S Lewis and Clark
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Environmental
Impact Statement
Final
ERRATA to the DRAFT EIS
STATE DOCUMENTS COLLECTION
f^OV 2 2 1991
MONTANA STATE LIBRARY
1515 E. 6th AVE.
MELENA, MONTANA 59620
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FINAL ENVIRONMENTAL IMPACT STATEMENT
LEWIS AND CLARK NATIONAL FOREST
FIVE-TEAR NOXIOUS WEED CONTROL PROGRAM
1986-1990
Cascade, Chouteau, Judith Basin, Meagher, Wheatland,
Golden Valley, Fergus, Lewis and Clark, Pondera, Teton,
Glacier, Park, and Sweetgrass Counties of Montana
Type of Action: Administrative
Responsible Federal Agency; USDA - Forest Service
Lewis and Clark National Forest
Responsible Official; John D. Gorman, Forest Supervisor
Lewis and Clark National Forest
P.O. Box 871
Great Falls, Mt. 59403
For Further Information; H. Wayne Phillips, Ecosystem Coordinator
Lewis and Clark National Forest
P.O. Box 871
Great Falls, Mt. 59403
Telephone: (406) 727-0901
ABSTRACT: This Final Environmental Impact Statement describes the preferred
alternative and four other alternatives, including a "no action" alternative,
for controlling noxious weeds on the Lewis and Clark National Forest. The
affected area involved is 1230 acres of National Forest System land in Central
Montana impacted by noxious weeds.
The alternatives provide different approaches to weed management resulting in
different levels of control. The environmental consequences for the preferred
alternative and other alternatives are displayed. An analysis of the impacts
of herbicide use on human health, using worst case assumptions, is included in
the statement.
The preferred alternative provides for treating noxious weeds in an integrated
pest management approach using the most effective combination of chemical ,
cultural, and biological methods. Chemical control would be by ground
application of herbicide to target weeds by hand-held nozzle or solid pellets.
Cultural control would include hand pulling or grubbing. Biological control
would consist of releasing and monitoring insect bio-agents.
This Final Environmental Impact Statement consists of the Draft EIS published
in March, 1986, and errata pages to the Draft. The Errata includes five
addendum documents as follows;
1. Montana Noxious Weed List - expands on pages 8 and 9 of the Draft.
2. Forest Objectives for Noxious Weed Management- a new document.
3. Noxious Weed Inventory and Project Proposal/ Report - A update of the site
specific data base and reports in Appendix 5 and Table I of the Draft.
4. Management Constraints - An revision of Section E, page 22 of the Draft.
5. Content Analysis of Comments to the Draft EIS and copies of the Comments
a new document based on comments to the Draft.
Both the Draft EIS and Errata zire required for the ccxaplete Final EIS.
Digitized by the Internet Archive
in 2017 with funding from
Montana State Library
https://archive.org/details/lewisclarknation1986lewi
ERRATA
TO THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
FIVE YEAR NOXIOUS WEED CONTROL PROGRAM
LEWIS AND CLARK NATIONAL FOREST
JULY 1986
TABLE OF CONTENTS
Addendum #1
Montana Noxious Weed List
Addendum #2
Forest Objectives for Noxious Weed Management
Addendum #3
Noxious Weed Inventory and Project Proposal/Report
a. Definitions and Codes
b. Noxious Weed Inventory - Detailed Listing by Weed Species and Site Type
c. Summary of Pesticide Use
d. Pesticide Use Application by Project
e. Detailed Listing of Mechanical Treatments
f. Detailed Listing of Biological Treatments
g. Comparison of Alternatives by Treatment and Cost
Addendum #4
Management Constraints
Addendum #5
Content Analysis of Comments to the Draft EIS
and Copies of Comments Received
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ADDENDUM #1
MONTANA NOXIOUS UEED LIST
Sub-Chap ter 2
Designation of Noxious Weeds
^.5.201 DESIGNATirjN Of- NOXIOUS WEEDS (1) The department
designates certain exotic plants listed in these rules as
statewide noxious weeds under the County Weed Control Act
7-22-2101 (5), MCA. Ail counties must implement management
standards for these noxious weeds consistent with weed management
criteria developed under 7-22-2109 (2) (b) of the Act. The
department established two categories of the noxious weeds.
(History: Sec. 7-22-2101 MCA; I_MP , Sec. 7-22-2101 MCA; NEW 1986,
p . 337, Eff . 3/ 19/86. )
9.5.202 CATEGORY 1 ( 1 ) Category 1 noxious weeds are
weeds that are currently established in many counties of the
state. Management criteria for control of these weeds is
necessary in all counties to contain or suppress existing
infestations or to prevent, through eradication or other
appropriate measures, new infestations of these weeds. All of
these weeds render land unfit or greatly limit the beneficial
uses .
(2)
weeds :
( a )
(b )
(c )
(d )
( e )
( f )
(g )
( h )
( i )
7-22-2101
3/19/86. )
The following are designated as category 1 noxious
Canada Thistle ( C i r s i um ar vense )
Field Bindweed ( Convo 1 vu 1 us ar yens i s )
Whitetop ( Car dar i a dr aba )
Leafy Spurge ( Euphor b i a esu 1 a )
Russian Knapweed ( Cent aurea repens )
Spotted Knapweed ( Centaurea macu 1 o sa )
Diffuse Knapweed ( Centaurea d i f f usa )
Dalmation Toadflax ( L i nar i a dal ma t i c a )
St. Johnswort ( Hyper i cum per f or a turn ) . (History: Sec.
MCA; IMP, Sec. 7-22-2101 MCA; NEW 1986, p. 337, Eff.
9.5.203 CATEGORY 2 (1) Category 2 noxious weeds are weeds
that have not been detected in the State of Montana or have
recently been introduced into the State of Montana. These weeds
have the potential for rapid spread and invasion of lands,
thereby rendering them unfit for beneficial uses. County
planning to prevent the spread or introduction of these weeds is
necessary. Management criteria for detection and immediate
action to eradicate or contain these weeds is necessary in all
count i es .
(2)
weeds :
( a )
( b )
( c )
( d )
( e )
7-22-2101
3/ 19/86 . )
The following are designated as category 2 noxious
Dyers Woad ( I sa t i s tinctorial
Yellow Starthistle ( Centaurea solstitialis)
Common Crupina ( Cr up i na vu 1 q ar i s )
Tansy Ragwort ( Senec i o j_ac_ob^e^)
Rush Sk e 1 e t o nweed ( Cho nd r i 1 1 a i uncea ) . (History: Sec.
MCA; IMP, Sec. 7-2P-ai01 MCA; NEW 1986, p. 337, Eff.
1
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ADDENDUM #2
FOREST OBJECTIVES FOR NOXIOUS WEED MANAGEMENT
LEWIS AND CLARK NATIONAL FOREST
JULY 1986
The Forest objectives for noxious weed management are as follows:
1 . To prevent or reduce the invasion of noxious weeds on the Lewis and
Clark National Forest with a prevention program that combines public
information and education with good weed prevention practices, including
the establishment and maintenance of beneficial plant cover.
2. To control and/or contain noxious weed populations on National Forest
System lands in cooperation with State and County weed control
organizations and individual permittees and cooperators, using safe and
efficacious means for controlling weeds on a planned, priority basis.
3. To maintain a dynamic, on-going noxious weed inventory and program of
monitoring noxious weed populations and the effectiveness of noxious weed
control efforts.
The following implementation guidelines provide direction for accomplishing the
Forest objectives for noxious weed management.
A. PREVENTION
1 . Develop a public information and education program to emphasize
practices that prevent resource degradation and spread of noxious weeds.
The weed education program will include all Forest employees and the
public, including back-country/wilderness visitors. Publications, posters,
public service announcements, and other educational techniques will be used
to inform and involve the public and Forest Service employees in the Forest
weed management program.
2. Train workers treating noxious weeds on the Forest, both employees and
contractors, in plant identification, application techniques, and safety.
Plant identification training will include (a) target weeds, (b) other
weeds on the State-wide noxious weed list in Addendum #1, (c) rare plants
and (d) native species that may be mistaken for noxious weeds.
3. Maintain vegetative cover, preferably a closed plant community adapted
to the site, to limit the encroachment of noxious weeds. Require prompt
revegetation where mineral soil is exposed by activities, such as road
construction. Apply seed for revegetation based on species adaptation to
the specific site conditions, ease of establishment and seed availability.
1
4. Monitor travelways and staging areas, such as roads, trails, parking
areas, campgrounds, summer home sites, administrative sites, airstrips, and
t railheads for noxious weed invasion. Place a high priority on treating
noxious weeds on these sites to prevent the spread to other areas of the
Forest. Take special care to inspect construction sites, borrow pits and
rock quarries for noxious weeds to insure that the material used for road
construction and surfacing is weed free.
5. Consider weed infestations in designing travel plans to reduce the risk
of spreading noxious weeds through off-road vehicle travel.
6. Apply best range management practices to minimize livestock damage to
soils and streamsides. Maintain a healthy range ecosystem to help prevent
the establishment of noxious weeds and to retard the spread of noxious
weeds through natural competition. Develop the grazing system and best
range management practices on an individual allotment basis, considering
the specific ecosystem characteristics of each allotment.
7. Consider noxious weed control needs when developing timber sale area
improvement plans. Include plans for the prompt revegetation of areas
disturbed by roads construction and logging, including seeding as
necessary. Schedule weed treatment in sale area improvement plans where
noxious weed invasion following logging is likely.
8. Apply seed of competing species, adapted to the site, to areas treated
for noxious weed control , where noxious weed treatment leaves soil and
vegetation conditions vulnerable to reinvasion and reoccupancy by noxious
weeds .
B. CONTROL
1. Cooperate closely with other Federal, State and County agencies, private
individuals, contractors and permittees in planning and implementing
noxious weed control on the Forest.
2. Apply noxious weed control on a planned, priority basis, using the
following priorities for stratifying noxious weed populations for control:
a. Small size (1.0 acre or less), scattered (less than weed canopy
cover) , new infestations of any weed species on the Montana noxious
weed list (see Addendum #1). Mechanical treatment by hand pulling or
grubbing is the preferred treatment for individual plants and small
patches. Larger populations and weed species with deep root systems
should be chemically treated. Goal: Eradication.
(1) Rights-of-way, occupancy sites (see A-4 above)
(2) Riparian areas*
(3) General forest and range sites
2
b. Medium size (1.1 to 10.0 acres), low to moderate weed canopy cover
(1-25$), well established populations. Chemical treatment is the
preferred control method. Goal: Control and reduce the weed
population.
(1) Spotted knapweed and leafy spurge
(a) Rights-of-way, occupancy sites
(b) Riparian*
(c) General forest and range sites
(2) Other weeds on the Montana noxious weed list
(a) Rights-of-way, occupancy sites
(b) Riparian sites*
(c) General forest and range sites
c. Large size (over 10 acres) infestations. Chemical treatment is
applied to the periphery of the infestation to contain and prevent
further spread. Biological control will be emphasized within the main
body of the infestation if successful biological agents are
available. Goal; Containment.
(1) Spotted knapweed and leafy spruge
(a) Rights-of-way, occupancy sites
(b) Riparian sites*
(b) General forest and range sites
(2) Other weeds on the Montana noxious weed list
(a) Rights-of-way , occupancy sites
(b) Riparian sites*
(c) General forest and range sites
* Because of the possibility of contaminating surface water and groundwater in
the riparian zone, special management constraints limit the use of chemical
treatment (see Addendum #4, item 8 of the final EIS).
C. MONITORING
1 . Maintain the Forest noxious weed inventory and project proposal/report
data base and report accomplishments to the FSRAMIS reporting system.
2. Solicit support from the public and all employees in locating and
recording the location of noxious weed infestations.
3. Provide ocular pretreatment and post treafanent evaluations of all sites
treated, and document the evaluations in field records.
4. Establish permanent photo-points and ecosystem data plots on a select
number of priority noxious weed infestations to quantify the evaluation and
to demonstrate project effectiveness.
3
ADDENDUM #3a
NOXIOUS WEED INVENTORY AND PROJECT PROPOSAL/REPORT
Definitions and Codes
A. INVENTORY
PROJECT NUMBER - a unique number assigned to each individual project, and ties
the noxious weed inventory project proposal/report with the Forest Service
Range Management Information System (FSRAMIS) .
NAME
COUNTY
T,R,Sec - Location information, self explanatory
SITE TYPE CODES These are the four major environments in which the pests
(noxious weeds) are found.
RIP - Riparian and wetlands
OCC - Occupancy site, such as campgrounds, summer home areas, and
administrative sites.
GEN - General Forest and Rangelands .
ROW - Rights-of-way along Forest Roads and highways.
WEED SPECIES CODES
CADR - Cardaria draba - Whitetop
CANU - Carduus nutans - Musk thistle
CEDI - Centaurea diffusa - diffuse knapweed
CEMA - Centaurea masculosa - Spotted knapweed
CERE - Centaurea repens - Russian knapweed
CESO - Centaurea solstitialis - Yellow starthistle
CHJU - Chondrllla juncea - rush skeletonweed
CIAR - Cirsium arvense - Canada thistle
COAR - Convovulns arvensis - field bindweed
CRVU - Crupina vulgaris - Common crupina
EUES - Euphorbia escula - Leafy spurge
HYPE - Hypericum perforatum - St. Johnswort
ISTI - Isatis tinctoria - Dyers woad
LIDA - Linaria dalmatica - Dalmatian toadflax
LIVA - Linaria vulgaris - Yellow toadflax
SEJA - Senecio jacobaea - Tansy ragwort
TARGET PEST CODES
408 - Noxious weeds. See FSH 2109.11 -92.1 — 7 for additional codes
1
CANOPY COVER CODES This is the percent canopy cover of noxious weeds on the
infested area.
S - Scattered (less than ^%)
L - Low (1 to 10?!)
M - Moderate (10 to 2555)
H - High (greater than 25%)
INV ACRES
Inventoried acres in the project.
B. PESTICIDE TREATMENT
DILUENT CODE - This is the carrier for the pesticide.
1 - water
2 - oil
3 “ talc
4 - kerosene
See FSH 2109.11-93—3
NUMBER PESTICIDES - the number of pesticides in the formulation that is
proposed/applied to this project.
PESTICIDE TREATMENT UNIT CODE
1 - Acres
See FSH 2109.11-92.1 — 12 for additional codes.
METHOD CODE
100 - Aerial application
200 - Ground application as follows:
201 - Backpack broadcast sprayer
202 - Pressurized boom sprayer
203 - Basal applicator
204 - Herbie applicator
205 - VJiper - roller wick
206 - Spot applicator
207 - Injection
208 - Implant
209 - Granular applicator
See FSH 2109.11-92.1 — 13 for additional codes.
PESTICIDE PROP ACRES - Acres proposed for pesticide treataient.
PESTICIDE ACTUAL ACRES - Acres actually treated with pesticide.
2
PESTICIDE #1. if 2,
If there is more than one active ingredient in the pesticide formulation, they
are specified by repeating the following columns of data for each pesticide.
REG. CODE - EPA Registration Number Codes:
1 = 39511-6M-2935 for 2, 4-D Amine
2 = 46^-323 for liquid picloram ( Tordon 22K)
3 = 464-M1-1 for solid picloram (Tordon 2K pellets)
AI CODE -Active Ingredients in the pesticide formulation as follows:
208 - 2, 4-D Amine
225 “ Picloram (Tordon)
See FSH 2109.11-92.1—2 for additional codes
TYPE CODE - Pesticide Type:
1 - Fungicide, fumigants, nunaticides
2 - Insecticides
3 - Herbicides, algicides, and plant growth regulators
4 - Rodenticides, repellants, other animal damage control agents
See FSH 2109.11-92.1—1
MEASURE CODE - Quantity measurement of active ingredient code.
1 - pound
2 - ounce
3 - gram
4 - BIU
See FSH 2109.11-92.1—7.
A PPL. RATE - Application rate in pounds of active ingredient per net area of
pesticide application.
See FSH 2109.11-93—3.
PROPOSED LBS - Quantity of active ingredient proposed for application in
pounds .
See FSH 2109.11-92.1—7.
ACTUAL LBS - Quantity of active ingredient actually applied in pounds.
3
C . MECHANICAL TREATMENT
MECH TREAT TYPE - Type of mechanical treatment:
1 - handpulling and grubbing
2 - mowing
MECH PROP ACRES - Acres proposed for mechanical treatment.
MECH ACTURAL ACRES - Acres actually treated with mechanical methods.
D. BIOLOGICAL TREATMENT
BIOL AGENT - Biological Agent proposed/used.
RHCO - Rhinocylus conicus on musk thistle
URAF - Urophora affinis on spotted knapweed
HYEU - Hyles euphorbiae on leafy spurge
Add codes as needed by using the biological agents scientific name as above.
BIOL PROP ACRES - Acres proposed for biological treatment.
BIOL ACTUAL ACRES - Acres actually treated with biological agents.
4
6/27/86
A0DCNDUM/^3b
1
NOXIOUS WEED INVENTORY
DETAILED LISTING BY WEED SPECIES AND SITE TYPE
PROJECT
NUMBER
FOREST: LEWIS & CLARK N.
NAME COUNTY T
F.
R
DISTRICT
WEED
SEC SPECIES
1
SITE
WEED
INV
ACRES
11030^1
VOLCANO REEF
099
T26N
R09W
12
CEMA
GEN
1 .0
112403
EAR MOUNTAIN
099
T24N
R08W
4
CEMA
GEN
5.0
121301E
SAWMILL CREEK
049
T18N
R08W
9,11
CEMA
GEN
1 .0
GEN SITE TYPE
SUB-TOTAL
7.0
11 1008A
CAVE MOUNTAIN
099
T25N
R09W
26
CEMA
OCC
5.0
120903A
HOME GULCH
049
T22N
R09W
35
CEMA
OCC
4.0
121820C
FORD CR. RESORT
049
T19N
R09W
12
CEMA
OCC
10.0
122409A
WILLOW CR. ADMIN.
049
T20N
R09W
26,23
CEMA
OCC
0.1
OCC SITE TYPE
SUB-TOTAL
19.1
100002B
SUN RIVER
049
T21N
R09W
3,^
CEMA
RIP
96.0
100002C
SUN RIVER
049
T22N
R09W
35,36
CEMA
RIP
162.0
110414A
S. FORK TETON
099
T24N
R09W
2,4
CEMA
RIP
18.1
110414B
S. FORK TETON
099
T24N
R09W
2,4
CEMA
RIP
2.0
110801D
N. FORK TETON
099
T25N
R09W
25,36
CEMA
RIP
1.0
110801E
N. FORK TETON
099
T25N
R09W
25,36
CEMA
RIP
77.0
110922C
HWY 2-PIKE CR.
035
T30N
R13W
29,31
CEMA
RIP
20.0
121820D
FORD CR. RESORT
049
T19N
R09W
12
CEMA
RIP
40.0
RIP SITE TYPE
SUB-TOTAL
416.1
100002A
SUN RIVER RD.
049
T21N
R09W
2,3
CEMA
ROW
17.0
110801A
N. FORK TETON
099
T25N
R09W
7,8
CEMA
ROW
2.0
110922B
HWY 2-PIKE CR.
035
T30N
R13W
29,31
CEMA
ROW
20.0
111113B
BEAVER - WILLOW RD.
049
T20N
R09W
3,25
CEMA
ROW
0.5
121820A
BENCHMARK RD.
049
T19N
R09W
6,12
CEMA
ROW
10.0
122301A
HANNON GULCH
099
T22N
R09W
11,35
CEMA
ROW
19.0
ROW SITE TYPE
SUB-TOTAL
68.5
CEMA WEED SPECIES SUB.
-TOTAL
510.7
110801B
N. FORK TETON
099
T25N
R09W
7,8
CIAR
GEN
40.0
110922A
HWY 2-PIKE CR.
035
T29N
R13W
8,5
CIAR
GEN
40.0
121301C
HORSE MOUNTAIN
049
T18N
R08W
9,11
CIAR
GEN
2.0
GEN SITE TYPE
SUB-TOTAL
82.0
111008b
CAVE MOUNTAIN
099
T25N
R09W
26
CIAR
OCC
0.1
120903B
HOME GULCH
049
T22N
R09W
35
CIAR
OCC
0.2
122409C
WILLOW CR. ADMIN.
049
T20N
R09W
26,23
CIAR
OCC
6.0
OCC SITE TYPE
SUB-TOTAL
6.3
110801C
N. FORK TETON
099
T25N
R09W
17,36
CIAR
RIP
7.0
RIP SITE TYPE
SUB-TOTAL
7.0
1 1 1 1 1 3A
BEAVER - WILLOW RD.
049
T20N
R09W
3,25
CIAR
ROW
0.7
112204
PALLOKAVILLE RD.
035
T30N
R12W
25,35
CIAR
ROW
4.0
121820B
BENCHMARK RD.
049
T19N
R09W
6,12
CIAR
ROW
16.0
122301B
HANNON GULCH
099
T22N
R09W
11,35
CIAR
ROW
3.1
ROW SITE TYPE
SUB-TOTAL
23.8
11^
CIAR WEED 5^PFOTF.^ STm-TOTAT
6/27/86
ADDENDUM #3b
2
NOXIOUS WEED INVENTORY
DETAILED LISTING BY WEED SPECIES AND SITE TYPE
FOREST: LEWIS & CLARK N.
F.
DISTRICT
1
PROJECT
WEED
SITE
INV
NUMBER
NAME
COUNTY
T
R
SEC
SPECIES
WEED
ACRES
100001
DEARBORN R. TRAIL
049
T17N
R07W
6
EUES
GEN
1.0
112203
PALOOKAVILLE PAS.
