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Noxious Weed 
Management Projects 














Bonners Ferry Ranger District 


TABLE OF CONTENTS 





Page 
SUMMARYE Ee een ., k CeE fceeiessivobes scconnacde S-1 
CHAPTER 1 - PURPOSE AND NEED FOR ACTION...........scssssssconssorsscsooers 1-1 
EM TOOUCHON acerseecerteas cent eartartcetecre te cscs ss 1-1 
PTODOSCC_ACHOM ater te en sccsie Tee a eels teleetye 1-1 
Purpose and Need for Action.........cccccscesssessssecessssceeeneees 1-2 MAY | 
Scope Of Proposed ACctivities...........cccccessssscesssvsesesssees 1-2 oe 
Scope of Analysis: Connected, Cumulative, and Similar Actions:::::)4-6 \ 
Scope of Analysis: Alternatives..........cccccccsesssecsssseenees 1-6 wy) Q eles) \ 
SCODGLOMALIAIVSIS SIIMDACSiwanceete <7, aie a .eeeeaine 1-7 1 NU ¥j ~ \ 
Scope of Analysis: DeCiSIONS..............ceseresees eee 1-7 eet | “ \ 
Weed Management PhilOSOPHY.........::ssssscsssesessssesesssesssseeees 1-7, Yb 8G PR ’ 
ROUUL eR ACTIVI CS tee eats. teem tt csi 1-8 \ — 
Cah A Posie PAB ese CE EN LN ones cuca cess ar seed Masawanse poees brncden 2-1 
IMT OGU CHONG, tee wee een res eM ata ane centers 2-1 
Alternauve Development PlOCCSS 2 ..c..o.cs.ccos0+-.+sssrenepeesenne 2-1 
EES OS LSE Sv SS CIC AA a 2-1 
Alternatives Considered in Detail... ceeesscessseeeennees 2-2 
Methods and Practices Available Under Each Alternative............... 2-3 
Alternatives Considered but Not Given Detailed Study................. 2-5 
Treatment Methods Considered for Each Site... eeeeeseeeees 2-5 
Rationale for the Selection of the Preferred Control Method(s)....... 2-5 
NAOT OCHO esas cette te rtmmneee eeeetn cr ratcpes seca cnsanrs 2-9 
Comparison of the Alternatives Considered in Detail.................. 2-9 
ARE Raee Ar rca Le VIPS OINIVIEINi Do cryst secgargysteesece-vbectsgeasaaavs 3-1 
PEO CU CUO Ie craaanc ne accetcren se cass uegesh cxcuspestspgrasmeeases 3-1 
Alea DESCODUOMS eats: oy rata sesdaseescescuccisnsseess 3-1 
Forest Plan Management Direction for These Sites... 3-2 
Affected Resources on Proposed Treatment SiteS.......... cess 3-3 
CHAPTER IV - ENVIRONMENTAL CONSEQUENCES... ccceeeeesseeeneeeteeeens 4-1 
UNOCUICUOU ere tpuccccens ettcararerer tancatacecrbenansusssoankes 4-1 
Environmental Impacts on Affected RESOUICES..........cceeeeees 4-1 
PAGAN Sie tore it eacvendceesstans caves daneerorschciess 4-1 
Fisheries and Surface Water Quality... eeeeeseeeees 4-1 
Human Resources and Human Heallth..........ccsessseseeeeeeees 4-7 
PRAIVOG ccscrsson sare fans roc cate-sa ces tecaenheanrenensipesantosei 4-9 
gt sfet gers 1d) 9 Wage io pert s ea hy pen ee ee 4-10 
SOUS ANG CSlOUNOW ALOT. scaccagscarescansepuesvtnbonranesensaess 4-10 
Vegetative Community DIVETSItY.......csseeeseenes 4-11 


Wildlife and Threatened and Endangered Species................. 4-13 


Probable Environmental Effects That Cannot be Avoided........... 4-15 
Possible Conflicts with the Plans and Policies 


of Other JUriSCiClOns eel keira cesta tnsnnceare 4-16 
The Relationship Between Short-Term Uses and Long-Term 
PROCUCUVILY Aprcercrtties tee eesecccstunnace mene tetoant 4-16 
Irreversible and Irretrievable Commitment of Resources.......... 4-16 
CHAPTER V - SUMMARY OF PUBLIC COMMENTS. ............cesssccsseeesneeeens 5-1 
CHARTER VIS sLiS hOrbPREPARERG ese: cn mate terete tees 6-1 
REEERENCES CHED tex naetsucsccascseent essere REF-1 
LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THE RECORD 
OF DECISIONHROD) HAVE BEENISEN ik: .ccrcccccrscertse.cooeereoenene LOA-1 
ABPENDIGES wir meme ata ene arte eat sete eee 
A - Area Map and Site Location Map............cccscsescceseeeeees A-1 
B24 -  TOXICIDV as ater erec tert meee ae re B-1 
C - Procedures for Mixing, Loading, and Disposal of Pesticides....... C-1 
D-=' Spill. Plan. Seger cect nner aocctonena tee ert es D-1 
E = Biological ASSESSMONtSi.cdnrscte et eerie rteenn, E-1 


F - Idaho Panhandle N.F. Proposed Integrated Weed Management Program. F-1 


SUMMARY 


PROPOSED ACTION 


The Bonners Ferry Ranger District proposes to con- 
trol noxious weeds in certain geographical ecosys- 
tems on the district. Control alternatives include 
non-chemical and chemical treatment methods un- 
der an Integrated Pest Management program. 


Currently 41 sites with noxious weeds have been 
identified. Sites range in size from 0.24 acres to 33 
acres and total 335.55 acres. This area represents 
less than 0.08 percent of the four hundred ten thou- 
sand acres of National Forest System lands admin- 
istered by the Bonners Ferry Ranger District. It is 
important to note that on many of these sites the 
infestations of noxious weeds are still very scat- 
tered, and not all of these acres would require treat- 
ment. For example, the largest site is 13.8 miles of 
road in the Smith, Cow, and Beaver Creek drainag- 
es where infestations of primarily meadow hawk- 
weed can be found along the road. 


Thirty-eight of the forty-one sites are infested with 
meadow hawkweed (Hieracium pratense) ) or com- 
binations of meadow hawkweed and spotted knap- 
weed (Centaurea maculosa). Two of the sites are 
infested with Rush Skeleton Weed (Chrondrilla jun- 
cea), found in but three sites in Boundary County. 
One site, Roman Nose Lake #3, is infested with 
common tansy (Tanacetum vulgare). Ten other sites 
are infested with common tansy along with hawk- 
weed, spotted knapweed, or thistles. Three sites are 
infested with Dalmation toadflax (Linaria vulgaris). 


Twenty-five of the 41 sites are located in the Selkirk 
Ecosystem. Six sites are located in the Cabinet 
Mountains Ecosystem and seven sites are located 
in the Purcell Mountain ecosystem. Three sites are 
identified in the valley outside the three mountain 
ranges. 


This Final Environmental Impact Statement (FEIS) 
examines several alternatives for treating these 
sites. These alternatives include a variety of meth- 
ods including manual, cultural, and biological tech- 
niques. One alternative combines these non- 


chemical methods with herbicide applications. The 
effects of a no-action alternative are also analyzed. 


The preferred treatment varies by site and can in- 
clude either chemical, biological, or manual treat- 
ment or combinations of these treatments. A com- 
plete listing of preferred methods is provided in 
Table 2-1 (p. 2-6). 


This analysis also assumes that new sites will be 
discovered in key ecosystems and that these sites 
are in land types analyzed in this document. These 
new infestations are assumed to increase the total 
infestation acreage by twenty percent. The impacts 
analysis in Chapter 4 assumes that these sites are 
treated chemically. All chemical applications are 
made with ground based equipment. 


PURPOSE AND NEED FOR AC- 
TION 


Weed control is proposed in order to: 
ih Protect the natural condition and biodiversity 
of the Selkirk and Cabinet Mountain Ecosys- 
tems by preventing the spread of aggressive, 
non-native plant species that displace native 
vegetation. 


Prevent or limit the spread of noxious weeds 
in key low elevation lakes in the Purcell 
Mountain ecosystem. Lakes to be protected 
are Brush Lake, Dawson Lake, Robinson 
Lake, and Smith Lake. Campgrounds at 
these lakes under Forest Service jurisdiction 
and other campgrounds within this ecosys- 
tem will be targeted for weed control action. 


Comply with Federal and State Laws regulat- 
ing management of noxious weeds. 


Cooperate with other agencies and private 
individuals, including adjacent landowners, 
concerned with the management of noxious 
weeds. 


ALTERNATIVES: 
Scoping 


The public has been involved throughout the devel- 
opment of the EIS. Public comment has helped de- 
fine the issues and develop the range of alternatives 
for accomplishing management goals and objec- 
tives. 


Public comment was solicited formally with a notice 
published in the Federal Register that indicated our 
intent to prepare an EIS. Several articles published 
and news features in local newspapers solicited 
public input on the weeds in the Forest issue. 


ISSUES 


Analysis of public and internal input resulted in the 
following list of issues that guided the development 
of the alternatives. Each issue is stated as a ques- 
tion, often general in nature, and is followed by a 
synopsis of the specific comments received from 
the public. A brief discussion of how the issue is 
addressed in the EIS follows the synopsis of public 
comments, 


1. What are the potential impacts of noxious 
weeds on resources such as ecological commu- 
nities and processes; threatened, endangered, 
or sensitive plants and animals; soils; water qual- 
ity; aesthetics; wildlife and fish; and recreational 
opportunities? 


Most commenters viewed noxious weeds as a po- 
tential problem in the National Forests. Many have 
seen the impacts of non-native plants on vast areas. 
One commenter questioned our use of the terms 
“native” and "noxious" species. 


The Environmental Consequences section of this 
EIS (Chapter 4) discusses the impacts of noxious 
weeds on various resources. 


2. What are the potential impacts of weed con- 
trol methods on other forest resources as listed 
in issue 1? 


Although most commenters acknowledge the po- 
tential threat of noxious weeds, some question 


whether the use of herbicides in the Forest would be 
appropriate. Some commenters were concerned 
about the impact of herbicides on the biological 
resources. Others advocated a full range of control 
measures, including herbicide use, to reduce the 
threat. 


A full range of alternatives is developed in chapter 
2, and the environmental, social, and economic 
consequences of the alternatives are presented in 
Chapter 4. 


3. How would the weed management methods, 
particularly herbicide application, affect human 
health? 


Some commenters were specifically concerned 
about the impact of herbicide spraying on human 
health and on traditional hunting and gathering ac- 
tivities. 


The potential impacts of herbicide application on 
human health have been analyzed extensively. 
Chapter 4 presents the results of this analysis. 


ALTERNATIVES CONSIDERED IN 
DETAIL 


BRIEF OVERVIEW 


Four alternatives were developed to address the 
issues raised by public and agency comment. 
These alternatives represent the range of control 
methods currently available for treatment of noxious 
weeds. In addition to the No Action alternative, two 
of the action alternatives involve only non-chemical 
methods of control. The comparison of these atter- 
natives with the alternative that includes chemical 
use sharply defines the issue of possible human 
health and environmental impacts of herbicide use. 
The analysis of the No Action alternative addresses 
the impacts of the unchecked expansion of noxious 
weeds in the Forest. 


The four alternatives are outlined below with a brief 
discussion of the major issues relevant to these 
alternatives. Each of these alternatives, except the 
No Action alternative, involve a combination of treat- 
ment methods. 


ALTERNATIVE 1: No Action 


This alternative would result in a change in the cur- 
rent noxious weed control activities on the Bonners 
Ferry Ranger District. Control activities would be 
restricted to minimal amounts of manual control. 


The comparison of this alternative with the active 
control alternatives highlights the potential effects of 
uncontrolled weeds on the forest environment. The 
No Action alternative also provides a baseline for 
analyzing the possible adverse impacts of the con- 
trol alternatives. 


ALTERNATIVE 2: Manual 
Control 


and Cultural 


This alternative was developed in response to the 
possible impacts of treatment methods, such as 
chemical control, on non-target plants, and human 
health. Under this alternative, treatments such as 
hand pulling, clipping, and mowing would be imple- 
mented to destroy or limit reproduction of the weed 
species. Cost effectiveness and environmental/ 
human health trade-offs can be compared between 
this alternative and other proposed alternatives. 


ALTERNATIVE 3: Manual, Cultural and Bi- 
ological Control 


This alternative was developed in response to many 
of the same issues that prompted the development 
of Alternative 2. Under this alternative, treatments 
previously mentioned under Alternative 2 would be 
supplemented with the release of biological agents 
such as parasites, predators and pathogens that 
have shown some promise in reducing weed infes- 
tations. This alternative allows us to examine the 
possible impacts of introducing species that show 
some promise in bringing exotic plant species into 
better balance in these ecosystems. At the present 
time relatively few biological control agents are 
available that are effective against the weed species 
of concern here. However, some agents have 
shown promise in controlling Canada thistle. Cost 
effectiveness and environmental trade-offs between 
this alternative and other alternatives can be exam- 
ined. 


ALTERNATIVE 4: Manual, Cultural, Biologi- 
cal and Chemical Control 


Under this alternative a full range of treatments 
would be considered for each site. Herbicide pre- 
scriptions would be consistent with or more restric- 
tive than product label requirements. If an herbicide 
is used in the annual floodplain, the Forest Service 
would only apply a herbicide formulation approved 
by the U.S. Environmental Protection Agency for 
direct applications to water. In no case would the 
Forest Service apply herbicide directly to water. 


This alternative allows us to compare the cost and 
effectiveness of the chemical use with the potential 
environmental and health effects of this and other 
methods. 


ALTERNATIVES CONSIDERED 
BUT NOT GIVEN DETAILED STUDY 


Additional alternatives and methods were consid- 
ered by not given detailed study. These include use 
of the herbicide glyphosate (the active ingredient in 
Round-up) and grazing. The reasons for not consid- 
ering these alternatives in detail are provided in 
Chapter 2. 


AFFECTED ENVIRONMENT 


The 41 sites proposed for treatment are located in 
either the Purcell, Cabinet, or Selkirk Mountain Eco- 
systems on the Bonners Ferry Ranger Districts. 
These ecosystems lie within portions of northern 
Idaho, northwestern Montana, and/or southern Brit- 
ish Columbia. 


Most of the proposed projects sites are located ad- 
jacent to forest roads. A couple sites are located 
along trails that lead to relatively pristine portions of 
the Selkirk Ecosystem. 


Portions of two major river drainages (Kootenai Riv- 
er and Moyie River) are located on the Bonners 
Ferry Ranger District. The valleys of these two river 
drainages are typical intermountain glaciated val- 
leys which have been subject to extensive stream 
action since glacial times. The valleys generally 
range from .5 to 2 miles wide; however, narrow 
steep canyons also occur on the lower end of the 
Moyie River valley. Elevations on the valley floor 
range from 1800 feet near the Canada/U.S. bound- 


ary along the Kootenai River to 2633 feet where the 
Moyie enters the United States from Canada. From 
the valley floors, the mountains rise abruptly to ele- 
vations over 7500 feet. 


The climate of the area is primarily affected by mari- 
time weather patterns that are occasionally modi- 
fied by continental air masses. Weather varies con- 
siderably with elevation, slope aspect, and season. 
Annual precipitation ranges from 25 inches on the 
valley floor to 80 inches or more in the higher eleva- 
tions. Snow provides approximately 40 to 80 per- 
cent of the total precipitation depending on the loca- 
tion. Snow cover in open areas on the lower to mid 
valley floors typically vanishes in March or April. 
Snow accumulation is much greater in the higher 
elevations and can linger into the summer months. 


Soils in the valley floors and lower valley slopes 
have developed from two types of parent materials: 
materials deposited by glaciers (glacial tills) and 
post-glacial alluvial deposits. Glacial materials are 
often deposited as unstratified clayey and loamy 
deposits. Water-deposited materials occur on the 
stream terraces and alluvial fans of the valley bot- 
toms. Soils on the higher terraces have developed 
in stratified sand, gravel, and cobble. Soils on the 
lower terraces have developed in stratified silts, 
sands and gravels which are frequently deposited 
and disturbed. 


Soil development has also been affected by wind- 
deposited, volcanic ash. Soils in relatively undis- 
turbed areas on the valley floor often contain soil 
profiles several inches in depth that have been sig- 
nificantly affected by volcanic deposits that originat- 
ed in Cascade Range eruptions such as Mount 
Mazama. 


The vegetation is a complex mosaic of different 
aged stands of Pinus contorta (lodgepole pine), 
Pseudotsuga menziesii (Douglas-fir), Pinus ponde- 
rosa (Ponderosa pine), Larix occidentalis (Larch), 
Picea (Spruce), Abjes lasiocarpa (sub-alpine fir), 
Tsuga heterophylla (western hemlock), and Thuja 
plicata (western redcedar). 


Douglas-fir is believed to be the climax tree species 
on most dry sites. Common shrubs include Arctost- 
phylos uva-ursi (kinnikinnik), Berberis repens 
(Creeping Oregon grape), Symphoricarpos albus 


(Snowberry), Holodiscus discolor (ocean spray), 
and Physocarpus malvacea, ninebark. More mesic 
(moister) sites support an understory of Linnaea 
borealis (twinflower), Oregon grape, kinnikinnick, 
Cornus stolonifera (Red-osier dogwood), Shep- 
herdia canadensis  (Buffalo-berry), Agrostis 
stoloniféra (Redtop), and Aster occidentalis (West- 
ern aster). On moister sites larch is fairly extensive 
on the lower to mid slopes. 


Lodgepole pine is the most abundant conifer found 
throughout the area in all but the higher elevations. 
It occurs in all densities and age class distributions, 
and is frequently in pure, even-aged stands. 


Ponderosa pine is found to a limited extent on some 
of the dry sites at low elevations. This species often 
occurs in the open, park-like stands. Understories in 
these stands are dominated by bluebunch wheat- 
grass, rough fescue, and other bunchgrass spe- 
cies. Scattered Douglas-fir and lodgepole pine are 
also found on these sites and account for most of 
the coniferous reproduction. 


Spruce grows over a wide range of elevations on 
sites with abundant soil moisture. Spruce is found 
primarily in riparian areas and with sub-alpine fir on 
mesic northerly slopes. 


River bottom lands are well vegetated with conifers, 
primarily lodgepole pine, Douglas-fir, larch, ponde- 
rosa pine, and Engelmann spruce. Associated 
hardwood tree species include birch, cottonwood, 
and aspen with willow, alder, and other shrubs. 


COMPARISON OF THE ALTERNA- 
TIVES CONSIDERED IN DETAIL 


Chapters 2 and 4 discuss the impacts of the alterna- 
tives on the affected resources of the sites under 
consideration. Potentially affected resources range 
from the vegetation community to water quality, fih- 
series and human heatth. A brief synopsis of central 
findings is provided in this summary. The interested 
reader is encouraged to read Chapter 4 for a more 
complete disclosure. 


Table S-1 summarizes the risk of spread of noxious 
weeds under the various alternatives. 


Table S-1--Relative risk of the spread of 
noxious weeds. 


Alternative 1: No 
Action 


Alternative 2: Manu- 
al & Cultural 


Alternative 3: Manu- 
al, Cultural & Biolog- 
ical 


Highest risk of spread of 
any of the alternatives. 
Greatest risk that new 
invading species would 
find a place 

establish populations 
and spread. 


Low risk if carried out at 
least three times per 
year on an annual basis. 
Risk of vegetative spread 


may be higher than with 
herbicide control. 


Low to moderate risk if 
manual and Cultural 
control is carried out at 
least three times per 
year on an annual basis. 
Moderate risk of vegeta- 
tive spread if climatic 
conditions are not suit- 
able for the biological 
agents. 








Table S-1--Relative risk of the spread of 
noxious weeds. (continued) 


Alternative 4: Manu- | Low risk assuming careful 
al, Cultural, Biologi- | follow-up spray and 
cal & Chemical assuming manual and 
‘a, cultural control is carried 
Out at least three times 
per year in areas close 


to water. Biological con- 
trol may reduce the 
competitiveness of Cana- 
da thistle but there is 
potential for continued 
spread. 


Table S-2 summarizes the environmental impacts of 
the various alternatives. 


Table S-2--Summary of environmental impacts of the alternatives 


Alternative 1: No 
action 


Alternative 2: Manu- 
al & Cultural 


Alternative 3: Manu- 
al, Cultural & Biolog- 
ical 


Alternative 4: Manu- 
al, Cultural, Biologi- 
cal & Chemical 


IMPACT OF THE CONTROL ALTERNATIVES ON 


HUMAN HEALTH 


Impacts are related to the spread of noxious weeds. 


Minimal impacts. Minor soil disturbance. 


Low impact expected on native vegetation. 


Visual impacts of site treatment has the potential to disrupt some users 
experiences. Analysis does not indicate a risk of significant impacts on fish and 
wildlife. Short term localized impacts on some broadleaf species. 





The non-chemical alternatives would have little im- 
pact on human health and safety. The manual and 
mechanical alternatives could result in sprains, mi- 
nor irritations, or injury from flying objects. 


Current toxicology data supporting the registration 
of these herbicides indicate that these compounds 
provide low risk when used as directed. The issues 
of carcinogenicity, mutagenicity, and generalized 
health effects are addressed in Chapter 4. The risks 
of long-term deferred effects such as cancer are 
considered very slight and on the order of other 
riskS Commonly encountered in everyday life (for 
example, the cancer risks of transcontinental air 
flight from increased exposure to cosmic radiation). 
The exposures to chemicals from these projects 
would be quite transient and minimal, even on a 
Cumulative basis. 


There will always remain some uncertainty regard- 
ing the effects of herbicide exposure on human 
health. Sources of uncertainty include the neces- 
sary extrapolation of toxicology data from laboratory 
animals to humans, the use of high-dose cancer 
studies to predict rates of cancer from low doses, 
and the difficulty of predicting human dose levels 
under the conditions anticipated here. To compen- 
sate for this uncertainty, risk was analyzed conser- 
vatively which tends to overstate the risk. These 
factors are reviewed in Chapter 4 and in the Risk 
Analyses contained in the project file. 


CHAPTER 1 
PURPOSE AND NEED FOR ACTION 


INTRODUCTION 


This chapter: 


ts Describes what the Bonners Ferry Ranger 
District proposes to do. 


ei Explains why the proposed actions are need- 
ed. 
3. Locates the infested areas proposed for 


treatments with further reference to a Ssepa- . 


rate map document (Appendix A). 


PROPOSED ACTION 


The Bonners Ferry Ranger District proposes to con- 
trol noxious weeds in certain geographical ecosys- 
tems on the district. Control alternatives include 
non-chemical and chemical treatment methods un- 
der an Integrated Pest Management program. 


In the past several years the Bonners Ferry Ranger 
District has conducted extensive inventories of nox- 
ious weeds on large portions of the ranger district. 
District personnel have searched all suitable and 
likely locations including travel corridors, camp- 
sites, and vulnerable habitats. The district has also 
been treating noxious weeds as directed in the Ida- 
ho Panhandle National Forest Weed Pest Manage- 
ment EIS. In addition to some chemical control of 
noxious weeds, the District has also released bio- 
logical control agents, completed roadside grass 
seeding and fertilization, disseminated noxious 
weed information to the public, and will, in 1996, 
implement a noxious weed free hay policy. 


Currently 41 sites with noxious weeds have been 
identified. Sites range in size from 0.24 acres to 33 
acres and total 335.55 acres. This area represents 
less than 0.08 percent of the four hundred ten thou- 
sand acres of National Forest System lands admin- 
istered by the Bonners Ferry Ranger District. It is 
important to note that on many of these sites the 
infestations of noxious weeds are still very scat- 


tered, and not all of these acres would require treat- 
ment. For example, the largest site is 13.8 miles of 
road in the Smith, Cow, and Beaver Creek drainag- 
es where infestations of primarily meadow hawk- 
weed can be found along the road. 


Thirty-eight of the forty-one sites are infested with 
meadow hawkweed (Hieracium pratense) ) or com- 
binations of meadow hawkweed and spotted knap- 
weed (Centaurea maculosa). Two of the sites are 
infested with Rush Skeleton Weed (Chrondrilla jun- 
cea), found in but three sites in Boundary County. 
One site, Roman Nose Lake #8, is infested with 
common tansy (Tanacetum vulgare). Ten other sites 
are infested with common tansy along with hawk- 
weed, spotted knapweed, or thistles. Three sites are 
infested with Dalmation toadflax (Linaria vulgaris). 


Twenty-five of the 41 sites are located in the Selkirk 
Ecosystem. Six sites are located in the Cabinet 
Mountains Ecosystem and seven sites are located 
in the Purcell Mountain ecosystem. Three sites are 
identified in the valley outside the three mountain 
ranges. 


This Final Environmental Impact Statement (FEIS) 
examines several alternatives for treating these 
sites. These alternatives include a variety of meth- 
ods including manual, cultural, and biological tech- 
niques. One alternative combines these non- 
chemical methods with herbicide applications. The 
effects of a no-action alternative are also analyzed. 


The preferred treatment varies by site and can in- 
clude either chemical, biological, or manual treat- 
ment or combinations of these treatments. A com- 
plete listing of preferred methods is provided in 
Table 2-1 (p. 2-6). 


This analysis also assumes that new sites will be 
discovered in key ecosystems and that these sites 
are in land types analyzed in this document. These 
new infestations are assumed to increase the total 
infestation acreage by twenty percent. The impacts 
analysis in Chapter 4 assumes that these sites are 
treated chemically. Chemicals will be applied with 
either backpack sprayers or 


for pumper units mounted in the back of pickup 
trucks. There are no aerial 
applications proposed. 


PURPOSE AND NEED FOR AC- 
TION 


Weed control is proposed in order to: 


1: Protect the natural condition and biodiversity 
of the Selkirk and Cabinet Mountain Ecosys- 
tems by preventing the spread of aggressive, 
non-native plant species that displace native 
vegetation. 


a Prevent or limit the spread of noxious weeds 
in key low elevation lakes in the Purcell 
Mountain ecosystem. Lakes to be protected 
are Brush Lake, Dawson Lake, Robinson 
Lake, and Smith Lake. Campgrounds at 
these lakes under Forest Service jurisdiction 
and other campgrounds within this ecosys- 
tem will be targeted for weed control action. 


3. Comply with Federal and State Laws regulat- 
ing management of noxious weeds. 


4. Cooperate with other agencies and private 
individuals, including adjacent landowners, 
concerned with the management of noxious 
weeds. 


The designation of a plant species as a "noxious 
weed," therefore a target of control efforts, involves 
a series of value judgements. The evaluation pro- 
cess is based in part on Federal and State Law. The 
Federal Noxious Weed Act of 1974 defines a “*nox- 
ious weed" as “a plant which is of foreign origin, is 
new to, or is not widely prevalent in the United 
States, and can directly or indirectly injure crops, 
other useful plants, livestock or the fish and wildlife 
resources of the United States or the public 
health"(P.L. 93-629). The Idaho Noxious Weed Law 
defines a "noxious weed" as any exotic plant spe- 
cies established or that may be introduced in the 
state which may render land unsuitable for agricul- 
ture, forestry, livestock, wildlife, or other beneficial 
uses and is further designated as either a state-wide 
or county-wide noxious weed (Idaho Code 24 Chap- 
ter 22). 


Both the Federal and State laws define "noxious 
weeds" primarily in terms of interference with the 
commodity uses of land. The ability of spotted knap- 
weed, common tansy, hawkweed, and other nox- 
ious weeds to interfere with agricultural production 
has been widely demonstrated. However, this defi- 
nition is also relevant for National Forest areas as 
these species interfere with the benefits of natural, 
complete ecosystems. 


The proposed treatment of 335 acres identified in 
the proposed action does not reflect the enormity of 
the noxious weed problem in Boundary County as 
a whole. Spotted knapweed has been estimated to 
infest about 50 thousand acres of land in Boundary 
County, and hawkweed is estimated at 25,000 acres 
in the County (Personal Communication, Rich De- 
Carlo, Boundary County Weed Supervisor, 1995). 
Once a site is infested by these weeds, the weed 
species often becomes dominant and greatly re- 
duces the native grass and forb community and the 
grazing value of the land. Several researchers have 
shown reductions in native species of up to 90 per- 
cent on sites infested with leafy spurge or knap- 
weed (Belcher and Wilson 1989; Tyser and Key 
1988; Watson et al. 1989; Willard et al. 1988). In- 
creasing concern has also been expressed about 
the impacts of noxious weeds on wildlife, water 
quality, natural diversity, and other non-commodity 
resources (Willard et al. 1988; Lacey et al. 1989). 


The Forest Service is also interested in increasing 
cooperation with State and local efforts to control 
noxious weeds. In Idaho, the Idaho Noxious Weed 
Law (Idaho Code 22 Chapter 24) states that is un- 
lawful for any individual to allow noxious weeds to 
propagate or go to seed on their land unless they 
are complying with an approved weed management 
plan. This law directs the counties to develop weed 
control districts to plan and implement weed control 
efforts. 


SCOPE OF THE PROPOSED AC- 
TIVITIES 


Treatment is proposed on 41 sites on the Bonners 
Ferry Ranger District of the Idaho Panhandle Na- 
tional Forests. Sites have been grouped into one of 
3 "geographical ecosystems". These geographical 
ecosystems are physically separated by either the 
Kootenai River or the Purcell Trench. Each of the 


-2 


three is associated with a particular mountain 
range, namely the Purcells, the Cabinets, or the 
Selkirks. Site maps are provided in Appendix A, and 
the areas are briefly described below. 


In many of the following descriptions, a distinction is 
made between the total area of an infested site and 
the area within the perimeter of the infested site that 
is occupied by weeds. On many sites the current 
infestation is concentrated in spots on the sites. 
Thus the treatment may be confined to a smaller 
area than that reflected in the total site acreage. 


Selkirk Mountain Ecosystem 


Site #1a. Snow Creek Road #402. 

T62N, R1W, Sec. 28-34; T62N, R2W, Sec 25, 
34, 35; T61N, R1W, Sec 1-3. Spotted knap- 
weed, meadow hawkweed, common tansy, 
perimeter of the infestation encompasses 
approximately 18 acres, while the major in- 
festation is about 10 acres. This is a right-of- 
way site along the main road in the Snow 
Creek drainage. 


Site #1b. Caribou Pass Road #1007 North 
T62N, R2W, Sec. 34-36. Meadow and orange 
hawkweed, perimeter of the infestation en- 
compasses approximately 4.8 acres. Site is a 
road right-of-way with sporadic populations 
on both sides of road. 


Site #1c. Caribou Pass Road #1007 South. 
T61N, R2W, Sec. 1 and 2. Meadow hawk- 
weed, perimeter of the infestation encom- 
passes approximately 0.73 of an acre. Site 
occurs along road right-of-way. 


Site #1d. Snow Ridge Road 2624. 
T62N, R1W, Sec. 34 Common tansy, mead- 
ow hawkweed, perimeter of the infestation 
encompasses approximately 7.3 acres, while 
the majority of the infestation measures 2.3 
acres. Site occurs along road right-of-way. 


Site #1e Roman Nose Lake #3 
T61N, R2W, Sec. 14. Common tansy, perime- 
ter of the infestation encompasses approxi- 
mately 0.24 acres. Site occurs within the Ro- 
man Nose Lake #3 basin. 


Site #2a, Cascade Creek Road #2411 and Lower 
Myrtle Creek Road #633 
T62N, RiW, Sec. 14, 22, and 23. Spotted 
kKnapweed, perimeter encompassess ap- 
proximately 7.3 acres. Site occurs along road 
right-of-way. Myrtle Creek is the municipal 
’ water source for Bonners Ferry. 


Site #2b. Myrtle Creek Road #633 

T62N, R1W, Sec. 18; T62N, R2W, Sec. 13, 14. 
Spotted knapweed, perimeter of the infesta- 
tion encompasses approximately 6.7 acres, 
with the actual infestation consisting of 
approximately 1.0 acre. Site occurs along 
road right-of way. Myrtle Creek is municipal 
water source for Bonners Ferry. 


Site #2c. Upper Myrtle Creek Road #633 and Two 
Mouth Lakes Trail. 
T62N, R2W, Sec. 20. Meadow hawkweed, 
perimeter of the infestation encompasses 
approximately 0.48 acres. Site occurs along 
road and trail right-of-way. 


Site #3a. Ball Creek Road #432. 
T63N, R1W, Sec. 22-24. Spotted knapweed, 
meadow hawkweed, perimeter of the infesta- 
tion encompasses approximately 6.3 acres 
with a net infestation of one acre. Site occurs 
along the road right-of way of the main road 
in the Ball Creek drainage. 


Site #3b. Upper Ball Creek Road #432 and Road 
#2411 
T63N, RiW, Sec. 19 and 20; T63N, R2W, 
Sec. 24-26. Meadow hawkweed, common 
tansy, perimeter encompasses 9.6 acres, 
while net acres measure approximately 1.5 
acres. Site occurs along road right-of-way. 


Site #4. Trout Creek Road #2426. 
T63N, R1IW, Sec. 7-11. Spotted knapweed, 
meadow hawkweed, perimeter encompass- 
es approximately 13.1 acres, net acres mea- 
suring approximately 2 acres. Site occurs 
along road right-of-way. 


Site #5. Trout Creek Cattle Allotment. 
T63N, RiW, Sec. 11. Meadow and orange 
hawkweed, spotted knapweed, common tan- 
sy, perimeter encompasses approximately 8 
acres. Site occurs within Ball Creek cattle 
allotment, an on and off allotment where 


there are extensive efforts to control weeds 
on the private grazing land. 


Site #6. Parker Ridge Trail. 
T64N, R1W, Sec. 8. Spotted knapweed, 
hawkweed, perimeter encompasses approx- 
imately 0.9 acres, while net acres measure 
approximately 0.5 acres. Site occurs along 
first 1.2 miles of trail right-of-way. 


Site #7. Long Canyon Creek Trail. 
T65N, R2W, Sec. 36. Canada thistle, com- 
mon tansy, meadow and orange hawkweed, 
perimeter encompasses approximately 0.5 
acres. Site occurs at trailhead parking lot and 
first 0.5 miles of trail right-of-way. 


Site #8a. Lower Smith Creek Road #281. 
T65N, R2W, Sec. 23, 27, 33, and 34. Spotted 
knapweed, meadow hawkweed, common 
tansy, perimeter encompasses approximate- 
ly 9.6 acres, while net acres measure approx- 
imately 2.5 acres. Site occurs along road 
right-of-way. 


Site #8b. Smith Creek Road #281, Beaver Creek 
Road #2545, Cow Creek Road 
Creek Road #655, Dead Cow Creek Road 
#3303, Shorty Pass Road #282, Saddle 
Pass Road #2454. 
T64N, R3W, Sec. 1-11; T65N, R3W, Sec. 33. 
Hawkweed, spotted knapweed, perimeter 
encompasses approximately 33 acres, while 
net acres measure 8 acres. Site occurs along 
road right-of-ways. 


Site #8c, Upper Smith Creek Road #281 and West 
Fork Road #2464. 
T63N, R3W, Sec. 3, 10, 11. Meadow hawk- 
weed, perimeter encompasses approximate- 
ly 17 acres, while net acres measure approxi- 
mately 2 acres. Site occurs along road 
right-of-way. 


Site #8d. Cow Creek Cattle Allotment. 
T64N, R3W, Sec. 5 and 6. Orange and mead- 
ow hawkwee3g, thistle, perimeter encompass- 
es approximately 6 acres. Site occurs within 
cattle allotment. Cow Creek drainage was se- 
verely burned over during the Trapper Creek 
fire. Much of the drainage is open and vulner- 
able to noxious weed invasion. The drainage 


is noted for the presence of fens and sensi- 
tive plants. 


Site #9. Saddle Pass North Road #2455 and Silver 
Creek Road 1007. 
T65N, R3W, Sec. 9-11, 14, 15, 21, and 22. 
‘Meadow hawkweed, perimeter encompass- 
es approximately 17 acres, while the net 
acreage measures approximately 4.5 acres. 
Site occurs along road right-of-way. 


Site #10 Saddle Pass Harvest units. 
T65N, R3W, Sec. 10 and 15. Meadow hawk- 
weed, perimeter encompasses approximate- 
ly 20 acres, while the net acre measures ap- 
proximately 2.25 acres. Site occurs in timber 
harvest units near the U.S./Canadian border. 


Site #11. Grass Creek Road #636. 

T65N, R3W, Sec. 7 and 8; T65N, R4W, Sec. 
12-14, 23, 26, 27, 34; T64N, R4W, Sec. 3 and 
4. Meadow hawkweed, perimeter encom- 
passes approximately 19.9 acres, while the 
net acreage measures approximately 3 
acres. Site occurs along road right-of-way on 
the main road in Grass Creek. The Grass 
Creek drainage is associated with the Grass 
Creek cattle allotment. There are several sen- 
sitive plant species in this drainage. 


Site #12. Grass Creek Gravel Pit 
T64N, R4W, Sec. 9. Meadow hawkweed, pe- 
rimeter of the infestation encompasses ap- 
proximately 2 acres. Site occurs within a 
gravel pit and the population density of the 
invader species is very concentrated. 


Site #13. Bog Creek 
T6SN, R4W, Sec. 9, 16, 17. Meadow hawk- 
weed, perimeter of the infestation encom- 
passes approximately 1.5 acres. A concen- 
trated population occurs at the site. 


Site #14. Boundary Creek Road #2450. 
T65N, R2W, Sec. 17 and 18; T65N R3W, Sec. 
13. Spotted knapweed, meadow hawkweed, 
perimeter of the infestation encompasses 
approximately 3.9 acres. Site occurs along 
Boundary Creek Road. 


Site #15. Lower and Upper Italian Roads and Har- 
vest Units. 


T65N, R2W, Sec. 15, 21, and 22. Meadow 
hawkweed, perimeter of the infestation en- 
compasses approximately 12.1 acres. Site 
occurs within timber harvest units and along 
access roads. 


Purcell Trench - Valley Sites 


Site #16. Stampede skeleton weed site. 
T6ON, R1W, Sec. 12. Skeleton weed, dalma- 
tion toadflax, meadow hawkweed, perimeter 
of the infestation encompasses approximate- 
ly 12 acres. Site is associated with BPA pow- 
erline right-of-way and dry site meadows. 


Site #17a. BPA powerline south. 

T6ON, R1W, Sec. 14, heavy infestation of dal- 
mation toadflax and spotted knapweed, pe- 
rimeter of proposed treatment area encom- 
passes approximately 2.4 acres. Site occurs 
along BPA powerline and is used for motor- 
cycle and ATV recreation. Treatment site is a 
source of weeds to adjacent trails system. 


Site #17b. Motor bike access. 
T6ON, R1iW, Sec. 14, spotted knapweed, pe- 
rimeter of the infestation encompasses ap- 
proximately 2.4 acres. Site occurs along a 
new access for motorbikes and ATV's. 


Cabinet Mountain Ecosystem 


Site #18. Katka, Roads #314, #2209, #2207,and 

#2662 
T62N, R2E, Sec. 36: T62N, RSE, Sec. 31; 
FOWN@ROE, Sec, o,0, 6; 9,19, 15, 21, 2c, 20, 
29, and 32. Spotted knapweed, hawkweed, 
and tansy, perimeter of the infestation 
encompasses approximately 24.7 acres. Site 
occurs along road right-of-way. 


Site #19. Boulder Creek Road #408. 
T61N, RSE, Sec. 31 and 32, hawkweed and 
common tansy, perimeter of the infestation 
encompasses approximately 2.9 acres. Site 
occurs along road right-of-way. 


