United States 

Department of Agriculture

Forest Service

Animal and Plant Health

Inspection Service

Newtown Square, PA

NA–MB–01–13

December 2012

Gypsy Moth Management 

in the United States:

a cooperative approach

Record of Decision

Handy reference to alternatives

Alternatives:

•	 Alternative 1—No action (no change from the 1996 Record of Decision)

•	 Alternative 2—Add tebufenozide to the approved treatments

•	 Alternative 3—Add tebufenozide to the approved treatments and add future treatments through the 

application of the protocol

The complete final supplemental environmental impact statement “Gypsy Moth Management in the United States; 

a cooperative approach” consists of four volumes:

Volume I—Summary 

Volume II—Chapters 1-8; Appendixes A-E

Volume III—Appendixes F-I (risk assessments)

Volume IV—Appendixes J-M (risk assessments and risk comparison)

The record of decision is a separate document published and available at least 30 days after the notice of 

availability for the final supplemental environmental impact statement is published in the Federal Register (40 

CFR Part 1506.10).

All four volumes of the Final Supplemental EIS and this Record of Decision can be viewed and downloaded at 

http://na.fs.fed.us/pubs/detail.cfm?id=5251.
Contents

Purpose...........................................................................................................1

Statutory Authorities.......................................................................................1

The Decision...................................................................................................1

Alternatives....................................................................................................2

Environmentally Preferable Alternative........................................................2

Rationale for the Decision.............................................................................2

Meets USDA Goal............................................................................3

Responds to Issues.............................................................................3

Human Health......................................................................4

Nontarget Organisms............................................................4

Forest Condition...................................................................5

Provides Management Flexibility.....................................................5

Cumulative Effects.........................................................................................6

Mitigating Measures.......................................................................................7 

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

Monitoring.....................................................................................................8

Public Involvement........................................................................................9

Implementation............................................................................................10

Effective Date..............................................................................................10

Responsible Officials....................................................................................10

Attachment...................................................................................................11

Gypsy Moth Management 

in the United States:

a cooperative approach

Record of Decision


Supplemental Environmental Impact Statement

Record of Decision - Page 1

Purpose

This Record of Decision (ROD) documents the 

programmatic decision that will guide the U.S. 

Department of Agriculture’s (USDA) National 

Gypsy Moth Management Program and describes the 

rationale for that decision. Our decision is based upon 

consideration of the three alternatives analyzed in the 

final supplemental environmental impact statement 

(SEIS), “Gypsy Moth Management in the United 

States: a cooperative approach,” dated August 2012.

This decision does not change current direction for the 

USDA National Gypsy Moth Management Program, 

but adds to it. Since 1996, the USDA has carried 

out its gypsy moth management responsibilities 

through the Forest Service and the Animal and Plant 

Health Inspection Service (APHIS) and pursuant to a 

programmatic decision based on a 1995 environmental 

impact statement (EIS) for gypsy moth management. 

Changes in gypsy moth status, management techniques, 

and accepted methodology for preparing human health 

and ecological risk assessments have occurred since 

1995. In addition, updated and new information on 

gypsy moth and the approved treatments indicated that 

a supplement to the 1995 gypsy moth EIS was needed.

The USDA National Gypsy Moth Management 

Program was developed to guide how the Forest 

Service and APHIS will assist in funding and carrying 

out projects to reduce damage caused by gypsy moth 

outbreaks, eliminate isolated infestations of the insect, 

and slow the spread of gypsy moth along the leading 

edge of the infested area. The gypsy moth (Lymantria 

dispar [L.]) is a nonnative insect that alters ecosystems, 

destroys the beauty of woodlands, and disrupts people’s 

lives and livelihoods by feeding on the foliage of trees, 

shrubs, and other plants. Although European and Asian 

strains exist, only the European strain is known to be in 

the United States at this writing. The European gypsy 

moth, brought to the United States and accidentally 

released in eastern Massachusetts around 1869, is now 

established in all or portions of 19 northeastern, midAtlantic, and Midwestern states, and the District of 

Columbia. It continues to spread into uninfested areas. 

The Asian strain occasionally has been found in the 

United States, and has been eliminated whenever it has 

been found.

Statutory Authorities

The Forest Service and APHIS conduct pest 

management activities under broad discretionary 

authority given by Federal laws including the Plant 

Protection Act of 2000, as amended (7 U.S.C. 7701 

et seq.); and the Cooperative Forest Assistance Act of 

1978 as amended by the Forest Stewardship Act of 

1990 (16 U.S.C. section 2101(note)). USDA gypsy 

moth policy and activities conducted under these 

statutory authorities are described in Appendix B 

(Gypsy Moth Management Program) of the final SEIS.

