A06_Herbicide_SOP.pdf

APPENDIX B

HERBICIDE TREATMENT STANDARD

OPERATING PROCEDURES

STANDARD OPERATING PROCEDURES

APPENDIX B

HERBICIDE TREATMENT STANDARD

OPERATING PROCEDURES

This section identifies standard operating procedures (SOPs) that will be followed by the U.S. Department of the Interior Bureau of Land Management (USDI BLM) under all alternatives to ensure that risks to human health and the environment from herbicide treatment actions will be kept to a minimum. Standard operating procedures are the management controls and performance standards required for vegetation management treatments. These practices are intended to protect and enhance natural resources that could be affected by future vegetation treatments.

Prevention of Weeds and Early Detection and Rapid Response

Once weed populations become established, infestations can increase and expand in size. Weeds colonize highly disturbed ground and invade plant communities that have been degraded, but are also capable of invading intact communities. Therefore, prevention, early detection, and rapid response are the most cost-effective methods of weed control. Prevention, early detection, and rapid response strategies that reduce the need for vegetative treatments for noxious weeds should lead to a reduction in the number of acres treated using herbicides in the future by reducing or preventing weed establishment.

As stated in the BLM’s Partners Against Weeds: An Action Plan for the BLM, prevention and public education are the highest priority weed management activities. Priorities are as follows:

• Priority 1: Take actions to prevent or minimize the need for vegetation control when and where feasible, considering the management objectives of the site.

• Priority 2: Use effective nonchemical methods of vegetation control when and where feasible.

• Priority 3: Use herbicides after considering the effectiveness of all potential methods or in combination with other methods or controls.

Prevention is best accomplished by ensuring the seeds and vegetatively reproductive plant parts of new weed species are not introduced into new areas.

The BLM is required to develop a noxious weed risk assessment when it is determined that an action may introduce or spread noxious weeds or when known habitat exists. If the risk is moderate or high, the BLM may modify the project to reduce the likelihood of weeds infesting the site, and to identify control measures to be implemented if weeds do infest the site.

To prevent the spread of weeds, the BLM takes actions to minimize the amount of existing non-target vegetation that is disturbed or destroyed during project or vegetation treatment actions (Table B-1). During project planning, the following steps are taken:

• Incorporate measures to prevent introduction or spread of weeds into project layout, design, alternative evaluation, and project decisions.

• During environmental analysis for projects and maintenance programs, assess weed risks, analyze potential treatment of high-risk sites for weed establishment and spread, and identify prevention practices.

• Determine prevention and maintenance needs, to include the use of herbicides if needed, at the onset of project planning.

• Avoid or remove sources of weed seed and propagules to prevent new weed infestations and the spread of existing weeds.

During project development, weed infestations are prioritized for treatment in project operating areas and along access routes. Weeds present on or near the site are identified, a risk assessment is completed, and weeds are controlled as necessary. Project staging areas are weed free, and travel through weed infested areas is avoided or minimized. Examples of prevention actions to be followed during project activities include cleaning all equipment and clothing before entering the project site; avoiding soil disturbance and the creation of other

BLM Vegetation Treatments Using Herbicides B-1 September 2007 Final Programmatic EIS Record of Decision soil conditions that promote weed germination and establishment; and using weed-free seed, hay, mulch, gravel, soil, and mineral materials on public lands where there is a state or county program in place.

Conditions that enhance invasive species abundance should be addressed when developing mitigation and prevention plans for activities on public lands. These conditions include excessive disturbance associated with road maintenance, poor grazing management, and high levels of recreational use. If livestock grazing is managed to maintain the vigor of native perennial plants, particularly grasses, the chance of weeds invading rangeland is much less. By carefully managing recreational use and educating the public on the potential impacts of recreational activities on vegetation, the amount of damage to native vegetation and soil can be minimized at high use areas, such as campgrounds and off-highway vehicle (OHV) trails.

Early detection in recreation areas is focused on roads and trails, where much of the weed spread occurs.

The BLM participates in the National Early Warning and Rapid Response System for Invasive Plants (Figure B-1). The goal of this System to minimize the establishment and spread of new invasive species through a coordinated framework of public and private processes by:

• Early detection and reporting of suspected new plant species to appropriate officials;

• Identification and vouchering of submitted specimens by designated specialists;

• Verification of suspected new state, regional, and national plant records;

• Archival of new records in designated regional and plant databases;

• Rapid assessment of confirmed new records;

and

• Rapid response to verified new infestations that are determined to be invasive.

Herbicide Treatment Planning

BLM Manual 9011 (Chemical Pest Control) outlines the policies, and BLM Handbook H-9011-1 (Chemical Pest Control) outlines the procedures, for use of herbicides on public lands. As part of policy, the BLM is required to thoroughly evaluate the need for chemical treatments and their potential for impact on the environment. The BLM is required to use only U.S.

