ATTACHMENT C Pesticide Discharge Management Plan and Integrated Pest Management Plan.pdf

U.S. Department of the Interior September 21, 2020

Pesticide Discharge Management Plan & Integrated Pest Management Plan

Navajo Dam Primary Jurisdiction Area - Years 2020-2025 Navajo Unit, NM Interior Region 7 – Upper Colorado Basin

ATTACHMENT C:

Mission Statements The Department of the Interior (DOI) conserves and manages the Nation’s natural resources and cultural heritage for the benefit and enjoyment of the American people, provides scientific and other information about natural resources and natural hazards to address societal challenges and create opportunities for the American people, and honors the Nation’s trust responsibilities or special commitments to American Indians, Alaska Natives, and affiliated island communities to help them prosper.

The mission of the Bureau of Reclamation is to manage, develop, and protect water and related resources in an environmentally and economically sound manner in the interest of the American public.

Pesticide Discharge Management Plan & Integrated Pest Management Plan

Navajo Dam Primary Jurisdiction Area Years 2020-2025

Navajo Unit, NM Interior Region 7 – Upper Colorado Basin Western Colorado Area Office prepared by Shannon Hatch, Biological Science Technician

Cover Photo: Navajo Dam (Reclamation) iii

Contents

Page 1 Operator Information

1.1 Purpose and Background

1.2 Pest Management Area

Background Navajo Dam

Excluded Areas

1.3 Description of Management Areas

1.3.1 Lacustrine and Riverine Waters

1.3.2 Palustrine Wetlands

1.3.3 Wildlife Habitat

1.3.4 Critical Habitat and Natural Areas

1.3.5 Recreation Areas

1.4 Pesticide Use Patterns

1.5 Operator Type

2 Pest Management Team Members and Contacts

2.1 Decision Makers

2.2 Contact

2.3 Preparer

2.4 Additional Team Members and Responsibilities

3 Pest Problem Identification

3.1 Targeted Pests

3.1.1 Terrestrial Plants & Algae

3.1.2 Animals

3.2 Action Thresholds

3.2.1 Aquatic Plant Species

3.2.2 Terrestrial Plant Species

3.2.3 Animal Pest Species

3.3 General Location Map

3.4 Water Quality Standards

3.4.1 Summary of Tier 3 Waters and Waters Impaired for Pesticides 4 Pest Management Option Evaluation

4.1 Pest Management Strategy

4.1.1 Prevention

4.1.2 Early Detection and Rapid Response

4.1.3 Control and Management

4.1.4 Restoration

4.2 Pest Management Techniques

4.2.1 Cultural

4.2.2 Mechanical

4.2.3 Biological

4.2.4 Chemical

4.2.5 Integrated Control Methods

4.3 Targeted Pest Management Assessment

iv

4.3.1 Aquatic Vegetation

4.3.2 Terrestrial Plant Species

4.3.3 Animal Pest Species

4.4 Technology-Based Effluent Limitations

5 Response Procedures

5.1 Spill Response Procedures

5.1.1 Spill Containment

5.1.2 Emergency or Medical Services Information

5.1.3 Spill Notification

5.2 Adverse Incident Response Procedures

5.2.1 Responding to an Adverse Incident

5.2.2 Notification of an Adverse Incident

6 Documentation to Support Eligibility Considerations under Other Federal Laws

6.1 Monitoring, Documentation and Evaluation

6.2 Threatened, Endangered, Species of Concern, and Environmental

Commitments 7 Signature Requirements 8 Plan Modifications 9 Plan Availability Attachments

1 Operator Information

1.1 Purpose and Background

The U.S. Department of the Interior (Department), Bureau of Reclamation (Reclamation) is responsible for the identification and proper management of pests on Reclamation lands and at Reclamation-owned facilities in accordance with the national policies set out in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Federal Noxious Weed Act, Carlson-Foley Act, Halogeton Glomeratus Control Act (66 Stat. 579), Clean Water Act (CWA), and applicable State and local laws and standards. This responsibility is to be fully considered in the development of a local Integrated Pest Management (IPM) Plan and Pesticide Discharge Management Plan

(PDMP).

The use of the herbicides in this plan were previously analyzed under National Environmental Policy Act (NEPA) by the Bureau of Land Management (BLM) in the following documents:

Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact Statement (PEIS) and related Record of Decision, which made 18 herbicides available for a full range of vegetation treatments in 17 western; and in the Record of Decision for the Final Programmatic Environmental Impact Statement National Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron (Final PEIS) on BLM Lands, which added an additional 3 herbicides.

The goal of IPM is to manage pests and the environment to balance costs, benefits, public health, and environmental quality. IPM is a process for determining if pest management is needed; when management should be initiated; at what frequency treatments should be applied; what physical, cultural, biological, or chemical strategies should be employed; and the effect of the treatment.

The goal of the PDMP is to document how effluent limitations are to be achieved. This includes a description of the pest management area and the pest problem, the process by which pest management options are evaluated and pesticide discharges are minimized, and the measures taken to prevent spills, leaks, and misapplications.

This document also serves to meet compliance with Department Manual Section 609 Chapter 1 – June 26, 1995. Under this mandate, it is Department policy to control undesirable plants on the lands, waters, and facilities under its jurisdiction, to the extent economically practicable and as needed for resource/environmental protection and enhancement, as well as accomplishment of resource management objectives and protection of human health. In addition, the State of New Mexico and most New Mexico counties have laws, regulations, and policies addressing the control and management of noxious, nuisance and pest species.