 

The Decision

We have selected Alternative 3, which has two parts. 

First, it adds tebufenozide to the list of currently 

approved treatments in the USDA National Gypsy 

Moth Management Program. Second, it allows for 

adding new treatments to those already approved for 

the program. A new treatment may be added only if the 

risks it poses to human health and nontarget organisms 

are no greater than the risks disclosed in the final SEIS 

for the currently approved treatments and tebufenozide. 

The finding must be made through the application of 

the protocol that is described in Chapter 2 (Volume 

II) in the final SEIS and attached to this decision. Any 

new treatment must also be registered by the U.S. 

Environmental Protection Agency for use on gypsy 

moth.

 
Record of Decision

Record of Decision - Page 2

This decision, like the SEIS, and like the 1995 EIS and 

1996 decision, is programmatic; it does not authorize 

any specific project, but sets the parameters within 

which project decisions for gypsy moth management 

will be made. Implementation of this selected 

alternative requires that site-specific environmental 

analyses be conducted, and public input gathered to 

identify and consider local issues before any Federal 

or cooperative suppression, eradication, or slowthe-spread projects are authorized and implemented. 

These site-specific environmental analyses will be 

tiered to the programmatic SEIS and documented in 

accordance with agency National Environmental Policy 

Act (NEPA) implementing procedures. Alternative 3 

allows project managers to adapt available treatment 

options to local conditions in a manner that best 

reduces gypsy moth damage while minimizing 

unintended adverse environmental effects. Required 

consultations with appropriate Federal and State 

agencies, such as for threatened and endangered 

species, will also be conducted as needed before 

treatment projects are implemented. 

Actions taken against the gypsy moth by other 

agencies, organizations, or individuals without the 

participation of the Forest Service or APHIS are outside 

the scope of the SEIS and this ROD.

Alternatives

The following three alternatives were considered in 

detail in the SEIS:

Alternative 1—No action; that is, no change from the 

1996 Record of Decision

Alternative 2—Add the insecticide tebufenozide to the 

list of currently approved treatments

Alternative 3—Add the insecticide tebufenozide 

to the list of currently approved treatments, and add 

other new treatments that pose no greater risks to 

human health and nontarget organisms than the risks 

that exist with use of currently approved treatments 

and tebufenozide. Such treatments may be added only 

through the application of the protocol described in the 

final SEIS and attached to this ROD.

Environmentally Preferable 

Alternative

Alternative 3 is environmentally preferable. This 

alternative results in no greater risk to human health 

and nontarget organisms than the other alternatives 

would; and, as new treatments are added, may even 

be better than the other alternatives if new treatments 

result in fewer risks. Furthermore, because 

Alternative 3 allows for adding treatments in the 

future, project managers may have a greater array of 

options that will allow them to maximize treatment 

effectiveness and to minimize unintended adverse 

environmental effects by selecting treatments that 

better match site-specific conditions. Alternative 3 

includes a protocol for adding any new treatment to the 

approved list of treatments. The protocol is attached to 

this ROD. 

Rationale for the Decision

Alternatives were compared on the basis of three 

selection criteria: (1) how the alternatives respond 

to the goal of the USDA National Gypsy Moth 

Management Program, as determined by expected 

future conditions for each alternative, (2) how the 

alternatives respond to issues raised during scoping, 

and (3) how much flexibility the alternatives provide 

for managing ecosystems.

We selected Alternative 3 for these reasons: it fully 

meets the USDA goal of reducing the adverse effects 

of the gypsy moth on the nation’s forests and trees, it 

addresses the major issues associated with gypsy moths 

and their treatment, and it provides project managers 
Supplemental Environmental Impact Statement

Record of Decision - Page 3

the greatest amount of flexibility (the greatest number 

of options) in managing ecosystems affected by the 

gypsy moth.

 

Meets USDA Goal

Each of the three alternatives would meet the USDA 

goal to reduce the adverse effects of the gypsy moth on 

the nation’s forests and trees; however, in the long term 

Alternative 3 is the best choice. Alternative 3

not only adds the new treatment tebufenozide to 

the list of approved treatments in the gypsy moth 

program, but accommodates the timely addition of new 

treatments in the future through the implementation of 

the attached protocol. The addition of tebufenozide 

provides project managers with an insecticide option 

that not only is highly effective at reducing high gypsy 

moth population levels and protecting host foliage, 

but that may have fewer potential adverse effects 

on invertebrates in aquatic ecosystems than other 

currently available treatments. The availability of an 

additional treatment option gives project managers 

more choices (flexibility) and might also stimulate 

competition between manufacturers of these treatment 

products, which could translate into lower costs. 

