Vegetation management with herbicides in the Eastern Region : final environmental statement

Historic, Archive Document

Do not assume content reflects current
scientific knowledge, policies, or practices.

~ VEGETATION MANAGEMENT

pear WITH
oe HERBICIDES“:
in the es —
EASTERN REGION _
FINAL

ENVIRONMENTAL STATEMENT

EASTERN REGIO
FOREST SERVICE * U.S. DEPARTMENT OF AGRICULTURE

723618

RECORD OF DECISION

Vegetation Management with
Herbicides in the Eastern Region
Environmental Statement
USDA - Forest Service
Eastern Region

Based on the analysis in the Final Environmental Statement, it is my
decision to allow the use of herbicides to be considered as a viable
vegetation management alternative where appropriate. The proposed
annual use of herbicides in the Eastern Region is approximately 42,700
acres, The final use decision will be dependent upon site specific
environmental assessment reports considering all identified
alternatives,

Implementation of this plan will not take place until December 1, 1978,
after the Final Environmental Statement has been received by the
Environmental Protection Agency and this Record of Decison has been
made available to interested individuals, organizations, and agencies,

Date ay 36/ 78
Milwaukee, Wisconsin

EVE YURICH
egional Forester

633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Tie

EES

IV:

USDA FOREST SERVICE ENVIRONMENTAL STATEMENT
VEGETATION MANAGEMENT WITH HERBICIDES IN THE EASTERN REGION
USDA - FS - R9 - FES - ADM - Tigao

Prepared in Accordance with
Section 102(2)(c) of Public Law 91-190

SUMMARY SHEET

DRAFT ( ) FINAL (xX)
NAME OF AGENCY: FOREST SERVICE, EASTERN REGION
ADMINISTRATIVE (X) LEGISLATIVE ( )

DESCRIPTION OF ACTION

This Statement Proposes the use of herbicides on National
Forest System lands in the Eastern Region of the Forest
Service, USDA. This includes National Forest System land
located in the States of Illinois, Indiana, Maine, Michigan,
Minnesota, Missouri, New Hampshire, New York, Ohio,
Pennsylvania, Vermont, West Virginia and Wisconsin. It is
estimated that approximately 45,000 acres (0.4 percent) of the
11,250,000 acres of National Forest land in the Eastern Region
will be involved annually in chemical vegetation control
activities. Vegetation Management is needed primarily for the
management of roads and trails, grazing areas, recreation
developments, special use areas, timber management practices
and wildlife activities.

A variety of herbicides are used in the Eastern Region. This
is because of a diverse vegetation management program, the
limited uses allowed by individual herbicide labels, and the
large variety of herbicides available for purchase throughout
the Eastern Region. All herbicides used will be registered by
the U.S. Environmental Protection Agency (EPA). Only
application methods and dosage rates approved by EPA will be
used.

It is the policy of the Forest Service, USDA, not to use any
herbicide that is not registered by EPA. Thus, all herbicides
and all uses of herbicides Proposed for consideration in this
enviromental statement are registered in accordance with the
provisions of the Federal Insecticide, Fungicide, and
Rodenticide Act, as Amended. All herbicides proposed for use
meet the two primary criteria of this Act. Namely, when used
in accordance with label instructions they are effective for
the usage Proposed; and they are safe when used in accordance
with label instructions.

af

vas

:

This Statement also describes the procedural requirements for
the pretreatment review of all herbicide applications. It is
intended that the data on the environmental impacts and effects
of the proposed programs will apply on a continuing basis.

This Statement will be reviewed annually and revised if new
research indicates changes in the presently known environmental
effects of any of the herbicides being considered. Revisions

will be available at the Forest Supervisor offices and Regional
Office.

This Statement is general in nature. Individual projects will
be properly described and analyzed in detail in a site-specific
environmental assessment report or environment statement,
written to provide public and other agencies full understanding
of the proposed project.

SUMMARY OF ENVIRONMENTAL IMPACT AND ADVERSE ENVIRONMENTAL EFFECTS

Herbicide residues in the air or water, while possible, are
uncommon within the National Forests of the Eastern Region.

When they have occurred, the levels have been below established
limits considered hazardous to non-target organisms. The
herbicides used are EPA rated moderately toxic to nearly
non-toxic to man. Their persistence in the forest environment
is short, with approximately 95 percent of the applied herbicide
decomposing within 3 months after application.

The application of herbicides may cause a temporary adverse
impact on local aesthetics. Vegetation which is highly
susceptible to the herbicide being used will die or experience
reduced vigor. However, non-susceptible plants will respond to
the changed environment with increased vigor and will tend to
dominate the site. The increased vigor results in greater
survival and growth of the desired plants.

Twenty-five years of proper herbicide use by the Forest Service
in the Eastern Region have produced no known health problems in
Forest Service personnel, herbicide applicators, or local Forest
residents. On a local basis, the incidence per capita of cancer
in rural areas where herbicides are used has not increased since
1930. Scientific data which was gathered after approved
herbicide applications shows little if any human health hazards
exist from current herbicide use. Public objection to herbicide
use, however, continues to be an issue.

Favorable effects of herbicide use include enhanced production
and protection of resources, and improved economic welfare and
community stability. Where vegetative management can be safely
accomplished with herbicides, the greatest dollar savings to the
taxpayer and consumer will be realized.

ALTERNATIVES CONS IDERED

A. Biological D. Manual
B. Fire E. Mechanical
C. Herbicides F. No Action or Postponing Action

2 i bl

'

VII. FEDERAL AGENCIES, STATE DEPARTMENTS OF NATURAL RESOURCES,
ORGANIZATIONS, GROUPS, INDIVIDUALS AND COMPANIES.

A Total of 226 copies of the Draft Environmental Statement were
mailed out. Twenty-four response were received:

Agencies, Groups and Individuals that responded to the Draft
Statement and to whom the Final Statement will be sent:

Federal Agencies

1. Agricultural Research Services, USDA
Soil Conservation Service, USDA
Department of Interior
Environmental Protection Agency

State Agencies

2. Illinois, Bureau of The Budget
Maine, Department of Conservation
Michigan, Department of Natural Resources
Minnesota, Department of Natural Resources
Ohio, Department of Natural Resources
Pennsylvania, Department of Environmental Resources
West Virginia, Department of Natural Resources
Wisconsin, Department of Natural Resources

Associations

3. Coalition For Economic Alternatives
Defenders of Wildlife
Environmental Defense Fund
Friends of the Earth
The Izaak Walton League of America
Minnesota Herbicide Coalition
The Wilderness Society

Others, Individuals and Companies

4. Mason C. Carter, Purdue University
Harvey A. Holt, Purdue University
Mrs. G. Altonen
Consolidated Papers, Inc.

TSI Company

VIII. Date Draft Environmental Statement made available to the
Environmental Protection Agency and to the public
September 19, 1977.

Date Final Environmental Statement made available to the PS ings
Environmental Protection Agency and to the public OCl 24.

iv

USDA FOREST SERVICE ENVIRONMENTAL STATEMENT
VEGETATION MANAGEMENT WITH HERBICIDES IN THE EASTERN REGION

USDAS=—FS5— R9°— FES — ADM — 77 - 10

Prepared in accordance with

Section 102(2)(c) of Public Law 91-190

Type of Statement: Final

Date of Transmission to EPA: OCT 24 1978

Type of Action: Administrative

Responsible Official: Steve Yurich

I. DESCRIPTION

Regional Forester
Eastern Region

TABLE OF CONTENTS

A. INTRODUCTION

1. Environmental Objectives

2. Management Objectives

a.

Db

Forest Roads, Trails and Facilities
Range
Recreation

Special Use Permits

(1) Utilities and Communication Uses

(2) Transportation Uses

(3) Agriculture Uses

(4) Recreation Uses

Timber Management

(1) Release

(2) Thinning

(3) Tree Nurseries

(4) Reforestation

Wildlife

(1) Wildlife Openings in Forest Areas
(a) Opening Maintenance
(b) Sharptail Grouse Management
(c) Kirtland's Warbler Habitat Management

PAGE

Lo

ODOM MAOAOAARDaAMNFF LFW

ire

(2) Browse Production
(3) Wetland Plant Management
(4) Aquatic Plant Management

ENVIRONMENTAL SETTING
Appalachians

Lake States
Midlands

New England

Ozark Highlands

WP WN rH

SOCIAL AND ECONOMIC CHARACTERISTICS
Appalachians

Lake States

Midlands

New England

Ozark Highlands

MF Wh ee

ALTERNATIVES

1. Biological

a. Control

b. Tree Improvement

Fire

Herbicides

Manual

Mechanical

No Action or Postponing Action

Nim Wh

DESCRIPTION OF HERBICIDES PROPOSED FOR USE

METHODS OF APPLICATION
1. Basal Stem

2. Cut Surface

3. Foilage

4. Soil Treatment

REVIEW OF PLANNED USES

ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION

A.

NON-LIVING COMPONENTS

1 Adee.

2. History and Archeology

3. Land Ownership - Land Use
4. Soils

ou Visual

6. Water

LIVING COMPONENTS

1. Domestic Animals
2. Human Health

3. Soil Organisms

vi

Lt We

IV.

4. Vegetation

a. General

b. Endangered or Threatened Plant Species
5. Forest Vertebrate Animals

a. General

b. Mammals

Cue By ras

d. Fish and Amphibians

e. Endangered and Threatened Animal Species
6. Forest Invertebrate Animals

a. General

b. Insects

c. Crustaceans and Mollusks

C. SOCIAL ECONOMIC COMPONENTS

D. HERBICIDE TOXICITY

Zine.

TCDD (a contaminant of 2,4,5-T and 2,4,5-TP)
254-D

2o¢c5- EPpy (Silvex)
Atrazine

Dalapon

Dicamba

Amitrole

Picloram

10. MSMA and Cacodylic Acid
ll. Krenite

12: Simazine

13. Dichlorprop

OMON AUK WN -

FAVORABLE EFFECTS

A. NON-LIVING COMPONENTS

B. LIVING COMPONENTS

C. SOCIAL ECONOMIC COMPONENTS

SUMMARY OF PROBABLE ADVERSE ENVIRONMENTAL EFFECTS
WHICH CANNOT BE AVOIDED

A. NON-LIVING COMPONENTS

B. LIVING COMPONENTS

RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S
ENVIRONMENTAL AND MAINTENANCE AND ENHANCEMENT OF
LONG-TERM PRODUCTIVITY

A. NON-LIVING COMPONENTS

B. LIVING COMPONENTS

C. SOCIAL ECONOMICS COMPONENTS

vii

101

102
102
119
i Be ie
146
150
152
15
157
158
161
162
162
163

164

164

165

165

166

166

168

169

169

1/0

LZ

v.18

VII.

Note

IX,

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES
CONSULTATION WITH OTHERS

BIBLIOGRAPHY

GLOSSARY OF TERMS

APPENDIX

A. CONTROLS ON HERBICIDE USE

B. SAMPLE ENVIRONMENTAL ANALYSIS

C. LIST OF AGENCIES AND ORGANIZATIONS WHO RECEIVED
DRAFT STATEMENT AND RESPONSES RECEIVED

viii

PAGE

172
178,
174

189

dine

A.

DESCRIPTION

INTRODUCTION

On September 30, 1973, the Eastern Region of the Forest
Service made a Final Environmental Statement, The Use of
Herbicides in the Eastern Region, available to the Council
on Environmental Quality and the public. The 1973 herbicide
statement covered all herbicide projects within the Eastern
Region through CY 1978.

This statement which incorporate significant new information
covers the Eastern Region's National Forest herbicide
program of the future. It does not concern herbicide use on
privately owned land adjacent to, or intermingled with,
National Forest land. This statement will focus on the
scope and direction of a broad and continuing Regional
herbicide program. Detailed impacts of local projects and
local benefit/cost reviews will be united with this
statement through site specific environmental analysis
(Appendix B); or environmental statements, if required.
Herbicide use is discussed for six management activities:
timber management; forest roads and facilities; special use
permits; wildlife; range; and, recreation. The environmental
impacts and the effects of this program will be reviewed
annually, and when necessary, addenda will be published to
update this statement. Addenda will be published in the
Federal Register and filed in National Forest offices within
the Eastern Region.

When alternative methods of vegetation management are
technologically available and economically feasible they
will be preferred over the use of herbicides. Herbicides
will be recommended and used when they will achieve the
specific resource management objectives with the least
potential hazard to non-target components of the environment.

1. Environmental Objectives

The environmental objectives of vegetation management
include preserving the integrity of the ecosystem,
avoiding irreversible degradation, and protecting human
health and endangered plant and animal species while
selectively altering the composition and density of
plant communities. The purpose is to create growth
conditions favorable to certain forest trees, range
grasses and forbs, wildlife browse, and other preferred
plant species, while discouraging unfavorable or
unwanted pest plants. Vegetation management also
includes the modification of environmental factors
associated with plant growth: soil protection, exposure
to sunlight, adequate moisture, and available nutrients.

Management Objectives

Management's objective in the Eastern Region is to
manage the Forests so as to, maximize the net public
benefits while staying within the constraints set by the
environmental objectives. Activities where vegetation
management benefits the public include:

a.

Forest Roads, Trails and Facilities

Vegetation management on forest roads and trails is
necessary to prevent brush encroachment into driving
lanes, to maintain sight distances on curves for the
safety of the traveler, to permit drainage ditches
and associated structures to function as intended,
and to reduce roadway maintenance costs. The
possibility of accidents involving pedestrians,
animals, and vehicles is decreased when brush is
controlled and rights-of-way are maintained.

A method of vegetation control is needed that can be
used without disturbing highly erodable soil on cut
or fill slopes, where rock out croppings exist, and
where stones and stumps are present. Roadside
Maintenance often receives a low priority, compared
to maintenance of the road's driving surface. When
dollars are available for roadside maintenance, a
method is needed that will produce lasting results,
especially if brush is a problem.

Control of pest grasses and woody vegetation near
radio transmitter sites, equipment storage areas,
warehouses, Sign posts, and parking lots is needed
to reduce the risk of fire and to protect the
facility from physical damage. In addition,
uncontrolled vegetation and algae growth in sewage
lagoons interfers with the treatment process,
equipment operation, and can create a health hazard.

Range

Vegetation management on range allotments is
necessary where past grazing and/or management
practices have allowed less palatable or noxious
forage to increase at the expense of more desirable
forage plants. Often times, the invading plants are
poisonous. A method of forage renovation is needed
that does not involve complete destruction of the
whole forage resource for a long period of time.

Brush and trees that invade range lands compete with
forage grasses for sunlight, moisture, space, and
nutrients. They need to be controlled. A method
which keeps fences and cattle guards clean of brush

d.

and vines is needed. Otherwise, the life of these
structures is shortened, resulting in costly repairs
and replacements.

The 1975 national assessment, prepared in accordance
with the Forest and Rangeland Renewable Resources
Planning Act of 1974, predicts that the Nation's
range forage demand will increase by 17 percent
between 1970 and 1980. There seems to be little
possibility that grain production costs or demand
for grain as a human food are going to decrease
Significantly to lessen this growing demand for
forage. In fact, range forage, as a source of
livestock feed can be converted to meat with less
expenditure of fossil fuel, labor, and fertilizer
than grain and is receiving increased attention.
The Eastern Region's National Forest System lands
are capable of producing additional forage. Range
management programs designed to control vegetation
can improve operating efficiency and increase total
forage production.

Recreation

Vegetation management is used in recreation areas
for the safety and convenience of the public. At
these sites, methods of plant control are needed
which allow for elimination of target weed or
encroaching vegetation with a minimum of disturbance.

Poisonous weeds in areas of concentrated public use
such aS campgrounds, picnic sites, and swimming
beaches, are a danger to people, especially
children. Skin poisoning accounts for an annual
loss of 330,000 working days in the U.S., plus added
days of restricted activity (Du Pont Co. 1976). A
method which would control these poisonous plants
and reduce their resprouting, yet not directly
expose workers to the toxic effects of the weeds is
desirable.

Recreation area walkways and parking lots require
protection from invading grasses and weeds that
break up black top surfaces, hide traffic control
structures, and lower aesthetic values.

Special Use Permits

The Eastern Region has granted permits allowing
other government agencies, industry, and individuals
to construct and maintain roads, pipelines, power
and communication lines, and recreation facilities,
and to engage in agricultural activities on National
Forest land. Special use permits require the :

development of a joint management plan by the Forest
Service and permittee. Vegetation maintenance often
needs to be a part of this management plan.

Gy

(2)

(3)

(4)

Utilities and Communication Uses. Having the

facilities necessary to carry available services
to the public is only one challenge utility
companies must face in providing reliable
services to customers. Utility companies, such
as gas, electric, and communication, must
Maintain their rights-of-way so.as to provide
reliable service and at the same time provide
an aesthetically pleasing appearance and a land
area capable of supporting wildlife and
recreation activities. Trees or brush growing
into conductors not only cause outages, but
other major and costly problems. Uncontrolled
vegetation growth can be a fire hazard, hinder
access of maintenance crews, and hide potential
problems from line inspectors. The aim of
right-of-way vegetation management is to grow
select vegetation requiring little maintenance,
while affording benefits for scenic, wildlife,
and recreation values, and soil stabilization.

Transportation Uses. Approximately 2,480 miles

of roads, highways and railroads (21,300 acres)

located on Eastern Region National Forest
System lands are maintained by someone other
than the Forest Service. These travelways are
regulated by easements and permits issued
mainly to individuals, industry, or State or
local government highway departments. The
vegetation management problems on these
roadways are similar to those stated for Forest
Service roadway maintenance. Vegetation control
along railroad tracks is required to allow the
train engineer a clear view of the tracks ahead
and to lessen the chance of train caused wild
fires.

Agriculture Uses. About 5,000 acres of Eastern
Region National Forest land is under permit for
cultivation of crops and pasture. These lands
are managed similar to commercial agriculture
lands and present many of the same weed control
problems. There is a need for control of weeds
in crop lands and noxious and poisonous plants
on pasture lands. Most of the permit areas are
small in size, and the permittees prefer to
manage them with the equipment and practices
accepted for use on the family farm.

Recreation Uses. Selected areas of the Eastern
Region are under permit or cooperative agreement

ee

to individuals or groups for the development
and maintenance of recreation facilities.

These developments range from summer home
cabins used by a single family, to winter
recreation complexes available to thousands.

In 1975, the number of recreation permits was
13359 708,830 acres). The objective of
vegetation management on special use recreation
lands is to present a visually attractive and
natural, but safe landscape. This involves
highly selective management of vegetation in
lawns, along trails and walkways, and around
buildings, sewage treatment facilities, parking
lots, signs, and play areas.

Timber Management

Ensuring an adequate and containing supply of timber
and timber products was a major reason for
establishing the National Forest System in 1897.
Today, supplying wood fiber remains a major function
of the National Forests, as reaffirmed by Congress
with the passage of the National Forest Management
ACteOLm@19/ 6:

Demand for timber from U.S. Forests is expected to
increase. Using medium level projections and a 1970
price base, the The Nation's Renewable Resource, An
Assessment, 1975, shows demand could rise from 11.7
billion cubic feet in 1970, to 27.3 billion cubic
feet by 2020; an increase of 133 percent in 50
years. Under present conditions, both the Nation's
supply and demand for wood products are rising.
Because demand is rising faster than supply, either
the price of wood products will climb to the point’
of balancing supply with demand, or supplies must be
increased to the point of holding down price rises.
Therefore, given a fixed or decreasing land base it
is necessary to intensify management so a drastic
increase in relative price can be avoided.

Future supply increases will depend largely on the
level of forest management, the area of land
available for commercial timber production, and
timber cutting practices and policies. However,
supply projections based on a trio of present trend
assumptions indicate a demand-supply squeeze will
occur. The three assumptions are: (1) recent
levels of management will continue, (2) cutting
practices and policies will be similar to those of
recent years, and (3) the slow downward trend in
available commercial timber land area will extend
through the next 45 years. (Resources Planning Act,
1975)”

Improvements in utilization and increases in net
imports of softwoods from Canada and hardwoods from
tropical regions can meet part of the projected
growth in demand. However, these potentials are
relatively small, when compared to the total
increase in demand. The Nation must look to its
own domestic timber resources as the best means of
meeting this demand. Intensive vegetation
Management on private and public lands is one way to
help meet the demand.

In some timber stands, individual trees assert
dominance over others and the stands develop
efficiently. In other cases, crowding becomes
serious. At its worst, this crowding results in
death, stagnation, or spindly stands of small trees,
all of which are seldom marketable, even with long
stand rotations. In most cases, greater stand
growth efficiency can be achieved by judicious
removal of some of the trees; new growth is
concentrated on trees that are best able to grow
to a large size.

Vegetation management early in the life of a timber
stand can have a major beneficial impact on future
timber yields. A practice known as timber stand
improvement (TSI) can increase the average annual
yields of wood per acre on National Forest lands in
the Eastern Region. Common TSI activities include:

(1) Release. This constitutes any type of treatment
that frees young trees from overtopping or
closely surrounding vegetation, which is
inhibiting their establishment as the new
forest stand. Some typical examples are
cutting, halting the growth of unwanted trees
and brush which overtop young conifers, and
deadening large cull trees in stands of young
hardwoods. Removal of grass, weeds, or brush
from around individual seedlings or small trees
to reduce competition for nutrients, soil
moisture, and sunlight also constitutes release.

(2) Thinning. Thinning operations aim at optimizing
the growth and development of trees in
established stands by controlling the stocking
or tree numbers. Felling or deadening of trees
in an immature stand, in order to accelerate
diameter growth, control species composition,
or improve average form of the remaining trees,
without permanently breaking the stand canopy,
may be classified as thinning (Figure 1).

It is in the land management and timber
management plans that guidelines on what

eS

49 YEARS SLOW GROWTH

7 YEARS FAST GROWTH FOLLOWING
TIMBER STAND IMPROVEMENT

Figure 1. Cross-section of a tree left in an area that was thinned.
Average annual growth per acre increased by 94 percent after
thinning.

percentage of each National Forest should be in
hardwood and conifer acreages are noted. The
decision to release or thin a timber stand
which needs treatment is follow-up to a prior
commitment to grow conifers or hardwoods.

(3) Tree Nurseries. Nursery production of trees for
private, State, and Federal reforestation
programs is carried out in Federal and leased
nurseries on Eastern Region National Forest
System lands. The nursery beds used for
growing seedlings are fertilized regularly and
properly watered. But, these conditions are
also favorable for weed growth. If the weeds
in nursery beds were not controlled, their fast
growth characteristics would enable them to
dominate the tree seedlings, causing heavy
mortality

(4) Reforestation. Another timber activity,
reforestation, requires vegetation management.
In preparation for planting, seeding, or
natural regeneration, a site must be prepared.
Foresters call this practice site preparation.
Reforestation sites may be abandoned pastures
or fields, rights-of-way, brush fields, or
recently harvested timber stands. Site
preparation can be for either artificial
reforestation, such as planting or seeding by
people, or for natural reforestation where new
trees are the result of volunteer growth. In
either instance, site preparation is the act of
modifying vegetation and/or soil to make it
suitable for artificial or natural
reforestation.

Wildlife

The objective of vegetation management in wildlife
management is to retard or change plant succession.
Descriptions of the wildlife programs in the Eastern
Region which depend on the activity follow:

(1) Wildlife Openings in Forest Areas

(a) Opening Maintenance. Small, 1-5

acre openings, for game and non-game
species, are important wildlife habitat
components. Numerous openings result
temporarily from timber harvest, fire,
mechanical disturbance, and natural
change. Others are developed and
maintained through effective management
plans. Although the inventory is not
complete, approximately 1 percent of the

(2)

Region's lands are in permanent openings.
The long-term objective is to eventually
maintain 3-5 percent of the Region's lands
in wildlife openings. Natural and manmade
openings require maintenance to control
the encroachment of conifers and
broad-leaved trees. Controlling some
plant species along opening edges
preserves other shrub species of value to
wildlife.

(b) Sharptail Grouse Management. Approximately
23,000 acres are managed in the Eastern
Region so suitable habitat can be
maintained for sharptail grouse, and a
variety of wildlife associated with an
Open environment. The optimum range for
sharptail grouse includes a mixture of
open, shrub, and escape cover. Treatments
are needed to maintain areas in a low
shrub vegetation community.

(c) Kirtland's Warbler Habitat Management.
Some 55,000 acres of jack pine stands have
been identified as critical habitat for
the nesting of Kirtland's Warblers on the
Huron National Forest. Jack pine
regeneration requires the stands be burned
under prescribed conditions. (Jack pine
cones require heat to open and release
their seeds.) However, experience has
shown that burning in jack pine stands
stimulates oak sprouting. Where the
density of oak stems occupy over 25
percent of the area, these stands will not
be used by the Kirtland's Warbler. A
method is needed to eliminate the oak
sprouts or sprouting potential.

Browse Production

Production of red maple, dogwood and other high
value browse species, preferred by deer, can be
increased with properly timed vegetation
treatments. Aerial application of herbicides in
scrub aspen stands have been found to increase
browse by 4,000 stems per acre. Vegetation
treatments stimulate such species as red maple,
to increasing browse yield at greater rates than
lower value browse species. In general, a
favorable browse increase results when the
density of less desired overstory vegetation is
reduced.

(3) Wetland Plant Management

Managed wetland systems, such as greentree
reservoirs which replace lost waterfowl
habitats, often require some plant management to
keep weed growth from blocking water flow in
ditch channels. Dikes built to control water
levels require protection from tree roots of
sprouting trees. The roots penetrate the dikes,
allowing water to escape and weaken the dike.

(4) Aquatic Plant Management

Vegetation found in an aquatic environment is as
diverse and specialized as that associated with
any forest habitat. A variety of submergent and
emergent aquatic plants, along with various
forms of algae, are present. These plants serve
as food sources for herbivorous animals, and
provide habitat for insect production upon which
fish, waterfowl, and other animals are dependent
for food. The aquatic environment is generally
less "stable" than the terrestrial environment,
and is sensitive to minute changes in the
environment.

Situations may exist where algae or aquatic
plants become dangerous or a nuisance to man and
wildlife. Aquatic vegetation can reduce the
diversity of the aquatic ecosystem, and effect
the dissolved oxygen levels of water, which can
result in fish kills. An excess of aquatic
vegetation and algae is considered undesirable
in ponds and lakes used for fishing, boating,
and swimming. Several species of blue-green
algae, (cyanophyceae), produce toxic substances
when they die and decay. These algae have been
responsible for mammalian, avian, and fish
deaths (Bennett 1971). Controlling aquatic
vegetation can improve many of these situations.

ENVIRONMENTAL SETTING

This 20-State Eastern Region covers a diverse area, with
every land form from jagged mountain peaks to gently rolling
fields represented. The Forest Service has broken the Region
down into five major areas to facilitate land management
planning. Each area is made up of National Forests
reflecting similar geographic, climatic, and social-economic
conditions. The areas include the: Appalachians, Lake
States, Midlands, New England, and Ozark Highlands.

10

i.

Appalachians

The Appalachian area consists of hilly or mountainous
uplands extending from northern Pennsylvania to southern
Ohio and West Virginia. The National Forests in this are
the Allegheny, Monongahela, and Wayne. (Figure 2)

The climate is characterized by distinct seasons,
frequent changes of weather, considerable precipitation,
high humidity, moderate cloudiness, and winds. The
sources of many rivers are located in the highlands.
These headwaters are cold, clear, and generally clean.
However, in some areas, water has been polluted by
sediment, acid water from coal mine drainage, sewage, and
industrial discharges and spillage. The soils of the
Appalachian hardwood forest are highly variable and
affect the capability of the area to produce timber,
wildlife forage, water, and a variety of recreational
opportunities.

The Eastern hardwood forests are some of the most complex
biological communities known. The Appalachian hardwood
forests are dominated by oaks, with spruce and fir
occurring on the higher elevations. A wide variety of
other trees and shrubs, many of which are unique, also
occur in the area. Living in close association are many
forms of wildlife, including rare and endangered species.

Range is of minor but growing importance. Fossil fuel
and mineral production is major.

Lake States

The Lake States area is known for many water bodies and
diversified terrain. About 1 out of every 16 acres is
surface water. Portions of three States - Michigan,
Minnesota, and Wisconsin, in which eight National Forests
are located, make up the area. The Forests are the
Chequamegon, Chippewa, Hiawatha, Huron, Manistee,
Nicolet, Ottawa, and Superior.

The area has long, cold winters and short growing
seasons. Much of the moderate precipitation falls as
snow and spring run-off goes to recharge the many lakes
and wetlands. Streams are plentiful, but compared to
other areas of the Eastern Region they carry little
water. Water quality is generally high, tends to be
soft, and is often stained brown by drainage from organic
wetlands.

The soils in the Lake States are reflections of glacial
deposit, featuring glacial outwash, upland moraine,
lowland moraine, lacustrine plains, and organic soils.
Erosion and stream sedimentation hazards are insignificant
except in small areas. A variety of minerals are found
under these surface soils.

11

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12

The National Forest Syston

U. S. DEPARTMENT OF AGRICULTURE
FOREST SERVICE — EASTERN REGION
REGIONAL HEADQUARTERS
633 W. Wisconsin Ave., Milwaukee, Wisconsin 53203

FIELD OFFICES MISSOURI

Mark Twain National Forest Rolla. Mo. 65401
ILLINOIS Ranger Districts and Headquarters

Shawnee National Forest

317 E. Poplar St. Ava Ava, Mo.
Harrisburg, Ill. 62946 Cassville Cassville, Mo.
pape Cedar Creek LU A:ea Fulton, Mo.
. Ranger Districts and Headquarters Doniphan Doniphan, Mo.
Elizabethtown Elizabethtown, IN. Fredericktown Fredericktown, Mo.
Jonesboro Jonesboro, III. Houston Houston, Mo.
Murphysboro Murphysboro, III. Poptar Bluff Poplar Bluff, Mo.
Vienna Vienna, III. Potosi Potosi, Mo.
Rolla Rolla, Mo.
INDIANA-OHIO Salem raat Mo. 2
Wayne-Hoosier Nati Van Buren Van Buren, Mo.
1615 J Nase ELS Willow Springs Willow Springs, Mo.
Bedford, Indiana 47421 Winona Winona, Mo.
Brownstown Brownstown, Ind.
Tell City Tell City, ind.
pies Athens, Ohio
ote onton,.Ouio NEW HAMPSHIRE & MAINE
MICHIGAN White Mountain National Forest, Federal Bldg.

Hiawatha National Forest, 2727 .N. Lincoln Rd.

719 Main St., Laconia, N. H. 03246

Escanaba, Mich. 49829 Ammonoosuc Littleton, N. H.
Manistique Manistique, Mich. Androscoggin Gorham, N. H.
Munising Munising, Mich. Evans Notch Bethel, Maine
Rapid River Rapid River, Mich. Pemigewasset Plymouth, N. H.
St. Ignace St. Ignace, Mich. Saco Conway, N. H.
Sault Ste. Marie Sault Ste. Marie, Mich.

Huron-Manistee National Forests
421 S. Mitchell Street
Cadillac, Michigan 49601

PENNSYLVANIA

Allegheny National Forest, Spiridon Bldg

Warren. Pa., 16365

; ee Bradtord Bradford, Pa.
Baldwin Baldwin, Mich. Marienville Marienville, Pa.
Cadillac Cadiliac, Mich. Ridgway Ridgway, Pa.
Harrisville Harrisville, Mich. Sheffield Sheffield, Pa.
Manistee Manistee, Mich.

Tawas East Tawas, Mich. Green Mountain Nationa! Forest
White Cloud White Cloud, Mich. Federal Building West Street

Ottawa National Forest

Rutland, Vermont 05701

ichi Q Manchester Manchester, Vt.
Se ee aie a eae . Middlebury Middlebury, Vt
Bergland Bergland, Mich. Rochester Rochester, Vt.
Bessemer Bessemer, Mich. Hector LU Area Montour Falls, N.Y.
Jron River lron River, Mich.
si peo Mich. WEST VIRGINIA
ntonagon ntonagon, Mich. j F 4
Watersmeet Watersmeet, ich, Nee
Cheat Parsons, W. Va.
MINNESOTA ‘ Cauley Richwood. W. Va
Chippewa National Forest Greenbrier Bartow, W. Va.
Cass Lake, Minnesota 56633 Marlinton Martinton, W. Va.
: Potomac Petersburg, W. Va.
Blackduck Blackduck, Minn. Whi . : .
ace Cake (ace iene. Minn. White Sulphur ene Springs,
Deer River Deer Rivet Minn. ie
Marcell Marcell, Minn.
Walker Walker, Minn. WISCONSIN

Superior National Forest, 236 Federal Bldg.
Duluth, Minnesota 55801

Aurora Aurora, Minn.
Gunflint Grand Marais, Minn.
isabella Isabella, Minn.
Kawishiwi tly, Minn,

LaCroix Cook, Minn,

Tofte Tofte, Minn.

Two Harbors Two Harbors, Minn.
Virginia Virginia, Minn.

Sel
Ww)

Chequamegon National Forest, Federal Bldg.
Park Falls, Wisconsin 54552

Glidden Glidden, Wis.
Hayward Hayward, Wis.
Medford Medford, Wis.
Park Falls Park Falls, Wis.
Washburn Washburn, Wis.

Nicolet National Forest, Federal Bldg.

Rhinelander, Wis. 54501

Eagle River
Florence
lakewood
Laona

Eagle River, Wis.
Florence, Wis.
Lakewood, Wis.
Laona, Wis.

Many different timber types make up the forest cover,
including most northern hardwoods and different conifers
- pine, spruce, fir, hemlock, and cedar. Within these
forests, a diversity of wildlife is found. The most
important Lake States breeding ranges for the bald eagle,
osprey, Kirtland's Warbler and eastern population of
greater sandhill crane are located on the National
Forests. Grazing is minor within this area

Midlands

The Midlands consist of rough and rolling lands in
southern Illinois and Indiana. The National Forests are
the Shawnee and Hoosier.

The climate is characterized as continental. Temperature
extremes from 115°F to -26°F have been recorded.
Precipitation ranges from 40 to 50 inches annually, with
most falling as rain. Violent spring and summer storms
are not unusual and are sometimes accompanied by
tornadoes. Stream run-off is variable, with many smaller
tributaries going dry in summer and flow deficiencies
restricting water use in lower reaches. To improve this
situation and provide a water supply for such uses as
recreation, fish and wildlife habitat, a number of ponds
and multi-purpose reservoirs have been constructed on
streams originating within, or passing through, the
Shawnee or Hoosier National Forests. These ponds,
reservoirs, and streams are a valuable fishery resource
for the Midlands.

Midland soils are derived from sandstone, shale and
limestone; are usually acid, low in phosphates, calcium,
and nitrogen; and, are susceptible to erosion. The
Forest lands are capable of rapid hardwood growth.
Highly productive agriculture lands are present in
scattered locations, especially along river bottoms.

A mixture of plants are found within the Forests.
Hardwoods are the most evident, but other plants, ranging
from xerophytic prickly pear cactus to hydric swamp
tupelo and bald cypress can also be found. Several rare
and unique plants also occur. Associated with the
diverse vegetation is a variety of terrestrial wildlife.
Local waters are used as resting and wintering areas by
migrating waterfowl.

The unglaciated Midlana's terrain exhibits unique
geological formations and is rich in archeological
history. Forest ownership is extremely scattered.
Agricultural uses are increasing.

14

New England

The New England area, laced with numerous streams and
dotted with lakes and ponds, contains rolling foothills,
coastal plains, and the highest mountain peaks in the
Northeast. National Forests are the Green Mountain and
White Mountain, located in the States of Maine, New
Hampshire, and Vermont. The New England year is divided
into four distinct seasons, with frequent weather changes
influenced by the ocean and high elevation.

Today, forests composed primarily of northern hardwoods
and spruce-fir cover 70 percent of the area. Alpine and
subalpine vegetation is found in higher mountain areas.
The vegetation provides productive habitat for an
assortment of game and non-game wildlife. National
Forest water yield and quality is high, while that which
is closer to population and industrial centers is
seriously degraded. The waters provide a variety of
fishing experience.

Forage and agricultural uses are common on private lands
within the Forests. Mineral activities are limited to
common variety sand, gravel, and stone.

Ozark Highlands

The Mark Twain National Forest in Missouri, is located in
the Ozark Highlands. Landscape, climate, vegetation, and
wildlife in the Ozark area is often varied and distinct.
The range of soil fertility is extreme, from rich river
bottom lands to almost barren glades. The Ozark plateau
is underlain with limestone and dolomite bedrock,
honeycombed with underground streams and caverns. It is
here that such rare animal life as the Indiana bat and
the blind cave fish can be found.

National Forest land in Missouri now represents 11
percent of the State's commercial forest land. Total
commercial forest land acreage may be shrinking by as
much as 100,000 acres annually, as private landowners
convert their brush or forest land to grass.
Urbanization is also reducing the State's acreage of
forest land. The decreasing acreage of forest land in
private ownership is increasing the pressure on publicly
owned forested lands.

This area has local problems with water quality, timing
of flows, and duration of flows; however, it does not
suffer from a shortage of water. The nature of karst
topography allows easy contamination of ground water.

In spite of considerable precipitation and high humidity,
lack of available surface: water places limits on the
wildlife and recreation resources.

is:

Forest types are primarily oak-hickory and pine
hardwoods. Mixed with the forests, is a large range
resource. Mineral deposits are found throughout the
area.

SOCIAL AND ECONOMIC CONSIDERATIONS

The Eastern Region is rich in cultural history. On September
1, 1976, the National Register of Historic Places listed 17
sites located within National Forests in the Eastern Region.
These 17 sites merit special recognition and management.

Many other culturally significant areas within the National
Forests are protected through normal multiple use planning
and management.

i

Appalachians

The Appalachian Area has historically possessed a
specialized economy, heavily dependent on utilization of
the Region's natural resources: minerals, timber,
farmland, and water. Prior to the early 1960's, the
depletion of resources and mechanization of industry
caused jobs to disappear and out-migration to occur. The
area experienced much social and economic distress;
however, with recent expansion of light manufacturing and
service industries, employment has shown a marked
improvement. In-migration has started in a few areas.
Per capita income is increasing at a strong rate.

Lake States

The economy of the Lake States Area is dependent on
natural resource-based businesses. Forest industries
employ the largest number of people; agriculture, mining
and recreation are the other leading employers. Growing
demands for wood products, increased interest in
minerals, and the desire of many individuals in Eastern
cities to "get away from it all'' offers an optimistic
outlook for the area's economic future. (USDA Forest
Service, LSAG)

Natural resource-based economies have traditionally grown
slower than industrialized economies. The Lake States
Area is no exception, as demonstrated by a long history
of slow economic growth.

Seeking greater financial security, many young people
have moved from the area. This out-migration is
reflected in 33 percent of the Lake States area residents
being 65 years of age or older (only ten percent of the
National population falls into this age bracket). Also,
there are only 28 people per square mile, about half of
the National average. The life style of the area is
classified as rural, with the area's largest urban center

16

being Duluth - Superior and having a population of
150,000 people. Total population within the Lake States
Planning Area was estimated at 3.1 million people in

IJ 70ee ites) expectedsto increase to 3.3 million by 1990,
and 3.4 million by 2000.

Midlands

The Midland Area ecomony is truly a mixed economy.
Industrial activities, manufacturing, and service jobs
account for more than half the area's employment.
Mining, agriculture, and forestry are important in some
areas.

Social and economic development has been influenced by
the major rivers of this area, which serve as the
principle commercial link between the Midlands and the
rest of the central United States, from Pennsylvania to
New Orleans. At the same time, these rivers have helped
isolate the area, slowing economic and social
interchanges. Economically, the negative effects are
felt through high tolls on products, and the need to
travel great distances in order to reach a bridge and
cross a waterway.

New England

The New England Area, with its 35 million people, is one
of the most populated areas of the country. The National
Forests of New England are among the most intensively
used forested areas in the Nation. With 17 percent of
the Nation's people, the population density averages 340
people per square mile, compared to a National average

obe Stok,

Population distribution is extremely uneven, with
concentrations along the eastern seaboard megalopolis and
only 2 million people in the more rural States of Maine,
New Hampshire, and Vermont. The projected growth within,
and adjacent to, the New England Forests will have a
marked impact on both public and private lands within the
area. The National Forests are a significant portion of
the public land in this area, and they will share this
impact in the form of ever-increasing pressures for the
goods and services they provide.

Ozark Highlands

Although agriculture has been the basic industry of the
area, the presence of an abundance of natural resources
has provided for considerable hunting, fishing, logging
and mining. The population of the Ozark Highlands Area
has changed irregularly over the past 40 years,
increasing slightly in the 1930's and 1960's, and
decreasing in the 1940's and 1950's. One of the major

17

reasons for the decline was the exceedingly high rate of
out-migration by young people. The lack of employment
opportunities is the major factor behind this
out-migration. Also of significance, is the change in
land ownership patterns. Farm ownership has given way
largely to owners who use the land for rural residence,
hunting clubs, investment purposes, etc.

The per capita personal income of the area has increased
steadily since 1940; in addition, the dollar gap between
the Nationwide per capita personal income average and
that of the area is closing. Some influx of light
industry has occurred. Through proper management and
better utilization, the forest-based industries will
substantially increase and contribute to the economy.
The mineral industry will continue to increase its
contribution to the area's economic well-being. The
improved economic outlook is already reflected in a
decreasing rate of out-mitgration by the area's
population; however, the population growth in the Ozark
Highlands is not keeping pace with the National growth.

The National Forest System lands are a significant
economic entity in the area. From 36 million to 45
million people live within a day's driving distance of
the area. Current programs are estimated to be directly
or indirectly responsible for over 1,200 jobs, with their
total value to the area said to exceed $15 million. A
program aimed at supplying the apparent future demands
would more than double the economic benefits.

D. ALTERNATIVES
1. Biological

a. Control. Biological control of vegetation is a
natural process featuring animals, insects, disease,
biochemical interference, and environmental changes.
Releasing more of a plant's natural enemies or
pathogens can induce natural vegetation control. The
objective is to work against the pest plants by
either reducing their growth during a specific period
of time or to reduce their numbers.

The use of livestock is one form of biological
control. Livestock has been used to reduce competing
grasses and forbs from plantations. In some areas,
livestock have been used to reduce buildup of
specific vegetation species by intensive grazing.

Some advantages in using livestock are:

a) Low cost.

18

b) Should the population increase and more food
production lands be last to development, using
livestock to manage vegetation could become a
very important social benefit.

c) Produces a very low environmental hazard to
man.

d) And, if rare, endangered or threatened
plants exist on or near the treatment site, they
can be protected from grazing and trampling
damage by fencing or other physical barriers.

Disadvantages:

a) Competition between wildlife and some forms
of domestic livestock for food, water, and
shelter will exist. Continual disturbance to
wildlife will exist when livestock is present.

b) Cold weather and winter snows have excluded
grazing animals from some areas of Region 9.
This is especially true of goats, which have a
low tolerance to cold.

c) Livestock are affected by some diseases that
could spread to wildlife, such as deer.

However, with proper precautions, the
opportunities for transmitting diseases to
wildlife could be reduced.

d) Soil compaction can be a problem in bedding
areas. Livestock trails can be a source of
erosion.

e) Biological controls using livestock may
cause a serious predation problem, making
predator control necessary and giving rise to
pressure from livestock owners for such control
programs.

£) Rare, endanagered, and threatened plants and
their habitat stand the chance of being harmed
or destroyed if not excluded from use by
livestock.

g) Confinement of livestock to specific areas
can involve high costs, but if the animals are
left to wander, areas not intended for grazing
may be used.

The Eastern Region's potential for forage production

is receiving more attention. Where livestock is
available and Forest Service people are trained to

19

administer grazing, it could become a method of
biological vegetation control.

Aquatic vegetation control is mostly a problem in
manmade lagoons, ponds and lakes. While lagoons are
found Region wide, the manmade ponds and lakes are
common to the Ozark, Midlands and Appalachian areas.
Ducks and geese can be used to control excess duck
weed and other aquatics. By up-rooting plants in
search for bottom food, carp can control aquatic
vegetation. Efforts at such aquatic vegetation
control result in increased water turbidity and a
change in bottom nutrients to a more usable form.
The long-term effect is a more luxurious vegetative
growth. In many States, it is illegal to utilize
grass carp to control vegetation. Very lattleme1t
any, of this control method will be used in the
Eastern Region.

Insect damage to plants may be in the form of
defoliation, girdling, or sap removal. Common life
forms of the attacking insects are larval, nymphal,
and adult. The attacked plants are weakened or
killed.

Diseases are caused by living parasitic agents, which
live and feed on, or in, plants. They are most
commonly caused by fungi, bacteria, and viruses.
Environmental conditions have to be right before
infection occurs. Injury may be in the form of
overdeveloped tissues, stunting, lack of chlorophyll,
incomplete organ development or death of plant
tissue. Pioneering research by the Stanford Research
Institute (Wilson 1969) in the use of plant pathogens
to control weeds has identified the following
principles:

a) the natural resistance of host plants acts
as the primary deterrent to biological control
of weeds by restricting disease to insignificant
levels.

b) natural weed populations may be expected to
display a relatively high degree of natural
resistance to most local disease organisms.

c) disease susceptibility is, therefore, the
exception rather than the rule and high degrees
of susceptibility are exceptional.

d) most natural plant disease epidemics in the

past have resulted from the accidential
importation of foreign pathogens.

20

b.

e) the fact that local plant populations
develop resistance to local pathogens or insect
pests does not preclude their susceptibility to
forms from which they have been protected by
natural barriers.

Biological control can include non-living agents.
These agents include such things as nutrient
adjustments, extreme heat or cold, plant-toxic
chemicals (other than herbicides), and too little or
too much water. These causes do not act like a
disease, in that they are not transmitted from one
plant to another.

Allelopathy, biochemical interference among plants,
can be an important form of external regulation of
plant growth. Foliage extracts from some species of
fern, goldenrod, and aster has been found to be
inhibit seed germination of some other plants. Aster
foliage extract has inhibited both shoot and root
growth of seedlings growing on cotyledon reserves.
Foliage extracts of fern, grass, goldenrod, and
aster, and root washings of goldenrod and aster have
inhibited shoot growth and dry weight accumulation of
seedlings which had exhausted cotyledon reserves and
were dependent upon soil medium for nutrition
(Horsley).

Biological control holds promise for the future, but
more research is needed before it can become a viable
alternative in forest vegetation management. Many
problems still exist. The major disadvantage being
there is no way to contain biological agents within a
specific target area; they could spread into adjacent
areas. Another problem is the biological agent may
not be sufficiently specific to the target plants and
devastate beneficial plants as well.

Tree Improvement. Providing resource managers with
plants having superior growth characteristics can
reduce the need for competing vegetation control. An
example is reforestation. A growth advantage is
wanted for the planted trees. This advantage could
be obtained through biological development of the
trees which will be planted, rather than pest plant
control.

Biological evolution of vegetation is a process
featuring genetics, nursery practices, and soil
preparation for planting and succession. The
objective is to work through the preferred plants.
Individual plant characteristics for tolerance and
early, fast growth can be identified, and through
genetic breeding passed along to offspring. Plants

HN

FISCAL

bred for favorable growth characteristics could
reduce the need for control of associated vegetation.

Transplants conditioned for early, fast growth could
prevent better established plants from squeezing them
out. Physiological shock is often exhibited by
plants transplanted from a controlled nursery
environment to an uncontrolled field situation. An
adjustment in nursery soil nutrients and introduction
of mycorrhizal fungi could reduce this shock, making
the plants heartier.

Programs aimed at reestablishing vegetation usually
require some type of site preparation prior to
planting or seeding. Site preparation involves
exposing mineral soil by altering, removal or
repositioning of accumulated vegetative matter. A
thorough job of site preparation can often reduce the
need for control of unwanted pest plants.

Vegetative communities are never static for very
long. Conditions are either moving toward, or away
from climax stands. The maturity of a vegetative
community is determined by the complex association of
plants found there and what will happen under the
given conditions. Based on sound knowledge of
matural succession, host plants could be matched to
ecological conditions, rather than competing against
them.

Better use of host vegetation, holds promise for the
future. Research is under way, but findings are slow
due to the time involved in working with many forest
plant species. As a reliable method of vegetation
management, biological control is technically
unavailable and its economic benefits unknown.

Fire

Fire, aS a vegetation manipulator, has long been a part
of the forest environment. Used as a prescribed and
controlled tool, today fires are a part of the vegetative
management program in timber, range, wildlife, fuels
management, and rights-of-way clearing. The average
annual acreage in the Eastern Region receiving prescribed
burns is about 6,400 acres (average of 1974 and 1975
accomplishments).

A 2 year summary of prescribed burning plans for the
Region shows the following:

FUELS ESTIMATED

YEAR TIMBER WILDLIFE RANGE MANAGEMENT OTHER COST/ACRE

MSY)
1976

891 "aen) 1864 facS 138 act 3,869 ac. Trac. $ 4.96
$74 -a@AFe2e 134 fac 4 ac. 360" ac. Dac. $10.68

22

Some of the advantages in using fire for vegetation
management are:

1. Fire is a natural phenomenon which plays an
important role to varying degrees in different ecosystems.

2. Plant communities have different tolerances and
responses to fire.

3. Fires of varying intensities, applied
knowledgeably at the proper times of the year, can have a
beneficial impact on the resources.

4. Fire is one of the most economic methods of
achieving various objectives in land management.

5. Depending on the type of vegetation burned, the
visual impacts can be minimal, with greening occuring in
2 to 3 weeks.

Some of the drawbacks in using fire for vegetation
Management are:

1. Smoke from prescribed fires adds particle matter
to the air. However, by choosing the proper weather
conditions, the effects can be minimized.

2. If prescribed fire is not properly applied,
damage can occur to the humus, soil, and wildlife.

3. Visual impact can be heavy if woody tree growth
1s common to the area.

4, Weather conditions required for a successful burn
do not always occur.

5. The proper quantity of fuel may not be available
to support a fire which is necessary to accomplish the
job.

6. The use of fire is generally limited to areas
where selectivity is not required. Endangered or
threatened plant species may be injured.

7. Unwanted plants that are native to an area, but
have long been suppressed by successional change, can be
released by fire and once again dominate the site.

8. If the prescribed fire is not hot enough to

control plants with well established root systems,
prolific sprouting can occur.

23

9. The number of days when fire can be used
effectively are limited. In fact, some years they do not
occur at all; or when they do, the danger of wild fire
is very high, reducing the availability of fire fighters
and equipment.

10. Burning also results in the loss of significant
amounts of nitrogen through volatilization.

A properly prescribed fire which is skillfully applied
can meet specific vegetative management objectives. As
more is learned of fire's vegetation management potential
and more people are trained to administer prescribed
fire, it will receive increased emphasis in the Eastern
Region's vegetation management program. Fire will be
used where non-selective vegetation management is needed
and proper environmental safeguards can be met.

Herbicides

Chemical control of vegetation involves the use of
materials that cause a malfunction in plant growth
processes. Many of these chemicals are related to
naturally occurring plant growth regulators. Entry into
the plant may be through foliage, stems or roots.
Herbicides, as these chemicals are called, may be
selective or non-selective. The selective herbicides
generally act on broad-leaved plants, whereas most
grasses, coniferous trees, and certain legumes are
relatively resistant. The non-selective herbicides
generally control all vegetative types.

Herbicides are considered an alternative method, because
they have been found to be both effective and useful for
vegetation management. Effectiveness is shown by a
herbicide's ability to control a specific target pest or
produce a wanted plant reaction. Usefulness is
determined by the ability to achieve desired results
while applying herbicides according to directions and
cautions on the label, without causing unreasonable
adverse environmental effects.

Vegetation growth is affected by available light, heat,
nutrients, and water. Generally, the use of light and
heat are functions of the plant's foliage, while uptake
of nutrients and water are functions of the roots. The
best vegetation management alternative is that method
which not only controls the competition for above ground
light and heat, but also controls root competition for
nutrients and water. Herbicides are the only available
alternative which consistently meet these objectives.

24

Today, herbicides are available for vegetation management
programs in timber, range, wildlife, agriculture,
recreation, and rights-of-way maintenance. Some
application methods are appropriate only at certain times
of the year, while others are suitable all year long.

The major advantages in using herbicides are lasting
effectiveness, minimum environmental impact, and low cost.

It is becoming increasingly apparent that alternative
non-herbicide techniques may be more violent and more
destructive to ecosystems. Selective herbicides do not
kill all vegetation or physically disrupt the soil.

There are no physical effects on wildlife, except as they
relate to habitat change and the availability of favored
food species. Wildlife habitat areas treated with
herbicides remain accessible to browsing animals. In
contrast, areas matted with heavy slash from downed trees
and brush are only partially accessible, and by the time
wildlife can move around, the browse has often grown
above their reach.

Because of the minimum physical impact on an area treated
with herbicides, many benefits occur that are not
possible with other alternative methods: (1) Soil
protection is not removed, (2) cover and food still
remain for wildlife, (3) nutrients are not removed or
bunched, (4) microclimatic extremes are minimized, (5)
new undesirable plants find it difficult to become
established due to competition from preferred vegetation,
(6) dying plants gradually add their branches, leaves,
and bark to the forest floor, where they form a mulch
that enriches the soil and conserves moisture, (7) as
pest overstory plants gradually fade from the plant
community, increased amounts of sunlight and
precipitation, necessary for the vigorous development of
preferred vegetation, can reach the ground, and (8) the
source of new growth, the plants roots can be controlled.

Costs of herbicide use are generally lower than for other
alternatives. Costs, however, are not the overriding
consideration in prescribing herbicide applications in
selected areas. The environmental effects, social
impacts, and combined resource objectives all must be
considered reviewed, then, if herbicide use is still an
available option, it should be chosen over a higher cost
alternative which is more destructive.

In managing the National Forest's grazing resource,
herbicides can be used to reduce unpalatable plants and
noxious or poisonous plants from range and pasture lands,
without tilling the soil. Plowing to eliminate unwanted
plants destroys usable forage plants, increases erosion,
and takes the area out of production for up to 1 year,

25

while the new plants get established to where they can
stand the stress of livestock grazing. Herbicides are
also useful in range revegetation programs, for
controlling trees and brush that are competing with
wanted forage species for sunlight, moisture, heat, and
nutrients. Fences entwined with brush and vines are
easily freed and kept clean through the use of herbicides.

The use of herbicides for vegetation management along
roads and trails is often coordinated with mechanical
equipment use. Mechanical equipment alone is unsatis-
factory for some species of brush control, due to
excessive stump and root sprouting, rock outcroppings,
stones, and cut or fill slopes. Using herbicides to
control woody growth allows for maintenance of roadsides
where mowing equipment would disturb highly erodable
soils. Because herbicides reduce resprouting of stumps
and brush, the time between maintenance operations is
extended, freeing dollars for other much needed road
maintenance activities.

Herbicides can also be used at recreation areas to extend
the life of walkways and parking lots. They may be used
to control aquatic weeds, and to improve aesthetics.
Trails can be kept free of stump sprouts and tree
seedlings. At remote or limited access recreation Sites,
where mechanical or hand vegetation control methods are
impossible or extremely costly, herbicides become the
only effective vegetation control method. Herbicides may
be selected over other plant control methods at a
recreation site where a target weed or the encroachment
of vegetation must be eliminated with a minimum of
disturbance.

The use of herbicides has been controversial, especially
the aerial application of 2,4,5-T. Much of the concern
originated from publicity given to a chemical used in
Vietnam. Agent Orange contained an impurity -
tetrachlorodibenzo-p-dioxin, more commonly known as TCDD
or dioxin. The TCDD dioxin content now contained in
2,4,5-T has been reduced to a fraction of the level in
Agent Orange. TCDD has been found to be one of the most
toxic chemicals known to scientists, but when 225 tol Baglk
used according to label directions, it is not believed to
result in significant danger to the environemnt from
TCDD. Even when new monitoring programs, capable of
dioxin detection to 1 part per trillion, became
available, debates on the use of 2,4,5-T will continue,

The Eastern Region has used herbicides since 1950.
Experience has shown the herbicide alternative for
vegetation management to be effective, of reasonable
cost, and when used as directed, it does not constitute a
hazard to humans, animals or the general quality of the
environment. Herbicide use still remains as a preferred
method for most vegetation management programs.

26

Manual

Manual vegetation management methods include the use of
hand-operated tools such as the axe, brush whip, brush
axe, chain saw, and brush cutter. Manual methods are
used in timber, range, wildlife, recreation, fire, and
right-of-way maintenance programs.

Generally speaking, manual methods have little adverse
effect on the environment. This method can be selective
and accomplished with little visual impact in areas of
concentrated public use. Control of vegetation can be
exact, making this method suitable for use along streams,
in recreation areas, around buildings, and near wildlife
projects. The season of year has little effect, unless
it 1s winter cold or snow depth. Long term local
employment is possible.

The major disadvantages are high cost and ineffective
results. It is not unusual for an acre of land to
contain over 26,000 brush or hardwood stems (Jensen
1977). If stems were placed on a 2-foot by 2-foot
spacing, 10,890 stems could be fitted to an acre.

Forlish (1972) found 3-4 year old aspen clearcuts contain
12,700-13,700 aspen stems, plus other species like
cherry, red maple, birch, and hazel. In the Ozark and
Midlands areas, hardwood reproduction would be less;
about 3,500 stems per acre (Brinkman-Lining, 1961).

A research project in the southeastern Adirondacks showed
that felling cull trees, which range in size from 8 to 36
inches d.b.h., require an average of 2.88 minutes per
tree. To manually fell 50 trees, would cost $14.40 per
acre, if the hourly rate for the chain saw operator is $6.
This would still leave the smaller trees and brush to
remove. Assuming there are 5,000 brush stems per acre
and a man is able to remove 240 stems per hour at $3 per
hour, it would add another $62.50 per acre to the cost of
manual brush removal.

Manual labor projects can help a local economy; however,
finding people to work at physically demanding jobs is a
problem. Many National Forest areas have a limited labor
supply. Urbanites are often unwilling or unable to
commute to rural areas for work, especially, when the pay
is low, the work seasonal, and the working conditions are
physically demanding.

It would require a minimum of 10 people working a full
year to clear 1,000 acres of heavy brush with hand

tools. Only specially funded public employment programs
could support such a large program. Programs of this
nature are established by the President and Congress, not
the Forest Service. To relocate the unemployed, while

Z]

possible, has a high cost and low worker appeal. Labor
skills learned in cutting brush and hoeing weeds have
little application for preparing the unemployed to find
meaningful employment. Recent public employment programs
have focused on helping urban areas with high
unemployment levels.

The most discouraging aspect of manual vegetation control
is its ineffectiveness. Hand cutting brush, like mowing
a lawn, can result in only a temporary reduction in plant
growth. Stumps and roots will send up sprouts to soon
replace those cut. In one year's time most new sprouts
have replaced the growth removed by cutting.

Many woody species vegetation are prolific sprouters.
Along roadsides, under utility lines, in hay or pasture
fields, and in young conifer plantations, a need exists
for lasting vegetation control. Cutting the aerial
portions of pest plants does not reduce the number of
stems that resprout the following year; rather, in some
species, there are substantial increases. The height of
the new growth can exceed 3 to 4 feet in the first year
(Arend and Roe, 1961). To annually or biennially crop
these sprouts in a 30,000-40,000 acre program, amounts to
a major expenditure of tax dollars, or in the case of
utility rights-of-way, an increased cost to the consumer.

Experience has shown that heavy cutting of brush and cull
trees in an area creates a mat of interlocking tree
branches and stems, impassable to many forms of

wildlife. Manual control of grass and weed pests in hay
and range pastures and removal of duck weed or algae
blooms from water, is physically impractical, if not
impossible.

The accident rate for people involved in woods work is
high. The 1972-1974 severity rate, (days of lost work
due to injury per 1 million man-hours of work), for the
logging industry group was only exceeded by 16 of 207
industrial groups listed by the National Safety Council
in the 1975 Work Industry Rates. Daily exposure to sharp
cutting edges, rough terrain, climatic extremes, and
physically demanding work make accidents a major factor
in discouraging the use of manual labor crews.

Manual control methods, while a part of the Regional
vegetation management program, are limited by cost and
ineffectiveness.

Mechanical
This method involves the use of motorized equipment to
either push-pull, or drive other pieces of equipment

designed to treat vegetation. It involves bulldozing,
shearing, tractor scarification, discing, cultivating,

28

chaining, chopping and mowing. Mechanical vegetation
control is used in range, agriculture timber, and
rights-of-way construction and maintenance programs.

Mechanical methods have the advantage of being able to
alter the position or form of the vegetation. Dozer
operated equipment can knock down or dig up vegetation to
create openings, brushhogs and hydro-axes can grind up
vegetation, and discing or cultivating will bury
vegetation. Excellent site preparation can thus be
accomplished. If done properly, the mechanical control
of vegetation is suitable for use in visually sensitive
areas. Large areas can be treated with minimum manpower
needs and low cost. Mechanical equipment also allows the
clean up of unwanted or unutilized vegetation which has
accumulated, while leaving adequate root material to
provide for vigorous resprouting.

Limits on the use of mechanical equipment are caused by
rough and rocky terrain, erosive soils, steep slopes,
winter weather, and muddy soil conditions. Soil erosion
and its affect on water quality and soil compaction are
two environmental concerns associated with mechanical
vegetation management. Soil compaction is of concern
because it reduces soil productivity. Selectivity is not
usually possible with mechanical methods, and the cost of
treating small areas is excessively high. Mechanical
methods can seriously impact wildlife which require a
specific, localized ecological niche.

Unless plant roots of sprouting plants are completely dug
out of the ground, the effectiveness of mechanical
vegetation control is reduced. Mowing operations
followed by chemical treatment have proven worthwhile for
use on roadsides and other areas where aesthetics are of
major concern.

Increasing prices and reduced availability of fossil
fuels may not make large mechanical vegetation control
projects possible in the future.

Mechanical treatment of vegetation is the first step to
helping establish desirable vegetation, and future use
will emphasize this objective.

No Action or Postponing Action

The "no action" alternative should not be interpreted as
the halting of all current land management programs;
rather, it means no efforts will be made to control
vegetation once an activity has been started. In other
words, once the needed vegetative community was
established by the land manager, mature would be allowed
to take its course. No maintenance projects would be
undertaken, even if the vegetation became detrimental to

29

the program, i.e. trees growing into electrical wires;
old, brittle branches hanging over trails, etc. This
method is very different from other alternatives.
Short-range costs and environmental impacts are the least
under this alternative.

Without treatment, fish species management in small
reservoirs and ponds can change from high dissolved
oxygen-demanding fish, such as trout and pike, to bull
heads and other rough species which require less oxygen.
This would be caused by aquatic plant and algae buildup
and the extraction of oxygen during vegetation
decomposition. Aquatic vegetation provides cover which
may cause some small forage fish, such as bluegill, to
Survive in over-abundant populations, thus leading to
stunted growth. Another detrimental effect which comes
from not controlling weed and algae growth is the
physical obstacle such growth presents to fishing
enthusiasts. Swimming would also be affected by the low
water quality, and the activity would be limited to those
periods of low algae populations or before aquatic plants
mature.

Without human manipulation of vegetation, forest cover
diversity, in a protected forest, decreases. This
reduces wildlife diversity and populations. Species
requiring forest types found in early successional stages
become very scarce.

Failure to control roadside vegetation would decrease
sight distance on curves and at intersections, hide
traffic control structures and directional Signs, and
keep many gravel roads damp and muddy throughout the
summer because of shading.

Succession in the Eastern Region goes from grass
communities to woody vegetation. Without vegetative
manipulation, the acreage and condition of the range
resource would deteriorate, reducing the number of
animals that could be allowed to graze. A decrease in
range forage without a corresponding reduction in
domestic livestock would mean an increased demand for
expensive, supplemental feeds, such as corn and soybeans.

An acre of forest land is limited in the amount of
vegetation it can produce. However, with management ,
those plants which are beneficial to man can be
proportionately increased and their growth stepped up,
eliminating unwanted vegetation which is competing for
available nutrients, moisture, and space. This is the
practice followed in timber management through selective
control of vegetation. Without selective control, more
growth would go into brush and trees of low fiber yield,
Until new technology and methods for utilizing brush and

30

low yield trees are developed, the Nation is faced with
reducing the timber supply or harvesting increased
acreage each year to supply existing demands.

Failure to control noxious weeds could result in a
National Forest noxious weed source that may be
detrimental to local agriculture.

David Marquis (1976) found that heavy tree thinning in
New England increased crop tree basal area growth by 53
percent and diameter growth by 64 percent over that of
unthinned controls. Williams (1976), in an 18-year study
of yellow poplar seedlings which were completely released
by herbicides in 1957, found growth of completely
released trees were four times taller and five times
larger in diameter by 1973, than seedlings not released.

The need for release is shown by experiments conducted on
the Chippewa National Forest in Minnesota. Prepared
plots showed that after 5 years, failure to release red
pine resulted in a reduction of 70 percent in survival,
more than 90 percent in height growth, and 99 percent in
total dry weight.

In Lower Michigan, studies evaluated the effects of
various degrees of overtopping aspen and scrub oak on the
growth of planted red pine. Growth was measured 5 to 15
years later. The results showed that when a 30 square
foot basal area hardwood overstory (90-150 trees, 6-8
inches d.b.h. per acre) is retained, cubic foot volume
growth is reduced 20 percent of the maximum; the diameter
growth is limited to 55 percent maximum; and, the height
growth declines to 58 percent of the maximum.

It is recognized that unchecked tall growing vegetation
along power and telephone rights-of-way, is a hazard that
could cause shorting, arcing, or other undesirable
effects. These conditions interrupt electric services to
customers, and in some cases, unmanaged right-of-way
growth could inhibit surveillance, maintenance and repair
of lines.

DESCRIPTION OF HERBICIDES PROPOSED FOR USE

Herbicide use in the Eastern Region involves a variety of
chemicals which have been selected to treat a wide range of
plants at various times of the year. The complex
relationship between host and target vegetation, and the
method in which each can be reached by a herbicide, are
considered when selecting a chemical for use.

The Following descriptions were extracted from the Herbicide
Handbook of the Weed Science Society of America (1974

31

Edition) and Agricultural Chemicals - Book II (Herbicides) by
W.T. Thomson.

AMITROLE - (3-amino-s-triazole)

A.

B.

HERBICIDIAL USE

General:

a. Perennial broadleaf weeds and grasses in
non-cropped areas. *

b. Some aquatic weeds.

c. Most crops if contacted by spray are sensitive.

d. Used in mixtures with more persistent herbicides
for general weed control in non-cropped areas and
as a directed spray in ornamental nurseries.

Application methods: Foliage spray on weeds.

Rates: 20 to 10 1b/A.

Usual carrier: Water - 20 to 200 gpa; water-soluble.

PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Absorption characteristics: Absorbed slowly.
Translocation characteristics: Good translocation.

Mechanism of action: Inhibits chlorophyll formation
and regrowth from buds.

Metabolism and persistence in plants: Glycine and.
serine of plants are utilized in biosynthesis of
B-(3-amino-s-triazolyl-1-)a-alanine.

AMS - (ammonium sulfamate)

A.

HERBICIDIAL USE

ie

General: Effective in killing most woody plants,
including hardwood and coniferous species such as
alder, ash, birch, cedar, elm, gum, hickory, maple,
oak, pine, willow, and poison ivy. Also is an
effective contact spray for control of herbaceous
perennials such as leafy spurge, bitter dock,
goldenrod, perennial ragweed, milkweed, and blueweed,
as well as most annual broadleaf weeds and grasses.

Application methods: (a) As foliar spray; (b) as
crystals or concentrated solution to cut surfaces

(frills, notches, or cups cut in bark, or freshly cut
stumps).

Sy)

Rates: (a) As foliar spray for brush, using
hydraulic equipment, 60 1b aihg water, 50 lb aihg
oil-water emulsion (up to 400 1b aihg used in
air-blast equipment; (b) as contact spray for
herbaceous plants, 100 lb aihg; (c) for spray
application=torcut surfaces,’ 7 to 10 1b in°2 gal
water; or (d) sprinkle crystals directly on cut
surface.

Usual carrier: Applied in water solution or in
oil-water emulsion in sufficient volume for full
coverage of foliage, stems, limbs, and base of woody
plants. Applications to freshly-cut surfaces should
saturate cut area. Oil-water emulsion is prepared by
dissolving herbicide in one-fourth the required
amount of water, then adding a pre-mix of one quart
Du Pont Surfactant WK or equivalent in 4 gal of No. 2
fuel oil per 100 gal of finished spray, followed by
remainder of water.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Ls

Absorption characteristics: Rapidly absorbed through
foliage and green stems; use of spreader-stickers or
application in oil-water emulsion improves wetting.
Crystals or concentrated solutions applied to freshly
cut wood surfaces are readily absorbed.

Translocation characteristics: Translocation has
been demonstrated in woody plants and in herbaceous
plants.

ASULAM - (Methyl sulfanilylcarbamate)

A. HERBICIDIAL USE

3

4.

General: Effective for control of certain perennial
weeds such as johnsongrass, horsetail, rush, bracken
fern, and tansy ragwort in noncrop, range, and forest
management areas.

Application methods: Aerial and ground foliage spray.

Rates: 1 to 6 1b ai/A depending on weeds present.

Usual carrier: Water-5 to 40 gpa.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Le

Foliar absorption characteristics: It is readily
absorbed by foliage, with the rate increased by the
addition of a wetting agent.

53

2. Translocation characteristics: It may be taken up by
either roots or leaves and translocated to other
parts of the plant. In certain grasses, there is
evidence that asulam is translocated from the leaves
into the root system resulting in the death of
several of the dormant buds on the rhizomes.

3. Mechanism of action: The site of action appears to
be the meristematic regions of the plant, and the
activity appears to be due to interference with the
process of cell division and expansion.

ATRAZINE - (2-chloro-4-(ethylamino)-6-(isopropylamino)-s-triazine)
A. HERBICIDIAL USE

1. General: Atrazine is a widely used selective
herbicide for control of broadleaf and grass weeds.
It is used also in some areas for selective weed
control in conifer reforestation, Christmas tree
plantations and grass seed fields, as well as for
non-selective control of vegetation in chemical
fallow. Atrazine also is used widely as a
non-selective herbicide for vegetation control in
non-crop land. Combination granules of atrazine plus
propachlor, atrazine plus alachlor and atrazine +
Sutan are presently marketed for weed control in
corn. In addition the granular combination of
AAtrex plus sodium chlorate and sodium metaborate is
currently marketed for non-selective vegetation
control. Sugarbeets, tobacco, oats, and many
vegetable crops are very sensitive to atrazine.

2. Application methods: Depending upon the crop or
intended use atrazine sprays may be applied preplant,
preemergence, or post-emergence, but before weed
seedlings are more than 1-1/2 inches high with few
exceptions. These exceptions include postemergent
application for yellow nutsedge and Canada thistle
control. Preemergence use is generally the perferred
method of application where it can be used. Under
dry conditions, a shallow incorportion may increase
the degree of weed control. A single lay-by
cultivation is sometimes useful to prevent relatively
tolerant late season grasses from developing. Aerial
applications have been very successful, especially
when wet weather prevents the use of ground equipment
and in cases where rough terrain such as in conifer
reforestation makes ground applications impractical.
A liquified formulation containing 4 1b ai/gal has
been developed and is currently registered for weed
control in corn and sorghum. Postemergent application

34

of either the wettable powder or liquified formulation
of atrazine are usually made in combination with a
nonphytotoxic crop oil, crop oil concentrate or
surfactact. These additions enhance the uptake of
atrazine and hence its activity.

3. Rates: Rates the equivalent of 2 to 4 1b/A are
required for selective weed control for most
Situations. Higher rates are used for nonselective
weed control. Lower rates will effectively control
cheatgrass and most other weeds in chemical fallow or
rangeland uses, and many common annual broadleaf weed
species.

4. Usual carrier: Water at 10 gpa or more is the usual
carrier for uniform ground application. Nitrogen
solution and other liquid fertilizers have been
widely and successfully used as carriers. The major
advantage is applying both herbicide and fertilizer
in one operation. Agitation in the spray tank is
necessary to keep the chemical in suspension.
Recently it has been recommended that aerial
application of atrazine be applied in a minimum of 2
gallons of water per acre. The typical volume of oil
applied by ground means is one gpa. This volume is
reduced to 1/2 gpa for aerial application.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

1. Foliar absorption characteristics: Absorbed through
both roots and foliage, although foliar absorption
often is small in most plants under field conditions,
depending on factors as species and environmental
conditions. The herbicide can be washed off plant
foliage by rain.

2. Translocation characteristics: Following absorption
through roots and foliage, it is translocated
acropetally in the xylem and accumulates in the
apical meristems and leaves of plants.

3. Mechanism of action: A photosynthetic inhibitor, but
may have additional effects.

4, Metabolism and persistence in plants: Atrazine is
readily metabolized by tolerant plants to
hydroxy-atrazine and amino acid conjugates. The
hydroxy-atrazine can be further degraded by
dealkylation of the side chains and by hydrolysis of
resulting amino groups on the ring and some co.
production. These alterations of atrazine are major
protective mechanisms in most tolerant crop and weed
species. Soil placement selectivity is also
important in the care of some deep rooted perennial
crops. Unaltered atrazine accumulates in sensitive
plants, causing chlorosis and death.

55

Biological properties other than herbicidial:
Limited studies have shown some minor fungicidal and
nematocidal activity but no insecticidal activity.

BENEFIN - N-butyl-N-ethyl-a,a,a-trifluoro-2,6-dinitro-p-toluidine

A. HERBICIDAL USE

A

General: Controls grasses and several broadleaf
weeds such as carpetweed, chickweed, knotweed,
lambsquarters, pigweed, purslane, redmaids, and
Florida pusley. Tolerant crops include lettuce,
peanut, alfalfa, clover, birdsfoot trefoil,
transplant burley and dark tobacco, and established
turfgrasses. Sensitive crops include beets, sorghum,
oats, ad spinach.

Application method: Benefin is a preemergence
herbicide and must be soil incorporated within eight
hours after application with equipment that breaks up
large clods and mixes the soil thoroughly; e.g.,
PTO-driven cultivators, hoes, tillers; double disc;
rolling cultivator; bed conditioner. Application and
incorporation can be preplanting or postplanting.

Rates<<. bol? toeleoes DLA

Usual carrier: Water at 5 to 40 gpa is the carrier
for the 1.5 1lb/gal liquid concentrate. A 2.5 percent
granule is also available for use on peanut and
burley tobacco.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

ie

Foliar absorption characteristics: Benefin is a soil
incorporated, preemergence herbicide and is not
normally applied to plant foliage.

Translocation characteristics: There is no
Significant absorption or translocation of benefin in
crops grown in soil treated with benefin.

Mechanism of action: Benefin affects seed
germination and associated physiological growth
processes.

Metabolism and persistence in plants: No significant

terminal residues or specific metabolites of benefin
have been detected in mature plants.

36

BENSULIDE - 0,0-diisopropyl phosphorodithioate S-ester with

N-(2-mercaptoethyl )benzenesulfonamide

A. HERBICIDAL USE

General: Betasan is registered for control of
crabgrass, annual bluegrass, redroot, pigweed,
watergrass, lambsquarters, shepherdspurse,
goosegrass, and deadnettle in grass and dichondra
lawns. Prefar is registered for controlling various
grass and broadleaf weeds in cotton, lettuce,
cucumbers, canaloupes, squash (summer & winter),
Crenshaw and Persian melons, muskmelons, watermelons,
tomatoes, peppers, broccoli, cabbage, and cauliflower.

Application method: Besatan should be used prior to
germination of weed seeds. It should be applied to
established grass lawns, prior to planting, at the
time of planting, or on established dichondra lawns.
The compound must be watered into the soil after
application. Bensulide provides long residual
control of the weeds for which it is registered.
Care should be exercised if reseeding with grass is
planned following treatment.

Rates: Rates of application are from 10 to 20 1b/A
for Betasan and 2 to 6 1b/A for Prefar.

4. Usual carrier: Water at the rate of 15 to 30 gal per
3000 to 3600 sq ft is the usual carrier for emulsifiable
liquid formulations of Betasan. Prefar is applied in 20
to 50 gallons of water per acre.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

i

Translocation characteristics: It is absorbed on the
root surfaces, and a small amount is absorbed by the
roots, but very little or none is translocated upward
to the leaves.

Mechanism of action: It inhibits the growth of roots
of weeds, but the mechanism of action is not known.

Metabolism and persistence in plants: Unchanged
ring-labelled Prefar-!4¢ could be detected in the
roots of lettuce plants after root application, but
none could be detected in the leaves. A large part
of the radioactive material in the leaves was evolved
as radioactive co, and some was present as labelled
amino acids.

si

BROMACIL - 5-bromo-3-sec-but yl-6-methyluracil

(5-bromo-6-methy1-3-(1-methylpropyl) uracil)

A. HERBICIDIAL USE

General type of plants controlled: Used on
non-croplandareas for control of a wide range of
annual and perennial grasses and broadleaf weeds,
and certain woody species. Combinations with diuron
(Krovar® ) used noncropland areas.

Application methods: Bromacil is sprayed or spread
dry(as granules, etc.) on soil surface, preferably
just before or during period of active growth of
weeds.

Rates: 1.5 to 5 1b/A - general weed control (where
bare ground is desired for an extended
period)-controls most annuals. 5 to 10 1b/A -
controls many perennial weeds, grasses and woody
species. 12 to 24 1b/A - controls hard-to-kill
perennials such as johnsongrass, bermudagrass,
dallisgrass, vaseygrass, nutsedge, saltgrass,
bouncingbet, dogbane, bracken fern, and horsetail.

Higher levels of dosage ranges are used on adsorptive
soils (usually those high in organic matter or
carbon). For basal treatment of brush mix 2 1b of
bromacil in 5 gal of water and apply 1 to 2 fl oz per
stem 2 to 4 inches in basal diameter; wet base of
stem to run-off.

Usual carrier: Water in sufficient volume to
uniformly cover area to be treated. Wettable powder
form requires continuous agitation to maintain
Suspension; water-soluble form requires agitation
only until dissolved. Bromacil also can be applied
in oil solutions or suspensions, or in dry, granular
formulations.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

1.

Foliar absorption characteristics: Bromacil is
mostly readily absorbed through root system; less so
through foliage and stems. Addition of a suitable
surfactant to the spray enhances foliar activity.

Translocation characteristics: Orange plants
maintained for 4 weeks,in sand on a nutrient solution
containing 10 ppm of " “C-2-bromacil took up less

than 54 of the applied activity. Approximately 85%
of this activity was found in the roots and 17% in
the stem and leaves of the plant.

38

3. Mechanism of action: Bromacil has been shown to be a
potent and specific inhibitor of photosynthesis.

BROMOXYNIL - 3,5-dibromo-4-hydroxybenzonitrile

(4-cyano-2,6-dibromophenol )

A. HERBICIDAL USE

a5

4.

General: Registered for use on wheat, barley, oats
rye, flax, and newly seeded turf to control certain
broadleaf weeds. Also, registered for the control of
certain weeds such as Russian thistle on industrial
sites, vacant lots, roadsites, and railroad
rights-of-way. Promising for sorghum and fall-seeded
legumes.

Application methods: Ground and aerial foliage spray
in water - postemergence.

Rates a 02> “tos lb aa/A¥

Usual carrier: Water - 2 to 20 gpa.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

1. Foliar absorption characteristics: The oil soluble
amine and ester have the capacity to resist removal
from foliage by rain, the sodium salt does not since
it is water soluble.

ZY. Translocation characteristics: Relatively little
movement once absorbed.

3. Mechanism of action: Photosynthetic and respiratory
inhibitor.

4. Metabolism and persistence in plants: May be
hydrolyzed to benzoic acid.

5. Biological properties other than herbicidal:
Molluscicide.

CACODYLIC ACID - hydroxydimethylarsine oxide

A. HERBICIDAL USE

General: Cacodylic acid is a contact herbicide which
will defoliate or desiccate a wide variety of plant
species. The phytotoxic properties of this herbicide
are quickly inactiviated on contact with the soil.
Current experimental uses include: weed control in
crops and in nut, fruit, and citrus orchards, and
weed control in new seedling areas. Commercial uses

st)

include: cotton defoliation, lawn renovation,
general weed control in noncrop areas such as around
buildings, near perennial ornamentals, along fence
rows, and spot control of noxious weeds and forest
management practices.

Application methods: Used as a directed spray,
postemergence.

Rates: Three to 10 1b/A.
Usual carrier: Mix with water plus 2 qt surfactant

per 100 gal of solution and apply at 40 gpa. All
formulations are 100% water soluble.