Environmental Protection Agency (USEPA)-registered herbicides that have been properly evaluated under National Environmental Policy Act (NEPA), and to carefully follow label directions and additional BLM requirements.

An operational plan is developed and updated for each herbicide project. The plan includes information on project specifications, key personnel responsibilities, and communication, safety, spill response, and emergency procedures. For application of herbicides not approved for aquatic use, the plan should also specify minimum buffer widths between treatment areas and water bodies. Recommended widths are provided in BLM Handbook H-9011-1 (Chemical Pest Control), but actual buffers are site and herbicide active ingredient specific, and are determined based on a scientific analysis of environmental factors, such as climate, topography, vegetation, and weather; timing and method of application; and herbicide risks to humans and non-target species. Table B-2 summarizes important SOPs that should be used when applying herbicides to help protect resources of concern on public lands.

Revegetation

Disturbed areas may be reseeded or planted with desirable vegetation when the native plant community cannot recover and occupy the site sufficiently.

Determining the need for revegetation is an integral part of developing a vegetation treatment. The most important component of the process is determining whether active (seeding/planting) or passive (natural recovery) revegetation is appropriate.

U.S. Department of the Interior policy states, “Natural recovery by native plant species is preferable to planting or seeding, either of natives or non-natives. However, planting or seeding should be used only if necessary to prevent unacceptable erosion or resist competition from non-native invasive species” (620 Departmental Memorandum 3 2004). This policy is reiterated in the USDI Burned Area Emergency Stabilization and Rehabilitation Manual, the BLM Burned Area Emergency Stabilization and Rehabilitation Manual (BLM H-1742-1), and the Interagency Burned Area Rehabilitation Guidebook.

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TABLE B-1

Prevention Measures

BLM Activity Prevention Measure

Project Planning

• Incorporate prevention measures into project layout and design, alternative evaluation, and project decisions to prevent the introduction or spread of weeds.

• Determine prevention and maintenance needs, including the use of herbicides, at the onset of project planning.

• Before ground-disturbing activities begin, inventory weed infestations and prioritize areas for treatment in project operating areas and along access routes.

• Remove sources of weed seed and propagules to prevent the spread of existing weeds and new weed infestations.

• Pre-treat high-risk sites for weed establishment and spread before implementing projects.

• Post weed awareness messages and prevention practices at strategic locations such as trailheads, roads, boat launches, and public land kiosks.

• Coordinate project activities with nearby herbicide applications to maximize the cost-effectiveness of weed treatments.

Project Development

• Minimize soil disturbance to the extent practical, consistent with project objectives.

• Avoid creating soil conditions that promote weed germination and establishment.

• To prevent weed germination and establishment, retain native vegetation in and around project activity areas and keep soil disturbance to a minimum, consistent with project objectives.

• Locate and use weed-free project staging areas. Avoid or minimize all types of travel through weed-infested areas, or restrict travel to periods when the spread of seeds or propagules is least likely.

• Prevent the introduction and spread of weeds caused by moving weed-infested sand, gravel, borrow, and fill material.

• Inspect material sources on site, and ensure that they are weed-free before use and transport.

Treat weed-infested sources to eradicate weed seed and plant parts, and strip and stockpile contaminated material before any use of pit material.

• Survey the area where material from treated weed-infested sources is used for at least 3 years after project completion to ensure that any weeds transported to the site are promptly detected and controlled.

• Prevent weed establishment by not driving through weed-infested areas.

• Inspect and document weed establishment at access roads, cleaning sites, and all disturbed areas; control infestations to prevent weed spread within the project area.

• Avoid acquiring water for dust abatement where access to the water is through weed-infested sites.

• Identify sites where equipment can be cleaned. Clean equipment before entering public lands.

• Clean all equipment before leaving the project site if operating in areas infested with weeds.

• Inspect and treat weeds that establish at equipment cleaning sites.

• Ensure that rental equipment is free of weed seed.

• Inspect, remove, and properly dispose of weed seed and plant parts found on workers’ clothing and equipment. Proper disposal entails bagging the seeds and plant parts and incinerating them.

Revegetation

• Include weed prevention measures, including project inspection and documentation, in operation and reclamation plans.

• Retain bonds until reclamation requirements, including weed treatments, are completed, based on inspection and documentation.

• To prevent conditions favoring weed establishment, reestablish vegetation on bare ground caused by project disturbance as soon as possible using either natural recovery or artificial techniques.

• Maintain stockpiled, uninfested material in a weed-free condition.

BLM Vegetation Treatments Using Herbicides B-3 September 2007

TABLE B-1 (Cont.)

Prevention Measures

BLM Activity Prevention Measure

Revegetation (Cont.)

• Revegetate disturbed soil (except travel ways on surfaced projects) in a manner that optimizes plant establishment for each specific project site. For each project, define what constitutes disturbed soil and objectives for plant cover revegetation. Revegetation may include topsoil replacement, planting, seeding, fertilization, liming, and weed-free mulching, as necessary.