These are benefits to the USDA National Gypsy Moth 

Management Program that Alternative 2 also provides 

but that Alternative 1 does not. 

The protocol associated with Alternative 3 will permit 

the timely addition of treatments that meet the USDA 

goals into the national program in the future. The 

authorization to add future new treatments through 

a streamlined, but rigorous protocol allows for the 

continuous improvement of the USDA National Gypsy 

Moth Management Program in responding to and 

reducing the adverse effects of the gypsy moth on the 

nation’s forests and trees. By providing more treatment 

options for project managers, this alternative increases 

the likelihood that project objectives (USDA goals) 

will be achieved while local issues and concerns, such 

as potential adverse effects on nontarget organisms 

and risks to human health, are addressed. Without the 

protocol, the Forest Service and APHIS would have 

to engage in the costly and time-consuming process 

to revise the SEIS each time we want to add a new 

treatment to the program, with no appreciable benefit. 

Applying the protocol, the agencies must prepare a 

human health and ecological risk assessment and a 

risk comparison of the human health and ecological 

risks of a new treatment with the risks identified for the 

currently authorized treatments and tebufenozide. They 

must also give the public an opportunity to review 

and comment on the findings of the risk assessment 

and risk comparison, and must consider those 

comments. Alternative 3 provides these benefits to the 

USDA National Gypsy Moth Management Program; 

Alternatives 1 and 2 do not.

 

Responds to Issues

The major issues that were raised during scoping and 

that influenced our decision are summarized in the 

question: How would gypsy moth, current treatments, 

tebufenozide, and a new treatment added under the 

protocol affect human health, nontarget organisms, and 

forest condition?

The SEIS, at Appendix E, “Biology, History, and 

Control Efforts for the Gypsy Moth,” describes how 

the response to gypsy moth has evolved over time. In 

particular, this appendix explains (or describes) how, 

over time, the program has replaced broad spectrum 

chemicals that pose greater risks to nontarget organisms 

and people with treatments that pose fewer risks. 

This is a trend that we anticipate will continue with 

our decision to select Alternative 3, as new treatment 

options become available and are examined for 

addition into the program.
Record of Decision

Record of Decision - Page 4

Human Health

Human health concerns fall within two categories:

(1) concerns about the effects caused by the presence 

of large numbers of gypsy moth caterpillars (including 

skin rashes, hazardous walkways, and emotional 

discomfort from the presence of vast numbers of 

insects), and (2) concerns about the effects of possible 

exposure to gypsy moth treatments. A detailed 

examination of the human health risks is presented in 

Volumes III and IV, Appendixes F through M of the 

final SEIS.

The choice of treatments under all three alternatives 

would provide project managers with a range of 

options to help them address site-specific issues and 

concerns related to human health risks from exposure 

to the insect as well as exposure to the treatments. 

The presence of large populations of gypsy moths is 

recognized as an ongoing risk to human health through 

irritation to eyes, skin, and respiratory system. The 

ability of the treatments to reduce the likelihood of 

caterpillars coming into contact with people and 

causing allergic reactions varies depending on the 

gypsy moth population levels in those areas that are 

planned for treatment. Some treatments might be 

better suited than others to reduce caterpillar levels and 

thereby be more effective in minimizing the potential 

for people to come into contact with the insect. 

Potential exposure of people to the approved treatments 

used in gypsy moth treatment projects has been 

examined in the risk assessments and is considered to 

be within an acceptable margin of safety. Nonetheless, 

public perception about pesticide exposure exists 

and commonly surfaces as an issue or concern when 

treatment projects are proposed. Having a range of 

treatment options affords project managers greater 

flexibility in selecting treatments that address human 

health concerns of the public and project objectives to 

reduce gypsy moth populations. 

Alternative 3, in the long term, provides the greatest 

flexibility to project managers to tailor treatments to 

specific situations. Alternative 3 provides a streamlined 

yet protective process for adding new treatments in 

the future to the approved list of treatments. Such 

treatments may be more efficacious on gypsy moth, 

but may not pose a greater health risk than currently 

approved treatments do. New treatments may very 

well pose even lower potential human health risks than 

current treatments do. 

Nontarget Organisms

The gypsy moth is the target of treatments. All other 

plant or animal species are considered nontarget 

organisms and are potentially affected directly or 

indirectly by some gypsy moth treatments. Nontarget 

organisms may also be affected by the presence of 

gypsy moth caterpillars as well as by the defoliation 

they cause. The ecological risks, including those to 

nontarget organisms, have been carefully examined and 

disclosed in the risk assessments (Appendixes F-M of 

the SEIS) that were prepared for each of the treatments 

in the SEIS.

 

Alternative 1 would not change the potential adverse 

effects on nontarget organisms that were previously 

described and accepted in the 1996 ROD. 

