Appendix A1 Rest of EA _Invasive_Plant_Treatment_Project_EA.pdf

United States Department of Agriculture

Forest Service

December 2011

Environmental Assessment Invasive Plant Treatment Project

San Gabriel River Ranger District, Angeles National Forest and San Dimas Experimental Forest, Pacific Southwest Research Station Los Angeles and San Bernardino Counties, California

Portions of T1N, R8W, R9W, R10W, and R11W; T2N, R8W, R9W, R10W, and R11W;

and T3N, R8W, R9W, and R10W, SBM

For Information Contact: Marian Kadota Adaptive Management Services Enterprise Team

(805) 220-6388 http://www.fs.usda.gov/goto/angeles/projects

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.

Environmental Assessment Invasive Plant Treatment Project iii

Table of Contents Chapter 1 - Introduction

Chapter 2 - Alternatives, including the Proposed Action

Chapter 3 - Affected Environment and Environmental Consequences

Human Health and Safety Invasive Plants and Native Vegetation Special Status Plants Wildlife Soils and Hydrology Special Land Designations (Wilderness and Research Natural Areas) Recreation and Scenic Resources Consequences Relative to Significance

Chapter 4 – List of agencies and persons consulted

Interdisciplinary (ID) Team Members Federal, State, And Local Agencies

References

Appendix A - Summary of Public Comments During Scoping Appendix B - Additional Invasive Plant Information Appendix C - Potential Treatment Prescription Options Appendix D –Responses to Comments on Preliminary EA Appendix E –T&E Species Accounts

List of Figures Figure 1. Project Area Map Figure 2. Decision key for invasive plant treatments Figure 3. Map of known populations of invasive plant species densities Figure 4. Map showing potential vectors and pathways in and near project area

List of Tables

Table 1. List of high and moderate priority invasive plants Table 2. Summary of treatment methods proposed Table 3. Summary of range of and typical application rates for each herbicide proposed Table 4. Herbicides considered for use, including examples of trade names, and how they affect plants Table 5. Distances (in miles) and acres by branch name Table 6. Summary of maximum annual treatment by branch and species Table 7. Maximum annual treatment by branch and invasive plant species/type Table 8. Comparison of alternatives iv

Table 9. Summary of hazard indicators and toxicity categories for pesticides Table 10. Signal Word used for each acute toxicity category.37 Table 11. Rating of risk to human health and safety for each herbicide and adjuvants (in general) considered in alternative 1 Table 12. Approximate acres by vegetation type within project area Table 13. High and moderate priority invasive plant species that are known to occur within 75 feet of the project area Table 14. Highlighted specific toxicities to plants by herbicide Table 15. Herbicide Behavior in the Environment Table 16. Invasive plants known to occur in and near the project area. Cal-IPC inventory categories, CDFA ratings, and the San Gabriel River Ranger District (SGRRD) priority

Table 17. High and moderate priority species reproductive mechanisms that have been identified (Warner et al. 2003)

Table 18. Dispersal vectors for high and moderate priority invasive plants Table 19. Vegetation type high and moderate priority invasive plant species are known to occur in

CHAPTER 1 - INTRODUCTION

Background _____________________________________ Executive Order 13112 defines invasive plants as “non-native plants whose introduction does, or is likely to, cause economic or environmental harm or harm to human health” (http://ceq.hss.doe.gov/nepa/regs/eos/eo13112.html). Some invasive plants can change ecosystem processes such as hydrology, fire regimes, and soil chemistry. These invasive plants have a competitive advantage because they are no longer controlled by their natural predators, and can quickly spread out of control. They spread with no consideration for land ownership boundaries.

Furthermore, invasive plants that grow along stream channels can easily and often increase their infestation because their seeds, effortlessly, are capable of traveling downstream.

The purpose of this environmental assessment is to update and expand the original project’s purpose and need, project area, and approved activities. The San Gabriel River Ranger District (District) has been implementing an arundo (Arundo donax) eradication project since 1998. The District has been successful in controlling the expansion of the populations, but the invasive plant species has not been completely eradicated from the District and needs continued treatment. The original decision is over 10 years old.

This project covers the majority of the main drainages on the San Gabriel River Ranger District and San Dimas Experimental Forest (i.e., San Gabriel, Big and Little Dalton, San Dimas drainages). The project is located in portions of T1N, R8W, R9W, R10W, and R11W; T2N, R8W, R9W, R10W, and R11W; and T3N, R8W, R9W, and R10W, SBM in Los Angeles and San Bernardino Counties, California.

During the past 20 years invasive plant species have invaded and/or expanded in the San Gabriel, Big and Little Dalton, and/or San Dimas drainages, including but not limited to: tamarisk (Tamarix spp.), tree-of-heaven (Ailanthus altissima), castorbean (Ricinus communis), Spanish broom (Spartium junceum), fountain grass (Pennisetum sp.), eupatory (Ageratina adenophora), English ivy (Hedera helix), cape ivy (Delairea odorata), periwinkle (Vinca sp.), tree tobacco (Nicotiana glauca), Himalaya blackberry (rubus armeniacus) and gorse (Ulex europaeus). Additionally, there are still small populations of arundo remaining in these drainages.