• Where practical, stockpile weed-seed-free topsoil and replace it on disturbed areas (e.g., road embankments or landings).

• Inspect seed and straw mulch to be used for site rehabilitation (for wattles, straw bales, dams, etc.) and certify that they are free of weed seed and propagules.

• Inspect and document all limited term ground-disturbing operations in noxious weed infested areas for at least 3 growing seasons following completion of the project.

• Use native material where appropriate and feasible. Use certified weed-free or weed-seed-free hay or straw where certified materials are required and/or are reasonably available.

• Provide briefings that identify operational practices to reduce weed spread (for example, avoiding known weed infestation areas when locating fire lines).

• Evaluate options, including closure, to regulate the flow of traffic on sites where desired vegetation needs to be established. Sites could include road and trail rights-of-way (ROW), and other areas of disturbed soils.

In addition to these handbooks and policy, use of native and non-native seed in revegetation and restoration is guided by BLM Manual 1745 (Introduction, Transplant, Augmentation and Reestablishment of Fish, Wildlife and Plants). This manual states that native species shall be used, unless it is determined through the NEPA process that: 1) suitable native species are not available; 2) the natural biological diversity of the proposed management area will not be diminished; 3) exotic and naturalized species can be confined within the proposed management area; 4) analysis of ecological site inventory information indicates that a site will not support reestablishment of a species that historically was part of the natural environment; or 5) resource management objectives cannot be met with native species.

When natural recovery is not feasible, revegetation can be used to stabilize and restore vegetation on disturbed sites and to eliminate or reduce the conditions that favor invasive species. Reseeding or replanting may be required when there is insufficient vegetation or seed stores to naturally revegetate the site.

To ensure revegetation success, there must be adequate soil for root development and moisture storage, which provides moisture to support the new plants. Chances for revegetation success are improved by selecting seed with high purity and percentage germination; selecting native species or cultivars adapted to the area; planting at proper depth, seeding rate, and time of the year for the region; choosing the appropriate planting method;

and, where feasible, removing competing vegetation.

Planting mixtures are adapted for the treatment area and site uses. A combination of forbs, perennial grasses, and shrubs is typically used on rangeland sites, while shrubs and trees might be favored for riparian and forestland sites. A mixture of several native plant species and types or functional groups enhances the value of the site for fish and wildlife and improves the health and aesthetic character of the site. Mixtures can better take advantage of variable soil, terrain, and climatic conditions, and thus are more likely to withstand insect infestations and survive adverse climatic conditions.

The USDI BLM Native Seed program was developed in response to Congressional direction to supply native plant material for emergency stabilization and longer-term rehabilitation and restoration efforts. The focus of the program is to increase the number of native plant species for which seed is available and the total amount of native seed available for these efforts. To date, the program has focused on native plant material needs of emergency stabilization and burned area rehabilitation in the Great Basin, but is expanding to focus on areas such as western Oregon, the Colorado Plateau, and most recently the Mojave Desert. The Wildland Fire Management Program funds and manages the effort.

The National Seed Warehouse is a storage facility for the native seed supply. Through a Memorandum of

BLM Vegetation Treatments Using Herbicides B-4 September 2007

Contact Local

Agency

Early

Warning

Rapid

Response

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Animal and Plant Health Inspection

Service

(APHIS)

National Agricultural

Pest Information

System

(NAPIS)

Database

Infestation on

Private Land

Call 800 Number

Suspected

New National

Records

Designated State Herbaria

Detection and

Reporting by:

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Federal and

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Records

State Weed Team

Assessment

APHIS

New Pest

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(Regulatory

Assessment)

National

Coordination

Mechanism

(Ecological

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Online Plant

Databases

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Public and

Private Lands

Action:

Form a Weed

Management

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Public Lands

Action by:

Impacted

Agency

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Detection Reporting

ID

Vouchering

Rapid Assessment

Program Planning

Figure B-1. National Early Warning and Rapid Response System for Invasive Plants.

BLM Vegetation Treatments Using Herbicides B-5 September 2007

Understanding with the BLM Idaho State Director, each state (Idaho, Oregon, Nevada, Utah and Colorado) can reserve an annual seed supply for purchase based on a reasonable projection of annual acreage to be stabilized or rehabilitated over a 5-year period.

The Great Basin Restoration Initiative (GBRI) grew out of concern for the health of the Great Basin after the wildfires of 1999. The goal of GBRI is to implement treatments and strategies to maintain functioning ecosystems and to proactively restore degraded ones at strategic locations. Native plants are emphasized in restoration projects where their use is practical and the potential for success is satisfactory. Monitoring is recommended to measure treatment success. To increase the availability of native plants, especially native forbs, the GBRI has established a collaborative native plant project, the Great Basin Native Plant Selection and Increase Project, to increase native plant availability and the technology to successfully establish these plants. This project is supported by funding from the BLM’s Native Plant Initiative.

