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United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Washington, D.C. 20240
http://www.blm.gov
JAN 1 3 2016
Dear Reader,
Enclosed for your review and comment is the Final Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and Rimsulfuron on Bureau of Land Management Lands in 1 7 Western States
Programmatic Environmental Impact Statement (PEIS). This document contains the
assessment, at a national scale, of the use of the active ingredients aminopyralid, fluroxypyr, and
rimsulfuron in Bureau of Land Management (BLM) vegetation treatments on public lands in the
western United States, including Alaska.
The draft PEIS was released on June 19, 2015, for which the public comment period closed on
August 3, 2015. The BLM received a total of 98 comments on the draft PEIS. The enclosed
final PEIS addresses each of those comments through either a comment response, or changes in
the analysis or supporting documentation.
The final PEIS assesses 3 alternative approaches to the use of aminopyralid, fluroxypyr, and/or
rimsulfuron to treat vegetation on public lands, as well as a “No Action” alternative that
considers the continued use of 18 previously approved herbicides. The final PEIS details the
expected impacts and benefits from the BLM’s use of herbicides, and provides analysis to
determine which herbicides should be approved for use.
The Final PEIS and associated documents will be available for public inspection at all BLM
State, District, and Field office public rooms. You can also review or download the document
from the BLM website at httn://blm. gov/3 vkd. The BLM will not issue a final decision on the
proposal until at least 30 days after the date that the Environmental Protection Agency publishes
its Notice of Availability in the Federal Register. A Record of Decision will then be issued, or a
supplemental analysis will be undertaken to address any significant information not previously
considered within the scope of analysis contained in the Final PEIS.
For further information, please contact Gina Ramos, PEIS Project Manager, at (202) 912-7226.
She can also be reached by email at blm wo vegeis@blm.gov, by fax via (202) 623-3793, or by
mail at 1849 C Street NW (Rm 2134 LM, WO-220), Washington, DC 20240.
Sincerely,
Michael H. Tupper
Acting Assistant Director
Resources and Planning
ITEM HAS BEEN DIGITIZED
IT)- Uo}Z\H
/
FINAL
PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT
VEGETATION TREATMENTS USING AMINOPYRALID,
FLUROXYPYR, AND RIMSULFURON ON BUREAU OF LAND
MANAGEMENT LANDS IN 17 WESTERN STATES
( ) DRAFT
LEAD AGENCY:
PROJECT LOCATION:
COMMENTS ON THIS FINAL PROGRAMMATIC
EIS SHOULD BE DIRECTED TO:
DATE BY WHICH COMMENTS ON THE EIS MUST
BE POSTMARKED TO THE BLM:
(X) FINAL
U.S. Department of the Interior
Bureau of Land Management
Washington Office, Washington, D.C.
Alaska, Arizona, California, Colorado, Idaho, Montana,
Nebraska, Nevada, New Mexico, North Dakota, Oklahoma,
Oregon, Texas, South Dakota, Utah, Washington, and
Wyoming
Ms. Gina Ramos
PEIS Project Manager
Bureau of Land Management
1849 C Street, NW Rm 2134 LM, WO-220
Washington, DC 20240
(206) 623-3793-FAX
Email: blm wo vegeis@blm.gov
30 Days after Publication of the EIS Notice of Availability
in the Federal Register
ABSTRACT
This Final Programmatic Environmental Impact Statement (PEIS) analyzes the potential direct, indirect, and cumulative
impacts associated with the Bureau of Land Management’s (BLM’s) use of the herbicides aminopyralid, fluroxypyr, and
rimsulfuron on the human and natural environment. These three herbicides would be added to the BLM’s list of
approved active ingredients and integrated into the vegetation management program that was analyzed in an earlier PEIS
released in 2007. Alternatives analyzed in the PEIS include the No Action Alternative, or a continuation of use of 1 8
currently approved herbicides. In addition, three action alternatives were evaluated: 1) the Preferred Alternative, which
would allow the BLM to use aminopyralid, fluroxypyr, and rimsulfuron in addition to the currently approved herbicides;
2) an alternative that would prohibit aerial spraying of the three new herbicides; and 3) an alternative that would only
allow the BLM to add the two new herbicides without acetolactate synthase-inhibiting active ingredients (aminopyralid
and fluroxypyr). Under all alternatives (including the No Action Alternative), projected maximum total use of herbicides
would be the same, at 932,000 acres annually.
RESPONSIBLE OFFICIAL FOR PEIS:
Steven A. Ellis
Deputy Director, Operations
Bureau of Land Management
ITEM HAS BEEN DIGITIZED
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EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
Proposed Action and Purpose and
Need
The Bureau of Land Management (BLM), an agency of
the U.S. Department of the Interior (USDOI),
administers vegetation on approximately 247 million
acres (public lands) in 17 states in the western U.S.,
including Alaska. Management of vegetation on public
lands, including habitat enhancement and management
to reduce the risk of wildfires, is an important function
of this agency. One of the BLM’s highest priorities is to
promote ecosystem health, and one of the greatest
obstacles to achieving this goal is the rapid expansion of
invasive plants across public lands. If not eradicated or
managed, invasive plants can jeopardize the health of
public lands and the activities that occur on them.
Herbicides are one method employed by the BLM to
manage these plants.
The BLM is proposing to add the herbicides
aminopyralid, fluroxypyr, and rimsulfuron to its list of
approved active ingredients for use on public lands.
These herbicides have been selected based on their
effectiveness at controlling invasive plant species and
their suitability for the BLM’s treatment needs. The new
herbicides would be integrated into the herbicide
treatment activities that were assessed in the Vegetation
Treatments Using Herbicides on Bureau of Land
Management Land in 1 7 Western States Programmatic
Environmental Impact Statement (2007 PEIS). The
Record of Decision (ROD) for the 2007 PEIS allows the
BLM to use 18 herbicide active ingredients for a full
range of vegetation treatments in 17 western states.
Therefore, the proposed action would increase the
number of herbicide active ingredients available to the
BLM from 18 to 21.
Proposed treatments using aminopyralid, fluroxypyr,
and rimsulfuron would occur on public lands in the
western U.S., subject to the restrictions on the
individual label of the associated formulation of each
active ingredient. Components of site-specific treatment
programs, including herbicide application methods
utilized, acres treated, and treatment locations, would be
determined at the local level and by Congressional
direction and funding. While the ROD for the 2007
PEIS makes no decisions regarding the number of acres
that can be treated using herbicides, the maximum
treatment acreage assumed in the 2007 PEIS — 932,000
acres annually — is being carried over to this action.
The need for the proposed action is the ongoing spread
of noxious weeds and other invasive plants, which
degrade the health of public lands and affect resources
such as wildlife, native plant communities, threatened
and endangered species, soil, water, and recreation.
Some invasive vegetation acts as a hazardous fine fuel
and contributes to the frequency, extent, and severity of
wildfires. The BLM requires effective tools for control
of invasive plants in order to prevent their spread into
non-infested areas, restore desirable vegetation in
degraded areas, and reduce wildfire risk. In particular,
the BLM has identified the need for additional herbicide
active ingredients that: 1) have less environmental and
human health impacts than some of the currently
approved herbicides (e.g., picloram); 2) increase options
for management of invasive annual grasses; and 3)
address potential herbicide resistance by certain species
(e.g., kochia, marestail, and pigweed) to active
ingredients currently used by the BLM.
The purpose of the proposed action is to improve the
effectiveness of the BLM’s vegetation management
program by allowing herbicide treatments with
aminopyralid, fluroxypyr, and rimsulfuron. This action,
by increasing the number of active ingredients, would
give the BLM increased flexibility and options when
designing on-the-ground herbicide treatments.
Herbicide Active Ingredients
Evaluated
The three new herbicides that the BLM proposes to use
are registered and available for use by the general
public. Aminopyralid, fluroxypyr, and rimsulfuron have
been deemed effective in managing target vegetation,
have minimal effects on the environment and human
health if used properly, and are registered with the U.S.
Environmental Protection Agency (USEPA).
All three of the new active ingredients would be used to
help reduce the spread of noxious weeds and other
invasive plants to reduce the buildup of hazardous fuels
and risk of wildfire; reduce the loss of wildlife habitat;
help stabilize and rehabilitate sites impacted by fire; and
restore native plant communities.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
ES-1
January 2016
EXECUTIVE SUMMARY
Aniinopyralid
Aminopyralid, primarily used for the management of
broadleaf weeds, is a selective herbicide that is used to
manage invasive annual, biennial, and perennial
herbaceous species, along with woody species. Target
plants include, but are not limited to: Russian
knapweed, musk thistle, spotted knapweed, yellow
starthistle, Russian thistle, and tansy ragwort. These
noxious weeds displace native plant species.
Aminopyralid is registered under the USEPA’s reduced
risk initiative. It may be used instead of picloram in
certain situations. Although not currently registered for
aquatic use, it is likely that aminopyralid will receive an
aquatic registration in the near future that would allow
for incidental overspray of this herbicide during
treatment of vegetation within close proximity to
wetland and riparian areas.
Fluroxypyr
Fluroxypyr is a selective herbicide that is used to
manage certain annual and perennial weeds, including
broadleaf species that are resistant to sulfonylurea
herbicides, such as annual kochia. It can be used to
manage invasive plants while maintaining native
rangeland grass species, and can be tank-mixed with
other active ingredients to improve its ability to manage
difficult-to-control weeds such as invasive pricklypear
cactus. Other weeds targeted by fluroxypyr include
marestail and black henbane. The use of fluroxypyr can
reduce the amount of other herbicide products used in
treatments.
Rimsulfuron
Rimsulfuron is a selective, acetolactate synthase-
inhibiting active ingredient that targets, among other
species, annual grasses such as cheatgrass (downy
brome) and medusahead rye. Rimsulfuron has been
observed to be more effective than imazapic in certain
areas and under certain conditions.
Alternative Proposals
Four program alternatives were developed for and
evaluated in this PEIS, including the Preferred
Alternative and the No Action Alternative. These
alternatives were developed based on the alternatives
presented in the 2007 PEIS. They address many of the
concerns that were raised during scoping for the 2007
PEIS, as well as concerns raised during scoping for this
PEIS. Alternatives were also developed to ensure that
the BLM complies with federal, tribal, state, and local
regulations. Under all alternatives, the goals of
herbicide treatments would continue to be to reduce the
risk of wildfire and to improve ecosystem health.
Alternative A - Continue Present
Herbicide Use (No Action Alternative)
Under this alternative, the BLM would continue to treat
up to 932,000 acres using herbicides annually. Only the
18 active ingredients approved in the ROD for the 2007
PEIS would be available for use by the BLM in its
vegetation treatment programs. The most widely used
herbicides would be clopyralid, glyphosate, imazapic,
tebuthiuron, and triclopyr.
Alternative B - Allow for Use of Three
New Herbicides in 17 Western States
(Preferred Alternative)
This alternative would allow the BLM to expand its
vegetation management program by permitting the use
of aminopyralid, fluroxypyr, and rimsulfuron, in
addition to the 1 8 currently approved active ingredients.
Therefore, a total of 21 active ingredients would be
available for use. Herbicide treatments would continue
to occur on up to 932,000 acres annually. It is estimated
that aminopyralid would make up 10 percent,
fluroxypyr would make up 1 percent, and rimsulfuron
would make up 1 6 percent of the total herbicide use on
BLM-administered lands. Use of other herbicides is
expected to decrease, particularly glyphosate, imazapic,
and picloram.
Alternative C - No Aerial Application
of New Herbicides
Alternative C would allow the BLM to expand its
vegetation management programs to include the use of
aminopyralid, fluroxypyr, and rimsulfuron; however,
the three new herbicides could only be applied using
ground-based methods. Aerial application (by helicopter
or fixed-wing aircraft) would not be allowed. With the
addition of three new active ingredients, a total of 21
active ingredients would be available for use. Herbicide
treatments would continue to occur on up to 932,000
acres annually. It is estimated that under Alternative C
aminopyralid would make up 6 percent, fluroxypyr
would make up less than 1 percent, and rimsulfuron
would make up 3 percent of the total projected herbicide
use on BLM-administered lands. Use of other
herbicides would decrease — particularly glyphosate and
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
ES-2
January 2016
EXECUTIVE SUMMARY
imazapic — although not as much as under Alternative
B.
Alternative D - No Use of New
Acetolactate Synthase-Inhibiting
Active Ingredients (No Rimsulfuron)
This alternative would allow the BLM to expand its
vegetation management program to include only the
two new herbicide active ingredients that do not belong
to the sulfonylurea, or the acetolactate synthase-
inhibiting, group of herbicide active ingredients.
Aminopyralid and fluroxypyr would be approved for
use, but rimsulfuron would not. With the addition of
two new active ingredients, a total of 20 active
ingredients would be available for use. Herbicide
treatments would continue to occur on up to 932,000
acres annually. It is estimated that under Alternative C,
aminopyralid would make up 10 percent of the total
projected herbicide use on BLM-administered lands,
and fluroxypyr would make up 1 percent of the total
herbicide use.
Direct and Indirect Impacts
In general, potential direct and indirect adverse impacts
and benefits would be similar under all of the
alternatives. Treatment goals would be the same, and
herbicides would be used on roughly the same land
area, under all of the alternatives. The small differences
among the alternatives would pertain to the relative use
of the various active ingredients and the efficacy of
treatments based on which active ingredients would be
available for use. As aminopyralid, fluroxypyr, and
rimsulfuron are of lower toxicity than some of the
herbicides currently used by the BLM, toxicological
risks associated with herbicide treatments would be
lower under the action alternatives, particularly
Alternatives B and C.
Impacts from herbicide treatments on local and regional
air quality would be minor for all alternatives. Air
quality emissions are largely based on acres treated,
which would be the same under all the alternatives
(including the No Action Alternative). Emissions of
criteria pollutants would occur at levels that correspond
to minor, short-term impacts to regional air quality.
None of the treatments would result in emissions that
exceed Prevention of Significant Deterioration
thresholds or National Ambient Air Quality Standards.
Greenhouse gas emissions would occur under all
alternatives, at a fraction of a percent of the total
greenhouse gas emissions for the western U.S.
However, reductions in wildfire risk associated with
herbicide treatments would result in an indirect
reduction in greenhouse gas emissions.
Under all alternatives, impacts to soil would continue to
be low. There is no evidence that the currently approved
herbicides or new herbicides proposed for use result in
significant adverse impacts to soil. Treatments would
benefit soil by restoring natural fire regimes and
slowing the spread of invasive plants, which should
reduce soil erosion and improve soil productivity. Some
treated lands could show a temporary increase in
erosion as the target vegetation is killed, followed by an
overall reduction in erosion as native vegetation that has
more extensive root systems or year-round cover
becomes established. Under all alternatives, herbicide
use would continue to improve watershed function and
water quality by reducing the risk of fire and post-fire
sedimentation, and potentially contributing to
stabilization of soils and a return to normal fire cycles.
Like the currently approved herbicides, the new
herbicides pose risks to vegetation. All three of the new
herbicides could adversely impact non-target
vegetation. Accidental spills and herbicide drift from
treatment areas could be particularly damaging to non¬
target vegetation, and treatment design would need to
consider special status species and populations. Buffer
zones would be used to reduce the risks to vegetation
from herbicide treatments under all alternatives. Long¬
term benefits could include a reduction in the spread of
invasive plant species and a reduction in the risk of
future wildfire in areas where the fire cycle is limiting
the ability of native vegetation to establish. Under the
action alternatives, the efficacy of some herbicide
treatments could be improved through use of the new
active ingredients, which may be more effective at
managing target species than currently approved
herbicides, and may improve control of populations of
invasive plant species that have developed a resistance
to currently approved herbicides.
Under all of the alternatives, herbicide treatments would
continue to pose risks to fish and wildlife. Herbicides
have the potential to kill or harm animals, or affect their
health and behavior, through exposures such as direct
spray, accidental spill, or ingestion of treated food
items. Damage to non-target plants from herbicide use
could adversely impact habitats used by fish and
wildlife. Aminopyralid, fluroxypyr, and rimsulfuron
have no to very low risk to fish and wildlife. In some
circumstances they would be used instead of currently
approved active ingredients with a greater risk.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
ES-3
January 2016
EXECUTIVE SUMMARY
Therefore, overall toxicological risks to fish and wildlife
could be lower under the action alternatives
(particularly Alternatives B and C) than under the No
Action Alternative.
Under all alternatives, buffers would be used between
aquatic habitats and treatments involving terrestrial
herbicides to reduce risks to aquatic organisms1.
Appropriate buffers would also be used between
treatment areas and habitats of special status species.
Vegetation treatments would adhere to the most recent
guidance for special status species, including land use
plan decisions for sage-grouse as amended by pertinent
sage-grouse EISs, and interim management direction as
outlined in Instruction Memorandum 2012-043
{Greater Sage-Grouse Interim Management Policies
and Procedures). Long-term beneficial effects to fish
and wildlife habitat through ecosystem enhancement
and reduction in wildfire risk would be similar under all
alternatives.
Herbicides would continue to have some risk for
toxicological effects to livestock and wild horses and
burros that graze in treated rangelands. These animals
could be exposed to herbicides by an accidental spill,
direct spray, herbicide drift, or by consuming herbicide-
treated vegetation. The three new herbicides are of less
toxicological risk to animals than some of the herbicides
used now, which would likely decrease in usage under
the action alternatives. Beneficial effects, which would
include improvements to rangeland condition and the
quality of forage, would be similar under all
alternatives.
Under all alternatives, herbicide treatments could affect
cultural or paleontological resources near or on the
surface, but would be more likely to affect traditional
cultural practices of gathering plants and the health of
Native peoples. Cultural and paleontological resources
could be impacted by equipment, and to a lesser extent
by the chemicals in herbicides. Based on the results of a
human health risk assessment, aminopyralid,
fluroxypyr, and rimsulfuron have no to low risks to
human health, and have less risk to human health than
some of the currently approved herbicides. However,
the herbicides that would decrease in usage under the
action alternatives also have no to low human health
risks. Standard operating procedures would help prevent
1 It is likely that aminopyralid will receive an aquatic
registration in the near future. If so, buffers associated with
its use near aquatic habitats could be reduced.
exposures of Native peoples to herbicides. Therefore,
risks would be similar under all of the alternatives.
Herbicide treatments could affect visual, wilderness,
and recreation resources under all alternatives. The level
of these effects would be similar under all the
alternatives. Treatments would remove and discolor
vegetation, making it less visually appealing. Over the
long term, landscapes should be more appealing as
native vegetation is restored. Treatments in wilderness
and other special areas would detract from the
“naturalness” of the area. Although use of mechanical
equipment would be strongly discouraged in these
areas, even limited use would create noise and reduce
the wilderness experience, and would need to be
authorized based on further site-specific analysis.
Recreationists could be exposed to herbicides or
experience less visually-appealing landscapes. In
addition, recreational areas could be closed for short
periods of time after application to protect the health of
visitors. Over the long term, herbicide treatments would
be expected to benefit visual resources, wilderness, and
recreation by helping to restore native plant
communities and reducing the risk of wildfire. The
degree of benefits from treatments would be similar
under all the alternatives.
Under all alternatives, social effects would be minor at "
the scale addressed in this PEIS. Herbicide treatment
programs would continue to benefit communities that
supply workers, materials, or services in support of
treatment activities. Some businesses, such as
recreation-based businesses and ranching operations,
could be adversely affected if treatments were to result
in the closure of areas used for recreation or by
domestic livestock for extended periods. There are
potential environmental justice concerns because a large
number of Native peoples and other minority groups
live in the West and work in or visit public lands that
may be treated with herbicides. The alternatives vary
slightly in terms of how much the BLM would spend
per herbicide treatment acre. These costs would be only
slightly lower under the action alternatives than under
the No Action Alternative, and would be lowest under
Alternative B.
Based on human health risk assessments, there would
be risks to humans (workers and the public) from
exposure to herbicides. These risks would be similar
under all the alternatives. The three new herbicides have
no to very low risk to human health (with an
unacceptable risk only predicted for one accidental
exposure scenario involving rimsulfuron). All
alternatives would be associated with a similar degree
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
ES-4
January 2016
EXECUTIVE SUMMARY
of benefit to human health associated with management
of invasive plants and reduction in wildfire risk.
Cumulative Impacts
The cumulative effects analysis for the 2007 PEIS was
for the BLM’s larger herbicide treatment program, and
is applicable to future treatments with the new active
ingredients. Addition of the new herbicides would result
in an increase in the number of active ingredients being
used on BLM lands.
Herbicide treatments contribute only minor amounts of
pollutants to the air, and would reduce the abundance of
fire-prone fuels and therefore emissions associated with
wildfire, resulting in fewer pollutants accumulating than
would occur without treatments. Treatments would
contribute to short-term loss of soil functions, process,
and productivity, which would be offset by watershed-
level restoration treatments. Water quality and
hydrology in the western U.S. have been impacted by
various human activities, and pollutants have been
documented in surface water and groundwater
resources. Use of the new herbicides would increase the
number of potential pollutants used by the BLM,
although use of herbicides with a greater risk to water
resources would likely decrease as a result of
availability of the new active ingredients. Treatments
that reduce risk of wildfire and that aim to improve
riparian habitats would benefit water resources on and
near public lands. Treatments would improve wetland
and riparian area functions and values and would slow
erosion, which contributes to wetland degradation on
public lands. With improvement in these areas, habitat
for fish and other aquatic organisms would also
improve.
Increased fire frequency and the spread of invasive
plants have altered plant communities and fire regime
condition class on public land and have led to a
cumulative loss of productivity. Herbicide treatments
would control invasive plants, and repeated treatments
followed by restoration would improve the condition of
plant communities and ecosystem processes.
Improvement in vegetation characteristics would benefit
wildlife. Some species that have adapted to degraded
ecosystems could lose habitat as a result of restoring
native plant communities, but most species would
benefit. Factors that have led to the loss of native
vegetation and ecosystem health have adversely
impacted rangelands used by domestic livestock and
wild horses and burros. Treatments would improve
rangelands for these animals, and increase the capacity
for public lands to support viable populations of
livestock and wild horses and burros.
Treatments could add to the cumulative loss of
paleontological and cultural resources, but risks would
be low. Treatments could impact plants used by Native
peoples for traditional lifeway uses, and the health of
Native peoples. However, the BLM would conduct pre¬
treatment surveys to identify areas of cultural concern
before conducting treatments to reduce the cumulative
loss of these values.
Treatments would result in some short-term and
temporary loss of visual, recreational, and wilderness
and other special area values due to vegetation being
killed or discolored. In some cases, areas might be
closed to visitors during and after treatments; however,
these impacts would be short-term and any values
affected would be restored within two growing seasons
in most cases.
Treatments would benefit local communities by
providing jobs and income, and by reducing the risk of
wildfire that could harm people and destroy property.
These gains would be minor in the context of the
western economy, but would still be a cumulative
benefit for many rural communities.
Treatments could harm the health of workers and the
public. Most herbicides, however, would pose few risks
to workers, and even fewer risks to the public, when
applied at the typical application rate and in accordance
with the label directions. New herbicides proposed for
use pose no to very low risk to humans. If treatments
restored natural fire regimes, reduced the risk of fire,
and slowed the spread of invasive plants, human health
would benefit.
Treatments could result in short-term loss of some
resources, including, but not limited to, soil, vegetation,
wildlife, and livestock forage opportunities. Over the
long term, loss of resource values would be slowed, and
in some cases, would be reversed. Short-term losses in
resource functions would be compensated for by long¬
term gains in ecosystem health.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
ES-5
January 2016
f
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TABLE OF CONTENTS AND LISTS OF
TABLES, FIGURES, AND MAPS
TABLE OF CONTENTS
TABLE OF CONTENTS
Page
Chapter 1. Proposed Action and Purpose and Need . 1-1
Introduction . 1-1
Proposed Action . 1-1
Purpose and Need for the Proposed Action . 1 -2
Scope of Analysis and Decisions to Be Made . 1-2
Study Area and Scope of Analysis . 1-2
Decisions to be Made . 1 -3
Documents that Influence the Scope of the PEIS . 1-3
Relationship to Statutes, Regulations, and Policies . 1-3
NEPA Requirements of the Program . 1 -4
Interrelationships and Coordination with Agencies . 1-4
National Level Coordination . 1-4
State and County Level Coordination . 1 -5
Non-governmental Organizations . 1-5
Cooperative Weed Management Areas . 1 -5
Consultation . 1-5
Public Involvement and Analysis of Issues . 1-6
Public Scoping Meetings . 1-6
Scoping Issues and Concerns . 1-7
Development of the Alternatives . 1-7
Issues Not Addressed in the PEIS . 1-7
Public Review and Comment on the Draft Programmatic EIS . 1-7
Limitations of this PEIS . 1-8
Preview of the Remainder of the PEIS . 1-9
Chapter 2. Alternatives . 2-1
Introduction . 2-1
Herbicide Active Ingredients Evaluated Under the Proposed Alternatives . 2-1
Aminopyralid . 2-1
Fluroxypyr . 2-2
Rimsulfuron . 2-2
Herbicide Formulations Used by the BLM and Tank Mixes . 2-2
Description of the Alternatives . 2-2
Alternative A - Continue Present Herbicide Use (No Action Alternative) . 2-3
Alternative B - Allow for Use of Three New Herbicides in 17 Western States (Preferred
Alternative) . 2-4
Alternative C - No Aerial Application of New Herbicides . 2-4
Alternative D - No Use of New Acetolactate Synthase-Inhibiting Active Ingredients (No
Rimsulfuron) . 2-7
Alternatives Considered but Not Analyzed Further . 2-7
Herbicide Treatment Standard Operating Procedures and Guidelines . 2-7
Monitoring . 2-9
Coordination and Education . 2-9
Mitigation . 2-9
Summary of Impacts by Alternative . 2- 1 0
Chapter 3. Affected Environment . 3-1
Introduction and Study Area . 3-1
Land Use and Ecoregions . 3- 1
Land Use . . . 3-1
Final Programmatic EIS
TABLE OF CONTENTS
Ecoregions . 3-1
Climate . 3-2
Air Quality . 3-2
Greenhouse Gas Emissions and Climate Change . 3-2
Class 1 Areas and Visibility Protection . P . 3-6
Herbicide Drift . 3-6
Topography, Geology, Minerals, Oil, and Gas . 3-6
Soil Resources . 3-6
Biological Soil Crusts . 3-7
Micro and Macroorganisms . 3-7
Soil Erosion . 3-7
Soil Disturbance . 3-8
Water Resources and Quality . 3-8
Water Resources . 3-8
Water Quality . 3-9
Wetland and Riparian Areas . 3-10
Vegetation . 3-1 1
Vegetation Classification System . 3-12
Noxious Weeds and other Invasive Vegetation . 3-17
Vegetation Condition and Fire Regimes . 3-17
Non-timber and Special Forest Products . 3-19
Special Status Species . 3-19
Fish and Other Aquatic Organisms . 3-20
Special Status Species . 3-20
Wildlife Resources . 3-20
Special Status Species . 3-21
Livestock . 3-21
Wild Horses and Burros . 3-22
Paleontological and Cultural Resources . 3-22
Paleontological Resources . 3-22
Cultural Resources . 3-22
American Indian and Alaska Native Cultural Resources . 3-23
European Settlement Resources . 3-25
Important Plant Uses and Species Used by American Indians and Alaska Natives . 3-25
Visual Resources . 3-25
Wilderness and Other Special Areas . 3-26
Recreation . 3-28
Rights-of-way, Facilities, and Roads . 3-29
Rights-of-way . 3-29
Facilities and Roads . 3-29
Social and Economic Values . 3-29
Social/Demographic Environment . 3-29
Economic Environment . 3-3 1
Environmental Justice . 3-32
Revenues Generated by BLM Lands . 3-33
Expenditures by the BLM . 3-35
Human Health and Safety . 3-37
Background Health Risks . 3-37
Risks from Diseases . 3-39
Risks from Injuries . 3-40
Risks from Cancer . 3-41
Risks from Using Herbicides on Public Lands . 3-41
Risks from Wildfire Control on Public Lands . 3-41
BLM Vegetation Treatments Three New Herbicides ii January 2016
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TABLE OF CONTENTS
Chapter 4. Environmental Consequences
Introduction . 4-1
How the Effects of the Alternatives Were Estimated . 4-1
Assumptions for Analysis . 4-2
Incomplete and Unavailable Information . 4-3
Subsequent Analysis before Projects . 4-3
Program Goals by Ecoregion . 4-4
Land Use . 4-4
Air Quality and Climate . 4-5
Scoping Comments and Other Issues Evaluated in the Assessment . 4-5
Emission Sources and Impact Assessment Methodology . 4-5
Methodology for Assessing Impacts to Air Quality . 4-5
Standard Operating Procedures . 4-6
Impacts by Alternative . 4-7
Mitigation for Herbicide Treatment Impacts . 4-10
Soil Resources . 4-10
Introduction . 4-10
Scoping Comments and Other Issues Evaluated in the Assessment . 4-10
Standard Operating Procedures . 4- 1 0
Factors that Influence the Fate, Transport, and Persistence of Herbicides in Soil . 4-10
Summary of Herbicide Impacts . 4-1 1
Impacts by Alternative . 4-13
Mitigation for Herbicide Treatment Impacts . 4-14
Water Resources and Quality . 4-14
Introduction . 4-14
Scoping Comments and Other Issues Evaluated in the Assessment . 4-14
Standard Operating Procedures . 4- 1 4
Summary of Herbicide Impacts . 4-15
Impacts by Herbicide . 4-17
Impacts by Alternative . 4-19
Mitigation for Herbicide Treatment Impacts . 4-20
Wetland and Riparian Areas . 4-21
Introduction . 4-21
Scoping Comments and Other Issues Evaluated in the Assessment . 4-21
Factors that Influence the Fate, Transport, and Persistence of Herbicides in Wetland and
Riparian Areas . 4-21
Methodology for Assessing Impacts to Wetland and Riparian Areas . 4-21
Summary of Herbicide Impacts . 4-22
Impacts by Alternative . 4-24
Mitigation for Herbicide Treatment Impacts . 4-25
Vegetation . 4-25
Introduction . 4-25
Scoping Comments and Other Issues Evaluated in the Assessment . 4-25
Standard Operating Procedures . 4-25
Impacts Assessment Methodology . 4-26
Summary of Herbicide Impacts . 4-27
Impacts by Ecoregion . 4-33
Impacts by Alternative . 4-33
Mitigation for Herbicide Treatment Impacts . 4-38
Special Status Plant Species . 4-38
Introduction . 4-38
Impacts Assessment Methodology . 4-38
Summary of Herbicide Impacts . 4-38
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Impacts from Use of the Three New Herbicides . 4-39
Mitigation for Herbicide Treatment Impacts . 4-41
Fish and Other Aquatic Organisms . 4-4 1
Introduction . 4-41
Scoping Comments and Other Issues Evaluated in the Assessment . 4-41
Standard Operating Procedures . 4-41
Impacts Assessment Methodology . 4-42
Summary of Herbicide Impacts . 4-44
Impacts by Alternative . 4-47
Mitigation for Herbicide Treatment Impacts . 4-48
Special Status Fish and Other Aquatic Organisms . 4-48
Introduction . 4-48
Impacts Assessment Methodology . 4-49
Summary of Herbicide Effects to Special Status Fish and Aquatic Invertebrates . 4-49
Impacts by Alternative . 4-50
Mitigation for Herbicide Treatment Impacts . 4-5 1
Wildlife Resources . 4-51
Introduction . 4-51
Scoping Comments and Other Issues Evaluated in the Assessment . 4-52
Standard Operating Procedures . 4-52
Impacts Assessment Methodology . 4-53
Summary of Herbicide Impacts . 4-54
Impacts of Herbicide Treatments on Wildlife and Habitat by Ecoregion . 4-57
Impacts by Alternative . 4-59
Mitigation for Herbicide Treatment Impacts . 4-60
Special Status Wildlife Species . 4-60
Introduction . 4-60
Impacts Assessment Methodology . 4-61
Summary of Herbicide Effects to Special Status Wildlife Species . 4-61
Impacts by Alternative . 4-61
Mitigation for Herbicide Treatment Impacts . 4-63
Livestock . 4-64
Introduction . 4-64
Scoping Comments and Other Issues Evaluated in the Assessment . 4-64
Standard Operating Procedures . 4-64
Impacts Assessment Methodology . 4-64
Summary of Herbicide Impacts . 4-65
Impacts by Alternative . 4-67
Mitigation for Herbicide Treatment Impacts . 4-68
Wild Horses and Burros . 4-68
Introduction . 4-68
Scoping Comments and Other Issues Evaluated in the Assessment . 4-68
Standard Operating Procedures . 4-68
Impacts Assessment Methodology . 4-68
Summary of Herbicide Impacts . 4-68
Impacts by Alternative . 4-69
Mitigation for Herbicide Treatment Impacts . 4-71
Paleontological and Cultural Resources . 4-71
Scoping Comments and Other Issues Evaluated in the Assessment . 4-71
Standard Operating Procedures . 4-71
Summary of Herbicide Impacts . 4-72
Herbicide Impacts on Native American Health . 4-73
Impacts by Alternative . 4-74
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TABLE OF CONTENTS
Mitigation for Herbicide Treatment Impacts . 4-75
Visual Resources . 4-75
Scoping Comments and Other Issues Evaluated in the Assessment . 4-75
Standard Operating Procedures . 4-75
BLM Assessment of Visual Resource Values . 4-76
Summary of Herbicide Impacts . 4-76
Impacts by Alternative . 4-76
Mitigation for Herbicide Treatment Impacts . 4-77
Wilderness and Other Special Areas . 4-77
Scoping Comments and Other Issues Addressed in the Assessment . 4-78
Standard Operating Procedures . 4-78
Summary of Herbicide Impacts . 4-78
Impacts by Alternative . 4-79
Mitigation for Herbicide Treatment Impacts . 4-80
Recreation . 4-80
Scoping Comments and Other Issues Evaluated in the Assessment . 4-80
Standard Operating Procedures . 4-80
Summary of Herbicide Impacts . 4-80
Impacts by Alternative . 4-81
Mitigation for Herbicide Treatment Impacts . 4-82
Social and Economic Values . 4-82
Introduction . 4-82
Scoping Comments and Other Issues Evaluated in the Assessment . 4-82
Standard Operating Procedures . 4-82
Impact Assessment Assumptions . 4-83
Summary of Herbicide Impacts . 4-83
Impacts by Alternative . 4-84
Mitigation for Herbicide Treatment Impacts . 4-87
Human Health and Safety . 4-87
Scoping Comments and Other Issues Evaluated in the Assessment . 4-87
Standard Operating Procedures . 4-87
Human Health Risk Assessment Methodology . 4-88
Uncertainty in the Risk Assessment Process . 4-89
Human Health Risks Associated with Herbicides . 4-89
Impacts by Alternative . 4-102
Mitigation . 4-103
Cumulative Effects Analysis . 4-103
Structure of the Cumulative Effects Analysis . 4-104
Resource Protection Measures and Other Information Considered in the Cumulative Effects
Analysis . 4-104
Analysis of Cumulative Effects by Resources . 4-105
Unavoidable Adverse Effects . 4-115
Relationship between the Local Short-term Uses and Maintenance and Enhancement of
Long-term Productivity . 4-117
Irreversible and Irretrievable Commitment of Resources . 4-121
Energy Requirements and Conservation Potential . 4- 1 23
Natural or Depletable Resource Requirements and Conservation . 4-123
Chapter 5. Consultation and Coordination . 5-1
Preview of this Section . 5- 1
Public Involvement . 5-1
Federal Register Notices and Newspaper Advertisements . 5-1
Scoping Meetings . 5- 1
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TABLE OF CONTENTS
Frequently Asked Questions . 5-1
Public Review and Comment on the Draft Programmatic EIS . 5-1
Agency Coordination and Consultation . 5-2
Endangered Species Act Section 7 Consultation . 5-2
Risk Assessment Coordination . i . 5-2
Cultural and Historic Resource Consultation . 5-2
Govemment-to-govemment Consultation . 5-2
List of Preparers of the Programmatic EIS and BA . 5-3
Chapter 6. Response to Comments . 6-1
Summary of Comments on the Draft Programmatic EIS . 6-1
Commenting Agencies, Organizations, and Individuals . 6-1
Specific Comments and Responses . 6- 1
Responses to Comments . 6-4
Chapter 7. References . 7-1
Chapter 8. Glossary . 8-1
Chapter 9. Index . 9-1
List of Appendices
Appendix A Common and Scientific Names of Plants and Animals Given in the Programmatic EIS . A-l
Appendix B Tribal and Agency Consultation . B- 1
Appendix C Alaska National Interest Lands Conservation Act (ANILCA) § 8 10 Analysis of Subsistence
Impacts . C-l
Appendix D Description of Vegetation Macrogroups . D-l
Appendix E Special Status Species List . E-l
List of Tables
1- 1 Key Issues (and Number of Comments) Identified During Scoping and Location Where Issues Are
Addressed in this PEIS . 1-8
2- 1 Formulations of the Three Herbicides Proposed for Use on Public Lands . 2-3
2-2 Herbicides Approved and Proposed for Use on Public Lands . 2-5
2-3 Average Acreage Treated Annually for Each BLM State Jurisdiction During 2006 to 2012 . 2-7
2-4 Historic Use of Herbicides by the BLM and Projected Future Use of Herbicides by the BLM Under
Each Alternative (as a percentage of all acres treated using herbicides) . 2-8
2-5 Mitigation Measures . 2- 1 0
2- 6 Summary and Comparison of Effects on Resources by Alternative . 2- 1 1
3- 1 Acres of Public Lands in 17 Western States and Percent of the State Administered by the BLM . 3-1
3-2 National Ambient Air Quality Impact Significance Criteria . 3-3
3-3 Counties Within the Treatment Area that are Designated Nonattainment or Maintenance Areas for
Various Pollutants . 3-4
3-4 Vegetation Classification System . 3-13
3-5 Estimated Acres of Invasive Plant Infestations on Public Lands in 2014 . 3-18
3-6 Grazing Permits and Leases in Force and Active Animal Unit Months in 201 1 . 3-22
3-7 Wild Horses and Burros on Public Lands in Fiscal Year 2013 . 3-23
3-8 Cultural Resources on Public Lands . 3-23
3-9 Culture Areas, Prehistoric Occupation Periods, and Selected Common Site Types . 3-24
3-10 Visual Resource Management Classes and Objectives and Appropriate Management Activities . 3-26
Final Programmatic EIS
TABLE OF CONTENTS
3-1 1 National Landscape Conservation System and Other Special Designation Areas on Public Lands as
of September 20 1 1 . 3-27
3-12 Estimated Recreation Use of Public Lands During Fiscal Year 201 1 . 3-28
3-13 Population, Age Distribution, and Race in the Western States and Alaska . 3-30
3-14 Percent Unemployment for the Western U.S. and Alaska . 3-31
3-15 Percent Employment by Industry in 201 1 . 3-32
3-16 Percent of People Below the Poverty Level for the Western U.S. and Alaska . 3-33
3- 1 7 Revenues Generated from Public Lands by Source for Fiscal Year 20 1 1 . 3-34
3-18 Estimated Benefits to Local Economies by Recreation on Public Lands in Fiscal Year 201 1 . 3-35
3- 1 9 Summary of BLM Jobs and Expenditures for the Management of the Lands and Resources Program
by Activity and Subactivity (dollars in thousands) . 3-36
3-20 BLM and USDOI Fire Suppression Expenditures Fiscal Year 2007 through Fiscal Year 2013 . 3-36
3-21 USDOI Unwanted Wildland Fires During 2006 to 2012 . 3-36
3-22 Herbicide Uses and Costs for Vegetation Treatments on Public Lands During 201 1 . 3-38
3-23 BLM Payments to States and Local Governments During Fiscal Year 201 1 . 3-39
3- 24 Mortality Rates (per 100,000 Population) and Causes of Death by State 2010 . 3-40
4- 1 Annual Emissions Summary for Herbicide Treatments Under All Alternatives . 4-6
4-2 Example NAAQS Compliance Analysis for Herbicide Treatments Under All Alternatives . 4-8
4-3 Estimated Soil Half-life (Aerobic Conditions) and Adsorption Affinity for Active Ingredients . 4-11
4-4 Factors Associated with Herbicide Movement to Groundwater . 4-16
4-5 Herbicide Physical Properties and Off-site Movement Potential . 4- 1 7
4-6 Anaerobic Half-life in Soil for Herbicides Analyzed in this PEIS . 4-21
4-7 Risk Categories Used to Describe Typical Herbicide Effects to Vegetation According to Exposure
Scenario and Ecological Receptor Group . 4-29
4-8 Buffer Distances to Minimize Risk to Non-target Vegetation from Off-site Drift . 4-30
4-9 Projected Herbicide Treatments, as a Percent of Total Acres Treated, in Each Ecoregion for
Each Vegetation Macrogroup Under All Alternatives . 4-34
4-10 Risk Categories Used to Describe Herbicide Effects on Non Special Status Fish and Aquatic
Invertebrates According to Exposure Scenario . 4-45
4-1 1 Risk Categories Used to Describe Herbicide Effects on Special Status Fish and Aquatic
Invertebrates According to Exposure Scenario . 4-50
4-12 Risk Categories Used to Describe Herbicide Effects on Non Special Status Wildlife According to
Exposure Scenario . 4-55
4-13 Risk Categories Used to Describe Herbicide Effects on Special Status Wildlife According to
Exposure Scenario . 4-62
4-14 Herbicide Risk Categories by Aggregate Risk Index for Occupational Receptors . 4-91
4-15 Herbicide Risk Categories by Aggregate Risk Index for Public Receptors . 4-92
4- 1 6 Aminopyralid Aggregate Risk Indices - Occupational Scenarios . 4-93
4-17 Aminopyralid Aggregate Risk Indices, Routine Exposure Scenarios for Public Receptors,
Short-term Exposure . 4-94
4-18 Aminopyralid Aggregate Risk Indices for Accidental Exposure Scenarios for Public Receptors
Based on Maximum Application Rates . 4-95
4-19 Fluroxypyr Aggregate Risk Indices - Occupational Scenarios . 4-96
4-20 Fluroxypyr Aggregate Risk Indices, Routine Exposure Scenarios for Public Receptors,
Short-term Exposure . 4-97
4-21 Fluroxypyr Aggregate Risk Indices for Accidental Exposure Scenarios for Public Receptors
Based on Maximum Application Rates . 4-98
4-22 Rimsulfuron Aggregate Risk Indices - Occupational Scenarios . 4-99
4-23 Rimsulfuron Aggregate Risk Indices, Routine Exposure Scenarios for Public Receptors,
Short-term Exposure . 4-100
4- 24 Rimsulfuron Aggregate Risk Indices for Accidental Exposure Scenarios for Public Receptors
Based on Maximum Application Rates . 4-101
5- 1 List of Preparers of the Programmatic EIS/BA . 5-3
Final Programmatic E1S
TABLE OF CONTENTS
6- 1 Comment Response Summary . 6-2
List of Figures
2- 1 Summary of Acres Treated Using Herbicides During 2006 to 20 1 2 . 2-4
List of Maps
1 - 1 Publ ic Lands Administered by the Bureau of Land Management . 1-10
3- 1 Ecoregion Divisions . 3-42
3-2 Class 1 Areas . 3-43
3-3 Oil and Gas Wells on BLM-administered Lands . 3-44
3-4 Soil Orders on Public Lands . 3-45
3-5 Hydrologic Regions . 3-46
3-6 Fire Regime Condition Classes on Public Lands . 3-47
3-7 National Landscape Conservation System Areas . 3-48
BLM Vegetation Treatments Three New Herbicides viii January 2016
Final Programmatic EIS
CHAPTER 1
PROPOSED ACTION AND
PURPOSE AND NEED
PROPOSED ACTION AND PURPOSE AND NEED
CHAPTER 1
PROPOSED ACTION AND
PURPOSE AND NEED
Introduction
The United States Department of the Interior (USDOI)
Bureau of Land Management (BLM) administers
approximately 247 million acres in 17 western states in
the continental United States (U.S.) and Alaska (Map 1-
1). One of the BLM’s highest priorities is to promote
ecosystem health, and one of the greatest obstacles to
achieving this goal is the rapid expansion of invasive
plants (including noxious weeds and other plants not
native to an area) across public lands. These invasive
plants can dominate and often cause permanent damage
to native plant communities. If not eradicated or
controlled, invasive plants jeopardize the health of
public lands and the activities that occur on them.
Herbicides are one method employed by the BLM to
manage these plants.
In 2007, the BLM published the Vegetation Treatments
Using Herbicides on Bureau of Land Management
Lands in 1 7 Western States Programmatic
Environmental Impact Statement (2007 PEIS; USDOI
BLM 2007a). The Record of Decision (ROD) for the
2007 PEIS allows the BLM to use 1 8 herbicide active
ingredients available for a full range of vegetation
treatments in 17 western states (USDOI BLM 2007b).
In the ROD, the BLM also outlines a protocol for
identifying, evaluating, and using new herbicide active
ingredients. Under the protocol, the BLM is not allowed
to use a new herbicide active ingredient until the agency
1) assesses the hazards and risks from using the new
active ingredient, and 2) prepares an Environmental
Impact Statement (EIS) under the National
Environmental Policy Act (NEPA) to assess the impacts
to the natural, cultural, and social environment
associated with the use of the new active ingredient on
BLM-administered lands. While the protocol originally
indicated that a Supplemental EIS could be prepared,
further legal review determined that since the vegetation
treatment program has been implemented, adding new
herbicides is considered a new action rather than a
supplemental action. Therefore, a separate EIS is
required to assess the impacts associated with the use of
new herbicides.
Proposed Action
The BLM is proposing to add the herbicides
aminopyralid, fluroxypyr, and rimsulfuron to its list of
approved active ingredients for use on public lands.
These herbicides have been identified by the BLM
based on input from BLM field offices and a
preliminary assessment of their effectiveness and
suitability for the BLM’s vegetation treatment needs.
The three new herbicides have been registered for use
by the U.S. Environmental Protection Agency
(USEPA), are deemed effective in controlling
vegetation, and have minimal effects on the
environment and human health if used according to the
herbicide label instructions.
Ecological risk assessments (ERAs) and a human health
risk assessment (HHRA) have been completed as part of
the PEIS process to be used in support of the assessment
of potential impacts of the new herbicide active
ingredients.
This action would increase the number of herbicide
active ingredients available to the BLM from 18 to 21.
The new herbicides would be integrated into the
herbicide treatment programs that were assessed in the
2007 PEIS and accompanying Programmatic
Environmental Report (17-States PER; USDOI BLM
2007c). Proposed treatments using aminopyralid,
fluroxypyr, and rimsulfuron could occur anywhere on
the 247 million acres of public lands in the western
U.S., including Alaska, unless restricted by the
herbicide label or BLM guidelines. Components of site-
specific treatment programs, including treatment and
herbicide application methods utilized, acres treated,
and treatment locations, would be determined at the
local level and by Congressional direction and funding.
While the ROD for the 2007 PEIS makes no decisions
regarding the number of acres that can be treated using
herbicides, the maximum treatment acreage assumed in
the 2007 PEIS — 932,000 acres annually — is being
carried over to this action.
BLM Vegetation Treatments Three New Herbicides
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January 2016
PROPOSED ACTION AND PURPOSE AND NEED
The three new herbicides would be available for use in
vegetation treatment programs on public lands
immediately after the ROD has been signed.
Purpose and Need for the
Proposed Action
The need for the proposed action is the ongoing spread
of noxious weeds and other invasive plants, which
degrade the health of public lands and affect resources
such as wildlife habitat, native plant communities,
threatened and endangered species habitat, soil, water,
and recreation. Some invasive vegetation acts as a
hazardous fine fuel and contributes to the frequency,
extent, and severity of wildfires. The BLM requires
effective tools for management of invasive plants in
order to prevent their spread into non-infested areas,
restore desirable vegetation in degraded areas, and
reduce wildfire risk. In particular, the BLM has
identified the need for additional herbicide active
ingredients that: 1) have less environmental and human
health impacts than some of the currently approved
herbicides (e.g., picloram); 2) increase options for
management of invasive annual grasses; and 3) address
potential herbicide resistance by certain species (e.g.,
kochia1, marestail, and pigweed) to active ingredients
currently used by the BLM.
The purpose of the proposed action is to improve the
effectiveness of the BLM’s vegetation management
program by allowing herbicide treatments with
aminopyralid, fluroxypyr, and rimsulfuron. This action
would increase the number of active ingredients
approved for use, and would give the BLM increased
flexibility and options when designing on-the-ground
herbicide treatments.
Including the three new herbicides in the vegetation
management program would also help meet the
purposes that were first identified in the 2007 PEIS,
which are to provide BLM personnel with the
herbicides available for vegetation treatment on public
lands and to describe the conditions and limitations that
apply to their use.
The overall goals of vegetation treatments with
herbicides are to reduce the risk of wildfires by reducing
hazardous fuels, stabilize and rehabilitate fire-damaged
1 Common and scientific names of plants and animals used
in this PEIS are provided in Appendix A.
lands, and improve ecosystem health by 1) controlling
invasive plants, and 2) manipulating vegetation to
benefit fish and wildlife habitat, improve riparian and
wetland areas, and improve water quality in priority
watersheds. The ability to utilize aminopyralid,
fluroxypyr, and rimsulfuron, in conjunction with other
herbicides and other types of vegetation treatments,
would help the BLM meet these natural resource goals.
Scope of Analysis and Decisions to
Be Made
This PEIS analyzes the effects of using aminopyralid,
fluroxypyr, and rimsulfuron to treat vegetation on
public lands in the western U.S., including Alaska.
These lands include Oregon and California Land Grant
lands, Coos Bay Wagon Road lands. National
Recreation Areas, Areas of Critical Environmental
Concern, and lands administered by the BLM through
its National Landscape Conservation System (NLCS),
such as Wilderness Study Areas (WSAs), designated
Wilderness Areas, National Monuments, and National
Conservation Areas.
Study Area and Scope of Analysis
The study area for this PEIS is generally the same as the
study area for the 2007 PEIS. It includes all BLM-
administered lands in the 17 western states of Alaska,
Arizona, California, Colorado, Idaho, Nebraska,
Nevada, New Mexico, North Dakota, Montana,
Oklahoma, Oregon, South Dakota, Texas, Utah,
Washington, and Wyoming. The total acreage of the
study area is approximately 247 million acres (USDOI
BLM 2013a).
The focus of this PEIS is to provide an analysis of the
use of aminopyralid, fluroxypyr, and rimsulfuron in
herbicide treatments to reduce hazardous fuels and
manage and control vegetation affecting other
resources. Other types of vegetation treatments with
herbicides are not evaluated, as discussed in the 2007
PEIS (USDOI BLM 2007a: 1-5). Additionally, the PEIS
will not evaluate policies and programs associated with
land use activities authorized by the BLM (e.g.,
livestock grazing, off-highway vehicle [OHV] use, and
timber harvesting), and will not make land use
allocations or amend approved land use plans.
Because this PEIS is programmatic in nature, it makes
broad assumptions about the acreages that would be
treated annually by the three herbicides proposed for
use. More specific estimates of acreages treated would
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PROPOSED ACTION AND PURPOSE AND NEED
be made at the regional, state, or local level, and
assessed in step-down EISs or Environmental
Assessments.
This PEIS provides a background, source of information
to which any necessary subsequent environmental
analyses can be tiered. In general, the NEPA process
may be done at multiple scales, depending on the scope
of the proposal. This PEIS represents the broadest level
of analysis; at this level, the study contains a broad
environmental impact analysis, focuses on general
policies, and provides Bureau-wide decisions on
herbicide use. Additionally, it provides an umbrella
Endangered Species Act (ESA) Section 7 consultation
for the range of activities described in the PEIS. The
next scale of analysis represents a regional level of
analysis, and may be prepared for regional or statewide
programs. Below the regional scale of analysis, there is
the option to prepare a field office level of analysis. At
the local scale, a project-level analysis is prepared for
site-specific proposals. The analysis may be tiered to
any or all of the higher levels of analysis. Tiering allows
local offices to prepare more specific environmental
documents without duplicating relevant portions of this
PEIS. Analyses done by local BLM offices will be
prepared in accordance with NEPA guidance and will
include public involvement. The various scales of
analysis and the tiering process are discussed in more
detail in the 2007 PEIS (USDOI BLM 2007a: 1-9 to 1-
10).
Decisions to be Made
The BLM will use the information in this PEIS and
public comments on the draft and final PEIS to develop
a ROD for the proposed action, which will be released
at least 30 days after the Notice of Availability of the
final PEIS is published. The ROD will indicate which
alternative is selected for implementation.
As part of selecting an alternative, the BLM decision¬
maker may choose to implement a portion of the
selected alternative (such as approving only one or two
of the three herbicides), or combine features of multiple
alternatives (such as restricting aerial application of only
one or two of the three herbicides). The ROD will
address significant impacts, alternatives, environmental
preferences, and relevant economic and technical
considerations.
If the decision-maker decides to approve the use of one
or more new active ingredients, the ROD will also
indicate what standard operating procedures (SOPs) and
mitigation will be implemented to minimize the impacts
of herbicide treatments with the three new active
ingredients, or will identity new SOPs. These SOPs and
mitigation measures would be implemented in addition
to those already specified in the ROD for the 2007
PEIS.
Documents that Influence the
Scope of the PEIS
Much of the scope of this PEIS is based on the PEIS
prepared in 2007 to evaluate the use of herbicides for
vegetation treatments on public lands. The 2007 PEIS
provides a detailed discussion of the BLM’s vegetation
management programs and herbicide use on BLM
lands, and evaluates the risks of using the 18 herbicides
currently approved for use by the BLM. Under the
current proposal, the herbicides approved for usage by
the 2007 PEIS would continue to be used, and overall
vegetation management programs would be mostly
unchanged, with the exception of the addition of the
three new herbicides. Where appropriate, information in
the 2007 PEIS that is relevant to analysis of the current
proposal is cited and incorporated by reference.
Documents that provide policy and guidance for
hazardous fuels reduction and land restoration activities
to reduce the risk of wildfires and restore fire-adapted
ecosystems include: the National Fire Plan (USDOI
and U.S. Department of Agriculture [USDA] 2001); the
Healthy Forests Initiative of 2002 and the Healthy
Forests Restoration Act of 2003 (Public Law 108-148);
Chapter 3 (Interagency Burned Area Emergency
Stabilization and Rehabilitation) in BLM Manual 620,
Wildland Fire Management (USDOI BLM 2004a); A
Collaborative Approach for Reducing Wildland Fire
Risks to Communities and the Environment 10-Year
Strategy Implementation Plan (USDOI and USDA
2006a); Interagency Burned Area Rehabilitation
Guidebook (USDA and USDOI 2006b); the Emergency
Stabilization and Rehabilitation Handbook (H- 1742-1;
USDOI BLM 2007d); and the National Strategy
(USDOI and USDA 2014). Additional documents and
policies that influence the scope of this PEIS are listed
in the 2007 PEIS (USDOI BLM 2007a: 1-6 and
Appendix F).
Relationship to Statutes,
Regulations, and Policies
The 2007 PEIS details the federal laws, regulations, and
policies that influence vegetation treatments on BLM-
BLM Vegetation Treatments Three New Herbicides
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January 2016
PROPOSED ACTION AND PURPOSE AND NEED
administered lands (USDOI BLM 2007a: 1-6 to 1-8).
These include the Federal Land Policy Management Act
of 1976 (FLPMA); Taylor Grazing Act of 1934; Oregon
and California Grant Lands Act of 1937; Carson-Foley
Act of 1968; Plant Protection Act of 2000; Section 15 of
the Federal Noxious Weed Act of 1974, as amended;
Noxious Weed Control Act of 2004, Public Rangelands
Improvement Act of 1978; Clean Air Act of 1970/1977,
as amended; Safe Drinking Water Act of 1974, as
amended; Wilderness Act of 1964; Clean Water Act of
1972; Federal Insecticide, Fungicide, and Rodenticide
Act of 1996; Federal Food, Drug, and Cosmetic Act of
2002; Food Quality Protection Act of 1996; Resource
Conservation and Recovery Act of 1976, as amended;
Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended;
Migratory Bird Conservation Act of 1929, as amended;
ESA of 1973, Wild Free-Roaming Horse and Burro Act
of 1971, as amended by the Public Rangelands
Improvement Act of 1978; Fish and Wildlife
Conservation Act of 1980, Sikes Act of 1974; Historic
Sites Act of 1935; National Historic Preservation Act of
1966 (NHPA); Archaeological Resources Protection
Act of 1979; American Indian Religious Freedom Act
of 1978; Native American Graves Protection and
Repatriation Act of 1990; Section 810 of the Alaska
National Interest Lands Conservation Act (ANILCA) of
1980, as amended; Executive Order (EO) 11990
( Protection of Wetlands ); EO 12898 ( Environmental
Justice ); EO 13045 ( Protection of Children from
Environmental Health Risks and Safety Risks); EO
13084 ( Consultation and Coordination with Indian
Tribal Governments); EO 13112 ( Invasive Species); and
EO 13186 (, Responsibilities of Federal Agencies to
Protect Migratory Birds).
Since the 2007 PEIS, the BLM has implemented a new
policy requiring consultation with Alaska Native
Corporations on the same basis as American Indian and
Alaska Native Tribes.
NEPA Requirements of the Program
Federal agencies are required to prepare an EIS when
the proposed action is likely to have a significant impact
on the quality of the human environment (42 U.S.C.
[United States Code] 4321 et seq; USDOI BLM 2008a).
An EIS is intended to provide decision-makers and the
public with a complete and objective evaluation of
significant environmental impacts, beneficial and
adverse, resulting from the proposed action and all
reasonable alternatives.
The intent of this PEIS is to comply with NEPA by
assessing the programmatic level impacts of using
aminopyralid, fluroxypyr, and rimsulfuron to treat
vegetation on public lands administered by the BLM.
Additional guidance for NEPA compliance and for
assessing impacts is provided in the Council on
Environmental Quality (CEQ) Regulations for
Implementing the Procedural Provisions of NEPA (40
Code of Federal Regulations [CFR] Parts 1500-1508),
and the BLM National Environmental Policy Act
Handbook H- 1 790- 1 (USDOI BLM 2008a).
Interrelationships and
Coordination with Agencies
In its role as manager of approximately 247 million
acres in the western U.S., including Alaska, the BLM
has developed numerous relationships at the federal,
tribal, state, and local levels, as well as with
conservation and environmental groups with an interest
in resource management, and private landowners.
Included are members of the public that use public lands
or are affected by activities on public lands.
National Level Coordination
The BLM regularly coordinates with the numerous
federal agencies that administer laws that govern
activities on public lands, administer lands adjacent to
or in close proximity to public lands administered by the
BLM, or that have oversight or coordination
responsibilities. These agencies include the Department
of Defense; Department of Energy, National Park
Service, U.S. Fish and Wildlife Service (USFWS),
Bureau of Reclamation, Bureau of Indian Affairs,
USDA Forest Service, Agricultural Research Service,
Animal and Plant Health Inspection Service, Natural
Resources Conservation Service, and U.S. Geological
Survey Biological Services.
National level coordination that is pertinent to the
proposed project includes coordination of invasive
species management, and fire and fuels management.
The National Invasive Species Council, which involves
13 federal departments and agencies, was established by
EO 13112 to develop strategies for coordinated,
effective, and efficient control of invasive species on
federal lands. Participating agencies include (but are not
limited to) the U.S. Departments of Agriculture,
Interior, Commerce, Defense, Transportation, and
Health and Human Services, and the USEPA. Other
groups that coordinate invasive species management at
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PROPOSED ACTION AND PURPOSE AND NEED
the national level include the Federal Interagency
Committee for the Management of Noxious and Exotic
Weeds, the Federal Interagency Committee on Invasive
Terrestrial Animals and Pathogens, and the Aquatic
Nuisance Task Force. These groups are discussed
further in the 2007 PEIS (USDOI BLM 2007a: 1-1 1).
The Wildland Fire Leadership Council, Interagency
Fuels Management Committee, and National Wildfire
Coordinating Group are national-level interagency
groups that coordinate wildland fire and fuel
management issues. The National Cohesive Wildfire
Management Strategy provides a long-term, national-
level strategy for reducing the effects of wildfires
throughout the U.S.
State and County Level Coordination
The BLM is required to coordinate with state and local
agencies under several acts, including: the Clean Air
Act, the Sikes Act, FLPMA, and Section 106 of the
NHPA.
The BLM coordinates closely with state resource
management agencies on issues involving the
management of public lands, the protection of fish and
wildlife populations, including federally and state-listed
threatened and endangered species, invasive and
noxious weeds, fuels and wildland fire management,
and herbicide application. Herbicide applications are
also coordinated with state and local water quality
agencies to ensure that they are in compliance with
applicable water quality regulations. At the agency or
state level, vulnerability assessments are done for
treatment programs to ensure that they do not result in
unacceptable surface water or groundwater
contamination. Thus, coordination of this issue must
include a groundwater specialist either at the agency
level or state level to make the vulnerability assessment.
Local and state agencies work closely with the BLM to
manage weeds on local, state, and federal lands, and are
often responsible for vegetation treatments on public
lands. The BLM participates in exotic plant pest
councils, state vegetation and noxious weed
management committees, state invasive species
councils, county weed districts, and weed management
associations found throughout the western U.S.
Non-governmental Organizations
The BLM coordinates at the national and local levels
with several resource advisory groups and non¬
governmental organizations, including: BLM Resource
Advisory Councils, the Western Governors’
Association, the National Association of Counties, the
Western Area Power Administration, the National
Cattlemen’s Beef Association, the American Sheep
Industry, the Society of American Foresters, and the
American Forest and Paper Association. The BLM also
solicits input from national and local conservation and
environmental groups with an interest in land
management activities on public lands, such as The
Nature Conservancy. These groups provide information
on strategies for weed prevention, effective treatment
methods, use of domestic animals to manage invasive
plants, landscape level planning, vegetation monitoring,
and techniques to restore land health.
Cooperative Weed Management Areas
Cooperative Weed Management Areas (CWMAs) are
composed of local, private, and federal interests.
CWMAs typically center on a particular watershed or
similar geographic area in order to pool resources and
management strategies in the prevention and control of
invasive plant populations. Much of the BLM’s on-the-
ground invasive species prevention and management is
done directly or indirectly through CWMAs. The BLM
participates in numerous CWMAs throughout the West,
several of which are showcase examples of interagency
and private cooperation in restoring land health.
Consultation
As part of this PEIS the BLM consulted with the
USFWS and the National Marine Fisheries Service
(NMFS), as required under Section 7 of the ESA. The
BLM prepared a formal initiation package that included:
1) a description of the program, listed threatened and
endangered species, species proposed for listing, and
critical habitat that may be affected by the program; and
2) a Biological Assessment for Vegetation Treatments
with Aminopyralid, Fluroxypyr, and Rimsulfuron on
Bureau of Land Management Lands in 17 Western
States (USDOI BLM 2015). The Biological Assessment
(BA) evaluated the likely impacts to listed species,
species proposed for listing, and critical habitat from the
proposed use of aminopyralid, fluroxypyr, and
rimsulfuron in the BLM’s vegetation treatment
programs, and identified conservation measures to
minimize impacts to these species and habitats.
Consultation with USFWS addressed populations of
sage-grouse that were proposed for listing at the time,
but not populations that were candidates for listing.
However, all BLM actions must comply with land use
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PROPOSED ACTION AND PURPOSE AND NEED
plan decisions, as amended by pertinent sage-grouse
ElSs. Interim management direction is outlined in
Instruction Memorandum 2012-043, Greater Sage-
Grouse Interim Management Policies and Procedures.
The BLM initiated consultation with Native American
tribes, Alaska Native groups, and Alaska Native
Corporations to identity their cultural values, religious
beliefs, traditional practices, and legal rights that could
be affected by BLM actions. Consultation included
sending out letters to all tribes and groups that could be
directly affected by vegetation treatment activities, and
requesting information on how treatments with the three
new herbicides could impact Native American and
Alaska Native interests, including the use of vegetation
and wildlife for subsistence, religious, and ceremonial
purposes (see Appendix B). Formal consultations with
Indian tribes and Alaska Native Corporations may also
be required during implementation of projects at the
local level.
The BLM conducted an ANILCA 810 Analysis of
Subsistence. During this process, the BLM invited
public participation and collaborated with Alaska
Natives to identify and protect culturally significant
plants used for food, baskets, fiber, medicine, and
ceremonial purposes. The findings are presented in
Appendix C.
The BLM consulted with State Historic Preservation
Offices (SHPOs) as part of Section 106 consultation to
determine how proposed vegetation treatment actions
could impact cultural resources. Formal consultations
with SHPOs also may be required during
implementation of projects at the local level.
Public Involvement and Analysis
of Issues
Scoping is the process by which the BLM solicits
internal and external input on the issues, impacts, and
potential alternatives that will be addressed in an EIS, as
well as the extent to which those issues and impacts will
be analyzed in the document (USDOI BLM 2008a).
Scoping also helps to begin identifying incomplete or
unavailable information and evaluating whether that
information is essential for making a reasoned choice
among alternatives.
The BLM published a Federal Register (FR) Notice of
Intent (NOI) on December 21, 2012, notifying the
public of its intent to prepare a PEIS to evaluate the use
of aminopyralid, fluroxypyr, and rimsulfuron herbicides
as part of its vegetation treatment programs in 17
western states. The NOI also identified the locations and
times of three scheduled public scoping meetings, and
stated that comments on the proposal would be accepted
until February 19, 2013.
Public notices of the scoping period and public
meetings were placed in newspapers serving areas in or
near locations where the meetings were held.
Public Scoping Meetings
Three public scoping meetings were held: one in
Worland, Wyoming (on January 7, 2012), one in Reno,
Nevada (January 9), and one in Albuquerque, New
Mexico (January 10). Decisions on where to hold
meetings were based on levels of attendance at scoping
meetings in these locations for the 2007 PEIS, as well as
discussions with local BLM offices. The determination
not to hold one or more scoping meetings in Alaska was
made by the BLM District office in Fairbanks, based on
low attendance at the meetings for the 2007 PEIS, low
past and projected future use of herbicides in Alaska,
and the overlap of the public scoping period with that of
another Environmental Assessment involving herbicide
use. In lieu of a public scoping meeting, the Alaska state
office offered to host a web-based meeting for anyone
who wanted to learn more about the project and provide
comments. As no members of the public responded to
this offer, the meeting was not held by the BLM.
The scoping meetings were conducted in an open-house
style. Information displays were provided at the
meeting, and handouts describing the project, the NEPA
process, issues, and alternatives were given to the
public. A formal presentation provided the public with
additional information on program goals and objectives.
At each meeting, the presentation was followed by a
question and answer session.
The BLM received 26 requests to be placed on the
mailing list from individuals, organizations, and
government agencies, and 43 written comment letters,
emails, or facsimiles on the proposal. In addition to
written comments received at the scoping meetings,
four individuals provided oral comments. As most of
the comment letters provided multiple comments, a total
of 255 individual comments were catalogued and
recorded during the public scoping period. A Scoping
Summary Report for the Vegetation Treatments Using
Aminopyralid, Fluroxypyr, and Rimsulfuron on Bureau
of Land Management Lands in 17 Western States
Programmatic Environmental Impact Statement
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PROPOSED ACTION AND PURPOSE AND NEED
(AECOM 2013) was prepared that summarized the
issues and alternatives identified during scoping.
Scoping Issues and Concerns
The vast majority of scoping comments received were
supportive of the BLM’s proposal to add aminopyralid,
fluroxypyr, and rimsulfiiron to its list of active
ingredients. Respondents provided information on the
effectiveness and safety of the three herbicides, as well
as extensive comments about the need to utilize these
herbicides to effectively control weeds.
The primary issues of concern identified during scoping
include the following:
• Need to develop a better mechanism for
notifying the public of aerial spraying of
herbicides, and implement additional
preventative measures for future applications to
minimize impacts to human health. Establish
larger buffers between herbicide application
areas and human habitation and/or sensitive,
high value crops.
• Need to discuss the screening process that the
BLM uses to determine whether chemical
applications are necessary when other types of
treatments are considered.
• Concerns about long-term persistence of
aminopyralid and fluroxypyr in treated plant
materials, and the potential to transport plant
tissue or manure of livestock that have ingested
these materials to sensitive areas, croplands,
and broadleaf garden plants.
• Concerns about impacts to water quality and
aquatic resources, including detection of
aminopyralid in groundwater and associated
impacts to irrigated plants/crops.
• Concerns about the risks to human health and
safety from herbicide use.
• Concerns about disproportionate adverse
effects to minority and low-income
populations.
• Need to evaluate options for restoration
activities following invasive plant removal to
prevent reestablishment of target species.
• Need to consider climate change, both in terms
of its effect on herbicide efficacy and
greenhouse gas (GHG) emissions associated
with the proposed project.
• Recommendation that vegetation treatments
with the proposed herbicides be monitored to
determine their effectiveness.
A summary of issues raised by scoping comments is
provided in Table 1-1.
Development of the Alternatives
Public comments were considered when developing
alternatives for analysis in this PEIS. As there were
several comments about herbicide drift during aerial
spraying and the potential for human health effects,
alternatives addressing these issues are evaluated in the
PEIS. The alternatives also reflect the alternatives that
were developed for the 2007 PEIS, as applicable. They
reflect public comments received during scoping for the
2007 PEIS that suggested the BLM avoid aerial
applications of herbicides or avoid the use of
acetolactate synthase (ALS)-inhibiting active
ingredients.
Issues Not Addressed in the PEIS
A very small number of comments were not addressed
in the PEIS because they were beyond the scope of the
document or did not meet the basic purpose and need of
the project. These comments primarily pertained to
streamlining or changing the evaluation process for new
herbicides, which is outside the scope of this PEIS.
Additionally, one comment requested an analysis of
whether increased carbon dioxide (CO2) in the
atmosphere could affect efficiency of herbicides, which
is also outside the scope of this PEIS.
Public Review and Comment on the
Draft Programmatic EIS
The Notice of Availability of the Draft Programmatic
Environmental Impact Statement for Vegetation
Treatments Using Aminopyralid, Fluroxypyr, and
Rimsulfuron on Bureau of Land Management Lands in
1 7 Western States was published in the Federal Register
on June 19, 2015. On the same date, the BLM issued a
press release notifying the public that the Draft PEIS
was available for public review and comment. The
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PROPOSED ACTION AND PURPOSE AND NEED
TABLE 1-1
Key Issues (and Number of Comments) Identified During Scoping and
Location Where Issues Are Addressed in this PEIS
Issue
Where Addressed
in PEIS
Interrelationships
Consider adjacent private, state, and federally owned lands, and coordinate weed control
efforts (2)
1-4
Description of Alternatives
Clarify the number of acres that would be treated (1)
2-3
Clarify that the new herbicides would not replace currently approved herbicides (1)
1-1, 2-2
Incorporate best management practices for aerial applications to adequately notify the public
and avoid accidental public exposures to spraying ( 1 )
4-87
Do not spray where there is a risk to crops ( 1 )
2-7, 4-83
Herbicide Treatment Standard Operating Procedures and Guidelines
Discuss the screening process used to decide whether chemical applications are necessary ( 1 )
2-7
Evaluate options for restoration of treated areas following invasive plant removal (1)
2-7
Incorporate effective monitoring of treated areas ( 1 )
2-9
Affected Environment
Thoroughly discuss cheatgrass, yellow starthistle, and other noxious weeds and non-native
species and the degree to which they threaten BLM lands (6)
3-17
Environmental Consequences
Address the impacts of the three herbicides compared to those of other herbicides and
treatment methods (6)
Chapter 4
Address the impacts associated with residual effects of aminopyralid, including its spread to
sensitive areas by grazing animals and damage to crops associated with use of contaminated
manure and compost materials (3)
4-12,4-27, 4-84
Include a discussion of climate change and GHG emissions (1)
4-7, 4-105
Assess the effects of composting operations and how treated plants would be disposed of (1)
4-84
Address the potential for surface water, groundwater, and drinking water contamination by
the three herbicides ( 1 )
4-15
Address herbicide drift and potential impacts to nearby private lands ( 1 )
4-82, 4-85
Address human health and safety risks associated with use of the three herbicides ( 1 )
4-87
Include an environmental justice analysis ( 1 )
4-84
Draft PEIS and supporting documentation were posted
to a BLM website, where the public was able to
download a copy of these documents. Copies of the
documents were available upon request and for public
inspection at all BLM state, district, and field office
public rooms.
A total of 98 substantive comments were received on
the Draft PEIS. Comments were received via letter,
electronic mail, and facsimile. A summary of the
comments received, issues identified, and specific
comments and responses are presented in Chapter 6 of
this PEIS. All comments are reproduced in the CD of
supporting documentation.
Limitations of this PEIS
This PEIS is a programmatic document that addresses
the broad impacts associated with the proposed action
and alternatives to the proposed action. Environmental
impacts are assessed at a general level because of the
broad land area analyzed in the PEIS. Site-specific
impacts would be assessed in NEPA documents
prepared by local BLM offices and tiered to this
document.
The analyses of impacts of the use of herbicides in this
PEIS are based on the best and most recent information
Bl.M Vegetation Treatments Three New Herbicides
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PROPOSED ACTION AND PURPOSE AND NEED
available. As is always the case when developing
management direction for a wide range of resources, not
all information that might be desired was available. In
these cases, discussions follow the direction provided in
the CEQ Regulations for incomplete or unavailable
information (40 CFR 1502.22[b]). In cases where
impacts could not be quantified, they have been
described in qualitative terms.
Preview of the Remainder of the
PEIS
The format of this PEIS follows guidance provided by
the CEQ and BLM National Environmental Policy Act
Handbook H- 1790- 1 (USDOI BLM 2008a).
• Chapter 2, Alternatives, describes and
compares the proposed alternatives.
• Chapter 3, Affected Environment, presents
existing natural and socioeconomic resources
on public lands in the western U.S.
• Chapter 4, Environmental Consequences,
evaluates the impacts of the alternatives on
public land resources in the western U.S., and
describes mitigation proposed for program-
related impacts to resources.
• Chapter 5, Consultation and Coordination,
describes the scoping and public hearing
processes, agencies contacted, and
govemment-to-govemment consultation, and
lists the preparers of this PEIS.
• Chapter 6, Response to Comments, provides a
summary of the comments received on the
Draft PEIS and the BLM’s responses to these
comments.5
• Chapter 7, References, lists the documents and
other sources used to prepare this PEIS.
• Chapter 8, Glossary, provides definitions for
important terms used in this PEIS.
• Chapter 9, Index, lists where significant issues,
resource descriptions, NEPA terms, and
agencies and groups discussed in this PEIS are
located.
• Appendices A through E provide supplemental
information that is pertinent to the analysis
presented in this PEIS.
• Acronyms, Abbreviations, and Symbols (a
fold-out sheet at the end of the document) lists
the acronyms, abbreviations, and symbols used
in this PEIS.
BLM Vegetation Treatments Three New Herbicides
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No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.
Original data were compiled from various sources. This information may not meet National Map Accuracy Standards
This product was developed through digital means and may be updated without notice.
Legend
BLM-administered Lands
Source BLM 201 3g.
Note Coverage for BLM-administered lands is not available for Texas, Nebraska, or Oklahoma
Map 1-1
Public Lands
Administered by the
Bureau of Land Management
0 25 50 75100125
0 50 100 150 200 250
250
^ Miles
■ Kilometers
500
125 250
3UU
I ou
I
) Miles
NATIONAL
LANDS
CHAPTER 2
ALTERNATIVES
ALTERNATIVES
CHAPTER 2
ALTERNATIVES
Introduction
Introductory and background information pertinent to
BLM herbicide treatment programs were provided in
the 2007 PEIS (USDOI BLM 2007a:2-l to 2-14). This
information is still applicable, and is pertinent to the
three herbicides addressed in this PEIS in terms of BLM
programs that implement herbicide treatments, planning
and management of vegetation treatments, and the
integration and selection of treatment methods within
treatment projects.
The BLM’s overarching goals for vegetation
management are to improve biological diversity and
ecosystem function, promote and maintain native and
resilient plant communities, and reduce invasive
vegetation and the risk of wildfire. Public lands are
administered under the principles of multiple use and
sustained yield. Thus, vegetation must be managed to
protect and enhance the health of the land.
Under all three action alternatives, the BLM would be
able to use the new herbicides immediately after the
signing of a ROD. Site-specific NEPA analyses would
be required prior to on-the-ground use of the new
herbicides. The new active ingredients would be
integrated into the BLM’s vegetation treatment
activities. They could be used anywhere on BLM lands,
subject to any applicable restrictions on their usage,
such as those identified on the individual pesticide label
and by each state’s pesticide regulatory agency.
Herbicide Active Ingredients
Evaluated Under the Proposed
Alternatives
The BLM proposes to add three new herbicide active
ingredients — aminopyralid, fluroxypyr, and
rimsulfuron — to its approved herbicide list. All three of
these herbicides have been registered by the USEPA
and deemed effective in controlling vegetation, and
have minimal effects on the environment and human
health if used in accordance with label instructions.
The new active ingredients were selected based on: 1)
input from BLM field offices on types of vegetation
needing control; 2) studies indicating that these active
ingredients would be more effective in managing
noxious weeds and other unwanted vegetation than
active ingredients currently used by the BLM; 3)
USEPA approval for use on rangelands, forestlands,
and/or aquatic environments; 4) input from herbicide
manufacturers regarding herbicides not currently
approved for use on public lands that may be
appropriate to manage vegetation; 5) the effectiveness
of the active ingredients on a variety of target species on
BLM lands; 6) the level of risk of the herbicidal
formulations to human health and the environment; and
7) the funds available to the BLM to conduct HHRAs
and ERAs of the proposed herbicides.
All three of the new active ingredients would be used to
help reduce the spread of noxious weeds and other
invasive plants to reduce the buildup of hazardous fuels,
reduce the loss of wildlife habitat, help stabilize and
rehabilitate sites impacted by fire, and restore native and
desirable plant communities.
Aminopyralid
Aminopyralid, primarily used for the management of
broadleaf weeds, is a selective herbicide that is used to
manage invasive annual, biennial, and perennial
herbaceous species, along with woody species. It is
applied either aerially or using ground application
equipment. It is mobile in both the xylem and phloem of
the target plant, and accumulates in leaf and root
meristematic tissue. Species targeted by this herbicide
include, but are not limited to: Russian knapweed, musk
thistle, spotted knapweed, yellow starthistle, Russian
thistle, and tansy ragwort (Lee 2013). These species are
rangeland weeds that displace native plant species.
Aminopyralid is registered under the USEPA’s reduced
risk initiative, indicating that the USEPA believes that it
poses less risk to human health and the environment
than existing herbicide options (USEPA 2012a).
Aminopyralid may be used instead of picloram in
certain situations. Although not currently registered for
aquatic use, it is likely that aminopyralid will receive an
aquatic registration in the near future that would allow
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ALTERNATIVES
for incidental overspray of this herbicide during
treatment of vegetation within close proximity to
wetland and riparian areas. Aminopyralid is appropriate
for use at rangeland, forestland, recreation, and cultural
resource sites; along rights-of-way (ROWs); and at
energy and mineral sites. It would be used to manage
noxious weeds and other invasive plants to restore
native plant communities and wildlife habitat,
predominantly on rangelands.
Fluroxypyr
Fluroxypyr is a selective, post-emergence herbicide that
is used to manage certain annual and perennial weeds,
including broadleaf species that are resistant to
sulfonylurea herbicides, such as kochia. It can be used
to manage invasive plants while maintaining native
rangeland grass species. It is applied to actively growing
plants using either aerial or ground-based equipment.
Fluroxypyr’s mode of action is by mimicking auxins
and disrupting plant cell growth. It is mobile in the
xylem of the plant, and to a lesser extent the phloem.
Fluroxypyr can be tank-mixed with other active
ingredients to improve its ability to manage difficult-to-
control weeds such as invasive pricklypear cactus.
Other invasive plant species targeted by fluroxypyr
include marestail and black henbane. The BLM has
indicated that the use of fluroxypyr can help reduce the
amount of other herbicide products used in treatments.
It is appropriate for use at rangeland, forestland,
recreation, and cultural resource sites; along ROWs; and
at energy and mineral sites (Lee 2013). Fluroxypyr
would be used to manage noxious weeds and other
invasive plants to restore native plant communities and
wildlife habitat, predominantly on rangelands. It would
also be used to control weeds in disturbed and cleared
areas, such as oil and gas sites.
Rimsulfuron
Rimsulfuron is a selective, ALS-inhibiting herbicide
that inhibits the biosynthesis of certain amino acids. It is
applied both pre- and post-emergence, by ground or
aerial methods. Rimsulfuron is active in both the xylem
and the phloem of the plant, but primarily the phloem.
Species targeted by this herbicide include winter annual
grasses, such as cheatgrass (downy brome) and
medusahead rye. Rimsulfuron has been observed to be
more effective than imazapic in certain areas and under
certain conditions. It is appropriate for use at rangeland,
forestland, recreation and cultural resource sites; along
ROWs; and at energy and mineral sites. Rimsulfuron
would be used predominantly on ROWs and rangelands
to reduce the buildup of hazardous fuels, and to restore
native plant communities.
Herbicide Formulations Used by the
BLM and Tank Mixes
The BLM generally uses several formulations of each
active ingredient approved for use on public lands.
Current USEPA-registered formulations of the three
herbicides proposed for use are shown in Table 2-1,
which includes the registration number of each
formulation, the concentration of the active ingredient,
and the herbicide resistance code.
Additionally, the three new herbicides could be used in
tank mixes with one or more of the previously approved
herbicides. Both aminopyralid and fluroxypyr can be
tank mixed with numerous other active ingredients,
including 2,4 dichlorophenoxyacetic acid (2,4-D),
chlorsulfuron, clopyralid, dicamba + diflufenzopyr,
glyphosate, metsulfuron methyl, picloram, sulfometuron
methyl, and triclopyr. Fluroxypyr would most
commonly be used with clopyralid, picloram, and
triclopyr. Rimsulfuron would usually be applied on its
own as a pre-emergent herbicide, but could be tank
mixed with chlorsulfuron for certain applications, along
with other herbicides registered for the same site of
application, unless prohibited by the label instructions.
Description of the Alternatives
Four alternatives have been developed for evaluation in
this PEIS, including the Preferred Alternative and the
No Action Alternative. Alternative actions are those that
could be taken to feasibly attain or approximate the
BLM’s objectives for herbicide use, as expressed in its
programs, policies, and land use plans.
Alternatives were developed based on the alternatives in
the 2007 PEIS. These alternatives address many of the
concerns raised during scoping for the 2007 PEIS, as
well as concerns raised during scoping for this PEIS (in
particular concerns about aerial spraying).
Under all alternatives, the BLM would continue to
follow all of the herbicide treatment SOPs and
mitigation measures stipulated in the ROD for the 2007
PEIS. General herbicide treatment SOPs would pertain
to treatments with the currently approved active
ingredients, as well as any new active ingredients added
under the various action alternatives. The BLM would
also continue to follow the monitoring requirements in
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-2
January 2016
ALTERNATIVES
TABLE 2-1
Formulations of the Three Herbicides Proposed for Use on Public Lands
Active
Ingredient
Trade Name
Manufacturer
USEPA
Registration
Number
Concentration
WSSA Herbicide
Resistance Code1
Aminopyralid
Milestone
Dow AgroSciences, L.L.C.
62719-519
2.0 lb a.e./gal
Group 4
Milestone VM
Dow AgroSciences, L.L.C.
62719-537
2.0 lb a.e./gal
Group 4
Aminopyralid +
GrazonNext
Dow AgroSciences, L.L.C.
62719-587
0.33+2.67 lb a.e./gal
Groups 4 + 4
2,4-D
GrazonNext HL
Dow AgroSciences, L.L.C.
62719-628
0.41+3.33 lb a.e./gal
Groups 4 + 4
Fore Front HL
Dow AgroSciences, L.L.C.
62719-630
0.41+3.33 lb a.e./gal
Groups 4 + 4
ForeFront R&P
Dow AgroSciences, L.L.C.
62719-524
0.33+2.67 lb a.e./gal
Groups 4 + 4
PasturAll
Dow AgroSciences, L.L.C.
62719-579
0.075+2.67 lb a.e./gal
Groups 4 + 4
PasturAll HL
Dow AgroSciences, L.L.C.
62719-629
0.1+3.54 lb a.e./gal
Groups 4 + 4
Aminopyralid +
Clopyralid
Sendero
Dow AgroSciences, L.L.C.
62719-645
0.5 + 2.3 lb a.e./gal
Groups 4 + 4
Aminopyralid +
Opensight
Dow AgroSciences, L.L.C.
62719-597
0.525+0.0945 % a.i.
Groups 4 + 2
Metsulfuron
Methyl
Chaparral
Dow AgroSciences, L.L.C.
62719-597
0.525+0.0945% a.i.
Groups 4 + 2
Aminopyralid +
Milestone VM Plus
Dow AgroSciences, L.L.C.
62719-572
0.1 +1.0 lb a.e./gal
Groups 4 + 4
1 riclopyr
Capstone
Dow AgroSciences, L.L.C.
62719-572
0. 1+1.0 lb a.e./gal
Groups 4 + 4
Rimsulfuron
Matrix
DuPont Crop Protection
352-556
25 % a.i.
Group 2
Fluroxypyr
Comet
Nufarm Americas, Inc.
71368-87
1.5 lb a.e./gal
Group 4
Fluroxypyr Herbicide
Alligare, L.L.C.
66330-385-
81927
2.8 lb a.e./gal
Group 4
Vista XRT
Dow AgroSciences, L.L.C.
62719-586
2.8 lb a.e./gal
Group 4
Fluroxypyr +
Clopyralid
Truslate
Nufarm Americas, Inc.
71368-86
0.75+0.75 lb a.e./gal
Groups 4 + 4
Fluroxypyr +
Surmount
Dow AgroSciences, L.L.C.
62719-480
0.67+0.67 lb a.e./gal
Groups 4 + 4
Picloram
Trooper Pro
Nufarm Americas, Inc.
228-599
1.0+ 1.0 lb a.e./gal
Groups 4 + 4
Fluroxypyr +
PastureGard
Dow AgroSciences, L.L.C.
62719-477
0.5+ 1.5 lb a.e./gal
Groups 4 + 4
Triclopyr
PastureGard HL
Dow AgroSciences, L.L.C.
62719-637
1.0+3. 0 lb a.e./gal
Groups 4 + 4
1 Resistance codes: Group 2 = Inhibition of acetolactate synthase, and Group 4 = growth regulators.
lb a.e./gal = pounds of acid equivalent per gallon; % a.i. = percent active ingredient; and WSSA = Weed Science Society of America
the ROD to ensure that SOPs and mitigation measures
are implemented appropriately. New SOPs and
mitigation measures that have been developed for the
action alternatives will be discussed, as appropriate,
elsewhere in this document. SOPs, mitigation measures,
and monitoring requirements that carry over from the
2007 PEIS can be found in Chapter 2 and Appendix B
of the ROD, as well as Chapter 2 of the 2007 PEIS
(USDOI BLM 2007a:2-22 to 2-56).
Alternative A - Continue Present
Herbicide Use (No Action Alternative)
This alternative describes an integrated vegetation
management program for resource management and
habitat enhancement, with only the herbicides approved
in the ROD for the 2007 PEIS used to manage
competing and unwanted vegetation. This alternative
corresponds to Alternative B of the 2007 PEIS, which
estimated that approximately 932,000 acres in the
western U.S. would be treated annually using
herbicides. As shown in Figure 2-1, total treatment
acreages using all herbicides have remained well below
this number.
Between 2006 and 2012, the BLM treated an average of
315,000 acres per year using herbicides. During this
time period, the annual acreage has ranged from about
260,000 to 436,000, with acres treated largely
dependent on funding. Increases in funding are typically
tied to incidence of wildfire. It is projected that the
acreage of public lands treated using herbicides will
increase from current levels, but will not exceed the
932,000-acre estimate from the 2007 PEIS. Therefore,
the maximum annual treatment area of 932,000 acres is
carried over to this PEIS for the purposes of analysis.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-3
January 2016
ALTERNATIVES
Figure 2-1. Summary of Acres Treated Using
Herbicides During 2006 to 2012.
Under this alternative, the BLM would continue to use
the 18 active ingredients currently approved for use,
which are listed in Table 2-2. The majority of
treatments would continue to occur in New Mexico,
Idaho, and Wyoming, as inferred from Table 2-3. The
projected use of each of the 18 approved herbicides
under the No Action Alternative is shown in Table 2-4.
The most widely used herbicides would be clopyralid,
glyphosate, imazapic, tebuthiuron, and triclopyr.
Estimates of herbicide use are based on the BLM’s
assessment of future needs as far as vegetation
treatment is concerned. Usage may vary from year to
year and percentages may change based on the total
acreage treated. Therefore, projected use of a particular
herbicide under the No Action Alternative does not
necessarily reflect historic usage of that herbicide.
Alternative B - Allow for Use of Three
New Herbicides in 17 Western States
(Preferred Alternative)
This alternative would allow the BLM to expand its
vegetation management program by permitting the use
of three new herbicide active ingredients to manage
competing and unwanted vegetation. Although the
BLM would likely treat more acres with herbicides than
it is currently, the projected maximum treatment acres
would remain at 932,000 acres annually.
Under the Preferred Alternative, the BLM would be
able to use, in 17 western states, the 18 active
ingredients that were approved for use in the 2007 PEIS
ROD, as well as aminopyralid, fluroxypyr, and
rimsulfuron.
These active ingredients could only be applied for uses,
and at application rates, specified on the label and in
accordance with the ROD. Under this alternative,
herbicides could be applied using ground or aerial
methods. Herbicides could be used individually, or tank
mixed with previously approved herbicides, as
applicable and in accordance with the individual
herbicide label.
The projected use of each of the new herbicides, as a
percent of use by all approved herbicides, is shown in
Table 2-4. It is estimated that aminopyralid would make
up 1 0 percent, fluroxypyr would make up 1 percent, and
rimsulfuron would make up 16 percent of the total
herbicide use on BLM-administered lands. As a result
of adding these new active ingredients, use of other
herbicides is expected to decrease, particularly
glyphosate, imazapic, and picloram.
Alternative C - No Aerial Application
of New Herbicides
This alternative would allow the BLM to use only
ground-based techniques to apply the three new
herbicides. Projected maximum treatment acres would
remain at 932,000 acres annually. This alternative
would be similar to Alternative B, except that aerial
application (by helicopter or fixed-wing aircraft) of the
three new herbicides would not be allowed. The BLM
would be restricted to only ground-based methods for
applying these herbicides, including by vehicle or on
foot with manual application devices. However, aerial
application of the 18 previously approved active
ingredients, where identified on individual active
ingredient labels, and in accordance with BLM policy,
would still be able to occur. Herbicides could be used
individually, or tank mixed with previously approved
herbicides, as applicable. These active ingredients could
only be applied for uses, and at application rates,
specified on the label, and in accordance with the ROD.
The projected amount of use of the new herbicides
under this alternative is shown in Table 2-4. It is
estimated that aminopyralid would make up 6 percent,
fluroxypyr would make up less than 1 percent, and
rimsulfuron would make up 3 percent of the total
projected herbicide use on BLM-administered lands.
Under this alternative, substantially less rimsulfuron
would be used than under Alternative B, as this
herbicide would not be applied aerially for large-scale
projects to control invasive annual grasses.
Aminopyralid use would also be less than under
Alternative B. However, all three herbicides would be
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-4
January 2016
ALTERNATIVES
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BLM Vegetation Treatments Three New Herbicides 2-5 January 2016
Final Programmatic E1S
TABLE 2-2 (Cont.)
Herbicides Approved and Proposed for Use on Public Lands
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-6
January 2016
ALTERNATIVES
applied using ground-based methods in various
treatment scenarios. As a result of adding the new
herbicides, it is predicted that use of other herbicides —
particularly glyphosate and imazapic — would decrease
compared to the No Action Alternative, although not as
much as under Alternative B.
Under this alternative, the BLM would develop new
SOPs for aminopyralid, fluroxypyr, and rimsulfuron
that restrict application by aerial methods.
TABLE 2-3
Average Acreage Treated Annually for Each
BLM State Jurisdiction During 2006 to 2012
State
Acres T reated
Annually
Percentage of
All Public
Lands Treated
Alaska
0
0.0
Arizona
5,621
1.8
California
1,525
0.5
Colorado
7,842
2.5
Idaho
35,401
11.2
Montana, North Dakota,
and South Dakota
8,857
2.8
Nevada
11,860
3.8
New Mexico, Oklahoma,
and Texas
189,654
60.1
Oregon and Washington
12,663
4.0
Utah
8,788
2.8
Wyoming and Nebraska
33,096
10.5
Total
315,307
100.0
Alternative D - No Use of New
Acetolactate Synthase-Inhibiting
Active Ingredients (No Rimsulfuron)
This alternative would allow the BLM to utilize the two
new herbicide active ingredients that do not belong to
the sulfonylurea, or the acetolactate synthase-inhibiting,
group of herbicide active ingredients. Aminopyralid and
fluroxypyr would be approved for use, but rimsulfuron
would not.
Under this alternative, the BLM would be able to use a
total of 20 herbicide active ingredients (the 1 8
previously approved active ingredients, plus
aminopyralid and fluroxypyr) on public lands in 17
western states. These active ingredients could only be
applied on sites, and at application rates, specified on
the individual label. Under this alternative, herbicides
could be applied using ground or aerial methods.
Herbicides could be used individually or in tank mixes
with previously approved active ingredients, in
accordance with label directions. The projected
maximum annual treatment acreage under this
alternative would remain at 932,000 acres.
Under this alternative, it is estimated that aminopyralid
would make up 10 percent of the total projected
herbicide use on BLM-administered lands, and
fluroxypyr would make up 1 percent of the total
projected herbicide use, similar to Alternative B (Table
2-4). As rimsulfuron would not be approved for use
under this alternative, the amount of glyphosate and
imazapic used would be greater than under Alternatives
B and C, and similar to levels under the No Action
Alternative.
Alternatives Considered but Not
Analyzed Further
The BLM based the alternatives being considered in this
PEIS on the alternatives that were identified for the
2007 PEIS. As herbicide treatments on public lands
have already been approved in the 2007 PEIS,
Alternative C from that document (No Use of
Herbicides) is not applicable and does not meet the
current project purpose and need. Based on a review of
scoping comments and the current alternatives, no
additional alternatives were considered for analysis in
this PEIS.
Herbicide Treatment Standard
Operating Procedures and
Guidelines
Under all of the alternatives, the BLM would follow
SOPs designed to minimize risks to human health and
the environment from herbicide treatment actions.
Standard operating procedures are management controls
and performance standards that are required of all
herbicide treatments. They are intended to protect and
enhance natural resources that could be affected by
herbicide treatments. The 2007 PEIS (USDOI BLM
2007a:2-22 to 2-35) provides a detailed discussion of
these SOPs, which include the following:
• Prevention measures during project planning,
development, and revegetation phases to
minimize the risk of introducing or spreading
noxious weeds.
• Herbicide treatment planning, which includes
evaluation of the need for chemical treatments
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-7
January 2016
ALTERNATIVES
and their potential for impact on the
environment, and development of an
operational plan that includes herbicide buffers
near water bodies, information on project
specifications, key personnel responsibilities
and communication, safety, spill, and response,
and emergency procedures.
• Procedures specific to site revegetation after
treatments to promote establishment and/or
recovery by the native plant community.
• Special precautions to minimize impacts to
special status species, wilderness areas, and
cultural resources.
• Standard operating procedures for applying
herbicides (listed in the 2007 PEIS; USDOI
BLM 2007a:Table 2-8, 2-30 to 2-35), both
general and designed to protect specific
resource elements (air quality, soils, water
resources, wetlands and riparian areas,
vegetation, pollinators, fish and other aquatic
organisms, wildlife, listed species, livestock,
wild horses and burros, cultural and
paleontological resources, visual resources,
wilderness and other special areas, recreation,
social and economic values, ROWs, and
human health and safety).
TABLE 2-4
Historic Use of Herbicides by the BLM and Projected Future Use of Herbicides by the BLM Under Each
Alternative (as a percentage of all acres treated using herbicides)
Active Ingredient
Historic Use
(2006-2012)
Projected Use Under Each Alternative
No Action
Alternative
Preferred
Alternative
Alternative C
(no aerial)
Alternative D
(no ALS inhibiting)
Herbicides Approved for Use on Public Lands
2,4-D
9.3
6
5
6
5
Bromacil
1.1
<1
<1
<1
<1
Chlorsulfuron
2.0
2
1
2
I
Clopyralid
18.3
13
14
14
14
Dicamba
1.9
1.5
<1
1
<1
Diflufenzopyr +
Dicamba
<1
<1
<1
1
<1
Diquat
<1
<1
<1
<1
<1
Diuron
1.9
2
<1
<1
<1
Fluridone
<1
<1
<1
<1
<1
Glyphosate
8.9
12
5
9
11
Hexazinone
<1
<1
<1
<1
<1
Imazapic
1.5
20
10
15
20
Imazapyr
1.7
2
1
1
1
Metsulfuron methyl
2.7
4
1
1
1
Picloram
7.1
8
4
7
4
Sulfometuron methyl
0.2
1
<1
<1
<1
Tebuthiuron
22.5
13
15
15
15
Triclopyr
20.8
15
16
16
16
H
erbicides Proposed for Use on Public Lands
Aminopyralid
0
0
10
6
10
Fluroxypyr
0
0
1
<1
1
Rimsulfuron
0
0
16
3
0
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-8
January 2016
ALTERNATIVES
All applicable SOPs (i.e., pertaining to herbicide
treatments) listed in the 2007 PEIS would be followed
during treatments with aminopyralid, fluroxypyr, and
rimsulfuron under all of the alternatives considered in
this PEIS. Additionally, all applicable mitigation
measures that were identified in the ROD for the 2007
PEIS (USDOI BLM 2007b:Appendix B) would be
followed, as applicable. Many of these mitigation
measures are specific to the 1 8 herbicides covered in the
2007 PEIS, and therefore would not apply to treatments
with the three new herbicides unless other herbicides
were also involved.
Monitoring
Monitoring of vegetation treatments is used to identify
whether treatments are implemented appropriately and
determine their effectiveness. The regulations at 43
CFR 1610.4-9 require that land use plans establish
intervals and standards for monitoring and evaluating
land management actions. Specific monitoring protocols
or studies for vegetation treatment projects are
developed and implemented at the local level. BLM
manuals, handbooks, and other technical documents
provide additional information on monitoring of
specific resources. A list of applicable reference
manuals and handbooks can be found in Appendix F of
the 2007 PEIS.
The BLM Assessment, Inventory, and Monitoring
(AIM) Strategy outlines the BLM monitoring program,
including monitoring for the vegetation resources found
on BLM-administered lands and monitoring of the
effects of treatments on these resources. The AIM
strategy addresses the BLM’s multiple-use and
sustainable yield mission, and ensures the collection of
defensible data to inform BLM managers and the public
about key ecological processes for maintaining
sustainable ecosystems. The AIM strategy establishes a
monitoring framework that is consistent and compatible
across scales, programs, and administrative boundaries.
The framework includes 1) use of core quantitative
indicators and consistent methods; 2) implementation of
a statistically valid, scalable sampling framework; 3)
application and integration of remote sensing
technologies; 4) implementation of electronic field data
collectors and enterprise data management; and 5)
capture of legacy data in a digital format (Toevs et al.
2011). As of November 2014, the AIM Strategy has
adopted core indicators and methods for terrestrial and
in-stream aquatic resources. Work is ongoing to
establish indicators and methods that will inform the
status and trends of other resources the BLM manages.
The BLM has adopted an ecosystem-based management
approach, which is applied to projects at the site-
specific level. The ecosystem-based management
framework ensures that local level decisions about
management goals and targets are informed and adapted
from learning based on science (monitoring) and local
knowledge.
The 2007 PEIS (USDOI BLM 2007a:2-35 to 2-39)
provides additional discussion of vegetation treatments
monitoring, including BLM guidance, procedures for
implementation, monitoring methods, and dissemination
of results.
Coordination and Education
As indicated during public scoping for this PEIS and the
earlier 2007 PEIS, the public has an interest in the
BLM’s vegetation treatment activities, particularly
individuals that live in close proximity to public lands,
have commercial operations that are dependent on
vegetation on or adjacent to public lands, or use public
lands for recreation. The BLM strives to keep the public
informed about its vegetation treatment activities
through regular coordination and communication. The
BLM also encourages the public to participate in the
environmental review process during the development
and analysis of local vegetation management programs.
The 2007 PEIS (USDOI BLM 2007a:2-39) summarizes
the ways in which the public can participate in this
process, as well as other applicable coordination efforts
between the BLM and the public.
Prior to herbicide treatments, the BLM posts entry
points onto public lands where the herbicide application
will take place. Information provided in the posting
includes the name of the herbicide product to be
applied, active ingredients, USEPA registration number,
application date, the period of time that must elapse
before a person without protective clothing may enter a
treatment site, and other warnings or information
required to ensure the safety of the public. Postings
remain at treatment sites for as long as necessary to
protect the public.
Mitigation
This PEIS identifies measures that the BLM proposes to
implement to mitigate adverse environmental impacts
identified in Chapter 4 (Environmental Consequences).
These measures are summarized in Table 2-5. As
defined by CEQ regulation 1508.20, mitigation
includes: 1) avoiding the impact altogether by not
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-9
January 2016
ALTERNATIVES
TABLE 2-5
Mitigation Measures
Resource
Mitigation Measures
Air Quality
None proposed.
Soil Resources
None proposed.
Water Resources and Quality
None proposed.
Wetland and Riparian Areas
None proposed.
Vegetation
• Establish herbicide-specific buffer zones around downstream water bodies, and nearby
habitats and non-target plant species/populations of interest for aminopyralid, fluroxypyr, and
rimsulfuron. Consult the ERAs for more specific information on appropriate buffer distances
under different soil, moisture, vegetation, and application scenarios.
• To protect special status plant species, implement all conservation measures for plants
presented in the Vegetation Treattnents Using Aminopyralid, Fluroxypyr, and Rimsulfuron
on Bureau of Land Management Lands in 17 Western States Biological Assessment (USDOI
BUM 2015). Apply these measures to all special status plant species.
Fish and Other Aquatic Organisms
• To protect special status fish and other aquatic organisms, implement all conservation
measures for aquatic animals presented in the Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and Rimsulfuron on Bureau of Land Management Lands in 1 7 Western States
Biological Assessment { USDOI BLM 2015).
Wildlife Resources
• When conducting herbicide treatments in or near habitats used by sensitive and listed
terrestrial arthropods, design treatments to avoid the use of fluroxypyr, where feasible.
• To protect special status wildlife species, implement conservation measures for wildlife
presented in the Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron
on Bureau of Land Management Lands in 17 Western States Biological Assessment (USDOI
BLM 2015).
Livestock
None proposed.
Wild Horses and Burros
None proposed.
Paleontological and Cultural
Resources
None proposed.
Visual Resources
None proposed.
Wilderness and Other Special
Areas
Mitigation measures that may apply to wilderness and special area resources are associated with
human and ecological health and recreation. Please refer to the Vegetation, Wildlife Resources, and
Recreation sections of Chapter 4.
Recreation
Mitigation measures that may apply to recreational resources are associated with ecological health.
Please refer to the Vegetation and Wildlife Resources sections of Chapter 4.
Social and Economic Values
None proposed.
1 luman Health and Safety
None proposed.
taking a certain action or parts of an action; 2)
minimizing impacts by limiting the degree or magnitude
of the action and its implementation; 3) rectifying the
impact by repairing, rehabilitating, or restoring the
affected environment; 4) reducing or eliminating the
impact over time by preservation and maintenance
operations during the life of the action; and 5)
compensating for the impact by replacing or providing
substitute resources or environments.
The analysis presented in this PEIS assumes that all of
the applicable SOPs identified in the 2007 PEIS
(USDOI BLM 2007a:Table 2-8) would be followed
during herbicide treatments with the three new active
ingredients. Additionally, it assumes that all applicable
mitigation measures developed in the 2007 PEIS and
included in the ROD for that document (USDOI
BLM2007b:Table 2-4) would be followed. Therefore,
only new mitigation measures specific to aminopyralid,
fluroxypyr, and rimsulfuron are presented in this PEIS.
Summary of Impacts by
Alternative
Table 2-6 summarizes the likely effects of vegetation
treatments using aminopyralid, fluroxypyr, and
rimsulfuron for each alternative. Information contained
in this table is discussed in more detail in Chapter 4
(Environmental Consequences).
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
2-10
January 2016
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides 2- 1 1 January 2016
Final Programmatic E1S
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides 2-12 January 2016
Final Programmatic E1S
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides 2- 1 3 January 2016
Final Programmatic E1S
TABLE 2-6 (cont.)
Summary and Comparison of Effects on Resources by Alternative
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides 2- 1 4 January 2016
Final Programmatic EIS
ALTERNATIVES
Final Programmatic EIS
TABLE 2-6 (cont.)
Summary and Comparison of Effects on Resources by Alternative
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides 2- 1 6 January 2016
Final Programmatic EIS
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-17
January 2016
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides 2- 1 8 January 2016
Final Programmatic EIS
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides 2- 1 9
Final Programmatic EIS
January 2016
ALTERNATIVES
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
2-20
January 2016
CHAPTER 3
AFFECTED ENVIRONMENT
AFFECTED ENVIRONMENT
CHAPTER 3
AFFECTED ENVIRONMENT
Introduction and Study Area
This chapter describes the natural and socioeconomic
environment of public lands in the western U.S.,
including Alaska, which would be affected by the
alternatives under consideration. It includes the
resources that were identified in Chapter 1, and provides
a framework for understanding the environmental,
cultural, and social consequences of the proposed
program and alternatives. In many instances, the
sections in this chapter reference material provided in
the affected environment chapter of the 2007 PEIS,
rather than repeating the full discussions here. However,
updated information is provided, where relevant.
Land Use and Ecoregions
Land Use
The BLM manages approximately 247 million acres in
the western U.S. and Alaska. Public lands make up less
than 0.1 percent of the total land area in some states, up
to approximately 68 percent of lands in Nevada (Table
3-1).
The BLM manages activities and resources on
rangelands throughout the West to ensure that
fundamental rangeland health is being sustained or
improved. The BLM permits livestock grazing on public
lands in a manner aimed at achieving and maintaining
rangeland health.
Other public uses on BLM-administered lands include
oil, gas, geothermal, and mineral development, various
types of recreation, forestry (harvest of timber and other
forest products), and cultural activities. Roads and trails
on BLM-administered lands support various forms of
travel, including OHV use and other motorized travel, as
well as non-motorized forms of travel such as mountain
bike, horse or pack animal, and foot. Additionally,
rights-of-way support petroleum pipelines, electrical
transmission lines, and other utilities.
Land use planning is directed by BLM Handbook H-
1601-1 ( Land Use Planning Handbook , BLM 2005).
This document provides guidance for preparing,
revising, amending, and maintaining land use plans.
Land use plans are developed with public input, in
accordance with the FLPMA, which requires the BLM
to manage public lands and their various resource
values to support multiple uses and sustained yields.
TABLE 3-1
Acres of Public Lands in 17 Western States and
Percent of the State Administered by the BLM
State
Acres of
BLM Land
Percent of State Lands
Administered by the BLM
Alaska
72,594,739
20.0
Arizona
12,202,750
16.8
California
15,330,274
15.3
Colorado
8,332,880
12.5
Idaho
11,611,720
21.9
Montana
7,983,412
8.6
Nebraska
6,354
0.2
Nevada
47,794,096
68.0
New Mexico
13,484,412
17.2
North Dakota
58,841
0.2
Oklahoma
1,975
0.2
Oregon
16,135,531
26.1
South Dakota
274,437
0.4
Texas
11,833
<0.1
Utah
22,854,632
43.3
Washington
429,167
0.9
Wyoming
18,373,316
29.4
Total
247,480,369
100
Source: USDOl BLM 2012a. Acreages are approximate and
subject to change in response to land transfers.
Ecoregions
Because this PEIS addresses a broad geographic region
with a diverse range of biophysical characteristics, the
study area has been subdivided into smaller,
homogeneous areas for analysis. Where possible,
information on resources has been organized by
ecoregions rather than by state boundaries. Ecoregions
are geographic areas that are delineated and defined by
similar climatic conditions, geomorphology, and soils
(Bailey 1997, 2002). Since these factors are relatively
constant over time and strongly influence the ecology
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AFFECTED ENVIRONMENT
ot vegetative communities, ecoregions may have similar
potentials and responses to disturbance (Clarke and
Bryce 1997; Jensen et al. 1997). Ecoregions, therefore,
provide a useful framework for organizing, interpreting,
and predicting changes to vegetation following
management treatments.
The public lands addressed in this PEIS lie within eight
major physiographic regions, or ecoregion divisions:
Tundra, Subarctic, Subtropical Steppe, Subtropical
Desert, Temperate Steppe, Temperate Desert,
Mediterranean, and Marine, including Mountain
Provinces (Map 3-1).
Climate
Climate is the statistical distribution of atmospheric
conditions, as determined by the weather patterns that
result from long-term fluctuations in global atmospheric
and hydrologic cycles. Climatic patterns describe the
annual distribution of energy and moisture, thus
affecting the amount and seasonal distribution of
temperature, precipitation, and winds. These factors
influence the composition and distribution of rangeland
vegetation, as well as the formation and erosion of
rangeland soils, and hydrological conditions. These
factors also influence the distribution of wind-borne air
pollutants, such as smoke from wildfires and prescribed
fires.
The western U.S. experiences several broad climatic
groups: polar, boreal, temperate, Mediterranean
highland, and dry. Polar and boreal climates dominate in
Alaska, while a humid temperate climate is
characteristic of the coastal areas of Washington,
Oregon, and northern California. The southern
California coast has a Mediterranean climate, while
mountainous areas have a highland climate. The rest of
the western states east of the Cascade, Sierra Nevada,
and Rocky mountains are characterized by a dry climate.
The 2007 PEIS presents specific information on the
climate within each of the eight ecoregions (USDOl
BLM 2007a:3-2 to 3-4).
Air Quality
Background information on air quality standards and
pertinent regulatory information is presented in the 2007
PEIS (USDOl BLM 2007a:3-3 to 3-4). Under the
authority of the Clean Air Act, the USEPA sets primary
and secondary National Ambient Air Quality Standards
(NAAQS) for the criteria pollutants sulfur dioxide
(SO2), nitrogen dioxide (NO2), carbon monoxide (CO),
ozone (O3), lead (Pb), and particulate matter (PM 10
[less than 10 microns in diameter] and PM2.5 [less than
2.5 microns in diameter]). Primary standards protect the
health of sensitive individuals, and secondary standards
protect the general welfare of the public.
The most recent NAAQS are listed in Table 3-2.
Different averaging periods are established for the
criteria pollutants based on their potential health and
welfare effects. The NAAQS are enforced by states,
which in some cases have adopted additional or more
stringent standards. Each state develops a plan
describing how it will attain and maintain the NAAQS.
Air quality agencies send these plans to the USEPA for
approval.
Geographic areas that meet the standards are attainment
areas and those that do not meet the standards are
nonattainment areas. Nonattainment areas must
implement a plan to reduce ambient concentrations
below the NAAQS. Once they comply with the
standards, they are designated as maintenance areas.
Table 3-3 lists counties with public lands that are
designated as nonattainment or maintenance areas for
each criteria pollutant. PM, O3, and NO2 concentrations
are expected to be higher near industrial areas and cities
where there are significant combustion sources and
vehicles. High SO2 concentrations occur primarily near
coal-fired power plants, smelters, and refineries.
Detailed sources of information about existing air
quality in the areas covered by this PEIS are limited to
data from available monitoring sites for criteria
pollutants. In the undeveloped regions of public lands,
ambient pollutant levels are expected to be low, and
probably negligible in remote areas. In general,
locations experiencing high ambient pollutant levels in
the treatment area are areas with commercial and
industrial land use (areas with mills, power plants, etc.),
and local population centers (areas with automobile
exhaust, residential heating, etc.).
Greenhouse Gas Emissions and
Climate Change
Climate change is a global issue that refers to any
significant change in measures of climate, including
temperature, precipitation, or wind, that extends for a
period (decades or longer) of time. Climate change is a
result of natural factors, such as volcanic eruptions, and
anthropogenic, or man-made, factors, including
changes in land use and burning of fossil fuels (USEPA
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TABLE 3-2
National Ambient Air Quality Impact Significance Criteria
Pollutant
Averaging Period
NAAQS
PSD Increments2
Primary
Secondary
Class I
Class II
no2
1-hour
100 ppb
NA
NA
NA
Annual
53 ppb
53 ppb
2.5 pg/m3
25 pg/m3
CO
1-hour
35 ppm
NA
NA
NA
8-hour
9 ppm
NA
NA
NA
PM.o
24-hour
150 pg/m3
1 50 pg/m3
8 pg/m ’
30 pg/m3
Annual
NA
NA
4 pg/m3
17 pg/m3
PM2.5
24-hour
35 pg/m3
35 pg/m3
2 pg/m ’
9 pg/nf
Annual
12 pg/m3
15 pg/m'
1 Pg/m3
4 pg/m3
so2
3 -hour
75 ppb
NA
25 pg/m3
5 1 2 pg/m3
24-hour
NA
0.5 ppm
5 pg/m3
91 pg/m3
Annual
NA
NA
2 pg/m3
20 pg/m3
Lead
Rolling 3-month
average
0. 1 5 pg/m3
0.15 pg/m’
NA
NA
03
8-hour
0.075 ppm
0.075 ppm
NA
NA
1 Annual standards are never to be exceeded. Short-term standards (those other than annual or quarterly) are not to be exceeded more than
once per year, except for 03, PM10, and PM2 5 standards. For 03, the expected number of days with ozone levels above the standard is
not to be exceeded more than once per calendar year. For PMI0, the standard is attained when the 99th percentile concentration for the
year is less than the standard. For PM2 5, the standard is attained when the 98th percentile concentration for the year is less than the
standard.
2 Prevention of Significant Deterioration (PSD) increments are the maximum amounts of pollutants allowed above a specified baseline
concentration. Class 1 areas are predominantly large national parks and wilderness areas as of August 7, 1977. Class II areas include a
variety of areas, such as national monuments, recreational areas, preserves, lakeshores, and wild and scenic rivers.
NA = Not applicable; ppb = parts per billion; ppm = parts per million; and pg/rrf = micrograms per cubic meter.
Sources: USEPA 2012b; 40 CFR 52.
2010a). Anthropogenic activities such as deforestation
and fossil fuel combustion emit heat-trapping GHGs,
which are defined as any gas that absorbs infrared
radiation within the atmosphere. The heat absorption
potential of a GHG is referred to as the Global
Warming Potential. Each GHG has a Global Warming
Potential value based on the heat-absorbing ability of
the GHG relative to C02 The carbon dioxide equivalent
(C02e) for a gas is derived by multiplying the tons of
the gas by the associated Global Warming Potential of
the gas. Greenhouse gases, both naturally occurring and
anthropogenic, prevent heat from escaping the
atmosphere and thereby regulate the Earth’s
temperature. Anthropogenic sources of GHGs have
elevated GHG concentrations within the atmosphere,
which has led to an increase in the Earth’s average
surface temperature over the last century (USEPA
2010a).
Unlike criteria air pollutants and toxic air contaminants,
which are of regional and local concern, GHGs are
global pollutants. They have the ability to affect global
temperatures due to their heat trapping ability, and are
therefore often discussed from a global perspective.
There are six recognized GHGs: CO?,
chlorofluorocarbons, methane, nitrous oxide (N2O), O3,
and water vapor. The federal Clean Air Act now
regulates these six GHGs. While certain sources are
required to meet the USEPA’s final GHG Reporting
Rule (74 FR 56260; 25,000 metric tons [MT]), other
types of projects (including the proposed herbicide
treatments) are not required to meet these rules.
The revised draft CEQ guidance for NEPA analysis
uses 25,000 MTC02e annual emissions as a reference
point for identifying projects that require quantitative
analysis of GHG emissions (CEQ 2014), although this
reference point is for the purposes of disclosure and not
a substitute for a determination of significance under
NEPA. Additionally, the guidance states that land
management agencies should consider net GHG
emissions that would occur with and without the
proposed project.
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AFFECTED ENVIRONMENT
TABLE 3-3
Counties Within the Treatment Area that are Designated Nonattainment or
Maintenance Areas for Various Pollutants
Pollutant
State
Nonattainment
Maintenance
Alaska
Fairbanks North Star Borough*
None
Arizona
Pinal*, Santa Cruz*
None
pm25
California
Alameda, Butte*, Contra Costa, El Dorado*,
Fresno, Imperial*, Kern*, Kings, Los
Angeles*, Madera, Marin, Merced, Napa,
Orange, Placer*. Riverside*, Sacramento, San
Bernardino*, San Francisco, San Joaquin, San
Mateo, Santa Clara, Solano*, Sonoma*,
Stanislaus, Sutter, Tulare, Yolo*, Yuba*
None
Idaho
Franklin*
None
Montana
Lincoln*
None
Oregon
Klamath*, Lane*
None
Utah
Box Elder*, Cache*, Davis, Salt Lake,
Tooele*, Utah*, Weber*
None
Washington
Pierce*
None
Alaska
Anchorage Municipality*, Juneau City and
Borough*
None
Arizona
Cochise*, Gila*, Maricopa*, Pima*. Pinal*,
Santa Cruz*, Y uma*
Gila*, Mohave*
California
Imperial*, Inyo*, Kern*, Los Angeles*,
Mono*, Orange, Riverside*, Sacramento, San
Bernardino*
Fresno, Inyo*, Kent*, Kings, Madera, Merced, San
Joaquin, Stanislaus, Tulare
PMI0
Colorado
None
Adams*, Arapahoe*, Archuleta*, Boulder*,
Broomfield, Denver, Douglas, Fremont*, Jefferson,
Pitkin*, Prowers*, Routt*, San Miguel*
Idaho
Bannock*, Bonner*, Power*, Shoshone*
Ada*, Bannock*, Power*
Montana
Flathead*, Lake*, Lincoln*, Missoula*,
Rosebud*, Sanders*, Silver Bow*
None
Nevada
Clark*, Washoe*
None
New Mexico
Dona Ana*
None
Oregon
Lane*
Jackson*. Josephine*, Klamath*, Lake*, Union*
Utah
Salt Lake, Tooele*, Utah, Weber*
None
Washington
None
King*, Pierce*, Spokane*, Thurston*, Walla Walla*,
Yakima*
Wyoming
Sheridan*
None
Arizona
Pinal*
Cochise*, Gila*, Greenlee*, Pima*, Pinal*
Montana
Lewis and Clark*, Yellowstone*
None
S02
Nevada
None
White Pine*
New Mexico
None
Grant*
Utah
Salt Lake, Tooele*
None
no2
None
None
Los Angeles*, Orange, Riverside*, San Bernardino*
CO
Alaska
None
Anchorage Municipality, Fairbanks North Star
Borough*
Arizona
None
Maricopa*, Pima*
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TABLE 3-3 (Cont.)
Counties Within the Treatment Area that are Designated Nonattainment or
Maintenance Areas for Various Pollutants
Pollutant
State
Nonattainment
Maintenance
CO
(cont.)
California
None
Alameda*, Butte*, Contra Costa*, El Dorado*,
Fresno*, Kern*, Los Angeles*, Marin*, Napa*,
Orange, Placer*, Riverside*, Sacramento*, San
Bernardino*, San Diego*, San Francisco, San
Joaquin*, San Mateo*, Santa Clara*, Solano*,
Sonoma*, Stanislaus*, Yolo*
Colorado
None
Adams*, Arapahoe*, Boulder*, Broomfield, Denver,
Douglas*, El Paso*, Jefferson*, Larimer*, Teller*,
Weld*
Idaho
None
Ada*
Montana
None
Cascade*, Missoula*, Yellowstone*
Nevada
None
Carson City*, Clark*, Douglas*, Washoe*
Oregon
None
Clackamas*, Jackson*, Josephine*, Klamath*,
Lane*, Marion*, Multnomah*, Polk*, Washington*
Utah
None
Utah*, Salt Lake*, Weber*
Washington
None
Clark*, King*, Pierce*, Snohomish*, Spokane*,
Yakima*
Ozone
Arizona
Maricopa*, Pinal*
Pinal*
California
Alameda, Amador, areas of Indian Country,
Butte, Calaveras, Contra Costa, El Dorado*,
Fresno, Imperial, Kern*, Kings, Los
Angeles*, Madera Marin, Mariposa Merced,
Napa Nevada*, Orange, Placer*, Riverside*,
Sacramento, San Bernardino*, San Diego*,
San Francisco, San Joaquin, San Luis
Obispo*, San Mateo, Santa Clara Solano*,
Sonoma*, Stanislaus, Sutter*, Tehama*,
Tulare, Tuolumne, Ventura*, Yolo
None
Colorado
Adams, Arapahoe, Boulder, Broomfield,
Denver, Douglas, Jefferson, Larimer*, Weld*
None
Nevada
Clark*
None
New Mexico
None
None
Oregon
None
None
Utah
None
None
Wyoming
Lincoln*, Sublett, Sweetwater*
None
Lead
California
Los Angeles*
None
Montana
Lewis and Clark*
None
* Only a portion of the county is in nonattainment or maintenance for the pollutant.
Notes: States that are not listed for a particular pollutant do not have counties within the treatment area that are also within nonattainment or
maintenance areas for that pollutant.
Source: USEPA 2012c.
For analysis of the proposed herbicide treatments,
comparing projected GHG emissions to regional or
national GHG emissions provides an understanding of
the relative contribution of the action to total GHG
emissions. The emissions can also be considered in
terms of federal goals for GHG reductions, such as
those described in EO 13693, Planning for Federal
Sustainability in the Next Decade. There are more
sources and actions emitting GHGs than are typically
encountered when evaluating the emissions of criteria
pollutants or toxic air contaminants. The global climate
change problem is much more the result of numerous
and varied sources, each of which might make a
relatively small addition to global atmospheric GHG
concentrations, but that together have a cumulative
effect. While there are difficulties in attributing specific
climate change impacts to any given proposed action
and quantifying those impacts, projected GHG
emissions can be used as a proxy for assessing a
proposed action’s potential climate change impacts.
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AFFECTED ENVIRONMENT
Class I Areas and Visibility Protection
Under the Clean Air Act, the U.S. has designated
certain national parks, wilderness areas, and Indian
reservations as Prevention of Significant Deterioration
(PSD) Class I areas (Map 3-2). These areas are
considered pristine and are therefore afforded special
protection from impacts associated with air pollution.
Mandatory Class I areas, which include large national
parks and wilderness areas that were in existence on
August 7, 1977, are a subset of Class I areas that may
not be redesignated, and are subject to visibility
protection regulations. Additional information on
policies related to visibility protection is presented in
the 2007 PEIS (USDOI BLM 2007a:3-4 to 3-6).
Herbicide Drift
Aerial and ground application of herbicides may
transport herbicides through drift, allowing airborne
herbicides to move beyond the intended target. The
primary factors that influence drift are droplet size,
wind speed, humidity, formulation of the herbicide,
height of application, equipment and application
techniques, and the size of the area treated with the
herbicide. The factor that has the greatest influence on
downwind movement is droplet size. Procedures that
can be employed to reduce drift include: 1) using a
lower spray nozzle height, 2) using the lower end of the
pressure range, 3) increasing the spray nozzle size,
4) using drift-reducing nozzles, 5) using drift control
additives, and 6) using sprayer shields (Hofman and
Solseng 2001). Additionally, several university
extension service agencies provide assistance regarding
SOPs to minimize herbicide spray drift (Dexter 1993,
Hofman and Solseng 200 1 ).
Topography, Geology, Minerals,
Oil, and Gas
The diversity in the landscape of the treatment areas
reflects differences in geologic processes and the effects
of climate, which have been shaping the land over a
long period of time.
A detailed baseline summary of mineral, oil, and gas
resources located within the project area, by ecoregion,
is presented in the 2007 PEIS (BLM 2007a:3-6 to 3-7).
Map 3-3 presents an update, based on the most recent
available digital data, of oil and gas wells on public
lands.
In 2011, conventional energy development from public
lands produced 43 percent of the nation’s coal, 13
percent of domestic natural gas, and 5 percent of the
domestically produced oil. BLM-administered federal
coal leases power more than 20 percent of the energy
generated in the United States. The BLM is also
actively promoting solar, wind, and geothermal energy
development on federal lands. Nearly 40 percent of U.S.
geothermal energy production capacity is on public
lands (USDOI BLM 2012b).
At the end of Fiscal Year (FY) 2012, the BLM
administered approximately 47,000 oil and gas leases,
of which approximately 23,000 were producing
(USDOI BLM 2013b). During 2011, geothermal leases
generated more than 4,600 gigawatts of electrical
power, and accounted for more than 40 percent of the
U.S. geothermal energy capacity (USDOI BLM 2013c).
States within the project area with the largest acreage of
public lands in producing status for oil and gas activities
are New Mexico, Colorado, Montana, and North
Dakota. Between 2006 and 20 1 2, there were substantial
increases in the amount of public land in producing
status in North Dakota and California, and sizeable
decreases in Alaska and Nevada (USDOI BLM 2013a).
Coal licenses and leases occur on public lands in
Colorado, Montana, New Mexico, Oklahoma, Utah, and
Wyoming. Mining operations occur on public lands in
the majority of the western states covered by this PEIS,
with most mining activity occurring in Nevada.
Geothermal potential exists in 12 of the 17 states
covered by this PEIS.
Soil Resources
Soils in the treatment area are diverse and range from
the arid, saline soils of the Southwest, to the clayey
glaciated soils of Montana, to the cold, wet permafrost
soils of Alaska.
Eleven soil orders are represented on public lands in the
western U.S. and Alaska (Map 3-4). Because soils
develop under local conditions of climate, parent
material, and vegetation, each ecoregion may contain
several or all of the soil orders as a result of various
combinations of local soil forming factors. A detailed
description of soils by soil order is presented in the 2007
2007 PEIS (USDOI BLM 2007a:3-7 to 3-9) and is
incorporated here by reference. Map 3-4 is a very basic
inventoiy of soil types at the landscape level. More
detailed mapping of soils and associated information
can be found in individual soil surveys completed for
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AFFECTED ENVIRONMENT
the western U.S., which are available on-line at
http://www.nrcs.usda.gov/wps/portal/nrcs/soilsurvev/soi
ls/survev/state/.
The concept of soil quality encompasses a soil’s
capacity to function. Healthy soils support plant and
animal diversity and productivity, air and water quality,
and human health (Soil Quality Institute 2001). They
filter and buffer pollutants, store and cycle nutrients,
and support structures and protect archaeological
resources. Soil quality is a function of each soil’s
inherited properties (texture, type of minerals, and
depth), as well as more dynamic properties that can
change with management (porosity, infiltration,
effective ground cover, and aggregate stability). The
ability of a soil to filter, buffer, degrade, immobilize,
and detoxify herbicides is a function of the soil quality.
Soil quality is integrated with the BLM’s management
activities, which can result in changes in certain soil
properties such as soil porosity, organic matter,
biological activity, and susceptibility to erosion. These
changes in turn affect the fate of herbicides in soils. For
example, disturbances that result in increased
susceptibility to erosion will affect the off-site
movement of certain herbicides that are designed to
bind to soil particles. Herbicides can alter soil organism
diversity and composition. Compaction or surface
disturbance may affect soil-activated herbicides from
reaching the root zone of target plants. Soil quality is
also considered by the BLM in health score cards used
to assess land health.
Biological Soil Crusts
Biological soil crusts (also known as cryptogamic,
microbiotic, cryptobiotic, or microphytic crusts) are
commonly found in semiarid and arid environments.
They are a community of organism at the surface of the
soil comprised of cyanobacteria, blue-green algae,
microfungi, mosses, liverworts, and lichens (Rosentreter
et al. 2007). Biological soil crusts provide important
functions, such as improving soil stability and reducing
erosion, fixing atmospheric nitrogen and contributing
nutrients to plants, and assisting with plant growth
(Belnap and Gardner 1993, Evans and Ehleringer 1993,
Eldridge and Greene 1994, Belnap and Giliette 1998,
Harper and Belnap 2001). They also enhance soil
fertility and stability. Biological soil crusts occupy open
spaces between the sparse vegetation of the Great Basin,
Colorado Plateau, Sonoran Desert, and the inner
Columbia Basin, and also occur in agricultural areas and
native prairies, and in Alaska.
Biological soil crusts can reach up to several inches in
thickness and vary in terms of color, surface
topography, and surficial coverage. Crusts generally
cover all soil spaces not occupied by vascular plants,
which may be 70 percent or more in arid regions
(Belnap 1994). They are well-adapted to severe growing
conditions, but are influenced by disturbances such as
compression from domestic livestock grazing, tourist
activities (hiking, biking, and OHVs), mechanical
treatment and agricultural practices (extensive tillage
and planting), application of herbicides, and military
activities (Peterjohn and Schlesinger 1990, Belnap
1995, U.S. Geological Survey [USGS] 2004). It is
prudent to minimize surface disturbance of soil crusts to
prevent invasions of annual fire-adapted grasses and
minimize dust produced from disturbance.
Micro and Macroorganisms
The soil microbial community plays a crucial role in
maintaining ecosystem health and sustainability, with
plant-microbe interactions contributing to the condition
of the ecosystem. Microorganisms help to break down
and convert organic remains into forms that can be used
by plants. Microorganisms, such as mycorrhizal fungi,
nitrogen-fixing organisms, and certain types of bacteria
assist plant growth, suppress plant pathogens, and build
soil structure. There is evidence that certain bacteria in
soil may suppress cheatgrass and other invasive species
(USFWS 2013). One of the main benefits of
mycorrhizal fungi is the improved uptake of nutrients
(predominantly phosphorous) and water by plants
(Allen 1991). Soil microorganisms are also important in
the breakdown of certain types of herbicides.
Macroorganisms, such as insects, earthworms, and
small burrowing mammals, mix the soil and allow
organic matter on the surface to become incorporated
into the soil. These organisms are part of a food web
that is essential to the cycling of nutrients within the
soil. Soil organisms interact and support plant health as
they decompose organic matter, cycle nutrients,
enhance soil structure, and control the populations of
soil organisms, including pests (Ingham, no date).
Soil Erosion
Soil erosion is a concern throughout the western U.S.
and Alaska, particularly in semiarid rangelands. The
quantity of soil lost by water or wind erosion is
influenced by climate, topography, soil properties,
vegetative cover, and land use. While erosion occurs
under natural conditions, rates of soil loss may be
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AFFECTED ENVIRONMENT
accelerated if human activities are not carefully
managed.
Tundra lands in Alaska are susceptible to erosion if the
thick vegetative mat overlying permafrost is disturbed
or removed. Trails quickly turn into widely braided ruts,
especially in wetlands and at streambank crossings. The
resulting gully erosion can rapidly erode substantial
quantities of previously frozen soils. Erosion from
aufeis (thick ice that builds up as a result of repeated
overflow) and anchor ice is also a concern, because of
spring breakup flood events leaving disturbed stream
channels. These events cause previously stable riparian
areas to form a long-lasting sequence of extensively
braided channels, especially in glacial soils.
Rangelands are affected by all four types of water
erosion: sheet, rill, gully, and streambank. Sheet erosion
is relatively uniform erosion from the entire soil surface
and is therefore often difficult to observe, while rill
erosion is initiated when water concentrates in small
channels as it runs off the soil. Sheet and rill erosion are
capable of reducing the productivity of rangeland soils,
but often go unnoticed. Gully and streambank erosion is
far more visible, and may account for up to 75 percent
of erosion in desert ecosystems (Hein 2002).
Wind erosion is most common in arid and semiarid
regions where lack of soil moisture greatly reduces the
adhesive capability of soil (Brady and Weil 2002). Most
wind erosion problems result from bare, exposed soils
with weak or degraded soil structure, such as along
trails or on sand dunes or disturbed surfaces. In addition
to moisture content, soil particle size (texture),
mechanical stability of aggregates and clods, and
presence of vegetation also affect the ability of wind to
move soil.
It is possible to control rates of soil erosion by
managing vegetation, plant residues, and soil
disturbance. Vegetative cover is the most significant
factor in controlling erosion because it intercepts
precipitation, reduces rainfall impact, restricts overland
flow, and improves infiltration. Biological soil crusts
are particularly important for protecting the soil and
controlling erosion in desert regions, but are easily
disturbed by grazing and human activities. While wind
erosion on rangelands is difficult to quantify, the
presence of natural vegetation on most rangelands is
generally sufficient to keep wind erosion from
becoming a serious problem.
In areas treated with herbicides, erosion can lead to
movement of herbicides on soil particles. Herbicides
bound to soil particles may be moved off site by wind or
water erosion events. Soil texture (sand, silt, and clay)
and structure affect the movement of water and
herbicides through soil, and the amount of herbicide that
is likely to be adsorbed by soil. The coarser the soil, the
faster the movement of percolating water and the lower
the opportunity for adsorption of dissolved chemicals.
Soils with more clay and organic matter tend to hold
water and dissolved chemicals longer. These soils also
have far more surface area onto which herbicides can be
adsorbed (LaPrade 1 992).
Soil Disturbance
Many western landscapes with undisturbed soils are
healthy, stable, and less vulnerable to erosion than areas
with disturbed soils. Soil disturbance stimulates erosion,
breaks up soil aggregates, and promotes the loss of
organic matter.
Soil compaction occurs when moist or wet soil
aggregates are pressed together and the pore space
between them is reduced. Compaction changes soil
structure, reduces the size and continuity of pores, and
increases soil density. Large animals, vehicles, and
people can cause soil compaction. Generally, soil made
up of particles of about the same size compacts less than
soil with a variety of particle sizes. Numerous rock
fragments can create bridges that reduce compaction.
Plant litter and roots, and soil organic matter, structure,
moisture, and texture all affect a soil’s ability to resist
compaction. In areas of rangeland where compaction
exists, compacted soil extends generally less than 6
inches below the soil surface, although it can be as deep
as 2 feet under heavily used tracks and roads (USDA
Natural Resources Conservation Service 1996).
Compaction becomes a problem when the increased soil
density limits water infiltration, increases runoff and
erosion, or limits plant growth or nutrient cycling (Soil
Quality Institute 2001).
Water Resources and Quality
Water Resources
Water resources in the western U.S. and Alaska are
important for fish and wildlife habitat and a variety of
human needs, such as domestic consumption, industrial
activities, crop irrigation, livestock watering, and
recreation. Numerous legal and policy requirements
have been established to manage water resources for
these multiple needs, including state law and case law
defining water rights, the Clean Water Act, the
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AFFECTED ENVIRONMENT
Colorado River Basin Salinity . Control Act, and EO
1 1988 ( Floodplain Management).
Water resources are classified as surface water or
groundwater. Surface water resources include rivers,
streams, lakes, ponds, reservoirs, and wetlands. Major
river systems (e.g., Colorado, Columbia, Snake,
Missouri, Arkansas, Rio Grande, and Yukon Rivers)
and their tributaries are important sources of water in
the western U.S and Alaska. Additional discussion of
surface water and groundwater resources can be found
in the 2007 PEIS (USDOI BLM 2007a:3-15).
As shown on Map 3-5, nine hydrologic regions have
been identified in the treatment area: Alaska, Pacific
Northwest, California, Upper Colorado, Lower
Colorado, Rio Grande, Missouri, Great Basin, and
Arkansas- White-Red (Seaber et al. 1987). Most public
lands occur in arid to semiarid environments in the
Great Basin and Colorado drainage basins. A discussion
of these hydrologic regions and their main hydrologic
resources is included in the 2007 PEIS (USDOI BLM
2007a:3- 1 1 to 3-15), and is incorporated here by
reference.
Groundwaters are more complex than surface waters in
that they occur in aquifers that are beyond our sight, can
have rapid or extremely slow flow rates, and can
recharge or discharge from streams and uplands or
alternate between discharging and recharging,
depending on a multitude of factors. Groundwaters or
aquifers can also become contaminated and can
transport contaminants over great distances very rapidly
or over thousands of years. Once contaminated, aquifers
can also be very difficult to cleanse, either naturally or
by remediation. Very shallow aquifers can release
contaminants over a matter of days, while very deep
aquifers with long flowpaths can take thousands of
years to flush, possibly longer if contaminants become
bound in the strata.
As populations in the western U.S. increase, water
availability has become a concern, particularly during
drought conditions. In the Southwest, in particular,
ongoing extraction of water from groundwater storage is
resulting in depleted aquifers. Additionally, use of
surface water is resulting in reduced flows in some
streams and rivers. Finally, there is evidence that
climate change is resulting in a shift in patterns of
precipitation, which could further exacerbate water
availability issues in certain areas (USGS 2005a).
Water Quality
Water quality is defined in relation to its specified
and/or beneficial uses, such as human consumption,
irrigation, fisheries, livestock, industry, or recreation.
The quality of surface water is determined by
interactions with soil, transported solids (organics and
sediments), rocks, groundwater, and the atmosphere.
The BLM has responsibilities to protect water quality in
accordance with mandates of the FLPMA and the Clean
Water Act, as well as other laws and regulations that
pertain to water quality. The BLM cooperates with the
USEPA, states, and tribes to meet water quality
standards. The BLM must maintain waters for
designated beneficial uses, restore impaired water
resources in support of their designated beneficial uses,
and provide water for public consumption and use
(USEPA 2013a).
Section 303(d) of the Clean Water Act requires that
water bodies violating state water quality standards and
failing to protect beneficial uses be identified and placed
on a 303(d) list (USEPA 20 1 3a). The delisting of 303(d)
listed streams is a priority of the BLM.
Nonpoint source pollution, the largest source of water
quality problems, comes from diffuse or scattered
sources rather than from an outlet, such as a pipe that
constitutes a point source. Sediment is a nonpoint
source of pollution that results from activities such as
livestock grazing and timber harvest. Erosion and
delivery of eroded soil to streams is the primary
nonpoint source pollution problem of concern to the
BLM (USDOI BLM 1980).
Additional discussion of water quality pollutants, and a
summary of baseline water quality information for
water resources in each hydrologic region, are provided
in the 2007 PEIS (USDOI BLM 2007a:3-15 to 3-18,
Maps 3-6 and 3-7).
In the western U.S., the key water quality issues limiting
water usability are the presence of elevated
concentrations of naturally occurring constituents (such
as dissolved minerals and trace elements such as
arsenic), irrigation return flows, mining, and
urbanization. Increased salinity in deep aquifers and
some surface water bodies in the arid West have made
them unsuitable sources of drinking water (USGS
2005a).
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Irrigation return flows may contain salts, trace elements,
and agrochemicals such as nitrate and pesticides. In
certain areas, irrigation water may be reused multiple
times, resulting in elevated levels of contaminants such
as selenium, boron, arsenic, mercury, and pesticides
(USGS 2005a). Herbicides can impact the quality of
both surface water and groundwater. Herbicide use in
agricultural areas accounts for approximately 70 percent
of the total national use of pesticides, and has resulted in
the widespread occurrence of these chemicals in
agricultural streams and shallow groundwater (USGS
1999).
Abandoned, inactive, and active mines can release
highly acidic and toxic mine drainage that contains
elevated levels of trace elements. These elements may
also be leached from exposed mine deposits (USGS
2005a).
Urbanization of many areas of the western U.S. has
resulted in increased wastewater return flows, as well as
increased stormwater runoff from developed areas.
Municipal treated wastewater may contain residual
herbicides and other pesticides, industrial and household
chemicals, and pharmaceuticals. Urban streams also
contain elevated concentrations of pesticides used at
residences, commercial areas, and public areas (USGS
2005a).
The most recent water quality inventories available are
the 2004 National Water Quality inventory (USEPA
2009a) for surface water, and the USGS National Water
Quality Assessment (USGS 2002 to 2012) for
groundwater. Based on the 2004 inventory, 45 percent
of stream miles in the western U.S. are in good
biological condition, compared to best-available
reference sites, 26 percent are in fair condition, and 28
percent are in poor condition. The most prevalent
stressors observed were nitrogen, phosphorus, riparian
disturbance, and streambed sediments. Nationwide, the
top sources of stream impairment were agricultural
activities, hydromodifications (e.g., water diversions,
channelization, and dam construction), and unknown or
unspecified sources.
Based on the most recent Alaska Water Quality
Assessment Report (USEPA 2010b), approximately 30
percent of inventoried river and stream miles are
classified as good waters, while approximately 70
percent are classified as impaired waters. The primary
causes of impairment are turbidity, fecal coliform, and
sedimentation/siltation, with resource extraction and
urban runoff/storm water as the primary sources of
impairment.
The USGS National Water Quality Assessment
(NAWQA) assesses trends in concentrations of
chloride, dissolved solids, and nitrate (USGS 2012). In
sampled wells in the western U.S., these pollutants
show increasing trends in some areas, relatively stable
trends in other areas, and decreasing trends in others.
Throughout much of the Great Basin, there is a stable
overall trend, with pollutants increasing in some
sampled wells but decreasing in others. In California’s
Central Valley, there is an increasing trend in all three
pollutants. In the Subtropical Desert Ecoregion there is
an increasing trend in chloride in the Rio Grande Valley
of New Mexico, and an increasing trend in dissolved
solids in the Rio Grande Valley and Central Arizona
basins. Dissolved solid concentrations are also
increasing in the Central Columbia Plateau of
Washington. In the upper Snake River Basin of Idaho,
chloride is increasing but nitrates are decreasing. One
other area showing a trend of improvement is the
Willamette Basin of Oregon, where nitrate
concentrations in groundwater are decreasing.
Pesticides have been detected in streams and
groundwater in the western U.S., and are most prevalent
in areas with substantial agricultural or urban land uses.
The NAWQA has been assessing surface water and
groundwater quality since 1991. According to the
NAWQA, pesticides are more frequently detected in
streams than in groundwater, and more frequently in
shallow wells than in deeper wells that tap aquifers. The
most commonly detected herbicides in sampled streams,
nationwide, include commonly used agricultural
herbicides and five herbicides used for nonagricultural
purposes, including three currently used by the BLM
(2,4-D, diuron, and tebuthiuron; USGS 2006). In
groundwater, compounds with relatively high mobility
and persistence have been detected most commonly,
none of which are currently used by the BLM in its
vegetation management programs.
Wetland and Riparian Areas
Wetlands are generally defined as areas inundated or
saturated by surface water or groundwater at a
frequency and duration sufficient to support vegetation
that is typically adapted for life in saturated soil.
Wetlands include bogs, marshes, shallows, muskegs,
wet meadows, estuaries, and riparian areas. The BLM
administers approximately 12.9 million acres of
wetlands. Of these, approximately 12.6 million acres are
found in Alaska (USDOI BLM 2012a).
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Riparian and wetland areas comprise approximately 5
percent of BLM lands (USDOl BLM 2012a). The
benefits of these vital areas, however, far exceed their
relatively small acreage. The functions of wetland and
riparian areas include water purification, stream
shading, flood attenuation, shoreline stabilization,
groundwater recharge, and habitat for aquatic,
semiaquatic, and terrestrial plants and animals (USEPA
2005a).
The BLM defines properly functioning wetlands as
those that: 1) support adequate vegetation, landform, or
debris to dissipate energies associated with wind action,
wave action, and overland flow from adjacent sites,
thereby reducing erosion and improving water quality;
2) filter sediment and aid floodplain development; 3)
improve floodwater retention and groundwater
recharge; 4) develop root masses that stabilize islands
and shoreline features against cutting action; 5) restrict
water percolation; 6) develop diverse ponding
characteristics to provide the habitat and the water
depth, duration, and temperature necessary for fish
production, waterbird breeding, and other uses; and 7)
support greater biodiversity (Prichard et al. 2003). This
assessment does not take into consideration the habitat
value of the wetland to fish and wildlife. It also does not
directly consider the presence of invasive plant species,
although it does assess vegetation characteristics that
can be altered by invasive species, such as structural
characteristics, age-class distribution, and species
diversity.
Ninety-eight percent of wetlands located on BLM land
are thought to be functioning properly. In Alaska, 99
percent of wetlands are considered to be in proper
functioning condition, in terms of their ability to
dissipate energy associated with high-flow events, with
the status of the remaining 1 percent unknown. Within
the lower 48 states, approximately 58 percent of
wetlands are considered to be in proper functioning
condition. Approximately 2 percent are considered to be
non- functional, 42 percent are functioning at risk, and
26 percent are unknown. Public lands with poorly
functioning wetlands tend to be located in the
southwestern U.S. For example, 15 percent of the
wetland acres in New Mexico and 14 percent of the
wetland acres in Arizona are considered non-functional
(USDOl BLM 2012a).
Riparian areas, according to the BLM, are green zones
along flowing-water features such as rivers, streams,
and creeks (Gebhardt et al. 1990). The BLM
administers approximately 155,300 miles of riparian
habitat in the treatment area. Of this, approximately
107,600 miles are found in Alaska (USDOl BLM
2012a).
It is estimated by the BLM that 42 percent of surveyed
riparian areas in the lower 48 states and 100 percent of
riparian areas in Alaska are properly functioning, in
terms of having adequate vegetation, landform, or large
woody debris present to dissipate stream energy
associated with high water flows (USDOl BLM 2012a).
Two percent of riparian areas in the lower 48 states are
considered non-functional, and 14 percent are
functioning but at risk (USDOl BLM 2012a). Poorest
functioning riparian areas are found in the Southwest,
while most riparian areas in Alaska, Colorado,
Montana, and Utah function properly.
Vegetation
The composition and distribution of plant communities
in the western U.S. have been influenced by many
factors, including climate, drought, insects, diseases,
wind, domestic livestock grazing, cultivation, browsing
by wildlife, and fire (Gruell 1983). Other activities that
have an effect on plant communities include
development, agricultural production, logging, mineral
extraction, reclamation activities, recreational activities,
and ROW development including road construction and
maintenance. In addition, non-native plant species have
invaded native plant communities, resulting in the loss
of ecosystem components in portions of the western
U.S.
Before European settlement, naturally occurring fire
was an important influence on the landscape of the
western U.S., and plant communities were adapted to
the occasional intense fires that burned over the
landscape (Gruell 1983). The exclusion of fire
following European settlement has caused significant
changes in plant species composition in the western
U.S., especially in areas adapted to fire (Swetnam
1990). Where fire-adapted communities previously
limited the expansion of pinyon, juniper, and other less
fire-tolerant species, exclusion of fire has resulted in
expansion of these species into the surrounding
ecosystems (Gruell 1983). The circumstance has also
contributed to accumulation of hazardous fuels. In
rangelands, many vegetation types have altered fire
regimes and are experiencing more frequent fires that
bum larger, more continuous areas, which has
contributed to the expansion of invasive grasses and
forbs. Invasive annual grasses have increased the
incidence of fires in sagebrush communities adapted to
infrequent fires, and have reduce the fire return
BLM Vegetation Treatments Three New Herbicides
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AFFECTED ENVIRONMENT
frequency to such an extent that portions of sagebrush
steppe have been converted to grassland.
Vegetation Classification System
In the 2007 PEIS, vegetation within the treatment area
was classified into 14 subclasses, consistent with the
1997 National Vegetation Classification Standard (see
USDOl BLM 2007a:3-19, Table 3-4). This standard
differentiated vegetation on the basis of growth form,
life history strategy, and percent of canopy closure or
hydrologic influences (Federal Geographic Data
Committee 1997), with important subclasses then
described by ecoregion (USDOl BLM 2007a:3-19 to 3-
25).
In 2008, a new, dynamic standard was adopted (Federal
Geographic Data Committee 2008), which the BLM is
currently using for all Resource Management Plans. The
new standard classifies vegetation based on floristic
(species-based) and physiognomic (growth form-based)
properties. Table 3-4 summarizes important
macrogroups within likely BLM vegetation treatment
areas, as well as their associated classes, subclasses,
formations, and divisions. The majority of future
vegetation treatments are likely to occur within these
macrogroups. A complete list of macrogroups within
the 17-states analysis area is provided in Appendix D,
along with brief descriptions of key macrogroups by
ecoregion.
As shown in Table 3-4, the new classification
incorporates climate and geographic location into its
hierarchy. Original vegetation descriptions in the 2007
PEIS considered ecoregion as well as vegetation
classifications. For the sake of clarity and consistency,
this PEIS will follow a similar approach to the earlier
PEIS for assessing impacts to vegetation. However, the
new classification system groupings will be introduced
into the analysis as appropriate.
Based on the BLM’s past vegetation treatment
activities, and future vegetation treatment goals, the
following macrogroups, by ecoregion, are the most
likely locations of future herbicide treatments.
Additional descriptions of vegetation within each
ecoregion can be found in the 2007 PEIS (USDOl BLM
2007a:3-19 to 3-25).
Tundra and Subarctic Ecoregions
Only very limited herbicide treatments are currently
proposed for macrogroups within these ecoregions, but
more may occur in them in the future. Regardless, the
vegetation macrogroups in this ecoregion are unlikely to
constitute more than a small fraction of the areas
receiving herbicide treatments.
Temperate Desert Ecoregion
The Temperate Desert Ecoregion includes the arid
shrublands and grasslands of the Great Basin and the
Rocky Mountains, as well as lower montane forests and
pinyon-juniper woodlands.
As far as locations of likely future herbicide treatments,
important macrogroups that occur in the Temperate
Desert Ecoregion include shrublands, grasslands, and
sagebrush shrubland and steppe. Rocky Mountain and
intermountain forests and woodlands are also important,
to a lesser degree.
Great Basin and Intermountain Dry Shrubland
and Grassland
The shrubland-steppe and grasslands in this macrogroup
occur throughout the Colorado Plateau and Arizona-
New Mexico Mountains, west to the Mojave Desert,
and north to the Wyoming Basin. The shrubland-steppe
is either shrub-dominated, dwarf shrub-dominated, or
grass-dominated with a sparse shrub layer. The
grasslands are located throughout the intermountain
western U.S., as a matrix over large areas of
intermountain basins and in mosaics with semi-desert
shrublands. The dominant perennial bunchgrasses and
shrubs of these grasslands are drought-resistant.
Great Basin and Intermountain Tall Sagebrush
Shrubland and Steppe
This macrogroup consists of shrublands and shrub-
steppe that are widely distributed from the Great Basin,
Columbia River Basin, Colorado Plateau, northern
Rocky Mountains, and northwestern Great Plains, as far
east as the Dakotas. Climate ranges from arid to
subhumid. Stands are dominated by Wyoming big
sagebrush and basin big sagebrush, sometimes along
with other shrub species. The herbaceous layer can be
sparse to strongly dominated by graminoids.
Northern Rocky Mountain-Vancouverian
Montane and Foothill Grassland and Shrubland
This macrogoup is comprised of shrublands in the lower
montane and foothill regions around the Columbia
Basin and north and east into the Northern Rocky
Mountains, and dry grasslands occurring in the canyons
and valleys of the northern Great Basin and Columbia
BLM Vegetation Treatments Three New Herbicides
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TABLE 3-4
Vegetation Classification System
AFFECTED ENVIRONMENT
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BLM Vegetation Treatments Three New I lerbicides
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January 2016
TABLE 3-4 (Cont.)
Vegetation Classification System
AFFECTED ENVIRONMENT
BLM Vegetation Treatments Three New TIerbicides
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AFFECTED ENVIRONMENT
Basin. The shrublands occur within a matrix of low-
elevation grasslands and sagebrush shrublands. The
grasslands consist of patchy graminoid cover, cacti, and
some forbs.
Southern Rocky Mountain Montane Grassland
and Shrubland
The shrublands in this macrogroup are dominated by
Utah serviceberry, alderleaf mountain mahogany, or
Gambel oak. The macrogroup extends from the
southern and central Great Plains, southwest to southern
New Mexico, extending north into Wyoming, and west
into the Intermountain West region.
Northern Rocky Mountain Lower Montane and
Foothill Forest
The ponderosa pine woodlands and “wooded steppes”
in this macrogroup are located in the foothills of the
northern Rocky Mountains in the Columbia Plateau
region and west along the foothills of the Modoc
Plateau and Eastern Cascades into southern interior
British Columbia, and east across Idaho into the eastern
foothills of the Rocky Mountains. The woodlands and
wooded steppes occur at the lower treeline/ecotone
between grasslands or shrublands and more moist
coniferous forests, typically on warm, dry, exposed
sites. The macrogroup also includes ponderosa pine
woodlands that occur along the eastern face of the
Rocky Mountains and into the Great Plains.
Southern Rocky Mountain Lower Montane Forest
This macrogroup consists of forests dominated by
ponderosa pine, either solely or mixed with other
coniferous species. Mixed forests typically have a shrub
understory, while forests dominated solely by ponderosa
pine typically have a grass-dominated understory.
Intermountain Singleleaf Piny on-Western
Juniper Woodland
This macrogroup consists of pinyon-juniper woodlands
that occur on dry mountain ranges of the Great Basin
and eastern foothills of the Sierra Nevada. They are
dominated by singeleaf pinyon, Utah juniper, or western
juniper. This macrogroup includes woodlands that have
expanded from their historical ranges into grasslands,
steppe, and shrub-steppe habitats, primarily as a result
of fire exclusion and livestock grazing.
Rocky Mountain Two-Needle Pinyon-Juniper
Woodland
This macrogroup includes pinyon-juniper woodlands
that occur on dry mountains and foothills of the
Colorado Plateau region, along the east and south
foothill slopes of the southern Rocky Mountains and
into the plains of southeastern Colorado and northern
central New Mexico, on dry mountains and foothills in
southern Colorado east of the Continental Divide, and in
mountains and plateaus of northern and central New
Mexico. Dominant species include two-needle pinyon,
Utah juniper, or oneseed juniper. This macrogroup
includes some woodlands that have expanded into
adjacent grasslands and become denser.
Temperate Steppe Ecoregion
The Temperate Steppe Ecoregion occurs in a semiarid
continental climate zone, and includes the Rocky
Mountains and the Great Plains. Most of the important
macrogroups in this ecoregion also occur in the
Temperate Desert Ecoregion and were described in the
previous subsection. They include many of the Rocky
Mountain grassland, shrubland, and forest, and pinyon-
juniper woodland macrogroups listed in Table 3-4 (see
Appendix D). Additionally, they include the grassland
and shrubland macrogroups of the Great Plains.
Great Plains Mixedgrass Prairie and Shrubland
This macrogroup consists of mesic and dry mixed grass
prairies of the Great Plains. On mesic sites they are a
mixture of mostly mixed grass prairie with some
tallgrass prairie. Graminoids such as western
wheatgrass, green needlegrass, big bluestem, and Idaho
fescue are dominant. With intensive grazing, cool-
season non-native species such as Kentucky bluegrass,
smooth brome, and field brome can increase in
dominance. Shrub species can increase in dominance
with fire suppression. The dry mixed grass prairies
occur on flat to rolling topography, and are dominated
by moderate to moderately dense medium-tall grasses
and scattered shrub.
Great Plains Shortgrass Prairie and Shrubland
This macrogroup includes shortgrass prairies dominated
by blue grama and buffalograss, and shrublands
dominated by honey mesquite. They occur on flat to
rolling uplands, and are characterized by a moderate to
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
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AFFECTED ENVIRONMENT
dense sod of short grasses, with scattered mid grasses
and forbs. The shortgrass prairies occur in the rain
shadow of the Rocky Mountains and range from the
Nebraska Panhandle south into Texas and New Mexico.
The shrublands occur primarily in Texas, Oklahoma,
and eastern New Mexico.
Subtropical Steppe
The Subtropical Steppe Ecoregion includes the plateaus
and high plains of northern Arizona, New Mexico, and
Texas. It supports a semiarid climate, and consists of
primarily perennial grassland communities, with some
shrublands and woodlands. Macrogroups that are most
likely to be targeted by vegetation treatments are Warm
Interior Chapparal, Rocky Mountain Two-Needle
Pinyon-Juniper Woodland, and Chihuahuan Desert
Scrub.
Warm Interior Chaparral
This macrogroup occurs in the northern Chihuahuan
Desert and adjacent Sky Islands and Sonoran Desert,
extending into limited areas of the southern Great
Plains. Vegetation consists of moderately dense to
dense grasslands, sometimes with scattered shrubs or
succulents.
Rocky Mountain Two-Needle Pinyon-Juniper
Woodland
These woodlands have two-needle pinyon, Utah juniper,
or oneseed juniper as the dominant species. Within the
subtropical steppe ecoregion they occur in mountains
and plateaus of northern and central New Mexico.
Chihuahuan Desert Scrub
The Chihuahuan Desert shrublands are concentrated in
the extensive desert grassland in foothills and piedmonts
of the Chihuahuan Desert, extending into the Sky Island
region to the west. Areas occupied by this macrogroup
generally saw a shift from the original perennial
grasslands to shrub-dominated communities. Possible
causes of the shift include livestock grazing, climatic
change, and fire suppression. Vegetation consists of
desert scrub species, with honey mesquite or velvet
mesquite and succulents as dominants.
Subtropical Desert
The Subtropical Desert Ecoregion occupies southeast
California, southern Nevada, Arizona, New Mexico,
and western Texas, and includes the Chihuahuan,
Sonoran, and Mojave Deserts. Vegetation is adapted to
dry conditions, and includes numerous xerophytic
plants. Since only a small fraction of the BLM’s
herbicide treatments occur in this ecoregion, no
discussion of individual macrogroups is presented here.
This information can be found in Appendix D.