CHLORAMBEN - 3-amino-2,5-dichlorobenzoic acid

A. HERBICIDAL USE

Le

General:

a. Preemergence control of seedling grass and
broadleaf weeds.

b. Preemergence use on soybeans, drybeans, lima
beans, seedling asparagus, pumpkin, squash, corn;
post-transplanting on tomatoes, peppers, sweet
potatoes, and various ornamentals.

Application methods: Ground spray or granular
application. Shallow incorporation recommended under
some conditions.

Rates*=.27£0.4 s1b/Ay

Usual carrier: Water, attaclay, or concentrate
through Economizer.

B. PHYSIOLOGICAL AND BIOCHEMCIAL BEHAVIOR

Le

224)

Absorption characteristics: Some foliar absorption,
resulting in epinasty.

Mechanism of action: Inhibits root development of
seedling weeds.

(2,4-dichlorophenoxy) acetic acid

A. HERBICIDAL USE

L.

General: 2,4-D is a systemic herbicide and is widely
used.for control of broadleaf weeds in cereal crops,
sugarcane, turf, pastures, and noncrop land. Most
dicot crops are susceptible at normal herbicidal
rates. The salt and long chain ester formulations

40

are of sufficiently low volatility that, with care,
they may be used near fairly susceptible crops, if
spray drift is prevented. High volatile ester
formulations should not be used in or near
susceptible crop areas. Salt formulations are
safest; they do not release enough vapors to cause
damage off the treated areas.

Application methods: Spray application is usually
postemergence, applied by aerial or ground equipment.

Rates: For crops and pastures, 0.25 to 2 lb/A
postemergence for most weeds. For brush control,
rates of 3 to 4 1b/100 gallons of spray are often
used.

Usual carrier: Water, diesel oil, or both,
dependingupon formulation used. Low volumes (e.g., 3
to 10 gpa) are generally used for aerial application,
and higher volumes (up to 400 gpa) are used for
ground application. Surfactants have enhanced
activity in some cases. Agitation is needed for some
formulations.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

ie

Foliar absorption characteristics: Plant roots
absorb polar (salt) forms of 2,4-D most readily.
Leaves absorb nonpolar (ester) forms most readily.
A rain-free period of 4 to 6 hr usually is adequate
for uptake and effective weed control. The esters
of 2,4-D tend to resist washing from plants and are
rapidly converted to the acid by the plants.

Translocation characteristics: Following foliar
absorption, 2,4-D translocates within the phloem,
probably moving with food material. Following root
absorption, it may move upward in the transpiration
stream. Translocation is influenced by the growth
status of the plant. Accumulation of the herbicide
occurs principally at the meristematic regions of
shoots and roots.

Mechanism of action: The mechanism of action of
2,4-D has been studied more than for any other
herbicide. Investigation has shown that it causes
abnormal growth response and affects respiration,
food reserves, and cell division; but the primary
mode of action has not been clearly established.

Metabolism and persistence in plants: Studies have
shown complexes with protein or amino acids,
oxidation of the acetate moiety and of the ring,
hydrolysis to the free phenol, and combination with
glycosides.

Al

5. Biological properties other than herbicidal: It can
act as a plant growth regulator and low rates can
induce rooting and blossom set. Also, it controls
the ripening of bananas and citrus fruits and delays
preharvest dropping of some fruits. Apparently,
2,4-D has little or no biological activity on
insects, nematodes, or plant pathogens.

DALAPON - 2,2-dichloropropionic acid
A. HERBICIDAL USE

1. General: For the contol of annual and perennial
grasses, dalapon is used in sugarcane, sugarbeets,
corn, potatoes, asparagus, grapes, flax, new legume
spring seedlings, citrus, and deciduous fru,
coffee, certain stone fruits, and nut trees.

2. Application methods: Can be applied with conventional
aerial or ground equipment as a foliage application.
Apply prior to crop emergence or postemergence.
Addition of wetting agent is usually helpful.

3. Rates: Rates range from 0.75 1b/A in flax to 20 1b/A
or more on noncropland. Multiple treatments at lower
rates are also used under certain conditions.

4. Usual carrier: Dalapon is used with a water carrier
at volumes of 5 to 300 gpa, depending on crop
situation, grass species, and method of application
and equipment available.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

1. Foliar absorption characteristics: Absorbed by both
roots and leaves. Easily washed off foliage.

2. Translocation characteristics: Translocates readily
throughout the plant. Accumulates in young tissue.

3. Metabolism and persistence in plants: Is not
degraded in plants.

DCPA - dimethyl tetrachloroterephthalate

A. HERBICIDAL USE

1. General: Annual grasses and certain annual broadleaf
species throughout the USA.

2. Application methods: Generally at planting time,
preemergent to the weeds; applied with conventional
sprayer.

42

Rates: Four to 10 1b/A, depending on soil type and
weed population.

Usual carrier: Apply in spray rigs delivering 25 to
40 gal of water per acre.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Le

Foliar absorption characteristics: Not absorbed by
foliage.

Translocation characteristics: Not translocated in
the plant.

Mechanism of action: Kills germinating seeds; exact
mechanism not yet known.

Metabolism and persistence in plants: Not considered
to be metabolized by plants.

DICAMBA - 3,6-dichloro-o-anisic acid

A. HERBICIDAL USE

ie

General: Preemergence applications control both
annual broadleaf and grass weeds. Foliar and soil
applications control phenoxy-tolerant annual and
perennial broadleaf weeds and brush species.
Registered uses in small grains, corn, flax,
perennial seed grasses, turf, and non-crop lands.
Useful also in sorghum, grass pasture, rape, tame
mustard, sugarcane, cole crops, and certain orchard
crops. Numerous growth regulatory uses in early
stage of development. Soybeans, other beans, and
most small-seeded legumes are sensitive. Spray drift
to these and other ornamentals and vegetable crops
should be prevented.

Application methods: May be applied by either ground
or aerial spray or as granules, by basal application,
and preemergence and postemergence, depending on
specific use.

Rates: Preemergence - 0.5 to 3 1b/A.
Foliar spray on broadleaf annuals - 0.06 to 0.25
lb/A.
Foliar spray on broadleaf perennials and brush
species — 0.5 to 10 1b/A.

Usual carrier: Water, applied at from 2 to 40 gpa.
No additional surfactant nor agitation necessary.
Attapulgite, vermiculite, and liquid and dry
fertilizers also have been used as carriers.

43

DICHLOBENIL - 2,6-dichlorobenzonitrile

A. HERBICIDAL USE

1. General: Dichlobenil is a powerful inhibitor of
germination and of actively dividing meristems and
acts primarily on growing points and root tips.
These properties lead to the following herbicidal
characteristics:

a.

Both monocotyledons and dicotyledons are controlled,
especially by inhibition of germinating seeds and
growth of young seedling plants.

Older plants, especially when shallow-rooted, are
controlled under favorable conditions and/or high
dosages. This applies especially to some annual
grass weeds.

The growth of emerging sprouts of perennial weeds is
stopped.

Crop plants for which the compound can be useful: In
general, established crops tolerate treatment very
well. In such cases the roots do not come into
contact with the dichlobenil that is located in the
upper layers of the soil. On the following crops the
product is in practical use: alfalfa, aquatic weed
control, citrus, vineyards, top-, soft-, cane- and
stone-fruits, fruit tree and tree nurseries,
ornamental plants and trees, nursery stock,
shelterbelt trees, cranberries, avocados, mangos,
transplanted rice, winter wheat, total weed control
and home gardening.

Application method: Application between sowing and
emergence of crop usually gives rise to prohibitive
phytotoxicity, especially with small-seeded crops.
With a number of relatively large-seeded crops (e.g.,
corn, cotton, wheat), when planted rather deeply,
there is marginal selectivity.

Over established crops dichlobenil can be applied,
either as a dispersible or wettable powder or as
granules, as a ground or aerial application. The
product must always be applied to the soil. For
total weed control and for weed control under trees,
dichlobenil should be applied to the soil. Under
circumstances of high water evaporation from the soil
(high temperature, wet soil, low relative air
humidity) dichlobenil can evaporate very rapidly.
From dry soil the evaporation of dichlobenil is

44

dependent on soil types and temperature. To enhance
the herbicidal effect under natural conditions the
best time for application is on dry soil just before
rainfall. An increase in herbicidal effectiveness
can also be obtained by incorporation (mechanically
or by irrigation), preferably after application on
dry soil. The herbicide should be used postemergence
or postplanting to the crop.

Rates:

Aquattcewecuscontrol:. 4,5 to 17 ke/ha (4 to 15 1b
ai/A) dependent upon depth
of water body.

Total weed control: PecCOs2 27 eKerats Nar 6.5) tOe20
lb ai/A) dependent upon
weeds present.

Bearing and nonbearing
fruit trees and bushes: 4 to 8 kg ai/ha (3.5 to 7 lb
ai/A).

Ornamental trees and shrubs: 2eieCO.oe Ke uaisha (2.5
COpomlLogal/ Ad.

Under asphalt: DieLoei3 ke av;namc10 to. }2 1b ai/A).

Usual carrier: The dispersible powder is suspended
in water. Granular formulations are usually
preferred because of excessive loss by volatilization
from the dispersible powder formulations under
certain conditions.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR IN PLANTS

1.

Foliar absorption characteristics: Dichlobenil is
absorbed from the soil by the root system; depending
on soil type and plant species, the herbicide can
accumulate in the roots up to three-fold. From the
vapor phase rapid uptake through the leaves takes
place.

Translocation characteristics: Recent studies have
shown that translocation from the roots into the
aerial parts is fast. In the leaves two competitive
processes take place: a part of dichlobenil
evaporates whereas another part of the herbicide is
hydroxylated. The ratio between these two processes
is dependent on the plant species. After take of
dichlobenil through the leaves the downward
translocation is rather slow.

45

3. Mechanism of action: Dichlobenil acts primarily on
growing points and root tips. Definite
characteritics at the toxic level in intact plants
include a rapid growth inhibition, followed by gross
disruption of tissues, notably in the meristems and
phloem, which may result in the swelling or collapse
of stem, root, and petiole, and a generalized brown
discoloration, frequently accompanied by the
exudation of gummy material from shoots. Leaves may
absciss and exhibit black discoloration over veins
and a deepened blue-green color intensity
interveinally.

4. Metabolism and persistence in plants: Plants grown
in soil treated with dichlobenil are exposed also to
2,6-dichlorobenzamide (BAM) and due to the transport
of BAM with the transpiration stream, this compound
and possibly its hydroxy metabolites may be present
in leaves.

DICHLORPROP - 2-(2,4-dichlorophenoxy)propionic acid
A. HERBICIDAL USE
1. General: Brush control in nonagricultural land.

DINOSEB - 2-sec-butyl-4,6-dinitrophenol
(2-(1-methylpropyl)-4,6-dinitrophenol)

A. HERBICIDAL USE

1. General: Controls seedling weeds and grasses in
crops. Does not control established perennial weeds
and grasses except with repeat treatments. Can be
used in fruit and nut orchards, grape vineyards,
mint, small grains, soybeans, peanuts, beans,
potatoes, corn, peas, pumpkins, squash, strawberries,
and certain forage crops.

2. Application methods: Applied as an overall or band
type application with conventional farm spray
equipment.

3. Rates: Rates of application range from 0.75 to 12
1b/A, depending upon crop, weed species, and time of

application.

4. Usual carrier: Water. (Oil-water emulsion or oil
solution for General type.)

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR
1. Foliar absorption characteristics: Principally

direct contact effect. Salts readily washed from
foliage; oil solution more resistant.

46

Translocation characteristics: Essentially no true
translocation. No residues have been traced to
foliar or root uptake.

Mechanism of action: Direct cell necrosis.

Biological properties other than herbicidal: Has
fungicidal and insecticidal properties.

DIQUAT - 6,7-dihydrodipyrido[],2-a:2',1'-c] pyrazinediium ion

(9 ,10-dihydro-8a, 10a-diazoniaphenanthrene-2A)

A. HERBICIDAL USE

La

General: Diquat is registered as a noncrop weed
killer, a general aquatic herbicide and as a
preharvest top killer or desiccant of seed crops.
Soil type or general climatic types do not directly
influence diquat usage.

Application methods: Aquatic weed control -
submerged weeds: Water treatments may be applied by
injecting diquat below the water surface, or by
pouring it directly from the container into the water
while moving slowly over the water surface in a

boat. Distribute evenly over infested areas.
Floating weeds: Apply by thoroughly wetting foliage.

Non-crop weed control - apply for full coverage and
thorough weed contact to point of run-off. The
younger the weeds, the better will be the control
obtained.

Rates: Aquatic weed control: 2 to 4 lb/surface A.
Noncrop weed control: 0.5 l1b/A.

Usual carrier: Water: 15 to 30 gpa for ground
spraying; 5 to 10 gpa for aerial spraying. No
agitation required. Addition of X-77 or other
nonionic or cationic surfactant: Dilute spray - 1/2
pt/100 gal. Concentrate spray - 2 oz/10 gal.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Foliar absorption characteristics: Very rapidly
absorbed by foliage. Very resistant to removal by
TaLpy

Translocation characteristics: Local systemic action
has been noted. Translocation via xylem can occur
under certain conditions.

47

Mechanism of action: Both the herbicidal activity
and organic chemical reactions of diquat formulations
are dependent solely upon the diquat cation, and are
not influenced by the nature of the associated anion,
since the salts are largely dissociated in aqueous
solution. A unique reaction of the diquat cation is
its facile one-electron reduction to a stable free
radical in aqueous solution. It is believed that
this free radical is formed in treated plants and is
responsible for the herbicidal activity, being
readily re-oxidized by atmospheric oxygen to
regenerate diquat and at the same time liberate
short-lived but very active radicals such as peroxide
radical within the plant cells.

Metabolism and persistence in plants: Metabolic
breakdown does not occur in plants. It is degraded
photochemically on plant surfaces.

Biological properties other than herbicidal:
Diquatis not useful as a fungicide, nematocide, or
insecticide.

DIURON - 3-(3,4-dichloropheny1)-1,1-dimethylurea

A. HERBICIDAL USE

1

General: Low rates selectively control germinating
broadleaf and grass weeds in crops such as cotton,
sugarcane, pineapple, grapes, apples, pears, citrus,
and alfalfa. At higher rates, diuron is a general
weed killer.

Application methods: For selective weed control,
diuron is sprayed on soil as a preemergence and/or as
a directed postemergence treatement; emerged weeds
(up to 2 inches high) are controlled in certain crops
when applied with a suitable surfactant added to
spray suspension, otherwise any well-established
weeds should first be removed by mechanical or other
means. For general weed control, diuron is sprayed
or spread dry (as granules) at any time except when
ground is frozen, but best results are obtained if
applied shortly before weed growth begins; dense
growth should be removed before application.
Increased contact activity on established weeds may
be obtained when applied with a suitable surfactant
added to spray suspension.

Rates: Selective in crops - 0.6 to 6.4 lb/A,
depending on crop and soil type. General weed
control (where bare ground is desired for an
extended period) - 4 to 16 1lb/A controls most

48

annuals; 16 to 48 1b/A controls most annuals and
perennials. Higher rates and repeat treatment may be
required where a longer period of control is desired
or when hard-to-kill deep-rooted perennial weeds are
present.

Usual carrier: Water in sufficient volume to
uniformly cover area to be treated. Continuous
agitation is required to maintain suspension. Also
can be applied for general weed control in oil
suspensions, or in dry, granular formulations.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

ic

Foliar absorption characteristics: Diuron is most
readily absorbed through the root system; less so
through foliage and stems.

Translocation characteristics: Translocation is
primarily upward in the xylem. (Also see monuron.)

Mechanism of action: Diuron is a strong inhibitor of
the Hill reaction.

ENDOTHALL - 7-oxabicyclo[2,2,1] heptane-2 ,3-dicarboxylic acid

(3 ,6-endoxohexahydrophthalic acid)

A. HERBICIDAL USE

Le

General: Various formulations are useful as a
preemergence and postemergence herbicide, turf
herbicide, aquatic herbicide, and harvest aid.
The compound is selectively toxic to plants.

Rates: Apply at dosages on crops or weeds as
recommended on container label.

Usual carrier: Water, in the case of liquid
formulations.

ERBON - 2-(2,4,5-trichlorophenoxy)ethyl 2,2-dichloropropionate

A. HERBICIDAL USE

General: A nonselective herbicide for general
vegetation control in noncrop areas.

Application methods: Applied with conventional spray
equipment either as a water spray (emulsion) or mixed
with oil. Apply as a thorough, drenching spray to
all exposed vegetation and oil.

Rates: For the control of established grasses and
broadleaf weeds use 120 to 160 1b/A. Use higher
dosages in areas of high rainfall. For spot
treatment, use 10 to 20 1b/10 gal water and apply to
wet all vegetation and exposed bare ground.

49

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Absorption characteristics: Erbon is absorbed by
both foliage and roots. As it is persistent in the
soil, its major effect on perennial broadleaved weeds
results from root uptake.

Translocation characteristics: Following absorption,
the compound is effectively translocated to growing
points.

GLYPHOSATE - N-(phosphonomethyl)glycine

A. HERBICIDAL USE

hs

General: Roundup is a very broad spectrum herbicide,
is relatively nonselective, and is very effective on
deep-rooted perennial species and on annual and
biennial species of grasses, sedges, and broadleaved
weeds. Selectivity may be achieved by directional
application.

Application methods: Apply as postemergence spray to
foliage of vegetation to be controlled. Use diluent
volumes of 20 to 30 gpa for normal use. Higher
volumes may be necessary for heavy, tall, and dense
foliage to assure adequate spray coverage of
understory vegetation. Use low pressures of 30 to

40 psi and suitable nozzles to avoid small droplets
which could lead to spray drift and to injury of
nearby susceptible plants.

Rates: Rates of use vary with species to be
controlled. Normally from 0.3 to 1.0 1b/A a.e. will
control annual species. Perennials will require
rates from 1.0 to 4.0 lbs/A a.e. with the majority of
perennials requiring 1.5 to 2.0 1b/A a.e.

Usual carrier: Water at 10 to 30 gpa or higher
volumes if extremely dense foliage. Does not need
agitation during application.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Le

Foliar absorption characteristics: Absorbed through
foliage and other photosynthetically active portions
of plant. Visual effect on foliage may not occur for
2 to 4 days for annual species and 10 days or more
for perennial species. May be washed off plant
foliage by rain, if rain occurs within 6 hours of
application.

50

2. Translocation characteristics: Facile translocation
throughout aerial and underground portions of the
contacted plant following absorption through
foliage. The underground plant parts of perennial
species are affected, resulting in failure of
regrowth from these propagation sites and subsequent
destruction of plant tissue. Root uptake from soil
is one or two orders of magnitude lower than for
other types of herbicides.

3. Mechanism of action: Not known at this time, but the
herbicide appears to inhibit the aromatic amino acid
biosynthetic pathway and may inhibit or repress
chlorismate mutase and/or prephenate dehydratase.

4. Metabolism and persistence in plants: Studies with
C labeled glyphosate show that plants can
metabolize glyphosate to give cO., and natural
organic products.

KRENITE - Ammonium Ethyl Carbamoylphosphonate

TYPE: Krenite is a carbamate compound used as a
post-emergence growth regulator - herbicide.

TOXICITY: LD,, - 24,000 mg./kg.

FORMULATIONS: 4 EC
USES: Used to control bud growth in most woody species.

RATES: Applied at 2-6 lbs. actual/100 gallons of water and
use 150-300 gallons of spray solution/acre. Use the higher
rates on large plants, dense growth or hard to control
Species.

APPLICATION: Apply within 2 months of leaf senescense
(coloration) in the fall. For suppression with minimum bud
effect, make an application during leaf expansion in the
spring.

PRECAUTIONS: Do not use on food or feed crops. Avoid drift
to desirable tree species. It has failed to produce bud
break where off-season temperatures are not low enough to
cause prolonged dormancy.

ADDITIONAL INFORMATION: Safe to fish and wildlife. This
compound either prevents spring bud break or provides growth
suppression. Plants treated in the summer or fall will not
show any symptoms until the folloing spring when they will
not leaf out. Spring application causes growth retardation

aye

with abnormal leaf growth. Not effective when applied to the
soil. May be applied with a surfactant. Phytotoxic symptoms
occur when applied to new growth in the spring but do not
occur when applied in the summer or fall.

LINURON - 3-(3,4-dichlorophenyl)-1-methoxy-1-methylurea
(N'-(3,4-dichoropheny1)-N-methoxy-N-methy1lurea)

A. HERBICIDAL USE

1. General: lLinuron selectively controls*germinating
and newly established broadleaf weeds and grasses in
crops such as soybeans, cotton, corn, sorghum,
potatoes, carrots and parsnips. It is also used for
short-term control of annual weeds in noncropland
areas.

2. Application methods: Linuron is sprayed on soil as a
preemergence or postemergence treatment. With a
suitable surfactant as a directed spray in certain
crops, it controls weeds up to 5 inches high; without
surfactant as a non-directed postemergence spray in
carrots, it controls emerged grasses up to 2 inches
and broadleaf weeds up to 6 inches high.

3. Rates: Selective in crops - 0.5 to 3 1b/A, depending
on crop and soil type.
Noncropland areas - 1 to 3 1b/A in 40 to 100 gpa
water.
Add surfactant for control of established annual
weeds.
Usual rate for surfactant is 0.5% by volume.

4, Usual carrier: Water in sufficient volume to
uniformly cover area to be treated. Continuous
agitation is required to maintain suspension.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

1. Absorption characteristics: Linuron is most readily
absorbed through the root system; less so through
foliage and stems. However, foliar absorption of
liuron is significantly greater than that of diuron,
monuron, or fenuron.

2. Translocation characteristics: Translocation is
primarily upward in the xylem (see monuron).

3. Mechanism of action: Linuron is a strong inhibitor
of the Hill reaction. (Also see monuron.)

52

MAA - Methanearsonic acid

A. HERBICIDAL USE

1%

General: One of the first major uses was as a
selective herbicide for the postemergence control of
crabgrass, dallisgrass, and other weedy grasses in
turf. Currently it is used extensively as a
selective postemergent herbicide in cotton and
noncrop areas for the control of johnsongrass,
nutsedge, watergrass, sandbur, foxtail, cocklebur,
pigweed, and other weeds. It is widely used also for
controlling weeds and grasses in noncrop areas. Also
mixed with 2,4-D/2,4,5-T brushkillers on noncropped
areas to increase conifer and other brush species
kill or dieback.

Application methods: In noncrop vegetation spray
foliage to obtain good coverage.

Rates: For lawn and ornamental use, 2.0 to 3.8 1b/A.

Usual carrier: Mix the recommended per-acre rates
with water and apply in a sufficient volume of spray
solution to obtain good coverage of the vegetation.
From 1 to 2 qt of a compatible surfactant per 100 gal
of spray solution will usually improve vegetation
control For cotton, 40 gpa spray volume on a
broadcast basis is usually sufficient. In noncrop
areas apply whatever spray volume is needed to obtain
coverage. All formulations are 100% water soluble.

B. PHYSICAL AND BIOCHEMICAL BEHAVIOR

ES:

Biological properties other than herbicidal: Some
fungicidal action.

MCPA - [(4-chloro-o-toly1)oxyJ acetic acid

(2-methy1-4-chlorophenoxyacetic acid)

A. HERBICIDAL USE

Ls

General: Selective foliage broadleaf killer, similar
to 2,4-D. More selective than 2,4-D at equal rates
on cereals, legumes, and flax.

Application methods: Aerial and ground application;
low-volume spray.

Rates: Used at rates from 0.12 to 1 lb ai/A.

Usual carrier: Water 2 to 30 gpa.

53

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIORS

1. Foliar absorption characteristics: Similar to
2,4-D. Absorbed through leaves or roots. Washed
off by rain if it follows soon after application.
Absorption increased by wetting agents.

2. Translocation characteristics: Readily translocated
in plant; movement with food material.” Concentration
of herbicide where foods actively utilized
(meristematic regions of growing plants).

3. Mechanism of action: Hormone type action. Low
volatile esters more effective on hard-to-control
weeds than salts of MCPA.

4. Metabolism and persistence in plants: Inactivation
follows many pathways. Complexing by proteins
probable. Decarboxylation in many instances.

MECOPROP - 2-[(4-chloro-o-toly1)oxy] propionic acid
(2-(2-methy1-4-chlorophenoxy)propionic acid)

A. HERBICIDAL USE

1. General: Mecoprop formulations are broadleaf weed
killers particularly effective for control of
chickweed, cleavers, clover, and plantain. The weeds
on which the various formulations of this compound
are particularly effective include common chickweed,
mouseear chickweed, clover, plantain, knotweed,
dichondra, pigweed, ragweed, lambsquarters, and
ground ivy. Mecoprop is useful for control of weeds
in cereals such as wheat, oats, and barley and for
lawn and turf.

Climatic conditions affect the action of mecoprop in
the same way they affect the action of other phenoxy
herbicides. Moist, warm conditions are conducive to
good results. Cold weather and drought produce a
delay in weed control action.

2. Application methods: Postemergence foliage
application.

3. Rates: Established turf in lawns and
fairways-2.24-3.36 kg/ha.

For weed control in cereals - 1.5-2.5 kg/ha

4. Usual carrier: Water at 350-900 L/ha.

54

The salt formulations of mecoprop used are highly
soluble in water; there is no need for additional
agitations after initial mixing.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

ie

Foliar absorption characteristics: Mecprop
formulations may be rendered ineffective if washed
off by rain immediately after application.

Translocation characteristics: Translocation of
mecoprop takes place from the foliage into roots of
treated plants.

Mechanism of action: Mecoprop acts in a similar
fashion to other phenoxy acids.

MONURON - 3-(p-chlorophenyl)-1,1-dimethylurea

(N'-(4-chloropheny1)-N ,N-dimethylurea)

A. HERBICIDAL USE

ie

Le

General: For general weed control in noncropland
areas.

Application methods: For general weed control,
monuron is sprayed or spread dry (as granules) at any
time except when ground is froxen, but best results
are obtained if it is applied shortly before weed
growth begins. Dense growth should be removed before
application.

Rates: General weed control (where bare ground is
desired for an extended period) - 4 to 16 1b/A
control most annuals; 6 to 48 1b control most annuals
and perennials. Higher rates and repeat treatment
may be required where a longer period of control is
desired or when hard-to-kill, deep-rooted perennial
weeds are present.

Usual carrier: Water in sufficient volume to
uniformly cover area to be treated (continuous
agitation is required to maintain suspensions, or in
dry, granular formulations).

PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Absorption characteristics: Monuron is most readily
absorbed through root system; less so through foliage
and stems.

Translocation characteristics: Translocation is
primarily upward in the xylem. In studies where
application was made to aerial parts of plants,
little or no monuron was detected below the lowest
point of application.

55

Mechansim of action: Monuron is a strong inhibitor
of the Hill reaction.

Intensive studies have shown that herbicidal action
is due partially to the build-up of a substance which
is phytotoxic to the oxygenliberating pathway in
photosynthesis.

NITROFEN - 2,4-dichlorophenyl-p-nitrophenyl ether

A. HERBICIDAL USE

i

4,

General: Controls annual grasses and broadleaf
weeds. Highly tolerant crops include asparagus, cole
crops (Brassica), carrots, peas, beans, peanuts,
soybeans, other legumes, potatoes, onion, cotton,
sunflower, and certain cucurbits. Highly sensitive
crops include lettuce, spinach, tomatoes, eggplant,
pepper, annual ryegrass, millet, and sudangrass.
Registered for preemergence use on certain cole
crops, carrots, celery, horseradish, parsley, and
postemergence on certain cole crops, carrots, celery,
horseradish, onions, and parsley.

Application methods: On vegetables and field crops
and soil applications of a wet spray preemergence and

to highly tolerant crops postemergence.

Rates: Four to 6 1b/A appear to be sufficient for
most common weeds.

Usual carrier: Water at about 50 to 75 gpa.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

ike

Ls

Mechanism of action: Contact herbicide.

Biological properties other than herbicidal: None
known. ;

56

CONTACT OILS, DIESEL OIL, FORTIFIED OILS, FUEL OIL,
KEROSENE, MINERAL SPIRITS, PAINT THINNERS,
PETROLEUM SOLVENTS, STOVE OIL, STODDARD SOLVENT, AND
WEED OILS

TYPE: Weed oils are both selective and non-selective contact
herbicides applied post-emergence before the crop emerges.

FORMULATIONS: One hundred percent petroleum compounds or
various dilutions.

USES: Alfalfa, ditch banks, blueberries, clovers, walnuts,
ornamentals, agricultural premises, irrigation water, and
non-crop areas.

IMPORTANT WEEDS CONTROLLED: Most weeds that are brought into
contact with it.

APPLICATION: Usually applied pre-emergence or as a directed
post-emergence spray.

1. Selective 011 - These include only the light oil
fractions with boiling ranges from 200-400°F, such as
kerosene and stoddard solvent. Used on most crops at
40-80 gallons actual/acre.

2. Contact Oils - These include crude oils, waste crankcase
oil, gasoline, kerosene, and fuel oils that are derived
from paraffin and naphthalene bases. They kill the top
growth of weeds upon contact. Use undiluted or mixed
with water and an emulsifier. Heavy oils injure the
growing point of weeds producing slow chronic toxicity.
Light unsaturated oils cause rapid burning and acute
toxicity develops. Very light oils burn only the parts
contacted and evaporate rapidly causing only local injury
to plants. Used considerably in non-crop areas and
applied pre-emergence to many crops before they emerge
and to orchard floors.

3. Fortified Oils - These form a contact spray material.
Usually fortified with Pentachlorphenol, Dinitro
compounds, TCA, 2,4-D, and other related compounds. With
this method less oil is needed for adequate control.
Fortified oils will kill such oil-tolerant weed as
fennel, poison hemlock, and St. Johnswort.

PRECAUTIONS: Do not apply on desired plants unless otherwise
recommended. Avoid drift.

ADDITIONAL INFORMATION:

i= Fuel Ouls — Sold by grades from 1 to 6. The lower the
grade, the greater the toxicity to plants.

a7

2. Stoddard Solvents - Used for selective weed control in
certain tolerant crops. The aromatic content should be
no greater than 254.

3. Diesel 0il - Used as a non-selective contact herbicide.
Oftensfontucied.

4. Kerosene - It has a low toxicity to plants. Can be used
on small carrots for selective weed control. Often used
as a diluent in oil soluble herbicides where an oil of
low plant toxicity is needed.

All petroleum oils are exempt from residue tolerances.
Viscosity influences the rate an oil will spread over and
penetrate a plant. The higer the viscosity, the slower
the penetration. Most contact oils hve a flash point of
over 180°F. Most selective oils have a flash point of
over 100°F. Oils for weed control should contain a

high percentage of unsaturated hydrocarbon and have a
sulfonatable residue of at least 25%. Those used
selectly are usually more highly refined so that
unpleasant odors or taste in market crops are reduced or
eliminated. Oils also express insecticidal activity.

PARAQUAT - 1,1'-dimethy1-4,4'-bipyridinium ion
YW PY
[as dichloride salts]

A. HERBICIDAL USE

1. General: Paraquat is registered for weed control
during establishment of grass seed crops. It is
registered as a general contact herbicide for noncrop
usages, as a herbicide for orchard weed control, as a
preemergence herbicide and as a direct postemergence
herbicide. Pasture renovation is another area of
development.

2. Application methods: Ground or air foliar spray -
contact activity mainly.

3. Rates: Grass seed bed weed control - 0.5 1b/A.
Desiccation - 0.25 to 0.75 1b/A.
General weed control - 0.5 to 1 1b/A.

4. Usual carrier: Water 5 to 50 gpa.

X-77 surfactant or equivalent is recommended for use
with paraquat. Other nonionic and cationic
surfactants are compatible with paraquat. When
applied in liquid fertilizers or nitrogen solutions,
16 to 32 oz. of X-/7 1s recommended.

58

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Ales

Foliar absorption characteristics: Very rapidly

absorbed by the foliage. Very resistant to removal
by rain.

Translocation characteristics: Local systemic action
has been noted. Transloction via the xylem can occur
under certain conditions.

Mechanism of action: Both the herbicidal activity
and the organic chemical reactions of paraquat
formulations are dependent solely upon the paraquat
cation, and are not influenced by the nature of the
associated anion, since the salts are largely
dissociated in aqueous solution.

Metabolism and persistence in plants: It has been
demonstrated that there is no metabolic breakdown of
paraquat in tomato, broad bean, and maize plants. In
sunlight, however, some photochemical breakdown
occurs for paraquat which remains on the outside of
treated plants. The extent of this breakdown under
conditions of high light intensity is about 25 to 50%
in 3 weeks, the only products formed being N-methyl
isonicotinic acid and methylamine (both of which have
very low mammalian toxicities). Since plants are
killed rapidly in bright sunlight, significant
quantities of the breakdown products are formed only
on the surface of dead tissus, and there is no
movement of these substances from the dead tissues to
other parts of the plant.

Biological properties other than herbicidal:

Paraquat has shown usefulness as a means of
controlling columnaris, a myxobacterial disease of
fish. No insecticidal or nematocidal properties have
been demonstrated.

PICLORAM - 4-amino-3,5,6-trichloropicolinic acid

A. HERBICIDAL USE

General: For general woody plant control and control
of most annual and perennial broadleaf weeds. Most
grasses are resistant, and broadleaf weed control in
grass crops is feasible. Most broadleaf crops are
sensitive.

Application methods: Granular formulations can be
applied by hand or with most commercial granular
applicators. Liquid sprays can be applied aerially,
or by ground equipment, knapsack equipment, and tree

og

injectors. All applications should be applied in a
manner to avoid drift. Liquid formulations can be
applied under conditions favorable for plant growth
anytime up to 3 weeks before frost. Granular
applications are most effective when rainfall occurs
soon after application.

Rates: For thick stands of brush use pellets or
beads at the rate of 2 to 8 pounds of picloram per
acre distributed evenly to the soil over the roots of
the woody plants to be controlled.

Liquid sprays usually are applied at rates of 2 -0z—Co
3 pounds of picloram per acre.

Rates for controlling deep-rooted perennial weeds,
such as field bind-weed and Canada thistle, usually
arewl: LOgj eG) b/ Ay

Usual carrier: The liquid salt formulations are
applied in water sprays. Tordon 155 is applied in
fuel oil.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

es

Absorption characteristics: Rapidly absorbed by both
tops and roots.

Translocation characteristics: Translocates both up
and down in plants. Accumulates in new growth.

PROMETONE - 2,4-bis(isopropylamino)-6-methoxy-s-triazine

(4,6-bis(isopropylamino)-2-methoxy-s-triazine)

A. HERBICIDAL USE

i

General: Prometone is a nonselective preemergence
and postemergence herbicide which controls most
annual and perennial broadleaf and grassy weeds on
noncrop land.

Application methods: Application of sprays or
granules can be made either before or after weed
emergence. Since much of its activity is through the
roots, adequate rainfall is required to move the
chemical into the root zone.

Rates: From 10 to 60 1b/A, depending upon the
particular weed species. The higher rates are used
only for control of hard-to-kill species such as
Johnsongrass, Bermudagrass, bindweed, and wild carrot.

Usual carrier: Water at 50 to 100 gpa or diesel oil,
fuel oil, or weed oil at 100 to 200 gpa are the usual]

60

carriers. Agitation in the spray tank is necessary
to keep the chemical in suspension.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

hy

Foliar absorption characteristics: Absorbed through
both foliage and roots.

Translocation characteristics: Translocated from
roots and stems acropetally.

Mechanism of action: A photosynthetic inhibitor, but
may have additional effects.

PRONAMIDE - N-(1,1-dimethylpropynyl1)-3,5-dichlorobenzamide

3,5-dichloro(N-1,1-dimethy1-2-propynyl)benzamide

A. HERBICIDAL USE

iv

oh

4.

General: Kerb is a selective herbicide that will
control many broadleaf and grass weeds preemergence
in lettuce. Kerb will also provide effective
preemergence and postemergence control of annual
bluegrass in bermudagrass turf. Kerb will control
quackgrass, perennial ryegrass, downy brome,
volunteer cereals, and many other winter grasses in
alfalfa, clover, trefoil, crown vetch, blueberries,
caneberries, grapes, apples, pears, stone fruits,
Christmas trees, and woody ornamental trees and
shrubs.

Application methods: Conventional surface
preemergence applications of Kerb are most effective
when there is ample rainfall or sprinkler

irrigation. Shallow soil incorporation (1 to 2
inches) will be beneficial in dry environments or in
fields watered by furrow irrigation. Kerb will also
provide excellent postemergence control of quackgrass
and many other grass weeds and several important
dicot species when applied in the fall or early
winter.

Rates =o 04/52to 2. 0.1b/ A;

Usual carrier: Water at 30 to 50 gpa.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Li

Foliar absorption characteristics: To obtain
activity, Kerb must move into the root zone of the
weeds. Little activity is obtained from foliar
contact alone.

61

Ds

Translocation characteristics: Kerb is readily
absorbed by plants through the root system,
translocated upward, and distributed into the entire
plant. The degree of translocation from leaf
absorption is not appreciable.

Mechanism of action: Kerb is strong inhibitor of
mitosis but may have additional effects.

Metabolism and persistence in plants: Metabolized
slowly by both tolerant and sensitive plants. The
metabolites observed involve alterations of the
aliphatic side chain.

Other biological properties: None

SIDURON - 1-(2-methylcylohexyl)-3-phenylurea

A. HERBICIDAL USE

Ls

General: Selectively controls certain germinating
annual weed grasses such as crabgrass (smooth and
hairy), foxtail and barnyardgrass, in newly seeded or
established plantings of bluegrass, fescue, redtop,
smooth brome, perennial ryegrass, orchardgrass,
zoysia, and the following strains of bentgrass:
Pencross, Seaside, Highland, Astoria, Nimisila, C-l,
C-7, and C-19. Should not be used on other bentgrass
strains nor on bermudagrass.

Application methods: Applied as a preemergence
treatment to bare soil as final operation following
spring seeding, or to new fall seedings or
established turf in the spring just before expected
emergence of annual weed grasses.

Rates: New seedings - 2 to 6 1b/A.
Spring treatment of fall seedings or for established
ture — Oo ton JeiD/ A.

Usual carrier: Water in sufficient volume to
uniformly cover area to be treated. Continuous
agitation is required to maintain suspension. Dry
formulations can be spread by suitable equipment.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

i

Absorption characteristics: Most readily absorbed
through root system; less so through foliage and
stems.

Translocation characteristics: Experimental evidence
indicates that siduron is translocated in the xylem.

62

Mechanism of action: Unlike other substituted urea
herbicides, siduron is not a potent inhibitor of
photosynthesis; phytotoxic symptoms appear to be
associated with root growth inhibition.

Metabo}ism and persistence in plants: In studies
with ~ C-labeled siduron, no metabolites of siduron
were detectable in barley plants after an 8-day
absorption period.

SILVEX - 2-(2,4,5-trichlorophenoxy)propionic acid

A. HERBICIDAL USE

AP

General: For control of woody plants, broadleaf
herbaceous weeds, and aquatic weeds. It is also
useful as selective postemergence herbicide in rice
and bluegrass turf. In sugarcane, it is used to
control wild lettuce, chicory, nightshade, tievine,
and certain other weeds not susceptible to 2,4-D.
For brush control in rangeland improvement programs,
especially post, blackjack, sand shinnery oaks,
yucca, and salt cedar. Controls alligator weed in
ditches and riverbanks. Controls 2,4-D tolerant
weeds such as chickweeds, spurges, and black medic in
furee

Application methods: Generally used postemergence.
Brush treatment by aerial or ground equipment.

Rates -meRiceme0s75)to7ls2501b/A;“sugarcane, | to 5
ib/Ateturtiyels> Lb/Ayeconitfter "release, +2 to 3 Ib/A;
brush spray, 1.5 to 16 1b/A; aquatic weeds, 4.25
lb/acre foot of water.

Usual carrier: Water or oil-water mixture. Oil for
basal bark, stump, and dormant cane treatment.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

Ll.

Absorption characteristics: Similar to 2,4-D. It is
absorbed through roots and foliage. Ester forms are
generally more effective as foliage sprays than salts.

Translocation characteristics: When applied to the
foliage, it is translocated along with food materials

in the phloem.

Mechanism of action: Similar to 2,4-D in disturbing
the normal processes of cell differentiation.

Metabolism and persistence in plants: Similar to
2,4-D.

63

5. Biological properties other than herbicidal: Useful
in reducing preharvest fruit drop of apples. Little
or no biological activity on insects nematodes, or
fungi.

SIMAZINE - 2-chloro-4,6-bis(ethy lamino)-s-triazine
A. HERBICIDAL USE

1. General: Simazine is a widely used selective
herbicide for control of broadleaf and grass weeds in
corn, citrus, deciduous fruits and nuts, olives,
pineapple, established alfalfa, and perennial grasses
grown for seed or pasture, turf grasses grown for
sod, ornamentals, nursery plants, Christmas tree
plantations, sugarcane, asparagus, and artichokes.

It is used also as a nonselective herbicide for

vegetation control in noncropland. Sugarbeets,

tobacco, oats, and many vegetable crops are very
sensitive to simazine.

2. Applications methods: Applications of either sprays
or granules should be made on bare soil prior to weed
emergence. It also may be applied prior to planting
for many crops. Simazine has little or no foliar
activity and must be absorbed by plant roots. Under
dry conditions, a shallow incorporation may increase
the degree of weed control.

3. Rates: The equivalent of 2 to 4 1b/A are required
for selective weed control under most conditions.
Higher rates are used for nonselective weed control
and in several specific weed crops situations.

4. Usual carrier: Water at 20 gpa or more is the usual
carrier for uniform application. Agitation in the
spray tank is necessary to keep the chemical in
suspension. Granules also are used widely in citrus,
fruit trees, and ornamentals.

B. PHYS LOLOGICAL AND BIOCHEMICAL BEHAVIOR

1. Foliar absorption characteristics: Absorbed mostly
through plant roots with little or no foliar
penetration. It has low adhering ability and is
readily washed from foliage by rain.

2. Translocation characteristics: Following root
absorption it is translocated acropetally in the
xylem, accumulating in the apical meristems and
leaves of plants.

3. Mechanism of action: A photosynthetic inhibitor; but
may have additional effects.

64

Metabolism and persistence in plants: Simazine is
readily metabolized by tolerant plants to
hydroxy-simazine and amino acid conjugates. The
hydroxy-simazine can be further degraded by
dealkylation of the side chains and by hydrolysis of
resulting amino groups on the ring and some CO
production. These alterations of simazine are major
protective mechanisms in most tolerant crop and weed
species. Unaltered simazine accumulates in sensitive
plants, causing chlorosis and death.

Biological properties other than herbicidal: Limited
studies have shown some minor fungicidal and
nematocidal activity but no insecticidal activity.

SODIUM CHLORATE - Sodium chlorate

A. HERBICIDAL USE

i.

Ze

sip

General: Used as a herbicide for morningglory,

St. Johnswort, Russian knapweed, Canada thistle, and
johnsongrass; and as defoliant. A nonselective
herbicide.

Ratecemel 2) cos —l/2elb/100esqe "ft.

Usual carrier: Apply only in dry form.

2,4,5-T - (2,4,5-trichlorophenoxy) acetic acid

A. HERBICIDAL USE

General: For the control of woody and herbaceous
weed plants by air or ground spray application under
a variety of conditions. Use rates vary: foliage
spraying of woody vegetation - 4 to 16 1b/A; basal
barke-supnto 16. 1b/A: dormant, brush —.up.to 9 1b/A;
selective conifer release - 2 to 3 lb/A; rangeland
andupastune — 0.5 to 3 1b/A.. Also useful in frill
and injection tree treatment and for weed control in
rice, sugarcane, and turf. Often used with 2,4-D for
brush control.

Application methods: Used postemergence in
conventional ground or air equipment as foliar
spray, as individual tree and stump treatment, as
directed dormant stem spray.

Rates: 0.5 to 16 1lb/A as noted above.

Usual carrier: Water, oil, or oil water emulsion

65

A.

PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

iy

Absorption characteristics: Similar to 2,4-D.
Absorbed through roots, bark, and foliage. Esters of
2,4,5-T are more resistant than salts to the washing
action of rain.

Translocation characteristics: Through phloem tissue
following foliar application. Characteristics
similar to those of 2,4-D.

Mechanism of action: Similar to 2,4-D. Several
modes of action have been demonstrated, but the basic
mechanism of action stil is not fully know.

Metabolism and persistence in plants: Similar to
24D.

Biological properties other than herbicidal: Little
or no biological activity on insects, nematodes or
fungi. It has been used as growth regulator to
increase size of citrus fruits and reduce excessive
drop of deciduous fruit.

2,.3,0-IBA, =— ©2>3,6-trichlorobenzoic acid

HERBICIDAL USE

Ie

General: Primarily for control of broadleaf
deep-rooted, noxious perennial weeds such as field
bindweed, leafy spurge, Canada thistle, Russian
knapweed, bur ragweed, blueweed, and climbing
milkweed; also used for nonselective control in
noncropland and for control of certain weedy plants
and vines such as smilax, honeysuckle, trumpet vine,
spruce, balsam, fir, cedar, pine, Macartney rose,
sumac, persimmon, sassafras, and hackberry. Spray
drift may injure susceptible crops such as beans of
all types, tomatoes, peas, cotton, tobacco, and
various ornamentals, orchard, and vine crops.

Application methods: By ground equipment as a coarse
spray applied with low or moderate pressure to both
weed foliage and soil. Best results are obtained if
applied after weed foliage appears in spring, but
before growth has progressed sufficiently to retain
more than half the spray.

Rates (ae/A): Noxious perennial weeds - 10 to 20 lb
Mixed broadleaf weeds - 20 to 30 1b for control
greater than 1 year

Woody vines - 10 to 20 lb

Woody brush - 4 1b

66

The above rates will give relatively long-term
residual soil action.

4. Usual carrier: Water is the usual carrier for
2,3,6-TBA. With light ground cover use 50 gpa, and
on denser areas use 100 to 200 gpa. Uniform foliage
and soil coverage is essential for optimum results.
The spray mixture is a true solution, so once mixed
agitation is not necessary. Little data is available
as to possible benefits of surfactants. Some Texas
studies indicate no advantage of surfactants or
"penetrating aids."

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

1. Foliar absorption characteristics: Both foliage and
root absorption contributed to plant kill. Since the
dimethylamine formulation is water soluble, the
absorptive properties of an aqueous solution would be
dependent upon the wetting ability of the carrier.

2. Translocation characteristics: The 2,3,6-TBA is
readily mobile in xylem, phloem, and mesophyll
cells. It, like phosphorus, moves freely through
both living and nonliving plant tissues. 2,3,6-TBA
accumulates in both the growing tips of plant roots
and shoots. The acid form placed on stems or leaves
of bean plants was absorbed and translocated
throughout the plants, causing growth modification.
The compound moved downward into roots and out into
the surrounding soil, whereupon roots of nearby
untreated plants absorbed the compound and
translocated if upward into their aboveground parts.
Transfer of the compound also occurred between the
root systems of various other genera.

3. Mechanism of action: , Functions as a growth
regulator. Acid form 2,3,6-isomer) demonstrated high
physiologic activity in the Avena coleoptile test.
This isomer caused cell elongation and proliferation
of tissue, induced adventitious roots, modified
leaves and other plant organs, and caused
parthenocarpic fruit development.

4. Metabolism and persistence in plants: Extremely
stable in plants and not subject to rapid enzymatic
decomposition.

TCA - trichloroacetic acid

A. HERBICIDAL USE

1. General: For control of grass seedlings and certain
established perennial grasses and cattails. Common

67

crop plants for which the compound is useful:
sugarbeets, red beets, and sugarcane as a
preemergence application or directed spray. It has
been used for grass control in other crops. It is
used also on noncropland including plant sites and
road shoulders for grass control.

2. Application methods: Can be applied with
conventional spray equipment.

3. Rates: For nonselective treatment, rates of 50 to
200 1b/A are used depending upon grasses to be
controlled. For selective use on crops, rates of
6 to 30 1b are used depending upon crop tolerance and
grass species.

4. Usual carrier: Sodium TCA is usually applied in a
water spray.

B. PHYSIOLOGICAL AND BIOCHEMICAL BEHAVIOR

1. Absorption characteristics: Absorbed more rapidly by
roots than by foliage. Is easily removed from
foliage by rain.

2. Translocation characteristics: Translocates
readily. Accumulates in growing tissues.

TEBUTHIURON - 1-(5-tert.-butyl-l, 3, 4-thiadiazol-2-yl)-l,
3 - dimethylurea

TYPE: Tebuthiuron is a substituted urea type compound used
as a pre-emergence herbicide.

FORMULATIONS : 80% WP, 5, 10, 20 and 40% pellets.

IMPORTANT WEEDS CONTROLLED: Alfalfa, bluegrasses, bromes,
bouncingbet, butter cups, chickweed, clovers, cocklebur,
dock, fescue, fiddleneck, filaree, foxtails, goldenrod,
henbit, horseweed, kochia, lambsquarters, morning glory,
mullein, nightshade, wild oats, pigweed, puncture vine,
ryegrass, prickley sida, sowthistle, spurge, sunflower,
Russian thistle, vetch, witchgrass and many others.

USES: Total vegetation control. Experimentally being tested
on sugar cane, pineapple, on range and pasture land and in
reforestation programs.

RATES: Applied at 3/4-8 lbs. actual/acre.

APPLICATION: Total vegetation control - apply as either a
pre- or post-emergence treatment to railroad right-of-ways,

68

industrial sites, tank farms, highway medians, etc. Rainfall
18 required to move the chemical into the soil. Apply either
before or during the period of active plant growth.

PRECAUTIONS: Do not use on any food or feed crop until

registration has been obtained. Do not apply near desirable
trees or plants.

ADDITIONAL INFORMATION: May be used in combination with
other herbicides. Controls a number of woody species of
plants. Use higher rates and/or repeat application to
control hard to kill perennial species. Spot treatment on
range and pasture land is effective. Water solubility is 2.5
ppm. Low toxicity to fish and wildlife. Vertical leaching
in the soil is slow and no lateral chemical movement has been
observed. Readily absorbed through the root system and
inhibits photosynthesis. The half life in the soil is 12-15
months in areas of 40-60 inches of rainfall.

VELPAR - 3-Cyclohexyl-6-(dimethylamino)
-l-methyl-s-triazine-2,4(1H, 3H)-dione

FORMULATIONS: 90% water soluble powder.

USES: Experimentally being tested on sugar cane and for
total vegetation control.

IMPORTANT WEEDS CONTROLLED: Annual boradleaf and grass
seedlings as well as most annual and perennial grasses,
broadleaf weeds, and vines depending upon rates.

RATES: Applied at 1 - 3 1b. on seedling weeds, 2 - 6
1lb./acre for top kill and short-term control of established
annual and perennial weeds and 4 - 10 1b./acre for
season-long general vegetation control.

APPLICATION: Applied post-emergence during periods of active
plant growth. Application when vegetation is dormant or
semi-dormant may not be effective. Spray to lightly wet the
foliage.

PRECAUTIONS: Do not use until registration has been
obtained. This material will not dissolve completely in
spray concentrations exceeding 12-1/2 lbs./50 gallons of
water. Do not use near desirable trees or plants. Prevent
delit.,

ADDITIONAL INFORMATION: May be used with a surfactant to
improve the wetting properties. Relatively harmless to fish
and wildlife. Taken up by both roots and foliage. Looks
very effective on brush and hard to kill perennial weeds.
This material is very rate responsive to the type of weed to
be controlled and the length of control desired. Water
solubility 32,000 ppm. More effective the higher the air
temperature.

69

F. METHODS OF APPLICATION

In order to be effective, a herbicide must enter the plant and
move to the site of action. Entry may be through various parts
of the plant: leaves, roots, seedling shoot before emergence,
or above-ground stem. Entry may also be forced, as when the
cut-surface method of application is used. Penetrating agents
or penetrants may be added to the herbicide to improve its
penetration of the plant foliage or stem surface., Before a
herbicide can enter the foliage, the cuticle or wax surface must
be penetrated. Some entry may take place through the stomata on
the under side of the leaf.

Entry of herbicides into plant roots is not as difficult as
entry into foliage, since no wax layer or cuticle is present.
The major problem with root uptake is getting the herbicide
through the soil to the roots. Soil-applied herbicides are
active on germinating seeds or small seedlings. Before
emergence, the shoot has a poorly developed cuticle and probably
no wax layers, making it more easily penetrated by herbicides.
Herbicides that are quite mobile in the soil, such as picloram,
will control large brush and trees.

Young stem tissue of herbaceous plants may be penetrated by
herbicide solutions in much the same way as leaves. However,
stems are less important than leaves because of the small
surface available.

Once in the plant, the herbicide must still move to the site of
action. Some of the herbicide may be chemically bound in the
plant, making it inactive. The remaining herbicide moves
through the xylem and/or phloem. Herbicides that enter the
roots or foliage may move upward in the xylem with the
transpiration stream. Phloem movement of herbicides is usually
down, but may also be up in some plants. Applications to the
leaves of perennial plants can thus move to the roots. Phloem
movement is associated with sugar transport and, therefore, good
light conditions are helpful. Also, it is very important not to
kill the leaf and stem tissues rapidly, since transport is via
living tissue.

To make use of this knowledge, the following methods of herbicide
application are used in the Eastern Region: (Figure 3)

1. Basal Stem - Application is made to this area via a
coarse-droplet spray at low pressure about 12 or 18
inchesabove the soil surface. Spray is applied until an
excess runs off onto the soil surface at the base of the
stem.

2. Cut Surface - This involves insertion of herbicides into
cuts made with special tools, or by applying herbicides into
frills or hacks made by axes or mechanical cutters. This
method includes applying herbicides to stumps of cut stems.

70

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Foliage - Here, the foliage is sprayed from air or ground.
Applications may be either broadcast to cover several acres,
directed at groups of plants, or a treatment of individual
plants. Helicopters are used exclusively for aerial
applications in the Eastern Region. Ground equipment may
consist of individually operated back pack (garden type)
sprayers, large 100 to 300 gallon tank type hydraulic
sprayers mounted on trailers, or four-wheel drive or crawler
type vehicles. Coarse sprays are used to control drift. In
addition, invert emulsions, foams and other drift control
agents or equipment may be used to produce large drops and
control of aquatic weeds where herbicides or algacides are
introduced into the water through a boat bailer or surface
spray.

Soil Treatment - This involves application of a herbicide,

liquid or granular in form, to the soil. Granules are a

type of formulation in which the active ingredient is mixed
and pressed with an inert carrier to form a small pellet
that can be distributed on the soil. As the granules slowly
decompose, the herbicide is released into the soil. Other
soil treatments with liquids act as soil sterilants, and
when present in or on the soil, prevent the growth of plants
(Figure 3).

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ele

ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION

This section is an analysis of both the anticipated favorable
and possibly adverse impacts of herbicide use in the Eastern
Region, as they may affect the local, regional, national, and
international environment. The environment, in this case,
includes not only the natural environment, but the social and
economic environment as well.

Planned measures to minimize and mitigate adverse environmental
impacts of herbicide use, including specifications and standards
necessary to maintain and protect environmental quality, are
found in Appendix A under Controls on Herbicide Use.

A. NON-LIVING COMPONENTS

1. Air. Herbicides can enter the air system and contribute
to air pollution. Entry may be in the form of drift or
vapors. Drift is defined as that part of the spray
which moves out of the target area in fine drops and
deposits on adjacent property. Vapors are volatilized
or photo-altered herbicide molecules from falling or
fallen spray drops. Recent experiments have shown the
amount of herbicides recovered on the target area to be

at least 70% to 85% (Norris, Montgomery, and Warren,
1976)

The different factors affecting drift are summarized in
Table 2. These factors do not have equal importance and
change with different herbicides, method of application,
and geographic location.

74

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habler2

Effect of Various Factors on Herbicide Drift

Less Drift Factor More Drift
Lower A. Release Height Higher
Lower B. Wind Speed! Higher
Faster C. Droplet Fall Rate Slower
Larger Ie Droplet Size Smaller
Lower a. Pressure / Higher
Jet b. Nozzle Type— Wide angle
cone or fan
Larger cau Oriitce, Size Smaller
Lower d. Air Shear on Spray Higher
Higher e. Surface Teneione’ / Lower
Higher f. Relative Humidity— Lower
Higher g. Viscosity Lower
Higher Jee Drop Dane tet Lower
Less Dew Air Stability Greater
E. Aircraft Turbulence
Slower 1. Speed Faster
Clear 2. Aircraft Aerodynamics Rough
Climbing 3. Flight Attitude Falling
Closer 4. Nozzle Location on Farther out
Boom cf. Center
Smaller F. Size of Treated Area Larger

sh ysiyeen speed at which air stability is reduced.

=,Certain nozzle types can produce larger drops or narrower range.
— Higher oil or surfactant content reduces surface tension.
~—,Important with evaporative carriers (water).

2/031 carriers are lighter (less dense) than water.

75

Spray droplets are measured as drop diameters in units
of micrometers or microns. A micron is 1/25,400 of an
inch. A droplet, with twice the diameter of another,
has eight times the volume or mass. The smaller droplet
has about 1/4 the surface of the large droplet and
therefore, will respond 16 times more to the force of
air movements.

Research has shown that. there is a rapid decrease in a
droplets drift potential as their size increases above

200 microns. (Figure 4)

LATERAL MOVEMENT (feet)

DISTANCE (feet)

FALL

5 M.P.H. WINO ——>

Figure 4 - Lateral movement of spray particles of various
diameter falling at terminal velocity in a 5 mph cross-
wind. Shaded areas indicate uncertainty due to varying
droplet evaporation (Reimer, et al. 1966)

As droplets fall through air which has less than 100
percent relative humidity, they will decrease in size
and can become increasingly subject to drift. The size
of the original drop and the distance it falls has a
great influence on the amount of evaporation. Covering
the drop with a coat of oil will aid in reducing the
evaporation. The position of the spray nozzle on the
application equipment and the speed at which the nozzle
moves through the air has a direct affect on drift. As
the spray leaves the nozzles mounted on an air craft, it
travels at speeds of about 25 m.p.h. It is subject to
shearing by the air through which the nozzle is moving;
this force will cause a break up of the drops. (Warren
1976). Drop size is affected very little by this force
with ground application moving 5 to 10 m.p.h.

76

As Table 2 and the above discussion indicate, drift can
be affected by many factors. Most of these can be
controlled, or adjusted to by the applicator, to
eliminate any environmental impact. With the best
available technology, it is routinely possible to
deposit 97 - 99% percent of the released spray within
ordinary target areas by aircraft or ground equipment
(CAST Report).

The vaporization potential of herbicides is known, so
appropriate formulation that will not produce
unacceptable air pollution or off-target effects can be
used. The main climatic factor affecting volatilization
is temperature. The amount of vapor accumulating in the
air would increase with higher temperatures, larger
treatment areas (over 100 acres in size), fine sprays,
and stable air conditions. The Eastern Region's
contribution to this source of pollution would be
negligible due to the small acreage, 7,000 to 10,000
acres, treated across the Region each year. The average
area size treated in the Eastern Region is between 35 to
45 acres.

Herbicides, as air pollutants, are removed from the air
by rainfall, photo decomposition, atmospheric fallout,
and adsorption to particulate matter. Atmospheric
washout allows entry into the oceans (Rabson, and
Plimmer 1973); therefore, this pathway, if not avoided,
could be an important contribution to worldwide
pollution.

The Clean Air Act has been studied, and the U.S.
Environmental Protection Agency contacted (letter of
March 9, 1977), for guidelines on air quality and
herbicide application. There is nothing that indicate
that aerially applied herbicides would be considered
pollutants under Federal law.

History and Archeology. Executive Order 11593

(Protection and Enhancement of the Cultural Environment)
requires that Forest Service plans and programs
contribute to the preservation and enhancement of
structures and objects of historical, architectural, or
archeological significance. The cultural resources of
the National Forests are a non-renewable resource of
growing importance. They are extremely fragile and can
be altered by relatively minor disturbances.

Herbicides applied indiscriminately on archeological
sites could contaminate archeological materials and
affect the correctness of carbon-14 dating. For
contamination to take place, items of archeological
significance would have to be on, or close to, the soil
surface. Herbicides proposed for use do not readily

dd

leach into the soil and are not persistent. Most of the
herbicide applications are to sites that have been
grossly altered by prior activities, such as road
construction, cultivated fields, timber sales and site
preparation, and utility rights-of-ways. To effectively
identify and protect a site of historical or
archeologicai importance, an archeological search must
be made before the major soil disturbance takes place.

Land Ownership - Land Use. Major consideration must be
given to land management, especially prime agriculture
lands. When possible, land use decisions which
irrevocably commit prime lands to non-farmland,
non-range, and non-forest land uses should be avoided,
thereby foreclosing the options for future generations.
The 1976 USDA Secretary's Memorandum No. 1827,
Supplement 1, advocates that land uses that preclude
land from future agriculture uses be avoided. Proper
herbicide use on forest lands in the Eastern Region will
not affect the long-term productivity or uses which can
be made of treated lands. The ability to use herbicides
as a management tool does identify some Forest lands
with a primary use, as in the case of utility
rights-of-way, agricultural uses, and range allotments.
Pressure to use Forest lands for these purposes exists
because permittees feel that once they establish an
investment in the land or the facilities they will be
able to maintain that use. These lands, however, in no
way exclude compatible use by the general public.

Soils. The forest floor is a major receptor of
herbicides. Deposition may be direct, washed from
vegetation by rain, or excreted from vegetation. Once
on the forest floor, some herbicide loss will occur by
photo-alteration and through volatilization. The
remainder will be washed into the humus layer and lower
soil layers by rainfall. What happens to the herbicide
after it enters the soil depends on the herbicide in
question and on a number of soil factors. High organic
content, moisture, aeration, temperature, iron oxides,
pH, and clay content reduces herbicide mobility in the
soil and aids rapid herbicide breakdown.

Undisturbed forest soils tend to be acid, low in organic
matter, have a cool temperature, and are dry, all of
which favors slow breakdown. However, most sites
receiving herbicides, have been disturbed by human
activities, i.e. road and utility rights-of-way
construction, site preparation, lard clearing for
agriculture, and abandoned man-made clearings. Such
disturbance can reduce the humus layer which protects
the soil; but, it also opens the area to sunlight and
increased soil temperature. Under field conditions,

78

most herbicides have been found to quickly degrade.
Herbicides give non-toxic and naturally abundant end
products, such as carbon dioxide, and water; and
chlorine, nitrogen, sulfer, and phosphrus.

Adsorption and leaching also take place in the forest
floor and soil. Most herbicide molecules attached to
soil particles provide temporary soil storage for later
release. The free and released molecules are subject to
leaching, movement with soil erosion to water sources,
volatilization, chemical degradation, biological
degradation, and plant uptake. Herbicide leaching in
the soil is a slow process and generally measured in
inches. Maximum persistence for some photosynthetic
inhibitors may reach 2 years. Most herbicide
persistence is measured in weeks, however.

Soil loss by erosion averages up to 0.1 ton/acre per
year from forest land. This must be accepted as a
normal geologic process. The rate probably varies from
less than 0.05 ton to 0.3 ton per year, depending on
geology, soil, climate, and vegetation. This process is
the most active where annual precipitation ranges from
15 to 30 inches per year. (Patric, 1976). This might
indicate soil bound herbicide molecules could move with
soil erosion to surface water. However, most soil
erosion within the undisturbed forest is not sheet
erosion, but almost always originates in stream
channels. On land sloping less than 35 degrees, there
is no evidence that tree death accelerates soil erosion
much above geologic rates. (Patric, 1976). Massive
rainfalls, bare soils, or excessively steep slopes
combined with soils containing herbicide molecules can
be an exception to this norm.

Visual. Visual impacts associated with using herbicides
to control vegetation include dead leaves, dead
branches, standing dead trees, and a change in
vegetation contrast.

The “brown out" caused by curing of the target
vegetation following herbicide application has an
immediate and adverse visual impact. Visual and
aesthetic values are generally lowered during "brown
out,"’ however, the effect is temporary, lasting only
until leaf fall. When dead brush and snag trees are
left following herbicide use, the visual signs may last
10 years or more.

The objective of herbicide use is to create a vegetation
change to desirable (economic, aesthetic) species at the
expense of undesirable species. This change can be
either temporarily adverse or pleasing, depending on the
thinking of the viewer. If the contrast in vegetation
looks artificial or out of place, the visual impact can

79

be negative. At the same time, the diversity of
vegetation and new stands of trees or grass, as
encouraged by treatment, add to the attractiveness of an
area. The visual impact of herbicide use often depends
on location, topography, access, shape, likelihood of
recreation use, etc.

Aquatic weed control can result in a temporarily
displeasing sight, caused by floating dead plants.

Water. No area of environmental concern has received as
much attention as water quality and quantity. The
waters associated with the Forests in the Eastern Region
are mainly headwaters and are known for their purity and
sensitivity to contamination. Only a few of the
projects involving herbicides call for application of a
chemical to water. Only those herbicides specifically
registered for use in water will be used for these
projects,

Certain concentrations of herbicides in water could
adversely effect the potability of drinking water; food
chain organisms in the aquatic environment; sensitive
irrigated crops; and, the industrial and recreational
uses of such water. Entry into the surface water may be
direct, by soil erosion, air wash out, or ground water
flow. Direct entry is mainly caused by an error in
application or through drift. Concentrations may reach

1 ppm, be short term, and local in nature.

The National Interim Primary Drinking Water Regulations
list the maximum contaminant levels (MCL) for organic
chemicals in drinking water. These MCL's are for
community water systems, where use for human consumption
is considered long-term. Most forest water systems are
considered non-community systems because they serve
transients (hikers, picnic areas, campground, etc.).
The proposed pesticide levels shown in the regulations
have been found safe for long-term human exposure, and
therefore are lower than levels necessary to protect
intermittent users.

Herbicide Interm MCL
Pie Pee 100 ppb
Silvex (2,4,5-TP) 10 ppb

Soil erosion to be a source of contamination, it must
Overcome considerable resistance from forest vegetation
and humus layers protecting the soil. However, massive
rainfalls immediately following an herbicide application
unprotected soils, steep slopes, and a short distance
from treated soil to surface water all increase the
chance of surface waters becoming contaminated from an
herbicide treatment area.

3

80

Herbicides which vaporize during application or from the
surface of vegetation eventually precipitate or wash out
of the air as the parent compound or as a photo-chemical
degradation product. Such fallout may be far removed
from the application site and is of low intensity, but
usually decreases very rapidly with distance from the
origin (Caro, 1971).

Some movement from certain herbicides to surface water
can occur through groundwater, but rarely if ever has
been shown to do so. This has greater possibility in
the Ozarks, where Karst topography is found. In other
areas, the slow movement of water through the upper soil
profiles allows for rapid herbicide degradation in the
forest floor and rooting zone before the herbicide has
moved very far. Wiese and Davis, (1964) found that
esters of 2,4-D commonly used in forest management, do
not leach beyond the top 3.1 inches of the soil
profile. The more persistent and active an herbicide
is, the more likely it is to leach down to the ground
water.

Although its known that herbicides can enter the surface
water, it is important to relate here what has actually
occurred during field use when label use directions and
Forest Service application procedures were followed.
From 1972 to 1976, 30 separate water surface sites close
to aerial applications of 2,4-D were monitored on
National Forests in the Lake States. The surface waters
included rivers, lakes, pot holes, impoundments, and
marshes. One hundred and sixty-one water samples were
collected and tested. These samples were collected
according to a planned schedule: immediately after
spraying; 4 hours later; 24 hours later; 65 hours later;
and after the first rain. Only three samples showed
detectable amounts of 2,4-D; the highest being 16.0 ppb
which showed up following a rainfall totaling .32
inches. The rainfall was the day after spraying. The
water sample was taken adjacent to the spray area at the
mouth of an ephemeral steam that ran through the spray
area. The dry stream bed received a direct application
of herbicide. This was will below the 100 ppb limit
allowed for public water supplies by EPA and much below
the LC,, values for sensitive crustaceans and fish.
Measures are now taken to protect ephemeral streams from
direct applications of aerially applied herbicides.

By moving downstream 1 mile, a 100-fold reduction in
herbicide concentration has been observed in several
instances; but, 1£ is difficult to give an exact rule of
thumb because of the nature of the dilution process in
forest streams. If we accept a 25-fold reduction in
concentration over a mile of stream as a conservative

81

estimate, then if a maximum herbicide concentration of
0.01 ppm was observed at the boundary of a treated area
it would be less than 0.0004 ppm 1 mile downstream.
There will be a return to nondetectable (€ 0.001 ppm)
levels in less than 24 hours after application.
Therefore, the highest level which humans could be
exposed to might be 0.01 ppm for 24 hours, if water was
taken for consumption from the stream immediately
downstream from the treated area. Of course, the more
remote the treated area is from the stream, and the
further the water which is to be drunk is from the water
entry point, the less likely a detectable residue will
occur (Abrahamson and Norris, 1976).

Mullison (1970) reviewed the concentrations of
herbicides found in water after spraying adjacent
uplands. Detected concentrations were from 0 to 70 ppb
(phenoxys) and up to 370 ppb (picloram). Time needed
for total disappearance ranged from 2 to 17 days
(phenoxys), up to 16 months (picloram). A June 1973 EPA
monograph stated, "Under field conditions picloram does
not present a serious threat to water quality a short
distance downstream from the site of application. It is
evident that precautions given on herbicide label are
adquate to allow the material to be used safely."

The effects of vegetation management on tiny headwater
stream flow within a National Forest may be measurable.
However, it is seldom detectable when the greater
volumes of flow are measured in large rivers. Stream
flow increases in proportion to the area and severity of
vegetation control. Water quantity increases as
evaporation losses through vegetation transpiration and
interception decrease. Vegetation regrowth may return
the area's transpiration level to what it was to before
herbicide treatment in 1 to 10 years, depending on the
degree of control. This makes the increase in water
quantity short-lived, as well as minute. A minor,
long-term water quantity outflow may occur due to a
change in vegetation. Permanently foliaged conifers
intercept, as well as transpire, more water than do
deciduous hardwoods, while grass uses less than either
kind of tree (Patric 1976).

Abrahamson and Norris (1976) reported on the results of
extensive water monitoring investigations following
present-day forestry herbicide applications. Forest
stream monitoring for several herbicides, over extended
periods of time, has consistently shown that leaching of
herbicides in forest soils have not resulted in
detectable (less than 0.001 ppm) concentrations of
herbicide in forest streams. Field testing on forest
lands has verified that overland flow of herbicides is
restricted to localized events, and that the overland

82

flow showed marked reduction in herbicide concentration
as it moves over uncontaminated soil. These
measurements were made immediately downstream from
treatment unit boundaries and, therefore, represent
maximum concentrations in the stream system. When
herbicide concentrations have been detected, more than
99 percent of all concentrations have been less than
0.01 ppm.

B. LIVING COMPONENTS

Le

Domestic Animals. The impact of herbicide use around
livestock and other domesticated animals is becoming
well documented. The lethal doses for various test
animals using particular chemicals are known. The acute
oral toxicity of a single dose of the phenoxy herbicides
to mammals ranges from 100 mg/kg to 2,000 mg/kg (CAST
Report No. 39). Signs of poisoning include loss of
appetite, loss of weight, weakness, lack of
coordination, alternations of the liver and other
internal organs, and in some instances, defective
offspring.

Since domestic grazing animals can tolerate up to 2,000
ppm of some phenoxy herbicides continouously in feed,
forage residue poses no hazard to animals, even from
ranges and pastures treated at exaggerated rates. No
residues appeared in the milk of cows which consumed
rations containing up to 300 ppm of 2,4-D, MCPA or
Srivex manceupstowsUsppmeot 254.5-1.) Similaryeffects
have been found with swine, sheep, and other other
animals. When grain, with a picloram residue of 5 ppm,
was fed to a cow, 97.7 percent of the picloram was
recovered unchanged in the urine (Fisher and others,
1965). Because the dog has a lower capacity to excrete
some herbicides, it has been found that herbicides are
about three times more toxic to dogs than other test
animals.

Milk from both diary and beef cows that had grazed on
2,4,5-T treated pasture or range was analyzed for TCDD
residues by Mahle et al. (1977). Milk was obtained from
treated farms in Missouri, Arkansas, and Oklahoma, and
compared with control milk purchased in a Midland,
Michigan, supermarket. The control milk would have

had very little likelihood of contact with 2,4,5-T.

At a detection level of one ppt, control milk was
indistinguishable from milk from cows grazing on grass
treated with 2,4,5-T.

TCDD residues have been confirmed in three beef fat

sample and possibly one liver sample by the EPA during
Phase 1 of the Dioxin Implementation Program. Samples
of beef fat and livers were obtained from animals which

83

had grazed on lands treated with 2,4,5-T and non-treated
areas. A total of 85 beef fat and 43 liver samples were
collected. Approximately 25 percent of the samples were
from nontreated areas.

A meeting of the analytical collaborators (Dow Chemical
Company, Havard University, and Wright State University)
was held on June 15, 1976, to discuss the results
obtained to date. The conclusions given by the
analytical collaborators were: :

a. Of the beef fat samples (85) analyzed, one showed a
positive TCDD level at 60 ppt; two samples appeared
to have TCDD levels at 20 ppt; and five may have
TCDD levels which range from 5 to 10 ppt. While
several laboratories detected levels (5 to 10 ppt)
in this range, the values reported were very near
the sample limits of detection.

b. The analytical method is not valid below 10 ppt.

c. A neutral extraction technique shows promise of
detecting levels below 10 ppt. However, this method
has been demonstrated by only one laboratory at this
time and has not been validated by other analytical
facilities.

d. The samples analyzed were peritoneal fat and kidney
fat taken from cattle which had grazed on rangelands
of known treatement with 2,4,5-T. Controls were the
same sample type taken from cattle from nontreated
areas within the same site.

e. Of the liver samples (43) analyzed, only one sample
suggested any TCDD residue, which was too close to
the sensitivity of the sample detection limits for
quantification. The fat sample analyzed from the
same animal showed no TCDD residue. Three liver
samples (for which fat.samples were analyzed and
showed positive data) showed no TCDD residues.

f. None of the collaborators reported TCDD in samples
of beef fat taken from cattle in nontreated areas
(at the sensitivity of the analytical method).
Three of the laboratories receiving liver samples
from cattle in nontreated areas observed no TCDD in
the samples (Ross 1976).

An additional dioxin collaborator's meeting was held in
Bay St. Louis, Mississippi, on March 3 and 4, 1977. Dr.
Ralph Ross (1977), reporting to the EPA on that meeting,
stated, "the reliability of Harvard's neutral extraction
technique is very poor at the low ppt range,
particularly below 13 ppt.'"' Later he states, in regard

84

to Harvard data, "Also, it is strange that there was no
inclusion of spiked samples below 13 ppt." Ross
indicates that analytical data reported by Wright State
University, Dow Chemical Company, and Harvard University
is more reliable for samples spiked by EPA with known
levels to TCDD than data furnished by Harvard where they
themselves add TCDD. The conclusions quoted in the
preceding paragraphs are those of EPA or those
participating in the Dioxin Implementation Program.

Work in Russia suggested that the threshold taste and
odor concentractions of auxin compounds, especially of
phenolic derivatives such as 2,4-D, that would prove
unacceptable to the consumer were considerably below the
threshold concentrations for toxic effects. No residues
of either 2,4-DB or 2,4-D were found in the milk of cows
that had been fed these compounds (Way 1969). Bache et
al. (1964a) also noted the absence of 2,4-D residues in
milk at any time during the study when a jersey cow was
fed 50 ppm (based on a daily ration of 50 pounds) of
2,4-D for 4 days.

Herbicides are generally less toxic to birds than to
mammals. The acute oral LD for poultry, mallards,
and pheasants ranges upwards of 2,500 ppm, and is
typically greater than 5,000 ppm when fed in treated
feed. (Pimentel 1971)

A subtle effect of herbicide treatment on some plants

is an increase in potassium nitrate to a lethal
concentration. Nitrogen uptake in plants is in the
nitrate form. When the metabolic process of certain
plants is interrupted by drought, heat, or chemicals,
the nitrates are not properly converted to non-toxic
protoplasm. In plants like Canadian thistle, smartweed,
and black cherry, the leaves may become toxic after an
herbicide treatment. They can have adverse effects if
eaten in sufficient quantities by herbivors.

Herbicide applications following label instructions
approved by EPA have not proven harmful to domestic
livestock. However, there have been instances where
poisonings occcurred from the use of certain herbicides
or contamination resulted from herbicide accidents.

The herbicide most often associated with these accidents
is 2,4,5-T and the dioxin that contaminates it. Reports
of these instances help expose the perils of an
accident, but should not be purported as examples of
regulated use. These accidents involve 2,4,5-T and
dioxin levels far above labeled allowances and use in
the National Forests.

Human Health. To do their job, herbicides must be able

to control target pests. By their nature, they are
toxic. Therefore, some may be hazardous to people. The

85

hazards, however, are relative. A highly poisonous
chemical may present less of a hazard than a less toxic
one, depending on the conditions of use.

Proof of safety of a properly registered pesticide is
not the responsibility of the user. Under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) as
amended in 1972, EPA has the responsibility to determine
whether an herbicide or any other pesticide, when used
consistent with its labeled directions will perform its
intended function without unreasonable adverse effects
on the environment, human beings, livestock, or wildlife.

The following is a discussion of human health
consideration as they relate to herbicides used by the
Forest Service. The material is complex and there is not
complete agreement among researchers. However, an
attempt has been made to include as broad a base as
possible to reflect this range of opinions. A great
deal of literature is available outside this document
for more details.

It should be pointed out, first, that the proposed
herbicide program would use low application rates,
carried out in areas of low human population, during a
limited time of the year. Only a small portion of
commercial forest land is treated each year. A maximum
of three or four (normally, one or two) applications
would be used during the life of a stand of trees. (The
life of a stand of trees, its "rotation age,'' ranges

from 85 to 140 years in this region.)

The degree of hazard or risk to humans from use of
herbicides in the forest depends on two factors. One is
the actual toxicity of the material itself (its
toxicological potential). The second is the risk of
exposure to levels that approach a hazardous dose.

Human exposure to a herbicide depends on the pattern of
use, frequency of application, amounts used, and fate of
the herbicide in the environment. Human exposure may
occur from handling concentrate before dilution, from
inhalation of spray or dust during application, or from
ingesting chemicals through food or water. Because the
highest risks are from the concentrate and because
humans handle the chemicals in this form at all stages
from manufacture to application dilution, humans
involved with application experience a greater risk than
any other organisms.

Toxicity is a measure of how poisonous a substance is.
For pesticides, acute oral toxicity is usually expressed

as the "LD. "| or lethal dose for 50 percent of the
test animals. The LD 0 is usually given in terms of
millagrams of pesticides per kilogram of body weight
(mg/kg body weight). LD. values are useful primarily
when comparing the toxic characteristics of two or more
chemicals.

86

Norris (1971) describes two kinds of toxicity: acute
and chronic.

Acute toxicity is the fairly rapid response of organisms
to a few relatively large doses of chemical administered
over a short period of time. Chronic toxicity is the
slow or delayed respose of organisms to the exposure of
relatively long period of time. There are, of course,
all gradations in between these two extremes. The kind
of response (acute or chronic) we observe in an organism
depends on the magnitude of the dose and the duration of
the exposure which results from the behavior of the
chemical.

Toxic levels of specified herbicides are usually unkown
in humans, but can be projected from LD_. data

? : 29 :
compiled on other mammals. Selected information on
herbicide toxicity was compiled by Heikes (1967) and is
Summarized in Table 3.

TABLE 3 - Relative Toxicity of Herbicides to People

Common Name Some Common LD 0 Loxtceity
or Designation Trades Names “neg fe Rating
2G. L Various 300 3)
2,4-D Various 500 4
Aspirin* 750 4
Dicamba Banvel-D 1,040 4
Atrazine Atrazine 3,080 4
Table salt* 3,020 4
Amitrole-T Amitrole-T, Cytrol 5,000 ae
Picloram Tordon 8 ,200 5

*Aspirin and table salt are not used as herbicides.
These household compounds are included to give the reader
a reference point in studying this toxicity table.