Alternative 2, with the addition of the insecticide 

tebufenozide to the list of approved treatments, would 

reduce the potential effects on aquatic invertebrates 

compared with some of the currently approved 

insecticides. Tebufenozide is also as effective as other 

approved treatments in reducing gypsy moth population 

levels and protecting tree foliage. The addition 

of tebufenozide to the list of approved treatments 

provides another treatment option that is efficacious on 
Supplemental Environmental Impact Statement

Record of Decision - Page 5

gypsy moth but has fewer potential nontarget effects 

around aquatic ecosystems than currently authorized 

treatments do. Alternative 3 has the same advantages 

and potential effects on nontarget organisms as 

Alternative 2 does. Under Alternative 3, however, 

through the application of the protocol required by our 

decision (Attachment), new future treatments that have 

no greater potential effects on nontarget organisms 

can be added to the approved list of treatments and 

incorporated into the USDA National Gypsy Moth 

Management Program more quickly. 

Forest Condition 

Tree species diversity, age class distribution, and 

overall health and vigor of forests and trees are affected 

by gypsy moth defoliation. During outbreaks, gypsy 

moth caterpillars often completely consume host 

tree foliage, causing trees to expend energy reserves 

to produce new leaves. Repeated defoliations in 

subsequent years weaken trees, leading to extensive 

areas of dieback and mortality, which permit other 

tree and plant species (including invasive plants) to 

grow and change the overall characteristics of the 

affected area. Oak species are the most highly favored 

hosts of the gypsy moth, and the impacts of gypsy 

moth outbreaks and defoliation on forest condition 

are particularly dramatic in oak-dominated forests. 

The alternatives in this SEIS and the approved list of 

treatments do, however, directly affect the management 

of gypsy moth populations and the impacts they cause. 

The current characteristics and condition of individual 

forest stands, then, can be protected through treatment. 

Overall, the current list of approved treatments in all 

three alternatives provides effective tools to reduce 

damage to trees and forest stands caused by gypsy 

moths. Alternative 2 adds the insecticide tebufenozide 

to the list of approved treatments. This insecticide 

is also effective in reducing gypsy moth populations 

and helps to protect forest conditions where it is 

used. When used around aquatic ecosystems, the 

insecticide also has fewer potential effects on nontarget 

invertebrates than currently approved treatments 

do. Alternative 3 not only adds tebufenozide to the 

list of approved treatments but also allows, through 

implementation of the protocol, the addition of new 

future treatments that are unknown at this time. 

Under this alternative, new treatments can be more 

quickly incorporated into the gypsy moth program. 

Such treatments may even be more effective against 

gypsy moths and, therefore, more protective of forest 

condition. 

 

Provides Management Flexibility

The alternatives differ in the range of treatments that 

the Forest Service and APHIS could use to manage 

or to help others manage gypsy moth infestations. 

Having a greater choice of treatment options will help 

project managers achieve a finer balance between 

meeting project objectives, addressing issues and 

concerns, and minimizing adverse effects.

Alternative 1 would provide only for the use of the 

current treatments, which were authorized in the 

1996 ROD. While those treatments have proved to 

be adequate options for gypsy moth projects in the 

past, Alternative 1 would keep managers locked into 

only those treatment options that were available in 

1996. Alternative 1 would not allow project managers 

to use new treatment options available since 1996 

or to examine and consider new treatment tools 

that could become available in the future. While 

gypsy moth projects would probably continue to be 

executed successfully under Alternative 1, the USDA 

National Gypsy Moth Management Program could 

not incorporate new and better treatment options that 

could give project managers a greater range of choices 

for addressing efficacy, project costs, local issues and 
Record of Decision

Record of Decision - Page 6

concerns, and potential adverse effects on nontarget 

organisms and human health and forest condition. 

 

Alternative 2 would add some flexibility by adding 

one new treatment option, tebufenozide. When 

applied near and around streams and other bodies 

of water, tebufenozide poses less of a risk to aquatic 

invertebrates than diflubenzuron does. Tebufenozide 

is as effective as diflubenzuron in reducing very 

high gypsy moth populations and protecting host 

tree foliage. Other approved treatment options 

could perform similarly but might require multiple 

applications, thereby doubling or tripling application 

costs. Alternative 2 would add a new treatment option 

in the USDA National Gypsy Moth Management 

Program, but it would not accommodate the 

examination and timely addition of new and better 

treatment options to the program in the future.