Mediterranean
The Mediterranean Ecoregion Division occupies most
of California (excluding deserts in the southeastern
portion of the state) and a portion of southern Oregon. It
supports chaparral communities, coniferous forests, and
oak woodlands, among other vegetation types. Based on
the BLM’s treatment program goals, important
macrogroups in this ecoregion are certain forests and
woodlands.
California Forest and Woodland
This macrogroup consists of savannas, woodlands, and
forests dominated by Californian endemic oak and
conifer species. These habitats occur almost entirely
within California below 8,000 feet.
Calif ornian-Vancouverian Foothill and Valley
Forest and Woodland
These forests and woodlands occur along the Pacific
Coast lowlands from southern California to southern
British Columbia. They occur inland from the coast, in
the dry interior lowland valleys, and are drought
tolerant.
Southern Vancouverian Montane and Foothill
Forest
The forests and woodlands of this macrogroup occur in
the foothills and lower montane elevations of the
southern Cascade and Klamath Mountains, the Modoc
Plateau, and the Sierra Nevada, Peninsula, and
Transverse Ranges. This macrogroup covers a broad
range of elevations. It includes dry montane Jeffery
pine-ponderosa pine woodlands, Sierran mixed conifer
woodlands, and mixed conifer woodlands tolerant of
serpentine soils, among others.
Marine
The Marine Ecoregion Division occupies the Cascade
and Coast Ranges of western Washington and Oregon,
and the coast mountains of southeastern Alaska, along
the Pacific Coast. The mild, rainy climate produces
conditions that are hospitable for dense forest
BLM Vegetation Treatments Three New I lerbicides
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AFFECTED ENVIRONMENT
communities, which are characteristic of this region.
Most treatments are in ROWs where the vegetation is
managed in an early serai condition. Since only a small
fraction of the BLM’s herbicide treatments occur in this
ecoregion, no discussion of individual macrogroups is
presented here. This information can be found in
Appendix D.
Noxious Weeds and other Invasive
Vegetation
Invasive plants are non-native species that may cause
physical or environmental damage or have other
adverse effects on humans. Invasive plants include
noxious weeds, which are designated by federal, state,
or county government as injurious to public health,
agriculture, recreation, wildlife, or property. Infestations
of invasive plants are capable of degrading wildlife
habitat; reducing plant and animal diversity; displacing
many threatened and endangered species; and reducing
opportunities for hunting, fishing, camping and other
recreational activities; and may cost millions of dollars
in treatments and loss of productivity to land owners.
Besides ecological and economic costs, invasive plants
can cause impacts to public safety. A few native
species, such as junipers, exhibit similar behavior,
contributing to hazardous fuels and reducing
groundwater through evapotranspiration.
The 2007 PEIS discusses the traits of invasive plants
and their mechanisms of invasion (USDOI BLM
2007a:3-26 to 3-27).
BLM Infestations
The estimated rate of weed spread on public lands is
4,300 acres per day (USDOI BLM 2012c). An estimate
of weed spread on all western federal lands is 10
percent to 15 percent annually (Asher and Dewey
2005).
Table 3-5 shows gross estimates of acres of infestation
of key invasive plant species targeted for treatment by
the BLM. These estimates were compiled by the BLM
from data provided by individual field offices during a
2014 inventory. Based on this inventory, total estimated
acres of invasive plant infestations on public lands in
the western U.S. states exceeds 79 million acres (more
than 30 percent of total land acres). States with the
largest infestations are Nevada, Oregon, Utah, and
Idaho. The most prevalent invasive plant species are
annual grasses, which represent nearly 70 percent of the
total infested areas. Other species/groups that occupy
more than 100,000 acres include thistles, halogeton,
knapweeds, woody species (Russian olive and
tamarisk), mustards (hoary cress, perennial pepperweed,
and Dyer’s woad), leafy spurge, toadflaxes, and
starthistles. The BLM treated approximately 260,000 to
436,000 acres of invasive plants using herbicides during
2006 through 2012. States with the greatest acreage
treated during this time period were New Mexico,
Idaho, Wyoming, Nevada, and Oregon.
Vegetation Condition and Fire
Regimes
The fire regime condition class (FRCC) is used by the
BLM to help describe common issues on public lands,
such as altered disturbance regimes, invasive species, or
highly altered plant communities. The FRCC classifies
land based on the degree of departure from historical
fire regimes.
The BLM currently uses the Fire Regime Condition
Class Mapping Tool, Version 2.2.0, to determine and
map FRCC on public lands. The FRCCs reflect the
current conditions’ departure from modeled reference
conditions. Three FRCCs have been defined, as follows
(National Interagency Fuels Technology Transfer
2010):
Condition Class 1 lands (approximately 58.9 million
acres of public lands) are within the natural or historical
range of variation, and risk of losing key components is
low. Vegetation attributes (composition and structure)
are intact and functioning.
Condition Class 2 lands (approximately 84.6 million
acres) have fire regimes that have been moderately
altered from their historical conditions. They experience
either an increased or decreased fire frequency of one or
more return intervals, potentially resulting in moderate
changes in fire and vegetation attributes.
Condition Class 3 lands (approximately 82.6 million
acres) have fire regimes that have been substantially
altered, and the risk of losing key components to fire or
other causes is high. Fire frequencies may have departed
by multiple return intervals from historical fire regimes,
potentially resulting in dramatic changes in fire size,
intensity, and severity, as well as changes in landscape
patterns. Vegetation attributes have been substantially
altered.
BLM Vegetation Treatments Three New Herbicides
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AFFECTED ENVIRONMENT
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BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
3-18
January 2016
AFFECTED ENVIRONMENT
Map 3-6 shows the breakdown of FRCCs on public
lands. Note that not all public lands fall into one of these
categories. Based on Vegetation Condition Class data
from Landfire (2010 and 2011), more than 58 percent
(48 million acres) of the Condition Class 3 lands occur
in the Temperate Desert Ecoregion, which is a
substantial increase from the 21 million acres reported
in the 2007 PEIS (USDOI BLM 2007a:3-29).
Approximately 18 million acres (21.5 percent) of
Condition Class 3 lands occur in the Subtropical Desert
Ecoregion, which is a slight increase from the number
reported in the 2007 PEIS. Condition Class 3 areas are
less prevalent in the remaining ecoregions: 4.9 million
acres occur in the Temperate Steppe Ecoregion, 3.2
million acres occur in the Subtropical Steppe Ecoregion,
3.1 million acres occur in the Subarctic Ecoregion, 3.0
million acres occur in the Tundra Ecoregion, 1.5 million
acres occur in the Mediterranean Ecoregion, and 0.67
million acres occur in the Marine Ecoregion.
The fire regime group is another mapping tool utilized
by the BLM that characterizes the presumed historical
fire regimes within landscapes based on interactions
between vegetation dynamics, fire spread, fire effects,
and spatial context (Barrett et al. 2010). A natural fire
regime is a general classification of the role fire would
play across a landscape in the absence of modem
human mechanical intervention (Agee 1993; Brown
1995 in Barrett et al. 2010). Five natural fire regime
groups have been developed based on the average
number of years between fires, combined with fire
severity (Barrett et al. 2010):
Fire Regime Group 1 - 0 to 35 year frequency, low to
mixed severity.
Fire Regime Group II - 0 to 35 year frequency,
replacement severity.
Fire Regime Group III - 35 to 200 year frequency,
low to mixed severity.
Fire Regime Group IV - 35 to 200 year frequency,
replacement severity.
Fire Regime Group V - 200+ year frequency, any
severity.
More fire is generally desired in groups I through III
where fire was historically more frequent. In groups IV
and V, too much fire has generally occurred on BLM
lands and fire-adapted invasive plant species are
prevalent.
Of the public lands categorized under the fire regime
group classification, the majority (66 percent) are in
group IV or V, with 44 percent in groups I through III.
Most public lands where fire is occurring much more
frequently than historically are found in the Temperate
Steppe (45 percent) and Temperate Desert (30 percent)
ecoregions.
Non-timber and Special Forest
Products
Special forest products include plant materials, fungi,
and bryophytes (mosses, liverworts, and homworts).
They consist of firewood, biomass, medicinal plants
(e.g., ginseng and goldenseal), wild foods (e.g.,
mushrooms, berries, roots, and syrups), decoratives and
floral greens (e.g., salal, ferns, and evergreen boughs),
flavors and fragrances (e.g., sassafras and balsam fir),
fibers (e.g., cedar bark, sweetgrass, and lichens), wild
native seeds, and transplants for restoration and nursery
stock. Special forest products are harvested for a variety
of reasons, including subsistence, cultural, spiritual,
commercial, recreational, and educational purposes.
During FY 2011, approximately $270,000 worth of
non-timber forest products were sold by the BLM in
western states. The actual value of non-timber forest
products harvested on public lands is substantially
greater (USDOI BLM 2012a). Nearly half of non¬
timber forest product sales on public lands were in
western Oregon, and about 1 8 percent were in Nevada.
Other important states for non-timber forest product
sales are Colorado and Utah.
Special Status Species
BLM special status species are: 1) species listed or
proposed for listing under the ESA, and 2) species
requiring special management consideration to promote
their conservation and reduce the likelihood and need
for future listing under the ESA. According to BLM
policy, BLM actions must not adversely impact special
status species. There are more than 150 plant species
occurring on or near public lands in the treatment area
that are federally listed as threatened or endangered, or
proposed for listing. The number may change over time
depending on future evaluations of each species’ status.
Special status plant species are distributed throughout
the western U.S., including Alaska. A list of these
species can be found in Appendix E.
BLM Vegetation Treatments Three New Herbicides
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AFFECTED ENVIRONMENT
For this PEIS, the BLM has consulted with the USFWS
and NMFS on listed species and species proposed for
listing, and their critical habitat, that could be affected
by the proposed treatments. As part of the consultation
process, the BLM prepared a BA, which provides a
description of the distribution, life history, and current
threats for each species (USDOI BLM 2015).
Information contained in the BA will be used as a
guideline by BLM field offices when developing local
projects.
Fish and Other Aquatic
Organisms
The BLM administers lands directly affecting almost
117,000 miles of fish-bearing streams and almost 3
million acres of reservoirs and natural lakes (USDOI
BLM 2012b). These habitats range from isolated desert
springs of the Southwest to large interior rivers and their
numerous tributaries.
Key fish species that occur in aquatic habitats in or
adjacent to BLM-administered lands are discussed in
the 2007 PEIS, by geographic region (USDOI BLM
2007a:3-30 to 3-35).
Special Status Species
Nearly 80 aquatic animal species occurring on or near
public lands are federally listed as threatened or
endangered, or are proposed for future listing. Included
in the total number are 61 species/subspecies of fish, 1 1
species of mollusk, and 7 aquatic arthropods. A
complete list of these special status species can be found
in Appendix E. Please note that this list is dynamic, and
will likely change throughout the time period
considered by this PEIS.
Special status aquatic animal species are found on
public lands throughout the U.S. Numerous listed
salmon populations are found in rivers of the Pacific
Coast states. In arid areas, many special status fish
species are found in the rare and fragile desert wetlands
and springs, as well as in the major rivers such as the
Colorado and the Rio Grande. In the deserts of the Great
Basin and Colorado Plateau, terminal lakes, marshes,
and sinks provide important habitat for special status
fish species that are adapted to their warm, saline
conditions.
Special status mollusks occur predominantly in the
Snake River of Idaho, and in thermal habitats and small
springs and wetlands in New Mexico, Arizona, and
Utah. Aquatic arthropods of special concern occur
predominantly in the vernal pools of California.
Wildlife Resources
Public lands sustain an abundance and diversity of
wildlife and wildlife habitat. Public lands provide a
permanent or seasonal home for more than 3,000
species of amphibians, reptiles, birds, and mammals.
Wildlife populations are found in areas where their
basic needs — food, shelter, water, reproduction, and
movement — are met. The area in which the needs of a
particular population are met is its habitat. Many
animals have special behaviors and physical traits that
allow them to successfully compete with other animals
in only one or a few habitats; many threatened and
endangered species fall into this category. Other
animals, such as mule deer, coyote, and American robin
are less specialized and can use a wider range of
habitats.
Several features make some habitats better for wildlife
than others. In turn, the more of these features that are
present, the greater the diversity of wildlife species that
are likely to be present. These features include:
• Structure - shape, height, density, and diversity
of the vegetation and other general features of
the terrain.
• Vertical layers - layers of vegetation (e.g.,
herbaceous, shrub, and forest canopy).
• Horizontal zones - vegetation and other habitat
features that vary across an area.
• Complexity - an integration of vertical layers
and horizontal zones.
• Edge - the area where two types of vegetative
communities meet, such as a forest and shrub
community.
• Special features - unique habitat features
needed for survival or reproduction, including
snags (dead trees), water, and rock outcrops.
For inventory and management purposes, the BLM
divides wildlife habitat based on land cover types:
Outside of Alaska, the vast majority of wildlife habitat
is in the shrub-scrub category, with herbaceous and
evergreen forest the next most abundant habitat types.
In Alaska, dwarf shrub, shrub-scrub, evergreen forest.
BLM Vegetation Treatments Three New Herbicides
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AFFECTED ENVIRONMENT
and sedge/herbaceous are the most abundant habitat
types (USDOI BLM 20 1 2a).
The BLM inventories a portion of its rangelands. The
BLM’s Rangeland health standards include levels of
physical and biological condition or degree of function
required for healthy lands and sustainable uses, as
defined in BLM Handbook H-4 180-1 ( Rangeland
Health Standards', USDOI BLM 2001). Of lands that
have been inventoried for rangeland health, 56 percent
are rated as meeting standards for rangeland health or
making significant progress toward meeting these
standards. The remaining 44 percent of evaluated lands
do not meet rangeland health standards, or are not
making significant progress toward meeting the
standards for various reasons. Livestock have been
determined to be a significant factor affecting rangeland
health on 29 percent of inventoried lands (BLM 2013d).
Based on a 2006 report, approximately 26 percent of
BLM-administered lands are forested. The most
common forest habitats are pinyon-juniper woodlands,
juniper woodlands, and Douglas-fir forests (USDOI
BLM 2006).
The BLM manages vegetation to improve wildlife
habitat. Plants, which are an important component of
habitat, provide food and cover. Food is a source of
nutrients and energy, while cover reduces the loss of
energy by providing shelter from extremes in wind and
temperature, and also affords protection from predators.
The important characteristics of wildlife and habitat in
the eight ecoregions that comprise the treatment area are
presented in the 2007 PEIS (USDOI BLM 2007a:3-36
to 3-43).
Special Status Species
There are 65 terrestrial animal species occurring on or
near public lands in the treatment area that are federally
listed as threatened or endangered, or proposed for
listing. Included in the total number are 9 species of
arthropod, 7 species of amphibian, 5 species of reptile,
16 species of bird, and 28 species of mammal. A
complete list of special status animal species may be
found in Appendix E. Please note that this list is
dynamic, and will likely change throughout the time
period considered by this PEIS.
Special status animal species are found on public lands
throughout the U.S. Special status arthropods are largely
butterflies that occur mostly in open habitats. Special
status amphibians occur in wetland habitats throughout
the West, and special status reptiles occur in warm
habitats of California and the Southwest. Special status
birds and mammals use a wide range of habitats found
on public lands throughout the western U.S.
Livestock
Approximately 155 million acres of public lands are
available for livestock grazing. The majority of the
grazing pennits issued by the BLM involve grazing by
cattle, with fewer and smaller grazing permits for other
kinds of livestock (primarily sheep and horses).
The BLM administers grazing lands under 43 CFR Part
4100 and BLM Manual MS-4100 ( Grazing
Administration - Exclusive of Alaska', USDOI BLM
2009a). For management purposes, lands that are
available for livestock grazing are divided into
allotments and pastures. The BLM administers nearly
18,000 permits and leases for grazing on more than
21,000 allotments under BLM management. Permits
and leases generally cover a 10-year period and are
renewable if the BLM determines that the terms and
conditions of the expiring permit or lease are being met.
The grazing permit establishes the allotment(s) to be
used, the total amount of use, the number and kind of
livestock, and the season of use. The grazing permit
may also contain terms and conditions as appropriate to
achieve management and resource condition objectives.
Allotment management plans further outline how
livestock grazing is managed to meet multiple-use,
sustained-yield, and other needs and objectives, as
determined through land use plans.
Geographically specific rangeland health standards and
guidelines are identified for each state to help direct the
grazing program for those states. The BLM conducts
reviews of land within its jurisdiction to determine the
level of compliance with rangeland health standards. As
of 2012, the BLM had inventoried approximately 126
million acres of rangeland. As stated previously,
approximately 56 percent of inventoried rangelands are
meeting all standards for rangeland health or making
significant progress toward meeting these standards
(BLM 2013d).
Public lands provide forage for many ranches and help
to support the agricultural component of many
communities scattered throughout the West. As of
October 2011, the total number of grazing
permits/leases in force was 17,694, with a total of 12.4
million Animal Use Months (AUMs) authorized (Table
3-6; USDOI BLM 2012a). There has been a gradual
decrease in the amount of grazing on BLM-
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AFFECTED ENVIRONMENT
administered lands, from 18.2 million AUMs in 1954 to
8.9 million AUMs in 2012 (USDOI BLM 2013e). In
most years the actual use of forage is less than the
amount authorized.
TABLE 3-6
Grazing Permits and Leases in Force and Active
Animal Unit Months in 201 1
State
Leases and
Permits
Active AUMs
Arizona
770
642,288
California
526
314,442
Colorado
1,471
584,901
Idaho
1,866
1,352,781
Montana
3,764
1,269,161
Nebraska
18
592
Nevada
684
2,120,374
New Mexico
2,272
1,847,960
North Dakota
79
9,279
Oklahoma
4
132
Oregon
1,231
1,023,040
South Dakota
472
73,223
Utah
1,452
1,190,920
Washington
265
33,073
Wyoming
2,820
1,925,583
Total
17,694
12,387,749
Source: BLM Public Land Statistics (USDOI BLM 2012a).
Wild Horses and Burros
The BLM, in conjunction with the Forest Service,
manages wild horses and burros on BLM- and Forest
Service-administered lands through the Wild Free-
Roaming Horse and Burro Act of 1971. As of June
2014, the free-roaming wild horse and burro population
was approximately 49,200 animals, with another 48,000
animals held in holding pens (Table 3-7; USDOI BLM
2014a). The population of free-roaming wild horses and
burros is nearly 22,500 animals above the Appropriate
Management Level (AML) of 26,500. The AML is an
estimate of the number of wild horses and burros that
can graze on public lands without causing damage to the
range.
Animals are managed within 179 wild horse and burro
Herd Management Areas (HMAs; USDOI BLM
2012b). Wild horse herds grow at an average rate of 20
percent annually. Management is accomplished by
carefully controlling horse and burro populations so that
their numbers do not exceed the carrying capacity of the
land. This is done primarily by gathering animals
periodically so that numbers are near the AML. Fertility
control is being used in some HMAs as a means to
reduce the population growth rate.
When horse and burro populations begin to exceed the
AML, excess animals are gathered and offered to the
public through periodic adoption. In FY 2011, 2,844
wild horses and burros were adopted in the U.S. Thirty-
three percent of these were adopted in the eastern U.S.
More than 227,000 animals have been adopted since
1971 (USDOI BLM 2012a). Public lands inhabited by
wild horses or burros are closed to grazing under permit
or lease by domestic horses and burros. The Wild Free-
Roaming Horse and Burro Act of 1971 mandates that
wild horses and burros can only be managed in areas
where they were found in 1971. Those that stray onto
non-designated public and/or private lands are removed.
Paleontological and Cultural
Resources
Paleontological Resources
The BLM is responsible for managing public lands and
their various resources so that they are utilized in a
manner that will best meet the present and future needs
of this Nation. The western U.S. has a fossil record that
includes almost all of the geologic periods from the
Cambrian (500+ million years ago) to the Holocene
(Recent; from approximately 11,000 years before the
present [BP]), and nearly every imaginable ancient
environment. Many fossil deposits are of national and
international importance. It is estimated that there are
more than 50,000 fossil sites documented on public
lands. More information on paleontological resources
and their management is provided in the 2007 PEIS
(USDOI BLM 2007a:3-45 and Table 3-8).
Cultural Resources
Cultural resources include archaeological, historic, or
architectural sites, structures, or places with important
public or scientific uses, and may include definite
locations (sites or places) of traditional cultural or
religious importance to specific social or cultural
groups. The BLM locates, classifies, and ranks cultural
resources, and manages them according to their relative
importance, to protect significant cultural resources
from inadvertent loss, destruction, or impairment, and to
encourage and accommodate the appropriate uses of
these resources through planning and public
participation.
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AFFECTED ENVIRONMENT
TABLE 3-7
Wild Horses and Burros on Public Lands in Fiscal Year 2013
State
Wild Horses
Wild Burros
Total
Maximum AML
Arizona
333
4,411
4,744
1,676
California
4,086
1,922
6,008
2,184
Colorado
1,205
0
1,205
812
Idaho
668
0
668
617
Montana, North Dakota, and South Dakota
160
0
160
120
Nevada
23,347
1,688
25,035
12,796
New Mexico, Oklahoma, and Texas
146
0
146
83
Oregon and Washington
3,120
60
3,180
2,715
Utah
3,979
313
4,292
1,956
Wyoming and Nebraska
3,771
0
3,771
3,725
Total
40,815
8,394
49,209
26,684
Source: USDOI BLM 2014a.
TABLE 3-8
Cultural Resources on Public Lands
State
Number of
Acres
(in millions)
Number of
Acres
Surveyed
Percent of
Acres
Surveyed
Number of
Properties
Recorded
Alaska
72.4
179,759
0.2
3,831
Arizona
12.2
980,953
8.0
13,953
California
15.3
2,135,675
14.0
34,522
Colorado
8.3
1,838,771
22.2
47,035
Idaho
11.6
2,581,358
22.3
17,753
Montana, North Dakota, and South Dakota
8.3
1,522,922
18.3
11,389
Nevada
47.8
3,000,829
6.3
57,688
New Mexico, Oklahoma, and Texas
13.6
1,771,607
13.0
39,209
Oregon and Washington
16.5
1,880,146
11.4
15,578
Utah
22.8
2,794,218
12.3
50,679
Wyoming and Nebraska
18.4
3,249,624
17.7
49,424
Total
247.2
21,935,862
8.9
341,061
Source: BLM Public Land Statistics (USDOI BLM 2008b, 2009b, 2010a, 201 1, 2012a, 2013a).
The cultural heritage for public lands administered by
the BLM in 17 western states extends back to
approximately 13,000 years BP. As one moves forward
in time, the number and variety of sites increases mainly
as a result of the increase in Native populations and,
after 500 BP or so, European and Euroamerican
immigration.
Table 3-8 summarizes the number of acres of public
lands inventoried for cultural resources, the number of
properties found on public lands, and the number of
properties listed in the National Register of Historic
Places (NRHP).
American Indian and Alaska Native
Cultural Resources
A brief review of the archaeology and ethnography of
culture areas within the study area was provided in the
2007 PEIS (USDOI BLM 2007a:3-45 to 3-53). This
review covers the Arctic and Subarctic (Alaska), the
Northwest Coast, the Southwest, the Great Basin, the
Plateau, California, and the Plains Culture Areas. Table
3-9 provides a summary of this information.
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AFFECTED ENVIRONMENT
TABLE 3-9
Culture Areas, Prehistoric Occupation Periods, and Selected Common Site Types
Culture
Area
Paleoindian
Middle Period or Archaic
Late or Sedentary Period
Arctic and
Subarctic
13,000+ to 9,000 B.P.
Open campsites
Cave or rockshelter occupation sites
Animal kill and lithic processing sites
9,000 to 6,000 B.P.
Semi -subterranean houses
Open campsites and tent camps
6,000 to 250 B.P.
Semi-subterranean house villages
Open campsites and tent camps
Northwest
Coast
12,500+ to 6,000 B.P.
Open campsites
Cave or rockshelter occupation sites
6,000 to 250 B.P.
Large, cedar plank pithouse villages
Fortified sites
Seafood capture or processing sites
Pictograph and petroglyph sites
California
11,000(7) to 8,000 B.P.
Open campsites
Animal kill or processing sites
8,000 to 5,000 B.P.
Open campsites and coastal villages
Plant or seafood processing sites
5,000 to 250 B.P.
Large coastal villages
Burial mounds
Extensive seafood, sea mammal, and
plant processing sites
Pictograph and petroglyph sites
Great
Basin
11,500+ to 8,000 B.P.
Open campsites
Cave occupation sites
Lithic processing sites
8,000 to 4,000 B.P.
Cave or rockshelter occupation sites
Pithouse villages
Plant and lithic processing sites
Fishing sites
4,000 to 250 B.P.
Cave or rockshelter occupation sites
Small pithouse villages
Plant and lithic processing sites
Storage pits
Pictograph and petroglyph sites
Southwest
11,500 to 8,000 B.P.
Open campsites
Animal kill and lithic processing sites
Cave occupation sites
8,000 to 2,000 B.P.
Open campsites
Cave or rockshelter occupation sites
Pithouses and storage pits
Waddle and daub structures
Lithic processing sites
Pictograph and petroglyph sites
2,000 to 250 B.P.
Pithouse villages
Storage pits
Above-ground structures (Pueblos)
Below-ground structures (Kivas)
Irrigation ditches and roads
Navajo hogans and pueblitos
Pictograph and petroglyph sites
Plains
12,000 to 8,000 B.P.
Open campsites
Cave or rockshelter occupation sites
Animal kill and lithic processing sites
8,000 to 2,000 B.P.
Open campsites
Cave or rockshelter occupation sites
Pithouses and storage pits
Tipi ring sites
Cairns and cairn lines
Animal kill, lithic, and plant processing
sites
2,000 to 250 B.P.
Open campsites and tipi ring sites
Waddle and daub structures
Earthlodge villages
Burial mounds
Storage pits
Cave or rockshelter occupation sites
Small pithouse villages
Cairns and cairn lines
Animal kill, lithic, and plant
processing sites
Pictograph and petroglyph sites
Plateau
12,500 to 8,000 B.P.
Open campsites
Cave or rockshelter occupation sites
Fishing sites
Lithic processing sites
8,000 to 4,000 B.P.
Open campsites
Small pithouse villages
Cave occupation sites
Animal or fish processing sites
Lithic processing sites
Plant processing sites
4,000 to 250 B.P.
Pithouse and longhouse villages, often
with burials
Open campsites
Cave occupation sites
Storage pits
Animal or fish processing sites
Lithic and plant processing sites
Pictograph and petroglyph sites
BLM Vegetation Treatments Three New Herbicides
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AFFECTED ENVIRONMENT
European Settlement Resources
The earliest Euro-American contacts with the western
U.S. and Alaska, which typically began with
exploration or trading, started in the 1500s in the
Southwest and California. By the late 1700s and early
1800s much of what is now the western U.S. was being
traversed by explorers and fur traders. A summary of
these encounters and the European settlement resources
present with the seven culture areas is provided in the
2007 PEIS (USDOl BLM 2007a:3-54 to 3-56).
Public lands in the West contain cultural resources
representing all major periods and events in the broad
sweep of Euro-American history. The most common
rural manifestations of these dominant themes include
transportation resources such as ferry sites, railroads,
trails, and roads; military sites (training grounds and
battlefields); and mining resources related to exploration
(prospect pits), extraction (adits, hydraulic cuts, and
quarries), and processing (smelters and mills). Other
resources include homesteading, ranching, and farming
resources (human and animal shelter and irrigation
development); fishery resources (boats, fish traps, and
weirs); and logging resources (stumpage, sawmills, and
human and animal shelter). Evidence of community
development includes rural schools, stores, churches,
and community centers. Recreation and leisure sites
include cabins, resorts, and trail systems.
Important Plant Uses and Species Used
by American Indians and Alaska
Natives
Although universally important, plant use by Native
American and Alaska Native groups is extremely
varied, both by region and by group. Subsistence use of
such plant products as roots and tubers, stalks, leaves,
berries, and nuts is essential to Native people.
Vegetation also provides habitat for important wildlife
species.
Most Native American and Alaska Native groups
constructed a variety of residential shelters and other
buildings such as ceremonial lodges and sweat houses,
using a combination of materials, usually employing a
locally derived hardwood as part of the structural frame.
The frames were then covered with other readily
available materials, such as planks, mats, and brush.
Wood has been burned to cook food, warm dwellings,
and facilitate toolmaking. Trees have been fashioned
into various types of watercraft and terrestrial hauling
devices. Various woods have been carved or used to
produce utilitarian implements like bowls and spoons,
and also ceremonial items, such as pipes and totems,
and many other items of material culture.
The use of plants for medicinal purposes is widespread.
Plants such as sweetgrass, cedar, and sage (referring to
both Salvia and Artemisia spp.), have seen important
religious and other ceremonial uses. The use of grasses
and other plant resources for basket, box, and tool
making also can be observed in the cultures of
numerous Native American and Alaska Native groups.
Plant products also have been used to make textiles,
cordage, and matting, as well as to tan hides. The use of
plant dyes, paints, and soaps is widespread.
Visual Resources
Public lands have a variety of visual (scenic) values that
warrant different levels of management. Visual
resources in these landscapes consist of land, water,
vegetation, wildlife, and other natural or man-made
features visible on public lands. Vast areas of grassland,
shrubland, canyonland, and mountain ranges on public
lands provide scenic views. Surface-disturbing impacts
on public lands have the potential to impact scenic
views. Visual Resource Management (VRM) is the
BLM’s system for protective management of scenic
values and minimizing the visual impacts of surface-
disturbing activities.
Different levels of scenic values require different levels
of management. The VRM system provides a way to
identity and evaluate scenic values to determine the
appropriate levels of management. The VRM system
has two stages: land use planning and land use plan
implementation. The land use planning stage involves
inventory of scenic values (Visual Resource Inventory
[VRI] Classes) and designation of visual management
decisions (VRM Classes). The land use plan
implementation stage involves visual impact analysis,
mitigation to reduce adverse visual impacts, and
determination of conformance to the land use plan
VRM Class designations.
BLM lands are inventoried for three scenic values: 1)
scenic quality, 2) public sensitivity for the scenic
quality, and 3) distance zones. VRI Classes are assigned
based on systematic procedures that combine the three
inventory factors, as outlined in BLM Handbook H-
8410-1, Visual Resource Inventory (USDOl BLM
1986a). There are four VRI classes, with VRI Class I
and II representing areas with the highest visual value
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
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January 2016
AFFECTED ENVIRONMENT
and VRI Class IV representing landscapes with lowest
visual value. The VRI information is taken into
consideration with the other natural and cultural
resource values and resource allocations to determine
VRM Classes during the land use planning process.
VRM Classes have established management objectives
which land use authorizations must meet to be in
conformance with the land use plan (USDOI BLM
1986a). VRM classes range from Class I to IV, with
Class IV allowing for the most visual change to the
existing landscape and Class I allowing for the least
(Table 3-10).
During the analysis stage, the potential visual impacts
from proposed activities or developments are assessed
to determine whether the potential visual impacts will
meet the management objectives for the area. A visual
contrast rating is used, in which the project features are
compared with the major features in the existing
landscape using the basic design elements of form, line,
color, and texture. This process is described in BLM
Handbook H-8431-1, Visual Resource Contrast Rating
(USDOI BLM 1986b). Activities or modifications in a
landscape that repeat the basic design elements are
thought to be in harmony with their surroundings.
Modifications that do not harmonize are said to be in
contrast with their surroundings.
Wilderness and Other Special
Areas
The BLM manages certain lands that possess unique
and important historical, anthropological, ecological.
biological, geological, and paleontological features.
These features include undisturbed wilderness tracts,
critical habitat, natural environments, open spaces,
scenic landscapes, historic locations, cultural landmarks,
and paleontologically rich regions. Special management
is administered with the intent to preserve, protect, and
evaluate these significant components of our national
heritage. Most special areas are either designated by an
Act of Congress or by Presidential Proclamation, or are
created under BLM administrative procedures.
The NLCS is the primary management framework for
these specially designated lands. Of the nearly 247
million acres administered by the BLM, approximately
27 million acres are managed under the NLCS program.
The NLCS designations primarily include National
Monuments, National Conservation Areas, Designated
Wilderness and WSAs, National Scenic and Historic
Trails, and Wild, Scenic, and Recreational Rivers (Map
3-7 and Table 3-11; USDOI BLM 2013a).
Outside of the NLCS framework, the BLM manages
other special areas, including Areas of Critical
Environmental Concern (ACECs), Research Natural
Areas, National Natural Landmarks, National
Recreation Trails, and a variety of other area
designations. The BLM uses the ACEC designation to
highlight public land areas where special management
attention is necessary to protect and prevent irreparable
damage to important historical, cultural, and scenic
values; fish or wildlife resources; or other natural
systems or processes. The ACEC designation may also
be used to protect human life and safety from natural
hazards.
TABLE 3-10
Visual Resource Management Classes and Objectives and Appropriate Management Activities
VRM
CLASS
Visual Resource Objective
Change Allowed
(Relative Level)
Relationship to the Casual
Observer
Class I
Preserve the existing character of the
landscape. Manage for natural ecological
changes.
Very Low
Activities should not be visible and
must not attract attention.
Class II
Retain the existing character of the
landscape.
Low
Activities may be visible, but should
not attract attention.
Class III
Partially retain the existing character of the
landscape.
Moderate
Activities may attract attention but
should not dominate the view.
Class IV
Provide for management activities which
require major modification of the existing
character of the landscape.
High
Activities may attract attention, may
dominate the view, but are still
mitigated.
HI M Vegetation Treatments Three New Herbicides
Final Programmatic EIS
3-26
January 2016
AFFECTED ENVIRONMENT
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8,682,156
774,124
5,320,721
517,785
591,671
380,795
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1,023,241
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Acres/Miles1
609,280/952
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89,300/149
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326,000
63,930
812,566
548,219
655,512
449,963
2,552,457
958,751
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5,636
574,401
12,835,035
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3,834,292
205,814
517,362
6,347
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169,523
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Acres
1,208,624
119,234
56,167
398,668
470,840
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256,207
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301,899
170,965
274,693
375,027
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Outstanding
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496,258
503,818
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State
Alaska
Arizona
California
Colorado
- 1
Idaho
Montana
Nebraska
Nevada
New
Mexico
North
Dakota
Oklahoma
Oregon
South
Dakota
Texas
Utah
Washington
Wyoming
Total
BLM Vegetation Treatments Three New Herbicides 3-27
Final Programmatic EIS
January 2016
AFFECTED ENVIRONMENT
Additional discussion of NLCS lands and ACECs is
provided in the 2007 PEIS (USDOI BLM 2007a:3-56 to
3-58). Table 3-1 1 summarizes current information about
these areas on BLM administered lands. A total of 1,024
areas comprising nearly 21 million acres are designated
as ACECs; 46 areas comprising more 400,000 acres are
designated as National Natural Landmarks; and 192
areas comprising over 500,000 acres are designated as
Research Natural Areas. An additional 36 million acres
fall under various other designations, such as the Lake
Todatonten Special Management Area, the Santa Rosa
Mountains National Scenic Area, HMAs, and Globally
Important Bird Areas. In addition, more than 3,300
miles of vehicle routes and trails are designated as
National Backcountry Byways and National Recreation
Trails (USDOI BLM 2012a). The BLM also cooperates
with the National Park Service in implementing the
National Natural Landmark Program as it applies to
public lands. The National Park Service, through the
National Natural Landmark Program, designates
significant examples of the Nation’s ecological and
geological heritage.
Recreation
Public lands provide visitors with a wide range of
recreational opportunities, including hunting, fishing,
camping, hiking, dog mushing, cross-country skiing,
boating, hang gliding, OHV driving, mountain biking,
birding, viewing scenery, and visiting natural and
cultural heritage sites. In addition to the recreational
opportunities afforded the public by wilderness and
other special areas discussed earlier, the BLM
administers more than 3,650 recreation sites and 380
Special Recreation Management Areas, 9,000 miles of
floatable/boatable rivers and lakes, 54 National Back
Country Byways, 5,750 miles of National Scenic,
Historic, and Recreational Trails, and thousands of
miles of multiple use trails used by motorcyclists,
hikers, equestrians, and mountain bikers (USDOI BLM
2012b, d).
The BLM's long-term goal is to provide opportunities
to the public for environmentally responsible recreation.
Over 4,000 communities with a combined population of
40 million people are located within 25 miles of public
lands, and more than 100 million acres of public lands
are located within a day’s drive of a major urban area
(USDOI BLM 2012b).
In 2010, the America’s Great Outdoors initiative, a
presidential conservation and recreation agenda, was
launched. This initiative has increased awareness of.
and expanded opportunities for, recreational
opportunities on BLM-administered lands.
BLM field offices reported 57.8 million recreational
visits to BLM public lands and waters in FY 2011, a
decrease of 1 percent from the previous year. The total
amount of time spent on public lands, reported as visitor
days, was estimated at 67 million visitor days, an
increase of less than 1 percent from the previous year
(Table 3-12; USDOI BLM 2012a).
TABLE 3-12
Estimated Recreation Use of Public Lands During
Fiscal Year 2011
State
Numbi
?r of Visitor Days1
thousands)
Recreation
Sites
Dispersed
Areas
Total2
Alaska
196
434
630
Arizona
9,187
1,540
14,554
California
1 1,523
3,907
15,486
Colorado
1,549
5,083
6,757
Idaho
1,337
3,177
4,542
Montana,
North Dakota, and
South Dakota
1,081
2,965
4,046
Nevada
1,917
3,225
5,379
New Mexico,
Oklahoma, and Texas
457
1,139
1,605
Oregon and
Washington
3,387
3,853
7,411
Utah
1,835
2,939
4,822
Wyoming and
Nebraska
674
1,003
1,697
Total
33,143
29,265
66,929
1 One visitor day equals 12 visitor hours.
2 Includes visitor days for recreation lease sites and recreation partnership
sites.
Note: Columns may not add up to totals due to rounding.
Source: BLM Public Land Statistics (USDOI BLM 2012a).
The greatest number of visitor days in FY 2011
occurred in Arizona and California. Overall, developed
recreational sites were used about as frequently as non-
developed dispersed areas. Recreational use of public
lands consists predominately of camping and
picnicking, which represented 42 percent of all visitor
days in 2011. Other important recreational activities
include off-highway travel (12 percent); non-motorized
travel, such as hiking, horseback riding, and mountain
biking (10 percent); hunting (8 percent); and viewing
public land resources and interpretation and education
(7 percent). The remaining visitor days were associated
with driving for pleasure, special events, sports and
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
3-28
January 2016
AFFECTED ENVIRONMENT
activities, power and non-power boating, fishing, and
swimming. Snow- and ice-based activities, such as
cross-country skiing, snowmobiling, and snowshoeing,
represented less than 1 percent of visitor days (USDOl
BLM 2012a).
Commercial revenues generated by recreation on BLM
lands are discussed in the Social and Economic Values
section of this chapter.
Rights-of-way, Facilities, and
Roads
Rights-of-way
Under FLPMA and the Mineral Leasing Act provisions,
the BLM issues ROW grants to authorize the
construction, operation, and maintenance of a wide
range of projects on public lands. These include
petroleum pipelines, electrical transmission lines,
telecommunications lines, energy development and
distribution facilities, water facilities, communication
sites, and roads. The ROWs are issued for a specific
term for the use of public lands. In FY 2011, there were
nearly 104,000 ROWs on public lands, and the BLM
issued nearly 2,700 new grants (USDOl BLM 2012a).
The length and width of an ROW (and the resulting
acreage of public lands) is dependent on a variety of
physical and operational factors, including topography,
geology, safety, type of use or uses proposed within the
ROW, current technology, and access needs. Individual
ROWs may also be subject to controls or limitations
prescribed by law or identified in BLM land use plans.
The BLM encourages the utilization of ROWs in
common, where practical, in order to minimize adverse
environmental impacts. Land use plans identity ROW
corridors for existing and future ROW development.
Vegetation can interfere with ROW site access, facility
maintenance, and electric power flow, and pose safety
problems for workers and other ROW users. Therefore,
ROW grants generally include provisions that authorize
the holder to manage vegetation within and adjacent to
the ROW using methods approved by the BLM. The
scope and intensity of vegetation treatments within
ROWs are operationally specific and highly variable.
Inspections are conducted periodically to assess
vegetation management needs within ROWs. Pre¬
emergence or post-emergence herbicides can be applied
to prevent or control young emerging and existing
vegetation. Other types of vegetation treatments may
also be utilized.
Invasive plant species may be associated with the open
conditions along ROWs. Additionally, vegetation
removal activities can result in ground disturbance that
facilitates the establishment and spread of these species.
The relatively open nature of ROWs makes them
attractive to many recreationists, which can facilitate the
spread of invasive plants that are present on ROWs.
Facilities and Roads
The BLM operates or oversees operations on numerous
facilities on public lands. These include oil, gas,
geothermal, and mineral exploration and production
sites; numerous campgrounds, 65 interpretive centers,
and other recreational facilities; nearly 5,000 buildings
and 655 administrative sites; more than 72,000 miles of
roads; and communication facilities (USDOl BLM
2012a).
Construction and operations disturbance can often
introduce noxious weeds and other invasive vegetation
to facility sites and roads. In general, vegetation
management at facilities focuses on controlling
vegetation that can pose a safety or fire hazard, or is not
aesthetically pleasing. In such situations the vegetation
is managed using several methods, which can be
integrated into an effective management process.
Residual herbicides, applied to vegetation before or
after emergence, offer extended management in areas
where bare ground is required for safety purposes.
Mechanical methods, such as mowing, and manual
control by hand pulling have been used to manage
vegetation along roads, as well as in sensitive areas.
Social and Economic Values
Social/Demographic Environment
The western U.S., including Alaska, is more sparsely
populated than the rest of the U.S., containing about 33
percent of the total U.S. population, but comprising
approximately 65 percent of the total land area. In 2010,
over 102 million people lived in this region, with over
60 million in California and Texas, alone (Table 3-13).
Population density is relatively low, averaging about 46
people per square mile (mi ), which is just over half of
the national average of nearly 87 people per mi2.
Density ranges from about 1 person per mi" in Alaska to
over 239 persons per mi2 in California. Based on 2010
census data, population growth in the western U.S.
between 2000 and 2010 was 13.8 percent, which was
higher than the national average of approximately 10
percent (U.S. Department of Commerce Bureau of the
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
3-29
January 2016
TABLE 3-13
Population, Age Distribution, and Race in the Western States and Alaska
AFFECTED ENVIRONMENT
Percent of Both Hispanic and Non-Hispanic Origin
More than
1 Race
7.3
3.4
4.9
3.4
2.5
2.5
2.2
4.7
3.7
OO
5.9
3.8
<N
2.7
2.7
\
2.2
2.9
3.9
OO
Other
p
611
17.0
7.2
«n
9'0
4.3
12.0
15.0
0.5
5.3
60
10.5
6.0
5-2
3.0
6.2
11.5
61.7
Asian/Pacific
Islander
6.4
3.0
13.4
2.9
0.7
OO
7.9
in
-
C\
4.0
p
3.9
2.9
OO
r-*
6'0
5.0
7.3
49.4
American
Indian
14.8
4.6
o
6.3
p
<N
9.4
5.4
8.6
8.8
0.7
(N
»n
2.4
0.9
as
66.6
African
American
3.3
6.2
4.0
90
0.4
4.5
OO
<N
VL
OO
cn
811
3.6
OO
O
12.6
6.6
17.4
Caucasian
66.7
73.0
57.6
81.3
89.1
89.4
86.1
66.1
68.4
90.0
72.2
83.6
85.9
70.4
SO
OO
Z'LL
90.7
YZL
68.8
31.6
Percent of
Hispanic
Origin
5.5
29.6
37.6
20.7
11.2
2.9
9.2
26.5
46.3
2.0
8.9
11.7
r-
<N
37.6
13.0
11.2
8.9
16.3
29.6
U09
Age Distribution
Percent
Over
65
L'L
13.8
11.4
601
12.4
14.8
13.5
12.0
13.2
14.5
13.5
13.9
14.3
10.3
9.0
12.3
12.4
13.0
11.6
29.6
Percent
Under
18
26.4
25.5
25.0
24.4
VLZ
22.6
25.1
24.6
25.2
22.3
24.8
22.6
24.9
27.3
31.5
23.5
O
<N
24.0
25.5
35.4
Density
(per
mi2)
<N
56.3
239.1
OO
19.0
OO
NO
23.8
24.6
17.0
9.7
54.7
39.9
10.7
C96
33.6
101.2
5.8
OO
46.4
l
Percent
Change
from
2000
13.3
24.6
001
16.9
21.1
9.7
6.7
35.1
13.2
4.7
8.7
12.0
7.9
20.6
23.8
14.1
14.1
9.7
15.0
i
Population
2010
(thousands)
710
6,392
37,254
5,029
1,568
989
1,826
2,701
2,059
673
3,751
3,831
814
25,146
2,764
6,725
564
308,746
102,795
33.3
State
Alaska
Arizona
California
Colorado
Idaho
Montana
Nebraska
Nevada
New Mexico
North Dakota
Oklahoma
Oregon
South Dakota
Texas
Utah
Washington
Wyoming
United States
Western
States
Western
States as a
Percentage of
Total U.S.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
3-30
January 2016
Source: U.S. Department of Commerce Bureau of the Census 201 1
AFFECTED ENVIRONMENT
Census 2011). Many of the western states exceeded the
national average, with growth rates of 20 percent or
higher during this time period. States with the greatest
rate of population growth were Nevada (35.1 percent),
followed by Arizona (24.6 percent), Utah (23.8 percent)
and Idaho (21.1 percent). Population growth was
highest in metropolitan areas. Population growth in the
western U.S. has slowed from the rate of increase
observed during the previous decade.
The age distribution of the population of the western
U.S. is similar to the nationwide distribution.
Approximately 25 percent of the population is under 18
years of age, while about 12 percent is over 65. Alaska
and Utah are slight exceptions, with a higher percentage
of people under 18 (26 percent and 32 percent,
respectively) and a lower percentage of people over 65
(8 percent and 9 percent, respectively).
Economic Environment
Employment
Between 2007 and 2012, employment fell by 2 percent
in the 17 western states, which was slightly lower than
the national decline of 3 percent. States with positive
employment growth during this period include Alaska,
Nebraska, North Dakota, Oklahoma, South Dakota,
Texas, and Wyoming. States with the most employment
growth were North Dakota (18 percent), Alaska (5.6
percent), and Texas (5.1 percent). States with above
average decreases in employment include Nevada
(-12.3 percent), Arizona (-8.8 percent), Idaho (-6.8
percent), California (-5.9 percent), Oregon (-4.3
percent), and New Mexico (-3.1 percent; U.S.
Department of Labor Bureau of Labor Statistics 2013a).
In 2014, the average annual nationwide unemployment
rate was 6.2 percent (Table 3-14). Unemployment rates
in the western U.S. were less than the national average,
with the greatest unemployment in Nevada (7.8
percent), California (7.5 percent), Arizona (6.9 percent),
Oregon (6.9 percent), and Alaska (6.8 percent). The
unemployment rate was lowest in North Dakota (2.8
percent), Nebraska (3.3 percent), South Dakota (3.4
percent), and Utah (3.8 percent; U.S. Department of
Labor Bureau of Labor Statistics 2015). Unemployment
rates were generally higher for African Americans and
Hispanics than other races.
Over 33 percent of the nation’s employment
opportunities, amounting to more than 58 million jobs,
are located in the western U.S. (Table 3-15).
Employment in the trade and services industries
accounts for over half of the total jobs. Industries related
to natural resources, such as agriculture and mining, are
important sources of employment and represent nearly
half of the nation’s agricultural services, forestry, and
fishing jobs. Employment in the government and
military sector is higher in Alaska than in other states,
accounting for 24 percent of total jobs versus about 14
percent overall in the western U.S.
TABLE 3-14
Percent Unemployment for the Western U.S. and
Alaska
State
Year
1990
2000
2010
2014
Alaska
7.0
6.6
8.0
6.8
Arizona
5.5
3.9
10.4
6.9
California
5.8
4.9
12.4
7.5
Colorado
5.0
2.7
9.0
5.0
Idaho
5.9
4.9
8.7
4.8
Montana
6.0
4.9
6.7
4.7
Nebraska
2.2
3.0
4.7
3.3
Nevada
4.9
4.1
13.8
7.8
New Mexico
6.5
4.9
8.0
6.5
North Dakota
4.0
3.0
3.8
2.8
Oklahoma
5.7
3.1
6.9
4.5
Oregon
5.6
4.9
10.8
6.9
South Dakota
3.9
2.3
5.1
3.4
Texas
6.3
4.2
8.2
5.1
Utah
4.3
3.2
8.1
3.8
Washington
4.9
5.2
9.9
6.2
Wyoming
5.5
3.9
7.0
4.3
United States
5.6
4.0
9.6
6.2
Source: U.S. Department of Labor Bureau of Labor Statistics
2015.
Income
Based on data from 2008 to 2012, the estimated per
capita income in the western U.S. was $28,575, which
was similar to the national average of $28,051. Per
capita income was greatest in Alaska, Colorado, and
Washington, and lowest in Utah, Idaho, and New
Mexico (U.S. Department of Commerce Bureau of the
Census 2014).
In 2011, the median household income in the western
U.S. was $52,376, a 4.1 percent decrease from the
previous year. The highest median annual income in the
western U.S. was paid to individuals employed by the
information sector ($60,379), followed by public
administration ($58,072), and professional services
($54,196). The lowest median annual income was
earned by those working in agriculture, forestry, fishing.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
3-31
January 2016
AFFECTED ENVIRONMENT
TABLE 3-15
Percent Unemployment by Industry in 2011
State
Agriculture
Mining and
Natural
Resources
Construction
Manufacturing
Transportation
and Public
Utilities
Trade
(Wholesale and
Retail)
Finance,
Insurance, and
Real Estate
Information
Services
Government
Total Number
(thousands)
Alaska
0.2
6.8
5.2
3.5
5.5
11.3
6.3
1.6
35.6
24.0
454
Arizona
0.8
1.1
4.9
5.0
3.2
14.4
12.4
1.5
43.0
13.6
3,228
California
1.1
1.5
4.3
6.7
3.2
13.3
10.3
2.6
44.0
13.1
19,969
Colorado
1.4
2.1
5.7
4.5
2.8
12.7
11.9
2.6
42.1
14.2
3,200
Idaho
4.4
1.9
5.9
6.8
3.2
14.5
9.4
1.4
38.2
14.4
879
Montana
4.7
3.0
6.4
3.2
3.4
14.0
9.0
1.4
39.5
15.3
629
Nebraska
4.2
1.1
5.1
7.8
5.1
14.1
9.7
1.6
37.2
14.2
1,231
Nevada
0.3
1.4
4.6
2.8
4.0
12.8
12.1
1.2
49.7
11.1
1,498
New Mexico
2.5
3.4
5.6
3.3
2.7
12.9
7.1
1.5
40.9
20.1
1,066
North Dakota
6.1
4.5
6.3
4.7
4.5
15.0
8.1
1.5
33.2
16.0
527
Oklahoma
4.0
6.0
5.4
6.4
3.2
12.8
7.9
1.3
35.8
17.2
2,168
Oregon
3.1
1.5
4.7
8.2
3.0
14.0
8.9
1.8
41.5
13.3
2,222
South Dakota
5.7
1.3
5.7
7.3
3.1
14.9
10.2
1.3
35.5
15.1
564
Texas
1.8
3.5
6.2
6.1
4.0
13.7
10.0
1.6
39.5
13.6
14,611
Utah
1.1
1.2
5.5
7.3
3.5
13.6
12.7
2.1
38.7
14.3
1,658
Washington
2.1
1.2
5.0
7.5
3.0
13.6
8.9
3.0
39.3
16.3
3,829
Wyoming
3.3
9.4
7.5
2.8
4.4
12.2
9.0
1.2
31.1
19.1
391
Western U.S.
1.8
2.3
5.2
6.2
3.5
13.5
10.1
2.1
41.3
14.0
58,124
Source: U .S. Department of Commerce Bureau of Economic Analy
sis 2012.
and hunting ($27,243); portions of the service industry
(e.g., accommodation and food services, arts,
entertainment, and recreation [$27,877]); and retail
trade ($34,057; U.S. Department of Labor Bureau of
Labor Statistics 2013a).
Environmental Justice
Executive Order 12898 directs federal agencies to
address the disproportionately high and adverse human
health or environmental effects of their actions on
minority and low-income populations. Minority
populations are defined as Hispanics, Asian Americans
and Pacific Islanders, African-Americans, American
Indians, and Alaska Natives. Low income populations
are defined as those below the poverty level, which is
established by the U.S. Census Bureau. Information on
minority and low income populations can be obtained
from Census data and then compared to an appropriate
statistical reference area.
Given the programmatic nature of this PEIS, it is not
feasible to do an analysis of minority and low-income
populations based on the complete coverage of BLM-
administered lands. These analyses will be done at the
local level for individual treatment programs. Instead,
general information for the states covered by this PEIS
is provided.
Information on minority populations is provided in
Table 3-13. The western U.S. contains a large
percentage of the nation’s minority populations,
including more than 60 percent of the nation’s
Hispanics and American Indians, and nearly 50 percent
of the nation’s Asian/Pacific Islanders. In particular,
Arizona, California, Nevada, New Mexico, and Texas
contain large Hispanic populations, which comprise
from 25 to over 45 percent of the total population in
each of these states. Almost 15 percent of Alaska’s
population is comprised of American Indians (Alaska
Natives).
The population of the western U.S. living below the
poverty level is estimated at 14.8 percent, which is
consistent with the national average (U.S. Department
of Commerce Bureau of the Census 2014). Table 3-16
presents the percent of people below the poverty level,
by state, as compared to the U.S. as a whole. The
highest poverty rates occur in New Mexico, Texas, and
Arizona, while the lowest rates occur in Alaska and
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
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January 2016
AFFECTED ENVIRONMENT
Wyoming. However, within each state, areas of high
poverty may vary geographically, and could include
some rural areas where BLM-administered lands are
prevalent.
TABLE 3-16
Percent of People Below the Poverty Level for the
Western U.S. and Alaska
State
Percent Below Poverty
Level
Alaska
9.6
Arizona
17.2
California
15.3
Colorado
12.9
Idaho
15.1
Montana
14.8
Nebraska
12.4
Nevada
14.2
New Mexico
19.5
North Dakota
12.1
Oklahoma
16.6
Oregon
15.5
South Dakota
13.8
Texas
17.4
Utah
12.1
Washington
12.9
Wyoming
11.0
Western Region
14.8
United States
14.9
Source: U.S. Department of Commerce Bureau of the Census
2014(2008 to 20 12 data).
Revenues Generated by BLM Lands
The BLM allows land use for authorized private
commercial activities such as energy and mineral
commodity extraction, timber harvesting, livestock
grazing, recreation, and the development of ROWs on
public land. Tax revenues generated by public land is
used to assist state and local governments, support the
General Fund of the U.S. Treasury, and offset charges
for program operations where certain fees collected can
be retained by the BLM. During FY 2011, the BLM
collected nearly $245 million from a variety of land
uses in the western U.S. (Table 3-17; USDOI BLM
2012a). Additionally, royalties collected by the Office
of Natural Resources Revenue from leasable minerals
produced from federal lands and managed by the BLM
are greater than $4 billion annually. Operating revenues
from mineral leases and permits totaled $1 1.2 million in
FY 2011 (USDOI BLM 2012a). These receipts include
rental collections from oil and gas ROWs, revenues
from developed lands within the Naval Oil Shale
Reserve in Colorado, lease rentals and bonus bids from
the National Petroleum Reserve in Alaska, and fees
related to mining claims, holding fees, and non¬
operating revenues.
Woodland products are an important commodity and
source of revenue generated on public lands. These
products include timber; other wood products, such as
fuelwood, posts, and poles; and non-wood forest
products, such as Christmas trees, cactus, seed, yucca,
pinyon nuts, mushrooms, and yew bark. During FY
2006 to 201 1, an average of approximately $28 million
was received annually from woodland products
harvested from public lands, the majority of which came
from timber sales. The average volume of timber
harvested annually between 2006 and 2011 was
approximately 20 million cubic feet. The revenue
generated from timber sales has generally decreased,
from $46.7 million in 1997 to $19.4 million in 2011
(USDOI BLM 2007e, 2008b, 2009b, 2010a, 2011,
2012a, 2013a).
Over ninety percent of income from the sale of timber
and other vegetative materials is derived from Oregon
and California and Coos Bay (Oregon) Wagon Road
Grant Lands. Timber sales on other public lands include
sales from salvage timber and forest health projects.
Grazing fees are derived using a formula established in
the Public Rangelands Improvement Act of 1978, which
is based on several index factors, including private land
lease rates, beef cattle prices, and the cost of production.
In 2012, the fee was $1.35 per AUM, which is the same
as the fee in 2011 (USDOI BLM 2012b).
Approximately $12.9 million was collected in grazing
receipts in FY 201 1 (USDOI BLM 2012a). Half of the
grazing fees are used by the BLM for rangeland
improvements (USDOI BLM 2012b).
Fees are charged at many public recreation sites to
provide for maintenance and improvement, and include
access fees for Entrance Permits, Special Area Permits,
Daily Use Permits, Commercial, Competitive, and
Group Permits, Leases, and Passports. At other
locations, generally those without public facilities, no
fees are charged. In FY 201 1, 90 percent of recreational
use on public lands, in terms of visitor days, occurred in
non-fee areas (USDOI BLM 2012a). The BLM also
issues special recreation permits to qualified
commercial companies and organized groups such as
outfitters, guides, vendors, and commercial competitive
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
3-33
January 2016
AFFECTED ENVIRONMENT
TABLE 3-17
Revenues Generated from Public Lands by Source for Fiscal Year 201 1
State
Mineral
Leases
Timber
Sales
Land and
Material Sales
Grazing
Fees
Recreation
Fees
Other1
Total
Alaska
$177,048
$0
$147,412
$0
$297,636
$244,200
$866,296
Arizona
164,145
30
1,148,015
590,660
1,558,148
5,174,916
8,635,914
California
1.150,461
375,327
1,519,999
236,116
3,919,741
15,463,819
22,665,463
Colorado
1,150,587
18,324
544,930
546,467
525,830
1,197,756
3,983,894
Idaho
48,153
669,386
437,872
1,427,646
905,063
2,012,714
5,500,834
Montana
2,275,206
573,232
122,619
1,774,829
392,321
231,322
5,369,5292
Nebraska
0
0
0
1,665
0
0
1,665
Nevada
-174,777
26,581
9,702,808
1,937,754
3,874,883
8,515,169
23,882,418
New Mexico
2,640,656
53,824
3,815,706
2,064,872
422,656
2,369,195
1 1,366,9092
North Dakota
3,397
0
712
14,353
0
4,125
22,587
Oklahoma
0
0
0
128
0
0
128
Oregon
53,499
16,959,414
297,646
1,107,627
2,441,837
1,975,359
22,835,3823
South Dakota
0
7,753
744
160,483
0
3,500
172,480
Texas
0
0
0
0
0
0
0
Utah
1,392,958
15,714
1,234,071
1,060,156
2,863,376
3,474,791
10,041,066
Washington
0
607,096
82,390
44,903
0
31,261
765,650
Wyoming
2,301,344
90,506
1,688,388
1,961,661
168,434
3,693,095
9,903,428
Multiple4
1 18,559,0095
0
0
0
0
0
118,559,009
Total
129,741,686
19,397,187
20,743,312
12,929,320
17,369,925
44,391,222
244,572,652
1 Includes fees and commissions, ROW rents, rent of land, and other sources.
2 Includes Land Utilization Project land purchased by the federal government under Title III of the Bankhead-Jones Farm Tenant Act and subsequently
transferred to the USDOl.
1 1ncludes Oregon and California receipts, Coos Bay Wagon Road receipts, and receipts from public domain sales and other categories.
4 These revenues are not broken down by state in the Public Land Statistics.
5 Includes mining claim and holding fees, application for permit to drill fees, and non-operating revenue. These revenues are not reported by state.
Source: BLM Public Land Statistics (USDOl BUM 2012a). _
event organizers who conduct activities on both fee and
non-fee lands. Nearly $17.4 million were collected in
recreation fees in FY 201 1 (USDOl BLM 2012a).
In FY 201 1, sales of public land and material, including
receipts from the sale of public land, and the sale of
vegetative and mineral materials, totaled nearly $20.8
million, of which $6.8 million was from the sale of
certain public lands in Clark County, Nevada, near the
city of Las Vegas, under the Southern Nevada Public
Land Management Act (USDOl BLM 2012a).
In addition to providing revenue for the BLM, all of the
major public land resource use categories generate
economic activity in the communities and states in
which they occur. For example, there are nearly 17,700
grazing permits/leases in force on public lands,
supporting nearly 12.4 million AUMs (Table 3-6).
Alaska and Texas have no grazing permits/leases in
force. The value of these grazing permits/leases and the
acreage they entail vary widely depending on the
location, soil characteristics, and precipitation. The
availability of public land grazing leases is highly
beneficial, if not crucial, to some ranching operations,
however, and consequently is very important to many
rural communities throughout the West.
Similarly, mineral development is an economic
mainstay of many western communities. Table 3-15
illustrates the relative importance to the employment
base of mineral extraction, particularly in Alaska, North
Dakota, Oklahoma, and Wyoming. Each of these states
has a much higher percentage of employment in the
mining/natural resource industry than the average for
the West as a whole. This industry sector includes oil
and gas, coal, aggregates, and hard rock minerals such
as gold and copper. Alaska’s oil industry not only
supports ongoing employment, but also contributes
toward minimizing taxes for all state residents and has
provided a substantial cash rebate to residents over the
years.
The BLM estimates the contribution to local economies
from recreation on public lands. These estimates serve
BLM Vegetation Treatments Three New I lerbicides
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AFFECTED ENVIRONMENT
as one example of the economic activity that depends on
the public land base. Recreational activity provides
revenue for local economies through expenditures
associated with activities such as hunting, fishing, and
wildlife viewing (Table 3-18). In FY 2012, an estimated
$3 1 million was injected into local economies through
these recreation-associated expenditures (USDOl BLM
2013a). These activities produce indirect economic
benefits to community businesses providing food,
lodging, equipment sales, transportation, and other
services. State fish and wildlife management agencies
also benefit from spending associated with these
activities from sources such as state tax revenue and
state administered fishing and hunting license programs.
Expenditures by the BLM
The budget for the BLM was $1.1 billion in FY 2014,
and was projected to be $1.1 billion in FY 2015
(USDOl BLM 2014b). In FY 2012, $960 million was
allocated to management of lands and resources (Table
3-19). These expenditures included integrated
management of public land, renewable and cultural
resources, fish and wildlife, threatened and endangered
species, recreation, and energy and minerals.
Wildland Fire Management
While the amount budgeted for wildland fire
management may be relatively consistent from year to
year, the cost of fighting fires has varied substantially.
Since 2009, the BLM’s fuels management budget has
averaged between $60 million and $100 million
annually. The total wildland fire management budget
for the BLM ranges from $250 million to $280 million
annually.
Table 3-20 shows the BLM’s fire suppression
expenditures for recent years. The variability often
results from changing weather, but terrain, vegetation,
and proximity to populated areas all contribute to the
cost of fighting a fire. The cost of fire suppression also
depends on the number and size of fires. Approximately
95 percent of wildland fires are controlled in the initial
attack, when they are relatively small and not yet
seriously out of control. Table 3-21 illustrates the total
acreage of USDOI-managed lands burned by unwanted
fires in recent years. Between 2008 and 2012, the
acreage burned by fires has varied, with the lowest
burned area in 2009 and the highest in 2012.
TABLE 3-18
Estimated Benefits to Local Economies by Recreation on Public Lands in Fiscal Year 2011
State'
Fishing
Expenditures
Hunting
Expenditures
Wildlife Viewing
Expenditures
Total
Alaska
$578,759,000
$140,125,000
$650,777,000
$1,369,661,000
Arizona
898,694,000
361,468,000
938,904,000
2,199,066,000
California
2,710,963,000
910,828,000
4,681,133,000
8,302,924,000
Colorado
608,089,000
497,348,000
1,554,265,000
2,659,702,000
Idaho
316,929,000
290,884,000
297,226,000
905,039,000
Montana
253,511,000
347,805,000
421,625,000
1,022,941,000
Nevada
161,990,000
144,570,000
405,696,000
712,256,000
New Mexico
337,233,000
184,025,000
332,835,000
854,093,000
North Dakota
93,729,000
129,114,000
22,913,000
245,576,000
Oregon
556,574,000
418,447,000
869,584,000
1,844,605,000
South Dakota
131,089,000
185,258,000
183,204,000
499,551,000
Utah
415,617,000
306,636,000
632,176,000
1,354,429,000
Washington
904,796,000
313,134,000
1,502,311,000
2,720,241,000
Wyoming
584,056,000
153,737,000
442,253,000
1,180,046,000
Total
8,552,029,000
4,383,379,000
12,934,905,000
25,870,310,000
'Estimates include only states with more than 50,000 acres of public lands. No estimates were made for Nebraska, Oklahoma, or Texas.
Source: BLM Public Land Statistics (USDOl BLM 2012a).
Note: Columns may not add up to totals due to rounding.
BLM Vegetation Treatments three New Herbicides
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AFFECTED ENVIRONMENT
TABLE 3-19
Summary of BLM Jobs and Expenditures for the Management of the Lands and Resources Program
by Activity and Subactivity (dollars in thousands)
Activity/Subactivity
2013 (Actual)
2014 (Enacted)
FIE1
Amount
FTE1
Amount
Management of Lands and Resources
5,994
$902,160
6,078
$956,875
Land Resources
1,417
231,587
1,493
245,474
Soil, Water, Air
227
41,455
227
42,939
Range Management
670
75,955
675
79,000
Forest Management
48
5,889
81
9,838
Riparian Management
171
21,321
169
21,321
Cultural Resources
116
15,131
114
15,131
Wild Horse and Burros
185
71,836
173
77,245
Wildlife and Fisheries
319
61,136
311
64,868
Wildlife Management
232
48,606
225
52,338
Fisheries Management
87
12,530
86
12,530
Threatened and Endangered Species
154
20,326
159
21,458
Recreation
531
63,429
541
66,961
Wilderness Management
151
17,300
155
18,264
Recreation Resource Management
380
46,129
386
48,697
Resource Protection and Maintenance
532
94,749
524
94,749
Energy and Minerals
1,157
110,092
1,261
130,119
Realty and Ownership
512
62,226
484
67,658
Transportation and Facilities Maintenance
341
65,632
335
65,632
Workforce and Organizational Support
442
160,661
434
165,724
National Landscape and Conservation System
244
29,909
253
31,819
Other2
345
41,988
337
44,109
1 Full-time equivalent.
2 Includes Communications Site Management Mining Law Administration, and Challenge Cost Share.
Source: USDOI BLM 2014b.
TABLE 3-20 TABLE 3-21
BLM and USDOI Fire Suppression Expenditures USDOI Unwanted Wildland Fires
Fiscal Year 2007 through Fiscal Year 2013 During 2006 to 2012
Fiscal Year
Total
Expenditure
BLM
Total
Expenditure
USDOI
2007
301,114,240
470,491,000
2008
251,381,120
392,783,000
2009
139,787,520
218,418,000
2010
147,976,960
231,214,000
2011
204,024,320
318,788,000
2012
298,132,480
465,832,000
2013
255,487,360
399,199,000
1 0-year
Annual
Average
223,749,184
349,608,100
NA = Not applicable.
Source: USDOI BLM 2014c.
Calendar
Year
Number
of Fires
Total
Acreage
2006
11,823
2,554,304
2007
8,212
2,896,507
2008
5,778
2,387,484
2009
6,225
511,790
2010
5,786
1,294,546
2011
7,615
1,423,895
2012'
9,151
3,186,827
Total
54,590
14,255,353
1 2012 values are estimated.
Source: USDOI 2014.
BLM Vegetation Treatments Three New Herbicides
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AFFECTED ENVIRONMENT
Hazardous Fuels Reduction
Reducing the hazardous fuels available to sustain a
wildland fire can be costly. The USDOI treated 733,871
acres in the wildland-urban interface (WUI) during
2012 at an average cost of $224 per acre. Treatment can
cost up to $5,000 per acre for labor-intensive, small,
mechanical treatments in forested WUI areas. During
the same year, the USDOI treated 266,619 acres in non-
WUI areas at a cost of about $69 per acre (USDOI
2014).
Weed Management
Herbicides and other vegetation management methods
are employed to control invasive plant species, which
have caused a variety of problems on public lands. The
Vegetation section of this chapter addresses several
major types of weed infestations on public lands. As
Duncan and Clark (2005) noted, “The economic impact
of most (weed) species is poorly documented. This is
generally due to the lack of quantitative information on
ecosystem impacts and the challenge of assessing non-
market cost such as those to society and the
environment (e.g., changes in fire frequency, wildlife
habitat, aesthetics, and loss of biodiversity).”
Expenditures for herbicides used on BLM land are a
relatively small part of the agency’s budget. Table 3-22
provides information about the estimated cost per acre
for currently approved herbicides. These estimates
include only the cost of the chemicals; labor and
equipment costs for herbicide application are in addition
to the costs shown. The BLM estimated it spent $12.7
million to treat weeds on approximately 204,000 acres
($62 per acre) during FY 2012 (Ramos 2014). These
costs included herbicide, labor, and equipment costs.
The cost of herbicides can vary dramatically, depending
on the type selected and the method of application.
Costs can also vary significantly by geographic region,
vendor, type of chemical (generic versus branded), and
size and terrain of the application target area. The
BLM’s range of estimated application costs for ground
applications is typically $45 to $450 per acre for
backpack sprayer applications, $35 to $450 per acre for
all-terrain vehicle (ATV)/utility terrain vehicle (UTV)
applications, and $25 to $120 per acre for boom sprayer
applications. Costs for aerial applications are estimated
at $6 to $40 per acre for fixed-wing aircraft and $ 1 5 to
$300 per acre for helicopter applications. Occasionally,
costs can exceed these ranges, depending on the site
conditions. Backpack sprayer applications have been
reported as high as $4,200 per acre, and ATV/UTV
applications have been reported as high as $800 per
acre.
Some herbicide treatments may require reseeding or
some other form of site restoration or rehabilitation
following herbicide application, particularly large-scale
treatments that clear an area of vegetation. The cost of
reseeding a site following a treatment varies depending
on the extent of work required, and can range anywhere
from $350 to $1,000 per acre (USDOI BLM 2014d).
Payments to State and Local Governments
Where the federal government maintains public land, it
makes payments to state and local governments for a
variety of purposes. Receipts from coal leases and
bonus payments, for example, are shared. Payments in
lieu of taxes help address the loss of potential local tax
income that could have been generated from those
public lands if they were in private ownership.
Payments in lieu of taxes, as well as other forms of
transfer payments, are generally set by law and provided
according to a formula. Payments in lieu of taxes, for
example, are computed based on the number of acres of
public lands within each county and multiplied by a
dollar amount per acre. Over $6 billion in payments
have been made since 1976. Table 3-23 shows the BLM
payments to states and local governments for FY 2011.
Note that this table does not include royalty payments
associated with leasable minerals that are returned to the
state of origin, which exceeded $2 billion in FY 2012.
Human Health and Safety
Background Health Risks
This section discusses background information on
human health risks of injuries, and cancer and other
diseases for people living in the states in which the
BLM is planning to implement herbicide treatments.
People living in these states are exposed to a variety of
risks common to the U.S. as a whole, including
automobile accidents and other injuries; contaminants in
the air, water, soil, and food; and various diseases. Risks
to workers may differ from those facing the general
public, depending on the nature of a person’s work.
Some of these risks may be quantified, but a lack of
data allows for only a qualitative description of certain
risks. Where data are only available for the U.S. as a
whole, it is assumed that these data apply to the
treatment states. Information for this section was
obtained from the Centers for Disease Control and
Prevention (CDC), the National Center for Injury
BLM Vegetation Treatments Three New Herbicides
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January 2016
AFFECTED ENVIRONMENT
TABLE 3-22
Herbicide Uses and Costs for Vegetation Treatments on Public Lands During 2011
Herbicide
Type of
Application
Acres Treated1
Total Herbicide
2
Expenditure
Cost per Acre for
Herbicide2
2,4- D
Aerial
1,571
$5,216
$3.32
Ground
37,380
223,161
5.97
Bromacil
Aerial
0
0
NA
Ground
6,338
728,836
115.00
Chlorsulfuron
Aerial
3,779
25,508
6.75
Ground
5,347
64,158
12.00
Clopyralid
Aerial
52,789
831,427
15.75
Ground
2,104
34,463
16.38
Dicamba
Aerial
128
1,440
11.25
Ground
11,044
141,691
12.83
Dicamba +
Aerial
0
0
NA
Diflufenzopyr
Ground
38
16
0.41
Diquat
Aerial
0
0
NA
Ground
17
55
15.50
Diuron
Aerial
0
0
NA
Ground
9,991
325,306
32.56
Fluridone'
Aerial
0
0
NA
Ground
0
0
NA
Glyphosate
Aerial
16,935
73,498
4.34
Ground
9,861
85,492
8.67
Hexazinone’
Aerial
0
0
NA
Ground
0
0
NA
Imazapic
Aerial
17,498
179,355
10.25
Ground
3,696
53,588
14.50
Imazapyr
Aerial
3,501
69,075
19.73
Ground
5,938
135,389
22.80
Metsulfuron methyl
Aerial
1 ,5 1 8
2,869
1.89
Ground
10,398
5E470
4.95
Picloram
Aerial
3,905
45,063
11.54
Ground
24,938
404,490
16.22
Sulfometuron methyl
Aerial
0
0
NA
Ground
1,116
6,731
6.03
Tebuthiuron
Aerial
73,493
66,144
0.90
Ground
133
162
1.22
Triclopyr
Aerial
106,580
576,006
5.32
Ground
3,176
75,620
23.81
1 Acres treated do not take into account whether the aerial application was by helicopter or airplane, nor do they distinguish between
ground application methods. Costs would vary depending on the application method.
2 Total herbicide expenditure and cost per acre do not include costs for labor, equipment, and application, and represent an average cost
for use throughout the BLM.
3 Herbicide not applied in 201 1, so no data are available. Estimated costs are $548.63 per pound active ingredient for fluridone and
$42.45 per pound active ingredient for hexazinone.
NA = Not available or not applicable.
BLM Vegetation Treatments Three New Herbicides
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January 2016
AFFECTED ENVIRONMENT
TABLE 3-23
BLM Payments to States and Local Governments During Fiscal Year 2011
State
Payments
in Lieu of
Taxes1
Mineral
Leasing
Act2
Tav
or Grazing Act
Proceeds
of Sales
Other
Total
Payments
Section 3
Section
15
Other
Alaska
$25,490,863
$4,064
$0
$0
$0
$0
$0
$25,494,927
Arizona
31,546,890
82,124
48,912
77,642
0
49,480
0
31,805,048
California
38,025,813
598,526
13,018
48,225
0
113,620
0
38,799,202
Colorado
27,022,334
514,788
63,511
29,612
18,632
29,940
0
27,678,817
Idaho
25,592,241
26,452
167,378
19,350
0
123,674
0
25,929,095
Montana
24,717,269
21,204
133,026
103,597
0
8,526
596,776
25,580,398
Nebraska
996,651
0
0
812
0
0
0
997,463
Nevada
22,942,298
105,787
213,384
3,168
0
118,288
1,025,321 3
33,636,189
New Mexico
32,916,396
1,240,210
214,208
138,216
15
105,467
10,025
34,624,537
North Dakota
1,452,758
1,562
0
7,314
0
6
0
1,461,640
Oklahoma
2,639,362
0
0
65
0
0
0
2,639,427
Oregon
13,062,332
26,823
126,848
28,766
0
9,614
85,486,761 4
98,741,144
South Dakota
4,995,110
0
0
0
0
0
0
4,995,110
Texas
4,629,597
0
0
0
0
0
0
4,629,597
Utah
34,659,277
694,786
132,435
0
0
27,200
0
35,513,698
Washington
13,843,603
0
0
22,651
0
11,505
0
13,877,759
Wyoming
25,656,797
1,084,182
160,744
332,280
31,313
86,234
0
27,351,550
Western States
330,189,591
4,400,508
1,273,464
811,698
49,960
683,554
87,118,883
424,527,658
All States
375,158,254
4,400,508
1,273,464
811,698
49,960
702,420
87,118,883
469,515,187
1 Payments in lieu of taxes are made by the USDOI, Office of the Secretary, for tax-exempt federal lands administered by the BLM, National Park
Service, USFWS, and Forest Service, as well as for federal water projects and some military installations.
2 These are payments to states of 50 percent of mineral leasing ROW rents.
1 Does not include direct payments of land sales under the Southern Nevada Public Land Management Act and some calendar year payments to Clark
County, Nevada and the State of Nevada under the Santini-Burton Act because they were not reported to Treasury in 2012.
4 These are Secure Rural Schools and Community-Self-Determination Act payments to 18 counties in Western Oregon authorized by Public Law 1 10-
343.
Sources: USDOI 201 1, USDOI BLM 2012b.
Prevention and Control, the National Center for Health
Statistics (NCHS), the National Institute for
Occupational Safety and Health (NIOSH), and the
Bureau of Labor Statistics.
Risks from Diseases
Disease Incidence
Despite the difficulties in establishing correlations
between work conditions and disease, certain illnesses
have been linked to occupational hazards. For example,
asbestosis and lung cancer among insulation and
shipyard workers has been linked to their exposure to
asbestos (NIOSH 2012). Pneumoconiosis among coal
miners has been correlated with the inhalation of coal
dust. Occupational exposures to some metals, dusts, and
trace elements, as well as CO, carbon disulfide,
halogenated hydrocarbons, nitroglycerin, and nitrates,
can result in increased incidence of cardiovascular
disease. Neurotoxic disorders can arise from exposure
to a wide range of chemicals, including some pesticides.
Dermatological conditions like contact dermatitis,
infection, trauma, cancer, vitiligo, uticaria and
chloracne have a high occurrence in the agricultural,
forestry, and fishing industries.
Disease Mortality
Mortality rates for the 17 western states in the BLM
treatment area are listed in Table 3-24. The five most
common causes of death in the U.S., as well as in these
1 7 states, are heart disease, cancer, respiratory disease,
stroke (cerebrovascular diseases), and accidents (CDC
2011). Counties in the western U.S. that have the
highest mortality rates are located in southern and
eastern North Dakota, central Texas, southern New
Mexico, and eastern Montana. Mortality rates are
generally lowest in counties in central and western
Colorado, Alaska, and northern Utah (CDC 2011).
Mortality rates for males are nearly one and a half times
those as for females, and mortality rates for African
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
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January 2016
AFFECTED ENVIRONMENT
Americans over one and a quarter times those for
Caucasians (CDC 2011).
Risks from Injuries
Injury Incidence
In 2011, nearly 32.4 million nonfatal injuries were
reported in the U.S., almost 4.3 million of which were
transportation related (CDC 201 1). Injuries accounted
for 29 percent of emergency department visits during
2010 (CDC 2011).
The rate of hospitalizations for injury is significantly
higher among elderly persons than among all other age
groups (CDC 2011). In 2010, more than 4,500 U.S.
workers died from occupational injuries. Although
difficult to enumerate, annually about 49,000 deaths are
attributed to work-related illnesses. In 2010, an
estimated 3.9 million workers in private industry and
state and local government had a nonfatal occupational
injury or illness (NIOSH 2012). Some chronic injuries
may be directly linked to the nature of the work
performed. For example, vibration syndrome affects a
large proportion of workers using chippers, grinders,
chainsaws, jackhammers, or other handheld power
tools, causing blanching and reduced sensitivity in the
fingers. The Bureau of Labor Statistics reported that in
2010, an estimated 29 percent of all work-related illness
cases were due to musculoskeletal disorders (NIOSH
2012). Noise-induced hearing loss may also affect
production workers who are exposed to noise levels of
80 decibels or more on a daily basis.
Acute trauma at work remains a leading cause of death
and disability among U.S. workers. During the period
from 1992 through 2011, more than 115,000 U.S.
workers died from occupational injuries. The Census of
Fatal Occupational Injuries Summary (U.S. Department
of Labor Bureau of Labor Statistics 2013b) identified
4,693 workplace deaths from acute traumatic injury in
2011. Occupational fatalities resulted from numerous
causes, including transportation incidents, falls, contact
with objects and equipment, and homicides.
TABLE 3-24
Mortality Rates (per 100,000 Population)1 and Causes of Death by State 2010
State
Cause of Death
All
Diseases
Cancer
Accidents2
Cerebrovascular and
Cardiovascular Disease
Chronic Respiratory
Disease
Alaska
771.5
192.4
41.5
176.9
58.7
Arizona
693.1
178.6
43.1
154.2
46.7
California
646.7
200.0
37.0
156.9
27.8
Colorado
682.7
168.9
49.7
149.5
43.5
Idaho
731.6
201.3
47.0
159.9
42.1
Montana
754.7
196.0
51.3
161.0
53.2
Nebraska
717.8
194.7
48.8
167.4
35.8
Nevada
795.4
230.6
49.5
174.2
41.3
New Mexico
749.0
189.6
47.7
152.4
60.7
North Dakota
704.3
200.9
43.1
157.1
38.8
Oklahoma
915.5
285.2
67.4
191.3
60.3
Oregon
732.1
178.0
45.3
173.9
37.8
South Dakota
715.1
195.1
46.0
171.0
44.5
Texas
772.3
225.5
43.0
165.9
39.0
Utah
703.2
180.3
33.1
133.7
40.6
Washington
692.3
188.5
40.4
170.5
37.6
Wyoming
778.8
207.0
59.5
172.6
59.8
United States
747.0
218.2
42.2
172.8
38.0
1 Age-adjusted death rate per 100,000 population, which accounts for changes in the age distribution of the population.
2 Accidents do not include motor vehicle accidents.
Source: CDC 2011. _
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
3-40
January 2016
AFFECTED ENVIRONMENT
The occupational fatality rate in 2011 was
approximately 3.5 fatalities per 100,000 employed.
Fatality rates were highest for the agriculture, forestry,
fishing, and hunting; mining; transportation; and
construction industries. The fatality rate for the
agriculture, forestry, fishing, and hunting sector was the
highest, at 24.9 fatal industries per 100,000 workers.
The mining sector had the second highest rate, at 15.9
fatalities per 100,000 employed. In the transportation
and construction industries the rates were 15.3 and 9.1
fatalities per 100,000 employed, respectively. The
largest number of fatal work injuries resulted from
transportation and warehousing-related incidents, which
accounting for 16 percent of workplace fatalities in
2011 (U.S. Department of Labor Bureau of Labor
Statistics 2013b).
Injury Mortality
Over 180,000 Americans died from injuries nationwide
in 2010. About 20 percent of these resulted from motor
vehicle accidents, while other accidental deaths
occurred from unintentional falls, drowning, and
poisoning (CDC 2011). Injury is the leading cause of
death and disability among children and young adults.
Risks from Cancer
Cancer Incidence
Nationwide, the chance of developing some form of
cancer during one’s lifetime is estimated to be about 40
percent (American Cancer Society 2012). There are
many causes of cancer development, including
occupational exposure to carcinogens, environmental
contaminants, and substances in food. In the U.S., at
least 30 percent of all cancer deaths and 87 percent of
lung cancer deaths are attributed to tobacco smoking.
Work-related cancers are estimated to account for 4 to
10 percent of all malignancies. It is difficult to quantify
the information because of the long time intervals
between exposure and diagnosis, personal behavior
patterns, job changes, and exposure to other
carcinogens. The NIOSH has reported that
approximately 20,000 cancer deaths and 40,000 new
cases of cancer each year in the U.S. are attributable to
occupational hazards (NIOSH 2012). Millions of U.S.
workers are exposed to substances that have tested as
carcinogens in animal studies and it is estimated that
less than 2 percent of chemicals in commerce have been
tested for carcinogenicity (NIOSH 2012).
Cancer Mortality
Based on the data shown in Table 3-24, cancer
accounted for between 19 and 25 percent of all deaths in
the treatment states in 2010. Nationwide, cancers
account for approximately 23 percent of all fatalities
(CDC 2011). Cancer mortality rates are generally
highest in Washington, California, South Dakota, and
Oregon, and lowest in Utah, New Mexico, Oklahoma,
and Montana, and differ depending on race and sex.
Generally, males have higher rates of cancer mortality
than females, and African Americans have higher rates
than Caucasians.
Risks from Using Herbicides on Public
Lands
Based on data from the USDOI accident reporting
database (SMIS), there were five accidents involving
ATV/UTVs and pesticide application between October
1, 2009 and June 16, 2014.
Risks from Wildfire Control on Public
Lands
During FY 2013, 2,573 fires totaling 1,166,649 acres
were suppressed on public lands. The number of
human-caused fires was 838 and the number of
lightning-caused fires was 1,735. Approximately 54
percent of fires occurred on rangelands and other non¬
forest lands. The remainder occurred in forests (USDOI
BLM 2014e).
Wildfires cause the loss of life and property. According
to the National Interagency Fire Center (2014), 34
people died from wildland fire-related accidents in
2013. From 2006 through 2011, the leading cause of
firefighter deaths nationally, which include federal,
state, and local firefighters and volunteers, as well as
private individuals who were involved in direct support
of wildland fire operations were: stress/overexertion
(51.2 percent), vehicle/aircraft accidents (17.3 percent),
and being caught or trapped (9.1 percent; U.S. Fire
Administration 2013).
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
3-41
January 2016
Marine
Temperate
Steppe
Temperate
Desert
Mediterranean
Subtropical
r. 1
Desert
Subtropical
Steppe
Tundra
Subarctic
Marine
0 100 200 400
0 200 400
NATIONAL
PUBLIC LANDS
BOO
BOO
Miles
| Kilometers
1.200 1,600
Legend
Ecoregion Divisions
BLM-administered Lands
Source USDA Forest Service 2004a
Mote Coverage for BLM-administered lands is not available for Texas, Nebraska, or Oklahoma
Map 3-1
Ecoregion Divisions
100
200
300
400
Miles
Kilometers
200
bo a
4 3 3
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data
Original data were compiled from various sources This information may not meet National Map Accuracy Standards
This product was developed through digital means and may be updated without notice
3-42
Legend
'^/X/\ Class I Areas
BLM-administered Lands
N
wAe
s
Source: National Park Service 2007.
Note: Coverage for BLM-administered lands is not available for Texas. Nebraska, or Oklahoma
Map 3-2
Class I Areas
I Kilometers
0 50 100 200 300 400
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data
Original data were compiled from various sources This information may not meet National Map Accuracy Standards
This product was developed through digital means and may be updated without notice
3-43
Legend
BLM-administered Lands
■i Oil Production
I Gas Production
Mixed Production
Dry Well
Source: USGS 2007
Note Coverage for BLM-administered lands is not avilable for Texas. Nebraska, or Oklahoma.
Map 3-3
Oil and Gas Wells on
BLM-administered Lands
0 50 100 200 300 400
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.
Original data were compiled from various sources This information may not meet National Map Accuracy Standards
This product was developed through digital means and may be updated without notice
3-44
NATIONAL
i Kilometers
PUBLIC LANDS
C- A<
*
1
V >
2*"*
w. .
Sums-*
Legend
Alfisols
Aridisols
Andisols
Entisols
Gelisols
Histosols
Inceptisols
Mollisols
Spodosols
Ultisols
Vertisols
Source: USDA National Resources Conservation Service 2000 to Present.
Note: Coverage for BLM-administered lands is not available for Texas, Nebraska, or Oklahoma.
E
Map
Soil Orders on
3-4
Public Lands
0 50 100 200 300 400
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.
Original data were compiled from various sources This information may not meet National Map Accuracy Standards
This product was developed through digital means and may be updated without notice
3-45
Columbia River,
Snake River
Missouri River
Platte River
Arkansas
River
Rio Grande.Riyer
Colorado River
Pecos River
Sacramento River
.4
San Joaquin Riyer
Colville River
River
9 - Souris-Red-Rainy
10 - Missouri
11 - Arkansas-White-Red
12 - Texas-Gulf
13 - Rio Grande
14 - Upper Colorado
15 - Lower Colorado
16 - Great Basin
17 - Pacific Northwest
18 - California
19 - Alaska
NATIONAL
0 100 200 400 600 800
0 200 400 800 1.200
Miles
H Kilometers
1,600
PUBLIC LANDS
Legend
BLM-administered Lands
Hydrologic Regions
- Rivers
Source USGS 2005b
Note Coverage for BLM-administered lands is not available for Texas, Nebraska, or Oklahoma.
W
N
Map 3-5
Hydrologic Regions
0 50 100 200 300 400
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data
Original data were compiled from various sources This information may not meet National Map Accuracy Standards
This product was developed through digital means and may be updated without notice
3-46
NATIONAL
I Kilometers
PUBLIC LANDS,
1 mV
-31
*
C i
i' ^ WJ ™
f* 1
Legend
Condition Class 1
Condition Class 2
Condition Class 3
Water
Snow/Ice
Urban
Agriculture
Barren
Sparsely Vegetated
Unclassified
E
Map 3-6
Fire Regime
Condition Classes
on Public Lands
0 50 100 200
300 400
Miles
Source: Landfire 2010, 2011.
Note: Coverage for BLM-administered lands is not available for Texas, Nebraska, or Oklahoma
0 50 100
200
300
I Kilometers
400
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data
Original data were compiled from various sources This information may not meet National Map Accuracy Standards
This product was developed through digital means and may be updated without notice
3-47
NATIONAL
Miles
Kilometers
PUBLIC LANDS,
ijk
f ,
ft
,#
t
it ;
- r A **
\ 1&
V t &
k y
Legend
- Scenic or Historic Trails
Wild and Scenic Rivers
Wilderness Study Areas
Wilderness Areas
National Monuments
BLM-administered Lands
National Conservation Areas, Forest
Reserves, Cooperative Management
and Protection Areas, National
Recreation Areas
Sources USDI BLM 2013h
Note Coverage for BLM-administered lands is not available for Texas, Nebraska, or Oklahoma.
Map 3-7
National Landscape
Conservation System Areas
50 100
Kilometers
400
No warranty is made by the Bureau of Land Management as to the accuracy, reliability or completeness of these data for individual or aggregate use with other data
Original data were compiled from various sources This information may not meet National Map Accuracy Standards
This product was developed through digital means and may be updated without notice
3-48
CHAPTER 4
ENVIRONMENTAL CONSEQUENCES
ENVIRONMENTAL CONSEQUENCES
CHAPTER 4
ENVIRONMENTAL CONSEQUENCES
Introduction
This chapter examines how herbicide treatment
activities that utilize the three new active ingredients
(aminopyralid, fluroxypyr, and rimsulfuron) may affect
natural, cultural, and socioeconomic resources on public
lands. The focus of the analysis is on the impacts
associated with application of herbicide formulations
that include the three active ingredients, and on the
alternative proposals for use of these herbicides. These
herbicides would be part of a larger vegetation
management program, and would potentially be used in
conjunction with other treatment methods and other
currently approved herbicides. A summary of impacts
associated with the use of the 18 currently approved
herbicides and with other treatment methods can be
found in the Vegetation Treatments on Bureau of Land
Management Lands in 17 Western States PEIS (USDOI
BLM 2007a) and Vegetation Treatments on Bureau of
Land Management Lands in 17 Western States PER
(USDOI BLM 2007c).
How the Effects of the
Alternatives Were Estimated
Within each resource area, applicable direct and indirect
effects are evaluated. Cumulative effects, unavoidable
adverse effects, and resource commitments that are lost
or cannot be reversed are identified in this PEIS. These
impacts are defined as follows:
• Direct effects - Effects that are caused by the
action and occur at the same time and in the
same general location as the action.
• Indirect effects - Effects that occur at a
different time or in a different location than the
action to which the effects are related.
• Cumulative effects - Effects that result from
the incremental impact of the action when it is
added to other past, present, and reasonably
foreseeable future actions. Cumulative effects
can result from individually minor but
collectively significant actions taking place
over a period of time. For this PEIS, potential
cumulative effects include those that could
occur on other federal and non-federal lands.
Cumulative effects also consider other types of
vegetation treatments and treatments with other
herbicides.
• Unavoidable adverse commitments - Effects
that could occur as a result of implementing
any of the action alternatives. Some of these
effects would be short-term, while others
would be long-term.
• Irreversible commitments - Commitments that
cannot be reversed, except perhaps in the
extreme long term. This term applies primarily
to the effects of use of nonrenewable resources,
such as minerals or cultural resources, or to
factors, such as soil productivity, that are
renewable only over long periods of time.
• Irretrievable commitments - Commitments
that are lost for a period of time. For example,
timber production is lost while an area is
mined. The production lost is irretrievable, but
the action is reversible. If the site is reclaimed,
it is possible to resume timber production.
In addition, this PEIS considers the interaction of
effects, as follows:
• Additive - total loss of resources from more
than one incident.
• Countervailing - negative effects are
compensated for by beneficial effects.
• Synergistic - the total effect is greater than the
sum of the effects taken independently.
This chapter should be read together with Chapter 2
(Alternatives), which explains the alternative proposals
that the BLM is considering for use of the three new
herbicide active ingredients for treating vegetation, and
Chapter 3 (Affected Environment), which describes the
important resources and their occurrence and status on
public lands. The analyses of environmental
BLM Vegetation Treatments Three New Iterbicides
Final Programmatic E1S
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January 2016
ENVIRONMENTAL CONSEQUENCES
consequences in this chapter build upon and relate to
information presented in these earlier chapters to
identity which resources may be impacted and how and
where impacts might occur.
Assumptions for Analysis
This analysis addresses large, regional -scale trends and
issues that require integrated management across broad
landscapes. It also addresses regional-scale trends and
changes in the social and economic needs of people.
This analysis does not identify site-specific effects
because its focus is on broad-scale management
direction. As discussed in Chapter 1, Proposed Action
and Purpose and Need, site-specific issues would be
addressed through environmental analyses prepared at
the state, district, or field office level.
At the local level, the Ecosystem-Based Management
approach would be used during development of site-
specific management goals to ensure that they are
informed and adapted from learning based on science
and local knowledge.
The assumptions about vegetation treatments that were
made in the 2007 PEIS (USDOI BLM 2007a:4-l to 4-2)
carry over in this PEIS, as the new herbicides would be
integrated into current treatment programs.
Vegetation treatments are implemented with
consideration for the larger land management context in
which they occur. The BLM considers whether and how
treatment areas will be re vegetated or stabilized to
ensure the long-term viability of the project area. The
BLM strives to minimize long-term increases in bare
ground resulting from vegetation treatments, which
might allow invasive plants to increase in abundance.
Treated vegetation is removed from the site if it poses a
further risk as hazardous fuel.
The impacts analysis assumes the following:
• Vegetation treatments would be developed and
applied in an Integrated Pest Management
context, where all treatment methods, costs,
and goals are considered.
• Tool(s) identified for the treatment would be
the appropriate means to achieve the project
objective.
• Post-treatment follow-up such as seeding,
monitoring, and retreatment would occur, as
needed to achieve land management objectives.
• Maintenance of past treatments has occurred,
and the BLM would maintain improved
vegetation conditions, rather than
implementing stand-alone, one-time
treatments.
• The BLM would determine the need for the
action based on inventory data and monitoring.
Post-treatment monitoring would occur after
the project to ascertain its effectiveness in
achieving the resource objective(s).
• The BLM would comply with federal, state,
tribal, and local regulations that govern
activities on public lands.
• The BLM would continue to follow SOPs and
applicable mitigation listed in the 2007 PEIS
(USDOI BLM 2007a:Table 2-8) and ROD
(USDOI BLM 2007b:Table 2) under all
alternatives to ensure that risks to human health
and the environment would be kept to a
minimum.
Examples of SOPs that pertain to all resource areas
include the following:
• Conduct a pre-treatment survey for sensitive
resources.
• Identity the most appropriate treatment
method. If chemicals are the appropriate
treatment, then select the chemical that is least
damaging to the environment while providing
the desired results.
• Consider surrounding land uses before
selecting aerial spraying as a treatment method.
• Apply the least amount of herbicide needed to
achieve the desired results.
• Prepare a spill contingency plan in advance of
treatment.
• Notify adjacent landowners prior to treatment.
• Require licensed applicators to apply
herbicides.
• Use only USEPA-approved herbicides, and
follow product label directions and “advisory”
statements.
BLM Vegetation Treatments Three New Herbicides
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January 2016
ENVIRONMENTAL CONSEQUENCES
• Follow the product label for use and storage.
• Review, understand, and conform to the
“Environmental Hazards” section on the
herbicide label. This section warns of known
pesticide risks to the environment and provides
practical ways to avoid harm to organisms or
the environment.
• Avoid accidental direct spray and spill
conditions to minimize risks to resources.
• Avoid aerial spraying during periods of adverse
weather conditions.
• Make helicopter applications at a target
airspeed of 40 to 50 miles per hour (mph), and
at about 30 to 45 feet above ground.
• Keep a copy of Safety Data Sheets (SDSs)/
Material Safety Data Sheets (MSDSs)3 at work
sites.
• Keep records of each application.
• Implement additional applicable SOPs specific
to individual resources, which are provided in
the impact analysis section for each resource.
Additionally, mitigation measures specific to treatments
with the three new herbicides have been identified for
certain resource areas in Chapter 4. These mitigation
measures could further reduce impacts associated with
herbicide treatments.
Incomplete and Unavailable
Information
According to the Council on Environmental Quality
regulations for implementing the procedural provisions
of NEPA (40 CFR 1502.22), if the information is
essential to a reasoned choice among alternatives and
the cost of gathering it is not excessive, it must be
included or addressed in the PEIS.
Generally, the types of incomplete and unavailable
information are the same as those described in the 2007
3 Hazardous chemical reporting is now required to be done
via an SDS, rather than the previously used MSDS. During
the period of transition to the new reporting system,
herbicides may have either an associated MSDS or SDS.
PEIS (USDOI BLM 2007a:4-3 to 4-4). Although
knowledge about many aspects of terrestrial and aquatic
species, forestland, rangelands, the economy, and
society is still incomplete, the alternatives were
evaluated using the best available information.
Ecological and human health risk assessments were
developed by the BLM for aminopyralid, fluroxypyr,
and rimsulfuron to address many of the risks that would
be faced by humans, plants, and animals, including
special status species, from the use of these three active
ingredients. To assess risks to other resources from the
use of herbicides, the BLM consulted information in the
risk assessments and supporting documentation; state,
federal, and local databases. Geographic Information
System (GIS) data, and contract reports; subject experts
within and outside of the BLM; and the current
literature.
A programmatic analysis over a 17-state area generally
summarizes information that may be available at finer
scales (e.g. at the regional and local level), but is too de¬
centralized and dispersed to be presented effectively. In
these cases such information will be presented during
analysis at the local level to make more informed
decisions about specific treatment projects involving
aminopyralid, fluroxypyr, and rimsulfuron.
While additional information may add precision to
estimates or better specify relationships, new or
additional information is unlikely to significantly
change the understanding of the relationships that form
the basis of the effects analysis presented in this chapter.
Subsequent Analysis before Projects
Before site-specific actions are implemented and an
irreversible commitment of resources is made,
information essential to fine-scale decisions will be
obtained by the local land managers. Localized data and
information will be used to supplement or refine
regional-level data and identify methods and procedures
best suited to local conditions in order to achieve the
objectives in this PEIS. Further analysis would be
necessary to deal with site-specific conditions and
processes. For example, mitigation measures identified
in the following sections (and in the 2007 PEIS) would
be appropriate for protecting resources under the wide
range of conditions that must be considered at the
programmatic level of analysis. However, by
considering more site-specific parameters, such as soil
and vegetation type and amount of rainfall, the BLM
may be able to use less restrictive mitigation measures
BLM Vegetation Treatments Three New Herbicides
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January 2016
ENVIRONMENTAL CONSEQUENCES
and still ensure adequate protection of the resource. It is
also possible that more restrictive measures would be
necessary. This subsequent analysis will be used to
bridge the gap between broad-scale direction and site-
specific decisions. This ‘"’step-down” analysis involves
subsequent NEPA analysis at various levels, which may
include the regional or statewide level, the district or
field office level, and the local or project-specific level
(USDOl BLM 2007a: 1-19).
Program Goals by Ecoregion
The goals of herbicide treatments were developed for
the 2007 PEIS, and are presented by ecoregion in the
following sections. These goals continue to represent
what the BLM hopes to achieve through the use of
vegetation treatments on public lands, and are being
carried forward in this PEIS. Herbicide treatments with
the three new herbicides would be incorporated into the
larger treatment program designed to meet these goals.
Temperate Desert Ecoregion
Over 70 percent of herbicide treatments would occur on
BLM land in the Temperate Desert Ecoregion. Most of
these treatments would be used to meet vegetation and
integrated weed management (IWM) objectives (as
outlined in BLM Manual 9015 [USDOl BLM 1992]; 33
percent of treatments), reduce hazardous fuels (25
percent), conduct emergency stabilization and burned
area rehabilitation activities (19 percent), and improve
rangeland health (12 percent). Improvements of wildlife
habitat and watershed health are objectives of lesser
importance (6 and 5 percent of treatments, respectively)
in this ecoregion.
Temperate Steppe Ecoregion
In the Temperate Steppe Ecoregion, most herbicide
treatments would be conducted to meet integrated
vegetation management (IVM) and/or IWM objectives
(62 percent of treatments). Other important objectives
include hazardous fuels reduction (25 percent) and
improvement of rangeland health (1 1 percent).
Subtropical Steppe Ecoregion
On BLM lands in the Subtropical Steppe Ecoregion,
herbicide treatments would be used to improve habitat
(38 percent of treatments), improve rangeland health
(21 percent), reduce hazardous fuels (17 percent), and
meet IVM and/or IWM objectives (1 1 percent).
Mediterranean Ecoregion
In the Mediterranean Ecoregion, chemical treatments
would be conducted primarily to improve forest health
(35 percent of treatments), and to meet maintenance-
related (28 percent) and IVM and/or IWM (20 percent)
objectives. Improvement of rangeland health (9 percent)
and recreation areas (6 percent) would also be important
objectives.
Marine Ecoregion
On BLM lands in the Marine Ecoregion, the majority of
herbicide treatments would be conducted to meet IVM
and/or IWM (69 percent) and maintenance-related (22
percent) objectives. Some less important treatment
objectives include maintaining ROWs (3 percent),
improving forest health (3 percent), and improving
habitat for native vegetation (3 percent).
Subtropical Desert Ecoregion
Less than 1 percent of herbicide treatments would occur
on BLM land in the Subtropical Desert Ecoregion.
Herbicide treatments in this ecoregion would focus on
managing woody species that have invaded shortgrass
and mixed-grass prairies and riparian areas of the desert
Southwest.
Tundra and Subarctic Ecoregions
Herbicide treatments in this ecoregion would occur on a
very small portion of public lands in these ecoregions. It
is estimated that no more than 1,000 acres of public
lands in Alaska would be treated with herbicides in any
year. Goals of future herbicide treatments in these
ecoregions would be to control invasive species in
disturbed areas (along trails and roads, and at heavy use
areas) to prevent their spread into more pristine areas.
Land Use
Laws, regulations, and plans that pertain to land use are
summarized in the 2007 PEIS (BLM 2007a:4-5). The
FLPMA of 1976 directs the BLM to manage public
lands to protect their resource values, and to develop
resource management plans consistent with those of
state and local governments. Management actions on
public lands are guided by land use plans, which
establish goals and objectives for resource management.
Similar to the 2007 PEIS, this PEIS is a national-level
programmatic analysis. It contains broad regional
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
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January 2016
ENVIRONMENTAL CONSEQUENCES
descriptions of resources, provides a broad
environmental impact analysis, and provides Bureau¬
wide decisions on herbicide use for vegetation
management. Additionally, it provides an umbrella ESA
Section 7 consultation for the broad range of activities
described in the PEIS.
Impacts to land uses have not been identified at the
programmatic level. It is assumed that vegetation
treatments by all methods would continue to occur on
up to 6 million acres annually, that treatments would
continue to focus on areas with high levels of hazardous
fuels and invasive plants, that land uses would comply
with the intent of Congress as stated in the FLPMA (43
U.S.C. 1701 et seq.), and that future land uses would be
similar to those that currently occur on public lands.
Adding new active ingredients to the BLM’s list of
approved herbicides would be expected to have a
minimal effect on land uses. Herbicide treatments
would continue to be conducted over the same
geographic area and with the same program goals, and
so would have no additional effects. However, it is
assumed that under all alternatives, existing land use
plans will be updated to include additions to the
approved herbicide list, with modifications occurring
primarily at the field office level.
Air Quality and Climate
Air quality is the measure of the atmospheric
concentration of defined pollutants in a specific area.
Air quality is affected by pollutant emission sources, as
well as the movement of pollutants in the air via wind
and other weather patterns. This air quality analysis
focuses on the release of criteria pollutants and GHGs
associated with herbicide treatments.
Scoping Comments and Other Issues
Evaluated in the Assessment
Scoping comments requested that this PEIS quantify
GHG emissions from the proposed project activities.
Emission Sources and Impact
Assessment Methodology
The potential impacts of herbicide use on air quality
originate primarily from ground vehicle (truck,
ATV/UTV, and boat) and aircraft (plane and helicopter)
emissions, as well as fugitive dust (dust created by
vehicle travel on unpaved roads) resulting from
herbicide transport and application. In addition, spray
drift (movement of herbicide in the air to unintended
locations) and volatilization (the evaporation of liquid to
gas) of applied herbicides temporarily results in
herbicide particles in the air, which can be inhaled and
deposited on skin or plant surfaces and affect humans,
wildlife, and non-target plants. Herbicide particles can
be transported away from the target location, depending
on weather conditions and the herbicide application
method.
Methodology for Assessing Impacts to
Air Quality
The methodology for assessing impacts to air quality
from herbicide applications is discussed in detail in the
2007 PEIS (USDOI BLM 2007a:4-6 to 4-8). Additional
information on methodology, data sources, and results
may be found in the air quality report that was prepared
as supporting documentation for the 2007 PEIS (ENSR
2005). The air quality methodology includes calculating
annual emissions for the proposed alternatives by state
from vehicle exhaust and fugitive dust (from travel on
unpaved roads). Emissions were calculated for CO,
nitrogen oxides (NOx), total suspended particulates
(TSP), PM io, PM25, and volatile organic compounds
(VOCs). Annual exhaust emissions were determined
using emission factor data for vehicles likely to be used
in herbicide treatments and for transportation, and
assumptions about periods of operation. It should be
noted that the 2007 PEIS used 1998 emission factors,
and therefore likely overestimates emissions using
newer vehicles. Table 4-1 presents the annual emissions
for Alternative B of the 2007 PEIS, which carries over
to all the alternatives considered in this analysis (as the
total treatment acreage would not change). Annual
fugitive dust emissions were determined using emission
factors that considered trip mileage and soil properties.
In this analysis, PSD levels are used to indicate whether
the herbicide use alternatives would significantly affect
air quality.
The USEPA’s California Puff (CALPUFF) “lite” air
pollutant dispersion model (a first level screening model
referenced in Appendix W of 40 CFR Part 51) was used
to provide an example of potential TSP and PM
emissions resulting from a single herbicide spraying
event. Spray drift from various herbicide application
methods was assessed using the AgDrift model.
As the current proposed action adds new active
ingredients to the list of herbicides approved for use by
the BLM, but does not increase the total amount of
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
4-5
January 2016
ENVIRONMENTAL CONSEQUENCES
TABLE 4-1
Annual Emissions Summary for Herbicide Treatments Under All Alternatives
State
Pollutant (tons per year)
CO
NOx
TSP
PM.o
PM2i
VOCs
Alaska
0.00
0.00
0.00
0.00
0.00
0.00
Arizona
3.40
0.41
14.66
3.09
0.42
0.24
California
0.54
0.06
2.37
0.50
0.07
0.04
Colorado
2.06
0.24
4.88
1.07
0.14
0.18
Idaho
24.22
2.92
60.35
13.18
1.67
1.71
Montana
4.97
0.60
11.58
2.58
0.32
0.35
Nebraska
0.00
0.00
0.00
0.00
0.00
0.00
Nevada
10.81
1.26
47.63
10.18
1.39
0.75
New Mexico
4.85
0.54
17.73
3.97
0.54
0.40
North Dakota
0.00
0.00
0.00
0.00
0.00
0.00
Oklahoma
0.00
0.00
0.00
0.00
0.00
0.00
Oregon (Total)
5.00
0.57
28.77
6.97
0.99
0.34
Eastern
1.31
0.15
2.55
0.56
0.07
0.09
Western
3.87
0.43
26.22
6.40
0.91
0.26
South Dakota
0.08
0.01
0.20
0.05
0.01
0.01
Texas
1.07
0.13
2.46
0.55
0.07
0.08
Utah
2.42
0.28
8.56
1.88
0.25
0.21
Washington
0.43
0.05
1.01
0.23
0.03
0.03
Wyoming
2.42
0.28
5.69
1.24
0.16
0.21
Total
62.27
7.35
205.89
45.49
6.06
4.55
Source: USDOI BLM 2007a.
herbicide application, a new analysis of emissions of
criteria pollutants has not been completed for this PEIS.
However, since the 2007 PEIS did not consider GHG
emissions, a GHG emission analysis has been
completed for this PEIS. Mobile source GHG emissions
were estimated using emission factor data for vehicles
likely to be used in herbicide treatments and for
transportation, using 2009 model year emission factors.
A quantitative analysis of carbon sequestration
(adsorption of atmospheric carbon dioxide by
vegetation and stored in woody biomass) was not
conducted, as there is no appropriate protocol for
evaluating impacts of land use changes on atmospheric
carbon release and sequestration.
Standard Operating Procedures
The 2007 PEIS (USDOI BLM 2007a:4-8 to 4-9) lists
SOPs that the BLM follows to minimize the potential
adverse effects of herbicide use on air quality. These
SOPs would continue to apply to herbicide treatments
involving aminopyralid, fluroxypyr, and rimsulfuron:
• Consider the effects of wind, humidity,
temperature inversions, and heavy rainfall on
herbicide effectiveness and risks.
• Apply herbicides in favorable weather
conditions to minimize drift. For example, do
not treat when winds exceed 10 mph (6 mph
for aerial applications) or rainfall is imminent.
• Use drift reduction agents, as appropriate, to
reduce the drift hazard.
• Select proper application equipment (e.g.,
spray equipment that produces 200- to 800-
micron diameter droplets [spray droplets of 100
microns and less are most prone to drift]).
• Select proper application methods (e.g., set
maximum spray heights and use appropriate
buffer distances between spray sites and non¬
target resources).
Additionally, all guidance provided in BLM manuals
and handbooks would continue to be followed. At the
local level, the BLM would consider best management
practices (BMPs) to reduce GHG emissions associated
with herbicide treatments, as appropriate.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
4-6
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ENVIRONMENTAL CONSEQUENCES
Impacts by Alternative
Impacts Common to All Alternatives
Based on the air quality analysis presented in the 2007
PEIS (USDOl BLM 2007a:4-9 to 4-13), the potential
impacts from herbicide applications on local and
regional air quality would be minor under all of the
treatment alternatives. Additionally, since the total area
treated using herbicides would be the same under all of
the alternatives, differences in air quality emissions
between alternatives would be minor.
Annual Air Quality Emissions
None of the predicted annual emissions by pollutant,
state, or alternative would exceed PSD annual emission
significance thresholds. Furthermore, under each
alternative, the total emissions from all the states for
each pollutant would be less than 25 percent of the PSD
threshold (250 tons per year) for a single facility.
Comparing the total emissions produced by all the states
to the PSD threshold is especially conservative because
the PSD threshold is designed to apply to one facility or
a group of facilities and not entire states. Potential
emissions would be highest in states with the greatest
number of acres treated. Based on CALPUFF “lite”
modeling, all PM concentrations resulting from a single
example herbicide spraying event would be
substantially lower than NAAQS thresholds at five
representative locations, and predicted concentrations
would be at least four orders of magnitude smaller than
assumed background concentrations (Table 4-2).
Spray Drift and Volatilization
Under all alternatives, atmospheric concentrations of
herbicides (predicted by particle size) resulting from
spray drift from aerial, ground vehicle, and hand
applications would be temporary in nature (most
predominant at the time and location of treatment) and,
as predicted by modeling, would not significantly
impact air quality. Based on modeling, herbicide
concentrations in the air tend to increase up to 1.5
kilometers (km) from the point of application
(concentrations may double between 0.6 and 1.5 km
from the application site), but then decrease slowly at
greater distances.
Chemical volatilization is temporary in nature, and none
of the currently approved herbicides or the three
proposed for use are likely to result in substantial
volatilization from soils. Chemical vapor pressure (the
pressure exerted by a vapor in equilibrium with its solid
or liquid phase) largely affects the potential for
volatilization of applied herbicides. Based on their
vapor pressures, aminopyralid, fluroxypyr, and
rimsulfuron are not expected to volatilize from dry soil
surfaces, and are essentially non-volatile from water and
moist soil (U.S. National Library of Medicine 2006,
2011, 2012). Therefore, application of these herbicides
would not impact air quality through volatilization.
Greenhouse Gas Analysis
Estimated annual GHG emissions from the project were
determined based on the methodology described under
Methodology for Assessing Impacts to Air Quality,
which can be found earlier in this Air Quality and
Climate section. Based on projections for trip mileage
made for Alternative B of the 2007 PEIS, GF1G
emissions associated with vehicles (ground and aerial)
used to transport and apply herbicides were calculated.
More information on the procedures used to estimate
emissions, including uncertainties and assumptions, can
be found in the Annual Emissions Inventory for BLM
Vegetation Treatment Methods (ENSR 2005). As the
total assumed treated acreage under that alternative
(931,850) would be the same under all the alternatives
analyzed in this document, there is no difference under
the alternatives as far as GHG emissions.
Based on a total herbicide treatment acreage of
approximately 932,000 acres, the proposed herbicide
treatments would generate approximately 3,333
MTC02e/yr of C02, 14 MTC02e/yr of N20, and 2
MTCO?e/yr of methane (CH4). Therefore, total GHG
emissions associated with the herbicide treatments
under all the alternatives is approximately 3,350
MTCO?e/yr. A comparison of this number to total
emissions for the western U.S. helps provide an
indication of the magnitude of GHG emissions
associated with the project. Based on a review of GHG
inventories provided by the USEPA (2014), not all 17
states covered in the analysis area have completed an
inventory; no data are available for Idaho, Nebraska,
North Dakota, or Wyoming. For the remaining 13 states
in the western U.S., total combined reported annual
GHG emissions is approximately 1,400 MMT (million
metric tons) C02e/yr. Estimated annual project-related
emissions are 0.0002 percent of this total, and 0.00006
percent of the annual national reported GHG emissions
of 5,546.3 MMTC02e/yr. Additionally, annual
emissions would be approximately 13 percent of the
amount (25,000 MTC02e/yr) that would require
mandatory reporting under the USEPA’s GHG
Reporting Rule, which is anticipated to capture
BLM Vegetation Treatments Three New I lerbieides
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ENVIRONMENTAL CONSEQUENCES
TABLE 4-2
Example NAAQS Compliance Analysis for Herbicide Treatments Under All Alternatives
Location
Pollutant
Averaging
Period
CALPUEF
Concentration
(Pg/m')
Background
Concentration1
(pg/m3)
Total
Concentration
(Pg/nQ
NAAQS
Standard2
(pg/m3)
Tucson,
Arizona
TSP
24-hour
2.79E-04
40
40
NA
Annual
7.65E-07
11
11
NA
PM10
24-hour
5.47E-04
30
30
150
Annual
1.50E-06
8
8
50
PM2.5
24-hour
7.21E-05
30
30
35
Annual
1.97E-07
8
8
15
Glasgow,
Montana
TSP
24-hour
1.06E-04
40
40
NA
Annual
2.90E-07
11
11
NA
-a
©
24-hour
2.36E-04
30
30
150
Annual
6.48E-07
8
8
50
PM25
24-hour
2.82E-05
30
30
35
Annual
7.74E-08
8
8
15
Winnemucca,
Nevada
TSP
24-hour
1.36E-04
40
40
NA
Annual
3.72E-07
11
11
NA
PM.o
24-hour
2.72E-04
30
30
150
Annual
7.44E-07
8
8
50
pm25
24-hour
3.60E-05
30
30
35
Annual
9.85E-08
8
8
15
Medford,
Oregon
TSP
24-hour
3.75E-03
40
40
NA
Annual
1 .04E-05
11
11
NA
PM.o
24-hour
8.20E-03
30
30
150
Annual
2.28E-05
8
8
50
pm25
24-hour
1.14E-03
30
30
35
Annual
3.19E-06
8
8
15
Lander,
Wyoming
TSP
24-hour
6.08E-05
40
40
NA
Annual
1 .67E-07
11
11
NA
PM10
24-hour
1.37E-04
30
30
150
Annual
3.75E-07
8
8
50
pm25
24-hour
1.72E-05
30
30
35
Annual
4.70E-08
8
8
15
1 PM10 data from Table 5 of the Montana Modeling Guideline for Air Quality Permits (November 2007; Montana Department of
Environmental Quality 2007). TSP concentrations calculated by multiplying PM10 data by 1.33. PM]0 concentrations are also
conservatively used as background concentrations for PM2 5.
2 None of the states analyzed have ambient air quality standards for TSP.
NA = Not applicable; and pg/m3 = micrograms per cubic meter.
approximately 85 to 90 percent of national GHG
emissions (USEPA 201 2d).
In terms of net GHG emissions, it is anticipated that
under all of the alternatives, reductions in wildfire risk
associated with herbicide treatments would result in
indirect reduction in GHG emissions. Smoke from
wildfires is a biogenic source of GHG emissions, and
wildfires can be exacerbated by certain invasive plants,
such as cheatgrass and other annual grasses. Reducing
wildfires is identified in the President’s Climate Action
Plan (Executive Office of the President 2013) as a
specific effort to protect natural resources. Wildfires
generated approximately 97 MMT C02e/yr in 2013
(USEPA 2015), which represented 0.7 percent of total
national emissions for that year. Because many factors
contribute to wildfire risk, it is not possible to quantify
the contribution to net reductions in GHG emissions of
the proposed herbicide treatments. However, the
reduction in wildfire risk from successful vegetation
BLM Vegetation Treatments Three New Herbicides
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January 2016
ENVIRONMENTAL CONSEQUENCES
treatments would be expected to have long-term
beneficial effects over many years.
Given the relatively low amount of GHG emissions
associated with herbicide treatments, and their role in
larger BLM efforts to reduce the frequency, extent, and
severity of wildfire, none of the alternatives are
expected to have a significant adverse effect on GHG
emissions or climate change.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
The No Action Alternative corresponds to the Preferred
Alternative in the 2007 PEIS. The air quality analysis
for this alternative assumed that 932,000 acres would be
treated using herbicides annually. While the BLM has
not come close to this maximum acreage since the
release of the ROD for the 2007 PEIS, for the purposes
of this analysis, the tables from the 2007 PEIS
(reprinted as Tables 4-1 and 4-2 in this document) are
still considered to be suitable, conservative estimates.
As indicated in Table 4-1, total pollutant emissions
would include approximately 206 tpy TSP, 62 tpy CO,
and 45 tpy PMio- Total GHG emissions would be 3,350
MTCO^e/yr. These emissions would continue to
dominate in states with the greatest number of acres
treated. While Table 4-1 assumes that the greatest
treatment acreage would occur in Idaho and Nevada, in
reality more extensive herbicide treatments occurred in
New Mexico during 2006 to 2011. However, no states
had treatment acres that reached or exceeded the
estimate for Idaho. Therefore, Table 4-1 should be used
as a guide, with the understanding that the proportion of
treatment acres by a state in any given year is likely to
shift over time. Idaho, Nevada, New Mexico, Oregon,
and Wyoming are likely to continue to be among the
states with the greatest annual air quality emissions.
Although not quantified, herbicide treatments under
Alternative A would be expected to have a positive
effect on air quality by reducing the risk of wildfire.
Smoke and wildfire cause short-term impacts to
visibility and air quality, predominantly through the
release of PM and CO. Actions to reduce wildfire risk
would continue to have an indirect effect on air quality,
depending on the efficacy of fuels reduction treatments.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under the Preferred Alternative, it is expected the total
annual emissions of criteria pollutants and GHGs would
be similar to those under the No Action Alternative.
With the introduction of the three new active
ingredients, the BLM would change its relative use of
herbicides, but the total area treated is still assumed to
be 932,000 acres. Likewise, it is assumed that there
would be no difference in the method of application for
the new herbicides. As under the No Action Alternative,
it is expected that the greatest release of air quality
pollutants would likely occur in Idaho, Nevada, New
Mexico, Oregon, and Wyoming.
Benefits to air quality from reduction of wildfire risk
would be similar to those under the No Action
Alternative. Treatments would continue to target
cheatgrass and other fire fuels.
Alternative C - No Aerial Application of New
Herbicides
Under this alternative, the new herbicides would not be
available for treatments involving aerial application
methods. Instead, currently approved herbicides would
continue to be utilized for plane and helicopter
treatments. Therefore, it is expected that the overall
extent of aerial applications would be much the same as
at present and under the other action alternatives. Total
releases of air quality pollutants, including criteria
pollutants and GHGs also would be similar to those
under the other alternatives. Similar to Alternatives A
and B, it is expected that the greatest release of air
quality pollutants would likely occur in Idaho, Nevada,
New Mexico, Oregon, and Wyoming.
Benefits to air quality from reduction of wildfire risk
would be similar to those under the other alternatives.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under Alternative D, total emissions of air quality
pollutants would be much the same as under the other
alternatives. Although rimsulfuron would not be
available for use under this alternative, currently
approved herbicides (such as aminopyralid) would
continue to be used to meet treatment goals, and the
total area treated with herbicides by aerial and ground
methods would be similar to the area treated under the
other alternatives. Therefore the total emissions of
criteria pollutants and GHGs would be about the same
as under the No Action Alternative and the other action
alternatives. Similar to the other alternatives, it is
expected that the greatest release of air quality
BLM Vegetation Treatments Three New Herbicides
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January 2016
ENVIRONMENTAL CONSEQUENCES
pollutants would likely occur in Idaho, Nevada, New
Mexico, Oregon, and Wyoming.
Benefits to air quality from reduction of wildfire risk
would be similar to those under the other alternatives.
Mitigation for Herbicide Treatment
Impacts
No mitigation measures are proposed for air quality at
the programmatic level.
Soil Resources
Introduction
Soil is an essential component of natural ecosystems,
providing habitat for a great variety of organisms and a
medium for plant growth, and protecting downgradient
ecosystems by serving as a physical and biological filter
of chemicals in the environment (Wild 1993).
Noxious weeds and other invasive vegetation can
impact soil function and reduce soil biodiversity. The
amount of moisture in the soil can be altered if
infiltration is reduced and runoff is increased on sites
dominated by invasive plants (Lacey et al. 1989). Many
noxious weeds and other invasive plants have relatively
sparse canopies, which allow for greater evaporation
from the exposed soil than dense vegetative cover. Sites
infested with invasive plants often have more extreme
soil temperatures that can alter soil moisture regimes.
Noxious weeds and other invasive plants may alter soil
nutrient availability for native species, alter soil
constituents (e.g., soil fungi and bacteria), and slow the
rate of natural plant succession (Olson 1999a). Some
weeds also produce toxins or allelopathic compounds
that can suppress the growth and germination of other
plants (Kelsye and Bedunah 1 989).
Herbicide applications inevitably result in contact with
soils, either intentionally for systemic treatments, or
unintentionally as spills, overspray, spray drift, or
windblown dust. In addition to direct application,
transmission to soil may occur when an herbicide is
transported through the plant from sprayed aboveground
portions to roots, where it may be released into soil.
Also, some herbicides remain active in plant tissue and
can be released into the soil during plant decay and
result in residual herbicide activity.
Scoping Comments and Other Issues
Evaluated in the Assessment
Several scoping comments were concerned with the
persistence of the herbicides in soil and residual soil
activity, particularly in regard to aminopyralid.
Herbicide fate in soil and the potential for transport of
the herbicide from the treatment site on wind-blown soil
particles were also concerns.
Standard Operating Procedures
The BLM would continue to implement the SOPs
identified in the 2007 PEIS to reduce impacts to soil:
• Minimize treatments in areas where herbicide
runoff is likely, such as steep slopes when
heavy rainfall is expected.
• Minimize use of herbicides that have high soil
mobility, particularly in areas where soil
properties increase the potential for mobility.
• Do not apply granular herbicides on slopes of
more than 1 5 percent where there is the
possibility of runoff carrying the granules into
non-target areas.
In addition, the BLM follows practices, when
implementing herbicide treatments, which help
minimize effects to soil. The BLM considers herbicide
and target site characteristics to determine the suitability
of the herbicide at that location. Knowledge of herbicide
persistence, mobility, and adsorption are included in
herbicide selection. Additionally, herbicide applications
are timed in relation to soil moisture and anticipated
weather conditions to reduce the potential for off-site
transport. Herbicide applications are avoided when the
soil moisture status and site characteristics increase the
possibility of runoff or deep percolation.
Factors that Influence the Fate,
Transport, and Persistence of
Herbicides in Soil
The fate and transport of herbicides in soil is a function
of their interaction with the soil environment, and is
generally considered a complex process (Bovey 2001).
Chemical, physical, and biological soil processes
influence herbicide availability, phytotoxicity, and fate
BLM Vegetation Treatments Three New Herbicides
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ENVIRONMENTAL CONSEQUENCES
and transport. Herbicides dissipate from soils by
transport with water or wind, through chemical or
biological degradation processes, or by immobilization
through adsorption onto soil surfaces. These processes
are discussed in more detail in the 2007 PEIS (USDOI
BLM 2007a:4-14 to 4-15). The estimated half-life and
soil adsorption (organic carbon-water partitioning
coefficient) of the three herbicides considered in this
PEIS are presented in Table 4-3.
TABLE 4-3
Estimated Soil Half-life (Aerobic Conditions) and
Adsorption Affinity for Active Ingredients
Herbicide
Soil Half-
life (days)
Soil Adsorption (K,,,.)
Aminopyralid
32 to 533
1.05 to 24.3 mL/g
Fluroxypyr
7-23
50 to 1 36 mL/g
Rimsulfuron
5 to 40
19 to 74 mL/g
Sources: USEPA 2005b, New York State Department of
Environmental Conservation (NYSDEC) 2009, U S. National Library
of Medicine 2011.
mL/g = milliliters per gram.
Soil structure affects water movement and may allow
herbicides to move through the soil profile before being
absorbed or degraded. Large soil cracks or openings can
cause rapid herbicide movement. Soil texture affects the
surface charge and the surface area for pesticide
adsorption. Soils with a higher clay content have a
greater ability to hold pesticides, but are more
susceptible to runoff. Sandy soils leach more readily
and provide fewer sites for pesticide adsorption.
Organic matter content is considered the most important
soil property affecting pesticide adsorption. Pesticides
are very strongly attracted to the surface of organic
matter and are less likely to leach in soils high in
organic matter.
Summary of Herbicide Impacts
The following section discusses impacts to soil from the
three active ingredients proposed for use. This
assessment of impacts assumes that SOPs listed in the
2007 PEIS (USDOI BLM 2007a:Table 2-8) would be
followed when using the three herbicides. These
procedures, which have designed to reduce potential
unintended impacts to soil, include using the lowest
effective application rate; testing smaller areas for
unintended consequences prior to treating larger areas;
evaluating soil characteristics to determine the
likelihood of herbicide transport by runoff, infiltration,
or wind; limiting herbicide use on fine-textured and
sandy soils, especially where soil can be transported
onto adjacent areas, potentially harming non-target
vegetation; and carefully evaluating the use of
herbicides on hot, dry, cold, wet, sodic (containing high
levels of sodium), and saline (containing high levels of
salts) soils.
Herbicides may indirectly affect soil through plant
removal, resulting in changes in physical and biological
soil parameters. As vegetation is removed, there is less
plant material to intercept rainfall and less to contribute
organic material to the soil. Loss of plant material and
soil organic matter can increase the risk of soil
susceptibility to wind and water erosion. The risk for
increased erosion would be temporary, lasting only until
vegetation is reestablished. If herbicide treatments lead
to revegetation with native plants, soil stability may be
improved relative to sites dominated by invasive plants.
Use of herbicides to manage noxious weeds and other
non-native, invasive species could benefit soil. Invasive
plants can increase the potential for wind or water
erosion by altering fire frequency or producing
chemicals that directly affect soil quality or organisms.
Negative effects associated with invasive plant species
include increased sediment deposition and erosion, and
alteration of soil nutrient cycles (Bossard et al. 2000).
For example, soft brome changes the physical
characteristics of soil and alters the cycling of carbon
and nitrogen (Norton et al. 2004).
Cheatgrass and other annual grasses increase the risk of
fire, so control of these species can minimize risk of fire
damage to soil. Soil can be damaged by fire through
changes to its structure, particularly through the loss of
organic matter, which can occur even at relatively low
temperatures. The loss of soil structure increases the
bulk density of the soil and reduces its porosity, thereby
reducing soil productivity and making the soil more
vulnerable to postfire runoff and erosion (Neary et al.
2005).
The potential effects of herbicides on biological soil
crusts are discussed in the 2007 PEIS (USDOI BLM
2007a:4-15 to 4-16). Past studies have shown both
positive and negative effects to biological soil crusts as
a result of herbicide treatments. Cyanobacteria, lichen,
and moss constituents may be impacted to varying
degrees. However, use of herbicides can also benefit
biological soil crusts by preventing the invasion of
annual grasses, which reduce biological crust cover. The
BLM’s guidance manual on biological soil crusts
instructs that caution should be used when applying
herbicides to soils that support these crusts (Belnap et
al. 2001).
BLM Vegetation Treatments Three New 1 lerbicides
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ENVIRONMENTAL CONSEQUENCES
Impacts of Aminopyralid
Aminopyralid is broken down in the soil by microbes
and sunlight. Studies of aminopyralid show a wide
range of soil half-lives under aerobic conditions (from 5
to 533 days; as summarized in AECOM 2015). Given
the variability, there is some uncertainty as to how long
this active ingredient persists in the environment after
application. Dow AgroSciences (2005) lists the average
half-life for aminopyralid at 34.5 days for North
American soils. A recent study in Colorado found that
the half-life of aminopyralid was approximately 29
days, with no appreciable herbicide residue left after 1
year (Lindenmyer 2012). It is expected that
aminopyralid remains active in the soil for a month or
more after application, and may have residual activity
during this time.
Based in its low toxicity to terrestrial invertebrates
(AECOM 2015), aminopyralid is believed to be of low
toxicity to soil macroorganisms. However, there is a
lack of information about its toxicity to soil
microorganisms, and about associated long-term effects
to soil productivity.
Aminopyralid is persistent in plant materials and the
manure of animals that have eaten plant materials
treated with this herbicide. Therefore, compost and
mulch made from contaminated plants and/or manure, if
applied to soil, can adversely affect crops and other
plantings (Washington State University Extension
2011). These contaminated materials should not be used
as soil amendments.
Aminopyralid is weakly sorbed (attached by physical or
chemical processes) to soil (Fast 2010), and therefore is
unlikely to be transported off-site in large amounts on
wind-blown soil.
Impacts of Fluroxypyr
Fluroxypyr is rapidly degraded in soil by
microorganisms, with reported half-lives of 1 week to
23 days under aerobic conditions (Lehmann 1991,
USEPA 1998a, National Library of Medicine 201 1). In
one study, only 1 percent of the active ingredient was
detected after 3 months (Brumhard and Fuhr 1992 cited
in National Libraiy of Medicine 2011). Fluroxypyr is
mobile to very mobile in soil, but its movement is
reduced by its quick microbial degradation. Fluroxypyr
has very minimal residual soil activity.
Fluroxypyr has two major metabolites: a pyridine and a
methoxypyridine. Fluroxypyr degrades first to the
pyridine and then to the methoxypyridine, which is
persistent in soil (Lehmann 1991; Cederlund et al.
2012). This second degradate has a high tendency to
adsorb to soil, and is slowly degraded in place by
microbial degradation and volatilization (Lehmann
1991). In one study, no significant degradation of the
second degradate was observed after 350 days
(Cederlund et al. 2012); however, another study
observed soil half-lives of 90 to 570 days under various
laboratory conditions (Lehmann et al. 1990).
Based in its low toxicity to terrestrial invertebrates
(AECOM 2014a), fluroxypyr is believed to be of low
toxicity to soil macroorganisms. However, there is a
lack of information about its toxicity to soil
microorganisms. Long-term effects to soil productivity
and biological processes are not known.
Given its rapid degradation, high mobility in soil, and
minimal residual activity, there would be a low risk of
transport of fluroxypyr off of the treatment site in
windblown soil. The amount adsorbed to soil would be
much less than the amount applied to the treatment site,
and would rapidly dissipate. The second degradate
would persist for longer and could be transported off the
treatment site.
Impacts of Rimsulfuron
Rimsulfuron breaks down rapidly in soil, with aerobic
metabolism the primary route of degradation. In aerobic
conditions, it has a soil half-life of 5 to 40 days, and in
anaerobic conditions, it has a soil half-life of 18 days
(NYSDEC 2009). Its mobility in soil ranges from
moderate in clay and silt loams to very mobile in sandy
loams.
One study of rimsulfuron found that it is poorly
mineralized, and that degradation products have the
potential to accumulate in soil. Rimsulfuron degrades
into a first metabolite, which then degrades rapidly into
a second metabolite. The second metabolite is not
readily degraded (Metzger et al. 1998). In one study of
an aerobic soil environment, there was no decline in this
chemical after 1 year. There is no indication that this
degradate exhibits toxicological properties (NYSDEC
2009).
One study of rimsulfuron found that there were no
adverse effects to the microflora of agricultural soils for
standard application rates of the herbicide (Radivojevic
et al. 2011). At much higher application rates, minor,
transitoiy adverse effects to soil microorganisms were
observed, indicating that short-term adverse effects to
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ENVIRONMENTAL CONSEQUENCES
soil could occur under accidental spill scenarios. Long¬
term effects to soil productivity and biological processes
are not known.
Rimsulfuron’s tendency to adsorb to soil varies by soil
type, and is greatest in soils with high organic matter or
clay content (Metzger et al. 1998). Therefore, there is
some potential for transport off-site on soil particles,
although clay and high-organic soils would likely have
a relatively low potential for wind erosion.
Impacts by Alternative
The BLM proposes use of herbicides to treat vegetation
to improve ecosystem function and health, including
soil health. However, herbicide treatments can also
affect soil fertility and function, and can kill or harm
soil organisms. The benefits and risks to soil under each
alternative are discussed in the following sections.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue its vegetation treatment programs, using only
the 18 currently approved herbicides. Herbicide
treatments would have both beneficial and adverse
effects on soil, as discussed in the previous sections.
Herbicides would continue to be used on approximately
932,000 acres annually.
Of the 1 8 active ingredients that would be used under
this alternative, those that are most persistent in soil
include diquat, diuron, hexazinone, imazapic, imazapyr,
picloram, and tebuthiuron (USDOI BLM 2007a:Table
4-7). Diquat has a half-life of 3 years or longer, but its
use would continue to be minimal (less than 1 percent
of all acres treated). Tebuthiuron has a half-life of
roughly 1 year. Its use would constitute approximately
13 percent of all acres treated under the No Action
Alternative. Other herbicides with half-lives of 90 days
or greater would make up approximately 30 percent of
all herbicide treatment acres.
Under this alternative, the herbicides with the most
extensive use on BLM lands would be imazapic (20
percent), triclopyr (15 percent), clopyralid (13 percent),
and tebuthiuron (13 percent; see Table 2-4). Impacts to
soil from these herbicides are discussed in the 2007
PEIS (USDOI BLM 2007a:4-16 to 4-21). None of these
herbicides have been found to have substantial impacts
on soil or soil organisms. Tebuthiuron is extremely
persistent in soil, and has been detected at application
sites more than 10 years after application (Gay et al.
1997 cited in USDOI BLM 2007a).
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under the Preferred Alternative, the total area receiving
herbicide treatments would remain the same (932,000
acres), but the suite of chemicals used at individual sites
would change with the introduction of aminopyralid,
fluroxypyr, and rimsulfuron into treatment programs.
Aminopyralid would be used on approximately 10
percent, and rimsulfuron on approximately 16 percent,
of all acres treated. Use of fluroxypyr would be minimal
(1 percent of all acres). Fluroxypyr and rimsulfuron
have relatively short half lives in soil (Table 4-3).
Aminopyralid also has a fairly short half-life, but there
is evidence that it may be quite persistent (with a half-
life of more than a year) under certain site conditions.
Additionally, plant materials and residues that have
been treated with aminopyralid may continue to release
aminopyralid to the soil until these materials have
decomposed. None of the new herbicides proposed for
use have been found to have substantial impacts on soil
or soil organisms.
With the addition of the three new herbicides, use of
some previously-approved herbicides is expected to
decrease, as shown in Table 2-4. Under the Preferred
Alternative, use of glyphosate, imazapic, and picloram
would decrease by an estimated 4 to 10 percent of the
total acres treated. Imazapic and picloram have fairly
long half-lives, relative to the new herbicides.
Therefore, the overall persistence of herbicides in soil
could be reduced under the Preferred Alternative.
Overall, potential adverse effects to soil and soil
organisms would be minor, although potentially less
than those under the No Action Alternative.
If availability of the new herbicides were to increase the
efficacy of the BLM’s vegetation treatment programs,
resulting in better control of noxious weeds and of
invasive species that increase fire frequency, there may
be a slightly greater benefit to soil resources than under
the No Action Alternative.
Alternative C - No Aerial Application of New
Herbicides
Under Alternative C, vegetation treatments would
utilize the same suite of chemicals as under Alternative
B, and the same maximum number of acres as under the
other alternatives, but a restriction on aerial application
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ENVIRONMENTAL CONSEQUENCES
of the new herbicides would result in slight differences
in the relative amounts of herbicides used. As shown in
Table 2-4, use of the new herbicides would be less than
under the Preferred Alternative, and the associated
reductions in use of glyphosate, imazapic, and picloram
would also be less. Therefore, overall persistence of
herbicides in soil would fall somewhere between the No
Action Alternative and the Preferred Alternative.
Impacts to soil would be minor, similar to the other
alternatives.
Benefits to soil resources could be slightly greater than
under the No Action Alternative, and slightly less than
under the Preferred Alternative.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under this alternative, the BLM would not add
rimsulfuron to its list of approved active ingredients.
However, all currently approved ALS-inhibiting
herbicides would continue to be used. As a result, the
breakdown of herbicide usage would be very similar to
that under the No Action Alternative. Because
rimsulfuron would not be available to manage
cheatgrass and other winter annuals, the BLM would
continue to rely heavily on imazapic for these uses.
With the introduction of aminopyralid, use of
glyphosate would be reduced. Glyphosate and
aminopyralid have similar soil half-lives, and under
certain conditions aminopyralid may be more persistent
than glyphosate. Overall, impacts to soil resources
would be minor, and would be very similar to those
under the No Action Alternative. It is expected that
benefits to soil from control of noxious weeds and other
invasive vegetation also would be similar to those under
the No Action Alternative.
Mitigation for Herbicide Treatment
Impacts
No mitigation measures are proposed for soil resources.
Water Resources and Quality
Introduction
The proposed herbicide treatments have the potential to
affect water resources on or near public lands by
altering water flows, surface water and groundwater
quantity and quality, and rates of groundwater recharge.
Surface water provides an important source of drinking
water, provides habitat for fish and wildlife, and is used
for recreation. Groundwater has numerous uses,
including irrigation, drinking water (for humans and
livestock), domestic needs, aquaculture, and other uses
(USGS 2013). Approximately 44 percent of the U.S.
population depends on groundwater for its drinking
water supply (National Groundwater Association 2010).
Studies have shown some groundwater supplies to be
contaminated with herbicides and other contaminants
(e.g., total dissolved solids and metals). Generally,
shallow groundwater aquifers are at greater risk for
contamination than deeper sources. As discussed in the
2007 PEIS (2007a:3-15 to 3-18) and Chapter 3 of this
PEIS, water quality is poor to moderate over many areas
in the West, primarily in areas associated with
agricultural activities. Thus, actions that further
deteriorate water quality or watershed health need to be
carefully evaluated before being implemented on public
lands.
Scoping Comments and Other Issues
Evaluated in the Assessment
Scoping comments were concerned about the potential
for the new herbicides to adversely affect water quality.
Comments addressed herbicide drift, erosion of
contaminated soils into waterways, and contamination
of surface water, groundwater, and drinking water. One
comment noted that aminopyralid has been detected in
surface water in Montana. Another comment inquired
about how invasive infestations of aquatic plants would
be controlled (to prevent deterioration of water quality)
if buffers are required around water bodies for
treatments involving the new herbicides.
One comment mentioned the requirements of the Clean
Water Act, and requested that the BLM show that use of
the new herbicides would not result in degradation of
water quality of Section 303(d)-listed waters, and
indicate how other anti-degradation provisions of the
Clean Water Act would be met.
Other commenters showed support for the new
herbicides by noting that they are safe to use around
water and have a low risk of resulting in water
contamination.
Standard Operating Procedures
The BLM would continue to implement the SOPs
identified in the 2007 PEIS to reduce unintended
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ENVIRONMENTAL CONSEQUENCES
impacts to water quality and quantity from the
application of herbicides:
• Consider climate, soil type, slope, and
vegetation type when developing herbicide
treatment programs.
• Note depths to groundwater and identify areas
of shallow groundwater and areas of surface
water and groundwater interaction.
• Review hydrogeologic maps of proposed
treatment areas or conduct site reconnaissance
to identify areas of shallow groundwater.
• Select herbicide products to minimize impacts
to water. This is especially important for
application scenarios that involve risk from
active ingredients in a particular herbicide, as
predicted by risk assessments.
• Use local historical weather data to choose the
month of treatment. Based on the phenology of
the target species, schedule treatments based on
the condition of the water body and existing
water quality conditions.
• Plan to treat between weather fronts (calms)
and at the appropriate time of day to avoid high
winds that increase spray drift and water
movements, and to avoid potential stormwater
runoff and water turbidity.
• When possible, plan to treat shallow areas,
which are easier to control.
• Conduct mixing and loading operations in an
area where an accidental spill would not
contaminate an aquatic body.
• Do not rinse spray tanks in or near water
bodies.
• Do not broadcast pellets where there is danger
of contaminating water supplies.
• Minimize treating areas with high risk for
groundwater contamination.
• As needed, maintain buffers between treatment
areas and water bodies. Buffer widths should
be developed based on herbicide- and site-
specific criteria to minimize impacts to water
bodies.
• Minimize the potential effects to surface water
quality and quantity by stabilizing terrestrial
areas as quickly as possible following
treatment.
These SOPs are general to herbicide treatments, and
would apply to treatments with the three new active
ingredients, as applicable.
Additionally, the ROD for the 2007 PEIS has identified
two mitigation measures for herbicide treatments that
apply to the three new active ingredients:
• Establish appropriate (herbicide-specific)
buffer zones to downstream water bodies,
habitats, and species/populations of interest.
These buffer zones are based on information
provided in the risk assessments indicating the
minimum safe distance to protect aquatic
organisms.
• Areas with potential for groundwater for
domestic or municipal water use shall be
evaluated through the appropriate, validated
USEPA model(s) to estimate vulnerability to
potential groundwater contamination, and
appropriate mitigation measures shall be
developed if such an area requires the
application of herbicides and cannot otherwise
be treated with nonchemical methods.
As a result of a court ruling in 2011, the National
Pollution Discharge Elimination System (NPDES)
regulations no longer provide an exemption for
discharges of pesticides that leave a residue into Waters
of the U.S. Therefore, NPDES permits are now required
for application of pesticides in or near aquatic habitats
in states where BLM herbicide treatments would occur.
Necessary NPDES permits would be obtained at the
local level for proposed herbicide treatment projects, in
accordance with the requirements detailed on the
USEPA’s NPDES Pesticide Homepage
(http://water.epa.gov/polwaste/npdes/pesticides/index.cf
m).
Summary of Herbicide Impacts
Aminopyralid, fluroxypyr, and rimsulfuron would only
be used on terrestrial vegetation; none of these
herbicides are currently approved for aquatic uses.
Aminopyralid, however, may receive an aquatic
registration in the near future that would address
incidental overspray of this active ingredient during
treatment of vegetation within close proximity to
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ENVIRONMENTAL CONSEQUENCES
wetland and riparian vegetation. Aminopyralid would
not be used to manage aquatic vegetation as a result of
this registration, and would not be applied directly to the
water column like other aquatic herbicides.
Impacts to Water Quality
The primary means of off-site movement of terrestrial
herbicides to water are runoff, leaching, drift, and
misapplication/spills. If aminopyralid receives an
aquatic registration, it could also reach water through
incidental overspray (direct spray). Surface water could
be affected by any type of off-site herbicide movement,
while groundwater potentially would be affected only
by leaching. Site conditions and application technique
can also influence the effects of an herbicide on water
quality. Pollution results from herbicide concentrations
that are elevated enough to impair water quality and the
beneficial use of the impacted water (USDOl BLM
1991). The 2007 PEIS (USDOl BLM 2007a:4-26 to 4-
29) goes into detail about the general ways by which
herbicides can impact water quality by the four means
of off-site movement. This information is summarized
in the following paragraphs.
Runoff and Leaching. Three physical properties, in
combination with climate, geology, and topography,
determine the runoff and leaching potential of an
herbicide: 1) persistence (the time a chemical stays
active); 2) soil adsorption (the tendency of a chemical to
bind to soil particles); and 3) solubility (the tendency of
a chemical to dissolve in water; Bonneville Power
Administration 2000).
TABLE 4-4
Factors Associated with Herbicide Movement to Groundwater
Category
Properties Increasing Likelihood of Groundwater Detection
Herbicide properties
Greater mobility (lower adsorption)
Greater pesticide persistence (lower reactivity)
Agricultural management practices
Higher pesticide use
Increasing proximity to pesticide application areas
Reductions in depth or frequency of tillage
Well characteristics
Decreasing well depth
Dug or driven (versus drilled) wells
Poorer integrity of surficial or annular well seals
Hydrogeologic and edaphic factors
Unconsolidated aquifer materials (versus bedrock)
Decreasing depth of upper surface of aquifer
Decreasing thickness or absence of confining layers
Higher hydraulic conductivity
Higher soil permeability
Increased recharge (from precipitation or irrigation)
Younger groundwater age
Source: Barbash et al. 1999.
Table 4-4 lists the factors associated with herbicide
movement to groundwater, and Table 4-5 lists the
physical properties of the three active ingredients
proposed for use and the associated off-site movement
potential via leaching and runoff. Herbicides must be
relatively persistent to have the potential to leach or run
off. Herbicides that adsorb strongly to soil particles
(because of herbicide and/or soil properties) tend to run
off with soil movement. Soils high in organic content or
clay tend to be the most adsorptive, while sandy soils
low in organic content are typically the least adsorptive
(USDOl BLM 1991). Herbicides with low soil
adsorption tend to leach down through the soil, although
herbicides with low solubility in water may be more
likely to run off. Site characteristics that may affect the
likelihood of an herbicide reaching a water body via
runoff or leaching include amount of precipitation,
depth to groundwater, and soil type.
Drift. The airborne movement of herbicides beyond the
treatment area is one mode of potential surface water
contamination. The application technique, weather
conditions, and applicator error can all contribute to
drift. Broadcast treatments from an aircraft or a boom
are more likely to drift from the treatment area than spot
and localized treatments. The potential for drift is also
increased during warm temperatures and wind speeds
greater than 5 mph (Bonneville Power Administration
2000). Because of the potential for drift, buffers
between the treatment site and nearby water bodies may
be specified to protect aquatic species.
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ENVIRONMENTAL CONSEQUENCES
TABLE 4-5
Herbicide Physical Properties and Off-site Movement Potential
Herbicide
Physical Properties
Off-site Movement Potential
Persistence
Solubility (mg/1)
Adsorption
(Koc)
Groundwater
Leaching
Surface Water
Runoff
Aminopyralid
Moderate
2,480
1 to 24
High
High
Fluroxypyr
Low
7,300
50 to 136
Low
Low
Rimsulfuron
Low
7
19 to 74
Low
Low
Note: The information in this table applies to the active ingredient itself, not the degradation products.
Sources: USEPA 2005c, NYSDEC 2009, U.S. National Library of Medicine 201 1, 2012. _
Misapplications and Spills. Herbicides registered for
use in terrestrial habitats may affect surface water and
groundwater as a result of unintentional spills or
accidental direct spray of water. Most experts agree that
misapplications and spills are the leading cause of
impacts to non-target resources. Misapplications and
spills are caused by failure to follow label instructions
and restrictions, unforeseen conditions and accidents,
and by applicator carelessness. The impacts of a spill
depend on the persistence and mobility of the spill, as
well as how quickly the spill is cleaned up.
Other Factors. Additional factors that may influence
the potential for herbicides to affect water quality
include the following:
• Type of water body (small and still water
bodies versus large and fast-moving rivers);
• Amount of rainfall;
• Type of vegetation (thick vegetation versus
little to no vegetation); and
• Application technique (aerial/broadcast versus
spot treatments).
Herbicides can also affect water quality by contributing
to increased nutrient loading to surface water and
groundwater. Nutrient enrichment of aquatic systems
can lead to algal blooms and eutrophication (mineral
and organic nutrient loading and subsequent
proliferation of plant life), resulting in decreased
dissolved oxygen content.
Benefits to water quality from herbicide treatments are
associated with a reduced risk of fire and post-fire
sedimentation. Additionally, control of invasive species
in terrestrial and aquatic systems can provide long-term
benefits to water quality with the return of more stable
soils, attenuated nutrient cycling, and a return to normal
fire cycles.
Impacts to Water Quantity
Removal of vegetation through use of herbicides has the
potential to affect water quantity by altering the
magnitude of base flows and the frequency and
magnitude of peak flows. Such effects would be most
likely to occur as a result of large-scale removal of
vegetation as a result of broadcast spraying. For some
treatment areas, the removal of vegetation could
improve groundwater recharge by limiting the amount
of water lost through sublimation or plant
evapotranspiration. In this case, base flows, which are
dependent on the quantity of groundwater discharge,
would increase. These changes could be very minor or
short-lived if the vegetation did not evapotranspirate or
sublimate large proportions of precipitation, or if areas
were revegetated quickly (Satterlund and Adams 1992).
Under some circumstances, large-scale removal of
vegetation could result in the reduction of groundwater
discharge and base flow as a function of reduced
infiltration rates. Reduced infiltration rates result in
more surface runoff reaching streams and lakes
immediately after a rain event, thus increasing the
velocity, frequency, and magnitude of peak stream
flows. These changes in water quantity could alter the
physical characteristics of stream channels and affect
the speed of water movement. Changes would persist
until the site was revegetated.
Impacts by Herbicide
The 2007 PEIS discusses the impacts to water resources
for each of the 18 currently approved herbicides
(USDOl BLM 2007a:4-29 to 4-34). The impacts of the
three new herbicides are discussed in the following
sections.
Aminopyralid
Aminopyralid is moderately persistent and has high
mobility in most soils because of its low soil adsorption
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ENVIRONMENTAL CONSEQUENCES
values (Table 4-5; USEPA 2005c). Therefore, it is
transported to surface water and groundwater.
Breakdown by microbes in soil is the primary form of
dissipation. Aminopyralid’s mobility and high water
solubility suggest that the herbicide is prone to leaching
(Lindenmeyer 2012). However, in past studies, leaching
of aminopyralid has not been documented at levels
below 1 foot (USEPA 2005b).
In water, aminopyralid is stable and does not readily
react with water, but is broken down by sunlight. The
half-life by photolysis is very short, at 0.6 days (USEPA
2005b). Therefore, it is expected that aminopyralid
rapidly dissipates in clear, shallow surface water
(USEPA 2005c). Within fast-moving water it rapidly
dissipates through mixing. The major metabolic
products of photolysis in water are oxamic acid and
malonamic acid, neither of which would form in large
concentrations, or are of concern from a toxicity
standpoint (USEPA 2005b).
Once aminopyralid leaches down to anaerobic soil
depths, degradation is likely to slow, which could be a
factor in groundwater contamination (USEPA 2005c).
At one study in Montana, aminopyralid was detected in
groundwater in one of 23 wells (Schmidt and Mulder
2009), indicating that there is some risk of groundwater
contamination. It is expected that concentrations of
aminopyralid in groundwater would be greatest in areas
with a high water table and when rainfall happens
immediately after application (USEPA 2005c).
Neither aminopyralid nor its major metabolic products
are included on the USEPA’s list of drinking water
contaminants (USEPA 2013b).
Because of its moderate persistence, high mobility, and
low soil adsorption, aminopyralid has a high potential
for surface water runoff. A Forest Service risk
assessment for this active ingredient detennined that in
areas with high annual rainfall virtually all of the
aminopyralid applied to a site could be transported
offsite in surface runoff (Syracuse Environmental
Research Associates, Inc. 2007).
Fluroxypyr
Based on soil adsorption characteristics, fluroxypyr is
expected to have a high mobility in soil. However, it has
a low potential for movement to groundwater because it
is rapidly broken down by microbes in the soil (soil
half-life is 1 to 3 weeks; California Department of
Pesticide Regulation 2005; U.S. National Library of
Medicine 2011). In field studies submitted to the
USEPA, fluroxypyr was generally not found below a
soil depth of 6 inches (USEPA 1998a), although this
may vary depending on soil type and amount of rainfall.
In sandy soils, the potential to leach to groundwater is
much higher, and has been identified as a concern
(NYSDEC 2006). Factors that influence the rate of
fluroxypyr degradation in soils include soil microbes,
organic matter, temperature, and soil moisture (Tao and
Yang 201 1).
In water, fluroxypyr does not readily break down by
photolysis, but is biodegraded by microorganisms in the
water and undergoes hydrolysis under certain
conditions. The aquatic half-life is fairly short, at 5 to 14
days (U.S. National Library of Medicine 2011).
The two major biotransformation products of fluroxypyr
(a pyridine and a methoxypyridine), may be more
persistent in water than fluroxypyr (Health Canada
2012). Studies of fluroxypyr in Sweden detected both
fluroxypyr and pyridine in the groundwater beneath a
railway treatment site (Cederlund et al. 2012).
Neither fluroxypyr nor its two major biotransformation
products are included on the USEPA’s list of drinking
water contaminants (USEPA 2013b).
Because of its quick rate of breakdown, fluroxypyr is
expected to have a low risk of surface water runoff. A
Forest Service risk assessment for this active ingredient
determined that up to 10 percent of applied herbicide
would leave a site in surface water runoff in areas with
clay soils and high rates of rainfall. For most other soils,
about half this amount was expected to run off, with
virtually no runoff from predominantly sandy soils
(Syracuse Environmental Research Associates, Inc.
2009).
Rimsulfuron
As discussed in the soil resources section, rimsulfuron is
unstable in soil, and therefore likely has a low risk of
leaching to groundwater. The pH of the site conditions
are likely a factor, with rimsulfuron less mobile in
acidic conditions. Its metabolites may have a greater
likelihood of contaminating groundwater, particularly
the second metabolite, which is not readily degraded
(Metzger et al. 1998).
There is little available information about rimsulfuron
and its metabolites in terms of groundwater and
surface water contamination. One study in sandy soils
found no rimsulfuron in groundwater following an
herbicide application, but did find the first metabolite
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ENVIRONMENTAL CONSEQUENCES
in the soil water at a depth of 3.3 feet, for as long as 3
years, in concentrations unsafe for drinking water.
Concentrations of the second metabolite were much
lower (Rosenbom et al. 2010).
In aquatic systems, rimsulfuron is broken down via
biodegradation and photodegradation. The
biodegradation half-life is estimated at 10 days under
aerobic conditions (NYSDEC 2009).
Neither rimsulfuron nor its two metabolites are included
on the USEPA’s list of drinking water contaminants
(USEPA 2013b).
Given its fairly rapid dissipation rate in the soil,
rimsulfuron has a low risk of surface runoff. If a rain
event were to occur a week after application of
rimsulfuron, only a very small portion of the active
ingredient would be available for movement (NYSDEC
1997).
Impacts by Alternative
Under all alternatives, one goal of herbicide treatments
would be to reduce noxious weeds and other invasive
species to improve watershed condition and protect
watersheds from wildfire. The BLM would also strive
to increase the number/acreage/miles of properly
functioning wetland/riparian areas to benefit water
quality. Work to restore degraded habitat and native
plant communities would be expected to benefit water
resources under all alternatives.
By minimizing fire risk through management of
cheatgrass and other winter annual grasses, the risk of
post-fire sedimentation into aquatic habitats would also
be minimized. When soils are carried into lakes and
streams, water quality diminishes as a function of
increased sedimentation and turbidity (USDOI BLM
2000). Additionally, some invasive vegetation, such as
pinyon and juniper, reduces water availability for native
species (USDOI BLM 1999). Furthermore, annual
grasses reduce the overall vegetative cover in a
watershed, relative to native grasses, which leads to
reduced infiltration, increased runoff, and loss of soil
moisture. Eventually, soils are transported to streams
and other aquatic bodies, increasing sedimentation and
reducing water quality. The benefits associated with
herbicide treatments that reduce the cover of non-native
invasive species would occur under all alternatives.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue its vegetation management programs using the
current list of 18 herbicides. The use of individual
herbicides may vaiy somewhat from historic usage
based on identified future projects, as summarized in
Table 2-4. The estimated total land area treated with
herbicides would remain at 932,000 acres annually. The
impacts under this alternative were summarized in the
2007 PEIS (USDOI BLM 2007a:4-35). In general,
herbicide treatments would provide benefits to water
resources by managing invasive species that damage
watersheds.