TABLE 4 - Explanation of Toxicity Ratings

Toxicity LD Probable Lethal Dose
Rating Class teates for 150 1b. person

At Extremely toxic Less than 5 A taste (less than 7 drops)

2 Very toxic 5-49 7 drops - 1 teaspoonful

3 Moderately toxic 50-499 1 teaspoonful - 1 ounce

4 Slightly toxic 500-4 5999 IMounces= lepinta (1. 1ba)

5 Nontoxic 5,000-14,999 Pepinte—=)squart

6 Nontoxic 15 ,000- & above More than 1 quart

87

Maximum Possible Human Exposure to Auxin-Type Herbicides from
User by thetForest Service

The maximum use of herbicides in the 85 to 140-year rotation
of a timber stand would be as follows:

One treatment during:

Year | - Site Preparation
Year 3 = Release
Year 4, 5 or 6 = Release

The treatment may consist of a single auxin-type herbicide,
another type of herbicide, or a combination of herbicides
depending on plant species composition and the objective of
the treatment.

The time between treatments would not be less than 2 years
between site preparation and a first release application;
not less than 1 year between the first and second release
applications; not less than 85 to 140 years until the next
site preparation treatment.

Herbicides may be applied by hand or backpack to individual
plants for control of poisonous weeds. With treatment of
individual plants, the amount of herbicide applied per acre
will vary with the number of stems per acre. However, the
maximum application rate probably does not exceed 1 pound
per acre. Livestock will be removed from the area of
treatment prior to application. Removal of livestock would
be dependent upon the amount of danger presented to
livestock from the wilting of poisonous plants rather than
to any hazard from herbicide residues. A given section of
range would be treated with no less than 15 years between
treatments, and more normally with 20 years between
treatments.

2,4-D is used for range rehabilitation. It may be applied
aerially at the rate of 2 to 3 pounds per acre. Because a
range rehabilitation program involves the removal of
livestock from an area prior to application and for a period
of approximately one growing season following application,
the possibility of contacting 2,4-D residues is remote.
Range rehabilitation programs on a given area of rangeland
would occur at intervals of no less than 15 to 20 years.
Most rangeland in the National Forests would never require
any chemical applications at all.

In the right-of-way maintenance programs, the use of
herbicides is based on the needs of the individual area but
would not generally exceed one application per year on any
given area.

88

Soil Organisms. The soil contains a large and varied
population of bacteria, fungi, actinomyctes, algae,
protozoa, insects, earthworms, and arachnids. The
populations are measured in the millions. Their
activity varies greatly with temperature, moisture,
organic content, aeration, and soil texture. Soil
organisms are beneficial to higher plants and are
essential for decomposing vegetative matter and aiding
the nutrient cycle.

The reaction of the soil organisms depends on the
herbicide and conditions found within the soil. There
is no evidence to indicate that the herbicides used,
when applied at recommended rates, will have any lasting
effects on soil organism populations (Bollen 1961).
Analyses of herbicide treatments at Eglin Air Force
Base, Florida, showed population levels of soil
micro-organisms to be the same on treated areas, three
years after spraying, as those found on adjacent control
areas of similar soil and vegetation (Young 1974).
Investigation of 2,4-D on penicillia mycelial dry weight
and total nitrogen content revealed both decreases and
increases, depending on pencillia investigated and the
concentrations of 2,4-D used (Pandey 1975).

In another study of 2,4-D with soil microflora soil
microflora enzyme systems were found to adjust, either
through mutation or selection (or both), and to utilized
2-4—-Deasmantoodssource, wAt tirst, thes2,4—-Dr°was ‘slow to
degrade. After 12 days the degradation accelerated with
no 2,4-D detected 6 days later. Successive additions of
2,4-D were completely degraded in 1 to 4 days (Audus
1964).

Some acceleration of nitrificaton was observed in soil
treated with atrazine, but the total production of
nitrates did not increase. During 4 years of applying
atrazine at a rate of 5.4 lb/ac, no change was found in
the number of micro-organisms in the soil, regardless of
the medium used for micro-organism determination
(Balicka and Sobieszczanski 1969, Balicka 1969).

During 4 years of applying linuron at 5.4 lb/ac, no
change was observed in the number of micro-organisms in
the soil; however, linuron caused apparent changes in
the composition of micro-organisms associated with roots
of treated plants. Linuron did not cause any change in
nitrification of the soil, but cellulose decomposition
in soil was impaired. (Balicka 1969).

The herbicide picloram at levels of 100 ppm had no
measurable effect on populations of bacteria and fungi
found in the soil, and it did not reduce nitrification
(Goring et al., 1967).

89

Simazine applied at 2-4 1lb/ac for weed control, did not
significantly affect the relative numbers of fungi and
bacteria in soil or the growth of some fungi (Eno,
1962). Farmer, Benoit and Chappell (1965) noted
inhibition of nitrification with simazine at
concentrations of 6 ppm or greater. Other investigators
observed some acceleration of nitrification in soil
treated with normal application rates of simazine, but
reported no increase in total production of nitrates
(Balicka 1969).

Vegetation

a. General: Herbicides are used to elicit a certain
response from the vegetation. This response is
measured by the immediate reaction of target pests
to the herbicidal action of the chemical used. The
response is also measured in long-term composition
changes produced within the vegetation. A variety
of herbicides, formulations, applicaton techniques,
and timing are used to achieve the desired effects.

A new plant community quickly appears following the
initial loss in plant numbers after an herbicide
treatment. The new community is different in size
and age, and may have a greater variety of species,
especially in the grass-forb community. The
wildlife and bird populations show a similar
change. Desirable plants, once in a subordinate
position, can now move to a dominant position. The
objective of vegetation management is to maintain
this new plant community once it consists of plant
species desirable to the resource manager.

A short-term vegetation impact of herbicide use is
the immediate reduction in the number of plants on
the treatment area. As vegetation metabolizes and
absorbs the herbicide, the chemical make up of an
individual plant species may change. Willard (1950)
reported that 2,4-D altered the palatability of some
plant species to animals. For example, livestock
would eat Canadian thistle, velvet-leaf, jimson
weeds, wild parsnip, sunflowers, round-leafed
mallow, and other unpalatable weeds. The ragwort
weed, highly toxic to cattle, had a marked increase
in sugar content after treatment with 2,4-D. This
made the plants attractive to cattle, but they were
still highly toxic. Normally, livestock and
wildlife will not feed on ragwort unless forced to
do so.

After the treatment of weed species with sublethal
concentrations (0.25 lb/ac) of 2,4-D, potassium

90

nitrate content declined from 44 percent to 6
percent in five species, and increased from 12
percent to 47 percent in the other four species
(Frank and Grigsby, 1957). The plant species were
sufficiently toxic to cause nitrate poisoning in
livestock, if they were consumed in large enough
quantities.

Fifteen days after black cherry brush had been
treated, until wet, with a 2,4,5-T concentration of
2,000 ppm, Grigsby and Ball (1952) reported
hydrocyanic acid content was reduced 85 percent.

Silvex, at 2 ppm, had no adverse effect on either
phytoplankton or zooplankton, which were at the base
of the food chain in small test ponds (Cowell, 1965).

Very little of the herbicide which reaches the
vegetation is metabolized. Rain washes much of the
herbicide left on the plant surface to the forest
floor. Some herbicides are passed through the plant
and excreted by the roots into the soil. The
remaining herbicides and breakdown products will
eventually enter the soil, either in leaf fall or
decomposition of dead stems and roots.

In the Elgin Air Force Base tests, a sample area,
measuring 1 square mile, received a total of 345,117
pounds of herbicide between 1962 and 1970 (Young
1974). A comparison of vegetative cover and
occurrence of plant species on the area between June
1971 and June 1973 indicates that areas with 0-60
percent vegetation cover in 1971, had a coverage of
15-85 percent in June 1973. The rate of change in
cover seemed to depend on soil type, soil moisture,
and wind. There was no evidence to indicate that
the existing vegetation coverage was in any way
related to herbicide residue in the soil;
dicotyledonous or broadleaf plants, normally
susceptible to damage from herbicide residues,
occurred throughout the entire test area. In

1971, 74 dicotyledonous species were found.

Favorable effects of herbicide use can be seen in
the survival and growth of preferred plants. The
benefits are measured in increased food, forage,
fiber, wildlife, and maintenance of existing
physical structures. In other cases, the beneficial
effects are shown by the removal of target plants
which are poisonous to humans or animals.

Wilde (1970a, 1970b) calculated that pine

plantations in Wisconsin require about 331 gallons
of water to produce 2.2 pounds of merchantable wood,

al

whereas evapotranspiration of ground vegetation
consumes about 23.5 gallons of water per 2.2 pounds
of oven-dry tissue. In turn, each 2.2 pounds of
weed biomass in the plantations reduces wood
production by 0.15 pounds throughout the years.
Therefore, timber growth in plantations with a heavy
cover of shrubby plants may underproduce more than
15 cords per acre over a 40-year rotation, or more
than a 1/3 cord per acre per year. At current
stumpage prices, pest plant control is apparently an
excellent investment, and likely to be more
important in the future.

In other Eastern Region growth studies, diameter
growth in a 7-year-old Wisconsin red pine plantation
increased 30 percent the first year after herbicide
application, and 8 percent the following season.
Height growth increased 13 percent the second year.
When shrub competition was eliminated in another red
pine plantation, growth increased by 300 percent.

In Minnesota, conifer plantation studies show more
seedlings were killed by competing vegetation than
any other factor (Dawson and Noste, 1976).

Hardwood plantations seem to respond even more
dramatically to competition control. Studies with
Populus showed a 425 percent growth increase after 4
years of complete vegetation control in a
plantation, compared to only clearing a b2-10cn
square around each tree. In investigation involving
silver maple, white ash, white pine and white spruce
in fertilized plots, the 3-year growth increase for
complete vegetation control ranged from 750 percent
for white ash to 37 percent for white spruce. These
results demonstrate the benefits which can be
realized from vegetation management (Dawson and
Noste, 1976).

Endangered or Threatened Plant Species. Vegetation
Management under six ‘of the seven alternatives
considered would probably affect endangered or
threatened plants if they were in the area being
treated. The alternative with little or no effect
would be the "No Action" alternative. Broadcast
treatments are more likely to unintentionally damage
unknown populations of such plants, than are
selective treatment methods. Herbicides are no
exception. The sensitivity of all plants to the
various herbicides is not known. It must be
assumed, however, that an herbicide application to
an unknown endangered or threatened plant will have
an adverse effect upon its population, but has never
been known to completely eliminate any species
because kill is never 100%.

92

The Endangered Species Act of 1973 directs the
Secretary of the Interior and Secretary of Commerce
to determine which species are endangered or
threatened and to publish them in the Federal
Register. The proposed list contains some 1,700
plants found in the United States. Forty of these
plants are found in the 20-State Eastern Region. At
this time, only three have been found on National
POrest@rands, sand:al. in 1) linois,

5. Forest Vertebrate Animals

a.

General. A wide variety of wildlife species inhabit

the National Forest land of the Eastern Region. The

survival needs of some species, such as the
Kirtland's Warbler, are very specific. Animals like
the bear or skunk are adaptable to a wide range of
foods, habitat conditions, and disturbances by man.
Proposed herbicide applications will occur on areas
occupied or visited by a significant number of these
easily adapted species. The wildlife impacts of any
herbicide application project depend on the wildlife
species present, the herbicide used, the size of the
area treated and long-term resource management
objective for the treated area. Routine activities
of individual wildlife species may result in
contacts with treated vegetation, soil or water, or
ingestion of treated food. Under forest conditions,
such exposure has not proven hazardous to wildlife.

Mammals. A hazard could occur to mammals, if they
are exposed to an acutely toxic dose of herbicide.
The acute oral toxicity of a single dose of the
phenoxy herbicides to mammals ranges from 100 mg/kg
to 2000 mg/kg, depending upon the test animal and
the particular chemical or formulation. The
herbicides are absorbed after ingestion, transported
via the plasma, concentrated in the kidneys, and
rapidly eliminated in the urine (Cast Report 39,

eh ioW ke

Controlled feeding trials and laboratory tests have
shown some herbicides to be toxic, teratogenic,
carcinogenic, or mutogenic to mammals. LD_., rates
have been established for most chemicals available
to man. The dosage rates used in controlled
experiments are not reached under conditions found
with normal forestry herbicide applications.

An evaluation of wildlife populations, following
massive field applications of herbicides at Elgin
Air Force Base, showed no difference in mouse

population densitities on herbicide treated areas

93

and control areas affording comparable habitats.
Mice collected on the treatment area were allowed to
breed in the laboratory and there were no birth
defects observed in the offspring. There were no
adverse impacts on reproduction of beach mice after
30 generations were exposed to TCDD. Post-mortem
examination of mice, rats, snakes, and a toad showed
no damage to liver, kidney, and gonadal tissues, and
no cleft palates. Observations of five fox kits
born and raised in a den within the spray area found
all kits to be apparently healthy and normal, even
though their mother had been observed on the test
area for a year. This fox family lived in the
middle of the heaviest sprayed area, where
back-to-back, day-to-day applications of 27 pounds
of herbicide per acre were made.

One significant finding of the Elgin Air Base
studies was that rodents showing no evidence of
physical abnormalities after gross and microscopic
examinations did show a TCDD like chemical, in fat
tissue and livers. The levels of TCDD like
chemical, 210-540 ppt, encountered would be suspect
to teratogenic or pathologic abnormalities.
However, defects were not found in either the
animals tested or the progeny of those that were
pregnant.

Cottontail rabbits, given a choice of either 2,4,5-T
treated vegetation or untreated vegetation ate
almost none of the treated vegetation (Springer
1957). Deer allowed to browse 2,4-D and 2,4,5-T
areas sprayed to improve deer browse showed no
preference for either untreated or herbicide
stimulated branch growth (Krafting and Hansen,
1963). Test animals are often repelled by herbicide
residue on their natural foods. When only limited
areas are treated, as proposed in the Eastern
Region, very few animals will be forced to feed
solely on food contaminated with herbicide.

Newton and Norris (1968) found that deer exposed to
feed treated with maximum field applications of
2,4-D, 2,4,5-T, and atrazine did not accumulate
significant amounts of herbicide. Forty-three days
after exposure, the muscle tissue of the deer showed
residue of 2,4-D and 2,4,5-T at less than 0.006

ppm. Atrazine levels could not be detected after 44
days. This study, the U.S. Department of Health,
Education,and Welfare's Food Basket studies of meat,
fish, and poultry, and EPA supported beef fat
monitoring programs all point out that herbicides
proposed for registered use in the Eastern forests
do not contaminate meat used for human consumption.

94

A more subtle and long-term impact of vegetation
management is its effect on wildlife habitat.
Vegetation management by herbicides is no

exception. It affects the vegetative layering of
the treated area and the species of plants making up
the replacement community. Because many wildlife
species habitat needs are very specific, some
animals will be adversely affected while others will
benefit. Westing (1971) found that as the vegetation
replacement community becomes established, the
original set of animal populations will be replaced
largely by a different set with lesser diversity.
The replacement animals ‘will have higher numbers
with fewer species, many of them new to the sprayed
area,

The greater the number of plant species controlled
at any herbicide site, the greater the impact on
wildlife habitat. The method of herbicide
application, broadcast or selective, also influences
this impact. Herbicide use generally sets
vegetation succession back to an earlier stage.
Small mammals, with limited home ranges or very
narrow habitat tolerances, will be most affected by
the thoroughness of individual herbicide

treatments. Large mammals like the moose, deer, or
bear benefit the most, as food availability and food
nutrition are improved within their home range.

Even small treatments that remove all mast producing
hardwoods will have an adverse effect on squirrels
and other mammals depending heavily on mast for food.

A 19-year study of selective vegetative management
in Pennsylvania showed a diversity of food plants,
useful to wildlife, developed on the sample
right-of-way following spraying. These plants
included common herbs of the Forest, as well as
invaders usable as food by many animals. Woody
plants were found interspersed throughout the
treated area. The taller, woody plants were found
to supply food throughout the year and were of
particular value as emergency food when deep snow
covered the ground. The right-of-way was used
heavily by such common wildlife species as
white-tailed deer, rabbit, grouse, and wild turkey.
A special study was made of the white-tailed deer on
the right-of-way and showed consistent and heavy use
in all seasons. This indicated that attractive food
and cover had been developed (Bramble and Byrnes,
19720:

Herbicides are the most effective vegetative control

method currently available for use. However, most
vegetation species are only controlled for a period

oh)

of time, and then return shortly to the treated site
unless controlled periodically by man or suppressed
by host plants. Wildlife biologists have long known
this, and manipulate vegetaton diversity and
manatain wildlife openings with herbicides to
benefit a variety of animals.

The activities of man and equipment during herbicide
applications will disturb wildlife. Large animals
will be able to leave the site temporarily, while
small mammals will head for cover or go underground.
This disturbance can have a serious impact if it
occurs during mating or at the time of birth.
Adverse impacts on wildlife, following herbicide
applications in the forest, have been found to be
local in nature and to cause fluctuations in animal
population. This occurs because of changes in
specific ecological niches, and not because of toxic
harm to the wildlife.

Birds. Herbicides have been found to be generally
less toxic to birds than mammals. The acute oral
LD, for the most common forms of game birds found
in the Eastern Region have ranged from 300 mg/kg to
greater than 5000 mg/kg. The LC,, for these birds
which were fed with herbicide treated feed is
typically greater than 5,000 ppm. Under field
conditions, a bird would Lave to consume daily all
the herbicide applied aerially to approximately 10
acres to duplicate the 5,000 ppm fed under
controlled trials.

Herbicide treated feeds, at rates lower than the
LD, or LC, 4 have affected the reproduction of

oe birds. Feeding trials found that 2,4-D, when
fed at daily rates of 1,250 ppm and 2,500 ppm,
depressed mallard duck reproduction. Mallard ducks
which were fed 2,500 ppm and 5,000 ppm of silvex
daily showed a nearly 100 percent reduction in
reproduction (USDI, 1970a). Both amitrole and
dalapon depressed mallard duck reproduction levels
25 percent less than those which produced mortality
(USDI, 1962).

Bramble and Brynes (1972) found wild turkeys used
right-of-way areas which had been treated with 2,4-D
and 2,4,5-T. The young turkeys were attracted to
the openings to feed on the various insects which
were more abundant on the grassy right-of-way than
within the wooded areas. Ruffed grouse numbers also
increased. The grouse were found on the edges,
within 150-200 feet of the right-of-way, rather than
on the right-of-way itself. This emphasizes the
importance of using herbicides to create an edge
effect.

96

Aqueous solutions of 2,4-D, picloram and 2,4-D, and
2,4,5-T, equivalent to 10 times recommended field
concentrations, were sprayed on fertile pheasant
eggs preceding incubation. None of the treatments
were found to have any adverse effects on hatching
success, or increase the incidence of malformed
embryos or subsequent chick mortality when compared
to water-sprayed control eggs. Herbicide
contamination was found to facilitate weight gain of
roosters from 0-4 weeks of age, while hens failed to
show a response. Residue analysis verified
herbicide deposition on the shell and entry into the
egg (Sommers and others 1974).

Insect feeding woodpeckers and tree cavity nesting
birds benefit from herbicide projects which leave
dead trees standing in the forest. These standing
cull trees can have many long term benefits to a
variety of birds.

Fish and Amphibians. The toxicity of herbicides to
fish 1s highly variable, and affected by chemical
formulation, water pH, temperature, water hardness,
oxygen content, suspended organic matter, and
dilution rate. The lakes, ponds and rivers of the
Eastern Region contain an abundance and variety of
both warm and cold water fish. These fish are
important as a sports fishery and contribute to the
commercial fisheries of the Region. The harvesting
of frogs is popular in the Ozarks and Midlands.

For the phenoxy herbicides, the LC 0 values range
from less than 1 ppm to more than 2°00 ppm in water
(one pound of herbicide active ingredient on an
acre-foot of water is equivalent to 0.370 ppm).
These values are equivalent to treatments of
10-10,000 pounds of phenoxy herbicide per acre in a
pond 4 feet deep; much higher than the 2-3 pounds of
herbicide active ingredient allowed for aerial
application over land by most label use directions.
Those phenoxy herbicides registered for aquatic weed
control are used at rates designed to keep water
residues below the 0.1 ppm level (CAST Report 39,
1975).

Schultz and Harman (1974) investigated the effects
on fish when 2,4-D was applied directly to water.
Rates used were 2, 4, and 8 lbs per acre. Only 7
percent of the fish, analyzed 28 days or more after
treatment, contained detectable 2,4-D residues; and,
only 1 percent (one fish) of those analyzed 56 days
or more after treatment contained detectable
residues. If tolerance levels are based on the

ey)

level of the parent compound only, it would appear
that fish could be consumed 1 month after

treatment. They also found little danger of
bio-magnification of 2,4-D in the aquatic food
chain. It was noted, however, that when fish were
exposed to radiated 2,4-D, radioactive compounds
were present in all fish tissues examined. Degraded
2,4-D products were also evident for as long as 84
days after some treatments. Therefore, the identity
and potential toxicity of these degraded products
must not be overlooked. However, EPA requires the
herbicide registrant to provide this data as well.
In general, the degraded herbicide is) less ttoxic
then the prevent herbicides.

The ester formulations of phenoxy herbicides are
often more toxic to fish than amine or metalic salt
formulations. This is probably due to the more
effective penetration ability of esters.

A review of Ecological Effects of Pesticides on
Non-Target Species found that chemicals can give an
off-taste or even toxicity to fish consumed by
humans. At some concentrations, herbicides will
cause liver degeneration, testicular degenerative
lesions, and abnormal spermatozoa in fish; the most
sensitive fish, exposure, herbicide combination
listed was: bluegills exposed for 48 hours to 0.50
ppm of 2,4,5-T acid. There seems to be a
considerable margin of safety, considering the
herbicide contamination concentrations found after
forest herbicide treatments.

The algacide copper sulfate, used for aquatic weed
control, has been found to have a small margin of
safety for fish. Trout, the most sensitive,
tolerated only 0.14 ppm, while smallmouth bass,

the least sensitive, could tolerate a dosage of

2.0 ppm. However, the algacide endothal has been
found to have a wide margin of safety for fish when
used at rates recommended on the label (Pimentel,
LOH).

The effects of herbicide use on amphibians have not
been widely investigated. The major impacts would
possibly be on frog egg and tadpole development.

Endangered and Threatened Animal Species. The
Forest Service does not have direct authority for
management of endangered and threatened animal
species. The agency's major contribution to
preserving any wildlife species on official State or
Federal lists is through critical habitat management.

98

The U.S. Department of Interior, in consultation
with the States, is charged under the 1973
Endangered Species Act with completing and
Maintaining official lists of wildlife species that
are classified as endangered or threatened. The
Forest Service will adopt these official lists and
may expand on an individual Forest basis as a means
of protecting unique wildlife species. Each
proposed herbicide project will be analyzed for its
direct impact on any threatened or endangered animal
species for any habitat loss or modification that
might occur.

6. Forest Invertebrate Animals

a.

General. The number of invertebrates per acre in a
forest environment can only be estimated, and would
be listed in the millions. The Forest Service is
interested in the impact of herbicide use on
invertebrates, because these animals are an
intricate part of a forest community. Invertebrates
are also important because they are food for the
vertebrates; thus, they can be an early indicator to
potentially dangerous food chain build-ups.

Insects. Several studies have been made of how
herbicides affect insects. Most of the studies to
the aquatic or soil life stages of the insect, and
not to the adult stage. No significant hazard to
insects is expected as a result of acute toxicity
from proposed herbicide use at EPA regulated
application rates.

The following species of bottom-dwelling organisms
were reduced by 50 percent or more, after an
application of 2,4-D ranging from 1 ppm to 4 ppm:
mayfly nymphs, horsefly nymphs, common midges,
phantom midges, biting midges, caddice fly larvae,
and water beetles. Simazine, at 0.5 ppm to 10 ppn,
produced similar results, as did atrazine at 0.5 ppm
to 2 ppm. Water monitoring samples taken from
potholes immediately following a 1971 spray project
in the Lake States showed a concentration of

.050 ppm of 2,4-D. Mosquito larve, in water treated
with 2,4-D at a rate of 100 ppm, showed 60 percent
fewer larvae than in the control reached the pupal
state (Smith and Isom, 1967). This study added
further evidence that 2,4-D is relatively non-toxic
to some invertebrate species.

Honey bees have responded in different ways to 2,4-D

exposure. In one investigation, honey bees
decreased by 22 percent, following a 3 lb/ac 2,4-D

o9

treatment in fields they were using. However,
dusting bees with 2,4-D did not cause any mortality
(Palmer-Jones, 1964). It is not known if the
toxicity observed in the field was due to jig isa,
dissolved in the nectar or to the production of a
toxic metabolite secreted by the plant into the
nectar.

The insects in the Elgin Air Force Base herbicide
test grid were sampled in 1971, following completion
of spray activities, and again in 1973. A much
greater number of small to minute insects were taken
in the 1973 survey. The two studies showed
similarities in the insects distribution pattern at
it related to the vegetation, number of insect
species, and insect diversity. Generally, the 1973
study showed a reduction of the extremes found in
these parameters during the 1971 study, possibly due
to insect succession following vegetation succession.

Chansler and Pierce (1966) reported that cacodylic
acid injected at a rate of 1 to 2 ml per injection
at 2-inch intervals around the trunk of trees killed
bark beetles. The trees were injected with the
herbicide soon after the beetles had attacked the
tree and before most of the eggs had hatched. The
beetles died before constructing their egg
galleries. Some of the eggs failed to hatch, and a
high brood mortality occurred. Excessive moisture
in the phloem, following herbicide injection, has
been found to cause severe brood reduction.
Cacodylic acid has been screened as a insecticide.
It has exhibited no insecticidal properties when
applied as a contact spray to insects.

Benefits to some insects, especially honey bees,
increase as plant succession is changed to
conditions favoring flowering forbs. Other
investigations show insect populations can increase
following herbicide treatment due to the increase in
organic matter which results from the decay of
controlled plants.

Crustaceans and Mollusks. Detectable residues of
herbicides do not appear in surface waters, unless
the chemicals are directly added to the water, or
fall there incidental to spraying forest vegetation,
or are added to control aquatic vegetation.
Detectable herbicide residues are not expected to be
found in the silt of forest waters either. When
herbicide residues have been found in silt outside
the forest area, it has been attributed to wind
blown erosion from bare soil treated with
herbicides. With the forest conditions present and

100

precautions taken, in the Eastern Region,
crustaceans and mollusks in or near the National
Forests are not expected to be exposed to any
residue from a herbicide project.

Should an accident occur during treatment or
metrological conditions cause contamination of
forest water, the concentration in the water would
be expected to fall below detectable levels in a few
days. Such residues are diluted through stream
flow, decomposed by sunlight, or destroyed by
micro-organisms.

Oysters, crabs, mussels, and a wide variety of other
crustaceans and mollusks are not directly affected
by the phenoxy herbicides at rates approved for
direct application to water. Since 1971,
concentrations of from 0-16 ppb of 2,4-D have been
found during actual forest water sampling in the
Eastern Region; however, this is much less than
herbicide concentrations approved for direct water
application.

Tests with dicamba in a model aquatic ecosystem,
clearly show that dicamba or its metabolites did not
accumulate in the clams, crabs, or snails examined
(Sanborn, 1974).

Bulter (1963) found exposure of oysters to 2.0 ppm
of 2,4,5-T for 96 hours had no effect on shell
growth. Brown shrimp exposed to 1.0 ppm of 2,4,5-T
for 48 hours showed no harmful effects. Similar
tests using silvex did, however, show some growth
loss and mortality or paralysis.

SOCIAL ECONOMIC COMPONENTS

The fact that herbicides are widely used on private
rangelands and pasture, on private forests, for a variety of
utility and highway right-of-way needs, on home lawns, and
on food crops is ample evidence that they are efficient and
inexpensive when compared to available alternatives.
Herbicides have not been found to have serious unintentional
side effects when used under forest conditions following
approved use directions. Where vegetation control is
needed, herbicides usually have less harmful side effects on
the environment than alternative control methods.

Favorable effects of herbicide use are production and
protection oriented, and improved economic welfare and
community stability are the results. Public and private
forest benefits are measured by increased timber volume and
value, increased forage for domestic livestock, improved
wildlife habitat, increased recreational opportunities, and
reduced cost of facility maintenance.

LOU

Such forest resources as timber, forage, wildlife, and
recreation are all renewable resources. They are also raw
materials or basic materials for use in later manufacturing
processes. Forest products are at the beginning of the
commodity production process; money paid for them tends to
stay in the local area, more so than dollars spent in
communities based on secondary or later stages of
manufacture.

The number of people needed for primary resource production,
however, is not as great as the number of people required
for the secondary manufacturing processes.

Hunting, fishing, and recreation opportunities bring income
into National Forest areas. This income is from the
purchase of goods and services. An increase in forest
visitors can be accommodated without requiring a
corresponding increase in community expenditures for local
government, schools, Sanitation, etc., that new permanent
residents require. Counties in which National Forests are
located receive a share of National Forest receipts, and may
receive additional payment in lieu of property taxes. The
amount of the National Forest receipts shared by the
counties in the Eastern Region for Fiscal Year 1975 was
$25,946,500:

Aerial herbicide applications are the least labor intensive
of the herbicide application methods used. Ground methods
of application, especially cut surface and basal stem
methods, employ more people. A reduction in the use of
herbicides and a move to more manual vegetation control
would provide longer or increased employment needs for
laborers, (if available and assuming they would work at such
tasks) resulting in a favorable short-term economic impact
on the local communities. A long-term adverse local
employment and economic effect would occur with the
reduction in usable resources and future availability.
Nationally this would result.in an increased cost to the
taxpayer. Consumers would feel little impact under the
assumption of constant total output. If a constant total
out put was not maintained, however, a strong increase in
consumer price would occur with only a small decrease in
output.

HERBICIDE TOXICITY
l. 2,4,5-T

In the following dicussion, the toxicity of 2,4,5-T will
be discussed first, followed by a separate discussion on
the toxicity of TCDD. In these discussions of toxicity,
as in subsequent discussions the carcinogenic,
mutagenic, embryo-toxic, and teratogenic potential of

102

2,4,5-T, many laboratory studies will be cited. These
studies are useful in indicating that a compound may
have the potential for biological activity when
administered at high dosages or for prolonged periods.
The important consideration is whether or not such
potential would be realized under field conditions;
whether the necessary dosage level and/or period of
exposure would be achieved under forest or rangeland
applications.

Acute Toxicity

LD 0 (lethal dose of 50 percent of the test animals)
Paes fore2,4,o51beare given in Table 5.

TABLE 5 - Toxicological Information on 2,4,5-T (Harvey

1975)

LD.) ng/kg
Animal Body Weight
Mouse 389
Rat ; 500
Guinea pig 381
Dog + 100

Rowe and Hymas (1954) have published a more extensive table
of of LD_, values for various species exposed to different
formulations of the phenoxy herbicides (see Table 6). They
conclude that the LD values for 2,4,-D and 2,4,5-T and
their common derivatives are the range of 300 to 1,000 mg/kg
forethbe rat, mouse, guinea pic®and rabbit..." In this
study, dogs wre found to be "somewhat more susceptible" and
chicks more tolerant than the species designated above.

Norris (1976a) has reported acute toxicity values Table 7 in
general agreement with those of Rowe and Hymas (1954).
Norris concludes that "the non-effect or threshold level for
an acute toxic response, however, is unlikely to occur in
the forest environment."’ The following section (Fate of
2,4,5-T in the Environment) will discuss the probability of
human exposure to a toxic dose of 2,4,5-T resulting from
application in a forest environment.

Additional information on the toxicity of 2,4,5-T comes from
experimental studies on humans and reports from residents
living near sprayed areas.

Five human volunteers ingested a single 5 mg/kg dose of
2,4,5-T. At this dosage rate, which far excess the amount a
single person would be likely to encounter in a forest
environment, all of the 2,4,5-T was absorbed into the body
and excreted unchanged via the urine. Subjects did not
present any detectable clinical effects (Gehring et al.
1973):

103

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In a similar study, Kohli et al. (1974) reported on
absorption and aroretuon of 24,575 10 people. Of eight
male volunteers, one volunteer took 2 mg/kg, another 3 mg/kg,
and the remaining six volunteers took 5 mg/kg 2,4,5-T. The
authors-found that “2,4,5°1 is readily absorbed from the
gastrointestinal tract and eliminated unchanged from the

body mainly via the kidneys.'' The authors reviewed data

from other studies on the metabolism-of 2,4,0-© in zother
animal species. They conclude:

In general the pattern of metabolism of 2,4,5-T
in man seems to be similar to the various animal
species that have been studied. The comparison
of pharmacokinetics indicates that man falls in
between rat and dog... It will be therefore
justified to speculate that 2,4,5-T will have a
low toxicity in man. As suggested by the quick
rurn-over of the compound in man it would seem
that accumulation in the system would be
unlikely. Based on the kinetics of single dose
administration, Gehring et al. (1974) have
calculated the likely plasma concentration to
result on repeated exposure to 2,4,5-1 and have
concluded that plasma concentrations will reach
a plateau after 3 days. Fear of cumulative
toxicity may therefore be remote.

Shoecraft (1971) reports that, after repeated spraying of
forest lands near Globe, Arizona with 2,4-D, 2,4,5-T, and
silvex, humans suffered from swelling of eyes, arms, legs,
parts of the skin turning dark and purple, loss of hair and
eyelashes, problems with vision, inability to talk or
swallow, back pain, nose bleeds, inability to walk without
limping, rashes, nausea, and muscle spasms. Investigations
of the incident by a team representing various professions
concluded that neither the incidence nor type of human
eiinesses in Globe were different from what would be
normally expected in other similar communities (Tschirley
1970). Therefore, it is questionable that herbicides
"cause" the illnesses.

An anonymous "Herbicide Spray - Fact Sheet" references Acres
U.S.A., February 1975, as reporting: "The Women's Center
Committee on the Environment, Fayetteville, Arkansas,
reported that in Arkansas, a field was sprayed with 2,4,5-T
above a spring supplying 20 people; six out of eight babies
conceived there miscarried, one severely deformed with a

cleft head and no legs."' No documentation or verification
of this report is presented from scientific literature.

C.A.T.§. (Citizens Against Toxic Sprays, Inc.) (1976)

associated spring herbicidal sprays and the use of 2,4-D,
2,4,5-T, and silvex with lung ailments in forest valley

106

residents and unusual uterine bleeding, gynecological
problems, higher incidences of spontaneous abortions, and
birth defects in offspring. No documentation or
verification of this report is presented from scientific
literature.

Chronic Toxicity

Chronic toxicity data for 2,4,5-T is given by Norris (1976a)
(Table 8). The values reported to cause chronic toxicity
are far above those likely to be encountered in a forest
environment (see following section on the Fate of 2,4,5-T in
the Environment).

Additional data on chronic exposure comes from examining
data on occupationally exposed herbicide workers. Pesticide
applicators are routinely exposed to 2,4,5-T through their
occupation. One study showed a significant increase in
chromosomal breaks when workers were exposed to herbicides.
Between herbicide application seasons, the incidence of
chromosomal breaks was significantly lower than the
incidence in an unexposed population. This data does not
seem to suggest an overall adverse effect, but may imply
that a repair mechanism can compensate for previous exposure
(Yoder et al 1973). 2,4,5-T was the least frequently used
agent and it is not likely that any observed effect could be
attributed to it. In another study, Swedish railroad
workers exposed to the phenoxy herbicides 2,4-D and 2,4,5-T
had a normal incidence of tumors and mortality (Axelson and
Sundall 1974).

107

TABLE 7 - Acute Toxicity of neve!

ES Lee

Organism 2 ,4-D Dleome Amitrole Picloram
Birds:

LD 0° mg/kg 360-2 ,000 300 2 ,000+ 2,000+

No effect, ppm2/ 7203 6003/ 2,000t3/ 1,000
Rodents:

LD.,, mg/kg 375-800 400-950 5 ,000+ 2,000+

No-effect, ppm2/ 1,500 3003 2,000+3/ 3,000
Ruminants:

LDe me 400-5 500-15 000 = ga=-—-— 2,000

BE aly eel 002 eee 2,0003/
Other mammals:

LD.,, mg/kg 100 100 LOO 4d ies per

Nogffect, ppm2/ 500 2003/ 000k eee
Fish: Al

TL_, ppmt 1-60 1-30 325 13-

waa eceee ppm>/ 0.16/ 0.18/ 326/ 1 oe!
Other Aquatics:

TL. ppm: 1-5 055-50 20 1+

No“effect, ppm2/ 0.16/ 0.056/ 2 / 0.16/

en

1, list of references for specific values in this table is available
from the author.

2 concentration in diet for a limited exposure which causes no acute
effect.

LU sires daily food consumption is 10 percent of body weight and that
20 percent of LD. 9 in daily diet has no acute effect.

oO oet our median tolerance limit, i.e., the concentration of herbicide
in the water which will kill 50 percent of an exposed population of
aquatic organisms in 48 hours.

elconcent ra aten in water which has no acute effect following 48 hours'
exposure.

6/

—'Assumes 10 percent of TL has no effect.

From: Norris, 1976a.

108

Herbicides
and
organism

PotD:
Mule deer
Cattle
Sheep

15 (1 Ss al
Dog
Cattle
Sheep

Amitrole:
Rat
Rat

Rat

Picloram:
Sheep
Dog
Rat
Quail

TABLE 8 - Chronic Toxicity of Herbreides= |

Equivalent
concentraf$jon
Dose in diet— Duration Effect
mg/kg ppm days
240 2,400 30 Slight
50 500 As Be None
100 1,000 481 None
10 100 90 None
125 200 I None
100 1,000 481 None
a 503/ 476 None
a 100 3/ 730 Thyroid adenomas
& adenocarcinoma
-- 500 3/ 119 Normal
followed by thyroid
14 days no
amitrole
110 1,100 30 None
150 1,500 730 None
—— 1,0003/ 90 None
oe 5003/ 3 generations None

>

—'A list of references for specific values in this table is available
from the author.

Eee sames food intake is 10 percent of body weight per day.

3)

—Actual concentration tested.

erom: Norris. 19/6a.

109

Effects of 2,4,5-T_Upon Reproductive Functions

All chemicals are presumed to cause toxic effects upon the
developing embryo if they do not cause the death of the
mother first. Chemicals can become available to the embryo
in spite of the mother's excretion and metabolism
capabilities. The embryos would have to be susceptible to
the chemical, that is, in a stage where the chemical could
produce embryotoxicity.

Embryotoxicity is a generalized term covering manifestations
such as lethality, growth retardation, and teratogenicity.
Different chemicals may cause either fetal death or
teratogenic effects, or both effects may be found depending
on the size or the timing of the dose. Teratogens must be
present during the formation of the structures that the
particular chemical affects. The mother must be exposed to
a particular dose at a very precise time in her pregnancy to
produce a teratogenic effect.

The teratogenic potential of 2,4,5-T has received wide
publicity since 1969 when one company reported it as a
teratogen. Ailegations were made that its use as a military
defoliant had caused fetal malformations in the Vietnamese
population. The herbicide used by Bionetics Research
Laboratories, Inc., was contaminated to a high degree (about
30 ppm) with TCDD. Some studies confirmed the
teratogenicity of 2,4,5-T, but the implication of the
herbicide in any increase in birth defects in humans has not
been supported.

Levels necessary to produce a teratogenic effect would not
be expected as a result of the proposed Forest Service
treatment projects. Neither a sufficient dose nor a
sufficiently long exposure period could be achieved when
2,4,5-T is used as registered by EPA. The possibility of
exposure to a hazardous dose will be discussed in following
sections.

Carcinogenic and Mutagenic Potential of 2,4,9-1 and ICDD

Dost (1977) has summarized the relationship between
carcinogenicity and mutagenicity:

Probably the most important issue about any
chemical introduced into the environment by
human activity is the possibility that it may
increase the incidence of cancer in the human
population. The prcdability of mutagenic
activity is of almost equivalent concern,
both because of the possibility of genetic
alteration and because mutagenesis may be a

110

useful predictor of carcinogenic activity.
The relationship is by no means constant.
However, McCann et al. (1975) have assembled
data from a number of laboratories using
microbial systems ("Ames test") and find that
85% of known carcinogens are positive, 10% of
non-carcinogens are active.

Two previously cited studies (see Chronic Toxicity of
2,4,5-T) have not found either tumors or chromosomal
aberrations in herbicide applicators that could be related
to 2,4,5-T. There is no evidence that 2,4,5-T or TCDD is
mutagenic in 2,4,5-T production workers.

Pesticide and Toxic Chemical News (July 13, 1977) reports

yet unpublished research by Van Miller, Lalich, and Allen.
The report indicates that TCDD produced neoplasms in rats

fed 5, 50, and 500 ppt TCDD and at 1 and 5 ppb (mistakenly
reported as 5 ppt) TCDD.

Kociba et al. (1977 has also reported on a yet unpublished
feeding study. Dow's studies indicate that neoplasms were
produced when TCDD was fed to rats at the rate of 2,200 ppt,
but not at 210 or 22 ppt. Dow reports:

Dow's findings of neoplasms at 2,200 ppt support
the University of Wisconsin report of neoplasms
at 5,000 ppt, but the absence of neoplastic
response at 210 and 22 ppt appear to contradict
the University of Wisconsin report of neoplasms
at levels as low as 5 ppt.

One study suggests that TCDD may be a promoter of neoplastic
activity at levels greater than 1 ppt. At 1 ppt there were
no tumors. Further analysis is required to determine the
carcinogenic potential of 2,4,5-T.

The current effect level of 80 to 200 ppt TCDD in beef fat
set by EPA is based on demonstration of noncarcinogenicity.

Jensen and Renberg, 1976, have evaluated the cytogenic
effects of 2,4,5-T and 2,4-D by means of induced micronuclei
in erythrocytes of bone marrow. Additional chemical
analyses of the test substances reaching the target cells
was also performed. The data did not present reliable
indication of lack of mutagenic action, but did indicate
that the compounds do not seem to enter the cells to any
appreciable extent. The authors concluded that, "From the
point of view of risk estimation this lack of penetration of
the cells and the rapid excretion in mammals do not point to
any cytogentic hazard being connected with these herbicides."

Human Exposure to 2,4,5,-T

The hazard 2,4,5-T and 2,4,5-TP presents to humans (in light
of the foregoing data) depends on a person being exposed to

111

a hazardous dose of two factors: (1) The pattern of use of
the chemical, and (2) Its fate in the environment.

Fate of 2,4,5-T in the Environment

The application of 2,4,5-T results in spray residues in or
on vegetation, the forest floor, water, and air.
Additionally, smaller amounts of 2,4,5-T may enter the soil
or water as spray drift or as residues washed by rain from
foliage. Once an application has been made, 2,4,5-T and its
contaminant TCDD follow different pathways in the
environment.

Vegetation

2,4,5-T deposits on vegetation can only result from direct
application or drift. 2,4,5-T can be absorbed by plants
(Norris and Freed 1966a, 1966b; Hurtt et al. 1970; Morton et
al. 1967). Only 10 to 30 percent of the applied dose of
2,4,5-T and 2,4-D is actually absorbed into the foliage of
big leaf maple. Of the material absorbed, only five percent
or less is actually translocated from the absorbing organ to
other parts of the plant. This accounts for the ability of
big leaf maple to resprout from the roots after herbicide
application (Norris and Freed 1966a, 1966b). Any absorbed
2,4,5-T not translocated would be subject to degradation
either while the leaf remains on the plant or after it has
fallen to the forest floor. Some of the material not
absorbed by the plant would be washed from the leaf surface
by raring

Norris (1976a) has discussed behavior and impact Of 92,4 pose
in the forest. Data from Norris (1976a) are given in Tables
9 and 10. The tables indicate that high levels tof 25 455-1
would not persist on a variety of Forest plants or forage
grasses. Norris points out:

The resprouting of lush, succulent vegetation on
many spray areas within a year after application
is evidence of this fact. Residues of more than
a few parts per million of herbicide would
produce visible damage symptoms and/or prevent
such resprouting. We conclude, therefore, that
residues of this magnitude do not occur in this
vegetation.

Norris et al. (1977) examined samples of blackberries, vine
maple, Douglas-fir, grass, forest floor, and soil ‘for
2,4,5-T immediately after andl, 3, 6, and 12 months after
aerial application of 2,4,5-T isooctyl ester at 2 1b/A.

This sampling regime was repeated after a second application
12 months later." the authors found:

Initial concentrations of 2,4,5-T varied among

plant species from 11 ppmw in vine maple to 115
ppmw in grass. After 1 month, concentrations

a2

ranged from 0.5 to 11 ppmw; and after 1 year,
maximum residues were less than 0.5 ppmw.
Residues in understory vegetation were higher
after the second application probably because
of the reduction in overstory vegetation after
the first application. Herbicide residues were
not detected in samples collected 1 year later.

Comparison of the values given in this reference with those
previously cited for acute and chronic toxicity indicate
that there would be little or no chance of being exposed to
a health hazard from treated vegetation.

TABLE 9 - Residues of Herpicide! in Forage Grass.

Herbicide Residue
Time of Treatment

(weeks) 2,4,5-T2/
Sisal Abana «. eae DDO ener cern,
0 100
1 60
2 30
4 15
8 6
16 2
ape

Rate of appplication, salelb/acre .(iad2 kg/ha) :

2 date from Figure 4 of Morton et al., 1967. From Norris, 1976a.
areal 2:/
TABLE 10 - Residues of 2,4,5-T in Forest Vegetation— —
Months after application
Specimen 0 1 3 6 LZ 24
PRG SOT re as Ppa fo ie
Vine maple
(Acer circinatum) Vy a5 20250 0.20 0200 4 (0520
Douglas-fir 3/
(Pseudotsuga menziesii) Lael. 0 ©0530 0.50 0.20 O.=
Blackberries
(Rubus sp.) S$) Oe6— 0205 0.02 OU gue On
Grass
(Various species) 114 soe OT00 0.10 G210. 0:

Dorris etralasy 1975.
2/, lb/acre (2.24 kg/ha) as isooctyl ester applied by helicopter in April.

3/9 means less tha 0.01 ppm. From Norris, 1976a.

SS

Soil - The forest floor is a major receptor of herbicide
residues. Residues may result from aerial or ground
application of herbicides and from the fall of foliage
containing residues (Norris 1967). Herbicides in the forest
floor follow four pathways (Norris 1967a): (1) Volatilize
and re-enter the air; (2) be adsorbed on soil, mineral, or
organic matter; (3) be leached through the soil profile by
water; or (4) be degraded by chemical or biological merans.
Norris (1967a) reports that phenoxy esters appear to be
rapidly hydrolized to nonvolatile forms.

Adsorbed herbicides are not biologically available, although
small amounts may become available through adsorption.
Norris (1967a) describes the process of adsorption and
leaching:

Adsorption and leaching are processes which work
in opposition to one another. Adsorbed
molecules are not available for leaching, but
adsorption is not permanent, except for
pyridydilium derived type herbicides (diquate
and paraquate). The amount of herbicide which
is adsorbed is in equilibrium with the amount of
herbicide in the soil solution. As the
concentration of herbicide in the soil solution
decreases, more pesticide will be released from
adsorption sites....

Leaching is a slow process capable of moving
pesticides only short distances (Harris 1967,
1969)... Herbicides are generally more mobile in
soil than insecticides, because several are more
polar, but mobility is relative, and even the
movement of herbicides is measured in terms of
only inches or a few feet.

In leaching tests, Wiese and Davis (1964) found that 9 oo Tol §
bound in soil remained in the upper 6 inches of test columns
even after the application of 4.5 inches of water. It is
unlikely leaching will significantly reduce the amount of
herbicide in the forest floor.

The most important pathway for reducing the herbicide load
in the forest floor is degradation. In a laboratory study
Norris (1970) has established that 2,4,5-T, while more
persistent than 2,4-D, approached 90 percent degradation
after 4 months in red alder forest floor material. The
degradation rate of 2,4,5-T was not greatly influenced when
2,4-D was applied concurrently.

In a recent field study (Norris et al. 1977a), samples of
foliage, forest floor, and soil were examined for residues
Oe? . ame

114

Initially residues in forest floor were equivalent
Con0n 341 b/As2;4,5-— bothsshortly after the first
application and 1 month later. A 90% decline in
herbicide level occurred the first 6 months after
application, and less than 0.02 1b/A remained
after 1 year. Initial levels were 1.3 1b/A after
the second application which reflects decreases
in overstory vegetation after the first
application. The residue level decreased more
than 90% the first 30 days after the second
application and less than 0.02 1b/A remained 12
months later.

There was little leaching of 2,4,5-T from forest
floor into soil. No residues were found deeper
than 12 inches, and maximum residues did not
exceed 1 ppmw. Residue levels were generally
lower in soil after the second application.

After reviewing 11 references on the degradation of 2,4,5-T
in the soil under varying conditions, the EPA Advisory
Committee on 2,4,5-T (Wilson 1971) concluded that "Although
the rate of disappearance varies, there have been no reports
of carryover of 2,4,5-T from one year to the next indicating
that no build-up in the soil would result from recommended
rates of treatment applied annually."

Water - Herbicide entry into forest streams may occur
through three possible routes: (1) Subsurface water flow or
leaching; (2) overland flow; and (3) direct application and
drift. As discussed in the preceding section, leaching is a
relatively slow process which is unlikely to contribute
Significant residues to forest streams.

Abrahamson and Norris, 1976, have discussed herbicide entry
further.

Overland Flow--Runoff: Overland flow of
herbicides can occur only if overland flow of
water occurs. Hydrologists report that overland
flow of water is extraordinarily uncommon on
nearly all forest lands. The infiltration
capacity of forest lands far exceeds intense
rates of precipitation. There are areas, such as
roads, skid trails, and landings where some
localized overland flow can occur. These areas,
where the soil is compacted or bare of
vegetation, are scattered and can usually be
avoided during application. Field testing on
forest lands has verified that overland flow of
herbicide is restricted to localized events
involving bare, compacted, or water repellent
soils and litter immediately adjacent to streams

ES

and that the overland flow has shown marked
reduction in herbicide concentration in water as
it moves over uncontaminated soil.

Direct Application and Drift: Direct application
or drift of spray materials are the principal
routes of entry to forest streams. This is a
physical process, independent of the particular
herbicide applied which can be markedly
influenced by man. Herbicide concentrations in
forest streams which are in or adjacent to
treated areas range from nondetectable limits
(less than 0.001 ppm), to a maximum of 1 ppm,
with more than 99 percent of all values less than
0.01 ppm even when no particular effort is made
to avoid direct application to stream surface
with either ground or aerial application

methods. Research has shown that the location of
forest treatment units with a buffer strip along
the streams reduced maximum herbicide concent-—
rations in streams to less than 0.01 ppm with
residues detected for less than 1 day after
application.

These measurements were made immediately
downstream from treatment unit boundaries and,
therefore, represent maximum concentrations in
the stream system. Extensive monitoring of
present-day operational applications of herbicide
in forests show most applications do not result
in measureable concentrations of herbicide in
nearby streams. Improved formulations,
equipment, application technology, coupled with
an increasing awareness of the forest manager's
opportunity to prevent stream contamination with
herbicides are the reasons for these successful
programs.

2,4,5-T has been found in forest streams only when applied
directly to the stream or from spray drift. Even under
these conditions, the concentration of 2,4,5-T decreased
from approximately 1.0 ppm to less than 0.01 ppm within 1
day after treatment (Norris 1967). Heavy rains 6 months
after treatment did not result in detectable 2,4,5-T
residues in streams (Norris 1968).

If residues of 2,4,5-T should occur in streams (as when
direct application is made), downstream dilution, including
the addition of uncontaminated water from downslope or side
streams, could reduce residues. Assuming a conservative
25-fold reduction in concentration over a mile of stream
",.maximum herbicide concentrations of 0.01 ppm observed at
the boundary of a treated area would be nondetectable (less
than 0.001 ppm) 1 mile downstream" (Abrahamson and Norris
1976).

116

The risk analysis for herbicides in general may be applied
to 2,4,5-T. "The maximum expected human exposure level is
calculated to be 0.01 ppm for 24 hours if water for
consumption is taken from the stream immediately downstream
from the treated area."

Norris determined that herbicide concentrations in excess of
0.1 ppm are seldom encountered in streams close to treatment
areas even immediately after spraying (Norris 1971). It has
been calculated that a 150-pound person would have to drink
179 gallons of water containing 0.1 ppm 2,4,5-T to ingest
1/100 of the calculated LD, 9 for humans (Norris 1967).
Stream water was sampled after 2,4,5-T and 2,4-D had been
applied to adjacent brush stands. The herbicides were
detected at rates ranging from 0.5 ppb to 70 ppb. The
herbicide concentration amounts fell below the detectable
level in a few days (Tarrant and Norris 1967). This is
below the .1 ppm tolerance level for potable water for human
consumption recommended by the EPA Advisory Committee on
2,4,5-T (Wilson 1971). More recent EPA guidelines have
recommended that a level of 60 ppb be adopted as the water
quality criteria for 2,4,5-T levels (Newton 1977).

Buffer strips are used around streams in order to minimize
the chances of herbicides entering the streams. The local
project supervisor may increase the width of the buffer
strip from a minimum of 100 feet because of the unusually
rough topography, especially sensitive crops, or other
similar reasons.

Air —- Relatively little is known about the exact fate of
2,4,5--T in the air in a forest environment. Although spray
may volatilize or be dispersed by the wind as fine droplets
(drift), both problems may be minimized through the use of
current spray technology and by observing responsible
practices when applying herbicides.

The EPA Advisory Committee on 2,4,5-T (Wilson 1971)
concluded that:

Probably most of the 2,4,5-T that gets into the
air very soon either settles out or is washed
out by rain and thereby is returned to soil and
water. There is no evidence to suggest that
2,4,5-T remains in the air for more than a few
weeks after insertion.

Tschirley (1971) has analyzed the hazard of human exposure
to 2,4,5-T based on the amount of 2,4,5-T and 2,4-D that
remains suspended in the air. He based his analysis on data
taken from the State of Washington where phenoxy herbicides
were widely used for weed control in wheat during the spring
and early summer.

10 GY

The hazard of human exposure to 2,4,5-T
suspended in the air is extremely small, based
on the data of Bamesberger and Adams showing the
amount of 2,4-D and 2,4,5-T in the Bite sel ney
found levels of 0.06 micrograms per cubic
meter. Assuming a man will inhale about 30
cubic meters of air per day, the exposure would
be 1.8 micrograms per day. For a 70 kg man,
this would be 0.025 micrograms per kg body
weight per day ... This is about one-two
millionth of the "no effect level" (50 mg/kg).

Although this analysis is not directly applicable to a
forest situation, these figures provide an approximation of
the hazard to people from contaminated air.

Summary - From the foregoing references, the following can
be concluded for forest management applications of Qe:

1. High levels of 2,4,5-T would not persist on forest
vegetation, but would be degraded roughly 90 percent
in 1 month.

2. 2,4,5-T would not persist in the forest floor, but be
approximately 90 percent degraded after 4 months.

3. 2,4,5-T residues would not enter forest streams in
significant amounts unless a direct application is made
to streams. Careful planning and current spray
technology can minimize or eliminate direct application
to or drift of herbicides to water. Where detectable
levels have been found, they have not persisted more
than a few days.

4. 2,4,5-T suspended in the air is expected to settle or
wash out, and is not expected to remain suspended for
long periods.

When used as registered by the Environmental Protection
Agency (even immediately after spraying), 2,4,5-T residues
have not been found to exceed the acute or chronic toxicity
levels discussed earlier. Because 2,4,5-T does not persist
in various components of the forest environment, initial
levels of 2,4,5-T decrease rapidly, quickly reducing the
already remote possibility of receiving a toxic dose. Since
2,4,5-T residues on any component of the forest environment
are quickly degraded, repeated applications of 2,4,5-T
separated by one year intervals (as in two release sprayings
on the same site) are not expected to significantly increase
either the human health hazard or residue levels beyond
those expected from a single application of 2,4,5-T.

118

2. TCDD (Contaminant)

TCDD, an impurity in 2,4,5-T, is much more toxic than
2e4,0-1l, 1eselt: LD.) values for TCDD is reported by
Harvey (1975):

LD. ng/kg
Animal Bode Weight
Rat, male 0.022
Rat, female 0.005
Guinea pig 0.0006

A more extensive table of LD_, values is given by Schwetz
ebraliee 1975) (lable ll). tRe most susceptible laboratory
animal tested in these studies was the guinea pig. Schwetz
et al. (1973) reports: (1) TCDD is highly embryotoxic,
citing studies by Sparschu et al. (1971); (2) accidental
contact with chlorodibenzo dioxins should not present a
serious threat to vision based on extrapolations to people
from rabbit eye irritation tests; and (3) repeated contacts
with the skin of small amounts of TCDD may be expected to
produce chloracne.

ce)

TABLE 11 - Lethality of Beh ge cee chlor od bere radon

eee eee

Time of Number
Route of death, days deaths/
Species and adminis- pos tadmin- LD Dose number
sex Sample tration istration mere mg/kg treated
Rat, male c Oral 9-27 0.022 0.008 0/5
, 0.016 0/5
0.032 10/10
0.063 5/5
Rat, female c Oral 13-43 0.045
(0.030-0.066 )
Guinea pig, c Oral 5-34 0.0006
male (0.0004-0.0009 )
Guinea pig, d Oral 9-42 0.0021
(0.0015-0.0030)
Rabbit, mixed c Oral 6-39 OeLI5
(0.038-0.345)
Cc Skin 1-22 0.275
(0.142-0.531)
c Intraperitoneal 6-23 ~ 0.032 0/5
0.063 Zhe
0.126 245
05252 2/5
0.500 otis.
Dogs, male c Oral 9=15 0.30 0/2
3.00 212
Dogs, female C Oral - 0.03 0/2
0.10 0/2

___ rr

='Response to individual doses are given in those cases in which an
LD.. could not be calculated. The LD for oral administration
to’rabitts was calcuated by using the method of Litchfield and Wilcoxon
(9); the remaining values were calculated by using the Weil modificaton
of the method of Thompson (15, 16).

poetcers refer to sample identification in Table 1.

From: Schwetz, B.A. et al. 1973. Toxicology of Chlorinateu
Dibenzo-p-dioxins, Environ. Health Perspect. Ds

120

A "safe" human dosage level for TCDD has not been established.
The human hazard from TCDD has been estimated by extrapolating
from the toxic dose for laboratory animals and applying a
safety factor. There is disagreement among scientists as to
what the safety factor for humans should be, and as to
whether or not TCDD contaminated pesticides should be used
without establishment of these levels. Streisinger (1976)
suggests that setting a safety factor at 10 or 100 times the
toxic level for guinea pigs (the most sensitive animal so far
tested) may not be adequate to protect humans. He further
points out that individual people vary in their sensitivity

to many drugs. Occupational exposure or exposure from
industrial accidents discussed in this section suggest that
people are not more sensitive than laboratory animals.

Information on the effect of TCDD on humans comes from studies
of occupationally exposed industrial workers (Wilson 1971):

The Dow Chemical Co. ... has prepared an
extensive health inventory of 126 manufacturing
personnel in an effort to identify adverse
effects of inhaled 2,4,5-T. The inhalation
rate of the agent was estimated to be 1.6 to
8.1 mg/day per worker, depending on the work
assignment, for periods of up to three years
and at total career exposures in excess of
10,000 mg. The survey indicates that no
illness was associated with 2,4,5-T intake.
Specifically there was no increase in skin
ailments or of alkaline phosphatase of SGPT
levels as compared with controls having no
exposure to 2,4,5-T.

The result was entirely different in a plant
where the 2,4,5-T produced contained a high
proportion of dioxin. The latter plant was
studied by Bleiberg...in 1964 and again six
years later by Poland et al...who also reviewed
earlier studies in factories in other countries
where TCDD had been a problem. Poland and
associates reported on 73 employees whose
health was found to be improved compared to
that of workers in the plant six years

earlier. Eighteen percent of the men had
suffered moderate to severe chloracne, the
intensity of which correlated significantly
with the presence of residual hyper-
pigmentation, hirsutism, and eye irritation...
The chloracne did not correlate with job
location or duration of employment at the plant
or with coproporphyrin excretion. One of the
men had uroporphy-rinuria but, unlike the
situation six years earlier, no porphyria could

iheaik

be found. Systemic illness such as may be
produced by TCDD was markedly less than that
reported in previous studies of 2,4,5-T plants
and probably no greater than expected in
unexposed men of the same age.

Dost (1977) describes several more incidences of human
exposure to TCDD:

Probably the first clinical description of human
TCDD exposure arose from the study by Kimmig and
Schulz (1957) of workers in chlorophenol
factories in Germany. The principal symptom was
a persistent skin lesion (chloracne; so-called
because it is characteristic of a number of
related compounds and was at one time thought to
be caused by free chlorine (Herxheimer, 1899)).

The active agent was established as TCDD, and
animal studies showed that the same lesions
appeared on rabbit ears after application of as
little as 0.002% TCDD (Kimmig and Schulz, 1957).
High topical doses and oral doses of 50 mg/kg or
greater caused liver necrosis. A similar
industrial intoxication in France was reported by
Dugois and Colomb (1957).

Several severe accidental exposures to TCDD have
occurred in recent years. In three notable
cases, runaway chlorophenol plant reactions
caused widespread exposures. An explosion in a
British plant in 1968 resulted in 79 cases of
chloracne (May 1973). In Czechoslovakia a
pentachlorophenate production stream overheated
under pressure, producing large amounts of TCDD
(Jirazek et al. 1974). (It should be noted that
in this and some earlier German work a different
numbering convention was used. 2,3,6,7-TCDD and
2,3,7,8-TCDD are the same compound.) Of 80
exposed workers, 76 developed chloracne,
porphyria cutanea tarda, disorders of plasma
lipids, hepatic damage, neural lesions, and
neurasthenia.

All of these exposures were to a mixture of TCDD
with other agents. Possibly the only published
amount of exposure to pure TCDD is the
description by Oliver (1975) of laboratory
contact by three individuals associated with
Synthesis experiments. The individuals all had
utilized typical protective procedures but
sufficient contact developed nonetheless. The
exposures were not sufficient to cause
porphyrinuria or liver damage but serum
cholesterol was raised. In two cases personality
changes and neural disorders developed two years
after exposure.

In the U.S., TCDD extracted form hexachlorophene
production was stored in oil, then mistaken for
waste lubricating oil and sprayed on several
horse arenas and farms in Missouri, for dust
control. The incidents occurred in spring and
summer of 1971. On one horse breeding farm, 62
of 85 horses exercised in the sprayed area became
i11 and 48 died, the last in January, 1974, two
and a half years later. Hundreds of birds and
rodents died, along with a number of dogs and
cats. Several children were exposed through play
in the arena soil. One developed a severe
hemorrhagic systitis and others showed clear
evidence of chloracne. All recovered. The TCDD
concentration in the soil was later established
at more than 30 ppm, a truly massive amount.
(This concentration amounts to 120, 1b per acre
per foot of depth, as suming Sax 610 o8lb
soil/acre-foot or 6 x 10 times more than
presently allowed by EPA at 2 lbs 2,4,5-T/A.)
The details of the latter event are described by
Carter et al. (1975) and Kimbrough. et al. »(1975).

Approximately five years after the initial exposure, a child
who had played in the contaminated horse arena, was studied
again along with her sister and mother, who also frequented
the area. The results of all studies indicated that the
responses of all three patients were normal. Beale et al.
conc luded:

In the patient presented here, the toxicity of
the compound appeared relatively early and was
self-limited. However, our experience
demonstrates that people exposed to dioxin can
recover completely with no apparent sequelae
from the toxin. It remains to be determined
whether the exposure to dioxin in these children
will result in abnormal pregnancies or affect
their offspring.

In a recent court case, C.A.T.S. vs. Bergland, and in
previously cited references, residents living near the
Siuslaw National Forest reported varied ill effects from the
use of 2,4,5-T on adjoining National Forest land. There
are, however, apparently no verified cases of chloracne, one
of the most conspicuous and best documented effects of TCDD
exposure in industrial workers.

In January 1977, U.S. Congressman Jim Weaver requested and
received a report, "Human Milk Monitoring: Preliminary
Results for Twenty-one Samples," dated 12/15/76. This study
reported finding 1.3 ppt TCDD in human milk from one donor
living near the Siuslaw National Forest. Milk from four
other donors in the same general area did not contain

I

detectable levels of TCDD with the limit of detection
ranging from 0.6 to 1.6 ppt. The study also reported TCDD
at 1.4, 0.9, and 0.6 ppt in human milk from three donors
near San Angelo, Texas. Three other donors had no
detectable TCDD with limits of detection ranging from 1.2 to
1.9 ppt. The authors emphasized (1) the report was
preliminary, (2) additional field and control samples were
being analyzed, and (3) only when results from those
experiments are obtained would they contemplate publication.

The results from this study were reported in the press,
causing substantial controversy regarding both the details
of how the study was conducted and the significance of the
findings. The controversy is not resolved. Copies of the
report were sent by Harvard to EPA and FDA before the
correspondence with Congressman Weaver in January 1977.

There are substantial questions about the sample collection
methodology, the proximity of the reported values to the
limits of detection, and use of an analytical method. Also
questions remain about the standards for data evaluation
which are different from those used by the EPA Dioxin
Monitoring Committee.

EPA is currently monitoring for TCDD in human milk from
several areas where 2,4,5-T is used in forestry. EPA and
FDA have not taken any regulatory action because of the data
reported by the Harvard scientists. For these reasons, we
note the results of the study and await clarification of
both the adequacy of the study and the significance of the
findings by the scientific community and regulatory agencies.

Fate of TCDD in the Environment

Applications of 2,4,5-T containing up to 0.1 ppm TCDD would
introduce small amounts of TCDD into the environment. As
discussed with reference to 2,4,5-T and the environment,
residues may be found in: (1) vegetation, (2) the forest
floor, (3) forest streams, and (4) air.

Vegetation - Crosby and Wong (1977) have analyzed the
persistence of TCDD as it occurs, in actual herbicide
formulations, on leaves, soil, or glass plates. When
exposed to natural sunlight, most or all TCDD was lost
during a single day. This loss was due principally to
"photochemical declorination." The herbicide formulation
provides a hydrogen donor which allows photolysis to occur.
Pure TCDD, as used in earlier experiments, would not have
been subject to photolysis because a hydrogen donor was
lacking. Despite the known persistence of pure TCDD, it is
not stable in thin films as actually formulated when exposed
to outdoor light.

124

Plant uptake of TCDD incorporated in soils does not appear
to be significant. Soybean and oat plants took up only
trace amounts of TCDD in the first 10 to 14 days after
exposure to sandy soil containing 40,000 times the
equivalent amount of TCDD contained in an application rate
of 2 pounds per acre 2,4,5-T (with 0.5 ppm TCDD). No
detectable TCDD was in the grain or beans at maturity,
probably due to normal dilution by plant growth, including
volatilization or photodecomposition from the leaf surface
or metabolism. TCDD is not translocated from the point of
application on the leaf surface to other parts of the plant
and some is washed off with rain water (Isensee and Jones
1 ys

There is variability in the calculations of toxic doses of
TCDD in an acre of sprayed land. The largest number of
toxic doses has been calculated by Streisinger (1976a,b).
He believes there would be one toxic dose of TCDD in 0.3 -
0.6 acres of treated foliage, based on the toxicity of TCDD
to guinea pigs. For a person to ingest this toxic dose,
some mechanism for collecting and concentrating the
herbicide from all contaminated surfaces (including all
vegetation and soil) must exist to make this toxic dose
available.

Although it is extremely improbable, if an individual did
encounter a concentrated source of TCDD, it would not follow
that all TCDD taken in would be stored completely. Ross
(1976) details the process by which TCDD is stored,
metabolized, and excreted:

This is a dynamic process and at the same time that
some TCDD is being stored, other TCDD is being
metabolized and excreted. The higher the storage
level, the more rapid rate of excretion. Every
level of continous intake will finally reach a
maximum level of storage, at which the excretion
rate equals the rate of intake. The maximum
storage level is nearly reached in 7 weeks and
essentially complete in 12 to 13 weeks. This is
well shown by Rose et al. (1976). When intake
ceases, as it would if consumption of the
hypothetical beef liver were paced at monthly
intervals, excretion of TCDD or its metablolites
continues and the maximum possible storage level is
not attained. It has been shown that half the
stored TCDD is excreted in from 15 to 30 days.

Soil - Earlier reports of laboratory data (Kearney 1976b)
indicated that pure TCDD on soil surfaces could not be
degraded by sunlight. Crosby and Wong (1977) have
demonstrated that TCDD, as it actually occurs in formulated
herbicide products, is rapidly degraded (about 15% in six
hours) on the soil surface by the action of sunlight.

12S

In five soils with widely varying characteristics, TCDD was
found to be immobile, even when subjected to leaching
(Helling 1973). The possibility of TCDD entering ground
water is remote (Tschirley 1971).

If TCDD is incorporated into soil, it disappears slowly.
About half the TCDD is lost after one year (Kearney 1973).
It seems unlikely, however, that TCDD would be incorporated
in soils under forest conditions, since it does not leach
into the soil. TCDD is not produced from breakdown products
of 2,4,5-T in soils (Kearney 1971) or in sunlight (Plimmer
L971):

Water - TCDD is nearly insoluble in water - 0.2 ppb (Dow
Chemical Company 1970). For this reason, it would be
expected to remain on the surface of plants and soil at the
application site. Previously cited references indicate that
TCDD does not leach in soils. Because it is immobile in
soils, Kearney et al. (1973) concluded there would be "no
ground water contamination problems." In the natural
environment, any TCDD would be expected to be found
associated with other constituents of the formulation which
are less soluble in water. They would form a thin film on
water surfaces. Such films are expected to be degraded by
sunlight, much like thin films on vegetation or the soil
surface. Residues might, therefore, be substantially less
than would be indicated from research with pure laboratory
systems, suggesting that TCDD would be only slowly degraded
in water.

Air - Explosion of a chemical plant in Seveso, Italy, in
July 1976 resulted in widespread contamination of the
surrounding countryside with TCDD. The exact amount of TCDD
released by the explosion has not been precisely determined.
However, it is believed to be quite high. From this
unfortunate incident, we are beginning to receive additional
information regarding human exposure to TCDD. Hawkes (1977)
reported that the pollution "ig not as serious as some had
feared."" Although there have been serious cases of
chloracne, most patients are expected to recover completely,
and pregnant women exposed to TCDD contamination at a
critical stage of pregnancy "have now had their babies
without any higher than average incidence of abnormality."
These observations are consistent with the health record of
the many applicators and manufacturing plant workers who
have been exposed to high levels of these materials at
frequent intervals.

Field Burning - Although thermal production of TCDD from
2,4,5-T is chemically possible in the laboratory, the
levels of TCDD which might be produced in the field through
burning of 2,4,5-T treated vegetation are not expected to
substantially exceed TCDD levels present from the original

126

application of herbicide (Norris and Pierovich 1977).
Laboratory experiments usually use closed systems and high
concentrations of 2,4,5-T, where heating is prolonged and
uniform, but without actual combustion.

Actual field burning conditions occur with a free exchange
of air and temperatures above 1200°C are common. Under
these conditons, complete oxidation of all carbon compounds,
including 2,4,5-T, trichlorophenol, and TCDD are expected.
Furthermore, under actual field conditions, the
concentration of 2,4,5-T on vegetation decreases rapidly
after spraying, reducing the possible amount of TCDD that
might form if burning occurred.

An important consideration in this regard is the possbility
of wildfire occurring in treated areas shortly after
treatment with herbicides that contain TCDD. Fire records
for areas in Region 9 where this type of treatment is
carried out show that the possibility of wildfire occuring
at any time is quite remote. Thus the chance of actually
burning much of the area once a fire starts is also very
small.

Some areas are purposely burned in order to remove enough of
the logging residue and vegetation to plant a new crop of
conifers. In order to do this, it is necessary to wait one
to three months for enough drying to occur to permit
effective burning. This is ample for the degradation of any
Significant amounts of 2,4,5-T that might be present (Norris
et@al lia)?

Bioaccumulation - Bioaccumulation means the uptake and at
least temporary storage of a chemical by an organism. TCDD
is present in such minute quantities in the environment that
toxicity from primary exposure (that is, exposure resulting
from indirect ingestion of vegetation or water, dermal
absorption or inhalation is unlikely (Norris et al. 1977a).
Concern for bioaccumulation is that it may be a mechanism by
which organisms collect or concentrate TCDD from primary
exposure. These organisms would then carry possibly
toxicologically significant residues as food sources for
other creatures.

For instance, the amount of TCDD required to produce harmful
effects in humans is spread out over such an area that
direct personal exposure to that amount is unlikely. But,
if deer bioaccumulate TCDD as they feed, human consumption
of these deer could conceivably lead to significant human
exposure. The question is, then, does bioaccumulation
occur, and if it does, to what degree? There are three ways
to study this question: physical-chemical properties,
laboratory studies, and environmental monitoring.

Physical-chemical properties are good indicators of the

potential for bioaccumulation. Chemicals with low water
solubility and high fat solubility have a strong potential

127

for bioaccumulation. DDT is an example of a chemical which
is low in water solubility (0.001 ppm) and is high in fat
solubility (86,000 ppm in corn oil). DDT is known to
bioaccumulate in exposed organisms. TCDD is low in water
solubility (0.0002 ppm) but is also low in fat solubility
(47 pmm in corn oil)., The ratio of oil solubility to water
solubility is 86 x 10 for DDT and 0.2 x 10 for TCDD.
These physical-chemical properties suggest that TCDD would
bioaccumulate in exposed organisms, but probably to a lesser
degree than DDT. The degree of bioaccumulation depends on
the magnitude and duration of organisms exposure.

Bioaccumulation can also be studied in laboratory animals or
in small laboratory ecosystems. Several such studies have
been done. Data from laboratory feeding studies of mammals
and fish, and from laboratory-scale, aquatic ecosystems are
pertinent.

In laboratory feeding studies with repeated exposure, Fries
and Marrow (1975) report that after six weeks of exposure,
rats reached a steady state which was 10.5 times the daily
intake. Rose et al. (1976) also repeat steady state
concentration in rats in seven weeks at little more than ten
times the daily intake level. These data establish that in
laboratory feeding studies, animals which ingest TCDD in
their diet will accumulate TCDD in certain body tissues, at
least for as long as exposure continues.

It is also clear, however, that TCDD is not irreversibly
accumulated in these feeding studies. Piper et al. (1973),
Allen et al. (1975), Rose et al. (1976), and Fries and
Marrow (1975) all found a halflife for TCDD residence in the
body which ranged from approximately 12 to 30 days. These
data indicate that once exposure to TCDD stops, the body
burden will decrease. In a feeding study with rainbow
trout, Hawkes and Norris (1977) report limited and
preliminary data indicating that, on a whole body basis,
TCDD levels in fish are approximately of the same order of
Magnitude as the level of TCDD in the food which they
consume.

Several laboratory-scale aquatic ecosystem studies have been
conducted with TCDD. Matsumura and Benezet (1973) exposed
several organisms in model aquatic ecosystems to TCDD.
Unfortunately, in most of their studies, the concentration

of TCDD in the water was substantially in excess of the
limits of its solubility, preventing meaningful
interpretation of the data. In one experiment, however,

TCDD was adsorbed on sand in the bottom of the aquariums and
Matsamura and Benezet found 0.1 ppb TCDD in water and 157

ppb in brine shrimp, to give a concentration factor of 1,570.

Isensee and Jones (1975) also used a laboratory-scale,

aquatic ecosystem to study TCDD bioaccumulation i mosquito
fish, fingerling, channel catfish, algae, duckweed, snails,

128

and water fleas. TCDD was adsorbed on soil which, when
equilibrated with the water, resulted in TCDD concentrations
in water ranging from 1,330 to 0.05 ppt. Concentrations in
excess of 200 ppt exceed the limits of water solubility for
TCDD and prevent meaningful interpretation of those
bioaccumulation data.

In experiments where the water concentration was less than
200 ppt, bioaccumulation ratios (that is, the ratio of the
concentration of TCDD in the organism to,the concentyation
of TCDD in the water) ranged from 2 x 10° to 63 x 10

They found a strong, positive correlation between the
concentration of TCDD in tissue and concentration of TCDD in
water for all organisms. Isensee (1977) recalculated this
data from a dry weight basis to a fresh weight basis in
order to make the data more comparable to other studies. He
reports the average degree of bioaccumulation ranged from 2
to 7 x 10° times the water concentration of TCDD. The

total amount of TCDD accumulated was directly related to the
water concentration. Equilibrium concentrations in tissues
were reached in 7 to 15 days. He reports TCDD
bioaccumulates to about the same magnitude as many of the
chlorinated hydrocarbon insecticides in model aquatic
ecosystems.

These results from laboratory studies indicate that
organisms exposed to TCDD in their diet or in aquatic
ecosystems will bioaccumulate TCDD. The degree of bio-
accmulation which occurs from the use of TCDD-contaminated
herbicides in forest ecosystems depends on the magnitude and
duration of organism exposure. In laboratory studies,
organism exposure is assured through regular addition of
TCDD to the food for feeding studies or in aquatic
ecosystems. This occurs through the placement of a
substantial reservoir of TCDD adsorbed on sand or soil,
resulting in continuous release of small quanities of TCDD
to water.

In the natural environment, several processes operate to
reduce or eliminate TCDD exposure to organisms and thereby
minimize the opportunities for bioaccumulation. Crosby and
Wong (1977) report TCDD in herbicide formulations disappears
rapidly from vegetation and soil when exposed to sunlight.
This mechanism would markedly reduce or eliminate organism
exposure through dermal contact with or ingestion of
contaminated vegetation. In the aquatic environment, the
likelihood of 2,4,5-T and TCDD entry to aquatic systems is
slight, but if it does occur, chemicals in the water are
rapidly diluted and carried downstream with streamflow.

TCDD which adsorbs on sediments provides a reservoir of TCDD
in the aquatic ecosystem studies. However, in the real
stream system, TCDD liberated from the sediments is quickly
moved downstream with streamflow. The opportunity is
minimal for bioaccumulation by a particular organism.

129

The third approach to evaluating TCDD bioaccumulation is to
look directly for evidence of bioaccumulation in the field.
Several efforts in this regard have been made, but with
markedly diffeent sophistication and sensitivity of
analytical methods. For instance, Woolson et al. (1973)
analyzed samples of eagle tissues from various regions in
United States. No TCDD was detected. The minimum detection
limit, however, was 50 ppb, which is not an adequate level
of sensitivity to properly evaluate bioaccumulation of TCDD,
considering the inherent toxicity of the molecule.

Young et al. (1976) studied the behavior and bioaccumulation
of TCDD in animals from the Elgin Air Force Base site used
for equipment development and testing for application of
herbicides in Vietnam. The study area received massive
applications (1,000 pounds per acre) of 2,4,5-T, much of
which contained TCDD in excess of 1 ppm. Analysis of soil
from the test site shows TCDD residue levels in the range of
10 to 1,500 ppt. Analysis of rodents, reptiles, birds,
fish, and insects shows the presence of TCDD in tissues of
at least some of the organisms involved in this test
program. The results of this test substantiate the
theoretical data and the data from laboratory tests which
indicate that, if TCDD is available to organisms i the
field, it will be bioaccumulated. The degree to which
herbicide used at Elgin test site was contaminated with TCDD
and the massive rates of application, however, make this
data not directly applicable to the use of herbicides in
forestry. It is useful to indicate TCDD does have a
potential for bioaccumulation.

Other studies done in connection with the registered uses of
2,4,5-T for vegetation control have found relatively little
TCDD in biological samples. In 1973-74, the Environmental
Protection Agency, cooperatively with the Forest Service,
conducted a monitoring program for TCDD in tissues of
animals from several areas in western Oregon and Washington
which had been recently treated with 2,4,5-T. The
methodology employed at that time was not adequate to
establish the presence of TCDD in these environmental
samples, but was adequate to determine which samples did not
contain TCDD in the low-to-middle part per trillion range.

Results of the monitoring program showed approximately 84
percent of the samples did not contain detectable levels of
TCDD. The remaining samples are described by EPA as
"minutely suggestive" for TCDD. In 1976, five of these
samples were reanalzyed by two laboratories (participants in
the dioxin monitoring program). Two did not contain
detectable TCDD. EPA describes the results of analysis of
the other three as follows: ''Some of the samples analyzed
in 1973-74 still appear positive for TCDD. Unfortunately,
the results from the two laboratories participating in the
confirmation vary widely. The confirmation analysis,

130

therefore, still does not give a precise quantification of
the amount of TCDD present. It does appear, however, that
from a qualitative standpoint TCDD was present in a small
percentage of the forest samples collected in 1973."
Assuming three out of five samples (60%) which were possible
positives in the 1973-74 analysis are, in fact, qualitative
for TCDD, then 9.6% of the 1973 samples were positive for
TCDD and 90.4% did not contain detectible residues.