Other invasive plant species are anticipated to invade and/or expand into these drainages. One of the reasons is due to existing populations nearby (e.g. yellow star thistle [Centaurea solstitialis], Euphorbia [Euphorbia sp.], Canada thistle [Cirsium arvense]).

If the invasive species are left unchecked, the ecosystems in these drainages will dramatically change.

Invasive plants create a host of adverse environmental effects, including displacement of native plants and reduction in habitat and forage for wildlife (including federally listed threatened and endangered, and Forest Service sensitive1 species); reduction in water quantity; potential reduction in soil productivity; and potential increase in the intensity and frequency of wildfires. After wildfires, non-native plant species typically re-establish more rapidly than native plants, suppressing the recovery of the native vegetation and allowing the invasive plants to expand their range. In addition, when wildfires occur too frequently (tamarisk and arundo-dominated communities experience higher fire frequencies than native riparian communities), some native vegetation loses the ability to recover, effectively converting high diversity native plant communities into low diversity non-native plant communities.

1 Forest Service sensitive species are those plant and animal species identified by the Regional Forester or which population vaibility is a concern (FSM 2670.5) http://ceq.hss.doe.gov/nepa/regs/eos/eo13112.html

The Angeles National Forest Land Management Plan (Forest Plan) states, “….some of the greatest threats to riparian and aquatic habitats are from the invasion of non-native plant species, particularly tamarisk, arundo, and cape ivy within the stream channels….” (Forest Plan, part 1, p. 41; USFS 2005).

The Federal Noxious Weed Act of 1974 (7 USC 214), Section 15, requires federal land management agencies to develop and establish a management program for control of undesirable plants that are classified under state or federal law as undesirable, noxious, harmful, injurious or poisonous on federal lands under the agency’s jurisdiction (7 USC 2814[a]). The Act also requires the federal land management agencies to enter into cooperative agreements to coordinate the management of undesirable plant species on federal lands where similar programs are being implemented on state and private lands in the same area (7 U.S.C. 2814[c]).

The Wyden Amendment (Public Law 105-277, Section 323 as amended by Public Law 109-54, Section 434) authorizes the Forest Service to enter into cooperative agreements to benefit resources within watersheds on National Forest System lands. Agreements may be with willing federal, tribal, state, and local governments, private and nonprofit entities, and landowners to conduct activities on public or private lands for the protection, restoration, and enhancement of fish and wildlife habitat and other resources; reduction of risk for natural disaster where public safety is threatened; or a combination of both.

Executive Order 13112 of February 3, 1999, Invasive Species, is intended to prevent the introduction of invasive species, provide for their control, and to minimize the economic, ecological, and human health impacts that invasive species cause. Agencies shall identify which actions could affect the status of invasive species; use an integrated weed management approach to managing invasive species; and not authorize, fund, or carry out actions that would likely cause or promote the introduction or spread of invasive species unless it can be shown the actions clearly outweigh the potential harm caused by invasive species.

The National Fire Plan 10-year Comprehensive Strategy Implementation Plan (USFS 2001) includes an action to eradicate or minimize the rate of spread of invasive species that negatively impact natural fire cycles and fire-adapted ecosystems.

Forest Service National Strategic Plan (USFS 2007a) includes objectives to reduce adverse impacts from invasive and native species, pests, and diseases, and restore and maintain healthy watersheds and diverse habitats.

The Forest Plan (USFS 2005) has goals to reverse the trend of increasing loss of natural resource values due to invasive species (Goal 2.1), retain a natural evolving character within wilderness (Goal 3.2), improve watershed conditions through cooperative management (Goal 5.1), improve riparian conditions (Goal 5.2), and provide ecological conditions to sustain viable populations of native and desired non-native species (Goal 6.2). The Forest Plan Weed Management Strategy (appendix M in the Forest Plan, part 3) includes coordinating with the Los Angeles Weed Management Area (WMA) to continue controlling and/or removing tree-of-heaven, tamarisk, and arundo in San Gabriel, Big and Little Dalton, and San Dimas canyons.

The desired conditions for the project area are to have structure, function, and composition of plant communities and wildlife habitat unimpaired by the presence of invasive non-native plants (Forest Plan, part 1, p. 32; USFS 2005); to have the watercourses functioning properly with riparian vegetation consisting primarily of native species, with minimal or no presence of invasive non-native plants (Forest Plan, part 1, p. 41; USFS 2005); and to reduce and control exotic species over time to restore healthy riparian systems (Forest Plan, part 2, pp. 42, 66; USFS 2005).

Purpose and Need for Action _______________________ Based on national, agency, and forest direction, the needs for this project are to:

• Eradicate, control, contain, and/or suppress2 existing invasive plant species in the San Gabriel, Big and Little Dalton, and San Dimas canyon drainages from the Forest boundary to their headwaters.

• Provide for aggressive treatment of new infestations of invasive plants (in terms of new areas and new species) to allow for rapid treatment and containment of small infestations before they become established.