Site #20. Boulder Meadows. 
T6ON, R3E, Sec. 20 and 21. Meadow hawk- 
weed, perimeter of the infestation encom- 
passes approximately 1.5 acres. Site occurs 


within a meadow identified as unique grizzly 
bear habitat. 


Site #21. Black Mountain, Road #274. 
T61N, R2E, Sec. 31; T60N, R2E, Sec. 5 and 
6, meadow hawkweed and common tansy, 
‘perimeter of the infestation encompasses 
approximately 6.3 acres. Site occurs road 
right-of-way. 


Site #22. Twenty Mile Road #408 West. 
T6ON, R1E, Sec. 1, 12; T60N, R2E, Sec 7. 
Meadow hawkweed and common tansy, pe- 
rimeter of the infestation encompasses ap- 
proximately 2.4 acres. Site occurs along road 
right-of-way. 


Site #23. Cabin Creek Road 
T61N, R2E, Sec. 8, 17, 18. Meadow hawk- 
weed, knapweed, perimeter of the infestation 
encompasses approximately 3.6 acres. Site 
occurs along road right-of-way. 


Purcell Mountain Ecosystem 


Site #24. Meadow Creek Roads ##229, #211, and 
Campground access road. 
T62N, R2E, Sec. 8; T63N, R2E, Sec. 2, 11-15, 
20, 24, & 32. Meadow hawkweed and spot- 
ted knapweed, perimeter encompasses 17 
acres, while net acres measure approximate- 
ly 1.5 acres. 


Site #25. Sinclair Lake Area. 

T64N, R2E, Sec. 3 and 10. Meadow hawk- 
weed and spotted knapweed, perimeter en- 
compasses approximately 3.2 of an acre, 
while net acres measure approximately 0.5 of 
an acre. Site occurs adjacent to the Moyie 
River and Sinclair Lake near a day use facility 
and a proposed interpretive site. 


Site #26. Brush Lake campground and day use 
access roads. 
T64N, R1E, Sec. 9, 15, 16, 21, and 22. Mead- 
ow hawkweed and common tansy, perimeter 
encompasses approximately 6.8 acres, net 
acres are approximately 1 acre. Treatment 
area is primarily along road right-of-way. 


Site #27. Robinson Lake 
T65N, R2E, Sec. 21. Meadow hawkweed, 
and common tansy, perimeter encompasses 
approximately 5.3 acres, while the net acres 
measure approximately 0.5 of an acre. Site 
occurs along access roads to the camp- 
ground and the boat launch. 


Site #28a. Copper Creek Campground Access 
T65N, R2E, Sec. 14. Spotted knapweed, pe- 
rimeter encompasses approximately 3.4 
acres, while the net acre measures approxi- 
mately 0.25 of an acre. Site occurs along the 
Copper Creek road. 


Site #28b. Copper Creek roads #2509 and #2511 
T64N, R2E, Sec. 1 and 2; T65N, R2E, Sec. 24, 
25, and 36; T65N, RSE, Sec. 30 and 31. Can- 
ada thistle, spotted kanpweed, and meadow 
hawkweed, perimeter encompasses approx- 
imately 14.5 acres, while the net acres mea- 
sure approximately 12 acres. Site occurs 
along roads and in timber harvest units along 
roads. 


Site #29. Smith Lake and campground access. 
T63N, R2E, Sec 30. Spotted knapweeed, 
common tansy, perimeter encompasses ap- 
proximately 1 acre, while net acres measure 
approximately 0.05 acres. Site occurs 
around the Smith Lake Campground. 


SCOPE OF THE ANALYSIS: CON- 
NECTED, CUMULATIVE, AND SIM- 
ILAR ACTIONS 


In the preparation of an EIS, a recurring issue is the 
extent or scope of the analysis required for a pro- 
posal. Regulations contained in 40 CFR 1508.25 
address the scope of the analysis and outline sever- 
al elements to be considered in the analysis of the 
proposed action. 


These regulations recognize that separate activities 
can combine and interact to increase impacts sig- 
nificantly beyond the effects of individual actions. 
For example, it is possible that the herbicide runoff 
from one spray site would not harm aquatic organ- 
isms; however, when combined with runoff from oth- 
er sites the total impact could be significant. As 
explained in 40 CFR 1508.25, these actions would 


be cumulative, and their cumulative impacts must 
be addressed. The possibility of cumulative impacts 
to valuable resources, such as water, human health, 
and wildlife is one reason these 41 sites are consid- 
ered in a single EIS. 


The regulations governing the scope of an EIS (40 
CFR 1508.25) also refers to the combined analysis 
of connected actions. For example, if a road were 
being built to access a timber harvest, then the road 
construction would be connected to the harvest. 
Timber harvest would not be possible in the ab- 
sence of the road construction, and the rationale for 
road construction would be diminished in the ab- 
sence of the timber harvest. Thus, the effects of 
these connected actions would be analyzed togeth- 
er. 


The actions proposed here are part of a larger pro- 
gram of noxious weed control on the Bonners Ferry 
Ranger District. This program includes monitoring 
and mapping of infestation sites, public education 
efforts, cleaning of equipment in certain situations, 
restoring disturbed areas that might otherwise facili- 
tate the establishment of exotic species, and other 
activities. 


The negative environmental impacts of these other 
program activities is small, and their primary effect 
is to forestall the types of activities proposed in this 
EIS. Therefore, discussion of these other control 
activities is limited in this EIS, except when an alter- 
native calls for greatly expanding the activity. 


The regulations in 40 CFR 1508.25 provide for the 
combined evaluation of similar actions that are rea- 
sonably foreseeable, such as those that share a 
common timing or geography. For example, it is 
possible that new noxious weed establishments 
may occur within the areas analyzed in this EIS. 
Prior to conducting additional control projects, the 
impacts of previous control projects will be consid- 
ered. 


SCOPE OF THE ANALYSIS: AL- 
TERNATIVES 


In determining the scope of the analysis, the Forest 
Service must consider three types of alternatives 
(40 CFR 1508.25(b)): the no-action alternative, oth- 
er reasonable courses of action, and mitigation 


-6 


measures not included in the proposed action. 
Chapter 2 considers possible alternatives for con- 
trolling weeds. Alternatives that have a reasonable 
likelihood of at least partial success are discussed 
in detail. A range of mitigation measures are also 
discussed for the alternatives. The impacts of the 
no-action alternative, as well as other alternatives, 
are discussed in the following chapters. 


SCOPE OF THE ANALYSIS: IM- 
PACTS 


Regulations contained in 40 CFR 1508.25(c) require 
that an EIS analyze three types of impacts: direct, 
indirect, and cumulative. Cumulative effects are de- 


scribed above in the discussion on cumulative ac- . 


tions. 


Direct effects are caused by the action and occur at 
the same time and place as the proposed action. 
For example, direct effects of herbicide application 
could include impacts on some non-target native 
plant species. Indirect effects caused by the action 
occur later in time or are removed in place. For 
instance, with the spread of noxious weeds, it might 
be reasonable to predict a change in vegetative 
composition with an eventual impact on native plant 
diversity. These and other reasonably foreseeable 
direct, indirect, and cumulative impacts are ana- 
lyzed in Chapter 4. 


SCOPE OF THE ANALYSIS: DECI- 
SIONS 


Proposals of this nature within National Forest Sys- 
tems involves two levels of decisions. 


The first level is the development of a Forest Plan 
that guides all resource management programs, 
practices, uses, and protection measures. The Ida- 
ho Panhandle National Forest Plan, the Forest Plan 
Final EIS, and the Record of Decision which were all 
published in 1987, consist of both forest-wide and 
area-specific standards and guidelines that provide 
for land uses under a given set of management 
constraints. For example, the Forest Plan provides 
the objective of noxious weed control based on inte- 
grated pest management conducted in cooperation 


with counties, other agencies, and private landown- 
ers. 


The second level occurs during the Forest Plan im- 
plementation. This level involves the analysis and 
implementation of management practices designed 
to achieve the goals and objectives of the Forest 
Plan. 


This EIS documents the analysis for a second level 
decision concerning the control of noxious weeds 
on Bonners Ferry Ranger District. The proposed 
action is not a general management plan. If the 
decisionmaker selects an action alternative, the ac- 
tivities will be implemented as soon as possible, and 
will most likely begin in late spring of 1996. 


WEED MANAGEMENT PHILOSO- 
PHY 


As noted in the previous section on “scope of the 
decisions", there are two levels of decisions involved 
in planning activities on National Forest Systems 
Lands. The first level is the Forest Plan, which pro- 
vides direction and standards for all resource man- 
agement. During this planning process, the Idaho 
Panhandle National Forests decided to use IPM (In- 
tegrated Pest Managment) principles in managing 
various pests. This decision derives from the regula- 
tions that implement the National Forest Manage- 
ment Act of 1976 (86 CFR 219.27 (3)) and calls for 
the use of IPM when dealing with forest pests. Be- 
cause the decision to implement an IPM program 
has already been made, it need not be revisited in 
this document. 


The second level of decision involves implementing 
the directions provided from the first decision level. 
In the present example, then, we must implement 
projects consistent with a policy or program of Inte- 
grated Pest Management. Implementation is made 
more difficult because there is no standard defini- 
tion of IPM (see, for example, several articles in the 
Journal of Pesticide Reform, winter 1989 issue). The 
Forest Service handbook on Forest Service Pest 
Management (FSH 3409.11, 6/86) gives the follow- 
ing definition of IPM: 


A decisionmaking and action process incorporat- 
ing biological, economic, and environmental 


-7 


evaluation of pest-host systems to manage pest 
populations. 


A variety of activities could be carried out under an 
IPM program. Although some people consider IPM 
to be an absolute alternative to pesticide applica- 
tion, in reality, IPM provides a full range of manage- 
ment alternatives. Many of these alternatives are 
non-controversal and have minimal adverse envi- 
ronmental impact. For example, inventory and mon- 
itoring activities, public education, and pulling of 
small weed infestations are all important phases in 
pursuing an IPM program on the Idaho Panhandle 
National Forests. The inventory results gathered on 
the Bonners Ferry Ranger District have been shared 
with the public during the scoping process. In addi- 
tion, public education efforts are emphasized and 
are currently being expanded. These parts of an 


IPM program typically do not require extensive anal- 


ysis in an environmental document such as this EIS. 


As the Forest Service implements control projects 
on specific sites, the agency must choose specific 
treatment methods. Some of the treatments, such 
as pesticide application, may have potential ad- 
verse impacts that must be considered in the selec- 
tion process. The analysis of potential adverse ef- 
fects is provided in an environmental document 
such as this EIS. NEPA regulations also require that 
this EIS consider a full range of treatment alterna- 
tives consistent with an IPM program. 


An IPM program also requires that the Forest priori- 
tize treatment activities. The overall Forest strategy 
is to contain weeds in currently infested areas and 
to prevent the spread of weeds to susceptible but 
generally uninfested areas. The Forest also at- 
tempts to eradicate small infestations in generally 
uninfested areas. The Forest has had a weed man- 
agement strategy in place since 1989 when the Fi- 
anl ElS, Weed Pest Management, Idaho Panhandle 
National Forests 

was completed. This guiding strategy reference is 
included in this document as Appendix F. 


Currently the largest area on the Bonners Ferry 
Ranger District as well as the Idaho Panhandle Na- 
tional Forest that has limited populations of noxious 
weeds is the Selkirk Mountain Ecosystem and por- 
tions of the Cabinet Mountain Ecosystem. However, 
within these ecosystems, there are a number of 
open, grassy meadows and riparian and wetland 


1 


habitats that would provide excellent weed habitat 
even with no site disturbance. The challenge of an 
IPM program for noxious weeds is to keep these 
areas weed free. 


Under an IPM program, prevention strategies are 
commonly recognized as the best way to avoid the 
impacts of noxious weeds and the need for more 
costly treatment at a later date. Prevention of weed 
spread to these uninfested areas is an important 
aspect of our ecosystem management. Prevention 
measures could include the promotion of weed-free 
forage by all back-country users. The Forest Service 
will be requiring weed-free forage in other back- 
country areas. 


An emphasis on the use of weed-free forage is not 
intended to ignore other sources for the spread of 
weeds. Many drainages are accessed by Forest 
Service and County roads, most open at least a 
portion of the year, if not year round. Vehicles carry- 
ing noxious weed seeds from infested areas to unin- 
fested areas can and do contribute to the spread of 
weeds. 


FUTURE ACTIVITIES 


As noted in the introductory sections of this chapter, 
District personnel have conducted extensive recon- 
naissance, monitoring, mapping, and other data 
collection efforts to determine the extent of weed 
infestation on the Bonners Ferry Ranger District. 
Several conclusions can be reached from these ef- 
forts. 


The control of species such as hawkweed on the 
Bonners Ferry Ranger District in the Selkirk and 
Cabinet Mountain Ecosystems are reaching the 
"now or never" stage. The extent of infestation of 
meadow hawkweed on some of the other districts 
on the Idaho Panhandle National Forests is a case 
in point. When the size of infestation exceeds sever- 
al hundred acres, eradication and even contro! be- 
comes unfeasible because of logistic, financial, and 
environmental constraints. 


An aggressive control program can reduce the in- 
festation of weeds in the Selkirk and Cabinet Moun- 
tain Ecosystems. On successive years treatment 
needs should be reduced as weeds are eradicated 
or reduced on individual sites. 


-8 


In future years it is possible that new infestations of 
weeds will be discovered. Many of these may be 
small enough to control manually. However, others 
may require more aggressive treatment. As a worst 


case, this EIS assumes that the infestation acreage 
and treatment increases by 20 percent over current 
levels. 


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CHAPTER Il 
ALTERNATIVES 


INTRODUCTION 


This chapter: 


ih. describes the internal scoping and the public 


involvement process used to develop the al- 


ternatives, 
28 identifies the environmental issues and con- 
cerns, 
3. describes and compares the alternatives, 
4. identifies monitoring proposals. 
ALTERNATIVE DEVELOPMENT 
PROCESS 


INTERNAL SCOPING AND PUBLIC IN- 
VOLVEMENT 


The public has been involved throughout the devel- 
opment of the EIS. Public comment has helped de- 
fine the issues and develop the range of alternatives 
for accomplishing management goals and objec- 
tives. 


Public comment was solicited formally with a notice 
published in the Federal Register that indicated our 
intent to prepare an EIS. Several articles published 
and news features in local newspapers solicited 
public input on the weeds in the Forest issue. The 
project file contains copies of these articles. In addi- 
tion, meetings were held on a one-on-one basis with 
interested individuals. 


It is apparent that control of exotic species is an 
important issue with many segments of the public. 
The Forest Service is but one of many agencies and 


organizations with an interest in controlling the im- 
pacts of these species. 


ISSUES 


Analysis of public and internal input resulted in the 
following list of issues that guided the development 
of the alternatives. Each issue is stated as a ques- 
tion, often general in nature, and is followed by a 
synopsis of the specific comments received from 
the public. A brief discussion of how the issue is 
addressed in the EIS follows the synopsis of public 
comments. 


1. What are the potential impacts of noxious 
weeds on resources such as ecological commu- 
nities and processes; threatened, endangered, 
or sensitive plants and animals; soils; water qual- 
ity; aesthetics; wildlife and fish; and recreational 
opportunities? 


Most commenters viewed noxious weeds as a po- 
tential problem in the National Forests. Many have 
seen the impacts of non-native plants on vast areas. 
. One commenter questioned our use of the terms 
"native" and "noxious" species. 


The Environmental Consequences section of this 
EIS (Chapter 4) discusses the impacts of noxious 
weeds on various resources. 


2. What are the potential impacts of weed con- 
trol methods on other forest resources as listed 
in issue 1? 


Although most commenters acknowledge the po- 
tential threat of noxious weeds, some question 
whether the use of herbicides in the Forest would be 
appropriate. Some commenters were concerned 
about the impact of herbicides on the biological 
resources. Others advocated a full range of control 
measures, including herbicide use, to reduce the 
threat. 


A full range of alternatives is developed in this chap- 
ter, and the environmental, social, and economic 
consequences of the alternatives are presented in 
Chapter 4. 


3. How would the weed management methods, 
particularly herbicide application, affect human 
health? 


Some commenters were specifically concerned 
about the impact of herbicide spraying on human 
health and on traditional hunting and gathering ac- 
tivities. 


The potential impacts of herbicide application on 
human health have been analyzed extensively. 
Chapter 4 presents the results of this analysis. 


ALTERNATIVES CONSIDERED IN. 


DETAIL 


BRIEF OVERVIEW 


Four alternatives were developed to address the 
issues raised by public and agency comment. 
These alternatives represent the range of control 
methods currently available for treatment of noxious 
weeds. In addition to the No Action alternative, two 
of the action alternatives involve only non-chemical 
methods of control. The comparison of these alter- 
natives with the alternative that includes chemical 
use sharply defines the issue of possible human 
health and environmental impacts of herbicide use. 
The analysis of the No Action alternative addresses 
the impacts of the unchecked expansion of noxious 
weeds in the Forest. 


The four alternatives are outlined below with a brief 
discussion of the major issues relevant to these 
alternatives. Each of these alternatives, except the 
No Action alternative, involve a combination of treat- 
ment methods. These treatment methods are dis- 
cussed in greater detail in the following sections. 


MONITORING AND MITIGATION FEA- 
TURES COMMON TO MORE THAN ONE 
ACTIONALTERNATIVE 


lf a decision is made to apply herbicides, all chemi- 
cal applications would be conducted in accordance 


2-2 


with label instructions. In addition, no spray applica- 
tions would be made when the wind speed exceeds 
8 mph. All applications would be directed by an 
applicator certified in accordance with U.S. EPA and 
State of Idaho standards. All applications would be 
made with ground based equipment including truck 
mounted sprayers and backpack sprayers. Informa- 
tion on spills, spill avoidance, and the handling of 
pesticides (including herbicides) is contained in Ap- 
pendices C and D. Compliance with these provi- 
sions would ensure that pesticides are applied in 
accordance with State of Idaho Best Management 
Practices for pesticide use. 


Post-spray vegetation monitoring would be con- 
ducted on representative sites. Monitoring sites 
would be selected prior to treatment, then reviewed 
yearly. 


ALTERNATIVE 1: No Action 


This alternative would result in a change in the cur- 
rent noxious weed control activities on the Bonners 
Ferry Ranger District. Control activities would be 
restricted to minimal amounts of manual control. 


The comparison of this alternative with the active 
control alternatives highlights the potential effects of 
uncontrolled weeds on the forest environment. The 
No Action alternative also provides a baseline for 
analyzing the possible adverse impacts of the con- 
trol alternatives. 


ALTERNATIVE 2: Manual 
Control 


and Cultural 


This alternative was developed in response to the 
possible impacts of treatment methods, such as 
chemical control, on non-target plants, and human 
health. Under this alternative, treatments such as 
hand pulling, clipping, and mowing would be imple- 
mented to destroy or limit reproduction of the weed 
species. Cost effectiveness and environmental/ 
human health trade-offs can be compared between 
this alternative and other proposed alternatives. 


ALTERNATIVE 3: Manual, Cultural and Bi- 
ological Control 


This alternative was developed in response to many 
of the same issues that prompted the development 
of Alternative 2. Under this alternative, treatments 
previously mentioned under Alternative 2 would be 
supplemented with the release of biological agents 
such as parasites, predators and pathogens that 


have shown some promise in reducing weed infes- 
tations. This alternative allows us to examine the 
possible impacts of introducing species that show 
some promise in bringing exotic plant species into 
better balance in these ecosystems. At the present 
time relatively few biological control agents are 
available that are effective against the weed species 
of concern here. However, some agents have 
shown promise in controlling Canada thistle. Cost 
effectiveness and environmental trade-offs between 
this alternative and other alternatives can be exam- 
ined. 


ALTERNATIVE 4: Manual, Cultural, Biologi- 
cal and Chemical Control 


Under this alternative a full range of treatments 
would be considered for each site. Herbicide pre- 
scriptions would be consistent with or more restric- 


tive than product label requirements. If an herbicide | 


is used in the annual floodplain, the Forest Service 
would only apply a herbicide formulation approved 
by the U.S. Environmental Protection Agency for 
direct applications to water. In no case would the 
Forest Service apply herbicide directly to water. 


Under.this alternative approximately 174 pounds of 
2,4-D, 23 pounds of dicamba, 12 pounds of clopy- 
ralid, and 46 pounds of picloram would be applied 
to project areas identified for treatment with herbi- 
cides. 


This alternative allows us to compare the cost and 
effectiveness of the chemical use with the potential 
environmental and health effects of this and other 
methods. 


METHODS AND _ PRACTICES 
AVAILABLE UNDER EACH ALTER- 
NATIVE 


The following section describes the control meth- 
ods available under the alternatives reviewed in the 
previous section. 


Manual Control: 


Manual control methods range from hand pulling 
and grubbing with hand tools to clipping or cutting 
the plants with scythes or other cutters. If sufficient 
root mass is removed, the individual plant can be 
destroyed. Cutting the plants will reduce reproduc- 
tion of perennial plants and weaken its competitive 


advantage by depleting carbohydrate reserves in 
the root systems. 


Cultural Control: 


Cultural control generally involves manipulating a 
site to increase the competitive advantage of desir- 
able species and decrease the competitive advan- 
tage of undesirable species. Manipulations could 
involve transplanting native plants to shade out 
weedy species or covering weed-seed contaminat- 
ed soil with a layer of uncontaminated soil. Seeding 
grass species and applying fertilizer on site where 
ground cover is sparse could help to culturally con- 
trol weeds. 


Biological Control: 


Biological control is the use of biotic agents to at- 
tack undesirable plant species. Populations of na- 
tive species are generally limited in part by herbivo- 
rous and pathogenic organisms as well as by 
competition for nutrients and moisture. Non-native 
vegetation has had a dramatic impact in many parts 
of the West because it has been introduced without 
biological control agents present. The introduction 
of these control agents is viewed by most experts as 
the best long-term solution to the noxious weed 
problem where there are large, widespread popula- 
tions of a given species. 


Currently, two biocontrol agents, Urophora affinis 
and Urophora quadrifasciatus, are present in some 
knapweed infestations on the district. In sufficient 
concentrations these seedhead flies can reduce 
seed production by 50 to 90 percent. However, 
knapweed is such a prolific seed producer that 
these organisms have had no effect on the density 
of the infestations and little effect on its rate of 
spread. 


Several biological agents are currently being intro- 
duced into the United States for the control of Cana- 
da thistle. Ceutorhynchus litura is a stem mining 
weevil which attacks the young Canada thistle 
plants in early spring. The stem mining larvae inter- 
nally attack the elongating stem in early summer. As 
the larvae develop they begin to create numerous 
exit holes near the root crown leaving the plant suc- 
ceptible to a variety of plant pathogens. Under ideal 
circumstances (soil, size of infestation, climate etc.) 
population densities may be reduced up to 90 per- 
cent depending on the number of weevils released 
at the infestation (Rees, 1992). 


Urophora cardui is a stem and shoot gall fly which 
attacks Canada thistle. Adults deposit their eggs on 
the axil of the stem in early summer. As the larvae 
develop they burrow into the stem creating a walnut 
size bowl or gall. The gall formation diverts the nor- 
mal nutrient translocation away from the metobolic 
and reproductive systems of the plant. As a result 
flowers develop abnormally, and seed production is 
reduced. 


Climatic and habitat conditions are expected to play 
a major role in the success of biological control 
agents. The adaption of these biocontrol organisms 
to the habitats currently infested by Canada thistle 
remains an unknown. 


Chrysolina quadrigemina is a defoliating beetle 
which attacks St. Johnswort or goatweed. This defo- 
liating beetle has successfully reduced the density 
of this weed in locations where fall temperatures are 
mild and the rainfall is abundant. There have been 
introductions of this beetle annually on the Bonners 
Ferry Ranger District since 1990. The beetle is thriv- 
ing and is found at several locations on the district. 
There is evidence of St. Jonnswort populations suf- 
fering the effects of defoliation by this beetle. 


It should be noted that biological control agents will 
not completely eradicate a noxious weed infesta- 
tion. Rather, a biological control strategy would al- 
low the weed species to spread, though at lower 
density, through all suitable habitats in the forest. 


Chemical Control 


Four herbicides, 2,4-D, dicamba, clopyralid, and pi- 
cloram, were considered for application on various 
sites. Three chemicals were approved for use in the 
1989 IPNF Weed Pest Management EIS (2,4-D, gly- 
phosate, and picloram). 2,4-D is a herbicide with 
very little persistence in the environment. @,4-D has 
several formulations, some of the common brand 
names include, Weed-B-Gon, HiDep, and Solution. 
The herbicide has low toxicity to aquatic species 
and several formulations are approved for use in 
water and near water. At application rates of 1 to 1.5 
pounds per acre 2,4-D exhibits good control of 
knapweed with repeat applications and moderate 
control of goatweed, houndstongue, sulfur cinque- 
foil, and Canada thistle. 


Dicamba (the active ingredient in Banville) is a broa- 
dleaf herbicide that is readily absorbed by leaves 
and roots and is concentrated in the metabolically 
active parts of the plants. Dicamba is effective 


against a similar range of weed species as 2,4-D at 
similar application rates. However, dicamba is 
somewhat more persistent than the 2,4-D herbicide 
and thus provides somewhat longer control of sus- 
ceptible species. 


Picloram (the active ingredient in Tordon) controls a 
variety of broad-leaved weed species, including all 
the weeds species of concern here. Picloram is gen- 
erally applied at rates of one-quarter to one-half 
pound per acre. However, picloram’s combination 
of mobility and persistence have generated concern 
over possible ground-water contamination. Possi- 
ble environmental impacts are compared between 
this method and the other chemical and non- 
chemical control methods. 


Clopyralid is a relatively new herbicide that is very 
selective and is toxic to some members of only three 
plant families: the composites, the legumes, and the 
buckwheats. Clopyralid is the active ingredient in 
Transline, and along with 2,4-D, is one of two active 
ingredients in Curtail. At application rates of one- 
quarter to one-half pound per acre, clopyralid is 
very effective against knapweed, the hawkweeds, 
and Canada thistle. However, it does not control any 
of the other weed species of concern. Clopyralid is 
more persistent than 2,4-D and dicamba, but less 
persistent than picloram. 


The selective nature of clopyralid make it an attrac- 
tive alternative on sites with non-target species that 
are sensitive to the other herbicides. Clopyralid has 
soil-mobility characteristics comparable to piclo- 
ram, so the possibility of ground-water impacts 
must be addressed. 


Control with a combination of chemical 
and non-chemical control 


Site conditions such as vegetation types, soil types, 
and infestation levels vary significantly on some 
sites under consideration in this EIS. Therefore a 
combination of chemical and non-chemical meth- 
ods may be selected for some sites. The selection 
of a herbicide alternative for a site would not prevent 
the application of manual methods either concur- 
rently, or as a follow-up treatments, on remnant 
weeds on a Site. 


Control with mixtures of the herbicide Pi- 
cloram and 2,4-D 


Some control specialists treat several noxious weed 
species with mixtures of 2,4-D and picloram. Use of 


a mixture is done to reduce the quantity of the piclo- 
ram to half of what is normally applied, thus reduc- 
ing the amount of effects on non-target species. 


ALTERNATIVES CONSIDERED 
BUT NOT GIVEN DETAILED STUDY 


Glyphosate Control 


Glyphosate is a non-selective, broad-spectrum her- 
bicide that is absorbed by leaves and translocated 
throughout the plant. Glyphosate has little soil activ- 
ity and its absorption by roots is minimal to non- 
existent. 


Due to its non-selectivity, it tends to eliminate both 
desirable and undesirable vegetation. Even if desir- 
able vegetation is reseeded, hawkweed and other 
noxious weeds maintain their competitive advan- 
tage. In general, noxious weeds are aggressive pio- 
neer species that are well adapted to disturbance. 
For example, knapweed seed can remain viable for 
over 10 years in the soil, and this seedbank provides 
a ready source for reinfestation. 


Control with grazing 


Grazing by sheep and goats provides another non- 
chemical alternative of control that may be applica- 
ble to large infestations of some noxious weed spe- 
cies. However, given the small, scattered nature of 
these infestation and their isolated locations, control 
through grazing becomes quite unfeasible. Grazing 
is relatively ineffective as a control technique on 
small infestations. Many plants would be skipped in 
these small or scattered infestations, thus requiring 
some followup treatment. Grazing can be used ap- 
propriately in areas with large infestations on 
commodity-production lands where some econom- 
ic return can be gained on land that would other- 
wise be unproductive. 


Control of Other Exotic Species 


The Forest Service acknowledges that other exotic 
species exist within the Forest. Dominant species 
include: Dactylis glomerata (Orchard grass), 
Phleum pratense (Common timothy), Poa pratensis 
(Kentucky bluegrass) and Trifolium spp. (Clover). 
Many of these were intentionally introduced by 
seeding activities for erosion control. These species 
generally inhabit small areas. Under ideal circum- 


stances these species would not be present in the 
Forest. Fortunately, these species are relativiey 
non-aggressive and grazing by wild ungulates and 
domestic livestock has suppressed them. Eradica- 
tion of these non-native species would require in- 
tensive soil disturbance practices frequently seen in 
farming Communities across the West. The Forest 
Service will continue efforts to keep these species 
from spreading. These efforts include, for example, 
revegetating disturbed areas with appropriate na- 
tive species to reduce the potential impact of non- 
native species when feasible. 


TREATMENT METHODS CONSID- 
ERED FOR EACH SITE 


Table 2-1 lists the alternatives considered for each 
site. A number of sites were divided into two to four 
sub-sites, labelled A, B, C and D. Sites were sub- 
divided where characteristics such as variation in 
treatment needs, type of infestation, soil type, or 
other factors varied across the site and affected the 
control prescription. Application of picloram and 
clopyralid was not considered for sites or sub-sites 
where label requirements for depth to ground-water 
and soil type could not be met. 


Biological control was considered only for Canada 
thistle and St.John’s wart (goatweed), because of 
the unavailability of effective biological control 
agents for other weed species at this time. Burning 
was only considered for sites that were surrounded 
by water and where the native vegetation was suffi- 
ciently sparse that it would not be burned when 
treating the target species. 


RATIONALE FOR THE SELECTION 
OF THE PREFERRED CONTROL 
METHOD(s) 


In the preferred alternative, the Forest Service has 
attempted to design the most effective program 
possible within the environmental, economic, legis- 
lative, and regulatory constraints governing the 
management of National Forest lands. As indicated 
in the introduction, a principal goal of the Forest 
Service is to protect the biological integrity of the 
Selkirk and Cabinet Mountain Ecosystems by con- 
trolling aggressive non-native species. The Forest 
Service is not interested in conducting projects that 
only give the illusion of control. Furthermore if these 
control projects and this overall program cannot be 
demonstrated to protect biological integrity in these 























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2-7 


ecosystems, the FS does not intend to undertake 
them or to continue them once undertaken. 


When presenting the preferred alternative it is ap- 
propriate to explain the rationale used in selecting 
the preferred methods for treatment sites. Any se- 
lection involves a series of tradeoffs. We will attempt 
to explain how we made these tradeoff’s in design- 
ing the preferred alternative. 


It is clear that our program of controlling non-native 
species in the Selkirk and Cabinet Mountain eco- 
systems has been successful to date. Where the 
existing program has targeted control, the district 
has worked aggressively to limit the spread of nox- 
ious weeds, The 1989 EIS targeted areas in the 
Selkirks to a greater extent than other areas on the 
district. When compared to the Selkirk Mountain 
ecosystem, the population of noxious weeds in the 
Purcell Ecosystem is at least 100 fold greater. There 


are three other reasons why the Selkirk ecosystem — 


has far fewer noxious weeds as compared to the 
Purcell Mountain ecosystem. One is that the Selkirk 
Crest probably acts as a barrier to wind born seeds, 
thus drastically limiting an invasion to the eastside 
of the Selkirks even though the prevailing winds in 
the area are from the southwest. A lack of roads 
connecting east to west is also a consideration. 
Secondly, funding was limited, and the district 
placed a higher priority on treating weeds invading 
the Selkirks. Thirdly, there are several adjacent 
landowners on the west side of the Selkirks that 
have large farms and have effective weed control 
programs on there own land. 


The difficult decision now facing the Forest Service 
is the direction to take the noxious weed program. 
Although 4 alternatives are examined in this EIS in 
order to elaborate the decision space, there seem to 
be, in reality, only two basic choices. The first is to 
call off the effort to control these exotic species. 
Included in this first option are alternatives that are 
tantamount to calling off the effort because we can- 
not expect the budget to implement fully the alterna- 
tive (i.e., manual control) to contain the spread of 
weeds. The second option is to implement an ag- 
gressive control effort including the use of herbi- 
cides not identified in the 1989 EIS. 


The following sections of this Chapter and Chapter 
4 discuss in greater detail the environmental conse- 
quences of a no action alternative and an aggres- 
sive control program relying in part on chemicals. 
The impacts of intermediate control alternatives are 
also discussed. 


2-8 


In the remainder of this section the selection of par- 
ticular methods as part of a more aggressive pro- 
gram is discussed. 


The preferred alternative, Alternative 4, includes the 
herbicide picloram. This herbicide is very effective 
against most of the weeds currently infesting this 
area. However, several concerns are frequently 
raised with picloram. It is relatively persistent in the 
environment; it can affect a number of non-target 
species; and it can move from the site of application 
in some soil types. 


Moderate persistence is not in itself an undesirable 
property when combatting noxious weeds. All of the 
weed species of concern produce seeds which can 
remain viable for many years in the soil. Thus non- 
persistent herbicides must be reapplied very fre- 
quently in order to control the regular emergence of 
weed seedlings from the soil seed bank. Frequent 
reapplication of herbicides has the disadvantage of 
increasing human exposure as well as increasing 
off-site drift. Although these factors can be con- 
trolled they must be considered in our decision. 


In order to minimize impacts to non-target species 
and the possibility of migration through the soil, the 
application of picloram is limited to sites with resis- 
tant native species and soils that prevent leaching. 
The amount of picloram applied can be reduced in 
half with the addition of 2,4-D, thereby reducing 
effects to non-target species. Clopyralid can be 
used where control of knapweed or hawkweed is 
desired while protecting sensitive non-target spe- 
cies. However, clopyralid is not effective against 
most other weed species and requires more fre- 
quent application to control knapweed and hawk- 
weed. It also has similar soil mobility to picloram. 


On sites with soils more prone to leaching, less 
persistent chemicals such as 2,4-D or dicamba can 
be used. Some formulations of 2,4-D have been 
approved by the U.S. EPA for application to the 
edge and even over water. Only 2,4-D would be 
applied in the annual flood plain (after water levels 
have receded). The rapid degradation of this com- 
pound (2 to 4 weeks) would ensure that no chemical 
is available in the following spring runoff. 


Dicamba would be used in other areas beyond the 
annual flood plain where picloram and clopyralid 
cannot be used because of label restrictions and 
concerns about soil mobility. Dicamba is more per- 
sistent than 2,4-D and has the advantage of greater 
effectiveness against some species. 


The goal of this program is to erradicate or control 
most of the noxious weed species from these eco- 
systems. A possible exception is Canada thistle. 
Canada thistle is established in many locations and 
is a difficult plant to control because of its rhizoma- 
tous root system and prolific seed production. The 
preferred alternative is based on a two-pronged ap- 
proach to this weed. We would attempt to eliminate 
many of the small infestations while containing the 
larger infestations with biological control agents 
and perimeter applications of herbicide. In this man- 
ner we hope to keep this weed confined while deter- 
mining the effectiveness of biological control. 


MONITORING 


Sampling methods enable the ready collection and 


computer storage of a variety of data on a particular . 


site. Variables that can be recorded include the 
plant species, the percent of total vegetation, fre- 
quency of the species, and biomass of individual 
species. 


Post-spray vegetation monitoring would be con- 
ducted on representative sites. Monitoring sites 
would be selected prior to treatment, then reviewed 
yearly. The effectiveness of treatment and its impact 
on non-target species would be monitored. 


COMPARISON OF THE ALTERNA- 
TIVES CONSIDERED IN DETAIL 


This section presents a comparison of alternatives 
by issue. This section also presents an estimate of 
the costs of the alternatives. 


ISSUE 1: IMPACT OF NOXIOUS WEEDS ON RE- 
SOURCES 


As documented in Chapter 4, noxious weeds can 
significantly impact the species diversity on infested 
sites. On heavily infested sites, aggressive species 
can comprise as much as 90 percent of the plant 
biomass. In addition, the elimination of some native 
species has been documented on such sites. 


Knapweed, tansy, hawkweed, Canada thistle and 
the remaining species of concern could have dev- 
astating impacts on riparian zones, grassland and 
open forest habitat, critical components in these 


re, 


ecosystems. Once established on a site, particularly 
a sunny, dry site, knapweed quickly becomes domi- 
nant even in the absence of disturbance. As native 
species decrease, the forage available for various 
wildlife species is reduced. There has been little 
research to document decreases in wildlife popula- 
tions with increasing noxious weed infestations. 
Such research is very difficult to conduct. Some 
wildlife species such as deer and elk can also shift 
grazing patterns, at least to a limited extent. It is 
certainly the case that use by big game animals has 
increased dramatically on some sites where nox- 
ious weeds have been treated (Thompson 1990). 


The impact of noxious weeds on other resources 
under the various alternatives is directly related to 
the effectiveness of the alternatives in controlling 
the spread of the weed. The control effectiveness of 
the alternatives is reviewed briefly below. 


The No Action alternative would allow noxious 
weeds to increase unchecked on these sites. It is 
very likely that the weeds would spread to new sites 
in the forest, as has already occurred on thousands 
of infested acres within the Purcell Mountain eco- 
system. Knapweed is relatively brittle, which allows 
seedheads to break off and cling to folded rafts, 
manty packs, backpack frames, boot laces, animal 
hair, etc. Some weed species also spread vegeta- 
tively. Portions of roots and or mature seeds could 
eventually spread to the edge of unstable stream 
banks and be carried downstream to start new in- 
festations. Under this alternative, the impacts of 
noxious weeds on other resources would increase 
as the size and number of infestations increased. 


Alternative 2 relies solely on manual and cultural 
control. If conducted 2 or more times per year on 
each site, a diligent program of manual and cultural 
contro! could prevent seed production of weeds. 
However, some weed species could not be eradi- 
cated because of their extensive root system which 
allows continual resprouting. This control regimen 
would have to be repeated annually for an indefinite 
period. 


With intensive manual and cultural control, the im- 
pacts of noxious weeds noted above, could be 
largely avoided. However, the difficulty of carrying 
out such an intensive control program should not be 
underestimated. Sufficient resources must be com- 
mitted to carry out the program annually. If the site 
were left untreated for a year or two, noxious weeds 
could quickly reassert dominance. The chance of 
spread to new sites would again increase. 


Alternative 3 combines biological control with man- 
ual and cultural control methods. Under this alterna- 
tive biological control would replace manual control 
on most Canada thistle sites. Biological control 
could reduce the competitiveness of Canada thistle 
in these ecosystems. Biological agents Ceutorhyn- 
chus litura (Stem mining weevil) and Urophora car- 
dui (gall fly) can reduce population density of Cana- 
da thistle up to 90 percent under ideal 
circumstances (Rees 1992). Biological control will 
not compeletely eradicate Canada thistle infesta- 
tions. It is also not known whether these biological 
agents will establish under the climatic conditions of 
North Idaho. 


