacteria, while another study examines the use 

of different herbicides on the soil invertebrate population. There is no study or set of 

studies that examines the impacts of different herbicides on each and every aspect of soil 

biology. Much of the research is based on indirect effects such as changes in persistence 

or metabolism of nutrients. The observed changes may mean a temporary depression in 

the activity of existing soil organisms, or could signal a complete change in the 

organisms present. In addition, while a few of the studies could be applied directly to 

conditions found locally, the majority of them are not specific to local ecosystem 

conditions. 
Site-Specific Invasive Plant Treatments 

3-79

Although this information is useful, it would cause uncertainty in the predicted effects (i.e., 

lower confidence) if the proposed herbicide treatments were in large, continuous, blocky 

acreages. The areas, however, proposed for herbicide applications are in specific spots or narrow 

bands, such as along roadsides that result in very localized effects. 

All alternatives, including the No Action Alternative, allow the use of herbicides in treatment of 

invasive plants. Although picloram and sulfometuron methyl are of particular concern due to 

toxicity to soil microorganisms and persistence (picloram only) in soil, all herbicides have some 

evidence of temporary effects to soil microorganisms. The known effects on soil organisms from 

the individual herbicides proposed for use in the Proposed Action and Restricted Herbicide Use 

Alternatives are presented in Table 3-17. It is likely that all herbicide treatments would have 

some effect on soil biota, but these effects would be more or less transitory depending on the 

timing, frequency, and herbicide used. The known effects of herbicide treatments on soil would 

be weighed against the effects of invasive plants on soil that result from no treatment or less 

effective treatments. All herbicides could persist under some circumstances related to soil 

texture, organic matter content, and soil moisture level, among others. All action alternatives 

include a site by site long-term strategy for restoring infestations of invasive plants (See Section 

2.1.3 on site restoration; See Section 3-6 – Botany and Treatment Effectiveness), which 

necessarily includes protecting or improving soil productivity and conditions for soil 

microorganisms. Successful restoration of native vegetation to areas infested with invasive plants 

is dependent, in part, on healthy soil organisms. Negative effects to soil organisms and soil 

productivity could complicate restoration and could delay restoration of native vegetation for a 

year or more. 

Table 3-17: Effects of Herbicides on Soil Organisms. 

Herbicide Effects 

Chlorsulfuron Growth inhibition for some fungi at >10,000 times the maximum application rate. Effects 

to soil nitrification (SERA, 2004a) 

Clopyralid No effect on nitrification, nitrogen fixation, or degradation of carbonaceous material at 

1-10 ppm (parts per million) in soil (SERA, 2004b) 

Glyphosate Readily metabolized by soil bacteria. Substantial information indicating it is likely to 

enhance or have no effect on soil microorganisms. One study showed transient 

decreases in the populations of soil fungi and bacteria (SERA, 2003a) 

Imazapic No information. (SERA, 2004c) 

Imazapyr Toxic to some bacteria at relatively high concentration (SERA, 2004d) 

Metsulfuron 

methyl 

At high surface application rates, decreases in soil bacteria were seen for 3 days, but 

reversed completely after 9 days (SERA, 2004e) 

Picloram Toxic to some soil organisms, even at low levels. Increasing persistence with 

increasing application rates. Most toxic at low pH levels (SERA, 2003b) 

Sethoxydim No effect on mixed bacterial populations at 50 ppm in soil. At 1000 ppm, substantial but 

transient increases in actinomycetes and bacteria, and slight decreases in various 

fungi. Azobacter in culture showed no inhibition until 5000 ppm (SERA, 2001b) 

Sulfometuron 

methyl 

Toxic to soil microorganisms. Microbial inhibition is likely to occur and could be 

substantial. Soil residues may alter composition of soil microorganisms (SERA, 2004e) 

Triclopyr One study showed inhibition of mycorrhizal fungi only at high (1000 ppm) levels, 

another study showed inhibition of one mycorrhizal fungus at 0.1 ppm. Expected levels 

in soil would be well below effect levels for most mycorrhizal fungi (SERA, 2003c) 
Final Environmental Impact Statement 

3-80

• Leaching Risk: Factors that determine the fate of herbicides in soil include mobility, 

degradation, and solubility. Herbicide degradation over time is a result of physical and 

chemical processes in soil and water. Herbicide fate in soil is determined by herbicide 

characteristics such as adsorption, solubility, degradation, and volatility. Soil 

characteristics such as organic matter, pH, temperature, moisture content, clay content, 

and microbial degradation are important in the fate of herbicides. Degradation rates 

generally decrease with increasing soil depth and decreasing temperatures. General 

characteristics for the proposed herbicides are displayed in Table 3-18, with more 

detailed information by herbicide contained in Appendix U. Herbicides are listed in order 

of most leach risk to least. 

As the table indicates, some of the proposed herbicides are highly soluble in water. Generally 

this is often taken as an indicator of the mobility of the herbicide in water with few exceptions. 

Glyphosate, while having a high solubility, also binds tightly with soil particles, because of this it 

has very low mobility. Herbicides with high mobility potential and long half-lives have a greater 

potential for leaching into near surface or ground water, if present. All listed herbicides would be 

expected to have higher adsorption, and lower solubility and half- life than shown in Table 3-18 

due to the inherent soil ecological systems found within the Forest and Scenic Area. Therefore, 

persistence and leaching potentials are some level lower than listed in the table, which was 

constructed by ranking measured levels of adsorption, persistence, and solubility for each 

herbicide against each other (a relative ranking) in order to display less technical and more 

understandable results. Examining each of the three ranked criteria together for each herbicide 

indicates the highest leach risk herbicides are picloram, chlorsulfuron, and imazapyr. Herbicides 

with the lowest risk for leaching appear to be sethoxydim, triclopyr, and glyphosate. 
Site-Specific 

3-81

Table 3-18: Relative Ranking of Herbicide Characteristics and Influencing Factors on Soil Properties. ModRisk Assessments (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f).

Herbicide 

Soil Mobility 

Factors Increasing Adsorption 

Soil Persistence 

Factors Decreasing Halflife Solubility Fa

So

Picloram High Increasing organic 

matter and clay content 

Moderate Decreasing application rate 

and increasing soil depth 

Very High 

Chlorsulfuron Moderate Increasing organic 

matter and low clay content 

Moderate Decreasing pH, increasing 

organic matter and temperature 

High De

Imazapyr Low Increasing organic 

matter and clay content, decreasing pH (<6.5) and moisture; and time 

Moderate Increasing light, soil 

microbial activity 

ModerateHigh 

Clopyralid High Low Increasing moisture Low Imazapic Low Increasing organic 

matter and clay content; and decreasing pH 

Moderate Increasing microflora High De

Metsulfuron methyl 

Moderate Increasing organic 

matter content 

Moderate Increasing microbes LowModerate De

Sulfometuron methyl 

Moderate Humic acid content Low-Moderate Decreasing particle size Low De

Sethoxydim Low Increasing organic 

matter 

Low LowModerate De

Triclopyr Moderate Increasing organic 

matter and clay content 

Low Increasing moisture and 

temperature 

Low 

Glyphosate Very Low Metallic cations Low ModerateHigh Af
Final Environmental Impact Statement 

3-82

An analysis of soil characteristics using the Mt. Hood Soil Resource Inventory (SRI) was 

conducted to sort which soils would be of lowest risk to soil organism toxicity and leaching 

when picloram or sulfometuron methyl are applied. It was discovered that there are only two 

main soil types that do not exhibit the increased risk attributes of soil texture, coarse fragment 

content, and/or pH. When soils in the SRI are identified as acidic (pH less than 6.9), or have the 

potential for high percolation rates, then they are recognized as a higher risk for soil organism 

toxicity or leaching. Potential for high percolation rates occurs with soil textures coarser than 

loam (i.e., sandy loam and loamy sands), or any texture with greater than 20 percent coarse 

fragments (i.e., gravel, cobble). The only soil types not meeting either of the two criteria are 153 

and 156, which are both on the far eastern side of the analysis area, and identified in blue in 

Figure 3-4. These soils (153 and 156) are wind deposited loamy soils that are located in dryer, 

more open stands of trees with grass and forbs in the understory, which result in more neutral pH 

levels. The entire remainder of the analysis areas exhibits acidic pH or relatively high percolation 

rates. Treatment areas identified as roadside, regardless of soil type, would be of lesser concern 

for picloram or sulfometuron methyl herbicide applications due to the amount of ground 

disturbance already present. It is extremely likely that significant soil biological systems have 

been and continue to be disrupted in these long, linear roadside areas. 

Conclusion - Alternatives 2 and 3 

• Erosion Hazard: There would be a net reduction in soil erosion risk from treated areas 

in the Proposed Action and Restricted Herbicide Use Alternatives when each site’s 

restoration plan is followed and effective (i.e., restored or temporary effective 

groundcover). A particular site’s effective groundcover level may actually decrease if the 

amount of vegetation lost from invasive plant eradication exceeds the success of 

restoration, which is why the implementation of each site’s restoration plan is critical. 

The use of herbicides would accelerate the eradication of invasive plants, allowing 

desirable native plants to occupy the growing space, which would then provide long-term 

soil stability and proper function. Based on personal visual observation of previous 

revegetation efforts (such as riparian and road obliteration projects) on totally denuded 

sites, few native plants occupied the site in the first year. Effective groundcover for the 

short-term is achieved with seed, mulch, or combination. By years five to ten, however, 

sites tended to recover with native plant recolonization, provided the temporary 

groundcover methods were effective. Some restoration sites on flat terrain actually 

received no follow-up seeding or mulching and had very good recovery of native plants 

and thus reduced the erosion hazard. 
Site-Specific Invasive Plant Treatments 

3-83

Figure 3-4. Map of Soil Distribution and Proposed Treatment Areas. 
Final Environmental Impact Statement 

3-84

• Soil Biology: Alternatives 2 and 3 treat the same amount of acres, but with drastically 

different strategy. The Proposed Action treats more acres and sites with herbicides, while 

Restricted Herbicide Use utilizes more non-herbicide treatments. Based on the existing 

condition and predicted rates of spread, added to the possible restoration, the Proposed 

Action would result in the most desirable impact on soils. Soil organism communities are 

likely impacted in some way whether a site is treated or not. Therefore, sites are either 

considered permanently degraded by invasive plants with no follow-up restoration, or 

temporarily impacted by herbicides (to some degree depending on which is used), 

followed by vegetative restoration. 

• Leaching Risk: Alternative 2 poses the highest leach risk strictly on an acreage treated 

basis because more acres are treated with herbicides. The risk would be substantially 

reduced by applicable PDC for application, weather conditions, etc. Table 3-18 above 

lists herbicides from highest leach risk to lowest, based on numerous factors. The risk of 

leaching enough herbicide to actually have measurable contamination of a well or surface 

water body is extremely low, even for the highest leach risk herbicides (picloram, 

chlorsulfuron, and imazapyr) due to dilution, precautionary PDC, and simply the lack of 

concentrated multiple applications in a small area that would show up later once 

sufficient amounts had leached from an application area to a monitoring location. 
Site-Specific Invasive Plant Treatments 

3-85

3.8.5. Alternatives Comparison 

The result of this analysis, which examines the impacts on soils from all proposed treatment 

methods for three alternatives, is summarized in Tables 3-19 and 3-20 below. 

Table 3-19: Specific Cause and Effect Concerns as Related to Analysis Standards and 

Guidelines. 

Analysis 

Element 

Cause and 

Effect 

Applicable Forest 

Service standard 

or finding 

Site-specific 

Consideration 

Process to Address 

Concern and Tie to 

PDC Table 

Effects of 

treatments on 

soil erosion 

Treatments have 

potential to cause 

soil disturbances 

that reduce 

surface cover, 

thus increasing 

soil erosion risk 

Mt. Hood Forest 

Plan FW - 025: 

Effective 

groundcover 

Loss of 

vegetation that 

results in 

elevated surface 

erosion potential 

Annually evaluate 

proposed treatment 

sites, review treated 

sites to determine if 

groundcover goals 

have been met, and 

ensure previous 

revegetation efforts 

are not damaged 

(PDC I.1) 

Effects on 

soil 

organisms 

Picloram and 

sulfometuron 

methyl are of 

concern due to 

toxicity risks. 

Mt. Hood Forest 

Plan FW – 032: 

Soil organisms 

Soil texture, soil 

pH 

Use other herbicides 

or treatment methods 

where soils are acidic 

(pH > 6.9) due to 

increased toxicity risk. 

Where these 

herbicides are used, 

no more than one 

application per year 

(PDC G.3 and G.4) 

Leaching 

potential 

Herbicide 

treatments may 

leach through the 

soil and into 

groundwater 

Concern, no 

standard or guide 

Soil texture, soil 

pH 

Use other herbicides 

or treatment methods 

where soils are 

coarser than loam, or 

exhibit > 20 percent 

coarse fragments, or 

pH is greater than 6.9 

(PDC G.3). Identify 

specific proposed 

spray areas annually 

for type of herbicide, 

soil texture and pH 

(PDC J.1), 
Final Environmental Impact Statement 

3-86

Table 3-20: Summary of Relative Impacts to Soils by Alternative. 

Alternative 

Acres of 

Proposed 

Herbicide 

Treatment 

Acres of 

Non -

Herbicide 

Treatments 

Soil Concerns: 

Erosion Hazard, Soil Biology, Leach Risk 

Overall, this alternative addresses soil concerns in the 

least positive way. The current and predicted future 

negative impacts on soils due to the spread of invasive 

plants outweigh the small amount of current 

eradication/control efforts. In addition, without EDRR, 

future infestations may be difficult to keep in check 

increasing the risk of future negative soil impacts. 

No Action 600 635 

This alternative addresses soil concerns in the most

positive way. The current and predicted future negative 

impacts on soils due to the spread of invasive plants is 

addressed by aggressively increasing eradication/ control/ 

containment efforts in a well thought out, sensitive manner. 

In addition to PDC to substantially reduce the risk of 

negative effects, the restoration plans for particular sites 

positively address the effective groundcover standard. With 

EDRR, future infestations could be addressed while they 

are small, reducing the risk of negative soil impacts by not 

treating. 

Proposed 

Action 

12,914 50 

Restricted 

Use 

Herbicide 

4,047 8,917 This alternative lies between the No Action and Proposed 

Action Alternatives. There may be sufficient positive 

impacts from treating the priority one sites to ‘neutralize’ 

the negative impacts from not treating other areas. 

3.8.6. Cumulative Effects 

The cumulative effects of an invasive plant infestation could be dramatic and irreversible. Soil 

lost to erosion may take centuries to replace. The loss of soil biota also could lead to degradation 

of soil properties that are not easily re-established. Changes in the soil biota could lead to 

changes in nutrient cycling that lead to a loss of nutrients from the ecosystem. Although very 

little research has been done on the restoration of soil biological communities, it stands to reason 

that large persistent invasive plant infestations would detrimentally effect the re-establishment of 

soil biota and native plant communities. Preventing the spread of invasive plants would have a 

positive impact on soils. 
Site-Specific Invasive Plant Treatments 

3-87

Cumulative effects of each alternative would be similar to its direct effects. Non-herbicide 

treatments may result in nutrient decrease, erosion, reduction in mycorrhizal hyphae, increased 

bare ground, and decreased litter layer, which transient effects are given revegetation with native 

or non-invasive species. Soil compaction, loss of microbiotic crusts, formation of hydrophobic 

surface layer on soil, and loss of volatized nitrogen, phosphorus and potassium may have longer 

term effects and need to be minimized or eliminated through site-specific PDC. Of these three 

components of this analysis (erosion, leaching risk, and soil organisms), the knowledge of the 

cumulative effects (defined as multiple applications to one site within a year, which would occur 

less frequently than single season applications) of herbicide application on soil biota is the most 

uncertain. Some herbicides are metabolized by soil bacteria, while others are toxic to soil 

microorganisms or no information about effects to these organisms is available, as described in 

Table 3-17 above. 

Picloram, chlorsulfuron, and imazapic are relatively water soluble and could move off-site in 

water. These herbicides are moderately adsorbed to soil particles and could be moved off-site 

with wind or mass soil movement. It is possible, but not likely, that they could be introduced to 

the Forest and Scenic Area from other sources, such as application(s) on adjacent ownerships. 

Movement of these herbicides to the Forest and Scenic Area is not expected to affect soil 

productivity, because most of the Forest and Scenic Area lands are upstream or upwind of other 

ownerships. It is more likely that these herbicides would move off the Forest and Scenic Area to 

the other ownerships below. Given the conclusions in the effects analysis, the occurrence of 

either scenario is very doubtful. 

As an example of perspective, the USDA Forest Service use of picloram is less than one percent 

of agricultural use (SERA, 2003b), while USDA Forest Service use of sulfometuron methyl 

nationwide is less than one percent of all use in California (SERA, 2004e). 

3.8.7. Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action 

and Restricted Herbicide Use Alternatives are consistent with all relevant standards and 

guidelines, when the proposed amendments are incorporated. The Forest Plan amendments are 

discussed in Section 3.16. 

3.8.8. Incomplete and Unavailable Information 

Information about specific herbicide effects to each of the myriad of soil organisms is not 

available. Much of the research is based on indirect effects such as changes in persistence or 

metabolism of nutrients. The observed changes may mean a temporary depression in the activity 

of existing soil organisms, or could signal a complete change in the organisms present. 
Final Environmental Impact Statement 

3-88

Soil organisms are important to the human environment because they could affect soil 

productivity, and none of the herbicides under consideration has notable effects to soil 

productivity. Hence, the unavailable information is insignificant in terms of providing a clear 

basis for choice between alternatives. 

3.9. Water Quality 

3.9.1. Existing Conditions 

Potential treatment areas are located in nearly every fifth-field watershed on the eastside and 

westside of the Forest and Scenic Area. The range of elevation, precipitation, and distance from 

treatment sites to streams is 25 to 5,400 feet, 10 to 120 inches, and zero to more than 2,000 feet, 

respectively. Site-specific information, including soils, slope, elevation, precipitation, distance to 

water, and landslide risk, about each potential treatment site is available in Appendix O – 

Existing Conditions Characteristics. 

Water Quality 

Surface and groundwater drinking water protection areas were delineated by the Oregon 

Department of Environmental Quality (DEQ) and Oregon Health Division (OHD) in response to 

source water assessments required by the 1996 Amendments to the federal Safe Drinking Water 

Act (SDWA). DEQ and OHD were required to delineate the groundwater and surface water 

source areas which supply public water systems, inventory each of those areas to determine 

potential sources of contamination, and determine the most susceptible areas at risk for 

contamination. Public water systems with greater than three hook-ups or serving more than 10 

people year-round are regulated by the requirements in the SDWA. 

Watersheds originating on the Forest supply high quality drinking water to approximately one 

million people in Oregon. There are eight drinking water protection areas including the City of 

Corbett, Portland, Estacada, The Dalles, various Clackamas River water providers (Oregon City, 

Lake Oswego), and the Timber Lake Job Corps (Table 3-21) on the Forest that contain proposed 

invasive plant treatment sites. There are no drinking water protection areas in the Scenic Area. 

The treatment areas located in each drinking water protection area are shown in Appendix V. 

Additional information regarding the potential effect of proposed invasive plant treatments on 

drinking water is located in Section 3-5 – Human Health and Safety. 
Site-Specific Invasive Plant Treatments 

3-89

Table 3-21: Proposed invasive plant treatment acres within drinking water protection 

areas. 

Drinking Water Protection Areas 

Drinking Water 

Source Clackamas Corbett Estacada Portland 

Timber1

Lake Job 

Corp 

The 

Dalles 

Grand 

Total

Bull Run 1.4 1.4

Clackamas River 

(Estacada) 1,350.0 1,350.00

Clackamas River 3.4 3.4

Dog River 0.1 0.1

Frog Lake 122.3 122.3

North Fork Gordon 

Creek 48.3 48.3

South Fork Gordon 

Creek 12.6 12.6

South Fork Mill 

Creek 24.9 24.9

Total 3.4 60.9 1,350.0 1.4 122.3 25.0 1,562.8 1

 Frog Lake is a back-up water source for the Timber Lake Job Corp. The primary water source is a well. 

Clean Water Act 

Rivers, streams, and lakes within and downstream of the treatment areas are used for boating, 

fishing, swimming, and other water sports. Additionally, the Forest and Scenic Area streams 

provide habitat and clean water for fish and other aquatic biota, each with specific water quality 

requirements. The Clean Water Act (CWA) protects water quality for all of these uses. 

The CWA requires States to set water quality standards to support the beneficial uses of water. 

The Act also requires States to identify the status of all waters and prioritize water bodies whose 

water quality is limited or impaired. For Oregon, the DEQ develops water quality standards and 

lists water quality limited waters. In addition, Region 6 of the Forest Service has entered into a 

Memorandum of Agreement (MOA) with the Oregon State DEQ to acknowledge the FS as the 

Designated Management Agency for implementation of the CWA on National Forest land. In an 

effort to support the CWA, the Forest and Scenic Area conduct a variety of monitoring and 

inventory programs to determine status of meeting state water quality standards as well as other 

regulatory and agency requirements. In an average year, approximately 75 sites are monitored 

for water temperature throughout the Forest and Scenic Area. In addition, other water quality 

monitoring occurs at various locations throughout the Forest and Scenic Area depending on the 

year. This could be turbidity monitoring, instream sediment sampling, water chemical sampling 

or surveys of physical stream conditions. Currently, approximately 25 miles of physical stream 

habitat is surveyed every year and to date approximately 1,200 miles of stream have been 

surveyed. Information collected during these surveys includes the number of pools and riffles, 

the amount of large wood, riparian area condition and types and numbers of fish and other 

aquatic organisms to name a few of the parameters. 
Final Environmental Impact Statement 

3-90

Various portions of nine streams on the Forest and Scenic Area do not meet Federally-approved 

state water quality standards (www.deq.state.or.us/wq/standards/wqstdshome.htm), and are now 

listed as water quality limited under Section 303(d) of the CWA on the DEQ 2002 303(d) list. 

Streams on the Forest and Scenic Area that are on the 303(d) list are shown in Table 3-22, along 

with the listed parameter. There is no numeric State water quality standards for any of the 

potential herbicides or adjuvants that may be used in either of the action alternatives, so none of 

the streams are categorized as water quality limited based on the use of those chemicals. 

Table 3-22: Streams on the Forest and Scenic Area that do not meet Federally-approved 

state water quality standards. These streams are listed as water quality limited under Section 

303(d) of the Clean water Act on the DEQ 2002 list. The parameter for which they are limited is 

listed below. 

Sub-basin Stream Listed Parameter(s) 

Eagle Creek Water Temperature Clackamas 

Fish Creek Water Temperature 

Clear Creek Water Temperature 

Lower Deschutes Gate Creek Water Temperature, Sediment 

Rock Creek Water Temperature, Sediment 

Eightmile Creek Sediment 

Fifteenmile Creek Sediment 

Fivemile Creek Sediment 

Middle Columbia-Hood 

Ramsey Creek Water Temperature, Sediment 

Streams listed for temperature do not meet the following current state water quality criteria for 

salmonids: 

• Eagle, Fish, and Ramsey creeks: core, cold water habitat (61 oF) and salmon and 

steelhead spawning (55 oF, spawning periods only) 

• Clear, Gate, and Rock creeks: salmon and trout rearing (64 oF) 

Only the lower 8,000 feet of Ramsey Creek within the Forest is listed for temperature. Water 

temperature standards are based on the 7-day average maximum temperature (a running average 

over seven days is used instead of the daily average temperature). Core, cold water habitat and 

salmon and trout rearing habitat standards must be met regardless of the time of year, whereas 

the 55 oF salmon and steelhead spawning criteria only applies during spawning periods, which 

vary by species and stream. 

By direction of the CWA, where water quality is limited, DEQ develops Total Maximum Daily 

Load (TMDL) plans to improve water quality to support the beneficial uses of water. For water 

quality limited streams on National Forest System lands, the USDA Forest Service provides 

information, analysis, and site-specific planning efforts to support state processes to protect and 

restore water quality. To date, two TMDL plans have been completed (Sandy River in 2005 and 

West Hood Subbasin in 2002) while the other basins on the Forest and Scenic Area are planned 
Site-Specific Invasive Plant Treatments 

3-91

for completion in the next two years. Once the TMDL plans are completed, streams would be 

removed from the 303(d) list and stream recovery would be achieved through an implementation 

plan. USDA Forest Service requirements for the two completed TMDL plans are to follow 

Northwest Forest Plan and Forest Plan measures that protect and restore water quality. Actions 

associated with this project would be consistent with both of the TMDL plans. 

In addition, a Water Quality Restoration Plan (WQRP) has been prepared for Fish Creek 

(Clackamas River watershed) and a draft WQRP has been prepared for the headwaters of 

Fivemile Creek, Eightmile Creek, Fifteenmile Creek and Ramsey Creek by the USDA Forest 

Service. The purpose of the WQRP is to identify sources and causes of pollution, make 

recommendations for Best Management Practices (BMP) and restoration to reduce levels of 

potential pollutants, display any new monitoring that is pertinent to the 303(d) listing parameters 

and a proposed time-table for completing the restoration work. Information from the WQRP is 

often used by DEQ to develop their TMDL plan. 

The original water temperature 303(d) listing for Fish Creek is based on water temperature 

monitoring data. The WQRP recommended riparian planting where existing stream shading was 

insufficient and also riparian thinning to promote more rapid forest growth and shade recovery 

along streams. 

The original 303(d) listing for the other segments is based on information contained in the 1994 

Miles Creek Watershed Analysis (USDA Forest Service, 1994a). According to the draft WQRP, 

fine sediment levels have been reduced in all sample sites in Eightmile Creek and all but one 

sample site in Fifteenmile Creek between 1994 and 2000. The WQRP attributes the reduction, at 

least in part, to the implementation of a number of restoration projects that occurred after 1994. 

The draft WQRP makes several recommendations including continued restoration as funding 

allows, continued fine sediment monitoring, and implementation of BMP for Forest management 

activities. 

Groundwater 

Groundwater is found throughout the Forest and Scenic Area. Groundwater depths vary 

considerably and range from a few feet to hundreds of feet from the ground surface. Geologic 

conditions, soil type and precipitation are a few factors that help determine groundwater 

characteristics. The direction and speed with which groundwater moves are controlled by the 

slope of the water table and aquifer permeability. Aquifer permeability is a measure of how easy 

it is for groundwater to move through the geologic material that makes up the aquifer. The 

steeper the slope of the water table and the higher the aquifer permeability, the faster 

groundwater would move through a geologic formation. Depending on conditions, it can take 

anywhere from several hours to many decades for groundwater to move through an aquifer. 

Groundwater traditionally comes in contact with surface streams, lakes or ponds in the form of 

seeps or springs. These seeps or springs can be sources of high quality water due to their clean, 

cold condition. 
Final Environmental Impact Statement 

3-92

Riparian Conditions 

Native riparian vegetation plays a key role in forming aquatic habitat for fish and other aquatic 

species. Roots help stabilize stream banks, preventing accelerated bank erosion and providing for 

the formation of undercut banks, important cover for juvenile and adult fish. Riparian areas with 

native vegetation could supply downed trees (large wood) to streams. In turn, downed trees in 

streams influence channel morphology characteristics such as longitudinal profile; pool size, 

depth, and frequency; channel pattern; and channel geometry. Turbulence created by large wood 

increases dissolved oxygen in the water needed by fish, invertebrates and other biota. The extent 

of the hyporheic zone (place where ground water meets stream water) adjacent to and under the 

stream surface is increased by large wood in streams. Invasive plants could slow down or prevent 

the establishment of native trees, decreasing or delaying the future supply of large wood in 

stream channels. 

Riparian forest canopy protects streams from solar radiation in summer, and could moderate 

minimum winter nighttime temperature, preventing the incidence of anchor ice or freeze-up in 

streams (Beschta et al., 1987). Changes in water temperature regime could affect the survival and 

vigor of fish, and affect interspecies interactions (FEMAT, 1993). 

Riparian areas are dynamic. Disturbances characteristic of uplands such as fire and windthrow, 

as well as disturbances associated with streams, such as channel migration, floods, sediment 

deposition by floods and debris flows, shape riparian areas (FEMAT, 1993). Frequently 

disturbed ground in riparian areas makes these areas especially vulnerable to plant invasion. 

The rapid growth and propagation characteristics of many invasive plants allow them to outcompete native vegetation. This competitive advantage results in the loss of functional riparian 

communities, loss of rooting strength and protection against erosion, decreasing slope stability 

and increasing sediment introduction to streams, and impacts on water quality (Donaldson, 

1997). Invasive plants are especially difficult to control in riparian areas since invasive plants 

thrive in the moist environment and treatment measures are sometimes limited. 

Knotweed species are an example of an invasive plant with potential effects to riparian areas. 

Knotweed species leaves fall off in a short period in the fall, leaving soil beneath the plants 

relatively unprotected from rain, leading to potential for some increased erosion and sediment 

delivery to streams. In addition, if a relatively large number of knotweed leaves are decomposing 

in a small stream at any one time, there could be a local increase in biological oxygen demand 

and a reduction in the amount of dissolved oxygen for other organisms in the stream (USDA 

Forest Service, 2005a). 
Site-Specific Invasive Plant Treatments 

3-93

3.9.2. Effects Analysis & Methodology 

The water quality effects analysis utilizes research and relevant monitoring to provide a context 

for effects of each of the alternatives. In addition, herbicide concentrations derived from 

herbicide risk assessments completed by SERA (SERA 2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 

2004c, 2004d, 2004e, 2004f) and associated worksheets areused as a general indication of the 

potential delivery of herbicides to adjacent surface water. These concentrations were modified in 

the worksheets to reflect some specific site conditions for each of the treatment areas. A 

complete description of how this information was used in the aquatics analysis can be found in 

Section 3.10 – Aquatic Organisms and Habitat, and in the Water Quality Specialist Report. 

3.9.3. Direct/Indirect Effects 

Alternative 1 – No Action Alternative 

Under this alternative management of invasive plants would only occur in areas that are covered 

under existing NEPA. Invasive plants would continue to grow on sites where their treatment is 

currently not authorized by a NEPA analysis. Invasive plants are often less effective for stream 

bank stabilization than deeper rooted native plant species. Most invasive plants also provide less 

stream-shading than native hardwoods and conifers. Increased water temperatures resulting from 

reduced shading due to invasive plants are possible in streams that have the following conditions: 

• Stream channel is moderately wide (10 feet to 20 feet); 

• Stream channel has an east-west orientation; 

• Slopes next to the stream are greater than 30 percent; 

• Limited groundwater input 

• Riparian area has the potential for larger coniferous or hardwood streamside riparian 

vegetation; and, 

• Site has a large contiguous block of short invasive plants along the south edge of the 

stream. 

The likelihood that the adjacent stream has some increased stream temperature resulting from 

shade loss increases as the number of these conditions increase at a treatment site. In reality, any 

stream temperature increase would likely be very localized and small due to the localized nature 

of most of the infestations and the low probability that all of the conditions described above are 

found at any one site. It is anticipated that most of the infestation areas have an insignificant 

effect on water temperature due to meeting very few of the above conditions. 
Final Environmental Impact Statement 

3-94

Where invasive plants provide less effective ground cover and a shallow root system than native 

plants, there is a greater potential for a surface erosion, bank erosion, and in-stream sediment 

delivery during high intensity rainfall events. This situation is similar to the stream temperature 

description above, in that most of the sediment increase to adjacent surface water is anticipated 

to be insignificant, due to the localized infestation of invasive plants. Infestations do have the 

potential to introduce small, localized amounts of sediment in areas that have highly erosive 

banks that are covered with a large (approximately 50 feet or more along the edge of the stream) 

contiguous block of shallow rooted invasive plants. Talmage (2004) found that if a shallower 

rooted invasive plant species such as knotweed species completely occupy an unstable stream 

bank, the potential for stream bank instability during high flows is much greater than if the same 

site was occupied by deeper rooted native vegetation. Invasive plants also could complicate 

restoration by preventing the re-establishment of native vegetation that is more effective for 

providing stream shading, stream bank/soil stability, and ground cover. 

The localized effects of invasive plants out competing more beneficial native plants on key sites 

such as stream banks and riparian areas would continue. Invasive plants are likely to spread in 

areas that do not have an active eradication, containment, and control program. The potential 

adverse effects to water quality and soil stability would continue to mount. 

In addition to the effects of invasive plant infestations described above, effects associated with 

the current invasive plant eradication program are part of this alternative. The program utilizes 

manual, mechanical and herbicide treatments to treat a variety of areas in the Forest and Scenic 

Area. From 1999 to 2003, 3,894 acres of invasive plant infestations have been treated under 

existing programs, with a typical yearly program treating approximately 1,200 acres (acreage 

treated in 2003). Of these treated acres, roughly 50 percent are sprayed with herbicides, 40 

percent are treated by mechanical means and 10 percent are treated manually. Table 3-23 shows 

the number of acres of invasive plant treatment within riparian reserves that has occurred from 

1999 to 2003 on the Forest and Scenic Area. 

Indirect, direct and cumulative effects to the aquatic environment for current treatment programs 

are contained in each of the existing NEPA documents (USDA Forest Service, 1993a; 1996c; 

1998b; BPA, 2001). These documents also contain applicable project design criteria and/or 

mitigation measures aimed at minimizing introduction of pollutants, such as herbicides and 

sediment. In general, these documents do not anticipate any indirect, direct or cumulative effects 

to the aquatic environment. 
Site-Specific Invasive Plant Treatments 

3-95

Table 3-23: Number of acres of invasive plant treatments within riparian reserves that has 

occurred from 1999 to 2003 on the Forest and Scenic Area under the No Action 

Alternative (Alternative 1). 

Fifth-Field 

Number Fifth-Field Watershed Name 

Acres Treated in 

Riparian Reserves 

1707010502 Fifteenmile Creek 3.4 

1707010503 Fivemile Creek 4.9 

1707010506 East Fork Hood River 16.2 

1707010507 West Fork Hood River 206.7 

1707010508 Lower Hood River 25.2 

1707010512 Middle Columbia/Grays Creek 48.7 

1707010513 Middle Columbia/Eagle Creek 10.8 

1707030605 Beaver Creek 3.1 

1707030607 Middle Deschutes River 29.7 

1707030609 Tygh Creek 8.3 

1707030610 White River 135.4 

1708000102 Zigzag River 18.0 

1708000107 Columbia Gorge Tributaries 767.5 

1708000108 Lower Sandy River 609.1 

1709001102 Upper Clackamas River 3.8 

1709001103 Oak Grove Fork Clackamas River 18.6 

1709001104 Middle Clackamas River 191.0 

Total 2100.4 

Alternative 2 – The Proposed Action 

The Proposed Action would implement invasive plant treatments on up to 13,000 acres within 

the Forest and Scenic Area. In addition to these 13,000 acres, other acres may be treated as part 

of the EDRR described in Chapter 1 and Chapter 2 of this document. Effects of this program on 

water quality are displayed in the EDRR portion of this analysis shown below. Table 3-24 shows 

the number of acres of invasive plant treatment within riparian reserves on the Forest and Scenic 

Area. The numbers include herbicide, manual, mechanical, and cultural treatment methods 

prescribed in this alternative (see Table 2-3). 
Final Environmental Impact Statement 

3-96

Table 3-24: Acres of invasive plant treatments within riparian reserves on the Forest and 

Scenic Area for Proposed Action (Alternative 2). Acreage numbers include herbicide, 

manual, mechanical, and cultural treatment methods. Also shown are the differences in acres 

treated between Alternative 2 and Alternative 1. Values in bold represent a reduction in acres 

treated in riparian reserves between Alternative 2 and Alternative 1.

Fifth-Field 

Number Fifth-Field Watershed Name 

Acres Treated 

in Riparian 

Reserves 

Acre Change Between 

Alternative 1 & 

Alternative 2 

1707010502 Fifteenmile Creek 17.6 14 

1707010503 Fivemile Creek 65.7 61 

1707010504 Middle Columbia/Mill Creek 45.1 45 

1707010506 East Fork Hood River 416.5 400 

1707010507 West Fork Hood River 511.0 304 

1707010508 Lower Hood River 57.1 32 

1707010512 Middle Columbia/Grays Creek 41.1 -8 

1707010513 Middle Columbia/Eagle Creek 16.0 5 

1707030605 Beaver Creek 2.3 -1 

1707030607 Middle Deschutes River 46.9 17 

1707030609 Tygh Creek 56.9 49 

1707030610 White River 646.7 511 

1708000101 Salmon River 63.3 63 

1708000102 Zigzag River 150.3 132 

1708000103 Upper Sandy River 505.4 505 

1708000104 Middle Sandy River 27.4 27 

1708000107 Columbia Gorge Tributaries 639.0 -128 

1708000108 Lower Sandy River 816.5 207 

1709001101 Collawash River 38.1 38 

1709001102 Upper Clackamas River 246.0 242 

1709001103 Oak Grove Fork Clackamas River 55.6 37 

1709001104 Middle Clackamas River 600.7 410 

Total 5065.2 

Fifth-field watersheds with the largest increase in treatments within the riparian reserves are the 

White River (+511 acres), Upper Sandy River (+505 acres), Middle Clackamas River (+410 

acres), East Fork Hood River (+400 acres), West Fork Hood River (+304 acres), Upper 

Clackamas River (+242 acres), Lower Sandy River (+207 acres) and Zigzag River (+132 acres). 

The potential adverse effects of the Proposed Action on stream turbidity, dissolved oxygen, 

water temperature, peak flows, low flows, water yield, and water chemistry are discussed below. 
Site-Specific Invasive Plant Treatments 

3-97

Soil Disturbance, Turbidity and Fine Sediment 

Invasive plant eradication has the potential to temporarily leave treatment areas with reduced 

ground cover which in turn has the potential for increased erosion and resulting sedimentation. In 

addition, equipment used in plant treatment has the potential to disturb or displace soil, making 

the soil more vulnerable to erosion. Herbicide treatments do not kill all invasive plants 

immediately. Repeated treatments over several successive years are needed for invasive plant 

eradication, containment, and control. As treated vegetation dies there is the potential for surface 

erosion from exposed soil surfaces and loss of root holding strength. As stated in Section 3.8 – 

Soil Productivity, there should be a net reduction in soil erosion risk with this alternative when 

compared to Alternative 1, because desirable native plants that provide long-term soil stability 

and proper function would eventually reoccupy the treated sites. Short term erosion would be 

mitigated by creation of a restoration plan that would identify specific measures to ensure 

protection against erosion and resulting sedimentation. These measures would be implemented as 

part of the project. A reduction in associated sedimentation is also expected from the reduction in 

erosion risk since the two are strongly related. 

Proposed manual, mechanical, and cultural treatment measures such as pulling, mowing, weed 

wacking, or grazing by goats are not likely to cause much soil disturbance or increase the 

potential for measurable surface erosion/sedimentation (see Section 3.8 – Soil Productivity). 

Hand-pulling involves manually pulling the invasive plant/roots out of the ground. When 

invasive plants are pulled, some surface soil may be exposed during the process, but the amount 

of off-site sediment movement is expected to be insignificant due to the small amount of soil 

exposure expected. 

Where invasive plant control measures result in the reduction of area ground cover (e.g. 

vegetation, duff, litter, or rocks) as called for in the Mt. Hood Forest Plan standard and guideline 

FW-082 and FW-082, PDC would be implemented to further reduce the risk of erosion and 

sedimentation. These PDC would be tailored to reduce erosion based on site specific conditions 

in the treatment areas. Typical PDC such as application of mulch, hydroseeding with soil binding 

agents or erosion control blankets may be used to reduce the potential for soil detachment from 

raindrop impact and create a favorable environment for native vegetation to re-establish faster in 

the treatment area.

It is expected that streams would meet turbidity standards because implementing the PDC would 

reduce erosion and sediment delivery; the proposed treatments would not create significant 

amounts of ground disturbance; and most of the invasive plant treatment sites are already 

adjacent to disturbed areas such as roads (82 percent of the treatment acres). Supporting 

information regarding the potential effect of proposed invasive plant eradication, containment 

and control efforts on soil disturbance and ground cover is located in Section 3.8 – Soil 

Productivity. 
Final Environmental Impact Statement 

3-98

Dissolved Oxygen and Nutrients 

The herbicide, manual, mechanical, and cultural treatments proposed would not result in 

significant amounts of plant material or nutrients entering streams or other water bodies at once. 

Invasive plant treatments would occur at different times and in different places, so the probablity 

of large amounts of plant material entering surface water all at once is very low. In addition, 

streams on the Forest and Scenic Area have naturally vegetated riparian areas that provide large 

amounts of organic matter including tree leaves and needles. Due to the natural high input of 

organic matter into streams and the small amount of invasive plant material entering the water, a 

negligible adverse effect on in-stream dissolved oxygen levels is anticipated. 

There are few stream reaches that exhibit symptoms of excessive levels of nitrogen or 

phosphorus (e.g., large mats of algae) that would stimulate primary production. One short stream 

reach where algae are common is in Clear Branch just below Clear Branch Dam on the Hood 

River Ranger District. This short section of stream (about one quarter-mile long) has little shade 

and the water released from the reservoir is thought to be phosphorous rich. The combination of 

additional nutrients and additional sunlight has stimulated algae growth. Further downstream, 

once the stream enters a wooded, well-shaded area, the algae disappear rapidly. This 

combination of sunlight and high nutrient levels is very uncommon in streams on the Forest and 

Scenic Area. 

Virtually all streams have some algae and/or aquatic macrophyte growth as natural components 

of the ecosystem. The growth of this flora is controlled primarily by water temperature, sunlight, 

and available nutrients. The relative lack of algae and macrophyte presence is due to cool, well 

shaded water that is naturally low in available nutrients in most areas. Fertilizer use on the Forest 

and Scenic Area is uncommon as are the presence of other chemicals that could accelerate (or 

retard, in some cases) aquatic flora growth. 

Water Temperature 

Conditions such as stream aspect, streambank slope and riparian vegetation play a role in the rate 

at which solar energy reaches small forested streams (Brown, 1983). Most invasive plants 

provide little or no shade to streams, the exception being knotweed species and blackberry in 

sites that have a very narrow perennial stream channel (less than five feet wide). Temporary loss 

of knotweed and blackberry vegetation in these small channels has a higher potential for short 

term water temperature increase when compared to other invasive plant types, because this 

vegetation is providing shade. As described above, several other physical factors including 

stream orientation, existing topographic shading and groundwater input play a part in 

determining whether loss of stream shading would result in water temperature increase. All of 

the other plants currently provide very little stream shading due to their height and density, so 

there would be a negligible effect on in-stream temperatures resulting from invasive plant 

treatment efforts. Any loss of stream shade that may occur is expected to be temporary, until 

native vegetation reaches and surpasses the height of the invasive plants that are removed. Native 

shrub recovery (passive restoration) could be relatively rapid (several years), while the length of 

time for deciduous and coniferous trees to reach maturity could take many years. 
Site-Specific Invasive Plant Treatments 

3-99

On treatment areas where re-vegetation (active restoration) is proposed after herbicide, manual, 

mechanical, and cultural treatments, re-establishment of native plants would take place more 

quickly. This could be expected to have positive effects on stream bank stability and stream 

shading, and potential long-term reduction in water temperature. An insignificant effect on 

instream water temperature is expected as a result of implementing proposed invasive plant 

treatment efforts. 

The risk for adverse effects to shade-producing native vegetation is relatively low with direct 

hand/selective and spot spraying (e.g., backpack sprayer) techniques that would be used near 

waterbodies. Spot spraying enables the applicator to target specific invasive plants, thereby 

minimizing the potential for overspray to native plants. 

Peak Flows/Low Flows/Water Yield 

The methods used during the herbicide, manual, mechanical, and cultural treatments of invasive 

plants are expected to have a negligible or no effect on water infiltration into the soil and surface 

runoff. Compared to the total watershed, the actual area to be treated by all invasive plant 

treatment methods is very small (Table 3-26). Herbicide treatment methods would not alter soil 

parameters that would reduce water infiltration. Soil compaction from manual (hand pulling), 

mechanical (mowing, etc.), or cultural (grazing by goats) treatment methods is expected to be 

very minor and localized so increased surface runoff would be insignificant. Eighty-two percent 

of the proposed treatment acres are located adjacent to roads that already have considerable soil 

disturbance and compaction. As a result, an insignificant effect on peak flows, low flows, or 

water yield is expected. 

Riparian Structure 

Invasive plant treatment and removal in riparian areas is intended to provide the opportunity for 

the eventual return of native vegetation and corresponding restoration of natural riparian 

structure. Some desired future conditions for B7 General Riparian Areas identified in the Forest 

Plan are: “dynamic, multi-aged communities . . .” that consist of a “multi-latered canopy 

including large tall green trees, dead snags, intermediate size trees and understory vegetation.” 

When invasive plants occupying riparian sites are eradicated, the length of time before suitable 

native vegetation (passive restoration) returns to perform important riparian functions, such as 

stream shading and streambank stability, would vary across the Forest and Scenic Area. On 

invasive plant treatment areas where native vegetation would be planted (active restoration) 

riparian structure would return more rapidly. In general, improved long-term riparian structure 

and function due to invasive plant treatment would benefit water quality and listed aquatic 

species, due to long-term improvements in stream shading, vegetative stream bank stabilization, 

and in-channel large wood inputs. 
Final Environmental Impact Statement 

3-100

Water Chemistry 

Herbicides used to control terrestrial invasive plants for the Proposed Action could enter water 

through spray drift, surface water runoff, percolation and groundwater contamination. This has 

the potential to reduce water quality due to introduction of herbicides and associated adjuvant 

and impurities. Some of these adjuvants may also alter water quality characteristics such as pH 

(Bakke, 2003a). The primary pathway for potential herbicide introduction into surface water 

depends on a variety of factors including: application method, timing and amount of herbicide 

application, herbicide properties, soil properties, site conditions and management practices. Once 

on the ground or plant surface, herbicide fate is controlled by numerous biological, physical and 

chemical processes including: ingestion by animals, insects, worms or microorganisms; 

movement downward in the soil; adherence to or dissolved in soil particles; degradation into less 

(or more) toxic compounds; movement by runoff water on the soil surface; or transported by 

eroding sediment. Needless to say, herbicide delivery and fate is a very complex situation. 

Detailed discussions about herbicide delivery and fate are contained in the herbicide risk 

assessments completed by SERA (SERA 2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 

2004e, 2004f). This information is also summarized in Appendix Q – Herbicide Information 

Summary and PDC Crosswalk. 

Soil type and chemical stability, solubility, and toxicity could determine the extent to which an 

herbicide would migrate and impact surface waters and groundwater. Some herbicides such as 

glyphosate strongly adsorb to soil particles, which prevents it from excessive leaching. Other 

herbicides such as picloram are highly soluble in water and more mobile. The herbicide risk 

assessments completed by SERA (SERA 2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 

2004e, 2004f) and associated worksheets utilize modeling to predict potential concentrations 

reaching surface water take these physical characteristics into account. These concentrations were 

estimated and utilized along with several other factors in Section 3.10 – Aquatic Organisms and 

Habitat to help determine risk of herbicide treatment to aquatic organisms for specific sites 

outlined in this EIS. 

As stated above, due to its chemical nature picloram has one of the highest potentials of all of the 

herbicides analyzed in the EIS to leach into groundwater. Some studies have looked at the 

potential of groundwater contamination from picloram. Neary and others (1985) monitored two 

springs approximately 140 meters (450 feet) downslope of two 5-acre plots that were treated 

with picloram applied at the rate of 4.4 lb/ac. The study took place in the Coweta Watershed in 

North Carolina which has an average annual rainfall of approximately 80 inches. Picloram 

residues were detected in “trace amounts” 82 days after the initial herbicide treatment. During 

the 40 weeks that the two springs were monitored, picloram residues were present in only “trace 

levels” for a period of 18 days. According to the study: “In terms of water quality impacts, there 

was no adverse effect on the quality of the springs.” It should be noted that the concentration of 

picloram applied in this study is almost 13 times higher that the application rate that would be 

allowed for picloram in this EIS. 
Site-Specific Invasive Plant Treatments 

3-101

Bovey et al. (1975) conducted an investigation to determine the concentration of 2,4,5-T and 

picloram in subsurface water after spray applications to the surface of a seepy area in Texas. A 1-

to-1 mixture was sprayed at 2.5 lb/ac every six months on the same area for a total of five 

applications. Supplemental irrigation in addition to a total of 85.5 cm natural rainfall was used to 

leach picloram into the subsoil. Seepage water was collected on 36 different dates, and one to six 

wells in the watershed were sampled at 10 different dates during 1971, 1972, and 1973. 

Concentration of 2,4,5-T and picloram in seepage and well water from the treated area was 

extremely low (less than 1 ppb) during the 3-year study. Again, it should be noted that the 

application rate of this study was considerably higher than the rate proposed in this EIS for 

picloram. 

By contrast, triclopyr BEE (ester formulation) is one of the more potentially toxic herbicides 

proposed for use in this EIS; however, it is somewhat immobile in soils and tends to rapidly 

breakdown into the less toxic triclopyr acid (Ganapathy, 1997). In soil, triclopyr BEE hydrolyzes 

to triclopyr acid with a half-life of three hours (Bidlack, 1978) while in water BEE converts to 

acid in less than a day (Somasundarm and Coates, 1991; Bidlack, 1978). Triclopyr acid is also 

photodegradable. A study of photolysis found the half-life of triclopyr acid on soil under midsummer sun was two hours (McCall & Gavit, 1986). Photodegradation can be particularly 

important in water. Johnson et al. (1995) found triclopyr acid dissolved in water had a half-life 

due to photolysis of one to 12 hours. 

In a 1990 field study, Stephenson et al. examined the soil dissipation of triclopyr on both sandy 

and clay soils and its potential for vertical movement. The researchers found triclopyr to be 

rapidly degraded in both sand and clay soils; 50 percent and 90 percent disappearance of the 

compound was observed after two and four weeks, respectively. An average of 90 percent or 

more of the triclopyr did not leach below the organic layer at the two sites over a one year 

period; 97 percent or more of the triclopyr was recovered within six inches of the soil surface. 

The authors also found little lateral movement of triclopyr, detecting less than 1 ppb triclopyr in 

runoff samples from one to 105 days after treatment with 2.7 lbs ai/ac (this application rate is 

almost three times higher than what is proposed in this EIS). They concluded: "...our field 

studies of actual triclopyr persistence and mobility confirm earlier laboratory results and indicate 

that environmental problems are very unlikely to occur because of excessive triclopyr persistence 

and/or mobility in soil." In contrast, studies conducted for Dow Chemical classified triclopyr as 

mobile (Hamaker, 1975). This apparent contradiction in soil mobility may be explained by a 

study that showed that triclopyr sorption to soil increases with time, decreasing the potential for 

leaching (Buttler et al., 1993). 

Several studies have focused on the fate of triclopyr in runoff from forested sites. Thomposon et al. 

(1995) studied triclopyr BEE and triclopyr acid in first order streams. The authors injected a 3.6 lb 

ai/ac solution (over three times stronger than what is proposed in this EIS) of triclopyr BEE directly 

into a small stream at two locations at different depths. Sediment, invertebrates and periphyton were 

sampled at seven locations at different time intervals. As the herbicide pulse moved downstream, the 

BEE degraded to the less toxic triclopyr. The study concluded that triclopyr had almost no adverse 

effects on the drifting and benthic invertebrates. Periphyton growth increased after herbicide 

introduction possibly due to nutrient enrichment from components in the formulation. Periphyton 

conditions returned to control levels three months after herbicide introduction. 
Final Environmental Impact Statement 

3-102

Newton et al. (1990) studied an application of triclopyr, picloram and 2,4-D to brush in 

southwestern Oregon. Both triclopyr TEA, and triclopyr BEE were applied to 100 by 200 meter 

plots at the rate of 2.0 and 3.9 lb ai/ac for the TEA and 1.5 and 2.9 lb ai/ac for the BEE. At 37 

days after application, 24 and 51 percent of the applied triclopyr was present in the surface soil. 

The largest decrease in soil residue occurred between 37 and 79 days after application. As a 

result of the monitoring, the researchers concluded that due to the immobile nature of triclopyr in 

soil-water, the herbicide would only move very short distances in forest subsurface flow. 

In summary, research indicates that both triclopyr TEA and triclopyr BEE rapidly convert to 

triclopyr acid which, in the case of triclopyr BEE is considerably less toxic to aquatic organisms. 

Triclopyr exhibits very little horizontal and vertical movement through soils and degrades fairly 

rapidly (average half life of several hours to 30 days). 

Water runoff during rain events could transport herbicides to waterways, and convey them to 

aquatic species habitat directly adjacent and downstream of the treatment site. Two factors that help 

determine herbicide concentrations delivered to aquatic organisms include the amount of herbicide 

reaching surface water and the dilution of the herbicide once it reaches water. While potential 

herbicide concentrations delivered to water are discussed above and in other resource sections in 

this Chapter, these discussions focused on a single herbicide application during the course of a 

year. In some cases, there is a potential of having multiple applications of an herbicide on a singe 

site in a year, so there is a chance that some residual herbicide would still be stored in the soil when 

the next application occurs. The potential of having higher herbicide concentrations delivered to 

surface water would be highest for those herbicides that have a high persistence in soil and a high 

mobility through soil. This higher concentration would be most evident in a “first flush” situation, 

where multiple herbicide applications occur prior to the first fall rains. A table displaying these 

particular attributes can be found in Section 3.8 – Soil Productivity. Only three herbicides are rated 

moderate to high in both persistence and mobility categories – picloram, chlorsulfuron and 

metsulfuron methyl. PDC that include limiting the application of picloram to once per calendar 

year per site and limiting application of picloram, chlorsulfuron and metsulfuron methyl to soil 

types that do not encourage persistence and mobility are designed to reduce the likelihood of 

increased herbicide concentration from the first flush. 

As mentioned above, the other factor influencing delivery to aquatic organisms is dilution of 

herbicide in water. The mixing zone size needed to reduce or dilute downstream herbicide levels 

below any threshold effect concentration is a critical parameter. Mixing zone size can vary 

greatly and can depend upon the volume of herbicide input, the volume of the water body, the 

entry point (e.g., gravel bar inundation or drift deposition), and turbulence, which is generally 

greater for small but steep headwater streams. Hydrologically complex waterways with 

meanders, pools, riffles, and eddies that accelerate mixing and dilution are more likely to 

disperse contaminants than simplified waterways with consistent channel velocities that allow 

contaminants to maintain a more consolidated profile (Jobson, 1996; Lee, 1995; Heard et 

al.,2001; as cited in USDC NOAA, 2003). Streams on the Forest and Scenic Area have high 

channel complexity (wood, pools, boulders), so it is expected that mixing of chemicals would 

occur rapidly and there would be a rapid decrease of concentration with time. Mixing distances 

are also usually shorter in smaller streams (Heard et al., 2001; as cited in USDC NOAA, 2003). 
Site-Specific Invasive Plant Treatments 

3-103

Information about downstream mixing and dilution for herbicides used in forestry is relatively 

limited. Evans and Duseja (1973) sprayed picloram at the rate of one and two lb/ac over areas 

that ranged between one and two acres. They took runoff samples from a drainage ditch at a 

distance of 5, 10, 100 and 1,000 meters downstream of the treatment area. The site experienced a 

1.5 inch rainstorm within the first week after spraying. Picloram concentrations were diluted 85 

percent to 98 percent within 100 meters below the treatment areas and were diluted to 

concentrations below detection levels in all but one site 1,000 meters below the treatment areas. 

After 12 weeks all concentrations were ≤ 0.001 ppm and within a year picloram was not 

detectable. It should be noted that concentrations used in this study are three to six times greater 

than the concentration proposed in this EIS. In addition, the sample site was a drainage ditch 

which represents a simplified waterway with a low mixing potential when compared to complex 

streams found on National Forest land. 

Johnsen and Warskow (1980) directly injected 1.5 lbs of picloram at a concentration of 6.258 

ppm into a 1.3 cfs stream in Arizona and sampled water at 400, 800, 1,600, 3,200, 6,400 and 

9,700 meter intervals along the stream. The original 6.258 ppm solution had been diluted to a 

concentration of 0.282 ppm (96 percent reduction in concentration) by the time it reached 1,600 

meters downstream and 0.10 ppm (99.9 percent reduction in concentration) by the time it 

reached 3,200 meters downstream. Two days after the picloram injection, concentrations were at 

or near the detection limit of 0.001 to 0.004 ppm at the 400 to 1,600 meter sample points. It 

should be noted that the original concentration of 6.258 ppm of picloram that was introduced into 

the stream by this study is approximately 560 times more concentrated than the highest picloram 

concentration predicted by the herbicide risk assessments completed by SERA (SERA 2001b, 

2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) and associated worksheets for any 

of the treatment sites analyzed in this EIS. 

PDC are utilized to reduce or eliminate negative effects of management activities on resources. 

A detailed discussion of specific aquatic-related PDC and how they would reduce or eliminate 

herbicide introduction into water is included in Section 3.10 – Aquatic Organisms and Habitat 

and a list of PDC and how they would address specific effects from herbicide application is 

summarized in Appendix Q – Herbicide Information Summary and PDC Crosswalk. As 

described in Section 3.10, the amount of herbicide reaching surface water by spray drift is 

expected to be minimal considering the restrictions of no broadcast boom spraying within 100 

feet of surface water and when wind speeds are outside the range described in the PDC (Section 

2.2) as well as using coarse spray, low nozzle pressure spray heads. Herbicides entering surface 

water through surface runoff are also expected to be minimal, since among other things, targeted 

spot spraying techniques that reduce the total amount of herbicide applied would be used within 

100 feet of surface water (PDC F.1.), application of herbicides is restricted if rainfall is expected 

immediately after application (PDC C.3.). This would minimize the amount of herbicide 

reaching the ground surface as well as minimize the potential for herbicide drift. 
Final Environmental Impact Statement 

3-104

The potential routes of herbicide entry described above should result in insignificant short term 

and long term indirect effects to water quality. As discussed above and in Section 3.10 – Aquatic 

Organisms and Habitat, PDC would be employed to minimize the potential for introduction of 

herbicides into area surface and groundwater. The likelihood of herbicide drifting would be 

substantially reduced by: 1) no aerial application of herbicides; 2) limited broadcast spraying 

outside of the aquatic influence zone; 3) selective application techniques only within the aquatic 

influence zone; and 4) use of coarse spray, low nozzle pressure spray heads. PDC that would 

limit the total amount of herbicide applied next to water features by only utilizing selective 

application techniques, not allowing use of more toxic and mobile herbicides and adjuvants next 

to water features, restricting application of herbicides if rainfall would occur immediately after 

application and treating sites to minimize erosion would reduce the likelihood of secondary 

herbicide introduction. As indicated by the mixing and dilution studies cited in the paragraphs 

above, any trace amount of herbicide that may reach surface water would be quickly diluted. 

Summary of Indirect/Direct Effects 

Table 3-25 below is a summary of the potential pathways of effects on water quality from 

proposed herbicide, manual, mechanical, and cultural treatments of invasive plants. This table is 

a summary of the information provided above. 

Table 3-25: Potential pathways of effects to water quality from treatment methods. (I = 

Insignificant estimated effect; B = Potential long-term beneficial effect.) 

Potential Pathways of Effects 

Treatment Methods 

Soil Disturbance, Turbidity, and Sedimentation Dissolved oxygen and nutrients Stream Shade and Water temperature Peak flows, low flows, water yield Riparian structure Water Chemistry 

Cultural I I I I I N/A 

Manual I I I I I/B N/A 

Mechanical I I I I I/B N/A 

Herbicides and adjuvants I I I I I/B I 

Restoration1 (revegetation) B I B B B N/A 

1

 Restoration (Revegetation) would be done on selected invasive plant treatment sites. 

N/A – Not Applicable 

The potential adverse effects of the Proposed Action on aquatic organisms/plants and drinking 

water quality are discussed in the Section 3.5 – Human Health and Safety and Section 3.10 – 

Aquatic Organisms and Habitat. 
Site-Specific Invasive Plant Treatments 

3-105

Cumulative Effects – Alternative 2 

Most proposed invasive plants treatment areas on the Forest and Scenic Area are upstream of 

other sources of herbicides and sediment on both non-Federal and Federal lands. Where streams 

migrate and flow downstream through other land ownerships (BLM, Federal, State, Tribal, or 

private), the potential exists for herbicides or sediments originating from invasive plant treatment 

sites on the Forest and Scenic Area to mix with those originating from sites being treated offNational Forest System lands. There is also the potential for herbicides and sediments from 

invasive plant treatment sites adjacent to the Forest and Scenic Area watersheds to mix together 

at some point downstream if simultaneous treatment occurs. As described in Section 3.4 of this 

document and Section 4.1.1 of the Invasive Plant FEIS (2005a), the effects could be additive or 

synergistic in nature. As described in the Water Chemistry section above, expected mixing and 

dilution of any trace amount of herbicide that may result from invasive plant treatment would 

occur quickly, making it highly unlikely that herbicide concentrations would be additive or 

synergistic with similar treatments at the watershed scale. Limited monitoring done by the State 

of California seems to support this conclusion. In response to concerns about potential 

contamination of drinking water from herbicide treatments on nearby private lands, numerous 

surface water samples were collected in the late 1990s both immediately downstream of 

herbicide application sites (site scale), and on larger channels potentially distant from application 

sites (watershed scale). Approximately 40,631 pounds of active ingredient of 13 herbicides and 

19 insecticides were applied within the privately-owned watersheds upstream of locations 

sampled at the watershed scale (Jones et al., 2000). 

One hundred eight water samples were collected at six sites on the Klamath, Trinity and Scott 

rivers, and Elk, Pine and Supply creeks on four occasions between September 1998 and October 

1999 (Jones et al., 2000). Timing of sample collection was scheduled partially to coordinate with 

runoff events. The first collection, done under dry conditions in September 1998, served as 

background. Collections in October 1998 and 1999 sampled storm runoff. Collections in June 

1999 corresponded to the end of the heaviest pesticide application season (Jones et al., 2000). 

No detectable concentrations of any herbicides were identified (reliable detection limits ranged 

from 0.04 to 2.0 ppb). The analysis included two herbicides that are being proposed for use in 

this EIS, glyphosate and triclopyr. Some possible explanations for the lack of detection include 

several months passed between dry weather application and the first rain, potentially allowing 

chemical degradation or adsorption to soil. Also, dilution of streamflow between application and 

monitoring sites may also have contributed to the lack of positive detections (Jones et al., 2000). 
Final Environmental Impact Statement 

3-106

Table 3-26 shows the number of acres of treatment in each fifth-field watershed to give an idea 

about how much treatment would actually occur on the Forest and Scenic Area. In addition, the 

table displays road density in each fifth-field watershed. Road density could be used as a 

surrogate for the amount of sediment related to human activity since roads are used to access 

structures, land treatment sites, and since roads themselves are sources of sediment. 

Table 3-26: Ownership, acres of treatment areas and road density in each fifth-field 

watershed. 

Watershed Name 

Total 

Watershed 

Acres 

Percent of 

Watershed 

in Forest/ 

Scenic Area 

Ownership 

Proposed 

Treatment 

Acres 

Percent of 

Watershed 

Treated 

Road 

Density* 

(mi/mi2) 

Beaver Creek 10,6742.0 1% 45.5 0% 0.2 

Bull Run River 88,985.0 88% 2.4 0% 2.6 

Collawash River 97,421.1 99% 64.1 0.1% 2.7 

Columbia Gorge 

Tributaries 103,926.1 43% 942.3 1% 0.4 

East Fork Hood River 100,953.3 68% 1254.1 1% 1.9 

Fifteenmile Creek 157,237.5 11% 227.8 0.1% 0.4 

Fivemile Creek 78,190.5 24% 511.8 1% 1.0 

Lower Clackamas 

River 117,660.7 1% 3.4 0% 0.1 

Lower Hood River 51,289.3 6% 250.3 1% 1.2 

Lower Sandy River 47,155.2 8% 856.6 2% 0.5 

Middle Clackamas 

River 138,506.6 90% 747.4 1% 2.5 

Middle Columbia/ 

Eagle Creek 84,495.2 55% 79.2 0.1% 0.3 

Middle Columbia/ 

Grays Creek 92,722.8 31% 173.3 0.2% 0.4 

Middle Columbia/ 

Mill Creek 130,697.6 13% 214.0 0.2% 0.4 

Middle Deschutes 

River 195,384.6 2% 315.6 0.2% 0.1 

Middle Sandy River 40,956.7 16% 40.5 0.1% 1.6 

Oak Grove Fork 

Clackamas River 90,542.0 88% 175.8 0.2% 3.7 

Salmon River 73,716.1 92% 172.8 0.2% 1.9 

Tygh Creek 81,558.4 51% 298.1 0.4% 0.9 

Upper Clackamas 

River 100,496.8 94% 484.9 1% 3.5 

Upper Sandy River 34,200.9 90% 1,060.7 3% 2.5 

West Fork Hood River 65,466.3 66% 1,620.5 3% 1.7 

White River 176,272.2 60% 3,171.7 2% 2.3 

Zigzag River 37,763.7 97% 368.7 1% 1.1 

* Road density values include some roads off National Forest System lands 
Site-Specific Invasive Plant Treatments 

3-107

According to the table above, total acres treated in any fifth-field watershed exceeds two percent 

of the total watershed acreage in only two fifth-field watersheds. Those watersheds are Upper 

Sandy River and West Fork Hood River. Less than one percent of the total watershed area is 

proposed for treatment in the majority of the remaining fifth-field watersheds. Forest and Scenic 

Area ownership in these two watersheds is 89.8 percent and 65.5 percent for the Upper Sandy 

River and West Fork Hood River respectively. Since the major land holdings are National Forest 

System lands, effects of invasive plant treatments at individual sites are described in this 

document. Detrimental effects to water quality from each of the projects are expected to be very 

low due to PDC that employ measures to reduce or eliminate harmful effects to the aquatic 

environment. These PDC were developed using modeling, research and other documents and 

field experience (See Section 2.2, Subsection F: Water Quality and Aquatic Organisms). The 

majority of the remaining the fifth-field watersheds propose to treat less than 1 percent of the 

total watershed acres so no cumulative effects from proposed invasive plant treatments are 

expected. 

Even if the invasive plant treatments are occurring at the same time on both Federal and nonfederal lands, the potential for sediment-related cumulative effects is very low considering the 

negligible amount of sediment expected to reach perennial streams from either manual, 

mechanical, or cultural treatments of invasive plants. Forest streams listed on the 303 (d) list for 

sediment displayed in the Existing Condition section are located in the Fivemile and Fifteenmile 

fifth-field watersheds. Only 61 and 14 acres of additional riparian reserve treatment are being 

proposed in this alternative when compared to the No Action Alternative in these two 

watersheds. This acreage only represents 0.5 and 1.9 percent of the total riparian reserve in each 

of the watersheds, respectively. As described above, road density could be used as an indicator of 

the amount of past and present human disturbance, and the resulting levels of sedimentation. 

Fivemile and Fifteenmile fifth-field watersheds have road densities of 1.02 and 0.37 mi/mi2

respectively. These watersheds have low relative road densities when compared to the other 

fifth-field watersheds in the analysis (14 and 20 highest road densities out of the 24 fifth-field 

watersheds analyzed in this document). These represent moderate to low relative road densities, 

which when coupled with the low amount of proposed disturbance in riparian reserves PDC to 

reduce erosion and sediment delivery and apparent improving trend related to sedimentation 

identified in the draft WQRP would result in negligible sediment related cumulative effects. 

The potential for cumulative effects is negligible considering the insignificant amount of 

herbicide or sediment expected to reach surface water due to implementation of PDC that would 

minimize the amount and type of herbicides that actually reach surface water, the distance 

between potential treatment areas, and dilution over time and space by mixing and additional 

inflow from downstream tributaries and ground-water entering streams. 
Final Environmental Impact Statement 

3-108

Alternative 3 – Restricted Herbicide Use Alternative 

Herbicide treatments would be completed only on priority 1 sites under this alternative. All other 

sites (priority 2 through 5) only have manual, mechanical and cultural methods proposed. The 

potential effects of priority 1 invasive plant herbicide treatment sites is similar to those described 

above for Alternative 2 (Proposed Action), but the potential effects from the use of herbicides are 

much more limited since the number of acres potentially treated is much less. 

As described in Section 3.8 – Soil Productivity, this alternative would have a lower potential for 

long term erosion when compared to the No Action Alternative, due to the establishment of 

native vegetation on treatment sites. Since the erosion potential is lower, the associated 

sedimentation resulting from the erosion would be lower than Alternative 1. According to the 

soils analysis, the primary source of erosion is from the inability of the invasive plants to protect 

the soil from erosion. Actual erosion and sediment production from the mechanical and manual 

activity is expected to be very low due to the PDC. Manual, mechanical and cultural treatment 

methods could be repeated yearly on invasive plant treatment areas if necessary to achieve 

adequate control of invasive plants. Even with the larger number of acres proposed for treatment 

with manual, mechanical and cultural treatment methods, the risk of adverse effects on water 

quality due to sedimentation is expected to be low because PDC (Section 2.2) would reduce that 

risk. 

Cumulative Effects – Alternative 3 

As described in the cumulative effects section of Alternative 2, actual treated acres comprise a 

very small percentage of actual fifth-field watershed acres. Since the amount of herbicide used is 

less than Alternative 2, concern over cumulative effects associated with herbicide application is 

less than Alternative 2, which is very low. This is due to less herbicide used overall, 

implementation of PDC that would minimize the amount and type of herbicides that actually 

reach surface water, the distance between potential treatment areas as well as dilution over time 

and space by mixing and additional inflow from downstream tributaries and ground-water 

entering streams. It is unlikely that herbicide exposure from invasive plant treatments would add 

or accumulate in-stream because the herbicides considered in this EIS do not bio-accumulate 

Forest streams listed on the 303 (d) list for sediment displayed in the Exiting Condition section 

are located in the Fivemile and Fifteenmile fifth-field watersheds. The number of acres treated in 

the riparian reserve is the same as Alternative 2 (61 and 14 acres respectively) for these two 

watersheds, but all of these acres would be treated using manual or mechanical methods instead 

of manual, mechanical and herbicide. This acreage only represents 0.5 and 1.9 percent of the 

total riparian reserve in each of the watersheds respectively, which is a very small percentage of 

the total. As described above, road density could be used as an indicator of the amount of past 

and present human disturbance, and the resulting levels of sedimentation. Fivemile and 

Fifteenmile fifth-field watersheds have road densities of 1.02 and 0.37 mi/mi2

 respectively. 

These watersheds have low relative road densities when compared to the other fifth-field 

watersheds in the analysis (14 and 20 highest road densities out of the 24 fifth-field watersheds 

analyzed in this document). These represent moderate to low relative road densities, which when 
Site-Specific Invasive Plant Treatments 

3-109

coupled with the low amount of proposed disturbance in riparian reserves, PDC to reduce 

erosion and sediment delivery, and apparent improving trend related to sedimentation identified 

in the draft WQRP would result in negligible sediment related cumulative effects. 

3.9.4. Early Detection/Rapid Response Strategy 

Total treatment acres for the EDRR would be similar to those outlined in Alternative 2 and 3 for 

each fifth-field watershed. The anticipated treatment acres are shown in Appendix J and are 

equivalent to what was analyzed in this document. Since this acreage is generally located in the 

same fifth-field watersheds, many of the physical characteristics that influence herbicide 

concentration and erosion would be similar for new treatment areas. The proposed program of 

work would periodically be reviewed to ensure, among other things, that new site meet the 

conditions outlined in this document (see Section 2.1.3). Due to this in conjunction with the 

PDC, the potential effects of EDRR herbicide, manual, mechanical and cultural effects 

treatments are expected to be similar to those described above for Alternatives 2 and 3. 

The EDRR proposes to treat up to 13,000 acres annually across the Forest and Scenic Area and 

would be limited as described in Chapter1 and 2 of this document. This has the potential to 

create cumulative effects through repeated treatments over a long period of time. Concern from 

herbicide application is low, due to implementation of PDC that would minimize the amount and 

type of herbicides that actually reach surface water, the distance between potential treatment 

areas as well as dilution over time and space by additional inflow from downstream tributaries 

and ground-water entering streams. Exposure of ground that has been treated to remove invasive 

plants has the potential for erosion and resulting sedimentation. Sites that were treated in prior 

years would be in a variety of states of recovery ranging from full native plant re-vegetation to 

recently treated, seeded and mulched. According to the soils analysis (Section 3.8), erosion is 

expected to be less on treated sites when compared to the No Action Alternative due to the 

presence of new native vegetation and PDC that include seeding, mulching and restricting 

vehicle access. Since this erosion is less than what is present at the site prior to treatment, 

resulting sedimentation is expected to be less as well. The long-term result is an expectation that 

these sites would be closer to natural rates of erosion and sedimentation due to the recovery of 

native vegetation. 

3.9.5. Aquatic Conservation Strategy Objectives 

In order for a project to proceed, “a decision maker must find that the proposed management 

activity is consistent with the Aquatic Conservation Strategy objectives” (page B-10, ROD, 

USDA Forest Service and USDI BLM, 2001). The nine objectives are listed on page B-11 of the 

Aquatic Conservation Strategy ROD. The effects analysis above has focused on key parameters 

or indicators that make up elements of the nine Aquatic Conservation Strategy objectives, to 

determine if the Invasive Plant EIS project would restore, maintain, or degrade these indicators. 

Once this determination has been made, the indicators should be examined together to make a 

final determination of whether the project is consistent with the objectives. Table 3-27 displays 

the individual indicators and the effect this project has on those indicators at the fifth-field 

watershed scale.
Final Environmental Impact Statement 

3-110

Table 3-27: Water quality indicators and project effects at the fifth-field watershed scale. 

Effects of the Actions 

Alternative 1 

Effects of the Actions 

Alternative 2 

Effects of the A

Alternative 

INDICATORS Restore1 Maintain2 Degrade3 Restore Maintain Degrade Restore Maintain Water Quality Temperature X X X Sediment X X X Chemical Contamination X X X Habitat Access Physical Barriers X X X Habitat Elements Substrate X X X Large Woody Debris X X X Pool Frequency X X X Pool Quality X X X Off-channel Habitat X X X Refugia X X X Channel Condition and Dynamics Width/Depth ratio X X X Streambank Condition X X X Floodplain Connectivity X X X Flow/Hydrology Peak/base flows X X X Drainage Network Increase X X X Watershed Conditions Riparian Reserves X X X 1 “Restore” means the action(s) would result in acceleration of the recovery rate of that indicator. 2 “Maintain” means that the function of an indicator does not change by implementing the action(s) or recovery would continue at its c3 “Degrade” means to change the function of an indicator for the worse. 
Site-Specific Invasive Plant Treatments 

3-111

The following summarizes Table 3-27: 

• The proposed project has a risk of adding some minor amounts of sediment and herbicides to 

surface water, but since the amount is insignificant and not expected to affect watershed 

function at the fifth-field scale, the project would maintain this element. 

• It is anticipated that this project would aid in restoration of the riparian reserve conditions by 

allowing native vegetation to return to sites infested by invasive plants. 

• Indicators other than those described in the proceeding paragraph would be maintained as 

outlined in the effects analysis above. 

Table 3-28 displays specific Aquatic Conservation Strategy objectives and the indicators from the 

previous table that comprise each objective. All of the indicators that are checked for a particular 

objective should be evaluated together to determine whether the action maintains or enhances the 

specific Aquatic Conservation Strategy objective. 

Table 3-28: Aquatic Conservation Strategy objectives and water quality indicators. 

Aquatic Conservation Strategy Objectives

Indicators #1 #2 #3 #4 #5 #6 #7 #8 #9 

Temperature X X X X 

Sediment X X X X X 

Chem. Contamination X X X 

Physical Barriers X X X X 

Substrate X X X X 

Large Woody Debris X X X 

Pool Frequency X X 

Pool Quality X X 

Off-Channel Habitat X X X X 

Refugia X X X X 

Width/Depth Ratio X X X 

Streambank Condition X X X X 

Floodplain Connectivity X X X X X X 

Peak/base Flows X X X 

Drainage Network 

Increase X X X 

Riparian Reserves X X X X X X X X 

The following is a summary of how this project compares to the Aquatic Conservation Strategy 

objectives (Aquatic Conservation Strategy ROD B-10): 

• ACS Objective #1. This project would at least maintain, if not enhance the distribution, diversity 

and complexity of watershed and landscape-scale features because of the protection that the 

Riparian Reserves provide to the aquatic and terrestrial systems and restoration of the Riparian 

Reserves through invasive plant eradication. No new road crossings of streams or wetlands are 

proposed, which would maintain the current level of aquatic habitat fragmentation. Channel 

components that contribute to channel complexity (pool quantity and quality, substrate, flows) 

would be maintained due to the existence of the Riparian Reserves. 
Final Environmental Impact Statement 

• ACS Objective #2. The project would maintain spatial and temporal connectivity within and 

between watersheds. Nothing proposed with this project would reduce the spatial and 

temporal connectivity. 

• ACS Objective #3. This project would maintain the physical integrity of the aquatic system, 

including streambanks, side channels (refugia), and channel bottom configurations due to the 

protection provided to Riparian Reserves. PDC aimed at reducing soil compaction and 

erosion, and the lack of any new stream crossings would greatly reduce risks of increased 

peak flow, and resulting bank erosion and channel bed scour. There are no temporary roads 

entering the Riparian Reserves and insignificant short-term inputs of sediment are expected 

to be very localized if they occur. This project would result in long term benefits to Riparian 

Reserve conditions, but it is unclear whether they would be noticeable at the fifth-field scale 

for this objective. 

• ACS Objective #4. This project would maintain water quality necessary to support healthy 

ecosystems through project design criteria and the existence of Riparian Reserves. PDC 

aimed at reducing erosion would maintain the overall sediment levels in the long term, but 

there is a low risk of a short term, limited increase. In addition, PDC aimed at minimizing 

herbicide introduction into surface water as described in the text above, would keep 

concentrations at an insignificant level. Since the amount of these is so small and not 

expected to effect watershed function, the project would maintain this element. 

• ACS Objective #5. This project would maintain sediment regimes through PDC and the 

existence of Riparian Reserves. There is a low risk of slight inputs of sediment from 

treatment areas, but they are anticipated to be very small and localized. 

• ACS Objective #6. This project would maintain in-stream flows through PDC and Riparian 

Reserves. As described in the effects section, no increase in peak flows would result from 

this project. 

• ACS Objective #7. This project would maintain the timing, variability, and duration of 

floodplain inundation through PDC and Riparian Reserves. As described in the effects 

section, no increase in peak flows would result from this project. 

• ACS Objective #8. This project would aid in restoration of the species composition and 

structural diversity of plant communities in riparian areas and wetlands through invasive 

plant eradication, native vegetation establishment and the existence of Riparian Reserves. 

• ACS Objective #9. This project would aid in restoration of habitat to support welldistributed populations of native plant and riparian dependent species through invasive plant 

eradication, native vegetation establishment and the existence of Riparian Reserves. 

3-112
Site-Specific Invasive Plant Treatments 

3.9.6. Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action and 

Restricted Herbicide Use Alternatives are consistent with all relevant standards and guidelines, when 

the proposed amendments are incorporated. The Forest Plan amendments are discussed in Section 

3.16. 

3.9.7. Incomplete and Unavailable Information 

Invasive plant inventories are incomplete, so the locations of future infestations cannot be predicted. 

Recently, a nation-wide database, NRIS/Terra, has been implemented that would enable the tracking 

of existing infestations, the addition of new inventory locations, and the aggregation of invasive 

plant data at regional and national scales. It is unlikely, however, that budget or staff time allotted 

would ever be sufficient to have completely up-do-date inventories of invasive plants across the 

Pacific Northwest Region. 

In addition, the GLEAMS model runs for all surfactants and adjuvants are not available at the time 

of this document. These model results would give a better idea about expected delivery of particular 

chemicals to surrounding surface water, which in turn would help provide a better prediction of 

resulting effects to the aquatic environment. 

3.10. Aquatic Organisms and Habitat 

3.10.1. Existing Conditions 

The following section describes existing distribution and relative status of native and/or culturally 

important salmonid species as well as two aquatic snails on the Forest and Scenic Area. A 

description of habitat conditions, limited to those habitat parameters that could be affected by actions 

proposed in this EIS, follows the salmonid species discussion. Included in the habitat section is a 

description of critical habitat and essential fish habitat. National Marine Fisheries Service (NMFS) 

designates critical habitat based on physical and biological features that are essential to the listed 

species. Essential features of designated critical habitat are: (1) substrate, (2) water quality, (3) water 

quantity, (4)water temperature, (5) water velocity, (6) cover/shelter, (7) food for juveniles, (8) 

riparian vegetation, (9) space, and (10) safe passage conditions (50 CFR 226.212). Essential fish 

habitat is waters and substrate necessary to fish (specifically chinook and coho salmon) for 

spawning, breeding, feeding, or growth to maturity. Most of the information regarding fish 

distribution and habitat conditions was taken from existing Oregon Department of Fish and Wildlife 

and/or USDA Forest Service survey information, much of which is unpublished data. 

3-113
Final Environmental Impact Statement 

Aquatic Organisms 

Salmonids (salmon, trout and char) are used as management indicator species of aquatic habitats in 

the Forest Plan. Due to their value as game fish and their sensitivity to habitat changes and water 

quality degradation, salmonids are used to monitor trends within Forest streams and lakes. Although 

other fish species may be present (e.g., sculpins and dace), population status and trends are 

unknown. Since more information exists on salmonids, this group serves as a better choice for 

monitoring aquatic environments. 

The Forest and Scenic Area are home to several populations of salmon, steelhead, and resident trout. 

There are over 1,600 miles of fish-bearing streams on the Forest, with approximately 300 miles 

supporting anadromous populations of salmon and steelhead. In the Scenic Area, there are 60 miles 

of fish-bearing streams, with 17 miles supporting anadromous species (all land ownerships); 47miles 

of fish-bearing streams, with 10 miles supporting anadromous specis on National Forest System 

lands within the Scenic Area. 

Most salmonids that reside in Forest and Scenic Area streams are an important cultural, economic 

and recreational resource. A number of species are listed as endangered or threatened under the 

Endangered Species Act (ESA), or are sensitive species identified by the USDA Forest Service, 

Pacific Northwest Region, Regional Forester (Table 3-29), by distinct population segment (DPS) or 

evolutionarily significant unit (ESU), which are large geographic areas that usually contain several 

sub-populations of the species considered to be in the same metapopulation. For example, a Lower 

Columbia River ESU steelhead would not be expected to breed with a Middle Columbia River ESU 

steelhead, even though it is the same species. 

3-114
Site-Specific Invasive Plant Treatments 

Table 3-29: Special status species found in Forest and/or Scenic Area streams. The date after 

the listing status is the date of listing or the most recent status review and subsequent Federal 

Register notice.

Species DPS/ESU Status 

Major River Systems 

Where Found 

Bull Trout 

(Salvelinus confluentus) Columbia River DPS Threatened  6/1998 Hood River, Columbia River 

Sandy River, Clackamas River, 

Hood River, West Columbia 

River Gorge Tributaries, 

Columbia River 

Steelhead Trout 

(Oncorhynchus mykiss) 

Lower Columbia River 

ESU 

Threatened 

 1/2006 

Steelhead Trout Middle Columbia River 

ESU 

Threatened 

1/2006 

Fifteenmile, Fivemile, Mill 

Creeks, Columbia River 

Sandy River, Clackamas River, 

Hood River, West Columbia 

River Gorge Tributaries, 

Columbia River 

Chinook Salmon 

(O. tshawytscha) 

Lower Columbia River 

ESU 

Threatened 

6/2005 

Chinook Salmon Upper Willamette River 

ESU 

Threatened 

6/2005 Clackamas River 

Sandy River, Clackamas River, 

Hood River, West Columbia 

River Gorge Tributaries, 

Columbia River 

Coho Salmon 

(O. kisutch) 

Lower Columbia River 

ESU 

Threatened 

6/2005 

Federally Listed Species found only in the Columbia River by the Action Area 

Steelhead Trout Upper Columbia River 

ESU 

Threatened 

1/2006 Columbia River 

Steelhead Trout Snake River ESU Threatened 

1/2006 Columbia River 

Chinook Salmon Upper Columbia River 

ESU 

Endangered 

6/2005 Columbia River 

Chinook Salmon Snake River ESU Threatened 

6/2005 Columbia River 

Columbia River, West Columbia 

River Gorge Tributaries, Sandy 

River 

Chum Salmon 

(O. keta) Columbia River ESU Threatened 1/2006 

Sockeye Salmon 

(O. nerka) Snake River ESU Endangered 6/2005 Columbia River 

USDA Forest Service, Pacific Northwest Region Sensitive Species 

Redband/ Inland Rainbow 

Trout (O. mykiss) Not Applicable (N/A) Sensitive 7/2004 

White River, Mill Creek, BadgerTygh, Fifteenmile, Fivemile 

Columbia duskysnail 

(Lyogyrus n. sp. 1) N/A 

Sensitive - 

7/2004; Survey 

and Manage – 

1/2001 

Throughout Forest/Scenic Area 

Other Species Addressed in this Analysis 

Basalt juga (snail) N/A 

Survey and 

Manage 

1/2001 

Springs and seeps in the Scenic 

Area 

Columbia River, West Columbia 

River Gorge Tributaries, 

Fifteenmile Creek, Mill Creek, 

Sandy River 

Pacific lamprey 

(Lampetra tridentata) N/A Culturally and locally important 

Coastal Cutthroat Trout 

(O. clarki) N/A 

Forest 

Management 

Indicator 

Species 

Throughout Forest/Scenic Area 

except White River and most of 

the Fifteenmile Creek basins. 

3-115
Final Environmental Impact Statement 

Aquatic macroinvertebrates are an important resident of streams, lakes, and ponds in the Forest and 

Scenic Area. Presence, abundance, and status of macroinvertebrate species that reside in area water 

bodies are not well understood. Most streams within the Forest and Scenic Area have good water 

quality within their natural constraints (e.g., glacial streams are naturally turbid at times and carry a 

high sediment load) and habitat conditions are generally favorable. Macroinvertebrate populations 

appear robust and a range of species representing a wide variety of feeding groups (predators, 

grazers, leaf shredders) are usually present, but definitive studies to characterize diversity, richness, 

and biomass are lacking. Therefore, with the exception of the Columbia duskysnail, other aquatic 

macroinvertebrates are discussed collectively in regards to their anticipated response to proposed 

treatments. 

Listed or sensitive species in Table 3-29 were federally listed or designated as sensitive for a number 

of factors. Although there are different reasons for their current status, common issues include 

impaired fish passage at dams and other obstructions, commercial and recreational fishing, habitat 

modification and/or loss, hatchery influences, and pollution. Hydropower, irrigation, domestic water 

supply, and flood control dams have disrupted migrations and eliminated historically available 

habitat. Commercial and recreational fishing have reduced numbers of wild fish in some 

populations. Habitat has been degraded, simplified, and fragmented due to a variety of land 

management activities. Hatchery programs have strongly influenced populations, partly by dilution 

of native gene pools due to interbreeding. Reduced water quality from both point and non-point 

sources has had an impact at localized, and even regional scales, in some watersheds. Impacts to the 

Columbia duskysnail and Basalt juga have primarily been from habitat modification and water 

quality degradation. 

Columbia River Bull Trout 

The only known population of bull trout in the Forest is found in the East Fork Hood River and 

Lower Hood River fifth-field watersheds. Bull trout presence in the Forest has been documented in 

the Middle Fork Hood River, Clear Branch both above and below Clear Branch Dam, Pinnacle 

Creek, Coe Branch, Eliot Branch, Bear Creek, and the mainstem Hood River (Figure 3-5). Most bull 

trout in the Middle Fork Hood River are found primarily within Laurance Lake (reservoir), and in 

Clear Branch and Pinnacle creeks. Clear Branch Dam, completed in 1969, has effectively split the 

Hood River bull trout population into two segments. Above the dam, the population of bull trout is 

believed to exhibit primarily an adfluvial life history: adult fish reside in the reservoir and move into 

Clear Branch or Pinnacle Creek as early as June, spawn mainly during September, and move back 

into the reservoir to spend the winter. There may be a fluvial (completely stream dwelling) 

population component above the reservoir as well. 

Below Clear Branch Dam it is believed there are fluvial and adfluvial subpopulations present, but 

relatively little is known about this segment of the overall population. A small number of individuals 

annually migrate into the Hood River from the Columbia River, and some individuals have returned 

more than once (Hood River Soil and Water Conservation District, 2004; French, 2006). Other large 

bull trout have been observed below Clear Branch Dam that are not tagged, thus leading biologists to 

believe there may be a wholly stream resident population as well. 

3-116

Final Environmental Impact Statement 

Bull trout use of Scenic Area streams is not well understood. Given that some adult bull trout move 

between the Columbia and Hood rivers it is obvious there is some bull trout use in the Columbia 

River mainstem. One tagged adult bull trout from the Hood River was captured by a fisherman in 

Drano Lake, located on the Washington side of the Columbia River about 12 miles downstream of 

the Hood River. Whether adult bull trout migrating out of the Hood River overwinter in the 

mainstem Columbia River and/or utilize other tributaries to the Columbia is not known. Also, there 

may be bull trout that spawn in other river systems besides the Hood River that make use of the 

Columbia River at some point in their lives. 

Bull trout reach sexual maturity between four and seven years of age and are known to live as long 

as 12 years. Bull trout spawn in the fall, and require clean gravel and very cold-water temperatures 

for spawning and egg incubation. Bull trout fry utilize side channels, stream margins, and other low 

velocity areas. Adults require large pools with abundant cover in rivers. Presumably, the various 

forms of bull trout interbreed, which helps to maintain viable populations throughout their range. 

Lower Columbia River Steelhead 

Lower Columbia River steelhead are found in the Clackamas River, Sandy River, Hood River, and 

some West Columbia Gorge tributaries (Figure 3-6), as well as the Columbia River mainstem for 

migration to and from the Pacific Ocean2. Adult winter steelhead enter rivers and streams primarily 

from March through June. A small run of summer steelhead occurs in the Hood River. These fish 

enter the mainstem Hood River from June through September, overwinter in larger tributaries or the 

mainstem, and spawn the following spring. Adult steelhead spawn in late winter to spring (January–

June), depending in part on the run type (summer or winter steelhead), stream discharge and water 

temperature. Steelhead fry emerge from the gravel between late June and late July, and rear in 

freshwater habitat for one to three years. Yearling juvenile steelhead are usually found in riffle 

habitat, but some of the larger juvenile steelhead will be found in pools and faster runs. Smolt 

emigration takes place primarily from March through June during spring freshets. 

In regards to habitat utilization, steelhead are more of an opportunist anadromous species compared 

to Chinook and coho salmon. As such, they are often more widespread and can utilize smaller 

streams more readily than many salmon species. Their stronghold habitats on the Forest and Scenic 

Area tend to be larger rivers and streams. 

 

2

 This use of the Columbia River also applies to other anadromous fish species described herein. 

3-118

Final Environmental Impact Statement 

Middle Columbia River Steelhead 

Middle Columbia River steelhead presence on the Forest is limited to the Fifteenmile, Fivemile, and 

Middle Columbia Mill Creek fifth-field watersheds (Figure 3-6). Also, there are some steelhead that 

ascend tributaries to the Columbia River in the Scenic Area, near The Dalles, Oregon. This stock is 

the eastern-most run of wild winter steelhead trout in the Columbia River Basin3

, and thus, is unique 

at local and regional scales. Steelhead have been documented upstream of the Forest boundary in 

North Fork Mill Creek, Fifteenmile Creek, Ramsey Creek, Fivemile Creek, and Eightmile Creek. A 

barrier falls restricts steelhead from ascending to the Forest in South Fork Mill Creek. Life history 

information and run timing is similar to that described for Lower Columbia River winter steelhead. 

Lower Columbia River Chinook 

Lower Columbia River Chinook salmon occur in the Sandy River and Hood River Basins, the 

Clackamas River Subbasin as well as in some West Columbia River Gorge tributaries (Figure 3-7). 

This ESU is made up of both spring and fall run components. The spring run occurs in the Hood 

River and Sandy systems, while fall run Chinook are present in all three river systems. 

Most spring Chinook salmon in the Hood River Basin ascend the West Fork Hood River, and based 

on available information, use appears to be low in the East and Middleforks of the Hood River. Fall 

Chinook are found only in the mainstem Hood River and up to Punchbowl Falls near the mouth of 

the West Fork Hood River. Fall Chinook are also found in some Columbia River tributaries within 

the Scenic Area. 

Spring Chinook in the Sandy River Basin utilize the mainstem Sandy River and upper basin tributary 

streams, such as the Salmon River, Zigzag River, Still Creek, and Clear Fork of the Sandy River. 

They enter these watersheds from April through August and spawn from August through early 

October. Spring-run Chinook salmon in the Sandy River have been influenced by spring-run 

Chinook salmon introduced from the Willamette River ESU. Analyses, however, suggest that 

considerable genetic integrity still exists in the Sandy River population (Myers et al., 1998). 

Fall Chinook within the Sandy and Clackamas rivers primarily spawn and rear in the mainstem and 

larger tributaries downstream from the Forest. The fall Chinook populations in the Lower Columbia 

River ESU have a large-scale hatchery component and experience relatively high harvest and 

extensive habitat degradation. Most fall run fish emigrate to the marine environment as subyearlings. Modifications in the river environment have altered the duration of freshwater residence. 

Tule fall Chinook salmon return at adult ages three and four; while “bright” fall Chinook salmon 

return at ages four, five, and six. 

 

3

 It has not been confirmed that steelhead in the Mill Creek Watershed or other tributaries to the Columbia River near 

The Dalles are the same genetic stock as those found in the Fifteenmile Creek and Fivemile Creek watersheds. The 

USDA Forest Service assumes these fish are the same, but that has not been validated. 

3-120

Final Environmental Impact Statement 

Upper Willamette River Chinook 

Upper Willamette River spring Chinook salmon occur only in the Clackamas River Subbasin (Figure 

3-7). The ESU consists of both naturally spawning and hatchery produced fish. These spring 

Chinook enter the Clackamas River Subbasin from April through August and spawn from September 

through early October. These fish primarily spawn and rear in the mainstem Clackamas River and 

larger tributaries. Spawning in the upper Clackamas drainage has been observed in the mainstem 

Clackamas from the head of North Fork Reservoir upstream to Big Bottom, the Collawash River, 

Hot Springs Fork of the Collawash River, lower Fish Creek, South Fork Clackamas River, Oak 

Grove Fork, and Roaring River. 

The life history of Upper Willamette River Chinook includes traits from both ocean- and stream-type 

developmental strategies. The timing of the spawning migration is limited by Willamette Falls. High 

flows in the spring allow access to the Upper Willamette River Basin, whereas low flows in the 

summer and autumn prevent later-migrating fish from ascending the falls. The low flows may serve 

as an isolating mechanism, separating this ESU from others nearby. 

Lower Columbia River Coho Salmon 

Coho stocks occurring on the Forest are currently found in the Sandy, Clackamas, and Hood river 

systems, as well as in some West Columbia River Gorge tributaries (Figure 3-8). The indigenous run 

of coho salmon in the Hood River is at a very low level and may be extinct, but there is some natural 

reproduction occurring (French, 2006). The coho salmon that do enter the Hood River appear to 

primarily utilize the mainstem as well as the lower reaches of the East Fork Hood River. 

The Clackamas River contains an early run stock and the last significant run of wild late-winter coho 

in the Columbia River Basin. Spawning occurs mid-September to the end of April with the peak 

occurring mid-February. Adults prefer deep pools and tributaries for over-wintering, while juveniles 

will seek out inundated floodplains and other protected slow-water habitats, such as side channels 

and slow water pools. Woody debris and habitat diversity are important to this species. Primary 

streams utilized in the Sandy River Basin include the Sandy River, Salmon River, Still Creek, and 

Zigzag River. In the Clackamas River, coho are found mostly in the Clackamas River, Collawash 

River, Fish Creek, Oak Grove Fork, and Hot Springs Fork. 

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Final Environmental Impact Statement 

Listed Species Found Primarily in the Columbia River 

The six anadromous salmonid stocks discussed below use the Columbia River primarily as a 

migration corridor to and from spawning and primary rearing areas in the middle and upper 

Columbia River Basin, well upstream of the action area described in this EIS. Both adults and 

juveniles migrate through the Columbia River Gorge during certain times of the year, and could be 

present during periods when invasive plant treatments occur. The period of time they spend in the 

Columbia River Gorge, however, is believed to be relatively brief, especially adults. With the 

exception of chum salmon, none of these species are known to utilize the Columbia River mainstem 

in the Scenic Area or Oregon tributaries for spawning or primary rearing. 

Adult anadromous salmon and steelhead migrate in the main channel of the Columbia River, 

generally mid-channel and in the upper 25 feet (range one to 50 feet) of the water column. 

Outmigrating juveniles (smolts) tend to use near shore and off-channel habitat, but also will use midchannel and deeper water habitats where the velocity is greater. Juvenile downstream migration 

behavior and timing (Table 3-30) varies greatly depending on species, age, season, photoperiod and 

habitat availability. Data for chum salmon are from seining data at various locations below 

Bonneville Dam as that is where most Columbia River salmon reside. 

Table 3-30: Downstream juvenile migration timing for six federally listed salmonid stocks 

based on passage at Bonneville Dam. Data was taken from the Bonneville Dam Fish Passage 

Center for 2001-2005, except for chum salmon which is based on seining data below Bonneville 

Dam. The period between the dots is the primary migration period, but some individuals migrate 

during the longer period designated by the diamonds.

Mar Apr May Jun Jul Aug Sept Oct Nov 

Spring 

Chinook 

Fall Chinook 

Steelhead 

Sockeye 

Coho 

Chum 

• Upper Columbia River Steelhead: This inland steelhead ESU encompasses the Columbia 

River Basin upstream from the Yakima River to the United States/Canada border. Adults return 

to the Columbia River in late summer and early fall, and most migrate quickly upstream to their 

natal streams. Some individuals, however, overwinter in mainstem Columbia River reservoirs 

and then ascend over dams in the middle Columbia River in April and May. 

• Snake River Steelhead: The Snake River steelhead ESU is distributed throughout the Snake 

River drainage system, including tributaries in southwest Washington, eastern Oregon and 

north/central Idaho. Snake River Basin steelhead are generally classified as summer run, based 

on their adult run timing patterns. Summer steelhead adults enter the Columbia River from late 

June to October and would be expected to migrate upstream through the Columbia River Gorge 

primarily in July and early August. 

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Site-Specific Invasive Plant Treatments 

• Upper Columbia River Spring Chinook: The drainages encompassing this ESU are between 

the Rock Island and Chief Joseph dams on the upper Columbia River. Adults would migrate 

upstream through the Columbia River Gorge primarily from March through May. 

• Snake River Chinook (spring, summer and fall runs): This run consists of spring and summer 

Chinook salmon returning to the major tributaries of the Snake River. Snake River spring 

Chinook adults migrate through the Columbia River Gorge from March through June, and 

summer run adults would pass from June into September. Snake River fall run Chinook salmon 

enter the Columbia River in July and August and move quickly upstream as they are seen at the 

lower Snake River mainstem dams from August through November. 

• Columbia River Chum: Chum salmon in the Columbia River once numbered in the hundreds of 

thousands of adults and, at times, approached a million per year. The total number of chum 

salmon returning to the Columbia River in the last 50 years has averaged perhaps a few thousand 

per year. The majority of the Columbia River chum salmon populations spawn and rear in the 

Columbia River and tributaries below Bonneville Dam. Some spawning has been documented in 

the mainstem Columbia River, as well as several tributaries in Washington. Spawning in Oregon 

tributaries below Bonneville Dam has not been documented. 

Up to several hundred adult chum salmon per year ascend Bonneville Dam, but little is known 

where of all these fish spawn. On the Oregon side of the river small numbers have been 

documented spawning in Eagle Creek and others in shoal areas of the Columbia itself near 

Multnomah Falls (Fiedler, 2006). Spawning in other Oregon tributaries to the Columbia River is 

possible. Columbia River chum enter the Columbia River beginning in late September, and 

spawning peaks November through December. Fry emerge from the gravel from February to 

April, and typically out-migrate within a month of emergence.

• Snake River Sockeye: This run of sockeye spawns at the highest elevation, and has the longest 

freshwater migration (over 900 miles) compared to any other sockeye population in the world. 

Adults return into the Columbia River in summer, with peak migration over Bonneville Dam in 

July. 

USDA Forest Service, Pacific Northwest Region Sensitive Species 

• Redband Trout: Redband/inland rainbow trout (redband trout) occur in the White River, Tygh 

Creek, Fifteenmile Creek, Fivemile Creek, and Middle Columbia/Mill Creek fifth-field watersheds 

on the Forest (Figure 3-9). Redband trout populations within the White River and Tygh Creek 

watersheds are genetically distinct from those in the Deschutes River and are unique among other 

redband trout populations east of the Cascades (Currens et al., 1990). Rainbow trout within the 

other watersheds listed above may be the redband subspecies (Behnke, 1992), but definitive genetic 

analysis has not been conducted. 

3-125
Final Environmental Impact Statement 

Spawning occurs in the spring, fry emergence from the gravel normally occurs by the middle of 

July, but depends on water temperature and exact time of spawning. Redband rainbow trout 

prefer water temperatures from 50 to 57 oF, but have been found actively feeding at temperatures 

up to 77 oF in high desert streams of Oregon and have survived in waters up to 82 oF. 

• Columbia Duskysnail: This species of aquatic mollusk has been found across the Forest during 

surveys conducted over the past several years (Mt. Hood National Forest, unpublished data). 

Although surveys have not been conducted in the Scenic Area, they are likely present in habitats 

described below. Habitat requirements for this species are fairly specific: cold, well oxygenated 

springs, seeps, and small streams, preferring areas without aquatic macrophytes (Furnish and 

Monthey, 1998). Individuals have not been found in larger streams and rivers, or glacial streams. 

Surveys for the Columbia duskysnail have been conducted at sites across the Forest for a wide 

range of projects. This mollusk has been found in many areas across the Forest and is likely to be 

present in seeps, springs, and smaller streams near some sites proposed for invasive plant 

treatment in this EIS. 

The Columbia duskysnail (and Basalt juga, discussed below) is also a Survey and Manage 

species as outlined in the Northwest Forest Plan. The Forest Plan was amended by the 2001 

Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, 

Protection Buffer, and other Mitigation Measures Standards and Guidelines. Annual species 

reviews have been conducted since 2001 to incorporate the new information gained from surveys 

and from other research. Changes to species lists were made that include moving species to 

different categories, changing their range or taking them off the list. The most recent annual 

species review was documented in a memo on December 19, 2003. 

The decision to conduct surveys for all survey and manage species lies with the line officer based 

on input from resource specialists (USDA Forest Service and USDI BLM, 2001). The line officer 

needs to consider the probability of species presence as well as the probability that the project 

would cause a significant negative effect on the species habitat or the persistence of the species at 

the site. Surveys for the two survey and manage aquatic mollusks would not be conducted as part 

of this project, even though presence of the Columbia duskysnail at least is likely, because 

anticipated effects would not significantly affect habitat or species persistence at each site. 

3-126

Final Environmental Impact Statement 

Other Important Aquatic Species 

• Basalt Juga: These small snails have only been found at two location within the Oregon 

portion of the Scenic Area: in Canyon Creek just west of the town of Hood River and in 

several small seeps just above (south) Interstate 84 about half-mile east of The Dalles Dam. 

Individuals have been found at several locations on the Washington side of the Scenic Area 

and east of the Scenic Area on both sides of the river. They have never been found in any 

survey conducted on the Forest, and they are not believed to reside in Forest streams. Their 

habitat requirements appear similar to the Columbia duskysnail’s (Furnish and Monthey, 

1998). Given known locations, any small seeps, springs or streams within the Scenic Area 

are potential habitat where they may reside. 

• Pacific lamprey: Relatively little is known about Pacific lamprey distribution and population 

status in streams within the Forest and Scenic Area. These fish have been documented in 

various watersheds including West Columbia River Gorge Tributaries, Fifteenmile Creek, 

Mill Creek, and Sandy River, as well as the Columbia River itself. Pacific lamprey are 

culturally important to indigenous tribes in the area and some tribal fishing does occur in 

Fifteenmile Creek near the mouth. 

The mapped distribution (Figure 3-10) reflects the known distribution based on spawning 

surveys, smolt trapping and personal observations by Forest Service fisheries personnel. It is 

likely they are more widespread than indicated in Figure 3-10, especially in Columbia River 

tributaries and the Sandy River Basin. A falls near the mouth of the White River is a 

complete barrier to all fish species thus Pacific lamprey are not present in this watershed 

upstream of that point. Dam barriers in the Hood and Clackamas rivers appear to preclude 

lamprey upstream, although some lamprey may ascend past North Fork Dam on the 

Clackamas. 

Pacific lamprey have a unique life history (Wydoski and Whitney, 2003). The adults spawn 

from April through July in streams. Eggs hatch in about three weeks and the larvae burrow 

into silt and mud in slower areas of coldwater streams. The larvae live in the stream bottom 

like this for four to seven years at which point they metamorphose into adults and migrate to 

the Pacific Ocean to begin their adult, parasitic lifestyle. 

• Coastal cutthroat trout: Cutthroat trout occurring in waters of the Forest and Scenic Area are 

composed of two native stocks: an anadromous (sea-run) form and resident stock. These fish are 

a Management Indicator Species on the Forest and Scenic Area. Resident populations of 

cutthroat are widespread throughout much of the Forest and Scenic Area (Figure 3-9). 

Historically, sea-run cutthroat trout occurred in the Clackamas River, Sandy River, and Hood 

River, but these anadromous cutthroat populations appear to have greatly declined throughout 

these watersheds. Consistent indicators in abundance trends for most populations of either 

resident or sea-run cutthroat trout do not exist. Coastal cutthroat trout tend to spawn in very 

small (first- and second-order) tributaries. They spawn from December to May; young emerge 

from gravel during June and July. Young fry move into channel margin and backwater habitats 

during the first several weeks. During the winter, juvenile cutthroat trout use low velocity pools 

and side channels with complex habitat created by large wood. Coastal sea-run cutthroat 

juveniles rear in freshwater for two to three years. 

3-128

Final Environmental Impact Statement 

Critical Habitat 

Critical habitat has been designated for Columbia River bull trout, Lower Columbia River steelhead 

trout, Mid-Columbia River steelhead trout, Lower Columbia River Chinook salmon, and Upper 

Willamette River Chinook salmon. Much of the discussion concerning critical habitat, including 

effects analyses, will center on the primary constituent elements (PCE) described below for each 

species. 

Bull Trout Critical Habitat 

Bull trout critical habitat has been designated in the mainstem Hood River, West Fork Hood River, 

Middle Fork Hood River, and a short section of the East Fork Hood River (70 Federal Register 

56233, September 26, 2005) (Figure 3-11). The upper limit of designated critical habitat was halted 

at the Forest boundary in the West Fork and Middle Fork. No bull trout critical habitat was 

designated elsewhere on the Forest or Scenic Area. 

The PCE of bull trout critical habitat are derived from studies of bull trout habitat requirements, life 

history characteristics, and population biology. The PCE are: 

• Permanent water having low levels of contaminants such that normal reproduction, growth 

and survival are not inhibited. 

• Water temperatures ranging from 36 to 59 0

F, with adequate thermal refugia available for 

temperatures at the upper end of this range. Specific temperatures within this range will vary 

depending on bull trout life history stage and for geography, elevation, diurnal and seasonal 

variation, shade, such as that provided by riparian habitat, and local groundwater influence. 

• Complex stream channels with features such as woody debris, side channels, pools, and 

undercut banks to provide a variety of depths, velocities, and instream structures. 

• Substrates of sufficient amount, size, and composition to ensure success of egg and embryo 

over-winter survival, fry emergence, and young-of-the-year and juvenile survival. A minimal 

amount of fine substrate less than 0.25 inch in diameter and minimal substrate embeddedness 

are characteristic of these conditions. 

• A natural hydrograph, including peak, high, low, and base flows within historic ranges or, if 

regulated, a hydrograph that demonstrates the ability to support bull trout populations. 

• Springs, seeps, groundwater sources, and subsurface connectivity to contribute to water 

quality and quantity. 

• Migratory corridors with minimal physical, biological, or chemical barriers between 

spawning, rearing, over-wintering, and foraging habitats, including intermittent or seasonal 

barriers induced by high water temperatures or low flows. 

• An abundant food base including terrestrial organisms of riparian origin, aquatic 

macroinvertebrates, and forage fish. 

• Few or no predatory, interbreeding or competitive non-native species present. 

3-130

Final Environmental Impact Statement 

Steelhead Trout and Chinook Salmon Critical Habitat 

Critical habitat for several evolutionarily significant units of the above species was designated in 

September 2005 by the NMFS (70 Federal Register 52630, September 2, 2005). Unlike bull trout 

critical habitat, which did not include stream reaches on the Forest and Scenic Area, critical habitat 

for steelhead and Chinook encompasses a large amount of the available habitat across all land 

ownerships. Lower Columbia River steelhead and Chinook critical habitat is the most ubiquitous 

across the Forest and Scenic Area because these species are the most widespread (Figure 3-12). MidColumbia River steelhead critical habitat is present only in the Fifteenmile and Mill Creek 

watersheds on the eastside of the Forest, and some small tributaries to the Columbia River in the 

Scenic Area. Critical habitat for Upper Willamette River Chinook is centered in the Clackamas 

River Subbasin (Figure 3-13). 

Primary constituent elements for steelhead and Chinook are sites and habitat components that 

support one or more life stages. The first three, listed below, refer to freshwater habitat components, 

whereas the last three relate to estuarine or marine habitat components. Nothing proposed in any 

alternative would have an affect on estuarine or marine habitat components, thus they are not 

discussed. 

• Freshwater spawning sites with water quantity and quality conditions and substrate 

supporting spawning, incubation and larval development. 

• Freshwater rearing sites with: 

→ Water quantity and floodplain connectivity to form and maintain physical habitat 

conditions and support juvenile growth and mobility; 

→ Water quality and forage supporting juvenile development; and 

→ Natural cover such as shade, submerged and overhanging large wood, log jams and 

beaver dams, aquatic vegetation, large rocks and boulders, side channels, and undercut 

banks. 

• Freshwater migration corridors free of obstruction and excessive predation with water 

quantity and quality conditions, and natural cover, such as submerged and overhanging large 

wood, aquatic vegetation, large rocks and boulders, side channels, and undercut banks 

supporting juvenile and adult mobility and survival. 

3-132


Site-Specific Invasive Plant Treatments 

Essential Fish Habitat 

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (Public Law 104-267), established procedures designed to 

identify, conserve, and enhance essential fish habitat (EFH) for those species regulated under a 

Federal fisheries management plan – in this case Chinook and coho salmon. Section 305(b) of the 

MSA directs Federal agencies to consult with NMFS on all proposed actions that may adversely 

affect EFH. Adverse effects include direct or indirect physical, chemical, or biological alterations of 

the waters or substrate and loss of, or injury to, benthic organisms, prey species and their habitat, and 

other ecosystem components, if such modifications reduce the quality or quantity of EFH. 

Pacific salmon (Chinook and coho) EFH was designated in 1999, but the actual identification of 

stream reaches considered to be EFH was left to the action agencies, such as the USDA Forest 

Service. EFH is coincident with Chinook salmon critical habitat where it’s designated. In addition, 

however, are streams within the Fifteenmile Creek and Mill Creek watersheds that support either 

Chinook and/or coho, but were not designated as critical habitat. Specifically, the USDA Forest 

Service considers the following stream segments as EFH: Fifteenmile Creek from its mouth to the 

Forest boundary; Eightmile Creek from its mouth to the Forest boundary; Mill Creek from its mouth 

to the confluence of the North and South Forks; South Fork Mill Creek from its mouth to the 

impassable falls at near river mile 2.3; and North Fork Mill Creek from its mouth to the Forest 

boundary. 

There are several streams in the Scenic Area that contain EFH. Most of these stream segments are 

short as the distance between creek mouths and natural impassible barrier falls is often less than onehalf mile. There are a few exceptions, however, such as the Sandy River, Tanner Creek, Herman 

Creek, and Viento Creek, which all have a mile or more of EFH. 

Aquatic Habitat Conditions 

Aquatic habitat conditions across the Forest and Scenic Area vary depending on the location, past 

land management activities, and natural events such as floods, fire, and debris torrents. In general, 

streams that have experienced little to no land management are in good condition even though Forest 

Plan standards (i.e., pools per mile, pieces of wood per mile) are not always met. Some of these 

streams have been impacted by natural events and, indeed, were formed or maintained by such 

events. Glacial streams such as White River, Newton Creek and Eliot Branch of the Hood River are 

examples of streams exhibiting relatively degraded conditions due to natural events (in this case 

repeated glacial debris flows). 

Fish habitat conditions within watersheds where land management has occurred range from poor to 

good, depending on the type and scale of disturbance, proximity to streams, and duration of land 

management activities. On the westside of the Cascades, watersheds have been affected by logging, 

dams, road construction, and past flood control activities. Some grazing has occurred in the 

Clackamas River Subbasin. On the eastside, major land management activities contributing to 

degraded aquatic habitat have included logging, road construction, irrigation, agriculture, and 

grazing. Separately and cumulatively, these activities have resulted in some loss of connectivity, 

reduction of stream shading, alteration in riparian vegetation and function, increased sedimentation, 

reduced instream large woody debris, and loss of pools. 

3-135
Final Environmental Impact Statement 

Despite past impacts, most streams or stream segments contain good quality habitat. There are no 

streams with degraded conditions over their entire length within the Forest and Scenic Area, even 

those streams listed on the DEQ 303d list. A common scenario is shorter stream segments 

experiencing some impairment interspersed with good habitat quality reaches. Water quality, in 

terms of temperature and fine sediment is good to excellent across most of the Forest and Scenic 

Area with few streams listed on the DEQ 303d list (See Table 3-22 in Section 3.9 – Water Quality), 

but in some streams habitat conditions decline further downstream. 

Actions proposed in all alternatives would not affect physical stream habitat parameters such as pool 

quantity and quality, large woody debris levels, channel geometry, stream flow, or the amount of 

spawning size gravel. Treatment of invasive plants would not target conifers or deciduous trees, thus 

impacts to these species and the benefits they provide as habitat elements would be negligible. As 

such, there will be no further discussion of these parameters, including describing existing 

conditions. 

Instead, existing habitat conditions and subsequent analysis will focus on those habitat elements that 

could be affected by invasive plant treatment: water temperature, fine sediment levels, water chemistry, 

dissolved oxygen, and nutrients. Existing conditions for these elements focus on areas where 

conditions are poor, because the vast majority of streams within the Forest and Scenic Area are in good 

condition based on available information from water quality and physical habitat surveys. A detailed 

discussion of these elements can be found in Section 3.9 - Water Quality. The discussion below focuses 

on the relationship between these habitat elements and fish populations/habitat. 

Water Temperature 

Water temperatures across the Forest and Scenic Area are generally cool and fall within preferred 

ranges for salmonids. Preferred temperatures vary by species and lifestage, but generally range from 

10-16 oC for many salmonids, although spawning often occurs at lower temperatures (Bjornn and 

Reiser, 1991). Some streams near the forest boundary exceed 16 oC in late summer and fall, but there 

are no known streams within the Forest and Scenic Area where water temperatures approach lethal 

limits of 23-29 oC. In terms of fish and other aquatic animal requirements, shade is most important in 

water temperature regulation. Primary shade producing elements within the Forest and Scenic Area 

are coniferous and deciduous trees and, to some extent, topography. The amount of shade varies 

across the Forest and Scenic Area, and in some cases shade has been reduced due to land management 

activities such as timber harvest, roads, and grazing. 

Fine Sediment 

Levels of fine sediment (defined here as sand or silt <1 mm in diameter) in spawning habitat or 

riffles within stream reaches across the Forest and Scenic Area vary widely depending on a variety 

of factors, including parent soil type, stream size, gradient, flow regime, water source (e.g., glacial, 

spring-fed, snowmelt), and past land management activities. Many streams on the Forest in 

particular have naturally high sediment loads given their glacial origin. Local fish stocks and other 

stream dwelling animals have evolved to survive in these conditions. Many studies have taken place 

to try and determine the amount of fine sediment in spawning gravel that limits survival of salmonid 

embryos. Many investigators have accepted that significant embryo mortality can be expected when 

fine sediment (particles <0.8 mm in diameter) approaches or exceeds 20 percent of the redd (Waters, 

1995) 

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Site-Specific Invasive Plant Treatments 

As mentioned above, there are segments of some streams with high amounts of fine sediment that 

may be detrimental to salmonid spawning and egg incubation, reduce insect production or survival, 

and may decrease available rearing habitat by filling pools or other slow water areas. In glacial 

streams, such as the East Fork Hood River, this is largely a natural phenomenon. In non-glacial 

streams within the Forest the amount of fine sediment in suitable spawning areas and riffles can 

exceed 20 percent, thus exceeding the standards set in the LRMP. This standard is exceeded in 

streams that have experienced little to no land management indicating the source is natural, at least 

in some areas. 

Water Chemistry 

There are no known streams or stream reaches within the Forest or Scenic Area that are impaired for 

water chemistry (in this context water chemistry refers to the presence of herbicides, pesticides, or 

other chemicals). Herbicide application to control invasive plants to date has been limited (see 

Section 3.10.2.1). Likewise, the use of pesticides, fertilizers, and other chemicals agents within the 

Forest and Scenic Area has not been a common occurrence. Mining utilizing cyanide leach methods 

has not occurred in this area. As such, surface waters do not contain large amounts of chemicals and 

there are no areas with long standing chemical sources leading to degraded conditions for aquatic 

organisms. 

Dissolved Oxygen 

Dissolved oxygen (DO) levels, which are tied to water temperature, are believed to be well within 

the tolerable range for salmonids in streams across the Forest and Scenic Area. Salmonid DO 

requirements vary somewhat depending on the life stage (Bjornn and Reiser, 1991); incubating eggs 

in the gravel may be the most susceptible to low DO levels. Results from the literature vary, but 

levels of 8 mg/L or higher have been correlated with high survival of embryos and alevins. 

Spawning and rearing salmonids can survive DO concentrations <5 mg/L, but growth, food 

conversion efficiency, and swimming performance may be adversely affected (Bjornn and Reiser, 

1991). In summary, DO levels above 8 mg/L appear to satisfy living requirements for adult and 

juvenile salmonids. 

Forest and Scenic Area streams where DO has been measured, which are relatively few (at least on a 

regular basis), generally have DO levels in excess of 8 mg/L. Since DO is linked closely with water 

temperature (increased water temperatures decrease the solubility of DO in the water, thus 

decreasing DO levels), and since water temperatures are well within the tolerable range for 

salmonids across the Forest and Scenic Area, it is assumed that DO levels naturally fall within the 

acceptable range. 

3-137
Final Environmental Impact Statement 

3.10.2. Effects Analysis4

3.10.2.1. Alternative 1 – No Action Alternative 

Actions proposed in this alternative would continue already approved invasive plant treatments at 

locations across the Forest and Scenic Area. Using 2003 as an example, 1,235 total acres were 

treated with over half (58 percent) of the total acres estimated to lie within riparian reserves and an 

estimated 23 percent within the aquatic influence zone (AIZ) (Table 3-31). Within the Forest, the 

vast majority of sites were located on the Barlow Ranger District within the White River, Middle 

Deschutes River, and Tygh Creek fifth-field watersheds, although there were relatively large areas 

available for treatment in the Upper Sandy River and Middle Clackamas River watersheds. Most 

treatment in the Scenic Area occurred in the Sandy River Delta. 

Table 3-31: Acres treated within upland areas, riparian reserves, and the aquatic influence 

zone in 2003 within the Forest and Scenic Area. The total acres treated was the actual amount 

treated, but the area within each land type was estimated based on the percentage of each land 

type treated from 1999-2003. 

Acres (and Percent of Total) of Treatment 

Land Type Scenic Area Forest Total 

Upland Area 142 (21%) 381 (68%) 523 (42%) 

Riparian Reserve 533 (79%) 179 (32%) 712 (58%) 

Aquatic Influence Zone 160 (24%) 118 (21%) 278 (23%) 

Total Acres Treated* 675 560 1235 

* Note the total acres treated is the sum of the upland area and riparian reserve area 

only. The riparian reserve area includes the aquatic influence zone.

 

4

 Additional information regarding the impacts of this project on fish species is contained in Fisheries Biological 

Evaluation and Fisheries Biological Assessment. Also, additional information on a variety of aquatic species is 

available in Appendix W – Summary Tables of Site-Specific Herbicide Effects for Various Aquatic Species. 

3-138
Site-Specific Invasive Plant Treatments 

Direct and Indirect Effects 

Existing treatments already occurring under existing NEPA are not extensive or aggressive enough 

to eradicate, or even control, existing invasive plant infestations. In addition, many new infestations 

would not be treated under this alternative. As a result, the biggest effect of the No Action 

Alternative on aquatic organisms and ecosystems is the continued existence and spread of invasive 

plants that could out-compete native vegetation. Severe infestations of some invasive plant species 

could negatively affect a variety of riparian functions at the site-specific scale including shade and 

soil stability. Although not every infestation would reduce aquatic habitat quality, there is an 

increase in the risk of accelerated impairment without aggressive treatment. 

Direct and indirect effects from both herbicide and non-herbicide treatments are possible under this 

alternative. Effects have already been described in the environmental analyses that lead to approval 

of existing invasive plant treatments. There are stipulations regarding treatments in riparian areas in 

each of the environmental analyses that limit effects to aquatic species and habitat. These 

stipulations vary but include no herbicide treatment buffers, no spray buffers, and no mechanized 

equipment zones adjacent to streams. In addition, prevention practices included in the Invasive Plant 

ROD (2005b) would be applied to currently approved treatments, providing an additional layer of 

protection for aquatic resources. 

Cumulative Effects 

Cumulative effects on aquatic fauna and flora from invasive plant treatment across the Forest and 

Scenic Area are possible given repeated treatments each year and over the course of several years, as 

well as from past, present and future land management activities across all land ownerships that 

could affect the habitat elements described above. The cumulative effects analysis discussed herein, 

and for Alternatives 2 and 3 below, address the past, present and future invasive plant treatments 

across the project area and downstream on salmonids, macroinvertebrates, and aquatic plants/algae. 

The physical scope of this cumulative effects analysis incorporates the entire Forest and Scenic 

Area, as well as non-federal lands located within the fifth-field watersheds that lie partially on the 

Forest and Scenic Area (See Section 3.2.4). Discussion of the latter is tempered with the knowledge 

that herbicide use and other activities that could contribute to cumulative effects are extensive, plus 

there is no known tracking system or database that definitively summarizes such activities. The time 

scale associated with this cumulative effect analysis is 10 to 15 years. 

Land management activities to be considered in this analysis are those that could affect the habitat 

and biological elements discussed above, primarily shade, water temperature, nutrients, dissolved 

oxygen, food resources, and fine sediment and turbidity. Site-specific and cumulative effects from 

herbicides on aquatic fauna and flora are discussed in the Alternatives 2 and 3 sections. The full 

scope of activities that could affect one or more of the above elements is extensive; this discussion 

will focus on those that are believed to have a larger potential impact. These activities are as follows: 

3-139
Final Environmental Impact Statement 

• Timber harvest 

• Road building and maintenance 

• Agricultural practices 

• Herbicide application 

• Urban influence 

The following discussion details potential or expected effects on habitat and biological elements 

from each of the land management activities. It is organized by the element being discussed as one 

or more land management activities could affect any given element. A comparison of invasive plant 

treatment effects under the No Action Alternative to other activities is presented. Much of the 

following discussion would apply to cumulative effects associated with the two action alternatives 

and thus will be referred to extensively in those sections. 

Water Temperature 

Water temperature is closely linked to the amount of shade provided by vegetation, although other 

factors such as stream flow also help moderate temperatures. The activities described above that 

could reduce shade (e.g., timber harvest, roads, grazing) also could lead to corresponding increases 

in water temperature, if the amount of shade removed or artificially maintained at a low level affects 

long reaches of stream. Summer water temperature increases resulting from shade loss are more 

pronounced in small streams, especially on the eastside of the Cascades where summer air 

temperatures are generally warmer for longer periods of time. 

Aside from shade reduction, the only other land management activity implemented as part of any of 

the above activities that could have a potentially large impact on water temperature are water 

withdrawals for irrigation, power production, and/or municipal use. Water withdrawals for these 

purposes occur at a large number of locations across the Forest and Scenic Area, as well as from 

downstream reaches. Increases in water temperature from water withdrawals would be more likely in 

smaller streams, reasoning that a higher percentage of the total flow would be diverted, and on the 

eastside of the Cascades where less water in streams, coupled with warmer air temperatures, would 

result in water temperature increases. There are certainly instances, however, where large streams 

experience significant water withdrawals during times of the year when increased water 

temperatures result downstream. The East Fork Hood River near the town of Parkdale (below the 

Forest) is one example. 

As previously mentioned, there has been an extensive effort to monitor water temperature in streams 

across the Forest and Scenic Area, and with a few exceptions these streams meet Oregon DEQ water 

temperature criteria. It appears then, that although water temperatures in streams within the Forest 

and Scenic Area may have risen as a result of shade reductions or water withdrawals, there are few 

instances where these increases lead to DEQ standards not being met. Below the Forest boundary, 

especially east of the Cascade crest, many streams reaches do not meet DEQ temperature standards 

for a variety of reasons. 

3-140
Site-Specific Invasive Plant Treatments 

Potential increases in water temperature resulting from invasive plant treatments authorized in the 

No Action Alternative would not lead to a cumulative increase in water temperature in any stream 

within the Forest or Scenic Area, or downstream from either the Forest or Scenic Area. This is based 

on the very small amount of typical riparian treatment across all fifth-field watersheds. These 

treatments would not reduce shade enough to increase water temperatures due to the small size of 

treated area and the fact that the majority of species treated do not provide shade. 

Nutrients and Dissolved Oxygen 

These two habitat elements are discussed together as they often are interrelated, although DO levels 

are also correlated with water temperature. Increased nutrient levels in area streams could result 

from a variety of factors including, but not limited to, fertilizer application near or in streams, large 

amounts of decomposing vegetation, point or non-point pollution sources that increase nitrogen 

and/or phosphorus levels, and the presence of reservoirs that could act as nutrient sinks, releasing 

nutrient rich water compared inflow conditions. Increases in nutrients could stimulate algae and 

macrophyte growth, which in turn could lead to increased oxygen demand and subsequent reductions 

in DO. 

Of the land management activities presented above, agricultural practices would have the highest 

potential to increase nutrient levels in area streams. As such, most increases, both in the past and 

foreseeable future, would occur primarily on non-federal land. One exception, at least in the past, is 

fertilization of forested areas to promote new tree growth. The application of fertilizers in the Forest, 

and especially Scenic Area, is now very uncommon. The effects of fertilizer application are 

relatively short-term since the fertilizer is quickly taken up by aquatic fauna and/or diluted. Past 

forest fertilization, therefore, would have resulted in a nutrient spike that could have stimulated plant 

growth for a short period, but not a sustained amount of time. Future fertilization projects are not 

scheduled in the Forest or Scenic Area, but the use of fertilizers on other federal ownerships, or state 

or private lands is possible. 

Common agriculture practices on both sides of the Cascades involve the application of fertilizers. In 

addition to lands designated for agriculture, many private homeowners apply fertilizers to lawns 

and/or gardens that could then be washed into surface waters. Although applying fertilizer on one 

lawn is negligible, application across an entire neighborhood could result in nutrient spikes or 

prolonged increases in nutrient levels. Agriculture fertilizer application could occur across large land 

areas and, at times, could result in large influxes of nutrients into surface water. In areas where shade 

also is limited, the combination of increased nutrients with increased sunlight could result in large 

amounts of plant and algal growth. 

Nutrient increases due to decaying plant matter in most areas would primarily be a small scale, 

natural process. Invasive plants treated on the Forest and Scenic Area would be left on the ground 

and not disposed of in or near creeks. Since invasive plant treatments currently authorized are very 

small in scale and located primarily away from surface water, there is little chance that large 

amounts of cut or killed vegetation would be deposited in streams. Consequently, an increase in 

nutrients even at the site scale would be small and the cumulative contribution to other nutrient 

sources downstream would be irrelevant. Similarly, decreases in DO levels, either from an increase 

in nutrients and subsequent biological oxygen demand and/or increased water temperatures, would 

be insignificant. 

3-141
Final Environmental Impact Statement 

Food Resources 

It is difficult to quantify the current state of food resources in streams within the Forest and Scenic 

Area as well as downstream. Given the generally good water quality seen in streams within the 

Forest and Scenic Area it is probable that aquatic communities also are in good health. Areas of 

degradation, both natural and human exacerbated, do exist: floral and faunal communities likely are 

somewhat impaired in these areas. Also, some water quality parameters in some watersheds worsen 

downstream, therefore it stands to reason that floral and faunal communities at least have been 

altered in terms of species diversity. 

Since the impacts to habitat from already approved invasive plant treatments would not contribute to 

cumulative habitat and water quality effects downstream, there also would not be cumulative effects 

to food resources. Treatments in the aquatic influence zone are small in scope, spread across many 

fifth-field watersheds, and would not result in measurable effects on habitat, and thus food resources. 

Fine Sediment and Turbidity 

Erosion and sedimentation are natural processes that occur in every landscape and stream system. 

Land management activities could exacerbate this process. Timber harvest activities both during and 

following implementation could disturb soil, reduce vegetative ground cover, and reduce or 

eliminate the duff layer, leading to increased erosion rates that may increase stream sedimentation. 

Past timber harvest across the Forest and on other federal, state, and private land was widespread, 

occurring in virtually every fifth-field watershed and in many areas resulted in large amounts of fine 

sediment entering streams. Little timber harvest has occurred in the Scenic Area in the last several 

decades. 

Roads could be a significant, chronic source of fine sediment to streams and other water bodies. 

Native surface and gravel roads, in particular, often contribute large amounts of fine sediment to 

streams. Road densities vary considerably across the landscape depending in large part on past 

timber sale activity and urban development (see Section 3.9 – Water Quality). The sediment 

contribution per unit area from roads could be much greater than all other land management 

activities combined, even compared to other logging activities that disturb soil such as log skidding 

and yarding (Gibbons and Salo, 1973). Roads in non-forested and urban areas also could contribute 

large amounts of sediment to streams, especially during storm events. 

Erosion from crop fields and pastures also could be significant depending on location and farming 

practices. In areas where vegetated buffer strips are incorporated much of the eroded soil could be 

trapped before entering streams, likewise no-till farming practices that leave stubble over the winter 

also reduce erosion rates. Even so, erosion from a farmed field would be greater than a fully 

vegetated piece of land. Livestock grazing also could accelerate soil erosion in and along streams 

because cattle reduce the amount of soil stabilizing riparian vegetation, and often trample and 

degrade stream banks, increasing erosion susceptibility. 

Urban areas also could be sources of fine sediment. Homes and other structures are sometimes built 

adjacent to streams with partial or complete riparian vegetation removal, or replacement with other 

species that may not provide the same degree of soil stability. Impervious surfaces, such as parking 

lots and roads, decrease infiltration and increase storm related runoff peaks, potentially exacerbating 

stream bank erosion. 

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Site-Specific Invasive Plant Treatments 

Although some soil erosion could occur resulting from invasive plant treatment under the No Action 

Alternative, the amount of fine sediment entering streams would be negligible. Most treatments 

involve some form of a buffer for mechanized treatment, and hand applied treatments such as hand 

pulling or spot herbicide spraying have a low risk of soil disturbance. Compared to past, present, and 

future land management activities else that either resulted in large-scale erosion, or have a relatively 

high potential to do so, invasive plant treatments currently authorized would contribute very little to 

the cumulative sediment load in area streams. 

3.10.2.2. Aquatic Organism Screening and Analysis Methodology – Action Alternatives 

Large Scale Analysis 

To focus the effects analysis on particular sites that could result in higher risk of effects from 

herbicide treatments to aquatic organisms, a screening process was used. The process incorporated a 

number of physical and chemical factors that, when looked at together, identified areas needing to be 

analyzed in greater detail because they could lead to a higher risk of detrimental effects to aquatic 

organisms. These factors included: whether any of the proposed treatment area was within a 

Riparian Reserve; proximity of treatment areas to streams, lakes, and pond;, and the potential of any 

herbicide to enter water at a high enough concentration to potentially result in a biologically relevant 

response from aquatic organisms, which is an action or result of an action that significantly impairs 

or disrupts essential behavioral patterns such as breeding, feeding or sheltering. “Biological 

relevance” is meant to convey the idea that there are a range of actions that may have some small 

effect on a listed species or the species’ habitat, but that effect would not significantly affect 

essential behavioral patterns such as breeding, feeding, or sheltering. This screening process resulted 

in a subset of proposed treatment sites that may have a higher risk of effects from herbicides to 

aquatic organisms. 

Site Specific Analysis 

A more detailed analysis was conducted on the higher risk sites identified by the process described 

above. This analysis included an examination of a variety of local site parameters and PDC that 

influence delivery of herbicides to provide a qualitative assessment of risk of detrimental herbicide 

effects to aquatic organisms. Local site-specific field conditions (other than soil type and 

precipitation) were compared with those assumed in the SERA risk assessments and worksheets to 

determine if the amount of herbicide entering water would have the potential to be higher or lower 

than the model output. The following parameters were examined: 

• Average site slope: If the actual slope was greater than 10 percent, modeled results may 

underestimate actual herbicide concentrations in water. If the actual slope was less than 10 

percent, modeled results may overestimate actual herbicide concentrations. (Source of data: 

GIS) 

• Stream flow (based on stream size): If the actual stream flow was greater than 1.8 cfs, 

modeled results may overestimate actual herbicide concentrations. If the actual streamflow is 

less than 1.8 cfs, modeled results may underestimate actual herbicide concentrations. It was 

assumed that streams greater than seven feet in width had flows greater than 1.8 cfs, and 

streams narrower than seven feet had lower flows. (Source of data: Forest and Scenic Area 

stream surveys) 

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Final Environmental Impact Statement 

• Riparian vegetation type: If the actual vegetation type is non-vegetated, modeled results may 

underestimate actual herbicide concentrations. If the actual vegetation type is shrub or tree 

dominated, modeled results may overestimate actual herbicide concentrations. (Source of 

data: GIS) 

• Acres proposed for treatment within 100 feet of the stream/pond: If the actual treatment site 

is located 100 feet or further from the closest water body, the modeled results may 

overestimate the actual herbicide concentration. Similarly, if less than 10 acres of the block is 

within 100 feet of the water body, the modeled results may overestimate the actual herbicide 

concentrations. On the other hand, if more than 10 acres of the treatment block is located 

within 100 of the closest water body then the modeled results may underestimate actual 

herbicide concentrations. Note that the modeled block width was 50 feet, but for our 

screening process and site specific analysis the 100 foot aquatic influence zone was used as 

this area had already been calculated for each site. (Source of data: GIS) 

The above parameters were examined to identify whether site conditions were similar to those 

modeled in the GLEAMS runs for the SERA Herbicide Risk Assessments (2001b, 2003a, 2003b, 

2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) or not. Other model assumptions were also taken 

into consideration and evaluated when comparing worksheet outputs with actual sites. For example, 

the model assumes all herbicide would be broadcast sprayed up to the water’s edge, which would not 

occur under either of the action alternatives. Another assumption is that the treatment block, or site, 

acts as a small drainage with all the applied herbicide emptying into the adjacent water body at a 

single point. This is not the case in a real life herbicide application situation. Finally, the model 

assumes that herbicide entering water bodies would be diluted instantly. The amount and rate of 

dilution would vary depending on the mixing zone characteristics (see Section 3.9 – Water Quality). 

Application and Expected Benefits of Aquatic Project Design Criteria 

The PDC related specifically to water quality and aquatic ecosystems, including standards adopted 

as part of the Invasive Plant ROD (2005b), were intended to greatly reduce the undesired effects of 

invasive plant treatments. The application of the PDC at each site would further minimize, and in 

some cases eliminate, effects to aquatic flora, fauna, and habitat regardless of the treatment method. 

The following discussion outlines how the consequences of the various proposed treatments would 

be minimized by implementation of the PDC. 

One important PDC (B.1) was intended to inform applicators at the beginning of each season of the 

spray sites and associated sensitive areas. This briefing would ensure each applicator was aware of 

the presence and location of sensitive aquatic areas, as well as pertinent operational details, including 

acceptable treatment timing. The presence of ESA listed fish species and the preferred timing of 

treatments to avoid particularly important or sensitive life stage periods (such as spawning and egg 

incubation) would be addressed. This would result in increased effectiveness to properly implement 

all PDC. 

3-144
Site-Specific Invasive Plant Treatments 

Several PDC, including B.9 and G.5, would greatly reduce the chance that treatment activities would 

disturb aquatic fauna during implementation. These PDC limit human access to streams or other 

water bodies and ensure mechanized equipment (tractors, all-terrain vehicles) would not operate 

directly adjacent to water bodies. Since sensitive stream segments and/or time periods would be 

identified up front as outlined above (PDC B.1), along with the PDC stipulating Oregon Department 

of Fish and Wildlife Guidelines for Timing of In-Water Work Periods (Appendix M) would be 

followed, personnel conducting herbicide treatments would not enter any streams with listed fish 

species during sensitive spawning and rearing time periods. The need for workers to enter water is 

very low anyway because all invasive plants proposed for treatment, with the exception of knotweed 

species, are terrestrial species and PDC stipulating herbicide would not be applied in water. 

Numerous PDC (B.3, G.5, G.6, I.1) are intended to minimize the risk of soil erosion into adjacent 

water bodies by restricting areas where mechanized spraying equipment could operate, as well as the 

incorporation of erosion control measures at any site where vegetation removal could result in 

sediment delivery to water. The intent is to allow treatment to address site specific invasive plant 

objectives while ensuring that treatment does not result in excess erosion to water bodies. 

Herbicide Project Design Criteria 

Standards outlined in the Invasive Plant ROD (2005b), as well as the PDC in this EIS, are designed 

to avoid water contamination from herbicides. Many of the PDC regulate operational considerations 

of herbicide application, such as how much herbicide could be transported each day, the distance 

from open water that refueling or tank cleaning could occur, wind and other weather application 

guidelines, and stipulations regarding acceptable herbicides for certain situations. The intent of these 

PDC is to ensure environmentally safe application designed to reduce or eliminate detrimental 

effects to aquatic ecosystems. The following discussion focuses on those PDC that directly 

contribute to the protection of water bodies on the Forest and Scenic Area. 

Herbicides used to control invasive terrestrial plants have the potential to enter water through a 

variety of pathways including spray drift, surface water runoff or percolation. Various PDC have 

been designed to greatly reduce or eliminate the chance that herbicides could enter water through 

these pathways. These include utilizing spot spraying or other selective herbicide application 

techniques within certain distances of surface water (F.1), limiting the use of herbicides that are 

more toxic to the aquatic environment (F.1 and F.2) and specifying environmental conditions for 

application that reduce offsite herbicide movement (C.1, C.2, C.3). 

Water Contamination from Drift 

Drift is one mechanism for unintended offsite introduction of herbicide when it is applied as a spray. 

Drift occurs when fine droplets of liquid herbicide become windborne and are transported to 

adjacent areas. It is a physical process that depends on droplet size (which is dependent on opening 

size and application pressure), nozzle height and weather conditions (primarily wind), rather than 

specific properties of an herbicide (USDA Forest Service, 2005a). The herbicide droplets could be 

subsequently deposited on surface waters that either contain aquatic species or serve as runoff 

conduits to water containing aquatic species. 

3-145
Final Environmental Impact Statement 

In a ground, application broadcast spray drift study conducted by the Spray Drift Task Force (1997), 

the amount of drift varied depending on droplet size, wind, and nozzle height. When nozzle height 

was 20 inches, wind speed 10 mph (crosswind), and a spray droplet volume median diameter of 341 

microns (a common size in agricultural applications), the amount of drift outside the direct spray 

zone was only 0.5 percent of the total sprayed. If the application rate were one pound of active 

ingredient per acre then only 0.08 ounce (2.28 g) per acre would be deposited 25 feet outside the 

spray zone. At 100 feet, the deposition amount would be less than half that amount, about 0.03 

ounces (0.9 g) per acre. For the largest droplet size (762 microns) increasing the nozzle height to 50 

inches more than doubled the spray deposited at 25 feet compared to the control tests, but the 

amount deposited at 100 feet was about the same as the control (0.03 ounces per acre). This 

illustrates how increasing droplet size also decreases the opportunity for drift. 

Felsot (2001) used the EPA/USDAFS AGDRIFT model that utilizes a combination of physical 

equations that describe spray drift and field measurements. AGDRIFT simulations of herbicide 

sprays were made for several application scenarios, including a truck mounted spray boom set at two 

heights. Felsot found that in the ground spray scenario, 99.5 percent of the applied spray remained 

on the target area and 99.9 percent of the applied spray remained within 100 feet downwind of the 

last spray swath. 

