EnvironmentalAssessment.pdf

Environmental Assessment for the Invasive Exotic Plant Management Program

Coronado National Forest; Cochise, Graham, Pima, Pinal and Santa Cruz Counties in Southeastern Arizona; and Hidalgo County in Southwestern New Mexico

United States Department of Agriculture

Forest Service

September 2004

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Environmental Assessment Invasive Exotic Plant Mangement Program

CORONADO NATIONAL FOREST

TABLE OF CONTENTS

Table of Contents............................................................................................................. iii Abstract Chapter 1 – Purpose and Need for Action

Introduction Purpose and Need for Action Proposed Action Adaptive Management Strategy Decision Framework Public Involvement Issues Issues and Concerns Addressed Through Project Design Incorporation by Reference

Chapter 2 - Alternatives Alternative 1 - No Action Alternative 2 – Non-herbicide control combined with a program of monitoring, restoration and prevention Alternative 3 - Integrated Vegetation Management - The Proposed Action Mitigation Measures Common to All Action Alternatives Mitigation Measures Involving the Use of Herbicides Comparison of Alternatives Alternatives Considered but Eliminated from Further Analysis

Chapter 3 – Affected Environment and Environmental consequences Project Area Vegetation – Forest Plant Communities (Issue 1) Wildlife (Issue 2) Water Quality (Issue 4) Soil Quality (Issue #2) Effects to Human Health (Issue 3) Costs vs. Benefits of Treatments (Issue 5) Wilderness (Issue 7)

References and Acronyms References Acronyms Used in the Environmental Assessment

Maps Appendices

Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F

ABSTRACT

The Coronado National Forest proposes to develop and implement an Integrated Vegetation Management (IVM) program for the control of invasive exotic plants. The project area is located on National Forest lands in southeastern Arizona and southwestern New Mexico. This action is needed in order to meet the requirements of law, regulation and policy and because invasive exotic plants occur on and near the Coronado National Forest.

The proposed action would authorize the use of physical and cultural methods of invasive exotic plant removal as well as ground based application of chemical herbicides. In addition to the proposed action, the Forest Service also evaluated the following alternatives:

• All treatments recognized under IVM except for the use of herbicides

• No Action

Based upon the effects of the alternatives analyzed and disclosed in this EA, the Forest Supervisor will decide whether to implement the proposed management program, or to implement an alternative to the program. If the Forest Supervisor decides to implement all or part of the program, he or she will also decide when and under what terms and conditions the Forest would conduct such activities, and what measures would be needed to meet Forest Plan goals and standards and to provide adequate mitigation.

The Forest Service has prepared this Environmental Assessment in compliance with the National Environmental Policy Act (NEPA) and other relevant federal and state laws and regulations. This Environmental Assessment discloses the direct, indirect, and cumulative environmental impacts that would result from the proposed action and alternatives. The document is organized as follows:

Chapter 1, Purpose and Need for Action. This section includes information on the purpose of and need for the project, the agency’s proposal for achieving that purpose and need, public involvement and issued identified by the interdisciplinary team.

Chapter 2, Alternatives, Including the Proposed Action: This chapter provides a description of the agency’s proposed action as well as alternative methods for achieving the stated purpose. These alternatives were developed based on significant issues raised by the public and other agencies. This section also includes mitigation measures included in the proposed action.

Chapter 3, Affected Environment and Environmental Consequences: This section describes the affected environment and environmental consequences of implementing the proposed action and alternatives. The No Action Alternative provides a baseline for evaluation and comparison of the other alternatives.

Chapter 4, Consultation and Coordination: This section provides a list of preparers and agencies consulted during the development of the environmental assessment.

Appendices: The appendices provide more detailed information to support the analyses presented in the environmental assessment.

Additional documentation, including more detailed analyses of project-area resources, may be found in the project planning record located at the Coronado National Forest Supervisor’s Office in Tucson, Arizona.

Invasive Exotic Plant Management Program Environmental Assessment

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CHAPTER 1 – PURPOSE AND NEED FOR

ACTION

Introduction

The Organic Act of 1897 provided for the establishment of National Forests, in part “…for the purpose of securing favorable conditions of waterflows…” The Forest Service Natural Resource Agenda for the 21st century clarified that statement to identify critical issues facing our watersheds and ecosystems including invasion of exotic species.

Actions identified to implement this policy include preventing “…exotic organisms from entering or spreading in the United States”. Further, the Federal Noxious Weed Act (7 U.S.C. § 2801-2814) and Executive Order 13112 authorize federal agencies to initiate control and eradication actions against incipient infestations of invasive exotic species that are introduced into this country. Federal actions such as noxious weed and invasive species eradication or control projects must be analyzed to determine the potential environmental consequences (National Environmental Policy Act of 1969).