035
T30N
R12W
25
EUES
GEN
1 .0
121301A
HORSE MOUNTAIN
049
T18N
R08W
9,11
EUES
GEN
37.0
GEN SITE TYPE
SUB-TOTAL
122409B
WILLOW CR. ADMIN.
049
T20N
R09W
26,23
EUES
OCC
0.1
OCC SITE TYPE
SUB-TOTAL
100002D
SUN RIVER RD.
049
T21N
R09W
2
EUES
ROW
0.1
ROW SITE TYPE SUB-TOTAL 0.1
EUES WEED SPECIES SUB-TOTAL 39.2
D-1 District Total 669.0
ADDENDUM ^3b
6/27/86 3
NOXIOUS WEED INVENTORY
DETAILED LISTING BY WEED SPECIES AND SITE TYPE
PROJECT
NUMBER
FOREST: LEWIS & CLARK N.F.
NAME COUNTY T R
DISTRICT
WEED
SEC SPECIES
4
SITE INV
WEED ACRES
401032
YOGO CROSSING
045
T13N
R11E
27
CADR
GEN
10.0
GEN SITE TYPE
SUB-TOTAL
10.0
401003B JUDITH ROAD
045
T13N
R1 IE
35
CADR
ROW
1.0
ROW SITE TYPE
SUB-TOTAL
1.0
CADR WEED SPECIES SUB-TOTAL
11.0
401037
WILLOW CR. MUSK
045
T14N
RlOE
8
CANU
GEN
2.0
GEN SITE TYPE
SUB-TOTAL
2.0
CANU WEED SPECIES SUB-TOTAL
2.0
401006
SHED CR.
015
T20N
R10E
8,29
CEMA
GEN
5.0
401014
HIGHWOOD G.S.
015
T20N
R9E
20
CEMA
GEN
1.0
401015
HIGHWOOD CR.
015
T20N
R9E
20
CEMA
GEN
1 .0
401016
TIMBER CR.
015
T20N
R10E
27
CEMA
GEN
1.0
401017
N&S FORK HIGHWOOD
015
T20N
R9E
33,28
CEMA
GEN
1 .0
401018
POSTIL CR.
015
T20N
RlOE
17
CEMA
GEN
2.0
401020
COW CR. TRAIL
045
T19N
R9E
3
CEMA
GEN
3.0
401031
JUDITH STA. K.
045
T13N
R11E
35
CEMA
GEN
0.1
GEN SITE TYPE
SUB-TOTAL
14.1
401007
SHONKIN
015
T20N
RlOE
18,19
CEMA
ROW
5.0
401009
HIGHWOOD ROW
015
T20N
R9E
20
CEMA
ROW
5.0
401025B
HIGHWOOD BALDY RD.
013
T19N
R8E
13
CEMA
ROW
4.5
401029
LONE TREE ROAD
045
T16N
R9E
25
CEMA
ROW
0.1
ROW SITE TYPE
SUB-TOTAL
14.6
CEMA WEED SPECIES SUB-TOTAL
28.7
401002
LITTLE BELT-PINE
013
T19N
R11E
11,12
EUES
GEN
67.0
401005
SPRING COULEE
045
T15N
R9E
24
EUES
GEN
1 .0
401010
WOLF BUTTE
045
T15N
RlOE
4
EUES
GEN
5.0
401019
BLACKTAIL HILLS
045
T15N
RlOE
24
EUES
GEN
15.0
401021
L. BELT CR.-S.PEAK
013
T19N
R9E
25
EUES
GEN
25.0
401023
STARVATION CORNER
045
T19N
R9E
15
EUES
GEN
0.5
401024
DRY GULCH
045
T15N
RlOE
35
EUES
GEN
5.0
401028
SOUTH PEAK
045
T19N
R9E
29
EUES
GEN
0.5
401030
DARK CANYON
045
T1 IN
R13E
2
EUES
GEN
0.3
401033
BUFFALO CANYON
045
T12N
R4E
32
EUES
GEN
5.0
401034
FRENCHIES GULCH
045
T16N
R9E
25,35
EUES
GEN
10.0
401038
LONE TREE SPURGE
045
T16N
R9E
26
EUES
GEN
2.0
GEN SITE TYPE
SUB-TOTAL
136.3
401036
DRY POLE CMPGD.
045
T12N
RUE
23
EUES
OCC
5.0
OCC SITE TYPE
SUB-TOTAL
5.0
401003A JUDITH ROAD
045
T13N
R11E
35
EUES
ROW
1.0
401008B
YOGO CR.
045
T13N
R11E
20
EUES
ROW
1 .0
401025A
HIGHWOOD BALDY RD.
013
T19N
R8E
13
EUES
ROW
0.5
401035
DIVIDE ROAD
045
T15N
RlOE
26,25
EUES
ROW
2.0
I ROW typr ?;im-TnTAT.
6/21/S6
ADDENDUr-i #3b
4
DETAILED
NOXIOUS WEED INVENTORY
LISTING BY WEED SPECIES AND SITE TYPE
FOREST;
LEWIS & CLARK N.F.
DISTRICT 4
PROJECT
NUMBER
NAME
COUNTY T R
WEED SITE
SEC SPECIES WEED
INV
ACRES
EUES WEED SPECIES SUB-
-TOTAL
145.8
401001
RUSSELL -TRASK
045 T12N RUE
12 LIVU GEN 3.0
GEN SITE TYPE SUB-TOTAL
3.0
401008A
YOGO CR.
045 T13N R11E
20 LIVU ROW
1.0
ROW SITE TYPE SUB-TOTAL 1.0
LIVU WEED SPECIES SUB-TOTAL 4.0
D-4 District Total 191.5
6/27/86
ADDENDUM #3b
5
NOXIOUS WEED INVENTORY
DETAILED LISTING BY WEED SPECIES AND SITE TYPE
FOREST: LEWIS & CLARK N.F. DISTRICT 6
PROJECT
NUMBER
NAME
COUNTY
T
R
SEC
WEED
SPECIES
SITE
WEED
INV
ACRES
606904A
PASTURE GULCH RD.
029
T09N
R10E
22,27
CEMA
ROW
5.0
606905
SPRING CR.
059
T09N
R10E
15,10
CEMA
ROW
5.0
606910
FAWN CR. RD.
059
T10N
RlOE
CEMA
ROW
5.0
606911
CASTLES RD.
059
T09N
R09E
CEMA
ROW
3.0
606912
MILL CR. RD.
059
T10N
R09E
11
CEMA
ROW
3.0
ROW SITE TYPE
SUB-TOTAL
CEMA WEED SPECIES SUB-
-TOTAL
606904B
PASTURE GULCH RD.
059
T09N
R10E
CIAR
ROW
1.0
606908
SPRING CR. RD.
059
T09N
R10E
CIAR
ROW
10.0
606909A
FOREST LAKE RD.
059
T06N
RlOE
CIAR
ROW
5.0
606909B
FOREST LAKE RD.
059
T06N
RlOE
CIAR
ROW
5.0
ROW SITE TYPE
SUB-TOTAL
CIAR WEED SPECIES SUB-
-TOTAL
606901A
JUDITH GAP
107
T11N
R15E
19,20
EUES
GEN
37.0
606901B
JUDITH GAP
107
TUN
R15E
19,20
EUES
GEN
50.0
606901C
JUDITH GAP
107
T11N
R15E
19,20
EUES
GEN
25.0
606903A
LITTLE SNOWIES
027
T12N
R21E
24,15
EUES
GEN
10.0
606903B
LITTLE SNOWIES
027
T12N
R21E
24,15
EUES
GEN
15.0
606903C
LITTLE SNOWIES
027
T12N
R21E
24,15
EUES
GEN
1 .0
606906
PORCUPINE
027
T11N
R18E
7
EUES
GEN
1.0
GEN SITE TYPE
SUB-TOTAL
606902
BIG SNOWIES
037
T11N
R19E
17
EUES
ROW
5.0
ROW SITE TYPE SUB-TOTAL
EUES WEED SPECIES SUB-TOTAL
21.0
21.0
21.0
21.0
139.0
5.0
144.0
D-6 District Total
186.0
6/27/86
ADDENDUM #3b
6
NOXIOUS WEED INVENTORY
DETAILED LISTING BY WEED SPECIES AND SITE TYPE
PROJECT
NUMBER
FOREST: LEWIS & CLARK N.
NAME COUNTY T
F.
R
DISTRICT 7
WEED SITE
SEC SPECIES WEED
INV
ACRES
777779
COPPER CR.
059
T11N
R06E
5 , 6 CEMA
GEN
5.0
GEN SITE TYPE SUB-TOTAL
5.0
777771A
US89 ROW CASCADE
013
T13N
R08E
CEMA
ROW
30.0
777772A
US89 ROW MEAGHER
059
T12N
R08E
CEMA
ROW
20.0
777772B
US89 ROW MEAGHER
059
T12N
R08E
CEMA
ROW
10.0
777773
MEAGHER CO. RD.
059
CEMA
ROW
38.0
ROW SITE TYPE SUB-TOTAL
98.0
CEMA WEED SPECIES SUB-
-TOTAL
103.0
777775
MCGEE COULEE
013
T16N
R08E
31 EUES
GEN
1.0
777776
MING COULEE
013
T16N
R05E
28 EUES
GEN
2.0
777777D
TENDERFOOT
059
T14N
R04E
30 EUES
GEN
5.0
777778
LOGGING CR. SPURGE
013
T15N
R05E
1 2 EUES
GEN
0.1
GEN SITE TYPE SUB-TOTAL
8.1
777777A
SMITH RIVER
013
T15N
R03E
30,31 EUES
RIP
35.0
777777B
SMITH RIVER
059
T14N
R03E
12,13 EUES
RIP
15.0
777777C
SMITH RIVER
059
T14N
R04E
6,18 EUES
RIP
10.0
RIP SITE TYPE SUB-TOTAL
60.0
777771B
US89 ROW MEAGHER
013
T13N
ROSE
EUES
ROW
10.0
ROW SITE TYPE SUB-TOTAL
10.0
EUES WEED SPECIES SUB-
-TOTAL
78.1
777780
COOKS CORNER
059
T12N
R07E
28 LIDA
GEN
2.0
GEN SITE TYPE SUB-TOTAL
2.0
LIDA WEED SPECIES SUB-
-TOTAL
2.0
D-7 Kings Hill District Total 183.1
Forest Total
1229.6
6/30/86
ADDENDUM #3c
SlirtflARY
1
DISTRICT: 1
TOTAL
DISTRICT: 4
TOTAL
DISTRICT: 6
TOTAL
DISTRICT: 7
TOTAL
Forest Totals:
NOXIOUS UEED INVENTORY
SUMMARY OF PESTICIDE USE
NUMBER OF PESTICIDES = 2 I NUMBER OF PESTICIDES = 1
PROPOSED
ACRES
TREATED
ACTUAL
ACRES
TREATED
PROPOSED
POUNDS
PEST.l
(208)*
ACTUAL
POUNDS
PEST.l
(208)*
PROPOSED
POUNDS
PEST. 2
(225)*
ACTUAL 1
POUNDS 1
PEST. 2 1
(225)*
I PROPOSED
POUNDS
1 208
ACTUAL
POUNDS
208
PROPOSED
POUNDS
225
actual
POUNDS
225
38.0
0.0
5.10
0.00
2.80
0.00 1
58.1
0.0
1
37.00
0.00
100.2
0.0
1
9.80
0.00
196.3
NUMBER OF PESTICIDES = 2
1
! NUMBER OF PESTICIDES =
1
PROPOSED
ACTUAL
PROPOSED
ACTUAL
PROPOSED
ACTUAL 1
1 PROPOSED
ACTUAL
PROPOSED
ACTUAL
ACRES
ACRES
POUNDS
POUNDS
POUNDS
POUNDS 1
POUNDS
POUNDS
POUNDS
POUNDS
TREATED
TREATED
PEST.l
(208)*
PEST.l
(208)*
PEST.2
(225)*
PEST.2 1
(225)*
: 208
208
225
225
11.0
0.0
1 12.00
0.00
99.2
0.0
1
56.35
0.00
110.2
NUMBER OF PESTICIDES = 2
1
NUMBER OF PESTICIDES =
1
PROPOSED
ACTUAL
PROPOSED
ACTUAL
PROPOSED
ACTUAL 1
PROPOSED
ACTUAL
PROPOSED
ACTUAL
ACRES
ACRES
POUNDS
POUNDS
POUNDS
POUNDS 1
POUNDS
POUNDS
POUNDS
POUNDS
TREATED
TREATED
PEST.l
PEST.l
PEST.2
PEST.2 1
I 208
208
225
225
(208)*
(208)*
(225)*
(225)*
107.0
0.0
115.90
0.00
30.50
0.00 1
1
47.0
0.0
1
6.75
0.00
154.0
NUMBER OF PESTICIDES = 2 I NUMBER OF PESTICIDES = 1
PROPOSED
ACRES
TREATED
ACTUAL
ACRES
TREATED
PROPOSED
POUNDS
PEST.l
(208)*
ACTUAL
POUNDS
PEST.l
(208)*
PROPOSED
POUNDS
PEST.2
(225)*
ACTUAL 1
POUNDS 1
PEST.2 1
(225)*
PROPOSED
POUNDS
1 208
ACTUAL
POUNDS
208
PROPOSED
POUNDS
225
ACTUAL
POUNDS
225
63.0
0.0
36.00
0.00
18.00
0.00 1
1
50.0
0.0
1
150.00
0.00
48.1
0.0
1
I
14.50
0.00
161.1
621 .6
acres
356.0 lbs. 2,4-D (code 208)
138.7 lbs. picloram (code 225)
* ASSUMING THAT FIRST PESTICIDE=208 AND SECOND PESTICIDE=225
'V.
6/30/86
ADDENDUM m
NOXIOUS WEED INVENTORY
PESTICIDE USE APPLICATION BY PROJECT
FOREST:
LEWIS 6 CLARK N.F.
DISTRICT
1
TARGET
PROJECT
-
SITE WEED PEST CANOPY
INV REG.
AI TYPE MEASURE APPL.
PROPOSED
actual
NUHBER
NAME
COUNTY T
R SEC
TYPE SPECIES CODE COVER
ACRES CODE
CODE CODE CODE RATE
LBS.
LBS.
100001 DEARBORN R. TRAIL
049
T17N R07W 6 GEN EUES
408 S
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 2
PESTICIDE
«1
1
208
3
1
1.00
0.10
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
2
225
3
1
5.00
0.30
0.00
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
0.00
100002A SUN
RIVER RD.
049
T21N R09H 2,3 ROW CEMA
408 S
17.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
♦1
2
225
3
1
0.25
2.00
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
17.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
0.00
100002B SUN
RIVER
049
T21N R09W 3,4 RIP CEMA
408 S
96.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
1
208
3
1
2.00
2.00
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
4.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
0.00
100002C SUN
RIVER
049
T22N R09W 35,36 RIP CEMA
408 S
162.0
DILUENT CODE =
1
NUHBER OF PESTICIDES = 1
PESTICIDE
41
1
208
3
1
2.00
4.00
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0.00
PROPOSED ACRES
=
6.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
0.00
100002D SUN
RIVER RD.
049
T21N R09W 2 ROW EUES
408 S
0.1
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
♦1
2
225
3
1
0.50
0.05
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
0.1 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
110304 VOLCANO REEF
099
T26N R09H 12 GEN CEMA
408 S
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.25
0.03
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
110414A S.
FORK TETON
099
T24N R09H 2,4 RIP CEMA
408 S
18.1
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
1
208
3
1
2.00
12.20
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
18.1 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
110414E: S.
FORK TETON
099
T24N R09W 2,4 RIP CEMA
408 S
2.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
n
i.
225
3
1
0.25
0.50
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
2.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
110801A N.
FORK TETON
099
T25N R09W 7,8 ROW CEMA
408 S
2.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.25
0.25
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
2.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
110801D N.
FORK TETON
099
T25N R09W 25,36 RIP CEMA
408 L
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.25
0.25
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
110801E N.
FORK TETON
099
T25N R09W 25,36 RIP CEMA
408 L
77.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
1
208
3
1
2.00
8.80
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
10.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
110922B HWY
2-PIKE CR.
035
T30N R13W 29,31 ROW CEMA
408 S
20.0
DILUENT CODE =
1
NUHBER OF PESTICIDES = 1
PESTICIDE
41
1
208
3
1
2.00
10.00
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
20.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
1
Srt o ^ ^ oO^ ^ ^ ^ 9 ^ <=»Oq 0^0
O OOO OOO OOO OOO OOQ OOQ ooo ooo
6/30/86
ADDENDUM #3cl
NOXIOUS WEED INVENTORY
FfSTICIDE USE APPLICATION BY PROJECT
FOREST: LEWIS 6 CLARK N.F. DISTRICT 1
TARGET
PROJECT
NUMBER NAME COUNTY
SITE WEED PEST CANOPY
T R SEC TYPE SPECIES CODE COVER
INV
ACRES
REG.
CODE
AI
CODE
TYPE MEASURE APPL.
CODE CODE RATE
PROPOSED
LBS.
ACTUAL
LBS.
lllOOBA CAVE MOUNTAIN
099
T25N R09W 26 OCC CEMA
408 S
5.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
tl
2
225
3
1
0.25
0.63
0.0(
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.0(
PROPOSED ACRES
=
5.0 ACTUAL ACRES = 0.0
PESTICIDE
#3
0.00
0.00
0.0(
111008B CAVE MOUNTAIN
099
T25N R09W 26 OCC CIAR
408 S
0.1
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
0.50
0.05
0.0(
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0.0(
PROPOSED ACRES
=
0.1 ACTUAL ACRES = 0.0
PESTICIDE
#3
0.00
0.00
0.0<
111113B BEAVER - WILLOW RD.
049
T20N R09W 3,25 ROW CEMA
408 S
0.5
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
2
225
3
1
0.50
0.05
0.0(
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.0(
PROPOSED ACRES
=
0.5 ACTUAL ACRES = 0.0
PESTICIDE
«3
0.00
0.00
0.01
112203 PALOOKAVILLE PAS.
035
T30N R12W 25 GEN EUES
408 S
1.0
DILUENT CODE =
0
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
0.50
0.05
0.0(
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.0(
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
«3
0.00
0.00
O.Ot
112204 PALLOKAVILLE RD.
035
T30N R12W 25,35 ROW CIAR
408 S
4.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
3
225
3
1
0.50
0.50
O.Oi
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
O.OI
PROPOSED ACRES
=
4.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
0.0'
112403 EAR MOUNTAIN
099
T24N R08W 4 GEN CEMA
408 S
5.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.25
0.13
0.0'
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
O.Ol
PROPOSED ACRES
=
5.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
O.O'I
120903A HOME GULCH
049
T22N R09W 35 OCC CEMA
408 L
4.0
i
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
0.25
0.50
0.01
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0.0
PROPOSED ACRES
=
4.0 ACTUAL ACRES = 0.0
PESTICIDE
*3
0.00
0.00
0.0
1209038 HOME GULCH
049
T22N R09W 35 OCC CIAR
408 S
0.2
j
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
il
2
225
3
1
0.25
0.03
0.0
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.0
PROPOSED ACRES
=
0.2 ACTUAL ACRES = 0.0
PESTICIDE
#3
0.00
0.00
0.0)
121301A HORSE MOUNTAIN
049
T18N R08W 9,11 GEN EUES
408 S
37.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 2
PESTICIDE
41
1
208
3
1
1.00
5.00
0.01
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
2
225
3
1
0.50
2.50
0.0
PROPOSED ACRES
37.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.0
1213018 SAWMILL CREEK
049
T18N R08W 9,11 GEN CEMA
408 S
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.25
0.03
0.0;
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.0
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.0
121301C HORSE MOUNTAIN
049
T18N R08W 9,11 GEN CIAR
408 S
2.0
1
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.50
0.10
0.0
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.0
PROPOSED ACRES
=
2.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.0
121820A BENCHMARK RD.
049
T19N R09W 6,12 ROW CEMA
408 S
10.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.50
0.50
0.0
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.0
PROPOSED ACRES
10.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.0
2
6/30/86
3
AnULNUUM #36 .
NOXIOUS UEED INVENTORY
PESTICIDE USE APPLICATION BY PROJECT
FOREST:
LEWIS 6 CLARK N.F.
DISTRICT
1
TARGET
PROJECT
.
SITE HEED PEST CANOPY
INV REG.
A I TYPE MEASURE APPL. PROPOSED
ACTUA
NUNBER
NAME
COUNTY T R SEC
TYPE SPECIES CODE COVER
ACRES CODE
CODE CODE CODE RATE LBS.
LBS.
121820B BENCHMARK RD.
049
T19N R09W 6,12 ROW
CIAR
408 S
16.0
DILUENT CODE =
1
NUMBER OF PESTICIDES =
1
PESTICIDE
«1
2
225
3
1
0.50
1.25
0.00
TREATMENT UNIT
C0DE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
16.0 ACTUAL ACRES =
0.0
PESTICIDE
♦3
0.00
0.00
0.00
122301A HANNON GULCH
099
T22N R09H 11,35 ROW
CEMA
408 L
19.0
DILUENT CODE =
1
NUMBER OF PESTICIDES =
1
PESTICIDE
41
2
225
3
1
0.25
1.50
0.00
TREATMENT UNIT
C0DE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
19.0 ACTUAL ACRES =
0.0
PESTICIDE
43
0.00
0.00
0.00
1223018 HANNON GULCH
099
T22N R09H 11,35 ROW
CIAR
408 S
3.1
DILUENT CODE =
1
NUMBER OF PESTICIDES =
1
PESTICIDE
41
2
225
3
1
0.50
0.25
0.00
TREATMENT UNIT
C0DE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
z
3.1 ACTUAL ACRES =
0.0
PESTICIDE
43
0.00
0.00
0.00
122409A WILLOW CR. ADMIN.
