United States Department of Agriculture
Invasive Plant Control Project Final Supplemental Environmental Impact Statement
Forest Service Carson and Santa Fe National Forests May 2018 MB-R3-10-26
For More Information Contact:
Sandra Imler-Jacquez, Forest NEPA Coordinator 11 Forest Lane, Santa Fe, NM 87508 (505) 438-5443 [email protected]
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Cover photo: Bull thistle (Cirsium vulgare). Photo courtesy of Forest & Kim Starr, Starr Environmental, Bugwood.org
Final Supplemental Environmental Impact Statement for the Invasive Plant Control Project Carson and Santa Fe National Forests Colfax, Los Alamos, Mora, Rio Arriba, San Miguel, Santa Fe, Sandoval, and Taos Counties, New Mexico
Lead Agency: USDA Forest Service
Responsible Officials: James Duran, Carson National Forest Supervisor 208 Cruz Alta Road, Taos, NM 87571 James E. Melonas, Santa Fe National Forest Supervisor 11 Forest Lane, Santa Fe, NM 87508
Abstract: This final supplemental environmental impact statement updates and corrects some analyses in the Forest Service’s Final Environmental Impact Statement (FEIS) for the Invasive Plant Control Project for the Carson and Santa Fe National Forests published in September 2005. It keeps the same purpose and need, proposed action, alternatives, adaptive strategy, and design features (also referred to as mitigation measures) as the final environmental impact statement. The following substantive updates are contained in this supplement: • The addition of aminopyralid as an herbicide proposed for use; • The acres and species of weeds in the forests; • The analysis of effects in chapter 3; and • The analysis of effects of the proposed amendment to the Santa Fe National Forest Plan. The pages in this supplement are intended to replace portions of the final environmental impact statement as noted in each section. If something is not addressed in this supplement, it means it was not updated. This final supplemental environmental impact statement and the draft record of decision are subject to objection pursuant to 36 CFR 218.8, Subparts A and B. For more information on how to comment/file objections see the project website at: http://www.fs.usda.gov/project/?project=27249 or contact Sandra Imler- Jacquez, project team leader, at 505-438-5443.
Contents
Summary of the Final Supplemental Environmental Impact Statement for the Invasive Plant Control Project .1 Introduction ...... 1 Purpose and Need for Action ...... 1 Public Involvement and Issues ...... 2 Proposed Action ...... 4 Alternatives Considered in Detail ...... 4 Forest Plan Amendment ...... 7 Environmental Consequences and Comparison of Alternatives ...... 8 Preface ...... 12 Notes on This Document ...... 12 Chapter 1. Purpose of and Need for Action ...... 13 Introduction and Setting ...... 13 Definition of Invasive Plant ...... 13 Purpose and Need for Action ...... 13 Background: Existing Condition ...... 15 Management Direction – Desired Condition ...... 21 Other Direction ...... 21 Proposed Action ...... 22 Decision-making Framework ...... 24 Public Involvement ...... 24 Issues ...... 26 Chapter 2. Alternatives, Including the Proposed Action...... 27 Introduction ...... 27 Alternatives Considered but Eliminated from Detailed Study ...... 27 Alternatives Considered in Detail ...... 27 Forest Plan Amendment ...... 38 Permits and Authorizations Required ...... 39 Comparison of Alternatives ...... 40 Chapter 3. Affected Environment and Environmental Consequences ...... 43 Introduction ...... 43 Cumulative Actions for Cumulative Effects Analysis ...... 43 Assumptions Common to the Analysis of Effects ...... 51 Vegetation ...... 52 Wildlife Resource ...... 66 Fish and Aquatic Resources ...... 97 Water Resources ...... 104 Soil ...... 115 Air Quality ...... 123 Heritage Resources ...... 130 Recreation and Wilderness ...... 132 Visual Resources ...... 143 Livestock Grazing...... 146 Social-Economic Resources ...... 153 Consistency with Forest Plan, Laws, and Policies ...... 171 Other Required Disclosures ...... 171 Preparers and Contributors ...... 173 Distribution of the Supplemental Environmental Impact Statement ...... 174 References ...... 175 Appendix 1. Past, Present, and Future Weed Control Activities ...... 185 Appendix 2. Weed Species Ecology and Impacts ...... 185
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Appendix 3. Herbicides: Characteristics, Effects, and Risk Assessments ...... 189 Program Description ...... 190 Application Methods ...... 190 Overall Conclusions ...... 190 Human Health Risk Assessment ...... 190 Factors Affecting Hazard of Herbicides...... 190 Wildlife Risk Assessment ...... 192 Aquatic Risk Assessments ...... 195 Specific Herbicide Characteristics and Environmental Effects ...... 195 Appendix 4. Effects of Non-Herbicide Weed Control Methods ...... 197 Appendix 5. Herbicide Model for Watershed Analysis...... 197 Appendix 6. Chemical Spill Prevention and Cleanup Plan ...... 197 Appendix 7. Weed Populations and Treatments ...... 197 Appendix 8. Implementation and Monitoring ...... 203 Appendix 9. Response to Comments on the Draft Environmental Impact Statement ...... 203 Appendix 10. Response to Comments on the Draft Supplemental Environmental Impact Statement ...... 203 NEPA ...... 203 Law, Regulation, Policy ...... 206 Best Available Science ...... 207 Public Involvement ...... 209 Proposed Action ...... 210 Alternatives ...... 215 Effect Analysis ...... 217 Wildlife ...... 221 Water Resources ...... 229 Health and Safety ...... 232 Index ...... 239
List of Tables Table S-1. Weed distribution by species ...... 2 Table S-2. Proposed amendment to the Santa Fe National Forest Plan (pp. 75-76; bold text is new language) . 8 Table S-3. Comparison of alternatives by issues and objectives (purpose and need) ...... 10 Table S-4. Weed species locations and impacts (shows the changes from the final environmental impact statement only) ...... 16 Table S-5. Weeds by landform type as of August 1, 2013 ...... 18 Table S-6. Weed species and their abundance in the project area as of August 1, 2013 ...... 20 Table S-7. Summary of treatments proposed for alternative B ...... 29 Table S-8. Summary of treatments proposed for alternative C ...... 30 Table S-9. Summary of treatments proposed for alternative D ...... 31 Table S-10. Additional treatment criteria and limitations ...... 31 Table S-11. Design features and monitoring requirements for all alternatives ...... 33 Table S-12. Proposed amendment to the Santa Fe National Forest Plan (pp. 75-76) ...... 39 Table S-13. Comparison of alternatives by issues and objectives (purpose and need) ...... 41 Table S-14. Past and present actions (1987-2013) contributing towards the cumulative effects baseline ...... 44 Table S-15. Reasonably foreseeable future actions (2015-2025) ...... 47 Table S-16. Summary of cumulative actions by key resource ...... 49 Table S-17. Weed infestations by vegetation type as of August 1, 2013 ...... 53 Table S-18. Acres of treatment method in in aspen ...... 57 Table S-19. Acres of treatment method in big sagebrush ...... 57 Table S-20. Acres of treatment method in blue grama ...... 57 Table S-21. Acres of treatment method in deciduous shrub mix ...... 57 Table S-22. Acres of treatment method in juniper ...... 58
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Table S-23. Acres of treatment method in perennial grass mix ...... 58 Table S-24. Acres of treatment method in piñon-juniper ...... 58 Table S-25. Acres of treatment method in ponderosa pine ...... 58 Table S-26. Acres of treatment method in sparsely vegetated areas ...... 59 Table S-27. Acres of treatment method in spruce-fir ...... 59 Table S-28. Acres of treatment method in upper deciduous-evergreen forest ...... 59 Table S-29. Acres of treatment method in upper forb mix ...... 59 Table S-30. Threatened or endangered plant species ...... 63 Table S-31. Forest Service Southwestern Region regional forester’s sensitive plant species, 2013, on the Santa Fe (SF) and Carson (C) National Forests ...... 64 Table S-32. Wildlife management indicator species, habitat, and weed infestation ...... 71 Table S-33. Effects to management indicator species ...... 75 Table S-34. Threatened or endangered wildlife species ...... 79 Table S-35. Effects to, and determinations for, threatened or endangered species ...... 82 Table S-36. Sensitive species, amphibians ...... 84 Table S-37. Sensitive species, birds ...... 84 Table S-38. Sensitive species, mammals ...... 85 Table S-39. Sensitive species, snail ...... 86 Table S-40. Sensitive species: Effects to amphibians ...... 87 Table S-41. Sensitive species: Effects to birds ...... 87 Table S-42. Sensitive species: Effects to mammals ...... 89 Table S-43. Sensitive species: Effects to snail ...... 91 Table S-44. Highest priority migratory birds and habitats used ...... 93 Table S-45. Effects to migratory birds and habitats ...... 94 Table S-46. Sensitive aquatic species found on the Carson and Santa Fe National Forests and occupied or suitable habitats ...... 98 Table S-47. Environmental consequences and determinations for fish and aquatic species ...... 100 Table S-48. Watersheds on, or intersecting, the forests and the acreage of weeds on National Forest System lands ...... 106 Table S-49. Characteristics of representative watersheds ...... 108 Table S-50. Impaired waterbodies in representative watersheds 2012-2014 ...... 109 Table S-51. Weed acres by erosion hazard class ...... 116 Table S-52. Weed acres by revegetation potential class ...... 116 Table S-53. Characteristics of herbicides in soil ...... 121 Table S-54. National ambient air quality standards for criteria pollutants of concern. (New Mexico standards are the same as the national standards) ...... 124 Table S-55. Affected heritage resource sites ...... 131 Table S-56. Recreational visits to the Carson and Santa Fe National Forests ...... 134 Table S-57. Cumulative effects to recreation and wilderness resources ...... 142 Table S-58. Cumulative effects of action alternatives to visual quality...... 146 Table S-59. Grazing allotments with known weed infestations on the Carson National Forest ...... 147 Table S-60. Grazing allotments with known weed infestations on the Santa Fe National Forest ...... 148 Table S-61. Wild horse territories ...... 151 Table S-62. Ethnicity and race at the county scale (all figures are percentages) ...... 154 Table S-63. Percent of population below the Federal poverty level by county (all figures are percentages) ..155 Table S-64. Comparison of the toxicity of herbicides proposed for use ...... 160 Table S-65. Cumulative effects to human health and safety ...... 166 Table S-66. Present net value (rounded to nearest dollar) of the alternatives ...... 170 Table S-67. Risk assessments ...... 189 Table S-68. Herbicide use program description ...... 190 Table S-69. Herbicides formulations, application rates, target plants ...... 190 Table S-70. Herbicide risk assessment standard terminology ...... 190
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Table S-71. Herbicide characteristics ...... 190 Table S-72. Exposure risk of herbicides ...... 192 Table S-73. Relative risk of each herbicide ...... 193 Table S-74. Effects of each herbicide ...... 194 Table S-75. Level of Concern for Chemical Use Using the Risk Quotient Method ...... 195 Table S-76. Herbicide formulations, impurities, other ingredients ...... 196 Table S-77. Summary of treatments for the action alternatives ...... 200
List of Figures Figure S-1. An illustrative concept of the definition of an invasive plant, or “weed” ...... 13 Figure S-2. Weed distribution in the project area, August 1, 2013 ...... 19 Figure S-3. Dominant vegetation types on the Carson and Santa Fe National Forests ...... 55 Figure S-4. Locations of weeds in valley bottoms and riparian areas on the Carson and Santa Fe National Forests, August 1, 2013 ...... 105 Figure S-5. Areas of slight, moderate, and severe erosion hazard on the Carson and Santa Fe National Forests ...... 117 Figure S-6. Areas of revegetation potential (ranging from poor to high) on the Carson and Santa Fe National Forests ...... 118 Figure S-7. PM10 24-hr maximum values in Taos and Santa Fe with 3-year moving average (micrograms per cubic meter) ...... 125 Figure S-8. PM2.5 24-hr values for 98th percentile weather conditions in Taos and Santa Fe with 3-year moving average (micrograms per cubic meter) ...... 125 Figure S-9. PM2.5 annual mean values in Taos and Santa Fe with 3-year moving average (micrograms per cubic meter) ...... 126 Figure S-10. Visibility conditions on worst 20 percent visibility days for San Pedro Parks Wilderness and glide path to 2064 goal ...... 127 Figure S-11. Visibility conditions on worst 20 percent visibility days for Bandelier National Park and glide path to 2064 goal ...... 128 Figure S-12. Weeds located near recreation sites, August 1, 2013 ...... 136 Figure S-13. Locations of weeds in wilderness areas, August 1, 2013 ...... 137
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Summary of the Final Supplemental Environmental Impact Statement for the Invasive Plant Control Project Introduction In northern New Mexico’s Carson and Santa Fe National Forests, more than 13,260 acres of invasive nonnative plant populations (weeds) inhabit National Forest System lands. Although this amount represents about 0.5 percent of the 3 million acres managed by these two national forests, weed treatments are most effective when infested areas are still small and before weeds are well established. It is important to control weed infestations at an early stage, before costly large-scale treatments such as aerial herbicide spraying become necessary.
This supplement summarizes the “Final Supplemental Environmental Impact Statement for the Invasive Weed Control Project.” It provides an overview of the purpose and need for the project, proposed action, the public involvement to date, issue and alternative development, and a summary of the expected effects of alternatives on the human environment.
The pages in this supplement replace portions of the final environmental impact statement as noted in each section. Editorial notes are provided in bracketed, bold text. If something is not addressed or written in this supplement, it means it was not updated and the text in the 2005 final environmental impact statement is still valid. This final supplemental environmental impact statement is best read in conjunction with the final environmental impact statement. The 2005 final environmental impact statement has been posted on the two national forests’ websites: the Carson National Forest website and Santa Fe National Forest website. Purpose and Need for Action The purpose of, and need for, controlling or eradicating weed infestations on the Carson and Santa Fe National Forests is to maintain or improve the diversity, function, and sustainability of desired native plant communities on the Carson and Santa Fe National Forests. Protecting the abundance and diversity of native plant communities will also help maintain or enhance other natural resources that can be impacted by weeds and the loss of desired plant communities. Weeds are aggressive, undesirable plants that are a serious threat to the forests. Weeds typically outcompete native plants for space, water, and nutrients because they have characteristics that give them a competitive advantage over native plant species. They demonstrate high reproductive capacity through prolific seed production and root sprouting. If left uncontrolled, they tend to dominate areas and reduce the diversity and sustainability of native plant populations. In some areas, weeds have increased so dramatically they create a monoculture by entirely taking over large areas.
Without effective control, weeds will increasingly impact natural resources on the Carson and Santa Fe National Forests in the following ways:
• Native plant communities will become more impacted as weeds gradually dominate these communities. Some weed species form monocultures or greatly simplified ecosystems. Ecosystem processes become degraded, with evidence of slower nutrient cycling and lower hydrological stability. They prove less sustainable when confronted with natural disturbances such as fire. Weeds also threaten the continued existence of certain endangered, sensitive, or rare plant species that occur on the two national forests. • Erosion is increased by many weed species. Knapweeds and other weeds have a single, deep taproot and outcompete native grasses that have better soil-holding root systems. Native riparian plants, including rushes, sedges, willows, and cottonwoods, maintain streambank stability better than the weed species currently spreading through the riparian zones on the Carson and Santa Fe National Forests.
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• Wildlife habitat quality decreases when weeds take over native plant communities. Palatable forage for game and nongame species of wildlife decreases as weeds like thistle, leafy spurge, and toadflax take over. Weeds such as black henbane, poison hemlock, and yellow starthistle can poison animals. Negative impacts to wildlife magnify in riparian areas because of the important role riparian vegetation plays for a large number of southwestern wildlife species. A large percentage of the known weed infestations occur in or near riparian areas. • Recreation opportunities are lessened when dense weed infestations limit access to streams and riparian areas. Some weeds cause allergies or skin irritations. Scenic values and wilderness characteristics also typically decline as weeds reduce the abundance and diversity of native plant communities. • Wildland fires are known to burn more intensely and severely in areas where weed species like saltcedar, Siberian elm, and Russian olive have taken over native riparian ecosystems. • The majority of known weed infestations (approximately 13,260 acres) occurs within 150 feet of roads or trails. In terms of current weed species distribution, the most dominant weed species are the nonnative thistles, followed by the valley bottom species of saltcedar, Siberian elm, and Russian olive. Table S-1 shows the weed species distribution by percent of inventoried weed infestations.
Table S-1. Weed distribution by species Species Acres Percent Thistles 13,731 70.8 Trees 4,396 22.7 Knapweed 951 4.9 Toadflax 65 0.3 Grasses 131 0.7 Others 118 0.6
Public Involvement and Issues Collaboration and Scoping In 1996 and 1997, the Forest Service met informally with other Federal, State, and County agencies to discuss the threat of weeds and coordinate treatments. In 1998, the Forest Service began scoping for this project, starting with public meetings held in Taos and Espanola. In March 2000, a letter was sent to approximately 450 individuals, agencies, Tribes, and organized groups to inform them about the Forest Service’s weed control treatment proposals. At that time, each national forest was independently working on separate environmental assessments for forestwide weed control projects. As a result of the March 2000 scoping, a decision was made to combine the efforts of the two national forests and document the analysis in an environmental impact statement. In December 2000, the Forest Service sent a new letter to the public about the proposed action. On December 15, 2000, the Forest Service published a notice of intent to prepare an environmental impact statement in the Federal Register.
The Forest Service first contacted Tribal governments about treating weeds in 1999. The Carson and Santa Fe National Forests included the Tribal governments in their March and December 2000 scoping efforts. In December 2003, the Forest Service sent another letter to all potentially affected Tribal governments to initiate consultation and solicit their comments about the proposed project.
Issues were identified from the comments received during scoping. The treatment that appeared to be of greatest concern to those who commented was the use of herbicides. Most opposition was based on concerns
2 Final Supplemental Environmental Impact Statement
that herbicides could adversely impact human health, non-target plants, and wildlife. Concerns over the impact to water quality and fish were also mentioned. On the other hand, others were concerned that non- herbicidal methods would be less effective and weeds would spread faster than they could be controlled.
Public Comment on the Draft Environmental Impact Statement On July 16, 2004, the Forest Service published a notice of availability of the draft environmental impact statement in the Federal Register. The legal notices announcing the start of the 45-day comment period were published in the newspapers of record on July 22, 2004. The Forest Service received 106 letters on the draft environmental impact statement; of these, 7 were received after the end of the comment period, which was August 30, 2004.
The Forest Service’s interdisciplinary team identified approximately 750 individual comments contained in the letters. As with scoping, the use of herbicides continued to be a main concern among members of the public. In response, the final environmental impact statement clarified and expanded its discussion of the risks associated with the use of herbicides (see appendix 3 of the final environmental impact statement). Appendix 9 of the final environmental impact statement responds to comments received on the draft environmental impact statement. Other relevant comments were incorporated into the final environmental impact statement.
Appeal of the Record of Decision On September 12, 2005, the Carson and Santa Fe National Forest Supervisors signed a record of decision selecting alternative B. The Forests published a notice of availability of the final environmental impact statement and record of decision in the Federal Register on November 18, 2005. The legal notices announcing the start of the 45-day appeal period were published in the newspapers of record on November 23, 2005. Eight appeals of the record of decision were submitted. The Forest Service met with the appellants but was unable to resolve the issues stated. The Deputy Regional Forester reversed the decision on February 23, 2006.
Draft Supplemental Environmental Impact Statement The Forest Service prepared a draft supplemental environmental impact statement to correct the deficiencies identified by the Deputy Regional Forester and to update the analysis and facts where needed pursuant to 40 CFR 1502.9(c)(1). In accordance with the Council of Environmental Quality (CEQ) regulations at §1502.9(c)(4), the draft SEIS was “prepare(d), circulate(d), and file(d) … in the same fashion (exclusive of scoping) as a draft and final statement.” The project was not re-scoped, but the public had the opportunity to comment before a final decision was made.
In February 2012, the Forest Service sent postcards to 274 people and organizations anticipating the draft supplemental environmental impact statement would be published that spring, and asking them how they would like to be notified. Seventeen responses were received.
On March 21, 2014, the Forest Service published a notice of availability of the draft supplemental environmental impact statement in the Federal Register. The legal notices announcing the start of the 45-day comment period were published in the newspapers of record on March 24, 2014. The Forest Service received 33 letters on the draft supplemental environmental impact statement.
The Forest Service’s interdisciplinary team identified approximately 75 individual comments contained in the letters. The use of herbicides continued to be a main concern among members of the public. Appendix 10 of the final supplemental environmental impact statement responds to comments received on the draft supplemental environmental impact statement. The Forest Service has published regulations that institute an objection process in lieu of the appeal process. This project and its decision fall under the objection process (36 CFR 218).
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Proposed Action The proposed action is an integrated set of management actions considered necessary to control weeds on the Carson and Santa Fe National Forests with the goal of completely eliminating them or at least preventing their spread. Under policy stated in Forest Service Manual 2903, invasive weeds and other invasive species in aquatic and terrestrial areas of the National Forest System are to be managed by using an integrated pest management approach. The integrated pest management approach recognizes that using only one treatment method is unlikely to be effective. Treatment methods used in conjunction with integrated pest management involve four broad categories:
1. Mechanical/Physical (mowing, prescribed burning, etc.), 2. Cultural (re-seeding, fertilizing, etc.), 3. Biological (grazing, use of biocontrol agents, etc.), and 4. Chemical (use of herbicides). Weeds proposed for treatment are those on the New Mexico Department of Agriculture’s noxious weeds list at the time of this writing or in the future. As of this writing, 21 of the 37 listed weeds are known to occur in the Carson and Santa Fe National Forests, and 5 have the potential to occur. The two national forests do not intend to treat medicinal plant species such as St. John’s wort (Hypericum perforatum) and wild licorice (Glycyrrhiza lepidota).
Weed treatments would begin in 2017. During approximately the next 10 years, each national forest anticipates treating 300 to 800 acres per year, based on anticipated funding. The maximum acreage treated per year, given sufficient funding, would be 3,000 acres (1,500 acres on each forest). The implementation period could extend beyond 10 years if monitoring shows treatment results are within expected outcomes.
To treat weeds on the State’s noxious weed list, the following treatment methods are proposed:
• Hand pulling, grubbing with hand tools or hand operated power tools, mowing and disking, girdling, or plowing with tractor-mounted implements; • Biological control using insects or plant pathogens introduced into the weed habitat; • Controlled grazing using goats and sheep to intensively and repeatedly graze weeds; • Herbicide application using hand or vehicle-mounted sprayer applications; and • Prescribed burning using limited pile or broadcast burning to eliminate seed heads and resident populations of weeds. Reseeding or replanting after the initial treatment would follow in some situations, since this has been shown to increase the effectiveness of controlling weeds (Endress et al. 2012).
The scope of the proposal includes treatments to existing weed infestations, as well as an adaptive strategy for responding to infestations not yet discovered or established. The adaptive strategy would evaluate new weed populations and allow immediate treatment, if the effects fall within parameters described in this final supplemental environmental impact statement. Failure to deal immediately with these new—usually small— infestations is likely to lead to larger scale treatments with greater impacts later. Alternatives Considered in Detail This section summarizes the four alternatives considered in detail in the final supplemental environmental impact statement, the adaptive management strategy, treatment objectives and decision criteria, mitigation and monitoring requirements, and the forest plan amendment.
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Alternative A–No Action. This is the baseline for comparing the other alternatives and is the alternative where proposed weed control actions would not occur on the two national forests.
Alternative B–Proposed Action. This is the agency’s proposed action as previously described, developed to fully meet the purpose and need for action while minimizing the risk of adverse impacts through design features and monitoring requirements.
Alternative C–No Herbicides. This alternative eliminates herbicide use and was developed in response to public concerns raised about potential effects of herbicides on human health, fish, wildlife, and non- target native vegetation.
Alternative D–Herbicides Only. This alternative exclusively relies on herbicides and was developed in response to the cost effectiveness issue associated with proposed non-herbicide treatments.
Adaptive Strategy The action alternatives (alternatives B, C, and D) employ an adaptive strategy. Using this adaptive strategy, weed treatments would be monitored, evaluated, and modified as necessary to improve effectiveness of future treatments or reduce the potential for adverse effects to people and natural resources. This strategy also allows for applying the same weed control treatments to new weed infestations as long as the actions and effects (including decision-making criteria and limitations on treatments) are within the scope of the environmental impact statement and record of decision.
The adaptive strategy would cover weeds found in newly surveyed areas, newly established populations, or weeds newly listed as noxious by the State of New Mexico in the two national forests. The Carson and Santa Fe National Forests propose an adaptive strategy with the following actions: • Annually inventory portions of the two national forests that are likely to have new infestations (for example, areas burned by wildfires or recently disturbed) and map them. Budgets will govern the extent of these inventories. • Identify the weed treatment objective, priority, and methods to use for newly mapped infestations, based on the specific criteria described in the environmental impact statement. • Monitor the effectiveness and effects of weed treatment activities and associated design features. • Evaluate and disclose monitoring results, and use those results to determine appropriate modifications in treatment prescriptions, design features, or implementation practices. • Implement modifications or other feasible and appropriate treatment methods based on monitoring results, as long as the action and its effects are considered by an interdisciplinary team and determined by the responsible official to be within the scope of actions and effects evaluated in the environmental impact statement (in accordance with Forest Service Handbook 1909.15, Sec. 18).
Treatment Objectives and Decision Criteria Specific treatment objectives for a given weed species fall into one of the following categories:
• Eradication • Containment (preventing small populations from expanding once eradication is no longer feasible) • Control (reducing or maintaining large populations over time) Treating every weed infestation within 1 to 2 years is beyond the budget and personnel resources of the two national forests. Therefore, a system for setting priorities is proposed so treatment concentrates on invasive species that have the greatest impact on the resource base, and those invasive plants that become more
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difficult to control if action is delayed. Weeds become much more difficult to control once they have spread. Thus, the highest priority is to eradicate new species occurrences on the two national forests and then to keep existing populations from spreading or increasing in size.
In addition, new weed infestations found in the following locations would be considered for an elevated priority ranking:
• Areas that are now relatively weed free and have little or no road access, such as areas designated as wilderness, roadless recreation or semi primitive, or nonmotorized, including the road corridors and trails that lead to those areas. • Areas that are now relatively weed free and provide unique and desirable wildlife habitat, such as recovery habitat for threatened or endangered species, deer and elk winter range; and riparian habitat. • Areas on the two national forests with weed populations adjacent to other land ownerships where land managers have active weed control programs. • Areas of high human use, including, but not limited to, administrative sites, developed recreation sites such as campgrounds, scenic viewpoints, interpretive sites, and trailheads.
Schedules for implementing weed treatments would be based first on the priorities just described and spread out over time based on levels of funding and staffing on the two national forests.
Selection of various treatment methods may be based on treatment objectives for a particular site and by factors such as proximity to water or roads (which increases chance of weed spread) and the size of the weed infestation (small infestations are easier to eradicate). For the greatest likelihood of success, flexibility in treatment methods is needed to address differences in site-specific conditions. In particular, selection of treatment methods may take into consideration local resources of special concern:
• Areas of high human use such as a recreation site, administrative site, or area where people often collect plants. • Areas with a shallow water table (less than 6 feet deep) and soil with a high permeability rate, where there may be a risk of an herbicide leaching through the soil to the groundwater. • Riparian areas or areas next to live water bodies containing aquatic species. • Presence or proximity of threatened, endangered, or sensitive plant species. • Presence or proximity of threatened, endangered, or sensitive wildlife species. • Wilderness and designated nonmotorized areas.
Mitigation and Monitoring This final supplemental environmental impact statement lists design features and monitoring requirements for all action alternatives. The mitigations were developed specifically for this project in order to avoid or minimize the risk of adverse impacts to human health and safety; native plants; special status plants or wildlife; air, soil, water, riparian and aquatic resources; and heritage resources. The bullets that follow summarize design features that are described in more detail in the final supplemental environmental impact statement.
• Human Health/Safety and General Mitigations: These govern herbicide application and use, public notification, traffic control, and other protection measures. • Native Vegetation and Treatment Effectiveness: These direct the treatments so they have a minimal impact on native vegetation. They include cleaning equipment, revegetation (or mulching as appropriate), and use of proper seed to revegetate.
6 Final Supplemental Environmental Impact Statement
• Threatened, Endangered, and Sensitive Plants: These require survey and/or avoidance of occupied habitat. For Holy Ghost ipomopsis (Ipomopsis sancti-spiritu), buffers apply to treatments such as grazing, mowing, and prescribed burning. For spot applications, herbicide use is prohibited within, and for 25 feet around, Holy Ghost ipomopsis plants and occupied habitat. • Wildlife, including Threatened, Endangered, and Sensitive Species: Depending on the level of protection required by law, regulation, and policy, these measures require surveys, avoidance, or both and use of seasonal restrictions to reduce impacts during breeding periods. For example, managed grazing with sheep or goats is prohibited in Rocky Mountain bighorn sheep habitat. • Air, Soil, Water, Riparian, and Aquatic Resources: These measures restrict some treatments in certain places, such as slope restrictions for mechanical treatments and herbicide use restrictions near water. Although some herbicides may be permitted near water if registered for such use by the Environmental Protection Agency, no direct application of herbicide to water is permitted as part of this project in order to avoid impacts to native fish. Procedural restrictions also apply. These include complying with smoke management for prescribed burns and evaluating watersheds for total herbicide use before proceeding. Potential for accidental spills of herbicides, gasoline, or other chemicals associated with treatments would be minimized by restrictions on where these chemicals can be handled. Spill prevention and cleanup plans and other established procedures also help reduce the impacts to soil, water, and aquatic resources. • Heritage Resources: A programmatic agreement exists to ensure that heritage resources would be protected in accordance with applicable law, regulation, and policy. The programmatic agreement spells out the requirements for conducting heritage resource inventories and evaluations for this project prior to implementation. It requires development of appropriate design features to avoid adverse impacts to heritage resources. • Monitoring and Adaptive Management: Inventory and mapping of weeds will be conducted annually. Newly found weed populations will be identified and prioritized for treatment. Treatments will be monitored for effectiveness and effects to other resources. If the treatments initially prescribed in the environmental impact statement are not effectively meeting the given treatment objective, another method may be used as long as the action and effects are within the scope of effects considered in the environmental impact statement. The evaluation and decision by the responsible official regarding consistency with the environmental impact statement will be documented in the project record. Forest Plan Amendment Alternatives B and D include a nonsignificant, programmatic amendment to the Santa Fe National Forest Plan. The amendment would allow the use of herbicides in places currently prohibited by forest plan standards and guidelines. These areas are in municipal watersheds and on soils with low revegetation potential. No amendment is proposed for the Carson National Forest Plan because it does not prohibit the use of herbicides in any specific areas.
To meet the purpose and need for this project and protect ecosystem diversity and sustainability in the long term, it may be necessary to occasionally apply herbicides within those areas if they are infested with weed populations that cannot be effectively treated with other methods. The proposed amendment would continue to protect municipal watersheds, soil productivity, and human health and safety. For instance, soil erosion rates would still be required to remain within tolerance levels based on the terrestrial ecosystem survey data, in order to maintain long-term soil productivity. Table S-2 shows the specific language changes in forest plan direction.
7 Invasive Plant Control Project
Table S-2. Proposed amendment to the Santa Fe National Forest Plan (pp. 75-76; bold text is new language) Existing Forest Plan Direction Proposed Forest Plan Direction 5. Chemical treatments may be applied: 5. Chemical treatments may be applied: a. when determined through an a. when determined through an environmental analysis to environmental analysis to be have no adverse environmental, economic, or social environmentally, economically, and socially impacts for longer than 6 months. acceptable. b. on areas outside municipal watersheds b. within municipal watersheds only when the and human habitation. municipality concurs with the proposed treatment and design features. c. on soils with moderate or high c. on any soil provided that soil erosion on that site is revegetation potential. not increased to above the tolerance level identified in the terrestrial ecosystem survey for the affected soil unit. d. on areas that would benefit from d. on areas that would benefit from selective control of selective control of plant species. plant species. e. on areas where the chemicals will not e. on areas where the chemicals will not violate State violate State water quality standards. water quality standards. f. on soils with moderate to high cation f. In areas of human habitation: exchange capacity. • Apply this adaptive strategy identified in the EIS in table S-10: Method(s) must have been documented to be low risk of causing harm to people. • Apply the design features listed in the EIS in table S-11 under “Human Health/Safety and General Mitigations.” g. on piñon-juniper retreatment areas on g. on piñon-juniper retreatment areas on stands where 80 stands where 80 percent of the trees are percent of the trees are less than 6 feet in height, with less than 6 feet in height, with more than 25 more than 25 trees per acre. trees per acre.
Environmental Consequences and Comparison of Alternatives This section provides a comparative summary of the alternatives in terms of the most significant issues or effects anticipated, based on the analysis in the environmental impact statement.
Summary of Environmental Consequences The most noticeable consequences from weed treatment alternatives B, C, and D would be the long-term beneficial improvements to native ground vegetation such as grasses, forbs, and shrubs. Riparian vegetation such as rushes, sedges, willows, and cottonwoods would particularly benefit from this project. Protecting and improving native plant communities would have positive effects on soil and water conditions, as well as wildlife and aquatic habitats (particularly due to enhancing riparian vegetation).
Negative effects to native vegetation, soil, water, wildlife, and aquatic organisms would be minor and of short duration. The minor, short-term increases in sediment (more with alternative C) and herbicide delivery to streams (alternatives B and D) would have no significant consequences. There would be a low risk of adverse impacts to fisheries, including Rio Grande cutthroat trout (a sensitive fish species) or other aquatic organisms based on use of design features, risk assessments, and Environmental Protection Agency guidelines. Alternative C would cause more ground disturbance and associated impacts to soils, especially those with a severe erosion hazard rating. However, all alternatives would remain within soil erosion tolerance levels needed to protect long-term soil productivity. Soils with low revegetation potential would receive herbicide treatments under alternatives B and D. Reestablishing native vegetation could take longer under alternative C due to soil disturbance and germination of weed seed from the seed bank. Mitigation requirements for all
8 Final Supplemental Environmental Impact Statement alternatives would ensure that vegetative ground cover is adequately reestablished. With the required design features, all soil and water quality standards would be met.
Differences between alternatives in their effects to air quality, heritage resources, livestock grazing, recreation, wilderness, and visual resources are expected to be negligible, such that they would not be given weight in the decision-making process. There would be minor increases in noise and traffic, although generally within background levels.
By controlling the spread of weeds and protecting native plant communities, habitats, and watershed conditions on the two national forests, alternatives B and D would maintain or enhance social or economic conditions, particularly for local rural communities in northern New Mexico who typically rely on the two national forests’ natural resources for their livelihood, traditional culture, and quality of life.
Comparison of Alternatives The alternatives are compared in terms of the significant issues and how well they meet the purpose and need (objectives) for the project. Table S-3 provides the comparison of alternatives, based on the detailed environmental analysis documented in the final environmental impact statement. The comparison table provides a basis for choice between alternatives.
9 Invasive Plant Control Project Table S-3. Comparison of alternatives by issues and objectives (purpose and need) Significant Issues and Objectives Alternative A Alternative B Alternative C Alternative D Issue 1: Herbicides No risk of health impacts from Low risk of health impacts to No risk of health impacts from Same as alternative B but and Human Health herbicide exposure (0 acres workers or general public from herbicide exposure (0 acres slightly higher risk of exposure treated with herbicides). using herbicides based on treated with herbicides). for people with chemical Environmental Protection Slightly increased risk of sensitivities as 100 percent of Agency registration, risk exposure to smoke from treatments are with herbicides. assessment data, and design prescribed burning. features. Higher risk to people with multiple chemical sensitivities, although public notification requirement provides a means for people with this condition to avoid exposure to treated areas. Issue 2: Herbicides No risk of herbicide impacts to Low risk of herbicide impacts to No risk of herbicide impacts Same as alternative B and Wildlife wildlife. Weeds would degrade wildlife based on Environmental to wildlife. Less improvement native plant habitats, especially Protection Agency registration, in wildlife habitat. riparian areas important to risk assessments, and design numerous species. features. Native wildlife habitat quality (especially riparian habitat) would improve as weeds are eradicated and controlled. Issue 3: Herbicides No short-term impacts from Short-term reduction in some Similar to alternative B for Same as alternative B and Native Plant herbicides. In the long term, non-target plant species. Long- short-term reduction in non- Communities weed-caused decline in term improvement in abundance target plants. Low to abundance and diversity of and diversity of native plant moderate long-term native plant communities. communities. improvement in native plant communities. Weed spread rate may equal or exceed control rate without herbicide use. Issue 3 Continued: No risk of treatment-related No impact to threatened or Same as alternative B Same as alternative B Rare or Sensitive impacts. In the long term, endangered plants due to Native Plant Species weeds may cause a decline in mitigation measure. For federally listed or sensitive sensitive plants, treatments “may plant species. impact individuals but are not likely to result in a trend toward Federal listing or loss of population viability,” due to design features and species locations.
10 Final Supplemental Environmental Impact Statement Significant Issues and Objectives Alternative A Alternative B Alternative C Alternative D Issue 4: Cost and No cost effectiveness; would Moderately cost effective. Least cost effective. Most cost effective. Treatment incur much higher costs in Effectiveness (based future. on level of effort to meet objectives) Objectives: Protect No protection; no Highest level of treatment Lowest level of effectiveness High level of effectiveness and native plant effectiveness. Weed-related effectiveness and resource and resource protection from resource protection from weed communities, soil impacts to vegetation, soil, protection from weed impacts weed impacts. Fewer acres impacts. Not quite as effective and water quality, water, riparian habitat, etc. due to combination of treatments treated annually for a given as herbicides combined with wildlife habitat, and would continue. including herbicides. budget due to need for repeat other methods. long-term ecosystem treatments on the same health acreage more often than when combined with other methods.
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Preface Notes on This Document • The pages in this supplement replace portions of the final environmental impact statement as noted in each section. Editorial notes are provided in bracketed, bold text. If something is not addressed or written in this supplement, it means it has not been updated and the text in the 2005 final environmental impact statement is still valid. This final supplemental environmental impact statement is best read in conjunction with the final environmental impact statement. The 2005 final environmental impact statement has been posted on the two national forests’ websites: Carson National Forest website Santa Fe National Forest website
• Tables and figure numbers are preceded by “S-.” Where a table or figure replaces one from the final environmental impact statement, it is noted. • A limited number of paper copies of the final environmental impact statement and final supplemental environmental impact statement are available from the Carson and Santa Fe National Forests. • Throughout this document, the term used for invasive plants will be “weeds.” • “Design features” and “mitigation measures” are used interchangeably. • This document contains revised acreage numbers. When consulting the final environmental impact statement, refer to this document for the correct acreages. • The risk assessments for certain herbicides have been updated; they replace or complement the earlier risk assessments. Any references to the risk assessments now include those listed in appendix 3 (Syracuse Environmental Research Associates, Inc. (SERA) 2003a–2007). • Most resource specialists wrote their section directly into this document; thus, separate, updated specialist reports exist only for heritage resources and for social and economic resources. The information in this final supplemental environmental impact statement supersedes the specialist reports prepared for the 2005 final environmental impact statement.
12 Final Supplemental Environmental Impact Statement
Chapter 1. Purpose of and Need for Action Introduction and Setting [No change from the final environmental impact statement] Definition of Invasive Plant [New section] Executive Order 13112 defines an invasive species as “an alien species whose introduction does or is likely to cause economic or environmental harm or harm to human health.” This definition encompasses plants, animals, and microorganisms. Although invasive species come in many life forms, this document addresses invasive plants (weeds) only. Figure S-1 illustrates how a particular plant species may be determined to be invasive, as interpreted by the authors of this supplement and further defined by the Invasive Species Advisory Committee (ISAC 2006).
Figure S-1. An illustrative concept of the definition of an invasive plant, or “weed”
Noxious weed lists promulgated at the Federal, State, or County government levels are used to regulate invasive plants. Although most noxious weed lists are comprised mainly of invasive plants, not all weeds species found on these lists are necessarily invasive. For example, the lists may include agronomic weed species as well.
Purpose and Need for Action [Replaces third paragraph] In general, weed invasion and spread results in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability and water quality. Weeds can alter ecosystems by changing the frequency and intensity of wildfires (Quigley and Arbelbide 1997, DiTomaso 2000, Tu et al. 2001, ISAC 2006). More specifically, where weeds occur and continue to spread over native grasslands, riparian areas, rare plant areas,
13 Invasive Plant Control Project
and other sites on the Carson and Santa Fe National Forests, they are reducing the abundance and variety of native plants. This, in turn, impacts the abundance and diversity of wildlife species that depend on those native habitats. In addition, the root systems of some weed species do not hold soil in place as well as native plants, resulting in increased soil erosion and streambank instability (Lacey et al. 1989, ISAC 2006). Some weeds, such as saltcedar (also known as tamarisk), reduce water quantity, which is particularly critical to the arid lands in New Mexico (ISAC 2006).
[Replaces fourth paragraph]
In New Mexico, the occurrence of weed species is increasing. Existing populations are predicted to spread, and new weed infestations are projected to appear each year (Renz 2004). While the number of known weed infestation sites on the two national forests is relatively small, occupying less than half of 1 percent of the 3 million acres of land in the Carson and Santa Fe National Forests, there are likely more weed infestation sites that have not yet been discovered. Weeds typically spread at a rate of between 5 and 30 percent per year, depending on the plant species and site-specific conditions (DiTomaso 2000, Tu et al. 2001, Frid et al. 2013).
[Replaces 3rd bullet] • Water quality is impacted by weeds. Across the two forests, almost 8,600 acres of known weed populations are found in valley bottom lands and within 150 feet of streams. As native vegetation changes to one or more weed species, the amount of surface water runoff and stream sedimentation is likely to increase as well. Weeds that displace native rushes and sedges along streams typically reduce the soil stability of those streambanks (Enloe et al. 2004). Water quality can become degraded from these changes in plant composition along streams. Water infiltration rates can be reduced where weeds dominate, and their presence influences soil moisture and nutrient availability (DiTomaso 2000). [Replaces 2nd, 3rd, and 5th bullets, p. 15] • Wildlife habitat is degraded or lost when weeds cause a decline in native vegetation that provides cover, seeds, and habitat for small mammals. Over decades, large areas of weeds would likely lead to a reduced populations of deer, elk, and nongame wildlife populations (FICMNE 1998). Palatable forage for game and nongame wildlife species decreases as weeds take over (DiTomaso 2000). The North Ponil area on the Carson National Forest has more than 1,300 acres of bull thistle, along with small populations of knapweed and leafy spurge, threatening this area’s habitat quality. In addition, livestock and wildlife can be injured or die from weeds that are poisonous to animals that feed on them, such as black henbane and poison hemlock (FICMNE 1998). Yellow starthistle can induce a neurological disorder in wild or domestic horses that is usually fatal. • Weeds can impact the quality of recreational activities on the two national forests. Along trails, hikers encounter thistles and knapweeds that have spiny flowers and leaves. Dead weed stalks are known to impede access to meadows and riparian areas or discourage return trips (FICMNE 1998). Increased weed spread is expected along popular recreation use corridors such as State Highway 38 (Questa Ranger District), State Highway 4 (Jemez Ranger District), and State Highway 63 (Pecos/Las Vegas Ranger District). The North Ponil area of the Questa Ranger District demonstrates this growing conflict as bull thistle populations spread through the Ponil Fire burned area. Saltcedar is becoming so dominant along some streams it is limiting public access to those popular streamside areas (USDA Forest Service 1998b, 1998c). In addition, forest visitors and workers may come in contact with some weeds such as black henbane, which pose a health threat. • Wilderness characteristics could be threatened as weeds spread into these areas and form monocultures, reducing the natural diversity and integrity of native plants and animals. These changes in plant composition lead to detrimental changes in ecological processes and functions. Known weed populations in wilderness areas on the two national forests total approximately 560 acres.
14 Final Supplemental Environmental Impact Statement
Background: Existing Condition [Replaces entire section]
The New Mexico Department of Agriculture (NMDA) established a list of 37 weed species considered to be noxious and known to occur or with potential to occur within the State (NMDA 2009). The New Mexico Department of Agriculture categorizes the weeds into four classes: • Class A weeds (21 species) are not present or have very limited distribution in the state • Class B weeds (10 species) exist only in particular areas of the state • Class C weeds (6 species) are wide-spread throughout the state • Watch list weeds (8 species) have the potential to become problematic, but more data is needed before listing them as noxious
Of the 37 noxious weeds listed with the New Mexico Department of Agriculture, 21 species are known to occur in the two national forests, and 5 species have potential to occur there. Table S-4 lists these species and their main threat to the two national forests. For a more detailed discussion, see appendix 2, “Weed Species Ecology and Impacts.”
Photo 1. Leafy spurge (Santa Fe National Forest photo)
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Table S-4. Weed species locations and impacts (shows the changes from the final environmental impact statement only)
Weed Species and NMDA Class Life Cycle1 Location Impact
Tree of Heaven Perennial Found in fence rows, roadsides, Threat to natural areas because of (Ailanthus altissima) and waste areas. tendency to invade.
AIAL
(Class B)
Spotted knapweed Biennial or short-lived Prefers disturbed areas to Highly adapted to capturing moisture perennial. establish but can spread into and nutrients so it can spread and (Centaurea undisturbed areas once in a site. choke out native species. Decreases biebersteinii) the water storage capacity of soil and can increase soil erosion CESTM potential by replacing native plants’ network root system with taproot. (Class A)
(Fuller’s) teasel Biennial Found disturbed areas, abandoned Prickly plant with spines or sharp fields, and along roadsides. edges, can crowd out native plants (Dipsacus fullonum) and is known to form a monoculture.
DIFU2
(Class B)
Cheatgrass Annual Found on all exposures and types Quickly invades burned areas, of topography desert valleys to roadsides, and other disturbed sites (Bromus tectorum) mountains. outcompeting desired perennial vegetation. BRTE
(Class C)
16 Final Supplemental Environmental Impact Statement
Weed Species and NMDA Class Life Cycle1 Location Impact
Saltcedar Perennial shrub Riparian areas Replaces native wood species such (tamarisk) as cottonwood, willow, and mesquite. Chemically alters the soil (Tamarix spp.) to eliminate competition from native species to reduce the habitat TARA effectiveness for native wildlife species. Uses more water than (Class C) native species and changes the flood/sediment deposition regime so that native species such as cottonwood cannot regenerate. Remove field bindweed (COAR4) from list
1 The life cycle of a weed species along with its means of reproduction (seed, root sprouting, and so forth.) help determine how fast a weed species can take over a site, spread to new places, and how well it can be controlled. Perennial plants persist year after year and so can have a high capacity to spread by roots. These types of weeds can be rather difficult to control. Annuals grow and die after a single year and may be more vulnerable to control actions that disrupt this cycle pattern. Biennials take 2 or more years to complete their life cycle and may be the most susceptible to control efforts that disrupt their reproductive pattern.
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Figure S-2 [replaces figure 2 in the final environmental impact statement] is a map of weeds in the project area, although the points on the map do not accurately represent the size or extent of each weed infestation.
For the last several years, resource specialists have noticed weed species increasing on the two national forests. Forest Service personnel started surveying weeds in 1997 and have continued up to the present. The first surveys sampled a portion of each ranger district and found 16 species. The surveys completed to date do not cover the entire project area. Not all disturbed sites (such as recent fires) have been completely surveyed, but these areas serve as likely places for weeds to gain a foothold. As summarized in Table S-6 and displayed in Figure S-2, of the 3,030,721 million acres of National Forest System lands in the project area, there are approximately 13,256 acres of known weed infestations in a wide range of sizes and a broad distribution. As shown in Table S-6, Canada thistle is the most abundant weed in the two national forests. Acreages of all weed species shown in the table do not reflect the density of weeds in each site since most of these sites also have native vegetation that would not be treated. The size of each weed infestation currently varies from less than 1 acre to over 1,000 acres. Most infestations (more than 75 percent) are less than 1 acre; an ideal size for effectively treating them (Frid et al. 2013).
Table S-5 shows the distribution of known weeds in the project area by general landform type.
Table S-5. Weeds by landform type as of August 1, 2013 Estimated Minimum Maximum Average Infested Areas Acres* Size Size Size Within 150 feet of open system roads 4,593 0.003 1,182 67 Within 150 feet of trails, motorized and 12,070 0.01 2,793 19 nonmotorized Riparian areas (150 foot buffer) 3,815 0.002 827 67 Valley bottoms (150 foot buffer) 4,777 0.004 850 76 Scattered 4,818 0.01 1,306 110 Within 50 feet of well pads (Jicarilla 150 0.01 97 15 Ranger District) In wilderness 561 0.002 252 19 Within 150 feet of a trailhead 9 0.0002 3 1 * Some invasive plant populations may fall into more than one category and would be counted more than once.
18 Final Supplemental Environmental Impact Statement
Figure S-2. Weed distribution in the project area, August 1, 2013
19 Invasive Plant Control Project
Table S-6 shows weed species and their known abundance as of August 1, 2013.
Table S-6. Weed species and their abundance in the project area as of August 1, 2013 Common Name Scientific Name Forest Acres1 Russian knapweed Acroptilon repens Carson NF 41 Russian knapweed Acroptilon repens Santa Fe NF 69 tree of heaven Ailanthus altissima Santa Fe NF 0.1 cheatgrass Bromus tectorum Santa Fe NF 74 whitetop Cardaria draba Carson NF 49 whitetop Cardaria draba Santa Fe NF 8 musk thistle Carduus nutans Carson NF 585 musk thistle Carduus nutans Santa Fe NF 3,158 diffuse knapweed Centaurea diffusa Carson NF 394 diffuse knapweed Centaurea diffusa Santa Fe NF 108 yellow star-thistle Centaurea solstitialis Carson NF 1 spotted knapweed Centaurea stoebe ssp. micranthos Santa Fe NF 339 Canada thistle Cirsium arvense Carson NF 310 Canada thistle Cirsium arvense Santa Fe NF 5,325 bull thistle Cirsium vulgare Carson NF 1,647 bull thistle Cirsium vulgare Santa Fe NF 2,183 poison hemlock Conium maculatum Santa Fe NF 22 Fuller's teasel Dipsacus fullonum Santa Fe NF 0.1 Russian olive Elaeagnus angustifolia Carson NF 331 Russian olive Elaeagnus angustifolia Santa Fe NF 919 leafy spurge Euphorbia esula Carson NF 9 leafy spurge Euphorbia esula Santa Fe NF 0.02 black henbane Hyoscyamus niger Carson NF 44 perennial pepperweed Lepidium latifolium Carson NF 43 Dalmatian toadflax Linaria dalmatica Santa Fe NF 18 yellow toadflax Linaria vulgaris Carson NF 47 Scotch thistle Onopordum acanthium Carson NF 130 Scotch thistle Onopordum acanthium Santa Fe NF 392 tamarisk / saltcedar Tamarix ramosissima Carson NF 548 tamarisk / saltcedar Tamarix ramosissima Santa Fe NF 1,090 Siberian elm Ulmus pumila Santa Fe NF 1,509 1 Because more than one species may exist in a mapped footprint, the acres total more than the 13,256 acres known in the project area.
Smaller populations of weed species pose a threat because of their ability to take over a plant community and their potential to spread. Once they become established across large areas, these species are difficult to eradicate. Also, the weed survey results likely underestimate actual weed infestations on the two national forests, since many areas have not been surveyed.
In valley bottoms or in riparian areas, complexes of saltcedar/Siberian elm/Russian olive/bull thistle are common, along with populations of bull thistle, Canada thistle, and musk thistle. Wildlife species depend heavily on riparian areas in the arid Southwest, and the ability of weeds to reduce native plant diversity has a
20 Final Supplemental Environmental Impact Statement
magnified impact on the wildlife habitats. Travel corridors have the most known weeds. Weeds along roads and trails are easily surveyed, and weeds also tend to become established in disturbed areas such as rights-of- way. Bull thistle and Canada thistle are the most likely to spread, but small populations of leafy spurge found along Highways 285 and 64 near Tres Piedras also pose a threat of spread.
Away from valley bottoms, riparian areas, and main travel routes, Canada thistle, musk thistle, and bull thistle pose the largest threat of spreading because of their ability to adapt to a wide variety of habitats. On the Jicarilla Ranger District, infestations of Scotch thistle and musk thistle are found at natural gas wellheads and along roads leading to these facilities. Although the amount of Scotch thistle is relatively small, the potential for spread is high because of the intermingled land ownership and use in this area. Along the Rio Tusas drainage, the amount of leafy spurge is relatively small, but when the threat is greater when seen in the context of infestations on adjacent private land.
On average, weeds are projected to increase annually in the United States at a rate of 8 to 12 percent per year without treatment (FICMNE 1998). Projections on the two national forests indicate the spread is expected to be between 5 and 30 percent annually. The low end of this range is lower than the national average for some species based on arid growing conditions in the Southwest. Saltcedar found in riparian areas is expected to increase at a slower rate due, in part, to the release of the saltcedar leaf beetle (Diorhabda spp.) as a biocontrol agent. Leafy spurge would likely increase at the higher rate. For purposes of this analysis, an estimate of 8 percent per year is used in order to account for growth without overstating the estimates in the face of the variable nature of the species and other conditions.