The two primary purposes for pest species control at the various Reclamation facilities are: 1) safety of dams and related structures, and 2) noxious and/or nuisance pest control around public facilities and Operations and Maintenance (O&M) facilities. Certain pests, primarily woody vegetation, must be controlled where species roots have the potential to cause or contribute toward structural problems on dams and related structures. Noxious and nuisance weeds have the potential to create fire hazards, preclude desirable vegetation, displace native plants and wildlife, increase maintenance costs, detract from aesthetics, and cause a variety of other problems.

The plan follows the adaptive management approach. First, pest species are identified through inventory of the property and by gathering information from other sources. Second, Reclamation’s goals and management objectives are established and recorded for the properties. Third, priorities are assigned to the pest species and areas based on the severity of their impacts, while considering the ability to control them. Fourth, methods are considered for controlling them or otherwise diminishing their impacts and, if necessary, re-order priorities based on likely impacts on target and non-target species. Fifth, control methods are implemented. Sixth, the results of management actions are monitored and evaluated considering pest management objectives for the management area. Finally, this information is used to modify and improve future pest management objectives, control priorities, and plans, thereby starting the cycle again.

The premise behind this combined IPM/PDMP plan is that a structured, logical approach to pest management, based on the best available information, is cheaper and more effective than an ad-hoc approach where one deals with pest problems as they arise.

1.2 Pest Management Area

This IPM & PDMP includes all the lands, water, and facilities managed by Reclamation in the Navajo Dam Unit’s Primary Jurisdiction Area (PJA) in northwest New Mexico. Reclamation is responsible for operation and maintenance in the PJA area of Navajo Dam. The state of New Mexico does not have National Pollutant Discharge Elimination System (NPDES) delegation authority for Federal facilities. The Environmental Protection Agency (EPA) is responsible for implementing the water pollution control program for these facilities.

Background The Western Colorado Area Office (WCAO) in Durango, CO has primary responsibility for managing reservoir operation and maintenance facilities within the PJA. This plan includes only this water project located within the state of New Mexico. The reservoir associated with this project provides benefits for water storage, flood control, municipal and industrial use, hydropower, recreation, fish and wildlife and irrigation purposes.

Navajo Dam Navajo Dam is located about 34 miles east of Farmington, New Mexico. Navajo Reservoir has a surface area of 15,610 acres, is approximately 35 miles long, and includes over 150 miles of shoreline. The reservoir provides important recreation and fish and wildlife benefits; however, its primary purposes are for flood control and to provide irrigation water for the Navajo Indian Irrigation Project (NIIP).

Excluded Areas Areas excluded from this document are those areas outside of the PJA designated boundary, except for the “boneyard” area, as identified on the attached map.

1.3 Description of Management Areas

The following areas are of particular interest in implementing a pest management plan, especially concerning the selection and use of chemical control measures.

1.3.1 Lacustrine and Riverine Waters

Includes waters flowing into a reservoir, the reservoir itself, and outflows released from the reservoir. Lacustrine and riverine are terms defined in Classification of Wetlands and Deepwater Habitats of the United States (Cowardin et al., 1979). These waters may provide habitat for fish and other aquatic organisms and may be a source of water for wildlife, livestock, irrigation, recreation, municipal water supplies and many other downstream uses. This category also includes Reclamation facilities and lands that are part of an irrigation distribution system.

1.3.2 Palustrine Wetlands

Isolated wetlands located about the flood pool elevation, including all non-tidal wetlands (Cowardin et al., 1979).

1.3.3 Wildlife Habitat

Wildlife habitat is considered the native and planted woodlands, grasslands, and riparian areas that provides habitat for a diversity of wildlife species and plants.

1.3.4 Critical Habitat and Natural Areas

Critical habitats are those areas that are designated by the U.S. Fish and Wildlife Service (USFWS) or National Marine Fisheries Service (NMFS) as areas with features that are essential for the conservation of endangered and threatened species. These areas may require special management considerations, protection, or avoidance. While there is no critical habitat or designated natural areas within the PJA, Reclamation considered these areas as they are downstream and could potentially be impacted by IPM methods used within the PJA.

1.3.5 Recreation Areas

Picnic areas, campgrounds, special use areas, and areas adjacent to residential areas require additional care and timing to avoid incidental pesticide exposure to the public. While there are no recreation areas within the PJA, Reclamation considered these areas as they are downstream and could potentially be impacted by IPM methods used within the PJA.

1.4 Pesticide Use Patterns

Pest management activities within the following “pesticide use patterns” will be described in further detail in Section 3 of this plan.

Mosquitoes and other flying insect pests – activities to control public health/nuisance and other flying insect pests that develops or is present during a portion of their life cycle in or above standing or flowering water. Public health/nuisance and other flying insect pests in this use category include mosquitoes and black flies.

Weeds and algae – activities to control weeds, algae, and pathogens that are pests in water and at water’s edge, including ditches and/or canals.

Animal pests – activities to control animal pests in water and at water’s edge. Animal pests in this use category include fish, insects, mollusks, crustaceans, and pathogens.