049
T20N R09H 26,23 OCC
CEMA
408 S
0.1
DILUENT CODE =
1
NUMBER OF PESTICIDES =
1
PESTICIDE
41
2
225
3
1
0.25
0.50
0.00
TREATMENT UNIT
C0DE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
0.1 ACTUAL ACRES =
0.0
PESTICIDE
43
0.00
0.00
0.00
122409B WILLOW CR. ADMIN.
049
T20N R09H 26,23 OCC
EUES
408 S
0.1
DILUENT CODE =
1
NUMBER OF PESTICIDES =
1
PESTICIDE
41
2
225
3
1
0.50
0.05
0.00
TREATMENT UNIT
C0DE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
=
0.1 ACTUAL ACRES =
0.0
PESTICIDE
43
0.00
0.00
0.00
122409C WILLOW CR. ADMIN.
049
T20N R09H 26,23 OCC
CIAR
408 L
6.0
DILUENT CODE =
1
NUMBER OF PESTICIDES =
1
PESTICIDE
41
2
225
3
1
0.50
0.60
0.00
TREATMENT UNIT
C0DE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.00
PROPOSED ACRES
z
6.0 ACTUAL ACRES =
0.0
PESTICIDE
43
0.00
0.00
0.00
3
Oo ^ ^ ^
oo OOO OOO OOO ooo
6/30/86
ADDENDUM #3d
NOXIOUS WEED INVENTORY
PESTICIDE USE APPLICATION BY PROJECT
FOREST: LEWIS i CLARK N.F. DISTRICT 4
TARGET
PROJECT
NUMBER
NAME COUNTY
SITE WEED PEST CANOPY
T R SEC TYPE SPECIES CODE COVER
INV
ACRES
REG.
CODE
AI
CODE
TYPE MEASURE APPL. PROPOSED
CODE CODE RATE LBS.
ACTUf
LBS
401002
LITTLE BELT-PINE
013
T19N RUE 11,12 GEN EUES
408 H
67.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
1.00
12.00
0.'
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0.'
PROPOSED ACRES
15.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
0.1
401003A JUDITH ROAD
045
T13N RUE 35 ROW EUES
408 L
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
1
208
3
1
2.00
2.00
0.'
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.'
PROPOSED ACRES
z
1.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
0/
401003B JUDITH ROAD
045
T13N RUE 35 ROW CADR
408 L
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.50
0.25
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.
401005
SPRING COULEE
045
T15N R9E 24 GEN EUES
408 M
1.0
1
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
1.00
0.50
0.!
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.
PROPOSED ACRES
z
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.1
401006
SHED CR.
015
T20N RlOE 8,29 GEN CEMA
408 L
5.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
n
225
3
1
0.50
1.25
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
O.j
PROPOSED ACRES
=
5.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.
401007
SHONKIN
015
T20N RlOE 18,19 ROW CEMA
408 S
5.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.50
2.50
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.
PROPOSED ACRES
=
5.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.
401008A YOGO CR.
045
T13N RUE 20 ROW LIVU
408 L
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
n
225
3
1
0.50
0.25
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.
PROPOSED ACRES
z
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.
4010088 YOGO CR.
045
T13N RUE 20 ROW EUES
408 L
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
n
225
3
1
1.00
0.50
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.!
PROPOSED ACRES
z
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.
401009
HIGHUOOD ROW
015
T20N R9E 20 ROW CEMA
408 S
5.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.50
2.50
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.
PROPOSED ACRES
z
5.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.
401010
WOLF BUTTE
045
T15N RlOE 4 GEN EUES
408 H
5.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
1.00
2.50
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.
PROPOSED ACRES
z
5.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.
401014
HIGHWOOD G.S.
015
T20N R9E 20 GEN CEMA
408 S
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
n
i.
225
3
1
0.50
0.25
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0.
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
o.j
401015
HIGHWOOD CR.
015
T20N R9E 20 GEN CEMA
408 S
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
2
225
3
1
0.50
0.25
0.
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
42
0.00
0.00
0,
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.
4
6/30/86
ADDENDUM m
NOXIOUS WEED INVENTORY
PESTICIDE USE APPLICATION BY PROJECT
FOREST:
LEWIS i CLARK N.F.
DISTRICT i
TARGET
PROJECT
SITE WEED PEST CANOPY
INV REG. AI
TYPE MEASURE APPL.
PROPOSED
actual
NUMBER
NAME
COUNTY T ’
R SEC
TYPE SPECIES CODE COVER
ACRES CODE CODE
CODE CODE RATE
LBS.
LBS.
401017
N6S FORK HIGHWOOD
015
T20N R9E 33,28 GEN CEMA
408 S
1.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
2
225
3
1
0.50
0.25
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.00
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
«3
0.00
0.00
0.00
401018
POSTIL CR.
015
T20N RlOE 17 GEN CEMA
408 L
2.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
2
225
3
1
0.50
0.25
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
«3
0.00
0.00
0.00
401019
BLACKTAIL HILLS
045
T15N RlOE 24 GEN EUES
408 M
15.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
2
225
3
1
1.00
10.00
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
15.0 ACTUAL ACRES = 0.0
PESTICIDE
#3
0.00
0.00
0.00
401020
COW CR. TRAIL
045
T19N R9E 3 GEN CEMA
408 L
3.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
2
225
3
1
0.50
0.25
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
1.0 ACTUAL ACRES = 0.0
PESTICIDE
«3
0.00
0.00
0.00
401021
L. BELT CR.-S.PEAK
013
T19N R9E 25 GEN EUES
408 H
25.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
♦1
2
225
3
1
1.00
8.00
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0.00
PROPOSED ACRES
=
10.0 ACTUAL ACRES = 0.0
PESTICIDE
i3
0.00
0.00
0.00
401023
STARVATION CORNER
045
T19N R9E 15 GEN EUES
408 S
0.5
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
2
225
3
1
1.00
0.50
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0.00
PROPOSED ACRES
r
0.5 ACTUAL ACRES = 0.0
PESTICIDE
«3
0.00
0.00
0.00
401024
DRY GULCH
045
T15N RlOE 35 GEN EUES
408 M
5.0
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
41
0
L.
225
3
1
0.50
1.75
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.00
PROPOSED ACRES
=
5.0 ACTUAL ACRES = 0.0
PESTICIDE
*3
0.00
0.00
0.00
401025A HIGHWOOD BALDY RD.
013
T19N R8E 13 ROW EUES
408 M
0.5
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
0.50
0.25
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.00
PROPOSED ACRES
=
0.5 ACTUAL ACRES = 0.0
PESTICIDE
iZ
0.00
0.00
0.00
401025B HIGHWOOD BALDY RD.
013
T19N R8E 13 ROW CEMA
408 L
4.5
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
0.50
2.25
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
4.5 ACTUAL ACRES = 0.0
PESTICIDE
#3
0.00
0.00
0.00
401028
SOUTH PEAK
045
T19N R9E 29 GEN EUES
408 S
0.5
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
0
t.
225
3
1
1.00
0.50
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.00
PROPOSED ACRES
=
0.5 ACTUAL ACRES = 0.0
PESTICIDE
*3
0.00
0.00
0.00
401029
LONE TREE ROAD
045
TUN R9E 25 ROW CEMA
408 S
0.1
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
0.50
0.05
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
0.1 ACTUAL ACRES = 0.0
PESTICIDE
*3
0.00
0.00
0.00
401031
JUDITH STA. K.
045
T13N RUE 35 GEN CEMA
408 S
0.1
DILUENT CODE =
1
NUMBER OF PESTICIDES = 1
PESTICIDE
11
2
225
5
1
0.50
0.05
0.00
TREATMENT UNIT
CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
=
0.1 ACTUAL ACRES = 0.0
PESTICIDE
*Z
0.00
0.00
0.00
5
8 0 oOo ^ 9 ^ o^C>
o oOo 000 000 ooc> 000 000 000 oc5o 000
6/30/86
ADDENDUM #3d
NOXIOUS UEEO INOENTORY
PESTICIDE USE APPLICATION BY PROJECT
PROJECT
NUMBER
NAME COUNTY
FOREST: LEWIS i CLARK N.F.
TARGET
SITE WEED PEST CANOPY
T R SEC TYPE SPECIES CODE COVER
DISTRICT
INV REG.
ACRES CODE
4
AI
CODE
TYPE MEASURE APPL. PROPOSED
CODE CODE RATE LBS.
ACTL
LBS
401032
YOGO CROSSING 045
T13N RUE 27 GEN CADR
408 L
10.0
DILUENT CODE = 1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
1
208
3
1
2.00
10.00
0.
TREATMENT UNIT CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0,
PROPOSED ACRES =
10.0 ACTUAL ACRES = 0.0
PESTICIDE
13
0.00
0.00
0.
401033
BUFFALO CANYON 045
T12N R4E 32 GEN EUES
408 M
5.0
DILUENT CODE = 1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
1.00
2.50
0,i
TREATMENT UNIT CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0
PROPOSED ACRES =
5.0 ACTUAL ACRES = 0.0
PESTICIDE
#3
0.00
0.00
0,
401034
FRENCH I ES GULCH 045
T16N R9E 25,35 GEN EUES
408 M
10.0
DILUENT CODE = 1
NUMBER OF PESTICIDES = 1
PESTICIDE
*1
2
225
3
1
1.00
5.50
0
TREATMENT UNIT CODE=
1 METHOD CODE = 206
PESTICIDE
#2
0.00
0.00
0
PROPOSED ACRES =
10.0 ACTUAL ACRES = 0.0
PESTICIDE
*3
0.00
0.00
0
401035
DIVIDE ROAD 045
T15N RlOE 26,25 ROW EUES
408 L
2.0
DILUENT CODE = 1
NUMBER OF PESTICIDES = 1
PESTICIDE
«1
2
225
3
1
0.50
0.50
0
TREATMENT UNIT CODE=
1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0
PROPOSED ACRES =
2.0 ACTUAL ACRES = 0.0
PESTICIDE
13
0.00
0.00
0
401038
LONE TREE SPURGE 045
T16N R9E 26 GEN EUES
408 M
2.0
DILUENT CODE = 1
NUMBER OF PESTICIDES = 1
PESTICIDE
#1
2
225
3
1
1.00
1.00
0
TREATMENT UNIT CODE=
1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0
PROPOSED ACRES =
2.0 ACTUAL ACRES = 0.0
PESTICIDE
*3
0.00
0.00
Oi
6
6/30/86
ADDENDUM ^3d
NOXIOUS WEED INVENTORY
PESTICIDE USE APPLICATION BY PROJECT
FOREST:
LEWIS 6 CLARK N.F.
DISTRICT
6
TARGET
PROJECT
-
SITE WEED PEST CANOPY
INV REG.
AI
TYPE HEASURE APPL, PROPOSED
actual
NUHBER
NAME
COUNTY T
R SEC
TYPE SPECIES CODE COVER
ACRES CODE
CODE
CODE CODE RATE LBS.
LBS.
606901 A JUDITH GAP
107 TUN R15E 19,20 GEN EUES
408 L 37.0
DILUENT CODE =
0 NUMBER OF PESTICIDES = 1
PESTICIDE 11
3
225
3
1
0.50
5.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 209
PESTICIDE *2
0.00
0.00
0.00
PROPOSED ACRES
= 37.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606901E! JUDITH GAP
107 TUN RISE 19,20 GEN EUES
408 M 50.0
DILUENT CODE =
1 NUHBER OF PESTICIDES = 2
PESTICIDE 11
1
208
3
1
0.50
28.50
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
2
225
3
1
1.90
7.50
0.00
PROPOSED ACRES
= 50.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606901C JUDITH GAP
107 TUN RISE 19,20 GEN EUES
408 H 25.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE 41
1
208
3
1
1.90
47.50
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
2
225
3
1
0.50
12.50
0.00
PROPOSED ACRES
= 25.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606902 BIG SNOWIES
037 TUN R19E 17 ROW EUES
408 L 5.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE 41
1
208
3
1
1.90
3.80
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
0
X.
225
3
1
0.50
1.00
0.00
PROPOSED ACRES
= 5.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606903A LITTLE SNOWIES
027 T12N R21E 24,15 GEN EUES
408 L 10.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE 41
1
208
3
1
1.90
9.50
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
0
225
3
1
0.50
2.50
0.00
PROPOSED ACRES
= 10.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606903B LITTLE SNOWIES
027 T12N R21E 24,15 GEN EUES
408 M 15.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE 41
1
208
3
1
0.50
22.80
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
0
225
3
1
0.50
6.00
0.00
PROPOSED ACRES
= 15.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606903C LITTLE SNOWIES
027 T12N R21E 24,15 GEN EUES
408 H 1.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE 41
1
208
3
1
1.90
1.90
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
2
225
3
1
0.50
0.50
0.00
PROPOSED ACRES
= 1.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606904A PASTURE GULCH RD.
029 T09N RlOE 22,27 ROW CEMA
408 L 5.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 1
PESTICIDE 41
2
225
3
1
0.25
0.75
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
0.00
0.00
0.00
PROPOSED ACRES
= 5.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606905 SPRING CR.
059 T09N RlOE 15,10 ROW CEMA
408 L 5.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 1
PESTICIDE 41
2
225
3
1
0.25
1.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
0.00
0.00
0.00
PROPOSED ACRES
= 5.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
606906 PORCUPINE
027 TUN RISE 7 GEN EUES
408 M 1.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE 41
1
208
3
1
1.90
1.90
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE 42
0
225
3
1
0.50
0.50
0.00
PROPOSED ACRES
= 1.0 ACTUAL ACRES = 0.0
PESTICIDE 43
0.00
0.00
0.00
7
88g 88§ 888 888 88§ 888 888 888 888 888
ADDENDUM #3d
6/30/86 8
NOXIOUS WEED INVENTORY
PESTICIDE USE APPLICATION BY PROJECT
FOREST; LEWIS 6 CLARK N.F. DISTRICT 7
TARGET
PROJECT SITE WEED PEST CANOPY
NUMBER NAME COUNTY T R SEC TYPE SPECIES CODE COVER
INV
ACRES
REG.
CODE
AI
CODE
TYPE MEASURE APPL. PROPOSED
CODE CODE RATE LBS.
ACTUAL
LBS.
777771A US89 ROW CASCADE
013 T13N ROSE ROW CEMA
408 S
30.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 1
PESTICIDE
«1
1
208
3
1
3.00
90.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0.00
PROPOSED ACRES
= 30.0 ACTUAL ACRES = 0.0
PESTICIDE
13
0.00
0.00
0.00 I
777771B US89 ROW MEAGHER
013 T13N ROSE ROW EUES
408 S
10.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 1
PESTICIDE
«1
2
225
3
1
0.50
5.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.00
PROPOSED ACRES
= 10.0 ACTUAL ACRES = 0.0
PESTICIDE
*3
0.00
0.00
0.00
777772A US89 ROW MEAGHER
059 T12N ROSE ROW CEMA
408 S
20.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 1
PESTICIDE
«1
1
208
3
1
3.00
60.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
*2
0.00
0.00
0.00
PROPOSED ACRES
= 20.0 ACTUAL ACRES = 0.0
PESTICIDE
#3
0.00
0.00
0.00
7777728 US89 ROW MEAGHER
059 T12N ROSE ROW CEMA
408 S
10.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE
«1
1
208
3
1
1.00
10.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
*2
0
225
3
1
0.50
5.00
0.00
PROPOSED ACRES
= 10.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00 i
777773 MEAGHER CO. RD.
059 ROW CEMA
408 S
38.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 1
PESTICIDE
#1
3
225
3
1
0.25
3.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
♦2
0.00
0.00
0.00
PROPOSED ACRES
= 28.0 ACTUAL ACRES = 0.0
PESTICIDE
*3
0.00
0.00
0.00
777775 MCGEE COULEE
013 T16N ROSE 31 GEN EUES
408 M
1.0
DILUENT CODE =
0 NUMBER OF PESTICIDES = 1
PESTICIDE
«1
3
225
3
1
1.00
1.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 209
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
= 1.0 ACTUAL ACRES = 0.0
PESTICIDE
♦3
0.00
0.00
0.00
777776 MING COULEE
013 T16N R05E 28 GEN EUES
408 L
2.0
j
DILUENT CODE =
0 NUMBER OF PESTICIDES = 1
PESTICIDE
«1
3
225
3
1
1.00
1.99
0.00 1
TREATMENT UNIT
CODE= 1 METHOD CODE = 209
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES
= 2.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
777777A SMITH RIVER
013 T15N R03E 30,31 RIP EUES
408 M
35.0
;
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE
«1
1
208
3
1
1.00
12.00
0.00 !
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
♦2
2
225
1
1
0.50
6.00
0.00
PROPOSED ACRES
= 30.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
777777B SMITH RIVER
059 T14N R03E 12,13 RIP EUES
408 M
15.0
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE
41
1
208
3
1
1.00
5.00
0.00
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
42
n
t.
225
3
1
0.50
2.50
0.00
PROPOSED ACRES
= 10.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00
777777C SMITH RIVER
059 T14N R04E 6,18 RIP EUES
408 M
10.0
i
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE
41
1
208
3
1
1.00
4.00
0.00 1
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
42
2
225
3
1
0.50
2.00
0.00
PROPOSED ACRES
= 8.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00,
777777D TENDERFOOT
059 T14N R04E 30 GEN EUES
408 L
5.0
1
DILUENT CODE =
1 NUMBER OF PESTICIDES = 2
PESTICIDE
41
1
208
3
1
1.00
5.00
O.OOl
TREATMENT UNIT
CODE= 1 METHOD CODE = 206
PESTICIDE
42
2
225
3
1
0.50
2.50
0.00
PROPOSED ACRES
= 5.0 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
O.OOl
777778 LOGGING CR. SPURGE
013 T15N R05E 12 GEN EUES
408 S
0.1
DILUENT CODE =
0 NUMBER OF PESTICIDES = 1
PESTICIDE
41
3
225
3
1
0.50
0.01
O.OOl
TREATMENT UNIT
CODE= 1 METHOD CODE = 209
PESTICIDE
42
0.00
0.00
O.OOl
PROPOSED ACRES
= 0.1 ACTUAL ACRES = 0.0
PESTICIDE
43
0.00
0.00
0.00 i
8
6/30/86
ADDENDUM #3d
9
NOXIOUS UEEO INVENTORY
PESTICIDE USE APPLICATION BY PROJECT
PROJECT
NUhBER
NAME COUNTY
FOREST; LEUIS 6 CLARK N.F.
TARGET
SITE HEED PEST CANOPY
T R SEC TYPE SPECIES CODE COVER
DISTRICT
INV REG.
ACRES CODE
7
AI
CODE
TYPE MEASURE APPL.
CODE CODE RATE
PROPOSED
LBS.
actual
L8S.
777779
COPPER CR. 059
TUN R06E 5,6 GEN CEMA
408 L
5.0
DILUENT CODE = 0
NUMBER OF PESTICIDES = 1
PESTICIDE
3
225
3
1
0.50
2.50
0.00
TREATMENT UNIT CODE=
1 METHOD CODE = 209
PESTICIDE
♦2
0.00
0.00
0.00
PROPOSED ACRES =
5.0 ACTUAL ACRES = 0.0
PESTICIDE
«3
0.00
0.00
0.00
777780
COOKS CORNER 059
T12N R07E 28 GEN LIDA
408 L
2.0
DILUENT CODE = 0
NUMBER OF PESTICIDES = 1
PESTICIDE
3
225
3
1
0.50
1.00
0.00
TREATMENT UNIT CODE=
1 METHOD CODE = 209
PESTICIDE
#2
0.00
0.00
0.00
PROPOSED ACRES =
2.0 ACTUAL ACRES = 0.0
PESTICIDE
13
0.00
0.00
0.00
9
6/30/86
ADDENDUM #3e'
30-JUN'86
PAGC
NOXIOUS UEEO INVENTORY
DETAILED LISTING OF MECHANICAL TREATMENTS BY HEED SPECIES AND SITE TYPE
FOREST: LEHIS 6 CLARK N.F.
PROJECT
NUMBER NAME
COUNTY
T R
SEC
HEED SITE
SPECIES HEED
INV
ACRES
TREAT
TYPE
PROP
ACRES
ACTUAL
ACRES
DISTRICT 1
111008A CAVE MOUNTAIN
099
T25N R09W
26
CEMA
OCC
5.0
1
1.0
0.0
120903A HOME GULCH
049
T22N R09H
35
CEMA
OCC
4.0
1.0
0.0
100002C SUN RIVER
049
T22N R09H
35,36
CEMA
RIP
162.0
1
5.0
0.0
111113A BEAVER - HILLOH RD.
049
T20N R09H
3,25
CIAR
ROH
0.7
1
0.7
0.0
TOTAL INV.
ACRES
171.7
TOTAL TREAT ACRES
7.7
0.0
DISTRICT 4
401016 TIMBER CR.
015
T20N RlOE
27
CEMA
GEN
1.0
1
1.0
0.0
401018 POSTIL CR.
015
T20N RlOE
17
CEMA
GEN
2.0
1
1.0
0.0
401020 COH CR. TRAIL
045
T19N R9E
3
CEMA
GEN
3.0
1
2.0
0.0
401036 DRY POLE CMPGD.
045
T12N RUE
23
EUES
OCC
5.0
1
5.0
0.0
TOTAL INV.