Appendix 7 lists the most effective treatments for known weed species on the Carson and Santa Fe National Forests. In most cases, weed-infested sites require repeat treatments in the same area to meet the treatment objectives (for example, complete eradication or long-term control). For most deep-rooted perennial weeds, effective control with the least amount of soil disturbance may only be achieved through herbicide application. Management Direction–Desired Condition [No change from final environmental impact statement] Other Direction [Replaces entire section]
Other management direction relevant to this project includes the following:
Forest Service Manual 2900 – Invasive Species Management (December 5, 2011): Specifies management activities for invasive species will be based upon an integrated pest management approach. It prioritizes prevention, early detection and rapid response, control and management, restoration, and organizational collaboration as needed.
Executive Order 13112 (February 3, 1999): As pertains to this project, it directs Federal agencies to: … (2)(b) detect and control [invasive] species; (c) monitor population of such species; and (d) provide for restoration of native species.
“2008-2012 National Invasive Species Management Plan” (August 1, 2008): Directs Federal efforts (including overall strategy and objectives) to prevent, control, and minimize invasive species and their impacts through 2012. The plan gives Federal agencies, including the Forest Service, broad authority to prevent the spread of invasive species and authorizes them to assist State and private entities in their prevention efforts.
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“USDA Forest Service National Strategy and Implementation Plan for Invasive Species Management” (USDA Forest Service, October 2004): Provides overall strategic direction for addressing invasive species. It contains four elements: prevention, early detection and rapid response, control and management, and rehabilitation and restoration.
New Mexico Executive Order 00-22 (NMEO 2000): Directs state executive agencies to manage weed infestations designated by the New Mexico Department of Agriculture as Class A weed infestations on state land rights-of-way by making use of integrated pest management techniques.
Noxious Weed Management Act (1978): The State of New Mexico enacted this legislation to recognize the adverse economic and environmental impacts of weeds and the need for action to reduce this threat.
Forest Service Manual 2150 – Pesticide-Use Management and Coordination (USDA Forest Service 2013b): Provides requirements for use of pesticides (including herbicides).
Other laws, regulations, and policies will be followed as they apply to the control of weeds on National Forest System lands. Proposed Action [Replaces 1st paragraph] The proposed action is an integrated set of management actions considered necessary to control weeds on the Carson and Santa Fe National Forests with the goal of completely eliminating them or at least preventing their spread. Under policy stated in Forest Service Manual 2903, invasive weeds and other invasive species in aquatic and terrestrial areas of the National Forest System are to be managed by using an integrated pest management approach. The integrated pest management approach recognizes using only one treatment method is unlikely to be effective. Treatment methods used in conjunction with integrated pest management involve four broad categories:
1. Mechanical/Physical (mowing, prescribed burning, etc.), 2. Cultural (re-seeding, fertilizing, etc.), 3. Biological (grazing, use of biocontrol agents, etc.), and 4. Chemical (use of herbicides). Weeds proposed for treatment are those on the New Mexico Department of Agriculture’s noxious weeds list at the time of this writing or listed in the future. As of this writing, 21 of the 37 listed weeds are known to occur in the Carson and Santa Fe National Forests, and 5 have the potential to occur. The two national forests do not intend to treat medicinal plant species such as St. John’s wort (Hypericum perforatum) and wild licorice (Glycyrrhiza lepidota).
[Replaces 1st paragraph, p. 29]
Treatments would begin in 2017 and would take place for at least 10 years:1 ♦ Each national forest expects to treat an average of 300 to 800 acres per year (600 to 1,600 per year for both forests on average) depending on funding and methods used. ♦ Each national forest expects to treat no more than 1,500 acres per year (3,000 per year for both forests as a maximum).
1 The timeframe for the effects analysis in this supplement is 10 years. The two national forests expect to have controlled most weed populations by then; however, treatments are expected to be ongoing since completely preventing new introductions isn’t likely.
22 Final Supplemental Environmental Impact Statement
[Replaces 4th paragraph, p. 29] The adaptive management approach was further defined in January 2005 when the Forest Service published planning rules that recognize the role of adaptive management in implementing forest plans:
Adaptive management is an approach to natural resource management where actions are designed and executed and effects are monitored for the purpose of learning and adjusting future management actions, which improves the efficiency and responsiveness of management. (36 CFR 219.16, 70 FR 1060)
In 2008, Forest Service National Environmental Policy Act regulations at 36 CFR § 220.3 defined adaptive management as “[a] system of management practices based on clearly identified intended outcomes and monitoring to determine if management actions are meeting those outcomes; and, if not, to facilitate management changes that will best ensure that those outcomes are met or reevaluated. Adaptive management stems from the recognition that knowledge about natural resource systems is sometimes uncertain.”
[Replaces last sentence of 1st paragraph, p. 30] This strategy is consistent with Forest Service guidelines on applying adaptive management to site-specific environmental analysis for weed management projects (USDA Forest Service 2011b).
[Replaces all bullet points on p. 30] The proposed weed control program involves the following steps:
• Inventory by searching places with a high likelihood for new weed populations, and enter new weed locations in the Geographic Information System (GIS) database. • Prioritize and select appropriate treatment methods based on criteria in the final environmental impact statement and this final supplemental environmental impact statement (chapter 2), including applicable design features based on site conditions. • Develop an implementation plan that is reviewed and updated annually, including coordination with other agencies regarding weed control activities. • Complete any needed heritage, plant, and wildlife surveys. • Complete any needed permits (chapter 2). • Notify the public about the annual weed treatment schedule and site-specific locations. • Implement weed control treatments. • Monitor for: ♦ treatment effectiveness in meeting weed control objectives; ♦ effects on other resources relative to those predicted in the final environmental impact statement and this final supplemental environmental impact statement; and ♦ implementation and effectiveness of design features used to minimize adverse impacts. • Evaluate and document monitoring results for use in future weed treatment prescriptions.
Forest Plan Amendment [Replaces entire section]
Alternatives B and D include a nonsignificant, programmatic amendment to the Santa Fe National Forest Plan. The amendment would allow the use of herbicides in places currently prohibited by forest plan
23 Invasive Plant Control Project
standards and guidelines. These areas are in municipal watersheds and on soils with low revegetation potential. Chapter 2 provides the exact language of the proposed amendment. The Carson National Forest Plan does not prohibit the use of herbicides in any specific areas. Decision-making Framework [Replaces “EIS” with “SEIS.” Adds this paragraph]
The incorporation of the amendment will be conducted through use of the 1982 rule procedures as allowed by the transition language of the 2012 planning rule (36 CFR 219.17(b)(3)).
The predecisional administrative review process (known as the objection process2) required for the project will also be used for administrative review of the proposed amendment for the selected alternative (36 CFR 219.59(b)). Public Involvement [Replaces entire section] Collaboration and Scoping In 1996 and 1997, the Forest Service met informally with other Federal, State, and County agencies to discuss the threat of weeds and coordinate treatments. Newspaper articles were also published to inform the public about the threat of weeds and the full range of treatment options, such as those being considered by the Forest Service. In 1998, the two national forests began scoping for this project, starting with public meetings held in Taos and Espanola. In March 2000, a scoping letter was sent to approximately 450 individuals, agencies, Tribes, and organized groups to inform them about the weed control treatment proposals. At that time, each forest was independently working on separate environmental assessments for forestwide weed control projects. As a result of the March 2000 scoping, a decision was made to combine the efforts of the two national forests and document the analysis in an environmental impact statement.
In December 2000, the Forest Service sent a new scoping letter to the public about the proposed action. On December 15, 2000, the Forest Service published a notice of intent to prepare an environmental impact statement in the Federal Register. At the request of local citizens, a field trip was conducted to discuss weed infestations and show people the weed conditions on the Tres Piedras Ranger District.
The Forest Service first contacted Tribal governments about treating weeds in 1999. They included the Tribal governments in their March and December 2000 scoping efforts. In December 2003, the Forest Service sent another letter to all potentially affected Tribal governments to initiate consultation and solicit their comments about the proposed project.
A total of 34 individuals and 30 organizations commented during scoping. The largest number of comments questioned the need for treatment when other solutions, such as eliminating grazing and closing roads (which they considered to be the source of weeds), were available. Education was also suggested as a means of dealing with the weed problem. Some respondents suggested education as a substitute for treatment; others, presented it as a complementary activity.
The treatment that appeared to be of greatest concern to those who commented was the use of herbicides. Most opposition was based on concerns that herbicides could adversely impact human health, nontarget plants, and wildlife. Concerns over the impact to water quality and fish were also mentioned. Some respondents voiced concerns that herbicides were too nonselective and their impacts would be too broad. Potential impacts to people with multiple chemical sensitivities were mentioned as reason to avoid using
2 See 36 CFR 218, Final Rule for Project-level Predecisional Administrative Review Process
24 Final Supplemental Environmental Impact Statement
herbicides and any associated chemicals (for example, inert ingredients in the formulations). Suggestions were made to use a wide variety of nonchemical methods, such as hand digging (possibly enlisting volunteers to do this work) and using goats to graze the weeds where possible. In addition to the letters responding to the scoping letters, a petition with approximately 1,000 signatures was submitted stating opposition to the use of herbicides in managing weeds on the Carson National Forest.
One comment also raised concerns with using biological agents because of the possibility of introducing an insect that would have unforeseen effects, such as getting out of control itself.
Others stated chemicals might be used under controlled conditions so people who use the two national forests to collect and use certain products would not be adversely impacted from herbicides or other methods would not destroy these culturally and economically important plants.
Another set of comments supported the need to treat weeds and supported use of the integrated approach (including herbicides), as long as appropriate oversight is given to the efforts so they are coordinated within the two national forests and with other agencies conducting similar efforts. Some comments in this set also noted strong monitoring should be a priority to be successful.
Using the comments sent during scoping, the Forest Service’s interdisciplinary team identified four significant issues (see “Issues” section). The team then created alternatives C and D to respond to these issues. In May 2004, a four-page update was mailed to known interested or affected parties. It described the final issues and alternatives, as well as the status of the draft environmental impact statement and estimated release date.
Public Comment on the Draft Environmental Impact Statement On July 16, 2004, the Forest Service published a notice of availability of the draft environmental impact statement in the Federal Register. The legal notices announcing the start of the 45-day comment period were published in the newspapers of record on July 22, 2004. The Forest Service received 106 letters on the draft environmental impact statement; of these, 7 were received after the end of the comment period, which was August 30, 2004.
The Forest Service’s interdisciplinary team identified approximately 750 individual comments contained in the letters. Use of herbicides continued to be a main concern among members of the public. In response, the final environmental impact statement clarified and expanded the discussion of the risks associated with the use of herbicides (see appendix 3 of the final environmental impact statement). Appendix 9 of the final environmental impact statement responds to comments received on the draft environmental impact statement. Other relevant comments were incorporated into the final environmental impact statement.
Appeal of the Record of Decision On September 12, 2005, the Carson and Santa Fe National Forest Supervisors signed a record of decision selecting alternative B. The Forest Service published the notice of availability of the final environmental impact statement and record of decision in the Federal Register on November 18, 2005. The legal notices announcing the start of the 45-day appeal period were published in the newspapers of record on November 23, 2005. Eight appeals of the decision were submitted. The Forest Service met with the appellants but was unable to resolve the issues stated. The Deputy Regional Forester reversed the decision on February 23, 2006.
Draft Supplemental Environmental Impact Statement The Forest Service prepared a draft supplemental environmental impact statement to correct the deficiencies identified by the Deputy Regional Forester and to update the analysis and facts where needed pursuant to 40 CFR 1502.9(c)(1). In accordance with the Council on Environmental Quality regulations at §1502.9(c)(4), the draft supplemental environmental impact statement was “prepare(d), circulate(d), and file(d) … in the same
25 Invasive Plant Control Project
fashion (exclusive of scoping) as a draft and final statement.” The project was not re-scoped, but the public had the opportunity to comment on the draft supplemental environmental impact statement before a final decision.
In February 2012, the Forest Service sent postcards to 274 people and organizations anticipating the draft supplemental environmental impact statement would be published that spring and asking them how they would like to be notified. Seventeen responses were received.
On March 21, 2014, the Forest Service published a notice of availability of the draft supplemental environmental impact statement in the Federal Register. The legal notices announcing the start of the 45-day comment period were published in the newspapers of record on March 24, 2014. The Forest Service received 33 letters on the draft supplemental environmental impact statement.
The Forest Service’s interdisciplinary team identified approximately 75 individual comments contained in the letters. Use of herbicides continued to be a main concern among members of the public. Appendix 10 of the final supplemental environmental impact statement responds to comments received on the draft supplemental environmental impact statement.
The Forest Service has published regulations that institute an objection process in lieu of the appeal process. This project and its decision will fall under the objection process, whose regulations are found at 36 CFR 218. Issues [Add this sentence to first paragraph; otherwise, no change from final environmental impact statement] For this final supplemental environmental impact statement, the responsible officials have retained the four significant issues from the final environmental impact statement. The analysis of the public’s comments conducted in 2004 remains valid.
26 Final Supplemental Environmental Impact Statement
Chapter 2. Alternatives, Including the Proposed Action Introduction [No change from the final environmental impact statement] Alternatives Considered but Eliminated from Detailed Study [Add sentences to end of section “Organic Treatment Methods”] The Carson National Forest has inexpensively and effectively used plastic sheeting to cover and eradicate weeds on areas less than ¼ of an acre. The drawbacks to this method are its unsightliness, time required to kill the weeds, lethal effects on non-target plants, and creation of bare ground that is susceptible to soil erosion. Nonetheless, weed barriers, when shown to be effective and to meet the criteria of the adaptive strategy in the final environmental impact statement, may be used by the two national forests. Alternatives Considered in Detail Alternative A–No Action [Replaces entire section] Under the no-action alternative, weed treatments would not occur. This means neither forest would have an integrated, forest-wide approach to managing weeds. Previously approved, project-specific weed treatments, such as those along the lower Jemez River, would be implemented, along with those of other jurisdictions within the national forest boundaries, such as along Federal, State, and County roads. Weed inventories and prevention activities would continue to occur.
Alternative B–Proposed Action (Integrated Strategy) [Additional paragraph] The known weed populations have a footprint of 13,256 acres. This is a snapshot in time and does not necessarily encompass the full extent of acreage proposed to be treated. The proposed action would treat existing weeds and new populations as they are discovered. Any new populations to be treated must be on New Mexico Department of Agriculture’s weed list and must follow the adaptive management strategy described in chapter 2.
[Remove figure 3 and refer to figure S-2] Figure S-2 on page 19 shows the locations of the known weed populations. Appendix 7 shows how each species would be treated.
27 Invasive Plant Control Project
[New photo]
Photo 2. Hand-grubbed patch of bull thistle (Santa Fe National Forest photo)
[Replaces first two sentences of second paragraph of section under “Herbicides”]
Thirteen herbicides are proposed for use: 2,4-D, aminopyralid, clopyralid, chlorsulfuron, dicamba, glyphosate, hexazinone, imazapic, imazapyr, metsulfuron methyl, sulfometuron methyl, picloram, and triclopyr. The herbicide aminopyralid has been added as a proposed herbicide in this final supplemental environmental impact statement; the others were proposed and analyzed in the final environmental impact statement. Appendix 3 contains detailed information about each. Treatments using the herbicides are tailored to specific species and site conditions.
[Replaces entire section under “Mechanical”] Mechanical control methods include actions such as mowing, girdling, or root tilling. Mowing cuts plants off above ground. Root tilling digs into the soil to unearth the roots. Girdling is a method that may be used for invasive trees, such as Siberian elm (photo 3).
Photo 3. Girdled trees (photo courtesy of Tom Kaye, Institute for Applied Ecology)
28 Final Supplemental Environmental Impact Statement
Mowing and root tilling employ large mechanized equipment such as tractors with specially designed attachments. These methods have not been demonstrated to be effective in eradicating or substantially reducing weed infestations, and typically require frequent repeat treatments. They do reduce plant and root vigor. Feasibility for these two methods is also quite limited on the two national forests due to the steep slopes and other common terrain features such as trees, boulders, or logs. Thus, this method is only likely to be for minor, incidental use, mainly along highways in conjunction with ongoing road maintenance actions. Most mechanical treatment is proposed in combination with another method.
[Replaces table 6] The abbreviations shown below represent the kinds of treatments proposed in the action alternatives.
Treatment Method Abbreviation Biological BIO Grazing GR Herbicides HE Manual MA Mechanical ME Prescribed fire FR
Table S-7. Summary of treatments proposed for alternative B Percent Treatment Acres of Total BIO, FR, GR, HE, MA, ME 4 0.03 BIO, FR, HE, ME 181 1 BIO, GR, HE 21 0.2 BIO, GR, HE, MA 1 0.005 BIO, GR, HE, MA, ME 16 0.1 BIO, GR, HE, ME 43 0.3 BIO, HE, MA 22 0.2 BIO, HE, MA, ME 4,052 31 BIO, HE, ME 400 3 FR, GR, HE, MA, ME 73 1 FR, GR, HE, ME 0 0.0003 FR, HE, MA, ME 14 0.1 FR, HE, ME 617 5 GR, HE, MA, ME 2,682 20 GR, HE, ME 2,999 23 HE, MA 497 4 HE, MA, ME 1,629 12 HE, ME 3 0.02 Grand Total 13,256
29 Invasive Plant Control Project
Alternative C–No Herbicides [Additional paragraph] The known weed populations have a footprint of 13,256 acres. This is a snapshot in time, and does not necessarily encompass the full extent of acreage proposed to be treated. Alternative C would treat existing weeds and new populations as they are discovered. Any new populations to be treated must be on New Mexico Department of Agriculture’s weed list and must follow the adaptive management strategy described in chapter 2.
[Remove figure 4 and refer to figure S-2] Figure S-2 shows the locations of the known species of weed populations. Appendix 7 shows the method by which each species could be treated. Refer to page 29 for a key of abbreviations.
[Replaces table 7]
Table S-8. Summary of treatments proposed for alternative C Percent of Treatment Acres Total BIO 12 0.09 BIO, FR, GR, MA, ME 4 0.0 BIO, FR, ME 181 1.4 BIO, GR 9 0.067 BIO, GR, MA, ME 16 0.1 BIO, GR, ME 43 0.3 BIO, MA 23 0.2 BIO, MA, ME 4,052 31.0 BIO, ME 400 3.0 FR, GR, MA, ME 73 1.0 FR, GR, ME 0 0.0003 FR, MA, ME 14 0.1 FR, ME 617 5.0 GR, MA, ME 2,682 20.0 GR, ME 2,999 23.0 MA 497 4.0 MA, ME 1,629 12.0 ME 3 0.02 Grand Total 13,256
Alternative D–Herbicides Only [Additional Paragraph] The known weed populations have a footprint of 13,256 acres. This is a snapshot in time, and does not necessarily encompass the full extent of acreage proposed to be treated. Alternative D would treat existing weeds and new populations as they are discovered. Any new populations to be treated must be on New Mexico Department of Agriculture’s weed list and must follow the adaptive management strategy described in chapter 2.
30 Final Supplemental Environmental Impact Statement
[Remove figure 5 and refer to figure S-2] Figure S-2 on page 19 shows the locations of the known weed populations. Appendix 7 shows how each species would be treated.
[Replaces table 8]
Table S-9. Summary of treatments proposed for alternative D Treatment Acres Percent of Total Herbicide 13,256 100 Total 13,256
Adaptive Strategy–All Action Alternatives [No change from the final environmental impact statement]
Treatment Objectives, Priorities, and Decision Criteria [No change from the final environmental impact statement]
Additional Criteria for Prioritizing and Determining Objectives and Methods [No change from the final environmental impact statement]
[Replaces table 9]
Table S-10. Additional treatment criteria and limitations Weed Site Conditions Treatment Method Limitations Area of high human use such as Method(s) must have been documented to have a low risk of a recreation site, administrative causing harm to people. Examples include non-herbicide methods site, or area where people often with lowest risk (for example, those that avoid burning) or herbicide collect plants. formulations and application methods having the lowest risk of harmful effects to humans (for example, aminopyralid, glyphosate, imazapyr, imazapic, metsulfuron methyl, clopyralid products would be available for use per risk assessment results found in appendix 3). Also adhere to other design features that apply to protection of human health and safety (for example, notification). Use of herbicides shall occur during weekdays only. Area where there is a shallow Non-herbicide method(s) appropriate for the site conditions (manual water table (no more than 6 feet pulling or mowing) or an herbicide appropriately labeled for use in deep) and soil with a high these locations (for example, short-lived, non-leachable herbicides permeability rate, where there such as glyphosate, imazapic, imazapyr, metsulfuron methyl, may be a risk of an herbicide clopyralid, chlorsulfuron) that have been registered by the leaching through the soil to the Environmental Protection Agency for use on permeable soils with groundwater. shallow water tables. Herbicides that use picloram as their active ingredient (for example, Tordon 22K) would not be used in these situations per risk assessment results. Also adhere to design features to protect soil and groundwater resources. In riparian areas, including Method(s) determined and documented to have low risk to fish or outstanding national resource other aquatic species. Examples include a non-herbicide method (for waters, or areas next to live water example, mowing) that avoids erosion/sediment production or bodies containing aquatic herbicides registered by the Environmental Protection Agency for species. aquatic habitats; for example, chlorsulfuron, glyphosate formulations such as Rodeo (which does not use the surfactant polyethoxylated tallowamine), imazapic, and imazapyr. Also adhere to design features to protect to riparian, water, and aquatic resources.
31 Invasive Plant Control Project
Weed Site Conditions Treatment Method Limitations Threatened, endangered, or Method(s) determined and documented to have low risk to native sensitive plant species are plant species, such as non-herbicide methods (hand pulling) with present. appropriate disturbance controls. Herbicide applications include spot treatment (by hand or backpack spray) that avoid vehicle boom spray application of herbicides such as imazapyr, imazapic clopyralid, chlorsulfuron, because they have high potential to affect non-target plants up to several hundred feet away. Herbicides, if used from boom spray, could be used if risk ratings are similar to 2,4-D, which has low risk of impact beyond 25 feet of drift. For Holy Ghost ipomopsis, see specific design features later in this section. Adhere to design features to protect threatened, endangered, or sensitive plant species, including limitations on herbicide spraying from vehicles. Occupied threatened, Method(s) used must have been determined to have low risk to endangered, or sensitive wildlife wildlife species. These methods include non-herbicide methods at species habitat. the proper timing (for example, burning outside seasonal restrictions). Herbicide applications must be shown to be below the level of concern through specific risk assessment for the herbicide used when applied in these habitats (see appendix 3). No direct application of herbicides to water would be permitted under the adaptive strategy even where formulations are registered for such use (for example, AquaKleen formulation of 2,4-D). This restriction is imposed because of possible effects of direct application to Rio Grande cutthroat trout. Also adhere to other design features to protect threatened, endangered, or sensitive wildlife species. Wilderness and designated Motorized vehicles and mechanized equipment are prohibited in all nonmotorized areas. wilderness areas. In the Pecos Wilderness, sheep or goat grazing for weed control would continue to be prohibited by an existing closure order. In other locations of Rocky Mountain bighorn sheep habitat, managed grazing for weed control would also be prohibited. See design features. Santa Fe and Gallinas municipal Method(s) must have been documented to have a low risk of watersheds in the Santa Fe causing harm to people. Examples include non-herbicide methods National Forest with lowest risk (for example, those that avoid burning) or herbicide formulations/application methods having the lowest risk of harmful effects to humans. For example, aminopyralid, glyphosate, imazapyr, imazapic, metsulfuron methyl, and clopyralid products would be available for use per risk assessment results found in appendix 3. Also adhere to other design features to protect human health and safety (for example, notification). Method(s) used must be approved by the appropriate officials of the cities of Santa Fe and Las Vegas, New Mexico. Picloram will not be used in municipal watersheds.
32 Final Supplemental Environmental Impact Statement
Design Features and Monitoring Requirements [Replaces table 10]
Table S-11. Design features and monitoring requirements for all alternatives Row No. Description of Design Feature and Monitoring Requirement Alternatives Human Health and Safety 1 Herbicide formulations (specific products including mixtures) will not be used B, D unless they have been registered for use by the Environmental Protection Agency and all Environmental Protection Agency label requirements (including limitations) are strictly followed. Only herbicides with a completed risk assessment per Forest Service standards would be used. 2 In areas of human habitation or high use such as a recreation site, administrative B, D site or area where people often collect plants, the treatment method must have low risk of harmful effects to humans. Examples include nonherbicide methods (manual/mechanical/grazing) or herbicides rated as having the lowest risk of harmful effects to humans (see appendix 3). 3 Herbicide application will strictly adhere to Environmental Protection Agency label B, D instructions regarding temperature, humidity, wind speed and other weather variables, to avoid spray drift to nontarget plants or other resources while increasing treatment effectiveness. 4 Herbicide use will be restricted to Environmental Protection Agency-registered B, D application rates (usually in terms of pound per acre of active ingredient applied) and conditions listed on the label. Follow-up application of a second herbicide to an area should be conducted only after reviewing best available information on compatibility with the previous application’s formulation. 5 Herbicides may only be applied by a trained applicator under supervision of a B, D licensed applicator, in accordance with Forest Service directives. 6 Herbicide use will comply with the direction contained in Chapter 2150 of Forest B, D Service Manual 2100 - Environmental Management (USDA Forest Service 2013b), including the requirement that a pesticide use proposal (form FS-2100-2) be completed for all proposed pesticide (that is, herbicide) uses on National Forest System lands. 7 Herbicide applicators will have the chemical spill plan and emergency cleanup kit B, D onsite during treatments. The spill plan identifies methods to avoid accidental spills as well as how to report and clean up spills. The kit will contain appropriate spill cleanup supplies (see appendix 6).3 8 Workers handling herbicides will be required to wear protective clothing, including B, D a long-sleeved shirt and long pants to reduce worker doses. For herbicides containing hexazinone, respiratory protection would also be required per label direction. Clothes should be cleaned daily. Workers will also wear waterproofed boots, gloves, and other safety clothing and equipment listed on the herbicide label. Workers mixing or loading herbicides will be required to wear eye protection (goggles or eye shields) and Tyvek suits or herbicide-resistant aprons. 9 A pesticide application record (PAR) will be completed on a daily basis for each B, D project area detailing the herbicide application, treatment area, target species distribution and density, weather conditions, and recommendations for followup treatments or rehabilitation. 10 The Forest Service will provide public information about weed treatments using B, D herbicides, including herbicide to be used, locations, application schedules, and so forth. This information will be posted on the Santa Fe and Carson National Forest websites and mailed to those who request it.
3 A comment on the draft environmental impact statement submitted in 2004 by the New Mexico Environment Department states that in the event of spills, the Ground Water Quality Bureau Chief must be notified. This requirement is listed in Appendix 6 on page 295 under “Major Spills”.
33 Invasive Plant Control Project
Row No. Description of Design Feature and Monitoring Requirement Alternatives 11 To further notify forest visitors and users, signs regarding herbicide use will be B, D placed at access points to treatment areas prior to herbicide application. Signs will include the herbicide to be used, effective dates, and phone number for obtaining more information. 12 Traffic control and signing during weed treatment operations will be used as B, C, D necessary to ensure safety of workers and the public. Recreation sites, roads, trails, or other areas scheduled for treatment may be temporarily closed during weed treatment activities to ensure public safety. 13 Weed treatments will be coordinated with potentially affected adjacent B, C, D landowners and range allotment permittees. Cooperative efforts on adjacent lands and range allotments would increase treatment effectiveness and the ability to meet weed control objectives. 14 In highly used, developed recreation areas, use of herbicides would occur during weekdays only. Native Vegetation and Treatment Effectiveness 15 Prescribed burning, digging, pulling, and tilling weeds, and other ground- B, C, D disturbing activities will be designed to avoid or minimize impacts to native plants of cultural and traditional concerns. Prior to implementation, a Forest Service biologist or other qualified person will locate these plants to the extent possible. 16 Allotment permittees will be contacted about upcoming treatments (methods, B, C, D locations, schedules, and so forth) that may affect their grazing operations. Annual operating instructions may be adjusted as needed. Early coordination will minimize the impact of adjusting grazing operations during and after treatments, the extent and duration of which will be determined by site-specific conditions and weed treatment objectives. 17 Weed treatments will only be applied where weeds actually exist, not on areas B, C, D with a potential for weed infestations. 18 Vehicles used for weed treatments will be properly cleaned prior to entering B, C, D National Forest System lands and again before leaving the treated area to avoid further spread of weeds. 19 Where treatments result in exposing bare mineral soil, those sites will be B, C, D evaluated to determine the need for revegetation (seeding, planting), mulching, or other erosion or sediment control measures. The evaluation would consider the potential for subsequent reinvasion by weed species, potential for erosion, water runoff, and stream sedimentation. Where seeding is used, certified weed- free seed will be required. Seed mixes will be based on site-specific conditions and objectives. Treatment combined with reseeding has been shown to be effective at controlling weeds (Endress et al. 2012). 20 Herbicides will not be applied if snow or ice covers the target weed plants to B, D avoid runoff into soil and onto nontarget vegetation. 21 After treatment, livestock grazing will be deferred where needed to achieve weed B, C, D treatment objectives, based on site-specific conditions. This will be accomplished by working with permittees and adjusting their annual operating instructions as necessary. 22 Biological agents will not be released until screened for host plant specificity and B, C approved by the U.S. Department of Agriculture Animal Plant Health Inspection Service and the New Mexico Department of Agriculture. 23 All weeds that are mechanically or hand excavated after flower bud stage will be B, C double bagged and properly disposed of at an approved facility (for example, a covered landfill). 24 Use of prescribed fire must adhere to restrictions contained in the forest plan and B, C Forest Service directives, such as those for using fire within wilderness (Forest Service Manuals 2324.2 and 2324.04(b)), requirements for detailed burn prescriptions, and other requirements intended to avoid unexpected consequences.
34 Final Supplemental Environmental Impact Statement
Row No. Description of Design Feature and Monitoring Requirement Alternatives Threatened, Endangered and Sensitive Plants 25 The Santa Fe National Forest or Pecos-Las Vegas Ranger District will coordinate B, C, D with the New Mexico Environment Department (NMED) and U.S. Fish and Wildlife Service to obtain the most current survey information on the Holy Ghost ipomopsis prior to implementing any weed treatments in occupied Holy Ghost ipomopsis habitat. 26 Ground-disturbing activities, such as tilling, pulling, and digging up weeds, will be B, C designed to avoid trampling or other direct impacts to individual Holy Ghost ipomopsis plants or other threatened, endangered, and sensitive plants. 27 Herbicide use is prohibited within, and for 25 feet around, Holy Ghost ipomopsis B, D plants and occupied habitat; only hand removal by pulling or digging up weeds will be permitted. From 25 to 50 feet, only hand application of herbicides by wick or rag will be permitted. 28 Prior to implementing any managed grazing, spray application of herbicides, B, C, D mechanical (for example, mowing), or prescribed fire treatments within Holy Ghost ipomopsis or other sensitive plant species habitats, a Forest Service biologist or other qualified person will visibly mark a 50-foot buffer around groups or isolated individuals of the subject plants. 29 Within, and for 25 feet around, other sensitive plants occupied habitats, only B, C, D hand treatments will be permitted (for example, wick or rag to apply herbicides; shovel to dig up weeds); no spray herbicide application will be permitted. 30 A Forest Service biologist or other qualified person will be present during any B, C, D ground-disturbing activity within Holy Ghost ipomopsis and other sensitive plant species occupied habitats. 31 Where Holy Ghost ipomopsis or other sensitive plant roots may be intermingled B, C, D with weed roots, a Forest Service biologist or other qualified person will determine how to safely remove the weed(s). 32 Herbicide use proposals within any threatened, endangered, or sensitive plant B, D species potential habitat will require a survey of that habitat, if possible. If no survey is conducted, the potential habitat will be treated as if occupied by the threatened, endangered, or sensitive plant and all applicable occupied habitat design features will apply. Wildlife, including Threatened, Endangered and Sensitive Species 33 For treatment areas exceeding 1 acre within threatened, endangered, or B, C, D sensitive species wildlife habitat, surveys for the species will be conducted prior to implementation. If surveys are not conducted prior to implementation, that area will be treated as if occupied. Within occupied threatened, endangered, or sensitive species habitats, loud, persistent noise disturbances or modifications of breeding habitat features will be avoided. If a potentially adverse effect cannot be avoided, prepare a supplemental biological assessment and consult with U.S. Fish and Wildlife Service to determine the appropriate design features. 34 For occupied Mexican spotted owl and southwestern willow flycatcher habitat, B, C, D applicable breeding season restrictions will be implemented as specified in forest plans and U.S. Fish and Wildlife Service recovery plans for those species. 35 In areas that have suitable habitat for wintering bald eagles and where weed B, C, D treatments are proposed during that period (winter months through March), a presence/absence survey must be completed within a 0.5-mile radius of the work site before any work can begin and following any breaks of more than 10 days. If an eagle is present within the 0.5-mile radius, work will stop until the bird leaves of its own volition or if, in consultation with the U.S. Fish and Wildlife Service, a Forest Service biologist determines that the potential for harassment is minimal. If bald eagles nest on National Forest System land within 0.5-mile of areas planned for treatment, the U.S. Fish and Wildlife Service will be contacted to determine what additional consultation may be needed.
35 Invasive Plant Control Project
Row No. Description of Design Feature and Monitoring Requirement Alternatives 36 Survey to protocol must be completed for all treatment units within southwestern B, C, D willow flycatcher occupied habitat (Carson National Forest) before treatment can begin, if the timing of treatment coincides with dates birds are likely to be present in the area. If the flycatcher is found, no treatments can occur; if the flycatcher is not found, treatment can proceed. 37 No prescribed burns will be done within Mexican spotted owl protected activity B, C centers. Treatments will be done by hand pulling, grubbing, or herbicide application during part of the breeding season (early June to mid-July) to be effective. Treatments will be short-duration, low-disturbance activities that would occur once or twice in a season (depending on size of the treatment area). A biologist can accompany applicators to monitor any owl activity that might occur. A year after treatment, monitoring would be done for any reoccurrence of the weed. 38 In areas proposed for treatment occupied by Forest Service sensitive wildlife B, C, D species, and where individuals in the population may be impacted, a Forest Service biologist will prescribe design features to avoid or minimize the impacts to individuals, while continuing to maintain population viability and avoid a trend toward Federal listing. 39 Only herbicides documented to have a low risk to wildlife and domestic animals B, D (for both ingredients and application rates) will be used. 40 No controlled grazing with sheep or goats will be permitted in areas occupied or B, C frequented by bighorn sheep (high country/wilderness). 41 No weed treatments will occur in Jemez Mountain salamander habitat during the B, C, D late summer monsoon season when salamanders are above ground. In areas receiving 5 consecutive days of rain, treatments will be stopped until a Forest Service biologist or other qualified person determines the surface has dried sufficiently to resume treatment. 42 No herbicide or soil-disturbing treatments, including controlled grazing, will occur within 50 feet of Rio Grande cutthroat trout occupied streams between June 1 and June 30 (spawning season). Air, Soil, Water, Riparian, Fish, and Other Aquatic Resources 43 All prescribed burning must comply with the New Mexico smoke management B, C requirements (permitting, monitoring, and so forth) to maintain levels of these emissions within State and Federal air quality standards. 44 Heavy mechanized equipment such as tractors with tillers or mowers will not be B, C used on slopes over 40 percent, to minimize erosion potential. 45 Heavy equipment will not be used to mechanically dig up weeds within riparian B, C zones unless a Forest Service soil, water or fisheries specialist examines the site-specific conditions and determines there would be no adverse impacts to water quality, stream morphology, or aquatic resources. 46 Herbicides used within 25 feet of a waterbody, or within riparian or other areas B, D with a shallow water table, will be restricted to hand application of a short-lived, nonleachable herbicide that has been registered by the Environmental Protection Agency for use on permeable soils, near water, or in areas having shallow water tables (for example, 2,4-D, glyphosate, triclopyr). Herbicides with picloram as their active ingredient (for example, Tordon 22K) will not be used in these locations or within the municipal watersheds of the Gallinas and Santa Fe Rivers. A Forest Service soil, water, or fisheries specialist, or other qualified person will verify and map, and if necessary, visibly mark these areas. 47 Herbicide application within a riparian area or 50 feet from a waterbody is limited B, D to hand application onto individual weed plants (using backpack spray wand or glove, wick, or rag). Backpack spray application upwind of surface water or when precipitation is likely will be avoided. If necessary, a Forest Service soil, water, or fisheries specialist, or other qualified person will visibly mark these areas prior to implementation.
36 Final Supplemental Environmental Impact Statement
Row No. Description of Design Feature and Monitoring Requirement Alternatives 48 Mixing, pouring, loading, or transferring herbicides (even small amounts) will not B, D occur within 200 feet of open water and will comply with the approved chemical handling, and spill prevention and containment plan (see appendix 6). In the event of a spill of sufficient quantity that would reasonably injure or be detrimental to human health, animal or plant life, or property, the Forest Service will contact the New Mexico Environment Department Ground Water Quality Bureau chief and Surface Water Quality Bureau chief. 49 In riparian areas or next to live waterbodies containing fish, methods used must B, C, D have been documented to have low risk to aquatic species. 50 Prescribed burning in riparian areas will be incidental to the primary activity (for B, C example, pile burning slash from mechanical treatment of woody invasive species). No broadcast burning will be permitted in riparian areas solely for the purpose of treating weeds. Heritage Resources 51 Adhere to “Appendix F - Standard Consultation Protocol for Noxious Weed B, C, D Control” of the First Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities, including conducting pre- implementation heritage inventories and evaluations, applying appropriate design features to avoid adverse impacts, consulting with the State Historic Preservation Office and Tribes, and monitoring treatment activities for effects to cultural resources. 52 Ground-disturbing activities will be designed to avoid direct impacts to cultural B, C resource sites. Root tilling, mowing, hand pulling, digging, or other weed treatments that disturb the soil beyond an aggregate of one meter square will require heritage inventory, evaluation, and consultation with the State Historic Preservation Office and Tribes. Follow the protection measures specified under stipulation 6 in appendix F of the protocol discussed in #51 above. 53 No herbicides will be applied from vehicles within 25 feet of cultural resources B, D consisting of perishable materials with analytic or informational value, including wood, organic ceramic paints, datable materials, and residues on artifacts. Within 25 feet of such cultural resources, herbicides must be applied by hand to individual weeds to avoid getting herbicides or carrier fluids onto those remains. Prior to implementation, a Forest Service archaeologist or other qualified person will mark areas for hand application or avoidance. 54 Apply the design features listed previously under Native Vegetation and B, C, D Threatened, Endangered, and Sensitive Plants to minimize potential harm to plants of ethnographic concern and native plants. 55 Notification of Tribes and other traditional use groups will occur before herbicides B, C, D are used to inform them of pending chemical treatment activities and schedules. This measure will reduce the risk to native plants used for traditional cultural purposes and the risk to the health of individuals who gather these plants. 56 Sheep or goat grazing will not be used on heritage resource sites easily B, C damaged by trampling as identified through heritage resource inventories prior to implementation. 57 Conduct fuel assessments and remove fuels from around cultural resource sites B, C with perishable materials before prescribed burning or avoid burning around sites with perishable materials altogether. Use burn prescriptions that ensure low temperature, intensity, duration, and residence time on sites that fire will burn through. Municipal Watersheds 58 Weed treatments within the Santa Fe and Gallinas municipal watersheds will be B, C, D agreed to and coordinated with the appropriate officials for the cities of Santa Fe and Las Vegas, respectively. Proposed use of herbicides within these municipal watersheds would occur only upon agreement from officials of these cities.
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Row No. Description of Design Feature and Monitoring Requirement Alternatives Monitoring and Adaptive Management 59 Weed inventories and mapping will be conducted annually, and treatment of B, C, D newly found populations will be identified and prioritized based on criteria in the “Adaptive Strategy” section of this chapter. 60 Treated sites will be monitored, evaluated, and the results documented to B, C, D determine: - Effectiveness of the method(s) used in meeting the objective; - Whether impacts to resources or people were within the scope of predictions; and - Implementation and effectiveness of design features, and whether mitigations should be modified or added to enhance effectiveness. 61 Changes in prescriptions made as a result of monitoring and evaluation, and B, C, D treatments for newly found weed populations must comply with all design features and monitoring requirements in the environmental impact statement. The actions and effects must be within the scope of those considered in the environmental impact statement. New actions or effects outside of those considered in this environmental impact statement will be evaluated in accordance with Forest Service Handbook 1909.15, Chapter 10, Section 18, to determine if additional environmental analysis under the National Environmental Policy Act is required.
Forest Plan Amendment [Additional paragraphs]
The incorporation of the amendment will be conducted through use of the 1982 rule procedures as allowed by the transition language of the 2012 planning rule (36 CFR 219.17(b)(3)).
As stated on page 24, the predecisional administrative review (objection) process employed for the project will also be used for administrative review of the proposed amendment for the selected alternative (36 CFR 219.59(b)).
38 Final Supplemental Environmental Impact Statement
[Replaces table 11]
Table S-12. Proposed amendment to the Santa Fe National Forest Plan (pp. 75-76) Proposed Forest Plan Direction Existing Forest Plan Direction (bold text shows new language) 5. Chemical treatments may be applied: 5. Chemical treatments may be applied: a. when determined through an environmental a. when determined through an environmental analysis to be environmentally, economically, and analysis to have no adverse environmental, socially acceptable. economic, or social impacts for longer than 6 months. b. on areas outside municipal watersheds and b. within municipal watersheds only when the human habitation. municipality concurs with the proposed treatment and design features.4 c. on soils with moderate or high revegetation c. on any soil provided that soil erosion on that potential. site is not increased to above the tolerance level identified in the terrestrial ecosystem survey for the affected soil unit. d. on areas that would benefit from selective d. on areas that would benefit from selective control of plant species. control of plant species. e. on areas where the chemicals will not violate e. on areas where the chemicals will not violate State water quality standards. State water quality standards. f. on soils with moderate to high cation exchange f. In areas of human habitation: capacity. • Apply this adaptive strategy identified in the EIS in Table S-10: Method(s) must have been documented to be low risk of causing harm to people. • Apply the design features listed in the EIS in Table S-11 under “Human Health/Safety and General Mitigations.” g. on piñon-juniper retreatment areas on stands g. on piñon-juniper retreatment areas on stands where 80 percent of the trees are less than 6 feet where 80 percent of the trees are less than 6 feet in height, with more than 25 trees per acre. in height, with more than 25 trees per acre.
Permits and Authorizations Required [Replaces entire section] • Consult and obtain concurrence from the U.S. Fish and Wildlife Service on the Forest Service’s biological assessment and determinations of effects to threatened or endangered species. This will occur prior to signing a record of decision authorizing project implementation (Completed: Carson National Forest Consultation # 2-22-00-I-237 and Santa Fe National Forest Consultation # 2-22-00-I-324 (USFWS 2005) and recent consultation Santa Fe National Forest Consultation # 02ENNM00-2015-I-0149 (USFWS 2015)). • Consult and obtain concurrence from the New Mexico State Historic Preservation Officer regarding identification, evaluation, and determination of effects of the project on heritage resources. Final consultation and concurrence from the State Historic Preservation Office will occur prior to implementation (Pursuant to the programmatic agreement, subsequent initiation of noxious weed control projects will be contingent upon completion of the identification and protection of historic properties, and
4 In a 2004 comment on the draft environmental impact statement, the New Mexico Environment Department suggested the Forest Service may wish to “retain the prohibition on application of certain higher risk herbicides, such as picloram [in municipal watersheds].” Picloram would not be used in municipal watersheds. The design features listed in Table S-11 (such as rows 1, 4, and 46 to 49) and the requirement to obtain the concurrence of the municipality ensure the safety of the application method. Retaining flexibility in weed treatments is crucial to the success of this project.
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compliance with applicable provisions of National Historic Preservation Act in accordance with Appendix F - Standard Consultation Protocol for Noxious Weed Control” of the First Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities.) • Obtain concurrence from U.S. Department of Agriculture Animal and Plant Health Inspection Service (APHIS) and the State of New Mexico for any biological control method to be used. • Forest Service employees or contractors supervising application of herbicides must first be certified by New Mexico Department of Agriculture (NMDA). Herbicide application must comply with all requirements found in Forest Service Manuals 2900 and 2150, including the Region 3 Supplemental Manual 2150.45. This includes pre- and post-implementation requirements as well as coordination with other agencies. • Following Forest Service policy and procedures, regional forester review and approval must be obtained before using herbicides in wilderness and any other situations as directed. • Comply with the New Mexico Pesticide Control Act governing public applicators, record keeping, and other requirements. • Prior to burning, a burn plan must be prepared and burn permit obtained from New Mexico Environment Department, Air Quality Bureau. • Obtain a permit for any discharge of pesticides into “Surface Waters of the United States” as required by the Environmental Protection Agency’s National Pollutant Discharge Elimination System (NPDES) authorized under the Clean Water Act. • Comply with the National Pollutant Discharge Elimination System interim guidance (January 9, 2012) and any future Regional guidance (as issued) governing compliance with the Environmental Protection Agency’s pesticide general permit (PGP) under the Clean Water Act. • Comply with the antidegradation policy of the New Mexico Environment Department governing protection of water quality in designated Tier 3 waters (outstanding national resource waters) under the Clean Water Act.5 Consult with, and obtain concurrence from, the New Mexico Environment Department Surface Water Quality Bureau regarding any treatments that could result in short-term degradation to the chemical, physical, or biological integrity of these waters. Comparison of Alternatives [Replaces entire section] This section provides a comparative summary of the alternative treatments and effects of implementing each alternative. Information is focused on activities and effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives.
Likely the most important consequence of any of the action alternatives (alternatives B, C, and D) would be preventing the spread of weeds into large monocultures, which would then require more drastic means of treatment, like spraying herbicides from airplanes. The Carson and Santa Fe National Forests are uniquely positioned to prevent the spread of weeds because the populations are relatively small and isolated, when treatments in general are the most effective.
Table S-13 provides a comparison of alternatives based on the significant issues or effects, as well as how well the alternatives meet the purpose and need (objectives) for the project. The comparison table is intended to provide the public and decision makers with a basis for choice between alternatives.
5 http://www.nmenv.state.nm.us/swqb/onrw/
40 Final Supplemental Environmental Impact Statement
In addition to the summarized comparison of alternatives related to significant issues and project objectives, there are a few other key differences between the effects of each alternative, based on the effects analysis described in chapter 3. The most noticeable consequences from weed treatment under alternatives B, C, and D would be the long-term, beneficial improvements to native ground vegetation such as grasses, forbs, and shrubs. Riparian vegetation such as rushes, sedges, willows, and cottonwoods would particularly benefit from this project. Protecting and improving native plant communities would have positive effects on soil and water conditions, as well as wildlife and aquatic habitats (particularly due to enhancing riparian vegetation).
Negative effects to native vegetation, soil, water and aquatic organisms would be minor and of short duration. The increases in sediment (more with alternative C) and any possible herbicide delivery to streams (for alternatives B and D) would have no measurable, long-term consequences. There would be a low risk of adverse impacts to fisheries, including Rio Grande cutthroat trout (a sensitive fish species) or other aquatic organisms based on application of design features, risk assessments, and Environmental Protection Agency guidelines. Alternative C would cause more ground disturbance and associated impacts to soils, especially on soils with a severe erosion hazard rating. However, all alternatives would remain within soil erosion tolerance levels needed to protect long-term soil productivity. Soils with low revegetation potential would receive herbicide treatments under alternatives B and D. Reestablishing native vegetation could take longer under alternative C due to soil disturbance and germination of weed seed from the seed bank. Mitigation requirements for all alternatives would ensure that vegetative ground cover is adequately reestablished. With the required design features, all soil and water quality standards would be met.
Differences between alternatives in their effects to air quality, heritage resources, livestock grazing, recreation, wilderness, and visual resources are expected to be negligible. There would be minor increases in noise and traffic associated with the action alternatives, although generally within background levels.
By controlling the spread of weeds and protecting native plant communities, habitats, and watershed conditions on the two national forests, alternatives B and D would maintain or enhance social or economic conditions, particularly for local rural communities in northern New Mexico who typically rely on the forest natural resources for their livelihood, traditional culture and quality of life.
Table S-13. Comparison of alternatives by issues and objectives (purpose and need) Significant Issues and Objectives Alternative A Alternative B Alternative C Alternative D Issue 1: No risk of health Low risk of health No risk of health Same as Herbicides and impacts from impacts to workers or impacts from alternative B but Human Health herbicide general public from herbicide exposure slightly higher risk exposure (0 acres using herbicides based (0 acres treated with of exposure for treated with on EPA registration, risk herbicides). Slightly people with herbicides). assessment data, and increased risk of chemical design features. Higher exposure to smoke sensitivities as risk to people with from prescribed 100 percent of multiple chemical burning and slightly treatments are sensitivities, although elevated risk of with herbicides. public notification mechanical injuries requirement provides a to workers. means for people with this condition to avoid exposure to treated areas.
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Significant Issues and Objectives Alternative A Alternative B Alternative C Alternative D Issue 2: No risk of Low risk of herbicide No risk of herbicide Same as Herbicides and herbicide impacts impacts to wildlife based impacts to wildlife. alternative B Wildlife to wildlife. Weeds on EPA registration, risk Less improvement would degrade assessments, and in wildlife habitat. native plant design features. Native habitats, wildlife habitat quality especially riparian (especially riparian areas important to habitat) would improve numerous as weeds are controlled. species. Issue 3: No short-term Short-term reduction in Similar to alternative Same as Herbicides and impacts from some non-target plant B for short-term alternative B Native Plant herbicides. In the species. Long-term reduction in non- Communities long term, weed- improvement in target plants. Low to caused decline in abundance and diversity moderate long-term abundance and of native plant improvement in diversity of native communities. native plant plant communities. Weed communities. spread rate may equal or exceed control rate without herbicide use. Issue 3 No risk of No impact to threatened Same as alternative Same as Continued: treatment-related or endangered plants B alternative B Rare or impacts. In the due to mitigation Sensitive long term, weeds measure. For sensitive Native Plant may cause a plants, treatments “may Species decline in impact individuals but federally listed or are not likely to result in sensitive plant a trend toward Federal species listing or loss of population viability,” due to design features and species locations. Issue 4: Cost Not cost effective; Moderately cost Least cost effective. Most cost and Treatment would incur much effective. effective. Effectiveness higher costs in (based on level future. of effort to meet objectives) Objectives: No protection; no Highest level of Low level of High level of Protect native effectiveness. treatment effectiveness effectiveness and effectiveness and plant Weed-related and resource protection resource protection resource communities, impacts to from weed impacts due from weed impacts. protection from soil and water vegetation, soil, to integrated Fewer acres treated weed impacts. quality, wildlife water, riparian combination of annually for a given Not quite as habitat, and habitat, and other treatments including budget due to need effective as long-term resources would herbicides. for repeat herbicides ecosystem continue. treatments on the combined with health same acreage more other methods. often than when combined with other methods.
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Chapter 3. Affected Environment and Environmental Consequences Introduction [Replaces entire section] This chapter summarizes the physical, biological, social, and economic environments of the project area and the environmental consequences of implementing the proposed action and alternatives. The environmental consequences focus on the project’s purpose and need and the issues identified in chapter 1, providing the scientific and analytical basis for the comparison of alternatives presented at the end of chapter 2. As used in this final supplemental environmental impact statement, “impact” means a harmful, undesirable, or negative effect.
An agency-approved adaptive weed management strategy was incorporated into this proposed project to address uncertainties about new or undiscovered weed infestations as well as post-implementation monitoring results that may indicate a need to modify treatment methods to meet project objectives. In the context of this uncertainty, the effects described in this chapter include consideration of the adaptive strategy, including use of treatment method selection criteria, prioritization ratings, thresholds, limitations, design features, and monitoring requirements described in chapter 2. Cumulative Actions for Cumulative Effects Analysis [Replaces entire section] This section discusses other activities and land uses occurring within and surrounding the Carson and Santa Fe National Forests that could contribute to cumulative effects when added to the effects of weed treatments in this project. Cumulative effects are those impacts on the environment resulting from the incremental impacts of the action when added to other past, present, and reasonably foreseeable future actions and can result from individually minor but collectively significant actions taking place over a period of time. Cumulative effects can be beneficial or adverse.
Unless noted in an individual resource section, the geographic extent for which cumulative effects have been evaluated consists of land administered by, and immediately adjacent to, the two national forests, based on the area directly or indirectly affected by project activities. The time period for cumulative effects is the time during which project activities are anticipated to occur: approximately 10 years (or more) beginning in 2017. The existing condition for each resource encompasses the past and present actions shown in table S-14. Because weed infestations are well distributed spatially, no concentration of treatment would occur across the 3 million acres comprising the two forests.
Past and Present Actions (1987–2014) On June 24, 2005, the Chairman of the Council on Environmental Quality provided guidance to agencies on the consideration of past actions in cumulative effects analysis (Connaughton 2005):
“The environmental analysis required under NEPA is forward-looking, in that it focuses on the potential impacts of the proposed action that an agency is considering. Thus, review of past actions is required to the extent that this review informs agency decision-making regarding the proposed action…Generally, agencies can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into the historical details of individual past actions.”