The Empire State Electric Energy Research Corporation commissioned a 1989-1990 study aimed at: 

• Assessing the effect of buffer zone width and vegetation density on herbicide deposition 

outside treated powerline rights-of-way. 

• Field testing the effectiveness of specific buffer strategies in protecting water quality during 

operational herbicide treatment. 

• Determining water quality criteria for protecting aquatic organisms and human health 

(Environmental Consultants Inc., 1991). 

Spray of an herbicide containing 2,4-D ester (which is not proposed for use in this EIS) was 

measured on vertical arrays of string located 0, 10, 25, 50, 75 and 100’ from the edge of the sprayed 

area. A dye was added to the herbicide mixture to stain the string arrays. The stem foliage treatment 

was made from atop an all-terrain vehicle, with nozzles adjusted to produce a coarse spray under 50 

lb/sq inch pressure. The low-volume basal treatment, applied by backpack sprayer, was intended to 

coat evenly all exposed bark on the lower 18 inches of each stem. 

This study found that dye deposition occurred at all distances from zero to 100 feet into the buffer 

zones, although typically concentrations were an order of magnitude greater at zero feet than at 100 

feet, and concentrations generally (although not absolutely) decreased with increasing distance into 

the buffers. Among other items, the report concluded: 

3-146
Site-Specific Invasive Plant Treatments 

Trained field crews that are effectively supervised can achieve safe herbicide applications that do not 

result in biologically relevant direct application or drift of herbicide into vegetated areas more than 

25 feet from the edge of the treated area. Biological relevant is an action or result of an action that 

significantly impairs or disrupts essential behavioral patterns such as breeding, feeding or sheltering. 

This provides protection for humans using water from, and for aquatic organisms that are in, the 

areas designed to be protected by the use of buffers of the dimensions found effective in this test 

when using 2,4-D ester. If herbicides of lower toxicity than 2,4-D ester are used, narrower buffers 

could be used and still achieve protection. 

An additional study was conducted by this same group to determine: 

• Effects of buffer zone and application strategy on direct application and drift of herbicide to 

surface water. 

• Effects of buffer zones on herbicide movement to surface water during autumn, early winter 

and spring following treatment. 

Water bodies near eight powerline rights-of-way were monitored for picloram, triclopyr, imazapyr or 

2,4-D for parts of an 8-month post-treatment period. Sites were selected with sandy or loamy soils 

anticipated to be most likely to allow herbicide leaching to streams 

Most of the several hundred samples collected had non-detectable concentrations. Samples with 

detectable herbicide concentrations (triclopyr, imazapyr and picloram) were collected shortly after 

application or during the first significant rainfall after treatment. One detection occurred in the 

spring after autumn treatment. The highest single concentrations detected were 0.002 mg/l triclopyr, 

0.001 mg/l picloram and 0.006 mg/l imazapyr. Quantifiable detections were made at six of the eight 

sites. 

The report acknowledges that it is unlikely that maximum concentrations were captured because the 

samples were composited at daily intervals. Consequences of the 24-hour compositing are described 

as minimal with respect to risk analyses based on continuous exposure for times ranging from 48 to 

96 hours. 

The report concludes that: 

• “The 100 foot buffer was well tested and achieved the presumed goal of protecting aquatic 

organisms and human health”. 

• “The 30 foot buffer was well tested for basal applications and achieved the presumed goal of 

protecting aquatic organisms and human health”. 

• Based on indirect evidence, the 50 foot buffer for stem foliar application would achieve 

water quality goals. 

3-147
Final Environmental Impact Statement 

Several PDC would greatly reduce the likelihood of introduction of biologically relevant amounts of 

herbicides into the aquatic environment from broadcast spray drift. These include limiting broadcast 

spraying to distances greater than 100 feet from surface water, utilization of low pressure nozzles 

that apply larger droplets, application of triclopyr by spot application methods only and spraying 

when wind velocities are between two and 10 mph. As illustrated in the studies summarized above, 

this would result in a low risk of introduction of toxic levels of herbicides for aquatic species. 

Drift associated with spot spraying (direct foliar applications) would be very low although studies 

quantitatively assessing drift from spot spray applications have not been encountered. The following 

summary was taken from recent fish biological assessments prepared by the Bureau of Land 

Management (Ruediger and Roberts, 2005) and the Willamette National Forest (Sheehan, 2005). 

Hatterman-Valenti (1995) estimated drift for hydraulic sprayers with hand-held wands in field 

studies. These drift values were used as an upper bound estimate for drift from a backpack sprayer 

(Labatt-Anderson, 2002). For the backpack sprayer the amount of drift was extremely low: the mean 

percentage of total spray that drifted was 0.08 percent at a distance of three feet and 0.03 percent at 

seven feet. Labatt-Anderson (2002) estimated drift at 25 feet as 0.001 percent for the backpack 

sprayer. 

Based on the various studies cited above, the amount of herbicide that could directly enter surface 

water via drift from spot application is extremely low. For example, using the study in the preceding 

paragraph, one pound of herbicide applied via spot application at 25 feet could result in only 0.00001 

lb or 0.005 grams reaching water from drift. This small amount would be diluted rapidly in even the 

smallest streams. Herbicides more toxic to aquatic life, such as glyphosate and picloram, cannot be 

sprayed within 50 feet of surface water. Other, less toxic herbicides could be spot sprayed up to edge 

of the bankfull channel if permissible given label instructions. Triclopyr BEE, which is very toxic to 

aquatic organisms, is not allowed for use within 150 feet of any water body or intermittent stream, 

regardless of the application method (see PDC F.1). 

Water Contamination from Runoff, Leaching, and Percolation 

Herbicides could potentially enter streams and other water bodies in water transported by runoff, 

leaching, or percolation. Section 3.9 – Water Quality, contains a discussion of the fate of various 

herbicides once they are deposited on bare soil. Highlighted are picloram and triclopyr, which are 

potentially more toxic to aquatic fauna than some other proposed herbicides and, in the case of 

picloram, highly soluble and mobile in sandy soil. However, cited studies indicate little evidence of 

picloram in groundwater, even though application rates far exceeded those proposed in this EIS. 

Nonetheless, the potential movement capability of picloram is addressed by incorporating a design 

feature that prevents use of picloram (as well as sethoxydim and non-aquatic glyphosate) within 50 

feet of standing water and high water table areas. 

All of the herbicides proposed for use under all of the alternatives could be transported in surface 

runoff; however, there is a low risk of this occurring given herbicide label instructions and PDC that 

restrict use during periods of precipitation or if precipitation is forecast within 24-hours of 

application. As explained in Section 3.9, those herbicides that rate moderate to high in both 

persistence and mobility categories (such as picloram) could also enter water bodies during a “first 

flush” scenario in the fall. However, PDC have been designed to limit application of these herbicides 

to once per year, as well as application only in soil types where persistence and mobility are reduced. 

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Site-Specific Invasive Plant Treatments 

Relatively little herbicide would actually come into contact with bare soil within 100 feet of water 

bodies. Spot application targets individual plants or groups of plants and the applicator has a high 

level of control over the amount sprayed and thus can ensure most herbicide is deposited on the 

plant(s). This in turn results in less herbicide moving offsite from over spray areas (u.e., soil) into 

adjacent water bodies when compared to broadcast spraying. Furthermore, the overall total amount 

of herbicide applied by spot spraying would be less than broadcast spraying since spot application is 

more discriminatory. Broadcast spray would result in much more herbicide reaching bare soil 

because herbicide is normally applied in a continuous swath over a much larger area than spot 

spraying. 

PDC Application Summary 

As a result of all PDC are designed to protect aquatic resources the risk of a biologically relevant 

amount of herbicide reaching any water body is negligible. Broadcast spray limitations, focused 

application of spot spraying, limited drift, and other restrictions on certain herbicides depending on 

site conditions would result in very little herbicide reaching water via drift or other pathways. 

Although the actual amount of herbicide reaching water cannot be fully quantified, based on the 

professional judgment of the EIS interdisciplinary team hydrologist, fish biologist, and soil scientist 

and available research and monitoring, herbicide amounts reaching any surface water would be 

much lower than predicted (modeled). 

3.10.2.3. Alternative 2 – Proposed Action 

Invasive plant treatments considered in this EIS include manual, mechanical, cultural (e.g. goat 

grazing), and herbicide application methods, as well as site restoration (revegetation and erosion 

control) following treatment. All of the treatment methods have the potential to affect aquatic flora 

and fauna and their habitat through several pathways, primarily through effects to riparian and/or 

aquatic vegetation, sedimentation, water quality, and food sources. The majority of potential effects 

would be indirect (i.e., effects occurring after treatment implementation, but resulting from that 

treatment). The intensity and extent of treatment effects to aquatic plants, algae, fish, aquatic 

invertebrates, and their habitat would vary depending on a variety of factors, such as area treated, 

soil type, proximity of the treatment to water, and weather conditions during and after treatment. 

Invasive plant treatment proposed in this alternative is the most aggressive of the three alternatives 

outlined in this EIS. A detailed description of treatment objectives, methods, locations, and expected 

duration was presented in Chapter 2. Other interdisciplinary team specialists, notably the soil 

scientist and hydrologist, further describe treatments and their potential effects on soil, riparian, and 

aquatic resources. Note that the following discussion focuses on existing, known sites only. The 

EDRR will be discussed in its own section. About 5,065 acres in riparian reserves are available for 

treatment in any given year, although it is unlikely that all acres would be treated each year since 

that is a “worst case scenario” that includes a rate of spread factor that significantly increases the 

potential treatment area beyond actual infested area (see Chapter 2). 

Treatment methods in riparian reserves vary but are mostly a combination recognizing that one 

specific method would not be totally effective (Table 3-32). Treatment in the aquatic influence zone 

is significantly less than in riparian reserves. Most areas to be treated include herbicide application; 

very few acres would be treated solely with manual or mechanical methods. 

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Final Environmental Impact Statement 

Table 3-32: The area of proposed treatment methods in riparian reserves and the aquatic 

influence zone for the entire Forest and Scenic Area under the Proposed Action. 

Proposed Treatment Method 

Riparian Reserve 

Acres 

Aquatic Influence 

Zone Acres 

Manual, Mechanical 39.0 22.8 

Herbicide 21.8 10.0 

Herbicide with Manual 79.8 48.8 

Herbicide with Mechanical 62.9 24.7 

Herbicide with Mechanical and Cultural 1,402.4 425.7 

Herbicide with Manual and Mechanical 3,438.2 1,584.0 

Herbicide with Manual, Mechanical and Cultural 21.2 21.2 

TOTAL 5,065.3 2,137.2 

The following discussion of direct and indirect effects is grouped by non-herbicide and herbicide 

treatments.

Non-Herbicide Treatments: Direct Effects 

Direct effects from non-herbicide treatments to aquatic fauna and flora would only occur if treatment 

methods were implemented directly adjacent to, or within, water bodies where aquatic plants, algae, 

macroinvertebrates, or fish are present. To be a direct effect there would have to be an immediate 

impact that would harm aquatic species, or immediately alter a habitat element, such as water 

temperature or overhanging vegetation that could provide fish cover. As such, any activity outside 

the aquatic influence zone, and most activities inside this zone, has no potential to directly affect 

aquatic resources. 

Disturbance of aquatic organisms from personnel working in water would be minimal and would 

only occur during the Oregon Department of Fish and Wildlife in-water work period to avoid 

spawning and egg incubation. Equipment operation would not disturb aquatic organisms because of 

the 25 foot no operation buffer. Goats would not enter water to graze at the two sites in the Scenic 

Area where proposed. To concentrate the grazing in areas infested with invasive plants the goats are 

confined within temporary fence enclosures. The enclosures may be set up adjacent to surface water 

but would not cross creeks or other water bodies. The goats, therefore, may graze adjacent to, but not 

in, surface water. 

Immediate alterations to overhanging vegetation, or other aquatic habitat elements, would not occur 

as a result of manual, mechanical, or cultural treatments. Mowing, the method that would remove the 

most vegetation in a short time is not allowed within 25 feet of surface water. Manual treatments 

could remove invasive plants that are growing adjacent to water but not the two species that are large 

and could overhang water – knotweed species and blackberry. Goat grazing could remove patches of 

blackberry, but at site 22-07 (Wells Island) it would not impact shade as larger trees are the shade 

producing vegetation there. At the Sandy River Delta (22-01) the grazing would occur along sloughs 

or wetlands that are potentially accessible to fish only during winter and spring, whereas the grazing 

would occur in summer and fall. 

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Site-Specific Invasive Plant Treatments 

Non-Herbicide Treatments: Indirect Effects 

Indirect effects associated with non-herbicide treatments have the potential to affect the following: 

water temperature, dissolved oxygen and/or nutrient levels, and fine sediment/turbidity. However, 

the effect on these habitat and water quality elements is expected to be negligible (see Section 3.8 – 

Soil Productivity and Section 3.9 – Water Quality). 

The combination of site specific conditions (such as naturally high organic matter sources, other 

shade producing vegetation, limited soil exposure following treatment) and PDC would greatly limit 

the chance for impacts large enough to detect. The intensity and duration of any water temperature 

increases, turbidity, or nutrient levels, or decreases in DO would not be enough to rise to the level 

where biologically relevant effects to any aquatic fauna or flora would occur. Likewise, any fine 

sediment deposited on the streambed as result of non-herbicide invasive plant treatments would not 

be enough to affect aquatic macroinvertebrate survival, fish spawning success, fish feeding, or the 

amount of fish rearing habitat. 

Herbicide Treatment: Riparian Reserve Site Summary 

It is highly unlikely that herbicides would enter water via drift or from other transport mechanisms 

when applied outside riparian reserves due to the distance from surface water, adsorption, 

degradation, and accumulation in plants. As such the application of herbicides at sites located 

outside riparian reserves would not result in a biologically relevant herbicide amount entering area 

water bodies. Fifty two of the 208 known sites are located wholly outside riparian reserves (Table 

W-3, Appendix W). These sites, encompassing 592 acres, will not be discussed further in the aquatic 

related analysis. 

Sixty nine of the remaining 156 sites are located partially or wholly within riparian reserves but not 

near fish-bearing streams (Table W-4, Appendix W). These sites encompass about 1975 acres, or 

about 15 percent, of the total known acres proposed for treatment with herbicides. Of those 1,975 

acres, 267 acres (13.5 percent) lie within riparian reserves, but only 148 acres (7.5 percent) are 

within the aquatic influence zone. Thirteen of these sites lie completely outside the aquatic influence 

zone. Herbicide treatments proposed at these 69 sites would have no effects on any fish species due 

to their distance from fish-bearing waters, coupled with Invasive Plant ROD standards (2005b) and 

PDC designed to minimize water contamination from herbicides. 

The remaining 87 sites (Table W-5, Appendix W) are located adjacent to fish-bearing streams and 

they make up the majority of the proposed treatment area –10,514 acres or 80 percent. Less than half 

of this area (4,803 acres), however, lies within riparian reserves. More importantly, less than 20 

percent (1,988 acres) lie within the aquatic influence zone. Almost 80 percent (1,575 acres) of the 

aquatic influence zone acres lie adjacent to streams that contain federally listed fish species. Most of 

the 87 sites have invasive plant treatments proposed within the aquatic influence zone, but many 

sites have a very small amount. 

3-151
Final Environmental Impact Statement 

General Herbicide Treatment Consequences 

Based solely on the SERA herbicide risk assessments and associated worksheets, very few proposed 

herbicides would result in concentrations greater than the acute No Observable Effect Concentration 

(NOEC) for aquatic organisms5

. In no case would the proposed application of any herbicide result 

in direct mortality of any aquatic organism. At 11 sites, glyphosate, AQ glyphosate, picloram, and 

AQ triclopyr resulted in predicted concentrations greater than the NOEC for fish; and at three sites, 

imazapic and chlorsulfuron exceeded the NOEC for aquatic plants. The modeled concentrations do 

not take into account PDC and site specific parameters as compared to model assumptions. This is 

an extremely important fact to remember during the following discussion because the actual 

concentrations of herbicide reaching any water body would be far less than model predictions 

because of the PDC. Furthermore, it is important to remember that not all herbicides are proposed 

for use at all sites and predicted concentrations only exceed the NOEC at few sites. For example, AQ 

glyphosate, proposed for use at 81 sites near fish-bearing streams, only exceeded the NOEC for fish 

at eight of those sites. More detailed analysis results are discussed below and also can be found in 

Appendix W for the four aquatic organism groups. 

Herbicide risk assessment modeling conducted as part of the Invasive Plant FEIS (2005a) analysis 

indicated that chronic toxicity index concentrations for all aquatic organisms was not possible under 

a worst case delivery scenario (USDA Forest Service, 2005a). In other words, for a chronic effect to 

occur large amounts of herbicide would have to be applied continuously, or at regular intervals, to 

result in a constant supply of herbicide to water. This scenario would not occur as proposed in this 

EIS, even for those sites that could be treated up to three times each year. As such, only acute effects 

are possible and chronic effects will not be discussed further in this analysis. 

If individual fish were impacted as a result of proposed herbicide treatment, the effects would be 

sub-lethal. This is due to the very small amounts of herbicide and adjuvants, far below lethal levels, 

that might reach water where fish reside. The ecological significance of sub-lethal effects depends 

on the degree to which they influence behavior essential to the survival and reproductive potential of 

individual aquatic species. Sub-lethal effects are not readily apparent in fish (USDA Forest Service, 

2005a). When small changes in the health of individual fish are observed in a laboratory setting (e.g., 

a small percent change in behavior, the activity of a certain enzyme, or an increase in oxygen 

consumption), it may not be possible to infer a significant loss of essential behavior patterns of that 

fish species in the wild (USDA Forest Service, 2005a). The question becomes one of biological 

relevance – Is the effect large enough to reduce fitness, survival, or some other aspect of behavior? 

Much of the available toxicological research regarding the effects of herbicides and adjuvants on fish 

and other aquatic organisms has focused on the lethal dose. Although more limited, some research 

has investigated at least some of the sub-lethal toxicological endpoints generally considered 

important to the overall health and fitness of aquatic species. These sub-lethal toxicological 

endpoints are defined as: 

 

5

 The NOEC is the concentration of herbicide at which there are no statistically or biologically significant differences in 

the frequency or severity of any effect in the exposed or control population. In many cases, at least for fish, the NOEC is 

estimated as 1/20th of the LC50 for a particular herbicide (see Tables W-1 and W-2 in Appendix W). 

3-152
Site-Specific Invasive Plant Treatments 

• Increase or decrease in growth; 

• Changes in reproductive behavior; 

• Reduction in number of eggs produced, eggs fertilized, or eggs hatched; 

• Developmental abnormalities, including behavioral deficits or physical deformities; 

• Reduced ability to osmoregulate or adapt to salinity gradients; 

• Reduced ability to tolerate shift in other environmental variables; 

• Increased susceptibility to disease and/or predation; and, 

• Changes in migratory behavior. 

NMFS Northwest Fisheries Science Center has conducted research on the sub-lethal effects to fish 

from technical grade herbicides and some formulations for picloram (Tordon K), clopyralid 

(Transline), imazapyr (Habitat), imazapic (Plateau), triclopyr (Garlon 3A and Renovate), and 

glyphosate (no specific formulation tested for glyphosate) using zebra fish (Danio rerio). The results 

have not yet been published. Preliminary results suggest that the sub-lethal effects investigated do 

not occur in zebra fish for the herbicides and formulations tested. 

Other studies have attempted, directly or indirectly, to correlate the effects of herbicides or other 

contaminants to sub-lethal effects in a variety of fish species. Various behavior mechanisms, growth 

rates, and predator/prey interactions have all been studied. The risk assessments completed by SERA 

(2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, and 2004f) contain 

comprehensive reviews of many of these studies and, therefore, a detailed synopsis will not be 

presented here. A few examples, however, illustrate that observed behavioral and/or growth 

differences have been observed, but at much higher herbicide concentrations than would result from 

proposed herbicide treatments. For example, in one study conducted by Cohle and McAllister (1984, 

as cited in SERA 2004d) both bluegill and rainbow trout exhibited abnormal behavior during 96–

hour bioassays with the herbicide Arsenal (imazapyr) at concentrations at or exceeding 32 mg/L. 

The highest concentration in water predicted in our analysis was 0.000002 mg/L before PDC. In 

addition, Morgan et al. (1991, as cited in SERA 2003c) conducted studies with a flow through Ymaze to test avoidance of Garlon 3A (triclopyr TEA) by rainbow trout. They found a threshold for 

avoidance response to be 800 mg/L. Static tests to determine lethality resulted in a 200 mg/L 

threshold for behavioral changes. The highest concentration in water predicted in the analysis 

conducted for this EIS is 0.30 mg/L. 

Woodward (1979) found that picloram did affect cutthroat trout fry growth, but not at concentrations 

below 0.29 mg/L. The highest concentration in water anticipated in our analysis was 0.065 mg/L 

before PDC. In tests comparing juvenile bull trout and swim-up juvenile rainbow trout sensitivity to 

picloram, bull trout were more sensitive than rainbow trout in terms of growth rates (weight) 

compared to control fish (Fairchild et al., 2005). In the 28-day flow through tests, the NOEC for bull 

trout was 0.3 mg/L, compared to 1.2 mg/L for rainbow trout, both well above anticipated 

concentrations from the analysis conducted for this EIS. 

3-153
Final Environmental Impact Statement 

Weis et al. (2001) have extensively studied populations of mummichog (Fundulus heteroclitus), an 

abundant intertidal fish species found on the east coast of the continental United States. They 

compared populations residing in healthy streams with one population in a very polluted stream and 

demonstrated biochemical alterations leading to behavioral changes that lead to reduced growth, 

condition, and life span. Based on the results of their work, it seems clear that sub-lethal effects, as a 

result of high contaminant levels, can result in negative individual and population impacts in the 

polluted watershed. Herbicides, however, were not the focus of this study; the culprit appears to be 

“many organic contaminants and metals.” The polluted stream is surrounded by industrial sites, a 

sewage treatment plant, a power plant, and a major highway – anthropogenic conditions far different 

than the conditions within the Forest and Scenic Area. Although the study does demonstrate sublethal effects, it does not pinpoint the source (or sources) and the authors point out that impaired prey 

capture is likely a result of overall contaminant loading, which appears quite high, rather than any 

single chemical. Based on the description of their study site, it is safe to assume the Forest and 

Scenic Area streams are far less polluted. It is the professional opinion of the Fisheries Biologist on 

this EIS team that the small amount of herbicide proposed for use would not lead to individual or 

population effects as described by Weis et al. (2001). 

The reaction or susceptibility of fish to herbicides may vary depending on the life stage. For 

example, a multitude of studies have been conducted on the effects of various glyphosate-based 

herbicides on a number of fish species and life stages. In one study conducted by Folmar et al. 

(1979), the 96-hour LC50 ranged from 1.3 mg/L to 16 mg/L for various life stages of rainbow trout. 

In general, the LC50 was higher for older and larger life stages (at or above the fingerling stage). A 

notable difference was that the LC50 for eyed eggs was 16 mg/L, compared to 8.3 mg/L for a 2.0 g 

fingerling and adult (weight not specified). Folmer et al. (1979) also noted differences in effects 

among four different fish species (presumably all adults): fathead minnow appeared most sensitive 

(LC50 = 2.3 mg/L), whereas channel catfish were least sensitive (LC50 = 13 mg/L). 

Triclopyr also varies in its effects to different fish species, regardless of the type or formulation. As 

summarized in the risk assessment (SERA, 2003c), LC50 concentrations of triclopyr TEA ranged 

from 240 mg/L for rainbow trout (life stage not specified) to 947 mg/L for fathead minnow (life 

stage not specified). Although, the study showed that there was significant variation in effects on the 

same species in different studies. Triclopyr TEA and BEE both break down to triclopyr acid rapidly 

in water and soil (Ganapathy, 1997), and thus, the acid form may be the most prevalent and of the 

most concern in both water and soil until further breakdown occurs. Triclopyr acid is more toxic 

than Triclopyr TEA with LC50 concentrations of 117 mg/L for rainbow trout and 148 mg/L for 

bluegill (SERA, 2003c). TCP, a primary breakdown product of both triclopyr TEA and BEE in soil 

(Ganapathy, 1997), is more toxic than the TEA formulation with LC50 concentrations ranging from 

1.5 mg/L for rainbow trout to 2.1 mg/L for Chinook salmon to 12.5 mg/L for bluegill. 

3-154
Site-Specific Invasive Plant Treatments 

Product formulations often include adjuvants (additives mixed with the herbicide solution to 

improve performance of the spray mixture), or recommend the addition of adjuvants that could have 

toxic effects themselves. Effects of surfactants (a common group of adjuvants) to aquatic species 

have received some study (USDA Forest Service, 2005a). In general, aquatic species are more 

susceptible to adverse effects from surfactants than terrestrial species. At least some of the aquatic 

sensitivity to surfactants is due to irritation of gill membranes, and alteration of their permeability 

and molecular exchange properties. Due to the small amounts used resulting in very low 

concentrations reaching water (much lower than protective concentrations), the effects to aquatic 

organisms would be negligible from NPE-based surfactants (Bakke, 2003b). Concern has been 

expressed about the potential for surfactants increasing the movement of other harmful materials, 

such as pesticides, into soils. Herbicide mobility could be increased by the use of surfactants, but 

effects to mobility are unlikely given the low concentration of surfactants in the soil/water matrix at 

USDA Forest Service application rates (Bakke, 2003a). 

The combination of POEA (polyethoxylated tallow amine) surfactant and glyphosate may be 

harmful to fish and invertebrates since they breathe by movement of water. The combination of 

POEA surfactant and glyphosate has been shown to cause inflammation of gill tissue in fish, and to 

reduce survival rates especially for young fish (Folmar et al., 1979). Folmar (1979) demonstrated 

that the surfactant POEA is actually more toxic to fish than the herbicide it is mixed with (Folmar et 

al., 1979). This agrees with the conclusion in the SERA Risk Assessment for glyphosate (SERA, 

2003a). Formulations of glyphosate that do not contain surfactants are available and labeled for 

aquatic use, and would be used near water as needed under all alternatives. 

The above discussion highlights several important factors that are important to our analysis and the 

interpretation of the results. These factors are summarized below. 

Herbicides may have different levels of effects on fish depending on the life stage and/or species. 

For all herbicide HQ calculations, however, the lowest cited dose (or 1/20th of the LC50) that 

correlated to the NOEC regardless of the fish species and/or life stage was used. This is an additional 

safety factor in the analysis and ensures our results apply to all aquatic species and life stages. 

Though the discussion above centers on fish, the potential impacts and effects also apply to 

invertebrates and plants/algae. 

Sub-lethal effects to fish resulting from herbicides have been documented in several studies although 

the research is not as extensive as that for lethality. Based on the available information, the 

concentrations of herbicide that are expected in the Forest and Scenic Area water bodies are 

less (in most cases far less) than concentrations that resulted in observed sub-lethal effects. 

Note that these predicted concentrations are based solely on the modeled GLEAMS runs before site 

specific conditions and PDC are taken into consideration. PDC are expected to further reduce the 

amount of herbicide/adjuvant reaching water. 

3-155
Final Environmental Impact Statement 

Herbicide Treatments: Direct Effects 

Herbicide application, as proposed under the Proposed Action, would not result in direct mortality to 

aquatic organism. The estimated concentrations are all far below lethal levels for every aquatic 

organisms studied. While the amount of herbicides and adjuvants expected to reach water are 

estimated to be extremely low under the Proposed Action, the USDA Forest Service cannot conclude 

with certainty that the levels of chemicals potentially reaching streams harboring aquatic organisms 

would be zero. However, the amount is expected to be biologically irrelevant as explained below. 

Aquatic Plants and Algae 

Aquatic plants are a natural, and important, component of aquatic communities. Aquatic plants, 

especially phytoplankton, are consumed by small invertebrate animals, which in turn are consumed 

by larger animals such as birds or fish. Phytoplankton also could be consumed directly by certain 

fish. Small fish could be consumed by larger fish and by birds. Any impact to a component of the 

aquatic community may have a ripple effect on the food web. 

Based on the risk assessments used for this analysis, typical application rates of two herbicides, 

imazapic, and chlorsulfuron, could result in exposure concentrations that exceed the acute NOEC for 

aquatic plants, but only at three sites (Table 3-33)6

. No mortality of aquatic plants would occur at 

any site. Other herbicides proposed for use did not exceed the acute NOEC at any site. At each of the 

three sites there are other herbicides that are not predicted to exceed the aquatic plant NOEC that 

could be used, if effective and practical, to further reduce effects to aquatic plants. Predicted 

herbicide exposures did not exceed the acute NOEC for algae at any site. 

Conditions at the three sites, when compared to the SERA herbicide risk assessments and associated 

worksheets assumptions, indicate far less herbicide would actually enter water than predicted. Of the 

three sites, the one with the highest risk of larger amounts of herbicide entering water would be 66-

084 because it borders a small stream and has steeper slopes than assumed in the model (but with a 

vegetation buffer strip that would result in less herbicide routed to the stream). In site 22-01 the 

slope is less than assumed and the presence of riparian vegetation buffers would reduce the amount 

of herbicide entry. Although the amount of aquatic influence zone area is relatively large this is 

spread over a wide area (the site is about 1,573 acres in total size) and streams are much larger than 

modeled so dilution would be greater. 

A comparison of some of the major model assumptions with on the ground conditions and PDC is 

warranted and would apply to all application sites, regardless of risk. There are three major 

assumptions in the model that would rarely, if ever, be met in the field at Forest or Scenic Area sites 

and as a result far less herbicide would ever reach surface water as a result of proposed treatment. 

The first is that the model assumes herbicide is broadcast sprayed up to the water’s edge 

continuously across the entire treatment block. In no case would this ever happen in the field due to 

the 100 foot no broadcast spray buffer. There are no sites where invasive plants blanket the entire 

aquatic influence zone across the entire site; instead, the invasive plants grow in discreet patches. 

 

6

 See Tables W-6 and W-7 in Appendix W for predicted algae and aquatic macrophyte hazard quotient values for all 

sites within riparian reserves. 

3-156
Site-Specific Invasive Plant Treatments 

This means the actual amount of herbicide applied within the 100 foot swath closest to a water body 

would be less than modeled because spot spraying and hand application target individual plants or 

groups of plants. Due to the differing site conditions, it is not possible to estimate the actual amount 

of herbicide that would be applied, but it would be less than the modeled one lb/acre because there 

are no sites where invasive plants cover an entire treatment area to the exclusion of other plant 

species. 

The second relates to modeled block size. The 10 acre block is assumed to be 50 feet wide and 8,672 

feet long directly adjacent to the water body. In actuality, this scenario would likely never be 

realized in the field. Most aquatic influence zone treatment acres, by site, are smaller than 10 acres in 

size. For those sites where the aquatic influence zone size exceeds 10 acres (22-01, 66-008, 69-008, 

a few others) the aquatic influence zone “block” that would be treated is not a continuous area along 

a water body. By definition, the aquatic influence zone is 100 foot wide, not 50 feet as modeled, so 

at many sites even though aquatic influence zone acres are being treated that does not mean the 

treatment site is directly adjacent to a water body. 

Finally, this is a point source model that assumes all herbicide drains from the block at a single 

point; in effect, the block as described above acts as a small watershed. “The point source 

assumption is a simplification and is reasonably conservative – i.e., it [would] lead to somewhat 

higher concentration estimates than alternate assumptions” (SERA, 2004g). If runoff were to come 

uniformly off the treatment block, instead of at a single point, the average concentration in water 

would be about 72 percent of the point source assumption (SERA, 2004g). Point source runoff 

would not occur at any known site on the Forest or Scenic Area. In actuality, the herbicide that does 

runoff would approximate the uniform runoff assumption; although, herbicide would not drain or 

leach at uniform rates. Instead, herbicide would runoff or leach from numerous areas at different 

rates resulting in smaller amounts reaching the water body at different times in different places. This 

is a major difference that would result in less herbicide reaching water at any point in time or space, 

thus concentrations in water would be less at any given time. 

In summary, although the actual amount of herbicide reaching water cannot be quantifiably 

predicted based on differences in site conditions and PDC, it is clear that the amount reaching water 

would be far less than predicted. In all of these sites, application of PDC as described above would 

result in far less herbicide routed to water regardless of site conditions. As such, the effects to 

aquatic plants at these sites would be biologically irrelevant. 

Invertebrates and Fish 

Direct effects to aquatic invertebrates or fish from herbicide application would only occur if there 

were enough herbicide entering water at a given site to immediately cause an acute, sub-lethal effect 

that significantly impairs some biological function. This would not occur because of PDC designed 

to greatly minimizing drift, especially buffers, that would result in insignificant amounts (if any) 

entering water bodies. Concentrations would be far below lethal and NOEC concentrations. Direct 

application to water would not occur. 

3-157
Final Environmental Impact Statement 

3-158

Table 3-33. Proposed sites within riparian reserves where the NOEC was exceeded for at least one herbicand/or fish. Site specific conditions (average slope, vegetation buffer difference, stream width, sites acres within zone, and the amount of stream bank treated) are displayed for comparison with assumed values in the SERA heassessments and associated worksheets (listed below the table).

NOEC Exceeded? 

Treatment 

Site ID 

Within 

AIZ? 

Aquatic 

Plants Fish

T&E Fish 

Present? 

Pacific Northwest 

Region Sensitive 

Fish Present? 

Ave. 

Slope 

(%) 

Vegetation 

Difference 

Stream 

(ft

22-01 Y Y Y Y N 2 Less Delivered 1022-07 Y Y Y N 4 Less Delivered 50

65-012 Y Y N N 33 Less Delivered 5 65-019 Y Y Y N 16 More Delivered 1165-028 N Y Y N 23 Less Delivered 465-029 Y Y Y N 17 Less Delivered 465-031 Y Y N N 7 Less Delivered 165-036 Y Y N N 29 Less Delivered 165-041 Y Y Y N 31 Less Delivered 466-008 Y Y Y Y 18 No Change 8 66-052 Y Y Y 21 More Delivered 12 66-053 Y Y Y N 62 No Change 166-071 Y Y N N 24 Less Delivered 166-084 Y Y Y N 16 Less Delivered 7 66-091 Y Y N Y 28 Less Delivered 169-008 Y Y Y N 25 Less Delivered 269-012 Y Y Y N 0 Less Delivered 5 69-028 Y Y N N 13 Less Delivered 169-029 Y Y Y N 1 More Delivered 8 

SERA herbicide risk assessments and associated worksheet assumptions: 

• Herbicide applied via broadcast spray up to waters edge across the entire treatment block. • Site slope is 10 percent. • Vegetation along the stream at the treatment site is sparse grass. • Stream size is approximately 7 feet wide by 1 foot deep (corresponds to 1.8 cfs). • The application block is a rectangle 10 acres in size that is 50 feet wide and 8672 long adjacent to the stream. (AIZ acres are a c

this block size. Since the AIZ is 100 feet wide by definition not all treatment within this zone would occur within 50 feet of the 

• The model assumes the 10 acre block is essentially a small watershed with all herbicide emptying into the adjacent water body a
Site-Specific Invasive Plant Treatments 

3-159

Herbicide Treatments: Indirect Effects 

Algae and Aquatic Plants 

There would be no indirect effects to aquatic plants or algae resulting from the implementation 

of this alternative. There would be no mortality of any aquatic flora and the amount of herbicide 

that could leach into water bodies over time would be so small due to PDC, adsorption, 

degradation, and dilution it would be biologically irrelevant. 

Invertebrates 

Predicted herbicide concentrations did not exceed the NOEC for aquatic invertebrates at any site. 

There would be no mortality of aquatic invertebrates at any location as a result of herbicide 

application. Potential reductions in DO that could locally affect aquatic invertebrates due to large 

die-offs of aquatic plants or algae (USDA Forest Service, 2005a) would not occur because 

aquatic vegetation itself would not be treated with herbicides and not enough treated plants 

would fall in water at any site to decrease DO concentrations. 

Fish 

Since this EIS analyzes the effects of invasive plant treatment at sites across the Forest and 

Scenic Area, the number of fish species (and life stages) potentially affected is diverse. The 

following discussion and summary focuses on salmonids because most is known about their 

distribution, life history, and habitat needs. Likewise, much of the toxicity information available 

was also related to salmonids, specifically rainbow trout. Other fish species, such as lamprey and 

sculpin, are also important members of the aquatic community however there was no known 

herbicide toxicity information available for these species. Since definitive toxicological 

information regarding the herbicides and adjuvants proposed for use in this EIS were best 

summarized by the SERA risk assessments (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 

2004d, 2004e, and 2004f) and Bakke (2003a and 2003b) these were used as the basis for 

herbicide effects on fish. Given that the lowest cited dose concentration, regardless of fish 

species or life stage, was used to calculate HQ values, it is assumed that potential effects to fish 

other than those specifically studied would be similar. 

Biologically relevant effects to fish from herbicide application are not expected as a result of 

herbicide treatments. No fish mortality would occur at any site as the potential herbicide 

concentrations are all much lower than lethal concentrations.The risk of adverse effects to listed 

aquatic species is expected to be discountable if the concentration of herbicide or adjuvant is less 

than the NOEC (USDA Forest Service, 2005c). Likewise, adverse effects to other, non-listed fish 

species would also be discountable. At all sites except those profiled below the acute NOEC for 

fish was not exceeded by any herbicide. At the 70 sites with fish present not discussed below the 

low predicted herbicide concentrations coupled with PDC and site specific conditions as 

described above, would render effects to fish biologically irrelevant. 
Final Environmental Impact Statement 

Based on the risk assessments used for this EIS, four herbicides (glyphosate, AQ glyphosate, 

AQ triclopyr, and picloram) could result in exposures that exceed the acute NOEC for fish, but 

only at 17 sites (Table 3-33)7. Of those 17 sites, salmonids listed as threatened are present at 10 

sites, salmonids that are USDA Forest Service, Pacific Northwest Region 6 sensitive are found 

at three sites, and other salmonids, such as cutthroat trout, are the only salmonids present at five 

sites (but they also are found at most other sites). The herbicide glyphosate exceeded the NOEC 

at five sites (22-01, 22-07, 65-019, 69-012, and 69-029), picloram at four sites (65-028, 65-029, 

65-031, and 65-041), AQ triclopyr at one site (66-071), and AQ glyphosate the rest of the sites 

(as well as site 66-071 – the only site where two proposed herbicides exceeded the NOEC). At 

all site other herbicides are proposed that could be substituted for ones with a predicted NOEC 

exceedance. 

The 17 sites vary regarding conditions that would reduce the risk that herbicides could enter 

water (Table 3-33) but in all cases the expected amount of herbicide reaching streams would be 

less than modeled. For the most part, the sites have physical characteristics that would further 

minimize the risks posed by herbicides such as well vegetated buffer strips, larger streams (hence 

more stream flow) than modeled, and few acres treated in the aquatic influence zone. 

Application of PDC and site specific conditions that differ greatly from model assumptions 

would reduce the risk of potential herbicide effects at all of the above sites. Glyphosate and 

picloram cannot be applied within 50 of open water and, like all of the herbicides; they cannot be 

broadcast sprayed within 100 feet. These PDC alone would render their effects irrelevant at sites 

where proposed because the model assumes broadcast spray up to the water’s edge. Spot 

application of AQ glyphosate as opposed to the modeled broadcast application would alleviate 

the risk of biologically relevant effects at sites where proposed. 

As previously described, the exceedance of the NOEC for glyphosate likely has more to do with 

the added POEA surfactant in modeled formulations rather than glyphosate itself, which was 

classified as non-toxic or practically non-toxic to freshwater fish by the EPA (SERA, 2003a, 

page 4-12). PDC within the aquatic influence zone would reduce the potential effects of 

glyphosate as none would be applied within 50 feet of open water, regardless of the application 

method. Relatively high application rates compared to other proposed herbicides are likely the 

cause of AQ glyphosate (which does not include a surfactant) exceeding the NOEC. Glyphosate 

binds very tightly to soil particles, and thus, is not easily leached out. As such, it would not leach 

into nearby water bodies in great amounts, further reducing its potential effects on aquatic 

organisms. 

Picloram is one of the few herbicides proposed that persists in soil: most of the other proposed 

herbicides degrade or leach out relatively quickly. For this reason, picloram would not be applied 

within 50 feet of open water and it would only be applied once per year, even at sites where 

treatment is proposed up to three times in a given year. 

 

7

 See Table W-9 in Appendix W for a list of predicted fish hazard quotient values for all sites within riparian 

reserves. 

3-160
Site-Specific Invasive Plant Treatments 

Based on this analysis, the available site-specific evidence, and PDC, the amount of herbicide 

that could enter water at all sites, including the 17 described above, would be less than the 

NOEC and result in no relevant biological effects to fish or other organisms. 

Designated Critical Habitat and Essential Fish Habitat 

Bull Trout 

Most of the PCE for bull trout critical habitat would not be affected by application of herbicides 

as outlined in the Proposed Action. Invasive plant treatments involving herbicides would not 

change the availability of permanent water or the long-term contaminant level of that water 

(PCE-1). Any herbicide entering area streams (no lakes or ponds are designated as critical 

habitat) would be routed downstream in a short-term pulse lasting minutes or hours. Although 

herbicide application in some areas could result in localized shade reduction, these would not 

lead to an increase in water temperature (PCE-2). Most invasive plants provide no shade and 

those large enough to do so, such as knotweed species, are currently localized in small patches. 

There would be no effect to physical habitat structure, substrate conditions, natural flow patterns, 

connectivity with seeps and springs, or migration barriers (PCE-3 through 7). Herbicide use 

would not affect current distribution of non-native fish species (PCE-9). Since there would be no 

aquatic plant, algae and aquatic invertebrate mortality, as described above, there would be no 

effect to the bull trout food base. 

Steelhead Trout and Chinook Salmon 

Although worded differently, the PCE for steelhead and Chinook critical habitat are similar in 

scope and intent as those for bull trout. Similarly, most of the elements outlined in the PCE 

would not be affected by herbicide treatments on the Forest and Scenic Area. The critical habitat 

for these two species encompasses a much larger area than bull trout critical habitat and in most 

river systems extends well upstream of the Forest boundary. 

Herbicide treatments would not affect physical habitat characteristics, water quantity and 

floodplain connectivity, or freshwater migration (PCE-2a, 2c, and 3). The physical condition of 

spawning areas would not be affected (PCE-1). Since most steelhead and Chinook spawn in 

areas where there is adequate depth and velocity for their particular needs, this implies adequate 

mixing to greatly dilute the already small amount of herbicide that may enter streams and pass 

through spawning areas. Most of the known spawning streams for both species are much larger 

than the GLEAMS modeled stream flowing at 1.8 cfs so the concentration of herbicide would be 

lower than presented in this analysis. The discussion above regarding potential effects on the bull 

trout food base (e.g., forage) would also apply to salmon and steelhead. 

3-161
Final Environmental Impact Statement 

Early Detection/Rapid Response Strategy 

The EDRR is critical to eradicate or control new or as yet undiscovered invasive plant infestations in 

the next 15 years. Although it is not possible to characterize yet undiscovered site conditions, it is 

assumed that new sites would be similar in terms of soil type, slope, proximity to water, and other site 

conditions to at least one known site being analyzed in this EIS. As such, it is possible to predict 

potential effects from herbicide treatment applications, given the stipulations discussed in Chapter 2. 

The annual and total acre limitations described in Chapter 2, coupled with fifth-field watershed and 

riparian reserve area restrictions, are designed to allow treatment flexibility while at the same time 

ensuring that no watershed or riparian area is subject to excessive treatment. 

As outlined above, treatment of sites or portions of sites located outside riparian reserves would 

not result in any effects to aquatic fauna or flora. As such any proposed treatment outside 

riparian reserves would not require further scrutiny from an aquatic perspective. Treatment 

within riparian reserves would be expected to have the same level of impact as described above 

for known sites as long as site conditions met those encountered for known sites. Given that a 

wide range of conditions were assessed across the Forest and Scenic Area, such as slope, actual 

proximity to water, presence of vegetation along the water body, etc., it is likely that the analysis 

of existing sites encompasses a wide enough range of conditions that would approximate most, if 

not all, conditions encountered in the future. 

No new herbicides would be used at any new sites. The effects of already analyzed herbicides 

would be the same as described above as long as new site conditions where they are proposed are 

similar to those already analyzed. Since herbicide application at relatively few sites resulted in 

concentrations exceeding the NOEC for any aquatic organism, the fact that the GLEAMS model 

assumptions are conservative and the application of PDC coupled with site conditions would 

result in even less herbicide actually delivered to water, it is apparent that the risk of biologically 

relevant effects across the Forest and Scenic Area is quite low. As such, this would hold true at 

future sites. 

Cumulative Effects 

Although cumulative effects to stream shade, water temperature, nutrients and dissolved oxygen, 

food resources, and turbidity/fine sediment are possible under this alternative and could be 

greater than that described for the No Action Alternative, the overall treatment of invasive plants 

on the Forest and Scenic Area would not add significantly to effects from other land 

management activities. As discussed in Section 3.9 – Water Quality, the invasive plant 

treatments proposed at the fifth-field watershed scale would impact less than two percent of the 

total watershed in all but two watersheds. The two watersheds where treatments would cover 

more than two percent are primarily federally owned, thus many of the activities that could 

contribute to related cumulative effects, such as agriculture and urban influence, are not 

widespread. The cumulative effects of proposed treatments on the above elements, therefore, 

would be quite low for the same reasons as described in Alternative 1. 

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Site-Specific Invasive Plant Treatments 

It is recognized that just because the sheer scale of proposed treatment the effects from this 

alternative would likely be greater than in the No Action Alternative, but at the fifth-field scale 

the effects would still be negligible. To put it in perspective, although a maximum of 13,000 

acres are proposed for treatment in a given year under this alternative, only 2,137 of those acres 

are within the aquatic influence zone where most effects to aquatic resources would occur. The 

aquatic influence zone acres are spread over 22 fifth-field watersheds and encompass from less 

than 0.01 percent to slightly over 0.6 percent of the fifth-field watershed area. In most 

watersheds the amount of proposed aquatic influence zone treated is less than 0.1 percent of the 

total watershed area. Fewer acres would actually be treated for reasons already described. 

Especially given restrictive PDC, the cumulative effects would be quite small at the fifth-field 

scale. 

Site-specific analysis outlined above indicates the anticipated effects from herbicide application 

on all aquatic fauna and flora to be irrelevant, with no mortality. PDC, including restrictions on 

some herbicides with higher biological risk (such as triclopyr), are more restrictive than 

application controls used on state and private land (although we are assuming all formulation 

labels are followed regardless of the application site). As such, the very low impact of herbicide 

use on the Forest and Scenic Area would contribute very little to the overall cumulative herbicide 

effects at the fifth-field watershed scale. (See Section 3.2.4 – Ownership Patterns and Herbicide 

Use on Other Lands for more details.) 

Repeated herbicide treatments at the same location in a given year or over several years are not 

expected to result in cumulative effects to aquatic organisms. The herbicides proposed have not 

been shown to bioaccumulate in aquatic organisms (USDA Forest Service, 2005a) and the small 

amounts anticipated to enter water bodies would be diluted or excreted quickly. The few 

herbicides known to persist in soil are only proposed for use once per year, minimizing their 

effect and concentration in riparian soils (see Section 3.8– Soil Productivity). 

3.10.2.4. Alternative 3 – Restricted Herbicide Use Alternative 

Although the same area is proposed for treatment in this alternative compared to Alternative 2, 

the area proposed for treatment using herbicides is much less (Table 3-34). Alternative 3 relies 

more on manual and mechanical treatments. For example, over half of the riparian reserve acres 

(52 percent) in this alternative would be treated with non-herbicide methods only, compared to 

less than one percent in Alternative 2. Similarly, 57 percent of aquatic influence zone treatments 

would be non-herbicide treatments only, compared to 0.1 percent in Alternative 2. More detail 

on the specific areas for treatment can be found in Chapter 2 and Section 3.9– Water Quality. As 

in Alternative 2, the area in riparian reserves proposed for treatment in any given year is more 

than what would actually be treated given the rate of spread factor used in determining treatment 

acres for this EIS. 

Since less herbicide would be used, the effectiveness of treatments would be less, resulting in the 

need to treat sites more often, except at priority 1 sites where herbicides are still proposed. The 

following discussion of direct and indirect effects is grouped by non-herbicide and herbicide 

treatments. 

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Final Environmental Impact Statement 

Table 3-34: The area of proposed treatment methods in riparian reserves and the aquatic 

influence zone for the entire Forest and Scenic Area under the Restricted Herbicide Use 

Alternative. 

Proposed Treatment Method 

Riparian 

Reserve 

Acres

Aquatic 

Influence 

Zone Acres

Manual 92.8 52.2

Mechanical 9.8 4.6

Manual, Mechanical 2,491.7 1,139.9

Manual, Mechanical, Cultural 21.2 21.2

Herbicide 8.8 6.6

Herbicide with Mechanical 53.1 20.1

Herbicide with Manual and Mechanical 985.5 466.9

Herbicide with Mechanical and Cultural 1,402.4 425.7

TOTAL 5,065.3 2,137.2

Non-Herbicide Treatments: Direct Effects 

Potential direct effects from non-herbicide treatments to aquatic fauna and flora under this 

alternative would be the same as expected in Alternative 2, except that treatments may occur 

more frequently in an attempt to control invasive plants. Due to PDC that still apply however 

there would be no change in anticipated effects compared to Alternative 2. 

Non-Herbicide Treatments: Indirect Effects 

The same habitat elements discussed in Alternative 2 could be indirectly affected under this 

alternative. There would be no difference in effects to nutrients, dissolved oxygen, or shade 

reduction from blackberry removal under this alternative as compared to Alternative 2. Goat 

grazing is not prescribed over a larger area in this alternative and the efficiency of this grazing 

would be the same as in Alternative 2. Although more plants may be cut or killed from manual 

or mechanical methods, the amount disposed of in surface water (if any) would be the same as 

previously described. 

As described in Section 3.9 – Water Quality, the risk of erosion and potential sediment delivery 

to surface water under this alternative from manual and mechanical methods is very low, even 

lower than Alternative 1. 

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Site-Specific Invasive Plant Treatments 

Herbicide Treatments: Riparian Reserve Site Summary 

Of the 43 sites where herbicide treatment is proposed under this alternative, 17 of the sites are 

located outside riparian reserves. The application of herbicides at sites located outside riparian 

reserves would not result in a biologically relevant herbicide amount entering area water bodies, 

thus they are not discussed further. Nine of the 26 sites with some riparian reserve herbicide 

treatments are located adjacent to, or near, water bodies that do not harbor fish (Table W-4, 

Appendix W). These sites encompass 173 total acres with relatively little treatment proposed in 

riparian reserves (16 acres) and in the aquatic influence zone (11 acres). 

The remaining 17 sites where herbicides are proposed for use under this alternative are located 

adjacent to fish-bearing streams. Six of the sites are near water bodies that do not harbor special 

status fish species, but the remaining 12 sites are located next to streams where threatened, and in 

one case endangered, salmonids reside (Table W-5, Appendix W). None of the sites are located 

on the Barlow Ranger District. 

Although less than half the sites where herbicides are proposed for use in this alternative are 

located wholly or partially along fish-bearing streams, they make up the majority of the proposed 

herbicide treatment area – about 3,674 acres or 91 percent of the 4,047 acre total. Over half (66 

percent) of these site acres lie within riparian reserves, and one quarter of the acres (906 acres) 

lie within the aquatic influence zone. All 17 sites have some treatment proposed within the 

aquatic influence zone, though at several sites it is a very small amount. Four sites are quite large 

compared to the others (22-01, 66-007, 69-008, 69-027); these four sites encompass 3,295 acres 

of which 2,293 acres are within riparian reserves and 842 acres within the aquatic influence 

zone. 

Herbicide Treatments: Direct Effects 

Since the priority 1 sites in this alternative are the same as in the Proposed Action, potential site 

specific effects would be the same as already described for those sites. There would be no effect 

from herbicide treatment at priority 2 to 5 sites. Less than half the total riparian reserve acres 

proposed for herbicide treatment in the Proposed Action would be treated under Alternative 3, 

and proposed herbicide treatment in the aquatic influence zone is about two thirds less than the 

Proposed Action. 

Aquatic Plants and Algae 

Typical application rates of two herbicides, chlorsulfuron and imazapic, could result in exposures 

that exceed the acute NOEC for aquatic plants, but only at sites 22-01 and 66-084 (refer to Table 

3-33 also). The same discussion regarding potential effects from herbicides outlined for 

Alternative 2 would apply here for these two sites. 

Invertebrates and Fish 

As described for Alternative 2, direct effects to aquatic invertebrates or fish from herbicide 

application are not expected. Predicted herbicide concentrations are already well below lethal 

doses even before the application of PDC, which would result in even lower concentrations in 

water. Mortality to aquatic invertebrates or fish would not occur at any site. 

3-165
Final Environmental Impact Statement 

Herbicide Treatments: Indirect Effects 

Algae, Aquatic Plants, and Invertebrates 

As in Alternative 2, there would be no indirect effects to aquatic plants or algae resulting from 

the implementation of this alternative. There would be no mortality of any aquatic fauna and the 

amount of herbicide that could leach into water bodies over time would be so small due to PDC, 

adsorption, degradation, and dilution it would be biologically irrelevant. Predicted herbicide 

concentrations did not exceed the NOEC for aquatic invertebrates at any site thus effects to these 

organisms would be irrelevant. There would be no mortality of aquatic invertebrates at any 

location as a result of herbicide application. 

Fish 

Under this alternative there are only two herbicides, glyphosate and AQ glyphosate, which could 

result in exposures exceeding the acute NOEC for fish, but only at the seven sites listed below 

(refer to Table 3-33 as well): 

22-01 65-019 66-008 

69-008 69-012 69-028 

69-029 

Salmonids listed as endangered or threatened are present at six of the seven sites (all but 69-028); 

there are USDA Forest Service, Pacific Northwest Region sensitive fish species present at site 

66-008. 

As described in Alternative 2, although the predicted herbicide concentrations exceed the NOEC 

at these sites the actual expected concentrations would be much lower due to specific site 

conditions and PDC. At no site is mortality anticipated and the amount of herbicide that could 

enter water would be so small as to be irrelevant from a biological perspective. 

Early Detection/Rapid Response Strategy 

The same rationale and process described for the Proposed Action would apply to the Restricted 

Herbicide Use Alternative in regards to EDRR, except only the priority one sites would be 

treated with herbicides. It is likely the amount of herbicide applied in the future overall would be 

less than in the Proposed Action; however, this depends on the nature and location of new 

infestations. The same potential effects to riparian and aquatic systems already described would 

apply to areas treated under this alternative. 

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Site-Specific Invasive Plant Treatments 

Cumulative Effects 

Anticipated cumulative effects associated with the Restricted Herbicide Use Alternative would 

be negligible at the fifth-field watershed scale. On a relative range of effects the actions in this 

alternative would fall between the No Action and Proposed Action Alternatives in terms of 

herbicide effects, but would actually be less from a potential sedimentation perspective 

compared to the No Action Alternative. The cumulative effects of proposed treatments on the 

habitat elements described previously would be quite low for the same reasons as described for 

the previous alternatives. 

Although the riparian acres proposed for treatment are the same as in Alternative 2, the area 

subject to herbicide treatment is about half of that in the Proposed Action. Conversely, the 

riparian acres proposed for only manual or mechanical treatments more than doubles compared 

to the Proposed Action. All PDC would still apply, minimizing treatment effects at all sites. 

3.10.3. Determination of Effects Including Essential Fish Habitat 

Determination of Effects on Proposed, Endangered, and Threatened Species (PETS) Species –

Alternative 1

Given the scale of existing treatments, PDC already in place, and the incorporation of USDA 

Forest Service, Pacific Northwest Region prevention practices (Invasive Plant ROD, USDA 

Forest Service, 2005b), the effects to PETS species from authorized invasive plant treatments 

would not change from original determinations outlined in existing NEPA documentation. If 

anything, effects from future treatment would be less due to the application of prevention 

practices. Cumulative effects related to treatment would be insignificant. 

Since approved treatments would not eradicate or control invasive plants, aquatic habitat 

conditions at large invasive plant infestation sites could worsen. The scale and severity of habitat 

degradation would depend on several factors including the invasive plant species present. For 

example, Japanese knotweed can grow in large patches and exclude virtually all other plant 

species; reproduce rapidly and in a variety of ways; and roots shallowly. As such, it is a poor 

stream bank stabilizer and one of the most detrimental invasive plants to aquatic environments. 

As a result of increased invasive plant spread, riparian and aquatic habitat conditions would 

experience a slow decline in areas with large infestations. 

Effects on listed and USDA Forest Service, Pacific Northwest Region sensitive species would 

not change from original determinations as a result of this decline in habitat conditions; however, 

the trend in habitat conditions could be negative and lead to more degraded conditions at some 

sites. 

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Final Environmental Impact Statement 

Determination of Effects on PETS Species – Alternative 2

The Forest Service cannot state that no herbicide would ever enter any water body, but the 

analysis illustrates than the potential amounts would be so small as to be biologically 

insignificant. The potential amount of sedimentation and shade reduction also is quite small and 

would not result in any significant change in amounts of fine sediment or water temperature. 

Potential effects would be short-term and biologically irrelevant to all PETS species (Table 3-

35), and the long-term result of proposed treatment at all sites would be beneficial as native 

riparian vegetation would be restored. 

Although the effects of future herbicide treatments can be predicted based on existing site 

conditions, it is difficult to predict where new sites would be found and thus which stocks may 

be affected. Thus, the chance that invasive plant treatment may occur near streams with listed 

fish or USDA Forest Service, Pacific Northwest Region sensitive species from future herbicide 

treatment cannot be ruled out. Effects from such treatment would be insignificant however as 

treatment and site conditions would approximate those already described at known sites. 

There is a low probability of minor, discountable negative effects to designated Chinook salmon, 

chum salmon and steelhead trout critical habitat at the site scale. At the 5th field watershed scale 

the effect would be neutral. Essential fish habitat would not be adversely affected. 

Determination of Effects on PETS Species – Alternative 3

Effects from this alternative would be similar to those in Alternative 2 (Table 3-35), but on an 

even smaller scale as fewer acres would be treated with herbicide, the primary mechanism for 

impacts to aquatic species. 

There is a low probability of minor, discountable negative effects to designated Chinook salmon, 

chum salmon and steelhead trout critical habitat at the site scale. At the 5th field watershed scale 

the effect would be neutral. Essential fish habitat would not be adversely affected. 

Table 3-35. A summary of anticipated effects for aquatic PETS species that are found 

within the Forest and Scenic Area from Alternatives 2 and 3. 

Species DPS/ESU Effect 

Determination Rationale 

Potential short-term disturbance; 

EDRR. Bull Trout Columbia River NLAA 

Potential short-term disturbance; 

EDRR; Potential sub-lethal effects 

from herbicide application. 

Steelhead Trout Lower Columbia NLAA 

Potential short-term disturbance; 

EDRR. Steelhead Trout Middle Columbia NLAA 

Chinook Salmon Lower Columbia NLAA 

Potential short-term disturbance; 

EDRR; Potential sub-lethal effects 

from herbicide application. 

Chinook Salmon Upper Willamette NLAA 

Potential short-term disturbance; 

EDRR; Potential sub-lethal effects 

from herbicide application. 

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Site-Specific Invasive Plant Treatments 

Species Effect DPS/ESU Rationale Determination 

Potential short-term disturbance; 

EDRR. Chum Salmon Columbia River NLAA 

Potential short-term disturbance; 

EDRR; Potential sub-lethal effects 

from herbicide application. 

Coho Salmon Lower Columbia NLAA 

Federally Listed Species found only in the Columbia River 

Not present near treatment area; 

Columbia River so large herbicide is 

greatly diluted. 

Steelhead Trout Upper Columbia NLAA 

Not present near treatment area; 

Columbia River so large herbicide is 

greatly diluted. 

Steelhead Trout Snake River NLAA 

Not present near treatment area; 

Columbia River so large herbicide is 

greatly diluted. 

Chinook Salmon Upper Columbia NLAA 

Not present near treatment area; 

Columbia River so large herbicide is 

greatly diluted. 

Chinook Salmon Upper Columbia NLAA 

Not present near treatment area; 

Columbia River so large herbicide is 

greatly diluted. 

Sockeye Salmon Snake River NLAA 

USDA Forest Service, Pacific Northwest Region Sensitive Species 

Redband/Inland 

Rainbow Trout NA MIIH 

Potential short-term disturbance; 

EDRR; Potential sub-lethal effects 

from herbicide application. 

Columbia 

duskysnail NA MIIH 

Potential short-term disturbance; 

EDRR; Potential sub-lethal effects 

from herbicide application. 

Critical Habitat and Essential Fish Habitat 

Steelhead and Chinook Critical Discountable impacts 

Habitat NLAA 

Essential Fish Habitat NAA Discountable impacts 

Abbreviations/ Acronyms: 

CH Critical Habitat 

NE No Effect 

NLAA May affect, not likely to adversely affect 

MIIH May Impact Individuals or Habitat, but Will Not Likely Contribute Towards Federal 

Listing or a Loss of Viability to the Population or Species 

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Final Environmental Impact Statement 

3-170

3.10.4. Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action and 

Restricted Herbicide Use Alternatives are consistent with all relevant standards and guidelines, when 

the proposed amendments are incorporated. The Forest Plan amendments are discussed in Section 3.16. 

3.10.5. Incomplete and Unavailable Information 

Studies of effects to aquatic mollusks, fungi, or unicellular organisms are generally not available. 

Herbicide effects to these organisms are possible, although available information indicates both 

benefits and negative effects. Effects to aquatic mollusks, fungi and unicellular organisms are likely to 

be transient and localized. Standards and PDC that protect other aquatic organisms and are expected to 

also protect these organisms. 

Information concerning sub-lethal herbicide effects to fish and other aquatic organisms is also limited. 

The SERA risk assessments for some herbicides were based on studies that identified the NOEC for 

sub-lethal effects (SERA, 2001a, 2003a, 2003c, 2003e; Bakke, 2003b). These risk assessments most 

likely described the risk of sub-lethal effects to fish and the overall significance to fish populations. For 

other herbicides, the risk assessment estimated NOEC from lethal doses, which may or may not 

encompass concern for sub-lethal effects. The estimated NOEC values, however, are very conservative 

to take into account sub-lethal effects. 
Site-Specific Invasive Plant Treatments 

3.11. Wildlife 

3.11.1 Existing Conditions 

There are a number of ways that the Forest and Scenic Area analyze projects to ensure that the 

diversity of species found on the Forest and Scenic Area are maintained. Since the list of existing 

species is so extensive, it is more beneficial to concentrate the analysis on species that are more 

sensitive to anthropogenic influences. A variety of lists have been developed to help look at species 

that either are declining, sensitive to management, or important from a recreational perspective. Some 

species or species groups could be considered a litmus test for the ecology of the area because they 

are more easily detected and could be surveyed. 

The following lists are arranged in order of importance for analysis: wildlife special status species 

which includes Pacific Northwest Regional Forester’s sensitive species, survey and manage species, 

Forest Plan management indicator species (MIS), and landbirds listed as Partners in Flight focal 

species. The main discussion of these species and list is to determine what species on the list require 

further analysis for effects from invasive plant treatments. For some species, such as the threatened, 

endangered and sensitive species and survey and manage species, the effect is determined for the 

individual species. For other species such as the MIS and landbirds the effects analysis are used to 

assess the impact to similar species in that group. 

The first step in the analysis is to determine what species would be present in the area and habitats 

that would be treated. Some of the species on the list may occur in the area at some time during the 

year, but do not when the treatments are expected to occur and do not need further analysis. One 

example is the red-necked grebe: the red-necked grebe is only a winter migrant and no nesting has 

been documented on the Forest and Scenic Area. The second step is to look at the species habitat and 

range, and determine the potential for the species to be in an area that proposed for treatment. The 

tables summarize the present knowledge of these species on the Forest and Scenic Area, in order to 

concentrate the analysis on the species most likely to be affected by invasive plant treatments. 

Wildlife Special Status Species 

The Forest and Scenic Area terrestrial wildlife included in the USDA Forest Service, Pacific 

Northwest Region’s Proposed, Endangered, Threatened and Sensitive species program are listed in 

Table 3-26. The Proposed, Endangered, Threatened and Sensitive species program is a proactive 

approach for meeting the USDA Forest Service’s obligations under the Endangered Species Act 

(ESA); National Forest Management Act (NFMA); National Policy direction as stated in USDA 

Forest Service Manual, 2670 Section; and the U.S. Department of Agriculture Regulation 9500-4. The 

primary objectives of the program are to ensure that USDA Forest Service actions do not contribute to 

a loss of viability, or cause a trend toward listing under ESA. Species identified by the U.S. 

Department of Interior, Fish & Wildlife Service (FWS) as “candidates” for listing under the ESA, and 

species that meet the USDA Forest Service criteria for protection, are included on the USDA Forest 

Service, Pacific Northwest Regional Forester’s Sensitive Species Lists. 

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Final Environmental Impact Statement 

Table 3-36: Special Status/Sensitive Wildlife Species. These are terrestrial wildlife species found 

on the Forest and Scenic Area that are included in the USDA Forest Service, Pacific Northwest 

Region’s “Proposed, Endangered, Threatened and Sensitive species program.” (T=Threatened; 

E=Endangered; S=Sensitive; P=Proposed).

Species 

Forest 

Occurrence Scenic Area Occurrence 

Northern Spotted Owl (T) Documented Documented 

Northern Bald Eagle (T) Documented Documented 

Oregon Slender Salamander (S) Documented Documented 

Larch Mountain Salamander (S) Documented Documented 

Cope’s Giant Salamander (S) Documented Documented 

Cascade Torrent Salamander (S) Documented Documented 

Oregon Spotted Frog (S) Documented Suspected 

Painted Turtle (S) Suspected Documented 

Northwestern Pond Turtle (S) Suspected Documented 

Horned Grebe (S) Documented Documented 

Red-necked Grebe (S) No Records Documented winter migrant 

Bufflehead (S) Documented Documented 

Harlequin Duck (S) Documented Documented 

American Peregrine Falcon (S) Documented Documented 

Gray Flycatcher (S) Suspected Suspected 

Black Swift (S) No records Suspected 

Baird’s Shrew (S) Documented No records 

Pacific Fringe-tailed Bat (S) Documented Suspected 

Pacific Pallid Bat (S) No records Documented 

California Wolverine (S) Documented Documented 

Pacific Fisher (S) Suspected Suspected 

Crater Lake Tightcoil (Pristiloma arcticum crateris) (S) Documented No records 

Dalles Sideband (Monadenia fidelis minor) (S) Documented Documented 

Puget Oregonian (Cryptomastix devia) (S) Documented Documented 

Columbia Oregonian (Cryptomastix hendersoni) (S) Documented Documented 

The following details information for each of the special status species listed in Table 3-36. The 

descriptions focus on the action area for this project. The action area consists of the Forest and Scenic 

Area in Oregon. 

• Northern Spotted Owl: This bird is widespread on the Forest on both sides of the Cascades and 

on the Scenic Area. Experiencing a population decline across its range for reasons that are still 

being analyzed. 

• Northern Bald Eagle: This bird is widespread along the Columbia River in the Scenic Area 

and limited in distribution to a few larger lakes on the Forest. Experiencing a population 

recovery across most of its range in the Pacific Northwest. 

• Larch Mountain Salamander: Limited in distribution to rocky, forested areas especially where 

there is talus. More common on the Scenic Area. There are only a few locations on the Forest. 

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Site-Specific Invasive Plant Treatments 

• Oregon Slender Salamander: Widespread across both the Forest and Scenic Area. The known 

range for this species expanded in the last six years onto the eastside of the Cascades. 

• Cope’s Giant Salamander: Although it has limited range this species is found in fair numbers 

on both the Forest and Scenic Area in small cold moderately swift streams on the west side of 

the Cascades. 

• Cascade Torrent Salamander: Although it has limited range this species is found in fair 

numbers on both the Forest and Scenic Area in small cold moderately swift streams and seeps 

on the west side of the Cascades. 

• Painted Turtle: Although potential habitat exists, there are no known locations in the action 

area. The only known painted turtle site on the administrative units is on the Washington side 

of the Scenic Area, which is not in the action area. This species is easy to detect when present 

so it is not anticipated that any turtles are located in the project area or the ED/RR area. 

• Northwest Pond Turtle: There are only a few known sites located on the Scenic Area. This 

species is easy to detect when present. There are no known locations on the Forest. 

• American Peregrine Falcon: The peregrine falcon is a bird that occurs in small numbers in 

highly specialized cliff areas on both the Forest and Scenic Area. 

• Gray Flycatcher: This small flycatcher uses sagebrush for its principal habitat. It is suspected 

on both the Forest and Scenic Area where a small amount of sagebrush occurs. There are no 

records of the species on either area. This species will not be analyzed for effects because 

there is no risk of impact for this species. 

• Black Swift: This swift is the largest of the North American swifts and nest under or adjacent 

to large waterfalls. They are extremely secretive and difficult to find. Due to the large number 

of waterfalls in the Scenic Area, they are officially listed as suspected for the Scenic Area. 

There is also some potential for them on the Forest since there are a number of large 

waterfalls. This species will not be analyzed for effects, since there is no risk of impact for this 

species because no herbicide treatments would occur near large waterfalls. 

• Horned Grebe: This aquatic bird is mostly observed in the winter on the Forest and Scenic 

Area. No breeding records occur. This species has been documented on both the Mt. Hood and 

the Scenic Area. 

• Red-necked Grebe: This aquatic bird is mostly observed in the winter on the Scenic Area. No 

breeding records occur. This species has been documented on the Scenic Area; however it will 

not be analyzed for effects. There is no risk of impact for this species since it is a winter 

migrant and there would be no invasive plant treatments during the time that these species 

would be present. 

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Final Environmental Impact Statement 

• Bufflehead: Buffleheads are ducks that have been documented breeding recently on the Forest. 

This species occurs regularly in winter on both the Forest and the Scenic Area. 

• Harlequin Duck: Harlequin ducks occur in small numbers on Cascade streams on the Forest 

and Scenic Area. 

• California Wolverine: There are records of occurrence as recently as 1996 from the Forest and 

1990 for the Scenic Area. This mammal species occurs only in small numbers, if at all. It is 

possible that the amount of people presence on public lands has eliminated this species, but 

there is hope of finding wolverines still inhabiting our landscape. Recent analysis by Dr. Keith 

Aubry speculates that wolverine records in Oregon my be from wandering individuals at times 

of food shortages in their primary territories to the north and east (Aubry, Keith B. et al, 

Western Forest Carnivore Committee Conference March 2006). 

• Baird’s Shrew: Baird’s shrews are documented on the Forest, but not on the Scenic Area. 

There is a lack of good information on the actual populations of this species on the Forest. 

Surveys tend to kill this species, so there is a reluctance to do extensive surveys to determine 

the full extent of the population. 

• Pacific Fringed-tailed Bat: There are is one documented occurrence of this bat on the Forest, 

but it is listed as suspected on both units. The documented occurrence was revealed through 

personal communication with Mark Perkins, a bat researcher that conducted bat surveys on 

Mt. Hood National Forest in the 1990s (Perkins, 2006). 

• Pacific Pallid Bat: This bat is typically found in the drier areas of Oregon. It has been 

documented on the Scenic Area. The bat inhabits buildings, caves, rocky crevices, and may 

roost under bridges. 

• Pacific Fisher: Fishers were eliminated from most of Oregon, by fur trappers, many years ago. 

Efforts to restock the species from British Columbia took place on the eastside of the Cascades 

in the Crater Lake area. There have been no documented records of this mammal closer than 

the Crescent Ranger District, Deschutes National Forest. 

• Crater Lake Tightcoil–Pristiloma arcticum crateris: This snail species is so small that it is 

difficult to survey. There is a record of this species on the Forest. This species requires higher 

elevations with persistent snow cover. Perennial wet situations in mature forest habitats among 

rushes, mosses and other surface vegetation or under rocks and woody debris within 30 feet of 

open water in wetlands, springs, seeps and riparian areas. 

• Dalles Sideband–Monadenia fidelis minor: This snail inhabits the dryer areas of both the 

Forest and Scenic Area. This species is usually associated with basalt talus, within 200meters 

of streams, seeps, or springs in steppe or dry forest plant communities. May be found among 

rocks, shrubs, or other vegetation and under down wood. 

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Site-Specific Invasive Plant Treatments 

• Puget Oregonian–Cryptomastix devia: Both the Forest and Scenic Area are home to this snail 

species. Mature or old growth forest habitat, typically on or under hardwood logs and leaf 

litter. Rocks and talus, which are cool and moist beneath, may also be used. These snails are 

also found on or in the litter under sword fens growing under hardwood trees and shrubs, 

especially big leaf maples. 

• Columbia Oregonian–Cryptomastix hendersoni: This snail species is slightly more abundant 

than the Puget Oregonian and has been located on both administrative units. Generally found 

within 100-meters of streams, seeps and springs east of the Cascade divide and in the 

Columbia Gorge. In Western Cascades, it could also be found in mature forested habitats 

outside of riparian areas, among small, moist talus, hardwood leaf litter or shrubs, or under 

longs or other debris. 

Survey and Manage Species 

In 1994, the U.S. Department of the Interior, Bureau of Land Management (BLM) and the USDA 

Forest Service adopted standards and guidelines for the management of habitat for late-successional 

and old-growth forest related species within the range of the Northern Spotted Owl, commonly known 

as the Northwest Forest Plan (USDA Forest Service and USDI BLM, 1994). Mitigation measures 

were included for the management of known sites, site-specific pre-habitat disturbing surveys, and/or 

landscape scale surveys for about 400 rare and/or isolated species. These are species that, either 

because of genuine rarity or because of a lack of information, the Agencies did not know whether 

they would adequately be protected by other elements of the Northwest Forest Plan (USDA Forest 

Service and USDI BLM, 1994). The standards and guidelines for these mitigation measures are 

known as Survey and Manage (USDA Forest Service and USDI BLM, 2001). This decision was 

amended in January 2001 by the Record of Decision and Standards and Guidelines for Amendments 

to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and 

Guidelines. The 2004 Record of Decision to Remove of Modify the Survey & Manage Mitigation 

Measures Standards and Guidelines (USDA Forest Service and USDI BLM, 2004), removed the 

standards and guidelines, and moves some species onto the Region’s Proposed, Endangered, 

Threatened and Sensitive species program(USDA Forest Service and USDI BLM, 2004). On January 

9, 2006, Judge Pechman issued an order that set aside the 2004 Record of Decision (USDA Forest 

Service and USDI BLM, March 22, 2004) and reinstated the 2001 Record of Decision (USDA Forest 

Service and USDI BLM, January 2001), along with any amendments or modifications (including the 

2003 Annual Species Review decisions) that were in effect as of March 21, 2004. 

Table 3-37 lists the terrestrial Survey and Manage species that will be included in the analysis for the 

invasive plant treatment projects. 

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Final Environmental Impact Statement 

Table 3-37: Terrestrial Survey & Manage Species, included in the Record of Decision and 

Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and 

other Mitigation Measures Standards and Guidelines (USDA Forest Service and USDI BLM, 

2001). (S=Sensitive). 

Species 

Forest 

Occurrence 

Scenic Area 

Occurrence Surveys Needed? 

Great Gray Owl No Records No Records No 

Oregon Red Tree Vole Documented Documented No 

Larch Mountain Salamander (S) Documented Documented No 

Evening Field Slug 

(Derocerous hesperium) (S) No Records No Records Yes 

Crater Lake Tightcoil 

(Pristiloma arcticum crateris) (S) Documented No Records No 

Dalles Sideband 

(Monadenia fidelis minor) (S) Documented Documented No 

Puget Oregonian 

(Cryptomastix devia) (S) Documented Documented No 

Columbia Oregonian 

(Cryptomastix hendersoni) (S) Documented Documented No 

On page 22 of the Standards and Guidelines of the 2001 Survey and Manage ROD it indicates that, 

“the line officer should seek specialists’ recommendations to help determine the need for surveys 

based on site-specific information”. The line officers for this decision are the Mt. Hood National 

Forest, Forest Supervisor and Columbia River Gorge National Scenic Area, Area Manager. It is the 

Forest Wildlife Biologist recommendation that surveys are not necessary for the great gray owls on 

either the Forest or Scenic Area, based on a lack of records from multiple surveys over several years, 

Great gray owls were searched for during strategic surveys and project surveys from 1995-1998. No 

owls have ever been recorded during those surveys and no one has ever reported a great gray owl 

sighting on the Forest or Scenic Area. In addition, there are no habitat changes that would adversely 

affect great gray owl populations or there prey. Because the likelihood of an owl being present is low 

and the effects to the habitat would not impact great gray owls, it is recommended that no surveys be 

completed for this species. 

Red tree voles are arboreal species and there are no treatment methods that would affect this species 

or it’s habitat due to the ecology of this vole. It is the Forest Wildlife Biologist recommendation that 

surveys are not necessary for red tree voles for the invasive plant treatment project covered in this 

EIS. 

Larch Mountain Salamanders are terrestrial salamanders that are closely associated with mature 

timber and rock talus. All of the known locations in the Scenic Area and Forest for this salamander 

are in this type of habitat. An extensive amount of surveys were done on the Forest for this species 

and no new locations have been discovered despite research level survey efforts. The 

recommendation for this species on the Forest and Scenic Area is to avoid impacts to this species by 

not planning projects in this habitat. The PDC eliminate the need to survey for this species. 

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Site-Specific Invasive Plant Treatments 

Derocerous hesperium, a rare slug has not been located on the Forest despite extensive pre-project 

surveys and strategic survey efforts. In discussions with Steve Dowlan (2006), one of the authors of 

the 2003 Survey Protocol for terrestrial mollusk, he indicated that Derocerous hesperium had recently 

been discovered in grassy wet meadows with standing water. Dowlan (2006) felt that surveys were 

not warranted in areas that do not meet this habitat description. There are no anticipated impacts to 

the habitat or populations of this slug if they happen to be present in the proximity of the treatment 

areas. Therefore, it is the Forest Wildlife Biologist recommendation that efforts to survey for these 

species be confined to the meadow at site 69-028 unless they are part of the surveys for other species. 

Surveys for this species were completed in May and June of 2006 at site 69-028. The habitat at this 

site was too dry for this species, and no other sensitive or Survey and Manage mollusk were located 

during the protocol surveys. 

Pristiloma arcticum crateris (Crater Lake Tightcoil), Monadenia fidelis minor (Dalles Sideband), 

Cryptomastix devia (Puget Oregonian), and Cryptomastix hendersoni (Columbia Oregonian) are not 

found in the habitats that are planned for treatments or the PDC has been designed to reduce the 

impacts of treatment by avoiding broadcast boom spraying in the habitats where these species could 

potentially be found (near seeps, springs, and riparian areas). Since these species are typically under 

leaf litter or rocks and logs during the temperatures and humidity where invasive plant treatments 

normally take place, the potential impacts to these species does not warrant surveys. There would not 

be a substantial change to the native habitats that these species inhabit so the recommendation is that 

no surveys for these species be implemented for the treatment of invasive species. 

Management Indicator Species (MIS) 

The Forest Plan, which includes the Scenic Area lands in Oregon, utilized a strategy of Management 

Indicator Species (MIS) to represent other species: these species require special wildlife 

considerations. These species presumably are representative of the habitat needs of other species 

because they have similar biological traits. The species selected were elk, deer, pileated woodpecker, 

American marten, Northern Spotted Owl, silver gray squirrel, and Merriam’s turkey. All of these 

species are analyzed except Merriam’s turkey, which is an introduced species. 

Landbirds 

Approximately 176 bird species occur on the Forest and Scenic Area utilizing a wide variety of habitats. 

One hundred and eight of these birds are classified as landbirds. Of these birds 6 species are included in 

this analysis because they are recommended for management by the Partners in Flight Landbird 

Conservation Plan (2004) and the Conservation Strategy for Landbirds in Coniferous Forest of Western 

Oregon and Washington (Altman, 1999). The six species that are analyzed are: hermit warbler, blue 

grouse, rufous hummingbird, willow flycatcher, band-tailed pigeon, and olive-sided flycatcher. These 

species have wide distribution on the Forest and Scenic Area. 

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Final Environmental Impact Statement 

State Recognized Species Analysis for Scenic Area Management Plan 

The Scenic Area Management Plan incorporates the state listed species as a analysis tool. The species 

are addressed and effects to these species are located in Table X-4 in Appendix X – Effects of 

Herbicides on Wildlife Species. The effects analysis for these species is based on similar species 

addressed by the body of this EIS. This includes species in the same taxonomic group, life history, 

distribution, and feeding strategy. The effects to amphibians and reptiles are largely unknown and this 

is also reflected in this table. 

3.11.2 Effects Analysis & Methodology 

Excerpts from the Invasive Plants FEIS (2005a) are used throughout this discussion. The effects 

analysis of individual herbicides and surfactants are used here. Facts, figures, herbicides, and species 

analysis are modified to reflect the site-specific analysis effort on the Forest and Scenic Area. 

Additional information regarding the impacts of this project on wildlife species is contained in 

Appendix X – Effects of Herbicides on Wildlife Species, and Wildlife Specialist Report, Biological 

Evaluation, and Biological Assessment. 

The following terminology and introduction from the Invasive Plants FEIS (2005a) are repeated here 

for easy reference, and are pertinent to discussion of effects on wildlife on the Forest (Pages 4-42 to 

4-44). 

• NOAEL (No observed adverse effect level): An exposure level at which there is no statistically 

or biologically significant increases in the frequency or severity of adverse effects between the 

exposed population and its appropriate control. Some effects may be produced at this level, 

but they are not considered as adverse, or as precursors to adverse effects. In an experiment 

with several NOAELs, the regulatory focus is primarily on the highest one, leading to the 

common usage of the term NOAEL as the highest exposure without adverse effects. 

• LOAEL (Lowest Observed Adverse Effect Level): The lowest dose associated with an adverse 

effect. 

• Toxicity index: The benchmark dose used in analysis to determine a potential adverse effect 

when it is exceeded. Usually a NOAEL, but when data are lacking other values may be used. 

When considering the effects of herbicides on wildlife species, remember these herbicides are 

designed to affect plants at relatively low rates, while much higher rates would be required to kill 

animals. Plants have metabolic systems that do not exist in animals. It is these metabolic systems at 

which the herbicides are targeted. Michael (2002) explained it well when he said, “All chemicals, 

natural or man-made, are toxic at some level of exposure. The difference between acute and chronic 

toxicity versus the no observed effect level (NOEL) is primarily a function of the amount of exposure 

in a unit of time and the mode of action of the chemical. For example, vitamin D is essential to good 

health and mammals consume it on a daily basis. However, it could be very toxic, in fact more toxic 

than most of the herbicides used in forest management” (Michael, 2002). 

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Site-Specific Invasive Plant Treatments 

Results of numerous field studies indicate the likelihood for direct adverse effects to wildlife from 

herbicide use is low (e.g., Marshall & Vandruff, 2002; Dabbert et al., 1997; Fagerstone et al., 1977; 

Rice et al., 1997; Sullivan et al., 1998a, Cole et al., 1997; Cole et al., 1998; Johnson & Hansen, 1969; 

Nolte and Fulbright, 1997, McMurray et al., 1993a; McMurray et al., 1993b). The use of herbicides to 

treat invasive plants, however, does have the potential to harm free-ranging wildlife. Certain 

herbicides have the potential, for example, to affect the vital organs of some wildlife species, change 

body weight, reduce the number of healthy offspring, increase susceptibility to predation, or cause 

direct mortality. Birds and mammals may ingest vegetation or insects that have been sprayed with 

some herbicides and potentially experience these types of effects. 

Herbicides may also cause some malformations or mortality to amphibians that have been exposed to 

herbicides or surfactants in water (Relyea, 2005). In addition, herbicides contain impurities and 

additives, and produce metabolites that could be toxic to wildlife. A metabolite of triclopyr, 3,56-

trichloro-2-pyridinol (TCP), is toxic to animals. The impurity hexachlorobenzene, found in picloram 

and clopyralid, is carcinogenic. Surfactants added to herbicides could substantially increase toxicity to 

aquatic species, like amphibians. These substances were evaluated in the relevant risk assessments 

and, with the exception of surfactants, were found not to contribute substantially to toxic exposures or 

increase cancer risk (SERA, 2003a, 2003b, 2003c, 2004b). 

The results of the herbicide analysis indicate that birds or mammals that eat grass or insects are most 

susceptible to harm from herbicides. Birds or mammals that eat vegetation (primarily grass) that has 

been sprayed with herbicide have relatively greater risk for adverse effects because herbicide residue 

is higher on grass than it is on other herbaceous vegetation or seeds (Kenaga, 1973; Fletcher et al., 

1994; Pfleeger et al., 1996). Because of their small size and relatively larger surface area, herbicide 

residues on insects may also be higher (Kenaga, 1973). Some birds and mammals that eat grass 

include elk, rabbits and hares, chukar, California quail, and geese. Some bird species (like quail) are 

primarily herbivorous as adults but require insects as a primary food source as chicks. Insect-eating 

mammals include bats and shrews. Insect-eating birds include a huge number of species, such as 

bluebirds, flycatchers, swallows, wrens, and others. 

The measuring factors used for comparing the alternatives are: 

• The total number of acres of wildlife habitat benefited by removal of invasive species to 

restore native vegetation and rate of treatment. 

• The number of treatment acres that bisect or traverse areas of late-successional habitat where 

potential exposure to herbicides could occur for special status species using this habitat type. 

Surfactants (NPE) added to herbicides also have the potential to result in harmful doses to birds and 

mammals that eat vegetation or insects that have been sprayed. For the purpose of analysis, it is 

assumed that the number of plausible exposure scenarios that exceed the toxicity indices is the same 

for surfactant as it is for the herbicides. No estimate of acres treated using NPE surfactants is made 

because surfactants may not be used, or other additives may be used instead, so there is no direct 

correlation between acres treated with herbicide and acres treated with NPE. 

3-179 
Final Environmental Impact Statement 

Analytical Methods 

The analytical methods used in determining toxicity of herbicides and surfactants on wildlife species 

including special status species, management indicator species and land birds can be found in 

Appendix X. 

The number of acres of wildlife habitat benefited by removal of invasive species to restore native 

vegetation and rate of treatment is determined by the acres treated and the rate of treatment 

determined by the effectiveness of the treatment method. 

The number of special status species potentially exposed to herbicides following implementation of 

the PDC is determined by Geographic Information System (GIS) analysis of the number of acres of 

herbicide treatment that dissect or traverse habitat that is suitable for Northern Spotted Owls (eighty 

years old and older with multilayered canopies and greater than 60 percent canopy closure). 

The number of special status species potentially impacted by manual, mechanical, or cultural 

treatments following implementation of the PDC is determined by Geographic Information System 

(GIS) analysis of the number of acres of non-herbicide treatment that dissect or traverse habitat that is 

suitable for Northern Spotted Owls (eighty years old and older with multilayered canopies and greater 

than 60 percent canopy closure). 

Effects Thresholds 

Thresholds provide an overall measurement of how the Proposed Action would influence the existing 

environment. The regulations issued by the CEQ to implement the NEPA define significance of 

effects in terms of context and intensity. Context refers to the geographic area of effect, which varies 

with the physical setting of the Proposed Action and with each element of the environment being 

analyzed. Intensity refers to the severity of the effect. Duration also must be considered in the 

assessment of effects and effects must be quantified as much as possible. For this environmental 

impact statement, effects thresholds are defined using five categories of significance: 

• No Effect effects would not cause any observable change in natural conditions or impact the 

species being analyzed. 

• Negligible effects may or may not cause observable changes to natural conditions or the 

species being analyzed; regardless, they do not reduce the integrity of a resource. 

• Minor effects cause observable and short-term changes to natural conditions or the species 

being analyzed, but they do not reduce the integrity of a resource. 

• Moderate effects cause observable and short-term changes to natural conditions or kill or 

harm the species being analyzed, and/or they reduce the integrity of a resource. 

• Major effects cause observable and long-term changes to natural conditions and may kill a 

large number of the species being analyzed, and they reduce the integrity of a resource. 

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Site-Specific Invasive Plant Treatments 

Biological Evaluation Process and Summary 

Forest management activities that may alter the habitat for special status species are required to 

undergo review in a Biological Evaluation (FSM 2671.44 and FSM 2670.32) as part of the NEPA 

process. The Biological Evaluation process (FSM 2672.43) is intended to document that proposed 

management actions would not jeopardize the continued existence or cause adverse modification of 

habitat for listed or proposed species, or lead towards the likelihood of Federal listing for sensitive 

species 

The Biological Evaluation is a 4-step process as follows: 

Step 1) Pre-field review to determine if habitat for the species is present. 

Step 2) Field reconnaissance to determine if the species is present. 

Step 3) Risk assessment/analysis of effects for species by alternative. Risk assessment is based 

on evaluation of impacts to habitat (even if the habitat is not known to be occupied), 

individuals (risk from disturbance, actual physical harm to an individual or direct loss of 

habitat in known occupied territories), and population (based on available regional 

information). 

Step 4) A biological investigation if the risk assessment reveals a trend towards federal listing 

(sensitive species only) or consultation with the FWS if a may effect call is made for T, 

E, or P species under the Proposed Action. 

Each PETS species associated with the project area is evaluated based on these steps. Evaluation of 

impacts on a given species may be complete at the end of Step 1 (e.g., if no habitat is present, the risk 

is automatically determined to be none) or may extend through Step 4. If field reconnaissance is not 

undertaken and habitat is available, species occurrence is assumed. 

The FWS may modify a project based upon consultation. In addition, the USDA Forest Service 

provides for modification to any project based on a contract provision that is included in all project 

contracts. This provision provides for the protection of any threatened or endangered species and their 

habitat. 

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Final Environmental Impact Statement 

3.11.3 Direct/Indirect Effects 

The wildlife analysis shows there is little concern for direct or indirect effects from any of the 

proposed treatment methods. The PDC have alleviated any concern for toxic effects of the herbicides 

proposed by this document. When a concern existed a PDC was proposed to reduce or eliminate the 

negative effect. There have been almost no concerns for wildlife related to the other treatment 

methods. Disturbance to nesting birds, which is common to all methods proposed is the most likely 

negative indirect effect that would occur as a result of invasive plant treatments. This would result in 

some loss of reproduction for a small number of ground nesting birds. The list of herbicides being 

analyzed were selected for both their ability to effectively treat target plants and their relative safety 

to humans, terrestrial and aquatic wildlife species and fish. The following discussion focuses on 

“potential exposures.” Exposures to herbicides have a small potential to occur because of PDC. In 

order to be objective, potential herbicides are examined in the unlikely event that there is an 

unintentional exposure. 

The number of acres of potential exposures is estimated for each alternative based on the suite of 

herbicides that could be used. This is addressed for individual species when habitat has been 

delineated, and indicates the number of ways that animals could be exposed to a harmful dose of 

herbicide. “Plausible” includes worst-case scenarios, many of which are very unlikely to actually 

occur. Individual projects conducted are likely to involve small total acreages, or long narrow road 

shoulders. The default value used in aquatic exposure scenarios (e.g., amphibians) is a 10-acre 

treatment area. Herbicide application to larger areas would increase the likelihood of exposure, while 

a small number of acres would reduce likelihood of exposure, compared to the area analyzed in the 

exposure scenarios. The number of acres treated at one time within one project area is likely to 

influence the likelihood of exposure to herbicides for wildlife. 

Indirect mortality is possible from sub-lethal effects that could increase susceptibility to predation. 

Indirect effects to wildlife from cumulative herbicide exposure are also possible. For example, if a 

sub-lethal exposure affects an internal organ and the effect is not quickly reversed, then subsequent 

exposure could cause cumulative damage. All the herbicides in this EIS are excreted rapidly (often 

within 24 to 48 hours), and do not accumulate up the food chain. This reduces, but does not eliminate, 

the potential for these types of cumulative damage to internal organs. 

The herbicides with greatest potential for harm to birds and mammals, in decreasing severity are 

triclopyr, picloram, glyphosate, sulfometuron methyl, and clopyralid. The effects analysis is based on 

using the typical treatment and not the highest rate allowable (See Table 2-7). 

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Site-Specific Invasive Plant Treatments 

The effect to habitat and diversity could be demonstrated by an excerpt from research by Sullivan et 

al. (1998a): “Both indices of shrub diversity, however, were not different over the 5 years. Herbicide 

treatment initially reduced crown volume index of herbaceous vegetation, but values quickly 

recovered to untreated levels by the second year after treatment. Herbaceous species diversity was not 

affected by herbicide treatment. Diversity of small mammal communities apparently was not affected 

by herbicide application. In general, diversity of plant and small mammal communities seemed to be 

maintained, and hence, these treatment sites may not lower overall diversity of a forested landscape” 

(Sullivan et al. 1998). Also, Sullivan field tested the effect of herbicides for snowshoe hares and 

summarized the following: “Herbicide-induced habitat alteration in optimum habitat seemed not to 

affect abundance of snowshoe hares during summer and autumn” (Sullivan 1994). And this was 

further tested for bird species diversity by the following excerpt: “During autumn and winter, more 

birds and more species were found on sites treated with herbicides than on reference sites” (Schulz et 

al, 1992) 

Table 3-38: Summary of project effects to Special Status Wildlife Species. (T=Threatened; 

E=Endangered; S=Sensitive; P=Proposed). 

Species 

Project Effects 

Alternatives 

2 & 3 Reason 

Project 

Effects 

Alternative 1 Reason 

Northern Spotted Owl (T) No effect 

No effect from 

herbicide due PCD 

and minor effect from 

disturbance. 

Minor effect 

No Effect from 

herbicide due to 

PCD and No Effect 

from disturbance. 

Northern Bald Eagle (T) No effect PDC eliminate effects No effect Not in habitat 

Oregon Slender Salamander (S) Minor effect Could travel into 

sprayed areas. Minor effect Could travel into sprayed areas. 

Larch Mountain Salamander (S) No effect PDC eliminate 

spraying in habitat. No effect Not in habitat 

Cope’s Giant Salamander (S) No effect No aquatic effects 

expected due to PDC No effect Not in habitat 

Cascade Torrent Salamander (S) No effect No aquatic effects 

expected due to PDC No effect Not in habitat 

Oregon Spotted Frog (S) No effect No aquatic effects 

expected due to PDC No effect Not in habitat 

Painted Turtle (S) No effect No aquatic effects 

expected due to PDC No effect Not in habitat 

Northwestern Pond Turtle (S) No effect No aquatic effects 

expected due to PDC No effect Not in habitat 

Horned Grebe (S) No effect No aquatic effects 

expected due to PDC No effect Not in habitat 

Red-necked Grebe (S) No effect No aquatic effects 

expected due to PDC No effect Not in habitat 

Bufflehead (S) No effect No aquatic effects 

expected due to PDC No effect Not in habitat 

Harlequin Duck (S) Minor effect Minor effect from 

disturbance No effect Not in habitat 

American Peregrine Falcon (S) Minor effect Minor Disturbance, No 

herbicide Effects No effect Not in habitat 

Gray Flycatcher (S) No effect Specialized habitat. No effect Specialized habitat. 

Black Swift (S) No effect Specialized habitat. No effect Specialized habitat. 

Baird’s Shrew (S) Minor effect Could travel into 

sprayed areas. Minor effect Could travel into 

sprayed areas. 

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Final Environmental Impact Statement 

Species 

Project Effects 

Alternatives 

2 & 3 

Project 

Effects 

Reason Alternative 1 Reason 

Pacific Fringe-tailed Bat (S) No effect 

Not likely to come in 

contact with spray or 

ingest insects 

sprayed. 

Minor effect 

Not likely to come 

in contact with 

spray or ingest 

insects sprayed. 

Pacific Pallid Bat (S) Minor Effect 

Use habitat treated. 

Ingestion of treated 

insects possible. 

Minor Effect 

Use habitat 

treated. Ingestion 

of treated insects 

possible. 

California Wolverine (S) No effect Unlikely to be in areas 

sprayed. No effect Unlikely to be in 

areas sprayed. 

Pacific Fisher (S) No effect Unlikely to be in areas 

sprayed. No effect Unlikely to be in areas sprayed. 

Evening Field Slug (Derocerous 

hesperium) (S) No effect Pre Project Survey No effect Not in habitat 

Crater Lake Tightcoil (Pristiloma 

arcticum crateris) (S) Minor effect 

Method of application 

should reduce 

chances of being in 

contact with herbicides 

No effect Not in habitat 

Dalles Sideband (Monadenia 

fidelis minor) (S) Minor effect Could travel into sprayed areas No effect Could travel into sprayed areas 

Puget Oregonian (Cryptomastix 

devia) (S) Minor effect 

Method of application 

should reduce 

chances of being in 

contact with herbicides 

No effect Not in habitat 

Columbia Oregonian 

(Cryptomastix hendersoni) (S) Minor effect 

Method of application 

should reduce 

chances of being in 

contact with herbicides 

No effect Not in habitat 

Great Gray Owl No effect Not located on the 

Forest or Scenic Area. No effect 

Not located on the 

Forest or Scenic 

Area. 

Oregon Red Tree Vole No effect Forage outside spray 

zone 

No effect Forage outside 

spray zone 

Pileated Woodpecker No effect Specialized Forage No effect Specialized Forage 

American Marten No effect Unlikely to be in areas 

sprayed. No effect Unlikely to be in 

areas sprayed. 

Deer and Elk Minor effect 

Forage on the ground 

along roads 

occasionally 

Minor effect 

Forage on the 

ground along roads 

occasionally 

Hermit Warbler No effect Forage outside spray 

zone 

No effect Forage outside 

spray zone 

Blue Grouse Minor effect 

Forage on the ground 

along roads 

occasionally 

Minor effect 

Forage on the 

ground along roads 

occasionally 

Willow Flycatcher No effect Forage outside spray 

zone 

No effect Forage outside 

spray zone 

Band-tailed pigeon Minor effect 

Forage on the ground 

in openings 

occasionally 

Minor effect 

Forage on the 

ground in openings 

occasionally 

Olive-sided flycatcher No effect Forage outside spray 

zone 

No effect Forage outside 

spray zone 

Rufous Hummingbird No effect Specialized Forage No effect Specialized Forage 

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Site-Specific Invasive Plant Treatments 

Proximity of Species Habitat to Treatment Area 

The level of exposure is key to the effects analysis for the impacts to wildlife. One analysis point that 

is common to all of the alternatives is the proximity of habitat to the treatment areas. The majority of 

the treatments occur in early seral stage habitat. The notable exceptions are knotweed species and 

English ivy, which occur in any age stand. Knotweed species are most often found in riparian areas 

that may contain mature forest. The majority of the TES species and two of the MIS species occur in 

mature forest or aquatic habitats. Most often, these areas would not be receiving treatments. In the 

case of knotweed species and English ivy, the treatments would be implemented in such as way that 

the species would be adequately protected from receiving high exposure to herbicides. English ivy 

would be treated with manual and mechanical treatment methods, and knotweed species would 

receive stem injection or prudent use of foliar spray. Pacific pallid bats, deer and elk are the exception 

to the rule because they are heavy users of early seral habitats especially for foraging. Pallid bats have 

a very limited range in the Forest and Scenic Area, being confined to the drier habitats in the Scenic 

Area. 

Mature forest species are still analyzed because they occasionally pass through early seral habitats to 

get to adjacent stands. During these times they could be exposed to herbicides or forage on prey that 

have been in these areas. The level of exposure should be kept in mind as the species accounts are 

being reviewed. 

Manual, Mechanical, and Cultural Treatment Effects Common to All Alternatives 

There are no adverse effects to habitat from the use of manual, mechanical or cultural treatment to any 

of the species analyzed for any of the alternatives. There is a possible indirect effect of disturbance to 

nesting birds. Some birds would be flushed during the nesting season from personnel that are 

conducting manual, mechanical or cultural treatments. Most of these birds would return to the nest if 

only flushed once or twice because nest fidelity is high. There are a few species where disturbance 

may cause a nest failure for that year. Occasionally, mammals may also be displaced during one of 

these types of treatments. This could result in some young animals wandering away from the 

maternity site during this type of treatment. In some of these scenarios the young may become 

separated from the mother and die as a result. The actual number of times that this would happen is 

impossible to determine, and would vary depending on the species, time of year, and the individual 

animal involved. Treatments later in the year would have less effect on both mammal and avian 

disturbance, and resulting reproductive loss. 

3-185 
Final Environmental Impact Statement 

Alternative 1 – No Action 

Alternative 1 has the least number of acres of herbicide treatments that potentially could expose birds 

or mammals, such as pallid bats, Baird’s shrews, blue grouse, deer and elk that eat insects or 

vegetation to herbicides (Table 2-1). The three herbicides (glyphosate, picloram, and triclopyr) 

permitted in this alternative could result in 1235 acres of herbicide exposure that may, in rare cases, 

exceed the toxicity indices at typical application rates. This alternative, however, utilizes spot 

spraying more than it does broadcast spraying on the majority of treatment sites so this overestimates 

the impacts for this alternative. This is the only alternative that includes dicamba. The Invasive Plant 

FEIS (2005a) demonstrated that although this herbicide us very effective, it has a higher potential to 

exceed LOAELs compared to other herbicides analyzed, including those are included in the Proposed 

Action and Restricted Herbicide Use Alternatives. 

All four herbicides included in this alternative have the potential to have toxic effects for some 

species. The herbicide effects analysis indicated that glyphosate has the greatest potential for harmful 

doses to amphibians. The surfactant found in some glyphosate formulations is particularly toxic to 

aquatic species. Management direction in this alternative, however, severely restricts herbicide use in 

aquatic amphibian habitat, making this scenario less likely to occur. 

Picloram has potential risk to amphibians if it reaches the aquatic resource. Since little research has 

been done on the effects of herbicides on amphibians, fish are used as a surrogate for analysis. PDC 

that limit the distance herbicides may be spray near water features that could contain fish or 

amphibians would reduce this risk. Also, there is a lack of information on the effects to amphibians if 

they are directly sprayed. Terrestrial amphibians regulate moisture by staying hidden most of the day 

under bark, logs, and rocks. This should protect amphibians from being directly sprayed by herbicide 

in most cases. 

There is a risk to small insect eating mammals from ingesting picloram. The Baird’s shrew, a small 

insect eating mammal, is not likely to have habitat that is being treated in this alternative. The Baird’s 

shrews inhabit older forested stands and this alternative treats open disturbed sites. 

Triclopyr has the greatest risk to terrestrial wildlife. Plausible scenarios indicate risk to amphibians, 

deer and elk, migratory birds, and small insect eating mammals. These scenarios are considered worst 

case and the actual results are not expected to occur due to PDC (Section 2.2) that are implemented to 

reduce this risk. Due to the risk to wildlife and fish resources, triclopyr would not be broadcast boom 

sprayed. 

Although the use of herbicides represents potential risks to wildlife, in practice, the management 

direction included in this alternative as well as the environmental conditions and animal behavior 

would tend to minimize actual impacts. Actual adverse effects are therefore not likely to occur. Any 

short-term adverse effects would be largely offset by the long-term benefits of protecting species 

habitat from loss due to invasive plants. 

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Site-Specific Invasive Plant Treatments 

Alternative 2 – Proposed Action 

The Proposed Action rehabilitates the greatest amount of wildlife habitat by eradicating, controlling 

and containing invasive plants. This rehabilitation would return these areas to native vegetation. Many 

of the native plant species are preferred for cover and forage by several species of wildlife such as 

deer, elk, snowshoe hare, and mountain quail, not to mention native butterflies and insects. It is 

expected that removing competing vegetation would improve habitat for these species and others after 

the site is restored. 

Alternative 2 also treats the greatest amount of habitat that bisects or traverses mature forest where 

the potential for exposure of special status species wildlife is increased. By examining the life cycles 

of the special status species it becomes evident that the concern for exposure is minor because these 

species do not use the non-late seral habitats adjacent to their preferred late seral habitats on a regular 

or frequent basis. The amount of habitat adjacent to or bisected by the treatment areas is quantified in 

Table 3-39, Treatment Acre by Alternative and Spotted Owl Habitat Type, under suitable Northern 

Spotted Owl habitat. There are a little over five times as many acres in Alternative 2 near latesuccessional habitat that could include broadcast spraying than in Alternative 1 or 3. This 

demonstrates a greater potential for exposure. 

Most of the species analyzed do not use the early seral habitats that are being rehabilitated so the 

effects to these species both negative and positive are minor. The improvements are greatest for early 

successional species where the invasive plants occur most frequently. Examples of species benefited 

are deer, elk, quail, sparrows, finches, towhees, voles, mice, and weasels. These same species are at a 

higher risk from herbicide, manual, mechanical, and cultural treatment than other species because of 

their use of the target habitats. Herbicides permitted in the Proposed Action include chlorsulfuron, 

clopyralid, glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, sethoxydim, sulfometuron 

methyl, and triclopyr. The effects analysis of herbicide use (Appendix X, Table X-1) indicates that 

there are plausible scenarios that could put focal species at risk from use of clopyralid, glyphosate, 

picloram, sulfometuron methyl, triclopyr and NPE surfactant. Implementing the PDC (Section 2.2) 

reduces the effects to individuals in the treatment area. 

In this alternative, 2,373 acres would be treated annually with triclopyr, glyphosate, picloram, 

clopyralid, and sulfometuron methyl, posing a potential risk to species of wildlife designated as 

sensitive by the Regional Forester on these acres. There is an estimated 12,682 acres that occur in 

habitats used to some degree by wildlife where exposure to herbicides is likely. The acres of exposure 

do not imply that wildlife would necessarily receive toxic dosages, but merely demonstrates a risk. 

PDC and limiting certain herbicides to backpack spot spraying should drastically reduce the actual 

impacts of using the herbicide treatments. 

The Proposed Action represents a more than a five-fold increase in acres of potential exposure 

compared to Alternative 1. However, in relation to the total acres of habitat available for insect and 

vegetation-eating birds and mammals within the project area (1.1 million acres on the Forest and 

39,000 acres on the Scenic Area), and the wide distributions of most of their populations, 13,000 

acres per year represents a negligible risk to wildlife on a Forest scale. 

3-187 
Final Environmental Impact Statement 

All scenarios in this alternative do not approach a dose known to cause any adverse effect. The 

potential for some effects, to occur, however, cannot be ruled out. Potentially harmful scenarios from 

triclopyr are not plausible due to management direction in this alternative restricting use to selective 

application methods (Standard 16, Invasive Plant ROD, 2005b). Triclopyr scenarios are therefore not 

expected to occur. All other bird and mammal scenarios in this alternative exceed only the NOAEL 

and do not approach a dose known to cause any adverse effect (LOAEL). Nevertheless, the potential 

for some effects to occur cannot be ruled out. 

High application rates of glyphosate with surfactant could be lethal to amphibians, as discussed in 

Alternative 1. Management direction in this alternative requires the consideration of appropriate 

formulations and application method to reduce or eliminate negative effects to aquatic biota, so this 

effect is not likely to occur. 

The EDRR is designed to be aggressive in the control of invasive plants. This is necessary to ensure 

success in managing and controlling the spread of these highly competitive and easily established 

plants. By allowing the treatment of 13,000 acres each year this adds additional risk factors to wildlife 

just by adding additional exposure scenarios. This also expands the treatment into areas that may not 

have been originally anticipated; however, the new sites could likely be in the same vicinity of current 

treatment areas as the current invasive plants spread. The risk factors do not change and the PDC 

(Section 2.2) would still reduce the effects to little or no impacts to wildlife species. 

Similar to Alternative 1, the management direction included in this alternative as well as the 

environmental conditions and animal behavior would tend to minimize actual impacts. At the project 

scale, choices could be made to avoid situations that could cause harm to wildlife. For example, 

certain herbicides could be avoided in specific areas or times of the year where/when grass-eaters or 

amphibians may be at risk, or more specific application methods could be used. Actual adverse effects 

are therefore not likely to occur. Any short-term adverse effects would be largely offset by the longterm benefits to these species from protecting their habitat from loss due to invasive plants. 

Alternative 3 – Restricted Herbicide Use Alternative 

Alternative 3 would treat the same 13,000 acres of invasive plant infestations that are treated in the 

Proposed Action. The difference between Alternative 2 and Alternative 3 is the amount of herbicide 

that would be used in these two alternatives. In the EDRR for Alternative 2 the treatments would be 

primarily with herbicides, and in Alternative 3 treatments would be mostly manual and mechanical. 

In Alternative 3, 2028 acres of broadcast boom spraying occurs, whereas the Proposed Action 

(Alternative 2) would treat 12,214 acres with a broadcast boom sprayer. This is mentioned because 

broadcast boom spraying although more efficient at treating invasive plants is the most likely to spray 

herbicides on plants that would be eaten by wildlife and indirectly spray insects and small less mobile 

wildlife species such as newts and salamanders. Of the 2028 acres that would be sprayed by 

broadcast boom sprayer only 507 acres of this is in or adjacent to mature forest that would be 

considered suitable Northern Spotted Owl habitat and where potential special status species might be 

present in these adjacent stands. 

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Site-Specific Invasive Plant Treatments 

The biggest difference in the effect of this alternative compared to the Proposed Action is the 

effectiveness of the treatment. Manual, mechanical and cultural treatments have been attempted in the 

past as the sole way to control invasive plants and the effect has been met with very minor successes 

(See Section 3.6 – Botany and Treatment Effectiveness). This alternative still puts the species that 

rely on the early successional habitat at more risk from habitat loss, compared to the risk that a few 

individuals could receive a toxic dose of an herbicide treatment. 

The EDRR for Alternative 3 would still be 13,000 acres potentially per year but the treatments would 

not include herbicides except for the high priority areas. This eliminates any concern for toxic effects 

to wildlife and aquatic organisms. Manual, mechanical and cultural treatments are not really a 

concern for wildlife unless they disrupt nesting or reproduction. 

Alternative Comparison 

Alternative 2 also has the greatest benefit to wildlife habitat by reducing or eliminating invasive 

species on approximately 13,000 acres of the Forest and Scenic Area. The results of the analysis, 

however, indicate that Alternative 2 poses the highest exposure potential to wildlife from herbicides. 

It includes the greatest number of acres of treatment that are adjacent or bisect late-successional 

forest. Under Alternative 2, approximately 12,682 acres1

 are projected for treatment with herbicides 

where estimated doses could potentially expose wildlife to herbicides. Potential exposure to TES 

species occur on 2,373 acres.2 Most of these acres would not be suitable habitat for the TES species 

that could be affected. Additionally, PDC would reduce the risk of exposure. 

Alternative 3 includes 4,047 acres of treatment that could potentially expose birds, amphibians, and 

mammals that eat vegetation or insects to herbicides. Potential herbicide exposure of special status 

species occur on 506 acres.3

In contrast, Alternative 1 poses the lowest potential exposure risk to wildlife from herbicides. Under 

Alternative 1, two hundred thirty five acres would be treated with herbicides where some potential 

exist for exposure of special status species. 

These differences seem substantial, however in practice, the management direction included in all 

alternatives (including the No Action Alternative) as well as the environmental conditions and animal 

behavior would tend to minimize actual impacts. At the project scale, choices could be made to avoid 

scenarios that could cause harm to wildlife. For example, certain herbicides could be avoided in 

specific areas or times of the year, where/when grass-eaters or amphibians may be at risk. 

 

1

 Quarries and administrative sites that have no potential to affect wildlife populations due to low amounts of habitat are 

not considered as plausible scenarios that could affect sensitive or MIS species. 

2

 These acres are based on the acres of suitable Northern Spotted Owl habitat, since the sensitive species potentially 

affected would also utilize mature stands for habitat. 

3

 These acres are based on the acres of suitable Northern Spotted Owl habitat, since the sensitive species potentially 

affected would also utilize mature stands for habitat. 

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Final Environmental Impact Statement 

During analysis for possible impacts to threatened or endangered species, the analysis indicated that 

the risk of ingesting or absorbing herbicides from treatments was negligible. The proximity of 

invasive plant treatments and the noise created from mechanized methodologies could cause some 

disturbance to bald eagles based on current standards for disruption and disturbance distances. If 

implementation of new treatment sites, under EDRR, are close to new or unknown nest sites. A 

seasonal restriction in treatment areas within a quarter mile of a bald eagle nest site would be 

implemented when nests are located (PDC H.1). Early analysis indicated a possible need for 

protection of Northern Spotted Owls from disturbance. A test of spray equipment was initiated to 

determine the amount of noise created by the spray truck and equipment. Noise level measurements 

of spray equipment indicate that although noise levels could be detected and elicit an alert response 

from the owls, the noise level would be below what is currently considered to be disruptive to 

breeding and feeding activities. The sound level measurement of a truck mounted boom sprayer was 

64 decibels and is below the threshold for disturbance. All other sounds from other treatment methods 

are less than that of a truck mounted boom sprayer. Therefore there are no effects from disturbance 

from invasive plant treatments. 

3.11.4 Cumulative Effects 

Herbicide use occurs on lands other than the Forest and Scenic Area. Herbicide use occurs on other 

federal, state, and county ownerships, state and private forestry lands, rangeland, utility corridors, 

road rights of way, agricultural lands and private residences. Herbicide use on Pacific Northwest 

National Forests could contribute to some cumulative effects, but data is lacking that would permit 

any quantitative estimates of cumulative exposure or risk. 

Since much wildlife move and migrate, they could be exposed to herbicides on adjacent lands or 

along their migration routes. Species could be exposed to the same herbicide on multiple ownerships, 

or a combination of different herbicides. Wildlife could also be exposed to other chemicals, such as 

insecticides, rodenticides, fungicides, and others. This project does not include the use of any other 

types of chemicals, but the herbicide triclopyr and the insecticide chlorpyrifos share a common 

metabolite, TCP, which is toxic to aquatic organisms. Thus, the use of triclopyr could add to TCP 

exposure resulting from the use of chlorpyrifos. Another example of a potential cumulative effect is 

from hexachlorobenzene, a ubiquitous industrial pollutant, which is found in both picloram and 

clopyralid. While the amounts of hexachlorobenzene added to the environment from USDA Forest 

Service use of picloram and clopyralid do not represent a substantial addition in comparison to 

existing background levels (SERA, 2003b, 2004b), it could be considered a cumulative effect. 

The Invasive Plants FEIS (2005a) has addressed the cumulative effects for the Oregon and 

Washington region. The conclusion of the Invasive Plant FEIS (2005a) was that a three percent 

increase in land treated with herbicides, spread across the two state project area would not 

significantly increase potential adverse effects to wildlife. Additive effects from herbicide exposure 

are not likely to occur, or would be minimal, because herbicides considered in this EIS do not 

accumulate in the body, nor concentrate up the food chain (See SERA Risk Assessments, 2001b, 

2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f). Adverse effects that do occur 

would only occur to a few individual animals, and would not result in any important effects to any 

species populations. 

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Site-Specific Invasive Plant Treatments 

The small contribution that USDA Forest Service use of herbicide for invasive plant treatment makes 

to the statewide totals for herbicide use indicate that the potential cumulative effect on a regional 

scale is very small. Likewise, the relatively small differences between the alternatives, in comparison 

to the totals, make insignificant any differences between the alternatives in potential for cumulative 

effects to wildlife. 

3.11.5 Species Specific Discussions 

A full discussion of the direct, indirect, habitat, disturbance, and cumulative effects to threatened or 

endangered species are included in this section. 

Only a summary of the effects of invasive plant treatment and analysis for all non-threatened or 

endangered species is included here. Appendix X – Effects of Wildlife Species includes a more 

detailed analysis of the species habitat, lifecycle information, and in-depth discussion of the effects of 

the various treatments and alternatives for these species. 

3.11.5.1 General Overview of Herbicide Analysis by Species 

This analysis is the potential effects prior to implementing the standards and guidelines from the 

Invasive Plant ROD (2005b) and the PDC (Section 2.2). The analysis is based on exposure scenario 

results from the SERA risk assessments for mammals, birds, and honeybees using the typical 

application rate. The effects analysis is those effects that could be expected to exceed toxicity index 

based on the information outlined in Appendix P of the Invasive Plant FEIS (2005a). The anticipated 

effects are extrapolated results based on the scenarios used for particular taxonomic groups and may 

be different from actual toxicity of a particular species. Worst-case for both acute and chronic 

exposures are combined if it is anticipated that both scenarios would apply to the species analyzed. 

For species that are mobile and have large home ranges only the acute scenarios are applied, because 

these species would not be in an area long enough to receive chronic exposure to the herbicides. 

Effects determinations for the purpose of NEPA analysis are made on the effects to individuals and 

populations for Threatened and Endangered species, but only on the population basis for migratory 

birds, sensitive, and MIS. 

Basic assumptions for wildlife species analysis: 

• Aquatic organisms such as aquatic salamanders would have the same sensitivity to herbicides 

as fish. 

• Small insectivorous birds that defend territories may feed in the same area and are subject to 

chronic exposures. Exposures to herbicides by the three Partners in Flight watch listed 

insectivorous migratory birds, however, is probably low since these species forage higher in 

the canopy and forage mostly on insects above the spray zone. These species may occasionally 

eat species from the ground or that fly into the canopy but this incidence of exposure would be 

low. Other land birds may forage lower and could be subjected to higher levels of exposure. 

• Grouse may return to the same areas to feed on a regular basis, especially if the food supply is 

close to a breeding display area. As a result, chronic exposures may occur. 

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Final Environmental Impact Statement 

• Bats feed over a large enough area to not be subjected to chronic exposures. 

• Mustelids travel widely and would not be in the same area long enough to be subjected to 

chronic exposures. 

• Northern Spotted Owls and peregrine falcons forage over a large territory and would not be 

subjected to chronic exposures. 

• Aquatic birds that forage on fish or macro invertebrates would not find a concentration of 

herbicides in the water high enough to be exposed at levels that could get toxic. 

• Woodpeckers and hummingbirds would not be exposed to herbicide because of their feeding 

methods. Their food sources are protected. Since the beetles and ants that the woodpeckers 

feed on are buried inside of decaying wood, and since the nectar of flowers is inside the 

“throat” of the flower which is formed by the elongated petals, the food source of these two 

groups of birds is not likely to be contaminated by spraying herbicides. 

• Deer and Elk would occasionally feed in the same area for multiple days leading to chronic 

exposures. 

• The impacts to mollusk may be greater than depicted in the table based their skin may absorb 

herbicides more than the invertebrates that were used in the analysis. The likelihood of the 

sensitive mollusk being in the areas targeted for spraying, however, is extremely low based on 

habitat types. 

3.11.5.2 Northern Spotted Owl (Strix occidentalis caurina): Threatened 

A. Habitat 

Old growth coniferous forest is the preferred nesting, roosting and foraging habitat of spotted 

Northern Spotted Owls in Oregon. Old growth habitat components that are typical for Northern 

Spotted Owls are: Multilayered canopies, closed canopies, large diameter trees, abundance of dead or 

defective standing trees, and abundance of dead and down woody material. The following describes 

Northern Spotted Owl habitat as defined in the Programmatic Biological Assessment for Projects with 

the Potential to Modify the Habitats of Northern Spotted Owls and/or Bald Eagles or Modify Critical 

Habitat of the Northern Spotted Owl, Willamette Province, FY 2005-2006 (Reference). 

• Suitable habitat for the Northern Spotted Owls consists of habitat used by owls for nesting, 

roosting and foraging (NRF). Generally this habitat is 80 years of age or older, multi-storied 

and has sufficient snags and down wood to provide opportunities for nesting, roosting and 

foraging. The canopy closure generally exceeds 60 percent. A wildlife biologist makes sitespecific determinations and delineations of suitable habitat. 

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Site-Specific Invasive Plant Treatments 

• Dispersal habitat for the Northern Spotted Owls generally consists of mid-seral stage stands 

between 40 and 80 years of age with canopy closures of 40 percent or greater and an average 

dbh of 11 inches. Spotted owls use dispersal habitat to move between blocks of suitable 

habitat; juveniles use it to disperse from natal territories. Dispersal habitat may have roosting 

and foraging components, enabling Northern Spotted Owls to survive, but the habitat lacks 

structure suitable for nesting. A wildlife biologist makes site-specific determinations and 

delineations of dispersal habitat. 

• Critical Habitat Units (CHU): Designation of critical habitat serves to identify lands that are 

considered essential for the conservation and recovery of listed species. The functional value 

of critical habitat is to preserve options for the species eventual recovery. The Service’s 

primary objective in designating critical habitat was to identify existing Northern Spotted Owl 

habitat and highlight specific areas where management considerations or protections should be 

given highest priority. CHU were distributed in a manner that would facilitate demographic 

interchange. 

Since the designation of Northern Spotted Owl critical habitat in 1992, the Northwest Forest Plan 

(USDA & USDI 1994a) developed as a conservation strategy for all late-successional forest species, 

including the Northern Spotted Owl. Like critical habitat, the Northwest Forest Plan (USDA Forest 

Service and USDI BLM, 1994) was based on the work of the Interagency Science Committee. In 

addition, the Northwest Forest Plan incorporated recommendations from the Northern Spotted Owl 

recovery team and addressed the needs of other late-successional forest-associated species. 

Primary Constituent Elements 

Primary constituent elements are environmental factors the FWS determines are essential to a species’ 

conservation. For the Northern Spotted Owl the primary constituent elements of critical habitat have 

been identified as the physical and biological features that support nesting, roosting, foraging, and 

dispersal (USDI, 1992a). 

Current Information 

In 2004, the FWS initiated a 5-year review of the Northern Spotted Owl, Scientific evaluation of the 

status of the Northern Spotted Owl (Courtney et al., 2004). The review collates and analyzes the 

recent body of knowledge related to the Northern Spotted Owl since it was listed as a threatened 

species in 1990. The review includes a summary of current threats to the Northern Spotted Owl, 

including the barred owl, West Nile virus, habitat modification, and forest management challenges 

associated within the existing legal framework. Also included in the 5-year review is a report entitled, 

Status and Trends in Demography of Northern Spotted Owls, 1985-2003 (Anthony et al., 2004). 

The information in Coutney et al. (2004) and Anthony et al. (2004) was reviewed by Alan Dyck, 

Forest Wildlife Biologist for the Forest. The results of the 5-year review do not alter how the Forest 

Wildlife Biologist determines the effects to the Northern Spotted Owl or its habitat. This project was 

also reviewed for consistency with the Northwest Forest Plan (USDA Forest Service and USDI BLM, 

1994). As a result of the review, the effects to the habitat and the owl has not changed and the 

information in Courtney et al. (2004) does not alter the effects determination made for the treatment 

of invasive plants. 

3-193 
Final Environmental Impact Statement 

B. Pre-Field Review 

Habitat Available Within the Project Area 

Yes. The Proposed Action (Alternative 2) has approximately 2373 acres of the treatment areas that 

are either adjacent to or bisect suitable Northern Spotted Owl habitat. Also, there are approximately 

2976 treatment acres of dispersal habitat. Of these acres, 2175 acres that would receive broadcast 

boom spray treatments in/or adjacent to suitable habitat (Table 3-39). Approximately 2582 treatment 

acres are in or adjacent to Northern Spotted Owl critical habitat and 2068 acres are in Late 

Successional Reserve (LSR). LSR are a Northwest Forest Plan land allocation: this land allocation is 

managed to protect and enhance conditions of forest ecosystems, which serve as habitat for latesuccessional and old-growth related species, including the Northern Spotted Owl. 

Disturbance Noise Levels from Invasive Plant Treatments 

To determine if sound level disturbance would impact Northern Spotted Owls, a sound level reading 

was made on the truck and spray pump used by Hood River County. Two distances were measured 

for sound levels on a dirt parking area on a cold clear morning at 10 yards and 35 yards. At 10 yards, 

the decibel reading was 72 decibels and at 35 yards it was 64 decibels. In a white paper for the FWS, 

Kent Livesey analyzed the research on Northern Spotted Owl disturbance factors (BA 2003). In the 

document Livesey states, “...we estimated these sound-only levels to be: 40 dB for the ambient sound 

level; 44 dB for the detect threshold; 57 dB for the alert threshold; 70 dB for the disturbance 

threshold; and 92 for the injury threshold.” The Willamette Province Level One Team has interpreted 

this information and assigned a threshold for disturbance effects calls. When the sound levels reach 

the disturbance threshold 70 decibels, the effect determination is May Affect, Not Likely to Adversely 

Affect Northern Spotted Owls when the sound level reaches 92 decibels and above, the effect 

determination is May Affect, Likely to Adversely Affect Northern Spotted Owls. If sound levels are 

below 70 decibels, there is no effect anticipated. These effect determinations are reflected in the 

distance charts that are located in the Programmatic Biological Assessment (Reference). 

C. Field Reconnaissance 

A Level A survey was conducted for the project area in addition to examining some habitat during 

field reconnaissance. There is a high potential for species presence in some locations based on current 

field reconnaissance, GIS (Geographic Information System) analysis, and on historic data. 

D. Analysis of Direct and Indirect Effects 

Alternative 1 – No Action 

Effects to the owl would be limited to the existing planned invasive plant treatments. The habitat 

would continue to function as Northern Spotted Owl suitable or dispersal habitat. The effects analysis 

indicates that there would be no toxic effects to Northern Spotted Owls from the use of herbicides on 

the 450 acres of treatment on the Forest and 150 acres on the Scenic Area. 

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Site-Specific Invasive Plant Treatments 

The indirect effect of noise and disturbance would be negligible due to the very small area of suitable 

habitat and low noise created by mechanical and sprayers in the project area. Sound level readings of 

spray equipment indicate that sound levels were below the harm level at less than 35 yards and would 

be near ambient at the distance any owl would be nesting from the treatment areas. Manual and 

mechanical treatment would result in less noise than the use of broadcast boom spraying. There is no 

effect to Northern Spotted Owls from disturbance. The majority of the invasive plant treatments that 

would create noise occur along roads and openings. The Fish and Wildlife Service has indicated in the 

Biological Opinion for the Fiscal Year 2006 to 2007 May Affect, Likely to Adversely Affect (LAA) 

Disturbance activities, Willamette Planning Province Owls that Northern Spotted Owls rarely nest at or 

immediately adjacent to road or edges (Kerns et al. 1992, Perkins 2000). These effects are analyzed in 

the Biological Opinion for Effects to Northern Spotted Owls (Strix occidentalis caurina) from the 

Willamette Planning Province Fiscal Year 2006 – 2007 (FY06-07)activities that have the potential to 

adversely affect, due to disturbance, on U.S. Department of the Interior; Bureau of Land Management, 

Eugene District and Salem District, and the U.S. Department of Agriculture; Mt. Hood National Forest, 

Willamette National Forest and the Columbia River Gorge National Scenic Area (FWS Reference 

Number 1-7-05-F-0663). Implementation of this project would have no impact to habitat connectivity 

cells. There are no negative effects to habitat. The effects determination of invasive plant treatment 

on Northern Spotted Owls is No Effect to Northern Spotted Owls or their habitat. There are no 

effects to Critical Habitat since there are no changes to the primary constituent elements.

Alternative 2 – Proposed Action 

The Proposed Action would bisect or be adjacent to Northern Spotted Owl suitable, dispersal, critical 

habitat and LSR. The treatment areas are in habitats (mostly roads or openings) that cross or are within 

a GIS polygon designated as one of the categories of Northern Spotted Owl habitat. The breakdown of 

treatment acres in or adjacent to Northern Spotted Owl habitat is as follows: 2373 acres Northern 

Spotted Owl suitable habitat, 2976 acres dispersal habitat, 2582 critical habitat, and 2068 acres are in 

or adjacent to LSR. Approximately 18 percent of the proposed treatment areas would be in or adjacent 

to suitable Northern Spotted Owl habitat. The Proposed Action is to treat 2175 acres of areas in or 

adjacent to suitable habitat by broadcast boom spraying with a broadcast boom spray truck. There 

would be no impact to any of the primary constituent elements of Northern Spotted Owl habitat. The 

benefit to the habitat would be eliminating invasive plants that would otherwise out compete native 

vegetation which principle prey species use for foraging. The indirect effect of noise and disturbance 

would be negligible due to the very small area of suitable habitat and low noise created by mechanical 

and sprayers in the project area. Sound level readings of spray equipment indicate that sound levels 

were below the harm level at less than 35 yards and would be near ambient at the distance any owl 

would be nesting from the treatment areas. There is no effect to Northern Spotted Owls from 

disturbance. The majority of the invasive plant treatments that would create noise occur along roads 

and openings. The Fish and Wildlife Service has indicated in the Biological Opinion for the FY06-07 

LAA Disturbance activities, Willamette Planning Province Owls that Northern Spotted Owls rarely 

nest at or immediately adjacent to road or edges (Kerns et al. 1992, Perkins 2000). Implementation of 

this project would have no impact to habitat connectivity cells. There are no negative effects to habitat. 

The effects determination of invasive plant treatment on Northern Spotted Owls is No Effect to 

Northern Spotted Owls or their habitat. There are no effects to Critical Habitat since there are no 

changes to the primary constituent elements. The effects determination for Critical Habitat is No 

Effect.

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Final Environmental Impact Statement 

Table 3-39: Treatment Acre by Alternative and Spotted Owl Habitat Type. 

Treatment Acres Bisecting or Adjacent 

Habitat Type or Treatment Alternative 1 Alternative 2 Alternative 3 

Suitable habitat <1,235 2,373 2,373 

Broadcast Boom spraying in suitable habitat <415 2,175 507 

Dispersal habitat <1,235 2,976 2,976 

Critical Habitat <1,235 2,582 2,582 

Broadcast Boom spraying in Critical Habitat <415 2,222 548 

Manual and/or mechanical treatment only 635 83 10,417 

Alternative 3 – Restricted Herbicide Use Alternative 

Distribution of habitat types adjacent to the treatment areas is the same as Alternative 2. From the 

table above it is clear that the difference in the alternatives is the amount of area that would be 

sprayed with a broadcast boom sprayer. There would only be 507 treatment acres adjacent to suitable 

habitat sprayed by broadcast boom sprayer in this alternative. Both the toxic effect analysis and the 

analysis for disturbance show a negligible effect of the treatment on Northern Spotted Owl survival or 

recruitment and no effect to their habitat. The effects determination of invasive plant treatment on 

Northern Spotted Owls is No Effect. 

• Effects to NRF and Dispersal Habitat on a Local and Watershed Scale: There are no effects to 

the primary constituent elements of NRF (suitable) or dispersal habitat. There would be no 

changes in the age or structure, understory layer, down logs, or snag habitat. There may be 

improvements in forage for prey species in some situations. The removal of invasive plant 

species may improve prey habitat and contribute to improved prey conditions. 

• Effects to Critical Habitat: This project occurs adjacent to and in 2582 acres of critical 

Northern Spotted Owl habitat. No components in the Proposed Action or Restricted Herbicide 

Use Alternatives including herbicide, manual, mechanical, and cultural treatments would 

affect the ability of critical habitat to aide the recovery of the Northern Spotted Owl. There are 

no changes to the primary constituent elements of the habitat by any of the treatment methods. 

The effects determination for Critical Habitat is No Effect. 

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Site-Specific Invasive Plant Treatments 

• Effects to Northern Spotted Owl on a province scale (Willamette Province): The FWS issued 

an opinion on the effects noise disturbance of the herbicide treatments in the programmatic 

biological assessment titled, Programmatic Biological Assessment for Activities with the 

Potential to Disturb Northern Spotted Owls and/or Bald Eagles in the Willamette Province 

FY2006-2007.” The conclusion reached is the following: “After reviewing the current status 

of the bald eagle and Northern Spotted Owl, including critical habitat, the environmental 

baseline for both species, the effects of the Proposed Action, and the cumulative effects, it is 

the Service’s biological opinion that the FY 2005-2006 Habitat Modification Projects in the 

Willamette Province are not likely to jeopardize the continued existence of the bald eagle or 

Northern Spotted Owl and is not likely to destroy or adversely modify designated critical 

habitat for the Northern Spotted Owl” (USDI, 2005). The acres contained in the programmatic 

biological assessment were for the effects of the projects in treatment areas covered in 

Alternative 1. After taking noise level readings of herbicide spray equipment that would be 

used to treat invasive plants in the project area, it is clear that sound levels are below the 

disturbance threshold established by the Level One Team; therefore, there is no need for 

further consultation for disturbance to this species for invasive plant treatment from herbicide 

spraying. The sound levels generated by other manual and mechanical treatments also are 

considered below the disturbance threshold. 

• Effects to Northern Spotted Owl on the entire range of the species (Washington, Oregon, and 

California): The Record of Decision for Amendments to USDA Forest Service and USDI 

Bureau of Land Management Project Documents within the Range of the Northern Spotted 

Owl established a system of land allocations and a set of standards and guidelines that is 

considered to be consistent with maintaining viability for the Northern Spotted Owl across its 

range (USDA Forest Service and USDI BLM 1994). This EIS meets all the Standards and 

Guidelines set forth within this decision document. 

Early Detection/Rapid Response Strategy 

This provision creates the possibility of invasive plant treatment outside of the original mapped 

treatment areas. Expanding the area of treatment would have no effect on habitat, exposure to 

herbicide, or disturbance of Northern Spotted Owls. The actions created by the treatments pose no 

risk to Northern Spotted Owl survival or reproduction. 

3-197 
Final Environmental Impact Statement 

Cumulative Effects 

Currently, the only foreseeable future actions on USDA Forest Service lands within the watersheds 

that might be considered cumulative herbicide use and invasive plant treatments to the Proposed 

Action are those projects already approved and listed in the No Action Alternative and the EDRR. 

There would continue to be management activity within these watersheds that have the potential to 

adversely impact Northern Spotted Owl individuals due to disturbance. These types of projects would 

continue to be consulted on with the FWS. There are no actions outside of USDA Forest Service 

lands that become a cumulative effect for Northern Spotted Owls because there is no impact to 

Northern Spotted Owl habitat, the effect of noise is local and would not be considered cumulative and 

the herbicides used do not bioaccumulate. The possibility that there could be 13,000 acres of 

treatment per year with EDRR does not alter the determination of effects to the habitat or herbicide 

effects on the owl. The analysis of spray equipment noise levels and the type of equipment being used 

for cultural, manual and mechanical treatment has eliminated the concern for disturbance to Northern 

Spotted Owl nesting, foraging, or reproductive success. 

E. Project Design Criteria 

PDC or seasonal restrictions are proposed for the treatment of invasive plants in suitable habitat in the 

LSR and Congressionally Withdrawn land allocations. These restrictions would only be applied to 

areas of suitable habitat in these land allocations. There are 48 treatment sites in LSR totaling 

approximately 2068 acres for the Proposed Action. Of these sites there are 1058 acres that are suitable 

Northern Spotted Owl habitat. Treatment of invasive plants must occur during the critical breeding 

season for Northern Spotted Owls, but the noise levels produced by the treatment methods would not 

reach the level of harm. As a result, there is no need for further mitigation. 

F. Communication with U.S. Fish & Wildlife Service 

The Northern Spotted Owl was listed as threatened throughout its range under the ESA (55 CFR 

26114) on June 22, 1990. Any action that would result in a beneficial effect or could result in an 

adverse impact to the Northern Spotted Owl would result in a may effect determination and would 

require consultation with the FWS. 

Consultation with the FWS was initiated on for the treatment of invasive species in two separate 

consultation avenues. Disturbance effects of invasive plant treatments were analyzed and consulted on 

in the Programmatic Biological Assessment for Activities with the Potential to Disturb Northern 

Spotted Owls and/or Bald Eagles in the Willamette Province FY2006-2007 (Reference) and the 

Willamette Province Level One Team was given a presentation on the effects analysis and subsequent 

determination made on the effects to the Northern Spotted Owl and its habitat from the treatment of 

these invasive plants. The Level One Team was informed that the Forest and Scenic Area had 

determined that the effect from the use of herbicide, manual, mechanical, and cultural treatment of 

invasive plants was no effect to the Northern Spotted Owl or its habitat. The team was reminded that 

the disturbance effects had been analyzed in the Programmatic Biological Assessment. There was 

only one comment from the Level One Team on the use of herbicides: the comment was related to the 

use of picloram and its effects to fish through impacts to their food source. The comment was 

forwarded to the fisheries biological on the interdisciplinary team. The Level One Team made no 

comments on the effects determination. 

3-198
Site-Specific Invasive Plant Treatments 

A letter was sent to the U.S. Fish and Wildlife Service on August 29, 2006 amending the Biological 

Assessment to reflect effects determinations based on project alternatives information. 

3.11.5.3 Northern Bald Eagle (Haliaeetus leucocephalus): Threatened 

A. Habitat 

The bald eagle is a permanent resident in Oregon. Their nests are usually located in multi-storied 

stands with old-growth components, and are near water bodies that support an adequate food supply. 

Nests, which usually consist of a bulky platform of sticks, are usually located in the super-canopy of 

trees or on a cliff. Nest sites are usually within one-quarter mile of water in the Cascades. 

Adequate forage sources are possibly the most critical component of bald eagle breeding and 

wintering habitat. Fish, waterfowl, rabbits, and various types of carrion comprise the most common 

food sources for eagles in the Pacific Recovery Plan area. Wintering bald eagles perch on a variety of 

substrates, proximity to a food source being the most important factor influencing perch selection. 

Eagles tend to use the highest perch sites available that provides a good view of the surrounding area. 

Communal roosts are invariably near a rich food source and in forest stands that are multi-storied and 

have at least a remnant old growth component. 

B. Pre-Field Review 

Habitat Available Within the Project Area 

Yes. There are five areas outlined on the Forest and Scenic Area that are designated as part of the 

Bald Eagle recovery area. Two of these areas have eagles nesting in them. Two of the other areas do 

have eagles utilizing them throughout the year and may have undocumented nesting. All of the areas 

do have some invasive treatments planned (Sites #). There are three areas designated as bald eagle 

habitat areas (A13) in the Forest Plan which have proposed treatments. The habitat could be utilized 

as nesting, roosting, or perching habitat for the bald eagle. 

C. Field Reconnaissance 

A Level A survey was conducted. There is some potential for this species to inhabit the project area. 

Birds are nesting in the Timothy Lake and Clear Lake Areas as well as Rock Creek Reservoir, just off 

the Doewar. No communal roost areas are known for the Forest. There has been consistent use by 

adults in two areas of the Forest and nesting occurs within a half mile of some of the roadside 

treatment areas. 

D. Analysis of Direct and Indirect Effects 

Effects Common to All Alternatives 

No effect to the bald eagles would occur from ingesting or contacting herbicides. The effects analysis 

(Appendix X, Table X-3) showed no anticipated toxic effects to bald eagle. The concentrations of 

herbicides from invasive plant treatment would not be elevated to a point where there would be any 

observable effect to eagles. 

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Final Environmental Impact Statement 

Alternative 1 – No Action 

This alternative includes some pre-existing invasive plant treatments, including herbicide, manual, 

and mechanical treatment methods. There are three roadside treatment areas (Sites #) that are within a 

half-mile, but over one-quarter mile of a previously occupied bald eagle nest near Rock Creek 

Reservoir. These areas are outside the disturbance distance of the bald eagle nest. The nest was not 

occupied in 2005 but was successful in fledging young the previous year (Thurman, 2005). Due to of 

the proximity to the treatment areas, it is possible that people working in the treatment area could 

potentially create nest site disturbance. It is unlikely, however, given the nest was established in the 

proximity to the roads being proposed for treatment. There is already a fair amount of recreation at 

the lake near the nest site and the invasive plant treatments could potentially add to this disturbance. 

It is more likely that the nest is hidden from the road well enough to not be impacted by the 

treatments. The effect determination is No Effect to bald eagles or their habitat. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

• Effects to Habitat: Bald eagles usually nest within one-quarter mile of a water body in the 

Cascades. Eagles utilize large trees with platform nest. Diets vary with location and food 

availability. Eagles on the Forest primarily forage on fish although it is possible for them to 

eat carrion and dead or injured waterfowl on the lakes. 

There are three proposed treatment sites (Sites #) that are in mapped bald eagle habitat that 

was identified as part of the Forest Plan. There are 369 acres of treatment area that are 

adjacent to or within these bald eagle habitat areas (A13) land allocations. 

The primary constituent elements of bald eagle habitat include nest trees within a quarter mile 

of a water body and large trees for nesting and roosting. There are no treatments that would 

affect the availability of these habitat elements. 

• Effects to Individuals: There are two nest sites (thought to be alternates for the same pair) in 

the Clear Lake and Timothy Lake area (Sites #). These nest sites have produced young in the 

past (Isaacs, Frank B. and Robert G Anthony, March 2006). The distance from treatment areas 

to the nest sites is slightly over six tenths of mile for the nearest roadside treatment area. This 

distance is outside the disturbance distance for bald eagles. The effect determination is NO 

Effect to bald eagles or their habitat. 

• Effects to Population: None expected since no effects to individuals and no effects to habitat 

occurring with project implementation. 

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Site-Specific Invasive Plant Treatments 

Early Detection/Rapid Response Strategy 

This provision creates the possibility of invasive plant treatment outside of the original mapped 

treatment areas. Expanding the area of treatment would have no effect on habitat or from exposure to 

herbicide. There is a possibility of treatment areas moving closer to a nest tree and within the 

disturbance zone of eagles. If the treatment area expands into the area within a quarter mile of a bald 

eagle or one half mile line of sight it would be necessary to adhere to a seasonal restriction outlined in 

the PDC H.1. or re-consult with the Fish and Wildlife Service. 

