Exhibit 3a BLM 2018 Weeds BO.pdf

Specific to aquatic invasive plants, hand-pulling and/or smothering may be used when an infestation is very limited in extent and occurs close to the shoreline of a waterbody, but has not yet infested deeper waters.

Mechanical treatments should not occur on any slopes where excessive erosion to waterbodies (e.g., slope fall lines to lakes, streams, etc.) and resource damage will occur.

Proper erosion control techniques will be utilized on steep slopes to prevent excessive erosion and resource damage from occurring.

When working in watersheds with ESA-listed species, mechanical ground disturbing activities will not be conducted adjacent to or within riparian areas during the spawning season.

A 25-foot vegetative buffer will be maintained next to live water to leave ground cover intact and prevent erosion into streams or adjacent waterbodies.

Limit mechanical treatments to power tools that do not disturb the ground when working within 25 feet of streambanks, or floodprone areas along lakes, ponds, springs, and seeps.

1.3.3 Herbicide Application

Chemical herbicides and associated adjuvants are applied to target plants under this method. The

BLM proposes using ground-based or aerial application of herbicides, depending on: (1)

Treatment objective and priority of the target invasive plant species; (2) accessibility, topography, and size of the treatment area; (3) the expected efficiency and effectiveness of the method selected; (4) the risk for spread or invasion into other locations; and (5) the potential to harm priority habitats and vegetation complexes such as those associated with threatened, endangered, or sensitive species. Herbicides are extensively screened and tested before they are approved and registered for use by the EPA.

Herbicide labels contain information on the proper administration of each herbicide, including the following: (1) A list of the ingredients; (2) an EPA registration number; (3) precautionary statements (hazards to humans and domestic animals, personal protective equipment, user safety recommendations, first aid, and environmental hazards); (4) directions for use, storage, and disposal; (5) mixing and application rates; (6) approved uses and inherent risks of use;

(7) limitations of remedies; and (8) general information.

Proposed herbicide application methods include:

Spot spraying – This method targets individual plants and the immediate area around them. Most spot spraying is usually done with a backpack sprayer. However, spot spraying may also be applied using a hose from a truck-mounted or off-highway vehicle (OHV) mounted tank, or tanks mounted on pack animals. This is the most common herbicide application method.

Broadcast – Herbicide is applied to cover an area of ground rather than individual plants. This method may employ a spray system mounted on a truck or OHV.

Broadcast applications are used in areas where invasive plants occupy a large percentage of plant cover on the site, making spot spraying impractical.

Wicking/Wiping/Injecting – This method will be used when targeting invasive species such as Russian Olive (Elaeagnus angustifolia) trees. Most wicking/wiping/injecting would take place on stumps after trees were cut to prevent trees from re-sprouting.

Aerial application - This method will be used in areas where physical features, such as topography, restricted access, size and/or rate of infestation spread, personnel safety, or other factors (such as prohibitive cost of ground application) occur. Only helicopter applications are proposed.

Herbicide formulations and mixtures could contain one or more of the 15 active ingredients displayed in Table 2. The range of application rates for each chemical is derived from Human

Health and Ecological Risk Assessments and from the herbicide label. Additional herbicides may be added in the future at either the Land Use Plan Level or project level, through appropriate risk analysis, NEPA procedures, and ESA consultation (discussed in BLM 2018

BA). Table 3 provides specific buffers for individual active ingredients, environmental conditions, and types of waterbodies potentially encountered within the action area during ground-based applications. These buffers and plans are critical measures to minimizing potential exposure of ESA-listed fish and their habitats.

The BLM CFO and SFO propose to use only Washington State aquatic-certified adjuvants in riparian areas or in aerial applications in watersheds with ESA-listed fish. Table 4 lists currently approved additives and adjuvants (i.e., ingredients that improve herbicide effectiveness) available for use on BLM-administered lands in Idaho that have met this aquatic certification.

The intent of Table 4 is not to limit the BLM’s use to only the product names displayed. Review of new formulations/EUPs by the Salmon-Challis Level 1 Team will only be required where the active ingredients and maximum application rates are inconsistent with those already described in this proposed action.

Table 2. Proposed herbicides and application settings for use on BLM-administered land within the Challis and Salmon field offices.

General

Location

Herbicide Commonly Used

Brand Namesa

Maximum

Application Rate

(a.i. or acid equivalent

[a.e.]/acre)

Typical

Application

Rate (pounds

[lbs] a.i. or a.e.

acre)

Vegetation

- Away

From water

(>50 feet)

Vegetation

- Near

Water

(<50 feet)

Aerial

Delivery

2,4-D amine Amine 4, Weedar®

2.0 lb a.e./acre/app

4.0 lb/ae/acre/year 1.0–2.0 lb a.e./ac X X X

Aminopyralid Milestone® 0.11 lb a.e./acre/year 0.078–0.11 lb a.e./ac X X X

General

Location

Herbicide Commonly Used

Brand Namesa

Maximum

Application Rate

(a.i. or acid equivalent

[a.e.]/acre)

Typical

Application

Rate (pounds

[lbs] a.i. or a.e.

acre)

Vegetation

- Away

From water

(>50 feet)

Vegetation

- Near

Water

(<50 feet)

Aerial

Delivery

Chlorsulfuron Telar®

0.02 product/acre/year

(0.12. lb a.i./acre/year)

0.01–0.02 lb a.i./ac X

Clopyralid Transline® 0.5 lb a.e./acre/year 0.1–0.5 lb a.e./ac X X

Dicamba Banvel®

1.0 lb a.i./acre/app

2.0 lb a.i./acre/year 0.5–2.0 lb a.i./ac X

Fluroxypyr

Vista® XRT®, Starane®, Spotlight®

0.5 lb a.e./acre/year 0.25 lb a.e./ac X

Glyphosateb

Rodeo®, Roundup®, Accord®

1.7 lb a.e./acre/app

4.0 lb a.e./acre/year 0.5–3.0 lb a.e./ac X X X

Imazapic Plateau®

0.1875 lb a.i./acre/year

0.09–0.16 lb a.i./ac X X

Imazapyr

TVC Total, Habitat, Vegetation

Control®, Assault®, Chopper®, Arsenal®

1.5 lb a.e./acre/year 1.0 lb a.e./ac X X

Metsulfuron-methyl Escort® 0.15 lb a.i./acre/year

0.01–0.02 lb a.i./ac X

Picloram Tordon™ 1.0 lb a.i./acre/year 0.25–1.0 lb a.i./ac X

Rimsulfuron Matrix® 0.0625 a.i./acre/year 0.0469-0.0625 a.i./ac X X

Sulfometuron methyl

Oust Weed Killer®

DPX 5648

0.03–0.281 lb a.i./acre/app

0.03–0.38 lb a.i./acre/year

0.09–0.38 lb a.i./ac X

Triclopyr TEA:

triethylamine salt

Element 3A®, Garlon 3A®

2.0 lb a.e./acre/year 1–2.0 lb a.e./ac X X a List represents brands most commonly used, although brands other than those listed may also be used.

b Formulations containing the Polyoxyethyleneamine (POEA) surfactant (i.e., Roundup® and similar products) are not proposed

<100 feet from water.