ACRES
11.0
TOTAL TREAT ACRES
9.0
0.0
DISTRICT 6
606911 CASTLES RD.
059
T09N R09E
CEMA
ROH
3.0
1
3.0
0.0
606912 HILL CR. RD.
059
TION R09E
11
CEMA
ROH
3.0
1
3.0
0.0
TOTAL INV.
ACRES
6.0
TOTAL TREAT ACRES
6.0
0.0
DISTRICT 7
777773 MEAGHER CO. RD.
059
CEMA
ROH
38.0
1
10.0
0.0
TOTAL INV.
ACRES
38.0
TOTAL TREAT ACRES
10.0
0.0
Forest Total
32.7
ADDENDUM 3f
NOXIOUS WEED INVENTORy I
DETAILED LISTING OF BIOLOGICAL TREATMENTS BY UEEO SPECIES AND SITE TYPE
FOREST: LEWIS i CLARK N.F.
PROJECT
NUMBER NAME
COUNTY
T
R
SEC
WEED SITE
SPECIES WEED
INV
ACRES
BIOL PROP
AGENT ACRES
ACTUAL
ACRES
DISTRICT 1
121820C FORD CR. RESORT
049
T19N
R09W
12
CEMA
OCC
10.0
URAF
10.0
0.0
100002B SUN RIVER
049
T21N
R09W
3,4
CEMA
RIP
96.0
URAF
92.0
0.0
100002C SUN RIVER
049
T22N
R09W
35,36
CEMA
RIP
162.0
URAF
151.0
0.0
110801E N. FORK TETON
099
T25N
R09W
25,36
CEMA
RIP
77.0
URAF
67.0
0.0
121820D FORD CR. RESORT
049
T19N
R09W
12
CEMA
RIP
40.0
URAF
40.0
0.0
TOTAL INV.
ACRES
385.0
TOTAL TREAT ACRES
360.0
0.0
DISTRICT 4
401037 WILLOW CR. MUSK
045
T14N
RlOE
8
CANU
GEN
2.0
RHCO
2.0
0.0
TOTAL INV.
ACRES
2.0
TOTAL TREAT ACRES
2.0
0.0
DISTRICT 6
606910 FAWN CR. RD.
059
TION
RlOE
CEMA
ROW
5.0
URAF
5.0
0.0
606904B PASTURE GULCH RD.
059
T09N
RlOE
CIAR
ROW
1.0
URAF
1.0
0.0
606908 SPRING CR. RD.
059
T09N
RlOE
CIAR
ROW
10.0
URAF
10.0
0.0
606909A FOREST LAKE RD.
059
T06N
RlOE
CIAR
ROW
5.0
URAF
5.0
0.0
606909E: FOREST LAKE RD.
059
T06N
RlOE
CIAR
ROW
5.0
URAF
5.0
0.0
TOTAL INV.
ACRES
26.0
TOTAL TREAT ACRES
26.0
0.0
FOREST TOTAL 388.0 dcres
aedeuxw 3g
TAELE I
Ccnfarison of Alternatives by Treatment and Cost
Treatment V
Alternative 2 Alternative 3
Biolcgical Cultural
Cantrol 2/ CcPtrol 3/
Alternative
Chemical
Control M/
Alternative 5
Integrated
Pest Mgt.y
Bidogical treatment
1986 Acres
1,230 ac.
0
0
388 ac.
Cost
15,000
0
0
$2,000
5 year total
0
0
Acres*
6,150 ac.
0
0
2,000 ac.
Cost
75,000
0
0
$10,000
Mechanical treatmait
0
1986 Acres
1,230 ac.
0
33 ac.
Cost
$252,400
0
$3,000
5 year total
Acres •
6,150 ac.
0
155 ac
Cost
$1,260,000
0
$15,000
Herbicide treatment
0
1986 Acres
0
1,230 ac.
622 ac.
Herbicide lbs.
0
756 lb.
495 lb.
Cost
0
$108,000
$54,650
5 year total
Acres*
3,650 ac.
1,991 ac.
Herbicide lbs.
2245 lbs.
1,395 lb.
Cost
$320,800
$170,000
Total - 1986 Ac.
1,230 ac.
’1230 ac.
1,230 ac.
1043 ac.
1986 Cost
$15,000
$252,400
$108,000
169,650
5 year total ac.
6,150 ac.
$75,000
6,150 ac.
3,650 ac.
4,146 ac.
5 year total cost
$1,260,000
$320,800
$195,000
• Includlhg re-^treated acres
y Alternative 1 tcuLd have no treatment, (blaLcgical, mechanical, or herbicide) arxl rx) direct
treatment cost, therefore. Alternative 1 is not shown in the table. Hie environnental costs and
benefits of all alternatives are di^jlayed In Table n in D. Eiivirxnnental Ccnsequenoes.
^ Alternative 2 assumes amual monitoring of esdsting populations of bio-agents and new releases
as needed and available.
3/ Alternative 3 assumes hand gmbblng and mowing of all Infested acres annually during the
planning period, vdLth little or no reduction in area Infested by weeds, because of regrowth and
seed germ^tlon.
V Alternative 4 assumes a reduction in weed infested area each jear as treatment effbctively
reduces the populations of weeds, especially spotted knapweed, vMtetop, and thistles. All
infested acres would be treated annually.
Alternative 5 includes leas acres of chemical treatment than Alternative 4 hftr»aiL«<p of
prescribed bidogical treatment, mechanioal treatment, or defbment. On sane large areas the
weed managemoit stategy is oontairment, with bidogical oontrd applied to the major portion of
the area and ohemioal treatment on the periphery. As in Alternative 4 it is assumed that there Is
a gradual reduction in weed infested area from jear to jear.
O !
t .
'X-
iii 'si
ADDENDUM tf4
MANAGEMENT CONSTRAINTS
This section lists the revised constraints that must be applied to approved
projects.
1. All herbicide application workers must be advised explicitly of the
hazards of these chemicals and instructed in the careful herbicide
application techniques, so as to reduce dose levels below worst-case
values assumed in the risk analysis.
2. Sensitization to 2,4-D and picloram mixtures has occurred in humans,
and applicators may develop allergic reactions from repeated
exposure. All supervisory field personnel responsible for herbicide
application (both in service and contract applicators) are required to
inform their workers of the possibility of allergic reactions to some
mixtures of picloram and 2,4-D and to remove from their crews those
workers that exhibit such reactions. Any instances of allergic
reactions to pesticides must be reported to the Forest Supervisor.
3. Appropriate personal protective equipment will be considered in
developing project safety and health analysis (FS 6700-7) for Forest
Service applicators (see Health and Safety Code Chap. 9-10 FSH
6709.11.).
4. Pesticides must be applied under the supervision of a licensed
pesticide applicator under the laws of the State of Montana. To apply
picloram, the applicator must be licensed for restricted use
herbicides. Pesticides must be applied consistent with the
instructions on the label (see Appendix 9).
5. Personnel in charge of controlling noxious weeds must review state and
federal regulations and Forest Service manual instructions (FSM 2157
and FSH 2109.12) concerning proper disposal of pesticides and
pesticide containers. Federal and State regulations regarding the
proper disposal of pesticide wastes must be complied with.
6. No herbicides will be applied within municipal watersheds, wilderness
areas, proposed research natural areas, or areas occupied by rare
plant species. Weed control in these areas will be by cultural
methods only (hand grubbing, etc.). Sufficient buffer zones (at least
100 feet) will be established to prevent herbicide drift or subsurface
movement into these areas.
7. The use of herbicide to control weeds in campgrounds will be
restricted to 2,4-D only. Public notification and signing will
preceed the application of herbicide, and the treated area will be
closed to public use for two weeks following treatment. Areas
adjacent to water wells, and other selected areas within the
campgrounds will be mechanically treated by hand -grubbing.
8. No herbicide will be applied directly to any standing or running water
or where surface water from treated areas can run off into live water
sources.
1
Picloram is a persistent herbicide which will carry over in the soil,
with a half-life of approximately one month under highly favorable
conditions to more than four years in arid regions (USDA Forest
Service. 1984). It is water soluble and can move with water in
streams and irrigation or drainage ditches. Do not use picloram where
a sandy porous surface and substrate overlie ground water 10 feet or
less below the surface. Do not apply directly to steinding or running
water. Do no apply where surface water from treated areas can run off
to adjacent cropland, streams, irrigation ditches, ponds or wells. Do
not apply to the banks or bottom of irrigation ditches or intermittent
streams.
9. The location of the inventoried noxious weed infestations scheduled
for mechanical treatment will be compared with the Forest cultural
resource site atlas in consultation with the Forest Archeologist prior
to treatment. If it is determined that there is a probability of
cultural resource disturbance, then, on-site cultural inventory will
be conducted prior to treatment. If cultural resources are noticed
during mechanical treatment, the work will be stopped until the Forest
Archeologist can conduct a cultural resource evaluation.
2
ADDENDUM #5
CONTENT ANALYSIS
OF COMMENTS TO THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR NOXIOUS WEED CONTROL ON THE LEWIS AND CLARK NATIONAL FOREST
On March 21, 1986 the Draft EIS for the 5-Year Program to control Noxious Weeds
on the Lewis and Clark National Forest was mailed to 85 individuals, agencies,
and organizations for public comment. A notice of the release of the Draft EIS
appeared on the Federal Register on Friday April M, 1986. A news release
appeared in the Great Falls Tribune on February 24 and again on April 6, 1986
explaining the Noxious Weed analysis and comment procedures.
The original comment period was scheduled to end on May 7, 1986. The
Environmental Protection Agency requested that the comment period be extended
until May 19> 1986 to allow interested Individuals a full 45 days to review the
Draft after its appearance on the Federal Register. The request was accepted
and the comment period extended. Anyone who had received a copy of the Draft
EIS received a follow-up letter informing them that the comment period had been
extended to May 19. All comments received through May 29 were analyzed and
considered in developing the final EIS.
The Forest received 19 written comments on the Draft EIS. The comments were
categorized by representing group and location as follows:
9 comments coded - G - Government Agencies (State and Federal)
5 comments coded - I - Individuals (Not representing any
organization)
1 comment coded - T - Blackfeet Tribe
4 comments coded - 0 - Organizations (Stockgrowers, Environmental,
Educational)
M - In Montana
0 - Outside Montana
Comments were sorted into the following categories:
I. NEPA Process
II. Health and Safety (Risk Analysis)
III. Control Priority
IV. Management (Future Developments) - Roads, Timber, Oil and Gas
V. Economics
VI. Integrated Approach
VII. Revegetate/Reseeding
VIII. Education/Training Applicators
IX. Rare Plants
X. Biological Controls
XI . Monitoring/Inventory/Effectiveness
XII. Application Techniques
XIII. Wilderness/Backcountry/Weed Free Hay
1
I. NEPA PROCESS
A. Extend Comment Period
1 . Concern that the comment period should be extended so that comments
v;ould be accepted a full 45 days after the notice of release appeared
on the Federal Register.
RESPONSE: The comment period for reviewing the Draft EIS was extended
from May 7, 1986 to May 19, 1986. In late April a letter was sent to
all recipients of the Draft EIS informing them of the extended comment
period. The notice appeared on the Federal Register on Friday, April
4. The extension to May 19 allowed a full 45 day comment period after
the notice of release appeared. All comments received through May 29
were considered in developing the final EIS.
B. Document Additions/Corrections/Clarifications
1 . Concern that the individual be informed of the final decision.
RESPONSE: Anyone who commented on the Draft EIS will receive
notification of the final decision.
2. Concern that the documents include the worst case analysis by Ed
lionnig .
RESPONSE: Ed Monnigs’ health risk analysis (including the worst case
analysis information) is included in the Draft EIS as Appendix 8B.
3. Concern that the final EIS list policy items of preventive or passive
types of control that can be used under any of the alternatives.
Suggested that the list should be at the beginning of 'B. Alternatives
Considered.'
RESPONSE: We agree that certain preventive control measures would be
used under any of the alternatives. V/e have included a list of these
measures as a part of the selected alternative in Addendum #2 Forest
Objectives for Noxious Weed Management of the final EIS.
4. Suggestions that the noxious weed list should include all weeds listed
by the Montana Department of Agriculture for the state. Also wants
these weeds addressed in the management plan. See attached list.
RESPONSE: The weeds listed in the draft EIS were only the weeds known
to occur on the Lewis and Clark National Forest. We are aware that
there are other noxious weed species in Montana, and adjacent states,
and will remain vigilant for their occurrence on the Forest. The
noxious weed list in the Montana County Noxious Weed Control Act, is
included in the final EIS as Addendum #1 Montana Noxious Weed List.
2
5. Feels that the affected acreages are under estimated.
RESPONSE: The inventory of noxious weeds occurring on the Forest is
dynamic and revised to include populations of weeds as we become aware
of them. We encourage anyone that has knowledge of weeds on the
Forest to contact us so we can include them in our inventory. The
inventory has been revised since the draft EIS was written, and is
included in Addendum #3 Noxious Weed Inventory and Project
Proposal/Report. -
6. Correction - Leafy spurge roots and buds have been found much deeper
than 5 feet, which is the depth that was mentioned in the DEIS.
RESPONSE; True, leafy spurge roots can grow as deep as fifteen feet
with vegetative buds to depths of ten feet, according to The
Distribution, Biology, and Control of Leafy Spurge (Montana State
University, February, 1985). The point of this information, whether
five or fifteen feet, is that leafy spurge roots and vegetative buds
grow too deep for hand grubbing to be effective. Mechanical
treatment, to be effective, requires intensive cultivation repeated
several times during the growing season for several years.
7. Additions - References should be cited to document how noxious weeds
reduce big game forage production and lower wildlife, recreation and
esthetic values.
RESPONSE: Reference to reduction of big game forage and wildlife
habitat and recreation value can be found in the publications by
Montana State University, 1983 "Knapweed..." circular 307, Kelsey,
Richard G. 1984 "Living with Spotted Knapweed...", and Spoon, Charles
W. 1983 "Noxious Weed on the Lolo...." (see Appendix la of draft EIS).
8. Additions - DEIS discussed deer and elk eating young knapweed plants
but did not cite a reference. If wildlife eat the seed heads,
managers should be more concerned about the potential spread of
knapweed than with its forage value or importance as a food source.
RESPONSE: Our information on the use of knapweed seedheads by big
game animals was from personal communication with Don Bedunah,
Assistant Professor of Range Management at the University of Montana,
based on information gathered during an ongoing research project.
Reference to wildlife eating of plants and seed heads can be found in
Spoon, Charles W. 1983 "Noxious Weeds on the Lolo...." The Forest
recognizes that there is very little value in noxious weeds for
wildlife and that preventing the spread of noxious weeds is our goal.
That is why the Forest has entered into a noxious weed control program
and why good range management practices to prevent the spread of
noxious weeds is emphasized.
9. Correction - The DEIS implies that left unchecked, noxious weeds will
continue to spread on the Forest. Statement implies that weeds will
eventually dominate all vegetation in the Forest. Noxious weed
species will only spread unchecked to the extent that natural
conditions and land management practices will allow.
3
RESPONSE: It is true that these noxious weed species are not expected
to invade undisturbed dense coniferous forests, rockland, alpine turf,
etc. However, they are adapted to a wide variety of grassland,
shrubland, and forest habitats, especially under disturbed conditions
resulting from human activity and/or natural factors such as
wildfire.
10. Additions - Cite references for statements that allelopathic toxins
are produced by leafy spurge and spotted knapweed.
RESPONSE: The draft EIS (page 8) cites Kelsey, 1984 (Appendix la of
draft EIS), as the reference for allelopathic toxins in knapweed.
Another good reference for this property of knapweed is Fletcher, R.A.
and A.J. Renney, 1963> A Growth Inhibitor found in Centaurea spp.Can.
J. Plant Sci. 43: 475-481.
Reference to allelopathic properties of leafy spurge is found in
Messersmith, C.G., 1983 (Appendix la of draft EIS).
11. Correction - Chemical control methods that are proposed in the DEIS
have shown 99 to 100 percent suppression of weeds during the first
year, not control as indicated in the DEIS.
RESPONSE: By 'control' we mean the reduction of a pest problem to a
point where it causes no significant economic damage. See definitions
in Appendix Id-Glossary of the draft EIS.
12. Clarification - Rates in Appendix 5b is confusing - the rates shown
may be adequate for spot treatments of scattered, low-density
infestations within the acreage that is listed, but many treatments
would be at less than recommended rates if the entire acreage is
treated. The proposed application rate for each target weed and area
should be listed in the DEIS. Suggest that herbicides not be applied
at less than recommended rates because the treatments may not be
effective and because resistant or tolerant weed populations may
develop.
RESPONSE: Correct. The acres infested with noxious weeds vary in
their weed density by canopy cover class, as is indicated in Appendix
5c of the draft EIS. The amount of chemical proposed to treat each
infested area is based on the weed density and species present on that
site. The application rates are within the recommended rates on the
label and guidelines developed from the latest research. The actual
application rate of pesticide proposed per treated area is shown in
Addendum #3 Noxious Weed Inventory and Project Proposal/Report of the
final EIS.
13« Clarification - On page 'e' (summary) the last sentence. . ."The
possible cumulative..." is unclear and suggestion that it be reworded.
RESPONSE: We do not expect any cumulative or synergistic impacts of
the pesticide application proposed on the Lewis and Clark National
Forest with pesticide application that may occur on adjacent lands.
14. Addition - On page 15, second paragraph, last sentence... "In the long
term..." suggest that a similar statement be included in the
discussion of Alternative 5.
4
RESPONSE: Yes, it was intended that this statement apply to
bioloeical control in Alternative 5 as well. The first paragraph of
the description of the environmental consequences of Alternative 5 on
page 18 explains this.
15. Clarification - In Appendixes 4 and 5i a, b, c is there a method of
tracking specific spray projects between these tables?
RESPONSE: Yes, the projects can be tracked with the "project number"
which appears in the first column of Appendix 4 and 5b, and in column
12 of Appendix 5c. Appendix 5b is a summary of the detailed listing
of individual projects on Appendix 5c. The "project number" in column
12 of Appendix 5c is for the purpose of "lumping" individual projects
in the same general geographic area to allow the summarization in
Appendix 5b. The updated data in Addendum of the final EIS carries
the individual project number from inventory of noxious weeds through
the proposal for treatment by pesticide, mechanical, or biological
methods.
16. Clarification - In Appendixes 5c and 6, what do ’H', 'M*, 'L', and
'S’ mean in the column "Canopy Cover?"
RESPONSE: The canopy cover class of the noxious weed on the infested
area as follows:
S = Scattered (less than 1$)
L = Low (1 to 10?)
M = Moderate (10 to 25?)
H = High (greater than 25?)
This has been included in Addendum #3 Noxious Weed Inventory and
Project Proposal/Report of the final EIS.
17. Analysis of site-specific impacts would have been better accomplished
by discussing the impacts by type of project (open-range,
right-of-way, riparian, potentially occupied site).
RESPONSE: Sites to be treated on the Forest with herbicides are
classified into four environmental site types as discussed below.
Herbicide treatment proposed for each type is displayed in Addendum #1
of the final EIS. The human health risk analysis for proposed
herbicide treatment in each site type is contained in Appendix 8a of
the draft EIS.
1. Rights-of-way - Treatment occurs near a road right-of-way. Often
soils along rights-of-way are recently disturbed. Treatment of weeds
will provide existing grass species the opportunity to spread and
thrive. Herbicide application involves spot applications within 10-30
feet of the road in most cases. About 226 acres, or 35? of the area
to be treated are rights-of-way type.
2. Riparian - This indicates treatment occurs near a stream, lake,
wetland, etc. Mitigation measures in Addendum #4 of the final EIS are
prescribed to prevent herbicide application to any surface water and
to prevent ground water contamination. About 109 acres, or 17? of the
area to be treated with herbicides are in riparian areas.
5
3. Occupancy sites - These sites consist of campgrounds, summer home
areas, and Forest Service administrative sites that are associated
with concentrated human activity. Mitigation measures for herbicide
application in this type are discussed in Addendum #3 of the final
EIS. This is a minor site type. Only about 16 acres, or 3/5 of the
proposed herbicide treatment is proposed in this type.
4 . General Range and Forest Lands - Areas classified in this category
span a wide environmental gradient from grasslands and shrublands to
timber and parklands. There is generally less environmental and human
health hazard from herbicide treatment in this zone than the other
three site types. The majority of the proposed herbicide treatment is
in the general range and forest site type. About 291 acres, or 45$ of
the herbicide treatment proposed is in this type.
II. HEALTH AND SAFETY (RISK ANALYSIS)
A. Concern that the amount of water intake to reach ADI is directly
proportional to the size of the reservoir of water which is contaminated by
X amount of herbicide. The amount of water consumed is of secondary
importance. Question: Wouldn’t it be reasonable to assume that a truck
accident and resulting spill is a "major spill?"
RESPONSE: We agree that a truck accident resulting in the spill of
herbicides into reservoirs would be potentially a major concern. As
discussed in Section 3 of the Human Health Risk Analysis contained in
Appendix 8b of the draft EIS, the extent of damage caused by such a spill
is dependent on site specific variables such as the size of the reservoir,
flushing rate of the reservoir, size of the spill, use of the reservoir,
etc. The Human Health Risk Analysis contained in Appendix 8b and
summarized in Appendix 8a examines in detail the potential effects of large
spills into reservoirs of various sizes.