The EPA beef fat monitoring program, which was initiated in
1974, has been completed. Samples of beef fat (85) and
liver (43) from animals grazing in areas treated with
2,4,5-T have been analyzed for TCDD. Approximately 25
percent of these samples are from animals not exposed to
areas sprayed with 2,4,5-T. EPA reports one sample shows a
positive TCDD level at 60 ppt, two samples appear to have
TCDD at 20 ppt, five may have TCDD level at the range of 5
to 10 ppt. EPA states, ''The analytical method is not valid
below 10 ppt." Of the 43 liver samples analyzed, one sample
may contain TCDD, but the level is too close to the sample
detection limits for quantitation. A fat sample from the
same animal showed no TCDD residue. The results of the EPA
beef fat monitoring study indicate bioaccumulation of TCDD
in grazing animals is not sufficient to result in regularly
detectable levels of TCDD greater than 10 ppt in beef fat
and liver.

Newton (1975) reported on the analysis of livers from
mountain beavers caputred 2 months after a forested area in
western Oregon was treated with 2,4,-D and 2,4,5-T.

Analysis of the tissues showed no detectable levels of TCDD
with a minimum detection limit of less than 10 ppt.

Mountain beavers normally consume large quantities of
vegetation, thereby affording them substantial exposure to
herbicide-treated plants. In addition, they are a burrowing
animal which will put them in intimate contact with
herbicide and TCDD present on the soil surface.

Shadoff et al. (1977) conducted a broad study to determine
whether TCDD was accumulating in animals due to the use of
2,4,5-T in the mid-western United States. They did not
detect any TCDD (detection limit which averaged less than
10 ppt) in samples of fish, water, mud, and human milk from
areas in Arkansas and Texas.

Mesleson (1977), in a tentative and preliminary report to
Oregon Congressman Weaver, indicated some samples of human
milk from areas in which 2,4,5-T is used contained
detectable levels of TCDD. Mesleson reported three samples
out of six from Texas, and one sample out of five from
Oregon contained detectable levels of TCDD. The levels of
detection, however, were substantially below the 10 ppt
level established by EPA in the beef fat monitoring progrm
as the minimum acceptable, reportable level.

aol

The results of these various tests indicate that, if TCDD is
present in the environment in a form which is available to
organisms, then bioaccumulation would occur if organisms are
exposed. This concept is supported, both from an
examination of the physical-chemical properties of TCDD, as
well as by studies of its behavior in animals exposed
through feeding studies or in laboratory model aquatic
ecosystems. The degree to which bioaccumulation of TCDD
occurs in the field is dependent not only on the
physical-chemical properties of the compound, but also on
the persistence and availability of TCDD in the

environment. Mechanisms of degradation and dilution which
operate in the natural enviornment reduce the opportunities
for organisms to be exposed, and thereby reduce the degree
to which bioaccumulation might occur.

Monitoring for TCDD residues in animal samples from areas
where 2,4,5-T is used at normal rates of application tends
to show little or no detectable bioaccumulation of TCDD. In
the beef fat monitoring study, for instance, only three
samples out of 63 contained TCDD at levels within the range
at which the analytical method is valid quantatively. The
EPA monitoring for TCDD, in animal samples from western
forests conducted prior to June 1974, shows at least 84
percent of the samples do not contain detectable levels of
TCDD (the other 16 percent require confirmatory analysis).

The study of TCDD residues in livers of mountain beavers
from areas treated with 2,4,5-T shows no detectable levels
of TCDD, with minimum detection limit of less than 10 ppt.
A widescale monitoring of water, sediment, fish, beef, and
human milk from areas in the midwestern United States where
2,4,5-T has been applied also shows no detectable TCDD
residues at minimum detection levels which average 10 ppt.
These monitoring efforts indicate that substantial
bioaccumulation (sufficient to produce residue levels in
excess of 10 ppt TCDD in the majority of the populaton) is
not occurring in animals in or near areas treated with
2,4,5-T in current operational programs.

Cumulative Effects of TCDD - Some toxicologists interpret
recent experiments with primates (Allen et al. 1977) as
indicating that the effects of sublethal doses of TCDD may
be cumulative and death results if a sufficient number of
sublethal doses are received. Stated another way, these
experiments may suggest that the lethal amount of TCDD in
primates is approximately the same regardless of whether the
dose is received all at once or in numerous small doses. If
this is true, it means any estimate of an acceptable
exposure level must assume additive effects over long
periods. No chemical is known to have such properties.

A primate study by Allen (1977) used TCDD in the diet at 500
ppt. This is a level substantially greater than likely to

L352

be available to organisms in the forest, even immediately
altereapplacation of 2;4,5-T. Norris et al. (1977)
estimates initial TCDD residue levels on vegetation of 5 to
10 ppt immediately after application. Crosby and Wong
(1977) report TCDD halflife on vegetation of only a few
hours when exposed to sunlight. Therefore, the probability
of chronic exposure to levels of 500 ppt TCDD is remote.)
If the response of primates in Allen's study is proportional
to the dose received, exposure to 5 ppt would permit
Survival for 100 times as long as reported by Allen. This
would be well beyond the normal life span of primates.

Additional experimentation with primates is necessary to
clarify the Allen finding. Chronic exposure at levels
relevant to possible environmental residue levels is

needed. Periodic exposure to higher levels (10 to 500 ppt),
with periods of no exposure between, also need to be

tested. The exposure level used by Allen may have
overloaded or inactivated the detoxication and repair
processes of organisms usually employed in responding to
chronic toxic exposure. The exposure regimes described
above would test this hypothesis.

Cumulative effects of TCDD have not been seen in other
species. In guinea pigs, dose rates of 0.2 ug/kg weekly for
eight weeks provided a total dose almost three times the
LD.,, but no deaths occurred. Organ changes, while
measurable, were not severe (Vos et al. 1973). Vos et al.
(1974) also reported that rats accepted about three times
the LD of 20 ug/kg over a 13-week period without
dethalgcys

Experiments conducted thus far are not adequate to determine
with any certainty that TCDD does or does not have
cumulative effects in animals. The evidence to indicate
possible cumulative effects comes from a single study with
primates. Evidence opposing the cumulative effect theory
comes from studies with guinea pigs and rats, and from the
fact that no other chemical is known to have cumulative
effects. The possibility of cumulative effect is important,
and carefully designed experimentation is needed to clarify
the point. However, there is insufficient evidence at this
time for the Forest Serivce to determine that use of
2,4,5-T, as registered by EPA, would result in cumulative
toxic effects from TCDD in people or animals likely to come
in contact with spray materials.

Summary - Although there is not as much information on TCDD
as on 2,4,5-T, some assumptions can be made from the

foregoing references:

1. TCDD is rapidly broken down by sunlight on vegetation
and the soil surfaces.

133

2. TCDD is not significantly translocated from contaminated
soil to plants or from the site of application on the
leaf surface to other parts of the plant.

3. A toxic dose of TCDD may be spread over as little land
as one-third to one acre. However, this dose would have
to be accumulated and concentrated (before decomposition
could occur) from all contaminated surfaces within that
1/3 acre before it would be available.

4. TCDD is persistent when incorporated in soils, but is
more likel to remain on the soil surface, since it is
nearly insoluble in water.

5. TCDD residues are not expected in ground water because
TCDD does not leach significantly in soil.

6. TCDD is not likely to be produced by burning under field
conditions.

7. Humans exposed to substantial amounts of TCDD from
industrial accidents have suffered chloracne, but
apparently their offspring do not exhibit birth defects
as a result of this exposure.

8. TCDD is not sufficiently persistent nor available to
organisms in the forest for significant bioaccumulation
to occur.

Although TCDD is distributed in the forest environment as a
contaminant in 2,4,5-T, the amount of TCDD (0.1 ppm in
2,4,5-T) is so small and spread over such a great area that
exposure to a toxic dose is highly unlikely. Additionally,
TCDD as it occurs in actual herbicide formulations degrades
rapidly (within a single day), further decreasing the
possibility of contacting a toxic dose. Tschirley (1971)
and the New Zealand Department of Health (1977) offer
"worst-case estimations" supporting the remoteness of this
possibility.

Conclusions

Based on the foregoing discussion and the data available at
the printing of this statement, neither 2,4,5-T nor TCDD are
believed to be harmful to humans when used as registered by
the Environmental Protection Agency. However, it is
important to understand that no one including the U.S.
Forest Service, can guarantee the absolute safety of 2,4,5-T
or silvex. The New Zealand Department of Health, in a
report entitled "2,4,5-T and Human Birth Defects" (1977) has
expressed this difficult position very well:

It must be faced that there is no way in which

any substance, including common foodstuffs, can
ever be proved absolutely safe. To achieve such

134

a standard of proof would entail testing every
person with every substance at every conceivable
exposure level in every imaginable

circumstance. Otherwise there is always the
possibility of a single individual somewhere who
will react adversely under certain conditions.

The best that can be achieved for any substance
is a high degree of "assurance" of safety based
upon a rational and experienced scientific
judgment of the available evidence.

The accumulated data on 2,4,5-T and its TCDD
contaminant are sufficient to give a very high
assurance of safety in the normal use of this
material. This belief is in accordance with the
concensus of world-wide scientific opinion.

In the United States, this "high degree of assurance" is
afforded by registration of 2,4,5-T with the Environmental
Protection Agency for the uses designated in this
environmental statement.

2,4-D

2,4-D, like 2,4,5-T, is an auxin type herbicide. However,
unlike 2,4,5-T, it does not contain the contaminant TCDD.

Acute Toxicity

Acute toxicity values for 2,4,-D are given in Table 12.
eu -Dedenslighitly) less atoxtesthan 2,4,55-IT/ with LD

values ranging from 100 to 2,000 mg/kg. This data indicates
that various species can tolerate residues (no effect level)
of 500 to 1,500 ppm in their food (Norris 1976a). As will
be discussed (Fate of 2,4-D in the Environment), these
levels would not likely be found in a forest environment.

Additional data on the toxicity of 2,4-D to humans can be
derived from several reported incidents of 2,4-D poisoning,
therapeutic use, or experimental self-administration. These
cases have been summarized by Dost (1977). Accidental
poisoning with 2,4-D resulted in a range of symptoms, of
which one of the most serious appears to be neural damage.

A single suicidal dose, estimated to be 90 mg/kg of 2,4-D
resulted in death (Nielsen et al. 1965).

1355

Oral
Formulation
Alkanolamine
Isopropyl ester
Isopropyl ester
Isopropyl ester
Butyl ester
Butyl ester
Butyl ester
PGBE
Acid

Acid

Isopropyl ester

Unspecified
amine

Acid

Acid

Triethanolamine

Triethanolamine

Table 12 - Toxicity of 2,4-D

ACUTE TOXICITY OF 2,4-D

Organism

Chick

Rat

Chicks

Guinea pig

Rat

Guinea pig

Chicks

Rat

Dog

Chick
Rat

Mallard duck

Pheasant

Mule deer

Swine

Swine

Dose

380-765 mg/kg

700 mg/kg

1420 mg/kg

550 mg/kg

620 mg/kg

848 mg/kg

2000 mg/kg

570 mg/kg

100 mg/kg

541 mg/kg
700 mg/kg

2000 mg/kg

472 mg/kg

400-800 mg/kg

50 mg/kg

500 mg/kg

136

Eftectmmme cr ckeuce
LD.4 Rowe and
Hymas (1954)
LD. 4 Rowe and
Hymas (1954)
LDe9 Rowe and
Hymas (1954)
LDe9 Rowe and
Hymas (1954)
LD.4 Rowe and
Hymas (1954)
Leo Rowe and
Hymas (1954)
LD.4 Rowe and
Hymas (1954)
LD59 Rowe and
Hymas (1954)
LD.4 Rowe and
Hymas (1954)
LD<9 Rowe and
Hymas (1954)
LD 50 Hayes (1963)
LD 9 Tucker and
Crabtree (1970)
LD<9 Tucker and
Crabtree (1970)
LD. 9 Tucker and
Crabtree (1970)
Anorexia Bjorklund and
inl Erne (1966)
Probably Bjorklund and
lethal Erne (1966)
(Killed in

a moribund state)

Oral
Formulation

Butyl ester

Triethanolamine

Butoxyethanol
ester

Butoxyethanol
ester

Butoxyethanol
ester

Butoxyethanol

ester

Dimethylamine

Dimethylamine

Dimethylamine

Dimethylamine

Ethylhexyl
ester

Ethylhexyl
ester

Ethylhexyl
ester

Ethylhexyl
ester

(Continued)

Paplesi2 — loxicity of 2,4-D

ACUTE TOXICITY OF 2,4-D

Organism

Swine

Chicken

Oyster

Shrimp
Fish (salt
water)

Phytoplankton

Oyster

Shrimp

Fish (salt
water)

Phytoplankton
Oyster

Shrimp

Fish (salt

water)

Phytoplankton

Dose

100 mg/kg

300 mg/kg

3.75 ppm
(96 hrs.)

1 pp
(48 hrs.)

5 ppm

1 ppm
(4 hrs.)

2 ppm
(96 hrs.)

2 ppm (48
hrs.)

15 ppm
(48 hrs.)

1 ppm
(4 hrs.)

> ppm
(96 hrs.)

2 ppm
(48 hrs.)

10 ppm
(48 hrs.)

1 ppm
(4Aghrs.)

137,

Effect Reference
No effect Bjorklund and
Erne (1966)
Gastritis Bjorklund and
one) Erne (1966)
50% Bulter (1965)

decrease in
shell growth

No effect Bulter (1965)

48 hr Bulter (1965)

Lo

16% Bulter (1965)
degrease in
CO” fixation

No effect Butler (1965)
on shell

growth

10% Butler (1965)
mortality
or paralysis
No effect Butler (1965)
No effect Butler (1965)
CO” fixation

38% decrease Bulter (1965)
in shell growth

10% mortal- Bulter (1965)
ity or paralysis
No effect Bulter (1965)

(1965)

49% dgcrease Bulter
in CO
fixation

(Continued)

Table 12 - Toxicity of 2,4-D

ACUTE TOXICITY OF 2,4-D

Oral
Formulation Organism
oF
PGBE— ester Oyster
iW ;
PGBE— ester Shrimp
1/ :
PGBE— ester Fish (salt
water)
pope! ester Phytoplankton
Dimethy Llamine Bluegill
Alkanolamine Bluegill
Isoocytl ester Bluegill
Butyl ester Bluegill
Isopropyl Bluegill
ester
PGBE Bluegill
i)

Dose

1 ppm
(96 hrs.)

1 ppm
(48 hrs.)

4.5 ppm

1 ppm
(A°nrse-)

166 to 458
ppm

435 to 840
ppm

SrosLOso lay
ppm

1.3 ppm

1.1 ppm

2 ppm

='PGBE is propylene glycol butyl ether

138

Effect

39% decreas

e

Reference

Butler (1965)

in shell growth

No effect

48 hr LC,

Butler (1965)

Butler (1965)

L4% decrease Butler (1965)

in CO

fixation

48 hr LC

48 hr LC

46" hr EG

48 hr LC

48 hr LC

48 hr Le

50

50

50

50

50

50

Lawrence
(1969)

Lawrence

(1969)

Lawrence
(1969)

Lawrence
(1969)
Lawrence

(1969)

Hughes &
Davis

(1963)

Chronic Toxicity

Chronic toxicity values for 2,4-D appear in Table 13. The
doses range from 500 ppm to 2,400 ppm in the diet with the
duration of the experimental feeding period ranging from 30
to 112 days for various animal species.

A single human ingested an experimental dose of 500 mg of
2,4-D daily for three weeks with no evident effect (Assouly
1951, as reported in Nielson et al. 1965). Seabury (1963)
reports treating a patient with a terminal case of
coccidoidomycosis with 2,4-D. Since 2,4-D is a synethetic
plant hormone, it was hoped that 2,4-D might affect the
fungal infection. At the time of the treatment, no other

therapeutic agent was available. Dost (1967) summarizes the
effects:

In 24 treatments over a period of more than a
month the dosage was raised to a final treatment
of 3600 mg. No prior doeses, up to 2000 mg
caused any response, but the final
administration caused extreme quiescence, and
fibrillation of muscles in the face and hands,
followed by deep stupor and reflex failure. The
patient recovered from the 2,4-D within 48 hours
and died of the fungus disease about two weeks
later.

Effect of 2,4-D on Reproduction and Fetal Development

Dost (1977) has reviewed the effects of 2,4-D on
reproduction:

Asewitniec,4,.-1 the possibility that#2;4-D has
teratogenic potential was first studied by the
Bionetics Research Laboratories study (Bionetics
Research Laboratories, Inc., 1970). The data
were suggestive that incidence of failed lower
jaw formation was somewhat greater than that
resulting from the DMSO carrier. Schwetz et al.
(1971) measured teratogenic and fetotoxic
eErects Ot 2,4-)eand two esters on rats. The
higher daily doses (75 mg 2,4-D/kg; 75 mg
propylene glycol butyl ester of 2,4-D/kg;87.5 mg
isoocytl ester of 2,4-D/kg, each just below the
maternal toxic dose) caused decreased fetal
weight, subcutaneous edema, delayed bone
ossification and wavy ribs. Most of these
changes are fetotoxic rather than teratogenic.
The last two are developmental effects but have
no effect on survivability. No teratogenic
responses were found at any dose.

139

Oral
Formulation

Ethylhexyl
ester

Ethylhexyl
ester

Not specified

Not specified

Not specified

Alkanolamine

PGBE ester

PGBE ester

Acid

Organism

Sheep
Sheep &
cattle

Dog

Rat

Rat

Chicken

Chicken

Cattle

Mule deer

Table 13

CHRONIC TOXICITY OF 2,4-D

Dose

250/mg/kg/day
100/mg/kg/day
500 ppm in

feed

1250 ppm in
feed

500 ppm in
feed

100 mg/kg/day

50 mg/kg/day

100 mg/kg/day

80 and 240
mg/kg/day

140

Duration

17 days

10 days

2 years

2 years

2 years

10 days

10 days

10 days

30 days

Effect

I1il in 3 days
17 doses lethal

None to minor
effects.

None
No effects on

survival
hematology or

tumor incidence.

No effect in
reproduction
studies.

No effect on
weight gain.

No effect on
weight gain.

No effect.

Minor symptoms,
no weight loss.

Reference

Hunt et al.
(1970)

Hunt et al.
(1970)

House et al.
(1967)

House, et al.
(1967)

House, et al.
(1967)

Palmer and
Radeleff (1969)

Palmer and
Radeleff (1969)

Palmer and
Radeleff (1969)

Tucker and
Crabtree (1970)

Dost (1971) has summarized additional references:

There is some difference in definition of
teratogenic response among authors in the
field. A variety of skeletal defects that do
not interfere with postnatal survival were found
by Khera and McKinley (1972); most effects
observed were wavy ribs or fused sternum. The
increased incidence of these changes were
evident at doses as low as 25 mg/kg/day. 2,4-D
teratogenesis was studied by Bage et al. (1973)
but only in presence of 2,4,5-T. The mixture
caused some teratogenesis, but was less
effective than 2,4,5-T alone, so the impact of
2,4-D in the system was difficult to evaluate.

Hamsters are subject to a teratogenic effect of
high doses of 2,4-D. Collins and Williams
(1971) found that 2,4-D from three different
sources caused a low incidence of anomalies,
usually fused ribs, at doses of 100 mg/kg/day
through days 6-10 of gestation. There was no
satisfactory dose response relationship.
Dietary 2,4-D at 500 and 1000 ppm did not alter
reproductive function in a three-generation, six
litter study with rats. Percentage of pups
surviving to weaning and weanling weight was
decreased at 1500 ppm, however (Hansen et al.,
1971)

Sheep are apparently not subject to 2,4-D
induced teratogenesis. Binns and Johnson (1970)
administered 2 grams daily for 30, 60, and 90
days following breeding and caused no
malformation. There were presumably 6 sheep per
group but the number in this specific experiment
was not stated....

An interesting observation of 2,4-D distribution
in mouse festuses has been made by Lindquist and
Ullberg (1971). Labeled 2,4-D given late in
gestation accumulated early in the yolk sac,
passed on to the fetus and was almost

completely elminated by 24 hours after
administration. Distribution among tissues was
non-selective, and concentrations tended to
parallel those of the dam, perhaps explaining in
part the lack of teratogenic effect.

141

Carcinogenic and Mutagenic Potential of 2,4-D

Dost (1977) has reviewed the literature pertaining to the
carcinogenic and mutagenic potential of 2,4-D:

Imnes et al. (1969) screened 120 compounds for
tumorigenic properties in mice. 2,4-D and
several of its esters were included; none caused
tumor incidence. Apparently no other _
evaluations of cancer potential of 2,4-D have
been made. A number of mutagenic screens have
included 2,4-D, however. Jenssen and Renberg
(1976) found that 2,4-D would not induce
increased micronuclei in mouse bone marrow
erythrocyte, but the compound did slightly
depress mitotic activity. Sex-linked lethality
assay of 2,4-D in male Drosophila was also
negative for mutagenic activity (Vogel and
Chandler, 1974). Styles (1973) treated rats
with 2,4-D, then used serum from the animals in
a host mediated assay with histidine-requiring
S. typhimurium mutants. No effect of 2,4-D was
evident. Ina screen of 110 compounds with the
"Ames test," using eight histidine-requiring
mutant strains, Anderson et al. (1972) was
unable to detect mutagenic activity by 2,4-D.

Fate of 2,4-D in the Environment

As detailed under a previous discussion on 2,4,5-T,
application of a herbicide may result in residues on or in
four components of the environment: Vegetation, soil,
water, and air.

Vegetation - Morton et al. (1967) found the half life of
2,4-D to be between two to three weeks on forage grasses
when applied at the rate of one pound per acre (Table 14).
Norris and Freed (1966a, 1966b) applied three formulations
of 2,4-D to bigleaf maple under laboratory conditions. Of
the material absorbed, most remained in treated leaves. New
growth, the stem, and roots contained translocated material
in decreasing amounts in the order given. Differences
between formulations were not significant, but differences
in the amounts recovered from various sites in the plant may
account for differential effects on plant foliage, stems,
and roots. The amount of 2,4-D absorbed by the plant
varied, but order of sites in which decreasing amounts of
2,4-D occurred was the same. Any residues not absorbed by
the plant may be washed off by rain or fall to the forest
floor when the leaf falls from the plant.

142

Table 14 - Residues of arbi ide! in forage grass.

Herbicide Residue

Time of Treatment

(weeks )

ne

NDornr ©

2 ,4-p2!

ppm

A’Rate of application - 1 lb/acre (1.12 kg/ha).

2)

— Data from Figure 4 of Morton et al., 1967.

From:

Norris, 1976a.

Soil - As previously discussed, four possible routes exist
for decreasing the amount of pesticide in the forest floor:
(1) Volatize and re-enter the air; (2) be adsorbed on soil
particles; (3) be leached from the soil by water; and (4) be
degraded by chemical or microbial means.

Phenoxy esters are probably rapidly hydrolized to
nonvolatile forms (Norris 1974). Herbicide adsorbed to soil
particles is not biologically available and the leaching
process is slow (the dynamic nature of the
adsorption/leaching process is detailed under Fate of
2,4,5-T in the Environment). Thus, as with 2,4,5-T,

degradation is principally responsible for reducing the

amount of pesticide in the forest floor. Norris (1966)
investigated the degradation rate of two pounds per acre of
2,4-D applied to forest floor material from a red alder
stand. The rate of degradation followed mixed order
kinetics.

Norris and Greiner (1967) studied degradation of 2,4-D in
the forest floor at the rate of three pounds per acre. They
found that the type of litter (e.g., litter beneath red
alder, ceanothus, vine maple, bigleaf maple or Douglas-fir)
did not significantly alter the degradation rate of 2,4-D.
However, the degradation rate for the same chemical form in
high purity formulations was faster than that for commercial
preparations containing impurities, emulsifiers, and
solvents. The 2,4-D degradation rate was stimulated by
simultaneous application of DDT but not affected by diesel
oil. The authors conclude that persistence of 2,4-D "will
not likely be affected by either chemical in field
applications."

143

Norris (1970) also studied the degradation of several
herbicides including 2,4-D, in red alder forest floor
litter. At the end of the 35-day period, only six percent
of the original two pounds per acre treatment could be
recovered. Norris discussed 2,4-D degradation as follows:

The influence of rate of application, presence
of other herbicides, and pretreatment with
insecticides on the persistence of 2,4-D was
determined in the treatments indicated...With
only one exception, no significant differences
were found in 2,4-D recovery at 35 days.

The percent recovery of 2,4-D applied at two
rates is the same. That in the half life
(time to 50 percent decomposition) is
independent on starting concentration,
suggesting that the rate of degradation
follows the first-order rate law. However,
the rate constant was found to vary with time,
which indicates deviation from first-order
kinetics in this test period. This result is
not surprising considering the multiple and
sequential reactions possible in a
heterogenous system.

Newman and Thomas (1949) indicated that specific types of
soil micro-organisms are responsible for 2,4-D degradation.
Subsequent applications of 2,4-D to soil were less
persistent than the initial application, indicating that a
buildup of such organisms occurs and remains in the soil to
speed up degradation of succeeding application of 2,4-D.

Water - Norris (1967) analyzed four 2,4-D treatment areas
representing watersheds with different hydrologic
characteristics. Streams within the watersheds were sampled
for 2,4-D residues at various locations and points in time
following application of two to three pounds per acre
2,4-D. Residue values for the various watersheds will not
be given here. Norris was able to calculate the level of
water intake that could be tolerated by a 150-pound person.
Assuming that a person would respond in proportion to size
the same way as a laboratory test animal (rat) would, and
that a level of 100 times lower than the LD <9 wouldenot

produce any noticeable effect on a person, then the
individual would need to drink 671 gallons of water
containing 2,4-D at 100 ppb to ingest 1/100 of the
hypothetical LD. 9: Norris concludes:

It is clear from the calculated values...that man
can tolerate the concentrations of herbicides in
the water which resulted from the chemical brush
control projects monitored in these studies. A
similar comparison for chronic exposure to low
levels is probably not possible.

144

Of greater interest would be an expression of
biologically safe level of herbicide. This is
defined as that concentration of herbicide which
could be tolerated for extended periods of time
by nearly all members of the food chain with
little or no apparent damage. On the basis of
the data...and on the experience of the Ohio
River Sanitation Commission, this level might be
conservatively set at 100 parts per billion for
the herbicides investigated in this program
(Bond et al. 1959).

The following general conclusions for all herbicides can be
on the basis of studies conducted thus far.

1. Some herbicides (a few ppb) may appear in nearly all
streams which flow by or through treated areas.

2. The maximum concentration (5-85 ppb) is a function of
the proportion of the watershed treated, the amount of
live stream included in the unit, the ratio of the
surface of the stream to its volume, and the degree to
which brush overhanging the stream intercepts spray
materials.

3. The length of persistence (usually a few hours, but it
can be a few days) is a function of the hydrologic
nature of the area treated.

4. Nearly all of the herbicide found in the stream results
from the direct application of spray materials to the
surface of the water.

The land manager concerned with the planning and use of
herbicides should remember the three most important things
learned from these research efforts:

1. Herbicides can be used safely in the forest in most
instances.

2. Avoid the treatment of areas which have high water table.

3. When operating in areas which are particularly sensitive
from a biological or public relations standpoint, stream
contamination can be held to an absolute minimum by
recognizing and avoiding those situations which lead to
direct application to streams or surface water.

Air - No information relating to a human health hazard from
2,4-D suspending in the air from an application to forest
land has been found. However, it is assumed that drift,
regardless of the herbicide, could occur if reasonable
precautions are not observed. Herbicide application
controls as specified in Appendix A are observed in all
Forest Service projects.

145

Summary - "Assuming that maximum herbicide residues in
vegetation will approach 1-200 ppm shortly after
application," (Norris 1974) accumulation of a toxic dose of
2,4-D does not seem probable. Given either the relatively
high concentrations of 2,4-D in the diet or the extended
feeding periods necessary to produce chronic effects (see
2,4-D Chronic Toxicity) in animals, and taking into account
the two to three week half life of 2,4-D on vegetation,
exposure to a chronic dose seems improbable.

Residues of 2,4-D on foliage are expected to remain for only
two to three weeks and in soil for 35 days or less.

Residues in water and air would not be expected to reach
hazardous levels if careful application procedures are
observed. Thus, residue levels resulting from the proposed
applications of 2,4-D are not expected to reach or persist
at levels previously given for acute or chronie CoxicLey.
Finally, no carcinogenic or mutagenic properties apparently
are attributed to 2,4-D.

2,4,5-IP (Silvex)

Silvex is also an auxin-type herbicide. Silvex contains the
contaminant TCDD, as does 2,4,5-T. TCDD will not be
discussed again, in relationship to silvex, since it was
discussed in relation to 2,4,5-T. Less information is
Available on silvex than for eltner 2,4,0 1.00 c2.4c

Silvex - Acute Toxicity

Table 15 gives LD,, values for various silvex
formulations. LD 0 values range from 600 to 2,140 ng/kg
for various caiane species.

Subchronic (90-day) feeding studies at six dosages (Ome LO
30, 100, 300, and 600 mg/kg body weight/day) indicated that
2,4,5-TP has no adverse effects, except a slight liver
enlargement at dosages greater than 10 mg/kg/day. Mullison
(1966) states"...the significance of liver enlargement in
the absence of any pathological tissue alterations is
questionable."

Mullison (1966) reported a 90-day study feeding of rats
exposed to sodium salt of silvex at dosages rates oLei*%0;
Omg. 00 e003 mmand 10" 0lepercent or silvex. Studies at 1.0
percent level were discontinued because rats would not
satisfactorily accept their food. The results of these
studies were: (1) Growth effects were noted at levels
greater than 0.01 percent; (2) hematological measurements
were normal at 0.3 and 0.1 percent levels; and (3) at least
slight changes in kidney and/or liver weights were noted at
all dosages.

146

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Feeding studies using Kurosal®@ sz, a commercial product
containing silvex were also made on beagle hounds. The test
animals were fed dosages of 0.1, 0.03, and 0.01 (percent
silvex) for 89 days. The test also included control

animals. Evidence of adverse effects was observed at the

0.1 percent level (40 mg/kg/day). Mullison (1966) concludes:

We may conclude that Kurosal © sr, is moderate

in repeated oral toxicity when fed as a ‘part of
the diet to male and female beagle hounds for a
period of 89 days. No evidence of adverse effect
was found at the 0.03 percent (13 mg/kg/day)
level or below as judged by general appearance
and behavior, growth, mortality, food consumption,
hematological values, serum urea nitrogen and
alkaline phosphatase determinations, final body
and organ weights, and gross and microscopic
examination of the tissues.

Chronic Toxicity

Mullison (1966) also reports two studies involving silvex
fed to rats and beagles for two Y CADET ey aoeeee rates were
0.01, 0.003, or 0.001 percent Kurosal~™™”SL for the rat
study, and 0.019 percent for female beagles and 0.0056
percent for male beagles.

The results of the rat study were:

The "no ill-effect" level for Kurosal®) SL as
judged from this study is 0.01 percent (100 ppm
in the diet of rats for their lifetime of two
years. Since the acide equivalent of this
formulation is about 53 percent, this level of
Kurosal SL is equivalent to the ingestion of 53
ppm, (2.6 mg/kg/day) of 2(2,4,5-trichlorophenoxy)
propionic acid.

The results of the beagle study were:

As judged from Se sy en the "no ill-effect"
level for Kurosal SL is 0.019 percent (190
ppm) for female beagle hounds, and 0.0056
percent (56 ppm) for male beagles when fed in
their total diet for a period of two years.
Since the acid equivalent of this fo ation is
53.4 percent, these levels of Kurosal SL
are equivalent to the ingestion of 100 ppm and
30 ppm (2.6 mg/kg/day and 0.9 mg/kg/day) of
2(2,4,5-trichlorophenoxy) propionic acid
(silvex), respectively. These results compare
favorably with the 53 ppm, no effect level for
silvex reported previously from a two-year
dietary study in male and female rats,

148

Effects of Silvex Upon Reproductive Functions

The teratogenicity of silvex has been reviewed by Dost
C1977).

Silvex is teratogenic at high doses. Courtney
(1975) found that 398 mg/kg/day, on days 12-15
of gestation, caused 3% cleft palate in the
group given silvex in DMSO subcutaneously, and
7% where given orally in corn oil. Fetal
mortality increased to 25% in the group treated
subcutaneously.

The Dow Chemical Co. has also conducted a
series of teratology studies with silvex.

Dose rates of 75, 100, and 150 mg/kg/day from
day 6 to day 15 caused several cardiovascular
anomalies; 50 mg/kg/day caused retarded
ossification in the sternum and skull.
(Thompson et al., 1972). The no adverse effect
level was considered to be 25 mg/kg/day. The
PGBE ester caused skeletal changes at an intake
of 50 mg/kg/daily but no changes were found
after 35 mg/kg/day (23 mg/kg silvex acid
equivalent).

Carcinogenic and Mutagenic Potential of Silvex

No increase in tumors was found in mice fed a maximum
tolerable dose rate of silvex, 121 ppm for 18 months (Innes
et al. 1961). Point mutations were not detected when
screening silvex against two strains of bacteria (Anderson
etwal.1972:)%

Fate in The Environment and Risk of Human Exposure

Little specific information on residues of silvex in a
forest environment is available. However, silvex itself is
less toxic than 2,4,5-T. Both are closely related compounds
and both contain the contaminant TCDD. The behavior in the
environment and the risk of human exposure for silvex would
be expected to equal 2,4,5-T.

Bailey et al. (1970) studied the movement and persistence of
silvex in water and sediment under impounded conditions.
Application of the PBGE ester of silvex was made at the rate
of 9 kg/ha. Samples were taken 4, 12, 24, and 48 hours
after treatment and analyzed for the presence of the PGBE
ester of silvex. Although the concentration of silvex
initially increased in water, by the end of three weeks the
concentration had decreased to zero. Silvex and the PGBE
ester of silvex can apparently be adsorbed by sediment
particles. However, there was "essentially complete
disappearance" of both at the end of five weeks. A 9 kg/ha
dosage is a considerably greater dosage than would be

149

applied to a forest site

or than would be expected to enter

a forest stream (based on a conversion rate of l lb/acre =

5. Atrazine

1.12 kg/ha, and the usual application rate of 2-4 lbs silvex
per acre).

Unlike 2,4-D, 2,4,5-T, and silvex, atrazine is not an

auxin-type herbicide.
TCDD.

It does not contain the contaminant

The biological effects of atrazine as they relate to
humans include data on the toxicity of atrazine.

The LD. 4 for several organisms has been established:

Table 16 - Atrazine LD.
ee eS ene
Species Formulation Oral Dosage LD. Reference
Albino rats Technical 3,080 mg/kg Geigy Agriculture
Albino mice Technical 1,750 mg/kg Chemicals 1971
Albino rats 80W § lat, Oc40g/ke
Species Formulation Dermal Dosage LD <9 Reference
Albino rats 80W eshay MOR) aye Geigy Agricultural

Chemicals 1971

eee EE

Additional data on toxicity, provided by Geigy Agricultural
Chemicals (1971), indicate that “There has been no evidence
of toxicity in rats subjected to aerosol dust containing the
equivalent of 1.6 mg/liter of technical grade atrazine."

The question of teratogenicity and carcinogenicity of
atrazine has also been addressed, and "Long-term studies in
rats and mice have revealed no carcinogenic and teratogenic
effects either in the parents or progeny following long-term
administration of atrazine," (Geigy Agricultural Chemicals
1971).

The Technical Panel on Carcinogenesis of the Secretary's
Commission on Pesticides and Their Relationship to
Environmental Health (Health, Education and Welfare)
examined the available reports on tests of tumorigenicity
conducted on about 100 pesticidal chemicals and assigned
each of the pesticides to one of four groups: AUB Cat
D. Atrazine was placed in the group containing those
pesticides for which the available evidence was considered
insufficient for judgment (Group C). Atrazine was further
placed in Priority Group C4, one of four priority groups in
Group C. Priority Group C4 was characterized by "Tumor

150

Compound

Atrazine
Atrazine
Atrazine

incidence not elevated in adequate studies conducted in one
species only but current guidelines require negative results
in two animal species for judgments of negativity," (U.S.
Dept. of Health, Education, and Welfare 1969).

Chapter 8 of the Report contains information on tests run by
the Bionectics Research Laboratories of Litton Industries
with various pesticides and related compounds for
teratogenic effects. ''The Bionetics data were reanalyzed
statistically to account for litter effects."

The data for atrazine was placed in a table containing data
on "Tests which showed no significant increase of anomalies

(with particular doses, solvents, or test strains)".

The data for atrazine were as follows:

Increased Total
Dose per kg Mortality Number
Strains Solvent body weight (C57B1/6) of Litters
C3H DMSO 46.4 mg = 6
C57 DMSO 46.4 mg aie aya!
AKR DMSO 46.4 mg —— i

(U.S. Dept. of Health, Education, and Welfare 1969)

Current patterns of atrazine usage and its known fate in the
various components of the environment, indicate that an
accumulation constituting a hazard to any aspect of human
health is highly unlikely.

Fate in the Environment

Kozlowski and Kuntz (1963) found that:

When Plainfield sand to which atrazine, simazine,
or propazine was surface-applied and leached,
most of the herbicide remained in the first inch
of soil regardless of whether two, four, or
eight inches of water was used in leaching.
However, some herbicides, especially atrazine,
moved downward to a six inch depth. With
increased amount of leaching more herbicide was
translocated out of the first inch of
atrazine-treated soil. Such an effect was not
as apparent with simazine- or propazine-treated
soil. The greater leachability of atrazine was
probably related to its greater solubility.

This study, which demonstrates the difficulty of
removing triazine herbicides from upper soil
levels even with large amounts of water,
emphasizes the dangers of possible persistence
and accumulation of triazine herbicides in
forest nurseries, even in light sandy soils.

151

Atrazine is more readily adsorbed on muck or clay soils than
on soils of low clay and organic matter content. The
downward movement or leaching is limited by its adsorption
to certain soil constitutents. Adsorption is not
irreversible and desorption often occurs readily, depending
on temperature, moisture, pH, etc. Atrazine is not normally
found below the upper foot of soil in detectable quantities,
even after years of continuous use.

The residual activity of atrazine in soil at selective rates
for specific soil types is such that most rotational crops
can be planted one year after applications, except under an
arid or semiarid climate.

Atrazine will persist longer under dry and cold conditions
or conditions not conducive to maximum chemical or
biological activity. Broadcast rates needed in some of the
heavier organic matter soils of the North Central states
results in enough residue carryover, under some conditions,
to injure small grains, alfalfa, and soybeans planted 12
months later. Plant removal and chemical alteration are
also factors in dissipation.

Dalapon

Dalapon (2 ,3-dichloroproprionic acid) is a chlorinated
aliphatic acid. It is particularly effective against
grasses, but also controls certain dicotyledonous plants.

Dalapon is very low in acute oral toxicity to all mammals
tested. The acute oral toxicity ratings ranged from an

LD. o> of 3,860 mg of chemical per kg of body weight to an
LD? of 9,330 mg of chemical per kg of body weight. These
coptentrations are considered almost nontoxic. Dalapon has
a dermal toxicity rating which is mildly irritating (Bailey
and Swift 1968). The likelihood of human subjects,
livestock, or wildlife ingesting sufficient amounts of
sodium salapon to cause serious toxic effects is extremely
remote.

The acute oral LD at 95 percent confidence levels for
five different animal species for dalapon were as follows
(Paynter et al. 1960):

Animal Sex LPs
Rat Male 9 ,330
Rat Female 140
Mouse Female 4,600
Guinea pig Female 3,860
Rabbit Female 3,860

Chickens Mixed 5 ,660

152

No evidence has been found that dalapon sodium penetrates
the intact skin in actutely or subacutely toxic amounts in
rabbits (Paynter et al. 1960). Two dogs were each given
sodium dalapon orally by capsule, five days a week during an
80-day period. Doses were 50 mg/kg per day for the first
two weeks and then adjusted upward at weekly intervals to a
maximum dose of 1000 mg/kg per day. Other than vomiting,
the dogs were not adversely affected. During the autopsy
the viscera and body cavities revealed no specific findings
in either dog which could be associated with the oral
administration of sodium dalapon (Paynter et al. 1960).

Ten male and ten female rats were maintained for 97 days on
diets containing 0.0115 percent, 0.0346 percent, 0.115
percent , 0.346 percent or 1.15 percent of dalapon sodium.
In the male rats there was no effect at the 0.115 percent
level, which is equivalent to an average of about 115 mg/kg
per day for young growing animals. In the female rat there
were slight increases in average kidney weights at 0.115 and
0.346 percent levels. There was no evidence of adverse
effects at the higher concentrations of 0.346 and 0.15
percent (Paynter et al. 1960).

Twelve dogs were divided into four groups of two males and
one female. Each group was given 0, 15, 50, or 100 mg/kg
per day of dalapon sodium by capsule, five days a week for
52 weeks. The test dogs exhibited normal behavior, gained
weight, and exhibited outward reactions attributable to the
test material. The animals on 100 mg/kg per day dosages
showed an increase in average kidney weight. There was no
significant difference in the tissues from the control dogs
and the test dogs (Paynter et al. 1960).

Mature rats were given 5, 15, and 50 mg/kg of dalapon sodium
per day. No adverse effects were reported except that at 50
mg/kg per day there was a slight average increase in kidney
weight. Over a period of approximately 18 months, a total
of 2,476 rats in 261 litters were involved in the
experiment. The animals were given a diet containing 0.0,
0.1, or 0.3 percent dalapon sodium (Paynter et al. 1960).

Soil - Dalapon breaks down rapidly in soil, hydrolzes slowly
in water, but is persistent in plants. Thiegs (1955) showed
that the breakdown of dalapon in soils is due to
micro-biological action. Dalapon was found to decompose
most rapidly in warm, moist soils, whereas in cool or dry
soils the herbicide remained for extended periods.

Day, Jordan, and Russell (1963) reported that Jansen found
that soil fungi and a species of agrobacterium as well as
certain pseudomonads, decompose dalapon in the soil.
Dalapon may well be utilized by a wide range of soil
microorganisms, since its addition to soils has been
observed to have had a broad stimulating effect on soil
microflora (Day et al. 1963, Fletcher 1963).

oo

Day, Jordan, and Russell (1963) report on the persistence of
dalapon under laboratory conditions in 43 soils collected
from California citrus districts. The rates of
decomposition of dalapon were highly variable among the
soils studied, apparently due to differences in the
population of soil microorganisms capable of decomposing
dalapon. Decomposition of dalapon ranged from complete
disappearance in less than two weeks to the retention of
two-thirds of the added dalapon after eight weeks. The
capacity of the soil to decompose dalapon was essentially
random with respect to soil series, texture, cation-exchange
capacity, total organic matter, and geographical source.

Plants - As dalapon enters the plant, it is moved about
through the plant systems and may be excreted from the roots
into the surrounding soil as dalapon. It apparently is not
metabolized by the plant to any appreciable extent. Tests
with carbon 14-labeled dalapon show evidence that dalapon is
neither metabolized nor broken down by either susceptible or
resistant plants, but remains in the plant tissue as dalapon
(Leasure 1963).

Dalapon is readily absorbed through the roots, but seems to
be more systemic in its action when applied to foliage.
Dalapon is absorbed and translocated by plants. Once in the
plant, it is relatively stable and not readily metabolized.
Dalapon is transported readily in both phloem and xylem and
has proved useful as both a foliar spray and a soil
application for controlling susceptible weed species.

Water - Dalapon is apparently more persistent in water than
in soil. Oxygen levels are lower and microbal populations
are therefore different. Anaerobic species are favored in
aquatic environments, whereas aerobes usually predominate in
agriculture soils, particularly in the surface-soil layers.
Most microorganisms that effectively decompose herbicides
are aerobic (National Academy of Sciences 1968). Warren
(1964) reports that dalapon will hydrolize slowly depending
upon temperature unless some microorganisms are present.

Frank, Demint, and Comes (1970) provide data concerning the
concentration and persistence of dalapon in irrigation water
following tests on canal-bank treatments for weed control.
On the canal where dalapon was sprayed directly on the water
surface to provide a concentration of 100 ppb at the
application site, it was calculated that the residue level
would approach zero 20 miles downstream.

Frank, Demint, and Comes (1970) concluded that dissipation
of freely water-soluble herbicides, not extensively absorbed
from water solutions is affected principally by dilution.
They also concluded that it is unlikely that illegal

residues would be contained in crops irrigated with water
containing the concentration of dalapon found in their study.

154

Period
after

treatment
(days)

7
14
30
60

Dicamba

Dicamba is a broad spectrum herbicide useful for site
preparation, right-of-way clearing, weed control, and other
uses. The toxicity of dicamba to several species of animals
has been investigated.

Rabbits and guinea pigs are twice as sensitive to dicamba as
are rats. The oral LD, was 566 and 1,068 mg/kg
respectively. (Velsicdl Chemical Corporation Bulletin 521-2)

Dicamba was fed for 13 weeks to male and female rats at the
rate of 100, 500, 800, and 1000 ppm of the diet. Food
consumption and growth rate remained normal, no deaths
occurred, and pathology at the end of seven weeks was
negative. At the end of 13 weeks, there was some liver and
kidney pathology at the 800 and 1000 ppm level, but none at
or below the 500 ppm levels. Rats fed at 5, 50, 100, 250,
and 500 ppm of diet, and dogs fed at 5, 25, and 50 ppm of
diet, sowed no apparent effects after two years of
continuous feeding.

The dimethylamine salt of dicamba administered undiluted to
the skin of rabbits and rats produced a very mild irritation
when administered daily for two weeks. When diluted 1:40 in
water, no irritation was observed even after 30 days. There
was no evidence of systemic toxicity from absorption through
the skin (Velsicol Chemical Corporation 1974). No evidence
of toxicity due to inhalation has been noted. Rats on a
diet containing 500 ppm dicamba for three or four months did
not produce evidence of teratogenicity over a three
generation study (Velsicol Chemical Corporation 1974).

Fate in the Environment

Vegetation - Dicamba is not very persistent in plant

tissues. Dissipation can occur by metbolism within the
plant, exudation from the roots, and loss from the leaf
surface by washing, photodecomposition, or chemical
decomposition (Velsicol 1969). Dicamba and its metabolites
(5-hydroxy-2-methoxy-3, 6-dichlorobenzoic acid, and 3,
6-dichlorosalicylic acid) were dissipated rapidly from
bluegrass and bermuda grass as shown in the following table
(Velsicol 1969):

5-hydroxy-2 methoxy De omcarchloro—
3,6-Dichlorobenzoic salicylic
Dicamba (ppm) acid (ppm) acid (ppm)
2a Dee baw LOLS 25 1b DLD 10 lb
sillovl ART FO) 33. Omele 3 135.0 negligible (less
AA SS best se) ELA) LA Dee Seed, Slee) than 0.05 ppm)
Se eye) PAT 1i29 2.60 42.2 amounts in all
4.0 4.5 122) hha L139 Loo cases.

Similar dissipation patterns were found from green tissues
of silver beardgrass, little, bluestem, dallisgrass, and
sideoats grama (Morton et al. 1967). It should be noted
that both metabolites of dicamba are of low order toxicity.
Both metabolites are also herbicidally inactive.

Soil - Dicamba is relatively easy to leach from surface
layers of soil. Comparatively, dicamba is considered one of
the most mobile of the herbicides after it enters the soil
(Velsicol Chemical Corporation 1971).

Dissipation of dicamba in the soil has been studied (Sheets
et al. 1964, Burnside and Lavy 1966, Chirchillo 1968,
Velsicol Chemical Corporation 1971). It was found that
degradation by chemical and/or microbial action was most
rapid when soils were at or near 80 percent field capacity
and at 25° to 35° C. Under these conditions, breakdown

of the chemical was complete within a time frame of one to
two months. The rate of biodegradation increases with
temperature; reaching maximum at about 28 to 35 C. At
somewhere near 50 percent moisture biodegradation reached
maximum and then declines with increasing moisture. These
temperatures and moisture contents are conducive to
bacterial action. Audus (1964) and Cain (1966) found that
Bacillus cereus var. mycoides was capable of breaking down
dicamba and stated that this bacterium is a common organism,
found widely distributed in the soils.

Studies by Velsicol Chemical Corporation (1971) found that
dicamba was rapidly broken down or leached to deeper layers
of soil. There is some evidence that dicamba may be broken
down by photodecomposition (Velsicol Development Newsletter
Vole 1 F2)%

Water - Norris and Montgomery (1975) state that dicamba is
one of the most mobile herbicides in soil. They add that

entry into the soil profile reduces the probability of the
herbicide entering streams by overland flow except during

the first intensive storms after application.

Evidence obtained from stream monitoring, following an
application of dicamba, leads Norris and Montgomery (1975)
to conclude that dicamba posed no acute hazard to aquatic
organisms or to downstream water users, and the short
persistence of the herbicide in the water precluded chronic
exposure. They stated that dicamba can be used for brush
control on forest lands with little or no impact on aquatic
environment, if direct application to surface waters is
minimized by using appropriate spray application techniques.

Since the dimethylamine salt of the acid of dicamba is quite
soluble in water, photodecomposition might be one of the few
ways breakdown occurs in water. Uptake by stream or pond
vegetation and ultimate metabolism by the plants would also

156

contribute to clearing water of the chemical. Precautions
should be taken to avoid contamination of waterways, ponds,
or lakes (Velsicol Chemical Corporation, 1971).

Amitrole

Amitrole is also a broad spectrum herbicide like dicamba.
It can be used for conifer release and site preparation.
Like previously discussed herbicides, amitrole has been
tested to determine its toxicity to rats.

Dietary levels of 1,000 and 10,000 ppm of amitrole
administered to rats for 63 days resulted in altered body
weight gain and fatty metamorphosis of liver cells (Weir et
al. 1958). After 68 weeks of a two year feeding trial on
rats, levels up to 50 ppm had no effect on females but males
had enlarged thyroids. Poisoning symptoms have not been
noted for pure amitrole. In the event of ingestion of
amitrole-T, thiocyanate poisoning should be suspected. The
acute oral Ld 0 of NH SCN is 750 mg/kg (rats) (Weed

Science Sacmeey of America 1967).

Amitrole has been suspected of being teratogenic and
carcinogenic. Carcinogencity suspicions generated the
"cranberry scare" of 1958 to 1959. Later reports, however,
indicate that amitrole does not represent any unusual hazard
(House et al. 1967). No teratogenic effects attributed to
amitrole were found in treated hen's eggs (Dunachie and
Fletcher 1970).

Amitrole is an antithyroid agent and has been tested for
controlling hyperthyroidism. The stimulation of abnormal
growth of the thyroid gland after feeding high dosages of
amitrole has been construed as evidence of carcinogenicity.
In chronic feeding studies involving exaggerated rats fed
over a long period of time, thyroid tumors began appearing
in rats fed at 100 ppm for 68 weeks (Weir et al. 1958).

Exposure to amitrole among Swedish workers has resulted in a
significantly higher incidence of tumors and mortality. The
effects described are similar to those described in animal
experiments with amitrole. The investigators suggest that
safety precautions be observed when working with amitrole
(Axelson and Sundall 1974).

Fate in the Environment

Amitrole residues could not be detected two months after
application of one to two pounds per acre on three soil
types in Oregon (Norris 1970a). Amitrole was absorbed in
red alder humus more rapidly than it was desorbed (Norris
1970a). After 35 days, recovery of amitrole from red alder
forest floor material had dropped to 20 percent (Norris
1970b). The presence of 2,4-D or ammonium thiocyanate are
not likely to influence the persistence of amitrole in the

is?

field (Norris 1970b). Degradation of amitrole proceeded at
a near normal rate in steam-sterilized forest floor material
despite nearly complete absence of biological activity
(Norris 1970b).

Amitrole appears to become tightly absorbed to soil
particles and can complex metals (Sund 1956). Amitrole
disappears rapidly from soils; however, disappearance has
been attributed to adsorption, microbial degradation, and
nonbiological destruction as pointed out in a literature
review by Carter (1969). Evidence indicates that
nonbiological destruction is the most important cause of
amitrole disappearance in soils (Carter 1969).

Water - Amitrole was not degraded by biologic action in
river water, sewage, activated sludge, or anaerobic
digestion tests (Ludzack and Mandia 1962). Amitrole
interfered with nitrification in river water and activated
sludge. Chlorination degraded amitrole to unidentified
compounds. Studies of amitrole contamination in streams
following aerial applications indicate that maximum residues
occur immediately after spraying and decline rapidly
(Marston et al. 1968, Norris 1967, Norris et al. 1966,
1967). A maximum concentration of 155 ppb at the downstream
edge of a 100-acre unit treated at two pounds per acre was
attained 30 minutes after application began (Marston et al.
1968). The concentration decreased to 26 ppb by the end of
the two hour application and to non-detectable amounts six
days after spraying. No amitrole was detected more than 1.8
miles below the sprayed area.

In another study, maximum concentration immediately
downstream from the sprayed area was 422 ppb 0.17 hours
after spraying and dropped to 6 ppb eight hours after
spraying (Norris 1967). Residues did not persist into the
next year and heavy rains six months after application did
not introduce measurable amounts of amitrole into the same
stream (Norris et al. 1966, 1967).

Norris (1971b) concluded that the relatively large doses of
amitrole required to produce acutely toxic responses in most
nontarget organisms are not likely to occur from normal
chemical brush control operations on forest lands. The
short persistence, lack of biomagnification in food chains,
and the rapid excretion by animals prevents chronic exposure
and, therefore, chronic toxicity.

Picloram
Picloram has the chemical name 4-Amino-3,5,6-trichloro-
picolinic acid. It is usded for the control of annual and

deep-rooted perennial weeds in noncropland and rangeland.
Its primary forestry use is for site preparation.

158

Picloram has very low, acute oral toxicity. The LD

values range from 2000 mg of picloram per kg of body weight
in mice and rabbits, to 8200 mg of picloram per kg of body
weight in rats. A single dose of up to 500 mg per kg gave
no evidence of toxicity in calves. Picloram causes minimal
skin irritation and is not likely to be adsorbed through the
skin. Although the picloram dusts may be somewhat
irritating, they are not likely to cause illness when
inhaled. Picloram may cause mild irritation to the eyes,
which heals rapidly, and results in no corneal injury (Weed
Science Society of America 1967).

Chronic exposure to picloram shows little or no ill effects
on test animals. Feeding studies conducted for 90 days with
rats showed no adverse effects from dietary levels as high
as 1000 ppm of picloram (McCollister et al. 1969). In
long-term feedings, albino rats and beagle dogs were fed
picloram at a rate of 15 to 150 mg per kg of body weight for
two years. No observable adverse effects were noted in
either species as measured by body weight, food consumption,
behavior, mortality, hematological and clinical blood
studies, or urine analyses.

Picloram apparently has no teratogenic effect. Albino rats
fed picloram at various levels up to 3000 ppm showed no
adverse effects in terms of fertility, gestation, viability,
and lactation through three generations (McCollister et al.
1969). No information was found concerning the
carcinogenicity of picloram.

The chemical was evaluated using the procedures established
by the joint FAO/WHO Expert Committee on Food Additives. A
100-fold safety margin was used. The acceptable daily
intake of picloram for man is calculated to be 1.5 mg/kg of
body weight per day. A well-fed person in the United States
would consume 0.1 mg per day if he ate meat from animals
that grazed continuously on grasses containing 200 to 400
ppm of picloram. This is a fraction of the 90 mg/day that a
130-pound human could safely. consume; representing a safety
margin of 90,000 to 1 when compared to safe levels
deomonstrated in laboratory animals (McCollister and Leng
1969).

Fate in the Environment

Vegetation - Residues of picloram in woody plants in
tropical areas ranged from 31 to 687 ppm immediately after
spraying two pounds of active ingredient per acre. This
dropped to less than one ppm a month later (Bove and
Scrifres 1971).

Soil - Studies of persistence of picloram in soils (Hamaker

et al. 1967) have shown that with initial rates of one ounce
and two pounds acid equivalent per acre, the time for

do

decomposition to concentrations of 0.01 ounces per acre
would be 4.5 months and 4.6 years, respectively. The
half-life in soil of a herbicide may be a better measure of
persistence. Half-life is the time that is required for
half of the herbicide applied to the soil to be inactivated
or to disappear. Picloram degrades in soils with a variable
half-life of from 1 to 13 months (Goring et al. 1965). Most
investigators agree that dissipation is accelerated at
higher temperatures (Bovey and Scrifres 1971).

Norris et al (1976a) studied the leaching and persistence of
picloram on powerline rights-of-way in the Pacific
Northwest. The herbicides showed a rapid decline in
concentration in forest floor and soil after application.
Biologically significant residues were seldom present for
more than 12 months after application. There was no
leaching of herbicides below 30 cm in the soil and
relatively little below 15 cm. When a forest floor was
present, nearly all the detectable herbicide was present
there.

Norris et al. (1976b) reported picloram applied to a
southern Oregon hillside pasture was largely confined to the
surface six inches of soil and the concentration declined
rapidly with the time after application. Residues in the
surface six inches averaged 60, 20, and 4 ppb picloram 9,
18, and 27 months, respectively, after treatment.

Water - Norris et al (1976a) reported no residue of picloram
was found (minimum detectable level 0.1 ppb) in streams
flowing across treated powerline rights-of-way despite
intensive sampling with automatic equipment for periods in
excess of six months after application. The authors
conclude the lack of residues in stream water is consistent
with the relatively short persistence and limited mobility
of picloram in the environment.

Norris (1969) noted that in an area where 67 percent of a
watershed was sprayed in August, residues up to a maximum of
0.078 ppm were detected after the initial one inch storm and
they decreased thereafter. No residues were found after
late October or where only a small portion of the watershed
was treated.

Norris et al. (1976b) studied picloram outflow from a
16-acre hillside pasture watershed in southern Oregon. The
entire watershed was sprayed in June with two pounds per
acre picloram, including the stream channel. There was no
water in the stream until October. The first two storms
caused limited wetting of the stream channel and filled the
pools, but caused no outflow from this gauged watershed.
Maximum picloram concentration was about 0.1 ppm. The first
water to flow from the watershed carried some picloram, but
the concentration was low (20 ppb). No herbicide was
detected after January.

About 0.28 percent of the picloram applied to the watershed
appeared in streamflow during the three year study. The dry
stream channel accounts for 0.21 percent of the area of the
watershed. The authors concluded the herbicide outflow
largely represented mobilization of residues applied in and
near the dry stream channel.

10. Monosodium Methanearsenate (MSMA) and Cacodylic Acid

These two similar herbicides are used for thinning and
plantation release. In contrast to the previously discussed
herbicides, they are only applied by injection. The mode of
action and dermal penetration of organic arsenicals and the
fact that arsenic is one of the heavy metals poses more of a
hazard to operators than many other compounds with similar
LD.,'s. Special care must be exercised in providing
personal protection,

The toxicity of MSMA, as expressed by the acute oral
toxicity, is about the same in rats as cacodylic acid. The
LD., of technical grade MSMA (92.8 percent pure), is 1,400
meite for male rats. The oral LD., is 1800 mg/kg in rats
and 700 mg/kg in mice (Dickinson 1872).

The LD for a person is estimated to be about 1800

mg/kg.° The approximate dose necessary to cause the death of
a 150-pound human is 120 ml or about 1/2 cupful (Washington
Pest Control Handbook 1971).

MSMA is also known to be mildly irritating to the skin in
rabbits, but the Washington Pest Control Handbook (1971)
reports that cacodylic acid causes little or no skin
irritation. No data on the chronic effects of MSMA was
available. Both MSMA and cacodylic acid have similar
potential to be either teratogens or carcinogens. The
precise toxicity levels of cacodylic acid and monosodium
methanearsenate in humans is not known. Both cacodylic acid
and monosodium methanearsenate have a toxicity rating of
four. The safe use of organic arsenicals depends on
minimizing the exposure of anyone handling these chemicals.

Industrial Bio-Test Laboratories, Northbrook, Illinois,
found that 50 percent cacodylic acid resulted in an LD 0

of 1800 mg/kg in male rats and 1000 mg/kg in female ache:
Technical grades of cacodylic acid (61.3 percent cacodylic
acid) produced similar results, 1400 mg/kg in male rats and
1280 mg/kg in female rats (Ansul 1967).

Cacodylic acid is considered to be a teratogenic agent, as

in MSMA. Early studies indicated arsenic to be a carcinogen
but later studies failed to demonstrate arsenic~induced
cancers. The Secretary's Commission on Pesticides has placed
cacodylic acid in group C4 (not positive for carcinogenicity
in one species). MSMA is placed in the same C4 group.

161

Nake,

12h

Laboratory tests for mutagenicity have shown cacodylic acid
causes cell division when injected into mice. Significance
of the findings to field exposure is not known.

Krenite

Krenite (ammonium ethyl carbamoylphosphonate) has a very low
acute and chronic toxicity. The LD., for the male rat is
24,400 mg/kg. It has a relative low acute inhalation
toxicity (DuPont 1976). No long term feeding studies have
been undertaken as Krenite is not registered for food crop
use,

Fate in the Environment

Greenhouse soil disappearance tests with Gel abeled
Krenite indicated about a 10-day half-life. Under field
tests the half-life was about one week. Because of rapid
degradation there was little or no downward movement of
Krenite or its degradation products (Du Pont 1976).

Krenite is soluble in water but readily absorbed by soil
particles. Therefore, it does not have the potential to run
off into surface waters or leach into subterranian aquifers.
It has a Freundlick K equilibrium constant on Keypart silt
loam greater than 20, indicating a high absorption to the
soil (Du Pont 1976).

Simazine

Simazine has low toxicity to animals and probably also to
man, since there have been no reports of poisoning from
ingestion. Neither have there been any serious eye or skin
irritations reported from either experimental or commercial
use, despite the fact that simazine has been in use since
the late 1950's.

Acute Toxicity

The acute oral toxicity (LD, ) of simazine to rats, mice,
and rabbits is in excess of Rive g/kg of body weight (Geigy
Agric. Chemical 1970). Cattle fed 250 mg of simazine/kg of
body weight as a drench showed poisoning symptoms after one
dose, but survived three doses with 11 percent weight loss
(Palmer and Radeleff 1969). The acute dermal LD_. to
albino rabbits is greater than 10 g/kg. (Geigy aie.
Chemical 1970)

Chronic Toxicity

No sign of systematic toxicity was observed in rats when fed
daily dosages of 100 ppm of simazine 50W in their diet.
However, two yearling calves showed symptoms of poisoning

162

E32

after 3 and 10 doses of 25 mg/kg of body weight, while sheep
fed the same amount of simazine for five weeks remained
normal. (Geigy Agric. Chemical 1970)

Fate in the Environment

The half-life of simazine in soil varies indirectly with
temperature (Burschel 1961). At 25 See 50 percent of four
ppm od isappeared in 20 days, at 18°C in 39 days, and at
8.5°C in 140 days (Sheets 1970).

Soil - Simazine has little lateral movement in soil but can
be washed along with soil particles. Leaching is limited by
its low water solubility and adsorption to certain soil
constituents. It is more readily adsorbed on muck and clay
soils than in soils low in clay and organic matter (Weed
Science Society of America 1974).

Water - The low to moderate mobility of s-triazines (of

which simazine is one) reduces the possibility of
contamination by vertical leaching to ground watec.
Surface movement is somewhat more likely on steep slopes
when intense rainfall occurs immediately after application
(Helling 1970).

Air - Simazine is more volatile from dry soil than from wet
soil. Soil type and temperature, however, do not seem to
affect the rate of volatilization of simazine (Kearney et
al. 1964). The volatilization of simazine at 60°C was
found to be 35 percent in 24 hours (Foy 1964).

Dichlorprop

Dichlorprop (2,4-DP) has the chemical name of 2-(2,4-dichloro-
phenoxy) propionic acid. Its primary forest use is for brush
control along forest roads. It suse is very limited and,
therefore, it is mentioned in this statement only as a basis
for comparison with other herbicides.

Acute Toxicity

According to the toxicity summary for weedone brushkiller
170, the oral LD., is 375 mg/kg of body weight. Toxicity
via the inhalation route of dermal application is thought to
be minimal. Slight to moderate occular irritation may occur
from direct administration of the compound into the eye or
conjunctival eye sac of rabbits (Amchem).

Chronic Toxicity

No sign of systematic toxicity was noted in rats fed 12.4 mg
per day for 90 days.

163

Mutagenic Potential of Dichlorprop

Tests for point mutations were not detected when screening
dichlorprop against two strains of bacteria (Anderson et al.
1972).

Fate in the Environment

The median tolerance limit (TLm) of bluegill’ sunfish to
dichlorprop is as follows:

Acid Equiv. Ppm

24 hours 48 hours
Dimethy lamine 165 165
Isooctyl ester 16 16
Butoxyethanol ester | bad tai

(Hughes and Davis 1963)

In evaluating the effects of dichlorprop on fertilized fish
eggs and fry, no reduction in the survival period of the fry
was noted (Hiltibran 1967).

It has been observed in greenhouse studies that dichlorprop
after 103 days restricted root growth of alfalfa seedlings
(Burger et al. 1962).

III. FAVORABLE EFFECTS

A.

Non-Living Components

Herbicides are effective and the results are long lasting.
When compared to the other vegetation management
alternatives, only herbicides can give lasting control of the
pest plant's root system. The problem of sprouting or
regrowth of pest plants can not be overcome without good root
control Herbicides can give this control without disturbing
the humus layer, accelerating erosion, or possibly reducing
site quality through soil compaction. The diversity of
vegetation and new stands of trees or grass encouraged by the
selectiveness of many herbicides adds to the visual richness
of the Eastern Region.

The use of manmade ponds for fishing and swimming is often
possible only if unwanted algae and weeds can be controlled.
Herbicides and algaecides are available that will allow
control without harmful effects on the quality of the water.

164

Be

Living Components

Long-term studies have shown that most hardwood and conifer
Species respond favorably to full release at the juvenile
(5-10 years) stage of their growth and development. These
responses are displayed by improvement in the rate of
survival and the acceleration of individual tree growth.
Survival among young hardwoods and pine has been increased
by 15 percent to 20 percent through early release, with
individual trees of other species growing 3-1/2-4 times
taller than non-released individuals. Diameter growth is
also improved on the released trees. Twenty-two years after
treatment, 50-year old white pine trees in Minnesota had an
average diameter 3.3 inches larger than those not released.
Beneficial response to release is reflected in a greater net
growth (total cordwood or cubic feet yield) than
non-released stands. Spruce volumes can be increased 25
percent to 40 percent through early release. Most
significant is the early development of a sawtimber
component in the released stands as the result of improved
height and diameter growth. This early development of
sawtimber volume under certain growing conditions makes
early release in pine a sound forestry investment.

Herbicide use helps man to continue the historical
vegetation composition of many local forest areas. A
heterogeneous forest has been found to be more resistant to
insect and disease losses. In addition, plant diversity
benefits many species of wildlife. Wildlife food sources
can increase, as overhead canopies are opened up. Crowns of
remaining mast producers are stimulated and production is
increased. A greater variety of herbage becomes available
to browsing animals. A number of insect feeding
woodpeckers, cavity nesting birds, and small mammals benefit
from dead trees left standing following the herbicide
treatment. Wildlife openings once naturally created and
maintained by wildfires can now be managed by using
herbicides.

Social Economic Components

The labor savings made possible by the use of selective
herbicides on right-of-ways for the control of woody species
that would endanger powerlines, inhibit visibility, and
present other safety hazards have allowed maintenance people
to use a greater part of their budgets for providing better
roads, railroad beds, and utility transmission systems.
Besides being costly, other alternatives of brush removal
involving repeated removal followed by stacking and burning,
often resulted in escaped fires.

165

In timber management, a valuable wood resource can be
established to supply the Nation's growing demand for wood
fibers. In some cases, up to a 300 percent increase in high
quality wood production will occur. This will aid the
economic and social conditions of the local communities.
Increased forest output will increase returns both to the
Federal government and local counties from stumpage
payments. Another favorable effect of herbicide use is the
maintenance of a National timber supply which includes a
continual, competitively available, renewable resource that
requires minimal energy to go from raw material to end
product. In contrast, alternatives to wood products are not
renewable and conversion from raw material to consumer
product frequently requires a lot of energy.

The use of herbicides to quickly and effectively manage
vegetation frees available work crews for other needed
projects. The National Forests have a long list of needed
labor intensive work projects that can only be completed by
crews using hand tools. These projects; hiking trail’) camp
ground, and picnic area construction; creating wialars
openings; thinning and pruning of trees, etc., have few Lf
any alternatives to completion by hand aor, Government
efforts to employ people will produce the greatest benefits
to the Nation if work is accomplished in those areas where
alternatives to manual labor do not exist.

The aerial application of herbicides is less energy
demanding than completing the same release with work crews
using hand tools. A helicopter, while consuming 20-30
gallons of aviation fuel an hour, releases 50-100 ac/hour
(about 2.5-3.3 ac/gal of fuel). In comparison, a crew of
four people commuting to a work project in a car each day
would complete about one acre of release for each gallon of
fuel used. Accomplishing 10,000 acres of release work by
helicopter could result in a substantial fuels saving.

Herbicides are making more animal protein available at a
lower cost through improved pastures and rangeland.

As mentioned earlier, under the objective in Section I,
favorable effects of herbicide use are protection and
production orientated, resulting in improved economic
welfare and community stability.

IV. SUMMARY OF PROBABLE ADVERSE ENVIRONMENTAL EFFECTS WHICH
CANNNOT BE AVOIDED
A. Non-Living Components
1. Air. Minor losses of herbicide will occur through
volatilization. The amount of volatilization will be

greatest with aerial methods of herbicide application.
These losses can be greatly minimized, but not

166

completely eliminated. Once in the air, photo-alteration
can alter the chemical makeup of the herbicide.

Hazardous Substances. The hazardous substance - 2,3,7,8
Setetrachioro dibenzo — p — dioxin (TCDD) ~- is present
in 2,4,5-T and silvex. Pure TCDD is reportedly the most
toxic synthetic chemical known. In laboratory tests,
both TCDD and 2,4,5-T have demonstrated the biological
potential for producing teratogenic and mutagenic
effects and an increased tumor incidence. Risk to
humans, while apparent, is not real, due to the minute
volume of TCDD applied per acre and the near absence of
human exposure to most treatment areas.

Workers handling herbicides are exposed to safety risks
normally associated with chemical use. The hazard is
minimized through established safety practices and
standards.

Land Ownership - Land Use. Adverse land use patterns of
National Forest lands are not anticipated following
herbicide use.

Soils. The forest soils can be a major receptor of
herbicides. The amount of herbicide actually reaching
the soil can be minimized, but not completely
eliminated. The herbicides proposed for use have not
been found to accumulate in the soil, leach out, or move
overland abnormally.

The possibility of an accidental herbicide spill during
spray application or transportation of the containers
always exists. If such a spill should occur, some
concentrated herbicide could end up in the soil. The
greatest volume, but the least concentration of
herbicide, 5-10 percent, would occur from an accidental
spray rig spill. An accident involving 30 or 55 gallon
drums of pure herbicide would be the most adverse. The
chance of such an accident is very minor.

Visual. Visual and aesthetic values are generally
lowered during brown out; however, the effect is
temporary and lasts only until leaf fall. A longer
lasting visual impact is created by the standing dead
trees that will remain for several years.

Water. Herbicides which vaporize during application or
from vegetation eventually precipitate out, some
directly into water. Such contamination will be of
extremely low intensity, but unavoidable. Accidental
herbicide entry directly into waters adjacent to forest
treatment areas has not been found to exceed the EPA's
potable water standards. Investigations have shown a
100-fold dilution rate, with downstream movement of 1

1G,

mile and a maximum possible human exposure level of 0.01
ppm for 24 hours when measured immediately downstream
from a treated area.

With the decrease in vegetation on a treatment area, an
increase in stream flow will occur. Small treatment
areas make flow increase very minor. Flow will return
to the before treatment levels in 1 to 10 years,
depending on the amount of vegetation removed. This
change in stream flow can also be beneficial and could
be a goal of vegetation management.

Where the goal is conifer management, water quantity
will be less than if the same area were in grass or
hardwoods. Permanently foliaged conifers intercept, as
well as transpire, more water than do deciduous
hardwoods or grasses.

B. Living Components

Me

Domestic Animals. No direct adverse affect to livestock
is anticipated; however, an indirect effect may occur
through changes in the palatability of poisonous or
nitrate accumulating plants which may be consumed by
livestock trespassing in sprayed areas.

Man. Individuals involved with manufacturing, handling,
and applying the herbicides face the greatest hazards.
A lesser risk exists for those who might accidently
intake herbicide residues through forest water, fruits,
berries, or meat of wild game or fish. No direct,
unavoidable effects to man are anticipated when
herbicides are used according to label use directions,
safety precautions are taken, and standards established
for reducing risks are followed.

The noise made by mechanical herbicide applying
equipment may annoy some people. There is also an odor
associated with most herbicide uses that some people
find offensive.

Soil Organisms. There is no evidence to indicate that

the herbicides proposed for use, when applied at

recommended rates, will have any lasting effects on soil
organism populations.

Vegetation. Following herbicide use, there will be an

immediate reduction in the number of plants within the
treatment area. Some nontarget plants may be adversely
affected. Endangered or threatened plants, if present,
or their specialized micro-habitats, may be inadvertently
damaged or destroyed as a result of herbicide use.

168

Forest Vertebrate Animals. Herbicide applications will

occur on areas occupied or visited by a significant
number of wildlife species. The major impact will be a
long-term, subtle change in habitat. This habitat
change will occur with any of the vegetation management
alternatives considered and in the long run, is more
adverse than any immediate effects of herbicide
application.

The activities of man and his equipment during herbicide
application will disturb wildlife. Other treatment
methods considered would have a similar effect, probably
of longer duration.

Direct toxic effects are not anticipated.
Forest Invertebrate Animals. A significant hazard to

forest invertebrates is not expected as a result of our
proposed herbicide use in the Eastern Region.

V. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT
AND MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY.

A. Non-Living Components

I.

Air. Mature forests are low producers of oxygen.
Decaying forests are oxygen consumers. Using herbicides
to increase new stand growth, following the harvest of
mature stands, may contribute briefly to local air
pollution. The long-term affect, however, is an
increase in the quantity of oxygen and the quality of
the air.

Hazardous Substances. The benefits of herbicide use
continue to be weighed against risk. It is well
documented that many of the herbicides proposed for use
can produce toxic effects in test animals. These tests
should be used to show the potential risks involved with
misuse.

Such tests, however, bear little resemblance to field
applications proposed for use in the Eastern Region. To
achieve toxic dosages in tests, the testing techniques
frequently involve high dosage rates, extended periods
of exposure, forced feeding, subcutaneous injections,
exotic solvents, and the use of inbred strains of
laboratory animals. The small quantity of herbicide
available at any one forest location, the scattered
location of treatment areas, the short life of applied
herbicides, and the type and frequency of human activity
in the treated areas make the hazards of herbicide use
under field conditions improbable. In addition, there
are other sources of food, other than those treated with
herbicides, available to wildlife.

169

Land Ownership - Land Use. Most rights-of-way, ULility:
and transportation needs are long-term. Periodic
maintenance of vegetation using herbicides is necessary
to protect the investment costs for establishing these
land uses. The number of people benefiting from such
facilities is great and the benefits long-term.

Soils. The use of herbicides has an indirect affect on
the soil. The immediate effect is reduced vegetative
cover. The long-term effect is usually a vegetative
cover that better protects soil stability.

Visual. A direct result of herbicide application is a
brown-out or dying of the treated vegetation. The
visual signs of the foliage color change is only
seasonal, while evidence of dead twigs and stems will be
longer. Flowering plants soon cover many herbicide
treatment areas. They in turn, give way to a richness
of contrasting vegetation types that will long please
the users of the National Forests. Many of the young
pine stands and pastoral openings seen in the forests
today are partially the result of herbicide use.

Water. The long-term affect of herbicide use on water
is indirect. The kind of vegetation to which eventually
occupies an herbicide treated area will affect water
output. Grass stands will provide the most water
outflow, followed by hardwoods, and finally conifer
stands. Where no change in major vegetation type
occurs, water quantity outflow is minor and can return
to before treatment levels in 1 to 10 years.

Application of approved algaecides and herbicides
directly to water for weed control may necessitate
closure of the water body to human, livestock, or
irrigation use for a period of days. The results of
treatment however, can make the water usable for a
variety of activities which can be enjoyed for a period
of months.

B. Living Components

i

Domestic Livestock. Most livestock operations are based
on long-term management plans. A sudden consumer demand
for more meat cannot be met until forage is available
and animal numbers are increased. Maintenance of
grazing areas in forage production contributes to the
long-term livestock production needs of the Nation.

Man. The use of herbicides has freed man from the
laborous and never ending task of removing pest plants
by hand. Herbicides have greatly increased man's
productivity, both on the farm and in the forest. A

170

decision not to use herbicides would not be an end to
progress, but it would significantly reduce long-term
agricultural and forest productivity.

Soil Organisms. The activity of most soil organisms is
considered a benefit to plant growth. Some herbicide
applications have been found to increase the number of
active soil organisms.

Vegetation. The short-term effect of herbicide use on
vegetation is a reduction in plant numbers. At times
this reduction in plant numbers may be permanent and the
desired result of the herbicide application. The
majority of herbicide use is aimed at maintaining or
increasing the production of desirable vegetation
without inhibiting or destroying the land's ability to
produce.

When herbicides are used to reduce noxious or poisonous
weeds on National Forest lands, they not only benefit
the user, but also aid nearby landowners by eliminating
a source of infection.

Long-term timber needs can only be met if an active
timber management program is carried out today. It
takes time to grow trees. Future demands must be
predicted and actions taken now to meet those needs. We
cannot wait for the demand for wood to develop and then
start to grow the trees to supply the need. The time it
takes to grow a crop of trees is just too long. The
long-term benefit from vegetation management in
plantations is increased production of the renewable
natural resource - trees. A future generation will
benefit, the same as we are benefiting now from
reforestation efforts of 40-50 years ago.

In treating some of the woody vegetation that has
encroached on roadsides, trails, rights-of-way and
wildlife openings with herbicides, future maintenance of
these areas is more easily*accomplished by non-chemical
methods.

Forest Vertebrate Animals. Many wildlife species
benefit directly from a disturbed forest. Wildlife
populations can only be maintained if suitable habitat
is available. Early successional stages of forest
growth encourage wildlife diversity and abundance if
properly interspersed with older growth conditions.

Maintenance of young stands in a forest requires
disturbance. Distribution of disturbance and diversity

of vegetation are also important. Herbicides have been
found to be useful in maintaining forest openings for
wildlife and setting vegetation back to early successional

eal

Vix

stages. Long-term wildlife productivity on a forest-wide
basis is maintained by annually creating a vegetation
disturbance within a small pecentage of the forest cover
type. In addition, dead trees, resulting from herbicide
treatments, provide a long-term source of insect feed and
den or nesting sites for a variety of forest vetebrates.

Weeds and algae can be deterimental to the fishery
resource in a pond or lake. Through the use of
herbicides or algaecides, the life of this resource can
be greatly extended.

6. Forest Invertebrate Animals. Some research indicates
that certain herbicides have an immediate and harmful
affect on insects. The effects are short-term, however,
with insect populations quickly regaining former
numbers. Following some forms of herbicide treatment,
many species of flowering forbs, flowering shrubs, and
lush grasses will provide for increased insect
populations for several years. Honey bee production has
been known to increase. Insect feeding vertebrates find
an available source of feed.

C. Social Economic Components

The knowledge that today's resource programs are producing
for tomorrow's needs promotes community stability and
encourages investments in long-term community growth.

Herbicides offer the most effective and least expensive means
of protecting costly investments in road and utility
rights-of-way and recreation and other physical developments
from uncontrolled vegetation. The long-term benefits are
measured in increased food, lower utility rates, available
wood fiber, recreation opportunities, and improved wildlife
habitat.

IRREVERSIBLE OR IRRETRIEVABLE COMMITMENT OF RESOURCES

The results of herbicide use are not considered irreversible. It
is not expected that any plant or animal species will be
eradicated by the proposed use of herbicides. Some individual
plants will be killed, reducing the total number of that species
on the treatment area. Other plants will be partially affected,
losing only part of their foliage or stems; as a result, they
will suffer reduced growth. Occasionally one dominant use of the
forest's resources has been established on an area and
perpetuated through the use of herbicides. This commitment of
land, however, can be altered should circumstances warrant.