Alternative 3 includes all of the treatment options 

authorized in the 1996 ROD, adds tebufenozide, and 

allows the addition of new future treatment options 

to the USDA National Gypsy Moth Management 

Program through a streamlined, yet still protective 

process. Alternative 3 ensures that the USDA gypsy 

moth management program continues to evolve and 

incorporate new and better treatment options that will 

give project managers more flexibility in responding to 

local issues and concerns. 

The Forest Service and APHIS, and Federal, State, 

and Tribal cooperators would decide where and how 

to treat gypsy moths and how to mitigate treatment 

effects. Those decisions would require that local 

issues and concerns be considered and that site-specific 

environmental analyses be conducted and documented 

in accordance with agency NEPA implementing 

procedures.

Cumulative Effects

Cumulative effects are those impacts on the 

environment that result from more than one action, for 

example, from the incremental impacts of action by the 

USDA National Gypsy Moth Management Program 

and of other past, present, and reasonably foreseeable 

actions, regardless of what agency or person takes the 

other actions. Cumulative effects may result from 

individually minor, but collectively significant, actions 

taking place over time. Cumulative effects that may 

result from implementing any of the alternatives can be 

caused by:

• Repeated gypsy moth outbreaks and defoliation 

of the same area;

• Repeated treatment of the same area in the 

same season;

• More than one type of treatment being used in 

the same area in the same season; and

• Retreatment of the same area in the following 

season or a season soon after, such that the 

same resources are affected.

An analysis of cumulative effects for the different 

treatments is presented in Chapter 4 of the SEIS 

(Volume II): 

for the gypsy moth on pages 9 and 10; 

for Bacillus thuringiensis var. kurstaki (B.t.k.) on 

pages 14 and 15; 

for diflubenzuron on page 18; 

for disparlure on page 20; 

for dichlorvos on page 22; 

for Gypchek on page 23; 

for tebufenozide on pages 27 and 28, and 

for all treatments collectively on pages 28 and 29. 

The findings for cumulative impacts on human health 

and nontarget species are summarized here.
Supplemental Environmental Impact Statement

Record of Decision - Page 7

The cumulative effects on human health are anticipated 

to be less under Alternative 3 than under the other 

alternatives. The presence of large populations of 

gypsy moths is recognized as an ongoing risk to human 

health through irritation to eyes, skin, and respiratory 

system. To the extent that control and eradication 

efforts limit these effects, program actions would 

reduce this cumulative impact. The allowance for 

treatment options in addition to tebufenozide under 

Alternative 3 includes effective treatments that reduce 

exposure of humans to moths and moth parts, such 

as hairs, and thus the potential magnitude of adverse 

effects is less. 

Two treatments currently used in the program, B.t.k. 

and Gypchek, might also cause some skin irritation 

in people, but the amount of irritation is less than 

would result from people coming into direct contact 

with gypsy moth caterpillars. No plausible human 

health effects relate to the use of disparlure. Although 

diflubenzuron and tebufenozide are known to reduce 

the oxygen-carrying capacity of blood (increase 

methemoglobin), application rates used in USDA 

gypsy moth projects were determined to be unlikely 

to approach exposure levels of concern following 

application of either or of both treatments. Dichlorvos 

use in traps poses a potential risk of dermal exposure 

for persons who tamper with or ingest dichlorvos 

strips in traps. Adverse human health effects from 

dichlorvos have never been documented in USDA 

projects. Improper handling of dichlorvos strips poses 

a cumulative risk to workers, but program adherence 

to pesticide label restrictions and mandatory safety 

procedures preclude these effects. 

 

The cumulative effects on nontarget organisms are 

greatest from repeated defoliation of trees by gypsy 

moth caterpillars. The control efforts to reduce 

defoliation are associated with reduced cumulative 

effects on the host trees and those organisms depending 

on the host trees for survival. Gypchek, mass trapping 

with dichlorvos, and disparlure have no long-term or 

cumulative effects on nontarget terrestrial species. Use 

of these control measures in the USDA Gypsy Moth 

Management Program is not expected to impact aquatic 

organisms, based upon results of analysis of hazard 

quotients. Applications of B.t.k., diflubenzuron, and 

tebufenozide are known to affect various classes of 

invertebrates. B.t.k. and tebufenozide affect only larval 

stages of certain spring-feeding butterflies and moths 

that feed on treated foliage. Use of diflubenzuron 

is known to affect moths, butterflies, grasshoppers, 

parasitic wasps, aquatic insects, and some crustaceans. 

Repeated spraying of B.t.k, diflubenzuron, and 

tebufenozide in the same area over two or more 

consecutive years has the potential to result in 

cumulative impacts on those sensitive species. 

The availability and use of more treatment options 

under Alternative 3 provides future options that may be 

even safer to the environment. Under this alternative, 

project managers have the ability to choose treatments 

that minimize cumulative effects on sensitive species, 

while still reducing the extent of defoliation from the 

gypsy moth. 