• Focus on invasive plant species that are classified as undesirable, noxious, harmful, injurious, or poisonous, including but not limited to State listed high priority noxious weeds (such as arundo, tamarisk, and tree-of-heaven).

• Cooperate with state and county agencies and private landowners interested in managing invasive plants within the project area.

In meeting the needs for action, the following purposes (objectives) must be achieved:

• Improve riparian habitat, aquatic conditions, and the overall quality and quantity of water.

• Contain and/or eradicate highly flammable and fire-adapted invasive plant species (e.g.

arundo, tamarisk) that have the potential to increase fire severity and increase the frequency in occurrence of damaging wildfires in these drainages.

• Minimize adverse impacts from the project to populations of threatened, endangered, and/or Forest Service sensitive plant and wildlife species.

• Minimize adverse impacts to the native riparian vegetation within the project area.

• Provide for health and safety during implementation of the project to nearby residents, forest visitors, and project implementers.

Proposed Action _________________________________ The proposed action includes the eradication, control, containment, and/or suppression of existing and new infestations of invasive plant species that are undesirable, noxious, harmful, injurious, or poisonous, including but not limited to State listed high priority noxious weeds in the San Gabriel, Big and Little Dalton, and San Dimas canyon drainages from the Forest boundary to their headwaters.

The width of the project area would include these channels and average 100 to 350 feet from the edge of the high water mark (with a few areas that go beyond a quarter mile from the edge of the high water mark). Treatment areas would include non-National Forest System lands if the landowners/managers would like to enter into an agreement authorized under the Wyden Amendment.

The term for this project would be 15 years with the intent to review and, if needed, update the project, effects analysis, and possibly purpose and need after 15 years of implementation. In general, the proposed action would cap the maximum treatment of the invasive plant species populations and future expansions of these species to 200 miles and/or 4,100 acres annually, depending on funding and staffing. High priority for treatment would be: arundo (Arundo donax), tamarisk (Tamarix spp.)

and tree-of-heaven (Ailanthus altissima). Moderate priority invasive plants would be bigleaf periwinkle (Vinca major), cape-ivy (Delairea odorata), castorbean (Ricinus communis), crimson fountaingrass (Pennisetum setaceum), Eutopary (Ageratina adenophora), English ivy, Algerian ivy (Hedera sp.), fennel (Foeniculum vulgare), French broom (Genista monspessulana), gorse (Ulex europaeus), Himalaya blackberry (Rubus armeniacus), Italian ryegrass (Lolium multiflorum), pampas

2 Eradicate is to totally eliminate an invasive plant species from the project area; control is to reduce the infestation over time but some level of infestation may be acceptable; contain is to prevent the spread of the invasive plants beyond the perimeter of patches or infestations presently existing; and, suppress is to prevent seed production throughout the target patch and reduce the area coverage, preventing the invasive species from dominating the vegetation in the area where low levels may be acceptable.

grass (Cortaderia sp.), purple veldtgrass (Ehrharta calycina), Scotch broom (Cytisus scoparius), Spanish broom (Spartium junceum), spotted knapweed (Centaurea maculosa), tree tobacco (Nicotiana glauca) and yellow starthistle (Centaurea solstitialis).

The project incorporates an adaptive management strategy that allows the project to be modified based on invasive plant expansion, new infestations of invasive plants in the project area, and new and more effective treatment methods.

Prescriptions for treatment would follow integrated weed management (IWM) for each treatment site.

Proposed treatment methods include biological control (e.g. insects, pathogens), manual/mechanical, fire-wilting, and herbicide. Depending on the size of the treated material (invasive plants), additional treatment of this activity-generated material (biomass) could be required.

Monitoring and restoration are also key components to the proposed action. There would be two main types of monitoring: implementation monitoring and effectiveness monitoring. All monitoring would be similar to the information already compiled through Forest Service Activity Tracking System (FACTS) and National Resource Information System (NRIS) data collection. Monitoring is intended to compare baseline information with post treatment information, determine the effectiveness of treatment, and possibly provide adaptive management based on unanticipated effects, and monitor the restoration of treated sites. To ensure treated areas are not re-colonized with invasive plant species, restoration activities may be required. All surveys/monitoring would be documented in the project files.

No new permanent or temporary roads are being proposed with this action. Any access would be by foot or by vehicles using existing roads. Helicopters may be used for transportation in remote areas where access is difficult, including possibly the wilderness with the appropriate authorization.

A more detailed description of this proposal can be found in Chapter 2, Alternative 2 Proposed Action found in this document.

Decision Framework ______________________________ The San Gabriel River District Ranger and Manager for the Urban Ecosystems and Social Dynamics program for Pacific Southwest Research Station, Riverside Fire Lab (responsible official for San Dimas Experimental Forest) are the Responsible Officials for this project. The District Ranger and Program Manager will decide whether to approve the proposed action, approve a modification to the proposed action, or take no action on treating the vegetation related to this project at this time.