The term “noxious weed” has legal ramifications for states that have noxious weed laws or regulations. Noxious weeds in Arizona are those species that are “...liable to be, detrimental or destructive and difficult to control or eradicate...” (ARS § 3-201). New Mexico defines a noxious weed as “a plant species that is not indigenous to New Mexico and that has been targeted pursuant to the Noxious Weed Management Act for control because of its negative impact on economy or environment” (§ 76-7-1 to 76-7-22 NMSA 1978, Doc. 17). The term “noxious weed” has been selected for use in the Forest Service Region 3 Weed Management Strategy, issued in January 1999, to pertain to invasive exotic plants that will cause adverse environmental, social, and economic effects, altering management objectives for the Southwestern Region. Forest Service policy (Forest Service Manual 2080.5) defines noxious weeds as: “Those plant species designated as noxious weeds by the Secretary of Agriculture or by responsible state official. Noxious weeds generally possess one or more of the following characteristics: aggressive and difficult to manage, poisonous, toxic, parasitic, a carrier or host of serious insect or disease and being native or new to or not common to the United States or parts thereof.”

While small populations of designated noxious weeds occur on the Forest, a more significant problem is with invasive exotic species. Federal and state laws generally define noxious weeds in terms of interference with commodity uses and economic impacts; however, the impact of invasive exotic plants on ecosystem processes such as hydrology, fire frequency and plant productivity is a growing concern. Since the Coronado National Forest was established in 1908, invasive plants have increased in numbers and distribution across the Forest. This Environmental Assessment (EA) had been prepared to analyze and disclose the effects of a proposed integrated vegetation management program to eradicate and control invasive plants on the Forest. It provides general programmatic direction for weed and invasive species control. The guidance and analyses contained herein will be used to guide the development of annual operating plans throughout the Forest where invasive exotic plant management activities are proposed. Invasive exotic plants include noxious weeds (eg. yellow star thistle), but also include numerous other plant species that cause detrimental changes to native ecosystems. In this analysis, the term “noxious weed” is used to refer to those species that are designated as such on a state or federal list. The terms “invasive exotic”, “invasive plant” or “weed” are used to refer to the broader category of invasive plant species included in the analysis.

Purpose and Need for Action

The spread of invasive species threatens the health of native ecosystems by causing changes in the composition and functioning of native plant communities that are the foundation for native ecosystems. Invasive plants have characteristics that permit them to rapidly invade and dominate new areas, out competing other vegetation for light, moisture and nutrients. Some of these characteristics include (Westbrooks 1998):

• Early maturation;

• Profuse reproduction by seeds and/or vegetative structures;

• Seed with long viability periods;

• Seed dormancy allowing periodic germination during favorable conditions;

• Adapted to spread via human and natural agents such as in contaminated gravel or crop seed, in tires, and on livestock, pets or clothing;

• Production of biological toxins that suppress the growth of other plants;

• Prickles, spines or thorns that can cause physical injury and repel animals;

• The ability to parasitize other plants;

• Seeds that are the same size and shape as crop seed, making cleaning difficult;

• Root structures with large food reserves;

• Able to survive and produce seed under adverse environmental conditions;

• High photosynthetic rates.

Invasive plants are often spread by human activities associated with vehicles and roads, agricultural practices, urban development, contaminated livestock feed, contaminated seed, and poor range management practices (Belsky and Gelbard 2000). Monocultures of noxious weeds such as yellow star thistle can become established in unmanaged lands and spread to adjacent rangeland, forests, and farmlands, causing great environmental and economic impacts. According to a recent survey by the U.S. Department of the Interior, noxious weeds have invaded over 17 million acres of public lands in the West, more than quadrupling their range from 1985-1995 (Westbrooks 1998). When invasive species such as cheatgrass, red brome and medusahead are included, there are 100 million acres of moderately to heavily infested land. Invasive species are expanding their range on public lands at the rate of approximately seven square miles per day (Westbrooks 1998).

The public has become increasingly concerned as aggressive noxious weeds replace native plants, reduce access to recreational sites, and reduce forage for livestock and wildlife.

Noxious weeds and invasive species may have adverse health effects on humans by causing mechanical injuries and creating allergic reactions. A summary of adverse environmental impacts of invasive exotic species on public lands is presented below (Westbrooks 1998).

Wildlife, Plant Communities and Biodiversity: Solid stands of invasive plants can replace natural ecosystems and lead to extinction of native plant species, including threatened and endangered species. Invasive plants can impair soil and water resources, ruin fish spawning habitat by causing soil erosion, reduce the amount of cryptogamic ground crust which is important for nitrogen fixation and degrade wildlife habitat by simplifying plant communities and reducing available forage.

Cultural Resources: Plant species and populations traditionally used for religious and cultural practices by American Indians, Hispanics, Anglos, and others can be threatened by invasive plant species.

Recreation: Invasive plants can be a nuisance to hikers, campers, boaters, pets and rafters, and can reduce revenues from hunting, fishing, and tourism.

Forests: Invasive plants can increase the risk of fire hazards, are serious problems in forest nurseries and can reduce regeneration, growth and yield in plantations.

Wetlands and Waterways: Invasive aquatic plants slow water flow which results in more evaporation from ditches, reduce water intended for crops and can interfere with boat travel.