Approved aquatic herbicides would continue to be
applied directly to water to control aquatic species. The
2007 PEIS identified concerns associated with use of
the known groundwater contaminants 2,4-D, bromacil,
dicamba, diquat, diuron, hexazinone, and picloram.
Other herbicides were identified as having the potential
to leach to groundwater or be carried to surface water in
stormwater runoff.
Under this alternative, use of clopyralid, glyphosate,
imazapic, tebuthiuron, and triclopyr would comprise
herbicide treatments on approximately 73 percent of all
acres treated. Based on information in the 2007 PEIS,
glyphosate is a known groundwater contaminant,
persists in aquatic environments, and may stimulate
algal growth in low concentrations. There are fewer
concerns about the other herbicides in this list, although
imazapic is believed to be a groundwater contaminant,
and tebuthiuron has been detected in surface water.
Concerns associated with use of these herbicides would
continue under this alternative. The impact summary for
this alternative in the 2007 PEIS was that there would
be some risks to water resources from herbicide
treatments, as well as benefits associated with
watershed improvements.
Alternative B -Allow For Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, the extent of herbicide treatments
would be the same as under the No Action Alternative,
with associated risks to water resources over roughly
the same geographic area. However, the suite of
herbicides used would be slightly different.
Aminopyralid, fluroxypyr, and rimsulfuron would be
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added to the list of herbicides used to treat vegetation.
Therefore, the number of chemicals with the potential to
impact water resources would increase under this
alternative. None of the new herbicides are groundwater
or drinking water contaminants of concern, although the
potential for such contamination by these herbicides and
their degradation products exists.
Use of some previously-approved herbicides would
decrease under this alternatives, primarily that of
glyphosate, imazapic, and picloram. The use of the
known groundwater and drinking water contaminants,
glyphosate and picloram, would decrease by 7 percent
and 4 percent, respectively, meaning that roughly 1 1
percent fewer acres would be treated with these
herbicides than under the No Action Alternative. Use of
imazapic, a possible groundwater contaminant, would
decrease by 10 percent. Use of all other currently
approved herbicides would be the same as or within 3
percent of the current level of usage.
Under this alternative, use of fluroxypyr would be low
(approximately 1 percent of all acres treated), but use of
aminopyralid and rimsulfuron would account for 26
percent of all acres treated. As discussed in the Impacts
by Herbicide section, there may be some risk of
groundwater contamination associated with
aminopyralid and the degradation products of
rimsulfuron. Based on the available information, these
risks are likely lower than those associated with
glyphosate and picloram, indicating that effects to water
resources may be reduced under this alternative, relative
to the No Action Alternative.
None of the new herbicides would be used to manage
aquatic vegetation. Therefore, the level of benefit to
water resources from control of unwanted aquatic
vegetation, such as Eurasian watermilfoil, would be the
same as under the other alternatives. If availability of
the new herbicides were to increase the efficacy of the
BLM’s vegetation treatment programs, resulting in an
improvement in watershed condition, water resources
could receive a higher degree of benefit from treatment
programs than under the No Action Alternative.
Alternative C - No Aerial Application of New
Herbicides
Under this alternative, total maximum herbicide use
would be the same as under the other alternatives
(932,000 acres), but aerial applications of aminopyralid,
fluroxypyr, and rimsulfuron would not be allowed. The
number of chemicals with the potential to impact water
resources would be the same as under the Preferred
Alternative. However, use of glyphosate, picloram, and
imazapic would decrease by approximately 9 percent,
which is less of a decrease than under the Preferred
Alternative. Aminopyralid and fluroxypyr would only
be used on an estimated 9 percent of treatment acres.
Therefore, reduction in risks to water resources through
a reduction in use of known contaminants would be less
under this alternative than under the Preferred
Alternative.
Watershed-level benefits to water resources could be
slightly greater than under the No Action Alternative,
and slightly less than under the Preferred Alternative.
Not being able to apply the new herbicides aerially
would limit their usefulness in certain situations,
although these needs would continue to be met through
aerial applications of currently approved herbicides.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under Alternative D, total herbicide use would be the
same as under the other alternatives. However, without
the option of rimsulfuron, the percent of land area
treated with the new herbicides would be the lowest of
all the action alternatives, at approximately 1 1 percent
(10 percent for aminopyralid and 1 percent for
fluroxypyr). This alternative is the closest to the No
Action Alternative in terms of how much of each of the
currently available herbicides would be used. Most of
the currently available herbicides would be used at
levels similar to those under the No Action Alternative,
with the biggest reductions in use of picloram (4 percent
reduction) and metsulfuron methyl (3 percent
reduction). There could be some reduced risks to water
quality as a result of a decrease in the use of picloram,
but glyphosate would continue to be used at nearly the
same level as under the No Action Alternative.
The number of chemicals with the potential to impact
water resources would be greater than under the No
Action Alternative, but less than under the Preferred
Alternative and Alternative C.
Watershed-level benefits would be similar to those
under the No Action Alternative.
Mitigation for Herbicide Treatment
Impacts
No new mitigation measures, or measures specific to the
three new herbicides, are proposed for water resources.
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The BLM’s SOPs to protect water resources would
continue to be implemented: These include procedures
designed to prevent accidental spills of herbicides into
aquatic habitats.
Wetland and Riparian Areas
Introduction
Herbicide treatments have the potential to alter
vegetation, hydrology, or soils in wetland and riparian
areas, affecting the functions of these areas. However,
herbicide treatments that control non-native species in
wetland and riparian habitats would be beneficial.
Invasive plant species are one cause of degradation in
the function of wetland and riparian areas.
Scoping Comments and Other Issues
Evaluated in the Assessment
Scoping comments pertinent to wetland and riparian
areas included those addressing soil resources, water
resources and quality, and vegetation (see the Soil
Resources, Water Resources and Quality, and
Vegetation sections).
A few comments were specific to wetlands and riparian
areas, including one that noted the importance of using
aminopyralid in riparian areas to control invasive plants,
and one concerned with residual effects of aminopyralid
in vegetation in wetland and riparian areas.
Factors that Influence the Fate,
Transport, and Persistence of
Herbicides in Wetland and Riparian
Areas
If applied directly to wetlands and riparian areas,
herbicides dissipate by transport through water or wind,
through chemical or biological degradation, or through
adsorption and immobilization in soils. Wetlands and
riparian areas adjacent to herbicide treatment sites can
help filter herbicides from runoff through physical,
chemical, and biological processes (Mitch and
Gosselink 2000). Factors that influence herbicide fate in
wetlands include the amount and type of vegetation, the
amount of organic matter in the soil, oxygen
availability, and populations of soil microbes (Stoeckel
etal. 1997).
Saturated wetland soils have chemical and biological
characteristics that are different from well-drained
upland soils, including oxidation-reduction status, pH,
and organic content. The characteristics of wetland soils
affect their capacity to adsorb, transport, and transform
herbicides. The fate of herbicides in wetland soils is
dependent on the duration of saturation, soil
temperature, the kind and amount of organic matter, and
the nature and content of reactive chemicals present in
the soil.
The rate of breakdown in anaerobic systems can be
estimated by the measured anaerobic half-life (Table
4-6). With the exception of fluroxypyr, anaerobic
degradation processes are typically slower than the
degradation processes in well-drained soils where
oxygen is present. However, the soil type and other
environmental conditions are also important factors.
TABLE 4-6
Anaerobic Half-life in Soil for Herbicides
Analyzed in this PEIS
Herbicide
Anaerobic Soil
Half-life (days)
Aerobic Soil
Half-life (days)
Aminopyralid
462-990
32-533
Fluroxypyr
3.5-14
7-23
Rimsulfuron
18
5 to 40
Sources: USEPA 2005c, NYSDEC 2009, U.S. National
Library of Medicine 2011.
Methodology for Assessing Impacts to
Wetland and Riparian Areas
The BLM reviewed the literature and findings from
ERAs to assess the impacts to aquatic plant species
from the use of herbicides (AECOM 2014a,b; AECOM
2015). The ERA methods and results for aquatic and
terrestrial vegetation are summarized in the Vegetation
section of this chapter. Methods used by the BLM are
presented in detail in the Vegetation Treatments
Programmatic EIS Ecological Risk Assessment
Protocol (ENSR 2004).
The analysis of impacts to wetland and riparian areas
assumes that the BLM would follow applicable SOPs
identified in the 2007 PEIS:
• Survey for special status aquatic and riparian
plant species before treating an area, at a time
when the plants can be identified.
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• Use drift reduction agents to reduce the risk of
drift hazard.
• Use a selective herbicide and a wick or
backpack sprayer.
• Use an appropriate herbicide-free buffer zone
for herbicides not labeled for aquatic use. This
information is discussed in the ERA guidance
provided in the Vegetation section of this
chapter. Minimum buffer widths for herbicides
not labeled for aquatic use are 100 feet for
aerial, 25 feet for vehicle, and 10 feet for hand
applications (larger buffers may be required if
special status species are present).
Other SOPs would help minimize the risk of a spill into
wetland habitats, including preparing a spill
contingency plan in advance of treatments, mixing and
loading herbicide products in an area where an
accidental spill would not reach a water body, not
rinsing spray tanks in or near water bodies, following
product labels for use and storage, and having licensed
applicators apply the herbicides.
Summary of Herbicide Impacts
None of the three active ingredients proposed for use
are currently approved for direct aquatic applications.
Therefore, the BLM’s minimum buffers would apply,
unless ERAs indicate larger buffers are warranted, or
project-specific NEPA analysis indicates that a smaller
buffer is appropriate. Aminopyralid, fluroxypyr, and
rimsulfuron can be applied in dry riparian areas, non¬
irrigation ditch banks, seasonally dry wetlands, and
transitional areas between upland and lowland sites.
Additionally, if aminopyralid receives an aquatic
registration in the future, the buffers associated with its
use near aquatic habitats could be reduced.
Based on the likely usage of the three active ingredients,
wide-scale removal of riparian vegetation would not
occur. Fluroxypyr and rimsulfuron would not typically
be used near water, except possibly for spot treatments
of certain target species. However, aminopyralid would
be used in riparian treatments for selective removal of
certain species (e.g., knapweeds), although extensive
removal of riparian vegetation would be unlikely. If
aminopyralid receives an aquatic registration in the
future, reduced buffers near aquatic habitats would
allow its use in targeting a variety of wetland and
riparian species, such as purple loosestrife, Japanese
knotweed, and saltcedar. In riparian areas and wetlands.
aminopyralid would potentially provide an alternative to
glyphosate, which is less selective and more likely to
result in removal of non-target riparian and wetland
vegetation.
A general discussion of impacts to wetlands and
riparian areas from use of herbicides to control aquatic
and riparian vegetation is provided in the 2007 PEIS
(USDOl BLM 2007a:4-37 to 4-38). Herbicide
treatments can improve habitat quality for fish and
wildlife, improve hydrologic function, and reduce soil
erosion. Herbicide treatments would focus on non¬
native species that displace native vegetation and that
alter wildlife habitat, hydrology and soil conditions.
Many of the species targeted for control (such as purple
loosestrife, reed canary grass, and saltcedar) form dense
monocultures that shade out native species and reduce
wetland functions. Management of these species would
be expected to increase the functions and values of
treated wetlands and riparian areas.
While loss of vegetation could lead to short-term
impacts such as increased sedimentation and nutrient
loading, and alteration of vegetation, water temperature,
and hydrologic conditions, it is expected that these
short-term impacts would be minimal given that
extensive removal of riparian vegetation would be
unlikely.
A general discussion of the impacts to wetlands and
riparian areas from the use of herbicides in upland areas
is provided in the 2007 PEIS (USDOl 2007a:4-40).
Non-target wetland and riparian areas could be exposed
to herbicides transported from upland areas via a variety
of methods. The primary potential impacts would be
loss of non-target native vegetation and contamination
of water or soil, particularly as a result of an accidental
spill.
Aminopyralid
As discussed previously, aminopyralid could be used in
dry wetlands and riparian areas. Therefore, any
herbicide that remains adsorbed to soil particles could
be released into the water if these areas become flooded
or saturated following the treatments. Additionally, if
aminopyralid receives an aquatic registration, it could
be used in saturated conditions, and could enter the
water directly as a result of incidental overspray.
Aminopyralid does not have activity on submerged
aquatic species, such as watermilfoil and water-thyme,
and would not be applied directly to the water column
to treat unwanted aquatic vegetation. However, it may
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ENVIRONMENTAL CONSEQUENCES
be effective at controlling riparian invasives. Field
research trials support use of aminopyralid to manage
emerged shoreline invasive species (e.g., purple
loosestrife, Japanese knotweed, and invasive thistle
species; Peterson et al. 2013).
Aminopyralid is effective against many invasive
herbaceous broadleaf weeds, and may offer
improvements in control of Russian olive and saltcedar.
One study found that adding aminopyralid to triclopyr
increased its control of these species without injuring
desirable understory grass vegetation (Sluegh et al.
2011).
Aminopyralid has a photodegradation half-life of 0.6
days in aquatic systems (USEPA 2005c). In anaerobic
systems, however, the active ingredient is persistent,
with a half-life between 462 and 990 days (USEPA
2005c). The half-life in sediment is 999 days (Yoder
and Smith 2002).
As described in the ERA for aminopyralid, non-target
aquatic plants are not at risk for adverse effects from
exposure to aminopyralid, even under direct spray and
worst-case spill scenarios. However, non-aquatic plants
(including riparian species and emergent wetland
plants) would be at risk for adverse effects if a broadcast
spray treatment were to occur near wetland and riparian
habitats. Use of adequate buffers would be required to
prevent adverse effects to sensitive riparian and wetland
habitats under broadcast spray scenarios. These buffers
are discussed in more detail in the Vegetation section
(see Table 4-8).
Fluroxypyr
As discussed previously, fluroxypyr would have
minimal use in wetland and riparian habitats, except for
spot treatments of certain target species. It is not
approved for use in aquatic habitats or wetlands when
water is present. Therefore the amount of this active
ingredient that is likely to be released to wetland and
riparian areas under normal application scenarios is very
small. Accidental spills or movement from adjacent
upland areas could result in more of the active
ingredient entering wetland or riparian habitats.
Fluroxypyr is short-lived in anaerobic environments. In
anaerobic soil the half-life is 14 days or less (National
Library of Medicine 2011). In anaerobic aquatic
habitats, the half-life is 8 days (USEPA 1998a). The
breakdown products may persist for longer.
As described in the ERA for fluroxypyr, non-target
aquatic plants are not at risk for adverse effects from
fluroxypyr under direct spray or surface runoff
scenarios. However, they would likely be harmed by an
accidental spill of fluroxypyr into a pond or stream in
which they occur. The risks of such a spill occurring
would be reduced by applicable SOPs, as discussed
earlier in this Wetland and Riparian Areas section. Non-
aquatic plant species in wetlands and riparian areas
would be at risk for adverse effects from spray drift at
nearby upland habitats. Suitable buffers would be
required to prevent adverse effects to non-target plants
in sensitive riparian and wetland habitats. See Table 4-8
and the Vegetation section for more information on
buffers.
Algal growth may be stimulated at low fluroxypyr
concentrations but depressed at higher concentrations
(Zhang et al. 201 1).
Rimsulfuron
As discussed previously, rimsulfuron is not likely to be
used much in or near wetland and riparian areas, except
for spot treatments of certain target species. Similar to
fluroxypyr, only small amounts of this chemical are
likely to enter wetland and riparian areas under normal
application scenarios, although larger amounts could
enter these habitats as a result of an accidental spill or
movement from an adjacent treatment site.
Rimsulfuron has a high rate of soil adsorption in soils
with high organic content (Metzger et al. 1998).
However, it is quickly degraded under anaerobic
conditions. In anaerobic soil the half-life is
approximately 18 days. In anaerobic aquatic habitats,
the half-life is less than 2 days (NYSDEC 2009).
Breakdown products may persist for longer.
According to the ERA, rimsulfuron poses a risk to non¬
target aquatic plants under direct spray, accidental spill,
spray drift, and certain surface runoff scenarios. Risks
associated with surface runoff would be limited to
aquatic plants in ponds, and would be greatest in areas
with 50 inches of precipitation or more per year. Non-
aquatic plants, such as riparian and emergent wetland
species would also be at risk for adverse effects from
treatments in nearby upland areas. These findings
indicate that buffers are needed between treatment sites
and wetlands/riparian areas to protect vegetation from
unintended harm. These buffers are discussed in more
detail in the Vegetation section and Table 4-8.
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Impacts by Alternative
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue its ongoing vegetation management programs
in 17 western states, and would be able to use the
current list of 18 approved herbicides for treatments.
Impacts under this alternative would correspond to
those discussed under the Preferred Alternative in the
2007 PEIS (USDOI BLM 2007a:4-42). The total area
receiving herbicide treatments would be 932,000 acres
annually, of which approximately 10,000 acres would
consist of aquatic and riparian habitat. Herbicides used
to manage aquatic and riparian vegetation under this
alternative could include 2,4-D, diquat, fluridone,
glyphosate, and imazapyr, which are registered for
aquatic uses; and dicamba, tebuthiuron, and triclopyr in
riparian areas where contact with water can be avoided.
Use of the currently approved herbicides would be
associated with both beneficial and adverse effects to
wetlands and riparian areas. There would be some risk
for contamination of water and/or soils in these habitats
as a result of herbicide applications or spills, as well as
risks to non-target plant species from exposure to
herbicides via various pathways.
Herbicide treatments that target invasive riparian and
wetland plant species would be expected to benefit
these habitats by promoting the reestablishment of
native species and improving the functions provided by
the targeted wetlands and riparian areas. The BLM
would be able to control targeted invasive species (such
as Eurasian water milfoil, water-thyme, purple
loosestrife, and saltcedar) with the suite of herbicides
available for use.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, the estimated area of wetland and
riparian areas receiving herbicide treatments annually
would be the same as under the No Action Alternative
and the other action alternatives. However,
aminopyralid, fluroxypyr, and rimsulfuron would be
added to the list of herbicides available for use. Because
none of the new active ingredients would be registered
for direct applications to the water column, they would
not be used to control invasive aquatic species. 2,4-D,
diquat, fluridone, glyphosate, and imazapyr would
continue to be used for these aquatic applications.
While fluroxypyr and rimsulfuron would receive minor
use in wetland and riparian habitats, aminopyralid
would be an important component of riparian and
wetland treatments, particularly if it receives an aquatic
registration allowing incidental overspray into wetlands
and aquatic habitats. The BLM has identified
aminopyralid as a good alternative to glyphosate that is
more selective and therefore less likely to harm target
vegetation, and may be less of a concern in terms of
persistence in groundwater and aquatic habitats (see the
Water Resources and Quality section). However,
aminopyralid persists much longer than glyphosate in
anaerobic, wetland soils (462 to 990 days, versus 12 to
70 days for glyphosate). Therefore, use of aminopyralid
in and near wetland habitats may have a greater impact
than glyphosate from an environmental persistence
standpoint. Under this alternative, it is expected that use
of glyphosate would be reduced, relative to the No
Action Alternative. It is likely that the BLM would use
aminopyralid to target knapweeds in riparian areas, as
well as for other broadleaf invasive species.
The addition of fluroxypyr and rimsulfuron may also
reduce the usage of some other herbicides in wetland
and riparian areas, but not to a substantial degree.
Alternative C - No Aerial Application of New
Herbicides
Alternative C is similar to the Preferred Alternative in
that the same herbicides would be available for use, and
the total area of wetland and riparian areas treated
would be approximately 10,000 acres. As discussed in
the 2007 PEIS (USDOI BLM 2007a:4-43), nearly all of
the herbicide treatments in wetland and riparian areas
are done using ground-based methods. Additionally,
aerial applications of upland areas would be completed
using the currently approved herbicides, so risks to
wetlands and riparian areas from spray drift would be
much the same as under the other alternatives, although
different herbicides may be used than under
Alternatives B and D.
Benefits and risks to wetland and riparian areas would
be much the same as under the Preferred Alternative.
For ground-based treatments in wetlands and riparian
areas, aminopyralid would likely be used instead of
glyphosate in certain situations.
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ENVIRONMENTAL CONSEQUENCES
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Effects to wetlands and riparian areas under Alternative
D would be much the same as those under the Preferred
Alternative. Rimsulfuron would not be available for use
under Alternative D. However, since rimsulfuron would
receive minimal use near wetlands and in riparian areas,
there would be little difference in herbicide usage in
these areas relative to the other alternatives.
Aminopyralid would be used instead of glyphosate for
certain treatments in and near wetlands and riparian
areas, similar to the other action alternatives. Benefits
and risks to wetland and riparian areas would also be
much the same as under the other action alternatives.
Mitigation for Herbicide Treatment
Impacts
No mitigation measures have been developed that are
specific to wetlands and riparian areas. The BLM’s
SOPs to protect water resources and vegetation would
also help protect riparian and wetland habitats.
Additionally, mitigation measures for vegetation,
specified in the next section, would help protect riparian
and wetland habitats. These include utilizing adequate
buffer zones between sensitive non-target vegetation
and herbicide treatment areas, which in many cases
would be applicable to riparian and wetland vegetation.
Vegetation
Introduction
The present-day composition and distribution of native
plant communities in the western U.S. are influenced by
many factors, including physical factors (e.g., climate,
drought, wind, geology, topography, elevation, latitude,
slope, and exposure), natural disturbance (e.g., insects,
disease, fire, and wildlife browsing), and human-
management patterns (e.g., domestic livestock grazing).
Non-native plant species have caused a decline in the
extent of some native plant communities in each of the
western states. The rapid expansion of invasive plant
species across public lands continues to be a primary
cause of ecosystem degradation, and control of these
species is one of the greatest challenges in ecosystem
management. The recent increase in wildfires has been
influenced by changes in vegetation on public lands
over the past 100 years, which have resulted in
increases in hazardous fuels. Cheatgrass, which is
widespread on public lands, bums more frequently than
native vegetation types and is disproportionately
represented in the largest fires, indicating that invasion
of this species has substantially altered fire regimes
(Balch et al. 2013).
Scoping Comments and Other Issues
Evaluated in the Assessment
Numerous scoping comments received by the BLM
pertain to vegetation, addressing both the beneficial
effects associated with use of the three new herbicides
to control weeds, and the potential adverse effects to
non-target vegetation. Most comments discuss the
efficacy and low impact of the herbicides proposed for
use, and their low impact to native plant species relative
to other herbicides that are currently being used by the
BLM. Specifically, numerous comments identified the
efficacy of rimsulfuron at controlling cheatgrass and
medusahead rye, the efficacy of aminopyralid as a
control of knapweed, thistles, and rush skeletonweed,
and the efficacy of fluroxypyr on kochia.
Several comments were concerned about the effects to
non-target vegetation from residual aminopyralid or
fluroxypyr in manure and compost and other plant
materials. One comment addressed the importance of
reseeding of desirable species after treatments to
promote recovery of native plant communities
following herbicide treatments.
Standard Operating Procedures
Risks to non-target plants associated with herbicide use
would continue to be minimized by following the SOPs
listed in the 2007 PEIS, which are general procedures
designed by the BLM to reduce potential unintended
impacts to non-target vegetation from herbicide
treatments. Examples of pertinent SOPs (with slight
modifications since 2007) include the following:
• Conduct pre-treatment surveys for sensitive
habitat and special status species within or
adjacent to proposed treatment areas, at a time
when the plants can be found.
• Consider site characteristics, environmental
conditions, and application equipment in order
to minimize damage to non-target vegetation.
• Use drift reduction agents, as appropriate, to
reduce the drift hazard to non-target species,
and colorants to obtain a uniform coverage.
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• Turn off aerially applied treatments at the
completion of spray runs and during turns to
start another spray run.
• Refer to the herbicide label when planning
revegetation to ensure that subsequent
vegetation will not be injured following
application of the herbicide.
Additionally, the BLM would follow the mitigation
measures that were adopted in the 2007 ROD (USDOI
BLM 2007b: Table 2) for vegetation treatments
involving the 18 currently approved herbicides. These
mitigation measures include establishing herbicide-
specific buffer zones, limiting aerial applications of
certain active ingredients, and minimizing the use of
terrestrial herbicides in watersheds with downgradient
ponds and streams if potential impacts to aquatic plants
are identified. Some of these measures would apply to
treatments involving the three new active ingredients,
including tank mixes that include the currently approved
herbicides for which specific mitigation measures have
been developed.
These procedures would minimize impacts to plants and
ecosystems on public lands from use of the new active
ingredients to the extent practical. Long-tenn benefits to
native plant communities from management of invasive
plants would likely continue to outweigh any short-term
negative impacts to native plants associated with
herbicide use.
Impacts Assessment Methodology
The method of assessing impacts to non-target
vegetation from the three new herbicides was the same
as the method described in the 2007 PEIS (USDOI
BLM 2007a:4-45 to 4-46; Appendix C) for herbicides
with BLM ERAs. A brief overview of the ERA process
is presented here. Additionally, information about likely
future herbicide treatments, provided by local field
offices for development of the 2007 PEIS, was assumed
to be applicable to the alternatives in this PEIS. This
information includes the location, application method,
vegetation type, and size of the treatment (in acres).
Risk Assessment Methodology
Risk assessments evaluated the risks to terrestrial and
aquatic non-target plants from herbicide exposure. Risk
assessments consider assessment endpoints and
associated measures of effect. The assessment endpoint
is an expression of the value that is to be protected. In
the case of non-target plants, assessment endpoints
include mortality and negative impacts on growth,
reproduction, or other ecologically important sublethal
processes. For the most part, assessment endpoints
reflect direct effects of the herbicide, although indirect
effects were also considered.
Measures of effect are measurable changes in an
attribute of an assessment endpoint (or its surrogate) in
response to a stressor to which it is exposed (USEPA
1998b). For the ERAs, these measures generally
consisted of acute and chronic toxicity data (from
pesticide registration documents and from the available
scientific literature) for the most appropriate surrogate
species.
Because the BLM applies herbicides in a variety of sites
using a variety of application methods (e.g., via aircraft,
vehicle, and backpack), the following exposure
scenarios were considered to assess the potential
ecological impacts of herbicides under a variety of uses
and conditions:
• Direct spray of the receptor.
• Off-site drift of spray to terrestrial areas and
water bodies.
• Surface runoff from the application area to off¬
site soils or water bodies.
• Wind erosion resulting in deposition of
contaminated dust.
• Accidental spills to water bodies.
The AgDRIFT computer model was used to estimate
off-site herbicide transport due to spray drift. The
Groundwater Loading Effects of Agricultural
Management Systems (GLEAMS) computer model was
used to estimate off-site transport of herbicide in surface
runoff and root zone groundwater transport. The
AERMOD and CALPUFF computer models were used
to predict the transport and deposition of herbicides
adsorbed (i.e., reversibly or temporarily attached) to
wind-blown dust. Each model simulation was
conservatively approached with the intent of predicting
the maximum potential herbicide concentration that
could result from the given exposure scenario.
In order to address potential risks to plant receptors.
Risk Quotients (RQs) were calculated. To help translate
RQs into estimates of risk, the calculated RQs were
compared with Levels of Concern (LOCs) used by the
USEPA in screening the potential risk of herbicides. For
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ENVIRONMENTAL CONSEQUENCES
plants, distinct USEPA LOCs are currently defined for
the following risk categories: '
• Acute high risk - the potential for acute risk is
high.
• Acute endangered species - threatened,
endangered, and proposed species may be
adversely affected.
For the analysis presented in this PEIS, the LOC for
acute high risk (1) was used for typical terrestrial and
aquatic plant species. Wherever the RQ exceeded the
LOCs, it was assumed that acute adverse effects to non¬
target plant species could potentially occur under that
exposure scenario. The methodology for determining
risks to special status plant species is discussed later in
this section, under the Special Status Plant Species
subheading.
Summary of Herbicide Impacts
Under all alternatives, treatments involving the new
herbicides would be one component of the BLM’s
larger vegetation management programs, which have
been discussed in more detail in the 2007 PEIS and
PER. As discussed in the 2007 PEIS (UDSI BLM
2007a:4-47), the effectiveness of herbicide treatments in
managing target plants and the extent of disturbance to
plant communities varies by the herbicide selectivity,
the extent and density of the infestation, the size of the
application area, and the application method (e.g., aerial
vs. ground). Individual plant sensitivities, physical
features (e.g., soil type and slope), and weather
conditions (e.g., temperature, humidity, and wind speed)
at the time of application also factor into the success of
a treatment. Additionally, other treatments or herbicides
used in conjunction with treatments involving
aminopyralid, fluroxypyr, and rimsulfuron would
influence the effectiveness of the overall treatment.
Herbicide treatments would likely affect the plant
species composition of an area and might affect plant
species diversity. The discussions in this section focus
on the impacts of the three new herbicides on vegetation
(both target and non-target species). General discussions
about the impacts of herbicide treatments on vegetation
can be found in the 2007 PEIS (USDOI BLM 2007a:4-
47 to 4-48). For treatments involving one or more of the
three new herbicides, active ingredients that adversely
affect plants could come into contact with vegetation
via direct spraying, drift, runoff, wind transport, or
accidental spills. Potential impacts include mortality,
reduced productivity, and abnormal growth. These
exposure pathways and associated risks to non-target
plants were evaluated in risk assessments for the three
herbicides (AECOM 2014a,b; AECOM 2015).
Impacts of Aminopyralid
Target Plants
Aminopyralid is a post-emergence, selective herbicide
that is used to manage invasive annual, biennial, and
perennial species. It is a plant growth regulator that
binds to receptor sites normally used by the plant’s
natural growth hormones, causing death of the plant.
Anecdotal evidence and controlled studies of
aminopyralid have found it to be effective at controlling
yellow starthistle, Russian knapweed, various thistles,
rush skeletonweed, and other invasive plants of
rangelands (DiTomaso and Kyser 2006; Enloe et al.
2008; Bell et al. 2012). Other species controlled by
aminopyralid include oxeye daisy, Mediterranean sage,
and Japanese and other large knotweeds (DiTomaso et
al. 2013). The BLM has identified this herbicide for its
activity on difficult-to-control species in rangelands,
among other uses. It is an alternative to other growth
regulator herbicides that are commonly used on
broadleaf weeds, such as picloram, clopyralid, 2,4-D,
and dicamba. Studies have also found aminopyralid to
be as or more effective than the currently approved
growth regulator herbicides at lower application rates
(Enloe et al. 2007, 2008; Bell et al. 2012).
Aminopyralid has a higher specific activity than other
growth regulator herbicides, so less of it needs to be
used to achieve the same result (Iowa State University
2006). In mixtures with other active ingredients, it can
be used on hard-to-control species like poison hemlock
and catsears (DiTomaso et al. 2013).
There is some evidence that aminopyralid may be
effective against certain annual grasses when applied at
higher application rates pre- or early post-emergence
(DiTomaso 2012). At sites representative of annual
grasslands in California, it has been shown to control
medusahead rye and result in increased cover of more
desirable annual forage species, and may also have
utility in suppressing cheatgrass (DiTomaso 2012).
Additionally, aminopyralid may have a sterilizing effect
on annual grasses, and appears to reduce seed
production in cheatgrass (Rinella et al. 2013).
Non-Target Plants
Because aminopyralid is used to manage weedy
broadleaf species, it poses a risk to non-target native
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ENVIRONMENTAL CONSEQUENCES
forbs and other desirable species in treatment areas.
Generally speaking, it is a selective herbicide, falling
between picloram and clopyralid in terms of selectivity
(Iowa State University 2006). Studies with
aminopyralid indicate that some native species are more
tolerant to aminopyralid than others (Mikkelson and
Lym 2013), indicating that the native species
composition of treatment sites could be altered by the
use of aminopyralid. Based on its documented control
of invasive plants, key flowering plant families that are
affected by aminopyralid include the Asteraceae (aster),
Fabaceae (legume), and Polygonaceae (buckwheat)
families. Additionally, the timing of a treatment may
influence which native species will be most tolerant to
aminopyralid (Halstvedt et al. 2011). In general, this
herbicide is likely to select for perennial grass species
and more resistant forb species. However, there is also
evidence that use of aminopyralid causes an overall
increase in the relative cover and dominance of native
species (Green et al. 2011). Reduction in cover of non¬
native species and an increase in native species would
have a long-term beneficial effect at treatment sites.
One study documented adverse effects to forest
communities from use of aminopyralid. Aminopyralid
treatments in ponderosa pine stands (trees 5 to 10 years
old, at higher rates than those proposed by the BLM)
can result in injury to ponderosa pine trees, leading to
decreased canopy volume and variable growth patterns
(Wallace et al. 2012).
As stated on the herbicide label, aminopyralid may
impact non-target broadleaf plants indirectly if urine or
manure from animals that graze on treated pasture
within 3 days of the herbicide application comes into
contact with these plants (Iowa State University 2006).
Aminopyralid is persistent in plant materials, and may
remain in undigested remains of treated vegetation for
more than 2 years (Oregon State University 2009, Dow
AgroSciences 2014). This persistence in plant materials
is generally a concern for crops and other plantings that
are treated with compost that contains plant residues or
hay or straw from treated areas. However, it is possible
that some localized impacts to non-target native plants
could occur if livestock or wildlife graze in treated areas
and then release their waste materials on desirable
broadleaf native species.
The risk assessment for aminopyralid indicates that
aminopyralid poses a high risk to non-target plants
within the treatment area. As shown in Table 4-7, risks
for adverse effects to terrestrial plants would be high if
there was direct exposure to aminopyralid as a result of
a direct spray (as part of a treatment or accidental) or an
accidental spill. Therefore, it is likely that some non¬
target broadleaf species would be adversely affected if
they are present in the treatment area. For non-target
aquatic plants, however, ERAs predicted no risk under
direct spray or spill scenarios. Aminopyralid is not
approved for aquatic uses, but is likely to receive a
registration that addresses incidental overspray into
aquatic habitats. These risk assessment results indicate
that use indicate that use of aminopyralid right up to the
water’s edge would not harm aquatic plants.
Apart from direct spray scenarios, risks to terrestrial
plants would generally be low. Risks associated with
off-site drift decrease as the distance from the treatment
site increases and the application height gets lower
(plane to helicopter to high boom to low boom). The
buffer widths shown in Table 4-8 indicate the distances
within which adverse effects to non-target terrestrial
plants would be expected to occur for the various
application scenarios. For aerial applications, buffer
distances range from 1,200 to 1,800 feet, depending on
the application rate and type of aircraft used. Buffer
distances for ground applications are much lower,
ranging from 25 to 400 feet.
For surface runoff and root-zone groundwater flow
scenarios, no risks to non-target terrestrial or aquatic
plants were predicted. The GLEAMS model used to
complete this portion of the risk assessments considered
a variety of soil types and annual precipitation rates.
For wind erosion scenarios, no risks were predicted for
non-target terrestrial plants under the majority of the
evaluated conditions. Low risk was predicted for one of
the modeled watersheds, with affected plants at a
distance of 1.5 kilometers (0.9 mile) from the original
application site. The modeled watershed was Medford,
Oregon, a forested site with loam soils, where the
presence of tall vegetation caused the model to predict
relatively high rates of deposition.
Impacts of Fluroxypyr
Target Plants
Fluroxypyr is a selective, post-emergent herbicide that
is used to manage broadleaf species in rangelands and
other areas (see Table 2-2). It is in the pyridine class of
herbicides, and disrupts plant cell growth by inducing
auxin-like responses. It is often used in industrial sites,
along roads and railroads, and along ROWs. Based on
its documented control of weeds, key flowering plant
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ENVIRONMENTAL CONSEQUENCES
TABLE 4-7
Risk Categories Used to Describe Typical Herbicide Effects to Vegetation According
to Exposure Scenario and Ecological Receptor Group
Application Scenario
Amino
jyralid
Fluroxypyr
Rimsulfuron
Typ'
Max1
Typ
Max
Typ
Max
Direct Spray/Spill
Terrestrial plants
H2
[1:1]
H
[1:1]
H
[1:1]
H
[1:1]
H
[1:1]
H
[1:1]
Special status terrestrial plants
H
[1:1]
H
[1:1]
H
[1:1]
H
[1:1]
H
[1:1]
H
[1:1]
Aquatic plants pond
0
[2:2]
0
[4:4]
0
[2:2]
L
[2:4]
H
[1:2]
M
[2:4]
Aquatic plants stream
0
[2:2]
0
[2:2]
0
[2:2]
0
[2:2]
H
[1:2]
H
[1:2]
Off-Site Drift
Terrestrial plants
L
[10:18]
L
[10:18]
L
[11:18]
L
[11:18]
L
[9:18]
L
[9:18]
Special status terrestrial plants
L
[10:18]
L
[10:18]
L
[13:18]
L
[11:18]
L
[9:18]
L
[8:18]
Aquatic plants pond
0
[36:36]
0
[36:36]
0
[36:36]
0
[36:36]
0
[24:36]
0
[23:36]
Aquatic plants stream
0
[36:36]
0
[36:36]
0
[36:36]
0
[36:36]
0
[24:36]
0
[23:36]
Surface Runoff
Terrestrial plants
0
[42:42]
0
[42:42]
0
[42:42]
0
[42:42]
0
[42:42]
0
[42:42]
Special status terrestrial plants
0
[42:42]
0
[42:42]
0
[42:42]
0
[42:42]
0
[42:42]
0
[42:42]
Aquatic plants pond
0
[84:84]
0
[84:84]
0
[84:84]
0
[84:84]
0
[55:84]
0
[54:84]
Aquatic plants stream
0
[84:84]
0
[84:84]
0
[80:84]
0
[84:84]
0
[84:84]
0
[84:84]
Wind Erosion
Terrestrial Plants
0
[9:9]
0
[8:9]
0
[9:9]
0
[8:9]
0
[8:9]
0
[8:9]
Special status terrestrial plants
o
sc
0
[8:91
0
[8:9]
0
[7:91
0
[8:9]
0
[8:91
1 Typ = Typical application rate; and Max = Maximum application rate.
2 Risk categories: 0 = No risk (majority of RQs < applicable LOC); L = Low risk (majority of RQs 1-10 times the applicable LOC); M = Moderate risk
(majority of RQs 10-100 times the applicable LOC); and H = High risk (majority of RQs >100 times the applicable LOC). The Risk Category is based
on the risk level of the majority of risk quotients observed in any of the scenarios for a given exposure group and receptor type. For some “no risk”
exposure groups, RQs for one or more scenarios exceeded the applicable LOC. The reader should consult the risk tables in Chapter 4 of the ERAs
(AECOM 2014a,b; AECOM 2015) to determine the specific scenarios that result in the displayed level of risk for a given receptor group. The number
in brackets represents the number of RQs in the indicated risk category: number of scenarios evaluated.
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ENVIRONMENTAL CONSEQUENCES
TABLE 4-8
Buffer Distances to Minimize Risk to Non-target Vegetation from Off-site Drift
Application Scenario
Aminopyralid
Fluroxypyr
Rimsulfuron
Buffer Distance (feet) from Non-Target Terrestrial Plants
Typical Application Rate
Plane1
1,300 feet
1 ,200 feet
1 ,600 feet
Helicopter1
1,200 feet
900 feet
1,400 feet
High Boonr
200 feet
400 feet
400 feet
Low Boom"
25 feet
1 00 feet
1 00 feet
Maximum Application Rate
Plane
1,800 feet
1,500 feet
1,900 feet
Helicopter
1 ,600 feet
1 ,400 feet
1,600 feet
High Boom
400 feet
600 feet
700 feet
Low Boom
1 00 feet
400 feet
400 feet
Buffer Distance (feet) from Terrestrial Threatened , Endangered, and Sensitive Plants
Typical Application Rate
Plane
1 ,800 feet
1 ,200 feet
1 ,600 feet
Helicopter
1 ,600 feet
900 feet
1 ,400 feet
High Boom
400 feet
400 feet
400 feet
Low Boom
1 00 feet
1 00 feet
1 00 feet
Maximum Application Rate
Plane
2,000 feet
1 ,500 feet
1,900 feet
Helicopter
1,700 feet
1,500 feet
1 ,600 feet
High Boom
600 feet
700 feet
700 feet
Low Boom
400 feet
600 feet
400 feet
Buffer Distance (feet) from Non-Target Aquatic Plants 4
Typical Application Rate
Plane
NA4
NA
1,300 feet
Helicopter
NA
NA
1,000 feet
High Boom
NA
NA
200 feet
Low Boom
NA
NA
1 00 feet
Maximum Application Rate
Plane
NA
NA
1 ,400 feet
Helicopter
NA
NA
1,800 feet
High Boom
NA
NA
300 feet
Low Boom
NA
NA
1 00 feet
1 Aerial applications over both forester
2 High boom is 50 inches above groun
3 Aquatic plants in ponds and streams
4NA means that no buffers are require
habitat is not an approved use of thes
Buffer distances are the smallest mode
modeled still resulted in risk, or interp
and non-forested land were considered in the ERAs. The largest buffer distances are presented in this table,
d and low boom is 20 inches above ground.
were considered in the ERAs. The largest buffer distances are presented in this table.
d, since direct spray of plants was not predicted to result in adverse effects. However, a direct spray into an aquatic
e herbicides.
led distance at which no risk was predicted. In some cases, buffer distances were extrapolated if the largest distance
olated if greater precision was required.
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ENVIRONMENTAL CONSEQUENCES
families that are affected by fluroxypyr include the
Asteraceae (aster), and Fabaceae (legume) families.
The BLM has identified the effectiveness of this
herbicide on annual and biennial weeds, particularly
when tank-mixed with another herbicide such as 2,4-D,
dicamba, metsulfuron methyl, or triclopyr. It would be
used to manage species such as weedy (annual) kochia,
mustards, pricklypear, ragweed, leafy spurge, and
invasive blackberry. Fluroxypyr has been shown to
have a synergistic effect when mixed with 2,4-D to
control certain broadleaf weeds (Smith and Mitra 2006),
and to improve control of leafy spurge when mixed with
picloram (Peterson 1989). Fluroxypyr mixed with
picloram has also been shown to control cholla and
pricklypear, which can become dense on desert
grassland sites as a result of overgrazing (Cummings
and Duncan 2009).
Fluroxypyr has been identified as an option for
addressing weeds that are resistant to herbicides with
different modes of action. Its uses would likely include
oil and gas sites where resistance to currently approved
herbicides could be a problem. For instance, kochia that
is resistant to ALS-inhibiting herbicides can be treated
with fluroxypyr, although kochia can also develop a
resistance to fluroxypyr (Montana State University
Extension 2011).
Non-Target Plants
Fluroxypyr is a selective herbicide that controls
broadleaf species. Therefore it poses a risk to non-target
forbs, as well as desirable woody species in treatment
areas. Because fluroxypyr is often tank-mixed with
other active ingredients, its risk for non-target effects
should be considered in conjunction with those of the
other active ingredients.
Fluroxypyr would be used at oil and gas sites or other
locations where complete removal of vegetation is
desired. In these situations, non-target plants would not
be present within the treatment area.
The risk assessment for fluroxypyr indicates that this
active ingredient poses a high risk to non-target
terrestrial plants through direct spray scenarios (Table
4-7). It is assumed that direct spray of some non-target
vegetation within the treatment area (if present) would
occur, particularly if fluroxypyr is broadcast sprayed
over a large area where desirable broadleaf species are
present and are susceptible at the time of treatment.
In the case of aquatic habitats, direct spray into a pond
or a stream would not pose a risk to non-target aquatic
plant species. Therefore, standard buffers between
treatment areas and aquatic habitats would be sufficient
to prevent harm to aquatic plants. However, an
accidental spill of a large quantity of fluroxypyr (i.e., an
entire load of herbicide mixed for an application) into a
pond would pose a risk to non-target aquatic plants.
These risks would be minimized by SOPs, which
include conducting mixing and loading operations in
areas where an accidental spill would not contaminate
aquatic habitats.
Risks to terrestrial plants from off-site drift are
generally low, and would be greatest for aerial
applications of fluroxypyr. Suitable buffer distances to
protect non-target terrestrial plants range from 1 00 feet
for ground applications with a low boom to 1,500 feet
for certain airplane applications (Table 4-8). No risks to
terrestrial plants were predicted for surface runoff
exposure scenarios.
No risks to non-target aquatic plants were predicted for
exposures involving off-site drift, surface runoff, or
root-zone groundwater flow under a variety of site
conditions.
For wind erosion scenarios, no risks were predicted for
non-target terrestrial plants under the majority of the
evaluated conditions. Low risk was predicted for the
Medford, Oregon modeled watershed, with affected
plants at a distance of 1.5 km from the original
application site.
Additional effects to certain non-target plant species
could occur if populations of pollinators were harmed
by herbicide spraying. Based on ERAs, fluroxypyr
poses a low risk to pollinators under direct spray
scenarios. However, ERAs did not identify risks to
pollinators from use of aminopyralid or rimsulfuron.
Impacts of Rimsulfuron
Target Plants
Rimsulfuron is a selective, ALS-inhibiting herbicide
that controls target weeds by inhibiting the biosynthesis
of certain amino acids. It is applied both pre- and post¬
emergence, and is active in both the xylem and the
phloem of the plant. Invasive plants targeted by this
active ingredient include cheatgrass, medusahead rye,
and other annual grasses that have invaded public lands
in the western U.S. The BLM is proposing to use this
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ENVIRONMENTAL CONSEQUENCES
active ingredient extensively, based on reports that it is
effective at controlling winter annual grasses.
Rimsulfuron is effective against cheatgrass and
Japanese brome in the fall pre-emergence, or post
emergence in the fall or spring. It provides a longer
window of control than imazapic, although it must be
used at the highest label rates for effective spring
applications. Rimsulfuron can also be used to control
larger cheatgrass plants than imazapic (Beck, No date).
The effectiveness of rimsulfuron at controlling
cheatgrass and medusahead rye has been documented
(Zhang et al. 2010), although there is conflicting
evidence about its effectiveness relative to currently
approved active ingredients (primarily imazapic). Some
studies with rimsulfuron indicate that it is not as
effective at controlling cheatgrass as either of the
currently approved herbicides imazapic or sulfometuron
methyl (Clements and Harmon 2013). However, there is
also evidence that rimsulfuron is more effective than
imazapic under certain conditions (Hirsch et al. 2012).
Non-Target Plants
Rimsulfuron is a selective herbicide that targets annual
grasses and other annual species. Therefore, it has
minimal effects on perennial grasses and other desirable
perennial species. A study in northeastern California
rangelands found that rimsulfuron effectively controlled
cheatgrass and medusahead rye without substantially
impacting sagebrush and desirable perennial grasses
such as squirreltail (Zhang et al. 2010). Additionally,
there is some evidence that application of rimsulfuron
can result in an increase in perennial grass cover at
treatment sites, compared to no discemable effect by
imazapic (Hergert et al 2012). Therefore, rimsulfuron
may benefit perennial non-target plant species, with less
post-treatment restoration needed.
Based on information from the ERA, rimsulfuron poses
a high risk to non-target terrestrial plants under direct
spray scenarios (Table 4-7). Therefore, it is likely that
some native plant species within the treatment area (if
present) would be affected by treatments involving
rimsulfuron, particularly as a result of broadcast spray
applications.
An accidental direct spray of rimsulfuron into an
aquatic habitat (stream or pond), or a spill of
rimsulfuron into a pond, would pose a high risk for
adverse effects to non-target aquatic plants. The risk of
spills and accidental direct spray would be minimized
through the use of SOPs.
Non-target terrestrial vegetation would be at a low risk
for adverse effects from off-site drift of rimsulfuron
from treatment sites. Based on ERAs, buffers of 1 00 to
1,900 feet (depending on the application) would be
necessary to protect sensitive vegetation from adverse
effects from herbicide treatments with rimsulfuron
(Table 4-8).
Table 4-7 indicates that there is no risk to aquatic
vegetation from off-site drift, based on information
provided in the ERA. While there is some indication
that chronic (long-term) exposure to rimsulfuron
following off-site drift could adversely affect aquatic
plants, the modeled scenarios are overly conservative
because a chronic exposure is unlikely, and they do not
consider flow, adsorption to particles, or degradation of
the herbicide over time. The buffers presented in Table
4-8 represent the distance beyond which there would be
no risk to aquatic plants under any of the modeled
scenarios.
There are no predicted risks to non-target terrestrial or
aquatic plants in streams as a result of surface runoff of
rimsulfuron from a nearby treatment site. In the pond
setting, however, chronic exposures to surface runoff of
this herbicide could potentially affect aquatic plants
under certain site conditions. Modeled conditions that
were associated with adverse effects via surface runoff
included high levels of precipitation (25 inches or more
a year for sandy soils, 50 inches or more a year for loam
soils, and 1 00 inches or more a year for clay soils).
For wind erosion scenarios, no risks were predicted for
non-target terrestrial plants under the majority of the
evaluated conditions. Low risk was predicted for the
Medford, Oregon modeled watershed, with affected
plants at a distance of 1.5 kilometers from the original
application site.
Impacts of Tank Mixes and other Mixtures
Mixtures of more than one herbicide are often used to
increase the efficacy of a treatment or to control a wider
range of target species without requiring multiple
applications. Because pre-mixes and tank mixes often
include active ingredients with more than one mode of
action, they can provide better control of a target species
than a single active ingredient. Use of herbicide
mixtures is also one strategy for avoiding and managing
herbicide-resistant invasive plants (Montana State
University Extension 2011). Some species targeted for
control by the BLM (e.g., marestail, pigweed, and
kochia) have begun to exhibit resistance to currently
approved herbicides.
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ENVIRONMENTAL CONSEQUENCES
The ERAs for aminopyralid, fluroxypyr, and
rimsulfuron did not analyze the potential effects to non¬
target plants from mixtures involving these herbicides.
Tank mixes were discussed in Chapter 2 of this PEIS, in
the section Herbicide Formulations Used by the BLM
and Tank Mixes. Aminopyralid and fluroxypyr would
likely be mixed with numerous other previously
approved herbicides, but rimsulfuron would usually be
applied on its own.
Some mixtures involving the three new active
ingredients could pose a greater risk to non-target plants
than treatments involving any of these herbicides alone.
Certain plant species may be particularly sensitive to
mixtures. Conversely, use of one of the three new
herbicides in a mixture in the place of a more harmful
herbicide would likely result in a reduced risk to non¬
target plants.
There is uncertainty associated with the use of mixtures,
as the herbicides in a mixture may not interact in an
additive manner; some interactions may be antagonistic
and others may by synergistic. In general, buffers for
the formulated product will be based on the active
ingredient that requires the greatest buffer distance.
Impacts by Ecoregion
Table 4-9 provides a summary of the estimated percent
of the total acres treated using herbicides within each
ecoregion. The table also indicates how the treatments
would be spread out among the various vegetation
subclasses and macrogroups within each ecoregion. The
information provided in Table 4-9 updates Table 4-16
from the 2007 PEIS to reflect the new vegetation
classification system utilized by the BLM. The
treatment goals and associated target geographic areas
and vegetation are the same as those identified for the
Preferred Alternative in the 2007 PEIS. Table 4-9 is
applicable to all four of the alternatives being
considered in this PEIS.
The majority (71 percent) of herbicide treatment acres
would be in the Temperate Desert Ecoregion, in
shrubland, grassland, and steppe macrogroups. Many
treatments in these areas would have the goal of
restoring fire-damaged lands in the Great Basin,
improving sagebrush communities, and replacing
invasive annual grasses with native bunchgrasses and
forbs. Treatments may involve the management of such
species as sagebrush, rabbitbrush, and other shrub
species, annual grasses, and undesirable perennial forbs.
Rimsulfuron would likely receive wide use in this
ecoregion for managing invasive annual grasses,
particularly cheatgrass and medusahead rye, in various
plant community types. Aminopyralid and fluroxypyr
would typically be used in tank mixes to manage
broadleaf rangeland weeds such as yellow starthistle,
knapweeds, and annual kochia. Treatments to manage
invasive plant species can be successful with the
currently approved herbicides, but the availability of the
three new herbicides would allow the BLM more
flexibility when designing treatments.
An additional 25 percent of herbicide treatment acres
would be in the Temperate Steppe and Subtropical
Steppe Ecoregions, primarily in grassland, shrubland,
steppe, and chaparral macrogroups. In the Temperate
Steppe ecoregion, herbicide treatments would focus on
management of invasive annual and perennial grasses
and forbs, including cheatgrass, leafy spurge,
knapweeds, and thistles. All three of the new active
ingredients could be utilized for certain identified target
species. In the Subtropical Steppe Ecoregion,
rimsulfuron would be a new option for managing
infestations of invasive annual grasses in sagebrush and
pinyon-juniper communities, and would help to reduce
wildfire risk in these habitats. Similar to the Temperate
Steppe Ecoregion, the three new herbicides would offer
the BLM more options for meeting its treatment goals in
the Subtropical Steppe Ecoregion.
Impacts by Alternative
The primary goals of herbicide treatments would be to
control infestations of invasive plants and help restore
natural fire regimes. Other goals might be to improve
safety and protect infrastructure (e.g., controlling
vegetation along roadsides or at oil and gas sites).
Herbicides would commonly be used on rangelands
infested by annual grasses, such as cheatgrass and
medusahead rye, followed by revegetation with
perennial grasses and forbs, as needed. Herbicides
would also be used to suppress or thin shrubs such as
sagebrush in favor of herbaceous vegetation. In some
areas, herbicide treatments might reduce the vigor or
cover of perennial grasses and forbs over the short term,
but perennial grass and forb communities should
improve over the long term as shrub stands are thinned
to allow more light and nutrients to reach the understory
and competition with annual grasses and forbs is
reduced. In most cases, multiple treatments and
restoration would be necessary to recover native plant
communities and restore natural fire regimes.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
4-33
January 2016
ENVIRONMENTAL CONSEQUENCES
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BLM Vegetation Treatments Three New Herbicide
Final Programmatic EIS
4-34
January 2016
TABLE 4-9 (Cont.)
Projected Herbicide Treatments1, as a Percent of Total Acres Treated, in Each Ecoregion for
Each Vegetation Macrogroup Under All Alternatives
ENVIRONMENTAL CONSEQUENCES
BLM Vegetation Treatments Three New Herbicide
Final Programmatic EIS
4-35
January 2016
ENVIRONMENTAL CONSEQUENCES
All four of the alternatives analyzed in this PEIS
involve the same geographic area as far as herbicide
treatments, as well as the same assumed total acreage of
herbicide treatments annually (932,000 acres). Under all
alternatives, the breakdown in usage by ecoregion
(Table 4-9) would also be the same. The primary
differences among the alternatives are associated with
the herbicides that would be available for use, and the
relative proportion of their use (summarized in Table
2-4).
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue current vegetation management programs in 17
western states, and would treat an estimated 932,000
acres per year using both ground-based and aerial
applications of the 18 previously approved herbicides.
The impacts to vegetation under this alternative were
included in the discussion for the Preferred Alternative
of the 2007 PEIS (USDOI BLM 2007a:4-66 to 4-67).
Based on projected herbicide use under this alternative
(Table 2-4), imazapic, triclopyr, tebuthiuron, clopyralid,
and glyphosate would be used the most, together
accounting for approximately 73 percent of the land
area that would be treated. The risks and benefits of
using these herbicides are discussed in the 2007 PEIS
(USDOI BLM 2007a:4-48 to 4-66). Imazapic is used to
manage species such as cheatgrass, hoary cress, and
perennial pepperweed, and generally has a low to
moderate risk to non-target vegetation. Triclopyr is an
herbicide registered for aquatic use that is commonly
used on woody riparian species, as well as wetland and
aquatic invasives (e.g., Eurasian watermilfoil and purple
loosestrife). It has a moderate to high risk to non-target
plants. Tebuthiuron is used primarily to manage woody
invasive plants in rangelands and ROWs. The BLM
uses tebuthiuron to thin sagebrush and create more
favorable habitat for sagebrush-dependent species such
as sage-grouse. It has a moderate to high risk to non¬
target plants. Clopyralid is also used to control
broadleaf weeds, and is used in forest and rangeland
areas for the management of species such as diffuse and
spotted knapweed, yellow starthistle, and bull, Canada,
Scotch, and musk thistle. It generally has a low to
moderate risk to non-target plants. Glyphosate is
commonly used in areas where bare ground is desired,
and in aquatic and riparian habitats to manage invasive
plants such as purple loosestrife, giant reed, and water
lilies. It generally has a low to moderate risk to non¬
target plants.
The goals, effectiveness, and extent of herbicide
treatments would be much the same as at present.
Herbicide treatments would be used in conjunction with
other treatment methods to manage invasive plant
species, with varying degrees of effectiveness at
establishing and maintaining native and desirable plant
communities. Additionally, repeated use of the same
herbicides could allow target invasive plants to develop
herbicide resistance over time. With multiple treatments
over the long term, successful control of fire-adapted
invasive species such as cheatgrass would help reduce
fire risk, and maintenance and restoration of native plant
communities would help maintain and restore historic
fire regimes.
Monitoring of treatment sites would continue to be
conducted to determine the effectiveness of treatments
and the need for retreatment. Site revisits would be
made to compare the targeted population size against
pre-treatment data, to compare pre-treatment and post¬
treatment data, and to assess the establishment and
recovery of desirable vegetation.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, herbicide treatment projects
would be much the same as those under the No Action
Alternative, except that aminopyralid, fluroxypyr, and
rimsulfuron would be available for use in addition to all
of the currently approved herbicides.
Based on projected herbicide use under this alternative
(Table 2-4), rimsulfuron, triclopyr, tebuthiuron,
clopyralid, aminopyralid, and imazapic would be used
the most, together accounting for approximately 81
percent of the land area that would be treated. The new
active ingredients would account for an estimated 27
percent of all acres treated, with rimsulfuron and
aminopyralid accounting for approximately 26 percent
of all acres treated. Compared to the No Action
Alternative, use of imazapic, glyphosate, and picloram
would decrease substantially with the introduction of
these chemicals. Use of fluroxypyr would be minimal
under this and the other action alternatives.
While the three new herbicides are generally low risk,
they would still impact non-target plants under direct
spray and spill scenarios, much like the herbicides that
would be used most extensively under the No Action
Alternative. Therefore, there would not be a substantial
difference between the No Action Alternative and the
BLM Vegetation Treatments three New Herbicides
Final Programmatic EIS
4-36
January 2016
ENVIRONMENTAL CONSEQUENCES
Preferred Alternative in terms of risk to non-target
plants.
The introduction of the new active ingredients could
increase the effectiveness of certain components of
vegetation management by providing additional options
for targeting invasive plants. Aminopyralid could be
used to control of many of the species currently targeted
by picloram (e.g., knapweeds, thistles, and yellow
starthistle). This active ingredient is likely to receive an
aquatic registration in the near future that would allow
for incidental overspray of aquatic habitats during
treatment of wetland and riparian vegetation. With such
a registration, aminopyralid could be used in place of
glyphosate for management of certain invasive plants in
riparian areas. Because aminopyralid is more selective
than glyphosate, it may be less likely to result in
removal of non-target riparian vegetation.
Rimsulfuron would typically be used to manage
cheatgrass and other annual grasses, and as such could
be used instead of imazapic in some instances.
Rimsulfuron has been observed to be more effective
than imazapic in certain areas.
Fluroxypyr would be used minimally, but may increase
the effectiveness of certain herbicide treatments relative
to the No Action Alternative by controlling target
species that are resistant to other herbicides, improving
control of target species when mixed with other active
ingredients, and reducing the amount of other herbicides
products used in treatments.
Overall, there would be no change to the goals or extent
of herbicide treatment programs, relative to the No
Action Alternative, although it is possible that there
could be an improvement in the effectiveness of certain
treatments with the availability of the new herbicides.
Improved effectiveness of treatments could allow the
BLM to better meet its goals of managing undesirable
vegetation, reducing fire risk, and restoring natural fire
regimes.
Alternative C - No Aerial Application of New
Herbicides
Under Alternative C, herbicide treatment projects would
be much the same as those under the No Action and
Preferred Alternatives, except that in addition to all the
other currently approved herbicides, aminopyralid,
fluroxypyr, and rimsulfuron would be available for use
for ground treatments only.
Based on projected herbicide use under this alternative
(Table 2-4), triclopyr, tebuthiuron, imazapic, clopyralid,
and glyphosate would be used the most, together
accounting for approximately 69 percent of the land
area that would be treated, which is similar to the No
Action Alternative. The new herbicides would account
for approximately 10 percent of all acres treated, with
rimsulfuron and aminopyralid accounting for 9 percent
of all acres treated, or about one third of the amount
under the Preferred Alternative.
Overall risks to non-target plants under this alternative
would not be substantially different than under the other
alternatives. The most commonly used herbicides would
continue to pose a risk to non-target plants as a result of
herbicide treatments, particularly under direct spray and
spill scenarios.
Prohibiting aerial spraying of the three new herbicides
would limit their usefulness. For example, given the
abundance of cheatgrass and other invasive annual
grasses and the extensiveness of planned treatments for
these species, aerial spraying is one of the most cost-
effective treatment methods. The BLM would not have
the option to aerially spray rimsulfuron, and would
instead continue to utilize imazapic for these
applications. While the BLM would still have some
options to utilize the three new active ingredients to
increase the effectiveness of treatments, these options
would be limited relative to the Preferred Alternative.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under this alternative, herbicide treatment projects
would be much the same as under the other alternatives.
Similar to the other action alternatives, new active
ingredients would be available for use, but they would
only include aminopyralid and fluroxypyr. Based on
projected herbicide use under this alternative (Table 2-
4), triclopyr, tebuthiuron, clopyralid, glyphosate, and
aminopyralid would be used the most, together
accounting for approximately 70 percent of the land
area that would be treated. New herbicides would
account for approximately 1 1 percent of all acres
treated, with aminopyralid accounting for 10 percent.
In general, risks to non-target plants would be similar to
those under the other alternatives. Herbicides would
continue to pose a risk to non-target plants, particularly
under direct spray and spill scenarios.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
4-37
January 2016
ENVIRONMENTAL CONSEQUENCES
Prohibiting the use of rimsulfuron would give the BLM
one fewer herbicide option for its herbicide treatments,
relative to the Preferred Alternative and Alternative C.
The BLM would continue to utilize imazapic for
management of cheatgrass and other annual grasses.
However, aminopyralid would be available as an option
for management of undesirable broadleaf plants in
upland and riparian habitats, and use of picloram would
decrease by approximately the same amount as under
the Preferred Alternative. The availability of
aminopyralid and fluroxypyr could increase the
effectiveness of certain treatments relative to the No
Action Alternative, but this increase would be less than
under the Preferred Alternative.
Mitigation for Herbicide Treatment
Impacts
In addition to the SOPs identified earlier in this section
and in the 2007 PEIS (USDOI BLM 2007a:Table 2-8),
the following measures are recommended to reduce
impacts to non-target vegetation from the use of
herbicides:
• Use Table 4-8 to establish herbicide-specific
buffer zones around downstream water bodies,
and associated habitats and non-target plant
species/populations of interest for
aminopyralid, fluroxypyr, and rimsulfuron.
Consult the ERAs for more specific
information on appropriate buffer distances
under different soil, moisture, vegetation, and
application scenarios.
Special Status Plant Species
Introduction
As discussed in Chapter 3, public lands in the western
U.S. support numerous plant species that have been
given a special status based on their rarity or sensitivity.
Special status plants include approximately 165 species
that are federally listed as threatened or endangered, or
are proposed for federal listing. The remaining special
status species include candidates for federal listing, and
other species that warrant special attention and could
potentially require federal listing in the future. Many of
these species are threatened by competition with non¬
native plants and other invasive species. The Vegetation
Treatments Using Aminopyralid, Fluroxypyr, and
Rimsulfuron on Bureau of Land Management Lands in
17 Western States Biological Assessment (USDOI BLM
2015) provides a description of the distribution, life
history, and current threats of each federally-listed plant
species, as well as species proposed for listing. The BA
also discusses the risks to threatened and endangered
species, and species proposed for listing, associated
with the use of aminopyralid, fluroxypyr, and
rimsulfuron by the BLM.
Impacts Assessment Methodology
The BLM reviewed the literature and findings from
ERAs conducted by the BLM to assess the impacts to
sensitive plant species from the use of herbicides
(AECOM 20 1 4a, b; AECOM 2015). The ERA methods
are summarized in the Vegetation section of this
chapter, and are presented in more detail in the
Vegetation Treatments Programmatic EIS Ecological
Risk Assessment Protocol (ENSR 2004) and in
Appendix C of the 2007 PEIS.
The acute endangered species LOC for plants is 1,
which is the same as that for typical plant species.
However, separate plant toxicity endpoints were
selected to provide extra protection to special status
plant species. Thus, ERAs for some herbicides predicted
higher risks for special status plant species than for
“typical” plant species under certain exposure scenarios.
The potential risks to sensitive plant species from use of
herbicides can be minimized by following certain SOPs.
These SOPs were identified in the 2007 PEIS (USDOI
BLM 2007a:Table 2-8, 4-71), and would continue to be
implemented at the local level based on site conditions.
These SOPs include:
• Survey for special status plant species, at a time
they can be found and identified, before
treating an area. Consider effects to special
status species when designing herbicide
treatment programs.
• Use drift reduction agents to reduce the risk of
drift hazard.
• Use a selective herbicide and a wick or
backpack sprayer to minimize risks to special
plants.
Summary of Herbicide Impacts
The 2007 PEIS provides a general discussion of
potential impacts (adverse and beneficial) to special
status plant species from herbicide treatments (USDOI
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
4-38
January 2016
ENVIRONMENTAL CONSEQUENCES
2007a:4-71 to 4-73). This discussion considers the
BLM’s vegetation treatment program as a whole, and
therefore would also be applicable to herbicide
treatments that utilize the three new chemicals.
As many special status plant species are threatened by
the spread of non-native plants, fuels reduction and
control of competing vegetation are important
components of management programs for special status
plant species. Therefore, herbicide treatments conducted
as part of these programs would be expected to benefit
populations of special status plant species. Additionally,
general program goals of restoring native communities
and minimizing fire risk would also benefit these
species by improving habitat conditions and in some
cases reducing the risk of extirpation as a result of fire.
The BA provides additional information on which listed
and proposed plant species are most at risk from
competition with non-native plants and for extirpation
of populations from fire.
All herbicides would have the potential to harm
populations and individuals of special status plant
species. At the local level, locations and risks to
sensitive plant populations would be considered when
designing treatment projects, and the appropriate
precautions would be taken to avoid impacts to these
species. In some cases, manual spot treatments of
herbicides would be the only feasible option for
avoiding impacts to listed species. In other cases, some
level of short-term mortality may be acceptable for
long-term habitat improvement and increase in
population size.
Impacts from Use of the Three New
Herbicides
Based on information in the ERAs, all three herbicides
would pose risks to terrestrial special status plant
species under direct spray and off-site drift scenarios.
The greatest risks to terrestrial special status plants from
off-site drift would be associated with aerial
applications, where buffer distances of 900 to 2,000
feet (depending on application rate and site conditions)
would likely be required to protect populations of
special status plant species (Table 4-8). For ground
applications, smaller buffers of 25 to 700 feet would be
required.
The vast majority of the BLM’s special status plant
species are terrestrial. However, there are also aquatic
plant species (including species in wetland habitats) for
which separate risk analyses were completed.
Accidental direct spray or spill of fluroxypyr or
rimsulfuron could result in harm to aquatic special
status plant species. In the case of aminopyralid,
however, ERAs did not predict risks to sensitive non¬
target aquatic plants under these exposure scenarios.
Should aminopyralid receive an aquatic registration in
the future that allows for incidental overspray into
aquatic habitats, it is not expected that sensitive aquatic
plants would be harmed by applications in adjacent
upland or wetland areas. Off-site drift of fluroxypyr
would not be expected to harm sensitive aquatic plants,
assuming standard BLM buffers around aquatic
habitats. However, special status aquatic plants would
be at risk for harm from spray drift of rimsulfuron.
Buffers of 100 to 300 feet would likely be required for
ground applications, and buffers of 1,000 to 1,400 feet
would likely be required for aerial applications of
rimsulfuron.
Based on the predictions in the ERA, adverse effects to
terrestrial special status plant species should not occur
as a result of surface runoff of any of the three
herbicides. Additionally, it is not expected that surface
runoff of aminopyralid or fluroxypyr would harm
sensitive aquatic plants in downslope habitats.
However, surface runoff of rimsulfuron would have the
potential to adversely affect special status aquatic
plants, particularly in sandy soils and in areas with
greater than 50 inches of rainfall per year.
Additional indirect effects to certain special status plant
species could occur if populations of pollinators were
harmed by herbicide spraying. However, according to
risk assessments, risks to pollinators would be less than
those associated with direct spray of the rare plants
themselves. No adverse effects to pollinators were
predicted for direct spray or dermal contact with
vegetation sprayed by aminopyralid or rimsulfuron.
Low risks to pollinators were predicted under scenarios
involving direct spray by fluroxypyr. Management
efforts to protect rare plants would also help prevent
harm to insects in the vicinity. These management
efforts include:
• Designating buffer zones around rare plants.
• Managing herbicide drift especially to nearby
blooming plants.
• Using typical rather than maximum rates of
herbicides in areas with rare plants.
• Choosing herbicide formulations that are not
easily carried by social insects to hives, hills,
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
4-39
January 2016
ENVIRONMENTAL CONSEQUENCES
nests, and other ’’homes” in areas with rare
plants.
• Choosing herbicides that degrade quickly in the
environment when herbicides must be used in
rare plant habitat.
• Timing the herbicide applications when
pollinators are least active, such as in the
evenings or after blooming has occurred in rare
plant habitat, and if necessary dividing the rare
plant habitat into several treatments rather than
one large treatment to keep from treating all
blooming species at one time.
Effects to pollinators would be short-term, and
population-level effects are not anticipated when these
types of management practices are incorporated into
project design when rare plants are present.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Impacts to special status plant species under this
alternative were summarized in the 2007 PEIS under the
discussion for the Preferred Alternative (USDOl BLM
2007a:4-74). Up to 932,000 acres of public lands would
be treated with herbicides annually. Herbicide use
would be associated with risks to special status plant
species, although treatments would be designed at the
local level to avoid or minimize risks to these species.
Regardless of measures to avoid sensitive plant
populations, there would be some risk of accidental
exposure to herbicides. As identified in the 2007 PEIS,
active ingredients with the greatest risks for adverse
effects to special status plants would be 2,4-D,
bromacil, diquat, diuron, hexazinone, and sulfometuron
methyl.
Under this alternative, populations of special status
plant species would benefit from herbicide treatments
that reduce fuels (such as cheatgrass) and control non¬
native, invasive species that compete with native plants.
Aminopyralid, fluroxypyr, and rimsulfuron would not
be approved for use under this alternative, but the
species that they target would continue to be managed
using currently approved herbicides.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, the total acreage of public lands
treated with herbicides annually would be the same as
under the No Action Alternative and the other action
alternatives. However, aminopyralid, fluroxypyr, and
rimsulfuron could be used as part of vegetation
management programs throughout the 1 7 western states.
Special status plant species would continue to be at risk
for harm from contact with herbicides, although
treatments would continue to be designed to avoid or
minimize impacts to special status plant species.
In considering the active ingredients with the greatest
risk to non-target plants, discussed under Alternative A,
there would be little change in the amount of these
ingredients used under the Preferred Alternative, and all
except 2,4-D would continue to make up a very small
component of the total amount of herbicide used
annually. Under the Preferred Alternative, 2,4-D use is
estimated at 5 percent, versus 6 percent under the No
Action Alternative.
While the three new active ingredients would not offer
substantially different types of target species control,
they may be able to increase the efficacy of individual
treatments by addressing herbicide resistance issues,
adding to the strength of other herbicides in tank mixes,
and performing better than currently approved
herbicides under certain site conditions.
Alternative C - No Aerial Application of New
Herbicides
This alternative would be similar to the other
alternatives as far as risks and benefits to special status
plant species. Treatment acres would be the same as
those under the other alternatives, and the suite of
chemicals available would be the same as under the
Preferred Alternative, except that aminopyralid,
fluroxypyr, and rimsulfuron would only be available for
application using ground methods; aerial spraying of
these chemicals would not occur.
Since aerial spraying of herbicides would not occur in
habitats that support listed species, and is unlikely to
occur in many habitats that support populations of
special status plant species, this alternative would not be
substantially different than the Preferred Alternative as
far as risks to sensitive plant species.
Herbicides with the greatest risk to non-target plants
would continue to be used in small amounts, and at
levels similar to those under the No Action Alternative.
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ENVIRONMENTAL CONSEQUENCES
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
This alternative would be similar to the other
alternatives as far as total acres treated and herbicides
available for use, except that rimsulfuron would not be
added to the list of approved active ingredients.
Aminopyralid and fluroxypyr would be integrated into
herbicide treatment programs, including those designed
to improve habitats occupied by, or that could be
occupied by, special status plant species.
Because rimsulfuron would not be available for use, the
relative amount of each herbicide used under this
alternative would be very similar to the breakdown
under the No Action Alternative. Most importantly, the
relative use of herbicides with the greatest risks to non¬
target plants also would be very similar to the use of
these chemicals under the No Action Alternative. These
chemicals would continue to be used in small quantities,
and risks to non-target sensitive plant species would be
similar to those under the other alternatives.
Mitigation for Herbicide Treatment
Impacts
When using the previously approved herbicides, the
BLM would continue to follow mitigation for
vegetation and special status plants identified in the
2007 PEIS. The following mitigation is recommended
to reduce the likelihood of impacts to special status
plant species from applications of aminopyralid,
fluroxypyr, and rimsulfuron. This mitigation should be
implemented in addition to the SOPs designed to protect
plants presented in Chapter 2 and the general mitigation
recommended in the Vegetation section.
• To protect special status plant species,
implement all conservation measures for plants
presented in the Vegetation Treatments Using
Aminopyralid, Fluroxypyr, and Rimsulfuron on
Bureau of Land Management Lands in 17
Western States Biological Assessment (USDOI
BLM 2015). Apply these measures to sensitive
plant species, as well as listed species.
Fish and Other Aquatic
Organisms
Introduction
The proposed herbicide treatments have the potential to
affect fish and other aquatic organisms, predominantly
through indirect effects to aquatic habitats and adjacent
riparian and upland areas. Noxious weeds and other
non-native invasive species can be detrimental to
aquatic habitats. Infestations of riparian systems and
other habitats by non-native plants can reduce the ability
of these systems to support fish and other aquatic
organisms. Non-native plants can affect stream
morphology and habitat characteristics, bank erosion,
flow levels, and populations of native insects that
provide a food source for fish. Removal of invasive
species can help to restore a more complex vegetative
and physical structure and natural levels of processes
such as sedimentation and erosion.
Scoping Comments and Other Issues
Evaluated in the Assessment
None of the scoping comments received were specific
to fish or other aquatic organisms. However, comments
concerned with the potential for the new herbicides to
impact water resources would also apply to aquatic
organisms and their habitats. Additionally, comments
that support the new herbicides for their limited
environmental risk are applicable.
Standard Operating Procedures
The SOPs listed in the 2007 PEIS would be followed
for treatments with aminopyralid, fluroxypyr, and
rimsulfuron, as applicable:
• Develop and update an operational plan for
each herbicide project that includes information
on project specifications; key personnel
responsibilities; communication procedures;
safety, spill response, and emergency
procedures; and minimum buffer widths for
herbicides not approved for aquatic use.
• Use appropriate buffer zones based on label
and risk assessment guidance.
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• Minimize treatments near fish-bearing water
bodies during periods when fish are in life
stages most sensitive to the herbicide(s) used,
and use spot rather than aerial treatments.
• Use appropriate application equipment and
methods near water bodies if the potential for
off-site drift exists.
• Where feasible, use spot hand applications
within 20 feet of perennial streams and non¬
perennial streams with flowing water at the
time of application.
• Use herbicides that are least toxic to fish, yet
still effective.
• For treatment of aquatic vegetation, 1) treat
only that portion of the aquatic system
necessary to achieve acceptable vegetation
management, 2) use the appropriate application
method to minimize the potential for injury to
desirable vegetation and aquatic organisms,
and 3) follow use restrictions on the herbicide
label.
Additional mitigation for fish and aquatic organisms is
presented in the ROD for the 2007 PEIS (USDOI BLM
2007b:Table 2). Many of these mitigation measures
would apply to treatments involving the three new
herbicides, or tank mixes with these active ingredients.
• Limit the use of terrestrial herbicides
(especially diuron) in watersheds with
characteristics suitable for potential surface
runoff that have fish-bearing streams during
periods when fish are in life stages most
sensitive to the herbicide(s) used.
• To protect special status fish and other aquatic
organisms, implement all conservation
measures for aquatic animals presented in the
Biological Assessment for Vegetation
Treatments on Bureau of Land Management
Lands in 17 Western States (USDOI BLM
2007f).
• Establish appropriate herbicide-specific buffer
zones for water bodies, habitats, or fish or other
aquatic species of interest (see the 2007 PEIS
[USDOI BLM 2007a:Appendix C, Table C-
16], as well as recommendations in individual
ERAs [AECOM 2014a,b; AECOM 2015]).
• Consider the proximity of application areas to
salmonid habitat and the possible effects of
herbicides on riparian and aquatic vegetation.
Maintain appropriate buffer zones around
salmonid-bearing streams (see the 2007 PEIS
[USDOI BLM 2007a:Appendix C, Table C-
16], as well as recommendations in individual
ERAs [AECOM 2014a,b; AECOM 2015]).
• At the local level, consider effects to special
status fish and other aquatic organisms when
designing treatment programs.
Impacts Assessment Methodology
The methods used to assess impacts to fish and aquatic
organisms from the three new herbicides were the same
as the methods described in the 2007 PEIS (USDOI
BLM 2007a:4-77 to 4-79). A brief overview of the risk
assessment process is provided here.
Risk Assessment Methodology
Aquatic receptors (fish and aquatic invertebrates) were
evaluated to determine the effects of herbicide exposure
in terms of certain assessment endpoints and associated
measures of effect. The assessment endpoint is an
expression of the value that is to be protected. In the
case of aquatic organisms, assessment endpoints include
survival, growth, and reproduction. These assessment
endpoints generally reflect direct effects on organisms,
but indirect effects were also considered.
Measures of effect are measurable changes in an
attribute of an assessment endpoint (or its surrogate, as
discussed below) in response to a stressor to which it is
exposed (USEPA 1998b). For ERAs, they generally
consisted of acute and chronic toxicity data (from
pesticide registration documents and from the available
scientific literature) for the most appropriate surrogate
species.
Because the BLM uses herbicides in a variety of
programs with several different application methods, the
following exposure scenarios were considered to assess
the potential ecological impacts of herbicides to fish and
other aquatic organisms under a variety of uses and
conditions:
• Direct spray of the receptor or water body.
• Off-site drift of spray to terrestrial areas and
water bodies.
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ENVIRONMENTAL CONSEQUENCES
• Surface runoff from the application area to off¬
site soils or water bodies.
• Wind erosion resulting in deposition of
contaminated dust into water bodies.
• Accidental spills to water bodies.
Direct spray scenarios considered both a pond (1/4 acre,
1 meter [3.3 feet] deep) and a stream (representative of
Pacific Northwest low-order streams that provide
habitat for critical life stages of anadromous salmonids).
Accidental spill scenarios were limited to a pond, which
represents a worst-case scenario for a spill into an
aquatic habitat.
The AgDRIFT computer model was used to estimate
off-site herbicide transport due to spray drift. The
GLEAMS computer model was used to estimate off-site
transport of herbicides in surface runoff and root zone
groundwater transport. The CALPUFF computer model
was used to predict the transport and deposition of
herbicides sorbed (i.e., reversibly or temporarily
attached) to wind-blown dust. Each model simulation
was approached with the intent of predicting the
maximum potential herbicide concentration that could
result from the given exposure scenario.
Toxicological data for aquatic organisms were
extrapolated from data for representative or surrogate
species. Data describing both acute and chronic effects
were used to generate RQs for addressing potential risks
to aquatic receptors (see the ERAs [AECOM 2014a,b;
AECOM 2015] or the 2007 PEIS [USDOl BLM
2007a:4-100] for additional discussion of these
calculations). In order to address potential risks to these
receptors from exposure to the herbicides, RQs were
compared to LOCs defined by the USEPA for screening
the potential risk of pesticides. Distinct USEPA LOCs
were used for acute and chronic risks, and for potential
increased risks to special status species. For non special
status fish and aquatic invertebrates, LOCs were 0.5 for
acute high risk, and 1 for chronic risk. Wherever the RQ
exceeded the applicable LOCs, it was assumed that
adverse toxicological effects to the group in question
(fish or invertebrates) could occur. Corresponding levels
of risk (none, low, medium, or high) were obtained by
determining the factor by which the RQ exceeded the
LOC, and the number of modeled scenarios in which an
exceedance occurred.
Adjuvants, Degradates, Inert Ingredients, and Tank
Mixes
Adjuvants
The potential risks to aquatic organisms from adjuvants
were raised as a concern during the 2007 PEIS process.
Adjuvants generally function to enhance or prolong the
activity of an active ingredient, and are not under the
same registration guidelines as pesticides. In general,
adjuvants comprise a relatively small portion of the
volume of herbicide applied. Adjuvants listed for use
with the three new herbicides include the following:
• Aminopyralid - a nonionic surfactant.
• Fluroxypyr - a methylated seed oil surfactant.
• Rimsulfuron - several types of spray adjuvants
(e.g., nonionic surfactant, petroleum crop oil
concentrate, modified seed oil, ammonium
nitrogen fertilizer, and combination adjuvant
products).
The BLM reviewed toxicity data for these adjuvants to
assess risks to aquatic life. In addition, the GLEAMS
model was used in the ERAs to estimate the potential
portion of an adjuvant that might reach an adjacent
water body via surface runoff.
Degradates
It was beyond the scope of the ERAs to evaluate all of
the possible degradates of the herbicide formulations
being considered in this PEIS. Degradates may be more
or less mobile and more or less toxic in the environment
than their source herbicides (Battaglin et al. 2003).
Differences in environmental behavior (e.g., mobility)
and toxicity between parent herbicides and degradates
makes prediction of potential impacts challenging. For
example, a less toxic, but more mobile bioaccumulative,
or persistent degradate may have a greater adverse
impact due to residual concentrations in the
environment. The lack of data on the toxicity of
degradates of the specific herbicides represents a source
of uncertainty in the risk assessment.
This PEIS relies on information obtained during
preparation of the 2007 PEIS to determine the likely
effects of degradates on aquatic organisms. The BLM
conducted studies to evaluate information on degradates
and try to determine if it is likely for degradates to be
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ENVIRONMENTAL CONSEQUENCES
more toxic than the parent compounds (active
ingredients; see Appendix D of the 2007 PEIS).
Inert Ingredients
The BLM reviewed confidential information on inert
compounds used in herbicide formulations with
aminopyralid, fluroxypyr, and rimsulfuron.
Additionally, the ERAs used the GLEAMS model to
simulate the effects of a generalized inert compound in
a base-case watershed (annual precipitation rate of 50
inches per year, application area of 10 acres, slope of
0.05, surface roughness of 0.015, erodibility of 0.401
tons per acre, vegetation type of “weeds”) with a sand
soil type (see Appendix D of the ERAs; AECOM
2014a,b; AECOM 2015).
Tank Mixes
The ERAs for aminopyralid, fluroxypyr, and
rimsulfuron did not include a quantitative evaluation of
potential tank mixes for these active ingredients.
Therefore, information on simulations of tank mixes in
risk assessments completed for the 2007 PEIS were
used as guidance for determining how risks to aquatic
organisms may change when a tank mix is used, as
compared to the active ingredient alone. Aquatic
organisms may be at greater risk from the mixed
application than from the active ingredient alone.
Typical tank mixes of the three herbicides are discussed
in Chapter 2 of this PEIS.
Summary of Herbicide Impacts
The general impacts to fish and other aquatic organisms
as a result of herbicide treatments are discussed in the
2007 PEIS (USDOI BLM 2007a:4-80). Herbicides may
come into contact with fish and aquatic invertebrates by
entering a water body, with potential impacts that
include mortality, reduced productivity, abnormal
growth, and alteration of critical habitat. Factors that
influence an herbicide’s risk to aquatic organisms
include size of aquatic buffers, application rate,
application method, precipitation rate, soil type, and
herbicide mobility and persistence.
All herbicides pose some risk to non-target terrestrial
and aquatic plants. These risks should be considered, as
damage to riparian and aquatic plants may affect fish
and aquatic invertebrates. Potential effects from
vegetation removal in riparian areas include loss of
necessary habitat components (i.e., cover and food),
increased sedimentation into aquatic habitats, altered
nutrient dynamics, and increased water temperature due
to a reduction in shade. The sections on Vegetation and
Wetlands and Riparian Areas in this chapter discuss
these risks, as well as herbicide application practices
that can be used to reduce risk.
Based on the likely use of the three new active
ingredients, wide-scale removal of riparian vegetation is
unlikely to occur. Out of the three, fluroxypyr and
rimsulfuron would typically not be used near water,
except possibly for spot treatments of certain target
species. Aminopyralid would be used in riparian
treatments for selective removal of certain species (e.g.,
knapweeds), but extensive removal of riparian
vegetation would be unlikely. Additionally,
aminopyralid would provide an alternative to
glyphosate, which is less selective and more likely to
result in removal of non-target vegetation.
The BLM’s land management goals include restoring
and enhancing fish habitat, and restoring and
maintaining proper functioning condition of riparian
and wetland areas. Vegetation treatment programs in
these areas include herbicide treatments to remove
noxious weeds and other invasive species from these
areas. Such treatments, as part of an overall habitat
improvement program, would be expected to have a
beneficial effect on fish and other aquatic organisms by
improving stream/aquatic habitat conditions and
restoring important riparian habitat components for
juvenile fish growth, development, and survival, such as
streambank structure and complexity, habitat
complexity, and water quality (Groot and Margolis
1991).
Impacts of Aminopyralid
Aminopyralid is not currently registered for aquatic
uses, although it may receive an aquatic registration in
the near future that would address incidental overspray
of aquatic areas during treatment of adjacent upland
areas. Even with this registration, aminopyralid would
not be used to manage aquatic vegetation, and would
not be applied directly to the water column like other
aquatic herbicides.
The ERA for aminopyralid indicates that this herbicide
would not pose a risk to fish or aquatic invertebrates in
ponds or streams as a result of any of the modeled
exposure scenarios (Table 4-10). The ERA included a
direct spray scenario and a worst-case scenario
involving a spill of the active ingredient into the aquatic
habitat, as well as off-site drift and surface runoff
scenarios.
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ENVIRONMENTAL CONSEQUENCES
TABLE 4-10
Risk Categories Used to Describe Herbicide Effects on Non Special Status
Fish and Aquatic Invertebrates According to Exposure Scenario
Application Scenario
Aminopyralid
Fluroxypyr
Rimsulfuron
Typ1
Max1
Typ
Max
Typ
Max
Direct Spray/Spill
Fish pond
02
[2:21
0
[4:41
0
[2:21
0
[4:41
0
[2:21
0
[4:41
Fish stream
0
[2:21
0
[2:21
0
[2:21
0
[2:21
0
[2:2]
0
[2:21
Aquatic invertebrates pond
0
[2:21
0
[4:41
0
[2:21
0
[4:41
r —i
o
0
[4:41
Aquatic invertebrates stream
0
[2:21
0
[2:2]
0
[2:2]
0
[2:2]
0
[2:2]
0
[2:2]
Off-Site Drift
Fish pond
0
[36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:361
Fish stream
0
[36:361
0
[36:361
0
[36:36]
0
[36:361
0
[36:361
0
[36:361
Aquatic invertebrates pond
0
[36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:36]
Aquatic invertebrates stream
0
[36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:36]
Surface Runoff
Fish pond
0
[84:841
0
[84:841
0
[84:84]
0
[84:841
0
[84:841
0
[84:841
Fish stream
0
[84:841
0
[84:841
0
[84:841
0
[84:84]
0
[84:841
0
[84:84]
Aquatic invertebrates pond
0
[84:841
0
[84:841
0
[84:841
0
[84:84]
0
[84:841
0
[84:841
Aquatic invertebrates stream
0
[84:841
0
[84:84]
0
[84:841
0
[84:841
0
[84:841
0
[84:841
1 Typ = Typical application rate; and Max = Maximum application rate.
2 Risk categories: 0 = No risk (majority of RQs < applicable LOC for non special status species). The Risk Category is based on the risk level of the
majority of risk quotients observed in any of the scenarios for a given exposure group and receptor type. The reader should consult the risk tables in
Chapter 4 of the ERAs (AECOM 2014a,b; AECOM 2015) to determine the specific scenarios that result in the displayed level of risk for a given receptor
group
Based on toxicity data reviewed for the ERA,
aminopyralid exposures to fish of as high as 100 ppm
did not result in any observable mortality or sub-lethal
effects. Additionally, the ERA indicates that
aminopyralid is not likely to accumulate in fish tissue.
Toxicity data for aquatic invertebrates was similar, with
no adverse effects observed at concentrations of nearly
100 ppm.
Impacts of Fluroxypyr
Fluroxypyr is not registered for use in aquatic systems.
Therefore, routes for exposure to aquatic organisms
would be limited to accidental direct spray through a
misapplication or an accidental spill, or through off-site
drift or surface runoff. The SOPs and guidelines listed
in the 2007 PEIS and discussed in Chapter 2 of this
document would minimize the risks for misapplications
or accidental spills into aquatic habitats. Relevant SOPs
include preparing a spill contingency plan in advance of
treatments, mixing and loading herbicide products in an
area where an accidental spill would not reach a water
body, not rinsing spray tanks in or near water bodies,
following product labels for use and storage, and having
licensed applicators apply the herbicides.
The ERA for fluroxypyr indicates that this herbicide
would not pose a risk to non special status fish or
aquatic invertebrates in ponds or streams under any of
the modeled exposure scenarios (Table 4-10). The ERA
included a direct spray scenario and a worst-case
scenario involving a spill of the active ingredient into
the aquatic habitat, as well as off-site drift and surface
runoff scenarios.
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Based on toxicity data presented in the ERA, no effects
to fish were observed after exposure to fluroxypyr at
concentrations of approximately 7 milligrams per liter
(mg/L). The ERA also indicated that based on the
literature, fluroxypyr may accumulate in fish tissue.
Toxicity data for aquatic invertebrates indicated that no
adverse effects were observed at concentrations of 56
mg/L. While the ERA considered freshwater species as
surrogates, information from the USEPA (1998a)
indicates that the acid form of fluroxypyr is highly toxic
to certain marine invertebrates.
Impacts of Rimsulfuron
Rimsulfuron is not registered for use in aquatic systems.
Therefore, possible routes for exposure to aquatic
organisms would be the same as those for fluroxypyr:
accidental direct spray or spill, off-site drift, or surface
runoff. The SOPs and guidelines discussed in the
previous section for fluroxypyr would help prevent and
control spills and other releases into aquatic habitats.
Based on the results of the ERA, none of the modeled
exposure scenarios were associated with risks to fish or
aquatic invertebrates in streams or ponds, even under
the worst case accidental spill scenarios (Table 4-10).
Based on toxicity data reviewed for the ERA, exposures
to concentrations of rimsulfuron as high as 390 mg/L
does not result in adverse effects to fish, although the
potential for chronic effects is not known. Additionally,
the ERA indicates that rimsulfuron is not likely to
accumulate in fish tissue. Lower concentrations of the
herbicide were noted to cause adverse effects to aquatic
invertebrates, with test organisms affected at 50 mg/L of
rimsulfuron.
Impacts of Adjuvants, Degradates, Inert
Ingredients, and Tank Mixes
Adjuvants
The findings of analysis of adjuvants in the ERA
indicate that there is no risk to aquatic organisms
associated with the adjuvant identified for aminopyralid,
and very low risks associated with adjuvants identified
for fluroxypyr and rimsulfuron. The methylated seed oil
identified for fluroxypyr may be a concern under spill
and long-term exposure scenarios, neither of which are
likely under the proposed treatment programs. An
inert/adjuvant compound identified for rimsulfuron
could potentially cause behavioral and physiological
effects at very high exposure scenarios, which are also
unlikely.
When selecting adjuvants, BLM land managers must
follow all label instructions and abide by any warnings.
In general, adjuvants compose a relatively small portion
of the volume of herbicide applied. Nonetheless,
selection of adjuvants with limited toxicity and low
volumes is recommended for applications near aquatic
habitats to reduce the potential for the adjuvant to
influence the toxicity of the herbicide.
Degradates
Based on the analysis of degradates in the 2007 PEIS,
previous studies have determined that degradates are
often not identified or named in registration documents
and their physical and chemical attributes are often
poorly understood. The ERAs completed for
aminopyralid, fluroxypyr, and rimsulfuron factored in
the lack of data on the toxicity of degradates as a source
of uncertainty in the risk assessment process. Numerous
degradates of other herbicides have a similar or reduced
toxicity to the parent herbicide, but some may be more
toxic than the parent herbicide (Sinclair and Boxall
2003).
Inert Ingredients
As a result of the BLM’s review of confidential
information on inert compounds, it was found that all of
the inert ingredients identified in the formulations were
classified as approved for “food and nonfood use,”
which means that they are approved for use in pesticide
products applied to food.
The ERAs determined that inert ingredients associated
with aminopyralid, fluroxypyr, and rimsulfuron are not
predicted to occur at levels that would cause acute
toxicity to aquatic life. It is assumed that toxic inert
ingredients would not represent a substantial percentage
of the herbicide, and that minimal impacts to aquatic
habitats would result from these ingredients.
Tank Mixes
Use of tank mixes can result in changes to the toxic
effects of herbicides in the mixture. Herbicide
interactions can be additive, synergistic, or antagonistic,
and the mixture may have more or less toxicity than any
of the individual products. Based on simulations of tank
mixes in risk assessments completed for the 2007 PEIS,
aquatic organisms may be at greater risk from
applications of a mix of active ingredients than from use
of a single active ingredient alone. There is some
uncertainty in this evaluation because herbicides in tank
mixes may not interact in an additive manner. Thus, the
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ENVIRONMENTAL CONSEQUENCES
evaluation may overestimate risk if the interaction is
antagonistic, or it may underestimate risk if the
interaction is synergistic. In addition, other products
may also be included in tank mixes that may contribute
to the potential risk.
To reduce the potential for adverse impacts to aquatic
organisms, BLM land managers must follow all label
instructions and abide by any warnings. Labels for both
tank mixed products should be thoroughly reviewed,
and mixtures with the least potential for negative effects
should be selected, particularly when a mixture is
applied in a manner that increases the potential for risk
to nearby aquatic organisms.
Impacts by Alternative
The BLM proposes to treat riparian vegetation with the
three new herbicides to improve habitat for fish and
aquatic organisms on public lands. However, herbicide
treatments can also lead to the harm or even death of
fish and aquatic organisms. The following discusses the
habitat benefits and health risks to fish and aquatic
organisms under each alternative.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue its ongoing vegetation treatments programs in
the 17 western states with the 18 currently approved
active ingredients. Approximately 932,000 acres would
be treated annually, with approximately 10,000 acres of
aquatic and riparian habitat treated.
The potential impacts to fish and other aquatic species
under this alternative are discussed in the 2007 PEIS
(USDOI BLM 2007a:4-90 to 4-91). Use of herbicides
would result in some toxicological impacts to fish, with
long-term beneficial effects to fish through
improvements to aquatic and riparian areas through
removal of invasive species from these habitats.
The greatest risks to fish and other aquatic organisms
would be associated with the use of diquat, triclopyr,
and certain (non-aquatic) formulations of 2,4-D and
glyphosate. However, many of the currently approved
herbicides would have some level of risk to aquatic
organisms under spill and accidental direct spray
exposure scenarios. Buffer distances specified in the
2007 PEIS would continue to be applied to herbicide
treatments to protect aquatic species, and SOPs for
mixing, handling, transporting, and applying herbicides
would continue to be implemented to minimize the
likelihood of accidental spills and direct spray into
aquatic habitats.
The currently approved herbicides include active
ingredients that would continue to be used to manage
invasive aquatic plant species such as Eurasian
watermilfoil and water-thyme, species that alter riparian
habitats such as common reed, saltcedar, and Japanese
knotweed, and rangeland species that increase the risk
of fire and associated sedimentation into aquatic
habitats, such as cheatgrass. Treatment programs to
improve riparian and aquatic habitats would continue
under the No Action Alternative, which would be
expected to benefit fish and other aquatic species.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under the Preferred Alternative, the amount of
herbicide treatment on BLM-administered lands would
be the same as under the No Action Alternative, but
treatments could include use of aminopyralid,
fluroxypyr, and rimsulfuron. The projected acreage of
aquatic and riparian habitat treated annually with
herbicides would also be the same as under the No
Action Alternative, estimated at 10,000 acres.
As discussed previously, of the three new active
ingredients none would be applied directly to the water
column, although aminopyralid is likely to receive a
registration that would allow for incidental overspray
into aquatic habitats. None of the herbicides would be
used to treat invasive aquatic plant species, but
aminopyralid would be used in riparian treatments for
selective removal of invasive riparian and wetland
species. Fluroxypyr and rimsulfuron would most likely
be used for spot treatments of certain target species.
Given that the three new herbicides have no risk to
aquatic species (Table 4-10), their use in the BLM’s
vegetation management programs would be unlikely to
have an adverse effect on aquatic species, and could
result in a benefit to these species if they were used
instead of active ingredients with more toxicological
risk. As shown in Table 2-4, use of glyphosate,
imazapic, and picloram would decrease by the greatest
amount under this alternative. Of these, picloram and
glyphosate both have a substantially greater
toxicological risk to aquatic organisms than the three
new active ingredients. Therefore, it is possible that
aquatic organisms would be exposed to lower quantities
of more harmful chemicals under this alternative.
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ENVIRONMENTAL CONSEQUENCES
As far as benefits to aquatic species through habitat
improvements, effects under this alternative would be
much the same as under the No Action Alternative.
Invasive aquatic species would continue to be treated
with the same chemicals as at present. The three new
herbicides would be used in riparian and upland areas to
target largely the same species as under the No Action
Alternative.
Alternative C - No Aerial Application of New
Herbicides
Nearly all (98 percent) of the targeted aquatic and
riparian habitats are treated using ground-based
methods. Therefore, prohibiting aerial applications of
the three new herbicides under this alternative would
have a minimal effect on the BLM’s use of chemicals in
and around these habitats, relative to the Preferred
Alternative. Additionally, benefits to aquatic species
from removal of invasive species in aquatic and riparian
habitats would be similar to those under the other
alternatives.
The projected breakdown of herbicides used would be
slightly different than under the No Action and
Preferred Alternatives. Use of glyphosate would
decrease relative to the No Action Alternative, but not
as much as under the Preferred Alternative. Use of
picloram would be only slightly lower than under the
No Action Alternative. Therefore, there could be a
minor benefit to aquatic organisms through a reduction
in toxicological risks associated with the use of
glyphosate.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under Alternative D, aminopyralid and fluroxypyr
would be added to the list of approved active
ingredients, but rimsulfuron would not. As
rimsulfuron’s use near aquatic habitats would be
minimal under the other action alternatives, banning its
use would have very little effect on treatment programs
that affect habitats used by fish and other aquatic
species. Similar to the other action alternatives,
aminopyralid would be used near aquatic habitats for
treatment of undesirable wetland and riparian plants that
can impact fish and other aquatic organisms.
Rimsulfuron would not be used as an option for treating
cheatgrass under this alternative, but imazapic would
continue to be used to manage this species to reduce fire
risk and prevent fire-related sedimentation into aquatic
habitats. As both imazapic and rimsulfuron pose a very
low risk to aquatic species, there would be little
difference between Alternative D and the other action
alternatives as far as toxicological risks. The breakdown
of herbicide use under this alternative would be similar
to the No Action Alternative, with only a slight decrease
in the use of most active ingredients resulting from the
addition of aminopyralid and fluroxypyr. The greatest
decrease relative to the No Action Alternative would be
in the use of metsulfuron methyl (3 percent), which has
a low risk to aquatic species.
Mitigation for Herbicide Treatment
Impacts
In order to protect non special status fish and aquatic
invertebrates from potential toxicological effects
associated with herbicide treatments, the BLM would
continue to follow all applicable minimum buffer
distances for aquatic habitats, as well as all SOPs for
transport, handling, and application of herbicides. The
mitigation measures specified in the 2007 PEIS
(USDOI BLM 2007a:4-92) would also apply to
treatments involving the new herbicides, including
applications of tank mixes that include the currently
approved herbicides.
Based on the results of ERAs, no additional buffers or
other mitigation measures specific to aminopyralid,
fluroxypyr, or rimsulfuron are warranted.
Special Status Fish and Other
Aquatic Organisms
Introduction
As discussed in Chapter 3, BLM lands in the western
U.S. support numerous aquatic animals that have been
given a special status based on their rarity or sensitivity.
Included are fish, mollusks, and aquatic arthropods that
are federally-listed as threatened or endangered, or are
proposed for federal listing. The Vegetation Treatments
Using Aminopyralid, Fluroxypyr, and Rimsulfuron on
Bureau of Land Management Lands in 17 Western
States Programmatic Biological Assessment (USDOI
BLM 2015) provides a description of the distribution,
life history, and current threats of each federally listed
aquatic species that could potentially be affected by the
BLM’s herbicide treatment programs, as well as species
proposed for listing.
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ENVIRONMENTAL CONSEQUENCES
Impacts Assessment Methodology
Assessment of impacts to sensitive aquatic animal
species followed the same general methodology that
was developed for the 2007 PEIS (USDOI BLM
2007a:4-92 to 4-94). This methodology entailed
following the protocol for completing ERAs that was
developed with input from the USFWS, NMFS, and
USEPA (ENSR 2004). The ERA methods for assessing
impacts to aquatic organisms in general are summarized
earlier in this section. To complete the ERA, a more
conservative LOC of 0.05 (compared to an LOC of 0.5
for non special status species) was used to determine
acute risks to special status fish and aquatic
invertebrates. A more conservative LOC of 0.5
(compared to 1 for non special status species) was used
to determine chronic risks.
Corresponding levels of risk (none, low, medium, or
high) were obtained by determining the factor by which
the RQ exceeded the LOC, and the number of modeled
scenarios in which an exceedance occurred.
The results of the ERA analysis for two groups of
aquatic organisms — special status fish and aquatic
invertebrates — were used to determine the potential
impacts to sensitive aquatic species, which are
presented in the BA (USDOI BLM 2015). The analysis
presented here incorporates the findings of the BA, and
presents a comparison of the alternatives.
Summary of Herbicide Effects to
Special Status Fish and Aquatic
Invertebrates
A summary of the general effects of herbicide
treatments on sensitive fish species and populations is
presented in the 2007 PEIS (USDOI BLM 2007a:4-93
to 4-94). While the general toxicological risks to
individual organisms of sensitive species would be the
same as those predicted for non special status fish
species, which were described earlier in this chapter, the
associated population- and species-level effects could
be much greater for many sensitive species because of
their limited/fragmented distribution and limited
population size.
In general, risks to special status fish and aquatic
invertebrates from herbicide treatments would be
minimized by following applicable SOPs, which
include the following:
• Survey for special status fish and aquatic
invertebrate species before treating an area.
Consider effects to special status species when
designing herbicide treatment programs.
• Use drift reduction agents to reduce the risk of
drift hazard.
• Select herbicide products carefully to minimize
additional impacts from degradates, adjuvants,
inert ingredients, and tank mixtures.
• Maintain appropriate buffer zones between
treatment areas and water bodies with special
status fish and aquatic invertebrates.
• Minimize treatments near water bodies during
periods when fish and aquatic invertebrates are
in the life stage most sensitive to the herbicide
used.
Because the invasion and spread of non-native plant
species in aquatic and riparian habitats affects certain
populations of special status fish and aquatic
invertebrates, herbicide treatments to control these
species would benefit sensitive aquatic organisms by
improving water quality and flow, and increasing
dissolved oxygen. However, for most of the sensitive
fish and other aquatic species analyzed in the BA, the
primary threats to the species are changes in water
levels and quality associated with development, upslope
land use practices, groundwater pumping, and the
expansion of non-native fish populations. For these
species, the potential for water quality impacts
associated with herbicide use may outweigh habitat
improvements resulting from minimized invasive plant
infestations.
The typical risk levels for special status aquatic animals
associated with applications of the three new herbicides
are presented in Table 4-11. As shown in the table, the
risk level for all of the active ingredients are shown as 0,
or “no risk,” which means that the majority of risk
quotients are less than the LOC used for special status
species. In the case of aminopyralid and rimsulfuron, no
risks to sensitive fish and aquatic invertebrates were
predicted under any of the modeled scenarios. In the
case of fluroxypyr, there would be no risks associated
with accidental direct spray of the active ingredient, but
there would be a low risk to special status fish
associated with a truck or helicopter spill of the active
ingredient. Special status aquatic invertebrates could be
at risk from a helicopter spill of fluroxypyr.
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ENVIRONMENTAL CONSEQUENCES
TABLE 4-1 1
Risk Categories Used to Describe Herbicide Effects on Special Status
Fish and Aquatic Invertebrates According to Exposure Scenario
Application Scenario
Aminopyralid
Fluroxypyr
Rimsulfuron
Typ1
Max'
Typ
Max
Typ
Max
Direct Spray/Spill
Fish pond
03
12:21
0
[4:4]
0
[2:21
0
[2:4]
0
[2:2]
0
[4:4]
Fish stream
0
12:21
0
[2:21
0
[2:21
0
[2:2]
0
[2:21
0
[2:21
Aquatic invertebrates pond
0
12:21
0
[4:41
0
[2:21
0
[3:4|
0
[2:21
0
|4:4|
Aquatic invertebrates stream
0
[2:21
0
[2:21
0
[2:21
0
[2:21
0
[2:21
0
[2:21
Off-Site Drift
Fish pond
0
|36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:36|
Fish stream
0
[36:361
0
[36:361
0
[36:361
0
[36:36]
0
[36:361
0
|36:361
Aquatic invertebrates pond
0
|36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:361
0
[36:361
Aquatic invertebrates stream
0
|36:361
0
[36:36]
0
[36:361
0
[36:36|
0
[36:361
0
|36:36]
Surface Runoff
Fish pond
0
184:84|
0
[84:841
0
[84:84J
0
[84:84 1
0
[84:841
0
1 84:84]
Fish stream
0
1 84:84 1
0
1 84:84 1
0
[84:841
0
[84:841
0
[84:841
0
|84:841
Aquatic invertebrates pond
0
[84:841
0
184:841
0
[84:841
0
184:84)
0
[84:841
0
(84:84|
Aquatic invertebrates stream
0
[ 84:84 1
0
1 84:84 1
0
|84:841
0
1 84:84 1
0
[84:841
0
184:841
1 Typ = Typical application rate; and Max = Maximum application rate.
2 Risk categories: 0 = No risk (majority of RQs < most conservative LOC for special status species). The Risk Category is based on the risk level of the
majority of risk quotients observed in any of the scenarios for a given exposure group and receptor type. For some “no risk” exposure groups, RQs for
one or more scenarios exceeded the applicable LOC. The reader should consult the risk tables in Chapter 4 of the ERAs (AECOM 2014a,b; AECOM
2015) to determine the specific scenarios that result in the displayed level of risk for a given rcceptor^rou£_
The BLM’s SOPs would minimize the risks of spills
into aquatic habitats. Relevant SOPs include preparing a
spill contingency plan in advance of treatments, mixing
and loading herbicide products in an area where an
accidental spill would not reach a water body, not
rinsing spray tanks in or near water bodies, following
product labels for use and storage, and requiring
licensed applicators to apply the herbicides. Project
design criteria also require the BLM to consider
sensitive species that occur near potential treatment
areas when developing site-specific vegetation
treatment programs.
Impacts by Alternative
For the most part, the comparison of alternatives for
special status fish and aquatic invertebrates is similar to
that for all aquatic animals, which was presented earlier
in this section. While risk levels associated with
fluroxypyr are slightly higher for special status species
than for non special status species, fluroxypyr
treatments would make up only 1 percent or less of total
herbicide use (across all habitat types; see Table 2-4)
under all alternatives.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under this alternative, the BLM would continue its
vegetation treatment programs at current levels and with
currently approved herbicides, with approximately
10,000 acres of aquatic and riparian habitats targeted for
herbicide treatments annually. Programs would likely
continue to include habitat restoration components that
BLM Vegetation Treatments Three New Herbicides
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ENVIRONMENTAL CONSEQUENCES
are specifically designed to improve habitat for sensitive
species. Use of herbicides may be included in these
programs.
Under this alternative, there would be some risk to
sensitive aquatic species from use of herbicides,
particularly the more toxic formulations, such as
glyphosate.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, the goals of vegetation treatment
programs would be the same as under the No Action
Alternative, including treatments that target restoration
and improvement of special status aquatic species
habitats. The total acreage of aquatic and riparian
habitat treated annually would also be the same as under
the No Action Alternative.
The 2007 PEIS indicates that the currently approved
active ingredients with the greatest likelihood of
impacting special status aquatic animals are diuron,
picloram, and the more toxic formulation of glyphosate.
With the addition of aminopyralid, fluroxypyr, and
rimsulfuron under this alternative, use of glyphosate and
picloram would decrease. Use of diuron would also
decrease, but to a lesser degree (Table 2-4). Together,
use of these three active ingredients would decrease by
12 to 13 percent. Therefore, overall risks to aquatic
special status species would potentially be lower than
under the No Action Alternative.
Alternative C - No Aerial Application of New
Herbicides
Since few aerial applications target aquatic and riparian
areas, this alternative is likely to be similar to
Alternative B as far as benefits to aquatic habitats and
risks to sensitive aquatic species. The three herbicides
of concern (glyphosate, picloram, and diuron) would
decrease by 5 to 6 percent. Therefore, there could be
some reduced toxicological risk to special status aquatic
species relative to the No Action Alternative, but
potentially less than under the Preferred Alternative.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Since rimsulfuron is not used extensively near aquatic
habitats, prohibition of its use under this alternative
would have little effect as far as impacts to special
status aquatic species. Decrease in the use of
glyphosate, picloram, and diuron would be 5 to 6
percent under this alternative. Therefore the potential
for reduced risk to special status aquatic species would
be similar to that under Alternative C, and potentially
less than under the Preferred Alternative.
Mitigation for Herbicide Treatment
Impacts
Mitigation to reduce the likelihood of impacts to special
status fish and other aquatic species, as included in the
ROD for the 2007 PEIS, would continue to be
implemented, as would all SOPs and mitigation
presented earlier in this section. These measures would
be applied to the three new herbicides, as relevant. The
Biological Assessment for Vegetation Treatments Using
Aminopyralid, Fluroxypyr, and Rimsulfuron on Bureau
of Land Management Lands in 17 Western States
determined that given the low toxicity of the three new
herbicides to aquatic special status species, likely uses
of the herbicides, and SOPs for minimizing the risks for
spills into aquatic habitats, no new conservation
measures were necessary for herbicide treatments using
aminopyralid, fluroxypyr, or rimsulfuron (USDOI BLM
2015). However, in order to ensure that the BLM
references the most recent BA, the following mitigation
measure has been developed:
• To protect special status fish and other aquatic
organisms, implement all conservation
measures for aquatic animals presented in the
Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and Rimsulfuron on Bureau of
Land Management Lands in 1 7 Western States
Biological Assessment^ USDOI BLM 2015).
Wildlife Resources
Introduction
Public lands sustain an abundance and diversity of
wildlife resources. Over 3,000 species of wildlife occur
on public lands, and are dispersed over ecologically
diverse and essential wildlife habitats. Public lands are
vital to big game, upland game, waterfowl, shorebirds,
songbirds, raptors, and hundreds of species of non-game
mammals, reptiles, and amphibians (USDOI BLM
2012a).
The BLM manages vegetation to improve wildlife
habitat— areas where basic needs such as food, shelter.
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ENVIRONMENTAL CONSEQUENCES
water, reproduction, and movement are met. Plants are
an important component of habitat, providing food and
cover for wildlife. Food is a source of nutrients and
energy, while good cover prevents the loss of energy by
providing shelter from extremes in wind and
temperature. Cover also affords protection from
predators. Areas that have been impacted by invasive
plants may support fewer native wildlife species than
areas with intact native plant communities (Germano et.
al. 2001). The important characteristics of wildlife
habitat in the eight ecoregions that comprise the
treatment area are presented in the 2007 PEIS (USDOI
BLM 2007a:3-36 to 3-43). Invasive plants can change
habitat conditions by altering the structure of plant
communities, creating conditions that are unfavorable
for native wildlife species. For example, in an area
dominated by cheatgrass, fires are high in frequency and
have fewer unbumed patches than in native
communities, and can result in the loss of plant species
that provide value for habitat, such as certain types of
sagebrush (Miller et al. 2011). Areas dominated by
invasive plants may also become less suitable for
animal species that have co-evolved with native plant
community types (Olson 1999b).
This section begins with an assessment of risks to
general wildlife, including insects, birds, and small and
large mammals, and is followed by an assessment of
risks to special status wildlife species. Initial discussion
in this section focuses on the risks to wildlife health
from the use of herbicides, followed by an assessment
of the risks and benefits to wildlife from treating
vegetation in each ecoregion using the three new active
ingredients, followed by an assessment of impacts to
wildlife under each alternative.
Scoping Comments and Other Issues
Evaluated in the Assessment
Most scoping comments pertaining to wildlife resources
addressed the benefits to wildlife from using one or
more of the three new active ingredients. Respondents
stated that these herbicides have lower toxicity to
wildlife than some of the herbicides currently being
used. They also noted that these herbicides could be
used to control noxious weeds and invasive species that
alter habitats used by threatened and endangered
wildlife species. In particular, one comment addressed
the use of rimsulfuron to control cheatgrass in order to
maintain viable habitat for sage-grouse and other shrub-
steppe species.
The BLM also received a scoping comment requesting
that the PEIS address potential sub-lethal effects to
wildlife from the herbicides, reduced breeding/survival
of sensitive species, secondary cumulative effects, and
other unintended effects.
Standard Operating Procedures
The 2007 PEIS identified SOPs that minimize risks to
wildlife from herbicide applications on public lands.
These general procedures are designed to reduce the
risk of unintended impacts to wildlife, and were taken
into consideration when evaluating risks to wildlife
from use of aminopyralid, fluroxypyr, and rimsulfuron:
• Use herbicides of low toxicity to wildlife.
• Use spot applications or low-boom broadcast
applications, where possible, to limit the
probability of contaminating non-target food
and water sources, especially vegetation over
areas larger than the treatment area.
• Conduct pre-treatment surveys for sensitive
habitat and special status species within or
adjacent to proposed treatment areas.
• Use timing restrictions (e.g., do not treat during
critical wildlife breeding or staging periods) to
minimize impacts to wildlife.
The 2007 PEIS also included several SOPs that have
been developed to protect pollinators during herbicide
treatments:
• Complete vegetation treatments seasonally
before pollinator foraging plants bloom.
• Time vegetation treatments to take place when
foraging pollinators are least active both
seasonally and daily.
• Design vegetation treatment projects so that
nectar and pollen sources for important
pollinators and resources are treated in patches
rather than in one single treatment.
• Minimize herbicide application rates. Use
typical rather than maximum application rates
where there are important pollinator resources.
• Maintain herbicide free buffer zones around
patches of important pollinator nectar and
pollen sources.
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ENVIRONMENTAL CONSEQUENCES
• Maintain herbicide free buffer zones around
patches of important pollinator nesting habitat
and hibemacula.
• Make special note of pollinators that have
single host plant species, and minimize
herbicide spraying on those plants (if invasive
species) and their habitats.
A complete list of SOPs can be found in the 2007 PEIS
(USDOl BLM 2007a:Table 2-8). Additional mitigation
that was developed for wildlife resources and
incorporated into the ROD for the 2007 PEIS is specific
to the currently approved herbicides, and therefore is
not repeated here. These measures would be applicable,
however, for tank mixes or formulations that combine
currently approved active ingredients with the new
active ingredients.
Since the release of the 2007 PEIS, the White House
released the National Strategy to Promote the Health of
Honey Bees and Other Pollinators (White House
Pollinator Health Task Force 2015). In this strategy, the
BLM was tasked with taking steps to conserve and
manage pollinators and pollinator habitat on public
lands. Therefore, in addition to the pollinator SOPs
listed in the 2007 PEIS, the BLM would follow
appropriate BMPs for federal lands, as described at
http://www.fs.fed.us/wildfIowers/pollinators/BMPs/doc
uments/PollinatorFriendlyBMPsFederalLandsDRAFTO
5152015.pdf). These include BMPs for pesticide use,
which are similar to the pollinator SOPS listed above, as
well as BMPs for improving pollinator habitat by
removing invasive species, among others. During
NEPA analysis for site-specific herbicide treatment
projects, if impacts to pollinators are expected, the BLM
would describe site-specific prescriptions to prevent
those impacts.
Impacts Assessment Methodology
The methods used to assess impacts to wildlife from the
three new herbicides were the same as the methods
described in the 2007 PEIS (USDOl BLM 2007a:4-99
to 4-100). A brief overview of the risk assessment
process is provided here, with a more detailed
methodology presented in the risk assessments
(AECOM 2014a,b; AECOM 2015).
Risk Assessment Methodology
Wildlife receptors, representing different categories of
terrestrial animal species, were evaluated to determine
the effects of herbicide exposure in terms of certain
assessment endpoints and associated measures of effect.
The assessment endpoint is an expression of the value
that is to be protected. In the case of wildlife,
assessment endpoints include mortality, growth,
reproduction, and other ecologically-important sublethal
processes. These assessment endpoints generally reflect
direct effects on organisms, but indirect effects were
also considered. Measures of effect are measurable
changes in an attribute of an assessment endpoint (or its
surrogate) in response to a stressor to which it is
exposed (USEPA 1998b). For the ERAs, they generally
consisted of acute and chronic toxicity data (from
pesticide registration documents and from the available
scientific literature) for the most appropriate surrogate
species.
Because the BLM uses herbicides in a variety of
programs with several different application methods,
and because a range of wildlife species are found on
public lands, the following exposure scenarios were
considered to assess the potential ecological impacts of
herbicides to wildlife under a variety of uses and
conditions:
Direct spray of terrestrial wildlife:
• Small mammal - 100 percent absorption.
• Pollinating insect - 100 percent absorption.
• Small mammal - 1st order dermal absorption
(absorption occurs over 24 hours, taking into
consideration the potential for some herbicide
to not be absorbed).
Indirect contact with foliage after direct spray:
• Small mammal - 1 00 percent absorption.
• Pollinating insect - 100 percent absorption.
• Small mammal - 1st order dermal absorption.
Ingestion of food items contaminated by direct spray:
• Small mammalian herbivore - acute and
chronic exposure.
• Large mammalian herbivore - acute and
chronic exposure.
• Small avian insectivore - acute and chronic
exposure.
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ENVIRONMENTAL CONSEQUENCES
• Large avian herbivore - acute and chronic
exposure.
• Large mammalian carnivore - acute and
chronic exposure.
These exposure scenarios were considered as the most
plausible routes for acute and chronic (short- and long¬
term) impacts under a variety of conditions. The
selected receptors represent the range of wildlife species
found on public lands, as well as the different feeding
guilds that are present (herbivore, omnivore, and
carnivore).
Exposure scenarios involving off-site drift, surface
runoff, and wind erosion were not modeled for
terrestrial wildlife because the direct spray scenarios
were more conservative than scenarios involving wind
erosion or runoff. Risk from consumption of food
would be much greater if the food item was directly
sprayed by an herbicide than if the herbicide drifted or
was carried by water onto the food item.
Toxicological data for wildlife were extrapolated from
data for representative or surrogate species. Data
describing both acute and chronic effects were used to
generate RQs for addressing potential risks to wildlife
receptors (see the ERAs [AECOM 2014a,b; AECOM
2015] or the 2007 PEIS [USDOl BLM 2007a:4-100] for
additional discussion of these calculations).
In order to address potential risks to wildlife receptors
from exposure to herbicides, RQs were compared to
levels of concern defined by the USEPA for screening
the potential risk of pesticides. Distinct USEPA LOCs
were used for acute and chronic risks, and for potential
increased risks to special status species. For non special
status wildlife, LOCs were 0.5 for acute risk and 1 for
chronic risk. Wherever the RQ exceeded one or more of
these LOCs, it was assumed that adverse toxicological
effects to the wildlife group in question could occur.
Corresponding levels of risk (low, medium, or high)
were obtained by determining the factor by which the
RQ exceeded the LOC.
Summary of Herbicide Impacts
The 2007 PEIS provides a discussion of the general
risks to wildlife from herbicide use (USDOl BLM
2007a:4-101 to 4-102). Possible adverse direct effects
include death, damage to vital organs, change in body
weight, decrease in healthy offspring, and increased
susceptibility to predation. Possible indirect effects
include a reduction in availability of preferred food.
habitat, and breeding areas; decrease in wildlife
population densities within the first year following
application as a result of limited reproduction; habitat
and range disruption (as wildlife may avoid sprayed
areas for several years following treatment), resulting in
changes to territorial boundaries and breeding and
nesting behaviors; and increase in predation of small
mammals due to loss of ground cover (USEPA 1998c).
Habitat modification is often the main risk to wildlife
from herbicide use.
This effects analysis focuses on the effects of the three
active ingredients proposed for use, in terms of
toxicological effects to wildlife, effectiveness at
controlling invasive species and improving habitat, and
potential adverse effects to habitat.
As discussed in the 2007 PEIS, species that reside in an
area year-round and have a small home range (e.g.,
insects, small mammals, and territorial birds) would be
more at risk for adverse effects than more mobile
species. In addition, species feeding on animals that
have been exposed to high levels of herbicide could be
impacted, particularly if the herbicide bioaccumulates in
their systems. Although these scenarios were not
modeled, wildlife could also experience greater impacts
in systems where herbicide transport is more likely,
such as areas where herbicides are aerially sprayed, dry
areas with high winds, or areas where rainfall is high
and soils are porous. Wildlife that inhabit subsurface
areas (e.g., insects and burrowing mammals) may also
be at higher risk if soils are non-porous and herbicides
have high soil-residence times. The degree of
interception by vegetation, which depends on site and
application characteristics, would also affect direct
spray impacts. The impacts of herbicide use on wildlife
would primarily be site- and application-specific, and as
such, site assessments would have to be performed at
the field level, using available impact information, to
determine an herbicide-use strategy that would
minimize impacts to wildlife, particularly in habitats
that support special status species.
Depending on the type of herbicide treatment,
pollinators could benefit from or be adversely affected
by treatments with herbicides. Treatments that remove
non-native species that inhibit the growth of native plant
species utilized by pollinators or limit native forb
diversity would be expected to benefit pollinators. In the
federal guidance document listing pollinator-friendly
BMPs for federal lands, removal of invasive species is
identified as an effective way to increase pollinator
abundance and diversity. However, pollinators that
utilize invasive plant species as food and nectar sources
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ENVIRONMENTAL CONSEQUENCES
could be adversely affected by treatments that target
these species, particularly if- alternative habitat plants
are not available nearby.
Based on risk assessments, aminopyralid, fluroxypyr,
and rimsulfuron generally have very low risk to
wildlife, and the most substantial effects would be
associated with habitat modification.
Impacts of Aminopyralid
Aminopyralid would commonly be used on rangelands
to manage undesirable broadleaf species. Therefore,
wildlife most likely to be exposed to this active
ingredient would include those that inhabit or feed on
grasslands and grass-dominated shrublands, such as
ground-nesting birds, ground-dwelling mammals, and
large mammals that forage in these habitats, such as
deer, elk, and pronghorn.
The risk assessment for aminopyralid predicted that
exposure to this active ingredient would not pose a risk
to terrestrial wildlife (including pollinators) under any
of the modeled exposure scenarios (Table 4-12). Risk
quotients were all below the LOC of 0.5 (acute high
risk). Therefore, exposure of wildlife to this active
ingredient by direct spray, contact with sprayed
vegetation, or ingestion of plant materials or prey items
that have been exposed to this active ingredient is not a
concern from a toxicological perspective.
TABLE 4-12
Risk Categories Used to Describe Herbicide Effects on Non Special Status
Wildlife According to Exposure Scenario
Application Scenario
Amino
jyralid
Fluroxypyr
Rimsulfuron
Typ1
Max'
Typ
Max
Typ
Max
Direct Spray of Terrestrial Wildlife
Small mammal - 1 00% absorption
02
0
0
0
0
0
Pollinating insect - 100% absorption
0
0
0
0
0
0
Small mammal - 1st order dermal adsorption
0
0
0
0
0
0
Indirect Contact with Foliage After Direct Spray
Small mammal - 100% absorption
0
0
0
0
0
0
Pollinating insect - 100% absorption
0
0
0
0
0
0
Small mammal - lsl order dermal absorption
0
0
0
0
0
0
Ingestion of Food Items Contaminated by Direct Spray
Small mammalian herbivore - acute exposure
0
0
0
0
0
0
Small mammalian herbivore - chronic exposure
0
0
0
0
0
0
Large mammalian herbivore - acute exposure
0
0
0
0
0
0
Large mammalian herbivore — chronic exposure
0
0
0
0
0
0
Small avian insectivore - acute exposure
0
0
0
0
0
0
Small avian insectivore -chronic exposure
0
0
0
0
0
0
Large avian herbivore — acute exposure
0
0
0
0
0
0
Large avian herbivore - chronic exposure
0
0
0
0
0
0
Large mammalian carnivore - acute exposure
0
0
0
0
0
0
Large mammalian carnivore - chronic exposure
0
0
0
0
0
0
1 Typ = Typical application rate; and Max = Maximum application rate.
2 Risk categories: 0 = No risk (RQ < applicable LOC for non special status species).
The invasive species targeted by aminopyralid
treatments, such as yellow starthistle, knapweeds,
thistles, and tansy ragwort generally provide minimal
value to wildlife, and are detrimental to wildlife habitat
by forming monocultures that displace native species.
Therefore treatments that target these species should
benefit wildlife by improving habitat. The degree of
benefit would vary by species of wildlife. Elk, for
example, are adversely affected by spotted knapweed
because they prefer the native grasses that it displaces,
while deer are less affected because they eat more
shrubs and other browse (Utah State University 2014).
In grass-dominated habitats, aminopyralid has been
shown to benefit ground-nesting birds and ground¬
dwelling mammals by controlling invasive broadleaf
species while stimulating development of native grass
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ENVIRONMENTAL CONSEQUENCES
species (Green et al. 2011; Halstvedt et al. 2011;
Harrington et al. 2011).
As discussed in the Vegetation section, aminopyralid
poses a risk to non-target native forbs and other
desirable species in treatment areas, and therefore may
have an adverse effect on wildlife habitat. Depending on
the type of wildlife habitat and the size of the treatment
area, temporary loss of herbaceous vegetation could
have a short-term effect on broadleaf vegetation used by
wildlife for food, cover, or nesting. Many native forbs,
for example, provide important forage for wildlife, and
may provide seeds that have higher energy content than
foods provided by grass species (Kansas State
University 1991). Native forbs also provide sources of
pollen and nectar for certain native species of
arthropods, and may serve as larval host plants.
In general, the long-term effects of removing invasive
species from rangelands through aminopyralid
applications would be to benefit native plant
communities, improving wildlife habitat for numerous
species in target areas.
Impacts of Fluroxypyr
Fluroxypyr would be used in very small quantities in the
BLM’s treatment programs, accounting for 1 percent or
less of all herbicide treatment acres annually. Like
aminopyralid, fluroxypyr would be used extensively in
rangeland habitats, often in tank mixes, to manage
invasive plants while maintaining grass forage species.
Wildlife most likely to be exposed to this active
ingredient would include inhabitants of grasslands and
grass-dominated shrublands, including ground-nesting
birds and ground-dwelling mammals. Large mammals
that forage in these habitats would also have the
potential to be impacted. Fluroxypyr would help
manage invasive species that have developed a
resistance to other herbicide active ingredients. Annual
kochia and pricklypear are two of the target rangeland
species identified by the BLM for this active ingredient.
Both of these species provide some value for wildlife.
The risk assessment for fluroxypyr predicted that
exposure to fluroxypyr would not pose a risk to
terrestrial wildlife (including pollinators) under any of
the modeled exposure scenarios (Table 4-12). Risk
quotients were all below the LOC of 0.5 (acute high
risk). Therefore, exposure of wildlife to this active
ingredient by direct spray, contact with sprayed
vegetation, or ingestion of plant materials or prey items
that have been exposed to this active ingredient is not a
concern from a toxicological perspective.
One identified use of fluroxypyr is to control
pricklypear in desert habitats. Pricklypear provides
shelter and food for a wide variety of wildlife species,
including nesting habitat for birds, reptiles, and small
mammals, and cover for northern bobwhite. Its fruits,
seeds, and pads provide food for numerous species,
including white-tailed deer and collared peccaiy'
(Ueckert 1997). Therefore, use of fluroxypyr to control
pricklypear could have adverse impacts to certain
wildlife, depending on the species and the intent of the
treatment.
Impacts of Rimsulfuron
Rimsulfuron could potentially see widespread use on
public lands, depending on which alternative is selected,
primarily for management of cheatgrass, medusahead
rye, and other invasive winter annual grasses. This
active ingredient would be used in a variety of wildlife
habitats currently degraded by invasive plants, including
(but not limited to) grasslands, sagebrush-steppe, and
woodlands. The goals of these treatments would be to
both reduce the cover of the target species and reduce
the risk of future wildfire. Given its widespread use, a
wide variety of wildlife could be exposed to this active
ingredient.
Possible modes of wildlife exposure to rimsulfuron
include direct spray, dermal contact with treated
vegetation, and ingestion of plant materials or prey
items that have been exposed to the active ingredient.
The risk assessment for rimsulfuron predicted that none
of these exposure scenarios would pose a risk to any
type of terrestrial wildlife (including pollinators; Table
4-12). Risk quotients were all below the LOC of 0.5
(acute high risk). Therefore, use of rimsulfuron on
public lands does not present a toxicological concern for
wildlife Because rimsulfuron would often be used to
target large monocultures of cheatgrass and other
invasive species, the short-term result of applications
would likely be loss of vegetation and associated cover
in treatment areas, which may constitute an impact to
key habitat components for wildlife species. These
short-term impacts should be offset by long-term
improvements to habitat if treatment programs
effectively reduce cover of target plant species and
promote the establishment of native plant species. In
some cases, post-treatment rehabilitation may be
required.
While wildlife habitat on public lands has been
adversely affected by displacement of native species by
winter annual grasses, and associated reduced
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productivity, a potentially greater impact to wildlife
habitat is the role of invasive plants in increasing the
frequency and size of wildfires (Johnson and Davies
2012). Species like cheatgrass and medusahead rye
form a dense layer of litter that decomposes slowly and
is highly flammable (Pellant 1996, Johnson and Davies
2012). Therefore, even in situations where these target
species offer some value as forage to wildlife, they
increase the amount of fine fuels, resulting in hot,
frequent wildfires. The invasion of cheatgrass onto the
Intermountain rangelands, for example, has resulted in
destructive wildfires that have negatively impacted
wildlife and grazing resources (Clements et al. 2012;
Clements and Harmon 2013). In addition to directly
harming wildlife and their nests and food sources, and
displacing them from burned habitats, fires can result in
the long-term loss of key wildlife habitat components,
such as big sagebrush.
The BLM currently uses approved active ingredients to
control invasive annual grasses. The addition of
rimsulfuron would offer the BLM more herbicide
options for targeting these invasive species.
Additionally, as discussed previously, there is some
evidence that rimsulfuron may be less harmful to non¬
target species and promote the reestablishment of
desirable native species. Therefore, use of rimsulfuron
would likely provide some level of long-term benefit to
wildlife habitat.
Impacts of Herbicide Treatments on
Wildlife and Habitat by Ecoregion
The 2007 PEIS gives a description of impacts to
wildlife habitat from herbicide treatment programs, by
ecoregion (USDOI BLM 2007a:4-109 to 4-1 14). These
discussions focus on treatment goals in each ecoregion,
and how herbicide treatments to meet those goals could
impact wildlife and their habitat found in each
ecoregion. As the goals of herbicide treatments and the
assumptions of future treatments identified by local
BLM offices during preparation of the 2007 PEIS carry
over to this PEIS, the wildlife impacts by ecoregion are
still applicable and are not repeated here. The discussion
in this section focuses on new information since the
2007 PEIS, and how use of aminopyralid, fluroxypyr,
and rimsulfuron might change the way that herbicide
treatment programs impact wildlife and their habitat in
each ecoregion.
Tundra and Subarctic
Herbicides have not been used on public lands in Alaska
on Arctic tundra or in subarctic forests, and herbicide
treatments were not proposed for these regions as part
of the BLM’s vegetation treatment programs during
preparation of the 2007 PEIS. However, the BLM has
since come out with a Draft Dalton Management Area
Integrated Invasive Plant Strategic Plan (USDOI BLM
2009c), which addresses control of invasive plants
along the Dalton Highway and adjacent BLM-
administered lands, along trails and spur roads, and at
other heavy use areas (e.g., gravel pits, rest stops, mine
sites, and airstrips). The release of this document
indicates that some herbicide treatments are likely to
occur in Alaska over the next 10 years, primarily to stop
the spread of invasive plants from disturbed sites.
Based on the current information, herbicide treatments
(including the currently approved herbicides and the
three new herbicides) would have a minimal effect on
wildlife and their habitat. The proposed uses of
herbicides in these ecoregions are largely localized to
roadsides and other areas subject to ongoing human
disturbance, which are not prime habitat for wildlife
(USDOI BLM 20 1 3i). Furthermore, early control of
new invaders will prevent the spread of these species
into more pristine areas, thereby minimizing the risk of
future impacts to wildlife habitat associated with
noxious weeds and other invasive plant species. A total
of 19 invasive plant species have been targeted for
control in Alaska, including the nitrogen fixers white
sweetclover, alfalfa, bird’s-foot trefoil, and bird vetch,
which could alter ecosystem processes and wildlife
habitat in naturally nitrogen-poor areas.
Temperate Desert
The Temperate Desert Ecoregion would continue to
receive the vast majority of herbicide treatments (an
estimated 71 percent), with the goal of most treatments
to restore lands damaged by fires in the Great Basin,
and to benefit sage-grouse and other wildlife that use
sagebrush communities.
Rimsulfuron, in particular, would be used extensively in
the Temperate Desert Ecoregion, as a tool for
controlling winter annual grasses such as cheatgrass and
medusahead rye. Additionally, aminopyralid and
fluroxypyr would be used, often in tank mixes with
currently approved herbicides, to manage broadleaf
rangeland weeds such as yellow starthistle, knapweeds.
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and annual kochia. Treatments with these herbicides
would benefit a wide range of wildlife through habitat
improvements with long-term goals of restoring native
plant communities and reducing wildfire risk. Multiple
treatments and post-treatment reseeding/restoration of
native species would be necessary to meet these goals.
Wildlife that would benefit from these treatments would
include sage-grouse and shrub-dependent species. There
are roughly 200 species of wildlife in the Great Basin
(USDOI BLM 1999), many of which would likely
benefit from herbicide treatments in the Temperate
Desert Ecoregion.
Subtropical Desert
Treatments in the Subtropical Desert Ecoregion would
continue to make up a small fraction (less than 1
percent) of the planned herbicide treatments. Therefore
use of all herbicides, including the three new herbicides,
would be minimal. Herbicide treatments in this
ecoregion would continue to focus on managing woody
species that have invaded shortgrass and mixed-grass
prairies of the desert Southwest, including species such
as mesquite, creosotebush, and snakeweed. These
treatments benefit grassland-dwelling wildlife, such as
jackrabbits, antelopes, and quail, by removing shrubs
that have invaded these habitats and providing more
open conditions (Germano 1978 cited in USDOI BLM
1991). For species that utilize shrubbier habitats, such as
white-tailed deer, doves, and cottontail (McCormick
1975 cited in USDOI BLM 1991), herbicide treatments
to control invading shrubs could have a negative effect
on habitat.
Neither aminopyralid nor rimsulfuron has activity on
the woody species that would be targeted for
management in the Subtropical Desert ecoregion.
Therefore, these herbicides would have little impact on
wildlife habitat in this ecoregion. Fluroxypyr, however,
provides control of undesirable woody species such as
snakeweed and pricklypear, and could be used in
limited amounts to control these species in the
Subtropical Desert Ecoregion. Only a very small
amount of this active ingredient would likely be used
annually.
Temperate Steppe
Herbicide treatments in the Temperate Steppe
Ecoregion would represent approximately 1 6 percent of
all treated acres. More than three quarters of the
herbicide treatments in this ecoregion would focus on
management of invasive grasses and forbs, including
cheatgrass, leafy spurge, and several species of
knapweeds and thistles. Much of this work would be
done in support of the BLM’s Conservation of Prairie
Grasslands initiative, and would benefit wildlife that
inhabits short- and mixed-grass prairie grasslands, such
as lesser prairie-chicken, mountain plovers, and prairie
dogs.
Rimsulfuron is likely to be applied in wildlife habitat in
this ecoregion because its predominant use would be
control of cheatgrass. Aminopyralid has activity on
knapweeds and thistles, and would provide the BLM
with another option for management of these noxious
weeds that alter the structure and species composition of
prairie grasslands. Fluroxypyr would be used only
minimally, but would be one option for controlling leafy
spurge. While the BLM would be able to manage all of
these invasive species with the currently approved
active ingredients, the availability of aminopyralid
would allow additional herbicide options when
designing treatment programs to benefit wildlife habitat
in the Temperate Steppe Ecoregion.
Subtropical Steppe Ecoregion
Herbicide treatments in the Subtropical Steppe
Ecoregion would account for approximately 9 percent
of all treatment acres. More than three-quarters of the
treatments would occur in sagebrush and other shrub
habitats, and 12 percent would occur in pinyon-juniper
and other woodlands.
In sagebrush and pinyon-juniper communities,
rimsulfuron would be available for use as another
option for controlling infestations of cheatgrass and
other winter annual grasses, and helping to reduce
wildfire risk. Therefore, this active ingredient could be
used instead of currently approved herbicides (primarily
imazapic) in certain situations. None of the new
herbicides, however, would play a role in treatments to
thin sagebrush, pinyon and juniper, or other woody
species in this ecoregion. Some control of broadleaf
weeds could be offered by aminopyralid and
rimsulfuron. Treatments with the new herbicides to
control invasive plant species and reduce wildfire risk
would provide a benefit to wildlife habitat.
Mediterranean and Marine Ecoregions
Herbicide treatments in the Mediterranean and Marine
Ecoregions would represent approximately 5 percent of
all treated areas. More than three-quarters of the
treatments in these ecoregions would occur in forested
habitats, and would be focused on integrated weed
management and forest health. The objectives of forest
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ENVIRONMENTAL CONSEQUENCES
health treatments would be to stem the decline in older
forest habitats primarily due to fire exclusion, to restore
more natural fire regimes, and to reduce hazardous fuels
and the potential for catastrophic wildfires.
In forest and woodland habitats, the three new
herbicides would be used to manage herbaceous
invasive plant species that occur in the understoiy, or in
canopy openings or disturbed areas, such as cheatgrass,
knapweeds, and thistles. These treatments would be
expected to improve habitat for forest- and woodland¬
dwelling wildlife by removing species that offer limited
habitat value and displace higher value native forbs and
grasses. Control of fire-adapted annual grasses in the
understory would also help reduce fire risk in forest and
woodland areas.
Impacts by Alternative
The following sections detail the expected effects of
each of the four alternatives on terrestrial wildlife, and
compare these effects to those expected under the other
alternatives. These effects may vary depending on the
percentage of acres treated using different application
methods and different herbicides, as well as the size of
treatment events. Earlier in this section, SOPs were
described that would reduce some of the impacts
described below.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue its ongoing vegetation treatment programs in
17 western states, using the 18 active ingredients
currently approved for use. As estimated in the 2007
PEIS, approximately 7 percent of all treatment acres are
associated with vegetation treatments that are done
specifically to benefit wildlife and wildlife habitat. All
treatments, however, would be likely to benefit wildlife
habitat, as discussed in the previous section. A
discussion of the benefits and impacts to wildlife is
presented in the 2007 PEIS (Alternative B; USDOI
BLM 2007a:4- 1 1 5 to 4-116).
As identified in the 2007 PEIS, the currently approved
herbicides of greatest concern to wildlife are 2,4-D,
bromacil, diquat, and diuron, based on their relative
level of risk to wildlife as predicted by ERAs. Based on
the projections made in Table 2-4, treatments with these
four active ingredients would comprise only about 10
percent of all acres treated under this alternative
(compared to historic usage of about 1 3 percent). Other
currently approved herbicides may pose low to
moderate risk to wildlife under certain exposure
scenarios.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, the total acreage of wildlife
habitat treated with herbicides would be the same as
under the No Action Alternative and the other action
alternatives. Therefore, the degree of benefit to wildlife
from treatment programs would be expected to be
similar under all alternatives. The target species would
be the same as under the No Action Alternative, as
would treatment goals, including goals to improve
wildlife habitat. The ability to use aminopyralid,
fluroxypyr, and rimsulfuron under this alternative would
allow the BLM greater flexibility in designing treatment
projects, which could have a minor benefit to wildlife if
it translates to more effective treatments and better
achievement of project goals. The new active
ingredients would provide new tools for controlling
invasive species that may be resistant to one or more of
the currently approved herbicides. Additionally,
rimsulfuron would offer another option for wide-scale
cheatgrass treatment, which currently threatens shrub-
steppe and other important wildlife habitats throughout
much of the western U.S.
Under this alternative, use of 2,4-D, bromacil, diquat,
and diuron, when added together, would make up
roughly 8 percent of all acres treated. Their usage would
be slightly lower than under the No Action Alternative.
However, all three of the new active ingredients
proposed for use are of lower risk to wildlife than nearly
all of the other active ingredients currently approved for
use. Therefore, toxicological risks to wildlife would be
lower overall under this alternative than under the No
Action Alternative.
Alternative C - No Aerial Application of New
Herbicides
Under this alternative, the total acreage of wildlife
habitat treated with herbicides would be the same as
under the other alternatives. Therefore, it is expected
that the degree of benefit to wildlife from vegetation
treatments programs would be similar to that under the
other alternatives. Since the new herbicides would not
be applied using aerial methods, their use would be
limited to ground-based treatments. As a result,
currently approved active ingredients would continue to
be used in herbicide treatments that improve wildlife
habitat through large-scale control of invasive plants.
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ENVIRONMENTAL CONSEQUENCES
The degree of benefit to wildlife habitat could be
slightly lower than under the Preferred Alternative if the
effectiveness of treatment programs is limited by the
inability to utilize the new herbicides under aerial
spraying scenarios.
The BLM may need to continue to use herbicides with a
greater toxicological risk to wildlife instead of the three
new herbicides proposed for use. Under this alternative,
use of 2,4-D, bromacil, diquat, and diuron, when added
together, would make up roughly 9 percent of all acres,
which is slightly less than under the No Action
Alternative, and slightly greater than under the Preferred
Alternative. Both glyphosate and picloram, which
would have greater use under this alternative than under
the Preferred Alternative, have a greater toxicological
risk to wildlife than the three new herbicides. Risks to
wildlife from exposure to herbicides would be greater
than under the Preferred Alternative but less than under
the No Action Alternative.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under this alternative, the total acreage of wildlife
habitat treated with herbicides would be the same as
under the other alternatives, and the degree of benefit to
wildlife from treatment programs would be similar
under all alternatives. The inability to use rimsulfuron
under this alternative would remove one option for
treatment of invasives such as cheatgrass and other
annual grasses. Control of these target species to
improve wildlife habitat would continue with currently
approved herbicides (such as imazapic). However, the
effectiveness of treatments in certain areas could be
lower than under the other action alternatives,
particularly the Preferred Alternative.
Under this alternative, the currently approved active
ingredients with the greatest toxicological risk to
wildlife (2,4-D, bromacil, diquat, and diuron), when
added together, would make up roughly 8 percent of all
acres treated, which is the same as under the Preferred
Alternative, and slightly lower than under the No Action
Alternative and Alternative C. Relative to the Preferred
Alternative, use of glyphosate and imazapic would be
higher, similar to levels under the No Action
Alternative. Relative to rimsulfuron, imazapic is of a
similar toxicity to wildlife, so there would be little
difference from a toxicological risk standpoint between
the use of these two chemicals. Glyphosate, however.
has a greater toxicological risk to wildlife than
rimsulfuron. Therefore, risks to wildlife associated with
exposure to herbicides could be slightly greater under
this alternative than under the Preferred Alternative.
Mitigation for Herbicide Treatment
Impacts
The BLM would continue to implement the SOPs
identified earlier in this section, as well as all other
SOPs identified in the 2007 PEIS (USDOI BLM
2007a:Table 2-8). These include, but are not limited to,
timing restrictions to avoid critical wildlife breeding or
staging periods and pre-treatment surveys for sensitive
wildlife and their habitats. The mitigation measures for
wildlife specified in the 2007 PEIS (USDOI BLM
2007a:4-l 18) would also apply to treatments involving
the new herbicides, including applications of mixtures
of the new herbicides with currently approved
herbicides.
Given the low toxicological risk of aminopyralid,
fluroxypyr, and rimsulfuron to wildlife, no new
mitigation measures have been developed specific to
these active ingredients.
Special Status Wildlife Species
Introduction
As discussed in Chapter 3, public lands in the western
U.S. support over 200 species of terrestrial wildlife
(including birds, mammals, amphibians, reptiles,
mollusks, and arthropods) that have been given a special
status based on their rarity or sensitivity. Included are
more than 60 species that are federally listed as
threatened or endangered, or are proposed for federal
listing. Some of these species have habitat requirements
that have been or are being altered or reduced by
invasions of non-native plant species. The Vegetation
Treatments Using Aminopyralid, Fluroxypyr, and
Rimsulfuron on Bureau of Land Management Lands in
17 Western States Biological Assessment (USDOI BLM
2015) provides a description of the distribution, life
history, and current threats for each federally listed
animal species, as well as species proposed for listing.
The BA also discusses the risks to federally listed and
proposed terrestrial wildlife associated with each of the
herbicides proposed for use by the BLM under the
different alternatives.
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ENVIRONMENTAL CONSEQUENCES
Impacts Assessment Methodology
The BLM reviewed the literature and findings from
ERAs conducted by the BLM to assess the impacts to
sensitive wildlife species from the use of herbicides
(AECOM 2014a,b; AECOM 2015). The ERA methods
are summarized in the Wildlife Resources section of
this chapter, and are presented in more detail in the
Vegetation Treatments Programmatic EIS Ecological
Risk Assessment Protocol (ENSR 2004) and in
Appendix C of the 2007 PEIS. To complete risk
assessments for special status wildlife species, the
chronic risk LOC of 1 and the acute endangered species
LOC of 0.1 were used.
Summary of Herbicide Effects to
Special Status Wildlife Species
A summary of the general effects of herbicide
treatments on special status wildlife species and
populations is presented in the 2007 PEIS (USDOI
BLM 2007a:4-119 to 4-120). Use of herbicides can
affect the habitats of special status wildlife species, as
discussed for wildlife in general. Herbicide treatments
would be expected to benefit species that are threatened
because of noxious weeds and other invasive plant
species. Invasive plant species typically reduce the
prevalence of native plant species, many of which serve
as the preferred food (or in some cases the only food) of
special status wildlife species. Invasive species may also
detrimentally affect other important habitat components
such as structure for nesting, foraging, and cover.
Herbicide treatments that reduce the cover of non-native
species and increase the cover of native species would
be expected to benefit these special status wildlife
species.
Potential adverse effects to the habitat of special status
wildlife species from herbicide treatments include
removal of vegetation used for cover, nesting, or food,
including unintentional removal of larval host plants
and nectar sources for listed butterfly species.
The three new herbicides proposed for use by the BLM
could pose toxicological risks to special status wildlife
as a result of exposure via various pathways (direct
spray, contact with foliage after direct spray, and
ingestion of food items contaminated by direct spray).
Based on information presented in the ERAs,
aminopyralid and rimsulfuron would not pose
toxicological risks to any special status wildlife under
the modeled exposure scenarios. In the case of
applications involving fluroxypyr, there would be a low
risk to pollinating insects as a result of direct spray
scenarios. This is a conservative scenario that assumes
the insect absorbs 1 00 percent of the herbicide, with no
degradation or limitations to uptake.
The potential for special status wildlife and their habitat
to be exposed to herbicide treatments involving
herbicides would be minimized by following applicable
SOPs, which include the following:
• Survey for special status wildlife species before
treating an area. Consider effects to these
species when designing treatment programs.
• Use drift reduction agents to reduce the risk of
drift hazard.
• Select herbicide products carefully to minimize
additional impacts from degradates, adjuvants,
inert ingredients, and tank mixtures.
• Avoid treating vegetation during time-sensitive
periods (e.g., nesting and migration) for species
of concern in the area to be treated.
Herbicide treatments would adhere to the most recent
guidance for special status species, including land use
plan decisions for sage-grouse as amended by pertinent
sage-grouse EISs, and interim management direction as
outlined in Instruction Memorandum 2012-043
{Greater Sage-Grouse Interim Management Policies
and Procedures ).
Impacts by Alternative
For the most part, the comparison of alternatives for
special status wildlife is similar to that for all terrestrial
wildlife, presented earlier in this chapter. While risk
levels associated with fluroxypyr (presented in Table
4-13) are slightly higher for special status species than
for non special status species, fluroxypyr treatments
would make up only 1 percent or less of total herbicide
use under all alternatives, and would only pose a risk to
pollinating insects.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under this alternative, the BLM would continue its
treatment programs with the currently available
herbicides, treating up to 932,000 acres annually. Some
of the treatments would be implemented specifically to
benefit special status species and their habitat.
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TABLE 4-13
Risk Categories Used to Describe Herbicide Effects on Special Status
Wildlife According to Exposure Scenario
Application Scenario
Amino
>yralid
Fluroxypyr
Rimsulfuron
Typ'
Max'
Typ
Max
Typ
Max
Direct Spray of Terrestrial Wildlife
Small mammal - 100% absorption
02
0
0
0
0
0
Pollinating insect - 1 00% absorption
0
0
L
L
0
0
Small mammal - 1st order dermal adsorption
0
0
0
0
0
0
Indirect Contact with Foliage After Direct Spray
Small mammal - 100% absorption
0
0
0
0
0
0
Pollinating insect - 100% absorption
0
0
0
0
0
0
Small mammal - 1 st order dermal absorption
0
0
0
0
0
0
Ingestion of Food Items Contaminated by Direct Spray
Small mammalian herbivore - acute exposure
0
0
0
0
0
0
Small mammalian herbivore - chronic exposure
0
0
0
0
0
0
Large mammalian herbivore - acute exposure
0
0
0
0
0
0
Large mammalian herbivore - chronic exposure
0
0
0
0
0
0
Small avian insectivore - acute exposure
0
0
0
0
0
0
Small avian insectivore - chronic exposure
0
0
0
0
0
0
Large avian herbivore - acute exposure
0
0
0
0
0
0
Large avian herbivore - chronic exposure
0
0
0
0
0
0
Large mammalian carnivore - acute exposure
0
0
0
0
0
0
Large mammalian carnivore - chronic exposure
0
0
0
0
0
0
1 Typ = Typical application rate; and Max = Maximum application rate.
2 Risk categories: 0 = No risk (RQ < applicable LOC for special status species); and L = Low risk (RQ 1-10 times the applicable LOC for special status
species)^
Herbicides of greatest concern to special status wildlife
from a toxicological perspective are 2,4-D, bromacil,
diquat, diuron, glyphosate, hexazinone, and triclopyr.
Based on their projected usage (summarized in Table 2-
4), treatments with these active ingredients would total
approximately 38 percent of all acres treated (compared
to historic usage of about 44 percent). Out of these
active ingredients, triclopyr, glyphosate, and 2,4-D
would be used most widely, accounting for 33 percent
of all acres treated. Other currently approved active
ingredients may pose low to moderate risks to special
status wildlife under a few exposure scenarios.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, efforts to improve habitats that
support special status wildlife would benefit from the
addition of aminopyralid, fluroxypyr, and rimsulfuron
to the list of approved herbicides. These herbicides may
improve the effectiveness of certain treatments, relative
to treatments using the currently approved herbicides.
Therefore, the degree of benefit to special status species
may be slightly greater than under the No Action
Alternative in certain situations.
In certain treatment projects, herbicides of low toxicity
to special status wildlife would be used instead of
herbicides with a higher risk. In particular, use of
glyphosate would decrease by more than half.
Herbicides of greatest concern from a toxicological
perspective would account for about 30 percent of all
acres treated, with use of 2,4-D, glyphosate, and
triclopyr accounting for 26 percent of all acres treated.
Therefore risks for adverse effects to special status
wildlife associated with exposure to herbicides could be
slightly lower than under the No Action Alternative.
Alternative C - No Aerial Application of New
Herbicides
Under this alternative, treatments that improve habitats
utilized by special status wildlife species through large-
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scale control of invasive plants would be accomplished
using aerial spraying of currently approved herbicides,
but not the new herbicides. This restriction would limit
the benefits associated with introducing new herbicide
options, relative to the Preferred Alternative.
Since the new herbicides would not be used in aerial
applications, opportunities to use these active
ingredients in place of those with a greater toxicological
concern would be fewer than under the Preferred
Alternative. Herbicides of greatest concern from a
toxicological perspective would account for an
estimated 35 percent of all acres treated, with use of 2,4-
D, glyphosate, and triclopyr accounting for about 31
percent of all acres treated. Depending on where these
herbicides are used, risks to special status wildlife from
exposure to herbicides could be slightly lower than
under the No Action Alternative but slightly higher than
under the Preferred Alternative.
Alternative D — No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under this alternative, only two of the proposed active
ingredients would be available for use under the BLM’s
herbicide treatment programs. Use of new active
ingredients would be approximately the same as under
Alternative C, although the breakdown by herbicide
would be different. Programs aimed at improving
habitat for special status wildlife species would be
implemented without the option of rimsulfuron. The
degree of benefit to special status species could be
lower than under the Preferred Alternative if certain
treatments are less effective without the option of
rimsulfuron.
Under this alternative, based on herbicide usage
estimates by the BLM, herbicides of greatest
toxicological concern (2,4- D, glyphosate, and triclopyr)
would account for approximately 36 percent of all acres
treated, very similar to the No Action Alternative.
Therefore, risks for adverse effects to special status
wildlife would be similar to those under the No Action
Alternative and slightly higher than under the other
action alternatives.
Mitigation for Herbicide Treatment
Impacts
Mitigation to reduce the likelihood of impacts to special
status wildlife species, as included in the ROD for the
2007 PEIS, would continue to be implemented under all
alternatives, as would all SOPs and mitigation for
general wildlife species presented earlier in this section.
These measures would be applied to treatments with the
three new herbicides, as relevant.
The Biological Assessment for Vegetation Treatments
Using Aminopyralid, Fluroxypyr, and Rimsulfuron on
Bureau of Land Management Lands in 17 Western
States determined that given the low toxicity of the
three new active ingredients to most special status
species and SOPs for minimizing risks to wildlife, no
new conservation measures were necessary for
herbicide treatments using aminopyralid or rimsulfuron
(USDOl BLM 2015). For terrestrial arthropods,
however, the BA recommended a conservation measure
specific to use of fluroxypyr. Therefore, the following
mitigation is recommended to reduce the likelihood of
impacts to special status terrestrial wildlife species from
herbicide applications.
• When conducting herbicide treatments in or
near habitats used by special status and listed
terrestrial arthropods, design treatments to
avoid the use of fluroxypyr, where feasible. If
pre-treatment surveys determine the presence
of listed terrestrial arthropods, do not use
fluroxypyr to treat vegetation.
While no additional mitigation measures specific to the
three new herbicides were identified in the BA,
conservation measures were developed for species that
have been listed or proposed for listing since 2007.
Therefore, the following mitigation measure has been
developed to ensure that the new conservation measures
in the 2015 BA are incorporated:
• To protect special status wildlife species,
implement all conservation measures for
wildlife presented in the Vegetation Treatments
Using Aminopyralid, Fluroxypyr, and
Rimsulfuron on Bureau of Land Management
Lands in 1 7 Western States Biological
Assessment (USDOl BLM 2015).
Additional evaluations of situation-specific effects to
special status wildlife will occur prior to local
implementation of vegetation management activities
that involve the use of aminopyralid, fluroxypyr, and
rimsulfuron. Additional measures to protect special
status wildlife may be developed at that time.
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Livestock
Introduction
Public lands provide an important source of forage for
many ranches and help to support the agricultural
component of many communities scattered throughout
the West. Approximately 155 million acres of public
lands are available to be grazed by livestock. Noxious
weeds can affect the health of grazing lands by
displacing native grasses and other plant species.
Additionally, certain noxious weeds are poisonous to
livestock. Livestock that encounter noxious weeds may
also contribute to the spread of noxious weeds on
rangelands.
Scoping Comments and Other Issues
Evaluated in the Assessment
Scoping comments directly pertinent to livestock and
grazing included statements that the new herbicides are
safe for use on grazing sites, and that aminopyralid in
particular can be used in smaller amounts compared to
currently approved herbicides.