Mitigating Measures 

Given the variety of places in the United States and 

local conditions and circumstances where gypsy moth 

projects could be implemented under Alternative 3, it 

will be necessary to develop and implement specific 

mitigation measures for each treatment project. Our 

decision continues the practice in place since the 

1996 ROD, of project managers developing and 

implementing mitigation measures as necessary on 

a site-specific basis for each project, to address local 

conditions, needs, issues, and concerns.
Record of Decision

Record of Decision - Page 8

Site-specific mitigation measures developed and 

employed in gypsy moth projects under the 1996 

ROD have most often been put in place to minimize 

the exposure of people and nontarget organisms to 

treatments in and near project areas. Site-specific 

mitigation measures have also been implemented to 

reduce potential impacts on economic resources such 

as organic farms. At the same time, the objectives of 

gypsy moth projects have also been met. We expect 

that success will continue with our decision to select 

Alternative 3. Site-specific mitigation measures 

will continue to be developed and implemented 

at the project level, as appropriate. The SEIS 

presents examples of mitigation measures that were 

implemented on site-specific projects in the past 

(Volume II, Chapter 2, pages 4 and 5). 

Endangered Species Act

In compliance with the Endangered Species Act of 

1973 (16 U.S.C. sections 1531-1536, 1538-1540), the 

Forest Service and APHIS have committed to consult 

with the U.S. Fish and Wildlife Service (F&WS) 

or, when appropriate, the National Marine Fisheries 

Service on gypsy moth treatments that would be 

conducted by the Forest Service and APHIS, or those 

conducted in cooperation with other Federal agencies 

or States. 

 

We requested concurrence from the F&WS with our 

determination that USDA management of gypsy 

moth in the United States is not likely to adversely 

affect endangered and threatened species or critical 

habitat under the jurisdiction of the F&WS outside 

Karner blue butterfly (Lycaeides melissa samuelis)

habitat in Wisconsin. The F&WS concurred with 

our determination and indicated that “[e]ffective 

coordination with the [Fish and Wildlife] Service’s 

field organization will be a key element in ensuring 

the avoidance of adverse effects to listed species and 

their habitats.” Such coordination at a local level will 

ensure that the program will have no effect or is not 

likely to adversely affect federally listed species or 

designated critical habitat for each gypsy moth project 

that is proposed. We will ensure that any protection 

measures for threatened and endangered species or 

critical habitat that result from such coordination will 

be implemented. If incidental adverse effects to listed 

species or critical habitat are likely to occur, we will 

reinitiate consultation with the F&WS. Where formal 

consultations currently take place for USDA-sponsored 

gypsy moth treatments that may adversely affect 

Karner blue butterfly in Wisconsin, we will continue 

that established consultation process. This process has 

been developed and agreed to locally by the F&WS’ 

Green Bay, WI, Ecological Services Office. 

Monitoring

Gypsy moth populations in the United States are 

monitored annually by APHIS, the Forest Service, 

and the States, to detect new infestations, monitor 

population outbreaks, and to track populations 

along the leading edge of the infested area. Such 

monitoring provides the early warning needed to 

identify areas where direct intervention (treatments) 

may be necessary to eliminate isolated infestations 

of the insect, to reduce damage caused by population 

outbreaks, and to reduce the natural spread of the 

insect into uninfested areas. Once treatments are 

decided upon, the project areas are monitored during 

the treatments to ensure that they are carried out as 

planned. After the treatments, a subset of the project 

areas are assessed to determine if the treatments met 

the project objectives, that is, had the intended effect on 

the gypsy moth populations. 

Collectively, the insect and treatment monitoring and 

assessments implemented in the USDA National Gypsy 

Moth Management Program have served the program 
Supplemental Environmental Impact Statement

Record of Decision - Page 9

well over the years by helping to find new isolated 

infestations early and by projecting when and where 

damaging population levels are likely to occur and 

where. The result has been a highly successful gypsy 

moth management program. The Forest Service and 

APHIS plan to maintain this approach of monitoring 

and assessment, to ensure our funding and efforts are 

put to good effect. Project managers may do additional 

monitoring on a case-by-case basis after assessing local 

issues and concerns.

 

Public Involvement

An extensive public involvement effort informed the 

public about the SEIS and elicited suggestions, ideas, 

and concerns related to gypsy moth management. 

Public outreach was conducted throughout the duration 

of the SEIS process and was highlighted by formal 

public comment periods in which written comments 

were sought.