Rights-of Way: Highway and Utility Corridors: Invasive weeds increase road maintenance costs by growing through cracks in asphalt, obscure vision at intersections and increase costs of vegetation management.

Rangeland and Pastures: Invasive plants can injure grazing animals and reduce forage and water available and can create or contribute to existing soil erosion problems.

The current cost to the U.S. economy is estimated at over $40 billion every year. This economic impact will increase without intervention (Griffith 1999). Invasive exotic plants do not require human disturbance to become established, and therefore pose an increasing threat to the integrity of wildland ecosystems (Olson 1999). These species are all introduced from other areas and have few natural, ecological controls to limit their spread. The increasingly devastating effects of weed invasion include reducing biological diversity, impacting threatened and endangered species and wildlife habitat, modifying vegetative seral stages, changing fire and nutrient cycles, and degrading soil structure (Olson 1999).

Existing Condition While the Coronado National Forest does not have a severe problem with noxious weeds, there are small infestations of invasive exotic species in 7 of the 12 designated Ecosystem Management Areas (EMAs) that make up the Forest. The invasive exotic plant species included for analysis in this environmental assessment are those known to occur, suspected of occurring, or having the potential to occur on the Coronado National Forest.

Species initially included for management consideration are listed in Table 1. Additional species that will be considered are any that are listed as a noxious weed in Arizona or New Mexico State regulations, identified as an invasive exotic species by the

Southwestern Region of the Forest Service, or are identified as a species of local concern to the Coronado National Forest.

Table 1. Species initially included in the management program Species Common Name

Scientific Name Status

Yellow starthistle Malta starthistle

Centaurea soltitialis, Centaurea melitensis

AZ & NM noxious weed NM noxious weed

Canada thistle Cirsium arvense AZ & NM noxious weed Texas blueweed Helianthus ciliaris AZ noxious weed Sweet resin bush Euryops subcarnosus AZ noxious weed Salt cedar Tamarix spp. Regional list Bull thistle Cirsium vulgare Regional list Tree of Heaven Ailanthis altissima Local concern Pentzia Pentzia incana Local concern Buffelgrass Pennisetum ciliaris Local concern Fountain grass Pennisetum setaceum Local concern Giant reed Arundo donax Local concern Johnsongrass Sorghum halepense Local concern Lehmann lovegrass Eragrostis lehmanniana Local concern African sumac Rhus lancea Local concern One invasive exotic, Lehmann lovegrass, occurs in all EMAs, often in extensive populations. Other than Lehmann lovegrass, no invasive exotic plants have been noted in the Galiuro, Dragoon, Whetstone, Winchester, or Santa Teresa EMAs. Many of the known locations were identified during a 1999 survey of primary roads, recreation areas, and administrative sites on the Douglas, Nogales, Sierra Vista, and Safford Ranger Districts (Doc. 6, project record). The initial survey for the Santa Catalina EMA is not complete, although several species invasive plants have been identified in this EMA. In addition to the survey information, there are other known populations. Occurrence of each species is shown for each EMA in Table 2 and the locations of known populations are shown on maps 2-8. Additional surveys are needed in all EMAs. All known populations occur at the lower elevations, with the exception of the populations of Canada thistle, which have been found in the Pinaleno EMA at elevations over 8500 feet.

Eight designated wilderness areas occur on the Forest. Only the Pusch Ridge Wilderness in the Santa Catalina Mountains is affected by infestations of invasive plants to any significant degree. Buffelgrass and fountain grass are spreading throughout canyons at lower elevations.

Limited invasive plant management efforts have been undertaken on the Forest to date.

These efforts have been generally confined to control activities. Mechanical treatment, including burning, has been used to manage some populations, but it does not appear to effectively control the overall expansion of weeds or prevent the introduction of new weed species. In general, treatment with mechanical methods has been proven to be labor intensive and expensive, even with small weed populations. Soil disturbance associated with mechanical weed control efforts has proven to increase seed germination of target weed species. There is a need for an integrated, environmentally safe and cost effective program to control existing populations of weeds and to prevent or reduce the potential for future infestation on the Forest. Once weed populations become large, they can only be contained through constant, long-term intervention. Complete eradication once a species is well established is extremely difficult or impossible. Prevention of spread of weeds is the most cost effective and environmentally sound control method available.

