Attachment_4_Standard_Operating_Procedures_and_Mitigation_Measures.docx

Standard Operating Procedures and Mitigation Measures In the following section, Standard Operating Procedures applicable to non-herbicide treatments are listed first under each resource, followed by the Standard Operating Procedures, Mitigation Measures, and Oregon FEIS Mitigation Measures applicable to herbicide applications.

Standard Operating Procedures have been identified to reduce adverse effects to environmental and human resources from vegetation treatment activities based on guidance in BLM manuals and handbooks, regulations, and standard BLM and industry practices. The list is not all encompassing, but is designed to give an overview of practices that would be considered when designing and implementing a vegetation treatment project on public lands (USDI 2007b:2-29). Effects described in this EA are predicated on application of the Standard Operating Procedures or equivalent, unless an on-site determination is made that their application is unnecessary to achieve their intended purpose or protection. For example, the Standard Operating Procedure to “use herbicides of low toxicity to wild horses and burros, where feasible” would not need to be applied to treatments where wild horses and burros are not expected to occur.

2007 PEIS Mitigation Measures (marked as MMs in the list below) were identified for all potential adverse effects identified for herbicide applications in the Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact Statement (USDI 2007a), and adopted by its Record of Decision. In other words, no potentially significant adverse effect identified in the 17 A-23 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices States analysis remained at the programmatic scale after the PEIS Mitigation Measures were adopted. Like the Standard Operating Procedures, application of the Mitigation Measures is assumed in the analysis in this EA, and on-site determinations would decide if their application is unnecessary to achieve the intended purpose or protection.

2016 PEIS Mitigation Measures (marked as 2016 MMs in the list below) were identified for all potential adverse effects identified for herbicide use in the Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron PEIS (USDI 2016a), and adopted by its Record of Decision. In other words, no potentially significant adverse effect identified in the analysis remained at the programmatic scale after the PEIS Mitigation Measures were adopted. Like the Standard Operating Procedures, application of the Mitigation Measures is assumed in the analysis in this EA, and on-site determinations would decide if their application is unnecessary to achieve the intended purpose or protection.

Oregon FEIS Mitigation Measures (marked as Oregon FEIS MMs in the list below) were identified and adopted for adverse effects identified in the Final Vegetation Treatments Using Herbicides on BLM Lands in Oregon Environmental Impact Statement (Oregon Final EIS; BLM 2010a). Application of these measures is also assumed in the analysis in this EA unless on-site determinations are made that they are not needed, or there are alternative ways, to meet the intended purpose or protection. Again, no potentially significant adverse effect was identified at the programmatic scale in the Oregon FEIS with the Standard Operating Procedures and Mitigation Measures assumed.

Additional guidance, direction, orders, and protection measures can be found in numerous other BLM or Department of the Interior handbooks, manual, and management plans. Exclusion from this Appendix does not indicate that these additional measures are not also potentially applicable. BLM manuals and handbooks are available online.

Guidance Documents Fire Use BLM handbooks H-9211-1 (Fire Management Activity Planning Procedures) and H-9214-1 (Prescribed Fire Management), and manuals 1112 (Safety), 9210 (Fire Management), 9211 (Fire Planning), 9214 (Prescribed Fire), and 9215 (Fire Training and Qualifications).

Mechanical BLM Handbook H-5000-1 (Public Domain Forest Management), and manuals 1112 (Safety) and 9015 (Integrated Weed Management).

Manual BLM Domain Forest Management, and manuals 1112 (Safety), and 9015 (Integrated Weed Management).

Biological BLM manuals 1112 (Safety), 4100 (Grazing Administration), 9014 (Use of Biological Control Agents on Public Lands), and 9015 (Integrated Weed Management) and Handbook H-4400-1 (Rangeland Health Standards).

Chemical BLM Handbook H-9011-1 (Chemical Pest Control), and manuals 1112 (Safety), 9011 (Chemical Pest Control), 9015 (Integrated Weed Management), and 9220 (Integrated Pest Management).

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• Prepare fire management plan.

• Use trained personnel with adequate equipment.

• Minimize frequent burning in arid environments.

• Avoid burning herbicide-treated vegetation for at least 6 months.

Mechanical

• Ensure that power cutting tools have approved spark arresters.

• Ensure that crews have proper fire-suppression tools during the fire season.

• Wash vehicles and equipment before leaving weed infested areas to avoid infecting weed-free areas.