The time, labor, herbicides, and petroleum products used and the
vegetation killed are irretrievable.

i72

VII. CONSULTATION WITH OTHERS

On October 30, 1973, a Final Environmental Statement, The Use of
Herbicides in the Eastern Region, was sent to the Council on
Environmental Quality. The statement contained in this text is a
revision of the earlier statement. Scientific data, comments,
and suggestions incorporated in the original statement have been
used in the preparation of this Region-wide umbrella statement.

Since 1973, the Eastern Region's herbicide use program has been
challenged in two lawsuits. Expert testimony presented during
these hearings, along with Conclusions of Fact offered by the
Federal Judges have helped shape the organization and content of
this statement.

Other Forest Service Regions have filed final environmental
statements on their use of herbicides with CEQ. The substance
of these statements, as well as comments and suggestions offered
during public review have been considered and used in this
Eastern Region statement.

The site specific environmental analysis reports prepared for
individual herbicide projects are an extension of this umbrella
statement. The local site specific descriptions, local impacts,
and economic analysis contained in the project analysis are made
available for public review. They too have been considered when
applicable to Region-wide use.

The agencies, groups, and individuals shown on the following

lists have been requested to review and comment on this Draft
Statement. See Appendix C

L/S

Vine

BIBLIOGRAPHY

Here is a partial listing of the references used in developing
this statement.

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herbicides in forest watersheds that supply potable water.

AllenjeJi RS eePeeVaneMal ler sands Di Hie Noroackeloso.
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Allen, J.°R2, DAL Barsotti jeand Jin Pa VaneMiidior wel Cree
Reproductive dysfunction in non-human primates exposed to
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Amchem Products, Inc. 1972. Toxicity Summary for Weedone
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Andersen, K. J., EB. G.*Leighty, and M? Ty Takahashi. 91972.
Evaluations of Herbicides for possible mutagenic
properties. Agri. Food Chem. Vol 20, No. 3 pgs. 649-656.

Ansul Co. 1967. Toxiciological data - methane arsonic acid and
dimethycarsinic acid. 1969 addendum, Ansul Co., Marinette,
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Arend, John L. and Eugene I., Roe, 1961. Releasing conifers in
the Lake States with chemicals. Agricultural Handbook No.
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Ashton, F.M. and A.S. Craffs, 1973. Mode of Action of
Herbicides. Wiley, New York

Audus, L.J., 1964. Herbicide behavior in the soil. In the
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Axelson, Olaf, and Lennart Sundall. 1974. Herbicide exposure,
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Bailey, J. B., and J. E. Swift, 1968. Pesticide information and
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Bailey, G. Wo, Ay Do Thurston, tired aD mebOperm) memmmand
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of silvex and the persistence of silvex in water and
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Balicka, N., 1969. The action of several herbicides on the
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Balicka, N. and J. Sobieszczanski, 1969a. The effect of
herbicides on soil microflora. 1. Effects of herbicides on
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Beale, Marv G., William T. Shearer, Michael M. Karl,
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Bjorklund, Nils Erik and Kurt Erne. 1966. Toxicological studies
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Bollen, Walter B., 1961. Interactions between pesticides and
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Brinkman and Living, May 1961. Oak and pine reproduction
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of phenoxyalkyl carboxylic acids. Soil Sci. Soc. Amer.
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Butler, P. A. 1965. Effects of herbicides on estuarine fauna.
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eS

Cain, P. S. 1966. An investigation of the herbicidal activity
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Carter, Mason C. 1969. Amitrole. In: Degradation of
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CAST Report No. 39. February 1975.

Chansler, J.F., and D.A. Pierce, 1966. Bark beetle mortality in
trees injected with cacodylic acid (herbicide). J. Econ.
Entomol: 59:1357=1359.

Chirchillo, M. T. 1968. Biodegradation of bavel D under varying
conditions of temperature and moisture. Velsicol Chem.
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Collins, T.F.X., and C.H. Williams. 1971. Teratogenic studies
with 2,4,5-T and 2,4-D in the hamster. Bull. Environ.
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Cowell, B.C., 1965. The effects of sodium arsenite and silvex
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Crafts, A.S., 1961. The chemistry and mode of action of
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Day”, *D NEV tL. Se Jordan wand'ke CoeRusse leno 63, Persistence
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Dickinson, John 0. 1972. Toxicity of the arsenical herbicide

monosodium methanearsonate in cattle. Am? J). Veto Rese
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Dawson, D.H. and N.V. Noste, 1976. Review of competition control
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176

Dunachie, J. F., and W. W. Fletcher. 1970. The toxicity of
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Du Pont. 1976. Krenite brush control agent. Technical Data
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Foy, C. L. 1964. Volatility and tracer studies with
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Fralish, James, 1972. Youth, maturity, and old age. USDA Forest
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Frank, P.A. and B.H. Grigsby, 1957. Effects of herbicidal sprays

on nitrate accumulation in certain weed species.
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177

Frank, P. A., R.°J. Demint, and R. D. Gomes. 19708 “Herbicides
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Fries, G. F., and G. S. Marrow. 1975. Retention and excretion
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Gabriel and Nissen, 1971. A time study of felling cull trees
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Gehring, PiJ., C. G. Kramer, B.A. Schwet zy J.Q. Rose, V.K. Rowe,
and J. S. Zimmer. 1973. The fate of 2,4,5-trichlorophenoxy-
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Toxicol. Appl. Pharamcol. 25(3)441.

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C.R. Youngson, 1967. The affect of tordon on
micro-organisms and soil biological processes. Down to
Barth 22(4): 14-17"

Grigsby, B.H. and C.D. Ball, 1952. Some effects of herbicidal
Sprays on the hydrocyanic acid content of leaves of wild
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Confi= Procr.6°327=330:

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GLOSSARY OF TERMS

- Absorption - Penetration of a substance from the surface to
below the surface.

- Acid equivalent (a.e.) - The theoretical yield acid from an
active ingredient, on a per gallon basis, i.e., 4 lb.
a.e. yields 4 1b. of active acid per gallon of solution.
Not applicable to all herbicides, e.g., amitrole and
atrazine.

189

Active ingredient (a.i.) - The chemicals in a product that are
responsible for the herbicidal effects.

Acute toxicity - Poisoning by a single dose or dosages applied
over a short period.

Adjuvant - Substances which are added to spray materials to act
as wetting or spreading agents, stickers, penetrants,
emulsifiers, etc., aiding in the physical characteristics
of the herbicide materials.

Adsorbed (adsorption) - Adherence of a substance to a surface.
Algicide - A chemical intended for the control of algae.
Auxin - Plant growth hormone.

Auxin herbicide - A herbicide that has an effect like a plant
growth hormone.

Benefit-cost ratio - The ratio between the economic benefits
derived from a particular action and the cost of
performing that action. For example, if it costs $l to
treat an acre and we find the economic benefit from that
treatment has a value of $5, the benefit cost is 5:1.

Biota - The animal and plant life of a region or period.

Broad-leaved plants - Botanically, those classified as
dicotyledons. Morphologically, those having broad, often
compound, leaves.

Browse - Any material that is browsed or fit for browsing.
Feeding on buds, shoots, and leaves of woody growth by
livestock or wild animals.

Brush control - Control of woody plants.

Carcinogen (carcinogenicity) - Any substance that produces
cancer (the ability to prodtce cancer).

Carrier - The liquid or solid material added to a chemical
compound to facilitate its application.

Cations - An electropositive ion (soil particle).

Chromosomal - Pertaining to the small bodies within a cell
which occur in definite numbers in the cells of a given
species. These bodies are composed of genes which

control cell activities.

Chronic toxicity - The poisoning effects of a series of small
doses applied over a long period.

Co-Dominant (crown class) - Trees having their crowns in the
upper canopy, but which are less free than the dominants.

190

Concentration - The amount of active ingredient or acid
equivalent in a given volume of liquid, or in a given
weight of dry material.

Contact herbicide - A herbicide that kills primarily by contact
with plant tissue rather than as a result of
translocation.

Crop tree - Any tree forming or selected to form a component of
the final crop. Generally, a tree selected in a young
stand or plantation for carrying through to maturity.

Cull - Any tree, or plant rejected for use because it does not
meet certain specifications.

dbh - Abbreviation for diameter breast height.

Deciduous trees (hardwoods) - Those that lose their leaves
during winter.

Defoliator or Defoliant - A compound which causes the leaves or
foliage to drop from the plant.

Dermal - Through the skin, or by contact with the skin.

Dicotyledonous - A plant having two seed leaves or cotyledons;
the broad-leaf plants.

Dilutent - A material, liquid or solid, serving to dilute a
herbicide to field strength for adequate plant coverage,
maximum effectiveness and economy.

Dominant (crown class) - The trees having crowns in the upper
most layers of the canopy, and which are largely
free-growing.

Dormant spray - A herbicide applied during the period following
leaf-fall or leaf death and before bud break of evergreen
trees:

Drift - The movement of air-borne particles from the intended
contact area to other areas.

Ecosystem - The basic ecological unit, made up of a community
of organisms interacting with their inanimate environment.

Emulsion - The suspension of one liquid as minute globules in
another liquid; for example, oil dispersed in water.

E.P.A. - Environmental Protection Agency
Ester - Formed by the reaction of the herbicide acid, such as
2,4-D plus and alcohol. This reaction takes place with

heat, pressure, and in the presence of a catalyst, and is
known as esterification.

191

Foliage application - An application of a herbicide to the
foliage (leaves, stems, shoots) of a plant.

Forb - Any herbaceous plant that is not a grass nor similar to
one; e.g., geranium, buttercup, sunflower.

Forest type - A category of forest or forest land, cover type,
stand type. A category of forest defined by its
vegetation and/or locality factors.

Formulation - A term used synonomously with the product. It
contains the herbicide in a form that can be (1)
dissolved or suspended in a carrier and distributed in
solution or suspensions by sprayer; (2) distributed dry
by dusters or spreaders; or, (3) easily vaporized for
fumigation.

FSM - Forest Service Manual.

Gamma radiation — Penetrating rays emitted from radioactive
material and reducing the energy of the cell nucleus.

Girdle - Making more or less continuous incisions around a
living stem, through at least both bark and cambium.

Growing stock - All the trees growing in a forest or in a
specified part of it and generally expressed in terms of
number or volume. See crop trees.

Habitat - The abode, of a plant or animal, as it relates to all
the environmental influences affecting it.

Herbaceous plant (Herb) - A vascular plant that does not
develop wood tissue.

Herbicide - A phytotoxic chemical used for killing or
inhibiting (stunting) the normal development of a plant.

Host plant - The plants for which the area is being managed.
Those plants most favorable to man, and which man wants
to see occupy the site.

Karst topography - An irregular limestone region with
sinkholes, under ground streams, and caverns.

Leaching - Movement of a substance downward through the soil.

LC. 4 - A lethal concentration rate at which 50 percent of the
test animals will be killed. Usually expressed in ppm
(See below) and usually used in testing of fish or other
water animals.

LD, - A lethal dosage rate at which 50 percent of the test
animals will be killed. Usually expressed in terms of
milligrams of chemical per kilogram of body weight of the
test animal (mg/kg).

192

Low volatile ester - Chemically, an ester prepared with a
heavy, molecular weight; alcohol, such as the
butoxy-ethanol, iso-octyl, or propylene glycol butyl
ether esters. Biolgoically, it is an ester which is less
likely to injure plants by vapor activity, than a
high-volatile ester.

Mass median diameter - The drop diameter that divides the spray
depositon distribution into two equal parts by mass.

Mast - The fruit of trees such as oak, beech, sweet chestnut --
particularly where they are considered food for livestock
and certain kinds of wildlife.

Metabolism - The sum of the processes concerned in the building
of protoplasm and its destruction incidental to life.

Merchantable - Of trees, crops, or stands, or a size, quality,
and conditions suitable for marketing under given

economic conditions.

Mg/Kg - Abbreviation for dose in milligrams per kilogram of
body weight of animal.

Mg/Ml - Abbreviation for milligrams per milliliter.

Microflora - Microscopic organisms belonging to the plant
family.

Micron (u) - A metric unit of length equal to 1/1000 of a
millimeter or 1/1,000,000 of a meter. 1 inch equals
about 25,400 microns.

Mitotic - Cell division.

Mutagen (Mutagenicity) - Any substance capable of producing
genetic damage (The ability to produce genetic damage).

Non-selective herbicide - One that is toxic to all plants.

Non-target component or vegetation - Vegetation which is not
expected or not planned to be affected by the treatment.

Noxious weed - A plant defined by law as being especially
undesirable, troublesome, and difficult to control.
Definition of the term "noxious weed" will vary according
to legal interpretation.

Overstory - That portion of the trees in a forest that form the
upper most layer of vegetation.

Pathogen - The infective agent causing a disease, e.g. a
fungus, bacterium, or virus.

Perennial - A plant that lives for more than 2 years.

Persistent pesticide - Persistency is dependent upon such
properties as volatility and resistance to chemical
breakdown.

Pest plant - Any plant which injures man, his property, or
which annoys him.

Pesticide - Any substance or mixture of substances intended for
controlling insects, rodents, fungi, weeds, and other
forms of plant or animal life considered pests.

pH - The chemist's measure of acidity and alkalinity. It is a
scale in which the figure 7 indicates neutral; figures
below 7 indicate acidity; and, figures above 7 indicate
an alkalinity.

Phenoxy herbicides - Formulations of 2,4-D, 2,4,5-T, and
2.4, 5-TPe

Phloem - The tissues of the inner bark. They are characterized
by the presence of sieve tubes and transport foodstuffs.

Phosphorylation - The process of converting into a compound of
phosphorus.

Photoaleration - Changed by exposure to sunlight.

Photodecomposition - A process of breaking down a substance
through reaction to light.

Phtotoxic - Poisonous or injurious to plants.
Post emergence - After emergence of specified weed or crop.

ppb - parts per billion, e.g. 1 ppb might refer to 1 gallon of
herbicide in 1 billion gallons of water.

ppm - parts per million.
ppt —"parts per tririfion,

Precommercial thinning - Thinning out trees in a forest stand
by other than a commercial sale.

Pre-emergence herbicide - A herbicide applied after planting
the crop, but before the crop emerges above ground. The
purpose is to kill weed seedlings that appear ahead of
Chescrop.

Rate - The weight of active ingredient or acid equivalent of a
herbicide or volume of carrier applied to a unit area.
(Usually expressed in lbs. of herbicide in gallons of
carrier per acre.)

194

Registered - Pesticides that have been approved for use by the
Environmental Protection Agency or by the Department of
Agriculture.

Residue - That quantity of a substnce, especially of active
pesticide, remaining on or in a surface or crop.

Resistance - The degree to which a plant or animal species of
plant or other tolerates a toxic substance.

Roentgens - The unit used as a measure at radiation.

Selective herbicide - A herbicide that will kill some plant
species when applied to a mixed population, without
serious injury to other species.

Site preparation - The removal of vegetative competition or
physical obstacles from an area scheduled for
regeneration.

Softwood - A conventional term for both the timber and the
trees belonging to the botanical group gymnospermae
(pines and spruces).

Soil sterilant - A herbicide that prevents plant growth when
present in the soil. Soil sterilization may be temporary
or relatively permanent.

Spot spraying or treatment - An application of pesticide to
localized or restricted areas (generally a few square
feet); this is different from a broadcast application
(generally covering many acres).

Sprout - Any shoot arising from a woody plant, but particularly
from the base of a plant.

Stomata - A minute pore in plant leaves through which gaseous
exchange takes place.

Succession —- The gradual supplanting of one community of plants
by another.

Surfactant - A substance that reduces the interfacial tension
between the surface of a droplet and the surface of the

vegetation on which the droplet has landed.

Systemic herbicide - A herbicide that travels to other parts
of a plant, rather than staying where it was applied.

Target component or vegetation - Vegetation which is expected
or planned to be affected by the treatment.

Teratogen (Teratogenicity) - Any substance capable of producing
birth defects.

195

- Toxicity - Degree to which something is poisonous or physically
injurious.

- Translocated herbicide - Herbicide movement within the plant
from the point of entry.

- Travel Influence Zone - The travel influence zone is made up of
lands bordering selected roads and trails which have
significant recreation travel. It includes existing and
potential recreational occupancy sites, and is wide
enough to insure that the land can be managed for scenic
quality.

- Vegetational succession - The order in which plants become
established and grow in nature. Usually after a fire or
other disturbance, simple annual plants become
established first, then successively more complex and
longer living plants take over.

- Volatile - A compound is said to be volatile when it vaporizes
at ordinary temperatures on exposure to aire

- Volatility - The evaporation or vaporization (changing from a
liquid to a gas) at ordinary temperatures on exposure to
the air.

- Water Influence Zone - The water influence zone extends back
from the water line of selected streams and lakes. It
delineates land areas where the presence of water is a
predominating factor and a major item of consideration
when managing the area. It includes land areas suitable
for recreational use or other development in connection
with the utilization of water values. Streams suitable
for boating and canoeing and waterfowl marshes are
usually in this zone.

- Weed - A plant growing where it is not desired.

- Xylem - The principal strengthening and water-conducting tissue
of woody plants.

Geis

APPENDIX - A

CONTROLS ON HERBICIDE USE

Basic authority for the use of herbicides is contained in
legislation signed on October 21, 1972; the Federal,
Insecticide, Fungicide, and Rodenticide Act (FIFRA), as
amended. To insure that herbicide use is necessary and is
accomplished in a manner that will achieve specific resource
management objectives with the least potential hazard to all
non-target components of the environment, the following controls
were developed to mitigate adverse environmental effects
identified in Section II (ENVIROMENTAL IMPACTS OF THE PROPOSED

ACTION) of this statement:

When label directions are more constraining than those listed
below, the label directions will be followed:

Loo AEE

-- To minimize drift and volatilization, lessen the fall
distance to 30-40 feet above the vegetation when
aerially applying herbicides.

-- Use ground spray application equipment that produces
droplets larger than 200 microns mass median diameter.

-- Use aerial spray application equipment that produces
droplets larger than 400 microns mass median diameter.

-- When reasonable, use thickeners or invert emulsion
formulations for spray mixtures to minimize drift
and volatilization.

-- Avoid the aerial application of herbicides when a
warm air inversion is present, as the drift potential
is increased. Cold air inversions can help reduce
OrLecs

-- Always use the low volatile formulations of an
herbicide.

-- Apply aerial sprays only when the wind speed is
less than 8 m.p.h., or less, if required by the label.

-- Apply aerial sprays only when the temperature ranges
from 50-85 F. (measured 4.5 feet above ground
level).

-- Apply aerial sprays only when the relative humidity
is above 50 percent.

Soils

To avoid contaminating areas not scheduled for
treatment, the entire application system

must be leakproof and have a positive shut-off
mechanism capable of retarding drool.

When a range of application rates is suggested, use
the lowest rate recommended for effective treatment
with specific soils.

When the label's use directions allow the user a
range of application rates (e.g., 1-3 gallons per

100 gallons of dilutent), maximum of 6 pounds active
ingredient per acre, for one application of herbicide,
will be used.

Waste herbicide containers will be returned to the
manufacturer for re-use, properly incinerated
(1,000°C for 2 seconds dwell time), or triple
rinsed, crushed, and buried in a land fill approved
for such disposal by either EPA or a local unit of
government. Rinse solution will be added to the
herbicide mixture and used as part of the herbicide
application.

Water

Herbicides will not be applied within 50 feet of

open water such as streams, ditches, lakes, and ponds;
unless, the target pest is found in or adjacent to the
water and the herbicides are approved by EPA for
application to a water system.

For aerial and ground foliar spray applications, leave
a minimum 100-foot buffer zone between the treatment
area and open water. When the wind velocity exceeds

4 m.p.h. and is blowing toward private or other public
lands or open water, consider increasing the buffer
strip to at least 500 feet.

When treating slopes in excess of 30 percent, the
width of the untreated buffer-strip will be doubled.

The water source providing water for mixing with
herbicides shall be protected from herbicide
contamination.

A water surveillance program will be used by each
Forest. There will be periodical check to guarantee
that guidelines used for herbicide applications are
adequately protecting forest water sources so the
herbicide levels do not exceed those listed in the
National Interim Primary Drinking Water Regulations
or permanent regulations.

A-2

-- Ferrying routes by helicopters rigged for applying
herbicides will not cross lakes or ponds, and will
avoid other open waters where practical.

-- There will be no fog or air turbulence present, nor
will rain be expected on site within 2 to 4 hours.

Hazardous Substances

-- An area will be retreated, where needed, no sooner
tiiaaelsyeats10r92,4,5-1, and 3 years for cacodylic
acid, picloram, and dicamba.

-- Only herbicides currently registered and labeled by
the Environmental Protection Agency for the specific
use proposed will be used, unless:

(a)

(b)

(c)

(d)

An Experimental Use Permit is obtained from
EPA under Section 5, Federal Insecticide,
Fungicide, and Rodenticide Act, (FIFRA), as
amended.

A Special Local Needs Registration is issued
by an individual State under guidelines
contained in Section 24, FIFRA, as amended.

Parameters, as outlined in the U.S. EPA
Pesticide Enforcement Policy Statement No. 5
are met.

Aerial application of herbicides whose labels
bear no affirmative instructions for aerial
application must follow the procedures
established by US EPA Pesticide Enforcement
Policy Statement No. 7.

-- The use of an unregistered tank mix will not be
permitted unless it meets (a), (b) or (c) above.

-- All proposals for pesticide use on the National
Forests of the Eastern Region will go through a
review process which includes review by:

(a)

(b)
(c)

Forest Pesticide Use Committee or Forest
Pesticide Coordinator.

Regional Chemical Use Committee.

Pesticide-use proposals falling into one

or more of the following categories must

be reviewed by the field Pesticide-Use
Coordinating Committee before being approved
by the Regional Forester.

(1) Use of a pesticide (for a particular
purpose or use in a particular way) not labeled
under the Federal Insecticide, Fungicide, and
Rodenticide Act, as amended.

(2) Any application to water, or any
application whereby the pesticide could
reasonably be expected to get into water.

(3) Any use of a pesticide that can reasonably
be expected to affect threatened or endangered
species.

(4) Any program or project in which 640 or
more contiguous acres would be treated as one
application.

Proposed herbicide uses will be based on a
prescription for each treatment area that evaluates
and justifies the need for the treatment and
considers alternative procedures, benefits, and
possible adverse effects on the environment.

When not covered by an Environmental Impact Statement
or approved Environmental Analysis Report, an
environmental analysis and its documentary report
will be made for herbicide uses affecting any
resource, Other land use activity, or the
environment. When required, there will be provisions
for advance review of pesticide projects by concerned
Federal, State, and local agencies, and the general
public.

Pesticides will be handled and stored in a manner
which will safeguard public health and wildlife,
prevent damage to plants, prevent soil and water
contamination, and are in accordance with Federal,
State, or local laws and regulations.

Social/Economic

When pesticides are required, those methods of
application and formulations that will most
effectively suppress the pest, are the most

specific to target organisms, and have the least
potential hazard to all non-target components of the
environment will be recommended.

The use of controversial herbicides or controversial
methods of application will be analyzed and

reported to the public and other interested Federal,
State, and local agencies, so they may review and
comment on the action proposed.

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-- The news media will be utilized at the local level to
discuss pesticide-use issues and social concerns.

-- Results of herbicide efficacy and monitoring will be
made available to the public.

-- Whenever reasonable, effective, safe, and integrated
Suppression measures that may utilize biological,
cultural, and other techniques in place of, or in
association with, pesticides will be recommended and
used.

-- Legal clearances, as required by Federal, State,
and local laws or regulations will be obtained
before using pesticides (Section 24 regulations of
amended FIFRA).

-- All personnel who handle or supervise the use of
pesticides will receive training and/or certification.

Visual

-- If possible, treat aquatic weeds before heavy
seasonal use starts.

-- Along easily viewed roadside and rights-of-way,
treat hardwood brush at the youngest age possible.

-- Where aesthetic values are high, herbicide
treatments should occur during the dormant season,
using based spray or cut stump methods of application.

Landownership - Land Use

-- All uses of herbicides by permittees will follow the
policies and guidelines established for National
Forest use of chemicals.

--The Land Use Policies outlined in Secretary's
Memorandum No. 1827 will be followed.

Man

-- A safety plan and job hazard analysis will be
written for herbicide use. For each herbicide
proposed for use, the safety plan should cover:

(a) First aid instructions

(b) Poison Control Center telephone number
and evacuation procedures

(c) General safety information

(d) Storage

(e) Operational procedures

(f) Safety precautions:
- Accident prevention measures
- Transportation precautions

- Empty container disposal

Spill clean-up plan.

The job hazard analysis and Occupational Safety

and Health Act (OSHA) should be used to provide
guidance on protective clothing and safety equipment
needed for those handling and working with herbicides.

Applicators will be briefed before and during the use
season about safe measures for handling, transporting,
mixing, and applying herbicides; use of protective
clothing and equipment; plus, the need for personal
hygiene. Applicable safety measures will be used.

Persons applying restricted-use herbicides on National
Forest lands will must meet State Pesticide
Certification Plan or Government Agency Plan
guidelines, as approved by EPA. (To be effective
October® 213+ 1977.)

Certification of herbicide applicators used on
National Forests will follow Federal, State, and local
guidelines.

For aerial applications, an unsprayed buffer zone of
at least 100 feet will be left adjacent to all private
property, unless the private property holder agrees

in writing to a lesser distance. Individual tree
treatment methods may be used in this strip.

Projects will be carefully supervised to assure that
stated precautions for terbicide use are being
observed.

The herbicide 2,4,5-T will be limited to forest,
pasture, and industrial sites, unless label
restrictions are changed by the Environmental
Protection Agency. It will not be used in
recreation areas, water, around homes or offices,
or on food crops (except rice).

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Domestic Animals

Label instructions on allowing livestock to
graze on areas following herbicide application
will be followed.

Soil Organisms (RESERVED )

Wildlife

The project planners will review the list of
endangered and threatened wildlife published in the
Federal Register 40 (188): 44412-44429, September
26, 1975. (Memo to Forests, 2630, October 2, 1975),
and take reasonable action to determine if listed
wildlife occupy or frequent the proposed treatment
area.

When available, Forest/State recovery plan for
individual wildlife species will be reviewed.

"Unique'' - Species identified in FSM 2622.4;
State legislation; or species identified in Forest
unit plans will be reviewed.

Management practices approved for the protection of
active habitat sites for identified unique, threatened
and endangered animals (FSM 2630) will be followed.

Critical habitats of endangered or threatened fish and
wildlife species will be protected and enhanced where
possible.

Vegetation

When planning for herbicide programs, all the plants
on the Secretary of Interior's proposed list will be
treated as though they were officially classified.
Steps will be taken to assure their protection, until
such time as their official status is determined.

When planning the use of herbicides, available
information will be reviewed to determine whether
or not known locations of sensitive plants occur
in the immediate vicinity of the proposed project.

If known locations are identified within or in the
immediate vicinity of the project area, a field
reconnaissance will be made by a qualified Forest
Service person or out-Service botanist to determine
the distribution of the sensitive species.

-- When the actual distribution of the sensitive plant
is determined, efforts will be taken to modify the
herbicide treatment; or, the proposed treatment area
will be dropped, so as to avoid jeopardizing the
existence of the sensitive plant.

13. History and Archeology

-- The project planner will consult the National Register
of Historic Places, to avoid treating recognized areas
with herbicides.

-- Reconnaissance surveys will be conducted by the land
manager where an inventory of cultural values is
lacking.

-- Any Forest Service herbicide treatment proposed for
a site listed in the National Register of Historic
Places must be submitted to the National Advisory
Council on Historic Preservation for review and
comment, prior to approval of the project.

-- Broadcast herbicide treatments will be given to any
location of known historic or prehistoric sites,
buildings, objects, or properties related to
American history, architecture, archaeology, or
culture, such as settler or Indian artifacts, and
protected by the American Antiquities Act of 1906 (16
USC 431-433), National Historic Preservation Act of
1966 (PL 89-665), Executive Order 11593 (1971), NEPA
PL 91-190), or the Archeological and Historical
Conservation Act of 1974 (88 Stat. 174).

To comply with FIFRA as amended, these guidelines will be
reviewed on a timely basis and changed as needed.
DISCUSSION OF REVIEW COMMENTS RECEIVED
ON DRAFT STATEMENT
Federal Agencies
1. U.S. Department of Agriculture, Agricultural Research Station,

14th and Jefferson Drive S.W., Washington, D.C. 20250

2. U.S. Department of Agriculture, Soil Conservation Service,
14th and Jefferson Drive S.W., Washington D.C. 20250

3. U.S. Department of the Interior
Interior Building, Washington, D.C. 20240

4. U.S. Environmental Protection Agency
401 M. Street S.W., Washington, D.C. 20460

State Agencies

Through State-Federal Clearinghouse Coordinators
Illinois, Bureau of the Budget
Springfield, Illinois 62706
Pennsylvania, Department of Environmental Resources
P.O. Box 1467, Harrisburg, Pennsylvania 17120

State Department of Natural Resources

Maine, Department of Conservation
Augusta, Maine 04333

Michigan, Department of Natural Resources
Mason Building, Lansing, Michigan 48909

Minnesota, Department of Natural Resources
Centennial Office Building, St. Paul, Minnesota 55155

Ohio, Department of Natural Resources
Fountain Square, Columbus, Ohio 43224

West Virginia, Department of Natural Resources
Charleston, West Virginia 25305

Wisconsin, Department of Natural Resources

Box 7921, Madison, Wisconsin 53707
Organizations, Groups and Individuals

Coalition for Economic Alternatives

Box 323, Ashland, Wisconsin 54806

Defenders of Wildlife
1244 Nineteenth Street, NW, Washington, D.C. 20036

Environmental Defense Fund
1525 18th Street, NW, Washington, D.C. 20036

Friends of the Earth
620 C Street, S.E., Washington, D.C. 20003

The Izaak Walton League of America
Suite 806, 1800 N. Kent Street, Arlington, Virginia 22209

Minnesota Herbicide Coalition
110506 Windmill Court, Chaska, Minnesota 55318

LOR

The Wilderness Society
1901 Pennsylvania Avenue, N.W., Washington, D.C. 20006

Mason Carter, Head, Department of Forestry and Natural Resources
Purdue University, West Lafayette, Indiana 47907

Harvey Holt, Associate Professor, Dept. of Forestry
and Natural Resources
Purdue University, West Lafayette, Indiana 47907
Ms. G. Altonen
Duluth, Minnesota 55812

Companies
Consolidated Paper, Incorporated

Wisconsin Rapids, Wisconsin 54494

TSI Company
P.O. Box 151, Flanders, New Jersey 07836

A-1U0

APPENDIX —- B

ENVIRONMENTAL ANALYSIS REPORT
REGION 9
NICOLET NATIONAL FOREST
ALTERNATIVE METHODS OF PLANTATION
RELEASE ON THE NICOLET NATIONAL
FOREST

FOR FISCAL YEAR 1976-1/4

PROJECTS

Prepared by the Staff of the Nicolet National Forest, May 1976

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TABLE OF CONTENTS

PAGE
ENVIRONMENTAL STATEMENT RECOMMENDATIONS

DESCRIPTION

ENIVRONMENTAL EFFECTS

FAVORABLE ENVIRONMENTAL EFFECTS

ADVERSE ENVIRONMENTAL EFFECTS

ALTERNATIVES

RELATIONSHIPS BETWEEN SHORT-TERM USES OF MAN'S

ENVIRONMENT AND THE MAINTENANCE OF LONG-TERM

PRODUCTIVITY

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF
RESOURCES

CONSULTATION WITH OTHERS

ENVIRONMENTAL STATEMENT RECOMMENDATIONS

The applicability of the National Environmental Policy Act to
this activity has been considered. The Council on Environmental
Quality has set forth a number of considerations to guide
Federal Agencies in following Section 102(2) (C) of the National
Environmental Policy Act. Among them is the use of a
broad-based impact statement as background to site specific
environmental analysis. This format has been adopted by the
Eastern Region. A final environmental statement, The Use of
Herbicides in the Eastern Region, was submitted to the Council
on Environmental Quality on October 30, 1973. This proposed
project to use 2,4-D has been selected from several alternatives
available. The analysis is contained in this report and does
not indicate a significant environmental impact or high
controversy. The reasons for this decision are based on the
conclusions that the action will:

1. Cause no irreversible effects to the waters, air, soil, or
quality of the human environment.

2. Promote a desirable long term change in the vegetation
composition of the Nicolet National Forest that will aid
local economic stability and help to offset the long-term
National shortage of softwood timber.

3. Alter the habitat adversely for some species of wildlife,
but beneficially for other species of wildlife.

4. Not adversely affect rare or unique plants or animals.

5. Be carried out well within the guidelines established in the
final environmental statement on the Use of Herbicides in
the Eastern Region. Constraints for this project meet or
exceed all guidelines in that document.

6. Be the most desirable alternative from the stand point of
efficiency and minimum environmental impacts.

While the use of 2,4-D may be subject to some concern, tests and
investigations have not shown this herbicide to accumulate in
the environment or contain the dioxin TCDD. The areas to be
treated are small in size and widely scattered. Based on this
analysis, I have determined that the requirements of the
National Environmental Policy Act have been met. An
environmental statement as described in Section 102(2) (C), has
been prepared for the Eastern Region Herbicide Use Program and a
statement dealing with these specific projects is not needed.
This proposal to treat 340 acres of plantation using the methods
and subject to the management constraints, described herein is
approved.

Date THOMAS A. FULK
Forest Supervisor

b-3

its

A.

DESCRIPTION

Project Background

The 2,4-D herbicides are used in land management where their
particular selective properties coincide with the desired
changes in vegetation. The most common uses are suppression
of broad-leaved plants in the presence of grasses, conifers,
or certain legumes. The situations in which management
objectives are served by this kind of selectivity are
extra-ordinarily diverse. Each use of 2,4-D is governed by
the known response to 2,4-D of each kind of plant present.
Such general rules as "broad-leaved" plants are susceptible,
while grasses and conifers are resistant" have important
exceptions, and nothing short of a thorough knowledge of the
responses of each kind of plant under prevailing conditions
will make possible the effective use of 2,4-D.

The basic purpose of the conifer release program is the
attainment of Forest vegetative cover type objectives. The
Forest cover type objectives policy sets, as a goal, a fairly
definite pattern of vegetative cover types, age classes and
species mixtures, to be attained through long-term vegetative
manipulation. This eventual vegetative pattern is viewed as
the optimum situation obtainable on existing soil types, from
a multiple-use land management standpoint. Several factors,
primarily aesthetics, wildlife habitat, timber production, and
land capabilities were considered by an interdisciplinary team
in establishing these objectives.

The attainment of these objectives requires the maintenance of
conifer cover types during the regeneration period. Conifer
type maintenance necessitates the control of competing
hardwood regeneration and brush, to release conifer

seedlings. Conifer seedlings, being slower growing than
hardwoods, are not able to compete successfully for light,
moisture, and nutrients under growing conditions now found
over most of the Nicolet National Forest. Establishment of
conifer stands, therefore, requires management action to
control competing vegetation until conifers dominate the site.

The Forest composition objectives for the Nicolet National
Forest are covered in the following documents:

1. Timber Management Plan for the Nicolet National Forest,
July 1, 1965 extended to June 30; 1973.

2. Environmental Statement for the Use of Herbicides in
the Eastern Region, October 30, 1973.

The major effects of planned cover type manipulation are
briefly outlined below:

a. Favorable Effects.

(1) Improvement of wildlife habitat through an
increase in Forest vegetative cover type
diversity.

(2) Improved forest aesthetics by creation of a
heterogeneous mixture of conifer and hardwood
types.

(3) Increased forest resistance to insect and
diseased losses through increased cover type
diversity.

(4) Increase in forest fiber and economic yield
through conversion of hardwood stands to
higher yielding, higher value conifer types.

b. Adverse Impacts

(1) Increased fire hazard due to increased
percentage of Forest in more flammable
conifer types.

The prescribed conifer plantation release program for CY 1976
includes a total of 589 acres. Of this total, 249 acres are
proposed for release using various individual stem treatments,
and 340 acres are proposed for release using an aerial
herbicide application. Prescriptions for various treatments
are based on several factors; including, number and
distribution of competing stems, size of crop trees,
accessibility, and location of plantation in relation to
wetlands, surface waters, and heavy public use areas or
travelways.

Project Proposal

The project proposal is to release 340 acres of conifer
plantation from competing vegetation. The 2,4-D herbicide
ESTERON (R)99(R), Concentrate (EPA Registration No.
464-201-AA, Appendix F), a iow volatile ester; is the chemical
selected to accomplish the release. The herbicide will be
diluted with water and applied at a,rate of 8 gallons
herbicide-water spray mix per acre. Herbicide volume will

be 3 quarts per acre. Application will be by helicopter
equipped with a microfoil spray boom from an altitude of 50 to
60 feet above the vegetation. A 0.013 inch orifice nozzle
will be used. A nozzle of this size produces droplets with a
nearly uniform mass median diameter of from 1,500 to 1,700
microns. The purpose of having large droplets is to eliminate
spray drift and to minimize volatilization. The proposed
project is scheduled for completion between July 20, 1976, and
August 20, 1976.

Controls on our use and measures to mitigate identified
environmental impacts are listed in Section II-D.

Treatment Areas
Wildlife species on the Nicolet National Forest.

The Nicolet Forest is the home of many species of animals and
birds. A partial listing of these species that might be found
on the Nicolet is included in Appendix D. Wildlife species
present on the Forest may or may not include the 10 areas to
be treated with 2,4-D as part of their normal habitat.

An application of 2,4-D to these 10 areas will cause only a
minor and short-term habitat change. This change will be the
removal of the ingrowth of broad-leaved plants that have
invaded these areas since planting. The major habitat change
occurred at the time the mature timber was removed. We are
now managing these sites as red pine and black spruce
plantations. A herbicide manual or mechanical treatment now
would create the same habitat change. If the 2,4-D treatment
is successful, the change in vegetation will only be to take
these 10 areas back to the vegetative condition that existed
4-5 years ago when they were planted. The total effect of
treating 340 acres on the Nicolet National Forest will be to
affect 0.05% of the total habitat available on the Forest.

The total effect on wildlife will not be a significant

change. Rare or unique species identified as important to
this project are the Northern Bald Eagle and the American
Osprey. Nesting habitats adjacent to the spray areas have
been identified and protected by flight restriction areas
shown on the project maps. As discussed under environmental
effects, there is no evidence that any individual animal would
be psysiologically harmed by the content or amount of spray
material to be applied to these areas.

See Appendix B for Vicinity Map and Appendix C for individual
Area and Project Maps.

Area #1

Area 1 is located in the NE 1/4 Section 4, T37N, RI16E, Forest
County, Wisconsin. Area 1 is a 43 acre black spruce
plantation. Thirty-eight acres are proposed for aerial spray
to release the planted spruce from overtopping aspen and paper
birch. The,east side of the plantation area adjoins private
land owned by Armstrong Creek Township. There are no
residences on the private land. The private land is timber
covered and used for production of forest products.

The north boundary of the spray area is approximately 100 feet
south of private land. The owner of record is

Wayne Vandermeulen. There is a seasonal residence located
approximately 700 feet north of the spray area.

A 100-foot buffer area adjacent to private land on the east,
and 4 wet bog on the southeast will be established to prevent
any spray drift from getting onto private land or the wet
area. The west boundary of the spray area is National Forest
and is bordered by tall timber. A 100-foot area adjacent to
the timber will not be sprayed to provide a safety buffer for
the aircraft and pilot.

Soils on Area 1 are of the Stambaugh silt loam acpticemgee

These are deep, well-drained soils with medium infiltration
rate and slow permeability. There is very little run off from
these soils. Ground water is 5 or more feet below the
surface. Slopes are less than 10 percent and little erosion
Will occur On this site.

Area 1 lies .75 miles northeast of Laura Lake, 1.2 miles
northeast of Laura Gordon Campground, and 0.6 miles north of
an unnamed pond. The closest permanent dwelling is 12 miles
east of the spray area. Recreational use of the area is
limited to very occasional visits by hunters during the fall.

The original timber on this area was believed to be a mixture
of pine and hemlock. Poor quality aspen invaded the area
following clear cutting in the early 1900's. The aspen was
harvested in 1970, the site prepared by rock raking in 1971,
and planted to spruce in 1972. Spruce produce softwood timber
products.

This area has received no previous herbicide treatment.

This area will be sprayed from helipad B located on spray
Area #3.

Area #2

Area 2 is located in the NE 1/4 of Section 4, T3/N, RI16E,,
Forest County, Wisconsin. Area 2 lies .12 miles west of
Area 1. The two areas are separated by .12 miles of uncut
timber.

Area 2 was cut in 1970, site prepared in 1971, and planted to
red pine and black spruce in 1972. The north boundary of
Area 2 is .12 miles south of private land and surrounded by
uncut timber. Ten of the 20 acres of the plantation will be
aerially sprayed to release planted trees from aspen
competition.

The relationship of Area 2 to private land, water, residences,
and other human activity is substantially the same as
described for Area l.

The helicopter spraying Area 2 will use helipad B located in
Area 3.

This area has received no herbicide treatment in the past.
Area #3

Area 3 is located in the SW 1/4 of Section 7, T37N, RI6E,
Forest County, Wisconsin. Area 3 is a black spruce plantation
of 52 acres, of which 44 acres are proposed to be released
from overtopping aspen, willow, and several other minor
broad-leaved species. The closest private land is southerly
about,.25 miles. It is owned by Consolidated Papers,

ince These lands are managed as commercial forest lands

for timber production.

A 100 foot buffer area is developed around the lowland conifer
stand on the south edge of this plantation. Also, the west
edge of this plantation will not be sprayed to protect some
planted wildlife shrubs. Within the plantation is one wet
depression where standing water occurs at times of high
rainfall. This area will not be sprayed.

Soils on Area 3 are of the Padus swe, © These loams have
a high infiltration rate and a rapid rate of permeability.
Fragipans present in the underlying strata of these soils
often restrict permeability in local areas. The water table
is below 5 feet in nearly all this area.

Area 3 is .5 miles to a spring pond which flows to a stream
known as West Branch Armstrong Creek. Rat Lake is .75 miles
south of this area. The closest resident to this area is
southeasterly 1.5 miles.

The original timber stand on this area is not known. It was
harvest cut for aspen 15 to 18 years ago. A very low quality
stand of aspen came back and developed pathological problems.
Management decided to convert this stand to black spruce in
1972. In 1973, the area was prepared by rock raking and
planted to spruce in the spring of 1974. Spruce management
will fully use the capability of the site to produce softwood
timber products.

This area has received no previous herbicide treatment.

This area will be sprayed from helipad B which is located at
the southwest edge of this site.

Area #4

Area 4 is located in the SE 1/4 of Section 35, T39N, RI5E,
Florence County, Wisconsin. The 35 acre red pine and black
spruce plantation will be sprayed to release the planted trees
from aspen, red maple, and hazel competition.

Area 4 is surrounded by National Forest land. The closest
other ownership is .25 miles south and owned by the State of
Wisconsin. All other ownerships within .5 miles of Area 4 are
used for commercial forest purposes. The closest residence is
1 mile south.

The nearest permanent water body is .38 miles southeast.
There are no streams or wet areas immediately adjacent to this
area,

Area 4 is located in a part of the Nicolet Forest that
recelves very light recreation use. This area would
occasionally be visited by a hunter, but very few persons
would use this area for other recreation activities.

Soils of Area 4 are of the Stambaugh silt loam Sericeece
These are deep, well drained soils with a medium infiltration
rate and slow permeability. There is very little runoff from
these soils. Ground water is 5 or more feet below the soil
surface.

The original timber on this area was believed to be northern
hardwood - hemlock. The site was occupied by aspen and the
poor quality residual hardwood following clearcutting in the
early 1900's. Merchantable trees were harvested in the late
1960's. The site was rock raked in 1971, and planted to red
pine and black spruce in 1972.

This area has not received a previous herbicide treatment.
Approximately 70 acres of plantation, just south of Area 4,
were sprayed with 2,4-D in 1973.

The helipad for Area 4 is on National Forest land,
approximately 1,300 feet west of the spray area.

Area #5

Area 5 is located in the SW 1/4 of Section 8, T40N, R12E,
Forest County, Wisconsin. Area 5 is a 40 acre red pine
plantation. All 40 acres are proposed for release from aspen
competition by aerial spray.

There is a privately owned tract of land approximately 150
feet east of Area 5. There are no buildings or occupancy on
the private holdings. The land is currently forested. The
owner of record is Dale Jewson. The nearest occupied
dwellings are .75 miles southeast, 1 mile north, and 2 miles
west.

There are no streams or wet areas within Area 5. The nearest
permanent water body is .5 miles southwest. There is a wet
marsh that comes within 150 feet of the spray area. The 150
feet of forested land between the spray area and marsh will
provide sufficient buffer area to protect the wetlands.

Area 5.goils are mainly of the Crivitz loamy fine sand
series. with a small area of Padus loam on the eastern part
of Area 5. Crivitz soils are deep, excessively drained
soils. They have high infiltration rates and rapid
permeability. There is seldom any surface runoff. Padus
soils are deep and well drained. Infiltration rates are
usually high, permeability rapid, with no surface runoff.

Ground water in both soil types would be five or more feet
below and the soil surface.

Original forst types on Crivitz soils were red and white
pine. Original clearcutting in the early 1900's removed the
pine types. These were replaced by aspen. The aspen stand
was harvested in the late 1960's, the area rock raked and
planted to red pine.

There is an osprey nest location approximately .25 miles
southwest of the spray area. To prevent disturbance to any
nesting birds, a flight restriction area has been established
west of Area 5. The flight restriction area is shown on the
map of Area 5 in Appendix C. The spray contract will prohibit
the helicopter from flying over this area during spray
operations or when coming to or leaving Area 5.

Area 5 is located approximately 3 miles south of Forest
Service Kentuck Lake Campground, 2.5 miles north of Franklin
Lake Campground, and 2.25 miles east of Anvil Lake

Campground. While recreation use in this vicinity is heavy,
few people have been observed using National Forest lands
where spray Area 5 is located. Most recreation visits to
this vicinity are to the many lakes of the area. There are no
established hiking trails that would lead people to enter
spray Area 5.

This area has not received a previous herbicide treatment.

The helipad for Area 5 is located approximately 300 feet north
of the eastern edge of the area.

Area #6

Area 6 is located in the SW 1/4 of Section 7, T42N, RIIE,
Vilas County, Wisconsin. Area 6 is a 65 acre red pine
plantation. Twenty-eight acres are proposed for aerial
spraying to release the planted pine from overtopping aspen.
The area is surrounded by National Forest lands. It is
bounded on the east by a transmission line that is under
special use permit to Wisconsin-Michigan Power Co. A private
tract of 30 acres owned by Catherine Hunt is located 700 feet
north and west of the spray site. No developments are located
on this tract. The nearest full-time resident is located east
of the site about 1 mile, near the shore of Lac Vieux Desert
Lake.

B-1C

The southeast corner of this site is within the seen area from
County Trunk Highway E. For the traveler along this road,
only a few seconds vision would be available at normal travel
speeds for this highway.

Soils on this area are of the Vilas pericseo Infiltration
and permeability rates are very high on these porous soils.
Water tables are usually below 5 feet in depth. Run-off is
nearly non-existent on this soil type.

Area 6 is 1 mile west of Lac Vieux Desert Lake. The Wisconsin
River is 400 feet from the northeast corner of this area.

The timber on this site was a mixture of jack pine, red pine,
white pine, and aspen. It was harvest cut in 1969-1970.
Planting of red pine was accomplished after a prescribed burn
in 1971s

Herbicides have been used along the transmission line by the
power company on the very east edge of this site. As a whole,
herbicides have not been used on this site in the past.

This area will be sprayed from helipad G which is on the site.
Area #7

Area 7 is located in the SE 1/4 of Section 23 and the SW 1/4
of Section 24, T41N, RI11IE, Vilas County, Wisconsin. Area 7 is
a 57 acre red pine plantation. Thirty-seven acres are to be
sprayed to release the planted pine from aspen competition.

The nearest parcel of privately owned land is .37 miles west
of Area 7 at the closest point. The owner of record is Waino
Alinin. Current usage of the land is for forage crops and
timber products. There is a permanent residence on the land.

Soils in Area 7 are of the Pence sandy loam series, Vilas
sands, and Vilas loamy sands series. Slopes are 10

percent or less. Pence series soils are deep and excessively
drained. There soils have high infiltration rates and medium
to rapid permeability. They drain quickly after rain, with no
surface runoffs. The Vilas series are deep, excessively
drained soils. The soils are porous and droughty, with a high
infiltration rate and rapid permeability. Rainfall is
absorbed with no runoff. Ground water would be 5 or more feet
below the soil surface.

These dry sandy soils were originally pine lands. Area 7 was
stocked with 70 year old jack pine prior to harvest in 1969.
Area 7 was site prepared by prescribed burning and planted to
red pine in 1971.

ie al

Area 7 is in two parcels. The west side of the eastern
segment abuts a marsh - wetland. A 100-foot buffer strip will
be left adjacent to the marsh to prevent any spray material
from entering the marsh. There is a 600-foot strip of uncut
timber on the east between the spray area and the Deerskin
River, a cold water trout stream.

A small spring pond arises in the marsh between the two
portions of Area 7. Water from the spring pond flows
approximately .75 miles southeasterly and enters the Deerskin
River. There is very little risk of contaminating the water
with the spray due to the buffer strips and other control
methods. The Forest hydrologist has recommended that this
spring pond be tested for the presence of 2,4-D both, before
and after spraying. The objective of the water tests will be
to test the effectiveness of the methods used to prevent 2,4-D
from entering water bodies. Area 7 is the only site close
enough to water to make testing worthwhile.

Area 7 is adjacent to Forest Road 2537. This road is
maintained for public use, but is lightly used by the public.
The nearest developed recreation area is Spectacle Lake
Campground, 4 miles to the east and Anvil Lake Campground,

6 miles south. Some visitors use this area for access to the
Deerskin River for trout fishing. Deer hunting use is
relatively heavy in this part of the forest. Some berry
picking may occur within Area 7. The greatest concentration
of blueberry plants occurs in the western part of this area
adjacent to Road 2537. This part of the area does not need
spray to release the pine. Where the aspen stems are denser
in the spray portions of Area 7, there are few blueberry
plants.

Area 7 will be signed along Forest Road 2537 with notices that
the area has been sprayed with 2,4-D. This should alert all
visitors to the area of the possibility of chemical residue on
wild fruits.

The helipad for Area 7 is adjacent to the spray area on the
north side. There has been no previous herbicide application
on this area.

Area #8

Area 8 is located in the west 1/2 of Section 34, and SE 1/4 of
Section 33, T37N, R12E, Forest County, Wisconsin. The
plantation is 57 acres in size, of which 56 acres will be
treated with herbicide to release red pine from aspen

sprouts. The area is totally surrounded by National Forest
land for a distance of .75 miles. Northwest of this site,
Matt Zver has 91 acres of timbered land. The closest
full-time resident is on the shore of Pine Lake, a distance
oLelemile:

Bi

The Wolf River is south and east of this site. Its flood
plain is a bog and sedge ecotype of 100 feet in width. A
heavy spruce stand adjoins the bog-sedge type grading to the
high ground where the plantation is established. This spruce
stand is from 300 to 1,000 feet wide between the bog-sedge and
plantation.

Several wet areas exist in this plantation. A 100-foot buffer
strip is proposed to avoid any herbicide from getting to the
water.

Soils on Area 8 are of Pence-Crivitz erica: Infiltration
and permeability rates on these soils are high. No runoff is
expected to occur. Water tables are generally below 5 feet in
depth. These are gently rolling soils and some grades of
15-20 percent occur for short distances. Erosion is
negligible on this site.

The original forest on this area was a white pine type. It
was clearcut in the early 1900's and following a burn, gave
way to spruce-fir and low quality aspen. In 1971 and 1972, a
harvest cut of all trees was made. The area was then rock
raked in 1972, and planted to red pine and black spruce in
1973.

An active eagle's nest is present along the Wolf River, 1.2
miles north and west of this site. A flight restricted area
will be adhered to north, west, and east of this site, so as
to create as little disturbance of these birds as possible.

There has been no previous herbicide application to this site.

Area 8 will be flown from helipad J, which is located within
the site.

Area #9

Area 9 is located in Section 10, T31N, RI5E, Oconto County,
Wisconsin. Area 9 is a 76 acre red pine plantation with

32 acres to be sprayed to release the planted red pine from
aspen competition.

The nearest parcel of private land is 1 mile north and east of
Arealgouelhe: owners of record are Fs J< and R.°M. Hallada.
The closest residence is 1.5 miles south.

The soi of Area 9 are Vilas sand and Vilas loamy sand

series. These are deep, excessively drained soils.

Slopes are 15 percent or less. These soils are porous and
droughty, with a high infiltration rate and rapid permeability.
Surface runoff seldom occurs, and there are no drainage
channels developed. These soils were originally pine lands.
Following the original clearcutting at the turn of the

century, the site was barren or occupied by poor quality

aspen. Area 9 was planted to red pine during the Civilian
Conservation Corps days in the 1930's. In the spring of 1901,
the Civilian Conservation Corps planted red pine were
destroyed by wildfire. Area 9 was replanted to red pine
following the 1961 burn.

Hills Pond Creek is approximately 300 feet west of Area 9.
Hills Pond Creek is a popular cold water trout stream. The
300 foot strip between Area 9 and Hills Pond Creek is a mixed
stand of aspen and white pine and will not be sprayed. The
stand of timber will serve as a buffer area between the spray
area and the creek. :

Area 9 is divided by Forest Road 2113 (Oconto County

Trunk T). This is a heavily travelled road, leading to
Boulder Lake Campground 4.5 miles south. Area 9 is crossed by
forest visitors going to Hills Pond Creek for fishing, and is
heavily used during the deer hunting season in November. Area
9 has very few wild berry plants and is not commonly used by
berry pickers.

Dead vegetation will be visible from Forest Road 2E1S
following the herbicide spraying. At this location, however,
Forest Road 2113 is a deep cut. The screening effect of the
cut, and a few large conifers adjacent to the road, will
soften this impact. Area 9 will be posted with public notice
signs following herbicide application. These signs will
notify the public entering the area that it has been treated
with 2,4-D.

The helipad for Area 9 is located immediately adjacent to
Area 9.

There has been no previous herbicide application to this area.

Groundwater for Area 9 is 5 or more feet below the surface of
the sovl.

Area #10

Area 10 is located in the NW 1/4 of Section 5 and NE 1/4 of
Section 6, T31N, RI5E, Langlade County, Wisconsin. Area 10 is
a 20 acre red pine plantation. Twenty acres are proposed to
be sprayed to release the planted pine from aspen sprouts.
This site is totally surrounded by National Forest lands. The
nearest private land is westerly of the spray area .5 miles.
This land is subdivided into lots which are occupied by
recreation residence. The land is timber covered for the most
part. The nearest full-time resident is 2.5 to 3 miles
distant.

Near the northeast corner of the spray area is a swampy area.
A 100-foot buffer strip separates the treatment area from the
swamp.

Soils in Area 10 are of the Vilas perice. ~ These soils

have a very high infiltration and permeability rate. Water
tables are below 5 feet on nearly all locations of this site.
Erosion from run-off will be negligible because of very gently
rolling terrain, with no slopes exceeding 5 percent.

The original forest here was large white pine. Stumps are
still present after the clearcutting and burning of the early
1900's. Aspen occupied this area until it was prepared for
planting in 1972, and planted to red pine.

There has been no previous herbicide application to this area.

The area will be sprayed from helipad K, located close to
Area 9.

Controls and Mitigations

1. To protect the air environment in the Nicolet National
Forest, the following application practices have been
adopted.

-Limit the fall distance of herbicide from
helicopter to vegetation to 50 - 60 feet.

-Use spray equipment that is calibrated to
produce large droplets, e.g. the microfoil
boom with .013 inch orifice nozzle.

-Use a low volatile chemical formulation of 2,4-D.,

-Spray only when the wind velocity does not exceed
oes oH 9

-Spray only within a temperature range of 50-80°F.

-Spray only when the relative humidity is above 50
percent.

2. To protect the water environment in the Nicolet National
Forest, the following application practices have been
adopted.

-No herbicides will be applied within 100 feet
of open water such as streams, ditches, lakes, and
ponds.

-The water supply for mixing with the herbicide
shall be from a domestic source and protected
from back siphoning from the mixing tank.

-Ferrying routes by applying helicopters will not
cross lakes or ponds, and will avoid other open
waters where practicable.

-No spraying when fog or aic turbulence is present,
or rain is expected on site within 2-4 hours.

3. To protect the soil environment in the release areas, the
following application practices have been adopted.

-Herbicide containers will receive a triple rinse,
with rinse water being added to the spray mix,

and the containers disposed of in accordance with
Environmental Protection Agency requirements or in
State land fills approved for such disposal.

-To avoid contaminating areas not scheduled for
treatment, the entire aerial spray system must be
leak proof and have a positive shut-off mechanism
capable of eliminating drool of the nozzles or
clusters of nozzles.

4. To protect the wildlife environment in the release
Sl aes nee :
areas, the following practices have been adopted.

-Review the list of endangered and threatened
wildlife published in the Federal Register
40(188): 44412-44429, September 26, 1975
(memo to Forests, 2630, October 2, 1975). No
endangered or threatened wildlife are TOL
near the treatment areas.

-Review "Unique" species identified in FSM 2622.4;
The Fairest One of All; State legislation; or,
species identified in Forest Unit Plans. No unique
species of wildlife are in the treatment areas.

One osprey nest west of Area 5 will be protected
by restricting the flight path of the helicopter to
prevent flight over or near the nest.

-We will follow management practices approved for

the protection of active habitat sites for identified
unique, threatened and endangered wildlife species.
FSM 2633.4 (Appendix E).

-Critical habitat for endangered or threatened
wildlife species will be preserved and not modified.

5. To protect the vegetation <uvironment in the release
areas the following practices have been adopted.

-Review the list of endangered or threatened
plants published for Wisconsin in the Federal
Register Vol. 40, No. 127 on July 1, 1975 (Memo
to Forests 2600 Habitat, December 11, 1975). No
endangered or threatened plants are in the
treatment areas.

-Most endangered or threatened plant species are
found in unique micro-habitats which can be
learned and identified. Most such plants which
might be on the Nicolet are bog species and
would not inhabit these upland treatment areas.

6. To protect man the following application practices have
been adopted.

-Only a 2,4-D currently registered and labelled by
the Environmental Protection Agency for the
specific use proposed will be used.

-The proposal to use the herbicide 2,4-D has gone
through an established review process.

a. Areas are field surveyed by Ranger District
Stati.

b. Alternatives for those areas needing treatment
considered.

c. A proposal for herbicide written based on
area needs.

d. Nicolet National Forest pesticide use
coordination review.

e. Forest Service Region Chemical Use
Coordinating Committee approval.

f. An adequate Environmental Analysis Report
be written, and approved by the Forest
Supervisor, that is site specific and
describes relevant information required
for public and other agency understanding.

-Whenever reasonable, recommend and use effective,
safe, integrated suppression measures that may
utilize biological, ¢ultural, and other techniques
in place of or in association with herbicides.

-Obtain legal clearances required by Federal, State
and local laws or regulations before using 2,4-D.

-Provide for adequate training of all personnel
who handle or supervise the use of 2,4-D.

-Brief applicators before and during this project
in safe measures for transporting, mixing, and
applying 2,4-D; use of protective clothing and
equipment, plus the need for personal hygiene will
be thoroughly discussed.

Die

-An unsprayed buffer zone of at least 100 feet will
be left adjacent to all private property.

-Application will be carefully supervised to assure
that all stated precautions for 2,4-D use are being
observed.

~Areas being treated will be posted with signs
advising the public that the area has been
sprayed with 2,4-D (Appendix F). Signs will be
left in place for 90 days following the applications
of spray.

ENVIRONMENTAL EFFECTS

The herbicide 2,4-D has been widely investigated and studied by the
scientific community. Many of these studies have been under forest
conditions and methods of application proposed for use on the
Nicolet National Forest. These studies, plus 25 years of use
experience and observation by professional land managers, have been
used to develop this section.

A. Non-Living Components

i

Air. The herbicide 2,4-D can enter the air systems

‘and may contribute to air pollution. Entry may

be in the form of vapors, droplets, or as photo-altered
products. Volatilization and photo-alteration occurs
both during 2,4-D fall from aerial applications and
from the vegetationn surface. Droplets, vapors, and
drift become pollutents as aerosols (mass median
diameter less than 200 microns) captured and held aloff
by the wind.

Entry of 2,4-D into the air is determined by localized
atmospheric conditions, droplet size, and herbicide
formulation. Climatic parameters are wind-speed,
temperature, light intensity, and humidity. Application
equipment determines droplet size. A low volatile 2,4-D
will reduce the chance for volatilization because of a
heavier molecular weight. Herbicide loss can be
lessened by reducing the fall distance (See Figure Loe

There will be some odor from the application of 2,4-D.
This odor will be noticeble only for a very few days
and only for a very short distance from the application
site.

Minor air pollution from the helicopter engine exhaust
WiLL occur,

Hazardous Substances. The herbicide 2,4-D is listed in

in the United States Department of Agriculture Handbook

No. 332 (1969) as being only slightly toxic and mildly
irritating. Dioxins have not been found in 2,4-D. The
2,4-D approved by the Environmental Protection Agency is
found in all common weed killers sold to the general public
for yard weed control.

Soils. The forest floor will be a major receptor of 2,4-D.
Deposition may be direct, washed from vegetation by rain or
excreted from vegetation. Once on the forest floor, some
2,4-D loss will occur by photo-alteration and through
volatilization. The remainder will be washed by rainfall
into the humus layer and lower soil layers. What

happens to the 2,4-D after entry into the soil depends

on a number of soil factors including organic content,
moisture, aeration, temperature, iron oxides, pH and

clay content. High organic matter, high pH, (neutral

to slightly alkaline), high soil temperature, and high

soil moisture all tend to reduce the life of 2,4-D in

the soil. Soil micro-organisms also aid in breaking

down the 2,4-D. After entry into the humus and soil

layer, further movement is much reduced. 2,4-D is

quickly degraded in 2-4 weeks, it does not accumulate

in the soil. The herbicide 2,4-D gives non-toxic and
naturally abundant end products, such as carbon dioxide,
water, and chlorine.

Adsorption and leaching also take place in the soil.
Herbicide molecules attached to soil particles provide
temporary soil storage for later release. The free
and released molecules are subject to leaching

and movement with soil erosion to water sources. The
leaching of 2,4-D in the soil is a slow process and
seldom penetrates more than a few inches into the soil.

Soil loss by erosion rates up to 0.1 ton per acre per
year from forest land and must be accepted as a normal
geologic process. The rate probably varies from less
than 0.05 to 0.3 ton per year, depending on geology,
soil, climate, and vegetation. It is the most active
where annya 1 precipitation ranges from 15 to 30 inches
per year.

This might indicate a potential for soil bound herbicide
molecules to move with soil erosion to surface water.
However, most soil erosion in the undisturbed forest

is not sheet erosion, but almost always originates in
stream channels. On land sloping less than 35 degrees,
there is no evidence that tree death accelerates soil
erosion much above geologic rates.

Massive rainfalls, bare soils, or excessively steep slope,
combined with soils containing 2,4-D molecules can be
exception to this norm. The potential for surface water
contamination resulting from erosion of soil containing
2,4-D is further reduced by leaving a buffer zone around
water areas. These buffer zones serve as filter strips
which trap sediment, should erosion occur.

Although the indiscriminate use of 2,4-D may result

in environmental degradation, a review of the literature
and results of 25 years of Forest Servite herbicide
applications in Wisconsin indicate that the risk to the
soil within or adjacent to spray areas is minimal when
2,4-D is applied according to guidelines established

for this proposal. This conclusion is based on the low
toxicity of 2,4-D to other than target organisms and the
relative immobility of 2,4-D in the soil, plus the rapid
degradation of 2,4-D within the soil.

Visual. Visual impacts associated with using 2,4-D to
control vegetation include dead leaves, dead branches
and standing snag trees, and a change in vegetation
contrast.

The "brown out" caused by curing of the target
vegetation following 2,4-D applicaton has an
immediate and adverse visual impact. Visual and
aesthetic values are generally lowered during brown
out; however, the effect is temporary, lasting only
until, leaferall.

In the case of dead brush left from 2,4-D use, the visual
signs may last 5 years or more.

The objective of 2,4-D use is to create a vegetation
change. This change can be both adverse and pleasing,
depending on the thinking of the viewer. If the

contrast in vegetation change looks artificial or out

of place, the visual impact can be negative. At the same
time, the diversity of vegetation and new stands of trees
or grass, encouraged by spraying, add to the attractiveness
of an area.

Water. No area of environmental concern has received as
much attention as water quality and quantity. Water,
especially the oceans, is the repository for pollutents
washed from the air and soil. The waters associated with
the Forests of Wisconsin are mainly head waters and known
for their purity.

Any 2,4-D found in the waters of Wisconsin Forests should
be considered a contaminant. Certain concentrations of
2,4-D in water could adversely affect the potability of
drinking water for man and animals, the food chain
organisms in the aquatic environment, sensitive irrigated
crops, and industrial and recreational uses of such water.

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Entry of 2,4-D into the surface water may be direct,
by over land washing of soil, air wash out, or
ground water flow. Direct entry is mainly caused by
an error in application or through drift.
Concentrations may reach 1 ppm, but will be short
term and local in nature.

Washing, as a source of contamination, can occur, but
must overcome considerable resistance from forest
vegetation and humus layers protecting the soil.
Massive rainfalls immediately following an herbicide
application, unprotected soils, steep slopes, and a
short distance from treated soil to surface water all
increase the chance of surface waters becoming
contaminated from an herbicide treatment area.

Knowing that herbicides can enter the surface water

needs to be related to what has actually occurred in
field use. From 1972 to 1975, 13 separate water

surface sites close to aerial applications of 2,4-D

were monitored on National Forests in the Lake States.
The surface waters included rivers, a pot hole, an
impoundment and marsh. Eighty-two samples collected

were tested. These samples were collected immediately
after spraying; 4 hours, 24 hours, and 65 hours later;
and, after the first rain. Only six samples showed
detectable amounts of 2,4-D. The highest being 16.0

ppb (parts per billion) and showing up after a
thunderstorm rainfall totaling .32 inches. This rain
fell within 1 day of spraying. The water sample was
collected adjacent to the treated area from an
intermittent stream that was not protected and directly
sprayed. This is still below the 20 ppb limit recommended
for public water supplies by the Environmental Protection
Agency, and much below the LC.) values for sensitive
crustaceans and fish.

Measured concentrations were considerably less than the
24 hour LC (lethal concentration to 50 percent of
test organisms) of .960 ppm for rainbow trout using a
prophylene-glycol-butyl-ether ester of 2,4-D (U.S. Forest
Service, 1973; after FWPCA, 1968). These results
indicate that the aerial application of 2,4-D to sites
treated on the Forest resulted in negligible
contamination, and that controls over the 2,4-D aerial
spray program have been adequate for avoiding surface
‘water contamination. These controls will also be in
effect during 1976, on the Nicolet National Forest.

A 100-fold reduction in herbicide concentration, with

downstream movement of about 1 mile, has been observed
invseveraitests, but it 1s difficult to give an

B-21

exact rule of thumb because of the nature of the dilution
process in forest streams. If we accept a 25-fold
reduction in concentration over a mile of stream as a
conservative estimate, maximum herbicide concentrations
of 0.01 ppm observed at the boundary of a treated area
and stream would be less than 0.01 ppm 1 mile downstream.
Return to pretreatment levels will be obtained in less
than 24 hours after application. Therefore, maximum
possible human exposure levels might be 0.01 ppm (10 ppb)
for 24 hours, if water for consumption is taken from the
stream immediately downstream from the treated area.

Of course, the more remote the treated area is from the
stream, and the further the water to be drank is from

the water entry point, the less likely the probability

of detectable residue occurring (Abrahamson and

Norris, 1976).

Mullison (1970) 1? reviewed concentrations of herbicides
found in water after spraying the adjacent upland.
Detected concentrations were 0 to 70 ppb (phenoxys).

Time for total disapperance ranged from 2 to 17 days
(phenoxys). It is evident that precautions given on the
2,4-D label are adequate to allow the material to be used
safely.

The effects of vegetation management on tiny headwater
stream flow within the Nicolet National Forest may be
measurable, but are seldom detectable when the far
greater volumes of flow in large rivers are measured.
Stream flow increases are proportional to area and
severity of vegetation control. An increase in water
quantity comes about as evaporation losses through
vegetation transportation and interception decreases.
Vegetation regrowth may return the area to before 2,4-D
treatment transportation levels in 1 to 10 years,
depending on the degree of control, making the increase
in water quantity short lived as well as tiny. A minor
long term water quantity out flow may occur due to a
perpetuation of a specific vegetation type. Permanently
foliaged conifers intercept as well as transpire more
water than do deciduous hardwoods , while grass uses
less than either kind of tree.

Drs. Abrahamson and Norris (1976)° reported on the
results of extensive water monitoring investigations
following present-day forestry herbicide applications.
Forest stream monitoring for several herbicides over
extended periods of time has consistently shown that
leaching of herbicides in forest soils have not
resulted in detectable (less than 0.001 ppm)
concentrations of herbicide in forest streams. Field
testing on forest land has verified that overland flow
of herbicides is restricted to localized events and
that the overland flow has shown marked reduction in

herbicide concentration in water as it moves over
uncontaminated soil. These measurements were made
immediately downstream from treatment unit boundaries
and, therefore, represent maximum concentration in the
stream system. When herbicide concentrations have been
detected, more than 99 percent of all concentrations have
been less than 10 ppb.

While the probability of the 2,4-D applied to these 10
areas reaching surface water is very low, one site will be
monitored before and after treatment to test the
effectiveness of the spray application control methods.
(Refer to hydrologists recommendations, Appendix G).

Water samples will be collected before spray application,
immediately after spraying, 1 day after spraying, and as
immediately after the first and second rains following
Spraying as possible. These samples will be tested for
2,4-D by the WARF Institute, Inc., Madison, Wisconsin. The
results of the monitoring will be assembled in a report to
the Forest Supervisor, Nicolet National Forest. This
report will be on file in the Forest Supervisor's Office,
Federal Building, Rhinelander, Wisconsin. The public may
review the report after January 1, 1977.

B. Living Components

ile

Domestic Animals. The impact of 2,4-D use around livestock
and other domesticated animals is becoming well documented.
The lethal does for various test animals and particular
chemicals are known. The acute oral toxicity of a single
does of the phenoxy herbicides to mammals ranges from

100 mg/kg to 2,000 mg/kg. (Cast Report 39) Signs of
poisoning include loss of appetite, loss of weight,
weakness, lack of coordination, alterations of the liver
and other internal organs, and in some instances

defective offspring.

Since domestic grazing animals can tolerate up to

2,000 ppm of 2,4-D type herbicides continuously in feed,
there is no hazard to animals from forage residue,

even from treatment of ranges and pastures at

exaggerated rates. No residues appear in the milk of cows
consuming rations containing up to 300 ppm of 2,4-D.
Similar effects have been found with swine, sheep, and
other animals.

2,4-D is generally less toxic to birds than to mammals.
The acute oral LD 0 for poultry, mallards, and pheasants
range upwards of 3°500 ppm and is typically greater than
5,000 ppm when fed in treated feed.

A subtle effect of 2,4-D treatment to plants is the
increase in potassium nitrate to lethal concentrations
in nitrate accumulating plants. In some plants, such as

Canada thistle and smartweed or black cherry, the leaves
may become toxic to herbivores if eaten in sufficient
quantities. This may also be a natural occurring process
that takes place in Ehege plants as the vegetation goes
dormant in the fall. ’

2,4-D applications following label instructions approved
by the Environmental Protection Agency have not proven
harmful to domestic livestock. Instances have occurred,
however, where there have been poisonings by the use of
certain other herbicides or contamination from herbicide
accidents. The herbicide most often associated with these
accidents is 2,4,5-T and the dioxin that contaminates it.
Reports of these instances help expose the perils of an
accident, but should not be purported as examples of
regulated use of 2,4-D.

Man. Hazards to man are most likely to occur from exposure
to the concentrated 2,4-D before dilution. The principle
routes of entry into the body of man are by skin
absorption, oral ingestion, and inhalation. Diluted 2,4-D
may cause painful, but temporary discomfort to the eyes.

A massive dosage of 2,4-D received over a short period of
time could cause death. The LD for a 150-pound person
has been set at 500 ppm (500 aad Small doses, over a
long period of time to pregnant women hold potential

for inducing teratogenic effects in their babies. The
greatest risk is to those people manufacturing and
applying 2,4-D. A lesser risk exists for those who

might intake 2,4-D residues through forest water, fruits,
berries, or meat or wild game.

Few studies of 2,4-D toxicity to humans have been made.
The best we can do is project data compiled on other
animals to people. The 2,4-D herbicides available for use
in Wisconsin have been assigned a LD. of 500 mg/kg,

the toxicity for a 150-pound person.

2,4-D toxicity to a human depends on a herbicide being
present in or on an individual, in an active form, in
sufficient quantity, and for a period of time to produce
an effect. The chances of this combination of conditions
happening with 2,4-D treatments proposed is slight. As
an example, immediately following a 1973 spraying of
2,4-D on the Chippewa National Forest in Minnesota, the
concentration of 2,4-D on raspberries was found to be
4,000 ppb. A 198-pound person would have to consume
approximately 34,000 quarts of raspberries within a short
period of time to receive a lethal dose of 2,4-D from
these berries.

Statistics for the years 1971-73, published by the National
Agricultural Chemicals Association, show there were 13
fatalities: trom pesticides in 19710417/ in 71972). andelO0sin

1973. Of these, nine were from agriculture herbicides
Tied vein 1972, .and tour in 1973. Cancer from
herbicide use would be expected to be heaviest out where
the chemicals are used, where herbicide use is regular,
and where runoff from fields and forest might enter the
waterways. The Sixth Annual Report of the Council on
Environmental Quality published in December 1975, shows
just the opposite. "Analysis county by county," it says,
"reveals that a majority of the areas of high cancer
mortality are located in the large cities.'"' The report
also shows a two-thirds decrease of stomach cancer in
both males and females since recordkeeping started in
1930. A remarkable fact, considering some 40-odd years
of American diets consisting mainly of pesticide-protected
foods.

In the Totai Diet Program of the Food and Drug
Administration, grocery basket samples were collected in
30 different grocery markets in 30 different cities. The
sample tests covered the period of August 1972, through
July 1973. A variety of food classes was sampled. In
all, 1,729 chemical residues of 40 different compounds
were found. Only one, however, was a sample of 2,4-D (a
residue of 0.014 ppm was found on a vegetable).

In earlier monitoring programs, from 1963 to 1969, the
Food and Drug Administration found no residues of 2,4-D
in 13,000 samples of milk and 12,000 samples of meat.

Soil Organisms. The soil contains a large and varied
population of bacteria, fungi, actinomycetes, algae,
protozoa, insects, earthworms, arthropods, and

acarinids. The populations are measured in the millions.
Their activity vary greatly with temperature, moisture,
organic content, aeration, and soil texture. Soil
organisms are beneficial to higher plants. They are
essential for decomposing vegetative matter and aiding the
nutrient cycle.

2,4-D may have an adverse effect on some soil organisms.
At the same time, some soil organisms are attracted to
2,4-D. The reaction of the soil organisms depends on

the conditions found within the soil. There is no
evidence to indicate that the 2,4-D herbicides used when
applied at recommended rates, will have any lasting effects
on soil organism populations. Investigation of 2,4-D

on penicillia mycelial dry weight and total nitrogen
content have found both decreases and increases, depending
on pepgillia investigated and concentrations of 2,4-D
used.

In another study of 2,4-D with soil microflora, it was
found that soil microflora enzym systems adjust, either

through mutation or selection (or both) to utilize

2,4-D as a food source. At first, the 2,4-D was slow to
degrade. After 12 days, the degradation accelerated with
no 2,4-D 6 days later. Successive qqditions of 2,4-D were
completely degraded in 1 to 4 days.

a.

Vegetation

General. The herbicide 2,4-D is absorbed by plant

foliage, roots, and soft stem tissue. Once absorbed,

the 2,4-D moves within the plant along the pathways
that carry food and water. 2,4-D tends to accumulate
in the actively growing parts of roots and stems. As
the herbicide distributes through the plant, the
leaves and buds twist and curl, followed by malformed
new growth of stems and leaves. Sensitive young
plants may die in a few days. Hardy shrubs and trees
may succumb only after weeks or months, or may survive
without evident injury. The broad-leaved plants and
forbs are more susceptible to the herbicide properties
of 2,4-D than conifers and grass. Even within the
hardwoods, a degree of selectivity exists with target
plants like aspen, birch, hazel, and alder being
susceptible and maple, raspberries, and cherries being
more toierant.

In 1973 and 1974, acreage totaling 9,934 acres were
treated on the Chippewa and Superior National Forest,
Minnesota, and the Ottawa National Forest, Michigan.
The 2,4-D herbicide and application rate was the same
as proposed for use in this project. The average
percent control of the target species for all three
Forests was:

Species Percent Control
Aspen 70-90
Paper birch 90-100
Tag alder 90-100
Hazel 90-100
Sugar maple 50
Ras pberry 50

Our purpose in using 2,4-D is to elicit a certain
behavioral response from the vegetation. This
response is measured by the immediate reaction of
target plants to the herbicidal action of 2,4-D.
The response is also measured by the long-term
hardwood-conifer mix maintained within the Forest.

Very little of the 2,4-D reaching the vegetation is
metabolized. Rain washes much of the 2,4-D left on
the plant surface to the forest floor. Some 2,4-D

may be passed through the plant and excreted by the

roots into the soil. The remaining 2,4-D within

the plant and any breakdown products will eventually
enter the soil, either in leaf fall or decomposition
of dead stems and roots.

The application of 2,4-D may adversely effect some
nontarget plants. The degree to which this occurs
varies with the susceptibility of non-target plants,
the season of application, and how actively the plant
is growing. Should the red pine and black spruce

to be treated in this project not be completely
"hardened off", this year's needle growth would be
wilted by the 2,4-D. This condition is displayed

by a drooping of the needles on affected trees. It
does not bring about the death of the pines or spruce,
and is not considered serious.

Following the initial loss in target plant numbers
after the 2,4-D treatment, a new plant community will
quickly appear. The new community will be different
in size and age and may have a greater variety of
plant species. The wildlife and bird populations
should show a similar change. Desirable conifers,
once in a subordinate position, can now move to a
dominant position. It is the objective of vegetation
management to maintain this new plant community when
it consists of plant species desirable to the resource
manager.

Favorable effects of herbicide use can be 55e9, in the
survival and growth of host plants. Wilde’
calculated that pine plantations in Wisconsin require
about 331 gallons of water to produce 2.2 pounds of
merchantable wood, whereas evapotranspiration of ground
vegetation consumes about 23.5 gallons of water per 2.2
pounds of over-dry tissue. In turn, each 2.2 pounds

of weed bio-mass in the plantation throughout the

years reduces wood production 0.15 pounds. Therefore,
timber growth in plantations established in a heavy
cover of shrubby plants may under produce more than

15 cords per acre over a 40-year rotation, or more

than a 1/3 cord per acre per year. At current stumpage
prices, obviously, weed control is an excellent
investment.

In another Wisconsin growth study, diameter growth

in a 7-year old Wisconsin red pine plantation increased
30 percent the first year after herbicide application,
and 8 percent the following season. Height growth
increased 13 percent the second year. Two years

of shrub competition: control in another red pine
plantation increased growth by 300 percent.

In Minnesota, conifer plantation studies show more
seedlings were, killed by competing vegetation than any
other factor.

Endangered or Threatened Plant Species. Vegetation
management by any of the methods available to us

will probably affect endangered or threatened plants,
if they are in the area being treated. Broadcast
treatments are more likely to unintentionally damage
unknown populations of such plants, than are selection
methods of treatment. Herbicides are no exception.
The sensitivity of all the plants is now known; we
must, however, assume a 2,4-D program will have an
adverse effect on them. The Endangered Species Act of
1973 directed the Bureau of Sports, Fisheries and
Wildlife to publish a list of endangered and threatened
plants. They have adopted the Smithsonian Institute's
1974 report on endangered and threatened plant species
in the United States.