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Table S-14 shows past and present actions that have affected the composition of vegetation and presence of weeds in the cumulative effects area. The table provides a short description of the action; each specialist describes the effect or trend pertinent to their resource in their section. These actions form the baseline for the cumulative effects analysis.
Reasonably Foreseeable Actions Table S-15 shows the reasonably foreseeable future actions that could cumulatively contribute effects from this project. It contains only human actions that are reasonably foreseeable as defined by the courts (for example, Weinberger v. Catholic Action of Hawaii, 454 US 139, 70 E.Ed.2d 289 (1981)). The table provides a short description of the action; each specialist describes the effect or trend pertinent to their resource in their section.
Table S-16 summarizes the cumulative effect to the key issues identified in chapter 1. The left column in the table states the key resource followed by the specific effect this project could cause that resource. The middle columns display other past, present, or foreseeable future actions expected to cumulatively contribute to, or counteract, the specific effect listed in the left column. The last column, on the right, predicts the overall cumulative effect to the resource listed.
Table S-14. Past and present actions (1987-2013) contributing towards the cumulative effects baseline Action Description Comment Annual treatment of noxious weeds in Removes noxious weeds by pulling, For example, herbicide treatment of the Carson and Santa Fe National grazing, mowing, treating with saltcedar on the Jemez Ranger Forests chemicals, or other methods. District from 1999 – 2002; goat grazing of yellow toadflax south of Tres Piedras; annual, ongoing manual control by both national forests (hand pulling) Road construction and maintenance Uses heavy equipment to build or maintain permanent or temporary roads. Trail construction and maintenance Uses hand tools or light equipment (for example, all-terrain vehicle) to build or maintain trails. Creation of unauthorized routes Created by repeated driving in the same place off system roads or trails. Subdivision and development of private inholdings and land adjacent to the two national forests Mining claims and development of mining Wildfires, including suppression and This category includes suppression For a complete list of wildfires since rehabilitation activities such as use of fire 1987 in the Carson and Santa Fe retardants and building fire line with National Forests, see the project hand tools or heavy equipment. It record. also includes rehabilitation work such as seeding and mulching to reduce erosion. Hazardous fuels treatment and Thinning trees by hand or with For a complete list of hazardous fuels prescribed burning equipment. Conducting prescribed projects since 1987 in the Carson and fires. Santa Fe National Forests, see the project record. Livestock grazing Annual grazing of cattle pursuant to permit terms.
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Action Description Comment Jemez National Recreation Act This act established the Jemez National Recreation Area to conserve, protect, and restore the recreational, ecological, cultural, religious, and wildlife resource values of the Jemez Mountains. The Jemez National Recreation Area is comprised of 100,000 acres within the Jemez Mountains. The Santa Fe National Forest has developed numerous recreational facilities, campgrounds, day use sites, and fishing access, within the Jemez National Recreation Area. Wild and Scenic Rivers – Pecos, East Designated these rivers for their Fork Jemez, and Rio Chama (SFNF) "outstandingly remarkable scenic, and Rio Grande (CNF) recreational, geologic, fish and wildlife, historic, cultural, or other similar values, shall be preserved in free-flowing condition, and that they and their immediate environments shall be protected for the benefit and enjoyment of present and future generations" (Public Law 90-542, 1968). Creation of the Valles Caldera The creation of the Valles Caldera National Preserve National Preserve made lands previously in private ownership open to public use. The Valles Caldera National Preserve is made up of 89,000 acres within the Jemez Mountain Range and offers numerous recreational opportunities. Land transfers from the Carson and Santa Fe National Forest to other entities, for example: San Ildefonso and Santo Domingo. Respect the Rio program The Respect the Rio program is a multi-faceted restoration and education program started in 2001 and designed to balance the need for preservation of riparian and flood- prone areas with needs of the public. The Respect the Rio Program seeks to do this by accomplishing the following goals: 1. Identifying and addressing water quality issues that have developed from recreational use. 2. Educating the public about habitat, habitat needs, and ongoing restoration projects. 3. Creating community partnerships. 4. Creating a program and materials easily adaptable to other forests and agencies. Acquisition of lands, for instance The Forest Service acquires lands A comprehensive list of acquisitions is Echo Amphitheatre (Carson National through purchase, exchange, or not available at this time. Forest) transfer.
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Action Description Comment Road decommissioning Removes roads from the landscape, A comprehensive list of past road usually using heavy equipment to decommissioning is not available at restore the natural slope and reseed. this time. Has also occurred naturally with vegetation growing in unused roads. Forest product collection This includes products covered by a permit, such as fuelwood and Christmas trees, and other products such as piñon and products used for religious ceremonies. Administrative use This includes uses authorized by the Forest Service with a special use permit (excluding forest product collection) and the use of Forest Service roads by Forest Service staff to manage the national forests. Examples of activities authorized by a special use permit are access to communication sites, access to utility corridors, and outfitter and guide operations. Weed treatments on land in other Removes weeds by pulling, grazing, For example: mowing and herbicide jurisdictions mowing, treating with chemicals, or application in rights-of-way by the other methods. New Mexico Department of Transportation; herbicide treatments by private landowners within or adjacent to the national forests, with or without the participation of local soil and water conservation districts (extent unknown); New Mexico Salt Cedar Control Project along the Pecos and Rio Grande Rivers (2002- 2003) by the New Mexico Association of Conservation Districts; treatment of Russian olive and saltcedar by various soil and water conservation districts (2003) under the Non-Native Phreatophyte Eradication Project along the Rio Grande; big sage control treatments on the Jicarilla Reservation; treatment of Siberian elm along the Santa Fe River by the Santa Fe Watershed Association and the City of Santa Fe; weed treatments on Bureau of Land Management lands. Oil and gas leasing The Jicarilla Ranger District (Carson National Forest) has over 800 gas wells with associated roads, pipelines, and other facilities. In November 2012, the Santa Fe National Forest signed a decision to amend the forest plan to allow oil and gas leasing with certain stipulations. Preparation of travel management Designates a system of roads and All national forests and grasslands in plans and motor vehicle use maps by trails where people are allowed to New Mexico, and some Bureau of other national forests and agencies drive. Generally reduces the amount Land Management districts. of driving off-road allowed.
46 Final Supplemental Environmental Impact Statement
Action Description Comment Special Use Permits – acequia Replacement and/or repair of improvements, rights-of-way for acequia headgates and related pipelines (water/natural gas), infrastructure (rights-of-way for driveways, communication sites, driveways, pipelines, electric lines, outfitter/guides, etc. etc.) to private lands, authorization for outfitters and guides for recreational activities within, and adjacent to, National Forest System lands.
Table S-15. Reasonably foreseeable future actions (2015-2025) Action Description Comment Preparation of travel management Designates a system of roads and All national forests and grasslands in plans and motor vehicle use maps by trails where people are allowed to New Mexico, and some Bureau of other national forests and agencies drive. Generally reduces the amount Land Management districts. of driving off-road allowed. Transfer of management of lands in Senate Joint Memorial 16 authorized Pecos Canyon from New Mexico New Mexico State Parks to enter into Department of Game and Fish to the a joint powers agreement with the State Parks New Mexico Department of Game and Fish to better manage recreation on 186 acres of land divided among six locations along the Pecos River. These locations provide fishing access, day use, and overnight camping opportunities along the Pecos River. Projects on the schedule of proposed The project record contains the list of actions projects on the most recent schedule of proposed actions as of the date of this writing. Geothermal leases in Coyote and The Santa Fe National Forest is The project record shows a map of Cuba Ranger Districts expecting a geothermal leasing the area expected for leasing. The proposal in the near future. The grey striped area is where the proposal would be to drill exploration proposed leasing would be requested. wells north and west of the Valles Caldera National Preserve. Small roads would be developed to access the exploration wells. If the project moves to completion, production wells and a powerline would be installed. Oil and gas leases in Cuba Ranger The proposal is to lease additional The project record contains a map District acreage adjacent to lands currently showing existing oil and gas leases leased for oil and gas. Short roads (grey striped areas) and those would be developed to any new wells proposed for expansion or installed and would remain in use improvement (red boxes, on legend until the well is abandoned at which as "Pending Expressions”). point the road would be reclaimed. Oil and gas development on the The reasonable foreseeable Jicarilla Ranger District development scenario projects the addition of up to 700 new wells within the planning period. The actual number of wells depends on many factors, including the economy and changes in technology.
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Action Description Comment Acquisition of Miranda Canyon The Forest Service acquires lands (Carson National Forest) through purchase, exchange, or transfer. This parcel is approximately 5,000 acres. Weed treatments on land in other Removes weeds by pulling, grazing, For example, mowing and herbicide jurisdictions mowing, treating with chemicals, or application in rights-of-way by the other methods. New Mexico Department of Transportation; herbicide treatments by private landowners within or adjacent to the national forests, with or without the participation of local soil and water conservation districts (extent unknown); New Mexico Salt Cedar Control Project along the Pecos and Rio Grande Rivers (2002 – 2003) by the New Mexico Association of Conservation Districts; treatment of Russian olive and saltcedar by various soil and water conservation districts (2003) under the Non-Native Phreatophyte Eradication Project along the Rio Grande; big sage control treatments on the Jicarilla Reservation; treatment of Siberian elm along the Santa Fe River by the Santa Fe Watershed Association and the City of Santa Fe; weed treatments on Bureau of Land Management lands.
48 Final Supplemental Environmental Impact Statement
Table S-16. Summary of cumulative actions by key resource Other Actions Key Resource and Effect Contributing to the Effect Other Actions Countering Predicted Cumulative to that Resource to the Resource the Effect to the Resource Effect Human Health and Other actions that Creation of motor vehicle The risk of exposure to the Safety: risk of health introduce chemicals into use maps (fewer places that public or workers is impacts from herbicide the environment include, people can drive); considered to be negligible exposure but are not limited to: restoration projects (less (unforeseen accidents herbicides recently applied chance of needing fire excepted). Because the or expected to be applied retardant) such as El Rito risk of exposure is in northern New Mexico by Canyon Landscape immeasurable (below San Juan and Sandoval Restoration Project, Environmental Protection County Weed Management Southwest Jemez Agency standards), the Areas, Soil and Water Mountains Landscape cumulative effect cannot be Conservation Districts, Restoration Project, Upper measured. Bureau of Indian Affairs, Bitter Creek Project, and the Valles Caldera National Tio Gordito Project Preserve, Bureau of Land Management, National Park Service, Santa Fe Watershed Association, The Nature Conservancy, and Audubon Society. Other actions that may introduce chemicals are vehicle use; maintaining, constructing, and reconstructing facilities and roads; extracting oil, gas, geothermal, and mineral resources; and the aerial application of fire retardant. Native Vegetation: loss of Other actions that could Other actions that would Because the loss of native native plants cumulatively cause a loss cumulatively promote native plants caused by the of native plants are cutting plants are cutting trees and implementation of this trees and prescribed prescribed burning (for project is expected to last a burning (for a season or example, in the same season or less, it would not less); grazing livestock; project as listed above), cause negative effects camping outside developed weed control activities on when considered sites; constructing new public and private lands, cumulatively with other facilities (for example, seeding, planting, and actions. Resumidero Campground; erosion control following Buckman water diversion wildfires, fuel reduction facilities, power lines, and activities (by allowing more road reconstruction); and sunlight to reach the forest clearing vegetation from floor and promoting native highway rights-of-way. grasses and shrubs), and meadow and riparian restoration projects. Wildlife and Fish: Same actions as described Same actions as described The risk of exposure to herbicide-related health for “Human Health and for “Human Health and wildlife and fish is risk Safety.” Safety.” considered to be negligible (unforeseen accidents excepted). Because the risk of exposure is immeasurable (below Environmental Protection Agency standards), the cumulative effect cannot be measured.
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Other Actions Key Resource and Effect Contributing to the Effect Other Actions Countering Predicted Cumulative to that Resource to the Resource the Effect to the Resource Effect Wildlife and Fish: Other actions that could Wildfire burn area The overall effect of this reduction in native cumulatively, but rehabilitation (seeding, project would be to vegetation and thus habitat temporarily, reduce native planting, etc.), fuel reduction promote native vegetation; vegetation cover that may activities (such as the cumulatively, it would provide nesting, foraging or projects listed under Human contribute to improved hiding cover habitat for Health and Safety), meadow habitat for fish and wildlife some species include and riparian restoration when considered in context thinning and removing projects, and fish habitat with other landscape trees, prescribed burning, improvement projects on restoration projects. livestock grazing, public and private lands also restoration projects along contribute to restoration of riparian areas, and weed high quality wildlife and fish control treatments on habitat. Weed control private or other public activities on public and lands. These actions, private lands add to the however, tend to reduce beneficial cumulative effects native habitats for a of the project by restoring season or less during and diverse vegetation/habitat just after project activities. that is being displaced by After a season, native weeds. vegetation is restored or increases. Wildlife and Fish: Other actions that could Actions that cumulatively Disturbance from this disturbance disturb wildlife and fish by reduce disturbance are road project is expected to be causing noise or having and area closures, road negligible because the people and machinery decommissioning projects, acreage of each habitat present are maintaining, and travel management. treated would be small. constructing, and Because the direct and reconstructing roads and indirect effect would be facilities; oil and gas immeasurable, there would operations; forest thinning; be no cumulative effect. prescribed burning; wildfire suppression; wildlife and fish habitat improvements (for example, eliminating exotic fish, building fish barriers for Rio Grande cutthroat trout); reintroductions of wildlife species; or animal control actions conducted by the New Mexico Department of Game and Fish; driving vehicles; and camping, picnicking, and other recreational activities.
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Other Actions Key Resource and Effect Contributing to the Effect Other Actions Countering Predicted Cumulative to that Resource to the Resource the Effect to the Resource Effect Soil and Water: risk of Actions that could Actions that are expected to The direct and indirect unacceptable levels of soil cumulatively increase cumulatively stabilize soils, effects to soil and water erosion, sedimentation, these impacts for a season increase soil productivity, are expected to be and/or chemical or less are thinning, and improve water quality negligible because of the contamination prescribed burning, are weed control activities mitigations measures in livestock grazing, on private and other public place for each of the maintaining, constructing, lands (by reducing erosion proposed treatments (for and reconstructing roads caused by some weeds and example, seeding bare soil, and facilities, driving on restoring native plants that not using certain herbicides and off roads and trails, have better soil holding near water, and others). camping, equestrian uses, characteristics); wildfire burn Because the direct and gathering forest products, area rehabilitation indirect effect would be and weed control activities (erosion/sediment control); immeasurable, there would on private or other public fuel reduction activities; be no cumulative effect. land. meadow and riparian restoration; dispersed recreation site restoration; and road and trail closures. Air Quality: smoke or dust Other prescribed burning, Projects, such as thinning, Dust from this project particulates wildfires, and residential that reduce the risk of would be negligible; firewood and trash burning wildfire. therefore, there would be add to regional haze. no cumulative effects. Driving on dirt roads within Smoke from prescribed and adjacent to the forests burning is regulated by the temporarily causes dust. State of New Mexico; thus, no cumulative effects can occur because no burning is allowed under conditions that smoke would exceed state levels.
Assumptions Common to the Analysis of Effects [New section] The interdisciplinary team used these assumptions when analyzing effects to the various resources. Assumptions specific to each resource are listed in each respective section.
For alternative A (no action): • Weeds would spread, on average, at a rate of 8 percent per year (DiTomaso 2000, Tu et al. 2001, Frid et al. 2013). The rate of spread will not be uniform; it is species- and site-dependent. For instance, different species thrive at different elevations.
For the action alternatives (B, C, and D): • Alternatives B and D would result in the control or eradication of current weed populations in approximately a decade. Some populations would be easily eradicated; others would only be contained. • New weed populations will establish themselves. People, wind, and animals all spread weed seed “hitchhikers”. • Alternative C would result in ongoing control without foreseeable eradication of current weed populations on the forests. The cost of mechanical treatment is very high, and the other methods are not as effective or efficient as the use of herbicides. • All pertinent design features and monitoring requirements would be implemented.
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• The action alternatives will not result in a noticeable increase in the amount of traffic and noise over normal Forest Service business. The reason for this is that no new personnel would be hired to treat weeds. Even if contracted, contract crews would constitute a very small portion of the driving and work taking place in the project area on a given day. • The Forest Service may drive off roads to treat weeds. This use is expected to be negligible, because most of the known weed infestations occur along roads and trails. Any off-road driving by agency personnel or contractors to treat weeds would be limited in time and space; it would not occur every day in the same place, nor is it projected to be a repeated event. • Each national forest expects to treat an average of 300 to 800 acres per year (600 to 1,600 per year for both forests on average) depending on funding and methods used. • Each national forest expects to treat no more than 1,500 acres per year (3,000 per year for both national forests as a maximum).
Vegetation [Replaces entire section] Affected Environment The first part of this section discusses the weeds known to occur as well as other potentially affected vegetation. The second part focuses on sensitive plant species.
The Carson and Santa Fe National Forests lie within the Colorado Plateau Semi-Desert Province and Arizona- New Mexico-Mountains Semi-Desert-Open Woodland-Coniferous Forest-Alpine Meadow Province (Mountains Regime) of the Tropical/Subtropical Steppe Division; and the Great Plains-Palouse Dry Steppe Province and the Southern Rocky Mountains Steppe-Open Woodland-Coniferous Forest-Alpine Meadow Province (Mountains Regime) of the Temperate Steppe Division within the Dry Domain. Fire, insects, and disease are the primary natural sources of disturbance to vegetation (McNab and Avers 1994).
Vegetation types follow altitudinal gradients similar to those in the southern Rocky Mountains. Dominant vegetation cover types occurring in the two national forests include grasslands, sagebrush, shrublands, piñon- juniper, oak, ponderosa pine, mixed conifer, spruce-fir and subalpine. Within each cover type, riparian vegetation is found along streams, around lakes, and in valley bottoms.
Weeds threaten the biological diversity of native plant communities, ecosystem processes, and rare or special status plants. Weeds are highly adaptable and adept at usurping available moisture and nutrients, quickly spreading, and supplanting native vegetation. Weed infestations invariably lead to (1) a decline in abundance of native plants that occupy the same or similar habitats as the weeds, (2) undesirable changes in site conditions such as soil pH that may be vital to native plant survival, and (3) an overall loss in the richness and diversity of native plants. The weed species known to occur on the two national forests are listed in chapter 1 and described in detail in appendix 2.
The final environmental impact statement listed the known weed populations in both national forests as being approximately 7,260 acres. Today, we are aware of about 13,260 acres of weeds. Though studies show expansion rates vary between 5 and 30 percent annually (Tu et al. 2001), the increase in weeds in the project area is mostly explained by more surveys of the locations of weeds by Forest personnel in the years since the final environmental impact statement was published.
Infestations of Russian knapweed, hoary cress, and yellow toadflax have been identified in highway rights-of- way within the national forest boundaries. Major wildfires have occurred on both national forests in recent years. Monitoring of recent high-severity burns has identified these areas as locations for new infestations.
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The Jemez Ranger District of the Santa Fe National Forest completed the Jemez Riparian Enhancement Project in 2000, which shows that saltcedar, Russian olive, and Siberian elm trees can be effectively controlled using selective herbicides. Previously approved, small-acreage, weed control treatments have also occurred on the Carson National Forest, and on both national forests where other agencies have jurisdiction such as along highway rights-of-way.
Table S-17 displays the total acres of known weed infestations by vegetation cover type. The following paragraphs briefly describe the location of each vegetation cover type and list the inventoried weed infestations found in each. Figure S-3 displays the dominant vegetation types on the Carson and Santa Fe National Forests.
Grasslands (Blue Grama, Perennial Grass Mix, Upper Forb Mix) Grasslands are widespread at all elevations within both forests, typically as openings within shrublands and forest cover types. Weed species include black henbane, bull thistle, Canada thistle, leafy spurge, musk thistle, Scotch thistle, yellow starthistle, and yellow toadflax.
Table S-17. Weed infestations by vegetation type as of August 1, 2013 Percent of Total Acres Percent of all Weeds in of Vegetation Vegetation This Type Infested Type Infested Vegetation Percent of Vegetation Type1 Total Acres2 with Weeds3 with Weeds Type Project Area Aspen 79,044 214 0.27 1.6 0.01 Big sagebrush 177,218 391 0.22 2.9 0.01 Blue grama 16,826 19 0.12 0.1 0.001 Deciduous shrub 113,185 734 0.65 5.5 0.02 mix Juniper 229,178 961 0.42 7.3 0.03 Perennial grass mix 205,676 1,137 0.55 8.6 0.03 Piñon-juniper 411,180 1,552 0.38 11.7 0.05 Ponderosa pine 936,088 5,101 0.54 38.5 0.16 mix Sparsely vegetated 16,086 47 0.29 0.4 0.001 Spruce-fir 318,255 355 0.11 2.7 0.01 Upper deciduous- 731,753 2,733 0.37 20.6 0.08 evergreen forest mix Upper forb mix 20,086 7 0.04 0.1 0.0002 Total 3,254,576 13,253 100.0 0.41 1. Vegetation types are from the mid-scale vegetation analysis. 2. Includes privately held lands within National Forest System boundary. 3. Total acreage is off by 3 due to rounding error (total acres of weeds is 13,256).
Sagebrush-Shrub (Big Sagebrush, Deciduous Shrub) Sagebrush and shrub are widespread at lower and middle elevations (6,200 to 7,900 feet) within both national forests, typically as openings in forest cover types. Weed species known to be present include black henbane, bull thistle, Canada thistle, Dalmatian toadflax, musk thistle, perennial pepperweed, Russian knapweed, Scotch thistle, and spotted knapweed.
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Piñon-Juniper (Piñon-Juniper, Juniper) Piñon-juniper cover types are widespread at lower and middle elevations (5,700 to 8,400 feet) within both national forests. Weed species known to be present include bull thistle, Canada thistle, Dalmatian toadflax, diffuse knapweed, leafy spurge, musk thistle, Russian knapweed, Scotch thistle, Siberian elm, and spotted knapweed.
Ponderosa Pine Mix Ponderosa pine cover types are widespread at middle elevations (7,200 to 9,000 feet) within both national forests. Weed species known to be present include bull thistle, Canada thistle, Dalmatian toadflax, diffuse knapweed, leafy spurge, musk thistle, Russian knapweed, Russian olive, Scotch thistle, and yellow toadflax.
Upper Deciduous-Evergreen Forest Mix and Aspen Mixed conifer and aspen cover types are widespread at middle and upper elevations (6,900 to 11,200 feet) within both national forests. Weed species known to be present include black henbane, bull thistle, Canada thistle, diffuse knapweed, leafy spurge, musk thistle, Russian knapweed, Scotch thistle, spotted knapweed, and yellow toadflax.
Spruce-Fir Spruce-fir cover types are widespread at upper elevations (8,700 to 11,500 feet) within both national forests. Weed species known to be present include bull thistle, Canada thistle, musk thistle, Russian knapweed, and yellow toadflax.
Riparian Areas and Valley Bottom Lands Riparian areas and valley bottoms with wet soils are widespread throughout all elevations within both national forests. Riparian areas often overlap other cover types at the mapping scale used for this analysis. Where information indicated riparian areas present, the acres were subtracted from other cover types so they were not counted twice. Weed species known to be present include bull thistle, Canada thistle, Dalmatian toadflax, cheatgrass, hoary cress, musk thistle, poison hemlock, Russian knapweed, Russian olive, saltcedar, Scotch thistle, Siberian elm, spotted knapweed, yellow toadflax, and Fuller’s teasel.
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Figure S-3. Dominant vegetation types on the Carson and Santa Fe National Forests
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Environmental Consequences to Vegetation Alternative A (No Action) [Replaces first paragraph] The no-action alternative would not meet the purpose and need. It would not help maintain or improve diverse, sustainable native plant communities in weed-infested areas. It would result in continued invasion and spread of weeds throughout the two national forests, particularly on, and near, acres currently infested. Without an overall system to treat weeds, the Forest Service would be required to complete National Environmental Policy Act analysis on individual projects to treat weeds using methods other than hand- grubbing, which alone has not proven effective. Given the conservative estimate of an 8 percent spread per year, the number of acres impacted by weeds would double over the next 10 years. When the un-inventoried areas or unidentified weed populations are factored in, there may be 10 to 20 percent more weed-infested acres than are currently inventoried.
[Additional paragraph] The establishment of weed monocultures would probably occur in some areas, which could alter historical trends and natural ecosystem functions and processes in native plant communities (DiTomaso 2000). For example, following the 1996 Dome Fire on the Santa Fe National Forest, cheatgrass became an established monoculture in Bland Canyon. This resulted in an earlier fire regime than what exists under native vegetation. Similarly, the amount of culturally important plants (such as osha (Ligusticum porter)) could be reduced as they are replaced by invasive species.
[Replaces last sentence of 4th paragraph, p. 71] Knapweed infestations would have long-term detrimental effects on soil and water resources (USDA Forest Service 2007).
Alternative B (Proposed Action) [Replaces first paragraph] Table S-18 through Table S-29 display the treatments proposed in the project area’s different vegetation types. The vegetation types are from the two national forests’ midscale vegetation analysis. Acreages of weeds do not match precisely for two reasons. First, rounding errors from the GIS analysis are present. Second, weed species would be treated by multiple methods, so the acres listed in these tables are double counted. For example, spotted knapweed could be treated using herbicides, grazing, and by manually pulling. Thus, these tables display the maximum number of acres that could be treated by the method listed. The project record contains the suite of methods proposed in each vegetation type.6
6 VEG03_MidscaleVegDomTypeAlternativesAcres_20131021.xlsx
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[The following tables replace tables 15 through 23]
Table S-18. Acres of treatment method in in aspen Treatment Alternative B Alternative C Alternative D Biological 15 15 0 Grazing 190 190 0 Herbicides 214 0 214 Manual 86 86 0 Mechanical 213 213 0 Prescribed fire 1 1 0 Total known acres of weeds 214 in this vegetation type
Table S-19. Acres of treatment method in big sagebrush Treatment Alternative B Alternative C Alternative D Biological 141 141 0 Grazing 146 145 0 Herbicides 391 0 391 Manual 231 231 0 Mechanical 391 391 0 Prescribed fire 55 55 0 Total known acres of weeds 391 in this vegetation type
Table S-20. Acres of treatment method in blue grama Treatment Alternative B Alternative C Alternative D Biological 16 16 0 Grazing 0 0 0 Herbicides 19 0 19 Manual 3 3 0 Mechanical 19 19 0 Prescribed fire 0 0 0 Total known acres of weeds 19 in this vegetation type
Table S-21. Acres of treatment method in deciduous shrub mix Treatment Alternative B Alternative C Alternative D Biological 193 193 0 Grazing 363 363 0 Herbicides 734 0 734 Manual 424 424 0 Mechanical 693 693 0 Prescribed fire 57 57 0 Total known acres of weeds 734 in this vegetation type
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Table S-22. Acres of treatment method in juniper Treatment Alternative B Alternative C Alternative D Biological 577 577 0 Grazing 227 227 0 Herbicides 961 0 961 Manual 749 749 0 Mechanical 938 938 0 Prescribed fire 104 104 0 Total known acres of weeds 961 in this vegetation type
Table S-23. Acres of treatment method in perennial grass mix Treatment Alternative B Alternative C Alternative D Biological 716 716 0 Grazing 378 373 0 Herbicides 1,137 0 1,137 Manual 951 951 0 Mechanical 1,094 1,094 0 Prescribed fire 7 7 0 Total known acres of weeds 1,137 in this vegetation type
Table S-24. Acres of treatment method in piñon-juniper Treatment Alternative B Alternative C Alternative D Biological 782 782 0 Grazing 357 357 0 Herbicides 1,552 0 1,552 Manual 1,040 1,040 0 Mechanical 1,467 1,467 0 Prescribed fire 221 221 0 Total known acres of weeds 1,552 in this vegetation type
Table S-25. Acres of treatment method in ponderosa pine Treatment Alternative B Alternative C Alternative D Biological 1,672 1,672 0 Grazing 2,099 2,094 0 Herbicides 5,101 0 5,101 Manual 3,626 3,626 0 Mechanical 4,870 4,870 0 Prescribed fire 295 295 0 Total known acres of weeds 5,101 in this vegetation type
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Table S-26. Acres of treatment method in sparsely vegetated areas Treatment Alternative B Alternative C Alternative D Biological 38 38 0 Grazing 0.01 0.0001 0 Herbicides 47 0 47 Manual 38 38 0 Mechanical 47 47 0 Prescribed fire 0.3 0 0 Total known acres of weeds 47 in this vegetation type
Table S-27. Acres of treatment method in spruce-fir Treatment Alternative B Alternative C Alternative D Biological 37 37 0 Grazing 317 317 0 Herbicides 355 0 355 Manual 136 136 0 Mechanical 355 355 0 Prescribed fire 0 0 0 Total known acres of weeds 355 in this vegetation type
Table S-28. Acres of treatment method in upper deciduous-evergreen forest Treatment Alternative B Alternative C Alternative D Biological 545 545 0 Grazing 1,762 1,759 0 Herbicides 2,733 0 2,733 Manual 1,695 1,695 0 Mechanical 2,619 2,619 0 Prescribed fire 149 149 0 Total known acres of weeds 2,733 in this vegetation type
Table S-29. Acres of treatment method in upper forb mix Treatment Alternative B Alternative C Alternative D Biological 7 7 0 Grazing 0.004 0.004 0 Herbicides 7 0 7 Manual 7 7 0 Mechanical 7 7 0 Prescribed fire 0 0 0 Total known acres of weeds 7 in this vegetation type
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[Replaces third paragraph, page 76] Biological methods avoid loss of non-target plants altogether, as the insects cannot be released without approval from the U.S. Department of Agriculture Animal and Plant Health Inspection Service, based on assurance the insects would only consume the target weed species. The effectiveness of using biological methods to control weeds and restore native species would be more gradual and would not be detectable in the short term. Manual methods would be able to usually avoid cutting or digging up non-target plants. Herbicides applied manually or with backpack sprayers would use directional spray devices that minimize herbicide drift on non-target vegetation. Adherence to wind and weather condition requirements would minimize the amount of spray that would drift through the air onto non-target plants. Vehicle-mounted herbicide spraying is less precise but includes a directionally controlled wand and on/off switch to minimize application to non-target vegetation. Mechanical, grazing, and burning methods would impact entire roadsides or areas treated, unless a torch is used to burn just weed species. However, those three methods are expected to be used sparingly (appendix 7) so they would have very little effect on native vegetation across the two national forests. In addition, because methods like burning, grazing, and mowing only remove the tops of plants, they would have a less intense, short-term effect on the ground cover. On a landscape level, the temporary reduction in native species would be negligible.
[Additional paragraph] Managed livestock grazing can work in combination with other methods to reestablish healthy, resilient native plant communities. For example, cattle grazing, used appropriately through timing, duration, and intensity, can effectively control cheatgrass. Altering the timing, intensity, and duration of livestock grazing in riparian areas that have been treated for saltcedar can favor reestablishment of the native riparian flora while slowing down the recovery of saltcedar.
[Additional paragraph] Alternative B is expected to be the most effective at controlling weeds; studies show herbicides alone are not as effective as when they are combined with other methods (DiTomaso 2000, Endress et al. 2012, Frid et al. 2013). Frid et al. (2013) found early detection and treatment, before a seedbed is established, were key components of controlling weeds. The same study found seeding with native vegetation (cultural methods), in combination with other treatments, greatly reduced the chance weeds would reestablish.
Alternative C–No Herbicides [Replaces entire section] The most noticeable effects to native vegetation would be the beneficial increase in native species abundance and diversity on the treated acres, similar to effects described for alternative B. The main difference with this alternative is that for a given budget, fewer acres would be treated each year. More follow-up on the same sites would be needed to control weeds. In particular, most deep-rooted perennial weeds, such as Canada thistle or Russian knapweed, cannot be controlled effectively with mechanical and physical methods alone without repetitive treatments conducted at the site over a number of years. Biological controls would likely be effective in the long term, after biocontrol insect populations have grown enough to have a significant effect on weed populations, which could take years. The other non-herbicide treatment methods are generally not as effective against weed species as herbicide treatment in combination with these other methods. For a fixed amount of funding, the acres treated would logically be fewer in alternative C than alternative B.
Regardless of the non-herbicidal methods used, follow-up weed treatments at relatively close intervals could potentially impact native vegetation because the treatment areas would be in a disturbed condition more often and for longer periods. Even though follow-up treatments would control weeds, each time an area was retreated, soils and native vegetation would be disturbed, which could create favorable growing conditions for all plants, native and invasive. Under this alternative, it is likely the rate of weed spread would exceed the rate
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of weed control, and the Forest Service would not be able to get ahead of the weed problem. Thus, effects in the long term would be most similar to alternative A (no action).
Alternative D–Herbicides Only [Replaces entire section]
Beneficial effects to native vegetation abundance and diversity on the treated acres would be very similar to effects described for alternative B. The key difference is the slightly reduced effectiveness of some herbicide treatments without the supplemental use of other methods. It is well known from past studies that the most effective weed control treatments are those utilizing a combination of herbicides and non-herbicide methods. This reduced effectiveness means repeated treatments may be required above what would be necessary if a combination of treatments were used.
Numerous species of weeds would not be controlled with herbicides alone. For example, saltcedar has been successfully treated with herbicides and mechanical treatments. The combination proved more effective at controlling or eradicating saltcedar than herbicides alone.
Continuous use of herbicides alone can lead to other problems. DiTomaso et al. (2006) report the repeated use of herbicides can have a detrimental effect to the legume species that are important components of rangelands, pastures, and wildlands. Herbicidal control that lowers the abundance of these forbs may cause losses in the ecological function of rangelands and may ultimately accelerate further degradation (Endress et al. 2012). Repeated use can increase the abundance of other undesirable species, particularly annual grasses like medusahead. Finally, one population of yellow starthistle in Washington developed a resistance to picloram, and was cross-resistant to clopyralid, which acts in the same manner. Thus, the potential exists for weeds to develop resistance to herbicides if used year after year (DiTomaso et al. 2006).
Unlike alternative C, this reduced effectiveness would not likely result in a reduction in the number of acres treated because the cost-effectiveness of treating with herbicides is high.
Cumulative Effects –Vegetation [Replaces entire section]
In all action alternatives, cumulative impacts to non-target plant species would stem from forest management activities, public land uses, and activities on other public and private lands, as described in the beginning of this chapter.
Cumulative Impacts to Native Vegetation The direct and indirect effects to native vegetation from controlling or eradicating weeds would be an increase in the amount, vigor, and diversity of native plants. The cumulative effect from projects affecting native vegetation is expected to be an overall increase in the amount, vigor, and diversity of native plants across the project area. The focus of forest management in the reasonably foreseeable future would primarily be restoring fire-adapted ecosystems, native vegetation, and ecosystem functionality.
Implementing this project would add to the short-term reduction in non-target vegetation from herbicides applied in other ongoing weed treatment projects on private inholdings and on other public lands in and around the two national forests. Long-term ecosystem restoration projects would compensate for activities that remove or damage native vegetation, including short-term removal of non-target plants from this proposed project.
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Photo 4. Russian knapweed in the Gallina area, Coyote Ranger District (Santa Fe National Forest photo)
Cumulative Impacts to Weeds The predicted direct and indirect effect of this project is the reduction in the acreages and species of weeds present on the two national forests. The overall cumulative impact, when added to other, ongoing activities in the spatial area is difficult to assess. Some projects and activities would promote weeds, while others have a tendency to reduce them. On balance, it appears the overall trend is towards the establishment of new weed populations.
For example, weeds could establish themselves in areas where activities disturb soil, such as thinning, firewood gathering, prescribed burning, dispersed recreation, grazing, road maintenance, road building, and road decommissioning even with preventive measures in place. Ongoing, common activities in the Carson and Santa Fe National Forests by weekend recreationists, forest firefighting crews, grazing allotment permittees, or livestock all have the potential to unknowingly spread weeds from one location to another, bring them onto National Forest System lands, or spread them onto other lands.
Wildfires that burn with moderate to high severity through populations of invasive weeds often result in an exponential growth of that population, both in homogeneity and spatial extent. Many weed species (such as cheatgrass) are fire-adapted and can quickly invade an area and spread beyond any ability to control them. During the suppression of large wildfires, firefighting personnel and equipment can be brought in from different locations within the United States. If the vehicles come from or pass through places with weed populations, they can introduce new weed species. Motor vehicles are capable of not only bringing invasive weeds onto the national forests but can just as easily transport weeds to other land ownerships.
Cyclic changes in weather (drought, wet warm springs, and late winter weather) and subtle changes in climate can increase the establishment and spread of nonnative species. Many nonnative grasses and forbs are cool season plants that can take advantage of relatively warm, wet springs at lower elevations or drought
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conditions that leave many native species unable to compete for limited moisture and nutrients. Lower elevation ecosystems, such as piñon-juniper woodlands, naturally have high amounts of bare soil, warmer weather, less available moisture during the growing season, and are more susceptible to disturbance and invasive plant establishment when compared to higher elevations where moisture is generally not limiting and herbaceous plant communities are more resilient and more able to compete with weeds.
The activities that would cumulatively reduce the amount of weeds in the two national forests are weed control projects on other lands and prevention and education efforts. Such projects would reduce the possibility of weed transport into the national forests. Conversely, treating weeds on the two national forests would reduce the potential to transport weeds onto other lands. The preventive measures associated with public land projects, such as cleaning vehicles before they arrive at a site, would tend to reduce the introduction of new populations.
Special Status Plants [Replaces entire section] Special status plants are those listed as threatened or endangered under the Endangered Species Act or designated sensitive by the Southwestern Region regional forester of the Forest Service. The vegetation specialist report in the project file has detailed habitat information for each species.
Affected Environment for Endangered Plants The only federally listed plant species in the project area is the endangered Holy Ghost ipomopsis (Ipomopsis sancti-spiritu) and its critical habitat (Table S-30). No threatened plants exist on either national forest.
The only known population of the Holy Ghost ipomopsis exists in continuous scattered patches along 2 miles of Holy Ghost Canyon on the Santa Fe National Forest. The acreage of occupied habitat covers about 15 acres and the individual plants number approximately 2,500 (USDI 2002). In addition to the main population, Holy Ghost ipomopsis seedlings have been planted in Winsor, Panchuela, and Indian Canyons as part of a recovery effort. There are no known weeds currently growing within the Holy Ghost ipomopsis populations. Holy Ghost Canyon is the only designated critical habitat for this plant.
Table S-30. Threatened or endangered plant species Proportion of Estimated Acres of Sensitive Acres of Known Weeds Species Habitat Plant Species Habitat Habitat1 in the Habitat2 Affected Holy Ghost South aspect slopes in Holy 15 0 0 ipomopsis and Ghost Canyon, Santa Fe critical habitat National Forest. Plants have been transplanted to other places to aid recovery. 1 Acres of habitat is based on known areas of occupancy. 2 Acres of weed infestations are populations known as of August 1, 2013. Comprehensive surveys of both national forests have not been completed.
Affected Environment for Sensitive Plants Table S-31 identifies the sensitive plants growing or likely to occur in the two national forests. Acres of habitat are based on a combination of habitat type and known areas of occupancy. Acres of weeds in the habitat are based on known populations as of August 1, 2013. Where two numbers exist in a single cell, the top number is the Santa Fe National Forest and the bottom number is the Carson National Forest.
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Table S-31. Forest Service Southwestern Region regional forester’s sensitive plant species, 2013, on the Santa Fe (SF) and Carson (C) National Forests Acres of Proportion Known of Sensitive Estimated Weeds in Species Sensitive Plant Acres of the Habitat Species Forest Habitat Habitat Habitat Affected Alpine larkspur C Alpine meadows. Potential habitat 48,513 9 0.02 Delphinium alpestre 11,500-13,000 ft. Three known locales all Taos County; Latir Peak, Gold Hill and Wheeler Peak. Arizona willow SF Subalpine, high elevation meadows. 14,119 13 0.09 Salix arizonica C Pecos Wilderness and Midnight 18,162 761 4.2 Meadows. Chaco milkvetch SF Rio Arriba County in two known locales. 104,018 312 0.3 Astragalus micromerius Chama blazing star SF Upper Chama River valley. Specialized 3,021 132 4.4 Mentzelia conspicua habitat on gray to red shale and clay of the Mancos and Chinle formations on slopes of road cuts. Greene (Wheel) SF Rare and small populations in stable 27,160 169 0.6 milkweed grasslands but widespread through Asclepius uncialis Plains states. Specimen from Mesita de los Ladrones, Anton Chico Grant. Small stature is easily overlooked. Found in juniper-savannah. Heil’s alpine whitlow SF Specimen found in the Pecos 13,191 0.005 0.00004 grass Wilderness in open areas above Draba heilii timberline. Extreme rarity. Named in 2009. Pagosa milkvetch C Limited to clay soils of Mancos and 124,636 1,013 0.8 Astragalus Lewis formations. One location on missouriensis var. Jicarilla Ranger District* on black humistratus Mancos shale. One herbarium record in NM Biodiversity.org Pecos fleabane SF Subalpine meadows of high elevation 5,491 0 0 Erigeron subglaber C coniferous forests. All in Pecos and 256,990 75 0.03 Wheeler Peak Wilderness, except one population on Elk Mountain. Pecos (Gunnison’s) SF Type specimen found in the Pecos 50,615 78 0.2 mariposa lily Wilderness 8,500 to 11,200 foot aspen Calochortus glades, John’s Canyon, Beulah gunnisonii var. mountain meadows, Harvey’s Ranch perpulcher near Las Vegas, New Mexico. Appearance is a pale yellow form of the flower. Ripley’s milkvetch C Mainly Tres Piedras Ranger District and 175,908 704 0.4 Astragalus ripleyi south of Questa. Obvious, pale lemon flowers, many acres in several localities. Sagebrush/shrubs and piñon/juniper/oak woodland/open ponderosa pine
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Acres of Proportion Known of Sensitive Estimated Weeds in Species Sensitive Plant Acres of the Habitat Species Forest Habitat Habitat Habitat Affected Robust larkspur C Canyon bottoms and aspen groves 95,793 17 0.02 Delphinium from 7,000 to 10,000 ft. No populations robustum known on Santa Fe National Forest. One specimen from Carson National Forest in Taos County on Camino Real Ranger District. Others from Eagle Nest and Angel Fire. Small-headed C Ponderosa pine zone. Narrow range 51 0 0 goldenweed near Tres Piedras, Petaca to Las Lorandersonia Tablas west of forest road 519. Grows (Ericameria) on granitic dome hills rock outcrops, microcephala rock cracks. (=Happlopappus m.) Springer’s blazing SF No specimens found on the Santa Fe 13,947 169 1.2 star Los National Forest. Occurs on pumice Mentzelia springeri Alamos deposits. County only Tufted (Galisteo) SF Occurs on gypsum deposits. One 8,805 437 5.0 sand verbena location on Santa Fe National Forest in Abronia bigelovii Section 35, south of Navajo Peak. Wood lily SF Scattered locations throughout Santa 52,158 220 0.4 Lilium Fe National Forest in cool, moist site philadelphicum openings. North slopes in ponderosa (umbellatum) and mixed conifer. Vulnerable from damage to wetland areas and collecting. State endangered. Yellow lady’s-slipper SF Pecos Wilderness and adjacent areas. 58,671 1,771 3.0 Cypripedium Rare. Small scattered populations very parviflorum vulnerable to collecting. No specimens pubescens known for the Carson National Forest. * RD= ranger district
Environmental Consequences to Special Status Plants With the design features in place, determinations for the action alternatives are as follows: • Not likely to adversely affect the Holy Ghost ipomopsis. • No impacts are expected to the sensitive plants that occur in alpine and subalpine forest communities (alpine larkspur, Arizona willow, Heil’s alpine whitlow grass, Pecos fleabane, Pecos mariposa lily, and yellow lady’s-slipper). • Based on design features for sensitive plants (pg. 35), no impacts are expected to lower-elevation sensitive plant species. These species are very uncommon or are found only in very limited environments or some are not found on National Forest System lands but occur within a county. An individual of a species may be impacted, but is not likely to result in a trend toward Federal listing or reduced viability of the population for the other species of sensitive plants (Chaco milkvetch, Chama blazing star, Greene milkweed, Pagosa milkvetch, Ripley’s milkvetch, robust larkspur, small-headed goldenweed, Springer’s blazing star, tufted (Galisteo) sand verbena, and wood lily).
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Cumulative Effects to Sensitive Plants The direct and indirect effects of this project would be short-term disturbance (less than 1 day) or less than 5 percent of any plant’s habitat. Over time, the removal of weeds would promote or preserve the native vegetation. The direct and indirect effect to sensitive plants would be too small to measure, and would not contribute any noticeable cumulative effect when added to other activities in the analysis area.
Effects of Forest Plan Amendment to Vegetation, including Special Status Plants The effects of the proposed plan amendment to vegetation in future projects would be the same as described in this “Vegetation” section. The amendment changes where and when weeds could be treated (in areas of high human habitation, in municipal watersheds, and on certain soils). Once cleared for treatment, the effects of treatments themselves would be the same as described in this section. Obtaining clearance or permission for treatment could take longer due to the consultation and analyses required.
Wildlife Resource [Replaces entire section]
Methodology Each species’ habitat was modelled using GIS by the particular vegetation type the species typically uses.
The “Environmental Impact Statement for the Santa Fe National Forest Plan” (1987) used habitat as a proxy for the management indicator species chosen for the Santa Fe. The management indicator species were chosen based on commonly used habitats, their economic importance, or their high social interest.
Management indicator species are defined in the 1986 Carson National Forest Plan as, “[t]hose species selected in the planning process to monitor the effects of planned management activities on viable populations of all wildlife and fish species, including those species that are socially or economically important.” The Carson National Forest Plan designates specific management indicator species that could best be used to analyze the effects of site-specific proposals on the national forest. The Carson National Forest Plan allows flexibility on how management indicator species habitat and population trends are monitored. The 1986 environmental impact statement for the Carson National Forest Plan described the habitat groups and characteristics, along with projected trends of management indicator species, based on current direction and management of these habitats. The basis for determining habitat trend is a comparison of estimated management indicator species habitats at the time of preparing the Forest Plan to the present. The methods used to determine current habitats were developed to approximate similarity (to the degree possible) to the acreages used in the 1986 Carson National Forest Plan environmental impact statement. In some cases, the estimated acres of management indicator species habitats are based on certain parameters of habitat quality. The rationale and methods used to reach the current habitat estimates are described for each species or group. The methods generally included developing queries from existing vegetation stand exam data.
Environmental Consequences Common to All Species This section describes effects common to all wildlife species. The analysis focuses on the key issues identified in chapter 1, which are (1) how the weed treatments may cause habitat disturbance (noise and visual disturbance), (2) negative health impacts from herbicides used, or (3) impacts to habitat quality from reductions in existing surface vegetation.
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Alternative A–No Action As described in the “Vegetation” section of this final supplemental environmental impact statement, without treatments, over time weeds would continue to reduce the abundance and diversity of native vegetation that provides habitat for native wildlife species. For species that rely on native habitat, a decline in habitat quality would occur. For species that do not rely on the displaced habitat, no effect would occur.
The no-action alternative would allow weed populations to continue to expand beyond the 13,260 acres of presently known weeds. Monocultures of weeds cause structural changes in habitat, altering habitat. The habitat elements that native plants provide for wildlife, such as nesting and ground cover, grass production, seed sources, and prey base, would be reduced. The reduction in the amount of these habitat elements would negatively affect populations of big game, predator, small mammal, bird, reptile, and amphibian species. Because the weed populations are presently small in proportion to the entire acreages of both national forests, immediate loss of habitat or forage is not expected. Untreated, however, weeds expand at an estimated rate between 5 and 30 percent annually (see “Vegetation” section), depending on the species and ecologic conditions at each infestation site.
Over time, weeds could displace native habitat on large acreages and cause detrimental impacts to wildlife on the two national forests. For example, the invasion of Russian knapweed in Colorado has resulted in a large reduction in the availability of winter range for wildlife. In Montana, it was estimated there would be a loss of 220 elk annually due to weed invasions of big game winter ranges (FICMNE 1998). In Arizona, stands of the weed Lehmann lovegrass have fewer quail, small mammals, and seed-harvesting ants (FICMNE 1998). Frid et al. (2013) show weed populations are more difficult to eradicate once a seedbed has been established.
Alternative B–Proposed Action Alternative B offers the most flexibility for controlling weed populations and thereby is predicted to result in the most improvement of native plant communities when compared to alternatives C or D. Because of the diversity of treatment methods available, weeds are the most likely to be successfully controlled under alternative B, thus restoring the most native vegetation and promoting biological diversity.
Given the same level of funding, Forest personnel expect to be able to treat the most acreage with the most success under alternative B. For a number of weed species that resprout from roots left after mechanical or manual treatments (for example, Canada thistle or spotted knapweed), integrated treatments would be highly effective at reducing populations. As existing weed populations are controlled or eradicated, fewer treatments would be required after several years.
The treatment methods themselves pose a low risk to individual animals and no detectable effect to populations. A very small percentage (less than 1/100th of a percent) of habitat for any species would be treated in a given year. Because weeds exist in scattered patches across the two national forests, treatments would also be widely distributed. Weeds often establish themselves in disturbed areas, like road sides and recreation sites, which animals tend to avoid because of human presence. Thus, treatments are not expected to pose any additional disturbances to most wildlife.
The next paragraphs describe effects for the key issues:
Disturbance to Habitat: Disturbance to habitat from treatments is not expected to adversely impact wildlife species or populations. Mechanical methods (mowing, tilling), prescribed burning, and vehicle-mounted herbicide applications would cause the most noise. Biological controls would cause little to no noise disturbance. Manual methods, controlled grazing, and manual application of herbicides would cause minimal noise and habitat disturbance. Typically, the duration of traffic would be limited to 1 or 2 days and once complete, wildlife would soon return to these areas. The level of effect also depends on the current level of background noise for an area. Since many areas with weed infestations are near roads, trails, and high use recreation sites, wildlife that use these areas probably would be habituated to the presence of people.
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Fluctuating noise levels may elevate heart rate, catecholamine levels, and corticosteroid levels in wild animals, but these elevated levels are generally of short duration, and animals often habituate to these disturbances over time. Short-term increases in these measures do not correlate well with actual stress experienced by animals. Finally, since most wildlife would avoid the treatment areas during activities, the risk of direct herbicide exposure to those animals would be minimal.
Modification of Habitat: Overall, treatments may result in modified habitat for a season or less; the long- term effect of promoting native vegetation (and thus habitat) would be beneficial. Weed treatments would cause temporary, localized reduction in existing vegetation, including some native vegetation that could be killed or removed along with the weeds. This would not measurably impact wildlife habitat due to the relatively small acreages that would be treated in a given time and habitat, along with the design feature requiring prompt evaluation and revegetation of treated sites where bare soil is exposed. Ground cover would be expected to begin to return by the first growing season after treatment, and the abundance and diversity of native vegetation would gradually return over subsequent growing seasons.
Each method would have a slightly different, but minimal effect, on the structure and composition of wildlife habitat. None of the treatments would result in a loss of large trees, snags, or down log habitat components that are important for many species.
Managed grazing with sheep or goats would change the structure of vegetation, but the magnitude of this change would be small. The risk of transmitting disease to bighorn sheep would be avoided by not allowing sheep or goats to graze in bighorn sheep areas. The Carson and Santa Fe National Forests have a permanent closure order prohibiting pack goats in wilderness areas.
Biological controls (introduction of insects) would not adversely affect habitat for wildlife since this method would have been studied to ensure that the insects are plant-host specific. Thus the insects would not impact native vegetation or other beneficial insects.
Manual methods of weed control such as hand pulling, cutting, or digging would result in minimal changes in wildlife habitat quality, especially when conducted on such a small scale and spread widely across the national forests. Mowing or mechanical weed treatments would not result in any major alteration in habitat quality.
Burning of individual weeds with a propane torch would leave the remaining habitat structure and composition intact. Broadcast burning weed infestations in grasslands or similar habitats conducive to burning would result in a minor and temporary change to the seral stage and vegetative community. A controlled surface burn would result in little, if any, loss of large snags or down logs, so it would not impact the habitat trend or populations of snag-dependent species such as hairy woodpecker.
The impacts from herbicide use on vegetation structure depend on the application method, type of herbicide, and rate and season of application. Effects would be a potential change in composition of forbs, grasses, and shrubs in treatment areas. Non-target plants could be damaged by unintentional application, drift, or residual herbicide in soil. These short-term impacts to plant composition and community diversity would likely be offset within the first growing season. There would be no long-term loss of species diversity of native vegetation due to the proposed treatments, and species composition under most treatments is expected to resemble native plant assemblages within 1 to 3 years. For additional discussion relative to vegetation, see the “Vegetation” section.
Herbicide Toxicity Effects: Risk assessments of the herbicide formulations proposed for use have considered the risk of harm that could be caused by their use (USDA Forest Service 1992, SERA 2002 to 2007). The risk assessments concluded that potential risks of harm to most wildlife species are low for herbicide formulations proposed for use at the rates and application methods proposed.