Reclamation is required to submit a Notice of Intent (NOI) for any pest management activities anticipated to be performed under the pesticide use patterns mentioned above. An NOI provides notice to the Environmental Protection Agency (EPA) that a Decision-maker intends to discharge to Waters of the United States from pesticide application activities eligible for coverage under the “Pesticide General Permit (PGP) for Discharges from the Application of Pesticides.”

1.5 Operator Type

Reclamation has prepared this document as a Federal Government “Operator.” The term “Operator,” as defined in the PGP, refers to any entity associated with the application of pesticides which results in a discharge to Waters of the United States that meets either of the following two criteria: (i) any entity who performs the application of a pesticide or who has day-to-day control over the application (Applicator), or (ii) any entity with control over the decision to perform pesticide applications including the ability to modify those decisions (Decision-maker). Reclamation operates in both the Applicator and Decision-maker roles.

2 Pest Management Team Members and Contacts

2.1 Decision Makers

Organization Name: U. S. Bureau of Reclamation, Western Colorado Area Office Name: Ed Warner, Western Colorado Area Manager Address: 185 Suttle Street, Suite 2 City, State, Zip Code: Durango, CO 81303 Telephone Number: 970-248-0654 E-mail Address: lwarner@usbr.gov

Organization Name: U. S. Bureau of Reclamation, Western Colorado Area Office Name: Jerry Tensfield, Equipment Operator & Public Applicator Address: Navajo Dam, 1281 Hwy 511 City, State, Zip Code: Navajo Dam, NM 87419 Telephone Number: 505-632-3115 E-mail Address: jtensfield@usbr.gov

2.2 Contact

Organization Name: U.S. Bureau of Reclamation, Western Colorado Area Office Name: Melissa Werkmeister, Northern Lands & Recreation Group Chief Address: 445 West Gunnison Ave., Suite 221 City, State, Zip Code: Grand Junction, CO 81501-5711 Telephone Number: 970-248-0636 E-Mail Address: mwerkmeister@usbr.gov

2.3 Preparer

Organization Name: U.S. Bureau of Reclamation Name: Shannon Hatch, Lands & Recreation Group, Biological Science Technician Address: 185 Suttle Street, Suite 2 City, State, Zip Code: Durango, CO 81303 Telephone Number; 970-385-6573 E-mail: shatch@usbr.gov

2.4 Additional Team Members and Responsibilities

Table 2.1. Additional Team Members & Responsibilities Responsibilities Name Agency Title Phone Implement

IPM*

Strategies

Develop Revise

PDMP

Develop, revise, & implement corrective actions & other effluent limitation requirements

Scott Branham USBR Maintenance Supervisor

505.632.3115 X

Jerry Tensfield USBR Equipment Operator

505.632.3115 X

Melissa Werkmeister

USBR Lands & Recreation Group Chief

970.248.0636

X

*Integrated Pest Management

3 Pest Problem Identification

3.1 Targeted Pests

It is Reclamation policy to control undesirable plant and animal species on the lands, waters, or facilities under its jurisdiction, to the extent economically practicable and as needed for resource/environmental protection and enhancement, as well as the accomplishment of resource management objectives and the protection of human health and safety. Actions will be taken only when careful consideration indicates leaving the pest unchecked would result in more damage than controlling it with best available methods.

The pest problem at the Navajo Dam PJA includes both vegetation and animals, to include: 1) all noxious and invasive weeds growing within Reclamation’s PJA and within the headquarters’ boneyard area (outside of the PJA), particularly along access roads, around parking areas, and near structures and buildings; 2) undesirable vegetation growing around fences, roads, buildings, and structures; 3) burrowing animals that threaten the integrity of structures; and 4) rodents invading facilities.

3.1.1 Terrestrial Plants & Algae

A goal of Reclamation is to control invasive plants and algae per New Mexico state law. Table 3.1 lists weeds that have been identified by the state of New Mexico as part of its noxious weed control program. If any of these species are found growing within the pest management area, they could be a potential problem and the species should be evaluated for control. Many terrestrial pest species are aggressive and can adapt to a wide range of habitats. These plants can be a nuisance to turbines and pumps and can also displace desirable plant communities. Likewise, aquatic plant species can impact conveyance systems by restricting water flows for municipal, industrial, agricultural, recreation, and wildlife uses. Aquatic pest species can also restrict flows in canals which are used for power generation. In addition, these pests can impart unpleasant taste and odor to drinking water, increase the biological oxygen demand which depletes oxygen available to other plant and animal species, and potentially promote habitat where disease carrying vectors can breed.

Priorities are set to reduce or eradicate noxious weeds that have already become established on the property, according to their actual and potential impacts on the management goals for the property, and according to the ability to control them now versus later. Priority noxious terrestrial plants within the Navajo Dam PJA include the following:

Bull thistle (Cirsium vulgare) Canada thistle (Cirsium arvense) Cheatgrass (Bromus tectorum)

Musk thistle (Carduus nutans) Russian olive (Elaeagnus angustifolia) Tamarisk or salt cedar (Tamarisk spp.)

Other invasive plants that may also be present, or have the potential to exist near the PJA include:

Hoary cress or whitetop (Cardaria spp.)

Perennial pepperweed (Lepidium latifolium)

Russian knapweed (Acroptilon repens) Yellow toadflax (Linaria vulgaris)

Attachment J provides species specific pest management approaches for these species.