Forest Vertebrate Animals

General. A wide variety of wildlife species inhabit
the National Forest land of Wisconsin. The survival
needs of some species are very specific. Animals

like the bear or skunk are adaptable to a wide range

of foods, habitat conditions, and disturbance by man.
Proposed 2,4-D applications will occur on areas
occupied or visited by a significant number of wildlife
species. The wildlife impacts of any 2,4-D application
project will depend on the wildlife species present,
the size of the area treated, and the long term
resource management objective for the treated area.
Routine activities of individual wildlife species may
result in contacts with treated vegetation, soil, or
waters, or ingestion of treated food. Such exposure
under forest conditions has not proven hazardous to
wildlife.

Mammals. A hazard to mammals could occur if they were
exposed to an acutely toxic dose of herbicide. The
acute oral toxicity of a single dose of the phenoxy
herbicide 2,4-D to mammals ranges from 100 mg/kg to
2000 mg/kg, depending upon the test animal. 2,4-D is
absorbed in animals after ingestion, transported via
the plasma, concentrated,in the kidneys, and rapidly
eliminated in the urine.

Deer allowed to browse 2,4-D areas sprayed to improve
deer browse showed no preference for ejther untreated
or herbicide-stimulated branch growth. Test

animals are often repelled by herbicide residue on
their natural foods. When only limited areas are
treated, as proposed in this project, very few animals

will be forced to feed only on food contaminated with
7 ie Mad

B-28

Investigators!" found that deer exposed to feed

treated with maximum field applications of 2,4-D did
not accumulate significant amounts of herbicide.
Forty-three days after exposure, the muscle tissue of
the deer showed residue of 2,4-D at less than 0.006
ppm. This study, the U.S. Department of Health,
Education, and welfare Food Basket studies of meat,
fish, and poultry, and the Environmental Protection
Agency supported beef fat monitoring programs all point
out that herbicides proposed for registered use in the
Nicolet National Forest are not contaminating meat used
for human consumption.

The greater the number of plant species controlled at
any 2,4-D site, the greater the habitat impact on
wildlife occupying the area. The method of herbicide
application, broadcast or selective, also influences
this impact. The use of 2,4-D sets vegetation
succession back to an earlier stage. Small mammals
with small home ranges or very narrow habitat
tolerances will be most affected by the thoroughness
of individual herbicide treatments. Large mammals,
like deer or bear, benefit the most as an improvement
in food availability and food nutrition occurs within
their home range.

One 19 year qo of selective vegetation
management using herbicides showed a diversity of food
plants useful to wildlife developed on the sample area
following spraying. These plants included common herbs
of the forest as well as invaders usable as food by
many animals. Woody plants were found interspersed
throughout the treated area. The taller woody plants
were found to supply food throughout the year, and
were of particular value as emergency food when deep
snow covered the ground. The test area was heavily
used by common wildlife species such as white-tailed
deer, rabbit, and groguse. A special study made of the
white-tailed deer showed a consistent and heavey use
in all seasons, indicating that attractive food and
cover had been developed.

A more subtle and long term impact of vegetation
management is its affect on wildlife habitat.
Vegetation management will affect the vegetative
layering of the area treated and the species of plants
making up the replacement community. Because the
habitat needs of many wildlife species are very
specific, some animals will be adversely affected while
others will benefit. Investigators have found that as
the vegetation replacement community becomes
established, the original set of animal populations

largely be replaced by a different set of lesser
diversity. The replacement animals will have higher
numbers of fewer species, many of them new to the
sprayed area, but common to similar habitat types in
the Nicolet National Forest.

Vegetation management using herbicides is the most
effective vegetative control method we now have
available for our use. Most species of vegetation,
however, are only controlled for a period of time

and shortly return to the treated site, unless
periodically controlled or suppressed by host plants.
Wildlife biologists, have long used knowledge of

this fact to manipulate vegetation diversity and
maintain wildlife openings with herbicides to benefit
a variety of animals.

The activities of man and his equipment during
herbicide application will disturb wildlife. Large
animals will be able to leave the site temporarily,
while small mammals will head for cover or go
underground. This disturbance can have a serious
impact if it occurs during mating or at birthing
time. (Late July and August are not considered the
normal season for these activities). The implication
of using 2,4-D on total forest population distribution
or concentration will be very local in nature and
fluctuate only with changes in specific ecological
niches, rather than any direct detrimental effect of
the herbicides.

Birds. 2,4-D has been found to be generally less

toxic to birds than mammals. The oral LD... for

these birds with herbicide treated feed is typcially
greater than 5,000 ppm. Under field conditions, a

bird would have to daily consume all the herbicide
aerially applied to approximately 10 acres to duplicate
the 5,000 ppm feed under controlled trials.

Young pheasants have an LD. (Lethal dose for

50 percent of the organismS tested) of 472 mg of 2,4-D
per kilogram of body weight (U.S. Forest Serivce, 1973
after Pimental). The LD for grouse, a common game
bird on the Forest, is probably similar. Assuming an
LD<4 of 500 mg/kg for a grouse that weighs 1/2 kg.,

a grouse would have to eat 62.5 kg of raspberries
contaminated with 4,000 parts per billion of 2,4-D to
concentrate a lethal dose.

The large quantities of berries indicated above to
reach lethal concentrations would also have to be
consumed during a short period of time, since 2,4-D
does not concentrate within the organism through time,
unless exposure is constant. Obviously, the lethal

concentrations would never be accumulated. Ingestion
of lesser amounts may cause physiological responses
relative to reproduction and fertility (loss of egg
production in birds, and abortion in mammals). The
effect on egg production in birds has potential for
affecting very few species, due to the season of
application. The doses required to produce these
effects would probably not occur at the proposed rate
of application.

Feeding trials found that 2,4-D, when fed at daily
rates of 1,250 and 2,500 ppm, depressed mallard duck
reproduction.

Bramble and ae found wild turkeys and ruffed
grouse used 2,4-D treated areas. The young turkeys
were attracted to the openings to feed on various
insects more abundant on the grassy treatment areas
than within the wooded areas. Ruffed grouse numbers
were found on the edges within 150 to 200 feet of the
study area, rather than on the area itself. This
emphasizes the importance of using 2,4-D as a creator
of edge effects.

Aqueous solutions of 2,4-D, equivalent to 10 times
recommended field concentrations, were sprayed on
fertile pheasant eggs preceding incubation. No
treatments were found to cause any adverse effect

on hatching success, incident of malformed embryos, or
subsequent chick mortality relative to water-sprayed
control eggs. Herbicide contamination was found to
facilitate weight gain of roosters from 0 to 4 weeks
of age, while hens failed to show a response. Residue
analysis verified herbi¢ide deposition on the shell
and entry into the egg.

The helicopter itself may disrupt nesting birds and
other wildlife in the project areas. This would
probably not be of significant magnitude to constitute
an environmental consideration, except in the case of
unique species such as eagles, ospreys, and herons
that may be nesting in the vicinity of project sites.
During the time of year of application, both of these
species will have young in the nest near the fledgling
stage of development. The helicopter could
conceivably cause premature fledgling, or perhaps nest
abandonment, if proper precautions are not taken.

Ferrying routes and treatment areas will be located

a minimum of 20 chains (1/4 mile) from any known
active eagle nest, osprey nests, or heron rookeries.
This minimum distance may be increased for particular
nests, based on topography and screening vegetation
between the flight path and the nest site.

Bad

Fish and Amphibians. The toxicity of 2,4-D to fish
is highly variable and affected by chemical
formulation, water pH, temperature, water hardness,
oxygen content, and dilutent rate. The lakes, ponds,
and rivers of northern Wisconsin contain abundance
and variety of both warm and cold water fishy Minese
fish are important as a sports fishery.

For ESTERON 99 (propylene glycol butyl ether, ester)
the LC 0 at.48 hours of exposure for rainbow trout

is 0.98 ppm (one pound of herbicide on an acre-foot
of water is equivalent to 0.370 ppm). These values
are equivalent to treatments of 10 pounds of 2,4-D
herbicide per acre in a pond 4 feet deep; much higher
than the 3 pounds of herbicide allowed for application
by the ESTERON 99 Concentrate label use directions
for land vegetation treatments. The LC, for

bluegill to the same formulation of 2,42 at 24 hours
and 48 hours of exposure is 2.1 ppm , or about

23 pounds of herbicide per acre in a pond 4 feet

deep. If an accident were to occur that required the
dropping of a full 80 gallons of spray mixture into a
lake or pond, the one acre - 4 feet deep concentration
would be 2.8 ppm. This concentration would be quickly
diluted by the number of acres in the body of water,
photo decomposition, and micro organisms. There seems
to be a considerable margin of safety considering the
2,4-D contamination concentrations we have found after
forest herbicide treatments.

Schultz and Harman?! investigated the effects on
fish of 2,4-D applied directly to water. Rates used
were 2, 4, and 8 lbs. per acre. Only 7 percent of
the fish, analyzed 28 days or more after treatment,
contained detectable 2,4-D residues, and only

1 percent (one fish) of those analyzed

56 days or more after treatment contained detectable
residues. If tolerance levels are based on the level
of parent compound only, it would appear that fish
could be consumed one month after treatment. They
also found little danger of bio-magnification of 2,4-D
in the aquatic food chain. It was noted, however,
that when fish were exposed to radiated 2,4-D
radioactive compounds were ubiquitous in all fish
tissues examined. Degraded 2,4-D products were also
present for as long as 84 days after some treatments.
Therefore, the identity and potential toxicity of
these degraded products must rot be overlooked.

The ester formulations of 2,4-D are often more toxic
to fish than amine or metalicsulf formulations. This
is probably due to the more effective penetration
ability of esters.

The effects of 2,4-D use on amphibians has not been
widely investigated. The major impacts would
possibly be on frog egg and tadpole development.

Endangered and Threatened Animal Species. The

Forest Service does not have direct authority for
management of endangered and threatened animal
species. Our major contribution to preserving any
wildlife species appearing on State or Federal
official lists is through the management of critical
habitat. The U.S. Department of Interior, in
consultation with the States, is charged under the 1973
Endangered Species Act with completing and maintaining
official lists of wildlife species that are classified
as endangered or threatened. The Forest Service has
adopted these official lists and may expand them for
Forest use to protect additional unique wildlife
species. This proposed herbicide project has been
analyzed for its impact directly to any animal species
on an official list and the habitat loss or
modification that might occur.

6. Forest Invertebrate Animals

a.

General. The number of invertebrates per acre in a
forest environment can only be guessed at. The number
would be listed in the thousands. We are interested
in the impacts of 2,4-D use on invertebrates, because
invertebrates are an intricate part of a forest
community. Invertebrates are also important because
they serve as food for the vertebrates, and are thus
an early indicator to potentially dangerous food chain
build ups.

Insects. Several studies of how 2,4-D affects insects
have been made. Most relate to the acquatic or soil
life stages of the insect and not the adult stage.

No significant hazard to insects is expected as a
result of acute toxicity of this proposed herbicide
use at the Environmental Protection Agency regulated
application rates.

The following species of bottom-dwelling organisms
were reduced by 50 percent or more after an applicaton
of 2,4-D, ranging from 1 ppm: to 4 ppm: Mayfly
nymphs, horsefly nymphs, common midges, phantom
midges, biting midges, caddice fly, larvae, and water
beetles. Smith and Isom (1962), in another
investigation, concluded 2,4-D at low 1 ppb in water
concentrations had little effect upon bottom insects.

Honey bees have responded in different ways to exposure
to 2,4-D. One investigation showed honey bees to
decrease by 22 percent following treatment of a field

they were using with 3 pounds of 2,4-D per acre.
However, dug ting bees with 2,4-D did not cause any
mortality. It is not known if the toxicity

observed in the field was due to 2,4-D dissolved in
the nectar, or to the production of a toxic metabolite
secreted by the plant into the nectar.

Benefits to some insects, especially honey bees,
increase as plant succession is set back to conditions
favoring flowering forbs. Other investigations have
shown insect populations can increase following 2,4-D
treatments, due to the increase in organic matter
resulting from the decay of controlled plants.

Of mosquito larvae treated with 2,4-D at a rate of
100 ppm in water, about three-fifths fewer larvae as
in the control reached the pupal State. This

study added further evidence that 2,4-D is relatively
non-toxic to some invertebrate species

Crustaceans and Mulluscs. Detectable residues of
2,4-D do not appear in surface waters of the Nicolet
National Forest, unless the chemicals are directly
added to the water, or fall there incidental to
spraying forest vegetation, or unless the chemical is
added as a water treatment for the control of aquatic
vegetation. Detectable 2,4-D residues are not
expected to be found in the silt of forest waters
either. In investigations outside the forest area
where 2,4-D residues have been found in silt, it has
been attributed to wind blown erosion from bare soil
treated with 2,4-D. With the forest conditions and
precautions taken in the Nicolet National Forest, it
is not expected that crustaceans and mulluscs in or
near the National Forest will be exposed to any
residue from this herbicide project.

Should an accident during treatment happen or
metrological conditions occur that would cause a
2,4-D contamination of forest water, the
concentration in the water can be expected to fall
below detectable levels in a few days. Such residues
are diluted through stream flow, decomposed by sun-
light, or destroyed by microorganisms.

Crawfish, mussels, and a wide variety of other
crustaceans and mulluscs are not directly affected

by the 2,4-D herbicides at rates approved for direct
application to water for aquatic weed control.
Concentrations of 0-50 ppb found from actual forest
sampling in the Lake States, in the few samples where
residue has been detected, are much less than the
0.185 - 0.462 ppm concentration approved for direct
water application on some 2,4-D herbicide labels.

An adverse impact of a large accidental 2,4-D
contamination to a lake or pond would be the effect
plant vegetation decomposing would have on lowering
the water oxygen content, even if the herbicide level
itself was not high enough to cause crustacean and
mullusc mortality.

Social Economic Component. The fact that 2,4-D is
widely used on private rangelands and pasture,

private forests, in a variety of utility and highway
right of way uses, and on the home lawn is ample
evidence that it is efficient and inexpensive relative
to available alternatives. 2,4-D has not been found
to have serious unintentional side effects when used
in forest conditions following approved use directions.
Where the control of vegetation is needed, herbicides
usually have less harmful side effects on the
environment than alternative methods of control.

The favorable effects of 2,4-D use are production

and protection orientated. Improved economic welfare
and community stability are the results. Public and
private benefits are measured by increased timber
volume and value.

Forest trees, in the form of timber products, are a
renewable resource. They are also raw materials for
use in later manufacturing processes. As raw
materials, they are at the starting end of the
production process, and money paid for them tends

to stay in the local area more so than for communities
based on secondary or later stages of manufacture.

The numbers of people needed for primary resource
production, however, is not as great as the number of
people required in secondary manufacturing processes.

Our aerial herbicide applications are the least labor
intensive of the herbicide application methods used.
Ground methods of application, especially cut surface
and basal stem methods, employ more people. A
reduction in use of herbicides and a move to more
manual vegetation control would provide longer
employment or increased employment needs for laborers
and a favorable short term economic impact on the
local community. A long term adverse local employment
and economic effect would occur from a reduced usuable
future resource availability. Nationally, the effects
would be an increased cost to the taxpayer. Consumers
would feel little impact under the assumption of
constant total output. If a constant total output was
not maintained, however, a strong increase in consumer
price would occur with only a small decrease in output.

B=35

A long term economic benefit will result from growing
black spruce and red pine on these sites. By age 40,
if adequately released, these plantafions will produce
an estimated 36 to 43 cords per acre of high value
pulp and sawtimber, products worth about $3,600 to
$6,450 based on current prices. This assumes the
plantations are released to achieve 90 percent of
their potential, and that red pine and spruce are of
comparable value.

If unreleased, the areas will produce only about

13 to 25 cords per acre of mixed pine or spruce and
lower valued aspen, worth perhaps $1,040 to $3,750 per
acre during the same 40-year period.

Similar economic benefits were found in a Region-wide
reforestation - TSI evaluation. The evaluations
compared alternatives of growing one species of tree
versus growing another tree species on the same area.
Two cases, comparing growing red pine to a 100-year
rotation vs. growing aspen for 35-45 years, showed the
following when using stumpage rates current on the
Nicolet. A similar comparison was made involving
northern hardwood management.

Rate of
Site Index Return

Planting red pine vs. aspen management 60 5.68%
Planting red pine vs. aspen management 50 ula
Planting red pine vs. northern hardwood management 50 4.78%

Release vs.

Release vs.

Release vs.

When the rate of return and benefit/cost analysis
for releasing red pine on an acre of land was compared
to not releasing that acre, the following was found:

Rate of Benefit/Cost

Age Site Index Return at Th
no release 5 years 60 Qais 250 J
no release 10 years 70 9.55% v.99
no release 5 years 70 8.74% Pals

Release of existing stands is a very desirable
treatment from an economic standpoint.

An evaluation of a given timber management
investment is based on the cost and benefits to be
expected if a specific investment is made versus the
costs and benefits to be expected if the investment

B-36

ae

is not made. The evaluation is then made of the net
difference between the two timber management regimes,
one with the investment to be evaluated and one
without the investment. The rate of return shown is a
"real" or noninflated rate. A 4.8 percent internal
rate of return if inflated over a long tsxm at

5 percent compares to a 10 percent rate.

The economic and social effects of the production
and manufacture of forest products on the Nicolet
National Forest are of major importance to the
communities found in or near the National Forest.
To manage a part of the National Forest in high
fiber yield red pine and black spruce will benefit
the local economy and add to the social well being
of the people living here.

FAVORABLE ENVIRONMENTAL EFFECTS

A valuable wood resource will be established to supply wood-using
industries in and near the Nicolet National Forest. Up to about
a 300 percent increase in high quality wood production should
occur. This will aid the economic and social conditions of the
local communities. There will also be an increase in returns to
the Federal Government and counties from stumpage payment.

Management of conifer stands will continue the historical
vegetation composition of the northern Wisconsin area. The
variety of vegetation will generally benefit most wildlife species.
The variety will also provide an attractive and favorable contrast
to the predominantly hardwood-aspen forest now found over most

of the Nicolet.

The use of 2,4-D is effective and long lasting. When compared
to many of the other alternatives available to us, it is less
destructive and violent to the environment. The greatest saving
of the public's tax dollar will be realized.

A heterogeneous forest has been found to be more resistant to
insect and disease losses.

ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED

Minor soil contamination cannot be avoided. This contamination
shall probably last for 2 to 14 weeks. This impact will not
significantly affect soil biota.

As previously mentioned, there are aesthetic impacts which can
be minimized but not eliminated. These are temporary, occurring
primarily during the remainder of the summer of treatment, when
the "brown-out" effect of dead leaves is visible.

B-37

V1.

There will also be the habitat loss for certain wildlife species
mentioned earlier in this report. This is a necessary trade-off
in achievement of values associated with the composition
objectives policy.

The potential always exists for accidental dumping of the
herbicide due to a malfunctioning aircraft. The likelihood
of this occurrence is minimized by careful inspection and
certification of the aircraft.

There will be a slight and temporary odor from the herbicide.
A minor amount of air pollution will occur from vehicle exhaust.

Minor amounts of volatilized herbicide may enter the atmosphere.
Rates of dilution will be so great that effects on living
organisms are not expected.

If there is a good blueberry or raspberry crop this year, the
berries will most likely receive some 2,4-D residue. Treatment
areas will be posted to notify people of the herbicide application.

There will be an expenditure of approximately $6,000 of public
funds.

ALTERNATIVES

A. Biological

1. Controls. Biological control of vegetation is a process
featuring native animals, insects, diseases, and
environmental changes. Releasing more of a plant's natural
enemies against the host can increase the natural control.
The objective is to regulate the density of the pest
plants. An example would be controlled use of livestock
to reduce competing grasses and forbs in plantations.

Insect damage to plants may be in the form of defoliation,
girdling, or sap removal. Common life forms of the
attacking insects are larval and adult. The attacked
plants are weakened or killed.

Diseases are caused by living parasitic agents which live
and feed on or in plants. They are most commonly caused
by fungi, bacteria, viruses, and nematodes. Environmental
conditions have to be right before infection occurs.
Injury may be in the form of over developed tissues,
stunting, lack of chlorophyll, incomplete development of
organs, or death of tissue.

B-38

Biological control could also include non-living agents.
These agents include such things as nutrient adjustments,
extreme heat or cold, plant toxic chemicals other than
herbicides, and not enough or too much water. These
causes do not act like diseases in that the control is
not passed from one plant to another.

Biological control holds promise for the future, but still
needs research before becoming a reasonable alternative for
use in the Nicolet's vegetation management program. Many
problems with effective biological control still exist. A
major disadvantage being how to contain biological agents
within the 10 treatment areas. Spreading into adjacent
areas, insect and disease populations could rapidly expand,
attacking plants desirable for these sites. Another
problem is the biological agent may not be sufficiently
specific to the target plants and devastate other plants
desirable as wildlife food or even the planted pine or
spruce.

Evolution. In vegetative management, it is the resource
manager's need to only control the growth of selective
vegetation, not eliminate it. Reforestation is an example.
Growth advantage is wanted for the planted trees. This
advantage could be obtained through cultural improvement
rather than pest plant control. Biological evolution of
vegetation is a process futuring genetics, nursery
practices, soil preparation for planting, and succession.
The objective is to work through the host plants.
Individual plant characteristics for tolerance and early
fast growth can be identified and, through genetic
breeding, passed along to progeny. Host plants bred for
favorable growth characteristics could overcome the need
for control of associated vegetation.

A physiological shock is often exhibited by plants
transplanted from a controlled nursery environment to

an uncontrolled field situation. An adjustment in nursery
soil nutrients and introduction of mycorrhizal fungi may
reduce this shock and the resultant growth loss usually
suffered by transplants. Host transplants conditioned for
early fast growth could prevent better established plants
from squeezing them out.

Programs to reestablish vegetation usually require some
type of site preparation to prepare the area for planting
or seeding. Site preparation involves exposure of mineral
soil by removal or repositioning of accumulated vegetative
matter. ‘The more complete the site preparation, the less
chance of future need to control unwanted plants.

Vegetative communities are never static for very long.
Conditions are always developing for change, either
toward climatic stands, or away from them. Where a

vegetative community is at, at any time, determines the
complex association of plants to be found in it, and what
is to follow under given conditions. Based on sound
ecological knowledge of natural succession trends, host
plants could be matched to successional conditions rather
than competing against them.

Better use of the host vegetation, like control of pest
vegetation, holds promise for the future. Research and
studies are underway, but findings are slow, due to the
time involved in working with many forest plant species.

Fire

Fire, as a vegetative manipulator, has long been a part of the
forest environment in northern Wisconsin. Used as a controlled
and prescribed tool, fire is today a part of the vegetative
management program in timber management.

The use of prescribed fire is limited by season of year, daily
weather conditions, type of vegetation, terrain, local arr,
quality standards, and available manpower and equipment needs.
It can, however, be used for very specific treatments.

Some of the drawbacks to use of fire are:

1. High temperature in fires can not only consume the humus
layer above the soil, but also parch the soil, decreas ing
its porosity and increasing the chance of erosion and
excessive runoff.

2. Red pine and black spruce are not plant species with a
high fire tolerance. For this reason, the use of fire is
limited to non-selective uses. Fire cannot realistically
be proposed for thinning or control of competing
vegetation projects.

3. Hot fires often produce a vegetative change within the
burn area. Plants native to the area, but long
suppressed by successional change, are released to once
again dominate the site.

4. At times, fire is not hot enough to control plants with
well established root systems and prolific sprouting
occurs after the fire.

5, The number of days fire can effectively be used are very
limited. Some years they do not occur at all. And, when
they do, the danger of wildfire will most likely be high
reducing the fire fighters and equipment available for
prescribed burning

6. Burned areas are unsightly to some individuals.

7. If prescribed burning conditions occur during the nesting
or birthing season, fire will adversely affect many forms
of wildlife.

Fire, although used in the Nicolet National Forest, is specific
in its application for vegetative management.

Herbicides

Chemical control of vegetation involves the use of materials
that cause a malfunction in plant growth processes. Entry
into the plant may be through the foliage, stem, or roots.
Herbicides, as these chemicals are called, may be selective or
non-selective. The selective herbicides generally act on the
broad-leaved plants, whereas most grass, coniferous trees and
certain legumes are relatively resistant. The non-selective
herbicides generally control all vegetative types.

Herbicides are preferred as an alternative because they have
been found to be both effective and useful for vegetative
Management. Effectiveness is shown by a herbicide's ability
to control a specific target pest or produce a wanted plant
action. Usefulness is determined by the ability to apply
herbicides according to the directions and cautions of the
label without causing unreasonable adverse effects.

Today, herbicides are available for vegetative management
programs in timber, range, wildlife, agriculture, recreation,
and rights-of-way maintenance. The season of the year limits
some methods of application; however, other methods are
suitable in all seasons. The major advantages being lasting
effectiveness and low cost.

It is becoming increasingly apparent that the hazards of
non-herbicide use must include the effects of alternative
techniques that are more violent and often more destructive to
ecosystems. Selective herbicides, like 2,4-D, do not kill all
vegetation or physically disrupt soil. The effects on
wildlife are not physical, but related largely to habitat
change and the ratio of favored food species available. These
same habitat changes will occur with any method of conifer
release used. Plantation areas treated with herbicides remain
accessible to browsing animals. In contrast, areas strewn
with heavy slash are only partially accessible, and by the
time wildlife can move around, the browse has grown above
their reach. Because of the minimum physical impact on an
area treated with herbicides, many benefits occur that are not
possible with the other alternatives considered:

-site protection is not removed
-cover and food still remain for wildlife

-—nutrients are not removed or bunched

B-41

-microclimatic extremes are minimized

-new undesirable plants find it difficult to become
established due to competition from vegetation on site.

When considering the economics of using herbicides, the costs
generally run below the other alternatives available. Costs,
however, are not the overriding consideration in preferring
herbicide applications in selected areas. The environmental
effects, social impacts, and combined resource objectives are
reviewed.

If herbicides were not available, the cost of food, forest
products, electric power, and transportation would be higher.
Of the alternatives available, the use of herbicides has
proven to be the most effective and longest lasting.

The use of herbicides has been controversial, especially the
aerial application of 2,4,5-T. Much of the concern originated
from publicity given to a chemical called Agent Orange and
used in Viet Nam. Agent Orange contained an impurity;
tetrachlorodioxin, more commonly known as TCDD or dioxin. The
dioxin content now contained in 2,4,5-T has been reduced to a
fraction of one percent of its original content. Dioxin has
been found to be one of the most toxic chemicals known to

man. Until new monitoring programs, capable of dioxin
detection to 1 part per trillion, are analyzed, debates on the
use of herbicides will continue. 2,4-D has not been found to
contain any dioxins.

Eastern Region experience with herbicide use since 1950, has
shown this method of vegetative management to be effective, of
low cost, and when used in the forest at the registered dosage,
does not constitute a hazard to humans, animals, or the general
quality of the environment. Herbicide use still remains as a
preferred method for most vegetative management.

Several methods of herbicide treatment are approved by E.P.A.
registered labels for forestry application to release conifers.
A variety of herbicides are also available. They include 2,4-D
amines; 2,4-D + 2,4,5-T amines; 2,4-D + 2,4,5-T low volatile
esters; 2,4,5-T low volatile esters; 2,4,5-TD (Silvex);
cacodylic acid; dicamba; dicamba + mixes of 2,4-D or 2,4,5-T;
ammonium sulfamate; picloram or mixes of picloram + 2,4-D or
2,4,5-T; and 2,4-D low volatile esters. Some of these
herbicides are non-selective and must be applied as individual
stem treatments, others are limited in their registration to
the conifers they can be used with and the target pests they
will control, and still others are limited in the method for
which they can be applied. Some of these herbicides, e.g.
dicamba, picloram, and 2,4,5-T are more persistent in the
environment. An environmental assessment of the ecological
effects of each of these herbicides can be found on Pages 33 -
53 of the Final Environmental Statement, The Use of Herbicides
in the Eastern Region.

From over 20 years of herbicide experience, a knowledge of the
conditions existing on this 340 acres, and a review of the
E.P.A. registered labels available, we have considered the
following herbicides and methods of application available as
alternatives to consider.

1. Ground Application of Herbicides

a.

be

Mechanized Equipment. Broadcast Foliage Spray

Herbicide release could be done by a tractor mounted
power sprayer. A definite advantage would be better
control of spray drift. Also, less chance of
volatilization during droplet fall should exist.

Terrain, soils, and access limit the opportunity for
ground spray equipment. This alternative will not
provide as even a rate of application as a helicopter,
because of the difficulty of maneuvering equipment and
maintaining a steady applcation rate. Some mechanical
damage to the conifers being released will also occur
from being run over by the spray rig. To provide the
same degree of coverage to an acre of forest
plantation, gound spraying will introduce 4-5 times

as much herbicide as doing the work by an aerial
application.

Soil compaction would occur. Aesthetic impacts would
be the same as with an aerial herbicide application.

Costs are expected to vary from $35-$50, depending on
the variable involved. These 340 acres are considered
too rough to safely treat from the ground with
mechanical equipment.

Backpack Sprayers. Broadcast Foliage Spray

This alternative makes use of small back carried spray
equipment. The potential for off site contamination
would be minimized.

Where heavy brush and debris exists, this method would
be difficult to use. Walking is difficult, the job is
hot, body soaking from applied herbicide is a hazard,
and personal fatigue and the possibilitiy of accidents
are high. Aesthetic impacts would be comparable to an
aerial herbicide application. The rate of herbicide
application is difficult to control and the chance of
missing areas in need of treatment is high.

Costs are estimated to vary between $45-$70 per acre
for this alternative.

Backpack Sprayers. Basal Spray

Herbicides can be applied to the base of the target
species rather than applying it to the foliage. This
permits application during a longer period of time,
including the dormant period.

For this method of treatment, a more persistent
herbicide like 2,4,5-T, dicamba, silvex or picloram
works best. Basal sprays are also mixed with oil as a
carrier, rather than using water.

Aesthetics would be comparable to other herbicide
alternatives. Direct off site contamination would be
reduced. The volume of herbicide would be greater than
aerial application.

Costs including fuel oil, are estimated to vary between
$60-$80 per acre for this alternative. Treating each
individual stem when the target plants are less than

2 inches in diameter at the stump is difficult. Some
stems would be missed, and a great deal of extra time
would be needed to locate the pine or spruce and

insure they were completely released.

Cut Stump Treatment with 2,4-D + 2,4-DP Following
Hand Felling

The direct per treatment economic cost of this method
is the highest of alternatives available; estimated
at $70-$90 per acre. This price is based on the cost
of cutting the brush or trees competing with the
conifers, plus the cost of herbicide.

Herbicide use per acre in applying this method would be
two to three times greater than the amount required for
aerial treatment of the same area.

Applying herbicide to stumps after cutting would reduce
the concerns of off site drift and volatilization.

This alternative would adversely affect many forms of
wildlife, as the cut vegetation would create a barrier
to travel. The other impacts would be comparable to
those experienced with other herbicide use.

3. Aerial Spray

a.

2,4-D Low Volatile Ester (2 lbs. acid/acre) Applied
as a Mixture with Water at 8 gallons per acre

This alternative would result in the application of 1/3
less herbicide per acre than the selected alternative,
and about a $2 per acre reduction in cost.

B-44

The period available for application at this 2 pound
rate is shorter. Only the last 2 weeks in July and
maybe the first week in August can be considered for
making this treatment. Experience has shown that
target species are more susceptible to 2 pound
treatments during this short period; however, the
conifer needles may not be hardened off and damage to
the target species could occur. If there are delays
due to helicopter availability, a lengthy court
review, or adverse weather, the quality of the job
will suffer. A re-spray or following-up hand
treatment is more likely with this alternative.

2,4-D Low Volatile Ester (3 lbs. acid/acre) Applied
as a Mixture with Water at 8 gallons per acre

This is the alternative preferred and proposed for
completion.

For the conditions existing on these 340 acres, we
feel this is the best alternative available to us.
Each area to be treated was individually surveyed
with a series of 1/750 acre plots. The surveyor
recorded the presence or absence of a planted tree.
If a planted tree was present, the kind and amount
of competing vegetation was also recorded. Mapping
the location of the individual sample plots within the
proposed treatment area presented the analyst
informnation on the areas of heaviest and lightest
density of competing vegetation.

From the above information, the analyst compared
methods available and costs for different treatments.
Estimates of cost for this alternative are $18 per
acre. The period of effective treatment using 3 pounds
ofV2.4-Daranges fromJuly 15)— August 31.«° The) body of
this analysis is built around the selection of this
alternative.

Aerial Release with a 2,4-D Invert Emulsion (3lbs.
acid per acre). Applied as a Mixture with Water.

at 15 gallons spray mix per acre.

Invert emulsions of 2,4-D are effective and meet all
the standards to accomplish our release goals. This
alternative is as good or better than the proposal, in
reducing risk from drift.

The direct economic cost is estimated to be $28 per
acre, or about $10 more than the proposal. The amount
of helicopter fuel needed to apply the herbicide would
be about double. Different spray and mixing equipment
is required to handle this herbicide.

d. A 50/50 Mixture of 2,4-D and 2,4,5-T Low Volatile
Ester (3 lbs. acid/acre). Applied as a Mixture with
Water at 8 gallons per acre.

This alternative would do as good a job as the selected
alternative in controlling the target species. The
2,4,5-T in this mixture would also give us effective
contrtol of any maple, raspberries, and cherry species
present on site. These three species, even though
present, are not the major target Species to be
controlled. This alternative would also allow us to
take advantage of the full treatment season available
to us, including late August spraying should the
conifers be slow in "hardening off."

The herbicide 2,4,5-T is more persistent in soils and
water than is 2,4-D. The persistence is 3 to 6 months
under forest conditions. Other environmental impacts
with the use of 2,4,5-T are of more public concern
than the use of 2,4-D.

The direct economic cost of the 2,4,5-T + 2,4-D mixture
is more costly than 2,4-D alone. The total per acre
cost of this alternative is expected to be about $24.

(Manual )

Manual methods of vegetative management include the use of

hand operated tools such as the axe, brush whip, brush axe,
chain saws, and brush cutters. Generally speaking, manual
methods have little adverse effect on the environment. This
method can be selective and accomplished with little visual
impact in areas of concentrated public use. Control of areas
treated can be exact, making this method suitable for use along
streams, in recreation areas, and around buildings and wildlife
projects. The season of year has little effect, unless it is
snow depth in the winter. Long term local employment is
possible,

The major disadvantges are high cost and ineffective results.
It is not unusual for an acre of land to contain up to 20,000
hardwood stems. If stems were placed on a 2 foot by 2 foot
spacing, 10,890 stems could be fitted to an acre.

Many species of woody vegetation are prolific sprouters. In
young conifer plantations, the need exists for effective
vegetation control. The cutting of the aerial portions of
these plants does not reduce the number of stems that resprout
the following year and in some species, there are substantial
increases. The new height growth can exceed 3 to 4 feet in
the first year. To annually or bi-annually crop these sprouts
in a 300 - 400 acre program amounts to a major expenditure of
tax dollars.

GI
I
[~
CN

Manual labor projects can help a local economy, but it is
often the local economy that makes labor intensive work
impossible today. People are unavailable in many rural areas
and are not willing to commute to rural areas to participate
in hard physical labor under seasonal working conditions found
in the Forest. Large scale projects are limited by Federal
Manpower authorizations and the time available to physically
complete the work with small crews.

Experience has shown that heavy cutting of brush and cull
trees in an area creates a mat of interlocked tree branches
and stems impassable to many forms of wildlife.

The accident rate for people involved in woods work is high.
The 1972-1974 severity rate, (day of lost work due to injury
per 1 million man-hours of work), for the logging industry
group was only exceeded by 16 of 207 industrial groups listed
in the 1975 Work Industry Rates by the National Safety
Council. Daily exposure to sharp cutting edges, rough
terrain, climatic extremes, and physically demanding work make
accident occurrence a major factor in discouraging use of
physical labor crews.

Manual control methods, although a part of the regional
vegetative management program, are limited by cost and
effectiveness.

The direct economic cost of applying this method to areas
prescribed for aerial spraying are estimated at $50-$60 per
acre. Because this treatment is relatively ineffective, 5 to
10 consecutive yearly treatments may be required before these
stands are able to adequately compete with on-site hardwoods.
This would increase the total cost for treating these areas to
$275 - $550 per acre.

When the distribution of competing hardwoods is uneven, or the
number of stems per acre needing cutting is low, manual
removal has been selected as the method of treatment. The
buffer zones identified on the 10 aerial release areas will be
treated using hand tools without herbicides. Additional areas
identified as having a low number of stems per acre needing
treatment will be treated with hand tools without herbicides.
The total acreage to be accomplished during Calendar Year 1976
with hand tools without herbicides is 249 acres. The direct
cost of treating these acres is estimated to be $35-$45 per
acre. The lower cost is reflected in the fewer stems per acre
needing treatment on many of the acres.

(Mechanical)
This method involves the use of motorized equipment to either
push-pull or drive other pieces of equipment designed to treat

vegetation. It involves the practice of bull dozing, shearing,
discing, cultivating, chopping, or mowing.

B-47

Mechanical methods have the advantage of being able to alter
the position or form of the vegetation. Dozer operated
equipment can knock down or dig up vegetation to create
openings; brushhogs and hydro-axes can grind up vegetation;
and, discing or cultivating will bury vegetation. If done
properly, the mechanical control of vegetation is suitable for
use in visually sensitive areas. Large areas can be treated
with minimum man-power needs and cost. Mechanical equipment
also allows us to clean up accumulations of unwanted or
unutilized vegetation, while leaving adequate root material to
provide for vigorous responding.

Limits on the use of mechanical equipment are caused by rough
terrain, erosive soils, steep slopes, winter weather, and wet
soil conditions. Soil erosion and effects on water quality
are the main environmental concerns. It is not always
possible to be selective with mechanical methods, and the cost
of treating small areas is excessively high. Mechanical
methods will adversely effect wildlife requiring specific
localized ecological niches.

Unless plant roots are completely dug out of the ground, the
effectiveness of mechanical vegetation control is reduced.
Mowing operations, followed by chemical treatments, have
proven to be a combination of use where aesthetics are of
major concern.

Mechanical plantation release of the 340 acres in this
proposal was not seriously considered, because of the
scattered layout of the areas, the rough terrain, and the
difficulty of operating between the planted trees without
creating unavoidable damage to the trees to be released. The
direct cost for completing this proposal using mechanical
equipment is estimated at $40-$50 per acre, if it could be
done without destroying the red pine or black spruce.

No Cultural Treatment

No action should not be interpreted as a cessation of our
reforestation program. No action is only the absence of
treatment to established plantations. This alternative may be
more favorable from a long-term wildlife and short-term
economic standpoint. There would be no release costs. This
would result in an immediate savings of approximately $6,000.
No herbicide would be introduced into the environment. The
habitat for wildlife now living within or using each treatment
area would not immediately change due to this release. Of the
717 acres looked at for release needs during 1976, a total of
128 acres were identified as needing no treatment at this time.

An acre of forest land is limited in the amount of vegetation
it can produce. With management, the proportion of growth in
red pine and black spruce beneficial to man can be increased

by freeing these conifers to utilize available nutrients,

B-48

moisture, and space. This is the practice in timber
management, by selective control of vegetation. Without
selective control, growth will go into brush and trees of low
fiber yield. Until new technology and methods to utilize
brush and low fiber yield trees are developed, we either face
a reduced timber supply or have to harvest increased acreage
to supply existing demands.

Adoption of this alternative would forego the opportunity to
change 589 acres from very low to much higher timber
production. The result would be a long-term loss of timber
production. Also, original establishment costs would be lost
in proportion to growth and mortality losses.

The necessity for release is shown by experimental results on
the influence of qn overstory on growth of 10 to 25 years old
planted red pine. A 90 percent volume loss, 45 percent
diameter growth loss, and a 50 percent height growth loss
would be expected on plantations in urgent need of release.

In Lower Michigan, studies evaluated the effects of various
degrees of overtopping aspen and scrub oak to growth of
planted red pine. Growth was measured 5 to 15 years later.
The results were that when a 30 square foot basal area
hardwood overstory is retained, cubic foot volume growth is
reduced to 20 percent of the maximum; the diameter growth is
limited to 55 percent maximum; and, the height growth declines
to 58 percent of the maximum.

The benefits of release were shown in experiments on the
Chippewa National Forest in Minnesota. Prepared plots showed
that failure to release red pine resulted in a reduction at
the end of 5 years of 70 percent in survival; more than 90
percent in height growth; and, 99 percent in total dry weight.

These same adverse effects of no action can be expected on the
Nicolet National Forest.

RADIATION

Gamma radiation on biomass production has been under gudy in
northern Wisconsin (Zaultkovski and Salmonson, 1975).

Gamma radiation will directly affect ground vegetation by
selectively killing or severely damaging radio-sensitive plant
species, and indirectly by affecting tree canopies, thus
changing the micro-environment in which the ground vegetation
developes. Response to radiation treatments is slow; the
first signs of damage not occuring until after about 2 months
of irradiation.

Trees appear to be more radio-sensitive than ground
vegetation. Other results indicate vegetation zonation
results from the different radio-sensitivity of plants
composing irradiated communities, the more closed the over-
head canopy the greater sensitivity shown by the ground

B-49

Vit.

VELL,

IX.

vegetation. Plants known to survive under harsh conditions
are the least radio-sensitive.

The vegetation response to gamma radiation varies with the
time of year, radiation dose, length of exposure, distance
from the radiation received, and plant interphase chromosome
volume. In the Solidago, it was found 90 percent of these
plants treated with 105 roentgens, per 20 hour day, were
effected while for other plants the 90 percent yield was about
2,000 roentgens per day.

Vegetation management in northern Wisconsin using gamma
radiation is under study. Many more studies will need to be
conducted before we will recommend radiation treatments as an
alternative available for our use.

RELATIONSHIP BETWEEN SHORT-TERM USES OF MAN'S ENVIRONMENT AND
THE MAINTENANCE OF LONG-TERM PRODUCTIVITY.

Research indicates short-term environment impacts of 2,4-D as a
potentially hazardous substance to humans, wildlife, soil, and
water is very minor, when applied using the rates and methods
outlined in this report.

The areas we propose to use 2,4-D in will not achieve their
potential for timber production unless released. Brush and low
quality, poorly stocked stands of timber will develop, wasting
moisture and nutrients that otherwise could be available to
produce wood fiber and other timber products needed by the
American people in the future. Long-term productivity of timber
products will be greatly increased through growing these 340 acres
in more valuable species.

A reduction in quality of the biota is possible, if large areas
are converted to solid conifers. However, in growing conifers
these factors are considered, and adequate hardwoods left where
soils or a need to maintain diversity of habitat exists.

Conifers on the Nicolet are generally being grown where they grew
naturally, before their removal by man.

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

This proposal will use about 255 gallons of the herbicide 2,4-D.
Fuel to operate the helicopter and ground vehicles needed in
support of this project will be needed. The proposed program
will result in no other irreversible or irretrievable commitment
of resources when viewed from the long-term standpoint vital to
sound renewable natural resource management.

CONSULTATION WITH OTHERS

A. Environmental Impact Statement

In 1972 and 1973 draft and final environmental impact
statements were filed with the Council on Environmental
Quality. Public and other agency review was conducted

B-50

according to Forest Service guidelines, developed in
compliance with the National Environmental Policy Act. This
herbicide program statement covered herbicide use in the
Eastern Region of the Forest Service, which includes
Wisconsin. It developed policies and guidelines, with public
and other agency participation, which apply to all herbicide
projects in the Region. This environmental analysis is a
site-specific analysis which localizes the general regional
guidelines, and which includes additional specific guidelines
in response to conditions on each site.

A list of agencies, organizations, and individuals who
reviewed copies of the environmental statements is in the
Appendix as Item I.

Proposed Projects

The projects proposed herein for the summer of 1976, have been
reviewed by 26 Forest Service specialists. Reviews consisted
of field evaluations of individual herbicide use sites, as
well as office reviews. A list of those participating in this
phase of project development is included in this section.

In addition, the project proposal has been reviewed by the
Eastern Region Pesticide Use Coordinating Committee.
Membership of the Committee is also included in this section.
This review evaluated the project proposal for compliance with
guidelines developed in the environmental statement process
(described above), and for compliance with requirements of the
Federal Insecticide, Fungicide and Rodenticide Act.

Coordination with the State of Wisconsin has been accomplished
by personal contact and through written requests for project
reviews. Project descriptions and supporting data were sent
to the Secretary, Wisconsin Department of Natural Resources,
to District Directors, Northeast and North Central Districts,
Wisconsin Department of Natural Resources, to the State
Pesticide Review Board, and to the State Clearinghouse for
review of Federal proposals. Public involvement in projects
previously planned for 1975, revealed concern for use of
2,4,5-T, but little concern for the use of 2,4-D as proposed
herein. This is substantiated by a relative absence of public
concern for 2,4-D use during the past year by the Wisconsin
Department of Natural Resources on State Forest lands. This
has been true also, of projects implemented during the same
year by private parties, by counties in county forests under
WDNR guidance, and by other State agencies. Because these
projects of other agencies are similar to those proposed
herein, it has been determined that the use of 2,4-D is not an
item of major controversy.

B-51

APPENDIX C

Partial List of Federal and State Agencies, Associations, and
individuals that received copies of the Draft Environmental Statement
for Review and Response.

U. S. GOVERNMENT AGENCIES

U.S. Department of Agriculture

Mr. Talcott W. Edminster, Administrator
Agriculture Research Services, USDA
14th and Jefferson Drive, S.W.
Washington, D.C. 20250

Mr. Edwin L. Kirby, Administrator
Extension Service, USDA

14th and Jefferson Drive, S.W.
Washington, D.C. 20250

Mr. R.M. Davis

Soil Conservation Service, USDA
14th and Jefferson Drive, S.W.
Washington, D.C. 20250

Donald E. Wilkinson, Administrator
Consumer and Marketing Service, USDA
South Bldg.

14th and Independence Avenue, S.W.
Washington, D.C. 20250

Mr. David Hamil, Administrator

Rural Electrification Administration, USDA
South Building

14th and Independence Avenue, S.W.
Washington, D.C. 20250

U. S. Department of Health, Education and Welfare

Dr. David Mathews, Secretary

Department of Health, Education and Welfare
330 Independence Avenue, S.W.

Washington, D.C. 20201

U. S. Department of Interior

Director, Office of Environmental Project Review
Department of the Interior

Interior Building

Washington, D.C. 20204 (18 copies)

Illinois

U. S. Army Corps of Engineers

Chief of Engineers,

Office of the Chief of Engineers
Forrestal Building

Washington, D.C. 20314

Environmental Protection Agency

Edwin L. Johnson

Office of Pesticide Programs
Environmental Protection Agency
Waterside Mall

401 M. street, S.W.

Washington, D.C. 20460

John A. S. McGlennon, Administrator
Region 1, Environmental Protection Agency
Room 2303

John F. Kennedy Federal Building

Boston, Massachusetts 02203

Gerald M. Hansler, Administrator

Region 2, Environmental Protection Agency
Room 847

26 Federal Plaza

New York, New York 10007

Daniel J. Snyder IIL, Administrator
Region 3, Environmental Protection Agency
Curtis Building

6th and Walnut Streets

Philadelphia, Pennsylvania 19106

Ronald L. Mustard, Administrator

Director of the Office of Federal Activities
Region 5, Environmental Protection Agency
230 South Dearborn

Chicago, Illinois “60604

Jerome H. Svore, Administrator

Region 7, Environmental Protection Agency
1735 Baltimore Avenue

Kansas City, Missouri 64108

*STATE AGENCIES

Office of Planning and Analysis
Executive Office of the Governor
Room 614

605 State Office Bldg.
Springfield, Illinois 62706

Indiana

Maine

Michigan

Minnesota

Missouri

New Hampshire

Ohio

Pennsylvania

Vermont

West Virginia -

Wisconsin

State Clearinghouse

Office of the Governor

608 State Office Building
Indianapolis, Indiana 46204

State Planning Office
Executive Department

State of Maine

State House

Augusta, Maine 04333

Office of Planning Services
Executive Office of the Governor
Mason Bldg.

Lansing, Michigan 48926

Minnesota State Clearinghouse
300 Centennial Bldg.

658 Cedar Street

St. Paul, Minnesota 55155

Missouri Department of Community Affairs
P.O; bOxmL OU
Jefferson City, Missouri 65101

Office of Comprehensive Planning
Office of the Governor

State House Annex

Concord, New Hampshire 03301

Office of the Governor
State Clearinghouse

65 South Front Street
Columbus, Ohio 43215

Office of State Planning and Development
2301 North Cameron Street
Harrisburg, Pennsylvania 12720

State Clearinghouse
Office of the Governor
Montpelier, Vermont 05602

Grant Information Department
Office of Federal-State Relations
1800 Washington Street, East
Charleston, West Virginia 25305

J. R. Huntoon, Director

Bureau of Environmental Impacts
Department of Natural Resources
Box 450

Madison, Wisconsin 53701

*State - Federal Clearinghouse Coordinators (only States in R-9 with

National Forests)

Illinois

Indiana

Maine

Michigan

Minnesota

State Department of Resource Management

Anthony T. Dean, Director
Department of Conservation
605 State Office Bldg.
Springfield, Illinois 62706

State Forester
605 State Office Bldg.
Springfield, Illinois 62706

Joseph D. Cloud, Director
Department of Natural Resources
608 State Office Bldg.
Indianapolis, Indiana 46204

John F. Datena, State Forester
Department of Natural Resources
608 State Office Bldg.
Indianapolis, Indiana 46204

Commissioner

Department of Conservation
State Office Bldg.
Augusta, Maine 04330

Director

Bureau of Forestry
State Office Bldg.
Augusta, Maine 04330

Howard A. Tanner, Director
Department of Natural Resources
Mason Bldg.

Lansing, Michigan 48926

Henry H. Webster, Chief
Forestry Division

Department of Natural Resources
Mason Bldg.

Lansing, Michigan 48926

Michael O'Donnell, Acting Commissioner
Department of Natural Resources

300 Centennial Bldg.

658 Cedar Street

St. Paul, Minnesota 55155

Earl J. Adams, Director
Division of Lands and Forestry
Department of Natural Resources
300 Centennial Bldg.

658 Cedar Street

St. Paul, Minnesota 55155

cs

Missouri -

New Hampshire

Ohio

Pennsylvania

Vermont

Carl R. Noren, Director
Department of Conservation

P. O. Box 180

Jefferson City, Missouri 65101

Jerry Presley

Department of Conservation
Forestry Division

PU. box aLoU

Jefferson City, Missouri 65101

Edward J. Bennett

Division of Resource Development
State House Annex

P.O. Box 76 6

Concord, New Hampshire 03301

Robert W. Teater, Director
Department of Natural Resources
Fountain Square

Columbus, Ohio 43224

Charles E. Call, Chief
Division of Reclamation
Department of Natural Resources
Fountain Square

Columbus, Ohio 43224

Ernest Gebhart, State Forester
Division of Forestry

Department of Natural Resources
Fountain Square

Columbus, Ohio 43224

Honorable Maurice K. Goddard, Secretary
Department of Environmental Resources
Public Relations

Room 203

Evangelical Press Bldg.

P. O. Box 1467

Harrisburg, Pennsylvania 17120

Samuel S. Cobb, Director

Bureau of Forestry

Department of Environmental Resources
Room 203

Evangelical Press Bldg.

Pee 02. Boxsl467

Harrisburg, Pennsylvania 17120

Martin L. Johnson, Secretary

Agency of Environmental Conservation
Montpelier, Vermont 05602

Cap

West Virginia

Wisconsin

Arthur F. Heitmann, Commissioner
Department of Forests and Parks
Agency of Environmental Conservation
Montpelier, Vermont 05602

Ira S. Latimer, Jr., Director
Department of Natural Resources
1800 Washington Street, East
Charleston, West Virginia 25305

Lester McClung, State Forester
Department of Natural Resources
1800 Washington Street, East
Charleston, West Virginia 25305

Anthony Earl, Secretary
Department of Natural Resources
Box 450

Madison, Wisconsin 53701

S. W. Welsh, Administrator

Division of Forestry, Wildlife and Recreation
Department of Natural Resources

Box 450

Madison, Wisconsin 53701

Local Agencies and Commissions

Frederick 0. Rouse, Chairman
Great Lakes Basin Commission
2nd Floor, City Center Bldg.
220 E. Huron Street

Ann Arbor, Michigan 48108

Mr. William R. Bechtel, Cochairman
Upper Great Lakes Regional Commission
U. S. Department of Commerce, Room 2093
14th and E Street, N.W.

Washington, D.C. 20230

Associations

Air Pollution Control Association
440 5th Avenue
Pittsburgh, Pennsylvania 15213

American Camping Association, Inc.
Bradford Woods
Martinsville, Indiana 46151

American Conservation Association, Inc.
30 Rockefeller Plaza, Rm. 5425
New York, New York 10020

American Farm Bureau Federation
225 Touhy Avenue
Park Ridge, Illinois 60068

American Forage and Grassland Council
121 Dantzler Court
Lexington, Kentucky 40503

American Forest Institute
1619 Massachusetts Avenue, NW
Washington, D.C. 20036

American Mining Congress
1100 Ring Bldg.
Washington, D.C. 20036

American Motorcycle Association
Pe OceBox, 141
Westerville, Ohio 43081

American Pulpwood Association
1619 Massachusetts Avenue, NW
Washington, D.C. 20036

American Scenic and Historic Preservation Society
Federal Hall National Memorial

26 Wall Street

New York, New York 10005

Appalachian Mountain Club
5 Joy Street
Boston, Massachusetts 02108

Appalachian Trail Conference
Psd «. Box 236
Harpers Ferry, West Virginia 25425

Association of Interpretive Naturalists
International Business Office

6700 Needwood Road

Derwood, Maryland 20855

Boat Owners Council of America
534 N. Broadway
Milwaukee, Wisconsin 53202

Ducks Unlimited
P. O. Box 66300
Chicago, Illinois 60666

Environmental Defense Fund, Inc.
162 Old Town Road
East Setauket, New York 11733

Friends of the Earth
620 C Street, SE
Washington, D.C. 20003

General Federation of Women's Clubs
1734 N Street, NW
Washington, D.C. 20036

League of Women Voters
1730 M Street, NW
Washington, D.C. 20036

National Audubon Society
950 Third Avenue
New York, New York 10022

National Campers and Hikers Association, Inc.
7172 Transit Road
Buffalo, New York 14221

National Council of State Garden Clubs, Inc.
4401 Magnolia Avenue
St L0u is, eMissourisnool 10

National Forest Products Association
1619 Massachusetts Avenue
Washington, D.C. 20036

National Wildlife Federation
1412 16th Street, NW
Washington, D.C. 20036

Nature Conservancy

Suite 800

1800 North Kent Street
Arlington, Virginia 22209

North American Family Campers Association
Box 552

76 State Street

Newburypcrt, Massachusetts 01950

Outboard Boating Club of America
401 N. Michigan Avenue
Chicago, Illinois 60611

Sierra Club
530 Bush Street
San Francisco, California 94108

Sport Fishing Institute
Suite 801

608 13th Street, NW
Washington, D.C. 20005

The Conservation Foundation
1717 Massachusetts Avenue, NW
Washington, D.C. 20036

The Garden Club of America
598 Madison Avenue
New York, New York 10022

The Wilderness Society
1901 Pennsylvania Avenue, NW
Washington, D.C. 20006

Trout Unlimited
4260 E. Evans Avenue
Denver, Colorado 80222

Wildlife Management Institute
1000 Vermont Avenue, NW

709 Wire Bldg.

Washington, D.C. 20005

American Forestry Association
1319 18th Street, N.W.
Washington, D.C. 20036

American Water Resources Association
P.O. Box 434
Urbana, Illinois 61801

Appalachian Hardwood Manufacturers, Inc.
Room 408

NCNB Building

High Point, North Carolina 21261

Mr. Thomas P. Brogan, Executive Vice President
Northern Hardwood and Pine Mfgs. Association
Suite 207

Northern Bldg.

Green Bay, Wisconsin 54301

John D. Hoffman, Executive Director
Sierra Club Legal Defense Fund, Inc.
311 California Street, Suite 3ll
San Francisco, California 94104

Wilderness Watch Inc.
P.O. Box 3184
Green Bay, Wisconsin 54303

Wildlife Management Institute

1000 Vermont Avenue, NW
Washington, D.C. 20005

G9

Others - Individuals

Mr. George Banzhaf
622 North Water Street
Milwaukee, Wisconsin 53202

MeeeGse. Warren
Purdue University
Lafayette, Indiana 47907

Mason Carter
Purdue University
Lafayette, Indiana 47907

Robert Shipman

Pennsylvania State Univerisity

101 Ferguson Building

University Park, Pennsylvania 16802

Fred Tschirley

Botany Department

Michigan State University
East Lansing, Michigan 48823

Logan Norris

USFS - Pacific Northwest Experiment Station
Forestry Sciences Laboratory

3200 Jefferson Way

Corvallis, Oregon 97331

Companies

Mr. Robert Smith

TSI Company

Box 151, Highway 206
Flanders, New Jersey 07836

Thompson - Hayward Chemical Company
5200 Speaker Road .,
Kansas City, Kansas 66110

Mr. Morris L. Neuville, President
The Ansul Company

1 Stanton Street

Marinette, Wisconsin 54143

E. A. Snyder, President
Amchem Products, Inc.
Ambler, Pennsylvania 19002

C. B. Branch, President

The Dow Chemical Company
PReOveRpoxe1/06

Midland, Michigan 48640

C= Lp

Geigy Agricultural Chemicals
Divison of CIBA - Geigy Corp.
Ardsley, New York 10502

Robert S. Toth, General Manager
Pennwalt Corporation

Agchem Division

1630 E. Shaw Avenue, Suite 179
Fresno, California 93710

U. S. Borax and Chemical Corp.
3075 Wilshire Blvd.
Los Angeles, California 90010

Diamond Shamrock Chemical Company
Agricultural Chemical Division
1100 Superior Avenue

Cleveland, Ohio 44114

E. I. duPont de Nemours and Company, Inc.
Industrial and Biochemicals Department
1007 Market Street

Wilmington, Delaware 19898

Richard W. Fields, Manager
Velsicol Chemical Corporation
34] East Ohio Street

Chicago, Illinois 60611

List of Forestry Schools in R-9

Connecticut
School of Forestry and Environmental Studies
Yale University
New Haven, Connecticut 06511

Illinois
Department of Forestry
School of Agriculture
Southern Illinois University
Carbondale, Illinois 62901

Department of Forestry
University of Illinois
Urbana-Champaign

Urbana, Illinois 61901

Indiana
Department of Forestry and Conservation
School of Agriculture
Purdue University
Lafayette, Indiana 47907

Iowa
Department of Forestry
Iowa State Universty
Ames, Iowa 50010

Massachusetts
Department of Forestry and Wildlife Management
University of Massachusetts
Amherst, Massachusetts 01002

Maine
School of Forest Resources
University of Maine
Orono, Maine 04473

Michigan
School of Natural Resources
University of Michigan
Ann Arbor, Michigan 48104

Department of Forestry
Michigan State University
East Lansing, Michigan 48823

School of Forestry and Wood Products
Michigan Technological University
Houghton, Michigan 49931

Minnesota
College of Forestry
University of Minnesota
St. Paul, Minnesota 65201

Missouri
School of Forestry, Fisheries, and Wildlife
University of Missouri/Columbia
Columbia, Missouri 65201

New Hampshire
Institute of Natural and Environmental Resources
University of New Hampshire
Durham, New Hampshire 03824

New Jersey
Forest Section, Cook College
Rutgers, The State University
New Brunswick, New Jersey 08903

New York
School of Environmental and Resource Management
State of University of New York
College of Environmental Science and Forestry
Syracuse, New York 12310

G-12

Ohio
Division-Department of Forestry
School of Natural Resources
Ohio State University
Columbus, Ohio 43210

Pennsylvania
School of Forest Resources
The Pennsylvania State University
University Park, Pennsylvania 16802

Vermont
Department of Forestry
The University of Vermont
Burlington, Vermont 05401

West Virginia
Division of Forestry
West Virginia University
Morgantown, West Virginia 26506

Wisconsin
Department of Forestry
University of Wisconsin-Madison
Madison, Wisconsin 53706

College of Natural Resources
University of Wisconsin-Stevens Point
Stevens Point, Wisconsin 54481

Paper Companies

Boise - Cascade Corporation
International Falls, Minnesota 56649

Mr. Jack Cedergren
Vice-President, Lands and Timber
Potlatch Corporation

Northwest Paper Division
Cloquet, Wisconsin 55720

Champion International Papers
Hamilton, Ohio 45020

Consolidated Papers, Inc.
Wisconsin Rapids, Wisconsin 54494

Mr. J. S2¢Hensel

American Pulpwood Association
200 Franklin Street

Wausau, Wisconsin 54401

Mr. Lynn Sandberg, Woodlands Manager
Mead Corporation
Escanaba, Michigan 49829

Missouri Forest Products Association
Suite B-43, 400 East High Street
Jefferson City, Missouri 65101

Timber Producers Assoc. of Wisconsin and Michigan
201 West Wisconsin Avenue
Tomahawk, Wisconsin 54487

Timber Producers Association of Minnesota
Room 200

Christie Building

Duluth, Minnesota 55802

Mr. Richard Yankee, Supervisor
Field Operations

Packaging Corporation of America
Per. box 516

Manistee, Michigan 49660

Virginia Sportsmen's Club
Box 718
Virginia, Minnesota 55792

United Northern Sportsmen
130 East Orange Street
Duluth, Minnesota 55811

Clean Air, Clean Water
Boxga ll
St. Paul, Minnesota 55075

Minnesota Herbicide Coalition
110506 Windmill Court
Chaska, Minnesota 55318

Citizens for a Better Environment
Suite 2610

E. Van Buren Street,

Chicago, Illinois 60605

MP IRG
3036 University Ave, SE
Minneapolis, Minnesota 55414

Environmental Balance Association of Minnesota
1030 Minnesota Building
St. Paul, Minnesota 55101

Friends of the BWCA
1743 Lindig Street
St. Paul, Minnesota 55113

MECCA
P.O. Box 80089
St. Paul, Minnesota 55108

Cherie Mason, Field Representative
Defenders of Wildlife

900 N. Michigan Avenue

Chicago, Illinois 60611

Jim Bluhaugh, Outdoors Editor
Duluth Herald

424 West First Street

Duluth, Minnesota 55801

Weed Science Society of America
311 Illinois Building

113 N. Nail Street

Champaign, Illinois 61820

Robert A. Petry, Manager
Woodlands Operations

Nekoosa Papers, Incorporated
Port Edwards, Wisconsin 54469

Richard Rice

Coalition for Economic Alternatives
Box 323

Ashland, Wisconsin 54806

H. Paul Friesema
Northwestern University
2040 Sheridan Road
Evanston, Illinois 60201

Irwin J. Unger

Columbia Gas System Service Corporation
20 Montchanin Road

Wilmington, Delaware 19807

George B. Fell, Executive Secretary
Illinois Nature Preserves Commission
819 North Main Street

Rockford, Illinois 61103

Patrick R. Ott, Environmental Analyst
Columbus and Southern Ohio Electric Company
215 North Front Street

Columbus, Ohio 43215

Claire Bolduc, Researcher

Pine Tree Legal Assistance, Inc.
Coe Building, Room 53

61 Main Building

Bangor, Maine 04401

C-15

Richard Kluender

Southwest Division Forester
American Pulpwood Association
Post Office Drawer 4799
Fondren Station

Jackson, Mississippi 39216

Ms. Wilma Hammack

Engineering Services Library

Columbia Gas Transmission Corporation
PLU. bOxT i215

Charleston, West Virginia 25325

Mr. Ken Franklin
U.S. Power Association
Elk River, Minnesota 55330

J. M. Daley, Reporter

The Prospect-—News

Box 367

Doniphan, Missouri 63935

Dee Rau. y.

Senior Registration Scientist

3M Company, 3M Center - Building 230B
Agrichemicals Project

St. Paul, Minnesota 55101

Paul Johnston

Asplundh Environmental Services
Blair Mill Road

Willow Grove, Pennsylvania 19090

Ohio Environmental Protection Agency
Office of the Planning Coordinator
361 East Broad Street

Columbus, Ohio 43215

R. W. Sorensen, Chief Forester
Minnesota Power and Light Company
30 West Superior Street

Duluth, Minnesota 55802

Mrs. Jeannie Berg

Leech Lake Area

Chamber of Commerce

Box G

Walker, Minnesota 56484

(#1)

(#2)

United States Department of the Interior

OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240

In Reply Referee: NOV 2 8 1977
ER-77/924

Mr. Steve Yurich

Regional Forester

633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dean Me. Yurich:

Thank you for your letter of September 21, 1977, transmitting
for review and comment the Forest Service's draft environ-
mental statement for the proposed Use of Herbicides in the
Eastern Region. Accordingly, we have reviewed the statement
and offer the following comments for your consideration.

General Comments

We find the draft statement to be rather comprehensive but
makes some mistakes of omission as well as commission. Most
of the document is concerned with the phenoxy herbicides and
this is understandable. However, the proposal calls for the
use of other herbicides as well. And, the use and effects

of these other pesticides need to be addressed in a more
detailed manner. A reprint, and an inclusion as an addendum,
of toxicological data that has accompanied other Forest
Service statements on the use of herbicides would be in order.
Further, the large body of information concerning the effects
of herbicides, published by the U.S. Fish and Wildlife
Service, has been almost completely ignored.

Inasmuch as the environmental statement recognizes the contro-
versial nature of the herbicides 2,4,5,-T and 2,4,5,-TP con-
taining tetrachlorodibenzo-P-dioxin (TCDD) (p. 24, par. 5

and p. 41-51, item 2), the level of quality control used in
the manufacturing process to minimize the potential for

dioxin formation should be made known. Also, monitoring
measures for water quality of streams draining herbicide-
treated areas should be considered, especially where surface-
water resources are used for water supply.

The environmental analysis report for Nicolet National Forest
(app. B) carefully considers depth to ground water and soil
depth and characteristics in planning the application of

(#3)

(#4)

(#5)

herbicides (p. 110-117). However, we suggest that the
section on controls and mitigations for such applications

(p. 118) should include provisions for prompt remedial
measures in the event of accidental spills. The much higher
concentrations resulting from such spills are more likely
to reach ground water and to persist during lengthy ground-
water movement toward locations of possible significant
impact or release to a surface stream. We suggest also that
controls on herbicide use (app. A) such as those under Water
(item 4(1)) should include mention of types of environmental
Situations that will permit very rapid or almost instantaneous
movement of herbicides into ground water - as in areas where
the filtering effects of sufficient soil thicknesses will not
be available. Examples would include not only features of a
karst terrane such as caves and solution openings but also
areas where rock fractures, lava tubes, very coarse gravel,
or broken-rock fields are at or near the surface. Any such
areas of appreciable size that are characterized by extremely
large pore spaces should be isolated with buffer strips in
the same manner as streams (p. 97). Monitoring or sampling
of ground water or of surface water that can be affected by
herbicides transported in ground water should involve proper
allowances for delayed effects that may result from the
customarily lower velocities of ground water.

Vieni wine ntroductory »part. ofthe Description,the state-
ment identifies recreational areas of concentrated public
use (campgrounds, picnic sites, and swimming beaches) as
target areas for weed and vegetation control through the

use of herbicides. These areas, which are targets for
herbicide application, are the same areas where people will
be eating, sleeping, drinking the water, and playing. While
the draft addresses the environmental impacts of the pro-
posed action on an individual subject basis, it does not
address a synergistic effect on people who may be recreating
during or immediately after a herbicide application. While
wasn eracts One Inia Lily prebabiality.. wlll not cause
fatalities, the draft statement suggests that the application
of herbicides can cause physical stress to people, both
internal and external. This concern should be analyzed and
mitigating actions identified as appropriate.

Also, we are disappointed that the statement does not address
a policy regarding the use of herbicides in the vicinity of
Natural Areas and other special recognized State and Federal
areas. . Such areas include components of the State Wild and
Scenic River Systems, State Trail Systems, the National Wild
and Scenic Rivers System, and National Scenic Trails within

(#6)

(#7)

(#8)

(#9)
(#10)

(#11)

(#11)

(#11)

(#11)

(#11)

5

the several States of the proposal area. Further, we recom-
mend that all plant life within the designated boundaries of
these special areas should not be disturbed; i1-¢. ,» free or
species composition manipulation. And, while we assume that
future environmental statements regarding management practices
for each national forest in the region will present detailed
measures to protect these special areas, we recommend that

the overall policy for the Eastern Region should be set forth
in the final statement of this proposal.

Specrese Comments

Page i, par. 2: If used according to recommendations, regis-—
tration guarantees efficacy but does not guarantee "safety."
At best, there is a tacit promise of minimum hazard.

Page ii, V, par. 1: All “pesticides are, by their very nature,
toxic to something. Herbicides are toxic to plants and, in
sufficient quantity to fish, wildlife, and humans. To say
that something is nearly non-toxic has, therefore, little
meaning if the target organism(s) is not specified.

Page 10(4), par. 2: Aquatic herbicides may ameliorate or
help control a situation but they do not "cure."

Page 19(d): Accidental importation rather than importance.

Pages 24-25: If use of 2,4,5-T is so controversial, why then
continue to use it? Are there no reasonable alternatives?

Page’ 30,E.1: “Silvex# as) with 25455-1515 made rom 2,4,
trichlorophenol. Is there no dioxin present in the technical
material used?

Page 31, par. 5: Dicamba and picloram are not phenoxy
herbicides, as implied here.

Page 31, par. 6: Reference is made to table 4. Tables 1-4
are poorly arranged: table 3, page 373; table 1, page 38; :
table 2, page 42; another table 3, page 55; table 4, page 59.

Page 31-32: As used here, "low mammalian toxicity" refers
to oral lethal doses only. Oncogenicity at sublethal doses
can be a toxic effect as well and it should be noted that
arsenicals have been so implicated in epidemiological
studies.

Page 31-33: Monuron is suspected of being tumorigenic and
is being further tested.

C-19

(#11)

(#11)

(#12)

(#13)

(#14)

(#15)

(#16)

Pages 33-34, 8: TCA is quite corrosive and reacts readily
with protein. Decomposition produces chloroform and hydro-
chloric acid.

Page 34, 9: Pentachlorophenol is another phenoxy pesticide
containing toxic chlorinated dioxins.

Page 43, par. 3: This paragraph is poorly phrased and
creates misimpressions. TCDD is a tetrachlorodioxin arising
from the loss of one chlorine from each of two molecules of
the trichlorophenol used. Simple arithmetic shows that there
are four chlorine atoms left. By the same procedure, con-
densation of 2,4-D loses 2 atoms of chlorine in the forma-
tion of the respective dioxin, a dichlorodioxin; therefore,
One does not expect TCDD to be present. High temperatures
and high pressures are optimal conditions for dioxin forma-
tion. Under less than optimal conditions, the amount of
dioxin formed would be less but it is not an all or nothing
process as implied.

Page 54, 7: Water., first paragraph, tenth line - Glyphosate
is not presently registered for use in or around water.

Page 60, last par.: The comments about the incidence of
cancer in cities vs. rural areas are naive. Potential
sources of carcinogens in large cities are many and their
contribution cannot be easily separated. One could specu-
late just as easily that the rural incidence is mainly from
pesticides and might be even lower without them. Then, too,
"as much as 50-70 percent of aerial applied herbicides lost"
(page 38, A.1l.) into the air system may be adding to the
urban load.

Pageso0, par. os: Ihis 1s 4a blanket blind indictment of
herbicides and this document is not the proper forum for

such statements. If they are indeed as hazardous as this
statement would lead us to believe, then appropriate regula-
tory actions are in order. If other chemicals are terato-

genic, carcinogenic or mutagenic to animals, then approp-
riate regulatory actions are in order, but this situation
cannot be used to justify use of any hazardous agricultural
chemical.

Page 77, par. 2: Until a material balance is available and
an accounting made for the 50-70 % lost into the air, human
risk assessment is not complete. Although the per acre

volume of TCDD applied is small, the total volume of material

used annually is very large. This material is extremely
toxic - "the most toxic synthetic chemical known" - and
requires a better accounting.

We appreciate the opportunity to review and comment on thus
program and hope that these remarks will be of assistance
to you in preparing the final environmental statement.

Acting Cin
Pept ” Assistame

#1

#2

#3

4

#5

#6
#7
#8
#9

#10

#11

#12
#13
#14

#15

#16

Forest Service Response to Comments
by U. S. Department of the Interior

Toxicological data on other herbicides has been incorporated in
the Final Statement.

The section covering the contaminant TCDD was completely
rewritten.

The points mentioned concerning the sample EAR will be
considered in the evaluation of future project EAR's.

No research has been accomplished relating to the combined
effect of herbicide application and recreation activities.

We feel the current USFS policy on pesticide-use management in
conjunction with project EAR's provides the flexibility
required to make sound land management decisions for the areas
concerned.

Original statement unchanged. See US EPA comment #4.
Statement was clarified to show non-target organism to be man.
Wording changed.

Spelling corrected.

2,4,5-T is just one of several herbicides available for use and
herbicides are just one of several alternatives available to
accomplish the desired objective. 2,4,5-T is included because
even though it is controversial, it has not yet been proven to
be unsafe to humans when used properly. Individual project
EAR's will evaluate the target species, management objective,
available alternatives to accomplish the objective, and the
various impacts on the environment and the public. After this
evaluation, then a plan of attack will be developed using the
alternative selected.

This section was rewritten. See section II. D.4. fora
discussion of individual herbicide toxicity.

This entire section was rewritten.

Glyphosate reference was deleted.

This section was rewritten.

This is simply a statement of fact and this paragraph should
not be read alone, but should be considered with the rest of

the discussion under mammals.

The amount of herbicide lost into the air can be and is
minimized by the controls on herbicide use listed in appendix A.

C-22

ED ST%
ys 75

SZ

"AL pore?

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

Qnouinnys
V AGENC’

Re
(@)

%

OFFICE OF THE

9 8; a ly 1377 ADMINISTRATOR

Mr. Steve Yurich

Regional Forester, Eastern Region
U.S. Department of Agriculture
633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dear Mr. Yurich:

The Environmental Protection Agency has received and reviewed
the Forest Service's draft environmental impact statement
(DEIS) on "The Use of Herbicides in the Eastern Region."

Our major concerns are the lack of sufficient information in
the DEIS and the proposed use of some chemicals whose environ-
mental impacts are not adequately known. A more in-depth
explanation of these issues is found in our enclosed detailed
comments.

Review of pesticide applicability and use is based on the
appropriateness of the proposed project as it applies to
specific pesticide products. The products proposed for use
should be listed by their trade names, active ingredient
chemical names and EPA Registration numbers. This is
important since identical formulations of an active ingredient
(representing numerous products) may be registered for many
different use substitutions. This product information does
not appear in this general EIS, thus making detailed review
OPEoUe Gi.

Another major concern relates to usage of pesticides potentially
contaminated with dioxins. EPA is currently reviewing, under the
Rebuttable Presumption Against Registration (RPAR) process, the
chemical and biological properties of these pesticides to
determine their environmental impact. The results of this
investigative process will determine allowable uses. If

any changes from currently allowed uses result from this
evaluation, these changes would have to be incorporated into
a revised Forest Service herbicide program.

In addition to the two major concerns outlined above, we
would like to bring to your attention the CEQ Guidelines
for distribution of EIS's to EPA (Federal Register

August 1, 1973 p. 20559). The Guidelines require EIS's on
major program proposals or other major policy issues to be
sent to the Director of the Office of Federal Activities.
Following the CEQ procedures helps to assure a timely
response from EPA.

These comments classify your DEIS as ER-2 (Environmental
Reservations, Insufficient Information). The classification
and date of our comments will be published in the Federal
Register in accordance with our responsibility to inform

the public of our views on proposed Federal actions under
Section 309 of the Clean Air Act.

If I or my staff can be of further assistance, please
call.

Sincerely yours,
fi)

4

Peter L. Cook

Acting Director
Office of Federal Activities (A-104)

Enclosure: EPA's Detailed Comments on "The Use of
Herbicides in the Eastern Region"

(#1)

(#2)

(#3)

(#4)

(#5)

EPA's Detailed Comments on the Draft
Environmental Impact Statement "The Use of
Herbicides in the Eastern Region"

1. It was indicated in the DEIS that the document would be
reviewed and amended as new results are determined from
research on effects of herbicides. This continuing review
function should also include new biological-control discoveries
which may offer alternatives to use of herbicides.

2. The Section on "Description of Herbicides Proposed for
Use" (p. 30) includes an evaluation of each herbicide's
mammalian toxicity. A similar evaluation for avian and
aquatic species should be presented.

3. There is an overall understating of the potential hazard
to humans from some of the proposed herbicides, for example:

(p. 33) = “Paraquat as classified as highilvyetoxLe,
but no mention is made of the fact that there
is no known antidote for ingestion of the
chemical.

(p. 34) - Both Dalapon and TCA are referred to as having
"very low mammalian toxicity". This only
reflects their respective Oral LD59 values
and does not consider the appreciable eye
injury that’ could) resulc® from™ren contamination.

4. Although technically accurate, the statement on page 41,
"Tt is EPA that determines.... when used in accordance with
widespread and commonly recognized practices." is misleading.
We recommend that the following language be substituted for the
paragraph on page 41: "Proof of safety of a properly
registered pesticide is not the responsibility" orf ther user.
Under the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA) as amended in 1972, EPA has the responsibility to
determine whether an herbicide or any other pesticide, when
used consistent with its labeled directions will perform its
intended function without unreasonable adverse effects on

the environment, human beings, livestock, or wildlife."

5. The bottom of Table 4 and the Toxicity Rating column

on page 59 should be updated to include EPA standards as seen
in 40 CFR 162.10(h) "Warnings and Precautionary Statements".
Although Table 2, p. 42 gives the correct ratings, the old

(#6)

(#7)

(#8)

(#9)

USDA Agriculture Handbook, "Toxicity Rating System", does
not reflect the criteria which will be used by EPA in registra-
tion to determine in which toxicity category a pesticide belongs.

6. We do not see any indication of impacts which may result
from "use inconsistent with label directions" in your draft
statement; however, as you indicated in your summary, two
phenoxy herbicides you propose to use, namely 2,4,5-T and
2,4,5-TP, may be contaminated with 2,3,7,8-tetrachlorodibenzo-
dioxin (TCDD). Although many scientific studies have been
completed on 2,4,5-T and other phenoxy herbicides, as well
as on TCDD, questions remain unanswered about the possible
impacts of the use of these pesticides. Research will have
to be continued on all aspects of the toxicity, occurrence,
and environmental fate of these pesticides and possible

TCDD (dioxin) contamination until EPA determines that these
pesticides used in accordance with labeled directions will
not result in unreasonable adverse effects.

ijmeernewstateson NewsHampshiire (prohibits the use of 2,4,5-T

in watershed areas. In the past, New Hampshire has required
a permit be issued for all 2,4,5-T applications on rights-of-way
by commercial applicators. Is there likely to be any conflict

between U.S. Forest Service use proposals and existing State
laws or regulations?

Su IneAppendixeApeControls of Herbicides! Use.» (p. °96)', sit

is stated that product label directions must be followed for
that product's use. However, the controls listed in
Subsecurons oi, pain po2eoOms 73. Watery 8s Man;yvand 11.
Wildlife of this appendix may or may not be adequate depending
on the herbicide used. Due to the absence of a specific
product list in the general EIS, the adequacy of the listed
controls is not easily established. We believe the
introductory paragraph should include a statement to the
effect that the controls listed in Appendix A will be followed
unless the label of the product being used specifies controls
which exceed those in the Appendix. In this case, the product
label specifications, and not the listed controls, must be

the procedures followed.

9. In Appendix A-4 on page 98, the EIS should state if any
herbicide application will be made according to the procedures
in EPA's Pesticide Enforcement Policy Statement #7 (PEPS 7).
PEPS 7 covers EPA's stance on the aerial application of

(#19)

(#11)

registered pesticides. On page 36 it is stated that only
helicopters will be used for the aerial applications. We
feel that the Forest Service should be aware of EPA's
definition of the Terms, "aircraft," "airplane," and "aerial"
as they are used on pesticide product labels so that products
labeled appropriately can be obtained for helicopter use.

The terms are defined as follows:

Aircraft - any machine supported for flight by
air, including both airplane and helicopter.