The BLM will follow the following SOPs when revegetating sites:

• Cultivate previously disturbed sites to reduce the amount of weed seeds in the soil seedbank.

• Revegetate sites once work is completed or soon after a disturbance.

• When available, use native seed of known origin as labeled by state seed certification programs.

• Use seed of non-native cultivars and species only when locally adapted native seed is not available or when it is unlikely to establish quickly enough to prevent soil erosion or weed establishment.

• Use seed that is free of noxious and invasive weeds, as determined and documented by a seed inspection test by a certified seed laboratory.

• Limit nitrogen fertilizer applications that favor annual grass growth over forb growth in newly seeded areas, especially where downy brome (cheatgrass) and other invasive annuals are establishing.

• Use clean equipment, free of plants and plant parts, on revegetation projects to prevent the inadvertent introduction of weeds into the site.

• Where important pollinator resources exist, include native nectar and pollen producing plants in the seed mixes used in restoration and reclamation projects. Include non-forage plant species in seed mixes for their pollinator/host relationships as foraging, nesting, or shelter species. Choose native plant species over manipulated cultivars, especially of forbs and shrubs, since natives tend to have more valuable pollen and nectar resources than cultivars. Ensure that bloom times for the flowers of the species chosen match the activity times for the pollinators. Maintain sufficient litter on the soil surfaces of native plant communities for ground-nesting bees.

• Where feasible, avoid grazing by domestic and wild animals on treatment sites until vegetation is well established. Where total rest from grazing is not feasible, efforts should be made to modify the amount and/or season of grazing to promote vegetation recovery within the treatment area. Reductions in grazing animal numbers, permanent or temporary fencing, changes in grazing rotation, and identification of alternative forage sources are examples of methods that could be used to remove, reduce or modify grazing impacts during vegetation recovery.

Special Precautions

Special Status Species

Federal policies and procedures for protecting federally-listed threatened and endangered plant and animal species, and species proposed for listing, were established by the Endangered Species Act of 1973 and regulations issued pursuant to the Act. The purposes of the Act are to provide mechanisms for the conservation of threatened and endangered species and their habitats.

Under the Act, the Secretary of the Interior is required to determine which species are threatened or endangered and to issue recovery plans for those species.

Section 7 of the Act specifically requires all federal agencies to use their authorities in furtherance of the Act to carry out programs for the conservation of listed

BLM Vegetation Treatments Using Herbicides B-6 September 2007 species, and to ensure that no agency action is likely to jeopardize the continued existence of a listed species or adversely modify critical habitat. Policy and guidance (BLM Manual 6840; Special Status Species) also stipulates that species proposed for listing must be managed at the same level of protection as listed species.

The BLM state directors may designate special status in cooperation with their respective state. These special status species must receive, at a minimum, the same level of protection as federal candidate species. The BLM will also carry out management for the conservation of state-listed species, and state laws protecting these species will apply to all BLM programs and actions to the extent that they are consistent with Federal Land Policy and Management Act (FLPMA) and other federal laws.

The BLM consulted with the U.S. Fish and Wildlife Service (UFWS) and National Marine Fisheries Service (NMFS) during development of the Final Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact Statement (PEIS) as required under Section 7 of the Endangered Species Act. As part of this process, the BLM prepared a formal consultation package that included a description of the program;

species listed as threatened or endangered, species proposed for listing, and critical habitats that could be affected by the program; and a Biological Assessment (BA) that evaluated the likely impacts to listed species, species proposed for listing, and critical habitats from the proposed vegetation treatment program. Over 300 species were evaluated in the BA. The BA also provides broad guidance at a programmatic level for actions that will be taken by the BLM to avoid adversely impacting species or critical habitat.

Before any vegetation treatment or ground disturbance occurs, BLM policy requires a survey of the project site for species listed or proposed for listing, or special status species. This is done by a qualified biologist and/or botanist who consults the state and local databases and visits the site at the appropriate season. If a proposed project may affect a proposed or listed species or its critical habitat, the BLM consults with the USFWS and/or NMFS. A project with a “may affect, likely to adversely affect” determination requires formal consultation and receives a Biological Opinion from the USFWS and/or NMFS. A project with a “may affect, not likely to adversely affect” determination requires informal consultation and receives a concurrence letter from USFWS and/or NMFS, unless that action is implemented under the authorities of the alternative consultation agreement pursuant to counterpart regulations established for National Fire Plan projects.

Wilderness Areas

Wilderness areas, which are designated by Congress, are defined by the Wilderness Act of 1964 as places “where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain.” The BLM manages 175 Wilderness Areas encompassing over 7.2 million acres.

Activities allowed in wilderness areas are identified in wilderness management plans prepared by the BLM.

The BLM does not ordinarily treat vegetation in wilderness areas, but will control invasive and noxious weeds when they threaten lands outside wilderness area or are spreading within the wilderness and can be controlled without serious adverse impacts to wilderness values.