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When used at the application rates and concentrations listed on the labels, herbicides would have a very low risk of causing short- or long-term harm to wildlife species. There is a general lack of data and some uncertainty relative to herbicide effects on amphibians, so there is potential for an unquantifiable impact on amphibians from herbicide application. Based on design features and the risk assessments, the risk of toxicity to amphibians is considered low. Design features that minimize herbicide delivery in or near waterbodies, limit the amount of herbicide used within a given watershed, and limit the type of application permitted in riparian areas are required. Also, the extent of proposed herbicide treatments within potential amphibian habitat areas is very small. If herbicides were to impact individual amphibians on a local basis, it would not affect the population as a whole. Population or habitat trends would not be impacted for any wildlife species that occur on the national forests.
Alternative C–No Herbicides Like alternative B, eradicating, controlling, or containing weeds under alternative C would improve native vegetation and help maintain or improve biological diversity on the areas treated. However, given the same level of funding as alternative B, fewer acres would be treated and the effectiveness of each treatment application would be less. For a number of weed species that re-sprout from roots left after mechanical or manual treatments (for example, Canada thistle or spotted knapweed), a greater number of return treatments would probably not be effective at reducing populations. Treating weeds in a given area would require concentrated effort over several years. In the places where weed treatments were not successful, or if the spread rate of weeds continued to exceed the rate of control, the long-term effects would be similar to alternative A. Thus, the beneficial improvements to native vegetation and wildlife habitat would be lower for this alternative.
Short-term disturbance effects and habitat alteration effects to wildlife would be similar to those described for alternative B, except there would be more repeat treatments to achieve the objective so recovery of native vegetation would probably take longer. This alternative would completely eliminate the risk to individual animals posed by herbicide toxicity.
Alternative D–Only Herbicides As with alternatives B and C, implementation of this alternative would improve native vegetation and help maintain biological diversity by eradicating, controlling, or containing weeds on the two national forests. Some species of weeds do not respond to treatments that apply herbicides alone; for these sites, repeated treatments could be necessary and the expected effectiveness in meeting objectives would fall between alternatives B and C.
Effects of this alternative would be very similar to those described for alternative B. One difference would be it eliminates the risk to individuals posed by mechanical treatments. The level of noise and habitat disturbance would be slightly less than either alternative B or C as the use of herbicides would result in a reduced need for repeat treatments on many sites.
Cumulative Effects Common to All Species In all action alternatives, cumulative impacts to non-target plant species would stem from forest management activities, public land uses, and activities on other public and private lands, as described in the beginning of this chapter.
The weed infestations occupy less than one-half of 1 percent of the acreage on the Carson and Santa Fe National Forests and are well dispersed. Treatments would be spread out in both time and space. The actual direct and indirect effects of each alternative on wildlife are predicted to be of such low magnitude they cannot be measured. In all action alternatives, treatment in specific species habitat would be limited to less than 5 percent of the habitat for any one species. Of the species analyzed, only three have more than 5 percent of their habitat affected by weeds, with the largest being about 17 percent for Gunnison’s prairie dog. The
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addition of this disturbance to the amount of disturbance caused by other activities is not likely to overlap in space and time and would not be measurable. With the design features in place, concentrations of herbicides, and the duration of exposure on the terrestrial environment would be small and well below levels at which chronic exposure effects are documented.
Although some individual animals may be affected (from short-term disturbance), no impact to population or habitat trends is predicted, even when considering this project’s impacts in addition to other impacts occurring in the project area.
Affected Environment for Management Indicator Species Management indicator species were identified during development of the forest plans and are used to monitor effects of management activities on populations of wildlife and fish, including those that are socially or economically important.
Table S-32 displays the two national forests’ management indicator species, the estimated acres of existing habitat, the habitat trend, the population trend, and the acres and percent of weed infestations within those habitats. The estimated acres and percent represent the maximum amount of habitat that would be treated given known weed populations as of this writing.
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Table S-32. Wildlife management indicator species, habitat, and weed infestation Estimated Estimated Percent of Acres Acres (Miles) Habitat National Habitat Population (Miles) of of Habitat with with Species1 Forest Habitat1 Trend1 Trend1 Habitat Weeds2, 4 Weeds Brewer’s Carson Sagebrush Stable to Stable 96,083 377 0.4 sparrow increasing Juniper Carson Piñon- Declining Stable 352,263 1,445 0.4 titmouse Juniper Piñon jay Santa Fe Piñon- Declining Stable 362,176 1,381 0.4 Juniper Abert’s squirrel Carson Ponderosa Increasing Increasing 486,497 1,414 0.3 Pine Merriam’s Carson Most Increasing Stable to 574,875 1,431 0.3 turkey habitat Increasing types Santa Fe Stable to Stable 417,789 4,111 1 Increasing Hairy Carson Snags and Increasing Stable 719,950 1,508 0.2 woodpecker down logs Santa Fe in all Increasing Stable 804,768 6,125 0.8 habitats
Rocky Mountain Carson All Stable Stable 1,485,417 5,112 0.3 elk habitats Santa Fe Stable Increasing 1,216,074 8,931 0.7 Mourning dove Santa Fe Most Stable to Stable 908,160 6,866 0.8 habitats Increasing Rocky Mountain Carson Alpine Stable Stable 9,474 4 0.04 bighorn sheep Santa Fe Stable Stable 7,817 0.005 0.0001
White-tailed Carson Alpine Stable Stable 48,513 9 0.02 ptarmigan Red squirrel Carson Mixed Increasing Stable 486,497 1,414 0.3 Conifer Mexican Santa Fe Mixed Declining Stable 198,889 660 0.3 spotted owl Conifer Rio Grande Carson Aquatic Stable Stable (138) (1.8) 1.3 cutthroat trout Santa Fe Stable Declining 3,924 5 0.1 Resident trout3 Carson Aquatic Stable Stable (770) (19) 2.3 Aquatic macro- Carson Aquatic Stable Stable (1,850) (44) 2.4 invertebrates
1. From Carson and Santa Fe National Forests forestwide management indicator species reports (USDA Forest Service 2011b, 2012). 2. Acres of weeds are based on populations known as of August 1, 2013. 3. Resident trout include rainbow, German brown, brook, and Rio Grande cutthroat trout. The latter is addressed individually. 4. Acres of weeds located along linear miles of stream were calculated using a 66-foot buffer on each side of the aquatic habitat.
The discussion of each species below is taken from the forest plans and management indicator species reports (USDA Forest Service 1986a, 1987a, 2011, 2012).
Brewer’s Sparrow Brewer’s sparrow is an indicator for sagebrush habitat. In northern New Mexico the habitat for Brewer’s sparrow is sagebrush; brushy plains; and the interface of piñon-juniper, woodlands, and sagebrush. Brewer’s sparrow is strongly associated with high sagebrush vigor throughout its range, preferring areas dominated by
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high shrub cover, large patch size, and bare ground. The trend for habitat on the Carson National Forest is stable to increasing based on the gradual conversion of grasslands to sagebrush. The population trend for the Carson National Forest is considered stable.
Juniper (Plain) Titmouse The juniper (plain) titmouse is an indicator species for the presence of piñon-juniper canopies. The titmouse is a resident of deciduous or mixed woodlands, favoring oak and piñon-juniper. The titmouse usually nests in natural cavities or old woodpecker holes primarily in oak trees, but it is capable of excavating its own cavity in rotted wood. The species feeds mainly on insects, seeds, and occasional fruits and also is a bark gleaner. As a cavity nester, large, older trees are an important feature. The Carson National Forest showed a decrease in acres of habitat from between 1986 and 2011. There is a downward trend in habitat, with a loss of about 4.0 percent since 1986. The population trend, however, is stable. This titmouse is a common species on the Carson National Forest.
Piñon Jay Piñon jays nest mainly in stands of piñon and juniper trees. They need open woodlands for nesting and an adequate supply of seeds, especially nuts. They are gregarious and breed in colonies up to 150. They spend the winters in large flocks of tens to thousands searching for piñon nuts, which are a primary food source. The forest plan modeling predicted piñon jay habitat would improve with the implementation of projects that would improve foraging habitat. In 2002, drought and subsequent invasion by the Ips beetle caused many piñon trees on the Santa Fe National Forest to die, resulting in a loss of about 18 percent of piñon jay habitat. Thus, the habitat trend for piñon jay is ranked as declining. The population trend for the Santa Fe National Forest is ranked as stable based on the management indicator species report and breeding bird survey routes located near the Santa Fe.
Abert’s Squirrel Abert’s squirrel is an indicator for the presence of interlocking canopies in ponderosa pine. Abert’s squirrel depends on ponderosa pine for its life necessities and requires diversity of age classes and tree densities. Pine twigs, pine cones, pine seeds, pine bark, and truffles are used by Abert’s squirrel. In addition to pure ponderosa pine stands, Abert’s squirrels are also associated with Gambel oak, true piñon, juniper, quaking aspen, and Douglas-fir. Habitat on the Carson National Forest has increased just over 20 percent from 1986. The habitat condition for the species is considered poor to fair, but in an upward trend. The Abert’s squirrel population on the Carson National Forest is on an upward trend at this time.
Merriam’s Turkey Merriam’s turkey has the widest distribution and is the most common subspecies of turkey. It is found in many mountainous areas of northern New Mexico. The bird uses ponderosa pine, a source of mast (nuts and seed) and its favorite roosting tree. The ponderosa pine is an essential component of its permanent habitat, while surface water is a range requirement. Turkeys prefer to roost in tall mature or overmature ponderosa pines with relatively open crowns and large horizontal branches starting at 20 to 30 feet from the ground. Trees with a diameter of over 14 inches are used as roosts. A healthy ponderosa pine understory provides the turkey cover as well as forage. The Santa Fe National Forest Plan modeling determined feeding habitat was the primary limiting factor for turkey, and timber harvest patterns promoting early-seral stages were the most beneficial for turkey. The turkey was used as an indicator for the presence of old-growth pine in the Carson National Forest Plan. The Santa Fe National Forest rates the habitat trend for turkey as stable to increasing; the Carson National Forest rates the trend as slightly upward. The Santa Fe National Forest management indicator species report rates the turkey population as stable. The Carson National Forest management indicator species report indicates a stable to upward trend for turkeys due to transplants into previously unoccupied habitat.
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Hairy Woodpecker The hairy woodpecker is a forest generalist, keying in on available snags and live aspen. On both national forests, this species is found in areas with abundant snags and downed logs. Nests are primarily in trees averaging 17 inches in diameter and approximately 60 feet high. The hairy woodpecker forages primarily on tree trunks averaging 17 inches in diameter and greater than 30 feet high. Down logs are important for foraging by providing insects. The habitat trend on the Santa Fe National Forest is upward. The habitat trend on the Carson National Forest is considered upward. Population trends on both national forests are considered stable.
Rocky Mountain Elk Rocky Mountain elk inhabit most forest types with good forage and cover. These ungulates use a variety of habitat types during the course of their life. They appear to be extremely adaptable to a variety of successional stages and vegetation types. The habitat trends on the Santa Fe and Carson National Forests are rated as stable. The population trend for elk is rated as increasing on the Santa Fe National Forest and stable on the Carson National Forest.
Mourning Dove Mourning dove habitat is abundant in the Santa Fe National Forest. They are found in ponderosa pine, spruce- fir, aspen, and piñon-juniper forest types. Most nesting occurs in lower elevation habitats. The abundance of nesting and cover opportunities on the Santa Fe National Forest contribute to maintaining viable populations of mourning dove. The habitat trend for mourning dove is considered stable to increasing. The population trend for mourning dove on the Santa Fe National Forest is ranked as stable based on the statewide trend and breeding bird surveys in, and next to, the forest.
Rocky Mountain Bighorn Sheep Rocky Mountain bighorn sheep inhabit cliffs, crags, and other extremely rocky areas in tundra and alpine areas from the summit peaks to around 200 meters (656 feet) below treeline in the northern New Mexico mountains. Bighorn sheep prefer precipitous terrain adjacent to suitable feeding sites of high mountain meadows with grasses, forbs, and browse species. Currently, bighorn sheep occur in the Pecos, Latir Peak, and Wheeler Peak Wilderness areas and the Gold Hill area. For both national forests, the habitat and population trends are considered stable.
White-tailed Ptarmigan The white-tailed ptarmigan is used as an indicator for the presence of alpine tundra and subalpine deciduous shrub. Little is known about this avian species in New Mexico because it lives on the windswept tundra above 11,000 feet. The presence of high-elevation shrubby willows (Salix spp.) is likely the most important factor for successful overwintering of the species. On the Carson National Forest, ptarmigan habitat approximately coincides with the habitat for bighorn sheep. Ptarmigans are also considered to be present on Costilla, Latir, Wheeler, Truchas, and associated peaks. For the Carson National Forest, white-tailed ptarmigan habitat and population trend are considered stable.
Throughout its range, the white-tailed ptarmigan is listed as globally secure and common, widespread and abundant. There is no evidence of large-scale declines. While the actual number of ptarmigan on the Carson National Forest is uncertain (albeit low because New Mexico is the very southern end of its range), the species is still present and the population trend appears to be stable across the Forest. Although ptarmigan are on the forest in low numbers, it was never expected the Carson NF would achieve large breeding populations because of the limited amount of suitable habitat in the area (USDA Forest Service, Carson NF 2011).
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Red Squirrel Red squirrels are an indicator species for the mixed conifer habitat type. The squirrels require mature coniferous trees as a source of cones and seed. The best cone production occurs in 200- to 300-year-old Douglas-fir, 40- to 300-year-old white fir, and 150- to 200-year-old Engelmann spruce. The red squirrel is predominantly found in areas with greater than 60 percent canopy closure. Red squirrel habitat on the Carson National Forest has increased approximately 20 percent from 1986. The habitat trend is considered upward. The population trend is considered stable.
Mexican Spotted Owl The Mexican spotted owl is an indicator species of old growth, coniferous forest. Nesting and roosting habitat is characterized by steep topography, cool shady canyons, and mature, mixed conifer forest with high canopy closure. Protected activity centers are established by the Forest Service to protect territories of individual Mexican spotted owl. The Carson National Forest has very few areas suitable for Mexican spotted owls; there is one protected activity center on the Jicarilla Ranger District. The Mexican spotted owl population on the Santa Fe is considered rare but the trend is rated as stable. Since the writing of the Santa Fe National Forest Management Indicator Species Report, the Las Conchas Fire (June 2011) burned through nine Mexican spotted owl protected activity centers and habitat.
Rio Grande Cutthroat Trout The Rio Grande cutthroat trout is one of 14 subspecies of cutthroat trout native to the western United States. Rio Grande cutthroat trout are an indicator of clear, cold mountain lakes and streams in the Rio Grande Basin in Colorado and New Mexico. The decline in Rio Grande cutthroat trout numbers in New Mexico is attributed to many factors, including, but not limited to, (1) introduction of nonnative trout species that either prey upon, or hybridize with, Rio Grande cutthroat trout; (2) dewatering of streams for irrigation; and (3) altered stream habitat. On the Carson National Forest, Rio Grande cutthroat trout habitat and population trends are stable. On the Santa Fe National Forest, the habitat trend is stable and the population trend is downward.
Resident Trout Resident trout species are used as indicator species for quality perennial streams and riparian vegetation. Resident populations reproduce and sustain themselves in the wild. In the Carson National Forest Plan, resident trout are rainbow trout (Oncorhynchus mykiss), German brown trout (Salmo trutta), brook trout (Salvelinus fontinalis), and Rio Grande cutthroat trout (Oncorhynchus clarki virginalis). Except for the Rio Grande cutthroat trout, all resident trout in the Carson National Forest are nonnatives that have been stocked extensively in northern New Mexico over the past 100 years. Resident trout habitat and population trends are stable on the Carson National Forest.
Aquatic Macroinvertebrates Aquatic macroinvertebrates, or aquatic insects, are found in lakes, streams, ponds, marshes, and puddles. They help maintain the health of the water ecosystem by eating bacteria and dead, decaying plants and animals. Local populations of certain aquatic macroinvertebrates are indicator species for high-quality water. They are an indicator of overall aquatic conditions, quality of fisheries, and associated riparian habitat. For the purpose of analyzing the effects of forest management activities, the primary habitat requirement for aquatic macroinvertebrates is perennial water which supports resident trout. For the Carson National Forest, aquatic macroinvertebrate habitat and population trends are currently stable.
Environmental Consequences to Management Indicator Species Effects previously described for all wildlife habitat and populations on the Carson and Santa Fe National Forests apply to management indicator species. The following table provides additional information about the estimated effects of each alternative for each specific management indicator species on each national forest.
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Table S-33. Effects to management indicator species
Management Alternative A All Weed Management Alternatives: Indicator Species (No Action) B, C, and D
Brewer’s sparrow No impacts to population or habitat Same as alternative A. trends are expected because sagebrush habitat is not threatened by weeds. Juniper titmouse No impacts to population or habitat No impacts to population or habitat trends trends because weeds are not are expected because weed treatments expected to threaten the piñon pine would not affect piñon pine canopy used by canopy on which the juniper juniper titmouse. Any changes in understory titmouse depends. structure as a result of weed treatments would not affect population or habitat trends because this isn’t a component the species depends on. Piñon jay No impacts to population or habitat No impacts to population or habitat trends trends because weeds are not are expected because weed treatments expected to threaten the piñon pine would not affect piñon pine trees used by habitat on which the jay depends. piñon jay. Any changes in understory structure as a result of weed treatments would not affect population or habitat trends because this isn’t a component the species depends on. Abert’s squirrel No impacts to population or habitat No impacts to population or habitat trends trends because weeds are not are expected because weed treatments expected to affect interlocking would not affect interlocking canopies in canopies in ponderosa pine used ponderosa pine used by Abert’s squirrel. Any by Abert’s squirrel. changes in understory structure as a result of weed treatments would not affect population or habitat trends because this isn’t a component the species depends on. Merriam’s turkey No impacts to population or habitat No impacts to population or habitat trends trends because weeds are not are expected because weed treatments expected to affect the old growth would not affect old growth pine (roost tree, pine (roost tree, roost tree groups) roost tree groups) used by turkeys. No used by the turkey. Weeds would impacts to population or habitat trend are continue to displace native plants, expected because weed treatments would grasses, and insects used by result in improving native grasses and other turkeys, so habitat quality would surface vegetation so would improve turkey decline. habitat. Some loss of vegetation for a season following treatments could cause temporary displacement. Hairy woodpecker No impacts to population or habitat No impacts to population or habitat trends trends because weeds do not affect because weed treatments would not cause a snags and down logs important to loss of large snags or down log habitat hairy woodpecker. components on which the woodpecker depends. Any changes in understory structure as a result of weed treatments would not affect population or habitat trends because this isn’t a component the species depends on. Rocky Mountain Weeds would continue to displace No impacts to population or habitat trend are elk grasses used as elk forage so expected because weed treatments would habitat would decline in quality and result in improving elk foraging habitat. quantity. Some loss of vegetation for a season following treatments could occur, but elk are wide ranging and would not be affected by this small change.
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Management Alternative A All Weed Management Alternatives: Indicator Species (No Action) B, C, and D
Mourning dove Weeds would continue to displace No impacts to population or habitat trend are native habitat in a wide variety of expected because weed treatments would habitats that this species depends restore native vegetation that this species upon, resulting in a decline in uses. Since the dove uses a wide variety of habitat. habitats, temporary changes to understory structure in small patches of its habitat as a result of treatments would not impact population or habitat trends. Rocky Mountain No impacts to population or habitat No impacts to population or habitat trend are bighorn sheep trend are expected because weeds expected because weeds aren’t expected to are expected to remain very limited thrive at these high elevation grasslands, so in high elevation grassland bighorn very little of its habitat would be treated on sheep habitat. an annual basis. This means at any time, over 99 percent of bighorn sheep habitat would be intact. White-tailed No impacts to population or habitat No impacts to population or habitat trend are ptarmigan trend are expected because weeds expected because weeds aren’t expected to are expected to remain very limited thrive at these higher elevation alpine and in higher elevation alpine tundra subalpine habitats, so very little of the and subalpine deciduous shrub ptarmigan habitat would be treated on an habitat. annual basis. This means at any time, over 99 percent of white-tailed ptarmigan habitat would be intact. Red squirrel No impacts to population or habitat No impacts to population or habitat trend are trend are expected because weeds expected because weed treatments would do not affect mature mixed conifer not affect mature mixed conifer trees used trees used as primary red squirrel as primary red squirrel habitat. Any changes habitat. in understory structure as a result of weed treatments would not affect population or habitat trends because this isn’t a component the species depends on. Mexican spotted Weeds would continue to displace No impacts to population or habitat trend are owl native plants, grasses, and insects expected because weed treatments would used by prey species of the owl, so compose a small percentage of protected habitat quality would decline. activity centers and Mexican spotted owl habitat. Treatments would prevent further spread of weeds into prey habitat, which would be beneficial to the prey species that the owl feeds upon and therefore beneficial to the owl.
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Management Alternative A All Weed Management Alternatives: Indicator Species (No Action) B, C, and D
Rio Grande Weeds would continue to displace With design features in place the proposed cutthroat trout native plants and grasses within action may have an indirect impact to riparian, so habitat quality and individual Rio Grande cutthroat trout. The perennial water quality would Rio Grande cutthroat trout is carnivorous, decline. preying entirely on macroinvertebrates. If herbicide was to reach the aquatic environment, a reduction in aquatic vegetation and phytoplankton could occur, which could cause a trophic cascade (that is, a shift in the food chain), resulting in reduced aquatic invertebrate herbivore prey base for fish. Mechanical and grazing methods for weed removal could temporarily increase sedimentation due to ground disturbance in the riparian area. The impacts from alternatives B, C, and D would likely be a localized and small in scale. Therefore, the proposed action is not expected to decrease population viability or cause a trend to federal listing of Rio Grande cutthroat trout. Resident trout Weeds would continue to displace With design features in place the proposed native plants and grasses within action may have an indirect impact to riparian, so habitat quality and individuals of the resident trout. Resident perennial water quality would trout are carnivorous, preying entirely on decline. macroinvertebrates. If herbicide was to reach the aquatic environment a reduction in aquatic vegetation and phytoplankton could occur, which could cause a trophic cascade (that is, a shift in the food chain), resulting in reduced aquatic invertebrate herbivore prey base for fish. Mechanical and grazing methods for weed removal could temporarily increase sedimentation due to ground disturbance in the riparian area. The impacts from alternatives B, C, and D would likely be a localized and small in scale. Therefore, the proposed action is not expected to decrease population viability or cause a trend to federal listing of resident trout. Aquatic Weeds would continue to displace If herbicide was to reach the aquatic macroinvertebrates native plants and grasses within environment a reduction in aquatic riparian, so habitat quality and vegetation and phytoplankton could occur, perennial water quality would which could cause a trophic cascade (that is, decline. a shift in the food chain), resulting in reduced aquatic invertebrate abundance. Increased sedimentation from mechanical and grazing alternatives could impact aquatic macro- invertebrates by filling interstitial spaces in the substrate where these organisms dwell. Sessile species would be most likely impacted. However, the impacts from alternatives B, C, and D would likely be a localized and small in scale. Therefore, the proposed action is not expected to decrease population viability of aquatic macroinvertebrates.
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Cumulative Effects to Management Indicator Species Because there are no measurable direct or indirect impacts to population or habitat trend for any management indicator species, there would be no cumulative effects from this project. Even though there are no predicted negative impacts to population or habitat trends for management indicator species, some habitats would be improved as a result of the action alternatives. Combined with past, present, and foreseeable actions such as restoration projects (for example, Southwest Jemez Mountains Landscape Restoration Project) on the two national forests, there would be an improvement in habitat at a landscape level.
Affected Environment for Threatened and Endangered Species This section analyzes threatened or endangered wildlife species listed under the Endangered Species Act. Threatened, endangered, and sensitive plants are addressed in the “Vegetation” section. For purposes of this analysis, the affected environment includes the species actually found on the Carson and Santa Fe National Forests and the habitats they occupy or habitats suitable for occupation. The list of species was developed from information provided by the U.S. Fish and Wildlife Service.
No analysis for the following species is required. The Arkansas River shiner (threatened), piping plover (threatened), and black-footed ferret (endangered) do not occur, or have habitat, on either national forest. The least tern (endangered) has only been found near Bitter Lake National Wildlife Refuge, approximately 190 miles southeast of the Santa Fe National Forest. The Rio Grande silvery minnow is extirpated on the Santa Fe National Forest. Cochiti Reservoir is a permanent barrier to its upstream movement, and no critical habitat exists on either national forest.
Table S-34 identifies the species known to be present on the Carson and Santa Fe National Forests; critical habitat if present; each species’ status, habitat, and estimated acres of habitat; and acres of weeds within the habitat.
Jemez Mountains Salamander (Plethodon neomexicanus) and Critical Habitat This lungless salamander is found primarily in mixed conifer habitats with abundant rocks and surface logs, especially on steep, north-facing slopes. It occurs in relatively high humidity microhabitats and on soils containing deep igneous, subsurface rock that is fractured to allow retreat underground to below the frost line. The species predominantly occurs at an elevation between 7,200 and 9,500 feet but has been found as low as 6,998 feet and as high as 10,990 feet (USFWS 2012a). Much of the life cycle occurs underground, with surface activity inside rotted coniferous logs or under rocks during a brief period of the summer when conditions are warm and wet. Habitat is typically Douglas fir, blue spruce, Engelmann spruce, ponderosa pine, or white fir. There is no aquatic life stage for this salamander. Above-ground movement is likely associated with summer monsoon rains, generally July through August. When the temperatures are close to, or within, the mean range of 43 to 63 degrees Fahrenheit, more salamanders will be found under logs compared to within logs when temperatures are outside this range (USFS 2011a).
The salamander is endemic to north-central New Mexico Jemez mountain range where it is found in Los Alamos, Rio Arriba, and Sandoval Counties. The species likely occupied the Jemez Mountains for at least 10,000 years to 1.2 million years (USFWS 2012b). The majority of the salamander habitat is on federally managed lands. The land managers in the area consist of the Santa Fe National Forest, the Valles Caldera National Preserve, the Bandelier National Monument, the Los Alamos National Laboratory, as well as the Santa Clara Indian Reservation, and other private landowners.
Mexican Spotted Owl (Strix occidentalis) and Critical Habitat The Mexican spotted owl’s nesting and roosting habitat is characterized by steep topography, cool shady canyons, and mature mixed conifer forest having high canopy closure. Protected activity centers are established to protect the territories of individual Mexican spotted owls. Owls also use ponderosa pine and
78 Final Supplemental Environmental Impact Statement other vegetation types for foraging. The Carson National Forest has very limited areas suitable for Mexican spotted owl, with only one protected activity center on the Jicarilla Ranger District. Less than 1 acre of weeds has been found in this protected activity center.
Mexican spotted owl critical habitat is defined as suitable habitat found within critical habitat units that are expected to provide the “primary constituent elements” for the owl. Primary constituent elements essential to the conservation of the Mexican spotted owl include those physical and biological features that support nesting, roosting, and foraging. Critical habitat is limited to areas that meet the definition of “protected” and “restricted” habitats, as described in the recovery plan (USDI Fish and Wildlife Service 1995). Excluded from the designation of critical habitat are those areas in restricted habitat that do not contain the primary constituent elements.
Table S-34. Threatened or endangered wildlife species Federal Percent of Status / Estimated Acres of Habitat National Acres of Known Weed Infested by Species Forest Habitat Habitat1 Infestations2 Weeds Jemez Endangered Forested areas within 8,681 15 0.2 Mountains / Santa Fe Valles Caldera and within (occupied) (occupied) salamander 5 miles of Valles Caldera boundary above 6,900 ft. except for grasslands and piñon-juniper Critical habitat Santa Fe Specific areas with the 56,779 142 0.3 defined habitat. Mexican spotted Threatened/ Old growth and mature 33,182 (SF) 31 (SF) 0.09 (SF) owl Carson and mixed conifer habitat, 600 (C) >1 (C) 0.2 (C) (Strix Santa Fe narrow mesic canyons occidentalis lucius) PACs Critical habitat Refer to project record 198,889 (SF) 660 (SF) 0.33 (SF) for description 23,275 (C) 297 (C) 1.3 (C) Southwestern Endangered Low gradient riparian 148 27 0.2 willow flycatcher Carson areas with open water (Empidonax and well- developed traillii extimus) willow patches. Dense Critical Habitat riparian vegetation and well-developed willow patches along the Rio Grande del Rancho. New Mexico Santa Fe Wet meadows with tall 18,158 821 4.5 meadow Carson grass in the Jemez and 7,554 377 5.0 jumping mouse* Sangre de Cristo (Zapus Mountains hudsonius luteus) Yellow-billed Santa Fe Riparian areas along 639 10 1.6 cuckoo Carson river systems in 1,006 33 3.3 (Coccyzus cottonwood forest. americanus occidentalis) 1. Acres of habitat are based on a combination of habitat type, known areas of occupancy, and/or proximity to habitat features. 2. Acres of weed infestations are populations known as of August 1, 2013. Comprehensive surveys of both national forests have not been completed.
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Southwestern Willow Flycatcher (Empidonax traillii extimus) and Critical Habitat The southwestern willow flycatcher nests in dense riparian vegetation including box elders, saltcedar, and willows. Nest sites have been found in pure stands of saltcedar in New Mexico. However, the species prefers more diverse native riparian vegetation that includes willow and cottonwood. It is known to occur in Rio Arriba and Sandoval Counties (Biota Information System of New Mexico).
The species is not federally listed in the Santa Fe National Forest. The flycatcher has been found in two locations on the Carson National Forest, within critical habitat on the Camino Real Ranger District in Peñasco, New Mexico.
Southwestern willow flycatcher critical habitat is defined as suitable habitat found within flycatcher critical habitat units that is expected to provide the “primary constituent elements” for the flycatcher. The primary constituent elements essential to the conservation of the southwestern willow flycatcher include those physical and biological features that support feeding, sheltering, and cover while breeding and migrating. Southwestern willow flycatcher constituent elements of critical habitat are found in the riparian ecosystem within the 100-year floodplain or flood prone area. The final rule in the Federal Register (78 FR 344) identifies primary constituent elements.
New Mexico Meadow Jumping Mouse (Zapus hudsonius luteus) and Critical Habitat Habitat requirements are characterized by tall (averaging at least 24 inches), dense herbaceous riparian vegetation composed primarily of sedges and forbs, associated with perennial flowing water (USFWS 2013b). The New Mexico meadow jumping mouse is considered a habitat specialist exclusively dependent upon riparian areas (Morrison 1990, 1992; Frey and Malaney 2009). This mouse has been found above 6,890 feet in the Jemez Mountains and at 3,937 feet in the Rio Grande Valley; in all cases they occurred within 150 feet of permanent free-flowing water (NMDGF 2008).
The New Mexico meadow jumping mouse eats mainly seeds and insects. Although primarily nocturnal, this mouse is also occasionally diurnal in its activity. In New Mexico, these mice are generally active three to four months of the year and hibernate through the winter months (USFWS 2013b). Jumping mice generally have limited ability to move and limited dispersal capabilities (Morrison 1988, p. 13).
The New Mexico meadow jumping mouse occurs within eight conservation areas across its current range. The Jemez Mountains conservation area is located on the Jemez and Cuba Ranger Districts of the Santa Fe National Forest which contains seven known populations. Populations are loosely defined as a capture location or cluster of locations within a reasonable dispersal distance of one another (generally less than a half mile).
Yellow-Billed Cuckoo (Coccyzus americanus occidentalis) The yellow-billed cuckoo breeds in riparian woodlands and similar habitats at lower (2,800 – 5,500 ft) to middle (5,000 – 7,500 ft) elevations where stream conditions provide sufficient permanent moisture for emergent plants, or for a narrow band of deciduous trees and shrubs. Populations fluctuate substantially in response to fluctuations in caterpillar abundance. Declines resulting from loss or disturbance of riparian habitat have been consistently reported in the West. The greatest factors affecting the yellow-billed cuckoo have been the invasion of exotic woody plants into southwest riparian systems, and clearing of riparian woodlands for agriculture, fuel, development, and attempts at water conservation (BISON-M 2001).
The Carson and Santa Fe National Forests have less than approximately 640 acres of suitable habitat for the cuckoo. Approximately 10 acres of known weed infestations occur within the cuckoo’s habitat on both national forests. Yellow billed cuckoo habitat is very limited on the Forests, since the cuckoos’ are known to occur at elevations less than 7,500 ft. Non-native shrubs are one of the factors negatively impacting the cuckoo.
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Environmental Consequences to Threatened and Endangered Species Effects of weed treatments described for all wildlife habitat and populations on the forests apply to threatened and endangered species. Table S-35 provides additional disclosures of estimated effects of each alternative for each threatened or endangered species. Effects are generally the same for all action alternatives other than the minor differences noted in the general wildlife effects, such as the slower rate of native vegetation recovery under alternative C. Also under alternative C, the low risk of impacts to individual animals from herbicides would be eliminated, and under alternative D, the low risk of impacts to individual animals from mechanical treatments would be eliminated. Action alternatives would not be likely to affect threatened or endangered species based on previous consultations with the U.S. Fish and Wildlife Service in 2005: Carson National Forest Consultation # 2-22-00-I-237 and Santa Fe National Forest Consultation # 2-22-00-I-324 (USFWS 2005) and recent consultation Santa Fe National Forest Consultation # 02ENNM00-2015-I-0149 (USFWS 2015).
Jemez Mountains Salamander (Plethodon neomexicanus) and Critical Habitat With design features in place, alternative B, the preferred alternative, may affect but is not likely to adversely affect the Jemez Mountain salamander. Alternative B may affect but is not likely to adversely affect critical habitat.
The Jemez Mountains salamander is present above ground only during late summer monsoon rains when rainfall is sufficient. Herbicide treatments would not take place in rainy weather as this makes the treatments ineffective. Treatments of grubbing, hand pulling, or controlled grazing would also not take place during the period when there is a risk to the Jemez Mountains salamander because it is above ground and could be inadvertently stepped on by a crew person. The cooperative management plan (New Mexico Endemic Salamander Team 2000) will be used to identify areas to protect the salamander. Rain for five consecutive days would delay treatment until the land surface conditions dried. During rainy weather, treatments other than herbicides would be possible on habitat known to not support the salamander.
Mexican Spotted Owl and Critical Habitat With design features in place, alternative B may affect but is not likely to adversely affect, and may be beneficial to the Mexican spotted owl. Alternative B may affect but is not likely to adversely affect critical habitat.
These determinations are based on the predicted increase in prey species in potential foraging areas for the Mexican spotted owl. The design features for the action alternatives listed in chapter 2 would prevent adverse effects to Mexican spotted owl and critical habitat. The treatments would be short duration, low disturbance activities which would occur once or twice in a season (depending on size of the treatment area).
Southwestern Willow Flycatcher and Critical Habitat With design features in place, alternative B may affect but is not likely to adversely affect the southwestern willow flycatcher. For example, surveys would be performed if the proposed treatment would occur when flycatchers may be present in the area. If the flycatcher were found during the surveys, treatment would not take place until the birds completed nesting and their young dispersed. Further, the effects of treatment would last a year or less or to the end of the next growing season.
Alternative C would rely on mechanical treatments that, when implemented in riparian areas, could result in greater change in the short-term vegetation structure compared to alternatives B or D.
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New Mexico Meadow Jumping Mouse (Zapus hudsonius luteus) and Critical Habitat With design features in place for riparian areas, alternative B, the preferred alternative, may affect but is not likely to adversely affect the New Mexico meadow jumping mouse. Alternative B may affect but is not likely to adversely affect critical habitat.
Design features for riparian areas would ensure the mouse would have no impacts from herbicides. Only small amounts of habitat would be treated each year within the riparian habitat of the mouse. Small areas could be treated by hand pulling or grubbing depending on the weeds species. Native vegetation would be avoided by identification before treatment. The mouse hibernates below ground for nearly 9 months and emerges in July. Any treatments would take place before the mouse emerged from hibernation in July.
Yellow-Billed Cuckoo (Coccyzus americanus occidentalis) Yellow billed cuckoo habitat is very limited on the Forests, since the cuckoos’ are known to occur at elevations less than 7,500 ft. Non-native shrubs are one of the factors negatively impacting the cuckoo. Removal of these plants will improve the habitat for the cuckoo. Mitigation measures would prevent disturbance during the breeding season.
Herbicide application within a riparian area or 50 feet from a water body would be limited to hand application onto individual weeds (using backpack spray wand, glove, wick, or rag). For treatment exceeding 1 acre within threatened, endangered or proposed species, surveys for the species would be conducted prior to implementation. If surveys are not conducted, that area will be considered occupied. With mitigation measures in place, the proposed action may affect but is not likely to adversely affect the yellow-billed cuckoo.
Table S-35. Effects to, and determinations for, threatened or endangered species Threatened or Alternative A Alternatives B, C, and D Endangered Species (No Action ) (All Weed Management Alternatives) Jemez Mountains Weeds would continue to No effect. No treatments would occur when the salamander reduce vegetative Jemez Mountains salamander comes above invertebrate habitat used ground after several consecutive days of rain. by the salamander as Herbicide treatments are not effective and would prey, thereby reducing the not be used in these conditions. The treatments of Jemez Mountains grubbing, hand pulling, or controlled grazing salamander prey base. (goats) would also not take place during the period when there is a risk to the Jemez Mountains salamander because it is above ground and could be inadvertently stepped on. Jemez Mountains Weeds would continue to May affect, but not likely to adversely affect with an salamander critical invade critical habitat overall beneficial effect because treatments would habitat making the surface improve the habitat of the invertebrate prey of the inhospitable or Jemez Mountains salamander. inaccessible due to root density or dead plant litter. Mexican spotted owl Weeds would continue to May affect, but not likely to adversely affect with an (threatened) reduce native understory overall beneficial effect because treatments would vegetation used by owl’s improve the habitat of the prey the owl feeds on. prey, thereby reducing the Negligible negative effects would be expected owl’s prey base. given the design features that avoid disturbing owls during the breeding season. Mexican spotted owl Weeds would continue to May affect, but not likely to adversely affect with an critical habitat displace native understory overall beneficial effect because treatments would vegetation. The improve the habitat. characteristics of critical habitat that favor prey habitat would be changed.
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Threatened or Alternative A Alternatives B, C, and D Endangered Species (No Action ) (All Weed Management Alternatives) Southwestern willow Weeds would continue to Treatments would improve native willow and flycatcher (endangered) displace the native cottonwood riparian habitats preferred by willow riparian vegetation that flycatchers. During treatments, some loss of flycatchers prefer. existing vegetation would occur and could reduce suitability for use by flycatchers until native vegetation is reestablished. There would be a very low risk that some individual birds could be impacted by any treatments given the design features requiring surveys prior to treatments in potential habitat. Southwestern willow Weeds would continue to No effect to critical habitat because the elements flycatcher critical displace native riparian that compose it will not be changed. habitat vegetation within critical habitat. New Mexico meadow The jumping mouse feeds Design features for riparian areas, the mouse’s jumping mouse on seeds of the riparian habitat, would ensure the mouse would have no grass community. They impacts from herbicides. Only small amounts of depend on tall grasses in habitat would be treated each year within the the narrow riparian zone. riparian habitat of the mouse. Small areas can be Weeds spreading within treated by hand pulling or grubbing depending on this habitat will decrease the weeds species. Native vegetation would be the suitability of the avoided by identification before treatment. The habitat. Weed populations mouse hibernates below ground for nearly 9 would be expected to be months and emerges in July. Any treatments would robust and increase with take place before the mouse emerged from constant soil moisture hibernation in July. The proposed action would not thus lessening the survival be expected to decrease population viability or chances of the mouse. cause a trend to federal listing of this species. Yellow-billed cuckoo Continued decline in the No direct impacts are expected to the western- (Coccyzus americanus extremely limited riparian yellow billed cuckoo because treatments would not occidentalis) cottonwood willow forest occur during breeding season. required by the cuckoo for Removal of nonnative invasive shrubs would nesting. indirectly improve the cuckoo’s habitat. One of the greatest factors affecting the yellow-billed cuckoo is the invasion of exotic woody plants into southwest riparian systems.
Cumulative Effects to Threatened and Endangered Species Because there would be no negative direct or indirect effects to threatened or endangered species due to the design of the project, there would be no cumulative adverse effects. The action alternatives, however, are expected to have beneficial direct and indirect effects to native habitats. Combined with other projects that would improve habitats, such as the Southwest Jemez Mountains Landscape Restoration Project, there would be an overall cumulative beneficial effect to threatened and endangered species habitats.
Affected Environment for Sensitive Wildlife Species The effects common to all species apply to the sensitive species described in this section. For purposes of this analysis, the affected environment includes the species actually found on the national forests and the habitats they occupy or are suitable for occupation. The list of species in the project area was developed from the 2013 list of sensitive animals and plants (USDA Forest Service, Southwestern Region, 2013). Sensitive aquatic species are discussed in the “Fisheries and Aquatics” section of this chapter. Acres of habitat come from GIS analysis through vegetative cover types and local specialists’ knowledge. The weed populations are those known as of August 1, 2013. Detailed descriptions of the species’ habitats and life histories are located in the project record. The roundtail chub does not occur on either national forest; thus, it will not be discussed
83 Invasive Plant Control Project further. The Canada lynx’s habitat is high-elevation, spruce-fir in Colorado, where it was introduced. It is not historically known to occur on either national forest and will not be discussed further.
The next tables display each sensitive species, the national forest(s) on which it is found, its habitat, the amount of habitat, and the acres of habitat with weeds. Where two numbers exist in a cell, the top number represents the Santa Fe National Forest and the bottom number represents the Carson National Forest.
Table S-36. Sensitive species, amphibians Estimated Percent of Acres or Acres of Habitat Species National Miles of Known Weed with Name Forest Habitat Habitat within Habitat Weeds Northern Santa Fe Associated with 40,790 1,882 4.6 leopard frog Carson water 24,784 1,682 6.8 (Rana pipiens) Western Carson High-elevation lakes 31,447 12 0.04 boreal toad and forests. (Bufo boreas Reintroduced in one boreas) location 2008.
Table S-37. Sensitive species, birds Percent of Estimated Acres of Habitat Acres or Known Weed Infested National Miles of Infestations with Species Name Forest Habitat Habitat within Habitat Weeds American Santa Fe High cliffs with 89,213 1,063 1.2 peregrine falcon1 Carson horizontal breaks for (Falco peregrines nest ledges anatum) Bald eagle Santa Fe Riparian areas along 20,252 355 1.8 (Haliaeetus Carson major river corridors, 37,364 100 0.3 leucocephalus) but winter habitat is not always associated with riparian areas. Boreal owl Santa Fe High-elevation mature 193,548 620 0.3 (Aegolius Carson spruce-fir forests 179,652 52 0.03 funereus) Burrowing owl Santa Fe Prairie dog towns 61,301 581 1.0 (Western) Carson 73,863 471 0.6 (Aegolius funereus) Gray vireo Santa Fe Juniper grasslands 178,430 919 0.5 (Vireo vicinior) Carson with shrub component 119,437 951 0.8 Northern Santa Fe Most mature forested 24,867 174 0.7 goshawk Carson habitats except piñon- 7,247 13 0.2 (Accipiter gentilis) juniper White-tailed Santa Fe Alpine areas 136,685 3 0.002 ptarmigan Carson 48,513 9 0.02 (Lagopus leucurus) 1. Habitat, including the known 12 post-fledging areas, for the peregrine falcon on the Carson National Forest has not yet been mapped. The effects, however, would be the same as for that described for the Santa Fe National Forest.
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Table S-38. Sensitive species, mammals Percent of Estimated Acres of Habitat Acres or Known Weed Infested National Miles of Infestations with Species Name Forest Habitat Habitat within Habitat Weeds Cinereus Santa Fe Riparian areas in sub- 262,024 695 0.3 (masked) shrew Carson alpine coniferous 260,291 52 0.02 (Sorex cinereus forest in Sangre de cinereus) Cristo, Jemez, and San Juan Mountains unusually above 9,500 feet Preble’s shrew Santa Fe Near permanent or 60,153 1,896 3.2 (Sorex preblei) intermittent streams in arid to semi-arid shrub or grassland or lesser into conifer forest American water Santa Fe Permanent streams, 60,153 1,896 3.2 shrew Carson seldom below 8,000 37,997 1,083 2.9 (Sorex palustris feet navigator) Spotted bat Santa Fe Rock cliffs 60,153 1,896 3.2 (Euderma Carson 37,397 1,803 4.8 maculata) Pale Townsend’s Santa Fe Caves, mines or 267,638 1,568 0.6 big-eared bat Carson abandoned buildings 293,153 193 0.07 (Corynorhinus townsendii pallescens) American marten Santa Fe High-elevation spruce- 263,881 928 0.4 (Martes Carson fir forests 318,454 104 0.03 americana origenes) Gunnison’s prairie Santa Fe Mountain meadows 1,214 205 16.9 dog* Carson Valley floors and plains 51,465 814 1.6 (Cynomys gunnisoni) Pika Santa Fe Talus slopes in Pecos 86,326 0.03 0.00004 (Ochotona Carson Wilderness in Santa 48,513 9 0.02 princeps saxatilis) Fe National Forest and locations within and outside Pecos Wilderness on the Carson National Forest Goat Peak pika Santa Fe Talus slopes in the 86,326 0.03 0.00004 (Ochotona Jemez Mountains princeps around the Valles nigrescens) Caldera National Preserve and west side of Los Alamos County * Indicates candidate species for Federal listing as threatened or endangered.
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Table S-39. Sensitive species, snail Percent of Estimated Acres of Habitat Acres or Known Weed Infested Species National Miles of Infestations with Name Forest Habitat Habitat within Habitat Weeds Ruidoso Santa Fe Found on bare soil, under 16,912 16 0.1 snaggletooth stones, and in thin (Gastrocopta accumulations of grass ruisdsensis) thatch and juniper litter on mid-elevation carbonate cliffs and xeric limestone grasslands along the eastern slopes of the Sangre de Cristo and Sacramento mountains in eastern New Mexico, where the only extant occurrences are.
Environmental Consequences to Sensitive Wildlife Species Effects of weed treatments described for all wildlife habitat and populations on the forests apply to sensitive species. All the action alternatives would treat less than 0.1 percent (and in most cases, much less than that) of the species’ habitat in a given year. This means that the species would still have the vast majority of its range to forage and breed in. The disturbance caused by weed treatments, already composing a very low percentage of total habitat, would last a season or less; the long-term result of reducing weed populations is expected to be beneficial to sensitive species by preventing weed expansion in native habitat. As a result, none of the action alternatives are expected to cause negative effects to the species or its habitat. The proposed action is not expected to cause a trend towards Federal listing for any sensitive species.
Amphibians Effects to all sensitive amphibians are listed in Table S-40. The proposed action (alternative B) is not expected to decrease population viability or cause a trend to federal listing.
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Table S-40. Sensitive species: Effects to amphibians Alternatives B, C, and D Alternative A (All Weed Management Species (No Action) Alternatives) Reason for Determination Northern leopard frog There would be an With design features for The proposed action would not increased loss of riparian riparian and aquatic contribute to the primary threats and aquatic habitat. habitats in place, none of to this species, which are Weeds would continue to the action alternatives will changes in wetlands, especially spread in this habitat have an impact to the frog. the alteration of marshy ponds to decreasing its suitability for reservoirs; stocking of predatory the northern leopard frog. fish; natural local extinctions as ponds dry up during years of low precipitation; and predation and competition by introduced bullfrogs (Biota Information System of New Mexico). Western boreal toad There would be an With design features for Recent surveys indicate the increased loss of riparian riparian and aquatic species may have declined in and aquatic habitat near habitats in place, none of New Mexico in recent years, and the Trout Lakes. Weeds the action alternatives will it is believed to be extirpated. The would continue to spread have an impact to the toad. design features for riparian areas in this habitat, decreasing would prevent any negative its suitability for the boreal effects to the toad or its habitat. toad.
Birds Effects to all sensitive bird species are listed in table S-41. The alternative B is not expected to decrease population viability or cause a trend to federal listing.
Table S-41. Sensitive species: Effects to birds Alternatives B, C, and D Alternative A (All Weed Management Species (No Action) Alternatives) Reason for Determination American peregrine Nest habitat would not be Protection zones (A – D, with Falcon habitat is primarily cliffs, falcon affected. Cliff nesting increased protections the where weeds do not tend to areas do not have weeds closer to the nest site) are occur. Treatments would occur in but protected zones established for each nest less than 0.1 percent of foraging around the nesting areas site. Activities are subject to habitat in a given year. could be subject to a slow restrictions according to decline in prey as its zone. With these in place, habitat becomes more none of the alternatives will unsuitable due to the have an impact to the falcon. spread of weeds.
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Alternatives B, C, and D Alternative A (All Weed Management Species (No Action) Alternatives) Reason for Determination Bald eagle Increased loss of riparian The bald eagle is only The design features specifically habitat as weed tree present during winter months for the bald eagle would prevent species displace the (November through March). negative impacts to the eagle or cottonwoods used as No treatments of any type its habitat. roosting trees and hunting would take place in winter to perches. Weed trees do avoid disturbance to the not grow large enough for eagle. Identification of eagle use. Decreased use herbaceous invasive species of the winter habitat on would be extremely difficult the two national forests. to impossible. Prescription burns (except burning of piled material in designated areas) would not be done in riparian habitat used by the eagle because of the detrimental effects of fire to large cottonwoods. Treatments that restore or protect native vegetation (planting of cottonwoods and willow) over the long term benefit the eagle. Boreal owl No impacts are expected No impacts are expected to Boreal owl habitat is remote and to the boreal owl because the boreal owl because its under snow in breeding season its habitat is highly remote habitat is highly remote and in early spring. Treatments could (not very affected by under snow in breeding not occur in the habitat until late weeds) and under snow season in the season when hatchlings in breeding season. have fledged. Burrowing owl There would be a slow No impacts to the owl are Burrowing owls have only been (western) decrease in acres of expected with the design located on the Carson. Some prairie dog towns (prey) features in place. treatments, such as grazing and due to increased weed prescribed fire, would improve cover. Available nesting habitat for burrowing owls. areas for the owl would decrease, leading to a lower population or abandonment of currently used areas. Gray vireo Slow decrease of No impacts to the gray vireo Habitat is scattered and sparse. understory preferred by are expected with the design As displayed in the vegetation the vireo for nesting and features in place. section, weed treatments are not foraging for invertebrate expected to affect piñon-juniper prey. Habitat would habitat on which this species become less sustaining depends. for the species. Northern goshawk Slow decrease in habitat No impacts to the goshawk With design features in place, quality as the prey are expected with the design alternative B would have no species food base is features in place. Treatments impact to the northern goshawk decreased by weeds. would not occur in breeding because treatments would not habitat during breeding occur in breeding habitat during season around nest sites or breeding season. on post-fledging areas.
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Alternatives B, C, and D Alternative A (All Weed Management Species (No Action) Alternatives) Reason for Determination White-tailed Slow decrease of forbs With the design features in Ptarmigan habitat is extremely ptarmigan preferred by ptarmigan for place no impacts are high elevation and is cold most of food. Habitat would expected to the white-tailed the year; treatments would only become less sustaining ptarmigan. Less than 0.001 occur for short periods. Design for the species. percent of its habitat would features would avoid disturbance be treated, leaving most of during the nesting period. its range undisturbed.
Mammals Effects to all sensitive mammals are listed in Table S-42. The alternative B is not expected to decrease population viability or cause a trend to federal listing.
Table S-42. Sensitive species: Effects to mammals Alternatives B, C, and D Alternative A (All Weed Management Species (No Action) Alternatives) Reason for Determination Cinereus Impacts are not expected With the design features in This shrew is mainly at high (masked) shrew immediately as cinereus place, no impacts to the elevation wet meadows / marsh shrew feeds on insects. cinereus shrew are expected. areas. Weeds are uncommon in Weed populations these habitats. Activities for weed increasing in the habitat control would be occasional and not would likely lead to cause a negative impact to the decreased prey insects habitat of the shrew. therefore less food available. Preble’s shrew Impacts are not expected With the design features in This shrew is mainly at lower immediately as Preble’s place, no impacts to the elevations in sage scrub areas. shrew feeds on insects. Preble’s shrew are expected. Weeds are uncommon in this Weed populations habitat. Temporary activities for increasing in the habitat weed control would be occasional would likely lead to and not cause a negative impact to decreased prey insects the habitat of the shrew. This shrew therefore less food has only been found on the Santa available. Fe National Forest in Sandoval County. American water Habitat could decrease as With the design features in Water shrews feed on small shrew water quality decreases place, no impacts to the minnow and insects in the water. from sediment not American water shrew are Protecting water quality by captured by weeds before expected. removing weeds helps protect the it reaches a stream. habitat of the shrew. Spotted bat Cave and cliff crevices do Bat habitat is cave and This species is rare throughout its not support weeds, so no crevices on cliff faces. No range, indicating that its scarcity in effect if the project did not treatments would occur in New Mexico may be due to biology occur. these areas. rather than due to other impacts (NMDGF 2006). This, combined with the design features, means that weed treatments are not expected to impact the species.