Public Involvement _______________________________ The project was listed in the Schedule of Proposed Actions (SOPA) on the Angeles National Forest internet webpage beginning on October 1, 2008 and every quarter since. Scoping and public notification were conducted to inform the public of the proposal and provide them an opportunity to raise any issues associated with this invasive plant treatment proposal. A scoping letter was mailed out to approximately 240 agencies, groups, and individuals on May 15, 2009, which included a summarized description of the proposed action. A legal notice informing the public of this project proposal (with a 30-day scoping period) was published May 15, 2009, in the Inland Valley Daily Bulletin. The detailed purpose and need and proposed action document, map, and scoping letter were included on the Forest websites under “Projects and Plans” starting May 15, 2009 (http://www.fs.fed.us/r5/angeles/projects/)3. This internet site was referred to in both the legal notice and scoping letter.

3 Website has changed since this date. It is now: http://www.fs.usda.gov/goto/angeles/projects http://www.fs.fed.us/r5/angeles/projects/

Additional requests for input were sent to Native American groups. On June 29, 2009, the Forest tribal relations program manager sent an e-mail to six Native American “traditionalists” to ensure they were notified of the project. In addition, letters from the Forest Supervisor, dated October 19, 2009, were mailed to potentially interested groups requesting the identification of specific areas still being used by Tribal members for plant harvesting or collecting or which have other significance that would merit special consideration during project design and implementation.

Using the comments from the public and internal resource specialists concerns (see Issues section in this Chapter, below), the interdisciplinary team recommended a list of issues to be addressed with the responsible officials’ agreement.

Issues __________________________________________ The Forest Service received and reviewed comments from five individuals/groups, both orally and in writing, during the scoping period (see the summary of comments in appendix A). The Forest also received a concern from the forest tribal relations program manager. The Forest analyzed these comments to determine what the issues were related to this project proposal. Issues are points of discussion, dispute, or debate about the environmental effects of proposed actions. Issues were separated into two groups: key or major issues, and those that are not. Key issues are defined as having a cause and effect relationship with the proposed action; are within the scope of the analysis;

have not been decided by law, regulation, or previous decision; and produce conflicts that cannot be resolved through mitigation. Issues that were not determined to be key issues were identified as those that are outside the scope of the purpose and need; already decided by law, regulation, Forest Plan, or other higher level decision; irrelevant to the decision to be made; conjectural and not supported by scientific or factual evidence; or could be resolved through mitigation. A list of issues and reasons regarding their categorization are noted in appendix A in this document.

The interdisciplinary team recommended and the responsible officials approved two key issues that would be addressed in the analysis:

1. Herbicides are highly toxic to humans, including carcinogenicity, reproductive and developmental toxicity, neurotoxicity, and acute toxicity. (Measurement indicator is the threshold of concern4 for each herbicide proposed. Threshold of concern for humans is expressed as reference dose [RfD]5).

2. Herbicides are highly toxic to aquatic organisms, mammals, and birds, including carcinogenicity, reproductive and developmental toxicity, neurotoxicity, and acute toxicity.

(Measurement indicators are the toxicity index6 for each herbicide proposed for each major wildlife category. Toxicity index is usually reported as no observable adverse effect level [NOAEL] but may be reported as lethal dose, 50 percent [LD507; or a portion thereof] when data are lacking).

In addition, this document addresses the effects from this project for the following resources: invasive plants, special status plant and animal species (i.e., species protected under the Endangered Species Act and Forest Service sensitive), hydrology, special land designation areas (i.e., wilderness and research natural areas), recreation, and scenic resources.

4 Threshold of concern is a level of exposure below which there is a low potential for adverse effects to humans.

5 Reference dose (RfD) is a numerical estimate of a daily exposure to the human population, including sensitive subgroups such as children, that is not likely to cause harmful effects during a lifetime.

6 The toxicity index is the dose of herbicide used to determine the potential for an adverse effect to wildlife. It is the lowest dose reported to cause the most sensitive effect in the greatest number of sensitive species tested.

7 LD50 is a standardized measure for expressing and comparing the toxicity of chemicals and is the dose that kills half (50%) of the animals tested.

CHAPTER 2 - ALTERNATIVES, INCLUDING THE

PROPOSED ACTION

This Chapter describes the alternatives considered to achieve the purpose and need discussed in Chapter 1 of this document. Alternative 1 is the no action; alternative 2 is the proposed action; and alternative 3 was developed in response to the issues identified during scoping and noted above (i.e., herbicide toxicity). In addition, design features (protection measures) are incorporated into the alternative descriptions and are included in this chapter. The intent of these measures is to decrease potential adverse effects to people and the environment. This chapter also acknowledges alternatives considered but eliminated from detailed analysis. A table at the end of this chapter presents the alternatives in comparative form, defining the differences between the three alternatives and providing a basis for choice among options by the decision makers and the public.

Alternatives _____________________________________ Alternative 1, No Action Under the no action alternative, none of the activities proposed from the action alternatives would be implemented. The no action alternative would not preclude invasive plant treatment activities from the project area at some time in the future. This alternative represents the existing condition and expected future conditions (in the absence of this project), against which the other alternatives are compared.