Management of vegetation in a wilderness area is directed toward retaining the natural character of the environment. Tree and shrub removal is usually not allowed, except for fire, insect, or disease control.

Reforestation is generally prohibited except to repair damage caused by humans in areas where natural reforestation is unlikely. Only native species and primitive methods, such as hand planting, are allowed for reforestation.

Tools and equipment may be used for vegetation management when they are the minimum amount necessary for the protection of the wilderness resource.

Motorized tools may only be used in special or emergency cases involving the health and safety of wilderness visitors, or the protection of wilderness values.

Habitat manipulation using mechanical or chemical means may be allowed to protect threatened and endangered species and to correct unnatural conditions, such as weed infestations, resulting from human influence.

The BLM also manages a total of 610 Wilderness Study Areas (WSAs) encompassing nearly 14.3 million acres.

These are areas that have been determined to have wilderness characteristics worthy of consideration for wilderness designation. The BLM’s primary goals in WSAs are to manage them so as to not impair their wilderness values and to maintain their suitability for

BLM Vegetation Treatments Using Herbicides B-7 September 2007 preservation as wilderness until Congress makes a determination on their future.

In WSAs, the BLM must foster a natural distribution of native species of plants and animals by ensuring that ecosystems and processes continue to function naturally.

Cultural Resources

The effects of BLM actions on cultural resources are addressed through compliance with the National Historic Preservation Act, as implemented through a national Programmatic Agreement (Programmatic Agreement among the Bureau of Land Management, the Advisory Council on Historic Preservation, and the National Conference of State Historic Preservation Officers Regarding the Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act) and state-specific protocol agreements with State Historic Preservation Officers (SHPOs). The BLM’s responsibilities under these authorities are addressed as early in the vegetation management project planning process as possible.

The BLM meets its responsibilities for consultation and government-to-government relationships with Native American tribes by consulting with appropriate tribal representatives prior to taking actions that affect tribal interests. The BLM’s tribal consultation policies are detailed in BLM Manual 8120 (Tribal Consultation Under Cultural Resource Authorities) and Handbook H 8120-1 (Guidelines for Conducting Tribal Consultation). The BLM consulted with Native

American tribes and Alaska Native groups during development of the PEIS. Information gathered on important tribal resources and potential impacts to these resources from herbicide treatments is presented in the analysis of impacts.

When conducting vegetation treatments, field office personnel consult with relevant parties (including tribes, native groups, and SHPOs), assess the potential of the proposed treatment to affect cultural and subsistence resources, and devise inventory and protection strategies suitable to the types of resources present and the potential impacts to them.

Herbicide treatments, for example, are unlikely to affect buried cultural resources, but might have a negative effect on traditional cultural properties comprised of plant foods or materials significant to local tribes and native groups. These treatments require inventory and protection strategies that reflect the different potential of each treatment to affect various types of cultural resources.

Impacts to significant cultural resources are avoided through project redesign or are mitigated through data recovery, recordation, monitoring, or other appropriate measures. When cultural resources are discovered during vegetation treatment, appropriate actions are taken to protect these resources.

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TABLE B-2

Standard Operating Procedures for Applying Herbicides

Resource Element Standard Operating Procedure

Guidance Documents BLM Handbook H-9011-1 (Chemical Pest Control); and manuals 1112 (Safety), 9011 (Chemical Pest Control), 9012 (Expenditure of Rangeland Insect Pest Control Funds), 9015 (Integrated Weed Management), and 9220 (Integrated Pest Management).

General

• Prepare operational and spill contingency plan in advance of treatment.

• Conduct a pretreatment survey before applying herbicides.

• Select herbicide that is least damaging to the environment while providing the desired results.

• Select herbicide products carefully to minimize additional impacts from degradates, adjuvants, inert ingredients, and tank mixtures.

• Apply the least amount of herbicide needed to achieve the desired result.

• Follow herbicide product label for use and storage.

• Have licensed applicators apply herbicides.

• Use only USEPA-approved herbicides and follow product label directions and “advisory” statements.

• Review, understand, and conform to the “Environmental Hazards” section on the herbicide product label. This section warns of known pesticide risks to the environment and provides practical ways to avoid harm to organisms or to the environment.

• Consider surrounding land use before assigning aerial spraying as a treatment method and avoid aerial spraying near agricultural or densely populated areas.

• Minimize the size of application area, when feasible.

• Comply with herbicide-free buffer zones to ensure that drift will not affect crops or nearby residents/landowners.

• Post treated areas and specify reentry or rest times, if appropriate.

• Notify adjacent landowners prior to treatment.

• Keep a copy of Material Safety Data Sheets (MSDSs) at work sites. MSDSs are available for review at http://www.cdms.net/.

• Keep records of each application, including the active ingredient, formulation, application rate, date, time, and location.

• Avoid accidental direct spray and spill conditions to minimize risks to resources.

• Consider surrounding land uses before aerial spraying.