In addition to the state listed species, non-noxious broadleaf weeds are also controlled in the project area, including:

Blue mustard (Chorispora tenella) Burdock (Arctium minus) Common purslane (Portulaca oleracea) Common sunflower (Helianthus annuus) Curly dock (Rumex crispus) Dandelion (Taraxacum officinale) Field bindweed (Convolvulus arvensis) Flixweed (Descurainia sophia) Horseweed (Conyza canadensis) Kochia (Kochia scoparia) Lambsquarter (Chenopodium species) Marsh sowthistle (Sonchus arvensis) Prickly lettuce (Lactuca serriola)

Puncturevine (Tribulus terrestris) Ragweed (Ambrosia spp.)

Redroot pigweed (Amaranthus retroflexus) Russian thistle (Salsola kali) Spotted spurge (Euphorbia maculata) Tansy mustard (Descurainia pinnata) Tumble mustard (Sisymbrium altissimum) Tumble pigweed (Amaranthus albus) Western salsify (Tragopogon dubius) Yellow sweetclover (Melilotus officinalis)

All woody vegetation growing in and along reservoirs and dam infrastructure such as canals and ditches or intruding into pavement affecting Reclamation facilities are part of the pest problem. In addition to controlling invasive woody species, including Russian olive and tamarisk, native plant species, including willow (Salix spp.) and rabbitbrush (Chrysothamnus spp.) should also be removed when impeding dam infrastructure.

Aquatic plants growing along the San Juan River shorelines downstream from the dam, and in canals and ditches, may be targeted for control. These aquatic nuisance plants may include:

American pondweed (Potamogeton nodosus) Blue green algae (cyanobacteria) Cattail (Typha sp.)

Common waterweed (Elodea canadensis) Curly-leaf pondweed (Potamogeton crispus) Eurasian watermilfoil (Myriophyllum spicatum) Northern watermilfoil (Myriophyllum sibiricum) Parrotfeather (Myriophyllum aquaticum) Sago pondweed (Potamogeton pectinatus)

Both Eurasian water milfoil and parrotfeather are on the New Mexico noxious weed list.

Attachment J provides species specific pest management approaches for these species.

Table 3.1: Invasive and Noxious Weeds in New Mexico The following table lists all Class A, B, C and Watch List weeds according to the state of New Mexico list, updated September 2016. High priority weeds for control within Navajo Dam PJA are indicated by an *.

Class A Species – Class A species are currently not present in New Mexico or have limited distribution.

Preventing new infestations of these species and eradicating existing infestations is the highest priority.

Common Name Scientific Name Alfombrilla Drymaria arenariodes Black henbane Hyoscyamus niger Brazillian egeria Egeria densa Camelthorn Alhagi psuedalhagi *Canada thistle Cirsium arvense Dalmation toadflax Linaria dalmatica Diffuse knapweed Centaurea diffusa Dyer’s woad Isatis tinctoria Giant salvinia Salvinia molesta *Hoary cress (whitetop) Cardaria spp.

Leafy spurge Euphorbia esula Oxeye daisy Leucanthemum vulgare Purple loosestrife Lythrum salicaria Purple starthistle Centaurea calcitrapa Ravenna grass Saccharum ravennae Scentless chamomile Matricaria perforata Scotch thistle Onopordum acanthium Spotted knapweed Centaurea maculosa Yellow starthistle Centaurea solstitialis *Yellow toadflax Linaria vulgaris Class B Species – Class B are limited to portions of the state. In areas with severe infestations, management should be designed to contain the infestation and stop any further spread.

Common Name Scientific Name African rue Peganum harmala *Bull thistle Cirsium vulgare Chicory Cichorium intybus Halogeton Halogeton glomeratus Malta starthistle Centaurea melitensis *Perennial pepperweed Lepidium latifolium Poison hemlock Conium maculatum Quackgrass Elytrigia repens *Russian knapweed Acroptilon repens Spiny cocklebur Xanthium spinosum Teasel Dipsacus fullonum

Class C Species – Class C species are wide-spread in the state. Management decisions for these species should be determined at the local level, based on feasibility of control and level of infestation.

Common Name Scientific Name *Cheatgrass Bromus tectorum Curlyleaf pondweed Potamogeton crispus Eurasian watermilfoil Myriophyllum spicatum Giant cane Arundo donax Hydrilla Hydrilla verticllata Jointed goatgrass Aegilops cylindrica *Musk thistle Carduus nutans Parrotfeather Myriophyllum aquaticum *Russian olive Elaeagnus angustifolia *Tamarisk Tamarix spp.

Siberian elm Ulmus pumila Tree of heaven Ailanthus altissima Watch List Species – Watch list species are species of concern in the state. These species have the potential to become problematic. More data is needed to determine if these species should be listed. When these species are encountered, please document their location and contact appropriate authorities.