Alternative 2, Proposed Action (Adaptive Management Strategy – Herbicide Use) This alternative proposes the use of an adaptive management strategy, which includes early detection and rapid containment of invasive plants. Under this alternative prescription for treatments would follow an integrated weed management approach which includes the eradication, control, containment, and/or suppression of existing and new infestations of invasive plant species that are undesirable, noxious, harmful, injurious, or poisonous, including but not limited to State-listed high priority noxious weeds (such as arundo, tamarisk, and tree-of-heaven) in the San Gabriel, Big and Little Dalton, and San Dimas canyon drainages from the Forest boundary to their headwaters. The project is broken into 14 branches (see Figure 1 for a map of the project area and branch locations).

The width of the project area would include these channels and all tributaries and average 100 to 350 feet from the edge of the high water mark (with some areas that go beyond a quarter mile from the edge of the high water mark). Treatment areas would include non-National Forest System lands if the landowners/managers would like to enter into a cost-share agreement authorized under the Wyden Amendment. The project would be a long-term commitment for invasive plant management in the project area due to new species entering into the project area, re-colonization of treated species, and expansion of existing populations. The term of this project would be 15 years with the intent to review and, if needed, update the project, effects analysis, and possibly purpose and need after 15 years of implementation. These actions are being proposed by the Forest Service, the San Gabriel River District Ranger and Program Manager for the Urban Ecosystems and Social Dynamics program, Riverside Fire Lab. This alternative does not stop or remove previously approved decisions.

Figure 1. Project Area Map.

Adaptive Management Strategy Invasive plant infestations constantly change and evolve, as do the infestations of individual invasive plant species and treatment methods, including herbicide use (i.e., concentrations of herbicide and application methods). Early detection and rapid containment of invasive plants is the most efficient method for controlling their spread. A new project addressing these changes could take at least a year or more for a decision. The proposed action includes an adaptive management strategy that addresses these types of changes over the life of this project to allow for a rapid response for control and/or containment. New treatment methods (including change in concentrations or application methods of approved herbicides and/or biological control agents analyzed and approved for use by the US Department of Agriculture, Agricultural Plant Health and Insect Services), treatment of new species, and/or treatment of new areas within the project area would be part of the proposed action as long as the scope of the treatment and the effects are within those addressed in this document. Any new information would be reviewed by an appropriate interdisciplinary team; documented; and treatment approved by the appropriate Responsible Official through a letter to the files. Currently biological control agents are not in use within the project area and none is specifically proposed at this time. If one becomes available during the implementation period of this project, appropriate NEPA analysis would be conducted and consultation with US Fish and Wildlife Service and California Fish and Game would be initiated. The documentation would be included in the project record available for public review. This strategy would not allow for the use of new herbicides not addressed in this document; would not allow for “broadcast”8 (including aerial) applications of herbicides; would not allow herbicide use during pre-emergence of vegetation (preventing the invasive plant from germinating); and would not allow large and heavy equipment into the treatment areas (e.g. large bull dozers). The use of any new herbicides, broadcast applications, pre-emergent herbicide application, or use of large and heavy equipment would require new National Environmental Policy Act (NEPA) analyses, public involvement, documentation and decision. Figure 2 provides a decision key that incorporates the adaptive management strategy approach.

Decision Key

Step 1A Determine the best treatment method based on the invasive plant species present, consider the size of the infestation, and the location of the population. Determine the treatment strategy (eradicate, control, contain, or suppress). Can the treatment strategy be achieved using non-herbicide treatment methods (i.e., can the treatment strategy be manual and/or mechanical, such as a chainsaw, or should biological control be considered)?

Yes: Continue to Step 1B.

No: Continue to Step 2.

Step 1B Does the non-herbicide treatment method require some form of ground disturbance (e.g.

manual and/or mechanical)

Yes: Continue to Step 4.

No: Continue to Step 9.

Step 2 Have any conditions within the treatment area changed from what is described in this EA? Does the treatment area have an invasive species not specifically addressed in the EA? Is the proposed herbicide use (i.e., concentration or application method) different than what was proposed in the EA?

Yes: Continue to Step 3.

No: Continue to Step 6.

8 Broadcast spraying is defined as spraying via ground vehicles or aircraft with hose sprayers or booms using an array of spray nozzles. This method is not selective and all species, both native and non-native are sprayed.

Step 3 Is the herbicide treatment method analyzed in this EA (e.g. foliar herbicide application)?

Yes: Continue to Step 4.

No: Choose another treatment method OR conduct additional NEPA.

Step 4 Are there any unforeseen changed conditions (e.g. disturbance, new federal listing9 of an animal and/or plant species) from what was addressed in this EA)?

Yes: Conduct additional NEPA to address the area of change OR abandon treatment in that area.

No: Continue to Step 5A.

Step 5A Is the treatment site in a designated Wilderness Area?

Yes: Continue to Step 5B.

No: Continue to Step 6.

Step 5B If action is not taken, would the natural processes of the Wilderness Area be adversely affected?

Yes: Continue to Step 6.

No: Continue to Step 5C.

Step 5C Is there an imminent risk of invasive plants spreading outside the Wilderness Area?

Yes: Continue to Step 6.

No: Monitor invasive plant infestation.