A few comments, however, indicated that use of
aminopyralid may be incompatible with grazing
because of its persistence in vegetation. Comments
noted incidents involving use of manure from animals
that had grazed on vegetation treated with aminopyralid,
which resulted in damage to crops and other non-target
vegetation.
Standard Operating Procedures
The 2007 PEIS lists SOPs for minimizing risks to
livestock, which can be implemented at the local level
according to site conditions. These SOPs would apply to
use of the new active ingredients, when relevant, to
reduce potential unintended impacts to livestock from
herbicide treatments:
• Whenever possible and whenever needed,
schedule treatments when livestock are not
present in the treatment area. Design treatments
to take advantage of normal livestock grazing
rest periods, when possible.
• As directed by the herbicide label, remove
livestock from treatment areas prior to
herbicide application, where applicable.
• Use herbicides of low toxicity to livestock,
where feasible.
• Take into account the different types of
application equipment and methods, where
possible, to reduce the probability of
contamination of non-target food and water
sources.
• Notify permittees of the project to improve
coordination and avoid potential conflicts and
safety concerns during implementation of the
treatment.
• Notify permittees of livestock grazing or
feeding restrictions, if necessary (see below for
restrictions associated with each herbicide).
• Notify adjacent landowners prior to treatment.
• Provide alternate forage sites for livestock, if
possible.
The ROD for the 2007 PEIS (USDOI BLM 2007b:
Table 2) also lists mitigation measures for livestock that
are applicable to the currently approved herbicides.
These measures could apply to the three new active
ingredients if they are combined with one or more
currently approved active ingredients in a formulation
or tank mix.
Mitigation measures and SOPs would help minimize
impacts to livestock and rangeland on western BLM
lands to the extent practical. As a result, long-term
benefits to livestock from the control of invasive species
would likely outweigh any short-term negative impacts
to livestock associated with herbicide use.
Impacts Assessment Methodology
The methods used to assess impacts to livestock from
the three new active ingredients were the same as those
described in the 2007 PEIS (USDOI BLM 2007a:4-
125). Risk assessment results pertaining to mammalian
receptors were used to assess impacts to livestock from
the three new herbicides. The ERA methods are
summarized in the Wildlife Resources section of this
chapter, with a more detailed methodology presented in
the ERAs. For dermal exposure scenarios, small
mammals were used as receptors, as they are more
likely to be affected than large animals (larger surface
area to body weight ratio) and the results are more
conservative. For ingestion scenarios, a large
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ENVIRONMENTAL CONSEQUENCES
mammalian herbivore (mule deer) was used as the
receptor in the risk assessment.
Summary of Herbicide Impacts
The 2007 PEIS (USDOI BLM 2007a:4-125 to 4-126)
provides a discussion of the general effects of herbicide
use on livestock. This information is summarized here,
with more detailed discussion included for the three
active ingredients specifically covered by this PEIS.
Possible direct effects from herbicides include death,
damage to vital organs, change in body weight,
decreases in healthy offspring, and increased
susceptibility to predation. However, these effects are
largely dependent on the quantity of the herbicide and
the sensitivity of livestock to the herbicide used.
Possible indirect effects include reduction in the amount
of forage and the preferred forage type.
Beneficial effects to livestock could include an increase
in desirable forage and a decrease in noxious weeds and
other invasive species that constitute undesirable forage.
Additionally, treatments that reduce the risk of future
catastrophic wildfire through fuels reduction would also
benefit livestock. Invasive plant species that may
present a fire hazard in rangelands include cheatgrass,
medusahead iye, other winter annual grasses such as
ventenata and red brome, Russian thistle, oak, pinyon,
and juniper.
Over the short term, there would be minor impacts to
livestock rearing as a result of mandatory restrictions
associated with the use of herbicides. These include
restrictions on slaughter (for food) of animals that have
consumed treated vegetation, as well as various grazing
restrictions.
Noxious weed infestations can greatly reduce the land’s
carrying capacity for domestic livestock, which tend to
avoid most weeds (Olson 1999a). Cattle, in particular,
preferentially graze native plant species over weeds,
which often have low palatability as a result of defenses
such as toxins, spines, and/or distasteful compounds. In
addition, some noxious weeds are poisonous to
livestock. Although goats and sheep are more likely to
consume alien weeds than cattle, they also tend to select
native or introduced forage species over weeds (Olsen
and Wallander 1997, Olson 1999a). The success of
invasive plant species removal would determine the
level of benefit of the treatments over the long term.
Livestock consume large amounts of grass, and
therefore have a relatively greater risk for harm than
animals that feed on other herbaceous vegetation or
seeds and fruits, because herbicide residue is higher on
grass than it is on other plants (Fletcher et al. 1994;
Pfleeger et al. 1996). However, aminopyralid,
fluroxypyr, and rimsulfuron generally have a very low
risk to mammals, even when considering large
herbivores and conservatively assuming that 100
percent of the animal’s diet comes from treated
vegetation. Therefore, the most likely effects would be
associated with habitat modification and grazing
restrictions.
Impacts of Aminopyralid
Aminopyralid is a selective herbicide that is used to
control undesirable broadleaf plants in rangelands and
pastures. Therefore, it is likely to be used in areas
grazed by livestock.
The risk assessment for aminopyralid predicted that
none of the possible scenarios of aminopyralid exposure
(direct spray, contact with foliage after direct spray,
ingestion of food items contaminated by direct spray)
would pose a risk of adverse effects to livestock. As
discussed previously, even scenarios that assume 100
percent of the diet comes from treated vegetation
indicated no risk to livestock.
While aminopyralid is unlikely to adversely affect
survival, growth, or reproduction of livestock, some
restrictions in grazing would be necessary with the use
of aminopyralid. Persistent herbicides are a class of
systemic herbicides that are used to control a wide
variety of broadleaf species. These herbicides are
formulated to survive multiple years of exposure in a
growing environment. The BLM would follow all label
instructions when using herbicides. Aminopyralid is
persistent in vegetation and does not break down in
plants (Dow AgroSciences 2005), and therefore may be
present in the urine or manure of livestock that have
grazed in am inopyral id-treated rangelands. Therefore,
after grazing aminopyralid-treated forage, livestock
must graze for 3 days in an untreated pasture without
desirable broadleaf plants before returning to an area
where desirable broadleaf plants are present. There are
no other restrictions on grazing following application of
aminopyralid at the proposed typical or maximum
application rate. If aminopyralid is used in a mixture
with one or more other active ingredients, additional
grazing restrictions may apply.
As discussed in the Vegetation section, aminopyralid
has been observed to be successful at controlling
unpalatable and/or poisonous rangeland weeds, such as
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musk thistle, yellow starthistle, knapweeds, and tansy
ragwort. Russian knapweed and yellow starthistle, for
instance, are known to be toxic to horses, causing
“chewing disease” if large quantities are grazed over
time, which can result in death if not treated (Turner et
al. 2011). Tansy ragwort is toxic to various types of
livestock, but particularly to cattle and horses. Ingestion
of this noxious weed causes liver toxicity, and can result
in death of animals that graze in fields where tansy
ragwort is present (USDA Agricultural Research
Service 2006).
Successful removal of these noxious weeds and
restoration of grasses and other more palatable forage
species would be beneficial to livestock. Aminopyralid
is selective for broadleaf weeds, and therefore would
not harm the native grasses that are favorable as forage
for livestock.
Many forbs have a higher nutritional value than grasses,
even though forbs make up a small percentage of the
total cattle diet (Weir et al 2004). Non-target broadleaf
species that would be adversely affected by an
application of aminopyralid could include some of the
most nutritionally valuable forage plants for livestock
production. Therefore, while use of aminopyralid in
rangelands could reduce the cover of noxious weeds and
other unpalatable species, it could also reduce the
amount of high quality forage (forbs) available to
grazing animals (Weir et al. 2004).
Impacts of Fluroxypyr
Fluroxypyr is a selective herbicide that is used to
control undesirable broadleaf plants while maintaining
grass forage species. Therefore, fluroxypyr is likely to
be used in rangelands that are grazed by livestock.
According to the risk assessment, fluroxypyr does not
have a risk of causing adverse health effects to livestock
as a result of dermal exposure or ingestion scenarios.
Fluroxypyr does not have any grazing restrictions for
livestock, including lactating and non-Iactating dairy
animals. However, livestock must not eat treated forage
for at least 2 days before slaughter for meat. If
fluroxypyr is used in a mixture with one or more other
herbicides, additional grazing restrictions may apply.
As discussed in the Vegetation section, fluroxypyr is
effective at controlling pricklypear as well as other
undesirable rangeland plants. Therefore, use of this
herbicide could help improve the quality of rangeland
forage, although its total annual use by the BLM would
be low.
At high densities, pricklypear can interfere with forage
utilization and livestock movement and handling.
However, the fruits of the plant, in particular, are high
in carbohydrates and very palatable to livestock. While
the spines on plants are generally avoided, they may be
ingested by hungry animals. Ingestion of spines can
cause ulceration and bacterial infection of the
mouthparts and gastrointestinal tracts of sheep and goats
(Ueckert 1997). Therefore, control of pricklypear could
have either adverse or beneficial effects on livestock
forage, depending on how much of the species is
controlled and what other forage is present on the site.
Impacts of Rimsulfuron
Rimsulfuron is a selective herbicide that is used to
control winter annual grasses, such as cheatgrass and
medusahead rye. It is approved for use on rangelands,
and therefore is likely to be used in areas grazed by
livestock.
According to the ERA, rimsulfuron does not pose a risk
to mammals under any of the modeled exposure
scenarios. These include scenarios involving direct
spray, indirect contact with foliage after direct spray,
and ingestion of food that has been treated with the
active ingredient.
The label for rimsulfuron products includes a grazing
restriction for range and pasture areas. No livestock
grazing should occur on treated sites for 1 year
following application, to allow newly emerged grasses
sufficient time to establish.
Winter annual grasses reduce the quality of forage for
livestock by displacing native grasses, and providing a
very limited grazing season. Medusahead rye is rich in
silica and becomes unpalatable to cattle and sheep in
late spring (Oregon Department of Agriculture 2013).
The seeds of cheatgrass produce stiff awns that make
the plant unpalatable once the seed has dried. In
Nevada, for example, the cheatgrass grazing season for
livestock is only 4 to 5 weeks (University of Nevada
Cooperative Extension 1998). Native perennial grasses
stay green longer than invasive annual grasses, thus
extending the grazing season (Griffith 2004).
Additionally, cheatgrass increases the risk of wildland
fire in rangelands, which would potentially affect
livestock grazing in these areas. Nonetheless, cheatgrass
is utilized as a forage species for livestock (Emmerich et
al. 1993).
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ENVIRONMENTAL CONSEQUENCES
Impacts by Alternative
The potential effects to livestock under each alternative
are discussed in the following sections. There are few
differences among the alternatives, as the extent of
herbicide treatment generally would be the same, with
differences only in the relative percent of herbicides
used.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
This alternative represents a continuation of current
herbicide usage practices. The likely impacts of this
alternative on livestock were presented in the 2007
PEIS, under the discussion for the Preferred Alternative
(USDOI BLM 2007a:4-134; Tables 4-25 and 4-26).
Both positive and negative effects to livestock are likely
to continue under this alternative. Many of the currently
approved herbicides are associated with some level of
risk to livestock via one or more exposure pathways.
The mitigation measures presented in the ROD for the
2007 PEIS (USDOI BLM 2007b:Table 2) would
continue to be implemented to prevent adverse effects
to livestock from herbicide applications in areas grazed
by these animals.
Herbicide treatments under the No Action Alternative
would continue to improve rangeland across the West.
These treatments are controlling noxious weeds and
limiting the risk of wildland fire, both of which should
benefit livestock that use public lands. Multiple
treatments and post-treatment reseeding/restoration of
native species would be necessary to improve rangeland
over the long term.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, the same total acreage would be
treated using herbicides as under the No Action
Alternative, except that aminopyralid, fluroxypyr, and
rimsulfuron would be added to the list of approved
active ingredients. Addition of the new herbicides
would result in a shift in the relative amounts of the
various herbicides that are used. However, only
glyphosate, imazapic, and picloram would have a
substantial reduction in usage under this alternative.
Glyphosate and picloram are associated with low to
moderate risks to livestock under various exposure
scenarios (USDOI BLM 2007a:Table 4-26), but there is
no risk to livestock associated with use of imazapic
(USDOI BLM 2007a:4-129). Approximately 7 percent
fewer acres would be treated with herbicides that have
some level of risk to livestock.
Availability of the new herbicides would allow the
BLM more flexibility in designing treatment programs,
and could result in more successful treatment of
rangelands utilized by livestock. Additionally, the new
herbicides could be used in rangelands where livestock
mitigation measures from the 2007 PEIS restrict use of
other herbicides, to more effectively control rangeland
weeds.
Alternative C - No Aerial Application of New
Herbicides
Under this alternative, the three new herbicides would
not be applied using aerial methods, and use of these
chemicals would be lower than under the Preferred
Alternative. Instead, other herbicides would be used for
these large-scale treatments. As a result, approximately
5 percent fewer acres would be treated with herbicides
that have some level of risk to livestock, relative to the
No Action Alternative.
The BLM would be able to use the new herbicides in
some areas where use of currently approved herbicides
is limited by livestock mitigation measures from the
2007 PEIS, but not to the same degree as in
Alternative B.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under this alternative, aminopyralid and fluroxypyr
could be applied in rangelands via any application
method, but rimsulfuron would not be added to the list
of approved herbicides. Glyphosate and imazapic would
continue to be used instead under most circumstances.
Glyphosate is of low to medium risk to livestock, but
imazapic poses no risk to livestock through the modeled
exposure scenarios. Similar to the Preferred Alternative,
approximately 7 percent fewer acres would be treated
with herbicides that have some level of risk to livestock,
relative to the No Action Alternative. While the BLM
would not have rimsulfuron available for cheatgrass
treatment programs in rangelands, this invasive
rangeland species would continue to be controlled using
imazapic and other active ingredients.
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Mitigation for Herbicide Treatment
Impacts
The BLM would continue to implement the SOPs
identified earlier in this section, as well as all other
SOPs identified in the 2007 PEIS (USDOI BLM
2007a:Table 2-8). Additionally, the mitigation measures
for livestock that were specified in the ROD for the
2007 PEIS (USDOI BLM 2007b:Table 2) would
continue to be followed, as applicable.
Given their low toxicological risks, no mitigation
measures for livestock have been proposed specifically
for herbicide treatments with aminopyralid, fluroxypyr,
or rimsulfuron.
Wild Horses and Burros
Introduction
Herbicide treatments have the potential to affect wild
horses and burros on BLM-administered lands through
exposure to chemicals that could harm their health, or
through changes in vegetation that could positively or
negatively alter the carrying capacity of HMAs.
Adverse impacts could include direct harm to wild
horses and burros and a reduction in the availability or
quality of forage in HMAs (decreasing the carrying
capacity of the HMAs). Alternately, herbicide
treatments could improve the amount and quality of
forage, potentially increasing the carrying capacity of
the HMAs.
Scoping Comments and Other Issues
Evaluated in the Assessment
One scoping comment expressed concern about the
toxicity of herbicides to wild horses and burros. No
other scoping comments pertaining specifically to wild
horses and burros were received.
Standard Operating Procedures
The 2007 PEIS lists SOPs for minimizing risks to wild
horses and burros, which can be implemented at the
local level according to specific conditions. These SOPs
include the following:
• Use herbicides of low toxicity to wild horses
and burros, where feasible.
• Remove wild horses and burros from identified
treatment areas prior to herbicide application,
in accordance with label directions for
livestock.
• Take into account the different types of
application equipment and methods, where
possible, to limit the probability of
contaminating non-target food and water
sources.
The ROD for the 2007 PEIS (USDOI BLM 2007b:
Table 2) also lists several mitigation measures for wild
horses and burros that are applicable to the currently
approved herbicides. These mitigation measures would
be followed, as applicable, when using mixtures of
currently approved herbicides and new herbicides.
Additionally, the ROD specified that the herbicide label
grazing restrictions for livestock should be applied to
herbicide treatments in areas that support populations of
wild horses and burros.
Impacts Assessment Methodology
The methods used to assess impacts to wild horses and
burros from aminopyralid, fluroxypyr, and rimsulfuron
were the same as those described in the 2007 PEIS
(USDOI BLM 2007a:4-137). Risk assessment results
pertaining to mammalian receptors were used to assess
impacts to wild horses and burros. The ERA methods
are summarized in the Wildlife Resources section of
this chapter, with a more detailed methodology
presented in the ERAs. For dermal exposure scenarios,
small mammals were used as receptors, as they are
more likely to be affected than large animals (larger
surface area to body weight ratio) and the results are
more conservative. For ingestion scenarios, a large
mammalian herbivore (mule deer) was used as the
receptor in the risk assessment.
Summary of Herbicide Impacts
The 2007 PEIS (USDOI BLM 2007a:4-137 to 4-138)
provides a general discussion of the potential effects of
herbicide use on wild horses and burros. This
information is summarized here, with more detailed
discussion included for the three active ingredients
specifically covered by this PEIS.
Possible direct effects from herbicides include death,
damage to vital organs, change in body weight,
decreases in healthy offspring, and increased
susceptibility to predation. However, these effects are
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largely dependent on the sensitivity of exposed animals
to the herbicide used. Newborn horses and burros would
be most susceptible to herbicides, with the March
through June foaling season being a critical period.
Possible indirect effects include reduction in the amount
of forage and the preferred forage type. Additionally,
wild horses and burros may move out of HMAs and
onto lands that are not legally designated for wild horse
and burro management.
Beneficial effects to wild horses and burros could
include an increase in the treated area’s carrying
capacity for wild horses and burros with the removal of
non-native, unpalatable species. Additionally,
treatments that reduce the risk of future catastrophic
wildfire through fuels reduction would also benefit wild
horses and burros.
The three herbicides generally have a very low risk to
mammals. Therefore, the most likely effects would be
associated with habitat modification. Application of
herbicides in HMAs would follow guidance in the BLM
Wild Horse and Burros Management Handbook and
associated Herd Management Plans (USDOl BLM
2010b).
Impacts of Aminopyralid
The risk assessment for aminopyralid predicted that
none of the possible scenarios of aminopyralid exposure
(direct spray, contact with foliage after direct spray,
ingestion of food items contaminated by direct spray)
would pose a risk to mammals. Therefore, aminopyralid
does not pose a risk to wild horses and burros, even
under the unlikely scenario that they would be directly
sprayed during an herbicide application. The evaluated
scenarios are very conservative because they assume
100 percent absorption of the active ingredient, and that
100 percent of the animal’s diet comes from treated
vegetation.
Wild horses and burros forage on grasses and forbs, but
will also consume some shrubs. Based on a literature
review of studies about the diets of wild horses and
burros, these animals have a wide variation in diet
depending on the habitat and what species are available
(Abella 2008). While control of undesirable broadleaf
plants by aminopyralid may improve forage for wild
horses and burros, it may also reduce the availability of
desirable forb species, as well as the diversity of forage
species available. Currently, many HMAs are
overburdened with wild horse and burro populations
(USDOl BLM 2010b). Depending on the target species
of the treatment, herbicide treatments with aminopyralid
could improve the capacity of HMAs.
Impacts of Fluroxypyr
Based on the information in the ERA, there is no risk to
mammals from exposure to fluroxypyr under the
modeled dermal and ingestion exposure scenarios.
Therefore, this herbicide is safe to apply in habitats used
by wild horses and burros in standard BLM herbicide
applications, even under direct spray scenarios and
assuming that 100 percent of the animal’s diet comes
from treated vegetation.
Fluroxypyr would be used in tank mixes to help control
undesirable rangeland plants. Depending on the target
species, use of this herbicide could benefit the quantity
and quality of forage in wild horse and burro HMAs.
Impacts of Rimsulfuron
According to the ERA for rimsulfuron, this active
ingredient does not pose a risk to mammals under any
of the modeled exposure scenarios. These include
scenarios involving direct spray, indirect contact with
foliage after direct spray, and ingestion of food that has
been treated with the active ingredient. Therefore, this
herbicide is safe to use in habitats where wild horses
and burros occur and forage.
Rimsulfuron targets cheatgrass and other winter
annuals. Wild horse and burros are known to feed on
invasive annual grasses, although this may be based on
availability rather than preference (Abella 2008).
Treatments with rimsulfuron may improve forage for
wild horses and burros over the long term by increasing
the prevalence of more desirable perennial grasses.
Additionally, control of fire-dependent winter annuals
could decrease the occurrence of catastrophic fires that
adversely affect HMAs (USDOl BLM 2010b).
Impacts by Alternative
The following sections discuss the expected effects of
each of the four alternatives on wild horses and burros,
and compare the effects expected under each
alternative. These effects may vary depending on the
acreage treated using different application methods and
active ingredients, as well as the size of treatment
events.
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Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under this alternative, the 18 currently approved active
ingredients would continue to be available for use in
habitats used by wild horses and burros. Potential
impacts to wild horses and burros associated with these
active ingredients were assessed in the 2007 PEIS
(USDOI BLM 2007a:4-138 to 4-143; Tables 4-25 and
4-26). As discussed in that analysis, the currently
approved active ingredients have varying levels of risk
to wild horses and burros, from no risk to high risk,
under certain exposure scenarios for certain herbicides.
The mitigation measures in the ROD for the 2007 PEIS
(USDOI BLM 2007b: Table 2) were developed to
minimize these risks, and would continue to be followed
under this alternative.
Herbicide treatments with the currently approved active
ingredients, as a component of larger vegetation
treatments, would have a long-term positive effect on
wild horse and burro communities through
improvements in rangeland forage.
The focus of vegetation treatments would continue to be
removal and control of invasive vegetation, and
improvement of native shrubland and grassland
communities. If effective, these treatments would
benefit wild horse and burro habitat. Wild horses favor
native grasses, including bluebunch wheatgrass, western
wheatgrass, Indian ricegrass, and bluegrasses, and
riparian/wetland vegetation, including sedges. Wild
burros feed on a variety of plants, including grasses,
Mormon tea, paloverde, and plantain. Treatments that
improve range habitat should benefit these preferred
plant species.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under the Preferred Alternative, the scope and extent of
herbicide treatments would be similar to those under the
No Action Alternative, but the three new active
ingredients would be available for use as part of these
treatments. The maximum assumed total area affected
by herbicide treatments is the same as under the No
Action Alternative and the other action alternatives
(932,000 acres).
The three new active ingredients — aminopyralid,
fluroxypyr, and rimsulfuron — are effective at
controlling rangeland weeds, but have a low toxicity to
mammals. These herbicides could potentially be used to
improve habitat in areas used by wild horses and burros,
where mitigation measures restrict or limit applications
with other chemicals. Based on information provided by
the BLM about the likely use of herbicides under this
alternative (Table 2-4), glyphosate, imazapic, and
picloram would see a substantial reduction in usage as a
result of the addition of the three new herbicides. Of
these, glyphosate and picloram are associated with low
to moderate risks to wild horses and burros under
various exposure scenarios, while imazapic does not
present a risk. Compared to the No Action Alternative,
approximately 7 percent fewer acres would be treated
with herbicides that have some level of risk to wild
horses and burros under the Preferred Alternative.
Because a similar acreage of land would be treated with
herbicides under all of the alternatives, there would be
few differences as far as long-term benefits to
rangelands that support wild horses and burros.
However, addition of the new herbicides under this
alternative may allow the BLM to more effectively
control invasive species and reduce fire risk in wild
horse and burro habitats.
Alternative C - No Aerial Application of New
Herbicides
This alternative is much like the Preferred Alternative as
far as herbicide treatments in wild horse and burro
habitats, except that aerial applications of the three new
herbicides would be prohibited. For treatments requiring
aerial applications, one or more of the currently
approved herbicides would be used, similar to the No
Action Alternative. Approximately 5 percent fewer
acres would be treated with active ingredients that have
some level of risk to wild horses and burros, relative to
the No Action Alternative.
Long-term benefits to rangelands that support wild
horses and burros would be similar to those under the
other alternatives, as the acreage of land treated would
be the same.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under this alternative, rimsulfuron would not be
approved for use by the BLM, and would not be used in
wild horse and burro habitats. Therefore, glyphosate and
imazapic would continue to be used for most treatment
programs (including cheatgrass treatments) that would
incorporate rimsulfuron under Alternatives B and C.
Glyphosate is of low to medium risk to wild horses and
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burros, but there is no predicted risk associated with use
of imazapic. Similar to the Preferred Alternative,
approximately 7 percent fewer acres would be treated
with herbicides that have some level of risk to wild
horses and burros, compared to the No Action
Alternative.
Long-term benefits to rangelands that support wild
horses and burros would be similar to those under the
other alternatives, as the acreage of land treated would
be the same.
Mitigation for Herbicide Treatment
Impacts
The BLM would continue to implement the SOPs
identified earlier in this section, as well as all other
SOPs identified in the 2007 PEIS (USDOI BLM
2007a:Table 2-8). Additionally, the mitigation measures
for wild horses and burros that were specified in the
ROD for the 2007 PEIS (USDOI BLM 2007b:Table 2)
would continue to be followed, as applicable.
Given their low toxicological risks, no mitigation
measures for wild horses and burros have been
proposed specifically for herbicide treatments with
aminopyralid, fluroxypyr, or rimsulfuron.
Paleontological and Cultural
Resources
Invasive plants are present at paleontological and
cultural resource sites on public lands. Invasive plants
can impact paleontological and cultural resources by
displacing native plants and contributing to soil erosion.
Removal of invasive vegetation, when done in such a
way that the resources are not adversely affected, can
contribute to the restoration and maintenance of historic
and ethnographic cultural landscapes (USDOI National
Park Service 2003).
Scoping Comments and Other Issues
Evaluated in the Assessment
The BLM received a few comments addressing the
potential impact of herbicide treatments on
paleontological and cultural resources from tribes and
SHPOs. There was a concern about potential impacts to
culturally important plants that might be treated with the
new active ingredients. One comment stated that to
address such impacts, consultation with Indian nations
should occur at the local level, once site-specific
treatments are known. Additionally, local tribes should
be contacted for information about traditional cultural
properties and other culturally significant areas that
might be impacted. Finally, one comment was
concerned with negative impacts to historic buildings,
monuments, and cemeteiy stones from nearby herbicide
use.
Standard Operating Procedures
The 2007 PEIS documents the BLM’s processes for
identifying and managing paleontological, cultural, and
subsistence resources (USDOI BLM 2007a:4-147 to 4-
148). The BLM would continue to follow these
processes and protocols for vegetation treatments
involving aminopyralid, fluroxypyr, and rimsulfuron.
These processes are outlined in a national Programmatic
Agreement with the Advisory Council on Historic
Preservation and the National Conference of State
Historic Preservation Officers, state-specific protocol
agreements with SHPOs, resource management plans,
and numerous BLM handbooks.
Before proceeding with vegetation treatments, the
effects of BLM actions on cultural resources would be
addressed through compliance with the NHPA. Effects
on paleontological resources would be addressed as
outlined in resource management plans developed under
the authority of the FLPMA and site-specific NEPA
documents developed for vegetation treatments. The
BLM’s responsibilities under these authorities are
addressed as early in the vegetation management project
planning process as possible.
The BLM Cultural Resource Management program is
responsible for the study, evaluation, protection,
management, stabilization, and inventory of
paleontological, historical, and archeological resources.
The program also ensures close consultation with
Native American tribal and Alaska Native group
governments. The BLM initiated consultation with
these groups to identify their cultural values, religious
beliefs, traditional practices, and legal rights that could
be affected by BLM actions. Consultation included
sending letters to all tribes and groups that could be
directly affected by vegetation treatment activities, and
requesting information on how the proposed activities
could impact Native American and Alaska Native
interests, including the use of vegetation and wildlife for
subsistence, religious, and ceremonial purposes (see
Appendix B).
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As discussed in the 2007 PEIS, paleontological,
cultural, and subsistence resources within treatment
areas would be identified at the local level, and site-
specific mitigation measures would be developed during
the implementation stage of vegetation treatments, if
needed. Mitigation could include steps to avoid or
protect cultural resources from treatments. In the case of
subsistence resources, treatments may need to be
modified or cancelled in certain areas to avoid impacts.
Additionally, procedures to protect any cultural
resources discovered during the course of vegetation
treatments would be developed.
Additional SOPs that would apply to paleontological,
cultural and subsistence resources are those pertaining
to human health, which would apply to the safety of
Native peoples who might visit areas targeted by
treatments for subsistence, religious, or other traditional
purposes. These procedures include (but are not limited
to) posting treated areas with appropriate signs at
common public access areas, observing restricted entry
intervals specified by the herbicide label, and providing
public notification in newspapers or other media when
the potential exists for public exposure. Additionally,
SOPs pertaining to fish, wildlife, and vegetation would
help minimize potential impacts to subsistence
resources.
Summary of Herbicide Impacts
The 2007 PEIS (USDOI BLM 2007a:4-148 to 4-149)
provides a general discussion of the potential impacts of
herbicide use on paleontological, cultural, and
subsistence resources. This information is summarized
in the sections that follow.
Paleontological Resources
Herbicides may have the potential to affect fossil
materials, depending on: 1) fossil type; 2) minerals; 3)
degree of fossil ization; and 4) whether the fossil is
exposed or buried. Herbicides may cause soil acidity to
increase, or cause other chemical changes to fossil
materials, such as discoloration or deterioration. More
likely, damage to fossil materials, if present, would
result from the use of wheeled equipment to apply
herbicides, particularly vehicles traveling off roads,
which could potentially crush fossil materials exposed
on the surface. Additionally, herbicide treatments are
more likely to affect researchers, students, or other field
personnel conducting paleontological research than the
paleontological resources themselves.
Cultural Resources
Herbicide treatments could potentially affect buried
organic cultural resources, but would be most likely to
have an effect on aboveground structures and traditional
cultural practices of gathering plant foods or materials
important to local tribes or groups. Some chemicals can
cause soil acidity to increase, which would result in
deterioration of artifacts — even some types of stone
from which artifacts are made. Application of chemical
treatments can also result in impacts such as altering or
obscuring the surfaces of standing wall masonry
structures, pictograph or petroglyph panels, and organic
materials. One study of the effects of glyphosate and
triclopyr on stone and masonry material found that both
active ingredients resulted in salt formation and color
change. Additionally, glyphosate can lead to a long¬
term increased rate of deterioration (Oshida 2011). No
other active ingredients were included in the study, but
it is assumed that other herbicides could adversely affect
certain materials as well. While chemicals may affect
the surface of exposed artifacts, these materials can
generally be removed without damage if treated soon
after exposure. Additionally, herbicide treatment SOPs
include protocols for identifying cultural resources and
developing appropriate measures to mitigate or
minimize adverse impacts.
Organic substances used as inactive ingredients in
herbicide formulations, such as diesel fuel or kerosene,
may contaminate the surface soil and seep into the
subsurface portions of a site. These organic substances
could interfere with the radiocarbon or Carbon- 14 (C-
14) dating of a site (USDOI BLM 1991).
Subsistence Resources
Non-target plants affected by herbicide treatments may
include species that are important to Native American
tribes or Alaska Native groups for traditional
subsistence, religious, or other cultural practices.
Impacts to these resources would be avoided through
local level consultation with tribes and groups to
identify areas where plant resources of importance are
located. The potential health risks associated with
exposure to/consumption of plant materials with
herbicide residues are discussed in the Herbicide
Impacts on Native American Health section.
Treatments to control noxious weeds and other invasive
species could benefit populations of native plant species
used as subsistence or for other traditional practices,
through restoration of native plant communities.
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Fish and wildlife used for subsistence could be
adversely affected through - temporary displacement
from treatment sites or exposure to herbicides. The Fish
and Aquatic Invertebrates and Wildlife Resources
sections provide more detailed information on potential
effects to wildlife from herbicide treatments.
Herbicide Impacts on Native American
Health
Risk Assessment Methodology
The potential risks to Native Americans from exposure
to herbicides used in BLM programs were evaluated
separately from risks to other public receptors (see
Human Health and Safety section in this chapter).
Native Americans could be exposed to higher levels of
herbicides as a result of subsistence and cultural
activities such as plant gathering and consumption of
fish caught in local streams. Therefore, risk levels
determined for Native American receptors reflect
unique exposure scenarios as well as typical scenarios
for public receptors, but with higher levels of exposure
than public receptors.
The risk assessments assume that the Native American
receptors (154-pound adult and 33-pound child) are
exposed to herbicides via dermal contact with spray,
dermal contact with sprayed foliage, ingestion of
drinking water from a sprayed pond, ingestion of berries
containing spray, dermal contact with water in a sprayed
pond, and ingestion of fish from a sprayed pond. These
exposure methods are discussed further in the following
sections, with additional detail provided in the 2007
PEIS (USDOI BLM 2007a:4-149 to 4-150).
Dermal Contact
For scenarios involving dermal contact with sprayed
vegetation, risk assessments assume the following:
• The 50 percentile surface area of the head,
lower legs, forearms, and hands are exposed to
the herbicide (884 square inches (in ) for adults
and 434 in2 for children; USEPA 2004).
• Native American receptors contact foliage for 3
hours per day of subsistence activities (Harper
et al. 2002).
• Herbicide is transferred from foliage to skin at
a rate of 171 in /hour for adults and 56
in2/hour for children (USEPA 2012e).
For scenarios involving swimming in a contaminated
pond, the exposure time was assumed to be 2.6 hours
per day (Harris and Harper 1 997), for 70 days per year.
The exposed surface area was assumed to be 2,790 in2
for an adult swimmer and 1,023 in2 for a child swimmer
(USEPA 2004).
Ingestion
Risk assessments assume that adult Native Americans
ingest 1 quart of water per day (Harper et al. 2002) from
a sprayed pond, and Native American children consume
half the adult rate, or 0.5 quart/day.
The berry ingestion scenario assumes that a Native
American adult consumes 0.7 pound (lb)/day (Harper
et. al. 2002) and a Native American child consumes
0.15 lb/day (per California Environmental Protection
Agency [CalEPA] 1996).
The adult fish ingestion rate was assumed to be 2
lbs/day based on a high fish diet scenario (Harper et al.
2002). The high fish diet consists primarily of fish
supplemented by big game; aquatic amphibians,
crustaceans, and mollusks; small mammals; and upland
game birds. For Native American children, the ingestion
rate was scaled by body weight to 0.4 lb/day (per
CalEPA 1996).
Since it is assumed that a pond used for swimming is
also a source of drinking water, incidental ingestion of
contaminated water during swimming was not evaluated
separately; it is included in the drinking water scenario.
The methodology for estimating potential risk to human
health from exposure to herbicides is discussed in the
Human Health and Safety section, under the Human
Health Risk Assessment Methodology subsection.
Human Health Risks Associated with the Three New
Herbicides
Native American adults face the same risks that public
receptors face, as well as additional risks associated
with exposure to some herbicides as a result of unique
subsistence practices or increased time spent in treated
areas. The risks to public receptors are discussed in the
Human Health and Safety section. As shown in Table
4-15, there are no risks to public receptors from
exposures resulting from routine use (typical or
maximum application rate) or accidental scenarios.
Additionally, there are no risks to Native American
adults or children under any of the modeled exposure
scenarios. These results indicate that aminopyralid.
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fluroxypyr, and rimsulfuron do not pose an
unacceptable risk to Native American receptors, even
under worst-case accidental exposure scenarios.
See the Vegetation, Fish and Aquatic Invertebrates, and
Wildlife Resources sections in this chapter for more
information on the potential risks of the three new
herbicides to resources used by Native Americans.
Impacts by Alternative
The following is a discussion of how risk from
herbicides would vary under each herbicide treatment
alternative. Under all alternatives, the maximum
acreage treated annually is assumed to be the same, with
only the relative amount of each active ingredient used
varying among the different alternatives. Under all
alternatives, the BLM would use herbicide treatments
for resource benefit, which would have beneficial
effects on native plants and wildlife used by Native
American tribes. Additionally, under all alternatives
herbicide usage in Alaska would remain low, estimated
at a maximum of 1,000 acres per year. Under all
alternatives, the BLM would collaborate with Native
American tribes and Alaska Native groups to identify
and protect culturally significant plants used for food,
basket weaving, fibers, medicine, and ceremonial
purposes, and would use minimal impact treatments
where culturally significant species are known to occur.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under this alternative, only the 18 previously approved
herbicides would be available for use. Risks to
paleontological and cultural resources, and to human
health would be the same as those discussed under
Alternative B of the 2007 PEIS (USDOI BLM 2007a:4-
151). There are risks to Native American adults
associated with exposure to diquat when it is
accidentally spilled or applied at the maximum rate (low
risk), and with the consumption of fish contaminated
with 2,4-D (high risk) or hexazinone (moderate risk).
There are risks to Native American children associated
with exposure to diquat when it is applied at the typical
rate. There are also risks associated with berry picking
in areas sprayed with diquat at the typical rate. Native
American adults and children residing near the
treatment area face additional risks (i.e., low risk from
exposure to diquat when it is applied at the typical or
maximum rate, and moderate risk from diquat when
accidentally spilled; low risk from exposure to fluridone
when it is accidentally spilled).
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, aminopyralid, fluroxypyr, and
rimsulfuron would be available for use in herbicide
treatment programs, and as a result, there would be
lower usage of other herbicides, particularly imazapic,
glyphosate, and picloram. All of these herbicides have
no to low human health risks. Of the herbicides with
higher human health risks, use of 2,4-D would be
slightly lower than under the No Action Alternative
(approximately 1 percent fewer acres treated),
indicating that risks associated with consumption of fish
contaminated by 2,4-D would also be slightly lower.
Other herbicides associated with human health risks
(diquat, fluridone, and hexazinone) would continue to
make up a very small component of the total herbicide
usage. Generally, human health risks to Native
Americans would be similar to those under the No
Action Alternative.
Alternative C - No Aerial Application of New
Herbicides
Under this alternative, human health risks to Native
American receptors would be similar to those under the
Preferred Alternative and the No Action Alternative.
The new herbicides would not be applied aerially,
eliminating certain exposure pathways for Native
American receptors. According to the HHRA, aerial
application scenarios are generally associated with
greater overall human health risks than ground-based
methods. However, based on information for
occupational receptors (see Table 4-14), risk levels for
the three new herbicides are similar for aerial and
ground applications. Additionally, restriction of aerial
applications of the new chemicals would not reduce
aerial spraying of herbicides, as different active
ingredients would be used where aerial spraying is
needed.
Under this alternative, herbicides with higher human
health risks would be used at roughly the same levels as
under the No Action Alternative, over approximately 1
percent more land area than under the Preferred
Alternative. In general human health risks to Native
American receptors would be similar to those under the
other alternatives.
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Alternative D - No Use of New Acetolactate
Synthase-inhibiting Herbicides (No Rimsulfuron)
Risks to Native American receptors from exposure to
herbicides under Alternative D would be similar to
those under the other alternatives. Rimsulfuron would
not be used, and as a result the use of glyphosate and
imazapic would be higher than under the other action
alternatives (similar to the No Action Alternative). All
three of these active ingredients pose no to low risk to
Native American receptors, so there would be little
difference, from a human health standpoint, associated
with restricting the use of rimsulfuron. Use of 2,4-D
under this alternative would be slightly lower than
under the No Action Alternative and Alternative C (1
percent fewer acres), indicating that risks associated
with consumption of fish contaminated by 2,4-D would
also be slightly lower. In general, human health risks to
Native Americans would be similar to those under the
other alternatives.
Mitigation for Herbicide Treatment
Impacts
The BLM would continue to follow all of the SOPs for
herbicide treatments in the 2007 PEIS that apply to
paleontological and cultural resources (USDOI BLM
2007a:Table 2-8). Additionally, the BLM would follow
the mitigation measures identified in the ROD (USDOI
BLM 2007b), which are specific to certain previously
approved herbicides and would not apply to the new
active ingredients (but would apply if a mixture with
one or more of these previously approved herbicides is
used).
Given the low toxicity of aminopyralid, fluroxypyr, and
rimsulfuron to humans, no additional mitigation
measures are recommended for herbicide treatments
with these active ingredients.
Visual Resources
Visual resources consist of land, water, vegetation,
wildlife, and other natural or manmade features visible
on public lands. Vast areas of grassland, shrubland,
canyonland, and mountain ranges on public lands
provide scenic views to users of public lands. The
vegetation of an area, including the presence of native
species and noxious weeds, affects its scenic qualities.
Herbicide treatments also affect the visual quality of the
landscape to varying degrees by killing target vegetation
and creating a more open, “browned” landscape. Scenic
impacts from herbicide treatments are most likely to be
associated with projects that 1) reduce the visual rating
of the treatment site over the long term, or 2) result in
short- or long-term degradation of high-sensitivity
visual resources.
Scoping Comments and Other Issues
Evaluated in the Assessment
No scoping comments specific to visual resources were
received by the BLM. However, the visual quality of the
landscape is seen as a component of public benefit, and
management of public lands must take into account
visual resources. Lands located in highly visible areas
along roads typically provide this benefit to the largest
segment of the population.
Standard Operating Procedures
The 2007 PEIS identified several SOPs that would help
reduce the impact of herbicide treatments on visual
resources:
• Minimize the use of broadcast foliar
applications in sensitive watersheds to avoid
creating large areas of browned vegetation.
• Consider the surrounding land use before
assigning aerial spraying as an application
method.
• Avoid aerial spraying near agricultural or
densely populated areas, where feasible.
• At areas such as visual overlooks, leave
sufficient vegetation in place, where possible,
to screen views of vegetation treatments.
• Use SOPs that minimize off-site drift and
mobility of herbicides (e.g., do not treat when
winds exceed 10 mph; minimize treatment in
areas where herbicide runoff is likely; and
establish appropriate buffer widths between
treatment areas and residences), to contain the
visual changes to the intended treatment area.
• If the area is a Class 1 or II visual resource,
ensure that the change to the characteristic
landscape is low and does not attract attention
(Class I), or if seen, does not attract the
attention of the casual viewer (Class II).
• Lessen visual impacts by 1) designing projects
to blend in with topographic forms; 2) leaving
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some low-growing trees or planting some low-
growing tree seedlings adjacent to the
treatment area to screen short-term effects; and
3) revegetating the site following treatment.
• When restoring treated areas, design activities
to repeat the fonn, line, color, and texture of
the natural landscape character to meet
established VRM objectives.
These SOPs are designed to minimize visual impacts
associated with killing invasive plants and removing
vegetation. Additional guidance is provided in BLM
Manual Handbook H-8431-1, Visual Resource Contrast
Rating (USDOl BLM 1986b). No additional mitigation
for herbicide treatments was proposed in the 2007 PEIS
or specified in the 2007 ROD.
BLM Assessment of Visual Resource
Values
As discussed in BLM Handbook H-8410-1, Visual
Resource Inventory (USDOl BLM 1986a), potential
visual impacts from proposed activities must be
assessed to detennine whether the potential impacts will
allow the management objective for the affected area to
be met. A visual contrast rating is used, in which the
project features are compared with the major features in
the existing landscape, using basic design elements of
form, line, color, and texture. This process is described
in BLM Handbook H-8431-1, Visual Contrast Rating
(USDOl BLM 1986b). Activities or modifications in a
landscape that repeat the basic design elements are
thought to be in harmony with their surroundings.
Modifications that do not harmonize are said to be in
contrast with their surroundings.
Visual resource assessments would be conducted at the
project level to determine the potential impacts to visual
resources associated with defined vegetation treatment
projects.
Summary of Herbicide Impacts
As the overall vegetation treatment program is
programmatic in scope, no visual contrast rating was
conducted for the 2007 PEIS. It is expected that this sort
of analysis would occur at the local level for site-
specific herbicide treatment programs. Instead, the 2007
PEIS gave a general overview of how herbicide
treatments affect the visual quality of treated areas
(USDOl BLM 2007a:4-154). As the new active
ingredients affect vegetation in the same general way as
some of the currently approved active ingredients, the
general impact analysis for herbicide use in the 2007
PEIS would continue to apply even with the addition of
aminopyralid, fluroxypyr, and rimsulfuron to the list of
approved active ingredients.
In general, herbicide treatments have short-term adverse
effects and long-term positive effects on visual
resources. Herbicide treatments create openings and
patches of discolored vegetation that may contrast
markedly from surrounding areas of green vegetation.
However, these impacts would begin to disappear
within one to two growing seasons in most landscapes.
Over the long term, herbicide treatments would likely
improve visual resources on public lands by removing
infestations of invasive plants and rehabilitating
degraded ecosystems. Native-dominated communities
tend to be more visually appealing than plant
communities that have been overtaken by noxious
weeds or other undesired species. Additionally, control
of species that serve as fuels for wildland fire would
help reduce the size and intensity of future wildfires. A
reduced risk of fire would benefit visual resources, as
wildland fires substantially degrade the visual quality of
natural areas.
Impacts by Alternative
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue to implement vegetation treatment projects
using the herbicides currently approved under the ROD
for the 2007 PEIS. As discussed in the 2007 PEIS,
short-term adverse impacts to visual resources
associated with herbicide use would continue to occur.
The most dramatic effects would be seen in states with
the most acres treated, such as New Mexico, Idaho, and
Wyoming, and in project areas where large acreages are
treated.
Herbicide treatments in drier states, such as New
Mexico, Nevada, and Wyoming, could have a reduced
visual impact relative to those in more lush states
because visual color contrast between natural and
“browned” treated areas would be less dramatic.
Landscapes containing a large component of invasive
species often contrast with surrounding natural
landscapes and have a negative visual impact. For
example, cheatgrass often turns brown during summer,
while native species usually remain green long into
summer or fall. Over the long term, ongoing vegetation
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treatments under this alternative would have a positive
impact on visual resources,- as invasive plants and
unwanted vegetation would be removed, and visually
preferable native vegetation and ecosystems would
become reestablished.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under this alternative, impacts to visual resources
would be much the same as those under the No Action
Alternative. A comparable acreage of public lands
would be impacted by vegetation treatments, and the
geographic locations and size of treatments would be
similar to those discussed under the No Action
Alternative. It is possible that the availability of the
three new active ingredients would result in some
changes to treatments, but it is expected that these
changes would be minor.
If vegetation treatments prove to be more effective as a
result of being able to use aminopyralid, fluroxypyr, and
rimsulfuron, there could be greater short-term visual
impacts associated with removal of target vegetation.
However, associated long-term benefits of recoveiy of
native plant communities could also be greater.
Alternative C - No Aerial Application of New
Herbicides
While aminopyralid, fluroxypyr, and rimsulfuron would
not be applied aerially under Alternative C, the
currently approved active ingredients would continue to
be available for aerial applications. Therefore, the
overall extent of aerial treatments with herbicides
should not differ substantially from that under
Alternatives A and B. The total acreage of public lands
affected by herbicide treatments would be the same as
under the other alternatives, and the geographic
locations and size of treatments would be similar to
those discussed under the other alternatives. Short-term
impacts and long-term beneficial effects to visual
resources would be similar to those under the other
alternatives.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
While rimsulfuron would not be available for use under
this alternative, the 1 8 currently approved active
ingredients would be available for use, in addition to
aminopyralid and fluroxypyr. The maximum total
acreage of public lands affected by herbicide treatments
would be the same as under the other alternatives, and
the geographic locations and size of treatments would
be similar. Therefore, short-term impacts and long-term
beneficial effects to visual resources would be similar to
those under the other alternatives
Mitigation for Herbicide Treatment
Impacts
The BLM’s SOPs for minimizing impacts to visual
resources, listed earlier in this section, would continue
to be implemented when conducting vegetation
treatments. These SOPs would help reduce short-term
impacts associated with all herbicides, including
aminopyralid, fluroxypyr, and rimsulfuron.
No mitigation measures are proposed for visual
resources.
Wilderness and Other Special
Areas
Because of their special status, wilderness and other
special areas have strict guidelines for vegetation
treatments. These guidelines prohibit activities that
degrade the quality, character, and integrity of these
protected lands. Manipulation of vegetation through use
of herbicides and other methods is generally not
permitted, although there are exceptions in the case of
emergencies (e.g., wildfire threatening non-federal
lands), actions taken to recover a federally listed
threatened or endangered species, control of non-native
species, and restoration actions where natural processes
alone cannot recover the area from past human
intervention (USDOI BLM 2012e).
In WSAs, natural processes are relied on to maintain
native vegetation and natural disturbance regimes.
However, vegetation treatments, including herbicide
applications, are allowed if they meet the non¬
impairment standard (i.e., temporary and not creating
surface disturbance), or if they are conducted in
emergency circumstances, to protect or enhance
wilderness characteristics, are grandfathered uses or
valid existing rights, or are done to recover a federally
listed or candidate species (USDOI BLM 2012f).
There are no set restrictions on vegetation treatments in
other types of special areas. However, the unique
characteristics of these areas would be considered when
preparing management plans for treatment activities.
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Herbicides may be applied in wilderness and other
special areas under circumstances described in local
Resource Management Plans or relevant NEPA
documents. Herbicide treatments could affect these
areas by altering the existing plant species composition
and structure, and altering the visual qualities of treated
areas.
Scoping Comments and Other Issues
Addressed in the Assessment
None of the scoping comments received by the BLM
were specific to wilderness or other special areas.
Standard Operating Procedures
The 2007 PEIS identified several SOPs to reduce the
risk of spreading noxious weeds, prevent the
establishment of new invaders, and promote public
awareness to be followed in wilderness areas and other
special areas:
• Encourage backcountry pack and saddle stock
users to feed their livestock only weed-free
feed for several days before entering a
wilderness area.
• Encourage stock users to tie and/or hold stock
in such a way as to minimize soil disturbance
and loss of native vegetation.
• Revegetate disturbed sites with native
vegetation if there is no reasonable expectation
of natural regeneration.
• Provide educational materials at trailheads and
other wilderness entry points to educate the
public on the need to prevent the spread of
invasive plants.
• Use the “minimum tool” to treat noxious and
invasive vegetation, relying primarily on use of
ground-based tools, including backpack pumps,
hand sprayers, and pumps mounted on pack
and saddle stock.
• Use chemicals only when they are the
minimum method necessary to control invasive
plants that are spreading within the wilderness
or threaten lands outside the wilderness.
• Give preference to herbicides that have the
least impact on non-target species and on the
wilderness environment.
• Implement herbicide treatments during periods
of low human use, where feasible.
• Address wilderness and other special areas in
management plans.
• Maintain adequate buffers for Wild and Scenic
Rivers (14 mile on either side of river, Vi mile in
Alaska).
These SOPs would continue to apply to herbicide
treatments involving the three new herbicides. No
mitigation measures specific to wilderness or other
special areas were identified in the 2007 PEIS.
However, all pertinent mitigation in the Vegetation,
Fish and Other Aquatic Resources, Wildlife Resources,
Recreation, and Human Health and Safety sections
would potentially be applicable to herbicide treatments
in these areas.
Summary of Herbicide Impacts
The 2007 PEIS provides a general overview of the
effects of herbicide treatments on wilderness and other
special areas (USDOI BLM 2007a:4-156 to 4-157). The
discussion addresses herbicide treatments in general,
and does not include a discussion of impacts specific to
any of the active ingredients currently approved for use.
In general, herbicide treatments in wilderness and other
special areas would have short-term adverse effects and
long-term positive effects on special status area values.
Herbicide treatments could result in short-term closures
of special areas, and in disturbance and removal of
vegetation from treated areas. In the case of wilderness
areas and WSAs, only treatments that improve the
natural condition of these areas would be allowed.
Furthermore, use of motorized equipment to apply
herbicides would need to be authorized based on further
site-specific NEPA and minimum requirements
analysis, in accordance with BLM policy.
Long-term effects of treatments in special areas would
be beneficial, as noxious weed infestations and risk of
future catastrophic wildfires would be reduced in these
areas. The reduction of hazardous fuels and noxious
weeds on lands adjacent or near to special areas would
provide long-term benefits by reducing the likelihood
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ENVIRONMENTAL CONSEQUENCES
that noxious weeds would spread onto these unique
areas, or that a catastrophic wildfire would bum through
them, thus degrading their unique qualities. Herbicide
treatments in wilderness areas and WSAs, if successful,
would potentially improve the naturalness component of
wilderness character.
Impacts by Alternative
Generally, there would be few differences between the
alternatives as far as potential effects to wilderness and
other special areas, as the extent of treatments in these
areas would likely be the same under all the alternatives.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue its herbicide treatments in wilderness and other
special areas with the 1 8 currently approved herbicides.
For example, herbicide treatments would continue to be
used to control incipient populations of noxious weeds
and other invasive species in order to prevent the
expansion of these populations in wilderness and other
special areas. Additionally, the risk of wildland fire
could be reduced in these areas. Therefore, treatments
would benefit the targeted areas and help protect their
unique qualities.
Special areas that receive herbicide treatments would
continue to be affected by disturbance associated with
access to the treatment site (particularly for repeat
treatments), and by a temporary reduction in the
“naturalness” of the treated area with the loss of target
vegetation. Additionally, users of these areas might be
impacted by short-term closures following herbicide
applications (see the Recreation section for more
information). In most cases, the benefits of eradicating
noxious weeds and reducing the risk of wildland fire
would outweigh the potential short-term effects of
chemical treatments.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under the Preferred Alternative, effects to wilderness
and other special areas would be similar to those under
the No Action Alternative. Herbicide treatments in these
areas would likely involve the three new active
ingredients, as warranted, and could be more effective at
controlling target species as a result. However, given
that the overall method and extent of treating wilderness
and species areas would be more or less the same as
under the No Action Alternative, there would be only
minor differences as far as effects to these areas.
The three new active ingredients are all of low risk to
human health (see the Human Health and Safety section
for additional information), with no risk to public
receptors under routine or accidental exposure
pathways. However, the active ingredients that are
likely to decrease in usage as a result of adding the three
new active ingredients also have low to no risk to
human health. Therefore, there would be very little
difference between the Preferred Alternative and the No
Action Alternative as far as potential impacts to the
health of users of wilderness and other special areas
from herbicide treatments.
Alternative C - No Aerial Application of New
Herbicides
While the three new herbicides would not be applied
aerially under Alternative C, the total extent of aerial
treatments using herbicides would be similar to that
under Alternative B, as other herbicides could still be
applied via this method. Overall, it is not expected that
aerial applications would be used to target wilderness
and other special areas, as treatments would generally
not be this widespread. Impacts under this alternative
would be similar to those under the other alternatives,
with short-term adverse effects associated with
treatments and long-term benefits associated with the
removal of noxious weeds. Potential impacts to the
health of users of wilderness and other special areas
from herbicide treatments would also be similar to those
under the other alternatives.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Rimsulfuron would not be used to treat vegetation under
Alternative D, but treatments in wilderness and other
special areas could be completed with any of the
currently approved herbicides, aminopyralid, or
fluroxypyr. The extent of treatments in wilderness and
other special areas and the species targeted would be
similar to those under the other alternatives. Therefore,
effects to these areas would also be similar, with short¬
term adverse effects associated with treatments and
long-term benefits associated with the removal of
noxious weeds. Potential impacts to the health of users
of wilderness and other special areas from herbicide
treatments would also be similar to those under the
other alternatives.
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Mitigation for Herbicide Treatment
Impacts
The BLM's SOPs for minimizing impacts to wilderness
and other special areas, listed earlier in this section,
would continue to be implemented when conducting
vegetation treatments. These SOPs would help reduce
short-term impacts associated with all herbicides,
including aminopyralid, fluroxypyr, and rimsulfuron.
Mitigation measures that may apply to wilderness and
special area resources are associated with human and
ecological health and recreation. Please refer to the
Vegetation, Fish and Other Aquatic Resources, Wildlife
Resources, Recreation, and Human Health and Safety
sections of this chapter. No mitigation measures are
proposed specifically for wilderness or other special
areas.
Recreation
In areas that support high recreation use, the goals of
vegetation treatments include maintaining the
appearance of the area and protecting visitors from the
adverse effects of contact with noxious weeds and other
invasive/unwanted species. In these areas, herbicide use
is generally limited to spot treatments. However, larger
herbicide treatments would be more likely with
increasing distance away from high-use visitor areas.
Thus, hikers, hunters, campers, horsemen, livestock
owners, and users of plant resources for cultural, social,
and economic purposes would be at the greatest risk of
coming into contact with herbicide treatment areas.
Scoping Comments and Other Issues
Evaluated in the Assessment
No scoping comments specific to recreation were
received by the BLM.
Standard Operating Procedures
The 2007 PEIS presented several SOPs that the BLM
follows to help minimize the negative impacts of
herbicide treatments on recreation:
• Schedule treatments to avoid peak recreational
use times, while taking into account the
optimum management period for the targeted
species.
• Notify the public of treatment methods,
hazards, times, and nearby alternative
recreation areas.
• Adhere to entry restrictions identified on the
herbicide label for public and worker access.
• Post signs noting exclusion areas and the
duration of exclusion, if necessary.
• Use herbicides during periods of low human
use, where feasible.
These SOPs would continue to apply to herbicide
treatments involving the three new active ingredients.
Additionally, SOPs identified in the Human Health and
Safety, Fish and Aquatic Resources, and Wildlife
Resources sections would further reduce risks to
recreationists and the resources they use.
Summary of Herbicide Impacts
The 2007 PEIS provides a general discussion of the
potential effects of herbicide treatments on recreation
(USDOI BLM 2007a:4-160 to 4-161). This general
effects analysis would also apply to treatments
involving the three new herbicides, and is briefly
summarized here.
Herbicide treatments would have short-term negative
impacts and long-term positive impacts on recreation.
During treatments, there would be some scenic
degradation, as well as distractions to users (e.g., noise
from machinery). In addition, there would be some
human health risks to recreationists associated with
exposure to herbicides. These risks are discussed in
more detail in the Human Health and Safety section.
The three new herbicides generally pose very little risk
to human health for public receptors, even under
scenarios involving an accidental spraying by an
herbicide, entering a treated area soon after herbicide
application, or accidentally coming into contact with
herbicides that have drifted downwind. Finally, some
areas would be off-limits to recreation activities as a
result of treatments, generally for a few hours or days,
but potentially for at least one full growing season or
longer depending on the treatment. In most cases,
recreationists would be able to find alternative sites
offering the same amenities, but a lessened experience
could result if concentrated use occurred in these
alternative sites.
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ENVIRONMENTAL CONSEQUENCES
Over the long term, herbicide treatments would have a
positive effect on recreation, through the removal of
undesirable vegetation on treated lands. Herbicide
treatments would likely return public lands to a more
“natural” or desirable condition, which hikers and
nature enthusiasts would likely value over degraded
lands. In addition, the increased aesthetic value of
treated sites would benefit most recreational users.
Treatments to reduce fuels would reduce the risk of
wildfire in or near recreation areas. Additionally,
treatment of sites to restore native vegetation would
enhance fish and wildlife habitat, to the benefit of
hunters, birdwatchers, and other users of these
resources.
Impacts by Alternative
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under the No Action Alternative, the BLM would
continue its vegetation treatments with the 18 active
ingredients that are currently approved for use. This
alternative corresponds to the Preferred Alternative in
the 2007 PEIS (USDOI BLM 2007a:4-162). The
maximum acres of public lands treated with herbicides
would remain at 932,000 annually, and the states with
the most treatments would continue to include Idaho,
Nevada, Wyoming, and New Mexico. While these
states were estimated to account for 76 percent of
treatment acres under this alternative, they accounted
for only 18 percent of visitor days during 2012 (USDOI
BLM 2012b). Therefore, it is likely that an extensive
portion of the land affected by herbicide treatments
would occur in areas with a relatively low density of
recreational visitors.
Under this alternative, short-term impacts and long-term
benefits would occur on up to 932,000 acres of lands
annually. Depending on the success of treatments, it is
expected that degradation of public lands from wildland
fires and infestations of invasive plants would decrease,
and recreational users would be able to have improved
outdoor experiences.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
This alternative would allow aminopyralid, fluroxypyr,
and rimsulfuron to be used in the BLM’s herbicide
treatment projects, allowing increased flexibility for
meeting treatment objectives. The maximum land area
treated and the states with the largest amount of
treatment acres would be the same as under the No
Action Alternative. Therefore, the nature, extent, and
intensity of impacts to recreation would be similar to
those under the No Action Alternative.
The long-term benefits associated with this alternative
would also be similar to those under the No Action
Alternative, given that the program goals and target
species would not change. Allowing use of the three
new herbicides could result in more effective
treatments, which would have a slightly higher degree
of benefit to recreation than under the No Action
Alternative.
Alternative C - No Aerial Application of the New
Herbicides
It is unlikely that aerial spraying would occur in high
public use recreational areas under any of the
alternatives. Although the new herbicides would not be
applied aerially under Alternative C, aerial applications
of currently approved herbicides would still occur in
dispersed use areas at levels similar to those under the
other alternatives. The maximum land area treated, and
the states with the most treatment acres, would be the
same as under the other alternatives. Therefore the
nature, extent, and intensity of impacts to recreation also
would be similar to those under the other alternatives.
The long-term benefits associated with Alternative C
would be similar to those under the other alternatives,
with a reduction in degradation of public lands used for
recreation by invasive plants and wildland fire.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
While use of rimsulfuron would not be allowed under
Alternative D, herbicide treatments would be completed
with the 18 currently approved herbicides, as well as
aminopyralid and fluroxypyr. The maximum land area
treated and the states with the largest treatment acreage
would be the same as under the No Action Alternative
and all of the action alternatives. Therefore, impacts to
recreational sites and recreational users would be
similar to those under the other alternatives.
The long-term benefits to recreation under this
alternative would also be similar to those under the
other alternatives. Program goals and target species
would not change, so the only differences would be in
tenns of the effectiveness of treatments. Rimsulfuron
would not be available to treat cheatgrass, but other
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ENVIRONMENTAL CONSEQUENCES
herbicides such as imazapic and glyphosate would.
Depending on the location and type of treatment, these
currently approved herbicides may be less effective than
rimsulfuron at controlling annual grasses in certain
scenarios.
Mitigation for Herbicide Treatment
Impacts
The BLM's SOPs for minimizing impacts to recreation,
listed earlier in this section, would continue to be
implemented when conducting vegetation treatments.
These SOPs would help reduce short-term impacts
associated with all herbicides, including aminopyralid,
fluroxypyr, and rimsulfuron.
Mitigation measures that may apply to recreational
resources are associated with human and ecological
health. Please refer to the Vegetation, Fish and Other
Aquatic Resources, Wildlife Resources, and Human
Health and Safety sections of this chapter. No
mitigation measures that pertain specifically to
recreation are proposed.
Social and Economic Values
Introduction
Herbicide treatments have the potential to affect people,
communities, and economies in each of the 1 7 western
states that could receive treatments. Public lands support
ranching (grazing leases), mining, active and passive
recreation opportunities, and a myriad of other activities
that westerners rely on. In addition to these resource
uses, public lands provide social values that may not be
readily quantifiable. The large expanses of federal lands
are a significant contributor to the open spaces that
define the “sense of place” in many parts of the West.
Therefore, actions that affect federal lands, such as the
application of herbicides, have the potential to affect the
economic and social environment of the region.
The type of social and economic analysis presented in
this PEIS will be similar to what was provided in the
2007 PEIS. Given its programmatic nature, this PEIS
will address only general effects and expected trends,
with more detailed, site-specific analyses conducted at
the local level during the development of herbicide
treatment projects. Additionally, since the bulk of the
analysis in the 2007 PEIS was general to herbicide
treatments, and not specific to the herbicides being
considered, much of the analysis is the same for
treatments involving the three new herbicides. This
information will be referenced and summarized, as
appropriate, with additional discussion that involves any
new information that is available.
Scoping Comments and Other Issues
Evaluated in the Assessment
Several scoping comments were concerned with the
potential economic impacts to home and commercial
gardeners and composters associated with use of the
new herbicides. Aminopyralid, in particular, was
identified as a concern based on reports and personal
observations about the persistence of this herbicide in
manure, compost materials, and hay, and subsequent
damage to crops where the contaminated materials were
used. Additionally, a few comments cited potential
damage to crops from movement of herbicides on
windblown dust and off-site drift.
Other comments addressed the cost of the new
herbicides relative to herbicides that are currently being
used, and the cost of herbicide treatments in general,
relative to other treatment methods. There was general
support for aminopyralid, fluroxypyr, and rimsulfuron
in terms of their effectiveness and the potential to
reduce the cost of herbicide treatments.
As discussed in the 2007 PEIS (USDOI BLM 2007a:4-
164), the interests of all stakeholders must be
considered when planning treatment programs, and the
alternative selected for implementation must balance
out the interests of national and local stakeholders.
Standard Operating Procedures
The 2007 PEIS (USDOI BLM 2007a:4-164 to 4-165)
lists SOPs that have been designed by the BLM to
reduce potential adverse impacts to social and economic
conditions from the application of herbicides:
• Consider surrounding land use before selecting
aerial spraying as a treatment method, and
avoid aerial spraying near agricultural or
densely-populated areas.
• Post treated areas and specify reentry or rest
times, if appropriate.
• Notify adjacent landowners prior to treatment.
• Notify grazing permittees of livestock feeding
restrictions in treated areas if necessary, as per
label instructions.
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• Notify the public of the project to improve
coordination and avoid potential conflicts and
safety concerns during implementation of the
treatment.
• Control public access until potential treatment
hazards no longer exist, per label instructions.
• Observe restricted entry intervals specified by
the herbicide label.
• Notify local emergency personnel of proposed
treatments.
• Avoid aerial spraying during periods of adverse
weather conditions (imminent snow or rain,
fog, or air turbulence).
• During helicopter applications, apply
herbicides at an airspeed of 40 to 50 mph, and
at an elevation of about 30 to 45 feet above
ground.
• Comply with herbicide-free buffer zones to
ensure that drift will not affect crops or nearby
residents/landowners.
• Use spot applications or low-boom broadcast
applications where possible to limit the
probability of contaminating non-target food
and water sources, especially vegetation over
areas larger than the treatment area.
• Consult with Native American tribes and
Alaska Native groups to locate any areas of
vegetation that are of significance to the tribe
and that might be affected by herbicide
treatments.
• Work with Native American tribes and Alaska
Native groups to minimize impacts to
vegetation of cultural significance to the tribes.
• To the degree possible within the law, hire
local contractors and workers to assist with
herbicide application projects.
• To the degree possible within the law,
purchase materials and supplies, including
chemicals, for herbicide treatment projects
through local suppliers.
• To minimize fears based on lack of
information, provide the public with
educational information on the need for
vegetation treatments and the use of
herbicides in an I PM program for projects
proposing local use of herbicides.
These SOPs would continue to apply to herbicide
treatments involving the new chemicals. No additional
mitigation for social and economic values were
identified in the 2007 PEIS.
Impact Assessment Assumptions
This impact assessment generally makes the same
assumptions that were discussed in the 2007 PEIS
(USDOI BLM 2007a:4-165). Site-specific information
on likely use of the three new herbicides is unavailable,
and no information on specific application parameters
will be included. Other assumptions include the
following:
• Communities that are particularly dependent on
a single industry (e.g., ranching and recreation-
dependent communities) are more susceptible
to the effects of herbicide use than other
communities.
• The proposed use of the new herbicides would
only apply to public lands.
• None of the alternatives would significantly
affect ongoing, long-term trends such as the
increasing demand for outdoor recreation or
growth in urban, suburban and rural
populations.
• Treatments involving the new herbicides would
meet the project objective of improving the
effectiveness of the BLM’s vegetation
treatment programs. In turn, the cost of
wildland fire suppression and the loss of life
and property would be reduced.
Summary of Herbicide Impacts
The 2007 PEIS provides a general discussion of the
effects of herbicide treatments on social and economic
values (USDOI BLM 2007a:4-165 to 4-166). These
effects would continue to apply to herbicide treatments
involving the three new herbicides. They generally
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include social effects deriving from perceptions of
health and safety risks for different chemicals; the
success or failure of treatments using different
chemicals; economic effects associated with changes in
range productivity, wildfire risk, and access or
attractiveness for recreation activities, and associated
changes in employment and income; and direct and
indirect economic effects tied to the cost of applying the
herbicides.
Impacts of Aminopyralid
The BLM estimates that the cost per acre to apply
aminopyralid, based on the typical application rate of
this active ingredient, would be S6.73 per acre.
Therefore, aminopyralid would be relatively
inexpensive to apply, based on a review of the range of
costs for the currently approved active ingredients
provided in Table 3-21 ($1 to $1 15 per acre).
Use of aminopyralid is a concern from an economic
standpoint because of its persistence in plant materials.
If manure or compost originating from plant materials
that were previously treated with aminopyralid is used
on personal or commercial crops, loss of broadleaf
crops may occur. Incidents of crop and garden damage
as a result of using organic matter with aminopyralid
residues have been reported (Washington State
University Extension 2011). In 2010, several farmers
and gardeners in Washington State lost most of their
vegetable crops as a result of herbicide residues from
composted dairy manure (Oregon State University
2011). Therefore, this active ingredient can be
associated with economic impacts to private landowners
if not used in accordance with the label directions. The
BLM would follow all label instructions to prevent
impacts to crops and gardens associated with use of this
herbicide, including restrictions on grazing where
applicable. The BLM would not export manure, plant
residues, or other materials that may be treated with
aminopyralid for use as soil amendments.
Because aminopyralid is an active ingredient that targets
broadleaf plants, it could be associated with damage to
off-site crops as a result of herbicide drift. As discussed
in the vegetation section, buffers would be required to
prevent impacts to non-target plants, which would
include commercial crops and other broadleaf plants.
Therefore, the buffers specified in Table 4-8 would be
applicable to treatments with aminopyralid that are near
private lands.
Impacts of Fluroxypyr
According to estimates from the BLM, the cost per acre
to apply fluroxypyr is $16.53, based on the typical
application rate. It is relatively expensive, compared to
the costs of the currently approved active ingredients
(Table 3-21), but would only be used in small
quantities.
Like aminopyralid, fluroxypyr targets broadleaf plants,
and therefore may adversely affect nearby croplands
and other private lands as a result of herbicide drift. As
discussed in the Vegetation section, buffers would be
required to prevent impacts to non-target plants, which
would include commercial crops and other broadleaf
plants. Therefore, the buffers specified in Table 4-8
would be applicable to treatments with aminopyralid in
the vicinity of private lands.
Impacts of Rimsulfuron
The BLM estimates that the cost per acre to apply
rimsulfuron, based on the typical application rate of this
active ingredient, would be $2.81 per acre. It is
relatively inexpensive, compared to the costs associated
with the currently approved active ingredients (Table
3-21). Rimsulfuron is substantially cheaper than
imazapic, which costs $10 to $15 per acre, depending
on the mode of application.
Rimsulfuron has activity on annual plants, and could
harm certain crops and other non-target plants grown
commercially. Buffers would be required to prevent
impacts to non-target plants on private lands, as
discussed in the Vegetation section and Table 4-8, to
reduce the potential for adverse economic effects to
nearby landowners.
Impacts by Alternative
Impacts Common to All Alternatives
The 2007 PEIS (USDOI BLM 2007a:4- 1 7 1 ) includes a
substantial discussion on the impacts of herbicide
treatments on population and demography,
environmental justice, protection of children,
employment and income, perceptions and values,
invasive species control cost savings, wildland fire cost
savings, economic activity and public revenues
generated from BLM lands, expenditures by the BLM,
and effects on private property. Because the three new
active ingredients would be incorporated into larger
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herbicide treatment programs, with the same maximum
acreage assumed, these general impacts associated with
herbicide treatments would continue to occur.
Differences would be limited to which active
ingredients would be used. These differences are
captured in the earlier discussion specific to each of the
three new active ingredients, as well as in the
discussions for each of the alternatives.
Under all alternatives, herbicide treatments could occur
on public lands near minority or low-income
populations. As discussed in the 2007 PEIS (USDOI
BLM 2007a:4-167), it is not possible to determine
whether these populations would be disproportionately
affected at the broad scale of analysis in this PEIS.
Specific evaluation of environmental justice impacts
would be conducted in concert with environmental
analyses for site-specific treatment project proposals.
Additionally, ongoing consultation and close
communication with Indian tribes about the locations
and timing of future herbicide treatments would
continue to address potential impacts to Native
American populations.
Impacts of Individual Alternatives
Alternative A - Continue Present Herbicide Use
(No Action Alternative)
This alternative corresponds to the Preferred Alternative
under the 2007 PEIS (USDOI BLM 2007a:4-172 to 4-
173). Herbicide treatments would occur on up to
932,000 acres annually in 17 western states, and would
include only the 18 currently approved herbicides.
These treatment levels would be much the same as at
/ present, so there would likely be little change to existing
patterns and trends in population or demographic
conditions in the western U.S. Additionally, no changes
in employment associated with herbicide treatment
would occur.
Herbicide treatments would continue to generate some
employment in geographic areas affected by the
treatments, but the jobs would generally be short-term,
temporary positions or contracted work, which do not
encourage in-migration of workers and their families.
Herbicide treatments would take place on public lands,
away from areas where children are known to
congregate, such as schools and playground. While
children may visit public lands or live in the vicinity,
they are unlikely to make up a disproportionate
percentage of nearby populations or visitors to public
lands. Buffers between residences and treatment areas
and advance communication of treatments and site
closures would minimize risks to children. Therefore,
disproportionate impacts to children should not occur.
The 2007 PEIS estimated the costs to treat vegetation
under the Preferred Alternative (USDOI BLM 2007a:4-
172), which corresponds to the No Action Alternative
for this PEIS. This estimate is based on a maximum
total annual treatment area of 932,000 acres. While the
BLM’s current levels of treatment are much lower, this
PEIS assumes that the assumptions for treatment acres
in the 2007 PEIS will carry forward. Assuming this
maximum acreage and inflation costs of approximately
3 percent per year since 2007, the estimated costs to
treat vegetation using herbicides would be
approximately $1 10 million per year.
Herbicide treatments that reduce fire risk would
continue to be associated with cost savings associated
with reduced need for wildland fire suppression and
reduced loss of property. These savings cannot be
quantified. Herbicide treatments would also help reduce
the spread of noxious weeds, which would provide
some level of economic benefit by reducing the future
costs of vegetation management.
Commercial activities that occur on public lands, such
as timber sales, grazing, and recreation would continue
to be impacted a minor amount by herbicide treatments.
Additionally, there would continue to be a risk for
herbicide treatments to impact private property, which
could result in damage to crops or other non-target
plants of commercial value.
Alternative B - Allow for Use of Three New
Herbicides in 1 7 Western States (Preferred
Alternative)
Under the Preferred Alternative, the total acres treated
with herbicides each year would be the same as under
the No Action Alternative. However, the breakdown in
use of the various active ingredients would change with
the introduction of aminopyralid, fluroxypyr, and
rimsulfuron. Under this alternative, there would be a
substantial reduction (by approximately 21 percent) in
the use of glyphosate, imazapic, and picloram, and the
new active ingredients aminopyralid and rimsulfuron
would make up approximately 26 percent of herbicide
use, based on acres treated. Fluroxypyr, though
relatively expensive, would only constitute
approximately 1 percent of all acres treated. Glyphosate,
imazapic, and picloram are more expensive than
aminopyralid and rimsulfuron. Therefore, the estimated
costs to treat vegetation with herbicides (based on the
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cost and projected future use of each active ingredient)
would be lower under this alternative than under the No
Action Alternative. The estimated reduction in herbicide
costs is 1 to 2 percent per year.
In most other regards, the potential social and economic
impacts associated with herbicide treatments would be
similar to those under the No Action Alternative. While
there could be minor differences in the effectiveness of
certain herbicide treatments with the availability of the
new active ingredients, these differences would not
reflect measurable changes in socioeconomic impacts.
No changes in populations and demography, or
employment, would occur. The potential for
disproportionate adverse effects to minority populations
and children would continue to be low. The level of
economic benefit associated with fuels reduction and
control of noxious weeds would be similar to that under
the No Action Alternative, as would the level of risk to
commercial activities on public lands and adjacent
private properties.
This alternative would allow the use of aminopyralid,
which is of concern from an economic standpoint for its
potential to damage crops and gardens if used
inappropriately. However, the currently approved
herbicides clopyralid and picloram are also pyridine
carboxylic acids with a similar residual activity in
manure and plant materials. While total use of this class
of herbicides would increase by approximately 7
percent relative to the No Action Alternative, in all
cases, risks could be avoided by adhering to the
restrictions on the herbicide label.
Alternative C - No Aerial Application of New
Herbicides
Under Alternative C, the total acres treated with
herbicides each year would be the same as under the
other alternatives, and the list of active ingredients used
would be the same as under the Preferred Alternative.
However, the relative amount used would vary
somewhat because the three new active ingredients
would only be applied using ground methods, and could
not be utilized in aerial-based herbicide treatments.
Under this alternative, there would be a smaller
reduction in use of more expensive active ingredients,
as less of the new active ingredients would be used than
under the Preferred Alternative. Costs to treat vegetation
using herbicides (based on the cost and projected future
use of each active ingredient) would likely decrease, but
by a lesser amount, estimated at less than 1 percent per
year.
Other social and economic impacts associated with
herbicide treatments would be similar to those under the
other alternatives. No changes in populations and
demography, or employment, would occur. The
potential for disproportionate adverse effects to minority
populations and children would continue to be low. The
level of economic benefit associated with fuels
reduction and control of noxious weeds would be
similar to that under the other alternatives, as would the
level of risk to commercial activities on public lands
and adjacent private properties.
This alternative would entail slightly less use of
aminopyralid than under the Preferred Alternative, but
total use of the three pyridine carboxylic acids of
particular concern would be approximately 1 percent
less than under the Preferred Alternative. In all cases,
risks could be avoided by adhering to the restrictions on
the herbicide label.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under Alternative D, the maximum acreage treated with
herbicides each year would be the same as under the
other alternatives. The list of active ingredients would
be different than under the other alternatives, however,
as aminopyralid and fluroxypyr would be approved for
use and rimsulfuron would not. Under this alternative,
there would be very little reduction in the use of
glyphosate and imazapic, but a substantial reduction in
the use of picloram. Costs to treat vegetation using
herbicides would not decrease by a substantial amount,
relative to the No Action Alternative. The herbicide cost
reduction is estimated at a fraction of a percent per year,
much lower than under Alternatives B and C.
Other social and economic impacts associated with
herbicide treatments would be similar to those under the
other alternatives. No changes in populations and
demography, or employment, would occur. The
potential for disproportionate adverse effects to minority
populations and children would continue to be low. The
level of economic benefit associated with fuels
reduction and control of noxious weeds would be
similar to that under the other alternatives, as would the
level of risk to commercial activities on public lands
and adjacent private properties.
Use of aminopyralid under Alternative D would be the
same as under the Preferred Alternative, and total use of
the three pyridine carboxylic acids of particular concern
would also be the same as under the Preferred
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Alternative. In all cases, risks could be avoided by
adhering to the restrictions on-the herbicide label.
Mitigation for Herbicide Treatment
Impacts
The SOPs listed earlier in this section were designed to
reduce potential adverse impacts to social and economic
conditions from the application of herbicides. They
would apply to all treatments involving aminopyralid,
fluroxypyr, and rimsulfuron.
No mitigation measures are proposed for social and
economic resources.
Human Health and Safety
The use of herbicides involves potential risk or the
perception of risk to workers and members of the public
living or engaging in activities in or near herbicide
treatment areas. As part of the PEIS, an HHRA has been
conducted to evaluate the potential human health risks
of aminopyralid, fluroxypyr, and rimsulfuron as a result
of herbicide exposure during and/or after treatment of
public lands. The HHRA has been conducted to be
scientifically defensible, to be consistent with currently
available guidance where appropriate, and to meet the
needs of the BLM vegetation treatment program.
The three new active ingredients may be used with one
or more previously approved active ingredients, either
as a formulation or a tank mix (see Section on Herbicide
Formulations Used by the BLM and Tank Mixes in
Chapter 2). The human health risks associated with the
currently approved herbicides may be found in the 2007
PEIS (USDOI BLM 2007a:4-182 to 4-194). Only the
three herbicides proposed for use are considered in this
PEIS.
Scoping Comments and Other Issues
Evaluated in the Assessment
The BLM received a few scoping comments expressing
concerns about the health risks associated with
herbicides. In particular, one comment stressed the need
for additional preventative measures and oversight of
existing SOPs to protect human health, after reports that
an individual was sprayed during an aerial herbicide
application, and was not notified beforehand that the
treatment would occur. Another comment indicated that
the existing buffers between treatments and human
habitation are not adequate. However, one comment
also pointed out that risks associated with herbicides
should be considered alongside the risks associated with
other types of vegetation treatments that would be used
if herbicides were not allowed. None of the comments
specifically addressed the three active ingredients that
are being considered in this PEIS.
Standard Operating Procedures
The 2007 PEIS lists SOPs that were designed by the
BLM to reduce potential unintended impacts to human
health from the application of herbicides. These SOPs
would continue to apply to herbicide treatments
involving aminopyralid, fluroxypyr, and rimsulfuron,
and are considered when evaluating impacts to human
health and safety:
• Establish a buffer between treatment areas and
human residences based on guidance given in
the HHRA, with a minimum buffer of !4 mile
for aerial applications and 100 feet for ground
applications, unless a written waiver is granted.
• Use protective equipment as directed by the
herbicide label.
• Post treated areas with appropriate signs at
common public access areas.
• Observe restricted entry intervals specified by
the herbicide label.
• Provide public notification in newspapers or
other media where the potential exists for
public exposure.
• Have a copy of SDSs/MSDSs at work sites.
• Notify local emergency personnel of proposed
treatments.
• Contain and clean up spills and request help as
needed.
• Secure containers during transport.
• Follow label directions for use and storage.
• Dispose of unwanted herbicides promptly and
correctly.
The results from the HHRA will help inform BLM field
offices about the proper application of herbicides to
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ensure that impacts to humans are minimized to the
extent practical.
Human Health Risk Assessment
Methodology
The HHRA for aminopyralid, fluroxypyr, and
rimsulfuron follows the same methodology as the
HHRA for the 2007 PEIS (USDOI BLM 2007a:4-175
to 4-181), as discussed in detail in the HHRA. This
methodology is summarized here.
The BLM HHRA follows the four-step risk assessment
model identified by the National Academy of Sciences
(1983). The steps are: 1) hazard identification, 2) dose-
response assessment, 3) exposure assessment, and 4)
risk characterization.
Hazard Identification
The hazard identification section provides information
on the herbicide active ingredient characteristics and
usage, and toxicity profiles. Both acute (short-term) and
chronic (longer-term) toxicity information is
considered. Acute toxicity endpoints include oral,
inhalation, and dermal acute toxicity; eye irritation; skin
irritation; and dermal acute toxicity. Acute toxicity
endpoints include the median lethal dose (the dose that
kills 50 percent of test animals), the dose at which no
adverse effects were seen, and the lowest level at which
adverse effects were seen.
Inert ingredients were considered in the HHRA for the
2007 PEIS. As the inert ingredients found in
formulations of the three new herbicides would be the
same as those previously considered, no additional
analysis of these chemicals was done in the current
HHRA. The previous HHRA found that the majority of
inert ingredients are of minimal risk, and a few are in
the category of unknown toxicity.
Dose-Response Assessment
The dose-response assessment identifies the types of
adverse health effects an herbicide may potentially
cause, and defines the relationship between the dose of
an herbicide and the likelihood or magnitude of an
adverse effect (response). Dose-response values are
used to derive risk estimates. As none of the three
herbicides evaluated are designated as potential
carcinogens by the USEPA, the dose-response
assessment focuses on non-carcinogenic effects (i.e.,
potential toxic effects other than cancer).
Exposure Assessment
The exposure assessment predicts the magnitude and
frequency of potential human exposure to the
herbicides under consideration. The BLM takes care to
prevent exposures to applied pesticides, both through
worker training programs and by posting areas that
have just been sprayed with information on when
reentry into these areas is appropriate. However, to be
conservative, the HHRA has evaluated both routine
use and accidental exposure scenarios. Additionally,
exposures were evaluated both for applications using
the maximum application rate designated by the
herbicide label, and for applications using a typical
application rate defined by BLM.
Occupational Exposure Scenarios. Routine exposures
for occupational receptors include dennal and inhalation
exposures that could occur by a worker during an
application of the herbicide. For aerial applications,
occupational receptors that may come into routine
contact with herbicides include pilots and mixer/loaders.
For ground applications by backpack, the occupational
receptor is assumed to be an applicator/mixer/loader.
For the remaining application methods (horseback, and
spot and boom/broadcast methods for ATV/UTV and
truck mount applications), applicators, mixer/loaders,
and applicator/mixer/loaders were evaluated. The
exposure dose was calculated using the herbicide
application rate and the acres treated per day.
Accidental exposures for occupational receptors could
occur via spills or direct spray onto a worker. As a
worst-case scenario for an accidental exposure, a direct
spill event on an occupational receptor was evaluated.
The spill scenario assumes that 0.5 liter ('A quart) of the
formulation is spilled on a worker receptor. It is
assumed that 80 percent of the spill lands on clothing
and 20 percent lands on bare skin. The penetration rate
through clothing is assumed to be 30 percent. While
some of the herbicide labels require the use of gloves
while handling the herbicide, others do not. Therefore,
this scenario assumes that gloves are not worn.
Public Use Exposure Scenarios. Public use exposure
scenarios involve public receptors using public lands
treated with herbicides. Public receptors include: 1)
hikers/hunters; 2) beny pickers - child and adult; 3)
anglers; 4) swimmers - child and adult; 5) nearby
residents - child and adult; and 6) Native Americans -
child and adult. Two types of scenarios are addressed:
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• Routine-use exposure scenarios in which a
public receptor is exposed to herbicide active
ingredient(s) that have drifted outside the area
of application. It is assumed that the public
would heed posted signs and not enter a
treatment area during the treatment.
• Accidental scenarios where public receptors
may prematurely enter a sprayed area (a reentry
scenario), be sprayed directly, or contact water
bodies that have accidentally been sprayed
directly or into which an herbicide active
ingredient has accidentally been spilled.
These public exposure scenarios are thought to be
unlikely and represent worst-case conditions. Potential
exposure pathways include: 1) dermal contact with
spray, 2) dermal contact with foliage, 3) dermal contact
with water while swimming, 4) ingestion of drinking
water or incidental ingestion of water while swimming,
5) ingestion of berries, and 6) ingestion of fish.
Risk Characterization
The risk characterization estimates of the potential risk
to human health from exposure to herbicides. The
results of the exposure assessment are combined with
the results of the dose-response assessment to derive
quantitative estimates of risk. For the noncarcinogenic
active ingredients evaluated in this HHRA, risk is
described simply by the comparison of the exposure
doses to the appropriate dose-response values.
The Aggregate Risk Index (ARI) is a numeric
expression of risk that combines potential risks from
various exposure pathways, as discussed in more detail
in the HHRA (AECOM 2014c). The ARI is compared
against a target value of 1 . An ARI that is greater than 1
does not exceed the USEPA’s level of concern, and
indicates that no adverse health effects are expected. An
ARI below 1 indicates a potential concern for human
health.
Uncertainty in the Risk Assessment
Process
The HHRA incorporates various conservative
assumptions to compensate for uncertainties in the risk
assessment process. Conservative assumptions are made
throughout the risk assessment process, since every
assumption introduces some degree of uncertainty into
the process. Using conservative assumptions
exaggerates the risks to err on the side of protecting
human health.
Human Health Risks Associated with
Herbicides
The types of potential impacts to human health and
safety associated with herbicide use in general are
discussed in the 2007 PEIS (USDOI BLM 2007a:4-l 81
to 4-182). This general analysis would continue to apply
to herbicide treatments involving aminopyralid,
fluroxypyr, and rimsulfuron. It is summarized here,
followed by a more detailed analysis specific to the
three new active ingredients.
Herbicides can be toxic to humans to varying degrees
(any chemical poses a health risk at a high enough
dose). Most clinical reports of herbicide effects are of
skin and eye irritation. Short-term effects of exposure to
herbicides include nausea, dizziness, or reversible
abnormalities of the nervous system. In extreme cases
of prolonged, repeated, and excessive exposure, longer-
term health problems can result, including: organ
damage, immune system damage, permanent nervous
system damage, production of inheritable mutations,
damage to developing offspring, and reduction of
reproductive success. The label instructions of each
herbicide provide restrictions and precautions on usage
that minimize the risk of these effects. As part of
registration of herbicides, the USEPA adheres to a
uniform, health-based standard to ensure a “reasonable
certainty of no harm” to consumers.
The greatest risk for occupational exposure to
herbicides occurs when workers must directly handle
and/or mix chemicals. Spot and localized applications,
which require the most hands-on use of herbicides,
carry the greatest risk of exposure. Workers can also be
exposed to herbicides from accidental spills, splashing,
leaking equipment, contact with spray, or by entering
treated areas. Exposure can occur either through skin or
through inhalation. Adherence to operational safety
guidelines, use of protective clothing, equipment
checks, and personal hygiene can prevent incidents
from occurring. The herbicide label and corresponding
SDSs/MSDSs detail these application requirements in
addition to safety guidelines.
Public receptors can be exposed to herbicides by being
accidentally sprayed, by entering areas soon after
treatment (e.g., eating berries or other foods, and
touching vegetation), drinking contaminated water, or
accidentally coming into contact with herbicides that
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have drifted downwind. Members of the general public,
both visitors and residents, are less likely to be
repeatedly exposed than vegetation management
workers. The BLM has SOPs in place to prevent
exposure of the public to treated areas. However, there
has been one documented account of an accidental
spraying (via drift) of a worker engaged in other
resource work at the same time as an aerial herbicide
application in Nevada. The findings of this incident
indicate that both the contractor doing the spraying and
the BLM failed to implement SOPs that would have
prevented this occurrence. While the BLM has taken
steps to ensure that SOPs are followed in the future, the
incident shows that even with SOPs in place, accidental
exposures to herbicides can occur.
Tables 4-14 and 4-15 are summary tables that show the
level of risk each receptor (occupational and public)
would face during the application of a given herbicide,
for both maximum and typical application rate
scenarios. The ARls are partitioned into no, low,
moderate, and high levels of risk for ease of comparison
(no risk is identified as an ARI greater than 1, low risk
is between 1 and 0.1, moderate risk is between 0.1 and
0.01, and high risk is less than 0.01). These designations
are strictly for comparison purposes, and do not imply
actual risks to people. Tables 4-16 through 4-24 present
more detailed tables of ARIs for each herbicide and
receptor under occupational and public exposure
scenarios. Based on the HHRA (AECOM 2014c), the
three herbicides generally pose very little risk to human
health, with ritnsulfuron posing some risk to
occupational receptors under accidental exposure
scenarios.
Aminopyralid
Based on the hazard identification presented in the
HHRA, aminopyralid has low acute toxicity via oral,
dermal, and inhalation routes of exposure, but may
cause severe eye irritation in some forms. At mid- and
high-level doses, adverse effects to the stomach, ileum,
and cecum have been noted. Developmental and
reproduction studies indicate no evidence that fetuses or
offspring have increased susceptibility to aminopyralid.
Aminopyralid has been classified as “not likely to be
carcinogenic to humans,” and there is no evidence that
it is mutagenic or an endocrine disrupter (USEPA
2009b).
Dermal studies indicate that aminopyralid does not have
significant toxicity via the dermal route of exposure, as
it is either not absorbed or poorly absorbed through the
skin. For this reason, ARls were derived using oral and
inhalation exposures.
As shown in Tables 4-14 and 4-15, there are no risks to
occupational or public receptors from exposures
resulting from routine use (typical or maximum
application rate) or accidental scenarios. Tables 4-16
through 4-18 show the detailed HHRA results for
aminopyralid, presenting ARls by receptor and
exposure scenario. For all receptors, ARls were all well
above 1, with the lowest ARI of 94 for a child
swimming in a water body following a helicopter spill
(Table 4-18). This exposure pathway assumes incidental
ingestion of water while swimming. These results
indicate that aminopyralid does not present an
unacceptable risk to occupational or public receptors,
even under worst-case accidental exposure scenarios.
Fluroxypyr
Based on the hazard identification in the HHRA,
fluroxypyr has low acute toxicity via oral and dermal
routes, and moderate acute toxicity via inhalation. It is
not irritating to the skin, but is a mild eye irritant. At
high doses, it can target the kidney and result in other
adverse health effects. There is no evidence of increased
susceptibility following in utero, pre-natal, or post-natal
exposure. Endocrine disruption studies have not been
conducted. There is no indication that fluroxypyr is
carcinogenic or mutagenic (USEPA 2007).
Based on studies involving subchronic dermal
exposures of high doses of fluroxypyr, in which no
effects were observed, the USEPA has determined that
dermal risk assessment is not required for this chemical
(USEPA 2007). Therefore, ARls were derived using
oral and inhalation exposures.
As shown in Table 4-14 and 4-15, and shown in more
detail in Tables 4-20 and 4-21, there are no risks to
occupational or public receptors from exposures
resulting from routine use (typical or maximum
application rate) or accidental scenarios. For all
receptors, ARls were above 1, with the only ARls
below 500 for accidental exposures involving
swimming in a water body following an accidental spill
of fluroxypyr. These exposure pathways assume
incidental ingestion of water while swimming (Table
4-21). The lowest ARI was for a Native American child
swimming in a body of water following a helicopter
spill. These results indicate that fluroxypyr does not
present an unacceptable risk to occupational or public
receptors, even under worst-case accidental exposure
scenarios.
BLM Vegetation Treatments Using Three New I lerbicides
Final Programmatic EIS
4-90
January 2016
TABLE 4-14
Herbicide Risk Categories by Aggregate Risk Index for Occupational Receptors
ENVIRONMENTAL CONSEQUENCES
Rimsulfuron
Accid
N
X
C3
5
2
-2
s
£
S
s
s
2
£
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a
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hJ
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o
o
o
o
o
o
o
o
o
o
o
o
a.
>.
H
o
o
o
o
o
o
o
o
o
o
o
o
Fluroxypyr
Accid
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
Max
o
o
o
o
o
o
o
o
o
o
o
o
a.
K
H
o
o
o
o
o
o
o
o
o
o
o
o
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NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
d
5
o
o
o
o
o
o
o
o
o
o
o
o
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m
o
o
o
o
o
o
o
o
o
o
o
o
Receptor
Plane - pilot
Plane - mixer/loader
Helicopter - pilot
Helicopter - mixer/loader
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ATV/UTV - applicator4
ATV/UTV - mixer/loader
ATV/UTV - applicator/mixer/loader
Truck - applicator4
Truck - mixer/loader
Truck - applicator/mixer/loader
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03 03
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BLM Vegetation Treatments Three New Herbicide
Final Programmatic E1S
4-91
January 2016
TABLE 4-15
Herbicide Risk Categories by Aggregate Risk Index for Public Receptors
ENVIRONMENTAL CONSEQUENCES
Rimsulfuron
Accid
o
o
o
o
o
o
o
o
NC
NC
Max
o
o
o
o
o
o
o
o
NC
NC
a.
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H
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o
o
o
o
o
o
o
o
NC
NC
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Accid
NC
NC
NC
NC
NC
NC
o
o
o
o
Max
NC
NC
NC
NC
NC
NC
o
o
o
o
ft
H
NC
NC
NC
NC
NC
NC
o
o
o
o
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*3
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NC
NC
NC
NC
NC
NC
o
o
o
o
cs
s
NC
NC
NC
NC
NC
NC
o
o
o
o
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H
NC
NC
NC
NC
NC
NC
o
o
o
o
Receptor
Hiker/hunter (adult)
Berry picker (child)
Berry picker (adult)
Angler (adult)
Residential (child)
Residential (adult)
Native American (child)
Native American (adult)
Swimmer (child)
Swimmer (adult)
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BLM Vegetation Treatments Three New Herbicide
Final Programmatic EIS
4-92
January 2016
TABLE 4-16
Aminopyralid Aggregate Risk Indices - Occupational Scenarios
ENVIRONMENTAL CONSEQUENCES
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BLM Vegetation Treatments Three New Herbicide
Final Programmatic E1S
4-93
January 2016
TABLE 4-17
Aminopyralid Aggregate Risk Indices, Routine Exposure Scenarios for Public Receptors, Short-term Exposure
ENVIRONMENTAL CONSEQUENCES
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Final Programmatic E1S
4-95
January 2016
TABLE 4-19
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Final Programmatic EIS
4-96
January 2016
TABLE 4-20
Fluroxypyr Aggregate Risk Indices, Routine Exposure Scenarios for Public Receptors, Short-term Exposure
ENVIRONMENTAL CONSEQUENCES
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BLM Vegetation Treatments Three New Herbicide
Final Programmatic EIS
4-97
January 2016
TABLE 4-21
Fluroxvpyr Aggregate Risk Indices for Accidental Exposure Scenarios for Public Receptors Based on Maximum Application Rates
ENVIRONMENTAL CONSEQUENCES
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Final Programmatic EIS
4-98
January 2016
TABLE 4-22
Rimsulfuron Aggregate Risk Indices - Occupational Scenarios
ENVIRONMENTAL CONSEQUENCES
BLM Vegetation Treatments Three New Herbicide
Final Programmatic EIS
4-99
January 2016
TABLE 4-23
Rimsulfuron Aggregate Risk Indices, Routine Exposure Scenarios for Public Receptors, Short-term Exposure
ENVIRONMENTAL CONSEQUENCES
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BLM Vegetation Treatments Three New Herbicide
Final Programmatic EIS
4-100
January 2016
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73
BLM Vegetation Treatments Three New Herbicide
Final ITogrammatic EIS
4-101
January 2016
ENVIRONMENTAL CONSEQUENCES
Rimsulfuron
Based on the hazard identification presented in the
HHRA, rimsulfuron has low acute toxicity orally, by
dermal exposure, and by inhalation, but is a moderate
eye irritant. It is not a dermal sensitizer. Based on
subchronic and chronic toxicity studies, long-term
exposures to rimsulfuron can cause a variety of adverse
health effects targeting multiple organs. No
developmental toxicity has been observed at high doses,
and there is no evidence that rimsulfuron is an
endocrine disruptor. Rimsulfuron is classified as "Not
Likely a Human Carcinogen" (USEPA 2011).
As shown in Table 4-14, there is no risk to occupational
receptors under routine exposure scenarios, but low to
moderate risk under accidental exposure scenarios.
These scenarios assume that a mixed solution of
rimsulfuron is spilled directly onto an occupational
receptor, and that use of proper personal protective
equipment (PPE) would not prevent dermal exposure.
Therefore, this risk represents an unlikely scenario that
could be avoided through proper handling of the
herbicide, following all SOPs and label instructions, and
use of appropriate personal protective equipment. Table
4-22 shows the detailed HHRA results for occupational
exposure scenarios.
As summarized in Table 4-15, and shown in more detail
in Tables 4-23 and 4-24, there is no risk to public
receptors under routine or accidental exposure
pathways. All of the calculated ARls are above 1. The
lowest ARls were for accidental direct spray scenarios
involving children. These results indicate that
rimsulfuron does not present an unacceptable risk to
public receptors, even under worst-case accidental
exposure scenarios.
Impacts by Alternative
The following is a qualitative discussion of how risk
from herbicide exposure would vary under each
herbicide treatment alternative.
Alternative A - Continue Present Herbicide Use (No
Action Alternative)
Under this alternative, the BLM would continue to
implement herbicide treatments using the 1 8 herbicides
previously approved in the 2007 PEIS. The total area
treated with herbicides would be the similar to the
action alternatives, with differences in risk pertaining to
the relative amount of different herbicides used, and
their associated level of risk. Risks to humans from the
use of the previously approved chemicals vary, ranging
from no risk to high risk to occupational and public
receptors, depending on the exposure scenario.
Herbicides with the greatest amount of associated risk
include 2,4-D, bromacil, diquat, fluridone, hexazinone,
tebuthiuron, and triclopyr (see the 2007 PEIS for more
information [USDOI BLM 2007a:4-182 to 4-193]). Of
these, the active ingredients with the greatest projected
usage under this alternative include triclopyr,
tebuthiuron, and 2,4-D. Human health risks from these
chemicals would continue to be minimized by following
all label instructions, and SOPs to prevent accidental
exposures and protect human health. Additionally, the
mitigation measures specified in the ROD for the 2007
PEIS (USDOI BLM 2007b:Table 2), such as using the
typical application rate of these chemicals, where
feasible, would help to further minimize risks to
occupational and public receptors.
Under this alternative, ongoing treatment programs with
the currently approved herbicides would continue to
provide benefits to human health by reducing the
occurrence of noxious weeds and other invasive
vegetation. Additionally, ongoing treatment of species
that increase the risk of wildfire, such as cheatgrass,
would reduce the risk of wildfire and the associated
public health and safety risks.
Alternative B - Allow for Use of Three New
Herbicides in 17 Western States (Preferred
Alternative)
Under the Preferred Alternative, general risks associated
with herbicide treatments would be much the same as
under the No Action Alternative, as roughly the same
acreage would be treated with herbicides. The ability to
use aminopyralid, fluroxypyr, and rimsulfuron for
vegetation treatments could result in a slight change in
risk in certain treatment areas, as the relative amount of
herbicides would change. All three of the new
herbicides have no to very low risk to human health
(with an unacceptable risk only predicted for one
accidental exposure scenario involving rimsulfuron).
However, the three herbicides with the most substantial
predicted decrease in usage under this alternative —
imazapic, glyphosate, and picloram — also have no to
low human health risks. Use of the herbicides with
higher risk would likely remain at or near current levels.
Therefore, there would be little difference in risks to
human health and safety between the Preferred
Alternative and the No Action Alternative.
Introduction of the three new herbicides may allow the
BLM to be more efficient at controlling certain target
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
4-102
January 2016
ENVIRONMENTAL CONSEQUENCES
noxious weeds and other invasive vegetation, which
would have an associated health benefit. Use of
rimsulfuron may allow for better control of cheatgrass,
and an associated reduction in wildfire risk. These
beneficial effects are expected to be minor.
Alternative C - No Aerial Application of New
Herbicides
Under Alternative C, human health risks associated with
herbicide treatments would be similar to those under the
Preferred Alternative and the No Action Alternative.
The new herbicides would not be applied aerially,
eliminating certain exposure pathways for occupational
and public receptors. According to the HHRA, ARIs for
aerial application scenarios are generally lower than
those for ground-based methods, indicating greater
overall risk. However, there are no differences in risk
categories between aerial and ground application, as
shown in Tables 4-14 and 4-15. Additionally, restriction
of aerial applications of the new chemicals would not
reduce aerial spraying of herbicides, as different active
ingredients would be used where aerial spraying is
needed. For instance, to control cheatgrass, the currently
approved imazapic would be used in aerial applications
where rimsulfuron would have otherwise been used.
Furthermore, the maximum total area treated using
herbicides would not differ from that under the other
alternatives.
The relative use of the different chemicals would be
slightly different than under the No Action and
Preferred Alternatives, with use of the three new
herbicides being lower than under the Preferred
Alternative, and use of glyphosate, imazapic, and
picloram falling between the levels estimated for the No
Action and Preferred Alternatives. The relative amounts
of the other herbicides used would be roughly the same
as under the other alternatives. As the active ingredients
with usage levels that would change are all generally no
to low risk herbicides, overall risk from herbicide use
would be similar to that under the other alternatives.
Being unable to aerially apply the new herbicides could
have an impact on the effectiveness of herbicide
treatments to some degree, although the currently
approved herbicides could still be used to control the
target species via aerial methods. While less benefit to
human health from control of noxious weeds and
wildfire fuels is possible, the differences are expected to
be minor, relative to the Preferred Alternative.
Alternative D - No Use of New Acetolactate
Synthase-inhibiting Active Ingredients (No
Rimsulfuron)
Under this alternative rimsulfuron would not be used,
and as a result use of glyphosate and imazapic would be
higher than under the other action alternatives, similar
to the No Action Alternative. However, since the
differences in relative projected use involve all no- to
low-risk active ingredients, overall risks to human
health associated with herbicide treatments would be
similar to those under the other alternatives. Since the
total area treated using herbicides is expected to be the
same under all the alternatives, there would be little to
no difference in human health risk associated with
potential exposure to herbicides.
Under this alternative, the BLM would not be able to
use rimsulfuron to control cheatgrass and other winter
annual grasses. As there is evidence that rimsulfuron
may be more effective than imazapic and glyphosate in
certain situations, the human health benefits associated
with cheatgrass removal could be slightly less under this
alternative than under the Preferred Alternative. It is
expected that this difference would be minor.
Mitigation
As discussed previously, herbicide treatments involving
the new chemicals would continue to follow all of the
applicable SOPs for herbicide treatments listed in the
2007 PEIS and earlier in this resource section. The
ROD (USDOI BLM 2007b:Table 2) lists additional
mitigation measures for herbicide applications that
would also continue to be followed, although these
measures are specific to currently approved herbicides
and would not apply to the new herbicides, unless used
in a mixture with one of the other active ingredients.
Given the safety of aminopyralid, fluroxypyr, and
rimsulfuron to humans, no additional mitigation
measures are recommended for herbicide treatments
with these active ingredients.
Cumulative Effects Analysis
Under NEPA and its implementing guidelines, an
assessment of the proposed project and other projects
that have occurred in the past, are occurring in the
present, or are likely to occur in the future, which
together may have cumulative impacts that go beyond
the impacts of the proposed project itself, is required.
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
4-103
January 2016
ENVIRONMENTAL CONSEQUENCES
According to the Act (40 CFR §1508.7 and
1508.25 [a] [2]):
“Cumulative impact is the impact on the environment
which results from the incremental impact of the action
when added to the other past, present, and reasonably
foreseeable future actions regardless of what agency
(federal or non-federal) or person undertakes such other
actions. Cumulative impacts can result from
individually minor but collectively significant actions
taking place over a period of time. In addition, to
detennine the scope of Environmental Impact
Statements, agencies shall consider cumulative actions,
which when viewed with other proposed actions have
cumulatively significant impacts and should therefore
be discussed in the same impact statement.-”
The purpose of this cumulative effects analysis is to
determine if the effects of BLM vegetation treatments
with aminopyralid, fluroxypyr, and rimsulfuron have
the potential to interact or accumulate over time and
space, either through repetition or when combined with
other effects, and under what circumstances and to what
degree they might accumulate.
The 2007 PEIS provides a thorough cumulative effects
analysis for the BLM’s herbicide treatment program
(USDOI BLM 2007a:4-197 to 4-246). Since the three
new herbicides would be added to an existing program,
with no change in goals or acres or areas treated, much
of the 2007 analysis is inclusive of their use and does
not warrant repetition here. The analysis presented here
provides a general summary of the 2007 analysis, with
updated information provided where available.
Additionally, the analysis will include a discussion of
the cumulative effects associated with adding the three
new herbicide active ingredients to the BLM’s list of
approved active ingredients.
Structure of the Cumulative Effects
Analysis
The structure of the cumulative effects analysis is
described in the 2007 PEIS (USDOI BLM 2007a:4-197
to 4-201).
Class of Actions to be Analyzed - Large, regional scale
trends and issues that require integrated management
across broad landscapes, and regional-scale trends and
changes in the social and economic needs of people.
Appropriate Temporal Domain - The analysis period is
from 1930 through 2057. This is the date that was
identified in the 2007 PEIS. As the three new active
ingredients are being incorporated into the treatment
programs identified in the 2007 PEIS, the analysis
period remains the same.
Appropriate Spatial Domain - The analysis area
includes public lands in 17 western states, as well as
adjacent and nearby non-federal lands, depending on the
resource area.
Set of Receptors to be Assessed - The physical,
biological, and human systems discussed in Chapter 3
(Affected Environment).
Magnitude of Effects and Whether They are
Accumulating - Consider additive, countervailing, and
synergistic effects, using quantitative (where possible)
and qualitative analysis.
Resource Protection Measures and
Other Information Considered in the
Cumulative Effects Analysis
The resource protection measures considered in the
2007 cumulative effects analysis (USDOI BLM
2007a:4-201 to 4-202) are considered in the current
analysis. They include SOPs, monitoring measures, and
mitigation provided in the 2007 PEIS and PER (USDOI
BLM 2007a:Chapter 2; USDOI BLM 2007c:Chapter 2).
Additionally, they include all new mitigation measures
that have been developed by the BLM for use of the
three new herbicides, which can be found in Chapter 2
of this document.
Additionally, federal, state, local, and tribal resource
management and monitoring programs that pertain to
protection of environmental resources and restoration of
impaired resources are also considered in the
cumulative effects analysis. Regulatoiy programs exist
for air quality, water quality, wetlands, essential fish
habitat, threatened and endangered species, and
environmental justice.
Other pertinent information considered in the
cumulative effects analysis includes the following:
• Mitigation and SOPs identified in 2007 PEIS
would be more stringent than those required by
the USEPA.
• The BLM would comply with existing and
future regulations, including the FLPMA.
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
4-104
January 2016
ENVIRONMENTAL CONSEQUENCES
• A site-specific NEPA analysis would be
conducted prior to -implementing vegetation
treatments on public lands.
Analysis of Cumulative Effects by
Resources
Air Quality
Past Effects and Their Accumulation
Past effects to air quality, and their accumulation, are
discussed in the 2007 PEIS (USDOl BLM 2007a:4-202
to 203). They include emissions associated with wildfire
and prescribed fire, vehicle exhaust, commercial and
industrial land uses, and residential heating, among
other sources.
Since the 2007 PEIS was released in 2007, the USDOl
has begun to track GHG emissions, and in 2012
developed goals for reducing GHG emissions (USDOl
BLM 2014f). Since 2008, the USDOl has reduced direct
(vehicle) and certain indirect (e.g., purchased electricity)
GHG emissions by 11.6 percent, and reduced other
indirect GHG emissions (e.g., airline business travel) by
7.5 percent.
Nationwide, air quality has continued to improve since
over the last few decades. Between 1990 and 2000, air
pollution decreased for PMio (38 percent), lead (83
percent), NO2 (45 percent), CO (73 percent), and SO2
(75 percent). PM2.5 concentrations decreased between
2001 and 2010, and ozone concentrations decreased
between 2002 and 2010. Many toxic air pollutants also
declined. Pollutants of primary concern continue to be
PM and ozone. Greenhouse gas emissions continue to
increase in the U.S.; they have increased by 7 percent
since 1990 (USEPA 20\2f).
Based on data from the National Interagency Fire
Center, the annual number of wildfires between 1987
and 2012 has remained relatively steady, but the acreage
burned and average size of fires has increased (EcoWest
2014). Therefore, wildfires continue to contribute to air
pollution at increasing levels, although there is quite a
bit of variability from year to year.
Future Effects and Their Accumulation
Future effects to air quality, and their accumulation,
are discussed in the 2007 PEIS (USDOl BLM
2007a:4-202 to 203). The discussion focuses on fire-
related impacts to air quality, which are a main source
of concern in the area affected by the BLM’s
vegetation treatments. Sources of air quality
pollutants discussed in the preceding section, such as
wildfire and vehicle emissions, will continue to
contribute to cumulative air quality emissions.
Contributions of GHG emissions will also be
cumulative, and will potentially have an impact at a
global scale by contributing to climate change. It is
expected that in the future, air quality overall will
continue to improve, although emissions associated
with wildfire may continue to increase. Better vehicle
emission standards, other regulations, and efforts by
the USEPA, local air agencies, and other agencies to
reduce air quality emissions will all contribute to this
improvement in air quality.
Based on current trends, it is expected that GHG
emissions will continue to increase in the future, and
will continue to contribute to climate change.
Increased drought conditions in the western U.S.
could, in turn, contribute to an increase in wildfire,
which would contribute additional air quality
pollutants to the atmosphere.
Efforts by the BLM, Forest Service, and other
agencies to reduce the risk of wildfire on lands that
they manage will help offset some of the impacts to
air quality associated with wildfires. These programs
are likely to be ongoing during the duration of the
period of analysis covered by this PEIS.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be the similar under all of the
alternatives, the contribution to air quality in terms of
pollutants generated during treatments would also be the
similar under all the alternatives. Air quality emissions
are directly correlated with treatment acreage, as they
are correlated to number of vehicle miles driven. The
geographic location of air quality impacts would also be
the similar under all the alternatives. Air quality
emissions associated with treatment programs would be
cumulative to other releases of criteria pollutants and
GHGs within the geographic areas affected by
treatments.
Long-term benefits to air quality from a reduction in
wildfire risk would also be similar under all the
alternatives.
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
4-105
January 2016
ENVIRONMENTAL CONSEQUENCES
Soil Resources
Past Effects and Their Accumulation
Past effects to soil resources and their accumulation are
discussed in the 2007 PEIS (USDOI BLM 2007a:4-
205). They are predominantly associated with natural
resource extraction, renewable energy development,
grazing, road construction, timber harvesting, OHV and
other recreation use, agriculture, development, wildland
fire, and natural disturbances.
Future Effects and Their Accumulation
Future effects to soil resources and their accumulation
are discussed in the 2007 PEIS (USDOI BLM 2007a:4-
205 to 4-206). The factors contributing to past effects to
soil, as described in the previous paragraph, are ongoing
in the West, and will continue to impact soil resources.
Additionally, vegetation treatments by the BLM will
contribute to short-term loss of soil functions, process,
and productivity on nearly all treated land. Adverse
effects to soil will be offset by watershed-level
restoration treatments designed and implemented by the
BLM and other federal agencies with large landholdings
in the West. Numerous policies, programs, and
initiatives have been proposed to restore soil
productivity and improve the health of ecosystems by
the BLM and other federal, state, and local land
management entities. In addition, conservation
programs and BMPs to reduce soil loss in agricultural
areas have been developed and implemented during the
past several decades. All efforts to reduce the spread of
invasive vegetation, and to reduce the risk of wildfire,
are expected to help maintain soil productivity and
function.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be similar under all of the alternatives,
the contribution of the various alternatives to soil
impacts in terms of losses in soil function and
productivity would also be similar. Countervailing
effects associated with long-term improvement in soil
function and productivity would also be similar under
all the alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
soil resources would be 1 8. Under Alternatives B and C,
three additional herbicides would be used, and under
Alternative D, two additional herbicides would be used.
It is expected that impacts associated with all of the
herbicide active ingredients would be short-lived, as
herbicides and their breakdown products would degrade
over time. However, the ways in which these chemicals
might interact and the potential for synergistic effects
from use of multiple active ingredients are largely
unknown. The action alternatives would result in a
cumulative increase in the number of herbicide active
ingredients with the potential to impact soil and soil
organisms.
Water Resources and Quality
Past Effects and Their Accumulation
Past effects to water resources and their accumulation
are discussed in the 2007 PEIS (USDOI BLM 2007a:4-
207 to 4-208). They are predominantly associated with
mining activities, exploration and development of oil
resources, agriculture (including use of pesticides),
industry, and other human activities.
Based on the most recent (2004) National Water Quality
Inventory Report to Congress (USEPA 2009a), an
assessment of streams in the western U.S. determined
that the most prevalent stressors were nitrogen,
phosphorus, riparian disturbance, and streambed
sediments.
Based on the most recent Alaska Water Quality
Assessment Report (USEPA 2010b), the primary causes
of impairment are turbidity, fecal coliform, and
sedimentation/siltation, with resource extraction and
urban runoff/stormwater as the primary sources of
impairment.
Groundwater and surface water quality in the West have
been impacted by pollutants associated with agriculture
and other activities. Additionally, water quantity has
been impacted in many areas of the West, largely as a
result of ongoing population growth and irrigation. As
documented by the NAWQA, pesticides or their
degradates are prevalent in streams, and have been
detected in more than half of the shallow wells sampled
in agricultural and urban areas, and in 33 percent of the
deeper wells that tap major aquifers (USGS 2006).
About 1 percent of public-supply wells sampled by
NAWQA had a pesticide concentration greater than a
human health benchmark.
According to a recent study documenting trends in
pesticide concentrations in U.S. streams and rivers, the
proportion of mixed land use streams with pesticides
exceeding aquatic life benchmarks has generally stayed
the same over the last 20 years, with concentrations of
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
4-106
January 2016
ENVIRONMENTAL CONSEQUENCES
individual pesticides varying in response to shifts in use
patterns (Stone et al . 20 1 4). -
Future Effects and Their Accumulation
Future effects to water resources and their accumulation
are discussed in the 2007 PEIS (USDOI BLM 2007a:4-
208).
While it is difficult to predict the extent and magnitude
of future effects to water resources and quality, it is
assumed that activities that contribute to water quality
pollution and depletion will continue in the western
states. At the same time, efforts to improve water
quality are ongoing, including goals by the BLM for
percent of water bodies meeting State Water Quality
Standards. Target goals are raised every year. The BLM
and other land management agencies also continue
programs to restore degraded wetland/riparian areas,
which includes vegetation management programs.
Programs that will be implemented to meet restoration
goals are the same as those that were discussed in the
2007 PEIS.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be similar under all of the alternatives,
the impacts to water resources in terms of degradation
of water quality associated with treatments also would
be similar under all the alternatives. Countervailing
effects associated with long-term improvement in
function of wetlands, riparian areas, streams, and other
water bodies would also be similar under all the
alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
water resources would be 18. Under Alternatives B and
C, three additional herbicides would be used, and under
Alternative D, two additional herbicides would be used.
It is expected that impacts associated with all of the
herbicide active ingredients would be short-lived, as
herbicides and their breakdown products would degrade
over time. However, the ways in which these chemicals
might interact and the potential for synergistic effects
from use of multiple active ingredients are largely
unknown. Additionally, it is unknown the degree to
which these degradates might persist in groundwater.
The action alternatives would result in a cumulative
increase in the number of herbicide active ingredients
with the potential to impact water resources and result
in groundwater contamination.
Wetland and Riparian Areas
Past Effects and Their Accumulation
Past effects to wetland and riparian areas and their
accumulation are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-209 to 4-210). They are predominantly
associated with natural resource extraction, recreation,
dams and diversions, road construction, agriculture,
urbanization, and fire exclusion. Invasive plants and
catastrophic wildfires degrade wetland and riparian
function. Wetland losses in the lower 48 states have
continued to decline, although the rate has been slowed
by reestablishment of wetlands. Estimated net wetland
loss for the lower 48 states from 2004 to 2009 was
62,300 acres (USFWS 2011). However, most of these
wetlands were in the southeastern United States.
On BLM lands in the lower 48 states, 44 percent of
wetlands surveyed are not functioning properly or are
functioning at risk (USDOI BLM 2012a). This
percentage continues to increase, despite efforts by the
BLM to improve proper functioning condition. Only 16
percent of riparian areas in the lower 48 states are non¬
functional or functioning at risk, and the trend on BLM
lands is one of improvement in riparian condition. In
Alaska, impacts have been less, and nearly all wetlands
and riparian areas are in properly functioning condition.
F uture Effects and Their Accumulation
Future effects to wetlands and riparian areas and their
accumulation are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-210).
Factors that contribute to degradation of wetlands and
riparian areas, as described in the previous section,
continue to varying degrees in the West. Climate change
may also contribute to impacts, particularly as a result
of increased temperatures and extended drought periods.
Ongoing efforts to protect wetlands and riparian areas
have reduced the level of impact of natural and human
factors that degrade these habitats. Additionally,
vegetation treatment programs by the BLM and Forest
Service, along with restoration efforts by other agencies,
private landowners, and other entities, continue to
improve the condition of degraded wetland and riparian
habitats. While it is difficult to predict the extent and
magnitude of future effects to water resources and
quality, it is assumed that activities that contribute to
water quality pollution and depletion will continue in
the western states. At the same time, efforts to improve
water quality are ongoing, including goals by the BLM
for percent of water bodies meeting State Water Quality
BLM Vegetation Treatments Using Herbicides
Final Programmatic E1S
4-107
January 2016
ENVIRONMENTAL CONSEQUENCES
Standards, which increase each year. The BLM and
other land management agencies also continue
programs to restore degraded wetland/riparian areas,
which includes vegetation treatment programs. Future
treatment programs that will be implemented to meet
restoration goals are the same as those that were
discussed in the 2007 PEIS.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be similar under all of the alternatives,
potential impacts to wetlands and riparian areas
associated with herbicide treatments would also be
similar under all the alternatives. Some herbicides
would be released into wetland and riparian areas, and
removal of vegetation could have short-term impacts to
functions. Countervailing effects associated with long¬
term improvement in function of wetlands, riparian
areas, streams, and other water bodies would also be
similar under all the alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
water resources would be 1 8. Under Alternatives B and
C, three additional herbicides would be used, and under
Alternative D, two additional herbicides would be used.
It is expected that impacts associated with all of the
herbicide active ingredients would be short-lived, as
herbicides and their breakdown products would degrade
over time. However, the ways in which these chemicals
might interact and the potential for synergistic effects
from use of multiple active ingredients are largely
unknown. Additionally, it is unknown the degree to
which these degradates might persist in groundwater or
wetland or riparian soils. The action alternatives would
result in a cumulative increase in the number of
herbicide active ingredients with the potential to impact
wetland and riparian habitats and the species found in
them.
Vegetation
Past Effects and Their Accumulation
Past effects to vegetation (including native plant
communities and special status plant species), and their
accumulation, are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-211 to 4-212). They are predominantly
associated with exclusion of fire and alteration of
natural disturbance regimes, timber harvest, reseeding
and planting programs, and grazing. Human activities
have altered native plant communities, and have led to
the introduction and spread of invasive species.
Future Effects and Their Accumulation
Future effects to vegetation, and their accumulation, are
discussed in the 2007 PEIS (USDOI BLM 2007a:4-212
to 4-213). Many of the same human activities that have
altered native plant communities in the past will
continue to do so in the future. Populations of invasive
species will continue to spread, and altered disturbance
regimes will continue to cause large wildfires that
further alter vegetation in the western U.S. Treatments
by the BLM, Forest Service, and other entities to
remove hazardous fuels and control invasive species
will help offset these adverse effects, although multiple
treatments followed by restoration would be necessary
to recover native communities and restore disturbance
regimes in targeted areas.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be similar under all of the alternatives,
the contribution to vegetation impacts in terms of
departure from native conditions and disturbance
regimes would also be similar under all the alternatives.
Countervailing effects associated with long-tenn
improvement in plant communities and reduction in fire
risk would also be similar under all the alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
vegetation would be 18. Under Alternatives B and C,
three additional herbicides would be used, and under
Alternative D, two additional herbicides would be used.
Under all alternatives, herbicides would be available
that would allow the BLM to meet their treatment goals
to restore native communities. The action alternatives
would allow the BLM additional options for treating
invasive species that could improve the effectiveness of
treatment programs in certain circumstances. In all
cases, herbicide treatments could be used in concert
with other vegetation treatment methods. Additionally,
aminopyralid and fluroxypyr would be tank mixed with
other active ingredients, which could result in additive
or even synergistic effects to non-target plants.
Fish and Other Aquatic Organisms
Past Effects and Their Accumulation
Past effects to fish and other aquatic resources
(including special status aquatic species), and their
accumulation, are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-214 to 4-215). They are predominantly
associated with natural resource extraction; recreation;
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fire exclusion; construction of roads, dams, and
hydropower facilities; agriculture; and urbanization. In
Alaska, oil and gas development, and subsistence and
recreational fishing, have been the primary factors
affecting fish and aquatic resources.
The spread of invasive plant species and increase in
catastrophic wildfires in the western U.S. have also
been a factor in the degradation of water bodies that
provide habitat for fish and other aquatic organisms.
The BLM, other federal and state agencies, private
landowners, and businesses have implemented pest and
invasive plant control efforts that have resulted in the
application of thousands of tons of herbicides and other
pesticides to the environment. Some of these pesticides
break down relatively quickly in the environment or are
not harmful to aquatic organisms at typical application
rates. However, some are harmful to aquatic organisms
and may be persistent in the environment.
Future Effects and Their Accumulation
Future effects to fish and other aquatic resources, and
their accumulation, are discussed in the 2007 PEIS
(USDOl BLM 2007a:4-215). As discussed under the
cumulative effects discussions for water resources,
wetlands, and riparian areas, it is assumed that activities
that contribute to the degradation and loss of these
habitats will continue to occur in the western states,
although they will be offset to some degree by
protective regulations and restoration efforts, driven by
goals to improve water quality and regain the proper
functioning condition of riparian areas. Additionally,
efforts to remove dams and other blockages to fish
passage will continue to benefit fish populations by
expanding their ranges.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be similar under all of the alternatives,
the impacts to habitats that support fish and aquatic
resources would also be similar under all the
alternatives. Countervailing effects associated with
long-term improvement in function of aquatic habitats
would also be similar under all the alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
water resources would be 18. Under Alternatives B and
C, three additional herbicides would be used, and under
Alternative D, two additional herbicides would be used.
The potential toxicological effects to fish and aquatic
invertebrates associated with the active ingredients vary.
By allowing the BLM the option of using additional
active ingredients, the action alternatives would result in
a cumulative increase in the number of active
ingredients released to the environment that could enter
aquatic habitats. As the three herbicides have a very low
risk to aquatic species, a cumulative effect of adding
these active ingredients could be a reduction in overall
risk to aquatic species associated with herbicide use.
It is expected that impacts associated with all of the
herbicide active ingredients would be short-lived, as
herbicides and their breakdown products would degrade
over time. However, the ways in which these chemicals
might interact and the potential for synergistic effects
from use of multiple active ingredients are largely
unknown. Additionally, it is unknown the degree to
which these degradates might persist in aquatic habitats.
Herbicides and other pesticides may interact with a
wide range of pollutants and various other chemical and
non-chemical factors, in ways that are poorly
understood, to result in adverse effects to aquatic
populations, species, communities, and ecosystems
(Scholz et al. 2012).
Wildlife Resources
Past Effects and Their Accumulation
Past effects to wildlife and their accumulation are
discussed in the 2007 PEIS (USDOl BLM 2007a:4-216
to 4-220). The discussion considers habitat loss,
modification, and fragmentation, and wildlife health.
Habitat loss has occurred as a result of conversion to
agriculture, pastureland, and residential, commercial
industrial, and other development. On lands that have
not been converted to other uses, including most of the
lands managed by the BLM, habitat modification has
reduced their value to wildlife. The primary factors
contributing to habitat modification in the West include
grazing by domestic livestock and wild horses and
burros, timber management, fire suppression, and
invasion by invasive plants and other unwanted
vegetation. Mature forests, sagebrush habitats, and
grasslands have been most affected. Causes of wildlife
death, injury, sickness, and disturbance include hunting,
collisions with vehicles and structures, wildland and
prescribed fires, recreation, and pesticide use.
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Future Effects and Their Accumulation
Future effects to wildlife, and their accumulation, are
discussed in the 2007 PEIS (USDOI BLM 2007a:4-212
to 4-213). Many of the causes of impacts to wildlife
discussed in the preceding section will continue to have
effects on wildlife. Loss, modification, and
fragmentation of habitat will likely continue, increasing
the likelihood of local extirpations of wildlife
populations and loss of species diversity. Actions to
protect sensitive species and their habitats, restore
native plant communities and disturbance regimes,
control the spread of invasive species, and reduce the
risk of catastrophic wildfire are all expected to help
offset some of the adverse impacts to wildlife and
wildlife habitat.
Use of herbicides and other pesticides will continue and
likely increase, and wildlife will continue to be at risk
for exposure to these chemicals. Identifying and
restricting use of active ingredients with the greatest
toxicological risks to wildlife in favor of active
ingredients with lower risks would help reduce
cumulative effects associated with exposure to
pesticides.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be similar under all of the alternatives,
the impacts to wildlife habitat would also be similar
under all the alternatives. Countervailing long-term
effects associated with restoration of native plant
communities and disturbance regimes would also be
similar under all the alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
wildlife would be 18. Under Alternatives B and C, three
additional herbicides would be used, and under
Alternative D, two additional herbicides would be used.
The potential toxicological effects to wildlife associated
with the active ingredients vary. By allowing the BLM
the flexibility to use additional herbicides, the action
alternatives would result in the release of a larger
number of active ingredients. As the three herbicides
have a very low risk to wildlife, a cumulative effect of
adding these active ingredients could be a reduction in
overall risk to wildlife associated with herbicide use, as
use of herbicides with a greater risk to wildlife would
potentially be less.
It is expected that impacts associated with all of the
herbicide active ingredients would be short-lived, as
herbicides and their breakdown products would degrade
overtime. The ways in which aminopyralid, fluroxypyr,
and rimsulfuron might interact with other active
ingredients and the potential for synergistic effects are
largely unknown. Additionally, the toxicity of
breakdown products to wildlife is largely unknown.
Livestock
Past Effects and Their Accumulation
Past effects to livestock, and their accumulation, are
discussed in the 2007 PEIS (USDOI BLM 2007a:4-
222). They are predominantly associated with a
decrease in the ability of public lands to support
livestock grazing, which has occurred as a result of
changes in fire regimes and the spread of noxious
weeds. Past livestock grazing has contributed to these
adverse effects, as have mineral extraction, recreation,
and other activities.
Future Effects and Their Accumulation
Future effects to livestock, and their accumulation, are
discussed in the 2007 PEIS (USDOI BLM 2007a:4-222
to 4-223). Many of the factors discussed in the
preceding paragraph are ongoing and will continue to
impact the quality of rangelands utilized by livestock.
However, these effects will be minimized or offset by
ongoing management programs designed to restore
ecosystem processes and maintain livestock populations
in balance with the health of rangelands. Treatments
that control noxious rangeland weeds and reduce the
risk of fire will also help to improve rangeland quality.
Contribution of Treatment Alternatives to
Cumulative Effects
Because the acreage of public lands treated with
herbicides would be the same under all of the
alternatives, there would be no difference in the amount
of rangeland targeted by herbicide treatments under any
of the alternatives. Use of herbicides in rangelands
could have some short-term adverse effects by
removing large areas of vegetation and non-target
species used by livestock as forage. However, over the
long tenn it would have countervailing effects of
improving the quality of rangeland forage and
controlling noxious weeds that are unpalatable or toxic
to livestock.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
livestock would be 18. Under Alternatives B and C,
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ENVIRONMENTAL CONSEQUENCES
three additional herbicides would be used, and under
Alternative D, two additional herbicides would be used.
The potential toxicological effects to livestock
associated with herbicide active ingredients vary.
However, the three new herbicides are not associated
with toxicological risks to livestock, and their use may
result in a reduction in the use of active ingredients with
greater toxicological risks. Therefore, a cumulative
effect of adding these active ingredients could be a
reduction in overall risk to livestock associated with
herbicide use.
Wild Horses and Burros
Past Effects and Their Accumulation
Past effects to wild horses and burros, and their
accumulation, are discussed in the 2007 PEIS (USDOl
BLM 2007a:4-223 to 4-225). They include a large
reduction in the wild horse and burro populations in the
1930s and 1940s as a result of capture and removal,
which was halted with the passage of the Wild Free-
Roaming Horses and Burros Act of 1971. Since then,
the BLM has attempted to maintain populations at
levels that can be supported by the available resources,
but populations continue to be well above that level.
Activities that reduce the quantity or value of available
resources have had an adverse effect on wild horses and
burros. These include development, grazing, and
building of fences and other structures that impede herd
movements.
The maximum AML is currently 26,684, which is lower
than it was when the 2007 PEIS was completed.
However, the total number of wild horses and burros on
public lands has increased since then to 49,209, which is
over 22,500 animals more than public rangeland can
sustain (USDOl BLM 2014a).
Future Effects and Their Accumulation
Future effects to wild horses and burros, and their
accumulation, are discussed in the 2007 PEIS (USDOl
BLM 2007a:4-225). The BLM will continue
management efforts to keep wild horse and burro
populations at AMLs in balance with the condition of
rangelands, which will require continued removal and
adoption of animals, as well as measures to control
reproduction. Additionally, the factors discussed in the
preceding section will continue to impact the quality of
rangelands and impede movement by wild horses and
burros. Treatments that control noxious rangeland
weeds and reduce the risk of fire will also help to
improve rangeland quality and its ability to support wild
horse and burro populations.
Contribution of Alternatives to Cumulative Effects
The acreage of rangelands treated with herbicides would
be similar under all of the alternatives. Use of herbicides
in rangelands could have some short-term adverse
effects by removing large areas of vegetation and non¬
target species used by wild horses and burros as forage.
However, over the long term it would have
countervailing effects of improving the quality of
rangeland forage and controlling noxious weeds that are
unpalatable or toxic to wild horses and burros.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
wild horses and burros would be 18. Under Alternatives
B and C, three additional herbicides would be used, and
under Alternative D, two additional herbicides would be
used. The potential toxicological effects to wild horses
and burros associated with herbicide active ingredients
vary. However, the three new herbicides are not
associated with toxicological risks to large mammals,
and their use may result in a reduced need for active
ingredients with greater toxicological risks. Therefore, a
cumulative effect of adding the three new active
ingredients could be a reduction in overall risk to wild
horses and burros associated with herbicide use.
Paleontological and Cultural Resources
Past Effects and Their Accumulation
Past effects to paleontological and cultural resources,
and their accumulation, are discussed in the 2007 PEIS
(USDOl BLM 2007a:4-223 to 4-225). Past exploration
and development in the western U.S. has led to legal
and illegal collection of paleontological resources and
inadvertent damage. Many cultural resources have been
lost or damaged by exposure to the elements or by
collection or destruction of cultural sites. These losses
are permanent, but have been slowed by legislation
designed to protect these resources from damage and
removal.
Future Effects and Their Accumulation
Future effects to paleontological and cultural resources,
and their accumulation, are discussed in the 2007 PEIS
(USDOl BLM 2007a:4-226 to 4-228). While the
widespread loss and damage of paleontological and
cultural resources has been slowed, ground-disturbing
activities with the potential to disturb undiscovered
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ENVIRONMENTAL CONSEQUENCES
resources continue to occur in the western U.S. These
activities include resource extraction, livestock grazing,
and motorized recreation, among others. Over time,
additional buried resources may be exposed naturally
through erosion, increasing their susceptibility to
damage or collection. Additionally, wildfires and
invasive species have altered native plant communities,
and continue to displace native plants and animals that
provide traditional lifeway values to Native peoples.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be the same under all of the
alternatives, there would be no difference in the
geographic extent of public lands targeted by herbicide
treatments under any of the alternatives. Therefore, risks
for impacts to paleontological and cultural resources
would also be the same. Countervailing effects
associated with controlling invasive species and
reducing the risk of catastrophic wildland fire, which
would improve conditions for native plants and animals
that provide traditional lifeway values, would also be
similar under all the alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM would be 18. Under
Alternatives B and C, three additional herbicides would
be used, and under Alternative D, two additional
herbicides would be used. Adding new herbicides
would increase the total number of active ingredients
released into the environment. From a perspective of
potential risks to Native Americans from exposure to
herbicides, the three new herbicides have no to low risk
to humans via various exposure scenarios. The potential
for synergistic human health effects associated with
mixtures of multiple ingredients is not known.
Visual Resources
Past Effects and Their Accumulation
Past effects to visual resources, and their accumulation,
are discussed in the 2007 PEIS (USDOI BLM 2007a:4-
229 to 4-230). Humans have altered the visual character
of lands in the western U.S. through activities such as
resource extraction, agriculture, road construction,
urbanization and other development, timber harvesting,
livestock grazing, introduction of exotic species, and
exclusion of fire. As a result, landscapes have changed,
and are now marked by different vegetation
composition, structure, and pattern.
Future Effects and Their Accumulation
Future effects to visual resources, and their
accumulation, are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-225). The activities described in the
preceding paragraph continue to influence the visual
characteristics and scenic quality of landscapes.
Ongoing vegetation management programs will alter the
visual quality of public lands over the short term by
removing vegetation, and in some cases creating large
areas of open, browned, or blackened landscapes.
However the BLM’s long-term goals to restore
degraded lands, reinstate properly functioning
ecosystem processes, and restore degraded lands will
likely help improve the visual character of public lands,
particularly for VRM Class I and II lands with high
scenic values. Other federal, state, tribal, and local
agencies, and private conservation groups will also
continue efforts to improve land health which will result
in countervailing effects to visual resources.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides would be similar under all of the alternatives,
impacts to visual resources would occur over a similar
geographic area under all alternatives. Additionally, the
degree of the effects, and their contribution to
cumulative effects, would be similar under all the
alternatives. None of the alternatives would alter land
uses on public lands, or introduce long-term changes
that would be in conflict with the BLM’s visual
resource management goals. Over the long term, all of
the alternatives would be expected to contribute
positively to scenic qualities of public lands.
Additionally, all of the alternatives would help reduce
the risk of wildfire that has a visual impact on public
lands and other scenic lands in the western U.S.
Wilderness and Other Special Areas
Past Effects and Their Accumulation
Past effects to wilderness and other special areas, and
their accumulation, are discussed in the 2007 PEIS
(USDOI BLM 2007a:4-229 to 4-231). While wilderness
and other special areas continue to be protected from
development by their status designations, these areas are
threatened by factors that degrade their unique qualities.
These factors include: 1) exotic and non-native species;
2) wildland fire suppression; 3) loss of water and
deterioration in water quality; 4) fragmentation and
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isolation of wilderness as ecological islands; 5) loss of
threatened and endangered species; 6) deterioration in
air quality; 7) motorized and mechanical equipment
trespass and use; 8) increasing commercial and public
recreation use; 9) adjacent land uses; and 10)
urbanization and encroachment. All of these factors
continue to contribute to loss of wilderness values or
other unique qualities.
Future Effects and Their Accumulation
Future effects to wilderness and other special areas, and
their accumulation, are discussed in the 2007 PEIS
(USDOI BLM 2007a:4-231 to 4-232). The threats
described in the previous paragraph are ongoing, and
will continue to impact the unique qualities of
wilderness and other special areas. With increases in
population these areas may be further degraded through
overuse. Additionally, pressure to utilize protected areas
for resource extraction may result in future loss or
degradation of these areas. Vegetation treatment
programs in and near these areas that aim to control the
spread of noxious weeds and restore natural fire
regimes, if successful, will help reduce some of the
threats to wilderness and other special areas, but not
others. Actions by conservation groups and other
entities to protect these areas may also help offset or
slow some of the factors that degrade the unique
qualities of wilderness and other special areas.
Contribution of Alternatives to Cumulative Effects
Because the acreage of public lands treated with
herbicides, as well as the areas targeted for treatments,
would be similar under all of the alternatives, the
impacts to wilderness and other special areas would also
be similar under all the alternatives. Adverse effects to
these areas would generally be short-term effects
associated with site closures and disturbances during
herbicide treatments. Therefore, they would not be
expected to contribute to long-term adverse effects.
Countervailing effects associated with slowing future
degradation of these areas or improving them through
control of invasive species and restoration of native
habitats and disturbance regimes would also be similar
under all the alternatives.
The number of herbicides used, which would vaiy to
some degree under the alternatives, would not be
expected to have a substantial difference in how the
action contributes to cumulative effects. The BLM
would be able to control target species and reduce
wildfire risk under all alternatives, although there would
be a few additional options under the action alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM with the potential to impact
wildlife would be 18. Under Alternatives B and C, three
additional herbicides would be used, and under
Alternative D, two additional herbicides would be used.
The use of new active ingredients could introduce new
chemicals to areas that are relatively undisturbed.
Although the new active ingredients have low risk to
fish, wildlife, and other resources, the cumulative
increase in pesticide use in wilderness and other special
areas could have a negative connotation from a public
opinion perspective.
Recreation
Past Effects and Their Accumulation
Past effects to recreation, and their accumulation, are
discussed in the 2007 PEIS (USDOI BLM 2007a:4-223
to 4-233). Recreation opportunities on public lands have
increased with the creation of recreational facilities and
development of numerous recreation programs. These
programs provide opportunities for outdoor recreation
for millions of visitors annually. Other uses on BLM
lands, such as livestock grazing, timber harvesting, and
oil and gas activities, have limited recreation
opportunities in certain locations. Additionally, the
spread of invasive plants and wildfires have adversely
affected recreation opportunities.
Future Effects and Their Accumulation
Future effects to visual resources, and their
accumulation, are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-233 to 4-234). With the growth of the
population in the West and a continued interest in
recreation, the amount of use that BLM lands receive by
the public will likely continue to increase. At the same
time, the BLM will not be able to substantially expand
its recreational opportunities. Therefore, existing lands
and recreational facilities will be used more intensively,
potentially reducing the recreation experience in certain
areas and resulting in degradation of recreational
facilities. Recreational visitors likely contribute to the
spread of invasive species on public lands. Additionally,
development and other activities in areas near public
lands could lessen recreational experiences if they are
visible from public lands.
Vegetation treatment programs by the BLM have a goal
of restoring native plant communities, improving
wildlife habitat quality, controlling the spread of
invasive species, and reducing wildfire risk, and would
help to offset some of the impacts caused by
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ENVIRONMENTAL CONSEQUENCES
recreationists, as well as improve the quality of
recreational opportunities on public lands.
Contribution of Alternatives to Cumulative Effects
The acreage of public lands treated with herbicides
would be similar under all of the alternatives, and
impacts to recreation would occur over a similar
geographic area under all alternatives. Additionally, the
degree of the effects, and their contribution to
cumulative effect, would be similar under all the
alternatives. Adverse effects associated with herbicide
treatments would be short-term in duration, and would
be unlikely to contribute to long-term adverse effects to
recreation. Beneficial effects associated with control of
invasive species, reduction of wildfire risk, and
restoration of native plant communities would be
similar under all of the alternatives.
Under the No Action Alternative, the number of
herbicides used by the BLM would be 18. Under
Alternatives B and C, three additional herbicides would
be used, and under Alternative D, two additional
herbicides would be used. Under all alternatives,
herbicides would be available that would allow the
BLM to meet its treatment goals, including control of
invasive species at visitor centers and other recreational
facilities, restoration of native communities, and
protection of recreation sites from risks associated with
wildfire. The action alternatives would allow the BLM
additional options for treating invasive species that
could improve the effectiveness of treatment programs
in certain circumstances. Additionally, aminopyralid
and fluroxypyr would be mixed with other active
ingredients to improve their effectiveness against certain
target plants, and may help address resistance
management issues at sites where invasive species are
controlled repeatedly.
Social and Economic Values
Past Effects and Their Accumulation
Past effects to social and economic values, and their
accumulation, are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-235 to 4-236). Social and economic
factors that are important from the perspective of public
lands include the continued population growth in the
western U.S. (13.8 percent between 2000 and 2010;
U.S. Department of Commerce Bureau of the Census
2011), environmental justice concerns associated with
communities with high densities of Native Americans
and other minority populations, the importance of jobs
and industries associated with natural resources and
resource extraction, increasing wildfire risks and
associated risks to private property, and economic
benefits from activities conducted on BLM lands, such
as grazing, harvest of timber and other forest products,
and oil, gas, and geothermal development.
Industries related to natural resources, such as
agriculture and mining, are important sources of
employment and represent nearly half of the nation’s
agricultural services, forestry, and fishing jobs.
Future Effects and Their Accumulation
Future effects to social and economic values, and their
accumulation, are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-236 to 4-238).
It is expected that populations in the western U.S. will
continue to increase, and that use of BLM-administered
lands by the public will also continue to increase.
Population growth is cumulative, and actions on public
lands and elsewhere will continue to affect greater
numbers of people, including larger minority and low
income populations. BLM lands will continue to
provide a source of revenue for the federal government
and local economies, with a possible low-level increase
in those benefits through activities to improve the
condition of rangelands and other public lands. Oil, gas,
geothermal, and mineral resource extraction on public
lands is expected to continue to be an important source
of income into the future. Recreation is also likely to
continue to be an important source of income, with
vegetation treatments that improve the quality of public
lands for recreation likely to benefit recreational
opportunities.
It is expected that expenditures by the BLM will
continue to range from about $1 billion to $1.15 billion,
with budgets fluctuating from year to year. It is also
expected that the BLM will continue to generate more
revenue for the federal government than it spends. Oil
and gas resources will likely continue to be the primary
source of revenue, with timber sales, grazing, and
recreation also important, although to a much lesser
degree.
With population increases in the western U.S., it is
expected that effects to private property from activities
on public lands will be an increasing concern. However,
efforts by the BLM, Forest Service, and other agencies
to reduce wildfire risk may have an overall benefit to
private property over the long term if incidence and
severity of wildfire is reduced, particularly in the WUI.
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Contribution of Alternatives to Cumulative Effects
All of the alternatives would reduce the costs of
herbicide treatments, although it is expected that there
would be no difference in the BLM’s overall
expenditures on vegetation treatments. Under
Alternative B, the cost reduction could be between 1
and 2 percent, whereas the reduction would be less than
1 percent under Alternative B, and a fraction of 1
percent under Alternative D. Annual vegetation
treatments costs, assuming all methods, would be
similar under all the alternatives, amounting to an
estimated $1.4 billion. Under all alternatives, short-term
adverse impacts in terms of costs and long-term
improvements in terms of resource benefits would be
similar, although the cost to obtain the same degree of
benefit could be slightly higher under Alternatives B
and C because of lower herbicide costs. Under all
alternatives, the contribution of treatment actions to the
economy of the western U.S. would continue to be
minor.
Human Health and Safety
Past Effects and Their Accumulation
Past effects to human health and safety, and their
accumulation, are discussed in the 2007 PEIS (USDOI
BLM 2007a:4-238 to 4-241). In terms of occupational
risks, workers in the western U.S., including workers on
public lands, have been exposed to risks associated with
use of power tools, vehicles, loud noises, and other risk
factors. Certain occupations may expose workers to
chemicals (including pesticides) and other substances
that can lead to cancer and other health conditions. Job-
related fatalities and injuries continue to be reported in
the western states. The public is also exposed to various
chemicals and environmental pollutants, and may be at
risk for injury or death as a result of fire, particularly in
the WUI.
Future Effects and Their Accumulation
Future effects to human health, and their accumulation,
are discussed in the 2007 PEIS (USDOI BLM 2007a:4-
212 to 4-213). Many of the health and safety concerns
discussed in the preceding paragraph will continue to be
concerns in the future. Many occupations will continue
to be associated with some level of risk, particularly
when vehicles and machinery are operated, and when
workers are exposed to potentially hazardous chemicals.
Firefighters will continue to be exposed to high levels of
risk. However, implementation of employer health and
safety programs and associated steps to reduce risk will
continue to help protect worker health and safety.
Pesticide operators and other BLM workers will
continue to transport and handle ingredients that pose a
toxicological risk to humans, although these risks will
continue to be minimized through SOPs and use of
appropriate personal protective equipment.
The public will continue to be exposed to various
pollutants; the cumulative effects of these exposures
could include development of cancer and health
conditions. Risks associated with wildfire, such as
smoke inhalation risks and potential for loss of life,
could increase if large, difficult to control wildfires
continue to increase in frequency and size. Treatment
programs by the BLM and other agencies to take
aggressive actions to reduce catastrophic fire risk may
continue to offset some of the wildfire risk in targeted
areas, such as the WUI where the most people are likely
to be affected.
Contribution of Alternatives to Cumulative Effects
Under all of the alternatives, a similar acreage would be
treated with herbicides annually, with the same
treatment goals, so the geographic extent of adverse and
beneficial effects associated with herbicide use would
also be similar. Under all of the alternatives, herbicides
with some risk to human health would be applied in the
same areas on public lands, although the number of
herbicides used and the amounts of usage would vary
among the alternatives. Under the action alternatives,
two or three new active ingredients would be used, in
addition to currently approved herbicides, resulting in a
cumulative increase in the number of ingredients used
on public lands. The new herbicides have no to very low
risk to human health via various exposure scenarios.
The potential for synergistic human health effects
associated with mixtures of multiple ingredients is not
known.
Benefits to human health from herbicide treatments
would be similar under all the alternatives. Treatments
would help reduce wildfire risk and associated risks to
human health. Over the long term, restoration of natural
fire regimes and improvement in ecosystem health
should reduce risks to human health from activities
originating on public lands and affecting public land
users or those living near public lands.
Unavoidable Adverse Effects
The 2007 PEIS summarizes the unavoidable adverse
effects that would occur as a result of the BLM’s
vegetation management programs, including herbicide
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ENVIRONMENTAL CONSEQUENCES
treatments with the 18 currently approved herbicides
and other forms of vegetation treatment analyzed in the
2007 PER (USDOl BLM 2007a:4-243 to 4-246).
As the three new herbicides would be incorporated into
the BLM’s treatment programs, but the extent and goals
of those programs would remain unchanged, the
analysis provided in the 2007 PEIS is largely applicable
to treatments involving aminopyralid, fluroxypyr, and
rimsulfuron. This information is summarized here.
Air Quality
Herbicide treatments would continue to result in the
release of air quality pollutants, including GHGs. No
new air emissions would occur as a result of adding the
three new herbicides.
Soil Resources
Herbicide treatments would continue to result in
increased erosion over the short term, and potentially
loss of soil and soil function and productivity. No
additional impacts to soil would occur as a result of
adding the three new herbicides, although soil resources
would be exposed to new active ingredients and their
degradation products.
Water Resources and Quality
Herbicide treatments would continue to result in soil
erosion and surface water runoff from removal of
vegetation, and impacts to surface water and
groundwater quality. The geographic extent of water
resources potentially exposed to herbicide treatments
would show little change as a result of adding the three
new herbicides, but new active ingredients, degradates,
and other ingredients would be released to the
environment, increasing the number of potential water
contaminants.
Wetland and Riparian Areas
Herbicide treatments in wetlands and riparian areas
would continue to increase soil erosion and surface
water runoff, potentially leading to streambank erosion
and sedimentation into wetlands and riparian areas.
Removal of vegetation could also alter wetland
hydrology and function. The extent of these impacts
would not change substantially from current levels as a
result of adding the three new herbicides.
Vegetation
Herbicide treatments would continue to cause
unavoidable short-term disturbances to plant
communities by killing both target and non-target
plants. The extent of these impacts is not expected to
change substantially as a result of adding the three new
herbicides, as they act by modes of action similar to
those of some of the currently approved active
ingredients.
Fish and Other Aquatic Organisms
Removal or alteration of vegetation in and near aquatic
habitats would continue to affect fish and other aquatic
organisms through release of sediments into habitats, or
by changing other habitat characteristics (such as
amount of shading). With the addition of the three new
herbicides, the extent of these impacts would show little
change.
Wildlife Resources
Some wildlife would be exposed to herbicides as a
result of treatments and could suffer toxicological
effects. Adding the three new herbicides would not
substantially change the level of effects to wildlife, and
could potentially decrease them, as the three new
herbicides are of low risk to wildlife. Herbicide
treatments would also continue to alter wildlife habitat,
and could cause unavoidable short-term adverse effects
to wildlife habitat and behavior. With the addition of the
three new herbicides, the extent of these impacts would
not change substantially.
Livestock
Herbicide treatments would continue to temporarily
affect livestock by removing non-target vegetation used
as forage or for other needs. Some exposure of livestock
to herbicides could also occur, potentially resulting in
toxicological effects. The three new herbicides do not
pose a risk to livestock, and would not increase impacts
to vegetation used by livestock over current levels.
Wild Horses and Burros
Herbicide treatments would continue to have the
potential to impact wild horses and burros by removing
non-target vegetation used as forage or for other needs.
Some exposure of livestock to herbicides could also
occur, potentially resulting in toxicological effects. The
three new herbicides do not pose a risk to wild horses
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ENVIRONMENTAL CONSEQUENCES
and burros, and would not increase impacts to
vegetation used by these animals over current levels.
Paleontological and Cultural Resources
Paleontological Resources
Herbicide treatments would continue to have the
potential to affect fossil resources through exposure of
these resources or potential chemical alterations
associated with active or other ingredients in herbicide
formulations. The action to add three new herbicides
would not increase the likelihood of risk to these
resources unless one of the active ingredients is
particularly damaging to fossil resources. Use of SOPs
would reduce the likelihood of impacts to
paleontological resources.
Cultural Resources and Traditional Lifeway
Values
Herbicide treatments would continue to have the
potential to affect cultural resources, primarily through
chemical alterations of cultural materials associated
with active or other ingredients in herbicide
formulations. Use of herbicides would continue to have
the risk of impacting non-target plant species of cultural
importance to Native peoples. Herbicide treatments
could also discourage or prohibit Native peoples from
using these areas, or potentially harm Native peoples
harvesting plant materials or conducting other activities
in treated areas. However, the addition of three new
active ingredients would not increase these unavoidable
risks or impacts beyond current levels.
Visual Resources
Herbicide treatments would not result in unavoidable
adverse effects to visual resources over the long term,
but over the short term they could adversely affect the
visual character of the treated areas. Adding the three
new herbicides would not substantially change the
extent or degree of effects to visual resources.
Wilderness and Other Special Areas
Herbicide treatments would continue to affect
wilderness and other special areas through removal of
vegetation, alteration of plant communities, and through
human presence in wilderness areas. Adding the three
new herbicides would not substantially change the
extent or degree of these effects.
Recreation
Unavoidable adverse effects to recreation from
herbicide treatments would continue to include scenic
degradation and noise associated with treatments,
alteration of resources, and the temporary closure of
certain areas to recreation. Adding the three new
herbicides would not substantially change the extent or
degree of these effects.
Social and Economic Values
Short-term closures or restrictions on public lands, such
as implementation of herbicide use re-entry restrictions
to protect public health or to restrict access by grazing
animals for the time period specified on the herbicide
label until seeding efforts are established (up to two
growing seasons), would continue to be unavoidable.
Communities that are particularly dependent on a single
industry would continue to be the most susceptible to
adverse effects to employment or income due to
vegetation treatment projects. In particular, ranching
communities and recreation-dependent communities
may be more affected than communities with
diversified industries.
Limits on grazing activity on public lands could
continue to put additional pressure on often tight
economic margins in ranching. Closures of treatment
areas for extended periods of time could temporarily
affect some recreational uses and commercial activities.
Adding the three new herbicides would not substantially
change the extent or degree of these effects.
Human Health and Safety
Herbicide treatments would continue to have the risk of
harming workers or the public, primarily through
accidental exposures to herbicides. Although workers
would follow all SOPs to reduce risks, not all risks
could be avoided. The addition of three new active
ingredients would not increase the degree of risks to
human health and safety. The three new active
ingredients have no to low risks to humans.
Relationship between the Local Short¬
term Uses and Maintenance and
Enhancement of Long-term
Productivity
This section discusses the short-term effects of
herbicide treatment activities, versus the maintenance
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ENVIRONMENTAL CONSEQUENCES
and enhancement of potential long-term productivity of
public land environmental and social resources. The
2007 PEIS summarized this information for the BLM’s
ongoing vegetation management programs (USDOl
BLM 2007a:4-246 to 4-251).
As the three new herbicides would be incorporated into
the BLM’s vegetation management programs, but the
extent and goals of those programs would remain
unchanged, the analysis provided in the 2007 PEIS is
largely applicable to treatments involving aminopyralid,
fluroxypyr, and rimsulfuron. This information is
summarized here.
In all cases, short-term refers to the total duration of
vegetation treatment activities (10 to 15 years) and long¬
term refers to an indefinite period of time.
Air Quality
Herbicide treatments would have a small short-term
impact on air quality, predominantly associated with use
of vehicles during applications. Much of the focus of
treatments is on reducing hazardous fuels, restoring
natural fire regimes and reducing the occurrence of
large, unwanted wildfires. Thus, the proposed
vegetation treatments should reduce smoke emissions
associated with public lands over the long term. While
individual herbicide treatment projects would have
GHG emissions, repeated herbicide treatments and post¬
treatment reseeding/restoration may reduce the risk of
wildfire, leading to fewer GHG emissions in the long
term.
Soil Resources
Although treatments would have short-term effects on
soil condition and productivity, it is predicted that the
soil disturbance associated with restoration activities
would have less impact and be less severe than soil
erosion caused by wildfire and encroachment by
invasive species and noxious weeds. Furthermore,
monitoring and evaluation, integrated with an adaptive
management approach, would allow the BLM to adjust
treatments to reduce soil disturbance to levels similar to
historical conditions.
Restoration activities that move forests and rangelands
toward historical ranges of variability would provide
favorable conditions for soil functions and processes,
and contribute to long-term soil productivity levels at
the broad scale (USDA Forest Service and USDOl
BLM 2000).
Water Resources and Quality
Herbicide treatments would result in short-term impacts
to water quality through movement of active and other
ingredients into the water and through erosion and
surface water runoff from treatment sites. Successful
control of invasive plants, however, would lead to
improved conditions in watersheds over the long term,
with the greatest improvement likely to occur in
degraded watersheds. Additionally, treatments that
reduce hazardous fuels would benefit ecosystems by
reducing the chances of a large, unwanted wildfire,
which could result in the destruction of a large amount
of high quality habitat, potentially leading to erosion,
especially if followed by heavy rainfall. Hazardous
fuels reduction would also decrease the likelihood that
wildfire suppression activities would occur in or near
aquatic habitats.
Wetland and Riparian Areas
Removal of vegetation could cause a short-term
increase in soil erosion and surface water runoff and
could impact wetland and riparian areas. Additionally,
there could be some release of active and other
ingredients into wetland and riparian areas. Successful
control of invasive plants in wetlands and riparian areas,
however, would lead to improved conditions in these
habitats over the long term. The eventual growth of
desirable vegetation in treated areas would moderate
water temperatures, buffer the input of sediment and
herbicides from runoff, and promote bank stability in
riparian areas.
Vegetation
Herbicide treatments would remove vegetation from
treatment sites over the short term, and could impact
non-target desirable vegetation. However, treatments
that remove or control invasive vegetation would
benefit non-target species by providing increased access
to water and nutrients and enhanced vigor from reduced
competition with invasive species. Over the long term,
target sites should have an increased component of
native species. Additionally, control of cheatgrass and
other fire adapted species would benefit the long-term
health of plant communities in which natural fire cycles
have been altered. Over the long term, treatments
should also reduce the occurrence of large, unwanted
wildfires across the western U.S.