• Keep equipment in good operating condition.

Manual

• Ensure that crews have proper fire-suppression tools during fire season.

• Minimize soil disturbance, which may encourage new weeds to develop.

Biological

• Use only biological control agents that have been tested and approved to ensure they are host specific.

• If using domestic animals, select sites with weeds that are palatable and non-toxic to the animals.

• Manage the intensity and duration of containment by domestic animals to minimize overutilization of desirable plant species.

• Utilize domestic animals to contain the target species in the treatment areas prior to weed seed set.

Or if seed set has occurred, do not move the domestic animals to uninfested areas for a period of 7 days.

Chemical

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

• Conduct a pretreatment survey before applying herbicides.

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

• Select herbicide products carefully to minimize additional impacts from degradates, adjuvants, other 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 or certified applicators or State-licensed “trainees” apply herbicides, or they can be applied by BLM employees under the direct supervision of a BLM-certified applicator.

• 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 herbicide risks to the environment and provides practical ways to avoid harm to organisms or to the environment.

• 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, if appropriate.

• 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.

• Take precautions to minimize drift by not applying herbicides when winds exceed >10 mph 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 A-25 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices 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 application equipment 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 plant material.

The BLM has suspended the use of the adjuvant R-11.

Land Use Fire Use

• Carefully plan fires in the WUI to avoid or minimize loss of structures and property.

• Notify nearby residents and landowners who could be affected by smoke intrusions or other fire effects.

• Mechanical

• Collaborate on project development with nearby landowners and agencies. Manual

• Collaborate on project development with nearby landowners and agencies. Biological

• Notify nearby residents and landowners who could be affected by biological control agents.

Chemical

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

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

Air Quality Standard Operating Procedures for air quality are taken from BLM’s Soil, Water, and Air Management Manual (7000).

Fire Use

• Have clear smoke management objectives.

• Evaluate weather conditions, including wind speed and atmospheric stability, to predict effects of burn and impacts from smoke.

• Burn when weather conditions favor rapid combustion and dispersion.

• Burn under favorable moisture conditions.

• Use backfires, when applicable.

• Burn small vegetation blocks, when appropriate.

• Manage smoke to prevent air quality violations and minimize impacts to smoke-sensitive areas.

• Coordinate with air pollution and fire control officials, and obtain all applicable smoke management permits, to ensure that burn plans comply with federal, state, and local regulations.

Mechanical

• Maintain equipment in optimal working order.

• Conduct treatment activities during the wetter seasons.

• Use heavy equipment under adequate soil moisture conditions to minimize soil erosion.

• Minimize vehicle speeds on unpaved roads.

• Minimize dust impacts to the extent practicable.

Manual

• Maintain equipment in optimal working order.

• Conduct treatment activities during the wetter seasons.

• Minimize vehicle speeds on unpaved roads.

• Minimize dust impacts to the extent practicable.

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• 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 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 Resources Standard Operating Procedures for soil resources are taken from BLM’s Soil, Water, and Air Management Manual (7000).

General

• Assess the susceptibility of the treatment site to soil damage and erosion prior to treatment.

Fire Use

• Prescribe broadcast and other burns that are consistent with soil management activities.

• Plan burns so as to minimize damage to soil resources.

• Conduct burns when moisture content of large fuels, surface organic matter, and soil is high to limit the amount of heat penetration into lower soil surfaces and protect surface organic matter.

• Time treatments to encourage rapid recovery of vegetation.

• Further facilitate revegetation by seeding or planting following treatment.

• When appropriate, reseed following burning to re- introduce species, or to convert a site to a less flammable plant association, rather than to specifically minimize erosion.

Mechanical

• Time treatments to avoid intense rainstorms.

• Time treatments to encourage rapid recovery of vegetation.

• Further facilitate revegetation by seeding or planting following treatment.

• Use equipment that minimizes soil disturbance and compaction.

• Minimize use of heavy equipment on slopes >20%.

• Conduct treatments when the ground is sufficiently dry to support heavy equipment.

• Implement erosion control measures in areas where heavy equipment use occurs.

• Conduct mechanical treatments along topographic contours to minimize runoff and erosion.

• When appropriate, leave plant debris on site to retain moisture, supply nutrients, and reduce erosion.

• Prevent oil and gas spills to minimize damage to soil.

Manual

• Time treatments to avoid intense rainstorms.

• Time treatments to encourage rapid recovery of vegetation.