• Avoid aerial spraying during periods of adverse weather conditions (snow or rain imminent, fog, or air turbulence).

• Make helicopter applications at a target airspeed of 40 to 50 miles per hour (mph), and at about

30 to 45 feet above ground.

• Take precautions to minimize drift by not applying herbicides when winds exceed >10 mph

(>6 mph for aerial applications), or a serious rainfall event is imminent.

• Use drift control agents and low volatile formulations.

• Conduct pre-treatment surveys for sensitive habitat and special status species within or adjacent to proposed treatment areas.

• Consider site characteristics, environmental conditions, and application equipment in order to minimize damage to non-target vegetation.

• Use drift reduction agents, as appropriate, to reduce the drift hazard to non-target species.

• Turn off applied treatments at the completion of spray runs and during turns to start another spray run.

• Refer to the herbicide product label when planning revegetation to ensure that subsequent vegetation would not be injured following application of the herbicide.

• Clean OHVs to remove seeds.

BLM Vegetation Treatments Using Herbicides B-9 September 2007 http://www.cdms.net/

TABLE B-2 (Cont.)

Standard Operating Procedures for Applying Pesticides

Air Quality

See Manual 7000 (Soil, Water, and Air Management)

• Consider the effects of wind, humidity, temperature inversions, and heavy rainfall on herbicide effectiveness and risks.

• Apply herbicides in favorable weather conditions to minimize drift. For example, do not treat when winds exceed 10 mph (>6 mph for aerial applications) or rainfall is imminent.

• Use drift reduction agents, as appropriate, to reduce the drift hazard.

• Select proper application equipment (e.g., spray equipment that produces 200- to 800-micron diameter droplets [spray droplets of 100 microns and less are most prone to drift]).

• Select proper application methods (e.g., set maximum spray heights, use appropriate buffer distances between spray sites and non-target resources).

Soil

See Manual 7000 (Soil, Water, and Air Management)

• Minimize treatments in areas where herbicide runoff is likely, such as steep slopes when heavy rainfall is expected.

• Minimize use of herbicides that have high soil mobility, particularly in areas where soil properties increase the potential for mobility.

• Do not apply granular herbicides on slopes of more than 15% where there is the possibility of runoff carrying the granules into non-target areas.

Water Resources

See Manual 7000 (Soil, Water, and Air Management)

• Consider climate, soil type, slope, and vegetation type when developing herbicide treatment programs.

• Select herbicide products to minimize impacts to water. This is especially important for application scenarios that involve risk from active ingredients in a particular herbicide, as predicted by risk assessments.

• Use local historical weather data to choose the month of treatment. Considering the phenology of the target species, schedule treatments based on the condition of the water body and existing water quality conditions.

• Plan to treat between weather fronts (calms) and at appropriate time of day to avoid high winds that increase water movements, and to avoid potential stormwater runoff and water turbidity.

• Review hydrogeologic maps of proposed treatment areas. Note depths to groundwater and areas of shallow groundwater and areas of surface water and groundwater interaction.

Minimize treating areas with high risk for groundwater contamination.

• Conduct mixing and loading operations in an area where an accidental spill would not contaminate an aquatic body.

• Do not rinse spray tanks in or near water bodies. Do not broadcast pellets where there is danger of contaminating water supplies.

• Maintain buffers between treatment areas and water bodies. Buffer widths should be developed based on herbicide- and site-specific criteria to minimize impacts to water bodies.

• Minimize the potential effects to surface water quality and quantity by stabilizing terrestrial areas as quickly as possible following treatment.

Wetlands and Riparian Areas

• Use a selective herbicide and a wick or backpack sprayer.

• Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on risk assessment guidance, with minimum widths of 100 feet for aerial, 25 feet for vehicle, and 10 feet for hand spray applications.

Vegetation

See Handbook H-4410-1 (National Range Handbook), and manuals 5000 (Forest Management) and 9015 (Integrated Weed Management)

• Refer to the herbicide label when planning revegetation to ensure that subsequent vegetation would not be injured following application of the herbicide.

• Use native or sterile species for revegetation and restoration projects to compete with invasive species until desired vegetation establishes.

• Use weed-free feed for horses and pack animals. Use weed-free straw and mulch for revegetation and other activities.

• Identify and implement any temporary domestic livestock grazing and/or supplemental feeding restrictions needed to enhance desirable vegetation recovery following treatment. Consider adjustments in the existing grazing permit, to maintain desirable vegetation on the treatment site.

BLM Vegetation Treatments Using Herbicides B-10 September 2007

Pollinators

• Complete vegetation treatments seasonally before pollinator foraging plants bloom.

• Time vegetation treatments to take place when foraging pollinators are least active both seasonally and daily.

• Design vegetation treatment projects so that nectar and pollen sources for important pollinators and resources are treated in patches rather than in one single treatment.

• Minimize herbicide application rates. Use typical rather than maximum rates where there are important pollinator resources.