Step 6 Are special status10 fish, wildlife or plant species, designated critical and essential fish habitat, or cultural resources present?

Yes: Use treatment methods that pose low to negligible risk to fish, wildlife, and plant species and cultural resources. Examples include use of selected herbicides (e.g. aquatic imazapyr, aquatic glyphosate or aquatic triclopyr), surfactants (e.g.

methylated seed oil concentrates), manual or mechanical treatments, in conjunction with the appropriate design features and/or mitigation measures that are part of the NEPA decision for this document. Continue to Step 8.

No: Continue to Step 7.

Step 7 Are additional surveys required for special status species?

Yes: Conduct necessary surveys during the appropriate time of year prior. Evaluate results of surveys. If surveys illustrate a risk to the species surveyed, use treatment methods that pose low or negligible risk to fish, wildlife, and/or plant species. Examples include use of selected herbicides (e.g. aquatic imazapyr, aquatic glyphosate or aquatic triclopyr), manual or mechanical treatments, in conjunction with the appropriate design features and/or mitigation measures that are part of the NEPA decision for this document. Continue to Step 8.

No: Continue to Step 8.

Step 8 Is this a heavy public-use area and an herbicide treatment method is proposed?

Yes: Use an herbicide that poses low to negligible risk to the public. Continue to Step

9.

No: Continue to Step 9.

Step 9 Is the proposed treatment within the maximum annual treatment acres for that branch?

Yes: Continue to Step 10.

No: Conduct additional NEPA on additional treatment areas OR abandon treatment for that year.

Step 10 Document treatment methods for each treatment area each year. If treatment is based on the adaptive management approach, prepare a document demonstrating how the change is within the scope of the NEPA decision for this document. Documentation would be a letter to the files and available for public review upon request.

Continue to Step 11.

9 Federal listed species is a threatened, endangered, proposed or candidate species protected under the Endangered Species Act.

10 Special Status is defined as federally listed threatened, endangered, proposed and candidate species, and Forest Service sensitive species.

Step 11 Implement invasive plant treatment and all the appropriate design features and/or mitigation measures that are part of the NEPA decision. Is active restoration necessary?

Yes: Implement appropriate restoration strategies as outlined in the proposed action.

Continue to Step 12.

No: Allow passive restoration to revegetate treatment site. Continue to Step 12.

Step 12 Implement monitoring framework as outlined in the proposed action. Are invasive plants present at the time the treatment area is monitored?

Yes: Continue to Step 1.

No: Continue to Step 13.

Step 13 Implement monitoring framework for restoration as outlined in the proposed action. Is the restoration strategy effective?

Yes: Healthy, native plant communities and function have been restored.

No: Continue to Step 11.

Figure 2. Decision key for invasive plant treatments.

Eradicate, Control, Contain, and/or Suppress Presently invasive plant species known to exist within the project area include a large variety of species. This alternative divides invasive plant species into three categories: high, moderate, and low-priority species. Table 1 provides a summary of the high and moderate priority species that presently exist within the project area. There are 45 known low-priority invasive plants that are also located within the project area and 15 additional low-priority species within 0.5 miles of the project area. A table showing the full list of known invasive plant species is in appendix B in this document. It is anticipated these species cover approximately 4,100 acres within the project area along 200 miles of channel. Many of these species are quick invaders to new areas, including arundo and tamarisk. It is anticipated even with early treatments, tamarisk and other invasive plants will continue to expand in the project area due to the proliferation of seed and seed dispersal by wind and water, or in the case of arundo, through rhizomes or stem segments. Expansion of invasive plants will vary depending on species, whether vectors are nearby (e.g. roads, trails, flowing water) and amount of existing disturbance. It is anticipated invasive plants in the project area would generally expand at a rate of approximately one to five percent annually but could easily range from one to 15 percent (Asher and Dewey 2005).

Table 1. List of high and moderate priority invasive plants.

Common name Taxon name

High Priority Invasive Plant Species

Arundo, Giant Reed Arundo donax

Saltcedar, Tamarisk Tamarix spp.

Tree of Heaven Ailanthus altissima

Moderate Priority Invasive Plant Species

Eupatory Ageratina adenophora

Spotted knapweed Centaurea maculosa

Pampas Grass Cortaderia spp.

Scotch Broom Cytisus scoparius

Cape-ivy, German-ivy Delairea odorata purple veldtgrass Ehrharta calycina

Fennel Foeniculum vulgare

EstherLewis Sticky Note target weeds, target invasives list

Common name Taxon name

Moderate Priority Invasive Plant Species

French broom Genista monspessulana

English Ivy, Algerian ivy Hedera helix, H. canariensis

Italian ryegrass Lolium multiflorum

Tree Tobacco Nicotiana glauca

Crimson Fountaingrass Pennisetum setaceum

Castorbean Ricinus communis

Himalayan Blackberry Rubus armeniacus (Rubus discolor)

Spanish Broom Spartium junceum

Gorse Ulex europaeas

Bigleaf Periwinkle Vinca major

Yellow starthistle* Centaurea solstitialis

*yellow starthistle is not known to occur within the project area but there is a record of it occurring approximately 0.5 miles away.