Cumulative Effects 

No cumulative effects for the treatment of invasive plants from herbicide, manual, mechanical or 

cultural treatments or the EDRR. 

E. Project Design Criteria 

None. 

F. Communication with U.S. Fish & Wildlife Service 

The northern bald eagle is listed as threatened throughout its range under the ESA (55 CFR 26114) on 

June 22, 1990. Any action that would result in a beneficial effect or could result in an adverse impact 

to the bald eagle would result in a may effect determination and would require consultation with the 

FWS. 

Consultation with the U.S. Fish and Wildlife Service was initiated for invasive plant treatment in July 

of 2005 through the document titled “Programmatic Biological Assessment for Activities with the 

Potential to Disturb Northern Spotted Owls and/or Bald Eagles in the Willamette Province FY2006-

2007.” There were no effects to bald eagle from invasive plant treatment that were determined and 

therefore the Fish and Wildlife Service Biological Opinion did not list any terms or conditions March 

2005. 

3.11.5.4 Canada Lynx (Lynx Canadensis): Threatened 

A. Habitat 

In the Pacific Northwest, lynx are associated with high elevation, boreal forests that typify northern 

latitudes. They are found primarily above 4000 feet in Washington. Although scarce in Oregon, lynx 

range and habitat in Oregon and Washington is unclear. High quality lynx habitat is comprised of a 

mosaic of early successional forests with high prey densities (especially snowshoe hare) for foraging, 

and of late-successional forests with an accumulation of down logs used for denning, thermal and 

security cover. Intermediate successional stages are used mainly for travel and landscape connectivity 

but may also provide foraging opportunities. 

3-201 
Final Environmental Impact Statement 

B. Pre-Field Review 

Habitat Available Within the Project Area 

No. In a letter dated August 2 of 2001 (USDA, 2001) and updated on December 3 of 2003 (USDA, 

2003), the Forest has made a determination, based on the best available scientific and commercial 

data, that the Canada lynx and its habitat are currently not present on the Forest and Scenic Area. This 

letter is consistent with the January 2001 Record of Decision and Standards and Guidelines for 

Amendments to the Survey and Manage, Protection Buffer, and Mitigation Measure Standards and 

Guidelines (USDA Forest Service and USDI BLM, 2001), and is consistent with the Lynx 

Conservation Assessment and Strategy (Ruediger, 2000) as specified in this Record of Decision. 

The Lynx Nationwide Survey protocol was implemented and resulted in no lynx being located on the 

Forest and Scenic Area. Forest-wide winter tracking surveys have been conducted during the winters 

of 1994-1995, 1995-1996, 2000-2001, 2001-2002, 2002-2003, and 2003-2004. No lynx were detected 

during these surveys. 

No further analysis needed due to lack of habitat. 

3.11.5.5 Larch Mountain Salamander (Plethodon larseli): Sensitive 

Effects Common to All Alternatives 

There are no treatments planned in Larch Mountain salamander habitat. For Alternatives 2 and 3 the 

PDC would reduce the probability that any Larch Mountain salamanders would be near an area that 

would have herbicide treatment. 

Alternative 1 – No Action 

No short or long-term effects to the Larch Mountain salamander would be predicted with this 

alternative. There are no direct or indirect effects of invasive plant treatment on Larch Mountain 

salamanders. The treatment areas covered under the existing NEPA analysis have no known locations 

in an area where Larch Mountain salamanders are expected to occur. Extensive previous surveys on 

the Barlow Ranger District did not locate any LMS. It is possible but not expected that the BPA 

transmission line area (Sites #66-007 and #69-008) and or existing treatment areas in the Scenic Area 

could have possible Larch Mountain salamander sites adjacent to the transmission line which have not 

been discovered. 

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Site-Specific Invasive Plant Treatments 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

• Effects to Habitat: The Larch Mountain salamander prefers moist environments, typically in 

mature forest, and tends to avoid large open areas. These alternatives would not significantly 

alter the trees per acre and would not affect existing logs that are currently in these stands. It is 

probable that the microclimate would change within the road prism temporarily as a result of 

the invasive plant treatments, but this habitat is not considered suitable for Larch Mountain 

salamanders. Thus, these alternatives would not degrade or remove potential Larch Mountain 

salamander habitat from the area. 

• Effects to Individuals: A PDC is designed to eliminate concern for impacts to Larch Mountain 

salamanders. Although limited surveys for this species have been completed in the invasive 

plant treatment areas, potential habitat for the Larch Mountain salamander appears to occur. 

Species presence, therefore, is assumed in some areas but is impacts are avoided because of 

the implementation of the PDC. 

• Effects to Population: No detrimental effects should occur to individuals of the population due 

to the Larch Mountain salamander PDC, and therefore adverse effects to the population are 

not expected to occur. The Hood River and Barlow Ranger Districts on the Forest have 

recently conducted extensive surveys for the Larch Mountain salamander for three years, but 

found no populations or individuals outside of the Larch Mountain vicinity. In addition, 

although the range of the species is small, there is abundant potential habitat for the species in 

protected lands on the Forest, Scenic Area, and Gifford Pinchot National Forest. 

Predominantly, these protected lands are Wilderness areas, Congressional Reserves, LateSuccessional Reserves, and Scenic Area lands. 

Early Detection/Rapid Response Strategy 

The implementation of the PDC for Larch Mountain salamanders should eliminate any potential 

impacts to this species from implementation of the. No additional effects to populations are 

anticipated due to the EDRR. 

Cumulative Effects 

There are very few invasive plant treatment areas that that are within the known distribution of Larch 

Mountain salamanders. The habitat for this species lowers the likelihood of projects being planned in 

the area where this salamander lives. The projects in the Scenic Area have the greatest potential for 

impacting this species, but none of the treatments are planned in talus or rocky substrates. PDC for 

Larch Mountain salamanders eliminates any effect to this species so there are no cumulative effects. 

3-203 
Final Environmental Impact Statement 

3.11.5.6 Oregon Slender Salamander (Batrachoseps wrighti): Sensitive 

Effects Common to All Alternatives 

The herbicide effects analysis for Oregon Slender salamander indicated that there is very little 

information on the effects of herbicide on amphibians. Amphibians have skin that could move 

herbicides more readily into their system than other wildlife species. It is, therefore, assumed that the 

effects could be toxic for many of the herbicides that are proposed, if the herbicide contacts the skin 

through direct spraying or the amphibian moving into the herbicide shortly after the area being 

sprayed. Based on this assumption, it is predicted that some Oregon Slender salamander individuals 

could be impacted by herbicides used in their habitat. 

Oregon Slender salamanders are not often found on roadsides or forest openings (the areas where 

most invasive treatments would occur); rather they prefer to live in forested stands. Also, their habit 

of living under bark and in rotten logs would almost eliminate their exposure to herbicides, manual 

and mechanical treatment methods. 

Alternative 1 – No Action 

No short-term or long-term effects to the Oregon Slender salamander would be predicted with this 

alternative. The treatment areas covered under the existing NEPA analysis are located near areas 

where Oregon Slender salamanders are expected to occur. Due to their habitat preference, their 

exposure to herbicide, manual and mechanical treatment methods is extremely limited. Therefore 

there are no direct or indirect effects to this species. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

• Effects to Habitat: No effects to habitat are anticipated because the habitat preference for 

Oregon Slender salamander is different than the areas being treated. The only exception to this 

is the Recreational Residence area where English ivy would receive manual and mechanical 

treatments in wooded conditions. In the course of treating English ivy vines there is potential 

to disrupt pieces of bark and down wood where Oregon Slender salamanders may hide. This is 

a microhabitat consideration and the salamanders would move to alternate hiding areas. 

3-204
Site-Specific Invasive Plant Treatments 

• Effects to Individuals: There would be very limited opportunities for Oregon Slender 

salamanders to be exposed to invasive plant treatments. The effects to Oregon Slender 

salamander are minor. There would be 2175 acres adjacent to habitat that would be considered 

suitable for Oregon Slender salamanders that would be treated by broadcast boom spraying in 

Alternative 2 and 507 acres broadcast boom sprayed in Alternative 3. It is conceivable that 

during the spring salamanders that are dispersing could wander into a treatment area, when the 

area is adjacent to or through an older stand of trees similar to the suitable habitat for Northern 

Spotted Owls. When these cases occur, it is probable that the individual coming in contact 

with herbicides could be adversely impacted. It is anticipated, however, that this occurrence 

would be very limited and the number of individuals affected would be small. It is not 

expected that individuals would be adversely impacted by the manual, mechanical, or cultural 

treatments. Due to their habitat preference, their exposure to herbicide, manual and 

mechanical treatment methods is extremely limited. Therefore there are no anticipated direct 

or indirect effects to this species. 

• Effects to Population: No detrimental effects are expected to could occur to individuals and 

therefore adverse effects are not expected to the population as a whole. The Hood River and 

Barlow Ranger Districts on the Forest have recently found approximately 300 individuals of 

this species while conducting surveys for the Larch Mountain salamander. In addition, 

although the range of the species is small, there is abundant potential habitat for the species in 

protected lands on the Mt. Hood and Willamette National Forests as well as the Scenic Area. 

Predominantly, these protected lands are Wilderness areas, Congressional Reserves, LateSuccessional Reserves, and National Scenic Area lands. 

Cumulative Effects 

There are no anticipated impacts to this species therefore there are no cumulative impacts from the 

treatment of invasive plants from herbicide, manual, mechanical or cultural treatments, or the EDRR. 

Impacts if any are expected to be few and would not impact populations. 

3-205 
Final Environmental Impact Statement 

3.11.5.7 Cope’s Giant Salamander (Dicamptodon copei): Sensitive and 

Cascade Torrent Salamander (Rhyacotriton cascadae): Sensitive) 

Alternative 1 – No Action 

No effects to the Cope’s Giant salamander or Cascade Torrent salamander would occur with 

implementation of this alternative. There is potential habitat for these species on the near the BPA 

transmission line (Sites #66-007 and #69-008), but no areas of the Scenic Area were identified that 

would be impacted from treatments that are planned. Impacts to these species were analyzed under 

existing NEPA documents. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

• Effects to Habitat, Individuals, and Populations: The PDC intended to protect water quality 

and aquatic organisms would protect these salamanders. There are several streams and wet 

areas occurring within or adjacent to the invasive plant treatment area. The potential for 

increased sedimentation to these water sources from herbicide, manual, mechanical, and 

cultural treatments is minimal. The greatest risk to individuals is from the use of picloram, 

glyphosate, and triclopyr based on the herbicide effects analysis (Appendix X, Table X-3) and 

comments from the FWS (Bridges, personal communication). If these herbicides entered the 

stream or seep they could reduce invertebrate populations through reductions in aquatic plants 

or be toxic to both species. PDC that are intended to reduce herbicide making it into the 

stream and prudent use of picloram, glyphosate, and triclopyr should eliminate the hazard to 

these two aquatic salamanders (Section 2.2 – Project Design Criteria for All Alternatives). The 

protection measure proposed to eliminate the risk to listed fish would be adequate to protect 

individuals, habitat and populations. PDC (F.1.) that designates a 100 foot aquatic influence 

zone on streams, where special treatment precautions would occur, should eliminate the risk to 

these two species. Based on the PDC there are no effects predicted for the proposed treatment 

to populations of Cope’s Giant salamander and Cascade Torrent salamander. 

Early Detection/Rapid Response Strategy 

There are no additional effects predicted for Cope’s Giant Salamander or Cascade Torrent 

Salamander from the additional areas that could be treated with the EDRR. There are no effects to 

aquatic organisms anticipated due to the PDC. 

Cumulative Effects 

No effects are anticipated to these salamanders so no cumulative effects are predicted to occur with 

the Proposed Action. There would be some increase in sediment from reduction of vegetation but it 

expected to be small and would travel a short distance within the stream. PDC (F.1.) restricts 

treatments near streams would reduce or eliminate the majority of the cumulative effects. Currently, 

there are no foreseeable future actions other than those previously mentioned on the Forest and Scenic 

Area within the watersheds that are predicted to impact the Cope’s Giant salamander or Cascade 

Torrent salamander or there habitat. 

3-206
Site-Specific Invasive Plant Treatments 

3.11.5.8 American Peregrine Falcon (Falco peregrinus anatum): Sensitive 

Effects Common to All Alternatives 

Based on the herbicide effect analysis (Appendix X, Table X-1) there is very little risk of direct 

effects to Peregrine Falcons from the use of herbicides. The only possible direct effect is the possible 

ingestion of herbicides by eating birds that had been exposed to herbicides. The analysis shows no 

toxic effect from this exposure at levels that are probably higher than the actual exposures. The 

indirect effect to these birds would be from disturbance from workers doing herbicide, manual, 

mechanical, or cultural treatments. There is some potential for some disturbance at one sites but this 

site is in an area of high traffic now so the effect would be minor. 

Alternative 1 – No Action 

There is no nesting habitat or known locations in the areas of existing treatment areas or areas where 

existing NEPA is in place. Migrating or foraging may take place here but there is little to no effect 

anticipated from activities associated with this alternative. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

Both alternatives have the same minor impact to Peregrine Falcons because the high priority sites that 

would be treated in both alternatives have the same impact. A high priority site (Site #) is adjacent to 

a Peregrine Falcon nest site. The effect of having a potential disturbance to nesting peregrines would 

occur in both alternatives. This indirect effect is expected to be minor due to existing human traffic 

that the birds currently tolerate. 

• Effects to Habitat, Individuals, and Populations: There is no effect to Peregrine Falcon 

habitat. No alternative would alter cliff habitat. Herbicide, manual, mechanical, and cultural 

treatments have potential of disturbing nesting and foraging falcons. Falcons are fairly 

sensitive to disturbance and would occasionally abandon nest sites when they are disturbed. 

The disturbance factor is less when they chose nest locations where they have a regularly 

reoccurring amount of human activity as evidenced by their use of bridges and buildings in a 

downtown location. The nest site adjacent to the high priority treatment site is a similar type of 

location. There is a high degree of vehicle traffic in the immediate vicinity of this nest site. 

The effect, therefore, would be minimal on the nesting success of this pair from invasive plant 

treatment. Therefore the effect of disturbance would be minor to peregrine falcons. 

No effects are expected from any of the invasive plant treatment methods to either individuals 

or the population of peregrine falcons. 

Early Detection/Rapid Response Strategy 

The analysis is the same for the EDRR. It is not expected that there would be any additional nest sites 

affected by the EDRR. 

3-207 
Final Environmental Impact Statement 

Cumulative Effects 

Since the herbicides selected do not pose a risk from bioaccumulation or a long residual effect there 

are not anticipated cumulative effects from either projects on or off of the Forest and Scenic Area. 

3.11.5.9 Northern Painted Turtle (Chrysemys picta): Sensitive and 

Western Pond Turtle (Clemmys marmorata marmorata): Sensitive 

Effects Common to All Alternatives 

Very little research has been done on the effects of herbicides to reptiles. It is assumed therefore that 

the effects would be similar to other aquatic organisms such as fish (See Section 3-10 – Aquatic 

Organisms and Habitat). The PDC should reduce the risk of toxic effects and sedimentation from 

mechanical and manual methods. 

Alternative 1 – No Action 

No effects to the northern painted turtle or western pond turtle would occur with implementation of 

this alternative. There are no known locations where the previously approved invasive treatments 

occur. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

There are no treatment sites adjacent to the known locations for the turtles in the Scenic Area. There 

are no known locations and no anticipated impacts to turtles on the Forest. PDC F.1. that restricts 

treatments near water systems should effectively eliminate the risk to the turtles. 

Cultural methods such as the use of goats to control invasive plants would have a minor detrimental 

effect on turtle reproduction since the goats could walk along the shoreline of a pond and crush the 

shallow buried turtle eggs. Reproductive failure due to egg predation is possibly the reason for the 

decline in the turtle population. Goats could add to this loss. At this time there are no proposed 

cultural treatments at the known locations for the turtles. This method should be not be used in the 

known locations in the EDRR. 

• Effects to Habitat, Individuals, and Populations: There is a negligible potential for impacts to 

turtles, their populations or their habitat. By restricting herbicide use within 100 feet of a body 

of water, there should be very little chance of exposure to the turtles. The run-off that occurs 

should not raise concentrations to a level that would have toxic effects on the turtles. 

Currently, there are no planned treatments adjacent to a pond occupied by turtles. The EDRR 

would take into account the turtle locations and would take measures to avoid impacts to the 

turtles. 

Cumulative Effects 

Currently, there are no past, present, or foreseeable future actions within the area where turtles are 

known to occur that are predicted to impact the northern painted turtle, western pond turtle or their 

habitat. 

3-208
Site-Specific Invasive Plant Treatments 

3.11.5.10 Horned Grebe (Podiceps auritus): Sensitive and 

Bufflehead (Bucephala albeola): Sensitive 

Effects Common to All Alternatives 

The herbicide effects analysis (Appendix X, Table X-1) determined that there were no toxic effects 

from any of the herbicides analyzed for bufflehead and horned grebes. There are no treatments on the 

Forest that would be directly adjacent to ponds utilized by these species. On the Scenic Area, there are 

two treatment areas (Site #) where the use of goats in combination with other treatment methods in 

the Sandy River Delta (an area where these two species could occur). This area is not utilized for 

nesting and the effects from using any of the treatment methods would cause an impact to these two 

species. It is anticipated that some harassment from the treatments could occur but the effects would 

be minor to these birds. 

Early Detection/Rapid Response Strategy 

No impacts are anticipated for horned grebes, bufflehead, or their habitat from the EDRR. 

Cumulative Effects 

There are no cumulative effects predicted for this species because the effects from herbicide would 

not reside in the water long enough to accumulate in the system to affect these water birds in the fall 

or winter. Manual, mechanical, and cultural treatments are not anticipated to have any affect on 

bufflehead and horned grebes. 

3.11.5.11 Harlequin Duck (Histrionicus histrionicus): Sensitive 

Effects Common to All Alternatives 

The herbicide effects analysis (Appendix X, Table X-1) determined that there were no toxic effects 

from any of the herbicides analyzed for harlequin ducks. However, in discussion with the FWS about 

the use of herbicides there is concern for the health of macro invertebrate populations following the 

use of picloram. Picloram could affect the aquatic insects that harlequin ducks forage. The PDC F.1. 

restricting herbicide application within 100 feet of a stream or body of water is designed to reduce or 

eliminate this risk. 

Alternative 1 – No Action 

No effects to harlequin ducks would occur with implementation of this alternative. There are no 

known or suspected locations on the Barlow Ranger District, where the majority of the previously 

approved invasive treatments occur. 

3-209 
Final Environmental Impact Statement 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

Both the high priority sites for Alternative 3 and Alternative 2 have locations within the road prism 

near the streams and rivers where harlequin ducks are known to occur (Sites #). PDC F.1. restricts 

treatments near water systems labeled herbicides should effectively eliminate the risk to harlequin 

ducks. Sediment caused by manual and mechanical methods and even the reduction of streamside 

vegetation may temporarily increase sediment that could affect the macro invertebrates that these 

ducks forage. At this time there are no proposed cultural treatments at the known or suspected 

locations for harlequin ducks. 

Manual, mechanical, and herbicide treatments along the stream courses where harlequin ducks nest 

have the potential of disturbing nesting ducks. The work within the first 5 feet of the stream may 

cause hens to abandon their nest and could result in nest failure that year. Both the annual treatment of 

knotweed species and the EDRR could make this disruption of nesting an annual event until the 

invasive plants are treatment. 

• Effects to Habitat, Individuals, and Populations: Some loss of nest habitat may occur as 

streamside vegetation is removed as a result of treatment. It is not known how often harlequin 

ducks utilize invasive plants for nesting, but it is expected that occasionally these ducks would 

utilize knotweed species for nesting cover. When this is the case there would be a temporary 

loss of cover until natural vegetation returns. 

It is anticipated that there would be negative effects to individuals from nest disturbance. This effect 

could last several years for a particular stretch of stream where infestations occur. In some cases this 

disturbance could result in nest failure. More often, it would be a temporary disturbance and, if the 

hen is late into incubation, than the hen should return. 

The loss of individuals from nest disturbance would be localized and would not affect harlequin duck 

populations. 

Early Detection/Rapid Response Strategy 

The EDRR would increase the opportunity for affecting the macro invertebrates in the stream but the 

PDC would reduce or eliminate this risk. The continued presence in streamside areas to control 

knotweed species could potentially disrupt nesting for this species. Since the distribution of harlequin 

ducks is widely scattered, the effects would be limited to a few individuals and would be similar to 

recreation in the area. 

Cumulative Effects 

The manual and mechanical treatments have the most potential for causing cumulative effects of 

disturbance to nesting birds. Campgrounds, roads, and aquatic recreation such as rafting, kayaking, 

and fishing all create cumulative effects to these ducks. The continued intrusion into the harlequin’s 

habitat is additive and could reduce the reproductive rate for these birds and the use of habitat. 

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Site-Specific Invasive Plant Treatments 

3.11.5.12 Wolverine (Gulo gulo): Sensitive 

Alternative 1 – No Action 

No direct or indirect effects to the wolverine would occur with implementation of this alternative. The 

existing human use of this area would continue to limit opportunities for wolverines to utilize the 

area. The area, however, would continue to provide potential habitat for the species. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

• Effects to Habitat and Individuals: There is a very minor potential for disturbance (an indirect 

effect) and loss of utilization of some of the potential wolverine habitat by this implementing 

these two alternatives. Increasing human presence in low traffic areas would degrade the 

utilization of this habitat for wolverines, if they still exist on the Forest. Compared to other 

existing human presence in the treatment areas, the effects would be miniscule by comparison. 

The herbicide effect analysis (Appendix X, Table X-1) shows no toxic effects (direct effect) 

determined from herbicide use on wolverines. There are no anticipated direct or indirect 

effects from manual, mechanical or cultural treatments because their location is not in the 

proximity of areas identified as possible denning areas (Mt. Hood National Forest GIS 

system). 

Early Detection /Rapid Response Strategy 

The EDRR would potentially increase the amount of impact from human disturbance on the Forest 

and Scenic Area. The methods themselves would not pose a threat to wolverines, but the increase in 

human activity is a factor for a species that prefers seclusion. The effect is expected to be minor. 

Cumulative Effects 

The primary cumulative effect predicted for this species is to increase both the number of visitors to 

this area and expand the area of human impact in the project area. An increase in human use in this 

area could cause wolverines to discontinue utilizing the area. That is assuming that the current level of 

use has not already had that impact. 

Currently, there are many foreseeable future actions within the Forest that are predicted to impact 

wolverines and their habitat. Winter recreation, hiking, and climbing as well as proposed 

improvements for these activities increase human activity in the area, and would add to the effect of 

disturbance. Since there is already a high amount of human activity in the area from ski areas, 

businesses, a major highway, recreational uses and homes the effect of this project is considered to be 

a minimal addition. Any increase in human activity in areas where wolverines exist is a cumulative 

effect on this species. 

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Final Environmental Impact Statement 

3.11.5.13 Baird’s Shrew (Sorex bairdii permiliensis): Sensitive 

Alternative 1 – No Action 

No direct or indirect effects to the Baird’s shrew would be predicted with this alternative. The areas 

treated by the existing NEPA documents would not have Baird’s shrews because they are on the 

eastside of the Cascades or they are no in Baird’s shrew habitat. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

• Effects to Habitat: Effects to Baird’s shrew habitat are predicted to be minor. Although the 

areas treated are adjacent to suitable habitat for the shrew, the treatment areas themselves are 

not considered good habitat. The greatest possibility for exposure to herbicides would be on 

the 2175 acres of habitat adjacent to or in mature forest that would be broadcast boom 

sprayed. There is a lower chance of exposure in Alternative 3 where only 507 acres of habitat 

in or adjacent to mature forest would be broadcast boom sprayed in this alternative. A key 

component of habitat for this species is down logs. This alternative would not impact existing 

logs that are currently in these stands. No change in the microclimate in the adjacent stands is 

anticipated. It is predicted that this Proposed Action would not degrade nor remove potential 

Baird shrew habitat from the area. 

• Effects to Individuals: Direct and indirect effects to Baird’s shrews would be small due 

because of their habitat use. Although no surveys for this species have been completed in the 

invasive plant treatment project area, there appears to be potential habitat for the Baird shrew 

in the adjacent older forested stands. For this reason, species presence is assumed in these 

areas. Several of these stands with potential habitat are adjacent to other suitable habitat that 

individuals could migrate into after project implementation. As a result, shrews moving from 

one stand to another could pass through the treated area. This could cause exposure to 

herbicide by these individuals both directly and from the insects they ingest (direct and 

indirect effects). These shrews do not have long home ranges so they may receive a chronic 

exposure to the herbicides. The effects analysis (Appendix X, Table X-1) showed a toxic level 

of exposure is possible for Baird’s shrews with the following herbicides: clopyralid, picloram, 

sulfometuron methyl, triclopyr, and NPE surfactant. Triclopyr would only be spot sprayed so 

the effect of this herbicide on shrews is expected to be minor. 

Although the effects analysis shows a high level of toxicity for the shrews the risk to exposure 

is minor. Openings and roadside habitats where most of the invasive plant treatments would 

take place is not shrew habitat and only a few individuals who wander into this habitat are 

expected to be exposed. When exposed, however, there is a minor chance that the shrews 

could receive a toxic dose. 

No impacts from manual, mechanical or cultural treatment are expected. These methods 

would not affect shrews. 

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Site-Specific Invasive Plant Treatments 

• Effects to Population: Although detrimental effects could rarely occur to individuals of the 

population, adverse effects are not expected to the population as a whole. In addition, there is 

abundant potential habitat for the species in protected lands on the Forest and Scenic Area. 

Predominantly these protected lands are Wilderness areas, Congressional Reserves, LateSuccessional Reserves, and National Scenic Area lands. The effects to Baird’s shrews are 

expected to be minor and should not impact shrews at the population level. 

Early Detection /Rapid Response Strategy and Cumulative Effects 

The EDRR would increase the exposure risk to the shrews by both expanding the area of impact and 

by creating annual exposure opportunities until the invasive plants are treated. The habitat where 

invasive plants are being controlled, however, is on the fringes of the shrew’s habitat. 

The EDRR is the only cumulative impact to the Baird’s shrew. The annual attempt to treat invasive 

plants may take annual tolls on the individuals adjacent to herbicide treatment areas. No impacts are 

expected for shrews off the Forest and Scenic Area that would lead to a cumulative effect. 

Cumulative Effects 

No cumulative effects are anticipated for Baird’s Shrew because there are rarely any invasive species 

treatments, including herbicide treatments that occur in their habitat. 

3.11.5.14 Pacific Fringe-tailed Bat (Myotis thysanodes vespertinus): Sensitive 

Effects Common to All Alternatives 

The herbicide effects analysis (Appendix X, Table X-1) for Pacific Fringe-tailed bat showed little 

toxic effects determined for any of the herbicides. The NPE surfactant was the only toxic effect 

predicted for this species. Since bats feed above the areas that would be sprayed, there is no likely 

effect from direct contact with herbicide. The Pacific Fringe-tailed bat has been documented in areas 

outside the Pacific Northwest as eating beetles and gleaning these insects off vegetation. In this area, 

however, they tend to eat more moths than other insects. There is the possibility that insects (moths in 

particular) that are in the herbicide spray zone could fly in areas where bats could feed on them. Since 

bats forage over a wide area, it is not anticipated that they would receive a chronic dose from eating 

contaminated insects. The potential does exist in each alternative for Pacific Fringe-tailed bat to ingest 

insects that have been sprayed with herbicides (an indirect effect). 

Alternative 1 – No Action 

There is an extremely low potential for impacts to Pacific Fringe-tailed bats from this alternative. The 

species has not been documented in this area and the method of feeding on moths would make the 

risk to this species extremely low. The previous projects covered by existing NEPA documents would 

provide an opportunity of exposure to herbicides under this alternative. 

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Final Environmental Impact Statement 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

Due to the large area of treatment and wide variety of habitat types that this alternative encompasses, 

there is an increased risk to bats in general, and the Pacific Fringe-tailed bat would have a greater 

chance of being in an area where invasive plants would be treated with herbicides and the NPE 

surfactant. The NPE surfactant poses a risk to the bats if they ingest insects sprayed with the 

surfactant. The surfactant shows some toxicity to insect eating mammals from acute exposures. The 

risk is minor that the bats would be in the area and that they would ingest a flying insect that has been 

treated with the herbicides. There are no identified risks to bats from manual, mechanical, or cultural 

treatments. 

• Effects to Habitat: Pacific Fringe-tailed bat uses caves and buildings for roosting and 

maternity colonies. These would not be impacted by any of the alternatives. 

• Effects to Individuals: There is a very minor possibility that a few individuals could be 

impacted by the use of NPE surfactant. This would be rare and may never occur due to the low 

risk of ingesting insect coated in herbicides. 

• Effects to Population: There would be no impact to populations. The limited risk to 

individuals would be even less to the population. 

Early Detection /Rapid Response Strategy 

The EDRR would expand the opportunity of exposure to herbicides both spatially and temporally. 

The risk would continue to be low. 

Cumulative Effects 

The cumulative effect would be the ongoing nature of the invasive plant treatment project. 

3.11.5.15 Pacific Pallid Bat (Antrozous pallidus pacificus): Sensitive 

Effects Common to All Alternatives 

The herbicide effects analysis (Appendix X, Table X-1) for Pacific pallid bat showed minor toxic 

effects determined for any of the herbicides. The NPE surfactant was the only toxic effect predicted 

for this species. Since bats feed in the areas that would be sprayed and take prey from the ground or 

shrubs, there is a likely effect from ingesting insects that have come in contact with herbicide(s). The 

Pacific Pallid Bat has been documented in areas outside the Pacific Northwest as eating beetles and 

gleaning these insects off the ground and vegetation. There is the possibility that insects (moths in 

particular) in the herbicide spray zone could be ingested by bats. Since bats forage over a wide area, it 

is not anticipated that they would receive a chronic dose from eating contaminated insects. The 

potential does exist in each alternative for Pacific Pallid Bats to ingest insects that have been sprayed 

with herbicides. 

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Site-Specific Invasive Plant Treatments 

Alternative 1 – No Action 

There is an extremely low potential for impacts to Pacific Pallid Bats from this alternative. The 

species has not been documented in the areas targeted for herbicide treatment in this alternative. The 

previous projects covered by existing NEPA documents would provide a very limited opportunity of 

exposure to herbicides. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

Due to the large treatment area and wide variety of habitat types that these alternatives encompass, 

there is an increased risk to bats in general and the Pacific Pallid Bat would have a greater chance of 

being in an area where invasive plants would receive herbicide treatments, possibly including the 

NPE surfactant. The NPE surfactant pose a risk to the bats if they ingest insects sprayed with the 

surfactant. The surfactant shows some toxicity to insect eating mammals from acute exposures. The 

risk is minor that the bats would be in the area and that they would ingest a flying insect that has been 

treated with the herbicides in the eastern portion of the Scenic Area. There is no identified risk to bats 

from manual, mechanical, or cultural treatments. 

• Effects to Habitat: Pacific Pallid Bat uses caves, rocky areas and buildings for roosting and 

maternity colonies. These would not be impacted by any of the alternatives. 

• Effects to Individuals: There is a very minor possibility that a few individuals could be 

impacted by the use of NPE surfactant. This would be rare and may never occur due to the 

minor probability of ingesting insect coated in herbicides. 

• Effects to Population: There would be no impact to populations. The limited risk to 

individuals would be even less to the population. 

Early Detection/Rapid Response Strategy 

The EDRR would expand the opportunity of exposure to herbicides both spatially and temporally. 

The risk would continue to be low. 

Cumulative Effects 

The cumulative effect would be the ongoing nature of the invasive plant treatment project. 

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Final Environmental Impact Statement 

3.11.5.16 Fisher (Martes pennanti pacifica): Sensitive 

Effects Common to All Alternatives 

No effects to the fisher would be predicted with any alternative because there is no established 

presence of fishers on the Forest. 

• Effects to Habitat: Although there is no established presence of fisher on the Forest, there is 

the potential that populations to the south could move onto the Forest in the future. There is no 

evidence of this, but habitat is being considered in this analysis. 

The alternatives would not impact stand structure enough to alter fisher habitat. These 

alternatives would retain existing logs that are currently in these stands. Also, it is likely there 

would be additional down woody debris generated by the project. The microclimate would 

change within the harvest units, but probably not to the degree to make the treatment areas 

unsuitable for the fisher. Thus, these alternatives would degrade but not remove fisher habitat 

from the area. It is not expected that treatment in these stands would increase fragmentation of 

suitable habitat for the species. 

• Effects to Individuals: Although no surveys for this species have been completed in the 

Invasive treatment areas, there appears to be potential low quality habitat for the fisher within 

the older forested stands. For this reason, species presence is assumed in these areas. 

There is the slight possibility that a fisher traveling through the area could be impacted by the 

disturbance associated with implementation of this project. The stands with potential habitat, 

however, are adjacent to more suitable habitat that individuals could easily migrate into during 

project implementation. The proposed project does not have the potential to extirpate 

individuals that are present in or adjacent to the units. Fishers are not believed to be highly 

sensitive to human activity. Any fishers currently utilizing the area could easily change their 

travel habitat to avoid the management activity. 

• Effects to Population: Effects are not expected to the population since there would be no 

adverse effects to any individuals. 

Cumulative Effects 

No cumulative effects would occur from the proposed invasive plant treatments. 

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Site-Specific Invasive Plant Treatments 

3.11.5.17 Crater Lake Tightcoil (Pristiloma arcticum crateris): Sensitive 

Alternative 1 – No Action 

No effects to the Crater Lake Tightcoil would be predicted with this alternative. Projects occurring 

under existing NEPA are not in habitat for this species. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

• Effects to Habitat: It is anticipated that some habitat areas for this species may be present in 

the riparian areas, where knotweed species would be treated. Some treatment may take place 

in some portion or, in rare cases, all of the home range for this small species. In some rare 

cases, the amount of opening created by controlling the infestations could change the 

microclimate to make the habitat is no longer suitable. This would be a very rare situation 

based on the absence of this species in previous surveys. 

There are no major changes in effects expected between Alternatives 2 and 3. The knotweed 

treatment is part of both alternatives, and this is the area most likely to be habitat for this 

species. There are no projects using manual, mechanical or cultural that are expected to impact 

this mollusk. 

• Effects to Individuals: It is possible that some individuals may be removed from the 

population due to invasive species treatment in riparian areas even though the herbicides 

effects analysis showed no effect (Appendix X, Table X-1). The footprint of the treatments 

themselves is small in terms of ecological scale and, therefore, the resulting loss of individuals 

is anticipated to be small relative to the overall local population of these mollusks. PDC H.2. 

that limit the distance to streams and seeps should avoid impacting most individuals. 

• Effects to Population: Although it is anticipated that there is potentially some loss of 

individuals, these mollusk are widely scattered over the landscape from Klamath County, 

Oregon to the Forest and Scenic Area. Crater Lake Tightcoil occurs throughout the Oregon 

Cascades in widely scattered populations. The effect of this project would be extremely local 

and should not severely impact the population. 

Early Detection/Rapid Response Strategy 

The EDRR may extend the possible risk to the mollusk. The effects analysis, however, shows no 

toxicity from herbicides to this species, and it is not expected that the EDRR would increase the risk 

to this species significantly. 

Cumulative Effects 

There are very few projects that have the potential to impact Crater Lake Tightcoil due to the 

widespread habitat distribution. Most projects do not occur within or buffer the types of habitats, such 

as seeps, springs, or riparian areas, where the species is found. As a result, impacts to this species are 

rare. There are no anticipated cumulative effects for this mollusk. 

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Final Environmental Impact Statement 

3.11.5.18 Dalles Sideband (Monadenia fidelis minor), Puget Oregonian (Cryptomastix devia), 

Columbia Oregonian (Cryptomastix hendersoni): Sensitive 

Alternative 1 – No Action 

Effects to these three mollusks would be rare in this alternative. Projects occurring under existing 

NEPA are not in habitat for these species. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

• Effects to Habitat: It is anticipated that some habitat areas for these species may be present in 

the riparian areas, where knotweed species would be controlled. Some treatment may take 

place in some portion of the home range for these small species. In some rare cases, the 

amount of opening created by controlling the infestations could change the microclimate to 

make the habitat no longer suitable. The percentage of the habitat occupied by the infestations 

is small so the impact would be minor for the species. By following the PDC H.2. and 

avoiding the use of herbicides within 100 feet of a spring or seep, the risk to the species would 

nearly be eliminated. 

There are no major changes in effects expected between Alternative 2 and 3. The knotweed 

treatment is part of both alternatives and this is the area most likely to be habitat for this 

species. There are no projects using manual, mechanical or cultural that are expected to impact 

this mollusk. 

• Effects to Individuals: It is possible that some individuals may be removed from the 

population due to invasive species treatment in riparian areas even though the herbicides 

effects analysis showed no effect (Appendix X, Table X-1). The footprint of the treatments 

themselves is small in terms of ecological scale and, therefore, the resulting loss of individuals 

is anticipated to be small relative to the overall population of these mollusks. PDC H.2. that 

limit the distance to streams and seeps should avoid impacting most individuals. 

• Effects to Population: Although it is anticipated that there would potentially be some loss of 

individuals these mollusk are widely scattered over the landscape in Oregon and on the Forest. 

There is no anticipated major impact to the local populations even though there may be an 

impact to individuals. The effect of this project would be extremely local and should not 

severely impact the local or regional mollusk populations. 

Early Detection/Rapid Response Strategy 

The EDRR may extend the possible risk to these mollusks. Since the effects analysis shows no 

toxicity from herbicides to this species, it is not expected that the EDRR would increase the risk to 

this species significantly. 

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Site-Specific Invasive Plant Treatments 

Cumulative Effects 

There are very few projects that have the potential to impact Dalles Sideband, Puget Oregonian, or 

Columbia Oregon due to their habitat type and widespread distribution. Most projects do not occur 

within or buffer the types of habitats, such as seeps, springs, or riparian areas, where the species if 

found. As a result, the impacts to this species are rare. There are no anticipated cumulative effects for 

this mollusk. 

3.11.6 Management Indicator Species (MIS) 

3.11.6.1 Pileated Woodpecker (Dryocopus pileatus) 

The pileated woodpecker is a Forest Management Indicator Species. Concern over pileated 

woodpeckers arises from their association with mature forest habitat, a habitat type that has been 

affected by logging throughout the woodpeckers range. Breeding bird survey data collected between 

1966 and 1991 shows no significant change in the population in the western United States (Bull, 

2003). Pileated woodpeckers occur throughout the proposed treatment areas. 

Alternative 1 – No Action

None of the treatments occurring under existing NEPA analysis impact pileated habitat, forage, or 

nesting. There are no effects to pileated woodpeckers from this alternative. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

None of the proposed treatments would affect pileated woodpecker habitat, forage or nesting. The 

insects that pileated woodpeckers forage on live inside dead wood and snags: these insects have 

almost no chance of contacting herbicides at the treatment sites. The herbicide effects analysis 

showed no toxic effects to pileated woodpeckers (Appendix X, Table X-1). No habitat would be 

affected by manual, mechanical or cultural treatments. The EDRR would not increase or decrease this 

risk. 

Cumulative Effects 

There are no anticipated effects to this woodpecker, and there are no expected cumulative effects. 

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Final Environmental Impact Statement 

3.11.6.2 American Marten (Martes americana) 

The American marten is a Forest Management Indicator Species. Concern for this species arises out 

of their association with mature and old-growth forest. 

Alternative 1 – No Action 

Martens are expected to occur in some of the areas treated under the existing NEPA. These animals 

would potentially travel through areas treated, but avoid openings. They do, however, travel across 

roads and small forest openings at times, so they could go through a treatment area. Exposure would 

be short and acute. Their home range makes chronic exposure unlikely. The effects analysis for 

herbicides showed no risk of exposure. No habitat would be altered by this alternative. None of the 

treatment methods would have any effect on martens. The effect determination for this alternative is 

No Effect to martens or their habitat. 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

Martens do occur throughout the proposed treatment areas at the higher elevations. The analysis for 

these alternatives is the same as Alternative 1. Martens would travel through the treatment areas but 

there is no risk from any of the treatments methods. There are no toxic effects from herbicides as 

indicated in Appendix X, Table X-1 and there is no habitat altered. The effect determination for 

martens and their habitat is No Effect. This includes the EDRR as well as all treatment methods. 

3.11.6.3 Deer and Elk 

The effects to deer and elk are almost identical, since their habitat requirements and forage are so 

similar. 

Deer 

There are two different subspecies of mule deer that occur in Oregon: the subspecies expected to 

occur within the treatment areas is the black-tailed deer (Odocoileus hemionus). The black tailed deer 

is a Forest Management Indicator Species. Concern over this species arises from its status as an 

important game species. 

Elk 

Elk (Cervus elaphus) are Forest MIS. Two subspecies of elk occur on the Forest and Scenic Area. 

Roosevelt Elk (Cervus elaphus roosevelti) occur on the westside of the Cascades, and Rocky 

Mountain Elk (Cervus canadensis nelsoni) on the eastside of the Cascades. Concern over this species 

arises from its status as an important game species. 

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Site-Specific Invasive Plant Treatments 

Effects Common to All Alternatives 

Invasive plants probably affect deer and elk more than any other species analyzed in this section. 

Invasive plants out compete and replace native forage plants for these ungulates. Eradicating, 

controlling and/or containing invasive plants could substantially improve deer and elk habitat. This 

factor outweighs any detrimental effects of herbicide ingestion and disturbance. 

Of the herbicides analyzed, triclopyr has a toxic effect on ungulates when ingested over a number of 

days (chronic exposure). At times, deer and elk would continue to return to a patch of vegetation that 

they prefer over other plants and continue to forage in that area. Due to this site selection behavior 

they are prone to chronic exposures. As a result, the Invasive Plant ROD (2005b) contains a standard 

that restricts the use of triclopyr and does not allow broadcast boom spraying of this herbicide. 

Mammals that eat vegetation (primarily grass) that has been sprayed with herbicide have relatively 

greater risk for adverse effects because herbicide residue is higher on grass than it is on other 

herbaceous vegetation or seeds (Kenaga, 1973; Fletcher et al., 1994; Pfleeger et al., 1996). Deer and 

elk both eat grasses so they are more susceptible to toxic effects than carnivores. 

Alternative 1 – No Action 

Under the existing NEPA for invasive plant treatment, the use of triclopyr is available. This is the 

only herbicide that the effects analysis (Appendix X, Table X-1) shows as a potentially toxic 

herbicide for deer and elk. Since these projects are in deer and elk habitat, there potentially these 

projects could impact deer and elk where they occur. 

Alternative 2 – Proposed Action 

There is at least some deer and elk forage on every acre of the proposed treatment areas. Potentially 

deer and/or elk could be affected by the treatment of invasive plants. As a result, potentially 13,000 

acres of habitat could be improved by the removal of invasive plant, but also could expose of deer and 

elk to herbicides. There are 4,665 acres of proposed treatment that could potentially have toxic effects 

for deer and elk through the use triclopyr. This effect is offset by the fact that the herbicide would 

only be used as a spot spray. The amount of forage plants that would be sprayed would be reduced 

substantially. This should eliminate the potential for toxic effects from acute and chronic exposure 

since deer and elk rarely forage on the invasive plants targeted for treatment. 

If we assume deer and elk would ingest enough triclopyr to be toxic as a worst-case scenario, we can 

be sure that it would happen infrequently. Exposures of this magnitude are expected to be extremely 

rare, especially with a restriction of no broadcast boom spraying of this herbicide. 

Alternative 3 – Restricted Herbicide Use Alternative 

Similar to Alternative 2, deer and elk forage exist in all acres of this alternative. There would be 

13,000 acres of that would have improved forage by treatment. There are 2,821 acres that could be 

treated with triclopyr but would have little potential toxic effects by eliminating broadcast boom 

spraying of triclopyr. 

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Final Environmental Impact Statement 

The assumptions for toxicity are similar to Alternative 2. It is not expected that there would be any 

reasonable expectation that there would be a high enough dose for exposure to reach a chronic dose. 

The worst case scenario is that there is a minor potential, however, that an occasional animal could 

receive a toxic dose of triclopyr. This would not affect the population of deer or elk. There have been 

no reports of deer or elk suffering from exposure to any herbicides used on farms or commercial tree 

plantations where herbicide use is more prevalent. 

Cumulative Effects 

It is not known how many acres of invasive plant herbicide treatment would occur near the borders of 

the Forest and Scenic Area where this project could affect deer and elk that move across the boundary 

to forage. In these isolated situations, however, there could be cumulative effect of the herbicides on 

individual deer or elk that forage on both private and National Forest System lands in the Forest and 

Scenic Area that have been treated with herbicides. In rare situations, there could be an individual 

animal that received a toxic dose from this scenario. At this time there are no reports of animals in 

agricultural or commercial tree operations that have suffered toxic effects from use of herbicides 

where herbicides are used more widely for vegetation control. 

3.11.7 Other Species of Interest – Landbirds 

A. Habitat and Species Present 

Landbirds which include neotropical migratory birds that have been defined as those species that 

regularly breed in continental North America and winter south of the Tropic of Cancer, typically in 

Central and South America and the Caribbean. Landbirds are defined as all birds except loons, grebes, 

seabirds, waterfowl, long-legged waders, shorebirds, gulls, terns, alcids, cranes, and rails. Widespread 

declines in populations of many landbirds have intensified interest in avian conservation and resulted 

in policy direction to evaluate the impact of proposed activities on the nesting habitats of these 

species. 

The North American Breeding Bird Survey Program found that 75 percent of forest dwelling migrants 

in eastern North America declined in population during the 1980’s (Robbins et al., 1989). Potential 

causes of these declines are numerous and diverse, and may involve corridors and stopover sites, or a 

combination of these factors (Sherry and Holmes, 1992). Related to these potential causes is the 

problem of nest parasitism by the brown-headed cowbird, populations of which have expanded 

significantly in the last few decades due primarily to human-induced changes in the landscape 

(Ehrlich et al., 1988). One hundred sixty two species of landbirds breed in Oregon and Washington 

including common passerine songbirds, hawks, and owls (Andelman & Stock, 1994). 

Landbirds occur in a wide variety of habitat types including early and late-seral forests (Finch & 

Stangel, 1992). In the relatively arid western United States, however, densities of neotropical migrants 

are highest in riparian areas, with coniferous forests being the second-most used habitat by this 

assemblage of species (Saab and Rich, 1997). 

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Site-Specific Invasive Plant Treatments 

USDA Forest Service Landbird Strategic Plan 

In September 2000, the USDA Forest Service Landbird Strategic Plan (2000) was distributed. This 

plan set forth goals and actions to assist meeting the USDA Forest Service commitment to provide 

habitat for sustainable resident and migrant landbird populations and monitor their populations 

through time. It also provides direction to assess and disclose the effects of management actions on 

landbirds in NEPA documents. The strategic plan provides the incentive and means to make landbird 

conservation a part of all activity planning. It serves as new science that must be taken into account 

when planning and implementing USDA Forest Service actions. 

Partners in Flight 

Partners in Flight, a council of international parties interested in the conservation of migratory birds, 

has developed the North American Landbird Conservation Plan (2004) and several regional plans. 

The Forest and Scenic Area falls within the consideration zone for the Conservation Strategy for 

Landbirds in Coniferous Forest of Western Oregon and Washington (Altman, 1999). These plans 

summarize the conservation status of landbirds on a national scale and regional scale respectively. 

They also identify the species most in need of attention in each region. The plans have determined 

focal species based on habitat and risk criterion. 

Focal Species Analyzed 

The National Plan breaks the priorities for the species down to three levels: immediate action, 

management, and long-term planning and responsibility. The only species in the proposed treatment 

area that falls into the immediate action level is the Northern Spotted Owl: this species is covered 

previously in this section. The management level is the second highest priority and is used for this 

analysis. These species are also listed under the regional plan based on their habitat relationships. 

The Conservation Strategy For Landbirds in Coniferous Forest of Western Oregon and Washington 

(reference) set up biological objectives and management actions. The Plan says, “Simply stated, 

biological objectives are “what we think the birds need. They are not regulatory nor do they represent 

the policies of any agency or organization.” That stated, the list of management level focal species was 

used to select species to analyze which represent key species of birds that could indicate any adverse 

affects to landbirds from the proposed invasive plant treatments. 

The following species are listed in both plans and were used for analysis purposes and represent a 

variety of habitats and feeding strategies; hermit warbler (Dendroica occidentalis), blue grouse 

(Dendragapus obscurus), rufous hummingbird (Selasphorus rufus), willow flycatcher (Empidonax 

traillii), band-tailed pigeon (Columba fasciata), and olive-sided flycatcher (Contopus cooperi). The 

herbicide effects analysis showed no toxic effects from the proposed treatment methods to these birds. 

Appendix P of the Invasive Plants EIS (2005a) found that small insectivorous birds could be affected 

by herbicides if exposed to chronic levels of certain herbicides, such as sethoxydim, which could reach 

“three times greater than the chronic LOAEL for birds so suppressed reproduction of insectivorous 

birds are expected from chronic dietary exposures.” When the focal species were analyzed, it did not 

appear likely that most of the species analyzed would be exposed chronically due to feeding strategies 

of these birds. Two exceptions are for the blue grouse and band-tailed pigeon, which are opportunistic 

feeders that would feed on the ground and would return daily to a good food source. 

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Final Environmental Impact Statement 

For these two species, triclopyr and NPE surfactant could cause toxic effects with chronic exposures. 

Triclopyr, according to the Invasive Plant ROD standards (2005b), would only be spot sprayed so this 

should limit the amount of exposure and may eliminate the risk to landbirds from this herbicide. 

There might be some additional circumstances where this assumption could be incorrect and, as a 

result, some individuals of other species may receive a chronic does and be adversely impacted. 

Triclopyr, however, did not affect landbirds in a field study done by Homes. In summary he states: 

“On the basis of our observation that TBEE had no significant adverse effects at a concentration 

greater than the maximum expected environmental concentration, we propose that forestry 

applications of triclopyr at registered dosage rates pose little risk to wild songbirds.” (Holmes et al., 

1994) 

B. Analysis and Determination of Effects 

Effects Common to All Alternatives 

The treatment of invasive plants has short-term impacts by reducing cover, but restoring native 

vegetation would have long-term benefits by providing food and cover (See Section 3.6 – Botany and 

Treatment Effectiveness). Birds or mammals that eat vegetation (primarily grass) that has been 

sprayed with herbicide have relatively greater risk for adverse effects because herbicide residue is 

higher on grass than it is on other herbaceous vegetation or seeds (Kenaga, 1973; Fletcher et al., 1994; 

Pfleeger et al., 1996). Turkeys, grouse, quail, and waterfowl would all consume grass as part of their 

diet. Other birds would eat grass seeds especially. The end result of all of the alternatives is some 

degree of improvement in the quality of habitat, while having a short-term negative effect on 

individual birds. One example from this project would be the treatment of knapweed. Knapweed seed 

is not consumed by birds and provides very poor nest cover. By reducing the presence of knapweed 

and allowing native grasses and forbs that do provide food and cover there is a positive effect to the 

treatment. 

The effects of herbicides, from all methods of intake and to all species on the landscape, are limited. 

The studies that were analyzed for the Regional EIS indicted that there was a low toxicity of 

herbicides to birds. But because of the large gaps is data it must be stated that some effects to birds 

from herbicides are unknown. The data that are available would indicate however that the risk is low. 

Alternative 1 – No Action 

The herbicide effects analysis from Appendix X, Table X-1shows no effect from herbicides to the 

species analyzed except triclopyr and NPE surfactant for blue grouse and band-tailed pigeon. These 

two herbicides are allowed under the existing NEPA, so there could be some effect to these two 

species if they feed in areas that are sprayed with triclopyr or NPE surfactant. The treatment areas are 

limited and should not result in a large exposure to these species or other landbirds that are not 

analyzed. In addition, by eliminating the use of triclopyr from broadcast spraying the exposure to 

triclopyr is severely reduced. 

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Site-Specific Invasive Plant Treatments 

Alternative 2 – Proposed Action 

All of the treatment methods used to treat invasive plants have some short-term negative effect on 

early successional bird species use. All methods if implemented in the spring and early summer could 

impact nesting success of birds, especially ground nesting birds. All of these methods (herbicide, 

manual, mechanical, and cultural) could possibly flush birds from their nest. When flushed from a 

nest many birds return with no harm to the young or eggs, but some species are highly sensitive to 

disturbance and would abandon the nest. 

This alternative includes the use of triclopyr on 4,665 acres. Since this herbicide is only approved for 

spot spraying, the risk of exposure is reduced substantially. It is not likely that band-tailed pigeons, 

blue grouse or other ground feeding birds that they represent would receive chronic dosages that 

would become toxic. 

EDRR would expose landbirds to a possible 13,000 acres of disturbance and possible exposure to 

herbicides. In the short-term, this may cause some reduced reproduction from a reduction in ground 

cover for nesting but in the long-term their habitat would be restored or maintained and this is a 

greater benefit than the possible negative side affects. 

Alternative 3 – Restricted Herbicide Use Alternative 

Impacts to landbirds under Alternative 3 would be similar to those described under Alternative 2 with 

2,821 acres of proposed treatment that could potentially have exposure for grouse and pigeons 

through the use triclopyr. This could affect other bird species not considered under this analysis: these 

species are represented by ground foraging species such as grouse or pigeons. The effects of triclopyr 

would be a minor effect to birds because of the low toxicity of the herbicides analyzed and the 

restricted use of triclopyr. 

Cumulative Effects 

Birds are mobile animals that could potentially receive a dose of herbicides on private, state, or 

National Forest System lands in the Forest and Scenic Area, and fly to another area where herbicides 

are being used. In very rare cases, there is a potential for receiving a toxic dose. It is not possible to 

predict the amount of times this would actually happen but it is anticipated that this would only 

happen in extremely rare cases. It is also impossible to predict the effect of two different herbicides 

interacting synergistically that could cause a toxic effect. For example if a bird were to fly here from 

an agricultural field where there was use of a pesticide and then the bird arrived on the National 

Forest and ingested a herbicide there could be a combined effect that could harm the bird. For such an 

individual the effects would be cumulative, there are no major cumulative effects anticipated for any 

species populations. 

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Final Environmental Impact Statement 

3.11.8 Game Animals 

A variety of game animals exist on the Forest and Scenic Area. The list includes major species such 

as deer, elk, waterfowl, grouse, quail, squirrels, and wild turkeys. The majority of these species forage 

in openings, along road edges, and meadows. Some of these areas would be treated with herbicides. 

There is a high probability that some of these animals would ingest plants that have been sprayed by 

herbicides. One herbicide, triclopyr, had a potential effect for deer and elk based on chronic exposure. 

Since the method of delivery would be spot spraying, there are no anticipated toxic effect to deer and 

elk, although there is still a minor potential for a toxic effect. Deer, elk, and grouse have been 

analyzed for direct effects of the herbicides and it was determined that based on the method of 

application that there would be little to no effect on the species. 

The fact that game animals do forage in the areas that would be sprayed, there is a potential that a 

hunter could harvest an animal that has been foraging on herbicide treated areas. Since these 

herbicides to not bio-accumulate in the fat of animals, there would be no increase in the toxic effect to 

someone eating the animal. The dosage of herbicides that might be ingested by the animal is 

anticipated to be low. And depending on the size of the animal the amount ingested by a person would 

be even lower. Although there is no a research data that was reviewed to confirm the effect of eating 

meat from an animal that has been foraging on herbicide sprayed vegetation, it is expected that there 

would be no observable or detectable effects on people who eat meat from an animal harvested that 

has ingested herbicides sprayed at the recommended rates and by the methods prescribed by this 

document. Since, many of these same herbicides have been sprayed in much larger quantities on 

private lands, especially on commercial agriculture lands, and there have not been recorded cases of 

humans developing problems following the consumption of game animals foraging on these lands, it 

is assumed that there would be no health issues on this project. See Section 3.5 – Human Health and 

Safety for more information. 

3.11.9 Oregon State Sensitive Species 

The 2004 revision to the Management Plan for the Scenic Area plans for evaluating a wider range of 

species than normally included in the Mt Hood National Forest analysis. The Management Plan of the 

includes state listed species. The Management Plans glossary defines its review as follows: 

Sensitive wildlife species: Animal species that are (1) listed as endangered or 

threatened pursuant to federal or state endangered species acts, (2) listed as 

endangered, threatened, sensitive, or candidate by the Washington Wildlife 

Commission, (3) listed as sensitive by the Oregon Fish and Wildlife Commission, 

or (4) considered to be of special interest to the public, limited to great blue heron, 

osprey, mountain goat, golden eagle, and prairie falcon. 

In the SMA, sensitive wildlife species also include animal species recognized by the Regional 

Forester as needing special management to prevent them from being placed on federal or state 

endangered species lists. 

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Site-Specific Invasive Plant Treatments 

Appendix X, Table X-4 shows the effects analysis for the species listed for Oregon that may occur in 

the Scenic Area. The species listed have similar analysis to the other species already analyzed earlier. 

Many of these species are already represented by other similar species that have already been 

analyzed. For example there are four additional bat species but these species are similar in their 

requirements and habits to the fringed-tailed bat previously considered in this document. As such, the 

only further analysis for these species will be in the Appendix X, Table X-4. 

3.11.10 Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action and 

Restricted Herbicide Use Alternatives are consistent with all relevant standards and guidelines, when 

the proposed amendments are incorporated. The Forest Plan amendments are discussed in Section 

3.16. 

3.11.11 Incomplete and Unavailable Information 

The data available for mammals are derived from numerous studies conducted to meet registration 

requirements, and primarily on laboratory animals that serve as surrogates. Data for mammals are 

available for more types of toxicity tests and often on a wider variety of species than are available for 

birds. 

Availability of information on the direct toxicological effects of the 10 herbicides on wild mammals 

varies by herbicide. Glyphosate has been widely studied, including field applications. Little or no data 

on wildlife may exist for other herbicides have been tested on only a limited number of species under 

conditions that may not well represent populations of free-ranging animals (SERA 2001b, 2003a, 

2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f). 

Toxicity data available for birds are derived from studies conducted to meet registration requirements, 

and primarily on domestic birds that serve as surrogates. There are typically fewer types of toxicity 

studies conducted on birds using a more restricted variety of species than are conducted for mammals. 

Almost all laboratory data is collected on mallards and northern bobwhite. How the sensitivities of 

different bird species to herbicides may vary from that reported for mallard and bobwhite is not 

known. 

There is very limited information on the toxic effects of herbicides on amphibians as noted in Section 

3.11.3 under Alternative 1 – No Action, and in Section 3.11.5.6 Oregon Slender Salamander. 

Both indices of shrub diversity, however, were not different over the 5 years. Herbicide treatment 

initially reduced crown volume index of herbaceous vegetation, but values quickly recovered to 

untreated levels by the second year after treatment. Herbaceous species diversity was not affected by 

herbicide treatment. Diversity of small mammal communities apparently was not affected by 

herbicide application. In general, diversity of plant and small mammal communities seemed to be 

maintained, and hence, these treatment sites may not lower overall diversity of a forested landscape 

(Sullivan et al., 1998a). 

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Final Environmental Impact Statement 

3.12. Congressionally Designated Areas and Scenery Management 

The Columbia River Gorge is a congressionally designated area, established by the Columbia River 

Gorge National Scenic Area Act of 1986. Effects to the Scenic Area are described throughout Chapter 

3. The sections below specifically address the affected environment and consequences for designated 

wilderness areas and wild and scenic rivers. A discussion of effects to scenery management in the 

Scenic Area is contained in this section. 

3.12.1 Existing Conditions

Wild and Scenic Rivers 

There are five rivers which are part of the Wild and Scenic Rivers System in the Forest. Invasive plant 

species have been found and treatment is proposed in all five river corridors. Early detection could 

prompt additional treatments in any of the river corridors. Table 3-40 lists the wild and scenic rivers 

in the Forest and the acres in each management category (wild, scenic, or recreation) where invasive 

plants have been inventoried. Tables 3-44 and 3-45 describe the inventoried areas (1,465.5 acres) 

within wild and scenic river corridors in the Forest that would be treated for invasive plants in the 

Proposed Action and the Reduced Herbicide Use Alternative. 

Table 3-40: Wild and Scenic River Segments and Acres by Management Category within the 

Administrative Boundaries of the Mt. Hood National Forest. 

River Segment 

Mt. Hood 

National Forest 

Acres 

Other 

Ownership Total Acres 

Clackamas National Recreation River 8,640 0 8,640 

Clackamas National Scenic River 6,400 0 6,400 

Roaring National Recreation River 64 0 64 

Roaring National Wild River 4,320 0 4,320 

Salmon National Recreation River 3,360 0 3,360 

Salmon National Wild River 4,800 0 4,800 

Sandy National Wild River 1,440 0 1,440 

White National Recreation River 4,992 0 4,992 

White National Scenic River 2,080 0 2,080 

Total Acres 36,096 0 36,096 

The intent of the 1968 Wild and Scenic Rivers Act is to maintain the free-flowing character of the 

designated rivers and to protect their “outstandingly remarkable values.” Outstandingly remarkable 

values (ORV) are values or opportunities in a river corridor which are directly related to the river and 

which are rare, unique, or exemplary from a regional or national perspective. The ORV’s for the five 

wild and scenic rivers in the Forest are identified in Table 3-41. Detailed descriptions of the rivers and 

their outstandingly remarkable values are documented in the following management plans which are 

posted on the Forest website (http://www.fs.fed.us/r6/mthood/publications/): 

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Site-Specific Invasive Plant Treatments 

• Clackamas National Wild and Scenic River and State Scenic Waterway. Environmental 

Assessment and Management Plan. (USDA Forest Service, 1992) 

• Roaring National Wild and Scenic River. Environmental Assessment and Management Plan. 

(USDA Forest Service, 1993b) 

• Salmon National Wild and Scenic River. Management Plan. (USDA Forest Service, 1993c) 

• Upper Sandy National Wild and Scenic River. Management Plan. (USDA Forest Service, 

1994a) 

• White River National Wild and Scenic River. Management Plan. (USDA Forest Service, 

1994b) 

Table 3-41: Outstandingly Remarkable Values (ORV) for the Wild and Scenic Rivers in the 

Mt. Hood National Forest. 

ORV 

Clackamas 

River 

Roaring 

River 

Salmon 

River 

Sandy 

River 

White 

River 

Botany/Ecology X X X X X 

Cultural Resources X X 

Fisheries X X X X X 

Geology X X 

Hydrology X X 

Recreation X X X X X 

Scenery X X X X 

Water Quality X 

Wildlife Habitat X X X X 

Wilderness 

The 1964 Wilderness Act established the National Wilderness Preservation System to ensure that 

parts of the United States would be preserved and protected in their natural condition. A wilderness 

area is defined, in part, as an area which generally appears to have been affected primarily by the 

forces of nature, with the imprint of man’s work substantially unnoticeable. The Wilderness Act 

places responsibility upon the administering agency for preserving the wilderness character of the 

area. 

There are five wilderness areas that are entirely within the Forest (Badger Creek, Bull of the Woods, 

Mark O. Hatfield, Mt. Hood, and Salmon-Huckleberry) and a portion of one other wilderness area in 

the Forest (Mt. Jefferson). Table 3-42 shows the number of acres of each of the Wilderness areas in 

the Forest. Since trails are a primary pathway for the introduction and spread of invasive plants in 

wilderness, the miles of trail (in the Forest) for each wilderness are also shown. 

Invasive plant species have been inventoried only in the Mt. Hood Wilderness. Three sites, totaling 

15.3 acres, have been inventoried. A 3.7 acre site (Treatment ID 69-028) is in a meadow along Burnt 

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Final Environmental Impact Statement 

Lake trail (Trail #772). A 9.8 acre site (portion of treatment ID 66-003) is along McGee Creek trail 

(Trail #672). A 1.8 acre site (portion of treatment ID 66-005) is along the Pacific Crest National 

Scenic Trail (Trail #2000) near Lolo Pass. The EDRR of the Proposed Action and Reduced Herbicide 

Use Alternative could prompt treatment in other wilderness areas as well. 

Considering treating invasive plants in wilderness creates a management dilemma; it is usually not 

possible to both preserve natural conditions (treatment) and to also refrain from human manipulation 

(no treatment). A choice must usually be made to either preserve natural conditions by actively 

manipulating wilderness to manage invasive plants, or to keep wilderness free from intentional human 

manipulation and compromise natural conditions because of changes to the environment caused by 

invasive plants. Making this choice involves deciding upon the minimum requirement, which is 

whether or not management action is necessary in wilderness to preserve wilderness character. If it is 

decided that management action is warranted, then the minimum tool needed to implement treatment 

with the least adverse effects to the wilderness resource must be addressed (Hendee, 1990). 

Table 3-42: Land Area and Miles of Trail in the Six Wilderness Areas which are Entirely or 

Partially in the Mt. Hood National Forest 

Wilderness Total Acres 

Mt. Hood National 

Forest Acres Miles of Trail 1

Badger Creek 24,000 24,000 62 

Bull of the Woods 27,427 27,427 56 

Mark O. Hatfield 39,000 39,000 90 

Mt. Hood 47,160 47,160 106 

Mt. Jefferson 107,008 5,021 3 

Salmon-Huckleberry 44,600 44,600 54 

Total 289,195 187,208 371 

1

 Indicates miles of trail within the boundaries of the wilderness in the Mt. Hood National Forest 

Scenery Management 

Beautiful scenery may be the benefit enjoyed by the largest number of people who visit the Forest and 

Scenic Area. The visual resources of the Forest attract tourists from all parts of the nation, as well as 

nearby residents. The sheer beauty of the Forest is a significant part of the region’s human 

environment. There is always a dynamic tension between the need to actively manage National Forest 

System lands and the desire by citizens to view naturally appearing landscapes. 

Sightseeing and visiting sites of interest are important and rapidly growing outdoor recreation pursuits 

in the United States (Cordell, 1999). Cordell projected the number of sightseers in the Pacific Coast 

region to increase by 87 percent between the years 1995 and 2050. For the same time period, the 

number of trips and the number of days spent sightseeing are projected to increase by 138 percent and 

159 percent, respectively. 

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Site-Specific Invasive Plant Treatments 

Recent visitor sampling by both the Forest (2003) and the Scenic Area (2000) generated some 

statistics about the popularity of driving for pleasure and viewing scenery in the areas. Table 3-43 

shows selected statistics from the National Visitor Use Monitoring Reports for the Forest (Kocis et 

al., 2004) and the Scenic Area (Kocis et al., 2001). Visitors in both survey areas were asked about 

their satisfaction with the scenery they saw during their visit, and about how important this feature 

was to them. Overall, visitors to the Forest rated scenery as 4.8 (on a scale of 1 – 5; 4 = good, 

satisfied; 5 = very good, very satisfied). The mean importance rating for the Forest visitors was 4.5 

(on a scale of 1-5; 4 = important; 5 = very important). Overall, visitors to the Scenic Area also rated 

the scenery as 4.8. The mean importance rating for Scenic Area visitors was 4.9. 

Table 3-43: Measurement of People Viewing Scenery in the Forest (measured in 2003) and 

Scenic Area (measured in 2000). Source: National Visitor Use Monitoring (Kocis et al., 2001 and 

Kocis et al., 2004). Statistics with an * are among the top five activities in which respondents 

participated. Columbia River Gorge National Scenic Area statistics include participants in 

Washington State as well as Oregon.

Unit of Measure 

Mt. Hood National 

Forest (2003) 

Columbia River Gorge 

National Scenic Area 

(2001) 

Number of National Forest Visits 4,076,119 1,992,881 

Number of People (and %) Who 

Participated in “Driving for Pleasure” 

during National Forest Visit 

1,227,727 (30%)* 936,654 (47%)* 

Number of People (and %) Who 

Reporting “Driving for Pleasure” as Their 

Primary Activity during National Forest 

Visit 

155,300 (4%) 99,644 (5%)* 

Number of People (and %) Who 

Participated in “Viewing Scenery” during 

National Forest Visit 

2,433,851 (60%)* 757,295 (38%) 

Number of People (and %) Who 

Reporting “Viewing Scenery” as Their 

Primary Activity during National Forest 

Visit 

346,877 (9%)* 239,146 (12%)* 

Protecting or enhancing scenic integrity is one of the purposes for the management of the Scenic 

Area. The Scenic Area Management Plan (2004) divides Gorge lands into either General 

Management Area (GMA) or Special Management Area (SMA). Scenic standards, derived from the 

Forest Service Scenery Management System (SMS), differ for the two areas. The Plan also identifies 

22 key viewing areas from which the public can view Scenic Area landscapes. Key viewing areas 

from which the Oregon portion of the Scenic Area can be viewed are: 

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Final Environmental Impact Statement 

• Beacon Rock • Multnomah Falls 

• Bonneville Dam Visitor • Oregon Highway 35 

• Bridal Veil State Park • Pacific Crest Trail 

• Cape Horn • Panorama Point Park 

• Columbia River • Portland Women’s Forum State Park 

• Cook-Underwood Road • Rooster Rock State Park 

• Crown Point • Rowena Plateau and Nature Conservancy 

• Dog Mountain Trail • Sandy River 

• Historic Columbia River • Sherrard Point on Larch Mountain (SMA only) 

• Interstate 84, including rest • Washington State Route 14 

• Klickitat County Road 123 • Washington State Route 141 

• Larch Mountain • Washington State Route 142 

• Larch Mountain Road (SMA • Wyeth Bench Road (SMA only) 

Table 3-44 lists the landscape setting, land use designation, and scenic standards for the seven 

inventoried invasive plant sites in the Scenic Area. The landscape setting is the combination of land 

use, landform, and vegetation patterns that distinguish an area in appearance and character from other 

portions of the Scenic Area. Land use designation is the zoning allocation. 

Forest visual quality was inventoried in 1973 (and updated in 1983) using the Visual Management 

System which predates SMS. The Forest Plan FEIS categorizes the results of the inventory according 

to variety class, sensitivity level, distance zones, and visual condition (USDA Forest Service, 1990a). 

The Forest Plan prescribes visual quality objectives (VQO) to be achieved within various scenic 

viewsheds, the area which can be viewed from a particular vantage point such as a roadway, trail, or 

recreation area. The sensitivity levels of the viewsheds are based primarily on the volume and type of 

traffic at the vantage point (i.e. how critical is a viewer likely to be to changes in the landscape). 

Level I (Primary) viewsheds are considered the most important; they have VQO’s of “Retention” 

(equivalent to “High” scenic integrity objective, and “Not Visually Evident” scenic standard in SMS) 

or “Partial Retention” (equivalent to “Moderate” scenic integrity objective, and “Visually 

Subordinate” scenic standard in SMS). 

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Site-Specific Invasive Plant Treatments 

Table 3-44: Landscape Settings, Land Use Designations, and Scenic Standards for Invasive 

Plant Sites in the Scenic Area. 

Treatment 

ID Location 

GMA/ 

SMA 

Landscape 

Setting 

Land Use 

Designation Scenic Standard 

22-01 Sandy River 

Delta 

SMA River Bottomlands;

River Bottomlands 

Open Space; 

Public 

Recreation 

Not Visually Evident; 

Visually Subordinate 

22-05 Wyeth SMA Coniferous 

Woodland 

Forest/Public 

Recreation 

Visually Subordinate 

22-07 Wells Island SMA River Bottomlands Open Space Not Visually Evident 

22-08 East Pit GMA Oak Woodland Public 

Recreation 

Visually Subordinate 

22-11 Rowena Dell/ 

Rowena 

SMA Oak Woodland; 

Residential 

Open Space; 

Residential 

Not Visually Evident; 

Visually Subordinate 

22-12 Chenoweth 

Table 

SMA Oak Woodland; 

Oak Woodland 

Open Space; 

Agriculture 

Not Visually Evident; 

Visually Subordinate 

22-12 Sevenmile Hill SMA Gorge Walls/ 

Canyonlands; 

Oak Woodlands; 

Pastoral 

Agriculture/ 

Open Space; 

Agriculture; 

Agriculture 

Not Visually Evident; 

Visually Subordinate; 

Visually Subordinate 

22-17 Corbett SMA Coniferous 

Woodland; 

Coniferous 

Woodland; 

Pastoral 

Open Space; 

Public 

Recreation; 

Agriculture 

Not Visually Evident; 

Visually Subordinate; 

Visually Subordinate 

Seventy-nine inventoried invasive plant sites in the Forest (approximately 3,404 acres) are either 

wholly or partially in Level I viewsheds. The most sensitive of these are the sites along Oregon 

Highways 26 and 35 (Mt. Hood Scenic Byway) and Oregon Highway 224 (West Cascades Scenic 

Byway) where the VQO is “Retention.” There are also numerous inventoried invasive plant sites in 

Level II scenic viewsheds which also have visual quality objectives of either Retention or Partial 

Retention. Portions of 38 sites, totaling 1,023 acres, have a VQO of Retention. Portions of 44 sites 

(1,113 acres) have a VQO of partial retention. 

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Final Environmental Impact Statement 

3.12.2 Effects to Congressionally Designated Areas 

Direct/Indirect Effects 

Wild & Scenic Rivers 

The 1,465.5 acres of invasive plants in Wild and Scenic River corridors would not be treated in the 

No Action Alternative. This alternative would potentially harm the ecological, fisheries, recreation, 

scenic, and wildlife habitat ORV in the Wild and Scenic River corridors in the Forest. In the long-run, 

uncontrolled growth of invasive species would reduce species diversity and possibly even result in the 

local elimination of some native plant species (for more information, see Section 3.6 – Botany and 

Treatment Effectiveness). Animals dependent upon native plant species would be negatively affected 

(for more information, see Section 3.11 – Wildlife). Losses of macroinvertibrates which depend upon 

native plant species would negatively affect fisheries (for more information, see Section 3.10 – 

Aquatic Organisms and Habitat). The dense growth of some species, such as knotweed species, may 

occupy and eliminate streamside fishing spots and block boat launching sites. The scenic pattern, 

form, and texture of open areas and the forest understory would be altered, and scenic integrity would 

be reduced in the long-run. In both action alternatives, effects would be more favorable than the No 

Action Alternative. 

Aggressive action proposed to control or eradicate invasive species in the Proposed Action would 

enhance ecological, fisheries, recreation, scenery, and wildlife habitat ORV’s in the long-run. By 

maintaining native plant diversity, wildlife and fisheries habitats would benefit (see Section 3.11 – 

Wildlife and Section 3.10 – Aquatic Organisms and Habitat). Since herbicides are the most effective 

way of treating knotweeds which aggressively colonize along streams (see Section 3.6.2), the Proposed 

Action offers the best chance of preserving fishing and boating access. As described in the existing 

conditions section, all of the rivers, except the Clackamas River, have outstandingly remarkable scenic 

values. The short-term effects to scenic quality would be negative due to slight alterations in the 

characteristic landscape. Of the four primary landscape elements (line, form, color, texture), color 

would be altered most by the Proposed Action. All but 0.2 acres would be primarily treated with 

herbicides (mostly applied by broadcast herbicide applications). The unusual concentrations of dead or 

dying plants may be evident and unattractive to some people. About 700 acres would be actively 

restored, slightly altering the landscape texture for a brief period. The minor short-term negative effects 

(even in the immediate foreground) would last for one growing season, and the positive long-term 

effect of treatment would be restoration of the natural landscape character. Additional information may 

be found in Section 3.12.3 which describes effects to scenic integrity. 

Table 3-45 describes the areas (1,465.5 acres) within wild and scenic river corridors in the Forest that 

would be treated for invasive plants in the Proposed Action. 

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Site-Specific Invasive Plant Treatments 

Table 3-45: Proposed Action treatment sites in Wild and Scenic River corridors in the Forest. 

(Treatment: h = herbicide, mmh = manual, mechanical, and herbicide. Primary method: inject = 

herbicide injection, broadcast = herbicide application by boom spraying, mow = mechanical owing. 

Active and passive restoration methods are described in Section 2.1.3 of this document.)

River 

Segment 

Type Acres 

# of 

Sites

Site 

Description Treatment Method Priority Restoration

Clackamas Scenic 1.5 2 Road h inject 1 Active 

Clackamas Scenic 189.2 4 Road mmh broadcast 3 Passive 

Clackamas Scenic 0.1 1 Admin mmh broadcast 3 Passive 

Clackamas Recreational 167.2 2 Road mmh broadcast 1 Active 

Clackamas Recreational 484.7 2 Road mmh broadcast 3 Passive 

Roaring Wild 5.0 1 Road mmh broadcast 1 Active 

Salmon Wild 0.6 1 Road mmh broadcast 3 Passive 

Salmon Recreational 70.7 1 

Utility 

Corridor mmh broadcast 2 Active 

Salmon Recreational 0.9 1 Road mmh broadcast 3 Passive 

Salmon Recreational 60.3 1 Road mmh broadcast 4 Passive 

Salmon Recreational 0.2 1 Road mm mow 3 Passive 

Sandy Recreational 157.0 1 

Recreation 

Residences mmh broadcast 1 Active 

White Scenic 0.1 1 Road mmh broadcast 3 Passive 

White Recreational 9.1 2 Quarry mmh broadcast 2 Active 

White Recreational 68.6 1 

Utility 

Corridor mmh broadcast 2 Active 

White Recreational 120.2 1 Campground mmh broadcast 2 Active 

White Recreational 0.2 1 Pullout mmh broadcast 2 Active 

White Recreational 100.4 1 Road mmh broadcast 2 Active 

White Recreational 29.4 1 Road mmh broadcast 3 Passive 

The same areas in wild and scenic river corridors in the Forest would be treated for invasive plants in 

the Restricted Herbicide Use Alternative; however fewer acres would be treated with herbicides 

(Table 3-46). Because the probability of controlling invasive plants is lower without herbicides, 

protection or enhancement of ORV’s would take more time and effort, and in the case of knotweeds, 

may not be achieved. Manual or mechanical treatment of knotweed species would not be very 

effective at preserving fishing and boating access (see Section 3.6.2). 

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Final Environmental Impact Statement 

Table 3-46: Restricted Herbicide Use Alternative treatment sites in Wild and Scenic River 

corridors in the Forest. (Treatment: h = herbicide, mmh = manual, mechanical, and herbicide, mm 

= manual and mechanical. Primary method: inject = herbicide injection, backpack = herbicide 

application by backpack sprayer, mow = mechanical mowing. Active and passive restoration 

methods are described in Section 2.1.3 of this document.)

River 

Segment 

Type Acres 

# of 

Sites

Site 

Description Treatment Method Priority Restoration

Clackamas Scenic 1.5 2 Road c inject 1 Active 

Clackamas Scenic 189.2 3 Road mm mow 3 Passive 

Clackamas Scenic 0.1 1 Admin mm mow 3 Passive 

Clackamas Recreational 167.2 2 Road mmh backpack 1 Active 

Clackamas Recreational 484.7 2 Road mm mow 3 Passive 

Roaring Wild 5.0 1 Road mmh backpack 1 Active 

Salmon Wild 0.6 1 Road mm mow 3 Passive 

Salmon Recreational 70.7 1 

Utility 

Corridor mm mow 2 Active 

Salmon Recreational 0.9 1 Road mm mow 3 Passive 

Salmon Recreational 60.3 1 Road mm mow 4 Passive 

Salmon Recreational 0.2 1 Road mm mow 3 Passive 

Sandy Recreational 157.0 1 

Recreation 

Residence mmh backpack 1 Active 

White Scenic 0.1 1 Road mm mow 3 Passive 

White Recreational 9.1 2 Quarry mm mow 2 Active 

White Recreational 68.6 1 

Utility 

Corridor mm mow 2 Active 

White Recreational 120.2 1 Campground mm mow 2 Active 

White Recreational 0.2 1 Pullout mm mow 2 Active 

White Recreational 100.4 1 Road mm mow 2 Active 

White Recreational 29.4 1 Road mm mow 3 Passive 

Since most sites in the Reduced Herbicide Use Alternative would be treated primarily by mechanical 

mowing (1,134.8 acres), the texture of the scenic fabric in these areas would be temporarily altered. 

Treatment would be evident and unattractive to some people. Active restoration on 700 acres would 

briefly extend the period during which the landscape texture would appear modified. For the 330.7 

acres treated primarily by herbicides, effects similar to those described for the Proposed Action would 

occur. The long-term effect of treatments would be positive because of the restoration of the 

characteristic landscapes. Additional discussion of effects to scenic integrity may be found in Section 

3.12.3. 

Neither the Proposed Action nor the Restricted Herbicide Use Alternative would physically alter river 

banks or channels. Treatment would not cause logs or other large woody debris to enter the rivers. 

The free-flowing character of the wild and scenic rivers would not be affected. A discussion of the 

effects to water quality is found in Section 3.9. Cultural resources, geology, and hydrology ORV’s 

would be largely unaffected by any of the alternatives. 

3-236
Site-Specific Invasive Plant Treatments 

Wilderness 

Negative effects from No Action and the continued presence and expansion of orange hawkweed in 

the Mt. Hood Wilderness would include changes to the natural conditions and processes expected in 

wilderness. Left untreated, the hawkweed populations are predicted to double in size every six to 

seven years. The orange hawkweed plants would alter the meadow community along Burnt Lake 

Trail, interact in unknown ways with native wildlife species, and alter ecological processes such as 

plant community dynamics and disturbance processes (for more information, see Section 3.6.2, 

Effects on Native Plant Communities). Some visitors’ experiences may be diminished if they are 

aware that orange hawkweed is not a native plant. Taking no action avoids human manipulation of 

wilderness, but natural conditions would not be restored. 

If the No Action Alternative is selected, no herbicides from this project would be introduced into the 

Mt. Hood Wilderness ecosystem. There would be no risk of herbicide effects to non-target species. 

Ecosystem adaptations to invasive plants would be free from human interference. Effects of invasive 

plants would be determined by competitive and other interactions. Wilderness would remain freer 

from management in the No Action Alternative than in either of the action alternatives. 

With the No Action Alternative, localized changes would occur to natural conditions and processes 

that are expected in a wilderness setting, which would result in a loss or reduction in the sense that the 

Mt. Hood Wilderness is a predominately natural place. By rejecting treatment, the loss of natural 

conditions, native species, and natural ecosystem processes would be minor and localized in the shortrun. In several decades, these effects would become quite pronounced. Also, the Mt. Hood Wilderness 

could become a haven of invasive plants and a source of seed to spread to surrounding lands, both 

National Forest System lands and other ownerships. 

There are three sites (15.3 acres) in the Mt. Hood Wilderness that would be treated with herbicides in 

both the Proposed Action and the Restricted Herbicide Use Alternatives. The target plant is orange 

hawkweed. Since these are “Priority 1” sites, the prescribed treatment is the same in both the 

Proposed Action and Restricted Herbicide Use Alternatives: clopyralid or picloram applied by 

backpack sprayer (aqueous glyphosate for aquatic influence zones) with active restoration. Treatment 

with herbicides was determined to be the minimum requirement for both action alternatives because 

there is concern that the hawkweed populations may expand to landscape scale, displace native 

species, and alter ecosystem processes and because manual control methods are not very successful 

against orange hawkweed (for more information, see Section 3.6.2 – Botany and Treatment 

Effectiveness). Because herbicides would be spot-sprayed, unintended effects to species other than 

orange hawkweed would be negligible. 

Implementing either the Proposed Action or the Reduced Herbicide Use Alternative would protect 

natural conditions, however human manipulation of the wilderness environment is required to do so. 

Treatment would interfere with ecological dynamics between the native plant communities and the 

introduced invasive plants, affecting the sense that the wilderness is free from human manipulation. 

3-237 
Final Environmental Impact Statement 

Because the Burnt Lake and Pacific Crest, and McGee Creek Trails are popular, a few wilderness 

visitors may observe treatment activities or see the effects of treatment. Even small-scale, localized 

control methods require crews and activity that would be evident to a few visitors. Immediately after 

treatment, unusual concentrations of dead or dying vegetation may be seen along short sections of the 

Burnt Lake, Pacific Crest, and McGee Creek Trails. Active restoration would accelerate the return to 

a natural landscape, and minimize the time that the treatment would be evident (approximately one 

growing season). However, such evidence of treatment activities would add to the sense that the Mt. 

Hood Wilderness is not a place free from human manipulation. Because of snow conditions at the 

elevation of these trails, the effects of treatments would only be visible for about five months each 

year. 

The action alternatives favor species that are native to wilderness. Orange hawkweed would be less 

likely to alter natural plant communities, interact in unknown ways with native wildlife species, or 

alter ecological processes such as plant community dynamics and disturbance processes such as fire. 

The sense that wilderness is a predominately natural place would be enhanced. Also, wilderness 

would be less likely to be viewed as a source of invasive plants that threaten surrounding, nonwilderness lands. 

Early Detection/Rapid Response Strategy 

It is possible that some newly detected invasive plants in wild and scenic river corridors may be 

accessible only by boat. This would be the only physical effect on the rivers from EDRR. Otherwise, 

treating additional acres in wild and scenic river corridors would have the same minor short-term 

effects and the same long-term positive effects as described earlier. 

For wilderness, the response to the EDRR of new invasive plant populations would be determined 

through a site-specific minimum requirements analysis. No Action would be favored where an 

invasive plant is unlikely to displace native species or to alter ecological processes. Direct action 

would be initiated when it is determined that an invasive plant species has the ability to expand to 

landscape scale, displace native species, or to alter ecosystem processes. If new invasive plant 

populations expand to landscape scale, or if the new invasive plants displace native species and alter 

ecosystem processes, then wilderness character would be at risk. Under these circumstances, rapid 

response treatment would likely be implemented. If action is determined to be the minimum 

requirement, then manual treatment would be preferable if the invasive plant species is responsive to 

manual control, and if manual control treatments could be implemented in a timely manner and could 

be repeated as needed. Use of herbicides would be preferable if the invasive plant species is not 

responsive to manual control methods or if manual control methods are unlikely to be successful. 

The effects of EDRR would be similar to the effects described for the treatment of the three known 

populations of orange hawkweed in the Mt. Hood Wilderness. Early detection of small new 

population centers may require fewer follow-up treatments and less effect to the wilderness resource. 

3-238
Site-Specific Invasive Plant Treatments 

Cumulative Effects 

The affected area analyzed for cumulative effects to wild and scenic rivers and wilderness are the 

rivers and wilderness areas in the Forest. The timeframe considered was the span of this project 

(approximately 15 years). The only other likely foreseeable vegetation management treatment in wild 

and scenic river corridors is hazard tree removal along roadways. Ordinarily, individual tree removal 

is not evident to forest visitors, and has undetectable environmental effects. 

The removal of aggraded sediment at the State Hwy 35 bridge across White River is required every 

few years. While noticeable to motorists on the highway, effects of this action are seasonal, localized, 

and attributed more to the bridge structure than to the river environment. 

Outfitters and guides are authorized to lead whitewater trips on the Clackamas River during spring 

and early summer. Recreation is one of the outstandingly remarkable values of the Clackamas, and 

this activity is compatible with the management direction for the river. 

Cumulatively, these actions would not significantly affect the free-flowing nature of the rivers or 

negatively affect outstandingly remarkable values. The scenic integrity of the wild and scenic river 

corridors would not be reduced. 

Trail reconstruction is being studied for the Burnt Lake Trail within the Mt. Hood Wilderness in this 

decade. One of the objectives of reconstruction is to move about two miles of the trail out of sensitive 

areas; the effects to wilderness resulting from this action are expected to be positive. There would be 

minor cumulative effects with the treatment of orange hawkweed which is also proposed for this trail. 

If the actions overlap in time, then the effects of treating the hawkweed would likely be cloaked by 

the trail project. If the projects do not overlap, then wilderness visitors would notice minor 

disturbances along the trail for a longer period of time. Both projects would have positive long-term 

effects on the wilderness resource. 

Trail reconstruction is also anticipated on The Timberline Trail between Cloud Cap and Elk Cove 

(Mt. Hood Wilderness), and the Bagby Trail north of Elk Lake (Bull of the Woods Wilderness) in this 

decade. The Timberline Trail connects to the Pacific Crest Trail, so it is possible that a hiker might be 

witness to both trail reconstruction and invasive plant treatments in the same trip (but not on the same 

day). The trail gets a lot of use, a condition that is more likely to negatively affect wilderness visitors 

than the resource treatments. Use of the Bagby Trail would likely be significantly separated in both 

time and space from visitor observations of invasive plant treatments; wilderness users would be 

unlikely to detect a cumulative effect to wilderness conditions in the Mt. Hood National Forest. Also, 

all long-term effects would be positive. 

3-239 
Final Environmental Impact Statement 

3.12.3 Effects to Scenic Integrity 

Direct/Indirect Effects 

It is likely that No Action would not keep up with the aggressive invasion by non-native species. 

Effects to scenic resources would include changing the landscape character in many areas to a 

homogeneous species composition in grassland areas and in the forest understory that is inconsistent 

with the valued landscape character. The No Action Alternative would not be sufficient to maintain 

the native grass species. Conditions necessary for continued regeneration of oak species may be 

altered (Carey, 2002). In the long-term, plant species diversity would be reduced. The continued 

spread of invasive species would increase the risk of large-scale wildfires of great intensity, reducing 

scenic stability significantly. Knotweed species may overtake riparian vegetation and river banks 

altering the scenic pattern, form and texture of open areas and the forest understory extensively. The 

scenic integrity would be reduced. 

Aggressive action proposed to control or eradicate invasive species (Proposed Action) would help 

sustain the landscape character with some short-term effects to scenic integrity. Patches of dead 

vegetation, including desirable species, for at least one growing season would be a short-term 

negative effect. The unnatural appearance of mowed and brushed areas seen from immediate 

foreground distances (300 feet) would also be a short-term negative effect. The sites along I-84, 

Historic Columbia River Highway, and Oregon Highways 26, 35 and 224 would be seen by a large 

number of viewers; however, the degree of discernable detail would be small. For example, the visual 

effects from cultural treatment (goat grazing) in the Sandy River Delta as seen from I-84 would not be 

noticable. The duration of view from travel corridors would vary. Many treatment areas stretch for 

miles along the sides of roads. Such treatments would be more noticeable; however, the effect would 

be short-term. 

Direct beneficial effects would include the limitation of invasive plant species in the viewshed, 

maintenance of diverse community of native grasses, forbs, and shrubs, and maintenance of 

conditions consistent with the ecological setting that supports the desired landscape character, a 

mosaic of forested canopy and grassland openings. The Proposed Action would meet the existing 

visual quality objectives and be beneficial to the landscape character by reducing risks of altered plant 

species composition and related effects. The scenic integrity and scenic stability would be maintained. 

In the Restricted Herbicide Use Alternative, limiting usage of herbicides to Priority 1 sites and 

minimizing broadcast herbicide application methods would lessen short-term negative effects to 

scenic integrity. Other herbicide application methods, such as backpack spraying and injection, could 

more precisely target invasive plants, leaving more native vegetation unharmed, reducing the negative 

effects to scenic integrity. This alternative’s greater reliance upon manual and mechanical treatment 

methods (compared to the Proposed Action) which are less effective at controlling some invasive 

plant species, however, would increase both short-term and long-term negative effects. The unnatural 

appearance of mowed and brushed areas seen from immediate foreground distances, (300 feet) would 

be a short-term negative effect. Moreover, if invasive species are not controlled because of a heavier 

reliance upon less effective treatment methods, scenic integrity and scenic stability would be reduced 

in the long-term. Direct beneficial effects of this alternative would be the same as those for the 

Proposed Action, however to a lesser extent. 

3-240
Site-Specific Invasive Plant Treatments 

Early Detection / Rapid Response Strategy 

Treating newly-discovered populations of invasive species would not reduce scenic integrity. The 

visual absorption capacity in virtually all areas of the Forest, and especially in the Scenic Area is great 

enough to tolerate herbicide, manual, and mechanical treatments on 30,000 acres over 15 years 

without loss of landscape character or scenic integrity. 

Cumulative Effects 

No cumulative effects are expected from the proposed invasive plant treatments. 

3.12.4 Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action and 

Restricted Herbicide Use Alternatives are consistent with all relevant standards and guidelines, when 

the proposed amendments are incorporated. The Forest Plan amendments are discussed in Section 

3.16. 

3.12.5 Incomplete and Unavailable Information 

Congressionally Designated Areas 

The analysis of direct effects in wilderness is based on the dynamic tension between people who 

believe that it is more important for wilderness to remain free from management and people who 

believe that protecting natural conditions is more important. There is no data about either the absolute 

or the relative number of people who hold these views. There is also no quantitative information 

about the number of people who would likely observe treatment activities or see the effects of 

treatments. 

Scenic Integrity 

There is also no quantitative information about the number of people who would likely observe 

treatment activities or see the effects of treatments.

3-241 
Final Environmental Impact Statement 

3.13. Heritage Resources 

3.13.1 Existing Conditions

Eradication or treatment of invasive plant species through the application of herbicides and manual 

treatments (including hand tools such as shovels) falls within the description of activities determined 

to have no potential to affect heritage resources as determined within the 2004 Programmatic 

Agreement between Pacific Northwest Region of the USDA Forest Service, the State Historic 

Preservation Office (SHPO), and the Advisory Council on Historic Preservation (ACHP) 

(Programmatic Agreement, Appendix C.2). (Programmatic Agreement is included as Appendix Y.) 

Impacts from the use of “weed wrenches” is similar in scale and extent to impacts from shovels, and 

the use of this tool also falls within the definition of activities with no potential to affect heritage 

resources. No heritage resource survey is required for these activities. 

Mowing or brushing to control vegetation, including invasive plant treatments, has also been 

determined within the agreement to have no potential to affect heritage resources (Programmatic 

Agreement, Appendix C.5). No heritage resource survey is required for these activities. 

The proposed project includes two identified traditional gathering areas and six potential gathering 

areas containing plants that have a cultural significance to Native American peoples. Other areas with 

culturally significant plants are likely to be included within the remaining treatment areas. Culturally 

significant plants are collected and used as food, for medicine, or for ceremonies, and are important 

for American Indian lifestyles. An incomplete list of these plants in found in Table 3-47. 

Table 3-47: List of culturally significant plants likely to be found in proposed treatment areas. 

Common Name Scientific Name 

Blue Camas Camassia quamash 

Bitterroot Lewisia rediviva 

Wild Celery Lomatium nudicaule 

Biscuit Root Lomatium cous 

Canby’s Desert Parsley Lomatium canbyi 

Indian Carrot of False Caraway Perideridia gairdneri 

Field Mint Mentha arvensis 

Choke Cherry Punus demissa 

Blue Huckleberry Vaccinium species

Black Lichen Alectoria species 

Bear Grass Xerophyllum tenax

Especially important among the culturally significant plants are the camas, huckleberry and bitterroot. 

The plant species targeted for treatment (Table 2-3) do not include any plants identified for cultural 

uses. However, while the herbicides proposed for use are designed to target invasive plants, many 

have the potential to effect broadleaf varieties and grasses, including cultural plants (See Section 3-6 

– Botany and Treatment Effectiveness). 

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Site-Specific Invasive Plant Treatments 

Restoration of the treated areas is also proposed under each alternative. Restoration would consist of 

reseeding and/or planting. Reseeding would be accomplished using either hand spreaders or hydroseeders. The ground surface would be scarified using a rake or other hand tool. Saplings or small 

foliage would be planted using shovels, hoedads, or other hand tools (See Section 2.1.3 for more 

information on proposed restoration). Restoration using hand tools within previously disturbed 

ground falls within the description of activities determined to have little or no potential to affect 

heritage resources as determined within the 2004 Programmatic Agreement (PA) (Programmatic 

Agreement, Appendix A.1). Seeding by hand or spray has also been determined within the agreement 

to have no effect on heritage resources (Programmatic Agreement, Appendix C.1). No heritage 

resource surveys are required for these activities. 

Laws, Regulations and Policy 

The National Historic Preservation Act (NHPA) of 1966, as amended: This Act requires Federal 

agencies to consult with American Indian Tribes, state and local groups before nonrenewable heritage 

resources, such as archaeological and historic structures, are damaged or destroyed. Section 106 of 

this act requires federal agencies to review the effects project proposals may have on the heritage 

resources in the analysis area. 

36 CFR Part 800 – Protection of Historic Properties: (a) Purposes of the Section 106 process. Section 

106 of the National Historic Preservation Act requires Federal agencies to take into account the 

effects of their undertakings on historic properties and afford the Council a reasonable opportunity to 

comment on such undertakings. The procedures in this part define how Federal agencies meet these 

statutory responsibilities. The Section 106 process seeks to accommodate historic preservation 

through consultation among the agency official and other parties with an interest in the effects of the 

undertaking on historic properties, commencing at the early stages of project planning. The goal of 

consultation is to identify historic properties potentially affected by the undertaking, assess its effects 

and seek ways to avoid, minimize or mitigate any adverse effects on historic properties. 

3.13.2 Direct/Indirect Effects 

Alternative 1 – No Action 

Invasive plants treatments occur across the Forest and Scenic Area on a smaller scale, as previously 

analyzed and approved activities. Under Alternative 1, no additional treatments for invasive plants are 

proposed beyond those activities occurring under existing NEPA. There would be no effect under 

Alternative 1 to heritage resources other than the natural processes that are already occurring. 

However, the lack of any additional treatments could result in the proliferation of invasive plant 

species, which may compete with culturally significant plants. The potential exists for culturally 

significant plants to be adversely affected under Alternative 1. 

3-243 
Final Environmental Impact Statement 

Alternatives 2 &3 – Proposed Action and Restricted Herbicide Use Alternatives 

Under these alternatives, a combination of herbicide, mechanical (mowing and brushing), manual 

(hand tools), and cultural (goat grazing) treatments would be applied. These treatment methods are 

described in Table 2-2. As previously discussed, the application of herbicides, mowing and brushing, 

and the use of hand tools for the eradication of invasive plant species would have no effect on 

heritage resources. 

The effects of goat grazing within the Scenic Area were previously analyzed under Alternative 5 in 

the Final Environmental Impact Statement for the Sandy River Delta Plan (Chapter 4-42, USDA 

Forest Service, 1995a). On December 22, 1994 the Oregon SHPO concurred with the finding that the 

alternative would cause “no adverse effect” to cultural resources. The Sandy River Delta Plan (Page 

48, USDA Forest Service, 1995b) includes livestock grazing with mitigation measures (as described 

in Alternative 5) and is the current management guideline for this area. No further analysis was 

conducted on the use of goat grazing for this EIS. 

Although the list of herbicides proposed for treating invasive plant species are not designed to target 

plants desirable to Native American peoples, many of the proposed herbicides have the potential to 

affect other broadleaf plants and grasses, including culturally significant plants. Spot spraying or 

selective/hand methods may be employed if necessary to limit unwanted spray drift. PDC and label 

restrictions limiting nozzle pressure and spray, and restricting herbicide application during high winds 

or expected precipitation would also limit unwanted spray drift and spread. 

The Confederated Tribes of Warm Springs (CTWS), the Yakima Nation, the Confederated Tribes of 

the Grand Ronde, the Nez Perce Tribe, and the Confederated Tribes of the Umatilla Nation were 

consulted for concerns over potential effects to culturally significant plants. Tribal specialists from the 

CTWS agreed that any effects would be short-term, and eradicating or controlling the spread of 

invasive plants could potentially benefit desirable plant species. No modifications for proposed 

treatments were recommended by the Tribes. 

Restoration of the treated areas is also proposed under both alternatives. Restoration would consist of 

reseeding and/or planting. As previously discussed, the use of hand tools for scarifying, planting and 

seeding within previously disturbed ground would have no effect on heritage resource. 

3.13.3 Cumulative Effects 

Additional areas may be treated in the future as part of an EDRR. The EDRR would be designed to 

identify areas of newly inventoried invasive plant infestation and propose treatments for those areas. 

The application of mechanical, manual, or herbicide treatment methods as proposed under 

Alternatives 2 or 3 would have no potential to affect heritage resources. A cultural resource survey 

and consultation with the Oregon SHPO would not be required. 

Although the expected impacts from weed wrenches has been determined to be similar in extent to 

impacts expected from the use of shovels, the Forest and Scenic Area would ensure that 

archaeological sites are not impacted by any proposal to utilize a weed wrench. 

3-244
Site-Specific Invasive Plant Treatments 

As part of the continuing consultation process, the USDA Forest Service would meet annually with 

the Confederated Tribes of Warm Springs, Oregon to discuss treatment areas being proposed each 

year. Any tribal concerns over the effects of previous treatments and proposed treatments would be 

considered and may be incorporated into the design of future treatment projects. 

The quantity and quality of culturally significant plants have been declining through the years, due to 

encroaching vegetation. Invasive plant species have been contributing to the decline of these plants as 

they compete for sunlight, soil, nutrients and water. Continued treatment and suppression of invasive 

plants would reduce competition for the available resources and provide an opportunity for culturally 

significant plants to develop and spread. While there may be short-term effects to culturally 

significant plants, cumulative effects would be beneficial and restorative. The positive effects to 

native plants are discussed in more detail within Section 3.6 – Botany and Treatment Effectiveness. 

Any additional activities occurring or proposed with the potential to affect culturally significant plants 

were also considered for cumulative effects. These activities include grazing, timber harvest, 

underburning, quarry expansion, road obliteration or decommissioning, gathering of special forest 

products, watershed restoration, trail construction, reconstruction of parking areas, and off-highway 

vehicle (OHV) trails (Schedule of Proposed Actions, January to March 2006). Each of these activities 

was analyzed separately for environmental effects. None of these projects were found to impact 

known traditional gathering areas. Each project, however, has the potential for eliminating single 

plants or isolated pockets of culturally significant plants, with a short-term effect to reduce the overall 

populations of the plants. Grazing animals are likely to consume all edible plants. Any ground 

disturbing activities associated with timber harvest, quarry expansion, trail construction and 

reconstruction, and watershed restoration are likely to destroy plants. Road obliterations and 

decommissioning would probably destroy plants that have encroached into the open roadbeds. Other 

ground cover and brush would be consumed by low-temperature underburning. Off-highway vehicles 

are likely to destroy plants within and immediately adjacent to trails. 

While the overall populations of culturally significant plants may be reduced in the short-term, a net 

increase in plant populations would result over the long-term. Timber harvests have a tendency to 

open the forest canopy, allowing additional sunlight to reach the forest floor and benefit undergrowth, 

including culturally significant plants. When conditions are right, underburning could restore 

populations of huckleberries. As previously discussed, treatment of invasive plant species would also 

be beneficial and restorative to culturally significant plants. The cumulative effects of the proposed 

treatments on culturally significant plants are insignificant when compared with other activities 

occurring across the forests, especially when a long term net increase in those plants is anticipated. 

3.13.4 Management Standards and Guidelines 

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action and 

Restricted Herbicide Use Alternatives are consistent with all relevant standards and guidelines, when 

the proposed amendments are incorporated. The Forest Plan amendments are discussed in Section 

3.16. 

3-245 
Final Environmental Impact Statement 

3.13.5 Incomplete and Unavailable Information 

No inventory has been completed to determine if culturally significant plants are present in proposed 

treatment areas. 

3.14. Tribal Relations, Civil Rights and Environmental Justice 

3.14.1 Existing Condition 

Most of the people who would be directly affected by invasive plant treatments live close to the forest 

and either depend upon or simply visit the forest often. Many live in Multnomah, Clackamas, Hood 

River, and Wasco Counties. There are some individuals and distinct populations not living adjacent to 

the forest that may also be affected. The analysis focused on minority or low-income population 

groups of particular interest: Hispanics, Asians, and American Indians. A sizable number of 

individuals in these groups have a unique social and economic dependency upon the forest. Hispanic 

forestry workers do most of the manual labor to maintain Oregon’s National Forests. Hispanics and 

Asians do virtually all of the commercial harvesting of special forest product such as floral greens. 

Asian groups are particularly interested in wild mushroom harvesting for both personal and 

commercial use. American Indian Tribes have reserved treaty rights to hunt, fish, and gather plant 

materials in the areas proposed for treatment. 

The Forest and Scenic Area straddle the Cascade Mountains in northern Oregon. The two sides of the 

mountain range have different social and economic identities and characteristics. The eastside (Hood 

River and Wasco Counties) features a rural and dispersed human settlement and an economy that is 

highly dependent on agriculture (livestock, fruit tree cultivation). On the westside, there are also many 

rural communities and an agricultural component to the economy (landscape plant nurseries) adjacent 

to the Forest (Multnomah and Clackamas Counties). The social and economic landscape, however, is 

heavily influenced by the Portland metropolitan area, the region’s largest population center. 

Table 3-48 displays some pertinent data that help describe the social and economic landscape in the 

affected area. As Table 3-48 shows, persons of Hispanic or Latino origin comprise 25 percent of the 

population of Hood River County, an amount significantly higher than any of the other counties, 

Oregon, or the United States as a whole. In Multnomah and Clackamas Counties, Hispanics make up 

a smaller percentage of the population than for all of Oregon; however, there are still sizable, 

localized Hispanic communities (e.g. Woodburn, Oregon). The Asian population is sizable on the 

westside, especially in Multnomah County. On the eastside, however, it is fairly small. Percentage 

wise, the American Indian population in Multnomah and Clackamas Counties is below the Oregon 

average. In Wasco County, largely because of the Warm Springs Indian Reservation, American 

Indians make up a high percentage of the population compared to Oregon or the United States as a 

whole. 

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Site-Specific Invasive Plant Treatments 

Table 3-48: Selected Demographic Information for Multnomah, Clackamas, Hood River, and 

Wasco Counties, Oregon. Source: U.S. Census Bureau. 

People Quick Facts 

Multnomah 

County 

Clackamas 

County 

Hood 

River 

County 

Wasco 

County Oregon USA 

Population, 2004 estimates 672,161 363,276 21,155 23,669 3,594,586 293,655,404 

Population, % change 4/2000 

– 7/2004 

2% 7% 4% -1% 5% 4% 

Population, 2000 660,486 338,391 20,411 23.791 3,421,399 281,421,906 

White persons, %, 2000 1 79% 91% 79% 87% 87% 75% 

White persons not of 

Hispanic or Latino origin, %, 

2000 

77% 89% 71% 84% 84% 69% 

Persons of Hispanic or Latino 

origin, %, 2000 2

8% 5% 25% 9% 8% 13% 

Black or African American 

persons, %, 2000 1

6% 1% 1% 0% 2% 12% 

American Indian and Alaska 

Native persons, %, 2000 1

1% 1% 1% 4% 1% 1% 

Asian persons, %, 2000 6% 3% 2% 1% 3% 4% 

Native Hawaiian and Other 

Pacific Islander, %, 2000 1

0% 0% 0% 1% 0% 0% 

Persons reporting some other 

race, %, 2000 1

4% 2% 15% 6% 4% 6% 

Persons reporting two or 

more races, %, 2000 

4% 3% 3% 2% 3% 2% 

High School Graduates, % of 

persons age 25+, 2000 

86% 89% 78% 82% 85% 80% 

Median Household Income, 

1999 

$41,278 $52,080 $38,326 $35,959 $40,916 $41,994 

Persons Below Poverty, 2002 

estimates 

12% 8% 12% 13% 11% 12% 

Persons per square mile, 

2000 

1,518 181 39 10 36 80 

1

 Includes persons reporting only one race. 

2

 Hispanics may be of any race, so also are included in applicable race categories. 

Wasco County has the lowest household income and highest poverty rate among the jurisdictions 

compared in Table 3-48. Clackamas County has the highest household income and lowest poverty 

rate. Much of that affluence is concentrated in the southern part of the Portland metropolitan area 

(Lake Oswego, West Linn). Hood River County has the lowest percentage of high school graduates. 

3-247 
Final Environmental Impact Statement 

Jobs Created by Invasive Plant Treatments 

During the past century, Hispanic immigrants have done much of the agricultural labor in the western 

states (Gates and Crider, 2001). The National Agricultural Workers Survey of 1997-1998 reports that 

the typical worker tending and harvesting fruits, vegetables, nursery, field and other crops in the 

United States is young (2 out of 3 are under age 35); male (80 percent); Hispanic (90 percent, mostly 

from Mexico); poorly educated (median years of education is six); lack year-round employment; and 

low income (half of the workers earned less than $7,500 a year) (League of Women Voters, 2000). 

Latino forestry workers, who do most of the manual labor to maintain Oregon’s National Forests 

(including tree planting, pesticide application, thinning, and prescribed burning), are primarily 

Mexican immigrants (Sarathy, 2003). They constitute a non-unionized and seasonal workforce which, 

unlike Anglo forest workers from rural communities, travels throughout the Western United States to 

find employment in agriculture, non-timber forest products, tree planting, and fire fighting (Sarathy, 

2003). In 1997, 5 percent of Oregon workers and 18 percent of Latino Oregon workers were 

employed in Agriculture and Forestry (Gates and Crider, 2001). 

Most farm and forestry work is seasonal and temporary. Working conditions are often hard. Jobs can 

be in remote locations with workers housed in motels or in isolated camps. Compliance with 

minimum wage law by labor contractors varies. Non-English speaking workers, new immigrants, and 

those employed by unlicensed labor contractors may be underpaid. Unauthorized workers usually 

would not benefit from tax and social security deductions (League of Women Voters, 2000). Many 

work histories have included unsafe working conditions, and the employers have failed to take 

responsibility for the medical consequences of workplace accidents. Some workers have described the 

dangers of chemical exposure in the agriculture industry (Gates and Crider, 2001). Workers reported 

headaches, nausea, and dizziness after inhaling chemical fumes. One worker also reported a skin rash. 

Special Forest Products 

The Pacific Northwest may have the most diverse collection of forest workers in the world (Oregon 

Public Broadcasting, 2005). Wild mushroom harvesting is one of the most ethnically diverse forest 

products industries in the Pacific Northwest (Sarathy, 2003). This situation is driven by a changing 

(and increasingly global) economy, large populations of marginalized migrants, changing values 

toward resources, and growing demand for non-commodity uses of the environment. Research 

suggests that there is a growing tendency for recent immigrants (Hispanic and Asian) to see the 

products they remove from Northwest forests as sources of income, with less emphasis upon 

gathering for traditional subsistence products (Hansis, 1998). Native American tribes are also 

beginning to be interested in the economic potential of wild products such as mushrooms and 

huckleberries (Oregon Public Broadcasting, 2005). For example, wild berries, which perish quickly, 

can have considerable value added by converting them into jam for commercial sale, long shelf-life, 

and world-wide shipping. 

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Site-Specific Invasive Plant Treatments 

Workers may come to the forest from other parts of the region, particularly the Seattle/Tacoma 

metropolitan area. The project, therefore, would affect more than just the four counties surrounding 

the forest. A 1991 study of beargrass permits issued by the Gifford Pinchot National Forest revealed 

several findings about the demographics of permit holders and product gatherers. First, Latinos and 

Southeast Asians (Khmer, Khmer Krom, Laotian, and Vietnamese) were virtually the only permit 

holders. Second, most of the permit holders returned repeatedly to purchase additional permits. Third, 

permit holders emanated from only a few places. Southeast Asian permit holders were primarily from 

Tacoma and Aberdeen, Washington. Latino gatherers came mainly from Tacoma, Washington, and 

from the Hood River valley in Oregon. In the same study, it was found that most mushroom permit 

holders, both commercial and personal, on the Cowlitz Valley Ranger District in Randle were 

primarily of Khmer or Vietnamese origin, with a smaller number issued to people of Khmer Krom 

and Laotian origin (Hansis, 1998). 

During the 2003 National Visitor Use Monitoring (NVUM) project for the Forest (Kocis et al., 2004), 

forest visitors were asked whether or not they gathered forest products (mushrooms, berries, 

firewood, other) during their National Forest visit. Of the 4,076,119 visitors to the Forest during fiscal 

year 2003, 42,392 people (1.04 percent) reported that gathering forest products was their primary 

activity. In all, 137,365 said that they participated in gathering forest products, but for most it was not 

their primary activity. 

Treaty Rights 

The United States Government and the Tribes of Middle Oregon (Taih, Wyam, Tenino, and DockSpus Bands of the Walla-Walla, and the Dales, Ki-Gal-Twal-La, and the Dog River Bands of the 

Wasco), now part of the Confederated Tribes of the Warm Springs, entered into a treaty on June 25, 

1855 (ratified March 8, 1859). The Forest and Scenic Area east of the Cascade crest are lands ceded 

by the Tribes to the US Government according to that treaty. Article 1 of the treaty describes hunting, 

fishing, gathering, and pasturing rights in the ceded lands that were reserved by the Tribes: 

“. . . Provided, also, That the exclusive right of taking fish in the streams running 

through and bordering said reservation is hereby secured to said Indians; and at all 

other usual and accustomed stations, in common with citizens of the united States, 

and of erecting suitable housing for curing the same; also the privilege of hunting, 

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

common with citizens, is secured to them . . .” 

The Yakima, WallaWalla, Cayuse, Umatilla, Nez Perce, and Molala Tribes also entered into treaties 

with the US Government in 1855 (ratified 1959). Each treaty specified distinct lands to which rights, 

title, and claim were ceded to the United States. All treaties, except the Treaty with the Molala, 

include reserved treaty rights for hunting, fishing, and gathering. Wording in each treaty regarding the 

reserved rights are similar to the citation above from the Treaty with the Tribes of Middle Oregon. 

Canons of treaty construction, the tools developed by federal courts for interpreting Indian treaties, 

read such treaty language broadly in favor of the tribe. As such, these tribes have an interest in the 

effects of the Proposed Action on hunting, fishing, and gathering. 

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Final Environmental Impact Statement 

Certain natural foods found in the Forest and Scenic Area are culturally significant to the tribes. All 

tribes take advantage of assorted wild roots, fruits, and other plant-life. Salmon has long been, and 

continues to be a staple. The foods, the methods of obtaining them, and many special festivals and 

rituals that celebrate them are important parts of life on the Warm Springs Reservation. The Warm 

Springs Indians observe three annual religious feasts of thanksgiving based on native foods: the Root 

Feast in spring; the First Catch, or Salmon Feast, in spring; the Huckleberry Feast in early fall. 

In the short-run, some plants that are culturally significant to tribes may be affected by herbicides, 

even though they are not the target of herbicide treatments. These plants include blue camas 

(Camassia spp.), huckleberry (Vaccinium membranaceum), and bitterroot (Lewisia rediviva). Camas, 

a member of the lily family, grows in mountain meadows from 2,000 to 8,000 feet (Munz, 1963). 

Huckleberry is widely distributed in forested environments in the Northwest. Bitterroot grows in 

loose, gravelly slopes and rocky places from 2,000 to 9,000 feet (Munz, 1963). 

3.14.2 Direct/Indirect Effects

Executive Order 12898 – Federal Actions to Address Environmental Justice in Minority Populations 

and Low-Income Populations (1994) directs federal agencies to identify and address the issue of 

environmental justice: adverse human health and environmental effects of agency programs that 

disproportionately impact minority and low income populations. Executive Order 12898 also directs 

agencies to consider patterns of subsistence hunting and fishing when an agency action may affect 

fish and wildlife. 

Jobs Created by Invasive Plant Treatments 

As previously discussed in Section 3.7, more jobs would be created by the Restricted Herbicide Use 

Alternative than by either the Proposed Action or the No Action Alternatives. Hispanic workers 

would fill most of those jobs. Both Sarathy (2003) and the League of Women Voters (2000) found 

that the vast majority of forestry work is being done by Hispanic workers. 

Jobs created by the Proposed Action or the Restricted Herbicide Use Alternatives would be seasonal, 

physical, outdoor work. The work is generally categorized as manual labor or low-skilled work 

(Sarathy, 2003). As such, wages would generally be low. Currently the minimum wage in Oregon is 

$7.25/hour. Jobs may be in remote locations, and contractors may house workers in motels or in 

isolated camps. 

Forestry workers, usually disproportionately Hispanic, would have more exposure to the proposed 

herbicides than the population at large. The Proposed Action would have the greatest effect in this 

regard; the number of acres treated with herbicides for each job created would be 137 acres (this 

number would actually be larger since most acre would be treated more than once). The No Action 

Alternative would create the least exposure per worker; the number or acres treated with herbicides 

for each job created would be 16 acres. For the Reduced Herbicide Use Alternative, the number of 

acres treated with herbicides for each job created would be 25 acres (this number would actually be 

larger since most acre would be treated more than once). 

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Site-Specific Invasive Plant Treatments 

These statistics have little comparative value without also examining measures to ensure applicator 

safety. In their study of Latinos in the Oregon workforce, Gates and Crider (2001) reported examples 

of unsafe working conditions, made worse by the failure of employers to take responsibility for the 

medical consequences of workplace accidents. During interviews with Latino workers in the 

agriculture industry, more than one worker described the dangers of herbicide exposure (Gates and 

Crider, 2001). Because of concerns about worker health and anecdotal stories of poor working 

conditions, several PDC were developed for this project to reduce the exposure and hazard from 

herbicides for chemical applicators (see Section 2.2, Project Design Criteria for Alternatives 2 and 3). 

These criteria would apply to all herbicide treatments in the Proposed Action and in the Reduced 

Herbicide Use Alternative. PDC D.1 would require workers to use appropriate personal protective 

clothing and equipment at all times during application. Several other PDC that are primarily intended 

to protect natural resources would also enhance worker safety. PDC A.1 (label instructions), A.2 

(compliance with standards in Invasive Plant FEIS, 2005a), A.4 (transportation), A.5 (leak-proof 

containers), A.6 (transportation routes), and B.1 (pre-operations briefings) would incrementally 

contribute to worker safety. Together, these criteria would eliminate the kinds of unsafe working 

conditions reported by Gates and Crider (2001). 

Special Forest Products 

Harvesters of non-timber forest products tend to come from Asian, Hispanic, and American Indian 

communities. These groups would be affected by herbicide treatments in areas available for picking 

their products. Based on the Mt. Hood National Forest Mushroom Harvest map (which includes the 

Oregon portion of the Scenic Area), more than 50 percent of the Forest (more than 535,000 acres), is 

ordinarily open to mushroom gathering. Of the 13,000 acres proposed for invasive plant treatment, 

roughly 9,900 acres are in areas that are open to mushroom gathering. In the Proposed Action, 

approximately 9,789 acres in areas that are ordinarily open to mushroom picking would be treated 

with herbicides; in the Restricted Herbicide Use Alternative, approximately 3,282 acres would be 

treated with herbicides. These acre figures are 1.8 percent and 0.6 percent, respectively, of the portion 

of the forest open to mushroom picking. See Section 3.5 – Human Health and Safety for more 

information on the effects to special forest products. 

Most non-timber forest products are found in a forested environment. Products such as huckleberries, 

salal, ferns, and beargrass are not usually found in the disturbed areas along roads or in quarries. In 

addition, some proposed treatment areas are in areas such as campgrounds, resorts, and administrative 

sites that are off-limits to forest product gathering at any time. Considering only the forested sites that 

are not off-limits and where product gathering would likely occur, approximately 4,405 acres would 

be treated with herbicides in the Proposed Action (roughly 0.4 percent of the entire Forest and Scenic 

Area). In the Restricted Herbicide Use Alternative, approximately 1,705 acres of such sites would be 

treated with herbicides (roughly 0.2 percent of the entire Forest and Scenic Area). See Section 3.5 – 

Human Health and Safety for more information on the effects to special forest products. 

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Final Environmental Impact Statement 

Three PDC specifically address protection of forest visitors, especially forest workers and product 

harvesters, from exposure to herbicides (see Section 2.2). PDC D.2 would require signs to be placed 

at access points to treatment areas notifying the public of herbicide treatments. PDC D.3. would 

require announcement of herbicide applications to be published in local newspapers. PDC D.6. would 

require posting, barricading, or closing of developed campgrounds to prevent inadvertent public 

contact with herbicides. These criteria would apply to all herbicide treatments in the Proposed Action 

and in the Reduced Herbicide Use Alternative. 

Treaty Rights 

The reversal of negative impacts caused by invasive plants and the restoration of ecological 

communities and functions would benefit tribal interests. The long-term benefits of controlling 

invasive plants outweigh the short-term risks to localized populations of culturally significant plants. 

The Confederated Tribes of Warm Springs have been contacted about the proposed treatments. Tribal 

specialists agreed that any potential effects to culturally significant plants would be short-term, and 

controlling the spread of invasive plants could potentially benefit desirable plant species. No 

modifications for proposed treatments were recommended by the Confederated Tribes of Warm 

Springs; however the Forest Service agreed to meet annually to discuss any concerns about project 

implementation. 

Treating invasive plants with herbicides and the actions taken to protect human health may briefly 

interrupt traditional root and berry harvesting in some areas where tribes have reserved treaty rights. 

Periodically during the proposed 15 year project, fewer gathering areas would be available for tribal 

use for short periods of time (methods for public notification about herbicide treatments are contained 

in the PDC in Section 2.2). None of the alternatives, however, would abrogate reserved treaty right. 

Culturally significant plants are not specifically targeted by any of the proposed treatments; however, 

some of the herbicides are known to affect a range of broad leaf plants and grasses, potentially 

including cultural plants. Since it treats more acres with herbicides, the Proposed Action would have 

the greatest potential effect. The No Action Alternative, because it would treat the fewest acres 

overall, would have the least effect. The effects would be direct and short-term to localized plant 

populations. Three of the inventoried treatment areas (approximately 16 acres) are described as being 

in meadows, so effects to blue camas would be minimal unless early detection finds more invasive 

plant infestations in meadow environments. Camas may be affected by virtually all prescribed 

herbicides except clopyralid. Huckleberry may be most affected by chlorsulfuron, dicamba, 

glyphosate, imazapyr, picloram, and triclopyr. Bitterroot, like camas, may be affected by all the 

prescribed herbicides except clopyralid. Spot spraying or selective/hand methods may be employed if 

necessary to limit unwanted spray drift. Other prescriptions limiting herbicide application during high 

winds or expected precipitation would also limit unwanted spray drift and spread. In the long-run, 

populations of the desirable, culturally-important plants would re-colonize herbicide treated areas 

through seed dispersal from adjacent areas. Additional information about the direct and indirect 

effects to native plant communities is in Section 3.6.2. 

Effects to salmon (reserved fishing rights) and game animals (reserved hunting rights) would be 

indirect. Section 3.10.2 contains a discussion about the effects to salmon. Section contains a 

discussion of effects to game animals. Additional information about human health and safety is in 

Section 3.5. 

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Site-Specific Invasive Plant Treatments 

3.14.3 Early Detection/Rapid Response Strategy

Jobs Created by Invasive Plant Treatments 

Because the number of jobs created for both the Proposed Action and the Reduced Herbicide Use 

Alternative would increase proportionately to the number of new acres of invasive plants detected, the 

number of acres treated with herbicides as a ratio to the number of jobs created would remain 

constant. 

Special Forest Products 

Assuming that newly detected invasive plant infestations fall proportionately into the same treatment 

priority categories as do inventoried areas, the Proposed Action may treat approximately 22,590 acres 

with herbicides in areas that are ordinarily open to mushroom picking; in the Restricted Herbicide Use 

Alternative, approximately 7,581 acres may be treated with herbicides. These acre figures are still 

only 4.2 percent and 1.4 percent, respectively, of the portion of the forest open to mushroom picking. 

Considering only the forested sites where non-timber forest product gathering would likely occur, 

approximately 10,176 acres may be treated with herbicides in the Proposed Action (roughly 1 percent 

of the entire Forest and Scenic Area). In the Restricted Herbicide Use Alternative, approximately 

3,939 acres of such sites may be treated with herbicides (roughly 0.4 percent of the entire Forest and 

Scenic Area). 

Treaty Rights 

EDRR may increase the magnitude of effects to culturally significant plants in both space and time. 

Additional root and berry harvesting areas where tribes have reserved treaty rights may temporarily 

be affected. Assuming that newly detected invasive plant infestations fall proportionately into the 

same treatment priority categories as do inventoried areas, the Proposed Action would still have a 

greatest potential effect on culturally significant plants than the Reduced Herbicide Use Alternative. 

The effects would be direct and short-term to localized populations of these plants. Over the course of 

the project, more gathering areas may be unavailable for tribal use for brief periods of time. The No 

Action Alternative does not include the EDRR. 

3.14.4 Cumulative Effects

Most of the National Forests in Oregon and Washington have either proposed aggressive action 

against invasive plants or plan to declare their intent to do so in the next few years. Invasive plant 

treatment studies are underway for the Deschutes, Ochoco (including Crooked River National 

Grassland), Malheur, and Umatilla National Forests, areas where the Confederated Tribes of the 

Warm Springs have reserved treaty rights. The Deschutes/Ochoco project would treat approximately 

52,000 acres (nearly all acres with herbicides). The Malheur project would treat about 3,862 acres 

(3,333 acres with herbicides). The Umatilla project would treat about 25,000 acres (18,500 acres with 

herbicides). Also, the Tribe is aggressively treating areas on adjacent reservation lands (CTWS and 

BIA, 2005). These actions would have cumulative effects on the environmental justice issues 

discussed above; however, the quantitative effects are unknown until the extent of other proposed 

treatments are determined. 

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Final Environmental Impact Statement 

It is safe to conclude, however, that the reversal of negative impacts caused by invasive plants and the 

restoration of ecological communities and functions would benefit all minority and low-income forest 

users in the long-run. These groups may be inconvenienced in the short-term as a small percentage 

(probably less than 5 percent) of available non-timber forest product harvesting areas are restricted for 

brief periods. 

3.14.5 Management Standards and Guidelines

Relevant standards and guidelines contained in the Forest Plan and the Northwest Forest Plan are 

displayed in Appendix B of this document; relevant standards contained in the Scenic Area 

Management Plan are displayed in Appendix C. This analysis exhibits that the Proposed Action and 

Restricted Herbicide Use Alternatives are consistent with all relevant standards and guidelines, when 

the proposed amendments are incorporated. The Forest Plan amendments are discussed in Section 

3.16. 

3.14.6 Incomplete and Unavailable Information

No inventory has been completed to determine if culturally significant plants are present in proposed 

treatment areas. Also, no analysis has been done to reveal the ethnic make-up of forest product permit 

holders at the Forest or Scenic Area. 

3.15. Specifically Required Disclosures 

3.15.1 Adverse Environmental Effects that Cannot be Avoided 

Implementation of any action alternative would cause some adverse environmental effects that cannot 

be effectively mitigated or avoided. Unavoidable adverse effects often result from managing the land 

for one resource at the expense of the use or condition of other resources. Most adverse effects can be 

reduced, mitigated or avoided by limiting the extent or duration of effects. The application of Forest 

Plan standards and guidelines, Best Management Practices, Invasive Plant ROD standards (2005b), 

PDC, and monitoring are all intended to further limit the extent, severity, and duration of potential 

effects. Such measures are discussed throughout Chapter 3 and the purpose of this section is to fully 

disclose these effects. 

Table 3-49 below summarizes the unavoidable potential adverse effects to the environment associated 

with the invasive plant treatment alternatives considered in this EIS. 

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Site-Specific In

3-255 

Table 3-49: Adverse Effects that Cannot be Avoided for Site-Specific Invasive Plant Treatments proposeNational Forest and Columbia River Gorge National Scenic Area. 

Adverse Effect Reference Effects without Project Design Criteria 

USDA Forest Service Intended Response and 

Effects of invasive plant treatments on non-target plants, including culturally significant plants 

Section 3.6, Section 3.13 

There is some risk that native plants, including special status species and culturally significant species, may be injured and/or killed by herbicides. Herbicides may impact plants through overspray or drift from herbicide applications, root translocation or surface runoff. Also, manual, mechanical and cultural treatments entail some risk to native plants and plant communities. Any species along roadsides or where activities occur that disturb native plant communities would be threatened by not only invasive plants, but by invasive plant treatments. Adverse effects would most likely be localized and short-term. Without treatment, however, invasive plant infestations would increase and spread, displacing native plants and plant communities. 

Short-term adverse effects would be largely offset by treatment. The adverse efminimized by properly impPlant ROD standards (2002.2). PDC in Subsection E resources, including speciculturally significant specie

Herbicide effects of eating contaminated products, including deer, elk, fish, and special forest products (e.g., berries or mushrooms) 

Section 3.5, Section 3.11 

Potential health risks exist from handling or consuming spray-contaminated forest products, including special forest products (e.g., berries or mushrooms), deer, elk and fish. Chewing and eating contaminated plant material cause different exposure and dose patterns, compared to harvesters exposure to contaminated special forest products. The people who both harvest and consume special forest products may be exposed both through handling contaminated plant material and chewing or eating it, and thus may be at the greatest risk for exposure. 

By properly implementing standards (2005b) and PDexposures would remain bexposure levels developedwould be likely to experienhealth effects. The use of personal protective equipmnotification are examples oavoided, or where unavoid

greatly reduced. The analyno human health scenariothreshold of concern. No additional PDC are knohuman health associated wthe exception of no herbic
Final Environmental Impact Statement 

Adverse Effect Reference 

USDA Forest Service 

Effects without Project Design Criteria Intended Response and 

Economic impacts, including relative costs 

Section 3.7 The management of invasive plants is costly, and 

fiscal resources are limited. Increased operating costs due to expanded invasive plant management may result in direct or indirect increases in costs to users of National Forest System lands. Also, invasive plant management may compete with other land management needs, resulting in opportunitycost tradeoffs. A cost efficiency analysis, assuming both an unlimited and a constant (limited) budget estimate, is presented. Presently, the average annual cost per acre for the No Action Alternative is $193. The Proposed Action would increase this figure to $324; and the Restricted Herbicide Use Alternative would have an average annual per acre cost of $541. 

Cost-effectiveness is integdecision framework presenthird criteria states: “econotreatment.” Tables 3-11 and 3-12 presacres years annually and twith total cost of treatmentsituations and choices. 

Herbicide effects on soil organisms (e.g., invertebrates, fungi, actinomycetes, bacteria) 

Section 3.8 Picloram and sulfometuron methyl are of concern to 

soil organisms due to their toxicity and persistence. Effect of an herbicide treatment on the soil depends on the particular characteristics of the herbicide used, how it is applied, and soil physical, chemical and biological conditions. 

Factors that determine the fate of herbicides in soil include: mobility and degradation. Herbicide degradation over time is a result of physical and chemical processes in soil and water. Herbicide fate in soil is determined by herbicide characteristics, such as adsorption, solubility, degradation, and volatility. Soil characteristics, such as organic matter, pH, temperature, moisture content, clay content, and microbial degradation, are important in the fate of herbicides. Degradation rates generally decrease with increasing soil depth and decreasing temperatures. General characteristics for the proposed herbicides are displayed in Table 3-20, with more detailed information by herbicide contained in Appendix U. 

Short-term adverse effects be largely offset by long-tetreatment. Invasive plants effects on soil properties. increase the proportion of or decrease the amount of soil, deplete the soil of nutwith certain nutrients, chanproduce toxic herbicides thorganisms. Some of these difficult to reverse, and cadegradation and difficulty vegetation. By properly implementing standards (2005b) and PDeffects of herbicides shoulSoil resources are addressSubsection G of the PDC. 

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Site-Specific In

Adverse Effect Reference 

USDA Forest Service 

Effects without Project Design Criteria Intended Response and 

Herbicide effects on water quality 

Section 3.9 Herbicides used to treat invasive plants for the 

Proposed Action can enter water through spray drift, surface water runoff, percolation, groundwater contamination, and direct application. The potential routes of herbicide entry may result in indirect effects to aquatic organisms, their habitat and water quality. Water runoff during rain events could transport herbicides to waterways and convey them to aquatic species habitat. Soil type as well as chemical stability, solubility, and toxicity can determine the extent to which an herbicide would migrate and impact surface waters and groundwater. Some herbicides, such as glyphosate, strongly adsorb to soil particles which prevents it from excessive leaching. Other herbicides, such as picloram, are highly soluble in water and more mobile. 

The amount of herbicide reby spray drift is expected tconsidering the restrictions spraying within 100-feet of when wind speeds are outdescribed in the PDC (Secsophistication of newer eqbroadcast spraying. Also, herbicides entering ssurface runoff are expectetargeted spot spraying tecto apply herbicide within 1(PDC F.1.). This would miherbicide reaching the groThe potential for direct appsurface water is very low, and spot spraying herbicidused to apply herbicides dleast 15-feet of the water’s 

Herbicide effects on terrestrial species, including wildlife, pollinators, reptile, and amphibian species 

Section 3.11 All of the alternatives are associated with plausible 

scenarios that exceed the toxicity indices for birds and mammals that eat grass or insects, acres treated by herbicide that result in exposures exceeding a LOAEL (Lowest Observed Adverse Effect Level) for some species, and herbicides that may adversely affect amphibians. The number of acres treated at one time within one treatment area is likely to influence the likelihood of exposure to herbicides for wildlife. 

Short-term adverse effects would be largely offset by the habitat resulting from tAll the herbicides in this E(often within 24 to 48 houraccumulate up the food chdoes not eliminate, the pocumulative effects. The he

potential to harm birds and decreasing severity are: trglyphosate, sulfometuron 

3-257 
Final Environmental Impact Statement 

Adverse Effect Reference 

USDA Forest Service 

Effects without Project Design Criteria Intended Response and 

Indirect mortality is possible from sub-lethal effects that could increase susceptibility to predation. Indirect effects to wildlife from cumulative herbicide exposure also are possible. For example, if a sublethal exposure affects an internal organ and the effect is not quickly reversed, then subsequent exposure could cause cumulative damage. 

By properly implementing standards (2005b) and PDeffects largely should be aaddressed specifically in SPDC. 

Effects of treatment on designated Wilderness Areas 

Section 3.12 Taking action would protect natural conditions, but 

introduce human manipulation. By taking action, herbicides would be introduced into the Mt. Hood Wilderness. Treatment poses a slight risk of unwanted effects to species other than orange hawkweed. Modern human interference with ecological dynamics between the natural plant communities and the introduced invasive plants would be considered by some to be a negative effect. This interference may affect the sense that the wilderness is free from human manipulation. Those who think it is most important that wilderness be free from biophysical manipulation would likely object to utilization of herbicides and be greatly concerned about any effects they have to wilderness. Other wilderness areas may be impacted in a similar way under the EDRR. 

Negative effects from No Acontinued presence and ehawkweed in the Mt. Hood include changes to the natprocesses expected as paexperience. The orange haalter the natural meadow cLake Trail, interact in unknwildlife species, and alter esuch as plant community ddisturbance processes (i.ebe some experiential loss vegetation encountered alMcGee Creek and Pacific Trails. Taking no action avwilderness, but natural conprotected. Similar rationale constructed if invasive pladiscovered in other wildernEDRR. By properly implementing some of the effects could 

specifically addresses desAreas. 

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Site-Specific Invasive Plant Treatments 

3-259 

3.15.2 Short-term Uses and Maintenance of Long-term Productivity 

NEPA requires consideration of “the relationship between short-term uses of man’s environment 

and the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As 

declared by the Congress, this includes using all practicable means and measures, including 

financial and technical assistance, in a manner calculated to foster and promote the general 

welfare, to create and maintain conditions under which man and nature can exist in productive 

harmony, and fulfill the social, economic, and other requirements of present and future 

generations of Americans (NEPA Section 101). 

The continued expansion of invasive plants within the Forest and Scenic Area would result in 

serious, long-term adverse effects on a broad range of resources, reducing the long-term 

productivity of the National Forest System lands. Invasive plants create a host of environmental 

and other impacts, most of which are harmful to healthy, native ecosystem processes, including: 

displacement of native plants; reduction in functionality of habitat and forage for wildlife and 

livestock; increased soil erosion and reduced water quality; alteration of physical and biological 

properties of soil; loss of long-term riparian area function; loss of habitat for culturally 

significant plants; high cost (dollars spent) of controlling invasive plants; increased cost to 

maintaining transportation systems; and loss of recreational opportunities. Neighboring private 

and other public lands would also be affected. Invasive plants spread across landscapes, 

unimpeded by ownership boundaries. All land ownerships (private, corporate, tribal, and 

government) in the Pacific Northwest are affected by invasive plants, which have the potential to 

spread to neighboring lands. A sustainable solution to the problem would require cooperation 

and a long-term commitment from all landowners. 

The relationship between uses and long-term productivity as it relates to invasive plant 

management is described throughout this EIS, primarily in each of the resource areas discussed 

in Chapter 3. Chapter 3 discusses the relationship between land management activities and 

invasive plants, as well as describes the effects of the proposed invasive plant treatments on the 

resources. 

3.15.3 Irreversible or Irretrievable Commitments of Resources 

Irreversible commitments of resources are those that cannot be regained, such as the extinction 

of species or the removal of mined ore. Irretrievable commitments are those that are lost for a 

period of time, such as the temporary loss of timber productivity in forested areas that are kept 

clear for use as a power line rights-of-way or road. 

Implementation of the Proposed Action or Restricted Herbicide Use Alternatives would not 

produce irreversible or irretrievable commitment of resources. The invasive plant treatment 

proposed through these actions would be conducted within the constraints of the Invasive Plant 

ROD standards (2005b), PDC described in Section 2.2, and other national and regional 

management direction (which incorporate applicable laws, regulations, and policies). Adverse 

effects described in Chapter 3 are likely to be localized and short-term. 
Final Environmental Impact Statement 

3.15.4 Cumulative Effects 

Cumulative effects are addressed in each of the resource areas discussed in Chapter 3. 

Incremental impacts of the environment from multiple actions over time are assessed for each of 

the Forest and Scenic Area resources. 

3.15.5 Conflicts with Plans or Policies of Other Jurisdictions 

NEPA at 40 CRF 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently with and integrated with . . . other environmental 

review lands and executive orders.” 

Based on information received during scoping, informal consultation meetings, and analysis in 

the EIS, none of the alternative under consideration would conflict with the plans or policies of 

other jurisdictions, including the Confederated Tribes of Warm Springs. This project would not 

conflict with any other policies and regulations or laws, including the Safe Drinking Water Act, 

Clean Water Act, Endangered Species Act, Magnuson-Stevens Fishery Conservation and 

Management Act, Wild and Scenic Rivers Act, Wilderness Act, and National Historic 

Preservation Act. Refer to the following sections for discussions regarding these laws: 

• Section 3.9 – Safe Drinking Water and Clean Water Acts; 

• Sections 3.10 and 3.11 – Endangered Species Act; 

• Section 3.10 – Magnuson-Stevens Fishery Conservation and Management Act; 

• Section 3.12 – Wild and Scenic Rivers and Wilderness Acts; and 

• Section 3.13 – National Historic Preservation Act. 

3.15.6 Effects on Consumers, Civil Rights, Minority Groups, Women and 

Environmental Justice 

Executive Order #12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low Income Populations, directs Federal agencies to address effects accruing in 

a disproportionate way to minority and low income populations. Section 3.14 – Tribal Relations, 

Civil Rights and Environmental Justice discusses the impacts of this project on these groups. 

Additionally, in accordance with USDA Forest Service and BLM policy, contracting procedures 

would ensure that projects made available to contractors would be advertised and awarded in a 

manner that give proper consideration to minority and women-owned business groups. 

3.15.7 Effects on American Indian Rights 

No impacts on American Indian social, economic or subsistence rights are anticipated. No 

impacts are anticipated related to the American Indian Religious Freedom Act. The Confederated 

Tribes of Warm Springs, the Yakima Nation, the Confederated Tribes of the Grand Ronde, the 

Nez Perce Tribe, and the Confederated Tribes of the Umatilla Nation have historic interests in 

this area and have been contacted in reference to this Proposed Action and environmental 

analysis, as discussed in Sections 3.13, 3.14 and 4.4. 

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Site-Specific Invasive Plant Treatments 

3.15.8 Prime Farmlands, Rangelands, Forestlands, or Parklands 

No prime farmlands, rangelands, forestlands or parklands exist within the project area. Since 

none of these lands exist, there would be no direct, indirect or cumulative effects would occur. 

3.15.9 Wetlands and Floodplains 

Floodplains are areas within the riparian areas of Class 1, 2, and 3 streams, and vary from only a 

few feet, to the entire riparian area in width. Wetlands are areas that regularly are saturated by 

surface or ground water and subsequently are characterized by a prevalence of vegetation that is 

adapted for life in saturated soil conditions. Proposed invasive plant treatments within riparian 

areas are discussed in Sections 3.9 – Water Quality and 3.10 – Aquatic Organisms and Habitat. 

The environmental effects are consistent with the standards and guidelines for the Mt. Hood 

National Forest Land and Resource Management Plan (as amended) and Columbia River Gorge 

National Scenic Area Management Plan (see Appendices B and C). In addition, the proposed 

invasive plant treatments would be implemented using the standards from the Invasive Plant 

ROD (2005b) and PDC (Section 2.2). No adverse effects are anticipated to occur to wetlands and 

floodplains with any alternatives. As such, no direct, indirect, or cumulative effects to wetlands 

and floodplains are expected to occur. 

3.16. Forest Plan Amendment 

Alternatives 2 and 3 in this draft EIS propose an amendment to the Mt. Hood National Forest 

Land and Resource Management Plan (Forest Plan). The proposed amendment is a minor change 

to six of the standards and guidelines in the Forest Plan. The proposed changes are described in 

Table 2-8. These amendments if approved would be effective at the time of the decision and 

would apply to the respective management areas throughout the Forest and Scenic Area in 

Oregon. 