Table 2. Presence of species by EMA Species Chiricahua

EMA

Peloncillo

EMA

Pinaleño

EMA

Huachuca

EMA

Santa Rita

EMA

Tumacacori

EMA

Santa Catalina

EMA

Tree of Heaven X X X X Bull thistle X Texas blueweed X Yellow or Malta starthistle Potential Sweet resin bush X X Pentzia X X Canada thistle X Buffelgrass X X Fountain grass X X Giant reed X X Salt cedar X X X X X X X Johnson grass X Lehmann lovegrass X X X X X X X African Sumac X

Tree of Heaven: This species is native to central China. It was first introduced into the United States at Philadelphia, PA in1784. It was introduced into California in the mid- 1880s by Chinese immigrants, who valued the plant for its purported medicinal and cultural properties. It is now widely naturalized throughout the US. Tree of heaven occurs often on private land adjacent to the Forest, and there are small populations ranging from individual trees to small thickets on Forest lands in the Huachuca and Tumacacori EMAs. On the Forest, it is frequently found around abandoned mining settlements. Tree of heaven grows rapidly and is a prolific seed producer. Vegetative reproduction is by sprouting from stumps or root portions. It also appears to be somewhat allelopathic, that is, it produces a toxin that prevents the establishment of other plant species. Because of these characteristics, it can quickly take over a site and form an impenetrable thicket.

Bull thistle: There are approximately 40 acres in Chiricahua EMA infested with bull thistle. This area has been treated in the past with hand pulling and grubbing with limited success. It is a high priority for treatment.

Texas blueweed: The only population of Texas blueweed found is in the Peloncillo EMA. It is on private land but is adjacent to the Forest and poses a threat of infestation.

Yellow and Malta starthistle: There is an unconfirmed population of either Malta or yellow starthistle in the Peloncillo EMA on the Robertson allotment. There are populations on private land or lands of other jurisdiction adjacent to the Forest boundary.

Both species are winter annuals that are members of the sunflower family (Asteraceae) and native to Europe. A single yellow starthistle plant can produce up to 150,000 seeds and the species has become a significant pest in some areas of the West. It currently infests millions of acres in Oregon, Idaho, Washington and California. As the plant invades sites, it displaces native species, reduces plant diversity and contributes to accelerated soil erosion and surface runoff. Because of its highly invasive tendencies, yellow star thistle is a high priority to survey the National Forest and treat any plants that may be found.

Sweet resin bush and Pentzia: There are two populations of sweet resin bush in the Pinaleño EMA that cover approximately 100 acres. Much more extensive infestations occur on State land adjacent to the Forest on Frye Mesa. Additional, smaller populations are found in the Santa Catalina EMA in Sabino Canyon and Molino Basin. There is one population of Pentzia in the Pinaleño EMA as well as a mixed population of the two species in the Marijilda Creek area. These have been treated in the past using prescribed fire and hand-grubbing. A Weed Management Area has been established, of which the Coronado National Forest is a member. The Natural Resource Conservation Service (NRCS) is leading eradication efforts in the Safford area adjacent to the Forest boundary.

Sweet resin bush and Pentzia were introduced for erosion control and livestock forage during a period that began in 1935 (Pierson and McAuliffe 1995). These non-native plants were provided to Civilian Conservation Corps (CCC) work crews by the Soil Conservation Service (SCS) for use in erosion control projects and as landscaping for facilities on Forest Service land. The full extent of the infestation resulting from CCC projects is unknown, but there were as many as ten CCC camps and additional temporary spike camps on Coronado National Forest lands. CCC crews completed many erosion control and revegetation projects in the 1930s, and projects were located in most of the EMAs. Those completed after 1935 are likely to have resulted in the introduction of the sweet resin bush and pentzia, and possibly other species as well.

Canada thistle: There are small populations of Canada thistle at the Snowflat Campground, Hospital Flat, and Columbine Work Center in the Pinaleño EMA. These populations have been treated by grubbing with limited success, and are a high priority for further treatment.

Buffelgrass: This grass occurs in most canyons on the front range of the Santa Catalina EMA as well as in the Santa Rita EMA. It causes an unnatural buildup of fine fuel in the Sonoran desert ecosystem (Van Devender and Dimmitt 2000). The three populations in the Santa Rita EMA are fairly isolated and are a high priority for treatment.

Fountain grass: Fountain grass occurs along the Mt. Lemmon highway up to about 5,500 feet in elevation, in Sabino Canyon, and many other canyons on the front range of the Santa Catalina EMA. It is widely used as an ornamental grass and is spreading rapidly in the desert. There is also an isolated population in the Santa Rita EMA, which is a high priority for treatment.

Giant reed: This species occurs in the Van Horn exclosure in the Huachuca EMA and in Sabino and Bear Canyons on the front range of the Santa Catalina EMA. The Van Horn population is small and dense in the exclosure. The Sabino and Bear Canyon populations are more extensive but are currently restricted to the Canyon from the Forest boundary to Sabino Dam.

Salt cedar: There are scattered individuals of this species across the Forest. There are known populations in Robles Canyon and Bear Canyon (Santa Catalina EMA) and Stockton Pass Wash (Pinaleño EMA).

Johnson grass: Johnson grass occurs along most highways in southern Arizona. As such, it is a species that will easily spread to the Forest. There are several plants of

Johnson grass in the Falls exclosure in Redrock Canyon (Huachuca EMA). This exclosure protects an endangered native fish so the infestation of Johnson grass is a high priority for treatment.

Lehmann lovegrass: This species occurs throughout the Forest. In the past, Lehmann lovegrass was seeded in many areas to prevent erosion (Cox et. al. 1984). The grass has extended in range far beyond the seeded areas (Cox and Ruyle 1986). Well-established populations are not a high priority for treatment, but new or small populations should be treated.