Airplane - A powered, fixed-wing, heavier-than air
arrerart.

Aerial - pertaining to, or;used for, against, or
ineakr Cha ace

Accordingly, application by helicopter is consistent with
directions for use which include the terms aerial and aircraft.

10. On page 99, under Project Monitoring, the following
statement appears: "Results of herbicide efficacy and
monitoring will be made available to the public." Monitoring
activities are also mentioned on pages 55, 56 and 97. We
assume, based on these comments, that some project monitoring
program is planned. The subject EIS, however, does not describe
the mechanics of this aspect of the project. The Final EIS
should describe the monitoring programs being planned to

identify adverse effects and to determine project accomplishment
levels.

11. The FEIS should also describe in greater detail the effects
of the proposed program on adjacent private landholdings. This
analysis is particularly important for eastern forests which
are frequently interspersed with private inholdings.

C-27

#1

#2

#3
#4

#5

#6

#7
#8
#9

#10

#11

Forest Service Response to Comments
by Environmental Protection Agency

This subject was addressed by the DEIS on page 1 under
section I.A.

This section was rewritten. Herbicide toxicity is
discussed in section II. D.

See response #2.

Original paragraph deleted and recommended language
was substituted in section II. B. 2.

Table 3 was substituted to reflect the relative
toxicity of herbicides to people. Table 4 now
indicates the toxicity rating in easily understood
terms.

The impacts resulting from "use inconsistent with
label directions" are impossible to evaluate because
of the infinite number of ways various products can be
misused,

We wholeheartedly agree that scientific research
relative to all aspects of pesticide use should be
continued.

We do not anticipate any conflicts at this time.
Statement of clarification was added.

Paragraph (d) was added to call attention to EPA PEPS
#7.

The mechanics of the monitoring program can best be
discussed in the individual project EAR's because the
complexity of the monitoring will depend on the
complexity of the project.

Rather than discuss general impacts, it was felt the
individual EAR's could better cover any possible
impacts more specifically for the private landholdings
involved.

C-268

STATE OF ILLINOIS
EXECUTIVE OFFICE OF THE GOVERNOR

BUREAU OF THE BUDGET

SPRINGFIELD 62706

December 12, 1977

Mr. Steve Yurich, Regional Forester
U. S. Department of Agriculture
Eastern Region Forest Service

633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dear Mr. Yurich:

RE: Draft Environmental Impact Statement for Vegetation Management
Using Herbicides, DEIS #77-09-271

Pursuant to the National Environmental Policy Act (NEPA), OMB Circular
A-95 (revised) and the administrative policy of the State, the referenced
subject has been reviewed by the appropriate State agencies. No comments
were made on the referenced subject.

Thank you for your assistance.

Respectfully yours,
:

oa

T. E. Hornbacker, Director
Illinois State Clearinghouse

TEH :mec

C-29

STATE OF MAINE

DEFARTMENT OF CONSERVATION

AUGUSTA, MAINE 04337

AE eh De ee
November 21, 1977

MEMO TO: Steve Yurich, Regional Forester, Eastern Region, USFS

FROM: Richard Barringer, Commissioner Vie

SUBJECT: USFS Herbicides DEIS

While we do not expect National Forest lands in Maine to be significantly af-
fected by herbicide use, we appreciate the opportunity to camment on the DEIS.

Herbicides are a management tool of increasing importance in Maine forests.
Two major Maine paper conpanies are employing herbicides to release softwoods
fram hardwood campetition by aerial spraying on thousands of acres each year; other
owners are considering major herbicide programs. Our own Service Forestry program
conducts a few small herbicide release treatments each year; we also use small
amounts of herbicide for Ribes control work. In addition, there are ongoing private
and public right-of-way management programs. For these reasons, we find the up-to-
date review provided by this EIS to be especially useful.

We suggest that adding the answers to the following questions will improve
the usefulness of the statement:

(#1) 1. How many acres (of the 45,000 total) per year are treated for each of the
various management objectives listed in pp. 2-10? Are increases planned?

(#2) 2. What typical dosages and intervals of application (annually? once in a
rotation?) are associated with the different uses of herbicides?

(#3) 3. In what specific forest types and conditions will herbicides be used for
timber management? These details should be listed in the EIS if the potential use
of herbicides in a particular area is to be determined.

(A further problem is that the material on timber costs and benefits of herbicide
treatment is scattered throughout the statement and not well interpreted. For
example, the ad hoc citations on p. 65 do not help the reader assess the costs and
benefits of spraying in a realistic situation, since costs are omitted and atypical
cases (four years of canplete control) are cited. In contrast, the cases on pp. UG Wats
are more useful, although their service should be cited.)

4. National Forest proposed uses of herbicides are undoubtedly a small pro-
portion of the totals being used in wildland areas yearly; can an estimate of this
percentage be obtained?

The statement at a number of points asserts that herbicide use, by making more
timber available, will improve local economies and comunity stability. We do not
see this as a likely outcame in Northern New England, because the incremental timber
output will be small. Further, the prinicipal problems of local cammunities are lack
of markets, poor utilization, and lack of management on private lands. We doubt that

C-30
, | PAEN

Steve Yurich
November 21, 1977
Page Two

more timber production will solve any of these problems.

Thank you again for the opportunity to camment. We would like to receive
Six copies of the Final EIS.

#1

#2

#3

Forest Service Response to Comments
by State of Maine - Department of Conservation

See Table 1 for breakdown of acres by management
objective.

Dosages and intervals will be dependent upon the
chemical being used, the area being treated, and the
target species. These and other items will be fully
evaluated in the project EAR.

Individual EAR's will determine the use of specific
herbicides within the Forest types and conditions of
the Eastern Region. Herbicides will simply be one
method available to accomplish the silvicultural

ob jective. The EAR process will determine the method
to be used.

C52

STATE OF MICHIGAN

NATURAL RESOURCES COMMISSION

CARL T. JOHNSON

E. M. LAITALA WILLIAM G. MILLIKEN, Governor
DEAN PRIDGEON

HILARY F. SNELL DEPARTMENT OF NATURAL RESOURCES

HARRY H. WHITELEY STEVENS T. MASON BUILDING, BOX 30028, LANSING, MICHIGAN 48909

JOAN L. WOLFE HOWARD A. TANNER, Director
CHARLES G. YOUNGLOVE

December 8, CHE

Mr. Steve Yurich

Regional Forester

633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dear Mr. Yurich:

The Department has reviewed the federal draft environmental impact statement
on the Use of Herbicides in the Eastern Region prepared by the Department
of Agriculture, Forest Service.

In general, the Forest Service in our opinion has provided an incomplete
assessment in complying with the requirements of Section 102(C) of the
National Environmental Policy Act of 1969 (83 Statutes 852, 42 U.S. Code
Annotated sections 4321-4347). One of the recurring questions concerning
the adequacy of environmental impact statements addressed by the courts
and various reviewing agencies has been the meaning of the directive in
NEPA for federal agencies to comply with the spirit of the act ''... to
the fullest extent possible". Study of the legislative history of the
act has generally shown that this directive is to be interpreted as a
strong mandate to do a detailed assessment of environmental impacts and
to produce a document which will allow for objective decision-making.

In this regard, the draft EIS as prepared falls short of fulfilling the
requirements of the ''spirit'' of NEPA. This document is a persuasive
argument for the use of herbicides in vegetation management in the
eastern region. It is not an objective assessment of herbicide usage
and alternative methods of vegetation control as tools in a forest
management project. It specifically downplays the long-term environ-
mental consequences of herbicide use.

Detailed comments are attached for your consideration. We hope these
comments will aid in strengthening the final document as a rational
decision-making tool when deciding upon the various vegetation management
strategies to use in national forests. We appreciate the Opportunity to

provide comments.
Sincerely, Se

MICHIGAIN. Howard A. Tai >
rw ttachment Director

STATE C a 3 3

R1026 10/76

(#1)

(#2)

(#3)

DEPARTMENT OF NATURAL RESOURCES
Comments on
DRAFT FEDERAL EIS ON

HERBICIDES IN THE EASTERN REGION

In general, the Forest Service has complied with the specific five-point
requirement set forth in the National Environmental Policy Act of 1969.
The outline of the report is structured such that the major chapter
headings correspond to the five specific mandates outlined in Section
102(C) i-v of NEPA. The Forest Service has developed their environ-
mental impact statement within this format and has done a commendable
job of expanding upon the basic outline to include other facts germane
to the issue.

Certain inconsistencies in the report and the general bias toward
herbicide use as the best tool for vegetation management are cause
for criticism, however. The main statement in the introduction of the
document stresses that when alternative methods of vegetation manage-
ment are technologically available and economically feasible, that
they will be preferred over the use of herbicides. If this is indeed
thesprevai Hing opinionsor thesForest Service, it as strange. that ‘the
rest of the document is so overtly biased toward herbicide use for
vegetation management. Alternative methods of vegetation control
have their disadvantages emphasized while their advantages over
herbicide use receive minimal comment. The net result is that the
draft EIS is largely a promotional document supporting herbicide use
and is not the objective review of alternatives which the "spirit"

of NEPA seems to require.

Specific points which should be revised in the final statement are as
follows.

Page 9 In mentioning that herbicides will be used to optimize Kirtland
Warbler habitat in Jack Pine stands, no consideration is given to the
residual effects of the herbicides on the warblers or their food items.

Page 12 We disagree with the statement that "erosion and stream sedi-
mentation hazards are insignificant except in small areas'' of the
Vakesstates region.

Page 13. We assume that the reference to "bald express" in the text
is meant to be bald cypress (Taxodium dysticum). No scientific name
WeemLisced.in the text.

Pages 22-27 The initial alternatives on earlier pages listed specific
advantages and disadvantages of a particular method which allowed easy
comparison. I would suggest that the other alternatives follow this
format.

(#4)

598

Pages 30-82 The Forest Service has done a good job of reviewing the
herbicides to be used and the methods of application. Certain public
health and environmental hazard assessments of the chlorophenoxy
herbicides and their contaminants deserve a more detailed assessment.
Recent litigation regarding the use of phenoxy herbicides on the Siuslaw
National Forest has required that the Forest Service perform a thorough
analysis of specific environmental consequences (428 Federal Supplement
908, 1977). In particular, the deficiency in the EIS with respect to
the potential effects on human and animal health of 2,5,/,9-tetrachloro-—
dibenzo-p-dioxin (TCDD) was mentioned. The case decision written by
District Judge Skopil reiterates the points made by the Administrator
of the EPA in his order issued November 4, 1971. We believe that those
facts concerning 2,4,5-T and TCDD should be included in the final EIS.
They are listed below:

a. A contaminant of 2,4,5-T--tetrachlorodibenzoparadioxin (TCDD, or
dioxin)--is one of the most teratogenci chemicals known. The
registrants have not established that 1 part per million of this
contaminant--or even 0.1 ppm--in 2,4,5-T does not pose a danger
to the public health and safety.

b. There is a substantial possibility that even 'pure' 2,4,5-T is
itself a hazard to man and the environment.

c. The dose-response curves for 2,4,5-T and dioxin have not been
determined, and the possibility of 'no effect' levels for these
chemicals is only a matter of conjecture at this time.

d. As with another well-known teratogen, thalidomide, the possibility
exists that dioxin may be many times more potent in humans than in
test animals (thalidomide was 60 times more dangerous to humans
than to mice, and 700 times more dangerous than to hamsters; the
usual margin of safety for humans is set at one-tenth the tera-
togenic level in test animals).

e. The registrants have not established that dioxin and 2,4,5-T do not
accumulate in body tissues. If one or both (or some breakdown
product) does accumulate, even small doses could build up to dan-
gerous levels within man and animals, and possil)ly in the food
chain as well.

f. The question of whether there are other sources of dioxin in the
environment has not been fully explored. Such other sources,
when added to the amount of dioxin from 2,4,5-T, could result in
a substantial total body burden for certain segments of the human
population.

g. The registrants have not established that there is no danger from
dioxins other than TCDD, such as the hexa- and hepta-dioxin isomers,
which also can be present in 2,4,5-T, and which are known to be
teratogenic.

(#4)

ee

h. There is evidence that the polychlorophenols in 2,4,5-T may
decompose into dioxin when exposed to high temperatures, such as
might occur with incineration or even in the cooking of food.

1. Studies of medical records in Vietnam hospitals and clinics below
the district capital level suggest a correlation between the
spraying of 2,4,5-T defoliant and the incidence of birth defects.

j. The registrants have not established the need for 2,4,5-T in light
of the above-mentioned risks. Benefits from 2,4,5-T should be
determined at a public hearing, but tentative studies by this
agency have shown little necessity for those uses of 2,4,5-T
which are now at issue.'' Dow Chemical Company v. Ruckelshaus,

Ate co tiie sl s204 toe. G n.t4 (th Cir. 19735):

Pages 30-34 The aquatic toxicity data for herbicides is largely
ignored. No mention is made of specific directives to avoid
spraying herbicides over wetlands or surface waters.

Page 31 The cumulative effects of the buildup of arsenicals in
forest soil are not addressed.

Page 80 I would suggest that mention be made of the fact that

the immediate effect of reduced vegetation cover could be increased
soil erosion given the right combination of topography, soil type,
and rainfall.

4. The Department prefers emphasizing prescribed fire over herbicides
wherever possible, but we do find that for small-scale selective
treatments, in inaccessible locations and in rocky terrains, pelletized
Tordon herbicide is the best option.

5. Department staff through experience gained from many years of herbicide
application has come to the conclusion that broad-scale aerial appli-
cation does not accomplish the goal of woody species control. Tree
kill is spotty, sprouting of many species is tremendously stimulated,
and many desirable broad-leaf herbs are killed over large areas. For
large opening developments such as sharptailed grouse management areas,
we much prefer a combination of mechanical control and prescribed fire.
We continue to use Tordon for small opening creation and maintenance.

6. We find no argument with the EIS description of herbicide impact on
wildlife. Toxicity is very low for both mammals and birds, and the
disruption of herbicide application has merely a temporary effect,
but additional data on 2,4,5-T, as indicated earlier, is necessary in
final draft.

In general, the Forest Service has done a commendable job of complying with
the requirements of the National Environmental Policy Act in the preparation
of this impact statement. With these specific additions, the document should
Beetersserve: the spirit of NEPA of 1969.

Forest Service Response to Comments
by State of Michigan-Department of Natural Resources

#1 The method of vegetative management to be used on a
particular site will be more thoroughly evaluated
through the use of site specific EAR's.

#2 This consideration will be evaluated during the
preparation of the EAR for the site or project.

#3 Change was made.
#4 The sections discussing the description of herbicides

and herbicide toxicity have both been extensively
rewritten.

C=37

6000-7

STATE OF

ININJESOTA\ |
DEPARTMENT OF NATURAL RESOURCES

CENTENNIAL OFFICE BUILDING + ST. PAUL, MINNESOTA «+ 55155

DNR INFORMATION
(612) 296-6157

November 18, 1977
Mr. Steve Yurich, Regional Forester
633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203
Dear Steve:
We have reviewed the Draft Environmental Statement, "The Use of
Herbicides in the Eastern Region", and find the document to be
complete and objective in its treatment of the subject.
As the improper use of herbicides may have serious consequences in
any environment, it is imperative that they be expertly and completely
evaluated prior to determining if their use is warranted.
The revision of the Draft Environmental Statement is a necessary
on-going project as new research data and methods and techniques of
vegetative management become available.

Specific comments on the document are as follows:

Page 8 = The second sentence of the paragraph entitled, "Tree
Nurseries", appears to have a word or words left out.

Page 96 = Controls on Herbicide Use — The controls listed
included mph wind speed as the maximum allowed
to avoid drift. In the past we have used a
maximum allowable wind speed of 6 mph before
suspending aerial herbicide applications.

Page 60 — The first paragraph contains the apparent typographical
error of the word, “vound".

Thank you for the opportunity to review this document.
Sincerely,
x HO
James Le Brooks, Acting Director
JLB: RBH: REH:bs

cc: Bill Berndt

€-38

AN EQUAL OPPORTUNITY EMPLOYER

TO:

FROM:

REe

THE OHIO DEPARTMENT OF

MM. NATURAL RESOURCES

Steve Yurich,. Regional Forester
U.S. Department of Agriculture DATE: October 13591277

Charlese rh. Ca ieee vac cd Cf

Division of Reclamation

Comments on ''The Use of Herbicides in the
Rastern Kegion® .

Recommend use of biological agents as a means of
vegetation management:

1) Forest land accounts for a Slarge amount wf
acreage which would require a large amount
of herbicides being spread. over a wide area.

2) There appears to be some doubt as to what
the total affects of herbicides might be.

3) Use of biological species as a means of
natural competition is a more natural way
of altering an ecosystem.

CEC {DUP visa

DEPARTMENT OF ENVIRONMENTAL RESOURCES In reply refer to
P. O. BOX 1467 RM-F FM-O

HARRISBURG, PENNSYLVANIA 17120

November 3, 1977

Mr. Steve Yurich, Regional Forester
USDA, Forest Service

633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dear Mr. Yurich:

I have had various members of the staff of the Bureau of Forestry review
the Draft Environmental Statement for vegetation management using herbicides
that you sent to the Bureau for review and comment. I am pleased to report
that this careful review showed no errors, emissions or inconsistencies in the
Statement.

I would like to commend you and your staff for a careful and comprehen-
sive review of all aspects of the use of herbicides in forestry in the Eastern
Region. The information provided in this Draft Environmental Statement will be
most helpful to the Bureau of Forestry. Herbicides, properly used, are a most
valuable tool. They must be available to the forest land manager if he is to
do his job properly and efficiently. The Draft Environmental Statement should
do much to insure the continued availability of herbicides for use in forest
land management.

Sincerely yours,

*

ie Oe Thorpe, Diregeor
Bureau of Forestry

C-40

vi
LLL

STATE OF WEST VIRGINIA
DEPARTMENT OF NATURAL RESOURCES
CHARLESTON 25305

DAVID C. CALLAGHAN

Director

November 14, 1977

Mr. Steve Yurich, Regional Forester
U. S. Forest Service, Eastern Region
633 West Wisconsin Avenue

Milwaukee, Wisconsin 53208

Dears Massey uriechs
RE: Herbicide DES

The West Virginia Department of Natural Resources
has reviewed your Draft Environmental Statement entitled
"The Use of Herbicides in the Eastern Region" and finds
the document to be complete and technically accurate.
The Department's comments, dated October 13, 1972, on
the earlier draft appear to have been adequately con-
sidered and incorporated into this revision.

Page 100 of Appendix A includes "empty container
disposal" as a safety precaution. To our knowledge, no

formal disposal procedure has been developed in West
ViIrein pay.

The opportunity to provide further input is ap-
preciated. Please advise if additional information
would be beneficial.

ae

AA Co Callde

YL
e
I
Director

DCC/ db;

C-41

DAVID C. CALLAGHAN October 6, 1977

Director

STATE OF WEST VIRGINIA
DEPARTMENT OF NATURAL RESOURCES
CHARLESTON 25305

Mr. Steve Yurich, Regional Forester
633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dear Mr. Yurich: Re: 8420 (8540)

Reference is made to your letter of September 21 concerning
Public Law 91-190 with summary of the Environmental Impact State-
ment attached.

For your information, the Department of Natural Resources
has assigned all EIS reviews and comments to the Environmental
Review Team of which Mr. H. G. Woodrum is Chairman. I am for-
warding your letter to him for action.

I am sure a copy of his comments will be forwarded to you.

.Sincerely yours,

wt : = 3s ie
wo GA of Pex Suef : xe

Asher WZ Kelly, Jr.
State Forester

AWK : bmw

cco: H. G. Woodrum

{ fol
MISS

C-42

State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES

Anthony S. Earl
Secretary

BOX 7921
November 18, 1977 MADISON, WISCONSIN 53707

IN REPLY REFER TO: 1600

Mr. Steve Yurich, Regional Forester
U. S. Forest Service, Eastern Region
633 West Wisconsin Avenue

Milwaukee, Wisconsin 53203

Dears Mane wu imehis

Re: 8540 - Draft Environmental Statement,
The Use of Herbicides in the Eastern
Region, USDA-FS-R9-—DES-—ADM-7 7-10

The Department of Natural Resources has completed an interdisciplinary
review of the Draft Environmental Statement for the proposed use of
herbicides in the eastern region and submits the following comments and
concerns for your consideration.

The Department has no major objections to the draft statement. However,
final judgement on the proposal's environmental effects in Wisconsin
will be withheld since this generic statement must be followed by the
site specific Environmental Analysis Report as mandated by the Consent
Decree of January, 1977. The Department may, at that time, furnish
specific comments on the various sites to be treated with herbicides and
the kinds of herbicides used.

The uses of the herbicide 2,4-D for vegetation control and/or alteration
of vegetative stands are accepted practices which result in the least
physical disruption of the treated sites. The foregoing statement would
not apply should herbicides be used such as 2,4-5-T, which contain the
TCCD dioxin contaminant.

We take this opportunity to make the following specific comments on the
draft statement:

1. While the statement reads "only 0.4% of the total forest is to be
treated," this does not give the whole picture. Some data should

(#1) be presented on the cumulative totals of treated areas (over a 10-
or 20-year period), especially for red pine plantation release.

C~43

THIS IS 100% RECYCLED PAPER

Mr. Steve Yurich - November 18, 1977 iM

There is some apprehension among DNR wildlife biologists on the
adverse impacts of red pine plantation release on such wildlife as
deer and ruffed grouse.

(#2) ae On page ii, the last paragraph appears to be biased. The remarks
on page 24 and the top of page 25 appear to be more accurate.
(#3) Bie On page V, under "Wisconsin," change C. D. Besadny to J. R. Huntoon.
i On page 8, bottom of page, the term "opening" should be described
in the glossary.
De On page 17, under Control, "biological" would be a better term than
“natural” vegetation control.
Gs On page 20, we feel the term "genetic" control is more appropriate
than "evolution."
(#3) ie On page 75, the first sentence should read "Herbicides are effective

and the results are long lasting. (As it reads, it says that the
herbicides are long lasting.)

(#3) 8. On page 82, the third line should read "insect feed."

In summary, we have no substantive reasons for objecting to the generic
Environmental Statement. We would appreciate receiving eight copies of
the Final Environmental Impact Statement and look forward to reviewing
the site specific Environmental Analysis Report when it is completed.

In the future, I would appreciate your sending me all copies of Environ-
mental Impact Statements and Environmental Assessment Reports since this
Bureau is responsible for coordinating the review of these documents.

Thank you for the opportunity to review and comment on this document.

Sincerely,
Bureau of Environmental Impact

4

fine A eee Co Ore
Se < . s +9

_ James R. Huntoon
Director

C-44

Forest Service Response to Comments
by State of Wisconsin/Department of Natural Resources

#1 See Table 1 for the proposed average annual use
during the life of this statement.

#2 Last paragraph on page ii was revised.

#3 Suggested changes were made.

c-45

Box 323
Ashland, Wisconsin 54806

COALITION FOR ECONOMIC ALTERNATIVES

November 29, 1977

Steve Yurich
kegional Forester

Eastern kKegion

633 West Wisconsin Avenue
Milwaukee, Wisconsin 5%4203

Dear Mr. Yurich:

The Coalition for Kconomic Alternatives, a private community
development corporation, has reviewed your vrat't tnvironmental
impact Statement entitled "Use of Herbicides in tne tiistern hegiun".
Attached please tind vur comments and suggestions as inciuded in
three statements, one, a paper titled "Hooked on Drugs: A biosocial
Analysis Of the Use uf Pesticides", two, a summary oi the scien-

tific literature demonstrating the toxicity of the herbicides
2,4-D and Dae Got A arid three, "Specitic Comments on USUA Forest

Service Environmental Jtatement".

Sincerely, [engiXs ff

Kent Shifferd, Ph.D.
Co—Divecto

Jo
Co-—Diyector
C-46

HOOKED ON DRUGS: A BIOSOCIAL ANALYSIS OF PESTICIDE USE

Kent. D. Shitferd,. env.

America is hooked on drugs. Both American agriculture
and silviculture are dependent on. large amounts of herbicides
and insecticides’ Our farmers and our foresters argue that
these are essential management tools. And why not? These

chemical pesticides are in use all over the world. ine

average citizen Can boy? 3G hardware and drue Bvores.

They are used on Lown: “and home pardens. Moreover, they

have been around Yor a Long time with no arpareat human heaionh
problems. The present Tamily of biovidces were developed cur=
ing World War Two and and have been in commercial use For tween
years. They are used by trained prefessicna) mm Loresi

and agriculture and all the formulations currently in use
have been registered by the Environmental Protection Agency.
They were developed by scientists working in public, univerei—
ties, colleges and in corporate laboratories and they are
sold oi. the open market in accord with our free enterprise
system. The men and women who developed them had the public
good in mind. They wanted to end hunger and resource s10rbt-
ages around the world. I. seems that these herbicides are
the tools of the good guys. And, finally, all who use these
tools point out convincingly that they have become an integral
part of our economy and, if suddenly pulled out, would cause
great dislocations. Farmer's would go broke. Food woula cost
more. The Cost Of "producing Uinber would go up.

In the face of such seemingly reasonable arguments, how
can anyone be opposed to the controlled use of a particular
herbicide? How can they be opposed to herbicides and insect—
icides in general? And, assuming that we as a nation wanted
to break our habit, how could we do so without severe social
and economic dislocation?

This is a volatile issue. Tempers flare. Opponents
seldom listen. It is particularly important to remain calm.
One way to remain calm is to get back from immediate cases
and remind ourselves of some points on which both sides can,
perhaps, agree. First, the herbicides and insecticides whose
use we are debating have not been around as long as the aver-
age American has been alive. We have lived without them.
Civilization has existed without the current crop of pesticides.
Both agriculture and forestry have met their goals in the
past without them, and, if we ended their use sometime in the
future, on some gradual, phase-out program, agriculture and

7

as

—

Coalition for sconomic Alternatives

Hooked on Drugs

e
forestry and civilization would surely go on.

My second reminder is that these are all poisonous
Substances. No one disagrees with that. No one can find a
medical doctor who would advise him to eat a spoonful of
2,4-D. These are “economic poisons" and their lables carry
standard warnings against ingestion, exposure to eyes and
skin. What we are debating is whether these poisons can be
controlled in their use so that they poison only the target
Species. The issue is whether they can be confined to cer-
tain areas in the biosphere and to certain time periods,
and if non-target species will be affected. So we all agree
that these substances are harmful to some life forms (if
they were not, we would not use them). And we all agree that
man can be harmed by them under certain conditions.

My third reminder is about research. Science is an on-
going enterprise. No scientist believes that research into
the aetiology of disease is finished; no ecologist believes
that research into the interconnections between life forms
is finished. Research into the toxicity of these substances
is going on today. The techniques are becoming more and more
Sophisticated. Researchers are just beginning to see active
amounts of these new elements, amounts measured in parts per
billion and even parts per trillion. (The original research
on TCDD dioxin, a deadly contaminant of 2,4,5-T and Silvex,
was Carried out at parts per million levels, too crude an
analysis to detect lethal doses of the substance.) Some of
the new research does indicate danger to human health. At
the least, we can all agree that the jury is still out.

My fourth point is about the various interest groups
surrounding this issue. There are several kinds. The first
kind are those people who are trapped into using these econom-
ic poisons. Farmers are in this category. Faced with poor
returns on their investment and high labor costs, they cannot
break even, under present conditions, without using chemical
HeroLcloes. It is important for environmentalists to com-
minicate to farmers that we don't want to ruin them. It
would be foolhardy to propose an immediate ban on all agri-
cultural uses of herbicides. (Agriculture has trapped itself
inivemooie Wse, Guite innocently, by devising methods for
increasing world food production which, in part, let world
pope ton teach Hiner and tipner levels which’ in “turn in-
creased demand for higher yields per acre, which brought on
fue demand 10r current agricultural technologies. The inten-
ion Wasi mieniy moral, The result has been tragic-—we have
a heavy-handed agriculture, in environmental and energy terms,
and more starvation than was previously the case.) No one
Plcoauewover oc tragedy. Federal foresters are trapped too.

Coalition for Econemic Alternatives

Hooked on Drugs .

3

In the 1960's Congress required them to increase their
production of saw timber, and yet, requires them to hold

down costs. Under some accounting systems the immediate
dollar cost of hand release is higher than the cost of using
herbicides. Put between the rock and the hard place, forest-
ers turned to herbicides as a means to achieve an end. Per-
haps habitual use has worked a subtle change in a few minds,
and some foresters now defend herbicides from a philosophical
point of view, treating them as ends in themselves, to be
defended whatever the risk and whatever the alternatives.
Another form of entrapment is a narrow, specialized point

of view, one that considers only the goal to be achieved and

a Single technology to achieve it. It is more socially
efficient to make analyses at the other end of the scale,

and, taking into account economic, social and material
resources, to make allocations based on a broad assessment

of regional needs. Generally speaking, practioners in
forestry and agriculture are concerned only with maximizing
output from minimal input. They have little practice in
visualizing alternatives to their current technique. Finally,
with regard to interest groups surrounding this issue, there
are the manufacturers and the environmentalists. It is
difficult for environmentalists to be objective about them—
selves. Perhaps there are some who are in this debate for

the glory of it, and for whom obscure psychological rewards
balance the long hours after work and the frequent excursions
into one's own wallet. The rewards for the manufacturers

are’ nob at all) obscure. © Inéy arewproiitc. |Ole proriEs.

The herbicide industry is a growth industry. It is an ancient
principle of law that no man shall be a judge in his own case.
The testimony of those who stand to make a profit is inherntly
suspect. Environmentalists, whatever their psychological
rewards might be, speak for the inarticulate, for the children
forthe future and the creatures without language.

As a last reminder, I would like to introduce the evolu-
tionary perspective, the long—term view. This is pertinent
because the ways in which we modify the biosphere constitute
an evolutionary test for all organisms including man. All
living creatures, including ourselves, have only come to be
what we are over immense periods of time. The physiology of
individual species, including body chemistry, and their eco-—
logical relationships, are adaptations to ancient environments.
As these environments changed naturally some creatures adapted
and others became extinct. The pace of natural change was
increcibly slow. Even when man came on the scene and invented
agriculture, change was slow and it was not chemically pro-
found. Man did not alter the environment at the molecular

Coalition for Economic Alternatives
Hooked on Drugs

ih

level. Let's just take one example. If our atmosphere

had evolved with cyanide gasinstead of oxygen,then (all
other factors being constant), humantypes would have
evolved with a tolerance to cyanide gas. But the atmosphere
as it actually evoawed, did not contain cyanide and that is
why we cannot breath it without an extreme reaction (death).
It was not present in the environment to which we are an
adaptation and so we are not prepared by natural selection
todeal with it. The same laws are operating in the case of
phenoxy herbicides. When new, synthetic elements are in-
troduced into the biosphere they constitute an evolutionary
test for many species. The results of these tests will not
be known for generations. The new herbicides and pesticides
constitute an evolutionary test for many species including
our own. Over 5,000 different agents, formulated into more
than 40,000 combinations, compose the current crop of
pesticides. (These are just a fraction of the 500,000
synthetic compounds that have been introduced into the
biochemical environment since 1850.) Together they re-
present a new chemical environment for the earth. Very lit
tle research has been doneon their individual biotic impacts
Once released into the environment they combine, change and
recombine. Almost no research has been doneon this syn-
CeHeasuLcracuaVavy ObeitsS, biotic impacts.» We just do not
know what is bubbling in the chemical soup we have brewed,
nor do we know what its future impacts will be. We do not
now know which species will adapt to it and which will be-
comes excvitiCusm= |neapoint, ol this.is that. farmers and
foresters who conclude that since phenoxy herbicides have
been used for twenty years and, therefore must be safe,
ignore the lessons of evolution. Twenty years may be a
POrmemu0GtloneOn aemin's tite, but it.4as.an-insi¢nificant
moment of time compared to slow moving evolutionary processe
which formed our body chemistry and the ecological balances
which sustainlife. Twenty years is nothing -— human
evolution has been in process 100,000 times longer than
twenty years, the evolution of the cell more than a million
times as long. We must keep in mind a sense of perspective,
and it is natue's long range perspectives and the per-
spectives, Of Our grandchildren that we m<:ct keep in mind

as we make decisions affecting basic life processes.

The biosphere is a complex and dynamic place. The
PA00Ga vO, m ne comtrast,.~1S a simple, place...In.the lab
each animal species is tested for the direct effects of a
toxic substances, and perhaps a dozen different species are
Tec Cheb EM Ollnjenere mwitimpne: blospherc, sue more than a
dozen species. For example, there are over 40,000 species
of wasps. Each has its own niche and they are related to
Cachwocherand.tova million other species by a web of
pathways not yet fully explored. Along these pathways

c-50

Costa tions for HCGHoOHue muvee si eae bg

Hooked on Drugs

y)

travel the creations of man. They travel in i, .teamounts,
but in the biosphere, minute amounts ofcertain substance

can be potent. We are dealing on the mollecular scale here.
What is learned in the laboratoryis only the crudest ap-
proximation of what happens our here. Living systems are
far more responsive and sensitive than are laboratory test
systems. In short, there are many more surprises waiting
out here than in the laboratory. One reason for this is
that all creatures share the same fundamnntal biotic struc-
tures -—— the cell. The cell is the basis of life. To-

day we are pouring unfamiliar compounds into the web of
organic pathways and waiting to see where they will tyrn

up, that is, in whose cells they will temporarily lodge.
Chlorinated hydrocarbons have turned up in the fatty tis-
sues of Eskimos, concentrated there by biomagnification to
levels a thousand times greater than the levels in the
surrounding environment. There are countless examples

of leakage out of the system where the original application
took place. That is because all systems are interlocked by

the movement of air, water and animals. Biotic systems are
not closed systems, they are throughput systems. It is
difficult to control leaks in a throughout system with its |

thasands of input and output flues. And when leaks do occur
it is nearly always a surprise to the specialists and the
managers, and their first response, frequently, is to deny

it. And so we have to be on the watch for miner's canaries.

In the old days, when the workers went down into the

mines, they took a live canary. When the bird started to
sicken, they got out fast. The birds were less tolorant of
toxc mine gases than were the men and served as advance warn
ing of a hostile environment. Wildlife in general serves
that functiontoday. Bees and aquatic birds seem to go first
but we are not heeding the warnings. Our failure to heed
warning signs is partly the reult of the fact that no one

is minding the store. There are still too many specialists
and not enough generalists.

Isn't the EPA minding the store? Haven't they regist=
ered herbicides and pesticides currently ir use? Yes, they
have, but consider the magnitude of their propiem. = inere
are over 40,000 different formulations of herbicides and
pesticides. EPA's information about these materials and its:
evaluation procedureshave received a very low mark from
Senator Kennedy's Senate investigating committee. EPA
officials admit that most of the information in their
files was suppiied by the manufacturers. Their files were
found to be in disarray, their test programs inadequate
and actual misinformation and faulty
data by the committee. EPA is currently struggling with
the issue of reregistering all of these substances. They
apree >. * it mist be done but haven't yet decided on the
basic approach they want to take. Just to give one pertinent
example, a contracted study done for the federal government
in 1963, showing that 2, 4-D caused tumors in rats

C=51i

Coulton Lor become Aitarnumbives
Hooked on umes

‘a
O

Was eather supréssed or lost for years and was not made
public until this year. The conclusions of the Kennedy
subcommittee on administrative practice and procedure does
Nob s Insti coriidencesin EPA's record of minding the store.

In short, we are creating an environmental soup of
herbicides and pesticides and other potent compounds. We
have many specialists in the use of individual ingredients,
but no chef. And no doctor, either. The medical profession
is ill-equipped to diagnose pesticide poisoning. The very
idea of tracing clinical symptoms to minute amounts of
pesticideslandsherbicides; parts per billion, and parts per
trillion, is a new idea in the medical profession. The
laboratory equipment for such analyses is not available in
doctors offices or even in most laboratories in the nation.
Again, the problem is very complex. Countering simple
assertions about the safety of herbicides requires that
one think about less-than-simple phenomena, such as genetic
variation. The molecular structure of DNA contains thousands
and thousands of possibilities, so that the body chemistry
of no two individuals is alike even in the same species.
(The range of variations within a species is frequently
greater than the range of variations across species
boundaries). The chemical balance which maintains the
health of the cell is a balance of many variables, a
dynamic balance that changes in each individual throughout
his lifetime. Recall that we have added to this dynamic
natural system some 500,000 new compounds, and t’ 3ir decay
products and recombinations and then compute the number of
possible impacts, that is, the range oeffiaimpacts a single
compound or its decay products in combination with others,
might have. on unique individual organisms, and you have a
Soobtoivcian Ssenaehntmares: ylthaswnearly impossible: to single
Sui nach econpound or ocombineation asscausing illness in a
particular human being...) Butiit is no, surprise that the
National Cancer Institute has concluded that 90% of all
cancers are environmentally caused. So, with regard to
disease and herbicides, no one is looking in any eieertin eA
fashion. Most doctors don't know what to look for and don'
have the equipment anyway. Moreover, the patient could 2.
devote the resources necessary to trace down the poisoned
needle in the haystack. We simply do not know, and we have
no way of knowing what part of our upward spiraling rates
of cancer, heart. disease and other illnesses are caused by
the herbicides. We do know that these herbicides are in
thevaar weebreath,e am mother's) milk and,.at- autopsy, can be
Gourd snvoum organs) (Mourwildrecall that they are in use
everywhere. So were lead in paints, tetraethyl leaa in
gasoline, endrin, DDT, Dieldrin, thalidomide and hundreds
of ocheriptoxic substances until we learned, too late for

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Coalition for Economic Alternatives
Hooked on Drugs

#3

some people and animals we valued, that they were harmful.
If I may indulge in a redundancy, they were not proven
harmful until they were proven harmful by testing on the
public. Early warnings were ignored. Information was
surpassed. Manufactureres were indignant and experts
pooh-poohed the evidence.

But what would we ever do without them? Herbicides are
an integral part of our economy. It would collapse without
them. We don't know any other way (which does not mean
there aren't other ways). The first step is to sort out the
solutions from the problem. If we were to sudden*y cease
using all herbicides and pesticides the resu t would be
large losses in agriculture (as much as one third of the
annual production) and smaller losses, but real ones, in
forestry. The shock to farm income and farm families
would be unacceptable. But viewing the present system
without herbicides and pesticides does not constitute an
alternative system. Depriving the system of a component
on which it is overly dependent is no alternative. It
does not represent another way of doing things; it just
represents not doing them. And so, even while the drug is
poisoning the addict and producing unwelcome side affects
(inquilines), it would not be wise to withdraw cold turkey.
We must pursue a step by step policy. We must pursue a
gradual phase-out and phase-in of less harmful substitutes.
We must fund basic research into new methods of pest control
and crop management, while old methods, going back to the
pre-pesticide era, are employed. Individuals whose liveli-
hoods are threatened by this phase out program have a right
to be: compensated at public expense (just as the publiceas
now compensating the victims of environmentally induced
illness in the form of higher taxes and higher insurance
and medical costs). And we must look for slack in other
parts of the system, that is, we must be more efficient at
resource conservation and production so that we do not need
herbicides to overproduce for wasteful patterns of consump-
tion. And we must start somewhere.

In principle we should start with those uses which could
be ended without undue harm to individual family income and
livelihood. The Forest. Service use of herbicides is one
such place. The economic gains to be realized by current
investment in the present system of management by herbicides
will not be realized until the period 2020 to 2070 A.D.
These gains, in the form of timber and employment, will
not accrue to families now living. Even if this pine were
not released, the theoretical effect on the national
economy one hundred years from now is so minimal as to be
incalculable. But assuming we want to continue the release

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Coalition for Economic Alternatives
Hooked on Drugs

8

policy, the extra dollar cost of releasing by hand (whatever
it turns out to be, and we do not yet know what it will be)
represents only a small fraction of the annual budget of
the Chequamegon National Forest, a tiny fraction of the
total Forest Service budget. Moreover, it will be spread
evenly among tons of millions of taxpayers. (The Forest
Service accepts far greater losses each year.) Put in
perspective, the added dollar costs are minimal and are
Spread extremely thin. But even this minimal cost to the
local forest need not be sustained. There is slack in the
overall man-environment system. Both money and labor are
now being wasted. Money is being spent, workers are idle,
and labor intensive jobs are going begging all because of
inefficient management in our social system. Moreover,
there are newly available state and federal funds for
manpower programs. We have dollars, jobs and workers groping
around in the dark for each other. What we need is a sound
management approach, and we can begin here. This is an
economic alternative that calls for cooperation between the
state and federal people, and local citizens. Moreover,

it provides a free market opportunity which keeps federal
dollars here, in this region. The herbicide approach takes
federal expenditure out of the region, to down-state or
out-of-state spraying firms and to chemical corporations.

The herbicide—pesticide issue is complex. It is not
what it seems on the surface. Our economy became hooked
on’ these substances incrementally and without systematic
assessment. We were driven into it, in part, by pushers
with powerful economic assets and incentives, in part, by
an idealism ignorant of ecology and systems analysis. Getting
Cerne et Clhelie vic avs b witl “have to be done gradually,
Using a mix ot old and new substitutes to achieve the same
levels of satisfaction by means that are more consistent
with our molecular make-up and our evolutionary constraints.
We need to design our economic activities in accord with
nature simply because, over the long run, that is the most
efficient way. The Chequamegon Forest is a good place to
start. The potential losses that might be risked are very
small and exist far out in the future. Whereas the potential
gain is great. What we might learn here, working together
‘could have application on a wide scale. The Chequamegon
could become a leader, a model for national design bringing
together various social and economic elements in a soft
systems approach to timber production, an approach that has
greater economic benefit for the local area. This is what we
mean by our. slogan, "Hire people, not poisons". The
Coalition for Economic Alternatives is a non-profit
corporation interested in economic growth in this region,
not in growth that relies on hard systems with their
external diseconomies that strip our wealth and leave us
poorer and more polluted in the long run, but in soft-

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a

systems growth that make possible a sustained yield of
economic satisfaction and environmental quality for local

people.

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Re

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Coalition for teonomic Alternatives
Literature Summury

10
Literature Summary
Norback, et al on TCDD and OCDD

"Tissue Distribution and Excretion of Octachlorodiberyo -

p-Dioxin in the Rat", Toxicology and Applied Pharmacology,

32, 1975 330-338.

Summary of physiological results of administering TCDD to
subhuman primates & results of factory workers exposed.
Skin diseases in workers: ulcers, liver disease and
mortality in primates. On rats teratogenic effects and
fetal mortality. Hemorrhage, liver disease, lymph disease
and heart disease in chickens. OCDD less toxic than TCDD.
Embryotoxic at 500/mg/kg/day OCDD tends to be’ excreted
more readily than TCDD which is, instead, absorbed into
body tissue.

Earth News, Feb 22, 77. Harvard Medical Reséarchers found
traces of dioxin in Mother's Milk in Waldport, Oregon.

JeP. Van Miller, R.J. Marlar and J.R. Allen, "Tissue
Distribution and Excretion of Tritiated Tetrachlordibenzo-
pe-Dioxin in Non-human Primates and Rats".

Food and Cosmetics Toxicology, 14, pp. 31-34.

Summary of known effects in non-human primates. "acne,
alopecia, gastric hyperplasia, ulceration, atrophy of bone
marrow and hepatocellular changes". compared to rats,

primates absorb most of the TCDD into their skin and muscles
rather than into their livers. TCDD is not easily metabolized
in either case and remains in the body for long periods of
time.

Jcheenllen,sJ.P. Van Miller’ and D.H. Norback, "Tissue
Distribution, Excretion and Biological Effect of ["C]
Tetrachlorodibenzo-p—dioxin in Rats"

Summary of earlier research on effects includes retarded
sexual development and inhibited immunological responses.

Highman, "Strain Differences in Histopathologic, Hemotologic
and Blood Chemistry Changes Induced in Mice by a Technical
and a Purified Preparation of 245-Trichlorophen-oxyacetic
Acid." Journal of Toxicology, 1: 1976 1041-1054.

Lesions in. mouse heart tissue "are due primerily to 2,4,5-T
rather than contaminants".

53-82% of tests samples became moribund at 120 mg/kg of
2,4,5-T. Others showed blood chemistry changes and anemia.

‘Found major differences in results w/different strains of
mice and different colonies of same strain.

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Coalition for smconomic Alternatives
uiterature Summary

WAR

NCTR strain of mice showed illness and death at dose level
at or below 60 mg/kg 245-T. CRBL mice were able to tolerate
2x the dosage and showed lower incidense of lesions,

The lesions were due primarily to 245-T rather than to
benzine derivative contaminants found in technical (i.e.
commercial) preparations.

Evidence of bladder abnormalities suggests carcinogenic
potential

N.P. Goldstein et al "Peripheral Neuropathy after exposure
to an Este: of Dichlorophenoxy-acetic Acid" Journal of
American Medicals Association, Nov. 7, 1959." pps. Oot.

"Severe sensory and motor symptoms necessitated hospitalization
of three patients, a 52-year-old man, a 50-year-old woman,
and a 65-year-old man. In each case the disorder began

some hours after the use of preparations of dichlorophenoxy-
acetic acid (2,4-D) to kill weeds; the’ symptoms progressed
through a period of days until pain, paresthesias, and
paralysis were severe. Disability was protracted, and.
recovery was incomplete even after the lapse of years.

There was little doubt that the neurological damage was done
by the percutanescus absorption of spilled 2,4-D. The
electromyographic examination supported the diagnostis of
peripheral neuropathy. Since there is no antidote or other
specific treatment for2,4-D poisoning, this herbicide

Should be used with caution."

Kennedy/Hessel "The Biology of Pesticides"

"The first reports that Carbaryl, along with 2,4-D and

2,4,5,-T is capable of causing birth defects and reducing

litter size in laboratory animals---it certainly seems advisable
for pregnant women to avoid all contact with pesticides."

p- 95. John Holdren and Paul Ehrlich, Global Ecology,

N.Y. Harcourt, Brace, Jovanivich,= .o/7..

Goldstein "Peripheral Neuropathy"

Acute neurological damage persisting over years from spilling
10% solution on skin. Loss of weight. Loss of motor
abilities, pain, snausea, (rash; =sensory defivei., elosseo.

some reflexes; depression, versigoe, subeutancouceatcning.

Doses in animals caused diarrhea, rigidity, cronic tremor
coma and in some cases death.

"No antidote is known and there seems to be no specific
treatment for neuropathy if it developes." p. 1309

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Coalition for Economic Alternatives
Literature Summary

ee

Dr. Jacqueline Verett, Federal Food and Drug Administration

From: Dr. Jacqueline Verrett, Food and Drug Administration
"Dr. Verrett of the FDA has found that dioxin causes

birth defects in chickens and hamsters at levels 100,000 to

1,000,000 lower than the amount of thalidomide causing defects

in the same animals systems. Fed to female guinea pigs at

the incredible figure of dose-to—body-weight of 0.6 parts/

bidlion,biexin killed ™é0% of the animals."

Environment, July/August, 1970

"..eSubsequent tests showed that dioxin did irideed
cause birth defects in animals. ...Subsequent tests also
Showed that purified forms of 2,4,5-T and of some forms of
2,4-D caused birth defects ain animals." (Bionetics Study
done under contract to the National Cancer Institute)

Harvest of Death, Neilands, et.al.

"Evidence is now available implicating 2,4-D and
2,4,5-T in the deaths of over 100 reindeer and many mis-
carriages during the fifth month’ of pregnancy of these
animals in Swedish Lapland, in May, 1970. This case is
particularly disturbing because the herbicide treatment
occurred the previous summer. Vegetation contained 25 ppm
2,4-D and 1Oppm 2,4,5--T.

"From elsewhere it is known that exposure to 2,4;5-T
or 2,4-D reduces both egg production and poultry weight.
(A reference to a report by N. Dobson in "Agriculture",
London, "61", page 415, 1954-55)

"Though field data are meager, 2,4-D may also affect
certain animals indirectly because of its effect on plant
metabolism. It has been shown that certain plants such
as sugar beets after treatment with relatively low amounts
of 2,4-D may accumulate abnormally large quantities of nitrates
in their leaves."

Matthew J. Meselson and Robert Baughman, Harvard University,
Prehearing Statement, E.P.A. FIFRA Dochet #295

"We have analyzed samples of fish and shrimp from
South Vietnam, collected in rivers and estuaries draining
areas heavily sprayed with the herbicide n-butyl ¢,4,5-
trichlorophenoxyacetate. These samples contain up to
several hundred ppt of TCDD. No TCDD above the sensitivity
faMiteom ecouLs tppt was found in control samples.

Our results suggest that TCDD may be quite stable in
the environment and that it may accumulate in food chains.
although further research is needed to quantify these
Statements. Nevertheless, it becomes of interest to

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Coalition tor bkconomic Alternatives
Literature Summary

iS

consider what accumulated dose to an individual (expressed
as ppt of his body weight) could result from a given average
concentration of TCDD in the diet. As an example, we
consider life-long exposure for a 50-year old person
consuming five times his weight in food each year. The
accumulated dose will depend on the biological half-life

of TCDD and the average concentration in the diet as

shown in the table.

Unfortunately, neither the biological half-life nor
the range of present dietary concentrations is known.
However, limited experiments suggest that the biological
half-lifg for lethality is not less than two years in
monkeys. ’ Also, pilot studies by EPA indicate that levels
of about 1-40 ppt of TCDD appear in fat and liver of sheep
and cattle grazed on land treated with 2,4,5-T containing
0.04 ppm TCDD.’ Thus, for exposed populations dietary
levels in the range in the table cannot reasonably be
ruled out. Depending on the biological halflife, this
could result in accumulated doses of the order of 10 ppt
or more of TCDD as a result of the use of 2,4,5-T containing
O.1 ppm TCDD.

From the existing toxicological data, it is not possible
to say that such accumulated doses are or are not hazardous.
Short term doses of a few hundred ppt and a few thousand
ppt have been found toxic togthe immune systems of guinea
pigs and mice, respectively, and are lethal to guinea

pigs. "

Professor Theodore Sterling, "Man Against Himself: Biological
Dangers from the Use of Herbicides," Humanist in Canada,

#36.

t is often stated that the attack on 2,4,5-T was part of
the anti-Vietnam war movement, and that attempts to obtain
reasonable regulation of phenoxy herbicides are at bottom
political, anti-Vietnam, anti-American, or pro-communist
activities. These claims are sheer nonsense. The fact
that 2,4,5-T was a teratogen (i.e. a malformer of babies
tike Thalidemide) was determined quite independently of,
and before, reported damage to Vietnamese babies.

In 1969 the U.S. National Cancer Institute tested a series

of common household chemicals. One of the chemicals

tested was 2,4,5-T. Of the 120 household chemicals in the
first screening trials, some 20 were found to be carcinogens.
One of them turned out to be an effective teratogen — that
one was 2,4,5-T. Only after the National Cancer Institute's
discovery of the teratogenic properties of 2,4,5-T, was
attention given to reports of still—births and malformations
that were coming out of South Vietnam. The U.S. Army sought
to arrest such loose talk by appointing an investigating

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14.

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Literature Summary

1h

committee. That committee found no evidence of a rise

in the incidence of malformation in South Vietnam. However,
an impartial commission appointed by the American Association
for Advancement of Science found a definite increase in
malformations and still-births in those regions of Vietnam
that had been subjected to heavy defoliation. These findings
then, combined with a series of experiments definitely es—
tablished that 2,4,5-T was a teratogen and led to the
Cancellatroy in t9/).o! the reristration of ¢,4,5-T and a ban
of its use in granular forms around households and on food
products. The cancellation was fought bitterly by some

of the industry, cspecially by the Dow Chemical Corporation.
In the fall of 1971, Dow Chemical managed to get a court
Peeetme vere mie urewcance: Jalion of 2<,4,5-T because: of
Gechnical errors committed by the Environmental Protection
Agency trom holding public hearings. “In 1974, when ¢,4,5-1
related dioxins were discovered to persist in shrimp caught
off the South Vietnam coast, some three years after all
defoliation had ceased, public hearings were again ordered
by the courts in 1974. These were again postponed because

of industry pressure to collect more data about the spread

of dioxins among the animal and human population of North
America. As no additional data is needed to determine that
2,4,5-T is a serious hazard, the story of ALDRIN and
DIELDRIN is just being repeated with phenoxy herbicides -
except the game is played now for higher stakes than before.

"Report of the Secretary's Commission on Pesticides", H.E.W.

1969.

"Without dioxin, 2,4,-D causes birth defects in animals and
chromosome aberrations, abnormal mitosis and affects nucleaic
acid synthesis in plants."

Prevention Magazine, Nov. 1971, p. 3.

1971 -—.eggs sprayed - pheasants, partridges -— 2,4-D - By
19th day of incubation, 155 of 201 partridges (grey) embryos
had died, 43% of red-legged partridges and 77% of pheasants,

"Most of the surviving birds were partially or totally
paralyzed. They had fused cervical vertibrae, permanent
contracted claws, colorless feathers, underdeveloped
testicles and abnormal ovaries." Similar results w/ducks
and quail.

Staff report to U.S. Senate Subcommittee on Administrative.
Practice and Procedure" (Investigation of EPA), p. 15

A. Two year rat and dog study showed "increased tumor formation

in the rats" . .
B. An independent pathologist concluded that <,4-D is
carcinogenic in rats"

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Coalition for Economic Alternatives
Literature Summary |

1s

16. The Dioxin Story Lon W. House, Environmental Research Assist
Institute for Policy Studies, Portland State University,
Portland, Oregon pp. 5-68.

"Phenoxy herbicides have been used in Pacific Northwest
forests for some 20 years. In 1974 the EPA laboratories in
Prine, Florida analyzed animal specimens obtained from
various areas treated with herbicides. Several of these
specimens were from the Siuslaw National Forest of the
Central Oregon Coast Range. This area has had one to two
percent of the total area of the forest sprayed with
herbicides. EPA found positive TCDD levels in- specimens
obtained from this forest in the following amounts: 83 and
133-per trillion. (ppt), inewhens 013 potwineote! leogcm jay,
and two 14 ppt in deer mice.. TCDD was also found in three
Specimens from other Pacific Northwest forests, and in
several animals from Virginia right-of-ways (two Shpew
samples showed TCDD levels of just below 400 ppt).~

In late 1976 milk samples collected from women living
near the forest were analyzed at Harvard University in
laboratories of Drs. Meselson, Baughman, and O'Keefe, who
are’ collaborators in the EPA monitering program. The
technique utilized was neutral extraction/high resolution
direct probe mass spectrometry, which is considered ©
accurate. by the investigators down to 0.4 parts per trillion
from milk samples. TCDD was found in concentrations as
high as 1.5 ppt in milk of nursing mothers living near the
Siuslaw National Forest. TCDD was also found in mothers
milk from San Angelo, Texas, living near rangeland sprayed

' ay
with 3,4,5-T.

Toxicity
TCDD is commonly referred to as the most toxic chemical

ever synthesized by man. The acute lethal toxicity (LDs5qQ)
for chickens, mice, rats and guinea pigs is in the dose range
of 1 to 20 micrograms per kilo ram body weight. The LDs5q
for guinea pigs is 0.0000006 g/Kg >, Dr. Wilbur McNulty,
chairman of the Pathology Laboratory at the Oregon Primate
Center, started TCDD toxicity tests with Rhesus monkeys in
1975... Upon learning. how potent TCDD is on monkeys, he
discontinued his laboratory tests until a properly
isolated facility could be constructed. Dr. McNulty states
TCDD is almost too toxic to test under laboratory conditions,
that a speck seen only through a microscope was fatal to a
monkey in less than two weeks. "We used only 20 parts per
billion parts solution, and placed it in their? foods It is
the most toxic chemical we know."1© A level of 2 parts per
billion was lethal in 76 days.

TCDD causes congenital abnormalities (fetal deaths,
cleft palate, kidney and liver abnormalities) in rats

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Coalition for Economic Alternatives
Literature Summary

16

and mice.18 The no-effect dose for fetal effects in rats
was 0.03 micrograms per kilogram. Dr. Neuberg states:

Dini Selsey, far the smallest. effective dose of any teratogen
known today" ~"

TCDD is stable in the environment. About 50 Bee Tags OL
the amount applied to soil remains after one year. Given
the dissolution of dioxin in a light—transmitting film, the
presence of an organic hydrogen donor (such as a solvent or
pesticide), and ultraviolet light, photochemical dechlorina-
tion appears to be the primary mode of environmental
degradation of TCDD. 1 However, TCDD photo-—decomposition
is neglible in aqueous suspensions and in wet or dry soil.
TCDD is fat soluble, and has been shown to accumilate in
the liver and fat of rats.<3 Biological magnification has
been demonstrated in a study conducted by the Air Force
in which various species of rodents and birds were observed
to contain igvels of dioxin higher than levels in the
environment.<* In these aspects TCDD is similar to other
chlorinated hydrocarbons (such as DDT).

While the effects of TCDD on test animals has begun to
be established, the threat of human contamination via
herbicides has not been analyzed. There have been no
long-range epidermiological studies of the possible long-
range effects of herbicides on human populations. However,
in a project conducted by the EPA on workers who apply
herbicides, a marked increase in the amount of chromosomal
abnormalities was observed during the spraying season.<5
Dr. McNultley states: "Until better information is available
it is my opinion that the deliberate environmental

‘distribution of TCDD or products known to. contain TCDD at any

level causes a serious threat to human and snimal health". €
EPA

biclogical cencentration

The eastern oyster concentrated .0.1 ppm of butoxy-
ethanol ester of 2,4-D in water to a level of 18.0 in
itself during 7 days, as measured by 2,4-D disappeared
from the bodies of the oysters.

Esters of 2,4-D accumulated in sunfish after exposure
to sublethal concentrations in both laboratory and field
tests (Cope, 1965b), and the fish sampled from a reservoir
with 1 ppb showed an uptake of 2,4-D to a maximum of 150
ppb (Smith and Isom, 1967)

Within an hour after being treated with 2,4-D at a
rate of 100 1b/A, the concentration of 2,4-D in reservoir
water was about 1 ppb (Smith and Isom, 1967). Mussels
(primarily Elliptio crassidens) exposed to the water for 96
hours -concentrated the 2,4-D: 2 samples of mussels had an
average of 380 ppb and 700 ppb of 2,4-D in their tissues.
Asiatic clams concentrated 2,4-D to less than 140 ppb.

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Coalition for eeunomic Alternative
Literature solu ry

Ag

BCOLOMLCH Dune to ones MCuMicg: Ole Enon rcert wrecutie

,
Vifice of dhe wrgadent =woliree ul emwence and eee fOr ne ee gt

2y4-D Lodges in bottom vediment §

2,4-) appears to degrade rather rapidly in witer. For example,
the concentration dropped from 1,000 ppm of application rate to 10 ppb
within 30 days (louse et. al. 1967). However, significant concentrations
of 2,4-D (58.8 pp) were recorded and isolated from sediment samples
removed. from a reservoir some 10 months after treatment (Smith and Ison,

1967).
Ecological Effects of Pesticides on Non-target species, Executive Office

of the President. Offiee of weience and Technology.

Dioxin lodges in latty tissues and oun bussd up over time. Bill Hollyer
"The War on 2,4,5—I" in knvironmental Action, Nov. Dy LOTT, opp. -se—L

"Dow Chemical produced one of the three sets of laboratory analyses
showing tumors in animals fed 2,4,5-T. KPA is bound by federal law not
to reveal the results of the Dow study beforehand - but officials there
are planning to include them in the notice to ban, according to Holloway.

Two other studies also not available to the public are earmarkea to
be part of the notice.

One of them was carried out by scientists at the Lubratoire de
Genetique, Fondition Curie, in Paris. It involved feeding mice water
containing 60 parts per million (ppm) of 2,4,5=-T over a 400-day period.
The results show a number of "rare tumors" as well as evidence of leuxemia.

"In 2,4,5-I treated wice a significant increase in the incidence of.
neo-plastic lesions (tumors) was found," the report said. It conciuded:
"In view of these facts we fecl that the carcinugenesis observed in our
experiments should be attributea to 2,4,5-T per se."

Dr. treueric Kutz, a senior biochemist at LPA who has beer ccnducting
experiments on wildiife, expliins the process by whicn aioxin enters tne
human systern. WVioxin is net soluable in water but can ve carried long
distances frum : sprayed area. whut nappens, Kutz says, is that wnen
<,4,5-T is’ usea in a National forest or. rice field, run-citf containing
3loxin is washed inte stress and water-ways. It tner enters the food
cnain in lish ano wiudulie thut feed in tne taxes ani marsies, ana some
eventually encs Up, an tue ceean te be eaten by shelltisn and cther
organisms.

But whilse Jigyan 1s not soluble an water, if is*soiuvielin fatty
tissue. wnoen cattie. feed on sprayed rangelands, dioxin is able to enter

‘their systems. Hecause dioxin can lodge in fatty tissue, ana because it

is not washed out throu excretion, tne peivon bulid.u-u. vver time.
Holloway's stuaires of dicxin levels in beef liver and neet fat woula seem
to validate this claim, Kutz said.

The finai link in the regulatory process is for HPA to show tnat once
humans eat fish or beet tainted by dioxin, the substance lodges in them as
well, where 1t could potentiaily cause birth defects or other problems.

C-63

>

oi.

PAL

Pan

Coalition for snvirconmental Ai ternautives
isterature oumuary

Peta SVeCVeiie ests Ol mother's milk 1.0 perin ut Caltiternia befcre
Ce Seen Ot At ed te hee Ire Lit Serle... ~re «nown, .o.weve °*,
rid vee eat ;
Pe cheer e. owed PApeity iene Ee | ken Permian Gitte we ui cura Tire TC, LOli Mowery ¢
a ; :
He Cancer Liviiate ss 2Pe Sinnliicant because witncut them, norloway
Sain he wasn't i eye CCUG oroOCUCe, A dal Or cio, a Sit sth Ie
Wyegcay om 7 + Sel ce ” : } ees } E ae Amie
Jagr Soh yes Bb Se A NS Dee wert OVER We te NHesu Sue resiuith. pee
4 See eter | wes : Re P
Lee ANG haere es imine th ye CRE, Un MeEMroOVeldtse Coutts Ee Sec ACL Mi, Ab
Wea ea oeecr nts re BNET. OS onl tae oh ie eel Prine Oman tn le Lo ers Ler
wry ee
thi ey i ‘ ie We teh they 4 (ei Cee, Fe ee PGR CMa es canst
JES ER BS MSs jhe ue

Ferent Burin, arte, 2S wocdoliow, p. 147

2,4-D and ¢,4,5-T may accumulate in soils under relatively anaerobic
conditions.

A buildup of phenoxyacetic acids could cause crops to accumulate nitrate
in quantities as to be toxic.

Nitrate forms nitrite in animal cells which causés methemoglobinemia
(deviation of the blood oxygen-transport system caused by chemical
modification of the hemoglobin)

CheniedieVilliainam, J. Berry, Dy Gsgood, P: St. wWohn <p. 156
2,4-D has caused irritation of the eyes and gastrointestinal disturbances

decays‘ripidly in soil (30-60 days) but is known to last up to 10 months
in low-oxygen water.

indirect effects on small animals and birds by destroying habitat

indirect effects on fish - kills weeds - the decomposition uses the oxygen
in the water - reduction or elimination of dissolved oxygen - suffocation.

There is some evidence that 2,4-Db is carcinogenic - it is known to produce
chromosomai aberrations in plants at lO ppm (changes are inherited)

Affidavit - As inucn as 60% of spray materials can drift one mile from
target area.

STATH UF wloCuwSIN )
I) (Be

COUNTY UF vive, )

I, Kenneth Kagland, beim first duly sworn, depose:

1. 1 am ex.ployed by ine University ol wWisconsin-Maaisor as an
associate .refessor of mecheal-ical engineering.

2. I speciulaize in the areu of tluid dynamics and at.1u ,pneric

dispersion o1 air pollutur.ts.

3. lem informea that the Lnited States Forest Service proposes to
apply herbicijes from helicopters, with tne nelicopters flying at a
level of avpro. mit. sy 59-60 teet avove the trees, at an air speed of

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Coalition for Environmental Alternatives
Literature Summary

te

35-45 m.p.n., and with a nozzle size of approximately 0.13 inch. in
addition, I undestand that the nozzle pressure will be Approximately
2 pounds per square inch, and that the wind speed, presumably measured
at ground level, will be less than 8 m.yp.h.

Based upon the above information, it 15 my opinion to a serent.fi-
certainty, that there will be a lous of sf lenst % to 15 percent of the
herbicide materiatd:s Crom the area of inbetded applireation, and that chnese
materials will drift to areas as fur mas a mile from the intended sites

Of application. see, e.g., Van Valkenbury, Pesticide Formulations (197),
At 500.

4. in order to dete tiine the precase wis,nitude of the material tnat
would be lost, and the extent of the Lransport of this material away
trom the intended sites, 1t is necessary to know, for each individual
Site, the following information:

(a) The precise speed and altitude of tne aircraft;

(b) The precise viscosity, surface tension and chemical content of
the spray involved;

(c) The precise engineering detuils uz to tne nozzle in question;

(d) The speed.of the wind at the height of the aircraft, and the
stability of the atmosphere at the time of the flight, as this will
predominantly govern the extent of the transport of the materials.

5. In addition, the following factors are also important: the pressure
of the micro foil boom, the temperature of the spray,. the size and engineering
details of the control orifice, the volume of materials pumped, the
turbulence of the downdraft and updraft caused by the helicopter, and the
effect. af its interaction with the spray mist.

6. Without a detailed analysis of the above described factors, it is
possible to determine with precision the percent of the materials that
will be lost by drifting away from the intended area, or the extent
of the surface area of land and water that will be covered by this
unintended grift. This detailed analysis is very important, because it
is clear from the literature that under unfavorable conditions as much
as 60 percent of materials sprayed by helicopters can be transported
onto areas away from the target sites.

Kenneth Kagland

Sutscribed and sworn to before
me this 19 day of Juiy, 1974

Notary Public, State of wisconsin
my COMM1ISs1on is permanent

C=65

24.

25.

20.

Coat’ tion tor Beonomic niternative .
Literature Summary

20

Worlu Health Organization Warning, reported in CATS Newsletter, Vo!.
Fly Dee j

World Health Organization warned in 1Y75 "women in their reproductive
years and particularly pregnant women snould be excluded from ccntact
with 2,4,5-T

Dioxin the most toxic man-made chemical

Dr. Diane Courtney was quoted in tne Oreguniar. as saying that dioxin
invariably occurs in 2,4,5-T, that it is the most toxic man-made chemical,
that it is harmful in amounts to small to measure.

Quoted in CATS Newsletter, Vol. 2, #1

_ Meselson, 1973: Dioxin has heen found in soil samples and in foods
in Vietnam and the U.S. and in the soil it is found 10 years after
application.

In 1973, dioxin was found in birds and small animals along rights-
of-way in Virginia and in the Siuslaw National Forest here in Oregon.

This sampling was conducted by the EPA, but the EPA never released the
data.

EPA sponsored studies have turned’up dioxin in beef cattle in several
states and in human breast milk in Oregon and Texas.

One of the few studies done on human spray upplicators, by Yodei’,
Watson and Benson, 1973, shows "a marked increase in the frequency of
chromatid lesions. This trend was especially noticeable among workers
exposed to herbicides." The herbicides included 2,4-D and 2,4,5-T. In
the introduction this study mentions another, similar finding: "Increased
aberations of lymhocyte chromasomes have recently been reported in a group
of Michigan-:fruit producers involved in heavy pesticide spraying." -

CATS Newsletter, Vol. 2, #1

Pr. Logan Norris of tne Forestry ociuoul in Corvallis has stated: tnat
a

Ove = tis lLemnolecule Oo; M°oxin Cam cause a birtr defect. This makes 1
onvinu. that there is no safe uosare level

vamickyr, 1472: weuKemid has been .vunu to ve more ‘prevalent.ir ereéa»
sprayed witnu heroicides.
Perera, New York Times, 1972: A “ive-foid increase in liver cancer
nas beer found in areas of Vietnam Sprayed wits <,4-Lb and 2,4,°-T. 4 exe
two terbicides form the infamuus Agent Orange, the defoliant use“ 1.
Vietnam until an international protest stopped it.
There has also been an increase in chromosonai ubberations including

tnose of Mongolism (Ton That Tung, 1Y70O).

weureecnuriotie ©. Taylor: "I have collected over 100 cases of istness
in wnicn-2,4,5-T was shown or suspected to be a factor. High leveis of
2,4,5-1 have been found in peuple over wide areas surrounding the forests
whicn have been sprayed.‘ After exposure to <,4,5-l, people seem to be
more sensitive to other chemicals, ,. rfiaps becuuse of liver damage."

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271.

28.

29.

Coalition for Economic Alternatives
Literature Summary

ai

Buu Hoi, 1972: In animal studies dioxin causes extensive damage to the
heart and lungs and ali vital organs.

W.P. MeNulty, M.D., Chairman of the Laboratory of Pathology at Uregon
nxegional Primato Kesearchn Center, mentions, in addition to some oi tne
uata we nave mentioned above, damage to the immune system as a result
of exposure tu uioxin. he also states that monkeys are page: times

more sensitive to dioxin than are mice, rats, rabbits and dogs, and that
there are streng similurities in the response. of monkey: ad rumans.

He warns us tna*, ‘until better information 1s availatie, 1€ is aay Opinion
that tne dezsibe7ute environmental dastribution of Cu. (au coxan, or

products xnowr to tuitain TCbuo at any 1evei Causes a serious threat to
humans: an¢ animal lite." MeNuity uisu warns us of tne effect of
bloconeeltration of ‘uly, whic Méatc trat anna. 3 Lipher on The Puud

Chain, such as humars, whicin ext vontaminaled rey, uevesup sncreasinglLy
high concentrations of dioxin in tueir bouies.

One ot the few studies done on human spray applicators, by Yoder,
Watson and Benson, 1973, shows "a marked increase in the frequency of
chromatid lesions. ‘This trend was especially noticeable among workers
exposed to herbicides." The herbicides included 2,4-D and 2.4,0-.-. in
the introduction this study mentions another, similar finding: "Increased
aberations of lymnocyte chromasomes have recently been reported in a
group of Micnigan fruit producers involved in heavy pesticide spraying."

CATS Newsletter, Vol. 2, #1

Proposed testimony of Wilbur P. McNulty, Jr.

A dietary level of 20 ppb for young male rhesus monkeys was lethal in
12 days. 2 ppb killed in 76 days. The toxicity of TCbD for rhesus
monkeys is roughly l ug/ke body weight.

Testimony of Eloise W.*Kailan

p-. 4
reduced resistance to infection is a known effect of TCDD exposure

Dial
".. when picloram and 2,4-D interact, they potentiate their own individual
adverse effects.”

"These herbicides are enzyme inducers meaning that they affect the liver's
function to detoxify and remove a wide variety of subsequently administered
chemical substances..."

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(#1)

OPEC LSIC CummbnTS On "USDA Fie) omivivd oY iONMeNTAL STATEMENT

Tile USk CF HikBICTDES IN Whine pacTottN itseiuk"

UOMBC - wiLauUber
Co-birector

We are assured that "any herbicide used will be registered by the
E.P.A. as being safe to the environment, human beings, livestock, and
wildlife."(Paze i) In no way does an KPA registration mean that the
registered herbicide is "safe"; on the contrary, these substances are.
registered precisely because they are all poisons.

Furthermore, recent government reports have shown that the
effectiveness of the E.P.A. in protecting the public from the hazards
associated with herbicides is extremely lax. Ina report to Congress,
December 4, 1975, by the Comptroller General of the United States,
entitled "Federal Pesticide Registration Program: Is it Protecting
The Public and the Environment Adequately From Pesticide Hazards?",
General Accounting Office (GAO) found the following conditions.

"Safety and efficacy data has not been submitted to support marketing
many pesticides. (Safety data include information on cancer, genetic
changes, birth defects, and reproduction.) Safety and efficacy data is
not required for the pesticides as marketed, only for individual active
ingredients. Reviews of inert ingredients (such as vinyl chloride) are

not subjected to the full range of safety testing. Many labels do
not comply with requirements. Pesticide residue tolerances are not
monitored or reviewed. The safety of pesticide residues in some f'oods’
has not been determined. Statutory registration requirements are not
carried out on a timely basis."

fn December 1976, the United States Senate Committee on the
Judiciary completed its subcommittee hearings on "The Pesticides”.
An excerpt from that report states: "A clear example of EPA's tailure

} Sarat e ry Rete hae s n4 . aris 4 ve
to evyeluote data resulted nu the a,ercy = detearninaticon tneat reve wan

Van aeeuct) aeiitien’ bei wh Rebceinaratzon ot the -pestitade “,4-1. a.
April @, 1976, EPA mailed reresistratzon guidance packages tu manufacturers
be pov Cepreduc taeCOniLultingea,4,-) forswhaeh wmore thans4> resiave ‘ier ces
haverbeensverunted on guch- ooOdsusaS dairy disin, exes, poultry, mear., cur,
apvles, vegetables, and citrus fruits. Tre puidaurce packages cite” a
2-year rat ane dog feeding study perfwrmed vy hua in i965 as si 1iciens

the ‘chronic’ safety testing requirements for reregas.rat1on.

-

So satiofy
Yet, a summary report on the svudy an wPA's siles stated tha there ws
taneréased tumor formation’ in the rats. John M. Carley, Mana,er of ‘re

lierezistration Task Force, stated that he doubts that the summa, ~epe

wus even read in the preparation of the (Guidance packages. An iidepenrient

23

pathologist, wno reviewed the raw data on the study at the request uf suc
committee staff, concluded that 2,4-D is ‘carcinogenic (cancer-causing)
in rats." “

On page ii, we are assured that "O65 years of proper herbicide use bv
the Forest Service in the kastern Kegion have produced no known health
problems in Forest Service personnel, herbicide applicators, or local Forest

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Coalition for Bconomic Alternatives
SPECIFIC: COMMENTS - 2

residents." However, on page 58 the EIS states that "Few studies of herbicide
toxicity to humans have been made." No where in the EIS is there a single
reference to any actual studies done in the Eastern Region to uncover any
potential health problems in personnel, applicators, or local residents.

The EIS states on page 24 that "The TCD) dioxin content now contained in ‘ ,¢
has been reduced to a fraction of 1 percent of its original content.” what
the BLS fails to acknowledge is that before the TCDD contaminant was even
recognized, tens of thousands of vallons of extremely dirty 2,4,5-T were
sprayed over thousands of acres of National crest land in the sastern
KHegicn. ror instance, accordin;" to inforuavion contained in the ‘anviron-
mental Analysis Keport' for herbicide use on tue Chequameyon National Forest

in 1977, some 6,407 acres of the washburn visirict were sprayed with 2,4,5-1

nlone or in combination with ~« 4-D, between iyeO und 1973. Yet, there haw
never been released a deserijption ©* the areus where this contamar>ctea ¢ ., -.
was used. Nor has there heen ary effort to ascertain what damazes may «©

done to. the environment cr human health by the c1ioxin present. wer has ar’
testing been aone to ascertain whether a10xin might still be presert im - i:
or vegetation on these areas. a more teiling. and important assesment o£ Ov.
efrects of past misuses of 2,4,5-T by the Forest service woul? be the sor
study conducted hy “leselgow in the sulsiaw Nutional Forest, wnicr uetectea
leveis of TCDD dioxin in samples of mother's milk in areas where -,4,,-1 ao
been used by the Forest Service.

Presently I am a partner under contract with the Forest Service to
do manual release work in the Chequamegon National Forest, Hayward District.
So it is with first hand experience that I say the KIS assessment of manual
release is simply unimaginative and misleading.

"Generally speaking, manual methods have little adverse effect on the environ-—-
ment. This method can be selective and accomplished with little visual
impact... . Long term local employment is possible." (EIS, page 25).

This statement is a precise summation of major advantages of manual release. .

"The major disadvantages are high cost and ineffective results." "... finding
people to work at physically demanding jobs is a problem.” I can not agree
with these statements. The cost of hand release on the Chequamegon National
Forest averages less than $30 per acre. An extremely difficult site might
cost $50 to $70 per acre. One person with a saw and brush ax can do, on

the average, from .75 to about 3.0 acres of manual release per day, depending
on site conditions and specifications. I do not agree that "it would require
a minimum of 10 people working a full year to clear 1,000 acres of heavy

brush with hand tools." Nor is it. necessary for a “specially funded public
employment program" to replace herbicide release with manual methods. ‘Ten
people working a full year clearing heavy brush would be able to clear a
minimum of *2,000 acres with hand tools. ‘they could do it best on a contrectua:
bidding basis; there would be no need for a new government employment ,ro,.rax.

The EIS statement that "Many Naiional *orest areas have a limited labor supys '
does not square with the E1S's depicition on pages 14,15 and 16 of the area«
of the tastern kegion as being generally economically depressed. The prob-+
lem as not. .the availability of the *>or-’6rce. “Unemployment is hjeh <n

a4

“he areas of the * stern Kegion. The protlem is in the decision of the
Forest vervice to disccurage labor intensiv. methods, The Forest mervice
6 ‘ > E

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Coalition for tconomic alternatives
SPec EEC Colm y wre DS = Gi

does a very poor job of advertising bidding opportunities.

In assessing the cust tu the axpayer of herbicides vs manuai release many

factors not considered shuul? be examined, -Herbicide release has certain

hidden costs whicn a.e born by the public. Ume is tne cost of lengthy
court suits, as the Forest Service attempts to pursue an unpopular policy.
Another is the cost of preparing lengthy tnvironmental Impact Statements
and mnvironmental analysis reports. Another hidden cost that 1s difficult
give an exact figure to but could probably be measure ir the hundreds of
thousands of dollars is the damage done to the public image of the Forest
Service by its insistence om using herbicides. As the BIS recognizes on
page ii, "Public objection to herbicide use continues to be an issue,”
In pursuing an unpopular policy the Forest Service is doing great damage to
its careful public relations campaigns. In the public eye, such slogans as
"Give a hoot, don't pollute" become nothing but ironic hypocrisy.

As the EIS states, the accident rate for those of us who work in the woods

is indeed high. Speaking personally, I feel much safer facing the risks from
@ Saw or ax, which I can prepare for, than the risks posed by a carcinogenic
herbicide.

The Forest Service would actually be doing a better job of paving the taxpayer's
dollar by making’ the switch away from herbicides to a more labor intensive
approach. In doing so, the government would be making a small but important
move toward addressing the great national problem of unemployment.

Although resprouting is a problem in the use of manual methods, the EIS dis-
cussion does not represent the difficulties fairly. Every site is unique.
It is not possible to know now effective manual release will be until it

is done. There is no reason to assume that manual release will have to be
done “annually or biennially", as the EIS states. One advantage to manual
release is that often it is unnecessary to release all of a site. The hand
operator, being intelligent, is able to do a selective job on the site. The
spraying of herbicide simpl; effects the entire site.

Finally, accordimnys to Frofessur Orie L. Louks, who teaches forest ecology
at the Universit, of wisconsin - Madison, and who personally visited many
sites scheduled for herbicide reiease by the Chequamegon National Forest
in 1974, nost of the sites needed so release at all.

On page 27, tne siS fails to mention mechanical weed harvesting as
an alternavive 10 tne use of aquatic herbicides. Suci an alternat.ve is
employed by tne cit, of mMacison, wisconsin, because of puclic opposition
to using hoypicives in the laxes surrounding the city. The weeds and algae
that are narvested are Lien maue available to the ,ubiic for use as garden
mulch.