The regulations for forest planning under the National Forest Management Act (36 CFR Part 

219, as of July 1999) provide procedures for the Responsible Officials to amend a Forest Plan. 

The regulations state: “If the change resulting from the amendment is determined not to be 

significant for the purposes of the planning process, the Forest Supervisor may implement the 

amendment following appropriate public notification and satisfactory completion of NEPA 

procedures” (36 CFR 219.10(f)). The proposal to amend the Forest Plan was described in a 

scoping notice mailed to the public in September 2005. Analysis of these proposed changes is 

included in this EIS. 

Additional guidance on amending Forest Plans is provided in the Forest Service Manual 1900-

Planning. Section 1922.51 describes non significant amendments as: 

• Actions that do not significantly alter the multiple-use goals and objectives for long-term 

land and resource management; 

3-261 
Final Environmental Impact Statement 

3-262

• Adjustments of management area boundaries or management prescriptions resulting form 

further on-site analysis when the adjustments do not cause significant changes in the 

multiple-use goals and objectives for long-term land and resource management; 

• Minor changes in standards and guidelines; and/or 

• Opportunities for additional management practices that would contribute to achievement 

of the management prescriptions. 

The proposed amendment does not propose changes in management area boundaries or 

prescriptions, but does represent minor changes in standards and guidelines and provides for 

additional management practices that could contribute to achieving management prescriptions. 

The proposed minor changes to the standards and guidelines (A2-082, A12-031, B5-041, B7-070 

and A1-WR-064) would not alter any of the multiple use goals or objectives outlined in the 

Forest Plan for Wilderness Areas (A2), Outdoor Recreation Areas (A12), Pileated 

Woodpecker/Pine Martin Habitat (B5), General Riparian Areas (B7), or Wild and Scenic Rivers 

(A1). To the extent that invasive plants may adversely affect the multiple use goals of these 

management areas, however, allowing for the appropriate use of herbicides to treat invasive plant 

populations would contribute to achieving multiple use goals. 

The minor change to forestwide standard (FW-076) would not change the overall intent of the 

standard, it just clarifies that the standard does not prohibit the use of herbicides. Therefore, there 

would be no change in the multiple use goal of protecting water resources forestwide. 
CHAPTER 4 

Consultation and Coordination 
 
Site-Specific Invasive Plant Treatments 

CHAPTER 4: Consultation and Coordination 

4.1. Consultation with U.S. Fish and Wildlife Service (FWS) 

The FWS has Endangered Species Act (ESA) jurisdiction over non-marine fish, wildlife and 

plant species, such as the northern spotted owl, Canada lynx, and marbled murrelet that are listed 

or proposed for listing as threatened or endangered. The USDA Forest Service must consult with 

FWS concerning the effects of proposed actions on listed species and species proposed for listing 

under FWS jurisdiction.

Informal consultation was conducted with FWS for Northern Spotted Owl, northern bald eagle, 

and Canada lynx. Consultation with the FWS was initiated on for the treatment of invasive 

species in two separate consultation avenues. Disturbance effects of invasive plant treatments 

were analyzed and consulted on in the Programmatic Biological Assessment for Activities with 

the Potential to Disturb Northern Spotted Owls and/or Bald Eagles in the Willamette Province 

FY2006-2007 and the Willamette Province Level One Team was given a presentation on the 

effects analysis and subsequent determination made on the effects to the Northern Spotted Owl 

and its habitat from the treatment of these invasive plants. The Level One Team was informed 

that the Forest and Scenic Area had determined that the effect from the use of herbicide, manual, 

mechanical, and cultural treatment of invasive plants was no effect to the Northern Spotted Owl 

and its habitat. The team was reminded that the disturbance effects had been analyzed in the 

Programmatic Biological Assessment. The Level One Team made no comments on the effects 

determination. A letter was sent to the U.S. Fish and Wildlife Service amending the Biological 

Assessment to reflect effects determinations for Northern Spotted Owl based on project 

alternatives information. The letter was sent the Oregon State Supervisor of U.S. Department of 

Fish and Wildlife on August 29, 2006. 

Based on the effects analysis prepared for the project, there is no effect on bald eagles or Canada 

lynx; therefore, consultation is not required for these species. 

4.2. Consultation with National Marine Fisheries Service (NOAA 

Fisheries) 

NOAA Fisheries has Endangered Species Act (ESA) jurisdiction over marine species, such as 

anadromous fish. This project includes habitat for 12 marine species listed as threatened or 

endangered under the ESA. As a result, the USDA Forest Service is consulting with NOAA 

Fisheries under the ESA for this project. 

Informal consultation was conducted with NOAA fisheries on listed anadromous fish species and 

their habitat that occur within or near the proposed invasive plant treatment areas. The 

Willamette Province Level One Team was given a presentation on the Proposed Action and 

affected environment. The conversations with the Level One Team continued through the 

alternative refinement and analysis stages. 

4-1 
Final Environmental Impact Statement 

A BE and BA was prepared assessing impacts to listed fish species and designated critical 

habitat. Both are available in the project file located at the Mt. Hood National Forest 

headquarters in Sandy, Oregon or on-line at http://www.fs.fed.us/r6/mthood/projects/. The 

fisheries BE/BA determined that invasive plant treatments “May Affect, Not Likely to Adversely 

Affect” threatened or endangered fish species and habitat. Informal consultation on the Selected 

Alternative has been conducted and completed with the U.S. Fish and Wildlife Service (FWS) 

for threatened bull trout and their designated critical habitat. On June 5, 2007, the FWS 

concurred with the “May Affect, Not Likely to Adversely Affect” findings of the BA (TAILS 

#13420-2007-I-0107). 

The Forest Service initiated informal consultation on the Selected Alternative with the National 

Marine Fisheries Service (NMFS). NMFS did not concur with the “May Affect, Not Likely to 

Adversely Affect” findings in the BA for threatened and endangered anadromous fish species 

and designated critical habitat. NFMS issued a letter of nonconcurrence and request for 

additional information on April 23, 2007. On June 6, 2007, the Forest Service responded with the 

additional information and requested formal consultation with NMFS. On January 9, 2008 the 

NMFS completed a Biological Opinion which determined the Selected Alternative resulted in a 

“May Affect, Likely to Adversely Affect” finding, but was not likely to jeopardize the continued 

existence of any listed anadromous fish species or result in the destruction or adverse 

modification of designated critical habitat. The NMFS also determined the Selected Alternative 

would have adverse effects on essential fish habitat for coho and Chinook salmon. NFMS also 

determined that “the Proposed Action is likely to benefit ESA-listed species and their habitat by 

restoring native vegetation, preventing future weed infestation, and restoring ecosystem and 

riparian function, and have other beneficial effects as well (page 61).” 

Included in the Biological Opinion was a take statement and nondiscretionary terms and 

conditions that must be followed to meet Endangered Species Act Requirements. The terms and 

conditions included a variety of treatment and reporting requirements in addition to those 

included as part of the Selected Alternative, including: 

• Additional treatment stipulations in riparian areas designed to further minimize potential 

effects to listed anadromous fish species and habitat. 

• A list of approved additives (i.e. adjuvants) for use in riparian zones. 

• Specific field treatment monitoring and application tracking requirements. 

• Annual reporting requirements. 

The full title and reference number for the Biological Opinion are: Endangered Species Act 

Section 7 Formal Consultation and Magnuson-Stevens Fishery Conservation and Management 

Act Essential Fish Habitat Consultation for the Mount Hood National Forest and Columbia River 

Gorge National Scenic Area Invasive Plant Treatments Project, Clackamas County, Oregon 

(reference number 2007/01524). 

4-2 
Site-Specific Invasive Plant Treatments 

4.3. Consultation with Oregon State Historic Preservation Office 

(SHPO) 

The National Historic Preservation Act requires consideration be given to the potential effect of 

federal undertakings on historic resources. This includes historic and prehistoric cultural resource 

sites. The guidelines for assessing effects and for consultation are provided in 36 CFR 800. To 

implement these guidelines, Pacific Northwest Region (Region 6) of the USDA Forest Service 

entered an agreement in 2004 with the Oregon SHPO and the Advisory Council on Historic 

Preservation. In accordance with the agreement, the project was determined to have little or no 

effect to heritage resources, and no cultural resource survey was required. A no effect 

determination has been made for the Proposed Action (Alternative 2) and for the Restricted 

Herbicide Use Alternative (Alternative 3). No consultation with the Oregon SHPO is required. 

4.4. Consultation with Tribal Governments 

Consultation was conducted with the Confederated Tribes of Warm Springs. The Tribe 

expressed strong support for aggressive treatments, including herbicide treatments, to combat 

invasive plants. Tribal representatives said they believe the long-term benefits of treating and 

controlling invasive plants outweigh the short-term risks to localized populations of culturally 

significant plants. Tribal representatives met with members of the interdisciplinary team in 

August 2005. Also, the Tribe was invited to comment on the draft EIS. 

Letters requesting consultation were sent to the Yakama Nation, Confederated Tribes of the 

Grand Ronde, Nez Perce Tribe, and Confederate Tribes of the Umatilla Indian Reservation. The 

USDA Forest Service did not receive any responses. 

4.5. Consultation with State, County and Municipal Governments 

The Oregon Department of Agriculture (ODA) as well as Hood River and Wasco county noxious 

weed departments have conducted invasive plant treatments in and near the Forest and Scenic 

Area. Representatives from these departments and the USDA Forest Service have discussed the 

project throughout the preparation of this draft EIS. These departments were invited to review 

the PDC and the Proposed Act. In addition, the Department of Environmental Quality (DEQ) 

was consulted on the PDC to ensure water quality standards were being met. Comments were 

received from ODA, Hood River county and DEQ. These comments have been incorporated into 

the draft EIS. 

4-3 
Final Environmental Impact Statement 

4-4 

Coordination with municipal water boards would occur as a part of implementation planning to 

ensure compliance with the PDC and Municipal Watershed Agreements. The potentially affected 

major municipal water boards and organizations include City of Estacada (Clackamas River), 

City of Hood River, City of Portland (Bull Run Watershed), City of Sandy (Alder Creek), 

various Clackamas River Water Providers, Corbett Water District (Gordon Creek), and The City 

of The Dalles (The Dalles Watershed, South Fork Mill Creek). Other smaller water providers 

also would be contacted as part of implementation planning if invasive plant treatments would 

occur above their water intakes. 

4.6. Consultation with Columbia River Gorge Commission 

The USDA Forest Service presented the project to the Columbia River Gorge Commission as 

part of the Scenic Area Manager’s report in March 2006. The USDA Forest Service presented 

the project as an agenda item at the October 2006 at a Gorge Commission meeting as well. The 

Gorge Commission staff and each Commissioner were included in all public notifications. 
CHAPTER 5 

List of Preparers 
 
Site-Specific Invasive Plant Treatments 

CHAPTER 5: List of Preparers 

The following is a list of contributors to this EIS. Numerous other Forest Service employees 

contributed to the completion of this document through their assistance in review and support 

functions, and/or by providing USDA Forest Service level data and other information needs. 

Their help was greatly appreciated and recognized. 

5.1. Interdisciplinary Team Members – Core Members 

Gary Asbridge. Fisheries Biologist, USDA Forest Service, Mt. Hood National Forest, Hood 

River Ranger District, Parkdale, Oregon. Education: B.S. in Biology, Zoology emphasis; M.S. in 

Fishery Resources. Experience: Barlow Ranger District fisheries biologist for 4 years, Barlow 

and Hood River Ranger Districts fisheries program manager for 11 years. Fisheries technical 

support and analysis for a wide variety of Forest projects, including timber sales, silviculture, 

watershed restoration, road building/management, and recreation, as well as the design and 

implementation of watershed restoration projects and fish population/habitat surveys.

Jaimie Bradbury. GIS Analyst, Data Resources Management, USDA Forest Service, Pacific 

Northwest Region, Sandy, Oregon. Education: B.S. in Geography, Land Management Emphasis; 

M.S. in Geography, GIS/Cartography/Remote Sensing Emphasis. Experience: GIS analysis, data 

management and program coordination with the USDA Forest Service since 1988 providing 

support to all resource areas. 

Robin Dobson. Botanist/Ecologist, USDA Forest Service, Columbia River Gorge National 

Scenic Area, Hood River, Oregon. Education: M.S. and Ph.D. in Plant Pathology. Experience: 

Land use/natural resource planner, ecology and botany (weeds) program management and field 

work, environmental documentation, and wetland and forest restoration. 

John Dodd. Soil Scientist, USDA Forest Service, Mt. Hood National Forest, Barlow Ranger 

District, Dufur, Oregon. Education: B.S. in Soil Science, Land Use Emphasis. Experience: 

Provide technical soils information to managers to assist in making informed decisions. Types of 

projects information has been provided for include timber sales, ski area management, other 

recreation-related, grazing allotments, engineering, on and off-Forest small and large scale 

restoration projects through local watershed councils, irrigation districts, local municipal 

watersheds, etc. Monitoring projects for implementation and effectiveness. Experience with the 

USDA Forest Service since June of 1988, 17 of those years on the Mt. Hood National Forest. 

Michael Dryden. East Zone Archaeologist, USDA Forest Service, Mt. Hood National Forest, 

Hood River Ranger District, Parkdale, Oregon. Education: B.S. in Anthropology, undergraduate 

and graduate work in archaeological excavation. Experience: Heritage resource management, 

compliance, and consultation with the USDA Forest Service since 1984. 

5-1 
Final Environmental Impact Statement 

Alan Dyck. Wildlife Biologist, USDA Forest Service, Mt. Hood National Forest, Sandy, 

Oregon. Education: B.S. in Wildlife Management – Humboldt State University. Experience: Six 

years as Forest Wildlife Biologist on the Mt. Hood National Forest; three years as a Wildlife 

Biologist with the USDA Natural Resource Conservation Service; nine years as Wildlife 

Administrator for the U.S. Army at Fort Pickett; and an additional seven years as a biological 

technician for the Army, USDA Forest Service, and Fish and Wildlife Service. Worked in a 

variety of jobs dealing with fish and wildlife habitat and population management on public and 

private lands. Recent experience in analyzing the effects of Forest projects on wildlife habitat 

and management. 

Elisabeth Grinspoon. Social Scientist, USDA Forest Service, Pacific Northwest Region, 

Portland, Oregon. Education: B.A. in East Asian Studies; Master of Forestry; Ph.D. in 

Environmental Science, Policy, and Management. Experience: Participatory Rural Appraisal 

Specialist with United Nations Volunteers, Consultant to Food and Agriculture Organization of 

the United Nations, Program Specialist and Social Scientist with the USDA Forest Service since 

2002 

Malcolm Hamilton. Recreation Program Manager, USDA Forest Service, Mt. Hood National 

Forest, Sandy, Oregon. Education: B.S. in Forest Resource Management, and graduate studies in 

silviculture and forest ecology. Experience: 30+ years in silviculture and recreation management 

with National Forests in Oregon, California, and Arizona. 

Mark Kreiter. Hydrologist, USDA Forest Service, Columbia River Gorge National Scenic Area 

and Mt. Hood National Forest, Hood River, Oregon. Education: B.S. and graduate work in 

Geology, A.A.S. in Water Resources. Experience: Project effects assessments, watershed 

restoration and monitoring with the USDA Forest Service since 1989. 

David Lebo. Ecologist/Botanist. Westside Zone Botanist, USDA Forest Service, Mt. Hood 

National Forest, Oregon. Education: B.A. General Studies; M.A. English; M.S. Forest Ecology – 

University of Washington. Experience: Survey and Manage specialist for northwest Oregon and 

member of regional lichen taxa team (Mt. Hood National Forest and Regional Office, 2001-

2004); interagency ecologist for Winema National Forest and BLM-Klamath Falls Resource 

Area (1995-2000); ecologist, Mt. Baker-Snoqualmie and Olympic National Forests (summer 

1993); NEPA writer, forestry and biological technician, seasonal firefighter on Olympic National 

Forest (1980s).

Jennie O'Connor. Natural Resource Planner, USDA Forest Service, Mt. Hood National 

Forest, Sandy, Oregon. Education: B.A. in Biological Basis of Behavior and Environmental 

Studies; Master of Environmental Management, emphasis in Resource Ecology; Master of 

Forestry, emphasis in Silviculture – Duke University. Experience: Forest Plan implementation, 

National Environmental Policy Act (NEPA) coordination and writing, Freedom of Information 

Act (FOIA), and Sustainable Forest Management with the Forest Service since 2001. 

5-2 
Site-Specific Invasive Plant Treatments 

Gary K. Smith. Invasive Plants Program Manager and Integrated Weed Management Specialist 

(former), USDA-Forest Service, Pacific Northwest Regional Office, Portland, Oregon. 

Education: B.S. in Forestry; M.S. in Silviculture. Experience: Certified silviculturist; timber sale 

planning and administration; Integrated Pest Management; invasive plant management with 

USDA Forest Service since 1976. 

5.2. Interdisciplinary Team Members – Support Team Members 

Shawna Bautista. Wildlife Biologist, USDA Forest Service, Pacific Northwest Region, 

Portland, Oregon. Education: B.S. in Wildlife Management; M.S. in Zoology and Physiology. 

Janet Braymen. GIS Specialist, Data Resources Management, USDA Forest Service, Pacific 

Northwest Region, Hines, Oregon. Education: B.S. in Interdisciplinary Studies: Natural Science, 

Social Science and Communications.

Steve Bulkin. Forester, USDA Forest Service, Pacific Northwest Region, Portland, Oregon. 

Education: B.S. in Biology; M.S. in Natural Resource Management. 

Rochelle Desser. NEPA Coordinator, USDA Forest Service, TEAMS Enterprise Unit, Cove 

Junction, Oregon. Education: A.S. in Geo-technology. 

Margaret L. Dryden. Heritage Program Manager, USDA Forest Service, Columbia River 

Gorge National Scenic Area, Hood River, Oregon. Education: B.A. in Anthropology and History 

– Portland State University; M.A. in Anthropology – Portland State University. 

Chuti Fiedler. Fish & Wildlife Biologist, USDA Forest Service, Columbia River Gorge 

National Scenic Area, Hood River, Oregon. Education: B.S. Fisheries Management and B.S. in 

Wildlife Management – Oregon State University. 

Mike Ferris. Public Affairs Officer, USDA Forest Service, Columbia River Gorge National 

Scenic Area, Hood River, Oregon. Education: B.A. Psychology and Sociology. 

Tracii Hickman. Assistant Forest Fish Biologist and Willamette Fish Level 1 team 

representative, USDA Forest Service, Mt. Hood National Forest, Sweet Home, Oregon 

(telecommuter). Education: B.A. in Biology – Lewis and Clark College with graduate work in 

Fisheries – Oregon State University. 

Lance Holmberg. Botanist (former), USDA Forest Service, Mt. Hood National Forest, Barlow 

Ranger District, Dufur, Oregon. Education: B.S. in Natural Resources; M.A. in Biology – 

Humboldt State University. District Botanist with USDA Forest Service for 10 years.

Carol Horvath. Botanist (former), USDA Forest Service, Mt. Hood National Forest, Zigzag 

Ranger District, Zigzag, Oregon. Education: B.S. in Community Health – University of Oregon; 

B.S. in Biology – Portland State University. 

5-3 
Final Environmental Impact Statement 

5-4 

Jeff Jaqua. Archaeologist and Historic Preservation Specialist, USDA Forest Service, Mt. 

Hood National Forest, Zigzag Ranger District, Zigzag, Oregon. Education: B.A. in Anthropology 

– University of Montana; B.S. in Zoology – Montana State University.

Linda C. Mazzu. Botanist/Plant Ecologist (former), USDA Forest Service Pacific Northwest 

Region, Portland, Oregon. Education: B.S. Recreation and Park Management; M.S. Natural 

Resources. 

Mike Redmond. Environmental Coordinator, USDA Forest Service, Mt. Hood National Forest, 

Sandy, Oregon. Education: B.S. in Forestry; M.S. in Forestry. 

David Saiget. Fisheries Biologist, USDA Forest Service, Mt. Hood National Forest, Zigzag 

Ranger District, Zigzag, Oregon. Education: B.S. Biology – Oregon State University. 

Marty Stein. Forest Botanist, USDA Forest Service, Siuslaw National Forest, Waldport, 

Oregon. Education: B.S. in Forest Management. 

Ivars Steinblums. Forest Hydrologist, USDA Forest Service, Mt. Hood National Forest, 

Sandy, Oregon. Education: B.S. in Forestry/Forest Production – Humboldt State University; 

M.S. Forest Hydrology – Oregon State University.
CHAPTER 6 

Distribution List of Draft EIS 
 
Site-Specific Invasive Plant Treatments 

CHAPTER 6: Distribution List of Final EIS 

This Final Environmental Impact Statement will be distributed to individuals and organizations 

that responded throughout the development of this process, as well as Federal agencies, federally 

recognized tribes, State and local governments, and key partners. These organizations and 

agencies are listed below. Also, the mailing list includes 60 individuals that are not listed here. 

The complete mailing list is maintained in the project record, available at the Mt. Hood National 

Forest Headquarters Office in Sandy, Oregon. 

Advisory Council on Historic Preservation 

Asian Family Center 

Asian Pacific American Network of Oregon 

BARK 

BASG Corporation 

Bonneville Power Administration 

Bureau of Indian Affairs 

Bureau of Land Management 

Cambodian American Community of 

Oregon 

Chinese American Citizens Alliance 

Church of the Resurrection 

Citizens Interested in Bull Run 

City of Estacada 

City of Hood River 

City of Portland 

City of Sandy 

City of Stevenson 

Clackamas Board of Commissioners 

Clackamas County Community Health 

Division 

Clackamas River Basin Council 

Clackamas River Water 

Colorado State University Library 

Columbia Gorge Institute 

Columbia Helicopters Inc. 

Columbia River Gorge Commission 

Compliance Service International 

Confederated Tribes of the Grande Ronde 

Confederated Tribes of Umatilla Indian 

Reservation 

Confederated Tribes of Warm Springs 

Congressman David Wu 

Congressman Greg Walden 

Corbett Water District 

Department of Environmental Quality 

Department of Fish and Wildlife, Wildlife 

Division 

Department of Geology and Mineral 

Industries 

Department of Land Conservation and 

Development 

Department of State Lands Eastern Region 

Deschutes National Forest 

Division of State Lands 

Economic and Community Development 

Environmental Protection Agency, 

Region 10 

Federal Highway Administration 

Filipino American Association of Portland 

and Vicinity 

Fremont-Winema National Forest 

Freres Lumber Co. Inc. 

6-1 
Final Environmental Impact Statement 

Friends of Mt. Hood 

Friends of the Columbia Gorge 

Gifford Pinchot National Forest 

Gifford Pinchot Task Force 

Glacier View Enterprises 

Government Camp Water Company 

Grays Harbor County Commission 

Greenworks PC Landscape Architecture 

Holy Cross Church 

Holy Redeemer Church 

Hood River County 

Hood River County Watershed Group 

Hood River Soil and Water Conservation 

District 

Horticultural Services 

Immigrant Refugee Community 

Organization 

Japan American Society of Oregon 

Japanese American Citizens League 

Lewis and Clark College 

Loa Association of Oregon 

Mt. Hood Skibowl Winter and Summer 

Resort 

Mt. Hood Snowmobile Club 

Mt. Hood Study Group 

Mt. Scott Water District 

Multnomah County Health Department 

National Marine Fisheries Service, Habitat 

Conservation Division, Northwest Region 

Native Plant Society of Oregon 

Natural Resources Conservation Service, 

U.S. Department of Agriculture 

Governor’s Natural Resource Office, State 

of Oregon 

Nelson Tree Farm 

Nez Perce Tribe 

NOAA (National Oceanic and Atmospheric 

Administration) Fisheries 

NOAA Office of Policy and Strategic 

Planning 

Northwest Asian Weekly 

Northwest Coalition for Alternatives to 

Pesticides 

Northwest Environmental Deference Center 

Northwest Mountain Region, Federal 

Aviation Administration 

Northwest Oregon Invasive Weed Mgmt 

Partnership 

Northwest Power Planning Council 

Northwest Ecosystem Alliance 

Oak Lodge Water District 

Ochoco Lumber Company 

Office of the Maritime Administration 

Olympic National Forest 

Oregon State Representative District 52 

Oregon State Senator District 26 

Oregon State Senator District 30 

Oregon Department of Agriculture 

Oregon Department of Forestry, Resources 

Library 

Oregon Department of Transportation 

Oregon National Resource Council 

Oregon Senators 

Philippine American Chamber of Commerce 

of Oregon (PACCO) 

Physicians for Social Responsibility 

PNW 4 Wheel Drive Association 

Portland General Electric 

Portland Water Bureau 

6-2 
Site-Specific Invasive Plant Treatments 

6-3 

Regional Environmental Officer, U.S. 

Department of Interior, Office of the 

Secretary, Office of Environmental Policy 

and Compliance 

Rogue River-Siskiyou National Forest 

Sandy River Basin Watershed Council 

Schoenfeld & Schoenfeld, P.C. 

Scott Water District 

South Fork Water Board 

Southwest Washington Health Department 

St. Alexander Church 

St. Andrew Church 

St. Cecilia Church 

St. Elizabeth Ann Seton 

St. James Church 

St. John Church 

St. Luke Church 

St. Mary Church 

St. Matthew Church 

St. Michael The Archangel 

St. Patrick Church 

St. Peter Church 

St. Pius X Church 

State Economist 

State Representative District 15 

Thai Association of Oregon 

The City of The Dalles Watershed 

The Korean Society of Oregon 

The Nature Conservancy of Oregon 

The Research Group 

U.S. Army Corps of Engineers. 

Northwestern Division 

U.S. Congressman Brian Baird 

U.S. Congressman Earl Blumenauer 

U.S. Congressman Greg Walden 

U.S. Congressman Richard Hastings 

U.S. Congresswoman Darlene Hooley 

U.S. Department of Energy 

U.S. Department of the Interior 

U.S. Environmental Protection Agency 

U.S. Fish and Wildlife Service 

U.S. Senator Ron Wyden 

U.S. Senator Gordon Smith 

U.S. Senator Maria Cantwell 

U.S. Senator Patty Murray 

Umatilla National Forest 

USDA, Animal and Plant Health Inspection 

Service (APHIS) 

USDA, National Agricultural Library 

Wasco County Planning Dept 

Wasco County, Weed & Pest Department 

Wasco Soil & Water Conservation District 

Washington County Health and Human 

Service 

Washington County Jail 

Washington Department of Natural 

Resources 

Water Resources Department 

Weed & Pest Department, Hood River 

County 

Western Society of Weed Science 

Yakama Tribal Council 
 
References 
 
Site-Specific Invasive Plant Treatments 

REFERENCES 

Alien Plant Working Group. 2004b. Japanese Knotweed (Polygonum cuspidatum Sieb. and 

Zucc.) [Web Page]. Located at: http://www.nps.gov/plants/alien/fact/pocu1.htm. Accessed 

on: April 2004. 

Anonymous. 2002. Predicting Invasions of Nonindigenous Plants and Plant Pests. National 

Research Council Committee on the Scientific Basis for Predicting the Invasive Potential of 

Nonindigenous Plants and Plant Pests in the United States. Washington, D.C.: National 

Academy Press. 194 pp. 

Arthur, M.A., and Y. Wang. 1999. Soil nutrients and microbial biomass following weed control 

treatments in a Christmas tree plantation. Soil Science Society of America Journal 63(3): 629-

37. 

Asher, J. 1998. The Spread of Invasive Plants in Western Wildlands: A State of Biological 

Emergency. The Governor’s Idaho Weed Summit. [Web Page]. Located at: 

http://www.blm.gov/weeds/BOISUMMI.WPD.html. Accessed on: 19 April 2006. 

ATSDR (Agency for Toxic Substances and Disease Registry) U.S. Department of Health and 

Human Services. 2004. Guidance Manual for the Assessment of Joint Toxic Action of 

Chemical Mixtures. U.S. Department of Health and Human Services, Public Health Service, 

ATSDR, Division of Toxicology. 62 pp. plus appendices. 

Bakke, D. 2003a. Analysis of issues surrounding the use of spray adjuvants with herbicides. 

Unpublished report by the Forest Service Pacific Southwest Regional Pesticide Use 

Specialist. 

Bakke, D. 2003b. Human and ecological risk assessments of nonylphenol polyethoxylate-based 

(NPE) surfactants in Forest Service herbicide applications. Unpublished report by the Forest 

Service Pacific Southwest Regional Pesticide Use Specialist. 

Batcher, M.S. 2002. Element Stewardship Abstract for (Elytrigia repens va. repens) Quackgrass 

[Web Page]. Located at: http://tncweeds.ucdavis.edu. Accessed on: 13 April 2004. 

Beard, R. and J. Carbone. 2001. Invasive Plant Management Decision and Environmental 

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Program Description. SERA TR 02-43-17-02a. 

SERA (Syracuse Environmental Research Associates, Inc.). 2004g. Documentation for the use of 

GLEAMS (Version 3) and auxiliary programs in Forest Service risk assessments 

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Sheehan, M. 2005. Biological assessment for the buckhead knotweed glyphosate treatment 

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Sheley, R.L. and J.K. Petroff, eds. 1999. Biology and management of noxious rangeland weeds. 

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Soll, J. 2004a. Controlling Knotweed in the Pacific Northwest. The Nature Conservancy, Oregon 

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Soll, J. 2004b. Personal communication. Willamette Basin Conservation Director, The Nature 

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Somasundaram, L. and J.R. Coats. 1991. Pesticide transformation products: fate and significance 

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Spray Drift Task Force. 1997. A summary of ground application studies. 

Stein, M. 2005. Personal communication. Forest botanist, USDA Forest Service, Siuslaw 

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Sandy, Oregon. 

Stephenson, G. R., K. R. Solomon, C. S. Bowhey, and K. Liber. 1990. Persistence, leachability, 

and lateral movement of triclopyr (Garlon) in selected Canadian forestry soils. Journal of 

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Sullivan, T.P., R.G. Wagner, D.G. Pitt, R.A. Lautenschlager, and D.G. Chen. 1998a. Changes in 

diversity of plant and small mammal communities after herbicide application in sub-boreal 

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References-12 
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Sullivan, T.P., C. Nowotny, and R.A. Lautenschlager. 1998b. Silvicultural use of herbicide in 

sub-boreal spruce forest: implications for small mammal population dynamics. Journal of 

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Sullivan, T.P. 1994. Influence of Herbicide-Induced Habitat Alteration on Vegetation and 

Snowshoe Hare Populations in Sub-Boreal Spruce Forest. Journal of Applied Ecology 31(4): 

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Sylvia, D.M. and A.G. Jarstfer. 1997. Distribution of mycorrhiza on competing pines and weeds 

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The Research Group. 2000. Economic Analysis of containment Programs, Damages, and 

Production Losses from Noxious Weeds in Oregon. Oregon Department of Agriculture Plant 

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Thurman, R. 2005. Personal communication. Wildlife Biologist, USDA Forest Service, Mt. 

Hood National Forest, Barlow Ranger District. Durfur. Oregon. 

Topik, C., N.M Halverson, and T. High. 1988. Plant Association and Management Guide for the 

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Tu, M., et al. 2001. Sethoxydim. Weed Control Methods Handbook. The Nature Conservancy. 

Tu, M., C. Hurd, & J.M. Randall. 2001. Weed Control Methods Handbook: Tools and 

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Tyser, R.W. 1992. Vegetation associated with two alien plant species in a fescue grassland in 

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U.S. Census Bureau. 2004. Small Area Income & Poverty Estimates: Estimates for Oregon 

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2005. 

U.S. Department of Agriculture. Forest Service. 1988. General Water Quality Best Management 

Practices. Pacific Northwest Region. Oregon. 

References-13 
Final Environmental Impact Statement 

U.S. Department of Agriculture. Forest Service. 1990a. Final Environmental Impact Statement: 

Land and Resource Management Plan. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1990b. Land and Resource Management Plan: 

Mt. Hood National Forest. As amended. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1992. Clackamas National Wild and Scenic 

River and State Scenic Waterway. Environmental Assessment and Management Plan. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1993a. Environmental Assessment for the 

Management of Noxious Weeds. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1993b. Roaring National Wild and Scenic River. 

Environmental Assessment and Management Plan. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1993c. Salmon National Wild and Scenic River. 

Management Plan. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture, Forest Service. 1993d. Wells Island Open Space Plan. Columbia 

River Gorge National Scenic Area. Oregon. 

U.S. Department of Agriculture. Forest Service. 1994a. Fish Creek Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1994b. Mile Creeks Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1994c. Pesticide-Use Management and 

Coordination Handbook. Washington Office. Washington D.C. 

U.S. Department of Agriculture. Forest Service. 1994d. Upper Sandy National Wild and Scenic 

River. Management Plan. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1994e. White River National Wild and Scenic 

River. Management Plan. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1995a. Collawash/Hot Springs Watershed 

Analysis. Revised 2003. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1995b. Eagle Creek Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1995c. Final Environmental Impact State for the 

Sandy River Delta Plan. Columbia River Gorge National Scenic Area. Oregon. 

U.S. Department of Agriculture. Forest Service. 1995d. Salmon River Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

References-14 
Site-Specific Invasive Plant Treatments 

U.S. Department of Agriculture. Forest Service. 1995e. Sandy River Delta Plan. Columbia River 

Gorge National Scenic Area. Oregon. 

U.S. Department of Agriculture. Forest Service. 1995f. Upper Clackamas River Watershed 

Analysis. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1995g. White River Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1995h. Zigzag River Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1996a. Clackamas River – Oak Grove Fork 

Watershed Analysis. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1996b. East Fork Hood River and Middle Fork 

Hood River Watershed Analysis. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1996c. Environmental Assessment for the 

Control and Management of Noxious Weeds and Blackberries on Selected Lands within the 

Columbia River Gorge National Scenic Area. Columbia River Gorge National Scenic Area. 

Oregon. 

U.S. Department of Agriculture. Forest Service. 1996d. Lower Clackamas River Watershed 

Analysis. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1996e. North Fork Clackamas River Watershed 

Analysis. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1996f. Roaring River Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1996g. Upper Sandy Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1996h. West Fork of Hood River Watershed 

Analysis. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1997a. Bull Run River Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1997b. Olallie Lake Watershed Analysis. Mt. 

Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1997c. South Fork of Clackamas River 

Watershed Analysis. Mt. Hood National Forest. Oregon. 

References-15 
Final Environmental Impact Statement 

U.S. Department of Agriculture. Forest Service. 1998a. Columbia River Tributaries East 

Watershed Analysis. Mt. Hood National Forest. Oregon. 

U.S. Department of Agriculture. Forest Service. 1998b. Control and Management of Noxious 

Weeds on the Barlow Ranger District, Mt. Hood National Forest. Mt. Hood National Forest. 

Oregon. 

U.S. Department of Agriculture. Forest Service. 1999a. Oregon Columbia River Tributaries West 

Watershed Analysis. Columbia River Gorge National Scenic Area. Oregon. 

U.S. Department of Agriculture, Forest Service. 1999b. Stemming the invasive tide: Forest 

Service strategy for noxious and nonnative invasive plant management. Washington Office. 

Washington, D.C. 

U.S. Department of Agriculture. Forest Service. 2000a. Mill Creek Watershed Analysis. 

Columbia River Gorge National Scenic Area. Oregon. 

U.S. Department of Agriculture, Forest Service. 2000b. USDA Forest Service Landbird Strategic 

Plan. Washington Office. Washington, D.C. (FS-648) 

U.S. Department of Agriculture, Forest Service. 2001. Guide to Noxious Weed Prevention 

Practices. Washington Office. Washington, D.C. 

U.S. Department of Agriculture, Forest Service. 2002. Field Guide Invasive Plant Inventory, 

Monitoring and Mapping Protocol. Washington Office. Washington, D.C. 

U.S. Department of Agriculture. Forest Service. 2003. Salmon-Challis National Forest Noxious 

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U.S. Department of Agriculture. Forest Service. 2005a. Pacific Northwest Region Invasive Plant 

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U.S. Department of Agriculture. Forest Service. 2005b. Pacific Northwest Region Invasive Plant 

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U.S. Department of Agriculture, Forest Service. 2005c. Biological Assessment for the USDA 

Forest Service Pacific Northwest Region Invasive Plant Program. Portland, Oregon. 

U.S. Department of Agriculture, Forest Service. 2005d. Rowena Plan. Columbia River Gorge 

National Scenic Area. Oregon. 

U.S. Department of Agriculture, Forest Service and U.S. Department of Interior, Bureau of Land 

Management. 1994. Final Supplemental Environmental Impact Statement on Management of 

Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of 

the Northern Spotted Owl. Oregon, Washington and Northern California. 

References-16 
Site-Specific Invasive Plant Treatments 

U.S. Department of Agriculture, Forest Service and U.S. Department of Interior, Bureau of Land 

Management. 2001. Record of Decision and Standards and Guidelines for Amendments to 

the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and 

Guidelines. Oregon, Washington and Northern California. 

U.S. Department of Agriculture, Forest Service and U.S. Department of Interior, Bureau of Land 

Management. 2004. Record of Decision to Remove or Modify the Survey and Manage 

Mitigation Measure Standards and Guidelines. Oregon, Washington and Northern California. 

U.S. Department of Commerce, National Oceanic & Atmospheric Administration (NOAA). 

2003. Endangered Species Act – Section 7 Consultation Biological Opinion and MagnusonSteven Fishery Conservation and Management Act Essential Fish Habitat Consultation. 

Control of Knotweed on Bureau of Land management-Administered Lands, Sandy River 

Basin, Multnomah and Clackamas Counties, Oregon. USDI BLM, Salem District. NOAA 

National Marine Fisheries Service, Northwest Region. 

U.S. Department of Interior, Fish and Wildlife Service (FWS). 2005. Biological Opinion, 

Concurrence, and Conference Report on the Effects to 23 Species and 4 Critical Habitats 

from the U.S. Forest Service Pacific Northwest Regional Invasive Plant Program. (USFWS 

Reference Number 1-7-05-7-0653). 

U.S. Department of Agriculture, Natural Resources Conservation Service (NRCS). 1999. 

Noxious, Invasive, and Alien Plant Species: A Challenge in Wetland Restoration & 

Enhancement. [Web Page]. Located at: http://www.pwrc.usgs.gov/WLI/wris1.htm. Accessed 

on: 27 April 2006. 

U.S. Government Accountability Office. 2005. Invasive Species: Cooperation and Coordination 

Are Important for Effective Management of Invasive Weeds. Report to the Chairman, 

Committee on Resources, House of Representatives. GAO-05-185. [Web Page]. Located at: 

http://www.gao.gov/cgi-bin/getrpt?GAO-05-185. Accessed on: 12 September 2005. 

Van der Putten, W.H. 1997. Plant-soil feedback as a selective force. Tree 12(5):169-70. 

Wasco County Soil and Water Conservation District (SWCD). 2002. Mosier Watershed 

Assessment. The Dalles. Oregon. 

Waters, T.F. 1995. Sediment in streams: sources, biological effects, and control. American 

Fisheries Society Monograph 7. 

Weed Research and Information Center. 2006. Yellow Star Thistle Information. [Web Page]. 

Located at: http://wric.ucdavis.edu/yst/manage/management.html. Accessed on: 19 April 

2006. 

Weis, J., G. Smith, T. Zhou, C. Santiago-Bass, and P. Weis. 2001. Effect of contaminants on 

behavior: biochemical mechanisms and ecological consequences. BioScience 51(3): 209-

217. 

References-17 
Final Environmental Impact Statement 

References-18 

Wentz, D.A., B.A. Bonn, K.D. Carpenter, S.R. Hinkle, M.L. Janet, F.A. Rinella, M.A. Uhrich, 

I.R. Waite, A. Laenen, and K.E. Bencala. 1998, Water Quality in the Willamette Basin, 

Oregon, 1991-95: U.S. Geological Survey Circular 1161, updated June 25, 1998. [Webpage] 

Located at: http://water.usgs.gov/pubs/circ1161. Accessed on: July 2006. 

Whitson, T.D. Editor. 2001. Weeds of the West. 5th ed. Parker, R., Lee, R.D., Nelson, 

B.E...Cudney, D.W., Burrill, L.C., Dewey and others. Pioneer of Jackson Hole, Jackson, 

WY: The Western Society of Weed Science. 

William, R.D., A.G. Dailey, D. Ball, J. Colquhoun, R. Parker, J.P. Yenish, T.W. Miller, D.W. 

Morishita, and P.J.S. Hutchinson. 2004. Pacific Northwest Weed Management Handbook. 

Oregon State University (revised annually). 

Woodward DF. 1976. Toxicity of the herbicides dinoseb and picloram to cutthroat (Salmo clarki) 

and lake trout (Salvelinu namaycush). Journal of the Fisheries Research Board of Canada

33:1671-1676. 

Woodward, D.F. 1979. Assessing the hazard of picloram to cutthroat trout. Journal of Range 

Management 32(3): 230-232. 

Wydoski, R.S., and R.L. Whitney. 2003. Inland fishes of Washington. Second edition. University 

of Washington Press, Seattle, Washington. 

Zollinger, R.K. 2005. 2005 North Dakota Weed Control Guide. 2005 North Dakota Herbicide 

Compendium, W-253. 2005. North Dakota State University Extension Service. [Web Page]. 

Located at: http://www.ag.ndsu.nodak.edu?weeds/w253/w253-5b.htm. Accessed on: 9 July 

2005. 
Glossary 
 
Site-Specific Invasive Plant Treatments 

GLOSSARY 

Abiotic – Not biotic; not pertaining to life. 

Active Ingredient (ai) - In any pesticide product, the component (a chemical or biological 

substance) that kills or otherwise controls the target pests. Pesticides are regulated primarily on 

the basis of active ingredients. The remaining ingredients are called “inerts.” 

Active Restoration - The deliberate activities related to restoration. As an example, this might 

include seeding native grasses and planting native scrubs and trees. 

Acute Effect - An adverse effect on any living organism in which severe symptoms develop 

rapidly and often subside after the exposure stops. 

Acute Exposure - A single exposure or multiple brief exposures occurring within a short time 

(e.g., 24 hours or less in humans). The classification of multiple brief exposures as “acute” is 

dependant on the life span of the organism. (See also chronic exposure and cumulative exposure)

Acute Toxicity - Any harmful effect produced in an organism through an acute exposure to one 

or more chemicals. 

Adaptation - Changes in an organism's physiological structure or function or habits that allow it 

to survive in new surroundings. 

Adapted - How well organisms are physiologically or structurally suited for survival, growth, 

and resistance to pests and diseases in a particular environment. 

Adaptive Management - A continuing process of action-based planning, monitoring, 

researching, evaluating, and adjusting with the objective of improving implementation and 

achieving the goals of the standards and guidelines. 

Additive Effect - A situation in which the combined effects of exposure to two chemicals 

simultaneously is equal to the sum of the effect of exposure to each chemical given alone. The 

effect most commonly observed when an organism is exposed to two chemicals together is an 

additive effect. 

Adfluvial – fish that live in a lake or reservoir for most of their adult life but move into a stream 

or river to spawn. 

Adjuvant(s) - Chemicals that are added to pesticide products to enhance the toxicity of the 

active ingredient or to make the active ingredient easier to handle or mix. 

Administratively Withdrawn Areas (AWA) - Areas removed from the suitable timber base 

through agency direction and land management plans. 

Glossary-1 
Final Environmental Impact Statement 

Adsorption - The tendency of one chemical to adhere to another material such as soil. 

Aerobic - Life or processes that require, or are not destroyed by, the presence of oxygen. (See 

also anaerobic)

Affected Environment - Existing biological, physical, social, and economic conditions of an 

area subject to change, both directly and indirectly, as the result of a proposed human action. 

Agent - Any substance, force, radiation, organism, or influence that affects the body. The effects 

may be beneficial or injurious. 

Agency for Toxic Substances and Disease Registry (ATSDR) - Federal agency within the 

Public Health Service charged with carrying out the health-related analyses under 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and 

Superfund Amendments and Reauthorization Act (SARA). 

Alien Species - “With respect to a particular ecosystem, any species, including its seeds, eggs, 

spores, or other biological material capable of propagating that species, that is not native to that 

ecosystem” (Executive Order 13122, 2/3/99). (See also exotic species, invasive plant species, 

introduced species, and noxious weed)

Allelopathy - The suppression of growth of one plant species due to the release of toxic 

substances by another plant. 

Alluvial - Relating to clay, silt, sand, gravel, or similar detrital material deposited by flowing 

water. Alluvial deposits may occur after a heavy rain storm. 

Ambient - Usual or surrounding conditions. 

Amphibian - Any of a class of cold-blooded vertebrates (including frogs, toads, or salamanders) 

intermediate in many characteristics between fishes and reptiles and having gilled aquatic larvae 

and air-breathing adults. 

Anadromous - Fish that spend their adult life in the sea but swim upriver to fresh water 

spawning grounds to reproduce. 

Anaerobic - Life or process that occurs in, or is not destroyed by, the absence of oxygen. (See 

also aerobic)

Anions - Negatively charged ions in solution e.g., hydroxyl or OH- ion. (See also cations)

Annual - A plant that endures for not more than a year. A plant which completes its entire life 

cycle from germinating seedling to seed production and death within a year. 

Glossary-2 
Site-Specific Invasive Plant Treatments 

Annuity - Payment or receipt of a series of equal amounts at stated intervals for a specified 

number of time periods. An “annuity due” is a series of equal value outputs or inputs occurring 

for N equal time periods with “payments” made at the beginning of each period. 

Anoxia - Literally, "without oxygen.” A deficiency of oxygen reaching the tissues of the body 

especially of such severity as to result in permanent damage. 

Aquatic Influence Zone – Land adjacent to perennial and intermittent streams, rivers, ponds, 

lakes, springs, and wetlands that have a direct or potentially direct influence on the water body 

and its function where herbicides may enter surface waters. This zone has a default width of 100 

feet, realizing that in some areas it may be wider or narrower pending a site-specific review. 

Aqueous - Describes a water-based solution or suspension. 

Aquifer - An underground geological formation or group of formations containing usable 

amounts of groundwater that can supply wells and springs. 

Arid - A terrestrial region lacking moisture, or a climate in which the rainfall is not sufficient to 

support the growth of most vegetation. 

Background Level - In pollution, the level of pollutants commonly present in ambient media 

(air, water, soil.) 

Bacteria - Microscopic living organisms that metabolize organic matter in soil, water, or other 

environmental media. Some bacteria can also cause human, animal and plant health problems. 

Basal Herbicide Application Method - In pesticides, the spreading of a chemical on stems or 

trunks of plants just above the soil line. 

Base - Substances that (usually) liberate hydroxyl (OH-) anions when dissolved in water and 

weaken a strong acid. 

Benchmark - A dose associated with a defined effect level or designated as a no effect level. 

Benthic Region - The bottom layer of a body of water. 

Benthos - The plants and animals that inhabit the bottom layer of a water body. 

Best Management Practices (BMP) - A practice or combination of practices determined by a 

state or an agency to be the most effective and practical means (technological, economic, and 

institutional) of controlling point and non-point source pollutants at levels compatible with 

environmental quality. 

Bioaccumulation - The increase in concentration of a substance in living organisms as they take 

in contaminated air, water, or food because the substance is very slowly metabolized or excreted 

(often concentrating in the body fat.) 

Glossary-3 
Final Environmental Impact Statement 

Bioassay - (1) To measure the effect of a substance, factor, or condition using living organisms. 

(2) A test to determine the toxicity of an agent to an organism. 

Bioconcentration - The accumulation of a chemical in tissues of a fish or other organism to 

levels greater than in the surrounding water or environment. 

Bioconcentration Factor (BCF) - The concentration of a compound in an aquatic organism 

divided by the concentration in the ambient water of the organism. 

Biodegradability - Susceptibility of a substance to decomposition by microorganisms; 

specifically, the rate at which compounds may be chemically broken down by bacteria and/or 

natural environmental factors. 

Biodiversity or Biological Diversity - The diversity of living things (species) and of life 

patterns and processes (ecosystem structures and functions). Includes genetic diversity, 

ecosystem diversity, landscape and regional diversity, and biosphere diversity. 

Biological Control - The use of natural enemies, including invertebrate parasites and predators 

(usually insects, mites, and nematodes,) and plant pathogens to reduce populations of nonnative, 

invasive plants. 

Biological Magnification - The process whereby certain substances such as pesticides or heavy 

metals increase in concentration as they move up the food chain. 

Biologically Sensitive - A term used to identify a group of individuals who, because of their 

developmental stage or some other biological condition, are more susceptible than the general 

population to a chemical or biological agent in the environment. 

Biomass - The amount of living matter. 

Biota or Biome - All living organisms of a region or system. 

Body Burden - The amount of a chemical stored in the body at a given time, especially a 

potential toxin in the body as the result of exposure. 

Broadcast Herbicide Application Method - Herbicide treatment method generally used along 

roads; boom truck spray is directed at target species. Broadcast methods are used for larger 

infestations where spot treatments would not be effective. 

Bryophytes - Plants of the phylum Bryophyta, including mosses, liverworts, and hornworts; 

characterized by the lack of true roots, stems, and leaves. 

Buffer Zone - A strip of untreated land that separates a waterway or other environmentally 

sensitive area from an area being treated with pesticides. 

Glossary-4 
Site-Specific Invasive Plant Treatments 

Candidate Species - Those plant and animal species that, in the opinion of the Fish and Wildlife 

Service (FWS) or National Oceanic and Atmospheric Administration (NOAA) Fisheries, may 

qualify for listing as “endangered” or “threatened.” The FWS recognizes two categories of 

candidates. Category 1 candidates are taxa for which the FWS has on file sufficient information 

to support proposals for listing. Category 2 candidates are taxa for which information available 

to the FWS indicates that proposing to list is possibly appropriate, but for which sufficient data 

are not currently available to support proposed rules. 

Canons of Treaty Construction - Tools the federal courts developed for interpreting Indian 

treaties. 

Capillary Fringe - The zone above the water table within which the soil or rock is saturated by 

water under less than atmospheric pressure. 

Carcinogen - A chemical capable of inducing cancer. 

Carrier - A non-pesticidal substance added to a commercial pesticide formulation to make it 

easier to handle or apply. 

Chemical Abstracts Service (CAS) Registry Number - An assigned number used to identify a 

chemical. Chemical Abstracts Service is an organization that indexes information published in 

Chemical Abstracts by the American Chemical Society and that provides index guides to help 

locate information about particular substances in the abstracts. Sequentially assigned CAS 

numbers identify specific chemicals. The numbers have no chemical significance. The CAS 

number is a concise, unique means of chemical identification. 

Cations - Positively charged ions in a solution. (See also anion)

Characteristic Landscape - The naturally established landscape within a scene or scenes being 

viewed. 

Chronic Exposure - Exposures that extend over the average lifetime or for a significant fraction 

of the lifetime of the species (for a rat, chronic exposure is typically about two years). Chronic 

exposure studies are used to evaluate the carcinogenic potential of chemicals and other long-term 

health effects. (See also acute and cumulative exposure)

Chronic Reference Dose (RfD) - An estimate of a lifetime daily exposure level (in mg/kg/day) 

for the human population, including sensitive subpopulations, that is likely to be without an 

appreciable risk of deleterious effects. Chronic RfDs are specifically developed to be protective 

for long-term exposure to a compound (seven years to lifetime.) 

Chronic Toxicity - The ability of a substance or mixture of substances to cause harmful effects 

over an extended period, usually upon repeated or continuous exposure sometimes lasts for the 

entire life of the exposed organism. 

Clipping - To cut or remove seed heads and/or fruiting bodies to prevent germination. 

Glossary-5 
Final Environmental Impact Statement 

Clipping and Pulling - Cutting a portion of the invasive plant stem and pulling it from its 

substrate, generally the bole of a tree. 

Code of Federal Regulations (CFR) - Document that codifies all rules of the executive 

departments and agencies of the federal government. It is divided into fifty volumes, known as 

titles. Title 40 of the CFR (referenced as 40 CFR) lists all environmental regulations, including 

regulations for EPA pesticide programs (40 CFR Parts 150-189). 

Common Control Measures – A set of commonly used methods to effectively treat specific 

invasive plants. 

Competitive Seeding - Treatment method; most effective after weed populations have been 

reduced by other control actions.

Congressionally Reserved Areas (CRA) - Areas that require Congressional enactment for their 

establishment, such as National Parks, Wild and Scenic Rivers, National Recreation Areas, 

National Monuments, and Wilderness. Also referred to as Congressional Reserves. Includes 

similar areas established by Executive Order, such as National Monuments. 

Conifer - An order of the Gymnospermae, comprising a wide range of trees and a few shrubs, 

mostly evergreens that bear cones and have needle-shaped or scale-like leaves. Conifer timber is 

commercially identified as softwood. 

Connected Actions - Exposure to other chemical and biological agents, in addition to exposure 

to a specific pesticide formulation in a field application to control pest organisms. 

Contaminants - For chemicals, impurities present in a commercial grade chemical. For 

biological agents, other agents that may be present in a commercial product. 

Contain - Prevent the spread of the invasive plants beyond the perimeter of the patches or 

infestation areas mapped from the inventories as of November 2004. 

Control - Means, as appropriate, eradicating, suppressing, reducing, or managing invasive 

species populations, preventing spread of invasive species from areas where they are present, and 

taking steps such as restoration of native species and habitats to reduce the effects of invasive 

species and to prevent further invasions (Executive Order 13122, 2/3/99). 

Cultural Treatment Method / Control - The establishment or maintenance of competitive 

vegetation, use of fertilizing, mulching, prescribed burning, or grazing animals to control or 

eliminate invasive plants. 

Cumulative Effect - The impact on the environment that results from the incremental impact of 

the action when added to other past, present, and reasonably foreseeable future actions—

regardless of what agency (federal or non-federal) or person undertakes such other actions. 

Cumulative impacts can result from individually minor, but collectively significant, actions 

taking place over a period of time (40 CFR 1508.7). 

Glossary-6 
Site-Specific Invasive Plant Treatments 

Cumulative Exposure - Exposure resulting from one or more activities that are repeated over a 

period of time. (See also acute and chronic exposure)

Cut-Stump Herbicide Treatment Method - Used on woody species that normally re-sprout 

after being cut. Cut down the tree or shrub, and immediately spray or squirt herbicide on the 

exposed cambium (living inner bark) of the stump. 

Detritus - Loose fragments, particles, or grains formed by the disintegration of organic matter or 

rocks. 

Discount - In economics, discounting is the process of carrying an end value backward in time at 

compound interest. 

Distance Zones - Landscape areas denoted by specified distances from the observer. Used as a 

frame of reference in which to discuss landscape attributes or the scenic effect of human 

activities in a landscape. 

Disturbance - An effect of a planned human management activity, or unplanned native or exotic 

agent or event that changes the state of a landscape element, landscape pattern, or regional 

composition. 

Dosage/Dose - (1) The actual quantity of a chemical administered to an organism or to which it 

is exposed. (2) The amount of a substance that reaches a specific tissue (e.g. the liver). (3) The 

amount of a substance available for interaction with metabolic processes after crossing the outer 

boundary of an organism. 

Dose Rate - In exposure assessment, dose per time unit (e.g. mg/day); also called dosage. 

Dose Response - Changes in toxicological responses of an individual (such as alterations in 

severity of symptoms) or populations (such as alterations in incidence) that are related to changes 

in the dose of any given substance. 

Drift - The portion of a sprayed chemical that is moved by wind off of a target site. 

Early Detection Rapid Response (EDRR) - A process by which new infestations are identified, 

characterized, evaluated, and by which an effective treatment is designated, all of which are 

clearly analyzed in this NEPA document. 

Effect - Adverse and/or beneficial direct effects occur at the same time and in the same general 

location as the activity causing the effects. Adverse and beneficial indirect effects are those that 

occur at a different time or location from the activity causing the effects. Both types of effects 

are described in terms of increase or decreases, intensity, duration, and timing.

Endangered Species - Any species listed in the Federal Register as being in danger of 

extinction throughout all, or a significant portion, of its range. 

Glossary-7 
Final Environmental Impact Statement 

Endangered Species Act (ESA) - A law passed in 1973 to conserve species of wildlife and 

plants, determined by the Director of the U.S. Fish and Wildlife Service or the NOAA Fisheries 

to be endangered or threatened with extinction in all or a significant portion of its range. Among 

other measures, ESA requires all federal agencies to conserve these species and consult with the 

Fish and Wildlife Service or NOAA Fisheries on federal actions that may affect these species or 

their designated critical habitat. 

Endemic - A species or other taxonomic group that is restricted to a particular geographic region 

due to factors such as isolation or response to soil or climatic conditions. (Compare to 

“Indigenous” and “Native.”) 

Environmental Justice - Executive Order 12898 of February 11, 1994 requires federal agencies, 

to the greatest extent practicable and permitted by law, to make achieving environmental justice 

part of its mission by identifying and addressing, as appropriate, disproportionately high and 

adverse human health or environmental effects of its programs, policies, and activities on 

minority populations and low-income populations in the United States and its territories and 

possessions, the District of Columbia, the Commonwealth of Puerto Rico, and the 

commonwealth of the Mariana Islands. 

Eradicate – Attempt to totally eliminate an invasive plant species from the Forest and Scenic 

Area, recognizing that this may not actually be achieved in the short-term since reestablishment/re-invasion may take place initially. 

Evolutionary Significant Unit (ESU) – a group of salmon or trout populations that is a distinct 

population segment. Scientists established two criteria for ESUs: 1) the population must show 

substantial reproductive isolation; and 2) there must be an important component of the 

evolutionary legacy of the species as a whole. 

Essential Fish Habitat - waters and substrate necessary to fish (specifically chinook and coho 

salmon) for spawning, breeding, feeding, or growth to maturity. 

Exposure Assessment - The process of estimating the amount of contact with a chemical or 

biological agent that an individual or a population of organisms will receive from a pesticide 

application conducted under specific, stated circumstances. 

Exposure of Concern - A level of exposure greater than the level determined to have “no 

observable adverse effect.” This level was made more conservative in the R6 2005 FEIS to add a 

margin of safety to the risk assessment process. 

Exposure Scenario - The mechanism by which an organism (person, animal, fish) may be 

exposed to herbicides or additives. The application rate and method influences the amount of 

herbicide to which an organism may be exposed.

Exotic – Non-native species; introduced from elsewhere, but not completely naturalized. (See 

also exotic species, invasive plant species, introduced species, and noxious weed)

Glossary-8 
Site-Specific Invasive Plant Treatments 

Extirpate - To destroy completely; wipe out. 

Extrapolation - The use of a model to make estimates of values of a variable in an unobserved 

interval from values within an already observed interval. 

Fauna - The animals of a specified region or time. 

Federally Listed Species - Formally listed as a threatened or endangered species under the 

Endangered Species Act. Designations are made by the Fish and Wildlife Service or the National 

Marine Fisheries Service. 

Federal Insecticide and Rodenticide Act (FIFRA) Pesticide Ingredient - An ingredient of a 

pesticide that must be registered with EPA under the Federal Insecticide, Fungicide, and 

Rodenticide Act. Products making pesticide claims must submit required information to EPA to 

register under FIFRA and may be subject to labeling and use requirements. 

Fertilization - Treatment method involving adding of nutrients, which could improve the 

success of desirable species; may be limited, depending on species/soil characteristics. 

Flora - Plant life, especially all the plants found in a particular country, region, or time regarded 

as a group. Also, a systematic set of descriptions of all the plants of a particular place or time. 

Fluvial – Living in a stream or river. 

Foaming - Hot foam is a mechanical method that is effective on seedlings and annuals and can 

be applied under certain weather conditions, including wind and light rain. 

Foliar – Relating to, or applied to leaves. 

Food Chain - A hierarchical sequence of organisms, each of which feeds on the next, lower 

member of the sequence. 

Forage - Food for animals. In this document, term applies to both availability of plant material 

for wildlife and domestic livestock. 

Formulation - A commercial preparation of a chemical including any inerts and/or 

contaminants. 

Frill - Also called the “hack and squirt” treatment. Used to treat woody species with large, thick 

trunks. The tree is cut using a sharp knife, saw, or ax, or drilled with a power drill or other 

device. Herbicide is then immediately applied to the cut with a backpack sprayer, squirt bottle, 

syringe, or similar equipment.

Fry – Recently hatched fish. 

Glossary-9 
Final Environmental Impact Statement 

Fungi - Molds, mildews, yeasts, mushrooms, and puffballs, a group of organisms that lack 

chlorophyll and therefore are not photosynthetic. They are usually non-mobile, filamentous, and 

multi-cellular. 

Game Fish - Species like trout, salmon, or bass, caught for sport. Many of them show more 

sensitivity to environmental change than non-game fish. 

Grazing Animals - Treatment method which requires matching the invasive species with the 

appropriate grazer for best success. 

Groundwater Loading Effects of Agricultural Management Systems (GLEAMS) – A model 

which displays herbicide concentrations in streams under a variety of conditions. 

Groundwater - The supply of fresh water found beneath the Earth's surface, usually in aquifers, 

which often supply wells and springs. 

Habitat - The place where a population (e.g., human, animal, plant, microorganism) lives and its 

surroundings, both living and non-living. 

Hack and Squirt Herbicide Treatment Method - Also called the “frill” method. Used to treat 

woody species with large, thick trunks. The tree is cut using a sharp knife, saw, or ax, or drilled 

with a power drill or other device. Herbicide is then immediately applied to the cut with a 

backpack sprayer, squirt bottle, syringe, or similar equipment.

Halftime or Half-Life - The time required for the concentration of the chemical to decrease by 

one-half. 

Hand/Selective Herbicide Application- Herbicide treatment of individual plants through 

wicking, wiping, injecting stems, etc., with low likelihood of drift or delivery of herbicides away 

from treatment sites. This method ensures no herbicide directly contacts soil. 

Hand-pulling/Grubbing - Treatment method which is labor-intensive but effective on single 

plants or on small, low-density infestations.

Hazard Quotient (HQ) - The ratio of the estimated level of exposure to a substance from a 

specific pesticide application to the RfD for that substance, or to some other index of acceptable 

exposure or toxicity. A HQ less than or equal to one is presumed to indicate an acceptably low 

level of risk for that specific application. 

Hazard Identification - The process of identifying the array of potential effects that an agent 

may induce in an exposed of humans or other organisms. 

Herbaceous - A plant that does not develop persistent woody tissue above the ground (annual, 

biennial, or perennial.) Herbaceous vegetation includes grasses and grass-like vegetation, and 

broadleaved forbs. 

Glossary-10 
Site-Specific Invasive Plant Treatments 

Herbicide - A chemical preparation designed to kill plants, especially weeds, or to otherwise 

inhibit their growth. 

Herbicide Treatment Method / Control - The use of naturally derived or synthetic chemicals 

called herbicides to eliminate or control the growth of invasive plants. 

Humus - Organic portion of the soil remaining after prolonged microbial decomposition. 

Indian Tribe - Any American Indian or Alaska Native tribe, band, nation, pueblo, community, 

rancheria, colony, or group meeting the provisions of the Code of Federal Regulations Title 25, 

Section 83.7 (25 FR 83.7), or those recognized in statutes or treaties with the United States. 

Indigenous - An indigenous species is any which were or are native or inherent to an area. (See 

also, native.) 

Inerts - Anything other than the active ingredient in a pesticide product; not having pesticide 

properties. 

Infested Area - A contiguous area of land occupied by, in this case, invasive plant species. An 

infested area of land is defined by drawing a line around the actual perimeter of the infestation as 

defined by the canopy cover of the plants, excluding areas not infested. Generally, the smallest 

area of infestation mapped will be 1/10th (0.10) of an acre or 0.04 hectares. 

Integrated Weed Management (IWM) - An interdisciplinary weed management approach for 

selecting methods for preventing, containing, and controlling noxious weeds in coordination with 

other resource management activities to achieve optimum management goals and objectives. 

Interdisciplinary Team (IDT) - A group of individuals with varying areas of specialty 

assembled to solve a problem or perform a task. The team is assembled out of recognition that no 

one scientific discipline is sufficiently broad enough to adequately analyze the problem and 

propose action. 

Introduced Species - An alien or exotic species that has been intentionally or unintentionally 

released into an area as a result of human activity. (See also exotic species, invasive plant 

species, introduced species, and noxious weed)

Introduction - “The intentional or unintentional escape, release, dissemination, or placement of 

a species into an ecosystem as a result of human activity” (Executive Order 13122, 2/3/99). 

Invasive Plant Species - An alien plant species whose introduction does or is likely to cause 

economic or environmental harm or harm to human health (Executive Order 13122, 2/3/99). (See 

also exotic species, invasive plant species, introduced species, and noxious weed)

Irreversible Effect - Effect characterized by the inability of the body to partially or fully repair 

injury caused by a toxic agent. 

Glossary-11 
Final Environmental Impact Statement 

Irritant - Non-corrosive material that causes a reversible inflammatory effect on living tissue by 

chemical action at the site of contact as a function of concentration or duration of exposure. 

Key Issue – Significant issues identified by the public that are used to formulate alternatives, 

affect the design of alternative components, prescribe PDC, or describe environmental effects. 

LC50 (Lethal Concentration50) - A calculated concentration of a chemical in air or water to 

which exposure for a specific length of time is expected to cause death in 50 percent of a defined 

experimental animal population. 

LD50 (Lethal Dose50) - The dose of a chemical calculated to cause death in 50 percent of a 

defined experimental animal population over a specified observation period. The observation 

period is typically 14 days. 

Label - All printed material attached to, or part of, the pesticide container. 

Land Allocation - Commitment of a given area of land or a resource to one or more specific 

uses (e.g. wilderness). In the Northwest Forest Plan, one of the seven allocations of 

Congressionally Withdrawn Areas, Late-Successional Reserves, Adaptive Management Areas, 

Managed Late-Successional Areas, Administratively Withdrawn Areas, Riparian Reserves, or 

Matrix. 

Landscape - An area composed of interacting ecosystems that are repeated because of geology, 

land form, soils, climate, biota, and human influences throughout the area. Landscapes are 

generally of a size, shape, and pattern which are determined by interacting ecosystems. 

Landscape Character - Particular attributes, qualities, and traits of a landscape that give it an 

image and make it identifiable or unique. 

Landscape Setting - The context and environment in which a landscape is set; a landscape 

backdrop. It is the combination of land use, landform, and vegetation patterns that distinguish an 

area in appearance and character from other areas. 

Leachate - Water that collects chemicals as it trickles through soil or other porous media 

containing the chemicals. 

Leaching - The process by which chemicals on or in soil or other porous media are dissolved 

and carried away by water, or are moved into a lower layer of soil. 

Level of Concern (LOC) - The concentration in media or some other estimate of exposure 

above which there may be effects. 

Lichens - Complex thallophytic plants comprised of an alga and a fungus growing in symbiotic 

association on a solid surface (such as a rock.) 

Glossary-12 
Site-Specific Invasive Plant Treatments 

Littoral zone - (1) That portion of a body of fresh water extending from the shoreline lakeward 

to the limit of occupancy of rooted plants. (2) The strip of land along the shoreline between the 

high and low water levels. 

Lowest-Observed-Adverse-Effect Level (LOAEL) - The lowest dose of a chemical in a study, 

or group of studies, that produces statistically or biologically significant increases in frequency 

or severity of adverse effects between the exposed and control populations. 

Macroinvertebrate – Animals without backbones such as insects, clams, snails, etc. 

Macrophyte – Terrestrial or aquatic plant that is large enough to be seen without the aid of a 

microscope. 

Manual Treatment Method/Control - The use of any non-mechanized approach to control or 

eliminate invasive plants (i.e. hand-pulling, grubbing.) 

Material Safety Data Sheet (MSDS) - A compilation of information required under the OSHA 

Communication Standard on the identity of hazardous chemicals, health and physical hazards, 

exposure limits, and precautions. 

Mechanical Treatment Method/Control - The use of any mechanized approach to control or 

eliminate invasive plants (i.e. mowing, weed whipping, hot foam.) 

Microorganisms - A generic term for all organisms consisting only of a single cell, such as 

bacteria, viruses, protozoa and some fungi. 

Minimum Requirement - A determination about whether or not management action is 

necessary. In context, a determination about whether or not a management action is necessary in 

wilderness in order to preserve wilderness character.

Minimum Tool - Use of a weed treatment alternative that would accomplish management 

objectives and have the least impact on resources. 

Mitigation Measures - Modifications of actions taken to: 

1. avoid impacts by not taking a certain action or parts of an action; 

2. minimize impacts by limiting the degree or magnitude of the action and its 

implementation; 

3. rectify impacts by repairing, rehabilitating, or restoring the affected environment; 

4. reduce or eliminate impacts over time by preservation and maintenance operations during 

the life of the action; or, 

5. compensate for impacts by replacing or providing substitute resources or environments. 

Glossary-13 
Final Environmental Impact Statement 

Modification - A visual quality objective meaning human activities may dominate the 

characteristic landscape but must, at the same time, utilize naturally established form, line, color, 

and texture. It should appear as a natural occurrence when viewed in foreground or 

middleground. 

Mollusks - Invertebrate animals (such as slugs, snails, clams, or squids) that have a soft, unsegmented body, usually enclosed in a calcareous shell; representatives found on National Forest 

System land include snails, slugs, and clams. 

Monitoring - A process of collecting information to evaluate if objectives and anticipated or 

assumed results of a management plan are being realized or if implementation is proceeding as 

planned. 

Morbidity - Rate of disease, injury or illness. 

Mowing - Invasive plant treatment method which is limited to level/gently-sloping smoothsurface terrain. Treatment timing is critical, and must be conducted for several consecutive years. 

National Environmental Policy Act (NEPA) - An Act passed in 1969 to declare a national 

policy that encourages productive and enjoyable harmony between humankind and the 

environment, promotes efforts that prevent or eliminate damage to the environment and 

biosphere, stimulates the health and welfare of humanity, enriches the understanding of the 

ecological systems and natural resources important to the nation, and establishes a Council on 

Environmental Quality. 

National Forest Management Act (NFMA) - A law passed in 1976 as an amendment to the 

Forest and Rangeland Renewable Resources Planning Act, requiring preparation of Forest Plans 

and the preparation of regulations to guide that development. 

National Marine Fisheries Service (NMFS) - The federal agency that is the listing authority for 

marine mammals and anadromous fish under the ESA. 

National Pollutant Discharge Elimination System (NPDES) - As authorized by the Clean 

Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program 

controls water pollution by regulating point sources that discharge pollutants into waters of the 

United States. Point sources are discrete conveyances such as pipes or man-made ditches. 

Individual homes that are connected to a municipal system, use a septic system, or do not have a 

surface discharge do not need an NPDES permit; however, industrial, municipal, and other 

facilities must obtain permits if their discharges go directly to surface waters. 

National Visitor Use Monitoring (NVUM) - A permanent, ongoing sampling system which 

measures national forest visitor demographics, experiences, preferences, and impressions. A 

stratified random sample is done for 25% of the National Forest system each year according to a 

national research protocol. NVUM responds to the need to better understand the use and 

importance of, and satisfaction with, national forest system recreation opportunities. 

Glossary-14 
Site-Specific Invasive Plant Treatments 

National Wilderness Preservation System (NWPS) - The Wilderness Act of 1964 established 

the national Wilderness Preservation System to ensure that certain federally owned areas in the 

United States would be preserved and protected in their natural condition. The Act defines a 

wilderness area, in part, as an area which generally appears to have been affected primarily by 

the forces of nature, with the imprint of man’s work substantially unnoticeable. Areas included in 

the system are administered for the use and enjoyment of the American people in such manner as 

to leave them unimpaired for future use and enjoyment as wilderness. 

Native Species - With respect to a particular ecosystem, a species that, other than as a result of 

an introduction, historically occurred or currently occurs in that ecosystem (Executive Order 

13122, 2/3/99). 

Naturalized - Applied to a species that originally was imported from another country but that 

now behaves like a native in that it maintains itself without further human intervention and has 

invaded native populations. 

Non-local Native - This term has two meanings: (1) a population of a native plant species which 

does not occur naturally in the local ecosystem and/or (2) plant material of a native species that 

does not originate from genetically local sources. 

Non-target Species - Any plant or animal that is not the intended organism to be controlled by a 

pesticide treatment. 

No-Observed-Adverse-Effect level (NOAEL) - Exposure level at which there are no 

statistically or biological significant differences in the frequency or severity of any adverse effect 

in the exposed or control populations. 

No-Observed-Effect-Concentration (NOEC) - Synonymous with NOEL.

No-Observed-Effect-Level (NOEL) - Exposure level at which there are no statistically or 

biological significant differences in the frequency or severity of any effect in the exposed or 

control populations. 

Not Likely to Adversely Affect (NLAA) - Determinations are applied to those species that had 

very little habitat on National Forests in Region Six, were not in habitats susceptible to invasive 

plants, or were known to tolerate herbicide treatments without effects. 

Noxious Weed - “Any living stage (including but not limited to, seeds and reproductive parts) of 

any parasitic or other plant of a kind, or subdivision of a kind, which is of foreign origin, is new 

to or not widely prevalent in the United States, and can directly or indirectly injure crops, other 

useful plants, livestock, or poultry or other interests of agriculture, including irrigation, or 

navigation or the fish and wildlife resources of the United States or the public health” (Public 

Law 93-629, January 3, 1975, Federal Noxious Weed Act of 1974). (See also exotic species, 

invasive plant species, introduced species, and noxious weed)

Glossary-15 
Final Environmental Impact Statement 

Outstandingly Remarkable Value (ORV) - A characteristic of rivers or sections of rivers in the 

national Wild and Scenic River System. In order for a river to be included in the system, it must 

possess at least one “outstandingly remarkable” value, such as scenic, recreational, geologic, 

fish, wildlife, historic, cultural, or other similar features. ORV’s are values or opportunities in a 

river corridor which are directly related to the river and which are rare, unique, or exemplary 

from a regional or national perspective. 

Partial Retention - A visual quality objective which in general means human activities may be 

evident but must remain subordinate to the characteristic landscape. 

Passive Restoration – Allowing a site to self-restore through natural processes. 

Pathogen - A living organism, typically a bacteria or virus that causes adverse effects in another 

organism. 

Pendant, Pendulous - Referring to lichens that hang down from branches and/or stems of trees 

and shrubs (e.g., Usnea longissima). 

Percolation - Downward flow or filtering of water through pores or spaces in rock or soil. 

Perennial - A plant species having a life span of more than two years. 

Periphyton - Microscopic plants and animals that are firmly attached to solid surfaces under 

water such as rocks, logs, pilings and other structures. 

Persistence - Refers to the length of time a compound, once introduced into the environment, 

stays there. 

Personal Protective Equipment (PPE) - Clothing and equipment worn by pesticide mixers, 

loaders and applicators and re-entry workers, hazmat emergency responders, workers cleaning 

up Superfund sites, et. al., which is worn to reduce their exposure to potentially hazardous 

chemicals and other pollutants. 

Pest - An insect, rodent, nematode, fungus, weed or other form of terrestrial or aquatic plant or 

animal life that is classified as undesirable because it is injurious to health or the environment. 

Pesticide - Any substance used for controlling, preventing, destroying, repelling, or mitigating 

any pest. Includes fungicides, herbicides, fumigants, insecticides, nematicides, rodenticides, 

desiccants, defoliants, plant growth regulators, etc. 

Pesticide Tolerance - The amount of pesticide residue allowed by law to remain in or on a 

harvested crop. 

pH - The negative log of the hydrogen ion concentration. A high pH (greater than seven) is 

alkaline or basic and a low pH (less than seven) is acidic. 

Glossary-16 
Site-Specific Invasive Plant Treatments 

Phytoplankton – Free floating algae. 

Population - A group of individuals of the same species in an area. 

Population at Risk - A population subgroup that is more likely to be exposed to a chemical, or 

is more sensitive to the chemical, than is the general population. 

Porosity - Degree to which soil, gravel, sediment, or rock is permeated with pores or cavities 

through which water or air can move. 

Potable Water - Water that is considered safe for drinking and cooking. 

Prevention - To detect and ameliorate conditions that establishment, or spread of invasive 

plants. 

Project Design Criteria (PDC) - A set of required, implementation design criteria applied to 

projects to ensure that the project is done according to environmental standards and adverse 

effects are within the scope of those predicted in this environmental impact statement. 

Proposed Species - Any plant or animal species that is proposed by the Fish and Wildlife 

Service or NOAA Fisheries in a Federal Register notice to be listed as threatened or endangered. 

Potential Vegetation Type (PVT) - The term Potential Vegetation Type is used to represent the 

combination of species that could occupy the site in the absence of disturbance. 

Protozoa - Single-celled, microorganisms without cell walls containing visibly evident nuclei 

and organelles. Most protozoa are free-living although many are parasitic. 

Recreational Rivers - A classification within the national Wild and Scenic River System. 

Recreational rivers are those rivers, or sections of rivers, that are readily accessible by road or 

railroad, that may have some development along their shorelines, and that may have undergone 

some impoundment or diversion in the past.

Reference Dose (RfD) - The RfD is a numerical estimate of a daily exposure to the human 

population, including sensitive subgroups such as children, that is not likely to cause harmful 

effects during a lifetime. RfDs are generally used for health effects that are thought to have a 

threshold or minimum dose for producing effects. 

Registered Pesticides - Pesticide products which have been approved for the uses listed on the 

label. 

Registration - Formal licensing with EPA of a new pesticide before it can be sold or distributed. 

Under the Federal Insecticide, Fungicide, and Rodenticide Act, EPA is responsible for 

registration (pre-market licensing) of pesticides on the basis of data demonstrating no 

unreasonable adverse effects on human health or the environment when applied according to 

approved label directions. 

Glossary-17 
Final Environmental Impact Statement 

Reserved Rights - Rights tribes kept, or reserved, during treaty-making out of a greater number 

of rights they already owned. 

Resolved Issue - significant issues identified by the public that have been fully mitigated 

through the development of alternatives or project design criteria. 

Restoration - Ecological restoration is the process of assisting the recovery and management of 

ecological integrity. Ecological integrity includes a critical range of variability in biodiversity, 

ecological processes and structures, regional and historical context, and sustainable cultural 

practices. 

Retention - A visual quality objective which in general means human activities are not evident 

to the casual forest visitor. 

Revegetation - The re-establishment of plants on a site. The term does not imply native or 

nonnative; does not imply that the site can ever support any other types of plants or species and 

is not at all concerned with how the site ‘functions’ as an ecosystem. 

Riparian Area - A geographic area containing an aquatic ecosystem and adjacent upland areas 

that directly affect it. 

Riparian Reserves - Areas along live and intermittent streams, wetlands, ponds, lakes, and 

unstable and potentially unstable areas where riparian-dependent resources receive primary 

emphasis. Riparian Reserves are important to the terrestrial ecosystem as well, serving as 

dispersal habitat for certain terrestrial species. 

Risk - The chance of an adverse or undesirable effect, often measured as a percentage. 

Risk Assessment - The qualitative and quantitative evaluation performed in an effort to estimate 

the risk posed to human health and/or the environment by the presence or potential presence 

and/or use of specific chemical or biological agents. 

Salmonid – fish belonging to the family Salmonidae (salmon, trout, char). 

Saturated zone - A subsurface area in which all pores and cracks are filled with water under 

pressure equal to or greater than that of the atmosphere. 

Scenery Management - The art and science of arranging, planning, and designing landscape 

attributes relative to the appearance of places and expanses in outdoor settings. 

Scenic - Of or relating to landscape scenery; pertaining to natural or natural-appearing scenery; 

constituting or affording pleasant views of natural landscape attributes or positive cultural 

elements. 

Glossary-18 
Site-Specific Invasive Plant Treatments 

Scenic Integrity - State of naturalness or, conversely, the state of disturbance created by human 

activities or alteration. Integrity is stated in degrees of deviation from the existing landscape 

character in a national forest. 

Scenic Quality - The essential attributes of landscape that when viewed by people, elicit 

psychological and physiological benefits to individuals and to society in general. 

Scenic Rivers - A classification within the national Wild and Scenic River System. Scenic rivers 

are those rivers, or sections of rivers, that are free of impoundments, with shorelines or 

watersheds still largely primitive and shorelines largely undeveloped, but accessible in places by 

roads. 

Seen Area - The total landscape area observed based upon landform screening. Seen-areas may 

be divided into zones of immediate foreground, foreground, middleground, and background. 

Some landscapes are seldom seen by the public. 

Sensitive Species - Species identified by the Regional Forester for which population variability 

is a concern, as evidenced by significant current or predicted downward trend in population 

numbers or density; or significant current or predicted downward trends in habitat capability that 

would reduce a species’ existing distribution. 

Sensitivity Level - A particular degree or measure of viewer interest in the scenic qualities of the 

landscape. 

Smolt – young salmon or anadromous trout in the process of transforming to a saltwater 

dwelling fish 

Soluble – capable of being loosened or dissolved. 

Special Status Species – Federally listed and proposed threatened and endangered species; 

USDA Forest Service Pacific Northwest Region sensitive species and Survey and Manage 

species; Mt. Hood National Forest Land and Resource Management Plan management indicator 

species; and Sensitive Plan and Wildlife Species as defined in the Columbia River Gorge 

Management Plan. 

Species - “A group of organisms, all of which have a high degree of physical and genetic 

similarity, generally interbreed only among themselves, and show persistent differences from 

members of allied groups of organisms.” (Executive Order 13122, 2/3/99). 

Spot Herbicide Treatment Application - Herbicide treatment involving use of a backpack 

sprayer or other means. Application is aimed at specific target species, with methods of 

prevention (such as barriers,) to control damage to non-target species. 

Spring – The point where ground water emerges onto the land surface. 

Glossary-19 
Final Environmental Impact Statement 

Standards and Guidelines - The rules and limits governing actions, as well as the principles 

specifying the environmental conditions or levels to be achieved and maintained. 

Stem Injection – Herbicide treatment method where herbicides are injected into herbaceous 

stems using a needle and syringe. Herbicide pellets can also be injected into the trunk of a tree 

using a specialized tool.

Sub-Chronic Exposure - An exposure duration that can last for different periods of time (5 to 

90 days), with 90 days being the most common test duration for mammals. The sub-chronic 

study is usually performed in two species (rat and dog) by the route of intended use or exposure. 

Sub-Chronic Toxicity - The ability of one or more substances to cause effects over periods from 

about 90 days but substantially less than the lifetime of the exposed organism. Sub-chronic 

toxicity only applies to relatively long-lived organisms such as mammals. 

Sub-lethal – A negative effect on an organism that does not cause death. 

Substrate - With reference to enzymes, the chemical that the enzyme acts upon. 

Suppress – Prevent seed production throughout the target patch and reduce the area coverage. 

Prevent the invasive species from dominating the vegetation of the area; low levels may be 

acceptable. 

Surface Water - All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, 

impoundments, seas, estuaries, etc.) and all springs, wells, or other collectors which are directly 

influenced by surface water. 

Surfactant - A surface active agent; usually an organic compound whose molecules contain a 

hydrophilic group at one end and a lipophilic group at the other. Promotes solubility of a 

chemical, or lathering, or reduces surface tension of a solution. 

Survey and Manage - Mitigation measure adopted as a set of standards and guidelines within 

the Northwest Forest Plan Record of Decision and replaced with standards and guidelines in 

2001 (Record of Decision) intended to mitigate impacts of land management efforts on those 

species that are closely associated with Late-Successional or old-growth forests whose long-term 

persistence is a concern. This mitigation measure applies to all land allocations and requires land 

managers to take certain actions relative to species of plants and animals, particularly some 

amphibians, bryophytes, lichens, mollusks, vascular plants, fungi, and arthropods, which are rare 

or about which little is known. These actions include: (1) manage known sites; (2) survey prior 

to habitat-disturbing activities; and, (3) conduct extensive and general regional (strategic) 

surveys. 

Synergistic Effect - Situation in which the combined effects of exposure to two chemicals 

simultaneously is much greater than the sum of the effect of exposure to each chemical given 

alone. 

Glossary-20 
Site-Specific Invasive Plant Treatments 

Take - "The term 'take' means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or 

collect, or to attempt to engage in any such conduct." (Title 16, Chapter 35, Section 1532, 

Endangered Species Act of 1973) 

Thallus – The vegetative body of a lichen. 

Threatened Species - Plant or animal species likely to become endangered throughout all, or a 

significant portion of, its range within the foreseeable future. A plant or animal identified and 

defined in accordance with the 1973 Endangered Species Act and published in the Federal 

Register. 

Threshold - The maximum dose or concentration level of a chemical or biological agent that 

will not cause an effect in the organism. 

Tolerances - Permissible residue levels for pesticides in raw agricultural produce and processed 

foods. Whenever a pesticide is registered for use on a food or a feed crop, a tolerance (or 

exemption from the tolerance requirement) must be established. EPA establishes the tolerance 

levels, which are enforced by the Food and Drug Administration and the Department of 

Agriculture. 

Toxicity - The inherent ability of an agent to affect living organisms adversely. Toxicity is the 

degree to which a substance or mixture of substances can harm humans or animals. 

Toxicology - The study of the nature, effects, and detection of poisons in living organisms. Also, 

substances that are otherwise harmless but prove toxic under particular conditions. The basic 

assumption of toxicology is that there is a relationship among the dose (amount), the 

concentration at the affected site, and the resulting effects. 

Tracking Issue – Issues determined to be relevant, but are not used to formulate alternatives. 

These issues often describe minor or consistent consequences among alternatives considered in 

detail. 

Tribal and Treaty Rights - Native American treaty and other rights or interests recognized by 

treaties, statutes, laws, executive orders, or other government action, or federal court decisions. 

Treatment Area - An infested area where weeds have been treated or retreated by an acceptable 

method for the specific objective of controlling their spread or reducing their density. 

Treaty – A contract or compact between nations. It is an agreement that is binding upon the 

nations that sign the treaty. 

U.S. Fish and Wildlife Service (US FWS) - The federal agency that is the listing authority for 

species other than marine mammals and anadromous fish under the ESA. 

U.S. Forest Service (USDA FS or USFS) - The federal agency responsible for management of 

the nation’s National Forest lands. 

Glossary-21 
Final Environmental Impact Statement 

Variety Class - A particular level of visual variety or diversity of landscape character.

Viability - Ability of a wildlife or plant population to maintain sufficient size to persist over time 

in spite of normal fluctuations in numbers, usually expressed as a probability of maintaining a 

specific population for a specified period. 

Viable Population - A wildlife or plant population that contains an adequate number of 

reproductive individuals appropriately distributed on the planning area to ensure the long-term 

existence of the species. 

Viewshed - Total visible area from a single observer position, or the total visible area from 

multiple observer position. Viewsheds are accumulated seen-areas from highways, trails, 

campgrounds, towns, cities, or other viewer locations. Examples are corridor, feature, or basin 

viewsheds. 

Visual Absorption Capability - A classification system used to denote relative ability of a 

landscape to accept human alterations without loss of character of scenic quality. 

Visual Quality Objective - A desired level of excellence based on physical and sociological 

characteristics of an area. Refers to degree of acceptable alteration of the characteristic 

landscape. 

Water table – The upper surface of an unconfined or "phreatic" aquifer, typically represented by 

mapping the elevations of the water levels found in production wells. 

Well-distributed - Distribution sufficient to permit normal biological function and species 

interactions, considering life history characteristics of the species and the habitats for which it is 

specifically adapted. 

Wetland - An area that is regularly saturated by surface or ground water and subsequently is 

characterized by a prevalence of vegetation that is adapted for life in saturated soil conditions. 

Examples include swamps, bogs, fens, marshes, and estuaries. 

Wicking or Wiping - Using a sponge or wick on a long handle to wipe herbicide onto foliage 

and stems

Wild and Scenic River System - The Wild and Scenic Rivers Act of 1968 established a system 

of selected rivers in the United States, which possess outstandingly remarkable values, to be 

preserved in free-flowing condition. Within the national system of rivers, three classifications 

define the general character of designated rivers: Wild, Scenic, and Recreational. Classifications 

reflect levels of development and natural conditions along a stretch of river. Classifications are 

used to help develop management goals for the river. 

Glossary-22 
Site-Specific Invasive Plant Treatments 

Glossary-23 

Wilderness - Areas designated by Congressional action under the 1964 Wilderness Act. 

Wilderness is defined as undeveloped federal land retaining its primeval character and influence 

without permanent improvements or human habitation. Wilderness areas are protected and 

managed to preserve their natural conditions, which generally appear to have been affected 

primarily by the forces of nature with the imprint of human activity substantially unnoticeable; 

have outstanding opportunities for solitude or for a primitive and confined type of recreation; 

include at least 5,000 acres, or are of sufficient size to make practical their preservation, 

enjoyment, and use in an unimpaired condition; and may contain features of scientific, 

educational, scenic, or historical value as well as ecological and geologic interest. 

Wild Rivers - A classification within the national Wild and Scenic River System. Wild rivers are 

those rivers, or sections of rivers that are free of impoundments and generally inaccessible except 

by trail, with watersheds or shorelines essentially primitive and waters unpolluted. 
 
Index 
 
Site-Specific Invasive Plant Treatments 

INDEX 

Adjuvants (Surfactants) 2-51, 3-9, 3-12, 3-15, 3-16, 3-17, 3-24, 3-26, 3-90, 3-100, 3-

104, 3-113, 3-152, 3-155, 3-156, 3-159, 4-2 

Adverse Environmental 

Effects that Cannot be 

Avoided 

3-254 

Aerial Application of 

Herbicides 

3-104 

Alternatives Considered, But 

Dropped from Further 

Analysis 

2-66 

Biological Control 1-4, 1-31, 3-23 

Columbia River Gorge 

National Scenic Area 

Management Plan 

1-1, 1-19, 3-22, 3-261 

Commercial Herbicides 2-28 

Common Control Measures 1-13, 1-15, 2-1, 2-27, 2-31, 2-49, 2-63, 2-69, 3-49 

Consultation 1-1, 1-2, 3-24197, 3-198, 3-201, 3-243, 3-244, 3-245, 4-1 to 4-

4 

Cumulative Effects 3-1, 3-17, 3-18, 3-23, 3-24, 3-28, 3-31, 3-32, 3-53, 3-56, 3-58, 

3-68, 3-71, 3-86, 3-87, 3-94, 3-105, 3-107, 3-108, 3-109, 3-

139, 3-140, 3-142, 3-162, 3-163, 3-167, 3-190, 3-191, 3-197, 

3-198, 3-201, 3-203, 3-205, 3-206, 3-208, 3-209, 3-210, 3-211, 

3-213, 3-214, 3-215, 3-216, 3-217, 3-219, 3-222, 3-225, 3-239, 

3-241, 3-244, 3-245, 3-253, 3-258, 3-260, 3-261 

Decision Framework 1-22, 3-266 

Desired Future Condition 1-9, 1-11, 1-19, 2-39, 2-60, 2-68, 3-99 

Early Detection / Rapid 

Response (EDRR) 

1-3, 1-8, 1-13, 1-15, 2-19, 2-23, 2-32, 2-54, 3-1, 3-5, 3-7, 3-49, 

3-58, 3-68, 3-70, 3-109, 3-162, 3-166, 3-197, 3-201, 3-203, 3-

206, 3-207, 3-209, 3-210, 3-211, 3-213, 3-214, 3-215, 3-217, 

3-218, 3-228, 3-233, 3-241, 3-262, 3-263 

Environmental Justice 1-29, 3-25, 3-246, 3-250, 3-253, 3-260 

Forest Plan (Mt. Hood Land 

and Resource Management 

Plan) 

1-19, 1-21, 1-22, 1-24, 1-28, 2-3, 2-19, 2-39, 2-40, 2-49, 2-50, 

2-51, 2-69 to 2-71, 3-22, 3-32, 3-34, 3-44, 3-58, 3-71 to 3-73, 

3-78, 3-85, 3-87, 3-91, 3-97, 3-99, 3-1 

Forest Plan Amendments 1-21, 2-19, 2-39, 2-49, 2-71, 3-32, 3-58, 3-71, 3-87, 3-113, 3-

170, 3-227, 3-241, 3-245, 3-254, 3-261 

Index-1 
Final Environmental Impact Statement 

Goat Grazing 1-7, 1-10, 1-11, 1-12, 1-15, 2-3, 2-20, 2-23, 2-27, 2-34, 2-41, 

2-42, 2-50, 2-64, 2-69, 2-70, 3-149, 3-150, 3-164, 3-240, 3-244

Herbicides 1-12 to 1-16, 1-19, 1-21, 1-25 to 1-29, 1-31, 2-3, 2-9 to 2-11, 

2-18, 2-21 to 2-24, 2-27, 2-28, 2-30 to 2-32, 2-38 to 2-41, 2-49 

to 2-55, 2-57, 2-58, 2-63 to 2-65, 2-68 to 2-71, 3-2, 3-5, 3-9, 3-

10, 3-12, 3-13, 3-15, 3-16, 3-17, 3-18, 3-20 to 3-24, 3-28, 3-31 

to 3-33, 3-35, 3-38, 3-39, 3-41 to 3-44, 3-46 to 3-51, 3-53 to 3-

58, 3-63, 3-69, 3-71 to 3-73, 3-78 to 3-80, 3-82, 3-84, 3-85, 3-

87, 3-88, 3-90, 3-93, 3-94, 3-100 to 3-105, 3-107 to 3-109, 3-

11, 3-137, 3-139, 3-143, 3-145, 3-147 to 3-149, 3-151 to 3-

156, 3-159, 3-163, 3-165, 3-166, 3-170, 3-178, 3-179, 3-182 to 

3-1923-194, 3-198, 3-199, 3-204 to 3-227, 3-234 to 3-238, 3-

240, 3-242, 3-244, 3-250 to 3-253, 3-255, 3-258, 3-262 

 Chlorsulfuron 1-12, 1-13, 1-15, 2-23, 2-28, 2-30, 2-56, 2-57, 3-10, 3-47, 3-

48, 3-79 to 3-81, 3-84, 3-87, 3-102, 3-152, 3-156, 3-165, 3-

187, 3-252 

 Clopyralid 1-12, 1-13, 1-15 to 1-17, 2-23, 2-28, 2-30, 2-38, 2-56, 2-57 ,3-

10, 3-17, 3-47, 3-48, 3-79, 3-81, 3-153, 3-179, 3-182, 3-187, 3-

190, 3-212, 3-237, 3-225, 3-240, 3-245, 3-252, 3-257 

 Glyphosate 1-12, 1-13, 1-15, 2-9, 2-10, 2-23, 2-28, 2-30, 2-56, 2-57, 3-10, 

3-15, 3-16, 3-29, 3-32, 3-37, 3-44, 3-46, 3-48, 3-50, 3-54, 3-

79, 3-80, 3-81, 3-100, 3-105, 3-148, 3-1, 3-152, 3-153, 3-154, 

3-155, 3-160, 3-166, 3-182, 3-185, 3-187, 3-188, 3-206, 3-227, 

3-237, 3-252, 3-257 

 Imazapic 1-12, 1-13, 1-15 to 1-17, 2-23, 2-29, 2-30, 2-56, 2-57, 3-11, 3-

79, 3-81, 3-87, 3-152, 3-153, 3-156, 3-165, 3-187 

 Imazapyr 1-12, 1-13, 1-15, 2-23, 2-29, 2-30, 2-56, 2-57, 3-11, 3-79, 3-

80, 3-81, 3-84, 3-147, 3-153, 3-187, 3-252 

 Metsulfuron methyl 1-12, 1-13, 1-15 to 1-17, 2-23, 2-29, 2-30, 2-56, 2-57, 3-12, 3-

79, 3-81, 3-102, 3-187 

 Picloram 1-11, 1-12, 2-9, 2-10, 2-23, 2-30, 2-31, 2-41, 2-56, 2-59, 2-60, 

3-9, 3-13, 3-39, 3-40, 3-41, 3-46, 3-71, 3-72, 3-73, 3-74, 3-75, 

3-77, 3-78, 3-80, 3-93, 3-94, 3-95, 3-139, 3-140, 3-144, 3-149, 

3-151, 3-167, 3-170, 3-174, 3-175, 3-176, 3-179, 3-187, 3-194, 

3-197, 3-200, 3-225, 3-240, 3-244, 3-245 

 Sethoxydim 1-12, 1-13, 1-15, 2-23, 2-29, 2-56, 3-12, 3-47, 3-48, 3-79, 3-

80, 3-81, 3-148, 3-187, 3-223 

 Sulfometuron methyl 1-12, 1-13, 1-15, 2-23, 2-30, 2-56, 2-57, 3-12, 3-48, 3-79, 3-

81, 3-82, 3-85, 3-87, 3-182, 3-187, 3-212, 3-256, 3-257 

Index-2 
Site-Specific Invasive Plant Treatments 

 Triclopyr 1-12, 1-13, 1-15 to 1-17, 1-20, 2-9, 2-10, 2-23, 2-30, 2-38, 2-

54, 2-56, 2-57, 3-12, 3-27, 3-28, 3-31, 3-37, 3-46, 3-48, 3-79, 

3-80, 3-81, 3-101, 3-102, 3-105, 3-147, 3-148, 3-152, 3-153, 3-

154, 3-160, 3-163, 3-179, 3-182, 3-186, 3-187, 3-188, 3-190, 

3-206, 3-212, 3-221, 3-224, 3-225, 3-226, 3-252, 3-258 

Integrated Weed Management 

(IWM) 

1-10, 1-11, 1-13, 2-9, 2-23, 2-24, 2-26, 2-38, 2-41, 2-66, 2-68, 

2-69, 2-70, 3-24, 3-43 

Invasive Plant Inventory 1-3, 1-6, 1-13, 2-18, 2-32 

Monitoring 1-18, 1-19, 1-22, 2-22, 2-39, 2-60, 2-61, 3-2, 3-5, 3-24, 3-68, 

3-72, 3-74, 3-84, 3-89, 3-91, 3-93, 3-102, 3-105, 3-114, 3-149, 

3-231, 3-249, 3-254, 4-2 

No Action (Alternative 1) 1-1, 2-1, 2-3, 2-9 to 2-17, 2-62, 2-63, 2-69 to 2-71, 3-1, 3-19, 

3-30, 3-35 to 3-39, 3-41 to 3-43, 3-50 to 3-53, 3-56, 3-57, 3-61 

to 3-63, 3-68, 3-69, 3-70, 3-73, 3-78, 3-79, 3-86, 3-93, 3-95, 3-

107 to 3-109, 3-139 to 3-141, 3-143, 3-162, 3-163, 3-167, 3-

186, 3-189, 3-194, 3-198, 3-200, 3-202, 3-204, 3-206 to 3-213, 

3-215, 3-217 to 3-221, 3-224, 3-227, 3-234, 3-237, 3-238, 3-

240, 3-243, 3-250, 3-252, 3-253, 3-256, 3-258 

Northwest Forest Plan 1-19, 1-22, 3-32, 3-34, 3-44, 3-58, 3-71, 3-87, 3-91, 3-113, 3-

126, 3-170, 3-175, 3-193, 3-194, 3-227, 3-241, 3-245, 3-254 

Prevention 1-4, 1-19, 1-30, 1-31, 2-3, 2-61, 2-66, 2-67, 3-7, 3-24, 3-29, 3-

40, 3-52, 3-53, 3-56, 3-139, 3-167 

Project Design Criteria (PDC) 1-1, 1-10, 1-14, 1-16 to 1-18, 1-20 to 1-22, 1-24, 1-27, 1-28, 2-

18, 2-30, 2-32, 2-33, 2-38, 2-49, 2-50 to 2-52, 2-60, 2-65, 2-

70, 2-71, 3-9, 3-14, 3-16 to 3-24, 3-27 to 3-31, 3-41, 3-47, 3-

48, 3-50, 3-51, 3-55, 3-56, 3-76, 3-78, 3-84 to 3-87, 3-94, 3-

97, 3-100, 3-102 to 3-104, 3-107 to 3-109, 3-112, 3-143 to 3-

145, 3-148, 3-149, 3-151 to 3-153, 3-155 to 3-157, 3-159, 3-

160 to 3-162, 3-163, 3-165 to 3-167, 3-170, 3-176, 3-177, 3-

180, 3-182, 3-183, 3-186 to 3-191, 3-198, 3-201 to 3-203, 3-

206, 3-208 to 3-210, 3-217, 3-218, 3-244, 3-251, 3-252, 3-254, 

3-255 to 3-259, 3-261, 4-3, 4-4 

Proposed Action (Alternative 

2) 

1-19, 2-3, 2-18, 2-41, 2-49, 2-50, 2-60, 2-62, 2-63, 2-71, 3-30, 

3-31, 3-42, 3-50, 3-51, 3-55, 3-56, 3-62 to 3-64, 3-68, 3-84, 3-

95, 3-96, 3-105, 3-108 to 3-110, 3-149, 3-163 to 3-168, 3-187 

to 3-189, 3-194 to 3-196, 3-205, 3-210, 3-218, 3-221, 3-222, 3-

225, 4-3 

Purpose and Need for Action 1-1, 1-5, 1-22, 2-3, 2-26, 2-66 

Index-3 
Final Environmental Impact Statement 

Restricted Herbicide Use 

(Alternative 3) 

1-1, 1-19, 1-21, 1-24, 1-28, 2-3, 2-41 to 2-48, 2-60, 2-62, 2-69, 

2-71, 3-19, 3-31, 3-32, 3-51 to 3-53, 3-56 to 3-58, 3-61 to 3-

64, 3-66 to 3-71, 3-77 to 3-79, 3-82, 3-84, 3-87, 3-108, 3-113, 

3-163, 3-164, 3-166, 3-167, 3-170, 3-186, 3-188, 3-196, 3-200, 

3-203, 3-204, 3-206 to 3-212, 3-214, 3-215, 3-217 to 3-221, 3-

225, 3-227, 3-235 to 3-237, 3-240, 3-241, 3-244, 3-245, 3-250, 

3-251, 3-253, 3-254, 3-256, 3-259, 4-3 

Site Restoration Strategies 2-19, 2-31 

Special Forest Products 1-1, 1-27, 2-54, 2-65, 3-2, 3-25, 3-27, 3-28, 3-59, 3-60, 3-71, 

3-75, 3-78, 3-81, 3-83, 3-85 

Special Status Species 1-16, 1-17, 1-28, 1-29, 2-54, 2-65, 2-67, 3-18, 3-115, 3-171, 3-

172, 3-179, 3-180, 3-181, 3-187, 3-188, 3-189, 3-255 

Treatment Method 1—10 to 1-17, 1-20, 1-25 to 28, 1-31, 2-1, 2-3, 2-9, 2-11, 2-19, 

2-20, 2-23, 2-24, 2-26, 2-27, 2-32, 2-33, 2-38, 2-41, 2-42, 2-

49, 2-50, 2-52, 2-55, 2-60, 2-61, 2-62, 2-64, 2-65, 2-69, 2-71, 

3-2, 3-25, 3-30, 3-41, 3-53, 3-56, 3-59, 3-78, 3-85, 3-95, 3-96, 

3-99, 3-104, 3-108, 3-144, 3-149, 3-150, 3-164, 3-176, 3-180, 

3-182, 3-185, 3-190, 3-196, 3-198, 3-200, 3-204, 3-205, 3-207, 

3-209, 3-220, 3-223, 3-225, 3-240, 3-244 

 Manual 1-7, 1-10 to 1-12, 1-15 to 1-17, 1-26, 1-29, 2-3, 2-9 to 2-11, 2-

20, 2-23, 2-24, 2-27, 2-33, 2-34, 2-41, 2-42, 2-50, 2-53, 2-55, 

2-57, 2-64, 2-69, 2-70, 2-71, 3-5, 3-7, 3-9, 3-30, 3-35 to 3-39, 

3-41 to 3-44, 3-46, 3-47, 3-49, 3-51, 3-53 to 3-56, 3-62, 3-63, 

3-69, 3-70, 3-77, 3-78, 3-94 to 3-99, 3-104, 3-107 to 3-109, 3-

149, 3-150, 3-163, 3-164, 3-167, 3-171, 3-180, 3-185, 3-187 to 

3-189, 3-195 to 3-198, 3-200, 3-201, 3-204 to 3-212, 3-214, 3-

215, 3-217 to 3-219, 3-225, 3-235 to 3-238, 3-240 to 3-242, 3-

244, 3-246, 3-248, 3-250, 3-255, 3-261, 4-1 

 Mechanical 1-7, 1-9 to 1-12, 1-15 to 1-17, 1-26, 1-29, 2-3, 2-9 to 2-11, 2-

21, 2-23, 2-24, 2-27, 2-33, 2-34, 2-41, 2-42, 2-50, 2-52, 2-55, 

2-57, 2-64, 2-69, 2-70, 2-71, 3-7, 3-9, 3-30, 3-35 to 3-39, 3-41 

to 3-44, 3-46, 3-47, 3-49, 3-51, 3-53, 3-55, 3-56, 3-62, 3-63, 3-

69, 3-77, 3-78, 3-94 to 3-99, 3-104, 3-107 to 3-109, 3-149, 3-

150, 3-163, 3-164, 3-167, 3-180, 3-185, 3-187 to 3-189, 3-195, 

3-197, 3-198, 3-200, 3-201, 3-204 to 3-212, 3-214, 3-215, 3-

217 to 3-219, 3-225, 3-235, 3-236, 3-240, 3-241, 3-244, 3-255, 

4-1 

Index-4 
Site-Specific Invasive Plant Treatments 

Index-5 

 Cultural 1-3, 1-6, 1-7, 1-10 to 1-12, 1-15, 1-19, 1-24, 1-28, 1-29, 2-3, 2-

21, 2-23, 2-27, 2-34, 2-41, 2-42, 2-50, 2-57, 2-59, 2-64, 2-65, 

2-69, 2-70, 3-1, 3-9, 3-30, 3-38, 3-47, 3-56, 3-63, 3-77, 3-78, 

3-95 to 3-99, 3-104, 3-107 to 3-109, 3-149, 3-150, 3-164, 3-

180, 3-185, 3-187, 3-189, 3-196, 3-198, 3-201, 3-205 to 3-212, 

3-214, 3-215, 3-217 to 3-219, 3-225, 3-229, 3-236, 3-240, 3-

242 to 3-246, 3-248, 3-250, 3-252, 3-253 to 3-255, 3-259, 4-1, 

4-3 

 Herbicide treatment 1-12, 1-15, 1-26 to 1-28, 2-1, 2-3, 2-9 to 2-11, 2-20 to 2-23, 2-

26, 2-27, 2-30, 2-32 to 2-34, 2-38, 2-39, 2-41, 2-42, 2-49, 2-

50, 2-53, 2-55, 2-57, 2-61 to 2-65, 2-68, 2-69, 2-70, 2-71, 3-7, 

3-9, 3-14, 3-19, 3-30, 3-36, 3-39, 3-42 to 3-44, 3-46 to 3-48, 3-

50 to 3-52, 3-54 to 3-57, 3-62, 3-76, 3-77, 3-79, 3-84 to 3-87, 

3-94, 3-97, 3-99, 3-100, 3-105, 3-108, 3-139, 3-143, 3-145, 3-

146, 3-150 to 3-153, 3-156, 3-159, 3-161 to 3-168, 3-173, 3-

180, 3-183, 3-186, 3-187, 3-189, 3-197, 3-202, 3-210, 3-213, 

3-215, 3-222, 3-227, 3-244, 3-250 to 3-252, 3-256, 4-3 

Treatment Preferences 2-23 

Treatment Priorities 2-1 

Treatment Strategies 1-8, 1-1-9, 1-11, 2-1, 2-19, 2-24, 2-26, 2-31, 2-38, 2-39, 2-49, 

2-50, 2-60, 2-66, 2-68 

 Eradicate 1-5, 1-8, 1-9, 1-10, 1-15, 2-26, 2-31, 2-39, 2-49, 2-66, 2-68, 3-

4, 3-44, 3-54, 3-72, 3-99, 3-139, 3-162, 3-167, 3-234, 3-240 

 Control 1-4, 1-8, 1-9, 2-26 to 2-31, 2-57, 2-66, 2-68 

 Contain 1-5, 1-8, 1-9, 1-10, 1-15, 2-23, 2-26, 2-31, 2-34, 2-39, 2-49, 2-

51, 2-66, 2-68, 3-23, 3-38, 3-39, 3-44, 3-51, 3-53, 3-54, 3-56, 

3-57, 3-86, 3-94, 3-97 

 Suppress 1-8, 1-9, 1-15, 2-26, 2-31, 2-34, 2-49, 2-66, 2-67, 2-68, 3-7, 3-

33, 3-39, 3-57, 3-223, 3-245 

Unavoidable Adverse Effects 3-254 
 
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and 

activities on the basis of race, color, national origin, age, disability, and where applicable, sex, 

marital status, familial status, parental status, religion, sexual orientation, genetic information, 

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and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, 

1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 

(voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer. 
United States 

Department of 

Agriculture 

Forest 

Service 

March 2008 

Final Environmental 

Impact Statement 

Site-Specific Invasive Plant Treatments for 

Mt. Hood National Forest and Columbia 

River Gorge National Scenic Area in Oregon, 

including Forest Plan Amendment #16 

Appendices A - Z 

Mt. Hood National Forest and Columbia River Gorge 

National Scenic Area 

Clackamas, Hood River, Multnomah, and Wasco Counties 

Appendices 

APPENDIX A Standards From Preventing And Managing Invasive Plant Record Of Decision 

APPENDIX B Compliance With Mt. Hood National Forest Land And Resource Management Plan 

(1990) And Northwest Forest Plan (1994) 

APPENDIX C Columbia River Gorge National Scenic Area Management Plan – Consistency 

Determination 

APPENDIX D Prevention Of Invasive Plants – A Strategic And Collaborative Effort 

APPENDIX E Pesticide – Use Proposal (FW-2100-2) 

APPENDIX F Site And Treatment Information 

APPENDIX G Common Control Measures Summary 

APPENDIX H Proposed Herbicide Use At Treatment Sites In The Proposed Action 

APPENDIX I Oregon State Class A & B Noxious Weeds 

APPENDIX J Invasive Plant Treatments By Fifth Field Watersheds 

APPENDIX K Proposed Herbicide Treatments For Alternative 3 

APPENDIX L Sample Public Norifications

APPENDIX M Oregon Guidelines For Timing Of In-Water Work To Protect Fish And Wildlife 

Resources 

APPENDIX N Inventory And Monitoring Framework 

APPENDIX O Existing Conditions Characteristics 

APPENDIX P Ownership Patterns By Fifth Field Watershed 

APPENDIX Q Herbicide Information Summary And Project Design Criteria Crosswalk 

APPENDIX R Adjuvants And Surfactants Addressed By Bakke (2003A) 

APPENDIX S Economic Assumptions 

APPENDIX T Labor Cost, Wage Income And Potential Job Estimates 

APPENDIX U Effects On Soil Properties: Review Of Proposed Herbicides 

APPENDIX V Drinking Water Protection Areas 

APPENDIX W Summary Tables Of Site-Specific Herbicide Effects For Various Aquatic Species 

APPENDIX X Effects Of Herbicides On Wildlife Species 

APPENDIX Y Programmatic Agreement Regarding Cultural Resources Management 

APPENDIX Z Response To Comments 
APPENDIX A 

Standards from Preventing and Managing 

Invasive Plant Record of Decision 
 
Site-Specific Invasive Plant Treatments 

APPENDIX A: Standards from Preventing and Managing 

Invasive Plant Record of Decision 

The following standards and implementation guide are taken from Pacific Northwest Region 

Invasive Plant Program: Preventing and Managing Invasive Plants Record of Decision, page 

A-3 to A-8 (USDA Forest Service, 2005b). 

Standard # Text of Standard Implementation Schedule 

1 Prevention of invasive plant introduction, 

establishment and spread will be addressed in 

watershed analysis; roads analysis; fire and 

fuels management plans, Burned Area 

Emergency Recovery Plans; emergency 

wildland fire situation analysis; wildland fire 

implementation plans; grazing allotment 

management plans, recreation management 

plans, vegetation management plans, and other 

land management assessments. 

This standard will apply to all 

assessments and analysis

documents started or 

underway as of March 1, 2006; 

this standard does not apply to 

assessments and analysis 

documents signed or 

completed by February 28, 

2006. 

2 Actions conducted or authorized by written 

permit by the Forest Service that will operate 

outside the limits of the road prism (including 

public works and service contracts), require the 

cleaning of all heavy equipment (bulldozers, 

skidders, graders, backhoes, dump trucks, etc.) 

prior to entering National Forest System Lands.

This standard does not apply to initial attack of

wildland fires, and other emergency situations 

where cleaning would delay response time. 

This standard will apply to 

permits and contracts issued 

after March 1, 2006. Ongoing 

permits/contracts issued before 

this date may be amended, but 

are not required to be 

amended, to meet this 

standard. 

This standard will apply to 

Forest Service force account 

operations starting March 1, 

2006. 

3 Use weed-free straw and mulch for all projects, 

conducted or authorized by the Forest Service, 

on National Forest System Lands. If State 

certified straw and/or mulch is not available, 

individual Forests should require sources 

certified to be weed free using the North 

American Weed Free Forage Program 

standards (see Appendix O) or a similar 

certification process. 

Forests are already applying 

this standard on an informal 

basis; weed-free straw and 

mulch will be required as 

available, starting March 1, 

2006. 

Appendix A-1 
Final Environmental Impact Statement 

Standard # Text of Standard Implementation Schedule 

4 Use only pelletized or certified weed free feed 

on all National Forest System lands. If state 

certified weed free feed is not available, 

individual Forests should require feed certified 

to be weed free using North American Weed 

Free Forage Program standards or a similar 

certification process. This standard may need to 

be phased in as a certification processes are 

established. 

National Forest managers will 

encourage the use of weed-free

feed across the National 

Forests in the Region. 

Pelletized feed or certified 

weed-free feed will be 

required in all Wilderness 

areas and Wilderness 

trailheads starting January 1, 

2007. Pelletized or certified 

weed-free feed will be 

required on all National Forest 

System lands when certified 

feed is available (expected by 

January 1, 2009). Weed-free 

(or pelletized) feed 

requirements will be listed in 

individual Forest Closure 

orders. 

5 No standard. N/A 

6 Use available administrative mechanisms to 

incorporate invasive plant prevention practices 

into rangeland management. Examples of 

administrative mechanisms include, but are not 

limited to, revising permits and grazing 

allotment management plans, providing annual 

operating instructions, and adaptive 

management. Plan and implement practices in 

cooperation with the grazing permit holder. 

This standard will apply to 

grazing permits beginning 

March 1, 2006. 

7 Inspect active gravel, fill, sand stockpiles, 

quarry sites, and borrow material for invasive 

plants before use and transport. Treat or require 

treatment of infested sources before any use of 

pit material. Use only gravel, fill, sand, and 

rock that is judged to be weed free by District 

or Forest weed specialists. 

This standard will apply to 

rock source management 

beginning March 1, 2006. 

8 Conduct road blading, brushing and ditch 

cleaning in areas with high concentrations of 

invasive plants in consultation with District or 

Forest-level invasive plant specialists, 

incorporate invasive plant prevention practices 

as appropriate. 

This standard will apply to all 

road blading, brushing and 

ditch cleaning projects 

beginning March 1, 2006. 

Appendix A-2
Site-Specific Invasive Plant Treatments 

Standard # Text of Standard Implementation Schedule 

9 No standard. N/A 

10 No standard. N/A 

11 Prioritize infestations of invasive plants for 

treatment at the landscape, watershed or larger 

multiple forest/multiple owner scale. 

This standard will apply to 

invasive plant treatment 

projects with NEPA decisions 

signed after March 1, 2006. 

12 Develop a long-term site strategy for 

restoring/revegetating invasive plant sites prior 

to treatment. 

This standard will apply to 

invasive plant treatment 

projects with NEPA decisions 

signed after March 1, 2006. 

13 Native plant materials are the first choice in 

revegetation for restoration and rehabilitation 

where timely natural regeneration of the native 

plant community is not likely to occur. Nonnative, non- invasive plant species may be used 

in any of the following situations: 1) when 

needed in emergency conditions to protect 

basic resource values (e.g., soil stability, water 

quality and to help prevent the establishment of 

invasive species), 2) as an interim, nonpersistent measure designed to aid in the 

re-establishment of native plants, 3) if native 

plant materials are not available, or 4) in 

permanently altered plant communities. Under 

no circumstances will non-native invasive plant 

species be used for revegetation. 

This standard will apply to 

restoration and rehabilitation 

projects beginning March 1, 

2006. 

14 Use only APHIS and State-approved biological 

control agents. Agents demonstrated to have 

direct negative impacts on non-target organisms 

would not be released. 

This standard will apply to 

biological control projects 

beginning March 1, 2006. 

15 Application of any herbicides to treat invasive 

plants will be performed or directly supervised 

by a State or Federally licensed applicator. 

All treatment projects that involve the use of 

herbicides will develop and implement 

herbicide transportation and handling safety 

plan. 

This standard will apply to 

herbicide treatment projects as 

of March 1, 2006. 

Appendix A-3 
Final Environmental Impact Statement 

Standard # Text of Standard Implementation Schedule 

16 Select from herbicide formulations containing 

one or more of the following 10 active 

ingredients: chlorsulfuron, clopyralid, 

glyphosate, imazapic, imazapyr, metsulfuron 

methyl, picloram, sethoxydim, sulfometuron 

methyl, and triclopyr. Mixtures of herbicide 

formulations containing 3 or less of these active 

ingredients may be applied where the sum of all 

individual Hazard Quotients for the relevant 

application scenarios is less than 1.0. 

All herbicide application methods are allowed 

including wicking, wiping, injection, spot, 

broadcast and aerial, as permitted by the 

product label. Chlorsulfuron, metsulfuron 

methyl, and sulfometuron methyl will not be 

applied aerially. The use of triclopyr is limited 

to selective application techniques only (e.g., 

spot spraying, wiping, basal bark, cut stump, 

injection). 

Additional herbicides and herbicide mixtures 

may be added in the future at either the Forest 

Plan or project level through appropriate risk 

analysis and NEPA/ESA procedures. 

This standard will be applied 

to invasive plant projects with 

NEPA decisions signed after 

March 1, 2006. 

17 No standard. N/A 

18 Use only adjuvants (e.g. surfactants, dyes) and 

inert ingredients reviewed in Forest Service 

hazard and risk assessment documents such as 

SERA, 1997a, 1997b; Bakke, 2003b. 

This standard will apply to 

invasive plant treatment 

projects with NEPA decisions 

signed after March 1, 2006. 

19 To minimize or eliminate direct or indirect 

negative effects to non-target plants, terrestrial 

animals, water quality and aquatic biota 

(including amphibians) from the application of 

herbicide, use site-specific soil characteristics, 

proximity to surface water and local water table 

depth to determine herbicide formulation, size 

of buffers needed, if any, and application 

method and timing. Consider herbicides 

registered for aquatic use where herbicide is 

likely to be delivered to surface waters. 

This standard will apply to 

invasive plant treatment 

projects with NEPA decisions 

signed after March 1, 2006. 

Appendix A-4
Site-Specific Invasive Plant Treatments 

Standard # Text of Standard Implementation Schedule 

20 Design invasive plant treatments to minimize or 

eliminate adverse effects to species and critical 

habitats proposed and/or listed under the 

Endangered Species Act. This may involve 

surveying for listed or proposed plants prior to 

implementing actions within unsurveyed 

habitat if the action has a reasonable potential 

to adversely affect the plant species. Use sitespecific project design (e.g. application rate and 

method, timing, wind speed and direction, 

nozzle type and size, buffers, etc.) to mitigate 

the potential for adverse disturbance and/or 

contaminant exposure. 

This standard will apply to 

invasive plant treatment 

projects with NEPA decisions 

signed after March 1, 2006. 

21 Provide a minimum buffer of 300 feet for aerial 

application of herbicides near developed 

campgrounds, recreation residences and private 

land (unless otherwise authorized by adjacent 

private landowners). 

This standard will apply to 

invasive plant treatment 

projects with NEPA decisions 

signed after March 1, 2006. 

22 Prohibit aerial application of herbicides within 

legally designated municipal watersheds. 

This standard will apply to 

invasive plant treatment 

projects with NEPA decisions 

signed after March 1, 2006. 

23 Prior to implementation of herbicide treatment 

projects, National Forest system staff will 

ensure timely public notification. Treatment 

areas will be posted to inform the public and 

forest workers of herbicide application dates 

and herbicides used. If requested, individuals 

may be notified in advance of spray dates. 

This standard will apply to 

invasive plant treatment 

projects with NEPA decisions 

signed after March 1, 2006. 

1. ATSDR, 2004. Guidance Manual for the Assessment of Joint Toxic Action of Chemical 

Mixtures. U.S. Department Health and Human Services, Public Health Service, Agency 

for Toxic Substances and Disease Registry. 

Appendix A-5 
 
APPENDIX B 

Compliance with Mt. Hood National Forest 

Land and Resource management Plan (1990) 

and Northwest Forest Plan (1994) 
 
Site-Specific Invasive Plant Treatments 

APPENDIX B: Compliance with Mt. Hood National Forest 

Land and Resource Management Plan (1990) and Northwest 

Forest Plan (1994) 

Standards and Guidelines 

Is a plan 

amendment 

needed? 

Mt. Hood Forest Plan Standards and Guidelines 

FW-025 (Soil Productivity) 

In the first year following surface disturbing activities, the percent effective 

groundcover by soil erosion hazard class should achieve at least the following 

levels: 

 Soil Erosion Effective 

 Hazard Class Ground Cover

 Low to Moderate 60% 

 Severe 75% 

 Very Severe 85% 

FW-032 (Soil Productivity) 

Favorable habitat conditions for soil organisms should be maintained for short 

and long term soil productivity. 

FW-054 (Water) 

Water quality associated with management activities shall be in compliance 

with Oregon State requirements (Oregon Administrative Rules, Chapter 340-

41) established in accordance with the Federal Clean Water Act (1977, as 

amended 1987). 

FW-055 & FW-056 (Water) 

Compliance with State requirements shall be met through planning, 

application, and monitoring of Best Management Practices FEIS, (Appendix 

H). Best Management Practices (BMPs) describe the process which shall be 

used to implement the State Water Quality management Plan on lands 

administered by the USDA Forest Service. 

FW-057 & FW-058 (Water) 

Individual, general Best Management Practices which may be implemented 

(i.e. on a project by project basis) are described in General Water Quality Best 

Management Practices, Pacific Northwest Region, 11/88. Evaluations of ability 

to implement and estimated effectiveness shall be made at the project level. 

FW-060 (Water) 

Management practices causing detrimental changes water temperature or 

chemical composition, blockages of water courses, or deposits of sediment 

shall not be permitted (36 CFR 219.27 e). 

FW-062 (Water) 

Not more than 35 % of an area available for vegetative manipulation should be 

in a hydrologically disturbed condition at any one time. 

Appendix B-1 
Final Environmental Impact Statement 

Is a plan 

amendment 

Standards and Guidelines needed? 

Mt. Hood Forest Plan Standards and Guidelines 

FW-066 (Water) 

Cumulative effects analyses of management activities on water quality shall 

include lands on all ownerships. 

FW-075 (Water) 

The disposal or accidental discharge of petroleum products and hazardous 

materials on National Forest System lands shall be prevented. 

FW-076 (Water)

Potentially detrimental materials associated with management activities (e.g. 

pesticides, fertilizers, and road surface treatments) shall be prevented from 

entering water or other areas not intended for treatment. 

Yes 

FW-082 (Riparian Area) 

At least 95 percent ground cover (e.g. vegetation, duff, or litter) shall be 

maintained within all project activity areas (within riparian areas). 

FW-083 (Riparian Area) 

Ground disturbing activities should not occur in saturated soil areas. 

FW-084 (Riparian Area) 

Activities within and adjacent to riparian areas should not accelerate sediment 

delivery to streams, lakes, wetlands, seeps, and springs. 

FW-105 (Riparian Area) 

Fish bearing perennial streams – At least 95 % effective ground cover (e.g. 

adapted trees, shrubs, sedges, and grasses) in a project activity area should be 

maintained. 

FW-113 (Riparian Area) 

State water quality standards for turbidity shall be met. 

FW-123 (Riparian Area) 

Non-Fish bearing perennial streams (Class 3) – At least 90 % effective ground 

cover (e.g. adapted trees, shrubs, sedges, grasses, and duff) in a project activity 

area should be maintained. 

FW-129 (Riparian Area) 

Sediment loading shall be minimized and stream channel conditions 

maintained to meet State water quality standards for turbidity. 

FW-138 (Fisheries) 

Impacts on habitat for the management indicator species group (salmonids) 

shall be determined for each project affecting fisheries, in terms of habitat 

quality, quantity, and distribution. 

FW-156 (Forest Diversity) 

Vegetation management activities shall not result in a permanent loss of any 

species native to a particular ecosystem. 

Appendix B-2 
Site-Specific Invasive Plant Treatments 

Is a plan 

amendment 

Standards and Guidelines needed? 

Mt. Hood Forest Plan Standards and Guidelines 

FW-161 (Forest Diversity) 

Management activities shall contribute to recovery and conservation of 

Federally listed threatened or endangered species (endangered Species Act, 

`1973; 36 CEF 219.19) 

FW-162 (Forest Diversity) 

Habitat Management should provide for maintenance of viable populations of 

native and desirable non-native wildlife, fish, and plant species. 

FW-174 (Threatened, Endangered and Sensitive Plants and Animals) 

Threatened, endangered and sensitive plants and animals shall be identified 

and managed in accordance with the Endangered Species Act (ESA) (1973), 

Oregon ESA (1987), and FSM 2670. 

FW-175 (Threatened, Endangered and Sensitive Plants and Animals) 

Habitat for threatened, endangered and sensitive plants and animals shall be 

protected and/or improved. 

FW-177 & 178 (Threatened, Endangered and Sensitive Plants and 

Animals) 

Consultation with FWS shall occur on each program activity or project that the 

Forest Service determines may effect threatened or endangered species. 

Consult 

FW-179 (Threatened, Endangered and Sensitive Plants and Animals) 

Species Management Guides shall be prepared to address effects of 

management activities and identify opportunities to maintain or enhance 

habitat for plants frequently in conflict with mgmt. practices. 

FW-180 (Threatened, Endangered and Sensitive Plants and Animals) 

Lists of threatened, endangered and sensitive plant and animal species shall be 

maintained and updated periodically as new information is collected. 

FW-182, 183, 184 (Threatened, Endangered and Sensitive Plants and 

Animals) 

If habitat allocated for threatened, endangered or sensitive species protection or 

recovery (i.e. A8 Spotted Owl Habitat Areas and A13 Bald Eagle Recovery 

Areas) is lost (e.g. due to windthrow or wildfire), replacement habitat of equal 

or better quality (or the best available) shall be designated and allocated. For 

A8 Management Areas, replacement habitat shall be allocated if 30 acres or 

more habitat is lost. Replacement habitat should be located immediately 

adjacent to the remaining A8 habitat. 

FW-187 (Wildlife) 

Key habitat areas (e.g. reading areas, mineral licks, and wallows) should be 

protected. 

FW-189 (Wildlife) 

Existing natural meadows/openings shall be maintained. 

Appendix B-3 
Final Environmental Impact Statement 

Is a plan 

amendment 

Standards and Guidelines needed? 

Mt. Hood Forest Plan Standards and Guidelines 

FW-213 (Wildlife) 

Activities within key deer and elk rearing areas may be restricted between May 

15 and July 1. 

FW-243 (Wildlife) 

Plant community integrity of special habitat conditions, e.g. caves, cliffs, talus 

slopes, meadows, oak, and dry shrub should be protected. 

FW-279 (Hazardous Materials) 

Project spill contingency plans shall be developed for all project activities 

where oil or potentially hazardous substances are used by the Forest Service, 

its permittees, or other users (i.e. contractors) of National Forest lands. 

FW-280 (Hazardous Materials) 

Employee involvement with, and the use of, hazardous materials shall be in 

accordance with the USDA Forest Service Health and Safety Code Handbook. 

FW-281 (Hazardous Materials) 

Employees shall comply with all Forest Service policies as identified in the 

USDA Forest Service Health and Safety Code Handbook. 

FW-300 (Range Management) 

Plants identified as pests by Oregon Department of Agriculture (ODA) shall be 

controlled. 

FW-301 (Range Management) 

Implementation of control measures should adhere to priorities of prevention, 

early treatment, maintenance, correction, and no action. 

FW-375 (Timber Management) 

New provisions for all vegetation management. projects shall be followed for 

all projects planned with NEPA documents. 

FW-378 & FS-379 (Timber Management) 

Emphasis shall be on prevention of vegetation management problems and 

herbicides shall be used only when necessary. 

FW-380 (Timber Management) 

Competing vegetation shall be controlled when there is possibility that timber 

harvest areas cannot be reforested within 5-year period [because of invasive 

plants]. 

FW-381 (Timber Management)

In timber harvest areas, prevent damage to plantation crop trees, prevent 

stocking from falling below desired levels, insure reforestation within 5-year 

period, and maintain Pacific yew. 

Appendix B-4 
Site-Specific Invasive Plant Treatments 

Is a plan 

amendment 

Standards and Guidelines needed? 

Mt. Hood Forest Plan Standards and Guidelines 

Fw-382 & FW-383 (Timber Management) 

Silvicultural methods and cultural treatments should be applied to reduce 

hazards from insects, diseases, and weed species. If normal insect surveillance 

indicates the threat of an epidemic, project level detection and control 

operation (including coordination with other land ownerships) should be 

accomplished on a Forestwide basis (Regional Guide for Pacific Northwest 

region, 1984) 

FW-463 (Dispersed Recreation Activities) 

Designated trails, trailheads, associated facilities, and dispersed recreation sites 

impacted and/or adversely affected by management activities, shall be 

rehabilitated, restored, and/or relocated. 

FW-470 (Eligible Wild, Scenic, and Recreational Rivers) 

Outstandingly remarkable values of the identified eligible river segments 

(FEIS Appendix E) shall be protected and/or enhanced (FSH 1909.12, Chapter 

8, 7/87). 

FW-496 (Visual Resource Management) 

The visual quality objectives (VQOs) for wild segments shall be Preservation 

as seen from the river, river banks and trails within the B1 river corridor. A 

VQO of Retention may be allowed for recreational facilities. 

FW-497 (Visual Resource Management) 

The VQO for scenic segments shall be Retention as seen from the river, river 

banks, U.S. and State highways, Forest highways and roads, trails, and 

recreation facilities within the B1 river corridor. A VQO of Partial Retention 

may be allowed for structural facilities. 

FW-498 (Visual Resource Management) 

The VQO for recreational segments shall be Partial Retention as seen from the 

river, river banks, U.S. and State highways, Forest highways and roads, trails, 

and recreation facilities within the B1 river corridor. Modification may be 

allowed for structural facilities. 

FW-513 (Eligible Wild, Scenic, and Recreational Rivers) 

Water quality shall be maintained or enhanced during any management 

activities. 

FW-552 & 553 (Visual Resource Management) 

The visual quality objectives (VQO, USDA-Agriculture Handbook 462, 

National Forest Landscape Management, Vol. 2, Chap. 1, The Visual 

Management System) prescribed in management direction represent the 

minimum level that shall be achieved in long term visual resource 

management. Management Area VQO’s shall be prescribed as summarized in 

Table Four-22. See Management Area Standards and Guidelines. 

FW-554 (Visual Resource Management) 

Visual quality objectives for “designated viewsheds” shall be prescribed as 

listed in Table Four-23 Designated Viewsheds. 

Appendix B-5 
Final Environmental Impact Statement 

Is a plan 

amendment 

Standards and Guidelines needed? 

Mt. Hood Forest Plan Standards and Guidelines 

FW-556 & 557 (Visual Resource Management) 

The prescribed VQO should be achieved within one year after completion of 

any project activities. Short term deviations from prescribed visual quality 

objectives may occur due to catastrophic events, e.g. fire, windstorm, 

earthquake, and insect damage. 

FW-609 & 610 (Cultural Resources Management) 

All proposed projects which could affect a cultural resource shall be assessed 

for their effect on National Register, eligible, or unevaluated properties. 

Assessments shall use the criteria of “effect and adverse effect” (36 CFR 

800.9. Projects include all Federally funded undertakings, and undertakings 

requiring Federal permit (36 CFR 800.9 (a)(b)). 

FW-627 (Human Rights) 

The Forest shall be managed and administered in such a manner as to provide 

all persons equal opportunity, regardless of race, color, creed, sex, marital 

status, age, handicap, religion, or national origin. 

FW-628 (Human Rights) 

The Forest shall be managed to break down social and institutional barriers to 

legitimate uses of the Forest by nontraditional groups. 

FW-629 (Human Rights) 

Consultation with diverse cultural groups shall occur on a regular basis. 

FW-630&631 (Human Rights) 

The treaty rights and privileges of Native Americans shall be honored. Treaty 

rights and privileges should supercede other management direction. 

FW-632 (Human Rights) 

The American Indian Religious Freedom Act (1978) shall be considered in 

administration of the Forest. 

FW-639-640 (Human Rights) 

Special efforts shall be made to inform the public, including minorities and 

underprivileged individuals and groups, of benefits they are eligible to receive 

from Forest programs. Techniques suited to increase awareness and 

participation shall be used. 

A1-WR-064 (Vegetation Management) – Amendment #7 

Chemicals shall not be used to control noxious weeds in riparian areas. Yes 

A2-070 & A2-071 (Wilderness) 

Timber harvesting and commercial gathering of forest products shall not be 

permitted. Vegetation management activities shall produce or enhance 

wilderness values. 

A2-082 (Wilderness) 

Pesticide use shall be prohibited. Yes 

Appendix B-6 
Site-Specific Invasive Plant Treatments 

Is a plan 

amendment 

Standards and Guidelines needed? 

Mt. Hood Forest Plan Standards and Guidelines 

A2-074 (Wilderness) 

Areas that do not meet Wild and Scenic River bare ground and vegetative 

cover criteria (B.2, Four-138) shall be revegetated. 

A2-083 (Wilderness) 

Introduction of non-native plant species should not occur. 

A2-084 (Wilderness) 

Acceleration of soil displacement and erosion resulting from human activity 

should not occur. 

A12-031 (Outdoor Education Areas) 

Herbicides should not be applied outside of roads rights-of-way. Yes 

A12-032 (Outdoor Education Areas) 

If pesticide application is deemed necessary, biological control measures 

should be considered. 

B1-048 (Wild, Scenic and Recreational Rivers) 

Water quality shall be maintained or enhanced d. 

B1-050 (Wild, Scenic and Recreational Rivers) 

All river segments shall be managed to remain in a free flowing and unpolluted 

state. 

B2-071 (Scenic Viewsheds) 

All IPM (integrated pest management) activities shall minimize impacts to 

scenic quality. 

B5-041 (Pileated Woodpecker/Pine Martin Habitat) 

Herbicides should not be permitted outside of road rights-of-way. Yes 

B6-026 (Special Emphasis Watersheds) 

Activities involving fertilization or chemical treatment of vegetation, in 

municipal or domestic watersheds shall be coordinated with appropriate 

municipalities or individuals. 

B6-042 (Special Emphasis Watersheds) 

Activities involving pesticide application in municipal or domestic watersheds 

shall be coordinated with associated municipalities, groups or individuals. 

B7-070 (General Riparian Area) 

Application of herbicides shall be discouraged. Yes 

D-021 (Bull Run Watershed Management Unit) 

Chemical insecticides and herbicides shall be prohibited within the Bull Run 

physical drainage. 

Appendix B-7 
Final Environmental Impact Statement 

Standards and Guidelines

Is a plan 

amendment 

needed? 

Northwest Forest Plan Standards and Guidelines 

General Riparian Area, RA-3 

Herbicides, insecticides, and other toxicants, and other chemicals shall be 

applied only in a manner that avoids impacts that retard or prevent attainment 

of Aquatic Conservation Strategy objectives. 

C-4 & C-5 

Survey and Manage Standards &Guidelines: (1) manage known sites, (2) 

survey prior to ground-disturbing activities. 

C-6 

Manage recreation areas to minimize disturbance to Survey & Manage species. 

Northwest Forest Plan Aquatic Conservation Strategy Objective #9 

Maintain and restore habitat to support well-distributed populations of native 

plant, invertebrate, and vertebrate riparian dependent species. 

Appendix B-8 
APPENDIX C 

Columbia River Gorge National Scenic Area 

Management Plan – Consistency 

Determination 
 
Site-Specific In

APPENDIX C: Columbia River Gorge National Scenic Area Management Consistency Determination (CD-06-11-S) for the Site-Specific Invasive PTreatments for the Mt. Hood National Forest and the Columbia River GoScenic Area in Oregon Prepared by Robin Dobson, Ecologist, Columbia River Gorge National Scenic Area, September 2006 FINDINGS OF FACT The following findings of fact contain the applicable standards and guidelines from the Columbia River Gorge N

Management Plan (Management Plan). The Management Plan, as revised and adopted in 2004, is in effect. Mana

requires that projects on National Forest lands also be consistent with the Land and Resource Management Plans National Forests. The USDA Forest Service applies the more protective standard of either the Management Plan Resource Management Plan. For this project, the applicable Land and Resource Management Plan is the Mt. HooForest Plan. The applicable Forest Plan Standards and Guidelines are listed in Appendix B. 

Project Proposal The project proposal is described in Chapters 1 and 2 of the EIS. Appendix F – Site and Treatment Information, Existing Condition Characteristics provide site specific information for the 7 treatment areas in the Scenic Area. Plan does not apply regulations to herbicide use, per Special Management Area (SMA) Wildlife and Plants Polic

and federal regulations for air and water quality and for pesticide use shall be followed.” Herbicides are likewise General Management Area (GMA) guidelines. The manual, mechanical and cultural treatment methods are subjePlan requirements, and are the subject of this review. The following table displays information relevant to the codetermination.

Appendix C-1 
Final Environmental Impact Statement 

Appendix C-2 

Table C-1: Scenic Area Consistency Determination, Management Plan Information for Treatment Are

Treat ID Area Co. Acre Location LUD LS 

Scenic 

Standard

(VQO) Visible from N

22-01 Sandy River Delta Mult 1573

T1N/R3E/S13 TL 100 T1N/R3E/S24 TL 100, 500 T1N/R3E/S25 TL 100 T1N/R4E/ TL 100, 200, 300 

PR/OS RB VS/NVE Fg: I-84, Sandy Ri

Columbia River 

22-05 Wyeth Bench 

HoodRiver 

 90 

T2N/R8E/S5 TL 200, 900 – 31 ac T2N/R8E/S4 TL 201 – 20 ac T3N/R8E/S34 TL 400, 500, 600 – 28 ac T2N/R8E/S2 TL300, T3/R8/S35 TL200,300– 19 ac 

UA/OS F PR, F F 

CW/UA CW CW CW 

NVE/Na NVE VS NVE 

Fg: I-84 Fg: Wyeth Bench RFg: Wyeth Bench RFg: Wyeth Bench R

22-07 Wells Island 

HoodRiver 

 21 T3N/R10E/S26 TL 200 OS RB NVE Fg: Columbia Rive

22-08 East Pit 

HoodRiver 

24 T2N/R11E/S4 TL 100 

T3N/R11E/S33 TL 101 OS GMA GW – (GMA) VS Fg: HCRH 

22-11 Memaloose/ Rowena Wasco 110 

T2N/R12E/S5 TL 2400 - 13 ac T2N/R12E/S4 TL 201 - 9 ac T2N/R12E/S4 TL 800, S3C TL 500,600 - 25 ac T2N/R12E/S3 TL 400 - 33 ac T2N/R12E/ TL 400,500 - 24 ac 

Ag Ag/OS Ag OS A1/Ag/OS 

OW OW OW OW OW/GW 

VS VS VS NVE VS/NVE 

Fg: HCRH Fg: HCRH Mg: HRCH, Tom MFg: HCRH, RowenMg: HCRH 

22-12 7 Mile Hill Rd Chenoweth Tbl Wasco 81 T2N/R13E/S19 TL 300 - 55 ac T2N/R13E/S30 TL700, S31 TL200, 300,400 -26 ac A-1 OS G OW VS NVE Mg: I-84 Bg: Col River, SR122-17 

Chamberlain Road/Corbett Women Forum 

Thors Heights 

Mult 

139 

T1N/R4E/(S30) TL 400 – 19 ac T1N/R4E/S29CC TL 700 – 5 ac T1N/R4E/S29CC TL 300 – 5 ac T1N/R4E/S28D TL 700,600,500,400,100 – 28 ac T1N/R4E/S27 TL 1100,1000,900 – 40 ac T1N/R4E/S25CD TL 700,1100,1200,1000 – 9 ac T1N/R5E/S30C TL400, S30CC TL200,300 – 29 ac 

Ag/A1/OS/R Ag Ag Ag/OS Ag/OS PR/OS F 

P/CW/RR P P P/ CW P/ CW CW P 

VS/NVE VS VS VS / NVE VS / NVE VS / NVE VS 

Mg Col/Sandy RvrMg Columbia RiveMg Columbia RiveFg I-84 Fg I-84 Fg Women;s ForumFg Larch Mtn Rd 

Key to Table C-1 

LUD – Land Use Designation LS – Landscape Setting Scenic Standard KVA - KPR – Public Recreation RB – River Bottomlands VS – Visual Subordinance (Partial Retention) Fg: ForeOS – SMA Open Space P – Pastoral NVE. – Not Visually Evident (Retention) Mg: MidOS GMA – GMA Open Space RR in P – Rural Residential in Pastoral (GMA) Bg: BacAg – SMA Agriculture CW – Coniferous Woodland I-84 – InA-1 GMA Large Scale Agriculture GW – Gorge Walls, Canyon Lands and Wildlands HRCH – F – SMA Forest OW – Oak Woodlands Col Rvr R – Residential (GMA) G – Grasslands (GMA) SR14 – UA – Urban Area 
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Appendix C-3 

Table C-2: Consistency with Management Plan Guidelines 

Land Use DesignationsThe project is located in SMA Agriculture, Forest, Public Recreation and Open Space; GMA Agriculture and Open SpaLocks Urban Area (see Table C-1). All of these designations allow resource enhancement activities, and contain virtulanguage. Review Uses Findings 

Resource enhancement projects for the purpose of enhancing scenic, cultural, recreation and/or natural resources, subject to the guidelines in "Resource Enhancement Projects" (Part II, Chapter 7: General Policies and Guidelines). These projects may include new structures 

(e.g., fish ladders, sediment barriers) and/or activities (e.g., closing and revegetating unused roads, recontouring abandoned quarries). 