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ENVIRONMENTAL CONSEQUENCES
Fish and Other Aquatic Organisms
Herbicide treatments could have short-term adverse
impacts to fish and other aquatic organisms through
release or movement of active and other ingredients into
aquatic habitats. These impacts would be minimized
through the use of buffers. The three new herbicides are
of low risk to aquatic species. Over the long term,
control of noxious weeds in riparian habitats, reduction
of wildfire risk through hazardous fuels reduction, and
other efforts to improve the quality of watersheds would
have beneficial effects on fish and other aquatic
organisms. Benefits would include improved habitat
quality, improved hydrologic functions, and reduced
soil erosion.
Wildlife Resources
All treatments could have short-term adverse impacts to
wildlife and wildlife habitat, as discussed under
Unavoidable Adverse Effects above. The three new
herbicides are of lower risk to wildlife than many of the
currently approved herbicides. Treatments that improve
habitat would provide long-term benefits to wildlife by
restoring wildlife habitat and reducing the risk of
catastrophic wildfire. Habitat improvements would
likely be slow, occurring over multiple decades.
Livestock
The proposed vegetation treatments would affect the
availability and palatability of livestock forage over the
short term. These impacts would begin to disappear
within one to two growing seasons after treatment. Over
the long term, the quality of forage should improve, as
noxious weeds that are unpalatable or toxic to wildlife
would be controlled. Additionally, reduction in the risk
of future catastrophic wildfire would benefit livestock
by preventing the temporary loss of large blocks of
rangeland to fire, and reducing the prevalence of fire-
adapted species.
Wild Horses and Burros
The proposed vegetation treatments would affect the
availability and palatability of vegetation over the short
term. These impacts would begin to disappear within
one to two growing seasons after treatment. Over the
long term, the quality of forage should improve, as
noxious weeds that are unpalatable or toxic to wild
horses and burros would be controlled. Additionally,
reduction in the risk of future catastrophic wildfire
would benefit wild horses and burros by preventing the
temporaiy loss of large blocks of habitat that would
displace wild horses and burros and potentially reduce
the AML.
Paleontological and Cultural Resources
Paleontological Resources
Because paleontological resources are nonrenewable,
there is no difference between short-term and long-term
impacts. These resources cannot recover from some
types of adverse impacts. Once disturbed, the materials
and information of paleontological deposits may be
permanently compromised. Chemical alterations to
fossil materials would likely be permanent. Any
destruction of paleontological sites, especially those
determined to have particular scientific value, would
represent long-term losses. Furthermore, once
paleontological deposits are disturbed and exposed,
natural erosion could accelerate the destruction of
fossils, and exposed fossils would be vulnerable to
unauthorized collecting and digging. Any discoveries of
paleontological resources as a result of surveys required
prior to treatment would enhance long-term knowledge
of the area and these resources.
Cultural Resources and Traditional Lifeway
Values
Any destruction of cultural resource sites would
represent long-term losses. Chemical alterations to
historic materials would likely be permanent.
Archaeological excavation to recover scientific data
under the terms of an appropriate data recovery plan
could result in the partial or total destruction of the site,
although the recovered data would effectively mitigate
for this destruction. Any investigations of cultural
resources made during inventories or investigations
required prior to herbicide treatments would enhance
knowledge of the history and early inhabitants of the
region and serve to effectively mitigate further potential
effects of activities in the area.
Herbicide treatments could have short-term impacts on
traditional lifeway values by temporarily restricting
access to traditional use sites, and by impacting non¬
target vegetation of cultural importance. Herbicide
treatments could also temporarily displace wildlife used
for subsistence. However, long-term restoration of
native plant communities and natural ecosystem
processes to the benefit of traditional lifeway resources
should compensate for the short-term losses in use.
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ENVIRONMENTAL CONSEQUENCES
Visual Resources
Vegetation treatments would continue to affect visual
resources by changing the scenic quality of the
landscape. Over the short term, impacts to visual
resources from herbicide treatments would begin to
disappear within one to two growing seasons. The
regrowth of vegetation on the site would eliminate
much of the stark appearance of treated areas, and the
site would develop a more natural appearance.
Over the long term, vegetation treatments would likely
improve visual resources on public lands. Treatments
that aim to rehabilitate degraded ecosystems, if
successful, would result in plant communities
dominated by native species (see the Vegetation section
for more information). Native-dominated communities
tend to be more visually appealing and productive than
areas that have been overtaken by weeds (e.g., areas
supporting a cheatgrass monoculture).
Wilderness and Other Special Areas
Impacts to wilderness and other special areas would
begin to disappear within one to two growing seasons
after herbicide treatments. The regrowth of vegetation
on the site would eliminate much of the stark
appearance of treated areas, and the site would develop
a more natural appearance. Benefits to plants and
animals in terms of ecosystem function and improved
forage and cover would occur as the treated area
recovered.
Over the long term, vegetation treatments would likely
improve resources in wilderness and other special areas.
Treatments that successfully rehabilitate degraded
ecosystems would result in plant communities that are
dominated by native species (see the Vegetation section
for more information). Native-dominated communities
often provide better habitat for fish and wildlife,
including species of concern, that occur in communities
with a large component of non-native species.
Recreation
There would be some scenic degradation, as well as
distractions to users (e.g., noise from vehicles), from
treatments. In addition, there would be some human
health risks to recreationists associated with exposure to
herbicides, which would be minimized through use of
SOPs. Finally, some areas would be off-limits to
recreation activities as a result of treatments. These
effects would be localized and short-term.
Treatments that restore native vegetation and natural
fire regimes and other ecosystem processes would
provide a long-term benefit to recreationists. Treatments
would improve the aesthetic and visual qualities of
recreation areas, reduce the risk of recreationists coming
into contact with noxious weeds and poisonous plants,
increase the abundance and quality of plants harvested
from public lands, and improve habitat for fish and
wildlife sought by fishermen and hunters.
Social and Economic Values
Over the short term, restrictions on the use of treated
lands could cause social and economic hardship to
affected parties. However, individuals and industries
involved in the restoration of native ecosystems on
public lands would benefit.
Over the long term, most users of public lands, and
those with interests near public lands, would likely
benefit. An important goal of treatments is to restore
ecosystem health so that public lands can provide
sustainable and predictable products and services. In
addition, treatments would reduce risks to communities
associated with large-scale wildfire, improve ecosystem
health to the benefit of recreationists and other public
land users, and emphasize employment- and income-
producing management activities near those
communities most in need of economic support and
stimulus. The enhancement in long-term productivity of
public lands to provide for social and economic needs
would reflect not only the success or failure of
treatments, but also the influence of outside forces (e.g.,
economy, lifestyle changes, and climate) over which the
BLM and other federal agencies have no control
(USDA Forest Service and USDOI BLM 2000).
Human Health and Safety
Herbicide treatments could harm the health of workers
and the public over the short term, although SOPs
would minimize these risks. The three new herbicides
have no to low health risks under most exposure
scenarios. Adverse reactions to herbicides could cause
minor to severe discomfort to sensitive individuals, but
most symptoms would go away in a few hours. If
serious injury or death were to result from treatments
(most likely to occur as a result of vehicle operation),
the effects to the health of the affected individual would
be long-term, or in the case of death, permanent.
All treatments that successfully reduce the cover of
noxious weeds and restore native vegetation would help
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ENVIRONMENTAL CONSEQUENCES
to restore natural fire regimes and improve ecosystem
health, which would in turn provide a benefit to human
health. A reduced risk of wildfire would reduce the risk
of injury, death, and other health risks associated with
fire. Additionally, herbicide treatments would slow the
spread of poisonous and other noxious weeds that are
harmful or annoying to humans.
Irreversible and Irretrievable
Commitment of Resources
This section identifies irreversible and irretrievable
commitments of resources that would occur from
herbicide treatments. Irreversible and irretrievable
commitments of resources refer to impacts or losses to
resources that cannot be reversed or recovered.
Examples are the extinction of a species or the
permanent conversion of a vegetated wetland to open
water. In the first case, the loss is permanent and not
reversible under current genetic technology. In the
second case, it is possible the open water could be
drained, so while the initial loss of the vegetated
wetland is irretrievable, the action could be reversible.
Since aminopyralid, fluroxypyr, and rimsulfuron would
be utilized in existing treatment programs and are
generally of low risk to resources, their addition to the
list of approved active ingredients would not result in
additional irreversible or irretrievable commitments of
resources above what was discussed in the 2007 PEIS
(USDOI BLM 2007a:4-251 to 4-253). Commitments
pertaining to herbicide treatments from this earlier
document are summarized here.
Air Quality
Air quality would be affected by emissions from
vehicles used during herbicide applications. These
effects would occur only during the period of the
treatment activity and there would be no irreversible or
irretrievable effects on air quality.
Soil Resources
Herbicides could impact soil biota and productivity,
although it is unclear to what degree these effects would
be irreversible or irretrievable. It is expected that soil
functions would eventually return with the
establishment of native vegetation and a reduced risk of
wildfire.
Water Resources and Quality
An accidental herbicide spill could cause damage to
water bodies lasting for several months. The ability to
use water resources in the affected area could be lost for
an unknown period of time. In many cases, these
impacts could be reversed over time through
degradation of the active and other ingredients and their
degradates. In other cases, irreversible or irretrievable
commitments of water resources could occur.
Wetland and Riparian Areas
Although there would be short-term impacts to these
resources from herbicide treatments, these impacts
generally would not be irretrievable and would be
reversed with degradation of the herbicides and if
restoration treatments were successful. Under certain
circumstances, irreversible or irretrievable commitments
of wetland or riparian resources could occur.
Vegetation
Native vegetation and plant productivity that is lost as a
result of treatments would be irretrievable only until
vegetation is reestablished, usually within several
growing seasons. Some individual plants would be
affected irreversibly. However, with the use of
appropriate buffers to protect populations, irreversible
and irretrievable loss of special status plants would not
occur.
Fish and Other Aquatic Organisms
Special status aquatic invertebrates would be at risk for
adverse toxicological effects from herbicide treatments
with fluroxypyr under accidental spill scenarios. Buffer
zones to protect aquatic species would minimize these
risks. While some individual organisms could be
affected irreversibly by alterations to habitat, overall
effects to populations would be reversible. Additionally,
populations would benefit from treatments that improve
riparian and aquatic habitats.
Wildlife Resources
While none of the three new herbicides pose a
toxicological risk to wildlife, some individual organisms
could be affected irreversibly by equipment used during
treatments or habitat modification. However, overall
effects to populations would be reversible. Native
wildlife and habitat productivity that is lost as a result of
treatments would be irretrievable until native plant
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ENVIRONMENTAL CONSEQUENCES
communities are reestablished, usually within several
growing seasons. Treatments that improve rangeland
and forestland ecosystem health, including plant
productivity, would translate into benefits for wildlife,
except for those species that have adapted to or thrive in
areas where vegetation has changed from historic
conditions.
Livestock
Short-term loss in vegetation function and quality from
treatments would have a short-term impact on livestock
productivity. Although some livestock could be
displaced from public lands, forage could be found
elsewhere, although possibly at a higher cost. As
rangelands improve as a result of treatments, their
ability to support livestock use levels at or near current
levels should also improve. Herbicide treatments have
the potential to cause toxicological impacts to livestock,
although the three new herbicides are of low toxicity to
large grazing mammals. Any impacts to the livestock
operation and industry would be reversible.
Wild Horses and Burros
Short-term loss in vegetation function and quality as a
result of herbicide treatments would have a short-term
impact on wild horse and burro productivity. Wild
horses and burros could be removed from rangelands to
reduce their impacts to rangeland health and to speed up
the process of rangeland restoration. These animals
would be placed into adoption or long-term pastures, or
sold. As rangelands improve, their ability to support
populations of wild horses and burros near current
levels would also improve.
Herbicide treatments have the potential to cause
toxicological impacts to wild horses and burros,
although the three new herbicides are of low toxicity to
large grazing mammals. Any associated impacts to wild
horse and burro populations would be reversible.
Paleontological and Cultural Resources
Paleontological Resources
Because paleontological resources are nonrenewable,
any impacts would render the resource disturbance
irreversible and the integrity of the resource
irretrievable.
Cultural Resources and Traditional Lifeway
Values
Cultural resources are nonrenewable, so any impacts
would be irreversible, and the integrity of the affected
resource would be irretrievable. Any chemical changes
to cultural materials associated with herbicide exposure
would potentially be permanent. Archaeological
excavation to recover scientific data under terms of an
appropriate data recovery plan could result in the partial
or total destruction of the site, although the recovered
data would effectively mitigate for this destruction. Any
investigations of cultural resources made during
inventories or investigations required prior to vegetation
treatments would enhance knowledge of the history and
early inhabitants of the region and serve to effectively
mitigate further potential effects of activities in the area.
Overall, such finds could help fill gaps in our
knowledge of the history and early inhabitants of the
area.
Vegetation treatment activities would impact plants and
animals of traditional importance to Native peoples.
However, these effects should be short-term and
reversible, as native plant communities would recover
and habitat for fish and game species would improve.
Visual Resources
There would be no irreversible or irretrievable
commitment of visual resources. Although there would
be short-term impacts to visual resources from
vegetation treatments, loss of visual resources would
not be irretrievable and could be reversed if restoration
treatments are successful.
Wilderness and Other Special Areas
There would be no irreversible or irretrievable
commitment of resources. Although there would be
short-term impacts to wilderness and special area
resources from vegetation treatments, these impacts
would not be irretrievable and could be reversed if
restoration treatments are successful.
Recreation
There would be no irreversible or irretrievable
commitment of recreation resources. Although there
would be short-term impacts to recreation resources
from vegetation treatments, these impacts would not be
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ENVIRONMENTAL CONSEQUENCES
irretrievable and could be reversed if restoration
treatments are successful.
Social and Economic Values
Herbicide treatments would continue to involve a
substantial commitment by the BLM in terms of labor
and financial resources. Herbicide treatments associated
with restoration activities would continue to provide
temporary jobs in the western U.S. Once financial
resources are used, they cannot be retrieved. Treatments
that result in the closure of recreation or grazing areas
could have an irretrievable impact on the income of
those involved in these industries.
Human Health and Safety
Serious injury or death to humans caused by herbicide
treatments could be irreversible and irretrievable. Risk
of death or serious injury is very low, based on low
numbers of past incidents, but accidents do occur. It is
possible that humans would experience minor
discomfort from herbicide treatments, but provided
appropriate safety SOPs are implemented, these effects
would be short-term and reversible.
Energy Requirements and
Conservation Potential
Herbicide formulations may contain petroleum
products, and all herbicide treatment methods require
the use of energy, to operate equipment to treat
vegetation and to transport workers to and from the job
site. Less energy would be used to conduct aerial
treatments than ground treatments for each acre treated.
Because all of the alternatives treat the same land area
using herbicides, energy use for all, including the No
Action Alternative, would be similar.
Natural or Depletable Resource
Requirements and Conservation
Herbicide formulations may contain natural or
depletable resources as constituents of the herbicide
products or as carriers. It is anticipated that the use of
natural and depletable resources would be minimal, and
would be roughly the same under all of the alternatives,
as the acreage treated would be similar. All herbicide
treatment methods require the use of energy, as
described in the preceding section.
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CHAPTER 5
CONSULTATION AND COORDINATION
CONSULTATION AND COORDINATION
CHAPTER 5
CONSULTATION AND COORDINATION
Preview of this Section
This section summarizes the public involvement and
scoping and public comment process conducted for the
preparation of the Draft PEIS and BA. Summaries of
agency and govemment-to-government consultation
are provided. The individual preparers, with their areas
of expertise and/or responsibility, are also listed.
Public Involvement
Federal Register Notices and
Newspaper Advertisements
The BLM published a Federal Register Notice of
Intent (Notice) on December 21, 2012 (Federal
Register, Volume 77, Number 246, Pages 75648-
75649). The BLM also released a press release
concurrent with the Notice. The Notice asked the
public to provide comments on the proposal to use
aminopyralid, fluroxypyr, and rimsulfuron in its
vegetation treatment activities, and to identity issues
that should be considered in the PEIS. The Notice
provided the locations and dates of the public scoping
meetings, and stated that public comments on the
proposal would be accepted until the close of the
scoping period, or 15 days after the last public
meeting, whichever was later. The press release
indicated that the public comment period for the
scoping process was 60 days.
Public notices of the scoping period and public
meetings were placed in newspapers serving areas in
or near locations where the meetings were held.
Scoping Meetings
Three scoping meetings were held within the
geographic area covered by the project. One meeting
was held in Worland, Wyoming (January 7, 2013), one
was held in Reno, Nevada (January 9) and one was
held in Albuquerque, New Mexico (January 10). The
scoping meetings were conducted in an open-house
style. Informational displays were provided at the
meetings, and handouts describing the project, the
NEPA process, and issues and alternatives were given
to the public. A formal presentation provided the
public with additional information on program goals
and objectives. At each meeting, the presentation was
followed by a question and answer session.
The BLM received 26 requests to be placed on the
project mailing list from individuals, organizations,
and government agencies, and 43 written comment
letters or facsimiles on the proposal. In addition, to
written comments received at the scoping meetings,
four individuals provided oral comments. As most of
the comment letters provided multiple comments, a
total of 225 individual comments were catalogued and
received during the public scoping period.
A Scoping Summary Report for Vegetation Treatments
Using Aminopyralid, Fluroxypyr, and Rimsulfuron on
Bureau of Management Lands in 17 Western States
Programmatic EIS (AECOM 2013) was prepared that
summarized the issues and alternatives identified
during scoping.
Frequently Asked Questions
The BLM posted a list of frequently asked questions
(FAQs) to the project website, with handouts of the
same information provided at the public meetings. The
FAQ handout discussed the BLM’s proposed project,
including where the proposed activities would occur.
The handout also discussed the PEIS development
process and potential issues to be examined in the
PEIS, and detailed the public comment opportunities
and instructions.
Public Review and Comment on the
Draft Programmatic EIS
The Notice of Availability of the Draft Programmatic
Environmental Impact Statement for Vegetation
Treatments Using Aminopyralid, Fluroxypyr, and
Rimsulfuron on Bureau of Land Management Lands in
17 Western States was published in the Federal Register
on June 19, 2015. On the same date, the BLM issued a
press release notifying the public that the Draft PEIS
was available for public review and comment. The
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Draft PEIS and supporting documentation were posted
to a BLM website, where the public was able to
download a copy of these documents. Copies of the
documents were available upon request and for public
inspection at all BLM state, district, and field office
public rooms.
A total of 98 substantive comments were received on
the Draft PEIS. Comments were received via letter,
electronic mail, and facsimile. A summary of the
comments received, issues identified, and specific
comments and responses are presented in Chapter 6 of
this PEIS. All comments are reproduced in the CD of
supporting documentation.
Agency Coordination and
Consultation
Endangered Species Act Section 7
Consultation
The BLM initiated informal consultation with the
USFWS and NMFS (the Services) in February 2014. A
BA evaluating the likely impacts to listed species (and
species proposed for listing) and critical habitat from the
proposed action, and presenting programmatic level
conservation measures to minimize impacts to these
species, was submitted to the Services for their review
and comment. An Essential Fish Habitat Assessment, as
required under the Magnuson- Stevens Fishery
Management Act, was submitted as an appendix to the
BA.
After receipt and review of the BA, the BLM and the
Services held several meetings to discuss the document
and to respond to information requests from the
Services. Meetings/conference calls were held on May
28, June 12, June 23, July 30, August 20, September 3,
November 6, 2014, and January 9, 2015. The Services
provided comments on the BA in July 2014, and
subsequent discussions provided resolutions to issues
that were raised in the review comments.
Consultation letters were submitted by the Services in
October, 2015. Copies of these letters are provided in
the CD of supporting documentation that accompanies
this PEIS.
Risk Assessment Coordination
Ecological and human health risk assessments for
aminopyralid, fluroxypyr, and rimsulfuron were
prepared in accordance with the protocols that were
developed for risk assessments prepared for the 2007
PEIS. In 2002, The BLM convened a group of
scientists from the USEPA, USFWS, NMFS, BLM,
and its contractor, ENSR Corporation, to work
cooperatively to develop protocols for conducting
HHRAs and ERAs that would meet agency guidelines
and scientific and public scrutiny. Weekly conference
calls were held among the participants beginning in
May 2002, and continuing through November 2002. A
meeting was held in Boise on September 12 and 13,
2002, and in Denver, Colorado, on November 5 and 6,
2002, to discuss the risk assessment protocols.
Conference calls were held intermittently from
November 2002 through July 2003 to resolve
remaining issues related to the protocols. Conference
calls were also held among agency participants during
preparation of the risk assessments. The final HHRA
and ERA protocols were finalized and submitted to the
Services and USEPA in August 2003. These protocols
detail the methodology used to evaluate ecological and
human health risks associated with the use of
chemicals for controlling invasive vegetation and to
determine whether these chemicals are safe for use by
the BLM. The risk assessments evaluated a variety of
possible exposure scenarios.
Cultural and Historic Resource
Consultation
The BLM consulted with State Historic Preservation
Officers as part of Section 106 consultation under the
National Historic Preservation Act to determine how
treatments with the three new herbicides could impact
cultural resources listed on or eligible for inclusion in
the National Register of Historic Places. Formal
consultations with State Historic Preservation Officers
and Indian Tribes also may be required during
implementation of individual projects. Consultations
with State Historic Preservation Officers are ongoing
and will be completed by the time of the signing of the
ROD.
Government-to-government
Consultation
Federally recognized tribes have a unique legal and
political relationship with the government of the
United States, as defined by the U.S. Constitution,
treaties, statutes, court decisions, and executive orders.
These definitive authorities also serve as the basis for
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CONSULTATION AND COORDINATION
the federal government’s obligation to acknowledge
the status of federally recognized tribes.
The BLM consults with federally recognized tribes,
consistent with the Presidential Executive
Memorandum dated April 29, 1994, on Government-
to-Government Relations with Native American Tribal
Governments', and Executive Order 13175 dated
November 6, 2000, on Consultation and Coordination
with Indian Tribal Governments.
Policies enacted by the USDOl during August of 2012
require federal agencies to consult with Alaska Native
Corporations — the entities created under the Alaska
Native Claims Settlement Act (ANCSA) of 1971 — on
the same basis as American Indian or Alaska Native
Tribes.
The BLM formally consults with federally recognized
tribes and Alaska Native Corporations before making
decisions or undertaking activities that will have a
substantial, direct effect on federally recognized tribes,
or their assets, rights, services, or programs. To this
end, formal government-to-govemment consultation
with federally recognized traditional governments and
Alaska Native Corporations was initiated by written
correspondence in April 2013 (see Appendix B).
The letter sent to all of the tribal governments and
Alaska Native Corporations described the proposed
action. The tribes and native corporations were
provided with information on the project and were
asked to provide the BLM with their concerns about
vegetation treatments with the three new active
ingredients and their impacts on subsistence, religious,
and ceremonial purposes and traditional cultural
properties. The BLM also invited the tribes and native
corporations to call if they had questions or concerns,
or wanted additional information.
The BLM prepared an AN1LCA Section 810 analysis
of subsistence impacts to evaluate the potential
impacts to subsistence pursuits in Alaska. This
analysis is found in Appendix C of this PEIS.
List of Preparers of the
Programmatic EIS and BA
The following specialists (and company/agency and
area of specialty) that participated in the development
of this PEIS are listed below (Table 5-1). Because
much of the information in this PEIS was summarized
or incorporated by reference from the 2007 PEIS, the
people who contributed to the 2007 PEIS also
contributed to the current document. Those
individuals, though not listed here, are included by
reference (USDOl BLM 2007a:5-5 to 5-9). Agencies
included the BLM, USEPA, USFWS, and NMFS.
Subcontractors that provided assistance to the BLM
during preparation of the PEIS included AECOM
(previously ENSR Corporation); Historical Research
Associates (HRA); Planera, Inc. (Planera); and Paleo
Consultants.
TABLE 5-1
List of Preparers of the Programmatic EIS/BA
Contributor
Areas of Specialty
Years of
Experience
Highest Degree/Education
Bureau of Land Management
Francis Ackley
Wild Horses and Burros
29
B.S., Range and Forest
Management
Cathi Bailey
Wild and Scenic Rivers
27
B.S., Wildland Recreation
Management
Jerry Cordova
Native American and Alaska Native
Issues and Tribal Liaison Coordinator
40
B.S., Political Science and Native
American Studies
Scott Davis
Soil and Water Science, Forestry, and
Ecology
39
M.S., Soil and Water Science
Mike DeArmond
Vegetation, Range, Emergency
Stabilization and Rehabilitation, and
Riparian Areas
35
B.S., Forest Management
Melissa Dickard
Wetlands and Riparian Areas
11
M.S., Wildlife and Fisheries
Science
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TABLE 5-1 (Cont.)
List of Preparers of the Programmatic EIS/BA
Contributor
Areas of Specialty
Years of
Experience
Highest Degree/Education
Scott Feldhausen
Fish and Fish Habitat, and Threatened,
Endangered, and Sensitive Species
Consultation
25
B.S., Fisheries
Coreen Francis
Forestry and Woodland Resources
21
M.F., Silviculture
Eric Geisler
Alaska State Program Lead Lorestry,
Weeds, Botany, Soils, Range, and
Emergency Stabilization and
Rehabilitation
40
Master of Management and
Administration
Krista Gollnick-
Wade
Fire and Fuels Management
30
M.S., Fire Ecology and
Environmental Management
Leonard Gore
Data Coordinator
14
M.S., Geography
Doug Herrema
Special Areas (NLCS)
7
J.D., Law
Mike “Sherm” Karl
Plant Ecology, Livestock Grazing
Management, Terrestrial Vegetation, and
Rangelands
32
Ph.D., Rangeland Ecology
Lee Koss
Surface Water, Hydrology, and Riparian
Restoration
43
B.S., Water Resource Management,
Civil Engineering, and Biology
Richard Lee
Herbicide Use and Management, and
Integrated Pest Management
30
Ph.D., Weed Science
Dave Maxwell
Air Quality, Smoke Management, and
Climate
40
M.S., Air Pollution
M.B.A., Business
M.P.A., Public Administration
John McCarty
Visual Resource Management
32
B.S., Landscape Architecture
Dorothy Morgan
Recreation
20
B.S. Recreation and Parks
Management
Arie Pals
Public Affairs
2
M.A., Sustainable Development
Practice
Frank Quamen
Spatial Data Analyst
6
Ph.D., Wildlife Biology
Gina Ramos
Project Manager and Weed
Management, Invasive Species,
Pesticide Use, Range Management, and
Economics
33
B.S., Range Science
M.B.A., Business Administration
John Sherman
Wildlife Habitat
31
B.S., Wildlife Science and
Microbiology
Josh Sidon
Economic Conditions and Social
Environment
8
Ph.D., Economics
Carol Spurrier
Native Plant Communities, Species of
Concern, and Threatened and
Endangered Plants
34
M.S., Biology
Jeanne Standley
Natural Resources Specialist
23
B.S., Rangeland Resources
Paul Summers
Groundwater Hydrology and Water
Resources
44
B.S., Geology and Water Resources
Rob Sweeten
Visual Resource Management
14
B.L., Landscape Architecture and
Environmental Planning
Peter Teensma
Fire Ecology, Fire Management, and Air
Quality Management
28
Ph.D., Geography
Kim Tripp
Threatened and Endangered Animals
18
M.S., Zoology
Jennifer Whyte
Rights-of-Way
7
M.P.A, Public Administration
Dana Wilson
Public Affairs
5
M.P.P., Public Policy
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TABLE 5-1 (Cont.)
List of Preparers of the Programmatic EIS/BA
Contributor
Areas of Specialty
Years of
Experience
Highest Degree/Education
Kate Winthrop
Native American and Alaska Native
Issues, Paleontology, and Cultural and
Historic Resources
35
Ph.D., Anthropology
AECOM
Alan Abramowitz
Archaeology and Anthropology
12
M.A., Anthropology
Kim Anderson
Assistant Project Manager, Vegetation,
and Species of Concern,
15
M.S., Environmental and Forest
Biology
Christine Archer
Ecological Risk Assessment
10
B.S., Zoology
Suzy Baird
Ecological Risk Assessment
7
M.S., Toxicology
Lisa Bradley
Human Health Risk Assessment
23
Ph.D., Toxicology
Kristen Durocher
Ecological Risk Assessment
11
M.S., Natural Resources and
Terrestrial Ecology
Sarah Esterson
Air Quality/Greenhouse Gases
9
M.S., Public Administration
Michael Inman
Graphics
9
B.S., Geography
Adrienne Kieldsing
Ecological Risk Assessment
8
M.S., Environmental Science with a
specialty in Atmospheric Studies
George Lu
Greenhouse Gas Emissions and Climate
Change
10
B.S., Environmental and Resource
Sciences
Amanda MacNutt
Air Quality Dispersion Modeling
13
B.S., Meteorology
Glen Mejia
Fish, Wildlife, Livestock, and Wild
Horses and Burros
17
B.A., Environmental Studies and
Biology
Tina Mirabile
Water Resources
14
M.B.A., Business Administration
Robert Paine
Air Quality
31
M.S., Meteorology
Melissa Paliouras
Ecological Risk Assessment
7
B.S., Environmental Science
Stuart Paulus
Project Manager, NEPA Specialist, and
Wildlife Ecology
34
Ph.D., Wildlife Ecology
Colin Plank
Ecological and Human Risk Assessment,
and GLEAMS Modeling
12
M.S., Geology
Kelly Vosnakis
Human Health Risk Assessment
11
M.S., Civil and Environmental
Engineering and Environmental
Health
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CHAPTER 6
RESPONSE TO COMMENTS
RESPONSE TO COMMENTS
CHAPTER 6
RESPONSE TO COMMENTS
This chapter provides a summary of the comments
received on the Draft PEIS. A list of the agencies,
organizations, and individuals who submitted comments
is provided. Both general and specific comments and
the BLM’s responses to those comments are presented.
Summary of Comments on the
Draft Programmatic EIS
A total of 41 individual comment documents on the
Draft PEIS and supporting materials were received
during the public comment period from June 19, 2015,
through August 3, 2015. Comments were received via
letter, electronic mail, and facsimile. Thirty-nine
electronic mails, 1 facsimile, and 1 letter were received
(not counting duplicates of the same document sent via
various methods).
All comment documents received on the Draft PEIS, as
well as supporting materials, are provided on the CD of
supporting documentation provided with this PEIS and
included in the Administrative Record.
The project interdisciplinary team reviewed all
comment documents and identified substantive
comments (as defined in the BLM NEPA Handbook H-
1790-1) requiring specific responses. A comment
received a specific response if it 1 ) was substantive and
related to inadequacies or inaccuracies in the analysis or
methodologies used; 2) identified new impacts or
recommended reasonable new alternatives or mitigation
measures; and/or 3) involved substantive disagreements
on interpretation of significance. Numerous comment
letters in support of use of the three new herbicides were
received. These comment letters were noted by the
BLM and have been included in Appendix F, but they
were not considered substantive comments and
therefore did not receive responses.
After all comment documents were reviewed, each
substantive comment was assigned a code and identified
by topic, then distributed to the appropriate member of
the interdisciplinary team for response. A total of 98
substantive comments were identified and responded to.
Table 6-1 shows the breakdown of substantive
comments by topic. More than half (51 percent) of the
comments were concerned with the herbicide effects
analysis, ERAs, the scope of the analysis, effects to
water resources and water quality, the purpose and need
for the proposed action, and BLM herbicide treatment
programs.
Commenting Agencies,
Organizations, and Individuals
Written or oral comments were received from the
agencies, organizations, and individuals listed following
Table 6-1. This list includes all commenters, regardless
of whether the comments they provided were
substantive. The number following the name of the
organization or individual(s) below is a discrete
identification number that was used in the response to
comments process.
Specific Comments and Responses
Individual comments and responses are provided after
the list of respondents. They are organized by subject
headings that are similar to those in the PEIS, based on
the content of the comment, and within each subject
heading they are listed in order of comment number. In
some cases, comments have been modified slightly to
make them clearer to the reader. These modifications
are enclosed in brackets. Additionally, grammatical and
spelling corrections have been made, as appropriate.
Note that in the comment documents provided in
Appendix F, substantive comments are indicated with
gray highlighting, and the corresponding comment
number and PEIS subject heading are provided in
bracketed text.
The text of the Final PEIS has been revised or edited
where appropriate to address the comments.
Information on how specific comments were addressed
and where they are addressed within the Final PEIS is
detailed in the response to each comment.
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RESPONSE TO COMMENTS
TABLE 6-1
Comment Response Summary
Topic
Percent of
Comments
Herbicide effects analysis
13.3
Ecological risk assessment
10.2
Scope of analysis
8.2
Effects to water resources/water
quality
7.1
Purpose and need for the proposed
action
6.1
BLM herbicide treatment programs
6.1
Herbicide active ingredients
4.1
Effects to fish and other aquatic
organisms
4.1
Effects to social and economic values
4.1
Herbicide treatment standard
operating procedures and guidelines
3.1
Effects to vegetation
3.1
Effects to paleontological and
cultural resources
3.1
Public involvement
3.1
Relationship to statutes, regulations,
and policies
2.0
Topic
Percent of
Comments
Interrelationships and coordination
with agencies
2.0
Alternative C - No Aerial
Application of New Herbicides
2.0
Coordination and education
2.0
General environmental consequences
2.0
Effects to air quality
2.0
Effects to wetlands and riparian areas
2.0
Effects to wildlife
2.0
Effects to human health and safety
2.0
Description of the alternatives
1.0
Alternatives considered but not
analyzed further
1.0
Mitigation
1.0
Affected Environment - air quality
and climate
1.0
Effects on soil resources
1.0
Cumulative effects analysis
1.0
Agency/Group/Individual Document Number
Federal Agencies
U.S. Environmental Protection Agency 39
State Agencies
Arizona Game and Fish Department 23
Nevada Division of Environmental Protection, Bureau of Water Pollution Control 41
Nevada State Historic Preservation Office 37
New Mexico Department of Agriculture 20
New Mexico Vegetation Management Association 08
Wyoming Weed and Pest Council 38
County Agencies
Adams County Weed Control (Idaho) 40
Fremont County Weed and Pest District (Wyoming) 1 3
Lincoln County Conservation District of Nevada 16
Teton County Weed and Pest Control District (Wyoming) 3 1
City Agencies
Carlsbad Soil and Water Conservation District (New Mexico) 25
Industry and Related Groups
Dow AgroSciences 29
Idaho Power 15
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Conservation Groups and Related Groups
Alaska Community Action on Toxics 35
Coast Range Association 34
Copper Country Alliance 28
Oregon Wild 14
Individuals
Alpers, Greg (Dow AgroSciences) 1 7
Chamberlain, Scott 02
Duncan, Celestine 09
Eklund, Janelle 03
Eller, Barb 12
Free, Jim 10
Getts, Tom (University of California Cooperative Extension) 2 1
Harris, Todd (Franklin County Noxious Weed Control Board) 22
LaCasse, Richard 05
Maudlin, Larry 18
McDaniel, Kirk (New Mexico State University) 24
Murray, David 27
Pettingill, Jeffrey 07
Pierce, Andy 32
Public, Jean 01
Rehfeldt, Melissa 26
Schumacher, Michelle 36
Shumway, Mel 1 9
Scalet, Laura 06
Thomas, Terry (Idaho Department of Fish and Game) 1 1
Vandeman, Mike 04
Wardlaw, Katy 30
Wroncy, Jan, and Hale, Gary 33
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Responses to Comments
Proposed Action and Purpose and Need, Purpose and Need for the Proposed Action
03-02
Eklund, Janelle
Comment: Truth be known, most broadleaf plants are not weeds nor are they
noxious... Many of them are also beneficial to us, nutritionally speaking. Some so-
called weeds contain ten to one hundred times the nutrition of modem lettuces and
green vegetables.
Response: The comment is outside the scope of the PEIS, which addresses the
proposed use of three new herbicides in the BLM’s vegetation management program.
As stated in Chapter 1 of the PEIS, the BLM considers plants to be weeds when they
degrade the health of public lands and affect resources such as wildlife habitat, native
plant communities, threatened and endangered species habitat, soil, water, and
recreation.
03-05
Eklund, Janelle
Comment: Don’t think of weeds as weeds. 1 have studied wild plants and herbs and
know they have many nutritional and medicinal uses. Our society is too focused on
getting rid of that which we are ignorant about and do not want to take the time to
learn about. Take a lesson from the plants. Please DO NOT use any herbicides
anywhere!
Response: The comment is outside the scope of the PEIS, which addresses the
proposed use of three new herbicide active ingredients in the BLM’s vegetation
management program. As stated in Chapter 1 of the PEIS, the BLM considers plants
to be weeds when they degrade the health of public lands and affect resources such as
wildlife habitat, native plant communities, threatened and endangered species habitat,
soil, water, and recreation. Regardless of the decision made on whether to utilize the
new herbicides, the BLM would continue to use herbicides as one type of vegetation
treatment.
10-01
Free, Jim
Comment: Herbicide approval for Milestone and other similar products needs to be
moved forward and approved for use on [USDOI] lands. [Milestone] has been
approved for use on USDA National Forest Lands for years with no environmental
effects. The tax payers are not being served by having the [USDOI] do the same study
with the same results. It is costing the managers undo expense in managing invasive
species due to poor decision making at the upper level of government. The spread of
invasive species on BLM and Parks is resulting in millions of dollars in loss of habitat
and native vegetation. The cost to treat is way beyond any reason for delaying risk
assessment work for this many years. This lack of decision making is what gives our
agencies a bad name and add fuels to the fire that the federal government is inept in
managing lands and the states should take it over. Please make a decision even if it is
wrong.
Response: Any approvals made by the USDA Forest Service to use aminopyralid,
fluroxypyr, and rimsulfuron on National Forest lands do not apply to vegetation
treatments on BLM-administered public lands. The BLM must still complete its own
EIS to determine the potential effects of using these active ingredients on BLM-
administered lands, and make a decision about whether to allow their use.
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26-07
Rehfeldt, Melissa
36-07
Schumacher, Michelle
26-08
Rehfeldt, Melissa
36-08
Schumacher, Michelle
Comment: The herbicides the BLM wants to add will be used primarily for improving
the forage value of rangelands. BLM land managers plan to use aminopyralid to
control thistle species, fluroxypyr for prickly pear and kochia, and rimsulfuron on
annual grasses like cheatgrass. These particular plants are considered invasive in
rangelands because they decrease the amount of forage available for cattle and sheep.
However, the BLM doesn’t own cattle or sheep, it leases land to people who do. By
adding these three herbicides, the BLM will use public money to maintain the viability
of private ranching interests. In addition to managing land for the direct benefit of
grazing interests, the BLM also maintains [ROWs] for power lines, oil and gas
pipelines, and roads for extraction of natural gas, oil, timber, and minerals. The BLM
maintains over 106,000 rights of way that help keep the resource extractive industries
in business. Maintaining [ROWs] with herbicide represents yet another example of
public funds being used for private gain at the expense of ecological integrity.
Response: The BLM’s reasons for adding the three new active ingredients are
presented in Chapter 1 of the PEIS, under Purpose and Need for the Proposed Action.
The new active ingredients have less environmental and human health risks than some
of the currently approved herbicides, provide increased options for management of
annual grasses, and address herbicide resistance by certain species. While the forage
value of rangelands may be improved as a result of herbicide treatments with
aminopyralid, fluroxypyr, and rimsulfuron, the identified purposes of vegetation
treatments are to reduce the risk of wildfires, stabilize and rehabilitate fire-damaged
lands, and improve ecosystem health on public lands. The concerns raised in the
comment are outside the scope of the PEIS. Regardless of the decision made about
whether to utilize the three new active ingredients, the BLM will continue to
implement vegetation treatments with herbicides that have already been approved for
use. The PEIS does not evaluate policies and programs associated with land use
activities authorized by the BLM (such as livestock grazing and natural gas, oil,
timber, and mineral extraction), or address how funds are spent. A paragraph has been
added to Chapter 1 of the PEIS, under Study Area and Scope of Analysis, that more
clearly discusses the scope of the PEIS.
Comment: The apparent threats that invasive species pose to ecosystems need to be
placed in context of the ecological dynamics where they are found. Invasive species
provide an ecological snapshot of above and below ground processes playing out in
real time. If kochia, pricklypear, Russian thistle, and cheatgrass are growing and
spreading in western states, then wouldn't it be prudent to consider why they are
thriving. Plants don't have malevolent intent or characteristics - they are making use of
available niches. If we treat invasive species as ecological indicators rather than
problems, then it is possible to advance land management practices that make it less
likely that invasive species will thrive.
Response: The BLM recognizes that land management practices play a role in the
introduction and spread of invasive species as well as in preventing their
establishment. However, evaluating these practices is outside the scope of this PEIS.
The BLM is making a decision on whether to add aminopyralid, fluroxypyr, and
rimsulfuron to the list of active ingredients approved for use on public lands under an
already established vegetation management program.
Vegetation treatments using chemical and non-chemical methods are one component
of a strategy for addressing invasive vegetation on public lands, which also includes
prevention, inventory, and rehabilitation. Natural occurrences such as frequent wildfire
and other surface disturbances have increased invasive non-native grass species
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RESPONSE TO COMMENTS
exponentially. The BLM uses current land use plans and site-specific planning to map
out measures to avoid further establishment to reduce the spread of invasive species.
35-05 Comment: We find that the BLM does not provide justification for the use of the
Alaska Community proposed new herbicides, nor does the agency provide an adequate alternatives
Action on Toxics assessment for non-chemical vegetation management options.
Response: The BLM feels that the efficacy and low environmental and human health
risks of aminopyralid, fluroxypyr, and rimsulfuron provide a justification for their use
on public lands. The proposed new herbicides have lower toxicity to humans, fish, and
wildlife than several of the herbicides currently approved for use by the BLM.
Alternatives entailing use of non-chemical management options were not applicable to
the current PEIS, which is specific to aminopyralid, fluroxypyr, and rimsulfuron. The
BLM already uses herbicides as well as non-chemical methods to manage vegetation
on public lands. These non-herbicide treatment methods were assessed in the 2007
Vegetation Treatments Using Herbicides on BLM Lands in 17 Western States
Programmatic Environmental Report (USDOI BLM 2007c) and earlier EISs
referenced in that document. Regardless of the decision made on whether to utilize the
new herbicides, the BLM would continue to use an Integrated Pest Management
approach for managing vegetation.
Proposed Action and Purpose and Need, Scope of Analysis
04-01 Comment: Humans aren’t smart enough to make safe chemicals. Manual control [as
Vandeman, Mike an alternative to herbicides] is relatively harmless, and guaranteed to work.
Response: The BLM agrees that manual control is an effective method for treating
unwanted vegetation. The BLM uses an Integrated Pest Management approach to
manage invasive vegetation, which includes manual control and other non-herbicide
treatment methods. These non-herbicide treatment methods were assessed in the 2007
Vegetation Treatments Using Herbicides on BLM Lands in 17 Western States
Programmatic Environmental Report (USDOI BLM 2007c) and earlier EISs
referenced in that document. Non-herbicide treatment methods are outside the scope of
the current PEIS. The BLM is making a decision about whether to add three new
active ingredients to its list of herbicides approved for use, and will continue to use
herbicide treatment methods regardless of the decision made in the ROD for the PEIS.
A paragraph has been added to Chapter 1 of the PEIS, under Study Area and Scope of
Analysis, that more clearly discusses the scope of the PEIS.
Comment: Attention must be directed to the nonchemical management of weeds.
Response: Non-chemical methods for managing weeds are outside the scope of the
PEIS. Non-herbicide treatment methods, such as manual, mechanical, and biological
control, and fire, are used by the BLM, in addition to chemical control to manage
invasive plants. They were assessed in the 2007 Vegetation Treatments Using
Herbicides on BLM Lands in 1 7 Western States Programmatic Environmental Report
(USDOI BLM 2007c) and earlier EISs referenced in that document. A paragraph has
been added to Chapter 1 of the PEIS, under Study Area and Scope of Analysis, that
more clearly discusses the scope of the PEIS.
12-03
Eller, Barb
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
6-6
January 2016
RESPONSE TO COMMENTS
26-11
Rehfeldt, Melissa
36-11
Schumacher, Michelle
26-10
Rehfeldt, Melissa
36-10
Schumacher, Michelle
30-01
Wardlaw, Katy
Comment: Unmanaged or poorly managed open range grazing is one of the main
-contributors to the proliferation of invasive species in western rangelands. An
ecologically based, long-term solution to invasive species management would change
the way grazing is practiced on public lands. The BLM should lease land to grazers
that practice holistic, planned grazing rather than open range grazing. Ranchers who
practice holistic grazing find that their weed ‘problems’ disappear as their soil
improves, which also increases water holding capacity, stores carbon in the soil, [and]
improves diversity and abundance of forage plant species, leading to increased animal
health, and eventually higher economic returns.
Response: The concerns raised in the comment are outside the scope of the PEIS. The
PEIS addresses the effects of aminopyralid, fluroxypyr, and rimsulfuron use under
existing vegetation management programs on human health and public land resources.
It does not discuss non-herbicide methods of invasive species management. A
paragraph has been added to Chapter 1 of the PEIS, under Study Area and Scope of
Analysis, that more clearly discusses the scope of the PEIS. Grazing plans are specific
to allotments, which are developed at the field office level, based on existing land use
plan goals and objectives, and following the grazing regulations at 43 CFR 4100. In
some instances, the BLM uses grazing as a tool for controlling invasive plants as one
method of vegetation management.
Comment: Another option would be to reinstate traditional indigenous land
management practices like low-intensity burning to encourage populations of non-
domesticated grazing animals like deer, elk, [pronghorn] antelope, buffalo [American
bison], as well as top predators like wolves and cougars.
Response: Non-herbicide treatments are outside the scope of the PEIS. The BLM is
making a decision about whether to add three new active ingredients to its list of
herbicides approved for use. Regardless of any decisions made in the ROD for the
PEIS, the BLM will continue to use both herbicide and non-herbicide treatment
methods to manage invasive vegetation on public lands. A paragraph has been added
to Chapter 1 of the PEIS, under Study Area and Scope of Analysis, that more clearly
discusses the scope of the PEIS.
Comment: I am against the Bureau of Land Management allowing the three new
herbicides to be used to control invasive species in the western states. The new
herbicides are toxic to the environment and the use of herbicides to control invasive
species is a short-term solution. The mission of the BLM is to protect public lands for
future generations. To do that the BLM needs to put a stop to the grazing practices
which are degrading the land and allowing invasive species to become established.
Response: The potential toxicity of aminopyralid, fluroxypyr, and rimsulfuron to the
environment is discussed in Chapter 4 of the PEIS, under the various resource
sections. The ERAs prepared in support of the PEIS evaluate the toxicity of these
active ingredients to various environmental receptors via various exposure pathways.
Risk assessments determined that the three new active ingredients are of lower toxicity
than many of the active ingredients that are currently approved for use on public lands.
Use of herbicides is one method utilized by the BLM to manage invasive vegetation
on public lands. Within an Integrated Pest Management program, herbicides have
consistently been demonstrated to be effective for vegetation control alone or in
combination with other treatment tools, such as mechanical, fire, biological, and
manual techniques, including passive management.
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
6-7
January 2016
RESPONSE TO COMMENTS
35-04
Alaska Community
Action on Toxics
35-16
Alaska Community
Action on Toxics
35-18
Alaska Community
Action on Toxics
Grazing practices on public lands are outside the scope of this PEIS. A paragraph has
been added to Chapter 1 of the PEIS, under Study Area and Scope of Analysis, that
more clearly discusses the scope of the PEIS. The effects of livestock grazing on
rangeland health has been previously assessed in the October 2004 Proposed
Revisions to Grazing Regulations for the Public Lands (FES 04-39; USDOI BLM
2004b). The livestock grazing program is also assessed in Resource Management Plan
EISs, which outline the goals and objectives for landscape health that livestock grazing
must meet. Limitations or restrictions on grazing due to the spread of invasive species
are determined through activities such as allotment monitoring, permit authorizations,
and watershed assessments. Grazing use restrictions for specific areas are identified
through terms and restriction of livestock grazing permits, as determined through
allotment evaluations and monitoring conducted under the grazing regulations at 43
CFR4100.
Comment: We believe that there are effective and viable alternatives to the use of
herbicides for vegetation management.
Response: Non-herbicide treatments are outside the scope of the PEIS. The BLM is
making a decision about whether to add three new active ingredients to its list of
herbicides approved for use. Regardless of any decisions made in the ROD for the
PEIS, the BLM will continue to use both herbicide and non-herbicide treatment
methods to manage invasive vegetation on public lands. A paragraph has been added
to Chapter 1 of the PEIS, under Study Area and Scope of Analysis, that more clearly
discusses the scope of the PEIS.
Comment: Non-chemical methods exist that are effective and economical. New
technologies and products have been developed that provide safe, economical
alternatives to the use of herbicides.
Response: The BLM agrees that there are non-chemical means of controlling invasive
plants that are effective and economical. The BLM utilizes both chemical and non¬
chemical treatment methods to manage vegetation on public lands. Within an
Integrated Pest Management program, herbicides have consistently been demonstrated
to be effective for vegetation control alone or in combination with other treatment
tools, such as mechanical, fire, biological, and manual techniques, including passive
management. When developing treatment programs, the BLM considers all available
management options, and then selects the method or combination of methods that
optimizes vegetation control with respect to environmental concerns, effectiveness,
and cost of the treatment.
The use of non-chemical methods is outside the scope of the PEIS. Regardless of any
decisions made about the use of aminopyralid, fluroxypyr, and rimsulfuron, the BLM
will continue to use both herbicide and non-herbicide treatment methods to manage
invasive vegetation on public lands. A paragraph has been added to Chapter 1 of the
PEIS, under Study Area and Scope of Analysis, that more clearly discusses the scope
of the PEIS.
Comment: We assert that there are new and proven methods and technologies that
preclude the need for synthetic herbicides, including new acetic acid-based products,
improved infrared steam technology, [and] cultural and biological control methods.
We maintain that an integrated non-chemical approach would be highly effective and
preferable to threatening environmental and community health.
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
6-8
January 2016
RESPONSE TO COMMENTS
Response: Non-herbicide treatments are outside the scope of this PEIS. The BLM is
making a decision about whether to add three new active ingredients to its list of
herbicides approved for use. Regardless of any decisions made in the ROD for the
PEIS, the BLM will continue to use both herbicide and non-herbicide treatment
methods to manage invasive vegetation on public lands. A paragraph has been added
to Chapter 1 of the PEIS, under Study Area and Scope of Analysis, that more clearly
discusses the scope of the PEIS.
Proposed Action and Purpose and Need, Relationship to Statutes, Regulations, and Policies that Influence
Vegetation Treatments
35-03 Comment: The use of herbicides violates Article 29 of the United Nations
Alaska Community Declaration on the Rights of Indigenous Peoples to ensure that disposal of hazardous
Action on Toxics materials shall not take place in the lands and territories of our Indigenous People
without their free prior and informed consent.
Response: The referenced section of the United Nations Declaration of the Rights of
Indigenous Peoples says that “states shall take effective measures to ensure that no
storage or disposal of hazardous materials shall take place in the lands or territories of
indigenous peoples without their free, prior and informed consent” (United Nations
2008). Applying herbicides in accordance with the label instructions does not
constitute “disposal of hazardous materials.” Herbicides would be applied only as
needed to manage populations of invasive plant species, with the intent of benefiting
native species and restoring native plant communities.
As with all vegetation management actions, the BLM would consult with Native
American tribes, Alaska Native groups, and Alaska Native Corporations at the local
level during the NEPA process for all site-specific projects involving the use of
aminopyralid, fluroxypyr, and rimsulfuron.
39-01
U.S. Environmental
Protection Agency
Comment: In May 2015, the Pollinator Health Task Force issued a National Strategy
to Promote the Health of Honey Bees and Other Pollinators which tasked federal
agencies with helping to improve pollinator health. In the strategy, BLM is tasked with
including pollinator friendly plants in land management programs and identifying
plant species that are most beneficial to pollinators to consider in regional
development programs. In addition, the U.S. Forest Service and BLM issued a joint
document highlighting pollinator-friendly [BMPs] for federal lands which guides
federal land managers to effectively and efficiently use available resources and engage
public and private partnerships in taking action for the conservation and management
of pollinators and pollinator habitat on federal lands. The final PEIS should briefly
discuss these new resources and describe how activities involving the use of herbicides
for vegetation management, including the addition of these three herbicides, may
impact implementation of these best practices and the national strategy.
Response: The document referenced in the comment was published after the Draft
PEIS was completed. The text of the PEIS has been changed to include the new
information requested by the comment. Under Chapter 4, Wildlife, the Standard
Operating Procedures section has been expanded to include SOPs from the 2007 PEIS
that pertain directly to pollinators, to mention the National Strategy, and to provide a
link to the website where the Draft Pollinator-Friendly Best Management Practices
for Federal Lands document (USDOI and USDA 2015) can be found and referenced
during project development. The Summary of Herbicide Impacts subsection has also
been modified to include a brief discussion of the potential for adverse effects to
pollinators that utilize target plant species, as well as the potential for beneficial effects
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
6-9
January 2016
RESPONSE TO COMMENTS
by promoting native plant communities that have higher forb diversity than invasive
species monocultures.
The BLM already has SOPs in place to protect pollinators that align with many of the
actions listed in the federal BMP document under the Pesticide Use BMP.
Additionally, herbicide treatments designed to manage invasive plant species address
the guidance provided in the BMP document that links removal of invasive vegetation
with increasing pollinator abundance and diversity. During project development and
environmental analysis at the local level, the BLM would consider the potential for
site-specific herbicide treatments to affect pollinators, and would consult the BMP
document, as well as develop additional project-specific mitigation measures, as
needed.
Proposed Action and Purpose and Need, Interrelationships and Coordination with Agencies
39-11 Comment: [The] BLM should consult with each state lead agency responsible for
U.S. Environmental pesticide regulations prior to use where soils are susceptible to wind erosion or there
Protection Agency are sensitive crops grown in the area in order to minimize unintended impacts.
Response: As discussed in Chapter 1 of the document the PEIS provides a broad,
programmatic level environmental impact analysis to which more specific
environmental documents can be tiered. The discussion on tiering in the PEIS, under
Study Area and Scope of Analysis, has been expanded to more clearly describe the
various levels of environmental analyses and the tiering process. The concerns raised
in the comment would be addressed at the local level during the NEPA process for
site-specific vegetation treatments. At the local level, state agencies would have the
opportunity to provide input on proposed herbicide treatments, and the BLM would
take into account wind erosion and the site-specific potential for off-site movement of
soils treated with a particular herbicide active ingredient when planning treatments and
determining suitable buffers and mitigation. The BLM would also take into account all
applicable state and local regulations at the local level.
41-01
Nevada Division of
Environmental
Protection. Bureau of
Water Pollution Control
Comment: The project may be subject to [Bureau of Water Pollution Control]
permitting. Permits are required for discharges to surface water and groundwaters of
the State (Nevada Administrative Code NAC 445A.228). [Bureau of Water Pollution
Control] permits include, but are not limited to, the following:
• Stormwater Industrial General Permit
• De Minimis Discharge General Permit
• Pesticide General Permit
• Drainage Well General Permit
• Temporary Permit for Discharge to Groundwaters of the State
• Working in Waters Permit
• Wastewater Discharge Permits
• Underground Inspection Control Permits
• Onsite Sewage Disposal System Permits
• Holding Tank Permits
Please note that discharge permits must be issued from the [Nevada Division of
Environmental Protection] before construction of any treatment works (Nevada
Revised Statute 445A.585).
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
6-10
January 2016
RESPONSE TO COMMENTS
Alternatives, Introduction
03-01
Eklund, Janelle
Additionally, the applicant is responsible for all other permits that may be required.
-which may include, but not be limited to:
• Dam Safety Permits
• Well Permits
• 401 Water Quality Certification
• 401 Permits
• Air Permits
• Health Permits
• Local Permits
Division of Water Resources
Division of Water Resources
[Nevada Division of
Environmental Protection]
U.S. Army Corps of Engineers
[Nevada Division of
Environmental Protection]
Local Health or State Health
Division
Local Government
Response: The BLM is aware that vegetation treatment projects involving use of the
three new herbicides may be subject to local permitting requirements. The need for
permits would be determined on a site-specific basis, and the BLM would obtain all
necessary permits prior to implementing any treatment actions involving use of
herbicides.
Comment: Please do not use herbicides to control what you call “noxious weeds.” We
have already learned from other herbicides that were are just killing ourselves but we
never seem to learn from our mistakes. For example, it is proven that Roundup also
kills many crop plants along with ‘pesky weeds.’ So the solution was to use genetic
modification (GM) technology to create plants that would withstand the poisons of
Roundup. Nature fought back and now we are inundated with super weeds and super
bugs, resistant to these poisonous herbicides.
Response: The development of herbicide resistance is an issue of great interest in
production agriculture. Several plant species have been documented as being
resistance to particular herbicide active ingredients. Several factors contribute to the
development of an herbicide-resistant population of a plant species, including the
characteristics of the active ingredient, the genetic makeup of the plant species, and the
timing and frequency of the herbicide application.
The BLM is aware that herbicide resistance has the potential to develop within
populations of certain plant species that occur on BLM-administered lands. The BLM
has taken steps to prevent and address herbicide resistance. As part of the required
Integrated Pest Management and Pesticide Applicator Certification Training, the BLM
discusses the benefits of incorporating mechanical, manual, and biological control into
the overall herbicide resistance management strategy of a particular project. The BLM
provides training on the different mechanisms of activity of approved herbicide active
ingredients, and on the benefits of rotational use of herbicides with different
mechanisms of activity. In addition to this training, the BLM continues to monitor
herbicide application sites for herbicide resistant plant populations, and takes steps to
address herbicide resistance, as needed.
As stated in Chapter 1 of the PEIS, under Purpose and Need for the Proposed Action,
one reason that the BLM wishes to utilize the new active ingredients is to address
herbicide resistance by certain species to active ingredients currently approved for use.
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
6-11
January 2016
RESPONSE TO COMMENTS
14-01
Oregon Wild
Comment: Oregon Wild does not object to judicious use of herbicides to control high-
priority infestations of non-native weeds on public lands, but we do not want
widespread chemical use to be used to cover up the ecological damages caused by
weed-spreading activities such as livestock grazing, logging, mining, OHVs, fire-
suppression etc. Applying toxic chemicals containing under-tested active ingredients
and undisclosed and untested inert ingredients should be avoided as much as possible
and used only as a last resort. Executive Order 13112 of February 3, 1999 [Invasive
Species] requires BLM to focus first on prevention of the spread of invasive species
such as noxious weeds. BLM should therefore first focus on weed prevention, which
means: avoid and minimize the most common weed vectors, such as livestock and
OHVs; avoid and minimize soil disturbance caused by logging, road construction,
grazing, OHVs, fuel reduction, fire-suppression, firewood gathering, mining, etc.;
[and] avoid and minimize disturbance of healthy native vegetation cover caused by
logging, road construction, grazing, OHVs, fuel reduction, fire-suppression, firewood
gathering, mining, etc., including maintain forest canopy cover that helps suppress
weeds. BLM should prioritize conservation activities that help avoid the establishment
and spread of weeds thus minimizing the need for, and use of, chemical herbicides.
BLM must therefore minimize disturbance of soil and native vegetation caused by
livestock grazing, logging, yarding, log hauling, road work, OHVs, mining, etc.
Response: Executive Order 13112 requires the BLM to “prevent the introduction of
invasive species and provide for their control and to minimize the economic,
ecological, and human health impacts that invasive species cause.” Additionally, the
FLPMA of 1976 requires the BLM to manage public lands and their resource values to
support multiple uses, including the various examples listed in this comment.
Therefore, the BLM must allow for the land uses mentioned in the comment while at
the same time managing invasive plant species.
While the BLM agrees that the weed vectors identified in the comment contribute to
the spread of invasive plants on public lands, they are not the only weed vectors that
should be considered. The primary weed vectors are wind, water, wildlife, and self¬
propagation. Secondary factors are ground disturbance and fire. Human influences are
responsible for much of the spread and establishment of weeds we know today. Many
weeds have spread onto public lands from adjacent private lands without help from
livestock, OHV recreationists, or other commodity producers. Additionally, noxious
weeds and other invasive species are gaining a foothold in many protected special
areas such as wilderness study areas and wilderness areas that have little or no history
of livestock grazing, timber harvest, OHV use, or oil and gas exploration. Many intact
and healthy ecosystems have invasive and noxious weeds that cannot be attributed to
any specific cause or land use.
The BLM’s Weed Management and Invasive Species Program follows a strategy that
includes prevention, inventory, control, and rehabilitation. The BLM’s first line of
defense is prevention, followed by early detection and rapid response, both of which
are identified in the BLM’s Partners Against Weeds Action Plan (USDOI BLM 1996)
and Pulling Together: National Strategy for Invasive Plant Management (USDOI
BLM 1998). Steps that the BLM takes to prevent the establishment and spread of
invasive plants were discussed in the 2007 PEIS, which was incorporated by reference
into the current PEIS. Examples of prevention efforts include vehicle washing, animal
grooming and quarantine, use of weed-free hay and mulch, and public and user
education programs at field offices. Additionally, during planning and development of
projects with the potential to spread invasive plants, the BLM identifies steps to
minimize these risks.
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
6-12
January 2016
RESPONSE TO COMMENTS
28-01
Copper Country
Alliance
28-02
Copper Country
Alliance
The 2007 PEIS included the following SOP, which has been carried forward into the
-current PEIS: “Identify the most appropriate treatment method. If chemicals are the
appropriate treatment, then select the chemical that is the least damaging to the
environment while providing the desired results.” This SOP can be found in the
introductory section to Chapter 4 of the PEIS, under How the Effects of the
Alternatives Were Estimated, Assumptions for Analysis.
The PEIS does not evaluate policies and programs associated with land use activities
authorized by the BLM, including those listed in the comment, and does not make land
use allocations or amend land use plans. The BLM is making a decision on whether to
add aminopyralid, fluroxypyr, and rimsulfuron to the list of active ingredients
approved for use on public lands under an already established vegetation management
program. Regardless of the decision that is made on the use of these three active
ingredients, herbicides will continue to be used, along with other, non-chemical
treatment methods, to manage invasive vegetation on public lands.
Comment: Unless there is no effective non-herbicide alternative, herbicides should
not be employed. Herbicides should not be used simply because they are the cheapest
option.
Response: The decision about whether to utilize herbicide treatments or non-chemical
treatment methods is made at the local level after evaluating all of the options
available to treat the target species. Economic considerations are just one factor
considered when planning a vegetation treatment project. This process is discussed in
detail in the 2007 PEIS, and incorporated by reference and discussed briefly in the
current PEIS (in Chapter 2, under Herbicide Treatment Standard Operating Procedures
and Guidelines). As part of herbicide treatment planning, the BLM is required to
thoroughly evaluate the need for chemical treatments and their potential for impact on
the environment.
The 2007 PEIS included the following SOP, which has been carried forward into the
current PEIS: “Identify the most appropriate treatment method. If chemicals are the
appropriate treatment, then select the chemical that is the least damaging to the
environment while providing the desired results.” This SOP can be found in the
introductory section to Chapter 4 of the PEIS, under How the Effects of the
Alternatives Were Estimated, Assumptions for Analysis.
Comment: Unless the threat imposed by the invasive plant to natural ecosystems is
significant, herbicides should not be employed. Non-native dandelions, for instance,
have been in Alaska for a century. They are scattered among our native flowers and do
not seem to take over. Elodea, on the other hand, can quickly alter entire water bodies.
Response: The steps that the BLM follows when deciding whether to treat invasive
plants are described in detail in the 2007 PEIS, under Vegetation Treatment Planning
and Management, Site Selection and Treatment Priorities, and incorporated by
reference into the current PEIS. The BLM considers the threats to natural ecosystems
when determining whether a given population should be treated. The species and its
potential to spread aggressively and alter native plant communities are considered, as
well as its location and the size of the infestation, among other factors.
As discussed in Appendix C of the PEIS, in the AN1LCA Analysis of Subsistence
Impacts, it is expected that no more than 1,000 acres of public lands in Alaska would
be treated with herbicides in any year. Identified projects target invasive plants along
roads and other heavy use areas to prevent their spread into more pristine areas.
BLM Vegetation Treatments Using Herbicides
Final Programmatic E1S
6-13
January 2016
RESPONSE TO COMMENTS
28-03
Copper Country
Alliance
39-10
U.S. Environmental
Protection Agency
Comment: When herbicides are used, always use the ones with the least “collateral
damage” to non-targeted organisms, as long as they are still effective.
Response: During development of site-specific treatment plans, the BLM considers
the larger land management context in which the treatment will occur. This process
was discussed in the 2007 PEIS and PER, and would carry over to vegetation
treatment plans involving the three new active ingredients, should they be approved
for use in the ROD. The 2007 PEIS included the following SOP, which has been
carried forward into the current PEIS: “Identity the most appropriate treatment
method. If chemicals are the appropriate treatment, then select the chemical that is the
least damaging to the environment while providing the desired results.” This SOP can
be found in the introductory section to Chapter 4 of the current PEIS, under How the
Effects of the Alternatives Were Estimated, Assumptions for Analysis
Comment: The Draft PEIS outlines the process the BLM considers to determine the
suitability of the herbicide at that location, including herbicide and target site
characteristics. As a part of the site-suitability process, [US]EPA recommends that
BLM contact the USDA Natural Resources Conservation Service to determine
whether the application sites are highly erodible or the soil is prone to wind erosion
(light, sandy soils).
Response: As discussed in Chapter 1 of the document, the PEIS provides a broad,
programmatic level environmental impact analysis to which more specific
environmental documents can be tiered. The discussion on tiering in the PEIS, under
Study Area and Scope of Analysis, has been expanded to more clearly describe the
various levels of environmental analyses and the tiering process.
The soil characteristics of proposed treatment sites would be considered at the local
level during the NEPA process for site-specific herbicide treatments. Chapter 4 of the
PEIS, under Subsequent Analysis before Projects, discusses how local land managers
would utilize localized data and information to identify methods and procedures best
suited to local conditions. It is noted that the USDA Natural Resources Conservation
Service is a source of information regarding the soil aspects of a proposed site.
Alternatives, Herbicide Active Ingredients Evaluated Under the Proposed Alternatives
26-01
Rehfeldt, Melissa
36-01
Schumacher, Michelle
35-12
Alaska Community
Action on Toxics
Comment: Aminopyralid remains stable even after passing through an animal’s
digestive system. Deer, elk, or cows that graze where aminopyralid has been sprayed
will carry the still-active herbicide far and wide through their manure.
Response: The aminopyralid label contains specific restrictions associated with the
use of hay and straw from fields or other areas treated with this active ingredient. It
states that there are no grazing restrictions following its use, but does point out that the
urine and manure associated with grazing animals may contain enough aminopyralid
to cause injury to sensitive broadleaf plants for 3 days following grazing. It is hard to
determine the distance that wildlife would travel in the 3 days following a grazing
event of an area treated with aminopyralid, and whether urine and manure of these
animals would come in contact with a sensitive broadleaf plant species. However, the
PEIS does include a statement acknowledging the possibility of this type of impact to
non-target plants in Chapter 4, under Vegetation.
Comment: [USjEPA issued a conditional registration for aminopyralid in 2005 and it
is not scheduled for review until 2020. Aminopyralid should not be categorized by
BLM as a “reduced risk” herbicide because its evaluation is incomplete.
BLM Vegetation Treatments Using Herbicides
Final Programmatic EIS
6-14
January 2016
RESPONSE TO COMMENTS
26-04
Rehfeldt, Melissa
36-04
Schumacher, Michelle
35-19
Alaska Community
Action on Toxics
Response: The reduced risk designation is made by the USEPA, not the BLM. The
.term “reduced risk” refers to a registration program by the USEPA, which expedites
the review and regulatory decision-making of conventional pesticides that pose less
risk to human health and the environment than existing conventional alternatives.
More information on this program can be found at: http://www2.epa.gov/pesticide-
registration/conventional-reduced-risk-pesticide-program.
Aminopyralid met the requirements for inclusion into the reduced risk program. This
program expedites the review and regulatory decision-making process, but does not
alter the necessary testing requirements associated with preparing and submitting a
registration packet to the USEPA.
Regardless of the USEPA’ s reduced risk registration, the BLM still completed the
same level of risk analysis as it does for all herbicides proposed for use on public
lands. This risk analysis can be found in the ERA for aminopyralid.
Comment: Rimsulfuron is an acetolactate synthase-inhibitor, a type of herbicide that
kills plants by interfering with amino acid and DNA synthesis. Recent research
demonstrates that animals and people have very similar mechanisms of amino acid
synthesis, and may be affected by acetolactate synthase-inhibiting herbicides.
Response: A discussion of rimsulfuron’s acetolactate synthase-inhibiting mode of
action is provided in Chapter 2 of the PEIS, under Herbicide Active Ingredients
Evaluated under the Proposed Alternatives. Potential risks to wildlife and human
health are discussed in Chapter 4 of the PEIS, and are based on information from the
HHRAs and ERAs for rimsulfuron, both of which have been included as supporting
documents to the PEIS. As stated in the PEIS, rimsulfuron does not pose a risk to
wildlife or the public. It does pose a low to moderate human health risk to
occupational receptors (i.e., herbicide applicators) under accidental exposure scenarios
that are preventable through the use of proper herbicide handling and application
procedures and other SOPs. The comment does not provide a link or citation for the
research mentioned. However, the following is stated in the ERA for rimsulfuron:
“according to USEPA ecotoxicity classifications presented in registration materials,
rimsulfuron poses little to no acute toxicity hazard to terrestrial animals (mammals,
birds, and honeybees [Apis mellifera]', USEPA 2007). The rimsulfuron mode of action
is to inhibit acetolactate synthase (also known as acetohydroxyacid synthase), a key
enzyme in biosynthesis of certain amino acids in plants. As this enzyme only occurs in
plants, rimsulfuron has little toxic impact on mammals, birds, fish, or aquatic
invertebrates.” Rimsulfuron does not interfere with the biosynthesis of amino acids in
animals and people like it does in plants.
Comment: On August 1, 2006, the Attorney General of Alaska announced that
Alaska “joined with 13 other states and the U.S. Virgin Islands to petition the
Environmental Protection Agency ([US]EPA) to require pesticide manufacturers to
disclose on the label of their product all hazardous ingredients. The [USjEPA currently
requires that pesticide labels disclose only the product’s “active” ingredients that
contain toxic materials intended to kill insects, weeds, or other target organisms.
Pesticide products also contain many other “inert” ingredients, which are intended to
preserve or improve the effectiveness of the pesticides’ active ingredients. These
“inert” ingredients may be toxic themselves...” The news release further states that
“people who use or are impacted by use of a pesticide should have notice of all that
product’s potential health risks.” Thus, it would be wrong for BLM to apply herbicides
for which the manufacturers do not disclose ingredients that may harm human health.
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Response: In response to the referenced petitions to require pesticide manufacturers to
disclose all ingredients on their labels, the USEPA sought input from stakeholders
from the pesticide industry, environmentalists, and other experts on pesticide labeling
and “inert ingredients.” One of the recommendations from the stakeholder meetings
was to develop a rule to disclose the names of each of the “other inert ingredients” in
pesticide products. The recommendation would require the USEPA to initiate
rulemaking and amend 40 CFR 156.10(g) to disclose “other inert ingredients” and list
them on the pesticide label. On December 23, 2009, the USEPA announced its intent
to initiate rulemaking to this effect, but later decided not to pursue finalization of the
rulemaking. Until the USEPA issues a rule on “inert ingredients,” the BLM will
continue to follow the four-step risk assessment process identified by the National
Academy of Science (1983) when conducting HHRAs (hazard identification, dose-
response assessment, exposure assessment, and risk characterization). This process is
described in more detail in the HHRA.
Alternatives, Description of the Alternatives
35-25 Comment: We firmly oppose the use of these and other herbicides because of the
Alaska Community hazards posed to ecological and human health; and given that the BLM has failed to
Action on Toxics properly conduct alternatives assessment.
Response: The BLM evaluated both ecological and human health hazards in the
HHRA and ERAs as well as conducted an analysis of subsistence impacts pursuant to
Section 810 of the ANILCA (see Appendix C). The BLM provided additional analysis
in the chapter entitled Native American and Alaska Native Resource Uses.
The BLM disagrees that the alternatives assessment was not properly conducted.
Under the NEPA, federal agencies are required to consider a “reasonable range of
alternatives.” The PEIS is concerned only with the BLM’s use of the three herbicides
aminopyralid, fluroxypyr, and rimsulfuron, and the alternatives considered were
developed accordingly. The four alternatives considered in the PEIS are based on the
alternatives that were developed for the 2007 PEIS, which included a no aerial
spraying alternative, a no use of ALS-inhibiting active ingredients alternative, and a
“no action” alternative. Alternatives entailing use of non-chemical management
options are not applicable to the current PEIS. The BLM already uses herbicides as
well as non-chemical methods to manage vegetation on public lands. Regardless of the
decision made on whether to utilize the new herbicides, the BLM would continue to
utilize the 18 herbicides that have already been approved for use.
Alternatives, Alternative C - No Aerial Application of New Herbicides
14-05 Comment: We are opposed to aerial applications because it indicates (and essentially
Oregon Wild rewards) a large-scale failure of prevention efforts, and because aerial application is
non-discriminate. Too many non-target resources (including ecological [ly] important
native plants) will be impacted.
Response: Alternative C of the PEIS would prohibit aerial spraying of aminopyralid,
fluroxypyr, and rimsulfuron. However, aerial spraying of herbicides currently
approved for aerial applications could continue to occur, regardless of which
alternative is ultimately selected.
Decisions to treat large areas aerially are evaluated at a site-specific level and are
based on numerous factors (e.g., inaccessibility, treatment size, etc.). To ensure that
aerial applications are as precise as possible, the BLM uses Global Positioning System
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RESPONSE TO COMMENTS
(GPS) mapping tools to assist aerial applicators. The 2007 PEIS also included SOPs
for aerial spraying, which have been carried forward into the current PEIS. They
include measures such as avoiding aerial spraying during periods of adverse weather
conditions, and making helicopter applications at the appropriate speed and height
above the ground. At the local level, the BLM would consider the potential for adverse
effects to non-target resources when developing treatment projects.
34-03 Comment: Additionally, the [Draft PEIS] indicates that aerial spraying may be
Coast Range employed in the application of the chemical[s] in question. We oppose any aerial
Association spraying because studies have shown unacceptable drift occurs using the Best
Management Practices.
Response: An alternative that would prohibit aerial spraying of the three new active
ingredients is being considered in the PEIS (Alternative C). However, aerial spraying
of currently approved herbicides would continue to occur regardless of which
alternative is ultimately selected.
To ensure that aerial applications are as precise as possible, the BLM uses GPS
mapping tools to assist aerial applicators and avoid off-site drift. The 2007 PEIS also
included SOPs for aerial spraying, which have been carried forward into the current
PEIS. They include measures such as avoiding aerial spraying during periods of
adverse weather conditions, and making helicopter applications at the appropriate
speed and height above the ground. At the local level, the BLM would take the
potential for drift and adverse effects to non-target resources into account when
developing treatment projects. Chapter 4 of the PEIS identifies buffers zones to
minimize impacts to non-target vegetation as a result of herbicide drift during aerial
applications. More specific buffers would be developed at the local level based on site
conditions and other factors.
Alternatives, Alternatives Considered but not Further Analyzed
Comment: Unfortunately, a ‘no use of herbicides’ alternative is not being considered
as an option in the current process. Unfortunately, this means that the BLM is missing
out on adopting land management strategies that lead to more diverse and productive
ecosystems that are less prone to invasion.
Response: A ‘no use of herbicides’ alternative is not being considered in the PEIS
because it does not meet the stated project purpose, which is to “improve the
effectiveness of the BLM's vegetation management program by allowing herbicide
treatments with aminopyralid, fluroxypyr, and rimsulfuron.” A no use of herbicides
alternative was included in the 2007 PEIS. In the ROD for the 2007 PEIS, the BLM
made the decision to allow herbicide treatments with 18 active ingredients. Regardless
of the decision made in the ROD for the current PEIS, herbicides would still be used
by the BLM to treat invasive plants on public lands. The current action only concerns
the active ingredients aminopyralid, fluroxypyr, and rimsulfuron.
Alternatives, Herbicide Treatments Standard Operating Procedures and Guidelines
28-07 Comment: Land and water in and around the application area should be checked for
Copper Country “collateral damage” to non-targeted organisms.
Alliance
Response: As discussed in Chapter 1 of the document, the PEIS provides a broad,
programmatic level environmental impact analysis to which more specific
environmental documents can be tiered. The discussion on tiering in the PEIS, under
26-09
Rehfeldt, Melissa
36-09
Schumacher, Michelle
HI M Vegetation Treatments Using Herbicides
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RESPONSE TO COMMENTS
39-09
U.S. Environmental
Protection Agency
39-07
U.S. Environmental
Protection Agency
Study Area and Scope of Analysis, has been expanded to more clearly describe the
various levels of environmental analyses and the tiering process. At the site-specific
level, local land managers would be aware of non-target organisms of concern and
would design herbicide treatment projects to prevent unintended impacts to these
organisms. Suitable treatment buffers would be refined at the local level based on site
conditions and other factors.
The BLM has a series of SOPs in place that provide additional guidance for avoiding
unintended impacts to non-target organisms. These SOPs can be found throughout
Chapter 4 of the PEIS, in the individual resource sections. Additionally, as stated
under Assumptions for Analysis, the BLM would consider the larger land-
management context when implementing herbicide treatments. These considerations
would carry over once treatments are completed, as the BLM would consider the site
conditions following the herbicide application and would implement post-treatment
follow up, including seeding, monitoring, and retreatment, as needed to achieve land
management objectives. Post-treatment follow up would include an assessment of the
treatment site and nearby areas.
Comment: Additionally, [USjEPA recommends that BLM commit to using [USjEPA
certified Drift Reduction Technology as it becomes available.
Response: The BLM appreciates the recommendation and looks forward to seeing the
program in action when it is implemented. The USEPA’s web page discussing drift
reduction technology states that drift-reduction ratings and information about the use
of drift reduction technology will appear on pesticide labels. The BLM will continue
to follow the instructions on herbicide labels for all herbicide applications.
Comment: Many invasive plants on public lands are associated with roads, trails,
paths, and other areas where the soil has been disturbed and/or compacted resulting in
enhanced runoff and unanticipated significant impacts. Therefore the final PEIS
should highlight a process to assess those areas when specific actions will be taken.
Response: The BLM agrees that invasive plants are often associated with areas of
disturbance. Roads, trails, paths, and others areas serve as pathways for introducing
and spreading weeds and other invasive plants.
As discussed in Chapter 1 of the document, the PEIS provides a broad, programmatic
level environmental impact analysis to which more specific environmental documents
can be tiered. The concerns raised in the comment would be addressed at the local
level during the planning phase and subsequent environmental analyses for site-
specific vegetation treatments. Local land managers would consider site conditions,
including the potential for surface runoff, when developing herbicide treatments.
Additionally, local land managers would follow all applicable SOPs for minimizing
impacts to water resources, which are listed in Chapter 4 of the PEIS under Water
Resources and Quality, Standard Operating Procedures. Additional measures to
protect water resources would be identified at the site-specific environmental analysis
level, as required by the NEPA.
Alternatives, Coordination and Education
28-06
Copper Country
Alliance
Comment: Signs should go up around the herbicide application area (including the
drift zone) prior to, during, and after application. Signs should remain in the area for at
least a year. This is especially true in Alaska, where herbicides break down more
slowly than in wanner states.
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RESPONSE TO COMMENTS
Response: Standard operating procedures pertaining to posting treated areas are listed
in Chapter 4 of the PEIS, under Human Health and Safety, Standard Operating
Procedures. The BLM would post treated areas with appropriate signs at common
public access areas, as well as provide public notification in newspapers or other media
where the potential exists for public exposure. The BLM would consult the restricted
entry intervals on the herbicide label to determine the appropriate length of time that
signs marking treated areas should remain posted. The BLM would also notify local
emergency personnel of proposed treatments. Any additional site-specific issues would
be addressed during the local level analysis.
14-04 Comment: BLM should provide reasonable and timely public notification before
Oregon Wild applying herbicides.
Response: Standard operating procedures pertaining to public notification prior to
herbicide treatments are listed in Chapter 4 of the PEIS, under Human Health and
Safety, Standard Operating Procedures. The BLM would provide public notification in
newspapers or other media where the potential exists for public exposure. The BLM
would consult the restricted entry intervals on the herbicide label to determine the
appropriate length of time that signs marking treated areas should remain posted. The
BLM would also notify local emergency personnel of proposed treatments.
Alternatives, Mitigation
Comment: Aminopyralid has been known to be persistent in composted materials.
Therefore, [US]EPA recommends the final PEIS commit to ensure that following the
application of aminopyralid to an area, BLM should conduct site assessment and
ensure that plant materials are not removed and introduced into any composting
activities.
Response: As stated in Chapter 4 of the PEIS, under Social and Economic Values,
Summary of Herbicide Impacts, the BLM would follow all label instructions, and
would not export manure, plant residues, or other materials that may be treated with
aminopyralid for use as soil amendments. The concerns raised in the comment would
be addressed further at the local level during project planning and site-specific NEPA
analysis. The BLM would not design vegetation treatment projects that entail removal
of plant materials from a treatment site, and could include specific mitigation measures
to address these concerns, if warranted.
Affected Environment, Air Quality and Climate
39-20 Comment: While the Chapter 3 Greenhouse Gas Emissions and Climate Change
U.S. Environmental section notes that “regulatory agencies recognize that GHG emissions from a particular
Protection Agency project cannot be tied specifically to climate change impacts,” we recommend
agencies follow the approach recommended in the CEQ guidance of using the
projected GHG emissions as a proxy for assessing a proposed action's potential climate
change impacts. This allows an agency to present the environmental impacts in clear
terms with sufficient information to make a reasoned choice between the no-action an
alternatives and mitigation.
Response: The text of the PEIS has been changed to reflect the revised CEQ guidance
referenced in the comment ( Revised Draft Guidance on the Consideration of
Greenhouse Gas Emissions and the Effects of Climate Change in NEPA Reviews', CEQ
2014). The statement that GHG emissions cannot be tied specifically to climate change
39-12
U.S. Environmental
Protection Agency
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RESPONSE TO COMMENTS
impacts has been modified to state that projected GHG emissions can be used as a
proxy for assessing a proposed action’s potential climate change impacts.
Environmental Consequences, General
Comment: Herbicide applications are designed to destroy the growth of plant life and
are toxic to the environment because they adversely affect non-target plants, animals,
and people. The use of herbicides, including aminopyralid, fluroxypyr, and
rimsulfuron, will have detrimental effects to non-target plants, wildlife and people.
Herbicide chemical treatments will have a detrimental effect on the lands, waters, and
air as well as fish and wildlife resources that people rely on for hunting, fishing, and
gathering for their daily food.
Response: The potential for aminopyralid, fluroxypyr, and rimsulfuron to adversely
affect non-target plants, animals, and people is discussed in Chapter 4 of the PEIS
(Environmental Consequences). Appendix C of the PEIS is an ANILCA Section 810
Analysis of Subsistence Impacts, which provides an evaluation of the proposed project
on subsistence resource in Alaska. The BLM does not agree that use of these three
active ingredients would have detrimental effects to non-target plants, wildlife, or
people, or on the lands, waters, air, or fish and wildlife resources that people rely on
for hunting, fishing, and gathering their daily food. As disclosed in the PEIS,
aminopyralid, fluroxypyr, and rimsulfuron are non-toxic or of low toxicity to humans,
wildlife, and the environment. The BLM would design its herbicide treatment projects
to avoid impacts to non-target vegetation and other resources, and would develop
appropriate buffers for protecting these resources. The intent of vegetation treatments
would be to reduce the risk of wildfire and the spread of weeds and improve ecosystem
health, but these actions would not be done at the expense of resources that people rely
on for hunting, fishing, and gathering. During local-level NEPA analyses for site-
specific projects, the BLM would consult with Native American tribes, Alaska Native
groups, and Alaska Native Corporations and would take into account and address their
concerns.
Comment: Herbicide applications are likely to result in higher economic and
ecological costs over the long term, as plants develop resistance to herbicide
applications. Despite earlier claims that glyphosate resistance was unlikely, at least 19
weed species have developed glyphosate-resistant strains in agricultural areas
worldwide. Field studies in Washington state showed that star thistle repeatedly treated
with picloram developed resistance to not only to the herbicide actually used,
picloram, but to other herbicides (including clopyralid) with the same mode of action.
The use of herbicides will perpetuate resistance of the vegetation to treatment and will
not be effective in vegetation management in the future. Herbicide-resistant weeds
may also spread into areas beyond the application sites, thereby increasing the problem
and cost of weed control.
Response: The development of herbicide resistance is an issue of great interest in
production agriculture. Several plant species have been documented as being
resistance to particular herbicide active ingredients. Several factors contribute to the
development of an herbicide-resistant population of a plant species, including the
characteristics of the active ingredient, the genetic makeup of the plant species, and the
timing and frequency of the herbicide application.
The BLM is aware that herbicide resistance has the potential to develop within
populations of certain plant species that occur on BLM-administered lands. The BLM
has taken steps to prevent and address herbicide resistance. As part of the required
35-17
Alaska Community
Action on Toxics
35-01
Alaska Community
Action on Toxics
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Integrated Pest Management and Pesticide Applicator Certification Training, the BLM
discusses the benefits of incorporating mechanical, manual, and biological control into
the overall herbicide resistance management strategy of a particular project. The BLM
provides training on the different mechanisms of activity of approved herbicide active
ingredients, and on the benefits of rotational use of herbicides with different
mechanisms of activity. In addition to this training, the BLM continues to monitor
herbicide application sites for herbicide resistant plant populations, and takes steps to
address herbicide resistance, as needed.
As stated in Chapter 1 of the PEIS, under Purpose and Need for the Proposed Action,
one reason that the BLM wishes to utilize the new active ingredients is to address
herbicide resistance by certain species to active ingredients currently approved for use.
Environmental Consequences, Herbicide Effects Analysis
12-02
Eller, Barb
14-02
Oregon Wild
26-05
Rehfeldt, Melissa
36-05
Schumacher, Michelle
Comment: There is no data on the long-term human and ecology effects of mixtures
of multiple herbicides.
Response: Quantifying the potential long-term impacts associated with the use of
mixtures of herbicide active is not practical, given the different variables associated the
herbicide tank mixtures, differences in the concentration of the individual active
ingredients, environmental characteristics of the site of application, variability in the
post application environmental conditions, and many other individual factors that
influence the behavior, over time, of herbicide tank mixes.
The registration of herbicides is the responsibility of the USEPA. The BLM, like all
government agencies, relies on processes established by the USEPA, including
stringent and comprehensive standards for conducting human health and ecological
risk assessments. The USEPA does not currently require a quantitative evaluation of
potential tank mixes when conducting ERAs. However, the risk assessments did
address the uncertainties associated with herbicide mixtures, and the BLM would
consider the potential for additive or synergistic effects when selecting and using
herbicide mixtures.
Comment: BLM should disclose all ingredients (including so-called inert ingredients)
included in the herbicides it intends to use and BLM should disclose the health and
environmental effects of all those ingredients singly and in combination.
Response: A discussion of “inert” or “other” ingredients is provided in the human
health and ecological risk assessments. Unlike the active ingredient, federal law does
not require that the “other” ingredients be identified by name or percentage on the
label, as it is considered confidential business information; they are only listed as a
total percentage of the formulation.
The BLM requires that inert/other ingredients found in herbicide formulations be listed
in the InertFinder database, which is maintained by the USEPA and includes all
chemicals approved for use as inert ingredients in pesticide products.
Comment: [Although] the BLM is requesting the addition of three new herbicide
active ingredients, the herbicide formulations they purchase and use could contain a
number of active ingredients (such as PastureGard that contains fluroxypyr and
triclopyr). These herbicide formulations are not subject to toxicity testing, and their
potential synergistic effects are unknown.
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RESPONSE TO COMMENTS
26-06
Rehfeldt, Melissa
36-06
Schumacher, Michelle
28-08
Copper Country
Alliance
Response: The BLM is in agreement that herbicide mixtures are a source of
uncertainty in the risk assessment process, and is aware that the USEPA is discussing
possible methods of addressing risks to plants and animals from the use of mixtures as
part of the pesticide active ingredient registration process. Presently, however, there
are no guidelines/directives for evaluating such potential risks.
Section 133.2 of the ERAs prepared for aminopyralid, fluroxypyr, and aminopyralid
discusses mixtures and acknowledges that a quantitative evaluation of the potential
risks associated with mixtures is outside the scope of the risk assessments. To address
each possible combination of a tank mix involving two or more active ingredients
under several different application rates and scenarios would not be practical. It should
be noted that only herbicide active ingredients for which the BLM has completed risk
assessments would be used in mixtures with the three new active ingredients.
Therefore, although herbicide mixtures have not had individual risk assessments
completed, their individual components have. BLM land managers would continue to
thoroughly review labels for tank-mixed products, and would select mixtures with the
least potential for negative effects.
Comment: In addition, most herbicide formulations contain undisclosed, untested, and
unregulated surfactants and adjuvants that are not subject to regulatory scrutiny,
making it impossible to know the full effects of applying these chemicals on public
lands.
Response: The BLM is in agreement that adjuvants represent a source of uncertainty
in the risk assessment process. Adjuvant is a broad term that includes surfactants,
selected oils, anti-foaming agents, buffering compounds, drift control agents,
compatibility agents, stickers, and spreaders. Adjuvants are not under the same
registration guidelines as pesticides, and the USEPA does not register or approve the
labeling of spray adjuvants. Individual herbicide labels identify which types of
adjuvants are approved for use with the particular herbicide.
Adjuvants are discussed in Section 7.3.3. 1 of the ERAs for aminopyralid, fluroxypyr,
and rimsulfuron. The risk assessments identify what types of adjuvants have been
identified for use in formulations of the proposed active ingredients, and provide a
general analysis of their likely toxicity. Additionally, modeling was used to estimate
the potential portion of an adjuvant that might reach an adjacent water body via surface
runoff.
Comment: In many instances, “inert ingredients” are not inert at all, but have
significant impacts on organisms.
Response: The BLM acknowledges that the application of a pesticide may include the
application of one or more active ingredients, along with the associated “inert” or
“other” ingredients. These other ingredients are included in the pesticide formulation
for the purpose of, among other things, improving the active ingredient’s ability to
move through the plant surface, improving the stability of the formulation, and
reducing the degradation of the active ingredient.
A discussion of “inert” or “other” ingredients is provided in the human health and
ecological risk assessments. Unlike the active ingredient, federal law does not require
that the inert/other ingredients be identified by name or percentage on the label, as it is
considered confidential business information; they are only listed as a total percentage
of the formulation.
BLM Vegetation Treatments Using Herbicides
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RESPONSE TO COMMENTS
34-04
Coast Range
Association
35-06
Alaska Community
Action on Toxics
35-15
Alaska Community
Action on Toxics
The BLM requires that inert/other ingredients found in herbicide formulations be listed
in the InertFinder database, which is maintained by the USEPA and includes all
chemicals approved for use as inert ingredients in pesticide products.
Comment: We ask whether the BLM has assessed the non-monotonic effects of the
chemicals aminopyralid, fluroxypyr, and rimsulfuron. Are these chemicals hormone
mimicking compounds?
Response: Non-monotonic effects have not been evaluated, as the required testing for
pesticide registration does not include non-monotonic effects. That said, many of the
studies used in development of the toxicity endpoints selected by the USEPA
(described in Section 2.2 of the HHRA) do include testing both low and high doses.
As discussed in Section 2.2.1.10 of the HHRA, the USEPA is in the process of
screening chemicals under the Endocrine Disruptor Screening Program.
Aminopyralid, fluroxypyr, and rimsulfuron were not selected for screening in the first
batch of chemicals, suggesting low potential for endocrine disruption. The BLM
conducts periodic reviews of the active ingredients utilized in herbicide treatment
programs, and risk assessments are updated periodically. If any new information about
the potential for these active ingredients to cause endocrine disrupting effects becomes
available in the future, the BLM will review the information and evaluate whether
changes in the way the herbicides are used on public lands is warranted.
Comment: There is very little information or studies available in the open scientific
and peer-reviewed literature on the ecological and human health consequences of the
use of aminopyralid because it is a relatively new pesticide. What little information
exists is based almost exclusively on studies submitted to the [USEPA] by the
chemical corporation Dow AgroSciences in support of the registration of
aminopyralid.
Response: The registration of herbicides is the responsibility of the USEPA. The
BLM, like all government agencies, relies on pesticide toxicological studies required
and reviewed by the USEPA. The USEPA has stringent and comprehensive standards
for these studies. See http://www2.epa.gov/pesticide-registration/data-requirements.
USEPA scientists review and approve (or reject) the study results. Based on this
process, the USEPA has made the determination that the studies submitted in support
of the registration of aminopyralid were adequate.
In order to determine the potential toxicological risks associated with aminopyralid,
the BLM conducted human health and ecological risk assessments in support of the
PEIS. These risk assessments incorporated toxicity data from numerous studies
involving the active ingredient. In the ERA, these studies are listed in Appendix A.l.
In the HHRA, much of the toxicity information was obtained from risk assessments
prepared by the USEPA Office of Pesticide Programs Health Effects Division, as
discussed in Section 2.2 of the document.
Comment: For the other two herbicides, fluroxypyr and rimsulfuron, we find that
there is also insufficient information in the peer-reviewed literature with which to
make reasoned assessments concerning the ecological and human health implications
of their use. Therefore, we are opposed to their use as a precautionary measure.
Response: The required testing and studies on fluroxypyr and rimsulfuron have been
conducted in accordance with USEPA guidelines and with pesticide registration
requirements.
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35-20
Alaska Community
Action on Toxics
Section 2.2.4 of the HHRA outlines the studies for fluroxypyr used in support of
registration and development of dose-response values. Available studies included oral
and dermal subchronic toxicity, developmental toxicity, reproductive toxicity, chronic
toxicity, carcinogenesis, and mutagenicity. Test animals included mice, rats, rabbits,
and dogs.
Section 2.2.5 of the HHRA outlines the studies for rimsulfuron used in support of
registration and development of dose-response values. Available studies included oral
subchronic toxicity, developmental toxicity, reproductive toxicity, chronic toxicity,
carcinogenesis, and mutagenicity. Test animals included mice, rats, and dogs.
The dose-response values used in the HHRA are those developed by the USEPA in
support of pesticide registration, as presented in Table 3-1 of the HHRA. The results of
the risk assessment show that fluroxypyr and rimsulfuron do not pose unacceptable
risks under any of the routine use occupational or public exposure scenarios evaluated;
however, rimsulfuron poses potentially unacceptable risks to occupational receptors
under an accidental spill to skin scenario. These potential risks would be mitigated
through the use of personal protective equipment and by following all label
requirements.
Available ecotoxicological literature reviewed for fluroxypyr included studies
conducted as part of the USEPA pesticide registration process, the comprehensive risk
assessment published by the Forest Service in June 2009 (SERA 2009), and more
recent studies (after 2009) available from the USEPA’s Pesticide Ecotoxicity
Database, as described in Section 3.1 of the fluroxypyr ERA. Similarly, for
rimsulfuron, available ecotoxicological literature was reviewed from the USEPA
pesticides ecotoxicology database and the online ECOTOX database
(http://cfpub.epa.gov/ecotox/).
Ecotoxicological endpoints for the studies evaluated included growth, reproduction,
and mortality, as well as sublethal endpoints such as immobilization. Test species
included small mammals (e.g., rats, mice, and rabbits), birds (e.g., ducks and quail),
honeybees, vegetable crop species, coldwater and wannwater fish species, and aquatic
plants and invertebrates. Toxicity reference values were calculated based on exposure
concentrations for terrestrial plants and aquatic receptors and on acute dose-based
endpoints when possible, or on concentration-based endpoints using USEPA risk
assessment guidelines (Sample et al. 1996) for birds and wildlife. Toxicity reference
values were also based on the most sensitive available endpoint, which is a
conservative approach due to the wide range of data and effects available for different
species.
The uncertainties related to the available toxicity data are addressed in Section 7.1 of
both the rimsulfuron and fluroxypyr ERAs. It is noted in Section 7.5 that the
combination of many conservative assumptions used in the ERAs (e.g., the use of
safety factors, chronic exposures, laboratory toxicity tests, and continuous exposure to
predicted ecological exposures) is likely to over-predict, rather than under-predict,
risks for ecological receptors overall.
Comment: Pesticides have interactive effects and ultra low-level effects that are
below [USJEPA allowable levels. These effects include adverse neurological,
endocrine, immune, reproductive and developmental health outcomes.
Response: As outlined in Section 2.2 of the HHRA, the studies used to develop the
dose-response values included a range of doses in a variety of species, and cover the
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RESPONSE TO COMMENTS
35-21
Alaska Community
Action on Toxics
35-22
Alaska Community
Action on Toxics
35-23
Alaska Community
Action on Toxics
35-24
Alaska Community
Action on Toxics
health outcomes noted in the comment. Current pesticide registration requirements do
not include studies of interactive effects.
Comment: [US]EPA assessments of biological risk can be off by a factor of 10,000 at
ultra low doses. Scientists call for a new type of risk assessment in the open literature
because of the inadequacies of the current [US]EPA pesticide registration systems.
Response: Risk assessment methodologies are always evolving. The risk assessments
conducted in support of the PEIS followed existing regulations and guidelines. It is
beyond the scope of the PEIS to evaluate methods presented in the open literature that
have not been endorsed by the USEPA.
Comment: Pesticides have broad biological effects that are unintended and often
unpredictable because of physiochemical properties engineered into their molecules.
Response: The comment has been noted. The ERAs follow the most recent USEPA-
approved methodology for determining the potential toxicological effects of
aminopyralid, fluroxypyr, and rimsulfuron.
Comment: Pesticides of different classes can have similar impacts on endocrine
disruption and sexual development. Chemicals affect development at levels in the tenth
of a part per billion range.
Response: As discussed in Section 2.2.1.10 of the HHRA, the USEPA is in the
process of screening chemicals under the Endocrine Disruptor Screening Program.
Aminopyralid, fluroxypyr, and rimsulfuron were not selected for screening in the first
batch of chemicals, suggesting low potential for endocrine disruption. The BLM
conducts periodic reviews of the active ingredients utilized in herbicide treatment
programs. If any new information about the potential for these active ingredients to
cause endocrine disrupting effects becomes available in the future, the BLM will
review the information and evaluate whether changes in the way the herbicides are
used on public lands is warranted.
Comment: In the preeminent peer-reviewed environmental health journal published
by the National Institute for Environmental Health Sciences, Environmental Health
Perspectives , the authors warn: “Inert ingredients may be biologically or chemically
active and are labeled inert only because of their function in the formulated
product... Inert ingredients can increase the ability of pesticide formulations to affect
significant toxicological endpoints, including developmental neurotoxicity,
genotoxicity, and disruption of hormone function. They can also increase exposure by
increasing dermal absorption, decreasing the efficacy of protective clothing, and
increasing environmental mobility and persistence. Inert ingredients can increase the
phytotoxicity of pesticide formulations, as well as toxicity to fish, amphibians, and
microorganisms.” In the case of this permit application, the active ingredients cannot
be used without an adjuvant and/or surfactant. The scientific literature supports the fact
that the use of surfactants/adjuvants increases the bioavailability, toxicity, persistence,
and bioaccumulation of the active ingredient.
Response: In reviewing the article cited in the comment, the conclusions of the
authors appear to be centered on expanding the registration process utilized by the
USEPA. The BLM, like all pesticide users, relies on the process established by the
USEPA to address human health and environmental risks associated with the use of
pesticides. For pesticide formulations the USEPA states that all ingredients, “including
those in an inert mixture, must be approved for use by the USEPA.” As the pesticide
BLM Vegetation Treatments Using Herbicides
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6-25
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RESPONSE TO COMMENTS
registration policy evolves and changes, so will the evaluation associated with the use
of pesticides on public lands.
The USEPA’s Pesticide Registration Manual states that “...the registering division
will treat the adjuvant as if it were an ‘other ingredient’ in making the registration
decision, and will assure that any necessary tolerances or exemptions from the
requirement of a tolerance are established. It would also be within the Agency’s
authority to treat any tank-mixed substance as part of the pesticide (and thus needing a
Federal Food, Drug, and Cosmetic Act tolerance) in that it meets the Federal
Insecticide, Fungicide, and Rodenticide Act definition of pesticide — i.e., a ‘mixture’ of
substances intended to kill a pest.”
For adjuvants, the ERAs for aminopyralid, fluroxypyr, and rimsulfuron include
sections that discuss the potential toxicological impacts associated with the addition of
an adjuvant (Section 7.3.3. 1). The BLM also requires that the ingredients included in
the adjuvant are found within the same USEPA database that is used for inert/other
ingredients (the InertFinder database).
Environmental Consequences, Air Quality
39-19
U.S. Environmental
Protection Agency
39-21
U.S. Environmental
Protection Agency
Comment: We appreciate the discussion of climate change and the inclusion of GHG
emissions associated with the proposed action and alternatives. While the Draft PEIS
acknowledges the 2010 [CEQ] draft guidance on analyzing climate change impacts in
NEPA, we believe the most recent CEQ Revised Draft Guidance for Federal Agencies'
Consideration of GHG Emissions and Climate Change (2014) provides a reasonable
approach for conducting analysis of GHGs and climate change impacts. We note that
the Draft PEIS compares the GHG emissions to the 17 states and national emissions;
we believe this approach does not provide meaningful information for a programmatic-
level analysis. We recommend that the NEPA analysis provide a frame of reference,
such as an applicable Federal, state, tribal, or local goal for GHG emission reductions,
and discuss whether the emission levels are consistent with such goals.
Response: The text of the PEIS has been changed to reflect the recent revised CEQ
guidance cited in the comment. The effects analysis has been revised to consider the
net emissions that are likely to occur with and without the proposed action. A
discussion of the contribution of wildfires to GHG emissions has been added under the
Greenhouse Gas Analysis subsection of the Chapter 4 Air Quality and Climate
discussion. Wildfires are a biogenic source of GHG emissions that can be exacerbated
by certain invasive plants (e.g., cheatgrass and other annual grasses). In the case of the
proposed herbicide treatments, the reduction in wildfire risk from successful
vegetation management would be expected to have long-term beneficial effects over
many years. Use of the three new herbicides would allow the BLM additional options
for managing invasive species that contribute to wildfire, such as cheatgrass. Reducing
wildfires is identified in the President’s Climate Action Plan (Executive Office of the
President 2013) as a specific effort to protect natural resources.
Comment: Lastly, the Draft PEIS states that no mitigation measures would be
necessary for potential air quality and climate change impacts. We recommend the
final PEIS identify and commit to implementation of reasonable mitigation measures
to include at the project level to specifically reduce GHG emissions such as using
energy efficient equipment and limiting idling when possible.
Response: The BLM agrees that measures to reduce GHG emissions should be
considered at the project level. The Standard Operating Procedures Section of Chapter
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RESPONSE TO COMMENTS
4, Air Quality and Climate, has been changed to include a discussion of BMPs to
reduce GHG emissions, which would be considered at the local level.
Environmental Consequences, Soil Resources
35-14
Alaska Community
Action on Toxics
Comment: It is likely that aminopyralid is more persistent in our colder environment
[in Alaska] and may cause more damage to northern species and ecosystems.
Response: The residual activity of an herbicide is influenced by several factors,
including those associated with the herbicide, the environmental conditions of the
proposed site of application, and the physical and biological make-up of the soil.
Temperature, soil moisture, aeration, soil pH, and organic matter content all influence
the microbial population in the soil. During the site-specific analysis of a proposed
application of aminopyralid, the active ingredient’s residual potential would be
considered and addressed. The BLM would consider actions to reduce the residual life
of aminopyralid, as necessary, such as the following: 1) applying the lowest amount of
the herbicide consistent with achieving the desired result; 2) considering application of
a tank mixture to reduce the amount of aminopyralid applied while still achieving the
desired result; 3) making applications when the air temperature is at its warmest, when
the target plants are most susceptible; and 4) making spot treatment applications rather
than broadcast applications.
Environmental Consequences, Water Resources and Quality
12-01
Eller, Barb
Comment: Herbicides and their degradates are now commonly found in ground and
surface waters.
Response: The potential for aminopyralid, fluroxypyr, and rimsulfuron and their
degradates to be transported to surface water, and to infiltrate into and persist in
groundwater, is discussed in Chapter 4 of the PEIS, under Water Resources and
Quality. Studies by the USGS have shown that herbicides or their degradation products
do not commonly occur in shallow groundwater except in areas of agricultural land
use. The movement of any herbicide in groundwater is affected by many factors such
as thickness of the unsaturated zone, the amount of clay in the soil matrix, the depth to
the zone of saturation and the hydraulic gradient of the local groundwater flow system.
Herbicides or their degradation products rarely occur in bedrock aquifers. These
factors will be evaluated during the site-specific project level environmental analysis
as required by the NEPA.
26-02
Rehfeldt, Melissa
36-02
Schumacher, Michelle
Comment: Aminopyralid also has a high potential for surface water runoff because of
its chemical structure.
Response: The BLM agrees with this statement. A discussion of aminopyralid’s high
potential for surface water runoff can be found in Chapter 4, under Water Resources
and Quality. Aminopyralid is moderately persistent and highly mobile, and does not
adsorb well to soil particles. For these reasons, it has a high potential for surface water
runoff. However, given its low toxicity, surface water runoff of aminopyralid is not a
concern. Its major metabolic products following photolysis in water are oxamic acid
and malonamic acid, neither of which is of concern from a toxicity standpoint. Based
on its low toxicity, aminopyralid is likely to receive an aquatic registration in the near
future that would allow incidental overspray of aquatic habitats. The ERA for
aminopyralid determined that this active ingredient would not pose a risk to fish or
invertebrates in ponds or streams as a result of any of the modeled exposure scenarios,
including a spill of a large quantity of the active ingredient directly into a water body.
BLM Vegetation Treatments Using Herbicides 6-27 January 2016
Final Programmatic EIS
RESPONSE TO COMMENTS
39-02
U.S. Environmental
Protection Agency
39-04
U.S. Environmental
Protection Agency
39-05
U.S. Environmental
Protection Agency
Comment: As a result of a U.S. Sixth Circuit Court of Appeals decision in National
Cotton Council et al. v. EPA , as of October 31, 2011, point source discharges of
biological pesticides that leave a residue, into waters of the U.S. are required to comply
with [NPDES] requirements. Therefore, NPDES permits are required for pesticide
applications directly to, over, or near water and may be required for certain instances
on public lands. The final PEIS should include a discussion of the new permitting
requirements and outline a framework for obtaining a NPDES permit for project-
specific treatments to ensure that site-specific impacts and mitigation are considered.
Response: Although none of the proposed active ingredients have an aquatic label,
there could be applications over or near water, particularly for aminopyralid. BLM
field personnel would address NPDES requirements at the site-specific level. The
PEIS has been modified to include a brief discussion of NPDES permit requirements
in Chapter 4, under Water Resources and Quality.
Comment: The final PEIS should clarity plans for treatment of invasive plants within
buffer zones and anticipate measures to take to protect water quality within nearby
waterways; including specific mitigation measures for wetlands and riparian areas to
offset potential impacts associated with the three proposed herbicides.
Response: The concerns raised in the comment would be addressed at the site-specific
level for proposed projects that require treatment of invasive plants within the BLM’s
standard buffer zones for wetland and riparian areas (100 feet for aerial spraying, 25
feet for ground applications, and 10 feet for hand applications). As discussed in
Chapter 1 of the document, the PEIS provides a broad, programmatic level
environmental impact analysis to which more specific environmental documents can
be tiered. The discussion on tiering in the PEIS, under Study Area and Scope of
Analysis, has been expanded to more clearly describe the various levels of
environmental analyses and the tiering process. During the site-specific analysis, the
BLM would consider potential effects to water quality from proposed herbicide
treatments with aminopyralid, fluroxypyr, and rimsulfuron, and determine whether
specific mitigation measures are warranted.
Comment: In areas where there are soils with high infiltration rates, herbicides that
are highly soluble in water have the potential to leach into soils and contaminate
surface and groundwater, potentially causing exceedances of water quality and/or
drinking water standards. In addition, no water quality standards exist for herbicides
such as the proposed aminopyralid, which has the highest mobility, with some
modeling data suggesting that leaching can occur to 60 inches or greater in all soil
types in average rainfall/cool climates and a higher likelihood of reaching groundwater
than all other herbicides. Therefore, [USjEPA recommends that future site-specific
NEPA analyses include risk assessment data for adjuvants proposed for use with the
three proposed herbicides on BLM land.
Response: A discussion of the physical properties of aminopyralid, fluroxypyr, and
rimsulfuron and their potential for off-site movement is provided in Chapter 4 of the
PEIS, with this information summarized in Table 4-5. The potential for these three
active ingredients to leach into soils and contaminate surface water and groundwater is
discussed under Water Resources and Quality, Impacts by herbicide. The comment
does not include a citation for the referenced modeling data that indicate
aminopyralid’s higher likelihood of reaching groundwater than all other herbicides, so
the BLM is unable to address this portion of the comment. During local level NEPA
analysis, the BLM will consider herbicide characteristics for leaching to groundwater
and the potential for groundwater contamination on a site-specific basis. It is not clear
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RESPONSE TO COMMENTS
39-06
U.S. Environmental
Protection Agency
39-08
U.S. Environmental
Protection Agency
how the final sentence about the ecological risks of adjuvants pertains to the rest of the
comment, but the BLM acknowledges the importance of considering the total
application mixture, including adjuvants listed on the label, during the site-specific
analysis.
Comment: Additionally, BLM should consider excluding application of herbicides
near waterbodies with no water quality data and designated source water protection
areas.
Response: As discussed in Chapter 1 of the document, the PEIS provides a broad,
programmatic level environmental impact analysis to which more specific
environmental documents can be tiered. The concerns raised in the comment would be
addressed at the local level during the NEPA process for site-specific vegetation
treatments. Local BLM land managers would take into account water quality concerns
and special designations when designing site-specific treatment projects. As stated in
Chapter 1 of the PEIS, under State and County Level Coordination, “At the agency or
state level, vulnerability assessments are done for treatment programs to ensure that
they do not result in unacceptable surface water or groundwater contamination.”
Comment: Extensive chemical treatment activities have the potential to increase
erosion and sediment delivery to drainages from the creation of barren ground from
invasive plant removal. Applied herbicides could also be discharged to aquatic habitats
via surface runoff, wind drift, leaching, or accidental spills. Cumulatively, water
quality could also be impacted as a result of effects of other projects on BLM lands,
including but not limited to, road and trail construction and maintenance activities,
livestock grazing along drainages, and recreational activities adjacent to drainages.
Treatments near 303(d) listed waters [impaired/threatened stream/river segments and
lakes that are regulated by the USEPA under the Clean Water Act] or road ditches that
drain into waterways could further degrade water quality due primarily to sediment,
herbicide, and temperature loadings (vegetation removal). The final PEIS, therefore,
should identify added precautions that will be used when applying the herbicides near
streams or road ditches that drain into streams to minimize or avoid drift impacts and
sublethal effects to aquatic life.
Response: The BLM concurs that the types of impacts to aquatic habitats identified in
the comment must be recognized and considered when developing site-specific
herbicide treatment projects. However, the programmatic scope of the PEIS does not
allow the document to address site-specific impacts associated with individual
projects. The types of impacts identified in the comment would be addressed by the
BLM at the local level through additional NEPA analyses needed to authorize the
project, as well as through the development of appropriate protective measures needed
to comply with Federal Insecticide, Fungicide, and Rodenticide Act and Clean Water
Act permitting requirements.
Environmental Consequences, Wetland and Riparian Areas
39-03 Comment: [US]EPA is concerned about unintended consequences that may result
U.S. Environmental from application of herbicides such as drift, effects on non-target species, accidental
Protection Agency spills, and persistence in soils that may erode into waterways; especially in designated
habitat conservation areas. For example, application of the three proposed herbicides
near streams within Riparian Habitat Conservation Areas should follow requirements
of the Pacific Anadromous Fish/Inland Native Fish (PACFISH/INFISH) management
strategies that limit ground-disturbing activities within [Riparian Habitat Conservation
Areas]. Additionally, BLM should adhere to prescribed buffers i.e., 300 [feet] on all
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RESPONSE TO COMMENTS
fish-bearing streams and 1 50 [feet] on streams without fish for improved protection of
aquatic resources in [Riparian Habitat Conservation Areas] from herbicide application
projects.
Response: The BLM would determine appropriate buffers to protect aquatic resources
at the site-specific level, taking site conditions, presence of fish, and any applicable
land designations or management plans into account. As discussed in Chapter 4 of the
PEIS under Wetland and Riparian Areas, Methodology for Assessing Impacts to
Wetland and Riparian Areas, minimum buffer widths for herbicides not labeled for
aquatic use are 100 feet for aerial, 25 feet for vehicle, and 10 feet for hand
applications. Based on the low toxicological risks associated with aminopyralid,
fluroxypyr, and rimsulfuron, larger buffers were not identified at the programmatic
level to protect fish and other aquatic organisms from herbicide treatments involving
these active ingredients. However, the standard buffers would be adjusted as needed at
the local level to protect aquatic resources. Additionally, the BLM would consider the
potential for ground disturbance to affect water resources during the local level NEPA
analysis once the details of a proposed project are known. For actions proposed within
Riparian Habitat Conservation Areas, the special designation would be taken into
account when designing herbicide treatment projects, and appropriate steps would be
taken to protect the exceptional values that these areas provide.
Comment: Non-target wetland and riparian areas could be exposed to herbicides
transported from upland areas via a variety of methods. The primary potential impacts
would be loss of non-target native vegetation and contamination of water or soil,
particularly as a result of an accidental spill. Therefore, we recommend the final PEIS
emphasize the importance of using all herbicides, especially near waters and wetlands,
consistent with the limitations and instructions included on herbicide labels. Using
herbicides near waters is subject to NPDES permitting, which requires compliance
with herbicide labels to avoid impacts to aquatic resources.
Response: The PEIS states in various locations of the document that use of the new
herbicides would be consistent with the label instructions. The Assumptions for
Analysis section in Chapter 4 of the PEIS lists SOPs that pertain to herbicide use,
including following the product label for use and storage, and reviewing,
understanding and conforming to the “Environmental Hazards” section on the
herbicide label.
Although none of the proposed active ingredients have an aquatic label, there could be
applications over or near water, particularly for aminopyralid. BLM field personnel
would address NPDES requirements at the site-specific level. The PEIS has been
modified to include a brief discussion of NPDES permit requirements in Chapter 4,
under Water Resources and Quality.
Environmental Consequences, Vegetation
35-07 Comment: Non-target plants, particularly dicots (broadleaf plants) are sensitive to
Alaska Community [aminopyralid] and will be adversely affected by applications of aminopyralid. Studies
Action on Toxics have shown that exposure of non-target plants to aminopyralid causes damage
including deformed leaves and stems, as well as reduced fruit production at low
concentrations.
Response: The potential effects of aminopyralid on non-target plants are discussed in
Chapter 4 of the PEIS, under Vegetation, Impacts of Herbicide Treatments. The
document states that “aminopyralid poses a high risk to non-target plants within the
39-18
U.S. Environmental
Protection Agency
BLM Vegetation Treatments Using Herbicides
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6-30
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RESPONSE TO COMMENTS
35-09
Alaska Community
Action on Toxics
39-14
U.S. Environmental
Protection Agency
treatment areas," and Table 4-8 presents buffers that were developed to minimize risks
to non-target vegetation from off-site drift of aminopyralid during herbicide
applications. The mitigation measure at the end of the section would require the BLM
to establish herbicide-specific buffer zones between treatment areas and non-target
plant species/populations of interest.
Comment: Research also shows that aminopyralid altered native plant communities.
Response: The PEIS discusses aminopyralid’s potential to alter native plant
communities in Chapter 4 under Vegetation, Impacts of Herbicide Treatments, Impacts
of Aminopyralid (page 4-27). The BLM’s SOPs include measures to minimize impacts
to native plant communities, including conducting pre-treatment surveys and designing
treatments that minimize damage to non-target vegetation.
Comment: Application of herbicides such as aminopyralid [has] the potential to
damage a variety of vegetation communities, including macrophytic species (wetland
vegetation), grasslands, and forbs, resulting in reduced growth, curling, chlorosis
and/or necrosis and plant death. In particular, use of aerial applications may harm non¬
target forage and cover species more than other methods. It is also possible that the
number of acres treated annually may increase in years in which herbicides are applied
aerially, which would increase the adverse effects of herbicide application to non¬
target vegetation in those areas.
Response: The potential effects of aminopyralid, fluroxypyr, and rimsulfuron on non¬
target vegetation are discussed in Chapter 4 of the PEIS, Environmental
Consequences, Vegetation. This section also incorporates by reference the lengthier
discussion in the 2007 PEIS. These discussions mention the increased risks to non¬
target vegetation associated with aerial applications, and provide appropriate buffer
distances for both aerial and ground-based application methods to protect non-target
plants from adverse effects. The BLM would consider the site characteristics and
potential damage to non-target vegetation, including forage and cover species, when
designing herbicide treatment projects.
The current PEIS includes an alternative that would not allow aerial spraying of
aminopyralid, fluroxypyr, or rimsulfuron (Alternative C). As stated in Chapter 2 of the
PEIS, all alternatives assume a maximum of 932,000 acres would be treated annually
via ground and aerial methods combined. While it is true that aerial application of
herbicides enables a greater acreage of land to be treated annually, there would be no
difference in aerial treatment acreages across the alternatives being considered in the
PEIS. Aerial application of herbicides was approved by the 2007 PEIS. Therefore,
even if the three new herbicides were not allowed to be applied aerially, other
herbicides could, potentially with more damaging effects to non-target vegetation than
if the new herbicides were used.
Environmental Consequences, Fish and Other Aquatic Organisms
26-03 Comment: Fluroxypyr is toxic to freshwater fish and aquatic invertebrates.
Rehfeldt, Melissa
36-03 Response: A discussion of fluroxypyr’s toxicity to fish and aquatic invertebrates can
Schumacher, Michelle be found in Chapter 4, under Fish and Other Aquatic Organisms, and in the Fluroxypyr
ERA. The risk assessment determined that there would be a low risk to special status
fish and aquatic invertebrates in ponds under an unlikely accidental helicopter spill
scenario. The risk assessment predicted no risks to fish or aquatic invertebrates as a
result of exposure to fluroxypyr under any of the modeled scenarios.
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34-01
Coast Range
Association
34-02
Coast Range
Association
Comment: The [Draft PEIS] Chapter 4, Environmental Consequences (page 4-14)
states that ‘"the proposed herbicide treatments have the potential to affect water
resources on or near public lands by altering water flows, surface water and
groundwater quantity and quality, and rates of groundwater recharge.’'’ Additionally,
on Page 4-41 is stated under Fish and Other Aquatic Organisms that “The proposed
herbicide treatments have the potential to affect fish and other aquatic organisms,
predominantly through indirect effects to aquatic habitats and adjacent riparian and
upland habitats.” In both cases cited above, the BLM notes positive effects. Yet on
page 4-43 the DEIS states “All herbicides pose some risk to non-target terrestrial and
aquatic plants. These risks should be considered, as damage to riparian and aquatic
plants may affect fish and aquatic invertebrates. Potential effects from vegetation
removal in riparian areas include loss of necessary habitat components (i.e., cover and
food), increased sedimentation into aquatic habitats, altered nutrient dynamics, and
increased water temperature due to a reduction in shade.”
Response: The PEIS discusses potential adverse and beneficial effects of treatment
with the three new active ingredients. This comment references both types of effects.
The potential for adverse effects to water resources, aquatic habitats, fish, and other
aquatic resources does not preclude the potential for beneficial effects to these
resources if the appropriate SOPs and other protective measures are followed to
minimize the risks for adverse effects. As discussed in Chapter 4 of the PEIS under
Fish and Other Aquatic Organisms, the BLM has developed numerous SOPs and
mitigation measures for herbicide applications in riparian areas and near streams,
including buffers between treatment areas and aquatic habitats, and use of the
appropriate application method to minimize the potential for injury to desirable
vegetation and aquatic organisms. Based on the likely usage of the three new
herbicides, wide-scale removal of riparian vegetation would be unlikely to occur.
Fluroxypyr and rimsulfuron would typically not be used near water, except to spot
treat target species. Aminopyralid would be used in riparian treatments for selective
removal of species such as knapweeds, but extensive removal of riparian vegetation
would be unlikely. Additionally, many of the BLM's treatment programs developed at
the local level would be designed to improve riparian and aquatic systems, and to
restore and enhance fish habitat. Herbicide treatments, where appropriate, would be
used as one component of these treatment programs.
During local-level project planning and environmental analysis, the BLM would be
able to more specifically address the potential beneficial and/or adverse effects of
herbicide treatments to fish and other aquatic organisms, based on local site conditions.
In many cases, herbicide treatments would be implemented with the goal of improving
riparian habitats and would have a long-term beneficial effect. Site-specific mitigation
measures to protect aquatic resources from adverse effects would also be developed at
the local level, as needed.
Comment: The Coast Range Association has attached as part of our comments a
report titled Conservation of Aquatic and Fishery Resources in the Pacific Northwest:
Implications of New Science for the Aquatic Conservation Strategy of the North west
Forest Plan. The report has a section that speaks to pesticides and aquatic
species.. ..Specifically, we refer the BLM to Page 18 of the report, Chemical Use in
Forests. Please accept this section of the report as Coast Range Association comments.
Response: The BLM appreciates the infonnation and has read the section on Chemical
Use on Forests in the referenced article. The article is concerned with the potential for
hann to listed species of Pacific salmon when commonly used pesticides are applied
according to label instructions, and provides five recommendations pertaining to use of
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chemicals in forests. Risk assessments completed in support of the PEIS used a
conservative analysis to determine the potential risks to sensitive fish, such as Pacific
salmon, from exposure to the proposed active ingredients, and were used to develop
buffers for protecting sensitive fish species. The recommendations in the article are in
line with concerns evaluated by the BLM at the local level when site-specific treatment
plans are developed. For example, the BLM has SOPs in place to evaluate the need for
chemical treatments and their potential to impact the environment, apply the least
amount of herbicide needed to achieve the desired results, minimize the size of
application areas, consider surrounding land uses before selecting aerial spraying as a
treatment method, use the appropriate application method to minimize the potential for
injury to desirable riparian vegetation and aquatic organisms, and treat only that
portion of the aquatic system necessary to achieve acceptable vegetation management.
Comment: We also refer the BLM to the following article in BioScience: A
Perspective on Modem Pesticides, Pelagic Fish Declines, and Unknown Ecological
Resilience in Highly Managed Ecosystems (Article in BioScience 62(4):428-434,
March 2012).
Response: Thank you for the information. The BLM has reviewed the referenced
article, which is concerned with the potential cumulative effects of herbicides and
other pesticides on aquatic species (primarily fish) and ecological functions, and the
difficulties in assessing these effects. The article notes a decline in fish species in the
San Francisco estuary and states that pesticides are a possible contributing factor in the
decline of imperiled fish species. The article also identifies a need for additional
scientific research to look at the ecosystem-level effects of pesticides and the need for
ecosystem-based management rather than focusing on ERAs, which, according to the
authors, provide limited information.
The cumulative effects analysis of the PEIS acknowledges the past use of herbicides
and other pesticides by various entities. The text of the PEIS under Cumulative
Effects, Fish and Other Aquatic Organisms, has been revised to cite the referenced
article and incorporate a statement about the potential for pesticides to interact with
other pollutants and various chemical and non-chemical factors.
The BLM must base its effects analysis on the best available science. Ecological risk
assessments were completed in accordance with the USEPA’s most recent guidelines.
Uncertainties in this process, which include many of the concerns raised in the article,
have been identified in the PEIS and individual risk assessments. Should future
scientific research result in changes to procedures for assessing potential risks to
aquatic species, the BLM would follow the new established procedures for future risk
assessments.
Environmental Consequences, Wildlife Resources
35-11 Comment: Developmental studies involving gavage administration in adult female
Alaska Community rabbits documented signs of incoordination upon exposure. In the rabbit study.
Action on Toxics developmental toxicity was shown by a decrease in fetal body weights. Effects on the
nervous system are not well documented. “It seems reasonable to assume that the most
sensitive effects in wildlife mammalian species will be the same as those in
experimental mammals (e.g., changes in the gastrointestinal tract, weight loss, and
incoordination).”
Response: As indicated in Appendix A.2 of the aminopyralid ERA, the oral gavage-
rabbit study (Carney and Tomesi 2004) included in the studies used to derive the small
34-05
Coast Range
Association
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mammal toxicity reference value reported a no observed adverse effect level (104
mg/kg BW-day) that is higher than the chronic no observed adverse effect level
selected as the toxicity reference value (50 mg/kg BW-day). Therefore, the selected
toxicity reference value, based on a rat study with dietary exposure to aminopyralid, is
more protective than the values reported for the rabbit study. As indicated in the 2007
USDA Forest Service ERA for aminopyralid, the incoordination was rapidly reversible
and did not persist past the day of dosing.
Regarding the statement that the most sensitive effects in wildlife mammalian species
will be the same in experimental mammals, that is a source of uncertainty noted in
Section 7 of the ERA (Table 7-1). Species differ in terms of absorption, metabolism,
distribution, and excretion of chemicals. However, it has been shown in many cases
that laboratory studies overestimate risk relative to field studies (Fairbrother and
Kaputska 1996), and the toxicity reference values selected for use in the ERAs were
typically based on the lowest values identified in the toxicity review. Therefore, risks
estimated in the ERA are more likely to be overestimated than underestimated.
Additionally the concentrations of aminopyralid that animals were exposed to in
laboratory studies where adverse effects were seen are much generally much higher
than the levels that wildlife on BLM lands would be exposed to.
Comment: Herbicide treatments could also impact wildlife and livestock due
primarily to direct spray, accidental spills, drift, and ingestion of contaminated
vegetation, prey species, or water. Effects to animals could include death, damage to
vital organs, decrease in growth, decrease in reproductive output and condition of
offspring, and increased susceptibility to predation. Wildlife in particular could
experience disruption of dispersal and foraging, which could expose some species to
greater predation related to habitat and cover losses. Overall, terrestrial and aquatic
applications of herbicides are likely to alter vegetation and have secondary indirect
effects on animals, including food availability and habitat quality.
Response: Potential effects to wildlife and livestock from use of the three new active
ingredients are discussed in Chapter 4 under Wildlife Resources, Summary of
Herbicide Impacts, and Livestock, Summary of Herbicide Impacts. The discussions in
these sections include the concerns raised in this comment. Additionally, these sections
reference the 2007 PEIS, which includes lengthier discussions of the potential impacts
of herbicide use on livestock and wildlife.
Environmental Consequences, Paleontological and Cultural Resources
35-02 Comment: These herbicides may harm the health of people who are reliant on
Alaska Community traditional foods and medicinal plants.
Action on Toxics
Response: An HHRA was completed to determine the toxicological risks to humans
associated with use of aminopyralid, fluroxypyr, and rimsulfuron. As discussed in
Chapter 4 of the HHRA, the risk analysis included an assessment of exposure to the
active ingredients via both dermal exposure and ingestion (drinking contaminated
water and eating sprayed berries and fish). The risk assessment did not identify any
health risks associated with exposure to aminopyralid, fluroxypyr, or rimsulfuron via
any of these exposure scenarios.
Additionally, as discussed in the HHRA and PEIS, when herbicides are used as part of
a vegetation treatment program on public lands, the BLM takes care to flag the area to
be treated and to post the area with warnings about when re-entry can occur safely.
39-15
U.S. Environmental
Protection Agency
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35-13
Alaska Community
Action on Toxics
35-26
Alaska Community
Action on Toxics
This would help prevent exposure to treated areas by those gathering traditional foods
and medicinal plants following treatment.
Further measures to protect the health of people who are reliant on traditional foods
and medicinal plants would be identified at the site-specific level, as appropriate, and
these concerns would be considered when designing treatment projects at the local
level. During the NEPA process at the local level, ongoing coordination/consultation
with applicable Native American tribes, Alaska Native groups, and Alaska Native
corporations would occur to ensure that concerns about effects to subsistence resources
and those who utilize them are addressed.
Comment: To our knowledge, there have not been studies of [aminopyralid] on
subsistence resources, including medicinal plants, herbs, berry plants, fish or wildlife,
particularly in our traditional use areas.
Response: The BLM is also not aware of any studies of aminopyralid that specifically
involve subsistence resources. However, the effects analysis in Chapter 4 of the PEIS
provides a discussion of the potential impacts of aminopyralid on non-target plants,
fish, and wildlife, based on information provided in the ERA for the active ingredient.
These discussions provide useful information for predicting potential adverse effects to
subsistence resources. Additionally, the Paleontological and Cultural Resources
section of Chapter 4 includes a discussion of the potential impacts of herbicide
treatments on subsistence resources. Appendix C of the PEIS is an AN1LCA Section
810 Analysis of Subsistence Impacts, which provides an evaluation of the proposed
project on subsistence resource in Alaska.
Risk assessments use scientific data to extrapolate risks to larger groups of plants, fish,
and wildlife. The standard practice is to select surrogate species for which
toxicological data are available, and use these data to determine risks to similar
species. Section 6.2 of the aminopyralid ERA provides a thorough discussion of this
process, with a complete list of surrogate species provided in Appendix C of that
document.
Comment: Alaskans are particularly vulnerable to the effects of these chemicals due
to our reliance on medicinal plants and traditional foods.
Response: The BLM evaluated both ecological and human health hazards in the
HHRA and ERAs, and conducted an analysis of subsistence impacts pursuant to
Section 810 of the ANILCA. The AN1LCA analysis is included as Appendix C of the
PEIS. Additionally, a report on Native American and Alaska Native Resource Uses
has been provided as a supplemental report to the PEIS.
Environmental Consequences, Social and Economic Values
01-01 Comment: Aminopyralid is of concern to vegetable growers, as it can enter the food
Public, Jean chain via manure, which contains long-lasting residues of the herbicide. It affects
potatoes, tomatoes, and beans, causing deformed plants, and poor or non-existent
yields. Problems with manure contaminated with aminopyralid residue surfaced in the
[United Kingdom (UK)] in June and July 2008, and, and the end of July 2008, Dow
AgroSciences implemented immediate suspension of UK sales and use of herbicides
containing aminopyralid. Approval of aminopyralid was subsequently reinstated in the
UK on October 6, 2009, as reported by the UK regulatory authority, the Advisory
Council on Pesticides. The reintroduction was approved “with new recommendations
and a stringent stewardship programme devised to prevent inadvertent movement of
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03-03
Eklund, Janelle
35-08
Alaska Community
Action on Toxics
manure from farms.” Despite restrictions, symptoms of aminopyralid damage were
recorded on crops growing in allotments in Edinburgh, UK as recently as June 2010;
inquiries traced the source of contamination to a farm supplying hay to the stables
from where bags of manure had been obtained. Symptoms of aminopyralid injury to
vegetable crops were reported by small farms and gardeners in Britain in July 2011.
Response: The persistence of aminopyralid in manure, and associated adverse effects
to crops, are discussed in Chapter 4 of the PEIS under Social and Economic Values,
Summary of Herbicide Impacts, Impacts of Aminopyralid. The PEIS states that ‘the
BLM would follow all label restrictions to prevent impacts to crops and gardens
associated with the use of this herbicide, including restrictions on grazing, where
applicable. The BLM would not export manure, plant residues, or other materials that
may be treated with aminopyralid for use as soil amendments.”
The labels associated with herbicide formulations of aminopyralid contain extensive
requirements regarding the use of the active ingredient and the management of the
treated forage and subsequent manure associated with grazing animals. The BLM
would incorporate the requirements stated on the label into the site-specific
management of vegetation using this particular active ingredient.
Comment: Further, aminopyralid is of concern to vegetable growers, as it can enter
the food chain via manure, which contains long-lasting residues of the herbicide... The
article also states that aminopyralid can end up in gardens through manure, compost
(municipal or farm-made), straw, and hay. It and several others are some of the worst
of a host of next-generation herbicides. All must be avoided but aminopyralid is a
grower’s nightmare. If a grower is certified organic they will immediately lose their
certification for three or more years. Growers, thinking they are doing right by getting
municipal compost find out it is fatal later. Use of herbicides can destroy a farm’s or
homestead’s future for many years.
Response: The persistence of aminopyralid in manure, and associated adverse effects
to crops, are discussed in Chapter 4 of the PEIS under Social and Economic Values,
Summary of Herbicide Impacts, Impacts of Aminopyralid. The PEIS states that “the
BLM would follow all label restrictions to prevent impacts to crops and gardens
associated with the use of this herbicide, including restrictions on grazing where
applicable. The BLM would not export manure, plant residues, or other materials that
may be treated with aminopyralid for use as soil amendments.”
The labels associated with herbicide formulations of aminopyralid contain extensive
requirements regarding the use of the active ingredient and the management of treated
forage and manure associated with grazing animals. The BLM would incorporate these
requirements into the site-specific management of vegetation using this particular
active ingredient.
Comment: [Aminopyralid] is quite persistent in soils, with demonstrated half-lives of
32-533 days. Compost and manure contaminated with residues of aminopyralid causes
damage to and economic losses of crops on which the compost or manure have been
applied.
Response: The persistence of aminopyralid in soil, compost, and manure, and
associated adverse effects are discussed in Chapter 4 of the PEIS. Soil persistence is
discussed under Soil Resources, Impacts of Herbicide Treatments, Impacts of
Aminopyralid. Persistence in compost and manure is discussed in the same section, as
well as under Vegetation, Impacts of Herbicide Treatments, Impacts of Aminopyralid,
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35-10
Alaska Community
Action on Toxics
Non-Target Plants; and under Social and Economic Values, Summary of Herbicide
Impacts, Impacts of Aminopyralid. The PEIS states that “the BLM would follow all
label restrictions to prevent impacts to crops and gardens associated with the use of
this herbicide, including restrictions on grazing, where applicable. The BLM would
not export manure, plant residues, or other materials that may be treated with
aminopyralid for use as soil amendments.”
The labels associated herbicide formulations of aminopyralid contain extensive
requirements regarding the use of the active ingredient and the management of treated
forage and subsequent manure associated with grazing animals. The BLM would
follow the label requirements during all treatment actions involving use of this
particular active ingredient.
Comment: In a study of the effects of aminopyralid, crops were injured by the
herbicide at soil concentrations less than the limit of quantitation (0.2 pg kg (-1)).
Response: The potential effects of aminopyralid on off-site crops are discussed in
Chapter 4 of the PEIS, under Social and Economic Values, Summary of Herbicide
Impacts, Impacts of Aminopyralid. The PEIS notes that “treatment buffers would be
required to prevent impacts to non-target plants, which would include commercial
crops and other broadleaf plants.” These buffers are presented in Table 4-8 of the
PEIS, and were developed from information presented in the aminopyralid ERA,
which predicted risks to non-target plants under various exposure scenarios, using the
best available toxicity data for the herbicide.
Environmental Consequences, Human Health and Safety
03-04
Eklund, Janelle
Comment: And what does [aminopyralid] do to the health of humans? When it gets in
the food chain we are sure to ingest the very poisons we lace the plants with. Why do
we have so many health issues? It’s a no-brainer.
Response: Human health risks associated with use of aminopyralid are discussed in
Chapter 4 of the PEIS, under Human Health and Safety. Information provided is based
on the HHRA, which looked at both likely and unlikely exposure scenarios, including
ingestion of plant materials and water that have been sprayed with the herbicide. The
HHRA found that there are no risks to occupational or public receptors from routine
use or accidental exposure scenarios, even considering worst-case exposures. As stated
in Section 2.2. 1.9 of the HHRA, aminopyralid is rapidly absorbed, distributed, and
excreted by mammals when ingested. Tissue distribution and bioaccumulation of
aminopyralid appears to be minimal.
14-03
Oregon Wild
Comment: BLM should fully disclose the effects of herbicides on adults, children,
and pregnant women.
Response: Human health risks associated with aminopyralid, fluroxypyr, and
rimsulfuron are discussed in Chapter 4 of the PEIS, under Human Health and Safety.
Information provided is based on the HHRA that was prepared in support of the PEIS.
The BLM follows the four-step risk assessment process identified by the National
Academy of Science (1983) for assessing risks to human health: 1) hazard
identification; 2) dose-assessment; 3) exposure assessment; and 4) risk
characterization. The HHRA is included as a supplemental report to the PEIS. The
HHRA calculated risk to both occupational (e.g., herbicide applicators) and public
receptors, and for public receptors calculated risk to both adults and children via
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various exposure pathways. Pregnant women are included in the adult population, and
studies of developmental effects on the fetus are included in the development of the
toxicity endpoints (described in Section 2.2 of the HHRA). None of the three
herbicides presents an unacceptable risk to the public (adults, inclusive of pregnant
women, or children) under any of the exposure scenarios considered. Rimsulfuron was
found to have a low to moderate human health risk to adult workers under accidental
exposure scenarios; these risks would be mitigated through proper handling of the
herbicide, wearing appropriate personal protective equipment, and following all
applicable SOPs for herbicide applications.
Environmental Consequences, Cumulative Effects Analysis
39-13 Comment: The Draft PEIS utilized air quality analysis completed for the 2007 PEIS,
U.S. Environmental since the proposed action does not increase the total amount of herbicide application.
Protection Agency However, during the review of the 2007 PEIS, [USjEPA identified several issues with
the air quality emissions inventory and modeling. These issues may lead to an
underestimate of cumulative impacts to air quality due to lack of consideration of other
management activities that will be conducted under the land management plan that
potentially have impacts to air quality. Therefore, concerns regarding cumulative
impacts to air quality still remain.
Response: Because the issues with the air quality inventory and modeling that were
identified in 2007 have not been provided in this comment, it is difficult to respond to
specific concerns. It is also not clear what “land management plan” the comment is
referring to when it mentions other land management activities that have not been
considered in the cumulative effects analysis. The cumulative effects analysis of the
2007 PEIS, which is incorporated into the current PEIS by reference, considered
various actions by the BLM and other entities, with a focus on smoke emissions from
prescribed fire and wildland fire. Smoke from fire remains the largest air quality
concern on public lands, and was the focal point of the cumulative effects analysis.
The amount of air quality emissions associated with vehicles and aircraft that apply
herbicides is very small when compared to the amount associated with fire, and
herbicide treatments that reduce wildfire risk would be expected to benefit air quality
in the western states.
Consultation and Coordination, Public Involvement
28-04 Comment: Unless there is an urgent need to treat immediately, (again, Elodea in a
Copper Country water body used by boaters or float planes is an example), the 45-day public comment
Alliance period should be adhered to.
Response: For site-specific NEPA analysis, the level of public comment would be
determined by the local BLM office. Guidance in the NEPA BLM Handbook
(Handbook H- 1790-1; USDOI BLM 2008a) states that the public comment period for
all draft EISs must last at least 45 days. However, Environmental Assessments are not
required under CEQ regulations to be made available for public comment and review.
If they are made available, most would have a 30-day public comment period.
There would be a substantial period of time between identification of a need to treat
with herbicide and the treatment itself. The BLM would need to first go through the
NEPA process, including consultation with agencies as needed. Following completion
of the Environmental Assessment or EIS, a Pesticide Use Proposal would be prepared
for the proposed treatment. Following approval of the Pesticide use Proposal, the
proposed treatment would be allowed to occur.
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28-05
Copper Country
Alliance
33-01
Wroncy, Jan, and Hale,
Gary
Ecological Risk Assessment
29-01
Dow AgroSciences
29-02
Dow AgroSciences
Comment: Public comment periods should be well-publicized. Legal notices
generally are not read by the public. There should be an article and/or attention-
catching ad in a local paper and announcements on local radio stations.
Response: Thank you for your helpful insight. We will forward your comment to local
Authorized Officers who are instrumental in providing local public announcements.
For the Draft Programmatic EIS for Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and Rimsulfuron on Bureau of Land Management Lands in 1 7 Western
States , news releases were issued to national, state, and local news services to coincide
with the release of the Draft PEIS, and notice of the availability of the draft document
and the public comment period was published in the Federal Register on June 19,
2015, in accordance with federal regulations.
Comment: Regarding comments on the Draft Programmatic Environmental Impact
Statement Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron
on Bureau of Land Management Lands in 17 Western States. We need more time to
consider the impacts of [aminopyralid, fluroxypyr, and rimsulfuron] in light of the
recent [US]EPA ruling regarding small streams. Please extend the comment period for
30 more days.
Response: The BLM received one comment requesting an extension of the public
comment period. The BLM determined that a 45-day public comment period was
sufficient for the Draft PEIS, considering the USEPA’s recent Clean Water Rule does
not change the analysis or conclusions presented in the PEIS.
Comment: It is also worth mentioning that picloram (Tordon 22K) is not registered
for use in California but aminopyralid is registered in that state. Therefore, it is more
important for those BLM land managers in California to have aminopyralid as a tool in
their herbicide tool box so that they can effectively control key invasive/noxious weeds
like yellow starthistle using an effective, low rate herbicide.
Response: The BLM appreciates the comments provided by the commenter, and
recognizes the importance of being able to utilize vegetation management options that
offer efficacious results on several of the troublesome weed species found on lands the
BLM administers.
Comment: Regarding the potential toxicity of aminopyralid to amphibians, there
appears to be some discrepancy within the [ERA]. In several areas of the document
there is mention of no information on amphibian toxicity: 1. On Page 5 it states: “No
toxicity studies conducted on amphibian studies were found in the literature.” 2. On
page 5 in Table 3-1 there is mention of “no data” for amphibian toxicity reference
values. 3. On page 107 it is stated that, “No conclusions can be drawn regarding the
sensitivity of amphibians to exposure to aminopyralid relative to the surrogate species
selected for the ERA.” 4. On page 131 in Table 7.1 it states that there is a “lack of
toxicity information for amphibian and reptile species.” However, on page 33 in
Section 3. 1.3.2 there is a review of an amphibian study in which USEPA has classified
aminopyralid as practically non-toxic to aquatic-phase amphibians (USEPA2005b).
See also USEPA document number MR1D [Master Record Identifier] No. 46235816.
Therefore, the references to a lack of data for amphibians should be corrected.
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Dow AgroSciences
29-04
Dow AgroSciences
29-05
Dow AgroSciences
29-06
Dow AgroSciences
Response: The reviewer is correct that a single larval amphibian study was identified
in Section 3. 1.3.2 and presented in Appendix A. The sentence referencing a lack of
data for amphibians on page ES-3 will be deleted and amphibians will be added to the
sentence starting “Aminopyralid also has little toxic impact on...” The amphibian
study information will be added to Table 3-1 under the Additional Endpoints heading.
In Section 6.2.2, the text will be revised to indicate that the USEPA has classified
aminopyralid as practically non-toxic to aquatic-phase amphibians (USEPA 2005b),
but that no conclusions can be drawn regarding the sensitivity of adult amphibians to
exposure to aminopyralid relative to the surrogate species selected for the ERA. Table
7-1 will be revised to state “Information is limited and/or not available on the toxicity
of herbicides to reptile and amphibian species resulting from dietary or direct contact
exposures.”
Comment: It could be noted that all of the incidents listed in the Aminopyralid
Incident Report Summary (Table 2-2 of the aminopyralid [ERA]) were early in the
registration of aminopyralid. It was registered under the [US]EPA Reduced Risk
Program in 2005 and the incidents were from 2006 through 2009 which indicates that
applicators learned how and where to best apply aminopyralid. There were no
incidents listed past 2009 - 6 years ago.
Response: Given that the dates of the incidents are provided in the Table 2-2 and
therefore clearly shown in the document, the BLM feels that the suggested change to
the risk assessment is unwarranted. The purpose of Section 2.4 is to disclose
information about herbicide incident reports. Regardless of the validity of the
suggestion that the data indicate that applicators learned how and where to best apply
aminopyralid, we do not feel that it is appropriate to make this inference in the risk
assessment. Additionally, including this information would not change the conclusions
made in the document or the associated analysis in the PEIS.
Comment: In Section 7.3.1 “Degradates” it states “the lack of data on the toxicity of
degradates of aminopyralid represents a source of uncertainty in the risk assessment.”
However, aminopyralid goes to mineralization [(carbon, oxygen, and nitrogen)] so
there are no degradates to be studied. USEPA has not identified any metabolites of
concern in any matrices so the uncertainty stated here does not exist.
Response: The statement referenced in this comment, from the aminopyralid ERA, is
correct. Regardless of the information provided about the mineralization of
aminopyralid, there is a lack of ecotoxicity data available for terrestrial and aquatic
species on the degradates of aminopyralid. This lack of data represents a source of
uncertainty.
Comment: We would also like to add that fluroxypyr poses no chronic toxicity hazard
to mammals as the review of chronic data shows in the fluroxypyr [ERA] (page 28), so
that should be noted in the Executive Summary (ES-3) and elsewhere throughout the
document.
Response: The information in the referenced section of the fluroxypyr risk assessment
(Page 3-2 [28 on the pdf], Section 3. 1.2.1) indicates studies that show some chronic
toxicity (kidney and growth effects) to small mammals at high doses of fluroxypyr.
Therefore, we do not agree that the statement that fluroxypyr poses no chronic toxicity
to mammals based on the review of chronic data is correct.
Comment: In Section 4.3. 1.1 “Terrestrial Wildlife” it is improbable that with an LC50
[lethal concentration resulting in 50 percent mortality] of >25 pg a.i. [active
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ingredient]/bee for fluroxypyr that direct applications of fluroxypyr would be above
the [level of concern]. We recommend that these calculations be re-worked to be sure
that there is not an error.
Response: The calculations for the pollinating insect risk quotient, assuming 100
percent absorption, were reviewed and determined to be correct. No errors were found
in the calculations. The calculated dose of 41 mg acid equivalent per kilogram of body
weight (based on a typical application rate) divided by the toxicity reference value of
269 mg acid equivalent per kilogram of body weight results in a risk quotient of 0.15,
which slightly exceeds the most conservative level of concern of 0.1. Both the dose
and the toxicity reference values calculated were confirmed as correct. As indicated in
Section 4.3. 1.1, it was noted that this scenario is particularly conservative because it is
assumed that the insect is absorbing 100 percent of the herbicide.
Comment: While some aquatic plants are sensitive to fluroxypyr, its labeled uses do
not include applications to control submerged and/or floating plants in aquatic sites
and therefore it is highly unlikely that aquatic plants would be exposed to a level of
fluroxypyr that might cause injury or harm.
Response: The risk assessments consider exposure of ecological receptors to the
active ingredient in question, via various intentional and unintentional exposure
mechanisms. These exposure scenarios are not limited to likely situations for exposure;
they also include accidental (unlikely) exposure scenarios that are within the realm of
possibility and therefore represent a worst-case scenario. In the case of aquatic plants,
exposure to fluroxypyr could occur via drift or surface runoff from a nearby upland
application area, if an aquatic habitat was accidentally directly sprayed (i.e., the label
instructions were not followed), or if a truck or helicopter accidentally spilled its entire
load of herbicide mixed for an application into an aquatic habitat. The latter two
scenarios are labeled as accidental exposure scenarios, and the text of the ERA states
that the spill scenarios were developed “to represent worst-case potential impacts to
ponds” (Section 4.2. 1.5). Therefore, the risk assessment makes it clear that it is highly
unlikely that aquatic plants would be exposed to a level of fluroxypyr that might cause
injury or harm. Additionally, the discussion of potential effects to aquatic plants in the
PEIS under Vegetation, Impacts of Herbicide Treatments, Impacts of Fluroxypyr,
Non-Target Plants includes these worst-case scenarios.
Comment: Just a comment, the link to this reference did not work. New York State
Department of Environmental Conservation (NYSDEC). 2007. Letter to Mr. Jim
Baxter of Dow AgroSciences, LLC. Re: Withdrawal of Milestone Herbicide
Application (USEPA Reg. No. 62719-519) Containing the Active Ingredient
Aminopyralid. Chemical Code: 005209 Available at URL:
http:i/pmep.cce.cornell.edu/profiles/herb-growthred/24-d-
butylate/aminopyralid/aminopyr wth 0207.pdf.
Response: We tried the link to this reference provided in the ERA and found it to
work. The correct link, as given in the risk assessment is
http://pmep.cce.cornell.edu/profiles/herb-growthreg/24-d-
butylate/aminopyralid/aminopyr wth 0207.pdf. The URL provided in the comment
has an “i” instead of a backslash after “http:”.
Comment: While we appreciate the [ERA] data provided in the Draft PEIS, we
recommend the risk assessment include evaluation of risks from incidents that
applicants are required to report for each herbicide proposed for use e.g., wind erosion,
and tailor the evaluation to local conditions so accurate risks may be known.
39-16
U.S. Environmental
Protection Agency
29-08
Dow AgroSciences
29-07
Dow AgroSciences
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39-17
U.S. Environmental
Protection Agency
Response: The risk assessments were designed to be broad, and covered pesticide
exposure pathways (runoff, drift, wind erosion) under a variety of different site and
application conditions (slope, vegetation, weather, aerial applications, ground
applications) that may be relevant across the 17 western states under consideration.
Recommended treatment buffers identified in the risk assessments and PEIS may be
tailored (either increased or decreased) based on local site conditions, but it is not
feasible to do this type of analysis at the programmatic level.
Comment: Additionally, it may be appropriate to include a broader search of the
ecotoxicity data for these chemicals by also providing data from the open literature via
ECOTOX (http://cfpub.epa.gov/ecotox/).
Response: As detailed in Section 3.1 of the ERAs, USEPA’s on-line ECOTOX
database was queried for ecotoxicity data. These data are presented in Appendix A of
each pesticide ERA and were considered in the selection of the toxicity reference
values presented in Table 3-1.
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CHAPTER 7
REFERENCES
REFERENCES
CHAPTER 7
REFERENCES
Abella, S.R. 2008. A Systematic Review of Wild
Burro Grazing Effects on Mojave Desert
Vegetation, USA. Environmental Management
DOl 1 0. 1 007/s00267-008-9 1 05-7.
AECOM. 2013. Scoping Summary Report for the
Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and Rimsulfuron on Bureau of Land
Management Lands in 17 Western States
Programmatic Environmental Impact Statement.
Seattle, Washington.
_ . 2014a. Fluroxypyr Ecological Risk
Assessment Final Report. Prepared for the USDOI
BLM. Manchester, New Hampshire.
_ . 2014b. Rimsulfuron Ecological Risk
Assessment Final Report. Prepared for the USDOI
BLM. Manchester, New Hampshire.
_ . 2014c. Final Human Health Risk
Assessment. Prepared for the USDOI BLM.
Manchester, New Hampshire.
_ . 2015. Aminopyralid Ecological Risk
Assessment Final Report. Prepared for the USDOI
BLM. Manchester, New Hampshire.
Agee, J.K. 1993. Fire Ecology of Pacific Northwest
Forests. Island Press. Washington, D.C.
Allen, M.F. 1991. Ecology of Mycorrhizae.
Cambridge University Press. Cambridge, United
Kingdom.
American Cancer Society. 2012. Lifetime Risk of
Developing or Dying From Cancer. Available at:
http://www.cancer.org.
Asher, J.E., and S.A. Dewey. 2005. Estimated
Annual Rates of Weed Spread on Western Federal
Wildlands. Draft White Paper. Federal
Interagency Committee for Management of
Noxious and Exotic Weeds (FICMNEW).
Washington, D.C.
Bailey, R.G. 1997. Map: Ecoregions of North
America (Revised; Scale: 1:15,000,000). U.S.
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CHAPTER 8
GLOSSARY
GLOSSARY
CHAPTER 8
GLOSSARY
A
Absorption: The process by which a chemical or other
substance is able to pass through body membranes and
enter an organism.
Active ingredient (a.i.): The chemical or biological
component that kills or controls the target pest.
Acute risk: Risk associated with illness or injury
shortly after exposure to a potentially toxic substance.
Acute toxicity: The quality or potential of a substance
to cause injury or illness shortly after exposure to a
relatively large dose.
Adaptive management: A system of management
practices based on clearly identified outcomes,
monitoring to determine if management actions are
meeting outcomes, and if not, facilitating management
changes that will best ensure that outcomes are met or
reevaluated.
Additive: A substance added to another in relatively
small amounts to impart or improve desirable
properties or suppress undesirable properties.
Additive effect: A situation in which combined effects
of exposure to two chemicals simultaneously is equal
to the sum of the effect of exposure to each chemical
given alone.
Adjuvant: A chemical that is added to a pesticide by
the user to improve the pesticide’s efficacy. Adjuvants
are often included in the pesticide formulation,
becoming part of the inert, or other, ingredients
associated with the formulation.
Adsorption: 1) The adhesion of substances to the
surface of solids or liquids. 2) The attraction of ions of
compounds to the surface of solids or liquids.
Adverse impact: An impact that causes harm or a
negative result.
Aerobic: Utilizing oxygen or having oxygen present.
Aggregate Risk Index (ARI): A numeric expression
of risk that combines potential risks from various
exposure pathways. Used in the Human Health Risk
Assessment.
Air pollutant: Any substance in the air that could, if
present in high enough concentration, harm humans,
animals, vegetation, or material. Air pollutants may
include almost any natural or artificial matter capable
of being airborne in the form of solid particles, liquid
droplets, gases, or a combination of these.
Air quality: The composition of air with respect to
quantities of pollution therein; used most frequently in
connection with “standards” of maximum acceptable
pollutant concentrations.
Alien (species): Per Executive Order 13112, alien
species means, with respect to a particular ecosystem,
any species, including its seed, eggs, spores, or other
biological material capable of propagating that species,
that is not native to that ecosystem.
Allotment (grazing): Area designated for the use of a
certain number and kind of livestock for a prescribed
period of time.
Alternative: In an EIS, one of a number of possible
options for responding to the purpose and need for
action.
Ambient air: Any unconfined portion of the
atmosphere; open air and surrounding air. Often used
interchangeably with “outdoor air.”
Anadromous: A term used to describe fish that
mature in the sea and swim up freshwater rivers and
streams to spawn. Salmon, steelhead, and sea-run
cutthroat trout are examples.
Anaerobic: Lacking in oxygen.
Animal Unit (AU): A standardized unit of
measurement for range livestock that is equivalent to
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one cow, one horse, five sheep, five goats, or four
reindeer, all over 6 months of age.
Animal Unit Month (AUM): The amount of feed or
forage required by one animal unit grazing on a
pasture for 1 month.
Annual (plant): A plant whose life cycle is completed
in 1 year or season.
Aquatic: Growing, living in, frequenting, or taking
place in water; used to indicate habitat, vegetation, or
wildlife in freshwater.
Aquifer: Rock or rock formations (often sand, gravel,
sandstone, or limestone) that contain or carry
groundwater and act as water reservoirs.
Area of Critical Environmental Concern (ACEC):
An area within public lands that requires special
management attention to protect and prevent
irreparable damage to important historic, cultural, or
scenic values; fish and wildlife resources; other natural
systems or processes; or to protect life or provide
safety from natural hazards.
Arid: A term applied to regions or climates where lack
of moisture severely limits growth and production of
vegetation. The limits of precipitation vary
considerably according to temperature conditions.
Attainment area: A geographic area that is in
compliance with the National Ambient Air Quality
Standards. An area considered to have air quality as
good as or better than the National Ambient Air
Quality Standards as defined in the Clean Air Act.
B
Bioaccumulate: To take in or store a persistent
substance, as by a plant or animal. Over time, a higher
concentration of the substance is found in the organism
than in the organism’s environment.
Biodegradation: The process by which a substance is
broken down by microorganisms and/or natural
environmental factors.
Biodiversity: The variety of life and its processes,
including all life forms from one-celled organisms to
complex organisms such as insects, plants, birds,
reptiles, fish, other animals; and the processes,
pathways, and cycles that link such organisms into
natural communities.
Biological Assessment (BA): A document prepared
by or under the direction of a federal agency. A BA
addresses federally listed species and species proposed
for listing and designated and proposed critical habitat
that may be present in the action area, and evaluates
the potential effects of the action on such species and
habitat.
Biological crust: Thin crust of living organisms on or
just below the soil surface; composed of lichens,
mosses, algae, fungi, cyanobacteria, and bacteria.
Boom (herbicide spray): A tubular metal device that
conducts an herbicide mixture from a tank to a series
of spray nozzles. It may be mounted beneath a
helicopter or a fixed-wing aircraft, or behind a tractor
or all-terrain vehicle.
Broadcast spray: An application of an herbicide that
uniformly covers an entire area.
Broad-scale: At the level of a large, regional area,
such as a river basin; typically a multi-state area.
Buffer/buffer zone: A strip of vegetation that is left or
managed to reduce the impact that a treatment or
action on one area might have on another area.
Bunchgrass: A grass having the characteristic growth
habit of forming a bunch; lacking stolons or rhizomes.
C
California Puff (CALPUFF): CALPUFF is an
advanced non-steady-state meteorological and air
quality modeling system adopted by the U.S.
Environmental Protection Agency as the preferred
model for assessing long range transport of pollutants
and their impacts involving complex meteorological
conditions.
Carbon-14 dating: The use of the naturally occurring
isotope of carbon- 14 in radiometric dating to
determine the age of organic materials.
Carcinogen: A chemical capable of inducing cancer.