• Further facilitate revegetation by seeding or planting following treatment.

• Minimize soil disturbance and compaction.

Biological

• Minimize use of domestic animals if removal of vegetation may cause significant soil erosion or impact biological soil crusts.

• Closely monitor timing and intensity of biological control with domestic animals.

• Avoid grazing on wet soil to minimize compaction and shearing.

Chemical

• 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.

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• 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.

• To avoid the loss of finer-sized soil particles and avoid having herbicide-treated soils blown or washed off-site, avoid exposing large areas of wind-erosion group 1 or 2 soils when a combination of dry soil and seasonal winds are expected. Mitigation Measures could include the use of selective herbicides to retain some vegetation on site; reseeding so cover is present before the windy season affects dry soils; staggering treatment of strips until stubble regrows enough to provide an acceptable filter strip;

rescheduling treatments away from the windy season; or, other measures to prevent wind erosion on these soil groups. (Oregon FEIS MM) Water Resources Standard Operating Procedures for water resources are taken from BLM’s Soil, Water, and Air Management Manual (7000).

Fire Use

• Prescribe burns that are consistent with water management objectives.

• Plan burns to minimize negative impacts to water resources.

• Minimize burning on hillslopes, or revegetate hillslopes shortly after burning.

• Maintain a vegetated buffer between treatment areas and water bodies.

Mechanical

• Minimize removal of desirable vegetation near residential and domestic water sources.

• Do not wash equipment or vehicles in water bodies.

• Maintain minimum 25 foot wide vegetated buffer near streams and wetlands.

Manual

• Maintain vegetated buffer near residential and domestic water sources.

• Minimize removal of desirable vegetation near residential and domestic water sources.

• Minimize removal of desirable vegetation near water bodies.

• Minimize use of domestic animals near residential or domestic water sources.

• Minimize use of domestic animals adjacent to water bodies if trampling or other activities are likely to cause soil erosion or impact water quality.

Chemical

• 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 target aquatic 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.

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

• Establish appropriate (herbicide-specific) buffer zones for species / populations. (MM)

• Areas with potential for groundwater for domestic or municipal use shall be evaluated through the A-28 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices appropriate, validated model(s) to estimate vulnerability to potential groundwater contamination, and appropriate Mitigation Measures shall be developed if such an area requires the application of herbicides and cannot otherwise be treated with non-herbicide methods. (MM)

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

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

• To protect domestic water sources, no herbicide treatments should occur within 100 feet of a well or 200 feet of a spring or known diversion used as a domestic water source unless a written waiver is granted by the user or owner. (Oregon FEIS MM)

• Site-specific analyses for roadside treatments should specifically consider that drainage ditches and structures lead to streams and that normal buffer distances, herbicide selection, and treatment method selection may need to be changed accordingly, particularly where those ditches are connected to streams with Federally Listed or other Special Status species. (Oregon FEIS MM)

• Buffer intermittent stream channels when there is a prediction of rain (including thunderstorms) within 48 hours. (Oregon FEIS MM)

• Proposals to boom spray herbicides within 200 feet of streams that are within 1,000 feet upstream from a public water supply intake, or spot apply herbicides within 100 feet of streams that are within 500 feet upstream from a public water supply intake, will include coordination with the Oregon Department of Environmental Quality and the municipality to whom the intake belongs. (Oregon FEIS

MM)

Wetlands and Riparian Areas Fire Use

• Following treatment, reseed or replant with native vegetation if the native plant community cannot recover and occupy the site sufficiently.

Mechanical

• Manage riparian areas to provide adequate shade, sediment control, bank stability, and recruitment of wood into stream channels.

• Following treatment, reseed or replant with native vegetation if the native plant community cannot recover and occupy the site sufficiently.

Manual

• Following treatment, reseed or replant with native vegetation if the native plant community cannot recover and occupy the site sufficiently.

Biological

• Manage animals to prevent overgrazing and minimize damage to wetlands.

• Following treatment, reseed or replant with native vegetation if the native plant community cannot recover and occupy the site sufficiently.

Chemical

• 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 from water of 25 feet for vehicle, and 10 feet for hand spray applications.

• See mitigation for Water Resources and Vegetation. (MM) Vegetation Standard Operating Procedures for vegetation are taken from Handbook H-4410-1 (National Range Handbook), and manuals 5000 (Forest Management) and 9015 (Integrated Weed Management).

General A-29 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices

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

Fire Use

• Keep fires as small as possible to meet the treatment objectives.