The first formal opportunity for the public to comment 

on the SEIS was initiated in April 2004, when the 

Forest Service and APHIS published a Notice of 

Intent (NOI) to Prepare a Supplement to the Final EIS 

for Gypsy Moth Management in the United States: a 

cooperative approach (69 Federal Register (FR) 23492-

93, April 29, 2004). The public was invited to comment 

on the proposed supplement.

To identify and reach the interested and affected public 

across the United States, the Forest Service and APHIS 

developed a public outreach plan, compiled a national 

mailing list, and prepared informational materials about 

the SEIS project and the gypsy moth. In May 2004, the 

agencies mailed an informational bulletin requesting 

input on the plan to prepare the SEIS, to nearly 13,000 

individuals and organizations. Addressees included 

scientists, members of conservation and environmental 

groups, persons working in forestry and related 

industries, homeowners, landowners, over 2,000 

libraries, and Federal, Tribal, State, and local officials. 

The SEIS team also gathered comments and input from 

within the Forest Service and APHIS, other Federal 

land management agencies, and agencies in 25 different 

States that had expressed interest in the SEIS. The 

result of this extensive national scoping process was the 

identification of two significant issues that subsequently 

guided the development of the SEIS: the risk to human 

health and the risk to nontarget organisms.

The second formal opportunity for the public to 

comment was initiated in September 2008 with the 

publication in the Federal Register of the Notice of 

Availability of the draft SEIS (73 FR 54397, September 

19, 2008) and of the extension of the comment period, 

for a total of 90 days (73 FR 70640, November 21, 

2008). The Forest Service and APHIS mailed 419 

hard copies and 765 CDs (electronic copies) of the 

complete draft SEIS to individuals and organizations 

who requested it, and to Federal and State agencies 

interested in the gypsy moth, public health, or 

the environment. An additional 146 copies of the 

summary of the draft SEIS were mailed to individuals 

and organizations with the suggestion that if they 

wished to submit comments, they should review 

the complete draft SEIS. The draft SEIS was also 

available on a specially designed Web site for viewing 

and downloading. The Web site was visited by 1,240 

individuals; 792 visited once, and 448 visited more 

than once. Letters were received from commenters 

in 14 States across the country and from the District 

of Columbia. Thirty-four people sent 18 letters, 22 

e-mails, and 1 fax, for a total of 41 comment letters. 

Five of those comment letters were received after the 

December 18, 2008, deadline for public comment. 

Nevertheless, the Forest Service and APHIS considered 

the comments in those letters.
Record of Decision

Record of Decision - Page 10

The time period between the Notice of Availability of 

the final SEIS (October 19, 2012) and this decision 

also provided an opportunity for public comment. No 

comments were received during this period.

To conduct public involvement on a national scale 

and to ensure that the final SEIS serves all areas of 

the United States, the preparers of the SEIS were 

assisted by public affairs and forest project managers 

throughout the Forest Service and APHIS. A detailed 

accounting of the public affairs and public involvement 

activities and the Forest Service and APHIS response 

to comments appears in Volume II, Appendix C, of the 

final SEIS.

Implementation

This decision continues the requirement of the USDA 

National Gypsy Moth Management Program that 

specific gypsy moth treatments may be authorized 

only after analysis of the site-specific environmental 

effects, carried out in accordance with the National 

Environmental Policy Act and any other applicable 

legal requirements. 

Effective Date

Our decision is effective immediately. 

Our decision is not subject to administrative appeal 

because it neither implements a national forest land 

and resource management plan (36 CFR 215.1) nor 

approves, amends, or revises a national forest land 

resource management plan or regional guide (36 CFR 

219.17).

Questions concerning this decision or other topics 

related to the final SEIS should be directed to either of 

the following individuals:

Noel F. Schneeberger

USDA Forest Service

Northeastern Area State and Private Forestry

11 Campus Blvd., Suite 200

Newtown Square, PA 19073

Or

Julie Spaulding 

National Gypsy Moth Program

USDA Animal and Plant Health Inspection Service

Plant Protection and Quarantine

4700 River Road, Unit 137

Riverdale, MD 20737

Responsible Officials

James E. Hubbard, Deputy Chief Date

State and Private Forestry

USDA Forest Service

Sidney R. Yates Federal Building

201 14th Street, S.W.