Carnivore: An animal that feeds on other animals,
especially the flesh-eating mammals.
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Carrier: A non-pesticidal substance added to a
commercial pesticide formulation to make it easier to
handle or apply.
Carrying capacity: The maximum population of a
particular species that a particular region can support
without hindering future generations’ ability to
maintain the same population.
Chemical degradation: The breakdown of a chemical
substance into simpler components through chemical
reactions.
Chronic exposure: Exposures that extend over the
average lifetime or for a significant fraction of the
lifetime of the individual. Chronic exposure studies are
used to evaluate the carcinogenic potential of
chemicals and other long-term health effects.
Chronic risk: Risk associated with long-term health
effects after exposure to a potentially toxic substance.
Symptoms recur frequently or develop slowly over a
long period of time.
Class I area: Under the 1977 Clean Air Act
amendments, all international parks, parks larger than
6,000 acres, and national wilderness areas larger than
5,000 acres that existed on August 7, 1977. This class
provides the most protection to pristine lands by
severely limiting the amount of additional air pollution
that can be added to these areas.
Climate: The composite or generally prevailing
weather conditions of a region throughout the year,
averaged over a series of years.
Code of Federal Regulations (CFR): A codification
of the general and permanent rules published in the
Federal Register by the executive departments and
agencies of the federal government.
Consultation: Exchange of information and
interactive discussion. It often refers to consultation
mandated by statute or regulation that has prescribed
parties, procedures, and timelines (e.g. consultation
under National Environmental Policy Act or Section 7
of the Endangered Species Act).
Coos Bay Wagon Road Lands: Public lands in
Western Oregon that were granted to the State of
Oregon, and then to the Coos Bay Wagon Road
Company, to aid in the construction of a military
wagon road from Coos Bay to Roseburg, Oregon.
These lands were later reconveyed to the federal
government by Congress.
Council on Environmental Quality (CEQ): An
advisory council to the President of the United States
established by the National Environmental Policy Act
of 1969. It reviews federal programs for their effect on
the environment, conducts environmental studies, and
advises the President on environmental matters.
Countervailing: A type of cumulative impact where
negative effects are compensated for by beneficial
effects.
Cover: 1) Trees, shrubs, rocks, or other landscape
features that allow an animal to partly or fully conceal
itself. 2) The area of ground covered by plants of one
or more species, usually expressed as a percent of the
ground surface.
Criteria: Data and information that are used to
examine or establish the relative degrees of desirability
of alternatives or the degree to which a course of
action meets an intended objective.
Criteria pollutants: Air pollutants designated by the
U.S. Environmental Protection Agency as potentially
harmful and for which ambient air quality standards
have been set to protect the public health and welfare.
The criteria pollutants are carbon monoxide, sulfur
dioxide, particulate matter, nitrogen dioxide, ozone,
hydrocarbons, and lead.
Critical habitat: 1) Specific areas within the habitat a
species occupies at the time it is listed under the
Endangered Species Act that have physical or
biological features that a) are essential to the
conservation of the species, and b) may require special
management considerations or protection; and 2)
specific areas outside the habitat a species occupies at
the time it is listed that the Secretary of the Interior
determines are essential for species conservation.
Cultural resources: Archaeological, historic, or
architectural sites, structures, or places with important
public or scientific uses, which may include definite
locations (sites or places) of traditional cultural or
religious importance to specific social or cultural
groups.
Cumulative effects: Impacts on the environment that
result from the incremental impact of an action when
added to other past, present, and reasonably
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foreseeable future actions. Cumulative effects can
result from individually minor, but collectively
significant, actions taking place over a period of time.
D
Degradate: The chemical compound resulting from a
physical or biological breakdown of a more complex
chemical compound.
Degradation: Physical or biological breakdown of a
complex compound into simpler compounds.
Density: The number of individuals per a given unit
area.
Direct effects: Impacts on the environment that are
caused by the action and occur at the same time and
place.
Dispersion: The act of distributing or separating into
lower concentrations or less dense units.
Disturbance: Refers to events that alter the structure,
composition, or function of terrestrial or aquatic
habitats. Natural disturbances include, among others,
drought, floods, wind, fires, wildlife grazing, and
insects and pathogens. Human-caused disturbances
include actions such as timber harvest, livestock
grazing, roads, and the introduction of exotic species.
Dominant: A group of plants that by their collective
size, mass, or number exerts a primary influence onto
other ecosystem components.
Dose: The amount of chemical administered or
received by an organism, generally at a given point in
time.
Dose-response: Changes in toxicological responses of
an individual (such as alterations in severity of
symptoms) or populations (such as alterations in
incidence) that are related to changes in the dose of
any given substance.
Draft Environmental Impact Statement (DEIS):
The draft statement of the environmental effects of a
major federal action which is required under Section
102 of the National Environmental Policy Act, and
released to the public and other agencies for comment
and review.
Drift: That part of a sprayed chemical that is moved
by wind off a target site.
E
Ecoregion: Geographic areas that are delineated and
defined by similar climatic conditions,
geomorphology, and soils.
Ecosystem: Includes all the organisms of an area, their
environment, and the linkages or interactions among
all of them; all parts of an ecosystem are interrelated.
The fundamental unit in ecology, containing both
organisms and abiotic environments, each influencing
the properties of the other and both necessary for the
maintenance of life.
Ecosystem-based Management: Scientific
knowledge of ecological relationships within a
complex sociopolitical and values framework, that
works toward a goal of protecting native ecosystem
integrity over the long term.
Ecotone: A boundary or zone of transition between
adjacent communities or environments, such as the
boundary between a forest and a meadow. Species
present in an ecotone are intermixed subsets of the
adjacent communities.
Edge: The boundary zone or ecotone between two
communities, both of which affect the composition and
density of populations in these bordering areas.
Effect: Environmental change resulting from a
proposed action. Direct effects are caused by the
action and occur at the same time and place, while
indirect effects are caused by the action but are later in
time or further removed in distance, although still
reasonably foreseeable. Indirect effects may include
growth-inducing effects and other effects related to
induced changes in the pattern of land use, population
density, or growth rate, and related effects on air and
water and other natural systems, including ecosystems.
Effect and impact are synonymous as used in this
document.
Endangered species: Plant or animal species that are
in danger of extinction throughout all or a significant
part of their range.
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Endemic (species): Occurring naturally in a certain
region and having a distribution that is relatively
limited to a particular locality.
Environment: 1) The physical conditions that exist
within an area (e.g., the area that will be affected by a
proposed project), including land, air, water, minerals,
flora, fauna, ambient noise, and objects of historical or
aesthetic significance. 2) The sum of all external
conditions that affect an organism or community to
influence its development or existence.
Environmental Assessment (EA): A concise public
document, for which a federal agency is responsible,
that serves to: 1) briefly provide sufficient evidence
and analysis for determining whether to prepare an
Environmental Impact Statement or a finding of no
significant impact; 2) aid an agency’s compliance with
the National Environmental Policy Act when no
Environmental Impact Statement is necessary; and 3)
facilitate preparation of an Environmental Impact
Statement when one is necessary.
Environmental Impact Statement (EIS): A required
report for all federal actions that will lead to
significant effects on the quality of the human
environment. The report must be systematic and
interdisciplinary, integrating the natural and social
sciences as well as design in planning and decision¬
making. The report must identify 1) the environmental
impacts of the proposed action, 2) any adverse
environmental effects which cannot be avoided should
the proposal be implemented, 3) alternatives to the
proposed action, 4) the relationship between short¬
term uses of the human environment and the
maintenance and enhancement of long-term
productivity, and 5) any irreversible and irretrievable
commitments of resources which would be involved in
the proposed action should it be implemented.
Environmental Justice: The fair treatment and
meaningful involvement of all people regardless of
race, color, national origin, or income with respect to
the development, implementation, and enforcement of
environmental laws, regulations, and policies.
Eradicate: To remove all traces of a population or
eliminate a population to the point where individuals
are no longer detectable.
Erosion: The wearing away of the land surface by
running water, wind, ice, gravity, or other geological
activities; can be accelerated or intensified by human
activities that reduce the stability of slopes or soils.
Essential Fish Habitat: As defined by Congress in the
interim final rule (62 FR 66551): “those waters and
substrate necessary to fish for spawning, breeding,
feeding, or growth to maturity.” For the purpose of
interpreting the definition of Essential Fish Habitat,
“waters” include aquatic areas and their associated
physical, chemical, and biological properties;
“substrate” includes sediment underlying the waters;
“necessary” refers to the habitat required to support a
sustainable fishery and the managed species
contribution to a healthy ecosystem; and “spawning,
breeding, feeding, or growth to maturity” covers all
habitat types utilized by a species throughout its life
cycle.
Evapotranspiration: The sum of evaporation from
the land surface plus water loss from plants during
transpiration.
Exotic: Introduced into an area. Exotic species may
adapt to the area into which they are introduced and
compete with resident native (indigenous) species.
F
°F: Degrees Fahrenheit.
Fate: The course of a substance in an ecosystem or
biological system, including metabolism, microbial
degradation, leaching, and photodecomposition.
Fauna: The vertebrate and invertebrate animals of the
area or region.
Feasible: Capable of being accomplished in a
successful manner within a reasonable period of time,
taking into account economic, environmental, legal,
social, and technological factors.
Final Environmental Impact Statement (Final
EIS): A revision of the Draft Environmental Impact
Statement based on public and agency comments on
the draft.
Fire dependent (ecosystem): Evolving under periodic
perturbations by fire and consequently dependent on
periodic fires for normal function.
Fire return interval: The number of years between
two successive fires in a specified area.
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Fire tolerant: Able to withstand fire at a certain
frequency and intensity.
First (1 ) order dermal absorption: Absorption of a
material (herbicide) that occurs over 24 hours, taking
into consideration the potential for some herbicide to
not be absorbed.
Fisheries habitat: Streams, lakes, and reservoirs that
support fish populations.
Fishery: The act, process, occupation, or season of
taking an aquatic species. The combination of fish and
people who fish in a region.
Forage: Vegetation eaten by animals, especially
grazing and browsing animals.
Forbs: Broad-leaved plants; includes plants that
commonly are called weeds or wildflowers.
Forestland: Land where the potential natural plant
community contains 10 percent or more tree canopy
cover.
Formulation: The commercial mixture of both active
and inactive (inert) ingredients.
Fossilization: The process of fossilizing a plant or
animal that existed in some earlier age; the process of
being turned to stone.
Fragmentation (habitat): The breaking-up of a
habitat or cover type into smaller, disconnected
parcels.
Fuel (fire): Dry, dead parts of trees, shrubs, and other
vegetation that can bum readily.
G
Greenhouse Gas: Any gas that absorbs infrared
radiation within the atmosphere. These gases prevent
heat from escaping the atmosphere and regulate the
Earth’s temperature.
Groundwater: Subsurface water that is in the zone of
saturation. The top surface of the groundwater is the
“water table.” Source of water for wells, seeps, and
springs.
H
Habitat: The natural environment of a plant or animal,
including all biotic, climatic, and soil conditions, or
other environmental influences affecting living
conditions. The place where an organism lives.
Half-life: The amount of time required for half of a
compound to degrade.
Hazardous fuels: Includes living and dead and
decaying vegetation that form a special threat of
ignition and resistance to control.
Herbaceous: Non-woody plants that include grasses,
grass-like plants, and forbs.
Herbicide: A chemical pesticide used to control,
suppress, or kill vegetation, or severely interrupt
normal growth processes.
Herbicide resistance: The acquired ability of a weed
population to survive an herbicide application that
previously was known to control the population.
Herbivore: An animal that feeds on plants.
Herd Management Areas (HMAs): Areas
established for wild and free-roaming horses and
burros through the land use planning process. The
Wild Free-roaming Horse and Burro Act of 1971
requires that wild free-roaming horses and burros be
considered for management where they were found at
the time Congress passed the Act.
Home range: The area around an animal’s established
home that is visited during the animal’s normal
activities.
Hydrologic cycle (water cycle): The ecological cycle
that moves water from the air by precipitation to the
earth and returns it to the atmosphere; includes
evaporation, run-off, infiltration, percolation, storage,
and transpiration.
Hydrologic region: The highest level hydrologic unit
classification. Hydrologic regions are geographic areas
that contain either the drainage of a major river or the
combined drainage areas of a series of rivers.
Hydrolysis: Decomposition or alteration of a chemical
substance by water.
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I
Impermeable: Unable to be penetrated.
Indirect effects: Impacts that are caused by an action,
but are later in time or farther removed in distance,
although still reasonably foreseeable.
Inert (other) ingredient: Any substance or ingredient
that is added to the commercial product (formulation),
aside from the active ingredient.
Infestation: 1) The occurrence of one or more pest
species in an area or location where their numbers and
impacts are currently or potentially at intolerable
levels. 2) A sudden increase in destructiveness or
population numbers of a pest species in a given area.
Infiltration: The movement of water through soil
pores and spaces.
Insectivore: An organism that feeds mainly on insects.
Integrated Pest Management (IPM): A long¬
standing, science-based, decision-making process that
identifies and reduces risks from pests and pest
management related strategies. It coordinates the use
of pest biology, environmental information, and
available technology to prevent unacceptable levels of
pest damage by the most economical means, while
posing the least possible risk to people, property,
resources, and the environment. Integrated Pest
Management provides an effective strategy for
managing pests in all arenas from developed
agricultural, residential, and public areas to wild lands.
Integrated Pest Management serves as an umbrella to
provide an effective, all encompassing, low-risk
approach to protect resources and people from pests.
BLM Handbook H- 1740-2 ( Integrated Vegetation
Management ) defines Integrated Pest Management as
“a sustainable approach to managing pests by
combining biological, cultural, physical, and chemical
tools in a way that minimizes economic, health, and
environmental risks.”
Integrated vegetation management (IVM): A
system of controlling undesirable vegetation in which
1) undesirable vegetation within an ecosystem is
identified and action thresholds are considered, and 2)
all possible control options are evaluated and selected
controls are implemented. Control options, which
include biological, chemical, cultural, manual, and
mechanical methods, are used to prevent or remedy
unacceptable, unreliable, or unsafe conditions. Choice
of control option(s) is based on effectiveness,
environmental impact, site characteristics,
worker/public health and safety, security, and
economics. The goal of an integrated vegetation
management system is to manage vegetation and the
environment to balance benefits of control, costs, public
health, environmental quality, and regulatory
compliance.
Integrated weed management (IWM): A sustainable
approach for managing noxious weeds and other
undesirable plants that combines biological, cultural,
physical, and chemical tools in a way that minimizes
economic, health, and environmental risks. Integrated
weed management involves the use of several control
techniques in a well-planned, coordinated, and
organized program. It includes two phases: 1) inventory,
and 2) planning and implementation.
Invasive plants: Plants that 1) are not part of (if
exotic), or are a minor component of (if native), the
original plant community or communities; 2) have the
potential to become a dominant or co-dominant
species on the site if their future establishment and
growth is not actively controlled by management
interventions; or 3) are classified as exotic or noxious
plants under state or federal law. Species that become
dominant for only one to several years (e.g. short-term
response to drought or wildfire) are not invasive
plants.
Invasive species: Per Executive Order 13112, an
invasive species means an alien species whose
introduction does or is likely to cause economic or
environmental harm or harm to human health.
Invertebrate: Small animals that lack a backbone or
spinal column. Spiders, insects, and worms are
examples of invertebrates.
Irretrievable commitment: A term that applies to
losses of production or commitment of renewable
natural resources. For example, while an area is used
as a ski area, some or all of the timber production there
is “irretrievably” lost. If the ski area closes, timber
production could resume; therefore, the loss of timber
production during the time the area is devoted to
skiing is irretrievable, but not irreversible, because it is
possible for timber production to resume if the area is
no longer used as a ski area.
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Irreversible commitment: A term that applies to non¬
renewable resources, such as minerals and
archaeological sites. Losses of these resources cannot
be reversed. Irreversible effects can also refer to the
effects of actions on resources that can be renewed
only after a very long period of time, such as the loss
of soil productivity.
Issue: A matter of controversy, dispute, or general
concern over resource management activities or land
uses.
J
K
Koc: Soil organic carbon-water partition coefficient.
The ratio of the mass of a chemical that is adsorbed in
the soil per unit of mass of organic carbon in the soil
per the equilibrium chemical concentration in
solution.
L
Land management: The intentional process of
planning, organizing, programming, coordinating,
directing, and controlling land use actions.
Landscape: All the natural features such as
grasslands, hills, forest, and water, which distinguish
one part of the earth’s surface from another part;
usually that portion of land that the eye can
comprehend in a single view, including all of its
natural characteristics.
Large woody debris: Pieces of wood that are of a
large enough size to affect stream channel
morphology.
LC50: The lethal concentration required to kill 50
percent of the population.
LD50 (median lethal dose): The dose of a chemical
calculated to cause death in 50 percent of a defined
experimental animal population over a specified
observation period. The observation period is typically
14 days.
Leaching: Usually refers to the movement of
chemicals through the soil by water; may also refer to
the movement of herbicides out of leaves, stems, or
roots into the air or soil.
Level of concern (LOC): The concentration in media
or some other estimate of exposure above which there
may be effects.
Lichens: Organisms made up of specific algae and
fungi, forming identifiable crusts on soil, rocks, tree,
bark, and other surfaces. Lichens are primary
producers in ecosystems. They contribute living
material and nutrients, enrich the soil and increase soil
moisture-holding capacity, and serve as food sources
for certain animals. Lichens are slow growing and
sensitive to chemical and physical disturbances.
Lifeways: The manner and means by which a group of
people lives; their way of life. Components include
language(s), subsistence strategies, religion, economic
structure, physical mannerisms, and shared attitudes.
Litter: The uppermost layer of organic debris on the
soil surface, which is essentially the freshly fallen or
slightly decomposed vegetation material such as
stems, leaves, twigs, and fruits.
Long term/long-term: Generally refers to a period
longer than 1 0 years.
Lowest observed adverse effect level (LOAEL): The
lowest dose of a chemical in a study, or group of
studies, that produces statistically or biologically
significant increases in frequency or severity of
adverse effects between the exposed and control
populations.
M
Macrogroup: In the National Vegetation
Classification Standard, a middle-level vegetation
classification based on plant physiognomy,
biogeography, and floristics.
Material safety data sheet (MSDS): A compilation
of information required under the Occupational Safety
and Health Administration Communication Standard
on the identity of hazardous chemicals, health and
physical hazards, exposure limits, and precautions. In
2012, the Safety Data Sheet (SDS) became the new
hazardous chemical reporting system, replacing the
material safety data sheet.
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Microbial degradation: The breakdown of a chemical
substance into simpler components by bacteria or other
microorganisms.
Microbiotic crust: See biological crust.
Minimize: Apply best available technology,
management practices, and scientific knowledge to
reduce the magnitude, extent, and/or duration of
impacts.
Minimum tool (rule): Apply only the minimum-
impact policy, device, force, regulation, instrument, or
practice to bring about a desired result.
Mitigation: Steps taken to: 1) avoid an impact
altogether by not taking a certain action or parts of an
action; 2) minimize an impact by limiting the degree
or magnitude of the action and its implementation; 3)
rectify an impact by repairing, rehabilitating, or
restoring the affected environment; 4) reduce or
eliminate an impact over time by preserving and
maintaining operations during the life of the action;
and, 5) compensate for an impact by replacing or
providing substitute resources or environments (40
CFR Part 1508.20).
Mitigation measures: Actions taken to avoid,
compensate for, rectify, or reduce the potential adverse
impact of an action.
Monitoring: The orderly collection, analysis, and
interpretation of resource data to evaluate progress
toward meeting management objectives.
Multiple uses: A combination of balanced and diverse
resource uses that takes into account the long-term
needs of future generations for renewable and
nonrenewable resources. These may include
recreation, range, timber, minerals, watershed,
wildlife, and fish, along with natural scenic, scientific,
and historical values.
N
National Ambient Air Quality Standards
(NAAQS): Standards set by the U.S. Environmental
Protection Agency for the maximum levels of
pollutants that can exist in the outdoor air without
unacceptable effects on human health or the public
welfare.
National Back Country Byways: A program
developed by the BLM to complement the National
Scenic Byway program. The BLM’s Byways show
enthusiasts the best the West has to offer — from
waterfalls to geology sculpted by volcanoes, glaciers,
and rivers. Back Country Byways vary from narrow,
graded roads, passable only during a few months of the
year, to two-lane paved highways providing year-
round access.
National Conservation Areas: Areas designated by
Congress so that present and future generations of
Americans can benefit from the conservation,
protection, enhancement, use, and management of
these areas by enjoying their natural, recreational,
cultural, wildlife, aquatic, archeological,
paleontological, historical, educational, and/or
scientific resources and values.
National Environmental Policy Act (NEPA): An act
of Congress passed in 1969, declaring a national
policy to encourage productive and enjoyable harmony
between people and the environment, to promote
efforts that will prevent or eliminate damage to the
environment and the biosphere and stimulate the
health and welfare of people, and to enrich the
understanding of the ecological systems and natural
resources important to the nation, among other
purposes.
National Historic Trails: Trails established to
identify and protect historic routes; they follow as
closely as possible the original trails or routes of travel
of national historic significance.
National Landscape Conservation System (NLCS):
A single system that encompasses some of the BLM’s
premier land designations. By putting these lands into
an organized system, the BLM hopes to increase
public awareness of these areas’ scientific, cultural,
educational, ecological, and other values.
National Monument: An area designated to protect
objects of scientific and historic interest by public
proclamation of the President under the Antiquities
Act of 1906, or by the Congress for historic
landmarks, historic and prehistoric structures, or other
objects of historic or scientific interest situated upon
the public lands; designation also provides for the
management of these features and values.
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National Pollutant Discharge Elimination System
(NPDES): Refers to a USEPA permit program that
controls water pollution by regulating point sources
that discharge pollutants into waters of the United
States. In most cases, the NPDES permit program is
administered by authorized states.
National Recreation Area: An area designated by
Congress to assure the conservation and protection of
natural, scenic, historic, pastoral, and fish and wildlife
values and to provide for the enhancement of
recreational values.
National Recreation Trails: Trails established
administratively by the Secretary of the Interior to
provide for a variety of outdoor recreation uses in or
reasonably close to urban areas. They often serve as
connecting links between the National Historic Trails
and National Scenic Trails.
National Scenic Areas: Refers to the one national
scenic area managed by the BLM: The Santa Rosa
Mountains National Scenic Area in California, which
encompasses approximately 101,000 acres. This area
was designated by the Secretary of the Interior in 1990
to provide for the conservation, protection, and
enhancement of scenic, recreation, and pastoral values.
National Scenic Trails: Trails established by an Act
of Congress that are intended to provide for maximum
outdoor recreation potential and for the conservation
and enjoyment of nationally significant scenic,
historical, natural, and cultural qualities of the areas
through which these trails pass. National Scenic Trails
may be located to represent desert, marsh, grassland,
mountain, canyon, river, forest, and other areas, as
well as land forms that exhibit significant
characteristics of the physiographic regions of the
nation.
National Wild and Scenic Rivers: Rivers designated
in the National Wild and Scenic Rivers System that are
classified in one of three categories, depending on the
extent of development and accessibility along each
section. In addition to being free flowing, these rivers
and their immediate environments must possess at
least one outstandingly remarkable value: scenic,
recreational, geologic, fish and wildlife, historical,
cultural, or other similar values.
Native species: Species that historically occurred or
currently occur in a particular ecosystem and were not
introduced.
Natural community: An assemblage of organisms
indigenous to an area that is characterized by distinct
combinations of species occupying a common
ecological zone and interacting with one another.
Natural resources: Water, soil, plants and animals,
nutrients, and other resources produced by the earth’s
natural processes.
Neurotoxic: Affecting nerve cells and possibly
producing muscular, emotional, or behavioral
abnormalities, impaired or abnormal motion, and other
physiologic changes.
No action alternative: The most likely condition to
exist in the future if current management direction
were to continue unchanged.
No observed adverse effect level (NOAEL): The
exposure level at which there are no statistically or
biological significant differences in the frequency or
severity of any adverse effect in the exposed or control
populations.
Non-selective herbicide: An herbicide that is
generally toxic to plants without regard to species.
Non-target: Any plant, animal, or organism that a
method of application is not aimed at, but may
accidentally be injured by the application.
Noxious weed: Any plant designated by a federal,
state, or county government, or other governing body,
as injurious to public health, agriculture, recreation,
wildlife, or property.
Nutrient cycling: The circulation of nutrients and
elements such as carbon, phosphorous, nitrogen, and
others, among animals, plants, soils, and air.
O
Objective: A concise, time-specific statement of
measurable planned results that respond to pre-
established goals. An objective forms the basis for
further planning to define the precise steps to be taken
and the resources to be used to achieve identified
goals.
Omnivore: An animal that eats a combination of meat
and vegetation.
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Oregon and California grant lands: Public lands in
Western Oregon that were granted to the Oregon
Central Railroad companies (later the Oregon and
California Railroad Company) to aid in the
construction of railroads, but that were later forfeited
and returned to the federal government by revestment
of title.
Overgrazing: Continued heavy grazing which
exceeds the recovery capacity of the plant community
and creates a deteriorated rangeland.
Overstory: The upper canopy layer.
P
Paleontological resources: A work of nature
consisting of or containing evidence of extinct
multicellular beings. Includes those works or classes of
works of nature designated by the regulations as
paleontological resources.
Paleontology: A science dealing with the life of past
geological periods as known from fossil remains.
Particulate matter (PM): A complex mixture
consisting of varying combinations of dry solid
fragments, solid cores with liquid coatings, and small
droplets of liquid. These tiny particles vary greatly in
shape, size and chemical composition, and can be
made up of many different materials such as metals,
soot, soil, and dust.
Particulates: Solid particles or liquid droplets
suspended or carried in the air.
Pathogen: An agent such as a fungus, virus, or
bacterium that causes disease.
Payments in lieu of taxes: Payments made to counties
by the BLM to mitigate for losses to counties because
public lands cannot be taxed.
Per capita income: Total income divided by the total
population.
Perennial: A plant that lives for 2 or more years.
Permit: A revocable authorization to use public land
for a specified purpose.
Persistence: Refers to the length of time a compound,
once introduced into the environment, stays there.
Petroglyph: An image recorded on stone, usually by
prehistoric peoples, by means of carving, pecking, or
otherwise incised on natural rock surfaces.
Pictograph: A symbol that represents an object or a
concept by illustration.
pH: A measure of how acidic or alkaline (basic) a
solution is on a scale of 0 to 14 with 0 being very
acidic, 14 being very alkaline, and 7 being neutral. The
abbreviation stands for the potential of hydrogen.
Photodegradation: The photochemical transformation
of a molecule into lower molecular weight fragments,
usually in an oxidation process. This term is widely
used in the destruction (oxidation) of pollutants by
ultraviolet-based processes.
Photolysis: Chemical decomposition induced by light
or other radiant energy.
Phytotoxicity: The ability of a material such as a
pesticide or fertilizer to cause injury to plants.
Plant community: A vegetation complex, unique in
its combination of plants, which occurs in particular
locations under particular influences. A plant
community is a reflection of integrated environmental
influences on the site, such as soils, temperature,
elevation, solar radiation, slope aspect, and
precipitation.
PM2.5: Fine particulates that measure 2.5 microns in
diameter or less.
PM10: Particulate matter that measures 10 microns in
diameter or less.
Porosity: The ratio of the volume of void space in a
material (e.g., sedimentary rock or sediments) to the
volume of its mass.
Predator: An organism that captures and feeds on
parts or all of a living organism of another species.
Preferred alternative: The alternative identified in an
EIS that has been selected by the agency as the most
acceptable resolution to the problems identified in the
purpose and need.
Prescribed fire: A management ignited wildland fire
that burns under specified conditions and in a
predetermined area, and that produces the fire behavior
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GLOSSARY
and fire characteristics required to attain fire treatment
and resource management objectives.
Prevention of Significant Deterioration (PSD): A
U.S. Environmental Protection Agency program in
which state and/or federal permits are required in order
to restrict emissions from new or modified sources in
places where air quality already meets or exceeds
primary and secondary ambient air quality standards.
Productivity: The innate capacity of an environment
to support plant and animal life over time. Plant
productivity is the rate of plant production within a
given period of time. Soil productivity is the capacity
of a soil to produce plant growth, due to the soil’s
chemical, physical, and biological properties.
Programmatic EIS: An area-wide EIS that provides
an overview when a large-scale plan is being prepared
for the management of federally administered lands on
a regional or multi-regional basis.
Proper functioning condition: Riparian and wetland
areas achieve proper functioning condition when
adequate vegetation, landform, or large woody debris
is present to dissipate stream energy associated with
high water flows. This reduces erosion and improves
water quality; filters sediment, captures bedload, and
aids in floodplain development; improves floodwater
retention and groundwater recharge; develops root
masses that stabilize streambanks against cutting;
develops diverse ponding and channel characteristics
to provide habitat and water depth, duration, and
temperature necessary for fish production, avian
breeding habitat, and other uses; and supports greater
biodiversity.
Proposed action: A proposal by a federal agency to
authorize, recommend, or implement an action.
Public lands: Any land and interest in land owned by
the United States that are administered by the
Secretary of the Interior through the BLM, without
regard to how the United States acquired ownership,
except for 1) lands located on the Outer Continental
Shelf, and 2) lands held for the benefit of Indians,
Aleuts, and Eskimos. Includes public domain and
acquired lands.
Public scoping: A process whereby the public is given
the opportunity to provide oral or written comments
about the influence of a project on an individual, the
community, and/or the environment.
Q
Qualitative: Traits or characteristics that relate to
quality and cannot be readily measured with numbers.
Quantitative: Traits or characteristics that can be
measured with numbers.
R
Rangeland: Land on which the native vegetation is
predominantly grasses, grass-like plants, forbs, or
shrubs; not forests.
Raptor: Bird of prey; includes eagles, hawks, falcons,
and owls.
Receptor: An ecological entity exposed to a stressor.
Record of Decision (ROD): A document separate
from, but associated with, an EIS, which states the
decision, identifies alternatives (specifying which were
environmentally preferable), and states whether all
practicable means to avoid environmental harm from
the alternative have been adopted, and if not, why not.
Registered herbicide: All herbicides sold or
distributed in the United States must be registered by
the U.S. Environmental Protection Agency, based on
scientific studies, showing that they can be used
without posing unreasonable risks to people or the
environment.
Research Natural Areas: Special management areas
designated either by Congress or by a public or private
agency to preserve and protect typical or unusual
ecological communities, associations, phenomena,
characteristics, or natural features or processes for
scientific and educational purposes. They are
established and managed to protect ecological
processes, conserve biological diversity, and provide
opportunities for observation for research and
education.
Residue: The quantity of an herbicide or its
metabolites remaining in or on soil, water, plants,
animals, or surfaces.
Resource Management Plan: Comprehensive land
management planning document prepared by and for
the BLM’s administered properties under requirements
of the Federal Land Policy and Management Act.
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GLOSSARY
Bureau of Land Management lands in Alaska were
exempted from this requirement.
Restoration: Actions taken to modify an ecosystem to
achieve desired, healthy, and functioning conditions
and processes.
Return interval (fire): The average time between
fires in a given area.
Revegetation: Establishing or re-establishing
desirable plants on areas where desirable plants are
absent or of inadequate density, by management alone
(natural revegetation) or by seeding or transplanting
(artificial re vegetation).
Right-of-way (ROW): A permit or an easement that
authorizes the use of lands for certain specified
purposes, such as the construction of an access road or
pipeline.
Riparian: Occurring adjacent to streams and rivers
and directly influenced by water. A riparian
community is characterized by certain types of
vegetation, soils, hydrology, and fauna, and requires
free or unbound water or conditions more moist than
what is normally found in the area.
Riparian Habitat Conservation Area: A designation
made under the Pacific Anadromous Fish
Strategy/lnland Fish Strategy. A portion of a
watershed where riparian-dependent resources receive
primary emphasis and management activities are
subject to specific standards and guidelines. Includes
traditional riparian corridors, wetlands, intermittent
streams, and other areas that help maintain the
integrity of aquatic ecosystems.
Risk: The likelihood that a given exposure to an item
or substance that presents a certain hazard will produce
illness or injury.
Risk assessment: The process of gathering data and
making assumptions to estimate short- and long-term
harmful effects on human health or the environment
from particular products or activities.
Risk quotient (RQ): A value used in risk assessments
to compare toxicity to environmental exposure. The
risk quotient is calculated by dividing a point estimate
of exposure by a point estimate of effects. The risk
quotient is compared to the applicable Level of
Concern to analyze potential risk to non-target
organisms.
Runoff: That part of precipitation, as well as any other
flow contributions, that appears in surface streams,
either perennial or intermittent.
S
Safety Data Sheet (SDS): A compilation of
information required under the Occupational Safety
and Health Administration Communication Standard
on the identity of hazardous chemicals, health and
physical hazards, exposure limits, and precautions.
The SDS replaces the Material Safety Data Sheet
(MSDS).
Salmonids: Fishes of the family Salmonidae,
including salmon, trout, chars, whitefish, ciscoes, and
grayling.
Scoping: The process by which significant issues
relating to a proposal are identified for environmental
analysis. Scoping includes eliciting public comment on
the proposal, evaluating concerns, and developing
alternatives for consideration.
Section 3: Lands administered under Section 3 of the
Taylor Grazing Act. This section of the law provided
for the lease of grazing district lands to landowners
and homesteaders in or adjacent to the reserves first
and issuance of 1 to 1 0 year leases.
Section 15: Lands administered under Section 15 of
the Taylor Grazing Act. Under Section 15, public
lands outside of grazing districts could be leased to
ranchers with contiguous property.
Sediments: Unweathered geologic materials generally
laid down by or within water bodies; the rocks, sand,
mud, silt, and clay at the bottom and along the edge of
lakes, streams, and oceans.
Sedimentation: The process of forming or depositing
sediment; letting solids settle out of wastewater by
gravity during treatment.
Selective herbicide: A chemical designed to affect
only certain types of plants, leaving other plants
unharmed.
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GLOSSARY
Semi-arid: Moderately dry; region or climate where
moisture is normally greater than under arid
conditions, but still limits the production of vegetation.
Sensitive species: 1) Plant or animal species
susceptible or vulnerable to activity impacts or habitat
alterations. 2) Species that have appeared in the
Federal Register as proposed for classification or are
under consideration for official listing as endangered
or threatened species.
Short-term impacts: Impacts occurring during project
construction and operation, and normally ceasing upon
project closure and reclamation. For each resource the
definition of short-term may vary.
Significant: The description of an impact that exceeds
a certain threshold level. Requires consideration of
both context and intensity. The significance of an
action must be analyzed in several contexts, such as
society as a whole, and the affected region, interests,
and locality. Intensity refers to the severity of impacts,
which should be weighted along with the likelihood of
their occurrence.
Snag: A standing dead tree, usually larger than 5 feet
tall and 6 inches in diameter at breast height.
Socioeconomic: Pertaining to, or signifying the
combination or interaction of social and economic
factors.
Soil compaction: The compression of the soil profile
from surface pressure, resulting in reduced air space,
lower water holding capacity, and decreased plant root
penetrability.
Southern Nevada Public Land Management Act:
Act that provides for the disposal of public land within
a specific area in the Las Vegas Valley and creates a
special account into which 85 percent of the revenue
generated by land sales or exchanges in the Las Vegas
Valley is deposited. The remaining 15 percent goes to
state and local governments.
Special status species: Refers to federally listed
threatened, endangered, proposed, or candidate
species, and species managed as sensitive species by
the BLM.
Spot treatment: An application of an herbicide to a
small, selected area, as opposed to broadcast
application.
Stand: A group of trees in a specific area that is
sufficiently alike in composition, age, arrangement,
and condition so as to be distinguishable from the
forest in adjoining areas.
Standard Operating Procedures (SOPs): Procedures
followed by the BLM to minimize risks to human
health and the environment from treatment actions.
Step-down: Refers to the process of applying broad-
scale science findings and land use decisions to site-
specific areas using a hierarchical approach of
understanding current resource conditions, risks, and
opportunities.
Stressor: Any event or situation that precipitates a
change.
Subchronic: The effects observed from doses that are
of intermediate duration, usually 90 days.
Subsistence: Customary and traditional uses of wild
renewable resources (plants and animals) for food,
shelter, fuel, clothing, tools, etc.
Surfactant: A material that improves the emulsifying,
dispersing, spreading, wetting, or other surface-
modifying properties of liquids.
Surrogate: A substitute or stand-in.
Synergistic: A type of cumulative impact where total
effect is greater than the sum of the effects taken
independently.
T
Tank mixture: The mixture of two or more
compatible herbicides in a spray tank in order to apply
them simultaneously.
Target species: Plant species of competing vegetation
that is controlled in favor of desired species.
Terrestrial: Of or relating to the earth, soil, or land;
inhabiting the earth or land.
Threatened species: A plant or animal species likely
to become an endangered species throughout all or a
significant portion of its range within the foreseeable
future.
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Threshold: A level below which there is no apparent
or measurable adverse effect. .
Tier: In an E1S, refers to incorporating by reference
the analyses in an EIS or similar document of a
broader scope. For example, BLM field offices could
prepare environmental assessments for local projects
that tier to this PEIS.
Total suspended particulates (TSP): A method of
monitoring airborne particulate matter by total weight.
Toxicity: A characteristic of a substance that makes it
poisonous.
Toxicity Reference Value (TRV): A species-specific
and chemical-specific estimate of an exposure level
that is not likely to cause unacceptable adverse effects
on growth, reproduction, or survival. The three types
of toxicity reference values are dose-based,
concentration based, and tissue-based.
Tribe: Term used to designate any Indian tribe, band,
nation, or other organized group or community
(including any Alaska Native village or regional or
village corporation as defined in or established
pursuant to the Alaska Native Claims Settlement Act)
which is recognized as eligible for the special
programs and services provided by the U.S. to Indians
because of their status as Indians.
U
Understory: Plants that grow beneath the canopy of
other plants. Usually refers to grasses, forbs, and low
shrubs under a tree or shrub canopy.
Undesirable plants: Species classified as undesirable,
noxious, harmful, exotic, injurious, or poisonous under
state or federal law, but not including species listed as
endangered by the Endangered Species Act, or species
indigenous to the planning area.
Upland: The portion of the landscape above the valley
floor or stream.
V
Vascular plants: Plants that have specialized tissues
which conduct nutrients, water, and sugars along with
other specialized parts such as roots, stems, and
reproductive structures. Vascular plants include
flowering plants, ferns, shrubs, grasses, and trees.
Visual resources: The visible physical features of a
landscape.
Volatilization: The conversion of a solid or liquid into
a gas or vapor.
W
Water quality: The interaction between various
parameters that determines the usability or non¬
usability of water for on-site and downstream uses.
Major parameters that affect water quality include
temperature, turbidity, suspended sediment,
conductivity, dissolved oxygen, pH, specific ions,
discharge, and fecal coliform.
Watershed: The region draining into a river, river
system, or body of water.
Weed: A plant considered undesirable and that
interferes with management objectives for a given area
at a given point in time.
Weed-free (feed/straw/mulch/other materials):
Materials that have been inspected in the field of
origin to determine that they are free of viable noxious
weed seeds at the time of harvest. A weed-free
certification is available at the state level.
Wetlands: Those areas that are inundated or saturated
by surface water or groundwater at a frequency and
duration sufficient to support, and that under normal
circumstance do support, a prevalence of vegetation
typically adapted for life in saturated soil conditions.
Wetlands include habitats such as swamps, marshes,
fens, and wet meadows.
Wilderness: Land designated by Congress as a
component of the National Wilderness Preservation
System. For an area to be considered for Wilderness
designation it must be roadless and possess the
characteristics required by Section 2(c) of the
Wilderness Act of 1964. These characteristics are: 1)
naturalness - lands that are natural and primarily
affected by the forces of nature; 2) roadless and having
at least 5,000 acres of contiguous public lands; and 3)
outstanding opportunities for solitude or primitive and
unconfmed types of recreation. In addition, areas may
contain “supplemental values,” consisting of
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GLOSSARY
ecological, geological, or other features of scientific,
educational, scenic, or historical importance.
Wildfire: Unplanned human or naturally caused fires
in wildlands.
Wildland fires: Fires that occur on wildlands,
regardless of ignition source, damages, or benefits, and
include wildfire and prescribed fire.
Wildland Urban Interface (WUI): An area where
structures and other human development intermingle
with undeveloped wildlands or vegetative fuels.
Woodland: A forest in which the trees are often small,
characteristically short-boled relative to their crown
depth, and forming an open canopy, with the
intervening area being occupied by lower vegetation,
commonly grass.
XYZ
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CHAPTER 9
INDEX
INDEX
CHAPTER 9
INDEX
Air Quality
Description: 3-2
Effects: 4-5
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-5
Methodology for Assessing Impacts to Air Quality:
4-5
Standard Operating Procedures: 4-6
Impacts by Alternative: 4-7
Mitigation: 4-10
Cumulative Effects: 4-105
Unavoidable Effects: 4-116
Short- and Long-term Effects: 4-118
Irreversible and Irretrievable Effects: 4-121
Alternatives
Chapter 2 of the EIS is devoted to describing the
alternatives
Chapter 4 is devoted to analyzing the effects of the No
Action Alternative and alternatives B, C, and D
Development of Alternatives: 1-7
Description of the Alternatives: 2-2
Alternative A: 2-3
Alternative B: 2-4
Alternative C: 2-4
Alternative D: 2-7
Alternatives Considered but Not Analyzed Further: 2-7
Summary of Impacts by Alternatives: 2-10
See also Air Quality; Soil Resources; Water Resources
and Quality; Wetland and Riparian Areas; Fish and
Other Aquatic Organisms; Wildlife Resources;
Livestock; Wild Horses and Burros; Paleontological
and Cultural Resources; Visual Resources; Wilderness
and Special Areas; Recreation; Social and Economic
Values; and Human Health and Safety
American Indian and Alaska Native Cultural
Resources
Alaska National Interest Conservation Lands
(ANILCA) Section 810 Analysis of Subsistence
Impacts: Appendix C
See Paleontological and Cultural Resources
Anadromous Fish
See Fish and Other Aquatic Organisms
Biological Soil Crust
See Soil Resources
Climate
Description: 3-2
Consultation and Coordination
Chapter 5 of the EIS is devoted to consultation and
coordination
Description: 1-4
Coordination and Education: 2-9
Cumulative Effects
Structure of the Cumulative Effects Analysis: 4-104
Resource Protection Measures Considered in the
Cumulative Effects Analysis: 4-104
Cumulative Effects by Resources: 4-105
Unavoidable Adverse Effects: 4-115
Short- and Long-term Effects: 4-117
Irreversible and Irretrievable Effects: 4-121
Decisions to be Made
Decisions to be Made by Decisionmaker: 1-3
Demographic
See Social and Economic Values
Economic Environment
See Social and Economic Values
Ecoregions
Description: 3-1
Program Goals by Ecoregion: 4-4
Effects
Comparison of Alternatives: 2-1 1
How the Effects of the Alternatives Were Estimated:
4-1
Chapter 4 is devoted to analyzing the effects of the No
Action Alternative and alternatives B, C, and D
Environment
Chapter 3 of the EIS is devoted to a description of the
environment
Chapter 4 of the EIS is devoted to analysis of effects
on the environment
European Settlement Resources
See Paleontological and Cultural Resources
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Expenditures by the BLM
See Social and Economic Values
Fish and Other Aquatic Organisms
Description: 3-20
Special Status Species: 3-20
Effects: 4-41
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-41
Standard Operating Procedures: 4-41
Impacts Assessment Methodology: 4-42, 4-49
Summary of Herbicide Impacts: 4-44, 4-49
Impacts by Alternative: 4-47, 4-50
Special Status Fish and Other Aquatic Organisms:
4-48
Mitigation: 4-48, 4-51
Cumulative Effects: 4-108
Unavoidable Effects: 4-1 16
Short- and Long-term Effects: 4-119
Irreversible and Irretrievable Effects: 4-121
Fire
Vegetation Condition and Fire Regimes: 3-17
Greenhouse Gas Emissions
See Air Quality
Herbicides
Herbicide Active Ingredients Evaluated Under the
Proposed Alternatives: 2-1
Herbicide Formulations and Tank Mixes: 2-2
Herbicide Treatment Standard Operating Procedures:
2-7
Human Health and Safety
Description: 3-37
Effects: 4-87
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-87
Standard Operating Procedures: 4-87
Human Health Risk Assessment Methodology:
4-88
Human Health Risks Associated with Herbicides:
4-89
Impacts by Alternative: 4-102
Mitigation: 4-103
Cumulative Effects: 4-115
Unavoidable Effects: 4-117
Short- and Long-term Effects: 4-120
Irreversible and Irretrievable Effects: 4-123
Impacts
See Alternatives and Cumulative Effects
Important Plant Uses and Species Used by
American Indians and Alaska Natives
See Paleontological and Cultural Resources
Issues and Concerns
Issues and Concerns (scoping): 1-6
Issues Not Addressed: 1-7
Land Use
Description: 3-1
Effects: 4-4
Livestock
Description: 3-21
Effects: 4-64
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-64
Standard Operating Procedures: 4-64
Impacts Assessment Methodology: 4-64
Summary of Herbicide Impacts: 4-65
Impacts by Alternative: 4-67
Mitigation: 4-68
Cumulative Effects: 4-110
Unavoidable Effects: 4-116
Short- and Long-term Effects: 4-119
Irreversible and Irretrievable Effects: 4-122
Mitigation
Description: 2-9
See also Air Quality; Soil Resources; Water Resources
and Quality; Wetland and Riparian Areas; Fish and
Other Aquatic Organisms; Wildlife Resources;
Livestock; Wild Horses and Burros; Paleontological
and Cultural Resources; Visual Resources; Wilderness
and Special Areas; Recreation; Social and Economic
Values; and Human Health and Safety
Native Peoples
See Social and Economic Values; Paleontological and
Cultural Resources; and Cumulative Effects
Non-timber Forest Products
Description: 3-19
Noxious Weeds and Other Invasive Vegetation
Description: 3-17
Paleontological and Cultural Resources
Description: 3-22
Effects: 4-7 1
Scoping Comments and Other Issues Evaluated the
in Assessment: 4-71
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INDEX
Paleontological and Cultural Resources (cont.)
Effects (cont.)
Standard Operating Procedures: 4-7 1
Summary of Herbicide Impacts: 4-72
Herbicide Impacts on Native American Health: 4-
73
Impacts by Alternative: 4-74
Mitigation: 4-75
Cumulative Effects: 4-111
Unavoidable Effects: 4-117
Short- and Long-term Effects: 4-119
Irreversible Effects: 4-122
Public Involvement
Public Scoping Meetings: 1-6
Public Review and Comment on the Draft
Programmatic EIS: 1-7
Public Involvement: 5-1
Purpose and Need for the Proposed Action
Proposed Action: 1-1
Purpose and Need: 1-2
Recreation
Description: 3-28
Effects: 4-80
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-80
Standard Operating Procedures: 4-80
Summary of Herbicide Impacts: 4-80
Impacts by Alternative: 4-81
Mitigation: 4-82
Cumulative Effects: 4-113
Unavoidable Effects: 4-117
Short- and Long-term Effects: 4-120
Irreversible Effects: 4-122
Revenues Generated by BLM Lands
See Social and Economic Values
Riparian Areas
See Wetlands and Riparian Areas
Rights-of-way
Description: 3-29
Risk from Cancer, Disease, Injuries, or Using
Herbicides on Public Lands
See Human Health and Safety
Scoping
Scope of Analysis: 1-2
Public Involvement and Analysis of Issues: 1-6, 5-1
Social and Economic Values
Description: 3-29
Effects: 4-82
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-82
Standard Operating Procedures: 4-82
Impact Assessment Assumptions: 4-83
Summary of Herbicide Impacts: 4-83
Impacts by Alternative: 4-84
Mitigation: 4-87
Cumulative Effects: 4-114
Unavoidable Effects: 4-117
Short- and Long-term Effects: 4-120
Irreversible Effects: 4-123
Soil Compaction
See Soil Resources
Soil Erosion
See Soil Resources
Soil Resources
Description: 3-6
Effects: 4-9
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-10
Standard Operating Procedures: 4-10
Factors that Influence the Fate, Transport, and
Persistence of Herbicides in Soil: 4-10
Summary of Herbicide Impacts: 4-1 1
Impacts by Alternative: 4-13
Mitigation: 4-14
Cumulative Effects: 4-106
Unavoidable Effects: 4-116
Short- and Long-term Effects: 4-118
Irreversible Effects: 4-121
Special Status Species
See Fish and Other Aquatic Resources
See Vegetation
See Wildlife Resources
Species
Common and Scientific Names of Species:
Appendix A
Special Status Species List: Appendix E
Statues, Regulations, and Policies
Relationship to Statutes, Regulations, and Policies: 1-3
Stipulations and Required Operating Procedures
Herbicide Treatment Standard Operating Procedures
and Guidelines: 2-7
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INDEX
Stipulations and Required Operating Procedures
(cont.)
Monitoring: 2-9
See also Air Quality; Soil Resources; Water Resources
and Quality; Wetland and Riparian Areas; Fish and
Other Aquatic Organisms; Wildlife Resources;
Livestock; Wild Horses and Burros; Paleontological
and Cultural Resources; Visual Resources; Wilderness
and Special Areas; Recreation; Social and Economic
Values; and Human Health and Safety
Threatened and Endangered Species
Consultation: Chapter 5
List of Special Status Species: Appendix E
Topography, Geology, Minerals, Oil, and Gas
Description: 3-6
Vegetation
Monitoring: 2-9
Description: 3-1 1
Special Status Species: 3-19
Effects: 4-25
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-25
Standard Operating Procedures: 4-25
Impacts Assessment Methodology: 4-26, 4-38
Summary of Herbicide Impacts: 4-27, 4-38
Impacts by Ecoregion: 4-33
Impacts by Alternative: 4-33, 4-39
Special Status Plant Species: 4-38
Mitigation: 4-38, 4-41
Cumulative Effects: 4-108
Unavoidable Effects: 4-116
Short- and Long-term Effects: 4-118
Irreversible and Irretrievable Effects: 4-121
Vegetation Condition and Fire Regimes
Description: 3-17
Visual Resources
Description: 3-25
Effects: 4-75
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-75
Standard Operating Procedures: 4-75
BLM Assessment of Visual Resource Values: 4-76
Summary of Herbicide Impacts: 4-76
Impacts by Alternative: 4-76
Mitigation: 4-77
Cumulative Effects: 4-112
Unavoidable Effects: 4-117
Short- and Long-term Effects: 4-120
Irreversible and Irretrievable Effects: 4-122
Water Resources and Quality
Water Resources Description: 3-8
Water Quality Description: 3-9
Effects: 4-14
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-14
Standard Operating Procedures: 4-14
Summary of Herbicide Impacts: 4-15
Impacts by Alternative: 4-19
Mitigation: 4-20
Cumulative Effects: 4-106
Unavoidable Effects: 4-116
Short- and Long-term Effects: 4-118
Irreversible and Irretrievable Effects: 4-121
Wetland and Riparian Areas
Description: 3-10
Effects: 4-21
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-21
Factors that Influence the Fate, Transport, and
Persistence of Herbicides in Wetlands and Riparian
Areas: 4-21
Methodology for Assessing Impacts to Wetland
and Riparian Areas: 4-21
Summary of Herbicide Impacts: 4-22
Impacts by Alternative: 4-24
Mitigation: 4-25
Cumulative Effects: 4-107
Unavoidable Effects: 4-116
Short- and Long-term Effects: 4-118
Irreversible and Irretrievable Effects: 4-121
Wild Horses and Burros
Description: 3-22
Effects: 4-68
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-68
Standard Operating Procedures: 4-68
Impacts Assessment Methodology: 4-68
Summary of Herbicide Impacts: 4-68
Impacts by Alternative: 4-69
Mitigation: 4-71
Cumulative Effects: 4-111
Unavoidable Effects: 4-116
Short- and Long-term Effects: 4-119
Irreversible Effects: 4-122
Wilderness and Other Special Areas
Description: 3-26
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January 2016
INDEX
Wilderness and Special Areas (cont.)
Effects: 4-77
Scoping Comments and Other Issues Addressed in
the Assessment: 4-78
Standard Operating Procedures: 4-78
Summary of Herbicide Impacts: 4-78
Impacts by Alternative: 4-79
Mitigation: 4-80
Cumulative Effects: 4-112
Unavoidable Effects: 4-117
Short- and Long-term Effects: 4-120
Irreversible and Irretrievable Effects: 4-122
See also Recreation Resources
See also Visual Resources
Wildlife Resources
Description: 3-20
Special Status Species: 3-21
Effects: 4-5 1
Scoping Comments and Other Issues Evaluated in
the Assessment: 4-52
Standard Operating Procedures: 4-52
Impacts Assessment Methodology: 4-53, 4-61
Summary of Herbicide Impacts: 4-54, 4-61
Impacts of Herbicide Treatments on Wildlife and
Habitat by Ecoregion: 4-57
Impacts by Alternative: 4-59, 4-61
Mitigation: 4-60, 4-63
Special Status Wildlife Species: 4-60
Cumulative Effects: 4-109
Unavoidable Effects: 4-116
Short- and Long-term Effects: 4-119
Irreversible and Irretrievable Effects: 4-121
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January 2016
APPENDIX A
COMMON AND SCIENTIFIC NAMES OF
PLANTS AND ANIMALS GIVEN IN THE
PROGRAMMATIC EIS
SCIENTIFIC NAMES OF PLANTS AND ANIMALS
APPENDIX A
COMMON AND SCIENTIFIC NAMES OF
PLANTS AND ANIMALS GIVEN IN THE
PROGRAMMATIC EIS
This appendix contains a list of the common and scientific names of plant and animal species mentioned in the text
of the PEIS. Naming conventions for plants generally follow the USDA Natural Resources Conservation Service
PLANTS Database (http://plants.usda.gov/iava/), except in cases where a more widely used common name has
been used for clarity.
Common Name
Scientific Name
PLANTS
Grasses
Blue grass
Poa spp.
Blue grass, Kentucky
Poa pratensis
Bluestem, big
Andropogon gerardii
Brome, field
Bromus arvensis
Brome, Japanese
Bromus japonicus
Brome, red
Bromus rubens
Brome, smooth
Bromus inermis
Brome, soft
Bromus hordaceous
Buffalograss
Buchloe dactyloides
Buffelgrass
Pennisetum ciliare
Canarygrass, reed
Phalaris arundinacea
Cheatgrass (downy brome)
Bromus tectorum
Fescue, Idaho
Festuca idahoensis
Grama, blue
Bouteloua gracilis
Grass, Mediterranean
Schismus barbatus
Needlegrass, green
Nassella viridula
Reed, common
Phragmites australis
Reed, giant
Arundo donax
Ricegrass, Indian
Achnatherum hymenoides
Rye, medusahead
Taeniatherum caput-medusae
Sweetgrass
Hierochloe spp.
Wheatgrass, bluebunch
Pseudoroegneria spicata
Wheatgrass, western
Pascopyrum smithii
Forbs and Nonvascular Plants
Alfalfa
Medic ago spp.
Algae, blue-green
Cyanobacteria
Algae, brown
Phaeophyceae
Algae, green
Chlorophyta
Cattail
Typha spp.
Cress, hoary
Cardaria draba
Ginseng
Eleutherococcus pentaphyllus
Goldenseal
Hydrastis canadensis
Halogeton
Halogeton glomeratus
Henbane, black
Hyoscyamus niger
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SCIENTIFIC NAMES OF PLANTS AND ANIMALS
Common Name
Scientific Name
PLANTS (Cont.)
Knapweed
Centaurea spp.
Knapweed, diffuse
Centaurea diffusa
Knotweed, Japanese
Polvgonum cuspidatum
Knapweed, Russian
Acroptilon repens
Knapweed, spotted
Centaurea stoebe or Centaurea biebersteinii
Knapweed, squarrose
Centaurea virgata
Kochia
Kochia scoparia or Bassia scoparia
Kochia, forage
Bassia prostrata
Liverworts
Members of the Marchantiopsida class
Loosestrife, purple
Lythrum salicaria
Marestail (horseweed)
Conyza canadensis
Moss
Various species
Mustard
Brassicaceae
Pepperweed, perennial
Lepidium latifolium
Plantain
Plant ago spp.
Ragwort, tansy
Senecio jacobaea
Salvinia, giant
Salvinia molesta ( S . auriculata, S. biloba, S.
herzogii )
Skeletonweed, rush
Chondrilla juncea
Snakeweed
Gutierrezia spp.
Spurge, leafy
Euphorbia esula
Starthistle, Maltese
Centaurea melitensis
Starthistle, yellow
Centaurea solstitialis
Sweetclover
Melilotus officinalis
Thistle, bull
Cirsium vulgare
Thistle, Canada
Cirsium arvense
Thistle, Italian
Carduus pycnocephalus
Thistle, musk
Carduus nutans
Thistle, plumeless
Carduus spp.
Thistle, Russian
Salsola kali
Thistle, Scotch
Onopordum acanthium
Toadflax, Dalmation
Linaria dalmatica
Toadflax, yellow
Linaria vulgaris
Tobacco
Nicotiana spp.
Trefoil, bird’s-foot
Lotus corniculatus
Vetch, bird
Vicia cracca
Water- thyme
Hydrilla verticillata
Waterlily
Nymphaea spp.
Watermilfoil, Eurasian
Myriophyllum spicatum
Woad, Dyer’s
Isatis tinctoria
Shrubs and Trees
Cholla, tree
Opuntia imbricata
Creosote bush
Larrea tridentata
Douglas-fir
Pseudotsuga menziesii
Fir, balsam
Abies balsamea
Juniper
Juniperus spp.
Juniper, oneseed
Juniperus monosperma
Juniper, Utah
Juniperus osteosperma
Juniper, western
Juniperus occidentalis
Mesquite
Prosopis spp.
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January 2016
SCIENTIFIC NAMES OF PLANTS AND ANIMALS
Common Name
Scientific Name
PLANTS (Cont.)
Mesquite, honey
Prosopis glandulosa
Mesquite, velvet
Prosopis velutina
Mormon tea
Ephedra viridis
Mountain mahogany, alderleaf
Cercocarpus montanus
Oak, Gambel
Quercus gambelii
Oak, scrub
Quercus dumosa
Olive, Russian
Elaeagnus angustifolia
Paloverde
Parkinsonia spp.
Pine, Jeffrey
Pinus jeffreyi
Pine, ponderosa
Pinus ponderosa
Pinyon
Pinus edulis
Pinyon, Singleleaf
Pinus monophylla
Pinyon, twoneedle
Pinus edulis
Pricklypear
Opuntia spp.
Rabbitbrush
Chrysothamnus spp. and Ericameria spp.
Sagebrush
Artemisia spp.
Sagebrush, basin big
Artemisia tridentata ssp. tridentata
Sagebrush, Wyoming big
Artemisia tridentata ssp. wvomingensis
Salal
Gaultheria shallon
Saltcedar (tamarisk)
Tamarix ramosissima
Sassafras
Sassafras albidum
Serviceberry, Utah
Amelanchier utahensis
Tamarisk
Tamarix spp.
Yew
Taxus spp.
Yucca
Yucca spp.
INVERTEBRATES
Earthworm
Oligochaeta spp.
FISH
Salmon
Oncorhynchus spp.
BIRDS
Bobwhite, northern
Colinus virginianus
Dove
Various genera and species
Plover, mountain
Charadius montanus
Prairie-chicken, lesser
Tympanuchus pallidicinctus
Quail, mountain
Oreortyx pictus
Robin, American
Turdus americanus
Sage-grouse
Centrocercus spp.
MAM
MALS
Bison, American
Bison bison
Burro
Equus asinus
Cottontail
Sylvilagus spp.
Cougar
Puma concolor
Coyote
Can is latrans
Deer
Odocoileus spp.
Deer, mule
Odocoileus hemionus
Deer, white-tailed
Odocoileus virginianus
Elk
Cervus elaphus
Goat (domestic)
Capra hi reus
Horse
Equus caballus
Jackrabbit
Lepus spp.
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January 2016
SCIENTIFIC NAMES OF PLANTS AND ANIMALS
Common Name
Scientific Name
MA
MMALS (Cont.)
Peccary, collared
Tayassu tajacu
Prairie dog
Cynomys spp.
Pronghorn
Antilocapra americana
Sheep (domestic)
Ovis aries
Wolf
Can is lupus
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January 2016
APPENDIX B
TRIBAL AND AGENCY CONSULTATION
TRIBAL CONSULTATION
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Washington, D.C. 20240
http://www.blm.gov
APR 1 8 2013
In Reply Refer To:
1793 (220)
Dear Tribal Leader:
The Bureau of Land Management (BLM) would like to extend an invitation to you for
Government-to-Government consultation to exchange information on the proposed use of three
new herbicides to treat vegetation on BLM-administered lands. We are currently preparing a
Programmatic Environmental Impact Statement (PEIS) on this proposed action.
This letter includes information about the three new herbicides and how they would be used, if
approved. It also briefly discusses the risks and possible impacts associated with using them. A
“Frequently Asked Questions” sheet and a map of the potentially affected areas are attached to
this letter to provide further information about the project.
Herbicides are one part of a larger vegetation treatment program that has a goal of conserving
and restoring native vegetation, watersheds, and fish and wildlife habitat. As you may know, in
2007 the BLM completed a PEIS that discussed possible impacts to plants, fish, wildlife, and
other resources from the use of 1 8 different herbicides to control unwanted vegetation. The
document considered paleontological resources, cultural resources, subsistence resources, and
the health of Native Americans that may be exposed to these herbicides.
http://www.blm.gov/wo/st/en/prog/more/veg eis.html
The BLM has recently decided that it would like to use three additional herbicides to treat
vegetation. These chemicals are aminopyralid, fluroxypyr, and rimsulfuron. A new PEIS is
being prepared to discuss the possible impacts of using these three to treat vegetation.
Aminopyralid is a reduced-risk herbicide that controls numerous weed species, including
mustard species, knapweeds, starthistles, and thistles. It also can help control cheatgrass, also
known as downy brome. Aminopyralid is registered under the U.S. Environmental Protection
Agency’s reduced risk initiative, indicating that it poses less risk to human health and the
environment than other herbicides. Aminopyralid may be used instead of picloram in certain
BLM treatment projects.
Fluroxypyr is used to control annual and perennial broad-leaved weeds (such as marestail and
cocklebur), and can be used to control weeds while maintaining grass forage species. The BLM
has indicated that this herbicide can help reduce the amount of other herbicide products used in
treatments. It can also be tank-mixed with other herbicides to improve their effectiveness.
2
Rimsulfuron is used to control winter annual grasses. The BLM has identified rimsulfuron as a
useful addition to its list of herbicides because of its effectiveness against cheatgrass and
medusahead rye, if the treated site is rested from livestock grazing for a year to allow desirable
species to become established. Rimsulfuron has been observed to be more effective than
imazapic in certain areas.
An assessment of the risks to humans, terrestrial wildlife, aquatic species, and non-target plants
from using these chemicals has been completed. Based on the results of these assessments,
aminopyralid, fluroxypyr, and rimsulfuron are relatively low risk chemicals. They do not pose
unacceptable health risks to humans under exposure scenarios involving contact with treated
plant materials or water, or ingestion of treated water, berries, or fish. The herbicides pose low
risks to terrestrial wildlife and aquatic species, but can impact non-target plants under various
scenarios.
Vegetation treatments with the three new herbicides could occur anywhere on BLM-
administered lands in Alaska, Arizona, California, Colorado, Idaho, Kansas, Montana, Nebraska,
Nevada, New Mexico, North Dakota, Oklahoma, Oregon, South Dakota, Utah, Washington, and
Wyoming (see attached map). This is approximately the same area that was considered in the
2007 PEIS.
The BLM recently completed public scoping and is in the process of reviewing the comments
that were received and identifying alternatives to the proposed action. It is anticipated that a
Draft PEIS will be completed this summer.
The BLM appreciates our relationship and will continue to consult with you throughout the PEIS
process, and as more specific treatment projects in your geographic area are developed and
implemented. We will continue to keep you informed, and are always open to any feedback you
may have. In the meantime, we hope to hear from you during the PEIS process through one of
the many avenues available for communication with us, including a written or telephone
response to this letter, or through contact with the local BLM field or state office. We are
particularly interested in three issues: 1) specific concerns that you have about the use of
aminopyralid, fluroxypyr, and rimsulfuron on public lands; 2) potential impacts on subsistence
plants and animals, and on traditional cultural properties; and 3) potential impacts on resources
associated with reserved rights under treaty, where they exist. Please let us know whether you
would like to provide information and if you would like to receive review copies of the
documents that we produce.
3
Thank you for your participation in the PEIS process. We look forward to exchanging
information with you about the proposed project. If submitting written comments, please send
your comments to Stuart Paulus, AECOM Project Manager, 710 Second Avenue, Suite 1000,
Seattle, WA 98104. If you have any questions or concerns, or would like additional information,
please feel free to call the PEIS Team Leader, Gina Ramos, at (202) 912-7226
Assistant Director
Renewable Resources and Planning
Enclosures
BUREAU OF LAND MANAGEMENT
VEGETATION TREATMENTS PROGRAMMATIC EIS FOR USE OF THREE
NEW HERBICIDES ON PUBLIC LANDS IN THE WESTERN U.S., INCLUDING ALASKA
FREQUENTLY ASKED QUESTIONS
Q. What is the Bureau of Land Management (BLM) proposing to do?
A. The BLM is proposing to prepare a programmatic Environmental Impact
Statement (PEIS) to evaluate the viability of using aminopyralid, fluroxypyr, and
rimsulfuron herbicides as part of BLM vegetation treatment programs. The new EIS
will comply with National Environmental Policy Act (NEPA) regulations. In 2007,
the BLM prepared the Vegetation Treatments Using Herbicides on Bureau of Land
Management Lands in 1 7 Western States Programmatic Environmental Impact
Statement (17-States PEIS). Under the Record of Decision for the 17-States PEIS,
the BLM is allowed to use 18 herbicides. If approved for use, up to three new
herbicides will join the list of ElS-approved herbicides currently in use on BLM
lands. The purpose of vegetation treatment programs includes the conservation and restoration of
vegetation, Fish, and wildlife habitat; improvement of watershed functions; fuels and fire management;
invasive and noxious weeds management; and soil stabilization.
^uch 3 A*
NATIONAL SYSTEM OF PUBLIC LANDS
Q. Where would the proposed actions occur?
A. If approved, the new herbicides could be utilized on public lands administered by the BLM in the
western U.S. and Alaska. The majority of these lands are in Alaska, Arizona, California, Colorado, Idaho,
Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming. Field offices and personnel
would not be required to use the three herbicides unless they deem it appropriate.
Q. Will the EIS include National Monuments and National Conservation Areas?
A. Yes, since the 2007 17-States PEIS included these lands in its analysis. These units are already
included as part of the broad programmatic treatment area to the extent that conservation and restoration
project work, including invasive and noxious weed treatments, are allowed by the individual National
Landscape Conservation System proclamations.
EIS Development Process
Q. Why is the BLM developing this programmatic EIS?
A. The BLM is preparing a programmatic EIS to evaluate the potential for use of three new herbicides for
the conservation and restoration of vegetation, watershed functions, and fish and wildlife habitat on surface
lands administered by the BLM in the western U.S., including Alaska.
1
BLM Vegetation Treatments EIS
Q. Is this EIS a land-use plan?
A. No, this EIS is not a land-use plan. The scope of this EIS is restricted to assessing the viability of
incorporating treatments with the three new herbicides into existing vegetation treatment strategies.
Q. What is the difference between a programmatic EIS and project-specific EIS?
A. A programmatic EIS is designed to look at the broad, general impacts associated with a decision to
fully implement a program or additional treatment. A programmatic EIS also allows for the tiering of more
site-specific NEPA documents, such as land-use plans, eliminating the need for repetitive discussions of the
same issues. A project-specific EIS looks at impacts associated with a site-specific project, such as
vegetation treatment activities on 1,000 acres of BLM-administered lands.
Q. Who is developing the EIS?
A. The BLM Office of Forest, Range, Riparian and Plant Conservation in Washington, D.C., is leading
the project, supported by BLM technical resource specialists in BLM offices throughout the western U.S.
and Alaska.
Q. How much has been done so far, and what is the next step?
A. The Notice of Intent to develop the EIS was published in the Federal Register on Friday, December 21,
2012, and a news release was distributed to the media, interested groups, and state agencies by the BLM at
the same time. The schedule for scoping meetings was also published in the Federal Register, and this
“Questions and Answers” information sheet was made available through the BLM website at
www.blm.Rov/3kvd. Three public scoping meetings will be held throughout the western U.S. in January
2013 during the 60 day public scoping process.
Potential Issues to Be Examined in the EIS
Q. Does this EIS involve controversial issues?
A. It is anticipated that most public scrutiny will focus on issues associated with the use of new herbicides
to control noxious weeds and other vegetation. Specific issues to be addressed in the EIS include the effects
of the three new herbicides on human and environmental health, on threatened and endangered species, and
on resources used by Native Americans and Alaska Native groups.
2
BLM Vegetation Treatments EIS
Q. Will there be an assessment of risks to the public and the environment from the use of herbicides?
A. Ecological and human health risk assessments were done to determine the likely risks to humans,
plants, and fish and wildlife from the treatments involving the three new herbicides proposed for use by the
BLM. The EIS will not evaluate the risks from herbicides presently being used by the BLM, which have
already been evaluated in the earlier EISs, unless new information has become available to suggest that
these herbicides require further evaluation.
Q. Will there be a process developed to determine which new chemicals the BLM can use to control
vegetation?
A. The 2007 17-States PEIS already includes protocols that the BLM follows to evaluate new chemicals
that may be developed in the future, prior to their use by the agency. New herbicides could only be used if
they are: (1) registered for use by the EPA; (2) used for treatment of appropriate vegetation types and at
application rates specified on the label directions; and (3) determined by the BLM to be safe to humans and
the environment, based on an analysis of their potential toxicological and environmental impacts.
Public Involvement
Q. When will the public be able to make comments on the project?
A. NEPA regulations require federal agencies to seek public input during development of the EIS. The
public will have several opportunities to discuss this project with the BLM and to make comments by:
1 . Attending any of the scoping meetings listed in the table below:
Location
Date
Meeting
Time
Worland Field Office,
101 South 23rd, Worland, WY
(307) 347-5100
January 7, 2013
7 pm local
Hyatt Place Reno Airport, 1790
East Plumb Lane,
Reno, NV (775) 826-2500
January 9, 2013
7 pm local
Albuquerque District Office, 435
Montano Road NE,
Albuquerque, NM
(505) 761-8700
January 10, 2013
7 pm local
3
BLM Vegetation Treatments EIS
2. Submitting comments on issues identified in the scoping process within 60 days of the Federal
Register’s Notice of Intent published on December 21, 2012. The closing date for submission of
comments is February 19, 2013.
3. Submitting comments during additional public comment periods associated with the Draft EIS and
Final EIS.
Q. How can the public comment on the program?
A. The public can provide formal comments to the court reporter who will be available during each
scoping meeting. Forms to submit written comments will also be available during scoping meetings, and at
local BLM offices, and may be turned in to the BLM at the scoping meeting or local office. These forms
can also be emailed to VegEIS@blm.gov.
Q. What will be done with these comments?
A. The comments will be compiled and summarized by major resource areas and issues in a scoping
summary report. Public comments and the scoping summary report will be used to evaluate issues and
concerns associated with the proposed program, and to develop alternative programs to treat vegetation
using the new herbicides on BLM-administered lands. The scoping summary report will be made available
to the public in late spring.
Q. How can I find out more information and follow the progress of the new EIS?
A. Interested individuals can visit http://www.blm.gov/wo/st/en/prog/more/vegeis.html
for regular updates on the EIS process. The website will be available throughout the public scoping
process.
4
Chickaloon Village Traditional Council
(Nay’dini’aa Na’)
October 30, 2013
Chief Gary Harrison,
Chairman
Rick Harrison,
Vice-Chairman
Penny Westing,
Secretary/Elder
Albert Harrison,
Treasurer/Elder
Burt Shaginoff,
Elder Member
Doug Wade,
Elder Member
Larry W ade,
Elder Member
Shawn a Larson,
Member
Lisa Wade,
Member
Edwin L. Roberson
Assistant Director
Renewable Resources and Planning
U.S. Department of the Interior
Bureau of Land Management
Dear Mr. Roberson,
Jennifer Harrison,
Executive Director
Thank you for the invitation to initiate government-to-government consultation
concerning the proposed use of three new herbicides to treat vegetation on BLM-
administered lands. Although this letter serves as a beginning to a government-to-
government consultation, we must emphasize that this correspondence does not fulfill
your obligation to consult and engage fully and in person with the Chickaloon Village
Traditional Council prior to and regarding any decisions about the use of herbicides on
BLM-administered lands, lands traditionally used by our Tribal Citizens.
Background and Short History
Chickaloon Native Village is a vibrant, innovative, and culturally rich Ahtna Athabascan
Tribe based in Sutton in south-central Alaska. As a response to the environmental and
social injustice suffered by Chickaloon Village Tribal Citizens, coupled with the passing of
the Alaska Native Claims and Settlement Act (ANCSA) of 1971, our Elders re-established
the Chickaloon Village Traditional Council (CVTC) in 1973, to reassert the Tribe's identity,
cultural traditions, economic self-sufficiency and to reunify our citizens. The mandate for
the Council was: To restore our traditional worldview by rejuvenating our traditional
Athabascan culture, values, oral traditions, spirituality, language, songs, and dance.
Chickaloon Native Village gained federal recognition in 1973 and on November 24, 1982,
according to Federal Register Vol. 58, No. 202. We are governed by a nine-member
Traditional Council (CVTC), tasked to reassert the Tribes identity and cultural traditions,
and create economic self-sufficiency for the Tribe. It is the vision of our Tribe's Land Use
Committee to have land, water and air that is cleaner and healthier than it is today, to
sustain our community's life needs, balancing stewardship of the natural world and
economic development for our current and future generations. It is our mission to
educate, guide, advocate for and develop policy that protects the integrity of natural
habitats while supporting development that respects ecological limits.
Findings Concerning the Proposed Use of New Herbicides
Chickaloon Village Traditional Council exercises powers of self-government by reason of
its original tribal sovereignty as passed down from our ancestors since time immemorial
with a responsibility to protect the health and well-being of our Tribal Citizens. The
Council has responsibility to prevent contamination that may harm present or future
-R&P-M20O p.o. BOX 1 105 Chickaloon, Alaska 99674 Phone (907) 745-0707 Fax (907) 745-0709
e email: cvadmin@chickaloon.org Home Page: http://www.chickaloon.org
NOV \ $
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generations and to ensure that we pass on a world with water that is pure to drink, as
well as lands and waters that support our customary and traditional way of life. Our
Chickaloon Tribal Citizens depend on the harvest of berries, medicinal plants, fish and
wildlife for our spiritual, cultural and physical sustenance. We depend on the lands and
waters of the watersheds in our region for the safe harvest of our traditional subsistence
foods. The people of the Native Village of Chickaloon are concerned about the proposed
use of any herbicides, including the proposed new herbicides by the BLM and potential
harm to our health. Herbicide applications are designed to destroy the growth of plant
life and are toxic to the environment because they adversely affect non-target plants,
animals, and people. The use of herbicides, including aminopyralid, fluroxypyr, and
rimsulfuron, will have detrimental effects to non-target plants, wildlife and people.
Herbicide chemical treatments will have a detrimental effect on the lands, waters, and
air as well as fish and wildlife resources that Native people rely on for hunting, fishing,
and gathering for their daily food. These herbicides may harm the health of the Native
people who use our traditional land* and waters. The use of herbicides violates Article 29
of the United Nations Declaration on the Rights of Indigenous Peoples to ensure that
disposal of hazardous materials shall not take place in the lands and territories of our
Indigenous peoples without their free, prior and informed consent. We believe that there
are effective and viable alternatives to the use of herbicides for vegetation management.
The Chickaloon Village Traditional Council finds as a matter of tribal policy that the use of
herbicides is detrimental to land, waters, and air resources as well as fish and wildlife
that Alaska Native people use in our daily lives and that the use of herbicides will have a
detrimental effects on the health of our people. Therefore, our Council opposes the use
of herbicides for vegetation management and calls upon BLM to adopt a policy of
prohibiting the use of herbicides. We find that BLM does not provide justification for the
use of the proposed new herbicides nor does the agency discuss non-chemical
vegetation management options.
There is very little information or studies available in the open scientific and peer-
reviewed literature on the ecological and human health consequences of the use of
aminopyralid because it is a relatively new pesticide. What little information exists is
based almost exclusively on studies submitted to the U.S. EPA by the chemical
corporation Dow AgroSciences in support of the registration of aminopyralid. Non-target
plants, particularly dicots (broadleaf plants) are sensitive to the herbicide and will be
adversely affected by applications of aminopyralid1. Studies have shown that exposure of
non-target plants to aminopyralid causes damage including deformed leaves and stems,
as well as reduced fruit production at low concentrations2. It is quite persistent in soils,
with demonstrated half-lives of 32-533 days. Compost and manure contaminated with
residues of aminopyralid causes damage to and economic losses of crops on which the
compost or manure have been applied. Research also show that aminopyralid altered
native plant communities3. In a study of the effects of aminopyralid, crops were injured
by the herbicide at soil concentrations less than the limit of quantitation (0.2 pg kg (-1)4.
Developmental studies involving gavage administration in adult female rabbits
documented signs of incoordination upon exposure. In the rabbit study, developmental
toxicity was shown by a decrease in fetal body weights. Effects on the nervous system are
not well documented. "It seems reasonable to assume the most sensitive effects in
wildlife mammalian species will be the same as those in experimental mammals (e.g.,
changes in the gastrointestinal tract, weight loss, and incoordination)."5 EPA issued a
P. O. BOX 1105 Chickaloon, Alaska 99674
e mail: cvadmin@chickaloon.org
Phone (907) 745-0707 Fax (907) 745-0709
Home Page: http://www.chickaloon.org
conditional registration for aminopyralid in 2005 and it is not scheduled for review until
2020. It should not be categorized by BLM as a "reduced risk" herbicide because its
evaluation is incomplete. To our knowledge, there have not been studies of this herbicide
on subsistence resources, including medicinal plants, herbs, berry plants, fish or wildlife,
particularly in our traditional use areas. It is likely that aminopyralid is more persistent in
our colder environment and may cause more damage to northern species and
ecosystems. For the other two herbicides, fluroxypyr and rimsulferon, we find that there
is also insufficient information in the peer-reviewed literature with which to make
reasoned assessments concerning the ecological and human health implications of their
use. Therefore, we are opposed to their use as a precautionary measure.
Non-chemical methods exist that are effective and economical. New technologies and
products have been developed that provide safe, economical alternatives to the use of
herbicides. For example, the provincial government of British Columbia recommends
the use of ecological vegetation management rather than the use of herbicides. The
government's Integrated Pest Management Program notes that "repeated herbicide
applications to keep sites bare, such as around electrical substations, along a fence lines
or railroad tracks, will encourage the growth of weeds. The herbicides create a
disturbance, both in the vegetation, and, depending on the herbicide, in the soil-which
then encourages weed invasion. This disturbance is not limited to the area of application,
but may be felt in the vegetation for some distance away...Minimizing herbicide use can
reduce weed growth and result in cost effective vegetation management systems."6
Integrated pest management includes cultural methods, mechanical removal, cultivation,
mulching, flaming, hot water, controlled burning, or a variety of non toxic herbicides
based on corn meal gluten, vinegar, or microbial agents.
Several forms of alternative herbicides have recently come on the market and are
currently a very active research subject in Canada. Corn meal gluten applied to mature
grass over multiple seasons acts as a pre-emergent herbicide to suppress clover,
dandelion and other weed growth by up to 90%. Vinegar (acetic acid) effectively kills
many weeds when applied directly to the shoots, and Cirsium arvense, the invasive
thistle targeted by this permit application, is particularly susceptible according to USDA
tests. The Environmental Protection Agency recently approved at least one commercial
vinegar-based mixture; a vinegar-based product would be an excellent choice for weed
control as vinegar degrades quickly into nontoxic components. 7
Herbicide applications are likely to result in higher economic and ecological costs over
the long term, as plants develop resistance to herbicide applications. Despite earlier
claims that glyphosate resistance was unlikely, at least 19 weed species have developed
glyphosate-resistant strains in agricultural areas worldwide8. Field studies in Washington
state showed that star thistle repeatedly treated with picloram developed resistance to
not only the herbicide actually uses, picloram, but to other herbicides (including
chlorpyralid) with the same mode of action.9 The use of herbicides will perpetuate
resistance of the vegetation to treatment and will not be effective in vegetation
management in the future. Herbicide-resistant weeds may also spread into areas beyond
the application sites, thereby increasing the problem and cost of weed control. We assert
that there are new and proven methods and technologies that preclude the need for
synthetic herbicides, including new acetic acid-based products, improved infrared steam
P. O. BOX 1105 Chickaloon, Alaska 99674
emtail: cvadmin@chickaloon.org
Phone (907) 745-0707 Fax (907) 745-0709
Home Page: http://www.chickaloon.org
technology, cultural and biological control methods. We maintain that an integrated non¬
chemical approach would be highly effective and preferable to threatening
environmental and community health.
On August 1, 2006 the Attorney General of Alaska announced that Alaska "joined with 13
other states and the U.S. Virgin Islands to petition the Environmental Protection Agency
(EPA) to require pesticide manufacturers to disclose on the label of their product all
hazardous ingredients...The EPA currently requires that pesticide labels disclose only the
product's "active" ingredients that contain toxic materials intended to kill insects, weeds,
or other target organisms. Pesticide products also contain many other "inert"
ingredients, which are intended to preserve or improve the effectiveness of the
pesticides' active ingredients. These "inert" ingredients may be toxic themselves..." The
news release further states that "people who use or who are impacted by the use of a
pesticide should have notice of all that product's potential health risks." Thus, it would
be wrong for BLM to apply herbicides for which the manufacturers do not disclose
ingredients that may harm human health.
Dr. Warren Porter, Professor of Environmental Toxicology at the University of Wisconsin,
Madison, completed a review of the literature concerning the environmental health
effects of low-dose chemical mixtures of pesticides.10 He concluded:
• Pesticides have interactive effects and ultra low-level effects that are below EPA
allowable levels. These effects include adverse neurological, endocrine, immune,
reproductive and developmental health outcomes.
• EPA assessments of biological risk can be off by a factor of 10,000 at ultra low
doses. Scientists call for a new type of risk assessment in the open literature
because of the inadequacies of the current EPA pesticide registration system.
• Pesticides have broad biological effects that are unintended and often
unpredictable because of physicochemical properties engineered into their
molecules.
• Pesticides of different classes can have similar impacts on endocrine disruption
and sexual development. Chemicals affect development at levels in the tenths of
a part per billion range.
In the preeminent peer-reviewed environmental health journal published by the National
Institute for Environmental Health Sciences, Environmental Health Perspectives ,n the
authors warn: "Inert ingredients may be biologically or chemically active and are labeled
inert only because of their function in the formulated product.Jnert ingredients can
increase the ability of pesticide formulations to affect significant toxicological endpoints,
including developmental neurotoxicity, genotoxicity, and disruption of hormone function.
They can also increase exposure by increasing dermal absorption, decreasing the efficacy
of protective clothing, and increasing environmental mobility and persistence. Inert
ingredients can increase the phytotoxicity of pesticide formulations, as well as toxicity to
fish, amphibians, and microorganisms." In the case of this permit application, the active
ingredients cannot be used without an adjuvant and/or surfactant. The scientific
literature supports the fact that the use of surfactants/adjuvants increases the
P. O. BOX 1105 Chickaloon, Alaska 99674 Phone (907) 745-0707 Fax (907) 745-0709
emiail: cvadmin@chickaloon.org HomePage: http://www.chickaloon.org
bioavailability, toxicity, persistence, and bioaccumulation of the active ingredient.
For the reasons stated above, Chickaloon Village Traditional Council firmly opposes the
use of these and other herbicides because of the hazards posed to ecological and human
health. We are particularly vulnerable to the effects of these chemicals due our reliance
on medicinal plants and traditional foods. We anticipate that BLM will initiate formal
government-to-government consultation with our Tribe as mandated.
May Creator Guide Our Footsteps,
1
1 Human Health and Ecological Risk Assessment Final Report for Aminopyralid. 2007. Prepared for
the USDA/Forest Service and National Park Service. SERA TR-052-04-04a.
2
1 Aminopyralid, Chemical Watch Fact Sheet. Beyond Pesticides, 2011.
3
l Almquist TL and RG Lym. 2010. Effect of aminopyralid on Canada thistle and the native plant
community in a restored tallgrass prairie. Invasive Plapt Science and Management 3(2): 155-168.
4
l Fast BJ et al. 2011. Aminopyralid soil residues affect rotational vegetable crops in Florida. Pest
Management Science 67(7):825-830.
5
i Human Health and Ecological Risk Assessment Final Report for Aminopyralid. 2007. Prepared for
the USDA/Forest Service and National Park Service. SERA TR-052-04-04a.
6
I Provincial Government of British Columbia Integrated Pest Management Programme — B.C. Pest
Monitor Newsletter: http://www.env.gov.bc.ca/epd/ipmp/publications/pest monitor/vol5 l.htm. Accessed
September 14. 2009.
7
l Quarles, W. 2010. Alternative herbicides in turfgrass and organic agriculture. The IPM Practitioner:
Monitoring the Field of Pest Management. 22(5/6) May/June 2010.
8
P. O. BOX 1105 Chickaloon, Alaska 99674
emiail: cvadmin@chickaloon.org
Phone (907) 745-0707 Fax (907) 745-0709
Home Page: http://www.chickaloon.org
1 A. J. Price, K. S. (2011). Glyphosate-resistant Palmer amaranth: A threat to conservation tillage.
Journal of Soil and Water Conservation , 66 (4), 265-275.
x Provincial Government of British Columbia Integrated Pest Management Programme — B.C. Pest
Monitor Newsletter: http://www.env.gov.bc.ca/epd/ipmp/publications/pest monitor/vol5 l.htm. Accessed
September 14. 2009.
9
l Sabba, R.P. et al. 2003. Inheritance of Resistance to Clopyralid and Picloram in Yellow Starthistle (Centaurea solstitialis
L.) Is Controlled by a Single Nuclear Recessive Gene. Journal of Heredity. 94(6):523-527
10
i Porter, W. 2005. Report as an expert witness.
11
1 Cox, C. and M. Surgan. 2006. Unidentified inert ingredients in pesticides: implications for human and
environmental health. Environmental Health Perspectives www.ehponline.org/docs/2006/9374/abstract.pdf
Phone (907) 745-0707 Fax (907) 745-0709
Home Page: http://www.chickaloon.org
P. O. BOX 1105 Chickaloon, Alaska 99674
email: cvadmin@chickaloon.org
Xashia (Band of<Pomo Indians
of t fie Stewarts (Point (Rancfieria
May 3,2013
Please note that there have been changes to our Tribal Council and Administration.
Emilio Valencia, Tribal Chairman
Sandy Pinola, Tribal Vice-Chairman
Violet Wilder, Tribal Secretary
Glenda Jacob-McGill, Tribal Treasurer
Elayne May-Muro., Member- At-Large
Angelique Lane, Member-At-Large
Dino Franklin, Member-At-Large
Teresa Romero, Tribal Administrator
Jerry Rice, Fiscal Officer
Otis Parrish, THPO
Jan Guthrie, Housing Director
Nina Hapner, Environmental Director
Please note that we have moved and our new address is: 1420 Guerneville Road,
Suitet 1, Santa Rosa, CA 95403. Please address further correspondence to the current
Chairperson above.
If you have any questions, please contact our office at (707) 591-0580.
Sincerely,
Lenora Vigil-Moya
Front Office Receptionist
cc: file
1420 Guerneville Road, Suite 1 ♦ Santa Rosa, CA 95403
(707) 591-0580 ♦ (707) 591-0583 Fax ♦ email: tribalofc@stewartspoint.org
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KOI NATION OF NORTHERN CALIF ORNI
Koi Nation Information Update
This is the current information for the Koi Nation of Northern
California (formerly Lower Lake Rancheria Koi Nation)
Chairman:
Darin F. Beltran
Office Phone #: (707)575-5586
Office Fax #: (707)575-5506
Address:
P.O. Box 3162
Santa Rosa, CA 95402
Email Address: kn@koination.com
Website:
koination.com
Please update your contact information.
s)
Thank you vmf much, *
Tribal Council of the KoTNation of Northern California
NAKNEK NATIVE VILLAGE
P.O. BOX 210 - Naknek, Alaska 99633
Phone: 907.246.4210 • Fax: 907.246.3563
Naknek Native Village Council
PO Box 210
Naknek, AK, 99633
Phone: 1-907-246-4210
Fax: 1-907-246-3563
nnvcpresident@gmail.com
AECOM
710 Second Avenue, Suite 100
Seattle, WA 98104
To Whom It May Concern:
The Naknek Native Village Council is writing to inform AECOM that Leon Kiana is no
longer the Naknek Native Village Council Administrator. Please direct all mail,
questions/concerns and correspondence to Mr. Patrick Patterson Jr. , Naknek Village
Council President until further notice.
The Naknek Native Village Council would like to also request an update in address
and contact information. Our current contact information is as listed on the top of
. . . Nli R nek
this letter.
Sincerely,
Patrick Patterson Jr.
Naknek Village Council President
Native Village of Unalakleet
Native Village of Unalakleet
PO Box 270
Unalakleet. AK 99684
(907) 624-3622
June 14, 201 3
Stuart Paul us, AECOM Project Manager
710 Second Avenue, Suite 1000
Seattle, WA 98104
RE: Proposed Use of three new herbicides to treat vegetation on BLM-administered lands
Dear Mr. Stuart Paulus:
The Native Village of Unalakleet (NVU) received an invitation for a government-to-government
consultation to exchange information on the proposed use of three new herbicides to treat
vegetation on BLM-administered lands. The NVU Tribal Council respectfully requests that BUM
not spray these herbicides on the Unalakleet River. The Tribal Membership of Unalakleet
harvests berries, greens, fish and game from the Unalakleet River and everywhere in its vicinity.
Please forward any pertinent information about immediate or perceived threats to the natural
flora and fauna caused by invasive plant species that you would like to target. The Native Village
of Unalakleet Tribal Council will meet again on June 20, 2013 and can notify you of future dates
if need be.
Please do not hesitate to call us if you have questions or need more information.
Sincerely:
Kemut Ivanott Sr, President
CC: file
NVU Tribal Council
P.O. Box 270
Unalakleet, AK 99684
Ph: (907)624-3622
Fax: (907) 624-3621
Email: vjohnson@kawerak.org
PALA TRIBAL HISTORIC
PRESERVATION OFFICE
PMB 50, 35008 Pala Temecula Road
Pala, CA 92059
760-891-3510 Office | 760-742-3189 Fax
PALATHPO
May 7,2013
Stuart Paulus, Project Manager
AECOM
710 Second Avenue, Suite 1000
Seattle, WA 98104
Re: Government-to-Government Consultation on the Proposed Use of Three New Herbicides to
Treat Vegetation on BLM-Administered Lands
Dear Mr. Paulus,
We are in receipt of a letter from Edwin L. Roberson, Assistant Director, Renewable Resources
and Planning of the Bureau of Land Management regarding a proposal to approve three new
herbicides for use on BLM-administered public lands. This letter constitutes our response on
behalf of Robert Smith, Chairman of the Pala Band of Mission Indians.
At this time, we do not request formal government-to-government consultation on the proposed
action. Further, we do not have any specific concerns about the proposed herbicides, nor do we
have any reserved rights under treaty. However, we would like to comment that consultation on
the use of new herbicides should be specific to the Indian nations that may be impacted by their
use. That is, as herbicide applications are scheduled for specific areas, the local tribes should be
contacted so they are aware that native plant resources might be affected, and they can plan
accordingly. They should also be contacted for information regarding TCPs and other significant
areas that may be impacted by scheduled applications.
Thank you for the opportunity to comment.
Tribal Historic Preservation Officer
Pala Band of Mission Indians
STATE HISTORIC PRESERVATION
OFFICE CONSULTATION
KSR&C NoaS-os-oil
6425 SW 6lh Avenue
Topeka, KS 66615
phone: 785-272-8681
fax: 785-272-8682
cultural_resources@kshs.org
Kansas Historical Society
Sam Brownback, Governor
Jennie Chinn, Executive Director
May 1,2013
Stuart Paulus
AECOM Project Manager
710 Second Avenue, Suite 1000
Seattle WA 98104
RE: Herbicide Treatments
1793(220)
Statewide
Dear Mr. Paulus,
Our staff has reviewed the materials received April 26, 2013, regarding the above referenced
project in accordance with 36 CFR 800. The SHPO has determined the proposed project will not
adversely affect any property listed or eligible for listing in the National Register of Historic Places.
Please refer to the Kansas State Review & Compliance number (KSR&C#) listed above on any
future correspondence.
If you have any questions regarding this review, please contact Kim Gant (785) 272-8681 ext. 225.
Sincerely,
Jennie Chinn
leer
Patrick Zollner 1
Director, Cultural Resources Division
Deputy State Historic Preservation Officer
Big Sky. Big Land. Big History.
Montana
Historic Preservation
Museum
Outreach Interpretation
Publications
Research Center
STUART PAULUS
AECOM MANAGER
710 SECOND AVE
SUITE 1000
SEATTLE WA 98104
RE: PEIS for Aminopyralid, Fluroxypyr and Rimsulfuron Herbicides
Mr. Paulus:
We know of no direct or indirect effect potential to Historic Properties as a result of application of these
herbicides. We recommend eliciting tribal comments or concerns regarding potential impacts resulting
from use of culturally important plants which might be treated as either target or non-target plants.
Thank you for providing us an opportunity to comment.
Stan Wilmoth, Ph.D.
State Archaeologist/deputy, SHPO
225 North Roberts Street
P. O. Box 201201
Helena, MT 59620-1201
(106) 444.2694
(406) 444-2696 FAX
montanahistoricalsociety.org
I
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I
State
Historical
Society
of North Dakota
Jack Dalrymple
Governor of North Dakota
April 30, 2013
North Dakota
State Historical Board
Gereld Gerntholz
Valley City - President
Calvin Grinnell
New Town - Vice President
A. Ruric Todd III
Jamestown - Secretary
Albert I. Berger
\ Grand Forl<s
Mr. Stuart Paulus
AECOM Project Manager
710 Second Avenue, Suite 1000
Seattle, WA 98104
ND SHPO Ref: 13-0822 BLM 1793 (220) PEIS on adding three herbicides to
list of approved active ingredients for use in vegetation treatments on public
lands
Diane K. Larson
Bismarck
Dear Mr. Peters,
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Chester E. Nelson, Jr.
Bismarck
Margaret Puetz
Bismarck
Sara Otte Coleman
Director
Tourism Division
ft)
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Kelly Schmidt
State Treasurer
We reviewed ND SHPO Ref: 13-0822 BLM 1793 (220) PEIS on adding three
herbicides to list of approved active ingredients for use in vegetation treatments on
public lands and would like to comment that some herbicides can have a negative
impact on historic buildings, monuments and cemetery stones if applied too close
to or on the structures. This can be due to salt crystallization, discoloration,
change in pH, pitting of surfaces, and accelerated deterioration.
Please see:
http://wmv.scribd.com/doc/37784733/The-Effects-of-Herbicide-on-Stone-and-
Masonry
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Alvin A. Jaeger
Secretary of State
Mark Zimmerman
Director
Parks and Recreation
Department
Grant Levi
Acting Director
partment of Transportation
([
Merlan E. PaaverucLjjr;^
Director
Thank you for the opportunity to review this PEIS document. Please include the
ND SHPO Reference number listed above in further correspondence for this
specific project. If you have any questions please contact Susan Quinnell, Review
and Compliance Coordinator at (701) 328-3576, or scjuinnell@nd.gov
Sincerely,
Merlan E. Paaverud, Jr.
State Historic Preservation Officer (North Dakota)
Accredited by the
American Alliance
of Museums since 1989
North Dakota Heritage Center • 612 East Boulevard Avenue, Bismarck, ND 58505-0830 • Phone: 701-328-2666 • Fax: 701-328-3710
Email: histsoc@nd.gov • Web site: http://history.nd.gov • TTY: 1-800-366-6888
ENVIRONMENTAL PROTECTION AGENCY
CONSULTATION
UJ
C3
T
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
ENFORCEMENT AND
COMPLIANCE ASSURANCE
AECOM
Attn. Stuart Paul us
710 Second Avenue, Suite 1000
Seattle, WA 98104
Dear Mr. Paulus:
The Environmental Protection Agency (EPA) has reviewed the Bureau of Land Management's
(BLM) Notice of Intent (NOI), dated December 21, 2012, to prepare an Environmental Impact
Statement (EIS) to evaluate the use of aminopyralid, fluroxypyr, and rimsulfuron herbicides as
part of the its vegetation treatment programs on public lands in 17 Western States.
According to the NOI, BLM will assess environmental impacts associated with use of the
proposed herbicides on all surface estate public lands under its administration in 17 Western
States. The need for the proposed action is to expand the existing vegetation treatment program
and increase flexibility and options when designing herbicide treatments.
We understand that the use of herbicides is a necessary strategy to control noxious weeds in light
of the scope and severity of noxious weed invasions. Therefore, we support the overall purpose
of the proposed action to treat vegetation on public lands. The NOI identifies a preliminary list of
resources and issues to address in the EIS analysis, including, but not limited to, the effects of the
herbicides and their inert ingredients on human, vegetation, fish and wildlife, livestock, water
quality, tribal resources; and cumulative impacts.
We offer the following comments for your consideration.
Impacts to Water Resources
We recommend that the EIS analyze potential adverse impacts of the proposed action to water
quality and aquatic resources. In particular, we are concerned about the unintended consequences
that may result from applications of herbicides such as drift, effects on non-target species,
persistence in soils that may erode into waterways. If buffers exist around waterways, EPA
recommends that the EIS include information explaining the treatment of invasive plants within
buffer zones, as well as information about aquatic invasive plant infestations and how they
would be treated to prevent deterioration of water quality within waterbodies found on the
analysis area.
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper
Section 303(d) of the Clean Water Act (CWA) requires each state to identify waterbodies that
are not meeting or not likely to CWA water quality standards and to develop water quality
restoration plans or Total Maximum Daily Loads for these waters. We recommend the EIS
demonstrate that there would be no net degradation of water quality to Section 303(d) listed
waters. Also, please indicate how use of the proposed herbicides would meet anti-degradation
provisions of the CWA that prohibit degrading water quality standards within water bodies that
are currently meeting water quality standards.
The proposed chemical treatment may also impact waters that serve as sources of drinking water.
The 1 996 amendments to the Safe Drinking Water Act require federal agencies that manage
lands that drain to drinking water sources to protect these source waters. EPA recommends that
the analysis of impacts identify all drinking water sources, any potential contamination of these
sources that may result from the proposed action, and measures that would be taken to protect
these sources.
EPA is aware that aminopyralid has been detected in surface and groundwater in Montana. The
contamination in groundwater has been anecdotally linked to impacts on irrigated plants/crops.
Thus, we recommend the EIS explicitly address these groundwater concerns in the water
resources section.
Chemical Treatments
We recommend the BLM analyze herbicides to determine whether they: 1) are registered for the
intended use, 2) will achieve the desired results, and 3) will have minimal adverse effects on the
environment.
Providing the best available information on chemicals is essential in evaluating chemical use in
invasive plant control and eradication. If other alternatives such as prevention and mechanical
control are not feasible, use of herbicides may provide less environmental impact than the
establishment of invasive plants. Issues such as sub-lethal effects on wildlife, reduced
breeding/survival of sensitive species, secondary cumulative effects, and unintended effects need
to be discussed. Liquid and granular herbicides can be applied broadcast, banded, as spots, or
directed to specific plants using appropriate application technology such as mechanized ground
equipment, or manual applicators such as backpack sprayers or tree injectors. Use of global
positioning systems, specialized application equipment and careful attention to weather
conditions can enhance application accuracy and minimize off-site chemical movement. Models
can also be used to assess the effectiveness of alternative drift control practices and predict the
environmental fate of chemicals before their use.
Since chemical treatment is one of several available vegetation management alternatives, we
recommend the BLM discuss the screening process used in deciding whether chemical
applications are necessary given other weed treatments are already in use on BLM lands. The
BLM must ensure that its use of registered pesticides is consistent with all labeling requirements
and coordinate with individual state programs to make sure the new herbicides are registered for
the intended use in each state.
2
Landscape Approach and Cumulative Effects
EPA recommends that the EIS assess the effects of the proposed herbicide applications using a
landscape approach because BLM administered lands are often intertwined with a mix of other
privately, state, and federally owned lands.
Where infestations cross jurisdictional boundaries, a coordinated effort will increase the
likelihood of bringing the invasive population to a manageable level. It is recommended that the
EIS process use a landscape approach in assessing cumulative effects and identify what
assumptions will be used with respect to adjacent non-BLM lands, as well as the mechanisms for
cooperating with other landowners to disclose the sum of individual effects of all projects on
local environment. We recommend that BLM consider EPA’s Consideration of Cumulative
Impacts in EPA Review ofNEPA Documents 1 when preparing this EIS.
Public Participation and Environmental Justice
We recommend that the EIS disclose what efforts were taken to ensure effective public
participation. Also, consistent with Executive Order 12898 (. Federal Actions to Address
Environmental Justice in Minority and Low-Income Populations) the EIS should include an
environmental justice analysis to identify low-income and minority populations in the project
area and disclose what efforts were taken to avoid, minimize, reduce or mitigate impacts to these
communities if these populations will be impacted by the proposed project.
Restoration
EPA recommends that the EIS evaluate options for restoration activities following invasive plant
removal to prevent their re-establishment.
We recommend including an evaluation of restoring natural processes to assist in the return of
stressed natural communities and creating high quality habitats. For example, restoring
hydrology to a wetland or riparian site, returning a stream to its natural channel, reintroducing
fire, and creating conditions that allow natural processes (large woody debris, carbon storage,
nutrient cycling) to occur are all activities that have great potential for restoration success.
Climate Change Effects
EPA recommends that the EIS evaluate whether changes in plant growth, resulting from
increased CO2 in the atmosphere, could affect herbicide efficiency either through uptake rates of
the active ingredient or by increased biomass that enables plants to withstand herbicides'
effectiveness.
1 EPA’s Consideration of Cumulative Impacts in EPA Review ofNEPA Documents is located at
http://www.epa.gov/compliance/resources/policies/nepa/cumulative.pdf
3
We also recommend that the EIS quantify the greenhouse gas emissions from the project
activities and discuss mitigation measures to reduce emissions.
Monitoring
We recommend that the proposed project be designed to include an effective feedback element,
which includes both implementation and effectiveness monitoring.
Specifically, it is recommended that the EIS include information and assurances regarding
adequate monitoring and evaluation to determine if application rates are effective, buffers are
sufficient, off-target drift is minimized, and specific goals and endpoints are being met. We
recommend there be a commitment in using the best available techniques for monitoring,
evaluating, and mitigating impacts from those herbicides that are known to be persistent and that
migrate through soil into groundwater.
Monitoring is a necessary and crucial element in identifying and understanding the consequences
of actions. For the proposed project, monitoring would show whether the proposed treatments
would be effective in managing invasive plant populations and in minimizing environmental
impacts. This information would also be helpful in planning future land management activities.
Other
We recommend the EIS document assess the effects of composting operations and how treated
plants will be disposed of (left in place, mulched, composted, etc) particularly those treated with
either aminopyralid or fluroxypyr. Aminopyralid and fluroxypyr are in the group of pyridine-
based herbicides that have been causing problems in compost. They persist through composting
cooperations, and then when the compost is used on sensitive plants, as in right-of-way use, the
plants die.
We appreciate the opportunity to review the NOI and look forward to reviewing the draft EIS
related to this project. The staff contact for the review is Julie Roemele. She can be reached at
(202) 564-5632. '
Sincerely,
LilbQAK’O ^borY) rw
Susan E. Bromm
Director
Office of Federal Activities
4
U.S. FISH AND WILDLIFE SERVICE AND
NOAA NATIONAL MARINE FISHERIES
SERVICE CONSULTATION
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Washington, DC 20240
http://www.blm.gov
MAR 3 2015
In Reply Refer To:
6842 (WO-230)
Memorandum
To:
From:
Subject:
The Bureau of Land Management (BLM) is requesting initiation of consultation under the
Endangered Species Act (ESA) on the Draft Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and Rimsulfuron on the BLM lands in 17 Western States Programmatic
Environmental Impact Statement (PEIS). Attached is final Biological Assessment (BA) used to
complete the BLM’s effects analysis for Threatened, Endangered and Proposed (TEP) species
and their designated or proposed critical habitat, pursuant to the ESA, Essential Fish Habitat, and
the Magnuson-Stevens Fishery Conservation and Management Act. The analyses in the BA and
PEIS incorporate the best scientific and commercial data available to the BLM. The BLM
analysis addresses a total of 341 species, subtotaled by species’ type below.
Type of
Species
Number of
Species
Plant
163
Mollusk
11
Arthropod
16
Fish
83
Amphibian
11
Reptile
7
Bird
21
Mammal
29
*Total
341
Craig W. Aubrey
Chief, Division of Environmental Review Ecological Services Program
Shelley J. Smith (X
Acting Deputy Assistant Director, Resources
lanning
Section 7 Consultation for Draft Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and RimsulfuroiUm the Bureau of Land Management Lands in 17
Western States Programmatic Environmental Impact Statement EIS (PEIS)
includes subspecies and populations that are treated separately.
2
The PEIS assesses, on the national level, the BLM’s proposed use of the active ingredients
aminopyralid, fluroxypyr, and rimsulfuron. If approved, the BLM will add these three herbicides
to the BLM’s list of approved active ingredients and integrate them into the BLM Vegetation
Management Program. Herbicide treatments using all approved active ingredients would occur
on the BLM-administered lands in 17 western states, including Alaska. The prescribed
treatments would take place on no more than 932,000 acres annually, which is the same acreage
limit that was analyzed in the PEIS and BA released in 2007. The BLM plans to continue to
treat vegetation on the BLM-administered lands using an integrated pest management approach,
utilizing a variety of vegetation management tools, including herbicides, prescribed fire, and
mechanical, manual, and biological control methods. With the exception of the three new
herbicides, use of all of the vegetation management tools by the BLM have been previously
analyzed at the EIS level and approved through Records of Decision.
As part of the PEIS analysis of herbicide use, ecological risk assessments (ERAs) were prepared
by the BLM to assess the risks of these herbicides to fish and wildlife, including TEP species and
their designated or proposed critical habitat. The ERA methodology was developed in
collaboration with the U.S. Fish and Wildlife Service, National Marine Fisheries Service, and the
Environmental Protection Agency for the 2007 PEIS and BA.
During development of the current PEIS and BA, standard operating procedures (SOPs) and
conservation measures were developed to minimize potential effects to plants and animals from
treatments using aminopyralid, fluroxypyr, and rimsulfuron. SOPs and conservation measures
specific to TEP species and their designated or proposed critical habitat are included in the BA.
Additionally, the BLM would continue to follow all SOPs and conservation measures identified
in the 2007 PEIS and BA. These measures are conservative and designed to apply across all
public lands. During project planning, local field offices have the opportunity to identify
additional appropriate local SOPs and conservation measures to reduce further potential effects
at the project scale. All subsequent actions implemented are subject to the National
Environmental Policy Act analysis and consultation under the ESA, if it is determined that they
“May Affect” TEP species and/or their designated or proposed critical habitat.
The BLM’s proposed use of the active ingredients aminopyralid, fluroxypyr, and rimsulfuron
would require field offices to comply with all SOPs and conservation measures contained in the
PEIS, BA and in the ERAs for TEP species and their designated or proposed critical habitat that
could be affected by a site-specific proposed action. The proposed action also requires
consultation at the project-level if it is determined that the project actions “May Affect” a TEP
species or their designated or proposed critical habitat.
The scale of the proposed action is the 17 states evaluated in the PEIS. Although herbicide
treatments using the three new herbicides could occur anywhere on the 245 million acres of
public lands administered by the BLM; actual treatment locations and levels are determined by
Congressional direction and funding. With current funding levels, the BLM is treating an
average of 3 1 5,000 acres per year using herbicides (about one tenth of one percent of BLM-
administered lands). For the purposes of evaluating the effects of herbicide treatments with
aminopyralid, fluroxypyr, and rimsulfuron on TEP species and/or their designated or proposed
critical habitat, the estimate of 932,000 acres treated annually using all herbicides (about four
tenths of one percent of BLM-administered lands) was carried over from the 2007 PEIS.
3
Outside of one, no effect determination found on a fish species within the federal mineral estate,
the BLM has determined, through the effects analysis that the proposed action may affect but is
Not Likely to Adversely Affect all species analyzed in the BA. The effects determination
assumes that the BLM will protect TEP species through the use of conservation measures
identified for various species groups in the 2007 and current BA, additional conservation
measures developed by local field offices (primarily for spot treatments near TEP plants), and
SOPs identified in the 2007 and current PEIS. Subsequent site-level actions that do not conform
to these standards may not result in a determination of Not Likely to Adversely Affect.
Regardless, all subsequent actions remain subject to consultation if a “May Affect”
determination is made at the local level.
The BLM appreciates the opportunity to work with you and your staff to clarify the information
about the PEIS and the consultation. If you have any questions regarding the PEIS, please
contact Gina Ramos, Division of Forest, Riparian, and Rangeland Resources (WO-220) at (202)
912-7226. If you have any questions regarding consultation or essential fish habitat, please
contact Kim Tripp, Senior Specialist, Threatened, and Endangered Species Program (WO-230) at
(202)912-7237.
Attachment
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Washington, DC 20240
http://www.blm.gov
MAR 3 2015
In Reply, Refer To:
6842 (WO-230)
Donna Wieting
Director, Office of Protected Resources (F/PR)
National Marine Fisheries Service
1315 East- West Highway
Silver Spring, MD 20910
Dear Ms. Wieting:
The Bureau of Land Management (BLM) is requesting initiation of consultation under the
Endangered Species Act (ESA) on the Draft Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and Rimsulfuron on BLM lands in 17 Western States Programmatic Environmental
Impact Statement (PEIS). Please find enclosed, the final Biological Assessment (BA) used to
complete the BLM effects analysis for Threatened, Endangered, and Proposed (TEP) species and
their designated critical habitat, pursuant to the ESA, and Essential Fish Habitat pursuant to the
Magnuson-Stevens Fishery Conservation and Management Act (MSA). The analyses in the BA and
PEIS incorporate the best scientific and commercial data available to the BLM.
The BLM analysis addresses a total of 341 species, subtotaled by species’ type below.
Type of
Species
Number of
Species
Plant
163
Mollusk
11
Arthropod
16
Fish
83
Amphibian
11
Reptile
7
Bird
21
Mammal
29
*Total
341
*Includes subspecies and populations that are treated separately.
The PEIS assesses, on the national level, the BLM’s proposed use of the active ingredients
aminopyralid, fluroxypyr, and rimsulfuron. If approved, the BLM will add these three herbicides to
its list of approved active ingredients and integrate them into the BLM Vegetation Management
2
Program. Herbicide treatments using all approved active ingredients would occur on BLM-
administered lands in 17 western states, including Alaska. The prescribed treatments would take
place on no more than 932,000 acres annually, which is the same acreage limit that was analyzed in
the PEIS and BA released in 2007. The BLM plans to continue to treat vegetation on the BLM
administered lands using an integrated pest management approach, utilizing a variety of vegetation
management tools, including herbicides, prescribed fire, and mechanical, manual, and biological
control methods. With the exception of the three new herbicides, use of all of the vegetation
management tools by the BLM have been previously analyzed at the EIS level and approved through
Records of Decision.
As part of the PEIS analysis of herbicide use, ecological risk assessments (ERAs) were prepared by
the BLM to assess the risks of these herbicides to fish and wildlife, including TEP species and their
designated or proposed critical habitat. The risk assessment methodology was developed in
collaboration with the U.S. Fish and Wildlife Service, National Marine Fisheries Service (NMFS),
and the U.S. Environmental Protection Agency for the 2007 PEIS and BA.
During development of the current PEIS and BA, standard operating procedures (SOPs) and
conservation measures were developed to minimize potential effects to plants and animals from
treatments using aminopyralid, fluroxypyr, and rimsulfuron. SOPs and conservation measures
specific to TEP species are included in the BA. Additionally, the BLM would continue to follow all
SOPs and conservation measures identified in the 2007 PEIS and BA. These measures are
conservative and designed to apply across all public lands. During project planning, local field
offices have the opportunity to identify additional appropriate local SOPs and conservation measures
to reduce further potential effects at the project scale. All subsequent actions implemented are
subject to the National Environmental Policy Act analysis and consultation under the ESA, if it is
determined that they “May Affect” TEP species or their designated or proposed critical habitat.
The BLM’s proposed use of the active ingredients aminopyralid, fluroxypyr, and rimsulfuron would
require field offices to comply with all SOPs and conservation measures provided in the PEIS, BA,
ERAs for TEP species, and their designated or proposed critical habitat that could be affected by a
site-specific herbicide treatment project. The proposed action also requires consultation at the
project-level if it is determined that the project actions “May Affect” TEP species or their designated
or proposed critical habitat.
The scale of the proposed action is the 17 states evaluated in the PEIS. Although herbicide
treatments using the three new herbicides could occur anywhere on the 245 million acres of public
lands administered by the BLM; actual treatment locations and levels are determined by
Congressional direction and funding. With current funding levels, the BLM is treating an average of
315,000 acres per year (about one-tenth of one percent of BLM-administered lands) using herbicides.
For the purposes of evaluating the effects of herbicide treatments with aminopyralid, fluroxypyr. and
rimsulfuron on TEP species and their designated or proposed critical habitat, the estimate of 932,000
acres treated annually using all herbicides (about four tenths of one percent of BLM-administered
lands) was carried over from the 2007 PEIS.
The proposed action does not fund or carryout any subsequent program or on-the-ground action that
could cause a direct or indirect effect to TEP species or their designated or proposed critical habitat.
3
Subsequent decisions which authorize, fund or carry out actions that may affect TEP species or their
designated or proposed critical habitat, or result in adverse effects to Essential Fish Habitat (EFH),
will be subject to consultation at the local level.
Outside of one, no effect determination found on a fish species within the federal mineral estate, the
BLM has determined, through the effects analysis that the proposed action may affect but is Not
Likely to Adversely Affect all species analyzed in the BA. The effects determination assumes that
the BLM will protect TEP species through the use of conservation measures identified for various
species groups in the 2007 and current BA, additional conservation measures developed by local
field offices (primarily for spot treatments near TEP plants), and SOPs identified in the 2007 and
current PEIS. Subsequent site-level actions that do not conform to these standards may not result in
a determination of Not Likely to Adversely Affect. Regardless, all subsequent actions remain subject
to consultation if a “May Affect” determination is made at the local level.
The BLM conducted an analysis of potential impacts to EFH in the BA and concluded the proposed
action does not adversely affect EFH (it does not fund, authorize, or undertake any on-the-ground
actions that could impact EFH). Consultation under MSA on EFH is not required for actions which
would not cause an adverse effect (50 CFR 600.920). If, based on the information contained in the
administrative record, NMFS disagrees with our finding, NMFS may issue advisory conservation
recommendations if you conclude there are adverse effects. Per the NMFS policy and guidelines,
actions subject to ESA consultation which are determined to be NLAA, by definition do not cause an
adverse impact to EFH. This proposed action creates a common standard for project or site-level
implementation regardless of the presence of ESA-listed species or presence of EFH.
Thank you for the productive meeting and agreeing to initiate consultation. If you have any
questions regarding the PEIS, please contact Gina Ramos, Division of Forest, Riparian, and
Rangeland Resources (WO-220) at (202) 912-7226. If you have any questions regarding
consultation or essential fish habitat, please contact Kim Tripp, Senior Specialist, Threatened, and
Endangered Species Program (WO-230) at (202) 912-7237. The BLM looks forward to completing
this programmatic consultation in an expeditious manner and as close to the time frames defined by
the regulations as possible, given no further delays.
( Sincerely,
Ml(d\
/Shelley J. Smith I
Acting Deputy Assistant Director
Resources and Panning
Enclosure
_ _ APPENDIX C
ALASKA NATIONAL INTEREST LANDS
CONSERVATION ACT (ANILCA) § 810
ANALYSIS OF SUBSISTENCE IMPACTS
'
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS
APPENDIX C
ALASKA NATIONAL INTEREST LANDS
CONSERVATION ACT (ANILCA) § 810
ANALYSIS OF SUBSISTENCE IMPACTS
Introduction
On December 21, 2012, the United States Department
of the Interior (USDOI) Bureau of Land Management
(BLM) issued a Notice of Intent in the Federal Register
to prepare a Programmatic Environmental Impact
Statement (PEIS) to evaluate the viability of using
aminopyralid, fluroxypyr, and rimsulfuron herbicides
as part of BLM vegetation management programs in 1 7
western states, including Alaska. A total of 18
herbicides were approved for use on public lands under
the 2007 Vegetation Treatments Using Herbicides on
Bureau of Land Management Lands in 17 Western
States Programmatic Environmental Impact Statement
(2007 PEIS; USDOI BLM 2007a). If approved for use
under the current project, the three new herbicides will
join the list of ElS-approved herbicides currently in use
on BLM lands, bringing the total to 2 1 .
The Notice of Intent for the PEIS identified the
locations and times of public scoping meetings, and
stated that comments on the proposal would be
accepted until February 19, 2013. Information gathered
at the public meetings and during the comment period
led to the development of the Vegetation Treatments
Using Aminopyralid, Fluroxypyr, and Rimsulfuron on
Bureau of Land Management Lands in 17 Western
States PEIS. This document assesses on a national
level the BLM’s proposed use of aminopyralid,
fluroxypyr, and rimsulfuron. Together with the 2007
PEIS, it addresses the BLM’s herbicide treatment
programs on the 17 western states, including Alaska.
Because of the programmatic nature of herbicide use
by the BLM, the PEIS addresses a wide range of
impacts that are inclusive of the extensive and diverse
land area under analysis. Should herbicide use be
proposed locally, then site-specific impacts of all
vegetation treatments would be addressed and analyzed
in additional National Environmental Policy Act
(NEPA) documents prepared by local BLM offices and
tiered to the PEIS documents.
BLM-administered lands (public lands) are federally
owned lands and interests in lands (such as federally
owned mineral estate) that are administered by the
Secretary of the Interior through the BLM. In Alaska,
public lands also include lands selected, but not yet
conveyed, to the State of Alaska or Native
Corporations and villages.
Chapters 3 (Affected Environment) and 4
(Environmental Consequences) of the PEIS provide
detailed descriptions of the affected environment and
the potential effects of the various alternatives on
subsistence resources, with information in the 2007
PEIS referenced where appropriate. This appendix uses
the detailed information presented in the PEIS to
evaluate the potential impacts to subsistence pursuant
to Section 810(a) of the Alaska National Interest Land
Conservation Act (ANILCA).
Subsistence Evaluation
Factors
Section 810(a) of ANILCA requires that an evaluation
of subsistence uses and needs be completed for any
federal determination to “withdraw, reserve, lease, or
otherwise permit the use, occupancy or disposition of
public lands.” As such, an evaluation of potential
impacts to subsistence under ANILCA § 810(a) must
be completed for the PEIS. This evaluation must
include findings on three specific issues:
• The effect of use, occupancy, or disposition on
subsistence uses and needs;
• The availability of other lands for the purpose
sought to be achieved; and
• Other alternatives that would reduce or
eliminate the use, occupancy, or disposition of
public lands needed for subsistence purposes
(16 United States Code § 3120).
BLM Vegetation Treatments Three New 1 lerbicides
Final Programmatic E1S
C-l
January 2016
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS
A finding that the proposed action may significantly
restrict subsistence uses imposes additional
requirements, including provisions for notices to the
State of Alaska and appropriate regional and local
subsistence committees, a hearing in the vicinity of the
area involved, and the making of the following
determinations, as required by Section 810(a)(3):
• Such a significant restriction of subsistence
uses is necessary, and consistent with sound
management principles for the utilization of
the public lands;
• The proposed activity will involve the minimal
amount of public lands necessary to
accomplish the purposes of use, occupancy, or
other disposition; and
• Reasonable steps will be taken to minimize
adverse effects upon subsistence uses and
resources resulting from such actions.
To determine if a significant restriction of subsistence
uses and needs may result from any one of the
alternatives discussed in the PEIS, including their
cumulative effects, the following three factors in
particular are considered:
• Reductions in the availability of subsistence
resources caused by a decline in the population
or amount of harvestable resources;
• Reductions in the availability of resources
used for subsistence purposes caused by
alteration of their normal locations and
distribution patterns; and
• Limitations on access to subsistence resources,
including limitations resulting from increased
competition for the resources.
Evaluation of Alternatives
and Findings
The alternatives presented below are associated with a
decision about whether to allow the BLM to use the
herbicides aminopyralid, fluroxypyr, and rimsulfuron
on public lands in the western U.S. and Alaska. All of
the alternatives involve herbicide treatments on the
same number of total acres, with differences in how
much of each herbicide would be used annually. No
specific projects are proposed under any of the
alternatives. When a project is proposed, the BLM will
be required to initiate a site-specific NEPA analysis of
the proposed actions. For lands covered under the
ANILCA, the BLM would also conduct an additional
ANILCA § 810 Analysis of Subsistence Impacts.
During this process, the BLM will invite public
participation and collaborate with Alaska Natives and
Alaska Native Corporations to identify and protect
culturally significant plants used for food, baskets,
fiber, medicine and ceremonial purposes. For this
document, the evaluation and findings required by
ANILCA § 810 are similar for all four alternatives
considered in the PEIS, primarily because of the
programmatic nature of the proposed herbicide use,
and because there is little difference in location or
amount of total herbicide use among the alternatives.
The BLM has found that none of the alternatives in the
PEIS result in a finding of “may significantly restrict
subsistence uses and needs.”
A subsistence evaluation and finding under ANILCA §
810 must also include a cumulative impacts analysis.
The discussion below begins with evaluations and
findings for each of the four alternatives discussed in
the PEIS. Finally, the cumulative case, as discussed in
Chapter 4 (Environmental Consequences) of the PEIS,
is evaluated. This approach helps the reader to separate
the subsistence restrictions that would potentially be
caused by activities proposed under the alternatives
from those that would potentially be caused by past,
present, and future activities that could occur, or have
already occurred, under the vegetation management
program.
ANILCA § 810(a) Evaluations and
Findings for All Alternatives and the
Cumulative Case
The following evaluations are based on information
relating to the environmental and subsistence
consequences of alternatives A through D and the
cumulative impacts analysis as presented in Chapter 4
(Environmental Consequences) of the PEIS. The
evaluations and findings focus on potential impacts to
subsistence resources themselves, as well as access to
resources, and economic and cultural issues that relate
to subsistence use.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
C-2
January 2016
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS
Evaluation and Findings for Alternative A -
Continue Present Herbicide Use (No Action
Alternative)
Under this alternative, the BLM would continue
current vegetation management activities in Alaska
with the 18 herbicides approved for use in the Record
of Decision (ROD) for the 2007 PEIS (currently
approved herbicides). This alternative represents the
Preferred Alternative of the 2007 PEIS.
Approximately 932,000 acres would be treated with
herbicides annually across 17 western states. It is
estimated that no more than 1 ,000 acres of public lands
in Alaska would be treated with herbicides in any year.
Since the release of the 2007 PEIS, 0 acres in Alaska
have been treated using herbicides, although some
herbicide use has been proposed in association with
future projects to limit the spread of invasive species
from disturbed sites into more pristine areas.
Only herbicides that are registered for use in Alaska
would be applied in the state. At present, 15 of the 18
currently approved herbicide active ingredients are
registered for use in Alaska, although the list includes
only certain formulations of the registered active
ingredients. This list is available from the Alaska
Department of Environmental Quality.
All herbicide treatments would be guided by standard
operating procedures (SOPs) that serve to protect
habitat and resources from potential impacts. The SOPs
that pertain to herbicide application are found in
Chapter 2 of the 2007 PEIS (USDOI BLM
2007a:Table 2-8). Additional mitigation measures that
were developed to protect various resources can be
found in the ROD for the 2007 PEIS (USDOI BLM
2007b:Table 2). There is concern in Alaska about the
use of herbicides in sensitive environments, including
tundra and boreal forests, but herbicide use may be
appropriate where impacts to soil and other resources
are negligible, and where other treatment methods do
not provide adequate vegetation control (Hebert 200 1 ).
Evaluation of the Effect of Use, Occupancy, or
Disposition on Subsistence Uses and Meeds
In Alaska, use of herbicides would have both beneficial
and adverse effects. Herbicides would be used to
eliminate or reduce the extent of infestations of
invasive vegetation, which could help restore
ecosystem function to the benefit of subsistence
resources. The Dalton Management Area Integrated
Invasive Plant Strategic Plan Environmental
Assessment (USDOI BLM 2013), which incorporates a
draft of the strategic plan (USDOI BLM 2009),
proposes use of herbicides to control invasive plants
along the Dalton Highway and adjacent BLM-
administered lands along trails and spur roads, and at
other heavy use areas (e.g., gravel pits, rest stops, mine
sites, and airstrips). The intent of the herbicide
treatments is to stop the spread of invasive plants from
disturbed sites into the more pristine areas. Prevention
of weed spread into these areas would be expected to
help protect subsistence resources from the ecological
changes caused by invasive plant species. For example
nitrogen fixing weeds (white sweetclover, alfalfa,
birdsfoot trefoil and bird vetch) have the risk of
altering ecosystem processes and wildlife habitat by
introducing nitrogen into naturally nitrogen-poor areas.
The first herbicide treatments under this plan are
scheduled to occur in Fiscal Year 2016.
Herbicide treatments are expected to have short-term
adverse and long-term beneficial effects. Undesirable
impacts from herbicide use could include: 1) overspray
onto non-target species that would result in injury or
death of plants; 2) accidental spills that could kill non¬
target plants and run into wetlands or streams; 3)
herbicide drift from the application site that could
damage plants; and 4) toxicity to organisms, including
people, from excessive contact or ingestion. The BLM
has developed SOPs to minimize the adverse effects of
herbicide treatments. Part of the NEPA process for
vegetation treatments is consultation with Native
groups and the public to determine the location of
important subsistence resources that might be affected
by herbicide treatments, in order to minimize or
eliminate the undesirable impacts of the treatments.
The BLM would work closely with subsistence users to
minimize impacts to subsistence resources in
particular, and would follow guidance under Human
Health and Safety in Chapter 4 of the 2007 PEIS in
areas that may be visited by people after treatments.
If necessary for the protection of subsistence plants and
wildlife forage, the BLM would: 1) use drift reduction
agents with herbicides, as appropriate, to reduce the
drift hazard to non-target species; 2) refer to the
herbicide label when planning revegetation to ensure
that desirable vegetation would not subsequently be
injured by the herbicide; and 3) consider site
characteristics, environmental conditions, and
application equipment in order to minimize damage to
non-target vegetation. To protect fish and wildlife, the
BLM would: 1) use buffer zones based on label and
risk assessment guidance; 2) minimize treatments near
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fish-bearing water bodies during periods when fish are
in life stages most sensitive to the herbicide(s) used; 3)
use appropriate application equipment/methods near
water bodies if the potential for off-site drift exists; 4)
use herbicides that are the least toxic to fish; 5) treat
only the portion of the aquatic system necessary to
achieve acceptable vegetation management; 6) select
the appropriate application method(s) to minimize the
potential for injury to desirable vegetation and aquatic
organisms; 7) follow water use restrictions presented
on the herbicide label; 8) minimize treatments during
nesting and other critical periods for birds and other
wildlife; and 9) use herbicides of low toxicity to
wildlife.
To protect water resources, the BLM would: 1)
consider climate, soil type, slope, and vegetation type
when determining contamination risk; 2) conduct
mixing and loading operations in an area where an
accidental spill would not contaminate an aquatic
body; 3) refrain from rinsing spray tanks in or near
water bodies; 4) refrain from broadcasting pellets
where there is danger of contaminating water supplies;
5) minimize treating areas with high risk for
groundwater contamination; 6) maintain herbicide-free
buffers between treatment areas and water bodies; and
7) use the appropriate herbicide-free buffer zone for
herbicides not labeled for aquatic use based on risk
assessment guidance, with minimum widths of 100 feet
for aerial, 25 feet for vehicle, and 10 feet for hand
spray applications.
Evaluation of the A vailability of Other Lands
for the Purpose Sought to be Achieved
The purpose sought to be achieved under the No
Action Alternative is to continue to manage public
lands to prevent the spread and establishment of
invasive non-native plants and to reduce hazards
caused by excessive fuel loads. The lands that would
be selected for weed control or fuels reduction
treatments include areas on public lands in Alaska
where invasive plants occur and areas with an
abundance of fire fuels that increase the likelihood of
catastrophic fire. The objective of treatments is to
restore land health. In the future, areas of proposed
treatment would be prioritized and analyzed under an
appropriate NEPA document. Given that the BLM
would propose future treatments on public lands only,
other lands would not be available for the purpose.
Lands administered by other federal agencies in Alaska
are directed by their own planning documents. State-
and Native Corporation-administered lands cannot be
considered in a BLM plan, and under BLM policy
other public lands outside of Alaska are not considered
under ANILCA.
Evaluation of Other Alternatives that Would
Reduce or Eliminate the Use, Occupancy, or
Disposition of Public Lands Needed for
Subsistence Purposes
Other alternatives pertaining to use of herbicides on
public lands needed for subsistence include the action
alternatives, which are presented and analyzed in
Chapters 2 and 4 of the main body of the PEIS. These
alternatives were developed based on the alternatives
in the 2007 PEIS, and address many of the concerns
raised during scoping for the 2007 PEIS and for this
PEIS, including risks associated with aerial spraying
and use of acetolactate synthase (ALS) inhibiting
active ingredients. These alternatives represent a range
of options for feasibly attaining or approximating the
BLM’s objectives for herbicide use, as expressed in its
programs, policies, and land use plans.
Findings
The No Action Alternative would not significantly
restrict subsistence use in Alaska. Although no
herbicide treatments under the vegetation management
program have occurred in Alaska to date, some
herbicide use is proposed for the future. For all future
projects, individual, site-specific NEPA analysis is
required prior to implementing the project. In this way,
the BLM would be able to define with local input what
SOPs and mitigation measures would be required to
prevent damage to subsistence plants and animals.
When projects are proposed, local communities would
be given the opportunity to participate in the planning
process and assist with the design of proposed
treatments. The No Action Alternative also includes all
of the SOPs and mitigation measures from the 2007
PEIS that have been developed to minimize impacts to
resources and human health. Over the long term,
actions to reduce the spread of invasive plants and
reduce wildfire risk would likely benefit subsistence
resources.
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Evaluation and Finding for Alternative B - Allow
for Use of Three New Herbicides in 17 Western
States (Preferred Alternative)
Alternative B, the Preferred Alternative, would allow
the BLM to use aminopyralid, fluroxypyr, and
rimsulfuron, in addition to the 18 currently approved
active ingredients, in its herbicide treatment programs.
Under this alternative, as under the other alternatives,
the estimated maximum acreage of herbicide
treatments on public lands in 17 western states is
932,000 acres annually. Within Alaska, it is estimated
that no more than 1,000 acres of public lands would be
treated with herbicides in any given year. Only
herbicides that are registered for use in Alaska would
be applied in the state. Formulations of aminopyralid,
fluroxypyr, and rimsulfuron are registered in Alaska,
so all three could be used in the state.
All herbicide treatments would be guided by SOPs that
serve to protect habitat and resources from potential
impacts, as well as mitigation measures developed for
the currently approved herbicides, which can be found
in the 2007 PEIS and the associated ROD.
Additionally, all of the mitigation developed for use of
the three new herbicides would be followed, as
applicable. This mitigation is presented in Table 2-5 of
the PEIS.
Evaluation of the Effect of Use, Occupancy, or
Disposition on Subsistence Uses and Needs
Potential effects to subsistence resources under the
Preferred Alternative would be similar to those under
the No Action Alternative. There would be no
difference between the alternatives as far as the goals
of herbicide treatments or the land areas affected,
although the mix of herbicides used could be different.
Use of herbicides would have both beneficial and
adverse effects, with a potential long-term benefit of
reducing or eliminating target infestations of invasive
plant species.
Plants, fish, and wildlife used for subsistence could be
adversely affected by herbicide treatments. It is
assumed that non-target plants could be impacted by
treatments utilizing any of the active ingredients,
although the species impacted and level of effect would
vary by active ingredient used. Herbicide treatments
could temporarily displace wildlife, and could result in
toxicological impacts to fish and wildlife.
Toxicological risks would vary based on the active
ingredients used. All three of the new active
ingredients are of lower risk to fish and wildlife than
nearly all of the other active ingredients currently
approved for use. Additionally, use of the currently
approved herbicides with the greatest risk to fish and
wildlife would decrease under this alternative, relative
to the No Action Alternative. Therefore, toxicological
risks to fish and wildlife could also be lower under this
alternative, depending on which herbicides were
selected for use in Alaska in the future.
Evaluation of the A vai lability of Other Lands
for the Purpose Sought to be Achieved
Just like under the No Action Alternative, the lands
that would be selected for weed control or fuels
reduction treatments include areas on public lands in
Alaska where invasive plants occur and areas with an
abundance of fire fuels that increase the likelihood of
catastrophic fire. Future treatments would occur on
public lands only; other lands would not be available
for this purpose and could not be considered by the
BLM.
Evaluation of Other Alternatives that Would
Reduce or Eliminate the Use, Occupancy, or
Disposition of Public Lands Needed for
Subsistence Purposes
Other alternatives that would define the types of
vegetation management actions allowed on public
lands needed for subsistence include the other action
alternatives, and No Action Alternative, which are
presented and analyzed in Chapters 2 and 4 of the main
body of the PEIS. These alternatives represent a range
of options for feasibly attaining or approximating the
BLM’s objectives for herbicide use, as expressed in its
programs, policies, and land use plans.
Findings
The Preferred Alternative would not significantly
restrict subsistence use in Alaska. Although no
herbicide treatments under the vegetation management
program have occurred in Alaska to date, some
herbicide use is proposed for the future. For all future
projects, individual, site-specific NEPA analysis is
required prior to implementing the project. In this way,
the BLM would be able to define with local input what
SOPs and mitigation measures would be required to
prevent damage to subsistence plants and animals.
When projects are proposed, local communities would
be given the opportunity to participate in the planning
process and assist with the design of proposed
treatments. The Preferred Alternative includes all of
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ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS
the SOPs and mitigation measures from the 2007 PEIS
that have been developed to minimize impacts to
resources and human health. It also includes additional
mitigation measures for aminopyralid, fluroxypyr, and
rimsulfuron from the current PEIS to minimize impacts
to resources and human health associated with these
active ingredients. Over the long term, actions to
reduce the spread of invasive plants and reduce
wildfire risk would likely benefit subsistence
resources.
Evaluation and Findings for Alternative C - No
Aerial Application of New Herbicides
Alternative C, the No Aerial Application of New
Herbicides Alternative, would allow the BLM to use
aminopyralid, fluroxypyr, and rimsulfuron, in addition
to the 18 currently approved active ingredients, in its
herbicide treatment programs. However, only ground
applications of the new herbicides would be permitted;
aerial applications of aminopyralid, fluroxypyr, and
rimsulfuron would be prohibited. Under this
alternative, as under the other alternatives, the total
acreage of herbicide treatments on public lands in 1 7
western states would not exceed 932,000 acres
annually. Within Alaska, it is estimated that no more
than 1,000 acres of public lands would be treated with
herbicides in any given year.
Evaluation of the Effect of Use, Occupancy , or
Disposition on Subsistence Uses and Needs
Potential effects to subsistence resources under
Alternative C would be similar to those under the other
alternatives. There would be no difference among the
alternatives as far as the goals of herbicide treatments
or the land areas affected, although the mix of
herbicides used could be different. And while
aminopyralid, fluroxypyr, and rimsulfuron would only
be applied using ground methods, other active
ingredients could be applied aerially. Use of herbicides
would have both beneficial and adverse effects, with a
potential long-term benefit of reducing or eliminating
target infestations of invasive plant species.
Similar to the other alternatives, non-target plants, fish,
and wildlife used for subsistence could be adversely
affected by herbicide treatments. Wildlife could be
temporarily displaced from treatments sites, and fish
and wildlife could be subject to toxicological risks
associated with exposure to herbicides. Impacts to fish
and wildlife would vary depending on the type of fish
or wildlife exposed to the treatment, the type of
exposure, and the active ingredient(s) used.
Aminopyralid, fluroxypyr, and rimsulfuron have a
lower toxicological risk to fish and wildlife than many
of the currently approved herbicides, so this alternative
would allow the BLM more opportunities than at
present to select active ingredients that do not harm
fish and wildlife, depending on the treatment needs.
Evaluation of the A vailability of Other Lands
for the Purpose Sought to be Achieved
Just like under the other alternatives, the lands that
would be selected for weed control or fuels reduction
treatments include areas on public lands in Alaska
where invasive plants occur and areas with an
abundance of fire fuels that increase the likelihood of
catastrophic fire. Future treatments would occur on
public lands only; other lands would not be available
for this purpose and could not be considered by the
BLM.
Evaluation of Other Alternatives that Would
Reduce or Eliminate the Use, Occupancy, or
Disposition of Public Lands Needed for
Subsistence Purposes
Other alternatives that would define the types of
vegetation management actions allowed on public
lands needed for subsistence include the other action
alternatives and the No Action Alternative, which are
presented and analyzed in Chapters 2 and 4 of the main
body of the PEIS. These alternatives represent a range
of options for feasibly attaining or approximating the
BLM’s objectives for herbicide use, as expressed in its
programs, policies, and land use plans.
Findings
Alternative C would not significantly restrict
subsistence use in Alaska. Although no herbicide
treatments under the vegetation management program
have occurred in Alaska to date, some herbicide use is
proposed for the future. For all future projects,
individual, site-specific NEPA analysis is required
prior to implementing the project. In this way, the
BLM would be able to define with local input what
SOPs and mitigation measures would be required to
prevent damage to subsistence plants and animals.
When projects are proposed, local communities would
be given the opportunity to participate in the planning
process and assist with the design of proposed
treatments. Alternative C includes all of the SOPs and
mitigation measures from the 2007 PEIS that have
been developed to minimize impacts to resources and
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ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS
human health. It also includes additional mitigation
measures for 'aminopyralid, fluroxypyr, and
rimsulfuron from the current PEIS (Table 2-5) to
minimize impacts to resources and human health
associated with these active ingredients. Over the long
term, actions to reduce the spread of invasive species
and reduce wildfire risk would likely benefit
subsistence resources.
Evaluation and Findings for Alternative D - No Use
of NewAcetolactate Synthase-inhibiting Active
Ingredients (No Rimsulfuron)
Alternative D, the No Use of New Acetolactate
Synthase-inhibiting Herbicides alternative, would
allow the BLM to use aminopyralid and fluroxypyr, in
addition to the 1 8 currently approved active
ingredients, in its herbicide treatment programs.
Rimsulfuron, however, would not be added to the list
of approved active ingredients. Under this alternative,
as under the other alternatives, the total acreage of
herbicide treatments on public lands in 17 western
states would not exceed 932,000 acres annually.
Within Alaska, it is estimated that no more than 1,000
acres of public lands would be treated with herbicides
in any given year.
Evaluation of the Effect of Use, Occupancy , or
Disposition on Subsistence Uses and Needs
Under Alternative D, potential effects to subsistence
resources would be similar to those under the other
alternatives. There would be no difference among the
alternatives as far as the goals of herbicide treatments
or the land areas affected, although the mix of
herbicides used could be different. Use of herbicides
would have both beneficial and adverse effects, with a
potential long-term benefit of reducing or eliminating
target infestations of invasive plant species.
Similar to the other alternatives, non-target plants, fish,
and wildlife used for subsistence could be adversely
affected by herbicide treatments. Wildlife could be
temporarily displaced from treatment sites, and fish
and wildlife could be subject to toxicological risks
associated with exposure to herbicides. Impacts to fish
and wildlife would vary depending on the type of fish
or wildlife exposed to the treatment, the type of
exposure, and the active ingredient(s) used.
Aminopyralid and fluroxypyr have a lower
toxicological risk to fish and wildlife than many of the
currently approved herbicides, so this alternative would
allow the BLM more opportunities than at present to
select active ingredients that do not harm fish and
wildlife, depending on the treatment needs. However,
the number of new lower risk herbicides available
would be less than under the other action alternatives.
Evaluation of the A vail ability of Other Lands
for the Purpose Sought to be Achieved
Just like under the other alternatives, the lands that
would be selected for weed control or fuels reduction
treatments include areas on public lands in Alaska
where invasive non-native plants occur and areas with
an abundance of fire fuels that increase the likelihood
of catastrophic fire. Future treatments would occur on
public lands only; other lands would not be available
for this purpose and could not be considered by the
BLM.
Evaluation of Other Alternatives that Would
Reduce or Eliminate the Use, Occupancy, or
Disposition of Public Lands Needed for
Subsistence Purposes
Other alternatives that would define the types of
vegetation management actions allowed on public
lands needed for subsistence include the other action
alternatives and the No Action Alternative, which are
presented and analyzed in Chapters 2 and 4 of the main
body of this PEIS. These alternatives represent a range
of options for feasibly attaining or approximating the
BLM’s objectives for herbicide use, as expressed in its
programs, policies, and land use plans.
Findings
Alternative D would not significantly restrict
subsistence use in Alaska. Although no herbicide
treatments under the vegetation management program
have occurred in Alaska to date, some herbicide use is
proposed for the future. For all future projects,
individual, site-specific NEPA analyses is required
prior to implementing the project. In this way, the
BLM would be able to define, with local input, what
SOPs and mitigation measures would be required to
prevent damage to subsistence plants and animals.
When projects are proposed, local communities would
be given the opportunity to participate in the planning
process and assist with the design of proposed
treatments. Alternative D includes all of the SOPs and
mitigation measures from the 2007 PEIS that have
been developed to minimize impacts to resources and
human health. It also includes additional mitigation
measures for aminopyralid and fluroxypyr from the
current PEIS (Table 2-5) to minimize impacts to
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resources and human health associated with these
active ingredients. Over the long term, actions to
reduce the spread of invasive plant species and reduce
wildfire risk would likely benefit subsistence
resources.
Evaluation and Findings for the Cumulative Case
The Cumulative Case, as presented within the
Cumulative Effects Analysis in Chapter 4 of the PEIS,
is a discussion of impacts that could affect the
management decisions contained within Alternatives A
through D. The cumulative effects analysis in the PEIS
is based on the analysis in the 2007 PEIS, which was
completed for the BLM’s vegetation management
program, and which includes herbicide treatments as
well as other treatment methods. Since the three new
herbicides would be added to an existing program, with
no change in program goals or in acres or areas treated,
much of the 2007 analysis is inclusive of their use.
The analysis of cumulative impacts is a four-step
process that follows guidance provided in Considering
Cumulative Effects Under the National Environmental
Policy Act (Council on Environmental Quality [CEQ]
1997):
• Specify the class of actions of which effects
are to be analyzed.
The PEIS cumulative effects analysis considers large,
regional scale trends and issues that require integrated
management across broad landscapes, and regional-
scale trends and changes in the social and economic
needs of people.
Potential cumulative effects include those assessed for
all land ownerships, including lands administered by
other federal agencies and non-federal lands,
particularly effects on air quality and terrestrial and
aquatic species. The analysis and disclosure of
cumulative effects alerts decision-makers and the
public to the context within which effects are
occurring, and to the environmental implications of the
interactions of known and likely management
activities. During subsequent analyses for site-specific
activities, local cumulative effects should be important
considerations in the design of site-specific alternatives
and mitigation measures.
• Designate the appropriate time and space
domain in which the relevant actions occur.
The analysis period covered by the cumulative effects
analysis primarily begins in the 1930s with the passage
of the Taylor Grazing Act, and continues through 2057.
For purposes of this analysis, the spatial domain for
past, present, and reasonably foreseeable activities is
primarily the 17 western states evaluated in the PEIS.
• Determine the magnitude of effects on the
receptors and whether those effects are
accumulating.
The set of receptors assessed in the cumulative effects
analysis are the physical, biological, and human
systems discussed in Chapter 3 (Affected
Environment).
The potential extent of the total cumulative effects
(e.g., number of animals and habitat affected), and how
long the effects might last (e.g., population recovery
time), are estimated to determine the magnitude of
effects that could accumulate for each resource. Where
possible, the assessment of effects on a resource is
based on quantitative analysis (e.g., level of risk to
humans from use of an herbicide). However, many
effects are difficult to quantify (e.g., animal behaviors;
human perceptions) and a qualitative assessment of
effects is made.
The purpose of the analysis of cumulative effects in the
PEIS is to determine whether the effects are additive or
synergistic or have some other relationship. Additive
(or combined) effects on specific resources often are
difficult to detect and do not necessarily add up in the
strict sense of one plus one equals two. It is much more
likely that an additive or combined effect would be
greater than one but less than two. A synergistic effect,
in theory, is a total effect that is greater than the sum of
the additive effects on a resource. To arrive at a
synergistic effect in this example (continuing with the
numeric analogy), the total cumulative effect would
need to end up greater than two. In the highly variable
western U.S. environment, where natural variations in
population levels can exceed the impacts of human
activity, such an effect would need to be much greater
than the hypothetical two to be either measurable or
noteworthy. A countervailing effect occurs when an
impact has both adverse and beneficial effects. For
example, herbicide treatments would harm or destroy
vegetation used by some species of wildlife (adverse
effect), but would improve overall ecosystem health
that would lead to improved watershed conditions and
habitat for other wildlife (beneficial effect).
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Resource analysts have tried to keep the cumulative
analysis useful, manageable, and concentrated on
meaningful potential effects. The cumulative analysis
considers in greatest detail activities that are more
certain to happen and that are geographically in or near
public lands, and activities identified during scoping as
being of greatest concern. The guiding principles from
existing standards, criteria, and policies that control
management of the natural resources of concern have
been used to help focus the analysis. For areas where
existing standards, criteria, and policies are not
available, the resource experts used their best judgment
to focus the analysis.
Evaluation of the Effect of Such Use,
Occupancy, or Disposition on Subsistence Uses
and Needs
The PEIS Cumulative Effects Analysis in Chapter 4
does not include a specific section on subsistence. The
following information is from the wildlife, fish, and
vegetation sections, since subsistence resources fall
into these categories.
Since a similar number of acres would be treated with
herbicides under all of the alternatives considered in
the PEIS, there would be similar effects to subsistence
resources under all of the alternatives. Differences
would be limited to the relative amount of use of
various herbicides. Therefore, cumulative effects
would be similar under all the alternatives (including
the No Action Alternative), although the Preferred
Alternative and the other action alternatives could
result in an increase in the number of active ingredients
being released on public lands.
There would be short-term adverse impacts but long¬
term benefits to vegetation, fish, and wildlife, including
resources used for subsistence purposes. Potential
exposures to herbicides used by the BLM would be
cumulative to exposures to other pesticides, as well as
other chemicals that are released to the environment as
a result of human activities. Mitigation measures and
SOPs would help minimize impacts to fish, wildlife,
and native plants. A countervailing effect of long-term
improvement in ecosystem health as a result of
successful herbicide treatments would offset short-term
losses.
Although aminopyralid, fluroxypyr, and rimsulfuron
are of low toxicity to fish and wildlife, some of the
currently approved herbicides may harm these
resources through certain exposure scenarios.
Treatments would also alter wildlife habitat and
behavior. The extent of these disturbances would vary
by individual treatments. In general, large, aerial
applications of herbicides would be most likely to
result in exposures to wildlife in the area.
Subsistence users would be warned of planned
sprayings ahead of time, and may need to avoid certain
areas during and after vegetation treatments. There
may also be a perception by subsistence users that
subsistence resources are being tainted by exposure to
herbicides and other chemicals, particularly in more
pristine areas.
Treatments that improve habitat would provide long¬
term benefits to fish and wildlife. Treatments that
remove hazardous fuels from public lands and reduce
the risk of large, intense wildfire would reduce future
death and injury of wildlife and lead to improved
habitat. Treatments that control populations of non¬
native species on public lands would be expected to
benefit most fish and wildlife over the long term by
aiding in the re-establishment of native vegetation and
restoring habitats to near historical conditions.
Regardless of the alternative chosen, there would be a
cumulative loss of native vegetation and healthy
ecosystem function. Over the long term, treatments
should slow this loss and help to restore native
vegetation and natural fire regimes and benefit
ecosystem health, wildlife, and wildlife habitat.
In addition to the programmatic-level analysis provided
in the PEIS, site-specific analysis would be conducted
on proposed projects, to include an analysis of
potential effects on subsistence resources, if applicable.
Evaluation of the A vai! ability of Other Lands
for the Purpose Sought to be Achieved
The purpose sought to be achieved under the PEIS is to
use aminopyralid, fluroxypyr, and rimsulfuron in the
BLM’s herbicide treatment programs, to increase the
options available for preventing the spread and
establishment of invasive plants and reducing hazards
caused by excessive fuel loads. The lands that would
be selected for weed control or fuels reduction
treatments include areas on public lands where
invasive plants occur and areas with an abundance of
fire fuels that increase the likelihood of catastrophic
fire. The objectives of treatments are to restore land
health. In the future, proposed treatment areas would
be prioritized and analyzed under an appropriate NEPA
document. Given that future treatments would occur on
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public lands only, other lands would not be available
for this purpose. Lands administered by other federal
agencies in Alaska are directed by their own planning
documents. State- and Native Corporation-
administered lands cannot be considered in a BLM
plan, and under BLM policy other public lands outside
of Alaska are not considered under ANILCA.
Evaluation of Other Alternatives that Would
Reduce or Eliminate the Use, Occupancy, or
Disposition of Public Lands Needed for
Subsistence Purposes
In addition to the Preferred Alternative to allow use of
aminopyralid, fluroxypyr, and rimsulfuron in
vegetation treatment programs, other alternatives
would include the No Action Alternative to use only
the currently approved herbicides, and the other action
alternatives that are presented and analyzed in Chapters
2 and 4, which place certain restriction on use of the
new active ingredients. These alternatives were created
to represent a range of options for feasibly attaining or
approximating the BLM’s objectives for herbicide use
on public lands, as expressed in its programs, policies,
and land use plans.
Findings
Actions described in the PEIS, when taken into
consideration with the analysis presented as the
cumulative case, would not significantly restrict
subsistence use and needs in Alaska. While herbicide
treatments are likely to occur in Alaska in the future,
the estimated treatment area is 1,000 acres or less,
statewide, per year. Additionally, the new herbicides
being proposed for use are of lower toxicity to fish and
wildlife that might be used for subsistence than many
of the currently approved herbicides. When proposed,
site-specific projects will continue to require additional
NEPA analysis, which will include public input and
consultation with local native communities and entities
that could be affected. A subsequent ANILCA § 810
Analysis of Subsistence Impacts will also be required
for each proposed project.
Environmental Justice
Executive Order 12898, Federal Actions to Address
Environmental Justice in Minority Populations and
Low-Income Populations, and an accompanying
Presidential memorandum require each federal agency
to make the consideration of environmental justice part
of its mission. The existing demographics (race and
income) and subsistence consumption of plants and
animals, and mitigating measures and their effects are
presented.
Consultation and Coordination with Indian Tribal
Governments
Executive Order 13175, Consultation and
Coordination with Indian Tribal Governments, requires
consultation with tribal governments on “actions that
have substantial direct effects on one or more Indian
tribes.” Representatives of the BLM have solicited
input from local tribal governments and Alaska Native
Corporations to discuss subsistence issues relating to
use of aminopyralid, fluroxypyr, and rimsulfuron (see
Chapter 5, Consultation and Coordination). The BLM
has also met with local tribal governments to discuss
use of herbicides in the larger vegetation treatment
program, and has established a dialogue on
environmental justice with these communities.
Executive Order 12898 also calls for an analysis of the
effects of federal actions on minority populations with
regard to subsistence. Specifically, environmental
justice is:
The fair treatment and meaningful involvement of
all people regardless of race, color, national origin,
or income with respect to the development,
implementation, and enforcement of
environmental laws, regulations, and policies. Fair
treatment means that no group of people, including
racial, ethnic, or socioeconomic group should bear
a disproportionate share of the adverse
environmental consequences resulting from
industrial, municipal, and commercial operations
or the execution of federal, state, local, and tribal
programs and policies.
Section 4-4 of Executive Order 12898, regarding the
Subsistence Consumption of Fish and Wildlife,
requires federal agencies to collect, maintain, and
analyze information on the consumption patterns of
populations that principally rely on fish and/or wildlife
for subsistence, and to communicate to the public any
risks associated with the consumption patterns. To this
end, the subsistence analyses of all alternatives, located
in Chapter 4 (Environmental Consequences) of the
PEIS, have been reviewed and found to comply with
environmental justice requirements.
Further guidance is found in the CEQ document,
Environmental Justice - Guidance under the National
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
C-10
January 2016
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS
Environmental Policy Act , December 1997, and
USEPA, Region 1, Interim Environmental Justice
Policy December 2000. Additionally, the USDOI has
an Environmental Justice Strategic Plan 2012 - 2017
(USDOI 2012).
Government-to-Government Consultation with
Federally-Recognized Tribes
The BLM formally consults with federally recognized
tribes before taking actions that will have a substantial,
direct effect on federally recognized tribes or their
assets, rights, services, or programs. The BLM initiated
consultation with Alaska Native groups in the form of
a letter sent on April 18, 2013, to 5 19 tribes and Alaska
Native Corporations throughout the 17 states that could
be directly affected by vegetation management
activities. The letter requested information on how the
proposed activities could impact Native American and
Alaska Native interests, including the use of vegetation
and wildlife for subsistence, religious, and ceremonial
purposes. The Alaska BLM District office in Fairbanks
made the decision not to hold one or more public
scoping meetings in Alaska based on low attendance at
the meetings for the earlier PEIS, low past and
projected future use of herbicides in Alaska, and the
overlap of the public scoping period with that of an
Environmental Assessment for a different project
involving herbicide use ( The Dalton Management Area
Integrated Invasive Plant Strategic Plan). In lieu of a
public scoping meeting, the BLM Fairbanks District
office offered to host a web-based meeting for anyone
who wanted to learn more about the project and
provide comments. As no members of the public
responded to this offer, no web-based meeting for the
project was held.
When future vegetation treatment projects are
proposed, local BLM offices will initiate site-specific
analysis and NEPA documentation. This process will
include consultation with Alaska Native groups to
determine if culturally important areas and plants could
be impacted by proposed vegetation treatments.
Proposed treatments of plants that are important for
maintaining traditional lifeways may need to be
modified or cancelled in certain areas. On the other
hand, there may be long-term benefits, such as
reducing or eliminating invasive plant competitors,
which would allow proliferation of traditionally used
plants.
References
Council on Environmental Quality. 1997.
Considering Cumulative Effects Under the
National Environmental Policy Act.
Washington, D.C.
Hebert, M. 2001. Strategic Plan for Noxious and
Invasive Plants Management in Alaska.
University of Alaska. Fairbanks, Alaska.
U.S. Department of Interior (USDOI). 2012.
Environmental Justice Strategic Plan 2012
2017. Office of Environmental Quality and
Compliance. Washington, D.C.
U.S. Department of Interior Bureau of Land
Management (USDOI BLM). 2007a. Final
Vegetation Treatments on Bureau of Land
Management Lands in 17 Western States
Programmatic Environmental Impact
Statement. Washington, D.C. Available at:
http://www.blm.gov/wo/st/en/prog/more/veg
eis.html.
_ . 2007b. Record of Decision for Vegetation
Treatments Using Herbicides on Bureau of
Land Management Lands in 17 Western States
Programmatic Environmental Impact
Statement. Washington, D.C. Available at:
http://www.blm.gov/wo/st/en/prog/more/veg
eis.html.
_ . 2009. Draft Dalton Management Area
Integrated Invasive Plant Strategic Plan.
Central Yukon Field Office. Fairbanks,
Alaska.
_ . 2013. Dalton Management Area Integrated
Invasive Plant Strategic Plan Environmental
Assessment. Central Yukon Field Office.
Fairbanks, Alaska.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
C-ll
January 2016
'
.
APPENDIX D
DESCRIPTION OF VEGETATION
MACROGROUPS
*
MACROGROUP DESCRIPTIONS
APPENDIX D
DESCRIPTION OF VEGETATION
MACROGROUPS
Introduction
This appendix provides descriptions of the subset of
macrogroups that comprise the majority of the BLM’s
proposed vegetation treatments, as referenced in Table
4-9 of this PEIS. Table D-l provides a list of all the
vegetation macrogroups occurring on BLM-
administered lands in the western U.S., as well as their
associated classes, subclasses, formations, and
divisions.
The macrogroup is a middle-level classification in the
hierarchy of the revised United States National
Vegetation Classification1. The middle-level
classifications are based on plant physiognomy,
biogeography, and floristics. The macrogroup level
classification is based on “combinations of moderate
sets of diagnostic plant species and diagnostic growth
forms that reflect biogeographic differences.”