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Alternatives B, C, and D Alternative A (All Weed Management Species (No Action) Alternatives) Reason for Determination Pale Cave and cliff crevices do No impacts are expected to the The occurrence of this bat is Townsend’s big- not support weeds, so no pale Townsend’s big eared bat correlated strongly with the eared bat effect if the project did not because its main threats are availability of caves or cave-like occur. habitat loss, cave vandalism, roosting habitat (mines, buildings, and disturbance by cave snags, etc. (Perkins and Schommer explorers at maternity and 1992), which are highly sensitive to hibernation roosts. The design disturbance and the presence of features associated with this people. Weed treatments would not project would prevent take place in roosting habitat disturbance from the people because weeds don’t grow in them. conducting treatments. The design features would prevent disturbance to the bat. American Indirect impacts to the No impacts to the marten are This project doesn’t propose any marten marten would occur slowly expected because its main activities listed by scientific studies as weeds decrease habitat threats are timber harvest, as the main disturbance factors to quality for its prey species. trapping, snag removal, and the marten. firewood collection. This project does not propose any of those activities. Rocky Mountain Impacts are not expected No impacts to the bighorn Same as at left. bighorn sheep as bighorn sheep feed on sheep are expected because a diversity of plants and weeds aren’t expected to thrive will avoid those weeds at these high elevations, so which are toxic. Only very little habitat would be treated small amounts of weeds on an annual basis. Goats are would be expected to prohibited in bighorn sheep survive in their high- habitat by a permanent closure elevation habitat. order to avoid introducing disease to the bighorn sheep population. Gunnison’s Impacts are not expected No impacts to Gunnison’s Same as at left. prairie dog immediately as prairie dog are expected Gunnison’s prairie dog because its main threats feed on common grasses include predation, man, habitat and plants, avoiding those loss, and sylvatic plague (Biota weeds which are toxic. Information System of New Weed populations Mexico). This project would increasing in prairie dog improve habitat by increasing towns would likely lead to native plants that compose its decreased health and loss habitat. of prairie dogs or abandonment of the prairie dog town.
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Alternatives B, C, and D Alternative A (All Weed Management Species (No Action) Alternatives) Reason for Determination American pika Pika feed on common American pika inhabits high- No disturbance to the pika from grasses within their high- elevation rocky slopes in the treatments is expected (see left). elevation talus slope Sangre de Cristo Mountains at Weeds are generally not consumed habitat. They cut and store elevations above by the pika as the preferred forage grass to dry as hay for approximately 10,000 feet. This is grass. winter food. Weed species is an herbivore (Biota populations would be Information System of New expected to be small Mexico). No impacts to the pika within the talus slopes. No are expected because increase in weeds and treatments would not occur in therefore no decrease in its habitat – rocky, talus slopes. grasses are expected The pika isn’t expected to be within the rocky, high- subject to disturbance from elevation habitat. treatment. The proposed action would not be expected to decrease population viability or cause a trend to federal listing of this species. Goat Peak pika Goat Peak pika feed on Same as the American pika. Same as American pika. common grasses within their high elevation talus slope habitat. They cut and store grass to dry as hay for winter food. Weed populations would be expected to be small within the talus slopes. No increase in weeds and therefore decrease in grasses are expected within the rocky, high- elevation habitat.
Snail Effects to the sensitive snail are listed in Table S-43. The proposed action (alternative B) is not expected to decrease population viability or cause a trend to federal listing.
Table S-43. Sensitive species: Effects to snail Alternatives B, C, and D Alternative A (All Weed Management Species (No Action) Alternatives) Reason for Determination Ruidoso Impacts not Wildfire is the biggest threat to No impacts are expected to snaggletooth expected as this the snail because of the loss of the Ruidoso snaggletooth. snail feeds on cover and vegetative substrate Design features will avoid dead or decaying in its habitat. This snail lives impacts to the snail. The plant material. near limestone outcroppings proposed action would not be Weeds in where weed treatments are expected to decrease limestone habitat unlikely to occur. Since the snail population viability or cause are low to none. feeds on dead or decaying a trend to federal listing of plants, its food sources would this species. not be treated.
Cumulative Effects – Sensitive Species Because there would be no measurable direct or indirect effects to sensitive species as a result of the protective design features being in place, there would be no cumulative effects.
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Affected Environment for Migratory Birds Presidential Executive Order 13186 (January 2001) requires unintentional take of migratory birds reasonably attributable to agency action be disclosed and the effects to migratory bird populations be determined, with emphasis on species of concern that emphasizes conservation of neotropical migratory birds. The Forest Service analyzes impacts of proposed forest management activities by addressing the following: (1) effects to “highest priority” species as identified by New Mexico Partners in Flight, (2) effects to important bird areas, and (3) effects to important overwintering areas.
New Mexico Partners in Flight considers eight risk factors in identifying conservation priority species: (1) global abundance, (2) New Mexico breeding abundance, (3) global breeding distribution, (4) New Mexico breeding distribution, (5) threats to breeding in New Mexico, (6) importance of New Mexico to breeding, (7) global winter distribution, and (8) threats on the wintering grounds. Species with the highest risk factors are classified as highest priority for conservation action. This evaluation addresses general effects to migratory birds and specific effects to highest priority species for the main habitat types found in the project area.
Important Bird Areas. “Important Bird Area” is a designation created by National Audubon and Bird Life International7 to recognize the importance of specific areas for breeding or migrating birds. The important bird areas in, or near, the Santa Fe National Forest and Carson National Forest are Bandelier National Monument, Caja del Rio, Chama River Gorge/Golondrino Mesa, Randall Davey Audubon Center/The Nature Conservancy Santa Fe Preserve, Upper Rio Grande Gorge, and Valles Caldera National Preserve.
Important overwintering areas are often large wetlands. Areas considered important on the two national forests include the Rio Chama, Rio Grande at White Rock Canyon, Upper Rio Grande Gorge, and Pecos Canyon corridors. These areas provide wintering habitat for bald eagle.
Table S-44 lists highest priority migratory bird species either known to occupy, or are likely to occur in, the two national forests, based on appendix D of Partners in Flight and habitat on the forests.
7 http://iba.audubon.org/iba/siteSearch.do
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Table S-44. Highest priority migratory birds and habitats used Highest Priority Species Primary Habitat Black swift High elevation riparian woodland Red-naped sapsucker Hammond’s flycatcher Veery American dipper MacGillivray’s warbler Lewis’s woodpecker Middle elevation riparian woodland Red-headed woodpecker Brown-capped rosy finch Alpine tundra White-tailed ptarmigan Williamson’s sapsucker Mixed conifer Olive-sided flycatcher Dusky flycatcher Ferruginous hawk Piñon-juniper Gray vireo Black-throated gray warbler Gray flycatcher Bendire’s thrasher Ferruginous hawk Plains and mesa grassland Prairie falcon Bendire’s thrasher Long-billed curlew Lark bunting Lewis’s woodpecker Middle elevation riparian woodland Red-headed woodpecker Blue grouse Spruce-fir Boreal owl Flammulated owl Ponderosa pine Virginia’s warbler Grace’s warbler Bendire’s thrasher Great Basin desert shrub Sage sparrow Loggerhead shrike Sage thrasher MacGillivray’s warbler Montane shrub Green-tailed towhee Black swift Cave/Rock/Cliff Prairie falcon
Environmental Consequences to Migratory Birds Effects previously described for all wildlife habitat and populations on the forests apply to migratory birds. Table S-45 provides additional disclosures of estimated effects of each alternative for migratory birds. No unintentional take of migratory bird species is anticipated because any disturbance associated with treatment would be short duration (less than a few days in a season) and on less than 0.1 percent of habitat, leaving the majority of forage and breeding habitat available. Over time, removal of weeds would promote native vegetation favorable to migratory birds.
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Table S-45. Effects to migratory birds and habitats Alternatives: High Priority Migratory Bird Alternative A B, C, D1 Species Habitats (No Action) (All Weed Management) Black swift High elevation Weeds would continue to No unintentional take of these Red-naped riparian woodlands spread and the loss of native species is anticipated or sapsucker plants and plant diversity expected. Treatments would would reduce habitat quality, benefit these birds because native Hammond’s impacting these birds. plants would become more flycatcher abundant, improving plant American diversity and habitat quality once dipper weeds are eliminated or controlled. Native plants provide Veery important food sources to species MacGillivray’s directly, as seeds, or for the prey warbler species of predators. No impact to population or habitat trends are Wilson’s Wet meadows Weeds would continue to expected. phalarope spread and the loss of native Bobolink plants and plant diversity would reduce habitat quality, impacting these birds. Brown- Alpine tundra Weeds would continue to No unintentional take of these capped rosy spread and the loss of native species is anticipated or finch plants and plant diversity expected. No treatments are likely would reduce habitat quality. White-tailed to occur in this habitat, thus no ptarmigan impacts would be expected. Treatments would benefit these birds because native plants would become more abundant, improving plant diversity and habitat quality once weeds are eliminated or controlled. Native plants provide important food sources to species directly. Northern Mixed conifer Weeds would continue to No unintentional take of these goshawk spread and the loss of native species is anticipated or Mexican plants and plant diversity expected. Treatments would spotted owl would reduce habitat quality, benefit these birds because native impacting these birds. plants would become more Williamson’s abundant, improving plant sapsucker diversity and habitat quality once Olive-sided weeds are eliminated or flycatcher controlled. Native plants provide important food sources to species Dusky directly (seeds) or for the prey flycatcher species of predators. No impact to Ferruginous Plains/mesa Weeds would continue to population or habitat trends would hawk grasslands spread and the loss of native be expected. Prairie falcon plants and plant diversity would reduce habitat quality, Bendire’s impacting these birds. thrasher Long-billed curlew Lark bunting Ferruginous Piñon-juniper Weeds would continue to No unintentional take of these hawk spread and the loss of native species is anticipated or Gray vireo plants and plant diversity expected. Treatments would
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Alternatives: High Priority Migratory Bird Alternative A B, C, D1 Species Habitats (No Action) (All Weed Management) Bendire’s would reduce habitat quality, benefit these birds because native thrasher impacting these birds. plants would become more abundant, improving plant Black- diversity and habitat quality once throated gray weeds are eliminated or warbler controlled. Native plants provide Gray important food sources to species flycatcher directly, as seeds or for the prey species of predators. No impact to Lewis’s Mid-elevation Weeds would continue to population or habitat trends would woodpecker riparian woodland spread and the loss of native be expected. Red-headed plants and plant diversity woodpecker would reduce habitat quality, impacting these birds. Blue grouse Spruce/subalpine Weeds would continue to No unintentional take of these fir Boreal owl spread and the loss of native species is anticipated or plants and plant diversity expected. Treatments would would reduce habitat quality, benefit these birds because native impacting these birds. plants would become more Flammulated Ponderosa pine Weeds would continue to abundant, improving plant owl spread and the loss of native diversity and habitat quality once plants and plant diversity weeds are eliminated or Virginia’s controlled. Native plants provide warbler would reduce habitat quality, impacting these birds. important food sources to species Black- directly (seeds) or for the prey throated gray species of predators. No impact to warbler population or habitat trends would be expected. Bendire’s Great Basin desert Weeds would continue to No unintentional take of these thrasher shrub spread and the loss of native species is anticipated or Sage sparrow plants and plant diversity expected. Treatments would would reduce habitat quality, benefit these birds because native Loggerhead impacting these birds. plants would become more shrike abundant, improving plant Sage diversity and habitat quality once thrasher weeds are eliminated or controlled. Native plants provide Green-tailed Montane shrub Weeds would continue to important food sources to species Towhee spread and the loss of native directly, as seeds, or for food plants and plant diversity species of prey for predators. No would reduce habitat quality, impact to population or habitat impacting these birds. trends would be expected. Black swift Cave/rock/cliff No weed infestations are No unintentional take of these known to occur in this habitat species is anticipated or type. expected. No treatments are likely to occur in this habitat, thus no impacts would be expected. No impacts to population or habitat trends would be expected.
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Alternatives: High Priority Migratory Bird Alternative A B, C, D1 Species Habitats (No Action) (All Weed Management) Important Bird Areas: Bandelier The important bird areas Treatments would benefit birds National Monument, Caja del Rio, encompass all habitat types because native plants would Chama River Gorge / Golondrino from low elevation to upper become more abundant, Mesa, Caja del Rio, Randall Davey elevation forest types. Weeds preserving native plant diversity Preserve / Santa Fe Canyon would continue to spread and and habitat quality once weeds Preserve, Upper Rio Grande Gorge the loss of native plants and are eliminated or controlled. and the Valles Caldera National plant diversity would reduce Native plants provide important Preserve. habitat quality, impacting birds food sources to species directly, that use these areas. as seeds, or for the prey species of predators. No impact to population or habitat trends would be expected. Over-wintering areas Overwintering areas are Treatments reducing weeds such associated with large river as saltcedar would maintain or riparian areas. These areas enhance habitat quality and are among the most heavily suitability of overwintering areas. impacted by weeds such as saltcedar, which reduces habitat suitability for many migratory bird species. 1. Assumes full compliance with design features, conservation and recovery plans, and other project requirements.
Cumulative Effects to Migratory Birds The direct and indirect effects of this project would be short-term disturbance (less than 5 days) on less than 0.1 percent of habitat on an annual basis, leaving the majority of forage and breeding habitat available. Over time, the removal of weeds would promote native vegetation favorable to migratory birds. The direct and indirect effect to migratory birds would be immeasurable and would not contribute any noticeable cumulative effect when added to other activities in the analysis area.
Effects of Forest Plan Amendment to All Wildlife Species The proposed amendment to the Santa Fe National Forest Plan allows weed treatment with herbicides in the currently restricted area of municipal watersheds and on soils with a low revegetation potential. The amendment would result in no long-term effects to wildlife resources presently or when future projects are implemented.
The language of the amendment for municipal watersheds would not affect riparian or aquatic resources because of the design features in place for areas near water.
The language of the amendment for soils would not affect wildlife because ground cover needs to be restored quickly, thereby providing forage or cover vegetation preventing soil loss.
The deletion of language for soils with moderate to high cation exchange would not affect wildlife. These soils would still need to be revegetated or treated for regrowth of minimal vegetation providing forage or cover.
The modifications proposed by the amendment with design features and protocols included have minimal short-term disturbance effects to individuals but would not affect populations. The amendment is not expected to cause any long-term impacts to wildlife during the implementation of future projects because the intent of weed treatment is to preserve, restore, or improve habitat quality. Future projects in treatment areas would be analyzed for potential effects to wildlife at the appropriate level required by the National Environmental Policy Act.
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Fish and Aquatic Resources [Replaces entire section] Affected Environment for Fish and Aquatic Resources The affected environment for fish and aquatic resources is San Juan, Arkansas, and Rio Grande River basins in northern New Mexico (refer to the “Water Resources” section for a map and description of watersheds). Forty-eight of the 55 project watersheds have weeds infestations, the majority of which are found along roads and within 300 feet of perennial streams. Riparian areas (terrestrial habitat directly adjacent to streams) support a diverse assortment of both plant and animal species (Naiman et al. 1993). The ability of a nonnative species to establish in an area outside its native range in areas with high diversity can be greater than in less diverse areas (Planty-Tabacchi et al. 1996, Stohlgren et al. 1999). This is particularly important to consider in areas where high plant diversity is focused in the riparian zone, such as the arid Southwest (Knopf et al. 1988). Riparian areas are vital to fish and aquatic resources because high-quality riparian areas and high- quality streams are analogous, meaning you must have one to have the other (Hynes 1975).
How Weeds Affect Fish and Aquatic Resources The link between terrestrial environments and aquatic ecosystems can be difficult to understand, but the importance of streamside vegetation for stream health cannot be overstated. For example, the majority of productivity in mountain streams is the result of organic and nutrient inputs from surrounding areas (Cummins and Klug 1979, Vannote et al. 1980). The deposition of leaf litter into streams can provide large quantities of consumable nutrients for a variety of aquatic insects (Wallace and Webster 1996), which, in turn, are consumed by insectivorous fish (Sublette et al. 1990, Rinne 1995). Further, terrestrial invertebrates that fall from streamside vegetation into streams can constitute an important part of a fish’s diet (Rinne 1995). Streamside vegetation is also critical for preserving the integrity of stream channels (Gran and Paola 2001) and reducing excessive bank erosion (Beeson and Doyle 1995). The ability to stabilize stream banks varies between vegetation types and species (Lyons et al. 2000). A combination of grasses, shrubs, and trees may be the best at reducing erosion because the roots of each extend to different depths, holding a greater portion of the soil profile in place (Zuazo and Pleguezuelo 2008).
Weeds threaten the composition of riparian plant and animal species. Weeds have three things in common: (1) they are habitat generalists, meaning they can do well in most environments; (2) they are highly adaptable to change; and (3) they have high reproduction rates, meaning they produce offspring early and often (Sakai et al. 2001). Native vegetation often cannot compete with successful invaders and can become extirpated from an area (Lodge 1993). As invasive plants continue to spread and outcompete native species, a dramatic shift in species composition can occur, from a diverse community of plants to a monoculture with one species (Eiswerth and Johnson 2002).
As the riparian plant community changes, so does the interaction between the vegetation and nearby stream. For example, deposition of leaf litter from an invasive shrub into an adjacent stream caused a four-fold decrease in aquatic insect abundance when compared to areas of native vegetation (Baily et al. 2001). Such a reduction in prey abundance could increase stress on fish and other insectivorous organisms. Additionally, a reduction in the variety of plants present could result in a less stable soil horizon, which could increase stream sedimentation because of stream bank erosion. Excessive sedimentation can reduce aquatic habitat for insects along the stream bottom, smother or damage fish eggs, and can cause damage to the gills of aquatic organisms because of abrasions (Newcombe and MacDonald 1991). It is important to note that only a few examples of how weeds may impact fish and aquatic resources are presented here and that other impacts from weeds may exist.
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Forest Sensitive Aquatic Species Analysis and Habitat Information The analysis of aquatic management indicator species appears in the “Wildlife” section of this chapter. In addition to being a management indicator species, the Rio Grande cutthroat trout is a Forest Service sensitive species and a candidate for listing under the Endangered Species Act; therefore, it will also be analyzed in this section. Table S-46 displays the Forest Service Southwestern Region sensitive aquatic species found on the Carson and Santa Fe National Forests and lists their occupied or suitable habitats. A full species description is located in the project record.
Table S-46. Sensitive aquatic species found on the Carson and Santa Fe National Forests and occupied or suitable habitats Estimated Acres of Percent of Acres or Known Weed Habitat National Miles of Infestations Infested with Species Name Forest Habitat Habitat within Habitat* Weeds Lilljeborg’s pea-clam Santa Fe Nambe Lake in the 0.1 0 0 Pisidium lilljeborg Pecos Wilderness, Santa Fe National Forest Sangre de Cristo Carson Only historical 8 0 0 pea-clam location is at Middle Pisidium Fork Lake, Carson sanguinichristi National Forest Nokomis fritillary Carson Wetlands associated 37,398 1,803 4.8 Speyeria nokomis with flowing water. nokomis Streamside meadows with an abundance of violets Rio Grande chub Santa Fe Headwater streams SF = 1,822 SF = 298 SF = 16.4 Gila pandora Carson C = (78) C = (0.6) C = 0.8 Rio Grande cutthroat Santa Fe Headwater streams SF = 3,924 SF = 5 0.1 trout Carson C = (138) C = (1.8) 1.3 Onchoryncus virginalis clarkii Rio Grande sucker Santa Fe Headwater streams SF = 2,235 SF = 367 16.4 Catostomus plebius Carson C = (69) C = (0.4) 0.6 * Acres of weeds located along linear miles of stream were calculated using a 66-foot buffer on each side of the aquatic habitat.
Lilljeborg’s Pea-clam The New Mexico population of the species occurs in Nambe Lake, which is located in a glacial cirque about 11,300 feet in elevation. The surrounding habitat includes rocky talus and stands of Englemann spruce.
Sangre de Cristo Pea-clam The only known population of Sangre de Cristo Pea-clam occurs at Middle Fork Lake in the Sangre de Cristo Mountains of northern New Mexico at approximately 10,845 feet in elevation (Taylor 1987). Current population and distribution of this species are unknown.
Nokomis Fritillary Butterfly The Nokomis fritillary butterfly is found in streamside meadows and open seepage areas with an abundance of violets generally surrounded by desert landscapes (Pyle 1976). No confirmed sightings of this species are documented on National Forest System lands. Potential threats include weeds, insecticides, and elimination of food sources by herbicides.
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Rio Grande Chub Rio Grande chub are native to the Rio Grande basin in New Mexico but is also found in the Pecos and Canadian River drainages. Rio Grande chub inhabits cold water streams, and uses undercut banks, brush, and woody debris for cover (Rinne 1995b). The greatest threats to this species include degraded and fragmented habitat, invasive fish, and land use changes which reduce natural stream function (Rees et al. 2005).
Rio Grande Cutthroat Trout The Rio Grande cutthroat trout occurs in high-elevation mountain streams from south-central Colorado to southern New Mexico (Rinne 1995, Young et al. 2005). Rio Grande cutthroat trout occur in streams with clean gravel and cobble substrates, high habitat heterogeneity, and minimal influence from nonnative salmonid competitors (Harig and Fausch 2002). The greatest threats to this species include hybridization with nonnative trout, habitat degradation, and stream dewatering (Stefferud 1988).
Rio Grande Sucker Rio Grande sucker typically occurs in low-gradient streams at middle (6,600 to 8,600 feet) elevations (Calamusso and Rinne 1996, Calamusso et al. 2002). The greatest threats to this species include competition from the nonnative white sucker (Catostomus commersonii) and habitat degradation (Calamusso et al. 2002).
Environmental Consequences–Fish and Aquatic Resources Methodology Scientific literature was reviewed to evaluate the effects of herbicide application on fish and aquatic species. Additionally, to evaluate the risk of herbicides reaching aquatic ecosystems at levels that would cause harm, a “worst-case scenario” model was created using picloram as the representative herbicide because of its mobility in soil. The model used alternative D (herbicide only) and assumed all weed infestations (as of 2005) would be treated in the same year rather than being spread out over the next 10 years. The amount of picloram entering aquatic ecosystems with surface water runoff and overland flow after terrestrial application was modeled in the 11 representative watersheds (refer to appendix 5 of the final environmental impact statement).
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Table S-47. Environmental consequences and determinations for fish and aquatic species Alternative A Alternatives B, C, and D Species (No Action) (All Weed Management Alternatives) Reason for Determination Lilljeborg’s No impacts are expected No impacts to the Lilljeborg’s pea-clam or its habitat The design features that limit the use of certain pea-clam because no known populations are expected because no treatments would take place herbicides in riparian environments would prevent of weeds are found around in or around the lake. adverse impacts to this species. Otherwise, no other Nambe Lake. kinds of treatments would occur in or around Nambe Lake, so there would be no effect to the clam. Sangre de No impacts are expected No impacts to the Sangre de Cristo pea-clam or its The design features that limit the use of certain Cristo pea- because no known populations habitat are expected because no treatments would take herbicides in riparian environments would prevent clam of weeds are found around place in or around the lake. adverse impacts to this species. Otherwise, no other Middle Fork Lake. kinds of treatments would occur in or around Middle Fork Lake, so there would be no effect to the clam. Nokomis If weeds are not treated, the With design features in place the proposed actions may The design features requiring hand application of fritillary Nokomis fritillary butterfly’s have an impact on the butterfly or its habitat. However, herbicide in this species’ habitat would greatly food base may shift from native the unintentional application of herbicides to this reduce the risk of accidental treatment of native to nonnative vegetation. As this species’ preferred forage would be minimal because of plants. Furthermore, the scale at which weeds have butterfly continues to forage, it targeted herbicide application. Mechanical and grazing infested Nokomis fritillary habitat is such that could inadvertently pollinate alternatives would have a greater impact to this species impacts from mechanical and grazing would be nonnative plants, which would and its habitat because precise treatment of weeds minimal. perpetuate the spread of would be difficult. However, less than 5 percent of the undesirable weeds and further species habitat is anticipated to be treated; therefore, shift the butterfly’s food base. the proposed treatments are not expected to decrease population viability or cause a trend to federal listing of Nokomis fritillary butterfly. Rio Grande Weeds would continue to With design features in place, the proposed treatments The design features for riparian areas are to avoid Chub displace native plants and could have an indirect impact to individuals of the Rio herbicide use within 50 feet on either side of grasses within riparian, so Grande chub. Rio Grande chub is carnivorous, feeding streams of known Rio Grande chub occupancy habitat quality and perennial on zooplankton and aquatic insects. If herbicide was to during spawning season (March 1 to July 31). water quality would decline. reach the aquatic environment (alternatives B and D), a Furthermore, design features specify the quantity, reduction in aquatic vegetation and phytoplankton duration, and type of herbicides to be used near could occur, which could cause a trophic cascade (that fish-bearing streams, which would minimize is, a shift in the food chain), resulting in reduced negative impacts to Rio Grande chub. Additionally, aquatic invertebrate herbivore prey base for fish. ground disturbance from other alternatives would be Mechanical and grazing methods for weed removal localized and small in scale. Because treatments could temporarily increase sedimentation due to would occur outside of spawning season, no ground disturbance in the riparian area. The impacts impacts to eggs would be expected. Fish are highly from alternatives B, C, and D would likely be a mobile and could temporarily seek better conditions localized and small in scale Therefore, the proposed if necessary. actions are not expected to decrease population viability or cause a trend to federal listing of Rio Grande chub.
100 Final Supplemental Environmental Impact Statement
Alternative A Alternatives B, C, and D Species (No Action) (All Weed Management Alternatives) Reason for Determination Rio Grande Weeds would continue to With design features in place, the proposed treatments The design features for riparian areas are to avoid cutthroat displace native plants and may have an indirect impact to individuals of the Rio herbicide use within 50 feet on either side of trout grasses within riparian, so Grande cutthroat trout. Rio Grande cutthroat trout is streams of known Rio Grande cutthroat trout habitat quality and perennial carnivorous, preying entirely on macroinvertebrates. If occupancy during spawning season (March 1 to water quality would decline. herbicide was to reach the aquatic environment July 31). Furthermore, design features specify the (alternative B and D), a reduction in aquatic vegetation quantity, duration, and type of herbicides to be used and phytoplankton could occur, which could cause a near fish-bearing streams, which would minimize trophic cascade (that is, a shift in the food chain), negative impacts to Rio Grande cutthroat trout. resulting in reduced aquatic invertebrate herbivore prey Additionally, ground disturbance from other base for fish. Mechanical and grazing methods for alternatives would be localized and small in scale. weed removal could increase sedimentation due to Because treatments would occur outside of ground disturbance in the riparian area. The impacts spawning season, no impacts to eggs would be from alternatives B, C, and D would likely be a expected. Fish are highly mobile and could localized and small in scale. Therefore, the proposed temporarily seek better conditions if necessary. actions are not expected to decrease population viability or cause a trend to federal listing of Rio Grande cutthroat trout. Rio Grande Weeds would continue to With design features in place, the proposed treatments The design features for riparian areas are to avoid sucker displace native plants and may have an indirect impact to individuals of the Rio herbicide use within 50 feet on either side of grasses within riparian, so Grande sucker. Rio Grande sucker is omnivorous, streams of known Rio Grande sucker occupancy habitat quality and perennial feeding on both aquatic vegetation (for example, algae) during spawning season (March 1 to July 31). water quality would decline. and aquatic invertebrates. If herbicide was to reach the Furthermore, design features specify the quantity, aquatic environment (alternatives B and D), a reduction duration, and type of herbicides to be used near fish in aquatic vegetation and phytoplankton could occur, bearing streams, which would minimize negative which could negatively impact Rio Grande sucker by impacts to Rio Grande sucker. Additionally, ground limiting available forage as well as cause a trophic disturbance from other alternatives would be cascade (that is, a shift in the food chain), resulting in a localized and small in scale. Because treatments reduced aquatic herbivorous invertebrate prey base for would occur outside of spawning season, no fish. Mechanical and grazing methods for weed impacts to eggs would be expected. Fish are highly removal could increase sedimentation due to ground mobile and could temporarily seek better conditions disturbance in the riparian area. The impacts from if necessary. alternatives B, C, and D would likely be a localized and small in scale. Therefore, the proposed actions are not expected to decrease population viability or cause a trend to federal listing of Rio Grande sucker.
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Alternative A–No Action Weed infestations would go untreated under alternative A. This alternative would likely result in a greater abundance of undesirable plants on the two national forests. Weeds would continue to displace native plants and grasses within riparian areas, reducing forage, habitat, and water quality, which would negatively affect fish and aquatic resources.
Effects of Ground Disturbance There would be no sediment caused by ground-disturbing weed treatments under this alternative.
Effects of Herbicides Since herbicides would not be applied under this alternative, no effects from herbicides to fish and aquatic resources would occur.
All Action Alternatives (B, C, and D) For all the action alternatives, the proportion of weed-infested habitat is small and the proportion expected to be treated each year even smaller, which reduces the risk of impact to an individual organism from any treatments. Alternative C would eliminate the risk from herbicides and alternative D would eliminate the risk of impacts from ground-disturbing activities. Alternative B (combination of alternatives C and D) is expected to be the most successful at eradicating weed infestations. The treatment and eradication of weed populations on the two national forests would have long-term beneficial effects for fish and aquatic resources.
Effects of Ground Disturbance Mechanical and grazing methods of weed control could increase sediment transport to streams; however, because of the small scale of most treatment areas, increased soil erosion would likely be within acceptable limits as described in the “Soil Resources” section. Land devoid of vegetation post treatment would be planted with native plant species, which will reduce the risk of erosion. Based on the analysis presented in the soil, water, and vegetation section, along with design features to limit sediment transport, there would be a minimal increase in sediment delivery to streams, resulting in a low risk of impact to fish and aquatic resources.
Effects of Herbicides With the design features in place, concentrations of herbicides and the duration of exposure on the aquatic environment would be small and well below levels at which chronic exposure effects are documented for aquatic organisms. The risk assessments for each herbicide formulation include reviews of relevant information on an herbicide’s likely long-term effect, based on application rates used by the Forest Service. Furthermore, following label instructions and proper application procedures (as outlined by the herbicide manufacturer) would greatly reduce the likelihood of herbicides reaching the aquatic system. If an herbicide was to reach the aquatic environment, however, a reduction in aquatic vegetation and phytoplankton could occur. This could cause a shift in the food chain, resulting in fewer prey for fish.
Results of “Worst-case Scenario” Analysis This document analyzes three methods of potential contamination by herbicides: (1) leaching through soil to reach groundwater; (2) overland flow into water; or (3) accidental spills into water. 1. Leaching through soil. The risk of herbicides leaching through the soil into groundwater is low. Soils are rarely a receptor for herbicide application because herbicides would be sprayed directly on weeds and not the soil, meaning little herbicide would touch soil in the first place. Herbicides on soil pose little risk to groundwater because chemicals typically disappear from the soil surface by plant uptake, volatilization, natural decomposition, or adsorption of the herbicide by soil particles. As Norris et al. (1991) indicates, leaching of chemicals through the soil profile is least likely to occur in undisturbed forest environments.
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The half-lives (the time it takes for half the active ingredient to degrade) of most of the herbicides are 24 to 48 hours in water. Finally, the herbicides that pose the greatest risk in aquatic environments would be prohibited from use near such environments (see table S-11, rows 41-42 and 46-49). For example, picloram would not be used in an aquatic environment or in areas having a shallow water table. Another feature limits herbicide use to a short-lived, nonleachable herbicide registered by the Environmental Protection Agency for use on permeable soils with shallow water tables. Monitoring the effects of treatments and effectiveness of design features would further reduce the risk of unexpected impacts over the life of this project.
2. Overland flow. No measurable impacts to aquatic organisms are expected as a result of overland flow of herbicides. The risk of herbicides being carried in water from rain or irrigation to aquatic systems varies depending on soil type and the timing and intensity of rain following an application. Studies show that the risk of herbicides entering aquatic systems from overland flow runoff tends to be lower on well-vegetated forests and rangelands. Norris et al. (1991) indicated overland flow occurs infrequently on most undisturbed forest lands because the infiltration capacity of the forested soils is usually greater than the rate of precipitation. However, denuded and compacted soil, such as along roads, trails, and in campsites where many known weeds are located, have potential to allow surface runoff. High-severity wildfires reduce soil infiltration rates, increasing the magnitude of erosion and runoff. This effect is greatly diminished by the second year after a fire because vegetation recovery begins and soil erosion is reduced once the erosion rills break through the soil hydrophobic layer (DeBano 2000).
The worst-case-scenario modeling performed for this analysis assumed all known weed infestations in Ponil Creek and Lower Jemez River watersheds would be treated in the same year. The results of the model determined the level of herbicide that could potentially reach the water might exceed the “no effect” threshold. Because all weeds would not be treated in a single year (refer to the assumptions on page 51), the quantity of herbicide required to exceed the “no effect” threshold would not be applied within a timeframe to negatively affect fish and aquatic resources. Furthermore, herbicides selected for use in riparian areas or next to aquatic habitats would be restricted to those registered by the Environmental Protection Agency for use in aquatic habitats and documented as having a low risk to fish and other aquatic species. Monitoring the effects of treatments and effectiveness of design features would further reduce the risk of unexpected impacts over the life of this project.
3. Accidental spills. Accidental spills are possible, but considered unlikely with standard herbicide use and handling procedures in place. If a spill were to occur, the containment plan would reduce the risk of negative effects.
Cumulative Effects to Fish and Aquatic Resources The analysis area for cumulative effects on fisheries and aquatic resources is the San Juan, Arkansas, and Rio Grande River Basins. This boundary represents the areas where the actions proposed in this project are most likely to interact with other activities, in particular the weed treatments and ground disturbance on both national forests and other lands contained in these watersheds.
Cumulative Effects of Ground Disturbance The potential for weed treatments to increase soil erosion and sediment transport would be minimal (as just described) and thus would not contribute cumulatively to sediment production in any watershed, especially since all the activities that cause soil erosion would be widely distributed across the forests and occur at different times throughout the year. With no cumulative increase in sediment delivery from this project, there would be no cumulative effect to aquatic insects or fish and aquatic habitat. There would be few acres following treatment largely devoid of vegetation because weeds only compose a portion of the vegetation in a treatment area. Furthermore, design features require bare ground be revegetated with native plants (Table S- 11, row 19).
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Cumulative Effects of Herbicides As just described, the direct and indirect negative effects from herbicides to aquatic insects or fish and aquatic habitat would be low and of short duration (one to two days). To be cumulative, the effects from this project must overlap in space and time with the effects of other projects. Because of the short duration of treatment effects on National Forest System lands, a cumulative impact from herbicides originating on other jurisdictions would be unlikely. Fish and aquatic insects are not likely to be cumulatively exposed to herbicides from multiple jurisdictions at the same time.
Furthermore, most of the jurisdictions that use herbicides are required by law to follow similar, risk-reducing measures as presented in this document. Government agencies applying herbicides must all meet acceptable levels of water quality protection.
Generally, properties bordering the forests have small livestock and hay operations. The landowners do not typically use large amounts of herbicides, although this could increase as thistles and other weeds invade pasture lands. However, cumulatively, there would be a low risk herbicide use by the forests and adjacent landowners would exceed the “level of no concern” thresholds proposed by the two national forests.
Cumulative Effects of Controlling or Eradicating Weeds The direct and indirect effect of the action alternatives, as just described, would be to promote native vegetation, which would increase native habitat that aquatic insects and fish depend on. This project would cumulatively improve stream quality along with other projects that promote native vegetation along streams. The most likely cumulative effects from all weed treatments in northern New Mexico, together with other ecosystem restoration, travel management, and road closing and decommissioning projects, would promote the occurrence of native plants and subsequent soil stability, which would reduce sedimentation and improve aquatic conditions.
Effects of Forest Plan Amendment to Fish and Aquatic Resources Proposed amendments to the Santa Fe National Forest Plan allow weed treatment with herbicides in currently restricted areas (municipal watersheds) and on soils with a low revegetation potential. The amendment would result in no long term effects to fish and aquatic resources when future management projects are implemented using the new standard. The effects of future projects in watersheds and on soils with a low revegetation potential would be the same as those described in this section, with the resultant effect being increased native vegetation that is beneficial to aquatic species. Treatments in these areas would be subject to the design features and adaptive strategy which are designed to minimize impacts to wildlife and its habitat. Water Resources Affected Environment [No changes to the final environmental impact statement except as written in this section] Watershed Characteristics [Figure S-4 replaces figure 8]
104 Final Supplemental Environmental Impact Statement
Figure S-4. Locations of weeds in valley bottoms and riparian areas on the Carson and Santa Fe National Forests, August 1, 2013
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[Table S-48 replaces table 31]
Table S-48. Watersheds on, or intersecting, the forests and the acreage of weeds on National Forest System lands Acres of Fourth-level Basin Fifth-level Watershed Total Acres NFS Acres Weeds Canadian Headwaters Vermejo River 204,432 2,380 0 Headwaters Outlet Vermejo River 150,409 46 0 Cimarron Ponil Creek 208,056 58,979 1,464 Eagle Nest Lake - Cimarron 213,810 1,901 <1 Creek Mora Upper Mora River 205,457 38,147 247 Coyote Creek 158,845 6,882 <1 Sapello River 187,617 27,179 3 Alamosa-Trinchera Punche Arroyo – Rio Grande 161,508 2,362 0 Conejos Rio de los Piños 98,967 58,003 0 Rio San Antonio 140,335 62,657 45 Upper Rio Grande Costilla Creek 248,591 39,874 51 Latir Creek – Rio Grande 182,066 6,779 4 Red River 121,273 99,927 95 Red River – Rio Grande 144,250 6,640 1 Rio Chama – Rio Grande 177,911 38,093 6 Rio Grande del Rancho 94,207 83,058 180 Embudo Creek 205,050 147,305 75 Arroyo Aguaje de la Petaca 158,474 92,115 49 Santa Cruz River 116, 772 69,564 71 Pojoaque Creek 123,993 44,459 139 Rio Pueblo de Taos 174,567 37,663 <1 Rio Pueblo de Taos – Rio 205,386 52,002 15 Grande Rio Tesuque – Rio Grande 128,713 24,099 2 Rio Chama Chavez Creek 107,978 13,722 0 Chavez Creek-Rio Chama 145,309 674 0 El Vado Reservoir 177,883 201 0 Rio Nutrias-Rio Chama 152,301 45,229 44 Rio Cebolla 85,324 33,117 1 Rio Puerco 130,217 94,768 2,090 Arroyo Seco 103,523 82,386 0 El Rito 86,443 68,119 401 El Rito–Rio Chama 103,940 61,554 32 Rio Tusas 126,520 115,725 9 Rio Vallecitos 121,766 96,884 0 Rio Ojo Caliente 119,698 49,013 1 Rio Ojo Caliente-Rio Chama 88,597 53,492 99 Outlet Conejos River 166,122 568 0 Abiquiu Reservoir 168,403 128,630 1,632
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Acres of Fourth-level Basin Fifth-level Watershed Total Acres NFS Acres Weeds Rio Gallina 179,293 131,378 1,711 Rio Grande-Santa Headwaters Galisteo Creek 222,374 35,934 253 Fe Arroyo Tonque-Rio Grande 248,839 33,824 11 Outlet Galisteo Creek 206,318 515 2 Santa Fe River 163,876 32,808 37 Canada Ancha-Rio Grande 231,745 92,589 258 Jemez Upper Jemez River 128,582 35,007 858 Middle Jemez River 83,704 48,764 340 Rio Guadalupe 171,203 163,627 843 Rio Salado 158,058 2,465 0 Lower Jemez River 123,263 1,083 0 Rio Puerco La Canada de la Lena-Rio 112,114 5,411 22 Puerco Arroyo San Jose-Rio Puerco 164,268 54,945 336 Pecos Headwaters Cow Creek-Pecos River 222,190 167,941 406 Cow Creek 81,534 61,663 255 Tecolote Creek 181,571 41,817 78 Tecolote Creek-Pecos River 153,500 38,792 1 Headwaters Canon Blanco 107,249 22,700 243 Headwaters Gallinas River 200,949 30,887 4 Outlet Canon Blanco 165,401 20,372 0 Upper San Juan Canon Bancos 79,497 49,700 345 La Jara Creek 185,048 50,919 287 Navajo Reservoir 128,049 6,386 58 San Juan River – Navajo 67,873 13,073 112 Reservoir Blanco Canyon Tapicito Creek 117,542 4,922 < 1 Carrizo Creek 203,192 31,077 44 Canada Larga 189,991 7,928 0
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[Table S-49 replaces table 32]
Table S-49. Characteristics of representative watersheds Stream Name HUC 4 Basin Name USGS Gaging USGS Gaging Q 20 Flow (HUC code) Station Number USGS Gaging Station Name Station Status May/Sept. (cfs) Carson National Forest Red River Upper Rio Grande Basin 08266820 Red River below Fish Hatchery, near active 254/77 (13020101) Questa, NM Rio Hondo Upper Rio Grande Basin 08268700 Rio Grande near Arroyo Hondo, NM discontinued (2004) 1471/293 (13020101) Rio Grande del Upper Rio Grande Basin 08276000 Rio Pueblo de Taos at Los Cordovas, NM discontinued (1965) 373/23 Rancho (13020101) Canjilon Creek Rio Chama Basin 08287000 Rio Chama below Abiquiu Dam, NM active 106/5 (13020102) Rio Tusas/Rio Rio Chama Basin 08289000 Rio Ojo Caliente at La Madera, NM active 6613/1072 Vallecitos (13020102) Ponil Creek Cimarron Basin 07207500 Ponil Creek near Cimarron, NM active active (11080002) Santa Fe National Forest Santa Cruz River Upper Rio Grande Basin 08291500 Santa Cruz River at Riverside, NM discontinued (1951) 1679/554 (13020101) Pojoaque River Upper Rio Grande Basin 08313000 Rio Grande at Otowi Bridge, NM active 571/16 (13020101) Upper Jemez Jemez Basin (13020202) 08321500 Jemez River below East Fork near Jemez discontinued (1990) 115/24 River Springs, NM Pecos River Pecos Headwaters Basin 08378500 Pecos River near Pecos, NM active 512/96 (13060001) Upper Gallinas Pecos Headwaters Basin 08382000 Gallinas River near Lourdes, NM active 24/9 River (13060001)
108 Final Supplemental Environmental Impact Statement
There are approximately 1,713 miles of perennial streams on the Carson and Santa Fe National Forests.
Surface and Groundwater Quality Surface water quality is generally good on the two national forests. Land management activities typically affect the amount of sediment and water most often. Activities that disturb vegetation or the soil surface have the greatest potential to produce sediment by increasing soil erosion. Sediment in streams and rivers varies naturally, with higher loads usually observed during spring runoff and summer storms.
Uses of water on the two national forests include coldwater fisheries, livestock and wildlife watering, recreation, domestic uses, and irrigation. Common sources of sediment to streams are livestock grazing, off- road-vehicle use, and poorly located or maintained roads (USDA Forest Service 1986a).
Several stream or river segments within and near the national forests are on the 2014 to 2016 State of New Mexico’s Clean Water Act8 303(d) and 305(b) List of Impaired Waters (NMED 2014). The entire report can be found at New Mexico’s Environmental Department website. The report lists the probable causes of impairment (such as turbidity, stream bottom deposits, or temperature) as well as the probable sources of these impairments (for example, grazing, streambank modification, or removal of riparian vegetation). The impaired waterbodies in the representative watersheds are shown in Table S-50.
Table S-50. Impaired waterbodies in representative watersheds 2012-2014 Impaired Stream Name and Segment Designated Assessment Unit Length Use Not Probable Cause of ID (miles) Supported Impairment Probable Source(s) of Impairment Carson National Forest Red River (Placer 5.63 High quality Nutrient/eutrophication Source unknown Creek to coldwater biological indicators headwaters) aquatic life NM-2120.A_710 Rio Hondo (Rio 8.5 High quality Temperature, water Highway/road/bridge runoff (non- Grande to USFS coldwater construction related), rangeland boundary aquatic life grazing, streambank NM-2120.A_600 modifications/destabilization Rio Grande del 11.5 High quality Nutrient/eutrophication Flow alterations from water diversions. Rancho (Rio coldwater biological indicators, habitat modification - other than Pueblo de Taos to aquatic life specific conductance, hydromodification, highways, roads, Hwy 518) temperature, water bridges infrastructure (new NM-2120.A_501 construction), natural sources, source unknown, streambank modifications/destabilization Canjilon Creek 30.63 High quality Nutrient/eutrophication Agriculture, drought-related impacts, (Perennial portions coldwater biological indicators, flow alterations from water diversions, Abiquiu Reservoir aquatic life specific conductance, highway/road/bridge runoff (non- to headwaters) temperature, water, construction related), livestock (grazing NM-2116.A_030 turbidity or feeding operations), loss of riparian habitat, on-site treatment systems (septic systems and similar decentralized systems), source unknown, streambank modifications /destabilization, wildlife other than waterfowl.
8 Federal Water Pollution Control Act of 1948 as amended (that is, the Clean Water Act). 109 Invasive Plant Control Project
Impaired Stream Name and Segment Designated Assessment Unit Length Use Not Probable Cause of ID (miles) Supported Impairment Probable Source(s) of Impairment Rio Nutrias (Rio 34.63 High quality Turbidity Crop production (crop land or dry land), Chama to coldwater loss of riparian habitat, headwaters) aquatic life highway/road/bridge runoff (non- NM-2116.A_060 construction related), livestock (grazing or feeding operations), loss of riparian habitat, rangeland grazing, streambank modifications/destabilization. Rio Tusas (Rio 42.9 Coldwater Nutrient/eutrophication Crop production (crop land or dry land), Vallecitos to aquatic life biological indicators highways, roads, bridges infrastructure headwaters) (new construction), impervious NM-2113.A_30 surface/parking lot runoff, livestock (grazing or feeding operations), on-site treatment systems (septic systems and similar decentralized systems), rangeland grazing, wastes from pets, wildlife, other than waterfowl. Rio Vallecitos (Rio 36.31 High quality Aluminum, Channelization, highway/road/bridge Tusas to coldwater temperature, water, runoff (non-construction related), headwaters) aquatic life turbidity irrigated crop production, loss of NM-2112.A_00 riparian habitat, natural sources, other recreation pollution sources, rangeland grazing, streambank modifications/destabilization, surface mining. North Ponil Creek 14.78 High quality E. coli, Forest roads (road construction and (South Ponil Creek coldwater nutrient/eutrophication use), habitat modification - other than to Seally Canyon) aquatic life, biological indicators, hydromodification, low water crossing, NM-2306.A_110 primary temperature, water, rangeland grazing, silviculture contact turbidity harvesting. North Ponil Creek 7.03 High quality Aluminum, gross alpha Habitat modification - other than (Seally Canyon to coldwater - adjusted, Radium hydromodification, low water crossing, headwaters) aquatic life, 226, Radium 228, natural sources, rangeland grazing, NM-2306.A_162 domestic temperature, water, source unknown, watershed runoff water supply turbidity following forest fire, wildlife other than waterfowl. Middle Ponil Creek 10 High quality Benthic Loss of riparian habitat (South Ponil to coldwater macroinvertebrate Greenwood aquatic life bioassessments Canyon) (stream), temperature, NM-2306.A_121 water Middle Ponil Creek 11 High quality Nutrient/eutrophication On-site treatment systems (septic (Greenwood coldwater biological indicators systems and similar decentralized Canyon to aquatic life systems), rangeland grazing, source headwaters) unknown, watershed runoff following NM-2306.A_124 forest fire, wildlife other than waterfowl Greenwood 5.24 High quality Aluminum Natural sources, source unknown Canyon (Middle coldwater Ponil Creek to aquatic life headwaters) NM-2306.A_22 McCrystal Creek 6.81 High quality Temperature, water, Loss of riparian habitat, source (North Ponil Creek coldwater turbidity unknown to headwaters) aquatic life NM-2306.A_112
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Impaired Stream Name and Segment Designated Assessment Unit Length Use Not Probable Cause of ID (miles) Supported Impairment Probable Source(s) of Impairment Santa Fe National Forest Santa Cruz River 8.1 Marginal E. coli, temperature, Source unknown (Santa Clara coldwater water Pueblo boundary aquatic life, to Santa Cruz primary Dam) contact NM-2111_50 Pojoaque River 0.6 Marginal polychlorinated Source unknown (San Ildefonso coldwater biphenyls boundary to aquatic life, Pojoaque warmwater boundary) aquatic life NM-2111_20 East Fork Jemez 10.39 High quality Aluminum, arsenic, Highway/road/bridge runoff (non- River (San Antonio coldwater temperature, water construction related), natural sources, Creek to VCNP aquatic life other recreational pollution sources boundary) NM-2106.A_13 Redondo Creek 0.73 High quality Turbidity Highway/road/bridge runoff (non- (Sulphur Creek to coldwater construction related), loss of riparian VCNP boundary) aquatic life habitat, rangeland grazing NM-2106.A_25 San Antonio Creek 11.28 Domestic Aluminum, arsenic, Forest roads (road construction and (East Fork Jemez water supply, temperature, water, use), loss of riparian habitat, natural to VCNP high quality turbidity sources, other recreational pollution boundary) coldwater sources, rangeland grazing, site NM-2106.A_20 aquatic life clearance (land development or redevelopment), streambank modifications/destabilization Rio Puerco de 8.81 Coldwater Aluminum, E. coli, Channelization, highway/road/bridge Chama (Abiquiu aquatic life, nutrient/eutrophication runoff (non-construction related), Reservoir to Hwy primary biological indicators, impervious surface/parking lot runoff, 96) contact, temperature, water loss of riparian habitat, on-site NM-2115_20 warmwater treatment systems (septic systems and aquatic Life similar decentralized systems), rangeland grazing Poleo Creek (Rio 12.16 High quality Turbidity Forest roads (construction and use), Puerco de Chama coldwater loss of riparian habitat, natural sources, to headwaters) aquatic life rangeland grazing, streambank NM-2116.A_023 modifications/ destabilization Rito Resumidero 2.75 High quality Benthic Source unknown (Rio Puerco de coldwater macroinvertebrate Chama to aquatic life bioassessments headwaters) (stream) NM-2116.A_025 Polvadera Creek 13.94 High quality Sedimentation or Loss of riparian habitat, natural (Canones Creek to coldwater siltation, temperature, sources, off-road vehicles, rangeland headwaters) aquatic life water grazing NM-2116.A_011 Willow Creek 5.26 High quality Sedimentation or Source unknown (Pecos River to coldwater siltation, specific headwaters) aquatic life conductance NM-2114.A_030
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On December 15, 2010, the New Mexico Water Quality Control Commission issued an order and statement of reasons (effective January 14, 2011) designating outstanding national resource waters. This designation applies to all streams and their tributaries and wetlands originating in wilderness areas administered by the U.S. Forest Service in the State of New Mexico. A list and maps of designated stream segments and wetlands can be found at the New Mexico Environment Department website.
Groundwater on the Carson and Santa Fe National Forests is widely variable and often associated with riparian areas and wetlands. Depths to groundwater can vary from shallow to several hundred feet or more depending on topography and geology. Typically, the mountainous terrain in the two national forests provides areas of groundwater recharge. Shallow groundwater resources, such as those associated with wetlands and places adjacent to streams and riparian areas, are stored in saturated soils and deeper sediments and supplement surface waterbodies through discharge of groundwater during periods of low flow. Other groundwater resources, such as springs and seeps, are important sources of water for wildlife and habitat for groundwater-dependent species. Sources of potential contamination of groundwater are varied but commonly include fuels, oils, solvents, paints, and detergents, and the generation of solid and liquid wastes. Typical sources of contamination on National Forest System lands include mines, oil and gas wells, landfills, and septic systems and associated leach fields.
Drinking water wells in the two national forests range in depth from 55 feet to 150 feet or more. Yield of groundwater from these formations usually is low (less than 25 gallons per minute) (USDA Forest Service 1986a). In contrast, most valley bottoms have shallow groundwater in alluvial deposits. This groundwater is most likely closest to ground surface in May and June, declining through the summer as streams approach low flow conditions.
Groundwater quality on the forests is variable but generally thought to be high due to the remoteness of the resource to large sources of contamination, such as those described above. Groundwater quality near areas of urban development, mining activities, and oil and gas development is most likely to demonstrate a lower quality than areas far removed from these potential sources of contamination.
Analysis Methods [No change from the final environmental impact statement]
Environmental Consequences to Water Resources [Additional summary section]
Summary of Effects to Surface Water Quality For any action alternative, a slight increase in sedimentation following treatment is expected when compared to alternative A. An increase in sedimentation means that surface water quality could decrease (for example, more turbidity). The no-action alternative would keep sedimentation at background levels initially, but as invasive species continue to spread in extent and displace native vegetation, water quality could be expected to decline. In the first 1 to 3 years, alternative C would probably produce the most sediment of the action alternatives because without the option of herbicides, most treatments would be ground-disturbing and would need to be repeated to control invasive species populations. After 3 years, the restoration of native plant communities and the revegetation of bare soil caused by these ground-disturbing treatments is likely to reduce the amount of sediment produced, with an overall improvement to surface water quality.