Alternative 4 combines all available control meth- 
ods. Application of the herbicides 2,4-D, dicamba, 
clopyralid, and picloram would be combined with 
manual, Cultural and biological control. This alterna- 
tive can effectively prevent the spread of exotic 


weeds and the resulting impacts discussed under 


the No Action alternative. Low persistent herbicides 
such as 2,4-D and dicamba may require repeated 
treatments in following years until the infestation 
sizes and densities are reduced. Since most of the 
moderately persistent herbicides would remain in 
the upper 4 to 6 inches of soil, some resprouting of 
plants could occur from deep roots, particularly in 


areas that are missed or lightly sprayed. Sites with 
mature weeds likely harbor large numbers of seeds 
that remain viable for many years. Followup treat- 
ment may be necessary as new seedlings emerge. 


A major difference among the herbicides would be 
the frequency of respray. 2,4-D and dicamba are 
herbicides with low persistence, and annual respray 
would likely necessary to control newly emerging 
plants. In addition, higher rates must be used than 
with the other two chemicals (one pound versus 
one-quarter to one-half pound per acre). Picloram 
could remain effective for 1 or 2 years against knap- 
weed. A small amount of follow-up spraying might 
be necessary to control skips in the treatment. This 
would typically involve less than 20 percent of the 
original treatment area. 


Clopyralid is more persistent than 2,4-D and dicam- 
ba but less persistent than picloram. Two years of 
knapweed control could be possible with clopyralid, 
but it is likely that annual respraying would be re- 
quired over a larger area than with picloram. 


Table 2-2 summarizes the risk of spread of noxious 
weeds under the various alternatives. 


Table 2-2--Relative risk of the spread of noxious weeds. 


Alternative 1: No 
Action 


Highest risk of spread of any of the alternatives. 


Greatest risk that new invading species would find a place 
establish populations and spread. 


Alternative 2: Manu- 
al & Cultural 


Alternative 3: Manu- 
al, Cultural & Biolog- 


Low risk if carried out at least three times per year on an annual basis. Risk of 
vegetative spread may be higher than with herbicide control. 


Low to moderate risk if manual and cultural control is carried out at least three 
times per year on an annual basis. Moderate risk of vegetative spread if climatic 


ical conditions are not suitable for the biological agents. 


Alternative 4: Manu- 
al, Cultural, Biologi- 
cal & Chemical 

for continued spread. 


ISSUE 2: IMPACT OF THE CONTROL ALTERNA- 
TIVES ON THE ENVIRONMENT 


The impact of increasing weed infestation on other 
resources is elimination of some species from given 
sites and reduction in species diversity. The No Ac- 
tion alternative would have no other environmental 
impacts. 


Alternative 2, the Manual and Cultural Alternative 
would have little physical impact on other resourc- 
es, Ground disturbance would be quite localized. 


The two biological agents proposed for the control 
of Canada thistle have undergone extensive host 
specificity testing. Urophora cardui (gall fly) is very 
host specific toward Canada thistle. However, two 
other non-native thistles, Cirsium vulgare (Bull this- 
tle) and Carduus acanthodes (Plumeless thistle) 
showed incidental ovipositing during host- 
specificity tests. Ceutorhyncus litura (Stem mining 
weevil) has a broader host range and can attack 
several native and non-native members of the Cirs/- 
um (thistle) genus. No sensitive Cirsium species 
have been identified on the Bonners Ferry Ranger 
District. 


2-11 


Low risk assuming careful follow-up spray and assuming manual and cultural 
control is carried out at least three times per year in areas close to water. Biological 
control may reduce the competitiveness of Canada thistle but there is potential 





Chapter 4 reviews in detail the possible impacts of 
herbicide applications on various resources includ- 
ing non-target plant species, soil and water, fish and 
wildlife species. Generally, the direct impacts would 
be minimal because of the low toxicity of these com- 
pounds and the limited extent of the spraying. The 
greatest impacts would be to non-target plant spe- 
cies. A few native forbs plants would be eliminated 
from areas that are directly sprayed. However, these 
species could readily recolonize from unsprayed 
areas. Most native forbs and grasses would tolerate 
the proposed treatments. There are no threatened, 
endangered, or sensitive plant species on these 
sites. (Sensitive plant species are those deemed by 
the Forest Service to be rare, at least locally. See 
Chapter 4 for further description.) 


For some people, herbicide use would represent an 
undesirable human intrusion in an area that is to be 
protected from human impacts. For others, howev- 
er, the human-caused introduction of these aggres- 
sive non-native species requires a speedy, effective 
response to protect native ecosystems and other 
forest resources. 


Table 2-3 summarizes the environmental impacts of 
the various alternatives. 


Table 2-3--Summary of environmental impacts of the alternatives 


Alternative 1: No 
action 


Alternative 2: Manu- 
al & Cultural 


Alternative 3: Manu- 
al, Cultural & Biolog- 
ical 


Alternative 4: Manu- 
al, Cultural, Biologi- 
cal & Chemical 


ISSUE 3: IMPACT OF THE CONTROL ALTERNA- 
TIVES ON HUMAN HEALTH 


The non-chemical alternatives would have little im- 
pact on human health and safety. The manual and 
mechanical alternatives could result in sprains, mi- 
nor irritations, or injury from flying objects. 


Current toxicology data supporting the registration 
of these herbicides indicate that these compounds 
provide low risk when used as directed. The issues 
of carcinogenicity, mutagenicity, and generalized 
health effects are addressed in Chapter 4. The risks 
of long-term deferred effects such as cancer are 
considered very slight and on the order of other 
riskS COMmonly encountered in everyday life (for 
example, the cancer risks of transcontinental air 
flight from increased exposure to cosmic radiation). 
The exposures to chemicals from these projects 
would be quite transient and minimal, even on a 
Cumulative basis. 


There will always remain some uncertainty regard- 
ing the effects of herbicide exposure on human 
health. Sources of uncertainty include the neces- 


Impacts are related to the spread of noxious weeds. 


Minimal impacts. Minor soil disturbance. 


Low impact expected on native vegetation. 


Visual impacts of site treatment has the potential to disrupt some users 
experiences. Analysis does not indicate a risk of significant impacts on fish and 
wildlife. Short term localized impacts on some broadleaf species. 





Sary extrapolation of toxicology data from laboratory 
animals to humans, the use of high-dose cancer 
Studies to predict rates of cancer from low doses, 
and the difficulty of predicting human dose levels 
under the conditions anticipated here. To compen- 
sate for this uncertainty, risk was analyzed conser- 
vatively which tends to overstate the risk. These 
factors are reviewed in Chapter 4 and in the Risk 
Analyses contained in the project file. 


COST OF ALTERNATIVES 


Table 2-4 displays the estimated on-site cost of im- 
plementing each alternative for one year. Monitor- 
ing of site conditions and other activities that are 
provided under all alternatives including the No Ac- 
tion alternative would cost about $2,000 per year. 


Following the table is a discussion of the assump- 
tions used to develop these costs. No attempt was 
made to develop the costs of failure to control nox- 
ious weeds or to quantify the beneficial effect of 
control on biodiversity. These benefits and the cost 
of impacts on biodiversity are very difficult to quanti- 
fy on an economic basis. 


Table 2-4.--The estimated 1-year on-site costs of the alternatives 












The following assumptions were used in determin- 
ing costs: 


1) All costs are for implementing each alternative on_ 


all sites for 1 year. 

Manual control cost estimates assume implementa- 
tion of the program at least two times during the 
active growing season. 


2) Labor costs for implementation procedures re- 
flect (GS-5) wages totaling $75.00/day and (GS-4) 
wages at $70.00/day. 


3) Stock costs, subsistence and fringe benefits av- 
erage approximately 85% of the total wage cost to 
implement the alternative/site. 


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4) A worker can pull and/or clip and bag approxi- 
mately one-tenth acre per day depending on the 
weed infestation level and site conditions. All manu- 
al and cultural treatment cost estimates display the 
total cost of twice a year action. 


5) Chemical cost estimates assume the following 
materials cost: 2,4-D, $11.25/gal.; picloram, 
$90/gal.; dicamba, $90/gal.; clopyralid, $217/gal. 


6) Chemical application costs for the remote sites 
average approximately $287/acre. This cost per 
acre figure includes chemical, wages, and travel 
costs. 


7) A worker applying herbicides with a backpack 
sprayer can cover 3 to 5 acres per day depending 
on the circumstances. 






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CHAPTER III 
AFFECTED ENVIRONMENT 


INTRODUCTION 


This chapter: 


ap provides a brief overview of the project 
areas, 
2. connects this document to the goals, ob- 


jectives, and standards outlined in the 
Idaho Panhandle Forest Plan for the 
Management Areas in which these sites 
are located, 


Ey, describes the site characteristics of the 
areas proposed for treatment, 


4. describes the site-specific condition of 
the resources and attributes that might 
be affected by the proposed actions. 


AREA DESCRIPTIONS 


The Selkirk Mountain, Purcell Mountain, and 
Cabinet Mountain Ecosystems are located in 
mountainous terrain in northern Idaho. The pro- 
posed Environmental Impact Statement covers 
410,000 acres that comprise the Bonners Ferry 
Ranger District of the Idaho Panhandle National 
Forest. This area is in Boundary County, the 
northern most county in Idaho. The largest por- 
tion of this area is bordered on the west by the 
crest of the Selkirk range and on the east by the 
Kootenai National Forest and northwest Mon- 
tana. The southern boundary is the county line 
separating Bonner and Boundary Counties. The 
Northern boundary is the international border 
separating Canada and the United States. See 
Appendix 

A to review area map. 


Portions of two major river drainages (Kootenai 
River and Moyie River) are located on the Bon- 
ners Ferry Ranger District. The valleys of these 
two river drainages are typical intermountain gla- 


ciated valleys which have been subject to exten- 
sive stream action since glacial times. The valleys 
generally range from .5 to 2 miles wide; however, 
narrow steep canyons also occur on the lower 
end of the Moyie River valley. Elevations on the 
valley floor range from 1800 feet near the 
Canada/U.S.boundary along the Kootenai River 
to 2633 feet where the Moyie enters the United 
States from Canada. From the valley floors, the 
mountains rise abruptly to elevations over 7500 
feet. 


The climate of the area is primarily affected by 
maritime weather patterns that are occasionally 
modified by continental air masses. Weather var- 
ies considerably with elevation, slope aspect, 
and season. Annual precipitation ranges from 25 
inches on the valley floor to 80 inches or more in 
the higher elevations. Snow provides approxi- 
mately 40 to 80 percent of the total precipitation 
depending on the location. Snow cover in open 
areas on the lower to mid valley floors typically 
vanishes in March or April. Snow accumulation is 
much greater in the higher elevations and can 
linger into the summer months. 


Soils in the valley floors and lower valley slopes 
have developed from two types of parent materi- 
als: materials deposited by glaciers (glacial tills) 
and post-glacial alluvial deposits. Glacial materi- 
als are often deposited as unstratified clayey and 
loamy deposits. Water-deposited materials occur 
on the stream terraces and alluvial fans of the 
valley bottoms. Soils on the higher terraces have 
developed in stratified sand, gravel, and cobble. 
Soils on the lower terraces have developed in 
Stratified silts, sands and gravels which are fre- 
quently deposited and disturbed. 


Soil development has also been affected by 
wind-deposited, volcanic ash. Soils in relatively 
undisturbed areas on the valley floor often con- 
tain soil profiles several inches in depth that have 
been significantly affected by volcanic deposits 
that originated in Cascade Range eruptions such 
as Mount Mazama. 


The vegetation is a complex mosaic of different 
aged stands of Pinus contorta (lodgepole pine), 
Pseudotsuga menziesii (Douglas-fir), Pinus pon- 
Gerosa (Ponderosa pine), Larix occidentalis 
(Larch), Picea (Spruce), Abies lasiocarpa (sub- 
alpine fir), Tsuga heterophylla (western hem- 
lock), and Thuja plicata (western redcedar). 


Douglas-fir is believed to be the climax tree spe- 
cies On most dry sites. Common shrubs include 
Arctostphylos uva-ursi (kinnikinnik), Berberis 
repens (Creeping Oregon grape), Symphoricar- 
pos albus (Snowberry), Holodiscus discolor 
(ocean spray), and Physocarpus malvacea, 
ninebark. More mesic (moister) sites support an 
understory of Linnaea borealis (twinflower), Ore- 
gon grape, kinnikinnick, Cornus sto/onifera (Red- 
osier dogwood), Shepherdia canadensis 
(Buffalo-berry), Agrostis stolonifera (Redtop), 
and Aster occidentalis (Western aster). On 
moister sites larch is fairly extensive on the lower 
to mid slopes. 


Lodgepole pine is the most abundant conifer 
found throughout the area in all but the higher 
elevations. It occurs in all densities and age class 
distributions, and is frequently in pure, even- 
aged stands. 


Ponderosa pine is found to a limited extent on 
some of the dry sites at low elevations. This spe- 
cies often occurs in the open, park-like stands. 
Understories in these stands are dominated by 
bluebunch wheatgrass, rough fescue, and other 
bunchgrass species. Scattered Douglas-fir and 
lodgepole pine are also found on these sites and 
account for most of the coniferous reproduction. 


Spruce grows over a wide range of elevations on 
sites with abundant soil moisture. Spruce is 
found primarily in riparian areas and with sub- 
alpine fir on mesic northerly slopes. 


River bottom lands are well vegetated with coni- 
fers, primarily lodgepole pine, Douglas-fir, larch, 
ponderosa pine, and Engelmann spruce. Associ- 
ated hardwood tree species include birch, 
cottonwood, and aspen with willow, alder, and 
other shrubs. 


FOREST PLAN MANAGEMENT 
DIRECTION FOR THESE SITES 


As explained in Chapter 1920 of the Forest Serv- 
ice Manual, planning for units of the National For- 
est System involves two levels of decisions. The 
first is the development of a Forest Plan that pro- 
vides direction for all resource management pro- 
grams, practices, uses, and protection mea- 
sures. The second level of planning involves the 
analysis and implementation of management 
practices designed to achieve the goals and ob- 
jectives of the Forest Plan. The second level re- 
quires site-specific analysis to meet National En- 
vironmental Protection Act (NEPA) requirements 
for decision making. 


This EIS presents the results of the site-specific 
analysis required for the second level of decision. 
Thus it is appropriate to review the Forest Plan 
direction for the Forest in general, and for the 
specific Management Areas in which these sites 
are located, in order to show the connection be- 
tween the decisions made in the Forest Plan and 
the decisions proposed in this EIS. 


A Forest objective for the first planning period is 
to inventory, map, and complete an activity 
schedule for significant weed plant communities, 
which include Centarea maculosa (Spotted knap- 
weed), Hypericum perforatum (St. Johnswort or 
Goatweed), Cirsium arvense (Canada thistle), 
Linaria dalmatica (Dalmation toadflax), Tanace- 
tum vulgare (Common tansy), Hieracium auranti- 
acum orange hawkweed, Hieracium pratense, 
meadow hawkweed, Euphorbia esula, leafy 
spurge, Cynoglossum officinale hound’s-tongue, 
Chonarilla juncea, rush skeleton weed, and Lyth- 
rum salicaria purple loosestrife. The Bonners Fer- 
ry Ranger District has completed inventories for 
the Selkirk and Cabinet Ecosytems and most of 
the Purcell Mountain Ecosystem. 


The Idaho Panhandle Forest Plan requires the 
development of management direction for nox- 
ious weeds. The goals and standards for the pro- 
tection of other resources such as soil and water 
also have implications for weed-control projects. 
These standards will be reviewed below in our 
discussion of the resources potentially affected 
by these control activities. 


Project sites occur in a variety of land manage- 
ment allocations. Land management allocations 
affected include Management Areas (MA’s) 1, 2, 
3, 4, 7, 9, 10, and 17. A brief statement of the 
golas for each of these management areas is as 
follows: 


MA 1 - Provide for long-term growth and pro- 
duction of commercially valuale wood prod- 
ucts on those lands that are suitable for tim- 
ber production. 


MA 2 - Manage identified grizzly bear habitat 
to support the Forest’s share of a recovered 
grizzly bear population while providing the 
production of commercially valuable wood 
products. 


MA 8 - Provide sufficient winter forage areas 
to support existing and projected big game 
opulatio while providing for the production of 
commercially valuable wood products. 


MA 4 - Provide winter forage to support exist- 
ing and projected big game populations 
through scheduled timber harvest and per- 
manent forage areas. 


MA 7 - Manage identified caribou habitat to 
support the Forest’s share of a recovered 
caribou population, while providing for the 
prodction of commercially valuable wood 
products. 


MA 9 - Manage to maintain and protect exist- 
ing improvements and resource productive 
potential within minimum investments. 


MA 10 - Provide the opportunity for a semi- 
primitive recreation experience. The area will 
be managed in its present condition, with no 
new roads. 


MA 17 - Manage for developed recreation 
opportunities in a roaded natural and rural 
recreation setting. 


The standards for all these allocations include 
the use of integrated pest management for pro- 
tection against pests. 


3-3 


AFFECTED RESOURCES ON 
PROPOSED TREATMENT SITES 


AIR QUALITY 


All projects of the Idaho Panhandle National For- 
ests (IPNF) must comply with procedural require- 
ments of the Clean Air Act (US EPA, 1971) and 
State Implementation and Smoke Management 
Plans. The United States Environmental Protec- 
tion Agency (EPA) has adopted national primary 
and secondary ambient air quality standards 
(NAAQS) under the authority of Section 109 of 
the Clean Air Act. These standards include ac- 
ceptable levels of pollutants and particulate mat- 
ter. The Prevention of Significant Deterioration 
(PSD) requirements of this Act limit the increase 
of pollutants such as these from point sources 
that could impact Class 1 areas. The Cabinet 
Wilderness, approximately 20 miles to the south- 
east of the Bonners Ferry Ranger District, is the 
closest Class 1 airshed. 


The air quality in the IPNF is generally good to 
excellent throughout a majority of the year. Sea- 
sonal variation in weather patterns and human 
activities contribute to variation in the air quality. 
Smoke from agricultural field burning, wood 
burning stoves, prescribed burning and wildfires 
contribute to seasonal deterioration of the air 
quality. Dust from agricultural lands and motor 
vehicle traffic on gravel and dirt roads can cause 
reduced air quality and visibility, especially when 
there are high winds. 


The project area lies within the state of Idaho's 
North Idaho smoke management zone. The IPNF 
is part of the Northern Region of the Forest Serv- 
ice. This region has signed a Memorandum of 
Agreement with the State of Montana, and is a 
member of the Montana State Airshed Group. 
This group monitors air quality in the state of 
Montana, their concern is primarily smoke and 
particulates from forest residue burning. Prevail- 
ing winds in the project area are southwest. Activ- 
ities in this portion of Idaho predominately affect 
air quality in Montana airsheds. 


FISHERIES 


Species Present 
Bull Trout (Salvelinus confluentus) 


The bull trout is considered a Category C1 spe- 
cies under the Endangered Species Act (1973). 
The U.S. Fish and Wildlife Service decided on 
June 8, 1994 that the bull char is warranted but 
precluded from listing. On February 6, 1995 the 
USFWS changed the bull char status to warrant- 
ed. This means significant threats exist to the 
continued existence of the species and the USF- 
WS is in the process of drafting regulations. The 
Forest Service recognizes bull trout as a sensitive 
species in Region 1. 


Bull trout are found in cold water streams, rivers, 
and lakes (U.S.D.A. 1989). Bull trout spawn in late 
summer through fall (August to November), often 
in areas of ground water infiltration. Fry hatch at 
the end of January and emerge in early spring 
(April). Juveniles remain near the stream bottom 
or in low velocity habitat (pools and pocketwater) 
for the first two years of their life. Unembedded 
substrate and dispersed woody debris are com- 
monly used forms of cover. Most juveniles mi- 
grate at the beginning of the third growing sea- 
son into larger lakes or rivers. Bull char usually 
mature at age 5 to 6. Adult migration begins in 
early spring (March or April) and may extend 
through the entire summer. Most fish are in 
spawning streams by August. Some adults will 
spawn more than once during their lifetime, but 
they may not spawn each year (Pratt 1992). 


Bull trout are present in several of the drainages 
proposed for spraying. Fluvial bull trout from the 
Kootenai River have been found at the mouth of 
Snow and Caribou Creeks (Paragamian 1994). 
Bull trout have also been located in Myrtle, Trout, 
Boundary, Grass, Parker, and Long Canyon 
Creeks. It is not known whether these fish are 
from resident or fluvial populations. The status of 
bull trout in the Kootenai River, below the 
Kootenai falls, is thought to be at a high risk of 
extinction (personal communication, Dave 
Cross, IPNF Fisheries 


3-4 


Biologist, 1995) 


Westslope Cutthroat Trout (Oncorynchus clarki 
lewisi) 


Westslope cutthroat trout are listed as a Catego- 
ry species, as of November 15, 1994, under the 
Endangered Species Act, (1973). This means 
that the U.S. Fish and Wildlife Service indicates 
that proposing to list as endangered or threat- 
ened is possibly appropriate, but for which con- 
clusive data on the biological vulnerability and 
threats are not currently available to support the 
proposed rules. Westslope cutthroat are also 
recognized by the Forest Service as a sensitive 
species in Region 1. 


Westslope cutthroat trout occur in clear, cool 
streams usually with water temperatures less 
than 17 degrees celsius. Cutthroat habitat con- 
tains rocky, silt-free riffles, for spawning and slow, 
deep pools with well vegetated stream banks for 
feeding and resting (U.S.D.A. 1989). They tend to 
occupy headwater areas especially when other 
salmonid species are present in the same stream 
(Hickman and Raleigh 1982). Cutthroat trout usu- 
ally reach sexual maturity at age 3 to 4. They 
spawn in the spring, usually in April or May. Fry 
and juveniles occur in stream sections that are 
shallow with slow velocity flows. As fish grow larg- 
er and mature, they seek out deep water habitat 
types such as pools and deep runs (Hickman 
and Raleigh 1982; Baltz et al. 1991). During win- 
ter, cutthroat trout typically seek deeper water 
associated with large woody debris (Moore and 
Gregory 1988). Strong populations of this spe- 
cies exist in only 36% of its original range in Idaho 
(Rieman and Apperman, 1989). 


Westslope cutthroat trout are present in most 
drainages of the Kootenai and Moyie River. 
Westslope cutthroat have not been found in 
McGinty, Gable, Twentymile, Cow, or Katka 
Creeks, drainages where spraying is proposed. 
The status of populations in remaining water- 
sheds proposed for spraying is unknown. In 
drainages where introduced rainbow and brook 
trout occur, long term viability of westslope cut- 
throat may be in question (personal communica- 
tions Dave Cross, IPNF Fisheries Biologist, 1995). 
In many cases this may not be due to solely 
introduced species. Instead, cumulative effects 
from fishing pressure, introduced species, and a 


depressed cutthroat population from managed 
disturbances have all played a part to tip the 
balance against cutthroat. 


Redband Trout (Oncorhynchus mykiss gibbsi) 


Redband trout are listed as a C2 species under 
the Endangered Species Act (1973) and are rec- 
ognized as a sensitive species in Region 1. 


Redband Trout are a strain of rainbow trout that 
are native to the Kootenai River Basin. The main- 
stem Kootenai retains a hybrid mixture of 
redband/rainbow/cutthroat, but barriered tribu- 
taries may have headwater redband populations 
(U.S.D.A. 1994). Field evidence indicates that in- 
terior redband and westslope cutthroat generally 
coexisted below Kootenai Falls before exotic spe- 
cies were introduced. For the most part the two 
species were segregated spatially, but in sympa- 
tric situations they were able to maintain a high 
degree of genetic integrity. It is only where the 
coastal rainbows were introduced that we see 
hybrid swarms of rainbow-redband-cutthroat 
where few if any individuals are genetically pure. 


The stocking of coastal rainbows (as early as 
1914) has complicated the redband picture, as 
did the release of eastern brook trout, yellow- 
stone cutthroat, and a host of other species 
(U.S.D.A. 1994). Redbands are generally found 
to be virtually extirpated through hybridization 
with introduced rainbows. In essence, in those 
places where someone has bothered to look for 
redbands, it looks like there are very few clues left 
to interpret about their status. 


Preliminary results from genetic surveys con- 
ducted in 1994, located redband trout in only 
three of the nine streams surveyed. Saddle and 
Grass Creeks were found to contain genetically 
pure populations, while Boundary Creek has a 
97% pure population (personal communication, 
Doug Perkinson, Kootenai National Forest Fish- 
eries Biologist, 1995). 


White Sturgeon (Acipenser transmontanus) 
The United States Fish and Wildlife Service has 


listed the Kootenai River population of White 
Sturgeon as endangered under the Endangered 


3-5 


Species Act 
59:171:45989-46001). 


(Federal Register 


White sturgeon are anadromous in most of the 
larger rivers in which they occur but are landlock 
in the middle and upper Columbia River system. 
The Kootenai River population range includes 
lake and river habitats between the outflow of 
Kootenay Lake and Kootenai Falls upstream in 
Montana. Most fish have been found only in the 
Kootenai River, but a few have been located in 
larger tributary streams (Graham 1981). In 1989, 
a State of Montana enforcement officer cited an 
angler for taking of a sturgeon in the Yaak River 
(U.S.D.A. 1993). However, few have been sighted 
in other tributary streams . 


Spawning period for white sturgeon occurs in 
May and June. Spawning probably occurs over 
rock or bedrock substrate in swift currents near 
rapids, when water temperatures are between 
8.9 and 16.7 degrees celsius (Graham 1981). It is 
believed that that most spawning in the Kootenai 
River occurs in the canyon section between Bon- 
ners Ferry and Kootenai Falls. Sturgeons have 
not been identified in any of the tributary streams 
proposed for spraying. 


Other Species 


In addition to the above mentioned species, trib- 
utaries and lakes of the Moyie and Kootenai River 
support sculpins (Cottus), slimy sculpins (Cottus 
cognatus), redside shiner (Richardsonius baltea- 
tus), mountain whitefish (Prosopium williamsoni), 
kokanee salmon (Oncorhynchus nerka), rainbow 
trout (Oncorhynchus mykiss), peamouth (My- 
locheilus caurinus), northern squawfish (Pty- 
chocheilus oregonensis), pumpkinseed (Lepo- 
mis gibbosus), largemouth bass (Micropterus 
salmoides), yellow perch (Perca flavescens), 
crappie (Pomoxis), and brook trout (Salvelinus 
fontinalis). 


HUMAN RESOURCES and HUMAN HEALTH 


The impacts of the control alternatives are ana- 
lyzed for two groups of people, the workers in- 
volved in the control activity and the general pub- 
lic who might be on or near these sites. Chapter 
4 discusses risk to human health. 


RANGE 


Grazing areas are identified as transitory range- 
land within the Cow Creek, Grass Creek and low- 
er Trout Creek drainages. Transitional range- 
lands are those lands whose open character is 
maintained by fire, flooding, pest outbreaks, or 
other disturbances. These sites could eventually 
revert to forest cover if natural disturbances are 
controlled. Both wild ungulates and domestic 
livestock frequently forage throughout these iso- 
lated areas. 


RECREATION 
The sites under consideration are located prima- 


rily along Forest roads and trails where dispersed 
recreation such as driving for pleasure, hiking, 


hunting, or traveling to an outdoor forest activity — 


would occur. 


A few sites are associated with campgrounds 
including Robinson Lake, Copper Creek, Brush 
Lake, Smith Lake, and Meadow Creek Camp- 
grounds. These sites vary in the amount of devel- 
oped recreational use from low to high. These 
sites were identified for treatment due to current 
limited noxious weed populations which if con- 
trolled may prevent invasion into riparian zones. 


SOILS AND VEGETATION TYPES 


Soils are an important part of the analysis primari- 
ly because of the interaction of soil characteris- 
tics and herbicides. Three soil characteristics of 
particular importance are the percent organic 
matter of the soil, the available water holdilng 
capacity of the soil, and the permeability of the 
soil. These three characteristics plus the chemi- 
cal properties of the herbicide determine the 
availability of the herbicide for uptake by plants 
and its tendency to move through the soil. 


When incorporated into the soil, part of the herbi- 
cide dissolves in the soil water and part adsorbs 
onto soil particles, primarily organic matter and 
fine particles. The amount of herbicide adsorbed 
onto soil particles depends on the characteristics 
of the chemical and on the amount of organic 
matter and fine material in the soil. Any herbicide 
that remains in soil water is available for uptake 
by plant roots. However, if the water moves off- 


3-6 


o 


site or out of the rooting zone it takes some of the 
dissolved herbicide with it. 


As proposed in this EIS, the majority of the herbi- 
cide will be applied to the road prism. Soils within 
the road prism are generally devoid of organic 
matter, have low water holding capacity and gen- 
erally restricted permeability rates. Herbicides 
applied to roads have a high risk of being carried 
off-site either dissolved in water or adsorbed onto 
soil particles. If these transported herbicides end 
up being directed off the road and onto the un- 
disturbed forest floor, then, a very good soil situa- 
tion exists for retaining the herbicide in the sur- 
face soils. If the transported herbicide is directed 
into ditches and streams, little to no filtration will 
take place. 


Most undisturbed soils in North Idaho have a 
surface litter layer which ranges from 2 to 5 inch- 
es thick. The lower part of this litter layer is highly 
decomposed and would have a high capability of 
adsorbing herbicide. Below the the organic litter 
layer is volcanic ash which occurs as the surface 
layer of mineral soil. This ash layer ranges from 7 
to 16 inches in thickness. The top part of the ash 
is enriched in organic matter and the entire ash 
layer has a very high water holding capacity and 
herbicide-nutrient holding capacity. 


The risk of herbicide moving through undis- 
turbed forest soils into the ground water is low in 
most places. An exception is in the lower Purcell 
trench, where areas of wind blown glacial sands 
have formed sand dunes with little or no volcanic 
ash deposition on top of them. On these sites the 
soils are not conducive to retaining herbicides 
within the surface soils. Little organic matter oc- 
curs, the water holding capacity is very low and 
the permeability is very rapid. These soil charac- 
teristics will provide easier movement of herbi- 
cides through the soil, but ground water is proba- 
bly quite deep in these areas. 


There are two basic categories of vegetation 
types associated with the projects areas: Ripari- 
an areas and upland areas. There are only a 
couple of sites occupying riparian areas. These 
sites occur along the lower reach of Trout Creek 
and one of the lower reaches of Grass Creek. The 
floodplains associated with these riparian sites 
are nearly level to gently sloping. High water ta- 
bles are common near stream channels. As one 


moves away from the stream channels the 
chance of encountering a high water table dimin- 
ishes. 


Upland areas are where most of the sites are 
located. Upland areas do not have the hydrologic 
regimes and resulting moisture to support the 
vegetation associated with riparian areas. 


While most of the proposed treatment sites are 
located in upland areas, the locations of these 
sites are commonly along roads or trails often 
leading to riparian areas. The Selkirk and Cabinet 
Mountain ecosystems contain several species of 
sensitive plants. Sensitive plant species are 
those species whose population viability is deter- 
mined to be a concern due to evidence of a sig- 
nificant Current or predicted downward trend in 
population or habitat. The vast majority of these 
species habituate riparian zones. A list of species 
present on the Bonners Ferry District as well as 
the ecosystems they are found 

in and drainage population size is part of the 
project file. 


Vegetation surveys have been done for all sites. 
On these sites, there are no threatened or endan- 
gered plant species as listed under the Endan- 
gered Species Act. In addition, there are no 
sensitive plant species on these sites. 


Within the Selkirk Mountain ecosystem, there are 
fens*, a type of wetland habitat. These are bog- 
like low-gradient areas where peat soils are 
formed. These sites are often dominated by 
sedges and sphagnum mosses. There are 5 sen- 
sitive plant species that grow primarily in these 
fens. Two of the noxious weeds species, meadow 
and yellow hawkweed, would find this habitat 
suitable for colonization. 


* Fen A non-acidic peat forming wetland that 
receives nutrients from sources other than pre- 
cipitation, usually through ground water move- 
ment. Most fens have standing water dominated 
by emergent vegetation, open peatland with 
sedges and short shrubs, or raised peat domi- 
nated by shrubs and trees. 


3-7 


WILDLIFE 


Several threatened and endangered animal spe- 
cies may occur or have suitable habitat in the 
project areas. These are the grizzly bear (threat- 
ened), the woodland caribou, the northern Rocky 
Mountain wolf (gray wolf), and the bald eagle (all 
three listed as endangered). Further information 
on these species can be found in the Biological 
Evaluation. 


Treatment areas include the recovery zones for 
the Selkirk Mountain and Cabinet/Yaak Grizzly 
Bear Ecosystems. The woodland caribou recov- 
ery zone is also included in some treatment areas 
in higher elevations of the Selkirk Mountains. Al- 
though the recovery zone for gray wolves is fur- 
ther south in central Idaho, the Idaho Panhandle 
is a transition area and is used by wolves travel- 
ling from Canada to the south. The entire district 
is within the generalized recovery zone for bald 
eagles, but habitat only occurs within treatment 
areas in the Robinson Lake vicinity and the vicini- 
ty of the Kootenai River along the Katka Road. 


The U.S. Fish and Wildlife Service has developed 
recovery plans for all four species. Copies of 
these recovery plans are available at the Idaho 
Panhandle National Forest’s Supervisor's Office. 


There are numerous species of wildlife designat- 
ed as sensitive by the Region 1 Regional Forest- 
er. Those known to be present, or whose habitat 
occurs near treatment areas, are the eleven spe- 
cies listed for the Bonners Ferry Ranger District. 
These are: Coeur d'Alene salamander, common 
loon, harlequin duck, boreal owl, flammulated 
owl, black-backed woodpecker, lynx, fisher, wol- 
verine, Townsend's big-eared bat, northern bog 
lemming. Of these, two species are not known to 
occur on the district, and have marginal habitat. 
These are common loon and Townsend's big- 
eared bat. 


Further information on these species is present- 
ed in the Biological Evaluation. 


The Bonners Ferry Ranger District has four spe- 
cies which are used as management indicator 
species. These are pileated woodpecker, gos- 
hawk, pine marten and white-tailed deer. These 
species vary in abundance from uncommon 


(goshawk) to abundant (white-tailed deer). 
Pileated woodpecker, goshawk and pine marten 
prefer older timbered stands, and white-tailed 
deer prefer a mixture of timbered stands with 
some openings. 


Other faunal groups of concern include a diverse 
group commonly referred to as neotropical mi- 
grant birds. These birds typically are small song- 
birds that migrate from northern breeding 
grounds to the neotropics for the winter, but as a 
management group also include resident birds 
such as chickadees. Many of these birds are in- 
sectivorous, but some are granivorous. Their 
habitat requirements vary from virtually rocky 
slopes (rock wrens), to meadows and lower seral 
stages (chipping sparrows), to densely timbered 


old growth stands (winter wren). Around 150 spe- . 


cies occur within the great elevational distances 
of the treatment areas. 


WATER QUALITY 


Both the Kootenai and Moyie Rivers flow through 
the Bonners Ferry Ranger District. The headwa- 
ters for both rivers are in Canada, the Kootenai 
River also flows through the State of Montana. 
Beyond the confluence of the Moyie and 
Kootenai Rivers, The Kootenai flows west and 
north back into Canada. The Idaho Department 
of Health and Welfare Rules and Regulations, 
Title 1, chapter 2, "Water Quality Standards and 
Waste Water Treatment Requirements" identify 
the beneficial uses for these rivers. The beneficial 
uses include: Domestic water supply, Agricultur- 
al water supply, Cold water biota, Salmonid 
spawning, Primary and Secondary contact recre- 
ation. Both rivers have been identified as a Spe- 
cial Resource Waters. 


There are several municipal watersheds within 
the District. Myrtle Creek is the municipal water- 
shed for the community of Bonners Ferry. Twen- 
tymile and Brown Creeks are the water sources 
for the Naples Area. Mission Creek is the water- 
shed for the Mount Hall Area. Caribou Creek is 
the watershed for the Deep Creek Area. 


Myrtle Creek and the Moyie River are both stream 
segments of concern. Site specific BMP’s have 


3-8 


been developed but do not deal with herbicide 
application. The primary concern for Myrtle 
Creek is oil contamination from spills. There are 
no Outstanding Resource Waters on the Bonners 
Ferry Ranger District. 


The Water Quality Antidegradation Policy (IDAPA 
16.01.2051) states that the existing instream wa- 
ter uses and the level of water quality necessary 
to protect the existing uses shall be maintained 
and protected. The Idaho Forest Practices Act, 
Title 38, Chapter 13, Idaho Code, Rule 6 lists Best 
Management Practices applicable to the use of 
chemicals. BMP’s applied to these proposed 
projects are discussed in Chapter 4 and the sec- 
tion on Mitigation Measures. 


IDAPA 16.01.2250 adopts the National Toxic Rule 
water quality standards for acceptable levels of 
toxic substances. 


Wetlands, Floodplains, and Riparian Areas. 


There are no proposed activities within wetlands. 
As mentioned in a preceeding section "Soils and 
Vegetation", proposed activities are designed to 
keep the noxious weed species from invading 
wetlands in the Selkirk and Cabinet Mountain 
ecosystems and some of the wetlands in the Pur- 
cell Mountain ecosystem. Activities are proposed 
in two floodplain/riparian areas. 


GRASS CREEK 


Approximately 0.25 acre of meadow hawk- 
weed has been identified in a riparian area in 
Grass Creek. The site is between the creek 
and road #636, approximately 1/4 mile from 
Boundary Creek. The riparian vegetation 
consists of cedar, spruce and hemlock trees 
with understory shrubs. The population of 
hawkweed is spotty and could be effectively 
treated with 2,4-D. 


The majority of Grass Creek is characterized 
as having a low gradient, fairly straight chan- 
nel pattern. It flows through a narrow, gently 
sloping, U-shaped glacial valley. The Use 
Designation for Grass Creek is Primary Con- 
tact Recreation (IDAPA, 1992). The Forest 
Service also recognizes Cold Water Biota 
and Salmonid Spawning as uses for Grass 
Creek. Grass Creek is a Class | Stream per 


definitions of the Idaho Forest Practices Act. 
Grass Creek has been identified as an impor- 
tant fisheries stream in the Forest Plan (IPNF, 
1987). The majority of the length of Grass 
Creek is MA 16. 


TROUT CREEK 


Meadow hawkweed populations are located 
adjacent to Trout Creek along road #417. In 
this area, the creek has been channelized 
and rip rap has been placed against the 
south bank. The channel bottom consists of 
cobble and smaller boulders. An island of 
deposited cobble sized material is located in 


the middle of the creek. Vegetation on the 
island consists of alder and cedar. Meadow 
hawkweed has also infesting the island. The 
conifer vegetation on the island is approxi- 
mately 10 years of age, indicating that the 
island has been stable for several years. Ri- 
parian vegetation is mostly absent from the 
banks of the stream. Vegetation consists of 
grass (quack grass with some timothy) and 
occasional clumps of alder. There is a grove 
of dense cedar trees between the road and 
grassy area, no hawkweed was observed 
within the densely timbered area. 


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CHAPTER IV 
ENVIRONMENTAL CONSEQUENCES 


INTRODUCTION 


This chapter evaluates the potential environmental 
consequences of each of the alternatives on each 
site. This evaluation considers the following: 


- direct effects 

- indirect effects 

- cumulative effects 

- probable environmental effects that cannot 
be avoided 

- possible conflicts with the plans and policies 
of other jurisdictions 

- the relationship between short-term use and 
long-term productivity 

- the irreversible and irretrievable commitment 
-of resources 


Potential environmental consequences are evaluat- 
ed for each of the affected resources described in 
Chapter 3. Definitions of the different types of effects 
are listed below. 


1. Direct effects are caused by the action 
and occur at the same time or place. 


2. Indirect effects are caused by the action 
and are later in time or farther removed in 
distance but still reasonably foreseeable. 