The ecological context of the macrogroup level is sub¬
continental to regional differences in mesoclimate,
geology, substrates, hydrology, and disturbance
regimes. An example of a scientific name for a
macrogroup is the Pseudotsuga menziesii-Quercus
garryana-Pinus ponderosa-Arbutus menziesii
(Douglas-fir-Oregon white oak-ponderosa pine-Pacific
madrone) macrogroup. The colloquial name for this
macrogroup is Northern Vancouverian Montane and
Foothill Forest.
In order to match the geographical breakdown in the
2007 PEIS, the macrogroup descriptions in this section
are presented by ecoregion. Descriptions for
macrogroups found in more than one ecoregion are
repeated, where applicable. Descriptions come directly
from the U.S. National Vegetation Classification web
site.
Marine Ecoregion
Californian-Vancouverian Foothill
and Valley Forest and Woodland
These forests occur along the Pacific Coast lowlands
from southern California to southern British Columbia.
They occur inland from the coast, in the dry interior
lowland valleys, some on the east side of the Cascades,
and are drought-tolerant. These forests are not part of
the Temperate Coastal Rainforest. Dominant species
within this macrogroup are Pseudotsuga menziesii ,
Pinus ponderosa , Quercus garryana , Quercus kelloggii
(California black oak), Lithocarpus densiflorus
(tanoak), Umbellularia californica (California laurel),
and Arbutus menziesii.
Vancouverian Lowland and Montane
Rainforest
This macrogroup consists of tall forests 164 to 328 feet
(50 to 100 meters) dominated by evergreen needle¬
leaved trees of the Pacific Northwest coast, limited to
the coast, in lowland valleys, and lower mountain
slopes (below subalpine snow pack) of the Coastal and
Cascade Ranges. Forests include those influenced by
salt spray exposure, the interior forests of the
windward and leeward Coast and Cascade Ranges, and
cool temperate lower montane forests where winter
snowpack typically lasts for 2 to 6 months, sometimes
referred to as the “rain-on-snow” zone because of the
common occurrence of major winter rainfall on an
established snowpack. Climate is wet, mild maritime.
1 Available at: http://usnvc.org/.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
D-l
January 2016
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BLM Vegetation Treatments Three New Herbicides D-5
Final Programmatic EIS
January 2016
Table D-l (Cont.)
Vegetation Classification System for Western States
MACROGROUP DESCRIPITONS
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BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
D-6
January 2016
MACROGROUP DESCRIPTIONS
Forests along the immediate coast experience
uniformly wet and -mild climate, where precipitation
averages 79 to 118 inches (2,000 to 3,000 millimeters)
per year, with frequent fog and low clouds during
warmer months, and additional precipitation from fog
drip can be significant. Away from the coast, climate is
still mild but with more moisture and temperature
extremes. Major forest tree species are Pseudotsuga
menziesii, Tsuga heterophylla (western hemlock),
Thuja plicata (western redcedar), A hies amabilis
(Pacific silver fir), Chamaecyparis nootkatensis
(Alaska cedar), and Picea sitchensis (Sitka spruce).
The deciduous broad-leaved trees Alnus rubra (red
alder) and Acer macrophyllum (bigleaf maple) are
abundant on recently disturbed sites. Pinus contorta
(lodgepole pine) is common along the ocean. Abies
grandis (grand fir) and Pinus monticola (western white
pine) occur sporadically and Sequoia sempervirens
(redwood), Umbellularia californica, and
Chamaecyparis lawsoniana (Port Orford cedar) are
found in southern Oregon and northern California.
Southern Vancouverian Lowland
Grassland and Shrubland
This macrogroup is found from Vancouver Island
down the Pacific Coast to San Francisco. It occurs
along the coast on coastal terraces and ridgeline balds
in the Coast Ranges, the Klamath Mountains, and at
low elevations on the lee side of the coastal mountains
in the northern part of the range. Steep slopes on
coastal bluffs and headlands are typical occurrences of
this macrogroup, though sometimes it can be found on
relatively level ridgelines. Attributable to shallow soils,
steep slopes, sunny aspect, and/or upper slope position,
these sites are dry and marginal for tree establishment
and growth except in favorable microsites. The
vegetation is grassland with some dwarf-shrubs, which
can occur as small patches but are usually in a matrix
with the herbaceous vegetation. Bunchgrasses are often
dominant and may include Calamagrostis nutkaensis
(Pacific reedgrass), Festuca rubra (red fescue),
Festuca roemeri (Roemer’s fescue), or Danthonia
californica (California oatgrass). Dwarf-shrub species
imbedded in the herbaceous cover often include
Arctostaphylos uva-ursi (kinnikinnick), Arctostaphylos
Columbiana (hairy manzanita), Arctostaphylos
nevadensis (pinemat manzanita), Gaultheria shallon
(salal), Juniperus communis (common juniper), Rubus
spectabilis (salmonberry), and Vaccinium ovatum
(California huckleberry). Occasionally, scattered
stunted trees, such as Picea sitchensis , Pseudotsuga
menziesii or Quercus garryana , can be present.
Mediterranean Ecoregion
California Forest and Woodland
This macrogroup consists of savannas, woodlands, and
forests dominated by Californian endemic oak and
conifer species. These woodlands occur almost entirely
within California below 8,000 ft (2,450 m). They
include the oak woodlands of Quercus agrifolia
(California live oak), Quercus lobata (valley oak), and
Quercus douglasii (blue oak). Stands include rare
endemic evergreen coniferous forests limited to the
coast including Hesperocyparis macrocarpa (Monterey
cypress), Cupressus sargentii (Sargent’s cypress),
Pinus muricata (Bishop pine), and Pinus torreyana
(Torrey pine), as well as the more widespread, rugged
Pinus sabiniana (California foothill pine) and Pinus
coulteri (Coulter pine).
Californian-Vancouverian Foothill
and Valley Forest and Woodland
These forests occur along the Pacific Coast lowlands
from southern California to southern British Columbia.
They occur inland from the coast, in the dry interior
lowland valleys, some on the east side of the Cascades,
and are drought-tolerant. These forests are not part of
the Temperate Coastal Rainforest. Dominant species
within this macrogroup are Pseudotsuga menziesii,
Pinus ponderosa, Quercus garryana, Quercus
kelloggii, Lithocarpus densijlorus , Umbellularia
californica, and Arbutus menziesii.
Southern Vancouverian Montane and
Foothill Forest
This macrogroup includes forests and woodlands of
foothill and lower montane elevations of the southern
Cascade and Klamath Mountains, the Modoc Plateau,
and the Sierra Nevada, Peninsula, and Transverse
Ranges. This macrogroup covers a broad range of
elevation and latitude, and for the most part occurs in
relatively dry habitats. It includes dry montane Pinus
jejfreyi (Jeffrey pine)- Pinus ponderosa woodlands;
Sierran mixed conifer woodlands dominated by
Pseudotsuga menziesii, Pinus ponderosa, Calocedrus
decurrens (Incense cedar), Abies concolor (white fir),
Abies magnifica (California red fir), Pinus lambertiana
BI.M Vegetation Treatments Three New Herbieides
Final Programmatic EIS
D-7
January 2016
MACROGROUP DESCRIPTIONS
(sugar pine), Pinus jeffreyi , or Sequoiadendron
giganteum (giant sequoia); mixed conifer woodlands
tolerant of serpentine soils; and the forests on the east
side of the Sierra Nevada, on the Modoc Plateau and in
the Warner Mountains that are dominated by Pinus
monticola and/or Abies concolor var. lowiana (Sierra
white fir) where Pinus ponderosa is often present, but
Pseudotsuga menziesii is notably absent.
California Chaparral
This macrogroup is composed of evergreen
sclerophyllous shrubland that dominates the
cismontane side of the coastal mountain ranges from
about San Francisco south to Ensanada in Baja
California, and east into the foothills of the Sierra
Nevada. It reaches its greatest extent in the Transverse
and Peninsular ranges of central and southern
California but is also an important part of the western
foothills of the Sierra Nevada. Chaparral occurs from
sea level to 4,921 feet (1,500 meters). Chaparral is
closely associated with the Mediterranean climate
pattern of winter rain and summer drought. Within that
climate regime it can be found under a wide range of
rainfall and temperature conditions, but over 60 percent
of the current distribution is in areas that receive
between 10 and 30 inches (250 and 750 millimeters) of
annual precipitation, and where average January daily
temperature falls between 41 and 59 °F (5 and 15 °C),
indicating that summer drought stress may limit
chaparral shrub seedling establishment and that injury
to adult shrubs from winter freezes may impose
species-specific distributional limits. Chaparral soils
tend to be shallow and rocky. Substrates include
fractured sandstones and shales, coarse-grained
decomposed granitic soils, fine-grained weathered
volcanics, and mafic substrates such as serpentines and
gabbros. These substrates add to the landscape
diversity and have substantial effects on plant species
diversity. The diversity of shrubs in chaparral includes
shrub species such as Adenostoma fasciculatum
(chamise), Ceanothus cuneatus (buckbrush),
Ceanothus megacarpus (bigpod ceanothus), Ceanothus
crassifolius (hoaryleaf ceanothis), several species of
Arctostaphylos (manzanita), and Cercocarpus
montanus (alderleaf mountain mahogany).
Cool Interior Chaparral
This macrogroup consists of chaparral that occurs on
side slopes between low-elevation desert landscapes
and higher pinyon-juniper woodlands of the western
and central Great Basin on steep, exposed slopes with
rocky and/or shallow soils, and among montane forests
above 4,550 feet (1,500 meters), from the southern
Cascades of Oregon to the Peninsular Ranges of
California into Baja California, Mexico, where much
annual precipitation occurs as snow. These hardy
shrublands have open canopies with little undergrowth
and are dominated by evergreen or winter-deciduous
shrubs. Dominant shrubs include Arctostaphylos
glandulosa (Eastwood’s manzanita), Arctostaphylos
nevadensis ,
manzanita),
manzanita),
ceanothus),
Ceanothus
integerrimus
Arctostaphylos patula
Arctostaphylos pungens
Ceanothus cordulatus
Ceanothus diversifolius
greggii (desert ceanothus),
(deerbrush), Ceanothus
(greenleaf
(pointleaf
(whitethorn
(pinemat),
Ceanothus
pinetorum
(Coville ceanothus), Ceanothus sanguineus (redstem
ceanothus; in Oregon), Ceanothus velutinus
(snowbrush ceanothus), Cercocarpus intricatus
(litteleaf mountain mahogany), Cercocarpus montanus
var. glaber (birchleaf mountain mahogany),
Chrysolepis sempervirens ( =Castanopsis empervirens ;
bush chinquapin), Eriogonum fasciculatum (Eastern
Mojave buckwheat), Garrya flavescens (ashy siltassel),
Holodiscus discolor {=Holodiscus microphyllus\
oceanspray), Prunus emarginata (bitter cherry),
Prunus subcordata (Klamath plum), Prunus virginiana
(chokecherry), Purshia stansburiana (Stansbury
cliffrose), Quercus garryana var. breweri (Brewer’s
oak), Quercus turbinella (Sonoran scrub oak), and
Rhus trilobata (skunkbush sumac). Most of these
chaparral species are fire-adapted, resprouting
vigorously after burning or producing fire-resistant
seeds.
California Annual and Perennial
Grassland
This macrogroup is found in Mediterranean California
from 30 to 3.600 feet (10 to 1,200 meters), with cool,
wet winters and hot, dry summers, receiving on
average 20 inches (50 centimeters; range 10 to 30
inches [25 to 100 centimeters]) of precipitation per
year, mainly as winter rain. It is found with fine-
textured soils, moist or even waterlogged in winter, but
very dry in summer. Historically, these grasslands were
common among oak savanna and woodland and
probably experienced similar frequent fire regimes.
Today they are limited to small relictual, remnant and
restored stands. These communities are best
represented on xeric to mesic ultramafic (a type of
igneous rock) sites where alien annual grasses are less
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
D-8
January 2016
MACROGROUP DESCRIPTIONS
well-adapted. Wet ultramafic sites may contain stands
of Muhlenbergia - rigens (deergrass) or Leyrnus
triticoides (beardless wildrye). Characteristic plant
species include a dominance by native, cool-season
bunchgrasses Nassella pulchra (purple needlegrass),
Nassella cernua (nodding needlegrass), Nassella lepida
(foothill needlegrass), Aristida species (threeawn),
Agoseris heterophylla (annual agoseris), Elymus
glaucus (blue wildrye), Leymus triticoides (beardless
wildrye), Festuca californica (California fescue,),
Melica californica (California melicgrass), and Poa
secunda ( =Poa scabrella\ Sandberg bluegrass), and
native forbs such as Achyrachaena mollis (blow
wives), Bloomeria crocea (common goldenstar),
Triteleia ixioides ( =Brodiaea lutea; prettyface),
Chlorogalum pomeridianum (wavyleaf soap plant),
Clarkia purpurea (winecup clarkia), Dodecatheon
jeffreyi (Sierra shootingstar), Achillea millefolium var.
borealis ( =Achillea borealis ; boreal yarrow), and
Castilleja attenuata ( =Orthocarpus attenuatis;
attenuate Indian paintbrush).
California Ruderal Grassland and
Meadow
This macrogroup encompasses the non-native-
dominated annual grasslands found in California. They
occur on the coastal plains, in the Central Valley, in the
foothills and in disturbed rural and urban areas.
California annual grassland is found on a wide variety
of soils, sometimes in complex mosaics. Most are
noncalcic Mollisols, medium to heavy texture, about
1.6 feet (0.5 meters) deep. Native graminoid and forb
species can be present with low or insignificant cover.
The overwhelming dominance of introduced species is
undeniable. Non-native species make up 50 to 96
percent of the foliar cover. Dominant introduced
graminoid species include Avena fatua (wild oat),
Bromus diandrus (ripgut brome), Bromus hordeaceus
(soft brome), Bromus madritensis (compact brome),
Folium perenne ssp. multiflorum ( =Lolium
multiflorum’, Italian ryegrass), Taeniatherum caput-
medusae (medusahead rye), and Aegilops triuncialis
(barbed goatgrass). Introduced forb species include
Erodium botrys (longbeak stork’s bill), Erodium
cicutarium (redstem stork’s bill), Medicago
polymorpha (burclover), Geranium dissectum (cutleaf
geranium), Hypochaeris glabra (smooth cat’s ear), and
Carduus pycnocephalus (Italian plumeless thistle).
There are many more species that can be dominant.
Subtropical Desert Ecoregion
Madrean Warm Montane Forest and
Woodland
This woodland and forest group occurs in mountains
and plateaus in the Sierra Madre Occidentale and
Sierra Madre Orientate in Mexico, Trans-Pecos Texas,
southern New Mexico and Arizona, generally south of
the Mogollon Rim. These forests and woodlands are
composed of Madrean pines ( Pinus arizonica [Arizona
pine], Pinus engelmannii [Apache pine], Pinus
leiophylla [Chihuahuan pine], Pinus strobiformis
[Southwestern white pine]) or madrones {Arbutus
arizonica [Arizona madrone], Arbutus xalapensis
[Texas madrone]) and evergreen oaks {Quercus
arizonica [Arizona white oak], Quercus emoryi
[Emory oak], Quercus gravesii [Chisos red oak],
Quercus grisea [gray oak], Quercus hypoleucoides
[silverleaf oak], or Quercus rugosa [netleaf oak])
intermingled with patchy shrublands on most mid¬
elevation slopes 4,790 to 7,546 feet (1,460 to 2,300
meters). In northern stands, Pinus ponderosa
dominates with Madrean oak species. This group also
includes Hesperocyperis arizonica (Arizona cypress)-
dominated stands with Quercus hypoleucoides or
Quercus rugosa in the understory. Other tree species
may include Juniperus deppeana (alligator juniper),
Juniperus flaccida (drooping juniper), Pinus
cembroides (Mexican pinyon), Pinus discolor (border
pinyon), and Pseudotsuga menziesii. Subcanopy and
shrub layers may include typical encinal (found in oak
groves) and chaparral species, such as Agave spp.
(agave), Arctostaphylos pringlei (Pringle manzanita),
Arctostaphylos pungens (pointleaf manzanita), Garrya
wrightii (Wright’s silktassel), Nolina spp. (beargrass),
and Quercus turbinella. Some stands have moderate
cover of perennial graminoids, such as Muhlenbergia
emersleyi (bullgrass), Muhlenbergia longiligula
(longtongue muhly), Muhlenbergia virescens
(screwleaf muhly), and Schizachyrium cirratum (Texas
bluestem).
Warm Interior Chaparral
This macrogroup occurs prominently across central
Arizona (Mogollon Rim) and western New Mexico,
south into mountains in the northwestern Chihuahuan
region and Madrean Occidentale in northern Mexico,
and north into extreme southwestern Utah and southern
Nevada. It also occurs in mountains in the Sonoran and
western Mojave Deserts, and extends from northeast
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
D-9
January 2016
MACROGROUP DESCRIPTIONS
Kern County, California, and south into Baja Norte,
Mexico. Stands are found on foothills, xeric mountain
slopes and canyons in hotter and drier habitats and
often dominate along the mid-elevation transition zone
between desert scrub and montane woodlands 3,281 to
7,218 feet (1,000 to 2,200 meters). Sites are often steep
and rocky. Parent materials are varied and include
basalt, diabases, gneiss, schist, shales, slates,
sandstones, and more commonly, limestone and
coarse-textured granitic substrates. The vegetation is
characterized by a moderate to dense evergreen shrub
layer dominated by sclerophyllous shrubs such as
Quercus turbinella and Ceanothus greggii. Other
common shrubs from the eastern portion of its range
(Arizona and New Mexico) include Quercus toumeyi
(Tourney oak), Cercocarpus montanus var.
paucidentatus (hairy mountain mahogany), Garrya
wrightii, Purshia stansburiana, Rhus trilobata (Tucker
oak), with Arctostaphylos pungens and Arctostaphylos
pringlei at higher elevations. In desert chaparral stands
in the western part of the range, Quercus john-tuckeri
(Tucker oak), Quercus cornelius-mulleri (Muller oak),
Quercus berberidifolia (scrub oak), Arctostaphylos
patula, Arctostaphylos glauca (bigberry manzanita),
Rhus ovate (sugar sumac), Cercocarpus montanus var.
glaber, Garrya flavescens , Juniperus californica
(California juniper), and Nolina parry i (Parry’s
beargrass) characterize this shrubland.
Chihuahuan Desert Scrub
This macrogroup typically occurs as invasive upland
shrublands that are concentrated in the extensive desert
grassland in foothills and piedmonts of the Chihuahuan
Desert, extending into the Sky Island region to the
west. Substrates are typically derived from alluvium,
often gravelly without a well-developed argillic or
calcic soil horizon that would limit infiltration and
storage of winter precipitation in deeper soil layers.
Prosopis spp. (mesquite) and other deep-rooted shrubs
exploit this deep-soil moisture that is unavailable to
grasses and cacti. Vegetation is typically dominated by
Prosopis glandulosa (honey mesquite) or Prosopis
velutina (velvet mesquite) and succulents. Other desert
scrub species that can codominate include Acacia
neovernicosa (viscid acacia), Acacia constricta
(whitethorn acacia), Juniperus monosperma (oneseed
juniper), or Juniperus coahuilensis (redberry juniper).
Larrea tridentata (creosote bush) is typically absent or
has low cover. Grass cover is typically low and
composed of desert grasses such as Dasyochloa
pulchella ( =Erioneuron pulchellum ; low woollygrass),
Muhlenbergia porteri (bush muhly), Muhlenbergia
setifolia (curlyleaf muhly), and Pleuraphis mutica
(tobosagrass). 1
«•
k
Southern Plains Scrub Woodland and
Shrubland
This macrogroup ranges from the High Plains, Rolling
Plains, and Red Bed Plains of Texas and Oklahoma,
south into parts of the Edwards Plateau and
Chihuahuan Desert regions of Texas. The open to
closed canopy is dominated or codominated by
Prosopis glandulosa var. glandulosa (honey mesquite).
Associated species can include Ziziphus obtusifolia
(lotebush), Quercus fusiformis (Texas live oak),
Sideroxylon lanuginosum (gum bully), Aloysia
gratissima (whitebrush), Mahonia trifoliolata
(algerita). Yucca glauca (soapweed yucca), Opuntia
spp. (pricklypear), Acacia greggii (catclaw acacia),
Mimosa spp. (mimosa), Rhus lanceolata (prairie
sumac), Nassella leucotricha (Texas wintergrass),
Bouteloua curtipendula (sideoats grama), Bouteloua
gracilis (blue grama), Bouteloua hirsute (hairy grama),
Buchloe dactyloides (buffalograss), Schizachyrium
scoparium (little bluestem), Ruellia nudiflora
(Runyon’s wild petunia), Croton monanthogynus
(prairie tea), Rhynchosia senna (Texas snoutbean), and
Indigofera miniata (coastal indigo).
Subtropical Steppe Ecoregion
Rocky Mountain Two-Needle Pinyon-
Juniper Woodland
These woodlands are composed of Pinus edulis
(twoneedle pinyon), Juniperus osteosperma (Utah
juniper), or Juniperus monosperma. Pinus edulis
and/or Juniperus osteosperma- dominated woodlands
occur on dry mountains and foothills of the Colorado
Plateau region. Juniperus monosperma-dovnmdLXed
woodlands have an understory of perennial grasses
such as Bouteloua gracilis and Pleuraphis jamesii
(James’ galleta) and other herbaceous species typical
of the shortgrass prairie. These woodlands occur along
the east and south foothill slopes of the southern Rocky
Mountains and into the plains of southeastern Colorado
and northern and central New Mexico. Pinus edulis
and/or Juniperus monosperma- dominated woodlands
exist on dry mountains and foothills in southern
Colorado east of the Continental Divide, and in
mountains and plateaus of northern and central New
Mexico.
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MACROGROUP DESCRIPTIONS
Great Plains Shortgrass Prairie and
Shrubland
The shortgrass prairie in this macrogroup is dominated
by the shortgrasses Bouteloua gracilis and Buchloe
dactyloides. Shrublands in this macrogroup are
dominated by Prosopis glandulosa. The shortgrass
prairies occur on flat to rolling uplands. The surface
soil may be sandy loam, loam, silt loam, or loamy clay.
The subsoil is often finer than the surface soil. The
shortgrass prairies are characterized by a moderate to
dense sod of short grasses with scattered mid grasses
and forbs. The foliage of these species is 3 to 7 inches
(7 to 19 centimeters) tall, while the flowering stalks of
Bouteloua gracilis may reach 18 inches (45
centimeters). The mid grasses are usually stunted by
the arid conditions and often do not exceed 2.3 feet
(0.7 meters). Other short graminoids found in this
community are Bouteloua hirsuta (hairy grama), Carex
duriuscula (needleleaf sedge), Carex inops ssp.
heliophila (sun sedge), and Carex fdifolia (threadleaf
sedge; in Nebraska). Several mid grasses occur
regularly, such as Aristida purpurea (purple threeawn),
Bouteloua curtipendula, Pascopyrum smithii (western
wheatgrass), Schizachyrium scoparium, Elymus
elymoides (squirreltail), Sporobolus cryptandrus (spike
dropseed), Hesperostipa comata (=Stipa comata;
needle and thread), and Vulpia octoflora (sixweeks
fescue). Forbs such as Astragalus spp. (milkweed),
Gaura coccinea (scarlet beeblossom), Machaeranthera
pinnatifida var. pinnatifida (lacy tansyaster), Opuntia
polyacantha (plains pricklypear), Plantago patagonica
(woolly plantain), Psoralidium tenuiflorum (slimflower
scurfpea), Ratibida columnifera (upright prairie
coneflower), and Sphaeralcea coccinea (scarlet
globemallow) are common throughout the shortgrass
prairies.
Apacherian-Chihuahuan Semi-Desert
Grassland and Steppe
This macrogroup occurs in the northern Chihuahuan
Desert and adjacent Sky Islands and Sonoran Desert,
extending into limited areas of the southern Great
Plains on alluvial flats, loamy plains, and basins
sometimes extending up into lower piedmont slopes
and broad mesas. Included in this macrogroup are the
mesic grasslands that occur in relatively small
depressions or swales and along drainages that receive
runoff from adjacent areas. Occupying low topographic
positions, these sites generally have deep, fine-textured
soils that are neutral to slightly or moderately
saline/alkaline. Vegetation is characterized by a
moderately dense to dense graminoid layer of perennial
grasses that is typically dominated by Pleuraphis
mutica or with Bouteloua eriopoda (black grama)
codominant (more historically) or Bouteloua gracilis
on broad alluvial plains and flats. In mesic swales and
depressions and along drainages, Sporobolus airoides
(alkali sacaton), Sporobolus wrightii (big sacaton), and
Pleuraphis mutica (tobosa swales) dominate,
sometimes with other mesic graminoids such as
Pascopyrum smithii or Panicum obtusum (vine
mesquite). Sporobolus airoides is more common in
alkaline soils and along drainages. In degraded stands,
Scleropogon brevifolius (burrograss), Dasyochloa
pulchella, or Aristida spp. may co-dominate.
Pleuraphis jamesii can become important in northern
stands and Bouteloua gracilis in the Great Plains and
on degraded stands. Scattered shrub or succulent
species can be present, especially on degraded sites and
along drainages and in depressions.
Warm Interior Chaparral
This macrogroup occurs prominently across central
Arizona (Mogollon Rim) and western New Mexico,
south into mountains in the northwestern Chihuahuan
region and Madrean Occidentale in northern Mexico,
and north into extreme southwestern Utah and southern
Nevada. It also occurs in mountains in the Sonoran and
western Mojave Deserts, and extends from northeast
Kern County, California, and south into Baja Norte,
Mexico. Stands are found on foothills, xeric mountain
slopes and canyons in hotter and drier habitats, and
often dominate along the mid-elevation transition zone
between desert scrub and montane woodlands at 3,281
to 7,218 feet (1,000 to 2,200 meters). Sites are often
steep and rocky. Parent materials are varied and
include basalt, diabases, gneiss, schist, shales, slates,
sandstones, and more commonly, limestone and
coarse-textured granitic substrates. The vegetation is
characterized by a moderate to dense evergreen shrub
layer dominated by sclerophyllous shrubs such as
Quercus turbinella and Ceanothus greggii. Other
common shrubs from the eastern portion of its range
(Arizona and New Mexico) include Quercus toumeyi,
Cercocarpus montanus var. paucidentatus , Garrya
wrightii , Purshia stansburiana , Rhus trilobata , with
Arctostaphylos pungens and Arctostaphylos pringlei at
higher elevations. In desert chaparral stands in the
western part of the range, Quercus john-tuckeri ,
Quercus cornelius-mulleri, Quercus berberidifolia,
Arctostaphylos patula, Arctostaphylos glauca, Rhus
ovata, Cercocarpus montanus var. glaber
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MACROGROUP DESCRIPTIONS
(=Cercocarpus betuloides), Garrya flavescens,
Juniperus californica, and Nolina parryi characterize
this shrubland.
Chihuahuan Desert Scrub
This macrogroup typically occurs as invasive upland
shrublands that are concentrated in the extensive desert
grassland in foothills and piedmonts of the Chihuahuan
Desert, extending into the Sky Island region to the
west. Substrates are typically derived from alluvium,
often gravelly without a well-developed argillic or
calcic soil horizon that would limit infiltration and
storage of winter precipitation in deeper soil layers.
Prosopis spp. and other deep-rooted shrubs exploit this
deep-soil moisture that is unavailable to grasses and
cacti. Vegetation is typically dominated by Prosopis
glandulosa or Prosopis velutina and succulents. Other
desert scrub species that can codominate include
Acacia neovernicosa. Acacia constricta, Juniperus
monosperma, or Juniperus coahuilensis. Larrea
tridentata is typically absent or has low cover. Grass
cover is typically low and composed of desert grasses
such as Dasyochloa pulchella ( =Erioneuron
pulchellum ), Muhlenbergia porteri, Muhlenbergia
setifolia, and Pleuraphis mutica.
Southern Plains Scrub Woodland and
Shrubland
This macrogroup ranges from the High Plains, Rolling
Plains, and Red Bed Plains of Texas and Oklahoma,
south into parts of the Edwards Plateau and
Chihuahuan Desert regions of Texas. The open to
closed canopy is dominated or codominated by
Prosopis glandulosa var. glandulosa. Associated
species can include Ziziphus obtusifolia, Quercus
fusiformis , Sideroxylon lanuginosum, Aloysia
gratissima, Mahonia trifoliolata, Yucca glauca,
Opuntia spp.. Acacia greggii. Mimosa spp., Rhus
lanceolata, Nassella leucotricha, Bouteloua
curtipendula , Bouteloua gracilis , Bouteloua hirsuta,
Buchloe dactyloides, Schizachyrium scoparium,
Ruellia nudiflora , Croton monanthogynus, Rhynchosia
senna , and Indigofera miniata.
Temperate Desert Ecoregion
Northern Rocky Mountain Lower
Montane and Foothill Forest
This macrogroup consists of Pinus ponderosa
woodlands and “wooded steppes,” located in the
foothills of the northern Rocky Mountains in the
Columbia Plateau region and west along the foothills
of the Modoc Plateau and Eastern Cascades into
southern interior British Columbia. It also occurs east
across Idaho into the eastern foothills of the Montana
Rockies. These woodlands and wooded steppes occur
at the lower treeline/ecotone between grasslands or
shrublands and more mesic coniferous forests,
typically on warm, dry, exposed sites. These
woodlands and wooded steppes receive winter and
spring rains, and thus have a greater spring “green-up”
compared with the drier woodlands in the central
Rockies. However, sites are often too droughty to
support a closed tree canopy. Elevations range from
less than 1 ,640 feet (500 meters) in British Columbia to
5,249 feet (1,600 meters) in the central Idaho
mountains. Occurrences are found on all slopes and
aspects; however, moderately steep to very steep slopes
or ridgetops and plateaus are most common. These
woodlands and wooded steppes generally occur on
most geological substrates, from weathered rock to
glacial deposits to eolian deposits. Characteristic soil
features include good aeration and drainage, coarse
textures, circumneutral to slightly acidic pH, an
abundance of mineral material, and periods of drought
during the growing season.
The Pinus ponderosa woodlands have a shrubby or
grassy understory, whereas the Pinus ponderosa
wooded steppes have widely spaced, scattered Pinus
ponderosa trees over generally shrubby but sparse
understories. The woodlands are generally fire-
maintained, whereas the wooded steppes are often too
dry and with vegetation too widely spaced to be able to
carry fire. Pinus ponderosa var. ponderosa is the
predominant conifer; Pseudotsuga menziesii or Pinus
flexilis (limber pine) can be present in the tree canopy
but are usually absent. The understory can be shrubby,
with Artemisia tridentata (big sagebrush),
Arctostaphylos patula, Arctostaphylos uva-ursi,
Cercocarpus ledifolius (curl-leaf mountain mahogany),
Physocarpus malvaceus (mallow ninebark), Purshia
tridentata (antelope bitterbrush), Symphoricarpos
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MACROGROUP DESCRIPTIONS
oreophilus (mountain snowberry) or Symphoricarpos
albus (common snowberry), Amelanchier alnifolia
(Saskatoon serviceberry), and Rosa spp. (rose) being
common species. In transition areas with sagebrush
steppe, Purshia tridentata , Artemisia tridentata ssp.
wyomingensis (Wyoming big sagebrush), Artemisia
tridentata ssp. tridentata (basin big sagebrush), and
Artemisia tripartita (threetip sagebrush) can be
common in fire-protected sites such as rocky areas.
Deciduous shrubs, such as Physocarpus malvaceus,
Symphoricarpos albus , or Spiraea betulifolia (white
spirea), can be abundant in more northerly sites or
more moist climates. Herbaceous vegetation in the
wooded steppes is predominantly fire-resistant grasses
and forbs that resprout after surface fires; shrubs,
understory trees and downed logs are uncommon. The
wooded steppes support grasses such as
Pseudoroegneria spicata (bluebunch wheatgrass),
Hesperostipa spp. (needle and thread), Achnatherum
spp. (needlegrass), dry Care x (sedge) species ( Carex
inops [long-stolon sedge]), Elymus elymoides, Festuca
idahoensis (Idaho fescue), or Festuca campestris
(rough fescue).
Southern Rocky Mountain Lower
Montane Forest
These forests are dominated by Pinus ponderosa, either
solely or mixed with Pseudotsuga menziesii, Pinus
edulis , Pinus contorta, Populus tremuloides (quaking
aspen), and Juniperus spp. (juniper). Ponderosa pine
forests with a mixture of other tree species have a
typically shrubby understory composed of Artemisia
nova (black sagebrush), Artemisia tridentata ,
Arctostaphylos patula, Arctostaphylos uva-ursi,
Cercocarpus montanus, Purshia stansburiana, Purshia
tridentata , Quercus gambelii (Gambel oak),
Symphoricarpos spp., Prunus virginiana , Amelanchier
alnifolia , and Rosa spp. Common grasses in the
understory include Pseudoroegneria spicata ,
Pascopyrum smithii, and species of Hesperostipa,
Achnatherum , Festuca, Muhlenbergia, and Bouteloua.
Ponderosa pine forests dominated solely by ponderosa
pine have a grass-dominated understory composed of
Festuca arizonica (Arizona fescue), Muhlenbergia
virescens, Pseudoroegneria spicata, Andropogon
gerardii (big bluestem), Schizachyrium scoparium,
Festuca idahoensis, Piptatherum micranthum
(littleseed ricegrass), and Bouteloua gracilis.
Intermountain Singleleaf Pinyon-
Western Juniper Woodland
These woodlands are composed of Pinus monophylla
(singleleaf pinyon), Juniperus osteosperma, or
Juniperus occidentals (western juniper). Woodlands
composed of scattered Juniperus osteosperma trees
exist on dry foothills and sandsheets of the Colorado
Plateau and eastern Great Basin. Juniperus
osteosperma woodlands have an understory dominated
by grasses such as Bouteloua gracilis, Hesperostipa
comata, and Pleuraphis jamesii. Woodlands dominated
by Pinus monophylla form an open to dense tree layer,
often with the wider ranging Juniperus osteosperma.
These woodlands exist on dry mountain ranges of the
Great Basin region and eastern foothills of the Sierra
Nevada. Woodlands dominated by Juniperus
occidentals are largely restricted to the Columbia
Plateau region and Pinus monophylla is not present.
Rocky Mountain Two-Needle Pinyon-
Juniper Woodland
These woodlands are composed of Pinus edulis,
Juniperus osteosperma, or Juniperus monosperma.
Pinus edulis and/or Juniperus osteosperma- dominated
woodlands occur on dry mountains and foothills of the
Colorado Plateau region. Juniperus monosperma-
dominated woodlands have an understory of perennial
grasses such as Bouteloua gracilis and Pleuraphis
jamesii and other herbaceous species typical of the
shortgrass prairie. These woodlands occur along the
east and south foothill slopes of the southern Rocky
Mountains and into the plains of southeastern Colorado
and northern and central New Mexico. Pinus edulis
and/or Juniperus monosperma-dominated woodlands
exist on dry mountains and foothills in southern
Colorado east of the Continental Divide, and in
mountains and plateaus of northern and central New
Mexico.
Northern Rocky Mountain-
Vancouverian Montane and Foothill
Grassland and Shrubland
This macrogroup is composed of shrublands in the
lower montane and foothill regions around the
Columbia Basin and north and east into the Northern
Rockies, and dry grasslands occurring in the canyons
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MACROGROUP DESCRIPTIONS
and valleys of the northern Great Basin and Columbia
Basin, particularly along the Snake River canyon, the
lower foothill slopes of the Blue Mountains, and along
the main stem of the Columbia River in eastern
Washington.
The shrublands typically occur below treeline, within
the matrix of surrounding low-elevation grasslands and
sagebrush shrublands, usually on steep slopes of
canyons on all aspects. Rhus glabra (smooth sumac),
Amelanchier alnifolia, Prunus emarginata, Prunus
virginiana , Rosa spp., Symphoricarpos oreophilus, and
Holodiscus discolor are the most common dominant
shrubs, occurring alone or in any combination.
Occurrences in central and eastern Wyoming can
include Artemisia tridentata ssp. vaseyana (mountain
big sagebrush) and Cercocarpus montanus, but neither
of these are dominant, and where they occur the stands
are truly mixes of shrubs, often with Amelanchier
alnifolia, Prunus virginiana, and others being the
predominant taxa. Festuca idahoensis, Festuca
campestris , Calamagrostis rubescens (pinegrass),
Car ex geyeri (Geyer’s sedge), Aristida purpurea,
Koeleria macrantha (prairie junegrass),
Pseudoroegneria spicata, and Poa secunda are the
most important grasses. Geum triflorum (old man’s
whiskers), Potentilla gracilis (slender cinquefoil),
Lomatium triternatum (nineleaf biscuitroot),
Balsamorhiza sagittata (arrowleaf balsamroot), and
species of Eriogonum (buckwheat), Phlox (phlox), and
Erigeron (fleabane) are important forbs.
The grasslands are found on steep open slopes, from
300 to 5,000 feet (90 to 1,525 meters). Soils are
derived from residuum and have patchy, thin, wind¬
blown surface deposits. Slope failures are common
occurrences. The grasslands are dominated by patchy
graminoid cover, cacti, and some forbs. Aristida
purpurea var. longiseta (Fendler threeawn),
Sporobolus cryptandrus, Poa secunda,
Pseudoroegneria spicata, Festuca idahoensis, and
Opuntia polyacantha are common species. Deciduous
shrubs Rhus glabra, Symphoricarpos spp.,
Physocarpus malvaceus, Holodiscus discolor, and
Ribes spp. (gooseberry) are infrequent native species
that can increase with fire exclusion.
Southern Rocky Mountain Montane
Grassland and Shrubland
This macrogroup is composed of shrublands dominated
by Amelanchier utahensis (Utah serviceberry),
Cercocarpus montanus, or Quercus gambelii. Stands
dominated by one or another of these shrubs often
intergrade with each other. This macrogroup is found
in the mountains, plateaus, foothills, and canyon slopes
of the southern Rocky Mountains and Colorado
Plateau, and on outcrops and canyon slopes in the
western Great Plains. It ranges from the southern and
central Great Plains, southwest to southern New
Mexico, extending north into Wyoming, and west into
the Intermountain West region. These shrublands occur
between 4,921 and 9,514 feet (1,500 and 2,900 meters)
and are usually associated with exposed sites, rocky
substrates, and dry conditions, which limit tree growth.
Where Cercocarcus montanus dominates pure stands
in parts of Wyoming and Colorado, Quercus gambelii
is absent. Quercus gambelii is typically dominant on
the more mesic and higher elevation sites from 6,562 to
9,514 feet (2,000 to 2,900 meters). On stands where
Quercus gambelii is dominant, other vegetation
typically includes Amelanchier alnifolia, Amelanchier
utahensis, Artemisia tridentata, Cercocarpus
montanus, Prunus virginiana, Purshia stansburiana,
Purshia tridentata, Robinia neomexicana (New
Mexico locust), Symphoricarpos oreophilus, or
Symphoricarpos rotundifolius (mountain snowberry).
On stands where Cercocarpus montanus is dominant,
other vegetation typically includes Amelanchier
utahensis, Purshia tridentata, Rhus trilobata, Ribes
cereum (wax currant), Symphoricarpos oreophilus, or
Yucca glauca. Grasses are represented by species of
Muhlenbergia (muhly), Bouteloua, Hesperostipa, and
Pseudoroegneria spicata.
Great Basin and Intermountain Dry
Shrubland and Grassland
This macrogroup consists of shrubland-steppe and
grasslands. The shrubland-steppe occurs throughout the
Colorado Plateau, Arizona-New Mexico Mountains,
west to the Mojave Desert, and north to the Wyoming
Basin, on alluvial flats and fans, talus slopes, plateaus,
and bluffs. Slopes range from gentle to steep, and
substrates are variable and include sandstone talus,
fine-textured alluvium, sand, clay, loams, cinder,
cobbles, and coarse gravels. These shrubland-steppes
can either be shrub-dominated, dwarf shrub-dominated,
or grass dominated with a sparse shrub layer. Common
shrubs include Atriplex canescens (fourwing saltbush),
Eriogonum corymbosum (crispleaf buckwheat),
Ericameria nauseosa (rubber rabbitbrush), Ephedra
viridis (Mormon tea), Ephedra torreyana (Torrey’s
jointfir), Krascheninnikovia lanata (winterfat),
Chrysothamnus viscidijlorus (yellow rabbitbrush),
Tetradymia canescens (spineless horsebrush), and
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MACROGROUP DESCRIPTIONS
Gutierrezia sarothrae (broom snakeweed). Herbaceous
species include Pleuraphis jamesii , Bromus tectorum
(cheatgrass), Achnatherum hymenoides (Indian
ricegrass), Aristida purpurea, and Hesperostipa
comata.
The grasslands are semi-arid to arid and are located
throughout the intermountain western U.S. They occur
on sites over an elevational range of about 3,609 to
10,794 feet (1,100 to 3,290 meters) in most of the
range, and 1,148 to 1,394 feet (350 to 425 meters) in
the Columbia Basin on a variety of landforms,
including swales, playas, mesas, alluvial flats, and
plains. These grasslands constitute a matrix over large
areas of intermountain basins, and also can occur as
large patches in mosaics with semi-desert shrublands.
Substrates are often well-drained sandy or loam soils
derived from sedimentary parent materials, but are
quite variable and can include fine-textured soils
derived from igneous and metamorphic rocks. The
dominant perennial bunchgrasses and shrubs of these
grasslands are all drought-resistant plants. Dominant or
codominant species are Achnatherum hymenoides,
Achnatherum lettermanii (Letterman’s needlegrass),
Achnatherum nelsonii (Columbia needlegrass),
Achnatherum speciosum (desert needlegrass),
Bouteloua eriopoda, Bouteloua gracilis, Hesperostipa
comata, Pleuraphis jamesii, Poa cusickii (Cusick’s
bluegrass), Poa secunda, and Pseudoroegneria spicata.
Scattered shrubs and dwarf-shrubs often are present,
especially Artemisia tridentata ssp. tridentata,
Artemisia tridentata ssp. wyomingensis, Atriplex spp.
(saltbush), Coleogyne spp. (coleogyne), Ephedra spp.
(jointfir), Gutierrezia sarothrae, and
Krascheninnikovia lanata, which are the typical
dominant species of adjacent shrublands.
Great Basin and Intermountain Tall
Sagebrush Shrubland and Steppe
This macrogroup consists of shrublands and shrub-
steppe that is widely distributed from the Great Basin,
Columbia River Basin, Colorado Plateau, northern
Rocky Mountains, and northwestern Great Plains, as
far east as the Dakotas, at elevations as low as 1,640
feet (500 meters) in the northwestern Great Plains to
8,202 feet (2,500 meters) in the Rocky Mountains and
Colorado Plateau. This macrogroup occurs on flat to
steeply sloping upland slopes on alluvial fans and
terraces, toe slopes, lower and middle slopes, draws,
badlands, and foothills. Sites with little slope tend to
have deep soils, whereas those with steeper slopes have
shallow to moderately deep soils. Climate ranges from
arid in the western Great Basin to subhumid in the
northern Great Plains and Rocky Mountains, with
much of the precipitation falling primarily as snow.
The amount and reliability of growing-season moisture
increase eastward and with increasing elevation. Stands
are dominated by Artemisia tridentata ssp.
wyomingensis and Artemisia tridentata ssp. tridentata
and, in some cases, codominated by Amelanchier
utahensis, Atriplex canescens, Ephedra nevadensis
(Nevada jointfir), Ephedra viridis, Ericameria
nauseosa, or Sarcohatus vermiculatus (greasewood).
Other common shrubs include Artemisia frigida
(prairie sagewort), Atriplex confertifolia (shadscale
saltbush), Atriplex gardneri (Gardner’s saltbush),
Chrysothamnus spp. (rabbitbrush), Ericameria spp.
(rabbitbrush), Grayia spinosa (spiny hopsage),
Krascheninnikovia lanata, Peraphyllum ramosissimum
(wild crab apple), Prunus virginiana, Purshia
tridentata, Symphoricarpos longijlorus (desert
snowberry), and Tetradymia spp. (horsebrush). The
herbaceous layer can be sparse to strongly dominated
by graminoids including Achnatherum hymenoides,
Achnatherum lettermanii, Achnatherum pinetorum
(pine needlegrass), Achnatherum thurherianum
(Thurber’s needlegrass), Bouteloua gracilis, Bromus
tectorum, Carex Jilifolia, Elymus albicans (Montana
wheatgrass), Elymus elymoides, Elymus lanceolatus
(thickspike wheatgrass), Festuca idahoensis,
Hesperostipa comata, Leymus ambiguous (Colorado
wildrye), Pleuraphis jamesii, Poa J'endleriana
(muttongrass), Poa secunda, Pseudoroegneria spicata,
Sporobolus airoides, and Sporobolus cryptandrus.
Temperate Steppe Ecoregion
Northern Rocky Mountain Lower
Montane and Foothill Forest
This macrogroup consists of Pinus ponderosa
woodlands and “wooded steppes,” located in the
foothills of the northern Rocky Mountains in the
Columbia Plateau region and west along the foothills
of the Modoc Plateau and Eastern Cascades into
southern interior British Columbia, and east across
Idaho into the eastern foothills of the Montana
Rockies. These woodlands and wooded steppes occur
at the lower treeline/ecotone between grasslands or
shrublands and more mesic coniferous forests,
typically on warm, dry, exposed sites. These
woodlands and wooded steppes receive winter and
spring rains, and thus have a greater spring “green-up”
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MACROGROUP DESCRIPTIONS
compared with the drier woodlands in the central
Rockies. However, sites are often too droughty to
support a closed tree canopy. Elevations range from
less than 1,640 feet (500 meters) in British Columbia to
5,249 feet (1,600 meters) in the central Idaho
mountains. Occurrences are found on all slopes and
aspects; however, moderately steep to very steep slopes
or ridgetops and plateaus are most common. These
woodlands and wooded steppes generally occur on
most geological substrates, from weathered rock to
glacial deposits to eolian deposits. Characteristic soil
features include good aeration and drainage, coarse
textures, circumneutral to slightly acidic pH, an
abundance of mineral material, and periods of drought
during the growing season.
The Pinus ponderosa woodlands have a shrubby or
grassy understory, whereas the Pinus ponderosa
wooded steppes have widely spaced, scattered Pinus
ponderosa trees over generally shrubby but sparse
understories. The woodlands are generally fire-
maintained, whereas the wooded steppes are often too
dry and with vegetation too widely spaced to be able to
carry fire. Pinus ponderosa var. ponderosa is the
predominant conifer; Pseudotsuga menziesii or Pinus
flexilis can be present in the tree canopy but are usually
absent. The understory can be shrubby, with Artemisia
tridentata, Arctostaphylos patula, Arctostaphylos uva-
ursi, Cercocarpus ledifolius, Physocarpus malvaceus,
Purshia tridentata , Symphoricarpos oreophilus or
Symphoricarpos albus, Amelanchier alnifolia, and
Rosa spp. being common species. In transition areas
with sagebrush steppe, Purshia tridentata , Artemisia
tridentata ssp. wyomingensis, Artemisia tridentata ssp.
tridentata , and Artemisia tripartita can be common in
fire -protected sites such as rocky areas. Deciduous
shrubs, such as Physocarpus malvaceus ,
Symphoricarpos albus , or Spiraea betulifolia , can be
abundant in more northerly sites or more moist
climates. Herbaceous vegetation in the wooded steppes
is predominantly fire-resistant grasses and forbs that
resprout after surface fires; shrubs, understory trees and
downed logs are uncommon. The wooded steppes
support grasses such as Pseudoroegneria spicata,
Hesperostipa spp., Achnatherum spp., dry Carex
species ( Carex inops), Elymus elymoides, Festuca
idahoensis, or Festuca campestris.
Also included are Pinus ponderosa woodlands that
occur along the eastern face of the Rocky Mountains
and into the Great Plains. These woodlands are
variable, ranging from very sparse patches of trees on
drier sites, to nearly closed-canopy forest stands on
north slopes or in draws where available soil moisture
is greater. They occur primarily on gentle to steep
slopes along escarpments, buttes, canyons, rock
outcrops or ravines and can grade into surrounding
mixed grass prairie. Soils typically range from well-
drained loamy sands to sandy loams formed in
colluvium, weathered sandstone, limestone, scoria, or
eolian sand. These woodlands are primarily dominated
by Pinus ponderosa, but can include a sparse to
relatively dense understory of Juniperus scopulorum
(Rocky Mountain juniper), Thuja occidentalis
(arborvitae), or Cercocarpus species (mountain
mahogany) with just a few scattered trees. Deciduous
trees are an important component in some areas
(western Dakotas, Black Hills) and are sometimes
codominant with Pinus ponderosa, including Fraxinus
pennsylvanica (green ash), Betula papyrifera (paper
birch), Quercus macrocarpa (bur oak), Ulmus
Americana (American elm), Acer negundo (boxelder),
and Populus tremuloides. Important or common shrub
species with Pinus ponderosa can include
Arctostaphylos uva-ursi, Mahonia repens (creeping
barberry), Yucca glauca, Symphoricarpos spp., Prunus
virginiana, Juniperus communis, Juniperus
horizontalis (creeping juniper), Amelanchier alnifolia,
Rhus trilobata, and Physocarpus monogynus (mountain
ninebark). The herbaceous understory can range from
sparse to a dense layer with species typifying the
surrounding mixed grass prairie, with mixed grass
species common such as Andropogon gerardii,
Bouteloua curtipendula, Carex inops ssp. heliophila,
Carex fdifolia, Danthonia intermedia (timber
oatgrass), Koeleria macrantha, Nassella viridula
(green needlegrass), Oryzopsis asperifolia (roughleaf
ricegrass), Pascopyrum smith'd, Piptatherum
micranthum, and Schizachyrium scoparium.
Southern Rocky Mountain Lower
Montane Forest
These forests are dominated by Pinus ponderosa, either
solely or mixed with Pseudotsuga menziesii, Pinus
edulis, Pinus contorta, Populus tremuloides, and
Juniperus spp. Ponderosa pine forests with a mixture
of other tree species have a typically shrubby
understory composed of Artemisia nova, Artemisia
tridentata, Arctostaphylos patula, Arctostaphylos uva-
ursi, Cercocarpus montanus, Purshia stansburiana,
Purshia tridentata, Quercus gambelii, Symphoricarpos
spp., Prunus virginiana, Amelanchier alnifolia, and
Rosa spp. Common grasses in the understory include
Pseudoroegneria spicata, Pascopyrum smith'd, and
species of Hesperostipa, Achnatherum, Festuca,
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
D-16
January 2016
MACROGROUP DESCRIPTIONS
Muhlenbergia , and Bouteloua. Ponderosa pine forests
dominated solely by ponderosa pine have a grass-
dominated understory composed of Festuca arizonica ,
Muhlenbergia virescens, Pseudoroegneria spicata,
Andropogon gerardii, Schizachyrium scoparium,
Festuca idahoensis , Piptatherum micranthum, and
Bouteloua gracilis.
Intermountain Singleleaf Pinyon-
Western Juniper Woodland
These woodlands are composed of Pinus monophylla ,
Juniperus osteosperma, or Juniperus occidentals.
Woodlands composed of scattered Juniperus
osteosperma trees exist on dry foothills and sandsheets
of the Colorado Plateau and eastern Great Basin.
Juniperus osteosperma woodlands have an understory
dominated by grasses such as Bouteloua gracilis ,
Hesperostipa comata, and Pleuraphis jamesii.
Woodlands dominated by Pinus monophylla form an
open to dense tree layer, often with the wider ranging
Juniperus osteosperma. These woodlands exist on dry
mountain ranges of the Great Basin region and eastern
foothills of the Sierra Nevada. Woodlands dominated
by Juniperus occidentals are largely restricted to the
Columbia Plateau region and Pinus monophylla is not
present.
Rocky Mountain Two-Needle Pinyon-
Juniper Woodland
These woodlands are composed of Pinus edulis,
Juniperus osteosperma , or Juniperus monosperma.
Pinus edulis and/or Juniperus osteosperma- dominated
woodlands occur on dry mountains and foothills of the
Colorado Plateau region. Juniperus monosperma-
dominated woodlands have an understory of perennial
grasses such as Bouteloua gracilis and Pleuraphis
jamesii and other herbaceous species typical of the
shortgrass prairie. These woodlands occur along the
east and south foothill slopes of the southern Rocky
Mountains and into the plains of southeastern Colorado
and northern and central New Mexico. Pinus edulis
and/or Juniperus monosperma- dominated woodlands
exist on dry mountains and foothills in southern
Colorado east of the Continental Divide, and in
mountains and plateaus of northern and central New
Mexico.
Northern Rocky Mountain-
Vancouverian Montane and Foothill
Grassland and Shrubland
This macrogroup is composed of shrublands in the
lower montane and foothill regions around the
Columbia Basin and north and east into the Northern
Rockies, and various types of grasslands. The
grasslands are geographically extensive in this
ecoregion, with one type of grassland being a dry
grassland occurring in the canyons and valleys of the
northern Great Basin and Columbia Basin particularly
along the Snake River canyon, the lower foothill slopes
of the Blue Mountains, and along the main stem of the
Columbia River in eastern Washington, another
grassland type commonly referred to as the Palouse
Prairie in the Blue Mountains of Oregon and north into
the Okanagan and Fraser Plateaus of British Columbia
and the Canadian Rockies, and another grassland type
located in the mountains and large valleys of
northwestern Wyoming and western Montana, and east
into the central Montana mountain “islands” foothills
and the Rocky Mountain Front and Big and Little Belt
Ranges.
The shrublands typically occur below treeline, within
the matrix of surrounding low-elevation grasslands and
sagebrush shrublands, usually on steep slopes of
canyons on all aspects. Rhus glabra , Amelanchier
alnifolia , Prunus emarginata, Prunus virginiana, Rosa
spp., Symphoricarpos oreophilus , and Holodiscus
discolor are the most common dominant shrubs,
occurring alone or in any combination. Occurrences in
central and eastern Wyoming can include Artemisia
tridentata ssp. vaseyana and Cercocarpus montanus,
but neither of these are dominant, and where they occur
the stands are truly mixes of shrubs, often with
Amelanchier alnifolia , Prunus virginiana, and others
being the predominant taxa. Festuca idahoensis,
Festuca campestris, Calamagrostis rubescens, Carex
geyeri, Aristida purpurea, Koeleria macrantha,
Pseudoroegneria spicata, and Poa secunda are the
most important grasses. Geum trijlorum, Potentilla
gracilis, Lomatium triternatum , Balsamorhiza
sagittata, and species of Eriogonum, Phlox, and
Erigeron are important forbs.
The dry grasslands are found on steep open slopes,
from 300 to 5,000 feet (90 to 1,525 meters). Soils are
derived from residuum and have patchy, thin, wind-
BLM Vegetation Treatments Three New Herbicides
Pinal Programmatic EIS
D-17
January 2016
MACROGROUP DESCRIPTIONS
blown surface deposits. Slope failures are common
occurrences. The grasslands are dominated by patchy
graminoid cover, cacti, and some forbs. Aristida
purpurea var. longiseta, Sporobolus cryptandrus, Poa
secunda, Pseudoroegneria spicata, Festuca idahoensis,
and Opuntia polyacantha are common species.
Deciduous shrubs Rhus glabra , Symphoricarpos spp.,
Physocarpus malvaceus, Holodiscus discolor, and
Ribes spp. are infrequent native species that can
increase with fire exclusion. The Palouse Prairie
grasslands are found on rolling topography composed
of loess hills and plains lying over basalt plains. The
climate of these grasslands has warm to hot, dry
summers and cool, wet winters. Annual precipitation is
high, ranging between 15 and 30 inches (38 and 76
centimeters). Soils are typically deep, well-developed,
and old. The remaining grasslands outside of the
Palouse Prairie area are influenced by shorter summers,
colder winters, and young soils derived from recent
glacial and alluvial material. In the eastern portion of
the range in Montana, winter precipitation is replaced
by a large spring peak in precipitation. Elevations
range from 984 to 5,413 feet (300 to 1,650 meters),
ranging from small meadows to large open parks
surrounded by conifers in the lower montane, to
extensive foothill and valley grasslands below the
lower treeline. Many of these valleys may have been
primarily sage-steppe with patches of grassland in the
past, but because of land-use history post-settlement
(herbicide, grazing, fire suppression, pasturing) they
have been converted to grassland-dominated areas.
Soils are relatively deep, fine-textured, often with
coarse fragments, and non-saline, often with a
biological soil crust. The most important species are
cool-season perennial bunchgrasses and forbs (greater
than 25 percent cover), sometimes with a sparse (less
than 10 percent cover) shrub layer. Festuca campestris
and Festuca idahoensis are dominants, and
Pseudoroegneria spicata occurs as a codominant, as
well as a diversity of other native grasses. Forb
diversity is typically high in both mesic and dry aspects
of these grasslands.
Southern Rocky Mountain Montane
Grassland and Shrubland
This macrogroup is composed of shrublands dominated
by Amelanchier utahensis, Cercocarpus montanus, or
Quercus gambelii. Stands dominated by one or another
of these shrubs often intergrade with each other. This
macrogroup is found in the mountains, plateaus,
foothills, and canyon slopes of the southern Rocky
Mountains and Colorado Plateau, and on outcrops and
canyon slopes in the western Great Plains. It ranges
from the southern and central Great Plains, southwest
to southern New Mexico, extending north into
Wyoming, and west into the Intermountain West
region. These shrublands occur between 4,921 and
9,514 feet (1,500 and 2,900 meters) and are usually
associated with exposed sites, rocky substrates, and dry
conditions, which limit tree growth. Where
Cercocarcus montanus dominates pure stands in parts
of Wyoming and Colorado, Quercus gambelii is
absent. Quercus gambelii is typically dominant on the
more mesic and higher elevation sites from 6,562 to
9,514 feet (2,000 to 2,900 meters). On stands where
Quercus gambelii is dominant, other vegetation
typically includes Amelanchier alnifolia, Amelanchier
utahensis, Artemisia tridentata, Cercocarpus
montanus, Prunus virginiana, Purshia stansburiana,
Purshia tridentata, Robinia neomexicana,
Symphoricarpos oreophilus, or Symphoricarpos
rotundifolius. On stands where Cercocarpus montanus
is dominant, other vegetation typically includes
Amelanchier utahensis, Purshia tridentata, Rhus
trilobata, Ribes cereum, Symphoricarpos oreophilus,
or Yucca glauca. Grasses are represented by species of
Muhlenbergia, Bouteloua, Hesperostipa, and
Pseudoroegneria spicata.
Great Plains Shortgrass Prairie and
Shrubland
The shortgrass prairie in this macrogroup is dominated
by the shortgrasses Bouteloua gracilis and Buchloe
dactyloides. Shrublands in this macrogroup are
dominated by Prosopis glandulosa. The shortgrass
prairies occur on flat to rolling uplands. The surface
soil may be sandy loam, loam, silt loam, or loamy clay.
The subsoil is often finer than the surface soil. The
shortgrass prairies are characterized by a moderate to
dense sod of short grasses with scattered mid grasses
and forbs. The foliage of these species is 3 to 7 inches
(7 to 19 centimeters) tall, while the flowering stalks of
Bouteloua gracilis may reach 1 8 inches (45
centimeters). The mid grasses are usually stunted by
the arid conditions and often do not exceed 2.3 feet
(0.7 meters). Other short graminoids found in this
community are Bouteloua hirsuta, Carex duriuscula,
Carex inops ssp. heliophila, and Carex fdifolia (in
Nebraska). Several mid grasses occur regularly, such
as Aristida purpurea, Bouteloua curtipendula,
Pascopyrum smithii, Schizachyrium scoparium, Elymus
elymoides, Sporobolus cryptandrus, Hesperostipa
comata, and Vulpia octoflora. Forbs such as Astragalus
spp., Gaura cocci nea, Machaeranthera pinnatifida var.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
D-18
January 2016
MACROGROUP DESCRIPTIONS
pinnatifida, Opuntia polyacantha, Plantago
patagonica, Psoralidium tenuiflorum, Ratibida
columnifera, and Sphaeralcea coccinea are common
throughout the shortgrass prairies.
Great Plains Mixedgrass Prairie and
Shrubland
This macrogroup consists of mesic and dry mixed grass
prairies, which extend from Kansas and New Mexico
north through western Nebraska and eastern Colorado,
northward through Wyoming and the western Dakotas
into eastern and central Montana, west to the Rocky
Mountain Front Range in Montana and Wyoming. The
mesic mixed grass prairies are a mixture of mostly
mixed grass prairie with some tallgrass prairie, on
mostly moderate to gentle slopes, usually at the base of
foothill slopes (for example the hogbacks of the Rocky
Mountain Front Range, where it typically occurs as a
relatively narrow elevational band between montane
woodlands and shrublands and the shortgrass steppe).
It also occurs east on the Front Range piedmont
alongside the Chalk Bluffs near the Colorado-
Wyoming border, out into the Great Plains on the
Palmer Divide in Colorado, and on piedmont slopes
below mesas and foothills in northeastern New
Mexico. Soil texture is the defining environmental
descriptor; soils are primarily mesic, fine and medium
textured, and do not include sands, sandy soils, or
sandy loams. Graminoids typically comprise the
greatest amount of canopy cover and include
Pascopynim smithii, Nassella viridula, Andropogon
gerardii, and Festuca idahoensis (in Montana). Other
species include Schizachyrium scoparium,
Muhlenbergia montana (mountain muhly), Sporobolus
cryptandrus, Sorghastrum nutans (Indiangrass),
Pseudoroegneria spicata , Bouteloua gracilis, and
Bouteloua curtipendula. Shrub species such as
Symphoricarpos spp., Artemisia frigida , and Artemisia
cana (silver sagebrush) also can occur. With intensive
grazing, cool-season exotic species such as Poa
pratensis (Kentucky bluegrass), Bromus inermis
(smooth brome), and Bromus japonicus (Japanese
brome) can increase in dominance. Shrub species such
as Juniperus virginiana (eastern redcedar) can also
increase in dominance with fire suppression.
The dry mixed grass prairies occur on flat to rolling
topography with deep, sandy loam to loam, coarse-
textured soils. The vegetation is dominated by
moderate to moderately dense medium-tall grasses and
scattered shrubs. Dominant species include
Hesperostipa comata, Carex inops ssp. heliophila , and
Carex fdifolia. Calamovilfa longifolia (prairie
sandreed) is often found with high cover values on
sandier soils, and Koeleria macrantha cover increases
on degraded sites. Other common species include
Hesperostipa neomexicana (New Mexico
feathergrass), Hesperostipa curtiseta (shortbristle
needle and thread), and Schizachyrium scoparium.
Common woody species include Dasiphora fruticosa
spp. Jloribunda (shrubby cinquefoil), Rhus trilobata,
and Juniperus horizontalis.
Bl.M Vegetation Treatments Three New Herbicides
Final Programmatic HIS
D-19
January 2016
APPENDIX E
SPECIAL STATUS SPECIES LIST
>
SPECIAL STATUS SPECIES LIST
APPENDIX E
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Abalone, white
Haliotis sorenseni
CA
Invertebrate
FE
Abronia, transmontane
Abronia turbinata
OR
Plant
BS
Adders-tongue
Ophioglossum pusillum
MT, OR
Plant
BS
Adobe-lily, striped
Fritillaria striata
CA
Plant
BS
Agave, Arizona
Agave arizonica
AZ
Plant
FE
Agave, Murphey’s
Agave murpheyi
AZ
Plant
BS
Agave, Santa Cruz striped
Agave parviflora
AZ
Plant
BS
Agoseris, pink
Agoseris lackschewitzii
ID
Plant
BS
Agoseris, tall
Agoseris el at a
OR
Plant
BS
Albatross, short-tailed
Phoebastris albatrus
AK, CA, OR
Bird
FE
Alkaligrass, Howell’s
Puccinellia howellii
CA
Plant
BS
Alkaligrass, Lemmon’s
Puccinellia lemmonii
MT
Plant
BS
Alkaligrass, Parish’s
Puccinellia parishii
CA
Plant
BS
Alkaligrass, Wright’s
Puccinellia wrightii
AK
Plant
BS
Allocarya, Calistoga
Plagiobothrys strictus
CA
Plant
FE
Allocarya, coral-seeded
Plagiobothrys figuratus
OR
Plant
BS
Allocarya, desert
Plagiobothrys salsus
OR
Plant
BS
Alopecurus, Sonoma
Alopecurus aequalis
CA
Plant
FE
Alumroot, Duran’s
Heuchera duranii
CA
Plant
BS
Alumroot, gooseberry-leaved
Heuchera grossulariifolia
OR
Plant
BS
Ambersnail, Kanab
Oxyloma haydeni kanabensis
AZ
Invertebrate
FE
Ambrosia, San Diego
Ambrosia pumila
CA
Plant
FE
Ammannia
Ammannia robusta
OR
Plant
BS
Amole, narrow-leaved
Chlorogalum angustifolium
OR
Plant
BS
Amole, purple
Chlorogalum purpureum
CA
Plant
FT
Amphipod, Arizona cave
Stygobromus arizonensis
AZ
Invertebrate
BS
Amphipod, Malheur cave
Stygobromus hubbsi
OR
Invertebrate
BS
Amphipod, Noel’s
Gammarus desperatus
NM
Invertebrate
FE
Anemone, bog
Anemone oregana
OR
Plant
BS
Angelica, King’s
Angelica kingii
ID
Plant
BS
Angelica, rough
Angelica scabrida
NV
Plant
BS
Apple, Squaw
Peraphyllum ramosissimum
OR
Plant
BS
Arnica, northern
Arnica lonchophylla
AK
Plant
BS
Arnica, Shasta
Arnica viscosa
OR
Plant
BS
Arrowhead, Sanford’s
Sagittaria sanfordii
CA
Plant
BS
BI.M Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-l
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Artemisia, Estes
Artemisia ludoviciana ssp.
estesii
OR
Plant
BS
Aster, Gorman’s
Eucephalus gormanii
OR
Plant
BS
Aster, Huachuca golden
Heterotheca rutteri
AZ
Plant
BS
Aster, Jessica’s
Aster jessicae
ID
Plant
BS
Aster, Laguna Mountains
Dieteria asteroides
CA
Plant
BS
Aster, Orcutt’s woody
Xylorhiza orcuttii
CA
Plant
BS
Aster, pygmy
Aster pygmaeus
AK
Plant
BS
Aster, Red Rock Canyon
Lonactis caelestis
NV
Plant
BS
Aster, rush
Aster borealis
OR
Plant
BS
Aster, San Bernardino
Symphyotrichum defoliatum
CA
Plant
BS
Aster, tall alpine
Oreostemma elatum
CA
Plant
BS
Aster, wayside
Eucephalus vialis
OR
Plant
BS
Aster, white-topped
Sericocarpus rigidus
OR
Plant
BS
Avens, slender-stemmed
Geum rossii
OR
Plant
BS
Avens, water
Geum rivale
OR
Plant
BS
Azalea, alpine
Loiseleuria procumbens
OR
Plant
BS
Baccharis, Encinitas
Baccharis vanessae
CA
Plant
FT
Balloonvine
Cardiospermum corindum
AZ, ID
Plant
BS
Balsamroot, big-scale
Balsamorhiza macrolepis
CA
Plant
BS
Balsamroot, lanate
Balsamorhiza lanata ssp.
CA
Plant
BS
Balsamroot, large-leafed
Balsamorhiza macrophylla
MT
Plant
BS
Balsamroot, silky
Balsamorhiza sericea
CA
Plant
BS
Balsamroot, woolly (=Hooker’s)
Balsamorhiza hookeri ssp.
CA, OR
Plant
BS
Barberry, island
Berberis pinnata
CA
Plant
FE
Barberry, Kofa Mountain
Berberis harrisoniana
AZ, CA
Plant
BS
Barberry, Nevin’s
Berberis nevinii
CA
Plant
FE
Bartonberry
Rubus bartonianus
OR
Plant
BS
Bat, Allen’s big-eared
Idionycteris phyllotis
AZ, CO, NM,
NV, UT
Mammal
BS
Bat, big brown
Eptesicus fuscus
NV
Mammal
BS
Bat, big free-tailed
Nyctinomops macrotis
CO, NV, UT
Mammal
BS
Bat, Brazilian free-tailed
Tadarida brasiliensis
NV, UT
Mammal
BS
Bat, California leaf-nosed
Macrotus californicus
AZ, CA, NV
Mammal
BS
Bat, greater western mastiff
Eumops perotis
AZ, CA, NM,
NV
Mammal
BS
Bat, hoary
Lasiurus cinereus
NV
Mammal
BS
Bat, lesser long-nosed
Leptonycteris curosoae
yerbabuenae
AZ, NM
Mammal
FE
Bat, Mexican long-nosed
Leptonycteris nivalis
NM
Mammal
FE
Bat, Mexican long-tongued
Choernycteris mexicana
AZ, NM
Mammal
BS
Bat, occult little brown (Arizona)
Myotis lucifugus
AZ, NM
Mammal
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-2
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Bat, pale Townsend’s big-eared
Plecotus towns endii
pallescens
NM
Mammal
BS
Bat, pallid
Antrozous pallidus
CA, MT, NV,
OR
Mammal
BS
Bat, pocketed free-tailed
Nyctinomops femorosaccus
AZ
Mammal
BS
Bat, silver-haired
Lasionycteris noctivagans
NV
Mammal
BS
Bat, spotted
Euderma maculatum
AZ, CA, CO,
ID, MT, NV,
OR, UT, WY
Mammal
BS
Bat, Townsend’s big-eared
Plecotus townsendii
AZ, CA, CO,
ID, MT, NV,
OR, IJT, WY
Mammal
BS
Bat, Underwood’s mastiff
Eumops underwoodi
AZ
Mammal
BS
Bat, western red
Lasiurus blossevillii
NV, UT
Mammal
BS
Beaked-rush, California
Rhynchospora californica
CA, WY
Plant
BS
Beakrush, white
Rhynchospora alba
OR
Plant
BS
Bear, grizzly
Ursus arctos horribilis
ID, MT, OR,
WY
Mammal
FT
Bear, polar
Ursus maritimus
AK
Mammal
FT
Beardtongue, Absaroka
Penstemon absarokensis
CA, OR, WY
Plant
BS
Beardtongue, Alamo
Penstemon alamosensis
NM
Plant
BS
Beardtongue, Barrett’s
Penstemon barrettiae
OR
Plant
BS
Beardtongue, bashful
Penstemon pudicus
NV
Plant
BS
Beardtongue, blue-leaf
Penstemon glaucinus
CA, OR
Plant
BS
Beardtongue, bush
Keckiella lemmonii
OR
Plant
BS
Beardtongue, closed-throated
Penstemon personatus
CA
Plant
BS
Beardtongue, Cordelia
Penstemon floribundus
NV
Plant
BS
Beardtongue, Death Valley
Penstemon fruticiformis
CA, NV
Plant
BS
Beardtongue, Degener
Penstemon degeneri
CO
Plant
BS
Beardtongue, Gibbens
Penstemon gibbensii
CO, WY
Plant
BS
Beardtongue, Graham’s
Penstemon grahamii
CO, UT
Plant
BS
Beardtongue, Harrington
Penstemon harringtonii
CO
Plant
BS
Beardtongue, Jaeger
Penstemon thompsoniae
NV
Plant
BS
Beardtongue, Lahontan
Penstemon palmeri
NV
Plant
BS
Beardtongue, Mount Trumbull
Penstemon distans
AZ
Plant
BS
Beardtongue, Nevada dune
Penstemon arenarius
NV
Plant
BS
Beardtongue, Pahute Mesa
Penstemon pahute ns is
NV
Plant
BS
Beardtongue, parachute
Penstemon debilis
CO
Plant
FT
Beardtongue, Penland
Penstemon penlandii
CO
Plant
FE
Beardtongue, Pennell
Penstemon leiophyllus
NV
Plant
BS
Beardtongue, pinto
Penstemon bicolor ssp.
AZ
Plant
BS
Beardtongue, rosy two-tone
Penstemon bicolor ssp.
CA, NV
Plant
BS
Beardtongue, Sheep Range
Penstemon petiolatus
AZ
Plant
BS
Beardtongue, stemless
Penstemon acaulis
WY
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-3
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Beardtongue, Stephen’s
Penstemon stephensii
CA
Plant
BS
Beardtongue, Susanville
Penstemon sudans
CA, NV
Plant
BS
Beardtongue, thread-leaved
Penstemon filiformis
CA
Plant
BS
Beardtongue, Tiehm
Penstemon tiehmii
NV
Plant
BS
Beardtongue, Tracy’s
Penstemon tracyi
CA
Plant
BS
Beardtongue, Tunnel Springs
Penstemon concinnus
NV
Plant
BS
Beardtongue, Wassuk
Penstemon rubicundus
NV
Plant
BS
Beardtongue, Whipple’s
Penstemon whippleanus
MT
Plant
BS
Beardtongue, White River
Penstemon scariosus var.
albifluvis
CO, UT
Plant
BS
Beardtongue, yellow twotone
Penstemon bicolor
NV
Plant
BS
Beargrass, Dehesa
Nolina interrata
CA
Plant
BS
Bear-poppy, dwarf
Arctomecon humilis
UT
Plant
FE
Bear-poppy, Las Vegas
Arctomecon californica
NV
Plant
BS
Bear-poppy, white
Arctomecon merriamii
CA, NV
Plant
BS
Beauty, Ogilvie Mountains
Spring
Claytonia ogilviensis
AK
Plant
BS
Beavertail, short-joint
Opuntia basilaris
CA
Plant
BS
Bedstraw, Alvin meadow
Galium californicum
CA
Plant
BS
Bedstraw, boreal
Galium kamtschaticum
OR
Plant
BS
Bedstraw, El Dorado
Galium californicum ssp.
sierrae
CA
Plant
FE
Bedstraw, Hardham’s
Galium hardhamiae
CA
Plant
BS
Bedstraw, island
Galium buxifolium
CA
Plant
FE
Bedstraw, Kingston
Galium hilendiae
CA
Plant
BS
Bedstraw, Modoc
Galium glabrescens
CA
Plant
BS
Bedstraw, Onyx Peak
Galium angustifolium
CA
Plant
BS
Bedstraw, San Gabriel
Galium grande
CA
Plant
BS
Bee
Anthophora sp.
NV
Invertebrate
BS
Bee
Hesperapis sp.
NV
Invertebrate
BS
Bee
Perdita haigi
NV
Invertebrate
BS
Bee
Perdita sp.
NV
Invertebrate
BS
Bee, Mojave gypsum
Andrena balsamorhizae
NV
Invertebrate
BS
Bee, Mojave poppy
Perdita meconis
NV
Invertebrate
BS
Beehive cactus, Santa Cruz
Coryphantha recurvata
AZ
Plant
BS
Beeplant, yellow
Cleome lutea
MT
Plant
BS
Beetle, American burying
Nicrophorus americanus
MT, WY
Invertebrate
FE
Beetle, blind cave leiodid
Glacicavicola bathyscoides
ID
Invertebrate
BS
Beetle, Bruneau dunes tiger
Cicindela waynei
NV
Invertebrate
BS
Beetle, Chiricahua water
scavenger
Cymbiodyta arizonica
AZ
Invertebrate
BS
Beetle, click
Cardiophorus sp.
NV
Invertebrate
BS
Beetle, Columbia River tiger
Cicindela columbica
NV
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-4
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Beetle, coral pink sand dunes
tiger
Cicindela albissima
UT
Invertebrate
C
Beetle, delta green ground
Elaphrus viridis
CA
Invertebrate
FT
Beetle, Devil’s Hole Warm
Spring riffle
Stenelmis calida
ID, NV
Invertebrate
BS
Beetle, Holsinger’s Cave
Pseudanophthalmus
holsinger
AZ
Invertebrate
C
Beetle, Idaho dunes tiger
Cicindela arenicola
ID
Invertebrate
BS
Beetle, Maricopa tiger
Cicindela oregona
AZ, NV
Invertebrate
BS
Beetle, Moapa Warm Spring
riffle
Stenelmis moapa
NV
Invertebrate
BS
Beetle, Mount Hermon june
Polyphylla barbata
CA
Invertebrate
FE
Beetle, Ohlone tiger
Cicindela ohlone
CA
Invertebrate
FE
Beetle, Roth’s blind ground
Pterostichus rothi
OR
Invertebrate
BS
Beetle, San Joaquin dune
Coelus gracilis
CA
Invertebrate
BS
Beetle, Sand Mountain pygmy
scarab
Coenonycha pygmaea
NV
Invertebrate
BS
Beetle, Siuslaw sand tiger
Cicindela hirticollis
OR
Invertebrate
BS
Beetle, valley elderberry
longhorn
Desmocerus californicus
dimorphus
CA
Invertebrate
FT
Bensoniella, Oregon
Bensoniella oregana
CA, OR
Plant
BS
Bentgrass, Henderson’s
Agrostis hendersonii
OR
Plant
BS
Bentgrass, Howell’s
Agrostis howellii
OR
Plant
BS
Bentgrass, northern
Agrostis borealis
OR
Plant
BS
Birds-beak, hispid
Cordylanthus mollis ssp.
hispidus
CA, OR
Plant
BS
Birds-beak, Mount Diablo
Cordylanthus nidularius
CA
Plant
BS
Birds-beak, pallid
Cordylanthus tenuis ssp.
pallenscens
CA, NM
Plant
BS
Birds-beak, palmate-bracted
Cordylanthus palmatus
CA
Plant
FE
Birds-beak, Pennell’s
Cordylanthus tenuis ssp.
capillaris
CA
Plant
FE
Birds-beak, Point Reyes
Cordylanthus maritimus ssp.
palustris
CA, OR
Plant
BS
Birds-beak, salt marsh
Cordylanthus maritimus ssp.
maritimus
CA
Plant
FE
Birds-beak, seaside
Cordylanthus rigidus
CA
Plant
BS
Birds-beak, soft
Cordylanthus mollis ssp.
mollis
CA
Plant
FE
Birds-beak, Tecopa
Cordylanthus tecopensis
AZ, CA, NV
Plant
BS
Biscuitroot, Canyonlands
Lomatium latilobum
CO
Plant
BS
Biscuitroot, Goodrich
Cymopterus goodrichii
NV
Plant
BS
Bison, wood
Bison bison
AK
Mammal
FE
Bittercress, Constance’s
Cardamine constancei
ID
Plant
BS
Bittercress, Saddle Mountain
Cardamine pattersonii
OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-5
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Bitterweed, Richardson’s
Hymenoxys richardsonii
ID
Plant
BS
Blackbird, rusty
Euphagus carolinus
AK
Bird
BS
Blackbird, tricolored
Agelaius tricolor
CA, OR
Bird
BS
Blackbird, yellow-headed
Xanthocephalus
xanthocephalus
ID
Bird
BS
Bladderpod, beautiful
Lesquerella pulchella
MT
Plant
BS
Bladderpod, Calder’s
Lesquerella calderi
AK
Plant
BS
Bladderpod, cushion
Physaria pulvinata
CO
Plant
BS
Bladderpod, double
Physaria brassicoides
MT
Plant
BS
Bladderpod, Dudley Bluffs
Lesquerella congesta
CO
Plant
FT
Bladderpod, Fremont
Lesquerella fremontii
WY
Plant
BS
Bladderpod, Idaho
Lesquerella carinata
MT
Plant
BS
Bladderpod, Kodachrome
Lesquerella tumulosa
UT
Plant
FE
Bladderpod, large-fruited
Lesquerella macrocarpa
WY
Plant
BS
Bladderpod, pagosa
Lesquerella pruinosa
CO
Plant
BS
Bladderpod, Piceance
Lesquerella parviflora
CO
Plant
BS
Bladderpod, prostrate
Lesquerella prostrata
WY
Plant
BS
Bladderpod, Pryor Mountains
Lesquerella lesicii
MT
Plant
BS
Bladderpod, Salmon twin
Physaria didymocarpa
ID, MT
Plant
BS
Bladderpod, San Bernardino
Mountains
Lesquerella kingii
CA
Plant
FE
Bladderpod, sidesaddle
Lesquerella arenosa
WY
Plant
BS
Bladderpod, Uncompaghre
Lesquerella vicina
CO
Plant
BS
Bladderpod, western
Lesquerella multiceps
WY
Plant
BS
Bladderpod, White Bluffs
Physaria tuplashensis
OR
Plant
FT
Bladderwort, flat-leaved
Utricularia intermedia
OR
Plant
BS
Bladderwort, humped
Utricularia gibba
OR
Plant
BS
Bladderwort, lesser
Utricularia minor
OR
Plant
BS
Bladderwort, northern
Utricularia ochroleuca
OR
Plant
BS
Blazingstar, Ash Meadows
Mentzelia leucophylla
NV
Plant
FT
Blazingstar, creamy
Mentzelia tridentata
CA
Plant
BS
Blazingstar, golden
Mentzelia chrysantha
CO
Plant
BS
Blazingstar, Inyo
Mentzelia inyoensis
CA
Plant
BS
Blazingstar, Pioche
Mentzelia argillicola
NV
Plant
BS
Blazingstar, polished
Mentzelia polita
CA, NV
Plant
BS
Blazingstar, Roan Cliffs
Mentzelia rhizomata
CO
Plant
BS
Blazingstar, Royal Gorge
Mentzelia densa
CO
Plant
BS
Blazingstar, Tiehm’s
Mentzelia tiehmii
NV
Plant
BS
Blazingstar, united
Mentzelia congesta
OR
Plant
BS
Bleedingheart, few-flowered
Dicentra pauc [flora
OR
Plant
BS
Blue, Great Basin small
Philotiella speciosa
NV
Invertebrate
BS
Blue, Sand Mountain
Euphilotes palliscens
NV
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-6
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Bluebell, Drummond’s
Mertensia drummondii
AK
Plant
BS
Blueberry, velvet-leaf
Vaccinium myrtilloides
OR
Plant
BS
Bluecup, Mission Canyon
Githopsis diffusa
CA
Plant
BS
Bluecurls, Hidden Lake
Trichostema austromontanum
CA
Plant
FT
Blue-eyed grass, St. George
Sisyrinchium radicatum
NV
Plant
BS
Blue-eyed grass, pale #1
Sisyrinchium sarmentosum
OR
Plant
BS
Blue-eyed grass, pale #2
Sisyrinchium pallidum
CO, WY
Plant
BS
Bluegrass, Hart’s
Poa hartzii
AK
Plant
BS
Bluegrass, loose-flowered
Poa laxiflora
OR
Plant
BS
Bluegrass, Napa
Poa napensis
CA
Plant
FE
Bluegrass, ocean-bluff
Poa unilateralis
OR
Plant
BS
Bluegrass, Porsild’s
Poa porsildii
AK
Plant
BS
Bluegrass, San Bernardino
Poa atropurpurea
CA
Plant
FE
Bluegrass, short-leaved
Poa arnowiae
MT
Plant
BS
Bluegrass, timber
Poa rhizomata
OR
Plant
BS
Blue-star, Jones
Amsonia jonesii
CO
Plant
BS
Blue-star, Kearney’s
Amsonia kearneyana
AZ, CA
Plant
FE
Bluestar, Peeble’s
Amsonia pee hies ii
A Z, WY
Plant
BS
Bluestem, little
Schizachyrium scoparium
OR
Plant
BS
Boa, rosy
Lichanura trivirgata
AZ, CA
Reptile
BS
Bobolink
Dolichonyx orysivorus
OR, MT, UT
Bird
BS
Bobwhite, masked (quail)
Colinus virginianus
AZ
Bird
FE
Bog-orchid, canyon
Platanthera sparsiflora
OR
Plant
BS
Bog-orchid, choris
Platanthera chorisiana
OR
Plant
BS
Bog-orchid, small northern
Platanthera obtusata
OR
Plant
BS
Bolandra, Oregon
Bolandra oregana
OR
Plant
BS
Bolete, red-pored
Boletus haematinus
CA
Plant
BS
Boneset, western
Ageratina occidentalis
MT
Plant
BS
Breadroot, aromatic Indian
Pediomelum aromaticum
CO
Plant
BS
Breadroot, Beaver Dam
Pediomelum castoreum
NV
Plant
BS
Breadroot, Chihuahua
Pediomelum pentaphyllum
AZ
Plant
BS
Breadroot, Indian
Pediomelum hypogaeum
MT
Plant
BS
Brickellbush, Mohave
Brickellia ohlongifolia
MT
Plant
BS
Bristlemoss, Shevock
Orthotrichum shevockii
CA, NV
Plant
BS
Brittlebrush, annual
Psathyrotes annua
ID, WY
Plant
BS
Brodiaea, Chinese Camp
Brodiaea pallida
CA
Plant
FT
Brodiaea, dwarf
Brodiaea terrestris
OR
Plant
BS
Brodiaea, Indian Valley
Brodiaea coronaria
CA
Plant
BS
Brodiaea, Kaweah
Brodiaea insignis
CA
Plant
BS
Brodiaea, Leach’s
Triteleia hendersonii
OR
Plant
BS
Brodiaea, Orcutt’s
Brodiaea orcuttii
CA
Plant
BS
Brodiaea, thread-leaved
Brodiaea filifolia
CA
Plant
FT
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-7
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Broom, round-leaf
Errazurizia rotundata
AZ
Plant
BS
Broom, San Clemente Island
Lotus dendroideus
CA
Plant
FE
Bryum, beautiful
Bryum calobryoides
ID, OR
Plant
BS
Buckwheat
Eriogonum sp.
CA
Plant
BS
Buckwheat, altered andesite
Eriogonum robustum
NV
Plant
BS
Buckwheat, Beatley
Eriogonum beatleyae
NV
Plant
BS
Buckwheat, blushing wild
Eriogonum ursinum
CA
Plant
BS
Buckwheat, Brandegee’s wild
Eriogonum brandegeei
CO
Plant
BS
Buckwheat, calcareous
Eriogonum ochrocephalum
ID
Plant
BS
Buckwheat, Churchill Narrows
Eriogonum diatomaceum
NV
Plant
C
Buckwheat, Clay Hill
Eriogonum viridulum
CO
Plant
BS
Buckwheat, clay-loving wild
Eriogonum pelinophilum
CA, CO
Plant
FE
Buckwheat, Clokey’s
Eriogonum heermannii
NV
Plant
BS
Buckwheat, Colorado wild
Eriogonum coloradense
CO
Plant
BS
Buckwheat, Comb Wash
Eriogonum clavellatum
CO
Plant
BS
Buckwheat, Crosby’s
Eriogonum crosbyae
CA, NV, OR
Plant
BS
Buckwheat, Cushenbury
Eriogonum ovalifolium var.
vineum
AZ, CA
Plant
FE
Buckwheat, Cusick’s
Eriogonum cusickii
OR
Plant
BS
Buckwheat, Darin
Eriogonum concinnum
NV
Plant
BS
Buckwheat, Deer Lodge
Eriogonum pharnaceoides
NV
Plant
BS
Buckwheat, Deeth
Eriogonum nutans
NV
Plant
BS
Buckwheat, desert
Eriogonum desertorum
CO
Plant
BS
Buckwheat, ephedra
Eriogonum ephedroides
CO
Plant
BS
Buckwheat, forked (Pahrump
Valley buckwheat)
Eriogonum bifurcatum
CA, NV
Plant
BS
Buckwheat, Frisco
Eriogonum soredium
UT
Plant
C
Buckwheat, golden
Eriogonum chrysops
OR
Plant
BS
Buckwheat, grand
Eriogonum contortum
CO, OR
Plant
BS
Buckwheat, green
Eriogonum umbellatum
CA, OR
Plant
BS
Buckwheat, Hoffmann’s
Eriogonum hoffmannii
CA
Plant
BS
Buckwheat, Hooker’s wild
Eriogonum hookeri
OR
Plant
BS
Buckwheat, lone
Eriogonum apricum
CA
Plant
FE
Buckwheat, Kem
Eriogonum kennedyi
CA
Plant
BS
Buckwheat, Klamath Mountains
Eriogonum hirtellum
CA
Plant
BS
Buckwheat, Las Vegas
Eriogonum corymbosum
NV, UT
Plant
C
Buckwheat, Lewis
Eriogonum lewisii
NV
Plant
BS
Buckwheat, Lobb’s
Eriogonum lobbii
OR
Plant
BS
Buckwheat, Lunar Crater
Johannesshowellia
crateriorum
NV
Plant
BS
Buckwheat, matted
Eriogonum caespitosum
MT
Plant
BS
Buckwheat, matted cowpie
Eriogonum shockleyi var.
shockleyi
ID
Plant
BS
BI.M Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-8
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Buckwheat, mouse
Eriogonum nudum
CA
Plant
BS
Buckwheat, Packard’s cowpie
Eriogonum shockleyi var.
packardiae
ID
Plant
BS
Buckwheat, Panamint Mountains
Eriogonum microthecum
CA
Plant
BS
Buckwheat, Pinyon mesa
Eriogonum mensicola
CA
Plant
BS
Buckwheat, Piute
Eriogonum breedlovei
CA
Plant
BS
Buckwheat, playa
Eriogonum salicornioides
OR
Plant
BS
Buckwheat, prostrate
Eriogonum prociduum
CA, NV, OR
Plant
BS
Buckwheat, Railroad Canyon
wild
Eriogonum soliceps
MT
Plant
BS
Buckwheat, Red Mountain
Eriogonum kelloggii
CA, UT
Plant
C
Buckwheat, Reveal’s
Eriogonum contiguum
CA
Plant
BS
Buckwheat, San Carlos wild
Eriogonum capillare
NM
Plant
BS
Buckwheat, San Pedro River
wild
Eriogonum terrenatum
AZ
Plant
BS
Buckwheat, Scarlet
Eriogonum microthecum var.
phoeniceum
NV
Plant
BS
Buckwheat, Schoolcraft’s
Eriogonum microthecum var.
schoolcraftii
CA, NV
Plant
BS
Buckwheat, single-stemmed wild
Eriogonum acaule
CO
Plant
BS
Buckwheat, smooth
Stenogonum salsuginosum
MT
Plant
BS
Buckwheat, Snow Mountain
Eriogonum nervulosum
CA, OR
Plant
BS
Buckwheat, southern mountain
wild
Eriogonum kennedyi var.
austromontanum
CA
Plant
FT
Buckwheat, Steamboat
Eriogonum ovalifolium var.
williamsiae
NV
Plant
FE
Buckwheat, sticky
Eriogonum viscidulum
AZ, NV
Plant
BS
Buckwheat, Temblor
Eriogonum temhlorense
CA
Plant
BS
Buckwheat, Thome’s
Eriogonum thornei
CA
Plant
BS
Buckwheat, Tiehm’s
Eriogonum tiehmii
NV
Plant
BS
Buckwheat, Umtanum desert
Eriogonum codium
OR
Plant
FT
Buckwheat, Visher’s
Eriogonum visheri
MT
Plant
BS
Buckwheat, Welsh’s
Eriogonum capistratum
ID
Plant
BS
Buckwheat, Wild Rose Canyon
Eriogonum eremicola
CA
Plant
BS
Buckwheat, windloving
Eriogonum anemophilum
NV
Plant
BS
Buckwheat, woodside
Eriogonum tumulosum
CO
Plant
BS
Bufflehead
Bucephala alheola
OR
Bird
BS
Bug, hairy shore
Saldula villosa
OR
Invertebrate
BS
Bug, Harney Hot Spring shore
Micracanthia fennica
OR
Invertebrate
BS
Bug, Oregon plant
Lygus oregonae
OR
Invertebrate
BS
Bug, Pahranagat Naucorid
Pelocoris shoshone shoshone
NV, OR
Invertebrate
BS
Bug, Santa Rita Mountains
chlorochroan
Chlorochroa rita
AZ
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Pinal Programmatic EIS
E-9
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Bugbane, tall
Cimicifuga elata
OR
Plant
BS
Bug-on-a-stick, leafless
Buxbaumia aphylla
OR
Invertebrate
BS
Bug-on-a-stick, pipers
Buxbaumia piperi
CA
Invertebrate
BS
Bugseed, crescent
Corispermum navicula
CO
Plant
BS
Bulrush, drooping
Scirpus pendulus
OR
Plant
BS
Bulrush, little
Scirpus rollandii
CO
Plant
BS
Bulrush, Rolland’s
Trichophorum pumilum
CO
Plant
BS
Bulrush, slender
Schoenoplectus heterochaetus
MT
Plant
BS
Bumblebee, Franklin’s
Bombus franklini
OR
Invertebrate
BS
Bunting, Mckay’s
Plectrophenax hyperboreus
AK
Bird
BS
Bupleurum
Bupleurum americanum
OR
Plant
BS
Burbot
Lota lota
ID
Fish
BS
Bush, gentry indigo
Dalea tentaculoides
AZ
Plant
BS
Bush, iodine
Allenrolfea occidentalis
OR
Plant
BS
Bush, Marble Canyon indigo
Psorothamnus arborescens
AZ
Plant
BS
Bush-mallow, Arroyo Seco
Malacothamnus palmeri
CA
Plant
BS
Bush-mallow, San Clemente
Island
Malacothamnus clementinus
CA
Plant
FE
Bush-mallow, Santa Cruz Island
Malacothamnus fasciculatus
CA
Plant
FE
Buttercup, autumn
Ranunculus aestivalis
UT
Plant
FE
Buttercup, California
Ranunculus californicus
OR
Plant
BS
Buttercup, Cooley’s
Ranunculus cooleyae
OR
Plant
BS
Buttercup, glacier
Ranunculus glacialis var.
camissonis
AK
Plant
BS
Buttercup, glacier
Ranunculus glacialis
AK
Plant
BS
Buttercup, mountain
Ranunculus populago
OR
Plant
BS
Buttercup, northern
Ranunculus pedatifidus
MT
Plant
BS
Buttercup, obscure
Ranunculus triternatus
NV, OR
Plant
BS
Buttercup, sagebrush
Ranunculus reconditus
OR
Plant
BS
Buttercup, southern Oregon
Ranunculus austrooreganus
OR
Plant
BS
Buttercup, Turner’s
Ranunculus turneri
AK
Plant
BS
Butterfly, baking powder flat
blue
Euphilotes bernardino minuta
NV
Invertebrate
BS
Butterfly, bay checkerspot
Euphydryas editha bayensis
CA
Invertebrate
FT
Butterfly, Behren’s silverspot
Speyeria zerene behrensii
CA
Invertebrate
FE
Butterfly, Callippe silverspot
Speyeria callippe callippe
CA
Invertebrate
FE
Butterfly, early blue
Euphilotes enoptes
NV
Invertebrate
BS
Butterfly, El Segundo blue
Euphilotes battoides allyni
CA
Invertebrate
FE
Butterfly, Fender’s blue
Icaricia icarioides fenderi
OR
Invertebrate
FE
Butterfly, Great Basin silverspot
Speyeria nokomis
AZ, CO, NV,
UT
Invertebrate
BS
Butterfly, insular blue
Plebejus saepiolus insulanus
OR
Invertebrate
BS
Butterfly, Lange’s metalmark
Apodemia mormo langei
CA
Invertebrate
FE
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-10
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Butterfly, lotis blue
Lycaeides argyrognomon
lotis
CA
Invertebrate
FE
Butterfly, Mattoni’s blue
Euphilotes palliscens mattoni
NV
Invertebrate
BS
Butterfly, mission blue
Icaricia icarioides
missionensis
CA
Invertebrate
FE
Butterfly, Mount Charleston blue
Plebejus shasta
charlestonensis
NV
Invertebrate
BS
Butterfly, Myrtle’s silverspot
Speyeria zerene myrtleae
CA
Invertebrate
FE
Butterfly, Oregon silverspot
Speyeria zerene hippolyta
CA, OR
Invertebrate
FT
Butterfly, Palos Verdes blue
Glaucopsyche lygdamus
palosverdesensis
CA
Invertebrate
FE
Butterfly, Quino checkerspot
Euphydryas editha quino
CA
Invertebrate
FE
Butterfly, Rice’s blue
Euphilotes palliscens ricei
NV
Invertebrate
BS
Butterfly, San Bruno elfin
Callophrys mossii hayensis
CA
Invertebrate
FE
Butterfly, Smith’s blue
Euphilotes enoptes smithii
CA
Invertebrate
FE
Butterfly, Spring Mountains dark
blue
Euphilotes ancilla cryptica
NV
Invertebrate
BS
Butterfly, Spring Mountains
icarioides blue
Plebejus icarioides
austinorum
NV
Invertebrate
BS
Butterfly, Taylor’s checkerspot
Euphydryas editha taylori
OR
Invertebrate
FE
Butterfly, Thome’s hairstreak
Mitoura thornei
CA
Invertebrate
BS
Butterfly, Uncompahgre fritillary
Boloria acrocnema
CO
Invertebrate
FE
Butterfly plant, Colorado
Gaura neomexicana var.
coloradensis
CA, CO, WY
Plant
FT
Butterweed, Gander’s
Packera ganderi
CA
Plant
BS
Butterweed, Layne’s
Senecio layneae
CA
Plant
FT
Button-celery, San Diego
Eryngium aristulatum
CA
Plant
FE
Cabbage, slender wild
Caulanthus major
OR
Plant
BS
Cabbage, smooth wild
Caulanthus crassicaulis
OR
Plant
BS
Cactus, Acuna
Echinomastus erectocentrus
var. acunensis
AZ
Plant
FE
Cactus, Bakersfield
Opuntia treleasei
CA
Plant
FE
Cactus, bracks
Sclerocactus cloveriae
NM
Plant
BS
Cactus, Colorado hookless
Sclerocactus glaucus
CO, UT
Plant
FT
Cactus, cushion
Coryphantha vivipara
ID
Plant
BS
Cactus, Duncan’s cory
Coryphantha duncanii
NM
Plant
BS
Cactus, Fickeisen Plains
Pediocactus peeblesianus var.
Jickeiseniae
AZ
Plant
FE
Cactus, Knowlton’s
Pediocactus knowltonii
CO, NM
Plant
FE
Cactus, Mesa Cerde
Sclerocactus mesae-verdae
CO, NM, UT
Plant
FT
Cactus, Nichol’s Turk’s head
Echinocactus
horizonthalonius var. nicholli
AZ
Plant
FE
Cactus, Pariette
Sclerocactus brevispinus
UT
Plant
FT
BLM Vegetation Treatments Three New Herbicides
Final Programmatic CIS
E-l 1
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Cactus, Peebles Navajo
Pediocactus peeblesianus var.
peeblesianus
A Z
Plant
FE
Cactus, Pima Pineapple
Coryphantha scheeri var.
robustispina
AZ
Plant
FE
Cactus, San Rafael
Pediocactus despainii
NM, UT
Plant
FE
Cactus, Winkler
Pediocactus winkleri
UT
Plant
FT
Caddisfly, a
Rhyacophila chandleri
OR
Invertebrate
BS
Caddisfly, Haddock’s
rhyacophilan
Rhyacophila haddocki
ID, OR
Invertebrate
BS
Caddisfly, Scott’s apatanian
Allomyia scotti
OR
Invertebrate
BS
Calicoflower, harlequin
Downingia insignis
ID
Plant
BS
Calycadenia, dwarf
Calycadenia villosa
CA
Plant
BS
Calycadenia, Hoover’s
Calycadenia hooveri
CA
Plant
BS
Calycadenia, small-flowered
Calycadenia micrantha
CA
Plant
BS
Camas, Cusick’s
Camassia cusickii
ID
Plant
BS
Camas, Howell’s
Camassia howellii
OR
Plant
BS
Camas, small-flowered death
Zigadenus fontanus
OR
Plant
BS
Camissonia, small
Camissonia parvula
MT
Plant
BS
Campion, long-stiped
Silene occidentalis
CA
Plant
BS
Campion, Red Mountain
Silene campanulata
CA
Plant
BS
Candle, miner’s
Cryptantha scoparia
MT, OR
Plant
BS
Candle, Owl Creek miner’s
Cryptantha subcapitata
WY
Plant
BS
Candystick
Allotropa virgata
ID
Plant
BS
Caribou, woodland
Rangifer tarandus caribou
ID, OR
Mammal
FE
Catchfly, Bolander’s
Silene hookcri
OR
Plant
BS
Catchfly, Jan’s
Silene nachlingerae
NV
Plant
BS
Catchfly, Spalding’s
Silene spaldingii
ID, MT, OR
Plant
FT
Catfish, Yaqui
Ictalurus pricei
AZ
Fish
FT
Catseye, Fendler’s
Cryptantha fendleri
MT
Plant
BS
Catseye, Gypsum Valley
Cryptantha gypsophila
CO
Plant
BS
Catseye, Shacklette’s
Cryptantha shackletteana
AK
Plant
BS
Catseye, smooth
Crypthantha semiglabra
AZ
Plant
BS
Catseye, unusual
Cryptantha insolita
NV
Plant
BS
Caulostramina, Jaeger’s
Caulostramina jaegeri
CA
Plant
BS
Ceanothus, Calistoga
Ceanothus divergens
CA
Plant
BS
Ceanothus, coyote
Ceanothus ferrisae
CA
Plant
FE
Ceanothus, Hearst’s
Ceanothus hearstiorum
CA
Plant
BS
Ceanothus, lakeside
Ceanothus cyaneus
CA
Plant
BS
Ceanothus, Mahala-mat
Ceanothus prostratus
ID
Plant
BS
Ceanothus, Monterey
Ceanothus cuneatus
CA
Plant
BS
Ceanothus, Pine Hill
Ceanothus roderickii
CA
Plant
FE
Ceanothus, Rincon Ridge
Ceanothus confusus
CA
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-12
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Ceanothus, Vail Lake
Ceanothus ophiochilus
CA
Plant
FT
Cedar, ground
Lycopodium complanatum
OR
Plant
BS
Centaury, spring-loving
Centaurium namophilum
CA, NV
Plant
FT
Cereus, desert night-blooming
Cereus greggii
CA, NM
Plant
BS
Chaenactis, desert
Chaenactis xantiana
OR
Plant
BS
Chaenactis, Shasta
Chaenactis suffrutescens
CA
Plant
BS
Chaenactis, Thompson’s
Chaenactis thompsonii
OR
Plant
BS
Chanterelle, blue
Polyozellus multiplex
CA
Plant
BS
Char, arctic (Kigluaik
Mountains)
Salvelinus alpinus
AK
Fish
BS
Chat, yellow-brested
Icteria virens
CO
Bird
BS
Checkerbloom, coast
Sidalcea oregana ssp. eximia
CA, OR
Plant
BS
Checkerbloom, Cuesta Pass
Sidalcea hickmanii ssp.
anomala
CA
Plant
BS
Checkerbloom, dwarf
Sidalcea malviflora
CA, OR
Plant
BS
Checkerbloom, Hickman’s
Sidalcea hickmanii ssp.
hickmanii
OR
Plant
BS
Checkerbloom, Owens Valley
Sidalcea covillei
CA
Plant
BS
Checkerbloom, Parish’s
Sidalcea hickmanii ssp.
parshii
CA
Plant
C
Checker-mallow, Butte County
Sidalcea rohusta
CA
Plant
BS
Checker-mallow, Keck’s
Sidalcea keckii
CA, UT
Plant
FE
Checker-mallow, Kenwood
Marsh
Sidalcea oregana ssp. valida
CA
Plant
FE
Checker-mallow, meadow
Sidalcea campestris
OR
Plant
BS
Checker-mallow, Nelson’s
Sidalcea nelsoniana
OR
Plant
FT
Checker-mallow, pedate
Sidalcea pedata
CA
Plant
FE
Checker-mallow, Wenatchee
Mountains
Sidalcea oregana var. calva
OR
Plant
FE
Checkerspot, Spring Mountain
acastus
Chlosyne acastus
NV
Invertebrate
BS
Chickweed, creeping
Stellaria humifusa
OR
Plant
BS
Chicory, California
Rajinesquia californica
OR
Plant
BS
Chinquapin, golden
Chrysolepis chrysophylla
OR
Plant
BS
Chipmunk, gray-footed
Tamias canipes
NM
Mammal
BS
Chipmunk, Organ Mountains
Colorado
Eutamias quadrivittatus
australis
NM
Mammal
BS
Chipmunk, red-tailed
Tamias ruficaudus
OR
Mammal
BS
Cholla, Blue Diamond
Opuntia whipplei var.
multigeniculata
NV
Plant
BS
Cholla, Munz
Cylindropuntia munzii
CA
Plant
BS
Cholla, sand
Grusonia pulchella
NV
Plant
BS
Chub, Alvord
Gila alvordensis
OR
Fish
BS
Bl.M Vegetation Treatments Three New Herbicides
Final Programmatic FIS
E-13
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Chub, bonytail
Gila elegans
AZ, CA, CO,
NV, UT, WY
Fish
FE
Chub, Borax Lake
Gila boraxobius
OR
Fish
FE
Chub, Catlow tui
Gila bicolor ssp.
OR
Fish
BS
Chub, Chihuahua
Gila nigrescens
NM
Fish
FT
Chub, Cowhead Lake tui
Gila bicolor ssp.
CA
Fish
FP
Chub, Fish Lake Valley tui
Gila bicolor ssp.
NV
Fish
BS
Chub, flathead
Platygobio gracilis
CO, NM
Fish
BS
Chub, Gila
Gila intermedia
AZ, NM
Fish
FE
Chub, Goose Lake tui
Gila bicolor thalassina
OR
Fish
BS
Chub, headwater
Gila nigra
AZ, NM
Fish
C
Chub, homyhead
Nocomis biguttahtus
WY
Fish
BS
Chub, Hot Creek Valley tui
Gila bicolor ssp.
NV
Fish
BS
Chub, humpback
Gila cypha
AZ, CO, UT,
WY
Fish
FE
Chub, Hutton tui
Gila bicolor ssp.
OR
Fish
FT
Chub, Independence Valley tui
Gila bicolor isolata
NV
Fish
BS
Chub, least
Iotichthys phlegethontis
NM, UT
Fish
C
Chub, leatherside
Gila copei
ID, UT, WY
Fish
BS
Chub, Mohave tui
Gila bicolor mohavensis
CA
Fish
FE
Chub, Newark Valley Tui
Lepidomeda copei
NV, UT, WY
Fish
BS
Chub, northern leatherside
Gila bicolor newarkensis
NV
Fish
BS
Chub, Oregon
Oregonichthys crameri
OR
Fish
FT
Chub, Oregon Lakes tui
Gila bicolor oregonensis
OR
Fish
BS
Chub, Owen’s tui
Gila bicolor snyderi
CA
Fish
FE
Chub, Pahranagat roundtail
Gila robusta jordani
NV
Fish
FE
Chub, railroad valley Tui
Gila pandora
CO
Fish
BS
Chub, Rio Grande
Gila bicolor ssp.
NV
Fish
BS
Chub, roundtail
Gila robusta
AZ, CO, NM,
UT, WY
Fish
C
Chub, Sheldo tui
Gila bicolor eurysoma
OR
Fish
C
Chub, sicklefin
Machrybopsis meeki
ID, OR
Fish
BS
Chub, Sonora
Gila ditaenia
AZ
Fish
FT
Chub, southern leatherside
Lepidomeda aliciae
UT
Fish
BS
Chub, sturgeon
Machrybopsis gelida
ID, MT, UT
Fish
BS
Chub, Summer Basin tui
Gila bicolor ssp.
OR
Fish
BS
Chub, Umpqua Oregon
Oregonichthys kalawatseti
OR
Fish
BS
Chub, Virgin River
Gila seminuda
AZ, NV, UT
Fish
FE
Chub, Yaqui
Gila purpurea
AZ
Fish
FE
Chuckwalla
Sauromalus ater
AZ, NV, UT
Reptile
BS
Chuckwalla, Glen Canyon
Sauromalus obesus ssp.
NV, UT
Reptile
BS
Chuckwalla, western
Sauromalus obesus
UT
Reptile
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-14
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Cinquefoil, circumpolar
Potentilla stipularis
AK
Plant
BS
Cinquefoil, Cottam’s
Potentilla cottamii
NV
Plant
BS
Cinquefoil, Platte
Potentilla plattensis
MT
Plant
BS
Cinquefoil, snow
Potentilla nivea
OR
Plant
BS
Cinquefoil, Soldier Meadows
Potentilla basaltica
CA, NV
Plant
C
Cladonia
Cladonia uncialis
OR
Plant
BS
Clarkia, beaked
Clarkia rostrata
CA, OR
Plant
BS
Clarkia, Brandegee’s
Clarkia biloba ssp.
brandegeeae
CA
Plant
BS
Clarkia, Caliente (Vasek’s
clarkia)
Clarkia trembloriensis ssp.
caleintensis
CA
Plant
BS
Clarkia, Enterprise
Clarkia mosquinii ssp.
xerophylla
CA
Plant
BS
Clarkia, Mariposa
Clarkia biloba
CA
Plant
BS
Clarkia, Mildred’s
Clarkia mildrediae
CA
Plant
BS
Clarkia, Mosquin’s
Clarkia mosquinii ssp.
mosquinii
CA
Plant
BS
Clarkia, northern
Clarkia borealis
CA
Plant
BS
Clarkia, Pismo
Clarkia speciosa ssp.
immaculata
CA
Plant
FE
Clarkia, Presidio
Clarkia franciscana
CA
Plant
FE
Clarkia, Shasta
Clarkia borealis ssp. arida
CA, OR
Plant
BS
Clarkia, small southern
Clarkia australis
CA
Plant
BS
Clarkia, Springville
Clarkia springvillensis
CA
Plant
FT
Clarkia, Vine Hill
Clarkia imbricata
CA
Plant
FE
Clarkia, white-stemmed
Clarkia gracilis
CA
Plant
BS
Claytonia, Great Basin
Claytonia umbellata
CA
Plant
BS
Cleomella, flat-seeded
Cleomella plocasperma
ID
Plant
BS
Cliff-brake, Bridge’s
Pellaea bridgesii
OR
Plant
BS
Cliffbrake, Sierra
Pellaea brachyptera
OR
Plant
BS
Cliff-rose, Arizona
Purshia subintegra
AZ
Plant
FE
Clover, Bameby’s
Trifolium barnebyi
WY
Plant
BS
Clover, Butte County golden
Trifolium jokerstii
CA
Plant
BS
Clover, Currant Summit
Trifolium andinum
NV
Plant
BS
Clover, Dedecker’s
Trifolium dedeckerae
CA
Plant
BS
Clover, Douglas
Trifolium douglasii
OR
Plant
BS
Clover, Frisco
Trifolium friscanum
UT
Plant
C
Clover, Leiberg’s
Trifolium leibergii
OR
Plant
BS
Clover, Monterey
Trifolium trichocalyx
CA
Plant
FE
Clover, mountain
Trifolium andinum
CO
Plant
BS
Clover, Owyhee
Trifolium owyheense
ID, OR
Plant
BS
Clover, Pacific Grove
Trifolium polyodon
CA
Plant
BS
Clover, plumed
Trifolium plumosum
CA, WY
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-15
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Clover, Santa Cruz
Trifolium buckwestiorum
CA
Plant
BS
Clover, showy Indian
Trifolium amoenum
CA
Plant
FE
Clover, Thompson’s
Trifolium thompsonii
OR
Plant
BS
Clubmoss, bog
Lycopodiella inundata
OR
Plant
BS
Clubmoss, treelike
Lycopodium dendroideum
OR
Plant
BS
Clubrush, water
Schoenoplectus subterminalis
OR
Plant
BS
Collinsia, few-flowered
Collinsia sparsijlora
OR
Plant
BS
Collinsia, San Antonio
Collinsia antonina
CA
Plant
BS
Collomia, Barren Valley
Collomia renacta
CO, NV
Plant
BS
Collomia, bristle-flowered
Collomia macrocalyx
OR
Plant
BS
Collomia, Mount Mazama
Collomia mazama
ID, OR
Plant
BS
Collybia, branched
Collybia racemosa
CA
Plant
BS
Columbine, Laramie
Aquilegia laramiensis
OR, WY
Plant
BS
Columbine, Rydberg’s golden
Aquilegia chrysantha
CO, ID
Plant
BS
Columbine, Sitka
Aquilegia formosa
MT
Plant
BS
Combleaf, desert
Polyctenium fremontii
OR
Plant
BS
Combleaf, William’s
Polyctenium williamsiae
CA, NV, OR
Plant
BS
Condor, California
Gymnogyps californianus
AZ, CA, UT
Bird
XN, FE
Copper, Hermes
Lycaena hermes
CA
Invertebrate
C
Coral, hairy-stemmed
Clavulina castanopes
CA
Plant
BS
Coral, strap
Clavariadelphus ligula
CA
Plant
BS
Coralroot, Chisos Mountains
Hexalectris revoluta
AZ, OR
Plant
BS
Coralroot, purple-spike
Hexalectris warnockii
AZ, CO
Plant
BS
Cordgrass, prairie
Spartina pectinata
OR
Plant
BS
Coreopsis, Mount Hamilton
Coreopsis hamiltonii
CA
Plant
BS
Comsnake
Elaphe guttata
UT
Reptile
BS
Corwnscale, San Jacinto Valley
Atrip lex coronata
CA
Plant
FE
Corydalis, Case’s
Corydalis caseana
ID
Plant
BS
Cotton-grass, green keeled
Eriophorum viridicarinatum
OR
Plant
BS
Cotton-grass, russet
Eriophorum chamissonis
OR
Plant
BS
Cotton-grass, slender
Eriophorum gracile
CO
Plant
BS
Coyote-thistle, Loch Lomond
Eryngium constancei
CA
Plant
FE
Coyote-thistle, Oregon
Eryngium petiolatum
OR
Plant
BS
Crane, greater Sandhill
Grus canadensis tabida
CA
Bird
BS
Crane, Sandhill
Grus canadensis
OR
Bird
BS
Crane, whooping
Grus americana
CO, ID, MT,
WY
Bird
FE, XN
Crayfish, Shasta
Pacifastacus fords
CA
Invertebrate
FE
Crazyweed, challis
Oxytropis besseyi
ID
Plant
BS
Crazyweed, Columbia
Oxytropis campestris var.
columbiana
OR
Plant
BS
Crazyweed, slender
Oxytropis campestris
OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-16
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Crazy weed, Wanapum
Oxytropis campestris var.
wanapum
OR
Plant
BS
Creamsacs, pink
Castilleja rubicundula ssp.
rubicundula
CA
Plant
BS
Crescentspot, Steptoe Valley
Phyciodes cocyta arenacolor
NV
Invertebrate
BS
Cress, Bodie Hills rock
Arabis bodiensis
CA
Plant
BS
Cricket, Arizona giant sand
treader
Daihinibaenetes arizonensis
AZ
Invertebrate
BS
Cricket, Mary’s Peak ice
Grylloblatta sp.
OR
Invertebrate
BS
Cricket, Navajo Jerusalem
Stenopelmatus navajo
AZ
Invertebrate
BS
Croton, Wiggins
Croton wigginsii
CA
Plant
BS
Crownbeard, big-leaved
Verbesina dissita
CA
Plant
FT
Cryptantha, beaked
Cryptantha rostellata
OR
Plant
BS
Cryptantha, bristlecone
Cryptantha roosiorum
CA
Plant
BS
Cryptantha, Clokey’s
Cryptantha clokeyi
CA
Plant
BS
Cryptantha, deep-scarred
Cryptantha excavata
CA
Plant
BS
Cryptantha, Gander’s
Cryptantha ganderi
CA
Plant
BS
Cryptantha, gray
Cryptantha leucophaea
OR
Plant
BS
Cryptantha, Mariposa
Cryptantha mariposae
CA
Plant
BS
Cryptantha, Milo Baker’s
Cryptantha milo-bakeri
OR
Plant
BS
Cryptantha, narrow-stem
Cryptantha gracilis
OR
Plant
BS
Cryptantha, Osterhout
Cryptantha osterhoutii
CO
Plant
BS
Cryptantha, Rollins’
Cryptantha rollinsii
CO
Plant
BS
Cryptantha, Schoolcraft’s
Cryptantha schoolcraftii
CA, NV
Plant
BS
Cryptantha, seaside
Cryptantha leiocarpa
OR
Plant
BS
Cryptantha, serpentine
Cryptantha clevelandii
CA
Plant
BS
Cryptantha, silky
Cryptantha crinita
CA, WY
Plant
BS
Cryptantha, Snake River
Cryptantha spiculifera
OR
Plant
BS
Cryptantha, tufted
Cryptantha caespitosa
CO, ID
Plant
BS
Crytpantha, Unita Basin
Cryptantha breviflora
ID
Plant
BS
Cuckoo, black-billed
Coccyzus erythropthelmus
ID
Bird
BS
Cuckoo, yellow-billed (western
DPS)
Coccyzus americanus
AZ, CA, CO,
ID, MT, NM,
NV, OR, UT,
WY
Bird
FT
Cui-ui
Chasmistes cujus
NV
Fish
FE
Curlew, bristle-thighed
Numenius tahitiensis
AK
Bird
BS
Curlew, Eskimo
Numenius borealis
AK, MT
Bird
FE
Curlew, long billed
Numenius americanus
CO, ID, MT,
UT, WY, OR
Bird
BS
Currant, Moreno San Diego
Ribes canthariforme
CA
Plant
BS
Currant, wax
Ribes cereum
OR
Plant
BS
Currant, Wolfs
Ribes wolfii
ID
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-17
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Cusickiella, Bodie Hills
Cusickiella quadricostata
CA, NV, WY
Plant
BS
Cycladenia, Jones
Cycladenia humilis var.
jonesii
AZ, CA, UT
Plant
FT
Cymopterus, desert
Cymopterus deserticola
CA
Plant
BS
Cymopterus, Greeley’s
Cymopterus acaulis
ID, OR
Plant
BS
Cymopterus, purple
Cymopterus purpurascens
OR
Plant
BS
Cymopterus, Ripley’s
Cymopterus ripleyi
CA
Plant
BS
Cyperus, short-pointed
Cyperus acuminatus
OR
Plant
BS
Cypress, Baker’s
Cupressus bakeri
OR
Plant
BS
Cypress, Gowen
Cupressus goveniana
CA
Plant
FT
Cypress, Piute
Cupressus arizonica ssp.
nevadensis
CA
Plant
BS
Cypress, Santa Cruz
Cupressus abramsiana
CA
Plant
FE
Cypress, Tecate
Callitropsis forbesii
CA
Plant
BS
Dace, Amargosa speckled
Rhinichthys osculus
CA
Fish
BS
Dace, Ash Meadows speckled
Rhinichthys osculus
nevadensis
NV
Fish
FE
Dace, Clover Valley speckled
Rhinichthys osculus
oligoporus
NV
Fish
FE
Dace, desert
Eremichthys acros
NV
Fish
FT
Dace, Foskett speckled
Rhinichthys osculus ssp.
OR
Fish
FT
Dace, Independence Valley
speckled
Rhinichthys osculus
lethoporus
NV
Fish
FE
Dace, Kendall Warm Springs
Rhinichthys osculus thermalis
WY
Fish
FE
Dace, longfin
Agosia chrysogaster
AZ, NM
Fish
BS
Dace, Meadow Valley speckled
Rhinichthys osculus
NV
Fish
BS
Dace, millicoma
Rhinichthys cataractae
OR
Fish
BS
Dace, Moapa
Moapa coriacea
NV
Fish
FE
Dace, Moapa speckled
Rhinichthys osculus moapae
NV, OR
Fish
BS
Dace, Monitor Valley speckled
Rhinichthys osculus ssp.
NV
Fish
BS
Dace, northern redbelly x
finescale
Phoxinus eos x phoxinus
neogaeus
MT
Fish
BS
Dace, Oasis Valley speckled
Rhinichthys osculus ssp.
NV
Fish
BS
Dace, Owens speckled
Rhinichthys osculus ssp.
CA
Fish
BS
Dace, Pahranagat speckled
Rhinichthys osculus velifer
NV
Fish
BS
Dace, pearl
Margariscus margarita
MT
Fish
BS
Dace, relict
Relictus solitarius
NV
Fish
BS
Dace, speckled
Rhinichthys osculus
AZ, NM
Fish
BS
Dace, Umatilla
Rhinichthys umatilla
OR
Fish
BS
Dace, White River speckled
Rhinichthys osculus ssp.
NV
Fish
BS
Daisy, basalt
Erigeron basalticus
OR
Plant
BS
Daisy, Blochman’s leafy
Erigeron blochmaniae
CA
Plant
BS
Daisy, Cedar Mountain Easter
Townsendia microcephala
WY
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-18
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Daisy, Engelmann’s
Erigeron engelmannii
OR
Plant
BS
Daisy, hairy Townsend
Townsendia strigosa
CO
Plant
BS
Daisy, Hall’s
Erigeron aequifolius
CA
Plant
BS
Daisy, Howell’s
Erigeron howellii
OR
Plant
BS
Daisy, Kachina
Erigeron kachinensis
CO
Plant
BS
Daisy, Kern River
Erigeron multiceps
CA
Plant
BS
Daisy, Maguire
Erigeron maguirei
AZ, UT
Plant
FE
Daisy, Panamint
Enceliopsis covillei
CA
Plant
BS
Daisy, Parish’s
Erigeron parishii
CA
Plant
FT
Daisy, Piper’s
Erigeron piperianus
OR
Plant
BS
Daisy, rock (Laphamia,
Hanaupah)
Perityle villosa
CA
Plant
BS
Daisy, Siskiyou
Erigeron cervinus
OR
Plant
BS
Daisy, Willamette
Erigeron decumbens var.
decumbens
OR
Plant
FE
Dalea, ornate
Dalea ornata
CA, OR
Plant
BS
Dandelion, desert
Malacothrix torreyi
MT
Plant
BS
Dandelion, Rocky Mountain
Taraxacum eriophorum
MT
Plant
BS
Darter, Arkansas
Etheostoma cragini
CO
Fish
C
Darter, Iowa
Etheostoma exile
CO
Fish
BS
Darter, orangethroat
Etheostoma spec tab He
MT
Fish
BS
Deer, Columbian white-tailed
Odocoileus virginianus
leucurus
OR
Mammal
FE
Deer-fern
Blechnum spicant
ID, NM
Plant
BS
Desertgrass, King’s
Blepharidachne kingii
ID
Plant
BS
Desert-mallow, Rusby’s
Sphaeralcea rusbyi
CA
Plant
BS
Desert-parsley, adobe
Lomatium concinnum
CO
Plant
BS
Desert-parsley, Bradshaw’s
Lomatium bradshawii
OR
Plant
FE
Desert-parsley, Englemann’s
Lomatium engelmannii
OR
Plant
BS
Desert-parsley, fringed
Lomatium foeniculaceum
OR
Plant
BS
Desert-parsley, Hoover’s
Lomatium tuberosum
OR
Plant
BS
Desert-parsley, Nuttall
Lomatium nuttallii
MT
Plant
BS
Desert-parsley, Packard’s
Lomatium packardiae
ID, NV
Plant
BS
Desert-parsley, Rollins’
Lomatium rollinsii
OR
Plant
BS
Desert-parsley, salmon-flower
Lomatium salmoniflorum
ID
Plant
BS
Desert-parsley, smooth
Lomatium laevigatum
OR
Plant
BS
Desert-parsley, Snake Canyon
Lomatium serpentinum
OR
Plant
BS
Desert-parsley, taper-tip
Lomatium attenuatum
MT
Plant
BS
Desert-parsley, Watson’s desert
Lomatium watsonii
OR
Plant
BS
Dichanthelium, Geyser’s
Dichanthelium lanuginosum
CA
Plant
BS
Dickcissel
Spiza americana
MT, UT
Bird
BS
Disc, Cockerell’s striate
Discus shemeki
AZ, UT
Invertebrate
BS
Disc, marbled
Discus marmorensis
ID
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-19
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Ditaxis, California
Ditaxis californica
CA
Invertebrate
BS
Dodder, sepal-tooth
Cuscuta denticulata
ID
Plant
BS
Dogweed, Wright’s
Adenophyllum wrightii
NM
Plant
BS
Dogwood, Pacific
Cornus nuttallii
ID
Plant
BS
Doublet (dimeresia)
Dimeresia howellii
ID, UT
Plant
BS
Douglasia, Mackenzie River
Douglasia arctica
AK
Plant
BS
Downingia, Bacigalupi’s
Downingia bacigalupii
ID
Plant
BS
Draba, beavertip
Draba globosa
MT
Plant
BS
Draba, Douglas’
Cusickiella douglasii
OR
Plant
BS
Draba, globe-fruited
Draba globosa
ID
Plant
BS
Draba, golden
Draba aurea
OR
Plant
BS
Draba, lance-leaved
Draba cana
OR
Plant
BS
Draba, long-stalked
Draba longipes
OR
Plant
BS
Draba, Mount Eddy
Draba carnosula
CA
Plant
BS
Draba, Ogilvlie Range
Draba ogilviensis
AK
Plant
BS
Draba, Wind River
Draba ventosa
MT
Plant
BS
Draba, Yellowstone
Draba incerta
ID
Plant
BS
Dropseed, annual
Muhlenbergia minutissima
OR
Plant
BS
Dropseed, tall
Sporobolus asper
ID
Plant
BS
Duck, canvasback
Aythya valisineria
MT
Bird
BS
Duck, fulvous whistling
Dendrocygna bicolor
A Z, ID
Bird
BS
Duck, harlequin
Histrionicus histrionicus
ID, MT, WY,
OR
Bird
BS
Dudley a, Conejo
Dudleya abramsii ssp. parva
CA
Plant
FT
Dudleya, many-stemmed
Dudleya multicaulis
CA
Plant
BS
Dudleya, marcescent
Dudleya cymosa ssp.
marcescens
CA
Plant
FT
Dudleya, panamint
Dudleya saxosa
CA
Plant
BS
Dudleya, San Luis Obispo
Dudleya abramsii ssp.
murina
CA
Plant
BS
Dudleya, San Luis Obispo
serpentine
Dudleya abramsii ssp.
bettinae
CA, ID
Plant
BS
Dudleya, Santa Clara Valley
Dudleya abramsii ssp.
setchellii
CA
Plant
FE
Dudleya, Santa Cruz Island
Dudleya nesiotica
CA
Plant
FT
Dudleya, variegated
Dudleya variegata
CA
Plant
BS
Dudleya, Verity’s
Dudleya verityi
CA
Plant
FT
Dudleya, Santa Monica
Mountains
Dudleya cymosa
CA
Plant
FT
Duskysnail, Columbia
Colligyrus sp.
OR
Invertebrate
BS
Dwarf-flax, Marin
Hesperolinon congestum
CA
Plant
FT
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-20
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Eagle, bald
Haliaeetus leucocephalus
AK, AZ, CA,
CO, ID, MT,
NM, NV, OR,
UT, WY
Bird
BS
Eagle, golden
Aquila chrysaetos
AK, AZ, CA,
MT, NV, UT,
WY
Bird
BS
Earthworm, Oregon giant
Driloleirus macfreshi
OR
Invertebrate
BS
Eater, truffle
Cordyceps ophioglossoides
CA
Plant
BS
Eatonella, white
Eatonella nivea
ID, OR
Plant
BS
Egret, snowy
Egretta thula
OR
Bird
BS
Eider, spectacled
Somateria fischeri
AK
Bird
FT
Eider, Steller’s
Polysticta stelleri
AK
Bird
FT
Elfin, hoary
Callophrys polios
OR
Invertebrate
BS
Entoloma, indigo
Entoloma nitidum
CA
Plant
BS
Eriastrum, Brandegee’s
Eriastrum brandegeae
CA
Plant
BS
Eriastrum, Harwood’s
Eriastrum harwoodii
CA
Plant
BS
Eriastrum, Tracy’s
Eriastrum tracyi
CA
Plant
BS
Eriastrum, yellow-flowered
Eriastrum luteum
CA
Plant
BS
Erigeron, white cushion
Erigeron disparipilus
OR
Plant
BS
Erigeron, Yukon
Erigeron yukonensis
AK
Plant
BS
Eriogonum, short- flowered
Eriogonum brachyanthum
OR
Plant
BS
Eulachon, Pacific
Thaleichthys pacificus
OR
Fish
FT
Evax, short-leaved
Hesperevax sparsiflora
CA
Plant
BS
Evening-primrose, Antioch
Dunes
Oenothera deltoides
CA
Plant
FE
Evening-primrose, dwarf
Camissonia pygmaea
OR
Plant
BS
Evening-primrose, Eureka
Valley
Oenothera avita
CA
Plant
FE
Evening-primrose, Hardham’s
Camissonia hardhamiae
CA
Plant
BS
Evening-primrose, Kern River
Camissonia integrifolia
CA
Plant
BS
Evening-primrose, naked¬
stemmed
Camissonia scapoidea
OR
Plant
BS
Evening-primrose, narrowleaf
Oenothera acutissima
CO
Plant
BS
Evening-primrose, obscure
Camissonia andina
MT
Plant
BS
Evening-primrose, Organ
Mountain
Oenothera organensis
NM
Plant
BS
Evening-primrose, pale
Oenothera pallida
MT
Plant
BS
Evening-primrose, Palmer’s
Camissonia palmeri
ID
Plant
BS
Evening-primrose, Saint
Anthony
Oenothera psammophila
ID
Plant
BS
Evening-primrose, San Benito
Camissonia benitensis
CA
Plant
FT
Evening-primrose, slender
Camissonia exilis
AZ, OR
Plant
BS
HI M Vegetation Treatments Three New Herbieides
Final Programmatic FIS
E-2 1
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Evening-primrose, slender-
flowered
Camissonia graciliflora
OR
Plant
BS
Evening-primrose, tufted
Oenothera caespitosa
OR
Plant
BS
Evening-primrose, winged-seed
Camissonia pterosperma
ID
Plant
BS
Evening-primrose, Wolfs
Oenothera wolfii
CA, OR
Plant
BS
Eyed-grass, strict blue
Sisyrinchium montanum
OR
Plant
BS
Fairy fan
Spathularia flavida
CA
Plant
BS
Fairy shrimp, conservancy
Branchinecta conservatio
CA
Invertebrate
FE
Fairy shrimp, longhorn
Branchinecta longiantenna
CA
Invertebrate
FE
Fairy shrimp, riverside
Streptocephalus woottoni
CA
Invertebrate
FE
Fairy shrimp, San Diego
Branchinecta sandiegonensis
CA
Invertebrate
FE
Fairy shrimp, vernal pool
Branchinecta lynchi
CA, OR
Invertebrate
FT
Fairypoppy, white
Meconella oregana
OR
Plant
BS
Falcon, American peregrine
Falco peregrinus anatus
AZ, CO, OR
Bird
BS
Falcon, arctic peregrine
Falco peregrinus tundrius
OR
Bird
BS
Falcon, northern aplomado
Falco femoralis ssp.
Septentrionalis
AZ, NM
Bird
FE/XN
Falcon, Peale’s peregrine
Falco peregrinus
OR
Bird
BS
Falcon, peregrine
Falco peregrinus
ID, MT, NM,
NV, WY
Bird
BS
Falcon, prairie
Falco mexicanus
ID
Bird
BS
False yarrow, Cusick’s
Chaenactis cusickii
AZ, ID
Plant
BS
False-oats, Siberian
Trisetum sihiricum
AK
Plant
BS
Fameflower, spinescent
Talinum spinescens
OR
Plant
BS
Fawn-lily, Coast Range
Erythronium elegans
OR
Plant
BS
Fawn-lily, Howell’s
Erythronium howellii
OR
Plant
BS
Fawn-lily, Scott Mountain
Erythronium citrinum
CA
Plant
BS
Fawn-lily, Tuolumne
Erythronium tuolumnense
CA
Plant
BS
Feathergrass, Porter
Ptilagrostis porteri
CO
Plant
BS
Felwort, marsh
Lomatogonium rotatum
ID, MT
Plant
BS
Fern, Aleutian shield
Polystichum aleuticum
AK
Plant
FE
Fem, bird’s-foot
Pellaea mucronata
OR
Plant
BS
Fern, coffee
Pellaea andromedifolia
OR
Plant
BS
Fem, goldenback
Pentagramma triangularis
ID
Plant
BS
Ferret, black-footed
Mustela nigripes
AZ, CO, MT,
UT, WY
Mammal
FE/XN
Feverfew, Colorado
Parthenium ligulatum
CO, NV
Plant
BS
Fiddleleaf, matted
Nama densum var.
parviflorum
CO
Plant
BS
Fiddleneck, bent-flowered
Amsinckia lunaris
CA
Plant
BS
Fiddleneck, large-flowered
Amsinckia grand i flora
CA
Plant
FE
Fiddleneck, Malheur Valley
Amsinckia carinata
OR
Plant
BS
Fieldslug, evening
Deroceras hesperium
OR
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-22
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Figwort, black-flowered
Scrophularia atrata
CA
Plant
BS
Figwort, Organ Mountain
Scrophularia laevis
NM
Plant
BS
Filaree, round-leaved
California macrophylla
CA
Plant
BS
Fireweed, Oregon
Epilobium oreganum
CA, OR
Plant
BS
Fireweed, Siskiyou
Epilobium siskiyouense
CA
Plant
BS
Fisher
Martes pennanti
CA, MT, OR
Mammal
C
Fishhook cactus, Great Basin
Sclerocactus pubispinus
NV
Plant
BS
Fishhook cactus, Paria Plateau
Sclerocactus sileri
AZ
Plant
BS
Fishhook cactus, Wright
Sclerocactus wrightiae
UT
Plant
FE
Flameflower, Pinos Altos
Talinum humile
NM
Plant
BS
Flannelbush, California
Fremontodendron californica
AZ, CA
Plant
BS
Flannelbush, Mexican
Fremontodendron mexicanum
CA
Plant
FE
Flannelbush, Pine Hill
Fremontodendron
californicum ssp. decumbens
CA
Plant
FE
Flatsedge, Great Plains
Cyperus lupulinus ssp.
lupulinus
OR
Plant
BS
Flatsedge, Schweinitz
Cyperus schweinitzii
MT
Plant
BS
Flatworm
Kenkia rhynchida
OR
Invertebrate
BS
Flax, Brewer’s dwarf
Hesperolinon breweri
CA
Plant
BS
Flax, drymaria-like western
Hesperolinon drymarioides
CA
Plant
BS
Flax, glandular western
Hesperolinon adenophyllum
CA
Plant
BS
Flax, Lake County dwarf
Hesperolinon didymocarpum
CA
Plant
BS
Flax, Napa western
Hesperolinon serpentinum
CA
Plant
BS
Flax, Tehama County western
Hesperolinon tehamense
CA
Plant
BS
Fleabane, broad
Erigeron latus
NV, OR
Plant
BS
Fleabane, buff
Erigeron ochroleucus
MT
Plant
BS
Fleabane, Fish Creek
Erigeron piscaticus
AZ
Plant
BS
Fleabane, gorge
Erigeron oreganus
OR
Plant
BS
Fleabane, Idaho
Erigeron asperugineus
MT
Plant
BS
Fleabane, Lemmon
Erigeron lemmonii
AZ
Plant
C
Fleabane, linearleaf
Erigeron linearis
MT
Plant
BS
Fleabane, Muir’s
Erigeron muirii
AK
Plant
BS
Fleabane, Salish
Erigeron salishii
OR
Plant
BS
Fleabane, sheep
Erigeron ovinus
CA, NV
Plant
BS
Fleabane, Zuni
Erigeron rhizomatus
AZ, NM
Plant
FT
Fleece, golden
Ericameria arborescens
OR
Plant
BS
Flicker, gilded
Colaptes chrysoides
AZ, CA
Bird
BS
Floater, California
Anodonta calif orniensis
ID, NV
Invertegrate
BS
Fly, Delhi Sands flower-loving
Rhaphiomidas terminatus
CA
Invertebrate
FE
Flycatcher, ash-throated
Myiarchus cinerascens
OR
Bird
BS
Flycatcher, cordilleran
Empidonax occidentalis
ID
Bird
BS
Flycatcher, dusky
Empidonax oberholseri
ID
Bird
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-23
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Flycatcher, gray
Empidonax wrightii
CA, OR
Bird
BS
Flycatcher, Hammond’s
Empidonax hammondii
ID, OR
Bird
BS
Flycatcher, olive-sided
Contopus borealis
AK, ID, NM,
OR, WY
Bird
BS
Flycatcher, southwestern willow
Empidonax traillii extimus
AZ, CA, CO,
NM, NV, UT
Bird
FE
Flycatcher, willow
Empidonax traillii
ID
Bird
BS
Forget-me-not, pale alpine
Eritrichium nanum
OR
Plant
BS
Four-o’ clock, Macfarlane’s
Mirabilis macfarlanei
ID, OR
Plant
FT
Fox, kit
Vulpes velox macrotis
CO, ID, OR,
UT
Mammal
BS
Fox, San Joaquin kit
Vulpes macrotis mutica
CA
Mammal
FE
Fox, San Miguel Island
Urocyon littoralis littoralis
CA
Mammal
FE
Fox, Santa Catalina Island
Urocyon littoralis catalinae
CA
Mammal
FE
Fox, Santa Cruz Island
Urocyon littoralis
santacruzae
CA
Mammal
FE
Fox, Santa Rosa Island
Urocyon littoralis santarosae
CA
Mammal
FE
Fox, swift
Vulpes velox
CO, MT, WY
Mammal
BS
Foxtail cactus, Alverson’s
Coryphantha vivpara var.
alversonii {=Escobaria
vivipara)
CA
Plant
BS
Frasera, tufted
Frasera paniculata
CO
Plant
BS
Fringepod, Santa Cruz Island
Thysanocarpus conchuliferus
CA
Plant
FE
Fritillary, butte
Fritillaria eastwoodiae
CA
Invertebrate
BS
Fritillary, coronis
Speyeria coronis
OR
Invertebrate
BS
Fritillary, Gentner’s
Fritillaria gentneri
CA, OR
Plant
FE
Fritillary, Great Basin
Speyeria egleis
OR
Invertebrate
BS
Fritillary, meadow
Boloria bellona
OR
Invertebrate
BS
Fritillary, Ojai
Fritillaria ojaiensis
CA
Plant
BS
Fritillary, San Benito
Fritillaria viridea
CA
Plant
BS
Fritillary, silver-bordered
Boloria selene
OR
Invertebrate
BS
Fritillary, talus
Fritillaria falcata
CA
Plant
BS
Frog, California red-legged
Rana draytonii
CA
Amphibian
FT
Frog, Chiricahua leopard
Rana chiricahuensis
AZ, NM
Amphibian
FT
Frog, Columbia spotted
Rana luteiventris
ID, MT, NV,
OR, UT, WY
Amphibian
C
Frog, foothill yellow-legged
Rana boylei
CA, OR
Amphibian
BS
Frog, inland tailed
Ascaphus montanus
OR
Amphibian
BS
Frog, lowland leopard
Lithobates yavapaiensis
AZ, CA
Amphibian
BS
Frog, mountain yellow-legged
Rana muscosa
CA, NV
Amphibian
FE
Frog, northern cricket
Acris crepitans
CA, CO, NM,
UT
Amphibian
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-24
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Frog, northern leopard
Rana pipiens
AZ, CO, ID,
MT, NV, OR,
WY
Amphibian
BS
Frog, Oregon spotted
Rana pretiosa
CA, OR
Amphibian
FT
Frog, plains leopard
Rana blairi
AZ, CO
Amphibian
BS
Frog, relict leopard
Lithobates onca
AZ, NV
Amphibian
C
Frog, San Sebastian leopard
Rana yavapaiensis
CA, NM, UT
Amphibian
BS
Frog, Sierra Nevada yellow-
legged
Rana sierrae
CA
Amphibian
FE
Frog, tailed
Ascaphus truei
MT
Amphibian
BS
Frog, wood
Rana syvatica
MT
Amphibian
BS
Fumewort, cold-water
Corydalis aquae-gelidae
OR
Plant
BS
Fungi
Albatrellus avellaneus
OR
Fungi
BS
Fungi
Alpova alexsmithii
OR
Fungi
BS
Fungi
Arcangeliella camphorata
OR
Fungi
BS
Fungi
Boletus pulcherrimus
OR
Fungi
BS
Fungi
Bridgeoporus nobilissimus
OR
Fungi
BS
Fungi
Chamonixia caespitosa
OR
Plant
BS
Fungi
Cortinarius barlowensis
OR
Fungi
BS
Fungi
Cudonia monticola
OR
Fungi
BS
Fungi
Cystangium idahoensis
OR
Fungi
BS
Fungi
Destuntzia rubra
OR
Fungi
BS
Fungi
Gastroboletus imbellus
OR
Fungi
BS
Fungi
Gastroboletus vividus
OR
Fungi
BS
Fungi
Gomphus kauffmanii
OR
Fungi
BS
Fungi
Gymnomyces fragrans
OR
Fungi
BS
Fungi
Gymnomyces nondistincta
OR
Fungi
BS
Fungi
Helvella crassitunicata
OR
Fungi
BS
Fungi
Mythicomyces corneipes
OR
Fungi
BS
Fungi
Octaviania macrospora
OR
Fungi
BS
Fungi
Otidea smithii
OR
Fungi
BS
Fungi
Phaeocollybia dissiliens
OR
Fungi
BS
Fungi
Phaeocollybia gregaria
OR
Fungi
BS
Fungi
Phaeocollybia oregonensis
OR
Fungi
BS
Fungi
Phaeocollybia pseudofestiva
CA, OR
Fungi
BS
Fungi
Phaeocollybia scatesiae
CA, OR
Fungi
BS
Fungi
Phaeocollybia sipei
OR
Fungi
BS
Fungi
Phaeocollybia spadicea
CA, OR
Fungi
BS
Fungi
Pseudorhizina californica
OR
Fungi
BS
Fungi
Ramaria gelatiniaurantia
OR
Fungi
BS
Fungi
Ramaria rubella
OR
Fungi
BS
Fungi
Ramaria spinulosa
OR
Fungi
BS
Fungi
R h izopogon chamal eon ti n us
OR
Fungi
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-25
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Fungi
Rhizopogon ellipsosporus
OR
Fungi
BS
Fungi
Rhizopogon exiguus
OR
Fungi
BS
Fungi
Rhizopogon inquinatus
OR
Fungi
BS
Fungi
Stagnicola perplexa
OR
Fungi
BS
Fungi
Thaxterogaster pavelekii
OR
Fungi
BS
Fungus, stalked orange peel
Sowerbyella rhenana
CA, OR
Fungi
BS
Fuzzwort, pacific
Ptilidium californicum
CA
Plant
BS
Gambusia, Pecos
Gambusia nobilis
NM
Fish
FE
Gar, shortnose
Lepisosteus platostomus
MT
Fish
BS
Gecko, barefoot banded
Coleonyx switaki
CA
Reptile
BS
Gecko, Utah banded
Coleonyx variegates
UT
Reptile
BS
Gecko, western banded
Coleonyx variegatus
UT
Reptile
BS
Gentian, Cathedral Bluff dwarf
Gentianella tortuosa
CO
Plant
BS
Gentian, elegant
Gentiana plurisetosa
OR
Plant
BS
Gentian, glaucous
Gentiana glauca
OR
Plant
BS
Gentian, hiker’s
Gentianopsis simplex
MT
Plant
BS
Gentian, Mendocino
Gentiana setigera
CA, OR
Plant
BS
Gentian, moss
Gentiana prostrata
OR
Plant
BS
Gentian, Newberry’s
Gentiana newberryi
OR
Plant
BS
Gentian, sheared
Gentianopsis detonsa
AK
Plant
BS
Gentian, slender
Gentianella tenella
OR
Plant
BS
Gentian, Sunnyside green
Frasera gypsicola
NV
Plant
BS
Gentian, swamp
Gentiana douglasiana
OR
Plant
BS
Gila monster, banded
Heloderma suspectum
AZ, NV, UT
Reptile
BS
Gilia, Aztec
Gilia formosa
NM
Plant
BS
Gilia, dark-eyed
Gilia millefoliata
CA, CO, OR
Plant
BS
Gilia, Hoffmann’s slender-
flowered
Gilia tenui flora ssp.
hoffmannii
CA
Plant
FE
Gilia, Little San Bernardino
Mtns.
Linanthus maculatus
CA
Plant
BS
Gilia, Monterey
Gilia tenuiflora ssp. arenaria
CA
Plant
FE
Gilia, narrow-stem
Gilia stenothyrsa
CO
Plant
BS
Gilia, Rabbit Valley
Gilia caespitosa
UT
Plant
C
Gilia, sand
Gilia tenuiflora
CO, CA, NM
Plant
FE
Gilia, spreading
Ipomopsis polycladon
ID
Plant
BS
Glasswort, red
Salicornia rubra
ID
Plant
BS
Globeberry, Texas
Ibervillea tenuisecta
AZ
Plant
BS
Globeberry, Tumamoc
Tumamoca macdougalii
AZ
Plant
BS
Globeflower, American
Trollius laxus
OR
Plant
BS
Globemallow, Baker’s
Iliamna bakeri
OR
Plant
BS
Globemallow, California
Iliamna latibracteata
OR
Plant
BS
Globemallow, longsepal
Iliamna longisepala
OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-26
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Globemallow, Railroad Valley
Sphaeralcea caesoutisa
NV
Plant
BS
Globemallow, white-stemmed
Sphaeralcea munroana
MT
Plant
BS
Glossopetalon, pungent
Glossopetalon pungens
CA
Plant
BS
Gnatcatcher, blue-gray
Polioptila caerulea
MT
Bird
BS
Gnatcatcher, coastal California
Polioptila californica
californica
CA
Bird
FT
Goat, mountain
Oreamnos americanus
OR
Mammal
BS
Goatsfoot, greening
Albatrellus ellisii
CA
Fungi
BS
Goby, tidewater
Eucyclogobius newberryi
CA
Fish
FE
Godwit, marbled
Limosa fedoa
MT
Bird
BS
Gold, July
Dedeckera eurekensis
CA
Plant
BS
Goldenaster, Oregon
Heterotheca oregona
OR
Plant
BS
Goldenaster, Shevock’s hairy
Heterotheca shevockii
CA
Plant
BS
Goldenbush, Antelope Canyon
Ericameria cervina
NV
Plant
BS
Goldenbush, Eastwood’s
Ericameria fasciculata
CA
Plant
BS
Goldenbush, Gilman’s
Ericameria gilmanii
CA
Plant
BS
Goldenbush, Palmer’s
Ericameria palmeri
CA
Plant
BS
Goldenbush, whitestem
Ericameria discoidea
WY
Plant
BS
Golden-carpet, northern
Chrysosplenium tetrandrum
OR
Plant
BS
Goldeneye, Barrow’s
Bucephala islandica
CO, ID
Bird
BS
Goldeneye, showy
Heliomeris multiflora
MT
Plant
BS
Goldenhead, Lone Mountain
Tonestus graniticus
NV
Plant
BS
Goldenrod, few-flowered
Solidago velutina
MT
Plant
BS
Goldenstar, San Diego
Muilla clevelandii
CA
Plant
BS
Goldenweed, beartooth large-
flowered
Pyrrocoma carthamoides
MT
Plant
BS
Goldenweed, bugleg
Pyrrocoma insecticruris
ID, OR
Plant
BS
Goldenweed, Palouse
Pyrrocoma liatriformis
ID, OR
Plant
BS
Goldenweed, Snake River
Pyrrocoma radiata
ID, OR
Plant
BS
Goldenweed, sticky
Pyrrocoma hirta
ID, OR
Plant
BS
Goldfields, Burke’s
Lasthenia burkei
CA
Plant
FE
Goldfields, Contra Costa
Lasthenia conjugens
CA, UT
Plant
FE
Goldfields, Coulter’s
Lasthenia glabrata
CA
Plant
BS
Goldfields, large-flowered
Lasthenia ornduffii
OR
Plant
BS
Goldfields, smooth
Lasthenia glaberrima
OR
Plant
BS
Goldfinch, lesser
Carduelis psaltria
OR
Bird
BS
Goldflower, Cooper’s
Hymenoxys lemmonii
OR
Plant
BS
Goldthread, spleenwort-leaved
Coptis aspleniifolia
OR
Plant
BS
Goldthread, three-leaf
Coptis trifolia
OR
Plant
BS
Goose, Aleutian Canada
Branta canadensis
leucopareia
CA, OR
Bird
BS
Goose, dusky Canada
Branta canadensis
AK, OR
Bird
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-27
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Goose, emperor
Chen canagica
AK
Bird
BS
Gooseberry, Idaho
Ribes oxyacanthoides
OR
Plant
BS
Gooseberry, Sequoia
Ribes tularense
CA
Plant
BS
Gooseberry, straggly
Ribes divaricatum
OR
Plant
BS
Gopher, desert pocket
Geomys bursarius
NM
Mammal
BS
Gopher, fish spring pocket
Thomomys umbrinus
abstrusus
NV
Mammal
BS
Gopher, Guadalupe Southern
pocket
Thomomys umbrinus
guadalupensis
NM
Mammal
BS
Gopher, Idaho pocket
Thomomys idahoensis
WY
Mammal
BS
Gopher, San Antonio pocket
Thomomys umbrinus curtatus
NV
Mammal
BS
Gopher, southern pocket
Thomomys umbrinus ssp.
NM
Mammal
BS
Gopher, western pocket
Thomomys mazama ssp.
OR
Mammal
BS
Gopher, Wyoming pocket
Thomomys clusius
WY
Mammal
BS
Goshawk, northern
Accipiter gentilis
A Z, CA, CO,
ID, MT, NV,
OR, UT, WY
Bird
BS
Gramma, blue
Bouteloua gracilis
ID
Plant
BS
Grape-fern, lance-leaved
Botrychium lanceolatum
ID
Plant
BS
Grape-fem, mountain
Botrychium montanum
OR
Plant
BS
Grape-fern, pumice
Botrychium pumicola
OR
Plant
BS
Grappling hook, Palmer’s
Harpagonella palmeri
CA
Plant
BS
Grass
Poaceae
CA
Plant
BS
Grass bug, american acetropis
Acetropis americana
OR
Invertebrate
BS
Grass, Blasdale’s bent
Agrostis blasdalei
CA
Plant
BS
Grass, blue-eyed
Sisyrinchium septentrionale
OR
Plant
BS
Grass, Colusa
Neostapfia colusana
CA
Plant
FT
Grass, Diablo Canyon blue
Poa diaboli
CA
Plant
BS
Grass, Eureka Dune
Swallenia alexandrae
CA
Plant
FE
Grass, Hitchcock’s blue-eyed
Sisyrinchium hitchcockii
OR
Plant
BS
Grass, Hoover’s bent
Agrostis hooveri
CA
Plant
BS
Grass, Hoover’s semaphore
Pleuropogon hooverianus
CA
Plant
BS
Grass, Scribner’s
Scribneria bolanderi
OR
Plant
BS
Grass, Scribner’s panic
Dichanthelium oligosanthes
MT
Plant
BS
Grass, Solano
Tuctoria mucronata
CA
Plant
FE
Grass-fern
Asplenium septentrionale
OR
Plant
BS
Grasshopper, Idaho pointheaded
Acrolophitus punchellus
ID
Invertebrate
BS
Grasshopper, Siskiyou short-
homed
Chloealtis aspasma
OR
Invertebrate
BS
Grasshopper, Zayante band¬
winged
Trimerotropis infantilis
CA
Invertebrate
FE
Grass-of-pamassus, Kotzebue’s
Parnassia kotzebuei
OR
Plant
BS
Grass-of-pamassus, northern
Parnassia palustris
OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-28
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Grayling, arctic
Thy m alius arcticus
MT
Fish
C
Greasebush, rough dwarf
Glossopetalon pungens var.
pungens
NV
Plant
BS
Greasebush, smooth dwarf
Glossopetalon pungens var.
glabrum
NV
Plant
BS
Grebe, Clark’s
Aechmophorus clarkii
OR
Bird
BS
Grebe, eared
Podiceps nigricollis
OR
Bird
BS
Grebe, homed
Podiceps auritus
OR
Bird
BS
Grebe, red-necked
Podiceps grisegena
ID, OR
Bird
BS
Greenbriar, English Peak
Smilax jamesii
CA
Plant
BS
Greenthread, Green River
Thelesperma caespitosum
WY
Plant
BS
Greenthread, Uinta
Thelesperma pubescens
CA, NM, WY
Plant
BS
Grosbeak, blue
Guiraca caerulea
UT
Bird
BS
Groundsel, San Francisco Peaks
Senecio franciscanus
AZ
Plant
FT
Groundstar, Santa Ynez
Ancistrocarphus keilii
CA
Plant
BS
Grouse, Columbian sharp-tailed
Tympanuchus phasianellus
CA, CO, ID,
MT, OR, UT,
WY
Bird
BS
Gull, Franklin’s
Larus pipixcan
MT, OR
Bird
BS
Gumplant, Ash Meadows
Grindelia fraxino-pratensis
CA, ID, NV
Plant
FT
Gumweed, Howell’s
Grindelia howellii
ID, MT
Plant
BS
Gymnopilus, blue-green
Gymnopilus punctifolius
CA
Plant
BS
Gyrfalcon
Falco rusticolus
OR
Bird
BS
Hairstreak, Barry’s
Callophrys gryneus
OR
Invertebrate
BS
Hairstreak, Johnson’s
Callophrys johnsoni
OR
Invertebrate
BS
Halimolobos, puzzling
Halimolobos perplexa
ID
Invertebrate
BS
Hare, Alaskan
Lepus othus
AK
Mammal
BS
Harebell, Alaska
Campanula lasiocarpa
OR
Plant
BS
Harebell, Castle Crags
Campanula shetleri
CA
Plant
BS
Harebell, chaparral
Campanula exigua
CA
Plant
BS
Harebell, Sharsmith’s
Campanula sharsmithiae
CA
Plant
BS
Harebell, swamp
Campanula californica
CA
Plant
BS
Harmonia, Hall’s
Harmonia hallii
CA
Plant
BS
Harmonia, Nile’s
Harmonia doris-nilesiae
CA
Plant
BS
Harrier, northern
Circus cyaneus
ID, OR
Bird
BS
Hawk, ferruginous
Buteo regalis
AZ, CO, ID,
MT, NV, NM,
OR, UT, WY
Bird
BS
Hawk, northern gray
Buteo nitidus
AZ, ID, MT,
WY
Bird
BS
Hawk, Swainson’s
Buteo swainsoni
CA, MT, NV,
UT
Bird
BS
Hawksbeard, Idaho
Crepis bakeri
ID
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-29
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Hawkweed, shaggy
Hieracium horridum
OR
Plant
BS
Hazardia, Orcutt’s
Hazardia orcuttii
CA
Plant
C
Hearts, three
Tricardia watsonii
ID
Plant
BS
Hedgehog cactus, Arizona
Echinocereus triglochidiatus
var. arizonicus
AZ
Plant
FE
Hedgehog cactus, Howe’s
Echinocereus engelmannii
CA
Plant
BS
Hedgehog cactus, Kuenzler’s
Echinocereus fendleri var.
kuenzleri
NM
Plant
FE
Hedgehog cactus, Simpson’s
Pediocactus simpsonii
ID
Plant
BS
Hedgehog, violet
Sarcodon fuscoindicus
CA
Fungi
BS
Hedge-hyssop, Boggs Lake
Gratiola heterosepala
CA, OR
Plant
BS
Heliotrope, salt
Heliotropium curassavicum
OR
Plant
BS
Helodium, Blandow’s
Helodium hlandowii
ID, OR
Plant
BS
Hendersons, ricegrass
Achnatherum hendersonii
OR
Plant
BS
Heron, black-crowned night
Nycticorax nycticorax
MT
Bird
BS
Hesperian (snail). Sisters
Hochbergellus hirsutus
OR
Invertebrate
BS
Hesperian, Siskiyou
Vespericola sierranus
OR
Invertebrate
BS
Hookless cactus, Uinta Basin
Sclerocactus wetlandicus
UT
Plant
FT
Hopsage, spiny
Grayia spinosa
MT
Plant
BS
Horkelia, Henderson’s
Horkelia hendersonii
CA
Plant
BS
Horkelia, Parry’s
Horkelia parryi
CA
Plant
BS
Horkelia, shaggy
Horkelia conges ta
AZ, OR
Plant
BS
Horkelia, thin-lobed
Horkelia tenuiloba
CA
Plant
BS
Horkelia, three-toothed
Horkelia tridentata
OR
Plant
BS
Homshell, Texas
Popenaias popei
NM
Invertebrate
C
Horsehair, yellow-twist
Bryoria tortuosa
CA
Plant
BS
Horse-mint, Cusick’s
Agastache cusickii
MT, OR
Plant
BS
Horse-nettle, Parish’s
Solanum parishii
OR
Plant
BS
Howellia, water
Howellia aquatilis
CA, ID, MT,
OR
Plant
FT
Hulsea, Inyo
Hulsea vestita
CA
Plant
BS
Hummingbird, Calliope
Stellula calliope
ID
Bird
BS
Hummingbird, rufous
Selaphorus rufus
ID
Bird
BS
Hutchensia, prostrate
Hutchinsia procumbens
MT
Plant
BS
Ibis, white-faced
Plegadis chihi
AZ, CO, MT,
WY
Bird
BS
Iguana, desert
Dipsosaurus dorsalis
UT
Reptile
BS
Indian paintbrush, San Clemente
Island
Castilleja grisea
CA
Plant
FE
Ipomopsis, ballhead
Ipomopsis congesta
MT
Plant
BS
Ipomopsis, Holy Ghost
Ipomopsis sancti-spiritus
NM
Plant
FE
Iris, Gorman’s
Iris tenax
OR
Plant
BS
Iris, Munz’s
Iris munzii
CA
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-30
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Isopod, socorro
Thermosphaeroma
thermophilus
NM
Invertebrate
FE
Ivesia, alkali
Ivesia kingii var. kingii
CA, NV
Plant
BS
Ivesia, Ash Creek
Ivesia paniculata
CA, OR
Plant
BS
Ivesia, Ash Meadows
Ivesia kingii var. eremica
CA, NV
Plant
FT
Ivesia, Castle Crags
Ivesia longibracteata
CA
Plant
BS
Ivesia, grimy
Ivesia rhypara ssp. rhypara
NV, OR
Plant
BS
Ivesia, Jaeger’s
Ivesia jaegeri
CA, NV
Plant
BS
Ivesia, Kingston Mountains
Ivesia patellifera
CA
Plant
BS
Ivesia, Pickering’s
Ivesia pickeringii
CA
Plant
BS
Ivesia, Pine Nut Mountains
Ivesia pityocharis
NV
Plant
BS
Ivesia, Plumas
Ivesia sericoleuca
CA
Plant
BS
Ivesia, Shelly’s
Ivesia rhypara ssp. shellyi
OR
Plant
BS
Ivesia, Shockley’s
Ivesia shockleyi
OR
Plant
BS
Ivesia, Webber
Ivesia webberi
CA, NV
Plant
FT
Jackrabbit, black-tailed
Lepus californicus
OR
Mammal
BS
Jackrabbit, white-tailed
Lepus townsendii
OR
Mammal
BS
Jaguar
Panthera onca
AZ, NM
Mammal
FE
Jaguarundi
Puma yaguarondi
AZ
Mammal
FE
Jay, pinyon
Gymnorhinus cyanocephalus
AZ, NV
Bird
BS
Jewelflower, California
Caulanthus californicus
CA
Plant
FE
Jewelflower, common
Streptanthus glandulosus
OR
Plant
BS
Jewelflower, Dorr’s Cabin
Streptanthus morrisonii ssp.
hirtiflorus
CA
Plant
BS
Jewelflower, early
Streptanthus vernal is
CA
Plant
BS
Jewelflower, Freed’s
Streptanthus brachiatus
CA
Plant
BS
Jewelflower, Hoffman’s
Streptanthus glandulosus var.
hoffmanii
CA
Plant
BS
Jewelflower, Kruckeberg’s
Streptanthus morrisonii ssp.
kruckebergii
CA
Plant
BS
Jewelflower, Lemmon’s
Caulanthus coulteri
CA
Plant
BS
Jewelflower, Masonic Mountain
Streptanthus oliganthus
CA, NV
Plant
BS
Jewelflower, Metcalf Canyon
Streptanthus albidus ssp.
albidus
CA
Plant
FE
Jewelflower, Morrison’s
Streptanthus morrisonii ssp.
morrisonii
CA
Plant
BS
Jewelflower, Mount Hamilton
Streptanthus callistus
CA
Plant
BS
Jewelflower, Piute Mountains
Streptanthus cordatus
CA
Plant
BS
Jewelflower, Santa Barbara
Caulanthus amplexicaulis
CA
Plant
BS
Jewelflower, Socrates Mine
Streptanthus brachiatus
CA
Plant
BS
Jewelflower, Three Peaks
Streptanthus morrisonii ssp.
elatus
CA
Plant
BS
Jewelflower, Tiburon
Streptanthus niger
CA
Plant
FE
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-3 1
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Juga (snail), barren
Juga hemphilli hemphilli
OR
Invertebrate
BS
Juga (snail), bulb
Juga bulbosa
OR
Invertebrate
BS
Juga (snail), Dalles
Juga hemphilli dallesensis
OR
Invertebrate
BS
Juga (snail), opal springs
Juga sp.