• Conduct low intensity burns to minimize adverse impacts to large vegetation.

• Limit area cleared for fire breaks and clearings to reduce potential for weed infestations.

• Where appropriate, use mechanical treatments to prepare forests for the reintroduction of fire.

• Use plant stock or seed from the same seed zone and from sites of similar elevation when conducting revegetation activities.

Mechanical

• Power wash vehicles and equipment to prevent the introduction and spread of weed and exotic species.

• Remove damaged trees and treat woody residue to limit subsequent mortality by bark beetles.

• Use plant stock or seed from the same seed zone and from sites of similar elevation when conducting revegetation activities.

• Identify and implement any temporary domestic livestock grazing and / or supplemental feeding restrictions needed to enhance desirable vegetation recovery following treatment.

Manual

• Remove damaged trees and treat woody residue to limit subsequent mortality by bark beetles.

• Use plant stock or seed from the same seed zone and from sites of similar elevation when conducting revegetation activities.

Biological

• Use domestic animals at the time they are most likely to damage invasive species.

• Manage animals to prevent overgrazing and minimize damage to sensitive areas.

• 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, including the application of state or regional grazing administration guidelines, needed to maintain desirable vegetation on the treatment site.

• Use plant stock or seed from the same seed zone and from sites of similar elevation when conducting revegetation activities.

Chemical

• 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 plants for revegetation and restoration projects to compete with invasive plants until desired vegetation establishes.

• Minimize the use of terrestrial herbicides (especially sulfometuron methyl) in watersheds with downgradient ponds and streams if potential impacts to aquatic plants are identified. (MM)

• When necessary to protect Special Status plant species, implement all Conservation Measures for plants presented in the 2007 Vegetation Treatments on Bureau of Land Management Lands in 17 Western States and 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron Biological Assessments (see Conservation Measures later in this Appendix). (MM, 2016 MM)

• Establish appropriate (herbicide-specific) buffer zones (Tables A-1 and A-2 in Appendix A) around downstream water bodies, habitats, and species / populations of interest. Consult the Risk Assessments prepared for the PEIS for more specific information on appropriate buffer distances under different soil, moisture, vegetation, and application scenarios. (MM)

• Use Table A-4 in Appendix A to establish herbicide-specific buffer zones around downstream water bodies, and associated habitats and non-target plant species / populations of interest for aminopyralid, fluroxypyr, and rimsulfuron. Consult the Risk Assessments for more specific information on appropriate buffer distances under different soil, moisture, vegetation, and application scenarios. (2016 MM) A-30 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices Pollinators Chemical

• 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 and in their habitats.

Fish and Aquatic Organisms Standard Operating Procedures for fish and other aquatic organisms are taken from BLM Manuals, including Manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans) Fire Use

• Maintain vegetated buffers near fish-bearing streams to minimize soil erosion and soil runoff into streams.

• Minimize treatments near fish-bearing streams during periods when fish are in sensitive life stages (e.g., embryo).

Mechanical

• Minimize treatments adjacent to fish-bearing waters.

• Do not wash vehicles in streams or wetlands.

• Refuel and service equipment at least 100 feet from water bodies to reduce the chance for pollutants to enter water.

• Maintain adequate vegetated buffer between treatment area and water body to reduce the potential for sediments and other pollutants to enter the water body.

Manual

• Refuel and service equipment at least 100 feet from water bodies to reduce the chance for pollutants to enter water.

• Minimize removal of desirable vegetation near fish-bearing streams and wetlands. Biological

• Limit access of domestic animals to streams and other water bodies to minimize sediments entering water and potential for damage to fish habitat.

Chemical

• 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 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 meet vegetation management objectives, 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.

• Limit the use of terrestrial herbicides in watersheds with characteristics suitable for potential surface runoff that have fish-bearing streams during periods when fish are in life stages most sensitive to the herbicide(s) used. (MM) A-31 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices

• To protect Special Status fish and other aquatic organisms, implement all Conservation Measures for aquatic animals presented in the 2007 Vegetation Treatments on Bureau of Land Management Lands in 17 Western States and 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron Biological Assessments (see Conservation Measures later in this Appendix). (MM, 2016 MM)

• Establish appropriate herbicide-specific buffer zones for water bodies, habitats, or fish or other aquatic species of interest (Table A-1 in appendix A) and recommendations in individual Ecological Risk Assessments). (MM)

• At the local level, consider effects to Special Status fish and other aquatic organisms when designing treatment programs. (MM)

• Use of adjuvants with limited toxicity and low volumes is recommended for applications near aquatic habitats. (Oregon FEIS MM) Wildlife Resources Standard Operating Procedures for wildlife resources are taken from BLM Manuals, including Manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans) Fire Use

• Minimize treatments during nesting and other important periods for birds and other wildlife.