Project as described meets guideline Project requires the following condition 

Resource Enhancement Projects Guidelines - Applicable 1. Applications for resource enhancement projects must describe the goals and benefits of the 

proposed enhancement project. They must also thoroughly document the condition of the resource before and after the proposed enhancement project. 

Project as described meets guideline. WProject requires the following condition 

SMA Open Space 

1. An Open Space plan shall be completed by the primary managing agency or land owner 

prior to any new land uses or development, and shall be reviewed by the USDA Forest Service. The Open Space plan shall include the following: 

A. Direction for resource protection, enhancement, and management. B. Review of existing uses to determine compatibility with Open Space values. 

 C. Consultation with members of the public and with agency and resource specialists. 

 Project as described meets guideline. 

Applicable Open Space Plans address inva Sandy River Delta FEIS: pages 2-15, 2-1

Delta Plan pages 27-40. 

 Columbia River Tribs West Watershed A Columbia River Tributaries East Watersh Wells Island Open Space Plan, pages 9- Rowena Plan, page 51 

Project requires the following condition 

2. F. Treatment of noxious weeds shall be permitted without completion of an SMA Open Space 

plan when the following criteria have been met: (1) Noxious weed infestation is new and eradication is still viable. (2) Delayed or deferred treatment could have widespread or major adverse impacts to one 

or more of the following resources: (a) Displacement of native and traditionally gathered plants; 

 Project as described meets guideline. O

completed for Chenoweth Table and thdescribes 1) the state of noxious weed adverse resource impacts from delayeeffects are thoroughly evaluated. 

Project requires the following condition 
Final Environmental Impact Statement 

Appendix C-4 

(b) Degradation of wildlife habitat and forage; (c) Degradation or loss of agricultural uses of land, such as cropland or livestock forage; (d) Limitation of recreational uses. (3) For federal lands, treatment effects have been thoroughly evaluated in an 

environmental assessment. 

Scenic Resources Table C-1 displays the scenic standard for each treatment area, and the closest Key Viewing Area. Scenic resources 3.12, Scenery Management. SMA guidelines apply to most treatment areas. GMA guidelines apply to all of Treatment acres of Area 22-11, 55 acres of Area 22-12 and 8 acres of Area 22-17. In addition, about 30 acres of Area 22-05 are subject to Scenic Area guidelines. SMA guidelines are evaluated first, followed by GMA guidelines. Where SMA and Gessentially the same, they are combined. SMA Scenic Resource Guidelines - Applicable Findings SMA Design Guidelines Based on Landscape Settings

A. Pastoral: Pastoral areas shall retain the overall appearance of an agricultural landscape. 

(1) The use of plant species common to the landscape setting shall be encouraged. The use 

of plant species in rows, as commonly found in the landscape setting, is encouraged. 

 Project as described meets guideline. S

Section 2.1.3, and 2.1.4. 

 Project requires the following condition 

B. Coniferous Woodland and Oak-Pine Woodland: Woodland areas shall retain the overall 

appearance of a woodland landscape. New developments and land uses shall retain the overall visual character of the natural appearance of the Coniferous Woodland and Oak-Pine 

Woodland landscape. (2) Use of plant species native to the landscape setting shall be encouraged. Where nonnative plants are used, they shall have native-appearing characteristics. 

 Project as described meets guideline. S

Section 2.1.3, and 2.1.4. 

 Project requires the following condition 

D. River Bottomlands: River Bottomlands shall retain the overall visual character of a floodplain 

and associated islands. (2) Use of plant species native to the landscape setting shall be encouraged. Where nonnative plants are used, they shall have native-appearing characteristics. 

 Project as described meets guideline. S

Section 2.1.3, and 2.1.4. 

 Project requires the following condition 

E. Gorge Walls, Canyonlands, and Wildlands: New developments and land uses shall retain the 

overall visual character of the natural-appearing landscape. 

(4) Use of plant species non-native to the Columbia River Gorge shall not be allowed 

 Project as described meets guideline. S

Section 2.1.3, and 2.1.4. 

 Project requires the following condition 
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Appendix C-5 

SMA Guidelines for Development and Uses Visible from KVAs

1. The guidelines in this section shall apply to proposed developments on sites topographically 

visible from key viewing areas. (GMA KVA Guideline 1) 

As described in Table C-1, at least portions 

topographically visible from KVAs (source: 

2. New developments and land uses shall be evaluated to ensure that the required scenic 

standard is met and that scenic resources are not adversely affected, including cumulative effects, based on the degree of visibility from key viewing areas. 

 Project as described meets guideline. S Project requires the following condition 

4. In all landscape settings, scenic standards shall be met by blending new development with 

the adjacent natural landscape elements rather than with existing development 

 Project as described meets guideline. S Project requires the following condition 

5. Proposed developments or land uses shall be sited to achieve the applicable scenic standard. 

Develop-ment shall be designed to fit the natural topography, to take advantage of landform 

and vegetation screening, and to minimize visible grading or other modifications of landforms, vegetation cover, and natural characteristics. When screening of development is needed to meet the scenic standard from key viewing areas, use of existing topography and vegetation shall be given priority over other means of achieving the scenic standard such as planting new vegetation or using artificial berms. 

 Project as described meets guideline. S Project requires the following condition 

6. The extent and type of conditions applied to a proposed development or use to achieve the 

scenic standard shall be proportionate to its degree of visibility from key viewing areas. (GMA KVA Guideline 4.A. (1) through (5)) 

A. Decisions shall include written findings addressing the factors influencing the degree of 

visibility, including but not limited to: 

(1) The amount of area of the building site exposed to key viewing areas, (2) The degree of existing vegetation providing screening, (3) The distance from the building site to the key viewing areas from which it is visible, (4) The number of key viewing areas from which it is visible, and (5) The linear distance along the key viewing areas from which the building site is visible (for 

linear key viewing areas, such as roads). 

 Project as described meets guideline. S Project requires the following condition 

Table C-1 identifies the closest KVA. 

B. Conditions may be applied to various elements of proposed developments to ensure they are 

visually subordinate to their setting as seen from key viewing areas, including but not limited to: (GMA KVA Guideline 4.B. (1) through (4)) (1) Siting (location of development on the subject property, building orientation, and other 

elements), 

 Project as described meets guideline. S Project requires the following condition 
Final Environmental Impact Statement 

Appendix C-6 

(2) Retention of existing vegetation, (3) Design (color, reflectivity, size, shape, height, architectural and design details and other 

elements), 

(4) New landscaping. 

7. Sites approved for new development to achieve scenic standards shall be consistent with 

guidelines to protect wetlands, riparian corridors, sensitive plant or wildlife sites and the buffer zones of each of these natural resources, and guidelines to protect cultural resources. 

 Project as described meets guideline. S Project requires the following condition 

8. Proposed developments shall not protrude above the line of a bluff, cliff, or skyline as seen 

from key viewing areas. 

 Project as described meets guideline. S Project requires the following condition 

SMA Guidelines for KVA Foregrounds and Scenic Routes 1. All new developments and land uses immediately adjacent to scenic routes shall be in 

conformance with state or county scenic route guidelines. 

 Project as described meets guideline. S Project requires the following condition 

GMA Scenic Resource Guidelines - Applicable Findings Overall Scenic Provisions 5. For all proposed development, the determination of compatibility with the landscape setting 

shall be based on information submitted in the site plan. 

 Project as described meets guideline. S Project requires the following condition 

Key Viewing Areas

2. Each development shall be visually subordinate to its setting as seen from key viewing areas. 

 Project as described meets guideline. S Project requires the following condition 

3. Determination of potential visual effects and compliance with visual subordinance policies 

shall include consideration of the cumulative effects of proposed developments. 

 Project as described meets guideline. S Project requires the following condition 

5. New development shall be sited to achieve visual subordinance from key viewing areas, 

unless the siting would place such development in a buffer specified for protection of wetlands, riparian corridors, sensitive plants, or sensitive wildlife sites or would conflict with guidelines to protect cultural resources. In such situations, development shall comply with this guideline to the maximum extent practicable.

 Project as described meets guideline. S Project requires the following condition 

6. New development shall be sited using existing topography and/or existing vegetation as 

needed to achieve visual subordinance from key viewing areas. 

 Project as described meets guideline. S Project requires the following condition 
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Appendix C-7 

7. Existing tree cover screening proposed development from key viewing areas shall be retained 

as specified in the Landscape Settings Design Guidelines section of this chapter. 

 Project as described meets guideline. S

no existing trees are planned to be rem

 Project requires the following condition 

Landscape Settings 

GMA Landscape Settings guidelines apply only to new structures and vegetation planted or retained for screening; the guidelines do not apply to this project. 

n/a 

Scenic Travel Corridors 

I-84 and the Historic Columbia River Highway are Scenic Travel Corridors in the vicinity of this proposal. The Scenic Travel Corridor guidelines apply only to buildings, view clearing in public rights-of-way, utilities, and quarries and therefore do not apply to this project. 

n/a 

Cultural Resources The proposed treatment methods fall within the description of activities found to have no potential to affect heritage rewithin the 2004 Programmatic Agreement between the Pacific Northwest Region of the USDA Forest Service, The StaOffice, and the Advisory Council on Historic Preservation (Appendix Y). See Section 3.13.1 The SMA and GMA requirements are essentially the same. Findings for the SMA requirements suffice for the GMA. SMA Cultural Resource Policies – Applicable Findings 1. New developments or land uses shall not adversely affect significant cultural 

resources. 

 Project as described meets guideline  Project requires the following condition to meet this 

“Should any historic or prehistoric cultural resources be 

activities, the applicant shall cease work and immediateand the Washington Office of Archeology and historical should also notify the Indian Tribal governments within 2prehistoric or otherwise associated with Native America

7. The USDA Forest Service shall be responsible for performing steps 1 through 5 

under guideline 4 for forest practices and National Forest system lands. 

 Project as described meets guideline – See Section  Project requires the following condition to meet this 

8. The USDA Forest Service shall consult with the Indian tribal governments and 

other consulting parties in performing steps 1 through 5 under guideline 4. Project as described meets guideline (will continue t

 Project requires the following condition to meet this 
Final Environmental Impact Statement 

Appendix C-8 

Indian Tribal Treaty Rights and ConsultationThe Confederated Tribes of Warm Springs, the Yakama Nation, the Nez Perce Tribe, the Confederate Tribes of the Uas well as the Confederated Tribes of the Grand Ronde were given opportunity to comment on the project. USDA Formembers of the Warms Springs Tribe. Further opportunities for tribal consultation and comment will continue throughothis is a USDA Forest Service project and most of the affected area is within the SMA, the SMA treaty rights process hsites are not located in the Columbia River or its fishbearing tributaries. Findings for the SMA requirements suffice for SMA Treaty Rights and Consultation Policies - Applicable Findings 1. The USDA Forest Service shall consult with the Indian tribal governments to determine 

the effect of all new development or uses in the SMA on treaty rights and shall notify the county or reviewing agency of the determination. 

Project as described meets guideline 

 Project requires the following condition to m

6. New uses and development shall not affect or modify any treaty or other rights of the 

Indian tribal governments. 

Project as described meets guideline 

 Project requires the following condition to m

8. New developments or land use shall protect access to usual and accustomed tribal or 

Indian fishing sites or stations protected under treaty rights, and as established by court interpretations of those treaties 

Project as described meets guideline 

 Project requires the following condition to m

10. Federal land management agencies shall not deny Indian tribal governments, or individual 

members of Indian tribes, access to any area on federal or state land that is traditionally used in connection with tribal treaty or ceremonial rights or for traditional uses. 

Project as described meets guideline 

 Project requires the following condition to m
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Appendix C-9 

Natural ResourcesAppendix O – Existing Condition Characteristics provides site specific information for the 7 treatment areas in the Sceare discussed in Sections 3.6 – Botany; 3.8 – Soils; 3.9 – Water Quality; 3.10 – Aquatic Organisms and Habitats; and guidelines apply to most treatment areas. GMA guidelines apply to all of Treatment Area 22-08, about 19 acres of Are22-12 and 8 acres of Area 22-17. In addition, about 30 acres of Area 22-05 are in an Urban Area and not subject to SGMA portion of Area 22-17 has no sensitive natural resources. The other GMA areas contain water resources (pondsplant and a sensitive wildlife site. SMA guidelines are evaluated first, followed by GMA guidelines. Where SMA and Gessentially the same, they are combined.SMA Natural Resource Policies – Applicable Findings Water Resources (Wetlands, Streams, Ponds, Lakes, and Riparian Areas) A. All Water Resources shall, in part, be protected by establishing undisturbed buffer zones as 

specified in 2.A.(2)(a) and 2(b) below. These buffer zones are measured horizontally from a wetland, stream, lake, or pond boundary as defined below. (1) All buffer zones shall be retained undisturbed and in their natural condition, except as permitted 

with a mitigation plan. 

(2) Buffer zones shall be measured outward from the bank full flow boundary for streams, the high 

water mark for ponds and lakes, the normal pool elevation for the Columbia River, and the wetland delineation boundary for wetlands on a horizontal scale that is perpendicular to the wetlands, stream, pond or lake boundary. On the main stem of the Columbia River above Bonneville Dam, buffer zones shall be measured landward from the normal pool elevation of the Columbia River. The following buffer zone widths shall be required:  (a) A minimum 200 foot buffer on each wetland, pond, lake, and each bank of a perennial or 

fish bearing stream, some of which can be intermittent. 

(b) A 50-foot buffer zone along each bank of intermittent (including ephemeral), non-fish 

bearing streams. 

 Project as described meets guide Project requires the following cond

Appendix O describes the proximity o

resource buffers. Buffers will be enterPracticable Alternative Test and MitigThe Project Design Criteria (PDC) of SAppendix A mitigate impacts to water 

3) The buffer width shall be increased for the following: 

(a) When the channel migration zone exceeds the recommended buffer width, the buffer width 

shall extend to the outer edge of the channel migration zone. 

(b) When the frequently flooded area exceeds the recommended riparian buffer zone width, the 

buffer width shall be extended to the outer edge of the frequently flooded area. 

(c) When an erosion or landslide hazard area exceeds the recommended width of the buffer, 

the buffer width shall be extended to include the hazard area. 

Project as described meets guide

 Project requires the following cond
Final Environmental Impact Statement 

Appendix C-10 

(4) Buffer zones can be reconfigured if a project applicant demonstrates all of the following: (1) the 

integrity and function of the buffer zones is maintained, (2) the total buffer area on the development proposal is not decreased, (3) the width reduction shall not occur within another buffer, and (4) the buffer zone width is not reduced more than 50% at any particular location. Such features as intervening topography, vegetation, man made features, natural plant or wildlife habitat boundaries, and flood plain characteristics could be considered. 

Project as described meets guide

not request a buffer reconfiguratio

 Project requires the following con

B. When a buffer zone is disturbed by a new use, it shall be replanted with only native plant species of 

the Columbia River Gorge. 

Project as described meets guide

 Project requires the following cond

C. The applicant shall be responsible for identifying all water resources and their appropriate buffers 

(see above). 

Project as described meets guide

 Project requires the following cond

D. Wetlands Boundaries shall be delineated using the following: 

(1) The approximate location and extent of wetlands in the Scenic Area is shown on the National 

Wetlands Inventory (U. S. Department of the Interior, 1987). In addition, the list of hydric soils and the soil survey maps shall be used as an indicator of wetlands. 

(2) Some wetlands may not be shown on the wetlands inventory or soil survey maps. Wetlands that 

are discovered by the local planning staff during an inspection of a potential project site shall be delineated and protected. 

(3) The project applicant shall be responsible for determining the exact location of a wetlands 

boundary. Wetlands boundaries shall be delineated using the procedures specified in the ‘1987 

Corps of Engineers Wetland Delineation Manual (on-line Edition)’. 

(4) All wetlands delineations shall be conducted by a professional who has been trained to use the 

federal delineation procedures, such as a soil scientist, botanist, or wetlands ecologist. 

Project as described meets guide

have been delineated. 

 Project requires the following cond

E. Stream, pond, and lake boundaries shall be delineated using the bank full flow boundary for 

streams and the high water mark for ponds and lakes. The project applicant shall be responsible for determining the exact location of the appropriate boundary for the water resource. 

Project as described meets guide

 Project requires the following cond

G. Buffer zones shall be undisturbed unless the following criteria have been satisfied: 

(1) The proposed use must have no practicable alternative as determined by the practicable 

alternative test. Those portions of a proposed use that have a practicable alternative will not be located in wetlands, stream, pond, lake, and riparian areas and/or their buffer zone. 

Project as described meets guide

has been completed. 

 Project requires the following cond
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Appendix C-11 

(3) Unavoidable impacts to wetlands and aquatic and riparian areas and their buffer zones shall be 

offset by deliberate restoration and enhancement or creation (wetlands only) measures as required by the completion of a mitigation plan. 

Project as described meets guide

completed. 

 Project requires the following cond

Wildlife and Plants

A. Protection of sensitive wildlife/plant areas and sites shall begin when proposed new developments 

or uses are within 1000 ft of a sensitive wildlife/plant site and/or area. Sensitive Wildlife Areas are those areas depicted in the wildlife inventory and listed in Tables 4 and 7, including all Priority 

Habitats listed in this Chapter. The approximate locations of sensitive wildlife and/or plant areas 

and sites are shown in the wildlife and rare plant inventory. 

 Project as described meets guide Project requires the following cond

Table C-1 and Appendix O describe tto sensitive wildlife/plant areas and sit

invasive plants. A Practicable Alternatbeen prepared. The PDC of Section 2mitigate impacts to sensitive wildlife/p

C. The USDA Forest Service wildlife biologists and/or botanists, in consultation with the appropriate 

state biologists, shall review the site plan and their field survey records. They shall: (1) Identify/verify the precise location of the wildlife and/or plant area or site, 

(2) Determine if a field survey will be required, 

(3) Determine, based on the biology and habitat requirements of the affected wildlife/plant species, 

if the proposed use would compromise the integrity and function of or adverse affects (including cumulative effects) to the wildlife or plant area or site. This would include considering the time of year when wildlife or plant species are sensitive to disturbance, such as nesting, rearing seasons, or flowering season, and 

Project as described meets guide

 Project requires the following cond

(4) Delineate the undisturbed 200 ft buffer on the site plan for sensitive plants and/or the 

appropriate buffer for sensitive wildlife areas or sites, including nesting, roosting and perching sites. 

Project as described meets guide

 Project requires the following cond

D. The local government, in consultation with the State and federal wildlife biologists and/or botanists, 

shall use the following criteria in reviewing and evaluating the site plan to ensure that the proposed developments or uses do not compromise the integrity and function of or result in adverse affects to the wildlife or plant area or site: 

(1) Published guidelines regarding the protection and management of the affected wildlife/plant 

species. Examples include: the Oregon Department of Forestry has prepared technical papers that include management guidelines for osprey and great blue heron; the Washington Department of Wildlife has prepared similar guidelines for a variety of species, including the western pond turtle, the peregrine falcon, and the Larch Mountain salamander (Rodrick and Milner 1991). 

Project as described meets guide

 Project requires the following cond
Final Environmental Impact Statement 

Appendix C-12 

(2) Physical characteristics of the subject parcel and vicinity, including topography and vegetation. (3) Historic, current, and proposed uses in the vicinity of the sensitive wildlife/plant area or site. (4) Existing condition of the wildlife/plant area or site and the surrounding habitat and the useful life 

of the area or site. 

(5) In areas of winter range, habitat components, such as forage, and thermal cover, important to 

the viability of the wildlife must be maintained or, if impacts are to occur, enhancement must mitigate the impacts so as to maintain overall values and function of winter range. 

(6) The site plan is consistent with the "Oregon Guidelines for Timing of In-Water Work to Protect 

Fish and Wildlife Resources" (Oregon Department of Fish and Wildlife 2000) and the Washington guidelines when they become finalized. 

(7) The site plan activities coincide with periods when fish and wildlife are least sensitive to 

disturbance. These would include, among others, nesting and brooding periods (from nest building to fledgling of young) and those periods specified. 

(8) The site plan illustrates that new developments and uses, including bridges, culverts, and utility 

corridors, shall not interfere with fish and wildlife passage. 

(9) Maintain, protect, and enhance the integrity and function of Priority Habitats (such as old growth 

forests, talus slopes, and oak woodlands) as listed on the following Priority Habitats Table. This 

includes maintaining structural, species, and age diversity, maintaining connectivity within and between plant communities, and ensuring that cumulative impacts are considered in documenting integrity and function. 

E. The wildlife/plant protection process may terminate if the local government, in consultation with the 

USDA Forest Service and state wildlife agency or Heritage program, determines (1) the sensitive wildlife area or site is not active, or (2) the proposed use is not within the buffer zones and would not compromise the integrity of the wildlife/plant area or site, and (3) the proposed use is within the buffer and could be easily moved out of the buffer by simply modifying the project proposal (site plan modifications). If the project applicant accepts these recommendations, the local government shall incorporate them into its development review order and the wildlife/plant protection process may conclude. 

F. If the above measures fail to eliminate the adverse affects, the proposed project shall be prohibited, 

unless the project applicant can meet the Practicable Alternative Test and prepare a mitigation plan to offset the adverse effects by deliberate restoration and enhancement. 

Project as described meets guide

 Project requires the following cond

Buffers will be entered to treat invasivAlternative Test and Mitigation Plan h

Section 2.2 and Standards in Appendwildlife/plant areas and sites. 
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Appendix C-13 

Soil Productivity

A. Soil productivity shall be protected using the following guidelines: 

(1) A description or illustration showing the mitigation measures to control soil erosion and stream 

sedimentation. 

Project as described meets guide

 Project requires the following cond

(2) New developments and land uses shall control all soil movement within the area shown on the 

site plan. 

Project as described meets guide

 Project requires the following cond

(3) The soil area disturbed by new development or land uses, except for new cultivation, shall not 

exceed 15 percent of the project area. 

Project as described meets guide

 Project requires the following cond

(4) Within 1 year of project completion, 80 percent of the project area with surface disturbance 

shall be established with effective native ground cover species or other soil-stabilizing methods to prevent soil erosion until the area has 80 percent vegetative cover. 

Project as described meets guide

3.8 

 Project requires the following cond

GMA Natural Resource Policies - Applicable Findings Streams, Ponds, Lakes, and Riparian Areas

Approval Criteria for Other Review Uses in Aquatic and Riparian Areas 1. The uses identified in guideline 2 under "Review Uses," above, may be allowed only if they meet all 

of the following criteria: 

A. The proposed use is water-dependent, or is not water-dependent but has no practicable 

alternative. A local government may conclude that a practicable alternative to the proposed use 

does not exist if the "Practicable Alternative Test" in the "Wetlands" section of this chapter is satisfied, substituting the term "stream, pond, lake, or riparian area" as appropriate. 

B. The proposed use is in the public interest. In determining if a proposed use is in the public 

interest, the guidelines under "Public Interest Test" in the "Wetlands" section of this chapter shall be considered, substituting the term "stream, pond, lake, or riparian area" as appropriate. 

C. Measures have been applied to ensure that the proposed use results in minimum feasible 

impacts to water quality, natural drainage, and fish and wildlife habitat of the affected stream, pond, lake, and/or buffer zone. As a starting point, the following mitigation measures shall be considered when new uses are proposed in streams, ponds, lakes, and buffer zones: 

 Project as described meets guide Project requires the following cond

Table C-1 and Appendix 0 describes t

activities to water resource buffers. Buinvasive plants and a Practicable Altehave been prepared. The PDC of SecAppendix A mitigate impacts to water 
Final Environmental Impact Statement 

Appendix C-14 

 (1) Construction shall occur during periods when fish and wildlife are least sensitive to disturbance. In Oregon, work in streams, ponds, and lakes shall be conducted during the periods specified in Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources (Oregon Department of Fish and Wildlife 2000), unless otherwise coordinated with and approved by the Oregon Department of Fish and Wildlife. In Washington, the Washington Department of Fish and Wildlife shall evaluate specific proposals and specify periods for in -water work.  (2) All natural vegetation shall be retained to the greatest extent practicable, including aquatic 

and riparian vegetation. 

 (3) Nonstructural controls and natural processes shall be used to the greatest extent 

practicable. 

 (6) Temporary and permanent control measures shall be applied to minimize erosion and 

sedimentation when riparian areas are disturbed, including slope netting, berms and ditches, tree protection, sediment barriers, infiltration systems, and culverts. 

D. Groundwater and surface water quality will not be degraded by the proposed use. 

E. Those portions of a proposed use that are not water-dependent or that have a practicable 

alternative will be located outside of stream, pond, and lake buffer zones. 

F. The proposed use complies with all applicable federal, state, and local laws. G. Unavoidable impacts to aquatic and riparian areas will be offset through rehabilitation and 

enhancement.

Stream, Pond, and Lake Buffer Zones 1. Buffer zones shall generally be measured landward from the ordinary high watermark on a 

horizontal scale that is perpendicular to the ordinary high watermark. On the main stem of the 

Columbia River above Bonneville Dam, buffer zones shall be measured landward from the normal pool elevation of the Columbia River. The following buffer zone widths shall be required: A. Streams used by anadromous or resident fish (tributary fish habitat), special streams, 

intermittent streams that include year-round pools, and perennial streams: 100 feet. 

B. Intermittent streams, provided they are not used by anadromous or resident fish: 50 feet. 

 Project as described meets guide

treat invasive plants. 

 Project requires the following cond
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Appendix C-15 

C. Ponds and lakes: Buffer zone widths shall be based on the dominant vegetative community 

and shall use the same guidelines as in the "Wetlands Buffer Zones" section of this chapter, substituting the term "pond or lake" as appropriate. 

2. Except as otherwise allowed, buffer zones shall be retained in their natural condition. When a 

buffer zone is disturbed by a new use, it shall be replanted with native plant species. 

 Project as described meets guide Project requires the following cond

Wildlife Habitat

Approval Criteria for Review Uses Near Sensitive Wildlife Areas and Sites 1. Uses that are proposed within 1,000 feet of a sensitive wildlife area or site shall be reviewed by the 

Oregon Department of Fish and Wildlife or the Washington Department of Fish and Wildlife. The approximate locations of sensitive wildlife areas and sites are shown in the wildlife inventory. State wildlife biologists will help determine if a new use would adversely affect a sensitive wildlife area or site. 

2. The local government shall submit site plans to the Oregon Department of Fish and Wildlife or 

Washington Department of Fish and Wildlife. State wildlife biologists shall review the site plan and their field survey records. They shall (1) identify/verify the precise location of the wildlife area or site, (2) ascertain whether the wildlife area or site is active or abandoned, and (3) determine if the proposed use may compromise the integrity of the wildlife area or site or occur during the time of year when wildlife species are sensitive to disturbance, such as nesting or rearing seasons. In 

some instances, state wildlife biologists may conduct field surveys to verify the wildlife inventory and assess the potential effects of a proposed use. 

3. The following factors may be considered when site plans are reviewed: 

A. Biology of the affected wildlife species. 

B. Published guidelines regarding the protection and management of the affected wildlife species. 

The Oregon Department of Forestry has prepared technical papers that include management guidelines for osprey and great blue heron. The Washington Department of Fish and Wildlife has prepared similar guidelines for a variety of species, including the western pond turtle, the peregrine falcon, and the Larch Mountain salamander (Rodrick and Milner 1991). 

C. Physical characteristics of the subject parcel and vicinity, including topography and vegetation. 

D. Historic, current, and proposed uses in the vicinity of the sensitive wildlife area or site. 

 Project as described meets guide

within 1,000’ of sensitive wildlife a3.10 and 3.11 for a complete desService conducted analysis ratheand Wildlife. 

 Project requires the following cond
Final Environmental Impact Statement 

Appendix C-16 

 E. Existing condition of the wildlife area or site and the surrounding habitat and the useful life of  the area or site. 

4. The wildlife protection process may terminate if the local government, in consultation with the state 

wildlife agency, determines (1) the sensitive wildlife area or site is not active, or (2) the proposed 

use would not compromise the integrity of the wildlife area or site or occur during the time of year when wildlife species are sensitive to disturbance. 

5. If the local government, in consultation with the state wildlife agency, determines that the proposed 

use would have only minor effects on the wildlife area or site that could be eliminated through mitigation measures recommended by the state wildlife biologist, or by simply modifying the site plan or regulating the timing of new uses, a letter shall be sent to the project applicant that describes the effects and measures needed to eliminate them. If the project applicant accepts these recommendations, the local government shall incorporate them into its development review order and the wildlife protection process may conclude. 

6. The project applicant shall prepare a wildlife management plan if the local government, in 

consultation with the state wildlife agency, determines that the proposed use would adversely affect a sensitive wildlife area or site and the effects of the proposed use cannot be eliminated through site plan modifications or project timing. 

Wildlife Management Plans 

1. Wildlife management plans shall be prepared when a proposed use is likely to adversely affect 

a sensitive wildlife area or site. Their primary purpose is to document the special characteristics of a project site and the habitat requirements of affected wildlife species. This information provides a basis for the project applicant to redesign the proposed use in a manner that protects sensitive wildlife areas and sites, maximizes his/her development options, and mitigates temporary impacts to the wildlife area or site and/or buffer zone. 

 Project as described meets guide

3.10.2.4, effects to aquatic organwould be minimal. Per Sections 3sensitive wildlife areas or sites of minimal. Therefore no wildlife ma

 Project requires the following cond

Rare Plants Approval Criteria for Review Uses Near Sensitive Plants 1. Uses that are proposed within 1,000 feet of a sensitive plant shall be reviewed by the Oregon or 

Washington Natural Heritage Program. The approximate locations of sensitive plants are shown in the rare plant species inventory. State heritage staffs will help determine if a new use would invade 

 Project as described meets guide

within 1,000’ of a sensitive plant. description. The USDA Forest Sethan Oregon Department of Fish 

 Project requires the following cond
Site-Sp

Appendix C-17 

the buffer zone of sensitive plants. 

2. The local government shall submit site plans to the state heritage program. The state heritage 

staffs will review the site plan and their field survey records. They will identify the precise location of the affected plants and delineate a 200-foot buffer zone on the project applicant's site plan. If the field survey records of the state heritage program are inadequate, the project applicant shall hire a person with recognized expertise in botany or plant ecology to ascertain the precise location of the affected plants. 

3. The rare plant protection process may conclude if the local government, in consultation with the 

state heritage program, determines that the proposed use would be located outside of a sensitive 

plant buffer zone. 

4. New uses shall be prohibited within sensitive plant species buffer zones, except for those uses that 

are allowed outright. 

5. If a proposed use must be allowed within a sensitive plant buffer zone in accordance with the 

provisions in "Variances for Setbacks and Buffers" in Part II, Chapter 7, the project applicant shall 

prepare a protection and rehabilitation plan that complies with the guidelines in "Protection and Rehabilitation Plans" in this section. 

6. The local government shall submit a copy of all field surveys and protection and rehabilitation plans 

to the Oregon or Washington Natural Heritage Program. The state heritage program will have 20 days from the date that a field survey is mailed to submit written comments to the local government. 

 The local government shall record and address any written comments submitted by the state 

heritage program in its development review order. 

 Based on the comments from the state heritage program, the local government will make a final 

decision on whether the proposed use would be consistent with the rare plant policies and guidelines. If the final decision contradicts the comments submitted by the state heritage program, 

the local government shall justify how it reached an opposing conclusion. 

7. The local government shall submit all requests to reduce sensitive plant species buffer zones to the 

Oregon or Washington Natural Heritage Program. The state heritage program will have 20 days from the date that such a request is mailed to submit written comments to the local government. 

 The local government shall record and address any written comments submitted by the state 

heritage program in its development review order. 

 Based on the comments from the state heritage program, the local government will make a final 

decision on whether the reduced buffer zone is justified. If the final decision contradicts the 
Final Environmental Impact Statement 

Appendix C-18 

comments submitted by the state heritage program, the local government shall justify how it 

reached an opposing conclusion. 

Sensitive Plant Buffer Zones 1. A 200-foot buffer zone shall be maintained around sensitive plants. Buffer zones shall remain in an 

undisturbed, natural condition. 

2. Buffer zones may be reduced if a project applicant demonstrates that intervening topography, 

vegetation, manmade features, or natural plant habitat boundaries negate the need for a 200-foot radius. Under no circumstances shall the buffer zone be less than 25 feet. 

3. Requests to reduce buffer zones shall be considered if a professional botanist or plant ecologist 

hired by the project applicant (1) identifies the precise location of the sensitive plants, (2) describes 

the biology of the sensitive plants, and (3) demonstrates that the proposed use will not have any negative effects, either direct or indirect, on the affected plants and the surrounding habitat that is vital to their long-term survival. 

All requests shall be prepared as a written report. Published literature regarding the biology of the 

affected plants and recommendations regarding their protection and management shall be cited. The report shall include detailed maps and photographs.

 Project as described meets guide

treat invasive plants. 

 Project requires the following cond

Protection and Rehabilitation Plans 1. Protection and rehabilitation plans shall minimize and offset unavoidable impacts that result from a 

new use that occurs within a sensitive plant buffer zone as the result of a variance. All plans shall meet the following guidelines: A. Protection and rehabilitation plans shall be prepared by a professional botanist or plant 

ecologist hired by the project applicant. 

B. Construction, protection, and rehabilitation activities shall occur during the time of year when 

ground disturbance will be minimized and protection, rehabilitation, and replacement efforts will be maximized. 

C. Sensitive plants that will be destroyed shall be transplanted or replaced, to the maximum extent 

practicable. Replacement is used here to mean the establishment of a particular plant species in areas of suitable habitat not affected by new uses. Replacement may be accomplished by seeds, cuttings, or other appropriate methods. 

 Replacement shall occur as close to the original plant site as practicable. The project applicant 

shall ensure that at least 75 percent of the replacement plants survive 3 years after the date 

Project as described meets guide

Standards in Appendix A minimize anfulfill the requirements of a GMA Rare Rehabilitation Plan. 

 Project requires the following cond
Site-Sp

Appendix C-19 

they are planted. 

D. Sensitive plants and their surrounding habitat that will not be altered or destroyed shall be 

protected and maintained. Appropriate protection and maintenance techniques shall be applied, such as fencing, conservation buffers, livestock management, and noxious weed control. 

E. Habitat of a sensitive plant that will be affected by temporary uses shall be rehabilitated to a 

natural condition. 

F. Protection efforts shall be implemented before construction activities begin. Rehabilitation 

efforts shall be implemented immediately after the plants and their surrounding habitat are disturbed. 

2. Protection and rehabilitation plans shall include maps, photographs, and text. The text shall: 

A. Describe the biology of sensitive plant species that will be affected by a proposed use. 

B. Explain the techniques that will be used to protect sensitive plants and their surrounding habitat 

that will not be altered or destroyed. 

C. Describe the rehabilitation and enhancement actions that will minimize and offset the impacts 

that will result from a proposed use. 

D. Include a 3-year monitoring, maintenance, and replacement program. The project applicant 

shall prepare and submit to the local government an annual report that documents milestones, successes, problems, and contingency actions. 
Final Environmental Impact Statement 

Appendix C-20 

Recreation ResourcesPortland Women’s Forum is located about 350’ east of a treatment site in Area 22-17. Herman Creek Campground is Twin Tunnels Trail of the HRCH is adjacent to Area 22-08. Sandy River Delta (22-01), Memaloose/Rowena (22-11) an12) have user developed trails. No recreation sites are located in the GMA; GMA guidelines do not apply. SMA Recreation Resource Guidelines - Applicable Findings 1. New developments and land uses shall not displace existing recreational use. 

 Project as described meets guide

D.2., D.3., D.4., D.5., D.6., and S

 Project requires the following cond

2. Recreation resources shall be protected from adverse effects by evaluating new developments and 

land uses as proposed in the site plan. An analysis of both onsite and offsite cumulative effects shall be required 

 Project as described meets guide

D.2., D.3., D.4., D.5., D.6., and S

 Project requires the following cond

4. Mitigation measures shall be provided to preclude adverse effects on the recreation resource. 

 Project as described meets guide

D.2., D.3., D.4., D.5., D.6., and S

 Project requires the following condition 
Site-Specific Invasive Plant Treatments 

Invasive Plant Treatment within Sensitive Buffer Zones 

“Practicable” Alternative Test and Mitigation Plan 

“Practicable” Alternative Test 

As per the Management Plan Guidelines, this test is met because the proposed actions require, in 

instances where invasive plants are located within buffer zones, that the proposed treatments 

occur within the buffer zones in order to treat the invasive plants. It would not be possible to 

treat these invasive plants effectively or safely (especially, in terms of reducing adverse impacts 

to non-target flora) without entering the buffer zones. Thus, there is no other practicable 

alternative than to enter the buffer zones to achieve the proposed objectives of the site specific 

EIS for the Forest and Scenic Area. 

This project has no “practicable” alternative and thereby meets this test to enter the buffer zones. 

Mitigation Plan 

The use of “NEPA” here refers to the Site-Specific Invasive Plant Treatments EIS completed for 

the Forest and Scenic Area. 

1. Mitigation Plan shall be prepared when: 

A. The proposed development or use is within a buffer zone (wetland, pond, lakes, 

riparian areas, wildlife or plant areas and/or sites). 

B. There is no practicable alternative (see the “practicable alternative” test). 

See Practicable Alternatives Test above. 

2. In all cases, Mitigation Plans are the responsibility of the applicant and shall be prepared by 

an appropriate professional (botanist/ecologist for plant sites, a wildlife/fish biologist for 

wildlife/fish sites, and a qualified professional for water resource sites). 

Prepared by USDA Forest Service Ecologist 

3. The primary purpose of this information is to provide a basis for the project applicant to 

redesign the proposed use in a manner that protects sensitive water resources, and 

wildlife/plant areas and sites, that maximizes his/her development options, and that 

mitigates, through restoration, enhancement, and replacement measures, impacts to the 

water resources and/or wildlife/plant area or site and/or buffer zones. 

See discussion below. 

Appendix C-21 
Final Environmental Impact Statement 

4. The applicant shall submit the mitigation plan to the local government. The local 

government shall submit a copy of the mitigation plan to the Forest Service, and 

appropriate state agencies. If the final decision contradicts the comments submitted by the 

state and federal wildlife agency/heritage program, the local government shall justify how 

it reached an opposing conclusion. 

Not applicable to this project. 

5. A project applicant shall demonstrate sufficient fiscal, technical, and administrative 

competence to successfully execute a mitigation plan involving wetland creation. 

Not applicable to this project. 

6. Mitigation plans shall include maps, photographs, and text. The text shall: 

A. Describe the biology and/or function of the sensitive resources (e.g. Wildlife/plant 

species, or wetland) that will be affected by a proposed use. An ecological assessment 

of the sensitive resource to be altered or destroyed and the condition of the resource 

that will result after restoration will be required. Reference published protection and 

management guidelines. 

See Invasive Plant NEPA 

B. Describe the physical characteristics of the subject parcel, past, present, and future uses, 

and the past, present, and future potential impacts to the sensitive resources. Include the 

size, scope, configuration, or density of new uses being proposed within the buffer 

zone. 

See Invasive Plant NEPA 

C. Explain the techniques that will be used to protect the sensitive resources and their 

surrounding habitat that will not be altered or destroyed (for examples, delineation of 

core habitat of the sensitive wildlife/plant species and key components that are essential 

to maintain the long-term use and integrity of the wildlife/plant area or site). 

See Invasive Plant NEPA, and mitigation measures of 6(D) below. 

Appendix C-22 
Site-Specific Invasive Plant Treatments 

D. Show how restoration, enhancement, and replacement (creation) measures will be 

applied to ensure that the proposed use results in minimum feasible impacts to 

sensitive resources, their buffer zones, and associated habitats. 

The Invasive Plant NEPA has a large number of Project Design Criteria (PDC) 

which provide and ensure that sensitive resources shall be impacted to the 

minimum extent possible. A few examples are given below, but for a complete list 

the NEPA document should be referenced. 

1. Comply with herbicide application buffers on “live” streams, intermittent 

steams, and lakes, ponds or wetlands in the NEPA document. 

2. Where an invasive plant species is to be treated within 5-feet of a sensitive plant 

species, the invasive plant should be either manually treated or the sensitive 

plant should be covered with a barrier. 

3. Restoration would be considered for any site within the treatment area with soil 

disturbance or vegetative density low enough to allow re-infestation or 

introduction of other invasive plants... 

The above measures and those in the NEPA document will be followed and with 

the successful implementation of these measures, the disturbance to the buffer 

would be adequately mitigated. 

E. Show how the proposed restoration, enhancement, or replacement (creation) 

mitigation measures are NOT alternatives to avoidance. A proposed development/use 

must first avoid a sensitive resource, and only if this is not possible should 

restoration, enhancement, or creation be considered as mitigation. In reviewing 

mitigation plans, the local government, appropriate state agencies, and Forest Service 

shall critically examine all proposals to ensure that they are indeed last resort options. 

See Invasive Plant NEPA and 6(D) above. 

7. At a minimum, a project applicant shall provide to the local government a progress report 

every 3-years that documents milestones, successes, problems, and contingency actions. 

Photographic monitoring stations shall be established and photographs shall be used to 

monitor all mitigation progress. 

See Monitoring within the NEPA document. 

Appendix C-23 
Final Environmental Impact Statement 

8. A final monitoring report shall be submitted to the local government for review upon 

completion of the restoration, enhancement, or replacement activity. This monitoring report 

shall document successes, problems encountered, resource recovery, status of any sensitive 

wildlife/plant species and shall demonstrate the success of restoration and/or enhancement 

actions. The local government shall submit copies of the monitoring report to the Forest 

Service; who shall offer technical assistance to the local government in helping to evaluate 

the completion of the mitigation plan. In instances where restoration and enhancement 

efforts have failed, the monitoring process shall be extended until the applicant satisfies the 

restoration and enhancement guidelines. 

See Monitoring in the NEPA Document. 

9. Mitigation measures to offset impacts to resources and/or buffers shall result in no net loss 

of water quality, natural drainage, fish/wildlife/plant habitat, and water resources by 

addressing the following: 

A. Restoration and enhancement efforts shall be completed no later than one year after 

the sensitive resource or buffer zone has been altered or destroyed, or as soon 

thereafter as is practicable. 

See above mitigation measures 6(D) and other PDC in the NEPA Document. 

B. All natural vegetation within the buffer zone shall be retained to the greatest extent 

practicable. Appropriate protection and maintenance techniques shall be applied, 

such as fencing, conservation buffers, livestock management, and noxious weed 

control. Within five years, at least 75 percent of the replacement vegetation must 

survive. All plantings must be with native plant species that replicate the original 

vegetation community. 

See NEPA. There are specific PDC that relate to the restoration after Invasive 

Plant treatment. Follow-up restoration shall use native plants to the maximum 

extent possible. 

C. Habitat that will be affected by either temporary or permanent uses shall be

rehabilitated to a natural condition. Habitat shall be replicated in composition, 

structure, and function, including tree, shrub and herbaceous species, snags, poolriffle ratios, substrata, and structures, such as large woody debris and boulders. 

See NEPA. Treatment of invasive plants will be completed hand-in-hand with 

restoration to ensure habitat enhancement. The habitat will be impacted to the 

minimum extent possible when treatment is being considered. 

Appendix C-24 
Site-Specific Invasive Plant Treatments 

D. If this standard is not feasible or practical because of technical constraints, a sensitive 

resource of equal or greater benefit may be substituted, provided that no net loss of 

sensitive resource functions occurs and provided the County, in consultation with the 

appropriate State and Federal agency, determine that such substitution is justified. 

Not applicable to this project. 

E. Sensitive plants that will be destroyed shall be transplanted or replaced, to the 

maximum extent practicable. Replacement is used here to mean the establishment of 

a particular plant species in areas of suitable habitat not affected by new uses. 

Replacement may be accomplished by seeds, cuttings, or other appropriate methods. 

 Replacement shall occur as close to the original plant site as practicable. The project 

applicant shall ensure that at least 75 percent of the replacement plants survive 3 

years after the date they are planted. 

Not applicable to this project – Treatments are designed to not impact sensitive 

plants to the extent that they would be destroyed. 

F. Nonstructural controls and natural processes shall be used to the greatest extent 

practicable. 

See NEPA. Within the NEPA, treatments are designed using the least intrusive 

methods first and only if effectiveness is not achievable, will more impacting 

designs be considered. 

(1) Bridges, roads, pipeline and utility corridors, and other water crossings shall be 

minimized and should serve multiple purposes and properties. 

Not applicable to this project. 

 (2) Stream channels shall not be placed in culverts unless absolutely necessary for 

property access. Bridges are preferred for water crossings to reduce disruption 

to hydrologic and biologic functions. Culverts shall only be permitted if there 

are no practicable alternatives as demonstrated by the ‘Practical Alternative 

Test’. 

Not applicable to this project. 

 (3) Fish passage shall be protected from obstruction. 

Not applicable to this project. 

 (4) Restoration of fish passage should occur wherever possible. 

Not applicable to this project. 

Appendix C-25 
Final Environmental Impact Statement 

.(5) Show location and nature of temporary and permanent control measures that 

shall be applied to minimize erosion and sedimentation when riparian areas are 

disturbed, including slope netting, berms and ditches, tree protection, sediment 

barriers, infiltration systems, and culverts. 

Not applicable to this project. 

 (6) Groundwater and surface water quality will not be degraded by the proposed 

use. Natural hydrologic conditions shall be maintained, restored, or enhanced in 

such a manner that replicates natural conditions, including current patterns 

(circulation, velocity, volume, and normal water fluctuation), natural stream 

channel and shoreline dimensions and materials, including slope, depth, width, 

length, cross-sectional profile, and gradient. 

See NEPA and PDC. There are specific PDC related to protecting water 

quality. 

(7) Those portions of a proposed use that are not water-dependent or that have a 

practicable alternative will be located outside of stream, pond, and lake buffer 

zones. 

Not applicable to this project. 

 (8) Streambank and shoreline stability shall be maintained or restored with natural 

revegetation. 

See NEPA, PDC, and 6(D) above. 

(9) The size of restored, enhanced, and replacement (creation) wetlands shall equal 

or exceed the following ratios. The first number specifies the required acreage 

of replacement wetlands, and the second number specifies the acreage of 

wetlands altered or destroyed. 

Restoration: 2: l 

Creation: 3: l 

Enhancement: 4: l 

Not applicable to this project. 

Appendix C-26 
Site-Specific Invasive Plant Treatments 

G. Wetland creation mitigation shall be deemed complete when the wetland is selffunctioning for 5 consecutive years. Self-functioning is defined by the expected 

function of the wetland as written in the mitigation plan. The monitoring report shall 

be submitted to the local government to ensure compliance. The Forest Service, in 

consultation with appropriate state agencies, shall extend technical assistance to the 

local government to help evaluate such reports and any subsequent activities 

associated with compliance. 

Not applicable to this project. 

H. Wetland restoration/enhancement can be mitigated successfully by donating 

appropriate funds to a non-profit wetland conservancy or land trust with explicit 

instructions that those funds are to be used specifically to purchase protection 

easements or fee title protection of appropriate wetlands acreage in or adjacent to the 

Columbia River Gorge meeting the ratios given above in guideline. These 

transactions shall be explained in detail in the Mitigation Plan and shall be fully 

monitored and documented in the monitoring report. 

Not applicable to this project. 

Appendix C-27 
Final Environmental Impact Statement 

Additional GMA Guidelines 

Key guidelines not covered by the SMA guidelines are covered below and are predominantly 

related to entering protected buffer zones. 

Wetlands 

1. No Practicable Alternative Test. 

(See SMA section) 

2. Public Interest Test. 

The following factors shall be considered when determining if a proposed use is in the 

public interest: 

A. The extent of public need for the proposed use 

The treatment of invasive plants within the buffer zones of wetlands is decidedly 

within the public interest. Without treatment, the functionality of these wetlands 

could be compromised and those same invasive plants could become detrimental to 

the adjacent uplands. Invasive plant (aka noxious weed) control is widely practiced 

by most county governments. 

B. The extent and permanence of the beneficial or detrimental effects that the proposed 

use may have on the public and private uses for which the property is suited. 

Impacts from non-herbicide treatments are minimal. The long-term beneficial 

effects of treatment could last for years with prolonged increases in wetland 

function. 

C. The functions and size of the wetland that may be affected 

In this particular case, the size and function of the wetland will vary depending on 

the wetland to be treated. 

D. The economic value of the proposed use to the general area. 

The economic value could come in terms of enhanced recreation, increase in 

wetland function (flood control), or in terms of plant diversity, to mention a few. 

The value of these is highly variable and difficult to enumerate; but is generally 

given a high value by the public. 

Appendix C-28 
Site-Specific Invasive Plant Treatments 

E. The ecological value of the wetland and probable effect on public health and safety, 

fish, plants, and wildlife. 

The ecological value is extremely high for most wetlands, but generally increases 

with size and function of the wetland. In most cases, wetlands are becoming 

recognized for their very high value in maintaining viable natural resources. 

In all cases where this guideline is invoked, the values associated with the wetland, 

stream, pond or lake clearly meet all of the above guidelines and thus meet the 

Public Interest Test. 

3. Measures will be applied to ensure that the proposed use results in the minimum feasible 

alteration or destruction of the wetland’s functions, existing contour, vegetation, fish, and 

wildlife resources, and hydrology. 

The inclusion and development of the PDC and Standards in Appendix A were 

specifically developed to minimize all impacts to wetlands, native plants, fish, wildlife, 

and hydrological systems. No grading or loss of contours will occur in this project. 

4. Groundwater and surface-water quality will not be degraded by the proposed use. 

The inclusion and development of the PDC and Standards in Appendix A were 

specifically developed to protect groundwater and surface-water quality. 

5. Those portions of a proposed use that are not water-dependent or that have a practicable 

alternative will not be located in wetlands or wetlands buffer zones. 

Treatment is proposed where invasive plants occur; both within and outside of buffers. 

6. The proposed use complies with all applicable federal, state, and local laws. 

The invasive plant treatments are design to comply with all applicable federal laws. 

7. Areas that are disturbed during construction of the proposed use will be rehabilitated to 

the maximum extent practicable. 

Restoration with native species is required on treated areas. 

8. Unavoidable impacts to wetlands will be offset through the deliberate restoration, 

creation, or enhancement of wetlands. Wetlands restoration, creation, and enhancement 

are not alternatives to the guidelines listed above; they shall be used only as a last resort 

to offset unavoidable wetlands impacts. 

A Wetlands Compensation Plan is not necessary because effects to wetlands are 

minimal. 

Appendix C-29 
Final Environmental Impact Statement 

Streams, Ponds, Lakes and Riparian Areas 

1. No Practicable Alternative Test. 

See “Wetlands” above. 

2. Public Interest Test. 

See “Wetlands” above. 

3. Measures have been applied to ensure that the proposed use results in minimum feasible 

impacts to water quality, natural drainage, and fish and wildlife habitat of the affected 

stream, pond, lake, and/or buffer zone. 

As a starting point, the following mitigation measures shall be considered when new uses 

are proposed in streams, ponds, lakes, and buffer zones: 

(1) Construction shall occur during periods when fish and wildlife are least sensitive to 

disturbance. In Oregon, work in streams, ponds, and lakes shall be conducted 

during the periods specified in Oregon Guidelines for Timing of In-Water Work to 

Protect Fish and Wildlife Resources (Oregon Department of Fish and Wildlife 

2000), unless otherwise coordinated with and approved by the Oregon Department 

of Fish and Wildlife. In Washington, the Washington Department of Fish and 

Wildlife shall evaluate specific proposals and specify periods for in water work. 

No in-water work is proposed in this project. 

(2) All natural vegetation shall be retained to the greatest extent practicable, including 

aquatic and riparian vegetation. 

The PDC and Standards in Appendix A require native vegetation to be retained 

to the greatest extent practicable. 

(3) Nonstructural controls and natural processes shall be used to the greatest extent 

practicable. 

No structural controls are proposed. 

(4) Bridges, roads, pipeline and utility corridors, and other water crossings shall be 

minimized and should serve multiple purposes and properties. 

Not applicable to this project. 

Appendix C-30 
Site-Specific Invasive Plant Treatments 

(5) Stream channels shall not be placed in culverts unless absolutely necessary for 

property access. Bridges are preferred for water crossings to reduce disruption to 

streams, ponds, lakes, and their banks. When culverts are necessary, oversized 

culverts with open bottoms that maintain the channel's width and grade should be 

used. 

Not applicable to this project. 

(6) Temporary and permanent control measures shall be applied to minimize erosion 

and sedimentation when riparian areas are disturbed, including slope netting, berms 

and ditches, tree protection, sediment barriers, infiltration systems, and culverts. 

Bare soils, which do not vegetate naturally, will be seeded with native plants. 

4. Groundwater and surface water quality will not be degraded by the proposed use. 

The inclusion and development of the PDC and Standards in Appendix A were 

specifically developed to protect groundwater and surface-water quality. 

5. Those portions of a proposed use that are not water-dependent or that have a practicable 

alternative will be located outside of stream, pond, and lake buffer zones. 

Treatment is proposed where invasive plants occur; both within and outside of buffers. 

6. The proposed use complies with all applicable federal, state, and local laws. 

The invasive plant treatments are designed to comply with all applicable federal laws. 

7. Unavoidable impacts to aquatic and riparian areas will be offset through rehabilitation 

and enhancement. 

A Rehabilitation and Enhancement Plan is not necessary because effects to water 

resources are minimal. 

Wildlife Habitat 

All GMA guidelines are covered under the SMA guidelines. The development and design of 

the PDC and Standards in Appendix A were completed to ensure that this project would not 

adversely affect, as defined by the Management Plan, any sensitive wildlife areas and sites. 

Thus a ‘Wildlife Management Plan’, as described in the GMA Guidelines is not required. 

Appendix C-31 
Final Environmental Impact Statement 

Rare Plants 

Again the PDC and Standards in Appendix A were specifically designed to ensure that this 

project would not adversely affect any sensitive flora and, thus, no ‘Protection and 

Rehabilitation Plan’, as defined in the Management Plan, is required. 

Natural Areas 

There are no lands under USDA Forest Service control within the Scenic Area that are 

designated “Agricultural—Special”, as defined by the Management Plan. 

/s/ Robin Dobson 9/15/2006 

Prepared by: 

Robin Dobson 

Ecologist, Columbia River Gorge National Scenic Area 

Appendix C-32 
APPENDIX D 

Prevention of Invasive Plants – A Strategic 

and Collaborative Effort 
 
Site-Specific Invasive Plant Treatments 

Appendix D-1 

APPENDIX D: Prevention of Invasive Plants – A Strategic and 

Collaborative Effort 

Prevention is the cornerstone of an effective invasive species program. 

The following are actions that are currently in place to prevent the invasion and/or the spread of 

invasive plants on the Mt. Hood National Forest and the Columbia Gorge National Scenic Area 

in Oregon. Many of these actions are fully in place and operational, while others are still in 

transition as materials and/or procedures are finalized (e.g., some information/education 

materials are still in the development phase). Additional prevention measures are also being 

“invented” as we work collaboratively with partners and interested publics. As such, prevention 

is a work in progress and requires continual updates and new considerations. 

• Collaborate with federal, state, county, and local agencies, Tribal governments, 

communities, public organizations and interested publics to develop and refine strategies 

for prevention and treatment across multiple ownership boundaries 

• In partnership with others, develop and distribute informational materials at key locations 

(e.g., campgrounds, picnic areas, parking lot/staging areas, trailheads, boat launches, 

Visitor Centers, and District Offices). Information should include “tips” for recreation 

users on ways to minimize the risk of introducing or spreading invasive plants, and a 

contact name or agency. 

 

• Train key Forest Service personnel how to recognize species of concern and how to take 

measures to reduce the risk of weed establishment and spread on national forest lands 

• Conduct a risk assessment for invasive plants in NEPA planning as well as routine 

maintenance activities, documenting occurrence where it exists and incorporating 

appropriate prevention and/or treatment measures for the activity proposed 

• Require appropriate contracts and permits to specify the cleaning of ‘off-road’ equipment 

prior to the arrival at a job site, and/or before leaving a weed infested area to reduce the 

risk of carrying and spreading weeds and seeds of invasive plants (e.g., timber sales, road 

decommissioning or maintenance, natural resource restoration activities, etc.) 

• Where feasible and available, utilize weed-free plant materials (such as weed-free straw, 

etc.) for re-vegetation activities, erosion control, and/or wildlife forage enhancement. 

Communicate with state and county agencies and plant growers regarding availability of 

weed-free plant material sources 

• Ensure that areas of soil disturbance re-vegetate promptly to minimize the risk of 

invasion of undesirable plants 
Final Environmental Impact Statement 

Appendix D-2 

• Inspect stockpiled gravel or rock, and on-Forest rock quarries and borrow pits for 

invasive plants, and if species of concern are present, treat area before material from the 

area is used on the Forest 

• In range administration annual operating plans, specify appropriate actions and practices 

to minimize the invasion and/or spread of invasive plants 
Site-Specific Invasive Plant Treatments 

Appendix D-3 

One example of information distributed: 

INVASIVE NONNATIVE PLANTS ARE A SERIOUS THREAT 

TO HEALTHY FOREST ECOSYSTEMS 

 

SIMPLE THINGS YOU CAN DO TO HELP 

STOP THE SPREAD OF INVASIVE NONNATIVE PLANTS 

(WEEDS) 

1. LEARN TO IDENTIFY WEEDS. One Source: 

http://egov.oregon.gov/ODA/PLANT/weed_weedlistcommon.shtml 

 

2. CONTROL WEEDS WHERE YOU LIVE. 

3. IF YOU’VE BEEN WALKING IN AN AREA WITH WEEDS, CHECK 

YOUR SOCKS, SHOES, AND PANTS FOR SEEDS AND DISPOSE OF 

THEM IN THE GARBAGE BEFORE LEAVING THE SITE AND BEFORE 

ENTERING THE NATIONAL FOREST. 

4. KEEP VEHICLES AND EQUIPMENT OUT OF WEED PATCHES. 

5. IF YOU DID DRIVE THROUGH WEEDS, WASH YOUR VEHICLE’S 

UNDERCARRIAGE, RADIATOR, TIRES, AND WHEELS, BEFORE 

ENTERING THE NATIONAL FOREST. 

6. KEEP YOUR PETS AND PACK ANIMALS OUT OF WEED PATCHES. 

7. FEED PACK ANIMALS PROCESSED FOOD PELLETS BEFORE AND 

DURING BACKCOUNTRY TRIPS. 

8. CLEAN YOUR BOAT, MOTOR, TRAILER, TACKLE, AND GEAR 

BEFORE LEAVING A LAKE OR RIVER INFESTED WITH AQUATIC 

WEEDS. 

9. BE AN INFORMED GARDENER AND DON’T BUY PLANTS THAT MAY 

MOVE OFF YOUR PROPERTY. 
 
APPENDIX E 

Pesticide – Use Proposal (FW-2100-2) 
 
Site-Specific Invasive Plant Treatments 

Appendix E-1 

APPENDIX E: Pesticide – Use Proposal Form (FS-2100-2) 

 DEPARTMENT/ 

 AGENCY

CONTACT/PHONE NO.

 

 

REGION FOREST

DATE 

SUBMITTED

PESTICIDE - USE PROPOSAL

(Reference FSM 2150)

 

1) OBJECTIVE

 a) Project No.

 b) Specific Target Pest

 c) Purpose

 

 

 

 

2) PESTICIDE

 a) Common Name

 b) Formulation

 c) % AI,AE,or lb / Gal.

 d) Registration No.

 

 

 

 

 

3) 

 a) Form Applied

 b) Use Strength (%) or Dilution Rate

 c) Diluent

 

 

 

4)

 lbs. AI Per Acre or Other Rate 

5) APPLICATION

 a) Method

 b) Equipment

 

 

 

6) 

 a) Acres or Other Unit to be Treated

 b) Number of Applications

 c) Number of Sites

 d) Specific Description of Sites

 

 

 

 

7)

 a) Month(s) of Year

 b) States 

 

8) SENSITIVE AREAS

 a) Areas to be Avoided

 b) Areas to be Treated with Caution

 

 

 
Final Environmental Impact Statement 

Appendix E-2 

9) REMARKS

 a) Precautions to be Taken

 b) Use of Trained / Certified

 Personnel

 c) State and Local 

 Coordination

 d) Other Pesticides Being

 Applied to Same Site

 e) Monitoring

 f) Other

 

 

 

 

 

 

 

 

 

Approval (Signatures of Approving Official) Date 

(mm/dd/yy): 

 

 
Site-Specific Invasive Plant Treatments 

Appendix E-3 

Instructions for Completing Form FS-2100-2, Pesticide Use Proposal 

HEADING - Provide requested information.

OBJECTIVE (Block 1)

a) Project Number - Assign in accordance with field IPMWG procedures.

b) Specific Target Pest - Identify the target pest by common and scientific name. Identify life cycle stage for animals 

 or stage of growth for plants (e.g. emergent or pre-emergent, seedling, sapling, etc.)

c. Purpose - State exact purpose of pesticide use.

PESTICIDE (Block 2)

a) Common name of active ingredient(s) as indicated on the pesticide label. When a combination of pesticides are to 

 used on a single pest, use the word "AND" in listing the pesticide names. When alternate materials are proposed, 

 use the word "OR" in listing the names.

b) Indicate product formulation (i.e., amine, ester, emulsifiable concentrate, granules, solution, etc.).

c) Percentage active ingredient, acid equivalent, or pounds per gallon (as indicated on the pesticide label).

d) List the EPA registration number from the pesticide label.

PESTICIDE - continued (Block 3)

a) Form Applied - e.g., dust, granule, emulsion, bait, solution, gas, etc.

b) Use strength or Dilution Rate - List the quantity of concentrate mixed with the quantity of diluent or indicate the 

 percentage strength of the formulation.

c) Diluent - Identify the pesticide carrier, i.e., water, oil, talc, kerosene, etc.

PESTICIDE - continued - (Block 4)

Pounds of Active Ingredient Per Acre or Other Rate - State pounds of active ingredient per acre to be applied, unless 

some other unit is indicated. If reporting in acreage is not appropriate, indicate units used. Indoor applications of 

residual sprays may be expressed as percent of actual ingredient in the prepared spray in gallons per M (1,000) 

square feet. Point of runoff, which may appear on a label is generally considered to be 1 gallon per 1,ooo square feet 

on most indoor surfaces. If dusts are used instead of sprays, express as ounces or pounds of prepared dust per M 

(1,000) square feet. Treatment of trees is listed by number of trees or is application is by hydraulic sprayer, is 

expressed as pounds or quarts of concentrate per 100 gallons of diluent - oil or water, whichever is used. If the 

pesticide for trees or brush is applied by air or mist blower, express as pounds of active ingredient per acre. 

Fumigants or inside aerosols are expressed as pounds of the fumigant or aerosol per M (1,000) cubic feet. Rodent 

baits should be listed as ounces or pounds of the prepared bait per bait station. Treatments in water may be 

expressed in parts per million (ppm) by weight or volume - specify. In spot applications, the rate of application is 

expressed in pounds or gallons per 1,000 square feet indoors or pounds per acre of active ingredient outdoors applied 

to the spot area treated.

APPLICATION - (Block 5)

Indicate as specifically as possible the method (i.e., aerial, ground, etc.) of application and the type of equipment such 

as helicopter, hand compression sprayer, mist-dust blower, hydraulic sprayer, injector, etc.

APPLICATION - (Block 6)

a) Acres or Other Unit to be Treated. State in terms of acres, unless otherwise indicated. Some projects may require 

 repeat applications. Report only the units to be treated for the first application.

b) Number of Applications - For projects that require repeat applications to the same area, indicate their estimated 

 number and their timing.

c) Number of Sites - If the reported figures are a consolidation from several locations, indicate the number of 

 locations. 

d) Specific Descriptions of Sites - Indicate the type of area and pertinent portion of the area to be treated; such as 

 ditchbank, rangeland, powerline right-of-way, tree nursery, etc. Specify if pesticide is to be applied in or around 

 water and whether it will be applied directly to water or to the shore. Where applicable, indicate the slope of the 

 treated area. For aquatic use, indicate water quality (hardness and pH) if available or applicable.
Final Environmental Impact Statement 

Appendix E-4 

APPLICATION (Block 7)

a) Month(s) of Year - State month(s) of year.

b) State(s) - Indicate State and other designation that identifies the area geographically.

SENSITIVE AREAS (Block 8)

a) Areas to be Avoided - Identify sensitive areas to be avoided. Indicate if the area is subject to inadvertent treatment 

 as a result of drift. Describe fully in "remarks" (Block 9) what protective measures are to be taken.

b) Areas to be Treated with Caution - Identify sensitive areas to be treated with special precautions to avoid 

 contamination.

REMARKS (Block 9)

Use this line for information which will be helpful to the field IPMWG in evaluating the project.

a) Precautions to be Taken - Describe specific precautions be taken to protect sensitive areas; for example, no 

 application within 100 feet of streams.

b) Use of Trained / Certified Personnel - Provide information on the status of training and/or certification of personnel 

 doing the actual work and of those supervising. Has project been reviewed by a field biologist, agronomist, 

 entomologist, or other appropriate subject matter specialist?

c) State and Local Coordination - Indicate coordination on the project at a State or local level.

d) Other Pesticides Being Applied to Same Site - Indicate what other pesticides are being or will be applied on the 

 same site within the year.

e) Monitoring - Describe any monitoring of the operation be to conducted. Indicate effectiveness of prior projects and 

 mention undesirable side effects observed.

f) Other - Indicate if the project is to be accomplished by contract.

Environmental analyses (EA's and/or EIS's) may be referred for additional information.

APPROVAL (Block 10)

a) Signature of Approving Official

b) Date of Signature 
APPENDIX F 

Site and Treatment Information 
 
Site-Specific In

APPENDIX F: Site and Treatment Information Site information and treatment information for Proposed Action Alternative, including overall treatment prescripmethods for each site. Invasive Plant Species abbreviations are defined in Table 2-3. 

Treat 

ID District Acres Site Description 

Site 

Objective 

Overall 

Treatment 

Invasive 

Plant 

Species 

Treatment 

Strategy 

Herbicide 

Methods 

Cultural 

Methods 

22-01 Scenic Area 1,573 Forested Site (not covered by other category) Active Restoration Herbicide plus Manual, Mechanical & Cultural CIAR4, CYSC4, PHAR3, RUDI2, TAVU Control, Contain, Suppress Broadcast Application, Backpack Sprayer Goat Grazing 22-05 Scenic Area 90 Manmade Opening Active Restoration Herbicide plus Manual & Mechanical CEDI3, CIAR4, PHAR3, RUDI2 Contain, Tolerate Backpack Sprayer 22-07 Scenic Area 21 Flood Plain Active Restoration 

Herbicide 

plus Manual, Mechanical & Cultural 

CIAR4, CYSC4, RUDI2 

Control Backpack Sprayer Goat Grazing 

22-08 Scenic Area 24 Quarry Active Restoration Herbicide plus Manual & Mechanical CEDI3, RUDI2 Control Backpack Sprayer 22-11 Scenic Area 110 Forested Site (not covered by other category) Active Restoration Herbicide plus Manual & Mechanical CEDI3, CHJU, CYOF Eradicate, Control Backpack Sprayer 22-12 Scenic Area 82 Forested Site (not covered by other category) Passive Restoration Herbicide plus Manual CEDI3 Control Backpack Sprayer 22-17 Scenic Area 139 Manmade Opening Passive Restoration Herbicide plus Mechanical RUDI2 Control Broadcast Application, Backpack Sprayer 

61-002 

Barlow Ranger District 

134.90 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

Appendix F-1
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

61-003 

Barlow Ranger District 

55.00 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-005 

Barlow Ranger District 

72.20 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-006 

Barlow Ranger District 

92.70 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-007 

Barlow Ranger District 

5.40 Quarry Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

61-009 

Barlow Ranger District 

43.20 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-017 

Barlow Ranger District 

96.50 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-018 

Barlow Ranger District 

48.20 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-019 

Barlow Ranger District 

264.70 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-020 

Barlow Ranger District 

0.50 Quarry Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

Appendix F-2 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

61-021 

Barlow Ranger District 

46.30 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-022 

Barlow Ranger District 

11.30 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical LIVU2 Eradicate Broadcast Application, Backpack Sprayer 

61-023 

Barlow Ranger District 

10.90 Quarry Active Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-024 

Barlow Ranger District 

30.10 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-025 

Barlow Ranger District 

54.10 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-026 

Barlow Ranger District 

34.70 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-027 

Barlow Ranger District 

26.80 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-028 

Barlow Ranger District 

51.60 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-029 

Barlow Ranger District 

40.20 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

Appendix F-3
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

61-030 

Barlow Ranger District 

6.00 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical SEJA Eradicate Broadcast Application, Backpack Sprayer 

61-034 

Barlow Ranger District 

58.50 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-036 

Barlow Ranger District 

25.80 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-039 

Barlow Ranger District 

75.90 Road & Adjacent Plantation Active Restoration Herbicide plus Manual & Mechanical CYOF, CYSC4, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

61-040 

Barlow Ranger District 

10.40 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CYOF Control Broadcast Application, Backpack Sprayer 

61-041 

Barlow Ranger District 

59.20 Utility corridor Active Restoration Herbicide plus Manual & Mechanical CYOF, CYSC4, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

61-042 

Barlow Ranger District 

52.10 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-043 

Barlow Ranger District 

15.70 Road & Adjacent Plantation Active Restoration Herbicide plus Manual SEJA Eradicate Backpack Sprayer 

61-044 

Barlow Ranger District 

20.20 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

Appendix F-4 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

61-045 

Barlow Ranger District 

33.20 Administrative Site Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-046 

Barlow Ranger District 

2.90 Plantation Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-047 

Barlow Ranger District 

1.50 Corral Active Restoration Herbicide plus Manual CEDI3, CYOF Control Backpack Sprayer 

61-048 

Barlow Ranger District 

38.80 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-049 

Barlow Ranger District 

19.60 Road & Adjacent Plantation Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-050 

Barlow Ranger District 

111.80 Harvest Unit Active Restoration Herbicide plus Manual CEDI3, CYOF Control Backpack Sprayer 

61-051 

Barlow Ranger District 

0.40 Landing Passive Restoration Herbicide plus Manual CEDI3, CYOF Control 

Broadcast Application, 

Backpack Sprayer 

61-053 

Barlow Ranger District 

3.70 Plantation Passive Restoration Herbicide plus Manual CEDI3, CYOF Control Backpack Sprayer 

61-055 

Barlow Ranger District 

6.90 Road & Adjacent Plantation Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-057 

Barlow Ranger District 

0.60 Administrative Site Active Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

Appendix F-5
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

61-058 

Barlow Ranger District 

9.90 Plantation Passive Restoration Herbicide plus Manual CEDI3, CYOF Control Backpack Sprayer 

61-059 

Barlow Ranger District 

22.80 Plantation Passive Restoration Herbicide plus Manual CEDI3, CYOF Control Backpack Sprayer 

61-062 

Barlow Ranger District 

3.80 Plantation Passive Restoration Herbicide plus Manual CEDI3, CYOF Control Backpack Sprayer 

61-064 

Barlow Ranger District 

0.40 Manmade Opening Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-065 

Barlow Ranger District 

18.90 Plantation Passive Restoration Herbicide plus Manual CEDI3, CYOF Control 

Broadcast Application, 

Backpack Sprayer 

61-066 

Barlow Ranger District 

8.40 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-071 

Barlow Ranger District 

40.80 Plantation Active Restoration Herbicide plus Manual CYOF, CYSC4, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

61-073 

Barlow Ranger District 

31.10 Campground Active Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-074 

Barlow Ranger District 

45.70 Plantation Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-075 

Barlow Ranger District 

12.50 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

Appendix F-6 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

61-076 

Barlow Ranger District 

15.40 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-077 

Barlow Ranger District 

44.80 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-078 

Barlow Ranger District 

22.40 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-079 

Barlow Ranger District 

37.20 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-080 

Barlow Ranger District 

18.00 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-081 

Barlow Ranger District 

3.50 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-082 

Barlow Ranger District 

0.30 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-083 

Barlow Ranger District 

19.00 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-084 

Barlow Ranger District 

32.40 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3 Control Broadcast Application, Backpack Sprayer 

Appendix F-7
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

61-085 

Barlow Ranger District 

15.90 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-086 

Barlow Ranger District 

66.40 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-087 

Barlow Ranger District 

30.20 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-088 

Barlow Ranger District 

59.70 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-089 

Barlow Ranger District 

88.60 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

61-090 

Barlow Ranger District 

0.50 Plantation Active Restoration Herbicide plus Manual SEJA Eradicate Backpack Sprayer 

61-091 

Barlow Ranger District 

3.70 Quarry Active Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

61-092 

Barlow Ranger District 

6.00 Plantation Passive Restoration Herbicide plus Manual CEDI3, CYOF Control Backpack Sprayer 

61-093 

Barlow Ranger District 

19.10 Utility corridor Active Restoration Herbicide plus Manual & Mechanical CEDI3, CYOF Control Broadcast Application, Backpack Sprayer 

61-095 

Barlow Ranger District 

104.30 Road Prism Passive Restoration Herbicide plus Manual & Mechanical SEJA Control Broadcast Application, Backpack Sprayer 

Appendix F-8 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

65-001 

Clackamas River Ranger District 

33.80 Road & Adjacent Streamside Passive Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3 Control Broadcast Application, Backpack Sprayer 

65-002 

Clackamas River Ranger District 

61.60 Road Prism Active Restoration Herbicide plus Manual & Mechanical HIAU, HIPR Eradicate Broadcast Application, Backpack Sprayer 

65-003 

Clackamas River Ranger District 

64.90 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3 Control Broadcast Application, Backpack Sprayer 

65-005 

Clackamas River Ranger District 

0.10 Road Prism Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

65-006 

Clackamas River Ranger District 

0.20 Road Prism Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

65-007 

Clackamas River Ranger District 

3.40 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-008 

Clackamas River Ranger District 

0.20 Road Prism Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

65-009 

Clackamas River Ranger District 

1.00 Road Prism Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

65-010 

Clackamas River Ranger District 

13.00 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

Appendix F-9
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

65-011 

Clackamas River Ranger District 

1.10 Hiking Trail Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

65-012 

Clackamas River Ranger District 

12.60 Road - Closed or Decommissioned Active Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3 Control Broadcast Application, Backpack Sprayer 

65-013 

Clackamas River Ranger District 

48.40 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3, HIPR Control Broadcast Application, Backpack Sprayer 

65-014 

Clackamas River Ranger District 

4.50 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-015 

Clackamas River Ranger District 

18.70 Road Prism Active Restoration Herbicide PHAR3 Control 

Broadcast Application, 

Backpack Sprayer 

65-016 

Clackamas River Ranger District 

4.00 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical LIVU2 Eradicate Broadcast Application, Backpack Sprayer 

65-017 

Clackamas River Ranger District 

4.10 Meadow Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-018 

Clackamas River Ranger District 

1.10 Road Prism Passive Restoration Manual & Mechanical HEHE Control 

65-019 

Clackamas River Ranger District 

5.00 Plantation Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

Appendix F-10 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

65-020 

Clackamas River Ranger District 

422.90 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3, HEHE Control Broadcast Application, Backpack Sprayer 

65-021 

Clackamas River Ranger District 

3.20 Road Prism Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

65-022 

Clackamas River Ranger District 

5.20 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-023 

Clackamas River Ranger District 

416.40 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3 Control Broadcast Application, Backpack Sprayer 

65-024 

Clackamas River Ranger District 

4.60 Road Prism Active Restoration Herbicide plus Manual & Mechanical CYSC4 Eradicate Broadcast Application, Backpack Sprayer 

65-025 

Clackamas River Ranger District 

2.80 Road - Closed or Decommissioned Active Restoration Herbicide plus Manual & Mechanical CYSC4 Control Broadcast Application, Backpack Sprayer 

65-026 

Clackamas River Ranger District 

4.70 Road - Closed or Decommissioned Active Restoration Herbicide plus Manual CIAR4 Eradicate Backpack Sprayer 

65-027 

Clackamas River Ranger District 

0.70 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual CIAR4 Eradicate Backpack Sprayer 

65-028 

Clackamas River Ranger District 

0.80 Road Prism Active Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

Appendix F-11
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

65-029 

Clackamas River Ranger District 

11.60 Meadow Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-030 

Clackamas River Ranger District 

11.40 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-031 

Clackamas River Ranger District 

14.30 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-032 

Clackamas River Ranger District 

2.70 Road Prism Active Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-033 

Clackamas River Ranger District 

9.60 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-034 

Clackamas River Ranger District 

5.20 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

65-035 

Clackamas River Ranger District 

5.30 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-036 

Clackamas River Ranger District 

3.60 Lake Active Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3 Control Broadcast Application, Backpack Sprayer 

65-037 

Clackamas River Ranger District 

0.40 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEBI2, CEDI3 Control Broadcast Application, Backpack Sprayer 

Appendix F-12 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

65-038 

Clackamas River Ranger District 

1.10 Road Prism Active Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

65-039 

Clackamas River Ranger District 

0.30 Meadow Active Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

65-040 

Clackamas River Ranger District 

1.70 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

65-041 

Clackamas River Ranger District 

4.20 Administrative Site Active Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

65-042 

Clackamas River Ranger District 

9.60 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

65-043 

Clackamas River Ranger District 

18.50 Lake Active Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

65-044 

Clackamas River Ranger District 

23.00 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

65-045 

Clackamas River Ranger District 

0.10 Administrative Site Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

65-046 

Clackamas River Ranger District 

8.30 Road Prism Active Restoration Herbicide plus Manual & Mechanical HIVU Eradicate Broadcast Application, Backpack Sprayer 

Appendix F-13
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

66-001 

Hood River Ranger District 

20.80 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical HIAU Eradicate Broadcast Application, Backpack Sprayer 

66-003 

Hood River Ranger District 

42.80 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical HIAU Eradicate Backpack Sprayer 

66-004 

Hood River Ranger District 

18.90 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical HIAU Eradicate Backpack Sprayer 

66-005 

Hood River Ranger District 

43.70 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical HIAU Eradicate Backpack Sprayer 

66-006 

Hood River Ranger District 

58.60 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical HIAU Eradicate Backpack Sprayer 

66-007 

Hood River Ranger District 

449.10 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical HIAU Eradicate Broadcast Application, Backpack Sprayer 

66-008 

Hood River Ranger District 

551.60 Utility corridor Active Restoration Herbicide plus Manual & Mechanical CEDI3, CYSC4, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-009 

Hood River Ranger District 

9.30 Quarry Passive Restoration Herbicide plus Manual & Mechanical CEPR2 Control Broadcast Application, Backpack Sprayer 

66-010 

Hood River Ranger District 

10.00 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

Appendix F-14 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

66-011 

Hood River Ranger District 

3.00 Road - Closed or Decommissioned Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

66-012 

Hood River Ranger District 

0.70 Quarry Active Restoration Herbicide plus Manual & Mechanical CEPR2 Control Broadcast Application, Backpack Sprayer 

66-013 

Hood River Ranger District 

10.80 Quarry Active Restoration Herbicide plus Manual & Mechanical CEPR2 Eradicate Broadcast Application, Backpack Sprayer 

66-016 

Hood River Ranger District 

78.80 Utility corridor Active Restoration Herbicide plus Manual & Mechanical CEBI2, HIAU, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-017 

Hood River Ranger District 

66.60 Quarry Active Restoration Herbicide plus Manual & Mechanical CEBI2, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-018 

Hood River Ranger District 

51.20 Quarry Active Restoration Herbicide plus Manual & Mechanical CEPR2, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-020 

Hood River Ranger District 

1014.30 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical SEJA Control Broadcast Application, Backpack Sprayer 

66-023 

Hood River Ranger District 

355.70

Major Resort/Permit Area 

Active Restoration 

Herbicide 

plus Manual & Mechanical 

CEDI3, CEPR2, SEJA 

Eradicate, Control 

Broadcast Application, Backpack Sprayer 

66-025 

Hood River Ranger District 

1.60 Quarry Active Restoration Herbicide plus Manual & Mechanical CEPR2 Eradicate Broadcast Application, Backpack Sprayer 

Appendix F-15
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

66-026 

Hood River Ranger District 

0.10 Quarry Active Restoration Herbicide plus Manual & Mechanical CEBI2 Eradicate Broadcast Application, Backpack Sprayer 

66-027 

Hood River Ranger District 

4.00 Quarry Passive Restoration Herbicide plus Manual CEDI3 Control Backpack Sprayer 

66-028 

Hood River Ranger District 

0.80 Quarry Active Restoration Herbicide plus Manual & Mechanical CEPR2 Eradicate Broadcast Application, Backpack Sprayer 

66-029 Hood River 0.70 Major Resort/Permit Area Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 66-030 

Hood River Ranger District 

0.30 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CEPR2, CYOF, HYPE, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-033 

Hood River Ranger District 

17.50 Campground Active Restoration Herbicide plus Manual CEDI3 Control Backpack Sprayer 

66-035 

Hood River Ranger District 

6.90 

Major Resort/Permit Area 

Passive Restoration 

Herbicide 

plus Manual & Mechanical 

CEDI3 Control 

Broadcast Application, 

Backpack Sprayer 

66-037 

Hood River Ranger District 

9.60 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual CEDI3 Control Backpack Sprayer 

66-038 

Hood River Ranger District 

261.50 Quarry Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

Appendix F-16 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

66-039 

Hood River Ranger District 

3.50 Quarry Active Restoration Herbicide plus Manual & Mechanical CEBI2, SEJA Eradicate Broadcast Application, Backpack Sprayer 

66-040 

Hood River Ranger District 

1.10 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

66-041 

Hood River Ranger District 

1.00 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Mechanical LIVU2 Eradicate Backpack Sprayer 

66-042 

Hood River Ranger District 

2.80 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

66-043 

Hood River Ranger District 

1.40 Road & Adjacent Plantation Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

66-044 

Hood River Ranger District 

0.40 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

66-046 

Hood River Ranger District 

1.80 Road & Adjacent Plantation Active Restoration Herbicide plus Manual & Mechanical CYSC4 Eradicate Backpack Sprayer 

66-047 

Hood River Ranger District 

7.10 Road & Adjacent Plantation Active Restoration Herbicide plus Manual & Mechanical CESO3 Eradicate Broadcast Application, Backpack Sprayer 

66-048 

Hood River Ranger District 

3.60 Quarry Active Restoration Herbicide plus Manual & Mechanical CEBI2 Eradicate Broadcast Application, Backpack Sprayer 

Appendix F-17
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

66-049 

Hood River Ranger District 

3.70 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CEBI2 Eradicate Broadcast Application, Backpack Sprayer 

66-051 

Hood River Ranger District 

5.70 Quarry Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

66-052 

Hood River Ranger District 

8.80 Quarry Active Restoration Herbicide plus Manual & Mechanical CEDI3 Eradicate Broadcast Application, Backpack Sprayer 

66-053 

Hood River Ranger District 

4.20 Road & Adjacent Plantation Active Restoration Herbicide plus Manual & Mechanical CEPR2, CYOF Eradicate Broadcast Application, Backpack Sprayer 

66-055 

Hood River Ranger District 

41.20 Lake Active Restoration Herbicide plus Manual & Mechanical CEDI3, LIVU2 Eradicate, Control Broadcast Application, Backpack Sprayer 

66-057 

Hood River Ranger District 

80.30 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical SEJA Control Broadcast Application, Backpack Sprayer 

66-058 

Hood River Ranger District 

14.90 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical SEJA Control Broadcast Application, Backpack Sprayer 

66-059 

Hood River Ranger District 

39.70 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical LIVU2, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-060 

Hood River Ranger District 

132.20 Multi-use Trail Passive Restoration Herbicide plus Manual & Mechanical CEBI2, SEJA Control Broadcast Application, Backpack Sprayer 

Appendix F-18 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

66-062 

Hood River Ranger District 

151.90 Quarry Active Restoration Herbicide plus Manual & Mechanical CEDI3, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-063 

Hood River Ranger District 

631.40 Multi-use Trail Active Restoration Herbicide plus Manual & Mechanical CEBI2, CEPR2, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-067 

Hood River Ranger District 

133.60 Multi-use Trail Active Restoration Herbicide plus Manual & Mechanical CEBI2, CYSC4, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-069 

Hood River Ranger District 

50.50 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical SEJA Control Broadcast Application, Backpack Sprayer 

66-071 

Hood River Ranger District 

64.70 Multi-use Trail Active Restoration Herbicide plus Manual & Mechanical CEBI2, CYSC4, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-074 

Hood River Ranger District 

109.10 Road Prism Active Restoration Herbicide plus Manual & Mechanical CEDI3, CEPR2, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-081 

Hood River Ranger District 

22.20 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Mechanical LIVU2 Eradicate Broadcast Application, Backpack Sprayer 

66-082 

Hood River Ranger District 

93.10 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Mechanical LIVU2 Eradicate Broadcast Application, Backpack Sprayer 

66-083 

Hood River Ranger District 

27.70 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Mechanical LIVU2 Eradicate Broadcast Application, Backpack Sprayer 

Appendix F-19
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

66-084 

Hood River Ranger District 

73.20 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Mechanical LIVU2 Eradicate Broadcast Application, Backpack Sprayer 

66-085 

Hood River Ranger District 

148.10 Pullout Area Along a Road Active Restoration Herbicide plus Manual & Mechanical CEDI3, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-086 

Hood River Ranger District 

296.40 Road & Adjacent Plantation Passive Restoration Herbicide plus Manual & Mechanical CEDI3, SEJA Control Broadcast Application, Backpack Sprayer 

66-087 

Hood River Ranger District 

76.80 Natural Opening Active Restoration Herbicide plus Manual & Mechanical CEDI3, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-089 

Hood River Ranger District 

154.40 Utility corridor Active Restoration Herbicide plus Manual & Mechanical CEDI3, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

66-091 

Hood River Ranger District 

120.20 Campground Active Restoration Herbicide plus Manual & Mechanical CEDI3, SEJA Eradicate, Control Broadcast Application, Backpack Sprayer 

69-001 

Hood River Ranger District 

7.50 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEBI2 Control Broadcast Application, Backpack Sprayer 

69-002 

Zigzag Ranger District 

0.10 Road & Adjacent Forest Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

69-003 

Zigzag Ranger District 

44.90 Recreational Residences Active Restoration Herbicide plus Manual & Mechanical HIVU Eradicate Broadcast Application, Backpack Sprayer 

Appendix F-20 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Invasive 

Overall 

Treatment 

Plant Treatment Herbicide Cultural 

Species Strategy Methods Methods 

69-004 

Zigzag Ranger District 

24.10 Road & Adjacent Disturbed Area Passive Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

69-005 

Zigzag Ranger District 

42.70 Recreational Residences Passive Restoration Manual & Mechanical CEBI2, CEDI3, HIVU Control, Suppress 

69-006 

Zigzag Ranger District 

0.10 Recreational Residences Active Restoration Herbicide plus Manual & Mechanical CEPR2, HIPR Eradicate, Control Broadcast Application, Backpack Sprayer 

69-007 

Zigzag Ranger District 

0.50 Road & Adjacent Disturbed Area Passive Restoration Manual & Mechanical CEBI2, HIVU Control, Suppress 

69-008 

Zigzag Ranger District 

1067.80 Recreational Residences Active Restoration Herbicide plus Manual & Mechanical 

CEBI2, CEPR2, CYSC4, HIAU, HIPR, HIVU, RUDI2 

Eradicate, Control 

Broadcast Application, Backpack Sprayer 

69-010 

Zigzag Ranger District 

0.10 Recreational Residences Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

69-011 

Zigzag Ranger District 

0.10 Quarry Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

69-012 

Zigzag Ranger District 

0.20 Road & Adjacent Disturbed Area Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

69-013 

Zigzag Ranger District 

0.10 Utility corridor Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

Appendix F-21
Final Environmental Impact Statement 

Treat 

ID District Acres Site Description 

Site 

Objective 

Overall 

Treatment 

Invasive 

Plant 

Species 

Treatment 

Strategy 

Herbicide 

Methods 

Cultural 

Methods 

69-014 

Zigzag Ranger District 

0.10 Hiking Trail Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

69-015 

Zigzag Ranger District 

0.10 Road & Adjacent Disturbed Area Active Restoration Herbicide POCU6 Eradicate 

Stem Injection, 

Backpack Sprayer 

69-016 

Zigzag Ranger District 

444.60 Road Prism Passive Restoration Herbicide plus Manual & Mechanical CEDI3, HEHE Control Broadcast Application, Backpack Sprayer 

69-017 

Zigzag Ranger District 

0.90 Road & Adjacent Disturbed Area Passive Restoration Manual & Mechanical HEHE Control 

69-018 

Zigzag Ranger District 

1.10 Road & Adjacent Streamside Passive Restoration Manual & Mechanical HEHE Control 

69-019 

Zigzag Ranger District 

0.70 Streamside Active Restoration Manual & Mechanical HEHE Control 

69-020 

Zigzag Ranger District 

0.40 Recreational Residences Active Restoration Manual & Mechanical HEHE Control 

69-021 

Zigzag Ranger District 

1.40 Road & Adjacent Disturbed Area Passive Restoration Manual & Mechanical HEHE Control 

69-022 

Zigzag Ranger District 

0.80 Recreational Residences Active Restoration Manual & Mechanical HEHE Control 

69-023 

Zigzag Ranger District 

0.60 Streamside Active Restoration Manual & Mechanical HEHE Control 

69-024 

Zigzag Ranger District 

0.20 Road & Adjacent Disturbed Area Passive Restoration Manual & Mechanical HEHE Control 

Appendix F-22 
Site-Specific In

Treat 

ID District Acres Site Description 

Site 

Objective 

Overall 

Treatment 

Invasive 

Plant 

Species 

Treatment 

Strategy 

Herbicide 

Methods 

Cultural 

Methods 

69-025 

Zigzag Ranger District 

3.30 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CEDI3 Control Broadcast Application, Backpack Sprayer 

69-026 

Zigzag Ranger District 

1.10 Road & Adjacent Disturbed Area Active Restoration Herbicide plus Manual & Mechanical CYSC4 Eradicate Broadcast Application, Backpack Sprayer 

69-027 

Zigzag and Clackamas Ranger Districts 

216.80 Utility corridor Active Restoration Herbicide plus Manual & Mechanical CYSC4, HIAU, RUDI2 Eradicate, Control Broadcast Application, Backpack Sprayer 

69-028 

Zigzag Ranger District 

3.70 Recreational Residences Active Restoration Herbicide plus Manual & Mechanical HIAU Eradicate Backpack Sprayer 

69-029 

Zigzag Ranger District 

0.40 Road Prism Active Restoration Herbicide plus Manual & Mechanical HEHE, POCU6 Eradicate, Control Stem Injection, Backpack Sprayer 

69-030 

Zigzag Ranger District 

3.10 Recreational Residences Active Restoration Herbicide plus Manual & Mechanical HIAU Eradicate Broadcast Application, Backpack Sprayer 

Appendix F-23
 
APPENDIX G 

Common Control Measures Summary 
 
Site-Specific In

APPENDIX G: Common Control Measures Summary Common Control Measures The following table summarizes common control methods applied target invasive species found in, or in close pror Scenic Area. The table provides information about specific herbicides and other control methods that are effec

species. These prescriptions would be applied using the Project Design Criteria (PDC) in Section 2.2. These recoas the basis for all treatment methods proposed and analyzed in this EIS for both known treatment areas as well a

will be identified through the Early Detection / Rapid Response Strategy (EDRR). The table was prepared by Lin

Botanist) May 2005 and updated by David Lebo (Forest Botanist) and Robin Dobson (Scenic Area Biologist/EcoJanuary/February 2006. 

Target Species General Prescription Herbicide Options When/How to Trea

Bohemian knotweed (POBO) Japanese knotweed (POCU6) Giant knotweed (POSA4) Himalayan knotweed (POPO5) Perennials

• Herbicide treatment most effective. Use stem 

injection or foliar spray. Dead canes can be 

left. 

• Some manual removal possible for small 

infestation (1-5 plants). All plant parts should be removed. 

• Re-vegetate with desirable species if 

surrounding cover is primarily non-native. 

• Glyphosate • Imazapyr • Triclopyr 

• Stems > 3/4": Stem in

Foliar spray 

• Foliar spray for all ste

imazapyr and follow-u

• Treat June through Se• Stem injection should 

foliar spray should req

Appendix G-1 
Final Environmental Impact Statement 

Target Species General Prescription Herbicide Options When/How to Trea

Bull thistle (CIVU) Spiny plumeless thistle (CAAC) Musk thistle (CANU4) Biennial (musk thistle can be a winter annual, annual, or biennial) 

• Use manual, mechanical or herbicide control 

or a combination. 

• Any manual method that severs the root 

below the soil surface will kill these plants. Effective control requires cutting at the onset of blooming. Treatment before plants are fully bolted results in re-growth. Repeated visits at weekly intervals over the 4 to 7 week blooming period provide most effective control. 

• Timing of mowing is critical (within 2 days of 

full flowering for musk thistle). 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Biological controls may be helpful to 

suppress populations in combination with other methods. 

• Re-vegetate with desirable species. 

• Clopyralid • Picloram • Chlorsulfuron • Glyphosate • Metsulfuron methyl• Triclopyr 

• Backpack spray whene• Apply to rosettes in eit• Yearly revisits will be n

of which is dependent 

and the seed bank. 

Butter and eggs (LIVU2) Dalmation toadflax (LIGEDA)Perennials

• Hand pull or dig small populations or when 

regular volunteers are available. Plants can 

be left on site, but may reduce germination of desirable species due to mulching effect. 

• Cutting stands in spring or early summer will 

eliminate plant reproduction, but not the infestation. 

• These treatments may take up to ten years 

due to long term seed viability. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Re-vegetate with desirable species. Plant 

communities in good condition may recover 

without replanting. 

• Metsulfuron methyl• Glyphosate 

• Backpack spray. This s

scattered. 

• Apply during active gro

bloom or in late summ

growth. 

• Revisits will be necess

which is dependent on the seed bank. This coEven after three years treatments, control ma

Appendix G-2 
Site-Specific In

Target Species General Prescription Herbicide Options When/How to Trea

Canada thistle (CIAR4) Perennial sowthistle (SOAR2) Perennial 

• Herbicide treatment is most effective. • The only manual technique would be hand 

cutting of flower heads, which only 

suppresses seed production. 

• Mowing may be effective in rare cases if 

done monthly (this intensity would damage native species). 

• Covering with plastic tarp may also work for 

small infestations. 

• Re-vegetate with desirable species. 

• Clopyralid • Picloram • Glyphosate 

• Chlorsulfuron

• Broadcast spray in den

dominant plant commu

• Backpack spray whene• Apply in spring before 

flowering. 

• Or apply in fall to roset

dependent upon herbic

• Yearly revisits will be n

of which is dependent and the seed bank. 

Dyer’s woad (ISTI) Biennial or perennial 

• Hand pulling is an effective control in difficult 

terrain; otherwise, herbicide treatment is 

most effective. 

• Chlorsulfuron • Metsulfuron • Imazapic • Aquatic Label 

Glyphosate 

• If infestation is large, b

spring after emergence

• Backpack spray in spri

actively growing. 

English ivy (HEHE) Perennial 

• Manually remove infestations by removing 

vines first, than digging root mats from the 

soil. Vines must be cut at both the shoulder and ankle height, then stripped away from the tree. Work away from the tree pulling out the entire root mat for at least six feet. –Apply herbicide where manual techniques are unsuccessful. Most successful in combination with string trimming. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Triclopyr • Glyphosate 

• Larger stems: Cut and 

• Foliar spray requires c

the leaf or string trimm

• Yearly revisits will be n

of which is dependent and the seed bank. 

Appendix G-3 
Final Environmental Impact Statement 

Target Species General Prescription Herbicide Options When/How to Trea

False brome (BRSY) Perennial 

• Control can be difficult since young plants 

tend to sprout under salal, braken fern, and 

other vegetation in many types of forest habitats, including dense conifer forest with closed canopies. False brome is a prolific seed producer, but may produce only a short-lived seed bank (1 year) although further research is needed to verify. 

• Repeated mowing each season (2-3 times) 

along trails and roads before seed set occurs (in July) can effectively control the spread of existing populations. Repeated mowing each season is needed to remove all seed heads. 

• Repeated grazing can effectively control 

populations. 

• Herbicide applications are currently the most 

effective control treatment. 

• Glyphosate 

formulation without surfactant 

• Glyphosate formulation 

surprisingly, was not e

done at Oregon State Forests. Difference in rglyphosate formulationto different application application. 

• Treat before seed set o

Seed heads can remaiNovember or Decembe

Garlic mustard (ALPE4) Biennial (sometimes flowers first season) 

• Hand pulling is the simplest and most 

effective approach for managing small or 

isolated infestations. It is important to remove the entire plant since new plants can sprout from root fragments. All pulled plants should be removed from the site, placed in bags, and disposed of as seed ripening continues even after plants are pulled. Seeds can remain viable in the soil for up to five years, so it is important to pull out all garlic mustard 

plants in an area every year until the seed bank is exhausted and seedlings no longer appear. 

• Herbicide treatment is the most effective 

control for larger populations. 

• Researchers are investigating the potential 

effectiveness of biological control agents 

(weevils and leaf-feeding beetles). 

• Glyphosate • Triclopyr 

• Glyphosate can be app

year, but is most effect

spring or fall when the growing and absorbs tgrowing leaf tissue or b

• Glyphosate is a non-se

kills all plants. Applicatreduce harm to native which tend to be more year. 

Appendix G-4 
Site-Specific In

Target Species General Prescription Herbicide Options When/How to Trea

Himalayan blackberry (RUDI2) Cutleaf blackberry (RULA) Perennial (canes die off annually) 

• Use a combination of herbicides and manual 

and/or mechanical treatments. Usually 

mechanical removal of large biomass in the summer (using a mower, brush hog or brush claw), followed by manual removal of resprouting canes and roots, then herbicide treatment of new growth in the fall/winter is most effective. The massive root crown must be fully dug out at some point if using only manual/mechanical techniques. The cultural technique of grazing with goats is also a technique proving successful if goats can be confined to the blackberry area. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative amounts of herbicide to manual treatments would decline over time. 

• Re-vegetate with desirable species. 

• Triclopyr • Glyphosate 

• Cut and paint larger ca• Broadcast spray is pos

cut if non-targets are n

• Backpack spray whene• Yearly revisits will be n

of which is dependent and the seed bank. 

Houndstongue (CYOF) Perennial 

• Hand pull or dig for small populations. Entire 

root system must be removed. Plants could 

be left on site if no seed pods are present (seed can remain viable for more than one year). 

• These treatments may take up to five years. • If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Re-vegetate with desirable species. 

• Metsulfuron methyl• Imazapic • Picloram • Chlorsulfuron • Glyphosate 

• Roadsides: Broadcast 

where dominant plant 

native. 

• Large non-sensitive sit

spray 

• Other sites: Backpack • Apply during active gro

rosette stage.

• Revisits will be necess

which is dependent on the seed bank. 

Appendix G-5 
Final Environmental Impact Statement 

Target Species General Prescription Herbicide Options When/How to Trea

Leafy spurge (EUES) Perennial 

• Leafy spurge is one of the first plants to 

emerge in the spring. Seed germination is 

high and seeds can remain dormant for 5-8 years in soils, although most seeds germinate within 2 years. Seeds are dispersed from mid- to late-July. They are explosively discharged (up to 16 feet), can float in and spread by water, and be dispersed by birds. 

• Repeated herbicide treatment (for 5-10 years 

or possibly longer) is the most effective control. 

• Prescribed fire in conjunction with herbicide 

treatment can be an excellent control in open 

areas. Results are very good whether burning is followed by spraying or vice versa, but, as with herbicide application alone, repeated treatments are needed for 5-10 years or longer. 

• Some weed extension services support 

repeated mowing or hand cutting, in conjunction with herbicide application to control leafy spurge; however, others consider mechanical and manual treatment ineffective because of the plant’s extensive root system and ability to resprout. It is also capable of regrowing from belowground vegetative tissue. 

• Repeated sheep grazing, reportedly, has 

proven effective on ranches in Montana. 

• Biological controls (e.g., spurge hawkmoth) 

have been released, but are not effective by themselves in controlling leafy spurge. 

• Glyphosate 

• Picloram 

• Timing of application is 

by herbicide. Apply gly

prevent flowering and tAn alternative recommglyphosate after seed safter fall regrowth but b

• Apply picloram in sprin

during seed developm

the fall (late SeptembeSome research stressetwo herbicide applicationce in the spring to pdevelopment and agaitranslocation of the he

• Leafy spurge cannot b

single herbicide treatmmonitoring and reapplimust continue for at lepossibly, longer. 

Appendix G-6 
Site-Specific In

Target Species General Prescription Herbicide Options When/How to Trea

Meadow hawkweed (HIPR) Orange hawkweed (HIAU)Common hawkweed (HIVU)Perennials

• Herbicide treatment is most effective. • Some manual removal possible for small 

infestations. All plant parts should be 

removed. 

• Covering with plastic tarp may also work for 

small infestations. 

• Nitrogen fertilization after treatment will 

encourage native plant growth if done in the 

spring. 

• Re-vegetate with desirable species. 

• Clopyralid • Picloram • Glyphosate 

• Backpack spray whene• Broadcast spray in are

where dominant plant 

native. 

• Treat in spring after mo

emerge but before budmay also be effective, 

• Yearly revisits will be n

of which is dependent 

and the seed bank. 

Mediterranean sage (SAAE) Biennial 

• Best control is with current biological control; 

otherwise, herbicide treatment is effective. 

• Clopyralid • Picloram • Aquatic Label 

Glyphosate for 

riparian/high water areas 

• Backpack spray in late 

Medusahead rye (TACA8) Winter annual 

• Repeated cutting/mowing with herbicide 

treatment is effective. 

• Manual removal can be effective with small 

populations. 

• A combination of prescribed fire (in June), 

herbicide application, and reseeding with 

native grasses is considered highly effective. Repeated treatments may be needed 

• Grazing supplemented by herbicide 

application and reseeding can also be effective. 

• No known or approved biological control 

agents. 

• Active restoration (seeding of a competitive 

desirable species) is important. 

• Glyphosate 

• Imazapic 

• Treatment should be d

formation or during the 

winter. 

Appendix G-7 
Final Environmental Impact Statement 

Target Species General Prescription Herbicide Options When/How to Trea

Perennial peavine (LALA4) Herb robert (GERO) Perennial 

• Hand pulling is most effective if the entire 

plant is pulled. Can be left on site. 

• Care must be taken not to pull desirable 

vegetation which is intermingled usually. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Glyphosate • On large infestations: 

early spring. 

• Yearly revisits will be n

of which is dependent and the seed bank. 

Perennial pepperweed (LELA2) Perennial 

• Manual removal is not effective because of 

the extent of the plant’s underground rooting 

system. 

• Tillage spreads rhizomes that form new 

plants. 

• Mowing at the flower bud growth stage can 

be effective when integrated with herbicide treatment(s). 

• Biological control is limited because of the 

inability of biological control insects to select between Lepidium species, several of which are endangered. 

• Herbicide use is the most effective treatment.

• Glyphosate • Metsulfuron methyl• Chlorsulfuron 

• Glyphosate is most eff

budding plants in the fa

hard frost. Fall and sprmore effective than fallarge or severe infesta

• Metsulfuron and chlors

when applied from flowflowering. 

Policeman’s helmet (also known as ornamental jewelweed) (IMGL) Annual 

• Hand pulling is effective for small infestations 

of this shallow-rooted plant. 

• Mechanical treatment (mowing and cutting) 

is an effective control measure, but plants can resprout later, so mechanical treatment is not a long-term solution. 

• Herbicide treatment should only be 

considered for larger infestations. 

• Aquatic Labeled 

Glyphosate 

• Triclopyr 

• Herbicide treatment sh

plants flower and prod

• It’s important to practic

re-vegetate the site foltreatment (especially wglyphosate, which is a that kills all vegetation) infestation. 

Puncturevine (TRTE) Annual 

• Herbicide treatment is the most effective 

control. 

• Biological control agents (insects) may be 

effective against puncturevine and are being 

tested. 

• Chlorsulfuron • Picloram • Imazapic 

• Aquatic Label 

Glyphosate for 

riparian/high water areas 

• Backpack spray young 

Appendix G-8 
Site-Specific In

Target Species General Prescription Herbicide Options When/How to Trea

Purple loosestrife (LYSA2) Perennial 

• Hand removal of small populations or 

isolated stems is possible, but only if entire 

rootstock is removed. All plant parts must be removed from site. 

• The only other technique would be hand 

cutting of flower heads, which only suppresses seed production. 

• Herbicide treatment is most effective. • Re-vegetate with desirable species. 

• Glyphosate • Larger stems: Cut and 

under inflorescence. 

• A glove technique for h

used. Wick up the top heads are removed. 

• Yearly revisits will be n

of which is dependent and the seed bank. 

Reed canarygrass (PHAR3) Perennial 

• Use a combination of herbicides and manual, 

mechanical, cultural or prescribed fire 

treatments. Manual treatments or mowing are only practical for small stands when multiple entries per year can be made. The entire population must be removed 2 to 3 times per year for at least five years. 

• Discing or plowing can be effective especially 

after herbicide treatment. 

• Prescribed burning several weeks after 

herbicide treatment or in the late fall could 

also be effective. 

• Covering populations with black plastic may 

be effective if shoots are not allowed to grow 

beyond tarps. This technique could take over two years to be effective. 

• Sulfometuron

methyl 

• Glyphosate 

• Backpack spray whene

• Broadcast spray in den

dominant plant commu

• Apply in early spring w

before other wetland s

• Yearly revisits will be n

of which is dependent and the seed bank. 

Rush Skeletonweed (CHJU) Perennial 

• No manual techniques recommended. • Frequent mowing of plants infested with gall 

mites by decrease the rate of spread. 

• Re-vegetate with desirable species. 

• Clopyralid • Picloram • Glyphosate 

• Broadcast spray in den

dominant plant commu

• Backpack spray whene• Apply to rosette in late 

bolting stage in spring. 

• Application may be diff

surface. 

• Plants less than 5 year• Aggressive repeated tr

necessary. 

• The number will be de

herbicide used and the 

Appendix G-9 
Final Environmental Impact Statement 

Target Species General Prescription Herbicide Options When/How to Trea

Scotch broom (CYSC4) Perennial 

• Hand pull, cutting, weed wrenching or 

digging small populations or when regular 

volunteers are available. Hand pulling or weed wrenching is most effective in moist soils. Plants can be left on site if no seed pods are present (seed can remain viable for more than one year). Cutting will require multiple visits in one year. 

• These treatments may take up to ten years 

due to long term seed viability. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Re-vegetate with desirable species. 

• Triclopyr • Glyphosate • Clopyralid • Picloram 

• Larger plants: Cut and • Smaller plants: Backpa

pulling or weed wrench

• Apply during active gro

spring to young plants

• Yearly revisits will be n

of which is dependent and the seed bank. 

Scotch thistle (also known as Scotch cottonthistle) (ONAC) Biennial 

• Herbicide treatment is the most effective 

control. 

• Picloram • Chlorsulfuron • Clopyralid • Metsulfuron • Aquatic Label 

Glyphosate for 

riparian/high water areas 

• Backpack spray in the 

bolt or during the fall o

Shining geranium (GELU) Annual 

• Hand pulling can be effective if the entire 

plant is pulled. Can be left on site. 

• Care must be taken not to pull desirable 

vegetation which is intermingled usually. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Glyphosate • On large infestations: 

early spring. 

• Yearly revisits will be n

of which is dependent and the seed bank. 

Appendix G-10 
Site-Specific In

Target Species General Prescription Herbicide Options When/How to Trea

Spotted knapweed (CEBI2) Diffuse knapweed (CEDI3) Meadow knapweed (CEPR2) Brownray knapweed (CEJA5) Black knapweed (CENI2) Russian knapweed (CERE6) Squarrosa knapweed (CESQ) Yellow star thistle (CESO3) Biennials or perennials 

• Hand pull or dig small populations or when 

regular volunteers are available. 

• Remove all plant parts from the site. Multiple 

entries per year are required. 

• Mowing is possible, but timing is critical. • These treatments may take up to ten years 

due to long term seed viability. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Re-vegetate with desirable species. 

• Clopyralid • Picloram • Glyphosate 

• Roadsides: Broadcast 

where dominant plant 

native. 

• Other sites: Backpack • Treat in spring before • Yearly revisits will be 

of which is dependent 

and the seed bank. 

St. Johnswort (HYPE) Perennial 

• Hand removal of small populations or 

isolated stems is possible, but repeated 

treatments will be necessary as lateral roots give rise to new plants. Pulled or dug plants must be removed from the area and burned.

• These treatments may take up to ten years 

due to long term seed viability. 

• Biological controls will most likely not be 

effective in damp, cool climates. 

• Re-vegetate with desirable species. 

• Metsulfuron methyl• Picloram • Glyphosate 

• Backpack spray whene• Broadcast spray larger 

where dominant plant 

native. 

• Apply metsulfuron met

fully emerged and in a

• Apply picloram in early 

bloom. 

• Yearly revisits will be n

of which is dependent and the seed bank. 

Appendix G-11 
Final Environmental Impact Statement 

Target Species General Prescription Herbicide Options When/How to Trea

Tansy ragwort (SEJA) Common tansy (TAVU) Biennial or perennial 

• Hand pulling is effective if done in moist 

soils. This is most effective after the 

population has been brought under control. 

• Mowing is the most common technique and 

is effective if done prior to flowering. 

• These treatments may take up to ten years 

due to long term seed viability. 

• Ensure biological controls are present nearby 

or request their introduction. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Re-vegetate with desirable species. 

• Metsulfuron methyl• Picloram • Clopyralid • Glyphosate 

• Roadsides: Braodcast 

where dominant plant 

native 

• Large non-sensitive sit

spray 

• Other sites: Backpack • During active growth, u

stage. 

• Revisits will be necess

which is dependent on the seed bank. 

Water hemlock (CIMA2) Biennial or perennial 

• Hand grubbing (digging and pulling) and 

herbicide treatment are the best control 

methods. 

• Aquatic Labeled 

Glyphosate 

• Picloram 

• Backpack spraying pla

early summer, when p

best time to apply herb

Whitetop (CADR) Perennial 

• Diligent hand pulling or digging can control 

small infestations, but plants must be 

completely removed within 10 days after emergence throughout growing season for two to four years 

• Mowing followed a month later by herbicide 

may be effective. Mowing must be done 

during full flowering. 

• If herbicides are used, manual treatments 

could be used for follow-up. Relative 

amounts of herbicide to manual treatments would decline over time. 

• Re-vegetate with desirable species. 

• Metsulfuron methyl• Chlorsulfuron • Sulfometuron

methyl 

• Glyphosate • Picloram 

• Backpack spray whene

• Broadcast spray in den

dominant plant commu

• Apply at pre-bloom to b

to rosettes in the fall 

• Yearly revisits will be n

of which is dependent and the seed bank. 

Appendix G-12 
APPENDIX H 

Proposed Herbicide Use at Treatment Sites 

in the Proposed Action 
 
Site-Specific In

APPENDIX H: Proposed Herbicide Use at Treatment Sites in the ProposSelected herbicides are based on the prescriptions described in Common Control Measures (Mazzu, 2005). Elevelight gray) have no herbicides prescribed. 

Treatment 

ID Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr 

Metsulfuron 

methyl Picloram Sethoxydim 

S

22-01 22-05 22-07 22-08 22-11 22-12 22-17 

61-002 61-003 61-005 61-006 61-007 61-009 61-017 61-018 61-019 61-020 61-021 61-022 61-023 61-024 61-025 61-026 61-027 61-028 61-029 61-030 61-034 61-036 61-039 61-040 

Appendix H-1 
Final Environmental Impact Statement 

Treatment 

ID Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr 

Metsulfuron 

methyl Picloram 

S

Sethoxydim 

61-041 61-042 61-043 61-044 61-045 61-046 61-047 61-048 61-049 61-050 61-051 61-053 61-055 61-057 61-058 61-059 61-062 61-064 61-065 61-066 61-071 61-073 61-074 61-075 61-076 61-077 61-078 61-079 61-080 61-081 61-082 61-083 61-084 61-085 61-086 61-087 61-088 

Appendix H-2 
Site-Specific In

Treatment 

ID Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr 

Metsulfuron 

methyl Picloram 

S

Sethoxydim 

61-089 61-090 61-091 61-092 61-093 61-095 65-001 65-002 65-003 65-005 65-006 65-007 65-008 65-009 65-010 65-011 65-012 65-013 65-014 65-015 65-016 65-017 65-018 65-019 65-020 65-021 65-022 65-023 65-024 65-025 65-026 65-027 65-028 65-029 65-030 65-031 65-032 

Appendix H-3 
Final Environmental Impact Statement 

Treatment 

ID Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr 

Metsulfuron 

methyl Picloram 

S

Sethoxydim 

65-033 65-034 65-035 65-036 65-037 65-038 65-039 65-040 65-041 65-042 65-043 65-044 65-045 65-046 66-001 66-003 66-004 66-005 66-006 66-007 66-008 66-009 66-010 66-011 66-012 66-013 66-016 66-017 66-018 66-020 66-023 66-025 66-026 66-027 66-028 66-029 66-030 

Appendix H-4 
Site-Specific In

Treatment 

ID Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr 

Metsulfuron 

methyl Picloram 

S

Sethoxydim 

66-033 66-035 66-037 66-038 66-039 66-040 66-041 66-042 66-043 66-044 66-046 66-047 66-048 66-049 66-051 66-052 66-053 66-055 66-057 66-058 66-059 66-060 66-062 66-063 66-067 66-069 66-071 66-074 66-081 66-082 66-083 66-084 66-085 66-086 66-087 66-089 66-091 

Appendix H-5 
Final Environmental Impact Statement 

Treatment 

ID Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr 

Metsulfuron 

methyl Picloram 

S

Sethoxydim 

69-001 69-002 69-003 69-004 69-005 69-006 69-007 69-008 69-010 69-011 69-012 69-013 69-014 69-015 69-016 69-017 69-018 69-019 69-020 69-021 69-022 69-023 69-024 69-025 69-026 69-027 69-028 69-029 69-030 

Appendix H-6 
APPENDIX I 

Oregon State Class A & B Noxious Weeds 
 
Site-Specific Invasive Plant Treatments 

APPENDIX I: Oregon State Class A & B Noxious Weeds 

Taken from Oregon Department of Agriculture Noxious Weed Control Program, 

2006 Noxious Weed Policy and Classification System 

(http://www.oregon.gov/ODA/PLANT/WEEDS/docs/weed_policy.pdf). 

Noxious weeds, for the purpose of this system, shall be designated “A” or “B” and may be given 

the additional designation of “T” according to the Oregon Department of Agriculture Noxious 

Weed Rating System. 

• “A” Designated Weed 

A weed of known economic importance which occurs in the state in small enough 

infestations to make eradication or containment possible; or is not know to occur, but its 

presence in neighboring states make future occurrence in Oregon seem imminent. 

Recommended Action: Infestations are subject to eradication or intensive control when and 

where found. 

• “B” Designated Weed 

A weed of economic importance which is regionally abundant, but which may have limited 

distribution in some counties. 

Recommended Action: Limited to intensive control at the state, county or regional level as 

determined on a case-by-case basis. Where implementation of a fully integrated statewide 

management plan is not feasible, biological control (when available) shall be the main 

control approach. (“B” weeds targeted for biological control are identified with an asterisk). 

• “T” Designated Weed 

A priority noxious weed designated by the Oregon State Weed Board as a target on which the 

Oregon Department of Agriculture will develop and implement a statewide management 

plan. “T” designated noxious weeds are species selected from either the “A” or “B” list. 

Appendix I-1 
Draft Environmental Impact Statement 

Weed 

Class Common Name Family Scientific Name 

A African rue Caltrop Peganum harmala 

B Austrian peaweed Fabaceae Sphaerophysa salsula 

A, T Barbed goatgrass Poaceae Aegilops triuncialis 

B Bearded creeper 

(Common crupina) 

Asteraceae Crupina fulgaris 

B Biddy-biddy Zygophyllaceae Acaena novae-zelandiae 

B Buffalobur Solanaceae Solanum rostratum 

B Bull thistle * Asteraceae Cirsium vulagre 

B Butterfly bush Buddlejaceae Buddleja davidii 

A Camelthorn Fabaceae Alhagi pseudalhagi 

B Canada thistle * Asteraceae Cirsium arvense 

A Coltsfoot Asteraceae Tussilago farara 

B, T Common bugloss Boraginaceae Anchusa officinalis 

A, T Common cordgrass Poaceae Spartina anglica 

B Creeping yellow cress Brassicaceae Rorippa sylvestris 

B Cutleaf teasel Dipsacaceae Dipsacus laciniatus 

B Dalmatian toadflax * Scrophulariaceae Linaria dalmatica 

A, T Dense flowered cordgrass Poaceae Spartina densiflora 

B Diffuse knapweed * Asteraceae Centaurea diffusa 

B Dodder Cuscutaceae Suscuta spp. 

B Dyers woad Brassicaceae Isatis tinctoria 

B English ivy Araliaceae Hedera helix 

B Eurasian watermilfoil Haloragaceae Myriophyllum spicatum 

A European water chestnut Trapaceae Trapa natans 

B False brome Poaceae Brachypodium sylvaticum 

B Field bindweed * Convolvulaceae Convolvulus arvensis 

B French broom * Fabaceae Cytisus monspessulanas 

A, T Giant hogweed Apiaceae Heracleum mantegazzianum 

B Giant horsetail Equietaceae Equisetum telmateia 

B, T Giant knotweed Polygonaceae Polygonum sachalinense 

B, T Gorse * Fabaceae Ulex europaeus 

B Hairy white top Brassicaceae Cardaria pubescens 

B Halogeton Chenopodiac Halogeton glomeratus 

B Himalayan blackberry Rosaceae Rubus discolor(precerus) 

B, T Himalayan knotweed Polygonaceae Polygonum polystachyum 

B Houndstongue Boraginaceae Cynoglossum officinale 

A Hydrilla Hydrocharitaceae Hydrilla verticillata 

A, T Iberian starthistle Asteraceae Centaurea iberica 

B Italian thistle * Asteraceae Carduus phycnocephalus 

B, T Japanese knotweed Polygonaceae Polygonum cuspidatum 

B Johnsongrass Poaceae Sorghum halepense 

B Jointed goatgrass Poaceae Aegilops cylindrica 

B Jubata grass Poaceae Cortaderia jubata 

Appendix I-2 
Site-Specific Invasive Plant Treatments 

Weed 

Class Common Name Family Scientific Name 

A King-devil hawkweed Asteraceae Hieracium piloselloides 

B Kochia Chenopodiaceae Kochia scoparia 

A, T Kudzu Fabaceae Pueraria lobata 

B, T Leafy spurge * Euphorbiaceae Euphorbia esula 

B Lens-podded white top Brassicaceae Cardaria chalapensis 

A Matgrass Poaceae Nardus stricta 

A, T Meadow hawkweed Asteraceae Hieracium pratense 

B Meadow knapweed * Asteraceae Centaurea pratensis 

B Mediterranean sage Lamiaceae Salvia aethiopis 

B Medusahead rye Poaceae Taeniatherum canputmedusae 

B Milk thistle * Asteraceae Silyburn marianum 

A Mouse-ear hawkweed Asteraceae Hieracium pilosella 

B Musk thistle * Asteraceae Carduss nutans 

B Myrtle spurge Euphorbiaceae Euphorbia myrsinites 

B Old man ́s beard Ranunculaceae Clematis vitalba 

A, T Orange hawkweed Asteraceae Hieracium aurantiacum 

A Ovate goatgrass Poaceae Aegilops ovata 

A Paterson’s curse Boraginaceae Echium plantagineum 

B Perennial pepperweed Brassicaceae Lepidium latifolium 

A Plumeless thistle Asteraceae Carduus alanthoides 

B Poison hemlock Apiaceae Conium maculatum 

B Policeman’s helmet Balsaminaceae Impatiens glandulifera 

B Portuguese broom Fabaceae Cytisus striatus 

B, T Portuguese broom Fabaceae Cytisus striatus 

B Puncturevine * Zygophyllaceae Tribulus terrestris 

B, T Purple loosestrife * Lythraceae Lythrum salicaria 

A Purple nutsedge Cyperaceae Cyperus rotundus 

A, T Purple starthistle Asteraceae Centaurea calcitrapa 

B Quackgrass Poaceae Agropyron repens 

B Ragweed Asteraceae Ambrosia artemisiifolia 

B, T Rush skeletonweed * Asteraceae Chondrilla juncea 

B Russian knapweed * Asteraceae Acroptilon repens 

B Saltcedar * Tamaricaceae Tamarix ramosissima 

A, T Saltmeadow cordgrass Poaceae Spartina patens 

B, T Saltmeadow Cordgrass Poaceae Spartina patens 

B Scotch broom * Fabaceae Cytisus scoparius 

B Scotch thistle Asteraceae Onopordum acanthium 

A Silverleaf nightshade Solanaceae Solanum elaegnifolium 

A Skeletonleaf bursage Asteraceae Ambrosia tomentosa 

B Slender flowered thistle * Asteraceae Carduus tenuiflorus 

B Small broomrape Orbanchaceae Orobanche minor 

A, T Smooth cordgrass Poaceae Spartina alterniflora 

A Smooth distaff thistle Asteraceae Carthamus baeticus 

B South American 

waterweed(Elodea) 

Hydrocharitaceae Elodea (egeria)densa 

Appendix I-3 
Draft Environmental Impact Statement 

Weed 

Class Common Name Family Scientific Name 

B Spanish broom Leguminosae Spartium junceum 

B Spikeweed Asteraceae Hemizonia pungens 

B Spiny cocklebur Asteraceae Xanthium spinosum 

B, T Spotted knapweed * Asteraceae Centaurea maculosa 

A, T Squarrose knapweed Asteraceae Centaurea virgata 

B St.Johnswort (Klamath weed) Hypericaceae Hypericum perforatum 

B Sulfur cinquefoil Rosaceae Potentilla recta 

A Syrian bean caper Zygophyllaceae Zygophyllum fabago 

B, T Tansy ragwort * Asteraceae Senecio jacobaea 

A Texas blueweed Asteraceae Helianthus ciliaris 

B Velvetleaf Malvaceae Abutilon theophrasti 

B White top (Hoary cress) Brassicaceae Cardaria draba 

A, T Wolly distaff thistle Asteraceae Carthamus lanatus 

B Yellow flag iris Iridaceae Iris pseudacorus 

A Yellow floating heart Menyanthaceae Nymphoides peltata 

A, T Yellow hawkweed Scrophulariaceae Hieracium floribundum 

B Yellow nutsedge Cyperacea Cyperus esulentus 

B, T Yellow starthistle * Asteraceae Centaurea solstitialis 

B Yellow toadflax * Scrophulariaceae Linaria vulgaris 

Appendix I-4 
APPENDIX J 

Invasive Plant Treatments by Fifth Field 

Watersheds 
 
Site-Specific Invasive Plant Treatments 

APPENDIX J: Invasive Plant Treatments by Fifth Field 

Watershed 

Acres of proposed treatments and percentage of total watershed proposed for treatment by 5th

field watersheds. The table describes 5th fields either partially or wholly contained within the 

Forest and Scenic Area that include treatment areas. 

Watershed # Watershed Name 

Watershed 

Acres 

Treatment 

ID 

Treatment 

Acres 

Percent 

Treated in 

Watershed 

61-009 0.10 0.00% 

61-017 96.09 0.06% 

61-018 7.99 0.01% 

61-089 84.56 0.05% 

1707010502 Fifteenmile Creek 157237.53 

61-095 39.07 0.02% 

Subtotal 157237.53 227.81 0.14% 

61-002 119.38 0.15% 

61-003 55.02 0.07% 

61-005 72.23 0.09% 

61-006 92.15 0.12% 

61-007 5.44 0.01% 

61-009 43.11 0.06% 

61-088 59.71 0.08% 

1707010503 Fivemile Creek 78190.47 

61-095 64.79 0.08% 

Subtotal 78190.47 511.83 0.65% 

22-12 81.89 0.06% 

66-033 17.30 0.01% 

66-042 2.74 0.00% 

66-055 36.70 0.03% 

66-074 53.18 0.04% 

1707010504 Middle Columbia/ 

Mill Creek 

130697.64 

66-081 22.23 0.02% 

Subtotal 130697.64 214.04 0.16% 

61-095 0.10 0.00% 

66-008 331.13 0.33% 

66-010 10.01 0.01% 

66-011 3.03 0.00% 

66-013 10.81 0.01% 

66-018 51.22 0.05% 

66-025 1.61 0.00% 

66-027 4.00 0.00% 

1707010506 East Fork Hood River 100953.29 

66-028 0.82 0.00% 

Appendix J-1 
Final Environmental Impact Statement 

Watershed # Watershed Name 

Watershed 

Acres 

Treatment 

ID 

Percent 

Treatment Treated in 

Acres Watershed 

66-030 0.26 0.00% 

66-035 5.52 0.01% 

66-038 85.74 0.08% 

66-041 1.03 0.00% 

66-042 0.08 0.00% 

66-043 1.36 0.00% 

66-047 7.08 0.01% 

66-053 4.24 0.00% 

66-062 145.79 0.14% 

66-063 412.97 0.41% 

66-074 11.01 0.01% 

66-082 93.09 0.09% 

66-084 73.17 0.07% 

Subtotal 100953.29 1254.07 1.24% 

66-003 34.57 0.05% 

66-004 18.88 0.03% 

66-005 25.02 0.04% 

66-006 58.62 0.09% 

66-007 448.78 0.69% 

66-009 9.31 0.01% 

66-012 0.67 0.00% 

66-016 78.79 0.12% 

66-017 66.57 0.10% 

66-023 350.89 0.54% 

66-026 0.07 0.00% 

66-029 0.69 0.00% 

66-040 1.08 0.00% 

66-048 3.59 0.01% 

66-049 3.65 0.01% 

66-060 105.24 0.16% 

66-063 217.98 0.33% 

66-067 103.70 0.16% 

66-071 64.71 0.10% 

66-083 27.70 0.04% 

1707010507 West Fork Hood River 65466.30 

69-008 0.00 0.00% 

Subtotal 65466.30 1620.51 2.48% 

1707010508 Lower Hood River 51289.31 66-035 1.38 0.00% 

66-038 175.75 0.34% 

Appendix J-2 
Site-Specific Invasive Plant Treatments 

Watershed # Watershed Name 

Watershed 

Acres 

Treatment 

ID 

Percent 

Treatment Treated in 

Acres Watershed 

66-044 0.40 0.00% 

66-046 1.82 0.00% 

66-055 4.53 0.01% 

66-067 21.49 0.04% 

66-074 44.95 0.09% 

Subtotal 51289.31 250.32 0.49% 

22-05 10.44 0.01% 

22-07 21.19 0.02% 

22-08 23.53 0.03% 

22-11 109.86 0.12% 

1707010512 Middle Columbia/ 

Grays Creek 

92722.76 

66-067 8.33 0.01% 

Subtotal 92722.76 173.35 0.19% 

1707010513 Middle Columbia/ 

Eagle Creek 

84495.22 

22-05 79.16 0.09% 

Subtotal 84495.22 79.16 0.09% 

61-041 4.21 0.00% 

61-055 6.91 0.01% 

61-057 0.59 0.00% 

61-083 0.31 0.00% 

61-087 19.84 0.02% 

1707030605 Beaver Creek 106742.00 

61-093 13.66 0.01% 

Subtotal 106742.00 45.52 0.04% 

61-048 19.81 0.01% 

61-050 93.99 0.05% 

61-058 9.94 0.01% 

61-059 22.77 0.01% 

61-062 3.80 0.00% 

61-064 0.44 0.00% 

61-065 18.92 0.01% 

61-066 8.34 0.00% 

61-073 31.09 0.02% 

61-079 21.57 0.01% 

61-080 17.98 0.01% 

61-081 3.52 0.00% 

61-082 0.29 0.00% 

61-083 18.61 0.01% 

61-085 10.13 0.01% 

1707030607 Middle Deschutes River 195384.59 

61-086 24.33 0.01% 

Appendix J-3 
Final Environmental Impact Statement 

Watershed # Watershed Name 

Watershed 

Acres 

Treatment 

ID 

Percent 

Treatment Treated in 

Acres Watershed 

61-087 10.12 0.01% 

Subtotal 195384.59 315.65 0.16% 

61-018 40.19 0.05% 

61-019 246.49 0.30% 

61-020 0.49 0.00% 

61-021 6.82 0.01% 

1707030609 Tygh Creek 81558.38 

61-089 4.07 0.00% 

Subtotal 81558.38 298.06 0.37% 

61-019 18.02 0.01% 

61-021 39.43 0.02% 

61-022 11.27 0.01% 

61-023 10.93 0.01% 

61-024 30.12 0.02% 

61-025 54.12 0.03% 

61-026 34.72 0.02% 

61-027 26.81 0.02% 

61-028 51.60 0.03% 

61-029 40.20 0.02% 

61-030 5.98 0.00% 

61-034 58.46 0.03% 

61-036 25.80 0.01% 

61-039 75.93 0.04% 

61-040 10.40 0.01% 

61-041 54.98 0.03% 

61-042 52.14 0.03% 

61-043 15.74 0.01% 

61-044 20.16 0.01% 

61-045 33.17 0.02% 

61-046 2.89 0.00% 

61-047 1.47 0.00% 

61-048 19.02 0.01% 

61-049 19.55 0.01% 

61-050 17.81 0.01% 

61-051 0.36 0.00% 

61-053 3.74 0.00% 

61-071 40.82 0.02% 

61-074 45.73 0.03% 

1707030610 White River 176272.25 

61-075 12.53 0.01% 

Appendix J-4 
Site-Specific Invasive Plant Treatments 

Watershed # Watershed Name 

Watershed 

Acres 

Treatment 

ID 

Percent 

Treatment Treated in 

Acres Watershed 

61-076 15.39 0.01% 

61-077 44.66 0.03% 

61-078 22.43 0.01% 

61-079 15.63 0.01% 

61-084 32.39 0.02% 

61-085 5.79 0.00% 

61-086 39.88 0.02% 

61-087 0.20 0.00% 

61-090 0.51 0.00% 

61-091 3.65 0.00% 

61-092 5.99 0.00% 

61-093 5.40 0.00% 

66-001 20.75 0.01% 

66-008 112.08 0.06% 

66-020 1014.29 0.58% 

66-037 9.63 0.01% 

66-039 3.52 0.00% 

66-051 5.67 0.00% 

66-052 8.78 0.00% 

66-057 80.31 0.05% 

66-058 14.94 0.01% 

66-059 39.70 0.02% 

66-069 50.45 0.03% 

66-085 145.55 0.08% 

66-086 296.42 0.17% 

66-087 67.97 0.04% 

66-089 154.45 0.09% 

66-091 120.19 0.07% 

69-026 1.12 0.00% 

Subtotal 176272.25 3171.64 1.80% 

66-008 66.12 0.09% 

66-085 2.51 0.00% 

69-001 7.50 0.01% 

69-004 24.14 0.03% 

69-006 0.09 0.00% 

69-016 72.25 0.10% 

1708000101 Salmon River 73716.08 

69-024 0.19 0.00% 

Subtotal 73716.08 172.80 0.23% 

Appendix J-5 
Final Environmental Impact Statement 

Watershed # Watershed Name 

Watershed 

Acres 

Treatment 

ID 

Percent 

Treatment Treated in 

Acres Watershed 

69-002 0.01 0.00% 

69-008 3.72 0.01% 

69-010 0.02 0.00% 

69-011 0.01 0.00% 

69-012 0.20 0.00% 

69-013 0.07 0.00% 

69-014 0.03 0.00% 

69-015 0.03 0.00% 

69-016 348.62 0.92% 

69-017 0.93 0.00% 

69-018 1.08 0.00% 

69-019 0.72 0.00% 

69-020 0.43 0.00% 

69-021 1.39 0.00% 

69-022 0.77 0.00% 

69-023 0.61 0.00% 

69-025 3.25 0.01% 

69-028 3.73 0.01% 

1708000102 Zigzag River 37763.73 

69-030 3.10 0.01% 

Subtotal 37763.73 368.72 0.98% 

66-003 8.22 0.02% 

66-005 18.71 0.05% 

66-007 0.04 0.00% 

66-016 0.01 0.00% 

1708000103 Upper Sandy River 34200.89 

69-008 1033.74 3.02% 

Subtotal 34200.89 1060.72 3.10% 

69-008 16.36 0.04% 

69-016 23.72 0.06% 

1708000104 Middle Sandy River 40956.70 

69-029 0.40 0.00% 

Subtotal 40956.70 40.48 0.10% 

1708000105 Bull Run River 88984.99 69-008 2.35 0.00% 

Subtotal 88984.99 2.35 0.00% 

22-01 778.27 0.75% 

22-17 138.10 0.13% 

69-003 14.88 0.01% 

1708000107 Columbia Gorge 

Tributaries 

103926.08 

69-005 11.00 0.01% 

Subtotal 103926.08 942.25 0.91% 

1708000108 Lower Sandy River 47155.16 22-01 794.81 1.69% 

Appendix J-6 
Site-Specific Invasive Plant Treatments 

Watershed # Watershed Name 

Watershed 

Acres 

Treatment 

ID 

Percent 

Treatment Treated in 

Acres Watershed 

22-17 0.95 0.00% 

69-003 28.69 0.06% 

69-005 31.71 0.07% 

69-007 0.48 0.00% 

Subtotal 47155.16 856.63 1.82% 

65-017 4.05 0.00% 

65-026 4.72 0.00% 

65-027 0.73 0.00% 

65-028 0.77 0.00% 

65-029 11.63 0.01% 

65-030 11.39 0.01% 

65-031 14.27 0.01% 

65-032 2.74 0.00% 

65-033 9.64 0.01% 

1709001101 Collawash River 97421.08 

65-041 4.18 0.00% 

Subtotal 97421.08 64.12 0.07% 

65-014 4.54 0.00% 

65-016 4.01 0.00% 

65-023 415.11 0.41% 

65-040 1.67 0.00% 

65-042 9.65 0.01% 

65-043 18.51 0.02% 

65-044 23.02 0.02% 

65-045 0.11 0.00% 

1709001102 Upper Clackamas River 100496.76 

65-046 8.31 0.01% 

Subtotal 100496.76 484.93 0.48% 

65-001 33.30 0.04% 

65-003 64.81 0.07% 

65-009 1.03 0.00% 

65-010 12.99 0.01% 

65-011 1.07 0.00% 

65-015 18.69 0.02% 

65-018 1.09 0.00% 

65-024 4.58 0.01% 

65-034 5.20 0.01% 

65-035 5.30 0.01% 

65-037 0.39 0.00% 

1709001103 Oak Grove Fork 

Clackamas River 

90542.01 

65-038 1.08 0.00% 

Appendix J-7 
Final Environmental Impact Statement 

Watershed # Watershed Name 

Watershed 

Acres 

Treatment 

ID 

Percent 

Treatment Treated in 

Acres Watershed 

65-039 0.28 0.00% 

69-027 25.95 0.03% 

Subtotal 90542.01 175.76 0.19% 

65-002 61.59 0.04% 

65-005 0.06 0.00% 

65-006 0.24 0.00% 

65-008 0.20 0.00% 

65-012 12.38 0.01% 

65-013 46.77 0.03% 

65-019 4.95 0.00% 

65-020 414.39 0.30% 

65-021 3.22 0.00% 

65-022 5.18 0.00% 

65-023 1.28 0.00% 

65-025 2.80 0.00% 

65-036 3.62 0.00% 

1709001104 Middle Clackamas River 138506.60 

69-027 190.75 0.14% 

Subtotal 138506.60 747.43 0.54% 

1709001106 Lower Clackamas River 117660.69 65-007 3.38 0.00% 

Subtotal 117660.69 3.38 0.00% 

Appendix J-8 
APPENDIX K 

Proposed Herbicide Treatments for 

Alternative 3 
 
Site-Specific In

APPENDIX K: Proposed Herbicide Treatments for Alternative 3 Proposed herbicide treatments and selected herbicides for Alternative 3 – Restricted Herbicide Alternative are baprescriptions described in Common Control Measures (Mazzu, 2005). No sites have sethoxydim, listed as a potetreatment sites not listed in this table have the same manual and mechanical treatments prescribed under Alternat

Action Alternative. 

Treatment 

ID 

Overall 

Treatment 

Herbicide 

Methods Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr 

Metsulfuron 

methyl Piclo

22-01 

Herbicide plus Manual, Mechanical & Cultural 

Broadcast Application, Backpack Sprayer 

22-08 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

61-022 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

61-050 

Herbicide plus Manual 

Backpack Sprayer 

65-002 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

65-005 Herbicide Stem Injection 65-006 Herbicide Stem Injection 65-008 Herbicide Stem Injection 65-009 Herbicide Stem Injection 65-011 Herbicide Stem Injection 

Appendix K-1 
Final Environmental Impact Statement 

Treatment Overall Herbicide Metsulfuron 

ID Treatment Methods Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr methyl Piclo

65-016 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

65-019 Herbicide Stem Injection 65-021 Herbicide Stem Injection 65-046 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

66-001 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

66-003 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

66-004 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

66-005 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

66-006 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

66-007 

Herbicide plus Manual & Mechanical 

Broadcast Application, Backpack Sprayer 

66-016 

Herbicide plus Manual & Mechanical 

Broadcast Application, Backpack Sprayer 

Appendix K-2 
Site-Specific In

Treatment Overall Herbicide Metsulfuron 

ID Treatment Methods Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr methyl Piclo

66-041 

Herbicide plus Mechanical 

Backpack Sprayer 

66-047 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

66-059 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

66-081 

Herbicide plus Mechanical 

Backpack Sprayer 

66-082 

Herbicide plus Mechanical 

Backpack Sprayer 

66-083 

Herbicide plus Mechanical 

Backpack Sprayer 

66-084 

Herbicide plus Mechanical 

Backpack Sprayer 

69-002 Herbicide Stem Injection 69-003 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

69-006 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

69-008 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

69-010 Herbicide Stem Injection 

Appendix K-3 
Final Environmental Impact Statement 

Treatment Overall Herbicide Metsulfuron 

ID Treatment Methods Clopyralid Chlorsulfuron Glyphosate Imazapic Imazapyr methyl Piclo

69-011 Herbicide Stem Injection 69-012 Herbicide Stem Injection 69-013 Herbicide Stem Injection 69-014 Herbicide Stem Injection 69-015 Herbicide Stem Injection 69-026 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

69-027 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

69-028 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

69-029 

Herbicide plus Manual & Mechanical 

Stem Injection 

69-030 

Herbicide plus Manual & Mechanical 

Backpack Sprayer 

Appendix K-4 
APPENDIX L 

Sample Public Notifications 
 
Site-Specific Invasive Plant Treatments 

APPENDIX L: Sample Public Notifications, Taken from 2005 

Mt. Hood National Forest Herbicide Applications 

SAMPLE #1 

PUBLIC NOTICE 

Mt. Hood National Forest Integrated Weed Management Program

An integrated Weed Management Program which includes the use of herbicides, hand-pulling, 

and biological control will be implemented on the Barlow Ranger District of the Mt. Hood 

National Forest. The use of herbicides will only be applied from April 1 to October 30, 2005. 

The total area to be treated with the use of herbicides will not exceed 350 acres; listed below: 

Diffuse knapweed/Spotted knapweed: 

T1S; R11E; Sec., 15, 21, 22, 23, 24, 25, 26, 27, 28, 29, 31, 32, 33, 34, 34, 35, 36. 

T2S; R10E; Sec., 13, 24 

T2S; R11E; Sec., 1, 2, 3, 4, 5, 6, 8, 9, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 24, 25, 26, 

27, 28, 30, 31, 32, 33, 34, 35, 36. 

T2S; R12E; Sec., 3, 8, 9, 10, 18, 19, 20. 