3. Cumulative effects are the impacts which 
result from the action when added to other 
past, present, and reasonably foreseeable 
future actions regardless of which agency or 
person undertakes such actions. For exam- 
ple, the potential for cumulative impacts on 
water quality from several herbicide projects 
in a given watershed is addressed in the sec- 
tion entitled Fisheries and Surface Water 
Quality. 


4-1 


ORGANIZATION OF THIS 
CHAPTER 


The discussion of the environmental impacts of the 
various alternatives is intended to be site-specific 
without being tediously repetitive. For each re- 
source presented in Chapter 3, environmental im- 
pacts are discussed for the various site alternatives. 


ENVIRONMENTAL IMPACTS ON 
AFFECTED RESOURCES 


AIR QUALITY 


The no-action alternative and the non-chemical 
control alternatives would have no impacts on air 
quality if implemented on any of the sites. 


Alternatives that involve spraying of herbicides 
would have a short-term, localized impact on air 
quality because ofthe drift of spray particles. Gener- 
ally the greatest part of this drift would settle out 
within 25 feet of the site, although small amounts 
could carry greater distances (USDA Forest Serv- 
ice, 1993). The smell of chemicals such as 2,4-D 
may also persist at a spray site for several days 
following spraying. 


FISHERIES and SURFACE WATER QUALITY 


The discussion of impacts of the alternatives on 
surface water quality has been combined with the 
section on fisheries because of the relationship be- 
tween topics. The discussion of groundwater quality 
is provided in the section on soils. 


INDICATORS 


The following analysis will focus on the effects to 
water quality, the toxic characteristic of each herbi- 
cide, and the concentration of herbicide to which 
aquatic biota are exposed. 


EFFECTS SPECIFIC TO ALTERNATIVES 
Alternative 1: No Action 
Direct, Indirect, and Cumulative Effects 


As discussed in greater detail in the section on Veg- 
etative Community Diversity, without treatment it be- 
comes increasingly likely that noxious weeds will 
become more widely established across the Bon- 
ners Ferry Ranger District. An indirect effect of nox- 
ious weed invasion could be increased water runoff 
and sediment yield from infested sites. Lacey et al. 
(1989) have shown an almost three-fold increase in 
sediment yield from knapweed sites compared to a 
non-infested bunch grass site. Runoff increased by 
about 50 percent from the knapweed site. 


At the present time, most infested sites are along 
road clearings. Noxious weeds are probably having 
little effect on sediment yield in comparison to other 
road related activities (road use, maintenance, etc.). 
Impacts from future spread of the weeds would de- 
pend on the slope, soil characteristics, precipitation 
patterns, and distance to water from the infested 
sites. However, even under the worst-case noxious 
weed infestation scenario, it is unlikely that increase 
in sediment yield to streams would be sufficient to 
affect fisheries or water quality. 


Alternative 2: Manual and Cultural Control 
Direct, Indirect, and Cumulative Effects 


Manual treatment would result in localized soil dis- 
turbance. An increase in sediment to streams from 
the manual treatment along road cuts and fills and 
within the two riparian areas is possible, but the 
increase would likely be undetectable for several 
reasons. First, disturbed areas would be replanted 
with grass seed after treatment reducing erosion as 
roots became established . Second, not all sedi- 
ment reaching ditchlines would be transported di- 
rectly to streams. Many ditchlines are intercepted by 


4-2 


relief culverts, which drain onto the forest floor. Fi- 
nally, soil disturbance would be minimal and local- 
ized in comparison to the entire watershed. 


Cultural treatments (seeding, transplanting, and fer- 
tilizing) would not effect fisheries. Fertilizers would 
be applied according to Forest Service and manu- 
facture guidelines. Runoff nutrient concentrations 
therefore would not be large enough to enrich 
streams. Seeding and transplanting would involve 
limited soil disturbance. There are no cumulative 
effects with this alternative. 


Alternative 3: Manual, Cultural, and Biological 
Control 


Direct, Indirect, and Cumulative Effects 


Effects from manual and cultural treatments are sim- 
ilar to those displayed in alternative 2. Release of 
biocontrol. agents would have no direct effect on 
fisheries or surface water quality. The biocontrol 
agents would not compete with aquatic insect spe- 
cies since their food base is very specific, nor would 
they provide more than an incidental food source for 
fish. There are no cumulative effects with this alter- 
native. 


Alternative 4: Manual, Cultural, Biological, and 
Chemical Control 


Direct, Indirect, and Cumulative Effects 


Effects from manual, cultural, and biological treat- 
ments are similar to those displayed in alternatives 
2 and 3. 


The herbicides proposed for use on these site are 
all characterized by relatively low aquatic toxicity. 
The 96-hour LC,, for the four herbicides is provided 
in Table 4-1. The 96-hour LC, refers to the concen- 
tration that is lethal to 50 percent of the fish exposed 
at that level for 96 hours. The lower the LC,, the 
more toxic the compound. 


Table 4-1.Toxic levels of herbicides to fish 
96 hour LC50 LC50 divided NOEL 
(milligram/liter) by 10 (milligram/liter) 


a ah 
iim eae oo 


Notes: 2,4-D, dicamba, and picloram values are taken from Mayer and Ellersieck 1986 and Woodward 
1976 and 1979. Clopyralid value is from Dow Chemical Company 1986. 

2,4-D acid is the parent compound which is formulated in a variety of forms, including the amine which 
would be used under the 2,4-D alternative. 










Herbicide 
(test species) 









Clopyralid 
(rainbow trout) 






2,4-D acid 
(cutthroat trout) 







2,4-D amine 
(rainbow trout) 





Dicamba 
(rainbow trout 





Although the LC., is frequently used as a toxicity site. On a runoff-dominated site, rainfall is more like- 
standard, fifty percent fish mortality is generally not ly to produce overland flow. These two classes of 
acceptable. Because we often do not have long- sites are differentiated on the basis of vegetative 
term test results that provide safe concentrations or cover, soil type, degree of disturbance and compac- 
no-observed-effect levels (NOEL), the U.S. EPA has tion, and slope. The majority of the proposed treat- 
recommended that the 96-hour LC,, be divided by ment sites are runoff-dominated (road cuts and 
10 to set a standard for concentrations to protect fills), except for Saddle Creek, where the majority of 
aquatic species (U.S. EPA 1986). Table 4-1 provides the proposed treatment sites are previously har- 
these concentrations, which are used as a bench- vested stands adjacent to roads. Roads enhance 
mark to judge the significance of possible impacts. runoff by concentrating flows on compacted road 
It is interesting to note that the NOEL for picloram surfaces and ditches, intersecting groundwater flow 
developed from long-term laboratory studies corre- from cut slopes, and using coarse material with low 
sponds fairly closely to the LC,, divided by 10 (see organic matter to create the fill slope. Since the 
Table 4-1). Saddle Creek sites are undisturbed forest soils, they 


were determined to be infittration-dominated. 
The second part of the risk analysis for aquatic spe- 


cies involves determining the possible herbicide Based on a review of scientific studies of picloram 
concentration in streams. Field studies of pesticide runoff to streams (Rice 1990), it is estimated that a 
spray operations have shown that pesticide input to maximum of 10 percent of the herbicide applied on 
streams ranged from non-detectible to 6 percent of a runoff-dominated site and 1 percent on an infiltra- 
the amount applied (as reviewed in Monnig 1988). tion dominated site could be lost to the stream ina 
six hour period. Because of its relatively long envi- 
In order to predict the potential water quality im- ronmental persistence and relatively low soil ad- 
pacts of herbicide applications on the sites under sorption (high mobility), picloram represents the 
consideration, it is important to distinguish between worst case of the herbicides analyzed here. 
infiltration-dominated sites and runoff-dominated 
sites. In all but the most severe conditions, rainfall On this basis, the worst-case concentrations of her- 
percolates into the soil on an infittration-dominated bicide can be calculated for drainages in the vicinity 


4-3 


of the proposed treatment sites. Each seasons en- 
tire herbicide application was calculated per drain- 
age as if weeds were sprayed continuously along 
each road in a matter of a few days instead of over 
a period of 1 to 2 months. It was assumed that a 
severe thunderstorm could wash 10 percent of the 
active ingredient into the stream on_ runoff- 
dominated sites and 1 percent on infiltration domi- 
nated sites over a six hour period. The average 
cubic feet per second (cfs) water yield for the month 
of July was used to calculate the liters of water 
produced during an average 6 hour time period. 
Herbicide application is conducted mid-May 
through early August, stream flow for the month of 
July was used as a worse case since the July flow 
is much lower than the June flow. Five year average 
water yield was used to calculate the yields for Boul- 
der, Smith and Boundary Creeks, this information 
was obtained from stream guages. The yield per 
acre of drainage from these drainages was used to 
calculate an estimated cfs water flow for the remain- 
ing drainages. See Table 4-3 for results.. 


With this methodology, Meadow Creek showed the 
highest concentration of Picloram at 0.0287 mg/L 
(Table 4-3). Grass Creek showed the highest con- 
centration of 2,4-D at 0.0690 milligrams per liter (a 
mg/L is equivalent to a part per million). These re- 
sults are well below the estimated NOEL. With the 
average july CFS water yield of these drainages, this 
analysis shows that 100 percent of the application 
amount scheduled for each drainage could be 
washed into the creek over a period of 6 hours and 
the concentration would still be less than NOEL. 


Again it should be emphasized that these calcula- 
tions represent a worst case scenario and the prob- 
ability that these concentrations would be reached 
is very low, It is unlikely that any herbicide would be 
detected in stream water as a result of these spray 
operations because of the low level of herbicide use 
spread over a period of 2 months or more compared 
to the water yield in these drainages over the same 
period of time. 


A report by Scott et al. (1976), of the Fish and Wild- 
life Service, concluded that a concentration of 0.6 
ppm picloram decreased cutthroat fry growth by 
25%. No adverse effects were observed when con- 
centrations were below 0.3 ppm. Woodward (1979) 
concluded that picloram increased the mortality of 
fry in concentration above 1.3 ppm and reduced 
their growth in concentrations above 0.61 ppm 


4-4 


when exposure exceeded 20 days. Worst case sce- 
nario concentrations calculated in Table 4-3 are well 
below these documented effect levels or the 0.35 
mg/L concentration listed in Table 4-1. 


Concentrations for clopyralid, dicamba, and 2,4-D 
that could enter streams under a worst case scenar- 
io are also low, see Table 4-3. The highest concen- 
tration of clopyralid, dicamba, and 2,4-D is .0209 
mg/L, .0155 mg/L, and .3478 mg/L respectively. 
These are far below the LC., divided by 10 value 
reported in Table 4-1. 


When herbicides are applied, there is often concern 
that they will bioconcentrate in organisms through 
uptake and retention by tissue or gills. For this to 
occur, retention of a pollutant must exhibit a high 
resistance to breakdown or excretion by an organ- 
ism to allow a sufficient uptake period for an elevat- 
ed concentration. A high concentration must also 
be applied for an extended period of time. Bidlack 
(1980) studied channel catfish exposed up to 28 
days to picloram at 1 ppm (mg/L). Analysis showed 
that picloram did not bioconcentrate. Each herbi- 
cide proposed has worst case scenario concentra- 
tions below 1 mg/L and would not be applied over 
an extended period. Therefore, there is a low risk of 
bioconcentrating. 


Concern is sometimes expressed over the possible 
cumulative or synergistic effects of mixtures of 
chemicals on sensitive resources. Synergism is a 
special type of interaction where combined effect of 
a certain herbicide with other chemicals in the envi- 
ronment is greater than the effect of any one chemi- 
cal alone. This issue is discussed in greater detail in 
the section on Human Health Impacts. As noted 
there, EPA currently supports an additive model in 
predicting such interactions. Even with the assump- 
tion that the chemicals are present simultaneously, 
their additive concentrations are still well below the 
NOEL thresholds. Furthermore, where more than 
one herbicide is applied, the dosage would be re- 
duced (personal communication, Bob Klarich). 
From the small doses expected from this project, 
synergistic effects are not expected. 


Herbicides can also indirectly influence fish popula- 
tions by affecting the populations of other organ- 
isms upon which fish are dependent. Table 4-2 pro- 
vides toxicity data for other aquatic organisms (eg. 
macro-invertebrates). 


As indicated in Table 4-2, these herbicides are gen- Wildlife Service and the U.S. EPA as indicators of a 
erally less toxic to lower orders of aquatic organisms 
than to fish species. Although the species listed in ; ae 
Table 4-2 are not the only aquatic organisms found case concentrations of the herbicides in water are 


in these waters, they are used by the U.S. Fish and well below levels that would affect these organisms. 


wide range of aquatic organisms. Again, the worst- 


Table 4-2.Toxic levels of herbicides to aquatic organisms other than fish 


Clopyralid Daphnids (Daphnia sp.) 48 hr LC50 is 225 mg/L 


Clopyralid Ram’s horn snail (Helisoma No mortality after 48 hours in a solution 
trivolvis) containing 1 mg/L 
Clopyralid Green Algae (Se/enastrum 96 hr LC50 is 61 mg/L 
capricornutum) 


48 hr LC50 is greater than 100 mg/L 
Dicamba Daphnia magna 96 hr LC50 is greater than 100 mg/L 
Picloram Scuds (Gammarus fasciatus) 


Picloram Scuds (Gammarus pseudolimnae- | 96 hr LC50 is 16.5 mg/L 
us) 
Picloram Stonefly (Pteronarcys californica) | 96 hr LC5O is 4.8 mg/L 


Values provided on this table are taken from Mayer and Ellersieck 1986 (2,4-D, dicamba, and picloram) 
and Dow Chemical Company 1986 and undated (clopyralid). 






























on a specific site is not affecting a specific aquatic 


It must be recognized that Forest Service spraying resource does not exonerate all possible applica- 
is minimal compared to the overall use of herbi- tions of these herbicides. The U.S. EPA has the 
cides. A demonstration that Forest Service spraying overall responsibility for determining the possible 


4-5 


aquatic and other environmental impacts of these 
herbicides under their registered use patterns. If 
unacceptable impacts are suspected, the EPA must 
require additional testing and monitoring under the 
pesticide registration process. During the registra- 
tion or reregistration of these compounds, the EPA 
did not identify impacts to aquatic organisms as a 
major concern. In fact, the EPA continues to allow 
the application of some formulations of 2,4-D direct- 
ly to water. The major surface water concern identi- 
fied for picloram is the possible contamination of 
irrigation water and effects downstream on sensitive 
crops. 


Municipal Watersheds 
Spraying is proposed in two municipal watersheds 


above the water system diversion points. These 
streams are Caribou Creek and Myrtle Creek. The 


National Toxic Rule has set water quality standards 
for acceptable levels of compounds in surface wa- 
ter. The acceptable level of 2,4-D for domestic water 
supplies is 93 micrograms per liter (ug/L). The ac- 
ceptable level of 2,4-D for waters that support or- 
ganisms for human consumption is 790 ug/L. 


The results of the worst case scenario discussed 
above were converted to ug/L. Under the worst case 
scenario, the concentration of 2,4-D for Caribou 
Creek was 5.1 ug/L and the concentration of 2,4-D 
for Myrtle Creek was 17 ug/L. Both figures are well 
below the acceptable level established by the Na- 
tional Toxic Rule. Again it should be emphasized 
that these calculations represent a worst case sce- 
nario and the probability that these concentrations 
would be reached is very low. 


Table 4-3 Herbicide Concentrations mg/L (ug/L) Worst Case Scenario 











Boulder Creek 0.0068 


Snow Creek 0.0108 


Meadow Creek 











Grass Creek 
Saddle Creek 


N - Herbicide not planned for 
use in this drainage. 


a CC CC 










Best Management Practices 


Rule 6 of the Rules and Regulations Pertaining to 
the Idaho Forest Practices Act Title 38, Chapter 13, 
Idaho Code pertain to the use of chemicals. The 
purpose of these rules is to regulate handling, stor- 
age and application of chemicals in such a way that 
the public health and aquatic and terrestrial habitats 
will not be endangered by contamination of streams 
or other bodies of water. The rules have generally 
been adopted by the Forest Service as standard 
operational procedures. 


There is one exception. One rule requires that at 
least 25 feet be left untreated on each side of all 
Class | steams, flowing Class Il streams and areas 
of open water. As discussed in Chapter Ill, there are 
two locations where treatment of meadow hawk- 
weed is proposed within this zone, Trout Creek and 
Grass Creek. For these cases, a Request for Forest 
Practice Variance will be filed with the Idaho State 
Department of Lands. The request will be to use 
forms of the herbicide 2,4-D that have been certified 
for use over water within this zone. The herbicide 
would not be sprayed directly on water but would be 
spot sprayed by hand directly on hawkweed plants 
up to the edge of the water. 


In summary, the direct, indirect, and cumulative 
water-quality impacts of these projects would be 
minimal. Under reasonable assumptions, it can be 
concluded that no herbicides would be detected in 
surface water at the part-per-billion detection limit, if 
a decision were made to apply herbicides. Effects 
on aquatic organisms under normal-use scenarios 
should not be detectable. 


The impacts could be more serious in the event of 
a spill of herbicides directly into a small stream. It is 
not possible to predict the concentration or duration 
of contamination in advance. However, a spill could 
result in localized fish mortality, especially to young 
fingerlings, or mortality to the early developmental 
stages of other aquatic organisms. BMP direction 
will be followed in the case of a spill. Also see spill 
plan in Appendices. 


HUMAN RESOURCES and HUMAN HEALTH 
No-Action Alternative 


The spread of noxious weeds within the National 
Forest is likely to have little impact on human health 


4-7 


and safety. There are deleterious health impacts on 
humans. Certain noxious weeds are on County and 
State noxious weed lists due to there impacts to 
human health. Human reaction to certain weeds 
ranges from inducement of allergic reaction to 
death (as is the case of poison hemlock). Even 
though there is potential for such impacts, occur- 
ances have been few to date. 


Some people have a strong emotional response to 
the prospect of noxious weeds in the National For- 
est. The possibility of increased spread would likely 
affect their enjoyment of the forest resources. 


Manual Treatment 


The impacts to human health and safety from manu- 
al treatment are likely to be minor. Possible effects 
include a variety of sprains, cuts, and skin irritation 
to the individuals performing the work. It is likely that 
there would be a high turnover in the workforce 
doing manual treatment. 


Cultural Treatment 


The burning of individual knapweed plants presents 
little risk to human health or safety. There is the 
chance of minor burns to workers. 


Biological Treatment 


The release of biological control agents for Canada 
thistle poses no threat to human health or safety. 


Treatment with Herbicides 


There is a wide variety of opinions within the general 
population on the value and safety of pesticides, 
including the herbicides proposed here. Many peo- 
ple, particularly in rural and agricultural settings, 
view pesticides as a necessary part of business 
and, if used properly, a relatively safe tool. Increas- 
ingly, however, the risks of pesticide use are being 
questioned. 


The Northern Region of the Forest Service (Region 
1) has analyzed the risk of the use of clopyralid, 
2,4-D, dicamba, and picloram to control noxious 
weeds. This analysis is presented in two docu- 
ments: Risk Assessment for Herbicide Use in Forest 
Service Regions 1,2,3,4, and 10 and on Bonneville 
Power Administration Sites and Human Health Risk 
Assessment fot Herbicide Application to Control 


Noxious Weeds and Poisonous Plants in the North- 
ern Region. This is highly recommended reading for 
pesticide users and those analyzing projects such 
as those dicuseed in this document. These docu- 
ments are incorporated into this EIS by reference 
and are included as part of the project file. The 
salient findings of these Risk Assessment are pre- 
sented below. 


The analysis of the human health risk from pesticide 
use follows the same basic format as outlined under 
the section on fisheries. The toxicity information is 
reviewed for the herbicides of interest in order to 
determine the levels of these chemicals that would 
be injurious to human health. Exposures and doses 
that might occur as a result of these projects are 
then estimated for workers and members of the 
general public. In the final step, the toxic effect lev- 
els established in the first step are compared to 
dose levels to determine the possibility of health 
impacts. 


A considerable body of test data on laboratory ani- 
mals is available for these herbicides. Most of these 
tests have been conducted as a requirement for 
EPA registration of these compounds for use in the 
U.S. It should be noted that none of these com- 
pounds have completed all tests required for final 
registration. Current Federal regulations allow for 
conditional registration pending the completion of 
all tests and the discovery of no unreasonable ad- 
verse affects in the interim. This allowance for con- 
tinued use before all testing is completed concerns 
some members of the public and has led to charges 
that “untested” pesticides are allowed on the mar- 
ket. 


All the pesticides analyzed here have been subject- 
ed to long-term feeding studies that test for general 
systemic effects such as kidney and liver damage. 
In addition, tests of the effects on reproductive sys- 
tems, mutagenicity (birth defects), and carcinoge- 
nicity (cancer) have been — conducted. 
No-observed-effect levels (NOEL) are available for 
most types of tests. A NOEL is the highest dose in 
a particular test that did not result in adverse health 
impacts to the test organism. 


Extrapolating a NOEL from an animal study to hu- 
mans, however, is an uncertain process. The 
U.S.EPA compensates for this uncertainty by divid- 
ing NOELs from animal tests by a safety factor (typi- 


4-8 


cally 100) when deciding how much pesticide will be 
allowed on various foods. This adjusted dose level 
is referred to as the Acceptable Daily Intake (ADI) 
and is presumed by the EPA to be a dose that is 
safe even if received every day for a lifetime. 


The ADI is a convenient comparison point for deter- 
mining the significance of doses that people might 
receive from these weed-control projects. All doses 
to members of the general public would be below 
the ADI for the herbicides of concern. A concern 
raised occasionally is that persons gather wild 
foods and could gather foods directly sprayed with 
herbicide. This would be virtually impossible at any 
of the spray sites. The only wild foods commonly 
used are a few huckleberries. Spraying would typi- 
Cally occur about three weeks to two months before 
the fruit ripened, and plants that were unintentional- 
ly sprayed would not develop fruit. 


Worker doses for picloram, dicamba, and clopyralid 
are likely to be below the ADI if reasonable safety 
precautions are used. The worker doses of 2,4-D 
could exceed the ADI, but the risks would be very 
small because the spraying would take only a few 
weeks per year and the ADI assumes a lifetime of 
doses. 


There is the possibility of idiosyncratic responses 
such as hypersensitivity on the part of a small per- 
centage of the population. These persons are gen- 
erally aware of their sensitivities since they are typi- 
Cally triggered by a variety of natural and synthetic 
compounds. Such persons would not be permitted 
to work on the spray crews. 


The issue of delayed effects of low levels of chemi- 
cal exposure is raised by some people. Principal 
among these effects is cancer. All of these herbi- 
cides have undergone testing for cancer. Clopyralid 
and dicamba tests have shown no evidence of can- 
Cer initiation or promotion. The evidence for 2,4-D 
and picloram has been more widely debated. Cur- 
rent evidence is mixed, and these compounds 
seem at most weakly carcinogenic. Appendix B 
contains a letter from Dr. John Graham of the Har- 
vard University School of Public Health that summa- 
rizes the current evidence on 2,4-D. As noted in the 
letter, the weight of evidence that 2,4-D is a carcino- 
gen is not strong, and even if it is ultimately shown 
to be an animal carcinogen, it is unlikely to be a very 
potent one. 


Nonetheless, the Risk Assessments cited above as- 
sume that the two herbicides are carcinogens. 
These analyses also assume that any dose of a 
carcinogen could cause cancer and that the proba- 
bility of cancer increases with increasing dose. Esti- 
mations of the probability of developing cancer from 
exposure to these compounds are based on a con- 
servative extrapolation from cancer rates in animals 
subjected to the chemical over a lifetime. The pro- 
jected cancer rates are highest for workers since 
their doses are highest. Even here the risks seem 
relatively low compared to other commonly encoun- 
tered risks. For example, one round-trip transconti- 
nental air trip carries with it an increased risk of 
cancer from cosmic rays on the order of 1 in a 
million. A similar increased risk of cancer accumu- 
lates from living in Denver for 1.5 months compared 
to living at sea level, again because of cosmic rays. 
Smoking 2 cigarettes increases the risk of cancer by 
1 in a million, as does eating 6 pounds of peanut 
butter (due to aflatoxin exposure). Cancer probabili- 
ties of workers would increase by about 1 ina million 
after spraying 2,4-D for 137 days or spraying piclo- 
ram for about 11,000 days. Since the average Amer- 
ican has about a1 in 4 chance of developing cancer 
in his or her lifetime, the cumulative impact from 
spraying at the rates proposed would not be signifi- 
cant. 


Concerns are occasionally raised about the cumu- 
lative and synergistic interactions of the pesticides 
and other chemicals in the environment. Synergism 
is a special type of interaction in which the cumula- 
tive impact of two or more chemicals is greater than 
the impact predicted by adding their individual ef- 
fects. The Risk Assessments referenced above ad- 
dress the possibility of a variety of such interactions. 
These include the interaction of the active 
ingredients in a pesticide formulation with its inert 
ingredients; the interactions of these chemicals with 
other chemicals in the environment; and the cumu- 
lative impacts of spraying proposed here and other 
herbicide spraying the public might be exposed to. 


The basic conclusions are as follows: We cannot 
absolutely guarantee the absence of a synergistic 
interaction between the pesticides examined here 
and other chemicals to which workers or the public 
might be exposed. It is possible, for example, that 
exposure to benzene, a known carcinogen that 
comprises 1 to 5 percent of automobile fuel and 2.5 
percent of automobile exhaust, followed by expo- 
sure to any of these herbicides could result in unex- 


4-9 


pected biochemical interactions. Testing the virtual- 
ly infinite number of chemical combinations would 
be impossible. 


There are anumber of reasons to expect that syner- 
gistic or other unusual cumulative interactions 
would be very rare. Ames (1983) pointed out that 
many naturally occurring chemicals in the food peo- 
ple eat are teratogenic, mutagenic, and carcinogen- 
ic, and they are consumed at doses 10,000 times 
higher than man-made herbicides. Therefore, the 
low, short-lived doses that would result from spray- 
ing these herbicides are very small compared to 
many other chemicals in the environment. For these 
relatively small doses, a synergistic effect is not real- 
istically expected (Crouch et al. 1983). The EPA 
came to a similar conclusion in a discussion entitled 
Guidelines for the Health Risk Assessment of Chemi- 
cals (Federal Register September 24, 1986). They 
suggest in their discussion of interactions (synergis- 
tic or antagonistic effects) that "there seems to be 
consensus that for public health concerns regard- 
ing Causative (toxic) agents, the additive model is 
more appropriate (than any multiplicative model).* 


In summary, although ironclad guarantees cannot 
be given, we would reasonably expect that the hu- 
man health impacts from herbicide applications on 
these sites would be insignificantly small. 


RANGE 
No-Action Alternative 


The increasing spread of noxious weeds would lead 
to a reduction of available forage for both livestock 
and wildlife. 


Manual and Cultural Treatment 


Assuming that these treatments could prevent the 
spread of noxious weeds, there would be no impact 
from this alternative on range resources. dif, as ex- 
pected, funds are not adequate to implement this 
alternative, weeds would continue to spread, and 
the impacts would be similar to the no-action alter- 
native. 


Cultural Treatment 


Impacts could be similar to the manual alternative if 
weeds continued to spread. 


Biological Control 


Assuming that biological control of Canada thistle 
did diminish the competitive advantage of this spe- 
cies, there should be no impact from this alternative 
on range resources. If the method is ineffective, 
then other alternatives would have to be consid- 
ered. 


Treatment with Herbicides 


The use of herbicides could greatly reduce the 
probability of the spread of weeds. As noted in the 
Risk Assessments cited in the section on Human 
Health, feeding studies with cattle have shown low 
toxicity for these compounds. Toxicity levels are well 
above those levels that would be encountered by 
packstock eating treated grass. Feeding studies are 


not available for horses, but common observation of © 


horses grazing in treated areas indicates no effect 
from these herbicides. 


RECREATION 
No Action Alternative 


The spread of noxious weeds could negatively im- 
pact the recreational use and enjoyment of the Cab- 
inet, Purcell, and Selkirk Mountain Ecosystems. For 
many people the presence of noxious weeds is evi- 
dence of negative human impact and negligence in 
stewardship of natural resources.. 


Manual and Cultural Treatment 


lf these treatments were vigorously implemented to 
prevent the spread of weeds, they would prevent 
the negative impacts of exotic species on recre- 
ational opportunities. 


A complete program of manual and cultural treat- 
ment, would require the labor of about 170 individu- 
als over an 88 day period. A workforce of this size 
would significantly affect wilderness solitude of rec- 
reationists. The magnitude of this program would 
significantly affect the condition of trails, campsites, 
range, and other physical and biological resources. 


Biological Treatment 


The release of biological control agents would have 
no direct impacts on recreational opportunities. If 


4-10 


the method is successful in reducing the impact of 
Canada thistle, then it could have some positive 
indirect effect on recreational opportunities. 


Herbicide Treatment 


Treatment with herbicides could greatly decrease 
the likelihood of the spread of non-native vegetation 
to the Selkirk and Cabinet Mountain Ecosystems on 
the Bonners Ferry Ranger District thus minimizing 
the weeds’ impact on recreation. However, the treat- 
ment itself could affect recreational users, particu- 
larly during the short period of time during which 
treatment would occur on these sites. 


The visual impact of spraying would be quite tempo- 
rary and on most sites would only last a few hours 
or less. 


Once the spraying was completed, the evidence of 
spraying would not be obvious. The sprayed weeds 
would begin to yellow and wither, but the process 
would not look much different from the natural wilt- 
ing of plants that are going dormant. 


SOILS and GROUNDWATER QUALITY 
Non-chemical Alternatives 


As noted in the section on fisheries, there is some 
evidence that erosion rates are higher on 
knapweed-infested ground than on native grass- 
land sites. 


The non-chemical alternatives would have no signif- 
icant impact on groundwater quality. 


Treatment with Herbicides 


The soil characteristics of a site are an important 
consideration in the decision to use herbicides. As 
noted in the section on soils in Chapter 3, three 
characteristics are particularly relevant: the percent 
organic matter of the soil, the available water capac- 
ity of the soil, and the permeability of the soil. 


When incorporated into the soil, part of the herbi- 
cide dissolves in the soil moisture and part adsorbs 
onto soil particles, primarily organic matter and fine 
particles. The amount of herbicide adsorbed onto 
soil particles depends on the characteristics of the 
chemical and on the amount of organic matter and 


fine material in the soil. Any herbicide that remains 
in soil water is available for uptake by plant roots. 
However, if the water moves off-site or out of the 
rooting zone it takes some of the dissolved herbi- 
cide with it. The distance of travel and the concen- 
tration of the herbicide determine whether this her- 
bicide movement is a problem. 


All the herbicides analyzed here have some soil 
activity, that is, they dissolve to some extent in water 
and can be adsorbed fairly readily from soil mois- 
ture by susceptible plants. These herbicides can 
move with water as it moves through soil. 


Although these herbicides are all water soluble and 
soil active to some extent, they vary significantly in 
persistence in the environment. As we discussed in 


Chapter 2, persistence is not necessarily anegative . 


characteristic when combatting noxious weeds, 
provided the mobility of the chemical is controlled. 
These species all produce many seeds that remain 
viable in the soil for long periods and many species 
have rhizomes not directly contacted by the spray. 
Long-term control control requires either multiple 
applications of low-persistence chemicals or less 
frequent applications of more persistent chemicals. 
The critical element to consider is whether a more 
persistent chemical such as picloram can be held 
on the site to do the job it is intended to do. 


Since these chemicals can move with water, we 
must consider the permeablilty and water-holding 
capacity of the soil on a site. These properties deter- 
mine how much water moves through the soil into 
groundwater or surface water after rainfall. If the soil 
retains a large quantity of water in its upper horizons 
for later use by plants, the water and partially dis- 
solved herbicide will have little opportunity to move. 
In contrast, if a soil is highly permeable and has little 
water-holding capacity, moisture passes through 
the soil rapidly and carries some of the herbicide 
with it. 


In many areas of northern Idaho and western Mon- 
tana, soils retain almost all precipitation within the 
upper 2 feet of soil. Research on a prairie site in 
Missoula County found no picloram below 20 inch- 
es soil depth (Watson et al 1989). The minimum 
detection limit in this study was 10 parts per billion. 
On a forested site with coarser soils and precipita- 
tion rates more comparable to sites analyzed here, 


4-11 


eo 


this study found picloram levels ranging from 205 to 
366 parts per billion in the upper 5 inches of soil 
after an application of 1 pound of picloram per acre. 
A maximum concentration of 24 parts per billion was 
detected at soil depths between 30 and 40 inches. 
No picloram was measured in shallow groundwater 
wells with a detection limit of 0.5 parts per billion. 


Studies on picloram soil concentrations have in- 
cluded comparisons of picloram, 2,4-D, and clopy- 
ralid. Results reported by Rice and his coresearch- 
ers (1992) confirm that 2,4-D and clopyralid are less 
persistent than picloram. Clopyralid was not detect- 
ed at any time below 10 inches soil depth and, after 
30 days, 2,4-D was not detected below 2 inches soil 
depth. Picloram was detected in the 10 to 20 inch 
soil strata within 30 days of spraying, but was not 
detected below 10 inches soil depth one or two 
years after spraying. Detection limit in this study was 
about 10 parts per billion. 


Dicamba was not directly investigated in these stud- 
ies, but its persistence and mobility properties are in 
the range of 2,4-D and clopyralid (see review in 
USDA 1984). 


VEGETATIVE COMMUNITY DIVERSITY 
No-Action Alternative 


Under this alternative the knapweed, Canada 
thistle,shawkweed, dalmation toadflax, skeleton 
weed, goatweed, and other noxious weed infesta- 
tions would be allowed to expand without interfer- 
ence. It is likely that new infestations would occur as 
animals and humans move seeds or plant parts to 
new locations. 


As these noxious weeds spread, the negative im- 
pact on the diversity of native vegetation would be- 
come more apparent. Several researchers have al- 
so demonstrated that the number of native species, 
not just their total biomass, decreases on sites 
infested by noxious weeds. Belcher and Wilson 
(1989) found 7 to 11 species outside leafy spurge 
infestations but only 4 species where leafy spurge 
was most abundant. Tyser and Key (1988) reported 
significant reduction in species richness and diver- 
sity in knapweed infested fescue grasslands sur- 
veyed in Glacier National Park. 


Manual and Cultural Treatment 


With sufficient commitment of dedicated labor it is 
possible to eliminate some noxious weed species 
such as knapweed, houndstongue, and goatweed 
from a site with manual and cultural treatments. 
These plants can be killed if enough of the tap root 
and lateral roots are removed. However, these 
plants are prolific seed producers, and seed re- 
serves in the soil can remain viable for more than ten 
years. The disturbed ground around pulled plants 
provides a very good seedbed for the germination 
of seeds. Thus hand pulling would have to continue 
over many years to be effective. 


Native species could be effectively restored on 
these sites with a diligent program of manual and 
Cultural control of these species. In addition, control 
of these species on these sites would eliminate their 
spread to other areas. 


Canada thistle is one exception. This species has 
an extensive root system and sends out new shoots 
from numerous buds on lateral roots. Three or more 
pulling sessions per year may reduce the competi- 
tive advantage of the Canada thistle. However, Can- 
ada thistle could not be eliminated from these sites 
with manual or cultural treatment. The infestation 


could continue to fill in through vegetative reproduc- 


tion in spite of a rigorous hand pulling program. The 
composition of native species would continue to be 
affected, although some recovery could be antici- 
pated. If conscientiously applied, manual treatment 
could also greatly reduce or eliminate seed produc- 
tion. The greatest risk with manual and cultural 
treatment of Canada thistle is that the infestations 
would continue to spread vegetatively. 


Biological Control 


The impacts of the introduction of biocontrol agents 
on Canada thistle are difficult to predict. Although 
Urophora cardui and Ceutorhynchus litura are re- 
ported to reduce Canada thistle densities on some 
sites by as much as 80 to 90 percent(Rees 1992), it 
is not certain that these insect species will adapt to 
the climatic and site conditions in these areas. In 
some cases noxious weed species have adapted to 
conditions outside the habitat range of potential bio- 
control agents. 


lf these insect species do adapt to site conditions in 
north Idaho, they could reduce the density of these 


4-12 


infestations of Canada thistle. Canada thistle would 
likely continue to spread slowly through suitable 
habitats; however, its competitiveness against na- 
tive species would be greatly reduced. If the insect 
species did not establish on these sites within a 
reasonable timeframe or did not flourish once es- 
tablished, other alternatives, including the no-action 
alternative would have to be considered. 


Before introducing new biocontrol agents into this 
country the agent’s host-specificity must be tested. 
These biocontrol agents are tested against a wide 
variety of plant species under "eat-or-starve" condi- 
tions to ensure that their attack is confined to a 
narrow range of plant species and preferably only 
the weed of concern. Both of these insects were 
tested for host-specificity. U.cardui showed a very 
narrow range of attack. When tested against seven- 
teen closely related members of the composite, the 
insect laided eggs virtually only on Canada thistle 
(Peschken and Harris 1975). The only other inci- 
dents of egg laying were 1 of 21 females that ovipos- 
ited on a bull thistle (Cirsium vulgare) and 1 of 21 
females that oviposited on a plumeless thistle (Car- 
duus acanthoides). Both of these thistle species are 
also non-native. 


Ceutorhynchus litura has a somewhat broader host 
range than U. cardui. It will attack a wider variety of 
plant species of Cirsium, Silybum, and Carduus 
(Zwolfer and Harris 1965). There exist several native 
species in Montana that belong to the Cirsium ge- 
nus. As this insect species spreads, it could affect 
the populations of these species in some areas, but 
it is unlikely to cause their extinction. At the present 
time there are no sensitive Cirsium species on the 
Bonners Ferry Ranger District. 


Biological control agents will not erradicate a target 
or non-target plant species. Rather, under ideal cir- 
cumstances the control agents will reach a dynamic 
equilibrium with the plant species. 


Control with the Herbicide Picloram 


Herbicides such as picloram and 2,4-D are often 
perceived as greatly reducing the diversity of plant 
species on a spray site. For example, picloram is 
thought to create a grass monoculture at the ex- 
pense of broadleaf species. This generality is some- 
what overstated. 


Two studies have been conducted in western Mon- 
tana to measure the impact of herbicide application 
on native species. Willard et al. (1988) measured the 
impact of picloram on native grasses and broadleaf 
species. With the control of noxious weeds, the 
grass species generally showed marked increases. 
Likewise some broadleaf species such as arnica 
and yarrow were greatly reduced (see Appendix E 
for scientific names). Generally, members of the 
asteraceae (composite family), fabaceae (legume), 
polygonaceae (buckwheat), and apiaceae (parsley 
family) were affected by picloram. In contrast, mem- 
bers of the brassicaceae (mustard family), liliaceae 
(lily family), and scrophulariaceae (figwort family) 
were less affected by the spray. 


In a more extensive study, Rice et a/ (1992) com- 


pared the impacts of the herbicides 2,4-D, picloram, - 


and clopyralid to the impact of knapweed invasion 
on species number and diversity. The knapweed 
sites were in the initial stages of infestation, thus the 
diversity on these sites had not suffered as noted in 
the studies cited above by Tyser and Key (1988). 
Although the untreated knapweed plots in Rice’s 
study started with slightly higher numbers of spe- 
cies and diversity (by luck of random draw), within 
two years after spray the species number and diver- 
sity were virtually identical on all plots. Initially the 
impact to species was greater on sites sprayed with 
picloram than on sites sprayed with clopyralid. 


Clopyralid affects members of only three plant fami- 
lies, the composites, the legumes, and the buck- 
wheats. Thus this herbicide can be sprayed near 
tree, shrub, and forb species that might otherwise 
be affected by picloram. 