• Minimize treatments of important forage areas immediately prior to important use period(s), unless the burn is designed to stimulate forage growth.

Mechanical

• Minimize treatments during nesting and other important periods for birds and other wildlife.

• Retain wildlife trees and other unique habitat features where practical.

Manual

• Minimize treatments during nesting and other important periods for birds and other wildlife.

• Retain wildlife trees and other unique habitat features where practical.

• Biological.

• Minimize the use of livestock grazing as a vegetation control measure where and / or when it could impact nesting and / or other important periods for birds and other wildlife.

• Consider and minimize potential adverse impacts to wildlife habitat and minimize the use of livestock grazing as a vegetation control measure where it is likely to result in removal or physical damage to vegetation that provides a critical source of food or cover for wildlife.

Chemical

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

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

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

• To minimize risks to terrestrial wildlife, do not exceed the typical application rate for applications of dicamba, glyphosate, or triclopyr, where feasible. (MM)

• Minimize the size of application areas, where practical, when applying 2,4-D and Overdrive® to limit impacts to wildlife, particularly through contamination of food items. (MM)

• Where practical, limit glyphosate to spot applications in grazing land and wildlife habitat areas to avoid contamination of wildlife food items. (MM)

• Do not use the adjuvant R-11. (MM)

• To protect Special Status wildlife species, implement Conservation Measures for terrestrial animals presented in the 2007 Vegetation Treatments on Bureau of Land Management Lands in 17 Western States and 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron Biological A-32 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices Assessments (see Conservation Measures later in this Appendix). (MM, 2016 MM)

• Impacts to wildlife from herbicide applications can be reduced by treating habitat during times when the animals are not present or are not breeding, migrating or confined to localized areas (such as crucial winter range). (Oregon FEIS MM)

• When treating native plants in areas where herbivores are likely to congregate, choose herbicides with lower risks due to ingestion. This Mitigation Measure is applicable if large areas of the herbivores’ feeding range would be treated, either because the treatment areas are large or the feeding area for an individual animal is small. (Oregon FEIS MM)

• Where there is a potential for herbivore consumption of treated vegetation, apply dicamba, imazapyr, and metsulfuron methyl at the typical, rather than maximum, application rate to minimize risks. (Oregon

FEIS MM)

• Where possible, design native vegetation treatment areas to mimic natural disturbance mosaics.

Patchiness is usually beneficial to most wildlife, and patchiness is usually tolerated by species that prefer contiguous habitat. (Oregon FEIS MM)

• Use of adjuvants with limited toxicity and low volumes is recommended for applications near aquatic habitats. (Oregon FEIS MM)

• When conducting herbicide treatments in or near habitats used by special status and listed terrestrial arthropods, design treatments to avoid the use of fluroxypyr, where feasible. If pre-treatment surveys determine the presence of listed terrestrial arthropods, do not use fluroxypyr to treat vegetation. (2016

MM)

Threatened and Endangered Species Standard Operating Procedures for threatened and endangered species are taken from BLM Manual 6840 (Special Status Species) and Vegetation Treatments Using Herbicides on BLM Lands in 17 Western States Programmatic Biological Assessment.

Fire Use

• Survey for Special Status species of concern if project may impact federally- and state-listed species.

• Minimize direct impacts to species of concern, unless studies show that species will benefit from fire.

Mechanical

• Minimize use of ground- disturbing equipment near Special Status species of concern.

• Survey for species of concern if project could impact these species.

• Use temporary roads when long-term access is not required. Manual

• Survey for Special Status species of concern if project could impact these species.

Biological

• Survey for Special Status species of concern if project could impact these species.

Chemical

• Provide clearances for Special Status species before treating an area as required by Special Status Species Program policy. 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 Standard Operating Procedures for livestock are taken from BLM Handbooks H-4120-1 (Grazing Management) and H-4130 (Authorizing Grazing Use).