T3S; R11E; Sec., 1, 2, 3, 4, 12, 13, 21, 22, 23, 24, 25, 26, 27, 28, 30, 31, 32, 33, 35, 36. 

T3S; R12E; Sec., 6, 7, 18, 19, 20, 28, 29, 30, 31. 

T4S; R9E; Sec., 24, 25, 35, 36. 

T4S; R10E; Sec., 1, 2, 3, 4, 5, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 20, 21, 22, 23, 24, 

25, 26, 27, 28, 29, 31, 32, 33, 34, 35, 36. 

T4S; R11E; Sec., 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 13, 14, 15, 16, 21, 22, 23, 26, 27, 29, 30, 

31, 32, 33, 34, 35, 36. 

T5S; R9E; Sec., 1, 2, 3, 10, 11, 12, 13, 14. 

T5S; R10E; Sec., 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 20, 21, 22, 23, 

24, 25, 26.. 

T5S; R11E; Sec., 17, 18, 19, 20, 30, 33, 34. 

T6S; R11E; Sec., 1. 

 

Appendix L-1 
Final Environmental Impact Statement 

Common hound's-tongue: 

T5S; R10E; Sec., 10, 11, 14, 15, 16, 22, 23, 24, 25, 26. 

T5S; R11E; Sec., 17, 25, 30. 

Tansy ragwort: 

 T3S; R11E; Sec., 31, 32. 

 T4S; R11E; Sec., 5, 6, 7, 8, 17, 18. 

T5S; R9E; Sec., 2, 10, 11, 15. 

Scotch broom: 

T2S; R12E; Sec., 19. 

T4S; R11E; Sec., 23. 

T4S; R10E; Sec., 20. 

All restrictions and regulations regarding the use of herbicides will be followed as stated in the 

Region 6 Environmental Impact Statement for Managing Competing and Unwanted Vegetation, 

its accompanying Mediated Agreement, A Guide to Conducting Vegetation Management 

Projects in the Pacific Northwest Region, the Environmental Assessment for the Management of 

Noxious Weeds on the Barlow Ranger District, Mt. Hood National Forest, and the Modification 

to Design Features for Noxious Weed Treatment on the Barlow Ranger District. 

Herbicides will be applied directly to target weeds. Application dates are weather dependent. All 

areas where herbicides are to be used will be posted prior, during, and after application. 

Persons who know or suspect that they are hypersensitive to herbicides may contact the Forest 

Service to determine appropriate risk management measures. 

Questions regarding specific project areas, timing, and treatment may be obtained by calling Dan 

Fissell at the Barlow RD at (541) 467-5117. 

Appendix L-2 
Site-Specific Invasive Plant Treatments 

SAMPLE #2 

PUBLIC NOTICE 

Bonneville Power Administration Vegetation Management Program 

A vegetation management program to keep vegetation a safe distance away from electric power 

facilities and control noxious weeds will be implemented within a portion of the Big EddyOstrander Transmission Corridor. Methods will include manual, mechanical, and herbicide use. 

The project will be implemented from May 22 to October 30, 2005. The location of the sites to 

be treated are as follows: 

Willamette Meridian Township 2 South, Range 8 East, Sections 3, 4, 8, 9, 17, 18 and 19. There 

are approximately 2000 gross acres within the project area, of which about 200 acres will 

actually be treated. 

All restrictions and regulations regarding the use of herbicides will be followed as stated in the 

Transmission System Vegetation Management Program Final Environmental Impact Statement 

(FEIS), the Supplemental Analysis for the Transmission System Vegetation Management 

Program (SA-113), Forest Service Region 6 Environmental Impact Statement for Managing 

Competing and Unwanted Vegetation, its accompanying Mediated Agreement, and A guide to 

Conducting Vegetation Management Projects in the Pacific Northwest Region. 

Herbicides will be applied directly to target vegetation. Application dates are weather dependent. 

All areas where herbicide is to be used will posted prior, during and after application. 

Persons who are known to be or suspect that they are hypersensitive to herbicides may contact 

the Bonneville Power Administration to determine the appropriate risk management measures. 

Questions regarding specific project areas, timing and treatment may be obtained by contacting 

Bill Erickson at (509) 527-6249 or wterickson@bpa.gov. 

Appendix L-3 
Final Environmental Impact Statement 

SAMPLE #3 

PUBLIC NOTICE 

Mt. Hood National Forest Integrated Weed Management Program 

An integrated weed management program which includes the use of herbicides, hand pulling, 

and biological controls will be implemented on the Mt. Hood National Forest from June 1 to 

September 30, 2005. The locations and acreages of sites to be treated with herbicides are listed 

below: 

Clackamas River Ranger District: Road 46, milepost 21 to Squirrel Quarry, 1⁄4 acre; Road 4730-

135, 1/8 acre; Road 4651, 1⁄4 acre; Roads 57/5810 junction, 1/16 acre; Road 45/Highway 224 

junction, 1/8 acre; Road 45 from Oz Quarry to Road 4520 junction, 1⁄2 acre. 

Zigzag Ranger District: Highway 26, Laurel Hill Quarry to Ski Bowl, 20 acres. 

All restrictions and regulations regarding the use of herbicides will be followed as stated in the 

Region 6 Environmental Impact Statement for Managing Competing and Unwanted Vegetation, 

its accompanying Mediated Agreement, A guide to Conducting Vegetation Management Projects 

in the Pacific Northwest Region, and the Environmental Assessment for the Management of 

Noxious Weeds on the Mt. Hood National Forest. 

Herbicides will be applied directly to target weeds. Application dates are weather dependent. All 

areas where herbicide is to be used will be posted prior, during and after application. 

Persons who are known to be or suspect that they are hypersensitive to herbicides may contact 

the Forest Service to determine the appropriate risk management measures. 

Questions regarding specific project areas, timing and treatment may be obtained by calling 

Duane Bishop at Zigzag Ranger District, (503) 622-3191 or Tom Forney at Oregon Department 

of Agriculture, (503) 986-4621. 

Appendix L-4 
APPENDIX M 

Oregon Guidelines for Timing of In-Water 

Work to Protect Fish and Wildlife Resources 
 
OREGON GUIDELINES

FOR

TIMING OF IN-WATER WORK

TO PROTECT FISH AND WILDLIFE RESOURCES

June, 2000

Purpose of Guidelines - The Oregon Department of Fish and Wildlife, (ODFW),

under its authority to manage Oregon’s fish and wildlife resources has updated the

following guidelines for timing of in-water work. The guidelines are to assist the

public in minimizing potential impacts to important fish, wildlife and habitat

resources.

“The guidelines are to assist

the public in minimizing

potential impacts...”.

Developing the Guidelines - The guidelines are based on ODFW district fish

biologists’ recommendations. Primary considerations were given to important fish

species including anadromous and other game fish and threatened, endangered, or

sensitive species (coded list of species included in the guidelines). Time periods were

established to avoid the vulnerable life stages of these fish including migration,

spawning and rearing. The preferred work period applies to the listed streams, unlisted

upstream tributaries, and associated reservoirs and lakes.

“The guidelines are based

on ODFW district fish

biologists’

recommendations”.

Using the Guidelines - These guidelines provide the public a way of planning in-water

work during periods of time that would have the least impact on important fish,

wildlife, and habitat resources. ODFW will use the guidelines as a basis for

commenting on planning and regulatory processes. There are some circumstances where

it may be appropriate to perform in-water work outside of the preferred work period

indicated in the guidelines. ODFW, on a project by project basis, may consider

variations in climate, location, and category of work that would allow more specific

in-water work timing recommendations. These more specific timing recommendations

will be made by the appropriate ODFW district office through the established planning

and regulatory processes.

“These guidelines provide

the public a way of planning

in-water work during

periods of time that would

have the least impact on

important fish, wildlife and

habitat resources”.

Modification of Guidelines - There may be limited situations where minor

modification of the timing guidelines is warranted. ODFW may consider new

information, the need for greater detail, or other factors that would generally improve

the quality and usefulness of these guidelines. ODFW through the appropriate district

office may modify or clarify timing guidelines within the district as needed. Statewide

updates to guidelines will occur on a periodic basis.

“ODFW through the

appropriate district office

may modify or clarify timing

guidelines within the district

as needed”.

Public Comments - A limited technical public review of these updated guidelines was

conducted. A few responses provided specific biological information and

recommendations for changing in-water work periods. Applicable ODFW districts

reevaluated their timing recommendations based on this public response. Other

comments concerned format and application of the timing guidelines. Some responses

stated that different types of in-water activities should have different timing guidelines.

ODFW recognizes there will be occasions that more specific timing guidelines may

need to be established for specific activities. The established planning and regulatory

processes can accommodate that need.

“A limited technical public

review of these updated

guidelines was conducted”.

Northwest Region

Appendix M-1
Northwest Region North Coast Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless

otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

North Coast Watershed District

Astoria Office - (503) 338-0106

Pacific

Columbia

Columbia River Estuary (Mouth to Tongue Pt.) November 1 - February 28

(MAR,SHL,CHF,CHS,SS,CO,STW,STS

,CT*)

Youngs River July 15 - September 30 (CO,STW *)

Young’s Bay Tributaries July 1 – September 15 (CO,CT,STW)

Wallooskee River June 1 - September 30 (CO,CT*)

Other Columbia R. Est. Tribs. (Mouth to Tongue Pt.) July 1 - September 15 (CHF,STW*)

Necanicum

Necanicum River & tributaries July 1 - September 15 (CO,CHF,STW*)

Necanicum and Neawanna Estuary November 1-February 15

(MAR,SHL,CO,CHF,STW)

Ecola Creek and Tributaries July 1-September 15 (CO,CT,STW)

Nehalem

Nehalem Bay November 1 - February 15

(MAR,SHL,CHS,CHF,CO,STW,*)

Lower Nehalem River (below Hwy 26) July 1 - September 15 (CHF*)

N. Fk. Nehalem River July 1 - September 15 (CHF,STW*)

Cook Creek July 1 - September 15 (CHF,STW*)

Salmonberry River August 15 - September 15 (CHS,STW*)

Other Lower Nehalem River Tributaries July 1 - September 15 (CHF,CO,STW*)

Upper Nehalem River (above Hwy 26) July 1 - August 31 (CHS,STW*)

Other North Coastal tributaries (Columbia R. to Nehalem) July 1 – September 15 (CO,CT*)

Coastal Lakes October 1-February 15 (CT)

Coastal Lake Tributaries July 1- September 15 (CT)

Tillamook Office - (503) 842-2741

Pacific

Tillamook

Tillamook Bay November 1 - February 15

(MAR,SHL,CHF,CHS,STW,CO,CS*)

Miami,Kilchis,Wilson,Trask,Tillamook Rivers & Tribs. July 1 - September 15

(CHF,CHS,STW,CO,CS*)

Other Tillamook Bay Tributaries July 1 – September 15 (CO,CT)

Netarts Bay November 1 - February 15

(MAR,SHL,CHF,STW,CO,CS*)

Sand Lake November 1 - February 15

(MAR,SHL,CHF,STW,CO,CS*)

Nestucca

Appendix M-2
Northwest Region North Coast Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless

otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

Nestucca Bay November 1 - February 15

(MAR,SHL,CHF,CHS,STW,CO,CS*)

Nestucca River & Tributaries July 1 - September 15

(CO,CHS,CHF,CS,STW*)

Little Nestucca River & Tributaries July 1 – September 15 (CO,CHS,CHF,CS,STW)

Neskowin Creek and Tributaries July 1 - September 15 (CO,CS,STW*)

Other North Coastal Tributaries (Nehalem to Neskowin Cr.) July 1 – September 15 (CO,CT)

Coastal Lakes October 1 – February 15 (CT)

Coastal lake Tributaries July 1 – September 15 (CT)

Newport Office - (541)-867-4741

Pacific

Salmon

Salmon River Estuary November 1 - February 15 (MAR,SHL*)

Salmon River July 1 - September 15 (CHF,CO,CS,STW,CT*)

Siletz

Siletz Bay November 1 - February 15 (MAR,SHL*)

Siletz River July 1 - August 31

(CHF,CHS,CO,CS,STW,STS,CT*)

Yaquina

Yaquina Bay November 1 - February 15 (MAR,SHL*)

Yaquina River July 1 - September 15 (CHF,CO,STW,CT*)

Alsea

Alsea Bay November 1 - February 15 (MAR,SHL*)

Alsea River July 1 - August 31 (CHF,CHS,CO,STW,CT*)

Yachats River July 1 - September 15 (CHF,CO,STW,CT*)

Siuslaw

Siuslaw Bay November 1 - February 15

(MAR,SHL,CHF,CO,STW,CT*)

Siuslaw River July 1 - September 15 ( CHF,CO,STW,CT*)

Other Coastal Tributaries July 1 - September 15 (CO,STW,CT*)

Coastal Lakes October 1 – February 15 (STW,CO,CT)

Coastal Lake Tributaries July 1 – September 15 (STW,CO,CT)

North Willamette Watershed District

Clackamas Office (503) 657-2000

Columbia

Columbia River ( Big Creek to Bonneville Dam) November 1 - February 28

(CHF,CHS,CHR,SS,CO,CS,STW,STS,

CTS*)

Columbia River ( Within District above Bonneville Dam) November 15 - March 15

(CHF,CHS,CHR,SS,CO,CS,STW,STS,

CTS*)

Columbia R. Tribs. (Big Creek to St. Helens) July 1 - September 15 (CHF,STW*)

Clatskanie River July 15 - September 15 (CHF,STW*)

Appendix M-3
Northwest Region North Willamette Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

 Willamette

Multnomah Channel (including Scappoose Bay) July 1 - October 31 & December 1 - January 31

(CHF,CHS,CO,STW,STS,CT,WW *)

Milton Cr. & Scappoose Cr. July 15 - August 31 (CO,STW,JUV,WW*)

Willamette River (mouth to Willamette Falls) July 1 - October 31 & December 1 - January 31

(CHF,CHS,CO,STW,STS,CT,WW *)

Columbia Slough June 15 - September 15 (JUV,WW)

Johnson

Johnson Creek (below Gresham) June 1 - August 31 (STW,CO,CT,CHF*)

Johnson Creek (above Gresham) July 15 - August 31 (STW,CO,CT,CHF*)

Johnson Cr. Tribs. July 15 - August 31 (CT,STW,CO*)

Kellogg Creek July 1 - September 30 (STW,CO,CT*)

Tryon Creek July 15 - September 30 (STW,CO,CT*)

Clackamas River July 15 - August 31

(CHF,CHS,STW,CO,STS,CT*)

Abernethy Creek July 15 - September 30 (CO,STW,CT*)

Other Willamette River tribs. July 1 – October 15 (CT*)

Willamette River (Will. Falls to Newberg ) June 1 - October 31 & December 1 - January 31

(CHS,STW*)

Tualatin

Tualatin River (below Scoggins Cr.) June 1 - September 30 (CO,STW,CT,WW*)

Tualatin River (above Scoggins Cr.) July 1 - September 30 (CO,STW,CT,WW*)

Tributaries July 1 - September 30 (CO,STW,CT,WW*)

Beaver Creek July 1 - September 30 (CT*)

Molalla/Pudding River

Molalla River (below Molalla) June 1 – September 30 (STW,CT*)

Other Molalla River Tributaries (below Molalla) June 1 - September 30 (CT*)

Molalla River (above Molalla) July 15 - August 31 (CHS,STW,CT,RB*)

N. Fk & M. Fk Molalla July 15 - August 31 (CHS,STW,CT,RB*)

Other Molalla River Tributaries (above Molalla) July 15 - September 30 (STW,CT*)

Pudding River June 1 - September 15 (CHS,STW,CT*)

Butte Creek July 15 - September 30 (STW,CT*)

Abiqua Creek July 15 - August 31 (CHS,STW,CT,RB*)

Silver Creek July 15 - September 30 (STW,CT*)

Other Pudding River Tributaries June 1 - September 30,STW,CT,RB*)

Other Willamette River tribs. July 1 – October 15 (CT*)

Willamette River (Newberg to Yamhill River) June 1 – September 30 (CHS,STW,CT,RB*)

Chehalem Creek July 1 - October 15 (CT*)

Yamhill River July 1 - October 15 (STW,CT*)

Other Willamette River tribs. July 1 – October 15 (CT*)

Fairview Cr.,Arata Cr., Salmon Cr. June 15 - September 15 (CT,WW*)

Sandy River July 15 - August 31 (CHS,CHF,CO,STW*)

Tanner Creek July 15 - August 15 (CHF,CHS,CO,STW*)

Columbia River Tributaries (St. Helens to Sandy River) July 15 - August 31 (CHF,CO,STW,CT *)

Columbia River Tributaries (Sandy River to Herman Cr.) July 15 - August 31 (CO,STW,STS,CT *)

Appendix M-4
Northwest Region South Willamette Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

South Willamette Watershed District

Corvallis Office - (541) 757-4186

Willamette

Willamette River (Yamhill River to McKenzie River) June 1 – September 30 (CHS,STW,CT,RB*)

Spring Valley Creek July 1 - September 30 (CT*)

Glenn Creek July 1 - September 30 (CT*)

Mill Creek June 1 – September 30 (STW,CT,RB*)

Rickreall Creek July 1 – September 30 (STW,CT*)

Luckiamute River July 1 - September 30 (STW,CT*)

Santiam 

Santiam River June 1 – September 30 (STW,CT*)

North Santiam River (below Big Cliff Dam ) July 15 - August 31 (CHS,STW,CT,RB*)

Stout Cr., Rock Cr., & Mad Cr. July 15 - September 30 (STW,CT,RB*)

Lt. N. Fk. Santiam River July 15 - August 31 (CHS,STW,CT,RB*)

Sinker, Elkhorn Cedar Creeks & tributaries July 15 - September 30 (STW,CT,RB*)

Other Tributaries June 1 - September 30 (CT*)

Other Santiam River Tributaries (below Big Cliff Dam) June 1 - September 30 (CT*)

North Santiam River (above Detroit Dam) June 1 - September 30 (K,CT,RB*)

Breitenbush River June 1 - September 30 (K,CT,RB*)

South Santiam River (below Foster Dam) June 1 - August 31 (CHS,CT,RB*)

Crabtree Cr., & Thomas Cr. July 15 - August 31 (CHS,STW,CT,RB*)

McDowell Cr., Wiley Cr. July 15 - September 30 (STW,CT*)

Other South Santiam River Tributaries (below Foster Dam) June 1 - September 30 ( CT*)

South Santiam River (above Foster Dam) July 15 - August 31 (CHS,STW,CT,RB*)

Middle Santiam River & Quartzville Creek June 1 - September 30 (K,CT,RB*)

Marys River July 1 - September 30 (CT*)

Long Tom River July 1 - September 30 ( CT*)

Other West Bank Will. R. Tribs. (Will. Falls to McKenzie R.) July 1 - September 30 (CT*)

Calapooia

Calapooia River (below Holley) June 1 - September 30 (CHS,STW,CT*)

Calapooia River (above Holley) July 15 - August 31 (CHS,STW,CT,RB*)

Other East Bank Will. R. Tribs. (Will. Falls to Harrisburg) June 1 - September 30 (CT*)

Springfield Office - (541) 726-3515

Willamette

Willamette River (above McKenzie River) June 1 - October 31 (CHS,RB*)

McKenzie

McKenzie River (below Blue River) July 1 - August 31 (CHS,STW,CT,RB*)

Tribs. McKenzie River (below Blue River) July 1 - October 15 (CT,RB*)

McKenzie River (above Blue River) July 1 - August 15 (CHS,BUT,CT,RB*)

Middle Fork Willamette

Middle Fork Willamette River (to Rattlesnake Cr) July 1 - August 31 (CHS,STW,CT,RB*)

Middle Fork Willamette river (Rattlesnake to Hills Cr. Res.) by specific arrangement (CHS,STW,CT,RB,OC*)

Fall Creek July 1 - August 31 (CHS,STW,CT,RB*)

Middle Fork Willamette River tributaries July 1 - October 15 (CT,RB*)

Middle Fork Willamette River (above Hills Creek Reservoir) July 1 - August 15 (CHS,BUT,CT,RB*)

Coast Fork Willamette

Appendix M-5
Northwest Region Upper Willamette District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

Coast Fork Willamette River June 1 - October 31 (CHS,RB*)

Row River (below Dorena Res.) June 1 - October 31 (CHS,RB*)

Row River (above Dorena Res.) July 1 - October 15 (CT,RB*)

Southwest Region

Umpqua Watershed District

Roseburg Office - (541) 440-3353

Pacific

Umpqua River

Umpqua Bay & Smith Est. November 1 - January 31

(MAR,SHL,CHS,CHF,CO,STW,STS,,C

T*)

Umpqua River (Scottsburg and above) July 1 - August 31

(CHS,CHF,CO,STW,STS,CT*)

Umpqua River Tribs. July 1 - September 15 (CHF,CO,STW,CT*)

North Umpqua

North Umpqua River (below Soda Springs Dam) by specific arrangement

(CHF,CHS,CO,STW,STS,CT*)

 Tribs. North Umpqua (below Soda Springs) July 1 - September 15 (CHS,CO,STW,STS,CT*)

North Umpqua River (above Soda Springs Dam) June 15 - October 15 (RB,BT,BR*)

South Umpqua

South Umpqua River July 1 - August 31(CHF,CHS,CO,STW,CT*)

South Umpqua Tribs. July 1 - September 15 ( CHF,CO,STW,CT*)

Charleston Office - (541) 888-5515

Pacific

Coos

Coos Bay and River (to Millicoma R./S. Coos R. confluence) October 1 - February 15

(MAR,SHL,JUV,CHF,CO,STW,CT *)

Millicoma River, S. Coos R. and tribs. July 1 – September 15 (CHF,CO,STW,CT,MD*)

Coquille

Coquille River Estuary (Mouth to Bear Creek) October 1 - February 15

(MAR,SHL,JUV,CHF,CO,STW,CT *)

Coquille River and tribs. (Bear Creek and above) July 1 - September 15 (CHF,CO,STW,CT*)

Other Coastal Tributaries July 1 – September 15 (CHF,CO,STW,CT*)

Coastal Lakes October 1 – February 15 (CO,STW,CT*)

Coastal Lake Tributaries July 1 - September 15 (CO,STW,CT*)

Rogue Watershed District

Gold Beach Office - (541) 247-7605

Pacific

Sixes/Coastal Tributaries

Estuaries (Floras Cr., Sixes R., below 101 bridge) October 1 - May 31 (JUV CHF*)

Appendix M-6
Southwest Region Rogue Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

Floras Creek July 15 - September 30 (CHF,CO,STW,CT*)

Sixes River July 15 - September 30 (CHF,CO,STW,CT*)

Elk

Elk River Estuary (below 101 bridge) October 1 - May 31 (JUV CHF*)

Elk River July 15 - September 30 (CHF,CO,STW,CT*)

Euchre/Coastal Tributaries

Euchre Creek Estuary October 1 - May 31 (JUV CHF*)

Euchre Creek July 15 - September 30 (CHF,CO,STW,CT*)

Hubbard Cr., Brush Cr., Mussel Cr. July 15 - October 31 (STW,CT*)

Rogue River

Rogue River Estuary October 1 - May 31 (JUV CHF*)

Rogue River (below Marial) May 1 - September 30 (CHF*)

 Rogue River Tributaries (below Marial) July 15 - September 30 (CHF,STW,CT*)

Hunter

Hunter Creek Estuary October 1 - May 31 (JUV CHF*)

Hunter Creek July 15 - September 30 (CHF,STW,CT*)

Pistol/Coastal Tributaries

Pistol River Estuary October 1 - May 31 (JUV CHF*)

Pistol River July 15 - September 30 (CHF,STW,CT*)

Chetco/Coastal Tributaries

Chetco River Estuary October 1 - May 31 (JUV CHF*)

Chetco River July 15 - September 30(CHF,STW,CT*)

Meyers Cr., Thomas Cr., & Whalehead Cr. July 15 - October 31 (STW,CT*)

Winchuck

Winchuck River Estuary October 1 - May 31 (JUV CHF*)

Winchuck River July 15 - September 30 (CHF,STW,CT*)

Other Coastal Tributaries July 15 - October 31 (CT*)

Central Point Office (541) 826-8774

Rogue

Rogue River (above Marial) June 15 - August 31 (CHS,STW*)

Illinois River June 15 - September 15 (CHF,STW*)

Applegate River July 1 - September 15 (CHF,STW*)

Other Rogue River Tributaries (above Marial). June 15 - September 15 (CHS,STW*)

Rogue River (above Lost Cr.) June 15 - September 15 (BT,CT*)

High Desert Region

Deschutes Watershed District

The Dalles Office - (541) 296-4628

Columbia

Columbia River (Within District Bonneville to John Day Dam) November 15 - March 15

(CHF,CHS,SS,CO,STW,STS*)

Columbia River Tributaries July 1 - September 30 (STW,CO,RB*)

Fifteenmile Creek July 1 - October 31 (STW,RB*)

Hood River

Appendix M-7
High Desert Region Mid-Columbia District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

Hood River July 15 - August 31 (CHF,CHS,CO,STS,STW*)

East Fork Hood River & Tribs. July 15 – August 31 (CHF,CO,STS,STW*)

Middle Fork Hood River & Tribs. July 15 – August 15 (STW,CHS,BUT*)

West Fork Hood River & Tribs. July 15 – August 15 (CHS,STS,STW*)

Deschutes

Deschutes River (below Pelton Dam) February 1 - March 15 (CHF,STS,RB*)

White River July 1 - October 31 (RB*)

Buckhollow Cr. July 1 - October 31 (STS,RB*)

Bakeoven Cr. July 1 - October 31 (STS,RB*)

Trout Cr. July 1 - October 31 (STS,RB*)

Bend Office - (541) 388-6363

Deschutes

Metolius

Metolius River by specific arrangement (K,RB,BR,BUT*)

Spring Creek July 1 - September 30 (K,RB*)

Lake Creek July 1 - September 30 (K,RB,BR*)

Deschutes River (Pelton Dam through Lake Billy Chinook) July 1 - September 30 ( RB,BR*)

Crooked River

Crooked River (below Prineville Dam) July 1 - October 31 (RT*)

Prineville Reservoir July 1 - October 31 (RT*)

Crooked River (above Prineville Dam) July 1 - October 31 (RT*)

N.Fk. Crooked River (above Big Summit Prairie) July 1 - September 30 (RT*)

Deschutes River (Lake Billy Chinook to Bend) July 1 - September 30 (RB,BR,BUT,K*)

Squaw Creek July 1 - October 15 (RB,BR,BUT*)

Tumalo July 1 - October 15 (RB,BR*)

Deschutes River (Bend-North Canal Dam to Benham Falls) July 1 - October 15 (RB,BR*)

Deschutes River (Benham Falls to Wickiup Dam) July 1 - October 15 ( RB,BR*)

Little Deschutes River July 1 - October 15 (RB,BR*)

Fall River July 1 - October 15 (RB,BR*)

Deschutes River (Wickiup Reservoir to Crane Prairie Dam) July 1 - August 31 (RB,BR,K *)

Deschutes River (Crane Prairie Reservoir to Little Lava Lake) July 1 - August 31 (RB,BT,K*)

Klamath Watershed District

Klamath Falls Office - (541) 883-5732

Klamath

Klamath River (below Keno) July 1 - March 31 ( RB*)

Cottonwood Creek June 15 – September 15 (STW*)

Jenny Creek July 1 – January 31 (SCRT,JCS*)

Klamath River (above Keno) July 1 – February 1 (SNS,BCHUB,RB*)

Lost River above Bonanza July 1 – February 1 (RT,SNS)

Lost River below Bonanza July 1 - March 31 (RT*)

Williamson River August 1 - September 30

(RB,BT,BR,RT,SNS,LRS,KLS*)

Appendix M-8
High Desert Region Klamath Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

Sprague River August 1 - September 30

(BUT,LRS,SNS,RB,BT,BR *)

Sycan River August 1 - September 30

(RB,BT,BR,BUT,LRS,SNS*)

Wood River August 1 - September 30 (RB,BR,BUT,SNS*)

Sevenmile Creek August 1 - September 30 (RB,BR*)

Klamath Lake and Agency Lake July 1 - January 31 (RB,LRS,SNS,BCHUB*)

Silver Lake tributaries July 1 - September 15 (RT,BT*)

Summer Lake July 1 - September 15 ( *)

Chewaucan River July 1 - September 15 (RT*)

Goose Lake tributaries July 1 - September 15

(GRT,GLAM,GSUC,GCB,PRCH,PSCL

*)

Warner Valley tributaries July 1 - September 15 (WSUC,FD*)

Malheur Watershed District

Hines Office - (541) 573-6582

Columbia

Snake

Snake River (Malhuer County) Open

Malheur

Malheur River (below Namorf Dam) Open

Willow Cr. (below Brogan Cyn.) Open

Willow Cr. (above Brogan Cyn) October 1 - March 31 (RB,RT*)

Cottonwood, Cr., Squaw Cr. October 1 - March 31 (RB,RT*)

Other Tributaries October 1 - March 31 (RB,RT*)

Malheur River (Namorf Dam to Dreswsey Valley ) November 1 - March 31 (RT*)

North Fork Malheur (mouth to Beulah Res.) November 1 - March 31 (RT,RB*)

North Fork Malheur (above Beulah Res.) July 1 - August 31 (BUT,RT,BT*)

South Fork Malheur October 1 - March 31 (RT*)

Malheur River (above Drewsey Valley) July 1 - August 31 (BUT,RT,BT*)

Owyhee River

Owyhee River (below dam) November 1 - March 31 (RB,BT*)

Owyhee River (above dam) October 1 - March 31 (RB,RT*)

Succor Creek October 1 - March 31 (RT*)

Silvies River (above 5mi dam) October 1 - March 31 (RT,*)

Silver Creek (above Hwy 45) October 1 - March 31 (RT*)

Donner Blitzen River (Steen Mtns) October 1 - March 31 (RT*)

Alvord Basin October 1 - March 31 (LCT,AC*)

Catlow Valley tributaries October 1 - March 31 (LCT,CTC,RT*)

Trout Creek Mountains streams October 1 - March 31 (LCT,AC,RB,CT*)

Quinn River October 1 - March 31 (LCT,RB,CT*)

Appendix M-9
Northeast Region John Day Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

Northeast Region

John Day Watershed District

John Day Office - (541) 575-1167

Columbia River

Lower John Day

John Day River (below John Day) July 15 - August 31 (STS,RT*)

Rock Creek

Rock Creek (Gilliam Co.) July 15 - September 30 (STS,RT*)

North Fork John Day

North Fork John Day River (below U.S. 395) July 15 - August 31 (STS,RT*)

Middle Fork John Day

Middle Fork John Day River (below US 395) July 15 - August 31 (STS,RT*)

Middle Fork John Day River (above US 395) July 15 - August 15 (CHS,STS,RT,BUT*)

North Fork John Day River (above U.S. 395) July 15 - August 15 (CHS,STS,BUT*)

Upper John Day

South Fork John Day River

South Fork John Day River July 15 - August 31 (STS,RT*)

John Day River (above John Day) July 15 - August 15 (CHS,STS,BUT,RT,CT*)

Canyon Creek July 15 - August 31 (STS,RB,CT*)

Pendleton Office - (541) 276-2344

Columbia

Columbia River (John Day Dam upstream) December 1 - March 31

(CHF,CHS,SS,CO,STS*)

Willow Creek July 1 - December 31 (RT*)

Umatilla

Umatilla River (below Pendleton) July 15 - October 15 (CHF,CHS,CO,STS*)

Butter Creek July 1 - December 31 (RT*)

Umatilla River (above Pendleton) July 1 - August 15 (CHS,CHF,STS,RT*)

Birch Creek July 1 - October 31 (STS,RT*)

McKay Creek

McKay Creek (below reservoir) November 1 - March 31 (CHF,CHS,CO,STS*)

McKay Creek (above reservoir) July 1 - December 31 (RT*)

Wildhorse Creek July 1 - October 31 (CHF,CHS,CO,STS,RT*)

Meacham Creek July 1 - August 15 (CHS,STS,RT,BUT*)

Walla Walla

Walla Walla River (below Harris Park) July 1 - October 31 (STS,RT,BUT*)

Mill Creek July 1 - October 31 (STS,RT,BUT*)

Walla Walla River (above Harris Park) July 1 - August 15 (STS,RT,BUT*)

Grande Ronde Watershed District

Enterprise Office - (541) 426-3279

Columbia

Appendix M-10
Northeast Region Wallowa District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

Snake River (state line to Hells Canyon Dam) July 1 - October 15 (CHF,CHS,SS,STS*)

Grande Ronde

Grande Ronde River (below Wallowa River) July 1 - September 15 (CHF,STS*)

Wenaha River July 1 - August 15 (CHS,STS,BUT*)

Joseph Creek July 1 - March 31 (STS*)

Wallowa River July 15 - August 15 (CHS,STS,RB,BT,BUT *)

Imnaha River (above Big Sheep Creek) July 15 - August 15 (CHS,STS,BUT*)

Imnaha River (below Big Sheep Creek) July 1 – October 15 (CHF,STS*)

La Grande Office - (541) 963-2138

Columbia

Snake

Grande Ronde

Grande Ronde River (Wallowa River to Highway 244 Bridge) July 1 - October 15 (CHS,STS,RB,BUT*)

Minam River July 1 – August 15 (CHS,STS,RB,BUT*)

Lookingglass Creek July 1 - August 15 (CHS,STS,RB,BUT*)

Catherine Creek

Catherine Creek (to, and including Little Creek) July 1 - October 15 (CHS,STS,RB,BUT*)

Catherine Creek (above Little Creek) July 1 – August 15 (CHS,STS,RB,BUT*)

Grande Ronde River (above highway 244 bridge) July 1 - July 31 (CHS,STS,RB,BUT*)

Snake River Reservoir July 1 - November 30 (WW*)

Snake River Reservoir Tributaries July 1 - October 31 (RB*)

Burnt River July 1 - October 31 (RB,BT*)

Pine Creek July 1 – August 31 (RB,BUT *)

Powder River (mouth to Phillips Reservoir) July 1 - October 31 (RB*)

Anthony Creek July 1 – August 31 (RB,BUT*)

North Powder R. (above Dutch Flat Cr.) July 1 – August 31 (RB,BUT*)

Wolf Creek (above Wolf Creek Res.) July 1 – August 31 (RB,BUT*)

Big Muddy Creek (above Foothill Rd.) July 1 – August 31 (RB,BUT*)

Pine Creek (above North Fork Pine Cr.) July 1 – August 31 (RB,BUT*)

Salmon Creek (above Pocahontas Road) July 1 – August 31 (RB,BUT*)

Powder River (above Phillips Reservoir) July 1 – August 31 (RB,BUT*)

Deer Creek (above Phillips Reservoir) July 1 – August 31 (RB,BUT*)

Appendix M-11
1 Work period is established for named stream, all upstream tributaries, and associated lakes within the

watershed unless otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources -- June, 2000

* Coded fish species defined below provide the primary basis for timing guidelines. The species list should be considered

general information and is not necessarily comprehensive nor accurate.

AC - Alford chub

BCHUB – blue chub

BR - brown trout

BT - brook trout

BUT - bull trout

CR - Crappie

CHF - chinook salmon, fall

CHR - chinook salmon, summer

CHS - chinook salmon, spring

CO - coho salmon

CS - chum salmon

CT - cutthroat trout (includes sea run)

CTC - Catlow tui chub

GCB - goose lake chub

GLAM - goose lake lamprey

GSUC - goose lake sucker

JCRT – Jenny Creek red band trout

JCS – Jenny Creek sucker

JUV - juvenile salmonids

K - kokanee

KLS – Klamath largescale sucker

LCT - Lahontan cutthroat trout

LRS – Lost River sucker

MAR - various marine species of fish

MD – Millicoma Dace

MMS - Malheur mottled sculpin

PRCH - pit roach

PSCL - pit sculpin

RB - rainbow trout

RT - red band trout

SHL - various marine shell fish

SNS shortnose sucker

SS - sockeye salmon

STS - steelhead summer

STW - steelhead winter

WW - various warm water game fish

Appendix M-12
APPENDIX N 

Inventory and Monitoring Framework 
 
Site-Specific Invasive Plant Treatments 

APPENDIX N: Inventory and Monitoring Framework 

Taken from Appendix M in the Invasive Plant FEIS (USDA Forest Service, 2005a), 

modified by Invasive Plant ROD (USDA Forest Service, 2005b) 

It is assumed every Forest in Region Six has an invasive plants coordinator and is maintaining an 

up-to-date invasive plant inventory using NRIS/Terra, the nationally accepted protocol. The 

inventory will be the primary means to plan and prioritize treatments. The inventory will be used 

as the main vehicle for tracking treatment effectiveness both regionally and on a site-specific 

basis. 

In addition to the monitoring that is already required under various Forest Plans, this inventory 

and monitoring plan framework is part of all action alternatives in this Environmental Impact 

Statement (EIS). The framework would guide the development of detailed monitoring plans at 

the site-specific project scale. Invasive plant treatment and restoration actions are likely to be 

complex, involve multiple land ownerships and will take years to implement, due to the nature of 

invasive plant problems. It is likely that a site will be treated multiple times over the years. 

Tracking these efforts and subsequent progress will be crucial to determining success. 

A good monitoring program will be well thought out and have a high probability of detecting 

change in the resource being monitored (NPS, 2002). The Field Guide to Invasive Plant 

Inventory, Monitoring and Mapping (USDA FS, 2002) has been developed to guide monitoring 

efforts in conjunction with NRIS/Terra. It suggests a monitoring regime may start with annual 

monitoring for the first 3-5 years, decreasing in frequency to every other year for the next 5-10 

years and further decreasing monitoring frequency to every 3 years for the next ten years until 

the seed source has been exhausted (i.e. no new germination taking place). 

Monitoring regimes may vary in time and space depending on the species; for example, those that 

reproduce vegetatively may require a longer span of annual monitoring. The monitoring 

categories described in this framework (implementation/compliance, and effectiveness (of 

treatments in meeting project objectives, and effectiveness of protection measures) can be used 

to implement a long-term adaptive management strategy. By implementing an adaptive 

management approach, managers will identify and respond to changing conditions and new 

information on an ongoing basis, and assess the need to make changes to treatment and 

restoration strategies. 

Implementation/Compliance Monitoring

Implementation/compliance monitoring answers the question, “Did we do what we said we 

would do?” This question needs to be answered on a Regional scale, because adaptive 

management strategies require determination that actions are taking place as described in the 

Invasive Plants EIS. 

Appendix N-1 
Final Environmental Impact Statement 

If an action alternative is selected, each Forest Supervisor will be directed to assess compliance 

with the Invasive Plant Program EIS Record of Decision as a part of Forest Plan Implementation 

monitoring. Regional Office staff will periodically aggregate this information as a part of 

program oversight. 

An implementation/compliance checklist database, such as the Pacfish/Infish Biological Opinion 

Implementation Monitoring module database for the eastside, could be used as a template to 

input and analyze implementation/compliance monitoring data. The use of a consistent reporting 

format will allow for aggregation of information at various scales. Such as system will be used to 

determine patterns of compliance. 

Listed Species — An implementation/compliance monitoring database would track invasive 

plant treatment projects that are the subject of Section 7 consultations under the Endangered 

Species Act (ESA), generate annual reporting of compliance for use by the Services (NOAA 

Fisheries, U.S. Fish and Wildlife) and Forest Service (FS), and allow for common reporting of 

data on individual projects. As a minimum, on each project requiring consultation, reporting will 

be required on compliance with Standards 16, 18, 19, and 20 in the Invasive Plant EIS. 

Additional standards could be included, as appropriate, for the individual ecoregions, Forests, or 

projects. For example, Northwest Forest Plan (NWFP) riparian standards relevant to herbicide 

use or invasive plant control projects could be included in the database for those Forests in the 

NWFP-covered areas. 

Effectiveness Monitoring

Effectiveness monitoring, relative to project objectives, answers the question, “Were treatment 

and restoration projects effective?” This question could be answered on either a regional or a 

project-level scale. Invasive plant infestations require pre-project inventories to determine how, 

when, and where treatments are to be applied, and post-treatment monitoring to assess the 

effectiveness (treatment) in meeting project objectives (e.g. restoring structure and composition 

of native vegetation). 

A goal of the Effectiveness Monitoring component in the Regional Invasive Plant Program is to 

answer the following questions: 

• Have the number of new invasive plant infestations increased or decreased in the 

Region or at the project level? 

• What changes in distribution, amount and proportion of invasive plant infestations 

have resulted due to treatment activities in the region or at the project level? 

• Has the infestation size for a targeted invasive plant species been reduced regionally 

or at the project level? 

• Which treatment methods, separate or in combination, are most successful for 

specific invasive species? 

• Which treatment methods have not been successful for specific invasive species? 

Appendix N-2 
Site-Specific Invasive Plant Treatments 

The nation-wide NRIS/Terra database, and the upcoming FACTS database, provide common 

reporting formats to input information and provide a mechanism for addressing the above 

questions. In addition, current long-term ecological monitoring networks will assist the FS in 

determining trends of invasive plant infestations at the Regional level. 

The NRIS/Terra database could be sorted to answer the above questions because it tracks size 

and species of infestations as well as treatment methods. The Forest Inventory and Analysis 

Network (FIA) or the Forest Health Monitoring plots associated with the FIA network could be 

used to follow invasion trends. Such networks could be used to track trends in the spread or 

reduction in spread of the more dominant invasive plants in the region. Monitoring programs 

developed at the Forest level would answer more project specific questions. 

Listed Species - Monitoring that addresses the effectiveness of various measures designed to 

reduce potential adverse effects from the project, including standards in the EIS, “project design 

criteria”, “design features”, and “protection measures” may also need to be conducted. This type 

of monitoring will only be required for a representative sample of invasive plant treatment 

projects that pose a “high risk” to federally listed species. “High risk” projects are defined as 

projects with the potential to affect listed species, in the following situations: 

• Any project involving aerial application of herbicide. 

• Projects involving the use of heavy equipment or broadcast application of herbicide (e.g. 

boom spray or backpack spraying that is not limited to spot sprays) that occur in 1) 

riparian areas (as defined in NWFP, Pacfish, or Infish, as applicable), ditches or water 

corridors connected to habitat for listed fish; or, 2) proximity to federally listed plants or 

butterfly habitat. 

For the purposes of determining the need for protection measure effectiveness monitoring, 

invasive plant treatment methods that are not considered “high risk” can include, but are not 

limited to, the following: 

• Broadcast application of herbicide and use of heavy equipment that occurs outside of, 1) 

riparian areas, ditches or water corridors connected to water bodies, or, 2) areas in 

proximity to federally listed plants or butterfly habitat. 

• Manual methods including hand-pulling, grubbing, stabbing, pruning, cutting, etc. 

• Mechanical methods using small equipment like chainsaws, or equipment rarely used 

and not often in proximity to listed fish habitat, like flamers, foamers, hot steam, etc. 

• Prescribed fire used expressly for invasive plant control and which occurs outside of 

riparian areas or habitat for federally listed plants or butterflies. 

Appendix N-3 
Final Environmental Impact Statement 

• Herbicide applications using spot spray (used with a shield near listed plant locations) 

with a backpack sprayer, cut stump, injection, wicking wiping, basal bark applications, or 

other highly selective methods. 

• Minor uses of fertilizer to encourage native plant competition or growth. 

• Biological controls used in habitat areas for terrestrial wildlife or fish. Use in proximity 

to listed plants or butterflies should be evaluated on a case-by-case basis. 

• Broadcast applications (except aerial) using clopyralid, imazapic, and metsulfuron 

methyl in proximity to habitat for listed fish or listed terrestrial wildlife. 

A collection of several of these low risk projects in close proximity to each other and in 

proximity to habitat for listed species may constitute a “high risk” project, but this should be 

evaluated on a case-by-case basis. 

Monitoring for “high risk” invasive plant treatments that may affect ESA-listed species or 

designated critical habitat should determine if standards and/or protection measures were 

effective at reducing potential effect pathways (e.g. disturbance, sedimentation, exposure to 

herbicides) and results should be applicable elsewhere. Unique, individual monitoring efforts and 

protocols have not provided information that is applicable to other areas or projects. Therefore, a 

Regional approach is outlined in this framework that will help address the needs for protection 

measure effectiveness at a broader scale. The regional approach will be developed in 

consultation with other agencies, including but not limited to National Marine Fisheries Service 

and U. S. Fish and Wildlife Service. 

For example, Japanese knotweed is a serious invader of riparian areas and has the potential to alter 

ecosystems upon which listed salmon depend. The Region may have several Japanese knotweed 

treatment projects over the next several years and each one may have the potential to adversely 

affect listed salmon or designated critical habitat if adequate measures are not part of the 

treatment plan or are not complied with during implementation. Designing consistent monitoring 

protocol will allow a more efficient and effective evaluation of the project protection measures. 

To meet the objective of being able to evaluate standards and measures applied at the Regional, 

sub-Regional, and project level for protection of ESA-listed species and/or designated critical 

habitat in “high risk” projects, an interagency monitoring protocol and reporting schedule will 

be developed by 2007. The expectation being that this protocol would be applied to high risk 

projects to determine the effectiveness of Regional EIS standards, and additional standards or 

protection measures applied at finer scales, in reducing potential effect pathways (e.g. 

disturbance, sedimentation, exposure to herbicides, etc.) for listed species. 

Appendix N-4 
Site-Specific Invasive Plant Treatments 

In the interim, information obtained from implementation/compliance monitoring reports for 

“high risk” projects will be reviewed in 2005 and 2006 to inform the development of a consistent 

monitoring protocol for ensuring that standards and protection measures were effective. This 2-3 

year lag time, before protocol is developed and effectiveness monitoring is implemented, does 

not apply to aerial application of herbicides. All projects with aerial applied herbicide will 

include a monitoring plan to assess the effectiveness of measures in protecting ESA-listed 

species and/or designated critical habitat. 

Until a Regional, interagency effectiveness monitoring protocol for ESA-listed species and/or 

designated critical habitat is developed (2007), the need for effectiveness monitoring on “high 

risk” projects will be evaluated by Level 1 or other interagency technical teams during Section 7 

consultation. 

Recommendations for additional effectiveness monitoring beyond that described in this 

framework will require that Level 2 or other appropriate interagency management team agree to 

the recommendations of the technical or Level 1 team for the project. This process will help lead 

the Region toward efficient and reliable data collection and allow statistical analysis of the data 

gathered. 

References

USFS (U.S. Forest Service). 2001. Invasive Plant Management Decisions and Environmental 

Analysis. USDA Forest Service 

USFS (U.S. Forest Service). 2002. Field Guide – Invasive Plant Inventory, Monitoring and 

Mapping Protocol. USDA Forest Service. 

NPS (National Park Service). 2002. Invasive Plants Inventory and Monitoring Guidelines, 

National Park Service. 

Appendix N-5 
 
APPENDIX O 

Existing Conditions Characteristics 
 
Site-Speci

APPENDIX O: Existing Conditions Characteristics Summary of existing conditions at each treatment area, including habitat, elevation, slope, soil information, precipitatfauna, flora, recreation uses, and special uses. Table continued with more characteristics on page O-19. Information c

GIS layers, maintained in the Mt. Hood National Forest and Columbia River Gorge National Scenic Area, Geographi

library (http://www.fs.fed.us/r6/data-library/gis/). 

Key for table: 

SRI Soil Resource Inventory NWFP Northwest Forest Plan TES Threatened, Endangered, or Sensitive Species 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation (inch/year) 

Min. 

To W

(f

22-01 

Hardwood 

riparian forest & 

wetlands 

24.6 0-22 2 

Lahar Sauvie silt loam; Flat 

(0% slope) 

40 5

22-05 Open fields 379.3 1-52 22 

Wyeth 

gravelly loam 

(0-10% 

slope) 

80 35

22-07 Hardwood riparian forest 79.2 0-8 4 

Sandy 

Xerofluvents; 

Flat (0% 

slope) 

35 5

22-08 Restored rock 

quarry 

495.3 0-60 21 

Rock; No 

organic 

except small 

area (0-90% 

slope) 

30 5

22-11 Open fields / Oak forest 657.9 0-59 12 Bodell cobbly loam (2-20% slope) 20 5

1 GIS data on SRI Code is not available for the Scenic Area. 

Appendix O-1 
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

22-12 Open fields / Oak forest 760.5 0-34 13 

Bodell cobbly 

loam (5-45% 

slope); 

Skyline 

complex (0-

20 % slope) 

15 10

22-17 Active hay fields 612.3 1-60 11 

Loam, silt 

loam (0-20% 

slope) 

50 10

61-002 Coniferous forest 3360.0 1-44 13 161 Fine sandy loams & loams 45 0 61-003 Coniferous forest 2720.0 1-63 24 154 Fine sandy loams & loams 35 0 61-005 Coniferous forest 3280.0 2-40 16 161 Fine sandy loams & loams 35 3261-006 Coniferous forest 3360.0 0-34 11 161 Fine sandy loams & loams 35 0 61-007 

Rocky with 

minimum 

vegetation 

potential 

3600.0 3-33 19 161 

Fine sandy 

loams & 

loams 

40 0 

61-009 Coniferous forest 3040.0 2-53 18 156 Loams & silt loams 25 0 61-017 Coniferous forest 3520.0 1-52 17 156 Loams & silt loams 30 0 

Appendix O-2 
Site-Speci

Appendix O-3 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

61-018 Coniferous forest 3280.0 1-45 20 154 Fine sandy loams & loams 25 761-019 Administrative or agricultural 2640.0 0-78 17 156 Loams & silt loams 20 0 61-020 

Non-vegetated 

(<10%

vegetation) 

3040.0 15-16 15 156 Loams & silt loams 20 34

61-021 Coniferous forest 3120.0 3-38 15 352 Silt loams & heavy silt loams 25 0 61-022 Coniferous forest 3880.0 8-20 13 351 Silt loams & heavy silt loams 30 0 61-023 

Non-vegetated 

(<10%

vegetation) 

2760.0 7-39 21 350 

Silt loams & 

heavy silt 

loams 

20 2

61-024 Coniferous forest 2640.0 2-31 17 157 Loams & silt loams 20 1561-025 Coniferous forest 3200.0 3-30 12 352 Silt loams & heavy silt loams 40 0 61-026 Coniferous forest 2960.0 4-34 13 156 Loams & silt loams 25 0 61-027 Coniferous forest 2360.0 1-8 3 153-8 

Fine sandy 

loams & 

loams to dry 

meadows 

20 30

61-028 Coniferous forest 2480.0 0-25 11 156 Loams & silt loams 20 0 61-029 Coniferous forest 2880.0 1-43 13 352 Silt loams & heavy silt loams 30 0 
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

61-030 Coniferous forest 3460.0 9-12 11 350 Silt loams & heavy silt loams 30 2161-034 Coniferous forest 2400.0 1-26 7 152 Find sandy loams & silt loams 20 961-036 Coniferous forest 2440.0 4-14 8 156 Loams & silt loams 20 1861-039 Coniferous forest 3360.0 6-27 15 352 Silt loams & heavy silt loams 30 0 61-040 Coniferous forest 3440.0 6-19 11 352 Silt loams & heavy silt loams 30 0 61-041 Coniferous forest 3280.0 1-30 15 352 Silt loams & heavy silt loams 30 0 61-042 Coniferous forest 3120.0 3-27 11 352 Silt loams & heavy silt loams 30 0 61-043 Coniferous forest 3280.0 2-18 7 352 Silt loams & heavy silt loams 35 0 61-044 Coniferous forest 3160.0 3-13 6 352 Silt loams & heavy silt loams 25 461-045 Shrubland 3200.0 3-14 6 352 

Silt loams & 

heavy silt 

loams 

25 16

61-046 Coniferous forest 3160.0 7-16 11 352 Silt loams & heavy silt loams 25 9 61-047 Wet forblands; Forb meadow 3160.0 4-8 5 8 Dry meadows 25 161-048 Coniferous forest 3240.0 2-24 9 352 Silt loams & heavy silt loams 25 10

Appendix O-4 
Site-Speci

Appendix O-5 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

61-049 Coniferous forest 3080.0 4-20 12 351 Silt loams & heavy silt loams 25 161-050 Coniferous forest 3280.0 2-27 12 352 Silt loams & heavy silt loams 25 2061-051 Coniferous forest 2920.0 7-7 7 352 Silt loams & heavy silt loams 25 5861-053 Coniferous forest 3240.0 7-12 9 352 Silt loams & heavy silt loams 25 0 61-055 Bunchgrass vegetation 3240.0 2-17 9 352 Silt loams & heavy silt loams 25 1161-057 Coniferous forest 3400.0 2-3 2 352 Silt loams & heavy silt loams 25 2461-058 Coniferous forest 3200.0 3-7 4 352 Silt loams & heavy silt loams 25 3061-059 Coniferous forest 3160.0 2-23 10 352 Silt loams & heavy silt loams 25 0 61-062 Coniferous forest 3040.0 1-20 11 352 Silt loams & heavy silt loams 25 0 61-064 Coniferous forest 3000.0 16-16 16 352 Silt loams & heavy silt loams 25 0 61-065 Coniferous forest 3040.0 2-24 18 352 Silt loams & heavy silt loams 25 0 61-066 Coniferous forest 3160.0 2-15 7 352 Silt loams & heavy silt loams 25 2361-071 Coniferous forest 3280.0 4-32 19 350 Silt loams & heavy silt loams 30 0 
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

61-073 Coniferous forest 3000.0 0-21 12 350 Silt loams & heavy silt loams 25 0 61-074 Coniferous forest 3400.0 4-29 12 352 Silt loams & heavy silt loams 25 1061-075 Coniferous forest 3000.0 1-17 7 352 Silt loams & heavy silt loams 25 0 61-076 Coniferous forest 3040.0 3-13 8 352 Silt loams & heavy silt loams 25 0 61-077 Coniferous forest 2960.0 2-29 9 352 Silt loams & heavy silt loams 25 3961-078 Coniferous forest 3240.0 1-20 9 352 Silt loams & heavy silt loams 25 161-079 Coniferous forest 3240.0 0-15 6 352 Silt loams & heavy silt loams 25 0 61-080 Coniferous forest 3160.0 1-24 9 352 Silt loams & heavy silt loams 25 3861-081 Coniferous forest 3280.0 4-10 7 352 Silt loams & heavy silt loams 25 5761-082 Coniferous forest 2880.0 18-19 18 350 Silt loams & heavy silt loams 25 0 61-083 Coniferous forest 3088.0 1-26 14 352 Silt loams & heavy silt loams 25 0 

Appendix O-6 
Site-Speci

Appendix O-7 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

61-084 Coniferous forest 3360.0 5-59 37 354-7 

Gravelly 

loamy fine 

sands &

loamy fine 

sands with 

igneous rock 

outcrop 

40 0 

61-085 Coniferous forest 3000.0 3-48 18 156 Loams & silt loams 25 0 61-086 Coniferous forest 3000.0 0-23 8 352 Silt loams & heavy silt loams 25 0 61-087 Coniferous forest 3240.0 0-20 9 352 Silt loams & heavy silt loams 25 0 61-088 Coniferous forest 3360.0 1-29 14 161 Fine sandy loams & loams 35 1061-089 Coniferous forest 3280.0 0-57 14 156 Loams & silt loams 25 2261-090 Coniferous forest 3520.0 3-4 4 352 Silt loams & heavy silt loams 45 0 61-091 Administrative or agricultural 3320.0 9-20 14 352 Silt loams & heavy silt loams 40 1061-092 Coniferous forest 3520.0 7-15 11 352 Silt loams & heavy silt loams 25 661-093 Coniferous forest 3440.0 2-24 8 352 Silt loams & heavy silt loams 25 2061-095 Coniferous forest 3814.2 1-36 11 156 Loams & silt loams 80 65-001 Coniferous forest 1950.0 1-26 11 304 Gravelly & cobbly loams 60 2
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

65-002 Coniferous forest 1982.8 4-100 38 201-7 

Cobbly & 

gravelly 

loams with 

igneous rock 

outcrop 

90 0 

65-003 Coniferous forest 3600.0 2-56 28 323 Gravelly silt loams 60 0 65-005 Coniferous forest 0-0 100 Heavy loam to silty clay loam 60 1565-006 Coniferous forest 1450.0 6-6 6 100 Heavy loam to silty clay loam 60 565-007 Coniferous forest 2600.0 8-26 18 317 Cobbly loams 90 5065-008 Administrative or agricultural 1450.0 14-14 14 100 Heavy loam to silty clay loam 60 5 65-009 Coniferous forest 1800.0 17-43 32 102P 60 2265-010 Coniferous forest 2800.0 1-23 11 304 Gravelly & cobbly loams 60 1765-011 Administrative or agricultural 1500.0 15-31 23 100G 60 2065-012 Coniferous forest 3100.0 7-61 33 325-6 

Gravelly silt 

loams with 

unvegetate

d

talus & 

rubbleland 

120 0 

65-013 Coniferous forest 3200.0 6-70 33 322 

Gravelly 

loams & 

gravelly silt 

loams 

90 0 

65-014 Coniferous forest 3800.0 10-41 22 305D 70 7565-015 Administrative or agricultural 2000.0 2-20 7 3 Wet meadows 60 0 65-016 Coniferous forest 3800.0 19-29 22 305D 70 80

Appendix O-8 
Site-Speci

Appendix O-9 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

65-017 Coniferous forest 1600.0 22-88 52 7-13 

Igneous rock 

outcrop with 

felsenmeer 

slopes 

60 12

65-018 Administrative or agricultural 1500.0 5-7 6 100G 60 2065-019 Running water 800.0 0-79 16 11 Alluvial bottomlands 70 265-020 Coniferous forest 907.9 0-147 34 11 Alluvial bottomlands 80 0 65-021 Coniferous forest 1450.0 8-19 12 100 Heavy loam to silty clay loam 60 0 65-022 Coniferous forest 1500.0 12-41 22 100 Heavy loam to silty clay loam 10 2065-023 Coniferous forest 2453.8 1-68 17 306 Loams 80 0 65-024 Coniferous forest 1450.0 1-17 5 100G 60 365-025 Administrative or agricultural 1450.0 1-12 5 100G 10 0 65-026 Coniferous forest 2101.0 3-14 6 100 Heavy loam to silty clay loam 60 0 65-027 Coniferous forest 2159.6 1-14 7 100 Heavy loam to silty clay loam 60 0 65-028 Coniferous forest 1728.8 19-29 23 2 

Unstable 

sideslopes 

adjacent to 

major 

drainageways

60 10

65-029 Coniferous forest 1800.0 3-36 17 2 

Unstable 

sideslopes 

adjacent to 

major 

drainageways

70 4
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

65-030 Coniferous forest 1977.5 10-45 27 102 Heavy loam to silty clay loam 70 1065-031 Coniferous forest 2000.0 1-10 7 100 Heavy loam to silty clay loam 70 0 65-032 Coniferous forest 3400.0 17-37 27 327 Loams & gravelly silt loams 70 3565-033 Coniferous forest 3000.0 6-41 16 327 Loams & gravelly silt loams 70 1065-034 Coniferous forest 3227.1 5-31 17 304 Gravelly & cobbly loams 60 2365-035 Coniferous forest 3800.0 8-15 11 304 Gravelly & cobbly loams 60 2065-036 Coniferous forest 3200.0 23-38 29 317 Cobbly loams 120 0 65-037 Coniferous forest 3197.0 12-12 12 330 Stony loams 60 565-038 Coniferous forest 2308.2 28-52 39 6-13 

Unvegetated 

talus & 

rubbleland 

with 

felsenmeer 

slopes 

60 15

65-039 Coniferous forest 3200.0 13-13 13 323 Gravelly silt loams 60 565-040 Coniferous forest 4100.0 5-6 6 304X 70 1565-041 Coniferous forest 1800.0 10-76 31 2 

Unstable 

sideslopes 

adjacent to 

major 

drainageways

70 2

65-042 Coniferous forest 2400.0 9-30 19 306 Loams 60 2065-043 Coniferous forest 3200.0 7-31 17 302 Cobbly sandy loams 70 0 

Appendix O-10 
Site-Speci

Appendix O-11 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

65-044 Coniferous forest 3200.0 7-37 16 302 Cobbly sandy loams 80 0 65-045 Coniferous forest 2200.0 2-2 2 500 

Very gravelly loams & very 

stony silt 

loams 

60 78

65-046 Coniferous forest 3560.0 5-18 11 302 Cobbly sandy loams 80 0 66-001 Coniferous forest 5000.0 3-33 24 335 Sandy loams & silt loams 70 3066-003 Coniferous forest 3700.0 3-64 24 380 Gravelly loams 100 1566-004 Coniferous forest 3600.0 31-93 52 13-12 Felsenmeer slopes with wet talus 100 0 66-005 Coniferous forest 4240.0 1-60 29 345 Very gravelly loams 100 0 66-006 Coniferous forest 2800.0 1-74 31 374 Gravelly & cobbly loams 90 0 66-007 Coniferous forest 2200.0 0-74 22 378 Stony loams & cobbly loams 90 0 66-008 Administrative or agricultural 4000.0 1-99 18 361 Gravelly sandy loams 90 0 66-009 Coniferous forest 4000.0 9-38 24 333 Sandy loams & silt loams 120 0 66-010 Recreation sites 5400.0 2-11 6 379 

Cobbly loams 

& cobbly 

sandy loams 

120 0 

66-011 Administrative or agricultural 4400.0 6-9 7 361 Gravelly sandy loams 90 67
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

66-012 Coniferous forest 4000.0 17-25 20 335 Sandy loams & silt loams 120 2566-013 

Buildings, 

structures, or 

roads 

3920.0 12-33 19 380 Gravelly loams 90 8

66-016 Coniferous forest 3000.0 4-50 27 377 Loams & gravelly loams 90 0 66-017 Coniferous forest 3360.0 2-61 30 377 Loams & gravelly loams 90 0 66-018 Coniferous forest 3840.0 2-61 31 359 Cobbly & gravelly loams 80 0 66-020 Coniferous forest 3600.0 0-35 9 352 Silt loams & heavy silt loams 70 0 66-023 Coniferous forest 3000.0 3-75 29 374 Gravelly & cobbly loams 90 0 66-025 

Rocky with 

minimum 

vegetation 

potential 

3120.0 31-50 41 335 Sandy loams & silt loams 90 8

66-026 Coniferous forest 3280.0 0-0 333 Sandy loams & silt loams 120 0 66-027 Administrative or agricultural 2800.0 6-31 23 361 Gravelly sandy loams 80 0 66-028 Coniferous forest 3200.0 4-10 6 333 Sandy loams & silt loams 80 2566-029 Coniferous forest 2080.0 48-71 57 334-7 

Sandy loams 

& silt loams 

with igneous 

rock outcrop 

80 28

66-030 Coniferous forest 3000.0 21-41 31 380 Gravelly loams 100 3066-033 Coniferous forest 3600.0 2-39 20 158 Fine sandy loams & loams 35 90

Appendix O-12 
Site-Speci

Appendix O-13 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

66-035 Coniferous forest 3440.0 2-43 27 7 Igneous rock outcrop 60 1066-037 Tule meadow (standing water) 3520.0 0-23 5 352 Silt loams & heavy silt loams 60 4066-038 Coniferous forest 3440.0 3-60 19 347 Gravelly loams 60 0 66-039 

Rocky with 

minimum 

vegetation 

potential 

3680.0 12-32 20 330 Stony loams 70 0 

66-040 Shrubland 2320.0 22-33 27 377-6 

Loams & 

gravelly 

loams with 

unvegetated

talus & 

rubbleland 

90 15

66-041 Coniferous forest 3700.0 5-12 8 168 Gravelly & cobbly fine 

sandy loams 

80 60

66-042 

Rocky with 

minimum 

vegetation 

potential 

4160.0 22-37 30 7-6 

Igneous rock 

outcrop with 

unvegetated

talus & 

rubbleland 

60 10

66-043 

Talus with 

mimimum 

vegetation 

potential 

3680.0 12-30 18 335 Sandy loams & silt loams 80 10

66-044 Coniferous forest 3680.0 26-26 26 347 Gravelly loams 70 2066-046 Coniferous forest 3400.0 10-16 13 347 Gravelly loams 60 6066-047 

Man-caused 

minimum 

vegetation 

4200.0 15-23 20 333 Sandy loams & silt loams 100 35
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

66-048 

Rocky with 

minimum 

vegetation 

potential 

3600.0 23-66 37 335 Sandy loams & silt loams 100 30

66-049 

Man-caused 

minimum 

vegetation 

3840.0 18-33 27 333 Sandy loams & silt loams 80 10

66-051 

Rocky with 

minimum 

vegetation 

potential 

3600.0 6-33 18 355 

Gravelly 

loamy fine 

sands &

loamy fine 

sand 

40 20

66-052 

Buildings, 

structures, or 

roads 

4480.0 5-44 21 1 Fresh sands & gravels 90 20

66-053 Administrative or agricultural 3700.0 5-115 62 359 Cobbly & gravelly loams 80 166-055 Coniferous forest 3800.0 0-27 11 347 Gravelly loams 80 0 66-057 Coniferous forest 3700.0 2-28 10 352 Silt loams & heavy silt loams 70 0 66-058 Coniferous forest 3900.0 1-19 10 334 Sandy loams & silt loams 70 3066-059 Coniferous forest 4300.0 11-53 32 335 Sandy loams & silt loams 70 0 66-060 Coniferous forest 2400.0 1-57 22 378 Stony loams & cobbly loams 90 0 66-062 Coniferous forest 3000.0 2-68 26 333 Sandy loams & silt loams 90 0 66-063 Coniferous forest 3600.0 0-69 24 333 Sandy loams & silt loams 90 0 66-067 Coniferous forest 3600.0 0-55 18 333 Sandy loams & silt loams 90 0 

Appendix O-14 
Site-Speci

Appendix O-15 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

66-069 Coniferous forest 3800.0 1-10 5 352 Silt loams & heavy silt loams 60 0 66-071 Coniferous forest 3500.0 2-60 24 334 Sandy loams & silt loams 120 0 66-074 Coniferous forest 4000.0 1-40 16 347 Gravelly loams 80 0 66-081 Coniferous forest 3800.0 1-30 18 347 Gravelly loams 70 966-082 Coniferous forest 4000.0 3-65 27 380 Gravelly loams 90 0 66-083 Coniferous forest 3600.0 29-51 41 335 Sandy loams & silt loams 90 3066-084 Coniferous forest 3400.0 2-39 16 361 Gravelly sandy loams 80 0 66-085 Coniferous forest 4320.0 0-35 14 352 Silt loams & heavy silt loams 70 0 66-086 Coniferous forest 3200.0 0-46 13 304 Gravelly & cobbly loams 70 0 66-087 Coniferous forest 3500.0 1-23 9 304 Gravelly & cobbly loams 60 0 66-089 Coniferous forest 3400.0 0-49 13 352 Silt loams & heavy silt loams 60 0 66-091 Coniferous forest 3600.0 3-63 28 354 

Gravelly 

loamy fine 

sands &

loamy fine 

sands 

90 0 
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

69-001 Coniferous forest 2350.0 1-37 22 333 Sandy loams & silt loams 70 7569-002 Coniferous forest 0-0 111 

Very gravelly 

loams & 

gravelly silt 

loams 

80 0 

69-003 Coniferous forest 2550.0 4-44 21 338 Stony silt loams 90 0 69-004 Coniferous forest 3878.8 1-27 10 333 Sandy loams & silt loams 60 1 69-005 Coniferous forest 3800.0 11-41 20 343 

Gravelly 

loams & 

cobbly

gravelly 

loams 

90 50

69-006 Coniferous forest 1500.0 0-0 333 Sandy loams & silt loams 60 2069-007 Shrubland 3800.0 12-12 12 338 Stony silt loams 90 5069-008 Coniferous forest 1800.0 0-94 25 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

90 0 

69-010 Coniferous forest 2450.0 0-0 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 0 

69-011 Coniferous forest 1800.0 0-0 111 

Very gravelly 

loams & 

gravelly silt 

loams 

80 5

69-012 Coniferous forest 1600.0 0-0 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 0 

69-013 Coniferous forest 1800.0 0-0 15 

Steep to very 

steep, 

unstable 

dranageways 

80 15

Appendix O-16 
Site-Speci

Appendix O-17 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

69-014 Coniferous forest 1450.0 25-25 25 111 

Very gravelly 

loams & 

gravelly silt 

loams 

80 0 

69-015 Hardwood forest 1950.0 0-0 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 7

69-016 Coniferous forest 2874.6 0-97 15 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 0 

69-017 Coniferous forest 1600.0 15-18 16 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 7

69-018 Coniferous forest 1600.0 13-20 17 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 5

69-019 Coniferous forest 1800.0 2-4 3 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 5

69-020 Coniferous forest 1450.0 7-7 7 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 0 

69-021 Coniferous forest 1600.0 2-6 3 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 1

69-022 Coniferous forest 1639.8 2-6 4 346 Very cobbly loamy coarse sand, single 

grain 

80 2
Final Environmental Impact Statement 

Treatment 

ID # 

Habitat 

(excluding 

harvest) 

Average 

Elevation 

(ft) 

% Slope 

(Min – 

Max) 

% Slope 

(Average)

Main 

SRI 

Code 1 Soil Type Precipitation 

Min. 

(inch/year) 

To W

(f

69-023 Coniferous forest 1600.0 10-11 10 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 3

69-024 Hardwood forest 1450.0 19-19 19 11 Alluvial bottomlands 80 1569-025 

Buildings, 

structures, or 

roads 

2491.1 5-11 8 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 0 

69-026 Coniferous forest 1800.0 6-8 7 352 Silt loams & heavy silt loams 50 2069-027 Coniferous forest 1085.6 0-113 34 11 Alluvial bottomlands 80 0 69-028 Coniferous forest 3920.0 9-18 13 6 Unvegetated talus & rubbleland 90 469-029 

Buildings, 

structures, or 

roads 

1440.0 1-1 1 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 0 

69-030 Coniferous forest 1560.0 3-5 4 346 

Very cobbly 

loamy coarse 

sand, single 

grain 

80 31

Appendix O-18 
Site-Speci

Continuation . . . Additional existing condition characteristics by treatment area. 

Treatment 

ID # 

Miles of 

Stream 

Miles of 

Fish 

Bearing 

Stream 

Road / 

Stream 

Crossings 

Count 2

NWFP Key 

Watershed 

Acres 

Miles 

of 

Road 

Landslide 

Risk 

Fauna TES 

Species 

Present 

Flora TES 

Species 

Present 

R

22-01 0.96 0.96 0.00 0.00 Low Fish None 22-05 0.14 0.14 0.00 0.00 Low None None 22-07 0.00 0.00 0.00 0.00 Low Fish; Bald eagle None 22-08 0.00 0.00 0.00 0.00 Low 

Bald Eagle 

Peregrine 

falcon 

None 

22-11 0.10 0.10 0.00 0.00 Low 

Lewis' 

woodpecker; 

Peregrine 

Falcon 

None 

22-12 0.44 0.44 0.00 0.00 Low None None 22-17 0.17 0.17 0.00 0.00 Low None None 61-002 0.16 0.07 7 119.37 9.02 High Fish; Northern spotted owl None 61-003 0.25 0.18 4 55.02 4.09 High Fish; Northern spotted owl None 61-005 0.00 0.00 0 72.23 4.39 High Northern spotted owl None 61-006 0.18 0.02 2 92.13 6.89 High Fish; Northern spotted owl None 61-007 0.00 0.00 0 5.44 0.08 High None None 61-009 0.08 0.00 3 43.22 3.22 High Northern spotted owl None 61-017 0.36 0.03 7 96.07 7.22 High Fish; Northern spotted owl None 61-018 0.00 0.00 0 48.17 3.68 High Northern spotted owl None 

Appendix O-19 

2 GIS data on Road/ Stream Crossings Count is not available for the Scenic Area. 
Final Environmental Impact Statement 

Treatment 

ID # 

Miles of 

Stream 

Miles of 

Fish 

Bearing 

Stream 

Road / 

Stream 

Crossings 

Count 2

NWFP Key 

Watershed 

Acres 

Miles 

of 

Road 

Landslide 

Risk 

Fauna TES 

Species 

Present 

Flora TES 

Species 

Present 

R

61-019 0.65 0.12 23 257.56 19.75 High Fish; Northern spotted owl None 61-020 0.00 0.00 0 0.49 0.00 Low None None 61-021 0.00 0.00 0 46.26 3.46 Medium Northern spotted owl None 61-022 0.00 0.00 0 11.27 0.85 Medium Northern spotted owl None 61-023 0.10 0.10 2 10.93 0.06 Medium Fish; Northern spotted owl None 61-024 0.00 0.00 0 30.12 2.26 Medium None None 61-025 0.37 0.00 9 54.12 4.15 Low Fish; Northern spotted owl None 61-026 0.05 0.02 2 34.72 2.59 Low Fish None 61-027 0.00 0.00 0 26.81 2.00 Medium None None 61-028 0.17 0.00 7 51.60 3.86 Low Northern spotted owl None 61-029 0.02 0.00 1 40.20 3.03 Low Northern spotted owl None 61-030 0.00 0.00 0 5.98 0.24 Low Northern spotted owl None 61-034 0.00 0.00 0 58.46 4.43 Low Northern spotted owl None 61-036 0.00 0.00 0 25.80 1.95 Low Northern spotted owl None 61-039 0.51 0.00 3 75.93 0.82 Medium Northern spotted owl None 61-040 0.02 0.00 1 10.40 0.82 Low Northern spotted owl None 61-041 0.14 0.02 5 54.98 4.48 Medium Fish; Northern spotted owl None 61-042 0.16 0.00 5 52.14 3.84 Medium Northern spotted owl None 61-043 0.57 0.57 0 15.74 0.00 Low Fish; Northern spotted owl None 61-044 0.00 0.00 0 20.16 1.56 Low Northern spotted owl None 

Appendix O-20 
Site-Speci

Appendix O-21 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

61-045 0.00 0.00 0 33.17 0.18 Low None None 61-046 0.00 0.00 0 2.89 0.10 Low Northern spotted owl None 61-047 0.00 0.00 0 1.47 0.00 Low None None 61-048 0.00 0.00 0 19.02 2.90 Low Northern spotted owl None 61-049 0.00 0.00 0 19.55 0.11 Low Northern spotted owl None 61-050 0.00 0.00 0 17.81 0.00 Low Northern spotted owl None 61-051 0.00 0.00 0 0.36 0.00 Low None None 61-053 0.04 0.04 0 3.74 0.00 Low Northern spotted owl None 61-055 0.00 0.00 0 0.00 0.00 Low None None 61-057 0.00 0.00 0 0.00 0.00 Low None None 61-058 0.00 0.00 0 0.00 0.00 Low Northern spotted owl None 61-059 0.00 0.00 0 0.00 0.10 Low None None 61-062 0.00 0.00 0 0.00 0.00 Low None None 61-064 0.02 0.00 0 0.00 0.00 Low None None 61-065 0.27 0.15 0 0.00 0.00 Low Fish; Northern spotted owl None 61-066 0.00 0.00 0 0.00 0.46 Low Northern spotted owl None 61-071 0.13 0.00 0 40.82 0.23 Medium Northern spotted owl None 61-073 0.22 0.01 3 0.00 0.85 Medium Fish; Northern spotted owl None 61-074 0.00 0.00 0 45.73 0.18 Low None None 61-075 0.09 0.00 0 12.53 0.97 Low Northern spotted owl None 
Final Environmental Impact Statement 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

61-076 0.06 0.00 2 15.39 1.15 Low None None 61-077 0.00 0.00 0 44.66 3.33 Medium Northern spotted owl None 61-078 0.01 0.00 0 22.43 1.66 Low Northern spotted owl None 61-079 0.27 0.27 0 15.63 2.80 Low Northern spotted owl None 61-080 0.00 0.00 0 0.00 1.33 Low Northern spotted owl None 61-081 0.00 0.00 0 0.00 0.26 Low None None 61-082 0.00 0.00 1 0.00 0.16 Medium Northern spotted owl None 61-083 0.28 0.06 6 0.00 1.42 Low Fish; Northern spotted owl None 61-084 0.00 0.00 0 32.39 2.42 Medium Northern spotted owl None 61-085 0.00 0.00 0 5.79 1.17 Medium None None 61-086 0.08 0.00 3 39.88 4.91 Low Fish; Northern spotted owl None 61-087 0.07 0.00 3 0.20 2.31 Low Northern spotted owl None 61-088 0.00 0.00 0 59.71 4.39 High Northern spotted owl None 61-089 0.07 0.02 2 88.62 6.60 High Northern spotted owl None 61-090 0.02 0.00 0 0.51 0.00 Low None None 61-091 0.05 0.00 0 3.65 0.03 Medium Northern spotted owl None 61-092 0.00 0.00 0 5.99 0.00 Low Northern spotted owl None 61-093 0.00 0.00 0 5.40 0.06 Low Northern spotted owl None 61-095 0.05 0.03 2 103.96 7.84 High Fish; Northern spotted owl None 65-001 0.09 0.02 4 0.00 2.45 Low Northern spotted owl None 

Appendix O-22 
Site-Speci

Appendix O-23 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

65-002 0.05 0.03 2 12.81 4.61 High Fish; Northern spotted owl None 65-003 0.09 0.00 4 11.72 3.06 Low Northern spotted owl None 65-005 0.00 0.00 0 0.06 0.00 High Northern spotted owl None 65-006 0.01 0.01 0 0.00 0.00 High Northern spotted owl None 65-007 0.00 0.00 0 0.00 0.25 None None 65-008 0.00 0.00 0 0.00 0.02 High None None 65-009 0.03 0.00 1 1.03 0.02 Medium None None 65-010 0.00 0.00 0 0.38 0.97 Low Northern spotted owl None 65-011 0.00 0.00 0 1.07 0.03 Medium None None 65-012 0.09 0.02 4 0.00 0.99 High Northern spotted owl None 65-013 0.13 0.02 5 0.00 3.49 High Northern spotted owl None 65-014 0.00 0.00 0 0.00 0.17 Low Northern spotted owl None 65-015 0.09 0.07 0 0.00 0.11 Medium Northern spotted owl None 65-016 0.00 0.00 0 0.00 0.14 Medium Northern spotted owl None 65-017 0.03 0.03 0 4.05 0.20 High Fish; Northern spotted owl None 65-018 0.00 0.00 0 0.76 0.09 Medium None None 65-019 0.08 0.08 0 4.95 0.08 High Fish; Northern spotted owl None 65-020 2.96 0.69 55 414.37 15.56 High Fish; Northern spotted owl None 65-021 0.01 0.00 0 1.52 0.15 High 

Northern 

spotted owl None 
Final Environmental Impact Statement 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

65-022 0.00 0.00 0 1.86 0.20 High 

Northern 

spotted owl; 

Bald eagle 

None 

65-023 2.13 0.88 76 342.71 24.64 High Fish; Northern spotted owl Coldwater corydalis 65-024 0.00 0.00 0 4.58 0.13 Medium Northern spotted owl None 65-025 0.00 0.00 0 0.00 0.00 High None None 65-026 0.00 0.00 0 4.72 0.09 High None Pale blue- eyed grass 65-027 0.00 0.00 0 0.73 0.00 High None Adder’s tongue 65-028 0.00 0.00 0 0.77 0.01 High Northern spotted owl None 65-029 0.11 0.05 2 11.63 0.52 High Fish; Northern spotted owl None 65-030 0.03 0.00 1 11.39 0.60 High Northern spotted owl None 65-031 0.09 0.07 3 14.27 0.02 High Northern spotted owl None 65-032 0.00 0.00 0 2.74 0.23 High Northern spotted owl None 65-033 0.06 0.06 2 9.64 0.38 High Northern spotted owl None 65-034 0.00 0.00 0 5.20 0.30 Medium Northern spotted owl None 65-035 0.00 0.00 0 0.00 0.20 Low Northern spotted owl None 65-036 0.08 0.01 0 0.00 0.06 High Northern spotted owl None 65-037 0.02 0.00 1 0.00 0.06 Low Northern spotted owl None 65-038 0.01 0.00 0 0.00 0.06 Medium None None 65-039 0.02 0.02 0 0.00 0.00 Low Northern spotted owl None 65-040 0.00 0.00 0 0.00 0.04 Low Northern spotted owl None 65-041 0.00 0.00 0 4.18 0.17 High Northern spotted owl None 

Appendix O-24 
Site-Speci

Appendix O-25 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

65-042 0.09 0.00 2 6.90 0.37 High Northern spotted owl None 65-043 0.03 0.00 0 0.00 0.39 Medium Northern spotted owl None 65-044 0.11 0.00 2 0.00 0.55 Medium Northern spotted owl None 65-045 0.00 0.00 0 0.11 0.02 Low Northern spotted owl None 65-046 0.05 0.00 2 0.00 0.63 Low Northern spotted owl None 66-001 0.00 0.00 0 20.75 0.05 High Northern spotted owl None 66-003 0.00 0.00 0 34.57 0.18 Medium Northern spotted owl None 66-004 0.10 0.00 0 18.88 0.00 High None None 66-005 0.15 0.00 0 25.02 0.00 Medium Northern spotted owl None 66-006 0.39 0.03 1 58.62 0.16 High Northern spotted owl None 66-007 3.64 1.49 9 448.73 4.87 High Fish; Northern spotted owl None 66-008 3.49 2.72 48 178.20 20.37 High Fish; Northern spotted owl None 66-009 0.02 0.00 1 0.00 0.00 Low None None 66-010 0.12 0.00 0 0.00 0.00 Low None None 66-011 0.00 0.00 0 0.00 0.00 Low None None 66-012 0.00 0.00 0 0.67 0.07 Low Northern spotted owl None 66-013 0.00 0.00 0 0.00 0.22 Medium Northern spotted owl None 66-016 0.51 0.04 23 78.79 5.07 High Fish; Northern spotted owl None 66-017 0.16 0.00 4 66.57 4.37 Medium Northern spotted owl None 66-018 0.12 0.07 5 0.00 3.83 High Northern spotted owl None 
Final Environmental Impact Statement 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

66-020 4.00 0.13 14 1014.29 5.65 Medium Northern spotted owl None 66-023 1.86 0.14 77 350.83 26.10 High Fish; Northern spotted owl None 66-025 0.00 0.00 0 0.00 0.00 Low Northern spotted owl None 66-026 0.01 0.00 0 0.07 0.00 Low None None 66-027 0.02 0.02 0 0.00 0.00 Low Fish None 66-028 0.00 0.00 0 0.00 0.00 Low None None 66-029 0.00 0.00 0 0.00 0.05 High None None 66-030 0.00 0.00 0 0.00 0.04 Medium Northern spotted owl None 66-033 0.00 0.00 0 17.30 0.54 Medium Northern spotted owl Elegant rockcress 66-035 0.00 0.00 0 0.00 0.04 Medium None 

Watson’s 

desertparsley 

66-037 0.11 0.09 1 9.63 0.05 Low Fish; Northern spotted owl None C66-038 0.97 0.30 1 0.00 1.41 High Northern spotted owl 

Elegant 

rockcress; 

Watson’s 

desertparsley 

66-039 0.01 0.01 0 3.52 0.08 Medium Northern spotted owl None 66-040 0.00 0.00 0 1.08 0.00 Medium None None 66-041 0.00 0.00 0 0.00 0.13 Low Northern spotted owl None 66-042 0.00 0.00 0 2.74 0.00 High None Elegant rockcress 66-043 0.00 0.00 0 0.00 0.00 Low 

Northern 

spotted owl; 

Bald eagle 

None 

Appendix O-26 
Site-Speci

Appendix O-27 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

66-044 0.00 0.00 0 0.00 0.00 Northern spotted owl None 66-046 0.00 0.00 0 0.00 0.14 Northern spotted owl None 66-047 0.00 0.00 0 0.00 0.03 Low None None 66-048 0.00 0.00 0 3.59 0.00 Medium Northern spotted owl None 66-049 0.00 0.00 0 0.00 0.00 Low Northern spotted owl None 66-051 0.00 0.00 0 5.67 0.06 Low None None 66-052 0.02 0.02 0 8.78 0.07 Medium None None 66-053 0.00 0.00 0 0.00 0.02 Medium Fish; Northern spotted owl None 66-055 0.03 0.02 1 36.70 3.08 Low Northern spotted owl None 66-057 0.55 0.25 4 80.31 2.02 Medium Northern spotted owl None 66-058 0.00 0.00 0 14.94 0.78 Medium Northern spotted owl None 66-059 0.05 0.00 1 39.70 1.50 High Northern spotted owl None 66-060 0.57 0.20 20 105.24 7.85 Medium Fish; Northern spotted owl None 66-062 0.61 0.50 15 0.00 10.87 Medium Fish; Northern spotted owl None 66-063 1.40 0.54 47 217.98 47.45 High Fish; Northern spotted owl None 66-067 0.27 0.00 12 0.00 9.56 Medium Northern spotted owl None 66-069 0.19 0.00 1 50.45 0.66 Low Northern spotted owl None 66-071 0.46 0.06 20 0.00 3.64 Medium Northern spotted owl None 66-074 0.23 0.21 3 53.18 8.25 Medium Northern spotted owl Elegant rockcress 66-081 0.00 0.00 0 22.23 1.66 Low Northern spotted owl None 
Final Environmental Impact Statement 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

66-082 0.45 0.11 21 0.00 6.96 High Fish; Northern spotted owl None 66-083 0.00 0.00 0 27.70 0.00 Medium None None 66-084 0.24 0.20 11 0.00 5.49 High Fish; Northern spotted owl None 66-085 0.53 0.04 21 148.06 11.17 High Northern spotted owl None 66-086 1.42 0.02 49 296.42 22.09 High 

Northern 

spotted owl; 

Bald eagle 

None 

66-087 0.70 0.04 16 67.97 5.16 Low 

Fish; Northern 

spotted owl; 

Bald eagle 

None 

66-089 0.77 0.11 27 154.45 11.68 High Fish; Northern spotted owl None 66-091 0.52 0.11 23 120.19 8.31 High Fish; Northern spotted owl None 69-001 0.05 0.05 1 7.50 0.28 Medium Northern spotted owl None 69-002 0.00 0.00 0 0.00 0.00 Medium Northern spotted owl None 69-003 0.25 0.12 11 0.00 3.27 Northern spotted owl None 69-004 0.00 0.00 0 24.14 1.84 Low Northern spotted owl None 69-005 0.30 0.08 12 0.00 3.17 Northern spotted owl None 69-006 0.00 0.00 0 0.09 0.01 Low Northern spotted owl None 69-007 0.00 0.00 0 0.00 0.00 Northern spotted owl None 69-008 8.18 1.27 172 2.37 53.01 High Fish; Northern spotted owl None 69-010 0.01 0.01 0 0.00 0.00 Low Fish None 69-011 0.00 0.00 0 0.00 0.00 Medium Northern spotted owl None 69-012 0.00 0.00 0 0.00 0.00 Low Fish None 

Appendix O-28 
Site-Speci

Appendix O-29 

Treatment 

ID # 

Miles of 

Stream 

Miles of Road / 

Fish 

Bearing 

Stream 

Stream NWFP Key Miles Fauna TES Flora TES 

Crossings 

Count 2

Watershed 

Acres 

of Landslide 

Road Risk 

Species 

Present 

Species R

Present 

69-013 0.00 0.00 0 0.00 0.01 Low None None 69-014 0.00 0.00 0 0.00 0.00 Low None None 69-015 0.00 0.00 0 0.00 0.00 Low Fish None 69-016 3.27 2.36 30 72.25 16.91 High Fish; Northern spotted owl None 69-017 0.00 0.00 0 0.00 0.00 Low Northern spotted owl None 69-018 0.05 0.01 0 0.00 0.00 Low Fish; Northern spotted owl None 69-019 0.00 0.00 0 0.00 0.00 Low Fish; Northern spotted owl None 69-020 0.00 0.00 0 0.00 0.00 Low Fish; Northern spotted owl None 69-021 0.01 0.01 0 0.00 0.01 Low Fish; Northern spotted owl None 69-022 0.00 0.00 0 0.00 0.00 Low Fish; Northern spotted owl None 69-023 0.00 0.00 0 0.00 0.00 Low Fish; Northern spotted owl None 69-024 0.01 0.00 0 0.19 0.00 Low Northern spotted owl None 69-025 0.00 0.00 0 0.00 0.14 Low None None 69-026 0.00 0.00 0 1.12 0.00 Low Northern spotted owl None 69-027 2.06 1.06 4 188.12 2.43 High Fish; Northern spotted owl None 69-028 0.00 0.00 0 0.00 0.00 Low None None 69-029 0.02 0.02 0 0.00 0.00 Low Fish None 69-030 0.00 0.00 0 0.00 0.06 Low Northern spotted owl None 
 
APPENDIX P 

Ownership Patterns by Fifth Field Watershed 
 
Site-Specific In

APPENDIX P: Ownership Patterns by Fifth Field Watershed, within the FScenic Area Information compiled from existing GIS layers, maintained in the Mt. Hood National Forest and Columbia River Scenic Area, Geographic Information System data library (http://www.fs.fed.us/r6/data-library/gis/). 

5th Field Watersheds Acres by Ownership Class 

Watershed # Watershed Name 

USDA 

Forest 

Service 

USDI 

BLM 

Other 

Federal 

Govern’t 

Tribal 

Lands State 

Local 

Govern’t Private 

1707030605 Beaver Creek 1312.2 70547.8 34882.1708000105 Bull Run River 78650.7 1055.0 4791.3 4488.1709001101 Collawash River 96559.4 861.7 1708000107 Columbia Gorge Tributaries 44712.1 1.9 2021.5 17285.9 242.5 35840.1707010506 East Fork Hood River 68419.2 209.6 663.9 7102.2 24558.4 1707010502 Fifteenmile Creek 17579.6 58.9 33.1 251.9 10.8 139301.1707010503 Fivemile Creek 18557.0 544.4 59089.1709001106 Lower Clackamas River 1622.6 4935.3 1427.3 401.4 109274.1707010508 Lower Hood River 3273.8 157.4 222.4 318.4 9033.4 38278.1708000108 Lower Sandy River 3833.4 3614.4 760.8 497.6 37661.1709001104 Middle Clackamas River 124902.8 4848.7 86.6 19.7 8648.1707010513 Middle Columbia/Eagle Creek 46380.7 62.3 116.4 4.5 16865.0 445.2 19172.2 1707010512 Middle Columbia/Grays Creek 28936.4 211.1 603.7 7857.9 644.3 50089.1707010504 Middle Columbia/Mill Creek 16825.4 2097.4 1074.1 2611.3 5064.1 388.4 99480.

Appendix P-1 
Final Environmental Impact Statement 

5th Field Watersheds Acres by Ownership Class 

Watershed # Watershed Name 

USDA 

Forest 

Service 

USDI 

BLM 

Other 

Federal 

Govern’t 

Tribal 

Lands State 

Local 

Govern’t 

Private 

1707030607 Middle Deschutes River 2874.4 20736.7 56919.0 1392.1 113462.1708000104 Middle Sandy River 6571.6 7811.7 237.5 800.1 25535.1709001103 

Oak Grove Fork Clackamas River 79256.1 11285.9 

1708000101 Salmon River 67920.2 1463.6 74.2 915.0 3343.1707030609 Tygh Creek 41636.6 255.7 14595.4 39.6 25031.1709001102 Upper Clackamas River 94781.2 5578.3 137.1708000103 Upper Sandy River 30721.6 301.8 3177.1707010507 West Fork Hood River 42862.8 3873.5 18730.1707030610 White River 105184.6 3249.8 2915.8 10718.8 54203.2 1708000102 Zigzag River 36502.3 1261.4 

Total 1059876.6 52266.3 3456.2 150940.6 77358.7 29194.3 905646.0 

Percentage of Total 46.2% 2.3% 0.2% 6.6% 3.4% 1.3% 39.5% 

Appendix P-2 
APPENDIX Q 

Herbicide Information Summary and Project 

Design Criteria Crosswalk 
 
Site-

Appendix Q-1 

APPENDIX Q: Herbicide Information Summary and Project Design Criteria 

Prepared by Shawna L. Bautista, Pacific Northwest Region, Portland, OR 

and Stephen P. Bulkin, Pacific Northwest Region, Portland, OR 

March 16, 2006 

Mt. Hood National Forest and Columbia River Gorge National Scenic Area 

PDC Information incorporated by Jennie O’Connor, Mt. Hood National Forest, Sandy OR 

April 30, 2006 

The following information is designed to aid in the understanding of herbicides used for invasive plant treatment. A

the complex information about herbicides is prone to over simplification and errors. The information in these tables 

introduction to the herbicides, but should not be the sole source of information used for analysis purposes. It is imporespective risk assessments prepared by Syracuse Environmental Research Associates, Inc. (SERA) and peer-reviewanalysis information. These tables have five columns labeled herbicide characteristics, basic hazard identification, risk characterization, la

information, and project design criteria (PDC). Herbicide characteristics are general pieces of information about the 

often taken from the Herbicide Handbook (Weed Science Society of America, 2002) or the respective risk assessme2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f). Qualitative statements (e.g., highly water solubleinformation in charts on water solubility and soil mobility found at the end of the document. These categories are no

been gleaned from a variety of sources. These charts (water solubility and soil mobility) need to be completed and u

work in progress. To better understand each herbicide, it is important to recognize the difference between the inherent risks from the c

identification) from those risks associated with the intended use, which take into account application and exposure acharacterization). The hazard identification and risk characterization information is mostly taken from the respective each herbicide, prepared by SERA, Inc., as well as analysis results from the Invasive Plant FEIS (USDA Forest ServInvasive Plant FEIS already has conducted the analysis of effects from the hazard identification and risk characterizneed not be repeated. Standards added to Mt. Hood Land and Resource Management Plan and Columbia River Gorg

Management Plan from the Invasive Plant ROD (USDA Forest Service, 2005b) further reduce the potential risks lis

characterization column. PDC (Section 2.2 of this EIS) focus on reducing risks remaining after the application and e

taken into consideration (i.e., risk characterization), along with compliance with label directions and new Forest Pla
Final Environmental Impact Statement 

Appendix Q-2 

We have also included brief summaries of some label restrictions or information. Please note: the label restrictions cnot a comprehensive listing of all label requirements. The information is largely brief excerpts of some requirementformulations. Labels are also updated and revised periodically, so it is important to obtain and read the full label for 

Labels may be downloaded from the following website: www.cmds.net/manuf/default.asp. 

This version of the table contains, for each herbicide, the priority target species for the Mt. Hood National Forest an

National Scenic Area in Oregon. The herbicide became a first priority for the identified invasive plants based on eff

that species, as per recommendations from the local State and County weed specialists. Environmental and seasonal 

infestations that contain several species, may require using a different herbicide in a given treatment area. 

Herbicide grazing restrictions are summarized in the table on pages 35-36. Acronyms used in the table include: 

• LOC= Level of Concern. The concentration in media or some other estimate of exposure above which there 

• RfD = Reference dose. The RfD is a numerical estimate of a daily exposure to the human population, includ

such as children, that is not likely to cause harmful effects during a lifetime. RfDs are generally used for heathought to have a threshold or minimum dose for producing effects. 

The use of product names is for illustrative purposes only and is not intended as a recommendation for use or these products by the USDA Forest Service. 
Site-

Appendix Q-3 

Active Ingredient: Chlorsulfuron Trade Name(s): Telar, Glean, Corsair

Mode of Action: Acetolactate synthesis inhibitor Chemical Family: Sulfonylurea 

Forest-Scenic Area target species: Known infestations – thistles, houndstongue 

Invasive plants in close proximity – perennial pepperweed, whitetop, puncture 

Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Chlorsulfuron 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

SELECTIVE: controls broadleaf weeds some and grasses 

Supplemental label for mix with clopyralid for control 

of yellow starthistle in Oregon 

Very high water solubility at pH 7; decreases to medium solubility at pH 5 

Leaching, runoff Rainfall post treatment: Off 

target movement and nontarget effects. 

Do not contaminate water C.3. – 

Moderate affinity for organic material, but adsorption to clay is low 

High mobility in soils Treatment of powdery, dry 

soil and light sandy soils 

when there is little likelihood of rainfall soon after treating may result in off target movement and possible damage to susceptible crops when soil particles are moved by wind or water. 

G.2. – on soil

In H20, degraded by sunlight 

Half-live in water is 1 month 

Very low application rates; therefore, little potential to 

enter ground water 

A.8. – C.2. – F.1. – 
Final Environmental Impact Statement 

Appendix Q-4 

Chlorsulfuron 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Degradation by soil microbes is slow 

Half-life in field avg 40 days (range 4-6 wks); 

shorter at lower pH 

Low toxicity to soil microorganisms 

Exposure far below level of 

concern 

In field, degraded primarily by hydrolysis, but rates are slow 

Persistent Residues may injure 

susceptible plants up to 

4yrs after application in 

high pH soils 

E.1. – 

Absorbed thru roots and foliage; active in soil as a pre-emergent 

Do not apply thru irrigation system 

Resistant Biotypes may develop 

Application should be 

based on IPM principles 

Maintains native perennial grasses Potent herbicide. Requires small amounts of AI to be effective. 

May damage non-target plants and trees; Wind 

erosion concern 

Adverse effects on some nontarget plants are plausible 

A.8. – E.1. – 

Can cause body weight loss in mammals 

Worker and public 

exposures below level of 

concern (LOC) except workers using ground broadcast applications, which is slightly above LOC at high application rate (0.14 lb/acre) 

Do not apply in a way that will contact workers or other persons, either directly or through drift. 

A.8. – 

D.1. – equipm

Mild eye and skin irritant Mild irritation to skin and 

eyes from exposures to 

high levels from mishandling 

Only protected handlers may be in the area during

application. 

A.8. – D.1. – equipm

May alter insulin production, cholesterol 

levels, and triglycerides at high doses 

Exposures far below levels of concern 

A.8. – 
Site-

Appendix Q-5 

Chlorsulfuron 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Does not bioaccumulate or bioconcentrate 

No evidence of reproductive risk, 

malformations, cancer, or mutagenicity 

A.8. – 

Can cause mild body weight loss in mammals and birds 

Exposures well below levels of concern No plausible risk to insectivorous species 

Very low toxicity to fish, no effects to egg & fry 

Exposures far below levels of concern 

Do not contaminate water A.8 – A

F.1. – 

Very low toxicity to aquatic invertebrates 

Exposures far below levels of concern 

Do not contaminate water A.8 – A

F.1. – 

No data on effects to amphibians, fish used as a 

surrogate 

Exposures far below levels of concern 

Do not contaminate water A.8 – A

F.1. – H.2. – mollus

Aquatic plants are susceptible to 

chlorsulfuron, algae is less susceptible 

Peak exposures could damage aquatic plants at 

typical and high application rates; algae may be damaged at high rates 

Do not contaminate water A.8 – A

F.1. – 

Low toxicity to bees or beetles 

Exposure below level of 

concern 
Final Environmental Impact Statement 

Appendix Q-6 

Active Ingredient: Clopyralid Trade Name(s): TranslineMode of Action: Plant growth regulator Chemical Family: Not known Forest-Scenic Area target species: Known infestations – hawkweeds, knapweeds (not Russian), thistles, tansy rag

rush skeleton 

Invasive plants in close proximity – Mediterranean sage 

Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Clopyralid 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Extremely SELECTIVE for broadleaves. Post emergent herbicide 

Selectivity reduces threat to non-target plants 

Avoid non-target contact 

with spray in treated areas 

E.1. – 

Targets: knapweeds and families Asteraceae, Fabaceae, Solanaceae. Canada thistle; Does NOT effect conifers, grasses are tolerant 

Supplemental label for control on tree plantations 

and forest sites 

High water solubility 

0.01 % of that applied may reach stream after first 

significant rainfall 

Contamination threat to water resources and nontarget species 

Do not contaminate water. Do not apply directly to water or to areas where 

surface water is present. Do not contaminate irrigation ditches. 

C.3. – D.7. – F.1. – 

Photo degradation and hydrolysis do not occur 8-40 day 1⁄2 life in water 

A.8 – AC.2. – F.1. – 
Site-

Appendix Q-7 

Clopyralid 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Weakly adsorbed to soil Very high mobility in soil 

Users are advised not to apply where soils have a 

rapid to very rapid permeability throughout the profile (such as loamy sand to sand) and the water table is shallow. 

F.1 – AG.1 – 

Degraded by soil microbes Half-life in field avg 40 days (range 12-70 days) Relatively rapid breakdown reduces potential for run- off or leaching 

Low toxicity to soil organisms 

Exposures far below level 

of concern 

A.8. – 

Non-microbial degradation does not occur 

Do not use hay or straw from treated areas for composting or mulching on 

susceptible plants 

Contaminated with hexachlorobenzene (HCB) (less than that in picloram) 

HCB is a persistent carcinogen and it 

bioaccumulates 

Exposure levels far below level of concern. Clopyralid 

does not present any substantial cancer risk. 

A.8. – 

Does not bioaccumulate or bioconcentrate 

No evidence of reproductive risk, 

malformations, cancer, or mutagenicity 

Exposures far below levels of concern 

A.8. – 

High acute doses cause depression of central nervous system in mammals 

Exposures far below levels of concern 

A.8. – 

Chronic doses cause weight loss, thicken stomach lining in mammals

Exposures far below levels 

of concern 

A.8. – 

Low toxicity to birds Exposures far below levels of concern A.8. – 

Chronic risk to insecteating birds or mammals 

unknown 

A.8. – 
Final Environmental Impact Statement 

Appendix Q-8 

Clopyralid 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Slight skin and eye irritation 

Avoid contact with skin and eyes or clothing. Avoid 

breathing spray mist. 

Applicators and handlers must wear long-sleeved shirt and long pants, waterproof gloves, shoes plus socks 

A.8. – D.1 – equipm

Potent herbicide. Requires small amounts of AI to be effective. 

May damage susceptible non-target terrestrial plants 

Adverse effects on some non-target plant species 

due to drift are likely under certain conditions 

C.2. – E.1. – 

Low toxicity to birds and mammals

Exposures below levels of 

concern No grazing restriction A.8. – 

low toxicity to fish or aquatic invertebrates 

Exposures very far below levels of concern 

A.8. – F.1. – 

No chronic tests to fish, or eggs and fry studies

available; use surrogate 

Exposures very far below levels of concern 

A.8. – F.1. – 

No data on effects to amphibians, fish used as a 

surrogate 

Exposures far below levels of concern 

A.8. – F.1. – H.2. – 

mollus

Aquatic plants and algae are not susceptible 

Exposures far below levels 

of concern 

A.8. – F.1. – 

Low toxicity to bees and earthworms 

Exposures far below level of concern 

A.8. – 
Site-

Appendix Q-9 

Active Ingredient Glyphosate Trade Name(s): RoundUp, Rodeo, Accord, 

Aquatic formulations: Rodeo; Aquamaster

Mode of Action: Inhibits 3 amino acids and protein synthesis Chemical Family: None generall

Forest-Scenic Area target species: Known infestations – hawkweeds, knotweeds, butter n’ eggs, houndstongue, b

ragwort, thistles, reed canarygrass, knapweeds, St. Johnswort, scotch broom, r

Invasive plants in close proximity – shining geranium, false broom, garlic mus

purple loosestrife, water hemlock, whitetop, Dalmatian toadflax, perennial pea

pepperweed, medusahead rye, Mediterranean sage 

Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Glyphosate 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Broad spectrum, NON selective 

Will kill contacted desirable plants, 

boom-spray drift may adversely affect non-target 

species 

Keep people and pets off treated areas until spray 

solution has dried to prevent transfer of this product onto desirable vegetation. 

C.2. – D.2., DD.7. – E.1. – 

Quickly absorbed by leaves and rapidly moves thru plant; no root absorption 

No risk to non-target plants from runoff 

E.1. – 

Aquatic Use formulations exist 

G.1. – labeled 

F.3. – 

Very high water solubility Runoff, leaching potential Rainfall within 6 hours may reduce effectiveness; C.3. – 
Final Environmental Impact Statement 

Appendix Q-10 

Glyphosate 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Strongly adsorbed to soil particles, especially clay Low mobility in soil 

Low likelihood of runoff due to strong adsorption to 

soil; soil-bound glyphosate 

not available to plants 

No photo degradation or hydrolysis Degraded by soil microbes Avg half-life 25-47 days (range 3-130 days) 

May cause transient population decrease or 

increase in some bacteria & fungi 

Does not bioaccumulate or bioconcentrate 

No evidence of doserelated repr

oductive risk, 

malformations, cancer, or mutagenicity 

All exposures for workers and public far below level of con

cern 

A.8. – D.1 – equipm

May damage mucosal tissue, weight loss in 

mammals; mild liver toxicity 

All exposures for workers and public far below level of con

cern 

Applicators and other handlers must wear longsleeved shirt and long 

pants, shoes plus socks, and protective eyewear. 

A.8. – D.1 – equipm

Mild to moderate irritant to skin and eyes. 

Do not get in eyes or on clothing; Avoid breathing 

vapor or spray mist; 

A.8. – D.1 – equipm

Can cause diarrhea, weight loss in mammals; weight loss in birds at very high doses; some mortality

to pregnant rabbits observed 

Mortality to some large vegetation-eating mammals plausible at 

highest application rates only; some risk to insecteating birds & mammals at high rate 

A.8. – 

Chronic risk to insecteating birds at typical rate unknown; at highest rate, 

chronic risk to insecteating birds and mammals unknown 

A.8. – 
Site-

Appendix Q-11 

Glyphosate 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Surfactants (tallow amine or POEA) in non-aquatic use formulations very toxic to aquatic organisms 

Low toxicity to fish; surfactant in some 

formulations much more toxic than glyphosate 

Even aquatic formulation exceeds level of concern for endangered fish, with 

max risk assumptions; surfactant formulations may cause mortality at high application rate only 

Follow label – no POEA to reach water 

A.8. – A.9. – F.1. – 

Low toxicity to aquatic invertebrates 

Exposures below level of concern 

A.8. – F.1. – 

No malformations in amphibians; toxicity to amphibians is comparable 

to that of fish 

At typical rate, all exposures below level of 

concern 

A.8. – A.9. – F.1. – H.2. – mollus

Surfactants may be highly toxic to aquatic organisms 

Do not apply (surfactant formulations) directly to 

water, to areas where 

surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when cleaning equipment. 

A.8. – A.9. – B.7. – F.1. – F.2. – 

Aquatic plants and algae are susceptible to 

glyphosate; but it does not control submerged plants 

Exposures below levels of concern; some algae 

growth stimulated at low concentrations 

No restriction on the use of treated water for irrigation, 

recreation, or domestic purposes. If emerged weeds cover entire water body, treatment of aquatic weeds may result in oxygen depletion. 

A.8. – D.7. – F.1. – 
Final Environmental Impact Statement 

Appendix Q-12 

Glyphosate 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Low or no toxicity to bees, beetles, spider mites, wasps, isopods, 

earthworms, or snails. 

Highest application rate may pose risk to some

individual bees, but not likely to populations 

A.8. – F.1. – 
Site-

Appendix Q-13 

Active Ingredient: Imazapic Trade Name(s): PlateauMode of Action: acetolactate synthesis inhibitor Chemical Family: Imidazolinone Forest-Scenic Area target species: Known infestations – butter n’ eggs, houndstongue 

Invasive plants in close proximity – medusahead rye, Dyer’s toad, puncture vi

Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Imazapic 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Selective against some broadleaves & some grasses 

E.1. – 

Uptake by roots & leaves; active in soil as preemergent May damage non-target plants and trees Drift or runoff may cause some damage to susceptible species 

Do not treat inside of irrigation ditches; conduct small test areas to 

determine risk to desirable trees and plants 

C.2. – E.1. – E.4 – Badaptiv

Very high water solubility Leaching, runoff Do not contaminate water 

D.7. – F.1. – 

Adsorbs to OM in soil Moderately mobile in soils, leachable in coarse soils 
Final Environmental Impact Statement 

Appendix Q-14 

Imazapic 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Degraded by soil microbes Half-life avg. 120d 

Treatment of areas that were previously treated with chlorsulfuron, 

metsulfuron methyl, sulfometuron or imazapyr may cause compound injury or death to desirable plants 

E.1. – E.4. – adaptiv

No info on toxicity to soil microbes In H20, degraded by sunlight 

Not irritating to skin, minimal irritation to eye 

Mild eye irritation from mishandling; no exposure 

scenario exceeded RfD for workers or public except spill 

D.1. – equipm

Does not bioaccumulate or bioconcentrate 

No adverse effects to mammal reproduction or development, not carcinogenic or mutagenic Muscle, liver, & blood damage in dogs at high chronic doses 

Exposures far below levels of concern 

A.8. – 

Low toxicity to birds Exposures far below levels of concern A.8. – 

No plausible risk to insectivorous species 

A.8. – 

Low toxicity to fish, no effects to egg & fry 

Exposures far below levels of concern 

A.8. – 

F.1. – 

No data on effects to amphibians, fish used as a 

surrogate 

Exposures far below levels of concern 

A.8. – 

F.1. – H.2. – mollus
Site-

Appendix Q-15 

Imazapic 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Aquatic plants sensitive, algae is not 

Potential risk to aquatic 

plants at highest 

application rate only, no risk to algae 

A.8. – F.1. – 

Low toxicity to bees Exposure far below level of concern A.8. – 
Final Environmental Impact Statement 

Appendix Q-16 

Active Ingredient: Imazapyr Trade Name(s): Arsenal, Chopper, StalkerAquatic Formulation: HabitatMode of Action: acetolactate synthesis inhibitor Chemical Family: Imidazolinone Forest-Scenic Area target species: Known infestations – knotweeds Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Imazapyr 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Non-selective Uptake by roots & leaves; active in soil as preemergent 

May damage non-target plants; may be exuded into

soil from roots of treated plants 

Drift or runoff may cause some damage to 

susceptible species 

Do not apply to irrigation ditches; prevent drift to desirable plants 

C.2. – D.7. – E.1. – 

Very high water solubility Do not contaminate water F.1. – Weakly bound to soil, but OM and lower pH increase adsorption to moderate levels 

Moderately mobile in soils 

Photodegrades in H2O Half-life in water 1-2 d 

May be used in intermittent drainages, flood plains, 

and bogs when no water is present 

F.1. – F.3. – 

Degrades by soil microbes Half-life in soil 25-142 d; weed control for 3 mo-2yrs 

Slight effect on soil microbes at high doses 

Peak concentrations in soil well below level of concern 

A.8. – 
Site-

Appendix Q-17 

Imazapyr 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Mildly irritating to eyes and skin 

Mild eye irritation from mishandling; no exposure 

scenario exceeded RfD for workers or public except spill 

D.1. – equipm

Does not bioaccumulate or bioconcentrate 

No adverse effects to mammal reproduction or development, not carcinogenic or mutagenic No effects to birds or mammals even at high doses 

Exposures all below level 

of concern 

A.8. – 

No plausible risk to insectivorous species 

A.8. – 

Low toxicity to North American fish 

Exposures very far below 

levels of concern 

A.8. – F.1. – 

No data on effects to amphibians, fish used as a 

surrogate 

Exposures far below levels of concern 

A.8. – 

F.1. – H.2. – mollus

Some aquatic plant species sensitive to 

imazapyr 

Potential risk to aquatic plants at typical application rate, no risk to algae 

A.8. – F.1. – 

Low or no toxicity to bees Exposure well below level of concern A.8. – 
Final Environmental Impact Statement 

Appendix Q-18 

Active Ingredient: Metsulfuron methyl Trade Name(s): EscortMode of Action acetolactate synthesis inhibitor Chemical Family: Sulfonylurea Forest-Scenic Area target species: Known infestations – butter n’ eggs, houndstongue, thistles, St. Johnswort, tan

Invasive plants in close proximity – Dalmatian toadflax, Dyer’s toad, perennia

Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Metsulfuron methyl 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Selective for some broadleaf and woody species; can damage conifers 

E.1 – B

Resistant biotypes may develop 

Manage herbicide resistance, use IPM 

Potent herbicide; uptake by roots & leaves 

May damage non-target plants and trees; highly 

potent herbicide at low rates 

Drift, runoff or wind erosion, may cause 

damage to susceptible species 

This herbicide is injurious to plants at extremely low concentrations. Non-target 

plants may be adversely affected from drift and runoff. Do not use on irrigation ditches. 

C.2. – D.7. – E.1. – F.1. – 

High water solubility Runoff, leaching potential 

Do not contaminate water; do not apply or rinse 

equipment near desirable plants; 

B.7. – E.1. – F.1. – 
Site-

Appendix Q-19 

Metsulfuron methyl 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Low adsorption to clay, OM increases adsorption; active in soil as preemergent Very high mobility in soils 

Treatment of powdery, dry soil or light sandy soil when there is little 

likelihood of rainfall soon after treating may result in off target movement and possible damage to susceptible crops when soil particles are moved by wind or water. 

C.1. – C.3. – 

No photo degradation Slow microbial degradation at high pH, fast at low pH 

Typical half-life 30 d (range 1-6 wks) Short-term toxicity to soil microbes 

F.3. – 

Degrades by hydrolysis 

May be used in intermittent drainages, flood plains, 

marshes, and bogs when no water is present 

F.1. – A.8. – 

May alter insulin production, cholesterol 

levels, and triglycerides at high doses 

Exposures well below levels of concern even at highest application rates 

A.8. – D.1. – equipm

Irritates skin and eyes 

Mild eye irritation from mishandling; all exposures 

below levels of concern for workers and public 

Applicator and other handlers must wear longsleeved shirt, long pants, 

shoes plus socks 

Does not bioaccumulate or bioconcentrate 

No adverse effects to mammal reproduction or development, not carcinogenic or mutagenic Can cause body weight loss in mammals & birds 

Exposures well below 

levels of concern even at 

highest application rates 

A.8. – 

No plausible risk to insectivorous species 

A.8. – 
Final Environmental Impact Statement 

Appendix Q-20 

Metsulfuron methyl 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Low toxicity to fish, no effects to egg & fry 

Exposures very far below levels of concern 

A.8. – F.1. – 

No data on effects to amphibians, fish used as a 

surrogate 

Exposures very far below levels of concern 

A.8. – F.1. – H.2. – 

mollus

Can damage aquatic plants in acute exposures 

Potential risk to aquatic plants at typical application rate, no risk to algae 

A.8. – F.1. – 

Low or no toxicity to bees Exposure well below level of concern A.8. – 

F.1. – 
Site-

Appendix Q-21 

Active Ingredient: Picloram Trade Name(s): Tordon 22KMode of Action: Plant growth regulator Chemical Family: Pyridcarboxylic acid or picolinic Forest-Scenic Area target species: Known infestations – thistles, houndstongue, hawkweeds, Scotch broom, knap

tansy ragwort Invasive plants in close proximity – whitetop, leafy spurge, Mediterranean sag

skeletonweed, water hemlock 

Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Picloram 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proj

Selective: rate and season dependant; pre-emergent and soil active 

Off-site drift of picloram may cause damage to 

susceptible plant species 

Minimize drift and runoff 

C.2. – G.3. – sulfom

G.4. – year 

Target: composite, legume, buckwheat, and parsley families. Less affected families: mustard, lily, figwort. 

E.1. – 
Final Environmental Impact Statement 

Appendix Q-22 

Picloram 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proj

High water solubility Run-off, leaching potential; 

Under some conditions, picloram may also have a 

high potential for runoff into surface water... Do not apply directly to water, to areas where surface water is present. Do no allow runoff or spray to contaminate wells, irrigation ditches or any body of water used for irrigation or domestic purposes. 

D.7. – F.1. – G.3. – sulfom

G.4. – year 

Photodegradation Half-life in H20 is 2.6 days Weakly adsorbed to soils 

Very high mobility in soils; leaching potential greatest 

in sandy soils with low OM 

1-6% of application mobilized and reached drainage channels 

(monitoring results) 

Picloram is known to leach through soil into ground 

water under certain conditions as a result of agricultural use. Use of this chemical in areas where soils are permeable, particularly where the water table is shallow, may result in ground water contamination. 

A.8. – G.3. – sulfom

G.4. – year 

Degraded slowly in soil by microbes 

Half-life avg. 90 days (range 20-300 d) 

NTE 2 qts/ac/growing seas

on as a broadcast 

application 

G.3. – sulfom

G.4. – year 

Can inhibit microbial activity 

Microbial a

ctivity inhibition 

likely at rates used by FS 

G.3. – sulfom

G.4. – year 

Contaminated with hexachlorobenzene HCB (more than clopyralid) 

HCB is a persistent carcinogen and it 

bioaccumulates 

Exposure levels below level of conc

ern. Picloram 

does not present any substantial cancer risk. 

A.8. – 
Site-

Appendix Q-23 

Picloram 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proj

Does not bioaccumulate or bioconcentrate 

No adverse effects to mammal reproduction or 

development, not 

carcinogenic or mutagenic 

Weight loss and increased liver weight in mammals following long term exposure to high concentrations 

No exposures for workers or public exceeded levels 

of concern except spill 

A.8. – D.1. – equip

Moderate eye irritant, can cause skin sensitization 

Eye irritation and skin sensitization can occur with 

mishandling 

Applicator and other handlers must wear longsleeved shirt, long pants, 

shoes plus socks 

A.8. – D.1. – equip

Low in toxicity to mammals 

Exposure to insect-eating mammals exceed acute 

levels of concern only at highest application rates 

A.8. – 

Almost nontoxic to birds Exposures below levels of 

concern 

A.8. – 

Chronic risk to insecteating birds or mammals 

unknown at typical and highest rates 

A.8. – 

Toxic to fish 

Exposures exceed level of concern for listed fish at 

typical and highest application rate 

A.8. – F.1. – 

No data on effects to amphibians, fish used as a 

surrogate 

Potential adverse effects to amphibians at typical and 

highest application rates 

A.8. – F.1. – H.2. – mollu

Relatively nontoxic to bees 

Exposures below level of concern even at highest 

application rates 

A.8. – 
Final Environmental Impact Statement 

Appendix Q-24 

Active Ingredient: Sethoxydim Trade Name(s): POASTMode of Action: Inhibits acetyl co-enzyme (ACE) Chemical Family: Cyclohexanedione or cyclohexenForest-Scenic Area target species: Known infestations – reed canarygrass Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Sethoxydim 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Selective for annual and perennial grasses 

Low likelihood of impacting non-target plants from drift 

E.1. – C.2. – 

Soil activity prevents germination of grasses Absorbed rapidly by foliage and roots. Systemic Broadleaf and sedges are tolerant 

Some herbicide resistance can develop 

Very high water solubility Leaching, run-off potential Do not contaminate water. F.1. – Medium mobility in soil Photodegrades Phytolysis in <4 hours in soil; <1 hr in water Low soil persistence Degraded by soil microbes 5-25 day 1⁄2 life (avg is 5 days) Rapidly degraded 

Causes skin and eye irritation 

Skin or eye irritation from mishandling. 

Applicators and other 

handlers must wear coveralls over shortsleeved shirt and short 

pants; chemical resistant gloves and footwear, plus socks; protective eyewear; etc. 

D.1 – equipm
Site-

Appendix Q-25 

Sethoxydim 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Does not bioaccumulate or bioconcentrate 

Not mutagenic or carcinogenic 

A.8. – 

Can cause liver and blood toxicity in chronic doses 

All chronic exposures well below level of concern for 

workers and public 

A.8. – 

Decreased reproduction and maternal toxicity in high doses 

All acute exposures below level of concern except for 

drinking water contaminated by accidental spill 

A.8. – 

Reproductive and neurological effects to small mammals at high 

doses 

Exposures below levels of concern for mammals 

A.8. – 

Low toxicity to birds but reduced hatching for chronic exposures 

Exposures below levels of concern except chronic 

dose for grass-eating bird at highest application rate 

A.8. – 

Chronic risk to insecteating birds or mammals 

unknown at typical and highest rates 

Highly toxic to fish due to petroleum inert 

Exposure exceeds level of concern for federally listed 

fish at typical rate, and max exposure assumptions 

This product is toxic to aquatic organisms. Do not 

apply directly to water or to areas where surface water is present. 

A.8. – C.3. – F.1. – 

No data on effects to amphibians, fish used as a 

surrogate 

Plausible risk to amphibians 

A.8. – 

F.1. – H.2 – Smollus

Nontoxic to bees Exposure below level of 

concern 

A.8. – 
Final Environmental Impact Statement 

Appendix Q-26 

Active Ingredient: Sulfometuron methyl Trade Name(s): Oust XPMode of Action: acetolactate synthesis inhibitor Chemical Family: Sulfonylurea Forest-Scenic Area target species: Known infestations – reed canarygrass 

Invasive plants in close proximity – whitetop 

Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Sulfometuron methyl 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions & 

Information Proje

Non-selective Preemergent and post emergent. 

If a surfactant is used, contact with tree foliage may injure or kill trees. 

A.8. – 

A.9. – E.1. – 

Target: annual and perennial broadleaf weeds, some grasses and some woody tree species 

Do not apply more than 8 oz/ac/yr 

A.8. – 

Potent herbicide; uptake by roots & leaves 

May damage non-target plants and trees; highly 

potent herbicide at low rates 

Drift, runoff or wind erosion, may cause 

damage to susceptible species 

Potential for drift is an issue. Use weather and droplet size criteria 

C.1. – C.2. – C.3. – 

E.1. – 
Site-

Appendix Q-27 

Sulfometuron methyl 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions & 

Information Proje

Only medium solubility in water; difficult to create high concentrations 

May leach or runoff into water 

Low application rates and microbe degradation pose 

little risk for water contamination 

Do not treat dry or frozen soils, unless rainfall is anticipated 

A.8. – 

G.3. – sulfom

G.4. – year 

High mobility in soil 

Treatment of powdery, dry soil and light sandy soils 

when there is little likelihood of rainfall soon after treating may result in off target movement and possible damage to susceptible crops when soil particles are moved by wind or water. 

C.3. – G.3. – sulfom

G.4. – year 

Degraded by microbes, light and hydrolysis 

30 day 1⁄2 life in silt loam soils Some growth inhibition to soil microbes in lab, but not demonstrated while in soil 

Percolation could inhibit 

growth of microbes if lab 

results are relevant in the field 

G.3. – sulfom

G.4. – year 

Does not bioaccumulate or bioconcentrate 

Not mutagenic, carcinogenic 

A.8. – 

Reproductive and immune system effects to 

mammals at higher doses; very high doses cause neurotoxic effects 

Exposures far below levels of concern 

A.8. – 

Irritating to skin and eyes at high doses 

Mild irritation to skin and 

eyes from exposures to 

high levels from mishandling 

Only protected handlers may be in the area during

treatment 

A.8. – D.1. – equipm
Final Environmental Impact Statement 

Appendix Q-28 

Sulfometuron methyl 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization 

(SERA Risk Assess.) 

Label Restrictions & 

Information Proje

Causes hemolytic anemia and weight loss in mammals

Exposures far below levels of concern 

A.8. – 

Slightly toxic to fish. Highly toxic to embryo hatch 

Exposures very far below level of concern 

Do not apply directly to water or where surface 

water is present 

A.8. – F.1. – 

Can cause malformations in amphibians 

Exposures very far below 

level of concern 

A.8. – F.1. – H.2. – mollus

Low toxicity to bee Exposures well below level of concern A.8. – 
Site-

Appendix Q-29 

Active Ingredient: Triclopyr Trade Name(s): Garlon 4, Remedy, PathFinAquatic formulation: Garlon 3AMode of Action: Plant growth regulator Chemical Family: Pyridinecarboxylic acid Forest-Scenic Area target species: Known infestations – knotweeds, thistles, English ivy, blackberries, scotch bro

Invasive plants in close proximity – garlic mustard, policeman’s helmet 

Project Design Criteria (PDC) A.1. and A.2. applicable to all herbicide characteristics and risks. A.1. states: “Herbic

accordance with label instructions, except where more restricted measures are required as described . . .” And A.2. s

would comply with standards in the Pacific Northwest Regional Invasive Plant Program – Prevention and Managin(2005a), including standards on herbicide selection, broadcast use of some herbicides, tank mixing, licensed applicaadjuvants, surfactants and other additives.” Triclopyr 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization* 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Selective for broadleaf and woody plants Target: Woody and herbaceous plants, especially root- or stemsprouting species Absorbed thru roots, foliage and green bark. 

Non-target plant effects possible; some bryophytes 

and lichens sensitive to triclopyr 

Do not apply through any type of irrigation system. 

Two forms: salt (acid) (Garlon 3A) and ester (Garlon 4) 

Ester form more toxic and volatile 

Apply at cool temps with no wind. Combustible. 

C.1. – 

Salt formulation is highly soluble in water Runoff, leaching 

Do not contaminate water when cleaning 

equipment. 

A.3. – B.7. – D.7. – 

Ester formulation has medium water solubility. Less mobile 
Final Environmental Impact Statement 

Appendix Q-30 

Triclopyr 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization* 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Low adsorption to soils, varies with clay and OM content 

Very high mobility in soils 

The use of this chemical in areas where soils are 

permeable, particularly where the water table is shallow, may result in groundwater contamination. 

A.1. RApplic

G.1. – 

Degraded by photolysis in soil and water 1⁄2 life 2-6 hours in water Degraded by microbes in soil 

1⁄2 life avg 30days in soils; range 10-46 days Inhibits growth of soil fungi and bacteria 

Transient inhibition in the 

growth of some bacteria or 

fungi might be expected 

A.1. RApplic

Can cause severe eye damage 

Applicators and other 

handlers must wear longsleeved shirt and long 

pants; shoes plus socks; protective eyewear; chemical resistant gloves.

D.1. – equipm

Does not bioaccumulate or bioconcentrate 

Ester has much higher lipophilic tendancy (Kow = 

10, 233) than salt (Kow = 

0.35) 

Adverse effects to mammal reproduction or development only at doses 

that are maternally toxic 

Except for lactating dairy animals, there are no 

grazing restrictions 

A.8. – 

Evidence for carcinogenicity is marginal 

(not convincing, but not entirely negative) 

A.8. – 
Site-

Appendix Q-31 

Triclopyr 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization* 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Effects to kidney are basis of risk to for acute and chronic exposures humans 

At high application rates, chronic exposures to 

workers exceed level of concern; acute exposures do not exceed level of concern for workers. At high application rates, some acute and chronic exposures exceed level of concern for public. No exposures exceed level of concern at typical application rate. 

Do not apply this product in a way that will contact workers or other persons, 

either directly or through drift. 

A.8. – C.2. – D.1. – equipm

For wildlife, acute lethality only at very high doses, but effects to kidney and 

liver at lower doses 

Acute exposures below level of concern at typical 

application rate, but exceed 

level of concern for grass and insect eating mammals 

A.1. RApplic

Applic

Primary effect from chronic doses is to the kidney 

Using protective assumptions, chronic 

exposures exceed level of concern for grass-eating mammals. Risk from chronic exposure to contaminated insects unknown. 

A.1. RApplic

ApplicD.1. – equipm

Formulations contain inerts that are neurotoxic (Garlon 

3A = ethanol) (Garlon 4 = kerosene) 

Exposures very far below level of concern; less toxic than triclopyr 

A.8. – D.1. – 

equipm

Ester more toxic to birds that salt form 

Several scenarios exceed 

level of concern at typical 

and highest application rates for acute and chronic exposures 

A.1. RApplic

Applic
Final Environmental Impact Statement 

Appendix Q-32 

Triclopyr 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization* 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Salt/acid formulation low toxicity to fish; has aquatic 

use label 

Exposures exceed level of conc

ern for federally listed

fish at typical rate, but not other fish even at highest application rate 

(Garlon 3A) Permissible to treat flood plains, marshes, swamps, bogs 

etc. Permissible to treat non-irrigation ditch banks. When making application to banks or shorelines of moving water sites, minimize overspray to open water. 

A.1. RApplic

ApplicF.1. – 

Ester formulation toxic to fish and aquatic invertebrates 

Exposures exceed level of conc

ern for federally listed

fish at typical rate, but not other fish even at highest application rate 

(Garlon 4) This pesticide is toxic to fish. Do not 

apply directly to water, to areas where surface water is present... Do not contaminate water when disposing of equipment wash waters. 

A.1. RApplic

ApplicB.7. – F.1. – 

Metabolite TCP much more toxic to fish than the salt form, about the same toxicity as ester 

At typical application rate, no TCP exposures exceed 

level of concern. At highest application rate, chronic exposure exceeds level of concern 

A.8. – F.1. – 

Ester form much more toxic to aquatic plants and algae than salt form 

Only salt form exceeds level 

of concern for aquatic plants; algae not at risk from either form 

A.1. RApplic

ApplicF.1. – 

Ester formulation much more toxic to amphibians 

than salt formulation 

At typical application rate, risk to amphibians from either form is low. At highest 

rate, exposure to run-off of either form could adversely affect responsiveness of tadpoles. 

A.8. – F.1. – H.2. – mollus
Site-

Appendix Q-33 

Triclopyr 

Herbicide Characteristics 

Basic Hazard 

Identification 

Risk Characterization* 

(SERA Risk Assess.) 

Label Restrictions 

& Information Proje

Practically non-toxic to bees 

Exposure exceeds level of 

concern only for highest 

application rates 

A.8. – F.1. – 

*Results of these risk characterizations are from scenarios where triclopyr is broadcast sprayed over a large area. A 

Plan that was added by the Invasive Plant Program ROD (USDA Forest Service, 2005b) prohibits this type of applicrestricted to selective application methods only. Therefore, in practice, it is not plausible to create the exposures cauof triclopyr for invasive plant treatment in the USDA Forest Service, Pacific Northwest Region. 
Final Environmental Impact Statement 

Appendix Q-34 

Water Solubility Chart

Solubility Class 

Water Solubility 

(ppm=mg/L) Examples 

Very High 3,000 – 1,000,000 

chlorsulfuron, glyphosate, imazapic, imazapyr, picloram, 

sethoxydim, 

High 300-3,000 clopyralid, metsulfuron methyl, 2,4-D 

Medium 30-300 sulfometuron, triclopyr 

Low 2-30 

Slight 0.5-2 

Immobile <0.5 DDT (0.0012) 

From Jay Davis, US Fish and Wildlife Service 

Mobility in Soil (Koc)

Mobility Class Koc in Soil Examples 

Very High 0-35 clopyralid, picloram, metsulfuron methyl, triclopyr 

High 36-100 sulfomet.,chlrosufluron, 

Medium 100-1,000 imazapic, imazapyr, sethoxydim, atrazine 

Low 1,000-3,000 glyphosate 

Slight 3,000-10,000 Trifluralin 

Immobile >10,000 chlorpyrifos, DDT 

Adapted from Jay Davis, US Fish and Wildlife Service Mobility class categories by S.Bautista and are general breakdowns, not a definitive classification 
Site-

Appendix Q-35 

Grazing Restriction Table (Sources are Trade Name Labels for Specific Herbi

Livestock Use Restrictions by Herbicide* 

Herbicide 

Brand 

Name Restriction Remarks 

Chlorsulfuron 

Telar, Glean, Corsair, 

Landmark (oust + telar) 

None 

Clopyralid 

Transline, Redeem (Clopyralid + Triclopyr) 

Redeem: Do not graze treated areas until 

poisonous plants are dry and no longer 

palatable to livestock. Withdraw livestock from grazing treated grass at least 3 days prior to slaughter. 

See label for croplangrazing restrictions p

treatment in pastureRedeem: Herbicide application may incrpalatability of certain poisonous plants. 

Glyphosate RoundUp, Rodeo, etc. None

RoundUp: ingestion product or large amo

freshly sprayed vegemay cause temporagastrointestinal irrita

Imazapic Plateau 

Plateau: None. Plateau DG: Do not use on areas to be grazed. 

Imazapyr 

Arsenal, Chopper, 

Stalker 

Arsenal: none. Chopper: none. Stalker: none. 

Metsulfuron methyl 

(Escort)/Sulfonylurea None. 

This table is not meant to be an inclusive or up-to-date list; please refer to product labels for the m

accurate and inclusive information.
Final Environmental Impact Statement 

Appendix Q-36 

Grazing Restriction Table (Sources are Trade Name Labels for Specific Herbi

Livestock Use Restrictions by Herbicide*(continued) 

Herbicide 

Brand 

Name Restriction Re

Picloram Tordon 

Tordon 101/22K/K: allow one week of grazing/feeding in non-exposure area before 

moving livestock onto broadleaf cropland. Tordon 22K: herbicide application may increase palatability of certain poisonous plants. Do not graze treated areas until poisonous plants are dry and no longer palatable to livestock. Meat grazing animals up to two weeks after treatment should be removed from treated areas 3 days prior to slaughter. 

Sethoxydim Poast None Sulfometuron methyl 

(Oust)/Sulfonylurea, & Landmark (oust + telar) 

None 

Triclopyr 

(Garlon, Pathfinder, Remedy)/Synthetic auxin, Redeem (Clopyralid + Triclopyr) 

Forestry Garlon 4, Garlon 4, & Remedy: 2 quarts per acre or less, no restriction. If less than 25% of the grazing area is treated, there is no restriction. Slaughter: remove animals from treated area 3 days prior to slaughter. Garlon 3A: none. Remove animals from treated area 3 days prior to slaughter. Pathfinder II & Remedy RTU: 2.5 gallons per acre or less, no restriction. If less than 25% of the grazing area is treated, there is no restriction. Slaughter: remove animals from treated area 3 days prior to slaughter. Redeem: Do not graze treated areas until poisonous plants are dry and no longer palatable to livestock. Withdraw livestock from grazing treated grass at least 3 days prior to slaughter. 

This table is not meant to be an inclusive or up-to-date list; please refer to product labels for the most accurate information.
Site-

Appendix Q-37 

References BASF. 2002. Chopper herbicide (imazapyr). BASF Corporation. Research Triangle Park, NC. 7 pp. BASF. 2003. Plateau herbicide (imazapic). BASF Corporation. Research Triangle Park, NC. 16 pp. Dow AgroSciences. 1999. Specimen Label – Transline Specialty Herbicide (clopyralid). Revised 07-26-99. Dow A

Indianapolis, IN. 6 pp. 

Dow AgroSciences. 2000. Specimen Label – Tordon 22K (picloram). Revised 05-24-00. Dow AgroSciences LLC, IDow AgroSciences. 2001. Specimen Label – Forestry Garlon 4 Specialty Herbicide (triclopyr). Revised 02-26-01. D

Indianapolis, IN. 7 pp. 

Dow AgroSciences. 2003. Specimen Label – Garlon 3A Specialty Herbicide (triclopyr). Revised 03-19-03. Dow Ag

Indianapolis, IN. 9 pp. 

DuPont. DuPont Oust XP herbicide (sulfometuron methyl). 2002. E.I. du Pont de Nemours and Company. Wilming

DuPont. DuPont Telar DF herbicide (chlorsulfuron). 2002. E.I. du Pont de Nemours and Company. Wilmington, DeDuPont. DuPont Escort XP herbicide (metsulfuron methyl). 2005. E.I. du Pont de Nemours and Company. WilmingMicro Flow Company. Poast Herbicide label (sethoxydim). Micro Flow Company LLC. Memphis, Tennessee. 17 p

Monsanto. 2002. Roundup Original Herbicide (glyphosate). Monsanto Company. St. Louis, Missouri. 21 pp. 

Monsanto. 2004. Aquamaster Herbicide by Monsanto (glyphosate). Monsanto Company. St. Louis, Missouri. 19 ppSERA (Syracuse Environmental Research Associates, Inc.). 2001. Sethoxydim [Poast] - Human Health and Ecologi

Final Report. SERA TR 01-43-01-01c. October 31, 2001. 
Final Environmental Impact Statement 

Appendix Q-38 

SERA (Syracuse Environmental Research Associates I. 2003. Glyphosate- Human Health and Ecological Risk Asse

SERA TR 02-43-09-04a. March 1, 2003. 

SERA (Syracuse Environmental Research Associates, Inc.). 2003. Picloram - Revised Human Health and Ecologica

Report. SERA TR 03-43-26-01b. June 30, 2003. 

SERA (Syracuse Environmental Research Associates, Inc.). 2003. Triclopyr - Revised Human Health and Ecologic

Final Report. SERA TR 02-43-13-03b. March 15, 2003. 

SERA (Syracuse Environmental Research Associates, Inc.). 2004. Chlorsulfuron - Human Health and Ecological R

Report. SERA TR 04-43-18-01c. November 21, 2004. 

SERA (Syracuse Environmental Research Associates, Inc.). 2004. Clopyralid - Human Health and Ecological Risk 

Report. SERA TR 04-43-17-03c. December 5, 2004. 

SERA (Syracuse Environmental Research Associates, Inc.). 2004. Impazapic - Human Health and Ecological Risk A

Report. SERA TR 04-43-17-04b. December 23, 2004. 

SERA (Syracuse Environmental Research Associates, Inc.). 2004. Imazapyr - Human Health and Ecological Risk A

Report. SERA TR 04-43-17-05b. December 18, 2004. 

SERA (Syracuse Environmental Research Associates, Inc.). 2004. Metsulfuron methyl - Human Heath and Ecologi

Final Report. SERA TR 04-43-17-01b. December 9, 2004. 

SERA (Syracuse Environmental Research Associates, Inc.). 2004. Sulfometuron methyl - Human Health and Ecolo

Report. SERA TR 03-43-17-02c. December 14, 2004. 

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

Environmental Impact Statement Record of Decision. R6-NR-FHP-PR-02-05. USDA Forest Service, Pacific NoPortland, OR. October 2005. 40 pp. + appendices. 

Weed Science Society of America. 2002. Herbicide Handbook. 8th ed. William K. Vencill, ed. Weed Science Societ

Kansas. 493pp. 
APPENDIX R 

Adjuvants and Surfactants Addressed by 

Bakke (2003A) 
 
Site-Specific Invasive Plant Treatments 

Appendix R-1 

APPENDIX R: Adjuvants and Surfactants Addressed by Bakke 

(2003A) 

The following surfactants have been reviewed in risk assessments and may be used to help 

herbicides adhere to target plants (Bakke, 2003a). The effects of using these ingredients, along with 

other inerts and metabolites, have been disclosed in the Invasive Plant FEIS (2005a). Most 

surfactants do not have adverse effects of concern. At certain rates, NPE (Nonylphenol 

Polyethoxylate) surfactants have been shown to have adverse effects on human health and aquatic 

ecosystem elements so some limitations on their use have been included in the PDC. 

• Surfactants 

There are several different basic chemistries of surfactants. Examples of each1

: 

Ethoxylated fatty amines (Cationic) 

EntryTM II (Monsanto Company) 

POEA - Roundup® has 15 percent POEA 

Alkylphenol ethoxylate-based surfactants (non-ionic) 

R-11® Spreader Activator (Wilbur-Ellis Company) 

Activator 90 (Loveland Industries) 

X-77® (Loveland Industries) 

Latron AG-98TM (N) (Dow AgroSciences LLC) 

Latron AG-98TM (Dow AgroSciences LLC) 

Cide-kick®, Cide-kick® IITM (Brewer International) 

These surfactants usually include an alcohol as a solvent (isopropanol (X-77®, AG-98TM)), 

butanol (R-11®, AG-98TM (N)), glycol (AG-98TM (N), Activator 90), a silicone defoamer 

(polydimethylsiloxane), and water. 

 

1

 The use of product names is for illustrative purposes only and is not intended as a recommendation for use or an 

endorsement of these products by the USDA Forest Service. 
Final Environmental Impact Statement 

Appendix R-2 

Alcohol ethoxylate-based surfactants (non-ionic)

Activator N.F. (Loveland Industries) 

Silicone-Based Surfactants

Also known as organosilicones, these are increasing in popularity because of their superior 

spreading ability. This class contains a polysiloxane chain. Some of these are a blend of nonionic surfactants (NIS) and silicone while others are entirely silicone. The combination of 

NIS and a silicone surfactant can increase absorption into a plant so that the time between 

application and rainfall can be shortened. Examples: 

Sylgard® 309 (Wilbur-Ellis Company) –silicones 

Freeway® (Loveland Industries) –silicone blend 

Dyne-Amic® (Helena Chemical Company) - silicone blend 

Silwet L-77® (Loveland and Helena) - silicones 

Blends normally include an alcohol ethoxylate, a defoamer, and propylene glycol. 

Oils

Adjuvants that are primarily oil-based have been gaining in popularity especially for the 

control of grassy weeds. Oil additives function to increase herbicide absorption through 

plant tissues and increase spray retention. They are especially useful in applications of 

herbicides to woody brush or tree stems to allow for penetration through the bark. Oil 

adjuvants are made up of either petroleum, vegetable, or methylated vegetable or seed oils 

plus an emulsifier for dispersion in water. 

Vegetable Oils: The methylated seed oils are formed from common seed oils, such as 

canola, soybean, or cotton. They act to increase penetration of the herbicide. These are 

comparable in performance to crop oil concentrates. In addition, silicone-seed oil blends are 

also available that take advantage of the spreading ability of the silicones and the penetrating 

characteristics of the seed oils. 