Common Name Scientific Name Crimson fountaingrass Pennisetum setaceum Meadow knapweed Centaurea pratensis Myrtle spurge Euphorbia myrsinites Pampas grass Cortaderia sellonana Sahara mustard Brassica tournefortii Syrian beancaper Zygophyllum fabago Wall rocket Diplotaxis tenuifolia

Description of Pest Problems:

Reclamation has a responsibility for the protection of human health, the environment, and for the care and wise use of the natural and cultural resources entrusted to us. This plan is designed to provide guidance to Reclamation staff to manage pest species in a way that will:

Keep dam facilities, including tail race and weirs below the dam, free of vegetation which effect dam operations and safety inspections Minimize the distribution of weed seeds Control vegetation height on the crest of dams for road maintenance and to prevent snow accumulation due to vegetation on the shoulders of the road Control aquatic vegetation as needed in irrigation distribution systems Prevent excessive damage to trees and other planted vegetation by controlling high populations of invertebrate pests Keep grass areas around buildings and recreation facilities weed free for safety purposes and to increase aesthetics of Reclamation lands and water

3.1.2 Animals

Animal pests of concern consists primarily of insects, rodents and mollusks that pose a threat to human health and safety or may cause damage to dam structures, recreational facilities, resources, or adjacent crops and private property.

SSmall Mammals The most commonly targeted animal pests include:

Mice (Mus musculus) Deer mice (Peromyscus maniculatus) Burrowing mammals such as pocket gophers (Thomomys talpoides), prairie dogs (Cynomys ludovicianus), badger (Taxidea taxus), marmot (Marmota spp.) and ground squirrels (Spermophilus spp.)

If vegetation is allowed to grow near the dam and facilities, habitat for small mammals is created.

The nests and burrows of the animals can cause structural damage to dams and facilities. While these burrowing mammals usually are not a threat to the integrity of concrete dams, they can impact earthen-filled dams. Their burrowing activity can also be a serious threat to canal systems. Their burrows can weaken ditch banks, cause water loss by seepage and piping through the bank and result in complete loss or washout of the canal bank.

The deer mouse (Peromyscus maniculatus) is the most widely distributed member of the Peromuscus group of mice and is of greatest concern within the Navajo PJA. It is primarily active at night when it emerges from its nest to feed on many types of seeds, berries, fruits, and insects. With their high reproductive potential, they could easily overpopulate their habitats, but this seldom occurs because of predation by birds, larger mammals, and reptiles. Deer mice usually make their nests in a cavity inside a tree or stump, but they will nest in burrows in the ground made by other animals. They also will invade salvage well sites, vault interiors, elevation wells, flow meter locations, and stilling wells to make their nests. Besides the nuisance of accumulated nesting debris, this rodent is known to carry the viral disease known as Hantavirus Pulmonary Syndrome (HPS).

MMollusks Zebra (Dreissena polymorpha, collectively referred to as Dreissenids) and quagga mussels (Dreissena rostriformis bugensis) are pest species of concern. They are not covered in this PDMP but are addressed in the regional response plan. Zebra and quagga mussels are currently not present in Navajo Reservoir, and Reclamation has taken preventive measures to ensure that they do not become established through the implementation of a boat inspection and decontamination program.

The New Zealand mud snail (Potamopyrgus antipodarum) is an additional mollusk pest species of concern that is currently found directly downstream of the PJA in the San Juan River and at Lake Capote, between Durango and Pagosa Springs.

Mosquitoes The life cycles of mosquitoes (Culicidae family) vary widely from species to species. Only the adult females bite. Several genera may transmit diseases to humans such as encephalitis and West Nile virus. Mosquito control measures are most effective in the larval life stage; however, no mosquito control is proposed at this time.

Description of Pest Problems Reclamation has a responsibility for the protection of human health, the environment, and for the care and wise use of the natural and cultural resources entrusted to us. This plan is designed to provide guidance to Reclamation staff to manage pest species in a way that will:

Protect the structural integrity of the dam embankments from damage caused by intrusive burrowing animals, root systems of trees, and other woody vegetation, Decrease fire potential and habitat for other pest species, Control pests as necessary to protect public health and safety and to prevent damage to public and private property, and Control undesirable insects and vegetation in food plots

Animal pest species:

Damage caused by animal pest species includes destruction of underground utility cables and irrigation pipes, impact Reclamation’s earthen dams and dikes, direct consumption and smothering of forage by earthen mounds, and change in species composition on rangelands by providing seedbeds for noxious weeds. Also, animal pests may move from federal land to private land and result in a landowner complaint. Many of the animal species that will be controlled can also be harboring diseases such as Hantavirus or the bubonic plague.

3.2 Action Thresholds

3.2.1 Aquatic Plant Species

Pest Management Objective Maintain the water carrying capacity within Reclamation’s conveyance structures.

Action Threshold

As soon as plant material is visible.

BBasis for the action threshold There is no tolerance for aquatic plant growth because control is easier to achieve if addressed early in the vegetative growth stage. If control is delayed, the higher vegetative density will require more herbicide. In addition, large mats of dead and decaying plants could result in the depletion of dissolved oxygen and significant loading of total organic carbon to the reservoirs.

Method to determine when the action threshold has been met Weekly checks are made by O&M staff to keep fully apprised of developing issues related to aquatic plants in the canals with flowing water.

3.2.2 Terrestrial Plant Species

Pest Management Objective Ensure that plant pest species do not pose a threat to human health and safety or cause damage to dam structures, recreational facilities, resources, or adjacent private property.

Action Threshold One plant.