Summary of Effects to Groundwater Quality For any action alternative, a slight risk of effects to groundwater quality exists, but this risk correlates to the amount of herbicide use when compared to alternative A. An increase in acres treated by herbicide application poses a slight risk of groundwater effects from application near shallow groundwater tables (riparian areas
112 Final Supplemental Environmental Impact Statement
and wetlands) or accidental spills of herbicide. The no-action alternative would eliminate this risk as no weed treatments of any kind would occur. Compared to the other action alternatives, alternative C would also minimize or eliminate the potential for groundwater impacts because without the option of herbicides, most treatments would be mechanical or cultural in nature. Alternative B, which allows herbicide use with other specified treatment methods, may pose a slight risk of groundwater impacts, but design features would control and reduce this potential risk to groundwater resources.
Summary of Effects to Outstanding National Resource Waters from All Alternatives The designation of a waterbody as an outstanding national resource water (ONRW) comes with an antidegradation policy (20.6.4.8 NMAC). The antidegradation policy requires the following:
That “water quality be maintained and protected in ONRWs” and the policy is interpreted to mean “no new or increased discharges to ONRWs and tributaries to ONRWs would result in lower water quality in the ONRW.” The policy states “temporary and short-term degradation resulting from nonpoint source discharges shall last no longer than the activity that causes the degradation and shall in no event last longer than six months.”
Under the no-action alternative, there would be no effects from this project to outstanding national resource water because no weed treatments would take place. There would be no nonpoint discharges from weed control projects.
Under all action alternatives, the risk of impacts to surface waterbodies and wetlands designated as outstanding national resource waters is low and would comply with the requirements of the antidegradation policy, meaning that impacts would be temporary and short term. With the design features requiring not using certain herbicides near water and of revegetating denuded areas, no new or increased discharges to outstanding national resource waters and tributaries are expected. Because the effects of herbicides last only several days, the expected effect to outstanding national resource waters from herbicide treatment would comply with the timeframe (less than 6 months) outlined in the antidegradation policy. Vegetation in riparian areas tends to grow back within a season, eliminating the risk of an increased discharge to an outstanding national resource water stream. Finally, the location of the current weed populations in wilderness areas is such that the effects of any treatments are unlikely to reach streams.
Alternative A [No change from the final environmental impact statement]
Alternatives B and D [No change from the final environmental impact statement]
Alternative C [No change from the final environmental impact statement]
Cumulative Effects to Water Resources Under the no-action alternative, there would be no direct or indirect effects from weed treatments; therefore, there would be no cumulative effects to surface water quality, groundwater quality, or outstanding national resource waters. The effect of not treating weeds is that weeds would continue to spread. This would increase the loss of desirable plant species and biological diversity, which in turn would likely cause increased surface water runoff, soil erosion, and sedimentation in watersheds with weeds and, in the long term, in watersheds currently not affected by invasive species populations. Without some type of control of current populations, it is likely invasive populations will expand via pathways (such as roads and trails) used by Carson and Santa Fe National Forest personnel and visitors. New populations are likely to establish and expand via other means
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such, as seed dispersal by wildlife and cattle. It is plausible that, by 2025, extensive herbicide treatment (for example, aerial application) could be required to gain control of weed populations that are rapidly spreading and increasing in size.
The direct and indirect effects to surface water quality from the action alternatives are likely to be a minor increase in soil erosion and subsequent sediment transport to surface waterbodies from ground disturbances during project implementation. Most ongoing and foreseeable future activities on the two national forests (see Table S-14 and Table S-15) would continue to contribute to erosion and sediment, including vegetation and fuel management projects; road maintenance, reconstruction, closing, and decommissioning; prescribed burning and wildland fires, livestock grazing, and all recreational uses. The amount of sedimentation caused by weed treatments is expected to be so minor as to be too small to measure; thus, when added to other cumulative actions, none of the action alternatives are expected to contribute cumulatively to sedimentation enough to change surface water quality (for example, cause a listing of impaired waters). Herbicide use by adjacent landowners and agencies would cumulatively result in minor and short-term herbicide loading to the environment. Those additional acres would cumulatively add a small amount but would be unlikely to exceed Environmental Protection Agency standards.
The direct and indirect effect to groundwater quality from the action alternatives is minor or too small to measure. Other than effects of accidental spills of herbicide, the effects to groundwater from treatment of invasive species through mechanical or other cultural practices are unlikely. Herbicide use by adjacent landowners and agencies may cumulatively result in minor and short-term herbicide loading to groundwater resources, but design features for the Forest Service’s use of herbicides would control and reduce this potential risk to groundwater resources. Those additional effects could cumulatively result in a perceptible effect but would be unlikely to exceed Environmental Protection Agency standards.
No measurable direct or indirect effects from the action alternatives to outstanding national resource waters would occur; therefore, there would be no cumulative effects.
Implementation of any action alternative would combine with other stream and watershed restoration activities that could move nonattainment streams toward attainment status.
Effects of Forest Plan Amendment to Surface and Groundwater Quality The proposed amendment would help achieve desired conditions described in the forest plan for soil, water, and riparian conditions that would otherwise be threatened by the continued spread of weeds. Allowing herbicide applications within municipal watersheds, on national forest land adjacent to homes, and on soils within certain tolerances expands the opportunity to control weeds in the future. Because the amendment includes a mitigation measure that requires sufficient ground cover to ensure that soil erosion does not exceed the tolerance level for that soil type based on the Terrestrial Ecosystem Survey for the Santa Fe National Forest (USDA Forest Service 1993), long-term soil productivity would be maintained in all future projects where herbicides would be applied.
The proposed forest plan amendment would allow the use of herbicides (excluding picloram) in the Santa Fe and Gallinas municipal watersheds provided Santa Fe and Las Vegas city officials concur with the proposed treatment prescription and design features to be implemented. This stipulation could increase or decrease the amount of herbicide applications allowed in the future, depending on the personnel making decisions at the time. Allowing herbicides, as described throughout this chapter, is expected to increase the presence of native vegetation and thus is likely to improve water quality. Not allowing the use of herbicides is expected to have the opposite effect in this and future projects.
Other entities, including environmental organizations, have applied herbicides in the lower portions of these watersheds outside the national forest boundary. Allowing the use of herbicides in the watersheds would
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render treatments adjacent to the Santa Fe National Forest more effective in the future because weeds would be less likely to spread from the portion of the watershed on forest land to the lower watershed sections. Permitting the use of herbicides would improve the effectiveness of eradicating or controlling the spread of saltcedar, Siberian elm, Russian olive, and other weed species in the municipal watersheds and would contribute to improving water quality in the long term, and possibly even water quantity because of these species high water use. Soil [Replaces entire section; Figure S-5 replaces figure 10 and Figure S-6 replaces figure 11]
Methodology A review of scientific literature provided the basis for the effects to soils from the use of herbicides.
Affected Environment Soil landscapes on the Carson and Santa Fe National Forests can be subdivided into three provinces with distinct soil assemblages: Colorado Plateau Semi-Desert, Southern Rocky Mountain Steppe, and Southwest Plateau Provinces (Bailey 1995). The Rocky Mountain Steppe assemblage dominates the north-central region of New Mexico, the Colorado Plateau dominates the southern and western areas, and the Southwest Plateau occurs primarily in the Pecos-Canadian Plains and Valleys in the eastern part of the state. Specific soils associated with each assemblage on the forests are described in detail in the specialist’s report.
How Weeds Can Affect Soil Weed infestations affect soil quality by outcompeting native species for water and nutrients (Olson 1999a). Broadleaf weeds often produce deeper taproot systems and less canopy cover compared to the native species that they displace (DiTomaso 1999). Due to these physiologic and morphologic differences, weed infestations can cause negative changes in overall soil quality. The weed species that occur on the two national forests, where dense, are assumed to be causing these effects. Organic matter may be reduced or redistributed in weed-infested soil. Weeds may decay more slowly than native species (Olson 1999a; Olson and Kelsey 1997). Slower decay rates result in less annual input of organic matter to the soil. Since weeds also tend to have deeper roots and less foliage than native species, decay of these plants will contribute less litter and organic matter near the soil surface.
Infiltration can be reduced on weed infested sites due to reduced cover (DiTomaso 1999; Olson 1999a). Lacey et al. (1989) measured significantly greater surface water runoff, indicating less infiltration, from spotted knapweed dominated sites compared to adjacent native grass dominated sites. Decreased soil organic matter can reduce the amount of water held in the soil, especially near the surface (Brady and Weil 1999; Tisdall and Oades 1982).
Reduced cover - On weed-infested sites, reduced vegetative cover can result in higher evaporation from the exposed soil surface (Lauenroth et al. 1994, Olson 1999a). On sites where weeds are dense, the high transpiration rate may deplete water stored deeper in the soil (Olson 1999a).
Erodibility – Weed-infested soil has been shown to be more erodible than soil supporting native grass species (Lacey et al. 1989). With less cover than native species, weeds are less able to dissipate the kinetic energy of rainfall, overland flow, and wind that cause erosion (Torri and Borselli 2000; Fryrear 2000).
Biota - Since abundance of soil microbial biomass is generally related to the organic matter content of soils (Brady and Weil 1999), it is possible that weed-infested soils may support smaller populations of microorganisms than noninfested soils. Considering the deeper root distribution and reduced litter production
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of weeds compared to native grasses, it is possible weeds could result in a change of size or distribution of soil microbial populations.
Weeds directly limit nutrient availability through their ability to outcompete native species for limited resources. Weeds have high nutrient uptake rates and can deplete soil nutrients to very low levels (Olson 1999a). Potassium, nitrogen, and phosphorous levels were 44 percent, 62 percent, and 88 percent lower in spotted knapweed infested soil than in adjacent grass covered soil (Olson 1999a). In addition, some weed species germinate prior to native species and take up nutrients and water before native species are actively growing (Olson 1999a). In instances where weed decomposition occurs slowly, nutrients remain immobilized in the plant tissue and are unavailable for uptake by other species. Weeds indirectly limit nutrient availability due to increased soil erosion that can occur in infested areas. Erosion selectively removes organic matter and the finer sized soil particles that store nutrients for plant use, leaving behind soil with a reduced capacity to supply nutrients (Brady and Weil 1999).
The Forest Service, through surveys, has characterized the properties of soils on the two national forests. These are described in the 1993 terrestrial ecosystem surveys. Two interpretations, erosion hazard and revegetation potential, are pertinent to this project. The erosion hazard (Figure S-5) describes the susceptibility of the soil to erosion upon removal of vegetation and litter. Revegetation potential (Figure S-6) refers to the probable success and ease of native grass establishment. Revegetation potential is influenced by climate, soil characteristics, and slope. The following tables show the how much of the project area is in each category.
Table S-51. Weed acres by erosion hazard class Erosion Hazard Class Total Acres Acres of Weeds Percent Interpretation not available 645,091 1,134 0.2 Slight 536,798 1,568 0.3 Moderate 2,427,040 6,218 0.3 Severe 1,613,463 4,329 0.3
Table S-52. Weed acres by revegetation potential class Revegetation Potential Class Total Acres Acres of Weeds Percent Interpretation not available 18,199 6 0.03 High 2,506,454 4,900 0.2 Moderate 1,254,155 4,967 0.4 Low 1,443,585 3,376 0.2
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Figure S-5. Areas of slight, moderate, and severe erosion hazard on the Carson and Santa Fe National Forests
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Figure S-6. Areas of revegetation potential (ranging from poor to high) on the Carson and Santa Fe National Forests
118 Final Supplemental Environmental Impact Statement
Environmental Consequences to Soil Alternative A–No Action Without action, weeds would continue to spread at the assumed average rate of 8 percent per year. Dense weed infestations are likely to result in the negative impacts just described in the “Affected Environment” section. Erosion might increase and revegetation potential might decrease at the specific locations where weeds exist and at other locations.
Effects of the Action Alternatives Treatment Methods on Soil In summary, soil disturbance from this proposal would not be considered detrimental when considered with the beneficial, long-term improvements in soil quality and productivity in areas where weeds are treated and native vegetative is reestablished. For all methods, the size and extent of soil disturbance would be limited to the area treated, which is a small percentage of the project area overall (0.05 percent, based on an average of 1,500 acres treated per year). The duration of the effect would be limited to the recovery period, which typically ranges from a few months to a year. The design features in chapter 2 (Table S-11, row 19) and the proposed plan amendment ensure that erosion rates would not exceed tolerance levels established in the forest plans. Finally, most of the known weed populations are near roads, campsites, trails, and other locations that already have an existing level of soil disturbance. Overall, any treatment method would improve soil quality by controlling weeds and minimizing the negative effects of weeds described in the “Affected Environment” section.
The following paragraphs describe the effects the methods proposed are expected to have on soils.
• Mechanical methods, where heavy equipment removes or plows up weeds, are the actions most likely to leave bare soil or cause soil compaction following treatments. The design features that prohibit the use of heavy equipment such as mowers or mechanized diggers on slopes over 40 percent would reduce the potential for erosion. Methods that do not use herbicides are likely to require follow-up treatments, resulting in the potential for more ground disturbance than would occur from the use of herbicides. • Manual methods, such as incidental hand pulling and grubbing of weeds, would result in minor soil disturbance where weeds are pulled. The size of the disturbed area would be negligible when considered against the size of the project area. Any disturbed soil would be outweighed by the benefit of removing the weeds. • High-intensity, short-duration grazing can cause soil compaction that is proportional to the intensity and duration of grazing. The degree of compaction is not expected to reduce soil productivity because monitoring would control the amount of time herbivores would remain on a site. • Prescribed fire would result in little bare soil. Its use is governed by strict parameters designed to keep litter, duff, and some vegetation in place. • Biological methods, for example the release of insects, are expected to result in no ground disturbance because the biological agents attack the plant and leave the soil intact. These herbivorous insects have a high degree of host specificity and would not be expected to target beneficial, native vegetation. Biological control agents would provide the benefit of weed control without the potential for changes to soil biota communities. Table S-53 shows the characteristics of herbicides proposed for use in the project area as they pertain to their behavior in soil. Half-lives for these herbicides range from days for up to a year. A half-life is the time it takes for a pesticide to be reduced by one-half. It is a measures of how long an herbicide is expected to remain present in the soil. In general, less than 3 percent of the original amount of pesticide would remain in a soil after five half-lives have passed.
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Of the methods proposed, herbicides have the most potential to affect soil quality, but the science is inconclusive. The complex interactions between soil biota, environment, and herbicide type make predictions of impacts to soil biota difficult. Certain herbicides, such as glyphosate and dicamba, have been observed to cause weight reductions or mortality in earthworms. Surviving earthworms would be expected to recover, but the population may be decreased after each herbicide application. Soils with reduced earthworm populations would exhibit reduced water infiltration, nutrient cycling, and fewer stable soil aggregates compared to similar soils with greater earthworm populations (Brady and Weil 1999). In areas where earthworms are susceptible to the type of herbicide applied, the population may remain suppressed until application ceases. A study of the effects of herbicides on soil arthropods found no significant change in the arthropod population occurred due to herbicide exposure (Fuhlendorf et al. 2001).
Some research indicates herbicides can decrease the diversity and relative biomass of individual species of soil microorganisms (Forlani et al. 1995, Ka et al. 1995, SERA 2003a). Other researchers, however, found herbicides had no effect on soil bacteria, nematodes, or collembola beyond what was expected from the associated reduction in ground cover (Wardle et al. 2001). While herbicide exposure may influence the diversity of soil microorganisms, the reported data indicate this influence is transient as long as adequate time is allowed for the soil community to rebound between exposures. Brady and Weil (1999) report negative effects of most pesticides on soil microorganisms are temporary, and populations generally recover after a few days or weeks.
Alternative B–Proposed Action Alternative B proposes the full suite of treatments, so all the effects described above are anticipated to occur. The maximum annual acreage expected to be treated in the project area is 3,000 acres (0.1 percent of the project area), with the acres widely distributed in space and treated at different times. As a result, the magnitude and intensity of any effect would be negligible.
For up to a year following treatments, erosion may increase and revegetation potential decrease at the specific locations where weeds are treated. These negative impacts would be offset by the long-term, beneficial effects of reestablishing native vegetation.
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Table S-53. Characteristics of herbicides in soil Herbicide Solubility (ppm) Potential For Mobility Half Life (Days) Aminopyralid 212 (pH 5) High 5 to 343 depending on soil 205 (pH 7) type Chlorsulfuron 300 (pH 5) High 30 to 120 7,000 (pH 7) (increases with pH) Clopyralid methyl 1,000 High 15 to 287 Dicamba 4,500 High 7 to 42 Glyphosate 12,000 to 900,000 Low 2 to 174 Hexazinone 33,000 High in soil, low in leaf 30 to 180 litter Imazapic 2,200 Moderate 31 to 233 (increases with pH) Imazapyr 11,272 Moderate to h igh Several months Metsulfuron methyl 1,750 (pH 5.4) High 14 to 80 9,500 (pH 7) (increases with pH) Picloram 430 High 20 to 300 (increases with pH) Sulfometuron methyl 0 (pH 5) Low 30 300 (pH 7) (increases with pH) 2,4-D 890 to 800,000 High 30 or less Triclopyr 23 to 2,1 00,000 Moderate 30 to 46
Alternative C–No Herbicides Because alternative C is not expected to be as successful at controlling weeds across Carson and Santa Fe National Forests as quickly as the other action alternatives, weed populations would continue to spread and impact soils. In those areas, adverse effects on soil properties and soil quality would be similar to those described under alternative A but on fewer acres.
Without the option of herbicides, alternative C would require more digging, mowing, prescribed burning, grazing, and other non-herbicide treatment methods. It would also require more follow-up treatments to effectively control weeds on the same sites. This means the opportunity for soil disturbance and subsequent soil erosion would be greater than in the other action alternatives but is still considered negligible when considered in the context of the entire project area. Follow-up treatments would extend the duration soils are vulnerable to erosion, and repeated treatments over time would likely maintain the vulnerability of these sites to weed infestations, thus lowering soil productivity. This alternative eliminates the impacts from herbicides on the microbial community and earthworm populations.
For up to a year following treatments, or possibly longer, erosion might increase and revegetation potential might decrease at the specific locations where weeds are treated. These negative impacts would be only partially offset by the long-term, beneficial effects of reestablishing native vegetation.
Alternative D–Only Herbicides Alternative D reduces the potential for erosion and compaction caused by all the methods except herbicides. Since the acreage would only be treated with herbicides, all the soils would be subjected to the effects of herbicides described above.
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For up to a year following treatments, erosion might increase and revegetation potential might decrease at the specific locations where weeds are treated. These negative impacts would be offset by the long-term, beneficial effects of reestablishing native vegetation.
Cumulative Effects to Soil Alternative A–No Action Forest activities that contribute to the introduction and spread of invasive weeds would add cumulatively to the impacts of alternative A. Failure to act to control weeds would add to the reduced soil quality caused by weeds and other activities that introduce and spread invasive weeds. Soil quality would degrade in proportion to the increase in weed spread. For several years, these additive effects would not cause a large-scale loss of soil productivity. Over time, as weed infestations continue to spread and become more dominant on the national forests, loss of soil productivity would become evident.
All Action Alternatives All activities and land uses on the forests contribute to soil disturbance and some degree of erosion; most serve as vectors with the potential to introduce and spread invasive weeds. The action alternatives initially would cumulatively add minor, short-term increases in erosion for a season or less. However, management activities under the control of the Forest Service would include measures to avoid rates of erosion that exceed forest plan standards and to maintain soil productivity. Therefore, the cumulative effects of weed treatments and other activities occurring on the Carson and Santa Fe National Forests are expected to be negligible.
In addition, most ongoing and foreseeable future activities have objectives aimed at enhancing and restoring ecosystem function and healthy water and soil conditions. Many recent projects have successfully improved soil productivity. These projects include closing and decommissioning forest roads, reducing camping and grazing in riparian areas, and reducing where motorized use may occur throughout the forests. These actions would have cumulatively beneficial effects and would combine with the long-term beneficial effects of the proposed weed treatment project to reduce soil erosion and sedimentation.
Cumulative impacts to soil quality also would occur from the herbicide loading in alternatives B and D when added to other public agencies and private landowners in the area conducting similar herbicide treatments. Cumulative effects would also occur to soil organisms from herbicide applications; however, these impacts are expected to be temporary and limited to the treatment sites. Cumulatively, treatments would not affect soil organisms located away from treatments (on forest or off). Beneficial cumulative effects would occur in treated areas as native vegetation becomes reestablished and soil qualities improve over the long-term.
Effects of Forest Plan Amendment to Soil The proposed Santa Fe National Forest Plan amendment would modify the soil resource standards and guidelines. It would allow the Santa Fe to use herbicides on soils with a low revegetation potential. Not using herbicides on these soils would be counterproductive to meeting the purpose and need, and soils would be adequately protected by applying the adaptive strategy (Table S-10) and design features (Table S-11) listed. With the design features and adaptive strategy applied to this and all future projects, no negative impacts to soil productivity or characteristics would be expected to last longer than 6 months. Herbicides such as picloram, which are persistent in soil and are more mobile, would not be used near water (see chapter 2.) By controlling or eradicating weeds in this and future projects, an overall beneficial impact to soils is predicted; restoring native vegetation on soils generally reduces erosion, thereby increasing productivity. The design features and adaptive strategy listed in Table S-10 and Table S-11 replace the cation exchange standard and provide more protection to soils. Thus, deleting this standard from the forest plan would not be expected to reduce soil productivity or change soil characteristics in this or future projects that apply herbicides to certain soils. There would be no impact to soil resources, and erosion rates would not exceed the tolerance level identified in the terrestrial ecosystem survey for the affected soil unit.
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Air Quality [Replaces entire section]
Affected Environment Introduction The project area contains both the Carson and Santa Fe National Forests and is located within four major airsheds as defined by the New Mexico Environment Department: the Upper Rio Grande, the Middle Rio Grande, the Canadian River, and the Pecos (NMED 2003). All airsheds in New Mexico are based on watershed boundaries developed by the New Mexico Water Quality Control Commission. These airsheds cover many counties; however, the project area lies mainly in Rio Arriba, Taos, Colfax, Sandoval, Los Alamos, Santa Fe, Mora, and San Miguel Counties. The project area includes significant population centers along the Rio Grande – Santa Fe, Taos, Los Alamos, and Espanola – and many pueblos and small communities.
There are four class 1 areas within the project area: Wheeler Peak, San Pedro Parks and the Pecos Wilderness, which are all managed by the Forest Service; and Bandelier National Monument, which is managed by the National Park Service. Class 1 areas are identified in the Clean Air Act as areas that require the highest level of protection for air quality related values, such as visibility, in addition to the national ambient air quality standards (NAAQS).
Southwesterly winds typically blow across the mountainous region of northern New Mexico. Temperatures vary from an average daily maximum of 86 degrees Fahrenheit in July in Jemez Springs to an average daily minimum of 3 degrees Fahrenheit in Dulce in January (data from Western Regional Climate Center).
Emissions Emissions affecting air quality can come from a variety of sources. Emissions are typically associated with either point sources, such as large industrial facilities or power generation, or area sources, such as emissions from vehicles or fugitive dust from agriculture. Emissions and dust from as far away as California and Asia or as nearby as the Four Corners region can contribute to reductions in visibility, deposition of pollutants, and impacts to ambient air quality. For the purpose of this assessment, only emissions from the counties that contain the project area and some of the surrounding counties were considered because potential effects of herbicide drift and smoke affecting air quality is not likely to go farther than the area described.
There are many offsite sources (facilities) capable of impacting air quality in the project area, such as power plants, oil and gas operations on the west side of the forests and Four Corners area, natural gas compressor stations and refineries in the San Juan Basin, mining operations in Taos, Santa Fe, and Rio Arriba Counties, biomass plants, and other sources such as foundries and landfills (Environmental Protection Agency national emissions inventory).
Regulatory Environment There are two primary regulatory considerations under the Clean Air Act for actions by the Forest Service: the national ambient air quality standards and the regional haze program. National ambient air quality standards include primary standards to protect public health and secondary standards that protect the environment. The aim is to set standards for the concentration of certain pollutants in the ambient air so they are below levels that would impact public health or the environment. The regional haze program requires states or the Federal government to develop plans that reduce emissions from all sources across a state, so visibility returns to natural conditions without the impact of human-caused sources by 2064.
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National Ambient Air Quality Standards New Mexico and the Federal government have established air quality standards for specific criteria air pollutants. The criteria pollutants are carbon monoxide, lead, sulfur dioxide, particulate matter smaller than 10 microns (PM10), particulate matter smaller than 2.5 microns (PM2.5), ozone, and nitrogen dioxide. Of the seven criteria pollutants, the pollutants of concern for this project are the particulate matter pollutants PM2.5 and PM10 from prescribed fire. Table S-54 shows the national and New Mexico air quality standards for PM2.5 and PM10. Primary and secondary national standards are the same and the New Mexico standards are the same as the national standards for the two pollutants.
Air quality in the project area is classified as being “in attainment” for all criteria pollutants. A “nonattainment” designation means that violations of standards have been documented in the region. There are no nonattainment areas within the project area. Typically, all areas within the project area have very good air quality, with measured values that fall below all Federal and State standards.
[Table S-54 replaces table 41]
Table S-54. National ambient air quality standards for criteria pollutants of concern. (New Mexico standards are the same as the national standards) Pollutant Averaging Time Primary and Secondary Standard 3 PM10 24-hour 150 µg/m 3 PM2.5 Annual (arithmetic mean) 12 µg/m 24-hour 35 µg/m3 a. Concentrations are expressed in units in which they were promulgated. µg/m3 = micrograms per cubic meter. Units shown as µg/m3 are based upon a reference temperature of 25oC and a reference pressure of 760 mm of mercury. b. Primary standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public health. c. Secondary standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
Figure S-7 through Figure S-9 summarize the range of PM2.5 and PM10 pollutants found in or near the project area from the State’s air quality monitoring data from 2010 through 2012. For both PM2.5 and PM10, the measured values in Santa Fe and Taos are significantly below the standards. Both represent monitored values much closer to a variety of urban emission sources (primarily vehicles) and it is assumed values on the national forest are typically less than what is measured at either of these monitoring sites.
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Figure S-7. PM10 24-hr maximum values in Taos and Santa Fe with 3-year moving average (micrograms per cubic meter)
Figure S-8. PM2.5 24-hr values for 98th percentile weather conditions in Taos and Santa Fe with 3-year moving average (micrograms per cubic meter)
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Figure S-9. PM2.5 annual mean values in Taos and Santa Fe with 3-year moving average (micrograms per cubic meter)
Regional Haze–Visibility Visibility is the condition that allows people to see and appreciate the inherent beauty of the landscape features. It can be greatly impacted by particulate matter and gases that are in smoke or dust (Malm 2000). Visibility and other air quality standards are most stringent within designated class 1 areas. Thus, most monitoring for visibility is conducted in class 1 areas, which for this project are San Pedro Parks Wilderness and Bandelier National Monument. The results of this monitoring and projections for visibility in the future are shown in the next two figures.
The Regional Haze Rule sets a goal to return class 1 areas to natural visibility conditions by 2064. As of 2010, both class 1 areas were slightly ahead of schedule, but further improvements will be needed to meet the national visibility goal. In 2011, visibility was impacted at both monitoring locations as a result of smoke from the Las Conchas and Wallow Fires (Figure S-10 and Figure S-11).
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Figure S-10. Visibility conditions on worst 20 percent visibility days for San Pedro Parks Wilderness and glide path to 2064 goal
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Figure S-11. Visibility conditions on worst 20 percent visibility days for Bandelier National Park and glide path to 2064 goal
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Environmental Consequences to Air Quality None of the methods for treating weeds would result in emissions great enough to have a significant impact on human health or visibility. Weed treatments would be widely distributed across both national forests over time. Mandatory design features for protecting human health would continue to apply to herbicide application in municipal watersheds or in areas of human habitation and with prescribed fire. Neither human health nor visibility would be affected by project activities.
Methodology The mandatory design features for herbicide application and the scale of herbicide application and prescribed burns being proposed are such that both fall well below any limits for concern and meaningful quantification. Therefore only a qualitative discussion follows.
Alternative A–No Action Under the no-action alternative, there would be no impacts to air quality because the project would not occur. Because there would be no direct or indirect effects, there would be no cumulative effects.
Alternative B–Proposed Action Though alternative B would cause emissions, the amount would not be great enough to impact human health or visibility. In summary, since weed treatments would be widely distributed across both forests over time, human health and visibility would not be affected by project activities.
Gaseous emissions would originate from combustion of fuel in vehicles used to transport workers to and from treatment sites, vehicle mounted spray units applying herbicides, and from heavy equipment doing mechanical treatments such as mowing. The amount of gaseous exhaust emissions depends on size, age, and fuel efficiency of the engines; however, this is considered insignificant at this scale.
Vehicle traffic on forest roads would generate road dust. Dust caused by traveling to and from treatment areas would settle, typically within a few minutes, leaving no lasting impact. Spraying herbicides from a vehicle would produce little road dust because the speed would be slow. Similarly, dust from annual road-side mowing or root plowing would be minimal due to slow vehicle speeds and the low frequency of treatments (annually).
During herbicide applications, spray drift is expected to be contained near the application site, due to limitations restricting application under wind conditions that could result in drift. In addition, drift will be limited because the slow vehicle speed and low height of the spray boom would resulting in the herbicide depositing on the ground within a few feet of the target weed population.
Smoke from prescribed burning would release particulate matter (PM10 and PM2.5) emissions. All prescribed burning used to treat weeds would comply with the New Mexico smoke management program requirement. The New Mexico Smoke Management Program is designed to prevent conditions adverse to human health and to protect visibility. Only a relatively small amount of acres per year would be treated by prescribed fire (approximately 100 acres per year maximum) to control for weeds. The vegetation being burned have a low fuel loading for the most part. In this case, a large amount of emissions is not expected and would fall well below standards.
Alternative C–No Herbicides Alternative C would potentially create more dust because of more mowing and root plowing and more particulate emissions from prescribed burning than would occur under alternatives B or D. This would result in a slight increase in PM10 and PM2.5 from dust and smoke. Otherwise, effects would be similar to alternative B. Because estimated emissions are low and these emissions would be distributed across the national forests
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and over time, concentrations of pollutants would not affect air quality standards. Human health and visibility would not be affected by project activities.
Alternative D–Herbicides Only Impacts on air resources from alternative D would be similar to those under alternative B, except less dust would be created because there would be no mowing, root plowing, or other treatments with potential to produce dust and there would be no smoke emissions from prescribed burning. Because estimated emissions are low and these emissions would be distributed across the forests and over time, concentrations of pollutants would not affect air quality standards. Human health and visibility would not be affected by project activities.
Cumulative Effects The spatial boundary for the analysis of cumulative effects on air quality is contained within the following four airsheds as defined by New Mexico Environment Department (NMED): the Upper Rio Grande, the Middle Rio Grande, the Canadian River, and the Pecos airsheds (NMED 2003). Airsheds are similar to watersheds in that they are defined geographic areas that, because of topography, meteorology, or climate, they are frequently affected by the same air mass. The difference with airsheds is that air masses and air pollutants move between airsheds mostly based upon larger meteorological patterns, rather than primarily by topography, as with water flowing through a watershed. However, for the purpose of this assessment, the area is contained to the counties identified earlier in this section for the same reason given.
Current conditions for ambient air quality and visibility are good in the four airsheds that contain the project area. In terms of air quality impacts, neither human health nor visibility is expected to be impacted by project activities, and therefore there would be no cumulative effects. The particulate pollution and other contaminants in the air and the small amount of emissions produced during treatments at any given time and place would result in no noticeable cumulative increases in emissions within the airshed, even when considered with other ongoing and foreseeable future activities.
Effects of Forest Plan Amendment to Air Quality Implementing future projects under the proposed amendment would have no effect on air quality, human health, or visibility. Mandatory design features for protecting human health would continue to apply to herbicide application in municipal watersheds or in areas of human habitation and with prescribed fire. The effects described in this section would be the same under the plan amendment. Heritage Resources
Affected Environment Introduction [Replaces third paragraph] The final environmental impact statement, completed in 2005, tiered to the 2004 Programmatic Agreement (PA) titled “Invasive Weed Control” and was among the USDA Forest Service, Southwestern Region, Santa Fe and Carson National Forests, New Mexico Historic Preservation Officer, Advisory Council on Historic Preservation and in consultation with affiliated Tribes. That agreement expired in 2009. This final supplemental environmental impact statement adheres to the requirements laid out in “Appendix F - Standard Consultation Protocol for Noxious Weed Control” of the First Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities. This agreement is binding among the national forests in New Mexico, New Mexico State Historic Preservation Office (SHPO) and the Advisory Council on Historic Preservation; it addresses applicable Section 106 requirements of the National Historic Preservation Act. Pursuant to the programmatic agreement, subsequent initiation of noxious weed control projects will be
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contingent upon completion of the identification and protection of historic properties, and compliance with applicable provisions of National Historic Preservation Act in accordance with appendix F.
[Replaces fourth paragraph] Weed control methods such as manual and mechanized ground-disturbing treatments would need to follow the steps outlined in appendix F of the standard consultation protocol. Other methods, such as biological methods or direct hand application of herbicides to target weed species, were considered to have little or no effect on heritage resources and are exempt from further consideration under Section 106. The programmatic agreement and appendix F are available in the project record.
[Replaces sixth and seventh paragraphs and Table S-55 replaces table 45] Heritage resource surveys have been conducted on approximately 221,805 acres (15 percent) of the 1.5- million-acre Carson National Forest, and 278,000 acres (17 percent) of the 1.6-million-acre Santa Fe National Forest. Approximately 5,970 heritage resource sites have been recorded on the Carson National Forest, and 9,800 heritage resource sites have been recorded on the Santa Fe National Forest.
Table S-55 illustrates the number of known heritage sites completely within, or intersected by, currently inventoried weed infestations. Sites located completely within currently inventoried weed infestations on the Santa Fe National Forest consist of 101 sites with an average site size of 0.47 acre. Sites that intersect inventoried weed infestations on the Santa Fe National Forest consist of 215 sites with an average site size of 10.6 acres. Of the 10,020 acres of weed infestations on the Santa Fe National Forest, heritage sites encompass approximately 350 dispersed acres (3.5 percent) across the entire project area.
Sites located completely within currently inventoried weed infestations on the Carson National Forest consist of 17 sites with an average site size of 0.79 acre. Sites that intersect inventoried weed infestations on the Carson National Forest consist of 128 sites with an average site size of 15.6 acres. Of the 3,235 acres of weed infestations on the Carson National Forest, heritage sites encompass approximately 259 dispersed acres (8 percent) across the entire project area.
Table S-55. Affected heritage resource sites National Total Sites Within Weed Average Size Sites Intersect Average Size Forest Sites Infestations (Acres) Weed Infestations (Acres) Santa Fe 316 101 0.47 215 10.6 Carson 145 17 0.79 128 15.6 Totals 461 118 N/A 343 N/A
Archaeological Resources [Delete second paragraph, page 148]
Ethnographic and Traditional Cultural Property Resources [Replaces 5th paragraph, page 149] Traditional cultural properties are often difficult to identify during standard heritage resource surveys, and none have been identified in the areas of potential affect during scoping and Tribal consultation activities conducted to date for this project. Scoping and consultation for the initial environmental impact statement was initiated in December of 2000, and an additional solicitation of comments was mailed to Tribes in December of 2003, prior to release of the draft environmental impact statement for public review. As a result of the expired programmatic agreement for the 2005 final environmental impact statement Tribal consultation, the Carson and Santa Fe National Forests conducted consultation with Tribes for the final supplemental environmental impact statement. Letters were mailed to the Tribes on September 19, 2013.
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Environmental Consequences to Heritage Resources [No change from the final environmental impact statement]
Effects of Forest Plan Amendment to Heritage Resources [Additional section] The proposed amendment will have limited effect to archaeological resources in future projects. Effects from herbicides on the analytical potential of perishable materials such as wood, ceramic paint, datable materials, and residues on artifacts has not been studied, but the overall effect is not likely to be adverse. Since little is known about the effects of herbicides on archaeological sites, monitoring will be used to collect additional data on this treatment method.
The proposed amendment will have a short-term effect to ethnographic resources in future projects. Traditional plant habitats could be affected by herbicidal application to eradicate weeds and, if so, would interrupt the plant collecting cycle for traditional communities. The timing of weed treatments, however, would take into account the traditional cyclic calendar of local communities as identified through scoping. Design features that include notifying Tribes before the use of herbicides occurs will reduce the risk to plants used for traditional cultural purposes, and thus to the health of Native Americans who gather these plants (Table S-11, rows 2, 10-12, 54-55).
With the design features and adaptive strategy applied to this and all future projects, no adverse effects to heritage resources (archaeological or ethnographical) are anticipated from the plan amendments. By controlling or eradicating weeds in this and future projects, an overall beneficial impact to soils is predicted; restoring native vegetation on soils generally reduces erosion, thereby increasing productivity and stabilizing heritage resources. The design features and adaptive strategies listed in Table S-10 and Table S-11 provide more protection to heritage resources than the existing forest plan standard. Thus, modifying the existing standard would not adversely affect heritage resources in this or future projects that apply herbicides. Recreation and Wilderness [Replaces entire section; Figure S-12 replaces figure 12; Figure S-13 replaces figure 13] Affected Environment Introduction The affected environment and environmental consequences sections on recreation resources focus on current conditions, historic trends, and environmental effects of each alternative in terms of recreation and wilderness areas. This section also describes past, present, and foreseeable future land use activities that could contribute to cumulative impacts when combined with the effects of this project. The cumulative effects from those activities are described at the end of the “Environmental Consequences” section.
General Recreation Trends Recreation has increased as a proportion of overall national forest use. Outdoor recreation, specifically the component on public lands, is a multibillion dollar industry (Laitos and Carr 1999). In fact, recreation on National Forest System lands increased 1,161 percent between 1950 and 1995 and the Outdoor Recreation Coalition of America reported that in 1997 more than 90 percent of Americans over 16 years old were participating in outdoor recreation activities (Laitos and Carr 1999).
Visitors to the Carson National Forest and Santa Fe National Forest are predominantly local. On the Carson National Forest, greater than 60 percent of the visitors come from towns and mountain communities in Taos County, while around 5 percent come from out of state (USDA 2008, updated 2012). On the Santa Fe National Forest, greater than 60 percent of visitors come from Santa Fe, Albuquerque, or towns adjacent to
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the Santa Fe (Jemez Pueblo, White Rock, Las Vegas), while fewer than 1 percent of visitors are international (Kocis et al. 2010). On both national forests, visitors come from west Texas, Oklahoma, southern Colorado, and Kansas.
The most recent National Visitor Use Monitoring data for both forests are shown in Table S-56. Of the estimated 1 million visitors for the year of the survey, about 80 percent contacted were visiting the Carson National Forest for the purpose of recreation. Of the estimated 1.5 million visitors during the survey year, about 65 percent contacted were visiting the Santa Fe National Forest for the purpose of recreation.
Developed Recreation Developed recreation facilities include campgrounds, picnic areas, trailheads, and other areas containing specialized recreation facilities that are planned to accommodate a fixed number of people at one time. Currently there are approximately 54 developed recreation sites on the Santa Fe National Forest and 34 developed recreation sites on the Carson National Forest. On the Santa Fe National Forest, most weeds mapped in or near developed recreation sites are located along the Jemez River, where saltcedar, Russian olive, and Siberian elm have overgrown fishing access sites and campgrounds (Figure S-12). Invasive weeds are mapped within developed recreation sites on the Carson National Forest. The species include bull thistle and Canada thistle mapped at the June Bug, Elephant Rock, and Cebolla Mesa Campgrounds on the Questa Ranger District and Canada thistle at the Santa Barbara Campground on the Camino Real Ranger District. There are limited populations currently mapped within developed recreation sites, but the potential for expansion into more sites exists due to the existence of numerous weed populations along roads leading to recreation facilities on the two national forests.
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Table S-56. Recreational visits to the Carson and Santa Fe National Forests Santa Fe National Forest Carson National Forest FY 2008a FY 2009b % % that Consider % % that Consider Activity Participating Primary Activity Participating Primary Activity Developed camping 3.9 0.4 5.1 2.3 Primitive camping 4.2 0.6 1.9 0.4 Backpacking 1.0 0.1 1.8 0.9 Resort use 1.3 0.0 0.7 0.0 Picnicking 4.9 1.3 7.7 1.7 Viewing natural features 30.9 4.1 32.4 9.5 Visiting historic sites 2.5 0.0 2.8 0.1 Nature center activities 1.5 0.1 4.2 0.0 Nature study 6.2 0.0 10.1 0.4 Relaxing 26.9 3.5 21.6 4.3 Fishing 7.2 5.8 9.1 5.3 Hunting 5.1 5.0 2.3 1.5 OHV use 2.4 0.8 0.4 0.0 Driving for pleasure 14.9 2.9 11.3 1.7 Snowmobiling 4.0 2.5 0.0 0.0 Motorized water activities 0.0 0.0 0.1 0.0 Other motorized activity 0.0 0.0 0.0 0.0 Hiking/walking 40.2 24.7 66.5 50.7 Horseback riding 1.4 0.0 0.6 0.1 Bicycling 1.0 0.2 2.6 2.0 Non-motorized water 0.1 1.0 0.9 0.8 Downhill skiing 35.4 33.4 8.5 8.3 Cross-country skiing 8.2 6.9 9.4 9.1 Other nonmotorized uses 0.7 0.3 2.2 0.6 Gathering forest products 6.5 2.3 3.2 0.1 Viewing wildlife 23.6 0.7 22.2 0.6 Motorized trail activity 2.9 0.1 0.8 0.0 Some other activity 6.4 4.1 3.3 1.9 No activity reported 0.0 0.6 0.2 0.2 a. From the National Visitor Use Monitoring Results, USDA Forest Service, Region 3, Carson National Forest, 2008. b. From the National Visitor Use Monitoring Results, USDA Forest Service, Region 3, Santa Fe National Forest, February 2011.
Ski areas, organizational camps, and recreation residences (summer homes) are also included in this recreation category as “private sector” recreation. The Santa Fe Ski Area, Taos Ski Valley, Red River Ski Area, Enchanted Forest Cross Country Area, and Sipapu Ski Area are located within the two national forests. In addition, one Boy Scout camp, one Girl Scout camp, and one YMCA camp are located within the two forests. Leafy spurge and bull thistle are currently growing on the Philmont Boy Scout Ranch, and yellow star thistle is growing on the Rancho del Chaparral Girl Scout Ranch.
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Dispersed Recreation Dispersed recreation includes activities in Table S-56 that do not occur in developed facilities. Some developed recreation facilities such as trailheads, parking areas and vista points link with trails which facilitate a variety of dispersed recreation opportunities.
There are 1,095 miles of trails on the Santa Fe National Forest, including 208 miles designated for motorized use. Of these, about half are associated with the San Pedro Parks, Dome, Pecos, or Chama Wilderness areas. There are 540 miles of system trail, including the Pecos Wilderness, on the Carson National Forest and 2,353 miles of system travel ways. Trail use is predominantly recreation oriented. Travel ways are used primarily as 4-wheel drive roads for recreation, livestock trails, and fire access routes.
Three nationally designated scenic byways are located on the two national forests: the Enchanted Circle Scenic Byway, the Jemez Mountain National Scenic Byway, and the Santa Fe National Forest Scenic Byway. Four congressionally designated wild and scenic rivers are all, or partially, on the two national forests: Rio Grande, Rio Chama, East Fork Jemez, and Pecos Rivers. There are populations of Canada thistle, saltcedar, and Russian olive along the Rio Chama Wild and Scenic River.
Most of the dispersed recreation occurs along streams and around waterbodies, as well as in wilderness and designated roadless recreation areas. Camping and other recreational activities in undeveloped areas often remove native vegetation and create disturbed soil conditions that are more susceptible to weed establishment. Horses and other pack animals frequently used for recreation on the two national forests, particularly in wilderness, can transport weeds, especially if hay and feed are brought in. Off road vehicle use is another common way for weed seeds to be spread along routes designated for off-highway vehicles.
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Figure S-12. Weeds located near recreation sites, August 1, 2013
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Figure S-13. Locations of weeds in wilderness areas, August 1, 2013
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Wilderness Eight designated wilderness areas are located on the two national forests: Wheeler Peak Wilderness, Latir Peak Wilderness, Cruces Basin Wilderness, Pecos Wilderness, Chama Canyon Wilderness, San Pedro Parks Wilderness, Dome Wilderness, and the Columbine-Hondo Wilderness. Currently, about 560 acres of invasive weeds are mapped within wilderness areas on the two national forests. The potential for further expansion into, and within, the wildernesses is high due to the existence of numerous populations along roads and trails which provide access to the wilderness areas.
Motorized and mechanized weed treatments are not allowed within wilderness. Forest Service Manual 2323.26b states: Approve plant control only for…: b. Noxious farm weeds by grubbing or with chemicals when they threaten lands outside wilderness or when they are spreading within the wilderness, provided that it is possible to effect control without causing serious adverse impacts on wilderness values.
Herbicide treatments in wilderness areas require review and approval by the regional forester (Forest Service Manual 2323.04c).
Wilderness character is composed of four qualities: 1. Untrammeled – the primary ideal for wilderness where it is essentially unhindered and free from modern human control or manipulation. 2. Natural – where the natural condition of the land, its plants, wildlife, water, soil, air, and the ecological processes are managed, protected, and preserved. 3. Undeveloped –where wilderness retains its primeval character and influence, and is essentially without permanent improvements or human occupation. 4. Solitude or Primitive and Unconfined Recreation – where wilderness provides these types of recreation opportunities.
Environmental Consequences to Recreation and Wilderness Summary The principal relationship between recreation and invasive weeds is that recreation is a vector for spread of weeds. Direct and indirect impacts on recreation, both within and outside wilderness, resulting from implementation of the action alternatives would include short-term encounters with weed treatment crews, short-term closures of areas during treatments, and visual impacts from wilting plants. In some cases, herbicide treatment may be applied within a wilderness area. Some wilderness advocates would perceive that wilderness values were being reduced by the use of chemical weed control methods within wilderness. Cumulative effects resulting from action alternatives would be the protection of adjacent noninfested areas and preservation of intact plant communities, which would enhance recreation and wilderness experiences.
Direct and Indirect Impacts Weeds can affect the recreation experience. Invading weeds such as spotted knapweed, Scotch thistle, and yellow star thistle detract from the desirability of using recreation sites and enjoyment of the wilderness. These species diminish the usefulness of sites because the stiff plant stalks, thorns, or sharp bristles can discourage or prevent walking, sitting, or setting up a camp. Weeds also detract from the recreation experiences by reducing the variety and amount of native flora to observe or study and reducing forage availability for wildlife and recreational livestock.
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Alternative A–No Action General Recreation Trends Recreation on the forests is likely to cause the establishment of new weed populations, which would then spread at the assumed average rate of 8 percent per year. Weeds would typically spread along roads and motorized trails because motor vehicles are one of the main ways weed seed spreads. Roadsides and adjacent areas, such as turnouts, campgrounds, and firewood gathering areas, are usually disturbed, which favors the proliferation of most weed species.
The spread of weeds would degrade recreational values for people who understand and value natural conditions. The National Visitor Use Monitoring survey data (Table S-56 – Santa Fe National Forest) indicate 32 percent of visitors surveyed enjoy viewing natural features, 10 percent enjoy nature study, and 22 percent enjoy viewing wildlife.
Hunting opportunities would be reduced over time as weeds reduce the quality of forage and cover habitat for many wildlife species (refer to “Wildlife Resources” section).
Weeds such as spotted knapweed, Scotch thistle, and yellow star thistle would diminish the desirability of dispersed recreation opportunities because the rigid plant stalks, thorns, or sharp bristles would discourage or prevent walking, sitting, or setting up a camp.
Recreational experiences and values would especially decline where tall, dense weeds such as saltcedar dominate and limit access to riparian areas and stream banks. The dense thickets of saltcedar along the Green River in Desolation Canyon have eliminated many of the campsites used by river runners for the first 20 miles downriver from the Bureau of Land Management Sand Wash boat ramp. Weed species that cause allergies (hay fever, skin reactions) would also diminish recreational experiences for susceptible people.
On the other hand, this alternative would avoid the temporary closures of some recreation sites, trails, or roads during and immediately after treatment activities.
Wilderness The no-action alternative would have the following effects on the four wilderness characteristics: 1. Untrammeled – Not allowing any treatments in wilderness would preserve the untrammeled quality of wilderness. 2. Natural – Not allowing any treatments in wilderness would result in the proliferation of weeds over time. This would not manage, protect, or preserve its natural ecological processes. This assumes weed proliferation outside and introduction into wilderness is not a natural ecological process. 3. Undeveloped – The no-action alternative would have no effect on this quality because no permanent improvements or permanent occupation would occur. 4. Solitude or Primitive and Unconfined Recreation – The no-action alternative would preserve solitude and primitive and unconfined recreation because no treatments would occur.
Alternative B–Proposed Action General Recreation Trends Recreation on the two national forests is likely to cause the establishment of new weed populations, which would then spread at the assumed average rate of 8 percent per year. Under this alternative, the Forest Service expects to be able to control or eradicate new populations. Because the new populations are most likely to establish along roads and trails, Forest Service personnel would be able to get to them easily for treatment.
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The negative effects predicted for alternative A would not occur or would occur to a lesser degree, depending on how effectively new populations are eradicated.
Developed and Dispersed Recreation Herbicide applications and other treatments may cause temporary visual disturbances to some people who encounter weed treatment personnel; however, on most sites, treatments would only last a few days or less. There would be an insignificant increase in the amount of noise and traffic associated with these treatment activities, primarily due to the short timeframe needed to treat weeds at most weed infestation sites and the relatively small number of personnel needed to implement treatments. Proposed treatments typically would not require large crews of workers such as those used for thinning projects, prescribed burning, watershed restoration projects, etc.
Temporary closure of roads, trails, or recreation sites during and immediately after herbicide applications would have a minimal impact on recreational opportunities because they would not typically last more than a day or two and would occur during weekdays.
Odors emitted by herbicides could cause anxiety in persons unaware of their presence, although it is unlikely herbicides would be applied along trails or in recreation sites during a time when visitors are present because the Forest Service would close sites during herbicide application. Signs would be posted at access points to recreation sites, roads, or trails where herbicides would be used. The “Human Health and Safety” section describes the effects of herbicides on human health in detail.
Areas of wilting, dying, or dead weeds and weeds removed, cut, or burned would be apparent for a short time in the localized treatment sites. This would diminish the natural appearance of the treatment site. Within a growing season or two, early seral vegetation would fill in and become more noticeable than the dead plants or bare soil areas.
Wilderness The effects of alternative B on the four wilderness characteristics would be as follows: 1. Untrammeled – For some people, the sight of agency personnel spraying herbicides or hand grubbing weeds within a wilderness may diminish the quality of their wilderness experience. 2. Natural – Controlling weeds would promote native plants, which would be managing the natural condition of the land, its plants, wildlife, water, soil, air, and the ecological processes. 3. Undeveloped – Alternative B would have no effect on this quality because no permanent improvements or permanent occupation would occur. 4. Solitude or Primitive and Unconfined Recreation – No effect on solitude or primitive and unconfined recreation is expected because the acreage needing treatment is tiny compared to the acreage of the wildernesses. Temporary closures of sites during treatment are possible; the closures would generally last less than a week.
Alternative C–No Herbicides General Recreation Trends Alternative C would not be as effective at controlling newly established weed populations caused by recreational activities. The result on general recreation trends would be the same as alternative A but to a lesser extent.
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Developed and Dispersed Recreation Due to the need for additional repeat treatments, there would be a slight increase in the amount of noise and traffic associated with treatments on the forest. Some recreation sites and trails being treated with manual or other non-herbicide methods would not need to be temporarily closed to the public which would maintain more recreation opportunities, especially for visitors who are sensitive to chemically treated environments.
Wilderness The effects of alternative C on the four wilderness characteristics would be as follows: 1. Untrammeled – For some people, the sight of larger numbers of agency personnel treating weeds within a wilderness may diminish the quality of their wilderness experience, compared with alternative B. 2. Natural – Controlling weeds would promote native plants, which would be managing the natural condition of the land, its plants, wildlife, water, soil, air, and the ecological processes; this alternative would be less effective than alternative B because small isolated populations are difficult to monitor and applying more repeated treatments for effective control would be more difficult. 3. Undeveloped – Alternative C would have no effect on this quality because no permanent improvements or permanent occupation would occur. 4. Solitude or Primitive and Unconfined Recreation – No effect on solitude or primitive and unconfined recreation is expected because the acreage needing treatment is tiny compared to the acreage of the wildernesses.
Alternative D–Herbicides Only General Recreation Trends Effects under alternative D would be similar to effects under alternative B above. Ground-disturbing activities, such as mowing, tilling, digging, or burning, would not be implemented. Since these activities often need to be repeated in order to meet objectives, the effect over time would be a reduction in noise and traffic along roads and trails and within recreation sites during treatment activities.