• Maintain herbicide free buffer zones around patches of important pollinator nectar and pollen sources.

• Maintain herbicide free buffer zones around patches of important pollinator nesting habitat and hibernacula.

• Make special note of pollinators that have single host plant species, and minimize herbicide spraying on those plants (if invasive species) and in their habitats.

Fish and Other Aquatic Organisms

See manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

• Use appropriate buffer zones based on label and risk assessment guidance.

• Minimize treatments near fish-bearing water bodies during periods when fish are in life stages most sensitive to the herbicide(s) used, and use spot rather than broadcast or aerial treatments.

• Use appropriate application equipment/method near water bodies if the potential for off-site drift exists.

• For treatment of aquatic vegetation, 1) treat only that portion of the aquatic system necessary to achieve acceptable vegetation management, 2) use the appropriate application method to minimize the potential for injury to desirable vegetation and aquatic organisms, and 3) follow water use restrictions presented on the herbicide label.

Wildlife • Use herbicides of low toxicity to wildlife, where feasible.

• Use spot applications or low-boom broadcast operations where possible to limit the probability

See manuals 6500 (Wildlife of contaminating non-target food and water sources, especially non-target vegetation over areas and Fisheries Management) larger than the treatment area.

and 6780 (Habitat Management Plans) • Use timing restrictions (e.g., do not treat during critical wildlife breeding or staging periods) to minimize impacts to wildlife.

Threatened, Endangered, and Sensitive Species

See Manual 6840 (Special Status Species)

• Survey for special status species before treating an area. Consider effects to special status species when designing herbicide treatment programs.

• Use a selective herbicide and a wick or backpack sprayer to minimize risks to special status plants.

• Avoid treating vegetation during time-sensitive periods (e.g., nesting and migration, sensitive life stages) for special status species in area to be treated.

Livestock

See Handbook H-4120-1 (Grazing Management)

• Whenever possible and whenever needed, schedule treatments when livestock are not present in the treatment area. Design treatments to take advantage of normal livestock grazing rest periods, when possible.

• As directed by the herbicide product label, remove livestock from treatment sites prior to herbicide application, where applicable.

• Use herbicides of low toxicity to livestock, where feasible.

• Take into account the different types of application equipment and methods, where possible, to reduce the probability of contamination of non-target food and water sources.

• Avoid use of diquat in riparian pasture while pasture is being used by livestock.

• Notify permittees of the herbicide treatment project to improve coordination and avoid potential conflicts and safety concerns during implementation of the treatment.

• Notify permittees of livestock grazing, feeding, or slaughter restrictions, if necessary.

• Provide alternative forage sites for livestock, if possible.

BLM Vegetation Treatments Using Herbicides B-11 September 2007

Wild Horses and Burros

• Minimize using herbicides in areas grazed by wild horses and burros.

• Use herbicides of low toxicity to wild horses and burros, where feasible.

• Remove wild horses and burros from identified treatment areas prior to herbicide application, in accordance with herbicide product label directions for livestock.

• Take into account the different types of application equipment and methods, where possible, to reduce the probability of contaminating non-target food and water sources.

Cultural Resources and Paleontological Resources

See handbooks H-8120-1 (Guidelines for Conducting Tribal Consultation) and H 8270-1 (General Procedural Guidance for Paleontological Resource Management), and manuals 8100 (The Foundations for Managing Cultural Resources), 8120 (Tribal Consultation Under

• Follow standard procedures for compliance with Section 106 of the National Historic Preservation Act as implemented through the Programmatic Agreement among the Bureau of Land Management, the Advisory Council on Historic Preservation, and the National Conference of State Historic Preservation Officers Regarding the Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act and state protocols or 36 Code of Federal Regulations Part 800, including necessary consultations with State Historic Preservation Officers and interested tribes.

Cultural Resource Authorities), • Follow BLM Handbook H-8270-1 (General Procedural Guidance for Paleontological and 8270 (Paleontological Resource Management) to determine known Condition I and Condition 2 paleontological areas, Resource Management) or collect information through inventory to establish Condition 1 and Condition 2 areas, determine resource types at risk from the proposed treatment, and develop appropriate See also: Programmatic measures to minimize or mitigate adverse impacts.

Agreement among the Bureau • Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that of Land Management, the might be affected by herbicide treatments.

Advisory Council on Historic Preservation, and the National • Work with tribes to minimize impacts to these resources.

Conference of State Historic • Follow guidance under Human Health and Safety in the PEIS in areas that may be visited by Preservation Officers Native peoples after treatments.

Regarding the Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act

Visual Resources

See handbooks H-8410-1 (Visual Resource Inventory) and H-8431-1 (Visual Resource Contrast Rating), and manual 8400 (Visual

• Minimize the use of broadcast foliar applications in sensitive watersheds to avoid creating large areas of browned vegetation.

• Consider the surrounding land use before assigning aerial spraying as an application method.