Basis for the action threshold Many of the terrestrial plant pests on Reclamation’s management area are noxious weeds that must be controlled as mandated by federal, state, and local regulations. Because of this, there is “no tolerance” for these pests. Other terrestrial plants must be controlled to: 1) allow for unimpeded inspection of dam and dike faces, 2) maintain the structural integrity of Reclamation’s facilities, 3) keep grass areas around buildings and recreation facilities weed free for safety purposes and to increase aesthetics of Reclamation lands and water, and 4) control pests as necessary to protect public health and safety and to prevent damage to public and private property.

Pre-emergent herbicide can be applied to suppress weed seeds from sprouting.

Method to determine when the action threshold has been met Periodic checks are made by managing partners and O&M staff to keep fully apprised of developing issues related to terrestrial plant pest on Reclamation lands.

3.2.3 Animal Pest Species

Pest Management Objective Ensure that the animal pest species do not pose a threat to human health and safety or cause damage to dam structures, recreational facilities, resources, or adjacent crops and private property.

Action Threshold One pest.

Basis for the action threshold

Intrusive burrowing animals can negatively impact the structural integrity of the dam, dike, and canal embankments. Pests will also be controlled as necessary to protect public health and safety and to prevent damage to public and private property.

New Zealand mud snails can negatively impact native snails, mussels, and aquatic insects upon which native fish species depend.

Method to determine when the action threshold has been met Periodic checks are made by O&M staff to keep fully apprised of developing issues related to animal pest species on Reclamation lands.

Table 3.3: Summary of Action Threshold(s)

Target Pests Action Thresholds

Weeds, noxious and invasive

In addition to controlling all vegetation that grows a d j a c e n t t o the dam, Reclamation is committed to cooperating with the State of New Mexico and county weed management organizations to control noxious and invasive weeds. The goal is to help prevent the spread of weeds.

Vegetation along dams, structures, and roadways, including weeds and woody species

Vegetation along roadways leading to the dam, power plants and parking areas, must be controlled to protect the government’s investment in the pavement and access to its facilities, as well as to protect driver safety.

Vegetation growing over two feet, impairing drivers’ visibility, and/or impairing the road or shoulders, will be cut or sprayed with herbicides.

Vegetation--debris Whenever trash racks, weirs, and tail races below the dams get clogged with vegetation or debris, they must be cleared. This is a mechanical control effort that guarantees safe dam operations.

Aquatic vegetation The goal is to control aquatic vegetation whenever infrastructure such as canal gates, trash racks, spillways, or weirs become clogged or potentially clogged.

Small mammals

Whenever small mammals burrow or nest n e a r the dam or other Bureau of Reclamation buildings and infrastructure, they threaten the structural stability of the dam or other infrastructure (like canals), and potentially human health, and action must be taken. The management objective is to protect the structural integrity of the dam and related project facilities adjacent to the dam.

Mollusks Zebra and quagga mussels are covered under a separate plan. Reclamation supports NM Game & Fish efforts to prevent the spread of New Zealand mud snails in the San Juan River downstream of the PJA.

Mosquitoes To reduce mosquito populations in response to public complaints or mosquito born disease outbreak. Mosquito control measures are most effective in the larval life stage.

3.3 General Location Map

A map of the pest management area is provided as Attachment A.

3.4 Water Quality Standards

3.4.1 Summary of Tier 3 Waters and Waters Impaired for Pesticides There are no Tier 3 waters within the San Juan River Watershed.

None of the waters (San Juan River) related to this PDMP are impaired by any substance which is either an active ingredient of a pesticide to be discharged or a degradate of such an active ingredient.

4 Pest Management Option Evaluation

4.1 Pest Management Strategy

The intent of this plan is to coordinate the use of pest and environmental information with available pest control methods to prevent unacceptable levels of pest damage by the most economical means and with the least possible hazard to people, property, and the environment.

The application of pest control techniques not included in this plan may only be authorized through careful consideration and evaluation, using a Pesticide Use Proposal (PUP) form. The PUP form should list the name, formulation, and application dates of the pesticide, as well as a description of the proposed treatment site, sensitive aspects, or precautions of the pesticide. PUPs are developed in the Area Office and sent to the Regional Office for review/approval and need to be signed by a certified pesticide applicator. They are valid for a term of one year or, when incorporated into an approved IPM/PDMP plan, for the term of the plan.

The protocol for pest management record management and archiving may differ. Consult with project area managers to verify if an existing method is in place and/or if the use of PUPs as described above is acceptable.

4.1.1 Prevention

The most important pest management action is to prevent unwanted species from becoming established in the first place. The following are prevention measures that may be effective in preventing pest species from becoming established on WCAO lands:

Increased awareness, concern, and involvement among land users and managers, Improve education to promote voluntary adoption of prevention practices, Incorporate weed prevention, weed control, and land rehabilitation into project layout, design, alternative evaluation, and project decisions, Avoid or remove sources of weed seed and propagules to prevent new weed infestations and the spread of existing weeds, and Avoid creating soil conditions that promote weed germination and establishment by maintaining healthy, desirable vegetation that is resistant to weed establishment.

Equipment (includes Reclamation-owned, managing partner, contractor, subcontractor, and rental) used at Reclamation jurisdictional areas must be inspected and cleaned, if necessary, to ensure that equipment arrives and leaves clean to prevent the introduction or spread of invasive species.

4.1.2 Early Detection and Rapid Response

Early Detection and Rapid Response (EDRR) can stop the spread of new and emerging invasive plant species before they become established. It is one of the most cost-effective and ecologically viable methods for controlling invasive species and is well worth the effort to protect Reclamation's jurisdictional areas.