General

• Notify permittees of proposed treatments and identify any needed livestock grazing, feeding, or slaughter restrictions. Design treatments to take advantage of normal livestock grazing rest periods, A-33 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices when possible, and minimize impacts to livestock grazing permits.

• Provide alternative forage sites for livestock, if possible.

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

Chemical

• 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.

• Minimize potential risks to livestock by applying glyphosate or triclopyr at the typical application rate where feasible. (MM)

• Do not apply 2,4-D, dicamba, Overdrive®, picloram, or triclopyr across large application areas, where feasible, to limit impacts to livestock, particularly through contamination of food items.

(MM)

• Where feasible, limit glyphosate to spot applications in rangeland. (MM)

• Where there is a potential for livestock consumption of treated vegetation, apply dicamba, imazapyr, and metsulfuron methyl at the typical, rather than maximum, application rate to minimize risks to livestock. (Oregon FEIS MM) Wild Horses and Burros General

• Avoid critical periods and minimize impacts to critical habitat that could adversely affect wild horse or burro populations.

Fire Use

• Minimize potential hazards to horses and burros by ensuring adequate escape opportunities.

Chemical

• 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.

• Minimize potential risks to wild horses and burros by applying glyphosate and triclopyr at the typical application rate, where feasible, in areas associated with wild horse and burro use. (MM)

• Consider the size of the application area when making applications of 2,4-D, dicamba, Overdrive®, picloram, and triclopyr in order to reduce potential impacts to wild horses and burros. (MM)

• Apply herbicide label grazing restrictions for livestock to herbicide treatment areas that support populations of wild horses and burros. (MM)

• Where practical, limit glyphosate to spot applications in rangeland. (MM)

• Do not apply 2,4-D in HMAs during peak foaling season. (MM)

• Do not exceed the typical application rate of Overdrive® in HMAs during the peak foaling season in areas where foaling is known to take place. (MM)

• Where there is a potential for wild horse or burro consumption of treated vegetation, apply dicamba, imazapyr, and metsulfuron methyl at the typical, rather than maximum, application rate to minimize risks. (Oregon FEIS MM)

• Do not broadcast spray 2,4-D, clopyralid, diflufenzopyr + dicamba, glyphosate, picloram, or A-34 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices triclopyr where wild horses have unrestricted access to treated areas, or reduce risks to wild horses from these herbicides by herding wild horses out of treatment areas. (Oregon FEIS MM)

• To limit adverse effects to wild horses and burros, particularly through the contamination of food items, treatments should not exceed 15 percent of any Herd Management Area at any given time. (Oregon FEIS MM) Paleontological and Cultural Resources Standard Operating Procedures for paleontological and cultural resources are taken from BLM 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 Cultural Resource Authorities), and 8270 (Paleontological Resource Management). See also:

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 (1997) and the State Protocol between the Oregon-Washington State Director of the Bureau of Land Management (BLM) and The Oregon State Historic Preservation Officer (SHPO) regarding the manner in which the Bureau of Land Management will meet its responsibilities under the National Historic Preservation Act and the National Programmatic Agreement among the BLM, the Advisory Council on Historic Preservation, and The National Conference of State Historic Preservation Officers (USDI 2015).

General

• Follow standard procedures for compliance with Section 106 of the National Historic Preservation Act as implemented through the National Programmatic Agreement and state protocols or 36 CFR Part 800, including necessary consultations with the State Historic Preservation Officers and affected tribes.

• Follow BLM Handbook H-8270-1 to determine known Condition 1 and Condition 2 paleontological areas, 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 measures to minimize or mitigate adverse impacts.

• Identify opportunities to meet tribal cultural use plant objectives for projects on public lands.

Fire Use

• Identify cultural resource types at risk from fire use and design inventories that are sufficient to locate these resources. Provide measures to minimize impacts. Monitor significant paleontological and cultural resources for potential looting of materials where they have been exposed by fire.

Mechanical

• Identify cultural resource types at risk from mechanical treatments and design inventories that are sufficient to locate these resources. Provide measures to minimize impacts.

• Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that might be affected, adversely or beneficially, by mechanical treatments.

Manual

• Identify cultural resource types at risk from manual treatments and design inventories that are sufficient to locate these resources. Provide measures to minimize impacts.

• Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that might be affected, adversely or beneficially, by manual treatments.

Biological

• Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that might be affected, adversely or beneficially, by biological treatments.

A-35 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices Chemical

• Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that might be affected by herbicide treatments; work with tribes to minimize impacts to these resources.