African sumac: This exotic tree has been identified in Pontatoc Canyon in the Santa Catalina EMA; however, the species is spreading rapidly in the foothills adjacent to the Forest near Tucson. The species is widely used in the Sonoran desert as an ornamental tree.

This list does not include all of the species on the noxious weed lists for Arizona and New Mexico (Doc. 17), nor does it include all species that Forest users may consider a problem. It is the best information available on the species posing the most immediate threat to the Coronado National Forest. Species occurring in other areas adjacent to or near the Forest can also pose a threat. Russian knapweed, spotted knapweed, and dalmation toadflax are some that could easily infest the Forest from existing populations in southern Arizona and New Mexico. Additionally, roadways connecting the United States and Mexico create a situation of high risk for transport of invasive exotic plants.

There is no coordinated noxious weed management plan for the Forest at this time. This EA will describe how the Forest proposes to control populations of exotic invasive plants that exist on the Forest or populations that may be introduced in the future. This EA will provide the analysis needed to evaluate and disclose the environmental effects of invasive plant management on the Forest.

Desired Condition The following narrative was developed to describe the desired condition for the Forest at the end of 10-year term of the program:

Existing infestations of invasive exotic plants are eradicated or controlled through a coordinated Forest-wide approach to Integrated Vegetation Management. New populations are detected and treated as they become established. A Forest-wide approach is effective in controlling the spread of noxious weeds and invasive exotic plants, and is coordinated with the plans of other county, state and federal agencies. Treatment plans take into account the latest guidance regarding the protection of public health and ecosystem health well as the protection and recovery of federally-listed wildlife and plant species.

Proposed Action

To meet the purpose and need, the Coronado National Forest proposes to implement an Integrated Vegetation Management (IVM) approach to the control of invasive exotic plant species on the Forest. The purpose of the proposed action is to protect native plant communities on the Forest by preventing the introduction of invasive exotic plant species, eradicating invasive plant species where possible and by controlling the spread of established invasive plant species when eradication is not practicable. This action is needed because of the occurrence of invasive exotic plants on and adjacent to the Forest, and to meet the requirements of law, regulations and policy.

Integrated Vegetation Management is a decision-making and management process that uses a combination of expertise, treatment methods, monitoring, evaluation and education to achieve the following vegetation management goals (FSM 2080.2):

• Prevention of the introduction and establishment of invasive plant infestations.

• Containment and suppression of existing invasive plant and noxious weed infestations.

• Formal and informal cooperation with State agencies, landowners, weed control districts and boards and other Federal agencies in the management and control of invasive species.

• Education and awareness of employees, users of the Forest, adjacent landowners and State agencies about weed threats to native ecosystems.

The project area includes National Forest System lands in parts of Pinal, Pima, Santa Cruz, Cochise, and Graham Counties in southeastern Arizona and Hidalgo County in southwestern New Mexico on the Douglas, Nogales, Sierra Vista, Safford, and Santa Catalina Ranger Districts.

The proposed IVM approach would be divided into the four elements described below.

1. Treatment of existing populations Implement an integrated vegetation management strategy using cultural, mechanical, biological, or chemical methods of control.

• Cultural control methods involve reducing disturbance, planting, fertilizing or generally encouraging desired native vegetation to limit the encroachment of invasive species.

• Manual control methods involve hand pulling, hand grubbing, clipping and burning.

• Mechanical control methods involve mowing, tilling and other mechanized means of removing plants.

• Biological control methods involve the release of insects or plant pathogens that impact invasive species by reducing the ability of the invasive plant to dominate native plant communities.

• Chemical control methods involve treatment with herbicides that selectively kill invasive species while maintaining desired native vegetation. There will be no aerial application of herbicides.

Depending on the extent of the infestation and the feasibility of treatment, weed populations will be proposed for eradication, or containment and control. Tables 3 and 4 show the specific treatment proposals for those populations to be eradicated and for those to be controlled or contained. Known populations to be treated are identified on the attached maps 2 - 8.

Where chemical treatment is considered warranted, the following herbicides are proposed for use: 2,4-D, Chlorsulfuron, Clopyralid, Dicamba, Glyphosate, Imazapic, Imazapyr, Metsufuron, Picloram., Sulfometron methyl (Sufometuron), Triclopyr, Tebuthiuron.

Descriptions of each of these herbicides can be found in Appendix A.

Application of herbicides would be limited to spot treatment of individual plants or ground-based broadcast application on stands of weeds. Aerial application of herbicides is not being considered as an option for the IVM program.