Most treatment strategies would be intended to eradicate or control the high-priority invasive plant species. Dependent on location, invasive plant species, and potential vectors in the area, the strategy to manage the moderate and low-priority invasive plant species would consider containing and/or suppressing.

Treatment Prescriptions Prescriptions for treatment would follow integrated weed management (IWM) for each treatment site.

No single management technique is perfect for all invasive plant treatment situations. Multiple management actions are required for effective treatment. Integrated weed management includes an approach for selecting methods for eradicating, containing, controlling, and/or suppressing invasive plants in coordination with other resource management activities to achieve optimum management goals and objectives. This approach uses a combination of treatment methods, that when taken together, would eradicate, contain, control, or suppress a particular invasive plant species or infestation efficiently and effectively, with minimum adverse impacts to non-target organisms. This approach contrasts with the traditional approach of using a single treatment type, such as applying herbicides, to treat all invasive plant problems. Herbicides are one useful technique, but they are not the only method to control invasive plants and may not always be the most effective. In addition, there are multiple herbicides that can treat a given invasive plant species. Integrated weed management is species-specific, tailored to exploit the weaknesses of a particular invasive plant species, site-specific, and designed to be practical with minimal risk to the organisms and their habitats (Colorado Natural Areas Program 2000).

Potential herbicide and manual/mechanical treatment prescription options for known and expected invasive plants are provided in appendix C.

Treatment Methods Proposed treatment methods include biological control (e.g. insects, pathogens), manual/mechanical, fire wilting, and herbicide. These treatment methods are divided up further into specific types of treatment methods and are summarized in table 2. The timing of herbicide treatments would be dependent on the invasive plant species, location of the population, temperature extremes, as well as wind and rain restrictions (which vary by herbicide). The Regional Forester must pre-approve any herbicide treatment in research natural and wilderness areas (FSH 2109.14, 13.4; USFS 1994a). This needed approval would occur before a decision is made on this project. In addition, should specific biological control agent(s) be considered as a viable treatment method, the Regional Forester must approve the biological control agent (e.g. insect) in either or both wilderness areas prior to implementation (FSM 2323.04c; USFS 2007b).

Depending on the size of the activity generated material (invasive plants), treatment of this material (biomass) could include pile and burning adjacent to or at the treatment site (at a minimum, outside the 25-year floodplain), drag and remove off site (if vehicle access is adjacent to treatment area), or helicopter sling load material out of the treatment area for disposal off site (e.g. if the access is poor and pile and burning in place is not an option). If the biomass material is minimal, the material could be scattered above the high waterline to dry and decompose. Sites where tamarisk plants receive herbicide treatment would not be burned, and treated plants would not be cut for two growing seasons after initial treatment because disturbing the treated plants can induce some to resprout.

The selection of treatment method would be dependent on time of year; severity of infestation;

presence of sensitive resource areas (e.g. native plants and wildlife species, including protected species); degree of intermixing of invasive species with sensitive native habitats; access; proximity to surface water; and budget.

Table 2. Summary of treatment methods proposed.

Method Description Biological Control Method

Biological Control Agents

Biological control agents are normally insects or pathogens that attack specific invasive plant species. Prior to allowing use, US Department of Agriculture, Agriculture Plan Health and Insect Service (APHIS) is required to complete NEPA analysis and documentation. The current website of approved biological control agents is http://www.aphis.usda.gov/plant_health/plant_pest_info/weeds/enviro_docs.shtml Use of this method would comply with the APHIS NEPA document and decision.

Advantages and disadvantages –suppresses the spread of infestations but would not likely eradicate the invasive plant populations. If successful, can provide permanent, widespread control with a favorable cost:benefit ratio. Can have unintended consequences when a new biological entity is introduced into a new area.

Manual/Mechanical Methods Hand Pulling

Pulling or uprooting plants can be effective against some shrubs, tree saplings, and herbaceous invasive plants. Annuals and tap-rooted plants are particularly susceptible to control by hand pulling. It is not as effective against many perennial invasive plants with deep underground stems and roots that are often left behind to resprout.

The advantages of pulling include its initial small ecological impact, minimal damage to neighboring plants, and little (or no) cost for equipment or supplies. Normally effective with small populations and/or where a large pool of volunteer labor is available. The key to effective hand pulling is to remove as much of the root as possible while minimizing soil disturbance. For many species, any root fragments left behind have the potential to re-sprout, and pulling is not effective on plants with deep and/or easily broken roots. Disadvantages are that this method is labor and time intensive. Often times there are low mortality rates, which require repeated re-treatments to be effective, which could increase the project cost and frequency of disturbance to the treatment area.

http://www.aphis.usda.gov/plant_health/plant_pest_info/weeds/enviro_docs.shtml

Method Description Manual/Mechanical Methods

Pulling Using Tools

Most plant-pulling tools are designed to grip the plant stem and provide the leverage necessary to pull its roots out. Tools vary in their size, weight, and the size of the invasive plant they can extract. The Root Talon is inexpensive and lightweight, but may not be durable or effective as the all-steel Weed Wrench, which is available in a variety of sizes.