The effects of alternative D on the four wilderness characteristics would be as follows: 1. Untrammeled – For some people, the need for fewer people performing weed control would diminish the sense of excessive human intervention, compared with alternatives B and C. 2. Natural – Controlling weeds would promote native plants, which would be managing the natural condition of the land, its plants, wildlife, water, soil, air, and the ecological processes. This alternative would be less effective than alternative B for species most effectively controlled by non-herbicide methods; and more effective than alternative C for species most effectively controlled by herbicides. 3. Undeveloped – Alternative C would have no effect on this quality because no permanent improvements or permanent occupation would occur. 4. Solitude or Primitive and Unconfined Recreation – No effect on solitude or primitive and unconfined recreation is expected because the acreage needing treatment is tiny compared to the acreage of the wildernesses.
Cumulative Effects to Recreation and Wilderness The cumulative effect of the no-action alternative would be an increase in the establishment of new weed populations. The direct and indirect effect of the no-action alternative is that new weed populations are likely to become established as a result of recreational activity. This would add cumulatively with other actions that cause the establishment of weeds, such as wildfires, some prescribed burns, construction of facilities, road
141 Invasive Plant Control Project maintenance, and firewood collection. The cumulative effect on recreation would be a decrease in the quality of recreational activities due to weeds with thorns and allergens and due to a loss of native vegetation.
The direct and indirect effect of the action alternatives and the cumulative effect are shown in Table S-57.
Table S-57. Cumulative effects to recreation and wilderness resources Actions Contributing Cumulatively to the Direct And Direct and Indirect Effect Indirect Effect Summary of Cumulative Effect Loss of recreational opportunity The publication of Motor Vehicle Negligible. Weed treatments where sites are closed during Use Maps has reduced the would be widely dispersed and treatments, normally 1 to 5 days places where people can drive in closures would last for brief the forests. Areas are closed periods. This means people during administrative projects, would still have ample such as prescribed burns and opportunity for recreational thinning operations. During times activity across the project area. of high fire danger, the entire project area can be closed for several weeks. Visual disturbance from wilted, Prescribed burns, wildfires, and Negligible because the effects dead, or dying plants drought are the primary things would last a season or less and that cause plants to die. are not likely to occur in the same places. Noise and visual disturbance All activities conducted by Negligible. No additional national from crews performing national forest personnel, such forest personnel would be hired treatments, including in as prescribed burning, thinning to treat weeds, so there would be wilderness areas operations, trail maintenance, no net increase in activities. cleaning recreational facilities, performing monitoring activities, laying out sites, and suppressing wildfires all cause noise and visual disturbance.
Effects of Forest Plan Amendment to Recreation and Wilderness Part of the Santa Fe municipal watershed is located in designated wilderness. The effect of the forest plan amendment on wilderness during future projects depends on the municipality’s willingness to treat weeds using herbicides. If the municipality agrees to the use of herbicides (shown to be the most effective treatment against weeds in general), with the design features in place, the overall effect would be to promote the natural characteristic of wilderness by promoting native vegetation. Conversely, if the municipality prohibits the use of herbicides, then the natural characteristic might be compromised if weeds spread more quickly than the Forest Service can control them.
The plan amendment allows treatment in areas of human habitation, which is interpreted as recreation sites for this portion of the analysis. The effects of the amendment would be no different than those described in the direct, indirect, and cumulative effects because this project incorporates many elements (Table S-10 and Table S-11) to protect human health and safety.
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Visual Resources [Replaces entire section]
Affected Environment Visual Quality Objectives Five visual quality objectives have been prescribed in the forest plans for the Carson and Santa Fe National Forests. The visual quality objectives categorize lands according to scenic quality and viewer sensitivity. They are preservation, retention, partial retention, modification, and maximum modification. Preservation, for example, is the visual quality objective assigned to wilderness areas. When originally developed, the visual quality objectives described the existing condition of the national forests’ viewsheds. The visual quality objectives are not binding elements of the forest plans; however, the Forest Service makes every effort to ensure its management actions align with the existing visual quality objectives. See The Visual Management System (USDA Forest Service 1984) for definitions and descriptions of the visual quality objectives and the Carson and Santa Fe National Forest Plans (USDA Forest Service 1986b and 1987b) for an explanation of how visual quality objectives were applied to each national forests.
Though visual quality objectives have been established for both national forests, they have not been completely mapped in electronic (GIS) format. Due to technological changes and budget constraints, the visual quality objectives have not been completely transferred from old Forest Service mylar maps. For example, 62 percent of the Santa Fe National Forest (mainly the west side) has the visual quality objectives mapped in the GIS dataset.
Visual Elements Four visual elements—form, line, color and texture—exist in any landscape. Depending on their composition and where they are viewed from, they exert differing degrees of influence.
• Form: Landscape forms are determined by topography and vegetative pattern. The weed populations in the project area are relatively small and thus are indiscernible beyond foreground (up to ½ mile) views. Weeds do not dominate viewsheds in the project area. • Line: Line is anything that is arranged in a row or sequence. It can be the silhouette of a form, the edge of a meadow, a ridgeline, a tree trunk, a river, the path of an avalanche, a road. Weeds, being plants, conform to the line of surrounding vegetation. • Color: Color enables people to distinguish among objects of identical form, line, and texture. Weeds are plants; thus, their colors conform to the surrounding vegetation and natural environment. • Texture: Textures in the landscape are determined by geology, soils, topography, and vegetation. Weeds, as plants, conform to the textures of a forested or grassland environment.
Environmental Consequences to Visual Resources Summary Under the no-action alternative, the four visual elements would not noticeably change for many years.
Under all action alternatives, treating weeds would have a temporary effect on visual elements. All visual effects would be temporary because native vegetation is expected to grow back within a season or less. Further, all visual effects would be small because weed populations are currently small relative to the project area as a whole. Known weed populations cover 0.4 percent (13,256 acres) of the National Forest System lands in the project area (3,030,721 acres). The largest mapped patch of weeds is 2,793 acres of Canada thistle
143 Invasive Plant Control Project on the Santa Fe National Forest. The treatment sites are small and would not alter the overstory tree cover; thus, there would be minimal changes in form, line, color, or texture in the environment.
Direct and Indirect Effects Visual Quality Objectives All the alternatives conform to the visual quality objectives assigned. The no-action alternative conforms to visual quality objectives because weeds were part of the visual landscape when the visual quality objectives were assigned.
Under the action alternatives, weed treatments would meet visual quality objectives. The visual effects of treatments, which are dead or dying plants, are temporary. Brown, dead, or dying vegetation would last no longer than it takes for native vegetation to grow back, normally a season. Dead or dying vegetation is a natural phenomenon, especially given the current drought. Even weed control treatments applied in designated wilderness would be expected to conform to the visual quality objective of preservation since treatments would not substantially alter the form, line, color, or texture of the landscape, or create a stark contrast with the surrounding vegetation.
Visual Elements Alternative A Under alternative A, weeds are expected to spread at an average rate of 8 percent per year.
• Form: Over many years, weeds could dominate viewsheds. This, however, would not represent a significant change from the current landscape forms, which are dominated by “carpets” of trees or grass at the middleground and background views (photo 5).
Photo 5. Aerial view; example of current forest conditions in much of the project area. Note the uniform form, line, and texture
• Line: Without weed treatments, there would be no change in visual lines. Even with the continued spread of weeds, the lines formed would not be different from that presently found in a forested or grassland environment.
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• Color: There would be no change in color if weeds are not treated. Weeds, being plants, have colors naturally present in a forested or grassy environment. • Texture: Because weeds are plants, there would be no change to visual texture from what is currently expected in a forested or grassland environment if weeds are not treated.
Alternatives B, C, and D Overall, the treatment sites are small and would not alter overstory tree cover, thus there would be minimal changes in form, line, color, or texture in the environment. Of the 78 patches of weeds, 13 (17 percent) are 200 acres in size or greater. Any visual effect to the four visual elements would be temporary (normally a year or less), lasting until native vegetation grows back.
• Form: Because weed populations do not dominate viewsheds, treating them would not change landscape form in the middleground or background. In the foreground, people might observe dead or dying plants until native vegetation grows back; however, the presence of dead or dying vegetation is not uncommon in a forested environment and thus would not differ from current forms. In the foreground view, the visual impacts resulting from mowing, hand grubbing, and hand pulling would be a change in the form because these methods result in localized soil disturbance. Root plowing would be more noticeable. Biological methods would not be visually noticeable in the foreground other than dead or dying weeds. Use of prescribed fire would cause the burned vegetation to appear brown or blackened for a short period and might result in patches of bare soil until the site is revegetated, similar to the visual effect of a naturally caused surface fire.
• Line: Treating weeds would result in new lines, where the edge of treatments (brown areas) would abut green areas. Lines from mowing, hand grubbing, and hand pulling would be noticeable in the foreground until native vegetation grows back; lines from prescribed fires could be noticeable in the middleground as well. The lines created by weed treatments would be normal in a natural setting in that they would not be straight. • Color: Treating weeds from any method would result in brown vegetation. The color brown is common in a forested environment. The use of prescribed fire would cause blackened vegetation, also common in a forested environment. Because the color changes would be natural to a forested or grassy environment, there would be no direct or indirect effect. • Texture: Dead and dying plants are part of the natural texture of a forested environment (for example, piñon die-off of 2002 and wildfires); thus, treating weeds would not result in any unusual textures in the project area. Ground-disturbing methods, such as hand-pulling or mowing, would impact texture in the foreground by removing plants and leaving bare soil exposed until native vegetation grows back, normally a season.
Cumulative Effects to Visual Resources Visual Quality Objectives Because there would be no direct or indirect effect to visual quality objectives from any of the alternatives, there would be no cumulative effects.
Visual Elements Because alternative A (no action) has very little direct or indirect effects to the four visual elements, it would have no cumulative effects.
Table S-58 shows the anticipated cumulative effects for all action alternatives (B, C, and D) to the four visual elements.
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Effects of Forest Plan Amendment to Visual Resources The proposed plan amendment would have no effect to visual quality on future projects beyond what has been described in this section. The same effects to form, line, color, and texture described for this project would be the same for future projects under the plan amendment, which addresses where herbicides may be used.
Table S-58. Cumulative effects of action alternatives to visual quality Past, Present, and Reasonably Direct/Indirect Foreseeable Future Actions that Item Effect Overall Cumulative Effect Cumulatively Contribute to the Effect Form No effect in No direct or indirect effect; Road construction and maintenance middle- or thus, no cumulative effect to Trail construction and maintenance background. middle- or background. Creation of unauthorized routes Temporary The effect of weed treatments Construction and reconstruction of change in form in the foreground would recreational facilities (such as due to dying contribute a negligible campgrounds, fishing access, toilet vegetation or cumulative effect to form. It is installations) ground unlikely, for example, that the Subdivision and development of private disturbance. change in form caused by inholdings and land adjacent to the two weed treatments would be national forests noticed against something Mining claims and development of mining like the Las Conchas Fire or Wildfires, including suppression and the oil and gas pads present rehabilitation on the Jicarilla Ranger District. Hazardous fuels treatment and prescribed burning Line Temporary The effect of weed treatments Livestock grazing change in line on line would be negligible where treated when considered in context of Road decommissioning areas abut the activities listed at left. The Forest product collection untreated areas. lines created by treatments Administrative use would be relatively small Weed treatments on land in other (because of the small patch jurisdictions sizes), temporary, and would Oil and gas leasing be “natural” in the sense they would not be straight. Preparation of travel management plans and motor vehicle use maps by national Color No effect. No direct or indirect effect; forests and other agencies thus, no cumulative effect. Special Use Permits – acequia Texture Temporary effect The cumulative effect to improvements, ROW for pipelines of bare soil as a texture as a result of treating (water/natural gas), driveways, result of ground weeds would be negligible communication sites, outfitter/guides, etc. disturbance. when considered in context Geothermal leases in Coyote, Cuba and with the activities listed at left. Jemez Ranger districts The size of patches to be Oil and gas leases in Cuba Ranger treated is relatively small, and District the effect would be temporary because of the mitigation to Oil and gas development on the Jicarilla ensure that bare ground is Ranger District revegetated.
Livestock Grazing [Replaces entire section]
Affected Environment Effects of Weeds on Livestock Most livestock (and wildlife) depend on rangelands for grazing. Some weeds, such as larkspurs and locoweeds, are toxic when grazed (DiTomaso 2000). Due to their low palatability or toxicity, weeds can also
146 Final Supplemental Environmental Impact Statement reduce the forage available to livestock if extensive populations exist. Particularly troublesome are knapweeds because they are low in palatability and readily invade both disturbed and undisturbed sites (DiTomaso 2000). Downy brome (cheatgrass) is the most dominant weed in the West. Though it can be used as forage, in some years it only provides 10 percent of productivity of the perennial species it replaced (McHenry and Murphy 1985).
Effects of Livestock on the Spread of Weeds Domestic livestock, particularly sheep, cattle, and horses, have grazed in the project area for over 200 years. Livestock grazing over an extended period of time greatly changes the plant composition from the original ecosystems and can result in the presence of weeds (Endress et al. 2012, Murphy 1986). LeJeune (2001) describes how weeds are more successful competitors when nitrogen in soils is present, a situation chronic livestock grazing (along with fire suppression) has enhanced.
In the project area, the extent to which domestic livestock grazing has caused the spread of weeds is not known. Because the acreages of weeds in the project area are low, it can be assumed grazing management on the two national forests has been effective (for example, preventing severe overgrazing) at controlling the establishment and spread of weeds. Stipulations in grazing permits, such as not being allowed to feed hay on National Forest System lands, have likely prevented new weed populations from establishing.
The next two tables show the livestock grazing allotments administered by each national forest and the acres of known weed infestations in each allotment.
Table S-59. Grazing allotments with known weed infestations on the Carson National Forest Percent of Allotment Size of Allotment Acres with Weed Infested with Weeds Name of Allotment (acres) Infestation* (nearest percent) Angostura 17,716 0 0 Arroyo Hondo 18,974 2 0 Bancos 16,526 12 0 Black Copper / Red River 10,418 2 0 Black Lakes 12,038 0 0 Bobcat 6,284 3 0 Cabresto 26,907 256 1 Capulin 13,745 0 0 Carracas 32,554 331 1 Carson-Mojino 7,615 8 0 Columbine 9,016 1 0 Deer Creek Complex 5,379 1 0 East Piñon 3,051 1 0 El Rito Lobato 95,948 376 0 English 8,234 0 0 Flechado 6,365 1 0 Goose Creek 6,568 2 0 Jarita Mesa 63,676 5 0 La Cal 5,148 0 0 La Lama 15,628 8 0 Laguna Seca 29,122 31 0 Lakefork Baldy 8,271 19 0 Main Fork 4,191 2 0
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Percent of Allotment Size of Allotment Acres with Weed Infested with Weeds Name of Allotment (acres) Infestation* (nearest percent) Mesa 9,578 1 0 Midnight/Mallette 24,859 43 0 Miranda 8,069 30 0 Mogote 16,594 0 0 Olla-Ranchos 68,035 148 0 Private Land 61,214 24 0 Recreational 266 0 0 Red River 22,006 14 0 Rio Chiquito 29,129 6 0 Rio Pueblo 33,967 5 0 Rito Segundo 8,594 5 0 San Antone 41,843 13 0 San Antonio Mountain 7,478 0 0 San Cristobal 21,368 10 0 San Gabriel 3,969 1 0 Santa Barbara 34,235 39 0 Santos 8,800 5 0 Sawmill Park 2,055 1 0 Servilleta 10,263 2 0 Ski Area 1,167 0 0 Spring Creek 25,086 21 0 Sublette 10,940 0 0 TCLP 40,227 7 0 Tio Gordito 27,998 8 0 Tio Grande 31,986 32 0 Trampas 27,549 1 0 Tusas 43,641 0 0 Valencia 20,933 41 0 Valle Vidal 101,293 1,515 1 Vaqueros 31,818 175 1 * A zero means that less than 1 acre is infested with weed(s).
Table S-60. Grazing allotments with known weed infestations on the Santa Fe National Forest Percent of Allotment Size of Allotment Acres with Weed Infested with Weeds Name of Allotment (acres) Infestation* (nearest percent) Alamo 22,478 227 1 Aspen Mountain 17,372 53 0 Barbero 19,185 362 2 Bear Lake 41,446 1 0 Bear Springs 2,301 0 0 Bland Canyon 8,814 0 0 Bull Creek 14,636 4 0 Caja del Rio 66,873 50 0 Capulin 7,214 230 3
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Percent of Allotment Size of Allotment Acres with Weed Infested with Weeds Name of Allotment (acres) Infestation* (nearest percent) Cebolla / San Antonio 26,171 11 0 Chama 40,423 330 1 Chicoma 2,899 0 0 Chiquito 13,185 23 0 Colonias 24,073 45 0 Coyote 21,607 313 1 Cuba Mesa 7,374 96 1 Del Norte 7,890 4 0 Dome 3,426 1 0 El Cielo 12,175 4 0 El Invierno 45,695 114 0 El Pueblo 26,753 1 0 French Mesa 25,203 187 1 Gabaldon 8,571 46 1 Gallina Mountain 11,188 8 0 Gallina River 22,409 1,135 5 Glorieta 35,164 19 0 Gurule 8,361 1 0 Horse Thief 20,538 0 0 Jarosa 23,369 911 4 La Jara 17,549 104 1 La Presa 11,385 133 1 Las Conchas 1,396 2 0 Llaves 11,423 92 1 Los Indios 7,617 131 2 Macho 38,257 186 0 Mesa Alta 37,243 720 2 Mesa de las Viejas 20,942 2 0 Mesa del Medio 17,331 242 1 Mesa Poleo 25,972 530 2 Ojito Frio 10,603 45 0 Ojitos 18,527 29 0 Oso Vallecitos 44,991 6 0 Palomas 5,282 2 0 Penas Negras 16,734 69 0 Peralta 12,882 7 0 Pine Springs 30,949 5 0 Pollywog 20,845 64 0 Polvadera 21,027 16 0 Private land 29,566 2 0 Quemado 24,373 67 0 Recreational 4,106 260 6 Red Top 9,927 22 0 Rio de la Casa 17,882 18 0 Rosilla 18,763 46 0
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Percent of Allotment Size of Allotment Acres with Weed Infested with Weeds Name of Allotment (acres) Infestation* (nearest percent) San Diego 102,739 984 1 San Jose 13,775 0 0 San Luis 39,730 249 1 San Miguel 21,916 176 1 San Pedro 21,634 53 0 Santa Fe Watershed 24,458 44 0 Sapello 6,601 0 0 Senorito 21,672 143 1 Sierra Mosca 44,531 3 0 Simon 12,506 4 0 Soldier Creek 15,883 98 1 South Ojitos 9,712 42 0 Springs 29,789 153 1 Tecolote 11,082 78 1 Vacas 8,034 46 1 Valle Osha 8,967 0 0 Vallecitos 16,255 272 2 V-Double Slash 37,408 39 0 Youngsville 31,729 659 2 * A zero means that less than 1 acre is infested with weeds.
Between 0 and 2 percent of most allotments are infested with weeds. The two largest acreages of infestations are on the Valle Vidal and the Gallina River allotments. The acreage of weeds on the Valle Vidal allotment reflects the effects of the 2002 Ponil Fire because weeds tend to colonize disturbed areas. Bull thistle became established primarily along drainages and at the base of burned evergreens within the high-intensity burned areas. In the San Diego allotment, the majority of the weeds consists of saltcedar along the Jemez River. Permitted livestock grazing has not been allowed along the lower Jemez River area since 1980. Prior to that time, much of it was privately owned. Since then, it has been designated as a national recreation area and several recreation sites have been developed.
Table S-61 shows the wild horse and burro territories in the project area. Two territories (Jarita Mesa and Jicarilla) are occupied. These overlap with cattle grazing allotments, so the acres of weeds present are counted in Table S-59 and Table S-60.
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Table S-61. Wild horse territories Acres with Weeds Overlaps with Cattle National Name of Wild Horse (known as of Grazing Allotment(S) Forest or Burro Territory Acres Aug. 1, 2013) Listed Here Carson Jicarilla 75,000 598 Carracas Cabrestos Bancos Yso/Montosa 21,579 0.08 Canjilon Mogote Mesa De Las Viejas 20,942 2 Gallina Mountain Rio Chama Jarita Mesa 54,866 5 Jarita Mesa Santa Fe Caja del Rio 12,500 0 Caja del Rio Cochiti Pueblo (Tribal) Chicoma 2,899 0 Chicoma Oso Vallecitos Dome 3,426 0.8 Alamo San Diego 2,274 0 San Diego
Environmental Consequences to and from Livestock Grazing Alternative A
Effects of Weeds on Livestock The acreage of weeds currently present in the allotments is low which means forage availability is high, and the risk of livestock poisoning is low. Without treatment, weeds would continue to displace palatable native vegetation and reduce forage. This is likely to take many years and should not be an immediate concern to permittees, but it should be a long-term concern. Weeds are persistent once established. Should weeds become the dominant plants on the allotments, they would be extremely difficult and expensive to remove (Frid et al. 2013).
Effects of Treatments on Livestock Under the no-action alternative, there would be no risk of negative effects from treatments because they would not occur.
Effects of Livestock on the Spread of Weeds There would be no change from what is described in the affected environment because this project does not propose to alter grazing practices.
Alternatives B and D Effects of Weeds on Livestock Presently, the amount and species of weeds on the two national forests have not reduced the amount of forage available for domestic livestock because the weeds compose a small percentage of the available forage on the allotments. Thus, the effect of alternatives B and D would be to prevent such a loss from occurring. Under alternatives B and D, the Forest Service expects to have controlled or eradicated the weed populations within a decade. This means native vegetation would be restored or promoted, resulting in long-term beneficial effects on the allotments. There would be increases in density and vigor of native and desired forage grasses within proposed treatment areas (See “Vegetation Resources” section for more detail). There would be beneficial effects on soil and water resources that are important in maintaining quality rangeland conditions (See “Water Resources” and “Soil Resources” sections for more detail).
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Because alternatives B and D would control or eradicate the weeds toxic to domestic livestock, there would be a reduction in the risk of toxic effects to cattle from ingesting weeds. The two national forests are not currently at a level of infestation where weeds are displacing grazing opportunities except in very small, localized situations. Over the long term, control measures taken now would avoid more significant impacts in the future.
Effects of Treatments on Livestock No effects from treatments to livestock are expected to occur because the project design includes working with livestock permittees on the treatment schedule. It is anticipated permittees would manage their livestock so as to avoid potential effects.
Effects of Livestock on the Spread of Weeds There would be no change from what is described in the affected environment because this project does not propose to alter grazing practices.
Alternative C–No Herbicides Effects of Weeds on Livestock Alternative C would result in the same type of beneficial effects as alternatives B and D but to a lesser extent. Because the effectiveness of alternative C in eradicating or controlling weed establishment and spread is expected to be less than with alternatives using herbicides, this alternative would not realize the same level of benefit as quickly. The risk to livestock from ingesting poisonous weeds would be less than in the no-action alternative but more than in alternatives B or D for the reason stated above.
Effects of Treatments on Livestock No effects from treatments to livestock are expected to occur, because the project design includes working with livestock permittees as to the treatment schedule. It is anticipated permittees would manage their livestock so as to avoid potential effects.
Effects of Livestock on the Spread of Weeds There would be no change from what is described in the affected environment because this project does not propose to alter grazing practices.
Cumulative Effects Effects of Weeds on Livestock The direct and indirect effect of all the alternatives on the availability of forage is negligible; at present, weeds compose 2 percent or less of most of the allotments. Because the effect of the alternatives is negligible (immeasurable), there would be no cumulative effects.
Effects of Treatments on Livestock Since there would be no direct or indirect effects to livestock from treatments due to the design of the project, there would be no cumulative effects.
Effects of Livestock on the Spread of Weeds There would be no change from what is described in the affected environment because this project does not propose to alter grazing practices. Thus, there would be no cumulative effects.
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Effects of Forest Plan Amendment to Livestock Grazing The proposed plan amendment would have no effect on livestock grazing in the future because the restrictions imposed for herbicide use would not alter or affect grazing practices. Any effects from herbicide treatments in the future with the amendment in place would have the same effects as described in this section. Social-Economic Resources [Replaces entire section] Issues Analyzed From the comments made during scoping and notice and comment, the interdisciplinary team identified the following social issues to analyze in detail.
1. The proposed action may have a disproportionately high and adverse impact on the health of minority or low-income populations. This type of analysis is called “environmental justice” (Office of the President 1994). This issue did not result in the creation of a new alternative. a. Weed treatment activities have the potential to affect human health and safety in a number of ways, including exposure to machinery, equipment, or chemicals. Although exposure to machinery and equipment poses a safety risk, the larger public concern relates to the health risk posed by using herbicides. This risk is defined three ways: i. By direct exposure during application. ii. By contact with vegetation that has been sprayed and then collected for use. iii. By direct or indirect exposure for people with heightened chemical sensitivities.9 This issue resulted in the development of alternative C, which does not include herbicide use.
b. On weed infestation sites where nonchemical methods are proposed for use without supplemental herbicides, weed control effectiveness would be lower and treatment costs higher.10 This issue did not result in the creation of a new alternative.
Analysis Area The analysis area for this project includes the eight counties in which the Carson and Santa Fe National Forests are located: Colfax, Los Alamos, Mora, Rio Arriba, San Miguel, Sandoval, Santa Fe, and Taos Counties. The people living in these counties are the most likely to be affected by the project.
Affected Environment for Low Income and Minority Populations The issue analyzed here is “the proposed action may have a disproportionately high and adverse impact on the health of minority or low-income populations.”
Measure The measure is quantification of minority and low-income populations in the study area and comparison of potential impacts to health and the environment.
Rationale Executive Order 12898 requires all Federal agencies to analyze, and if necessary, address high and adverse human health or environmental effects of their actions and policies to minority and low-income populations.
9 Refer to page 33 of the FEIS for the complete wording of this issue. 10 Refer to page 34 of the FEIS for the complete wording of this issue.
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Assumptions • A population is considered a minority population if (a) the minority population of the affected area exceeds 50 percent or (b) the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the general population or other appropriate unit of geographic analysis (Council on Environmental Quality (CEQ) 1997). • Minority populations and low-income groups are identified at the county level because this unit of measure does not artificially dilute or inflate the affected minority population, pursuant to the 1997 guidance provided by the Council on Environmental Quality. • Low-income populations are identified using the annual statistical poverty thresholds from the 2010 census. The Census Bureau shows this data as a percent of the total population at different scales, shown below at the State and County levels. • This analysis addresses the risks from exposure to herbicides of the general public. People employed by the Forest Service to treat weeds would be required to follow all safety regulations and the mitigation measures listed in Table S-10 and Table S-11. Following these precautions would reduce the risk to workers to a negligible amount.
Methods Minority and low-income populations within the project area were identified using 2010 census data at the individual county levels. Tribes were included with the census bureau’s data on the counties.
Results The 2012 population of the study area is estimated to be 420,038 people. Table S-62 shows the percentages broken down by ethnicity and race.
Table S-62. Ethnicity and race at the county scale (all figures are percentages) Ethnicity Race Non- Native All Other Area Hispanic Hispanic American White Races Colfax County 48.2 48.6 2.3 94.3 3.4 Los Alamos County 15.6 75.0 1.0 89.7 9.3 Mora County 80.6* 18.1 2.9 94.2 2.8 Rio Arriba County 71.3* 13.3 18.0* 78.5 3.5 Sandoval County 36.3 46.6 13.4* 79.6 7.1 Santa Fe County 50.9* 43.7 3.9 91.4 4.7 San Miguel County 76.9* 19.6 2.8 92.4 4.8 Taos County 56.2* 36.1 7.2 88.4 4.4 * These represent minority populations according to the Council on Environmental Quality guidance.
Based on the information above, racial and ethnic minority populations exist within the analysis area:
• The Hispanic populations in Mora, Rio Arriba, Santa Fe, San Miguel, and Taos Counties • The Native American population in Sandoval and Rio Arriba Counties
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Table S-63. Percent of population below the Federal poverty level by county (all figures are percentages) Area Percent of Population in Poverty, 2007 to 2011 New Mexico 19.0 Colfax County 18.7 Los Alamos County 3.7 Mora County 16.3 Rio Arriba County 19.2* Sandoval County 12.4 Santa Fe County 15.6 San Miguel County 26.2* Taos County 21.5* These represent low-income populations according to the Council on Environmental Quality guidance.
Those counties that show a greater percentage of the population below poverty than the state level are considered low-income populations. Based on the 2010 census data, low-income populations exist in the analysis area in Rio Arriba, San Miguel, and Taos Counties.
People from rural communities use the two national forests for recreation, traditional purposes, livestock grazing, fuelwood collection, and other activities. Fuelwood is essential to many residents in the area. Commercial and individual use of posts, poles, and vigas is extensive. The majority of permittees grazing livestock on the two national forests are residents of the small Hispanic or Native American communities. The national forests contribute substantial employment in these communities through firefighting, timber crews, and rangeland work. Native Americans and Hispanics, in particular, gather plants, animals, wood products, and clay on the two national forests for religious purposes.
Most rural communities in the area rely on the Carson and Santa Fe National Forests to augment their incomes or for self-sufficiency. Special forest products and small commercial ventures contribute toward household livelihoods in northern New Mexico. These communities have established a cultural value of stewardship through many generations of interactions with the natural resources in the area. Quite often it is imperative for these residents to have a hands-on relationship with the forest that has sustained them for generations, as it is part of their cultural identity. These communities maintain a certain degree of self- sufficiency by meeting many of their own needs through self, family, and friends. Sustainability of the land and its resources is a common need.
The primary influences on the local economy are recreation and tourism (service sector), and agriculture (ranching, small produce farming, and miscellaneous forest products). Many of the residents commute to larger commercial centers for employment opportunities in manufacturing, construction, retail, and government sectors.
Environmental Consequences to Low Income and Minority Populations Direct and Indirect Effects to Human Health When determining whether human health effects are disproportionately high or adverse, the Council on Environmental Quality instructs agencies to consider the following three factors to the extent practicable (CEQ 1997):
(a) Whether the health effects, which may be measured in risks and rates, are significant (as employed by NEPA), or above generally accepted norms. Adverse health effects may include bodily impairment, infirmity, illness, or death; and
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(b) Whether the risk or rate of hazard exposure by a minority population, low-income population, or Indian tribe to an environmental hazard is significant (as employed by NEPA) and appreciably exceeds or is likely to appreciably exceed the risk or rate to the general population or other appropriate comparison group; and
(c) Whether health effects occur in a minority population, low-income population, or Indian tribe affected by cumulative or multiple adverse exposures from environmental hazards.
Alternative A Under the no-action alternative, no weed treatments would occur; thus, there would be no human health effects to any population in the analysis area.
Alternatives B and D There would not be a disproportionately high and adverse effect on minority or low-income populations under these alternatives. Because of the design features listed in Table S-11 when using herbicides, the risks of exposure to the general public would be negligible. The minority and low-income populations, being tied to the land and tending to use the land for economic benefit and subsistence uses, could have a higher rate of exposure than the general population. An actual exposure to hazardous chemicals, however, is highly unlikely because of the design features listed in Table S-11.
For example: • The Forest Service will provide public information about using herbicides, including the herbicide to be used, locations, and application schedules using signs, public notices, and other means. • Treatments will be coordinated with range allotment permittees. • In areas used by people (human habitation, recreational sites, traditional plant collections), only herbicides rated as having the lowest risk of harmful effects to humans would be allowed.
Alternative C–No Herbicides There would not be a disproportionately high and adverse effect on minority or low-income populations under this alternative because no herbicides would be used.
Cumulative Effects to Low-Income and Minority Populations None of the alternatives would cause a disproportionately high and adverse effect on minority or low-income populations; therefore, there would be no cumulative effects.
Affected Environment for Human Health and Safety The issue analyzed here is “Weed treatment activities have the potential to affect human health and safety in a number of ways, including exposure to machinery, equipment, or chemicals. Although exposure to machinery and equipment poses a safety risk, the larger public concern relates to the health risk posed by using herbicides. This risk is defined three ways: 1. By direct exposure during application. 2. By contact with vegetation that has been sprayed and then collected for use. 3. By direct or indirect exposure for people with heightened chemical sensitivities.”
Measures • Risk of exposure by application method • Potential length of exposure
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• Potential routes of exposure • Toxicity of herbicides proposed for use
Rationale Inherent to having confidence in the conclusions in this section is an understanding of what a reference dose is, how safe it is, and how it is determined. The U.S. Environmental Protection Agency develops reference doses for chemicals, including the herbicides proposed for use by the Forest Service. A reference dose is defined by the Environmental Protection Agency (1989) as an estimate of a daily dose over a 70-year life span a human can receive without an appreciable risk of deleterious effects. A reference dose is determined by subjecting animals to substances and determining the lowest observable effect level and the no observable effect level from the entire body of scientifically supportable studies performed for that substance. The no observable effect level represents the dose the Environmental Protection Agency believes would not result in an effect. Reference doses are calculated by dividing the no observable effect level, a level or dose already thought to not cause an effect, by a safety factor, usually 100, to account for extrapolation of animal data to humans and sensitive individuals. Therefore, the reference dose for a chemical is a dose at least 100 times lower than that shown to have an effect in any animal study performed with the subject chemical.
Toxicological studies using animals typically involve a purposeful exposure to dosages high enough to cause an effect. The causal dose in toxicological studies is significantly greater than what a worker would be exposed to while applying herbicides or what the public may be exposed to walking through a treated field or living adjacent to treated land. Herbicide applicators and the general public are clothed and do not purposely ingest herbicides under the same conditions as animals in studies of toxicological significance.
Assumptions • Workers applying herbicides are at a higher risk of exposure than the general public because they will be in more regular contact with herbicides. The maximum duration of exposure for workers on a yearly basis was estimated in the range of 10 to 40 days for commercial applicators (U.S. EPA 1995). This is far less than that used to establish reference doses, which assumes a daily exposure for 70 years. • Workers will follow the instructions, application rates, and safety precautions on the labels of the herbicide. • The public will avoid areas being treated with herbicides due to the Forest Service’s notification procedures (Table S-10 and Table S-11), such as signs and posting on the national forest websites. • Safe re-entry in areas where herbicides have been applied is when the herbicide has dried on the leaf surface. • The mitigations built into the project will prevent people from ingesting herbicides (Table S-11, rows 2, 10-14, 54-55, 58). • Chemically-sensitive individuals are generally aware of their sensitivities and would not be allowed to work on herbicide crews. They would not enter treated areas until either safe re-entry periods or a period they feel is adequate based on their personal knowledge of their sensitivity, has passed. ♦ A small percentage of the population has a hypersensitivity to a wide variety of chemicals, including perfumes, household cleaners, construction products, industrial chemicals, and the herbicides proposed for use in this project (Gibson 2000, Barrett and Gots 1998). A 1997 New Mexico behavioral risk factor survey completed by the New Mexico Department of Health’s Office of Epidemiology indicated 2 to 3 percent of those responding to the survey instrument were chemically sensitive, with up to 16 percent of the New Mexico population possibly sensitive (Vorhees 1997). ♦ It is unknown what percent of this population frequents the Carson and Santa Fe National Forests.
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Methods For a negative effect to human health to occur from an herbicide, a person must be exposed to it. The risk of exposure from herbicides was analyzed by reviewing the following scientific literature: • “The Risk Assessment for Herbicide Use in Forest Service Regions (RAHUFS) 1, 2, 3, 4 and 10 and on Bonneville Power Administration Sites” (USDA Forest Service 1992). This analysis was developed for the Forest Service specifically to address human health issues raised by the use of herbicides. • “Assessing the Safety of Herbicides for Vegetation Management in the Missoula Valley Region: A Question and Answer Guide to Human Health Issues” (Felsot 2001). • Risk assessments completed by the Forest Service under contract with Syracuse Environmental Research Associates for the chemicals proposed for use: 2,4-D, aminopyralid, picloram, clopyralid, dicamba, hexazinone, sulfometuron methyl, metsulfuron methyl, triclopyr, imazapic, and imazapyr (USDA Forest Service 1995d, 1996c, 1996d, 1997c, 1998b, 1998c, 1999b-d, 2002, 2001; SERA 2002-2007). The risk assessments consist of three things: (1) a review of toxicity test data (acute, chronic, and subchronic) for the herbicides to determine dosage that could pose a risk to human health; (2) an estimate of exposure levels to which workers and the general public could be exposed during treatment operations; and (3) comparison of dose levels to toxicological thresholds developed by the Environmental Protection Agency to determine potential health risks.
The Forest Service has developed additional protection measures, found in Table S-10 and Table S-11, to further reduce the risk of exposure. The end result is the Forest Service’s application of herbicides exceeds the safety requirements and mitigations required by the Environmental Protection Agency.
Results Method of Application The risk assessments compared risks of exposure to workers from backpack, ground-mechanical, and hand application.
The drift that can occur when spraying herbicides is a way people can become unintentionally exposed. Spray drift is when the herbicide is picked up by wind after leaving the nozzle and carried away from the intended treatment area. Spray drift is primarily a function of droplet size, release height, and wind speed (Teske and Thistle 1999).
Wind speed increases the number of droplets leaving the treated area if the wind is blowing away from the release point. If the wind is favorable (blowing into the treatment area), drift is reduced. Studies have shown over 90 percent of droplets land in the target area, 10 percent or less move off-target, and the droplets that move off-target most typically deposit within 100 feet of the target area (Felsot 2001, Yates et al. 1978, Robinson and Fox 1978, Teske and Thistle 1999).
Length of Exposure The magnitude of a hazardous dose comes in three forms: (1) a single dose occurring at once (acute exposure); (2) multiple doses over longer periods (chronic exposure); or, (3) regularly repeated doses over periods ranging from several days to months (subchronic exposure). As described in the “Rationale” section, the Environmental Protection Agency describes exposure in terms of reference doses to determine potential hazards of herbicides to humans.
The reference dose for each herbicide in this project serves as a conservative toxicological threshold for two reasons. First, the reference dose assumes daily exposure over 70 years. Second, the reference dose is calculated from the no observed effect level that assumes humans are 100 times more sensitive than animals.
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Route of Exposure Ingestion
Another measure for toxicity is LD50 (where LD stands for “lethal dose”). LD50 levels exist for oral, dermal, and inhalation exposure. LD50 is the dose that kills 50 percent of a test population, measured in one milligram of herbicide per kilogram of animal weight (U.S. EPA 1996a, 1996b). To arrive at LD50s in a laboratory setting, high doses of herbicides are given to animals orally, dermally, or by inhalation (U.S. EPA 1996c). These doses are much higher, by orders of magnitude, than any worker or member of the public would be exposed to during this project. Ingestion is the least likely route of exposure; the design features discouraging people (Table S-11, rows 2, 10-14, 54-55, 58) from going into areas while an herbicide is still wet means the public will have no chance of exposure, even if collecting plants. Since people are not likely to ingest herbicides, there will be no effect from ingestion. Therefore, this route of exposure will not be discussed further.
Dermal Absorption Studies show that human skin acts as a protective barrier that limits the amount of a chemical that passes into the body; only about 10 percent or less of the chemical passes through the skin to the bloodstream. In contrast, absorption of chemicals from the small intestine (oral ingestion) is quicker and more complete than from the skin (Ross et al. 2000). For this reason, a dermal LD50 is usually much higher than an oral LD50. This means that a person can tolerate greater doses of a substance without becoming sick when exposure is through skin contact rather than through ingestion (Hayes 1991).
Inhalation Inhalation of chemicals causes illness more quickly than by oral or dermal contact due to the rapid entry of the substance into the blood stream. Studies of pesticide applicators, however, show dermal exposures are greater than inhalation exposures (Ross et al. 2000).
Toxicity of Herbicides A comparison of toxicity for the herbicides proposed for use is shown in Table S-64.
Endocrine Disruption Chemicals can interact with components of the endocrine system. Scientists have discovered that many kinds of chemicals, including natural food biochemicals as well as industrial chemicals and a few pesticides, can mimic the action of the hormones estrogen or testosterone. Concern has also been expressed about potential effects on the thyroid hormone during early development (Felsot 2001).
Environmental Consequences to Human Health and Safety Effects from prescribed burning are analyzed in the “Air Quality” section of this report.
Direct and Indirect Effects of Alternative A There would be no impacts to human health and safety from any proposed treatment because treatments would not occur.
The effect of continued weed spread on human health, such as allergies, would remain; however, this effect is likely very small given the size of the weed populations in relation to the project area. Known weed populations occupy approximately 0.5 percent of the 3 million acres in the project area. People suffering from allergies are far more likely to be affected by juniper pollen, for example, since juniper trees are common in the national forests. Nonetheless, approximately 10 to 15 percent of the United States population suffers from allergy symptoms from weed species such as knapweed. Knapweed pollen is a common and powerful allergen that peaks in August and produces strong allergy symptoms. Knapweed pollen has been implicated in causing
159 Invasive Plant Control Project allergic rhinitis (Gillespie and Hedstrom 1979). Allergies to airborne seeds may also complicate or trigger asthma that may take up to 2 years to get completely under control.
Table S-64. Comparison of the toxicity of herbicides proposed for use Estimated Estimated Reference Acute Oral Carcino- Exposure Exposure to Dose Mutagenic and LD50 for Rats Herbicide genic1 to Public2 Worker2 (mg/kg/day) Reproductive3 (mg/kg/day) Aminopyralid E < RfD < RfD 0.5 No > 5,000 2,4-D D < RfD < RfD8 0.01 No 100 - 1,800 Chlorsulfuron E < RfD < RfD 0.05 No > 5,000 Clopyralid E < RfD < RfD 0.5 No 2,675 - 5,000 Dicamba D < RfD < RfD 0.03 No 757 - 1,701 Glyphosate E < RfD < RfD 0.1 No 2,000-6,000 Hexazinone D < RfD below to slightly 0.03/0.054 No 1,690 above RfD7 Imazapic E < RfD < RfD 0.05 No 5,000 Imazapyr E < RfD < RfD 2.55 No > 5,000 Metsulfuron E < RfD < RfD 0.25 No to slight > 5,000 methyl Picloram E < RfD < RfD6 0.2 No 3,000-5,000 Sulfometuron E < RfD < RfD 0.025 No > 5,000 methyl Triclopyr E < RfD < RfD 0.005 No to slight 630 - 729 RfD = Reference dose; units expressed as milligrams of herbicide per kilogram of body weight LD50 = lethal dose in milligrams of herbicide per kilogram of body weight 1. Environmental Protection Agency carcinogenicity classification based on daily consumption for 70 years. D = Not classifiable as to human carcinogenicity; E = Evidence of non-carcinogenicity 2. Exposures under typical exposure scenarios. Accidental and extreme exposure scenarios may exceed the reference dose. 3. Unlikely the compound is mutagenic or would pose a mutagenic risk to humans at expected exposure levels. 4. Two reference doses reported. 5. Provisional reference dose, the Environmental Protection Agency has not derived a reference dose for this compound. 6. USFS (1999b) reports workers wearing contaminated glove may receive an absorbed dose greater than the reference dose. The design features in Chapter 2 would prevent this scenario from occurring. 7. USDA Forest Service (1997a) reports over a range of plausible application rates, workers may be exposed to hexazinone at levels that exceed the reference dose. 8. USDA Forest Service (1998) reports workers involved in ground application of 2,4-D may be exposed to levels above the reference dose if effective methods to protect workers and minimize exposure are not employed. The design features in chapter 2 would prevent this scenario from occurring.
Cumulative Effects of Alternative A The effect on human health under this alternative is aggravated allergies. This risk is considered too small to be measurable; thus, there would be no cumulative effects from the no-action alternative.
Direct and Indirect Effects of Alternatives B and C Biological Treatments Biological treatments would result in no known risks to human health because the biological control method is designed to target specific plants. No health effects to people have been documented from this method.
Managed Grazing Managed grazing would result in no known risks to human health and safety. Humans have grazed livestock in the national forests for over 100 years without any documented, significant health effects.
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Manual Treatments Risks to worker’s health from manual methods are considered minor. The use of personal protective equipment like gloves, long sleeved shirts, and boots would prevent most skin irritations (such as cuts or blisters) from occurring. Rarer conditions can be triggered; for example, leafy spurge contains a latex-bearing sap that irritates human skin and may (rarely) cause blindness in humans upon contact with the eye (Callihan et al. 1991). There have also been claims (not medically supported) that hand-pulling knapweed may result in the formation of tumors on the hands. The risk of injury from repetitive motion and back and knee strain exists but would be no greater than any other physical labor normally performed by Forest Service employees. Workers with allergies to weeds would suffer the most from this method.
Because the public would not be treating weeds, there would be no effects from manual methods.
Mechanical Treatments Potential risks to human health from mechanical weed control methods are considered low. Mechanical methods, such as mowing or root tilling, are commonly used throughout the world. As a result, the mitigations to lesson risk (such as wearing hard hats, safety glasses, and ear protection) are well established and proven to work. A risk of physical injury due to accidents exists.
Because the public would not be treating weeds and would not be permitted entry when heavy equipment is operating, there would be no effects from mechanical methods.
Direct and Indirect Effects of Alternatives B and D
Herbicides Method of Application Since the public will not be applying herbicides, their risk of exposure by any application method proposed in this project is zero.
Following the design features requiring the use of personal protective equipment, application rates, and the weather conditions means that a worker’s risk of exposure to herbicides would be negligible. The risk assessments prepared for this project show that ground-mechanical application resulted in a lower risk of exposure than other methods, even though the total amount of herbicide applied in a given day was higher. Risks from backpack and hand application have the highest risk of exposure because workers are closer to the nozzle and to the containers from which the herbicides are sprayed. Backpack and hand application were also reported to increase the likelihood of a worker receiving repeated exposures that may remain on the worker's skin for an extended time period. Training in the application of herbicides and use of appropriate personal protective equipment will minimize this risk.
Drift – Because the public would stay out of or be restricted from entering areas during herbicide application, no exposure to spray drift would occur. Further, the spray drift analysis (see page 158) shows the risk of exposure to the public from ground methods is low (USDA Forest Service 1992). The study defines low risk as less than one-in-a-million chance of developing systemic problems, reproductive problems, or cancer.
The risk of exposure to workers from drift would be less than the Environmental Protection Agency’s reference dose. Felsot (2001) used a model called AGDRIFT I to simulate herbicide sprays for several scenarios, including a truck mounted spray boom set at two heights. His study showed that a child (who would be more susceptible to harm because of lower body weight) standing 27 feet from the sprayed edge would not receive a dose greater than the Environmental Protection Agency’s reference dose.
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Length of Exposure Acute Toxicity – The exposure to the public or workers to herbicides would be far less than the Environmental Protection Agency’s reference dose. Where the reference dose assumes a daily exposure for 70 years, workers (who would have more exposure than the public) would be exposed 10 to 40 days per year. Thus, the risk of acute exposure is zero for either workers or the general public. This conclusion is supported by various studies estimating the exposure to workers and the public under scenarios more conservative that what would actually occur in this project (USDA Forest Service 1995; 1996a; 1997a-c; 1998; 1998d; 1999c; 1999d; 2000; 2001). The most reasonable interpretation of the risks associated with application of herbicides on national forest lands is that, except for accidental exposures or extremely atypical or implausible scenarios (that is, acute direct spray entirely covering a naked child), use of herbicides on National Forest System lands would not pose an identifiable risk to workers or the general public.
Subchronic and Chronic Toxicity – The likelihood of chronic or subchronic exposure to the public to herbicides is zero, based on the assumption that the public would avoid, or be restricted from, entering places where herbicides are being applied. The likelihood of a member of the public being repeatedly exposed to herbicides above the reference dose is nearly zero.
Workers, who are expected to apply herbicides for 10 to 40 days per year for up to 10 years, would still have an exposure less than the Environmental Protection Agency’s reference dose (daily exposure for 70 years). The mitigations built into this project would further reduce a worker’s risk of exposure. As noted in Table S- 64, two exceptions exist. A Forest Service research project (1997d) reports that over a range of plausible application rates, workers may be exposed to hexazinone at levels that exceed the reference dose. Likewise, there is reasonable concern that workers applying triclopyr over a prolonged period of time in the course of a single season and/or several seasons may be at risk of impaired kidney function (USDA Forest Service 1996d).
Route of Exposure Dermal Absorption – The likelihood of a member of the public absorbing an herbicide through their skin is virtually zero. The mitigations are designed to inform the public of treatments, or restrict them from entering treated areas until the herbicide is absorbed by the plant. The likelihood of a member of the public being repeatedly exposed to herbicides through their skin above the reference dose is nearly zero.
Required personal protective equipment used by workers during pesticide application (gloves, waterproof boots, etc.) is designed to reduce exposure to sensitive areas on the body. Use of personal protective equipment is required by the Forest Service and would reduce the chance of dermal absorption. The use of personal protective equipment, combined with the fact that workers would be exposed only 10 to 40 days per year, means a worker’s exposure would be less than the LD50.
Inhalation – Studies show the risk of dermal exposure is higher than the risk of inhalation. Since the risk of dermal exposure is below the LD50, the risk of inhalation would be as well.
Toxicity of Herbicides Controlled studies suggest nearly all of the herbicides proposed for use by the Forest Service are not carcinogenic. Recently, the International Agency for Research on Cancer of the World Health Organization has designated glyphosate as a “probable” carcinogen. However, the Environmental Protection Agency has not endorsed this designation through the risk assessment process as of the date of this document. Further, no evidence exists showing the herbicides proposed for use would result in carcinogenic, mutagenic, teratogenic, neurological or reproductive effects based on anticipated exposure levels to workers and the public (Arbuckle 1999; Charles et al. 1996; Paustini 1996; Ibrahim, et al. 1991; Mattsson 1997; Mustonen 1986; Infoventures 1995a-j; OSU 1996a-h; U.S. EPA 1990 and 1990a; USDA Forest Service 1995, 1996a, 1997a, 1997c, 1998, 1998d, 1999c-d, 2000, 2001, 2001b; SERA 2002 - 2007).
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With respect to herbicides proposed in this project, it has been estimated in nearly all cases the dose a worker or a person from the public would be exposed to would be below the reference dose.
This conclusion excludes accidental spills and implausible exposure scenarios (spray over entire naked body or wearing heavily contaminated gloves for an extended period).
Synergistic Interactions – Concerns are occasionally raised about potential synergistic interactions of herbicides with other herbicides in the environment or when they are mixed during application. No one can guarantee the absence of a synergistic interaction between herbicides and/or other chemicals to which workers or the public might be exposed. For example, exposure to benzene, a known carcinogen that comprises 1 to 5 percent of automobile fuel and 2.5 percent of automobile exhaust, followed by exposure to any of these herbicides could result in unexpected biochemical interactions (USDA Forest Service 1997b). Analysis of the infinite number of materials a person may ingest or be exposed to in combination with the herbicides proposed here is outside the scope of this analysis; however, because the risk of exposure to the public is nearly zero to begin with, the chance of a synergistic interaction from this project is also very low.
Impurities and Inert Ingredients in Herbicide Formulations – During commercial synthesis of some pesticides, byproducts can be produced and transferred into the product eventually formulated for sale. Occasionally, byproducts or impurities are considered toxicologically hazardous, and their concentrations must be limited so potential exposures do not exceed levels of concern (Felsot 2001). The byproducts raised as points of concern are hexachlorobenzene, dioxins (especially tetrachlorodibenzo-p-dioxin), inert ingredients, dyes, and surfactants. The effects of each are summarized here; a more detailed examination exists in the project record.
Hexachlorobenzene The use of clopyralid or picloram in accordance with the label would not result in increases in the general exposure of either workers or members of the general public to hexachlorobenzene. The central estimates of worker exposure to hexachlorobenzene under normal conditions were estimated to be lower than the background levels of exposure by factors of about 1,000.
Dioxins (especially tetrachlorodibenzo-p-dioxin) Current quality control procedures during manufacturing have essentially eliminated any dioxin congeners of concern from domestic 2,4-D formulations. Thus, use of 2,4-D products manufactured in the United States, whether at home or in the national forests, does not contaminate the environment with the dioxin of greatest regulatory concern, tetrachlorodibenzo-p-dioxin (U.S. EPA 2000, chapter 8 of the Draft Dioxin Assessment).
Inert Ingredients The proprietary nature of herbicide formulations limits the understanding of the risks posed by inert ingredients in herbicide formulations. Studies on the toxicity of technical grade formulations, which often contain the inert ingredients, account for the toxicity of the inert ingredients, and as has been reported here, these studies show the use of herbicides by the Forest Service would not expose workers or the public to levels of concern.
Dyes Limited information is available on the toxicity of the majority of dyes used in the industry. There has been considerable concern over the carcinogenic potential of less used dyes Rhodamine B and Basic Violet 3. The Forest Service completed a risk assessment of Rhodamine B and Basic Violet 3. It estimated the excess cancer risk for Rhodamine B, assuming a lifetime of occupational exposure, was extremely low (USDA Forest Service 1997e). The excess cancer risk for Basic Violet 3 was estimated to be about twice that of Rhodamine B. Both estimates suggest use of these dyes does not pose an unacceptable health risk.