B. DEIS states that picloram will not be applied within 100 feet of water or
to the inner banks of ditches or water channels. The DEIS should address
whether the same constraints apply to 2,4-D and other herbicides, and the
reasons for this policy. An arbitrary buffer zone of 100 feet may preclude
herbicide use where it may be beneficial. Appropriate buffer zones should
be determined on case-by-case basis considering the geography of the area,
application method, and equipment. The hazard of the herbicides to fish
depends on fish size, the amount of exposure and the toxicity of the
product. Applicators must choose the most appropriate herbicide for each
individual site; follow label directions and precautions. When choosing
herbicides, their persistence and mobility in the environment, and their
toxicity and hazard to fish and wildlife should be considered . If two or
more herbicides are equally effective against weeds, the product with the
least potential for environmental damage should be used. Clarification
that picloram would not be used on riparian areas (within 100 feet of
water) would be useful here. In Appendix 8a, Table 3 - This table
indicates the use of picloram on riparian areas. Clarification on where in
the riparian area it is to be used would be helpful.
6
RESPONSE: We agree that a 100 foot buffer zone for picloram Is arbitrary,
and should instead be determined on a case by case basis, according to site
conditions. We are replacing the 100 foot buffer with the following
requir-ement statement, developed largely from the label, in the revised
Management constraints of Addendum of the final EIS.
"Picloram is a persistent herbicide, it will carry over in the soil,
with a half-life of approximately one month under highly favorable
conditions to mor« than four years in arid regions (USDA Forest
Service. 1984). It is water soluble and can move with water in
streams and irrigation or drainage ditches. Do not use picloram where
a sandy porous surface and substrate overlie ground water 10 feet or
less below the surface. Do not apply directly to standing or running
water. Do no apply where surface water from treated areas can run off
to adjacent cropland, streams, irrigation ditches, ponds or wells. Do
not apply to the banks or bottom of irrigation ditches or intermittent
streams" .
The same precautions do not apply to 2,4-D Amine, because it is not nearly
as persistent in the environment as picloram. Soil microorganisms readily
metabolize 2,4-D, especially under conditions of warmth and moisture that
also promote growth of microorganism populations. In soils , 2,4-D
generally has a short (one month or less) persistence. Plants metabolize
2,4-D readily by a variety of pathways to various degradation products
(USDA Forest Service. August 1984). Although the label allows application
of 2,4-D amine to aquatic weeds in water, the Lewis and Clark National
Forest will restrict its use to land surfaces only. 2,4-D will not be
applied to any water surface, including canals, ditches, streams, lakes,
ponds, seeps or marshes.
C. Concern that if the use of herbicides are restricted to 2,4-D in
campgrounds there will be less effective control of noxious weeds in these
important areas. Where picloram use restricted, the DEIS should clarify
whether picloram is restricted by the product label or by the Forest
Service. It should also describe the types of areas where the use of
picloram is restricted.
RESPONSE: As explained in B above, the revised restrictions were developed
from the label, with additional margins of safety added by the Forest
Service. The use of picloram is restricted from the campgrounds because of
the possibility of ground water and well contamination based on the
specific site conditions in the campgrounds proposed for treatment.
D. Potential problems associated with spills and application of herbicides
near v?ater should be considered before a project begins. Labeling
precautions that prevent contamination of ground water must be observed .
RESPONSE: We agree that potential problems associated with spills and the
application of herbicides near water require serious consideration. In
many cases the Forest Service will go beyond label precautions to minimize
potential for contamination of water. For example, picloram is restricted
from campgrounds for the reasons described in B and C above.
7
G. Campground closures following treatment with either 2,4-D or picloram are
unnecessary. There are no re-entry intervals and people may enter treated
areas without pr-otective clothing or equipment after sprays have dried. It
should be sufficient to post the treated areas and notify the public that
the areas have been sprayed and why they have been sprayed.
RESPONSE: Although the labels and use restrictions for the herbicides
2,4-D and picloram do no require reentry intervals, the Lewis and Clark
National Forest has elected to close the treated areas of campgrounds for
two weeks following treatment to further minimize the possibility of
general public exposure to herbicide residues.
III. CONTROL PRIORITY
A. Concern that Canada thistle on forest lands and roads will be controlled by
nature without the use of man-induced controls. A lot of money would be
wasted spraying Canada thistle on the Forest.
RESPONSE: We agree that Canada thistle is a low priority weed on the
Forest when compared to spotted knapweed and leafy spurge. These latter
two vjeeds are the main target weeds in the Lewis and Clark National Forest
weed control program. Control of Canada thistle is only a secondary
objective for chemical treatment where it is associated with the main
target weeds. As you have stated, Canada thistle populations often decline
as forest trees and associated vegetation advance along roadsides and in
timber harvest areas during the natural process of forest succession.
Also, in controlling Canada thistle care must be taken to distinguish the
noxious weed from the several native thistle sp)ecies which occur in the
ecosystem. For example, Cirsium longistylum is a Montana endemic, which
occurs only in the Little Belt and Big Belt Mountains of Montana.
Where Canada thistle occurs on the Forest adjacent to agricultural
cropland, and is an economic problem, we may consider this weed a higher
priority for control in cooperation with adjacent landowners. We will
continue to monitor Canada thistle populations and rely on biological
control agents, as they are developed and become available, for most Canada
thistle control.
B. Concern that the Forest should direct action to first halt the spread by
eradicating new outbreaks and small infestations, and second, reduce or
contain large existing infestations.
RESPONSE: We agree with these control priorities, and have clarified this
in Addendum #2 Forest Objectives for Weed Prevention and Control of the
final EIS.
8
IV. MANAGEMENT (FUTURE DEVELOPMENTS) - ROADS, TIMBER, OIL AND GAS
A. Management (General)
1. Concern that the Forest should consider the potential for noxious weed
infestation in management decisions. . .land management decisions
conducive to the introduction of weeds should be eliminated.
RESPONSE: The Forest Plan has standards that will be followed in the
decision making process. An important factor in the prevention of
noxious weeds is the reseeding and rapid establishment of vegetation
on disturbed sites, such as road cuts and fills, rock quarries and
gravel pits. If considerations are given to the spread of noxious
weeds in the planning and execution of management activities, the
spread of noxious weeds will be reduced. However, we cannot eliminate
all activities that are conducive to the introduction of weeds.
2. The DEIS suggests the weed problem is mainly along public
thoroughfares. Weed prevention techniques should be used in all areas
of the Forest.
RESPONSE: We agree that weed prevention techniques should be used in
all areas of the Forest. However, for efficiency and cost
effectiveness, control will be applied on a priority basis as outlined
in Addendum #2 Forest Objectives for Noxious Weed Management of the
final EIS.
B. Vehicles and Roads
1. Concern that vehicles from logging equipment, oil and gas operators,
road construction, mining, and hunters have the potential for
spreading noxious weed problem. Recommended washing equipment to
remove weed seeds before entering the National Forest. Concern that
parking lots for Forest Service and industry vehicles be weed free.
Concern that the Forest Service work with counties to identify
weed-infested areas (gravel pits) that are potential sources of
infestation to the National Forest. Concern that any oil and gas
project include a concise and comprehensive reclamation plan regarding
weed control on all roads being built to an exploration site and at
the site itself.
RESPONSE: The Forest has the same concern about the spreading of
noxious weed seed. Currently, there are no contract clauses that
provide for that requirement. Also we have no control over the
recreationist that travel the roads throughout the forest, except for
the use of road closures. Weed free parking lots will be one of the
items in a management section of the EIS. We have cooperated with the
counties in the past in inventory and treatment and will continue to
do so. It has been and will continue to be standard practice to
include reclamation of disturbed sites when dealing with gas and oil
development.
9
2.
Concern that the Forest Service should close newly-constructed roads
and eliminate off- road vehicle travel until permanent vegetative cover
is established. ORV use in weed-infested areas and weed-free areas
should be pr-ohibited.
RESPONSE: The Forest’s goal is to establish vegetation promptly on
roadsides and borr-ow pits following new road construction. The
establishment of a good seed-bed is essential. The Forest will try to
reseed roadsides immediately after construction. Closing the roads
permanently to ORV use in weed-infested or conversely in weed-free
areas, would essentially mean closing the Forest to motorized use.
Motorized vehicle use is a recreational pastime for many Forest
visitors, and we feel that the Forest should continue to provide the
opportunity to ORV users on suitable sites of the Forest.
C . Range Management
1. Suggestion that if proper range management, cattle disbursement
practices and recreation use development are being required and
enforced there should be little opportunity for noxious weeds to
"control out" desirable vegetation.
RESPONSE; Best range management practices and the maintenance of good
range vegetative conditions will help to prevent establishment and may
tend to retard the spread of weeds through natural competition.
However, these introduced noxious weeds have some competitive
advantages over native plants because of the lack of natural parasites
and diseases that effect native plant species. Although noxious weeds
usually establish on bare soil that is often associated with
disturbance by man's activities, weeds also may establish on the bare
soil resulting from gopher activity and other natural processes. The
ability of spotted knapweed to expand into an excellent condition
range area can be seen in the Blackfoot-Clearwater Game Range of
Western Montana (Morris, Melvin S. and Don Bedunah. 1984. Some
Observations on the Abundance of Spotted Knapweed in Western Montana
in Proceedings of the Knapweed Symposium, Montana State University
Bulletin 1315).
2. The DEIS does not mention that riparian areas are also disturbed by
livestock grazing. It should address ways to reduce disturbance of
riparian zones to minimize invasion by noxious weeds. The possibility
of using grazing management to improve range condition and to provide
increased plant competition with noxious weeds on all areas should be
investigated. The improved grazing practices should be specified in
the plan.
RESPONSE: All environmental site types discussed in the draft EIS
(riparian, road rights-of-way, occupancy sites, and general range and
forest) may be disturbed by livestock grazing if they are in
allotments where livestock graze under permit. The opportunity for
improved grazing practices depends on the site specific conditions on each
range allotment. Alternative grazing systems and practices for each allotment
are developed during the range environmental analysis process that results in
an allotment management plan. Weed prevention and control is one objective,
among several, that are used in developing allotment management plans. Grazing
practices, developed to meet the objectives for each allotment, are specified
in the allotment management plans.
10
D. Timbti- Management
1. No'/ioua weed control should be incorporated into all timber- har'vesting
plans .
RESPONSE: Timber- sale area impr-ovement plans are developed during the
planning for each timber sale. This plan displays tr-eatments needed
within the timber sale ai-ea. VJeed control is often scheduled in these
sale area, impr-ovement plans and is I’ecognized as a legitimate
treatment for the collection and expenditure of improvement funds
under the Knutson-Vandenberg Act of 1930.
The Forest often includes the seeding of grasses and legumes ori reads,
skid trails and other- disturbed sites for erosion and weed
prevention. Provision for this seeding is incorpor-ated into plans for-
the timber sales either thr-ough the timber sale contract or the sale
area improvement plan. This direction is provided for- in the Forest
Plan and is also highlighted in Addendum #2 Forest Objectives for-
Noxious VJeed Management of the final EIS.
V. ECONOMICS
A. Concern that the cost of weed control should be included in the cost of
timber sales, oil leases/explor-ation, and mining.
RESPONSE: We agree. The stabilization and revegetation of disturbed areas
with suitable species is a legitimate cost of these activities. This will
be further highlighted in Addendum #2 Forest Objectives for Noxious VJeed
Management of the final EIS.
B. Statement that money spent in weed control now will be only a fraction of
what it would cost later if the vreeds were not controlled now.
RESPONSE: Yes, and cost effectiveness is a major consideration in the
rationale for developing the Forest noxious weed program in this EIS.
C. Concer-n that the industry that brought the problem of noxious weeds to the
Forests is not bearing a substantial portion of the fiscal burden for
treating the problem. Grazing industry specifically mentioned.
RESPONSE: Actually, we have found that noxious weeds on the Forest usually
originate and spread along roadsides from seed transported by vehicle
travel. Public recreation travelers, along with other taxpayers, are
paying for- weed control through appropriations from Congress. The
livestock grazing permittees, through the use of range betterment funds
from grazing fees, have also supported noxious weed contrxjl efforts.
Individua] livestock permittees on allotments with noxious weed problems
have contributed additional funds in weed control by entering into
cooperative projects with the Forest Service.
D. The benefits and costs of weed control to wildlife, recreation and
watershed resources need to be more thor-oughly documented and discussed in
the DEIS, so that reviewers can determine if the program is truly cost
effective .
11
RESPONSE: We have not found cost multipliers for the effects of noxious
weed control on wiidlife, recreation and watershed values. Further-
research is needed in this regarxi . Whether the program is truly cost
effective is i-elated to the assumptions concerning the rate of spread of
noxious weeds if not controlled, and the resource loss or the future cost
of coi'trol as discussed in B above. Some of these assumptions are
discussed in the Environmental Consequences section of the draft EIS. When
additional information on other values becomes available we will utilize
them in further analysis.
E. DEIS suggests that the costs must be applied annually over a very long
period of time. If the proposed weed control measures are this ineffective
in reducing weed occurrence, Forest Service planners should develop a more
effective weed control program.
RESPONSE: The integr-ated pest management approach, selected as the
preferred alternative, provides for flexibility in applying the most
effective control measure available for each noxious weed infestation.
Weed science research in Montana cind adjacent states is active in the
uni vei'fities and the state and federal government. The Forest intends to
respond to advances in technology by applying the most effective practices
availabj.e .
VI. INTEGRATED APPROACH
A. Concern that admitting that Alt. 5 emphasizes chemical control as the
pr-imary method weakens the application of other control methods and does
not allow pr-oper- side boards for ”Go-No Go” conditions for the use of
chemical contr-ol, and emphasis on biological & mechanical control over
chemical . A realistic control program should consist of moi-e than one
approach (ie. biological, cultural, or chemical) and alternatives should
reflect a combination of control techniques at different levels or
intensities .
RESPONSE: After evaluating all of the alternatives, it is our decision to
adopt alternative #5, integrated pest management. The integrated pest
management approach provides for a combination of treatments based on the
most appropriate prescr-iption for the specific conditions at each site.
The mix of treatments in any one year vjill depend on a number of factors.
Including: (a) the success of the previous years treatment, (b) the
discovery of new noxious weed infestations and the r-ate of spread of
existing populations, (c) advances in technology, including the development
and availability of successful biological control agents, (d) funds
available from Congress and other sources, etc. The combination treatments
described for Alternative #5 in the draft EIS are estimated for the
five-year period, but may vary depending on the factors discussed above.
The integrated pest management approach selected provides the flexibility
to adjust to these changes fr-om year to year.
12
VII. REVEGETATE/ RESEED IMG
A. Ccjncetn l.hiat llio Fore^jl .should consider an active piograai to revetetate
exposed sites and use certified weed-free seed.
RESPOMSE: The prompt. reve£ietation of land disturbed by activities, such a.
i-oad construction, is a Forest-wide Management Direction in the For-est Plan
(Soil and VJater F-3 11,12). Forest seeding guidelines siecify certified
seed in the recommended seeding mixtures for revegetation pr-ojects. V'e
consider prompt revegetation of disturbed areas to be a key component of
our integr’ated weed management program.
B. Concern that chemical control that leaves the infected area less than fully
stocked or’ with less than 90^ crov/n closure is of little value because the
site is open to reinvasion. Measures should be taken to ensure site
occupancy of all types of treatment, particularly mechanical and herbicidal
by beneficial vegetation to prevent reinfection. Reseeding should be part
of the program.
RESPONSE: We agree that seeding competing vegetation into the treated area
Laay help control the weeds as well as minimize erosion fr-om the treated
area. Hard fescue, for’ example, where seeded for revegetation and erosion
centr'd , has been observed to form a dense stand that resists spotted
knapweed invasion (Morris, Melvin S. and Donald J. Bedunah. 1984.). We are
including the seeding of treated areas with competing vegetation as a
component of our biological control efforts, where residual vegetation
density following chemical or mechanical treatment is insufficient.
VIII. EDDXATION/TRAINING APPLICATORS
A. Tr-ain Herbicide Applicators
Concern that herbicide applicators should be thoroughly trained for- proper
application techniques and safety precautions. The whole program is no
better- than the person with the sprayer in their hand. Applicators should
be state certified. Herbicide applicators should take a plant
identification course and pass a test which would insure that they can
competently identify not only target weed species, but also rare plant
species.
RESPONSE; Supervision by a licensed pesticide applicator and training of
workers is required in the management constraints section of the dr’aft EIS
(page 22). We will expand the training required to include plant
identification of: (a) target weeds, (b) other weeds on the State wide
noxious weed list, category 1 and 2, (c) rare plants and (d) native plant
”look-a-likes" that may be mistaken for noxious weeds. Training will also
include the label requirements in the use of the herbicides, envir-onmental
corrstraints included in the draft and final EIS, and health and safety
precautions to keep wor’ker dose levels below worst-case values assumed in
the risk analysis.
13
B. Weed Education Pi'ogram
1. Suggestion that the Forest Service establish a str-ong weed
education program for all employees and the public, including
back-country and other users of the Forest. All field personnel
shouid be made aware of the weed problem so they can help with manual
control and inventory. Publications, posters, public ser'vice
announcements, meetings, and other' educational techniques could be
used to help educate the general public.
PESPONSE: We recognize the importance of a weed education pr‘ogr‘am and
the Forest is planning to conduct a training workshop for employees
working in the noxious weed program. We are also developing ways to
inform backcountry users (through the trailhead signing) to assist us
in the identification and location of infestations. An information
and education plan will be developed for the noxious v/eed program.
2. Public notification of herbicide applications in developed
recreation areas should be expanded to emphasize the weed problem.
RESPONSE: Again, we recognize that For-est visitors may be our best
source of information for identifying locations of infestations. The
public notification plans can be expanded to include information on
noxious weed identification and emphasis on the noxious weed problem.
X. RARE PLANTS
A. Concern that rare plant species may possibly be impacted by the actions
proposed. Inventoried rare plant species include known populations near
the pr-oject areas. Additional field surveys may reveal additional
unrecorded special plant sites at risk.
RESPONSE: The Management Constraints section of the draft EIS (page 22)
provides for pr'otecting known rare plant populations ft>om herbicide
application. We are in close contact with the Montana Heritage Program and
the Nature Conservancy in keeping our rare plant inventory current.
VJorker-s applying herbicides for weed control will be trained to identify
rai-e plants that are known to occur- near the project area.
E. Concern that the risk of affecting rare plants is not necessarily lower
using only cultural methods. The weed infestation itself, if allowed to
spr'ead, will also affect or eliminate rare plants from the area of
Infestation.
RESPONSE: We recognized the threat of noxious weeds to rare plants on page
13, pai-agraph 4 of the draft EIS. We feel that hand pulling or grubbing
v/eeds adjacent to rare plants jeopardizes the sur-vival of rare plants less
that applying herbicide. We will be guided by Management Constraint #4, in
Addendum #4 of the final EIS, when treating noxious weeds in areas occupied
by or' adjacent to rare plants.
14
X. BIOLOGICAL CONTROLS
A. Concern that biolot;ical contr’ol, in addition to insects, should also
include;
1. range stocking and grazing manipulation (T-M-1)
2. introduction or encouragement of competing plant species (T-M-1)
3. natural plant compounds that can be used as herbicides (T-M-1)
4. the potential use of plant pathogens, such as Sclerotinia fungus on
spotted knapweed and Canada thistle.
RESPONSE: We agree and intend to use all available biological control
technology, that is proven effective by research, in our integrated pest
management approach to noxious weed control.
XI . MONITORING/INVENTORY/EFFECTIVENESS
A. Concern that a complete on-going inventory and monitoring program of all
known weed infested areas, treated and untreated, be implemented. Suggest
program modifications from evaluation results, as needed.
RESPONSE: We have updated our inventory since the draft EIS and it is
displayed in Addendum #1 of the final EIS. This computer data base
includes the inventory of noxious weeds and the proposals for chemical,
mechanical and biological control. As additional information becomes
available, the data base will be updated. Monitoring of selected project
to evaluate the effectiveness of the control measures applied is a part o
the Forest Objectives in Addendum #2 of the final EIS.
XII. APPLICATION TECHNIQUES
A. Consider additional application techniques
1 . Suggestion that wick applicators and controlled droplet applicators be
considered for herbicide application in sensitive environments, such as
campgrounds and riparian areas.
RESPONSE: All available application techniques will be considered in
applying herbicide in this program, including wick applicators and
controlled droplet applicators. However, the restrictions on picloram in
campgrounds and riparian areas are because of its persistence in the
envir-onment and the possibility of groundwater contamination, rather than
dr-ift of the chemical during application.
15
2. Suiigestion that hand pulling be used to control weeds where there are
just a few plants.
RESPONSE: Hand pulling can be very effective on spotted knapweed, and
other tap-r‘Ooted species, when the soil is wet. These weeds are
fr'equently pulled by our field personnel when isolated individual weeds or
small patches are encountered. Where the draft EIS refers to hand
'’gr'ubbing” for cultural (mechanical control) we also mean hand "pulling”
when soil conditions ai‘e favoi-able.
3. Concern that emphasis be placed on use of nonchemical methods where
app] icable .
RESPONSE: In selecting alternative #5 Integrated Pest Management as the
preferred alternative, we intend that nonchemical methods be applied where
applicable. However, because chemical control provides the most
cost-effective means for controlling our most troublesome noxious weeds,
spotted knapweed and leafy spurge once established, chemical control will
continue to be a major control technique applied within our integrated
approach to weed management.
B. Concern that aerial application of herbicides should be prohibited on
Forest Service lands.
RESPONSE: Aerial application of herbicides was not included in any of the
alternatives considered in developing our noxious weed program, and is not
proposed in the prograiri selected.
C. Concern that the option of mowing weeds be discussed more fully, since
mowing is not generally effective because most target weeds will develop
flowers below the niowing height.
RESPONSE: As was stated, mowing has limited application in controlling
most vjeeds because the technique does not usually stop the production of
seed. Vie do not plan to use mowing in our mechanical control program.