Both work best on firm ground as opposed to soft, sandy, or muddy substrates and in small areas with easy access.

Advantages are initial small ecological impact and minimal damage to neighboring plants.

Normally effective with small populations and/or where a large pool of volunteer labor is available. Disadvantages include both tools can be cumbersome and difficult to carry to remote sites, this method can be labor and time intensive, often requires repeated re-treatments to be effective, which could increases the project cost and frequency of disturbance to the treatment area. Could spread invasive plants to other sites if equipment is not cleaned before leaving an infected site.

Clipping and Cutting

“Clipping and Cutting” requires cutting a portion of the invasive plant stem, generally cutting the bole of the tree/plant with cutting tools such as chainsaws, weed wacker/whip/eater.

Advantages and disadvantages are similar to the “pulling using tools” method as noted above. Another disadvantage is that many species can resprout from the base.

Girdling For trees (e.g. tamarisk), the main trunk of the trees would be stripped of the bark (consisting of secondary phloem tissue, cork cambium, and cork) around a tree’s outer circumference, causing its death. Death occurs from the inability of the leaves to transport sugars (primarily sucrose) to the roots.

Advantages to this treatment method are minimal ground disturbance and effective in killing larger sized trees. A disadvantage is that it takes time for the tree to die and during that time the tree can still produce seed. Another disadvantage is that some species can resprout from the base.

Tarping Invasive plants would be cut back within inches of the ground and opaque thick tarps or pond liners would be staked or weighed down over the treatment area. The tarp(s) would be applied in late spring/early summer and remain for up to 5 months, usually from June to November. This treatment is best used in small areas (less than 0.25 acres) where there is not an intermix of native plants.

Advantages to this treatment method are minimal ground disturbance and it has been known to be effective in small areas. Disadvantages are limited size of treatment area, could damage soil microorganisms, and high monitoring needs in high public use areas to ensure the tarp is left in place.

Fire-wilting Method Flaming Weed Torch

The weed torch is a treatment method that utilizes a propane torch to kill individuals but not ignite them This treatment is known as flaming, wilting, or blanching and the equipment can be carried by an indiviudal. The weed torch would only be used during times of low fire danger and in areas where there is low potential to carry fire. The most effective application is for the control of small diameter woody vegetation (one inch in diameter or less) such as French broom, other broom species and gorse, seedlings, and nonwoody grasses and forbs. To reduce potential for wildfire, ‘flaming’ is typically only undertaken when vegetation is very wet- either during or immediately after a rain event, or when vegetation is damp from fog and on low wind days (less than 5 mph is preferable).

An advantage to this form of treatment is that it has very minimal environmental impact. A disadvantage is the limited window of opportunity for treatment.

Herbicide Methods Hand/Selective Treatment of individual plants to avoid spraying other desirable plants. There is a low likelihood of drift or delivery of herbicides away from treatment sites. This method is used in sensitive areas, such as near water, to avoid getting any herbicide on the soil or in the water. Specific methods include:

a) Foliar Application (including basal bark) – These methods apply herbicide directly to the leaves and stems/trunk of a plant. An adjuvant or surfactant is often needed to enable the herbicide to penetrate the plant cuticle, a thick, waxy layer present on leaves and stems of most plants. These applicators range from backpack sprayer, to hand-pumped spray or squirt bottles, which can target very small plants or parts of plants.

http://en.wikipedia.org/wiki/Tree http://en.wikipedia.org/wiki/Death http://en.wikipedia.org/wiki/Leaf http://en.wikipedia.org/wiki/Sugar http://en.wikipedia.org/wiki/Sucrose http://en.wikipedia.org/wiki/Root

Method Description

b) Spot spraying – Spot spraying is similar to foliar spraying but would be for larger sized plants and/or population of plants. The focus still is on treating individual plants (instead of broadcast spraying) but over a larger area. Applicators would typically be backpack sprayers. Because of the potential to treat larger areas and larger sized vegetation, this method has a higher potential for drift.

c) Frill or Hack and Squirt – The frill method, also called the “hack and Squirt” treatment, is often used to treat woody species with large, thick trunks. The tree is cut using a sharp knife, saw, or ax, or drilled with a power drill or other device.

Herbicide is then immediately applied to the cut with a backpack sprayer, squirt bottle, syringe, or similar equipment.

d) Cut-Stump – This method is often used on woody species that normally resprout after being cut. Cut down the tree or shrub, and immediately spray or squirt herbicide on the exposed cambium (living inner bark) of the stump. The herbicide must be applied to the entire inner bark (cambium) within minutes after the trunk is cut. The outer bark and heartwood do not need to be treated since these tissues are not alive, although they support and protect the tree’s living tissues. The cut stump treatment allows for a great deal of control over the site of herbicide application; therefore, has a low probability of affecting non-target species or contaminating the environment. It also requires only a small amount of herbicide to be effective.

e) Cut, Resprout, and Spray or Paint/Daub – Cut 1-2 months prior to spraying. Apply herbicide when resprouts are 2-4 feet tall, but most effective in early fall through winter…