Aside from the on-site impacts to vegetation that 
might occur from herbicide application, these treat- 
ments have the benefit of protecting sites that are 
currently uninfested by reducing the sources of fur- 
ther infestation. As discussed in the section on the 
impacts of the no-action alternative the spread of 
these aggressive exotic species could significantly 
impact the vegetative diversity on sensitive sites in 
the Selkirk and Cabinet Mountain Ecosystems. Al- 
though herbicide application could have small and 
transitory impacts on the vegetation on treated 
sites, it would prevent much more serious, long- 
term effects on many thousands of susceptible 
acres in these Ecosystems. 


4-13 


Cumulative Impacts on the Vegetative Diversity 


As discussed under the no-action alternative, the 
failure to control noxious weeds on these sites 
tends to increase the probability that noxious weeds 
will spread to new sites. Likewise, the probability of 
weed spread would increase across sites on which 
weeds are only partially controlled, for example, 
through manual treatment. The probability of further 
spread is compounded as weeds spread to new 
sites. This compounding of probabilities occurs be- 
cause the new sites contribute to the probability of 
spread. Thus, in the same way that money in a bank 
increases more rapidly through compounding of in- 
terest, weed populations can increase rapidly 
through compounded spread. This, in large part, 
accounts for the explosive increase in certain weed 
populations in northern Idaho. 


By contrast, the impacts of alternatives such as her- 
bicide spraying on vegetative biodiversity tend to be 
much more easily confined to the site of application. 
Although herbicides could affect some plant spe- 
cies on the site of application, by preventing the 
spread of weeds their overall impact would be posi- 
tive. Impacts on vegetative diversity would be purely 
additive across the relatively few acres that are 
sprayed. 


WILDLIFE AND THREATENED AND ENDANGERED 
SPECIES 


No-Action Alternative 


The no-action alternative would have no direct im- 
pact in the short term on either threatened and en- 
dangered species or on wildlife species in general. 
The spread of noxious weeds could affect the 
habitat for many wildlife species, however, in the 
long term as more native habitat is replaced or re- 
duced by noxious weeds. The listed species most 
affected by this would be herbivorous, such as griz- 
zly bear, and wolves who depend on prey that are 
herbivorous. Of particular concern is the impact on 
grazing animals such as deer and elk. 


As noted in the previous section on vegetative com- 
munity diversity, noxious weeds can effectively sup- 
plant native vegetation on infested sites. Although 
there are reports of deer and elk eating knapweed 
(Willard et al 1988), it is definitely not a preferred 
forage. A Forest Service assessment of spotted 


knapweed infestation on winter range in the Lolo 
Nationa Forest predicted a loss of 220 elk annually 
by 1998. This would reduce the ability of the area to 
support gray wolves as well, and if infestation were 
to become extreme could affect their populations. 


Grizzly bears could have a reduction in succulent 
vegetative forage if sites were overrun by noxious 
weeds. Grizzly bears are not limited by forage quali- 
ty or quantity in either ecosystem, so the effect 
would probably not be a significant factor in recov- 
ery of this species in the forseeable future. Bears are 
forage opportunists, and would probably be able to 
Survive well even with a severe infestation. 


Woodland caribou and bald eagle would not be 
affected by the spread of noxious weeds. Caribou 
are ungulates, but their diet is very different from elk 
and deer, and would be unlikely to be directly or 
indirectly affected. 


Sensitive wildlife that depend on habitat features 
that are not immediately affected by noxious weed 
contamination would not be likely to be directly af- 
fected. Such species as black-backed woodpecker, 
flammulated owl and boreal owl depend more on 
snags than on ground vegetation. Species associ- 
ated with water such as common loon, CdA sala- 
mander and harlequin duck would not be affected 
because of the precautions noted for water quality; 
they are not dependent on the vegetation affected 
by noxious weed spread. Northern bog lemmings, 
which are associated with bogs but also occur in old 
growth moist forests, would be unlikely to be directly 
affected for the same reasons. 


Carnivores such as wolverine, fisher and lynx could 
be indirectly affected by noxious weed spread in 
much the same way as wolf is, ie, the herbivore prey 
they depend on could be reduced in number and 
kind by noxious weed spread. Of these species, 
fisher would be least affected because they are 
most dependent on older forests with dead and 
down material rather than an herbivorous understo- 


ry. 


Townsend's big-eared bat is apparently limited by 
lack of suitable habitat in our area, ie suitable caves 
or mine adits. No alternative would have any direct, 
indirect, or cumulative effect on this situation. 


Management indicator species would be affected in 
the same types of ways as the above species. 


4-14 


White-tailed deer would be most directly affected by 
the no action alternative of allowing the spread of 
noxious weeds, because its vegetative forage base 
would be altered. Pileated woodpecker and pine 
marten would be least affected by the spread of 
noxious weeds because their habitat is primarily 
large timbered stands that are not favored by any 
noxious weed under consideration at this time. Gos- 
hawks are predators of a number of animal species, 
some of which are herbivores and could be ad- 
versely affected by the spread of noxious weeds. 


Other groups of fauna such as neotropical migrant 
birds would be affected differently depending on 
their habitat needs. In general, the herbivorous or 
granivorous species would be most affected by the 
spread of noxious weeds in the same way as the 
other species above. Least affected species would 
be those dependent on large timber or water- 
related habitats, or whose habitat did not overlap 
those sites prone to infestation by weeds. 


Overall, to all the above species, the greatest effect 
of no action would be the change in biodiversity 
from native plant species upon which the native 
fauna depends. This is a serious concern that prob- 
ably would affect some species in a much more 
impactive way than others, and not in necessarily 
predictable ways. The cumulative effects to all these 
species from the loss of biodiversity from noxious 
weeds; fragmentation from roading, timber harvest- 
ing and rural development; fire suppression; in- 
creased direct human presence from recreation 
and other forest activities; and other human influ- 
ences, generally will make it favorable for those spe- 
cies which are generalists to survive at the expense 
of specialists. Most of the “emphasis” species listed 
above are specialists, and noxious weed infestation 
is thus a part of the cumulative effects which would 
make it less easy for those species to thrive. 


Other Non-chemical Alternatives 


The other non-chemical alternatives would have no 
direct affect on wildlife. If these alternatives allowed 
the continued spread of noxious weeds, they could 
have the indirect effects outlined above for the no- 
action alternative. 


Treatment with Herbicides 


Direct effects to wildlife from the application of these 
herbicides on these sites should be negligible 


based on the discussion below. None of the herbi- 
cides proposed here bioaccumulate in wildlife in 
concentrations greater than their general environ- 
mental concentrations. By contrast, concentrations 
of some organochlorine pesticides such as DDT in 
some wildlife species could be as much as 100,000 
times higher than the concentrations in the general 
environment because these chemicals bioaccumu- 
late. 


Inferences of possible effect can be made by com- 
paring the exposure levels wildlife would experience 
with the concentrations that elicit toxic responses in 
wildlife. As discussed in the Risk Assessments refer- 
enced above in the section on Human Health, im- 
mediately following an application of 1 pound of 
herbicide per acre the herbicide concentration on 
grasses and small forbs would be about 125 parts 
per million. Within 90 days the concentration of pi- 
cloram on vegetation would be about 25 parts per 
million (Watson et al. 1989). The concentrations of 
2,4-D, dicamba, and clopyralid would likely be less 
because of their faster breakdown rates. 


The avian toxicity of these herbicides is extremely 
low (USDA Forest Service 1984 in Spotted Bear 
Ranger District, Project File). The picloram LC,, for 
mallard ducks and quail is in excess of 10,000 parts 
per million (highest dose tested.) Comparable val- 
ues for clopyralid are 4,640 ppm (highest dose test- 
ed), for dicamba in excess of 10,000 ppm (highest 
dose tested), and for 2,4-D amine in excess of 5,000 
ppm. Feeding studies involving rodents also indi- 
cate similar values for these herbicides. These val- 
ues all indicate very low toxicity. 


Feeding studies on grazing animals also confirm the 
low toxicity of these herbicides. Deer that were fed 
foliage treated with 2,4-D at up to 4 times the rate 
proposed here showed no ill effects (Campbell et al. 
1981). Cattle fed picloram-treated hay with concen- 
trations 20 times and greater than those expected 
on the proposed sites suffered no lethal effects 
(Monnig 1988). Heifers fed dicamba at 20,000 ppm 
in feed showed no ill effects (Edson and Sanderson 
1965). Clopyralid feeding studies with grazing ani- 
mals are not available but would likely be similar to 
picloram, which is a close chemical analogue. 


Comparisons of the expected environmental con- 
centrations with the toxicity levels of these herbi- 
cides indicates that effects on birds, rodents, and 
grazing animals are not expected. In addition, the 


4-15 


scientific evidence reviewed in the Human Health 
Risk Assessment indicates that these herbicides 
are quickly excreted by exposed animals. Thus, ef- 
fects on predators such as wolves or on raptors 
such as eagles or falcons are not reasonably ex- 
pected. Because these herbicides do not bioaccu- 
mulate, the cumulative impacts of spraying sites 
inside and outside the National Forest would be 
insignificant. 


Direct effects to species not affected by habitat loss 
from weeds are negligible based on the rationale 
above. 


Indirect effects to wildlife from chemical treatment 
would be primarily from disturbance from the spray 
and Survey crews. This effect would be most notice- 
able on grizzly bears, wolverine and goshawk. Ad- 
ministrative use guidelines for any motorized use 
behind gates would be implemented, so the effects 
of disturbance would be controlled to acceptable 
levels with regard to grizzly bears. Disturbance to 
the other species would be no greater than that of 
other forest level activities. 


Cumulative effects of herbicide treatment may be 
considered as above. 


PROBABLE ENVIRONMENTAL EFFECTS THAT 
CANNOT BE AVOIDED 


The application of herbicides brings with it the likeli- 
hood of some environmental impacts that cannot be 
avoided. These have been discussed above and 
would primarily involve non-target plants. Although 
mitigation measures would probably prevent envi- 
ronmentally significant concentrations of herbicide 
from reaching surface water or groundwater, it is 
possible that minute amounts of herbicide will mi- 
grate from the site. Under reasonably foreseeable 
circumstances this would not have a significant en- 
vironmental impact. 


The adoption of the no-action alternative or any of 
the non-chemical alternatives would not immediate- 
ly result in unavoidable environmental impacts. 
However, it is clear that alternatives which allow the 
continued spread of noxious weeds would eventu- 
ally result in unavoidable environmental effects. Al- 
though the infestations are containable now and 
could theoretically be eliminated at any time in the 
future, after infestations reach a “critical mass" they 
are uncontrollable in any practical sense. This situa- 


tion is well illustrated by the knapweed infestations 
in many areas of northern Idaho. At the "point of no 
return," the adverse environmental impacts outlined 
above for the no-action alternative would be un- 
avoidable. 


POSSIBLE CONFLICTS WITH THE PLANS AND 
POLICIES OF OTHER JURISDICTIONS 


The Idaho Noxious Weed Law directs the county 
control authority to make all reasonable efforts to 
develop and implement a noxious weed program. 


The lack of weed control under the no-action alter- 
native would conflict with State and county weed 
control plans and policies. The other alternatives 
would indicate that the Forest Service is serious 
about doing something about the “weed problem." 


None of the alternatives would conflict with State 
and Federal water or air quality regulations or with 
U.S. Fish and Wildlife Service recovery plans for 
threatened and endangered species. Appendix F 
contains a biological assessment of the possible 
impacts of the preferred alternatives on threatened 
and endangered species. 


4-16 


THE RELATIONSHIP BETWEEN SHORT-TERM US- 
ES AND LONG-TERM PRODUCTIVITY 


None of the alternatives would involve the short term 
use of commodity-type resources. Some might ar- 
gue, however, that the impact of herbicide spraying 
on non-target plant species constitutes a short-term 
use of the resource. 


As discussed above, the more effective an alterna- 
tive is at controlling the spread of noxious weeds, 
the better that alternative is at protecting the natural 
resources of this area despite the possible short- 
term impacts on the environment. 


IRREVERSIBLE AND IRRETRIEVABLE COMMIT- 
MENT OF RESOURCES 


All of the alternatives that involve active control mea- 
sures would involve an irretrievable commitment of 
labor, fossil fuels, and economic resources. The no- 
action alternative would not involve such commit- 
ments, but it could result in the unavoidable deterio- 
ration of the natural condition of the area. The 
no-action alternative would likely irretrievably 
change the existing plant community diversity. 


CHAPTER V 


SUMMARY OF PUBLIC COMMENTS 


INTRODUCTION 
This chapter includes: 


1) abrief description of issues and of public partici- 
pation prior to and following publication of the 
DEIS, 


2) a brief description of public comments on the 
DEIS, 


3) | asummary of the public comments and agency 
responses, and 


4) photocopies of the letters and summaries of all 
Calls from all commentors to the DEIS and agen- 
cy responses to each. 


ISSUES AND PUBLIC PARTICIPATION 


Public comment was formally solicited with a notice 
published in the Federal Register that indicated that 
the Bonners Ferry Ranger District's intent to prepare 
an EIS on noxious weed management. News releases 
were published in several local papers and presented 
as radio announcements to solicit public input on 
weed management. 


Analysis of public and internal input resulted in a list of 
three issues that guided the development of the alter- 
natives. These issues are: 


1. What are the potential impacts of noxious 
weeds on resources such as the ecological com- 
munity and processes; threatened, endangered, 
sensitive plants and animals; soils; water quality; 
aesthetics; wildlife and fish; and recreational 
opportunities? 


2. What are the potential impacts of weed control 
methods on other forest resources as listed in 
issue 1? 


3. How would the weed management methods, 
particularly herbicide application, affect human 
health? 


PUBLIC RESPONSE TO THE DEIS 


The DEIS was released in June of 1995. Copies were 
distributed to any group or individual who had ex- 
pressed an interest in noxious weed control and to 
other potentially interested parties. Copies of the DEIS 
were available for review at several Forest Service offic- 
es. Local newspapers and the radio stations in Bound- 
ary and Bonner Counties provided news coverage of 
the DEIS. The Bonners Ferry Ranger District received 
comments from 8 individuals, organizations, or gov- 
ernment agencies. 


Most respondents supported an active program to 
control noxious weeds. Most of them supported the 
preferred alternative identified in the Draft EIS. In a 
number of comment letters a general support was of- 
fered for the Forest Service noxious weed control pro- 
gram with an implicit support for the Forest Service 
preferred alternative. 


The EIS was revised, where appropriate, to reflect 
comments received from the public. Very few substan- 
tive changes were needed. Some wording changes 
have been made to clarify issues raised in comments 
on the DEIS. These changes are noted in the respons- 
es to individual comment letters. Copies of all written 
comments, with individual responses, are reproduced 
and made part of this chapter. 





= 


(i 4 February 13, 1995, letter (copy enclosed) addressing the Notice of Intent for this project. 


IN REPLY REFER TO 


United States Department of the Interior “- 


OFFICE OF THE SECRETARY Kara ee 

Office of Environmental Policy and Compliance weer 

500 NE Multnomah Street, Suite 600_,, -¢ \ act : 
Portland, Oregon 97232-2036-——_| 


Soe August 21, 1995 






ER 95/0506 


Debbie Henderson-Norton, District Ranger 
Bonners Ferry Ranger District 

Idaho Panhandle National Forests 

Route 4, Box 4860 

Bonners Ferry, Idaho 83805 


Dear Ms. Henderson-Norton: 


The Department of the Interior (Department) has reviewed the Draft Environment Impact 
Statement (DEIS) for the Noxious Weed Management on the Bonners Ferry Ranger District, 
Idaho Panhandle National Forests, Boundary County, Idaho. The following comments have 
been prepared pursuant to the National Environmental Policy Act, Migratory Bird Treaty 
Act, and the Endangered Species Act of 1973, as amended, and are provided for your use 
and information when preparing the final documents. 


GENERAL COMMENTS 


The Department generally supports the integrated pest management approach which this 
project proposes for weed control. This approach consists of mechanical, cultural, 
biclogical, and chemical control measures. We agree that potential adverse impacts to fish 
and wildlife resources resulting from the proposed action would be relatively limited, 
compared to long-term impacts associated with the uncontrolled spread of noxious weeds in 
the project area. 


With respect to minimizing potential impacts associated with the use of herbicides, we 


‘incorporate, by reference, the comments included in the Fish and Wildlife Service’s (Service) 








5=2 


) 


A 


SS warranted, but precluded from listing, and (2) on February 6, 1995, the Service 


Debbie Henderson-Norton, District Ranger 2 
Bonners Ferry Ranger District 


SPECIFIC COMMENTS 


Page 3-4, Bull Trout Under the "Bull Trout” heading, the following two corrections should 
be made: 


* The DEIS states that bull trout is considered a "Category C1 species under the 


mene: ee es nn ee nr narra earn 


Endangered Species Act." Asa point of clarification, the bull trout is considered a 

















enor apa et 


category 1 candidate species, or Ci candidate species. Candidate species are placed in 


a ee er 


One of three categories: Category 1, Category 2, or Category 3. 





* The DEIS indicates that: (1) on June 8, 1994, the Service decided that the bull trout is 


eT rn oer —_—— 


changed the bull trout status to warranted and is in the process of drafting regulations. 
These statements are both incorrect. On June e Service published a not a notice 


of petition finding (59 FR 30364) that detested that listing the bull trout was 


warranted, but precluded due to other higher priority listing : actions. On June 12, 
1995, the Service published a 12-month recycled petition finding (60 FR 30825), 


indicating that that listing the bull trout is still warranted but precluded. 











Westslope Cutthroat Trout The DEIS indicates the westslope cutthroat trout is listed as a 
"Category species". As a point of clarification, the westslope cutthroat trout is currently _ 
considered a category 2 candidate species. 





Appendix E The clarifications and corrections provided also apply to the descriptions of the 
bull trout and the westslope cutthroat trout in the Sensitive Fish Biological Evaluation. 


We appreciate the opportunity to comment. 


Sincerely, 


ONC eel WOKE 


Charles S. Polityka i) 
Regional Environmental Officer 


Enclosure 


Unit. ~States Department of ) ~ Interior 


FISH AND WILDLIFE SERVICE 


Northern Idaho Field Office 
17703 E. Montgomery Drive, Suite #2 
Spokane, WA 99206 





February 13, 1995 


Ms. Debbie Henderson-Norton 

DiS ewvuete nemgers 

Bonners Ferry Ranger District 
Route 4, Box 4860 

Bonners Ferry, Idaho 83805-9764 


SUDJeCcu: Notice of Intent to Prepare an Environmental Impact Statement for 
Noxious Weed Treatment on the Bonners Ferry Ranger District 
(LOSEO200)  ER# 9570025 


Dear Ms. Norton: 


The U.S. Fish and Wildlife Service (Service) is writing in response to the 
subject Notice of Intent (NOI), dated December 30, 1994 and received in our 
office February 3, 1995. The proposed project involves an integrated pest 
management approach to weed control which includes mechanical, biological, and 
chemical control. These preliminary scoping comments are made pursuant to the 
National Environmental Policy Act (NEPA), Fish and Wildlife Coordination Act, 
Migratory Bird Treaty Act, and the Endangered Species Act. 


1. Endangered Species - The analysis area for the proposed project includes 
the recovery areas for the endangered woodland caribou (Rangifer tarandus 
caribou) “and the threatened grizzly bear (Ursus, arctos horribidias) 7 Your 
documentation for the project should include a list of threatened, endangered, 
and candidate species which occur in the treatment areas. You should ensure 
that the arplication activities will not threaten the continued existence or 
preclude recovery of any listed, proposed, or’ candidate species: 

2. Water Quality - The Service is concerned with water quality impacts of the 
propcsed project, particularly with respect to their effects on resident 
fisheries such as bull trout and westslope cutthroat trout. The activities 


should not result in any degradation of water quality, aquatic habitat, and 
wetlands in the analysis area or downstream. The Service is particularly 
concerned where the water table is high or where leaching or surface runoff is 
like2ys 


Application of herbicide sprays should not occur within 200 feet of 
reservoirs, lakes, ponds (livestock and recreational), pools left by seasonal 
streams, springs; or within 100 feet of perennial flowing streams and rivers, 
and wetlands (e.g. swamps, bogs, marshes, and potholes). Ground applications 
of solid herbicides (e.g. crystals, pellets) have a minimum buffer of 50 feet 
from all flowing waters. A distance of less than 50 feet to within 20 feet of 
flowing water may be considered depending on site specific factors. 


3. Migratory Birds - The Service also has concerns with project effects on 
bird species protected under the Migratory Bird Treaty Act (MBTA), which 
prchibits the take of migratory birds, nests, eggs, and nestlings. Use of 
herbicides may have detrimental effects on various bird species, particularly 
insectivorous, herbivorous, and granivorous (seed eating) species. Efforts 
should be made to protect migratory birds and their habitat. 


4. Fish and Wildlife - Short- and long-term impacts of the proposed project 

on fish and wildlife and their habitats should be given full treatment in the 

EIS prepared for this project. Specifically, we suggest that you consider 

incorporating the following points in the proposal: pt a ene 

} Gaver ae a Let Weal ox 

| ei : 
} 
\ 


AUG 1 7 1995 


5-4 


B 


Hak inncrtes xelboousl MisVvOlAGL Ligation, do not spr. enen wind velocities 
a 7 mph, rain or other precipitation is falling or is imminent, 
ier is foggy or is creating unstable air turbulence (normally when 
Temperatures exceed 80 degrees Fahrenheit) that may seriously affect 
7e normal spray pattern, and temperature inversions could lead to 
fsite movement of spray. Weather conditions in operation areas should 
monitored by trained personnel before and during application. 
perations should be immediately suspended anytime it appears that 
meat $a¥ conditions could jeopardize safe placement of spray on target 
areas. Also, the prescribed nozzle pressure as recommended should be 
used. Some applicators increase nozzle pressure creating molecule-like 
Groplets that drift in any air movement. 


7? 


a @ 


iS 


4 
a 
eure 


(co Veneta ed 


LACT AD 
3) 


4) 


Conduct all mixing, loading, and unloading in an area where an 
accidental spill will not contaminate soils and streams or other water 
bodies. If monitoring water is planned, this should be done according 
to a sampling schedule designated in approved plans before, during and 
after treatments and make the results readily available to state and 
local public health and water resources agencies and the general public. 
Careful consideration of the toxicity of mixtures of herbicides is also 
essential because interaction between herbicides may increase their 
toxicity. These synergistic effects of various formulations have not 
been well documented. Toxicity and persistence in the environment of 
Carrier solvents (e.g. diesel oil, kerosene, mineral oil, limonene) 
should also be assessed, along with the associated potential for impacts 
to fish and wildlife resources and their habitats. 


3 Preventative measures may in the case of somé types of exotic, plants be 
the cniy realistic management. Many exotic herbs, for example, will 
reinvade disturbed areas following removal efforts and will continue to 
eebccmpetesnative sspecies on badly trampledYysites. Iti is’ therefore, 
extremely important to encourage the re-establishment of native 
wegecation. For example, an area (e.g. overgrazed meadows, campsites) 
may be closed to reduce trampling and allow re-establishment of native 
species after exotics are removed. In severely disturbed areas, or 
those previously dominated by exotics, planting may be used to speed 
Succession, to prevent soil erosion, and to change local environmental 
conditions 

Exotic plant management programs cannot be one-time efforts. To be 

successful, these programs must be long-term, incorporating control efforts 

znto routine resource management efforts. A monitoring program to evaluate 

she ondoings status, ofsexcticavegetation msivital torsuccessfulvcentrol . 

Periodically, a reassessment of the type, number, location, and distribution 

of "pest" species should be made. Information collected could also be used to 

evaluate the success of control measures and removal techniques. 


The Service appreciates the opportunity to provide comments on the subject 
propesal. We will participate in formal scoping and review of the EIS for 
this preject as funding and time allow. For further information, please 
contact Suzanne Audet of my staff at (509) 891-6839. 


Sincerely, 


RODeLE On Hal. OCK 
Field Supervisor 


GGi BwS, Portland - Dunn 
PwS-£S, Boise 
eine, Bl Texel 


Response to US Department of Interior (Charles Polityka) letter received August 23, 1995. 


1. The comments from the US Fish and Wildlife Service of February 13, 1995 were considered and addressed 
in the preparation of the Draft EIS. 


2. The corrections you have identified have been incorporated into the Final EIS text. 
3. The correction you have identified has been incorporated into the Final EIS text. 
4. The corrections you have identified have been incorporated into Appendix E of the Final EIS. 


Thank you for your interest in noxious weed management on the Bonners Ferry Ranger District. 


5-6 


KOOTENAI COUNTY =: - 





11140 AIRPORT DR. ¢ HAYDEN, IDAHO 83835 * PHONE (208) 772-9239 * FAX (208) 762-3095 


August 3, 1995 


BobekKraricnh 

Interdisciplinary Team Leader 
Bonners Ferry Ranger District 
Rt 4 Box 4860 

Bonners. Ferry = LD s6cs05 


Dear Bob: 


After reviewing your draft Environmental Impact Statement, Noxious 
Weed Management Projects, my overall impression is that this 
document is quite comprehensive and thorough. I have only two 
comments to make it more complete: 


Lt. There was no mention of deleterious health impacts on humans 


from noxious weeds. Poison hemlock (Conium maculatum) was, of 
course, used by the ancient Greeks to put Socrates to death. 
Also, leafy spurge (Euphorbia esula) has toxic sap and “spotted 
knapweed (Centaurea maculosa) induces allergic reactions in in 


some people (to name just three examples). 


Lis No negative impacts to wetlands or riparian areas by noxious 


weeds were discussed. Purple loosestrife (Lythrum salicaria) 
crowds out cattails and other native wetland _ plants; 
_reportedly even fauna, such as song birds, leave once purple 
loosestrife becomes dominant since habitat for them no longer 


oneness Ae wo eee en ew 


exists there. The The hawkweeds also can crowd out native grasses 


in alpine meadows as wel] as in bottom lands, reducing or 


eliminating winter _range for large herbivores; what hawkweed 
does to smaller fauna _ is undocumented. 


Regarding the list of approved herbicides, I would suggest you add 
the very selective, environmentally friendly chemical triclopyr; 
the trade name is Garlon and it is very useful, especially in 


riparian areas. 
Sincerely, 

fj th 
Lhe. A Palle oe 


Frank aa agit 
Superintendent 


SJ 





NATURAL RESOURCES PROTECTION’ c. 


= 





Response to Kootenai County Natural Resources Protection (Frank Frutchi) letter received August 4, 1995. 


1. | Your comment that some noxious weeds can have deleterious health impacts on humans is true. We have 
expanded the discussion of human health in Human Resources and Human Health in Chapter 4. 


2. Fortunately, at this time on the Bonners Ferry District we do not have a population of purple loosestrife 
(Lythrum salicaria). There are only two small sites where wetlands/riparian areas are affected by noxious 
weeds and treatment with herbicides is identifed. At this time, the herbicides identified in this document used 
per label instructions should not pose a threat to the sites treated. This document is oriented to site specific 
projects, and as such had to address how to treat the sites currently needing our attention. If in the future 
there was a need to deal with a noxious weed problem involving significant wetland and or riparian areas, 
such site(s) would also be reviewed for site specific action. It is logical to assume that the herbicide triclopyr 
would be considered at that time. 


Thank you for your interest in noxious weed management on the Bonners Ferry 
Ranger District. 


RECEIVED 


~Aa14.-- 





Boundary fojijons Nortous Weed rors 7 
Bor 267 
Bonners Ferry, Idaho 83805 


August 14, 1995 


Debbie Henderson-Norton District Ranger 
Bonners Ferry Ranger District 

Rt 4 Box 4860 

Bonners Ferry ID 83805 


Dear Debbie: 


This letter is in response to the call for public comment on the noxious weed 
EIS for the Bonners Ferry Ranger District. As the Boundary County Weed Control 
Superintendent I highly recommend that alternative 4 (the integrated management 
approach) be adopted. I personally know the weed control crew and have the utmost 
respect and confidence in their ability to apply herbicides and access environmental 
hazards. 

It is important that the entire Forest Service, not only those folks in field, 
recognize and act upon the serious threat noxious weeds pose to healthy ecosystems. It 
is vitally important that funding for weed control programs remain in place and that 


more 1s done every year. 
My only concern with the Draft EIS is that under the Proposed Action the 41 


identified sites and 335 acres is misleading. It leads the the reader to believe that it is the 


extent of the weed problem when in fact it is FAR greater than t that. The severity and 
rapid spread of ‘Hershweed and knapweed needs to be clearly ‘stated and cannot be over 


emphasized. 











BS 
Bich bet (al 
& iat Carlo 


Boundary County 
Weed Control Superintendent 


5-9 


Response to Boundary County Noxious Weed Control (Rich Del Carlo) letter received August 14, 1995. 


1. |The Purpose and Need for Action section of Chapter 1 has been changed in the Final EIS to amplify the extent 
of weed populations on the Bonners Ferry Ranger District. 


Thank you for your interest in noxious weed management on the Bonners Ferry 
Ranger District. Your alternative preference is included in the summary of comments on alternatives in the Final 
EIS. Your comments will be considered in the alternative selection process. 


USDA-FOREST SERVICE 


RECORD OF PHONE CALL OR VISIT Of fp ox 


File Designation VASO ( mrt LES) vate (-1S- -45 Time Aico Par 
Subject Caorrmtnfr2 bite CA ELS = 


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SIGNATURE 
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TITLE 


FS-R1-04-6220-01 (1/82) 


Response to Terry Bicknell phone call received July 15, 1995. 


Thank you for your interest in noxious weed management on the Bonners Ferry Ranger District. Your alternative 
preferences are included in the summary of comments on alternatives in the Final EIS. Your comments will be 


considered in the alternative selection process. 


5-12 


“Bob K. pe 
AUGUST 4, 1995 Deb. ee 


BOX 48 Gab! 
NAPLES, iD $3847 oo 
DEBBIE HENDERSON-NORTON i, 
DISTRICT RANGER pe ts = f i 
BONNERS FERRY, i DAHO os 
DEAR DEBBIE; Sia ee 


Wise GU Kee LOn Gummer OURRHULIS SUPPORT “FOR JHE 
NOXIOUS WEED PROGRAM PROPOSED. 


NOS LOUS WEED CONTROL TS oe VERY IMBORTANT TO THE 
DEA OFM EC RORES MAS Were CASSPRAVA RE MRROPERRY: 


Wi GH IN KALE ERNAT EVES 4 WOULD =GIVE THE SEES BeCONTROL 
AN DEBE MOD COS) SEP EE CIEE. 


SUNCEREE,, 


ee ieee 

DON NYSTROM 

BOUNDARY CCOUNTY BEUMBER 
ANvEwQOO PRODUCTS 
CevMr lias 


Response to Boundary County Timber and Wood Products Committee (Don Nystrom) letter received August 7, 
1995. 


Thank you for your interest in noxious weed management on the Bonners Ferry Ranger District. Your alternative 
preference is included in the summary of comments on alternatives in the Final ElS. Your comments will be 
considered in the alternative selection process. 


ee - os Sater Pactra tare 
Bea tui eet ae 


Boundary Soil Conservation District s ate ie ' oe -seee 
P.O. Box 23 - Bonners Ferry, Idaho 83805 - Phone: 267-3340 SS Se 
Augrste LO yi 993 ee ae 


Rob Klarich 

Bonners Ferry Ranger District 
Idahn Panhandle Nationa! Forests 
Route 4 Box 4850 

Bonners Ferry, ID 83805 


De a aeo0. 


The Draft Environmental Impact Statement for Noxious 
Weeds Management Projects, Idaho Panhandle National Forests, 
was recently reviewed by members of the Roundary Soil 
Conservation District and the Natura! Resources Conservation 
Service and discussed at our last meeting. We would like to 
cammend you for your efforts and fully endorse your noxious 
weed management proposals as outlined in the draft EIS. 


Our group was particuiarly impressed with the 
comprehensiveness with which you have investigated the 
problem and developed alternative management solutions for 
noxious weeds on forest tands. As you know, the Boundary 
Soii Conservation District and the NRCS are very concerned 
with weed control in the local area. We find it refreshing 
and encouraging that you acknowledge that the problem is not 
onty with private land but that there is a responsibility 
and need for public !tand managers to address the issue. 


Bob, we wish you tuck in your endeavors to manage 
noxious weeds on forest lands and please ‘et us know if we 
can assist you in any way. We took forward to hearing of 
the progress and results of your efforts as your management 
plan may well become the modet to which other public tand 


agencies turn. 


Sincerely, 


SS een, 


Sfimed Kfar $. 


Leonard Kucera, Sr. 
Chairman 


CONSERVATICN - DEVELOPMENT - SELF-GOVERNMENT 


S71) 





Response to Boundary County Soil Conservation District (Leonard Kucera, Sr.) letter received August 15, 1995 
Thank you for your interest in noxious weed management on the Bonners Ferry Ranger District. Your alternative 
preference is included in the summary of comments on alternatives in the Final EIS. Your comments will be 
considered in the alternative selection process. 


And thank you for your offer of assistance. 


Phat he 





IDAHO FISH & GAME Re Me Rie ee 


PANHANDLE REGION Phone (208) 769-1414 + Fax (208) 769-1418 Philip E. Batt / Governor 
2750 Kathleen Avenue Jerry M. Conley / Director 
Coeur d'Alene, Idaho August 11, 1995 
83814 


Ms. Debbie Henderson-Norton 
U.S. Forest Service 

Route 4, Box 4860 

Bonners Ferry, ID 83805 


Dear Debbie: 
RE: NOXIOUS WEED MANAGEMENT PROJECT DEIS 


Thanks for the opportunity to comment on the Draft EIS for noxious weed management on the Bonners Ferry 
District. In general, we support selection of Alternative 4 because we believe it offers the greatest probability 
of success of all of the action alternatives, and because we believe the spread of noxious weeds poses a 
serious threat to biodiversity on the Bonners Ferry District. 


The Biological Evaluations in Appendix E generally provide well researched and substantiated reasons for 
determining that no effect will likely occur to fish and wildlife. Provided chemicals, and particularly those 
which are highly toxic and persist for long periods of time, are carefully applied, we agree impacts to fish and 
wildlife should be minimal and outweighed by the benefits of noxious weed control. Based on the worst case 
scenarios explored in the Fisheries BE’s, it is unlikely enough herbicide would enter into creeks to affect fish 
or aquatic invertebrate populations. Thus, the greatest risk of negatively impacting fish or wildlife is from 
untrained applicators or accidental spills. As we’re sure you are aware, using well trained, conscientious 
applicators is a must, and safety procedures to prevent spills in waterways are important. 


It may be worth noting that 28 of 41 (68%) of the sites proposed for treatment are roads. While not 
necessarily an applicable comment to this DEIS, it does point out’another problem with, and cost of. roads 
on the National Forest. Preventing the spread of noxious weeds is another justification for minimizing new 
road construction and maximizing opportunities for road obliteration. 


We commend the District for tackling the noxious weed problem and hope it becomes a successful program. 


Sincerely, 


~ 


lv“ 
David W. Ortmann 
Regional Supervisor 


DWO:CEC:kh 


ce US Fish and Wildlife Service, Spokane 
Inland Empire Public Lands Council 
Cal Groen, IDFG, Boise 





An Equal Opportunity Employer 


5-17 


Response to Idaho Fish and Game (David Ortmann) letter received August 14, 1995. 


Thank you for your interest in noxious weed management on the Bonners Ferry Ranger District. Your alternative 
preference is included in the summary of comments on alternatives in the Final EIS. Your comments will be 
considered in the alternative selection process. 


0816/95 09:22 FAY ou 65456584 Petar ee arth Yo01 


aoe a. 

Nae 2 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 
SZ; REGION 10. 
1200 Sixth Avenue 
Seattle, Washington 98101 

Reply To i Sys y 
Attn Of: WD-126 August 15, 1995 


Debbie Henderson-Norton, District Ranger 
Bonners Ferry Ranger District, Idaho 
Panhandle National Forests, Route 4, Box 4860 
Bonners Ferry, ID 83805 (208-267-5561) 


Re: Noxious Weed Management Projects 
Draft Environmental Impact Statement (DEIS) 


Dear Ms Henderson-Norton: 


The Environmental Protection Agency (EPA) has reviewed the 
DEIS for the Bonners Ferry Noxious Weed Management Projects. Our 
review was conducted pursuant to the Wational Environmental 
Policy Act (NEPA) and Section 309 of the Clean Air Act. Our 


comments are offered to assist in the preparation of the final 
BSS 


We are rating this DEIS an EC-2 {Environmental Concerns- 
Insufficient Information). A summary, of our comments will be 
published in the Federal Register. We believe additional 

-information is required to effectively communicate the nature and 
risks associated with the proposed-herbicide treatments and tie 
them to specific management objectives. We also believe 
potential impacts on ground and surface water should be assessed 
more clearly, and more detail provided on herbicide formulations 
and application methods in the affected management areas. We 
have no inherent objection to the use of certain herbicides under 
appropriate, controlled conditions, if more environmentally- 
benign alternatives have been demonstrated to be either 
ineffective or significantly not cosu-eL lect ive in relation to 
the herbicide application. 


CD send wi tenyvian evar 


A 
Caz 


08/16/95 09:22 FAX 26 553 6984 EPA REG X WATER by 002 


One area of concern is that the draft has not related 
specific mana management objectives to specific treatments, which may 


include herbicides. The management objectives of timber ~ 





production, game and wildlife habitat, and recreation are 
identified (cattle grazing is reportedly another), but not 


- associated with vegetation management methods. Would it be 


desirable, for example, to maintain some browse and shade for 
game animals? -Or do herbicide residues and potential water 
runoff take on more significance in areas designated for 
recreation? The appropriate method may vary according to asertea 





Management objectives. It would also be instructive to provide 


some damage threshold graphs, showing the level at which 
vegetation (ie, noxious weeds) becomes unacceptable if management 
goals are to be met. 


_Identifying overall management strategies, which would 





_-initially include prevention and maintenance before corrective 


-actions, would clarify the process for EIS readers Are cattle 
gGrazing and the roads themselves major contributors to weed 
development? Could native vegetation have been enhanced 
alongside roads to inhibit weed growth? Even though this is 
looking backward, it’s relevant to how the public will view 
future management strategies and lira should be mentioned in 
the document. “J6.8ad, Ol 2P2R Law Fi 


The DEIS presents some technical information on: each of the 
proposed herbicides to be used in Alternative 4 regarding plant 
specificity and persistance. As suggested above, these concerns. 
should to be related to management purpose, application 
techniques and site-specificity. We have enclosed a planning 
document from the Forest Service, Pacific Northwest Region, 
showing the kinds of site-specific considerations which should be 
assessed (see I-30). Much of the same information is contained 
in your supplemental document on risk’ assessment utes sent us, but 
_Some enumeration of of risk assessment _principles_an lanning needs 


“i Ws LEO. > be placed in the _body of the EIS. This would = Pp prepare the 


Le 
(hs 


fo\ & 
ote 


of riparian areas, drainage ditches and potential for—he 


outside reader to relate management objectives to environmental 
concerns. 


Since one of the concerns in Laingehechiriinn sietewe 


persistance of residues, it _would be -useful_to know the proximity 


_entering the surface and groundwater systems. The two maps in 
Appendix A may have some of that information, but they should be 
keyed to qualitative descriptions in the text. There is an 
obvious need for management flexibility, but the EIS should 
_include a description of which chemicals---2, 4-D, dicamba,_ 
-Clopyralid and plicloram---will likely be used in each situation. 
and indicate that records will be kept mapping location of 
‘specific applications. 