C. Concern that Dow Chemical Company may be planning to withdrav^f their Tordan
2K (solid beads) picloram formiulation from the market this year.
RESPONSE: We are aware of this decision, but have included piclor*am beads
in our program because of supplies that are still available from
distributors, etc. We will substitute liquid picloram when solid beads are
no longer available.
XIII.WILDERNESS/BACKCOUNTRY/WEED FREE HAY
A. Use of herbicides in VJilderness
1 . Concern that herbicides should be used in wilderness only as a last
resort. Suggestion that the use of chemical control in wilderness should
be reconsidered, as it would allow a longer term control, without requiring
repetition of mechanical treatment over an ever increasing area.
16
RESPONSE: We agr’ee that chemical control of noxious weeds in the
Wj]derriess be used only as a last resort. The Draft EIS does not propose
to use chemical controls in the Wilderness because the infestations are
small and can be controlled usinfj mechanical (hand-pulling) techniques.
E. Concern to control noxious weeds along roadsides and trailheads to prevent
weed introduction into wilderness and backcountry.
RESPONSE: The Forest will be treating noxious weeds along the access
routes (r'oadsides and trailheads) to prevent the spread of noxious weeds to
the backcountry and VJilderness. Again, as part of the education program,
Forest visitors will be encouraged to notify us if they encounter
infestations on the Forest.
C. Concern that the Forest Service should require the use of certified
weed-free hay and supplement feed for use in the backcountry and all forest
lands .
RESPONSE: There is no weed-free certification program in the state of
Montana, and therefore no "certified weed-free" hay available. We will
continue to urge commercial outfitters and recreation riders in the
wilderness and backcountry to bring clean supplemental feed that is free of
weed and weed seed. Personal responsibility for the purchase of hay from
weed-free sources and careful inspection is stressed as a part of the
"wilderness ethic" for backcountry wilderness visitors. Vie will include
this information in our trailhead information and education program.
D. Concern that on page 22, paragraph 4, sentence 1..."No herbicides will
be..." the statement ’areas near units of the National Park System' should
be added .
RESPONSE: The only project proposed for herbicide treatment near Glacier
National Park is Highway 2-Pike Creek along the highway over Marias Pass.
We feel that it is important to control spotted knapweed and other noxious
weeds along this source of weed seed to prevent the spread of noxious weeds
into the Park.
17
COMMENTS RECEIVED
ON THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT
UNITED STATES ENVIRONMENTAL PROTECTION AGE
WASHINGTON, D.C. 20460
APR 8 IS86
OFFICE OF
EXTERNAL AFFAIRS
Mr. John Gorman
Forest Supervisor
Lewis and Clark National Forest
P.O. Box 871
Great Falls, Montana 59403
Dear Mr, Gorman:
On March 24, 1986 this office received and officially filed the
draft Environmental Impact Statement (EIS) entitled: Lewis and Clark
National Forest, 1986-1990 Noxious Weed Control Program, Montana.
Your agency requested comments on the EIS be received by
May 7, 1986 (see enclosed). Section 1506.10 of the Council on
Environmental Quality regulations requires that the Environmental
Protection Agency publish a weekly Notice of Availability in
the Federal Register (FR) of the EISs filed during the preceding
week. Due to the F^ publication cycle, NOAs are published on Friday
of each week and notice only those FISs filed Monday through Friday
of the preceding week. The regulations further require that the
minimum review periods be calculated from the NOA £R publication
date.
Therefore, based on the official filing of this EIS, the
following dates apply:
Date NOA published in the F^ April 4, 1986
Due Date/Closure of the minimum May 19, 1986.
45-day review period
I strongly urge you to send a letter to all parties reviewing
the EIS informing them of the correct date. If you have any questions
please contact Jan Lott Shaw of my staff on area code 202 or FTS 382-5074.
Si ncerely
^11 an Hirscn
Di rector
Office of Federal Activities
Enel osure
1
DRAFT ENVIRONMENTAL IMPACT STATEMENT
Lewis and Clark National Forest
Five Year Noxious Weed Contr-o] Frofcram
1986-1990
Cascade, Chouteau, Judith Basin, Meafcher-,
Wheatland, Golden Valley, Fergus, Lewis and Clark,
Pondera, Teton, Glacier Counties, Montana
Type of Action: Administrative
Responsible Federal Agency: USDA - Forest Service - Lewis and Clark
National Forest
Responsible Official: John D. Gorman, Forest Supervisor
Lewis and Clark National Forest
P.O. Box 871
Great Falls, MT. 59403
For Further Information Contact: H. Wayne Phillips, Ecosystem Coordinator
Lewis and Clark National Forest
P.O. Box 871
Great Falls, MT 59403
Telephone: (406) 727-0901
Abstract: This Draft Environmental Impact Statement describes the preferred
alternative and four other alternatives, including a "no action" alternative,
for controlling noxious weeds on the Lewis and Clark National Forest. The land
area involved is 825 affected acres of National Forest land in Central Montana.
The alternatives provide different approaches to weed management resulting in
differ-ent levels of control. The environmental consequences for the preferred
alternative and other alternatives are displayed. An analysis of the impacts of
herbicide use on human health, using worst case assumptions, is included in the
stater/;ent. The preferred alternative provides for treating noxious weeds in an
integrated pest management approach using a combination of chemical, cultural,
and biological methods. Chemical control would be emphasized, using herbicides
applied on the ground to target weeds by handheld nozzle or solid pellets.
1
>0' ^ l~-
F0RE8T SERVICe
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ilMk t CM* NMnul fom
OMIFMM.M0IMM
i APR141986
1 RECEIVED
APR - R lORR
In Reply Refer To:
ER-86/534
Mr. John D. Gorman
Forest Supervisor
Lewis and Clark National Forest
P.O. Box 871
Great Falls, Montana 59403
Dear Mr. Gorman:
This is in regard to your transmittal of March 21, 1986, requesting the Department of the
Interior’s review and comments on the draft environmental statement concerning the
Noxious Weed Control Program in Lewis and Clark National Forest, Montana.
This is to inform you that the Department will have comments but will be unable to reply
within the allotted time as we have just received your transmittal. Please consider this
letter as a request for an extension of time in which to comment on the statement.
Our comments should be available about May 16, 1986.
Sincerely yours.
Environmental Project Review
2
BOARD MEMBERS
Walter H. Savoy, Chairman
Fort Shaw
Jody Cox, Vice Chairman
Milligan Route, Great Falls
Rev. Francis Mclnnis
College ot Great Falls
Dale Johnson
Belt
Eugene Suek
Bootlegger Trail, Great Falls
CASCADE COUNTY
CONSOLIDATED PESTICIDE PROGRAM
521 - l8t Avenue N,W.
Great Falls, Montana 59404
Phone 727-2804
pfOREST SEHV.U.
7 HEQEiy!*''-;, i
Douglai L Johnton
AdmIniBiralor
6- t^-l
Mr. John D. Gorman May 15, 1986
Forest Supervisor
Lewis and Clark National Forest
Box 871
Great Falls, MT 59403
Dear Mr. Gorman;
The Cascade County Weed District wishes to go on record as generally
supporting the concepts and methods of Alternative 5 Integrated Pest Management
(Preferred Alternative) as presented in the Draft Environmental Impact Statement
concerning noxious weed control on the Lewis and Clark National Forest.
I would suggest reconsidering the use of only hand grubbing in the wilderness
areas and including the other possible control methods as well. In areas of
difficult access, chemical control would allow a longer term control without
requiring regular repetition of a mechanical method over an ever increasing area
of infestation, at least for certain weeds such as Leafy Spurge.
I would also suggest that the risk of affecting rare plants is not necessarily
lower using only cultural methods. If the proximity of the rare plants to the
noxious weeds is so close that proper application of herbicides will affect them,
then the noxious weed infestation itself, if allowed to spread, will also affect
if not eliminate them from the area of the infestation. A deep rooted rhizomatous
perennial weed will not be reduced by pulling or shallow surface grubbing and
unless the mechanical treatment is repeated at 2-3 week intervals throughout the
growing season, the infestation will continue to develop and spread.
I would also suggest reducing the 100 foot buffer required between Pickloram
applications and water to a distance that more realistically reflects the actual
hazzard involved.
We appreciate having the opportunity to review and comment on the Lewis
and Clark National Forest E.I.S..
Sincerely,
James S. Freeman
Cascade County Weed Supervisor
Mosquito
Abatement
MOSQUITO ABATEMENT • WEED CONTROL
Weed
Control
MONTANA NATURAL HERITAGE PROGRAM
I »
I
W
rp:D SCHWINUEN, GOVEHNOH
STATE OF MONTANA
ISIS EAS T 6TH AVENUE
2 May 1986
John D. Gorman
Lewis and Clark National Forest
P.O. Box 871
Great Falls, MT 59403
MONTANA STATE I JHHAHY BUILDING
HELENA. MONTANA S><b20
(406) 444 J009
f-OREST
KAy5.J986 j
SgCeiyED I
Dear Mr. Gorman:
This letter, and the enclosed printout from our data base, are
in response to your request for comments on the Draft EIS for
the treatment of noxious weeds on the Lewis Clark National
Forest. The printout lists those species and their locations
which may possibly be impacted by the actions proposed, and
which are current ly contained in the data base. It is always
possible that additional field surveys would reveal previously
unrecorded special plant sites. This is not a list of all the
special plant locations on the Forest; there are many high
elevat ion/alpine species which I have not included, since they
are not likely to be in the areas to be treated. A few specific
comments are as follows:
1. Of particular concern is the Green Timber Basin-Beaver Creek
area, where two orchid species on the Heritage special plant
list are known to occur ( Amerorch is rotund if ol ia (3 populations),
Cypr ipedium passer inum) . This is a fragile and botanically
signigicant area, in which spraying operations could be
potentially harmful.
S. Although I didn’t find any areas listed in Appendix SB (pp.
1-4) which match the legals for Cirsium lonqistylum, it is
important to be aware of locations for it. This is a species
which is endemic to Montana, and it does in some instances occur
near/along roadsides.
3- There are some ambiguities in the location information which
is available for Bo trych ium par adoxum , which has been recorded
near Hwy. S on Marias Pass. I hope to be looking for this site
this summer with Wayne Phillips and others. This area is near
some of those listed in Appendix SB: 11095SA & B, 11S303,
1 12S04.
4. The site for Er iqeron f laqel laris is the only one known in
Montana; a portion is near one weed inventory site: Dearborn R.
Trail (100001; T17N, R07W, Sec. 6).
Hopefully this additional information will be of use to you in
■AN EQUAL OPPORTUNITY EMPLOYER '
drawing up the final EIS. It might be useful for Wayne Ph x ]
to review this information.
Thank you very much for the opportunity to comment on this t
EIS. If there are any questions^ or if you need
information, please do not hesitate to contact me.
Sincerely ,
Steve Shelly
Bo tani st
1 ips
raft
mo I e
5
36
Page 1
SPECIAL PLANT OCCURRENCES - LEWIS AND CLARK NATIONAL FOREST (excluding tliose at
high elevations or in
NAriE; CIRSIUN LCNGISTVLUM GRANK: G2Q SRANK: S30 alpine areas)
C011H0N NAHE: LONG-STTLED THISTLE
COUNTY; HTHEAG QUADNAHE: KINGS HILL
lOWNRANGE: G12Nfi08£ SECTION: 03 TRSCOMN: NEA,2NWA
DIRECTIONS: 0.A HI. S. OF KINGS KILL CAH^GROUND ALONG HHY. 89, LITTLE
BELT NOUNTAIMS.
TIAHE: CIRSIUH LONGISTYLUH GRANK: G2Q SRANK: 520
CONHGN NAflE: LONG-STYLED THISTLE
COUNTV; HTHEAG QUADNAHE: KINGS HILL
TOUNRANGE: 012N003E SECTION: 32 TRSCOHH; NEA
DIRECTIONS: LITTLE BELT ROUNTAINS, 20 HI. S. OP NEIHART, FOREST GREEN
RESORT.
NAHE: CIRSIUH LDNGI3TYLUH GRANK; G2Q SRANK: S2Q
CCHHON NAME: LONG-STYLED THISTLE
COUNTY: HTCASC QUADNAHE: MONARCH
TQWNRANGE: 015N007E SECTION: 03 TRSCOHH: NEANEA
DIRECTIONS: FROM MONARCH ON HWY. 39, GO EAST I MILE ON DRY FORK RD.
-'S120); SITE IS ON N. SIDE OF ROAD.
NAME: CIRSIUH LONGIBTvLUH GRANK: 623 SRANK: S23
COHMCH NAHE: LONG-STYLED THISTLE
COUNTY: HTCASC QUADNAHE: BARKER
TOWNPAIIGE; BiSNDSGE SECTION: 23 TRSCOHH: NEA
DIRECTIONS: ALONG TRAIL iS318 (BENDER CR. TRAIL) NEAR RD. #120 (DRY FORK
BELT CR. RD.)
NAHE: CIRSIUH LONGlSTViUH GRANK: G2B SRANK: S2Q
COMMON NAME: LONG-STYLED THISTLE
COUNTY: MTMEAG QUADNAHE: MOOSE MOUNTAIN
TOWNRANGE: 0i2N@07E SECTION: 36 TRSCOHH: NEA
DIRECTIONS: TUMPING CREEK CAMPGROUND (U.S. HWY 89, CA. 17.5 MI. S. OF
NEIHART).
NAME; CIRSIUH LONBISTYLUH GRANK: G2Q SRANK: S2Q
COMMON NAME: LONG-STYLED THISTLE
COUNTY: HTCASC QUADNAHE: BELT PARK BUTTE
T" 'NGE: 01AN00'E SECTION: 25 TRSCOHH: S2
ONS: NEIHART (LEGAL DESCRIPTION PLACES LOCATION IN GRAVEYARD
— GULCH DRAINAGE, NEAR CONFLUENCE WITH HARLEY CREEK, CA, 2 AIR
HI. WWW. OF NEIHART).
e
15/01 ''86
Page 2
SPECIAL PLANT OCCURRENCES - LEWIS AND CLARl, NATIONAL FOREST
lAHE: CIRSIUN LONGIST/LUM GRANK: GEO SPANK: SEC
:0HHDN NAME: LONG-STYLED THISTLE
;OUNTY: I1TJIJDI OUADNAHE: YOGO PEAK, NEIHART
OWNRANGE: 014N009L SECTION: 19 TRSCOMN:
IIRECTIONS: "LONG BALDY, LITTLE BELT MOUNTAINS" (SEE EODATA),
lAME: ERIGERQN FLAGELlARIS GRANK: GA SRANK: SI
IQMMON NAME: RUNNING FLEABANE
:OUNTV: MTLENI QUADNAME: BEAN LAKE, BLOWOUT MOUNTAIN
'OWNRANGE: 017N007W SECTION: 03 TRSCOMM: 10;T18NR7W:3A
IIRECTIONS: ALONG FALLS CREEK, FROM CA. 0.A-2.E MILES SOUTH OF ITS
CONFLUENCE WITH THE DEARBORN RIVER, S. OF THE DIAMOND BAR )(
ranch; ALONG EAST 5 WEST SIDES OF THE CREEK.
!AHE: PHLOX MISSOULENSiS • GRANK: GEQ SRANK: SEQ
:OMMON NAME: MISSOULA PHLOX
:0UNTY: MTMEAG QUADNAME: KINGS HILL
'OWNRANGE: 01EN008E SECTION: 0E TRSCOMM: NWA
IIRECTIONS: SWITCHBACK, KINGS HILL (U.S. HWY. 89, CA. 0.5 MI. S. OF
KINGS HILL PASS).
JAME: AMERORCHIS ROTUNDIFOLIA GRANK: GA SRANK: SI
lOMMON NAME: ROUND-LEAVED ORCHIS
lOUNTY: MTLEWI QUADNAME: PATRICKS BASIN
rOWNRANGE: 0E1N009W SECTION: 16 TRSCOMM: NEA, 9SEA, 15WE
3IRECTIONS: GREEN TIMBER BASIN, HEAD OF DRAINAGE OF TRIBUTARY OF BEAVER
CREEK, CA. 1.7 AIR MI. S. OF GIBSON DAM.
YAME: AMERORCHIS ROTUNDIFOLIA GRANK: GA SRANK: SI
:OMMON NAME: ROUND-LEAVED ORCHIS
lOUNTY: MTLEWI QUADNAME: SAWTOOTH RIDGE
rOWNRANGE: 021N009W SECTION: 15 TRSCOMM; NWA
IIRECTIONS: EAST SIDE OF BEAVER CREEK, CA. 1.6 AIR MI. SSE. OF GIBSON
DAM. E.0 AIR MI. S. OF NORTH FORK SUN RIVER.
lAME: AMERORCHIS ROTUNDIFOLIA
GRANK; GA
lOMMON NAME: ROUND-LEAVED ORCHIS
IQUNTY: MTLEWI QUADNAME: SAWTOOTH RIDGE, PATRICKS BASIN
1" 'NGE: 0E1N009W SECTION: EE TRSCOMM: SWA
ONS: MAINLY ALONG W. SIDE OF BEAVER CREEK, ADJACENT TO SAWMILL
^ FLAT; FRONT RANGE, ROCKY MOUNTAINS.
SRANK: SI
7
SS/'M/So
Page
3
SPECIAL PLANT OCCURRENCES - LEWIS AND CLARK NATIONAL FOREST
NANE: CiPRIPEDIUH PASSER I NUN GRANK: GA SRANK: SI
CGHNON NAHE: SPARROW ^S-EGG LADY’S-SLIPPER
COUNTY: NTLEWI OUADNAME: PATRICKS BASIN
TOWNRANGE: 021N009W SECTION: 16 TRSCOMM: NEA
DIRECTIONS: GREEN TIHBER BASIN, £ HI. S. OF GIBSON DAH.
NAHE: BOTRVCHIUH PARADu?;UH GRANK; G1 SRANK: SI
CGHHON NAHE: PECULIAR HQONWORT
COUNT-: HTFLAT ■YTGLAC OUADNAHE: SUHHIT
TOWNRANGE: DSeNDi^W SECTION: 36 TRSCOHH: NEAR BORDER 36 I E5
DIRECTIONS: CA. 1 HI. W. OF ilARIAS PASS, PONDERA AND FLATHEAD COUNTY
LINE (MOTE: CO, LINE WEST OF MARIAS PASS IS FLATHEAD-GLACIER
CO. LINE; IT IS WNW. OF THE PASS.).
8
United States
Department of
Agriculture
Soil
Conservation
Service
Federal Building, Room 4A3
10 East Babcock Street
Bozeman, MT 59715
John D. Gorman
Forest Supervisor ■ ' ^
Lewis & Clark National Forest
P.O. Box 871
Great Falls, MT 59403
Dear Mr. Gorman;
Appropriate SCS staff have reviewed the draft environmental impact statement
for "Noxious Weed Control". No technical comments were made as a result of the
review. In our opinion, the EIS represents a thorough discussion of the
program .
Thank you for the opportunity to review and comment on this draft EIS.
Sincerely
Glen H. Loomis
State Conservationist
cc :
James B. Newman, Director, Ecological Sciences Div. , SCS, Washington DC
Robert G. Lohmiller, State Resource Conservationist, SCS, Bozeman, MT
9
o V
GEORGE TURMAN
LIEUTENANT GOVERNOR
^tatc of Montana
C0ffice of ^ieuteoant (^oUernor
^elena 59620
(406)444-3111
FOREST SERVICE
Lew^s K Clark Natlurial Forest
Great Falls Montana
MAR 2 6 1986
RECEIVED
MaAc.fl 25, 1986
Ma. John GoAman, foAut SapCA.vAi>oA
LmLs and CloAk National foAn^t
P.O. Box 871
GAcat Valt^, MT 59403
RE: VAa{)t EnvlAonm<intit Impact Statement - Lewti and Cloak National
EoAeit NoxaolU) Weed ContAol PAogAam
Montana State IGR CleoAlnghome SAI No. MT860325-494-X
VeoA Ma. GoAman:
The above- captioned document hoe, been Aecetved. In oAdcA to pAovtde
notL{)tcatlon to paAtiei, that may be IntcACited In Aevim and! oA comment
on the pAopoAol, It toill be lifted In the next IntcAgoveAnmental Revleco
Bulletin Issued j^Aom tht6 o{^{^tce.
Any InquiAtci) oA commenti AegoAdlng the pAopoi>al Mill be doiected to
youA o{){)tce. Please pAovtde copta, o{j the enclosed Suggested Aevteiv {^oAm |
to potential AevtewcA.6 - thoie you ieel should be Invited to comment, a6 ;ii
tveil 06 to any evho may Aeque6t the oppoAtunity to do 60 . We have osked |
that comment6 be AetuAned by May 7, 1986 at Aequetted, and that copte6 |
be 6ent to the CleoAinghoute {^OA ouA {^ilet. |
The CleoA-lnghoute tntendU to take no ^uAtheA action on tlvU pAopo6al. \
Stneeaely,
C-cul' Alidth
SUE HEATH
CleoAinghouie ManageA
Enclo6uAe
10
MONTANA INTERGOVERNMENTAL REVIEW CLEARINGHOUSE
REVIEW AND COMMENT FORM
U.S. Department of Agriculture, Forest Service
Lewis and Clark National Forest
Appl leant:
P.O. Box 871, Great Falls, MT 59403
Address :
Draft Environmental Impact Statement - Lewis and Clark National Forest
Subject: Noxious Weed Control Program
Clearinghouse SAI No. MT360325-494-X
YOUR COOPERATION IS REQUESTED IN COMPLETING YOUR REVIEW AND RETURNING
THIS FORM WITH YOUR COMMENTS TO THE ABOVE ADDRESS, WITH A COPY TO THE
CLEARINGHOUSE, NO LATER THAN Mav 7. 1986
(406) 727-0901
Phone:
1 YES
NO
COMMENTS
Is this proposal consistent with the plans,
goals and objectives of your agency?