The U.S. Food and Drug Administration (FDA) considers methyl and ethyl esters of fatty 

acids produced from edible fats and oils to be food grade additives (CFR 172.225). Because 

of the lack of exact ingredient statements on these surfactants, it is not always clear whether 

the oils that are used in them meet the U.S. FDA standard. 
APPENDIX S 

Economic Assumptions 
 
Site-Specific Invasive Plant Treatments 

Appendix R-3 

MSO® Concentrate Methylated Seed Oil (Loveland Industries) 

Hasten® (Wilbur-Ellis Company) 

The surfactant in PathfinderTM II (a triclopyr formulation) 

Improved JLB Oil Plus (Brewer International) 

Cide-Kick and Cide-Kick II (Brewer International) 

Blends of vegetable oils and silicone-based surfactants 

Syl-tacTM (Wilbur-Ellis Company) 

PhaseTM (Loveland Industries) 

Crop Oils and Crop Oil Concentrates: These are normally derivatives of paraffin-based 

petroleum oil. Crop oils are generally 95 to 98 percent oil with 1 to 2 percent 

surfactant/emulsifier. Crop oils also promote the penetration of a pesticide spray. Traditional 

crop oils are more commonly used in insect and disease control than with herbicides. Crop 

oil concentrates are a blend of crop oils (80 to 85 percent) and a nonionic surfactant (15 to 

20 percent). The purpose of the nonionic surfactant in this mixture is to emulsify the oil in 

the spray solution and lower the surface tension of the overall spray solution. 

kerosene (found in the triclopyr formulation Garlon 4), 

Agri-dex® (Helena Chemical Co. or Setre Chemical Co.) 

Red-Top Mor-Act® (Wilbur-Ellis Company) 

• Special Purpose or Utility Adjuvants 

The special purpose or utility adjuvants are used to offset or correct certain conditions 

associated with mixing and application such as impurities in the spray solution, extreme pH 

levels, and drift. These adjuvants include acidifiers, buffering agents, water conditioners, antifoaming agents, compatibility agents, and drift control agents. 

The pH of most solutions is not high or low enough for important herbicide breakdown in the 

spray tank. pH reducing adjuvants (example LI-700®) are sometimes recommended for use with 

herbicides because of greater absorption of weak acid type herbicides when the spray solution is 

acidic. 

LI-700® Surfactant Penetrant Acidifier – (Loveland Industries) 
Site-Specific Invasive Plant Treatments 

APPENDIX S: Economic Assumptions 

Assumptions used in the calculation of present value of costs for invasive plant treatments on the 

Forest and Scenic Area. Assumptions prepared by Malcolm Hamilton, Forest Recreation 

Program Manager, December 2005. 

No Action Alternative 

No Action treatment acres are based on actual treatments in fiscal year 2003: 

• 450 acres of herbicide treatments (Forest); 150 acres of herbicide treatment (Scenic Area) 

• 100 acres of manual treatments (Forest); 25 acres of manual treatment (Scenic Area) 

• 10 acres of mechanical treatment (Forest); 500 acres of mechanical treatment (Scenic 

Area). 

With two exceptions, all areas are treated once per year for one year. The exceptions are the 

Sandy River Delta and the utility corridor under the Big Eddy-Ostrander powerline. About 130 

acres of the Sandy River Delta are treated each year. Treatment consists of three separate 

applications of herbicide. The powerline corridor site is sprayed with herbicide two times each 

year. 

To provide an equal timeframe for comparison to the two action alternatives, the No Action 

Alternative treatments were analyzed over a five year time horizon. 

Proposed Action and Reduced Herbicide Alternatives 

• Priority 1 and 2 sites with site objectives of eradicate and contain would receive the most 

intense treatments. Except as noted below, herbicide treatments would be applied three 

times per year for the first three years. 

• Picloram and Clopyralid would only be used one time per year at any site regardless of 

the prescription, priority or treatment strategies. 

• Triclopyr would be limited to hand/selective application techniques only (spot or 

backpack spray, wiping, basal bark, cut stump, injection). 

• Where broadcast herbicides applications methods (e.g., boom spraying) is the preferred 

treatment method, it would be done only one time and only during the first year of 

treatment. Subsequent herbicide treatments would employ some method of hand/selective 

application. The cost of backpack spraying was used for subsequent herbicide treatments. 

• All priority 1 and 2 sites would have active restoration, regardless of the treatment 

strategy. 

• Priority 3, 4, and 5 sites would be treated only once per year with herbicides. 

Appendix S-1 
Final Environmental Impact Statement 

• Active restoration would begin when all herbicide treatments are complete. 

• Some inventoried sites have multiple invasive plant species. The Proposed Action and the 

Restricted Herbicide Use Alternative both prescribe a suite of herbicides because of 

differential effects on the various plant species. Only one herbicide per site is analyzed, 

however. For upland treatment sites, the first herbicides listed in the inventory database 

for the site was used. For aquatic influence areas, the cost of aqueous glyphosate (Rodeo) 

is used. 

• The present value of costs for each of the alternatives includes proposed treatment areas 

only. The cost of the early detection / rapid response strategy (EDRR) is not included. 

• None of the treatments would be expected to be 100 percent effective in the early stages. 

For the purpose of cost analysis only, it is assumed that each year’s regime of vegetative 

treatments would be 80 percent effective in the Proposed Action and 60 percent effective 

in the Restricted Use Herbicide Alternative. 

• Restoration would occur on 50 percent of upland treatment areas, and 95 percent of 

aquatic influence areas corresponding to Forest Plan standards for vegetative ground 

cover. 

• Analysis for the Proposed Action (rows of data and statistics in Table 3-10) assumes five 

years of integrated treatments for every acre of inventoried invasive plants as described 

above. Treatment acres in years 2 through 5 are reduced by 80 percent per year, as shown 

in the table below, to simulate the effectiveness of treatment. Treatment of any given acre 

is assumed to be accomplished at the end of year 5. Because each area is treated for five 

years, the number of “new” acres treated in years 2 through N is reduced by 80 percent in 

order to maintain a fixed budget for each treatment regime. The table below demonstrates 

these assumptions for a hypothetical treatment regime of 1000 acres treated each year. In 

order to maintain a steady budget of 1000 acres of annual treatment, only 800 new, 

previously untreated acres are treated in years 2 through N. 

Treatment Year 

1 2 3 4 5 6 7 N N+1 N+2 N+3 N+4 

1000 200 40 8 1.6 

 800 160 32 6.4 1.6 

 800 160 32 6.4 1.6 

 800 160 32 6.4 1.6 

 800 160 32 6.4 1.6 

 800 160 32 6.4 1.6 

 800 160 32 6.4 1.6 

 800 160 32 6.4 1.6

1000 1000 1000 1000 1000 1000 1000 1000 200 40 8 1.6

Appendix S-2 
Site-Specific Invasive Plant Treatments 

• Analysis for the Restricted Herbicide Use alternative (rows of data and statistics in Table 

3-11) assumes five years of integrated treatments for every acre of inventoried invasive 

plants as described above. Treatment acres in years 2 through 5 are reduced by 60 percent 

per year, as shown in the table below, to simulate the effectiveness of treatment. 

Treatment of any given acre is assumed to be accomplished at the end of year 5. Because 

each area is treated for five years, the number of “new” acres treated in years 2 through N 

is reduced by 60 percent in order to maintain a fixed budget for each treatment regime. 

The table below demonstrates these assumptions for a hypothetical treatment regime of 

1000 acres treated each year. In order to maintain a steady budget of 1000 acres of annual 

treatment, only 600 new, previously untreated acres are treated in years 2 through N. 

Treatment Year 

1 2 3 4 5 6 7 N N+1 N+2 N+3 N+4

1000 400 160 64 26 

 600 240 96 38 26 

 600 240 96 38 26 

 600 240 96 38 26 

 600 240 96 38 26 

 600 240 96 38 26 

 600 240 96 38 26 

 600 240 96 38 26

1000 1000 1000 1000 1000 1000 1000 1000 400 160 64 26

Appendix S-3 
APPENDIX T 

Labor Cost, Wage Income and Potential Job 

Estimates 
 
Site-Specific In

APPENDIX T: Labor Cost, Wage Income and Potential Job Estimates Assumptions and data used for jobs created analysis for invasive plant treatments on the Forest and Scenic Area. prepared by Elisabeth Grinspoon, Social Scientist, January 2006. 

Treatment Type Acres Labor ($) Equipment ($) Herbicide ($) Total ($) Labor Cost ($) Wag

Alternative 1 - No Action Alternative Herbicide Treatment 4500 $175.00 $630,000.00Manual Treatment 625 $340.00 $212,500.00Mechanical Treatment 510 $100.00 $20,400.00Monitoring 6175 $2.00 $12,350.00Planning 1915 $2.00 $3,830.00

Sub-total $879,080.00 $7

Alternative 2 - Proposed Action Herbicide Treatment with Clopyralid, Backpack Spray 

3374 $184.00 $20.00 $38.00 $242.00 $620,750.86

Herbicide Treatment with Clopyralid, Truck Mounted Boom 

10084 $9.00 $8.00 $38.00 $55.00 $90,757.80

Herbicide Treatment with AQ Glyphosate, Backpack Spray 

2225 $184.00 $20.00 $21.00 $225.00 $409,362.54

Herbicide Treatment with AQ Glyphosate, Stem Injection 

1214 $184.00 $0.00 $21.00 $205.00 $223,290.62

Herbicide Treatment with Glyphosate, Stem Injection 

10 $184.00 $0.00 $29.00 $213.00 $1,848.10

Appendix T-1 
Final Environmental Impact Statement 

Treatment Type Acres Labor ($) Equipment ($) Herbicide ($) Total ($) Labor Cost ($) Wag

Herbicide Treatment with Imazapic, Backpack Spray 

166 $184.00 $20.00 $16.00 $220.00 $30,527.44

Herbicide Treatment with Imazapic, Truck Mounted Boom 

232 $9.00 $8.00 $16.00 $33.00 $2,088.00

Herbicide Treatment with Sulfometuron methyl, Backpack Spray 

4 $184.00 $20.00 $12.00 $216.00 $812.40

Herbicide Treatment with Sulfometuron methyl, Truck Mounted Boom 

17 $9.00 $8.00 $12.00 $29.00 $156.60

Herbicide Treatment withTriclopyr, Backpack Spray 

170 $184.00 $20.00 $116.00 $320.00 $31,235.10

Manual Treatment 24 $340.00 $8,251.66Mechanical Treatment 183 $100.00 $7,302.88Monitoring 65406 $2.00 $130,812.00Project Implementation Planning 13081 $2.00 $26,162.40Active Restoration 1923 $1,000.00 $769,213.60

Sub-total $2,352,572.00 $1,8

Alternative 3 - Restricted Herbicide Use Alternative Herbicide Treatment with Clopyralid, Backpack Spray 

3610 $184.00 $20.00 $38.00 $242.00 $664,221.60

Herbicide Treatment with Clopyralid, Truck Mounted Boom 

562 $9.00 $8.00 $38.00 $55.00 $5,058.00

Appendix T-2 
Site-Specific In

Treatment Type Acres Labor ($) Equipment ($) Herbicide ($) Total ($) Labor Cost ($) Wag

Herbicide Treatment with AQ Glyphosate, Backpack Spray 

2792 $184.00 $20.00 $21.00 $225.00 $513,769.95

Herbicide Treatment with AQ Glyphosate, Stem Injection 

20 $184.00 $0.00 $21.00 $205.00 $3,749.18

Herbicide Treatment with Glyphosate, Stem Injection 

36 $184.00 $0.00 $29.00 $213.00 $6,630.62

Herbicide Treatment with Imazapic, Backpack Spray 

977 $184.00 $20.00 $16.00 $220.00 $179,716.48

Manual Treatment 1431 $340.00 $486,635.20Mechanical Treatment 22882 $100.00 $915,271.60Monitoring 65406 $2.00 $130,812.00Project Implementation Planning 13081 $2.00 $26,162.40Active Restoration 2626 $1,000.00 $1,050,442.00

Sub-total $3,982,469.04 $3,1

Notes: 

• Labor costs for manual treatments include costs for project implementation planning and monitoring, which are as

total cost. 

• Labor costs for mechanical treatments are assumed to be 40% of total cost. 

• Labor costs of herbicide treatment under the No Action Alternative (Alternative 1) are calculated as 80% of total c

calculations for labor cost in herbicide treatments in both Proposed Action and Restricted Herbicide Use alternativ

• Wage income is calculated as 80% of labor cost given a 20% cost in taxes and benefits. 

• Total ($) in is the sum of Labor ($), Equipment ($), and Herbicide ($). 

Appendix T-3 
 
APPENDIX U 

Effects on Soil Properties: Review of 

Proposed Herbicides 
 
Site-Specific Invasive Plant Treatments 

APPENDIX U: Effects on Soil Properties: Review of Proposed 

Herbicides 

General characteristics for the proposed herbicides are displayed in Table 3-17 in Section 3.8 – 

Soil Productivity. Appendix prepared by John Dodd, Forest Soil Scientist, November 2005.

Chlorsulfuron 

Studies on the effects of chlorsulfuron on soil biota include lab and field studies on nematodes; 

fungi; populations of actinomycetes, bacteria, and fungi; and soil microorganisms. 

• Relatively little information is available on the toxicity of chlorsulfuron to soil 

invertebrates. 

• No effects of chlorsulfuron were found for soil biota at recommended application rates, 

with the exception of transient decreases in soil nitrification (SERA, 2003a). 

• The ‘no observable effects concentration’ for soil is 10 mg/kg, based on cellulose and 

protein degradation. 

• Chlorsulfuron degrades in aerobic soil. 

• Non-microbial hydrolysis plays an important role in chlorsulfuron breakdown, and 

hydrolysis rates increase as pH increases. 

• Adsorption to soil particles, which affects the runoff potential of chlorsulfuron, is 

strongly related to the amount of organic material in the soil. 

• Chlorsulfuron adsorption to clay is low. 

• Chlorsulfuron is moderately mobile at high pH. 

• Leaching is reduced when pH is less than six. 

• Modeling results indicate that runoff would be negligible in relatively arid environments 

as well as sandy or loam soils. 

• In clay soils, off-site loss could be substantial (up to about 55 percent of the applied 

amount) in regions with annual rainfall rates of 15 to 250 inches (SERA, 2003a; 

Herbicide Handbook, 2002). 

Appendix U-1 
Final Environmental Impact Statement 

Clopyralid 

Studies of clopyralid effects on soil invertebrates have been conducted, including field studies on 

the effects to microorganisms. 

• Soil concentrations from USDA Forest Service applications are expected to be 1,000 less 

than concentrations that would cause toxic effects. Therefore, no effects to soil 

invertebrates or microorganisms are expected from use of clopyralid (SERA, 1999a). 

• Clopyralid is degraded by soil microbes, with an estimated half-life of 14 to 29 days, 

meaning that one-half of the amount applied remains in the soils after 90 days, one-fourth 

of the applied amount remains after 28 to 58 days, one –eight after 42 to 87 days, and so 

on. 

• Increased soil moisture decreases degradation time. 

 

• Clopyralid is weakly adsorbed and has moderate leaching potential. 

• Modeling results indicate clopyralid runoff is highest in clay soils with peaks after 

rainfall events. 

• Clopyralid percolation is highest in sandy loam soils (SERA, 1999a; Herbicide 

Handbook, 2002). 

Glyphosate 

Numerous soil bacteria, fungi, invertebrates, and other microorganisms have been studied for 

effects of glyphosate application. 

• There is nothing to suggest glyphosate would adversely affect soil organisms. 

• Glyphosate is readily metabolized by soil microorganisms and some species can use 

glyphosate as a sole source of carbon (SERA, 2003b). 

• It is degraded by microbial action in both soil and water. 

• Sylvia and Jarstfer (1997) found that after 3 years, pine trees in plots with grassy weeds 

had 75 percent fewer mycorrhizal root tips than plots that had been treated 3 times per 

year with a mixture of glyphosate and metsulfuron methyl to remove weeds. 

• Glyphosate degrades in soil, with an estimated half-life of 30 days. 

• Glyphosate is highly soluble, but adsorbs rapidly and tightly to soil. 

Appendix U-2 
Site-Specific Invasive Plant Treatments 

• Glyphosate has low leaching potential because it binds so tightly to soil. 

• Modeling results indicate glyphosate runoff is highest in loam soils with peaks after the 

first rainfall (SERA, 2003b; Herbicide Handbook, 2002). 

Imazapic 

Imazapic is a relatively new herbicide, and there are no studies on the effects of imazapic on 

either soil invertebrates or soil microorganisms. 

• If imazapic was extremely toxic to soil microorganisms, it is reasonable to assume that 

secondary signs of injury to microbial populations would have been reported (SERA, 

2001a). 

 

• Imazapic degrades in soil, with a half-life of about 113 days. 

 

• Half-life is decreased by the presence of microflora. 

• Imazapic is primarily degraded by microbes and it does not degrade appreciably under 

anaerobic conditions. 

• Imazapic is weakly adsorbed in high soil pH, but adsorption increases with lower pH 

(acidic soils) and increasing clay and organic matter content. 

• Field studies indicate that imazapic remains in the top 12 to 18 inches of soil and do not 

indicate any potential for imazapic to move with surface water. 

• Modeling results indicate imazapic runoff is highest in clay and loam soils with peaks 

after the first rainfall. 

• Imazapic percolation is highest in sandy soils (SERA, 2001a; Herbicide Handbook, 

2002). 

Imazapyr 

There are no studies on the effects of imazapyr on soil invertebrates, and incomplete information 

on the effects on soil microorganisms. 

• One study indicates cellulose decomposition, a function of soil microorganisms, can be 

decreased by soil concentrations higher than concentrations expected from USDA Forest 

Service applications. 

• There is no basis for asserting adverse effects to soil microorganisms (SERA, 1999b). 

Appendix U-3 
Final Environmental Impact Statement 

• Imazapyr degrades in soil, with a half-life of 25 to 180 days. 

• Degradation rates are highly dependent on microbial action. 

• Anaerobic conditions slow degradation. 

• Imazapyr is weakly bound to soil, but adsorption increases with lower pH and 

increasing clay and organic matter content. 

• Adsorption increases with time as soil dries and is reversible. 

• Field studies indicate that imazapic remains in the top 20 inches of soil and do not 

indicate any potential for imazapic to move with surface water. 

• In forest field studies, imazapyr did not run off and there was no evidence of lateral 

movement. 

• Modeling results indicate imazapyr runoff is highest in clay and loam soils with peaks 

after the first rainfall. 

• Imazapyr percolation is highest in sandy soils (SERA, 1999b; Herbicide Handbook, 

2002). 

Metsulfuron methyl 

Studies on the effects of metsulfuron methyl on soil biota are limited to Pseudomonas species, 

though there are a few studies of insects that live in soil. The lowest observed effect 

concentration is 5 mg/kg, based on the Pseudomonas study. At recommended use rates, no 

effects are expected for insects. 

• Effects to soil microorganisms appear to be transient (SERA, 2003c). 

• Metsulfuron methyl degrades in soil, with a variable half-life up to 120 days. 

• Half-life is decreased by the presence of organic matter though microbial degradation of 

metsulfuron methyl is slow. 

• Non-microbial hydrolysis is slow at high pH but rapid at lower pH. 

• Adsorption to soil particles, which affects the runoff potential of metsulfuron methyl, 

increased with increased pH and organic matter. 

• Metsulfuron methyl has low adsorption to clay. 

Appendix U-4 
Site-Specific Invasive Plant Treatments 

• Modeling results indicate that off-site movement due to runoff could be significant in 

clay soils. 

• Metsulfuron methyl percolates in sandy soils (SERA, 2003c; Herbicide Handbook, 

2002). 

Picloram

The persistence of picloram increases with soil concentration, thus increasing the likelihood that 

it becomes toxic to soil microorganisms in the short-term. 

• Since picloram is toxic to microorganisms at low levels, toxic effects can last for some 

time after application. 

• Persistence in soils could affect soil microorganisms by decreasing nitrification. 

• Long-term effects to soil microorganisms are unknown (SERA, 2003d). 

• Picloram applied at a typical application rate is likely to change microbial metabolism, 

though detectable effects to soil productivity are not expected. 

• Field studies (Brooks et. al., 1995; Nolte and Fulbright, 1997) have not noted substantial 

adverse effects associated with the normal application of picloram that might be expected 

if soil microbial activity were substantially damaged. (SERA, 2003d) 

• Substantial effects to soil productivity from the use of picloram over the last 40 years 

have not been noted (SERA, 2003d). 

• Picloram has been studied on a number of soil invertebrates. 

• Metabolites may increase toxicity for some soil microorganisms. 

• Picloram has a typical half-life of 90 days. 

• However, picloram soil degradation rates vary in soil, depending on application rate and 

soil depth. 

• Picloram is water soluble, poorly bound to soils that are low in clays or organics, has a 

high leaching potential, and is most toxic in acidic soil. 

• Picloram should not be used on coarse-textured soils with a shallow water table, where 

groundwater contamination is most likely to occur (KSU, 2001; SERA, 2003d). 

• Picloram percolation is highest in loam and sandy soils (SERA, 2003d; Herbicide 

Handbook, 2002). However, modeling results indicate picloram runoff (not percolation) 

is highest in clay soils. 

Appendix U-5 
Final Environmental Impact Statement 

Sethoxydim 

Sethoxydim has not been studied on soil invertebrates. 

• Assays of soil microorganisms noted transient shifts in species composition at soil 

concentration levels far exceeding concentrations expected from USDA Forest Service 

application. 

• No adverse effects to soil organisms are expected (SERA, 2001c). 

• Sethoxydim is degraded by soil microbes, with an estimated half-life of 1 to 60 days. 

Adsorption of sethoxydim varies with organic material content. 

• Modeling results indicate sethoxydim runoff is highest in clay and loam soils with 

peaks after the first rainfall (SERA, 2001c; Herbicide Handbook, 2002). 

Sulfometuron methyl 

There are no studies on the effects of sulfometuron methyl on soil invertebrates. However, it is 

toxic to soil microorganisms. Microbial inhibition is likely to occur at typical application rates 

and could be substantial. Soil residues may alter composition of soil microorganisms. 

Sulfometuron methyl applied to vegetation at rates to control undesirable vegetation would 

probably be accompanied by secondary changes in the local environment that affect the soil 

microbial community more certainly than direct toxic action of sulfometuron methyl on 

microorganisms (SERA, 2003e). 

• The typical half-life for sulfometuron methyl varies from 10 to 100 days, depending on 

soil texture. Half-life decreases as soil particle size decreases. Presence of soil 

microorganisms also decreases half-life, though microbial breakdown occurs slowly. 

Sulfometuron methyl degradation occurs most rapidly at lower pH soils where rates are 

dominated by hydrolysis. 

• Sulfometuron methyl mobility is generally greater at higher soil pH and lower organic 

matter content. 

• Modeling results indicate sulfometuron methyl runoff is highest in clay and loam soils 

with peaks after the first rainfall. Sulfometuron methyl percolation is highest in sandy 

soils. Monitoring results generally support modeling results (SERA, 2003e; Herbicide 

Handbook, 2002). 

Appendix U-6 
Site-Specific Invasive Plant Treatments 

• Sulfometuron methyl applied to vegetation at typical application rates would probably be 

accompanied by secondary changes to vegetation that affect the soil microbial 

community more certainly than direct toxic action of sulfometuron methyl on soil 

microorganisms (SERA, 2003e). Arthur and Wang (1999) found that a formulation of 

sulfometuron methyl had a negative impact on the abundance of microorganisms and 

decreased soil nitrogen content on a Christmas tree farm. 

Triclopyr 

The five commercial formulations of triclopyr contain one of two forms of triclopyr, BEE 

(butoxyethyl ester) or TEA (triethylamine). Triclopyr BEE is much more toxic to aquatic 

organisms than triclopyr TEA. A breakdown product, TCP (3,5,6-trichloro-2-pyridinol), is more 

toxic than either form of triclopyr. Site-specific cumulative effects analysis buffer determinations 

need to consider the form of triclopyr used and the proximity of any aquatic triclopyr 

applications, as well as toxicity to aquatic organisms (SERA, 2003f).

• Triclopyr has not been studied on soil invertebrates. 

• Soil fungi growth was inhibited at concentrations 2 to 5 times higher than concentrations 

expected from USDA Forest Service application rates. 

• Triclopyr has an average half-life in soil of 46 days, while TCP has an average half-life in 

soil of 70 days. Warmer temperatures decrease the time to degrade triclopyr. 

• Soil adsorption is increased as organic material increases and decreased as pH 

increases. Triclopyr is weakly adsorbed to soil, though adsorption varies with organic 

matter and clay content. Both light and microbes degrade triclopyr (SERA, 2003f; 

Herbicide Handbook, 2002).

Impurities 

“Virtually no herbicide synthesis yields a totally pure product. Technical grade herbicides 

undoubtedly contain some impurities” (SERA, All risk assessments). Herbicide-specific risk 

assessments include the identity of impurities, if it is available. In some instances, toxicity and 

mobility of impurities is studied in conjunction with the technical grade of the herbicide. In other 

instances, risks of the impurities are assessed separately from the herbicide. Some impurities are 

more toxic than the associated herbicide, but the risks are minimized due to low concentrations 

of the impurity in the herbicide. 

Hexachlorobenzene, classified as a human carcinogen, is an impurity in both clopyralid and 

picloram (SERA, 1999a and 2003d). Hexaclorobenzene is ubiquitous and persistent in the 

environment and volatizes from the soil surface. Because hexachlorobenzene binds tightly to 

soil, it is not likely to percolate through soil to contaminate groundwater. 

Appendix U-7 
Final Environmental Impact Statement 

Metabolites 

Metabolites are substances created by the metabolism of herbicides. Most herbicides considered 

are not readily metabolized by aquatic animal species, and are passed through their bodies 

unchanged. Most herbicides are metabolized microbially. Herbicide-specific risk assessments 

include the identity of known metabolites. Some metabolites are more toxic or persistent than the 

associated herbicide, but the risks can be minimized by choosing herbicides appropriate to 

environmental factors such as soil type and climate. 

Soil microbes are able to use NPE surfactants and breakdown products. Concern has been 

expressed about the potential for surfactant increasing the movement of other harmful materials, 

such as pesticides, into soils. A study shows that this is not a concern at soil concentrations 

resulting from typical USDA Forest Service application rates. In the presence of oxygen, NPE is 

biodegradable in soil or water, with a half-life of a few up to 90 days. Breakdown products 

biodegrade more slowly, but are ultimately biodegradable (Bakke, 2003a). 

Appendix U-8 
APPENDIX V 

Drinking Water Protection Areas 
 
Site-Specific Invasive Plant Treatments 

APPENDIX V: Drinking Water Protection Areas 

Treatment areas within drinking water protection areas, including drinking water source number 

and treatment acres. All treatment areas are located on the Mt. Hood National Forest. 

Treatment Drinking Water Source 

ID # Name Number City 

Treatment 

Acres

61-095 Dog River 500030 The Dalles 0.10

65-001 Frog Lake 101635 Sandy 33.30

65-002 Clackamas River (Estacada) 100426 Estacada 61.03

65-002 Clackamas River (Estacada) 100426 Estacada 0.56

65-003 Frog Lake 101635 Sandy 64.81

65-005 Clackamas River (Estacada) 100426 Estacada 0.06

65-006 Clackamas River (Estacada) 100426 Estacada 0.24

65-007 Clackamas River (Clackamas) 100284 Clackamas 3.38

65-008 Clackamas River (Estacada) 100426 Estacada 0.20

65-009 Clackamas River (Estacada) 100426 Estacada 1.03

65-010 Frog Lake 101635 Sandy 12.99

65-011 Clackamas River (Estacada) 100426 Estacada 1.07

65-012 Clackamas River (Estacada) 100426 Estacada 12.38

65-013 Clackamas River (Estacada) 100426 Estacada 46.77

65-014 Clackamas River (Estacada) 100426 Estacada 4.54

65-015 Clackamas River (Estacada) 100426 Estacada 17.01

65-015 Clackamas River (Estacada) 100426 Estacada 1.67

65-016 Clackamas River (Estacada) 100426 Estacada 4.01

65-017 Clackamas River (Estacada) 100426 Estacada 4.05

65-018 Clackamas River (Estacada) 100426 Estacada 1.09

65-019 Clackamas River (Estacada) 100426 Estacada 3.58

65-019 Clackamas River (Estacada) 100426 Estacada 1.37

65-020 Clackamas River (Estacada) 100426 Estacada 347.07

65-020 Clackamas River (Estacada) 100426 Estacada 3.58

65-020 Clackamas River (Estacada) 100426 Estacada 62.36

65-020 Clackamas River (Estacada) 100426 Estacada 1.37

65-021 Clackamas River (Estacada) 100426 Estacada 3.22

65-022 Clackamas River (Estacada) 100426 Estacada 5.18

65-023 Clackamas River (Estacada) 100426 Estacada 416.39

65-024 Clackamas River (Estacada) 100426 Estacada 4.58

65-025 Clackamas River (Estacada) 100426 Estacada 2.80

65-026 Clackamas River (Estacada) 100426 Estacada 4.72

65-027 Clackamas River (Estacada) 100426 Estacada 0.73

Appendix V-1 
Final Environmental Impact Statement 

Treatment Drinking Water Source 

ID # Name 

Treatment 

Number City Acres

65-028 Clackamas River (Estacada) 100426 Estacada 0.77

65-029 Clackamas River (Estacada) 100426 Estacada 11.63

65-030 Clackamas River (Estacada) 100426 Estacada 11.39

65-031 Clackamas River (Estacada) 100426 Estacada 14.27

65-032 Clackamas River (Estacada) 100426 Estacada 2.74

65-033 Clackamas River (Estacada) 100426 Estacada 9.64

65-034 Frog Lake 101635 Sandy 5.20

65-035 Frog Lake 101635 Sandy 5.30

65-036 Clackamas River (Estacada) 100426 Estacada 3.62

65-037 Frog Lake 101635 Sandy 0.39

65-038 Clackamas River (Estacada) 100426 Estacada 1.08

65-039 Frog Lake 101635 Sandy 0.28

65-040 Clackamas River (Estacada) 100426 Estacada 1.67

65-041 Clackamas River (Estacada) 100426 Estacada 4.18

65-042 Clackamas River (Estacada) 100426 Estacada 9.65

65-043 Clackamas River (Estacada) 100426 Estacada 18.51

65-044 Clackamas River (Estacada) 100426 Estacada 23.02

65-045 Clackamas River (Estacada) 100426 Estacada 0.11

65-046 Clackamas River (Estacada) 100426 Estacada 8.31

66-033 South Fork Mill Creek 101342 The Dalles 0.63

66-042 South Fork Mill Creek 101342 The Dalles 2.78

66-074 South Fork Mill Creek 101342 The Dalles 21.49

66-081 South Fork Mill Creek 101342 The Dalles 0.01

66-086 Frog Lake 101635 Sandy 0.06

69-003 North Fork Gordon Creek 100530 Corbett 28.69

69-005 North Fork Gordon Creek 100530 Corbett 19.57

69-005 South Fork Gordon Creek 106541 Corbett 12.14

69-007 South Fork Gordon Creek 106541 Corbett 0.48

69-008 Bull Run 101008 Portland 1.37

69-027 Clackamas River (Estacada) 100426 Estacada 150.73

69-027 Clackamas River (Estacada) 100426 Estacada 0.56

69-027 Clackamas River (Estacada) 100426 Estacada 1.67

69-027 Clackamas River (Estacada) 100426 Estacada 62.36

69-027 Clackamas River (Estacada) 100426 Estacada 1.37

Grand Total 1562.92

Appendix V-2 
APPENDIX W 

Summary Tables of Site-Specific Herbicide 

Effects for Various Aquatic Species 
 
Site-Specific Invasive Plant Treatments 

APPENDIX W: Summary Tables of Site-Specific Herbicide 

Effects for Various Aquatic Species

Tables prepared by Gary Asbridge, Fish Biologist, February 2006; updated, August 2006. 

Table W-1. Toxicity indices for fish used in the effects analysis for the EIS. For each herbicide 

if more than one study or data set for a given fish species or life stage was available, the smallest 

dose was used to ensure that potential effects to all species and life stages would be addressed. 

Thus, for some species and life stages the dose is conservative. Likewise, if the chronic value 

was less than the acute value it was used in the effects analysis. 

Herbicide Duration Endpoint Dose Species 

Chlorsulfuron Acute NOEC 2 mg/l* Brown trout 

Clopyralid Acute NOEC 5 mg/l* Rainbow trout 

AQ Glyphosate Acute NOEC 0.5 mg/l* Rainbow trout 

Glyphosate Acute NOEC 0.065 mg/l* Rainbow trout 

Imazapic Acute NOEC 100 mg/l All fish 

Imazapyr Acute NOEC 5 mg/l* Trout, catfish, bluegill 

Metsulfuron methyl Chronic NOEC 4.5 mg/l Rainbow trout 

Picloram Acute NOEC 0.04 mg/l* Cutthroat trout 

Sethoxydim Acute NOEC 0.06 mg/l* Rainbow trout 

Sulfometuron methyl Chronic NOEC 1.17 mg/l Fathead minnow 

AQ Triclopyr (TEA) Acute NOEC 0.26 mg/l* Chum salmon 

Triclopyr (BEE) Acute NOEC 0.012 mg/l Bluegill, sunfish 

* 1/20th of the LC50

Table W-2. Toxicity concentrations for aquatic macroinvertebrates, aquatic macrophytes and 

algae that were used in the effects analysis for this EIS. Toxicity values are the same as those 

used by the USDA Forest Service in the Invasive Plant FEIS (2005a). Toxicity values were not 

available (NA) for some herbicides and/or organisms. 

Toxicity Concentration (mg/l) 

Herbicide 

Aquatic 

Macroinvertebrates Aquatic Macrophytes Algae 

Chlorsulfuron 10.00 0.000047 0.01 

Clopyralid 21.40 NA 0.69 

AQ Glyphosate 78.00 NA NA 

Glyphosate 1.10 3.00 0.89 

Imazapic 100.00 0.00127 0.05 

Imazapyr 100.00 0.013 0.02 

Metsulfuron methyl 17.00 0.00016 0.01 

Picloram 2.68 0.10 0.23 

Sethoxydim 0.26 0.25 0.25 

Sulfometuron methyl 6.10 0.00021 0.0025 

AQ Triclopyr (TEA) 13.90 0.42 0.42 

Triclopyr (BEE) 0.855 0.007 0.007 

Appendix W-1 
Final Environmental Impact Statement 

Table W-3. Proposed herbicide treatment sites within the Mt. Hood National Forest located 

outside riparian reserves. There are no sites wholly outside riparian reserves proposed in the 

Columbia River Gorge National Scenic Area. Proposed invasive plant treatments at these sites 

would have no effect on any aquatic species. 

Treatment 

Site ID Ranger District 

6th Field 

HUC 6th Field Watershed Name Acres 

61-020 Barlow 170703060902 Jordan Creek 0.5

61-022 Barlow 170703061007 Threemile Creek 11.3

61-027 Barlow 170703061005 Rock Creek 26.8

61-030 Barlow 170703061004 Gate Creek 6.0

170703061004 Gate Creek 9.4 61-036 Barlow 170703061005 Rock Creek 16.4

170703061001 Clear Creek 27.1 61-045 Barlow 170703061006 Middle White River 6.1

170703060706 Wapinitia Creek 94.0 61-050 Barlow 170703061006 Middle White River 17.8

61-051 Barlow 170703061006 Middle White River 0.4

61-055 Barlow 170703060503 Middle Beaver Creek 6.9

61-057 Barlow 170703060503 Middle Beaver Creek 0.6

61-058 Barlow 170703060706 Wapinitia Creek 9.9

61-059 Barlow 170703060706 Wapinitia Creek 22.8

61-066 Barlow 170703060706 Wapinitia Creek 8.3

170703061001 Clear Creek 43.7 61-074 Barlow 170703061006 Middle White River 2.0

61-077 Barlow 170703061006 Middle White River 44.7

61-081 Barlow 170703060706 Wapinitia Creek 3.5

61-084 Barlow 170703061003 Upper White River 32.4

61-085 Barlow 170703060706 Wapinitia Creek 15.9

61-092 Barlow 6.0

170703060503 Middle Beaver Creek 13.7 61-093 Barlow 170703061001 Clear Creek 5.4

65-007 Clackamas River 170900110601 Upper Clear Creek 3.4

65-011 Clackamas River 170900110306 Cot Creek 1.1

65-014 Clackamas River 170900110204 Last Creek 4.5

65-016 Clackamas River 170900110204 Last Creek 4.0

65-018 Clackamas River 170900110306 Cot Creek 1.1

65-022 Clackamas River 170900110401 Three Lynx Creek 5.2

65-026 Clackamas River 170900110107 Lower Collawash River Tributaries 4.7

65-035 Clackamas River 170900110303 Stone Creek 5.3

65-045 Clackamas River 0.1

170703061001 Clear Creek 18.8 66-001 Hood River 170703061003 Upper White River 1.9

66-011 Hood River 170701050601 Upper East Fork Hood River 3.0

66-012 Hood River 170701050702 Divers Creek 0.7

66-030 Hood River 170701050604 Pinnacle Creek 0.3

66-033 Hood River 170701050401 North Fork Mill Creek 17.3

Appendix W-2 
Site-Specific Invasive Plant Treatments 

6th Treatment Field 

6th Site ID Ranger District HUC Field Watershed Name Acres 

170701050606 Lower East Fork Hood River 5.5 66-035 Hood River 170701050801 Neal Creek 1.4

66-040 Hood River 170701050701 Camp Creek 1.1

66-041 Hood River 170701050602 Middle East Fork Hood River 1.0

170701050401 North Fork Mill Creek 2.7 66-042 Hood River 170701050603 Dog River 0.1

66-043 Hood River 170701050602 Middle East Fork Hood River 1.4

66-046 Hood River 170701050801 Neal Creek 1.8

66-047 Hood River 170701050605 Middle Fork Hood River 7.1

66-048 Hood River 170701050701 Camp Creek 3.6

66-049 Hood River 170701050703 Dead Point Creek 3.7

66-083 Hood River 170701050701 Camp Creek 27.7

69-002 Zigzag 0.01

69-004 Zigzag 24.1

69-006 Zigzag 0.1

69-007 Zigzag 170800010801 Gordon Creek 0.5

69-011 Zigzag 0.01

69-025 Zigzag 3.3

69-026 Zigzag 170703061001 Clear Creek 1.1

69-030 Zigzag 170800010202 Zigzag Canyon 3.1

TOTAL ACRES OUTSIDE RIPARIAN RESERVES 592.1

Appendix W-3 
Final Environmental Impact Statement 

Table W-4. Treatment sites with portions located within riparian reserves, but not close or 

adjacent to fish bearing streams, lakes, or ponds. Treatment sites are sorted by aquatic influence 

zone acres. Site ID numbers in bold are proposed for treatment in both Alternatives 2 and 3. 

Treatment 

Site ID Ranger District 

Site 

Acres

Riparian 

Reserve 

Acres 

Percent 

of Site in 

Riparian 

Reserve 

Aquatic 

Influence 

Zone 

Acres 

Percent of 

Site in 

Aquatic 

Influence 

Zone 

61-005 Barlow 72.2 0.9 1.2% 0.0 0.0% 

61-034 Barlow 58.5 0.3 0.5% 0.0 0.0% 

61-062 Barlow 3.8 0.1 2.6% 0.0 0.0% 

61-080 Barlow 18.0 0.3 1.7% 0.0 0.0% 

65-010 Clackamas River 13.0 0.8 6.2% 0.0 0.0% 

65-024 Clackamas River 4.6 0.6 13.0% 0.0 0.0% 

65-032 Clackamas River 2.7 0.1 3.7% 0.0 0.0% 

65-034 Clackamas River 5.2 0.5 9.6% 0.0 0.0% 

66-003 Hood River 42.8 0.3 0.7% 0.0 0.0% 

66-028 Hood River 0.8 0.0 1.3% 0.0 0.0% 

66-029 Hood River 0.7 0.7 100.0% 0.0 0.0% 

66-044 Hood River 0.4 0.2 50.0% 0.0 0.0% 

66-058 Hood River 14.9 0.2 1.3% 0.0 0.0% 

SUB-TOTAL 237.6 5.0 2.1% 0.0 0.0% 

22-05 Scenic Area 89.6 16.0 17.9% 6.4 7.1% 

22-08 Scenic Area 23.5 1.1 4.7% 0.4 1.7% 

22-11 Scenic Area 109.9 18.9 17.2% 8.8 8.0% 

22-12 Scenic Area 81.9 28.6 34.9% 14.0 17.1% 

22-17 Scenic Area 139.1 9.8 7.0% 4.6 3.3% 

61-009 Barlow 43.2 6.2 14.4% 4.4 10.2% 

61-018 Barlow 48.2 0.1 0.2% 0.0 0.0% 

61-025 Barlow 54.1 9.8 18.1% 6.9 12.8% 

61-028 Barlow 51.6 5.9 11.4% 4.5 8.7% 

61-029 Barlow 40.2 0.7 1.7% 0.5 1.2% 

61-039 Barlow 75.9 15.2 20.0% 12.2 16.1% 

61-040 Barlow 10.4 0.7 6.7% 0.6 5.8% 

61-042 Barlow 52.1 5.8 11.1% 4.3 8.3% 

61-044 Barlow 20.2 3.6 17.8% 1.1 5.4% 

61-048 Barlow 38.8 0.7 1.8% 0.0 0.0% 

61-053 Barlow 3.7 3.1 83.8% 2.1 56.8% 

61-064 Barlow 0.4 0.4 100.0% 0.3 75.0% 

61-065 Barlow 18.9 11.3 59.8% 5.2 27.5% 

61-071 Barlow 40.8 5.5 13.5% 3.4 8.3% 

61-075 Barlow 12.5 2.6 20.8% 2.1 16.5% 

61-076 Barlow 15.4 1.5 9.9% 2.3 14.7% 

61-078 Barlow 22.4 0.6 2.8% 0.5 2.1% 

61-079 Barlow 37.2 9.3 24.9% 7.0 18.8% 

61-083 Barlow 18.9 8.2 43.6% 5.6 29.7% 

61-087 Barlow 30.2 2.3 7.5% 1.7 5.6% 

61-088 Barlow 59.7 0.7 1.2% 0.2 0.4% 

61-090 Barlow 0.5 0.5 102.0% 0.3 64.0% 

Appendix W-4 
Site-Specific Invasive Plant Treatments 

Percent of 

Percent Aquatic Site in 

Riparian 

Treatment 

Site ID Ranger District 

Site 

Acres

Reserve 

Acres 

of Site in 

Riparian 

Reserve 

Influence Aquatic 

Zone Influence 

Acres Zone 

61-091 Barlow 3.7 2.6 70.7% 1.3 34.2% 

65-002 Clackamas River 61.6 10.1 16.4% 1.6 2.6% 

65-003 Clackamas River 64.8 4.6 7.0% 2.7 4.1% 

65-005 Clackamas River 0.1 0.1 60.0% 0.0 10.0% 

65-009 Clackamas River 1.0 1.0 103.0% 0.6 58.0% 

65-021 Clackamas River 3.2 2.0 62.2% 0.6 19.4% 

65-027 Clackamas River 0.7 0.7 100.0% 0.7 94.5% 

65-030 Clackamas River 11.4 3.0 26.1% 1.8 15.9% 

65-037 Clackamas River 0.4 0.4 97.5% 0.3 80.0% 

65-038 Clackamas River 1.1 1.0 89.1% 0.6 50.0% 

65-039 Clackamas River 0.3 0.3 93.3% 0.3 93.3% 

65-040 Clackamas River 1.7 1.4 81.8% 0.0 0.6% 

65-042 Clackamas River 9.6 3.7 38.8% 2.0 21.3% 

65-043 Clackamas River 18.5 3.2 17.2% 1.0 5.6% 

65-044 Clackamas River 23.0 4.7 20.4% 2.2 9.5% 

65-046 Clackamas River 8.3 1.1 13.4% 0.7 8.7% 

66-004 Hood River 18.9 5.5 29.3% 4.2 22.2% 

66-005 Hood River 43.7 4.0 9.1% 3.9 8.9% 

66-009 Hood River 9.3 0.7 7.6% 0.6 6.0% 

66-010 Hood River 10.0 4.9 48.8% 4.0 39.6% 

66-013 Hood River 10.8 1.0 9.5% 0.1 1.1% 

66-017 Hood River 66.6 10.7 16.0% 4.7 7.1% 

66-026 Hood River 0.1 0.1 70.0% 0.1 70.0% 

66-051 Hood River 5.7 0.9 15.1% 0.1 0.9% 

66-059 Hood River 39.7 2.0 5.1% 1.2 3.0% 

66-067 Hood River 133.5 13.5 10.1% 7.9 5.9% 

66-069 Hood River 50.5 9.2 18.3% 5.2 10.2% 

69-013 Zigzag 0.1 0.1 70.0% 0.1 50.0% 

69-014 Zigzag 0.0 0.0 100.0% 0.0 100.0% 

SUB-TOTAL 1737.6 261.4 15.0% 147.6 8.5% 

GRAND TOTAL 1975.2 266.5 13.5% 147.6 7.5% 

Appendix W-5 
Final Environmental Impact Statement 

Table W-5. Treatment sites located wholly or partially within riparian reserves adjacent to fish bearing streams, Treatment sites are grouped by the listing status (threatened, endangered, or USDA Forest Service, Pacific North– TES) of one or more fish species residing in the water body nearest the treatment site. Site ID numbers in bold 

treatment in both Alternatives 2 and 3. The zero acres associated with some sites are due to rounding to the first dsites are quite small. Note: A table key is located at the end. 

Treatment Site ID Ranger District 

Site 

Acres 

Riparian 

Reserve 

Acres 

Percent of 

Site in 

Riparian 

Reserve 

Aquatic 

Influence 

Zone 

Treatment 

Acres 

Percent of 

Site in 

Aquatic 

Influence 

Zone 

Special 

Status 

Species Fish Spe

THREATENED, ENDANGERED OR R6 SENSITIVE SPECIES PRESENT 

22-01 Scenic Area 1573.1 1402.4 89.1% 425.8 27.1% T&E 

ONMY1, ONKI, SA

ONTS2 (ONTS3, O

22-07 Scenic Area 21.2 21.2 100.0% 21.2 100.0% T&E 

ONMY1, ONKI, SA

ONTS2 (ONTS3, O

61-003 Barlow 55.0 27.6 50.1% 12.9 23.5% T ONMY3, 61-017 Barlow 96.1 11.8 12.3% 8.3 8.6% T ONMY3, 65-017 Clackamas River 4.1 4.1 100.0% 2.3 56.6% T ONTS, O

ONMY2, 

65-019 Clackamas River 5.0 5.0 100.0% 4.7 93.6% T ONTS, O

ONMY2, 

65-020 Clackamas River 414.4 400.0 96.5% 214.0 51.6% T ONTS, O

ONMY2, 

65-023 Clackamas River 416.4 232.4 55.8% 100.5 24.1% T ONTS, O

ONMY2, 

65-028 Clackamas River 0.8 0.8 100.0% 0.0 0.0% T ONTS, O

ONCL1 

65-029 Clackamas River 11.6 11.1 95.7% 2.6 22.1% T ONTS, O

ONCL1 

65-041 Clackamas River 4.2 4.2 100.0% 0.1 2.4% T ONTS, O

ONCL1 

66-007 Hood River 448.8 206.7 46.1% 127.5 28.4% T ONTS, O

Appendix W-6 
Site-Specific In

Aquatic Percent of 

Percent of 

Treatment 

Site ID Ranger District 

Site 

Acres 

Riparian 

Reserve 

Acres 

Site in 

Riparian 

Reserve 

Influence Site in 

Zone 

Treatment 

Acres 

Aquatic Special 

Influence Status 

Zone Species Fish Spe

66-008 Hood River 509.3 216.6 42.5% 103.1 20.2% T ONKI, ON

ONMY3, 

66-016 Hood River 78.8 25.0 31.7% 13.3 16.9% T ONTS, O66-023 Hood River 350.9 129.6 36.9% 49.0 14.0% T ONMY1, 66-025 Hood River 1.6 1.6 100.0% 0.1 6.3% T SACO, O66-027 Hood River 4.0 4.0 100.0% 0.6 15.0% T SACO, O

ONMY2 

66-053 Hood River 4.2 2.7 64.3% 0.6 13.1% T ONMY1 (

ONMY2, 

66-060 Hood River 105.2 51.1 48.6% 19.3 18.4% T ONTS, O66-062 Hood River 145.8 58.7 40.3% 19.7 13.5% T SACO, O

ONCL1 

66-063 Hood River 630.9 115.5 18.3% 40.3 6.4% T SACO, O

ONCL1 

66-082 Hood River 93.1 31.4 33.7% 12.3 13.2% T ONMY1 (

ONMY2, 

66-084 Hood River 73.2 19.6 26.8% 7.7 10.5% T ONMY1 (

ONMY2, 

69-008 Zigzag 1056.2 506.4 47.9% 210.4 19.9% T ONKI, ON

ONCL1 

69-010 Zigzag 0.0 0.0 100.0% 0.0 100.0% T ONTS, O

ONMY2, 

69-012 Zigzag 0.2 0.2 100.0% 0.2 100.0% T ONTS, O

ONMY2, 

69-015 Zigzag 0.0 0.0 100.0% 0.0 100.0% T ONKI, ON

ONCL1 

69-016 Zigzag 444.6 209.5 47.1% 96.8 21.8% T ONTS, O

ONMY2, 

69-017 Zigzag 0.9 0.9 100.0% 0.0 0.0% T ONTS, O

ONMY2, 

69-018 Zigzag 1.1 1.1 100.0% 1.0 86.4% T ONTS, O

ONMY2, 

Appendix W-7 
Final Environmental Impact Statement 

Aquatic Percent of 

Percent of 

Treatment 

Site ID Ranger District 

Site 

Acres 

Riparian 

Reserve 

Acres 

Site in 

Riparian 

Reserve 

Influence Site in 

Zone 

Treatment 

Acres 

Aquatic Special 

Influence Status 

Zone Species Fish Spe

69-019 Zigzag 0.7 0.7 100.0% 0.4 57.1% T ONTS, O

ONMY2, 

69-020 Zigzag 0.4 0.4 100.0% 0.2 50.0% T ONTS, O

ONMY2, 

69-021 Zigzag 1.4 1.4 100.0% 0.5 35.7% T ONTS, O

ONMY2, 

69-022 Zigzag 0.8 0.8 100.0% 0.3 37.5% T ONTS, O

ONMY2, 

69-023 Zigzag 0.6 0.6 100.0% 0.3 50.0% T ONTS, O

ONMY2, 

69-024 Zigzag 0.2 0.2 100.0% 0.1 50.0% T ONTS, O

ONMY2, 

69-027 Zigzag 216.7 177.8 82.0% 78.5 36.2% T ONTS, O

ONMY2, 

69-029 Zigzag 0.4 0.4 100.0% 0.4 87.5% T ONTS, O

ONMY2, 

SUB-TOTAL 6772.0 3883.5 57.3% 1574.9 23.3% 

Appendix W-8 
Site-Specific In

Treatment Site ID Ranger District 

Site 

Acres 

Riparian 

Reserve 

Acres 

Percent 

of Site in 

Riparian 

Reserve 

Aquatic 

Influence 

Zone 

Treatment 

Acres 

Percent of 

Site in 

Aquatic 

Influence 

Zone 

Special 

Status 

Species Fish Spe

R6 SENSITIVE SPECIES PRESENT 

61-002 Barlow 119.4 13.8 11.6% 3.9 3.3% S ONMY3, 61-006 Barlow 92.2 10.3 11.2% 6.4 6.9% S ONMY3 61-019 Barlow 264.5 56.8 21.5% 23.0 8.7% S ONMY3 61-021 Barlow 46.3 0.1 0.3% 0.0 0.0% S ONMY3 61-023 Barlow 10.9 6.8 62.4% 2.5 22.5% S ONMY3 61-024 Barlow 30.1 1.2 4.0% 0.1 0.3% S ONMY3 61-026 Barlow 34.7 3.0 8.6% 1.2 3.5% S ONMY3 61-041 Barlow 59.2 11.2 19.0% 4.2 7.1% S ONMY3 61-043 Barlow 15.7 15.7 100.0% 12.5 79.6% S ONMY3 61-046 Barlow 2.9 2.8 96.6% 0.7 23.8% S ONMY3 61-047 Barlow 1.5 0.7 46.7% 1.3 86.7% S ONMY3 61-049 Barlow 19.6 9.2 46.9% 1.8 9.2% S ONMY3 61-073 Barlow 31.1 22.5 72.3% 8.9 28.6% S ONMY3 61-082 Barlow 0.3 0.3 100.0% 0.2 66.7% S ONMY3 61-086 Barlow 64.2 4.9 7.6% 2.8 4.4% S ONMY3 61-089 Barlow 88.6 5.8 6.5% 1.7 1.9% S ONMY3 61-095 Barlow 104.0 6.2 6.0% 2.1 2.0% S ONMY3 66-037 Hood River 9.6 9.6 100.0% 8.6 89.1% S ONMY3 66-039 Hood River 3.5 2.8 80.0% 0.5 14.3% S ONMY3 66-052 Hood River 8.8 6.6 74.8% 1.1 12.5% S ONMY3 (66-057 Hood River 80.3 30.2 37.6% 12.6 15.7% S ONMY3, 66-085 Hood River 148.1 30.6 20.7% 13.7 9.3% S ONMY3 66-086 Hood River 296.4 104.9 35.4% 51.0 17.2% S ONMY3 66-087 Hood River 68.0 23.9 35.1% 15.2 22.4% S ONMY3 66-091 Hood River 120.2 26.2 21.8% 12.7 10.6% S ONMY3 

SUB-TOTAL 1720.1 406.2 23.6% 188.6 11.0% 

NON-SPECIAL STATUS SPECIES PRESENT 

61-007 Barlow 5.4 0.0 0.4% 0.0 0.0% ONCL1 

Appendix W-9 
Final Environmental Impact Statement 

Aquatic Percent of 

Percent 

Treatment 

Site ID Ranger District 

Site 

Acres 

Riparian 

Reserve 

Acres 

of Site in 

Riparian 

Reserve 

Influence Site in 

Zone 

Treatment 

Acres 

Aquatic Special 

Influence Status 

Zone Species Fish Spe

65-001 Clackamas River 33.3 15.7 47.1% 6.7 20.1% ONNE, O65-006 Clackamas River 0.2 0.2 100.0% 0.2 100.0% ONMY2, 65-008 Clackamas River 0.2 0.2 100.0% 0.2 100.0% ONMY2, 65-012 Clackamas River 12.4 9.1 73.4% 2.6 21.0% ONCL1 65-013 Clackamas River 46.8 10.5 22.4% 3.4 7.3% ONCL1 65-015 Clackamas River 18.7 12.9 69.0% 3.3 17.6% ONMY2, 65-025 Clackamas River 2.8 2.4 85.7% 0.0 0.0% ONCL1 65-031 Clackamas River 14.3 7.1 49.7% 1.6 11.2% ONCL1 65-033 Clackamas River 9.6 7.1 74.2% 1.5 15.6% COTTU 65-036 Clackamas River 3.6 1.0 27.8% 1.6 44.4% ONMY2, 66-006 Hood River 58.6 17.7 30.2% 17.0 29.0% ONMY2 66-018 Hood River 51.2 10.0 19.5% 3.6 7.0% ONCL1 66-020 Hood River 1014.3 197.0 19.4% 101.0 10.0% SAFO 66-038 Hood River 261.5 41.4 15.8% 23.5 9.0% ONCL1 66-055 Hood River 41.2 13.8 33.4% 1.5 3.6% ONCL1 66-071 Hood River 64.7 28.0 43.2% 12.1 18.7% ONMY2 66-074 Hood River 109.1 32.3 29.6% 10.7 9.8% ONCL1 66-081 Hood River 22.2 2.1 9.5% 0.1 0.5% ONCL1 66-089 Hood River 154.4 56.0 36.3% 17.5 11.3% SAFO 69-001 Zigzag 7.5 4.0 53.3% 1.2 16.0% ONMY2, 69-003 Zigzag 43.6 25.6 58.7% 7.0 16.0% ONCL1 (69-005 Zigzag 42.7 17.7 41.5% 7.8 18.3% ONCL1 (69-028 Zigzag 3.7 1.6 43.2% 0.8 21.6% ONCL1 

SUB-TOTAL 2022.0 513.4 25.4% 224.8 11.1% 

GRAND TOTAL 10514.1 4803.0 45.7% 1988.3 18.9% 

Appendix W-10 
Site-Specific In

Table Key: 

Special Status Species Forest Fish Species Present 

T - Fish listed as threatened are present or nearby 

ONMY1 – Lower Columbia River steelhead trout Oncorhynchus mykis

threatened. 

E - Fish listed as endangered are present or nearby ONMY2 – Resident coastal rainbow trout O. mykiss. S – USDA Forest Service USDA Forest Service, Pacific Northwest Region sensitive fish species present or nearby 

ONMY3 – Resident inland rainbow trout O. mykiss. USDA Forest Serv

Northwest sensitive species. 

Blank - Fish present or nearby but not PETS ONMY4 – Middle Columbia River steelhead trout O. mykiss. Listed as 

ONCL1 – Resident coastal cutthroat trout O. clarki. ONTS – Chinook salmon O. tshawytcha (all races and ESUs). Note: S

Hood River Basin are not listed as threatened, unlike other populations 

ONKI – Lower Columbia River coho salmon O. kisutch. Listed as threaONNE – Resident kokanee salmon O. nerka. SACO – Columbia River bull trout Salvelinus confluentus. Listed as thrSAFO – Resident (non-native) brook trout S. fontinalis. COTTU – Sculpin (various species) Cottus spp. 

Scenic Area Fish Species Present 

ONNE1 – Snake River sockeye salmon O. nerka (E). ONTS2 – Upper Columbia River spring Chinook salmon (E). ONMY5 – Upper Columbia River steelhead trout (T). ONTS3 – Snake River spring, summer, and fall Chinook salmon (T). ONMY6 – Snake River steelhead trout (T). 

ONKE – Columbia River chum salmon O. keta (T). 

Appendix W-11 
Final Environmental Impact Statement 

Tables W-6 – W-9 display predicted hazard quotient values for algae, aquatic plants, aquatic 

invertebrates, and fish. Hazard quotients (HQ) were calculated for all sites wholly or partially 

within riparian reserves for the first three organism groups. For fish, hazard quotients were only 

calculated for those sites within riparian reserves adjacent to fish bearing streams (regardless of 

species present). Herbicide toxicity concentrations used to calculate the following HQ values 

were those displayed in Tables W-1 and W-2, above, which were taken directly from the 

Invasive Plant FEIS (2005a). Some concentrations were not available for algae and aquatic 

plants. 

It is extremely important to note that the predicted HQ values are based solely on the GLEAMS 

model and they do not reflect site condition differences or the application of PDC as proposed in 

this EIS. These values were used as part of a screening process to identify sites with the greatest 

risk to contribute enough herbicide to a water body where biological effects could be relevant. 

The HQ value trigger for potential biological relevance was one. HQ values less than one 

indicate a concentration less than the “No Observable Effect Concentration” for the organism 

group and thus the effect of the herbicide would be discountable. There would be no mortality of 

any aquatic organism. 

The values are displayed below primarily to illustrate the fact that the toxicity of most herbicides 

at most sites is extremely low even before PDC and site specific conditions were applied. 

Table W-6. Predicted hazard quotient (HQ) values for algae at sites proposed for treatment with 

herbicides located within riparian reserves. These values reflect GLEAMS model predictions 

before application of PDC. Not all herbicides are proposed for use at all sites. A “P” following 

the treatment site ID indicates a pond. Toxicity concentrations for AQ Glyphosate were not 

available. Treatment Site ID 

Chlorsulfuron Clopyralid Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

22-01 0.0147 0.0107 0.1741 0.0000 0.0004 0.0008 0.4016 

22-05 0.0132 0.2972 0.0004 0.0008 0.5289 

22-07 0.0091 0.1273 0.1304 

22-08 P 0.0168 0.0338 0.0001 0.0488 0.0784 

22-11 0.0024 0.0036 0.0631 0.0000 0.0001 0.0001 0.0002 0.0176 0.0000 

22-12 P 0.0006 0.0000 0.0021 

22-17 0.0107 0.1741 0.3672 0.4016 

61-002 0.0107 0.0250 

61-003 0.0036 0.0176 

61-005 0.0036 0.0176 

61-006 0.0036 0.0176 

61-007 P 

61-009 0.0036 0.0176 

61-017 0.0036 0.0176 

Appendix W-12 
Site-Specific Invasive Plant Treatments 

Treatment Site ID Chlorsulfuron Clopyralid Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

61-018 0.0036 0.0176 

61-019 0.0036 0.0176 

61-021 0.0036 0.0176 

61-023 0.0091 0.0734 

61-024 0.0036 0.0176 

61-025 0.0107 0.0250 

61-026 0.0036 0.0176 

61-028 0.0036 0.0176 

61-029 0.0036 0.0176 

61-034 0.0036 0.0176 

61-039 0.0036 0.0000 0.0002 0.0176 0.2238 

61-040 0.0000 0.0002 

61-041 0.0036 0.0000 0.0002 0.0176 0.2238 

61-042 0.0036 0.0000 0.0002 0.0176 

61-043 0.0036 0.0002 0.0176 

61-044 0.0036 0.0000 0.0002 0.0176 

61-046 0.0036 0.0000 0.0002 0.0176 

61-047 0.0054 0.0000 0.0036 0.0543 

61-048 0.0036 0.0000 0.0002 0.0176 

61-049 0.0036 0.0000 0.0002 0.0176 

61-053 0.0036 0.0000 0.0002 0.0176 

61-062 0.0036 0.0000 0.0002 0.0176 

61-064 0.0036 0.0000 0.0002 0.0176 

61-065 0.0036 0.0000 0.0002 0.0176 

61-071 0.0036 0.0000 0.0002 0.0176 0.2238 

61-073 0.0036 0.0000 0.0002 0.0176 

61-075 0.0036 0.0000 0.0002 0.0176 

61-076 0.0036 0.0000 0.0002 0.0176 

61-078 0.0036 0.0000 0.0002 0.0176 

61-079 0.0036 0.0000 0.0002 0.0176 

61-080 0.0036 0.0000 0.0002 0.0176 

61-082 0.0036 0.0000 0.0002 0.0176 

61-083 0.0036 0.0000 0.0002 0.0176 

61-086 0.0036 0.0000 0.0002 0.0176 

61-087 0.0036 0.0000 0.0002 0.0176 

61-088 0.0036 0.0176 

61-089 0.0036 0.0176 

61-090 0.0107 0.0004 0.0250 

61-091 0.0226 0.0000 0.0015 0.1034 

61-092 0.0036 0.0000 0.0002 0.0176 

61-095 0.0132 0.0004 0.0272 

65-001 0.0226 0.1034 

Appendix W-13 
Final Environmental Impact Statement Treatment Site ID Chlorsulfuron Clopyralid Glyphosate 

Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

65-002 0.0315 0.1109 

65-003 0.0107 0.0250 

65-005 0.1186 0.2985 

65-006 P 0.0323 0.5812 

65-008 P 0.0072 0.0323 0.5812 

65-009 0.1186 0.0451 0.5812 

65-010 0.0226 0.1034 

65-012 0.0139 0.0268 

65-013 0.0141 0.0268 

65-015 0.0295 

65-017 0.0226 0.1034 

65-019 0.5103 0.0135 0.2727 

65-020 0.0296 0.1134 0.2727 

65-021 0.1186 0.0451 0.5812 

65-023 0.0132 

65-024 0.0053 0.2800 0.5812 

65-025 0.0035 0.0339 0.0771 

65-027 0.0053 

65-028 0.0053 0.2800 

65-029 0.0051 0.2848 

65-030 0.0051 0.2848 

65-031 0.0051 0.2848 

65-032 0.0132 0.0272 

65-033 0.0132 0.0272 

65-034 0.0226 0.1034 

65-036 0.0139 0.0268 

65-037 0.0107 0.0250 

65-038 0.0226 0.1034 

65-039 0.0107 0.0250 

65-040 0.0296 0.1134 

65-041 0.0051 0.2848 

65-042 0.0107 0.0250 

65-043 0.0296 0.1134 

65-044 0.0296 0.1134 

65-045 0.0226 0.1034 

65-046 0.0296 0.1134 

66-003 0.0141 0.0268 

66-004 0.0315 0.1109 

66-005 0.0315 0.1109 

66-006 0.0141 0.0268 

66-007 0.0141 0.0268 

66-008 0.0315 0.0019 0.1109 0.2727 

Appendix W-14 
Site-Specific Invasive Plant Treatments 

Treatment Site ID Chlorsulfuron Clopyralid Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

66-009 0.0139 0.0268 

66-010 0.0342 0.1150 

66-013 0.0141 0.0268 

66-016 0.0141 0.0004 0.0268 

66-017 0.0141 0.0004 0.0268 

66-018 0.0132 0.0004 0.0272 

66-020 0.0132 0.0004 0.0272 

66-023 0.0141 0.0004 0.0268 

66-025 0.0315 0.1109 

66-026 0.0342 0.1150 

66-027 0.0296 0.1134 

66-028 0.0296 0.1134 

66-029 0.0132 0.0272 

66-037 0.0107 0.0250 

66-038 0.0107 0.0250 

66-039 0.0296 0.0018 0.1134 

66-044 0.0296 0.1134 

66-051 0.0226 0.1034 

66-052 0.0315 0.1109 

66-053 0.0296 0.0117 0.0018 0.1134 

66-055 0.0132 0.0000 0.0004 0.0272 

66-057 0.0132 0.0004 0.0272 

66-058 0.0132 0.0004 0.0272 

66-059 0.0132 0.0000 0.0004 0.0272 

66-060 0.0141 0.0004 0.0268 

66-062 0.0141 0.0004 0.0268 

66-063 0.0141 0.0004 0.0268 

66-067 0.0141 0.0004 0.0268 0.6385 

66-069 0.0107 0.0004 0.0250 

66-071 0.0139 0.0004 0.0268 0.7350 

66-074 0.0132 0.0004 0.0272 

66-081 0.0000 0.0004 

66-082 0.0000 0.0004 

66-084 0.0117 0.0018 

66-085 0.0132 0.0004 0.0272 

66-086 0.0296 0.0018 0.1134 

66-087 0.0226 0.0015 0.1034 

66-089 0.0107 0.0004 0.0250 

66-091 0.0315 0.0019 0.1109 

69-001 0.0132 0.0272 

69-002 0.5103 0.2727 

69-003 0.0141 0.0268 

Appendix W-15 
Final Environmental Impact Statement Treatment Site ID Chlorsulfuron Clopyralid Glyphosate 

Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

69-004 0.0107 0.0250 

69-005 0.0141 0.0268 

69-006 0.0107 0.0250 

69-008 0.0315 0.1109 0.2727 

69-010 0.0135 0.2727 

69-011 0.5103 0.2727 

69-012 0.5103 0.0135 0.2727 

69-013 0.5103 0.2727 

69-014 0.0135 0.2727 

69-015 0.0135 0.2727 

69-016 0.0296 0.1134 0.2727 

69-017 0.2727 

69-018 0.2727 

69-019 0.2727 

69-020 0.2727 

69-021 0.2727 

69-022 0.2727 

69-023 0.2727 

69-024 0.2727 

69-025 0.0296 0.1134 

69-027 0.0296 0.1134 0.2727 

69-028 0.0315 0.1109 

69-029 0.5103 0.0135 0.2727 

Appendix W-16 
Site-Specific Invasive Plant Treatments 

Table W-7. Predicted hazard quotient (HQ) values for aquatic plants at sites proposed for 

treatment with herbicides located within riparian reserves. These values reflect GLEAMS model 

predictions before application of PDC. Not all herbicides are proposed for use at all sites. A “P” 

following the treatment site ID indicates a pond. The “NTV” stands for no toxicity value as toxic 

Clopyralid and AQ Glyphosate concentrations were not available for aquatic plants. Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim 

Sulfometuron methyl AQ Triclopyr 

22-01 3.1183 NTV 0.0516 NTV 0.0072 0.0220 0.0093 0.4016 

22-05 NTV 0.0882 NTV 0.0264 0.0100 0.5289 

22-07 NTV 0.0378 NTV 0.1304 

22-08 P NTV 0.0100 NTV 0.0219 0.1121 0.0784 

22-11 0.5125 NTV 0.0187 NTV 0.0005 0.0002 0.0002 0.0102 0.0405 0.0002 

22-12 P NTV NTV 0.0000 0.0049 

22-17 NTV 0.0516 NTV 0.3672 0.4016 

61-002 NTV NTV 0.0576 

61-003 NTV NTV 0.0405 

61-005 NTV 0.0405 

61-006 NTV NTV 0.0405 

61-007 

P 

61-009 NTV NTV 0.0405 

61-017 NTV NTV 0.0405 

61-018 NTV 0.0405 

61-019 NTV NTV 0.0405 

61-021 NTV 0.0405 

61-023 NTV NTV 0.1688 

61-024 NTV 0.0405 

61-025 NTV NTV 0.0576 

61-026 NTV NTV 0.0405 

61-028 NTV NTV 0.0405 

61-029 NTV NTV 0.0405 

61-034 NTV 0.0405 

61-039 NTV NTV 0.0005 0.0102 0.0405 0.2238 

61-040 NTV 0.0005 0.0102 

61-041 NTV NTV 0.0005 0.0102 0.0405 0.2238 

61-042 NTV NTV 0.0005 0.0102 0.0405 

61-043 NTV NTV 0.0102 0.0405 

61-044 NTV NTV 0.0005 0.0102 0.0405 

61-046 NTV NTV 0.0005 0.0102 0.0405 

61-047 NTV NTV 0.0125 0.2243 0.1248 

61-048 NTV 0.0005 0.0102 0.0405 

61-049 NTV NTV 0.0005 0.0102 0.0405 

Appendix W-17 
Final Environmental Impact Statement Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate 

Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

61-053 NTV NTV 0.0005 0.0102 0.0405 

61-062 NTV 0.0005 0.0102 0.0405 

61-064 NTV NTV 0.0005 0.0102 0.0405 

61-065 NTV NTV 0.0005 0.0102 0.0405 

61-071 NTV NTV 0.0005 0.0102 0.0405 0.2238 

61-073 NTV NTV 0.0005 0.0102 0.0405 

61-075 NTV NTV 0.0005 0.0102 0.0405 

61-076 NTV NTV 0.0005 0.0102 0.0405 

61-078 NTV NTV 0.0005 0.0102 0.0405 

61-079 NTV NTV 0.0005 0.0102 0.0405 

61-080 NTV 0.0005 0.0102 0.0405 

61-082 NTV NTV 0.0005 0.0102 0.0405 

61-083 NTV NTV 0.0005 0.0102 0.0405 

61-086 NTV NTV 0.0005 0.0102 0.0405 

61-087 NTV NTV 0.0005 0.0102 0.0405 

61-088 NTV 0.0405 

61-089 NTV NTV 0.0405 

61-090 NTV NTV 0.0220 0.0576 

61-091 NTV NTV 0.0072 0.0961 0.2379 

61-092 NTV 0.0005 0.0102 0.0405 

61-095 NTV NTV 0.0264 0.0625 

65-001 NTV NTV 0.2379 

65-002 NTV NTV 0.2550 

65-003 NTV NTV 0.0576 

65-005 0.0352 0.2985 

65-006 P NTV 0.0323 0.5812 

65-008 P 0.0021 NTV 0.0323 0.5812 

65-009 0.0352 NTV 0.0451 0.5812 

65-010 NTV 0.2379 

65-012 NTV NTV 0.0617 

65-013 NTV NTV 0.0617 

65-015 NTV 0.3506 

65-017 NTV NTV 0.2379 

65-019 0.1514 NTV 0.0135 0.2727 

65-020 NTV NTV 0.2609 0.2727 

65-021 0.0352 NTV 0.0451 0.5812 

65-023 NTV NTV 

65-024 NTV 0.6441 0.5812 

65-025 NTV 0.0780 0.0771 

65-027 NTV NTV 

65-028 NTV 0.6441 

65-029 NTV NTV 0.6550 

Appendix W-18 
Site-Specific Invasive Plant Treatments 

Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

65-030 NTV NTV 0.6550 

65-031 NTV NTV 0.6550 

65-032 NTV 0.0625 

65-033 NTV NTV 0.0625 

65-034 NTV 0.2379 

65-036 NTV NTV 0.0617 

65-037 NTV NTV 0.0576 

65-038 NTV NTV 0.2379 

65-039 NTV NTV 0.0576 

65-040 NTV 0.2609 

65-041 NTV NTV 0.6550 

65-042 NTV NTV 0.0576 

65-043 NTV NTV 0.2609 

65-044 NTV NTV 0.2609 

65-045 NTV 0.2379 

65-046 NTV NTV 0.2609 

66-003 NTV 0.0617 

66-004 NTV NTV 0.2550 

66-005 NTV NTV 0.2550 

66-006 NTV NTV 0.0617 

66-007 NTV NTV 0.0617 

66-008 NTV NTV 0.1186 0.2550 0.2727 

66-009 NTV NTV 0.0617 

66-010 NTV NTV 0.2645 

66-013 NTV 0.0617 

66-016 NTV NTV 0.0277 0.0617 

66-017 NTV NTV 0.0277 0.0617 

66-018 NTV NTV 0.0264 0.0625 

66-020 NTV NTV 0.0264 0.0625 

66-023 NTV NTV 0.0277 0.0617 

66-025 NTV 0.2550 

66-026 NTV NTV 0.2645 

66-027 NTV NTV 0.2609 

66-028 NTV 0.2609 

66-029 NTV 0.0625 

66-037 NTV NTV 0.0576 

66-038 NTV NTV 0.0576 

66-039 NTV NTV 0.1129 0.2609 

66-044 NTV 0.2609 

66-051 NTV 0.2379 

66-052 NTV NTV 0.2550 

66-053 NTV NTV 4.5983 0.1129 0.2609 

Appendix W-19 
Final Environmental Impact Statement Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate 

Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

66-055 NTV NTV 0.0097 0.0264 0.0625 

66-057 NTV NTV 0.0264 0.0625 

66-058 NTV 0.0264 0.0625 

66-059 NTV NTV 0.0097 0.0264 0.0625 

66-060 NTV NTV 0.0277 0.0617 

66-062 NTV NTV 0.0277 0.0617 

66-063 NTV NTV 0.0277 0.0617 

66-067 NTV NTV 0.0277 0.0617 0.6385 

66-069 NTV NTV 0.0220 0.0576 

66-071 NTV NTV 0.0274 0.0617 0.7350 

66-074 NTV NTV 0.0264 0.0625 

66-081 NTV 0.0097 0.0264 

66-082 NTV 0.0099 0.0277 

66-084 NTV 4.5983 0.1129 

66-085 NTV NTV 0.0264 0.0625 

66-086 NTV NTV 0.1129 0.2609 

66-087 NTV NTV 0.0961 0.2379 

66-089 NTV NTV 0.0220 0.0576 

66-091 NTV NTV 0.1186 0.2550 

69-001 NTV NTV 0.0625 

69-002 NTV 0.1514 0.2727 

69-003 NTV NTV 0.0617 

69-004 NTV 0.0576 

69-005 NTV NTV 0.0617 

69-006 NTV 0.0576 

69-008 NTV NTV 0.2550 0.2727 

69-010 NTV 0.0135 0.2727 

69-011 0.1514 0.2727 

69-012 0.1514 NTV 0.0135 0.2727 

69-013 0.1514 0.2727 

69-014 NTV 0.0135 0.2727 

69-015 NTV 0.0135 0.2727 

69-016 NTV NTV 0.2609 0.2727 

69-017 0.2727 

69-018 NTV 0.2727 

69-019 NTV 0.2727 

69-020 NTV 0.2727 

69-021 NTV 0.2727 

69-022 NTV 0.2727 

69-023 NTV 0.2727 

69-024 NTV 0.2727 

69-025 NTV 0.2609 

Appendix W-20 
Site-Specific Invasive Plant Treatments 

Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

69-027 NTV NTV 0.2609 0.2727 

69-028 NTV NTV 0.2550 

69-029 0.1514 NTV 0.0135 0.2727 

Table W-8. Predicted hazard quotient (HQ) values for aquatic invertebrates at sites proposed for 

treatment with herbicides located within riparian reserves. These values reflect GLEAMS model 

predictions before application of PDC. Not all herbicides are proposed for use at all sites. A “P” 

following the treatment site ID indicates a pond. Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate Imazapic 

Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

22-01 0.0542 0.0003 0.1409 0.0020 0.0000 0.0000 0.0000 0.0121 

22-05 0.0004 0.2405 0.0034 0.0000 0.0000 0.0160 

22-07 0.0003 0.1030 0.0015 0.0039 

22-08 P 0.0005 0.0274 0.0004 0.0000 0.0042 0.0024 

22-11 0.0277 0.0001 0.0510 0.0007 0.0000 0.0000 0.0000 0.0000 0.0015 0.0000 

22-12 P 0.0000 0.0002 0.0000 0.0002 

22-17 0.0003 0.1409 0.0020 0.3531 0.0121 

61-002 0.0003 0.0020 0.0021 

61-003 0.0001 0.0007 0.0015 

61-005 0.0001 0.0015 

61-006 0.0001 0.0007 0.0015 

61-007 P 

61-009 0.0001 0.0007 0.0015 

61-017 0.0001 0.0007 0.0015 

61-018 0.0001 0.0015 

61-019 0.0001 0.0007 0.0015 

61-021 0.0001 0.0015 

61-023 0.0003 0.0015 0.0063 

61-024 0.0001 0.0015 

61-025 0.0003 0.0020 0.0021 

61-026 0.0001 0.0007 0.0015 

61-028 0.0001 0.0007 0.0015 

61-029 0.0001 0.0007 0.0015 

61-034 0.0001 0.0015 

61-039 0.0001 0.0007 0.0000 0.0000 0.0015 0.0068 

Appendix W-21 
Final Environmental Impact Statement Treatment Site ID Chlorsulfuron Clopyralid Glyphosate 

AQ Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

61-040 0.0007 0.0000 0.0000 

61-041 0.0001 0.0007 0.0000 0.0000 0.0015 0.0068 

61-042 0.0001 0.0007 0.0000 0.0000 0.0015 

61-043 0.0001 0.0007 0.0000 0.0015 

61-044 0.0001 0.0007 0.0000 0.0000 0.0015 

61-046 0.0001 0.0007 0.0000 0.0000 0.0015 

61-047 0.0002 0.0005 0.0000 0.0000 0.0047 

61-048 0.0001 0.0000 0.0000 0.0015 

61-049 0.0001 0.0007 0.0000 0.0000 0.0015 

61-053 0.0001 0.0007 0.0000 0.0000 0.0015 

61-062 0.0001 0.0000 0.0000 0.0015 

61-064 0.0001 0.0007 0.0000 0.0000 0.0015 

61-065 0.0001 0.0007 0.0000 0.0000 0.0015 

61-071 0.0001 0.0007 0.0000 0.0000 0.0015 0.0068 

61-073 0.0001 0.0007 0.0000 0.0000 0.0015 

61-075 0.0001 0.0007 0.0000 0.0000 0.0015 

61-076 0.0001 0.0007 0.0000 0.0000 0.0015 

61-078 0.0001 0.0007 0.0000 0.0000 0.0015 

61-079 0.0001 0.0007 0.0000 0.0000 0.0015 

61-080 0.0001 0.0000 0.0000 0.0015 

61-082 0.0001 0.0007 0.0000 0.0000 0.0015 

61-083 0.0001 0.0007 0.0000 0.0000 0.0015 

61-086 0.0001 0.0007 0.0000 0.0000 0.0015 

61-087 0.0001 0.0007 0.0000 0.0000 0.0015 

61-088 0.0001 0.0015 

61-089 0.0001 0.0007 0.0015 

61-090 0.0003 0.0020 0.0000 0.0021 

61-091 0.0007 0.0036 0.0000 0.0000 0.0089 

61-092 0.0001 0.0000 0.0000 0.0015 

61-095 0.0004 0.0034 0.0000 0.0023 

65-001 0.0007 0.0036 0.0089 

65-002 0.0010 0.0081 0.0095 

65-003 0.0003 0.0020 0.0021 

65-005 0.0960 0.0090 

65-006 P 0.0001 0.0000 0.0176 

65-008 P 0.0058 0.0001 0.0000 0.0176 

65-009 0.0960 0.0014 0.0000 0.0176 

65-010 0.0007 0.0089 

65-012 0.0004 0.0064 0.0023 

65-013 0.0005 0.0049 0.0023 

65-015 0.0014 0.0000 

65-017 0.0007 0.0036 0.0089 

Appendix W-22 
Site-Specific Invasive Plant Treatments 

Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

65-019 0.4129 0.0058 0.0000 0.0082 

65-020 0.0010 0.0058 0.0097 0.0082 

65-021 0.0960 0.0014 0.0000 0.0176 

65-023 0.0004 0.0034 

65-024 0.0002 0.0240 0.0176 

65-025 0.0001 0.0029 0.0023 

65-027 0.0002 0.0014 

65-028 0.0002 0.0240 

65-029 0.0002 0.0024 0.0244 

65-030 0.0002 0.0024 0.0244 

65-031 0.0002 0.0024 0.0244 

65-032 0.0004 0.0023 

65-033 0.0004 0.0034 0.0023 

65-034 0.0007 0.0089 

65-036 0.0004 0.0064 0.0023 

65-037 0.0003 0.0020 0.0021 

65-038 0.0007 0.0036 0.0089 

65-039 0.0003 0.0020 0.0021 

65-040 0.0010 0.0097 

65-041 0.0002 0.0024 0.0244 

65-042 0.0003 0.0020 0.0021 

65-043 0.0010 0.0058 0.0097 

65-044 0.0010 0.0058 0.0097 

65-045 0.0007 0.0089 

65-046 0.0010 0.0058 0.0097 

66-003 0.0005 0.0023 

66-004 0.0010 0.0081 0.0095 

66-005 0.0010 0.0081 0.0095 

66-006 0.0005 0.0049 0.0023 

66-007 0.0005 0.0049 0.0023 

66-008 0.0010 0.0081 0.0000 0.0095 0.0082 

66-009 0.0004 0.0064 0.0023 

66-010 0.0011 0.0103 0.0099 

66-013 0.0005 0.0023 

66-016 0.0005 0.0049 0.0000 0.0023 

66-017 0.0005 0.0049 0.0000 0.0023 

66-018 0.0004 0.0034 0.0000 0.0023 

66-020 0.0004 0.0034 0.0000 0.0023 

66-023 0.0005 0.0049 0.0000 0.0023 

66-025 0.0010 0.0095 

66-026 0.0011 0.0103 0.0099 

66-027 0.0010 0.0058 0.0097 

Appendix W-23 
Final Environmental Impact Statement Treatment Site ID Chlorsulfuron Clopyralid Glyphosate 

AQ Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

66-028 0.0010 0.0097 

66-029 0.0004 0.0023 

66-037 0.0003 0.0020 0.0021 

66-038 0.0003 0.0020 0.0021 

66-039 0.0010 0.0058 0.0000 0.0097 

66-044 0.0010 0.0097 

66-051 0.0007 0.0089 

66-052 0.0010 0.0081 0.0095 

66-053 0.0010 0.0058 0.0001 0.0000 0.0097 

66-055 0.0004 0.0034 0.0000 0.0000 0.0023 

66-057 0.0004 0.0034 0.0000 0.0023 

66-058 0.0004 0.0000 0.0023 

66-059 0.0004 0.0034 0.0000 0.0000 0.0023 

66-060 0.0005 0.0049 0.0000 0.0023 

66-062 0.0005 0.0049 0.0000 0.0023 

66-063 0.0005 0.0049 0.0000 0.0023 

66-067 0.0005 0.0049 0.0000 0.0023 0.0193 

66-069 0.0003 0.0020 0.0000 0.0021 

66-071 0.0004 0.0064 0.0000 0.0023 0.0222 

66-074 0.0004 0.0034 0.0000 0.0023 

66-081 0.0034 0.0000 0.0000 

66-082 0.0049 0.0000 0.0000 

66-084 0.0058 0.0001 0.0000 

66-085 0.0004 0.0034 0.0000 0.0023 

66-086 0.0010 0.0058 0.0000 0.0097 

66-087 0.0007 0.0036 0.0000 0.0089 

66-089 0.0003 0.0020 0.0000 0.0021 

66-091 0.0010 0.0081 0.0000 0.0095 

69-001 0.0004 0.0034 0.0023 

69-002 0.4129 0.0082 

69-003 0.0005 0.0049 0.0023 

69-004 0.0003 0.0021 

69-005 0.0005 0.0049 0.0023 

69-006 0.0003 0.0021 

69-008 0.0010 0.0081 0.0095 0.0082 

69-010 0.0058 0.0000 0.0082 

69-011 0.4129 0.0082 

69-012 0.4129 0.0058 0.0000 0.0082 

69-013 0.4129 0.0082 

69-014 0.0058 0.0000 0.0082 

69-015 0.0058 0.0000 0.0082 

69-016 0.0010 0.0058 0.0097 0.0082 

Appendix W-24 
Site-Specific Invasive Plant Treatments 

Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate Imazapic Imazapyr AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

69-017 0.0082 

69-018 0.0058 0.0082 

69-019 0.0058 0.0082 

69-020 0.0058 0.0082 

69-021 0.0058 0.0082 

69-022 0.0058 0.0082 

69-023 0.0058 0.0082 

69-024 0.0058 0.0082 

69-025 0.0010 0.0097 

69-027 0.0010 0.0058 0.0097 0.0082 

69-028 0.0010 0.0081 0.0095 

69-029 0.4129 0.0058 0.0000 0.0082 

Table W-9. Predicted hazard quotient (HQ) values for fish at sites proposed for treatment with 

herbicides located within riparian reserves adjacent to fish bearing streams. These values reflect 

GLEAMS model predictions before application of PDC. Not all herbicides are proposed for use 

at all sites. A “P” following the treatment site ID indicates a pond. Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate Imazapic AQ Imazapyr Metsulfuron methyl 

Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

22-01 0.0001 0.0015 2.3838 0.3099 0.0000 0.0000 0.0000 0.6488 

22-07 0.0013 1.7427 0.2266 0.2106 

61-002 0.0015 0.3099 0.1439 

61-003 0.0005 0.1122 0.1012 

61-006 0.0005 0.1122 0.1012 

61-007 P 

61-017 0.0005 0.1122 0.1012 

61-019 0.0005 0.1122 0.1012 

61-021 0.0005 0.1012 

61-023 0.0013 0.2266 0.4221 

61-024 0.0005 0.1012 

61-026 0.0005 0.1122 0.1012 

61-041 0.0005 0.1122 0.0000 0.0000 0.1012 0.3615 

61-043 0.0005 0.1122 0.0000 0.1012 

61-046 0.0005 0.1122 0.0000 0.0000 0.1012 

61-047 0.0007 0.0723 0.0000 0.0000 0.3120 

Appendix W-25 
Final Environmental Impact Statement Treatment Site ID Chlorsulfuron Clopyralid Glyphosate 

AQ Glyphosate Imazapic AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

61-049 0.0005 0.1122 0.0000 0.0000 0.1012 

61-073 0.0005 0.1122 0.0000 0.0000 0.1012 

61-082 0.0005 0.1122 0.0000 0.0000 0.1012 

61-086 0.0005 0.1122 0.0000 0.0000 0.1012 

61-089 0.0005 0.1122 0.1012 

61-091 0.0031 0.5618 0.0000 0.0000 0.5948 

61-095 0.0018 0.5291 0.0000 0.1563 

65-001 0.0031 0.5618 0.5948 

65-006 P 0.0128 0.0001 0.9389 

65-008 P 0.0987 0.0128 0.0001 0.9389 

65-012 0.0019 1.0006 0.1544 

65-013 0.0019 0.7604 0.1544 

65-015 0.2111 0.0001 

65-017 0.0031 0.5618 0.5948 

65-019 6.9868 0.9083 0.0001 0.4405 

65-020 0.0041 0.9083 0.6521 0.4405 

65-023 0.0018 0.5291 

65-025 0.0005 0.1950 0.1246 

65-028 0.0007 1.6102 

65-029 0.0007 0.3698 1.6374 

65-031 0.0007 0.3698 1.6374 

65-033 0.0018 0.5291 0.1563 

65-036 0.0019 1.0006 0.1544 

65-041 0.0007 0.3698 1.6375 

66-006 0.0019 0.7604 0.1544 

66-007 0.0019 0.7604 0.1544 

66-008 0.0043 1.2588 0.0000 0.6376 0.4405 

66-016 0.0019 0.7604 0.0000 0.1544 

66-018 0.0018 0.5291 0.0000 0.1563 

66-020 0.0018 0.5291 0.0000 0.1563 

66-023 0.0019 0.7604 0.0000 0.1544 

66-025 0.0043 0.6376 

66-027 0.0041 0.9083 0.6521 

66-037 0.0015 0.3099 0.1439 

66-038 0.0015 0.3099 0.1439 

66-039 0.0041 0.9083 0.0000 0.6521 

66-052 0.0043 1.2588 0.6376 

66-053 0.0041 0.9083 0.0001 0.0000 0.6521 

66-055 0.0018 0.5291 0.0000 0.0000 0.1563 

66-057 0.0018 0.5291 0.0000 0.1563 

66-060 0.0019 0.7604 0.0000 0.1544 

66-062 0.0019 0.7604 0.0000 0.1544 

Appendix W-26 
Site-Specific Invasive Plant Treatments 

Treatment Site ID Chlorsulfuron Clopyralid Glyphosate AQ Glyphosate Imazapic AQ Imazapyr Metsulfuron methyl Picloram Sethoxydim Sulfometuron methyl AQ Triclopyr 

66-063 0.0019 0.7604 0.0000 0.1544 

66-071 0.0019 1.0006 0.0000 0.1544 1.1873 

66-074 0.0018 0.5291 0.0000 0.1563 

66-081 0.5291 0.0000 0.0000 

66-082 0.7604 0.0000 0.0000 

66-084 0.9083 0.0001 0.0000 

66-085 0.0018 0.5291 0.0000 0.1563 

66-086 0.0041 0.9083 0.0000 0.6521 

66-087 0.0031 0.5618 0.0000 0.5948 

66-089 0.0015 0.3099 0.0000 0.1439 

66-091 0.0043 1.2588 0.0000 0.6376 

69-001 0.0018 0.5291 0.1563 

69-003 0.0019 0.7604 0.1544 

69-005 0.0019 0.7604 0.1544 

69-008 0.0043 1.2588 0.6376 0.4405 

69-010 0.9083 0.0001 0.4405 

69-012 6.9868 0.9083 0.0001 0.4405 

69-015 0.9083 0.0001 0.4405 

69-016 0.0041 0.9083 0.6521 0.4405 

69-017 0.4405 

69-018 0.9083 0.4405 

69-019 0.9083 0.4405 

69-020 0.9083 0.4405 

69-021 0.9083 0.4405 

69-022 0.9083 0.4405 

69-023 0.9083 0.4405 

69-024 0.9083 0.4405 

69-027 0.0041 0.9083 0.6521 0.4405 

69-028 0.0043 1.2588 0.6376 

69-029 6.9868 0.9083 0.0001 0.4405 

Appendix W-27 
 
APPENDIX X 

Effects of Herbicides on Wildlife Species 
 
Site-Specific Invasive Plant Treatments 

Appendix X-1 

 

APPENDIX X: Effects of Herbicides on Wildlife Species 

Appendix prepared by Alan Dyck, Forest Wildlife Biologist, December 2006. 

All invasive plant treatment methods have the potential to temporarily disturb, displace, or directly 

harm various wildlife species. All methods are considered as part of the biological evaluation for 

the species in the project area. The primary focus of this analysis, however, is the effects from 

herbicides on wildlife. During scoping comment periods for the Invasive Plant FEIS (2005a), the 

public expressed specific concern about herbicides and their effects on wildlife species. Little 

concern was expressed about the effects of other kinds of treatment (manual, mechanical and 

cultural). The effects or disturbance to threatened and endangered wildlife is analyzed, and included 

in the discussion of alternatives. 

The wildlife analysis considers the effects of herbicide treatment on Special Status Species, 

including threatened, endangered, and sensitive species and survey and manages species, as well as 

those animals considered Management Indicator Species (MIS) in the Forest Plan. Some discussion 

on the effects to landbird is included with emphasis on Partners in Flight watch list species. For 

most species, the size and distribution of actual treatment areas, the dispersed populations of 

terrestrial wildlife, and the foraging area and behavior of individual animals eliminate the potential 

for direct effects at the population level. Herbicide effects analysis relies on information in the 

SERA Risk Assessments (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) 

unless otherwise noted. The risk assessments used peer-reviewed articles from public scientific 

literature, current U.S. Environmental Protection Agency (EPA) documents available to the public, 

and Confidential Business Information1 to evaluate toxicity and risk from the herbicides analyzed. 

Detailed information on the herbicide analysis conducted for this EIS, including the potential for 

endocrine disruption and synergistic effects, is documented in the Invasive Plant FEIS (2005a), 

Appendix P, Summary of Herbicide Effects to Wildlife. 

The Invasive Plant FEIS (2005a) quantitative estimates of worst-case doses of herbicide have been 

calculated using information such as body size, diet, and water concentrations to calculate the 

potential dose a certain type of animal might receive. The estimated dose was compared to the 

toxicity index (i.e., threshold dose). An estimated dose less than the toxicity index resulted in no 

plausible adverse effect. An estimated dose greater than the toxicity index was called a potential 

adverse effect. If an estimated dose exceeded the toxicity index, it was further evaluated to 

determine if the dose exceeded a known LOAEL (Lowest-Observed-Adverse-Effect Level). The 

LOAEL is the lowest dose of a chemical in a study, or group of studies, that produces statistically or 

biologically significant increases in frequency or severity of adverse effects between the exposed 

and control populations. 

1

 Confidential Business Information (CBI) is defined as information that contains trade secrets, commercial or financial 

information, or other information that has been claimed as confidential by the submitter (EPA/OPP, 2004). 

Individuals must apply for and be granted access to CBI. 
Final Environmental Impact Statement 

Appendix X-2 

 

Generally, this analysis was conducted for both acute and chronic exposures. (Note that this 

discussion is on exposure, which differs from acute or chronic effects. The acute and chronic effects 

imply toxic or non-effects to wildlife.) An acute exposure is a single exposure or multiple brief 

exposures occurring within a short time (e.g., 24 hours or less in humans). A chronic exposure are 

exposures that extend over the average lifetime or for a significant fraction of thee lifetime of the 

species (for a rat, chronic exposures is typically about two years) (Invasive Plant FEIS, 2005a). 

When data were insufficient to develop an estimate of chronic dose, acute doses were evaluated 

against the chronic toxicity index. When the acute dose is less than the chronic toxicity index, there 

is no plausible risk to the animal, because actual chronic exposures would be less than acute 

exposures. When the acute dose is greater than the chronic toxicity index, no estimate of risk could 

be made and potential effects remain uncertain because existing data do not provide sufficient 

information. The general results of the herbicide analysis have been applied to the specific focal 

species that were analyzed by the Forest Wildlife Biologist is summarized in Table X-3. The 

analyzed effects are predicted if none of the standards and guidelines presented in the Invasive Plant 

ROD (2005b) would be used and no Project Design Criteria (PDC) (Section 2.2) implemented. This 

analysis was conducted to look at what herbicides could harm wildlife species in order to determine 

the potential effects and help determine PDC that need to be implemented to reduce risk. 

Assumptions were made regarding whether the species would be exposed to acute or chronic levels 

of exposure and are described for the table. Habitat use and foraging strategies used by the species 

which could lead to different exposure scenarios were based on species knowledge and the 

professional judgment of the Forest Wildlife Biologist. Species information referenced, especially 

for mollusk, is based on Mt. Hood National Forest Wildlife Surveys conducted in 1997, 1998, 1999, 

2000, 2001, and 2002. The Land Mammals of Oregon (Verts and Carraway, 1998) was consulted on 

mammal habitat and life history. 

Data on toxicity of herbicides to amphibians are more limited than data for mammals and birds. 

“Little information exists about effects of herbicides, especially operational treatments, on some 

taxa such as amphibians and reptiles. However, the data available suggest that because of 

application timing (late summer-early autumn), habitat preference (wet areas, generally not 

harvested or treated), and the secretive nature of amphibians, they are unlikely to be exposed, and 

therefore, affected either directly or indirectly by herbicide treatments in northern forested 

ecosystems” (Lautenschlager and Sullivan, 2004). Consequently, quantitative estimates of dose 

from exposure scenarios for all herbicides have not been created for amphibians in the SERA Risk 

Assessments (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f).2

Quantitative exposure scenarios were conducted for amphibians when sufficient data existed to 

support the scenario (e.g., sulfometuron methyl). Toxicity data and exposure scenarios for fish 

provide a reasonable surrogate for effects on amphibians because several studies have found that 

amphibians are less sensitive, or about as sensitive, as fish to some herbicides (Berrill et al., 1994; 

Berrill et al., 1997; Perkins et al., 2000). Comparison of toxicity values for fish and amphibians for 

the herbicides analyzed indicate similar sensitivities See SERA Risk Assessments (2001b, 2003a, 

2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) for more information. 

2

 Amphibian exposure scenarios are available for sulfometuron methyl. 
Site-Specific Invasive Plant Treatments 

Appendix X-3 

With a few exceptions, the toxicity index used in this analysis for each herbicide represents a sublethal effect. Tables X-1 and X-2 list the toxicity indices used in the analysis and the potential 

effects to wildlife at the LOAEL. All toxicity indices represent the lowest dose (e.g. most sensitive 

endpoint) from the species most sensitive to herbicide effects, for which adequate data are available. 

The same methodology was used to quantitatively estimate risk from the use of surfactants added to 

herbicides prior to their use. Most surfactants used are based on a component known as nonylphenol 

polyethoxylate (NPE). The use of NPE-based surfactants in any of the 10 herbicides considered in 

this EIS could result in toxic effects to mammals and birds that eat contaminated vegetation or 

insects at typical and high application rates. Use of NPE is not likely to adversely affect amphibians 

found in the Pacific Northwest for normal operations. Overspray or accidental spills, however, 

could produce concentrations of NPE that could adversely affect amphibians, particularly in small 

stagnant ponds. 

Table X-1: Toxicity indices used and LOAELs reported for Mammals. Table from Invasive Plant 

FEIS (2005a), page 4-47. Classified by herbicides analyzed in this EIS (SERA 2001b, 2003a, 

2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) and NPE surfactants (Bakke, 2003b). 

Herbicide Duration1 Endpoint Dose Species Effect Noted at LOAEL 

Acute NOAEL 75 mg/kg Rabbit Decreased weight gain at 

200 mg/kg Chlorsulfuron 

Chronic NOAEL 5 mg/kg/day Rat Weight changes at 25 

mg/kg/day 

Acute NOAEL 75 mg/kg Rat Decreased weight gain at 

250 mg/kg Clopyralid 

Chronic NOAEL 15 mg/kg/day Rat Thickening of gastric 

epithelium at 150 mg/kg/day 

Acute NOAEL 175 mg/kg Rabbit Diarrhea at 350 mg/kg Glyphosate Chronic NOAEL 175 mg/kg/day Rabbit Diarrhea at 350 mg/kg 

Acute NOAEL 350 mg/kg Rabbit Decreased body weight at 

500 mg/kg Imazapic 

Chronic NOAEL2 45 mg/kg Dog Microscopic muscle effects 

at 137 mg/kg 

Acute NOAEL 250 mg/kg Dog No effects at highest doses 

tested Imazapyr 

Chronic NOAEL 250 mg/kg/day Dog No effects at highest doses 

tested 

Acute NOAEL3 25 mg/kg Rat Decreased weight gain at 

Metsulfuron 500 mg/kg 

methyl Chronic NOAEL 25 mg/kg/day Rat Decreased weight gain at 

125 mg/kg 

Acute NOAEL 34 mg/kg Rabbit Decreased weight gain at 

172 mg/kg Picloram 

Chronic NOAEL 7 mg/kg Dog Increased liver weight at 35 

mg/kg4

Acute NOAEL 160 mg/kg5 Rabbit 

Reduced number of viable 

fetuses, some dam mortality Sethoxydim at 480 mg/kg 

Chronic NOAEL 9 mg/kg/day Dog Mild anemia at 18 mg/kg/day 

Sulfometuron 

methyl Acute NOAEL 87 mg/kg Rat Decreased body weight at 433 mg/kg 
Final Environmental Impact Statement 

Appendix X-4 

Herbicide Duration1 Endpoint Dose Species Effect Noted at LOAEL 

Chronic NOAEL 2 mg/kg/day Rat Effects on blood and bile 

ducts at 20 mg/kg/day 

Acute NOAEL 100 mg/kg Rat Malformed fetuses at 300 

mg/kg 

Chronic7 NOAEL 0.5 mg/kg/day Dog Effect on kidney at 2.5 

mg/kg/day Triclopyr6

Chronic NOAEL 1 mg/kg/day Rat & 

Dog 

Effects on kidney, blood, and 

liver at 5 mg/kg/day 

Acute NOAEL 10 mg/kg Rat 

Slight reduction of 

polysaccharides in liver at 50 

mg/kg/day NPE 

Surfactants 

Chronic NOAEL 10 mg/kg/day Rat 

Increased weights of liver, 

kidneys, ovaries, and 

decreased live pups at 50 

mg/kg/day 

1. An acute dose is one that occurs over a short time. A chronic dose is a smaller amount given 

repeatedly over time. 

2. Imazapic – NOAEL calculated from a LOAEL of 137 mg/kg/day and application of a safety factor of 3 to 

extrapolate from a LOAEL to a NOAEL. 

3. The acute NOAEL of 24 mg/kg is very close to the chronic NOAEL, so chronic value is used for acute 

exposures as well. 

4. USEPA/OPP 1998. 

5. Source of the value used by EPA (180 mg/kg) is not well documented, so the lower value of 160 mg/kg 

from a rabbit study is used as the toxicity index for this analysis. 

6. Triclopyr BEE and TEA have equal toxicities to mammals (SERA, 2003c). 

7. Value taken from Quast et al. 1976 as cited in SERA, 2003c. This represents an extremely 

conservative approach, explained in more detail in the write up on triclopyr later in this document. 

SERA (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) and Bakke (2003b) 
Site-Specific Invasive Plant Treatments 

Appendix X-5 

Table X-2: Toxicity indices used and LOAELs reported for Bird. Table from Invasive Plant FEIS 

(2005a), page 4-47. Classified by herbicides analyzed in this EIS (SERA 2001b, 2003a, 2003b, 

2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) and NPE surfactants (Bakke, 2003b). 

Herbicide Duration1 Endpoint Dose Species Effects Noted at LOAEL 

Acute NOAEL 1686 mg/kg Quail No significant effects at 

highest dose Chlorsulfuron 

Chronic NOAEL 140 

mg/kg/day Quail No significant effects at highest dose

Acute NOAEL 670 mg/kg Mallard & 

Quail 

No signs of toxicity reported, 

LOAEL not determined Clopyralid 

Chronic2 NOAEL 15 

mg/kg/day Rat Thickening of gastric epithelium at 150 mg/kg/day 

Acute NOAEL 562 mg/kg Mallard & 

Quail 

No effects at highest dose 

Glyphosate 

Chronic NOAEL 100 mg/kg Mallard & 

Quail 

No effects on reproduction 

at highest dose 

Acute NOAEL 1100 mg/kg Quail No effects at highest dose 

Imazapic Chronic NOAEL 113 

mg/kg/day Quail Decreased weight gain in chicks at 170 mg/kg/day 

Acute NOAEL 674 mg/kg Quail No effects at highest dose 

Imazapyr Chronic NOAEL 200 

mg/kg/day 

Mallard & 

Quail 

No effects at highest dose 

Acute NOAEL 1043 mg/kg Quail No significant effects at 

Metsulfuron highest dose

methyl Chronic NOAEL 120 

mg/kg/day 

Mallard & 

Quail 

No significant effects at 

highest dose

Acute NOAEL 1500 mg/kg 

Chicken 

& 

pheasant 

No effect to reproduction. 

LOAEL not reported 

Picloram 

Chronic3 NOAEL 7 mg/kg/day Dog Increased liver weight at 35 

mg/kg/day 

Acute LOAEL >500 mg/kg Mallard & 

Quail 

No or low mortality at 

highest doses tested. 

LOAEL not available. Sethoxydim 

Chronic LOAEL4 10 

mg/kg/day Mallard 

Decreased number of 

normal hatchlings at 10 

mg/kg/day 

Acute LOAEL 312 mg/kg Mallard Decreased weight gain at 

Sulfometuron 625 mg/kg/day 

methyl Chronic5 LOAEL 2 mg/kg/day Rat Effects on blood and bile 

ducts at 20 mg/kg/day 

Acute LD50 388 mg/kg Quail 50 percent mortality at 388 

mg/kg 

Triclopyr BEE6

Chronic NOAEL 10 

mg/kg/day 

Mallard & 

quail 

Decreased survival of 

offspring, reduced eggshell 

thickness at 20 mg/kg/day 

Acute LD50 535 mg/kg Quail 50 percent mortality at 535 

mg/kg 

Triclopyr TEA 

Chronic NOAEL 10 

mg/kg/day 

Mallard & 

Quail 

Decreased survival of 

offspring, reduced eggshell 

thickness at 20 mg/kg/day 

NPE 

Surfactants7 Acute LOAEL 10 mg/kg Rat 

Slight reduction of 

polysaccharides in liver at 

50 mg/kg/day 
Final Environmental Impact Statement 

Appendix X-6 

Herbicide Duration1 Endpoint Dose Species Effects Noted at LOAEL 

Chronic LOAEL 10 

mg/kg/day Rat 

Increased weights of liver, 

kidneys, ovaries, and 

decreased live pups at 50 

mg/kg/day 

1. An acute dose is one that occurs over a short time. A chronic dose is a smaller amount given 

repeatedly over time. 

2. Chronic toxicity studies in birds are not available, so the value from mammal studies is used. 

3. Chronic toxicity studies in birds are not available, so the value from mammal studies is used. 

4. Based on one study in which a NOAEL was not determined, so the LOAEL is used. 

5. Birds may be somewhat less sensitive than mammals, but data are limited, so the lower value from 

mammal studies is used. 

6. Unlike in mammals, the toxicities of triclopyr BEE and triclopyr TEA are different for birds, so the 

indices of the two forms of triclopyr are presented separately 

7. Data on birds is not available in published literature, so values from mammals are used. 

Source: SERA (2001b, 2003a, 2003b, 2003c, 2004a, 2004b, 2004c, 2004d, 2004e, 2004f) and Bakke 

(2003b) 

Summary of Effects to Species Exposed to Herbicides 

Table X-3 summarizes effects of herbicides in individuals of target species. Basic assumptions for 

Table X-3 are: 

1. Aquatic organisms such as aquatic salamanders would have the same sensitivity to 

herbicides as fish. 

2. Small insectivorous birds that defend territories may feed in the same area and are subject to 

chronic exposures. Exposures to herbicides by the three Partners in Flight watch listed 

insectivorous migratory birds, however, is probably low since these species forage higher in 

the canopy and forage mostly on insects above the spray zone. These species may 

occasionally eat species from the ground or that fly into the canopy but this incidence of 

exposure would be low. Other land birds may forage lower and could be subjected to higher 

levels of exposure. 

3. Grouse may return to the same areas to feed on a regular basis, especially if the food supply 

is close to a breeding display area. As a result, chronic exposures may occur. 

4. Bats feed over a large enough area to not be subjected to chronic exposures. 

5. Mustelids travel widely and would not be in the same area long enough to be subjected to 

chronic exposures. 
Site-Specific Invasive Plant Treatments 

Appendix X-7 

6. Northern Spotted Owls and peregrine falcons forage over a large territory and would not be 

subjected to chronic exposures. 

7. Aquatic birds that forage on fish or macro invertebrates would not find a concentration of 

herbicides in the water high enough to be exposed at levels that could get toxic. 

8. Woodpeckers and hummingbirds would not be exposed to herbicide because of their feeding 

methods. Their food sources are protected. Since the beetles and ants that the woodpeckers 

feed on are buried inside of decaying wood, and since the nectar of flowers is inside the 

“throat” of the flower which is formed by the elongated petals, the food source of these two 

groups of birds is not likely to be contaminated by spraying herbicides. 

9. Deer and Elk would occasionally feed in the same area for multiple days leading to chronic 

exposures. 

10. The impacts to mollusk may be greater than depicted in the table based their skin may 

absorb herbicides more than the invertebrates that were used in the analysis. The likelihood 

of the sensitive mollusk being in the areas targeted for spraying, however, is extremely low 

based on habitat types. Since the potential is there, they are included in the table. 
Final Environmental Impact Statement 

Table X-3: Summary of Effects Analysis to Individuals of Target Species prior to implementation of Invasive PlProject Design Criteria. For species: T=Threatened; E=Endangered; S=Sensitive; P=Proposed. Symbology for ef

Doses are anticipated to be below the toxicity index; ▲ Doses are anticipated to be above the toxicity index; Unkunknown and there are no surrogate species. 

HERBICIDE 

Species 

Clopyralid Chlor- sulfuron Glyphosate Imazapic Imazapyr Metsulfuron methyl Picloram Sethoxydim 

Su

me

me

Threatened, Endangered and Sensitive Species 

Northern Spotted Owl (T) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Northern Bald Eagle (T) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Oregon Slender Salamander (S) Unk Unk Unk Unk Unk Unk Unk Unk ULarch Mountain Salamander (S) Unk Unk Unk Unk Unk Unk Unk Unk UOregon Spotted Frog (S) Unk Unk Unk Unk Unk Unk Unk Unk UCope’s Giant Salamander (S) ↓↓ ↓↓ ▲ ↓↓ ↓↓ ↓↓ ▲ ↓↓ Cascade Torrent Salamander (S) ↓↓ ↓↓ ▲ ↓↓ ↓↓ ↓↓ ▲ ↓↓ Painted Turtle (S) Unk Unk Unk Unk Unk Unk Unk Unk UNorthwestern Pond Turtle (S) Unk Unk Unk Unk Unk Unk Unk Unk UHorned Grebe (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Bufflehead (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Harlequin Duck (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ American Peregrine Falcon (S) 

↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ 

Grey Flycatcher (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Black Swift (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Baird’s Shrew (S)* ▲ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ▲ ↓↓ 

Appendix X-8 
Site-Specific In

HERBICIDE 

Species 

Clopyralid Chlor- sulfuron Glyphosate Imazapic Imazapyr Metsulfuron methyl Picloram 

Su

me

Sethoxydim me

Pacific Fringetailed Bat (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Pacific pallid bat (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ California Wolverine (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Pacific Fisher (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Crater Lake Tightcoil (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Dalles Sideband (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Puget Oregonian(S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Columbia Oregonian (S) ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ 

Management Indicator Species 

Pileated Woodpecker ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ American Marten ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Deer and Elk ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Gray Squirrel ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ 

Migratory Birds and Partners in Flight Watch list species (management) 

Hermit Warbler ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Blue Grouse ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Rufous Hummingbird ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Willow Flycatcher ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Band-tailed Pigeon ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ Olive-sided Flycatcher ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ ↓↓ 

Appendix X-9 
Final Environmental Impact Statement 

Life History and Occurrence of Wildlife Species Used For Evaluation of 

Alternatives 

Northern Spotted Owl (Strix occidentalis caurina): Threatened 

A. Habitat 

Old growth coniferous forest is the preferred nesting, roosting and foraging habitat of spotted 

Northern Spotted Owls in Oregon. Old growth habitat components that are typical for Northern 

Spotted Owls are: Multilayered canopies, closed canopies, large diameter trees, abundance of dead 

or defective standing trees, and abundance of dead and down woody material. The following 

describes Northern Spotted Owl habitat as defined in the Programmatic Biological Assessment for 

Projects with the Potential to Modify the Habitats of Northern Spotted Owls and/or Bald Eagles 

or Modify Critical Habitat of the Northern Spotted Owl, Willamette Province, FY 2005-2006 

(Reference). 

Suitable habitat for the Northern Spotted Owls consists of habitat used by owls for nesting, 

roosting and foraging (NRF). Generally this habitat is 80 years of age or older, multi-storied and 

has sufficient snags and down wood to provide opportunities for nesting, roosting and foraging. 

The canopy closure generally exceeds 60 percent. A wildlife biologist makes site-specific 

determinations and delineations of suitable habitat. 

Dispersal habitat for the Northern Spotted Owls generally consists of mid-seral stage stands 

between 40 and 80 years of age with canopy closures of 40 percent or greater and an average dbh 

of 11 inches. Northern Spotted Owls use dispersal habitat to move between blocks of suitable 

habitat; juveniles use it to disperse from natal territories. Dispersal habitat may have roosting and 

foraging components, enabling Northern Spotted Owls to survive, but the habitat lacks structure 

suitable for nesting. A wildlife biologist makes site-specific determinations and delineations of 

dispersal habitat. 

Critical Habitat Units (CHUs): Designation of critical habitat serves to identify lands that are 

considered essential for the conservation and recovery of listed species. The functional value of 

critical habitat is to preserve options for the species eventual recovery. The Service’s primary 

objective in designating critical habitat was to identify existing Northern Spotted Owl habitat and 

highlight specific areas where management considerations or protections should be given highest 

priority. CHUs were distributed in a manner that would facilitate demographic interchange. 

Since the designation of Northern Spotted Owl critical habitat in 1992, the Northwest Forest Plan 

(USDA & USDI 1994a) developed as a conservation strategy for all late-successional forest 

species, including the Northern Spotted Owl. Like critical habitat, the Northwest Forest Plan 

(USDA Forest Service and USDI BLM, 1994) was based on the work of the Interagency Science 

Committee. In addition, the Northwest Forest Plan incorporated recommendations from the 

Northern Spotted Owl recovery team and addressed the needs of other late-successional forestassociated species. 

Appendix X-10 
Site-Specific Invasive Plant Treatments 

Primary Constituent Elements 

Primary constituent elements are environmental factors the FWS determines are essential to a 

species’ conservation. For the Northern Spotted Owl the primary constituent elements of critical 

habitat have been identified as the physical and biological features that support nesting, roosting, 

foraging, and dispersal (USDI, 1992a). 

Current Information 

In 2004, the FWS initiated a 5-year review of the Northern Spotted Owl, Scientific evaluation of 

the status of the Northern Spotted Owl (Courtney et al., 2004). The review collates and analyzes 

the recent body of knowledge related to the Northern Spotted Owl since it was listed as a 

threatened species in 1990. The review includes a summary of current threats to the Northern 

Spotted Owl, including the barred owl, West Nile virus, habitat modification, and forest 

management challenges associated within the existing legal framework. Also included in the 5-

year review is a report entitled, Status and Trends in Demography of Northern Spotted Owls, 

1985-2003 (Anthony et al., 2004). 

The information in Coutney et al. (2004) and Anthony et al. (2004) was reviewed by Alan Dyck, 

Forest Wildlife Biologist for the Forest. The results of the 5-year review do not alter how the 

Forest Wildlife Biologist determines the effects to the Northern Spotted Owl or its habitat. This 

project was also reviewed for consistency with the Northwest Forest Plan (USDA Forest Service 

and USDI BLM, 1994). As a result of the review, the effects to the habitat and the owl has not 

changed and the information in Courtney et al. (2004) does not alter the effects determination 

made for the treatment of invasive plants. 

B. Re-Field Review 

Habitat Available Within the Project Area 

Yes. The Proposed Action (Alternative 2) has approximately 2373 acres of the treatment areas that 

are either adjacent to or bisect suitable Northern Spotted Owl habitat. Also, there are 

approximately 2976 treatment acres of dispersal habitat. Of these acres, 2175 acres that would 

receive broadcast boom spray treatments in/or adjacent to suitable habitat (Table X-4). 

Approximately 2582 treatment acres are in or adjacent to Northern Spotted Owl critical habitat 

and 2068 acres are in Late Successional Reserve (LSR). LSRs are a Northwest Forest Plan land 

allocation: this land allocation is managed to protect and enhance conditions of forest ecosystems, 

which serve as habitat for late-successional and old-growth related species, including the Northern 

Spotted Owl. 

Appendix X-11 
Final Environmental Impact Statement 

Disturbance Noise Levels from Invasive Plant Treatments 

To determine if sound level disturbance would impact Northern Spotted Owls, a sound level 

reading was made on the truck and spray pump used by Hood River County. Two distances were 

measured for sound levels on a dirt parking area on a cold clear morning at 10 yards and 35 yards. 

At 10 yards, the decibel reading was 72 decibels and at 35 yards it was 64 decibels. In a white 

paper for the FWS, Kent Livesey analyzed the research on Northern Spotted Owl disturbance 

factors (BA 2003). In the document Livesey states, “...we estimated these sound-only levels to be: 

40 dB for the ambient sound level; 44 dB for the detect threshold; 57 dB for the alert threshold; 70 

dB for the disturbance threshold; and 92 for the injury threshold.” The Willamette Province Level 

One Team has interpreted this information and assigned a threshold for disturbance effects calls. 

When the sound levels reach the disturbance threshold 70 decibels, the effect determination is May 

Affect, Not Likely to Adversely Affect Northern Spotted Owls when the sound level reaches 92 

decibels and above, the effect determination is May Affect, Likely to Adversely Affect Northern 

Spotted Owls. If sound levels are below 70 decibels, there is no effect anticipated. These effect 

determinations are reflected in the distance charts that are located in the Programmatic Biological 

Assessment (Reference). 

C. Field Reconnaissance 

A Level A survey was conducted for the project area in addition to examining some habitat during 

field reconnaissance. There is a high potential for species presence in some locations based on 

current field reconnaissance, GIS (Geographic Information System) analysis, and on historic data. 

D. Analysis of Direct and Indirect Effects 

Alternative 1 – No Action 

Effects to the owl would be limited to the existing planned invasive plant treatments. The habitat 

would continue to function as Northern Spotted Owl suitable or dispersal habitat. The effects 

analysis indicates that there would be no toxic effects to Northern Spotted Owls from the use of 

herbicides on the 450 acres of treatment on the Forest and 150 acres on the Scenic Area. The 

possible indirect effect of noise from the use of pumps and equipment used for broadcast boom 

spraying and mechanical treatment methods have been analyzed and the sound levels compared to 

the sound standards described by Livesey of the FWS Lacey Office and found to be below the 

disruption threshold and is therefore negligible. The majority of the invasive plant treatments that 

would create noise occur along roads and openings. The Fish and Wildlife Service has indicated in 

the Biological Opinion for the FY06-07 LAA Disturbance activities, Willamette Planning 

Province Owls that Northern Spotted Owls rarely nest at or immediately adjacent to road or edges 

(Kerns et al. 1992, Perkins 2000). These effects are analyzed in the Biological Opinion for Effects 

to Northern Spotted Owls (Strix occidentalis caurina) from the Willamette Planning Province 

Fiscal Year 2006 – 2007 activities that have the potential to adversely affect, due to disturbance, 

on U.S. Department of the Interior; Bureau of Land Management, Eugene District and Salem 

District, and the U.S. Department of Agriculture; Mt. Hood National Forest, Willamette National 

Forest and the Columbia River Gorge National Scenic Area (FWS Reference Number 1-7-05-F0663) 

Appendix X-12 
Site-Specific Invasive Plant Treatments 

Alternative 2 – Proposed Action 

The Proposed Action would bisect or be adjacent to Northern Spotted Owl suitable, dispersal, 

critical habitat and LSRs. The treatment areas are in habitats (mostly roads or openings) that cross 

or are within a GIS polygon designated as one of the categories of Northern Spotted Owl habitat. 

The breakdown of treatment acres in or adjacent to Northern Spotted Owl habitat is as follows: 

2373 acres Northern Spotted Owl suitable habitat, 2976 acres dispersal habitat, 2582 critical 

habitat, and 2068 acres are in or adjacent to LSR. Approximately 18 percent of the proposed 

treatment areas would be in or adjacent to suitable Northern Spotted Owl habitat. The Proposed 

Action is to treat 2175 acres of areas in or adjacent to suitable habitat by broadcast boom spraying 

with a broadcast boom spray truck. There would be no impact to any of the primary constituent 

elements of Northern Spotted Owl habitat. The benefit to the habitat would be eliminating 

invasive plants that would otherwise out compete native vegetation which principle prey species 

use for foraging. The indirect effect of noise and disturbance would be negligible due to the very 

small area of suitable habitat and low noise created by mechanical and sprayers in the project area. 

The majority of the invasive plant treatments that would create noise occur along roads and 

openings. The Fish and Wildlife Service has indicated in the Biological Opinion for the FY06-07 

LAA Disturbance activities, Willamette Planning Province Owls that Northern Spotted Owls 

rarely nest at or immediately adjacent to road or edges (Kerns et al. 1992, Perkins 2000). Sound 

level readings of the truck mounted boom sprayer were 64 decibels at 35 yards and were below the 

disturbance threshold, so the determination is No Effect from disturbance. Implementation of this 

project would have no impact to habitat connectivity cells. There are no negative effects to habitat. 

Table X–4: Treatment Acre by Alternative and Northern Spotted Owl Habitat Type 

Treatment Acres Bisecting or Adjacent 

Habitat Type or Treatment Alternative 1 Alternative 2 Alternative 3 

Suitable habitat <1235 2373 2373 

Broadcast Boom spraying in suitable 

habitat 

<415 2175 507 

Dispersal habitat <1235 2976 2976 

Critical Habitat <1235 2582 2582 

Broadcast Boom spraying in Critical 

Habitat 

<415 2222 548 

Manual and/or mechanical treatment only 635 82.5 10417 

Appendix X-13 
Final Environmental Impact Statement 

Alternative 3 – Restricted Herbicide Use Alternative 

Distribution of habitat types adjacent to the treatment areas is the same as Alternative 2. From the 

table above it is clear that the difference in the alternatives is the amount of area that would be 

sprayed with a broadcast boom sprayer. There would only be 507 treatment acres adjacent to 

suitable habitat sprayed by broadcast boom sprayer in this alternative. The toxic effect analysis 

indicates no effect to Northern Spotted Owls from herbicide. Exposure to herbicides would 

negligible since herbicides would rarely if ever be sprayed in suitable habitat and the chances of 

Northern Spotted Owls or their prey coming into contact with the chemicals is below any 

threshold for concern. The analysis for disturbance shows a negligible effect of the treatment on 

Northern Spotted Owl survival or recruitment and no effect to their habitat. Effects to NRF and 

Dispersal Habitat on a Local and Watershed Scale: There are no effects to the primary 

constituent elements of NRF (suitable) or dispersal habitat. There would be no changes in the age 

or structure, understory layer, down logs, or snag habitat. There may be improvements in forage 

for prey species in some situations. The removal of invasive plant species may improve prey 

habitat and contribute to improved prey conditions. 

Effects to Critical Habitat: This project occurs adjacent to and in 2582 acres of critical Northern 

Spotted Owl habitat. No components in the Proposed Action or Restricted Herbicide Use 

Alternatives including herbicide, manual, mechanical, and cultural treatments would affect the 

ability of critical habitat to aide the recovery of the Northern Spotted Owl. There are no changes to 

the primary constituent elements of the habitat by any of the treatment methods. 

Effects to Northern Spotted Owl on a province scale (Willamette Province): The FWS issued an 

opinion on the effects noise disturbance of the herbicide treatments in the programmatic biological 

assessment titled, Programmatic Biological Assessment for Activities with the Potential to Disturb 

Northern Spotted Owls and/or Bald Eagles in the Willamette Province FY2006-2007.” The 

conclusion reached is the following: “After reviewing the current status of the bald eagle and 

Northern Spotted Owl, including critical habitat, the environmental baseline for both species, the 

effects of the Proposed Action, and the cumulative effects, it is the Service’s biological opinion 

that the FY 2005-2006 Habitat Modification Projects in the Willamette Province are not likely to 

jeopardize the continued existence of the bald eagle or Northern Spotted Owl and is not likely to 

destroy or adversely modify designated critical habitat for the Northern Spotted Owl” (USDI, 

2005). The acres contained in the programmatic biological assessment were for the effects of the 

projects in treatment areas covered in Alternative 1. After taking noise level readings of herbicide 

spray equipment that would be used to treat invasive plants in the project area, it is clear that 

sound levels are below the disturbance threshold established by the Level One Team; therefore, 

there is no need for further consultation for disturbance to this species for invasive plant treatment 

from herbicide spraying. The sound levels generated by other manual and mechanical treatments 

also are considered below the disturbance threshold. 

Appendix X-14 
Site-Specific Invasive Plant Treatments 

Effects to Northern Spotted Owl on the entire range of the species (Washington, Oregon, and 

California): The Record of Decision for Amendments to USDA Forest Service and USDI Bureau 

of Land Management Project Documents within the Range of the Northern Spotted Owl 

established a system of land allocations and a set of standards and guidelines that is considered to 

be consistent with maintaining viability for the Northern Spotted Owl across its range (USDA 

Forest Service and USDI BLM 1994). This EIS meets all the Standards and Guidelines set forth 

within this decision document. 

Early Detection / Rapid Response Strategy 

This provision creates the possibility of invasive plant treatment outside of the original mapped 

treatment areas. Expanding the area of treatment would have no effect on habitat, exposure to 

herbicide, or disturbance of Northern Spotted Owls. The actions created by the treatments pose no 

risk to Northern Spotted Owl survival or reproduction. 

Cumulative Effects 

Currently, the only foreseeable future actions on USDA Forest Service lands within the 

watersheds that might be considered cumulative herbicide use and invasive plant treatments to the 

Proposed Action are those projects already approved and listed in the No Action Alternative and 

the EDRR. There would continue to be management activity within these watersheds that have the 

potential to adversely impact Northern Spotted Owl individuals due to disturbance. These types of 

projects would continue to be consulted on with the FWS. There are no actions outside of USDA 

Forest Service lands that become a cumulative effect for Northern Spotted Owls because there is 

no impact to Northern Spotted Owl habitat, the effect of noise is local and would not be 

considered cumulative and the herbicides used do not bioaccumulate. The possibility that there 

could be 13,000 acres of treatment per year with EDRR does not alter the determination of effects 

to the habitat or herbicide effects on the owl. The analysis of spray equipment noise levels and the 

type of equipment being used for cultural, manual and mechanical treatment has eliminated the 

concern for disturbance to Northern Spotted Owl nesting, foraging, or reproductive success. 

E. Mitigation Measures 

Mitigation measures or seasonal restrictions are proposed for the treatment of invasive plants in 

suitable habitat in the LSR and Congressionally Withdrawn land allocations. These restrictions 

would only be applied to areas of suitable habitat in these land allocations. There are 48 treatment 

sites in LSR totaling approximately 2068 acres for the Proposed Action. Of these sites there are 

1058 acres that are suitable Northern Spotted Owl habitat. Treatment of invasive plants must occur 

during the critical breeding season for Northern Spotted Owls, but the noise levels produced by 

the treatment methods would not reach the level of harm. As a result, there is no need for further 

mitigation. 

Appendix X-15 
Final Environmental Impact Statement 

F. Communication with U.S. Fish & Wildlife Service 

The Northern Spotted Owl was listed as threatened throughout its range under the ESA (55 CFR 

26114) on June 22, 1990. Any action that would result in a beneficial effect or could result in an 

adverse impact to the Northern Spotted Owl would result in a may effect determination and would 

require consultation with the FWS. 

Consultation with the FWS was initiated on for the treatment of invasive species in three separate 

consultation avenues. Disturbance effects of invasive plant treatments were analyzed and 

consulted on in the Programmatic Biological Assessment for Activities with the Potential to 

Disturb Northern Spotted Owls and/or Bald Eagles in the Willamette Province FY2006-2007 

(Reference) and the Willamette Province Level One Team was given a presentation on the effects 

analysis and subsequent determination made on the effects to the Northern Spotted Owl and its 

habitat from the treatment of these invasive plants. The Level One Team was informed that the 

Forest and Scenic Area had determined that the effect from the use of herbicide, manual, 

mechanical, and cultural treatment of invasive plants was no effect to the Northern Spotted Owl or 

its habitat. The team was reminded that the disturbance effects had been analyzed in the 

Programmatic Biological Assessment. There was only one comment from the Level One Team on 

the use of herbicides: the comment was related to the use of picloram and its effects to fish 

through impacts to their food source. The comment was forwarded to the fisheries biological on 

the interdisciplinary team. The Level One Team made no comments on the effects determination. 

A letter was sent on July 25, 2006 to the U.S. Fish and Wildlife Service outlining the effects 

determinations based on project alternatives information. The effects determination based on the 

analysis is no effect to Northern Spotted Owls or their habitats. The effects determination from 

disturbance is no effect to Northern Spotted Owls. 

3.10.5.1 Northern Bald Eagle (Haliaeetus leucocephalus): Threatened 

A. Habitat 

The bald eagle is a permanent resident in Oregon. Their nests are usually located in multi-storied 

stands with old-growth components, and are near water bodies that support an adequate food 

supply. Nests, which usually consist of a bulky platform of sticks, are usually located in the supercanopy of trees or on a cliff. Nest sites are usually within one-quarter mile of water in the 

Cascades. 

Adequate forage sources are possibly the most critical component of bald eagle breeding and 

wintering habitat. Fish, waterfowl, rabbits, and various types of carrion comprise the most 

common food sources for eagles in the Pacific Recovery Plan area. Wintering bald eagles perch on 

a variety of substrates, proximity to a food source being the most important factor influencing 

perch selection. Eagles tend to use the highest perch sites available that provides a good view of 

the surrounding area. Communal roosts are invariably near a rich food source and in forest stands 

that are multi-storied and have at least a remnant old growth component. 

Appendix X-16 
Site-Specific Invasive Plant Treatments 

B. Re-Field Review 

Habitat available within the project area 

Yes. There are five areas outlined on the Forest and Scenic Area that are designated as part of the 

Bald Eagle recovery area. Two of these areas have eagles nesting in them. Two of the other areas 

do have eagles utilizing them throughout the year and may have undocumented nesting. All of the 

areas do have some invasive treatments planned (Sites #). There are three areas designated as bald 

eagle habitat areas (A13) in the Forest Plan which have proposed treatments. The habitat could be 

utilized as nesting, roosting, or perching habitat for the bald eagle. 

C. Field Reconnaissance 

A Level A survey was conducted. There is some potential for this species to inhabit the project 

area. Birds are nesting in the Timothy Lake and Clear Lake Areas as well as Rock Creek 

Reservoir, just off the Doewar. No communal roost areas are known for the Forest. There has been 

consistent use by adults in two areas of the Forest and nesting occurs within a half mile of some of 

the roadside treatment areas. 

D. Analysis of Direct and Indirect Effects 

Effects Common to All Alternatives 

No effect to the bald eagles would occur from ingesting or contacting herbicides. The effects 

analysis (Appendix X, Table X-3) showed no anticipated toxic effects to bald eagle. The 

concentrations of herbicides from invasive plant treatment would not be elevated to a point where 

there would be any observable effect to eagles. 

Alternative 1 – No Action 

This alternative includes some pre-existing invasive plant treatments, including herbicide, manual, 

and mechanical treatment methods. There are three roadside treatment areas (Sites #) that are 

within a half-mile, but over one-quarter mile of a previously occupied bald eagle nest near Rock 

Creek Reservoir. These areas are outside the disturbance distance of the bald eagle nest. The nest 

was not occupied in 2005 but was successful in fledging young the previous year (Thurman, 

2005). Due to of the proximity to the treatment areas, it is possible that people working in the 

treatment area could potentially create nest site disturbance. It is unlikely, however, given the nest 

was established in the proximity to the roads being proposed for treatment. There is already a fair 

amount of recreation at the lake near the nest site and the invasive plant treatments could 

potentially add to this disturbance. It is more likely that the nest is hidden from the road well 

enough to not be impacted by the treatments. 

Appendix X-17 
Final Environmental Impact Statement 

Alternatives 2 & 3 – Proposed Action & Restricted Herbicide Use Alternatives 

Effects to Habitat: Bald eagles usually nest within one-quarter mile of a water body in the 

Cascades. Eagles utilize large trees with platform nest. Diets vary with location and food 

availability. Eagles on the Forest primarily forage on fish although it is possible for them to eat 

carrion and dead or injured waterfowl on the lakes. 

There are three proposed treatment sites (Sites #) that are in mapped bald eagle habitat that was 

identified as part of the Forest Plan. There are 369 acres of treatment area that are adjacent to or 

within these bald eagle habitat areas (A13) land allocations. 

The primary constituent elements of bald eagle habitat include nest trees within a quarter mile of a 

water body and large trees for nesting and roosting. There are no treatments that would affect the 

availability of these habitat elements. 

Effects to Individuals: There are two nest sites (thought to be alternates for the same pair) in the 

Clear Lake and Timothy Lake area (Sites #). These nest sites have produced young in the past 

(Isaacs, Frank B. and Robert G Anthony, March 2006). The distance from treatment areas to the 

nest sites is slightly over six tenths of mile for the nearest roadside treatment area. This distance is 

outside the disturbance distance for bald eagles. 

Effects to Population: None expected since no effects to individuals and no effects to habitat 

occurring with project implementation. 

 Early Detection /Rapid Response Strategy 

This provision creates the possibility of invasive plant treatment outside of the original mapped 

treatment areas. Expanding the area of treatment would have no effect on habitat or from exposure 

to herbicide. There is a possibility of treatment areas moving closer to a nest tree and within the 

disturbance zone of eagles. If the treatment area expands into the area within a quarter mile of a 

bald eagle or one half mile line of sight it would be necessary to adhere to a seasonal restriction 

outlined in the PDC H.1. (Section 2.2) or re-consult with the Fish and Wildlife Service. 

Cumulative Effects 

No cumulative effects for the treatment of invasive plants from herbicide, manual, mechanical or 

cultural treatments or the EDRR. 

E. Mitigation Measures 

None. 

Appendix X-18 
Site-Specific Invasive Plant Treatments 

F. Communication with U.S. Fish & Wildlife Service 

The northern bald eagle is listed as threatened throughout its range under the ESA (55 CFR 

26114) on June 22, 1990. Any action that would result in a beneficial effect or could result in an 

adverse impact to the bald eagle would result in a may effect determination and would require 

consultation with the FWS. 

Consultation with the U.S. Fish and Wildlife Service was initiated for invasive plant treatment in 

July of 2005 through the document titled “Programmatic Biological Assessment for Activities 

with the Potential to Disturb Northern Spotted Owls and/or Bald Eagles in the Willamette 

Province FY2006-2007.” There were no effects to bald eagle from invasive plant treatment that 

were determined and therefore the Fish and Wildlife Service Biological Opinion did not list any 

terms or conditions March 2005. 

3.10.5.2 Canada Lynx (Lynx Canadensis): Threatened 

A. Habitat 

In the Pacific Northwest, lynx are associated with high elevation, boreal forests that typify 

northern latitudes. They are found primarily above 4000 feet in Washington. Although scarce in 

Oregon, lynx range and habitat in Oregon and Washington is unclear. High quality lynx habitat is 

comprised of a mosaic of early successional forests with high prey densities (especially snowshoe 

hare) for foraging, and of late-successional forests with an accumulation of down logs used for 

denning, thermal and security cover. Intermediate successional stages are used mainly for travel 

and landscape connectivity but may also provide foraging opportunities. 

B. Re-Field Review 

Habitat available within the project area 

No. In a letter dated August 2 of 2001 (USDA, 2001) and updated on December 3 of 2003 

(USDA, 2003), the Forest has made a determination, based on the best available scientific and 

commercial data, that the Canada lynx and its habitat are currently not present on the Forest and 

Scenic Area. This letter is consistent with the January 2001 Record of Decision and Standards and 

Guidelines for Amendments to the Survey and Manage, Protection Buffer, and Mitigation 

Measure Standards and Guidelines (USDA Forest Service and USDI BLM, 2001), and is 

consistent with the Lynx Conservation Assessment and Strategy (Ruediger, 2000) as specified in 

this Record of Decision. 

The Lynx Nationwide Survey protocol was implemented and resulted in no lynx being located on 

the Forest and Scenic Area. Forest-wide winter tracking surveys have been conducted during the 

winters of 1994-1995, 1995-1996, 2000-2001, 2001-2002, 2002-2003, and 2003-2004. No lynx 

were detected during these surveys. 

No further analysis needed due to lack of habitat. 

Appendix X-19 
Final Environmental Impact Statement 

Larch Mountain Salamander (Plethodon larseli): Sensitive 

A. Habitat 

Habitat is mainly restricted to the talus slopes of the Columbia River Gorge, although the species 

is now known to occur at several locations in the Cascade Mountains of Washington. The Larch 

Mountain salamander could be found near the surface under rocks during wet weather, but it 

retreats to considerable depths in the talus during cold and dry weather. Individuals could occur far 

from streams and seepages, and seem to be less common in perpetually wet talus, compared to 

than in talus that varies from wet to dry with seasonal rainfall. In most cases, Larch Mountain 

Salamanders remains under bark, rocks, leaves, and logs unless it is raining or extremely wet. 

B. Re-Field Review 

Habitat available within the project area 

Yes. Some of the invasive plants treatment areas occur within the identified Larch Mountain 

salamander distribution range as defined in the Northwest Forest Plan. Some of the treatments do 

occur near or directly adjacent to talus slopes. Treatments in the Scenic Area and on the north side 

of the Forest have the greatest likelihood of being near Larch Mountain salamander populations. 

C. Field Reconnaissance 

Level A surveys were conducted. There is a low potential for this species to inhabit the project 

area due to the low distribution of this species. Some of the roads being treated, however, do have 

potential habitat for Larch Mountain salamanders. 

Appendix X-20 
Site-Specific Invasive Plant Treatments 

Oregon Slender Salamander (Batrachoseps wrighti): Sensitive 

A. Habitat 

The only amphibian endemic to Oregon, this species is found predominantly on the western slopes 

of the Cascade Range from the Columbia River south to southern Lane County. Sites have been 

found in Lane, Linn, Clackamas, and Multnomah counties as well as a few sites on the eastern 

slopes of the Cascades in Hood River and Wasco counties. Sites are generally scarce, occurring in 

scattered and often widely separated colonies. Sites are sometimes locally common. 

The Oregon Slender salamander is found in moist and dry woods consisting of Douglas-fir, maple, 

hemlock, and red cedar. It is most common in mature Douglas-fir forests and appears to be 

dependent on mature and old growth stands. Individuals are found under rocks, wood, or bark and 

wood chips at the base of stumps as well as under the bark and moss of logs. They are also found 

in rotting logs, in holes and crevices in the ground, and in termite burrows. Nests that have been 

located were found under bark and in rotten logs. 

B. Re-Field Review 

Habitat available within the project area 

Yes. All the older stands have potential Oregon Slender salamander habitat. 

C. Field Reconnaissance 

Level A surveys were conducted. There is a low potential for this species to inhabit the treatment 

areas because most treatment occurs along roadsides and openings, and this species occurs where 

there is a forest canopy. 

Cope’s Giant Salamander (Dicamptodon copei): Sensitive and 

Cascade Torrent Salamander (Rhyacotriton cascadae): Sensitive) 

A. Habitat 

Cope’s Giant Salamander: Cope’s Giant salamander prefers streams and seepages in moist 

coniferous forests. They limit their occurrence to waters with temperatures in the 8 to 14 o

C range. 

They would also inhabit cold clear mountain lakes and ponds. They occur in suitable areas from 

sea level up to approximately 4,430 feet elevation. The Cope's Giant salamander breed and rear its 

young within the cracks and crevices of the rocky substrates within the stream course. They 

sometimes leave streams on wet rainy nights but remain on wet rocks and vegetation near the 

stream. This salamander is most frequently found on pieces of wood in streams, under logs, bark, 

rocks or other objects near streams. 

Appendix X-21 
Final Environmental Impact Statement 

Cope's Giant salamander has the potential to be negatively affected by increased sedimentation, 

resulting from project activities adjacent to or intersecting streams and water sources. Sediment 

deposition within the substrate could impair preferred habitat characteristics. Also, sedimentation 

of streams could lead to asphyxiation of embryos and larvae as well as a degradation of overwintering habitat that may result in local extinctions. There is no information on the impact of 

herbicides on these aquatic salamanders so the assumption is that they would have the same 

sensitivity to herbicides as fish (See Section 3-9 – Aquatic Organisms and Habitat). 

Cascade Torrent Salamander: The range of this species is from the coastal mountains on the 

Olympic Peninsula in Washington south to Mendocino County in California. Also, there is a 

known population in the Cascade Mountains of southern Washington and northern Oregon, with a 

local disjunctive population in the southern Oregon Cascades. 

The Cascade Torrent salamander is most abundant in rocks bathed in a constant flow of cold 

water, but also occurs in cool rocky streams, lakes, and seeps. Individuals from this species require 

microclimatic and microhabitat conditions generally found only in older forests. 

The diet of this salamander consists of aquatic and semi-aquatic invertebrates, including 

amphipods, springtails, fly larvae, worms, snails, and spiders. They search for prey under rocks 

and other objects in streams. Adults occasionally are found under surface objects a few feet from 

water after heavy rains, but they are the most aquatic of our metamorphosed salamanders and 

should be expected only in saturated stream-side talus and in streams. Experiments have shown 

that this species are among the most sensitive of all terrestrial northwestern salamanders to loss of 

body water and would die quickly in a desiccating environment. 