5-20 


08/16/95 09:23 FAX 76.3250 6984 EPA REG X WATER 003 


- 


non-quantifi e_ 


| 
The proposed usage should indicate fhe method of application 
and type of formulétion. Is it sprayed on plants individually, ~~ 
or is that not cost-effective? The method would indicate 
potential unintended side-effects from non-selectivity on native 
plant species, as well as possible water contamination. 






A matrix (such as that 





on 2-11) could show some of these 
+USeS_and minuses alongside cost data, thus 


making the economic choices not appear so one-sided. a8 


We hope these comments will be useful to you as you prepare 
the final EIS. I£ you have any questions about our comments, 
Please contact Doug Woodfill at (206) 553-4012. 


Sincerely, 


AA 


Joan Cabreza, Chief 


Environmental Review Section 
Enclosure : 


Deh 


Response to United States Environmental Protection Agency, Region 10 (Joan Cabreza) letter received August 15, 
1.995: 


1. Control of noxious weeds on a given site has relatively little to do with management objectives and much to 
do with the goals and objectives throughout the ecosystem the site is associated with. The sites where chosen 
and EIS written to an ecosystem approach to weed management. 


Put another way, if a site had weeds and the weeds were to stay on that site, we would not propose treatment. 
Unfortunately, we know that is not the case. From noxious weed surveys, characteristics of noxious weeds species 
present, and resources within the ecosystems that make up the Bonners Ferry Ranger District sites were targeted 
where the risk of spread would have the greatest impact on sensitive areas in ecosystems which have no or very 
few noxious weeds. 


2. The Idaho Panhandle National Forests has operated under a multi-faceted integrated pest management 
(IPM) approach since the Record of Decision, Weed Pest Management, Idaho Panhandle National Forests, 
October 1989. The District has been actively surveying, vegetating new and old road sides, promoting public 
information about noxious weeds, and is about to (along with other Idaho Forests) go to a weed free hay 
restriction starting January 1, 1996. 


The Proposed Action in Chapter 1 in the Final EIS adds information regarding prevention and maintenance not 
presented in the Draft EIS. 


3. Further enumeration of strategy has been added to Chapter 1, Weed Management Philosophy by reference 
to an appendix F, "idaho Panhandle N.F. Proposed Integrated Weed Management Program". This was a 


guiding strategy reference for the 1989 Weed Pest Management, Idaho Panhandle National Forests EIS. 


There have been some other changes as well. In Chapter IV under "Human Resources and Human Health", 
additional information has been added to emphasize to the read that risk assessment has been completed. 


4. There is a reference in Chapter II for a table 2-1. The table was inadvertently left out of the draft publication. 
The Final EIS has table 2-1 which indicates the preferred treatment and distance to ground or surface water 
for each site. 


5. See response to #4. 


6. Chapter 1, "Proposed Action" in the Final EIS identifies that chemicals will be applied either from backpack 
sprayers or truck mounted boomless sprayers that are powered by gasoline engines. 


7. Table 2-4, the table that shows cost to implement each alternative, is the last of four tables in Chapter Il. The 


reader is shown other comparisons of the alternatives including environmental impacts which are in qualita- 
tive terms in tables 2-1, 2-2, and 2-3. 


Sree 


CHAPTER VI 


LIST OF PREPARERS 


The following individuals are core members of the inerdisciplinary team (ID Team) for the Noxious Weeds Manage- 
ment Projects EIS: 


NAME AREA OF EXPERTISE id AREA OF CONTRIBUTION 
Bob Klarich Range/Noxious Weed Mont. ID Team Leader, 
Writer/Editor 
Mark Grant NFMA/NEPA compliance Watershed Analysis, 
Editor 
Ed Monnig Environmental Chemistry Pesticide Impacts on Region 1 


Resources and Human Health 


John Chatel Fisheries Biologist Fisheries Resource 
North Zone, IPNF Analysis 

Diane Amato Botanist Vegetative Analysis 

Sandy Jacobson Wildlife Biologist Wildlife Analysis 

Maridel Merritt NFMA/NEPA compliance Editor 

Jerry Niehoff Soils Scientist Soils Analysis 


Idaho Panhandle NF 


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i 2 tn 


REFERENCES 


Ames, B.N. 1983. Dietary carcinogens and anticarcinogens. Science 221:1256-1264. 


Belcher, J.W. and S.D. Wilson 1989. Leafy spurge and the species composition of a 
mixed-grass prairie. Journal of Range Management 42(2):172-175. 


Campbell, D.L., J.Evans, G.D. Lindsey, and W.E. Dusenberry, 1981. Acceptance by 
black-tailed deer of foliage treated with herbicides. Research Paper PNW-290. USDA Forest 
Service. Pacific Northwest Forest Range Experiment Station. Portland, Oregon. 


Crouch, E.A.C., R. Wilson, and L. Zeise. 1983. The risk of drinking water, Water Resources 
Res 19:1359-1375. 


Del Carlo, Rich. 1995. Personal communication between Bob Klarich and Rich Del Carlo, 
Boundary County Weed Supervisor, Bonners Ferry, Idaho. 


Dow Chemical Company. 1986. Chemistry, environmental, and toxicology profiles of clopy- 
ralid herbicide. Form NO. 137-1846-86. Midland, Michigan. 


Dow Chimical Company. Undated. Clopyralid: technical information. Midland, Michigan. 


Edson, E.F. and D.M. Sanderson, 1965. Toxicity of the Herbicides 2-Methoxy-3, 
6-Dichlorobenzoic Acid (Dicamba) and 2-Methoxy-3, 5, 6-trichlorobenzoic Acid (Tricamba). 
Food Cosmet. Toxicol. 3-299-304. 


Lacey, C. 1987. Overview of the state noxious weed management plan. In: Proceedings of 
the annual conference of the Montana Weed Control Association. Great Falls. January 13-15. 


Lacey, J.R., C.B. Marlow, and J.R. Lane, 1989. Influence of spotted knapweed (Centaru- 
rea Maculosa) on surface runoff and sediment yield. Weed Technology 3:627-631. 


Losensky, J.B. 1987. An evaluation of noxious weeds on the Lolo, Bitterroot and Flathead 
Forests with recommendations for implementing a weed control program. Lolo National 
Forest. Missoula, Montana. 


Mayer, F.L. and M.R. Ellersieck, 1986. Manual of acute toxicity: interpretation and data 
base for 410 chemicals and 66 species of freshwater animals. Resource publication 160, 
U.S. Department of the Interior. Fish and Wildlife Service. Washington, D.C. 


Monnig, E. 1988. Human health risk assessment for herbicide applications to control 
noxious weeds and poisonous plants in the Northern Region. FPM Report 88-9. USDA 
Forest Service. Missoula, Montana. 


Pitcher, S.L. 1987. Letter from Steven L. Pitcher, State of Montana Water Quality Bureau, 
to Ronald C. Prichard, Supervisor, Beaverhead National Forest, February 6, 1987. 


Peschken, D.P. and P. Harris. Host specificity and biology of Urophora cardui (Diptera: 


Tephritidae). A biocontrol agent for Canada thistle (Cirsium Arvense). Canada Department 
of Agriculture, Regina, Saskatchewan. | 


Ref - 1 


Rees, N. 1992. Personal communication between J.T. Winfield and Norm Rees, Biological 
Control Specialist. Agriculture Research Station Rangeland Weeds Lab, Montana State 
Univesity. Bozeman, Montana. 


Rice, P.M. 1990. A Risk Assessment Method To Reduce Picloram Contamination of Streams 
and Groundwater From Weed Spraying Projects. Division of Biological Science, University 
of Montana, Missoula, Montana. 


Rice, P.M., D.J. Bedunah, and C.E. Carlson, 1992. Plant Community Diversity After Herbi- 
cide Control of Spotted Knapweed. USDA Forest Service. Intermountain Research Station. 
Ogden, Utah. 


Rules and Regulations, 1992. Idaho Forest Practices Act, Title 38, Chapter 13, Idaho Code. 
Idaho Department of Lands. Boise, Idaho. 


Spoon, C.W., H.R. Bowles and A. Kulla, 1983. "Noxious Weeds on the Lolo National 
Forest. A Situation Analysis Paper." USDA Forest Service, Northern Region. 


Thompson, J. 1990. Personal communication between E. Monnig and John Thompson, 
Wildlife biologist with State of Montana Department of Fish, Wildlife, and Parks, on the effects 
of herbicide application to contro! spotted knapweed on the Three-mile Game Range. 


Tyser, R.W. and C.H. Key. 1988. Spotted knapweed in natural area fescue grasslands: an 
ecological assessment. Northwest Science 62(4):151-159. 


USDA Forest Service, 1984. Pesticide background statements. Vol. 1, Herbicides. Agricul- 
ture Handbook no. 633. Washington, DC:U.S. Government Printing Office. 


USDA Forest Service, 1992. Risk Assessment for Herbicide Use in Forest Service Regions 
1, 2, 3, 4, and 10 and on Bonneville Power Administration Sites. FS 53-3187-9-30. 


U.S. Environmental Protection Agency. 1986. Ecological Risk Assessment. 
EPA-540/9-85-001. Office of Pesticide Programs. Washington, DC 20460. 


U.S. Environmental Protection Agency, 1986. Quality Criteria for Water (The Gold Book) 
EPA 440/5-86-001. Office of Water Regulations and Standards. Washington, D.C. 


Watson, V.J., P.M. Rice and E.C. Monnig, 1989. Environmental fate of picloram used for 
roadside weed control. Journal of Enviromental Quality 18:198-205. 


Willard, E.E., D.J. Bedunah, and C.L. Marcum, 1988. Impacts and potential impacts of 
spotted knapweed (Centaurea maculosa) on forest and range lands in western Montana. 
Montana Forest and Conservation Experiment Station. School of Forestry. University of 
Montana. Missoula, Montana. 


Woodward, D.F. 1976. Toxicity of the herbicides dinoseb and picloram to cutthroat (Salmo 
clarki) and take trout (Salvelinus hamaycush). J. Fish. Res Can. 33:1671-1676. 


Woodward, D.F. 1979. Assessing the hazard of picloram to cutthroat trout. J. Range 
Management 32:230-232. 


Ref - 2 


Yates, W.E., N.B. Akesson, and D.E. Bayer, 1978. Drift of glyphosate sprays applied with 
aerial and ground equipment. Weed Science 26:597-604. 


Zwolfer, H. and P. Harris, 1965. Ceutorhynchus litura (F.) (Col. Curculionidae). A potential 


onsect for the biological control of thistle, Cirsium Arvense (L) Scop., in Canada. Canada 
Department of Agriculture. Belleville, Ontario. 


Ref - 3 


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LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THE RECORD OF DECISION AND CHAPTER 
V HAVE BEEN SENT. 





LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS 
TO WHOM COPIES OF THE RECORD OF DECISION (ROD) HAVE BEEN SENT 


COPIES OF THE NOXIOUS WEED RECORD OF DECISION AND CHAPTER V HAVE BEEN DISTRIBUTED 
TO THE FOLLOWING AGENCIES, LIBRARIES, ORGANIZATIONS AND INDIVIDUALS AS OF SPETEMBER, 
1995. AN ASTERISK * DENOTES THOSE AGNECIES, LIBRARIES, ORGANIZATIONS, AND INDIVIDUALS 
TO WHOM A FINAL EIS WAS SENT ALSO. MOST RECEIVING FIANL EIS COPIES COMMENTED ON THE 
DRAFT EIS. 


FEDERAL AGENCIES AND OFFICIALS 


USDA/FOREST SERVICE, ENVIRONMENTAL CO-ORDINATOR, WASHINGTON DC 
*USDA/FOREST SERVICE, REGIONAL OFFICE-REGION 1, MISSOULA, MT 
*USDA/FOREST SERVICE, NATIONAL FORESTS 
IDAHO PANHANDLE NATIONAL FORESTS, COEUR D’ALENE, ID 
*USDA/FOREST SERVICE, RANGER DISTRICTS 
IDAHO PANHANDLE: AVERY DISTRICT, AVERY, ID 
IDAHO PANHANDLE: FERNAN DISTRICT, COEUR D’ALENE, ID 
IDAHO PANHANDLE: PRIEST LAKE DISTRICT, PRIEST LAKE, ID 
IDAHO PANHANDLE: SANDPOINT DISTRICT, SANDPOINT, ID 
IDAHO PANHANDLE: ST MARIES DISTRICT, ST MARIES, ID 
*USDA/NATIONAL AGRICULTURAL LIBRARY, BELTSVILLE, MD 
*DOCUMENTS DEPARTMENT - KW, THE LIBRARIES, COLORADO STATE UNIVERSITY, FORT COLLINS, 
CO 


US ENVIRONMENTAL PROTECTION AGENCY, DIR. FEDERAL ACTIVITIES, WASHINGTON DC 
*US ENVIRONMENTAL PROTECTION AGENCY, SEATTLE OFFICE, SEATTLE, WA 


USDI/U.S. FISH AND WILDLIFE SERVICE, SPOKANE, WA 
*USDI, OFFICE OF ENVIRONMENTAL COMPLIANCE, PORTLAND, OR 


FEDERAL CONGRESSIONAL DELEGATION: 
US SENATOR LARRY CRAIG (ID), WASHINGTON DC AND BOISE, ID 
US SENATOR DIRK KEMPTHORNE, CD’A, ID 
US REP HELEN CHENOWETH, BOISE, ID 


STATE AND LOCAL AGENCIES AND OFFICIALS 


*IDAHO DEPT. OF FISH AND GAME, COEUR D'ALENE, ID 

IDAHO DEPT. OF HEALTH & WELFARE, DIVISION OF ENVIRONMENT, COEUR D’ALENE, ID 
IDAHO STATE SENATOR TIM TUCKER, PORTHILL, ID 

BOUNDARY COUNTY COMMISSIONERS, BONNERS FERRY, !D 

*BOUNDARY COUNTY EXTENSION OFFICE, BONNERS FERRY, ID 

CITY OF BONNERS FERRY, BONNERS FERRY, IDAHO 

*KOOTENA! COUNTY NATURAL RESOURCES PROTECTION, COEUR D'ALENE, ID 
BONNER COUNTY WEED CONTROL, SANDPOINT, ID 


Noxious Weed Management Projects Draft EIS List of Agencies - 1 


LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THE RECORD OF DECISION AND CHAPTER 
V HAVE BEEN SENT. 





INDIAN TRIBAL AGENCIES 


KOOTENAI TRIBAL COUNCIL, BONNERS FERRY, ID 
YAKIMA INDIAN NATION, TOPPENSIH, WA 


UNIVERSITIES AND LIBRARIES 


*BOUNDARY COUNTY LIBRARY, BONNERS FERRY, ID 


BUSINESSES 


CPI, L.P., BONNERS FERRY, ID 
KPND, SANDPOINT, ID 


ORGANIZATIONS 


ALLIANCE FOR THE WILD ROCKIES, MISSOULA, MT 

KOOTENAI! VALLEY SPORTSMAN ASSOCIATION, BONNERS FERRY, ID 
NORTH IDAHO AUDUBON SOCIETY, BONNERS FERRY, ID 

INLAND EMPIRE PUBLIC LANDS COUNCIL, SPOKANE, WA 

GREYSTONE, ENGLEWOOD, CO 

WOODNYMPH WILDERNESS WATCH, MOSCOW, ID 

*BOUNDARY COUNTY SOIL CONSERVATION DISTRICT, BONNERS FERRY, ID 
*AGRICULTURAL COMMITTEE, BOUNDARY COUNTY, IDAHO 


INDIVIDUALS 


KAREN WILLIAMS, COEUR D’LENE, ID 
FRANCIS BUCHER, BONNERS FERRY, ID 
MIKE AND DAN RIPATTI, BONNERS FERRY, ID 
DONNA AND ART BRATTKUS, HOPE, ID 
*TERRY BICKNELL, MOYIE SPRINGS, ID 
INTERMOUNTAIN RESEARCH, SANDPOINT, ID 


List of Agencies - 2 Noxious Weed Management Projects Draft EIS 


APPENDIX A 
























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IDAHO PANHANDLE NATIONAL FORESTS 


INTEGRATED WEED MANAGEMENT 


POovoOn eve 


Potential New Invaders: Emphasis on education, awareness and preventicn cf 
noxious and undesirable weed species that do not yet occur on the National 

Forest. This will be accomplished by continuing to participate and further 
develop programs with State and County Agencies informing the public of the 
various noxious and undesirable weeds that are invading the State and rears 


of helping prevent or control these plants. 


A. People working to manage noxious and undesirable weeds need the 
knowledge and ability to recognize when a new plant is present ané 
what to do about it when one is found or thought to exist. To 
accomplish this the Forest will expand the present program for 
in-service training and involvement to reach more of those working on 
the District (including volunteers and other cooperators) in 
identification, monitoring, and treatment of new infestations as well 
as those that are established. The Forest will also expand work with 
the local State and County agencies in education and awareness 
programs for the public and land users to recognize Priority I noxious 
weeds. 


Be Develop a monitoring and survey program to maintain surveillance of 
the Forest for new invaders, spread of established invaders, outbreaks 
and other related information. 


ae The Forest will develop a noxious weed (undesirable plant) field guice 
for the IPNF with sufficient colored pictures and descriptions so it 
cen be carried in the field as an aid in identifying these plants. 
Include instructions on collection and submitting plants for 
pape ee Nahas and techniques to be used in recording infestations. 
his work will be accomplished in cooperation with State and Count: 
Agencies and the University of Idaho. 


ee 


4 form and instructions for submitting specimens to the U. of I. fer 
identification are included in Appendix J. 


De The IPNF will, at least, on an annual basis, share informetion on 
their respective noxious weed treatment programs and established 
priorities with State and County Agencies and County Weed Control 
Associations and other interested groups. The IPNF will continue 
support for the 5 County Weed Association in northern Idaho. 


Once a Priority I weed is identified as having invaded an area, it 
will be placed in Priority II and appropriate action taken. as 
described in Prioritvi1t.. 


0) 


A-6 


Priority I1!: hi 


Eradication of New Invaders: 


The highest priority for treatment will be given to new invading noxice | 
weeds. A key factor in treating Priority Il weeds is to prevent condi tt". 
that allow them to become established. Eradication is the goal for new _ 
invaders. Each District will develop their own list of new inveders. 
Components of this treatment priority include: 





rT 
+. 


A. New invaders are the highest priority for funding of control “ls 


B. The objective for new invaders is immediate control and eventual 
eradication while the infestation is spall and before it has a chane< 
3 to spread. Take appropriate isolation and eradication measures as 
F scon as a new invader is officially identified. Report location o 
the infestation to the University of Idaho who maintains a State wi1- 


inventory. 





3 


Bee There are drainages, road systems and areas on the IPNF where only a 
few or a small area of noxious weea infestation exists (breakout | 





e 
- 


3 areas). This includes several new weed infestations on the fores 
3 wnere the soil was not disturbed by human activity. Spotted knarwe 
leafy spurge, rush skeletonweed, common St. John's-wort, etc. ATE ve 
aggressive plants and compete successfully with native vegetation. 
example is the new infestation of rush skeletonweed on the meadow 
aiong the upper Coeur da' Alene river, section 20, TI54N., R-2b., Bos 

Merdian. This infestation is 100 yards from the road and no othe: ) 
Gevelopment is located near the site. Elimination of the few > eal 
in these areas followed by annual monitoring and follow-up treatment 

as needed will keep these areas free of noxious weeds. The son ofl 













will include revegetation to reduce opportunity for re-invasion o 
nexious weeds. 


meximize efforts to identify all infestations. 
E. Where feasible, identify and treat the cause(s) of the noxious we 


infestations to reduce the possibility of re-entry. This may inc 
the following: 





{ 5 ° 8 ‘ 
D Coordinate surveys with adjacent landowners and other agenczes “i 


% ix Means of transport (vehicle, animal, bird, etc.) 
2 2. Existing vegetation. Identify the vegetation growing on the s: 
- of the infestation. Include an estimate of crown density by 


species. 


~ 
" 


i 3. Identify soil and land conditions. This includes recent 
= | disturbances such as road construction, road maintenence. 
logging. catastrophes such as fire, landsiide, etc.. 


information that may be available such as distance from the 


4 4, If available, identify closest seed source and other a 
= Forest, property owner, travel route. etc.. 


A-7 | 








Priority ail 
Established Infestations: 


weed species in this priority have become well established and eradication is 
not economically or environmentally feasible within the boundaries of the IPNF. 
Generally the treatment for these invaders will be by biological control 
methods. Exceptions may be around campground, administrative sites, seed 
orchards and similar areas where mechanical mowing may be in order or chensica? 
treatment followed by revegetation with desirable plants to reduce opportunity 
for re-invesion by noxious weeds. Seeding of desirable plants and 
fertilization may be a control in may areas that are now a problen. 


This treatment priority includes the following: 
A. Emphasis will be on containment and preventing further spread. 


Be Special consideration will be given to "breakouts" from established 
infestation and along routes of spread, or adjacent to private lands. 


Acceptable, but immediate and effective control measures will be taken 
in such ereas. 


CA Any approved control measure may be used on established infestations, 
however, the decision on which to use will include the "cost/benefit 
of the alternatives and an evaluation of the likelihood for success. 


Ba Biological control will be emphasized on established infestations 
where successful agents are available and an evaluation shows there is 
reasonable expectation for success. Research Application and 
Development (R&D) efforts on biological control agents will be 
concentrated on Priority III species. 


Ee Management practices will be used in conjunction with control 
activities. These management practices include, but are not to be 
ienired: toc 


1. Promoting the introduction/growth of both native and non-nat-ve 
species of vegetation that will better compete with noxious weeds. 


2. Regulating the movement of and/or the use of livestock. 


3. Regulating the movement of and/or the use of vehicles. 


A-8 





ONT ate a cet ce ni et ON SER, St TOTITT 


eee ee 


ee Re ae ee Yee ee ee | a ww 


we gee Oye Pee Te 


. 
: 





PROPOSED FIVE YEAR IWM PROGRAM OBJECTIVES FOR NEW INVADERS Z Hi 


Summary: New invaders are isolated stands of noxious and other undesirable (a 
weeds whose population levels outside a specified area or region are such tha}™ 
all seed production can be prevented each growing season. Based on informatic:. 

gathered during inventory work (1987 & 1988) nine plant species have been 1 


identified on the Forest which meet this definition. As yet, none of the ni 


species occur in large enough population levels that they are causing any 


significant resource damage. However, all the species are highly aggressive. 
competitive and difficult to control. If left unchecked all will estabiisn © 
the Forest, impacting resources. Once established the financial burden of 

control would be staggering. Hence, control strategies are being implemented 


now while the numbers of weeds are few and the acreage affected are smal:. | 
This results in lower costs then if these weeds are allowed to become 





established. 


es which can be measured to 


Project objectives (statements of precise outcon 
determine actual accomplishments): 


his project is immediate containment (100% 


The overall objective of t 
Ultimately, howeve 


control) of the nine species listed as new invaders. 
he objective is to eradicate all infestations. 


ass 


2. To take appropriate control measures as soon as a new invader is officia 
identified to prevent all seed production. This will require follow-up — 
treatment each growing season until the invader is eradicated. 


2. To maintain a New Invader list on each Ranger District and Maintearo oan 
elert program that aids in early detection of new locations. 


4. To give highest treatment priority to funding control efforts on new 
invaders. 


5. To hold annual in-service weed education and identification courses anc 
reguire attendance. 


6. To provide weed education and identification clinics and training in 
cooperation with Counties and other organizations (an example is a Back 
Country Horsemen Clinic being held in 1989, cooperative work with the Nor 
Idaho Weed Association and the Idaho Weed Control Association) 


- To identify and develop strategies for a realistic and systematic survey 
all lands susceptible to invasion within the boundaries of the IPNF. 
Surveys will be scheduled to coincide with bloom periods to aid in 


detection. 


~ 


&. To identify high risk areas outside the areas of infestation and monitos 
tnese at high risk areas on an on-going basis. 


aw® 


2) 


9. To identify defendable weed barrier lines for each species conmcentrati 
control effort at the perimeters working towards the center of the 


infestation. 








Oe ee et ee ee 


10. 


ee 


Lae 


Ley 


14, 


16; 


To maintain a map record showing locations of all found infestations and 
keep maps up to date. 


To identify rehabilitation needs for ali sites in the project areas and 
carry through with rehabilitation. = 


To advise all agencies and organizations with a vested interest in 


manegement of the IPNF about these projects and to solicit their support 
and assistance. 


To identify and treat the causes of the infestations to reduce the 
possibility of re-invasion. 


To coordinate mapping and surveys with State and Local agencies maxinize 
efforts. Enlist support of volunteers, agencies and organizations such es 
the Idaho Wildlife Federation, Back Country Horsemen, Kootenai 
Environmental Association and Counties to help with inventory work. 


To supplement surveys with awareness posters at strategic locations 
throughout the Forest. 


To report all new invader locations to the University of Idaho which 
maintains a statewide inventory. 


A-10 


EO Oe ee oe Te ee ee 


: 





PROPOSED FIVE YEAR IWM PROGRAM OBJECTIVES FOR POTENTIAL INVADERS 1 





Summary: Potential invaders are noxious and other undesirable weeds as yetmy 
unrecorded on the IPNF but the potential for infestation is imminent. Peop] gm 
who work within the Forest Service as well as users of Forest resources needa 
the knowledge and ability to recognize these exotic species and what to co | 
about them when they are found or thought to exist. Thus, the emphesis in i 
proposed program is education, awareness, and prevention. During the 
environmental analysis, 28 species were identified as potential invaders -- } 
species are recognized as most likely to invade within the next 5 years. E | 
detection of the Forests future weed problems before they get out of hand a} 
good resource management. 
1. The overall objective is early detection of noxious and undesirable | 
while infestations are such that all seed production can be prevented al 
prevention of the conditions which allow them to invade the Forest. 


Project objectives (statements of precise outcomes which can be measured to 
determine actual accomplishments): 








2. To continue to participate and further develop programs with individual 
organizations, other federal agencies and state and county agencies to 
inform on the means of helping prevent and control these weeds. This 
includes providing clinics, publications and distribution of brochures if 
provide information on the "most likely" potential invaders. ’ 


To expand in-service training and involvement to reach more of those 
working on the Ranger Districts (including volunteers and other 
cooperators) in identification, proper reporting procedures, monitoring é& 
treatzent of potential invaders. IE 


LS) 


4. To use the University of Idaho form and instructions for submitting 
specimens (see Appendix J). 


5. To begin collecting initial information on potentiel invaders (i.e. A 
biology of the weed and of known natural enemies; the biology of the 
ecosystem surrounding the weec; monitoring techniques; non-toxic manag 
technigues; and chemical tools ideally used to quickly suppress the co 
outbreak). First priority will be given to the 10 most likely to invace 





tne next five years. 

6. To prioritize the potential invader list for development of surveys. R 
highest priority to those species which occur adjacent to Forest Service 
lands, species which occur along waterways which run through the Fores 
which occur along major transportation routes which run through the Fo 







7. To complete initial surveying for the 10 potential invader species thrq@ 
out tne Forest. 


8. To establish an annual weed alert and survey program on the Forest. 


To obtain herbarium specimens of potential invaders and display at i 
Ranger District Offices. 


We) 


Aq-1i 





10. To develop educational materials for distribution to Forest users. 


To take immediate action when potential invaders are identified to prevent 
all seed production. 


12. To immediately survey, identify, and locate on maps locations of all found 


potential invaders. Continue annual survey work for the found potential 


invaders until there is assurance the weeds are eradicated (5 or more years 
in some cases). 


tee www 


; 
| 
| 





PROPOSED FIVE YEAR PROGRAM OBJECTIVES FOR ESTABLISHED INVADERS 
Overview: 


Established invaders are noxious and 
the IPNF that for ell practical purposes seed pro 
prevented. 

however to attempt to contain exis 


undesirable weeds so common cr 
Therefore eradication is.not technically feasible. 
and prevent the establishment of new 
management activities. 





s 







duction can not be reasonab- 
It is feasil 
ting infestations, reduce infested acreage’ 
infestations as a result of land 
The primary purpose 
protection of uninfested acres of range. 
Within ithe bcuncaties of athe .leNre 


of this program shall be the 


forest, recreation and pasture ian 
determine actual accomplishments): 
1 


Project objectives (statements of precise outcomes which can be measured ol 
goal. 








The main cbjective is containment, with annual reduction as a long- tera ill 
2. To emphasize and prioritize control measures in recreational areas and ¢ 
along routes of spread. Control shall be prioritized beginning with -- 
of highest human usage. 
3. To locate, map and cause control of isolated infestations of spotted i 
knapweed and St. John's-wort. 
= ‘LU. To coordinate control efforts of northern Idaho counties. Such 
3 coordination will stress elimination of duplication and will encourege 
¥ cooperation and sharing of educational materials. 
on users of the Forest. 
; 6p 


meet objectives. 


To develop a targeted, Forest-wide education end awareness program foc 
To follow-up initial control efforts with site specific management ef 


~ 
. 






. 


‘7 
To determine site-specific injury/action levels using the criteria te 
Policy Priority III). 
SB. 


including seeding, fertilization, and other spot treatment as needec t 
recommended by the Idaho Noxious Weed Workgroup ( ppendix A - Noxious wé- 


To use management practices in conjunction with control activities. 
management practices include, but are not limited to: 





i. 
-- Promoting the introduction,growth of both native and desirable ii 
non-native vegetation that will better compete with targeted weeds. 


-- Regulating the movement of and/or use of livestock. 


-- Regulating the movement and/or use of vehicles. 


harvest sites. 


* 
-- Use the knapweed road model (Appendix E)or a similar method to pred 
the risk of knapweed invasion on all new road construction and 


timber 





ome 


_ mee 


wee 


\O 


* 
-- Use the Losenski knapweed road model (Appendix E) or a similar method 
to predict the risk of knapweed invasion on all new road construction and 
timber harvest sites. Use the risk rating to determine mitigation measures 
necessary to reduce target weed invasion risk. 
-- where practical, retain shade on road surfaces by limiting road-side 
clearing and harvest cutting. 


-- Newly constructed roads should be surveyed and all new knaepweed and St. 


Johns-wort plants pulled or spot sprayed seasonally as a part of road 
maintenance. 


-- Conduct a survey of existing roads. Those segments that are currentl 
free of knapweed and St. John's-wort should be treated as new constructicn. 


-- Evaluate the proposed cutting unit as to the risk of spotted knapweed 
invasion using the models in Appendix E). 


-- Consider requiring "clean" equipment for timber harvest in high risk 
ereas where spotted knapweed and St. John's-wort are not present. 


-- Use dozer scarification only when it is the only prectical treatment on 
moderete and high risk areas. This treatment should be carried out with 
"clean" equipment. 


-- Creme Re prescriptions should be directed at maintaining es much 
de as possible on site and limiting the amount of soil disturbance to 
t regeneration needs. On high risk areas, consider using single tree or 
ignt shelterwood harvest method. 

Luate the risk of permitting cattle use after harvest on high risk 
s (Cattle use occurs on about 3 percent of the Forest). 


-- Consider winter logging on high risk areas where seed is present to 
educe the threet of seed transfer to uninfested sites in the stand. 


-- Consider seeding non-sod forming grasses.and forbs to occupy disturbed 
tes on high risk areas. 

To expend and further the establishment of host-specific biological agent 

cn St. John's-wort and spotted knapweed and establish specific areas for 

repid colonization of new bioagents for future redistribution. Once 

established these areas will provide sites for training and education 

purpcoses. 


--Appropriate release sites for colonization of biological control agents 
11 be determined. Release site will be chosen depending on the severity 
the weed infestation, present and planned land use and weed control 

fforts. Releases will be made in densely infested areas. The number of 

agents released at any site will be that which is deemed optimum for fieid 
establishment. Where necessary, cooperation from permittees will be 
secured to protect the release sites from disturbance from people or 
livestock. 





q 
~ | 
P| 
Ee | 
| 











-- To collect and/or purchase biological agents. 


-- To develop a recordkeeping system and regularly monitor release sized 
ascertain colonization and establishment. 


-- To monitor the population development and spread of the colonized a 
agents. 


bioagents. Training will include procedures for collection and release 


-- To train in-service personnel on identification and life history of { 
--Purchase and/or develop educational materials which help the public a: 
involved agency personnel understand the major role biological control 


pleys in an integrated weed management progran. 


-- If appropriate, quantitative evaluation of the bioagent populations i” 
be performed following the guidelines and procedures set by Dr. Joe 
McCaffery, University of Idaho or a similar survey procedure. 


& 
Losenski's models may need modification to meet the 


climatic and environmental characteristics found on the IPNF. 


A=15 





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APPENDIX B 











HARVARD UNIVERSITY 
SCHOOL OF PUBLIC HEALTH 


DEPARTMENT OF HEALTH Poticy AND MANAGEMENT 677 Huntington Avenue 
(617) 732-1090 Boston, Massachusetts 02115 


February 1, 1990 


Dr. Richard E. Stuckey 
Director 
The National Association 

of Wheat Growers Foundation 
415 Second Street, N.E. 
Suite 300 
Washington, DC 20002 


Dear Dr. Stuckey: 


In response to your request for an independent review of the 
evidence on 2,4°D and cancer, I _ have the pleasure of 
transmitting to you the final report of the workshop held 
October 17°19, 1989. The report considers both the 


toxicological (animal) and epidemiological (human) evidence. 


The toxicology data by itself provides little reason to expect 
that 2,4=-D causes cancer in people. Experimental studies have 
shown an excess of brain tumors in male rats at the highest 
levels of exposure but not in female rats or mice of either 
gender. Further research is necessary to generate reliable data 
on the effects of high doses ingested by male rats. If 2,4-D is 


ultimately shown to be an animal carcinogen, it is unlikely to 
be a very potent one. 


weighing the epidemiological evidence, the workshop concluded 
that a cause-and-effect relationship between 2,4-D and cancer is 
far from being established. The results of two studies 
conducted by the same research tean suggest an association 
between the occupational use ef 2,4°-D and non-Hodgkin's 
lymphoma. However, the workshop participants felt this 
association needs to be interpreted cautiously, first, because 
other studies have not shown the sane results and second, 
because some factor other that 2,4-D might be involved. 
Additional epidemiological studies already underway in the 
United States, Canada, New Zealand and Sweden will address this 
question. 


Based on all available evidence, the panelists were asked to 
assess how likely it is that exposure to 2,4-D is capable of 
causing cancer in people. None of the panelists felt that the 
evidence was strong enough to conclude that 2,4-D is either a 
known or probable cause of cancer. Of the 13 panelists, 11 felt 
it is possible that exposure to 2,4-D can cause cancer in 
humans, though not all of them felt the possibility was equally 
likely: one thought the possibility was relatively strong, 


leaning toward probable; and five thought the possibility was 
relatively remote, leaning toward unlikely. A minority of two. 
participants felt it was unlikely that 2,4-D can cause Cancer in 
people. Several members felt that the evidence was barely | 
adequate to support any conclusion. (The panel stressed that it 
used the terms "probable" and "possible" in their ordinary sense 
and not as reference to specific carcinogen classification 
categories used by any regulatory agency.) 


As a means of resolving these issues, workshop participants 
stressed the need for future studies to develop more reliable 
and precise estimates of 2,4-D exposure and to distinguish more 
Clearly between 2,4-D and other agents in the collection and 
analysis of data and the reporting of results. 


In closing, I would like to recognize the distinguished panel of 
workshop participants and project staff for their thorough, 
expert evaluation of the complex body of scientific literature 
on this widely-used product. 


Yours sincerely, 


Qe De 


hn D. Graham, Ph.D. 
Director ; 
Program on Risk Analysis and Environmental Health 








APPENDIX C 





APPENDIX C 
PROCEDURES FOR MIXING, LOADING, AND 
DISPOSAL OF PESTICIDES 


The following measures will apply to all pesticide applications. 
1. All mixing of pesticides will occur at least 100 feet from surface waters or well heads. 
2. Dilution water will be added to the spray container prior to addition of the spray concentrate. 


3. All hoses used to add dilution water to spray containers will be equipped with a device to prevent 
back-siphoning. 


4. Applicators will mix only those quantities of pesticides that can be reasonably used in a day. 


5, During mixing, mixers will wear a hard hat, goggles or face shield, rubber gloves, rubber boots, and 
protective overalls. 


6. All empty containers will be triple rinsed and rinsate disposed of by spraying near the application site at 
rates that do not exceed those on the Spray site. 


7. All unused pesticide will be stored in a locked building in accord with pesticide storage regulations 
contained in Forest Service Handbook 2109.13. 


8. All empty and rinsed pesticide containers will be punctured and either burned or disposed of in a sanitary 
landfill. 


APPENDIX D 





APPENDIX D 
SPILL PLAN 


The following equipment will be available with vehicles or pack animals used to transport pesticides and in 
the immediate vicinity of all spray operations. Mi 


ONO nhWDND — 


. A shovel 

. A broom (except backcountry operations) 

. 10 pounds of absorbent material or the equivalent in absorbent pillows. 
. A box of large plastic garbage bags. 

. Rubber gloves 

. Safety goggles 

. Protective overalls 

. Rubber boots 


The appropriate Material Safety Data Sheets will be reviewed with all personnel involved in the handling of 
pesticides. 


The following material from the U.S. EPA document entitled Applying Pesticides Correctly: A Guide for Private 
and Commercial Applicators will be reviewed with all personnel involved in handling pesticides. 


CLEAN UP OF PESTICIDE SPILLS 
Minor Spllls 
Keep people away from spilled chemicals. Rope off the area and flag it to warn people. Do not leave 
unless someone is there to confine the spill and warn of the danger. If the pesticide was spilled on 
anyone, wash it off immediately. 


Confine the spill. If it starts to spread, dike it up with sand or soil. Use absorbent material such as soil, 
sawdust, or an absorbent clay to soak up the spill. Shovel all contaminated material into a leakproof 
container for disposal. Dispose of it as you would excess pesticides. Do not hose down the area, 
because this spreads the chemical. Aways work carefully and do not hurry. 


Do not let anyone enter the area until the spill is completely cleaned up. 


Major Spills 

The cleanup of a major spill may be too difficult for you to handle, or you may nc be sure of what to 
do. In either case, keep people away, give first aid if needed, and confine the spill. Then call Chemtrec, 
the local fire department, and State pesticide authorities for help. 


Chemtrec stands for Chemical Transportation Emergency Center, a public service of the Manufactur- 
ing Chemicals Association. Its offices are located in Washington, D.C. Chemtrec provides immediate 
advice for those at the scene of emergencies. 


Chemtrec operates 24 hours a day, seven days a week, to receive Calls for emergency assistance. For 
help in chemical emergencies involving spills, leaks, fire, or explosions, Call toll-free 800-424-9300 day 
or night. This number is for emergencies only. 


If a major pesticide spill occurs on a highway, have someone call the highway patrol or the sheriff for 
help. (Cary these phone numbers with you.) Do not leave until responsible help arrives. 


D-1 


In addition the section from the Northern Region Emergency and Disaster Plan entitled *Hazardous Materials 
Releases and Oil Spills' will be reviewed with all appropriate personnel (See following pages). Notification and 
reporting requirements as outlined in this section will be followed in the unlikely event of a serious spill. 


HAZARDOUS MATERIALS RELEASES AND OIL SPILLS 
(Excerpted from the Northern Region Emergency and Disaster Plan) 


AUTHORITY: Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); and 
Supertund Amendments and Reauthorization Act of 1986 (SARA). Other statutes that may apply include 
Resource Conservation and Recovery Act (RCRA); Hazardous and Solid Waste Amendments (HSWA); Toxic 
Substances Control Act (TSCA); Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); Clean Water 
Act (CWA); and Clean Air Act (CAA). 