Washington, DC 20250

Rebecca Bech, Deputy Administrator Date

Plant Protection and Quarantine

USDA Animal and Plant Health Inspection Service

Administration Building, Room 312-E

Washington, DC 20250-3401
Supplemental Environmental Impact Statement

Record of Decision - Page 11

Attachment 

Protocol for Adding New Treatments 

to the List of Approved Gypsy Moth Treatments

(Final Gypsy Moth SEIS, Volume II, Chapter 2, 

Alternative 3, pages 2 and 3)

A new treatment would be available for use upon the 

agencies’ finding that the treatment poses no greater 

risks to human health and nontarget organisms than are 

disclosed in the final SEIS for the currently approved 

treatments and tebufenozide, and it is registered by 

the U.S. Environmental Protection Agency for use on 

gypsy moth. The protocol for making the necessary 

finding that a treatment is authorized is as follows: 

1. Conduct a human health and ecological 

risk assessment (HHERA). In this risk 

assessment review all scientific studies 

available for toxicological and environmental 

fate information relevant to effects on 

human health and nontarget organisms. Use 

this information to estimate risk to human 

health and nontarget organisms. Include 

these four elements in the HHERA: (a) 

hazard evaluation, (b) exposure assessment, 

(c) dose-response assessment, and (d) risk 

characterization. The HHERA will do the 

following: 

•	 Identify potential use patterns, 

including formulation, application 

methods, application rate, and 

anticipated frequency of application. 

•	 Review hazards relevant to the human 

health risk assessment, including 

systemic and reproductive effects, 

skin and eye irritation, dermal 

absorption, allergic hypersensitivity, 

carcinogenicity, neurotoxicity, 

immunotoxicity, and endocrine 

disruption. 

•	 Estimate exposure of workers 

applying the chemical. 

•	 Estimate exposure of members of the 

public. 

•	 Characterize environmental fate and 

transport, including drift, leaching to 

groundwater, and runoff to surface 

streams and ponds. 

•	 Review available ecotoxicity data 

including hazards to mammals, birds, 

reptiles, amphibians, fish, and aquatic 

invertebrates. 

•	 Estimate exposure of terrestrial and 

aquatic wildlife species. 

•	 Characterize risk to human health and 

wildlife. 

2. Conduct a risk comparison of the human 

health and ecological risks of a new treatment 

with the risks identified for the currently 

authorized treatments and tebufenozide. This 

risk comparison will evaluate quantitative 

expressions of risk (such as hazard quotients) 

and qualitative expressions of risk that put the 

overall risk characterizations into perspective. 

Qualitative factors include scope, severity, 

and intensity of potential effects, as well as 

temporal relationships such as reversibility 

and recovery. 

3. If the risks posed by a new treatment 

fall within the range of risks posed by 

the currently approved treatments and 

tebufenozide, publish a notice in the Federal 

Register of the agencies’ preliminary findings 

that the treatment is authorized by the 2012 
Record of Decision

Record of Decision - Page 12

Record of Decision, for use in the USDA 

National Gypsy Moth Management Program. 

The notice must provide a 30-day public 

review and comment period, and must advise 

the public that the HHERA and the risk 

comparison are available upon request. 

4. If consideration of public comment leads to 

the conclusion that the preliminary finding 

is correct, publish a notice in the Federal 

Register that the treatment is authorized by 

the 2012 Record of Decision for use in the 

USDA National Gypsy Moth Management 

Program and therefore may be authorized by 

project decisions implementing that program. 

The Forest Service and APHIS will make 

available to anyone, upon request, a copy 

of the comments received and the agencies’ 

responses.
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, 

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of discrimination, write to 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.

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U.S. Department of Agriculture

Pesticide Precautionary Statement 

Pesticides used improperly can be injurious to humans, animals, and plants. Follow the 

directions and heed all precautions on the labels. 

Store pesticides in original containers under lock and key--out of the reach of children and 

animals--and away from food and feed. 

Apply pesticides so that they do not endanger humans, livestock, crops, beneficial insects, 

fish, and wildlife. Do not apply pesticides when there is danger of drift, when honey bees or 

other pollinating insects are visiting plants, or in ways that may contaminate water or leave 

illegal residues. 

Avoid prolonged inhalation of pesticide sprays or dusts; wear protective clothing and 

equipment if specified on the container. 

If your hands become contaminated with a pesticide, do not eat or drink until you have 

washed. In case a pesticide is swallowed or gets in the eyes, follow the first-aid treatment 

given on the label, and get prompt medical attention. If a pesticide is spilled on your skin or 

clothing, remove clothing immediately and wash skin thoroughly. 

Do not clean spray equipment or dump excess spray material near ponds, streams, or wells. 

Because it is difficult to remove all traces of herbicides from equipment, do not use the same 

equipment for insecticides or fungicides that you use for herbicides. 

Dispose of empty pesticide containers promptly. Have them buried at a sanitary land-fill 

dump, or crush and bury them in a level, isolated place. 

NOTE: Some States have restrictions on the use of certain pesticides. Check your State and 

local regulations. Also, because registrations of pesticides are under constant review by the 

Federal Environmental Protection Agency, consult your county agricultural agent or State 

extension specialist to be sure the intended use is still registered.