The Regional Forester must approve all proposed herbicide uses on National Forest System lands. The Regional Forester may delegate this approval authority to other line officers on a case-by-case basis or by supplement to the Forest Service Manual (FSM 2151.04). Approval authority has not been delegated at this time (Doc. 74). Approval will be indicated by signing the Pesticide Use Proposal (PUP, Form FS-2100-2) as described under the Proposed Action (pp. 19-21, this EA). The approval of the use of herbicides in Wilderness Areas, Wilderness Study Areas or Research Natural Areas cannot be delegated. Any application of herbicides in these areas would require the approval of the Regional Forester on a case-by-case basis (FSH 2109.14 – Pesticide Use Management and Coordination Handbook).

2. Monitoring The effectiveness of control methods will be monitored annually for a minimum of 5 years following treatment. Additional treatments will occur as necessary. All known populations of invasive plants will be monitored at least every 3 years noting density and area of infestation. Weed inventories on the Forest will be continued in order to detect new populations of invasive plants before they become well established and widespread.

3. Restoration In areas where there are large concentrations of an invasive species, the area would be restored to native vegetation, if feasible, following treatment. Restoration efforts would mainly involve erosion control and the planting of native species. In those situations where conditions of the site, soils, competing vegetation or other factors make it unlikely that native species can be re-established in a timely manner, appropriate non-native, non-persistent species may be used for soil protection until native species can re-establish.

4. Prevention, coordination, cooperation and education Continue to follow noxious weed prevention practices and incorporate guidance put forth in The Guide to Noxious Weed Prevention Practices (Appendix C) in planning for any resource management activities.

Continue on-going cooperation efforts with other agencies and landowners, and encourage new cooperative efforts as appropriate, especially the establishment of Cooperative Weed Management Areas. Opportunities exist to partner effectively with groups such as the Pima Invasive Species Council, other private organizations and public agencies to enhance invasive species control across landscapes with a mixture of public and private ownership. These efforts should include lands of all ownerships and jurisdictions to ensure overall control.

Partner with the State of Arizona and the State of New Mexico Departments of Transportation to cooperate on control of invasive exotic species and ensure mulches and seed mixes are weed free, including coordination of this treatment plan with the on-going Region-wide plan for treatment of invasive exotic plants in highway rights-of-way.

Continue to develop and implement educational and public awareness materials.

Timely, site specific review of treatment areas will occur on the districts prior to control activities to ensure that impacts to rare plants, wildlife and cultural resources will not occur as a result of weed management activities. All herbicide application will be done in accordance with Environmental Protection Agency (EPA) label restrictions. If monitoring determines that treatment activities are ineffective and control beyond the scope of this analysis becomes necessary, further analysis under NEPA would be conducted.

Other actions may be taken to assure an integrated approach to control of invasive exotic plants. These will be analyzed in the context of the planned revision of the Forest Plan beginning in Fiscal Year 2004 and may include, but not be limited to the following:

• Expand the current policy regarding weed-free livestock feed in Wilderness Areas to the entire Forest.

• Require use of weed-free mulches and seed mixes Forest-wide. Use native plant species for all re-vegetation and stabilization work. If native species do not meet the objectives of the project, non-native species may be used but must be sterile seed stocks or non-invasive species.

Consistency with Forest Plan Goals and Objectives This action responds to the following goals and objectives outlined in the Coronado National Forest Land and Resource Management Plan (LRMP, pages 9-11).

• Maintain or enhance the visual resource through sound landscape management principles.

• Increase the public’s awareness of their obligation to the resource and their responsibility in caring for it.

• Establish a dialogue with the public to gain their understanding of our goals and objectives and insure their informed participation in our management decisions.

• Develop Information Service Programs that will educate, inform, and involve people of southern Arizona and southwest New Mexico in management and enjoyment of the forest.

• Provide habitat for wildlife populations consistent with the goals outlined in the Arizona and New Mexico Department of Game and Fish Comprehensive Plans and consistent with other resource values.

• Provide for ecosystem diversity by at least maintaining viable populations of native and desirable nonnative wildlife, fish and plant species through improved habitat management.

• Improve the habitat of and the protection for local populations of Threatened and Endangered Species to meet the goals of the Endangered Species Act of 1973.

• To restore rangeland to at least a moderately high ecological condition (70% to 75% of potential production, fair range condition) with stable soil and a static or upward trend.

• Provide a favorable water flow in quantity and quality for off-Forest users by improving or maintaining all watersheds to a satisfactory or higher level.

In addition, the following Forest-wide standards and guidelines and Management Area direction will be met:

• “Coordinate, where needed, animal damage and plant control on Forest Service administered lands with the US Fish and Wildlife Service and State wildlife and plant agencies (LRMP, page 31-1).”

• “Safeguard water, people, animals, pets and property in connection with use of pesticides and fire retardants…(LRMP, page 45).”

• Conform to Department of Agriculture standards in the use of all pesticides and promote development of acceptable alternatives for the use of pesticides (LRMP, page 45).”

• “Chemicals may be used within guidelines approved by other agencies for the following purposes…Herbicides to control invading plants that reduce herbaceous forage. Not all of the control would be done by use of herbicides. Depending on individual site circumstances, the control might be by mechanical means, prescribed fire, fuelwood harvest, herbicides, or some combination (LRMP, pages 45-46).”