DEFINITION: A hazardous materials emergency or oil spill is defined as any release or threat of release of 
a hazardous substance or petroleum product that presents an imminent and substantial risk of injury to heatth 
or the environment. 


A release is defined as any spilling, leaking, Pumping, pouring, emitting, emptying, discharging, injecting, 
escaping, leaching, dumping, or disposing into the environment. 


Releases that do not constitute an immediate threat, occur entirety within the work place, are federally 
permitted, or are a routine pesticide application, are not considered to be an emergency and are not covered 
by this direction. 


RESPONSIBILITY:The first person who knows of a release and is capable of appreciating the significance 
of that release has the responsibility to report the release. 


Only emergency release response and reporting is covered by this direction. Non-emergency reporting will 
be accomplished by appropriate RO staff specialists who should be notified directly of all non-emergency 
releases. 


An emergency release of a hazardous substance or petroleum product may be from a Forest Service 
operation or facility; from an operation on National Forest land by a permit holder, contractor, or other third 
party; or from a transportation related vehicle, boat, pipeline, aircraft, etc., crossing over, on, or under Forest 
lands. Response and/or reporting by Forest Service employees will differ in each situation: 


1. ‘ifthe release is from a Forest Service facility or operation, the Forest Service and its employee(s) 
is clearly the “person in charge," and is fully responsible for all reporting. Immediate response 
action is limited to that outlined in emergency plans and Only to the extent that personal safety 
is not threatened. 


2. i the release is from a third party operation, the Forest Service will only respond and/or report 
the emergency ff the third party fails to take appropriate action. 


3. Ifthe release is from a transportation related incident, the Forest Service will only respond and/or 
report the emergency if the driver or other responsible party is unable or fails to take appropriate 
action. 


RESPONSE ACTION GUIDE: THE PRIMARY RESPONSIBILITY OF ANY FOREST EMPLOYEE(S) ENCOUN- 
TERING A HAZARDOUS MATERIALS EMERGENCY OR OIL SPILL IS COMPLETE AND ACCUKATE REPORT- 
ING TO APPROPRIATE AUTHORITIES IN A TIMELY MANNER. 

Forest Service employee(s) will not assume an incident command role for any hazardous materials emer- 
gency or oil spill, but may provide support services as directed by an authorized Federal On-Scene Coordina- 
tor (OSC) or other State or local authorized authority. ; 

Within the limits of personal safety, common sense, and recognition of the dangers associated with any 
hazardous materials emergency or oil spill, Forest Service employee(s) may provide necessary and immedi- 
ate response actions until an authorized OSC or other authority can take charge. These actions may include: 


- Public warning and crowd control. 
- Retrieval of appropriate information for reporting purposes. 


Additionally, and only after verification of the type of hazardous material involved and its associated hazards, 
a Forest Service employee(s) may also take actions including: 


- Rescue of persons in imminent danger. 
- Limited action to mitigate the consequences of the emergency. 


Under no condition shall a Forest Service employee(s): 


- Place themselves or others in imminent danger. 
- Perform or direct actions that will incur liability for the Forest Service. 


IF THERE IS ANY QUESTION THAT THE EMERGENCY MAY CONSTITUTE A THREAT TO PERSONAL 
SAFETY, LIMIT YOUR RESPONSE TO PUBLIC WARNING AND REPORTING OF THE INCIDENT. 


PRECAUTIONS: When approaching the scene of an accident involving any cargo, or other known or 
suspected hazardous materials emergency including oil spills: 


Approach incident from an upwind direction, if possible. 

Move and keep people away from the incident scene. 

Do not walk into or touch any spilled material. 

Avoid inhaling fumes, smoke, and vapors even if no hazardous materials are involved. 
Do not assume that gases or vapors are harmless because of lack of smell. 


Do not smoke, and remove all ignition sources. 


ORGANIZATIONS FOR EMERGENCY AND TECHNICAL ASSISTANCE: 


CHEMTREC - Chemical Transportation Emergency Center - 800-424-9300 
(24 hour) (For assistance in any transportation emergency involving 
chemicals.) 


Rocky Mountain Poison Control Center - 800-525-5042 (24 hour) 
303-629-1123 (24 hour) 


National Agricuttural Chemicals Association - 202-296-1585 
(For pesticide technical assistance and information referral.) 


Bureau of Explosives - 202-293-4048 
(For explosives technical assistance.) 


Centers for Disease Control - 404-633-5313 
(For technical assistance regarding etiologic agents.) 


EPA Region 8 (MT, ND, SD) 
Emergency Response Branch - 303-293-1723; FTS 564-1723 


EPA Region 10 (Idaho) 
Superfund Removal and Invest Section - 206-442-1196; FTS 399-1196 


Montana Department of Health and Environmental Sciences (24 Hour) 406-444-691 1 
Water Quality Bureau - 406-444-2406 
Solid Waste Managemen Bureau - 406-444-2821 


North Dakota State Health Department 
Environmental Engineering - 701-224-2348 
Hazardous Waste Division - 701-224-2366 
Radiological Hazardous Substances - 701-224-2348 


South Dakota Division of Environmental Quality : 
Office of Water Quality - 605-773-3296 
Office of Solid Waste Management - 605-773-5047 


Idaho Department of Heatth and Welfare | 
Water Quality Bureau - 208-334-5867 
Solid Waste Bureau - 208-334-5879 


HAZARDOUS MATERIALS RELEASES AND OIL SPILLS -- CONTACT LIST 
AND IMMEDIATE ACTION GUIDE 


INDIVIDUAL 


Do not expose yourself or others to any unknown 
matenal. 
a. Do not attempt rescue or mitigation until 
material has been identified and hazards and pre- 
Cautions noted. 
b. Warn others and keep people away. 
c. Approach only from upwind. 
d. Do not walk in or touch material. 
e. Avoid inhaling fumes and vapors. 
f. Do not smoke, and remove ignition sources. | District Dispatcher or Ranger 





Report the incident. Complete "Reporting Action 
Guide’ within reasonable limits of exposure and 
timeliness, and report information to District/ 
Forest Dispatcher. 


If there is any question that incident is a threat to 
personal safety, limit response to public wamings 
and reporting. 


HAZARDOUS MATERIALS RELEASES AND OIL SPILLS -- CONTACT LIST 
AND IMMEDIATE ACTION GUIDE 


DISTRICT 


Forest Dispatcher 


e 















Insure reporting individual is aware of hazards as- 
sociated with incident. 










Obtain as much information as possible, complete 
@ Copy Of the "Reporting Action Guide," and relay 
all information to Forest Dispatcher. 








For fixed facilities, verify if possible, whether or not 
an emergency guide, Spill Prevention Control and 
Countermeasure Plan, or similar response plan is 
available for the specific emergency. If so, imple- 
ment the response actions as indicated. 


Dispatch additional help, communications sys- 
tems, etc., to incident scene if incident is on Na- 
tional Forest land or is caused by Forest Service 
activity or facility. Otherwise support as requested 
by official in charge. 









If there is any question that incident is a threat to 
personal safety, limit response to public warning 
and reporting. 






HAZARDOUS MATERIALS RELEASES AND OIL SPILLS -- CONTACT LIST 


AND IMMEDIATE ACTION GUIDE 


FOREST 


Immediately contact the Forest Hazardous Materi- 
als Incident Coordinator who will take the following 
actions: 

a. Determine ff incident is true emergency. 

b. Determine who is responsible party for inci- 
Gent, and whether appropriate actions and report- 
ing have been accomplished. 

c. From available information, determine haz- 
ards and precautions, if possible, and relay further 
instructions to reporting individual through the 
District. 

d. Initiate appropriate local reporting actions, 
and coordinate responses with District. * 

e. Arrange Forest support for on-scene coordi- 
nator and/or local emergency response officials 
as requested. 


Make appropriate local emergency contacts as 
directed by Forest Hazardous Materials Incident 
Coordinator. 


Relay information from Forest Hazardous Materi- 
als Incident Coordinator back to District and up to 
Regional Office as appropriate. 


Forest Hazardous Materials Incident Coordinator who 
will determine extent of emergency. If incident is de- 
termined reportable, contact: 

a. National Response Center (X9). 

b. EPA Hazmat emergency response (X3). 

c. Regional Incident Dispatcher (1). 

d. County sheriff and/or county disaster and emer- 
gency services coordinator. 

e. State Emergency and Disaster organizations 
(X12, X15, X17, X21) 

f. North Dakota State Fire Marshal for oil spills ir, 
North Dakota only (X19). 

g. Internal Forest contacts. 





HAZARDOUS MATERIALS RELEASES AND OIL SPILLS - CONTACT LIST 
AND IMMEDIATE ACTION GUIDE 


REGIONAL INCIDENT DISPATCHER 







































Immediately contact the Regional Hazardous Ma- 
terials Incident Coordinator who will take the fol- 
towing actions:: 

a. Personally work with Forest Hazardous Mate- 
rials Incident Coordinator to determine extent of 
the emergency. If incident is reportable, imple- 
ment the following actions: 

(1) By Data General (DG) mailing list notity: 
Regional Forester, Deputy Regional Foresters, 
Staff Directors, Attorney-In-Charge (OGC). 

(2) Contact other RO specialists, other 
Agency personnel, etc., as necessary to deter- 
mine scope of problem and appropriate actions. 
RO specialist contacts include: 

(a) Regional Watershed Coordinator (if 
incident involves streams, lakes, rivers, etc.) (2) 

(b) Regional Reclamation Officer (if inci- 
dent involves mining) (12) 

(c) Regional Safety and Health Program 
Manager (6) 

(d) Regional Cooperative Forestry and 
Pest Management (if pesticide related) (13) 

(3) Arrange Regional support for on-scene 
coordinator and/or local emergency response offi- 
cials as requested. 

(4) Arrange a Regional investigationfollowup 
team if determined to be necessary. 

(5) Keep Regional Forester, Staff Directors, 
and OGC advised of situation via routine DG up- 
dates. 












Regional Hazardous Materials Incident Coordinator 


(11) 





Hf incident is determined to be reportable, verity that 
National Response Center and appropriate Federal, 
State, and loca! contacts have been made. 










WO Personnel Management (Safety and Health) (W4) 


HAZARDOUS MATERIALS RELEASES AND OIL SPILLS -- CHECKLIST 


HAZARDOUS MATERIALS AND OIL SPILLS REPORTING ACTION GUIDE 


Atthough reporting requirements vary depending on the type of incident, the responsibility of the employee(s) 
in the field is limited to collecting appropriate information and relaying it to the proper level of the organization 
in a timely manner. Following is a list of the information that should be collected, if possible; however, it ts 
more Important to maintain personal safety and report In a timely manner than to collect all information. 


1. Date: Time of release: 
Time discovered: 
Time reported: 
Duration of release: 
2. Location:(Include State, county, route, milepost, etc.) 
3. Chemical name: 
Chemical identification number: 
Other chemical data: 
NOTE: For transportation related incidents, this information may be available from the driver, placards on the 
vehicle, and/or shipping papers. 


4. Known heath risks: 
5. Appropriate precautions if known: 
6. Source and cause of release: 


7. Estimate of quantity released: gallons 
Quantity reaching water: gallons 
Name of affected watercourse: 


8. Number and type of injuries: 
9. Potential future threat to health or environment: 


10. Your name: 
Phone number for duration of emergency: 
Permanent phone number: FTS Commercial 





For transportation related incidents, also report: 
41. Name and address of carrier: 
12. Railcar or truck number: 


tf there is any doubt whether an incident is a true emergency, Or whether reportable quantities of hazardous 
materials or petroleum products are involved, or whether a responsible party has already reported the 
incident, always report the Incident. 











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APPENDIX E 








Uniced States 
Department of 
Agriculture 


Forest 
Service 


Bonners Ferry 
Ranger District 
(208) 267-5561 


Route 4, Box 4860 
Bonners Ferry, ID 
FAX (208) 267-7423 


83805-9764 


Re 


Reply toi “2670 Date: 6/7/95 
Subject: Sensitive Fish Biological Evaluation 
for Nexious Weed EIS 
To: District Ranger, Bonners Ferry 
i. introduction 
U.S.D.A. Forest Service policy (FSM~2672.4) requires a Biological 
Evaluation (B.E.) to be completed to review programs Or activities in 
Sufficient detail to determine how a project or proposed activity may 
éziect any threatened, endangered, proposed or sensitive species. The B.E. 
precess is intended to analyze and document activities necessary to ensure 
Proposed management will not jeopardize the continued existence or cause 
adverse modification of habitat’. 
wné purpose of this B.E. is to evaluate the potential effects of the 
roposed Noxious Weed EIS on threatened, endangered, and sensitive fish 
Species, and determine whether any such species and habitat are likely to 
be acversely affected by the proposed action. 


5 
e. 


eee Ge 


eee eee = 


Meee eee 


Cultural 


Biologica 


ction will use a combination of manual, cultural, biological, 
atments to control noxious weeds. Each treatment is 


a 9) 


O 


= 


range from hand pulling and grubbing with hand tools 
the plants with scythes or other cutters. If 
removed, the individual plant can be destroyed. 
reduce reproduction of perennial plants and weaken 


iS ese 


Control: 


ontrol generally involves manipulating a site to increase the 
ive advantage of desirable species and decrease the competitive 

of undesirable species. Manipulations could involve 

ting native plants to shade out weedy species or covering 


contaminated soil with a layer of uncontaminated soil. Seeding 
cies and applying fertilizer on site where ground cover is sparse 
p to culturally control weeds. 


DeControL: 


bictessecaimace 

hown some promise in reducing weed infestations. At the present time 
relatively few biclogical control agents are available that are effective 
aceéinst the weed species of concern here. 


Biclegical control is the use of biotic agents to attack undesirable plant 
species. Populations of native species are generally limited in part by 
herbivorcus and pathogenic organisms as well as by competition for 
nutrients and moisture. Non-native vegetation has had a dramatic impact in 
man rts of the West because it has been introduced without biological 


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ents present in its place of origin. The introduction of these 
ents is viewed by most experts as the best long-term solution to 
cious weed problem. 


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Currently, two biocontrol agents, Urophora affinis and Urophora 
ouadrifasciatus, are present in some knapweed infestations on the district. 
In sufficient concentrations these seedhead flies can reduce seed 
Ercducticn by 50 te 90 percent. However, knapweed is such -ayproliiicrseed 


producer that these organisms have had no effect on the density of the 
@ [Ome anoeletrule eLLects Onuiis ratemoLaspredc) 





Several ciclogical agents are currently being introduced into the United 
States for the control of Canada thistle. Ceuvutorhynchus litura is a stem 
minzsce weeval which attacks the young Canada thistle plants in early 
spring. The stem mining larvae internally attack the elongating stem in 
€ariy summer. As the larvae develop they begin to create numerous exit 
holes near the root crown leaving the plant succeptible to a variety of 
tient pethogens. Under ideal circumstances (soil, size of anftestation, 
climezre etc.) Eecrulacion densities may be reduced up to 90 percent 
depending er the number of weevils released at the infestation (Rees, 
Urorn=*2 Sargui is a stem and shoot. gall. fly which attacks Canadastnistie. 
Adults deposit their egas on the axil of the stem in early summer. As the 
larvae develop they burrow into the stem creating a walnut size bowl or 
o@.1. The gall formation diverts the normal nutrient translocation away 
from the metobolic and reproductive systems of the plant. As a result 
flowers Gevelop abnormally, and seed production is reduced. 

Chrvsclirné ouedrioemina is a defoliating beetle which attacks St. Johnswort 
or goatweed This defoliating beetle has successfully reduced the density 
cf this weed in locations where fall temperatures are mild and the rainfall 
LEAL Ce Le There have been introductions of this beetle annually since 
7650. Tne beetle is thriving and is found at several locations on the 
Gistrict. There is evidence of St. Johnswort populations suffering the 
effects of defoliation by this beetle. 

Climatic and habitat conditions are expected to play a major role in the 
success of biological control agents. The adaption of these biocontrol 


organisms to the habitats currently infested by Canada thistle remains an 


it chose hosbennored wher biological control agents will not completely 
€réarcste &@ noxious weed infestation. Rather, a biological control strategy 
wWou.c allow the weed species to spread, though at lower density, through 
Gis SUitacie habitats in the forest. 


Chemical Control 


Four herbicides, 2,4-D, dicamba, clopyralid, -and picloram, were considered 
ication on various sites. 2,4-D is herbicide with very little 

€ in the environment. The herbicide has low toxicity to aquatic 
end several formulations are approved for use in water and near 

eater. As noted above, aquatic applications are not proposed in this 

rogrem. At application rates of 1 to 1.5 pounds PeTreacre »2,.4-D exhibits 

control of knapweed with repeat applications and moderate control of 

gce tweed, houndstcngue, sulfur cinquefoil, and Canada thistle. 


e broadleaf herbicide that is readily absorbed by leaves and 
a is concentrated in the metabolically active Darts.ch the ‘plants. 
tive against a similar range of weed species as 2,4-D at 
ation rates. However, dicamba is somewhat more persistent 
herbicide and thus provides somewhat longer control of 


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only three plant families: the composites, the legumes, 
At application rates of one-quarter to one-half pound 


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Ficicram controls @ variety of broad-leaved weed species, including all the 


weeds species of concern here. Picloram is generally applied at rates of 
one-guarter to one-half pound per acre. However, picloram’s combination of 
mobility and persistence have generated concern over possible ground-water 
contamination. Possible environmental impacts are compared between this 


method and the other chemical and non-chemical control methods. 
Control with a combination of chemical and non-chemical control 


Site conditions such as vegetation types, soil types, and infestation 
levels vary significantly on some sites under consideration in this EIS. 
Therefore a combination of chemical and non-chemical methods may be 
selected for some sites. The selection of a herbicide alternative for a 
site would not prevent the application of manual methods either 
ncurrently or as a follow-up treatments on remnant weeds ona site. 


i) 
O 


Control with mixtures of the herbicide Picloram and 2,4-D 


Some control specialists treat several noxious weed species with mixtures 
ofak2e4-2Dwand proloram., \Use of a mixture’ is done to reduce the quantity of 
the cicioram to half of what is normally applied ana thus reducing the 
amount Of effects On non-target species’. 
Herbicide prescriptions would be consistent with or more restrictive than 
preduct=tebel nequirements. If a herbicide is used in the annual 
floodpléein, the Forest Service would only apply a herbicide formulation 
approved by the U.S. Environmental Protection Agency forsdirect 

ms t 


Cc water. 
3. Action/Evaluation Area 


lementation is proposed on 41 sites on the Bonners Ferry Ranger District 
undery County). The size of these sites range from .48 acres in Myrtle 
tc 33 acres in Saddle Creek. Over 83% of the 41 sites identified with 
€ ions are located along roads and trails. For more specific location 
ermation refer to the Noxious Weed EIS. 


9) 
+ 16%. 
jw 


4. Listed Species 


ervice Region 1 has identified three sensitive species 
nt in the analysis areas (U.S.D.A. 1989 and 1991). These 
sc considered Species of Special Concern by the State of 


on WM 





Eull Char, Salvelinus confluentus ° 
Redband Trout, Oncorhynchus mykiss 


Tre poll cher is now considered a Category Cl species under the Endangered 
Specsese Actes (19789 The U.S. Fish and Wildlife Service decided on June 8, 
1262. ~Sar ther buldecharadsS warkanted but (precluded from listing. On 

February €, 1995 the USFWS changed the bull char status to warranted. This 


meerns sionificant threats exist to the continued existence of the species 
i “S is in the process of drafting regulations. Redband and are 


ars 5 

listed es a C2 species under the Endangered Species Act (1973). 

Westslope cutthroat are.listed as a Category species, as of November 15, 
1994, under the Endangered Species Act, (1973). This means that the U.S. 

Fish and Wildlife Service indicates that proposing to list as endangered or 

threatened is possibly appropriate, but for which conclusive data on the 
iclogical’vulnerability and threats are not currently available to support 

the proposed rules. 


The United States Fish and Wildlife Service has listed the Kootenai River 
pepuletion of White Sturgeon as endangered under the Endangered Species Act 
‘Federal Register 59:171:45989-46001). 


Tnite Sturgeon, Acipenser transmontanus 


5. Prefield and Field Review 


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S conducted using literature-accounts, District and 
(IDFG) sightings, and the evaluation of the location 
ject. No field review was completed. 


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6. Analysis of Effects 


Status of Sensitive, Threaten, and Endangered Species in Analysis Area 


Bull Trout (Salvelainus confluentus) 





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re found in cold water streams, rivers, and lakes (U.S.D.A. 
chér spawn in late summer through fall (August to November), 

s of ground water infiltration. Fry hatch at the end of 

d emerge in early spring (April). Juveniles remain near the 

tom or in low velocity habitat (pools and pocketwater) for the 


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ears of their life. Unembedded substrate and dispersed woody 
commonly used forms of cover. Most juveniles migrate at the 
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he third growing season into larger lakes or rivers. Bull 
ture at age 5 to 6. Adult migration begins in early spring 

) and may extend through the entire summer. Most fish are in 
ms by August. Some adults will spawn more than once during 

€, but they may not spawn each year (Pratt 1992). 


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Bull trout ere present in several of the drainages proposed for spraying. 
2 2 trout from the Kootenai River have been found at the mouth of 
éribou Creeks (Paragamian 1994). Bull trout have also been. 

-1 Myrtle, Trout, Boundary, Grass, Parker, and Long Canyon Creeks. 
mot known whether these fish are from resident or fluvial 

¢. The status of bull trout in the Kootenai River, below the 

nea wlelbleyis thought tosbe atta thigh risksof “extinction (personal 
Twi Cat TOME eaVeMCrOS San. 


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Westslope Cutthroat (Oncorynchus clarki lewisi) 


Westsiope cutthroat trout occur in clear, cool streams usually with water 
tures less than 17 degrees celsius. Cutthroat habitat contains 

rocky, silt-free riffles, for spawning and slow, deep pools with well 
vegerétead stream banks for feeding and resting (U.S.D.A. 1989). They tend 
to occupy headweter areas especially when other salmonid species are 
present in the same stream (Hickman and Raleigh 1982). Cutthroat trout 
usually reach sexual maturity at age 3 to 4. They spawn in the spring, 
usually in April or May. Fry and juveniles occur in stream sections that 
llow with slow velocity flows. As fish grow larger and mature, they 
t deep water habitat types such as pools and deep runs (Hickman and 
Isee;)Ratte er al 1951)" © During winter. cutthroat® trout typically 
} eeper water associated with large woody debris (Moore and Gregory 
1968). Strong populations of this species exist in only 36% of its original 
range in Idaho (Rieman and Apperman, 1989). 


@ cutthroat trout are present in most drainages of the Kootenai and 


Westsiop 
Mcyie River. Westslope cutthroat have not been found in McGinty, Gable, 
Twentymiie, Cow, or Katka Creeks proposed for spraying. The status of 
oruléetions in remaining watersheds proposed for spraying is unknown. In 
Cc 


where introduced rainbow and brook trout occur, long term 


Viebrvecy ef westSlope cutthroat may be in question (personal 
commumucetions Dave Cross). In many: cases this: may not be vauertorsolely 
intresuced species. Instead, Cumulative effects from fishing pressure, 
inircaucea species, and a depressed cutthroat! population from managed 


nces have all played apart to tip the balance against: cutthroat. 
Redband Trout (Oncorhynchus mykiss gibbsi) 


Trout are a strain of rainbow trout that are native to the Kootenai 


Reabend 

River Basin. The mainstem Kootenai retains a hybrid mixture of 
redbend/reainbow/cutthroat, but barriered tributaries may have headwater 
redband populations (U.S.D.A.: 1994). Field:evidence indicates that “interior 
redbend anc westslope cutthroat generally coexisted below Kootenai Falls 
before exotic species were introduced. For the most part the two species 
were secregeted spatially, but in sympatric situations they were able to 
m&éintéin a high degree of genetic integrity. It is only where the coastal 
réinkcws were introduced that we see hybrid swarms of 
réinbcw-recapand-cutthroat where few if any individuals are genetically 
pure 


ckince cf ccastal rainbows (as early as 1914) has complicated the 

es as did the release of eastern brook trout, yellowstone 
host of other species (U.S.D.A. 1994). Redbands are 
c be virtually extirpated through hybridization with 
s. In essence, in those places where someone has bothered 
Gs, it looks like there are very few clues left to 
i€ir status. 





s from genetic surveys conducted in 1994, located redband 
e of the nine streams surveyed. Saddle and Grass Creeks 
in genetically pure populations, while Boundary Creek 
ation (personal communication, Doug Perkinson). 


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White Sturgeon cipenser transmontanus) 


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cm are anadromous in the most of the larger rivers in which 

t are landlock in the middle and upper Columbia River system. 
River population range includes lake and river habitats 

he outflow of Kootenay Lake and Kootenai Falls upstream in 

a. Most fish have been found only in the Kootenai River, but a few 
een located in larger tributary streams (Graham 1981). In 1989, a 

of Montana enforcement officer cited an angler for taking of a 

on in the Yaak River (U.S.D.A. 1993). However, few have been sighted 
ier tributary streams . 


wring period for white sturgeon occurs in May and June. Spawning 
obably occurs over rock or bedrock substrate in swift currents near 
s, when water temperatures are between 8.9 and 16.7 degrees celsius 
hem 1961). It is believed that that most spawning in the Kootenai River 
s in the canyon section between Bonners Ferry and Kootenai Falls. 
ons have not been identified in any of the tributary streams proposed 


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Other Species 


ion to the above mentioned species, tributaries and lakes of the 

K enem  Kaver Supportescuipins. (Cettus)yeslimy sculpins: (Cottus 
side shiner (Richardsonius balteatus), mountain whitefish 
-iémsoni), kokanee salmon (Oncorhynchus nerka), rainbow trout 
Oncerhynchus mykiss), peamouth (Mylocheilus caurinus), northern sgauwfish 
Prychcocheilus oregonensis), pumpkinseed (Lepomis gibbosus), largemouth 
ss (Micropterus salmoides), yellow perch (Perca flavescens), crappie 
omoxis), and brook trout (Salvelinus fontinalis). 


Direct, Indirect, and Cumulative Effects 


Manual treatment would result in localized soil disturbance. An increase in 
sediment tc streams from the manual treatment along road cuts and fills and 
within the twce riparian areas is possible, but the increase would likely be 
undetectable for several reasons. First, disturbed areas would be replanted 
with gress seed after treatment reducing erosion as roots became established 
Second, not ail sediment reaching ditchlines would be transported directly to 
Streams: Many ditchlines are intercepted by reliefculverts;swhich drain conte 
the forest filocry Finally, soil disturbance would be minimal and localized in 
comparison tc the entire watershed. 

Cultural treatments (seeding, transplanting, and fertilizing) would not effect 
fisheries. Fertilizers would be applied according to Forest Service and 
manufaéciune guidelines. Runoff nutrient concentrations therefore would not be 
large encuch te enrich streams. Seeding and transplanting would involve limited 
SOsie oss Ur bancerne Tnéres cr eanorcumulatriveretiectsiwithrthis’ alternative: 


Eirfects from manved tand “culturalytreatnients: are Simidar to those. displayed) in 
SrCesrecave: Z Kelease of biocontrol agents would have no direct effect on 
fasmerzes cy surface wacer quality. The ’pvocontrol "agents would not compete 
With G2Guet1e INSece Species since tneésrercoo base is very specific, nor would 
they previde more than an incidental food source for fish. There are no 
cumulative ezfects with this alternative: 


osed for use on these site are all characterized by 
VO. TOKLCIC VY = ner s6-nour DC for the four herbicides is 


relétiveiy 1 0 
provided a lanve 441 = = thie Vo=tiour LC, refers 25 the concentration nat is 
lethal ve St"percent "ol the fish exposed at that level for 96 hours> The “lower 


the LC the more toxic the compound. 


Table 4-1.Toxic levels of herbicides to fish 


Herbicide 96 hour LC50 LC50 divided NOEL 
(test Species) (milligram/liter) by 10 (milligram/liter) 
Cloryralic 103 10.3 not available 


(raeanbCwetreur,) 


2) 4eDacia 24 2.4 not available 


(Guitwinwe ees FOU) r 


DF. 4 =D Reais ae 420 42 not available 
(LES HnSSwee seas 
Dicamba 28 BD ai) not available 


ambe, and picloram values are taken from Mayer and Ellersieck 
Sward 1976 and 1979. Clopyralid value is from Dow Chemical Company 


2,4-D arid is the parent compound which is formulated in a variety Of forms, 
includine the amine which would be used under the 2,4-D alternative. 


Althesc guneeLe 1y ts eirequentty, used as a toxicity standard, fifty percent fish 
morteélity is genérally not acceptable. Because we often do not have long-term 
rest results that provide safe concentrations. or no-observed-effect levels 
(NOP | =e. U.S. EPA hes recommended thatthe 96-noursLC be divided by 10 to 
set & stanaerd for concentrations to protect aquatic species (U.S. EPA 1986). 
able 4-1 crcevides these concentrations, which are used as a benchmark to judge 
the sicriticance of possible impacts. It is)interesting to note that the NOEL 
for picicram developed from long-term laboratory studies corresponds fairly 
ClOSEs Vee mene LC. Givided by 10 (see Table 4-1). 
The SECCH 


cert of the risk analysis for aquatic species involves determining 

e herbicide concentration in streams. Field studies of pesticide 
s s have shown that pesticide input to streams ranged from 

non-Geterzible toe 6 percent of the amount applied. 


ict the potential water quality Preaere of herbicide 
acicre on the sites under consideration, it is important to distinguish © 
betweer infiltretion-dominated sites and runoff-dominated sites. In all but 
é conditions, rainfall percolates into the soil on an 

ominated site. On a runoff-dominated site, rainfall is more 

uce overland flow. These two classes of sites are differentiated 
on the basis as vegetative cover, soil type, degree of disturbance and 


compacticn, and slope. The majority of the proposed treatment sites are 
runoff-dorinated (road cuts and fills), except for Saddle Creek, where the 
majority cf the proposed treatment sites are previously harvested stands 
adjacent to roads. Roads enhance runoff by concentrating flows on compacted 
road surfaces and ditches, intersecting groundwater flow from cut slopes, and 
using coarse material with low organic matter to create the fill slope. It was 
assumed thet Saddle Creek sites are infiltration-dominated. 


Based con a review of scientific studies of picloram runoff to streams, it is 
estimated that a maximum of 10 percent of the herbicide applied on a 

nated site and 1 percent on an infiltration dominated site could be 
LOS TO te stream in a six hour period. Because of its relatively long 
Beene ee persistence and relatively low soil adsorption (high mobility), 
piclorer represents the worst case of the herbicides analyzed here. 


, the worst-case concentrations of herbicide can be calculated for 
€S in the vicinity of the proposed treatment sites. The seasons entire 
tion wes calculated per drainage as if weeds were sprayed continuously 
along eéch roeqd. In reality, approximately 40 percent or less of the distance 
ad would be sprayed. It was assumed that the seasons application 
place within a few days time and that a thunderstorm would wash 
he active ingredient into the stream over a six hour period. 
dology, Meadow Creek showed the highest concentration of 

2 


£ 
ho 
0287 mg/L (Table 4-3). Grass Creek showed the highest 


Se Paelorateicc 
concentrét 


étion of 2,4-D at 0.0690 milligrams per liter (a mg/L is equivalent to 
a part per million). These results are well below the estimated NOEL. With 
the water yieid of these drainages, this analysis shows that 100 percent of the 
application rete scheduled for each drainage could be washed into the creek 


Over @ perioc cf 6 hours and the concentration, would still be less than NOEL. 


Again it snouida be emphasized that these calculations represent a worst case 

1D and the probability that these concentrations would be reached is very 
ikely that any herbicide would be detected in stream water as a 

spray operations because of the low level of herbicide use 

od of 2 months or more compared to the water yield in these 

period ofr time. 


40) 


Ds 

Mm 
wo 

9 

S 

mM 


A report by Scott er aly (1976) of ther rish. and Wildjifer Service, concluded 
thet @ ccncencrationsot, 0.6 ppm picloram decreased cutthroat ‘fry growth by 25%. 
No edverse eftects were observed when, concentrations were below 0/3 ppm. 
Woodward (2575) concluded that’ picloram increased the mortality of fry in 
concentréticn above 1.3 ppm and reduced their growth in concentrations above 

O Cie Do Worst case scénario concentrations calculated in Table 4-3 are well 
belcw these accumented effect levels or the 0.35 mg/L concentration listed in 
Table 4-1 

Concenurezicns for clorpyralid, cdicamba, “and 2,/4-D that could enter streams 
under @ wcrst case scenario are also low. The highest concentration of 
clopyrelia, cicemba, and’2,4-D is" 7.0209 ma/l, 20155 ma/L; and 23278 ‘mo/h 
PESDECt Vely. Nese are far .Delow the LC, Givided by 10 value reported in 
Tepes. 2. 


When herbicides are applied, there is often concern that they will 
bioconcentrate in organisms through uptake and retention by tissue or gills. 
For this to occur, retention of a pollutant must exhibit a high resistance to 
breakdcwn or excretion by an organism to allow a sufficient uptake period for 
an elevated concentration. A high concentration must also be applied for an 
extended period of time. Bidlack (1980) studied channel catfish exposed up to 
28 days tc picloram at 1 ppm (mg/L). Analysis showed that picloram did not 
bioconcentrate. Each herbicide proposed has a worst case scenario 
concentration below 1 mg/L and would not be applied over an extended period. 
Therefcre, there is a low risk of bioconcentrating. 


etimes expressed over the possible cumulative or synergistic 
ixtures of chemicals on sensitive resources. Synergism is a 
one interaction where combined effect of a certain herbicide with 
als in the environment is greater than the effect of any one 
This issue is discussed in greater detail in the section on 


Human Heeith Impacts. As noted there, EPA currently supports an additive model 
in predicting such interactions. Even with the assumption that the chemicals 
are cresent simultaneously, their additive concentrations are still well below 
the NOEL threshclds. Furthermore, where more than one herbicide is applied, 
the dessoe would be reduced (personal communication, Bob Klarich). From the 
small does expected irom this project, synergistic effects are not expected. 
Herbicides can also-indirectly influence fish populations by affecting the 
populations of other organisms upon which fish aré dependent. Table 4-2 
provides toxicity data for other aquatic organisms. 

As indicated in Table 4-2, these herbicides are generally less toxic to lower 
orders of aguatic organisms than to fish species. Although the species listed 
in Table 4-2 are not the only aquatic organisms found in these waters, they are 
used by the U.S. Fish and Wildlife Service and the U.S. EPA as indicators of a 
wide rense of aquatic organisms. Again, the worst-case concentrations of the 
herbiciaces in water are well below levels that would affect these organisms. 


ree a 


levels of herbicides to aquatic organisms other than fish 


cr 
— 


Test Spécies Test Results 


Dapbrids (Daphnia sp-} 48 hr LC50 is 225 mg/L 
Rem’s horn snail (Helisoma trivolvis) 





No mortality after 48 hours in a 
solution containing 1 mg/L 


(ab) 


n Algae (Selenastrum capricornutum) 
96 hr LC50 is 61 mg/L 








Duck weed (Lemna minor) No growth reduction at 2 mg/L after 

21 days 
Dachnia maqna 48 hr LC50 is greater than 100 mg/L 
Seed shrimp (Cypridopsis vidue) 

48 hr LC50 is 8 mg/L 
Scuds (Gammarus fasciatus) 96 hr LC50 is greater than 100 mg/L 
Midges (Chironomus plumosus) 

48 hr LC50 is greater than 100 mg/L 
Derhnia magna 96 hr LC50 is greater than 100 mg/L 
Sow bugs (Asellus brevicaudus) 

96 hr LC50 is greater than 100 mg/L 
Scuds (Gammarus fasciatus) 96 hr LC50 is greater than 100 mg/L 
Shrimp (Palaemonetes kadiasis) 

96 hr LC50 is 28 mg/L 


Picioren aos Ort Ss) 7 Ge may LU 





ag) 
we 
fa) 
a) 
() 
"{ 
oO) 
} 
—/Y 
@ 
G 
QO, 
Y 


(Sammarus fasciatus) PO Nt sco 38) 27 mg/L 


= | ea) | -_ -~ 
T Sscuas (Gammérus 


¥6! 
w 
a) 
' 
.) 
Hy 
ie) 


seudolimnaeus) 
Zoenr LC50) is 16.5 mg/L 


Picloram Stonefly (Pteronarcys californica) 


vo Dr DCSOsis 4. 6 mg/L 





on this table are taken from Mayer ands Ellersieck) 1966) (2,4-D, 
icamba, end ricloram) and Dow Chemical Company 1986 and undated (clopyralid). 


It must be recognized that Forest Service spraying is minimal compared to the 
Ooveréil use cf herbicides. A demonstration that Forest Service spraying on a 
Speciltico “site sernct affecting a specific aquatic resource does not exonerate 
aim) pesser iicetions of these herbicides. The U.S. EPA has the overall 


etermining the possible aquatic and other environmental 
bicides under their registered use Dpetterns. nlf 
-. 


Vasece 


MNeCeeC err ewonpact € suspected, the EPA must require additional testing and 
monitoring under the pesticide registration process. During the registration 
or réreg:strétion of these compounds, the EPA did not identify impacts to 

nisms as 


nd &@ major concern. In fact, the EPA continues to allow the 
Of PSone LCrmutetlonss or 2.4 =D directly to water. The major surface 
ra é€d for picioram is the possible contamination of 

sfects downstream on sensitive Crops. 


Municire® waéversheas 

Spréying is proposed in two municipal watersheds above the water system 
Givers:cr points. These streams are Caribou Creek and Myrtle Creek. The 
National Toxic Rule has set water quality standards for acceptable levels of 
compounds in surface water. The acceptable level of 2,4-D for domestic water 
Supplies is "Ss micrograms per liter (ug/L). ‘The acceptable level of 2,4-D for 
waters coal support organisms for human consumption is 790 ug/L. 


The resuits cf the worst case scenario discussed above were converted to ug/L. 
ase scenario, the concentration of 2,4-D for Caribou Creek was 
concentration of 2,4-D for Myrtle Creek was 17 ug/L. Both 
figures are well below the acceptable level established by the National Toxic 
Rule. Acéin it should be emphasized that these calculations represent a worst 


case scenaric and the probability that these concentrations would be reached is 
very low 

Table 4-3 Herbicide Concentrations mg/L (ug/L) Worst Case Scenario 

Drainaoe Clopyralid 2,4-D Dicanba Picloram 
Boulder Creek 0.0068 . . ©. 0076 0.0016 0.0020 


0.0209 ie 8 


to 
ro) 
= 
' 
a 
a 
CF 
H 
a 
m 
nw 


SMES s 
Siiace nae 


Boundary 


Meadow Cr 


mM 


Gress Creexk 
=~ mY re. ~ = 
Saddie Creex 
recon seascnse 
weeas were § 
It wés assur 
acta ve nore 
ss Shi = 
CY, Poy (Paar s Gale 
Teel per sec 
(nero Cre we 
apewateceon 
bo ees: | 
Wnermeim eee Re 
chem CBee cin 
Gel curate eh 
yess Ne. Febcom 
CW eK FS £7 
CIS wete rele 
Best Manecement 
. £ -* aa 
Rule € cf the Ru 
ele Abele: Kise Ache 
<< ~ =~ 
purpose of these 
chemicals in suc 
= 7 = aie ee 
habscats (woe ne 
water. The rule 
opératsonal “proc 


There 1S oné exc 
untreated on eac 
areas of open wa 
where tr nt 

and Grass Creek. 
be filed with th 
TOmMceot meme miners 
this The 


spot sprayed by 


an ad 


Ee€acme 


Lp 


aS 


.0005 wOO Si Sc3)) 


0108 OSS 0.0541 #0,051 


.0045 


.0028 (Cdoe O(a! 