1
!
1
1
1
Does the proposed action conflict with
any applicable statute, order, regulation
or rule with which you are familiar?
Does this proposal overlap, conflict or
duplicate other existing programs or agencies?
!
Describe any suggestions or means of improving or strengthening the proposed plan.
Please convey your general conclusion by checking the appropriate response(s).
Proposal is supported.
Support only with conditions described below.
Non-supportive for the reasons described below.
Additional information is desired as described below.
No comment on this proposal.
REMARKS:
Revi ewer: _
Address :
Si gnature:
Title:
Phone:
Date:
Return to Applicant listed above, with a copy to:
Montana IGR Clearinghouse
Lt. Governor's Office, Attn: Room 210
State Capitol
Helena, MT 59620
United States
Environmental Protection
Agency
Region 8, Montana Office
Federal Building
301 S Park, Prawor 10096
Helena, Montana 59626-0096
7
REF: 8M0
John D. Gorman
Lewis & Clark National Forest
Box 871
Great Falls, Montana 59403
EFy\
Re: Draft EIS -- Lewis & Clark
National Forest Noxious Weed
Control Plan
Dear Mr. Gorman:
In accordance with our responsibilities under the National Environmental
Policy Act and Section 309 of the Clean Air Act, the Environmental Protection
Agency (EPA) Region VIII Montana Office has reviewed the referenced document.
1. The document has been discussed with personnel in the Montana
Department of Agriculture Environmental Management Division. EPA
feels that their technical comments adequately reflect our general
position on the proposed noxious weed treatment program.
2. All pesticide applications must be made by State-certified
applicators or operators. This will help to ensure that the
applications will be made safely and properly.
3. EPA supports the decision to use an integrated pest management
alternative rather than selecting a strict chemical approach.
EPA rates this DEIS - EC-1 (Environmental concerns - statement adequate).
Thank you for providing this opportunity for our review and comment. If
you have any questions regarding the above comments, please call me at
449-5432 or Richard Montgomery of my staff at 449-5486.
Sincerely
John F. Warden, Director
Montana Office
cc: Dale Vodehnal, 8PM-EA
12
Ml- 0
SIAH: OF MOM ANA
DFPAR I MFN r OF A(;klClji;i LRF
ENVIRONMENTAL MANAGEMENT DIVISION
AGRICULTURE/LIVESTOCK BLDG.
KEITH KELLY
O'HEcroB
I40«l 444 1144
TED SCHWINDEN
CAPITOL STATION
GARY GINGERY
GOVFJ1NOR
ADWiNISTBATOR
(40^1 444 2944
nil I.W, MOM ASA
May 20, 1986
Nr. John D. Gorman
Forest Supervisor
Lewis &< Clark National Forest |
P. □. Box 871 i
Great Falls, NT 59*403 '
Dear Mr. Gorman:
The Montana’s Interagency Planning Task Force has reviewed and
made the enclosed comments on the Draft Environmental Impact
Statement (DEIS) for the Lewis &c Clark National Forest Noxious
Weed Control Program. We support the use of all feasible
methods, described in the preferred alternative, to control
noxious weeds on the Lewis &< Clark National Forest.
We look forward to your consideration of our comments and your
response to them in the final EIS. We appreciate your agency’s
attempts to deal with the noxious weed problem on the Lewis &<
Clark National Forest.
Kei th Kel ly
Director
JEL/f rmde i s . ws
Enc 1 osure
An Affirmative Action/Equal Employment Opportunity Employer
Thiaiik you for the opportunity to review and comment on the Lewis
and Clark National Forest Noxious Weed Treatment Program DEIS.
The DEIS provided an objective discussion of environmental and
economic impacts that may result from each of the alternatives.
However, a realistic control program should consist of more than
one approach (ie. biological, cultural or chemical), and
alternatives should reflect a combination of control techniques
at different levels or intensities.
We agree that the preferred alternative (Alternative 5), which
emphasizes Integrated Pest Management (IPM) of noxious weeds,
best meets the control needs of the Lewis and Clark National
Forest. The IPM strategy should adequately contain noxious weed
infestations while minimizing adverse environmental impacts.
Early detection and treatment of invading weed species is
essential for successful weed management on forests and
rangeland. Judicious use of herbicides will be required pending
the development of more sophisticated biological and cultural
control methods. Existing biological, mechanical and cultural
control methods should be used where appropriate. The control of
small infestations and containment of larger infestations are
appropriate goals.
1 iO-Q 9.Z The best method of weed
management is to prevent the initial establishment of weeds. The
Lewis and Clark National Forest is fortunate in having only 876
14
total forest area, and suggests that the problem weeds occur
mainly along public thoroughfares. Nevertheless, weed prevention
techniques should be used in all areas of the forest.
Forest planners and managers should incorporate noxious weed
control into all timber harvesting plans and grazing management
systems to reduce instances of noxious weed establishment and
expansion. All heavy logging, road construction or oil
exploration equipment (ie. skidders, yarders, tractors, drilling
rigs, etc.) that operates on Forest Service land should be washed
to remove weed seeds before entering the Lewis and Clark National
Forest. Activities that disturb the soil should be minimized to
reduce the spread of weeds, and all disturbed sites should be
revegetated. Newly constructed roads should be closed to public
use until permanent vegetative cover is established along
roadsides. Dff-road vehicle use should not be allowed on weed-
free areas.
Immediate action should be taken to prevent noxious weeds from
invading back country and wilderness areas. This includes
controlling weeds along roadsides and trailheads, educating users
about noxious weeds, and allowing only certified weed-free feed
for stock animals to be taken onto Forest Service land.
2. Pyb_lj.c j.on and educatj.on^ The Forest Service should
establish a strong, long-term weed education program and address
this educational effort in the DEIS. Programs on weed
15
identification and control for all field personnel and a weed
education and awareness program targeted at the general public
are needed. Most outdoor recreationists do not distinguish
between native and introduced species and therefore have little
concern about noxious weeds. Some
may enjoy the
\
color provided by flowers of forbs» noxious or otherwise.
Public information and education activities might include weed
identification publications, posters, meetings, public service
announcements and other educational efforts to increase public
awareness of the weed problem. Informed citizens could also
provide information about weed infestations on Forest Service
1 and .
3- Environment a 1_ concerns^ We generally approve of constraints
against herbicide applications where runoff is likely to enter
state waters. The DEIS states that "picloram will not be applied
within 100 feet of water or to the inner banks of ditches or
water channels". The DEIS should, however, address whether or
not the same constraints apply to 2,4-D and other herbicides, and
the reasons for this policy. An arbitrary buffer zone of 100
feet may preclude herbicide use where it may be beneficial.
Appropriate buffer zones should be determined on a case-by-case
basis. Determination of any buffer zones should consider the
geography of the area, the application method and the eguipment.
16
The hazard of the herbicides to fish depends on fish size, the
amount of exposure and the toxicity of the product. Forest
Service applicators must choose the most appropriate herbicide
for each individual site. All labeling directions and
precautions must be carefully followed. When choosing among
different herbicides, their persistence and mobility i ri the
environment, and their toxicity and hazard to fish and wildlife
should be considered. If two or more herbicides are equally
effective against target weeds, the product with the least
potential for environmental damage should be used.
The DEIS states that "2, <4-0 will be used in areas where picloram
use is restricted". The DEIS should clarify whether picloram use
in these areas is restricted by the product label or by Lewis
and Clark National Forest policy. It should also describe the
types of areas where the use of picloram is restricted. The use
of other herbicides should also be considered.
Potential problems associated with spills and application of
herbicides near water should be considered before a project
begins. Labeling precautions that prevent contamination of
ground water must also be observed. Low levels of E,4-D,
picloram, and other herbicides have been detected in the ground
water in Teton County and elsewhere in the state.
Personnel charged with control of noxious weeds should review
state and federal regulations concerning proper disposal of
pesticides and pesticide containers. Any waste products should
17
be disposed of in accordance with applicable state regulations.
Legal definitions of noxious weeds or weeds do not necessarily
reflect their impact on components of natural communities.
References should be cited to document how noxious weeds reduce
big game forage production and lower wildlife, recreation and
esthetic values.
<4. Human healthy The analysis of the effects of S,4-D and
picloram on human health was very thorough. The DEIS concludes
that possible cummulative and synergistic effects of Forest
Service spraying are not reasonably expected and cites a study
that shows no sensitization to either or picloram.
However, sensitization to 2,4--D and picloram mixtures has
occurred in humans, and the DEIS should recognize that
applicators may develop allergic reactions from repeated
exposure .
5. Q^(IlfiQLoy.Qd sprailing^ The rationale for using E,4-D rather
than picloram or other herbicides in campground areas should be
explained. Picloram is less toxic to mammals than 2,'4-D,
although its metabolism is only partially understood. Picloram
is very persistent in the soil and is more effective on certain
weeds than 2,4-D. It may be more desirable to apply picloram on
spotted knapweed once every three years rather than treating it
every year with 2,4-D. High rates of picloram can cause injury
to grasses, but these rates are not proposed for use.
Herbicide application techniques are extremely important in
18
minimizing the i mpac t of any herbicide in a sens i t i ve
environment, Wick applicators, controlled droplet applicators,
and other hand-held equipment will minimize damage to non-target
vegetat ion.
Campground closures following treatment with either 2,4-D or
picloram are unnecessary. Since there are no re-entry intervals
specified on the labels, people may enter treated areas without
protective clothing or equipment anytime after the sprays have
dried. It should be sufficient to simply post the treated areas
and notify the public that the areas have been sprayed and why
they have been sprayed. Public notification of herbicide
applications in developed recreation areas should be expanded to
emphasize the weed problem. If campgrounds are closed due to
herbicide applications, the public should be made aware that the
problem is associated with the weeds that require control rather
than the control measure itself.
• Grazi^ng Q}§,Q#Qement ^ Although the preferred alternative
proposes the use of improved grazing practices as range allotment
management plans are implemented, more emphasis should be placed
on range management as a weed control strategy. The DEIS does
not mention that riparian areas are also disturbed by livestock
grazing. It should address ways to reduce disturbance of
riparian zones to minimize invasion by noxious weeds. The
possibility of using grazing management to improve range
condition and to provide increased plant competition with noxious
weeds on all areas should be investigated. The improved grazing
19
practices should be specified in the plan.
We recognize that noxious weeds may not necessarily be
detrimental to wildlife habitat, and some weeds may have
nutrients that are beneficial to certain wildlife species. The
DEIS discussed deer and elk eating young knapweed plants but did
not cite a reference. However, if wildlife eat the seed heads,
managers should be more concerned about the potential spread of
knapweed than with its forage value or importance as a food
source .
7, Ef f ec t i^yeness of control mettLodSi^ In the discussion
pertaining to biocontrol, plant pathogens are not mentioned. The
potential use of Sclerot^inia fungus on both spotted knapweed and
Canada thistle should be considered if the host range can be
narrowed to target weeds.
Although biocontrol of St. Johnswort by beetles has been
successful in California, it has been less dramatic in Montana.
St. Johnswort remains a problem in Montana despite successful
establishment of the beetle. Similarly, the hawk moth has been
successfully established on leafy spurge in Montana; but since it
is a foliage feeder, it does not do much damage to the plant.
Leafy spurge is particularly difficult to control due to its
extensive root system. Leafy spurge roots and buds have been
found much deeper than 5 feet, which is the depth that was
mentioned in the DEIS.
The cultural control section of the DEIS covers hand pulling but
20
needs more discussion of mowing. Mechanical treatments need to
be repeated more than once a year to reduce seed production
effectively. Mowing is not generally effective because most
target weeds will develop flowers on short plants that are below
the cutting height.
Chemical control methods that are proposed in the DEIS have shown
99 to 100 percent suggressign of weeds during the first year, not
controj. as indicated in the DEIS. However, chemical treatments
aid in preventing seed set. We recommend that Forest Service
personnel evaluate the effectiveness of individual treatments on
the various species. Evaluations should help determine if or
when program modifications are needed and identify which methods
are most effective over the long term.
The DEIS states that, left unchecked, noxious weeds will continue
to spread on the Lewis and Clark National Forest. Without
clarification, this statement implies that noxious weeds will
eventually dominate all vegetation in the forest. Noxious weed
species will only spread unchecked to the extent that natural
conditions and land management practices will allow. The DEIS
should also cite references for statements that allelopathic
toxins are produced by leafy spurge and spotted knapweed.
8. Aggl.lcatj.gn rates^ The DEIS indicates that Lewis and Clark
National Forest officials have a good grasp of the weed problem
since they list the target weeds and location of each proposed
project. However, the herbicide amount that is listed in
21
Appendix 5b is somewhat confusing. The rates shown may be
adequate for spot treatments of scattered, low-density
infestations within the acreage that is listed, but many
treatments would be at less than recommended rates if the entire
acreage is treated.
The proposed application rate for each target weed and area
should be listed in the DEIS. We suggest that herbicides not be
applied at less than recommended rates because the treatments may
not be effective and because resistant or tolerant weed
populations may develop. Recommended rates for spotted knapweed
are 2 pounds active ingredient (a.i.) of E,4-D per acre and .25
to .375 pounds a.i. of picloram per acre. Recommended rates for
leafy spurge control are 1 pound a.i. of 2, -4-0 plus .25 to .5
pounds a.i. of picloram per acre or .5 to 2 pounds a.i. of
picloram per acre, with yearly retreatments based on this rate.
EOQ5.L9.Ii. The noxious weed list should be
expanded to include those weeds listed by the Montana Department
of Agriculture in ARM 4.5.202-203. Although all weeds on the
list need not be considered high priority or targeted plants,
criteria for detection and management of all these species should
be addressed. This will help coordinate the Lewis and Clark
National Forest noxious weed treatment program with county
noxious weed management plans.
Leafy spurge and spotted knapweed are of primary concern to
landowners. Since 81 percent of the affected acres on the Lewis
22
and Clark National Forest involve these species, a cooperative
control program emphasizing these weeds should be implemented.
Coordinated weed control projects involving all adjoining
landowners are essential. Ue appreciate the emphasis on
coordinated weed control efforts involving adjacent landowners
and local weed boards.
10. E 9.0.00.0 Estimated costs of the noxious weed control
program range from $58.26 to $6^.63 per acre under the preferred
alternative, but the only benefits mentioned are an additional 70
AUMs of livestock forage. The benefits and costs of weed control
to wildlife, recreation and watershed resources need to be more
thoroughly documented and discussed in the DEIS, so that
reviewers can determine if the program is truely cost effective.
The DEIS suggests that the costs must be applied annually over a
very long time period. If the proposed weed control measures are
this ineffective in reducing weed occurrence. Forest Service
planners and managers should develop a more effective weed
control program.
23
IN Ki n •i
Kl I 1 H I '
ER 86/534
O' O
( W-;,,
Unued States Department oi the Interior
()[-l ICI- OF 'Fill SFCRETARY
01 [ ICi; OF FNVIRONMFNTAL PROJECT RFVll VV
Denver Federal Center, Building 67, Room 488
P.O.Box 25007
Denver, Colorado 80225-0007
i' 3 PC.,
John D. Gorman
Forest Supervisor
Lewis and Clark National Forest
P.O. Box 871
Great Falls, Montana 59403
Dear Mr. Gorman:
We have reviewed the Draft Environmental Impact Statement (DEIS) concerning
the Noxious Weed Control Program in the Lewis and Clark National Forest,
Montana, and offer the following comments.
We concur with the endangered and threatened species aspects of the document
and concur with the "no effect" determination.
Page "e" - Summary - last sentence ("The possible cumulative...")
This sentence is unclear and we suggest it be reworded.
Page 15 - Second full paragraph - last sentence ("In the long term...")
We suggest that a similar statement be included in the discussion
of Alternative 5.
Page 17 - Dow Chemical Company may be planning to withdraw their picloram
formulations from the market this year.
Page 22 - Paragraph 4 - Sentence 1 - ("No herbicides will be ....")
We would like to see added to this list "areas near units of the
National Park System."
Page 22 - Item No. 6 - The Tordan label requirements include a prohibition
against using the chemical where the water table on sandy soils is
within 10 feet of the surface.
Appendixes 4 and 5, a, b, c - Is there a method of tracking specific spray
projects between these tables?
Appendixes 5 a, b, c - Clarification that picloram would not be used on
riparian areas (within 100 feet of water) would be useful here.
Appendixes 5c and 6 - What do "H", "M", "L", and "S" mean in the column
"Canopy Cover"?
Appendix 8a, Table 3 - This table indicates the use of picloram on riparian
areas. Clarification on where in the riparian area it is to be used would be
hel pful .
We appreciate the opportunity to comment on this DEIS.
Sincerely
Robert F. Stewart
Regional Environmental Officer
25
Uniled States
Department of
Agriculture
Forest
Service
R-1
i/zc - M/-]
REPLY TO: 2250
Date: MAY 2 0 1986' 7-;'/ . r: : :
1_ *
SUBJECT: Draft EIS on your Noxious Weed Program
TO: Forest Supervisor, Lewis & Clark NF
;jAi' A 9 1038
■
S- ’0
' V : '
• , ‘ V f •
Enclosed are comments on your draft EIS. One thing that would be of value
is to document the location of the sites that will be treated with methods
other than herbicides. This looks like a good site specific document to
us .
Enc losures
26
Pft.fionn.oA/7.A9^
LEWIS & CLARK NOXIOUS WEED DEIS
PP&B
Chapter I, page ^ lists several issues. All of these need to be addressed in
one form or another in the EIS. Most appear to be addressed, but item h, soil
erosion associated with cultural treatment resulting from cultivating or
grubbing for weed control. A look at Chapter IV, page 16, only says "soil
disturbance and erosion would increase more under mechanical weed control than
other alternatives." More is needed to describe based on the sites treated
whether the eroded soil sediment will reach streams, have an effect on fish,
water quality, etc. If it won't happen, say so.
Chapter IV, page 17, paragraph 6 (fish). The term "LCj-q needs to be
referenced to the glossary to help reader find what it^lreans.
Chapter IV. I agree with OGC's comments. I suggest the L&C use the Deerlodge
EIS for some ideas on additional impacts. Obvious oversights are discussion of
the impacts of herbicides on permitted livestock grazing in the Forest.
Impacts of herbicide use on actual campground, recreation sites, heavy use
areas, page 22, provides mitigation in recreation sites, but gives no
indication of the impact to people that requires this mitigation.
27
United States
Department of
Agriculture
OGC
R-1
REPLY TO; * Date: April 17,1986
SUBJECT: Lewis and Clark Draft EIS Noxious Weed Control
TO: Bill Hardman, R&W
Our office has reviewed the Lewis and Clark Draft EIS - Noxious Weed
Control and we have the following brief canments.
Alternatives Considered - In our opinion this section could be iirproved in
providing a better comparison of alternatives as required by NEPA. Often,
a table similar to Table II, on page 23, is used to provide a clear and
concise comparison of the impacts of the alternatives. The discussion and
the table should attempt to meaningfully explain the different irrpacts
between the alternatives.
Environmental Consequences of Alternatives - In our opinion this section
provides a very minimal discussion of the impacts to the alternatives.
This section, in compliance with NEPA, is to thoroughly discuss the
environmental impacts of the alternatives and to form the scientific and
analytic basis for the previous comparisons of alternatives. Impacts for
all evaluation factors should be discussed in detail with appropriate
reference to any appendices where additional information is provided. In
our opinion, analysis of site-specific impacts would have been better
accomplished by discussing the impacts on each resource by type of project
(open-range, right-of-way, riparian, potentially occupied site) in addition
to type of treatment method. (Such discussions of project type would also
appear in the alternatives considered and affected environments sections as
well . )
Our office would be pleased to discuss these comments with you at your
convenience.
Christine T. Reck
28
ir
I'O : Lev;is and Clark National F-’orest ,/oed Control T
FROM: Montana wilderness Association
Id;: Noxious Weeds on public lands
■'larch 26, 19 8 6
liear hewis and Clark National Forest Weed Coritrol T ■
Thank you for the opportunity to comment on you
Forest Noxious V.’eed Control Treatment Program mci Dr
Flnvi ron, mental Impact Statement. I make these common’:
of toe Montana W ilderness Association as v;ell as my..
The Montana Wilderness Association's main conce
noxious weeds out of wilderness and other backcountr
can only be done by getting the weed aroblem alone r
a^ijacent areas under control. I'Je therefore sup;>ort .■
v;eed control program, which uses cheimical, manual, u
biolo’jical, and other effective metho Is to control ..
ITapIiusis shouK.l be placed on use of nonchemical mefi
app' 1 i ca bl a .
One important addition we would lil;e to see out
is a listing of items v;hi ch v;ill be a part of your
[)ro()rain. Rach of tnese policy items are preventive
ty[''es of control and can be used under any of the al
hy li.;tin'] these items, your control progra;-.i will bl-
under ;tood by noth the oulilic and the Forest Servic"^
r ” a t i o n a 1
, ft
s on behalf
‘If .
r n i .s kee ) i •
' areas, rh . .
..ivds and
n Integra te
■c'na :i i ca 1 ,
, ^ .1 5 .
.'.is vniere
into the F,
. ed contr )1
. passive
t amative
..luch bette
. . i t h t h . s
straii.nt 1 orward emphasis and discussion in th ' finr>i d.ocu.aent,
29
t:h'^ t rea t nf-'i t: 'Tco'jram will have a muclT greater chance of success.