The goals of the EDRR program are to:

Provide alert lists, identification resources, and reporting protocols for targeted pest species, Build an invasive pest network to detect new and emerging species within Reclamation’s jurisdictional areas, and Provide information and planning assistance to rapidly respond to and successfully manage detected species.

4.1.3 Control and Management

Control and management methods are actions taken to control, limit, or reduce the impact of pests on water system function. Control methods are generally categorized under four topics: biological control, chemical control, cultural or environmental control, and mechanical control.

These control and management methods are described under the Pest Management Techniques section of the IPM plan.

4.1.4 Restoration

Restoration is an integral component of comprehensive long-term prevention and control programs for invasive species; restoration may keep invasive species from causing greater environmental disturbances. Depending on the scale, duration, and frequency of the invasion, restoring the ecosystem to its original condition may not be technically or financially feasible.

4.2 Pest Management Techniques

4.2.1 Cultural

Cultural control includes any activity that promotes or enhances the vigor and growth of the desirable species. These activities can include site conditioning, the selection of site-suitable species, management of the species density, and controlled grazing.

4.2.2 Mechanical

Mechanical techniques for pest control are used to alter the environment in which a pest lives, traps and/or removes pests where they are not wanted, or to exclude pests. Examples of this type of control include any method that uproots, buries, cuts, smothers, or burns vegetation. Mechanical control can also include mechanical traps, glue boards, nets, and other barriers to prevent pest species from entering areas where they are not wanted.

4.2.3 Biological

Biological control organisms are used to limit growth, reproduction, and survival of a weed or pest.

In many cases invasive species have been introduced from foreign sources, often in the absence of natural enemies or predators. This often leads to uncontrolled invasive outbreaks. Some biological control strategies employ a natural predator which co-evolved with the pest in its native range. Such non-indigenous or non-native biological control agents are only used by Reclamation after they have been subjected to thorough study and evaluation by the U.S. Department of Agriculture (USDA), Agricultural Research Service (and/or its cooperators) and approved for release by the USDA Animal and Plant Health Inspection Service (APHIS) and each State’s Department of Agriculture.

Biological control of pests is most successful in stable ecosystems; thus it is not suitable for use in croplands. Use of biological control is advantageous because they are often a more environmentally friendly option, selective and host-specific, self-perpetuating, and sometimes the only available control option.

Care should be taken when collecting or purchasing biological control agents. Reclamation personnel must educate themselves on the environment and habitat requirements of the available biocontrol agents. Reclamation must also get permission when collecting biocontrol agents on non- Reclamation land or water. Always ensure that when biological control agents are purchased the seller certifies the samples as disease- and parasitoid-free.

4.2.4 Chemical

Chemical control includes the use of any manufactured or extracted chemical compounds that are applied to control a pest species. Some merely repel or confuse pests (PSU, 2011). Most are designed to alter the target pest’s ability to complete its life cycle.

At one time, chemicals were considered to be the most effective control available, but pest resistance rendered many pesticides ineffective. In recent years, the trend has been to use pesticides which have limited residual action. While this has reduced human exposure and lessened environmental impacts, the cost of chemical control has risen due to requirements for more frequent application. Since personal protection and special handling and storage requirements are necessary with the use of chemicals, the overall cost of using chemicals as a sole means of control can be quite costly when compared with nonchemical control methods.

Applicators must determine the appropriate method for applying pesticides to unwanted pests. This is dependent upon a number of factors: pesticide label restrictions; the treatment objective;

accessibility; topography; size of infestation; characteristics of the target and desired species; location of sensitive areas and potential environmental impacts in the immediate vicinity; costs; equipment limitations; and weather and vegetative conditions at the site.

Over very large or inaccessible areas, pesticide treatments may be applied aerially by helicopter or fixed-wing aircraft. Aerial applications, which require pre-approval by Reclamation, do not disturb the soil or protective organic layers and are not limited by inaccessibility or rugged terrain. In general, helicopters are more maneuverable than fixed-wing aircraft, more effective in areas with irregular terrain, and more effective for treating specific target vegetation in areas with multiple vegetation types. A common problem associated with aerial application of herbicides is drift of chemicals from the target site, which may be difficult to predict and manage.

Manual applications are suited for treatments of small areas or at sites that are inaccessible by vehicle. Manual spot vegetation treatments target individual plants through herbicide injections, applications on cut and/or intact surfaces, or granular application to the surrounding soil. Backpack sprayers can also be used to treat smaller infestations. To cover a larger area, mechanical equipment is typically used (BLM, 2005).

Appendix M contains a list of pesticides approved for use by the BLM; Reclamation defers to this list for pesticide usage on its lands. Refer to the complete label prior to considering the use of any herbicide formulation. Label changes can impact the intended use through the creation or elimination of Special Local Need (SLN) or 24 (c) registrations, changes in application sites, rates and timing of application, county restrictions, etc.

4.2.5 Integrated Control Methods

Integrating several management techniques often result in more effective pest control. The use of mowing or burning to prevent seed production and to stimulate new growth often improves the effectiveness of herbicide applications. Monitoring and treating invasive pests as they are discovered prevents the pests from reaching outbreak levels. It is more cost effective to prevent the establishment of invasive species by treating small populations or tree and shrub seedlings, rather than attempting to control an established infestation.