70029 -OLB9 0.0155 .0048 


.0524 .0138 


-0128 


.0014 .0477 


0652 2 LTs 


rail epg) .0287 


.0690 SOLS 4 


.03478 .0092 

tire herbicide application was calculated per drainage as if 
ed continuously along each road in a matter of a few days. 
hat a severe thunderstorm could wash 10 percent of the 

ient into the stream on runoff-dominated sites and 1 percent 
on dominated sites over a six hour period. The average cubic 
water yield for the month of July was used to calculate the 
produced during an average 6 hour time period. Herbicide 
conducted mid-May through early August, stream flow for the 
used as a worse case since the July flow is-much lower 
Five year average guaged water yield was used to 

for Boulder, Smith and Boundary Creeks. The yield per 
these drainages was used to calculate an estimated 

ow for the remaining drainages. 


i 


ey 
is 


4 Mm 
Ha} 


fag 


oth 


oO w 


and Regulations Pertaining to the Idaho Forest Practices 
er 13, Idaho Codé pertain to the use of chemicals. The 


wey that the public health and aquatic and terrestrial 
be endangered by contamination of streams or other bodies of 
have generally been adopted by the Forest Service as standard 


eption. One rule requires that at least 25 feet be left 

h side of all Class I steams, flowing Class II streams and 

ter. As discussed in Chapter III, there are two locations 

of meadow hawkweed is proposed within this zone, Trout Creek 
For these cases, a Request for Forest Practice Variance will 

€ Idaho State Department of Lands. The request will be to use 

Dicide 2,4-D that have been certified for use over water within 

herbicide would not be sprayed directly on water but would be 

hand directly on hawkweed plants up to the edge of the water. 


In summary, the direct, indirect, and cumulative water-quality impacts of these 
prejects would be minimal. Under reasonable assumptions, it can be concluded 
that no herbicides would be detected in surface water at the part-per-billion 


ision were made to apply herbicides. Effects on 
ormal-use scenarios should not be detectable, although 
to test this assumption. 


Gerece iar SyeEITONS alee Fy Oke 
6 


ovo 3 0 


ects could be more serious in the event of. a spill of herbicides 

y 2MtoO a small stream. It 4s not possible to predict the concentration 
éticn of contamination in advance. However ja Spill could resuit in 
lizea fish mortality, especially to young fingerlings, or mortality to the 
ly developmental stages of other aquatic organisms. 


7. Determination of Effrects 


. eo 


w concentrations which could enter streams, even under the 
cenério, the proposed action will have no effect on sensitive 
8. Recommendations and Conditions 

No conditions or recommendations are needed for the determination. 


9. Consultation With Others and References 


informal consulation with Bob Klarich, Bonners Ferry, Idaho Panhandle 
Nationa: Forest, 5/30/95; Dave Cross, Forest Fisheries Biologist, Idaho 
Penhancle National Ferest, 5/5/95; Doug Perkinson, Forest Fisheries 
Bao 6 kos ena Netogelmrorest) 5/2/95, 

Altenocrin FiWo, and Rew beary 2988. Conservation and distribution of 
Genetic verietion in polytypic species, the cutthroat trout. Conservation 
BLOT OOy. 202 a ag 


Baltz, O.M., B. Vondracek, L.R. Brown, and P.B. Moyle. 1991. Seasonal 
icrchabitat selection by rainbow trout in a small stream. 


>) 
J 
» 
J 
) 
D 
n 
1 
J 
i ee 


ion cf the American Fisheries Society 120:2:166-176. 


Bidileck, H.D., 1980. Kinetics of "Aged" Picloram in a Model Aquatic 


Microcos. The Dow Chemical Company. 
Bilby, k.E. and J.W. Ward. 1989. Changes in characteristics and function of 
oocy debris with increasing stream size in western Washington. 
ct 


ions of the American Fisheries Society. 118:368-378. 


Gorman, O.T., and J.R. Karr. 1978. habitat structure and stream fish 
communities. Ecology 59:507-515. 


Greham, P. 1961. Status of White Sturgeon in the Kootenai River. Montana 
Fis Wilalife, and Parks. Kalispell, Montana. 


rariitn, ©o.S. 1988. Review of competition between cutthroat trout and 


we we 


other saimcnids. American Fisheries Society Symposium 4:134-140. 


1c. 


Hicks, B.J. 1990. The influence of geology and timber harvest on channel 


morgnclcsy and salmonid populations in Oregon Coast Range streams. Doctoral 
dissertation. Oregon State University, Corvallis. 

uiekman mend RuFo Raleigh. 2 9e2, | Habitat esuitapiiacy index models: 
Curthreat Trout U.S.D.I. Fish and Wildlife Service, FWS/OBS-82/10.5. 

WEI. BPOrcL COMI s = COLoradoneeeunpedes, 

Tnvin D.B. 1987. Cutthroat trout abundance, potential yield, and 


on with brook trout in Priest Lake tributaries. Master’s thesis, 
ity of Idaho, Moscow, Idaho. 


| G. 1991. The use of wolman pebble counts and channel geometery 
channel stability. USDA Forest Service, Idaho Panhandle National 


S.V. Gregory. 1988. Summer habitat Utiirzation and 
t trout fry in Cascade Mountain Streams. Canadian 
= and Aquatic Sciences) 45:1921=2950'. 


Partricce, F. 1963. Kiver and stream investigations. Study VI: Kootenai 
River Fisheries Investigations. Project F-73-R-5. Idaho Department of Fish 


Pract, KD, 1592) *A review of bull trout iaite history .. Pages 5-3 tree: 
Uowell-end D.V. Buchanan, editors. Proceedings of the Gearhart Mountain 
Soe COC et RellOp 

Rieran, =.E., and K. Apperson, 1989. Status and analysis of salmonid 
ficteries, westsicpe cutthroat trout and analysis of fisheries information. 
Thano Deon. “cf Fish and Game: pp 71-16. 

Caco euee ore hee, Schultz and PvH. Eschmeyer. 1977 -8Fisheries and Wildlife 
Rescerch. United States Fish and Wildlife Service, U.S. Printing Office, 


Lob dare eomstas 
fe. Form # 024-020-0047-12. 


| Forest Service. 1991. Update on Northern Region sensitive 
list. Letter signed by the Regional Forester, 5/17/91. 


U.S.D.A., Forest Service. 1989. Caring for our natural community: Region 
1 - Threatened, Endangered and Sensitive Species Program. U.S.D.A. Forest 


Service, Northern Region. 


Woodwerd, D.F. 1979. Assessing the Hazard of Picloram to cutthroat trout. 
1 of Range Management. 32:230-232. 


List of Preparers 


Revi 


ian) 


a0 


Oo, 


ipa] 


y: Cha Qifitdant Date: CaaS: 
John C. Chatel ox 


Zone Fisheries Biologist 


United States Forest Bonners Ferry Route 4, Box 4860 


Department of Service Ranger District Bonners Ferry, ID 83805-9764 
Agriculture (208)267-5561 FAX (208) 267-7423 

> mee 
Reply to 92672.42 Date: June 2, 1995 


Subject: Noxious Weed BIS 
Threatened and Endangered Species Draft Biological Assessment 


To: District Ranger 


Introduction 





The U.S. Fish and Wildlife Service (USF&WS) list (FWS-1-4-93-SP-NI-(9-15) 
dated June 1, 1995 lists five threatened or endangered species that may 
occur on the Bonners Ferry Ranger District: Bald Eagle, Gray Wolf, 
Woodland Caribou, Grizzly Bear, and Peregrine Falcon. This Biological 
Assessment (BA) addresses these five species for the Weed Environmental 
Impact Statement area. 


The Bonners Ferry Ranger District proposes to control noxious weeds in 
certain areas on the district where control programs still have a chance of 
success. Control alternatives include non-chemical and chemical treatment 
methods under an Integrated Pest Management program. 


In the past several years the Bonners Ferry Ranger District has conducted 
extensive inventories of noxious weeds on large portions of the ranger 
district. The district has also been treating noxious weeds as directed in 
the Idého Panhandle National Forest Weed Pest Management EIS. District 
personnel have searched all suitable and likely locations including travel 
corridors, campsites, and vulnerable habitats. 


Currently 41 sites with noxious weeds have been identified. Sites range in 
size from 0.24 acres to 33 acres and total 335.55 acres. This area 
represents less than 0.08 percent of the four hundred ten thousand acres of 
National Forest System lands administered by the Bonners Ferry Ranger 
District. It is important to note that on many of these sites the 
infestations of noxious weeds are still very scattered, and not all of 
these acres would require treatment. For example, the largest site is 13.8 
miles of road in the Smith, Cow, and Beaver Creek drainages where 
infestations of primarily meadow hawkweed can be found along the road. 


Sites have been grouped into one of 3 “geographical ecosystems". Three Or 
the geographical ecosystems are physically separated by either the Kootenai 
River or the Purcell Trench. Each of the three is associated with a 
Pérticular mountain range, namely the Purcells, the Cabinets, or the 
Selkirks. Site maps are provided in Appendix A. 


38 of the forty-one sites are infested with meadow hawkweed (Hieracium 
pretense) ) or combinations of meadow hawkweed and spotted knapweed 


Centéurea maculosa). Two of the sites are infested with Rush Skeleton Weed 
(CHronar we) ta juncea), found in but three sites in Boundary County. One 
Site, Roman Nose Lake #3, is infested with common tansy (Tanacetum 
vuloare). Ten other sites are infested with common tansy along with 
hawkweed, spotted knapweed, or thistles. Three sites are infested with 


yellow toadflax (Linaria vulgaris). 


Twenty-five of the 41 sites are located in the Selkirk Ecosystem. Five 
sites are located in the Cabinet Mountains Ecosystem and seven sites are 
located in the Purcell Mountain ecosystem. Three sites are identified in 
the valley outside the three mountain ranges. 


The preferred treatment varies by site and can include either chemical, 
Biological, or manual treatment or combinations of these treatments. A 
complete listing of preferred methods is provided in Table 2-1 (p. 2-8) of 
the £iS- 


Weed control is proposed in order to accomplish the following. 1) Protect 
the nétural condition and biodiversity of the Selkirk and Cabinet Mountain 
Ecosystems by preventing the spread of aggressive, non-native plant species 
that displace native vegetation. 2) Prevent or limit the spread of noxious 
weeds in key low elevation lakes in the Purcell Mountain ecosystem. Lakes 
to be protected are Brush Lake, Dawson Lake, Robinson Lake, and Smith 
Lake. Campgrounds at these lakes under Forest Service jurisdiction and 
other campgrounds within this ecosystem will be targeted for weed control 
action. 3) Comply with Federal and State Laws regulating management of 
noxious weeds. 4) Cooperate with other agencies and private individuals 
concerned with the management of noxious weeds. 


Determination of Effect 


Peregrine Falcon: Peregrine falcons nest on cliff ledges, rock outcrops or 
steep talus slopes. There are no known nest territories on the Bonners 
Ferry Ranger District, and few large cliffs which would provide suitable 
breeding habitat. There are no known historic peregrine Sightings from the 


project area. 


Peregrine falcons are the classic endangered species affected by 
pesticides. However, the pesticides that were the nemesis of peregrines are 
persistent chlorinated hydrocarbons that bioaccumulated in fatty tissues, 
causing eggshell thinning and a drastic decline in nesting productivity. 


Based on the lack of suitable breeding habitat, the absence of known 
peregrines, the distance any spraying activity would be from any likely 
nesting cliff, and the relatively rapid breakdown rates of the herbicides 
proposed for treatment, the proposed project would have no effect on 


peregrine falcons. 





Bald Eagle: The entire district is within the recovery zone of the bald 
eagle. According to the USF&WS (Letter, 9/16/92), "the bald eagle should 
be reviewed" if a search of a 3.1 mi (5 km) zone around the project 
boundary reveals a previously recorded nesting territory. 


No known winter roost sites are near the proposed treatment areas. 
Disturbence in these areas would not be a factor because the time of year 
that spraying would occur is in spring and summer. 


There are two known eagle nests within these distances. One is the Robinson 
Lake territory, which is occupied by a pair of eagles highly habituated to 
human activities. The other nests along the upper Kootenai River near 
Katka. 


Disturbance is an issue with nesting bald eagles. The pair at Robinson Lake 
has been shown numerous times to be tolerant of human activity, especially 
in the campground and on the trails. These are the areas that will be 
treated in this project, with few if any outside of known use areas. The 
Kootenai River territory is probably less habituated to human presence, and 
would possibly be disturbed by continuing presence. However, Spraying is a 
short duration and relatively quiet activity. Disturbance can be kept to a 
minimum by following the conservation requirements below. 


The herpicides proposed will not directly affect this species if applied at 
the recommended rates and quantities identified in the EIS. The chemicals 
selected for this proposal are water soluble, therefore, the extent of 
bioaccumulation is insignificant. These herbicides are rapidly excreted by 
animals that might receive a small dose from contacting or consuming 
sprayed vegetation. Although none of these herbicides have been tested on 
threatened or endangered species of concern here, tests on surrogate 
species indicate that the compounds are only slightly toxic to these 
species. 


Based on the lack of suitable habitat at the project sites (except as 
noted), and the lack of toxicity, bioaccumulation potential, and degree of 
exposure to the herbicides proposed, this project is expected to have no 
effect on the bald eagle or its habitat. For the two locations near known 


nest territories, this project is not likely to adversely affect bald 
eagles or their habitat. 


Gray Wolf : Northern Idaho has been identified as a travel corridor to 
allow wolves to disperse from Canada and travel down to the Central Idaho 
Wolf Recovery Area (CIWRA). According to Hansen (1986) the "entire 
northern Idaho/northwestern Montana border area should be considered 
important to wolf conservation in northern Idaho and ultimately to wolf 
recovery in central Idaho". 


The USF&WS (Letter, 9/16/92) recommends that the gray wolf be reviewed in 
areas outside of the CIWRA if "a search of the project area and a 6.2 mile 
zone around the project boundary reveals previously recorded wolf 
sightings". Wolf sightings are distributed across the Bonners Ferry Ranger 
District. No den locations have been recorded, and most sightings indicate 
transient animals. However, denning animals are expected within the next 
few years. 





The Forest Plan states for wolf habitat that “in areas of reported 
ocCurrence, consider maintenance of a high number of prey species (deer, 
elk) and maintenance of security through road management". 


The primary effect of noxious weeds on wolves is their effect on the 
ungulate herbivore prey they depend on. As noted in the EIS, displacement 
of native forage plants with non-nutritious noxious weeds is detrimental to 
ungulates. This effect is more likely to cause a problem with wolves than 
the direct effect of either the chemicals themselves or the disturbance of 
the people applying the chemicals. Disturbance is controlled by 
administrative use guidelines behind closed gates, and for those sites 
within bear units, security is higher than in non-bear units. 


The toxicity of these compounds on wolves has not been tested Orrect. ya 
However, these compounds have been tested on dogs, as reviewed in the Human 
Health Risk Analyses referenced in Chapter 4 of the FIS. Due to the small 
and widely distributed herbicide treatment sites, it is unlikely that 
wolves would be exposed to these chemicals. Potential doses to wolves 
either from the direct contact with treated vegetation or from consumption 
of animals that have consumed treated vegetation are well below toxic 
levels. These herbicides are excreted rapidly through the kidneys in 
ungulates, the process taking up to five days at most (see Human Health 
Risk Analyses referenced in Chapter 4 of the EIS). These herbicides do not 
bioaccumulate in fat tissues (as would an organochlorine insecticide). 


ed cn the previous anélysis, the proposed weed control activities would 
ave’ no effect oneawolves or their hebitat. 


Woodland Caribou: Portions of the project area lie within the designated 
woodland caribou recovery area. Wocdland caribou would not be directly 
affected by the increase and spread of noxious weeds due to displaced 
habitat. Spraying and disturbance would be the two most likely effects of 
the noxicus weed control program. 


As noted for other ungulates, evidence does not exist that the proposed 
chemicals are either toxic or detrimental to health or reproductive 
potential. For caribou, this is especially true, because the amount of 
spraying necessary in the areas occupied by caribou is small. Additionally, 
caribou dine on different forage plants than many other ungulates, often 
preferring huckleberries or angelica instead of species mixed with those 
likely to harbor noxious weeds. 


Based on the above analysis, the proposed weed control activities would 
have no effect on caribou or their habitat. 


Grizzly Bear: The project area encompasses several Grizzly Bear Management 
Units (GBMU) across the district. 


The bear is not likely to be affected directly by use of the proposed 
herbicides. The proposed sites to be treated with herbicides are 
relatively small, and not generally in areas known to be favored by bears, 
although there are a few sites in important bear areas. Noxious weeds are 


not known to be part of grizzly bear foraging diets (Grizzly Bear 
Compendium 1987). Some incidental exposure could occur if bears graze on 
treated non-target vegetation. Immediately after treatment concentration 
on grass and leaves could range from 50 to 150 parts per million. These 
concentrations would be quickly reduced either through photodegradation or 
rainfall. Although these herbicides have not’ been tested on bears, tests 
on other mammalian species at much higher concentration and for longer 
periods have shown no ill effect. 


The major effect from noxious weed control activities would be from the 
access needed behind gates to control sites there. Administrative use 
guidelines are developed for such activities and are strictly adhered to. 
Spraying can be accomplished well within administrative use timelines 
because of the short time involved. Mortality risk associated with the 
proposed activity due to an increase in human activity in the area would be 
minimizea through scheduling restrictions. 

No past, present or reasonably forseeable actions, when considered with 
this project, would cause cumulative effects greater than the direct and 


indirect effects considered individually. 


Based orn the above analysis, the proposed timber management activities are 
not likely to adversely affect the grizzly bear or its habitat. 


CONSERVATION REQUIREMENTS 


The following should be done to ensure that the findings of not likely to 
adversely affect is valid. 


Gagezcey Bess 
Where it is necessary for herbicide applicators to camp in bear 


a. Utilize bear proof storage containers for human and livestock 
foods. 


b. Store foods away from sleeping areas. 


c. Suspend foods/garbage at a minimum of 10 feet above ground 
and four feet from the tree used for suspension. 


ad. Proper menu planning to eliminated excessive left over foods. 
e. Cooking and eating should be done away from sleeping areas. 


f. Proper cleanliness of cooking facilities, including removal 
of all cooking residues. 


Bald eagle: 


1. In the Katka vicinity Only (T61N, R3E, Sections 5, 6, 8,9), 
the following requirements apply. Plan spraying so that it is 
Gone as quickly and quietly as possible. Spray in the middle of 
the day, if possible, since eagles tend to be more apathetic to 
disturbance at this time. During some years, these precautions 
may not be necessary, and they may be waived upon consultation 
with the district wildlife biologist. 


PREPARED BY: 





SANDRA L. JACOBS 
District Wildlife Biologist 


Literature Cited 


Hansen, J. 1966. Wolves of Northern Idaho and Northeastern Washington. 
MT Coop. Wlidf Research Unit. USF&WS. 88 pp. pages 36, 51, 72, PP id = ols =pigs 


Northern Rocky Mountain Wolf Recovery Plan (NRMWRP). 1987. USFE&WS. Sey) 
29s, Ieee) WS. 


USF&WS. Letter dated September 16, 1992. Subject: Species List Requests 
for Fiscal Year M993. 


Grizzly Bear Committee. 1987. Grizzly Bear Compendium. U.S. 
falite service; Missoula; *MTe?tS6 pp. 


est Service. 1993. Draft Environmental Impact Statement, Noxious 
Weed Projects, Spotted Bear and Hungry Horse Ranger Districts. Hungry 
Ke 


United States Forest Bonners Ferry Route 4, Box 4860 





Department of Service Ranger District Bonners Ferry, ID 83805-9764 

Agriculture (208) 267-5561 FAX (208) 267-7423 

Reply te: =2672 40 Datetewune 47 1995 
Subject: Ncexious Weed EIS 


Sensitive Species Drait Biological Evaluation 


Tos= Distrzcr Ranger 
Introduction 


The Regional Forester for Region 1 of the Forest Service has designated 
certain wildlife species as sensitive. These species may warrant this 
designation for a variety of reasons, such as extremely limited or fragile 
habitat, continuing or past habitat reduction or limited reproductive 
potential. There are eleven species so designated that occur or whose 
habitat may occur on the Bonners Ferry Ranger District. These are Coeur 
d'Alene Salamander, common loon, harlequin duck, boreal owl, flammulated 
owl, black-backed woodpecker, lynx, fisher, wolverine, Townsend’s big-eared 
bat, and northern bog lemming. 


Refer to the introduction of the Noxious Weed EIS Biclogical Assessment 
(for threatened or endangerec wildiife); for & summarized description of the 


project. 
Determination of Effect 
Coeur d’‘Alene Salamander 


The known geographic range of the Coeur d’ Alene Salamander is in northern 
Idaho and northwestern Montana. As research continues, it is being 
discovered in many new locaéticns (Manns, pers. comn.). Coeur dad’ Alene 
salamanders inhabit splash zones of spring seepages over rock faces along 
roaas, waterfall spray zones, and edges of streams beneath moist rocks 
(Groves 1988, p. §&). They occur in wet, humid, and cool microhabitats 
containing fractured bedrock or gravel that provides shelter and retains 
moisture (USDA 1989, p. 40). In the northern part of its range in Idaho 
(Cabinet and Purcell Mountains) the lack of fractured rock types is 
probably the major factor in limiting the species’ distribution (Groves, 
19&€9 p. 4). Sharply fractured rock formations are often associated with 
Belt Rock formation but can also occur in other geologic types. Most of the 
Suitable habitat of this description falls within the Purcells and Cabinet 
cuntaéin Ranges for the project area. 


Because riparian areas are being sensitively handled for this project, it 
is unlikely that this species would come into direct contact with any of 
the herbicides to pe used. Further, the weeas targeted do not normally 

occur in rock cliffs or seepy rock faces, although they may occur in the 


ditches alongside roads, where salamanders also occur. Precautions noted to 
protect water quality would be adequate protection for this species. 


Cumulative or indirect effects would be probably greater without noxious 
weed control than with it, since the spread of less erosion-controlling 
plants such as knapweed may indirectly affect water quality. 


The proposed noxious weed treatment activities would have no effect 


individually or cumulatively on the Coeur d’Alene salamander or its 
habitat. 


Common Loon 


The geographic breeding range of the common loon extends from the southern 
coast of Iceland south throughout most of Canada, Alaska, and the northern 
border states. Loons are large, heavy-podiea pirds with their legs and 
feet positioned far te the rear &éllowing then to propel guickly through 
water but unable to walk weli on land. Lakes suitable for nesting are 10 
acres or larger with emergent shoreline vegetation and secluded areas for 
nesting and brood rearing. Only a few lakes on the district meet these 
criteria, and most are low elevation. There is no suitable habitat for 
common loons immediately adjacent to any treatment area, however several 
potentially suitable nesting lakes are near treatment sites. These are 
Dawson, Brush, Smith, Bussard and Robinson Lakes. 


Common loons have not been recorded as breeders in Boundary County for many 
years. Disturbance at nest sites is the likely cause. Once the lakes become 
extirpated, recolonizers would have é difficult time locating suitable 
nests again in this area where suitaple lakes are relatively rare. 


Loons forage on small fish. The greatest likelihood of the project 
affecting this species would be if the forage species were affected. As 
noted elsevnere, fish are not likely to be affected by the chemicals 
proposed. Because they do not bioaccumulate, loons would therefore also not 
be affected in this manner. 


There would be no cumulative effect associated with past, present, or 


5 


reascnably foreseeable future actions. 


The propesed ncxious weed treatnent activities would have no effect 
individually or cumulatively on the common loon or its habitat. 


Harlequin Duck 


The western geographic range of the harlequin duck extends south from 
Rlaska to portions of the northwestern United States and California. 
Harlequin ducks winter on the ocean and migrate inland to breed. They are 
generally associated with fast flowing streams which are 10 meters wide or 
greater during the breeding season (Cassirer & Groves 1990, p. 8). 


Harlequin duck habitat Goes occur on the district and there are recent 
records of breeding. As in common loon and Coeur d‘Alene salamander, 


water-associatea effects woud be mininial because of project design. 
Harlequin ducks forage on invertebrates which, because of their short 
life-cycle, generally do not have tine to vioaccunulate pesticides. In turn 
because of this and because the project chemicals do not bioaccumulate, the 
risk to harlequin ducks directly cr indirectly is immeasurable. 


There would be no cumulative effect associated with past, present, or 
reasonably foreseeable future actions. 


The proposed noxious weed treatment activities would have no effect on the 
harlequin duck or its habitat. 





Townsend’s Big-eared Bat 


The geographic range of Townsend’s big-eared bat extends throughout western 
North America, from British Columbia south to southern Mexico, eastward to 
South Dakota and western Texas with isolated populations in the southeast 
United States. Townsend’s Big-eared Bats have been found in a wide variety 
of habitats, from arid juniper/pine forests to high-elevation 
mixed-coniferous forests (USDA, 1985 pg. 32). Caves and cave-like 
s are @ critical habitat for this species, both as hibernacula in 
r and as roosts for summer nursery colonies (ODF&W, 1987, pg. 
hey occasionally use bridges and old buildings for roosting and in 
es have been known to use building attics as nursery sites 
(Perkins, 1352 p. 9). They are typically founa in shrub-steppe or forest 
edge (Notes of MT Bats, 1952). Foraging habitat is not well known but 
preliminary data suggests they forage along cliff faces and along small 
stream corridors in forested habitats (Perkins, pers. comm.). Other 
foraging habitat may include forest edges and openings, riparian areas 
where flying insects are abundant, and there are no obstructions to 
flight. Loss and disturbance of hibernacula and roosting habitat is the 
limiting factor for Townsend's big-eared bats. 


tf) 


StTTZUGe 


Natural cave habitat is virtually nonexistent on the Bonners Ferry Ranger 
District because of the lack of limestone. Hibernacula temperature and 
humidity requirements are so specific that it is unlikely that Townsend’s 
big-eared bats occur on the District because of lack of over-winter 
habitat. There are no caves or mine adits in the assessment area or in the 
Vicinity. 


Because of lack of suitable habitat tne proposed noxious weed treatment 


activities would have no effect on the Townsend's big-eared bat or its 
habitet. 


Northern bool lemiina 





The geographic range of the northern bog lemming extends from southern 
Alaska, throughout most of Canada and into northern Washington, Idaho, and 
Montana. The only known location of the northern bog lemming on the 
Bonners Ferry Ranger District is in & subalpine boggy meadow in the Selkirk 
Mountains. Northern bog lemnings typically inhabit sphagnum bogs, but are 
also occasionally found in mossy forests, wet sub-alpine meadows, and 


alpine tundra (Reichel and Beckstrom, 1993 P.1). According to the most 
Current research in Montana, Sphagnum mate are the most likely sites in 
which to find new bog lemming populations (Reichel and Beckstrom, 1993 )% 


S*weth the ether wetland-ascsceieted Species 1 this analysis, the 
Protections associated with water Qusiity snourid adequately protect this 
Species * trem any cheniice) Visi eescclciated with water. This species is not 


uy 


likely to be present in most of the sreas infested with the targeted 
NOXi0us weeds, since it OCCssS 2h Cather very moist habitats or old-growtth 
cecdaebrjsoittschds cece Cxposece snouia be VE Deere y nil. 


There would be no Cumulative effect associated with past, present, or 
reasonérly foreseeable future actions, 


Based on the above analysis, the proposed weed treatment activities would 
have no effect individually or cumulatively on the northern bog lemming or 
its habirar! 


Black-backead Woodpecker 


The geographic range of the black-backed woodpecker extends south from 
Alaska to central California and Nevada and throughout most of the northern 
United States. Black-backed woodpeckers nest in snegs or in live trees 
with heartrot which are at least 5 inches in diameter. They often use 
clumps’ of nesting, and are known to nest in spruce, lodgepole 


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4 
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pine, espen, ponderosa pine, Douglas-fir, and western larch (Thomas 1979, 
p- 361; Harris 1982, Penoe, e376 160). Black-backed woodpeckers feed 
rimaraly on wood-boring beevlese ang ewecialize on large areas of recently 
illed, beetle infested Eamoens Ereeaing densities cf Dlack-backed 
woodpeckers vary considerabiy in response to prey availability, increasing 
up tc 7 times the normal jevel during beetle epidemics (Jackman 1975, p. 
FORA 
Because this species is associated Prinarily with snags and the insects 
that live in them, it would net be affected by either the vegetation change 
Or the chemical treatments proposed. Based on this, the Proposed weed 
treatment activities would have no effect on woodpeckers or their habitat. 





The geographic breeding range of the flammulated owl extends from southern 
British Columbia throughout most of the western States but not along the 
coast. Flammulated owls are known to occur in Boundary County (District 
files). They occur in ponderosa Pine and Douglas-fir forests with fairly 
Open canopies (typically 35-653 closure) and snags at least ye heat =< | 0) ee 
Nesting stands are at least 35 acres in size. 


Flammulated owls are dependent on appropriately-sized snags for nesting 

and flying insects as prey. Neither of these life attributes would be 

affected by the proposed weed treatments. There would be no cumulative 
ffect associated with past, present, or rezsonably foreseeable future 


scl sOons: 


Based on the above analysis, the propcsed noxious weed treatment activities 
would have no effect on flamnulated owls and their habitat. 


Boree! Owl 


The geographic range of the boreal owl in North America extends from Canada 
and Alaska and throughout the northern Rocky Mountains in eastern 

ton, Idaho, Montana, Wyoming and Colorado. Boreal owls inhabit the 
spruce fir and upper cedar heulock zene in North Idaho. Mature and older 
conifer forests are suitable for nesting and foraging, and immature forests 
are used for foraging. 


As with the previous species who depend mostly on forest components such as 
snags, boreal owls would be unlikely to be directly affected by either the 
presence of weeds or tne use of chemicals to control them. Indirectly, the 
presence of noxious weeds may affect the quantity of rodent prey if an 
infestation is too severe, however, the likelihood is that boreal owls are 
limited by nest sites rather than prey base ana an infestation affecting 
rodent numbers would have to be serious indeed to switch this to the 


Based on the above analysis, the proposed weed treatment activities would 
have nc effect on boreal owls or their habitat. 


Lynx 


The geographic range of the lynx is wiaespread through the boreal regions 
of North America, Europe, and Asia, throughout most of Alaska and Canada 
and southward on the high elevation spine of the Cascades and Rocky 
Mountains into Washington, Iuaaho, Moneta, Wyoming, Colorado, and Utah. 
Lynx generally maintain home ranges cf petween 5 and 20 square miles, but 


ranges as large as 122 square mites nave been documented (Bender-Retie 

FETS, 1991 p. Al0-Az0O). According to Koehler (1990, p. 845-851), lynx in 

Washingten usea nigner elevations in tne sumuer than during the winter with 

the icwest elevation peing about 4500’. Denning habitat in Washington 

consisted of mature or old-growth spruce/sfir with a mix of lodgepole pine 

(Koehler, 1990, p. 845-851). Denning stands may be quite small (less than 
¢ 


in some cases) but must be interconnected by forested cover 
(Koehler and Brittel, 1990, p. 10-14). Other higher elevation mature and 
older stands likely provide denning habitat also. 


Snowshoe hare are the primary prey species of lynx. In Washington, hares 
are most abundant in young forests (approximately 20 years), usually 
lodgepole pine or other habitats with dense tree or shrub understory 
(Koehler, 1990, p. 845-851). Some portions of the project area occur within 
areas potentially inhabited by lynx. 


As with the other species dependent on forested areas, lynx would not be 
directly affected by either the presence of noxious weeds nor the control 
programs to remove them. Snowshoe hare may be indirectly affected by the 
spread of weeds if such spread reached a point that its native forage 


species were affected; however, many ct these plant species would not be 
affected by noxious weeds (such as loagepole pine seedlings). As previously 
need aithcugh no direct studies have been made On COxicity=to lynx, since 
the chemicals break down rap-dly and there is no bioaccumulation, the 
direct or indirect effects from the pesticides should pose no threat to 
this species. 


Based on the above anélysis, the proposed treatment activities would have 
no effect on lynx and its habitat. 


Wolverine 


Today the wolverine ranges from Alaska, most of Canada, and parts of the 

northwestern United States. Wolverine are a wide-ranging member of the 

Mustelid family. They inhabit "high elevation, mature coniferous forests 

with openings" and prefer "rocky places with scattered pockets of timber" 
(Groves, 19€9, p. 2 & 30). In Northwestern Montana they selected subalpine 

fir habitat and “large areas of nediwn. or scattered mature timber". They 
laged areas of "dense, young tinber” ana were rarely in large open 

eas. They aisc _reguire renore macltat With fone wal numan activity and 

ct besically roadless areas. They feed on a variety of small 

Sole, eNCew Leon Ce teen. 


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Incidental trapping poses a4 threat to wolverine populations. None of the 
alternatives, would significantly increase the potential of trapping. 


As with the other carnivores discussed, the largest potential threat from 
al noxious weed control is from ingestion and poisoning of chemicals, 

oncern especially since the wolverine is & scavenger of carrion. Again, 

Cumuiation and direct toxicity are not problems with the chemicals 


Disturbance from weed spraying crews may occur but this would be minimized 
by conformance with district administrative use guidelines. No increase of 
mortality risk would ocecur from thisi disturbance. 


No pest, present or reasonably forseeable éections, when considered with 
, would cause cumulative effects greater than the direct and 
€tsS consiaered inaiviauaiiy. 


Based on the above analysis, this proposed noxious weed treatment 
activities would have no effect on wolverine cr its habitat. 


Fisher 


The fisher was extirpated from most of its range by the early 1900s. It 
now occurs from southern Canadé south into the northwestern states and 
California and the Great Lake states. Research in various areas indicates 
fishers prey on a large variety of small mammals and carrion (Arthur et 
al., 1989, p. 680) and they are closely associated with seral to old growth 
coniferous forests. In northcentral Idaho, grand fir and spruce forests 
were preferred by fishers (Jones, 1951 p. &9-$2) and elevations from 


approximately 3000 to 5000 feet were used. They are thought to 
predominantly inhabit mid elevations in this area (Johnson pers. comm., 


1$91). Fisher also need late successionel habitats "linked together by 
closed-canopy forest travei corridors” (Jones, 1S91 p. 89-92). Large 
diameter spruce and grand fir snags and lerge downed material are used for 
denning and foraging. Fishers prefer nabitats with high canopy closure 
(>80%), and “avoid areas with low canopy closure (less than 50%)" (Powell, 
1S€2) pe GE) a Deranorthe: wintes they appeer to use 80-100 year old 
Douglas-fir and lodgepole pie foreste iy ado.tion tc the- above. 


Fishers use riparian areas because of their travel corridor value with 
dense overhead cover, and foraging opportunities. Neither of these have any 
direct tie to noxious weeds. Although fisher will eat carrion, some from 
large animals, most prey items are small rodents. The danger to fishers 
from an occasional carrion meal would be even less than that described for 
wolverine because of the lesser frequency of it and, as described, the low 
risk imposed by the chemicals anyway. 


There would be no increase in trapping risk imposed by this project. 
Besed on the above analysis, the proposed weed treatment activities would 


have no effect on fisher or their habitat. 


CONSERVATION REQUIREMENTS 


There are no conservation requiremelits mandatory to the determination of no 
effect fer this proj ect. 






Prepared By: 
SANDRA L. JACOBSON 


District VWildiife cBaclogisr 


PETE RATURE ClrTeD 


Arthur, Stephen M. 1989. Habitat use and diet of fishers. Journal of 
Wildlife Management 53(3):680-688. ~- 

Bender-Retie FEIS. 1991. Bender-Retie Timber Sale Final Environmental 
Impact Statement, Beaverhead National Forest. pages A1l0-A20. 





Bull, E. Perterson, S., and Thomas, J.W. 1986. Resource Partitioning 
Among Woodpeckers in Northeastern Oregon. Excerpts from 
PNW-144. 

Cassirer, E. Frances and Craig R. Grcves. 1650. Distribution, habitat 
use and status of harleguisn ducas (Histrionicus histrionicus) in 
northern Idaho, 1990. Idaho Dept. of Fish and Game. Natural 
Heritage Section. 

Copland, Jeff. 1994. Personai Communication regarding wolverine. 

Groves, Craig. 1989. Status an distribution of the Coeur d’ Alene 
Salamander (Plethcodon Vanaykei Idenoensis) in Idaho - Part at 
Idaho Dept. of Fish and Game Nongame Report, February ao Bee 

Groves, Craig. 1989. The wolverine wilderness symbol. Idaho Wildlife. 
Fall, 19692) pp. 2e6:-30, 

Groves, Craid. LSsier Status and distribution of the Coeur d’Alene 


salamander (Pletncodony vandykei idahoensis) in Idaho. Idaho 
Dept. of Fish and Gane Nongame Report, February 1988. 


Harris, M. 1982. Habitat Use Among Woodpeckers in Forest Burns. Masters 
Thesis, Univ of Montana. 61 pp. 

Jackman, Siri Marion. 1975. Woodpeckers of the Pacific Northwest: their 
characteristics and their role in the forests. M.S. Thesis. 
Oregon State University. 147 pp. 

Johnson, Greg. 1991. IDF&G Conservation Officer. Personal communication 
regarding fisher. 

Jienes, set fr. 1991. Halitat use of fisher in northcentral Idaho. M.S. 
Thesis, University of Idaho. 146. pp. 

Jenes, Jeff. Personal Communicétion regarding fishers, Western Forests 
Furbearer Meeréng, March 255 2594. 

Koehler, Gary M. 1¢¢90. Popuiation ana Bea Characteristics of lynx 
eng enowshoe haree in acrt: central Washington. Canadian 
Joernai of Zoology 6t(S)se45-e52 : 

Koehler, Gal no Britteti, 22D. 99. nageng epruce-fir habitat for 


MEnZY 
end snowshoe nares. <<. Of Forestry. 88(10):10-14. 
Ser.. Personal Comuunicatlon regarding Amphibians and Coeur 7a 
Rlene Salamanders, Region 1 Wildlife Congress, February 3, 1994. 
Notes on Montana Bats. January 21], 1552. 
ODF&W. 1987. Distribution, Stétus, and Habitat Affinities of Townsend's 
Big-Eared Bat (Plecotis townsendii) in Oregon. Technical 
Report # 86-5-01. p.27. 
Perkins, Mark. Personal Conmmunication regarding Townsend‘s big-eared bat. 
February, 1994. 
Powell, RA. I982. The Fisher Life History, Ecology, and Behavior. 
University of Minnisota Press, Minnesota. 2i7 pp. 
Reichel, J. & Beckstrom, S. 1993. Northern bog lemming survey, 1992. A 
Report to: USDA Forest Service, Kootenai National Forest. MT 
Heritage Program. 
Thomas, Jack Ward, et al. U. S.D.A.-Forest Service Agriculture Handbook 
No.553. Wildlife habitats in managed forests: the Blue 
Mountains of Oregon and Washington. 512 pp. 








USDA, 19°89. Caring for Our Natural Community. Threatened, Endangered, 


and Sensitive Species Program. p. 38 & 40. 
Wilson, Cynthia, Richard FE. Johnson and James D. Reichel. 1980. New 
records for the northern bog lemming in Washington. Murrelet 


617104106. 


APPENDIX F 


IDAHO PANHANDLE N, F. PROPOSED INTEGRATED WEED MANAGEMENT PROGRAM 








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