The Cascade Torrent salamander has the potential to be negatively affected by increased 

sedimentation resulting from project activities adjacent to or intersecting streams and water 

sources. Sediment deposition within the substrate could impair preferred habitat characteristics. 

Also, sedimentation of streams could lead to asphyxiation of embryos and larvae as well as a 

degradation of overwintering habitat that may result in local extinctions. There is no information 

on the impact of herbicides on these aquatic salamanders so the assumption is that they would 

have the same sensitivity to herbicides as fish (See Section 3-9 – Aquatic Organisms and Habitat). 

B. Re-Field Review 

Habitat available within the project area 

Yes. There are sites within the invasive plant treatment project area that include perennial or 

intermittent streams, wet areas, or seeps. 

Cope’s Giant Salamander: This species’ range is predominantly west of the Cascade Range. 

Potential habitat for this species does exist within the Forest and Scenic Area in the proposed 

treatment areas on the westside of Cascades. 

Appendix X-22 
Site-Specific Invasive Plant Treatments 

Cascade Torrent Salamander: Potential habitat for this species does exist within the project area. 

Areas on the westside of the Cascades in the proposed treatment areas appear to have all the 

habitat characteristics essential to the species. 

C. Field Reconnaissance 

A Level A survey was conducted based on a low potential for species occurrence and Project 

Design Criteria H.2. (Section 2.2) that would reduce or eliminate risk to there species. Field 

surveys have not been accomplished. 

American Peregrine Falcon (Falco peregrinus anatum): Sensitive 

A. Habitat 

The most critical habitat components for Peregrine Falcons are suitable nest sites, usually cliffs, 

overlooking fairly open areas with an ample food supply. They nest along seacoasts, near marshes, 

and even in cities, but they are not well suited to life in interior forests. They usually nest or roost 

near a marsh, lake, or coast where water birds are plentiful. 

B. Re-Field Review 

Habitat available within the project area 

There are suitable cliffs within sight and adjacent to the treatment areas. 

C. Field Reconnaissance 

A Level A survey was conducted based on known sites for species occurrence and low risk from 

herbicide use as indicated by the herbicide effects analysis. 

Northern Painted Turtle (Chrysemys picta): Sensitive and 

Western Pond Turtle (Clemmys marmorata marmorata): Sensitive 

A. Habitat 

Northern Painted Turtle: An aquatic turtle that frequents ponds, marshes, small lakes, ditches and 

streams where the water is quiet or sluggish and the bottom is sandy or muddy, and there is 

considerable vegetation. Mudbanks, logs, partially submerged branches, and rocks are preferred 

for sunning. 

Appendix X-23 
Final Environmental Impact Statement 

Western Pond Turtle: The western pond turtle inhabits ponds, marshes, and the slow-moving 

portions of creeks and rivers that have rocky or muddy bottoms. Partially submerged logs, 

vegetation mats, mudbanks, rocks and tree branches provide areas for sunning. Western pond 

turtles have been found to occur from sea level up to around 2000 feet. During the winter months 

these turtles usually hibernate in bottom mud. 

B. Re-Field Review 

Habitat available within the project area 

Northern Pond Turtle: Yes. Although not immediately adjacent to the ponds in the Scenic Area, 

the treatment sites are near the known sites for turtles on the eastern area of the Scenic Area. There 

are no known sightings of these species on the Forest. The USDA Forest Service, Pacific 

Northwest Regional Forester’s Sensitive Species list only has this species as suspected to occur on 

the Forest. 

Painted Turtle: No. The only known painted turtle sites on the administrative units are on the 

Washington side of the Scenic Area. Although potential habitat exists, there are no known 

locations. This species is easy to detect when present so it is not anticipated that any turtles are 

located in the project area or the EDRR area. 

C. Field Reconnaissance 

A Level A survey was conducted based on a low potential for species occurrence outside of the 

known areas. No observations have been made of any of the two species outside of the known 

locations in the Scenic Area. There is a potential for the turtles to live in areas previously unknown 

but these species are fairly conspicuous when they occur in a location. They are usually seen 

sunning on logs or exposed rocks and are easily observed. 

Horned Grebe (Podiceps auritus): Sensitive and Bufflehead (Bucephala albeola): 

Sensitive 

A. Habitat 

Horned Grebe: The Horned Grebe breeds throughout most of Alaska and Canada and, locally, just 

south of the Canadian border. It also breeds in northern Eurasia. Its habitat consists of areas with 

much open water surrounded with emergent vegetation. 

Bufflehead: The Bufflehead is a northern species that breeds from Alaska across Canada and south 

to Oregon, northern California, and Wisconsin. This species nests near mountain lakes surrounded 

by open woodlands containing snags. In many areas, the preferred nest trees are aspen, but they 

would also nest in ponderosa pine or Douglas-fir. 

Appendix X-24 
Site-Specific Invasive Plant Treatments 

B. Re-Field Review 

Habitat available within the project area 

Horned Grebe: Yes. This species occurs both on the Forest and Scenic Area as a winter resident 

and as a migrant. No breeding has been observed or documented for this species on the Forest or 

Scenic Area. 

Bufflehead: Yes. Buffleheads have been recently documented as breeding on the Forest at two 

locations monitored by the Wetland Wildlife Watch program. This species occurs both on the 

Forest and Scenic Area as a winter resident and as a migrant. 

C. Field Reconnaissance 

Annual surveys for wetland species (Wetland Wildlife Watch program) are performed by the 

Northwest Ecological Research Institute for the Forest. A comprehensive survey of amphibians 

and birds is performed in an attempt to locate breeding individuals and populations of wetland 

species. Although there are annual sightings of bufflehead and horned grebes this past year is the 

first year of any documented breeding of buffleheads and there has been no documented breeding 

of horned grebes. Habitat and individuals are recorded in the fall, winter, and early spring but 

these species move on before the annual invasive plant treatment would commence. 

Harlequin Duck (Histrionicus histrionicus): Sensitive 

A. Habitat 

This species occurs from Iceland and Greenland west to eastern Canada. It is absent from the 

central part of North America, and the “western” population ranges from eastern Siberia east 

through Alaska, and south to the Sierra Nevada of California and the mountains of southwestern 

Colorado. In the Northwestern United States, the Harlequin duck breeds along relatively lowgradient, slower-flowing reaches of mountain streams in forested areas. 

B. Re-Field Review 

Habitat available within the project area 

Yes. Level A surveys were conducted. Existing knowledge of the duck was incorporated. There is 

habitat for this species throughout the Forest and Scenic Area. There are several areas where this 

duck has been recorded throughout this area. 

Appendix X-25 
Final Environmental Impact Statement 

C. Field Reconnaissance 

Harlequin ducks have received some attention from biologists on the Forest because of their 

sensitivity to human intrusion and their secretive and cryptic nature. Several locations on the 

Forest have been surveyed for this duck to establish use. A few of these areas have invasive plant 

treatments (Sites #). 

Wolverine (Gulo gulo): Sensitive 

A. Habitat 

Populations in the Cascade Mountains are small and scattered. Wolverines are usually found in 

high temperate coniferous forests, from mid-elevation (around 4000 feet) to moderately high 

elevation (above timberline), depending on the season. Common tree species are sub-alpine fir and 

lodgepole pine. They prefer to feed along rivers and streams and in wet meadows. The den is 

usually in a rock crevice, cave, or beneath a talus slope. Territories may encompass 10 to 80 

square miles. Wolverines have been recorded traveling as far as 500 miles. Wolverines are 

believed to prefer areas of minimal people presence and high levels of solitude and seclusion. 

They are usually associated with wilderness, primarily because they are so vulnerable to the 

activities of humans. 

B. Re-Field Review 

Habitat available within the project area 

Yes. Wolverines have no real habitat preference, but instead appear to seek high elevations for 

denning and solitude. Wolverines are dependant on carrion for a large part of their diet and focus 

on big game populations rather than on specific habitats. Historic sightings of wolverines both 

verified and unverified are within a few miles of the treatment areas. Snow Bunny Snow Park had 

one verified track sighting in 1990 and one wolverine was found dead on interstate 84 in that same 

year. The best possible denning habitat for wolverines on the project area is on the north side of 

the Forest. The proposed treatment areas, however, occur in areas that lack solitude and seclusion 

qualities due to the open road densities, management activities, businesses, homes, and 

recreational opportunities in the area. It is unlikely, but possible, that a wolverine would be present 

in the treatment areas. 

Recent intensive field surveys on the Forest have not been accomplished. The last time broad 

based surveys were conducted over the watershed was during the winter of 1993-1994 and 1994-

1995. Some survey efforts have been ongoing to the east at the Badger Creek Wilderness and on 

the east and north sides of the Forest, but there have been no verifiable sightings of wolverine or 

signs of presence. The length of time with no verifiable sightings is 15 years. This fact calls into 

question if wolverines still exist on the Forest, Scenic Area, or even in the Oregon Cascades. 

Appendix X-26 
Site-Specific Invasive Plant Treatments 

C. Field Reconnaissance 

A Level A survey and strategic surveys were conducted based on a low potential for detecting 

species occurrence. No observations were made of wolverine or their tracks during field 

reconnaissance. The lack of sightings of this species is not a reliable indicator of species presence 

or absence. Since, the home range of wolverines is documented to be in the hundreds of miles, any 

wolverine that is present in the Cascades of Oregon may potentially travel or forage in the project 

area. 

Baird’s Shrew (Sorex bairdii permiliensis): Sensitive 

A. Habitat 

This species is endemic to Oregon. Its range is from northwestern Oregon from the Pacific coast 

east to the Cascades, and from the Columbia River south to Benton and Lane Counties. 

Little published information exists that assigns with certainty habitat characteristics to the Baird’s 

Shrew. In 1986, two specimens were collected in an open Douglas-fir forested area with numerous 

rotting logs in Polk County. The habitat of the Baird’s shrew could be described as moist 

coniferous forests with a shrubby understory. Individuals of the species tend to forage near logs 

and rocks. 

For the purpose of effects analysis on the Forest and Scenic Area, it is assumed that areas on the 

westside of the Cascades suitable for Northern Spotted Owls are also suitable for Baird’s shrews. 

Since this hypothesis has not been tested it may or may not be valid. 

B. Re-Field Review 

Habitat available within the project area 

Yes. As stated above, little is known about this species. The location and habitat characteristics of 

the forested areas of the invasive plant treatment areas does seem to fit with what little is known 

about the species. The affected area is probably similar to that of the Northern Spotted Owls on the 

westside of the Cascades. 

C. Field Reconnaissance 

A Level A survey was conducted. There is a moderate potential for this species to inhabit the areas 

adjacent to the treatment areas. In a few locations, such as those where English ivy would be 

manually or mechanically treated, the treatment areas may be occupied by Baird’s shrews. The 

habitat in these areas appears to be similar to those described for the shrew. 

Appendix X-27 
Final Environmental Impact Statement 

Pacific Fringe-tailed Bat (Myotis thysanodes vespertinus): Sensitive 

A. Habitat 

Little to nothing is known about this subspecies of the Fringed Myotis (Myotis thysanodes); only 

one source of information for the Pacific Fringe-tailed bat appears to exist. The distribution of this 

species is in California, Oregon, and Washington. No habitat data could be found on the Pacific 

Fringe-tailed bat, so habitat information and the following analysis are based on what is known for 

the Fringed Myotis. 

Although the Fringed Myotis is found in a wide variety of habitats throughout its range, it seems 

to prefer forested or riparian areas. Most Oregon records are west of the Cascade Mountains. Its 

nursery colonies and roost sites are established in caves, mines, and buildings. The species is 

thought to forage by picking up food items from shrubs or the ground. It consumes beetles, moths, 

harvestmen, crickets, craneflies, and spiders. 

B. Re-Field Review 

Habitat available within the project area 

Yes. This species is considered suspected on the Forest. Until recently there were no verified 

records that had been documented for this species on the Forest. But recently in personal 

communication with Mark Perkins, a bat researcher that conducted bat surveys on the Mt. Hood 

National Forest in the 1990’s, a documented occurrence was discovered. This species was 

documented on the Clackamas Ranger District during surveys conducted by Perkins (Perkins, 

2006). 

Bats often forage along roads and the Pacific Fringe-tailed bat may use roads for foraging and 

bridges for roosting. This species uses caves and may be found in caves, abandoned mines, or rock 

openings throughout the Forest and Scenic Area. 

C. Field Reconnaissance 

A Level A survey was conducted. There is a moderate potential for this species to inhabit the 

treatment areas. 

Appendix X-28 
Site-Specific Invasive Plant Treatments 

Pacific Pallid Bat (Antrozous pallidus pacificus): Sensitive 

A. Habitat 

The Pacific Pallid Bat prefers dry climates and, therefore, is found in Eastern and Southern 

Oregon. This bat has colonies in buildings, caves, hollow trees, rock piles, mines and will roost 

under bridges with the proper structure. It is described as a semi-desert species; however, it also 

uses woodland edges and rocky areas. It has been documented in the drier areas of the Scenic 

Area. 

The species forages by picking up food items from shrubs or the ground. It consumes beetles, 

moths, harvestmen, crickets, craneflies, and spiders. 

B. Re-Field Review 

Habitat available within the project area 

Yes. This species is considered documented on the Scenic Area. No verified records have been 

documented for this species on the Forest. Bats often forage along roads and the Pacific Pallid Bat 

may use roads for foraging and bridges for roosting. This species uses caves and may be found in 

caves, abandoned mines, or rock openings throughout the eastern portion of the Scenic Area. 

C. Field Reconnaissance 

A Level A survey was conducted. There is a moderate potential for this species to inhabit the 

treatment areas. 

Fisher (Martes pennanti): Sensitive 

A. Habitat 

In the northwest part of its range, the fisher occupies a wide variety of densely forested habitats at 

low to mid-elevations. The fisher is a moderate- to wide-ranging species and is considered rare in 

Oregon. West of the Cascade Range, all records for the species are for sites at elevations of 328 to 

5906 feet, and are located in the Sub-alpine fire, western hemlock, and Sitka spruce zones. The 

species tends to frequent riparian corridors. They are known to occasionally use cut-over areas, but 

this is not their optimal habitat. 

Research has shown that the habitat for fishers could be enhanced by minimizing forest 

fragmentation, both in the remaining old-growth and in second-growth forests; maintaining a high 

degree of forest-floor structural diversity in intensively managed plantations; preserving large 

snags and live trees with dead tops; maintaining continuous canopies in riparian zones; and 

protecting wetland habitat. 

Appendix X-29 
Final Environmental Impact Statement 

B. Re-Field Review 

Habitat available within project area 

Yes. The older forested stands have the structural characteristics of fisher habitat. Although these 

watersheds have been fragmented through past management, there remain enough unfragmented 

stands of old-growth and second-growth forests, including some of the stands proposed for 

treatment, that potential low quality habitat exists for the fisher. Fishers were reduced to extremely 

low numbers in Oregon as recently as 1950. There was a transplant of fishers into south central 

Oregon and those populations remain viable. No recent verifiable records exist for fishers on the 

Forest or Scenic Area. A few track sightings were recorded as potentially being fisher but these 

are unreliable due to the size overlap with American Marten (Martes americana). It is speculated 

that fishers have been extirpated from the Forest and Scenic Area. 

C. Field Reconnaissance 

A Level A survey was conducted. There is a low potential for this species to inhabit the project 

area. Since the early 1990’s, an ongoing effort to establish any presence of fishers on the Forest 

and Scenic Area has been unsuccessful. Track surveys and remote cameras have been utilized to 

attempt to locate this species. Two track records from the 1990s made this species appear to be a 

potential species on this Forest. Further inspection of the recorded data sheets indicated that the 

tracking crew was not sure about the actual species and even indicated it could have been a 

raccoon. This combines with the fact that there is size overlap between marten and fisher makes 

the records very suspect and, therefore, not considered a verified record by the Forest. Despite 

continued efforts and even remote camera surveys, following the track discovery, no fisher 

evidence has been recorded. 

It is the Forest Wildlife Biologist determination that fishers are not present on the Forest or Scenic 

Area. 

Appendix X-30 
Site-Specific Invasive Plant Treatments 

Crater Lake Tightcoil (Pristiloma arcticum crateris): Sensitive 

A. Habitat 

Crater Lake Tightcoil habitat is found above 2000 feet elevation in moist conifer forests and 

among mosses and other vegetation near wetlands, springs, seeps, and riparian areas. This species 

may be found on logs, among sedges, attached to decaying leaf surfaces, in litter, or inside other 

shells (USDI BLM, 1999). 

B. Re-Field Review 

Habitat available within project area 

Yes. Crater Lake Tightcoil has been found very rarely on the Forest and Scenic Area in the past. 

The habitat in the project area fits the habitat where this species has been found to occur. The 

project area does have mosses, wetlands, springs and seeps. 

C. Field Reconnaissance 

A Level A survey was done and it was determined that habitat for this species was present in the 

project area. In checking four years of protocol surveys from other projects in the vicinity of the 

proposed treatment areas, there are no records for this species. This is due in part to the fact that 

this species has not been found in most years when surveys have occurred. 

Habitat for this species is present in the project area and, therefore, presence is assumed although 

it is anticipated that this species would not be within the treatment areas. In most cases, the species 

is not likely to be in the treatment areas because the microclimate requirements for the species 

would not be present. The species is not anticipated in the roadside treatment areas. The seeps and 

springs would have buffers that would protect the individuals occurring in the treatment areas 

(Project Design Criteria H.2.). 

Appendix X-31 
Final Environmental Impact Statement 

Dalles Sideband (Monadenia fidelis minor), Puget Oregonian (Cryptomastix devia), 

Columbia Oregonian (Cryptomastix hendersoni): Sensitive 

A. Habitat 

Dalles Sideband: This species is usually found in steppe or dry forest plant communities, on 

terraces or rocky slopes, within 61 feet of springs and seeps (USDI BLM, 1999). This habitat is 

associated with the eastside of the Forest and Scenic Area. Key components of the habitat are rock 

outcrops, talus, shrubs, and riparian vegetation. 

Puget Oregonian: This species is found in moist conifer forest with hardwood component at low 

elevations through upper, western hemlock zone (USDI BLM, 1999). Key features of the habitat 

are large big-leaf maple trees (logs; sword ferns under canopy); other hardwood trees. 

Columbia Oregonian: This species is found in steppe or open forest near springs and seeps at low 

to mid-elevations (USDI BLM, 1999). Key features of the habitat are talus, logs, shrubs and leaf 

litter. 

B. Re-Field Review 

Habitat available within the project area 

Dalles Sideband: Yes. There is habitat for this species on the eastside of the Forest and Scenic 

Area. The majority of the time this species conserves moisture by living under rocks and logs, or 

in saturated wet areas, such as springs and seeps. 

Puget Oregonian: Yes: There is habitat for this species in isolated pockets throughout the proposed 

treatment area. Big leaf maple and other hardwoods occur in saturated soils and primarily in 

riparian areas. 

Columbia Oregonian: Yes. Spring and seeps occur in the proposed treatment areas. 

C. Field Reconnaissance 

A Level A survey was done and it was determined that habitat for these species was present in the 

project area. 

Habitat for these species is present in the project area and, therefore, presence is assumed. It is 

anticipated, however, that this species would not be within the treatment areas, in most cases 

because the microclimate requirements for the species would not be present. The species are not 

anticipated in the roadside treatment areas. The seeps and springs would have buffers that would 

protect the individuals occurring in the project areas (Project Design Criteria H.2.). 

Appendix X-32 
Site-Specific Invasive Plant Treatments 

Management Indicator Species (MIS) 

Pileated woodpecker (Dryocopus pileatus) 

The pileated woodpecker is a Forest MIS. Concern over pileated woodpeckers arises from their 

association with mature forest habitat, a habitat type that has been affected by logging throughout 

the woodpeckers range. Breeding bird survey data collected between 1966 and 1991 shows no 

significant change in the population in the western United States (Bull, 2003). Pileated 

woodpeckers occur throughout the proposed treatment areas. 

A. Habitat 

Pileated woodpeckers are associated with older, mature forest stand because of their dependence 

on both large-diameter trees with decay and on snags for nesting, roosting, and foraging (Bull, 

2003). Pileated woodpeckers have large home ranges. Telemetry studies in northeast Oregon have 

found that pileated woodpecker pairs had an average home range size of 543 acres. Home ranges 

averaging 1,181 acres and ranging from 660 to 2,609 acres have been reported for the Oregon 

Coast Range (Marshall et al., 1996). 

The pileated woodpecker is most commonly found in mature to old-growth mixed conifer forests; 

although hardwood forests located in valley bottoms are also utilized. Necessary habitat 

components for this species include large diameter snags or living trees with some decay which 

are used for both nesting and roosting sites; both large diameter trees and logs which are used for 

foraging; and a dense canopy to provide cover which protects them from predators (Bull, 2003). 

The pileated woodpeckers diet consists of carpenter ants, thatching ants, beetles, and occasionally 

wild fruits and nuts. The pileated woodpecker is a resident species that breeds throughout 

coniferous forests in western Oregon and Washington. Each pair excavates a new nest cavity each 

spring, usually in a dead tree at an average height of 50 feet above the ground. Courtship begins in 

February and March, nesting occurs from late March to early May, and nestlings are present from 

late May until early July. Adults are not migratory and do not exhibit seasonal movements outside 

of the nesting territory. Juveniles disperse from their natal area in the fall. In an Oregon study, an 

average juvenile dispersal distance of 2 miles was recorded, with a range 0 to 5.2 miles (Bull, 

1987). Timber harvest has the most significant effect on habitat for this woodpecker. Forest 

fragmentation likely reduces population density and makes birds more vulnerable to predation as 

they fly between forest fragments (Bull, 2003). 

B. Occurrence in Proposed Treatment Areas 

Suitable habitat for the pileated woodpecker is present throughout the proposed treatment areas in 

mature forest with a relatively closed canopy. 

Appendix X-33 
Final Environmental Impact Statement 

American Marten (Martes americana) 

The American marten is a Forest MIS. Concern for this species arises out of their association with 

mature and old-growth forest. 

A. Habitat 

Martens are associated with forested habitat and appear to prefer closed canopy mature forests. 

They have been observed using alpine areas and could use forest opening if there is sufficient 

down wood to provide cover (Csuti et al., 2001). The home range size of martens varies, with 

home ranges of approximately 6 square miles reported from Minnesota (Mech & Rogers, 1977 in

Ruggerrio et al., 1994) and home ranges of approximately 0.32 square mile reported in Montana 

(Burnett, 1981 in Ruggerio et al., 1994). In Oregon, the home range of a male American marten is 

generally about 1 square mile in size and the home range of a female is generally about 0.25 

square mile, with separation of home range territories within sexes and overlap between sexes 

being common (Maser, 1998). Martens are generally considered to be forest dependent species 

and have been observed to avoid large forest openings, although non-forested habitats are used by 

martens, particularly during summer above tree line. Martens have been observed crossing 

openings, particularly during winter (Ruggiero et al., 1994). 

Martens are primarily carnivorous and feed on small mammals including shrews, voles, woodrats, 

rabbits, squirrels, and mountain beaver, although marten’s prey items also include birds, insects, 

and fruits (Csuti et al., 2001). 

B. Occurrence in Proposed Treatment Areas 

In Oregon, martens are known to inhabit the Coast Ranges, the Cascades and the Blue Mountains. 

The higher elevation sites would be within the areas that martens exist on the Forest. Numerous 

remote camera and tracking surveys have documented this species occurring widely on the Forest 

and Scenic Area. With the large home ranges it is always possible that this species would travel 

through an area that has been treated. 

Deer and Elk 

The effects to deer and elk are almost identical, since their habitat requirements and forage are so 

similar. 

Deer: There are two different subspecies of mule deer that occur in Oregon: the subspecies 

expected to occur within the treatment areas is the black-tailed deer (Odocoileus hemionus). The 

black tailed deer is a Forest MIS. Concern over this species arises from its status as an important 

game species. 

Appendix X-34 
Site-Specific Invasive Plant Treatments 

Elk: Elk (Cervus elaphus) are Forest MIS. Two subspecies of elk occur on the Forest and Scenic 

Area. Roosevelt Elk (Cervus elaphus roosevelti) occur on the westside of the Cascades, and 

Rocky Mountain Elk (Cervus canadensis nelsoni) on the eastside of the Cascades. Concern over 

this species arises from its status as an important game species. 

A. Habitat 

Deer and elk are considered ecotone species, using edge habitats between open areas and forests. 

They are also known to utilize old-growth coniferous forest, and are often found far from forest 

edges in this habitat. Deer and elk breed from September to November. One or two young are born 

in May or June. Migration patterns vary considerably throughout the range of the subspecies. 

Populations inhabiting higher elevations in summer migrate down-slope to lower elevations when 

accumulations of snow make forage unavailable, while other populations move short distances to 

preferred food patches or do not migrate at all. 

Dietary habits of deer and elk are relatively broad. Although traditionally considered a browser, 

deer are actually intermediate between browsers and grazers, with grasses and forbs making up a 

high proportion of the diet during some years and seasons. Browse consisting mainly of the tender 

new shoots of woody plants makes up approximately three-fourths of deer diets annually. In 

spring and summer, the new green growth of forbs and grasses could make up over half the food 

eaten. The fruits, nuts, buds, shoots and leaves of a wide variety of trees, shrubs, and vines as well 

as mushrooms, lichens, and other foods are regularly consumed. 

Grasses and sedges make up the bulk of elk diets, with forbs and browse utilized to a lesser extent. 

Elk require a juxtaposition of forest for cover and open habitats for forage. Dispersal corridors 

between summer and winter ranges must provide these requirements, along with relative freedom 

from human disturbance. River corridors are often used as migration corridors. 

Travel corridors between summer and winter range, freedom from human disturbance in fawning 

areas, and cover to escape harsh environmental conditions and predators are important 

components of high-quality deer and elk habitat. Within the Cascades elk typically begin 

migrating in June up-slope to summer range following new plant growth as it becomes available. 

Calving areas are defined as the upper reaches of winter range which offer open brush and grassy 

areas near water and nearby forested areas for cover. The elevation of calving varies with the 

depth of the snow pack and the availability of forage and cover. Young are born in early June and 

within a week or two, cow-calf herds are formed. 

B. Occurrence in Proposed Treatment Areas 

Suitable habitat for both deer and elk is present in the Study Area and individuals of this species 

have been observed within the treatment areas. 

Appendix X-35 
Final Environmental Impact Statement 

Analysis of State Listed Species for Scenic Area Analysis 

Oregon State Endangered, Threatened, Sensitive and Candidate Species with historic or suspected 

range in the Scenic Area as defined by the1992 Management Plan for the Columbia River Gorge 

National Scenic Area that have not been addressed in the body of this EIS. 

Table X-5: Summary table of effects for Oregon State Endangered (E), Threatened (T), Sensitive 

(S) and Candidate (C) Species. The sensitive species are broken down into Sensitive-Critical (SC), 

Sensitive-Vulnerable (SV), and Sensitive-Undetermined (SU). 

Project Name: Site-Specific Invasive Plant Treatment EIS State: Oregon 

Species 

Presence

SPECIES 

(population segment) STATUS*

PREFIELD 

REVIEW 

Usual Habitat in OR/WA 

Habitat 

Present? 

Species 

Present? 

Effect 

Determination

Columbia spotted frog 

(Rana luteiventris)

C, WA-C, 

OR-SU 

Columbia basin (east of Cascades 

Range): In or near permanent slow 

ponds, streams, marshes with 

abundant vegetation (one known site 

at Conboy). No currents sites in 

Scenic Area. 

Y N No Effect 

Northern leopard frog 

(Rana pipiens) 

WA-E, 

OR-SC 

Lowland marsh/ponds with dense 

vegetation; presently found in Grant 

county only. Likely extirpated in Gorge.

Y N No Effect 

Western toad 

(Bufo boreas)

WA-C, 

OR-SV 

Widespread distribution in WA and 

OR: Most common near marshes and 

small lakes (breeding sites in midspring); can travel readily overland and 

be found along streams/seeps. 

Y Y Effect Unknown

Tailed frog 

(Ascaphus truei) OR-SV Clear, cold, fast forest streams with 

little silt and (often) cobble substrate. Y Y No Effect 

Cascades frog 

(Rana cascadae) OR-SV 

High elevation streams (1500-6000’) 

as well as mountain meadows and 

moist forests 

Y Y No Effect 

Northern red-legged Frog 

(West Cascades) 

(Rana aurora) 

OR-SU 

Moist forests and forested wetlands, 

breeding in cool ponds and slow 

streams. 

Y Y Effect Unknown

California Mountain king snake

(Lampropeltis zonata) 

WA-C, 

OR-SV 

Main population in CA and Klamath 

mountains, with disjunct pop. in 

Columbia River Gorge (Klickitat, 

Skamania county area): oak/pine 

woodland, rocky riparian within 

logs/rocky cover. No confirmed 

specimens on OR side of Scenic Area, 

although unconfirmed sightings have 

been reported at The Dalles and 

Maupin areas. 

Y N No Effect 

Sharptail snake 

(Contia tenuis)

WA-C, 

OR-SV 

East slope of WA Cascades, 

Columbia R. Gorge, W OR: rocky 

slopes and open pine and oak 

woodland w/prey species of small 

slugs 

Y Y Effect Unknown

Ferruginous hawk 

(Buteo regalis) 

WA-T, 

OR-SC 

Open prairie and shrub steppe in 

eastern WA and OR. Y N No effect 

Appendix X-36 
Site-Specific Invasive Plant Treatments 

Project Name: Site-Specific Invasive Plant Treatment EIS State: Oregon 

Species 

Presence

SPECIES 

(population segment) STATUS*

PREFIELD 

REVIEW 

Usual Habitat in OR/WA 

Habitat 

Present? 

Species 

Present? 

Effect 

Determination

Northern goshawk 

(Accipiter gentilis) 

WA-C, 

OR-SC 

Typically more common east of 

Cascades in a wide variety of forest 

ages, structural conditions, and 

successional stages. Uses stands of 

mature forest as nesting sites. 

Typically found between 1900 and 

6100 feet in Oregon. 

Y Y No effect 

Flammulated owl 

(Otus flammeolus)

WA-C, 

OR-SC 

E. Cascades: cavity nester in mature 

pine and mixed conifer, at midelevations. 

Winters S. of US border 

Y Y No effect 

Barrow’s goldeneye (breeding

population) 

(Bucephala islandica) 

OR-SU 

Cascade range: breeds along ponds, 

sloughs and lakes in mountainous 

areas, using tree cavities or nest 

boxes. Winters in large rivers or 

marine habitat. 

Y Not 

Breeding No effect 

American white pelican 

(Pelecanus erythrorhynchos) 

WA-E, 

OR-SV 

Gregarious birds that nest in large 

colonies on islands within shallow 

water and marshes free of human 

disturbance and mammalian 

predators. Post breeders sometimes 

seen in Col R. (such as Klickitat 

Delta). Winters in S US through 

Mexico. 

Y Y No effect 

Yellow-billed cuckoo 

(Coccyzus americanus)

WA-C, 

OR-SC 

Historic range in WA and OR. No 

reported breeding occurrences since 

the 1950’s, although individuals have 

been sighted east of Cascades 

sporadically. Riparian forests, with 

cottonwood/thick willow; Neotropical 

migrant. Considered extirpated from 

WA and OR. 

Y N No effect 

Lewis' woodpecker 

(Melanerpes lewis)

WA-C, 

OR-SC 

Open pine/oak woodland, conifer 

forests, and riparian woodland; 

neotropical migrant. Commonly seen 

in east areas of Scenic Area in dry 

forest types of oak and pine. 

Y Y No effect 

White-headed woodpecker 

(Picoides albolarvatus)

WA-C, 

OR-SC 

Central/E. WA/OR in mature and open 

coniferous forests, esp. ponderosa 

pines. Cavity nester. Unknown 

numbers in Scenic Area. 

Y Y No effect 

Three-toed woodpecker 

(Picoides tridactylus) OR-SC 

Range in Oregon cascades in forests 

with Pine or Spruce component with 

bark beetle availability (diseased/ 

dying/ burned trees). Very limited 

habitat in Scenic Area. 

Y Y No effect 

Black-backed woodpecker 

(Picoides arcticus)

WA-C, 

OR-SC 

Uncommon Cascades resident usu. at 

higher elevations (>3000’). East 

Cascades in WA. Scattered 

distribution as populations are highly 

associated with post-fire habitats in 

mature forests (stand-replacement 

fires with snags), dependent on high 

density of dead and insect-ridden 

trees. 

Y Y No effect 

Appendix X-37 
Final Environmental Impact Statement 

Project Name: Site-Specific Invasive Plant Treatment EIS State: Oregon 

Species 

Presence

SPECIES 

(population segment) STATUS*

PREFIELD 

REVIEW 

Usual Habitat in OR/WA 

Habitat 

Present? 

Species 

Present? 

Effect 

Determination

Williamson’s sapsucker 

(Sphyrapicus thyroideus) OR-SU 

East slopes of Cascades: breeds in 

coniferous mountain forests at mid to 

high elevation. Prefers large snags for 

nesting. Majority of population migrate 

to Southwest U.S. for winter. 

Y Unk No effect 

Willow flycatcher (East 

Cascades pop.) 

(Empidonax adastus) 

OR-SU 

Associated with shrub habitat. 

Dependent on willow thickets in 

riparian zones for nesting and 

migration. Neotropical migrant. 

Y Y No effect 

Purple martin 

(Progne subis) 

OR-SC, 

WA-C 

Western WA/OR up through Gorge to 

Western Wasco County: Nests in 

artificial & natural snags/crevices, 

often over water. Forages over open 

water/fields/forest canopy. Winters in 

South America. 

Y Y No effect 

Bank swallow 

(Riparia riparia) OR-SU 

East of Cascades along waterways or 

roadcuts where vertical cliffs of soil are 

exposed adjacent to large open area. 

Neotropical migrant. 

Y Y Minor effect 

White-tailed jackrabbit 

(Lepus townsendii) 

WA-C, 

OR-SU 

East of Cascades: open areas with 

native bunchgrass, sagebrush plains, 

can also be found in coniferous forests 

and subalpine meadows. On periphery 

of habitat in Scenic Area at the 

Dalles/Dallesport. 

Y Y No effect 

Washington ground squirrel 

(Spermophilus washingtoni) 

WA-C, 

OR-E 

Presently found in Columbia basin of 

WA state in sagebrush/grassland w/ 

sandy soils; also Giliam, Morrow and 

Umatilla counties, OR. May have 

historically been within the eastern 

edge of Scenic Area. 

Y N No effect 

Western gray squirrel 

(Sciurus griseus) 

OR-SU, 

WA-T 

Oak & mixed oak woodland, typically 

within 1⁄2 mile of water source. Core 

range for WA in Klickitat county 

Y Y No effect 

Townsend’s big-eared bat 

(Corynorhinus townsendii) 

WA-C, 

OR-SC 

Roosts and hibernaculum sites within 

caves, buildings, mines and bridge 

undersides, with exacting temp, 

humidity, and physical requirements. 

Very intolerant of human disturbance 

which results in loss of critical fat 

reserves during torpid period. 

Y Y Minor effect 

Silver-haired bat 

(Lasionycteris noctivagans) OR-SU 

Found throughout Oregon: among the 

most common bats in forested areas 

of America, most closely associated 

with coniferous or mixed coniferous 

and deciduous forest types, especially 

in areas of Old Growth. They form 

maternity colonies almost exclusively 

in tree cavities or small hollows 

Y Y Minor effect 

Western small-footed myotis 

(Myotis ciliolabrum) OR-SU 

West Cascades and eastward: Rears 

its young in cliff-face crevices, erosion 

cavities, and beneath rocks on the 

ground as well as hibernating in caves 

or mines. Relatively little is known 

about this species. 

Y Y Minor effect 

Appendix X-38 
Site-Specific Invasive Plant Treatments 

Project Name: Site-Specific Invasive Plant Treatment EIS State: Oregon 

Species 

Presence

SPECIES 

(population segment) STATUS*

PREFIELD 

REVIEW 

Usual Habitat in OR/WA 

Habitat 

Present? 

Species 

Present? 

Effect 

Determination

Long-eared myotis 

(Myotis evotis) OR-SU 

Statewide: found in coniferous roost in 

tree cavities and beneath exfoliating 

bark in both living trees and dead 

snags. 

Y Y Minor effect 

Long-legged- myotis 

(Myotis volans) OR-SU 

Statewide: especially dependent on 

wooded habitats of coniferous forests, 

usually at elevations of 4,000 to 9,000 

feet. Nursery colonies found in large 

mature trees that provide crevices or 

exfoliating bark, along openings or 

along forest edges where they receive 

a large amount of daily sun. Also 

found in rock crevices, cliffs, and 

buildings. Long-legged myotis forage 

over ponds, streams, water tanks, and 

in forest clearings, often on moths. 

Y Y Minor effect 

Appendix X-39 
 
APPENDIX Y 

Programmatic Agreement Regarding Cultural 

Resources Management 
 
Appendix Y-1
Appendix Y-2
Appendix Y-3
Appendix Y-4
Appendix Y-5
Appendix Y-6
Appendix Y-7
Appendix Y-8
Appendix Y-9
Appendix Y-10
Appendix Y-11
Appendix Y-12
Appendix Y-13
Appendix Y-14
Appendix Y-15
Appendix Y-16
Appendix Y-17
 
APPENDIX Z 

Response to Comments 
 
Site-Specific 

APPENDIX Z: Response to Comments 

Z.1. Comment Period ...............................................................................................................................................Z.2. Responding to Comments Process....................................................................................................................Z.3. Comments and Responses.................................................................................................................................

KEY ISSUES ........................................................................................................................................................

ISSUE: Treatment Effectiveness.....................................................................................................................

ISSUE: Economics and Social Resources.......................................................................................................

ISSUE: Water Quality and Aquatic Organisms..............................................................................................

RESOLVED ISSUES ...........................................................................................................................................

ISSUE: Human Health and Safety ..................................................................................................................

ISSUE: Public Notification.............................................................................................................................

TRACKING ISSUES............................................................................................................................................

ISSUE: Native Plant Communities.................................................................................................................ISSUE: Wildlife Species.................................................................................................................................ISSUE: Soil Productivity ................................................................................................................................ISSUE: Tribal/Treaty Rights and Environmental Justice ...............................................................................

ISSUES OUTSIDE THE SCOPE...................................................................................................................

ISSUE: Implementing Invasive Plant Management .......................................................................................

ISSUE: Aquatic Invasive Plants .....................................................................................................................

ISSUE: Aerial Herbicide Application or Prescribed Fire ...............................................................................

ADDITIONAL ISSUES .......................................................................................................................................

ISSUE: General Comments on DEIS/Purpose & Need ..................................................................................ISSUE: Prevention ..........................................................................................................................................ISSUE: Additional Technical Issues...............................................................................................................

ISSUE: Monitoring and Maintenance.............................................................................................................

Z.4. Agency Comments............................................................................................................................................

Letter 13: City of The Dalles ................................................................................................................................Letter 18: Hood River Soil and Water Conservation District...............................................................................Letter 21: U.S. Department of Interior, Office of Environmental Policy and Compliance ..................................Letter 24: Oregon Department of Agriculture ......................................................................................................Letter 26: U.S. Environmental Protection Agency, Region 10.............................................................................

Appendix Z-1 
Final Environmental Impact Statement 

The objective of this section is to display the public comments received by the USDA Forest Service regarding the thin the Draft EIS for the Site-Specific Invasive Plant Treatments, and to provide responses to these comments. The pub

to update and finalize the analysis in the Final EIS, and to help the Responsible Official select an alternative. 

Z.1. Comment Period The Draft EIS was released and distributed to the public on May 22, 2006. The Notice of Availability appeared in the 

26, 2006, initiating the formal 45-day comment period, which ended on July 13, 2006. Approximately 22 hardcopies CDs, and 977 summaries were either mailed or delivered to individuals, organizations, interested Tribes, and governmrecreational residence permitees, approximately 550 people, received a summary or CD announcing the project. In admade available on the Mt. Hood National Forest website (http://www.fs.fed.us/r6/mthood/projects/) and the project w

(http://www.fs.fed.us/r6/invasiveplant-eis/site-specific/MTH/). Hard copies of the document were made available for 

USDA Forest Service offices. Z.2. Responding to Comments Process During the pubic comment period 25 responses were received (See Table Z-1). Consistent with the National Environm(NEPA), 40 CFR 1503.4(b), this volume addresses substantive comments on the DEIS. Substantive comments includthe information in the DEIS as being inaccurate or inadequate, or which offer specific information that may have a be

Non-substantive comments are those that express opinions without any accompanying factual basis or rationale to supcomments are maintained in the project file in Mt. Hood National Forest Headquarters, Sandy, Oregon. 

A process for responding to comments on a DEIS has been outlined in the USDA Forest Service Handbook (FSH) whpreparing the EIS must “review, analyze, and respond to substantive comments on the draft EIS” (FSH 24.1). Possibl

comments include: 

1. Modify alternatives including the Proposed Action; 2. Develop and evaluate alternatives not previously given serious consideration by the agency; 3. Supplement, improve, or modify its analyses; 4. Make factual corrections; and, 5. Explain why the comments do not warrant further agency response, citing the sources, authorities, or reasons 

agency's position and, if appropriate, indicate those circumstances which would trigger agency reappraisal or 

Appendix Z-2 

All comments were assigned a unique identifying code and logged in. Each substantive comment was then assigned t

for a detailed response. All comments and response are part of the administrative record for this EIS, and have been cdecision-making process. 
Site-Specific 

Table Z-1. List of Respondents to the DEIS. 

Letter 

Number Agency, Organization, Business, or Individual 

Letter 

Number Agency, Organization, Busine

1 LeRoy W. Layton, Individual 14 Larry Grant, Individual 2 B. Sachau, Individual 15 Jean Anderson, Individual 3 Kim Antieau, Individual 16 Carl Ray Clark, Individual 4 Linda Short, Individual 17 Jurgen Hess, Columbia Gorge Ins5 Ron Garcia, Individual 18 Jordan Kim, Hood River Soil & Wa6 B Strasburger, Individual 19 David Marshall, Individual 7 Emery Ingham, Individual 20 Don Mench & Christy Slovacek, In8 Jack Burkhalter, Individual 21 Preston Sleeger, U.S. Department 

Environmental Policy & Complianc

9 Steven M. and Karen R. Schoenfeld, Individuals 22 Gloria Wiemann, Individual 

10 Vern Holm, Northwest Weed Management Partnership 23 Joanna Wagner, Northwest Enviro11 Jennifer Vollmer Ph.D., Environmental Resources Specialist, BASF Corporation 24 Katy Coba, Oregon Department of 12 Anne Saxby, Manager, Hood River Soil and Water Conservation District 25 Michael Carlson, Clackamas River 13 Dave Anderson, Water Quality Manager, City of The Dalles 26 Christine B. Reichgott, Manager of 

Environmental Protection Agency 

Appendix Z-3 
Final Environmental Impact Statement 

Z.3. Comments and Responses The proceeding tables display the substantive comments and USDA Forest Service response by issue area. Full letter

this appendix, expect for comment letters received from governmental agencies (Federal, State and local) per FSH 24letters are available in the project file in Mt. Hood National Forest Headquarters Office, Sandy, Oregon. 

KEY ISSUES 

ISSUE: Treatment Effectiveness 

Invasive plant treatments can vary in effectiveness, depending on the invasive species to be treated, size of the population/infestation, method of treatment, and a host of other factors including timing, weather, soils, and moisturtreatment methods in combination with other factors needs to reflect a balance between optimum effectiveness and 

desirable botanical resources. The proposed alternatives and treatment methods vary in how well they provide the 

treat invasive species and protect natural resources, including water quality, fish, wildlife, soil productivity, and nativcommunities. Further, the presence and spread of invasive plants within the Forest and Scenic Area may affect the presence and invasive plants on neighboring ownerships. The effectiveness of treatments would influence if and to what degree imight spread to other ownerships.

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

2.2 Treatment methods Use hand pulling or goats and stop poisoning every 

inch of earth in this country. 

All alternatives utilize a range of intreatment methods; none propose inch of the earth. Emphasis would herbicide treatment unless they are See Sections 1.3 and 2.1.3 for mo

Appendix Z-4 
Site-Specific 

ISSUE: Treatment Effectiveness 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

6.5 Comment/ 

opinion/position statement 1

In the long run herbicides don't really work, but they are fairly easy to administer and the herbicide makers are happy to receive the federal funds. 

Comment noted. 

11.3 Comment/ 

opinion/position statement 

Addition of newer chemistry will aid in reducing the 

active ingredient to the environment while also increasing effectiveness of treatments. Therefore, I 

support the Proposed Action alternative. 

Comment noted. 

11.5 Early Detection/ 

Rapid Response strategy 

All vehicle tracks (including road and utility right-ofways (ROW)) and hiking trials, excluding wilderness, should be included in the EIS. These are all major possible routes of spread. Due to budgeting, work force and numerous other resources that will be most likely limiting factors to treatment, the opportunity for spread beyond the designated Invasive Plant Treatment Areas is highly likely. Rather than minimizing approved treatment areas and waiting for the invasive plant occurrence to spread, causing a need for amendments and delays, add all travel routes now to assure a cost effective, efficient overall program. These areas and situations maybe covered under the Proposed Action alternative, EDRR, last paragraph of page 2-33. 

The Early Detection / Rapid Respo(EDRR) allows for treatment of uniplant sites that are unknown at this infestations that become establisheintent is to minimize the time betwedetection and USDA Forest Servic(treatment). The EDRR is described in Section2.1.4. 

1 The statement is: 1) a comment, opinion, or position statement with no specific concerns noted about adverse effects of the P

resource; 2) already decided by law, regulation, Forest Plan/Management Plan, or other higher-level decision; 3) outside the sAction; 4) irrelevant to the decision to be made; or, 5) conjectural and not supported by scientific evidence. 

Appendix Z-5 
Final Environmental Impact Statement 

ISSUE: Treatment Effectiveness 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

26.1 Toxicology Because science cannot, in any practical sense, 

assure safety through any testing regime, pesticide use should be approached cautiously. 

A conservative, cautious approach the Invasive Plant ROD standards which are above and beyond label advisories. For example, PDC A.8applications would not exceed the rates specified in Table 2-7, excepInvasive Plant ROD Standard 15 (2the use of licensed herbicide applictrained and tested in safety applicawell as safe disposal techniques. The Invasive Plant ROD standards in Appendix A; the PDC are listed layers of caution are discussed in S

26.2 Toxicology Aside from the potential for toxic effects to people, 

overuse of pesticides may cause problems such as: a)killing beneficial organisms that would otherwise help control pests; b) promoting development of pesticide resistance in pests, which starts a vicious cycle in which more and more pesticides are needed: c) resurgence of pest populations, and d) contamination of the environment. 

Compliance with Invasive Plant RO(2005b) would reduce the need for treatments over time by requiring ta long-tem site strategy for restorininvasive plant sites prior to treatmeeffective treatment methods and madverse effects to non-target specwould comply with Standards 19 arestoration strategies for this projeSection 2.1.3. Herbicide label advisories further dpotential for the development of hefor specific herbicides. All label direfollowed, as required in PDC A.1. Also, see response to Comment 2Effectiveness). Non-herbicide treatwould be used unless they are ine

Appendix Z-6 
Site-Specific 

ISSUE: Economics and Social Resources 

Invasive plant treatments vary in cost, which affects the acreage that could be effectively treated each year given a proposed treatments would be costly and fiscal resources are always limited. In addition to cost efficiency, the treatvary in the amount of employment provided. Increasing the number of jobs could benefit local communities that are 

reduced employment levels. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

6.6 Economics Hand digging and pulling give people jobs and has a 

much less negative impact. 

Section 3.7.3 of the EIS shows thabe created as the amount of manutreatment increases. Hand pulling, have less impact necessarily and ttreatments may actually exacerbatproblem. As documented in Sectioexample, “some authorities do not manual or mechanical treatment of because disturbance to the plant cgrowth of new plants from fragmenand rhizomes and redistribute the their rate of spread (Montana State Extension Service, 2006).” In Sectanalysis concluded that “many of tproposed for treatment are most ewith herbicide methods, making nomethods ineffective and unsuccess

17.7 Economics While expensive, this more natural weed control 

method provides jobs for rural people and is effective. Of course, a caution is that goats tend to eat everything, including native plants. 

Comment noted. As documented i“grazing could either promote or reabundance at a particular site. Whtreatments are combined with othetechniques, such as herbicides, secould be reduced and small infestaeliminated. 

Appendix Z-7 
Final Environmental Impact Statement 

ISSUE: Economics and Social Resources 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

17.10 Outside the scope Funding must be addressed in this strategy. Show 

Congress what the complete costs are. Educate congressional staffers as to the issue and what the needs are – that’s not lobbying. 

See response to Comment 17.6 (Isand Maintenance). 

26.3 Economics Integrated pest management, when viewed by 

traditional economics, often results in lower costs than conventional pest management. Additional costs beyond those considered in traditional analysis are likely to shift the balance even further towards IPM. Some of these additional costs are: potential long-term health effects, contamination of the environment, effects of pesticides on non-target animals and plants, the health effects to someone who may be particularly sensitive to a pesticide or pesticides, and any other effects that are not now understood, but will be uncovered over time. 

The alternatives were analyzed usof economic, quantitative, and quaprovide an assessment of effects bconsidered in “traditional” econom– Economics for more details. Integrated weed management (IWtechniques are incorporated into ais a process by which one selects combination of management technmechanical, and herbicide for examwould control a particular invasive infestation efficiently and effectiveladverse impacts to non-target orgaspecies-specific, site-specific and dpractical with minimal risk. 

Appendix Z-8 
Site-Specific 

ISSUE: Water Quality and Aquatic Organisms 

The application of herbicides in riparian areas has the potential to contaminate water and cause mortality to fish anspecies. Herbicides that do not directly affect fish may affect their food chain through lethal effects to aquatic insectalgae. Sub-lethal effects, such as behavior changes, could result in increased vulnerability to predators. Fish and oorganisms may also be impacted by manual and mechanical treatments, which may change dissolved oxygen levewater temperature, turbidity, fine sediment, and riparian structure. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

23.17 Water quality Water quality and the well-being of aquatic 

organisms are threatened more by herbicidal control methods than by either invasive plants or nonchemical means of controlling invasive plants. The Forest Service must carefully analyze the effects of its proposed actions on dissolved oxygen, water temperature, stream turbidity, peak flows, low flows, water yield, and water chemistry. The area of most concern is that of water chemistry. We urge the Forest Service to consider a less herbicideintensive method of invasive plant control. 

A thorough analysis of effects to waquatic organisms is contained in S3.10, and associated specialist reputilizes a blend of pertinent researcmodeling and literature review to deffects to water quality and aquatic implementing all of the proposed a3.9 includes discussion on the direcumulative effects of water quality disturbance, turbidity and fine sedioxygen and nutrients; water tempeflows/low flows/water yield; riparian water chemistry. This section was the analysis conducted and the resAlternative 3 (Restricted Herbicide less herbicide-intensive method of control. Only 4,047 acres were protreatment. 

Appendix Z-9 
Final Environmental Impact Statement 

ISSUE: Water Quality and Aquatic Organisms 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

23.18 Aquatics We also urge the Forest Service to use caution 

when treating invasive plant populations near riparian areas. Aggressive treatment may not be necessary to protect riparian systems; it might damage them instead. While “trained field crews that are effectively supervised can achieve safe herbicide applications that do not result in biologically significant direct application or drift of herbicide into vegetated areas more than 25’ from the edge of the treated area,” (DEIS 3-139) perfect applications may not be the norm. Thus a plan of action that completely eliminates herbicide applications anywhere near the vicinity of these streams would be ideal. The Forest Service must remember that the effects of some herbicide ingredients – surfactants, adjuvants, and inert ingredients – have not been thoroughly studied, and aquatic species are more susceptible to their effects than terrestrial species. 

Only trained and State or federapplicators would apply herbicisites within the Forest and ScePDC were carefully crafted to geliminate, the chance that herbotherwise move off-target. As outlined in Sections 3.9 and riparian dependent native faunof invasive plant treatment are negligible. Riparian function annative vegetation benefits, wouof proposed invasive plant treawere not treated, invasive plancontinue to spread, and have driparian native vegetation compstructure. The best available information reviewed risk assessments, incregarding surfactants, adjuvantingredients. These results were aquatic-related analysis and in (Section 2.2). See also respons11.16, 23.10, and 23.16. 

23.19 Aquatics Of specific concern are the seventeen sites 

mentioned on DEIS 3-151, for which modeling showed that four herbicides (glyphosate, AQ glyphosate, AQ triclopyr, and picloram) could result in exposures that exceed the acute NOEC for fish. The Forest Service expects the amount of herbicide to reach the water to be less than modeled, due to “physical characteristics that would further minimize 

the risks posed by herbicides such as well vegetated buffer strips, larger streams than modeled, and few acres treated in the aquatic influence zone.” (DEIS 3-151). This would be unnecessarily risky behavior on the part of the 

The analysis presented in Sectoutlines why the GLEAMS modrisk assessments would overesherbicide reaching water at Fotreatment sites. PDC would fur

amount reaching any water bodThe four herbicides do not all eat all seventeen sites – there aproposed for use at each of the used instead that did not exceeViable populations of aquatic smaintained if invasive plant tre

Appendix Z-10 
Site-Specific 

ISSUE: Water Quality and Aquatic Organisms 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

Forest Service, and contrary to the mandates of 36 C.F.R. 219.19, which states that “Fish and wildlife habitat shall be managed to maintain viable populations of existing native and desired nonnative species,” and 36 C.F.R. 219.27(a)(1), which states that “All management prescriptions shall: Conserve soil and water resources and not allow significant or permanent impairment of the productivity of the land.” 

implemented as proposed. Nonother treatment methods would individuals, and any sub-lethal biologically irrelevant (i.e. they fitness, survival, or some aspec

23.20 Aquatics The Forest Service admits that, “Alternative 3 relies 

more on manual and mechanical treatments. For example, over half of the riparian reserve acres (52 percent) in this alternative would be treated with non-herbicide methods only, compared to less than 1 percent in Alternative 2. Similarly, 57 percent of aquatic influence zone treatments would be nonherbicide treatments only, compared to 0.1 percent in Alternative 2.” Under this plan, fish at only seven sites would face the possibility of mortality due to applications of glyphosate. Surely the Reduced Herbicide Use Alternative is a better plan of action for aquatic species. However, the Forest Service excuses itself from this action by claiming that control methods would be less successful and would require that sites be treated more frequently. The Forest Service has defeated its own logic, however; no additional damage to the environment would occur from more frequent treatments, because only minimal damage is expected to occur from manual, cultural, and mechanical means of control in riparian areas. It is the price of labor that is the issue. 

Section 3.10.2.4 - There would fish resulting from herbicide apalternative (Alternative 3). The there are seven sites in this alt17 in Alternative 2, where the p

concentration could exceed the 

However, the actual amounts rless than predicted due to site (Section 2.2). Chapter 2 in the EIS describes assumptions regarding treatmeand mechanical methods geneas herbicide treatment. For somspecies, manual or mechanicaexacerbate the infestation, leadexistence and spread (see Sec

Appendix Z-11 
Final Environmental Impact Statement 

ISSUE: Water Quality and Aquatic Organisms 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

24.6 Water quality One of the pesticides on the proposed list, triclopyr, 

was detected in surface waters during the USGS National Ambient Water Quality Assessment (NAWQA) studies of the Willamette Basin. (pubs.usgs.gov/circ/circ1161/nawqa91.html). The number and frequency of detections of various herbicides found in the NAQWA study suggests that standard application practices may result in presence of herbicides in streams, sometimes above water quality standards. It should be noted that the occurrence in Oregon waters of some of these pesticides, such as chlorsulfuron, imazapic, imazapyr, metsulfuron methyl, sethoxydim, and sulfometuron methyl is unknown because of a lack of water quality data. 

A thorough analysis of effects taquatic organisms is contained 3.10, and associated specialist utilizes a blend of pertinent resmodeling and literature review effects to water quality and aquimplementing all of the proposesections were updated to clarifconducted and the results. In addition, PDC aimed at minidetrimental effects to water quausing the aforementioned soursources of the PDC include BePractices (BMP) suggested by Department of Environmental Qpesticide and herbicide applicarecommended by the EnvironmAgency (EPA) Region 10 for soThe majority of pesticides idenUSGS National Ambient Water (NAWQA) studies of the Willamin basins draining predominateareas. The report states that “Odeethylatrazine were detected forested basins (greater than 9area), and these compounds wextremely low concentrations ((Wentz et al, 1998). Neither of proposed for use with this proje

24.7 Aquatics As a result of a lawsuit filed against the EPA by the 

Washington Toxics Coalition (2002), a federal judge ordered that “buffer zones” be placed around salmon bearing streams for the application of certain pesticides. Of the 26 pesticides still being 

investigated for their potential effects on threatened and endangered salmon species, diuron, 2,4-D, and triclopyr are the only three that are approved for use 

Triclopyr is the only herbicide pproject that is discussed in the Coalition et. al. vs. EPA lawsuiorder from the lawsuit specificaweed programs and allows “the control of state-designated noxadministered by public entities, program implements the follow

Appendix Z-12 
Site-Specific 

ISSUE: Water Quality and Aquatic Organisms 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

on national forests. DEQ asks that the USFS keep these restrictions in mind during the potential application of these pesticides. (www.epa.gov/espp/wtc/maps.htm) 

NMFS (National Marine Fisherrequires for such programs . . .2004). The safeguards are listeEIS. These safeguards are incand through consultation with rincluding NMFS and U.S. Fish 

24.8 Water quality The Source Water Assessments of the Safe 

Drinking Water Act Amendments provide a database of information about the watersheds and aquifers that supply public water systems in Oregon. USFS should consult with DEQ to ensure that the GIS shape files of the 5th-field watersheds and 

aquifer recharge areas are included in the USFS GIS data in this area. As the USFS project team selects alternatives to address areas within the municipal watersheds and groundwater recharge areas, the focus should be on decreasing the risks presented by the potential contaminant sources on national forests. 

The most recent information on Drinking Water Protection Areathe DEQ and is included in Appconfirmed in a July, 2006 phonSheree Stewart of DEQ. 

24.9 Water quality Within the mission, budget, and legal authority, we 

request that the USFS consider local drinking water protection priorities when developing management plans for federal lands and facilities. This will 

preserve the use of public funds that would otherwise be spent to upgrade treatment facilities to remove the contaminants downstream. 

Considerable effort went into repotential detrimental effects to project. Section 3.9 – Water Qudiscussion of those potential efupdated to clarify the analysis 

24.10 Water quality To prevent the potential increase in sedimentation 

from the removal of vegetation, we recommend the use of less intensive treatments in the areas adjacent to public water supply streams and the intakes. We do recognize that vegetation removal can occur from natural events, especially as a result of fire. 

Invasive plant eradication has ttemporarily leave treatment areground cover which in turn has increased erosion and resulting addition, equipment used in plapotential to disturb or displace more vulnerable to erosion. Shbe mitigated by creation of a rewould identify specific measureagainst erosion and resulting s

Appendix Z-13 
Final Environmental Impact Statement 

ISSUE: Water Quality and Aquatic Organisms 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

measures would be tailored to on site specific conditions in thTypical measures such as apphydroseeding with soil binding control blankets may be used tfor soil detachment from raindrfavorable environment for nativestablish faster in the treatmenSee Sections 3.8 – Soil ProducQuality for more details. These to clarify the analysis and resuto Comment 23.17 (Issue: WatOrganisms). 

24.11 Water quality Herbicides can negatively impact the water quality 

in streams and groundwater serving as public water supply sources. Most herbicides are not monitored at the intakes or wells for public water supplies as part of the routine requirements to meet federal drinking water standards. Most communities and public water providers do not have the resources to increase their monitoring capabilities when significant areas are sprayed adjacent to or upstream of their intake or well. 

See response to Comment 24.and Aquatic Organisms). Also, Quality provides more informateffects to water quality in streaservicing as public water suppl

24.12 Water quality We recommend that USFS establish direct 

communication with the public water system operator or community liaison downstream of the USFS land management areas. As with all of our state and federal partners, we request that USFS’s management alternatives in the municipal watersheds/aquifers should be selected to support the overall goal of providing the highest quality water possible to downstream intakes and wells. 

Contact was made to cities thaProtection Areas identified for twere provided an opportunity to project. Contact with these varcontinue throughout the life of twith this project as this is a vercommunication link to maintain

Appendix Z-14 
Site-Specific 

RESOLVED ISSUES 

ISSUE: Human Health and Safety 

Invasive plant treatments within the Forest and Scenic Area may result in health risks to forestry workers and thcontamination of special forest products and drinking water. The health and safety of forestry workers and the pfrom exposure to herbicides. The public expressed particular concern about human health effects related to the chemicals and drinking water contamination. Public concern for drinking water contamination is high for the Foras a drinking water source for approximately a third of Oregonians. Implementing the PDC, as required by the amitigate any possible impacts to human health and safety. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Co

2.1 Comment/ opinion/ 

position statement 

I for one am sick and tired of toxic chemical pollutants covering our forests in the drive to get rid of invasive exotics. 

Comment noted. 

3.3 Toxicology & 

treatment methods 

I have asthma and chemical sensitivities and could become seriously ill if I come in contact with pesticides. Unfortunately we have many people in the area with cancer and other immune problems who could also be harmed by these herbicides. 

Risk assessments indicate these be detrimental to human health, application methods and rates. Frisks are smaller than one in a m2003a; 2003b; 2003c; 2004a; 202004e; 2004f). Further discussioare contained in Section 3.5 – HSafety. 

Appendix Z-15 
Final Environmental Impact Statement 

ISSUE: Human Health and Safety 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

6.4 Toxicology I have cancer and could become seriously ill if I 

come in contact with pesticides. Unfortunately we have many people in the area with other immune problems who could also be harmed by these herbicides. 

See response to Comment 3.3 (and Safety). 

15.2 Toxicology One needs to be mindful of current and prior 

lawsuits and, at minimum, EPA phaseouts of acknowledged "dangerous pesticides"... In the late 1960s persons in the Coast Range observed that their lands were being sprayed by the FS under the guise of "eliminating weeds and scrub"...The described "harmless" agent in the Siuslaw NF areas was identified as being 2,4,5T -- "dioxin" the most toxic molecule known at that time. It became widely known as "Agent Orange", the air-deposited pesticide used first in the Viet Nam. Agent Orange's effects are now a definitive issue for the VA's treatment of affected military personnel -- and a costly error for all taxpayers in terms of financially supporting the gross neglect of the dangers of Agent Orange. Similarly, despite the on-going use domestically of other pesticides, many have been shown to be carcinogens (19 products), 13 have been hormone system. 

Standard 16 of the Invasive Planstates: “Select from herbicide forone or more of the following 10 achlorsulfuron, clopyralid, glyphosimazapyr, metsulfuron methyl, psulfometuron methyl, and triclopyEIS tiers to these standards. As active ingredients listed in this stfor use on the National Forest Sy(a.k.a. Agent Orange) and other not approved for use. Information from laboratory and herbicide toxicity, exposure, and was used to estimate the herbiciassessments. Formal risk assesSyracuse Environmental Resear(SERA) using peer-reviewed artiscientific literature and current Eincluding Confidential Business Iconsidered worst-case scenarios exposures and application at maAt the project scale, additional labe integrated into herbicide use alternatives: 

Appendix Z-16 
Site-Specific 

ISSUE: Human Health and Safety 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

• Treatment methods would be 

necessary to eradicate, controplants on the Forest and Scentreatment is proposed and browould be limited to certain aremethods would be chosen bakey presented in Figure 1-4. 

• PDC would ensure proposed 

do not exceed conservative thfor human health, water qualitbotanical, wildlife and aquatic concern. The analysis throughdemonstrates that herbicide uin exposures of concern. 

More information on the impacts human health and safety can be of this EIS. 

23.10 Toxicology Important questions about the dangerous effects 

of some herbicides remain unanswered. The chemicals deemed safest for application, strangely enough, appear to be those least thoroughly studied. The effects of Imazapic on soil organisms have not been studied at all. NEPA also mandates that the Forest Service evaluate the nonlethal effects of herbicides on plants. The DEIS omits important recent research in this area, which examines the mutagenic effects of 2,4-D at exposure levels below application rates, and the increase in disease susceptibility to plants exposed to glyphosate. Finally, it is crucial to further investigate how herbicidal chemicals combine together to become synergistically toxic, and how their inert ingredients, and surfactant and adjuvant additives, affect plants and soils. 

Risk assessments considered acadditives, surfactants, metaboliteassessments are discussed in SHerbicides, Adjuvants, SurfactanIngredients, and referenced throUncertainties have been considethroughout Chapter 3. Uncertainthrough PDC that limit the rate, therbicide application sufficiently scenarios that would cause concImazapic is degraded by soil mic3.8 – Soil Productivity). Some starthropod population increases ocan utilize the carbon on some ofood source. There are effects of target plants, as discussed in Seand Treatment Effectiveness. 

Appendix Z-17 
Final Environmental Impact Statement 

ISSUE: Human Health and Safety 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

2,4-D is not proposed for use in 10 herbicides analyzed in the Inv(2005a) can be used on the ForeThese herbicides are listed in InvStandard 16 (2005b). Further, there are no known syneany of the proposed herbicide foanalyzed in the Invasive Plant FEenvironmental effects documenteof these formulations have been assessments for all proposed hedisclosed known effects. 

Appendix Z-18 
Site-Specific 

ISSUE: Public Notification 

The application of herbicides raises many public concerns; informing the public of invasive plant treatments wousome concerns. Information regarding location, time, and treatment method/type should be provided before treaPublic notification is a required component of the PDC. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

15.3 Public involvement I was unable to attend the "open house" on this 

subject . Notice of this event appeared on the same day as it was to occur, in the Oregonian via a very small announcement. Surely this was an ineffective way to announce such a vital issue to the public. 

The USDA Forest Service hosteJune 8, 2006 in Hood River and releases announcing these meetto local newspapers, including TMay 26, June 6 and June 14, 20of the meetings appeared in SanNews and The Oregonian. In addition, information regarding was posted to the Mt. Hood Natias well as the project website (http://www.fs.fed.us/r6/invasivep

specific/MTH/). Finally, a postca

meetings was distributed to the pcopy of the list is available at the Forest Sandy Office. 

Appendix Z-19 
Final Environmental Impact Statement 

TRACKING ISSUES 

ISSUE: Native Plant Communities 

Invasive plant treatments, especially herbicides may harm non-target plants, including culturally significant and 

species (USDA Forest Service Pacific Northwest sensitive plants, Survey and Manage plant species, federally l

and endemic plants). Different herbicides have varying degrees of potency and selectivity (e.g., some herbicide

plant families more readily than others), and application methods vary in the potential for off-site drift. As invasivnative plants are expected to benefit through increased habitat. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

22.1 Toxicology I am concerned by the use of herbicides like 

Imazapyr. It is not plant specific, so rare and endangered plants are also at risk. With a half-life of 17 months, and its high mobility, it can contaminate soil and water. 

Imazapyr is a non-selective herbdoes pose risks to non-target plamanaged through PDC that provknown sites of plants of concernbotanical buffers incorporated inHalf life of Imazapyr in soil is 25 herbicide is decomposed by sunmicrobes (See Appendix U). Potlow risk to fish, birds, mammals, to soil and water are minimized blabel requirements (PDC A.1.) aimplementing the PDC, especialWater Quality and Aquatic Organfor soils. All PDC are listed in SeMore information on the properticorresponding protection measuAppendix Q. 

Appendix Z-20 
Site-Specific 

ISSUE: Native Plant Communities 

Comment 

Number 

Comment Summary/ Topic Comment Text Response to Comment 

23.9 Botany The Forest Service fails to effectively consider the 

general impacts of its proposed actions. As a specific example, it fails to analyze the effects of herbicides on the population health of non-target plant species, saying that such information is unavailable, as studies have only been done on crop species. (DEIS 3-50). The Endangered Species Act (ESA) requires the Forest Service to use the best available scientific and commercial data in assessing the impacts to such species. The Forest Service has been using herbicides to eradicate invasive plant populations for years. Surely these treatments have produced some hard data about the effect of chemical control methods on non-target species. The law requires such data to have been collected. Additionally, the Management Plan for the Columbia Gorge National Scenic Area mandates specific sensitive plant protection standards. Revised Management Plan (RMP) at I-87-89. The Management Plan also includes a list of rare plant species in the Columbia Gorge. Management Plan, at I-134-35. Endemic species such as Howell's daisy (Erigeron howellii) and Oregon bolandra (Bolandra oregano) along with all listed rare plants must be protected by adequate buffer zones. The Forest Service must take special measures to prevent the further degradation of the habitat of sensitive plant species, eight of which are located in areas marked for invasive plant control measures. (DEIS 3-34). The Forest Service must also comply with the natural resource protection requirements for any actions that would occur in the National Scenic Area. Its willingness to gamble with the well-being of endangered 

Negative impacts (adverse effecfrom treatment of invasive plants EIS. It is acknowledged that natispecial status plant species, may weakened, or killed by treatment mechanical, cultural, or herbicidedemonstrates that herbicide treaagainst invasive plants. Some hedesigned to kill only plants in cerfamilies in order to avoid killing nMonitoring data indicates that theadversely impact non-target floraare not in the scientific literature, data is antidotal and professionaForest Service botanists and theThe proposal outlines six steps tplant species (Project Design CrThese measures are analogous the Scenic Area Management Plspecies protection guidelines. Buentered to treat invasive plants; a Alternative Test and Mitigation Pcompleted (See Appendix C). Thfound to fulfill the General ManagRare Plant guidelines. An Invasivwithin Sensitive Buffer Zone “PraTest and Mitigation Plan also weAppendix C). The EIS analyzed the sensitive pdefined by the Scenic Area ManaAdditional language has been adThe analysis concluded that impplants would be insignificant if thimplemented with the appropriatdesigned to minimize or eliminatimpacts. 

Appendix Z-21 
Final Environmental Impact Statement 

ISSUE: Native Plant Communities 

Comment Comment 

Number Summary/ Topic Comment Text Response to Comment 

populations of plants is alarming. The USDA Forest Service maint

regarding herbicide and pesticide on National Forest System landsavailable by contacting the Mt. Hheadquarters office of the ColumNational Scenic Area office. 

Appendix Z-22 
Site-Specific 

ISSUE: Wildlife Species 

The use of herbicides to treat invasive plants, if used in the certain habitats, could harm a variety of wildlife species. successional, wetland, talus, and aquatic habitats have special status species that may be affected by herbicides. Chave the potential, for example, to affect the vital organs of some wildlife species, change body weight, reduce the n

offspring, increase susceptibility to predation, or cause direct mortality. Wildlife, especially birds and mammals, may or insects that have been sprayed with some herbicides and potentially experience these types of effects. Amphibianpermeable skin that can absorb herbicides that affect them but herbicide effects to amphibians have not been thorouAquatic life stages of amphibians are susceptible to herbicides, but very little information has been documented on therbicides. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

6.1 Toxicology I am very concerned about pesticide use in the Mt. 

Hood National Forest and the Columbia River Gorge. These are heavily used recreational Areas and these areas contain many threatened and endangered species. 

Risk assessments indicate these hbe detrimental to human health, giapplication methods and rates. The are designed to avoid or minimize sensitive resources, including threaendangered species. These PDC ewould be no effect to human healthrecreationalists, as discussed in SeAquatic: The aquatic organisms an

indicates that the proposed herbiciwould not result in the direct mortaincluding threatened and endangeamount of herbicide entering streais expected to be biologically meanany, from herbicide application to flethal in nature. This analysis is dis3.10. 

Appendix Z-23 
Final Environmental Impact Statement 

ISSUE: Wildlife Species 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

Wildlife: The wildlife analysis indica

would be no effect to either of the tendangered species (Northern SpoEagle) that occur on the Forest anThis is shown in Table 3-36, and ththese species is in Section 3.11. 

23.14 Correction While the DEIS states that its goals will be reached 

by “manipulating vegetation to benefit fish and wildlife habitation. . .” (DEIS 1-3), there is no indication that this result would follow from the preferred action. The DEIS admits its own flaws in the Executive Summary, stating that the Proposed Actions “risks to non-target plants and animals, especially species of concern, have not been adequately evaluated.” (DEIS 3-2). This clearly violates 36 C.F.R. 219.19, which states that “Fish and wildlife habitat shall be managed to maintain viable populations of existing native and desired non-native species.” 

The two quotes in the comment cathe referenced pages or other sectThe purpose of this project is to ercontrol invasive plant infestations, negative impacts caused by the invto restore healthy, native plant comfunction at the impacted sites in a manner that meets current manageSee Section 1.2 for more details ogoals. 

23.21 Wildlife The true effects of herbicide applications on 

individual wildlife species are unknown and it is unwise to gamble with the health of already threatened animal populations. The use of herbicides to manage invasive plants has the potential to harm free ranging wild animals and birds, especially those that eat grass and insects. Alternative 2 chemically treats the greatest amount of habitat that includes mature forest, thus increasing the potential for exposure of special status species wildlife. (DEIS 3-175). It increases the amount of herbicide sprayed by 500%! It makes little sense to choose an action alternative that increases the survival pressures on already 

The EIS discloses that there is somthe wildlife effects analysis. As a madditional information across a widgroups, surrogates have been usetaxonomic groups of animals and fsurrogate for aquatic amphibians (The surrogates for testing are listeX-2 in Appendix X. The Regional I(2005a) Appendix P is referenced. The wildlife analysis discloses that bisects or traverses the greatest aforest. The wildlife analysis further examining the life cycles of the speit becomes evident that the concerminor because these species do nseral habitats adjacent to their pref

Appendix Z-24 
Site-Specific 

ISSUE: Wildlife Species 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

Appendix Z-25 

sensitive species. Conversely, there are no adverse effects to habitat from the use of manual, mechanical or cultural treatment to any of the species analyzed for any of the alternatives, with the exception of the possibility of disturbance of nesting birds. The Forest Service claims that, “[t]he biggest difference in the effect of [the Reduced Herbicide Use Alternative] compared to the Proposed Action is the effectiveness of the treatment. Manual, mechanical and cultural treatments have been attempted in the past as the sole way to control invasive plants and the effect has been met with very minor successes....This alternative still puts the species that rely on the early successional habitat at more risk from habitat loss, compared to the risk that a few individuals could receive a toxic dose of an herbicide treatment.” (DEIS 3-177). However, we see no concrete evidence that the reason for the failure of past non-chemical methods of control was the method itself, rather than the product of the construction of new forest roads, or of clearcut logging, or of poorly executed mechanical treatment methods, or lack of follow-up on removal projects. 

habitats on a regular or frequent ba– Wildlife). Also, the wildlife analysis demonsthabitats being treated are not the pany species analyzed, except deerPacific pallid bat, and band-tailed pdiscloses that these species could in treated areas, and could be exp(See Table 3-36 in Section 3-11). Soccasionally travel into the sprayed dispersing from their primary habiteffect also would be minor (See Ta3-11). The EIS points to several examplewhere manual and mechanical treaattempted and were unsuccessful. Conservancy and the Montana StaExtension Service recommend agaand mechanical treatments for cerSee Section 3.6 – Botany and TreaEffectiveness for more details. See responses to Comments 23.2 Prevention) for discussion of mana

23.22 Wildlife The Forest Service is apparently willing to risk the 

well-being of threatened and sensitive species such as the Northern Spotted Owl and the Crater Lake Tightcoil (“It is possible that some individuals may be removed from the population” (DEIS 3-204) as well as from other mollusk populations). It is willing to experiment with the health of the populations of various salamanders and turtles, when the effects of herbicides on amphibians and reptiles is not as well understood. It is also willing to use herbicides on areas known to be frequented by deer and elk, knowing that they sometimes tend to forage repeatedly in the same areas and that they tend to 

Section 3.11 - Wildlife discloses thsome species may be affected by case of the Northern Spotted Owl, individuals harmed, harassed, killeherbicides. There would be no impprimary constituent elements of spThe indirect effect of noise and disnegligible due to the very small arehabitat and low noise created by msprayers in the project area. The minvasive plant treatments that wouoccur along roads and openings. 
Final Environmental Impact Statement 

ISSUE: Wildlife Species 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

ingest more herbicides than any other animal, due to their grazing on leafy herbs. Triclopyr is especially toxic to ungulates, but will nevertheless still be used as a spot spray. 

In the case of the Crater Lake Tighdiscloses that there is a rare possiindividuals may be killed by invasivriparian areas. The analysis shows studies indicated that there would mollusk from herbicide treatment. Talso points out that the footprint of small and that PDC would assist in Section 3.11 discusses that some exposed to herbicides due to their herbicides are used in openings of high probability that deer and/or elsome herbicides. Since triclopyr is deer and elk the use of spot spraythe dosage that the deer or elk wopossible for these animals to recei

cause harm or make them more supredators. The number affected is very small. 

Appendix Z-26 
Site-Specific 

ISSUE: Soil Productivity 

Healthy soil organisms are fundamental to the ability of soil to provide water and nutrients to plants. All herbicides poaffect soil microorganisms. Manual and mechanical treatments may cause soil disturbance and/or erosion. Due to thimpacts and the removal of vegetation, slope stability may be impacted. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

11.17 Soils Table 3-17: In regard to Imazapyr and soil 

persistence: I am unsure of what your data source is for the table, but it appears old soil persistence data was used (original data submitted to EPA). Prior to the knowledge that imazapyr was degraded in soil by micro-organisms, sterile soil was used for persistence studies. Obviously with no microorganisms in the soil, imazapyr was not broken down. Typically imazapyr has a half-life in soil of three months, similar to other Imis and SUs. There are no cases of imazapyr and imazapic having been detected in ground water. 

This comment is correct. Based upTable 3-17 has been changed to reinformation. The rankings in the tasame. The updated data can be fohttp://tncweeds.ucdavis.edu/produ

azapyr.pdf. 

23.8 Soils & botany The DEIS does not adequately consider both 

cumulative and general impacts to plants and soils. The current DEIS fails to show how past herbicide use and invasive species management activities have negatively or positively affected the environment. NFMA requires monitoring “at intervals established in the plan, implementation shall be evaluated on a sample basis to determine how well objectives have been met and how closely management standards and guidelines have been applied.” 36 CFR 219.12(k). Vague or general statements of impact are not sufficient, impact from projects must be discussed on an individualized basis. Lands Council, 395 F. Supp. At 1028. 

The cumulative and general impacdiscussed in Section 3.6, and the idiscussed in Section 3.8. Monitoring would occur to ensure tare meeting the prescriptions and implementation has occurred accomanagement standards. This is reactivities. New language has been document clarifying the role and ex(see Section 2.3). 

Appendix Z-27 
Final Environmental Impact Statement 

ISSUE: Soil Productivity 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

NFMA clearly directs the Forest Service to create regulations to “insure research on and (based on continuous monitoring and assessment in the field) evaluation of the effects of each management system to the end that it will not produce substantial and permanent impairment of the productivity of the land.” 16 U.S.C. § 1604(g)(3)(C); Sierra Club v. Martin, 168 F.3d 1 (11th Cir. 1999). There is no evidence that the Forest Service thoroughly monitored and assessed each particular invasive plant control action previously undertaken, as required by law. We instead read anecdotal comments about how such actions have failed in the past due to the restricted use of herbicides. Detailed data about how past Forest Service land use and management practices have affected vegetation is also lacking. (DEIS 4-206.) For example, we cannot know for sure that new weed infestations were a result of a pure failure of non-herbicide methods of control. They may have been the product of the construction of new forest roads, or of clearcut logging, or of spotty mechanical treatment methods, or lack of follow-up on removal projects. Such vagueness in analysis is impermissible. 

Evaluation as to how well this has the past is contained in the annual monitoring reports for the Forest aThe annual monitoring reports for tavailable on-line at: http://www.fs.fed.us/r6/mthood/pub

results of the monitoring reports arexisting conditions sections contairesource area. In addition, impacts on individual sdisclosed in Chapter 3 in the EIS. information is available regarding teffectiveness since neither the Forhas had the authority for widespreaFurthermore, the Invasive Plant ROthat invasive plants be a consideraassessments as required by StandAs an example, any major road woconstruction or decommissioning) invasive plant prevention and treat

23.11 Law and 

regulations & soils 

The DEIS must adequately analyze the impact of herbicides on soil resources and productivity. NEPA requires that an EIS contain “high quality information and accurate scientific analysis...If there is incomplete or unavailable relevant data, the [EIS] must disclose this fact” up-front. Lands Council, 395 F.3d at 1031-32 (citing 40 C.F.R. § 1502.22). Decisions based on fuzzy science should be unacceptable to the public. The Forest Service admits that “the effect of an herbicide treatment on the soil depends on the particular characteristics of the herbicide used, how it is applied, and soil physical, chemical, and biological conditions.” (DEIS 

Council on Environmental Quality d“evaluate reasonably foreseeable seffects on the human environment environmental impact statement anincomplete or unavailable informatshall always make clear that such lacking” (Section 1502.22). Each reincludes an “incomplete and unavasection (See Sections 3.3.3, 3.5.8, 3.9.7, 3.10.4, 3.11.11, 3.12.5, 3.133.15.9). Section 3.8.8 discloses the unavailable information related to s

Appendix Z-28 
Site-Specific 

ISSUE: Soil Productivity 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

3-70). Generalizations about herbicide effects, then, are not permitted, and they are often attempts to minimize the lack of available data on the topics. 

Section 3.8 – Soil Productivity provand analysis on the characteristics used, how it is applied, and soil phand biological conditions that woulThe potential impacts are summarTable 3-17, and Appendix U. Appedetailed report of the impacts of easpecific soil types. In addition, the PDC (Section 2.2) minimize or eliminate effects from treatments, in part to provide addeuncertainties associated with herb

23.12 Soils In one paragraph, the Forest Service says three 

different things: that herbicides are harmless, that they are less harmful than other methods of control, and that they really do not know much about the effect of herbicides on soil biology. Which statement is the public to believe? The Forest Service ultimately states that “it is likely that all herbicide treatments would have some effect on soil biota, but these effects would be more or less transitory depending on the timing, frequency, and herbicide used.” Basically, we are told that what we don’t know, won’t hurt us. This is unacceptable under NEPA. 

Appendix Z-29 
Final Environmental Impact Statement 

ISSUE: Tribal/Treaty Rights and Environmental Justice 

Protecting and maintaining traditional uses of plants, animals, fish, and water rights on tribal reservation lands and thAmerican Indian Tribes is a trust responsibility of the Federal Government. The Confederated Tribes of Warm Springoutside the bounds of their Indian reservation on ceded as well as usual and accustomed sites on the Forest. Invasivtreatments have varying impacts to culturally significant plants, which include huckleberries (Vaccinium membranace(Camassia species), and possibly bitterroot (Lewisia rediviva) for the Confederated Tribes of Warm Springs, Yakama Confederated Tribes of the Grand Ronde, Nez Perce Tribe, and Confederate Tribes of the Umatilla Indian Reservati

Comment 

Number 

Comment Summary/ Topic Comment Text Response to Comment 

26.10 Tribal We appreciate the effort undertaken by the Forest 

Service to engage the Tribes, but recommend that the final EIS clarify the status of communication with the tribes that did not consult. 

No comments were received from members during the 45-day public All Tribes were sent a letter inviting on the EIS and informing them of tThe comment period expired and tService did not receive comments Ronde, Yakama, Umatilla and Nez allowed. 

Appendix Z-30 
Site-Specific 

ISSUES OUTSIDE THE SCOPE 

ISSUE: Implementing Invasive Plant Management 

Some members of the public suggested that the USDA Forest Service have a budget adequate to control the spread plants. The budget would be supplemented by developing partnerships and using volunteers or other workforces. Pavolunteer groups would provide assistance and expertise in the management and treatment of invasive plants. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

1.2 Comment/ opinion/ 

position statement 

Let’s get this job done this year. Too much time & money is spent on this already & not much field work has been accomplished that I know of. 

The USDA Forest Service must coregulations, including NEPA before implemented. 

14.1 Outside the Scope I trust that your tool kit contains all proven treatment 

methods. In some cases, that may mean a crew/day armed with shovels & pruning shears. Some sites may best be treated with a controlled burn. While other sites may involve chemicals (1) applied via hand sprayer, quad sprayer or helicopter. 

Comment noted. 

18.2 Comment/ opinion/ 

position statement 

Successful weed control requires a combination or 

sequential use of several methods (integrated weed management – IWM). IWM techniques are the least harmful and the most beneficial methods for weed control. Patterns of weed spread indicate that many species have a lag phase following introduction before they spread explosively. Therefore, early detection and 

Comment noted. 

Appendix Z-31 
Final Environmental Impact Statement 

ISSUE: Implementing Invasive Plant Management 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

treatment before explosive spread will prevent many future problems and avoid the necessity of truly aggressive chemical management of an otherwise uncontrollable infestation 

20.2 Outside the scope It is also important to fund the early protection/rapid 

response mechanism in order to follow through with invasive management. 

USDA Forest Service funding is outhis EIS. Funding for invasive planthe Forest and Scenic Area would budget levels change, information concerning invasive plants improveplant infestations are reduced. Appdollars are augmented and would caugmented with partner and volun

20.3 Outside the scope In the Sandy River Basin, there should be 

coordination with The Nature Conservancy knotweed eradication effort. 

The Nature Conservancy has receand updates from the USDA Foresthis project. In addition, USDA Forbeen working with The Nature ConSandy River Basin, prioritizing and implementation of invasive plant trchallenge cost share program. The share program resulted in the deveyear agreement between the ForesThe Nature Conservancy to eradicspecies in the Sandy River Basin ito achieve basin-wide ecosystem robjectives. 

20.4 Outside the scope When uses such as powerline corridors contribute 

to invasives, their special use permits should include funding support for the control and treatment efforts. 

Project implementation is outside tEIS. 

24.2 Comment/ opinion/ 

position statement 

ODA is pleased to see an early detection and rapid response approach has been included in the DEIS and strongly supports this approach for invasive species management. 

Comment noted. 

Appendix Z-32 
Site-Specific 

ISSUE: Implementing Invasive Plant Management 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

25.2 Outside the scope The continued success of our removal efforts on the 

lower river depends on timely treatment of known knotweed sites with the Clackamas basin on the Mt. Hood NF and identified in the DEIS. We are very concerned that if treatment continues to be delayed, fragments from plants growing upstream of River Mill Dam could re-colonize areas already treated by us downstream. 

Comment noted. 

Appendix Z-33 
Final Environmental Impact Statement 

ISSUE: Aquatic Invasive Plants 

Invasive plants floating or submerged in water. 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

12.3 Outside the scope And in particular with the Soil and Water 

Conservation District, we are concerned about aquatic weeds. In addition to the purple loosestrife that we have had for a couple of years, various types of knotweed have taken hold in our area. There are a couple sites down in the Scenic Area down on Tanner and Maupin creeks that are not present on your maps, and I am hoping that those sites will be treated as well. 

Invasive plants floating or submergcurrently being addressed through actions in cooperation with the Staplants are not included in this analto comment 26.7 for more details.) plant species, including purple loosknotweed, are included in this EISOnly invasive plant infestations ideNovember 2004 inventory are anaspecific EIS. Additional sites and sloosestrife) can be considered for tEDRR as described in Sections 1.3

26.7 Outside the scope On page 1-27 of the DEIS it is noted that the 

document will not address invasive plants floating or submerged in water because aquatic invasives, “are currently being addressed through other federal actions in cooperation with the states.” Since aquatic invasives are an emerging issue on National Forest land and elsewhere, please provide more specific information about the efforts underway to address aquatic invasives. Should the efforts under development prove insufficient to address aquatic invasives; the FS will need to revisit this issue. 

Currently, invasive plants floating owater are not present on the ForesThese species are primarily a probwaterways (e.g., Columbia River), including U.S. Fish and Wildlife SeFisheries, and U.S. Army Corps of conducting in-water treatments of addition, the Invasive Species CouState of Oregon House Bill 2181 wminimize the effects of invasive spstate. If aquatic invasive become establisForest or Scenic Area, the USDA Fwould need to reassess the probleconduct additional NEPA to allow t

Appendix Z-34 
Site-Specific 

ISSUE: Aerial Herbicide Application or Prescribed Fire 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

3.5, 4.3, 6.7 Toxicology; 

Treatment methods 

If you must use them, it should be done by backpacks ONLY. Truck and aerial spraying are so harmful and the chances of accidental poisoning are great. What if someone is hiking or working in the area when the planes spray or the trucks fog? What about the animals? There is no way to control drift. 

PDC minimize adverse effects to penvironment. Aerial spraying is not spraying is not proposed. Drift from broadcast spraying woulthrough use of low pressure systemnozzle size. Licensed applicators (Invasive Plant ROD Standard 15 [2applicators are knowledgeable abomanagement. The Forest would noto spraying and inadvertent public minimized (compliance with InvasiStandard 23 [2005b]). All Invasive standards (2005b) are listed in AppThe proposed invasive plant treatmeffects to human health, including See Section 3.5 – Human Health a

13.3 Treatment methods The draft EIS specifies that use of prescribed fire is 

Outside the Scope of this proposal. Would that prevent the use of hand torches in the treatment of puncturevine? From personal experience in an ag setting, one of the most effective treatments for relatively small areas of puncturevine where seeds have already been produced is to burn the ground with a hand torch (not a drip torch) to "roast the nuts". Would that be allowed? 

Prescribed fire was not considered treatment method in the EIS and, tused. Prescribed fire could be usemethod in the future if additional Nconfirms its effectiveness and apptreating invasive plants. 

Appendix Z-35 
Final Environmental Impact Statement 

ADDITIONAL ISSUES 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

1.1 Comment/ opinion/ 

position statement 

I do not have any technical comments concerning the eradication of these "weeds", however the USDA Forest Service "Proposed Action" plan sounds very well thought out so go ahead with this proposal 

Comment noted. 

Appendix Z-36 
Site-Specific 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

1.3 Comment/ opinion/ 

position statement 

I wonder if there is any merit in studying invasive species? I have a small woodland in Clackamas County & have many varieties of these plants to deal with. They appear to be very hardy, resilient to disease, & provide habitat for small animals, I have discovered. I use crossbow to dispose of these plants but wonder sometimes if let alone these plants would eventually be shaded out by trees etc. It is a very challenging problem I admit so keep up your work & take time to smell the Roses. 

Comment noted. 

3.1, 4.1, 6.2 Comment/ opinion/ 

position statement 

I understand the need to control non-native species, but I strongly oppose any chemical means of doing so. 

Comment noted. 

3.2, 4.2, 6.3 Toxicology Chemical pesticides are detrimental to area flora 

and fauna as well as to the water systems and the people in the forests or surrounding areas. 

Scientific peer-reviewed risk assesprepared for the herbicides proposassessments indicate that the formfor use would not be detrimental to water, and/or flora and fauna. PDC complies with Invasive Plant ROD 20 (2005b) to minimize or eliminate impacts to non-target plants, animaThe Invasive Plant ROD standards in Appendix A, and the PDC are lisFor more information, see Section Health and Safety. 

3.4 Comment/ opinion/ 

position statement 

My guess is that you'll use the pesticides anyway, even though herbicides don't really work. (If they did, you wouldn't have to keep using them.) 

Effective measures for treating invproposed. Common Control Measusummarize proven effective controtreating invasive plants. These mefor treatments proposed in this procontrol measures are summarized All treatments would be followed bpassive restoration, and the restormonitored over time. The restoratio

Appendix Z-37 
Final Environmental Impact Statement 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

establishing native plant communitreduce and eliminate the need to utime. The restoration approach for area is listed in Appendix F. 

3.6, 4.4, 6.8 Toxicology Please use the precautionary principle when making 

this decision. 

Many layers of caution have been proposal to use herbicides. The laydiscussed in Section 3.3 and illustr

These layers include label requiremstate laws, EPA approval process, Assessment, Invasive Plant FEIS ((2005b), treatment methods, and Pproject is guided by PDC that ensuwould be done in a cautious mann

7.1 Comment/ opinion/ 

position statement 

On invasive plants I’m for the “proposed action” NO 

HERBICIDE

Comment noted. 

8.4 Comment/ opinion/ 

position statement 

PS Somethings got to be done about ScotBloom

[sic] 

Scotch broom (Cytisus scoparius) 

list of invasive plants proposed for EIS (see Table 2-3). Scotch broom and widespread within the Forest aespecially along highways and roaareas (e.g., clearcuts and quarriesNorthwest, Scotch broom is considmeaning an invasive non-native thand widespread. Thus, only a few contain Scotch broom (see AppendAdditional Scotch broom populatioand Scenic Area may be treated in present other invasive plant specieEIS are of higher priority because spread out of control rapidly (e.g., hawkweeds, butter and eggs, yello

Appendix Z-38 
Site-Specific 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

9.1 Comment/ opinion/ 

position statement 

I am in receipt of the draft proposals for invasive plant treatments around Mt. Hood Forest and the Columbia Gorge. I own a cabin near Government Camp on Forest Road 31. In reading the abstract, as well as the more detailed documents on the proposed treatments, alternative 3, the restricted herbicide use alternative seems most appropriate. That would be my preference. Thank you for soliciting our comments. 

Comment noted. 

10.1 Comment/ opinion/ 

position statement 

I am writing to provide comments on the Mt. Hood and Columbia River Gorge National Scenic Area’s DEIS. Empiric evidence strongly suggests that both the Mt. Hood National Forest and the CRGNSA are being threatened by invasive weeds from outside their boundaries, most notable garlic mustard, false brome, and knotweed. These, and other invasives are moving at an alarming rate and in my estimation, it is critical that you have all the tools possible at your disposal to militate against these threats. Therefore, I am in favor of Alternative 2, the proposed action. 

Comment noted. 

11.6 Early Detection / 

Rapid Response strategy 

Throughout the document ‘road right-of-ways’ are specifically included in the management plan. ‘Utility right-of-ways’ must be given the same management options due to the travel use by both utility company and general public (assuming Mt Hood NF has utility right-of-ways). 

The Mt. Hood National Forest has Administration (BPA) and Portland (PGE) utility corridors. Both BPA acorridors are included in the EIS. Aa description of the utility corridors #61-041, 61-093, 66-008, 66-016, 027). BPA powerlines are located within sites #22-01, 22-05, and 22-12. Additional portions of the utility cortreated in the future, if necessary, described in Sections 1.3, 2.1.3. a

Appendix Z-39 
Final Environmental Impact Statement 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

11.13 Early Detection / 

Rapid Response strategy 

The EDRR described throughout the document is unacceptable, too limiting to address unknown future events and out of context. In the true sense of EDRR, when action is taken quickly against a new invading plant (very small acreage treated), impact to the environment, no matter what control strategy is implemented, is negligible. When the impact is negligible, a new or amended section to this EIS should not be required. At most, an Environmental Assessment or Pesticide Use Permit should be quickly completed to allow for rapid action, even if that action requires the use of an herbicide not in this EIS. An EIS is only for when an environmental impact is anticipated. Time taken to secure resources for a survey, conduct the survey, compare control measures and site description to the current EIS, etc., will allow the plant to seed and spread. Immediate action is needed to keep the impact negligible. 

The EDRR establishes a series of help ensure that the adverse effectreating uninventoried invasive plawithin the scope of the effects discThe basis for these caps is the curidentified in the inventory complete2004. These caps are discussed in Appendix J and Table 2-9. If the efscope of this EIS, no additional NErequired. If the effects are beyond EIS, then additional NEPA would bThe Forest and Scenic Area would Forest Service Handbook 1909.15Section 18.2 requires the USDA Fo“prepare supplements to either draenvironmental impact statements imakes substantial changes in the that are relevant to environmental There are significant new circumstinformation relevant to environmenbearing on the Proposed Action or The EDRR discussions in Sections 2.1.4 have been modified based oreceived. 

12.1 Comment/ opinion/ 

position statement 

I would like to support the more aggressive weed treatment for these areas. Invasive weeds have become a terrible problem for our region and it is a big problem on the National Forest. So, I would urge you, even through I am an organic orchardist and do not use herbicides on my own place – I would urge the National Forest to use them. I believe that you guys can abide by the labels and use them properly. And I think there is a real need to get out there and to treat this invasion of noxious weeds. 

Comment noted. 

Appendix Z-40 
Site-Specific 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

13.1 Comment/ opinion/ 

position statement 

Let me say that the City supports efforts to control invasive plants on forest lands including treatments in municipal watersheds. And overall, I am impressed with the proposed action outlined in the draft EIS. 

Comment noted. 

15.1 Treatment methods 

& correction 

I am concerned about the announced proposal "to treat invasive infestations on 13,000 acres" of the described areas. To comment effectively, one would have to know just how the terms "invasive" and "infestations" are specifically defined. One would need to know exactly which "208 sites" are involved, and exactly what the "variety of treatments" are. The 

terms "eradicate" and "contain" and "control" are vague, and without specificity, they are meaningless in terms of an adequate public comment. There is no described application methodology, nor how the application is to be itself "curtailed". 

All of the cited terms in the commethe document (glossary and/or texdefinitions in the glossary were clatreatment methodology is describein Table 2-2. 

16.1 Comment/ opinion/ 

position statement 

We all must rely on folks such as yourself, in such positions of power to do the “correct” and “lifesustaining” things toward the future of ALL involved 

Comment noted. 

16.3 Comment/ opinion/ 

position statement 

Large-scale spraying of chemical pesticides and herbicides are not the answer. They may be faster but they are never better. 

Comment noted. 

17.1 Comment/ opinion/ 

position statement 

I feel the proposed action is much too conservative to both stop the spread of invasive weeds and restore public lands to a long-term healthy ecosystem condition. The proposed action, Alternative 2, should be expanded to include much more land and include funding strategies for long term management and monitoring of National Forest lands. 

Comment noted. 

Appendix Z-41 
Final Environmental Impact Statement 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

17.2 Comment/ opinion/ 

position statement 

I feel the DEIS and the proposed action are a good start, well planned and on the right track. I’m very confident there will be sufficient care taken with 

herbicide usage. The proposal is cost effective and appears to adequately protect humans and the natural environment. 

Comment noted. 

17.3 Comment/ opinion/ 

position statement 

The cost and environmental impact of no action is much too weakly assessed and described. The impacts to the natural environment of doing nothing need to be displayed in terms the general public can relate to and understand. I recommend using similar allegories and facts used to describe the effects of wildfire on human and natural communities. The science must touch the hearts of the public to get their concern and support. 

The No Action Alternative adequatcurrent invasive plant treatments oScenic Area (Section 2.1.2). The im“natural environment of doing nothin Section 1.2. 

17.8 Prevention Knapweed is rampant and needs aggressive 

treatment. Unknowingly, hikers, bikers and their dogs are spreading weed seeds. 

Comment noted. 

17.9 Laws and 

regulations 

The Columbia River Gorge Commission should be listed as a consulting partner. Their responsibilities in the Scenic Area should be coordinated with these weed control efforts. The Forest Service should give a special presentation to the Commission to consult with them and get their input. 

The USDA Forest Service presentColumbia River Gorge CommissioScenic Area Manager’s report in MUSDA Forest Service made a presCommission meeting on October 1Commission staff and each Commincluded in all public notifications. TCommission has been added as a in Chapter 4. 

18.1 Comment/ opinion/ 

position statement 

The Hood River Soil and Water Conservation District strongly supports Alternative 2, the “Proposed Action Alternative” as the most viable solution to the invasive weed problem in the Columbia Gorge and Mt. Hood National Forest. As indicated by the expanding invasive weed problem in these areas, the current management practice is not working to control the problem. Alternative 3, the 

Comment noted. 

Appendix Z-42 
Site-Specific 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

“Restricted Herbicide Use Alternative” is not a cost effective or realistic means to control the invasive weed problem. 

20.1 Comment/ opinion/ 

position statement 

We support manual and mechanical invasive plant treatments, and the use of cultural (goat) treatments. 

Comment noted. 

21.1 Comment/ opinion/ 

position statement 

The Department of the Interior has reviewed the Draft Environmental Impact Statement for the SiteSpecific Invasive Plant Treatments for Mt. Hood National Forest and Columbia River Gorge National Scenic Area in Oregon, Including Forest Plan Amendment #16, Clackamas, Hood River, Multnomah, and Wasco Counties, Oregon. The Department does not have any comments to offer. 

Comment noted. 

23.5 Early Detection / 

Rapid Response strategy 

The Forest Service may not exempt itself from the requirements of NEPA by substituting its “Emergency Detection and Rapid Response” plan for national law.  The Forest Service, claiming that “the NEPA process does not allow for rapid response,” (DEIS 2-33), has set up a method for permitting herbicide treatments to be used on all land allocated to the forest and any plant species found to be invasive, including those not listed among the nineteen in the DEIS. This is a disturbing prospect for the following reasons. First, it is estimated that the 2004 survey only looked at about 50% of those forest lands likely to be infested with invasives. (DEIS 1-12). Second, 

new populations of plants are likely to have developed in the 2 year interim since 2004. That leaves, disappointingly, thousands of acres of potentially infested land unaccounted for. “Combining the known infestations (13,000 acres), future estimate (13,000 acres), and expansion acres 

The EDRR is based on the premisof similar treatments are predictabprecise location or timing of the trecurrently unpredictable. The currenrepresentative of future infestationThe EDRR is not exempt from the NEPA. The requirements of NEPA analysis are incorporated into the Eknown infestations, treatment areaconducted in Chapter 3. The methconsistency analysis (See Figure 1the sites identified under the EDRR anticipated environmental effects fanalyzed in this EIS. If the anticipaeffects are not analyzed in this EISbe required (See Section 1.3). The EDRR is also summarized as implementation project design criteare incorporated in both action alteare not optional and are incorporat

analysis (See Section 2.2). 

Appendix Z-43 
Final Environmental Impact Statement 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

(4,000), the total landscape assessed to be treated is 30,000 acres on the Forest and Scenic Area over the next 15 years.” (DEIS 1-12). This means that over half of forest lands infested with invasive plants may be treated with herbicides without following the careful scientific analysis mandated by NEPA. It is possible for the Forest Service to both follow the law and implement creative solutions to the invasives problem – if it would look seriously at such plans of action as a Better Management Alternative, and refuse to immediately reject suggestions to “suspend...logging projects until a comprehensive EIS is completed that fully addresses the existing problem and ‘root causes’” of invasive plant colonization (DEIS 1-26). The invasive plant crisis becomes partly the Forest Service’s own making when it refuses to take a hard look at the true causes of the problem and allows constant reinfestation of forest lands. 

In part, the EDRR was developed necessary to complete new and/or can take six months to a year. In thinvasive plant population could expcosts could increase and the oppoeradicating/controlling the invasive could be lost. In addition to the methodology estathe USDA Forest Service Handboo18 addresses new information and circumstances. Section 18.1 statesinformation or changed circumstanenvironmental impacts of the Propto the attention of the responsible odecision has been made and prior approved program or project, the rmust review the information carefuimportance. If, after an interdiscipliconsideration of new information wthe overall program or project, the determines that a correction, suppan environmental document is not implementation should continue. Dof the interdisciplinary review in the program or project file. If the respodetermines that a correction, suppto an environmental document is nrelevant direction in Sections 18.2-consistency determination of the Emeet this regulation. 

Finally, the EDRR is consistent with presented in “Adaptive Management Specific Environmental Analysis WhCircumstances Are Uncertain” (BearThe EDRR discussions in Sections 1have been modified based on the coAlso, see response to Comment 23.Prevention). 

Appendix Z-44 
Site-Specific 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

23.13 Analysis Throughout the DEIS, the Forest Service asserts 

that the Proposed Action will result in improved water quality and protection of animal life, including human life. The DEIS, however, focuses on the long term goal and not the short term effects that may hamper those goals. 40 C.F.R. 1508.7 states that the agency must analyze not only the direct impacts of a proposed action, but also the indirect and cumulative impacts of “past, present, and reasonably foreseeable future actions, regardless of what agency or person undertakes such other actions.” While the Forest Service does include some analysis on the future effects, the DEIS gives too much credit to the long term goals of restored ecosystems, while downplaying the short term effects – such as destruction of desirable insect and animal species, or water contamination -- that may make the long term goals impossible. 

The EIS analyzes and discloses shdirect, indirect, and cumulative effeinvasive plant treatment methods. anticipated by a treatment methodthe impacts. The PDC were develoeliminate the negative effects of treEIS discloses that there is not suffinformation to make authoritative sanalysis and disclosures are throudocument. (Example: Section 3.11Slender Salamander) Water quality: The potential advers

action alternatives on dissolved oxtemperature, stream turbidity, peak water yield, and water chemistry aSection 3.9. For example, the advepotential to disturb or displace soilsmore vulnerable to erosion. The Ppotential adverse effect; as such thquality would be negligible. Wildlife: Section 3.11 in the EIS dis

adverse effects, including the loss the herbicides in this EIS are excrewithin 24 to 48 hours), and do not food chain. This reduces, but does potential for effects to wildlife specimplementing the Invasive Plant R(2005b), and PDC (Section 2.2), thshould be avoided. Human Health: As Section 3.5 disc

impacts to human health and safetmitigated. As such, there are no sheffects to human health. 

Appendix Z-45 
Final Environmental Impact Statement 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

23.16 Toxicology The risk assessments for surfactants, adjuvants, 

and inert ingredients are incomplete or unavailable. It is alarming that human beings will be exposing themselves and their environment to chemicals whose effects have never been thoroughly studied. Moreover, the public has no idea what amount of these supposedly innocuous chemicals is being applied to public lands. The EIS does not estimate the number of acres treated with surfactants, adjuvants or inert ingredients for each alternative because only limited use information is available on these chemicals. Additionally, various herbicides potentially could be used at any treatment area, so the adjuvant, surfactants and inert ingredients used may vary. Again, the Forest Service must not make the mistake treating the symptoms of a disease (invasive plant colonization) without eradicating the disease itself (less than perfect management practices). 

Section 3.3 discusses surfactants, ingredients. Section 3.3.3 discloseand unavailable information related chemicals. Risk assessments consingredients, additives, surfactants, inerts. Uncertainties are appropriatthrough PDC that limit the rate, typherbicide application sufficiently to scenarios that would cause concerSection 3.5 found that there were nchemicals analyzed (including actiadditives, surfactants, metabolites humans when invasive plant treatmcompleted in conjunction with requ7 provides information on the typicof the NPE surfactant. Each resource area in Chapter 3 aof surfactants. Also, see response (Issue: Prevention). 

23.23 Laws and 

regulations 

The Forest Service must comply with the Management Plan for the Columbia River Gorge National Scenic Area. Forest Service land in the NSA is predominantly designated Special Management Area (SMA) Forest or Open Space. In either case the Forest Service must follow the general resource protections guidelines for scenic, natural, cultural, and recreation resources. Revised Management Plan (RMP) at II-38 & II-58. The proposed action should be classified as a resource enhancement project and must comply with the guidelines for Resource Enhancement Projects. RMP at II-38 & II-58. 

Appendix C provides a determinatof the project with the ManagemenColumbia River Gorge National Screvised. It addresses the applicablprotection guidelines. The project has been determined tenhancement project. Appendix C applicable Resource EnhancemenThe project does not need to compManagement Area (SMA) Forest Pbecause it does not meet the glossforest practice. The project does nforest tree or shrub species; the prnonnative shrub and herbaceous s

Appendix Z-46 
Site-Specific 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

Because this would be a project “conducted on or pertaining to forest land and relating to forest ecosystem management” the Forest Service must also comply with the Forest Practice guidelines. RMP at II-38 & II-58; RMP Glossary at 9. For any site where noxious weed treatment is proposed the Forest Service must also consult the applicable SMA Open Space plan. If a treatment site lies within an area that does not have a completed SMA Open Space plan then all treatment must comply with the noxious weed treatment provisions in the RMP. RMP at II-59. 

Appendix C has been revised to adwith SMA Open Space Plans. 

24.1 Comment/ opinion/ 

position statement 

The Oregon Dept. of Agriculture (ODA) strongly supports the proposed action, that is less restrictive of the uses of herbicide and is more effective at controlling and reducing invasive weed infestations while promoting and restoring healthy native communities and their natural functions. 

Comment noted. 

24.4 Comment/opinion/ 

position statement 

Despite a considerable body of data on acute exposure effects from the proposed list of herbicides, it is important to recognize that the chronic and sublethal risks are not yet well characterized. Because of these unknown risks, we encourage use of non-chemical alternatives with known risks wherever feasible. DEQ believes that use of non-chemical control, such as biological and cultural control should be considered first for treating widely spread invasive species infestations. 

Comment noted. 

24.5 Early Detection / 

Rapid Response strategy 

A flow chart that describes the decision making process would be helpful for land managers to consider trade-offs. 

The decision key (Figure 1-4) for thexpanded to incorporate treatment future infestations. The decision ketreatment methods preference, site implementation, monitoring, and re

Appendix Z-47 
Final Environmental Impact Statement 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

26.4 Treatment methods Page 2-23 of the DEIS indicates that the proposed 

alternative would utilize an Integrated Weed Management (IWM) strategy. We encourage the FS to embrace the full suite of options available to treat invasive plants, including biological controls and prescribed fire. Where herbicides are used we recommend the FS review progress on an annual basis toward reducing reliance on herbicides. 

Section 2.1.3 addresses non-herbimethods that would be used in comherbicides. The effectiveness of thbe reviewed and re-treatment needyear (see Figure 1-4). Biological control agents have alreby the U.S. Department of AgricultPlant Health and Insect Service (ADepartment of Agriculture releases agents for all land ownerships acroOregon. Also, prescribed fire was not found effective treatment method for any plants currently found within the FoArea (see Table 2-3 and Appendix analysis does not consider prescritreatment method and prescribed fscope. Finally, Each invasive plant treatmeither actively or passively restored as defined in Appendix F. The restwould be important to ending the con herbicides in the future. 

26.8 Treatment methods Expand the discussion of site-specific prescriptions 

into a decision key. This would be helpful both in terms of understanding the document, and ensuring consistency in how future infestations are treated. This decision key should prioritize available control tools and clearly define the basis for moving from one tool to the next. Every control option has pros and cons that need to be carefully considered when deciding which control to use. 

See response to Comment 24.5 (IsComments on DEIS/Purpose & Ne

Appendix Z-48 
Site-Specific 

ISSUE: General Comments on DEIS/Purpose & Need 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

26.9 Early Detection / 

Rapid Response strategy 

Page 1-6 of the DEIS indicates that the FS has surveyed approximately 50% of the areas likely to be infested. The DEIS should give some discussion to how treatment sites in the remaining, uninventoried areas will be identified. Given limited 

resources, consideration should be given to how to best utilize existing tools (NRIS/Terra database) and existing monitoring programs in order to systematically identify new infestations. 

Identifying new infestations, utilizinmonitoring programs, and training identification would all be considerimplementation. See response to C(Issue: Monitoring and Maintenanc

Appendix Z-49 
Final Environmental Impact Statement 

ISSUE: Prevention 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

12.2 Prevention We have a lot powerlines that come through from 

Bonneville that allow an easy transfer of weed seeds. 

See response to Comment 11.6 (IsComments on DEIS/Purpose & Ne

18.4 Prevention The importance of proper cleaning of equipment 

before entering and leaving infested sites cannot be emphasized enough. Equipment should include everything from clothing and shoes to spray equipment and vehicles. 

PDC B.5. requires that “equipment operations for invasive plant treatmbe properly cleaned prior to enterinSystem land and upon leaving infeherbicide transportation and handlrequired to ensure spay equipmencleaned (see PDC B.2.). In addition, both the Forest and Scimplementing new prevention stanguidelines through the adoption of ROD (2005b), which took effect in (Appendix A). Also, both the Foreshave local prevention standards coAppendix D. Both sets of standardrequirements for cleaning of equip

22.2 Prevention The best way to eliminate the spread of invasive 

plants is to discontinue road building and other ground disturbing activities. 

See response to Comment 23.2 (Is

23.1 Prevention The DEIS is thorough and the examined alternatives 

have been well-researched. However, the Commenters are still concerned that the DEIS does not do enough to resolve the invasive plant problem. The project is not entirely in compliance with the applicable laws, and it should be revised or withdrawn entirely until those laws can be observed. Most importantly, the Forest Service must recognize that the true root of the invasive plant problem is improper forest management, and that even the most responsible use of herbicides to control invasive plant populations will only relieve the symptoms of the disease – not ultimately cure it. 

This project is in compliance with a

and regulations. See Section 1.4 – Direction and Section 3.15 – SpecDisclosures. See response to Comment 23.2 (Isfor discussion of forest manageme

Appendix Z-50 
Site-Specific 

ISSUE: Prevention 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

23.2 Prevention & laws 

and regulations 

This DEIS fails to abide by Section 1502.14 of NEPA, if it fails to consider a reasonable alternative. While it analyzes a Restricted Herbicide Use Alternative, it fails to analyze an alternative which includes better land management practices (Better Management Alternative) to avoid further invasive plant infestation. Such an alternative would meet the purpose and need of the project by describing herbicides that should be available for vegetation treatment on public lands, and, conditions and limitations that apply to herbicide use – including using those herbicides as a last resort, after management alternatives and non-herbicide alternatives have failed. In failing to adequately consider prevention as an alternative, the Forest Service violates NEPA, which requires that the Forest Service meet the requirement for high quality scientific analysis when producing an EIS. 40 C.F.R. § 1502.22. Without addressing these causes of the introduction of invasives – in fact refusing to take a “hard look” at 

these causes using such scientific analysis – the Forest Service cannot hope to meet a stated purpose of the project: “to eradicate, contain and control invasive plant infestations.” In restricting the range of alternatives evaluated and considered, the Forest Service violates the very purpose of NEPA’s alternative analysis requirement, which is to foster informed decision-making and full public involvement. 42 U.S.C. §§ 4331, 4332(2)(E); 40 C.F.R. § 1508.9(b). The public should be made aware if there are safer, more effective, or more creative alternative management plans in existence from which to choose. Thus the existence of a viable but unexamined alternative can ultimately 

An alternative emphasizing preven“better land management practicesin the Invasive Plant FEIS (2005a) This site-specific EIS tiers to thesestated in Section 1.4. The USDA Forest Service Handbo22.31 states: “Agencies are encouenvironmental impact statements trepetitive discussions of the same on the actual issues ripe for decisioenvironmental review (§1508.28). environmental impact statement ha(such as a program or policy statemsubsequent statement or environmis then prepared on an action incluentire program or policy (such as a action) the subsequent statement oassessment need only summarize discussed in the broader statemendiscussions from the broader stateand shall concentrate on the issuesubsequent action. The subsequenstate where the earlier document is CFR 1502.20).” As a subsequent action, this site-sEIS does not need to repeat analythe Invasive Plant FEIS (2005a) anbetween prevention and treatmentwould have increased emphasis oconditions related to land uses and National Forest System lands that invasive plant introduction, establisHerbicide use was a “tool of last realternative. Alternative B in the Inv(2005a) represents the “Better MaAlternative” discussed in this commPrevention practices on the Forest would follow the prevention standa

Appendix Z-51 
Final Environmental Impact Statement 

ISSUE: Prevention 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

Appendix Z-52 

render an EIS inadequate. Alaska Wilderness Recreation and Tourism v. Morrison, 67 F.3d 723, 729 (9th Cir. 1995). 

adopted in the Invasive Plant ROD includes guidance on preventing thspread of invasive plants through lactivities. For example, prevention would be considered in all land use per Standard 1. These standards aAppendix A. Further, prevention alone does not and underlying need for action, as Section 2.5.1. Part of the stated pueradicate, contain and control invainfestations,” as stated in the commstrategies of eradicate, contain and in Section 1.2 include treating a knsome way. Prevention is defined aameliorate conditions that establisinvasive plants.” Prevention alone, incorporate the underlying need fodefined by the purpose and need fAlthough prevention does not meeneed, it is an important component management and integral to impletreatments. The Forest and Scenic prevention standards, in addition to ROD (2005b) standards, that are imanagement activities on both uniare included in Appendix D. See response to Comment 23.7 (Isfor discussion of range of alternativ

23.3 Prevention In contrast to a Better Management Alternative, the 

Proposed Action in the DEIS merely describes the disembodied use of herbicides for eradication and control. This action alternative is given a detailed analysis which seems much like a justification for its choice – especially when considering that the management plans of Alternative C, Reduced Herbicide Use Alternative, are given far less 

Alternative 3 – Restricted Herbicidmodifies the Proposed Action to reassociated with herbicides (See Semodification of the Proposed Actioentirely new alternative, the analysuses the analysis completed for thas a starting point. 
Site-Specific 

ISSUE: Prevention 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

attention. In fact, rather than analyzing what can be accomplished by Alternative C -- the less herbicideintensive Action and one more comparable to a Better Management Alternative – the Forest Service focuses more on what the Action does not do. For example, the Forest Service repeatedly concludes that such a plan would not provide effective control of invasive plants over as great an acreage as Alternative B. It claims that manual and mechanical means of control have been and will be ineffective. However, there is no data to conclusively show that herbicides are the perfect solution. Alternative C offers the positive consequences of less potential for harm to human beings, flora, and fauna. Yet the Forest Service glosses over this fact in its abstract, stating that “all of the action alternatives protect human health and the environment,” and makes similar statements throughout the body of the DEIS. 

Alternative 3 does offer the positive less potential for harm to human bfauna. These methods, however, aThe effectiveness of manual, mechmethods is discussed in the No Acanalysis (Section 2.1.2) and SectioTreatment Effectives. Both the positive and negative impare analyzed and discussed in eacareas in Chapter 3 of the EIS. 

23.4 Prevention The Forest Service fails to analyze the active, 

positive control of invasive species that has been and can be accomplished with, 1) prevention of the conditions that favor the introduction, establishment, and/or spread of invasive species, and, 2) passive treatments in conjunction with, or sometimes obviating the need for, 3) use of herbicides. In order to effectively analyze a less herbicide intensive alternative, the Forest Service needs to examine what has happened to invasive species and lands threatened with invasive species throughout the seventeen western states and elsewhere in the 

world when, a) prevention-focused management, invasive species treatment and restoration of ecosystems have been practiced together, and, comparatively, b) where herbicide treatments have been employed without altering conditions that have favored 

All alternatives analyze an integratmanagement (IWM) approach, whonly one proposed tool for treating IWM is a process by which one secombination of management technmechanical, and herbicide for examwould control a particular invasive infestation efficiently and effectiveladverse impacts to non-target orgaspecies-specific, site-specific and dpractical with minimal risk. See responses to Comment 23.2 aPrevention) for more information. 

Appendix Z-53 
Final Environmental Impact Statement 

ISSUE: Prevention 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

invasive species. When preventive actions and restorative treatments are part of the judicious use of herbicides, the latter will have far more lasting, positive results (i.e. efficacy) than spraying invasive species while leaving intact the activities that fostered the introduction, establishment and spread of invasive species. Yet this DEIS insists on disconnecting herbicide use from any other management on Forest Service lands and then purports to estimate the benefits of herbicide spraying. The benefits/costs of herbicide use alone versus herbicide use limited and conditioned by priorities for prevention and passive and/or active restoration must be analyzed in the DEIS. 

23.6 Laws and 

regulations 

The DEIS Fails to Adequately Protect Plant and Soil Resources as Required by the National Environmental Policy Act, the National Forest Management Act, and the Endangered Species Act. 1. The DEIS alternatives fail to best protect plant and soil resources because they do not address the underlying cause of the spread of invasive plants. Ostensibly, the goal of the Forest Service is to effectively control the spread of invasive plants across public lands. However, the DEIS fails to consider all reasonable alternatives which would effectively provide this control. Specifically, it rejects alternatives which equally emphasize both the control of the symptoms of the spread of invasive plants (meaning, the eradication of invasive plant populations and the restoration of damaged plant communities) and the initial prevention of such invasions. 

See response to Comment 23.2 an(Issue: Prevention). 

Appendix Z-54 
Site-Specific 

ISSUE: Prevention 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

23.7 Laws and 

regulations 

Disregarding viable alternatives that might more effectively protect plants and soils is inconsistent with NEPA’s requirement that a range of alternatives be thoroughly considered. The Forest Service seems enthusiastic about experimenting with new chemical treatments of invasive plants, to the exclusion of other alternatives. It states that “although the first preference is non-herbicide, non-ground disturbing methods, this EIS focuses analysis on herbicide treatments.” (DEIS 1-11). By claiming other treatment methods are/were ineffective, the Forest Service becomes automatically biased toward the Proposed Action – one that is more dangerous to plant and soil health and would expand existing herbicide use than less favored alternatives. `The Forest Service must remember that in determining the scope of alternatives to be considered, the Council on Environmental Quality (CEQ) advises that the emphasis [should be] on what is ‘reasonable’ rather than on whether the proponent or applicant likes or is itself capable of carrying out a particular alternative. Reasonable alternatives include those that are practical or feasible from the technical and economic standpoint and using common sense, rather than simply desirable from the standpoint of the applicant. 

The EIS considered 7 alternatives; included prevention only and no healternatives were dropped from furSection 2.5) because neither alternpurpose and need for this project (Additionally, the EIS considered thAlterative which analyzes the impainvasive plants with limited herbicidThe range of alternatives consider

• No Action Alternative (limit• Proposed Action; • Restricted Herbicide Use A• Prevention Only; • No Herbicide Use; • No Amendment to the Mt. • Maximize Cost Efficiency; • Maximize Worker Jobs. 

The maximize cost efficiency alternconsidered, but dropped from furthessentially the same as the ProposSection 2.5). All other alternatives of herbicide use less than consideAction. See responses to Comments 23.2 information (Issue: Prevention). 

Appendix Z-55 
Final Environmental Impact Statement 

ISSUE: Prevention 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

24.3 Prevention DEQ encourages the USFS to consider adopting 

preventative measures to avoid infestation of new invasive species population on national forests, such as limiting OHV uses and closing or restricting access to non-essential roads where needed. 

See response to Comment 23.2 (IsThe Forest will begin an OHV planwill designated specific OHV areas areas to OHV use, in fiscal year 20Area will begin a similar effort in fisplanning processes consider the imvariety of natural resource areas, iplants. 

26.6 Prevention An effective invasive plant management program 

must include both active control/eradication of existing populations and prevention of new populations. There are important vectors for spread of invasives that are not addressed in existing standards and guidelines. Specifically, the FS should consider adopting a site-specific standard prohibiting cross-country use of off-highway vehicles and limiting the use of OHVs to designated routes and in designated areas, and closing, decommissioning, or seasonally restricting access to non-essential roads that are high-risk vectors for spread of invasive plants. 

See response to Comment 18.4 an(Issue: Prevention) 

Appendix Z-56 
Site-Specific 

ISSUE: Additional Technical Issues 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

5.1 Outside the scope I believe that Japanese Knotweed should be rated 

as "T" on the noxious weed category list. It grows on my lot nearly 11' tall within the span of 5 to 6 weeks, and is taking over the entire lot between my cabin on Rd 12 Lot 79 and Still Creek. I have enclosed photos taken last year of a 3 week old growth. I would like to see the forest service develop a plan to irradiate this menace asap. 

The Oregon Department of Agricudetermines ratings for invasive plastate. The ODA lists Japanese knodesignated weed (http://oregon.gov/ODA/PLANT/WE

olicy.pdf

Invasive knotweeds (e.g., JapanesHimalayan) are considered high-prtreated within the Forest and Scentheir ability to rapidly spread, drastplant communities, and negatively functioning ecosystems. The EIS ppresently known and future knotwethe herbicide, aquatic glyphosate. has been demonstrated to be the mmethod for treating knotweeds. 

11.2 Comment/ opinion/ 

position statement 

I do not support the No Action alternative. Current herbicide use of only glyphosate, triclopyr, picloram and in some cases dicamba is unacceptable. Only two modes of action are represented and all herbicides are old chemistry requiring a high dose of active ingredient to control the weeds listed in the DEIS. 

Comment noted. 

11.7 Correction Pg1-4 

Within the weed list, I suggest changing Japanese knotweed (Polygonum cuspidatum) to Knotweed species (Polygonum spp). Several species of Polygonum are found in Oregon and they are rumored to have cross bread. All are extremely invasive and difficult to control. I suggest the change to avoid restrictions on control in case a knotweed plant has been miss identified as cuspidatum, when really Bohemian or a hybrid. 

Alternatives 2 and 3 allow treatmespecies through either the identifieor the EDRR. The correction has bthroughout the document to preven

Appendix Z-57 
Final Environmental Impact Statement 

ISSUE: Additional Technical Issues 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

11.8 Correction Pg1-11 

#2, first bullet. The last herbicide choice indicated appears to be a misspelling. This should be “aquatic imazapyr”. There is no aquatic form of imazapic. This is correct on pg2-23. 

The correction has been made. 

11.9 Laws and 

regulations 

Pg1-11 #2, third bullet. Rates of triclopyr and picloram can be greatly decreased, possible reduction by half, with the addition of OVERDRIVE® herbicide. OVERDRIVE is a combination of dicamba plus diflufenzopyr. Addition of 2oz to 6oz per acre of OVERDRIVE can reduce triclopyr and picloram rates by half, resulting in overall decrease in active ingredient. In addition, restriction to the amine form of triclopyr reduces control for some species, addition of OVERDRIVE to triclopyr can increase that control to equal or improved over triclopyr amine alone. 

The Invasive Plant ROD (2005b) amanagement direction to all NationResource management Plans in thRegion (Region Six). Standard 16 herbicide formulations containing ofollowing 10 active ingredients: chlclopyralid, glyphosate, imazapic, immetsulfuron methyl, picloram, sethsulfometuron methyl, and triclopyr.EIS tiers to these standards. As suactive ingredients listed in this stanfor use on the National Forest Sysdicamba and diflufenzopyr are not 

11.10 Botany Pg 2-20 Mechanical Methods 

In addition to mowing, etc. being used with herbicides to prevent root sprouting or mowing being used after herbicides to aid in further control, mowing is effective on species such as reed canarygrass or Japanese knotweed to remove old growth that could intercept herbicide spray. Mowing will also stimulate root sprouts that help deplete root 

reserves prior to an herbicide application. Allow the plants to re-grow to at least 2/3 their original height and spray the new shoots for a more effective treatment. 

The comment is correct: mowing is vegetative materials and to promotin order to decrease the amount of application needed and to increase effectiveness. This change has be2. 

Appendix Z-58 
Site-Specific 

ISSUE: Additional Technical Issues 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

11.11 Treatment methods Pg2-22 Herbicide Methods, Hand/Selective (e), 

Pg3-4 Japanese knotweed, Pg3-28 Spot herbicide treatment and broadcast herbicide treatment should be considered prior to stem injection treatments. Although stem injection has been promoted for control of knotweed with glyphosate and triclopyr, recent studies have shown the per ace rate applied typically far exceeds the EPA label rate of the herbicide. Stem injection should only be considered if stem density is low and total product used does not exceed EPA labels rates. Under no circumstance should imazapyr be applied by stem injection. Foliar treatment, spot or broadcast, of imazapyr can achieve 95% control. The following table was presented at the Western Society of Weed Science, March, 2006. Note the total Herbicide used per acre. 

Treatments 

Average 

# Stems 

/100 sq 

ft plot 

Time to 

Treat 

100 sq 

ft 

Herbicid

e used 

per Acre 

% 

Control 

3 qts of 

Habitat 

533 1.9 sec 3 qts 95 

1% Habitat 

Solution 

700 27.8 sec 25.7 oz 95 

Rodeo 

5 mls/stem 

617 30 min 

to 2 hrs 

354.9 

gal 

30 to 90 

Proposed treatment for knotweed shand/selective (stem injection) and a backpack sprayer. The potential glyphosate, triclopyr, and imazapyof potential treatments allows any that you discussed. The treatments based on the size of the infestation conditions. All proposed treatments are listed all potential herbicides are listed in 

Appendix Z-59 
Final Environmental Impact Statement 

ISSUE: Additional Technical Issues 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

11.12 Treatment methods Pg2-30 Imazapyr General Uses/Known to be 

effective on: For each herbicide the list of weeds controlled is near accurate, I would strongly recommend adding knotweed to Imazapyr. 

Table 2-6: Active ingredients and cherbicide names is meant to be illuinclusive. Imazapyr is proposed as for all knotweed sites and has bee6. See Appendix F for a summary treatments for each species, and Aof herbicides proposed at each tre

11.14 Treatment methods Pg2-35 

Third Priority of Treatment. I am concerned about the treatment priority list as related to roadsides. Goat grazing listed as number one is not safe for roadsides. Mechanical should be unacceptable for roadsides, since this is a main mechanism of weed spread. Herbicide use, as immediate control, should be a first consideration for roadside weed treatment. 

The treatments in Table 2-8 are posite-specific conditions. Thus, the cand herbicide treatment may be thtable has been changed to reflect tpreference discussed in Section 1.

11.15 Botany Pg2-41 & 42 

All the assumptions made are very realistic. I am only concerned that seed life was not considered. After the 3 to 5 years to rid the area of established plants, long-term plans should include monitoring the area for the expected documented or observed seed life of the species. Seedling or first year plants can often be hand pulled. 

Seed life/seed banks must be constreating invasive plants. Seed longvery long for some species: 5 to 10 hawkweed, St. Johnswort, and as years for Scotch broom. See Sectiinformation. Monitoring would be required to enof desired vegetation as indicated Section ”Site Restoration Strategy”monitoring are incorporated into boalternatives projects; therefore, bofor the life of the project (10 to 15 y

11.16 Toxicology Pg3-10, 3.3.1. Herbicide Risk Assessment, 3rd 

paragraph This section is misleading, stating that metabolites and inert ingredients are not as extensively tested as active ingredients. Although they are not as extensively tested, they are still extensively tested. The reduced toxicology focus can be attributed to 

The statement is intended to reflecmetabolite and inert ingredients artested independently from active inThe risk assessments reviewed inethose that may not be revealed to assessments considered additivesmetabolites and inert ingredients, a

Appendix Z-60 
Site-Specific 

ISSUE: Additional Technical Issues 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

the much lesser degree they occur or are introduced in to the environment. A great deal of the cost to register a herbicide is identifying, isolating, and testing the metabolites. All inert ingredients are revealed to EPA and categorized by toxicology properties to be revealed to the pubic in 5 categories. Actual inerts are not revealed to the public because they are proprietary information. Few impurities are in modern manufacturer products due to quality control. Generic products may have a higher level of impurities. 

use of surfactants shown to have peffects. Information regarding thesdiscussed in Section 3.3.2. 

13.2 Correction The draft EIS is pretty clear that precautions are to 

be taken to prevent application of herbicides to water, either directly or indirectly. Yet Table 2-10 indicates that an existing Standard and Guideline related to "Water (FW-076)", which I believe states the same objective, is proposed to be amended as part of this action. The language in that table gives the impression that "potentially detrimental materials" could be allowed to enter waters under the proposed standards. Is there more to the existing Standard and Guideline that requires its amendment? If so, perhaps there is a better way to amend the statement in Table 2-10 to avoid this misinterpretation. 

The wording of the Forest Plan amchanged to read as follows. 

“Water (FW-076b): Potentially dassociated with invasive plant trmanagement activities (e.g. pes

and road surface treatments) sh

from entering water or other aretreatment, according to standarNorthwest Region: Preventing aInvasive Plants Record of Decis

The Invasive Plant ROD (2005b) Saddresses water quality and aquatAppendix A). While the amount of herbicides anexpected to reach water area expeextremely low, the USDA Forest Sconclude with certainty that the levpotentially reaching streams would the amount is expected to be “biolomeaningless,” as explained in SecQuality and 3.10 – Aquatic Organis

Appendix Z-61 
Final Environmental Impact Statement 

ISSUE: Additional Technical Issues 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

16.2 Treatment methods For these invasive plants use goats or the like. I’m 

talking about natural means of controlling or ridding our problems. Not using chemicals like pesticides/herbicides that only destroy our environmental habitats. If 2-300 of these pygmy goats were fenced around these proposed areas that need attention (and I’ve seen this done in places to eat the invasive English ivy like in Lake Oswego), the goats would be well fed, the problem gets solved in a natural way, the environment gets re-fertilized at the same time. 

Goats can be very effective contromany circumstances, have minimagrazing is proposed at two sites (#and may be considered at other situnder the EDRR. 

17.4 Treatment methods Weed eradication treatments must be repeated over 

many years 

The maintenance schedule would based on the invasive plant specieconditions, identified treatment stratreatment method. Several invasivprescription assumptions were mamaintenance for analysis purposesassumptions are outlined in Sectioassumptions include treatment for years, and retreatment up to three 

17.5 Restoration & 

Monitoring 

Follow up eradication treatments with native grasses and herbaceous plant seedings and plantings. These plantings should be repeated over multiple years. Monitoring should be planned to go on forever. Weeds never sleep. 

In many cases additional plantings be required to get the desired outcwould be required to ensure estabvegetation as indicated in Chapter Restoration Strategy”. Restoration incorporated into both action alterntherefore, both would continue for project (10 to 15 years). 

Appendix Z-62 
Site-Specific 

ISSUE: Additional Technical Issues 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

19.1 Comment/ opinion/ 

position statement 

My comments relate mainly to the fact that a lot of this did not have to happen. I have noted scotch broom just starting to become established at sites in F.S. Region 6 and have called this to the attention of Forest Service employees in the districts involved. However, I found that they did not respond and I suspect the infestations grew from a few plants to a real problem. In the future, lets hit these problems before they turn into major disasters. 

Comment noted. 

19.2 Treatment areas I note there are now scotch broom plants along the 

shoulder of highway 26 east of Rhododendron. 

Three treatment areas are located corridor (sites #69-001, 69-016, an2-1 and 2-6 are maps illustrating tralong the Highway 26 corridor, and on the individual treatment areas is Appendix F. If the sites of concern are not incluand species (e.g., purple loosestrifusing the EDRR as described in Sand 2.1.4. 

23.15 Laws and 

regulations 

The Forest Service must comply with the applicable requirements for any invasive plant treatment within the National Scenic Area. Specifically, the Forest Service must determine the exact location of the water resource boundary and respect water resource buffer zones for any project location that may affect streams, ponds, lakes, wetlands, or other riparian areas in the Special Management Areas. RMP I-83–86. 

The project is designed to meet the boundary guidelines. The PDC of Streatment buffers and restrictions bherbicide and treatment method prTherefore, the exact location of wado not need to be determined, as tenter the Management Plan water no-practicable alternatives test and mitigation plan have been completC). 

Appendix Z-63 
Final Environmental Impact Statement 

ISSUE: Additional Technical Issues 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

25.1 Comment/opinion/ 

position statement 

Strategies of eradication that have the least impact on the environment are preferred. However, the only known successful control of Japanese Knotweed at this time requires herbicides. Biological control agents are not yet available, and digging, cutting, and covering are ineffective. A combination of stem injection and foliar application results in approximately 80% reduction of stems in one season. Immediate action is needed to address this invasive plant 

Comment noted. 

Appendix Z-64 
Site-Specific 

ISSUE: Monitoring and Maintenance 

Comment 

Number 

Comment Summary/Topic Comment Text Response to Comment 

17.6 Monitoring Create volunteer organizations to help with this 

effort, especially the long term monitoring 

The USDA Forest Service would emethods of implementation. Specifstrategies are outside the scope of response to Comment 18.3 (IssueMaintenance). The USDA Forest Service has actiinvolved in various land managemmonitoring activities. Such opportucontinue to be pursued where voluinterest. 

18.3 Monitoring & 

treatment methods 

One concern regarding the success of Alternative 2 as outlined in the DEIS is the minimal elucidation of details regarding a monitoring and maintenance schedule. While the DEIS does indicate that followup will be performed for 5-15 years, no detail is given as to the frequency of treatment or monitoring. All invasive weed eradication takes years of followup maintenance to be successful. A commitment to the follow-up treatment is just an important as the initial action. 

More information was added to the (Figure 1-4) and monitoring framewThe maintenance schedule would based on the invasive plant specieconditions, identified treatment stratreatment method. Several invasivprescription assumptions were mamaintenance for analysis purposesassumptions are outlined in Sectioassumptions include treatment for years, and retreatment up to three 

26.5 Analysis & 

monitoring 

We appreciate these cumulative impacts findings (page 3-6, DEIS) being included in the DEIS, and encourage the FS to use this knowledge to inform the cumulative impacts assessment. The FS should also look across the landscape and identify what assumptions will be used with respect to adjacent non-Forest/Scenic Area lands, as well as the mechanisms for cooperating with other land owners to disclose the sum of individual effects of all projects on the local environment. Cumulative effects analysis should also consider appropriate mitigation strategies to minimize adverse and to enhance beneficial cumulative 

Section 3.4 – Basis for Cumulative the information used to inform the analysis. Estimates of herbicide usas well as orchards in Hood River the analysis. The cumulative effectthat adjacent lands are effectively cooperation with this project. This updated to provide additional inforFunding and implementation methmechanisms for cooperation, for inmanagement on the Forest and Scoutside the scope of this documenimplementation would vary each ye

Appendix Z-65 
Final Environmental Impact Statement 

ISSUE: Monitoring and Maintenance 

Comment Comment 

Number Summary/Topic Comment Text Response to Comment 

effects. Monitoring and evaluation of the mitigation strategies’ effectiveness would also be an important component of the proposed action, especially if data obtained from such monitoring can be used to modify land management and to promote cost effectiveness in the expenditure of mitigation resources. 

change, information and knowledginvasive plants improves, and invainfestations are reduced. The decision key (Figure 1-4) and framework (Section 2.3) discuss howould be incorporated and used in 

Appendix Z-66 
Appendix Z-67 

Z.4. Agency Comments 

This section contains comment letters received from governmental agencies (federal, state, and local). The entire 

letter is included in this section per FSH 24.1.3. The responses to the substantive comments identified in these 

letters are contained in Section Z.3 of this Appendix. 

Letter 13: City of The Dalles 

06/19/2006 01:12 PM 

"Dave Anderson" <danderson@netcnct.net> 

To "Jennie O'Connor" <jmoconnor@fs.fed.us> 

cc 

Subject Invasive Plant Treatment draft EIS 

JennieAs Water Quality Manager, and Watershed Manager, for City of The Dalles, I am writing to ask a couple 

quick questions regarding the draft EIS currently out for public comment. I'm also trying to decide if I 

should be planning to go to Sandy this evening for the public meeting. 

First, before my questions, let me say that the City supports efforts to control invasive plants on forest 

lands including treatments in municipal watersheds. And overall, I am impressed with the proposed action 

outlined in the draft EIS. So, with that, here are my questions. 

1. The draft EIS is pretty clear that precautions are to be taken to prevent application of herbicides to 

water, either directly or indirectly. Yet Table 2-10 indicates that an existing Standard and Guideline 

related to "Water (FW-076)", which I believe states the same objective, is proposed to be amended as part 

of this action. The language in that table gives the impression that "potentially detrimental materials" 

could be allowed to enter waters under the proposed standards. Is there more to the existing Standard and 

Guideline that requires its amendment? If so, perhaps there is a better way to amend the statement in 

Table 2-10 to avoid this misinterpretation. 

2. The draft EIS specifies that use of prescribed fire is outside the scope of this proposal. Would that 

prevent the use of hand torches in the treatment of puncturevine? From personal experience in an ag 

setting, one of the most effective treatments for relatively small areas of puncturevine where seeds have 

already been produced is to burn the ground with a hand torch (not a drip torch) to "roast the nuts". Would 

that be allowed? 

Thanks for any clarifications that you can provide. 

Dave Anderson 

Water Quality Manager 

City of The Dalles 
Appendix Z-68 

Letter 18: Hood River Soil and Water Conservation District 
Appendix Z-69 

Letter 21: U.S. Department of Interior, Office of Environmental Policy and Compliance 

United States Department of the Interior 

OFFICE OF THE SECRETARY 

Office of Environmental Policy and Compliance 

500 NE Multnomah Street, Suite 356 

Portland, Oregon 97232-2036 

9043.1 

IN REPLY REFER TO

ER06/545 

 July 6, 2006 

Jennie O’Connor 

Mt. Hood National Forest 

16400 Champion Way 

Sandy, OR 97055 

Dear Ms. O’Connor: 

The Department of the Interior has reviewed the Draft Environmental Impact Statement for the SiteSpecific Invasive Plant Treatments for Mt. Hood National Forest and Columbia River Gorge National 

Scenic Area in Oregon, Including Forest Plan Amendment #16, Clackamas, Hood River, Multnomah, and 

Wasco Counties, Oregon. The Department does not have any comments to offer. 

We appreciate the opportunity to comment. 

 Sincerely, 

 

 Preston A. Sleeger 

 Regional Environmental Officer 
Appendix Z-70 

Letter 24: Oregon Department of Agriculture 
Letter 26: U.S. Environmental Protection Agency, Region 10 

Appendix Z-71 
 
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and 

activities on the basis of race, color, national origin, age, disability, and where applicable, sex, 

marital status, familial status, parental status, religion, sexual orientation, genetic information, 

political beliefs, reprisal, or because all or part of an individual’s income is derived from any 

public assistance program. (Not all prohibited bases apply to all programs.) Persons with 

disabilities who require alternative means for communication of program information (Braille, 

large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice 

and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, 

1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 

(voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.