• Minimize off-site drift and mobility of herbicides (e.g., do not treat when winds exceed 10 mph; minimize treatment in areas where herbicide runoff is likely; establish appropriate buffer widths between treatment areas and residences) to contain visual changes to the intended treatment area.

• If the area is a Class I or II visual resource, ensure that the change to the characteristic landscape is low and does not attract attention (Class I), or if seen, does not attract the attention of the casual viewer (Class II).

Resource Management) • Lessen visual impacts by: 1) designing projects to blend in with topographic forms; 2) leaving some low-growing trees or planting some low-growing tree seedlings adjacent to the treatment area to screen short-term effects; and 3) revegetating the site following treatment.

• When restoring treated areas, design activities to repeat the form, line, color, and texture of the natural landscape character conditions to meet established Visual Resource Management (VRM) objectives.

BLM Vegetation Treatments Using Herbicides B-12 September 2007

Wilderness and Other Special Areas

See handbooks H-8550-1 (Management of Wilderness Study Areas (WSAs)), and H 8560-1 (Management of

• Encourage backcountry pack and saddle stock users to feed their livestock only weed-free feed for several days before entering a wilderness area.

• Encourage stock users to tie and/or hold stock in such a way as to minimize soil disturbance and loss of native vegetation.

• Revegetate disturbed sites with native species if there is no reasonable expectation of natural regeneration.

• Provide educational materials at trailheads and other wilderness entry points to educate the public on the need to prevent the spread of weeds.

• Use the “minimum tool” to treat noxious and invasive vegetation, relying primarily on the use of ground-based tools, including backpack pumps, hand sprayers, and pumps mounted on pack and saddle stock.

Designated Wilderness Study Areas), and Manual 8351 (Wild and Scenic Rivers)

• Use chemicals only when they are the minimum method necessary to control weeds that are spreading within the wilderness or threaten lands outside the wilderness.

• Give preference to herbicides that have the least impact on non-target species and the wilderness environment.

• Implement herbicide treatments during periods of low human use, where feasible.

• Address wilderness and special areas in management plans.

• Maintain adequate buffers for Wild and Scenic Rivers (¼ mile on either side of river, ½ mile in

Alaska).

Recreation

See Handbook H-1601-1 (Land Use Planning Handbook, Appendix C)

• Schedule treatments to avoid peak recreational use times, while taking into account the optimum management period for the targeted species.

• Notify the public of treatment methods, hazards, times, and nearby alternative recreation areas.

• Adhere to entry restrictions identified on the herbicide product label for public and worker access.

• Post signs noting exclusion areas and the duration of exclusion, if necessary.

• Use herbicides during periods of low human use, where feasible.

Social and Economic Values

• Consider surrounding land use before selecting aerial spraying as a method, and avoid aerial spraying near agricultural or densely-populated areas.

• Post treated areas and specify reentry or rest times, if appropriate.

• Notify grazing permittees of livestock feeding restrictions in treated areas, if necessary, as per herbicide product label instructions.

• Notify the public of the project to improve coordination and avoid potential conflicts and safety concerns during implementation of the treatment.

• Control public access until potential treatment hazards no longer exist, per herbicide product label instructions.

• Observe restricted entry intervals specified by the herbicide product label.

• Notify local emergency personnel of proposed treatments.

• Use spot applications or low-boom broadcast applications where possible to limit the probability of contaminating non-target food and water sources, especially vegetation over areas larger than the treatment area.

• Consult with Native American tribes and Alaska Native groups to locate any areas of vegetation that are of significance to the tribes and Native groups and that might be affected by herbicide treatments.

• To the degree possible within the law, hire local contractors and workers to assist with herbicide application projects and purchase materials and supplies, including chemicals, for herbicide treatment projects through local suppliers.

• To minimize fears based on lack of information, provide public educational information on the need for vegetation treatments and the use of herbicides in an integrated pest management program for projects proposing local use of herbicides.

BLM Vegetation Treatments Using Herbicides B-13 September 2007

Rights-of-way

• Coordinate vegetation management activities where joint or multiple use of a ROW exists.

• Notify other public land users within or adjacent to the ROW proposed for treatment.

• Use only herbicides that are approved for use in ROW areas.

Human Health and Safety

• Establish a buffer between treatment areas and human residences based on guidance given in the HHRA, with a minimum buffer of ¼ mile for aerial applications and 100 feet for ground applications, unless a written waiver is granted.

• Use protective equipment as directed by the herbicide product label.

• Post treated areas with appropriate signs at common public access areas.

• Observe restricted entry intervals specified by the herbicide product label.

• Provide public notification in newspapers or other media where the potential exists for public exposure.

• Have a copy of MSDSs at work site.

• Notify local emergency personnel of proposed treatments.

• Contain and clean up spills and request help as needed.

• Secure containers during transport.

• Follow label directions for use and storage.

• Dispose of unwanted herbicides promptly and correctly.

BLM Vegetation Treatments Using Herbicides B-14 September 2007