List ■? ^
!)elov' are those items which should bo includop in
/our Moxiou
; V.eed Treatment Program. A good place to list fien
would probe’
■ly bo the start -\niw\m P
1. The Fo'i.'est h'^rvice should direct action to first halt the
spread by eradicating new outbreaks and small infestations, and
aecond , reduce large existing infestations.
. The o I
rest Service should emphasize eradication of weed
i n r c s t a i o n s
at trailheads since these are the major source of
spread of n
'xious weedis into the backcountry.
The f^orest dcrvice should consi.der the potential for noxious
■/e 'd introduction and infestations in management decisions. r,and
ise activities 'which are conducive to the introduction and s'^read
^f noxious ;oeds should be eliminated.
The I’orest Service should establish a strong weed ecHication
irogram, bo'
da internal and external. In particular, all field
'Cl sonnel s:
'ould be made a. -are of the weed problem and the
'orest's
'd control program. Trail crews and survey crews could
'Specially '*
IP Id with manual control of the v/eeds, as well as.
io i pi n g v; i t
1 t he 1 n ven to r y .
'. A coiTioleto on-going inventory and monitoring program of all
;nown weed infested areas, treated and untreated, must be
i nolement'^i'' in order to have a successful program.
The ^orest Service should work with counties to identify
ion-forest 'eed infested areas (gravel pits, etc.) that are
'otential sources of infestation to Forest Service lands.
’ . Foro'st Service vehicles, private road construction, logging,
30
niniiKj, dnd oil development vehirles nhould l)e cleancf r •jnlari
to prevent attachment ol noxious plant marts or seed;.
{] . Parkin^j lots for Forest Service and industry v.'ni.;l.?s si ^u
be weed free.
The cost of weed control sliould be included in tne cost of
timber sales, oil leases/explorat ion , mininq activit i , and
other disturbances.
Id. Tne Forest Service should undertake an active ; co jrar.; to
revejetate ex[>osed sites and use of certified wee i- 1 r n- seed
sboulJ bt? required.
11. The Forest Service should require the use of c ' ' i f ^
free supplement feed for use in the bac'ccoun t r / .
12. The Forest Service should close roads and elimiiate off-ro.
venicular travel in weed infested areas.
13. herbicide applicators should bo thoroughly trai loJ for
.proper applicaion techniques and safety precautions.
14. Use of herbicides only as a last resort in wilderness areas.
15. Aerial anmlication of herbicides should be prohi ited on
IT) rest Service lands.
Also, we feel a wick applicator should be used in riperian
a r ..'a s .
./e compleroent you on your commit. iient to initiatv' a weed
control mrograia and hopefully it will be a success.
S i ncere ly
Charles H. Ruzicka
31
n'y]m 7-
. /■■6 ; •
^ .1 >
r
i-'' pi--
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i MAY 14 1986 |
32
TO:
MARIAS RIVRR BASIN WRED CONIROi., INC.
COUR Tl lOUSE
SHELBY, MONTANA 5947^
April 6, 1986
Forest Supervisor
Noxious Weeds
Box 871
Great Falls, Montana ^9i;03
FOREST SERVICE
Great FiH’' •<ru«*na
j MAY 7 - 1986
RECEIVED
FR: Kathy Agpevig
MRBWC, INC, , Project Coordinator
102 Second St. S.E.
Cut Bank, Montana ^9k27
(k06) 873-14-960
I have read the draft Environmental Impact State-
ment regarding the ^-jear weed control plan. I
completely agree that alternative number 5 (IFM)
is the most sound and comprehensive approach to
weed control. This EIS appears to be complete
and thorough.
The MRBWC, INC. Project is slated to end in Dec.
1987. Because one of our most important target
areas has been the Blackfeet Reservation below
Lewis &Clark Nat*l. Forest, we are concerned about
the proposed gas and oil exploration near this
target area. We feel all gas/oil exploration
proposals must include a concise and comprehensive
reclamation plan regarding weed control on all
roads being built to an exploration site and at
the site itself.
Thank you for this opportunity to comment on your
Environmental Impact Statement,
Sincerely
Kathy Agpevig
33
i
5-19-86
Wildlands and resources associatic
FORlST Svi-- ■
L'?wii) ^ Cic^'K l''-'.' •
(jr' ,l •• '
KAY 22 1986
REC£iV‘YO _
Terry L. Albrecht, President
137 Old Ft. Shaw Rd.
Ft Shaw, Mt. 59443
Mr. John D. Gorman
Lewis & Clark National Forest
P.O. Box 871
Great Falls, Mt. 59403
Dear John:
Unfortunately, our group has no experti se . concerning the weed situation of the
forest. We wish to rely heavily on the professionalism of the Service and ask
that you consider these points:
1. Definition of infestation may account for the fact that we feel the affected
acreages are considerably under estimated^
2. Replant vegetative cover immediately after disruption of the surface and make
this a requirement of 'any private enterprise on the forest.
3. Road closures and public awareness of, how weeds are spread by vehicular travel.
4. Cooperation with the back-country horsemen and outfitters to enlist their
aid in early detection of infestation. , Require pelletized feed on the forest
for all.
5. Emphasize biological and cultivative control over chemical.
Sincerely,
34
BLACKFEET NATION
P.O. BOX 850
' " BROWNING, MONTANA 594
EARL OLD PERSON CHAIRMAN (406) 338-7179
JOHN RUSTER YELLOW KIDNEY, VICE CHAIRMAN
MYRNA I GALRREAEH SECRETARY
ElOUISE C COHELL, TREASURER
EX OFEICIO MEMBER
May 12, 1986
Jolm D. Gorman
I'orest Supervisor
Lewis & Clark National Forest
P.O. Box 871
Great Falls, F.Iontana 59403
Dear Mr. Gorman:
Enclosed is the Blackfeet Tribe's comments on the Lewis & Clark
National Forest Draft Environmental Impact Statement for the
treatment of noxious weeds on National Forest System lands.
VVe would appreciate it if a copy of the Final EIS , or any response
directly to us, be made available to:
Dave Broberg, Forester
Blackfeet Agency
Bureau of Indian Affairs
Browning, Montana 59417
Jim Claar , Biologist
BIA - Wildlife
P.O. Box A
Pablo, Montana 59855
Thank you for the opportunity to comment.
Very Truly Yours,
EARL OLD PERSON, Chairman
Blackfeet Tribe
enclosure:
cc: Dave Broberg
Jim Claar
35
COMMENTS ON NOXIOUS WEED CONTROL
LEWIS & CLARK DRAFT EIS
Alt #5 - Integrated Pest Management (p.b.)
Admitting that 5 emphasizes chemical control as the primary
method weakens the application of other control method and does
not allow proper side boards for "go - no go" conditions for the
use of chemical control.
Any chemical control which leaves the infected area less than
fully stocked or with less than 90% crown closure is of little
value because the site is open to reinvasion.
Affected Environment (TT 3. Q, C. + p. 12)
What precautions and identification training programs are going
to be put in place to insure against chemical applications of rare
plant populations occuring in noxious weed infection sites?
Alternative 1 No Action (TT 2. p.c.)
Knapweed and leafy spurge are primary invaders on disturbed sites
and have little ability to invade established sod or sites with close
to 100% crown covers. If proper range management , cattle disburse-
ment practices, road and recreation use development are being
required and inforced there should be little opportunity for noxious
weeds to "control out" desirable vegetation.
Alternative 2. Biological Control (p.c.)
Insects are but one facet of biological control. This section should
also include range stocking and grazing manipulation to increase
noxious weed control as well as plans for introduction or encourage-
ment of motive species that would be site competitors and occupiers
so that little opportunity is presented for a noxious weed to become
established. Natural plant compounds that can be extracted and
used as herbicides or growth exhibitors should also be discussed here.
3. Control Efforts to Date (p. 3)
The ratio of user funds to appropriated funds is appaling. It would
seem only fair and reasonable that the industry that brought us the
problem of noxious weeds should also bear tlie substantial portion
of this fiscal burden for treating the problem . It is inappropriate
for the general tax payer to shoulder 93% of the burden as they did
in 85 when the users (grazing industry) derive a very direct benefit.
To subsidize the grazing industry with artificially low land use permit
costs is one thing, but to balance the range improvement and protect-
ion work or the backs of the tax paying public is wrong.
36
TT 5 p. 20
The amount of watcf intake to reach ADI is directly pi-opfirlimial
to the size of the r-esevoir of water which is canitaminaled by x
amount of hei’bicide. The amount of water consumed is of
seconda ry iiTiportance.
Wouldn't it be reasonable to assume that a lru(;k accident and
resulting- spill is a "major- spill"?
E. Management Constraints (p. 22)
It would seem important to make mandatory for tlie laboi-ers who
apply herbicide to take a plant identification crourse and pass a
test which would require that they can competently identify not
only target weed species but also rare plant species.
Ceneral Comments:
It would seem prudent to take measures to ensui’e site occupancy
for all types of treatment, particularly mechanical and herbicidal,
by beneficial vegetation to prevent reinfection. Wouldn't reseeding
areas in conjunction with weed control practices be war-ranted?
37
I' s
iia6 ^
3ZI POPf-fyfW
cjoeiAw^
Dale Gorman
Forest Supervisor
Lewis and Clark National Forest
P.O. Box 871
Great Falls, Montana 59403
Dear Mr. Gorman:
Thank you for keeping me informed of your herbicide
program's progress.
Please notify me of all decisions regarding these programs.
Please also indicate if your documents include the worse case ana-
lysis by Ed Monnig in Region One* Please also indicate the date of
that document and the date of the decision notice, or its provision for
your use (e.g., accompanying correspondence from regional offices to
forest offices).
Thank you.
Rick Torre
38
i ''PR8 2J986
1
ij5£ceiyeiDj
T' f'i -• ^
April 2U , i 986
Celestine Lacey
P.U. Box 9U63
Helena, MT 59d04
John L). Gorman
Lewis and Clark Natl. Forest
Box 871
Great Falls, MT 59403
Re: Noxious Weed Treatment Program - Draft EIS
Dear Mr. Gorman,
Thank you for the opportunity to comment on the Lewis and
Clark National Forest Noxious Weed Control Draft Environmental
impact Statement. Overall, I believe your DEIS provides an
objective discussion of environmental and economic impacts that
would result from each of the five alternatives.
An integrated pest management approach is important in
managing noxious weeds on forestland and grazeable woodland. I
support apternative 5 (the preferred alternative) which provides
the best solution for weed control on the Lewis and Clark
National Forest.
There are several items that 1 would like to see included in
your DEIS.
1. Integrated pest management must include weed
prevention techniques. This includes implementing educational
programs on weed identification and control for all forest
service employees and users of forest lands. Publications,
posters, public service announcements, meetings, and other
educational techniques could be used to help educate the general
public. The use of certified weed free hay on all forest lands
would help prevent introduction of noxious weeds. Closure of
newly constructed roads (especially logging roads) until
permenant vegetative cover is established along roadsides.
Require all logging, oil exploration, and construction equipment
to be cleaned before entering a site.
Immediate action must also be taken to keep noxious weeds
from invading back-county and wilderness areas. This includes
controlling weeds along roadsides, trailheads, and educating
back-country users on noxious weeds.
39
1. The noxious weed list should include all weeds listea by
the Montana Department of Agriculture for the state. These weeds
should be addressed in the managment plan.
3. Page 12 (3). Why is herbicide use within campgrounds
restricted to Z,4-D only? Based on current information, other
herbicides may be less toxic and more effective on certain
noxious weed species. Herbicide application techniques are
extremely important in minimizing the impact of any herbicide in
a sensitive environment. Wick applicators, controlled droplet
applicators, and other hand held equipment will minimize damage
to non-target vegetation.
1 hope these suggestions will improve your noxious weed
management program on the Lewis and Clark National Forest. if
you have any questions, please contact me.
Sincerely ,
Celestine Lacey
40
COUNTY NOXIOUS WEED LIST
(Rules for the County Weed Control Act
Section 7-22-2101)
4.5.201 DESIGNATION OF NOXIOUS WEEDS (1) The department
designates certain exotic plants listed in these rules as
statewide noxious weeds under the County Weed Control Act
7-22-2101 (5) , MCA. All counties must implement management
standards for these noxious weeds consistent with weed management
criteria developed under 7-22-2109 (2) (b) of the Act. The
department established two categories of the noxious weeds.
(History: Sec. 7-22-2101 MCA; IMP, Sec. 7-22-2101 MCA; NEW 1986,
p. Eff. 3/14/86.)
4.5.202 CATEGORY 1 (1) Category 1 noxious weeds are
weeds that are currently established in many counties of the
state. Management criteria for control of these weeds is
necessary in all counties to contain or suppress existing
infestations or to prevent, through eradication or other
appropriate measures, new infestations of these weeds. All of
these weeds render land unfit or greatly limit the beneficial
uses .
(2) The following are designated as Category 1 noxious
weeds :
(a) Canada Thistle (Cirsium arvense)
(b) Field Bindweed (Convolvulus arvensis)
(c) Whitetop (Cardar ia draba)
(d) Leafy Spurge (Euphorbia esula)
(e) Russian Knapweed (Centaurea repens)
(f) Spotted Knapweed (Centaurea maculosa)
(g) Diffuse Knapweed (Centaurea diffusa)
(h) Dalmation Toadflax (Linaria dalmatica)
(i) St. Johnswort (Hypericum perforatum). (History: Sec.
7-22-2101 MCA; IMP, Sec. 7-22-2101 MCA; NEW 1986, p. Eff.
3/14/86. )
4.5.203 CATEGORY 2 (1) Category 2 noxious weeds are weeds
that have not been detected in the State of Montana or have
recently been introduced into the State of Montana. These weeds
have the potential for rapid spread and invasion of lands,
thereby rendering them unfit for beneficial uses. County
planning to prevent the spread or introduction of these weeds is
necessary. Management criteria for detection and immediate
action to eradicate or contain these weeds is necessary in all
counties .
(2) The following are designated as category 2 noxious
weeds :
(a) Dyers Woad ( Isatis tinctoria)
(b) Yellow Starthistle (Centaurea solstitialis)
(c) Common Crupina (Crupina vulgaris )
(d) Tansy Ragwort (Senecio jacobaea)
(e) Rush Skeletonweed (Chondrilla juncea) . (History: Sec.
7-22-2101 MCA; IMP, Sec. 7-22-2101 MCA; NEW 1986. p. Eff.
3/14/86.)
41
Z'M'3
u -' i -c.']'!- '.-n
. ;ii:d Cl.Dri: i'':ntiuna] Forect
oa ^.71
-rort >7:11-, : ■!•. 7':'+C3
FOREST SERVICE j
Lewrts & Clark l4atIonal Fv^rost
Great Falla Montana
■MAY1619835
RECEIVED
.1
In I’e^r-rds to the FnA/-:;.ron!rient&l Imroct ototement for tiie troat-
of noxiouo v/eedo for the llotrict-- l/jn very ■; leaned
U eee ore j}itpre"-t irr the control of noxious v;.eeds. A fev;
'o'i ':rs sperit now ivill he lust a dro'' in the bucket com-
.r’--'d to 'vhet it could cost later,
ereonclly nave seen h'-'V/ fast -b-otted knapweed tool; over
■ ■ e ) :' ssor.la and Z\.' n bake areas. ho one cared at that ti .ric
•.iv.l no’-.' it i-'. tot.:'-l,y out of h rid. ue have too beautiful an,
are- for tt.at to h<api-:eh.
j' ee wnero thei' a • a lot of C.'-nada Thistle acreage listed,
-■vi.nr; rerne i.od tlierc at bhc--'r. Cree' fo.,- f:rt.y years, I've
h- hi 'I lot •jf experience wit.i tiist, where thrr .; is far..-
ir-.u. Ivcd or adjoining thor.'^
I'ff' for ci-..ntrol b.' .i-.prr.;.' ing . .t .i.'anch or on all of .cur
h a, I ..'oi .dn't ap:end a jien ny for con troll This n.ay net
■ .• .ail ' libo mo, ooiin, I'Jirt I've seer lot of big i ro'j]-erii.L:
ti.r.rQ -in’: i-«.„.tuiO to ic. care of it. 1 shall .o 'j.ritc furthei-
■'et. ii as to uv reasons.
i co,r:e to ■h'-'O': Iree' thf^ fall, of 194h-- se lot rho Poro.it
.-■er . ice puu in the ndams Creen koad' in 194o, .>iithin tv;o to
fou • ,;/ca.rs, all of the areas that were torn up came into
h n.ada Thi.stle. This also i'ncluded all tne cut over areas,
next to i: ,> : .inch and any ;:j.-..ce that was logged.
y , i
b.-rrida Tbi-;
■ 0 V , a I'V’
too .ai’sa.
t fi.ed
tic.
th.er€'
id Ju
to '-et the Forest ..Service to spr.ay for
bach t'ime I v-;as i.n formed there v,a.s no
WO.S no 'ntereot either. The ole ti.mers i.n
;rt it ten .years a^^g n.atii'ae ■vi].l t.-;ke care
42
o,! UiJr,; (.I.-in-ido .-l'i i , ; l;le ^rubl'-^' , ’’ <■ 'o , '.nf.'-i that way,
.ven tlio road, throufli r\j ranch. A lot : -r e.y
liavc been 'alcted, i’ir.o tiao tau/^ht me a lot becauGC
I've boon very interested to ] eax’n some of tlie finer
•i'Oi. r;tj of r,;! tu:j.-o ,
J .'.aid before,, v/nere tiierc is no farm 'and jiivclved,
ji.il.ure v/ill ta,ke c-re of tliis Canada lliistlc Tm-o’)le;ii
■:n tnc fore;! j-orids and roads, I've seen it I'.o] yen , so
.'-sen for tbatj
'''he.-se other noxiou.s v/eed:, ^\ou h-r've. listed need a lot of
V/'' tchin'': and effort. You yet a lot of locyiny e^ uipraeiit
from i.nfe,. ted aress ainny with hr.nters from f.ar and widp
Ifr t can infest '^■n '’-ron in a ^nort tii c,
'n favor of usJ n;; a good spray to spot spray just
■. 'Koae the v/eodc are, I thini. that where tlier-e are just a
ow rlautr:,
s, , erson c
an
pull
tiler .
. up by the roots and get
’ll,' job done
, too.
y nio'/rin;
people to
fi
sh at
t h e ,
.aiitetail. .ieserv. ir. .e
sve brouy’.t
us a lot
of
Knopw
' e e u ,
If it is scattered,
nil it OU''
b,^' roots
w'n oi'
the
ground i_- wet .and for
■'OS. vier amounts ve oprai'^ — at the present time, i.t i.- under
C L J’l I- .c o 1 .
]. nt to t'nar': ou for tl'.e chance to participate in this,
and in clo.'^ in, T would j.iKc to :..entioa the ...ort imiortcnt
T:,-rt of my .spiaa yin.a,- proyram. It doesn't m-ke any dif-
f'srerce ">o\! t.iUcb time is sxwnb on sieetinys ar information
•■ik' ■ !ie whole rroywam
o r.icJ n 1 1 1 t h a s t 'n e s } r a y e r
'.ell i.s.aiued as to wuat they ai'e su^ o . ed to
dedicated to the job. There would be a lot
vf.i'.h the environment if that were tfne
is no better than the man or
in thej.r hand. ''pov must be
spray . nu
less problei:G
case. Thank.'-, again.
j. oui-s Trul; ,
€ i (
'erwi f. Tiu.rson
43
3721 7th Avenue North
Great Falls, Montana 59^01
May 19, 1986
I'M' V-
Forest Supervisor
Lewis and Clark National Forest
Noxious Weeds
Box 871
Great Falls, Montana 59^03
Sir;
The following are my comments regarding the Draft Environmental Impact
Statement on Noxious Weed Control dated March 1986:
Of the alternatives considered in this impact statement. No. 5 — Integrated Pest
Management would be the most cost effective and successful in control and
eradication, I would urge this type of approach to control of noxious weeds.
However, two points are made in Section E, Management Constraints, on which I
would like to comment briefly.
Constraint Item 5 limits herbicide useage in campgrounds to 2,4-D. Such a
limitation will result in less effective containment and eradication success
with weeds for which 2,i|-D is not the optimum control formula. Since
ampgrounds are focal points of human, vehicular, and animal activities (as
jted in Sect. C, 2d.), non-eradication in these areas could result in
infestation of adjacent clean or previously treated forest areas.
Constraint Item 4 provides for Cultural control only in wilderness areas. Such
limitations are probably not the most cost effective. Table II EVALUATION OF
ALTERNATIVES notes that Cultural control has the highest Soil Erosion impact
and is the most costly both short and long term of any of the action
alternatives. Soil Erosion from grubbing weeds should certainly be a
consideration within areas delicate enough to merit Congressional action.
Infestations of weeds result from both natural occurances and through human
related activities (i.e. weed seeds transported with feed grains and hay for
pack horses). Unless herbicide use is specifically prohibited by law, spot
spray applications together with appropriate mechanical treatment should be
evaluated for effective eradication at all appropriate sites — including those
within wilderness areas.
Thank you for the
II
rf
44
r
May 19, 1986
Dale Gorman
Supervisor
Lewis & Clark National Forest
Great Falls, Montana 59401
FOREST SER'GCE
Lewis i C'aik
fjraai T di<’ i ■
f' 201986
RECEIVED
Dear Mr. Gorman:
In reference to the noxious weed control plans, I wish to make the
recommendation as follows: to use every tool available to you to
effectively stop the spread of noxious weeds and the eventual eradicatio
of same in the Lewis & Clark National Forest.
Sincerely ,
a i
C.E "Ted" Lucas
Highwood, Montana
59450
45
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