OR
Invertebrate
BS
Juga, purple-lipped (Deschutes)
Juga hemphilli maupinensis
OR
Invertebrate
BS
Jumping-slug, malone
Hemphillia malone
OR
Invertebrate
BS
Jumping-slug, warty
Hemphillia glandulosa
OR
Invertebrate
BS
June beetle, Casey’s
Dinacoma caseyi
CA
Invertebrate
FP
Junegrass, Oriental
Koeleria asiatica
AK
Plant
BS
Kalmiopsis, fragrant (Douglas
Co. Population)
Kalmiopsis fragrans
OR
Plant
BS
Kangaroo rat, banner-tailed
Dipodomys spectabilis
AZ
Mammal
BS
Kangaroo rat, chisel-toothed
Dipodomys mi crops
UT
Mammal
BS
Kangaroo rat, desert
Dipodomys deserti
UT
Mammal
BS
Kangaroo rat, Fresno
Dipodomys nitratoides exilis
CA
Mammal
FE
Kangaroo rat, giant
Dipodomys ingens
CA
Mammal
FE
Kangaroo rat, House Rock
Valley chisel-toothed
Dipodomys microps
AZ
Mammal
BS
Kangaroo rat, Marysville
California
Dipodomys californicus
eximius
CA
Mammal
BS
Kangaroo rat, Merriam’s
Dipodomys merriami
UT
Mammal
BS
Kangaroo rat, Morro Bay
Dipodomys heermanni
morroensis
CA
Mammal
FE
Kangaroo rat, San Bernardino
Merriam’s
Dipodomys merriami parvus
CA
Mammal
FE
Kangaroo rat, short-nosed
Dipodomys nitratoides
brevinasus
CA, WY
Mammal
BS
Kangaroo rat, Stephens’
Dipodomys stephensi
CA, UT
Mammal
FE
Kangaroo rat, Tipton
Dipodomys nitratoides
nitratoides
CA
Mammal
FE
Kentrophyta, bastard
Astragalus tegetarioides
OR
Plant
BS
Kingsnake, California mountain
Lampropeltis zonata
CA, OR
Reptile
BS
Kingsnake, common
Lampropeltis getula
CO
Reptile
BS
Kingsnake, Sonoran mountain
Lampropeltis pyromelana
NV
Reptile
BS
Kingsnake, St. Helena mountain
Lampropeltis zonata zonata
CA
Reptile
BS
Kingsnake, Utah mountain
Lampropeltis pyromelana
infralabialis
UT
Reptile
BS
Kite, white-tailed
Elanus leucurus
CA, OR
Bird
BS
Kittenstails, featherleaf
Synthyris pinnatifida
OR
Plant
BS
Knotweed, Austin’s
Polygonum douglasii
MT
Plant
BS
Knotweed, Modoc County
Polygonum polygaloides
CA
Plant
BS
Kobresia, Bellard’s
Kobresia bellardii
OR
Plant
BS
Kruhsea
Streptopus streptopoides
OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-32
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Lacewing, cheese-weed moth
Oliarces clara
AZ
Invertebrate
BS
Ladies-tresses, Canelo Hills
Spiranthes delitescens
AZ
Plant
FE
Ladies-tresses, Ute
Spiranthes diluvialis
CO, ID, MT,
NV, OR, UT,
WY
Plant
FT
Ladies-tresses, western
Spiranthes porrifolia
ID, OR
Plant
BS
Lady’s-slipper, clustered
Cypripedium fasciculatum
CA, ID, OR
Plant
BS
Lady’s-slipper, mountain
Cypripedium montanum
CA
Plant
BS
Lady’s-slipper, small yellow
Cypripedium parviflorum
ID, OR
Plant
BS
Lady’s-slipper, yellow
Cypripedium alpinum
OR
Plant
BS
Lamprey, Alaskan brook
Lampetra alaskensis
AK
Fish
BS
Lamprey, Goose Lake
Lampetra tridentata
CA, OR
Fish
BS
Lamprey, Miller Lake
Lampetra minima
OR
Fish
BS
Lamprey, Pacific
Lampetra tridentata
CA, ID
Fish
BS
Lamprey, river
Lampetra ayresi
OR
Fish
BS
Lancetooth, hooded
Ancotrema voyanum
CA
Invertebrate
BS
Landsnail, Hatchita Grande
wood
Ashmunella hebardi
OR
Invertebrate
BS
Lanx (snail), rotund
Lanx subrotundata
OR
Invertebrate
BS
Lanx (snail), scale
Lanx klamathensis
OR
Invertebrate
BS
Laphamia, Inyo
Perityle inyoensis
CO, CA
Plant
BS
Lark, streaked horned
Eremophila alpestris strigata
OR
Bird
FT
Larkspur, Baker’s
Delphinium bakeri
CA
Plant
FE
Larkspur, Cuyamaca
Delphinium hesperium
CA
Plant
BS
Larkspur, dune
Delphinium parryi
CA
Plant
BS
Larkspur, flathead
Delphinium bicolor
OR
Plant
BS
Larkspur, Kern County
Delphinium purpusii
CA
Plant
BS
Larkspur, Nutall’s
Delphinium nuttallii
OR
Plant
BS
Larkspur, peacock
Delphinium pavonaceum
OR
Plant
BS
Larkspur, recurved
Delphinium recurvatum
CA
Plant
BS
Larkspur, red
Delphinium nudicaule
OR
Plant
BS
Larkspur, San Clemente Island
Delphinium variegatum
CA
Plant
FE
Larkspur, umbrella
Delphinium umbraculorum
CA
Plant
BS
Larkspur, Wenatchee
Delphinium viridescens
OR
Plant
BS
Larkspur, White Rock
Delphinium leucophaeum
OR
Plant
BS
Larkspur, Willamette Valley
Delphinium oreganum
OR
Plant
BS
Larkspur, yellow
Delphinium luteum
CA
Plant
FE
Layia, beach
Layia carnosa
CA
Plant
FE
Layia, Colusa
Layia septentrionalis
CA
Plant
BS
Layia, Comanche Point
Layia leucopappa
CA
Plant
BS
Layia, Jones’s
Layia jonesii
CA
Plant
BS
Layia, pale-yellow
Layia heterotricha
CA
Plant
BS
Legenere
Legenere limosa
CA
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-33
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Lemming, northern bog
Synaptomys borealis
MT
Mammal
BS
Lessingia, San Francisco
Lessingia germanorum
CA
Plant
FE
Lewisia, Cantelow’s
Lewisia cantelovii
CA, OR
Plant
BS
Lewisia, Columbia
Lewisia Columbiana
OR
Plant
BS
Lewisia, Congdon’s
Lewisia congdonii
CA
Plant
BS
Lewisia, Heckner’s
Lewisia cotyledon
CA
Plant
BS
Lewisia, Lee’s
Lewisia leana
OR
Plant
BS
Lewisia, Purdy’s
Lewisia cotyledon
OR
Plant
BS
Lewisia, Stebbin’s
Lewisia stebbinsii
CA
Plant
BS
Lichen
Bryoria subcana
OR
Plant
BS
Lichen
Calicium adspersum
OR
Plant
BS
Lichen
Chaenotheca subroscida
OR
Plant
BS
Lichen
Dermatocarpon
meiophyllizum
OR
Plant
BS
Lichen
Erioderma sorediatum
OR
Plant
BS
Lichen
Heterodermia leucomela
OR
Plant
BS
Lichen
Heterodermia sitchensis
OR
Plant
BS
Lichen
Hypogymnia duplicata
OR
Plant
BS
Lichen
Hypotrachyna revoluta
OR
Plant
BS
Lichen
Leioderma sorediatum
OR
Plant
BS
Lichen
Leptogium burnetiae
OR
Plant
BS
Lichen
Leptogium cyanescens
OR
Plant
BS
Lichen
Microcalicium arenarium
OR
Plant
BS
Lichen
Pilophorus nigricaulis
OR
Plant
BS
Lichen
Pseudocyphellaria mallota
OR
Plant
BS
Lichen
Stereocaulon spathuliferum
OR
Plant
BS
Lichen
Tholurna dissimilis
OR
Plant
BS
Lichen
Usnea nidulans
OR
Plant
BS
Lichen, Anderegg’s reindeer
Cladonia andereggii
ID
Plant
BS
Lichen, ball-bearing
Sphaerophorus globosus
ID
Plant
BS
Lichen, dot
Physcia semipinnata
ID, OR
Plant
BS
Lichen, earth
Catapyrenium congestum
ID
Plant
BS
Lichen, horsehair
Bryoria pseudocapillaris
CA, OR
Plant
BS
Lichen, Idaho range
Xanthoparmelia idahoensis
ID
Plant
BS
Lichen, long beard
Usnea longissima
CA
Plant
BS
Lichen, nail
Pilophorus acicularis
ID
Plant
BS
Lichen, orangebush
Teloschistes flavicans
CA, OR
Plant
BS
Lichen, powdery fog
Niebla cephalota
CA, OR
Plant
BS
Lichen, reindeer
Cladonia luteoalba
ID
Plant
BS
Lichen, scurfy jelly
Collema furfuraceum
ID
Plant
BS
Lichen, short-spored jelly
Collema curtisporum
ID
Plant
BS
Lichen, skin
Dermatocarpon lorenzianum
ID
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-34
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Lichen, stream stippleback
Dermatocarpon luridum
NV
Plant
BS
Lichen, transcending reindeer
Cladonia transcendens
ID
Plant
BS
Lichen, tube
Hypogymnia apinnata
ID
Plant
BS
Lichen, white-dot
Pseudocyphellaria anthraspis
ID
Plant
BS
Lichen, worm
Thamnolia vermicularis
ID
Plant
BS
Lichen, wovenspore
Texosporium sancti-jacobi
ID, OR
Plant
BS
Lily, adobe
Fritillaria pluriflora
CA
Plant
BS
Lily, black
Fritillaria camschatcensis
OR
Plant
BS
Lily, blue sand
Triteleiopsis palmeri
AZ
Plant
BS
Lily, western
Lilium occidentale
CA, OR
Plant
FE
Limpet, Banbury Springs
Lanx sp.
CA, ID
Invertebrate
FE
Linanthus
Linanthus sp.
CA
Plant
BS
Linanthus, Baker’s
Linanthus bolanderi
OR
Plant
BS
Linanthus, Mount Tedoc
Linanthus nuttallii var.
howellii
CA
Plant
BS
Linanthus, Orcutt’s
Linanthus orcuttii
CA
Plant
BS
Lip-fern, coastal
Cheilanthes intertexta
OR
Plant
BS
Lip-fern, Coville’s
Cheilanthes covillei
OR
Plant
BS
Lip-fern, Fee’s
Cheilanthes feei
OR
Plant
BS
Lipocarpha, aristulate
Lipocarpha aristulata
OR
Plant
BS
Liveforever, Laguna Beach
Dudleya stolonifera
CA
Plant
FT
Liveforever, Santa Barbara
Island
Dudleya traskiae
CA
Plant
FE
Liverwort
Barbilophozia lycopodioides
OR
Plant
BS
Liverwort
Calypogeia sphagnicola
OR
Plant
BS
Liverwort
Chiloscyphus gemmiparus
OR
Plant
BS
Liverwort
Cryptomitrium tenerum
OR
Plant
BS
Liverwort
Diplophyllum plicatum
OR
Plant
BS
Liverwort
Gymnomitrion concinnatum
OR
Plant
BS
Liverwort
Herbertus aduncus
OR
Plant
BS
Liverwort
Jamsoniella autumnalis
OR
Plant
BS
Liverwort
Jungermannia polaris
OR
Plant
BS
Liverwort
Kurzia makinoana
OR
Plant
BS
Liverwort
Lophozia laxa
OR
Plant
BS
Liverwort
Metzgeria violacea
OR
Plant
BS
Liverwort
Peltolepis quadrata
OR
Plant
BS
Liverwort
Porella bolanderi
OR
Plant
BS
Liverwort
Ptilidium pulcherrimum
OR
Plant
BS
Liverwort
Sphaerocarpos hians
OR
Plant
BS
Liverwort
Tritomaria exsectiformis
OR
Plant
BS
Lizard, blunt-nosed leopard
Gambelia silus (=sila)
CA
Reptile
FE
Lizard, California horned
Phrynosoma coronatum
CA, NV
Reptile
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-35
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Lizard, Coachella Valley fringe-
toed
Uma inornata
CA
Reptile
FT
Lizard, coast horned
Phrynosoma blainvillii
CA
Reptile
BS
Lizard, Colorado desert fringe¬
toed
Uma notata
CA
Reptile
BS
Lizard, desert night
Xantusia vigilis
UT
Reptile
BS
Lizard, desert spiny
Sceloporus magister
CO, UT
Reptile
BS
Lizard, dunes sagebrush
Sceloporus arenicolus
NM
Reptile
C
Lizard, flat-tailed homed
Phrynosoma mcalli
CA, CO
Reptile
BS
Lizard, greater short-homed
Phrynosoma hernandesi
MT
Reptile
BS
Lizard, island night
Xantusia riversiana
CA
Reptile
FT
Lizard, longnose leopard
Gambelia wislizenii
CA, CO
Reptile
BS
Lizard, Mohave fringe-toed
Uma scoparia
AZ, CA
Reptile
BS
Lizard, Mojave black-collared
Crotaphytus bicinctores
UT
Reptile
BS
Lizard, northern sagebrush
Sceloporus graciosus
graciosus
AZ, CA, OR
Reptile
BS
Lizard, panamint alligator
Elgaria panamintinus
CA
Reptile
BS
Lizard, Shasta alligator
Elgaria coerulea
NV
Reptile
BS
Lizard, side-blotched
Uta stansburiana
OR
Reptile
BS
Lizard, slevins bunchgrass
Sceloporus slevini
AZ
Reptile
BS
Lizard, Texas homed
Phrynosoma cornutum
AZ, CO, NM
Reptile
BS
Lizard, Utah night
Xantusia vigilis utahensis
UT
Reptile
BS
Lizard, Yuman desert fringe-toed
(Cowles fringe-toed)
Uma rufopunctata
AZ
Reptile
BS
Lizard, zebra-tailed
Callisaurus draconoides
UT
Reptile
BS
Lobelia, Kalm’s
Lobelia kalmii
OR
Plant
BS
Lobelia, pale-spiked
Lobelia spicata
MT
Plant
BS
Lobelia, water
Lobelia dortmanna
OR
Plant
BS
Locoweed, Bameby’s
Oxytropis arctica
AK
Plant
BS
Locoweed, Huddelson’s
Oxytropis huddelsonii
AK
Plant
BS
Locoweed, Kobuk
Oxytropis kobukensis
AK
Plant
BS
Locoweed, white
Oxytropis sericea
OR
Plant
BS
Loeflingia, sagebmsh
Loeflingia squarrosa ssp.
artemisiarum
CA
Plant
BS
Lomatium, adobe
Lomatium roseanum
CA
Plant
BS
Lomatium, Congdon’s
Lomatium congdonii
CA
Plant
BS
Lomatium, Cook’s
Lomatium cookii
OR
Plant
FE
Lomatium, Ochoco
Lomatium ochocense
OR
Plant
BS
Lomatium, Owens Peak
Lomatium shevockii
CA
Plant
BS
Lomatium, Raven’s
Lomatium ravenii
OR
Plant
BS
Lomatium, red-fruited
Lomatium erythrocarpum
OR
Plant
BS
Lomatium, Suksdorf s
Lomatium suksdorfu
OR
Plant
BS
Longspur, chestnut-collared
Calcarius ornatus
MT
Bird
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-36
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Longspur, McCown’s
Calcarius mccownii
MT
Bird
BS
Loon, common
Gavia immer
MT, OR
Bird
BS
Loon, yellow-billed
Gavia adamsii
AK
Bird
C
Lotus, red-flowered
Lotus rubriflorus
CA
Plant
BS
Lotus, scrub
Lotus argyraeus
CA, NV
Plant
BS
Lousewort, dwarf
Pedicularis centranthera
CA
Plant
BS
Lousewort, hairy
Pedicularis hirsuta
AK
Plant
BS
Lousewort, meadow
Pedicularis crenulata
MT
Plant
BS
Lousewort, Mount Rainier
Pedicularis rainierensis
OR
Plant
BS
Luina, colonial
Luina serpentina
OR
Plant
BS
Lung, lettuce
Lobaria oregano
CA
Plant
BS
Lungwort, Hall’s
Lobaria hallii
ID
Plant
BS
Lungwort, pored
Lobaria scrobiculata
ID
Plant
BS
Lungwort, smeared
Lobaria linita
ID, OR
Plant
BS
Lupine, Anthony Peak
Lupinus antoninus
CA
Plant
BS
Lupine, clover
Lupinus tidestromii
CA
Plant
FE
Lupine, Cobb Mountain
Lupinus sericatus
CA
Plant
BS
Lupine, Cusick’s
Lupinus lepidus
OR
Plant
BS
Lupine, Holmgren
Lupinus holmgrenianus
NV
Plant
BS
Lupine, inch-high
Lupinus uncialis
CA, ID
Plant
BS
Lupine, Kincaid’s
Lupinus sulphureus ssp.
kincaidii
OR
Plant
FT
Lupine, Mariposa
Lupinus citrinus
CA
Plant
BS
Lupine, Mcgee Meadows
Lupinus magnificus
CA
Plant
BS
Lupine, Mono Lake
Lupinus duranii
CA
Plant
BS
Lupine, Mountain Springs bush
Lupinus excubitus
CA
Plant
BS
Lupine, Nevada
Lupinus nevadensis
OR
Plant
BS
Lupine, Nipomo Mesa
Lupinus nipomensis
CA
Plant
FE
Lupine, orange
Lupinus citrinus
CA
Plant
BS
Lupine, Panamint Mountains
Lupinus magnificus
CA
Plant
BS
Lupine, Paradox Valley
Lupinus crassus
CO
Plant
BS
Lupine, Quincy
Lupinus dalesiae
CA
Plant
BS
Lupine, Sabine’s
Lupinus sabinianus
OR
Plant
BS
Lupine, San Luis
Lupinus ludovicianus
CA
Plant
BS
Lupine, shaggyhair
Lupinus spectabilis
CA
Plant
BS
Lupine, Tracy’s
Lupinus tracyi
OR
Plant
BS
Lynx, Canada
Lynx canadensis
AK, CO, ID,
MT, NM, OR,
UT, WY
Mammal
FT/PT
Madia, Hall’s
Madia hallii
CA
Plant
BS
Madia, Niles’
Madia doris-nilesiae
CA
Plant
BS
Madia, showy
Madia radiata
CA
Plant
BS
BI.M Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-37
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
\
Class
Status2
Madia, Stebbins’s
Harmonia stebbinsii ( =Madia
stebbinsii)
CA
Plant
BS
Maiden-hair, California
Adiantum jordanii
OR
Plant
BS
Malacothrix, Carmel Valley
Malacothrix saxatilis
CA
Plant
BS
Malacothrix, island
Malacothrix squalida
CA
Plant
FE
Malacothrix, lyrate
Malacothrix sonchoides
OR
Plant
BS
Malacothrix, Santa Cruz Island
Malacothrix indecora
CA
Plant
FE
Mallow, Carmel Valley bush
Malacothamnus palmeri
CA
Plant
BS
Mallow, Davidson’s bush
Malacothamnus davidsonii
CA
Plant
BS
Mallow, Gierisch
Sphaeralcea gierischii
AZ, UT
Plant
FE
Mallow, Indian Valley bush
Malocothamnus aboriginum
CA
Plant
BS
Mallow, Kern
Eremalche kernensis
CA, UT
Plant
FE
Mallow, Pima Indian
Abutilon parishii
AZ
Plant
BS
Manzanita, Arroyo de la Cruz
Arctostaphylos cruzensis
CA
Plant
BS
Manzanita, Del Mar
Arctostaphylos glandulosa
CA
Plant
FE
Manzanita, Gabilan Mountains
Arctostaphylos gabilanensis
CA
Plant
BS
Manzanita, hairy
Arctostaphylos hispidula
OR
Plant
BS
Manzanita, Hooker’s
Arctostaphylos hookeri ssp.
hookeri
CA
Plant
BS
Manzanita, lone
Arctostaphylos myrtifolia
CA, UT
Plant
FT
Manzanita, Klamath
Arctostaphylos klamathensis
CA
Plant
BS
Manzanita, Monterey
Arctostaphylos montereyensis
CA
Plant
BS
Manzanita, Morro
Arctostaphylos morroensis
CA
Plant
FT
Manzanita, Nissenan
Arctostaphylos nissenana
CA
Plant
BS
Manzanita, Otay
Arctostaphylos otayensis
CA
Plant
BS
Manzanita, Pajaro
Arctostaphylos pajaroensis
CA
Plant
BS
Manzanita, Pallid
Arctostaphylos pallida
CA
Plant
FT
Manzanita, Presidio
Arctostaphylos hookeri var.
ravenii
CA
Plant
FE
Manzanita, Sand Mesa
Arctostaphylos rudis
CA
Plant
BS
Manzanita, sandmat
Arctostaphylos pumila
CA
Plant
BS
Manzanita, Santa Margarita
Arctostaphylos pilosula
CA
Plant
BS
Manzanita, Santa Rosa Island
Arctostaphylos confertiflora
CA
Plant
FE
Manzanita, Sonoma canescent
Arctostaphylos cansecens
CA
Plant
BS
Marble, island large
Euchloe ausonides
OR
Invertebrate
BS
Mariposa lily, alkali
Calochortus striatus
CA, NV
Plant
BS
Mariposa lily, Arroyo de la Cruz
Calochortus clavatus var.
recurvifolius
CA
Plant
BS
Mariposa lily, broad-fruit
Calochortus nitidus
ID, OR
Plant
BS
Mariposa lily, crinite
Calochortus coxii
OR
Plant
BS
Mariposa lily, Dunn’s
Calochortus dunnii
CA
Plant
BS
Mariposa lily, green-band
Calochortus macrocarpus
ID, OR
Plant
BS
Mariposa lily, Greene’s
Calochortus greenei
CA, OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-38
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Mariposa lily, Howell’s
Calochortus howellii
OR
Plant
BS
Mariposa lily, Inyo
Calochortus excavatus
CA
Plant
BS
Mariposa lily, long-bearded
Peck’s
Calochortus longeharbatus
var. peckii
CA, OR
Plant
BS
Mariposa lily, one-leaved
Calochortus monophyllus
OR
Plant
BS
Mariposa lily, Pleasant Valley
Calochortus clavatus var.
avius
CA
Plant
BS
Mariposa lily, San Luis
Calochortus obispoensis
CA
Plant
BS
Mariposa lily, San Luis Obispo
Calochortus simulans
CA
Plant
BS
Mariposa lily, Sexton Mountain
Calochortus indecorus
OR
Plant
BS
Mariposa lily, Shasta River
Calochortus monanthus
CA
Plant
BS
Mariposa lily, Siskiyou
Calochortus persistens
CA, OR
Plant
C
Mariposa lily, Tiburon
Calochortus tiburonensis
CA
Plant
FT
Mariposa lily, Umpqua
Calochortus umpquaensis
OR
Plant
C
Marsh lily, Pitkin
Lilium pardalinum
CA
Plant
FE
Marsh-pennywort, whorled
Hydrocotyle verticillata
OR
Plant
BS
Marsh-rosemary, western
Limonium californicum
OR
Plant
BS
Marten
Martes americana
UT
Mammal
BS
Marten, Kenai
Mustela americana ssp.
AK
Mammal
BS
Martin, desert purple
Progne subis
AZ
Bird
BS
Martin, purple
Progne subis
MT, OR
Bird
BS
Massasauga
Sistrurus catenatus
CO
Reptile
BS
Mayfly
Acentrella feropagus
AK
Invertebrate
BS
Mayfly, Alaska endemic
Rhithrogena ingalik
AK
Invertebrate
BS
Meadowfoam, Baker’s
Limnanthes bakeri
CA
Plant
BS
Meadowfoam, Bellinger’s
Limnanthes floccosa ssp.
bellingeriana
CA, OR
Plant
BS
Meadowfoam, Butte County
Limnanthes floccosa ssp.
californica
CA
Plant
FE
Meadowfoam, Cuyamaca
Limnanthes gracilis
CA
Plant
BS
Meadowfoam, dwarf
Limnanthes floccosa ssp.
pumila
OR
Plant
BS
Meadowfoam, large-flowered
woolly
Limnanthes floccosa ssp.
grandiflora
OR
Plant
FE
Meadowfoam, Sebastopol
Limnanthes vinculans
CA
Plant
FE
Meadowfoam, slender
Limnanthes gracilis ssp.
gracilis
OR
Plant
BS
Meadowfoam, wooly
Limnanthes floccosa ssp.
floccosa
OR
Plant
FP/FE
Meadowlark, western
Sturnella neglecta
ID
Bird
BS
Meadowrue, alpine
Thalictrum alpinum
MT, OR
Plant
BS
Meadowrue, Cathedral Bluff
Thalictrum heliophilum
CO
Plant
BS
Meadowrue, purple
Thalictrum dasycarpum
ID, OR
Plant
BS
Mecca-aster
Xylorhiza cognata
CA
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-39
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Meesia
Meesia longiseta
CA
Invertebrate
BS
Mentzelia, bractless
Mentzelia nuda
MT
Plant
BS
Mentzelia, dwarf
Mentzelia pumila
MT
Plant
BS
Mentzelia, Packard’s
Mentzelia packardiae
OR
Plant
BS
Mesa-mint, Otay
Pogogyne nudiuscula
CA
Plant
FE
Mesa-mint, San Diego
Pogogyne abramsii
CA
Plant
FE
Microseris, coast
Microseris bigelovii
OR
Plant
BS
Microseris, Detling’s
Microseris laciniata
CA
Plant
BS
Microseris, Howell’s
Microseris howellii
OR
Plant
BS
Microseris, northern
Microseris borealis
OR
Plant
BS
Milk-vetch, Ames’ (= Suksdorf s
milk-vetch)
Astragalus pulsiferae var.
suksdorfii
CA, NV
Plant
BS
Milk- vetch, Applegate’s
Astragalus applegatei
OR
Plant
FE
Milk-vetch, Aquarius Mountain
Astragalus newberryi var.
aquarii
A Z
Plant
BS
Milk-vetch, Arthur’s
Astragalus arthurii
OR
Plant
BS
Milk-vetch, Ash Meadows
Astragalus phoenix
CA, NV
Plant
FT
Milk-vetch, Ash Valley
Astragalus anxius
CA
Plant
BS
Milk-vetch, Asotin
Astragalus asotinensis
OR
Plant
BS
Milk-vetch, Bameby egg
Astragalus oophorus var.
lonchocalyx
NV
Plant
BS
Milk-vetch, barren
Astragalus sterilis
ID
Plant
BS
Milk-vetch, Barr’s
Astragalus barrii
MT
Plant
BS
Milk-vetch, Bitterroot
Astragalus scaphoides
MT
Plant
BS
Milk-vetch, black (black woolly-
pod)
Astragalus funereus
CA, NV
Plant
BS
Milk-vetch, Brandegee
Astragalus brandegeei
CO
Plant
BS
Milk-vetch, Braunton’s
Astragalus brauntonii
CA
Plant
FE
Milk-vetch, broad-keeled
Astragalus platytropis
OR
Plant
BS
Milk-vetch, California
Astragalus californicus
OR
Plant
BS
Milk-vetch, Challis
Astragalus amblytropis
ID
Plant
BS
Milk-vetch, Cima
Astragalus cimae
NV
Plant
BS
Milk-vetch, Clara Hunt’s
Astragalus clarianus
CA
Plant
FE
Milk-vetch, cliff
Astragalus cremnophylax var.
myriorraphus
AZ
Plant
BS
Milk-vetch, Clokey’s
Astragalus aequalis
NV
Plant
BS
Milk-vetch, Coachella Valley
Astragalus lentiginosus var.
coachellae
CA, UT
Plant
FE
Milk-vetch, coastal dunes
Astragalus tener var. titi
CA
Plant
FE
Milk-vetch, coastal marsh
Astragalus pycnostachyus
CA
Plant
BS
Milk-vetch, Columbia
Astragalus columbianus
OR
Plant
BS
Milk-vetch, Cotton’s
Astragalus australis
OR
Plant
BS
Milk-vetch, Cronquist
Astragalus cronquistii
CO
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-40
January 20 1 6
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Milk-vetch, currant
Astragalus uncialis
NV
Plant
BS
Milk-vetch, curved-pod Mojave
Astragalus mohavensis ssp.
hemigyrus
CA, NV
Plant
BS
Milk-vetch, Cushenbury
Astragalus albens
CA
Plant
FE
Milk-vetch, Cusick’s
Astragalus cusickii var.
cusickii
OR
Plant
BS
Milk-vetch, Deane’s
Astragalus deanei
CA
Plant
BS
Milk-vetch, Debeque
Astragalus debequaeus
CO
Plant
BS
Milk-vetch, debris
Astragalus detritalis
CO
Plant
BS
Milk-vetch, Descanso
Astragalus oocarpus
CA
Plant
BS
Milk-vetch, Deseret
Astragalus desereticus
UT
Plant
FT
Milk-vetch, Diamond Butte
Astragalus toanus
AZ
Plant
BS
Milk-vetch, Drummond’s
Astragalus drummondii
ID
Plant
BS
Milk-vetch, Dubois
Astragalus gilviflorus var.
purpureus
WY
Plant
BS
Milk-vetch, Duchesne
Astragalus duchesnensis
CO
Plant
BS
Milk-vetch, Ferris’
Astragalus tener \2X. ferrisae
CA
Plant
BS
Milk-vetch, Ferron’s
Astragalus musiniensis
CO
Plant
BS
Milk-vetch, field
Astragalus agrestis
CA
Plant
BS
Milk-vetch, Fish Slough
Astragalus lentiginosus var.
piscinensis
CA
Plant
FT
Milk-vetch, Fisher Towers
Astragalus piscator
CO
Plant
BS
Milk-vetch, four-wing
Astragalus tetrapterus
ID, WY
Plant
BS
Milk-vetch, Gambel
Astragalus gambelianus
OR
Plant
BS
Milk-vetch, Geyer’s
Astragalus geyeri var. geyeri
CA, MT, OR
Plant
BS
Milk-vetch, Gilman’s
Astragalus gilmanii
NV
Plant
BS
Mi lk- vetch, Goose creek
Astragalus anserinus
CO, ID, NV,
UT
Plant
C
Milk-vetch, Grand Junction
Astragalus linifolius
CO
Plant
BS
Milk-vetch, Gray’s
Astragalus grayi
MT
Plant
BS
Milk-vetch, Gunnison
Astragalus an is us
CO
Plant
BS
Milk-vetch, heliotrope
Astragalus montii
UT
Plant
FT
Milk-vetch, Holmgren
Astragalus holmgreniorum
AZ, UT
Plant
FE
Milk-vetch, Horn’s
Astragalus hornii
CA
Plant
BS
Milk- vetch, horseshoe
Astragalus equisolensis
CA, UT
Plant
C
Milk-vetch, Huachuca
Astragalus hypoxylus
AZ
Plant
BS
Milk-vetch, Humboldt
Astragalus agnicidus
CA
Plant
BS
Milk-vetch, Hyattville
Astragalus jejunus var.
articulatus
WY
Plant
BS
Milk-vetch, Jacumba
Astragalus douglasii
CA
Plant
BS
Milk-vetch, Jepson’s
Astragalus rattanii
CA
Plant
BS
Milk-vetch, Lane Mountain
Astragalus jaegerianus
CA
Plant
FE
Milk-vetch, Laurence’s
Astragalus collinus
OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-41
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Milk-vetch, Lavin’s
Astragalus oophorus var.
lavinii
CA, NV
Plant
BS
Milk-vetch, least bladdery
Astragalus microcystis
OR
Plant
BS
Milk-vetch, Lemhi
Astragalus aquilonius
ID
Plant
BS
Milk-vetch, Lemmon’s
Astragalus lemmonii
CA
Plant
BS
Milk-vetch, lens-pod
Astragalus lentiformis
CA
Plant
BS
Milk-vetch, lesser rushy
Astragalus convallarius
MT
Plant
BS
Milk-vetch, lonesome
Astragalus solitarius
NV
Plant
BS
Milk-vetch, Long Valley
Astragalus johannis-howellii
CA
Plant
BS
Milk-vetch, Lost River
Astragalus amnis-amissi
ID
Plant
BS
Milk-vetch, Mancos
Astragalus humillimus
CO, NM
Plant
FE
Milk-vetch, Marble Canyon
Astragalus cremnophylax var.
hevronii
AZ
Plant
BS
Mi lk- vetch, Margaret Rushy
Astragalus convallarious var.
margaretiae
NV
Plant
BS
Milk-vetch, meadow
Astragalus diversifolius
ID, WY
Plant
BS
Milk-vetch, Mokiak
Astragalus mokiacensis
NV
Plant
BS
Milk-vetch, Mono
Astragalus monoensis
CA
Plant
BS
Milk-vetch, mourning
Astragalus atratus var.
mensanus
CA, ID
Plant
BS
Milk-vetch, Mulford’s
Astragalus mulfordiae
ID, OR
Plant
BS
Milk-vetch, Naturita
Astragalus naturitensis
CO
Plant
BS
Milk-vetch, Needle Mountains
Astragalus eurylobus
NV
Plant
BS
Milk-vetch, Nelson
Astragalus nelsonianus
CO, WY
Plant
BS
Milk-vetch, Newberry’s
Astragalus newberryi var.
castoreus
ID
Plant
BS
Milk-vetch, Osgood Mountains
Astragalus yoder-williamsii
ID, NV
Plant
BS
Milk-vetch, Osterhout
Astragalus osterhoutii
CO
Plant
FE
Milk-vetch, Packard’s
Astragalus cusickii var.
packardii
ID
Plant
C
Milk-vetch, painted
Astragalus ceramicus
MT
Plant
BS
Milk-vetch, Palouse
Astragalus ar rectus
OR
Plant
BS
Milk-vetch, park
Astragalus leptaleus
ID
Plant
BS
Milk-vetch, pauper
Astragalus misellus
OR
Plant
BS
Milk-vetch, Payson’s
Astragalus paysonii
ID
Plant
BS
Milk-vetch, Peck’s
Astragalus peckii
OR
Plant
BS
Milk-vetch, picabo
Astragalus oniciformis
ID
Plant
BS
Milk-vetch, Pierson’s
Astragalus magdalenae var.
peirsonii
CA
Plant
FT
Milk-vetch, Pipers
Astragalus riparius
OR
Plant
BS
Milk-vetch, plains
Astragalus gilviflorus
ID
Plant
BS
Milk-vetch, precocious
Astragalus proimanthus
WY
Plant
BS
Milk-vetch, Pulsifer’s
Astragalus pulsiferae var.
pulsiferae
CA
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-42
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Milk-vetch, railhead
Astragalus terminalis
ID, MT
Plant
BS
Milk-vetch, Ripley’s
Astragalus ripleyi
CO
Plant
BS
Milk-vetch, San Rafeal
Astragalus rafaelensis
CO
Plant
BS
Milk-vetch, sandstone
Astragalus sesquiflorus
CO
Plant
BS
Milk-vetch, Schmoll
Astragalus schmolliae
CO
Plant
C
Milk-vetch, sentry
Astragalus cremnophylax var.
cremnophylax
AZ
Plant
FE
Milk-vetch, Shevock’s
Astragalus shevockii
CA
Plant
BS
Milk-vetch, Shivwitz
Astragalus ampullarioides
UT
Plant
FE
Milk-vetch, silverleaf
Astragalus argophyllus
CA
Plant
BS
Milk-vetch, skiff
Astragalus microcymbus
CO
Plant
C
Milk-vetch, sleeping Ute
Astragalus tortipes
CO
Plant
C
Milk-vetch, Snake River
Astragalus purshii
ID
Plant
BS
Milk-vetch, Sodaville
Astragalus lentiginosus ssp.
sesquimetralis
NV
Plant
BS
Milk-vetch, South Fork John
Day
Astragalus diaphanus
OR
Plant
BS
Milk-vetch, spine-noded
Peteria thompsoniae
ID
Plant
BS
Milk-vetch, Spring Mountains
Astragalus remotus
NV
Plant
BS
Milk-vetch, starveling
Astragalus jejunus var.
jejunus
CO, ID
Plant
BS
Milk-vetch, sterile
Astragalus cusickii var.
sterilis
OR
Plant
BS
Milk-vetch, straw
Astragalus lentiginosus
NV
Plant
BS
Mi lk- vetch, Sweetwater
Astragalus aretioides
CO, MT
Plant
BS
Milk-vetch, three-comer
Astragalus geyeri var.
triquetris
AZ, NV
Plant
BS
Milk-vetch, Tiehm’s
Astragalus tiehmii
CA, NV
Plant
BS
Milk-vetch, Tonopah
Astragalus pseudiodanthus
CA, NV
Plant
BS
Milk-vetch, Toquima
Astragalus toquimanus
NV
Plant
BS
Milk-vetch, Torrey
Astragalus calycosus
NV, OR
Plant
BS
Milk-vetch, Trelease’s
Astragalus racemosus
WY
Plant
BS
Milk-vetch, triple-ribbed
Astragalus tricarinatus
CA
Plant
FE
Milk- vetch. Trout Creek
Astragalus salmonis
ID
Plant
BS
Milk-vetch, two-grooved
Astragalus bisulcatus
ID
Plant
BS
Milk-vetch, Tygh Valley
Astragalus tyghensis
OR
Plant
BS
Milk-vetch, Ventura Marsh
Astragalus pycnostachyus
var. lanosissimus
CA
Plant
FE
Milk- vetch, Veyo
Astragalus ensiformis
NV
Plant
BS
Milk-vetch, Walker Pass
Astragalus ertterae
CA
Plant
BS
Milk-vetch, Webber’s
Astragalus webberi
CA
Plant
BS
Milk-vetch, Whited
Astragalus sinuatus
OR
Plant
BS
Milk-vetch, Wind River
Astragalus oreganus
MT
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-43
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Milkweed, dwarf
Asclepias uncialis
CO
Plant
BS
Milkweed, Eastwood
Asclepias eastwoodiana
NV
Plant
BS
Milkweed, narrowleaf
Asclepias stenophylla
MT
Plant
BS
Milkweed, Welsh’s
Asclepias welshii
AZ, UT
Plant
FT
Miners-lettuce, Bostock’s
Montia bostockii
AK
Plant
BS
Minnow, loach
Tiaroga cobitis
AZ, NM
Fish
FE
Minnow, Rio Grande silvery
Hybognathus amarus
NM
Fish
FE
Mistmaiden, Thompson
Romanzoffia thompsonii
OR
Plant
BS
Molly, green
Kochia americana
MT
Plant
BS
Monardella, crisp
Monardella crispa
CA
Plant
BS
Monardella, flax-like
Monardella linoides
CA
Plant
BS
Monardella, Jennifer’s
Monardella stoneana
CA
Plant
BS
Monardella, Robison
Monardella robisonii
CA
Plant
BS
Monardella, robust
Monardella villosa
CA
Plant
BS
Monardella, San Luis Obispo
Monardella frutescens
CA
Plant
BS
Monardella, sweet-smelling
Monardella beneolens
CA
Plant
BS
Monardella, veiny
Monardella douglasii
CA
Plant
BS
Monardella, willowy
Monardella viminea
CA
Plant
FE
Monkeyflower
Mimulus sp.
CA
Plant
BS
Monkey flower, Bolander’s
Mimulus bolanderi
OR
Plant
BS
Monkeyflower, broad-toothed
Mimulus latidens
OR
Plant
BS
Monkeyflower, Calico
Mimulus pictus
CA
Plant
BS
Monkeyflower, Congdon’s
Mimulus congdonii
OR
Plant
BS
Monkeyflower, Cusick
Mimulus cusickii
OR
Plant
BS
Monkeyflower, disappearing
Mimulus evanescens
CA, OR
Plant
BS
Monkeyflower, dwarf purple
Mimulus nanus
MT
Plant
BS
Monkeyflower, Eastwood
Mimulus eastwoodiae
CO, OR
Plant
BS
Monkeyflower, Kaweah
Mimulus norrisii
CA, CO
Plant
BS
Monkeyflower, liverwort
Mimulus jungermannioides
CA
Plant
BS
Monkeyflower, membrane¬
leaved
Mimulus hymenophyllus
ID, OR
Plant
BS
Monkeyflower, Mojave
Mimulus mohavensis
CA
Plant
BS
Monkeyflower, pansy
Mimulus pulchellus
CA
Plant
BS
Monkeyflower, primrose
Mimulus primuloides
MT
Plant
BS
Monkey-flower, Pulsifer’s
Mimulus pulsiferae
OR
Plant
BS
Monkeyflower, pygmy
Mimulus pygmaeus
CA
Plant
BS
Monkeyflower, Shevock’s
Mimulus shevockii
CA
Plant
BS
Monkeyflower, slender-stalked
Mimulus gracilipes
CA
Plant
BS
Monkeyflower, slender-stemmed
Mimulus fdicaulis
CA
Plant
BS
Monkeyflower, spacious
Mimulus washingtonensis
ID
Plant
BS
Monkeyflower, square-stem
Mimulus ringens
MT
Plant
BS
Monkeyflower, stalk-leaved
Mimulus patulus
ID, OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-44
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Monkey-flower, Suksdorfs
Mimulus suksdorfii
OR
Plant
BS
Monkey-flower, three-colored
Mimulus tricolor
OR
Plant
BS
Monkey flower, Vandenberg
Mimulus fremontii
CA
Plant
C
Monster, gila
Heloderma suspectum
CA, UT
Reptile
BS
Montia, branching
Montia dijfusa
OR
Plant
BS
Moonpod, desert
Selinocarpus diffusus
AZ
Plant
BS
Moonpod, goosefoot
Ammocodon chenopodioides
AZ
Plant
BS
Moonwort
Botrychium lunaria
OR
Plant
BS
Moonwort, least
Botrychium simplex
ID
Plant
BS
Moonwort, Mingan
Botrychium minganense
ID, OR
Plant
BS
Moonwort, northern
Botrychium pinnatum
ID
Plant
BS
Moonwort, prairie
Botrychium campestre
OR
Plant
BS
Moonwort, scalloped
Botrychium crenulatum
CA, ID, NV,
OR
Plant
BS
Moonwort, slender
Botrychium lineare
CO, ID, OR,
UT, WY
Plant
C
Moonwort, stalked
Botrychium pedunculosum
OR
Plant
BS
Moonwort, twin-spiked
Botrychium paradoxum
MT, OR
Plant
BS
Moonwort, upward-lobed
Botrychium ascendens
AK, ID, OR
Plant
BS
Moonwort, western
Botrychium hesperium
OR
Plant
BS
Moose
A Ices americanus
OR
Mammal
BS
Morning-glory, Stebbins’
Calystegia stehhinsii
CA
Plant
FE
Morning-glory, three-fingered
Calystegia collina
CA
Plant
BS
Moss
Andreaea schofieldiana
OR
Plant
BS
Moss
Campylopus schmidii
OR
Plant
BS
Moss
Codriophorus depressus
OR
Plant
BS
Moss
Encalypta brevicollis
OR
Plant
BS
Moss
Encalypta brevipes
OR
Plant
BS
Moss
Encalypta intermedia
OR
Plant
BS
Moss
Entosthodon fascicularis
OR
Plant
BS
Moss
Ephemerum crassinervium
OR
Plant
BS
Moss
Iwatsukiella leucotricha
OR
Plant
BS
Moss
Limbella fryei
OR
Plant
BS
Moss
Meesia uliginosa
OR
Plant
BS
Moss
Orthodontium pellucens
OR
Plant
BS
Moss
Polytrichum sphaerothecium
OR
Plant
BS
Moss
Pseudocalliergon trifarium
OR
Plant
BS
Moss
Rhizomnium nudum
OR
Plant
BS
Moss
Rhytidium rugosum
OR
Plant
BS
Moss
Schistidium cinclidodonteum
OR
Plant
BS
Moss
Schistostega pennata
OR
Plant
BS
Moss
Scouleria marginata
OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-45
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Moss
Splachnum ampullaceum
OR
Plant
BS
Moss
Tayloria serrata
OR
Plant
BS
Moss
Tetraplodon mnioides
OR
Plant
BS
Moss
Tomentypnum nitens
OR
Plant
BS
Moss
Tortula californica
CA
Plant
BS
Moss
Tortula mucronifolia
OR
Plant
BS
Moss
Trematodon boasii
OR
Plant
BS
Moss, bent-kneed four-tooth
Tetraphis geniculata
CA, OR
Plant
BS
Moss, Gold Butte
Didymodon nevadensis
NV
Plant
BS
Moss, green bug
Buxbaumia viridis
CA
Plant
BS
Moss, slender thread
Orthodontium gracile
CA
Plant
BS
Moth, Kern primrose sphinx
Euproserpinus euterpe
CA
Invertebrate
FT
Mountain balm, Indian Knob
Eriodictyon altissimum
CA
Plant
FE
Mountain beaver, Point Arena
Aplodontia rufa nigra
CA
Mammal
FE
Mountain-avens, yellow
Dryas drummondii
OR
Plant
BS
Mountain-mahogany, Catalina
Island
Cercocarpus traskiae
CA
Plant
FE
Mountain-parsley, purple
Oreonana purpurascens
CA
Plant
BS
Mountainsnail, boulder pile
Oreohelix jugalis
ID
Invertebrate
BS
Mountainsnail, carinated striate
banded
Oreo helix strigosa
OR
Invertebrate
BS
Mountainsnail, Chelan
Oreohelix sp.
OR
Invertebrate
BS
Mountainsnail, Deschutes
Oreohelix variabilis
OR
Invertebrate
BS
Mountainsnail, Idaho banded
Oreohelix idahoensis
ID
Invertebrate
BS
Mountainsnail, lava rock
Oreohelix waltoni
ID
Invertebrate
BS
Mountainsnail, Ogden deseret
Oreohelix periphera
UT
Invertebrate
C
Mountainsnail, whorled
Oreohelix vortex
ID
Invertebrate
BS
Mouse, cactus
Peromyscus torridus
UT
Mammal
BS
Mouse, dark kangaroo
Microdipodops megacephalus
ID, NV, UT
Mammal
BS
Mouse, Great Basin pocket
Perognathus parvus
MT
Mammal
BS
Mouse, meadow jumping
Zapus hudsonius
MT
Mammal
BS
Mouse, New Mexico meadow
jumping
Zapus hudsonius luteus
AZ, CO, NM
Mammal
FE
Mouse, northern rock
Peromyscus nasutus
UT
Mammal
BS
Mouse, olive-backed pocket
Perognathus fasciatus
UT
Mammal
BS
Mouse, Pacific pocket
Perognathus longimembris
CA
Mammal
FE
Mouse, pale kangaroo
Microdipodops pallidus
NV
Mammal
BS
Mouse, Palm Springs little
pocket
Perognathus longimembris
bangsi
CA
Mammal
BS
Mouse, petaled
Pannaria rubiginosa
CA, OR
Plant
BS
Mouse, Preble’s meadow
jumping
Zapus hudsonius preblei
CO, WY
Mammal
FT
Mouse, rock pocket
Chaetodipus intermedius
UT
Mammal
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-46
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Mouse, Salt Marsh Harvest
Reithrodontomys raviventris
CA
Mammal
FE
Mouse, San Joaquin pocket
Perognathus inornatus
inornatus
CA
Mammal
BS
Mouse, silky pocket
Perognathus flavus
UT
Mammal
BS
Mouse, southern grasshopper
Onychomys torridus
UT
Mammal
BS
Mouse, Tulare grasshopper
Onychomys torridus
tularensis
CA
Mammal
BS
Mouse, white-eared pocket
Perognathus alticola alticola
CA
Mammal
BS
Mouse, yellow-eared pocket
Perognathus xanthonotus
CA
Mammal
BS
Mousetail
Myosurus clavicaulis
OR
Plant
BS
Mousetails, Sierra Valley
Ivesia aperta
CA, NV
Plant
BS
Mudwort, southern
Limosella acaulis
ID
Plant
BS
Muhly, marsh
Muhlenhergia glomerata
OR
Plant
BS
Mule ears, El Dorado
Wyethia reticulata
CA
Plant
BS
Murrelet, Kittlitz’s
Brachyramphus hrevirostris
AK
Bird
BS
Murrelet, marbled
Brachyramphus marmoratus
CA, OR
Bird
FT
Murrelet, Xantus’s
Synthliboramphus hypoleucus
CA, OR
Bird
BS
Mushroom, cauliflower
Sparassis crispa
CA
Plant
BS
Mushroom, little brown
Clitocybe subditopoda
CA
Fungi
BS
Mushroom, little brown
Mycena quinaultensis
CA
Fungi
BS
Mushroom, little green
Dermocybe humboldtensis
CA, OR
Fungi
BS
Mushroom, little green
Hydropus marginellus
CA
Fungi
BS
Mushroom, orange coral
Ramaria largentii
CA, OR
Fungi
BS
Mushroom, pinkish coral
Ramaria amyloidea
CA, OR
Fungi
BS
Mushroom, pinkish coral
Ramaria cyaneigranosa
CA
Fungi
BS
Mushroom, yellow coral
Ramaria aurantiisiccescens
CA
Fungi
BS
Mussel, western ridged
Gonidea angulata
OR
Invertebrate
BS
Mustard, Penland alpine fen
Eutrema penlandii
CO
Plant
FT
Mustard, slender-petaled
Thelypodium stenopetalum
CA
Plant
FE
Myotis, Arizona
Myotis occultus
AZ
Mammal
BS
Myotis, California
Myotis californicus
NV
Mammal
BS
Myotis, cave
Myotis velifer
AZ, CA, NM,
NV
Mammal
BS
Myotis, fringed
Myotis thysanodes
AZ, CA, CO,
ID, MT, NM,
NV, OR, UT,
WY
Mammal
BS
Myotis, fringe-tailed
Myotis thysanodes
phasapensis
MT
Mammal
BS
Myotis, Keen’s
Myotis keenii
OR
Mammal
BS
Myotis, little brown
Myotis lucifugus
NV
Mammal
BS
Myotis, long-eared
Myotis evotis
AZ, CA, ID,
NM, NV, MT,
WY
Mammal
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-47
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Myotis, long-legged
Myotis volans
AZ, ID, MT,
NM, NV
Mammal
BS
Myotis, northern
Myotis septentrionalis
MT
Mammal
BS
Myotis, western small-footed
Myotis ciliolabrum
AZ, CA, ID,
NM, NV
Mammal
BS
Myotis, Yuma
Myotis yumanensis
CA, CO, ID,
NM, NV
Mammal
BS
Nagoonberry
Rubus acaulis
OR
Plant
BS
Nama
Nama densum
MT
Plant
BS
Nannyberry
Viburnum lentago
MT
Plant
BS
Naucorid, Ash Meadows
Ambrysus amargosus
NV
Invertebrate
FT
Naucorid bug, Nevares Spring
(=Fumace Creek)
Ambrysus funebris
CA
Invertebrate
C
Navarretia, Baker’s
Navarretia leucocephala ssp.
bakeri
CA
Plant
BS
Navarretia, few-flowered
Navarretia leucocephala ssp.
pauciflora
CA
Plant
FE
Navarretia, many-flowered
Navarretia leucocephala ssp.
plieantha
CA
Plant
FE
Navarretia, marigold
Navarretia tagetina
OR
Plant
BS
Navarretia, Piute Mountains
Navarretia setiloba
CA
Plant
BS
Navarretia, shining
Navarretia nigelliformis
CA
Plant
BS
Navarretia, spreading
Navarretia fossalis
CA
Plant
FT
Navarretia, white-flowered
Navarretia leucocephala
OR
Plant
BS
Necklacepod, western
Sophora leachiana
OR
Plant
BS
Needle, giant Spanish
Palafoxia arida
CA
Plant
BS
Needlegrass, desert
Achnatherum speciosum
OR
Plant
BS
Needlegrass, green
Stipa viridula
ID
Plant
BS
Nemacladus, slender
Nemacladus capillaris
OR
Plant
BS
Nemacladus, Twisselmann’s
Nemacladus twisselmannii
CA
Plant
BS
Neoparrya, rock loving
Neoparrya lithophila
CO, OR
Plant
BS
Neststraw, Mason
Stylocline masonii
CA
Plant
BS
Neststraw, oil
Stylocline citroleum
CA
Plant
BS
Nighthawk, common
Chordeiles minor
OR
Bird
BS
Niterwort, Amargosa
Nitrophila mohavensis
CA, NV
Plant
FE
Nuthatch, pygmy
Sitta pygmaea
ID, OR
Bird
BS
Nuthatch, slender-billed
Sitta carolinensis
OR
Bird
BS
Nymph, Big Smoky wood
Cercyonis oetus alkalorum
NV
Invertebrate
BS
Nymph, Carson Valley wood
Cercyonis pegala ssp.
NV
Invertebrate
BS
Nymph, pallid wood
Cercyonis oetus pallescens
NV
Invertebrate
BS
Nymph, White River wood
Cercyonis pegala carsonensis
NV
Invertebrate
BS
Oak, bur
Quercus macrocarpa
MT
Plant
BS
Ocelot
Leopardus pardalis
AZ
Mammal
FE
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-48
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Onion, Aase’s
Allium aaseae
ID
Plant
BS
Onion, constricted Douglas
Allium constrictum
OR
Plant
BS
Onion, Geyer’s
Allium geyeri
OR
Plant
BS
Onion, Hickman’s
Allium hickmanii
CA
Plant
BS
Onion, Jepson’s
Allium jepsonii
CA
Plant
BS
Onion, Munz’s
Allium munzii
CA
Plant
FE
Onion, Parish wild
Allium paris hi i
AZ
Plant
BS
Onion, Rawhide Hill
Allium tuolumnense
CA
Plant
BS
Onion, Sierra
Allium campanulatum
OR
Plant
BS
Onion, Spanish needle
Allium shevockii
CA
Plant
BS
Onion, tall swamp
Allium validum
ID
Plant
BS
Onion, tapertip
Allium acuminatum
MT
Plant
BS
Onion, Tolmie’s
Allium tolmiei
ID
Plant
BS
Onion, two-headed
Allium anceps
ID
Plant
BS
Orache, Earlimart
Atriplex erecticaulis
CA
Plant
BS
Orache, subtle
A triplex subtilis
CA
Plant
BS
Orchid, chatterbox
Epipactis gigantea
ID
Plant
BS
Orchid, western prairie fringed
Platanthera praeclara
MT, WY
Plant
FT
Orchid, white-flowered rein
Piperia Candida
CA
Plant
BS
Orcutt grass, California
Orcuttia californica
CA
Plant
FE
Orcutt grass, hairy
Orcuttia pilosa
CA
Plant
FE
Orcutt grass, Sacramento
Orcuttia viscida
CA
Plant
FE
Orcutt grass, San Joaquin Valley
Orcuttia inaequalis
CA
Plant
FT
Orcutt grass, slender
Orcuttia tenuis
CA
Plant
FT
Oregonian (snail), disc
Cryptomastix sp.
OR
Invertebrate
BS
Oregonian, Mission Creek
Cryptomastrix magnidentata
ID
Fish
BS
Oregonian, Puget
Cryptomastix devia
OR
Invertebrate
BS
Oriole, Scott’s
Icterus parisorum
ID
Bird
BS
Orthocarpus, Shasta
Orthocarpus pachystachyus
CA
Plant
BS
Orthotrichium, halls
Orthotrichium hallii
ID
Plant
BS
Oryctes, Nevada
Oryctes nevadensis
CA, NV
Plant
BS
Osprey
Pandion haliaetus
NV, UT
Bird
BS
Otter, northern river
Lutra canadensis
UT, WY
Mammal
BS
Otter, northern sea
Enhydra lutris kenyoni
AK
Mammal
FT
Otter, river
Lutra canadensis
AZ, ID, NM,
NV, WY
Mammal
BS
Otter, sea
Enhydra lutris
OR
Mammal
BS
Otter, southern sea
Enhydra lutris nereis
CA
Mammal
FT/XN
Otter, southwestern
Lutra canadensis sonora
NM
Mammal
BS
Owl, boreal
Aegolius funereus
ID, MT
Bird
BS
Owl, burrowing
Athene cunicularia
CA, CO, MT,
OR, UT, WY
Bird
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-49
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
, State1
Class
Status2
Owl, cactus ferruginous pygmy-
Glaucidium brasilianum
AZ
Bird
FE/BS
Owl, California spotted
Strix occidentalis
CA
Bird
BS
Owl, elf
Micrathene whitneyi
CA
Bird
BS
Owl, flammulated
Otus flammeolus
ID, MT, OR
Bird
BS
Owl, great gray
Strix nebulosa
ID, MT, NV,
OR
Bird
BS
Owl, Mexican spotted
Strix occidentalis lucida
AZ, CA, CO,
NM, UT
Bird
FT
Owl, northern (Blue Mountains)
pygmy
Glaucidium gnoma
OR
Bird
BS
Owl, northern spotted
Strix occidentalis caurina
CA, OR
Bird
FT
Owl, short-eared
Asio flammeus
AK, UT
Bird
BS
Owl, western burrowing
Athene cunicularia
AZ, ID, NV
Bird
BS
Owl’s-clover, fleshy
Castilleja campestris ssp.
succulenta
CA
Plant
FT
Owl’s-clover, Humboldt Bay
Castilleja ambigua
CA
Plant
BS
Owl’s-clover, rosy
Orthocarpus bracteosus
ID, OR
Plant
BS
Owl’s-clover, succulent
Castilleja campestris
CA, CO, UT
Plant
FT
Oxytheca, Cushenberry
Oxytheca parishii var.
goodmaniana
CA, UT
Plant
FE
Paddlefish
Polyodon spathula
MT
Fish
BS
Paintbrush, annual Indian
Castilleja exilis
MT
Plant
BS
Paintbrush, aquarius
Castilleja aquariensis
UT
Plant
C
Paintbrush, ash-grey
Castilleja cinerea
CA
Plant
FT
Paintbrush, Chamber’s
Castilleja chambersii
OR
Plant
BS
Paintbrush, Christ’s
Castilleja christii
ID
Plant
C
Paintbrush, fraternal
Castilleja fraterna
OR
Plant
BS
Paintbrush, golden
Castilleja levisecta
OR
Plant
FT
Paintbrush, green-tinged
Castilleja chlorotica
OR
Plant
BS
Paintbrush, Mendocino Coast
Castilleja mendocinensis
CA, OR
Plant
BS
Paintbrush, Monte Neva
Castilleja salsuginosa
NV
Plant
BS
Paintbrush, Mount Gleason
Indian
Castilleja gleasonii
CA
Plant
BS
Paintbrush, Obispo Indian
Castilleja densiflora ssp.
obospoensis
CA
Plant
BS
Paintbrush, obscure Indian
Castilleja cryptantha
OR
Plant
BS
Paintbrush, ornate
Castilleja ornata
NM
Plant
BS
Paintbrush, purple alpine
Castilleja rubida
OR
Plant
BS
Paintbrush, soft-leaved
Castilleja mollis
CA
Plant
FE
Paintbrush, Steens Mountain
Castilleja pilosa var.
steenensis
OR
Plant
BS
Paintbrush, Thompson’s
Castilleja thompsonii
OR
Plant
BS
Paintbrush, Tiburon
Castilleja affmis
CA
Plant
FE
Paronychia, Ahart’s
Paronychia ahartii
CA
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-50
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Pasqueflower
Anemone nuttalliana
OR
Plant
BS
Peaclam, montane
Pisidium ultramontanum
OR
Invertebrate
BS
Peavine, thin-leaved
Lathyrus holochlorus
OR
Plant
BS
Pebblesnail, Ash Meadows
Pyrgulopsis erythropoma
NV
Invertebrate
BS
Pebblesnail, casebeer
Fluminicola sp.
OR
Invertebrate
BS
Pebblesnail, Columbia
Fluminicola columbianus
ID
Invertebrate
BS
Pebblesnail, Donner und Blitzen
Fluminicola insolitus
OR
Invertebrate
BS
Pebblesnail, Fall Creek
Fluminicola sp.
OR
Invertebrate
BS
Pebblesnail, Keene Creek
Fluminicola sp.
OR
Invertebrate
BS
Pebblesnail, Klamath
Fluminicola sp.
OR
Invertebrate
BS
Pebblesnail, Klamath Rim
Fluminicola sp.
OR
Invertebrate
BS
Pebblesnail, Lake of the Woods
Fluminicola sp.
OR
Invertebrate
BS
Pebblesnail, Moapa
Pyrgulopsis avernalis
NV
Invertebrate
BS
Pebblesnail, Newrite
Fluminicola sp.
OR
Invertebrate
BS
Pebblesnail, Pahranagat
Pyrgulopsis merriami
NV
Invertebrate
BS
Pebblesnail, tigerlily
Fluminicola sp.
OR
Invertebrate
BS
Pebblesnail, toothed
Fluminicola sp.
OR
Invertebrate
BS
Pelican, American white
Pelecanus erythrorhynchus
CO, NV, OR,
UT
Bird
BS
Pelican, brown
Pelecanus occidentals
AK, A Z, CA,
OR
Bird
BS
Pennycress, Kneeland Prairie
Thlaspi californicum
CA
Plant
FE
Pennycress, meadow
Thlaspi parviflorum
MT
Plant
BS
Pennyroyal, Todsen’s
Hedeoma todsenii
NM
Plant
FE
Penstemon, blowout
Penstemon hay deni i
WY
Plant
FE
Penstemon, Idaho
Penstemon idahoensis
CO, ID, NV
Plant
BS
Penstemon, Janish’s
Penstemon janishiae
CA, ID
Plant
BS
Penstemon, Lemhi
Penstemon lemhiensis
ID, MT
Plant
BS
Penstemon, narrowleaf
Penstemon angustifolius
MT
Plant
BS
Penstemon, Peck’s
Penstemon peckii
OR
Plant
BS
Penstemon, variable hot-rock
Penstemon deustus
OR
Plant
BS
Penstemon, Whited’s
Penstemon eriantherus
OR
Plant
BS
Penstemon, white-margined
Penstemon albomarginatus
AZ, CA, NV
Plant
BS
Penstemon, Wilcox’s
Penstemon wilcoxii
OR
Plant
BS
Pentachaeta, Lyons
Pentachaeta lyonii
CA
Plant
FE
Pentachaeta, slender
Pentachaeta exit is
CA
Plant
BS
Pentachaeta, white-rayed
Pentachaeta bellidiflora
CA
Plant
FE
Peppercress, Pueblo Valley
Lepidium montanum
NV
Plant
BS
Peppercress, Tiehm
Stroganowia tiehmii
NV
Plant
BS
Peppergrass, Borrego Valley
Lepidium flavum
CA
Plant
BS
Peppergrass, Davis’
Lepidium davisii
ID, OR
Plant
BS
Peppergrass, entire-leaved
Lepidium integrifolium
WY
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-5 1
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Peppergrass, Jared’s
Lepidium jaredii ssp .jaradii
CA
Plant
BS
Peppergrass, Ostler’s
Lepidium ostleri
UT
Plant
C
Peppergrass, Panoche
Lepidium jaredii ssp. album
CA
Plant
BS
Peppergrass, slickspot
Lepidium papilliferum
ID
Plant
FT
Phacelia
Phacelia sp.
CA
Plant
BS
Phacelia, Brand’s
Phacelia stellaris
CA
Plant
C
Phacelia, Charlotte’s
Phacelia nashiana
CA
Plant
BS
Phacelia, Clarke
Phacelia fdiae
NV
Plant
BS
Phacelia, clay
Phacelia argillacea
UT
Plant
FE
Phacelia, Cooke’s
Phacelia cookei
CA
Plant
BS
Phacelia, Death Valley round¬
leaved
Phacelia mustelina
CA, ID
Plant
BS
Phacelia, Debeque
Phacelia submutica
CO
Plant
FT
Phacelia, dwarf
Phacelia tetramera
OR
Plant
BS
Phacelia, Franklin’s
Phacelia franklinii
OR
Plant
BS
Phacelia, hoary
Phacelia incana
MT
Plant
BS
Phacelia, Hot Spring
Phacelia thermalis
MT
Plant
BS
Phacelia, Inyo
Phacelia inyoensis
CA
Plant
BS
Phacelia, island
Phacelia insularis
CA
Plant
FE
Phacelia, least
Phacelia minutissima
ID, NV, OR
Plant
BS
Phacelia, Macbride
Phacelia mollis
AK
Plant
BS
Phacelia, Mackenzie’s
Phacelia lutea var.
mackenzieorum
OR
Plant
BS
Phacelia, Malheur yellow
Phacelia lutea
ID
Plant
BS
Phacelia, Mono County
Phacelia monoensis
CA, NV
Plant
BS
Phacelia, Mount Diablo
Phacelia phacelioides
CA
Plant
BS
Phacelia, naked-stemmed
Phacelia gymnoclada
OR
Plant
BS
Phacelia, Nine Mile Canyon
Phacelia novenmillensis
CA
Plant
BS
Phacelia, North Park
Phacelia formosula
CO
Plant
FE
Phacelia, obscure
Phacelia inconspicua
ID, NV
Plant
BS
Phacelia, Parish
Phacelia parishii
AZ, CA, NM,
NV
Plant
BS
Phacelia, playa
Phacelia inundata
CA, NV, OR
Plant
BS
Phacelia, Scott Mountain
Phacelia dalesiana
CA
Plant
BS
Phacelia, Scott Valley
Phacelia greenei
CA
Plant
BS
Phacelia, silvery
Phacelia argentea
OR
Plant
BS
Phacelia, Siskiyou
Phacelia leonis
CA, OR
Plant
BS
Phacelia, Stebbin’s
Phacelia stebbinsii
CA
Plant
BS
Phacelia, sticky
Phacelia lenta
OR
Plant
BS
Phaeocollybia, California
Phaeocollybia californica
CA, OR
Fungi
BS
Phaeocollybia, olive
Phaeocollybia olivacea
CA, OR
Fungi
BS
Phaeocollybia, spruce
Phaeocollybia piceae
CA
Fungi
BS
Phainopepla
Phainopepla nitens
NV, OR
Bird
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-52
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Phlox, Beaver Rim
Phlox pungens
WY
Plant
BS
Phlox, Hazel’s prickly
Leptodactylon pungens
ID, OR
Plant
BS
Phlox, Henderson’s
Phlox hendersonii
OR
Plant
BS
Phlox, Kelsey’s
Phlox kelseyi
ID
Plant
BS
Phlox, many-flowered
Phlox multiflora
OR
Plant
BS
Phlox, mat prickly
Leptodactylon caespitosum
MT
Plant
BS
Phlox, Missoula
Phlox missoulensis
MT
Plant
BS
Phlox, Owyhee prickly
Leptodactylon glahrum
ID, NV
Plant
BS
Phlox, plains
Phlox andicola
MT
Plant
BS
Phlox, Yreka
Phlox hirsuta
CA
Plant
FE
Physa (snail), hot spring
Physella sp.
OR
Invertebrate
BS
Physa (snail), rotund
Physella columhiana
OR
Invertebrate
BS
Pika, American
Ochotona princeps
NV, UT
Mammal
BS
Pikeminnow, Colorado
Ptychocheilus lucius
A Z, CA, CO,
NM, UT, WY
Fish
FE/XN
Pillwort, American
Pilularia americana
OR
Plant
BS
Pilot, Mason’s sky
Polemonium chartaceum
CA
Plant
BS
Pincushion cactus, Brady
Pediocactus bradyi
AZ
Plant
FE
Pincushion cactus, Cochise
Coryphantha robbinsorum
AZ
Plant
FT
Pincushion cactus, Kaibab
Pediocactus paradinei
AZ
Plant
BS
Pincushion cactus, Lee
Coryphantha sneedii var. leei
NM
Plant
FT
Pincushion cactus, Siler
Pediocactus sileri
AZ, UT
Plant
FT
Pincushion cactus, Sneed
Coryphantha sneedii var.
sneedii
NM
Plant
FE
Pincushion cactus, Villard’s
Escobaria villardii
CA, NM
Plant
BS
Pincushion, Blaine
Sclerocactus blainei
NV
Plant
BS
Pincushion, desert
Chaenactis stevioides
ID
Plant
BS
Pincushion, Schlesser
Sclerocactus schlesseri
NV
Plant
BS
Pincushion, Tonopah
Sclerocactus nyensis
NV
Plant
BS
Pine, limber
Pinus flexilis
WY
Plant
BS
Pine, Washoe
Pinus ponder osa var.
washoensis
NV
Plant
BS
Pine, whitebark
Pinus albicaulis
NV, WY
Plant
BS
Piperia, Yadon’s
Piperia yadonii
CA
Plant
FE
Pipistrelle, western
Pipistrellus hesperus
NV
Mammal
BS
Pipit, Sprague’s
An thus spragueii
AZ, CO, MT,
NM
Bird
BS
Pitcher-sage, Gander’s
Lepechinia ganderi
CA
Plant
BS
Plagiobothrys, Austin’s
Plagiobothrys austiniae
OR
Plant
BS
Plant, Death Valley sandpaper
Petalonyx thurberi
CA
Plant
BS
Plant, Dolores skeleton
Lygodesmia doloresensis
CO
Plant
BS
Plant, white-margined wax
Glyptopleura marginata
ID
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic K1S
E-53
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
, State1
Class
Status2
Plover, mountain
Charadrius montanus
A Z, CA, CO,
MT, NM, NV,
UT, WY
Bird
FP/BS
Plover, piping
Charadrius melodus
CO, MT, NM,
WY
Bird
FT
Plover, snowy
Charadrius alexandrinus
CO, UT
Bird
BS
Plover, western snowy
Charadrius nivosus nivosus
CA, OR
Bird
FT
Pogogyne, profuse-flowered
Pogogyne floribunda
CA, OR
Plant
BS
Polemonium, great
Polemonium carneum
OR
Plant
BS
Polemonium, skunk
Polemonium viscosum
OR
Plant
BS
Polemonium, Washington
Polemonium pectinatum
OR
Plant
BS
Polygonum, Scott’s Valley
Polygonum hickmanii
CA
Plant
FE
Polypore, blue-capped
Albatrellus flettii
CA
Plant
BS
Polypore, blue-pored
Albatrellus caeruleoporus
CA
Plant
BS
Pondweed, Rafinesque’s
Potamogeton diversifolius
OR
Plant
BS
Poolfish, Pahrump
Empetrichthys latos
NV
Fish
FE
Popcomflower, altered andesite
Plagiobothrys glomeratus
NV
Plant
BS
Popcomflower, Greene’s
Plagiobothrys greenei
OR
Plant
BS
Popcomflower, hooked
Plagiobothrys uncinatus
CA
Plant
BS
Popcomflower, rough
Plagiobothrys hirtus
OR
Plant
FE
Popcomflower, shiny-fmited
Plagiobothrys lamprocarpus
OR
Plant
BS
Popcomflower, slender-branched
Plagiobothrys leptocladus
MT
Plant
BS
Poppy, arctic
Papaver gorodkovii
AK
Plant
BS
Poppy, diamond-petaled
California
Eschscholzia rhombipetala
CA
Plant
BS
Poppy, gold
Eschscholzia caespitosa
OR
Plant
BS
Poppy, pale
Papaver alboroseum
AK
Plant
BS
Poppy, red rock
Eschscholzia minutiflora
CA
Plant
BS
Poppy, walpole
Papaver walpolei
AK
Plant
BS
Potentilla, Hickman’s
Potentilla hickmanii
CA
Plant
FE
Prairie dog, Arizona black-tailed
Cynomys ludovicianus
arizonensis
AZ, NM
Mammal
BS
Prairie dog, black-tailed
Cynomys ludovicianus
AZ, CO, ID,
MT, NM, WY
Mammal
C
Prairie dog, Gunnison’s
Cynomys gunnisoni
AZ, CO, UT
Mammal
C
Prairie dog, Utah
Cynomys parvidens
UT
Mammal
FT
Prairie dog, white-tailed
Cynomys leucurus
CO, MT, UT,
WY
Mammal
BS
Prairie-chicken, lesser
Tympanuchus pallidicinctus
CO, NM
Bird
FT
Prickly poppy
Argemone munita
OR
Plant
BS
Prickly poppy, Sacramento
Argemone pleiacantha
NM
Plant
FE
Primrose, alkali
Primula alcalina
ID, MT
Plant
BS
Primrose, arctic dwarf
Douglasia beringensis
AK
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-54
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Primrose, Chukchi
Primula tschuktschorum
AK
Plant
BS
Primrose, Greenland
Primula egaliksensis
CO
Plant
BS
Primrose, Maguire
Primula maguirei
UT
Plant
FT
Primrose, mealy
Primula incana
MT
Plant
BS
Pronghorn, Sonoran
Antilocapra americana
sonoriensis
AZ
Mammal
FE/XN
Pseudoscorpion, Malheur
Apochthonius malheuri
OR
Invertebrate
BS
Puffin, tufted
Fratercula cirrhata
OR
Bird
BS
Pupfish, Amargosa
Cyprinodon nevadensis
CA
Fish
BS
Pupfish, Ash Meadows
Amargosa
Cyprinodon nevadensis
mionectes
NV
Fish
FE
Pupfish, desert
Cyprinodon macularius
AZ, CA
Fish
FE
Pupfish, Devil’s Hole
Cyprinodon diabolis
NV
Fish
FE
Pupfish, Owens
Cyprinodon radiosus
CA
Fish
FE
Pupfish, Warm Springs
Cyprinodon nevadensis
pectoralis
NV
Fish
FE
Purpusia, rock
Ivesia arizonica
NV
Plant
BS
Pussypaws
Cistanthe sp.
CA
Plant
BS
Pussypaws, Mariposa
Calyptridium pulchellum
CA
Plant
FT
Pussypaws, rosy
Calyptridium roseum
OR
Plant
BS
Pussypaws, Santa Cruz
Mountains
Calyptridium parryi var.
hessiae
CA
Plant
BS
Pussytoes, dense-leaved
Antennaria densifolia
AK
Plant
BS
Pussytoes, meadow
Antennaria arcuata
ID, NV, WY
Plant
BS
Pussytoes, flat-top
Antennaria corymbosa
OR
Plant
BS
Pussytoes, Nuttall’s
Antennaria parvifolia
OR
Plant
BS
Pygmyleaf, sagebrush
Loeflingia squarrosa
NV
Plant
BS
Pyrg, bifid duct
Pyrgulopsis peculiaris
NV
Invertebrate
BS
Pyrg, carinate duckwater
Pyrgulopsis carinata
NV
Invertebrate
BS
Pyrg, Dixie Valley
Pyrgulopsis dixensis
NV
Invertebrate
BS
Pyrg, Duckwater
Pyrgulopsis aloha
NV
Invertebrate
BS
Pyrg, Duckwater Warm Springs
Pyrgulopsis villacampae
NV
Invertebrate
BS
Pyrg, elongate Cain Spring
Pyrgulopsis augusta
NV
Invertebrate
BS
Pyrg, flat-topped steptoe
Pyrgulopsis planulata
NV
Invertebrate
BS
Pyrg, Humboldt
Pyrgulopsis homboldtensis
NV
Invertebrate
BS
Pyrg, Landye’s
Pyrgulopsis landyei
NV
Invertebrate
BS
Pyrg, large-gland carico
Pyrgulopsis basiglans
NV
Invertebrate
BS
Pyrg, median gland Nevada
Pyrgulopsis pisteri
NV
Invertebrate
BS
Pyrg, Moapa Valley
Pyrgulopsis carinifera
NV
Invertebrate
BS
Pyrg, northern Soldier Meadow
Pyrgulopsis militaris
NV
Invertebrate
BS
Pyrg, Oasis Valley
Pyrgulopsis micrococcus
NV
Invertebrate
BS
Pyrg, ovate Cain Spring
Pyrgulopsis pictilis
NV
Invertebrate
BS
Pyrg, southeast Nevada
Pyrgulopsis turbatrix
NV
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-55
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Pyrg, southern Duckwater
Pyrgulopsis anatina
NV
Invertebrate
BS
Pyrg, southern Soldier Meadow
Pyrgulopsis umbilicata
NV
Invertebrate
BS
Pyrg, southern steptoe
Pyrgulopsis sulcata
NV
Invertebrate
BS
Pyrg, Spring Mountains
Pyrgulopsis deaconi
NV
Invertebrate
BS
Pyrg, Squat Mud Meadows
Pyrgulopsis limaria
NV
Invertebrate
BS
Pyrg, sub-globose Steptoe Ranch
Pyrgulopsis orbiculata
NV
Invertebrate
BS
Pyrg, tranverse gland
Pyrgulopsis cruciglans
NV
Invertebrate
BS
Pyrg, vinyards
Pyrgulopsis vinyardi
NV
Invertebrate
BS
Pyrg, Wong’s
Pyrgulopsis wongi
NV
Invertebrate
BS
Pyrrocoma, racemose
Pyrrocoma racemosa
OR
Plant
BS
Pyrrocoma, sticky
Pyrrocoma lucida
CA
Plant
BS
Quail, mountain
Oreortyx pictus
OR
Bird
BS
Queen-of-the- forest
Filipendula occidentalis
OR, WY
Plant
BS
Quillwort, Nuttall’s
Isoetes nuttallii
OR
Plant
BS
Rabbit, pygmy
Brachylagus idahoensis
CA, ID, MT,
NV, OR, UT,
WY
Mammal
BS, FE
Rabbit, riparian brush
Sylvilagus bachmani
CA
Mammal
FE
Rabbitbrush, centennial
Chrysothamnus parryi
ID
Plant
BS
Rabbitbrush, Guadalupe
Chrysothamnus nauseosus
NM
Plant
BS
Ragwort, cut-leaved
Packera eurycephala
CA
Plant
BS
Ragwort, few flowered
Packera pauciflora
CO
Plant
BS
Ragwort, red hills
Packera clevelandii
CA
Plant
BS
Ragwort, western
Packera hesperia
OR
Plant
BS
Rail, California black
Laterallus jamaicensis
AZ, CA
Bird
BS
Rail, California clapper
Rallus longirostris obsoletus
CA
Bird
FE
Rail, light-footed clapper
Rallus longirostris levipes
CA
Bird
FE
Rail, Virginia
Rallus limicola
OR
Bird
BS
Rail, yellow
Coturnicops noveboracensis
OR, MT
Bird
BS
Rail, Yuma clapper
Rallus longirostris
yumanensis
AZ, CA, NV
Bird
FE
Raillardella, Muir’s
Carlquistia muirii
CA
Plant
BS
Raillardella, showy
Raillardella pringlei
CA
Plant
BS
Ramalina, dusty
Ramalina pollinaria
CA, OR
Plant
BS
Ramshom, Borax Lake
Planorbella oregonensis
NM
Invertebrate
BS
Ramshom, Great Basin
Helisoma newberryi
OR
Invertebrate
BS
Rasberry, northwest
Rubus nigerrimus
OR
Plant
BS
Rattlesnake, midget faded
Crotalus viridis
CO, WY
Reptile
BS
Rattlesnake, Mojave
Crotalus scutulatus
UT
Reptile
BS
Rattlesnake, New Mexican
ridge-nosed
Crotalus wil/ardi obscurus
AZ, NM
Reptile
FT
Rattlesnake, southwestern
speckled
Crotalus mitchellii pyrrhus
UT
Reptile
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-56
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Rattlesnake, speckled
Crotalus mitchellii mitchellii
UT
Reptile
BS
Red knot
Calidris canutus
AK
Bird
BS
Redberry
Rhamnus ilicifolia
OR
Plant
BS
Reedgrass, Brewer’s
Calamagrostis breweri
OR
Plant
BS
Reedgrass, Cascade
Calamagrostis tweedyi
ID
Plant
BS
Reedgrass, leafy
Calamagrostis foliosa
CA
Plant
BS
Reed-mustard, Bameby
Schoenocrambe barnebyi
ID, UT
Plant
FE
Reed-mustard, clay
Schoenocrambe argillacea
NM, UT
Plant
FT
Reed-mustard, shrubby
Schoenocrambe suffrutescens
CA, UT
Plant
FE
Ricegrass, little
Oryzopsis exigua
CA
Plant
BS
Ricegrass, small -flowered
Oryzopsis micranthum
ID
Plant
BS
Ricegrass, Wallowa
Achnatherum wallowensis
OR
Plant
BS
Ridge-cress, Bameby
Lepidium barnebyanum
UT
Plant
FE
Riffle beetle, Stephan’s
Heterelmis stephani
AZ
Invertebrate
C
Ringstem, sticky
Anulocaulis leiosolenus
NV
Plant
BS
Ringtail
Bassariscus astutus
NM, UT
Mammal
BS
Roach, pit
Lavinia symmetricus mitrulus
OR
Fish
BS
Roach, Red Hills
Lavinia symmetricus ssp.
CA
Fish
BS
Rockbrake, Steller’s
Cryptogramma stelleri
CO, OR
Plant
BS
Rockcress, Bodie Hills
Boechera bodiensis
NV
Plant
BS
Rockcress, Crandall
Arabis crandallii
CO
Plant
BS
Rockcress, Crater Lake
Arab is suffrutescens
CA, OR
Plant
BS
Rockcress, cross-haired
Arabis crucisetosa
OR
Plant
BS
Rockcress, Daggett
Arabis demissa
MT
Plant
BS
Rockcress, Darwin
Arabis pulchra
CA
Plant
BS
Rockcress, Elko
Boechera falcifructa
NV
Plant
BS
Rockcress, Fremont County
Boechera pusilla
WY
Plant
C
Rockcress, Hoffmann’s
Arabis hoffmannii
CA
Plant
FE
Rockcress, Koehler’s
Arabis koehleri
OR
Plant
BS
Rockcress, low northern
Braya humilis
MT
Plant
BS
Rockcress, McDonald’s
Arabis macdonaldiana
CA, OR
Plant
FE
Rockcress, park
Arabis fernaldiana
CO
Plant
BS
Rockcress, Santa Cruz Island
Sibara filifolia
CA
Plant
FE
Rockcress, sapphire
Arabis fecunda
MT
Plant
BS
Rockcress, sickle-pod
Arabis spars (flora
OR
Plant
BS
Rockcress, small
Arabis pusilla
WY
Plant
BS
Rock-daisy, black
Townsendia smithii
AZ
Plant
BS
Rock-daisy, Clifton
Perityle ambrosiifolia
AZ
Plant
BS
Rock-daisy, nodding
Perityle cernua
NM, WY
Plant
BS
Rock-jasmine, Alaska
Douglasia alaskana
AK
Plant
BS
Rockmat, Chelan
Petrophyton cinerascens
OR
Plant
BS
Rock-rose, Mount Diablo
Helianthella castanea
CA
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-57
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Rose, Grand Canyon
Rosa stellata
AZ
Plant
BS
Rosewood, Arizona Sonoran
Vauquelinia californica ssp.
californica
AZ
Plant
BS
Rosewood, limestone
Vauquelinia californica ssp.
pauciflora
NM
Plant
BS
Rosy-finch, black
Leucosticte atrata
NV, OR
Bird
BS
Rupertia, Hall’s
Rupertia hallii
CA
Plant
BS
Rush, Howell’s
Juncus howellii
OR
Plant
BS
Rush, Kellog’s
J uncus kelloggii
OR
Plant
BS
Rush, Red Bluff dwarf
Juncus leiospermus
CA
Plant
BS
Rush, three-flowered
Juncus triglumis
OR
Plant
BS
Rush, Tiehm’s
Juncus tiehmii
OR
Plant
BS
Rush, twelfth
Juncus uncialis
OR
Plant
BS
Rush-lily, large-flowered
Hastingsia bracteosa
OR
Plant
BS
Rush-lily, purple-flowered
Hastingsia bracteosa var.
atropurpurea
OR
Plant
BS
Rush-rose, island
Helianthemum greenei
CA
Plant
FT
Sabine-grass
Pleuropogon sabinei
AK
Plant
BS
Sage, American wood
Teucrium canadense
ID
Plant
BS
Sage, aravaipa
Salvia amissa
AZ
Plant
BS
Sage, arctic
Artemisia scnjavinensis
AK
Plant
BS
Sage, chicken
Sphaeromeria argcntca
MT
Plant
BS
Sage, Death Valley
Salvia funerea
NV
Plant
BS
Sage, Orocopia
Salvia greatae
CA
Plant
BS
Sagebrush, Lahontan
Artemisia arbuscula ssp.
longicaulis
OR
Plant
BS
Sagebrush, Laramie false
Sphaeromeria simplex
WY
Plant
BS
Sagebrush, Owyhee
Artemisia papposa
OR
Plant
BS
Sagebrush, Porter’s
Artemisia porteri
WY
Plant
BS
Sage-grouse, greater
Centrocercus urophasianus
CA, CO, ID,
MT, NV, OR,
UT, WY
Bird
PT
Sage-grouse, Gunnison
Centrocercus minimus
CO, UT
Bird
PE
Sagewort, coastal
Artemisia pycnocephala
OR
Plant
BS
Salamander, black
Aneides flavipunctatus
OR
Amphibian
BS
Salamander, California slender
Batrachoseps attenuatus
OR
Amphibian
BS
Salamander, California tiger
Ambystoma californiense
CA
Amphibian
FE/FT
Salamander, Cascade torrent
Rhyacotriton cascadae
OR
Amphibian
BS
Salamander, Coeur D’Alene
Plethodon idahoensis
ID, MT
Amphibian
BS
Salamander, Columbia torrent
Rhyacotriton kezeri
OR
Amphibian
BS
Salamander, Cope’s giant
Dicamptodon copei
OR
Amphibian
BS
Salamander, desert slender
Batrachoseps aridus
CA
Amphibian
FE
Salamander, Inyo Mountains
slender
Batrachoseps campi
CA
Amphibian
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-58
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Salamander, Jemez Mountains
Plethodon neomexicanus
NM
Amphibian
C
Salamander, Larch Mountain
Plethodon larselli
OR
Amphibian
BS
Salamander, limestone
Hydromantes brunus
CA
Amphibian
BS
Salamander, Olympic torrent
Rhyacotriton olympicus
OR
Amphibian
BS
Salamander, Oregon slender
Batrachoseps wrighti
OR
Amphibian
BS
Salamander, Santa Cruz long¬
toed
Ambystoma macrodactylum
CA
Amphibian
FE
Salamander, Shasta
Hydromantes shastae
CA
Amphibian
BS
Salamander, Siskiyou Mountains
Plethodon storm i
OR
Amphibian
BS
Salamander, Sonora tiger
Ambystoma tigrinum
stebbinsi
AZ
Amphibian
FE
Salamander, Tehachapi slender
Batrachoseps stebbinsi
CA
Amphibian
BS
Salamander, Van Dyke’s
Plethodon vandykei
OR
Amphibian
BS
Salamander, yellow-blotched
Ensatina eschscholtzi
CA
Amphibian
BS
Sallfly, Alaska
Alaskaperla ovibovis
AK
Invertebrate
BS
Salmon, Chinook (California
Coastal ESU3)
Oncorhynchus tshawytscha
CA
Fish
FT
Salmon, Chinook (Central
Valley Spring-run ESU)
Oncorhynchus tshawytscha
CA
Fish
FT
Salmon, Chinook (Lower
Columbia River ESU)
Oncorhynchus tshawytscha
OR
Fish
FT
Salmon, Chinook (Sacramento
River Winter-run ESU)
Oncorhynchus tshawytscha
CA, OR
Fish
FE
Salmon, Chinook (Snake River
Fall-run ESU)
Oncorhynchus tshawytscha
ID, OR
Fish
FT
Salmon, Chinook (Snake River
Spring/Summer-run ESU)
Oncorhynchus tshawytscha
ID, OR
Fish
FT
Salmon, Chinook (Upper
Columbia River Spring-run
ESU)
Oncorhynchus tshawytscha
OR
Fish
FE
Salmon, Chinook (Upper
Willamette River ESU)
Oncorhynchus tshawytscha
OR
Fish
FT
Salmon, chum (California
Coastal ESU)
Oncorhynchus keta
OR
Fish
BS
Salmon, chum (Columbia River
ESU)
Oncorhynchus keta
OR
Fish
FT
Salmon, chum (Hood Canal
Summer-run ESU)
Oncorhynchus keta
OR
Fish
FT
Salmon, coho (Central California
Coast ESU)
Oncorhynchus kisutch
CA, OR
Fish
FE
Salmon, coho (Lower Columbia
River ESU)
Oncorhynchus kisutch
OR
Fish
FT
Salmon, coho (Oregon Coast
ESU)
Oncorhynchus kisutch
OR
Fish
FT
BLM Vegetation Treatments Three New Herbicides
Final Programmatic FIS
E-59
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
, State1
Class
Status2
Salmon, coho (Southern
Oregon/Northem California
ESU)
Oncorhynchus kisutch
CA, OR
Fish
FT
Salmon, fall Chinook
Oncorhynchus tshawytscha
OR
Fish
BS
Salmon, sockeye (Snake River,
Idaho ESU)
Oncorhynchus nerka
ID, OR
Fish
FE
Saltbush, Griffith’s
Atriplex griffithsii
NM
Plant
BS
Saltbush, heart-leaved
Atriplex cordulata
CA
Plant
BS
Saltbush, Lost Hills
Atriplex vallicola
CA
Plant
BS
Sandfood
Pholisma sonorae
AZ, CA
Plant
BS
Sandfood, scaly
Pholisma arenaria
AZ
Plant
BS
Sandpiper, Bering Sea rock
Calidris ptilocnemis
AK
Bird
BS
Sandpiper, upland
Bartramia longicauda
ID, OR
Bird
BS
Sand-verbena, chaparral
Abronia umbellata var. aurita
CA
Plant
BS
Sand-verbena, pink
Abronia umbellata var.
brevifolia
CA, OR
Plant
BS
Sand-verbena, Ramshaw
Meadows
Abronia alpina
CA
Plant
C
Sandwort, Bear Valley
Arenaria ursina
CA
Plant
FT
Sandwort, Howell’s
Minuartia howellii
CA
Plant
BS
Sandwort, Lassie’s
Minuartia decumbens
CA
Plant
BS
Sandwort, marsh
Arenaria paludicola
CA, OR
Plant
FE
Sandwort, Nuttall’s
Minuartia nuttallii
CO
Plant
BS
Sandwort, Scott Mountain
Minuartia stolonifera
CA
Plant
BS
Sanicle, rock
Sanicula saxatilis
CA
Plant
BS
Sanicle, Tracy’s
Sanicula tracyi
CA
Plant
BS
Saniclef, Sierra
Sanicula graveolens
ID
Plant
BS
Sapsucker, red-naped
Sphyrapicus nuchalis
ID
Bird
BS
Sapsucker, Williamson’s
Sphyrapicus thryoideus
ID
Bird
BS
Sauger
Stizostedion canadense
MT
Fish
BS
Saw-wort, Weber
Saussurea weberi
CO
Plant
BS
Saxifrage, joint-leaved
Saxifragopsis fragarioides
OR
Plant
BS
Saxifrage, nodding
Saxifraga cernua
OR
Plant
BS
Saxifrage, wedge-leaf
Saxifraga adscendens
OR
Plant
BS
Scalebroom, gypsum
Lepidospartum burgessii
NM
Plant
BS
Scarab, aegialian
Aegialia knighti
NV
Invertebrate
BS
Scarab, big dune aphodius
Aphodius sp.
NV
Invertebrate
BS
Scarab, Ciervo aegialian
Aegialia concinna
CA
Invertebrate
BS
Scarab, Crescent Dunes aegialian
Aegialia crescenta
NV
Invertebrate
BS
Scarab, Crescent Dunes aphodius
Aphodius sp.
NV
Invertebrate
BS
Scarab, Crescent Dunes serican
Serica ammoomenisco
NV
Invertebrate
BS
Scarab, Guiliani’s dune
Pseudocotalpa guilianii
NV
Invertebrate
BS
Scarab, Hardy’s aegialian
Aegialia hardy i
NV
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-60
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Scarab, Humboldt serican
Serica humboldti
NV
Invertebrate
BS
Scarab, large aegialian
Aegialia magnified
NV
Invertebrate
BS
Scarab, Sand Mountain aphodius
Aphodius sp.
NV
Invertebrate
BS
Scarab, Sand Mountain serican
Serica psamnohunus
NV
Invertebrate
BS
Scarlet-gilia, Weber’s
Ipomopsis aggregate
WY
Plant
BS
Scheuchzeria
Scheuchzeria palustris
OR
Plant
BS
Scorpionflower, Beatley
Phacelia heatleyae
NV
Plant
BS
Sculpin, Malheur mottled
Cottus hendirei
OR
Fish
BS
Sculpin, margined
Cottus marginatus
OR
Fish
BS
Sculpin, pit
Cottus pitensis
OR
Fish
BS
Sculpin, rough
Cottus asperrimus
CA
Fish
BS
Sculpin, Shoshone
Cottus greenei
ID
Fish
BS
Sculpin, Wood River
Cottus leiopomus
ID
Fish
BS
Scurfpea, three-nerved
Pediomelum trinervatum
AZ
Plant
BS
Sea turtle, green
Chelonia mydas
CA, OR
Reptile
FT
Sea turtle, leatherback
Dermochelys coriacea
AK, CA, OR
Reptile
FE
Sea turtle, loggerhead
Caretta caretta
CA, OR
Reptile
FT
Sea turtle, Olive Ridley
Lepidochelys olivacea
CA
Reptile
FT
Seablite, California
Suaeda californica
CA
Plant
FE
Seal, Guadalupe fur
Arctocephalus townsendi
CA
Mammal
FT
Sea-lion, Steller
Eumetopias jubatus
AK, CA, OR
Mammal
FT/FE
Sea-purslane, verrucose
Sesuvium verrucosum
OR
Plant
BS
Sedge, abrupt-beaked
Carex abrupta
OR
Plant
BS
Sedge, Alaskan single-spiked
Carex scirpoidea
OR
Plant
BS
Sedge, beaked
Carex rostrata
OR
Plant
BS
Sedge, blackened
Carex atrosquama
OR
Plant
BS
Sedge, blunt
Carex obtusata
OR
Plant
BS
Sedge, bristly
Carex comosa
ID, OR
Plant
BS
Sedge, Buxbaum’s
Carex buxbaumii
ID
Plant
BS
Sedge, Canadian single-spike
Carex scirpoidea ssp.
scirpoidea
CO, OR
Plant
BS
Sedge, capitate
Carex capitata
OR
Plant
BS
Sedge, circumpolar
Carex adelostoma
AK
Plant
BS
Sedge, coiled
Carex circinata
OR
Plant
BS
Sedge, Constance’s
Carex constanceana
OR
Plant
BS
Sedge, Cordilleran
Carex cordillerana
OR
Plant
BS
Sedge, Crawford’s
Carex crawford ii
OR
Plant
BS
Sedge, Craw’s
Carex crawei
MT
Plant
BS
Sedge, dark alpine
Carex subnigricans
OR
Plant
BS
Sedge, few-flowered
Carex paucifiora
OR
Plant
BS
Sedge, foothill
Carex tumulicola
ID
Plant
BS
Sedge, giant
Carex spissa
AZ
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-61
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Sedge, green
Carex viridula
CO
Plant
BS
Sedge, hairlike
Carex capillaris
OR
Plant
BS
Sedge, hairy
Carex gynodynama
OR
Plant
BS
Sedge, Idaho
Carex idahoa
ID, MT, OR
Plant
BS
Sedge, Indian Valley
Carex arboriginum
ID
Plant
BS
Sedge, intermediate
Carex media
OR
Plant
BS
Sedge, Klamath
Carex klamathensis
CA, OR
Plant
BS
Sedge, large-awn
Carex macrochaeta
OR
Plant
BS
Sedge, lesser panicled
Carex diandra
OR
Plant
BS
Sedge, long-styled
Carex stylosa
OR
Plant
BS
Sedge, low northern
Carex concinna
CO
Plant
BS
Sedge, many-headed
Carex sychnocephala
OR
Plant
BS
Sedge, Mount Shasta
Carex straminiformis
ID
Plant
BS
Sedge, native
Carex vernacula
OR
Plant
BS
Sedge, Navajo
Carex specuicola
AZ, UT
Plant
FT
Sedge, new
Carex pelocarpa
OR
Plant
BS
Sedge, pale
Carex livida
CO, ID, OR
Plant
BS
Sedge, Parry’s
Carex parryana
ID
Plant
BS
Sedge, poor
Carex magellanica
OR
Plant
BS
Sedge, Pyrenaean
Carex pyrenaica
OR
Plant
BS
Sedge, retrorse
Carex retrorsa
OR
Plant
BS
Sedge, San Luis Obispo
Carex obispoensis
CA
Plant
BS
Sedge, saw-tooth
Carex serratodens
OR
Plant
BS
Sedge, short stemmed
Carex brevicaulis
OR
Plant
BS
Sedge, Sierra nerved
Carex nervina
OR
Plant
BS
Sedge, simple bog
Kobresia simpliciuscula
MT, OR
Plant
BS
Sedge, Siskiyou
Carex scabriuscula
OR
Plant
BS
Sedge, slender
Carex lasiocarpa
OR
Plant
BS
Sedge, small-winged
Carex stenoptila
MT
Plant
BS
Sedge, Smokey Mountain
Carex proposita
OR
Plant
BS
Sedge, sparse-leaved
Carex tenuijlora
OR
Plant
BS
Sedge, spikenard
Carex nardina
OR
Plant
BS
Sedge, string-root
Carex chordorrhiza
ID, OR
Plant
BS
Sedge, valley
Carex vallicola
OR
Plant
BS
Sedge, western
Carex occidentalis
ID
Plant
BS
Sedge, white
Carex albida
CA
Plant
FE
Sedge, yellow
Carex flava
CO
Plant
BS
Sedge, yellow bog
Carex dioica
OR
Plant
BS
Sedge, yellow-flowered
Carex anthoxanthea
OR
Plant
BS
Semaphoregrass, Oregon
Pleuropogon oregonus
OR
Plant
BS
Senecio, Ertter’s
Senecio ertterae
OR
Plant
BS
Sheep, bighorn
Ovis canadensis
NV
Mammal
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-62
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Sheep, California bighorn
Ovis canadensis californiana
ID
Mammal
BS
Sheep, desert bighorn
Ovis canadensis mexicana
CA, CO
Mammal
BS
Sheep, peninsular bighorn
Ovis canadensis nelsoni
CA
Mammal
FE
Sheep, Sierra Nevada bighorn
Ovis canadensis sierrae
CA
Mammal
FE
Shield-fern, crested
Dryopteris cristata
OR
Plant
BS
Shiner, Arkansas River
Notropis girardi
NM
Fish
FT
Shiner, beautiful
Cyprinella formosa
AZ, NM
Fish
FT
Shiner, Lahontan redside
Richardsonius egregius
OR
Fish
BS
Shiner, Pecos bluntnose
Notropis simus pecosensis
NM
Fish
FT
Shiner, river
Notropis blennius
CO
Fish
BS
Shootingstar, darkthroat
Dodecatheon pulchellum
OR
Plant
BS
Shootingstar, frigid
Dodecatheon austrofrigidum
OR
Plant
BS
Shoshonea
Shoshonea pulvinata
MT, WY
Plant
BS
Shrew, Alaskan tiny
Sorex yukonicus
AK
Mammal
BS
Shrew, Arizona
Sorex arizonae
NM
Mammal
BS
Shrew, Buena Vista Lake ornate
Sorex ornatus relictus
CA
Mammal
FE
Shrew, dwarf
Sorex nanus
UT
Mammal
BS
Shrew, Merriam’s
Sorex merriami
MT
Mammal
BS
Shrew, Preble’s
Sorex preblei
MT, NV, OR,
UT
Mammal
BS
Shrew, pygmy
Sorex hoyi
OR
Mammal
BS
Shrike, loggerhead
Lanius ludovicianus
AZ, ID, MT,
NM, NV, WY
Bird
BS
Shrike, San Clemente loggerhead
Lanius ludovicianus
CA
Bird
FE
Shrimp, California freshwater
Syncaris pacifica
CA
Invertebrate
FE
Shrimp, vernal pool tadpole
Lepidurus packardi
CA
Invertebrate
FE
Shrub, northern moon
Dendriscocaulon intricatulum
CA
Plant
BS
Sidalcea, bristly-stemmed
Sidalcea hirtipes
OR
Plant
BS
Sideband (snail), Columbia
Monadenia fidelis
Columbiana
OR
Invertebrate
BS
Sideband (snail), Deschutes
Monadenia fidelis ssp.
OR
Invertebrate
BS
Sideband (snail), green
Monadenia fidelis beryllica
OR
Invertebrate
BS
Sideband (snail), keeled
Monadenia circumcarinata
CA
Invertebrate
BS
Sideband (snail), Modoc rim
Monadenia fidelis ssp.
OR
Invertebrate
BS
Sideband (snail), Oregon/Dalles
Monadenia fidelis minor
OR
Invertebrate
BS
Sideband (snail), travelling
Monadenia fidelis celeuthia
OR
Invertebrate
BS
Sidewinder, Mojave Desert
Crotalus cerastes
NV, UT
Reptile
BS
Siidalcea, maple-leaved
Sidalcea malachroides
OR
Plant
BS
Silene, Seely’s
Silene seelyi
OR
Plant
BS
Silverberry, American
Elaeagnus commutata
ID
Plant
BS
Silverscale, Pahrump
A triplex argentea
NV
Plant
BS
Silverspot, Carson Valley
Speyeria nokomis carsonensis
NV
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-63
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
, State1
Class
Status2
Skeletonweed, thorn
Stephanomeria spinosa
MT
Plant
BS
Skeleton weed, Wheeler’s
Chaetadelpha wheeleri
OR
Plant
BS
Skink, Arizona
Eumeces gilberti
AZ
Reptile
BS
Skink, Coronado
Eumeces skiltonianus
interparietalis
CA
Reptile
BS
Skink, many-lined
Eumeces multivirgatus
UT
Reptile
BS
Skipper, Carson wandering
Pseudocopaeodes eunus
obscurus
CA, NV
Invertebrate
FE
Skipper, Dakota
Hesperia dacotae
MT
Invertebrate
BS
Skipper, Laguna Mountains
Pyrgus ruralis lagunae
CA
Invertebrate
FE
Skipper, Macneill sooty wing
Hesperopsis gracielae
AZ, NV
Invertebrate
BS
Skipper, Mardon
Polites mardon
CA, NM, OR
Invertebrate
C
Skipper, Mono Basin
Hesperia uncas giulianii
NV
Invertebrate
BS
Skipper, Pawnee montane
Hesperia leonardus montana
CO
Invertebrate
FT
Skipper, Railroad Valley
Hesperia uncas fulvapalla
NV
Invertebrate
BS
Skipper, Spring Mountain
comma
Hesperia comma ssp.
NV
Invertebrate
BS
Skipper, White Mountain
Hesperia miriamae
longaevicola
NV
Invertebrate
BS
Skipper, White River Valley
Hesperia uncas grandiosa
NV
Invertebrate
BS
Skipper, Yuma
Ochlodes yuma
OR
Invertebrate
BS
Skullcap, dwarf
Scutellaria nana
ID
Plant
BS
Skullcap, Holmgren’s
Scutellaria holmgreniorum
CA
Plant
BS
Skunk, spotted
Spilogale putorius
MT
Mammal
BS
Skyrocket, Pagosa
Ipomopsis polyantha
CO
Plant
FE
Slug, salamander
Gliabates oregonius
OR
Invertebrate
BS
Smelowskia, Johnson’s
Smelowskia johnsonii
AK
Plant
BS
Smelowskia, Holmgren
Smelowskia holmgrenii
NV
Plant
BS
Smelowskia, pearshaped
Smelowskia pyriformis
AK
Plant
BS
Smelt, delta
Hypomesus transpacificus
CA
Fish
FT
Snail, Big Bar hesperian
Vespericola pressleyi
CA
Invertebrate
BS
Snail, Bliss Rapids
Taylorconcha serpenticola
AZ, ID
Invertebrate
FT
Snail, Dona Ana talus
Sonorella todseni
NM
Invertebrate
BS
Snail, Hell’s Canyon land
Cryptomastix populi
OR
Invertebrate
BS
Snail, Hirsute Sierra sideband
Monadenia mormonum
CA
Invertebrate
BS
Snail, Morro shoulderband
Helminthoglypta walkeriana
CA
Invertebrate
FE
Snail, Newcomb’s littorine
Algamorda newcombiana
OR
Invertebrate
BS
Snail, Oregon shoulderband
Helminthoglypta hertleini
CA, OR
Invertebrate
BS
Snail, Pecos assiminea
Assiminea pecos
NM
Invertebrate
FE
Snail, Rosement talus
Sonorella rosemontensis
AZ
Invertebrate
C
Snail, Siskiyou shoulderband
Monadenia chaceana
CA, OR
Invertebrate
BS
Snail, Snake River physa
Physa natricina
ID
Invertebrate
FE
Snail, Tehama chaparral
Trilobopsis tehamana
CA
Invertebrate
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-64
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Snail, Trinity shoulderband
Helminthoglypta talmadgei
CA
Invertebrate
BS
Snail, Tuolumne sideband
Monadenia tuolumneana
CA
Invertebrate
BS
Snail, Utah valvata
Valvata utahensis
ID, UT
Invertebrate
BS
Snails, succineid
All species in family
Succineidae
A Z
Invertebrate
BS
Snake, desert glossy
Arizona elegans
NV
Reptile
BS
Snake, giant garter
Thamnophis gigas
CA
Reptile
FT
Snake, Great Plains rat
Elaphe guttata emoryi
UT
Reptile
BS
Snake, longnose
Rhinocheilus lecontei
ID
Reptile
BS
Snake, milk
Lampropeltis triangulum
CO, MT, UT
Reptile
BS
Snake, Mojave patch-nosed
Salvadora hexalepis
UT
Reptile
BS
Snake, Mojave shovel-nosed
Chionactis occipitalis
occipitalis
NV
Reptile
BS
Snake, narrow-headed garter
Thamnophis rufipunctatus
AZ, MN
Reptile
FT
Snake, Nevada shovel-nosed
Chionactis occipitalis talpina
NV
Reptile
BS
Snake, night
Hypsiglena torquata
OR
Reptile
BS
Snake, northern Mexican garter
Thamnophis eques megalops
AZ, NM
Reptile
FT
Snake, painted desert glossy
Arizona elegans
UT
Reptile
BS
Snake, ringneck
Diadophis punctatus
ID
Reptile
BS
Snake, San Francisco garter
Thamnophis sirtalis
CA
Reptile
FE
Snake, sharptail
Contia tenuis
OR
Reptile
BS
Snake, smooth green
Opheodrys vernalis
UT
Reptile
BS
Snake, Sonoran lyre
Trimorphodon biscutatus ssp.
lambda
UT
Reptile
BS
Snake, Tucson shovel-nosed
Chionactis occipitalis
klauberi
AZ
Reptile
C
Snake, two-striped garter
Thamnophis hammondii
CA
Reptile
BS
Snake, Utah blind
Leptotphlops humilis
UT
Reptile
BS
Snake, western ground
Sonora semiannulata
ID
Reptile
BS
Snake, western hog-nosed
Heterodon nasicus
MT
Reptile
BS
Snake-root, black
Sanicula marilandica
OR
Plant
BS
Snakeweed, Lone Mesa
Gutierrezia elegans
CO
Plant
BS
Snapdragon, dimorphic
Antirrhinum subcordatum
CA
Plant
BS
Snowberry, creeping
Gaultheria hispidula
OR
Plant
BS
Snowberry, long-flowered
Symphoricarpos longiflorus
OR
Plant
BS
Snow-wreath, Shasta
Neviusia cliftonii
CA
Plant
BS
Soaproot, dwarf
Chlorogalum pomeridianum
CA
Plant
BS
Soaproot, Red Hills
Chlorogalum grandiflorum
CA
Plant
BS
Softshell, spiny
Apalone spinifera
MT
Reptile
BS
Sorrel, Cape Krause
Rumex krausei
AK
Plant
BS
Sorrel, grassleaf
Rumex graminifolius
AK
Plant
BS
Spadefoot, Great Basin
Spea intermontana
CO, WY
Amphibian
BS
Spadefoot, plains
Spea bombifrons
MT
Amphibian
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-65
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
, State1
Class
Status2
Sparrow, Arizona grasshopper
Ammodramus savannarum
AZ
Bird
BS
Sparrow, Baird’s
Ammodramus bairdii
MT, NM, WY
Bird
BS
Sparrow, black-throated
Amphispiza bilineata
OR
Bird
BS
Sparrow, Botteri’s
Peucaea botterii
AZ
Bird
BS
Sparrow, Brewer’s
Spizella breweri
CO, ID, MT,
NV, WY
Bird
BS
Sparrow, grasshopper
Ammodramus savannarum
ID, OR, UT
Bird
BS
Sparrow, large-billed savannah
Passerculus sandwichensis
AZ
Bird
BS
Sparrow, Leconte’s
Ammodramus leconteii
MT
Bird
BS
Sparrow, Nelson’s sharp-tailed
Ammodramus nelsoni
MT
Bird
BS
Sparrow, Oregon vesper
Pooecetes gramineus
OR
Bird
BS
Sparrow, sage
Amphispiza belli
ID, MT, OR,
WY
Bird
BS
Sparrow, San Clemente sage
Amphispiza belli
CA
Bird
FT
Spectaclepod, beach
Dithyrea maritima
CA
Plant
BS
Spider-flower, many-stemmed
Cleome multicaulis
CO, WY
Plant
BS
Spikedace
Meda fulgida
AZ, NM
Fish
FE
Spikerush, beaked
Eleocharis rostellata
MT
Plant
BS
Spikerush, Bolander’s
Eleocharis bolanderi
OR
Plant
BS
Spinedace, Big Spring
Lepidomeda mollispinis
pratensis
NV
Fish
FT
Spinedace, little Colorado
Lepidomeda vittata
AZ
Fish
FT
Spinedace, Virgin
Lepidomeda mollispinis
AZ, NV, UT
Fish
BS
Spinedace, White River
Lepidomeda albivallis
NV
Fish
FE
Spineflower, Ben Lomond
Chorizanthe pungens var.
hartwegiana
CA
Plant
FE
Spineflower, Brewer’s
Chorizanthe breweri
CA
Plant
BS
Spineflower, Howell’s
Chorizanthe howellii
CA
Plant
FE
Spineflower, Indian Valley
Aristocapsa ins ignis
CA
Plant
BS
Spineflower, Monterey
Chorizanthe pungens var.
pungens
CA, CO
Plant
FT
Spineflower, Orcutt’s
Chorizanthe orcuttiana
CA
Plant
FE
Spineflower, Parry’s
Chorizanthe parryi var.
parryi
CA
Plant
BS
Spineflower, robust
Chorizanthe robusta var.
robusta
CA
Plant
FE
Spineflower, San Benito
Chorizanthe biloba
CA
Plant
BS
Spineflower, San Fernando
Valley
Chorizanthe parryi var.
fernandina
CA
Plant
C
Spineflower, slender-horned
Dodecahema leptoceras
CA
Plant
FE
Spineflower, Sonoma
Chorizanthe valida
CA
Plant
FE
Spineflower, straight-awned
Chorizanthe rectispina
CA
Plant
BS
Spirea, subalpine
Spiraea splendens
OR
Plant
BS
Spleenwort, Dalhouse
Asplenium dalhousiae
AZ
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-66
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Spleenwort, green
Asplenium trichomanes-
ramosum
CO, ID, OR
Plant
BS
Splittail, Sacramento
Pogonichthys macrolepidotus
CA
Fish
FT
Springbeauty, arctic
Claytonia arctica
AK
Plant
BS
Springfish, Hiko White River
Crenichthys baileyi grandis
NV
Fish
FE
Springfish, Moapa White River
Crenichthys baileyi moapae
NV
Fish
BS
Springfish, Railroad Valley
Crenichthys nevadae
NV
Fish
FT
Springfish, White River
Crenichthys baileyi baileyi
NV
Fish
FE
Springparsley, snowline
Cymopterus nivalis
OR
Plant
BS
Springparsley, Uinta basin
Cymopterus duchesnensis
CO
Plant
BS
Springsnail, alamosa
Tryonia alamosae
NM
Invertebrate
FE
Springsnail, Bruneau Hot
Pyrgulopsis bruneauensis
ID, MT, WY
Invertebrate
FE
Springsnail, Byla’s
Pyrgulopsis arizonae
AZ
Invertebrate
BS
Springsnail, Chupadera
Pyrgulopsis chupaderae
NM
Invertebrate
C
Springsnail, Crooked Creek
Pyrgulopsis intermedia
OR
Invertebrate
BS
Springsnail, crystal
Pyrgulopsis crystalis
NV
Invertebrate
BS
Springsnail, desert
Pyrgulopsis deserta
AZ
Invertebrate
BS
Springsnail, distal gland
Pyrgulopsis nanus
NV
Invertebrate
BS
Springsnail, elongate gland
Pyrgulopsis isolatus
NV
Invertebrate
BS
Springsnail, elongate Mud
Meadows
Pyrgulopsis notidicola
NV
Invertebrate
C
Springsnail, Fairbanks
Pyrgulopsis fairbanksensis
NV
Invertebrate
BS
Springsnail, Gila
Pyrgulopsis gilae
NM
Invertebrate
C
Springsnail, Grand Wash
Pyrgulopsis bacchus
AZ
Invertebrate
BS
Springsnail, Harney Lake
Pyrgulopsis hendersoni
OR
Invertebrate
BS
Springsnail, Huachuca
Pyrgulopsis thompsoni
AZ
Invertebrate
C
Springsnail, Idaho
Fontelicella idahoensis
ID
Invertebrate
FE
Springsnail, Jackson Lake
Pyrgulopsis robusta
OR
Invertebrate
BS
Springsnail, Kingman
Pyrgulopsis conica
AZ
Invertebrate
BS
Springsnail, Koster’s
Juturnia kosteri
NM
Invertebrate
FE
Springsnail, Malheur cave
Oncopodura mala
CA
Invertebrate
BS
Springsnail, New Mexico
Pyrgulopsis thermalis
NM
Invertebrate
C
Springsnail, Owyhee Hot
Pyrgulopsis owyheensis
OR
Invertebrate
BS
Springsnail, page
Pyrgulopsis morrisoni
AZ
Invertebrate
C
Springsnail, Roswell
Pyrgulopsis roswellensis
NM
Invertebrate
FE
Springsnail, San Bernardino
Pyrgulopsis bernardina
AZ
Invertebrate
FP
Springsnail, Socorro
Pyrgulopsis neomexicana
NM
Invertebrate
FE
Springsnail, Three Forks
Pyrgulopsis trivialis
AZ
Invertebrate
FP
Springsnails, hydrobiid
All species in genus
Pyrgulopsis
AZ
Invertebrate
BS
Spruce, white
Picea glauca
ID
Plant
BS
Spurge, flat-seeded
Chamaesyce platysperma
CA
Plant
BS
Spurge, Hoover’s
Chamaesyce hooveri
CA, UT
Plant
FT
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-67
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Spurge, Stony Creek
Chamaesyce ocellata
CA
Plant
BS
Squirrel, Coachella Valley
round-tailed ground
Spermophilus tereticaudus
CA
Mammal
C
Squirrel, Mohave ground
Spermophilus mohavensis
CA
Mammal
BS
Squirrel, Mount Graham red
Tamiasciurus hudsonicus
AZ
Mammal
FE
Squirrel, Nelson’s antelope
Ammospermophilus nelsoni
CA
Mammal
BS
Squirrel, Northern Idaho ground
Spermophilus hrunneus
hrunneus
ID
Mammal
FT
Squirrel, Osgood’s arctic ground
Spermophilus parryii
AK
Mammal
BS
Squirrel, Palm Springs round¬
tailed ground
Spermophilus tereticaudus
CA
Mammal
C
Squirrel, rock
Spermophilus variegatus
ID
Mammal
BS
Squirrel, Southern Idaho ground
Spermophilus hrunneus
ID
Mammal
C
Squirrel, Washington ground
Urocitellus washingtoni
OR
Mammal
C
Squirrel, western grey
Sciurus griseus
OR
Mammal
BS
St. Johns-wort, large Canadian
Hypericum majus
ID
Plant
BS
Stanleya, biennial
Stanleya confertiflora
ID, OR
Plant
BS
Star-tulip, Shirley Meadows
Calochortus westonii
CA
Plant
BS
Steelhead (California Central
Valley DPS4)
Oncorhynchus mykiss
CA
Fish
FT
Steelhead (Central California
Coast DPS)
Oncorhynchus mykiss
CA
Fish
FT
Steelhead (Lower Columbia
river DPS)
Oncorhynchus mykiss
OR
Fish
FT
Steelhead (Middle Columbia
River DPS)
Oncorhynchus mykiss
OR
Fish
FT
Steelhead (Northern California
DPS)
Oncorhynchus mykiss
CA
Fish
FT
Steelhead (Snake River Basin
DPS)
Oncorhynchus mykiss
ID, OR
Fish
FT
Steelhead (South Central
California Coast DPS)
Oncorhynchus mykiss
CA
Fish
FT
Steelhead (Southern California
DPS)
Oncorhynchus mykiss
CA
Fish
FE
Steelhead (Upper Columbia
River DPS)
Oncorhynchus mykiss
OR
Fish
FT
Steelhead (Upper Willamette
River DPS)
Oncorhynchus mykiss
OR
Fish
FT
Stenotus, woolly
Stenotus lanuginosus
CA
Plant
BS
Stickleaf, September 1 1
Mentzelia mcmorabilis
AZ
Plant
BS
Stickleaf, smooth
Mentzclia mollis
ID, NV, OR
Plant
BS
Stickleaf, southwest
Mentzelia argillosa
CO
Plant
BS
Stickleback, unarmored
threespine
Gasterosteus aculeatus
williamsoni
CA
Fish
FE
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-68
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Stickseed, beautiful
Hackelia bella
OR
Plant
BS
Stickseed, Cronquist’s
Hackelia cronquistii
ID, OR
Plant
BS
Stickseed, diffuse
Hackelia diffusa
OR
Plant
BS
Stickseed, rough
Hackelia hispida var.
disjuncta
OR
Plant
BS
Stickseed, sagebrush
Hackelia hispida
OR
Plant
BS
Stickseed, showy
Hackelia venusta
OR
Plant
FE
Stickseed, Three Forks
Hackelia ophiobia
ID, OR
Plant
BS
Stitchwort, James’
Pseudostellaria jamesiana
MT
Plant
BS
Stonecat
Noturus flavus
CO
Fish
BS
Stonecrop, Applegate
Sedum oblanceolatum
CA, OR
Plant
BS
Stonecrop, Bartram
Graptopetalum bartramii
AZ
Plant
BS
Stonecrop, Canyon Creek
Sedum paradisum
CA
Plant
BS
Stonecrop, Feather River
Sedum albomarginatum
CA
Plant
BS
Stonecrop, Lake County
Parvisedum leiocarpum
CA
Plant
FE
Stonecrop, Red Mountain
Sedum eastwoodiae
CA
Plant
C
Stonecrop, Rogue River
Sedum moranii
OR
Plant
BS
Stonefly, meltwater Lednian
Lednia tumana
MT
Invertebrate
C
Stonefly, Wahkeena Falls
flightless
Zapada wahkeena
OR
Invertebrate
BS
Storm-petrel, ashy
Oceanodroma homochroa
CA
Bird
BS
Storm-petrel, fork-tailed
Oceanodroma furcata
CA
Bird
BS
Strap-lichen, ciliate
Heterodermia leucomelos
CA
Plant
BS
Strawberry, Idaho
Waldsteinia idahoensis
ID
Plant
BS
Streptanthus, Howell’s
Streptanthus howellii
OR
Plant
BS
Sturgeon, North American green
Acipenser medirostris
AK, CA, OR
Fish
FT
Sturgeon, pallid
Scaphirhynchus albus
CO, MT, WY
Fish
FE
Sturgeon, white (Kootenai River
population)
Acipenser transmontanus
ID, MT
Fish
FE
Stylocline
Stylocline fdaginea
ID
Plant
BS
Sucker, blue
Cycleptus elongatus
MT, WY
Fish
BS
Sucker, bluehead
Catostomus discobolus
AZ, CO, UT,
WY
Fish
BS
Sucker, desert
Catostomus clarki
AZ, NM, UT
Fish
BS
Sucker, flannelmouth
Catostomus latipinnis
AZ, CO, UT,
WY
Fish
BS
Sucker, Goose Lake
Catostomus occidentalis
OR
Fish
BS
Sucker, June
Chasmistes liorus
UT
Fish
FE
Sucker, little Colorado
Catostomus sp.
AZ, UT
Fish
BS
Sucker, Lost River
Deltistes luxatus
CA, OR
Fish
FE
Sucker, Meadow Valley Wash
desert
Catostomus clarki
AZ, NV
Fish
BS
Sucker, Modoc
Catostomus microps
CA, OR
Fish
FE
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-69
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Sucker, mountain
Catostomus platyrhynchus
CO, OR
Fish
BS
Sucker, razorback
Xyrauchen texanus
AZ, CA, CO,
NM, NV, UT,
WY
Fish
FE
Sucker, Rio Grande
Catostomus plebeius
CO
Fish
BS
Sucker, Santa Ana
Catostomus santaanae
CA
Fish
FT
Sucker, shortnose
Chasmistes brevirostris
CA, OR
Fish
FE
Sucker, Sonora
Catostomus insignis
AZ, NM
Fish
BS
Sucker, Tahoe
Catostomus tahoensis
OR
Fish
BS
Sucker, Wall Canyon
Catastomus sp. (undescribed,
=murivallis)
CA, NV
Fish
BS
Sucker, Warner
Catostomus warnerensis
CA, NV, OR
Fish
FT
Sucker, Zuni bluehead
Catostomus discobolus
AZ, NM
Fish
C
Suckleya, poison
Suckleya suckleyana
MT
Plant
BS
Suksdorfia, violet
Suksdorfia violacea
OR
Plant
BS
Sullivantia, Oregon
Sullivantia oregana
OR
Plant
BS
Sumac, Kearney
Rhus kearneyi
AZ
Plant
BS
Sunburst, Hartweg’s golden
Pseudobahia bahiifolia
CA
Plant
FE
Sunburst, San Joaquin Adobe
Pseudobahia peirsonii
CA
Plant
FT
Suncup, Grand Junction
Camissonia eastwoodiae
CO
Plant
BS
Sunflower, Algodones Dunes
Helianthus niveus
CA
Plant
BS
Sunflower, Pecos
Helianthus paradoxus
NM
Plant
FT
Sunray, Ash Meadows
Enceliopsis nudicaulis var.
corrugata
CA, NV
Plant
FT/BS
Sunray, silverleaf
Enceliopsis argophylla
AZ, NV
Plant
BS
Sunshine, Sonoma
Blennosperma bakeri
CA
Plant
FE
Swallow, bank
Riparia riparia
CA
Bird
BS
Swan, trumpeter
Cygnus buccinator
AK, ID, MT,
OR, WY
Bird
BS
Sweetpea, Bullfrog Hills
Lathyrus hitchcockianus
NV
Plant
BS
Swertia, Umpqua
Frasera umpquaensis
OR
Plant
BS
Swift, black
Cypseloides niger
CO, ID, OR,
UT
Bird
BS
Swift, Vaux’s
Chaetura vauxi
ID
Bird
BS
Swordfem, California
Polystichum californicum
OR
Plant
BS
Swordfem, Kruckeberg’s
Polystichum kruckebergii
ID
Plant
BS
Tail-dropper, spotted
Prophysaon vanattae
OR
Invertebrate
BS
Tansy, cinquefoil
Sphaeromeria potentilloides
ID
Plant
BS
Tansy, rock
Sphaeromeria capitata
CO
Plant
BS
Tansymustard, Wyoming
Descurainia torulosa
WY
Plant
BS
Taraxacum, California
Taraxacum californicum
CA
Plant
FE
Tarplant, Congdon’s
Centromadia parryi ssp.
congdonii
CA
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic E1S
E-70
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Tarplant, Gaviota
Deinandra increscens ssp.
villosa
CA
Plant
FE
Tarplant, Hall’s
Deinandra halliana
CA
Plant
BS
Tarplant, Mojave
Deinandra mohavensis
CA
Plant
BS
Tarplant, Otay
Deinandra conjugens
CA
Plant
FT
Tarplant, pappose
Centromadia parryi ssp.
parryi
CA
Plant
BS
Tarplant, Red Rock
Deinandra arida
CA
Plant
BS
Tarplant, Santa Cruz
Holocarpha macradenia
CA
Plant
FT
Tarplant, Santa Suzana
Deinandra minthornii
CA
Plant
BS
Tarplant, scabrid alpine
Anisocarpus scabridus
CA
Plant
BS
Tarplant, Tecate
Deinandra floribunda
CA
Plant
BS
Tauschia, Hoover’s
Tauschia hooveri
OR
Plant
BS
Tern, black
Chlidonias niger
CO, ID, MT,
NM, NV, UT
Bird
BS
Tern, California least
Sterna antillarum browni
AZ, CA
Bird
FE
Tern, Caspian
Sterna caspia
UT
Bird
BS
Tern, least (interior)
Sterna antillarum
CO, MT, NM,
WY
Bird
FE
Tetracoccus, Parry’s
Tetracoccus dioicus
CA
Plant
BS
Thelypody, arrow
Thelypodium sagittatum
MT
Plant
BS
Thelypody, arrow-leaf
Thelypodium eucosmum
OR
Plant
BS
Thelypody, Howell’s
Thelypodium howellii
CA
Plant
BS
Thelypody, Howell’s spectacular
Thelypodium howellii ssp.
spectabilis
OR
Plant
FT
Thelypody, northwestern
Thelypody paniculatum
MT
Plant
BS
Thelypody, short-podded
Thelypodium brachycarpum
OR
Plant
BS
Thelypody, wavy-leaf
Thelypodium repandum
ID
Plant
BS
Thistle, Ashland
Cirsium ciliolatum
CA
Plant
BS
Thistle, Cedar Rim
Cirsium aridum
WY
Plant
BS
Thistle, Chorro Creek Bog
Cirsium fontinale var.
obispoense
CA
Plant
FE
Thistle, compact cobwebby
Cirsium occidentale
CA
Plant
BS
Thistle, fountain
Cirsium fontinale
CA
Plant
FE
Thistle, La Graciosa
Cirsium scariosum var.
loncholepis
CA
Plant
FE
Thistle, Mount Hamilton
Cirsium fontinale var.
campylon
CA
Plant
BS
Thistle, Ownbey’s
Cirsium ownbeyi
CO, WY
Plant
BS
Thistle, Pitcher’s
Cirsium pitcheri
CA
Plant
FT
Thistle, Rocky Mountain
Cirsium perplexans
CO
Plant
BS
Thistle, Sacramento Mountains
Cirsium vinaceum
NM
Plant
FT
Thistle, slough
Cirsium crassicaule
CA, WY
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-71
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Thistle, Suisun
Cirsium hydrophilum var.
hydrophilum
CA
Plant
FE
Thistle, surf
Cirsium rhothophilum
CA
Plant
BS
Thistle, Virgin River
Cirsium mohavense
NV
Plant
BS
Thistle, Wright’s marsh
Cirsium wrightii
AZ, NM
Plant
C
Thombush, seaside
Kaernefeltia californica
CA
Plant
BS
Thommint, San Diego
Acanthomintha ilicifolia
CA
Plant
FT
Thommint, San Mateo
Acanthomintha obovata
CA
Plant
FE
Thrasher, Bendire’s
Toxostoma bendirei
CA, NV
Bird
BS
Thrasher, Crissal
Toxostoma crissale
UT
Bird
BS
Thrasher, Le Conte’s
Toxostoma lecontei
AZ, CA, NV
Bird
BS
Thrasher, Le Conte’s (San
Joaquin population)
Toxostoma lecontei lecontei
CA
Bird
BS
Thrasher, sage
Oreoscoptes montanus
MT, NV, WY
Bird
BS
Threadsnake, western
Leptotyphlops humilis
UT
Reptile
BS
Threadstem, rigid
Nemacladus rigidus
ID, WY
Plant
BS
Thrush, Swainson’s
Catharus ustulatus
ID
Bird
BS
Tidy-tips, Munz’s
Layia munzii
CA
Plant
BS
Tidy-tips, ray less
Layia discoidea
CA
Plant
BS
Tightcoil, Crater Lake
Pristiloma arcticum
OR
Invertebrate
BS
Tightcoil, crowned
Pristiloma pilsbryi
OR
Invertebrate
BS
Timwort
Cicendia quadrangularis
OR
Plant
BS
Toad, Amargosa
Bufo nelsoni
NV
Amphibian
BS
Toad, Arizona
Bufo microscaphus
CA, NM, UT
Amphibian
BS
Toad, Arroyo
Bufo californicus
CA
Amphibian
FE
Toad, black
Anaxyrus exsul
CA
Amphibian
BS
Toad, boreal
Anaxyrus (=Bufo) boreas
boreas
CO, ID, MT,
UT, WY
Amphibian
C
Toad, Canadian
Bufo hemiophrys
MT
Amphibian
BS
Toad, Couch’s spadefoot
Scaphiopus couchi
CA
Amphibian
BS
Toad, Dixie Valley
Bufo boreas ssp.
NV
Amphibian
BS
Toad, Great Plains
Bufo cognatus
MT, UT
Amphibian
BS
Toad, Great Plains narrow¬
mouthed
Gastrophryne olivacea
AZ
Amphibian
BS
Toad, Sonoran green
Bufo ret if or mis
AZ
Amphibian
BS
Toad, western spadefoot
Scaphiopus hammondi
CA
Amphibian
BS
Toad, Woodhouse’s
Bufo woodhousii
OR
Amphibian
BS
Toad, Wyoming
Bufo baxteri
WY
Amphibian
FE
Toad, Yosemite
Anaxyrus canorus
CA
Amphibian
FT
Toadflax, blue
Nuttallanthus texanus
MT
Plant
BS
Tobacco, coyote
Nicotiana attenuata
OR
Plant
BS
Toothcup, lowland
Rotala ramosior
OR
Plant
BS
Topminnow, Gila
Poeciliopsis occidentalis
AZ, NM
Fish
FE
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-72
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Topminnow, plains
Fundulus sciadicus
CO
Fish
BS
Tortoise, desert
Gopherus agassizii
AZ, CA, NV,
UT
Reptile
FT
Towhee, green-tailed
Pipilo chlorurus
ID
Bird
BS
Towhee, Inyo California
Pipilo crissalis eremophilus
CA
Bird
FT
Townsendia, last chance
Townsendia aprica
CA, UT
Plant
FE/FT
Townsendia, mountain
Townsendia montana
OR
Plant
BS
Townsendia, Parry’s
Townsendia parryi
OR
Plant
BS
Townsendia, scapose
Townsendia scapigera
ID
Plant
BS
Townsendia, showy
Townsendia florifera
MT
Plant
BS
Tree-anemone
Carpenteria californica
CA
Plant
BS
Treefrog, Arizona
Hyla wrightorum
AZ
Amphibian
C
Treefrog, canyon
Hyla arenicolor
CO, WY
Amphibian
BS
Treefrog, lowland burrowing
Smilisca fodiens
AZ
Amphibian
BS
Trefoil, stipuled
Lotus stipularis
OR
Plant
BS
Trillium, Siskiyou
Trillium kurabayashii
OR
Plant
BS
Trillium, small-flowered
Trillium parviflorum
OR
Plant
BS
Trout, Apache
Oncorhynchus apache
AZ
Fish
FT
Trout, Bonneville cutthroat
Oncorhynchus clarki Utah
ID, NV, UT,
WY
Fish
BS
Trout, bull
Salvelinus confluentus
ID, MT, NV,
OR
Fish
FT, XN
Trout, coastal cutthroat
Oncorhynchus clarkii clarkii
OR
Fish
BS
Trout, Colorado River cutthroat
Oncorhynchus clarki
pleuriticus
CO, UT, WY
Fish
BS
Trout, fine-spotted Snake River
cutthroat
Oncorhynchus clarki ssp.
WY
Fish
BS
Trout, Gila
Oncorhynchus gilae
AZ, NM
Fish
FT
Trout, Great Basin redband
Oncorhynchus mykiss ssp.
OR
Fish
BS
Trout, greenback cutthroat
Oncorhynchus clarki ssp.
stomias
CO, UT
Fish
FT
Trout, inland Columbia Basin
redband
Oncorhynchus mykiss
gairdneri
NV
Fish
BS
Trout, interior redband
Oncorhynchus mykiss gihhsi
ID, NV, OR
Fish
BS
Trout, interior redband (Jenny
Creek)
Oncorhynchus mykiss
gairdneri
OR
Fish
BS
Trout, Lahontan cutthroat
Oncorhynchus clarki ssp.
hcnshawi
CA, CO, NV,
OR, UT
Fish
FT
Trout, Little Kern Golden
Oncorhynchus aguabonita
CA
Fish
FT
Trout, Paiute cutthroat
Oncorhynchus clarki scleniris
CA
Fish
FT
Trout, Rio Grande cutthroat
Oncorhynchus clarki
virginalis
CO, NM
Fish
C
Trout, westslope cutthroat
Oncorhynchus clarki lewisi
ID, MT, OR
Fish
BS
Trout, Yellowstone cutthroat
Oncorhynchus clarki bouvicri
ID, MT, UT,
WY
Fish
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-73
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
' State1
Class
Status2
Truffle, hypogeous
Choiromyces venosus
CA, OR
Fungi
BS
Truffle, yellow false
Leucogaster citrinus
CA, OR
Fungi
BS
Tryonia, Amargosa
Tryonia variegata
NV
Invertebrate
BS
Tryonia, Gila
Tryonia gilae
AZ
Invertebrate
BS
Tryonia, grated
Tryonia clathrata
NV
Invertebrate
BS
Tryonia, minute
Tryonia ericae
NV
Invertebrate
BS
Tryonia, Point of Rocks
Tryonia elata
NV
Invertebrate
BS
Tryonia, Sportinggoods
Tryonia angulata
NV
Invertebrate
BS
Tuctoria, Greene’s
Tuctoria greenei
CA
Plant
FE
Turtle, desert ornate box
Terrapene ornata
AZ
Reptile
BS
Turtle, northwestern pond
Actinemys (=Clemmys)
marmorata marmorata
OR
Reptile
BS
Turtle, painted
Chrysemys picta
OR
Reptile
BS
Turtle, snapping
Chelydra serpentina
MT, UT
Reptile
BS
Turtle, Sonoyta mud (Sonoran)
Kinosternon sonoriense
longifemorale
AZ, NM
Reptile
C
Turtle, southwestern pond
Actinemys marmorata pallida
CA
Reptile
BS
Turtle, spiny softshell
Trionyx spiniferus
MT
Reptile
BS
Twayblade
Liparis loeselii
OR
Plant
BS
Twayblade, northern
Lis ter a borealis
CO, OR
Plant
BS
Twinpod, Chamber’s
Physaria chambersii
OR
Plant
BS
Twinpod, common
Physaria didymocarpa ssp.
lanata
OR
Plant
BS
Twinpod, Dorn’s
Physaria dornii
CA, WY
Plant
BS
Twinpod, Dudley Bluffs
(piceance)
Physaria obcordata
CO, UT
Plant
FT
Twinpod, Rocky Mountain
Physaria saximontana
WY
Plant
BS
Twinpod, tufted
Physaria condensata
WY
Plant
BS
Ulota, large-spored
Ulota megalospora
ID
Plant
BS
Veery
Catharus fuscescens
ID
Bird
BS
Vervain, Red Hills
Verbena californica
CA
Plant
FT
Vetchling, Grime’s
Lathyrus grimesii
NV
Plant
BS
Violet, kidney-leaved
Viola renifolia
OR
Plant
BS
Violet, rock
Viola lithion
NV
Plant
BS
Violet, western bog
Viola primulifolia
OR
Plant
BS
Vireo, Bell’s
Vireo bellii
CA, NM, UT
Bird
BS
Vireo, gray
Vireo vicinior
CA
Bird
BS
Vireo, least Bell’s
Vireo bellii pusillus
CA
Bird
FE
Vireo, solitary
Vireo solitarius
ID
Bird
BS
Vole, Amargosa
Microtus californicus
scirpensis
CA
Mammal
FE
Vole, Ash Meadows montane
Microtus montanus
nevadensis
NV
Mammal
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-74
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Vole, Hualapai Mexican
Microtus mexicanus
hualpaiensis
AZ
Mammal
FE
Vole, Mexican
Microtus mexicanus
UT
Mammal
BS
Vole, Owens Valley California
Microtus californicus
vallicola
CA
Mammal
BS
Vole, Pahranagat Valley
montane
Microtus montanus fucosus
NV
Mammal
BS
Vole, Potholes meadow
Microtus pennsylvanicus
kincaidi
OR
Mammal
BS
Vole, red tree
Arborimus longicaudus
OR
Mammal
BS
Vole, Shaw Island Townsend’s
Microtus townsendii pugeti
OR
Mammal
BS
Vole, Virgin River montane
Microtus montanus rivularis
UT
Mammal
BS
Wafer-parsnip, Evert’s
Cymopterus evertii
WY
Plant
BS
Wafer-parsnip, William’s
Cymopterus williamsii
WY
Plant
BS
Wahoo, western
Euonymus occidentalis
OR
Plant
BS
Walker, Pacific
Pomatiopsis californica
OR
Invertebrate
BS
Walker, robust
Pomatiopsis binneyi
OR
Invertebrate
BS
Wallflower
Erysimum asperum
AK
Plant
BS
Wallflower, Ben Lomond
Erysimum teretifolium
CA
Plant
FE
Wallflower, coast
Erysimum ammophilum
CA
Plant
BS
Wallflower, Contra Costa
Erysimum capitatum
CA
Plant
FE
Wallflower, Humboldt Bay
Erysimum menziesii
CA
Plant
FE
Wallflower, Inuit
Parrya nauruaq
AK
Plant
BS
Wallflower, Menzie’s
Erysimum menziesii
CA
Plant
FE
Walrus, Pacific
Odobenus rosmarus
AK
Mammal
C
Warbler, blackpoll
Dendroica striata
AK
Bird
BS
Warbler, black-throated gray
Dendroica nigrescens
OR
Bird
BS
Warbler, Lucy’s
Vermivora luciae
CA
Bird
BS
Warbler, Macgillivray’s
Oporonis tolmiei
ID
Bird
BS
Warbler, Townsend’s
Dendroica townsendi
ID
Bird
BS
Warbler, Virginia’s
Vermivora virginiae
ID
Bird
BS
Warbler, Wilson’s
Wilsonia pusilla
ID
Bird
BS
Warbler, yellow
Dendroica petechia
ID
Bird
BS
Watercress, Gambel’s
Rorippa gambellii
CA
Plant
FE
Waterhemlock, bulb-bearing
Cicuta bulbifera
ID, OR
Plant
BS
Water-meal, Columbia
Wolffia columbiana
OR
Plant
BS
Water-meal, dotted
Wolff ia borealis
OR
Plant
BS
Water-pimpernel
Samolus parviflorus
OR
Plant
BS
Waterplantain, fringed
Damasonium californicum
ID, OR
Plant
BS
Water-starwort, The Dalles
Callitriche fassettii
OR
Plant
BS
Water-starwort, winged
Callitriche marginata
OR
Plant
BS
Waterthrush, northern
Seiurus noveboracensis
OR
Bird
BS
BLM Vegetation Treatments Three New 1 lerbicides
Final Programmatic EIS
E-75
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Water-umbel, Huachuca
Lilaeopsis schaffneriana var.
recurva
AZ
Plant
FE
Waterweed, long sheath
Elodea bifoliata
MT
Plant
BS
Waterwort, short seeded
Elatine brachysperma
OR
Plant
BS
Wavewing, Ibapah
Cymopterus ibapensis
AZ, NV
Plant
BS
Wavewing, intermountain
Cymopterus basalticus
NV
Plant
BS
Wave wing, longstalk
Cymopterus longipes
OR
Plant
BS
Waxflower
Jamesia tetrapetala
NV
Plant
BS
Waxwing, cedar
Bombycilla cedrorum
OR
Bird
BS
Weed, red poverty
Monolepis pusilla
OR
Plant
BS
Weevil, big dune miloderes
Miloderes sp.
NV
Invertebrate
BS
Westemslug, Tillamook
Hesperarion mariae
OR
Invertebrate
BS
Whale, blue
Balaenoptera musculus
AK, CA, OR
Mammal
FE
Whale, bowhead
Balaena mysticetus
AK
Mammal
FE
Whale, finback
Balaenoptera physalus
AK, CA
Mammal
FE
Whale, gray
Eschrichtius robustus
OR
Mammal
FE
Whale, humpback
Megaptera novaeangliae
AK, CA, OR
Mammal
FE
Whale, killer
Orcinus orca
CA, OR
Mammal
FE
Whale, Sei
Balaenoptera borealis
CA
Mammal
FE
Whale, sperm
Physeter catodon
AK, CA
Mammal
FE
Whip-scorpion, Shoshone cave
Trithyreus shoshonensis
CA, NV
Invertebrate
BS
Whipsnake (=striped racer),
Alameda
Masticophis lateralis
CA
Reptile
FT
Whipsnake, striped
Masticophis taeniatus
OR
Reptile
BS
Whiptail, Arizona striped
Aspidoscelis arizonae
AZ
Reptile
BS
Whiptail, canyon spotted
Cnemidophorus burti
AZ, NM
Reptile
BS
Whiptail, gray checkered
Cnemidophorus dixoni
NM
Reptile
BS
Whiptail, plateau striped
Cnemidophorus velox
UT
Reptile
BS
Whitefish, pygmy
Prosopium coulteri
OR
Fish
BS
Whitlow-grass, Adam’s
Draba pauciflora
AK
Plant
BS
Whitlow-grass, alpine
Draba micropetala
AK
Plant
BS
Whitlow-grass, Howell’s
Draba howellii
OR
Plant
BS
Whitlow-grass, Murray’s
Draba murrayi
AK
Plant
BS
Whitlow-grass, Standley
Draba standleyi
NM
Plant
BS
Wild-buckwheat, gypsum
Eriogonum gypsophilum
NM
Plant
FT
Wild-buckwheat, Yukon
Eriogonum flavum
AK
Plant
BS
Wild-rye, dune
Elymus simplex
WY
Plant
BS
Wild-rye, sand
Ley m us /laves cens
MT
Plant
BS
Willow, autumn
Salix serissima
CO
Plant
BS
Willow, False Mountain
Salix pseudomonticola
ID
Plant
BS
Willow, Farr’s
Salix farriae
OR
Plant
BS
Willow, glaucus
Salix glauca
OR
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-76
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Willow, hoary
Salix Candida
CO, ID, OR
Plant
BS
Willow, low blueberry
Salix myrtillifolia
CO, NM
Plant
BS
Willow, Maccall’s
Salix maccalliana
OR
Plant
BS
Willow, soft-leafed
Salix sessilifolia
OR
Plant
BS
Willow, Wolfs
Salix wolf'd
OR
Plant
BS
Willowherb, Nevada
Epilobiwn nevadense
NV
Plant
BS
Wintergreen, white-veined
Pyrola picta
MT
Plant
BS
Wire-lettuce, Malheur
Stephanomeria malheurensis
OR
Plant
FE
Wire-lettuce, Schott
Stephanomeria schottii
AZ
Plant
BS
Wolf, gray
Can is lupus
AZ, CO, ID,
MT, NM, NV,
OR, UT, WY
Mammal
FE, XN
Wolverine, North American
Gulo gulo luscus
CA, CO, ID,
MT, OR, UT,
WY
Mammal
BS
Wood fern, Aravaipa
Thelypteris puberula
AZ
Plant
BS
Wood fern, Nevada
Thelypteris nevadensis
ID
Plant
BS
Woodland-gilia, Latimer’s
Saltugilia ladmeri
CA
Plant
BS
Woodland-star, San Clemente
Island
Lithophragma maximum
CA
Plant
FE
Woodpecker, acorn
Melanerpes formicivorus
OR
Bird
BS
Woodpecker, black backed
Picoides arcdcus
MT
Bird
BS
Woodpecker, Gila
Melanerpes uropygialis
CA
Bird
BS
Woodpecker, hairy
Picoides villosus
MT
Bird
BS
Woodpecker, Lewis
Melanerpes lewis
ID, NV, OR,
UT
Bird
BS
Woodpecker, pileated
Dryocopus pileatus
ID
Bird
BS
Woodpecker, red-headed
Melanerpes erythrocephalus
MT
Bird
BS
Woodpecker, three-toed
Picoides tridactylus
ID, MT, OR,
UT
Bird
BS
Woodpecker, white-headed
Picoides ablolarvatus
ID, OR
Bird
BS
Woodrat, riparian
Neotoma fuscipes riparia
CA
Mammal
FE
Woodrat, Stephens’
Neotoma stepheni
UT
Mammal
BS
Woolly-heads, dwarf
Psilocarphus brevissimus
MT
Plant
BS
Woolly-heads, slender
Psilocarphus tenellus
ID
Plant
BS
Woolly-star, Hoover’s
Eriastrum hooveri
CA
Plant
BS
Woolly-star, Santa Ana Pviver
Eriastrum densifolium ssp.
sanctorum
CA
Plant
FE
Woolly-sunflower, Barstow
Eriophyllum mohavense
CA
Plant
BS
Woolly-sunflower, Fort Tejon
Eriophyllum lanatum
CA
Plant
BS
Woolly-sunflower, San Mateo
Eriophyllum latilobum
CA
Plant
FE
Woolly-threads, San Joaquin
Monolopia congdonii
CA
Plant
FE
Wormwood, mystery
Artemisia biennis
WY
Plant
BS
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-77
January 2016
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Wormwood, northern
Artemisia campestris ssp.
borealis var. wormskioldii
OR
Plant
C
Wormwood, purple
Artemisia globular ia
AK
Plant
BS
Wormwood, Siberian
Artemisia laciniata
AK
Plant
BS
Woundfm
Plagopterus argentissimus
AZ, NM, NV,
UT
Fish
FE
Wren, sedge
Cistothorus platensis
MT
Bird
BS
Yampah, red-rooted
Perideridia erythrorhiza
OR
Plant
BS
Yellowcress, Columbian
Rorippa columbiae
CA, OR
Plant
BS
Yellowcress, persistent sepal
Rorippa calycina
MT, WY
Plant
BS
Yellowcress, Tahoe
Rorripa subumbellata
CA, NV
Plant
C
Yellowhead, desert
Yermo xanthocephalus
WY
Plant
FT
Yellowthroat, common
Geothlypis trichas
UT
Bird
BS
Yerba santa, Lompoc
Eriodictyon capitatum
CA
Plant
FE
1 State refers to the administrative jurisdiction of the BLM state office for the state listed. Therefore, MT indicates that the species
may occur in Montana, North Dakota, and/or South Dakota; NM indicates that the species may occur in New Mexico, Texas,
and/or Kansas; OR indicates that the species may occur in Oregon and/or Washington; and WY indicates that the species may
occur in Wyoming and/or Nebraska.
2 BS = BLM sensitive species; C = Candidate species for listing under the ESA; FE = Federal endangered species; FT = Federal
threatened species; PE = Proposed for listing as an endangered species; PT = Proposed for listing as a threatened species; XE =
Experimental population, essential; and XN = Experimental population, nonessential.
3 ESU = Evolutionary Significant Unit.
4 DPS = Distinct Population Segment.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-78
January 2016
IONS, AND SYMBOLS
ft Systems
SPECIAL STATUS SPECIES LIST
Common Name
Scientific Name
State1
Class
Status2
Wormwood, northern
Artemisia campestris ssp.
borealis var. wormskioldii
OR
Plant
C
Wormwood, purple
Artemisia globularia
AK
Plant
BS
Wormwood, Siberian
Artemisia laciniata
AK
Plant
BS
Woundfm
Plagopterus argentissimus
A Z, NM, NV,
UT
Fish
FE
Wren, sedge
Cistothorus platensis
MT
Bird
BS
Yampah, red-rooted
Perideridia erythrorhiza
OR
Plant
BS
Yellowcress, Columbian
Rorippa columbiae
CA, OR
Plant
BS
Yellowcress, persistent sepal
Rorippa calycina
MT, WY
Plant
BS
Yellowcress, Tahoe
Rorripa subumbellata
CA, NV
Plant
C
Yellowhead, desert
Yermo xanthocephalus
WY
Plant
FT
Yellowthroat, common
Geothlypis trichas
UT
Bird
BS
Y erba santa, Lompoc
Eriodictyon capita turn
CA
Plant
FE
1 State refers to the administrative jurisdiction of the BLM state office for the state listed. Therefore, MT indicates that the species
may occur in Montana, North Dakota, and/or South Dakota; NM indicates that the species may occur in New Mexico, Texas,
and/or Kansas; OR indicates that the species may occur in Oregon and/or Washington; and WY indicates that the species may
occur in Wyoming and/or Nebraska.
3 BS = BLM sensitive species; C = Candidate species for listing under the ESA; FE = Federal endangered species; FT = Federal
threatened species; PE = Proposed for listing as an endangered species; PT = Proposed for listing as a threatened species; XE =
Experimental population, essential; and XN = Experimental population, nonessential.
3 ESU = Evolutionary Significant Unit.
4 DPS = Distinct Population Segment.
BLM Vegetation Treatments Three New Herbicides
Final Programmatic EIS
E-78
January 2016
ACRONYMS, ABBREVIATIONS, AND SYMBOLS
ACEC
Area of Critical Environmental Concern
AIM
Assessment, Inventory, and Monitoring
ALS
Acetolactate synthase
AML
Appropriate Management Level
ANCSA
Alaska Native Claims Settlement Act
ANILCA
Alaska National Interest Lands Conservation Act
ARI
Aggregate Risk Index
ATV
All-terrain vehicle
AUM
Animal Use Months
BA
Biological Assessment
BLM
Bureau of Land Management
BMP
Best management practices
BP
Before the present
C-14
Carbon- 14
CalEPA
California Environmental Protection Agency
CALPUFF
California Puff
CDC
Centers for Disease Control and Prevention
CEQ
Council on Environmental Quality
CFR
Code of federal Regulations
ch4
Methane
CO
Carbon monoxide
co2
Carbon dioxide
C02e
Carbon dioxide equivalent
CWMA
Cooperative Weed Management Area
EIS
Environmental Impact Statement
EO
Executive Order
ERA
Ecological risk assessment
ESA
Endangered Species Act
FAQ
Frequently asked questions
FLPMA
Federal Land Policy and Management Act
FR
Federal Register
FRCC
Fire regime condition class
FTE
Full-time equivalent
FY
Fiscal Year
GHG
Greenhouse gas
GIS
Geographic Information System
GLEAMS
Groundwater Loading Effects of Agricultural Management Systems
HHRA
Human health risk assessment
HMA
Herd Management Area
in2
Square inch(es)
IVM
Integrated vegetation management
IWM
Integrated weed management
km
Kilometer(s)
Koc
Organic carbon-water partition coefficient
lb
Pound(s)
LOC
Level of Concern
al Marine Fisheries Service
mg/L
mi2
mL/g
mph
MT
MTC02e/yr
IMSDS
n2o
NA
NAAQS
NAWQA
NC
NCHS
NEPA
NHPA
NIOSH
NLCS
NIMFS
no2
NOI
NOx
NRHP
NYSDEC
03
OHV
Pb
PEIS
PER
PM
PM25
PM.o
PPb
ppm
PSD
ROD
ROW
RQ
SDS
SHPO
so2
SOP
TSP
U.S.
U.S.C.
IJSDA
Cubic meter(s)
Milligram(s)s per liter
Square mile(s)
Milliliter(s) per gram
Mile(s) per hour
Metric ton(s)
Metric ton(s) carbon dioxide equivalents per year
Material Safety Data Sheet
Nitrous oxide
Not applicable or not available
National Ambient Air Quality Standard
National Water Quality Assessment
Not calculated
National Center for Health Statistics
National Environmental Policy Act
National Historic Preservation Act
National Institute for Occupational Safety and Health
National Landscape Conservation System
National Oceanic and Atmospheric Administration National Marine Fisheries Service
Nitrogen dioxide
Notice of intent
Nitrogen oxides
National Register of Historic Places
New York State Department of Environmental Conservation
Ozone
Off-highway vehicle
Lead
Programmatic Environmental Impact Statement
Programmatic Environmental Report
Particulate matter
Fine particulate matter less than 25 microns in diameter
Particulate matter less than 10 microns in diameter
Parts per billion
Parts per million
Prevention of Significant Deterioration
Record of Decision
Right-of-way
Risk quotient
Safety Data Sheet
State Historic Preservation Officer
Sulfur dioxide
Standard operating procedure
Total suspended particles
United States
United States Code
U.S. Department of Agriculture
USDOI
U.S. Department of Interior
USEPA
U.S. Environmental Protection Agency
USFWS
U.S. Fish and Wildlife Service
USGS
U.S. Geological Survey
UTV
Utility terrain vehicle
VOC
Volatile organic compound
VRI
Visual Resource Inventory
VRM
Visual Resource Management
WSA
Wilderness Study Area
WSSA
Weed Science Society of America
WUI
Wildland urban interface
Pg
Micrograms
Pg/mJ
Micrograms per cubic meter
2,4-D
2,4 dichlorophenoxyacetic acid
BLM Library
Denver Federal Center
Bldg. 50, OC-521
P.O. Box 25047
Denver, CO 80225
Bureau of Land Management
Forest Rangeland, Riparian, and
Plant Conservation Division, WO-220
1849 C Street, NW, Room 2134 LM
Washington, DC 20240
202-912-7226
Website address: http://blm.gov/3vkd
2
3
4
5
Cover photos and photo credits:
1. Red Canyon near Lander, Wyoming. Photo by Aaron Thompson, BLM.
2. Aerial spraying of mesquite in New Mexico. Photo by Eddy Williams (retired), BLM.
3. Spraying herbicide on salt cedar near the Dolores River in Utah.
4. Aerial spraying of leafy spurge at Bennett Peak, Wyoming. Photo by
Ken Henke, BLM.
5. Mule sprayer at Goose Creek, Utah. Photo by Gordon Edwards, High Country
Sprayers.
Cover, spine, and CD label layout and design provided by the BLM National Operations
Center, Information and Publishing Services Section.
BLMA/VO/PL-1 6/003+671 1
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