• Follow guidance under Human Health and Safety in the PEIS in areas that may be visited by Native peoples after treatments.

• Do not exceed the typical application rate when applying 2,4-D and triclopyr in known traditional use areas. (MM) Visual Resources Standard Operating Procedures for visual resources are taken from BLM handbooks H-8410-1 (Visual Resource Inventory) and H-8431-1 (Visual Resource Contrast Rating), and Manual 8400 (Visual Resource Management).

General

• At areas such as visual overlooks, leave sufficient vegetation in place, where possible, to screen views of vegetation treatments.

• Design activities to repeat the form, line, color, and texture of the natural landscape character Fire Use

• Minimize use of fire in sensitive watersheds to reduce the creation of large areas of browned vegetation.

• Consider the surrounding land use before assigning fire as a treatment method. Avoid use of fire near agricultural or densely populated areas, where feasible.

• Lessen visual effects in Class I and Class II visual resource areas.

Mechanical

• Minimize dust drift, especially near recreational or other public use areas.

• Minimize loss of desirable vegetation near high public use areas.

• Minimize earthwork and locate away from prominent topographic features.

• Revegetate treated sites.

• Lessen visual effects in Class I and Class II visual resource areas.

Manual

• Minimize dust drift, especially near recreational or other public use areas.

• Minimize loss of desirable vegetation near high public use areas.

• Lessen visual effects in Class I and Class II visual resource areas.

Biological

• At areas such as visual overlooks, leave sufficient vegetation in place, where possible, to screen views of vegetation treatments.

• Lessen visual effects in Class I and Class II visual resource areas.

Chemical

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

• 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).

• 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 VRM objectives.

A-36 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices Wilderness and Other Special Areas Standard Operating Procedures for Designated Wilderness, Wilderness Study Areas, and Wild and Scenic Rivers are taken from BLM Manuals, including Manuals 6330 (Management of Wilderness Study Areas (WSAs)), 6340 (Management of Designated Wilderness Areas), and 8351 (Wild and Scenic Rivers).

General

• Encourage backcountry pack and saddle stock users to feed their livestock only weed-free feed for several days before entering a Wilderness Area, and to bring only weed-free hay and straw onto BLM lands.

• 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 least intrusive methods possible to achieve objectives, and use non-motorized equipment in Wilderness and off existing routes in Wilderness Study Areas, and where possible in other areas.

• Address Wilderness and special areas in management plans.

• Control of weed infestations shall be carried out in a manner compatible with the intent of Wild and Scenic River management objectives.

Fire Use

• Minimize soil-disturbing activities during fire control or prescribed fire activities.

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

• Maintain adequate buffers for Wild and Scenic Rivers.

Mechanical

• If mechanized equipment is required, use the minimum amount of equipment needed.

• Time the work for weekdays or off-season.

• Require shut down of work before evening if work is located near campsites.

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

• Maintain adequate buffers for Wild and Scenic Rivers.

Manual

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

• Maintain adequate buffers for Wild and Scenic Rivers.

Biological

• Maintain adequate buffers for Wild and Scenic Rivers.

Chemical

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

• Use herbicides only when they are the minimum treatment 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. Mitigation Measures that may apply to Wilderness and other special area resources are associated with human and ecological health and recreation (see Mitigation Measures for Vegetation, Fish and Aquatic Organisms, Wildlife Resources, Recreation, and Human Health). (MM) A-37 Integrated Invasive Plant Management Environmental Assessment – Klamath Falls #DOI-BLM-ORWA-L040-2017-0015-EA - Appendices Recreation Standard Operating Procedures for recreation are taken from BLM Handbook H-1601-1 (Land Use Planning Handbook).

General

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

Fire Use

• Control public access to potential burn areas.

• Schedule treatments to avoid peak recreational use times, unless treatments must be timed during peak times to maximize effectiveness.

Mechanical

• Control public access until potential treatment hazards no longer exist.

• Schedule treatments to avoid peak recreational use times, unless treatments must be timed during peak times to maximize effectiveness.

Manual

• Control public access until potential treatment hazards no longer exist.

• Schedule treatments to avoid peak recreational use times, unless treatments must be timed during peak times to maximize effectiveness.

Biological

• Control public access in areas with control agents to ensure that agents are effective.

• Schedule treatments to avoid peak recreational use times, unless treatments must be timed during peak times to maximize effectiveness.

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

Chemical

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

• 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.

• Mitigation Measures that may apply…