Newly disturbed areas are prime locations for invasive species to become established. These areas should be planted to desirable vegetation as soon as possible after being disturbed. Chemicals and other control measures are often necessary to prevent the encroachment and spread of a pest during the time required to reestablish desirable vegetation. Biological control agents often take several years to effectively reduce a large population of invasive species but may have appropriate uses at certain disturbed sites.

It is expected that additional invasive species will present new challenges in management control.

New pesticides and applications, biological control agents, and other techniques will become available. After passing federal requirements, these new techniques may be implemented on a trial basis. Personnel will document and monitor the effects of these trials. If satisfactory results are achieved, the IPM plan will be updated to include the new management technique.

4.3 Targeted Pest Management Assessment

4.3.1 Aquatic Vegetation

NNo Action The presence of attached algae, aquatic plants, and other weeds in the water conveyance facilities can significantly impact water transport and can affect how water is used. These target pests must be controlled to maintain the purpose of the canals and allow Reclamation to deliver required quantities of water. The No Action option is not viable in Reclamation’s pest management areas.

PPrevention Water temperature, flow rates, water levels, substrate conditions, sunlight, and nutrients are all important factors that impact the growth of attached algae and aquatic plants in the water conveyance facilities. Purposeful management of these factors can reduce the capacity of the canal ecosystem to support nuisance levels of attached algae and aquatic plants.

For example, the control of nutrient loading to the canals could potentially reduce attached algae and aquatic plant densities within the canals. The aquatic ecosystems in the region appear to be sensitive to small changes in nutrient inputs. However, the threshold levels of nutrient concentrations that result in nuisance levels of attached algae and aquatic plants are currently unknown and are likely not the same for different problem species. Non-point sources of nutrients are difficult to control and manage. Locations of nutrient sources, quantification and seasonal variations of nutrient loadings, and threshold concentrations that result in nuisance algae and aquatic plant densities are all required in order to implement effective nutrient control measures.

Mechanical/Physical Methods Mechanical control involves the use of physical methods or mechanical equipment to control pest infestations. For attached algae and aquatic weeds, this could include pressure washing, abrasive scrubbing, weed removal by hand or machine, and dredging.

For the most part, hand pulling of terrestrial and aquatic weeds is not an option because of the large areas involved and the labor-intensive nature of this method.

A tractor mower is used to mow grasses and broadleaf weeds down to the high-water line. A backhoe or dragline is used to remove silt and sand from canal bottoms and disrupt some aquatic plant tubers.

Increased flow velocities in the earthen canals may cause certain attached algal species to detach or be sheared off. It is an option that may be explored for Ulothrix species or other target attached algae.

Cultural Methods Cultural control involves manipulation of the habitat to make it less suitable for the pest and reduce the development of the pest problems. For example, management decisions to line the canals with concrete may reduce problems associated with aquatic plants.

Canal draw-down is used during the irrigation off-season to kill aquatic plants/algae by exposing them to drying conditions and freezing temperatures. This also reduces the number of viable tubers in the soil in the earthen canals. However, sago pondweed and other aquatic plants can survive up to five months after dewatering so canal draw-down may not produce the expected results with respect to killing all aquatic vascular plants (particularly if the winter does not experience intervals of severe cold).

Complete canal draw-down of the water conveyance facilities is usually only conducted for about two weeks every fall for routine maintenance. This generally works well as a method to help control the attached algae in this canal. However, depending on conditions, there may not always be enough time for complete desiccation of the attached algae.

Partial canal draw-down can be used in the summer to kill aquatic plants/algae by exposing them to high temperatures and drying conditions. However, the use of canal drawdown in the summer can be difficult to coordinate with planned or anticipated water deliveries.

BBiological Control Agents Biological control organisms are used to limit growth, reproduction, and survival of a weed or pest.

In many cases invasive species have been introduced from foreign sources, often in the absence of natural enemies or predators. This often leads to uncontrolled invasive outbreaks. Some biological control strategies employ a natural predator which co-evolved with the pest in its native range. Such non-indigenous or non-native biological control agents are only used by Reclamation after they have been subjected to thorough study and evaluation by the USDA Agricultural Research Service (and/or its cooperators) and approved for release by the USDA Animal and Plant Health Inspection Service and each State’s Department of Agriculture.

Grass carp (Ctenopharyngodon idella) have been tested by Reclamation for aquatic plant control in a one-mile section of the Boulder Feeder Canal in 2008. Fish containment was a problem; a majority of the fish escaped within the first couple of days. With few to no fish left in the test section, the effectiveness of the fish could not be evaluated. Grass carp may be an option in the future for aquatic weed control in water conveyance facilities.

Pesticides Chemical herbicides are used by Reclamation or their contractors when other treatment options do not maintain attached algae and aquatic weeds below the nuisance threshold levels. Chemical herbicides are only applied if and when the action thresholds have been met. Appendix M contains a list of pesticides approved by the BLM. Applicators on Reclamation lands will refer to the complete label prior to considering the use of any herbicide formulation. Label changes can impact the intended use through such things as, creation or elimination of Special Local Need (SLN) or 24 (c) registrations, changes in application sites, rates and timing of application, county restrictions, etc.

The application rates will be based on the guidance provided in current product labels, publications by the USDA Extension…