It is untiortunate that the Forest Service has adopted tne standard
industry arguments in its aiscussion of: tne dioxin contaminant in ©,4,5-T.
(KIS, page 43-51.) Because of the extreme toxicity of dioxin, there is
simply no justification for allowing it into the biosphere. Thomas
Whitesides, writing in the Juiy 25, 1977 issue of "The New Yorker" responds
well and to tne point:

C-70

SPECIFIC COMMENTS = 4

"The government itself appears to have accepted the assurances of the Dow
chemical people and other herbicide manufacturers that the dioxin contaminant
in 2,4,5-T, once laid down, is ueyraded and effectively destroyed by the
action of sunlight and of soil bacteria. Yet 1f the contaminant is in fact
so handily decomposed in this manner, one wonders how to account for the re-
sults of an analysis of samples taken in 1975 of tne fatty tissues of cattle
that grazed un western rangeland that had been sprayed with 2,4,5-T during
the »revicus year, for the samples showed significant levels of dioxin -
levels of up te.sixty parts per trill.con. bow is it that trom grazie

land sprayed wit: this allegealy innocent herbicide the government perm21ts
the cistribution to the american dinner tuble of meat tuat as ceern Colvaminateg

With measurable amowuits. of one vf the most toxic subs.a@ ces “mown to man?
It.is not us though the government were unaware cf such fandings, or 07
.0h. Sa ,natecunce, Sor tie vary stud.wes that produces nese eo i woes
curiucted under the aca tees ef tne E.F.A. And 4 me@morandut dated Augusteeg
197S, i es tun ce cbhaervabhens Of ihe divxin-stud) ur Fai eeeonc inet Ca ae
the “VPA. vntae ws Copbeciae £“O, aus Sonternine ies Le walice the
findings: ‘stuices anciludimge tera lovenic anid Othe. Toxscity etfects increas
that tne resi.uc aevels menticned avove May preser. a nealth nazara to man

based on the applicaison of normal marzins of satety. *'

"Almost incredibly, the E.P.a. people still cannot make up tneir minds. ‘he

issue is completely stalled, and action on it is blocked. In the meantime,

Dr. Patrick O'Keefe and Dr. Matthew Meselson at Harvard have obtained

several samples of mothers' milk from Texas and Oregon, and subjected them

to analysis for possible dioxin content. The preliminary results of this
latest study indicate the presence of dioxin in parts-per-trillion amounts

in some of these samples. The potential significance of these findings
concerning a substance with a demonstrable capacity for inflicting relentlessly
cumulative damage can be indicated by the fact that a nursing infant consumes |
about one-tenth of its entire body weight in maternal milk each day. All |
in all, if one considers what is already known about the nature of dioxin,

the indications from such studies that this almost incomparably toxic sub- |
stance not only has entered the human food chain but may have invaded the |
maternal milk supply is surely a cause for swift and drastic action by our |
government," |

The "favorable effects of herbicide use" listed on page 74 of the
BIS would also occur if the release were done manually. It is false to
imply that manual vegetation control would result in a “reduction of
usable resources and future avaid&ability.". The same degree. of release
can be achieved by either method. |

The assertion that "aerial application of herbicides is less
energy demanding than manual release (EIS page 76) fails to take into
consider tion the fact that the hcrbicide itself is a petroleum product,.
and that a wreit deal of energy goes into its prcduction.

C= 7)

#1

#2

#3

Forest Service Response to Comments
by Coalition For Economic Alternatives

Proof of safety of a properly registered herbicide is
not the responsibility of the user. Under FIFRA as
amended in 1972, EPA has the responsibility to
determine whether a herbicide, when used consistent
with its labeled directions, will perform its intended
function without unreasonable adverse effects on the
environment, human beings, livestock, or wildlife.

The Forest Service cooperates with the EPA to provide
data when needed.

There have been no reported health problems, however,
it is also true there have been no research studies
for this purpose.

The amount of 2,4,5-T used is grossly overstated and
it is only an assumption that it was "extremely dirty."

“Defenders

OF WILDLIFE

November 25, 1977

Mr. Steve Yurich, Regional Forester
633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dear Mr. Yurich,

The following are comments from Defenders of Wildlife, a national,
non-profit, conservation organization upon the Draft Environmental
Statement "The Use of Herbicides in the Eastern Region." Eastern
Region Forest Service, U.S. Dept. of Agriculture FS - R9 - DES -
ADM - 77 - 10. We request thet this letter be included in the
hearing record.

In preparing this response, we have consulted with Frank E. Egler,
Ph.D., eminent vegetationist, Aton Forest, Norfolk, Connecticut.

Our overall reaction is that this Environmental Statement is mis-
titled. It should read "The Aerial Use of Herbicides, etc."
Although "selective" application is mentioned, it is suggested only
for small tracts exposed to public view. It is our belief that

the primary failing of this EIS is that it does not give proportionate
attention to all the possible alternatives for long-time, econ-
omically-sound forest management. Why is there a total absence

of experience and information gained from Forest Service Experiment
Stations forthis territory, although industry research is well-
represented? We refer specifically to Eastern Region policy
publications which do not recommend aerial spraying. The method

is certainly not recommended by the scientific community.

According to Dr. Egler, "I know of not one single research pub-
lication that adequately reports upon past such aerial spraying
(although the chemicals have been in use for over three decades),
with long-term results and logical predictions within the scope

of full vegetation potentialities, that would justify these
‘management procedures.'"

The Description of Herbicides proposed for use on pages 30-3,
along with the methods of application, 34-37 only serves to underline
the potential dangers in use by anyone less than a scientist.

The section on Environmental Impacts of the Proposed Action, 37-7h,
has been written entirely defensively, considering that detailed
research has been done in this field. Hazards and accidents do
occur as an irreconcilable element of our technological age.

In the field of herbicides, flight operators and manufacturers

are subject to their own accidents and hazards which should not be
confused with those of the National Forests, themselves.

Cars
1244 NINETEENTH STREET, NW ® WASHINGTON, DC 20036 © (202) 659-9510

Defenders

(#1)

OF WILDLIFE to Steve Yurich, page 2

Pages 63-65, "Environmental Impacts....on General Vegetation" is
totally inadequate, with writing that is often misleading. There
is no mention, for example, of herbicide effects on herbicide-
sensitive legumes, important in grazing. Here, as in the next
"Favorable Effects," the reader is never informed about the many
disadvantages of chemical control. The idea is promulgated that
herbicides help wildlife and diversify vegetation. "Completely to
the contrary, serial spraying of Eastern forests is done mainly to
convert to pure conifers -- notoriously a ‘desert! for wildlife,
comparable to the pure climax (sic) hemlock forests of the wilderness,
that lumbermen never tire of denouncing." (Dr. Egler)

In Summary of Probable Adverse Effects Which Cannot Be Avoided, 71-79,
we come to a memorable understatement: "some non-target plants may be
adversely affected." There has been no research on the non-target
species and this is quite unacceptable.

As to Consultation With Others, 83, the reference to the Council on
Environmental Quality is flagrantly misleading. Dr. Egler tells us
"In 197) the Forest Service Northern Region sent out a release
titled 'Projects Using Certain Herbicides OK'd by CEQ.' The CEQ

informed me that ‘under no condition has CEQ ever approved herbicides
or projects' (underlining theirs)”.

Controls on Herbicide Use, 96-10), makes the reader wonder if so many
controls are necessary, how can any spraying be done? When asked
about the effort to provide an unsprayed buffer zone of at least 100
feet from private property, Dr. Egler responded, "I should think this
regulation would lead to endless lawsuits. I have known volatility
from ground-sprayed brush to carry half as far, and spray from an
up-held knapsack sprayer nozzle to go farther, while the operator lit
a cigarette. Helicopter spraying is somewhat less precise. An un-
expected updraft could move the spray for thousands of feet."

We would like to conclude our statement with e significant admonition
from one of the country's leading experts on the use and effects of
herbicides. Says Dr. Egler, "Aerial spraying is a soothing, short-
term Band-Aid technology, easily and cheaply applied, understandably
promoted by economic interests, unsubstantiated by scientific research
and contrary to present legislation that governs the usage and manage::
ment of our federal National Forests for multiple uses, including

but not limited to wildlife, recreational, scenic and wilderness
values."

Thank you for the opportunity to comment on your proposal. We look
forward to seeing major revisions in it, based on reactions from
the public.

Sincerely,

? f :

Ch pre Melapu—
Cherie Mason

Field Representative
Great Lakes States

#1

Forest Service Response to Comments
by Defenders of Wildlife

Based on comments received from reviewers of the
Draft EIS, substantial modifications were made to
the following sections:

I. E. Description of Herbicides.

JIE, YP, Wetiinehay Vekeeyiicla -

LL. Divs etlerbicide Toxteatys

Environmental
Defense [AO ena eats

F AY atts stud ry) eat
Fund 1525 18th Street, NW, vino
ana

December 23, 1977
Steve Yurich
633 West Wiscon sin Avenue
Milwaukee, Wisconsin, 53203

Dear Mr- Yurich,

It has recently been brought to my attention that
there is a misstatement of fact in my comments on the
Environmental Impact Statement which we sent to you
on November 18, 1977. Somehow, footnote 1 on page 12
was added to the text without my knowledge. I would
like to delete this sentence. If it is possible, would
you please make the correction ?

Thank you very much for your cooperation.

Stephanie G. Harris
Research Associate

MOUrSe coil yz,

C-76

OFFICES IN: EAST SETAUKET, NY (MAIN OFFICE); NEW YORK CITY (PROGRAM SUPPORT OFFICE); WASHINGTON, DC; BERKELEY, CALIFORNIA; DENVER, COLORADO
Printed on 100% Recycled Paper

NS =“ Environmental

pt @ t aH a, ON

TEN ( <2 Defense
Fund

Steve Yurich
Regional Forester

633 West Wisconsin Ave.
Milwaukee, Wisconsin 53203

Dear Mr eourrcus

1525 18th Street, NW, Washington, D.C. 20036 » 202/833-1484

November 16, 1977

Please find enclosed the EDF comments on the environmental
impact statement for the use of herbicides in the eastern region.

SH/jkr
Enc.

YOurs=irely,

Ro"

] ‘
4 : ff
alin iinr ffi ty

jf

Stephanie Harris
Research Associate

Cai

OFFICES IN: EAST SETAUKET, NY (MAIN OFFICE); NEW YORK CITY (PROGRAM SUPPORT OFFICE); WASHINGTON, DC; BERKELEY, CALIFORNIA; DENVER, COLORADO

Printed on 100% Recycled Paper

Comments of the Environmental Defense Fund
On the Environmental Impact Statement
(USDA-FS-R9-DES -ADM- 77-10)
For the Use of Herbicides in the Eastern Region

tmeroducti on

This environmental impact statement (EIS) suffers from
severe deficiencies in its treatment of the impact of herbicide
use on human health. The same techniques are used in this
argument as were employed in the EIS for herbicidal use in the
western region (upon which we commented on July 8, 1977):
namely, improper deemphasis of the possibility of human exposure
to tetra-chloro-dibenzo-dioxin (TCDD), the toxic contaminant of
the herbicide 2,4,5-T. Each EIS cites inadequate studies which
not surprisingly failed to find TCDD in the food chain or the
environment either because it was not being looked for (i.e.,
the presence of only 2,4,5-T was under question), or because of
the use of insensitive analytical techniques which could not
Hebecc ie ye lseor) TCDD ats small, yetstoxicologically highly sig-
nificant levels. The Forest Service completely ignores the
recent findings of Dr. Matthew Meselson of Harvard University
that TCDD was identified in human breast milk donated by women
Wwhoeliyed in areas which had»been Sprayed with 2,4,5-T. This
Proogoft human exposure contradicts the Forest Services asser-
ttons of improbability of finding TCDD in the environment, and
thus of human exposure.

Wer wouldelike to focus our comments firsit on the signifi-

cance of TCDD in human breast milk, and then deal with specific

C75

statements in the FIS which we believe to be either false, mis-
leading, or contradictory. The following comments on human
health effects are excerpted from the July 8, 1977 EDF

comments referenced above, which are equally pertinent here.

Human Health Effects

In the course of the trial in Citizens” Against. Toxic Spravar
Inc. (CATS), et alv v.. Bergland’ (Civil No.9 76-438) (DeeOregcon,
Mar. 7, 1977); 1 was publicly revealed that’ 273,7;,38-tetra—
chlorodibenzodioxin (TCDD), a contaminant of 2,4,5-T, Silvex,
and other phenoxyacid herbicides, had been found in human breast
milk in areas of the United States which had previously received
treatment with these herbicides. The laboratory of Dr. Matthew
Meselson at Harvard University had identified TCDD in the fat
portion of human breast milk ranging from 10 to 40 parts per
trillion. While the Forest Service questions the validity of
the data, Dr. Patrick O'Keefe in the Meselson laboratory maintains
that there is unequivocal qualitative evidence of the presence
of TCDD in breast milk, even if the quantitation is still dif-
ficulteat Hower Wevels:

The conclusions which can be drawn from the analytical data
are clear: 1) there has been human exposure from the use of
2,4,5-T in the past; and 2) there is a very significant risk to
the health of nursing infants ingesting TCDD. The EIS states on
page 40:

Although some organisms can concentrate TCDD, the prob-

ability of receiving and accumulating a toxic dose is

rare because, as previously quoted CAST reports indicate,

eee there is no substantial supply of the chemical in
the environment subject to accumulation."

C—79

Pe indecasthis statement is correct; it becomes very difficult
to explain how the TCDD entered the human milk. While the EIS
Jae that 2,4,5-T residues would not be expected to accumulate
on) vegetation, in wildlife, or in water, it does not deal ade-
quately with the environmental fate of TCDD. Dr. Patrick
Pekeecreustated in his) testimonyu(in! CATS)! Inc. vie Bergland)
that "TCDD has been found in a number of environmental samples
and the potential for the entry of higher levels of TCDD into
the food chain exists as a consequence of forest burning opera-
eons. eS (pea0) hes TCDD! which contaminates) the 25.4, 5-T: con-
centrates in the fat of animals and thereby bioaccumulates up
the food chain. TCDD residues have been found in the fat of
animals of prey (e.g., shrews, deer mice) as well as herbivores
(e.g., beef cattle). Human beings, being omnivores, can ingest
TCDD residues in beef and the meat of wild animals (e.g., deer,
elk) as well as in forest vegetation (e.g., berries). Also, the
TCDD contaminates water used for drinking purposes. Human
beingsscan also be exposed to: TCDD by the air drift of the
herbicide during spray operations as well as the possibility of
being directly sprayed due to a faulty warning system. Besides
the TCDD which is released to the environment as a contaminant
of the herbicide, there is also the potential for the formation
Oem leclveat) 10, 00O0Ostimeseathe haturally occurring. -level due*to
burning of vegetation contaminated with 2,4,5-T, according to
Ehe testimony (in»the CATS case) of)Dr.'George Streisinger of
the University of Oregon. Obviously, there are many potential

routes of exposure to TCDD so that it should come as no surprise

C-80

that TCDD is being stored in human fat and then mobilized during
lactatwons

TCDD has been characterized by many scientists as the most
toxic small molecule ever synthesized by man. A level which
causes no physiological response in animals has yet to be deter-
mined -- even the smallest doses ever tested have caused some
adverse reaction. Besides causing overt signs of poisoning
(e.9.7 chloracne;,s/loss of) hair;«growth? inhibitions sidney sand
thyroid disorders, and atrophy of the thymus leading to immuno-
suppression) TCDD also causes birth defects and gene mutations.

Dri.n Wilbur McNulty,! Jews, of the: Onegon Reqional Primate
Research) Center, mstatedsinghas testitamonyaan the CATS “case)" that
"the toxicity of TCDD for rhesus monkeys is* roughly of the
order of lmicrogram (ug) per) kilogram (kg)! The "no-effect"
level, for) actite)or ‘chronic angestionges ;2 of course? completely
unknown but is bound to be considerably less than the lethal
level." Dr, James Allen, of the University of Wisconsin, also
found that rhesus monkeys receiving a dose of 1 ug/kg demon-
strated over 50% mortality and 100% morbidity. Death was caused
by severe blood loss due to a decrease first in red blood celis;
then by -asdecrease in®circulating white cells» and plateletae
Two out of 3 pregnant monkeys aborted, indicating severe feto-

toxic effects. Even at a dose of approximately 0.1 ug/kg,

minimal physiological effects (e.g., loss of hair, swelTingror
eyelids) were observed. (Allen; *J.7->Fd. Cosmet. ¥foxicol: @ te

be published).

C-81

The amount of TCDD being ingested by a nursing infant can
be calculated by taking the maximum amount of TCDD found in
the milk fat, multiplying by 4% to convert to a whole milk
basis, and multiplying by 150g milk ingested by an infant per
kg body weight per day. This equals 0.24 x 1073 ug TCDD/kg
body weight/day. If it is assumed that an infant nurses for
6 months, then the total accumulated dose would be 0.043 ug/kg.
Comparing this to the data of McNulty and Allen we see that the
nursing infant is receiving about one two hundredth of the
amount which was shown to be lethal in monkeys or one twentieth
the dose which caused minimal physiological effects in monkeys.
A "safe" human dose is usually calculated by multiplying the
Geseswiich causes no physiological effect in the most sensitive
species by a safety factor of at least 100 to account for dif-
ferences in sensitivity to the chemical between test animals
Sndeianemmtnetiits. Case it 1s obvious that a safety factor of
only about two and one half exists between the human dose and
the dose which caused minimal physiological effects in the
monkey. Because a no-effect level has not yet been determined
aueceLoOntie extreme toxicity of TCDD, a true "safe" level cannot
be calculated for man.

Furthermore, Allen and coworkers found that almost one half
(28 out of 60 animals) of Sprague-Dawley rats fed TCDD for 18
months in doses from 5 ppb to 1 ppt developed tumors at various
Sirecmcompareasto no tumors (0 out of 50 animals) in the controls
(ale nyaureeciemosomere, to be published). Because a safe level
of a carcinogen cannot be established, it is not possible to

postulate a "safe" level of TCDD for man.
C-82

(#1)

(#1)

(#1)

Therefore, it must be concluded that the nursing infant
ingesting TCDD in breast milk is indeed at risk. Symptoms of
TCDD's toxic effects on the infant might include: subcutaneous
edema, swelling of eyelids, conjunctivitis, isolated acniform
lesions, loss of weight, and early signs of ee Also, -the
risk of cancer in later life is increased because of ingestion

OfFTeDbD:.

Specific Comments

1. On p. 43 of the EIS it 1s stated that the no-ertece
level for embryotoxicity of TCDD is 0.00003 mg/kg/day, while on
p. 44 the EIS says that animals would not reach the lowest LD59
(0.0006 mg/kg) if they ate all of the TCDD covering an acre.

This does not mean, however, that the amount of TCDD ingested
would still not be greater than the so-called no-effect level
for embryctoxicity.

2. Regarding p. 44, the analysis for TCDD in a laboratory
test of decomposition of TCDD due to sunlight failed to measure
the TCDD at low enough levels. Page 44 concludes that the TCDD
has broken down entirely under simulated conditions of exposure
to sunlight whereas the level of detection was as high as 0.5 ppm.
With a chemical which is still toxic. in the parts per etre 2747
range, a measurement in the parts per million range is not only
irrelevant and inconclusive but also misleading if any conclu-
sions are drawn from this test as they are here.

3. In studying the biosynthesis of chlorodioxins by chloro-

phenol condensation in the soil, no TCDD was found, but the

(#1)

(#1)

(#1)

(#1)

Forest Service fails to state what the detection level of TCDD
was (p. 44). If it was as insensitive to low residues as all
of the other tests mentioned, then the conclusion that there
is no biosynthesis of TCDD may well be erroneous.

4. The measurement of TCDD in soil after heavy application
of 2,4,5-T is discussed on p. 45 without stating what period of
time had elapsed after the application of the herbicide and
Detoresane wanalysis for; TCDD was carried out. “Also, the
detection level of TCDD was 1 ppb, which is still too high a
level to predict whether or not the soil contains harmful
amounts: of “TCDD:

5. The statement of p. 45 that TCDD does not biomagnify
is seemingly contradicted on p. 46 which states that TCDD has
been found to bioaccumulate in algae, snails, and fish, and has
been found in samples of animal and bird tissue taken from
sprayed areas. (Certain of the animals sampled were predators,
like shrews). It is not Surprising that TCDD was not found in
the bald eagle carcasses studied as the detection level was
0.05 ppm (the EPA found TCDD in the wildlife samples in the
Cait eee CEO) iso, it LSsonot, stated: how the~eagies
were chosed for the study and whether they were from areas which
had received application of 2,4,5-T.

6. Pages 47 and 48 seem to either be missing or the pages
have been misnumbered.

Peer aoemale points out that heating confined 2,4,5=T up to
FO Gem Oceipn O64 senours, would convert 0.13% of the 2,4,5-T to
Mephpometitcetasa very important point of information as these

C-84

(#1)

(#1)

(#1)

temperatures can be reached by forest fires. In fact, vegeta-
tion which has been killed by 2,4,5-T would be likely to catch
on fire either accidentally or. on purpose in order .to cleargcic
area. Thus, generation, ore TCDD eshouldebesexpectcan ae: om such
fires.

8. The Forest Service seems to assume that there is a
threshold level of TCDD when it says on p..50: "At the present
levels of _.0.1,ppm,.dioxin,in.2,4,5-T,sthere.is virtuallyenoswa,,
anyone would be expased to enough TCDD to exceed the rate needed
for measureable effect." It proceeds to compare the amount of
TCDD needed for an acute toxic reaction to thesamount ofs lca
which is present in water; this fails to take into account the
infinitesimally smaller amounts of TCDD which could cause adverse
chronicyreactions, esuch as carcinogenicity, mutagenicity ao.
teratogenicity.

9... The Forest Servicesconcludes oOnep.mo) thats CDDE smog
being found in the environment on the basis of the results of
the Food .and, Drug Administrations sc. (PDA) Sanalvsic llores, 4, 3-0
residues ingflood overe al four-VGarsper Occ me EVvens 1 tec, da) tee
not found in food, this does not preclude the possibility of
finding TCDD, a much more persistent chemical and one which is
more likely to be present. Furthermore, the FDA usually uses a
multi-residue analytical method for phenoxyacid herbicides which
is not very accurate and which they readily admit cannot give
good quantitative data.

10. It is not enough to measure 2,4,5-T residues in food;

rather, TCDD should be measured as well. Thus, when the Forest

Cc-85

(#2)

(#2)

Sservicesstatesmthat. 2,4,5-T was not found in cow's. milk (p. 57)
this by no means indicates that harmful residues of TCDD were
nNotpresent.

ll. Page 60 presents a very important piece of information
which is seemingly ignored in the conclusions of the EIS; namely,
that chromosomal abnormalities were found in herbicide appli-
CacOrs, slats shoulda berincluded in’ the overall discussion of
risks of the use of these herbicides as it indicates that there
is a mutagenic effect of these chemicals on persons of high
exposure and thus a potential mutagenic effect on the general
population in the sprayed areas. Furthermore, this raises the
possibility of carcinogenicity of these compounds, particularly
Since Allen, et al. have found that TCDD is carcinogenic in
rats (see p. 5). Because mutagenic chemicals are very fre-
quently also carcinogenic, a severe threat to the local popu-
lation could very well be posed by the widescale spraying of
these hazardous chemicals.

12. The Forest Service presents a ludicrous argument on
p. 60 trying to prove that there is no increase in cancer within
wopulations exposed to 2,4,5-T spraying. They argue that the
National Cancer Institute's county-by-county cancer maps
anaicates in the words of the Council on Environmental Quality:
"a Majority of the areas of high cancer -mortality are located
Premlaraeecities. The implication from this apparently exoner-
Atese? 2) =Terrom any guilt Of Caulising a high cancer mortality
PaLeeoecaicemt is not used in large cities. This argument is

fallacious on two grounds: 1) the statement says the majority

C-86

(#2)

(#2)

TO

and not all of the cancer hot-spots are in large cities, "hence
an isolated instance of increased cancer incidence in forest
areas sprayed with 2,4,5-T could still have’ occurredgandecna.
statement would not be contradicted; 2) the latency period for
cancer is often as long as twenty or thirty years so that it

is probably too early to .begin looking for cancer increasessdauec
to 2,4,5-T exposure. Also, the Forest Service asserts thatycthe
decrease in stomach cancer rate should indicate that the pesti-
cide residues on food are not causing any carcinogenic response
in human populations. There is no reason to believe that if
indeed these chemicals did cause human cancer that the site
would be the stomach (e.g., the Allen rats developed tumors of
various sites from the ingestion of TCDD).

13. Page 61 cites the findings of the FDA's Total Diet
Study which found few herbicide residues in the marketbasket
survey of foods. As has been mentioned previously, the recovery
of these chemicals is very poor; negative results of such
analyses are highly suspect and prove little.

14. The Forest Service says on p. 62, that ithe toxiertyeo.
2,4,5-T has not been the basis for legal rulings against the
Forest Service in the National Environmental Policy Act (NEPA)
cases which have been brought. While technically true, this
statement is misleading. Courts have never found it necessary to
pass judgment on substantive issues because of procedural inade-
quacies in the environmental impact statements.

15. A ridiculous paragraph is included in p. 66 which

should be eliminated. It reads:

C-87

(#4)

(#5)

=i

Controlled feeding trials and laboratory tests have
shown some herbicides to be toxic, teraogenic, car-
cinogenic, or mutogenic (sic) to mammals. The same
results can be produced with a variety of other

(#3) chemicals. LD590 rates have been established for

most chemicals available to man. The dosage rates

used in controlled experiments are not reached under

conditions found within normal forestry herbicide

application:
Peco eOreo tle mwhated i -ercencesdoces-itymake, that.other chemicals
as well as herbicides have been found to cause acute and chronic
toxic effects? This certainly does not mean that herbicides
can be considered safe -- just because other chemicals are
arsOuMisale. mr lisisetuue that, LbPgg rates have been established
for most chemicals, but this in no way means that these chemicals
are safe.

Secondly, animals are fed high doses for three reasons:
to compensate for the short life span of animals compared to
humans; to compensate for the very fast metabolizing and
excreting of chemicals by animals compared to humans; and to
compensate for the relatively small number of test animals used
compared to the number of human beings exposed to the chemical.
High doses are essential to increase the percentage of animals
GecurnoecanceresoOmthacettewill, show in the small number of
auimails, usually 50, used in tests.

lGeme Page.67 says that deer did not accumulate 2,4,5-T,
but no mention is made of accumulation of TCDD.

17. The Forest Service admits on p. 74 that there would be
a favorable economic impact on local communities if manpower
were used to clear the forests instead of using chemicals; how-

ever, they then imply that there would be a later decrease in

C-88

ES Ra

usable resources which would cause a long-term adverse effect on
the community. There is no reason why there should be a decrease
in usable resources if the forest were properly managed or why
this decrease should occur only if chemical treatment is sub-

stituted for by manpower.

Conclusion

Despite ample evidence of the hazards posed by phenoxyacid
herbicides in general and 2,4,5-T, Silvex, and other TCDD con-
taining herbicides in particular, the Forest Service continues
the unconscionable use of these chemicals over tremendous land
areas and thus exposes large segments of the population to all
of the deleterious effects of these chemicals. The argument

that the decision of safety rests with the Environmental Pro-
1/

tection Agency (EPA) and not with the Forest Service is false
because in fact the NEPA requires the Forest Service to balance
the benefits against the rasks an the writing of the his ric
only way that it can be concluded that the risks do not far out-
weigh benefits is to downplay the risks by incomplete citations
from the large body of literature which now exists or by drawing
misleading conclusions. In fact, the Forest Service has done
DOCK) 17 sere Se tS.

The evidence of hazard of 2,47)5-T 16 clear) 1) 2,4, 5-0
cannot be produced without some contamination by TCDD; 2) TCDD

persists in the environment and bioaccumulates; 3) TCDD is

1/ In fact, EPA has issued a rebuttable presumption against any
regaustration of, 274 (5-7!

C-89

aS

present in human tissues (i.e. breast milk), hence there is
positive evidence of exposure; 4) TCDD is one of the most toxic
compounds ever synthesized by man and can cause a variety of
adverse physiological reactions including birth defects and
cancer. The continued registration of this compound by the

EPA is appalling , but even worse is the continued use of the
chemical by the Forest Service for large scale spraying opera-
tions.

The alternatives to the use of such hazardous chemicals
are the use of manpower or machinery. While this might be more
expensive in the short-term, there will be a positive economic
benefit to the community as well as decreased government monies
being spent on welfare and unemployment payments.

In sum, the Environmental Defense Fund opposes the use of
the phenoxyacid herbicides by the Forest Service in the eastern
region and believes iat the EIS is incomplete and misleading,
particularly in the section dealing with the impact on human

health.

Sincerely,

ep! iter, é nae ae,
/

Stephanie Harris
Research Associate

C-90

#1

#2

#3

#4

#5

Forest Service Response to Comments
by Environmental Defense Fund

The entire section on TCDD was rewritten and
incorporated in another section of the statement.

The entire section on Human Health was rewritten so as
to present more current information.

The paragraph was modified to eliminate the reference
to other chemicals.

This particular research was searching for 2,4,5-T and
nol Lor. LCDp:

The use of manual labor would provide some favorable
short-term economic benefit but the inefficiency of
manual labor would result in adverse long-term effects
due to a loss in the timber resource and resultant
increase in prices.

Cao

Quality herdcvooa—
produces a
better return
per acre per
CONneLary
to the assertion
Seethne draft
statement.

year,

PRIENDS OF THE EARTH

Ce SUOTRKBRE DO. G WASHINGTON, D.C. 20003

Davip Brower, President

(#1)

November 4, 1977

Mr. Steve Yurich

Regional Forester

633 West Wisconsin Avenue
Milwaukee, Wisconsin

Dear Mr. Yurich:

The following is our response to your request for comments
on the draft environmental statement, "The Use of Herbicides
in theysEastern Region". Our conclusions are supported by
the attached reports and material.

The draft statement basically outlines a program
whereby hardwoods in the National Forests will

be killed by aerial spray of herbicides in order

to make it possible to grow "more profitable"
softwoods. Timber spray projected will account

LOwe One Go eaAcres. oul, Of a, total of 43,695. treated

by herbicides proposed for the entire Eastern system.

Yet, the draft statement offers no proof that softwoods
are indeed more profitable than hardwoods. We think
that the draft statement does not meet the requirements
of the National Environmental Policy Act until this
is done, since this is the underlying assumption of
the entire program.

Mohasco, Inc. of New Amsterdam, New York, a major and
dominant producer of household furniture in the
United States did a quick survey of their hardwoods
needs and prices for the benefit of Friends of the
Barthes bnc.

It is fair to say that they were quite surprised at the
interest of the Forest Service in eliminating hardwoods
from the National Forests, because hardwoods are their
main furniture wood, and because hardwoods have been
in relatively short supply in the past few years.

Contrary to the Draft Statement's Conclusions, Hardwoods

OGLernan tiqualyjor Greater Yield Per Acre Per Year

Attached to this letter is a broadbrush breakdown
of furniture hardwood needs by Mohasco, and impressions
Ofepcice provided to wus by Mr. Robert Cortelyou,
Vice-President in charge of the furniture division.

C-92

Committed to the preservation, restoration, and rational use of the ecosphere

Unlawful uses
of herbicides
proposed:

The impact of the Forest Service upon the supply of
hardwoods can be substantial. For example, Mohasco
was rather taken aback by the recent decision of
the Forest Service to discontinue "cruising" for
downed hardwood in Appalachia. As a result of

this decision, prices jumped on hardwood.

We also consulted with a commercial timber tract

operator and timber consultant from southern Maryland.

Both were of the opinion that quality hardwoods

brought a greater or at least’ equal return “per acre pe aaa

than softwoods. Of particular importance was walnut.

Friends of the Earth would suggest that the government
should be in the business of producing quality hardwoods
on the eastern forests, rather than softwoods. This
incidently makes a better recreational use possible
for the National Forests.

This would make the use of herbicides applied by
airplane completely undesirable.

(2) The draft statement does not validly meet the requirements
of the National Environmental Policy act for a second
reason. The proposed uses of herbicides by the statement
proposes uses that are contrary to the label and
therefore, unlawful uses.

a. You are proposing the use of 2,4,5-T and Silvex on
land that is required by law to be multi-dimensional
in use, including recreational uses.

Yet, 2,4,5-T is banned for recreational, aquatic,
or home uses for good reason related to dioxin
content. |

Iltis a -mattersol *facerthat) everysscuare inchvon \
National Forest land is used for recreation such
(#2) as’ hunting, “and “this@fiact: isVnotbvat all diminished
by the separation of the National Forests into
general use zones. The dioxin in 2,4,5-T and
Silvex is picked up by wild animals and this
chemical is passed on to the consumer who eats

the animals (or fish). Use of 2,4-5-T under the
circumstances would be contrary to the label and |
unlawful.

types. It is also quite clear that it is impossible
to use volatile (low or high) 2,4-D without violating
the label instruction against drift. No user |

b. You have not limited the use of 2,4-D to non-velatile

can prevent this chemical from evaporating and drifter
many miles to other properties.

As a result of contamination of more than 4,000

C-335

(3)
Statement not
correct about
herbicides never
found in food.

| (#2)

(4)
(#2)

Square miles with 2,4-D with air concentrations of
5 to 10 parts per billion, grape growers have lost
20 to 50 percent of the 1977 crop and growers of
broadleaf crops“have lost yield. The State of
Washington has banned the use of high volatile
Bees and restricted the use of low volatile

74-D.

Friends of the Earth has requested the Environmental
Protection Agency to remove volatile 2,4-D from
the market since it is impossible to use lawfully
in compliance with the label restriction against
drift. (See attached letter.)

The plans of the Forest Service to use 2,4,5-T
in wildlife areas is irresponsible, and again
a violation of the label.

The draft statement pointedly notes that no herbicide
material has ever been found in food. This is incorrect,

Measurements of mother's milk in Texas and Oregon
have shown up to 40 parts per trillion in milk fat of dioxin.
This is an extremely serious matter, since such dioxin
levels can cause severe damage to children.

The Forest Service has been partly responsible for getting
these mothers into such deep health problems.

The draft statement does not describe how spray drift
from the herbicide program is going to be kept from
private property surrounding the National Forests.

The Forest Service in the eastern region has been
responsible for a very serious violation of label
requirements, recently written up in Organic Gardening.
We are enclosing a copy of that article.

In summary, the draft statement fails to meet the
requirements of the National Environmental Policy Act, and
proposes the unlawful use of herbicides. We hope that you
will tethink your program.

With best regards,

OL Neots

Erik Jansson
Research Associate

Secretary Robert Bergland

Rupert Cutler

Dave Ketchem

Tom Barlow, Natural Resources Defense Council

Maureen Hinkle, Environmental Defense Fund

Jetfirey Knight, © .0..

Rita Molyneaux, National Parks and Conservation Assoc.
Linda Billings, Sierra Club ;

Enforcement, E.P.A.
Edwin Johnson, Dep. Ass. Admin. Pesticides Programs
Council for Environmental Quality

FRIENDS OF THE EARTH

620 C STREET, S.E., WASHINGTON, D. C. 20003
(202) 543-4313

Davip Brower, President

INVENTORY OF HARDWOOD REQUIREMENTS BY MOHASCO, INC,
Pore RTENDS OF STHE EARTH, INC,

Pource: Mr. Robert Cortelyou
Vice-President in charge of the Furniture Division
Mohasco, Inc.
Amsterdam, New York 12010

Oak: Prices for oak were up 30 percent last year, but we
CavmccCtwascUlply Olart. in thessouth, supplies are
tight but available. The price trend has flattened this year.

Elm: Supplies tight but quantities available.

Sapgum or Tuplo: Quantities are available.

Walnut: We are always looking for walnut, and this is an

ideal tree for the private grower to make
money with. Prices are stable now in Appalachia with
normal inflationary increases.

Reale ittle sticky in supply this year. The price is
presently $100/1000 board feet premium over oak.

MapleY The Japanese practically bought the entire supply
Ti tneepasc “years to" build ‘bowling alleys:

Popular: Good stipply with normal pricing.

C-96

#1

#2

Forest Service response to comments
by "Friends of the Earth"

Data was misinterpreted. Although 29,465 acres are
estimated for Timber Management activities, only 7,000 -
9,000 acres are estimated for aerial spraying. (TABLE 1).
In addition, nowhere does the DEIS state that the Forest
Service is interested in eliminating hardwoods from the
National Forests. In fact, walnut plantings are treated
with herbicides to reduce grass competition thus promoting
better growth.

These statements are all subject to individual

interpretation. We feel we have met the requirements of
NEPA.

G-97

<r <

November 29, 1977

Mr. Steve Yurich, Regional Forester
United States Forest Service

633 W, Wisconsin Avenue

Milwaukee, Wisconsin 53203

Re: Draft Environmental Statement on the Use of Herbicides - Eastern Region
Dear Mr. Yurich:

By date of November 18, 1977, Kathy Sarton of our National Staff responded to the above notifica-
tion of intent, circulated to me, and I imagine others in the Izaak Walton League.

I would urge that the Regional Office very closely review and attempt to meet the spirit and con-
tent of Kathy Barton's review.

The issues she raises are, I believe, very germaine to the document that was circulated and to
the issu with which we're involved. To continue on the basis of intent that one perceives in
reviewing the document will only further muddy the issue and embroil the region in difficulty.

Aside from the comments that Kathy has made, I'd like to provide added emphasis if possible, for
the need to consider alternatives. All of the agencies when asked to consider alternatives

(human labor in releasing, et cetera) have indicated that even with today's increased cost of
chemicals, that this is till too expensive an alternative. I would suggest that it is my basic
feeling that these arguments are flayed by the very fact that they consider only the "known"

costs and do not consider the cost to the USFS of the defense around the Nation of the Herbicide
Applications and other non-measured costs. It may well be that the Forest Service could convince
the Administration or the Congress that a larger operating budget today may very well be justified
in some areas of the Region from an overall point of view.

I do hope that tne Regional Office will review Miss Barton's statement and that at leagt some
of the imput will be reflected in the Final Statemen

- Zentner, Mamber 1 cutive
/ WiF Board
National President Honorary President Executi onal Staff
DAVID F. ZENTNER, Minnesota HENRY GIBSON, California Chairm: utive Director and
vice-C lor, OUTDOOR AMERICA
National Vice-President ee bK LORENZ
KEITH Regional Governors
EITH TAYLOR, West Virginia a Re eDRD Calliorsia CHARL ronmental Affairs Director
BRUCE WARD Wyoming ROY CROCKETT, Indiana MAITLAND SHARPE
eae teeta Pron NELVIN ROBUCK, South Dakota - . ee Urban Environment Director
, Colorado KAREN GRIGGS, Indiana ink peer?” LARRY YOUNG
W. W. “BILL” HUBER, Georgia ALFRED J. KREFT, M.D., Oregon
National Treasurer STANLEY H. MYERS, Pennsylvania JAMES L. NEWBOLD, Maryland Save Our Streams
C. B. HARRIS, Virginia HELEN V. STAMMEN, Colorado Program Director
ba KEITH TAYLOR, West Virginia DAVE WHITNEY
c-9 8 LEO WINDISH, //linois
General Counsel Wilderness Consultant DAVID J. WRIGHT, lowa Southeast Representative

HOWARD S. WHITE, Illinois SIGURD F. OLSON, Minnesota DAVID F. ZENTNER, Minnesota GROVER C. LITTLE, JR.

THE IZAAK WALTON LEAGUE

ee

November 18, 1977

Steve Yurich, Regional Forester
633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

RE: Draft Environmental Statement on the Use of Herbicides in the
Eastern Region

Dear Mr. Yurich:

We have reviewed the Draft Environmental Statement on Herbicide Use in
the Eastern Region of the U.S. Forest Service and find it to be too general
to properly inform the public about USFS policies on and plans for
herbicide use in the eastern region. The intended use of individual herbi-
cides and implications of such use are discussed only in general terms.
Although the Service plans to prepare individual environmental analyses on
some specific herbicide application projects, the League believes that a
more comprehensive initial description of herbicide use for the entire region
is necessary to provide an overview of total planned use.

This DEIS is inadequate in several respects. The major omissions
we have noted are:

(1) the DEIS does not set forth a clear policy statement or set
of policy guidelines on herbicide use;

(2) it does not provide sufficient specific and comprehensive information
on the total herbicide program in the eastern region;

(3) it is not clear in what instances the public will have the
opportunity to review proposals for specific herbicide applications;

(4) it does not describe research activities or suggest a program for
initiating or continuing research; and

(5) it does not adequately discuss alternatives to herbicide use and
completely fails to suggest alternatives to phenoxy herbicides.

OF AMERICA

INCORPORATED

(#1)

(#2)

Mee Yurich -2- November 18, 1977

In addition:
(6) the League opposes the proposed use of phenoxy herbicides.

hes) Policy Guidelines. This impact statement should, as should any
programmatic statement, begin with a clear, specific statement of policy.
The control guidelines in Appendix A provide only a partial statement
of policy. They are often too general and ambiguous to provide specific
guidance in making difficult policy decisions.

For example, the first paragraph under number 5, "Social/Economic
Controls," states:

When pesticides are required, those methods of application and
formulations that will most effectively suppress the pest, are the
most specific to target organisms, and have the least potential
hazard to all non-target components of the environment will be
recommended. (p. 99)

Clearly there are cases where no one chemical will meet all three of these
criteria, but no policy is set that indicates where the trade-off between

the method "that will most effectively suppress the pest" and "have the
least potential hazard" should or will be made. In such cases, this
"guideline," in fact, provides no guidance. Moreover, there are no clear
guidelines to determine when a pesticide will be required in the first place.

The policy guidelines should provide answers to such questions as:
Under what circumstances will herbicides absolutely not be used? Will primary
consideration be given to pest control or environmental effects? What
alternatives will be considered before a decision is made to use herbicides?
When will the public be notified of a particular planned herbicide action?

The National Park Service prepared an environmental assessment on
"Pest Control in the National Park System, " in May 1977, which is a
programmatic statement similar in scope to this USFS herbicide DEIS. Its
policy statements and guidelines on pages 1 - 4 and in Appendix A could
serve as a partial model for this Forest Service statement.

(2) Specific and Comprehensive Information. The DEIS does not discuss
many aspects of herbicide use in specific terms and examples, making it
difficult for the public to evaluate these uses. Vital information missing
from this statement includes: Which herbicide is to be used on what target?
How much will be applied in what areas for what purpose? In what situation
are particular alternatives possible? How does the future program compare
with past practices? How often are applications necessary for different
situations?

Much of this information could be easily included in graphs or charts.
A chart listing, for 1976, a particular herbicide, where it was applied,
how many times it was applied there in one year, what its target was, what
the vegetation management objective was, how large an area was treated, and
how much was applied would help give a good overall description of the

C-100

(#3)

(#4)

Mr. Yurich -3- November 18, 1977

type and extent of herbicide use in this region. Such information would
particularly help the public to determine how necessary or appropriate each
use was. A short dixcussion of any major anticipated changes for the
future should follow such a chart, or be included elsewhere in the report.
Again, the NPS Pest Control Assessment (Appencix C) could serve as a model
for organizing this information.

(3) Advance Public Notification. Inclusion of more specific information
in the DEIS would not substitute for the preparation of individual environ-
mental analyses on specific actions. Notifying the public of specific planned
uses provides the public the best opportunity to examine and evaluate the
necessity, goals, and possible effects of such uses.

This DEIS does not, however, indicate in what instances the public
will receive advance notification of an herbicide application. Appendix A
control guidelines state only that the public will be notified "when required"
or in "the use of controversial herbicides or controversial methods of
application." The final EIS should list the exact circumstances under which
the public will receive advance notification of herbicide application.

We suggest that, at a minimum, the USFS should notify the public and
solicit comments on any proposal that falls into the categories listed on
page 98 of the DEIS--those proposals that must be reviewed by the field
Pesticide-Use Coordinating Committee before being approved by the Regional
Forester. These are:

(1) Use of a pesticide (for a particular purpose or use in a particular
way) not labeled under the Federal Insecticide, Fungicide, and
Rodenticide Act, as amended.

(2) Any application to water, or any application whereby the
pesticide could reasonably be expected to get into water.

(3) Any use of a pesticide that can reasonably be expected to affect
threatened or endangered species.

(4) Any program or project in which 640 or more contiguous acres
would be treated as one application.

The public should also be notified in advance of any proposal to use a
phenoxy herbicide.

(4) Research. Several kinds of research are necessary to improve
the herbicide program: monitoring of effectiveness and environmental
effects of herbicide use; development of more specific and/or less harmful
herbicides; experimentation with methods of control other than herbi-
cidal; and in some cases examination of the source of imbalance in the
system which necessitates control measures and research to determine
how to restore that natural balance so that control is no longer necessary.

It would be helpful if the statement included a brief summary of the

kinds of research that are being conducted. In addition, it should designate
areas in which alternatives to traditional methods will be tested.

C=107

(#5)

(#6)

Mr. Yurich -4- November 18, 1977

(5) Alternatives to Phenoxy Herbicides. Although this DEIS spends many

pages discussing phenoxy herbicides, it completely fails to mention what
less controversial and better-researched herbicides could be used as sub-
stitutes. Nor does it specify for what exact purposes these herbicides
are to be used. The discussion of TCDD is clearly a justification for its
use rather than an examination of its effects and possible alternatives.

The final EIS should discuss: (1) the specific purposes for which these
chemicals are to be used; (2) the available alternatives, chemical and other;
and (3) the advantages and disadvantages of using these alternative herbi-
cides compared to the phenoxy herbicides.

(6) Use of Phenoxy Herbicides. The Izaak Walton League at this time
opposes the use of the phenoxy herbicides. We disagree with the approach
and substance of the Forest Service's statement that "the present data
Support the contention that there is no reason to believe the proper use
of 2,4,5-T...is exerting any toxic effect on the environment or any hazard
to human reproduction." (p.51) We believe the present data do indicate

that 2,4,5-T has a toxic effect on the environment, particularly through
bio-accumulation, and may pose a hazard to human reproduction and health.

Statements in the DEIS itself indicate that research has not yet
Shown these herbicides to be safe; important research into the actual
hazards of TCDD are ongoing. For example:

The EPA is conducting sensitive chemical testing to determine
whether TCDD is getting into human foods or can be found in
humans. (p.45)

EPA will review these data [TCDD levels in beef fat and liver]
and extrapolate the levels found to various toxic effects
observed in various animal feeding studies. (p.46)

Further, the DEISadmits that TCDD can bio-accumulate in algae, snails,

and fish (p.46), but attempts to negate this fact by stating that "a litera-
ture review reveals that accumulation in food-chain organisms has not been
observed to a significant degree in nature." It should be obvious that
research in this area is not far enough advanced that a literature review
can be considered reliable and conclusive evidence.

During the period when EPA is researching these chemicals to determine
if they are safe, we should proceed with the assumption that they are not
safe. Ignorance is not an acceptable justification for using potentially
hazardous chemicals. To continue using these herbicides under the assump-
tion that the future will show they have no effect could have tragic conse-
quences if the future shows this assumption to be wrong.

The proposal to continue use of phenoxy herbicides, and the other
inadequacies of this DEIS seem contrary to the change in USDA attitude
toward chemical uses expressed in Secretary Bergland's remarks to the
National Agricultural Chemicals Association last September. The Secretary
lamented the practice of using poorly tested chemicals and indicated the
need for change, saying,

C-102

Mr. Yurich - 5 - November 18, 1977

When they began being used heavily, we did not give enough
thought to the eventual consequences to the environment and to
people. Their side effects and their long-term impact were often
unknown or ignored.

But over the years we have learned that there are dangers.
Sometimes our learning has been painful.

Now we must adjust.

The producers and users of chemicals must adjust, and the
Department of Agriculture must adjust.

One such necessary adjustment on the part of the USDA is a decision not
to use the potentially harmful phenoxy herbicides.

The Secretary also quoted the draft statement on integrated pest
control which states that the USDA will “give special emphasis to the
development and use of alternative tactics in integrated pest management
systems." Vegetation management should receive the same consideration,
but unfortunately in this DEIS little attention is given to the use of
alternative tactics.

In summary, the Izaak Walton League urges the US Forest Service
to prepare an addendum to the DEIS, or rewrite the DEIS, to include the
types of information we have suggested here. Most important, this DEIS,
which serves as the base for the future USFS vegetation management pro-
gram in the eastern region, should clearly establish USFS policy on herbi-
cide use--a policy that should reflect the more environmentally concerned
approach recently advocated by Secretary Bergland.

Thank you for the opportunity to review this statement.
Sincerely,

Katha Barr

Kathy Barton
Environmental Assistant

C-103

#1

#2

#3

ie
#5

#6

Forest Service Response to Comments
by The Izaak Walton League of America

The Forest Service policy on pesticide-use management
is well documented in directives issued by the
Washington Office.

This type of information will be included in the site
specific EAR's prepared for each proposed use of
herbicide.

Public notification and involvement is part of the EAR
process and will be accomplished on an individual
project basis.

This aspect is beyond the scope of this statement.

The discussion of herbicides was modified in the Final
Statement. Site specific EAR's will discuss the
various alternatives available for vegetation
management.

The phenoxy herbicides are currently registered for

forestry use by the EPA and as such, should remain
available as an alternative.

C-104

Minnesota Herbicide Coalition

— For Integrated Brush-Control Management

MEMBER ORGANIZATIONS

Minnesota Environmental Control
Citizens Association
Don Covill Skinner, President

Clear Air-Clean Water, Unlimited
Rodney Loper, President

Virginia Sportsman's Club
Ervin G. Denzler

Minnesota Conservation Federation
Milton Pelletier

Friends of the Earth, Minnesota Chapter
Dana Mcdill

United Northern Sportsmen
Duluth, MN

Northern Environmental Council
Barbara Clark
Wildlife and Pesticide Task Force

Harriet Lykken

Marion Vertnik,
for the people of Britt, MN

Harmon Seaver Defense Fund
for the people of Cook County, MN

Mt. Iron Sportsman's Club

Twin Cities Coordinator:

Donna M. Waters
110506 Windmill Court
Chaska, MN 55318

November 26, 1977

MY pele Ves TULICH

Regional Forester

Forest Service USDA

633 West Wisconsin Avenue
MWwMilwaukee, Wisconsin 53203

Comments of the Minnezota Herbicide Coalition
on the draft environmental statement, “ihe
Use of Herbicides in the Eastern Region",
USDA - FS = R9 - DES - ADM - 77 - 10
september 19, 1977

In reviewing the adequacy of the draft environ-
mental statement (DES) I have referred to the
Rules and Regulations for Preparation of Envir-
onmental Impact Statements issued by the Pres-
ident's Council on Environmental Quality con-
tained in Volume 38, No. 147 (Wednesday, August 1,
1973) of the Federal Register (40 us F.R. Section
1500). Specifically Section 1500.2" (bie

Staves wnat:

ort particular, agencies should use the envir-
onmentel pepe. ae tement process to explore al-
ternative actio t will avoid or minimize
adverse impacts and to evaluate both the long-
and short-range implications of proposed actions
to man, his phys ical ana social surroundings,
and to nature". "...to restore environmental
quality as_well as to avoid or minimize undesir-
able consequences for the environment".

we feel that the use of herbicides in the
Chippewa and superior National Forests of liinn-
esota presents an unacceptable rick to human
health, that it endangers our wildlife and the
quality of our environment.

Phone: (612) 646-0559
C-105 or 448-4514

ES SSS

————

2s

SSS SSS

(#1)

UsS. Forest Service DES (Herbicides)
11-26-77
Page 2

Comments on specific herbicides:
orivex) and TCDD

The draft ES states on page 77, in the "Summary of
Probable Adverse Environmental Effects Which Cannot Be
Avoided",that: “The hazardous substance - 2,3,7,8 - tetra=
chloro dibenzo - p - dioxin (TCUD) is present in 2,4,5-T and
Serve. euetuUre Cul "i> repeortiy. the most toxic) synthetic
chemical known. In laboratory tests, both ICDD and 2,4,5-I
have demonstrated the biological potential for producing
teratogenic and mutagenic effects and an increased tumor incid-
ence. Risk to humans, while apparent, is not real, due to the
minute volume of TCDD applied per acre and the near absence of
human exposure to most treatment areas."

This last statement that the risk to humans, while ape
Potent. eloenOtercal...i¢.ciearly false. In. the, course, of a
trials lcitizens Azainst. Toxic. Sprays,-inc. Git Sil aN
Bergland, Civil No. 76-43 CO rec on etiorenae. LO/ 7) saat was
publicly revealed that 2,3,7,8-tetrachlorodibenzo-p-dioxin,
(TCDD), a contaminant of 2,4,5-T and Silvex, had been found in
human breast milk in areas of the United States which had pre-
viously received treatment with these herbicides. The labora-
tory of Dr. hhatthew weselson at Harvard University had identif-
ied TCDD in the fat portion of human breast milk ranging from
10 to 40 parts per trillion.

Ureeratvrick.Uheele stated.in his testimony.,(in CATS,
Inc., ve Bergland) that "TCDD has been found in 2 number of
‘environmental samples and the potential for the entry of higher
levels of TCDD intothe food chain exists, as a consequence of
forest burning operations." (p. 10). The TCDD which contamin-
ates the 2,4,5-T concentrates in the fat of animals and thereby
bioaccumulates up the food chain. TCDD residues have been
found in the fat of animals of prey (e.g. shrews, deer mice)
as well as herbivores (e.g. beef Pee Human beings, being
omnivores, can ingest TCDD residues in beef and the meet of
wild animals (e.g. deer) as well as in forest vegetation (e.g.
berries, mushrooms, herbs). Also, the TCDD contaminates water
used for drinking purposes. Human beings can also be exposed
to ICDD by the air drift of the herbicide during spray opera-
tions as well as the possibility of being directly sprayed due
to a faulty warning system. Besides the TCDD which is released
to the environment as a contaminant of the herbicide, there is
also the potential for the formation of TCDD at 10,000 times
the naturally occurring level due to burning of vegetation con-
taminated with 2,4,5-T, according to the testimony (in CATS case)
of Dr. George Streisinger of the University of Oregon. Ob-
viously, there are many potential routes of exposure that TCDD
so that it should come as no surprise that TCDD is being

C-106

(#2)

U.S. Forest Service DES (Herbicides)
11-26-77
Page 3

stored in human fat and then mobilized during lactation.

The conclusions which can be drawn from the analytic
data are clear: 1) there has been human exposure from the
use of 2,4,5-T in the past; 2) there is a very significant
risk to the health of nursing infants ingesting TCDD.

(2) 2,4-D

In the discussion of the effects of 2,4-D on man and
his environment the Forest Service has failed to mention
studies that have indicated biological concentration of 2,4-D
in aquatic organisms, Ecological’ Eifects of Pesticideson
Non-Target Species, a publication of the Executive Office of
the President's Office of Science and Technology, June 1971,
authored by David Pimental cited two such studies: "Esters
of 2,4-D accumulated in sunfish after exposure to sublethal
concentrations in both laboratory and field tests (Cope, 1965b),
and the fish sampled from a reservoir with 1 ppb showed an up-
take of 2,4-D to a maximum of 150 ppb (Smith and Isom, 1967)."

senator Edward Kennedy's Staff Report on The Environ-
mental Protection Agency and the Regulation of Pesticides,
December 1976, p. 15, cites a study performed by the FDA (Food
and Drug Administration) in 1963 and 1964. This study; "Path-
ological Changes in Rats Fed 2,4-Dichlorophenoxy Acetic Acid
for Two Years", was reviewed by an independent pathologist who
concluded that 2,4-D "is carcinogenic (cancer-causing) in rats."

In view of the studies (cited above) (indicating bio-
accumulation and carcinogenicity) and because of the findings
of 2,4-D in water, soil, and animal samples taken from the
Chippewa and Superior National Forest in ltinnesota during the
1977 Herbicide Spray Programs, (luonitoring Report, FY 1977
Aerial Herbicide Project, Chippews National Forest and Water
Quality Monitoring of the 1977 Aerial Herbicide Program, Super-
ior National Forest), we feel that the continued use of 2,4=D
presents an unreasonable risk to the populations of Minnesota
living in or near our national forests, endangers our wild-
life and degradates the quality of our forest environment. We
therefore recommend that the use of 2,4-D for conifer release
be discontinued.

Alternatives to Herbicides
iwanual release and the use of mechanical devices are

feasible alternatives to the use of herbicides for conifer
release. Both of these alternatives or a combination of the

C-107

(#3)

U.S. Forest Service DES (Herbicides)
11-26-77
Page 4

two would serve to create more jobs. These alternatives
would minimize undersirable adverse impacts and fullfill

the guidelines of the CEQ “to restore environmental auality as
well as to avoid or minimize undesirable consequences for the
environment". We feel certian that there are adeauate numbers
of unemployeed people in northeastern Minnesota willing to
work at physically demanding jobs such as manual conifer
release and that this would help the local economy. We are
also willing to work with the Forest Service to further this
alternative.

Currently, in Wisconsin, 300 acres in the Cheauamegon
National Forest are being released by manual methods on an
experimental basis to determine cost-effectiveness. The cost
is running $25 - $34. an acre depending on the terrain.

Conclusion

The Minnesota Herbicide Coalition feels that the use of
herbicides in the eastern region is ill-conceived and that
this practice presents an unreasonable risk to human health,
while endangering our wildlife and the environmental auality
of northern Minnesota. We feel that menual release and mech-
anical devices offer a feasible alternative to the use of herb-
icides while benefiting the local economy.

Donna Wi. mee

Coorginator,
Minnesota Herbicide Coalition

C-108

#1

#2

#3

Forest Service Response to Comments
by Minnesota Herbicide Coalition

Federal regulation agencies have the data from this
and similar studies and have not taken any regulatory
action on it. It would be inappropriate for us to
further restrict the use of 2,4,5-T on the basis of
the quoted study because of the uncertainty which
surrounds it.

Studies are currently under way by EPA to look for
TCDD in human milk. We will carefully watch for the
resolution of these issues.

The Environmental Protection Agency is constantly
evaluating test data pertaining to pesticides and has
the responsibility for determining if any unreasonable
adverse effects from their use will occur. It would
be inappropriate for the Forest Service to remove that
responsibility from EPA.

The Forest Service does consider manual release and
there are many instances in which manual release is
selected.

Although there may be many unemployed people capable

of doing manual release, past experiences in trying to
obtain this help has proved unrewarding.

c-109

The

Wilderness 1901 Pennsylvania Ave., N.W.. Washington, D.C. 20006 (202) 293-2732

society

November 18, 1977

Mr. Steve Yurich, Regional Forester
633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dear Mr. Yurich:

Man-made herbicides are deliberately introduced into the environment
as a killing agent to perform various beneficial functions. The use of
these herbicides for vegetation manipulation in National Forest activities
is of deep concern to members of the Wilderness Society. For your consideration,
we submit our thoughts pertaining to the use of herbicides in the Eastern Region
of the Forest Service, USDA, as proposed in the Draft Environmental Statement.

Public objection to herbicide use persists in being an issue due to
emerging data that supports the citizens' fears that the widespread use of
highly toxic chemicals causes serious problems for man and his environment.
When a citizen reads sentences such as the following found on pages 43 and

44 of the DEIS, he is wary of herbicide usace: "Some scientists have called
TCDD the most toxic chemical known to man"-; It is not known if TCDD is
mutagenic or carcinogenic as well".; "At this time, there is no basis for

concluding that humans are more or less sensitive to dioxins than are test
animals".

Throughout the DEIS it is stated that the herbicides will be managed and
stored in a manner which will safeguard public health and wildlife, prevent
damage to plants, prevent soil and water contamination, and used in accordance
with Federal, State or local laws and regulations. These stated assurances
do not allay the citizens' fears. The citizen knows that reaction to exposure
of harmful herbicides can include damage to skin, eyes, the central nervous
system, and the respiratory tract. Also, he knows that improper application
because of failure to follow instructions on herbicide labels or ignorance of
herbicide or pesticide hazards causes most of the incidents of illnesses.
Citizens will continue to object to the usage of toxic substances until it
can be conclusively proven that the substances do not harm man and his
environment.

Present studies and investigations of specific dioxins support the con-
tention that there is no reason to believe that proper use of 2,45-T by the
Forest Service will exert any toxic effect on the environment or man. While
we know immediate hazards of herbicide usage, we do not know enough about
long-range effects. Herbicides do not break down readily. They can remain
in the environment for long periods, and can move through the food chain by
the process of bioaccumulation. The replacement of the original set of an
animal population in a sprayed area by a different set with lesser diversity
also concerns us. It causes us to ask the questions: "Should use of vegetation
Management be allowed where it adversely affects even a minimal community of

“THE ORGANIZATION OF SPIRITED PEOPLE WHO WILL FIGHT FOR THE FREEDOM OF THE WILDERNESS.”
110 — Robert Marshall
gs

100% recycled paper

page 2

animals?"; and "Will the continued use of herbicides eventually cause unknown

‘

or long range depletion of wildlife species and their habitats"?

The unknown problems and impacts connected with the use of herbicides,
urge us to request that an accelerated and comprehensive research be conducted
by The U. S. Forest Service into biological control or biological evolution
of vegetation in the Eastern forests. We concur with the sentence in the
Introduction which says, "When alternative methods of vegetation management
are technologically available and economically feasible they will be preferred
over the use of herbicides". Please consider this sentence when you write the
Final Environmental Impact Statement and conduct annual reviews on the use of
herbicides in our National Forests.

The Society looks forward to reviewing and commenting on the F.E.I.S.

Sincerely,

, 2

Grace Pierce

C=LTi

(#1)

(#2)

(#3)

UNIVERSI I Y DEPARTMENT OF FORESTRY & NATURAL RESOURCES

Nevember 23, 1977

steve Yurich

Regional Forester

633 West Wisconsin Avenue
Milwaukee, Wisconsin 53203

PeeeeoOmmenl SOs. on fo." Environmental Statement. Draft: the
use of herbicides in the eastern region

Dear Mr.) Yurich:

Iieappears that this;drait. statement covers all. imaginable
Topics esomecimes, repetitiously. The attached copies of selected
pages have some indicated corrections; generally involve mis-
Spelled, Wisnamed Or cancelled products.

AdditLonalecomments as.tollows:

Page 36 - The last paragraph on this page precludes the use of
‘Mist aS a Viable foliage application technique. I would con-
iomiisoemictakem Oo arbitraraly rule outsa specific technique,
Taw ceri step tOWerotromathe eastern quarter Of the U.S. This
application technique has proved to be very effective in southern
forestry although some of the initial research was conducted in
the northeast. Although it is not used in the eastern region to
avec reateexLent agtathis time, there are-areas where it probably
SO mDesUSeCd se paliaculanly in the coniferous, forests in. the
DOGeMeCt Nepalis ot the region.

Pace, s/s- the discussion on soil treatment uses granules and
pelletsyas Synonymous terms when they are in fact distinctly
Ciscerentatypcecmot rOrmulacions inj the herbicide trade... The
Damoenepnealscoserc ers tG a tigure Z which,was never found. “The
Table 3 on this page also appears to go without any particular
discussion. I would prefer to see some elaboration on the nature
Oravienecgement activity and the type of herbicide used. The table
Breaks OUutsthe various. crowth regulator herbicides into distinct
categories and distinct acreages. The other herbicides are lumped
Pyeovoucins mOude.OLeaction: Category. Why apply organic arsenicals

ve a,
wat iS
I7 (= ® Forestry Building
~ > West Lafayette, Indiana 47907

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(#8)

Steve Yurich
Pacem
November 23, 1977

as a foliage treatment for ten. acres of forest, road, trait sang
facilities and 100 acres of range? I doubt that picloram will

be used as the pure product but rather in combination with phenoxy
herbicides. How do the picloram treated acres fit with the phenoxy
treated acres? Where or why treat 155 acres with mytotic poisons

for timber management and only 25 acres with soil applied inhibitors?
Do these uses cover plantation establishment? The table does not
define the actual uses or use situations of the herbicide program,
nor the herbicides involved.

Page 38 - The first paragraph indicates that’ 50°to 70 percenmeae
aerial applied herbicides are lost. ‘On page 41, citing the Gi.
Report, it is possible to deposit 97 tox99 percent ot the relezce
spray within the target area. With improper application it would
be possible to lose all of the aerially applied herbicide. I would
think it would be in your best interest to emphasize the degree of
accuracy possible with best available technology and equipment.

Page 41 - I do not understand the proposed concept of biological

volitalization discussed in the Second paragraph. 10 1s" diteveus.
to conceptualize the difference between biologicaljyoli¢aiizae

and regular volitalization.

Page 43 - The second paragraph discussing dioxins seems to be an
overstatement appearing to implicate all phenoxy herbicides as
being contaminated with dioxins.

Page 52 - The last paragraph states that undisturbed forest soils
tend to be acid, low in organic matter, have a cool temperature,
and are dry, all of which favors slow breakdown. I would suggest
emphasis on the humus layer and moist surface horizon which would
contribute to herbicide adsorption and rapid decomposition.

Page 54 - The first paragraph discussiny water lists fivesspoemese
herbicides. I think it would be in your best interest not to fine
yourselves specifically to these herbicides, particularly ser.
simazine 1S not.on the list. Secondly, it would appear) toe or
would preclude the use of new herbicides which could become regis-
tered in the future. The second paragraph im this semestop tom ooo
that any herbicide found in the waters of the eastern region forests
should be considered a contaminart. That statement suggests that
use of any herbicide for aquatic weed control is to, in effect,
contaminate the water. The water is alreacy ccntaminated with a
particular pest and the herbicide application is an effort to re-
move the undesired contaminant. I think it's an unnecessary
overstatement.

C-—11T3

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(#10)

Cees LAL. Ci
Page 3
November 23, 1977

Page 61 - The fourth paragraph discusses the ADI of picloram
for humans and the related calculations. The whole paragraph
is apparently referenced to Emmingham, 1971. Knowing Emmingham
BnUmtiemiatunesOLeniseMastem'=s work, that. citation is a.gross
and complete error. Someone should thoroughly check reference
citations throughout the report.

Presumably some editor will review the final draft statement to
see that figures and tables are properly referenced, are properly
titled and sequenced in keeping with the body of the report.
Although the completeness is apparently there, the statement does
need some final editorial dressing to enhance the overall
presentation.

Page 96 - I think some of the proposed controls on herbicide
UseearesOverly or unnecessarily stringent.

Raven cee no DLrOpOSa cul Olapestacide, use.on national forests

in the eastern region does not allow any ready outlet for
cooperative research efforts. Since almost all research efforts,
particularly those similar to what we would be involved in,
constitute the use of a pesticide in an unlabeled manner, these
guidelines require a pesticide use proposal to be reviewed by

the field Pesticide-Use Coordinating Committee with final approval
by the Regional forester. This policy does not make allowances
for small research plots and has effectively killed any research
effort that we would undertake on U. S. Forest Service lands.

To me this is an unfortunate example of overkill.

ee a

oo. tthe Oe eel 4

a

Harvey A, HOLT
AsSsQciate roiessor Of Forestry

HAH: ng
enclosures

CCow Mem mCaArTlenm, alead
Deni OLeLOLeS UGLY «Ge NACUTal Resources

CwiL4

in the plant, the leaves and buds become twisted and curled,
followed by malformed new growth of stems and leaves. Sensitive
young plants may die in a few days, while hardy shrubs and trees
may succumb only after weeks or months. Some plants may survive
without evident injury. The phenoxy herbicides appear to eater
plants in an imperfect and uncontrolled way, and alter the
growth process normally governed by the natural hormones.

The herbicide is interferes with cell division and

enlargement, food utilization, and a wide array of other

vital plant processes. Exactly how they work is not

known, and indeed the exact workings of natural plant

growth regulators are equally obscure. Phenoxy herbicides 4re
far more toxic to green plants than to animals, because the
elements that have growth regulating ability in plants do

not act the same way in animals.

Because their effect on the plant is “systemic” rather than

"contact," phenoxys are effective even when only part of the
plant is treated. As a result, low pressure and low volume

sprays can be used.

Effects on plant growth may be seen after doses far below the
lethal dose. This creates a potential problem with spray
drift to susceptible vegetation.

Some growth regulators are quite mobile in soil, others are
very stable.

With the exception of dicamba and picloram, phenoxy herbicides
have short half-lives and do not persist long in the soil.

All have low mammalian toxicity (Table 4). Dioxin contained in
2,4,5-T and 2,4,5-TP has a high mammalian toxicity.

yas Organic Arsenicals

MSMA (Monosodium methanearsonate)
Cacodylic acid
DSMA (Disodium methanearsonate)

These herbicicdes have low mammalian toxicity (Table 4), and
are translocated in both xylem and phloem.

i Photosynthetic Inhibitors

atraxine (AAtrex®)

simazine (Princep®)

monuron (Telvar®)

difuron (Karmex®) =~

linuron (Lorox®)

=

bromacil (Hyvar =)
The evolution of oxygen during photosynthesis is stopped rapidly
in susceptible plants once these agents have entered a
plant. In resistant plants, the effect on photosynthesis is
much less and is temporary.

Carl

They have no direct effect on root growth. All can be
absorbed by the roots and most are absorbed by leaves,
but leaf adsorption varies greatly between compounds.

All of them move primarily in the xylem. Therefore, perennials
are controlled only by root applications, not by foliage sprays.

When post-emergence sprays are used, thorough wetting of the
foliage is important, since there is little downward
translocation and the action is of a "contact" rather than
"systemic" type. Surfactants or oils are often added to
increase foliage action.

In general, these compounds are moderately to highly resistant
to movement in the soil, but this varies with the compound,
soil, and rainfall. Persistence in the soil varies from a few
weeks to over 2 years, depending on the herbicide, amount
applied, climate, and soil.

All have very low mammalian toxicity.
4. Mitotic Poisons

trifluralin (Treflan®)
DCPA (Dacthal®)
Sodium metaborate tetrahydrate (Ureabor®)

These stop the growth of roots and/or shoots of germinating
seeds or small seedlings. Established annuals and perennials
are killed in only a few special cases. These herbicides

are highly selective between species.

Translocation occurs primarily in the xylem and is often poor.
Therefore, they must be applied so they make contact with
susceptible parts of the plant.

All have low mammalian toxicity.

5. Soil-Applied Inhibitors of Seedling Root and/or Shoot Growth
Casoron
dichlobenil (

diphenamid (Dypméeé-® Enide@®) =>

—_—

Included in this category are several chemical groups, the
modes of action of which are not known. However, they are all
soil-applied herbicides that inhibit the growth of roots
and/or shoots of seedling plants. Some of them also inhibit
the buds of certain perennials. They all have low mammalian
toxicity.

6. Chlorophyll Inhibitors

amitrole

This herbicide is very soluble in water.

C-116

It is translocated in both xylem and phloem and moves
throughout the plant. It interferes with pigment formation ia
the leaves, and new growth becomes almost white. Amitrole
persists for several months in some perennial plants and new
buds produce white leaves.

It is not very selective.

Because it is rapidly inactivated in the soil, it is used
entirely as a foliage spray.

Acute mammalian toxicity is very low. However, it has been
reported to have carcinogenic properties; therefore it is
registered only for non-food crop uses.

Amizine® - A mixture of amitrole and simazine, it gives
residual weed control for several months besides controlling
the weeds present at time of spraying.

7. Free Radical Formation

diquat ‘(ig ast)
paraquat AS rah ‘ar ven

These are very saiaeta in water.

They are strong cations.

They enter the foliage very rapidly (rain after 30 minutes
does not affect results). Plants are killed quickly, usually
within 1 or 2 days. Death is due to cell membrane destruction.
Action is much more rapid in bright light than in weak light
or in the dark. Usually plants are killed so rapidly that
there is little translocation.

They show very little true selectively.

They are strongly absorbed by clay colloids and, therefore,
have little or no activity in the soil.

Mammalian toxicity is high for paraquat and moderate for diquat.
Fish toxicity is low for both.

8. Interfere With Protein Metabolism

dalapon (Dowpon®)
TCA

Very soluble in water.
Dalapon enters the plant either through the roots or foliage,
while TCA utilizes mainly the roots, However, action takes

place in the foliage in both cases.

Dalapon is translocated in both the xylem and phloem, while
TCA is mainly in the xylem.

C=P7,

Because of the characteristics listed above, dalapon is used
mainly for foliage sprays and TCA for soil applications.

They are not absorbed by soil colloids and leach readily in all
soils. Normal soil life is limited to a few weeks under warn,
Moist conditions. They are used primarily to control annual
and perennial grasses.

Very low mammalian toxicity.

9. Miscellaneous | y ?
$e. - SO Ke ;

alkanolamine salts CDNBP) fe > this C

pentachlorophenol

copper sulfate (Algacide)

stoddard solvent

potassium endothal (Algacide)

glyphosate (Roundup®)

ammonium sulfamate

monobor-chlorate

ammonium ethyl carbamayl phosphonate (Krenite®)

Glyphosate (Roundup®) - A herbicide that shows a great deal of
promise for grass and weed control in forest plantations. It is
applied to the foliage and kills annual plants as well as many
perennials. It is translocated readily and has very little
activity in the soil. Mammalian toxicity is very low.

Krenite® - Absorbed by the foliage and stems, it causes
little, if any, visible effect on the foliage. This
herbicide prevents refoliation the following spring. It is
neither an eye irritant nor a skin sensitizer. And, it is
readily absorbed by soil particles and decomposed quickly
by soil microorganisms. It has very low mammalian toxicity.

Pentachlorophenol - This herbicide has high mammalian
toxicity. It does not translocate, but kills by contact
action.

Stoddard solvent - It causes very rapid destruction of the
plant cell membrane.

METHODS OF APPLICATION

In order to be effective, a herbicide must enter the plant and
move to the site of action. Entry may be through various

parts of the plant: leaves, roots, seedling shoot before
emergence, or above-ground stem. Entry may also be forced, as
when the cut-surface method of application is used.

Penetrating agents or penetrants may be added to the herbicide
to improve its penetration of the plant foliage or stem surface.
Before a herbicide can enter the foliage, the cuticle or wax
surface must be penetrated. Some entry may take place

through the stomata on the under side of the leaf.

C-118

control of aquatic weeds where herbicides or algacides are
introduced into the water through a boat bailer or surface

spray.

4. Soil Treatment - This involves application of a herbicide,
liquid or granular in form, to the soil. Granules are a
“/ type-of formulation in-which the active ingredient is mixed
and preseed-with—an_inert carrier to form a small pellet
_that can be distributed on the sott.~ As the granules slowly
decompose, the herbicide is released into the soil. Other
soil treatments with liquids act as soil sterilants, and
when in or on the soil, prevent the growth of

®Rigeres are in seres treated.
eelncledes sanusi serial sprey pregras of 7, 000-9,008 ecres.

II. ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION

This section is an analysis of both the anticipated favorable and
possibly adverse impacts of herbicide use in the Eastern Region, as they
may affect the local, regional, national, and international environment.
The environment, in this case, includes not only the natural environment,
but the social and economic environment as well.

Planned measures to minimize and mitigate adverse environmental impacts
of herbicide use, including specifications and standards necessary to
maintain and protect environmental quality, are found in Appendix A under
Controls on Herbicide Use.

C-119

UNIVERSI I Y DEPARTMENT OF FORESTRY & NATURAL RESOURCES

November 17, 1977
Mr. Steve Yurich
Regional Forester- Eastern Region
Forest Service, USDA
630 W. Wisconsin Avenue
Milwaukee, Wisconsin 53203

Dear Steve:

| appreciate the opportunity to review your draft environ-
mental statement on the use of herbicides in the Eastern Region.
| apologize for being so late in my response, but | find that every-
thing | do these days is at, or beyond, the deadline.

| believe your environmental statement is well written and
thorough in the scope of its' coverage. However, | believe the
Statement could be strengthened by a more specific discussion of
the benefit-cost ratios. On a number of occasions | have been in-
volved with groups preparing statements concerning the use of herbi-
cides in forestry. Uniformly, these statements are lacking in con-
cise descriptions of the economic impact on timber production and
the wood-based industry if currently used herbicides were not avail-
able. At several points in your statement (e.g., page 21, page 26,
page 29, page 137, page 138), valuable data is presented on the econ-
omic impact. However, I would suggest that this type of information
be expanded and summarized for the entire Region.

For example, in the appendix B, the Nicolet report indicates
that conversion of aspen or northern hardwoods to pine or spruce
plantations, followed by release using herbicides, can increase the
per acre value of the saw timber and pulpwood produced by $2,500 or
more. But there is no indication of the total number of acres in the
Nicolet National Forest scheduled for this treatment. | would like
to see a summary of the total benefits to be derived from timber man-
agement goals on each of the eastern national forests, the economic
impact of achieving or not achieving these goals, and the costs of
achieving these goals with and without herbicides. To this summary
could be added the non-timber goals and the cost of achieving these
goals with or without herbicides.

| realize the difficulties involved with preparing summaries

of the type | am suggesting. | suspect that many of our eastern
UE &,
oo 2,
I) (= ® Forestry Building
o ~ Bd West Lafayette, Indiana 47907
eo”

C=120

Mr. Steve Yurich
November 17, 1977

page 2 -

forests are in the process of re-drafting their long-range man-
agement plans in view of the new Forest Management Act. How can
one calculate the benefit-cost ratio for the use of herbicides in
type conversion before plans have been finalized on the extent of
type conversion to be achieved? But | believe that a decision wil]
have to be made by the Executive branch or the Congress in the near
future concerning the use of herbicides on both public and private
land. | fear that these decision makers may be forced to act with-
out the benefit of a full and complete assessment of the economic
impact of their decision.

Yours truly,

( Gg
Viper

Magon C. Carter
Professor and Head of Department

MCC:jh

C-121

#1

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Forest Service Response to Comments
by Purdue University-Department of Forestry
and Natural Resources
The reference to aerosols and mists was deleted.
Figure reference was corrected.
The elaboration of Table 1 will be handled on an
individual Forest basis through the use of

environmental analysis reports.

Paragraph was changed to reflect more current
information.

Confusing sentences were deleted.
This section was completely rewritten.
Original paragraph was unchanged.

The points brought out were clarified in the Final
Statement.

This entire section was rewritten and references
checked.

These controls were developed to mitigate adverse
environmental effects and we feel they are entirely
workable in the field.

We disagree! Research has not been "killed." The
pesticide-use proposal is not that difficult to
complete and could simply become a part of the
research proposal.

C-122

CON’ S'O' Tiel DAS iD) Eee ere hee ene

TIMBERLANDS OFFICE:
WISCONSIN RAPIDS, WIS. 54434
November 3, 1977 ry 0 429-3144 / 422-3267

Mr. Steve Yurich,
Regional Forester

633 West Wisconsin Avenue
Milwaukee, WI 53203

Dear Mew Vuc@ehis

I would like to comment on the Draft Environmental Impact Statement concerning
the Use of Herbicides in the Eastern Region of the Forest Service.

Our company owns and manages the forests on approximately 244,000 acres in
Wisconsin. We are within a continuing program to regenerate nonproductive land
and to increase the productivity of low productive land. To do this, we are
converting low productive hardwood sites, marginal aspen sites, and brush areas
to pine sites and plantations, primarily red pine but also jack pine. Because
of root sprouts, stump sprouts, and seeding in of deciduous species, a large
majority of our newly established plantations require at least one release
treatment to ensure that the pine will not be suppressed. We believe that
phenoxy herbicides properly applied is the most efficient and economical method
available to us. Most of our herbicide treatment work is done by aerial appli-
cation or backpack mist blowers, but we also do some basal spray application
work.

I would like to support the contents of the Draft Environmental Impact
Statement. The only exception that I have is that application of phenoxy her-
bicides in a mist form using backpack mist blowers is not considered. We be-
lieve that application of phenoxy herbicides using backpack mist blowers will
cause no environmental harm when applied under controlled conditions. Using
backpack mist blowers allows us to treat small areas and perimeters that can-
not be aerially treated or ground sprayed.

Thank you for this opportunity to comment.
Yours very truly,

CONSOLIDATED PAPERS, INC.

{ : 1
Ce bees
0 fiat ee nen lek

D.G. Hartman

C-123

Ts; TSI COMPANY
P.O. BOX 151
25 IRONIA ROAD
FLANDERS, NEW JERSEY 07836
(201) 584-3417

December 9, 1977

Steve Yurich
633 West Wisconsin Ave.
Milwaukee, Wisce 53203

Dear Mr. Yurich:

I have reviewed the "draft" Environmental Statement on
the use of herbicides in the USFS Eastern Region. I know that
the deadline is past and I appologize for not responding sooner.
Regardless, I would like to call your attention to the fact
that EPA requires that herbicides be labelled for specific for-
estry applications. This means that the product cannot legally
be used in forestry applications unless labelled for that pur-
posee

On page 59, the report lists various herbicides, some of
which are not legal to use because of lack of specific instruc-
tions for forestry use on their labels.

For example, Ansar, Daconate and Phytar 560 are all illegal
to use because of lack of forestry instructions on the labels.
I have enclosed the proper forestry labels for MSMA and Cacodylic
Acid. as far as I know, SILVISAR is the only brand of the above
active ingrédiiess formulated and labelled specifically for for-
estry use.

It might be wise to check your entire list with regard to
the above because I know of several instances where field work
was curtailed because of use of improperly labelled herbicides.

Pod

i ; Sy we

a

Sy i

Robert We Smith
General Manager

RWS/cls

Enclosures

C-124

AUFACTURERS AND DISTRIBUTORS OF QUALITY EQUIPMENT & CHEMICALS FOR FORESTRY & ENVIRONMENTAL SCIENCES

¥ U.S. GOVERNMENT PRINTING OFFICE: 1978—753-839

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