• “Maintain horizontal and vertical plant diversity…(LRMP, pages 48, 51, 63).”

Consistency with Laws and Policies Noxious weeds and other invasive plant species have raised concerns about ecosystem health and economic impacts. These concerns have been translated into laws and policies relative to the management of our National Forests and Grasslands. The Federal Noxious Weed Act became law in 1974 and was updated in 1990 with the passage of the Food, Agriculture Conservation and Trade Act, commonly called the Farm Bill. The Farm Bill directed Federal agencies to coordinate with state and local governments to contain and control undesirable plant species by entering into Memorandums of Understanding and other agreements where appropriate. The Farm Bill also directed Federal agencies to develop policy direction, and Forest Service Manual 2080 was issued in November of 1995. In 1998, the Forest Service issued a National Strategy for weed management entitled “Stemming the Invasive Tide: Forest Service Strategy for Noxious and Nonnative Invasive Plant Management” (USDA Forest Service 1998). The President signed Executive Order 13112, addressing invasive species, in February 1999. This order directs federal agencies to prevent introduction and spread of invasive species, to cooperate with a newly created Invasive Species Council, and to produce and follow direction given in an Invasive Species Management Plan.

The Forest Service is also directed by Section 302(b) of the Federal Land Policy and Management Act of 1976 to “take any action necessary to prevent unnecessary or undue degradation of the [public] lands: (43 U.S.C. 1732). Supplementing this mandate is Section 2(b)(2) of the Public Rangelands Improvement Act of 1978 in which Congress reaffirms a national policy and commitment to “manage, maintain, and improve the condition of public rangelands” (43 U.S.C 1711). The regulations for implementing the National Forest Management Act of 1976 (36 CFR Part 219.27 a.3.) also provide direction for controlling noxious weeds.

The Federal Plant Protection Act and implementing regulations and policies, requires the Forest Service to cooperate with State, county, and other Federal agencies in the application and enforcement of all laws and regulations relating to management and control of noxious weeds. Forest Service policy in FSM 22.59.033 states: “Forest officers should place noxious weed management emphasis on those areas where cooperative efforts are underway, such as organized weed control districts. Within budgetary constraints, the Forest Service shall control, to the extent practical, noxious farm weeds on all National Forest System lands”.

The Wilderness Act (P.L. 88-577) mandates that wilderness be managed so its community of life is untrammeled by man, its primeval character is retained and its natural conditions are preserved. Forest Service policy direction is to maintain wilderness in such a manner that ecosystems are unaffected by human manipulation and influences so that plants and animals develop and respond to natural forces (FSM 2320.2). The Wilderness Act and its implementing regulations (36 CFR 293) do not preclude the use of herbicides in wilderness to maintain the natural ecosystem, and the Manual appears to anticipate such use by establishing approval standards at 2323.04c. In order to preserve natural conditions and processes in wilderness, it may become necessary to remove invasive exotic vegetation. Herbicides are a potential tool for controling invasive species and may represent the appropriate “minimum tool” for accomplishing this objective.

The proposed action is responsive to these laws and policies. Lack of action against invasive plant species is clearly a violation of these laws and policies.

Adaptive Management Strategy

The proposed invasive plant management program provides direction for noxious weed management activities on the Forest for the next 10 years using an adaptive management approach. Adaptive management is a strategy that allows decision makers to take advantage of new information as it becomes available after a decision has been made. In other words, during the life of this project, invasive plants are likely to be introduced to new locations by vehicles, heavy equipment, livestock, wildlife, recreationists and all the usual vectors of spread, and will be detected through monitoring. It is also likely that additional species of invasive plants not identified in Table 1 may be discovered on the Forest over the term of the project. The Forest would respond to these new infestations by completing a site specific review to determine impacts to proposed, threatened, endangered and sensitive plants, wildlife and fish, as well as heritage resources or plant species of significance to local tribes. New populations will be treated as they are found as long as the conditions of this analysis and decision are met. Likewise, if implementation monitoring demonstrates that herbicides being used are not effective, and a new or improved product is available, the new product could be considered for use. An analysis would be accomplished to determine whether the effects of new treatments are similar to effects disclosed herein. As long as the new treatment activity fits within the range of effects analyzed and disclosed in the original EA, no further NEPA analysis will be performed. If monitoring determines that control beyond the scope of this analysis becomes necessary, further analysis under NEPA would be conducted.

Decision Framework

Given the purpose and need, the Forest Supervisor of the Coronado National Forest will review the proposed action and the other alternatives in order to make the following decisions:

• Whether the proposed action would result in significant environmental effects that would require the preparation of an Environmental Impact Statement, or if there is a finding of no significant impact.

• If significant impacts are not anticipated, the Forest Supervisor will determine whether the proposed action will proceed as described above and in Chapter 2, as modified by an alternative, or not at all.

• If it proceeds, the Forest Supervisor will determine the mitigation measures and monitoring requirements to be implemented by the Forest Service, and whether the project requires a Forest Plan amendment.

Public Involvement

The proposal was first provided to the public and other agencies for comment in a Scoping Report on March 23, 2000 (Doc. 13). Comments from this original scoping are being retained and included in the current analysis (Docs. 11-16). A revised public scoping notice was sent to 330 individuals and organizations on July 5, 2002 (Doc. 46).

The proposal was posted on the Coronado National Forest internet site from July 2002 to May 2003. Approximately 18 comments were received (Docs. 48-65). Members of the interdisciplinary team attended a meeting of the Pima Invasive Species on August 13th, 2002. In addition, the agency has participated in the Euryops and Pentzia Weed Management Group since 1999 (Docs 3, 4 and 7).

In accordance with regulations at 36 CFR 215, a 30-day comment period was initiated on November 24, 2003 with the publication of a legal notice in the Arizona Daily Star and Tucson Citizen. The comment period ended on December 24, 2003. In addition to the legal notice, a detailed description of the proposed action was also sent to 55 individuals and groups and posted on the Forest’s web site. One response was received and the comments have been considered in developing the analysis (Doc. 73).

Issues

Using the comments from the public, tribes, organizations and other agencies, the interdisciplinary team developed a list of issues to address. The Forest Service separated the issues into two groups: significant and non-significant issues. Significant issues were defined as those directly or indirectly caused by implementing the proposed action. Non-significant issues were identified as those: 1) outside the scope of the proposed action; 2) already decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the decision to be made; or 4) conjectural and not supported by scientific or factual evidence. The Council on Environmental Quality (CEQ) NEPA regulations require this delineation in Sec. 1501.7, “…identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3)…” A list of non-significant issues and reasons regarding their categorization as non-significant may be found at Doc. 65 in the project record.

As for significant issues, the Forest Service identified the following issues during scoping:

Issue 1: Effects of the alternatives on non-target native vegetation, including threatened, endangered and sensitive species. Effects will be described in narrative and tabular form through a wildlife specialist’s report, biological assessment and evaluation and analysis of effects on management indicator species (MIS) and other wildlife, fish and plants. Mitigation measures have been included in the design of all action alternatives to minimize exposure to non-target species.

Issue 2: Effects of the alternatives on non-target terrestrial and aquatic wildlife, including threatened, endangered and sensitive species. Wildlife exposure risks have been evaluated in a number of risk assessments, including the Risk Assessment for Herbicide Use in Forest Service Regions 1, 2, 3, 4 and 10 and on the Bonneville Power Administration Sites (USFS 1992), which is incorporated herein by reference. Effects will be described in narrative and tabular form through a wildlife specialist’s report, biological assessment and evaluation and analysis of effects on management indicator species (MIS) and other wildlife, fish and plants. Mitigation measures have been included in the design of all action alternatives to minimize exposure to non-target species.

Issue 3: Effect of the alternatives on human health (public and workers). Human exposure risks have been evaluated in a number of risk assessments, including the Risk Assessment for Herbicide Use in Forest Service Regions 1, 2, 3, 4 and 10 and on the Bonneville Power Administration Sites (USFS 1992), which is incorporated herein by reference. The evaluation criteria for these effects are the risks to human health of herbicide use, the predicted location and size of area to be treated, preferred treatment method, and identification of areas where no chemical treatments would be used. Two alternatives (No Action and No Herbicides) are responsive to this issue.

Issue 4: Effects of the alternatives on soil and water quality and quantity.

Evaluation criteria used to analyze these effects are tabular and narrative specialists reports on water quality, soil quality, upland vegetation and riparian area condition.

Protections for surface and ground water quality are included in the action alternatives through prescribed mitigation measures and label restrictions for herbicide use.

Issue 5: Costs vs. benefits. The proposed action includes activities that will be subsidized by taxpayers. Evaluation criteria for this issue will be the relative costs of treatments for each alternative.

Issue 6. List of invasive species identified for treatment. Some respondents suggested additions to the list of species proposed for treatments, notably African sumac and red brome. Others pointed out that species such as Bufflegrass and Lehmann lovegrass have value for soil stabilization and should not be considered for control.

Issue 7. Vegetation treatments in wilderness. Some respondents suggested that by excluding the use of herbicides in wilderness areas the Forest would significantly decrease its chances of success at controlling invasive species. One respondent questioned the compatibility and legality of herbicide use within wilderness in response to the 30-day opportunity to comment.

Issue 8. Use interactions and prevention. The proposed action does not adequately provide for prevention of the spread of invasive exotic plant populations. The evaluation criteria for this issue will be locations of invasive exotic plants in relation to permitted activities on the Forest, and a review of existing guidelines for noxious weed prevention.

Issues and Concerns Addressed Through Project Design.

In response to the scoping comments, the proposed action was modified to address some of the issues identified. African sumac (Rhus lancea) was added to the list of species to be controlled. Two respondents suggested that red brome (Bromus madritensis ssp.

rubens) also be included. This aggressive, winter-spring growing exotic annual grass occurs at lower elevations on the Forest, but is…