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Surfactants Like dyes and other inert ingredients, there is often limited information on the types of surfactants used and the toxicity of surfactants, especially since the industry considers the surfactant to play a key role in the effectiveness of the herbicide formulations. Most knowledge of surfactants is kept as proprietary information and not disclosed. This is not always the case. The Forest Service (1997c), which attempted to assess the effects of surfactant formulations on the toxicity of glyphosate, reported the toxicity of glyphosate alone was about the same as the toxicity of the glyphosate and surfactant mixed and greater than the toxicity of the surfactants alone. Whether this same pattern would hold true of other herbicides having the same or different surfactants is unknown. If so, the toxicological studies performed on herbicide formulations (which contain the inert ingredients and surfactants) may accurately portray the toxicity and risks posed to humans by the surfactant.
Endocrine Disruption In the live animal studies to date, only a handful of chemicals, including natural food biochemicals, a few pesticides, and several industrial chemicals show endocrine disrupting effects (Felsot 2001). With one exception, the drug diethylstilbestrol, any effects observed were in tests with doses at least thousands of times greater than environmental or dietary concentrations.
In virtually all published cases where a series of doses are tested, endocrine effects did not occur below some threshold dose (U.S. EPA 1997a). The Environmental Protection Agency (1997a) concluded, with few exceptions (for example, diethylstilbestrol), a causal relationship between exposure to a specific environmental agent and an adverse effect on human health via an endocrine disruption has not been established.
Uncertainty With the exception of accidental exposures, workers and the general public would not be exposed to any herbicides at concentrations that result in an adverse health effects. This conclusion is predicated on Forest Service employees wearing appropriate personal protective equipment, applying herbicides in accordance with the label, and implementing the job hazard analysis as prescribed for this project (chapter 2). By doing so, possible exposure by contact or through drift would result in a potential dose below that determined to be safe by the Environmental Protection Agency over a lifetime of daily exposure. It is also predicated on the findings, backed by toxicological studies, that a person can be exposed to some amount of a contaminant and not have an adverse effect (the dose determines the effect).
Comparison of Alternatives B, C, and D Alternative C, which proposes no herbicide use, would have no effects to human health from herbicides. It would, however, have the highest risk of physical injury (such as slips, trips, strains, and falls). Nonetheless, the risk of physical injury is considered to be low and no greater than from other Forest Service activities.
Alternative D would have the highest risk of accidental spills of herbicides, since herbicide use is the only method proposed. More time spent mixing and applying herbicides increases the risk of a spill. The public may be exposed to a spill should the herbicide reach surface or groundwater. The indirect effects of a spill would be commensurate with the proximity of the spill area to the public and public exposure pathways. In terms of effects to human health and safety from routine application of herbicides without spills, the discussion above shows the risk is expected to be low, meaning it would be lower than the exposures shown by the Environmental Protection Agency to cause health effects. We also recognize, in the discussion of uncertainty, there cannot be a 100 percent guarantee of no effect.
Alternative B contains the same risks described in alternatives C and D, but at lower levels.
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Cumulative Effects of Alternatives B, C, and D The spatial “boundary” of the effects considered here is an individual. The temporal boundary is from the start of this project for 10 years, anticipated to be from 2017 through 2027. This is the period of time during which the Forest Service anticipates having controlled or eliminated its known weed populations. Table S-65 displays the cumulative effects to human health and safety.
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Table S-65. Cumulative effects to human health and safety Method of Actions that Cumulatively Contribute to treatment Direct and Indirect Effects the Direct and Indirect Effect Cumulative Effect Biological No measurable effect to workers Not applicable Since there is no direct or indirect effect from or the public biological methods to human health and safety, there would be no cumulative effect. Controlled grazing No measurable effect to workers Not applicable Since there is no direct or indirect effect from or the public grazing to human health and safety, there would be no cumulative effect. Manual Risk of slips, trips, sprains, and Trail construction and maintenance A cumulative effect to overall physical health (in falls to workers. Construction and reconstruction of facilities terms of flexibility and soundness) is possible if the Suppression and rehabilitation of wildfires same workers conduct multiple projects, as is often the case with Forest Service employees. Hazardous fuels treatment Prescribed burning Other projects involving physical work Mechanical Risk of physical injury, primarily Road construction and maintenance Forest Service employees experiencing moderate due to accidents, to workers Trail construction and maintenance or severe injuries due to accidents are put on “light Construction and reconstruction of facilities duty” and would not continue with the physical activities until they were well. Thus, there would be Suppression and rehabilitation of wildfires no cumulative effects. Hazardous fuels treatment A cumulative effect to overall physical health (in Prescribed burning terms of flexibility and soundness) is possible if the Other projects involving physical work same workers conduct multiple projects, as is often Other projects involving heavy equipment the case with Forest Service employees. Herbicides Method of No effects to the public since Not applicable Since there is no direct or indirect effect to the application they would not be applying public, there would be no cumulative effects. herbicides. The risk of an effect to health to a worker is small Risk of exposure to workers enough to be immeasurable; therefore, there exists (dermal contact has the would be no cumulative effects. highest likelihood of resulting in exposure); however, it would be well below Environmental Protection Agency’s reference dose.
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Method of Actions that Cumulatively Contribute to treatment Direct and Indirect Effects the Direct and Indirect Effect Cumulative Effect Length of exposure The use of herbicides on Not applicable The risk of health effects to a worker or the public National Forest System lands is small enough to be immeasurable; therefore, would not pose an identifiable there would be no cumulative effects. risk to workers or the general public, either for acute, sub- chronic, or chronic toxicity. In all cases, the likely exposure would be far less than Environmental Protection Agency’s reference dose. Route of exposure The amount of dermal exposure Not applicable The risk of health effects to a worker or the public expected for workers would be is small enough to be immeasurable; therefore, less than the LD50 and would be there would be no cumulative effects. negligible. Inhalation would be even less. No risk of dermal exposure to the public. Very low risk of inhalation exposure for the public. Toxicity of Studies suggest the herbicides Not applicable Since the herbicides themselves are not expected herbicides proposed for use by the Forest to cause health effects, there would be no Service are not carcinogenic cumulative effects. and do not cause other health effects. Synergistic There would be a risk of There is no way to compile a complete list due A cumulative effect exists but cannot be quantified interactions synergistic interactions that to the sheer number of chemical that exist in due to the unknown exposures that an individual is would cause negative effects to society today. Examples are gasoline, subject to in their daily routine. human health. Studies covering household cleaning products, construction the effects of exposure to the materials, cigarette smoke, etc. infinite combinations of chemicals that exist in society do not exist. Hexachlorobenzene The use of clopyralid or Not applicable Since there would be no increase in exposure to picloram in accordance with the hexachlorobenzene, there would be no direct or label would not result in indirect effect to human health; thus, there would increases in the general be no cumulative effects. exposure of either workers or members of the general public to hexachlorobenzene.
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Method of Actions that Cumulatively Contribute to treatment Direct and Indirect Effects the Direct and Indirect Effect Cumulative Effect Tetrachlorodibenzo- The use of 2,4-D products Not applicable Since there would be no direct or indirect effects to p-dioxin manufactured in the United human health from tetrachlorodibenzo-p-dioxin, States do not contaminate the there would be no cumulative effects. environment with tetrachlorodibenzo-p-dioxin. Thus, there would be no human exposure to tetrachlorodibenzo- p-dioxin from this project. Inert ingredients Studies on the toxicity of Not applicable Since there would be no direct or indirect effects to technical grade formulations, human health from the inert ingredients contained which often contain the inert in the herbicides proposed for use in this project, ingredients, account for the there would be no cumulative effects. toxicity of the inert ingredients, and these studies show the use of herbicides by the Forest Service would not expose workers or the public to levels of concern. Dyes Use of dyes does not pose an Not applicable Since there would be no direct or indirect effects to unacceptable health risk in the human health from the dyes contained in the context of this project, which herbicides proposed for use in this project, there would not entail a lifetime of would be no cumulative effects. application. Surfactants A risk to human health may There is no way to compile a complete list of A cumulative effect exists, but cannot be quantified exist from the surfactants products that contain surfactants to which an due to the unknown exposures that an individual is contained in herbicides, but this individual would be exposed during the same subject to in their daily routine. risk has not been studied and timeframe of this analysis. Too many of them quantified. Most information on exist, and it is not possible to identify the daily surfactants is proprietary and habits and exposures of the workers not disclosed. Endocrine No causal relationship between Not applicable Since there would be no direct or indirect effects to disruption exposure to a specific herbicide the endocrine system from the herbicides and an adverse effect the proposed for use in this project, there would be no endocrine system has been cumulative effects. established.
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Cost-Benefit Analysis The issue analyzed in this section is: “On weed infestation sites where nonchemical methods are proposed for use without supplemental herbicides, weed control effectiveness would be lower and treatment costs higher.”
Measure Economic efficiency is measured in present net value.
Rationale Present net value is a common and widely accepted measure of economic efficiency for all kinds of projects.
Assumptions • This is not an exhaustive economic determination, but rather an estimate of economic efficiency. Some values are unknown, others are difficult to determine, and still others are dependent on the quality of the data provided. • Estimates from employees are used for local costs such as fence building. • The workforce used to treat weeds, either contracted or Forest Service employees, would not exceed 30 individuals on a part time or temporary basis. • Only costs and benefits contained in published Forest Service documents that relate directly to this project are included. • Sunk costs are not part of the analysis. • Nonmarket or indirect values such as detoxification and decomposition of toxic waste or potential property value changes are not used in the Quicksilver economic estimations (State of the Southern Rockies - San Juan-Sangre de Cristo Bioregion, 1998).
Methods Quicksilver, a public domain computer program, was used to model the economic efficiency of the alternatives. This program estimates present net value based on costs and benefits of the treatments contained in each alternative.
Results Present net value shows whether an investment will be profitable. It measures present cash outflow to projected inflows over the life of the project. For this analysis, it is used to show the relative benefit among alternatives, not their exact cost. The project record contains the estimated costs of various treatments used in the model.
In business, a negative value means that a project would not go forward because it would lose money, and that the result for the money spent would not be economical. This concept does not completely apply to forest management, because there is no projected cash inflow as a result of doing the project. However, using present net value shows the relative cost of the alternatives.
Alternative A (no action) has a negative value because Forest Service staff will continue to monitor known and new weed populations. An additional cost associated with the no-action alternative (not included in the present net value calculation) is that of performing National Environmental Policy Act analyses to treat individual weed infestations. The other three alternatives, B, C, and D, include the cost of treating and monitoring known and new weed infestations over time.
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Table S-66. Present net value (rounded to nearest dollar) of the alternatives Alternative A Alternative B Alternative C Alternative D (No Action) (Proposed Action) (No Herbicides) (Herbicides Only) -4,324 -99,325 -92,956 36,963 Source: Quicksilver analysis
Alternative D appears to be the most cost effective because the use of herbicides has been demonstrated to be more effective at controlling and eliminating weeds than other methods, so fewer treatments would be required. Using herbicides would also require fewer personnel.
The proposed action appears to be the most expensive because it encompasses all the methods of treatment. The present net values show that non-herbicidal methods are likely to cost more than herbicides. Frid et al. (2013) found that strategies that prioritize targeting small, new infestations consistently outperform strategies that target large, established patches.
Effects of Forest Plan Amendment to Social and Economic Resources The proposed plan amendment limits herbicide use to “when determined through an environmental analysis to have no long-term adverse environmental, economic, or social impacts.” This modified language would be more clearly and consistently interpreted than the vague original language. The modified language would also provide for greater consistency with environmental analysis requirements under the National Environmental Policy Act, which is appropriately based on estimated impacts rather than on the “acceptability” of a proposed action.
Environmental Justice The proposed plan amendment would have no effect on environmental justice in future projects. The amendment would allow chemical treatments “when determined through an environmental analysis to have no adverse environmental, economic, or social impacts for longer than 6 months.” First, this restriction applies to all areas equally and does not favor any specific group. Second, an analysis of environmental justice would be applied for individual projects. The design features and mitigations listed in the amendment would protect low-income and minority populations during herbicide use in future projects.
Human Health and Safety The design features listed in the amendment would protect people during herbicide use in future projects.
Cost-Benefit The proposed plan amendment is likely to increase the cost of future projects that use herbicides by requiring an analysis of effects up to 6 months, and monitoring for whether soils are within the standards listed.
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Consistency with Forest Plan, Laws, and Policies [New paragraph] All alternatives are consistent with Environmental Protection Agency, Occupational Safety and Health Administration, and Forest Service regulations for herbicide use and worker safety. An amendment to the Santa Fe National Forest Plan has been proposed; otherwise, this project is consistent with the Carson and Santa Fe Nation Forest Plans.
Other Required Disclosures Short-term Uses and Long-term Productivity [No change from final environmental impact statement]
Unavoidable Adverse Effects [No change from final environmental impact statement]
Irreversible and Irretrievable Commitments of Resources [No change from final environmental impact statement]
Incomplete or Unavailable Information [New section] All of the herbicides proposed for use by the Forest Service must be registered for use by the Environmental Protection Agency and the New Mexico Department of Agriculture. Registration of these herbicides and Federal regulations adopted to protect workers and the general public have required more scientific information and justification for use of herbicides. Nevertheless, there are many reports in the scientific literature that document associations between herbicide exposure and alterations of the immune system, autoimmune disorders, and increases in the probability of carcinogenesis. Samsel (2013), Missoula City- County Health Board (2001), Citron (1995), Environmental Protection Agency (1995) Glover-Kerkvliet (1995) are just a few references that provide information on such effects. The body of literature on herbicide effects raises concerns about additive and synergistic effects of exposure to more than one herbicide, unstudied or unknown consequences of low-level chronic exposures, toxicity of inert ingredients, by-products or contaminants of herbicides, and uncertainties about the health effects of sensitive populations. There is also the realization that it is difficult, if not impossible, for government or any scientific agency to fully evaluate a chemical and all the potential combinations of them to ensure that there would not be an adverse effect.
It would be inappropriate to suggest that use of herbicides to control weeds is without risk to workers and the general public. If herbicides are used, there is the possibility of worker and general public exposure, no matter how many design features are implemented. All chemical exposure results in some level of health risk, the risk primarily being a function of the dose, or amount a person or organism is exposed to over a period of time.
It is equally inappropriate to conclude that any exposure, regardless of dose, would result in an effect. It is easy to find a report showing a health effect caused by the exposure to an herbicide or any other chemical. The toxicological studies are purposely done using high doses to demonstrate an effect. It is the herbicides that show effects at low levels of exposure or those levels anticipated when in use that should raise concern. With respect to this project, the potential dose received by the worker or member of the public does not approach the exposure levels shown by Forest Service risk assessments to cause acute, chronic, or subchronic toxicity. Acute effects occur at doses thousands to tens of thousands of times higher than those estimated for
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the worker or public for this project. Likewise, chronic effects reportedly occur at doses significantly higher than that expected for this project.
There are simply too many variables (receptor sensitivity, dose received, use of personal protection, and so forth) for anyone to predict with 100 percent certainty the potential health risk of herbicide use and exposure. What is known is that through a process of continual review of toxicological data on herbicides, the Environmental Protection Agency, using very conservative assumptions, has determined a dose they believe would not result in an adverse health effect for herbicides proposed for use on this project. Some studies show that exposure to the herbicides proposed for use at high doses can cause deleterious effects. The risk assessments, however, have been completed to determine the estimated dose a worker or person of the general public might be exposed to under varying exposure scenarios. Most important, we know through a comparison of Environmental Protection Agency-established safe doses and estimated exposures that the estimated dose that a worker or person of the general public may be exposed to through use of an herbicide on this project would be below that determined to be safe by the Environmental Protection Agency for a lifetime of daily exposure. Therefore, no health effects or risks to workers and the general public are anticipated by the use of herbicides for this project.
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Preparers and Contributors [Revised section] From 1999 to 2002, the Forest Service worked with a team of contractors to develop the first draft of the environmental impact statement. From 2003 to 2005, an expanded interdisciplinary team composed of Forest Service staff and contractors prepared the final environmental impact statement published in 2005. That team is listed on pages 185-186 of the 2005 final environmental impact statement. The following lists the Forest Service personnel who prepared this final supplemental environmental impact statement.
Education and Name Position Contribution Experience Julie Bain Forest NEPA Coordinator, Project leader, National MS Environmental Studies Santa Fe National Forest Environmental Policy 18 years’ experience Act compliance, editor of Vegetation and Livestock Grazing sections, writer Francisco Carson National Forest Wildlife, fisheries and BS Wildlife Biology Cortez Wildlife, Fish, Rare Plant aquatic resources 21 years’ experience Program Manager Jennifer Cramer Forest Planner, Santa Fe Forest plan amendment PhD Plant Biology National Forest 6 years’ experience Timothy GIS Specialist, Santa Fe GIS MS Natural Resource Downing National Forest Management 3 years’ experience Michael Frazier Staff Officer, Santa Fe Recreation, wilderness, BA Liberal Arts National Forest and visual resources BS Forestry 42 years’ experience Michael Gatlin Fisheries Biologist, Carson Fish and aquatic BS and MS, Fisheries and National Forest resources Aquatic Ecology and Management 5 years’ experience Antonio Griego Biological Technician, Project record and BS Biology Santa Fe National Forest mailing list management 3 years’ experience Josh Hall Air and Water Quality Air quality MS Environmental Specialist, New Mexico Science, MS Natural National Forests Resource Management and Environmental Policy 8.5 years’ experience Hillary Hudson GIS Specialist, Santa Fe GIS MS Environmental Science National Forest 15 years’ experience Allan Lemley GIS Coordinator, Carson GIS BS Geology/Physics National Forest 13 years’ experience Jason McInteer Assistant Forest Heritage resources MA Anthropology Archaeologist, Santa Fe 12 years’ experience National Forest Greg Miller Forest Soil Scientist, Soil and water BS Soil Science Carson National Forest 34 years’ experience Skip Miller Forest Archaeologist, Heritage resources MFA in Native American Carson National Forest Art History and Ceramics 34 years’ experience in Archaeology, cultural anthropology and museums
173 Invasive Plant Control Project
Education and Name Position Contribution Experience Mary Orr Wildlife Biologist Wildlife, fisheries and BS Biology Espanola and Coyote aquatic resources BS Wildlife Biology Ranger Districts 33 years’ experience Judy York Forest Service writer- Editing, publication, BS Wildlife Resources editor layout MS Natural Resources TEAMS Enterprise Unit Communications 25 years’ experience Sandra Imler- Forest NEPA Coordinator, Project Leader, National BS Natural Resources Jacquez Santa Fe National Forest Environmental Policy 10 years’ experience Act compliance, writer/editor MS = Master of Science degree, BS = Bachelor of Science degree, MA = Master of Arts degree, MFA = Master of Fine Arts degree, BA = Bachelor of Arts degree, PhD = Doctor of Philosophy degree.
Distribution of the Supplemental Environmental Impact Statement The draft supplemental environmental impact statement was distributed, or made electronically available, to over 200 individuals and groups who specifically requested a copy of the document or commented during public involvement opportunities. In addition, copies were sent (or in some cases made electronically available) to Federal agencies, federally recognized Tribes, State and local governments, and organizations that have requested to be involved in the development of this analysis. These entities include the U.S. Environmental Protection Agency, U.S. Army Corps of Engineers, U.S. Department of the Interior, Federal Highway Administration, Advisory Council on Historic Preservation, USDA National Agricultural Library, State wildlife and fisheries management agencies, Tribes, county commissions, and local community governments. Due to the number of people, agencies, and organizations, a complete listing has been omitted from this environmental impact statement, but is available upon request.
The final supplemental environmental impact statement was distributed, or made electronically available, to individuals and groups who commented during public involvement opportunities. In addition, copies were sent (or in some cases made electronically available) to Federal agencies, federally recognized Tribes, State and local governments, and organizations that have requested to be involved in the development of this analysis. These entities include the U.S. Environmental Protection Agency, U.S. Army Corps of Engineers, U.S. Department of the Interior, Federal Highway Administration, Advisory Council on Historic Preservation, USDA National Agricultural Library, State wildlife and fisheries management agencies, Tribes, county commissions, and local community governments. Due to the number of people, agencies, and organizations. An electronic copy was also made available on the project website (http://www.fs.usda.gov/project/?project=27249).
174 Final Supplemental Environmental Impact Statement
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Infoventures 1995g Hexazinone: pesticide fact sheet. Prepared for the U.S. Department of Agriculture Forest Service by Information Ventures, Inc. Available from the project record, Santa Fe National Forest, Santa Fe, New Mexico.
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Infoventures 1995j. Picloram: pesticide fact sheet. Prepared for the U.S. Department of Agriculture Forest Service by Information Ventures, Inc. Available from the project record, Santa Fe National Forest, Santa Fe, New Mexico.
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U.S. Environmental Protection Agency. 1995. Picloram, reregistration eligibility decision (RED). August 1995.
U.S. Environmental Protection Agency. 1996a. Health effects test guidelines OPPTS 870.1100: acute oral toxicity. EPA 712-C-96- 190, Washington, D.C. 1996a
U.S. Environmental Protection Agency 1996b. Health effects test guidelines OPPTS 870.4100: chronic toxicity. EPA 712-C-96-192; Washington, D.C. 1996b
U.S. Environmental Protection Agency. 2000. Draft dioxin assessment, Chapter 8. [cited for regulatory information only]
U.S. Environmental Protection Agency. 2014. National emissions inventory air pollutant emissions trends data. Online at http://www.epa.gov/ttnchie1/trends/.
Vorhees, Ronald E. 1997. Multiple chemical sensitivity questions from the 1997 behavioral risk factor survey. New Mexico Department of Health, Public Health Division, Office of Epidemiology. Santa Fe, NM.
183 Invasive Plant Control Project
Wardle, D. A., G. W. Yeates, K. I. Bonner, K. S. Nicholson, and R. N. Watson. 2001. Impacts of ground vegetation management strategies in a kiwifruit orchard on the composition and functioning of the soil biota (abstract). Soil Biology and Biochemistry 33: 893-905.
Yates, W., N. Akesson and D. Bayer. 1978. Drift of glyphosate sprays applied with aerial and ground equipment. Weed Science 26(6): 597-604.
184 Final Supplemental Environmental Impact Statement
Appendix 1. Past, Present, and Future Weed Control Activities [No change from the final environmental impact statement]
Appendix 2. Weed Species Ecology and Impacts [Remove Field Bindweed (Convolvulus arvensis) (COAR4)]
The abbreviation for saltcedar (Tamarix spp.) is TARA.
The abbreviation for spotted knapweed (Centaurea biebersteinii) is CESTM.
[Add the following three species]
Cheatgrass (Bromus tectorum) (BRTE)
This description comes from Utah State University11.
Cheatgrass was introduced to North America through contaminated grain seed, straw packing material, and soil used as ballast in ships sailing from Eurasia. This first occurred between 1850 and the late 1890s. During this time, overgrazing coupled with drought left many Great Basin rangelands in poor condition. Cheatgrass was able to occupy areas where the native vegetation had been reduced, beginning its persistent march across the landscape. It can now be found across the landscape from the bottoms of desert valleys to mountain peaks as high as 13,000 feet. The plant communities most affected by cheatgrass invasion are those below 6,000 feet in elevation. These include piñon/juniper woodlands, sagebrush, and salt-desert shrub community types.
As a winter annual, cheatgrass seeds germinate at low fall temperatures. Seedling roots continue to grow throughout the winter, and by spring, are capable of out-competing native species for water and nutrients because most native vegetation is just getting started. Cheatgrass completes its life cycle quickly and can become dry by mid-June.
Cheatgrass is a prolific seed producer, and large seedbanks can develop. It only takes a few plants in a sagebrush/perennial grass community to produce enough seeds to overwhelm native perennials in seedling-level competition.
Fuller’s Teasel (Dipsacus fullonum) (DIFU2)
This description is taken from southwestlearning.org and the USDA’s Fire Effects Information system, accessed on December 12, 2013. (Image courtesy of USDA PLANTS Database, USDA NRCS PLANTS Database, Bugwood.org.)
11 http://www.usu.edu/weeds/plant_species/weedspecies/cheatgrass.html
185 Invasive Plant Control Project
Fuller’s teasel is a biennial plant that grows a two- to eight-foot flowering stem. The flowers are very small and packed into dense, cone-shaped heads. Once the plant has flowered, it becomes woody and persists through the winter. It is currently found in most of the 50 states. Native to Europe and temperate Asia, teasel may have been introduced to North America as early as the 1700s. It was likely cultivated for its role in producing wool or as an ornamental. Its frequent use in dried flower arrangements may aid its dispersal; for example, it is often found in and near cemeteries.
It occupies sunny and open sites, such as riparian areas, meadows, grasslands, roadways, forest openings, and disturbed sites. It may not seriously reduce biodiversity, but it has the potential to become more of a problem. Although few studies indicate the methods by which teasel impacts its nonnative habitats, several studies report that teasel may develop large monocultures, negatively impact riparian area integrity, and occupy habitats important to sensitive or threatened plant species.
Although several researchers and land managers consider teasel a potentially invasive nonnative species, common teasel was not a high-priority species in a list ranking those species thought to seriously reduce biodiversity. Common teasel was listed number 80 in a prioritized list of 81 nonnative invasive species in natural Canadian habitats. However, several morphological and reproductive characteristics suggest teasel has the potential to be a problematic invasive species.
A review reports that teasel's thick, well-developed taproot allows for substantial nutrient and water storage, which increases the potential for regrowth after damage and/or survival of inclement conditions. Barbs and spines defend teasel against herbivory and may focus grazing or browsing on unprotected associated vegetation. High levels of seed production, high seed germinability, and little dormancy in fresh seed allows for rapid establishment in open areas, and death of the parent provides habitat for future seedling recruitment.
While some teasel plants may be killed by cutting or mowing, many sprout and some may still produce seed. Typically, researchers and land managers suggest that belowground cutting is most effective, but plants may still regenerate. Reduced seed production and plant death are most likely if plants are cut just before or as they flower. However, viable seeds may be produced on cut stems, making disposal of flowering stems in cut areas important to successful teasel control.
Tree of Heaven (Ailanthus altissima) (AIAL)
This information comes from the National Park Service’s Integrated Pest Management Manual. (Image courtesy of USDA PLANTS Database, USDA NRCS PLANTS Database, Bugwood.org.)
Tree of heaven is in the family Simaroubaceae. It was introduced into the United States from China as a host tree for the Cynthia moth, Samia cynthia (Drury), which was introduced for silk production. It was brought to the eastern United States as nursery stock because of its ability to grow quickly under adverse conditions. Chinese miners also brought the seeds with them to California because of their medicinal and cultural importance. Distribution in the United States is from Massachusetts to Iowa and Kansas and south to southern Texas and Florida. Tree of heaven has established to a lesser extent in the western United States from southern Rockies to the Pacific Coast states.
It is a tall (to 60 feet), deciduous, polygamous tree and often colonizes by root sprouts. Stump sprouts can grow 6-12 feet in length in a single summer. Flowers are present in late May through early June in 12-inch-
186 Final Supplemental Environmental Impact Statement long terminal panicles. A large cluster of pink fruits develops from July to October. The flowers and vegetative parts, if bruised, are ill scented, almost nauseating, on hot days.
Tree of heaven is intolerant of deep shade and occurs most commonly along fence rows, roadsides, and waste areas. It is tolerant of urban conditions, including compacted, poor soils, and polluted air, and is common in dusty, smoggy areas such as inner cities where most other trees fail.
It is often used as an ornamental in urban areas. It spreads rapidly in disturbed areas and can quickly take over forest openings created by gypsy moth damage or fire. It can pose a serious threat to natural areas. It has been found growing up to two air miles from the nearest seed source.
Cutting the tree by removing all above-ground growth does not prevent regeneration of sprouts from the stump. Current treatment consists of felling the tree and treating the stump with herbicide. Chemical treatment kills remaining tissue and prevents regrowth of stump sprouts. Trees may be frilled and treated with felling, treated by injection, or treated by hack and squirt. The latter technique involves cutting into the cambium and applying herbicide into the wound.
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Appendix 3. Herbicides: Characteristics, Effects, and Risk Assessments [Replaces introductory paragraphs and Table S-67 replaces table 57]
This appendix provides a summary of the available scientific information about the characteristics and effects of herbicides proposed for use in this project. Detailed information can be found in literature cited in the environmental impact statement as well as on national and regional Web sites managed by other agencies and organizations including the Environmental Protection Agency, USDA Forest Service, The Nature Conservancy, and the Colorado Department of Agriculture.
A key component of this analysis is the individual risk assessments developed by the Forest Service for each herbicide. Each risk assessment discusses the formulations analyzed for use in this project. These risk assessments were developed to determine the risk of using each herbicide, with worksheets provided to evaluate the risk at project level circumstances (such as application rate and application method). The risk assessments provide Forest Service officials with a summary of the most relevant information available. They are not comprehensive summaries of all the available information. After comments on the 2004 draft environmental impact statement raised concerns about whether the evaluation of effects was adequate, the risk assessments were reexamined. As a result, this appendix incorporates by reference the 13 risk assessments available to date:
Table S-67. Risk assessments Herbicide Name Date Prepared Reference 1 Aminopyralid June 28, 2007 SERA 2007 2 2,4-D September 30, 2006 SERA 2006 3 Clopyralid December 5, 2004 SERA 2004c 4 Chlorsulfuron November 21, 2004 SERA 2004a 5 Dicamba November 24, 2004 SERA 2004b 6 Glyphosate March 25, 2011 SERA 2011a 7 Hexazinone October 25, 2005 SERA 2005 8 Imazapic December 23, 2004 SERA 2004f 9 Imazapyr December 16, 2011 SERA 2011b 10 Metsulfuron December 9, 2004 SERA 2004d 11 Sulfometuron December 14, 2004 SERA 2004b 12 Picloram September 29, 2011 SERA 2011c 13 Triclopyr March 15, 2003 SERA 2003b
Any cited references to the risk assessments in the final environmental impact statement, the draft supplemental environmental impact statement, or the remainder of these appendices are hereby updated with the ones listed above.
189 Invasive Plant Control Project
Program Description [Add aminopyralid (see Table S-68) to table 58]
Table S-68. Herbicide use program description Herbicide Name Other Information 1 Aminopyralid A reduced risk herbicide used post-emergence to control annual, biennial, and perennial broadleaf weed species including thistles and knapweeds. Also has excellent pre-emergence soil residual activity.
Application Methods [No change from final environmental impact statement] [Add aminopyralid (see Table S-69) to table 59)]
Table S-69. Herbicides formulations, application rates, target plants Herbicide Application Rate Name Trade Name(s) (pounds per acre) Target Invasive Plants 1 Aminopyralid Milestone, 0.03 to 0.11 Thistles, knapweeds, yellow Milestone VM starthistle
[Add aminopyralid (see Table S-70) to table 60]
Table S-70. Herbicide risk assessment standard terminology Term Abbrev Explanation (see risk assessments for specific definitions) Lowest Observed LOEC Used for plants to determine the lowest concentration at which a Effect Concentration concentration of herbicide had no effect.
Overall Conclusions [No change from the final environmental impact statement] Human Health Risk Assessment [No change from the final environmental impact statement] Factors Affecting Hazard of Herbicides [No change from the final environmental impact statement]]
[Add aminopyralid to table 61 as shown in Table S-71]
Table S-71. Herbicide characteristics Mutagenic and Acute oral LD50 for rats Herbicide Carcinogenic1 Reproductive2 (mg/kg/day) Aminopyralid E No >2000 1. Environmental Protection Agency carcinogenicity classification based on daily consumption for a 70-year life span. D = Not Classifiable as to Human Carcinogenicity; E = Evidence of Non-Carcinogenicity 2. Unlikely that compound is mutagenic or would pose a mutagenic risk to humans at expected exposure levels. Source: SERA 2007.
190 Final Supplemental Environmental Impact Statement
[This section updated] Potential for Exposure While the toxicity of a substance is the first part of the risk assessment, the second equally important consideration is the potential for exposure. The dose level that causes an effect in many toxicological studies is exponentially greater than what an applicator would be exposed to while applying herbicides. The method of exposure to herbicides in animal studies is also different than that of a worker or the general public, which also magnifies the chemical effect. In animal studies, herbicides are commonly pumped into stomachs, put directly into food, or placed directly on shaved skin. Potential exposure levels to workers and the general public associated with use of herbicides on forest lands have been estimated to be at or below Environmental Protection Agency reference doses. Therefore, dosages would not exceed acute toxicity dose levels when applying herbicides on forest lands.
Herbicide applicators and the general public are clothed and do not purposely ingest herbicides under the same conditions as animal studies of toxicological significance. Estimates of exposure to workers and the general public to herbicides applied to forest lands have been reported under various conservative exposure scenarios. The most reasonable interpretation of the risks associated with application of most herbicides on national forest lands is that, except for accidental exposures or extremely atypical and perhaps implausible exposures scenarios (for example, acute direct spray entirely covering a naked child), the use of herbicides on National Forest System lands would not pose an identifiable risk to workers or the general public.
Exposures under typical exposure scenarios (those following guidelines on the label) would be below the reference dose, a dose level determined to be safe by the Environmental Protection Agency over a lifetime of daily exposure.
There are exceptions worth noting that may help identify protective measures that could be instituted when applying herbicides.
• USDA Forest Service (SERA 2005) reports that, over a range of plausible application rates, workers may be exposed to hexazinone at levels exceeding the reference dose. • Likewise, there is reasonable concern that workers applying triclopyr over a prolonged period of time in the course of a single season or several seasons may be at risk of impaired kidney function (SERA 2003). • SERA (2006) reports if 2,4-D were applied directly to fruits and vegetables at anticipated application rates, the consumption of vegetables would be undesirable and could lead to health effects. These reports also point out the likelihood of such an exposure seems remote when applying on forest lands. Given the concern with the consumption of forest vegetation by the local population, this route of exposure is more likely than elsewhere in the United States and should be considered in the implementation process to avoid these exposures. • SERA (2006) reports exposure levels for workers involved in ground or aerial application of 2,4-D may exceed the reference dose slightly, based on central estimates of exposure, or substantially, based on upper limits of exposure. They indicate 2,4-D can be applied safely (exposure doses below the reference dose) if effective methods are used to protect workers and minimize exposure (personal protective equipment). • SERA (2003) reported no evidence that typical exposures to picloram would lead to a dose level exceeding the reference dose or level of concern, with the exception of wearing contaminated gloves for 1 hour, which results in estimates of absorbed doses that exceed the reference dose. • SERA (2003) notes exposure of workers to formulations of triclopyr over a long duration could exceed the level of concern and these levels should be avoided. • SERA (2007) explains the Environmental Protection Agency has judged aminopyralid to be a reduced risk herbicide. This judgment by the Environmental Protection Agency is supported by the current risk
191 Invasive Plant Control Project
assessment. Aminopyralid is an effective herbicide. As with any effective herbicide applied to terrestrial weeds, adverse effects in nontarget terrestrial plants are plausible. There is no indication, however, that adverse effects on workers, members of the general public or other non-target animal species are likely. This assessment of aminopyralid is tempered by the lack of information on aminopyralid in the open literature. All of the information on the toxicity of aminopyralid comes from studies submitted to the Environmental Protection Agency in support of aminopyralid registration. While these studies have been reviewed and the bulk of these studies appear to have been appropriately designed, conducted, and reported, the available information on aminopyralid is much less diverse than the information available on herbicides used for many years and for which the open literature is rich and varied. How herbicides are applied can have a direct impact on the potential for human exposure and subsequent adverse health effects. According to risk assessments completed on herbicide usage on national forest lands, herbicide applicators are at a higher risk than the general public from herbicide use. The risk assessments compared risks to workers for all types of application, including aerial, backpack, ground-mechanical, and hand applications. Lower risks were estimated for aerial and ground-mechanical application as compared to other methods, even though the total amount of herbicide applied in a given day was higher (SERA 1995- 2007).
Risks associated with backpack and hand application of herbicides were estimated to be the highest, due to workers being closer to the nozzle and to the containers from which the herbicides were sprayed. Backpack and hand application was also reported to increase the likelihood of a worker receiving repeated exposures that might remain on the skin for an extended period. The Environmental Protection Agency, in its reregistration of picloram (EPA 1995), also noted the highest risk for herbicide applicators was for those using the backpack application method, the lowest for aerial and ground-boom applicators. Although this is true in general, risk assessments worksheets run on the likely application rates and methods for the two national forests found this exposure reversed for 2,4-D applicators.
Route of Exposure [Add aminopyralid to table 62 as shown in Table S-72]
Table S-72. Exposure risk of herbicides RfD1 Estimated Exposure to Estimated Exposure to Herbicide (mg/kg/day) Public2 Worker2 Aminopyralid 0.5 Less than RfD3 Less than RfD (0.001 – 0.002) 1. RfD = reference dose. A daily dose expressed as milligrams of herbicide per kilogram of body weight = mg/kg 2. Exposures under typical exposure scenarios. Accidental and extreme exposure scenarios may exceed the reference dose. 3. Based on modeling of the most exposed individual, SERA found “based on a generally conservative and protective set of assumptions regarding both the toxicity of aminopyralid and potential exposures to aminopyralid, there is no basis for suggesting that adverse effects are likely in either workers or members of the general public even at the maximum application rate that might be used in Forest Service [or National Park Service] programs.” Source: SERA 2007 Wildlife Risk Assessment [No change from the final environmental impact statement, except 13 herbicides (not 12) are proposed for use]
[Add aminopyralid to table 63 as shown in Table S-73]
192 Final Supplemental Environmental Impact Statement
Table S-73. Relative risk of each herbicide
Plants, Risk Risk Risk Notes Direct Risk of of Risk Herbicide Drift/runoff Public Risk Public Worker Risk Risk to to Risk Plants, to Rick Aquatic Plants Plants Aquatic Animals Direct Direct Animals Aquatic Animal Animal Aquatic Carcinogenicity
Aminopyralid 1 1 NA 2 3 3 1 1 1 = lowest relative risk, 5 = highest relative risk
193 Invasive Plant Control Project
[Add aminopyralid to table 64 as shown in Table S-74]
Table S-74. Effects of each herbicide Teratogen Mutagen Toxicity Carcinogen (Birth (Genetic Reproductive Skin Eye Bio- Toxicity to Toxicity to Herbicide (Cancer) Defects) Damage) Inhibitor Irritant Irritant Accumulate Birds to Bees Mammals Target Plants Aminopyralid No No No No Slight None Minimal Practically Practically Low Broadleaf plants nontoxic nontoxic
194 Final Supplemental Environmental Impact Statement
Aquatic Risk Assessments [No change from the final environmental impact statement except to add aminopyralid to table 65 as shown in Table S-75]
Table S-75. Level of Concern for Chemical Use Using the Risk Quotient Method
1/20 Of LC50 Risk Level of Chemical (ppm)1 EEC2 (ppm) Quotient3 Concern Aminopyralid (Milestone) 6.0 0.1 0.1 Low
1. LC50 = Lethal concentration where 50 percent mortality occurs. The current risk assessment will use no observable effect concentration values rather than LC50 values for risk characterization. For aminopyralid, however, the resulting numbers are essentially identical to those of the Environmental Protection Agency because most of the >LC50 values used by U.S. EPA/OPP-EFED (2004) are actually no observable effect concentration values – that is, no mortality or sublethal effects were observed. 2. EEC = expected environmental concentration; ppm = parts per million. 3. This is below the level of concern by a factor of 10 (SERA 2007).
Specific Herbicide Characteristics and Environmental Effects [Add aminopyralid, otherwise no change from the final environmental impact statement]
Aminopyralid Aminopyralid is a relatively new pyridine carboxylic acid herbicide for controlling weeds and invasive plants on rangeland and pastures, rights-of-way, and wildlife habitat areas. It is particularly effective on musk and Canada thistles; spotted, diffuse, and Russian knapweeds, yellow starthistle, and other difficult-to-control broadleaf weeds (SERA 2007). It is primarily a post-emergence herbicide but has excellent pre-emergence soil residual activity. Aminopyralid can be applied to weeds at any stage of growth, but it works best when used during the specific weed(s) optimal growth stages for control. Residual activity control can last into the season after treatment on certain weed species.
Aminopyralid translocates throughout the entire plant, accumulating in meristematic tissues including the roots, effectively disrupting the plants’ growth metabolic pathways and eradicating susceptible broadleaf plant species. Aminopyralid has been shown to cause little or no injury to desirable cool- and warm-season grasses. Aminopyralid will not cause injury to mature tree species, such as pine, maple, and ash but can cause some leaf discoloration, curling, or other foliage symptoms from over-application. Leguminous trees, such as black locust and honey locust, can be seriously injured by under-tree application.
The Environmental Protection Agency considers aminopyralid a reduced risk herbicide because there is no evidence of adverse effects on workers, members of the general public, or wildlife and domestic animals. However, as with all relatively new herbicides, there is little information available in the published literature on the toxicity of aminopyralid to humans or other mammalian species. The few currently available for assessing potential hazards in humans are those supporting its registration.
Acute toxicity data indicate aminopyralid has low mammalian toxicity via oral, dermal, and inhalation routes of exposure (U.S. EPA 2005) for both technical and end-use formulations. The acute oral LD50 and dermal LD50 in rats were greater than 5,000 milligrams per kilogram, respectively, while the acute inhalation LC50 was greater than 5.5 milligrams per liter. In a metabolism study in rats, it was rapidly absorbed, distributed, and excreted following oral administration. Dermal irritation was negative for the aminopyralid technical. Eye irritation ranged from a slight, transient irritation to irritating for aminopyralid formulations.
Aminopyralid has been classified as “not likely” to be carcinogenic to humans; nor has it been found to be teratogenic, mutagenic, neurotoxic, or a reproductive hazard. It has tested negative for genotoxicity in both in
195 Invasive Plant Control Project vitro and in vivo systems with no long-term (chronic) toxicity evident. The aminopyralid human health and risk assessment (SERA 2007) and the Environmental Protection Agency determined no risks to workers or members of the general public are anticipated.
Toxicity studies on terrestrial plants reveal broadleaf plants are substantially more sensitive to aminopyralid than monocots (for example, grasses), which is consistent with the recommended uses of aminopyralid. As would be expected from an herbicide, some aquatic plants are more sensitive than aquatic animals to the effects of aminopyralid.
Relatively little information is available on the standard acute and chronic toxicity of aminopyralid to terrestrial invertebrates or terrestrial microorganisms. Based on bioassays in honeybees, earthworms, and soil microorganisms, aminopyralid does not appear to be very toxic to terrestrial invertebrates or soil microorganisms nor is there any indication it is likely to be toxic to aquatic animals, based on bioassays in fish and invertebrates.
Inert/Other Ingredients [Add aminopyralid to table 66 as shown in Table S-76]
Table S-76. Herbicide formulations, impurities, other ingredients Herbicide Name Hazard Identification 1 Aminopyralid Impurities, adjuvants and metabolites are considered together in the risk assessment. Formulations covered in this risk assessment contain only the triisopropanolamine (TIPA) salt of aminopyralid and water. Triisopropanolamine would be classified marginally as Category III (Caution), which applies to compounds with oral LD50 values in the range of >500 to 5,000 milligrams per kilogram.
196 Final Supplemental Environmental Impact Statement
Appendix 4. Effects of Non-Herbicide Weed Control Methods [No change from the final environmental impact statement]
Appendix 5. Herbicide Model for Watershed Analysis [No change from the final environmental impact statement]
Appendix 6. Chemical Spill Prevention and Cleanup Plan [No change from the final environmental impact statement]
Appendix 7. Weed Populations and Treatments [Replaces entire section] This appendix lists the weed species known in the project area as of August 1, 2013 and the proposed method(s) by which they would be treated. Where several species grow in the same vicinity, they are grouped together. More than one treatment is listed in alternatives B and C because different species respond to different treatments depending on their ecology and location. Thus, the tables show the maximum number of acres that would be treated by the method shown.
Note that treatments are not limited to only the known weed populations. The adaptive nature of this project, described in chapter 2, will allow the Carson and Santa Fe National Forests to treat new populations of weeds as they are discovered. In fact, recent studies show treating new populations before the seedbed is established is the most effective and least costly strategy for reducing and eliminating weeds (Frid et al. 2013).
The acreages and treatment methods provided here are a snapshot in time, helpful as a basis for evaluating the effects of weeds and the treatments.
197 Invasive Plant Control Project
Keys to abbreviations:
Weed species Code Scientific Name Common Name ACRE3 Acroptilon repens hardheads; Russian knapweed AIAL Ailanthus altissima tree of heaven BRTE Bromus tectorum cheatgrass CADR Cardaria draba whitetop; hoary cress CANU4 Carduus nutans nodding plumeless thistle; musk thistle CEDI3 Centaurea diffusa diffuse knapweed CESO3 Centaurea solstitialis yellow star-thistle CESTM Centaurea stoebe ssp. micranthos spotted knapweed CIAR4 Cirsium arvense Canada thistle CIVU Cirsium vulgare bull thistle COMA2 Conium maculatum poison hemlock DIFU2 Dipsacus fullonum Fuller's teasel ELAN Elaeagnus angustifolia Russian olive EUES Euphorbia esula leafy spurge HYNI Hyoscyamus niger black henbane LELA2 Lepidium latifolium broadleaved pepperweed LIDA Linaria dalmatica Dalmatian toadflax LIVU2 Linaria vulgaris butter and eggs; yellow toadflax ONAC Onopordum acanthium Scotch cottonthistle TARA Tamarix ramosissima saltcedar ULPU Ulmus pumila Siberian elm
198 Final Supplemental Environmental Impact Statement
Abbreviations for treatment methods Treatment Method Abbreviation Biological BIO Grazing GR Herbicides HE Manual MA Mechanical ME Prescribed fire FR
199 Invasive Plant Control Project Table S-77. Summary of treatments for the action alternatives Plant Species Alternative B Treatments Alternative C Treatments Alternative D Treatments Treatment Acres1 ACRE3 GR, HE, MA, ME GR, MA, ME HE 93.5 ACRE3 CADR GR, HE, MA, ME GR, MA, ME HE 0.2 ACRE3 CANU4 GR, HE, MA, ME GR, MA, ME HE 0.2 ACRE3 CEDI3 GR, HE, MA, ME GR, MA, ME HE 0.0 ACRE3 CEDI3 ELAN TARA BIO, GR, HE, MA, ME BIO, GR, MA, ME HE 0.1 ACRE3 CIVU GR, HE, MA, ME GR, MA, ME HE 0.1 ACRE3 TARA BIO, GR, HE, MA, ME BIO, GR, MA, ME HE 16.0 AIAL ULPU HE, MA, ME MA, ME HE 0.1 BRTE FR, GR, HE, MA, ME FR, GR, MA, ME HE 73.4 BRTE CANU4 HE, MA, ME MA, ME HE 0.5 CADR BIO, HE, MA, ME BIO, MA, ME HE 34.7 CADR CIVU ELAN TARA ULPU FR, HE, MA, ME FR, MA, ME HE 1.7 CADR CIVU TARA FR, HE, MA, ME FR, MA, ME HE 1.0 CADR ELAN ULPU FR, HE, MA, ME FR, MA, ME HE 0.7 CADR ONAC BIO, HE, MA, ME BIO, MA, ME HE 18.7 CANU4 HE, MA, ME MA, ME HE 1,309.7 CANU4 CIAR4 GR, HE, MA, ME GR, MA, ME HE 2,265.7 CANU4 CIAR4 CIVU GR, HE, MA, ME GR, MA, ME HE 2.8 CANU4 CIVU HE, MA, ME MA, ME HE 137.5 CANU4 CIVU ELAN TARA ULPU FR, HE, MA, ME FR, MA, ME HE 10.3 CANU4 CIVU ONAC HE, MA, ME MA, ME HE 3.4 CANU4 CIVU TARA HE, MA, ME MA, ME HE 1.8 CANU4 COMA2 HE, MA, ME MA, ME HE 0.1 CANU4 ELAN HE, MA, ME MA, ME HE 0.0 CANU4 LIDA BIO, HE, MA, ME BIO, MA, ME HE 8.3 CANU4 LIDA ONAC HE, MA, ME MA, ME HE 0.8 CANU4 ONAC HE, MA, ME MA, ME HE 1.4 CANU4 TARA HE, MA, ME MA, ME HE 0.3 CANU4 ULPU HE, MA, ME MA, ME HE 0.6 CEDI3 HE, MA, ME MA, ME HE 173.1 CEDI3 ELAN TARA BIO, HE, MA, ME BIO, MA, ME HE 328.4 CESO3 BIO, FR, GR, HE, MA, ME BIO, FR, GR, MA, ME HE 0.6 CESTM HE, MA MA HE 25.9
200 Final Supplemental Environmental Impact Statement Plant Species Alternative B Treatments Alternative C Treatments Alternative D Treatments Treatment Acres1 CESTM CIAR4 GR, HE, MA, ME GR, MA, ME HE 313.3 CIAR4 GR, HE, ME GR, ME HE 2,999.4 CIAR4 CIVU GR, HE, MA, ME GR, MA, ME HE 6.3 CIAR4 CIVU ELAN TARA ULPU BIO, FR, GR, HE, MA, ME BIO, FR, GR, MA, ME HE 3.7 CIAR4 CIVU TARA BIO, GR, HE, MA, ME BIO, GR, MA, ME HE 0.3 CIAR4 ELAN ULPU FR, GR, HE, ME FR, GR, ME HE 0.0 CIAR4 LELA2 LIVU2 HYNI BIO, GR, HE, ME BIO, GR, ME HE 43.0 CIAR4 ONAC GR, HE, MA, ME GR, MA, ME HE 0.2 CIAR4 TARA BIO, GR, HE, ME BIO, GR, ME HE 0.0 CIVU BIO, HE, MA, ME BIO, MA, ME HE 2,877.6 CIVU COMA2 BIO, HE, MA, ME BIO, MA, ME HE 0.0 CIVU ELAN TARA ULPU BIO, HE, MA, ME BIO, MA, ME HE 693.5 CIVU LIVU2 GR, HE, MA, ME MA, ME HE 0.1 CIVU ONAC BIO, HE, MA, ME BIO, MA, ME HE 26.8 CIVU TARA BIO, HE, MA, ME BIO, MA, ME HE 63.7 COMA2 BIO, HE, MA BIO, MA HE 22.2 DIFU2 HE, MA, ME MA, ME HE 0.1 ELAN HE, ME ME HE 3.3 ELAN TARA BIO, HE, ME BIO, ME HE 27.6 ELAN TARA ULPU BIO, FR, HE, ME BIO, FR, ME HE 116.2 ELAN ULPU BIO, FR, HE, ME BIO, FR, ME HE 64.4 EUES BIO, GR, HE BIO, GR HE 8.9 HYNI HE, MA MA HE 0.6 LELA2 GR, HE, ME GR, ME HE 0.1 LIDA BIO, GR, HE BIO HE 8.6 LIDA ONAC BIO, GR, HE, MA BIO, MA HE 0.6 LIVU2 BIO, GR, HE BIO HE 3.6 ONAC HE, MA MA HE 470.6 TARA BIO, HE, ME BIO, ME HE 372.9 TARA ULPU FR, HE, ME FR, ME HE 0.2 ULPU FR, HE, ME FR, ME HE 617.1 1. A value of 0.0 means that less than one-tenth of an acre of a species exists.
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Appendix 8. Implementation and Monitoring [No change from the final environmental impact statement]
Appendix 9. Response to Comments on the Draft Environmental Impact Statement [No change from the final environmental impact statement]
Appendix 10. Response to Comments on the Draft Supplemental Environmental Impact Statement [New section] NEPA Concern: The Forest Service failed to implement NEPA properly because it has prepared a hybrid of the programmatic and site-specific analysis that suffices as neither.
Response: The final environmental impact statement and final supplemental environmental impact statement provide project-level analysis of this proposal. It is not programmatic. The proposal presents a limited, specific set of treatments on a specific set of plants on National Forest System lands of the Carson and Santa Fe National Forests (final supplemental environmental impact statement, chapter 2 pp. 27-42). The known extent of weed populations (that is, site specific locations where treatments would begin) are displayed (figure S-2, p. 19). The direct, indirect, and cumulative effects of each kind of treatment to natural, cultural, and socioeconomic resources are thoroughly analyzed and presented in chapter 3 of the final environmental impact statement (pp. 63-184) and final supplemental environmental impact statement (pp. 43-168).
The adaptive management component of the project further ensures the effects will not extend beyond the scope of the predicted effects at any given location with any given treatment. The Forest Service must monitor the effects of treatments and adjust future treatments to remain within the scope of this environmental impact statement or do additional National Environmental Policy Act analysis (final supplemental environmental impact statement p. 38, design feature #61).
Associated Comments It does not contain site-specific analytical data. 40 C.F.R.§ 1502.1. Its data are internally inconsistent and not of the required "high quality," 40 C.F.R. § 1500.1(b), and "scientific accuracy, 40 C.F.R. § 1502.24.
In this case, the Forest Service declined to prepare a programmatic EIS for the control of invasive plants on the Santa Fe and Carson National Forests. If that course had been followed, then less detailed site-specific analysis (Environmental Assessments) could have been prepared to address the impacts of site-specific projects. Instead, the Forest Service prepared a hybrid of the programmatic and site- specific analysis that document that suffices as neither. This DSEIS and its accompanying FEIS neither provides the decision-maker with a detailed environmental disclosure nor provides the public with the high quality information needed to evaluate environmental consequences. As documented below, such action is clearly contrary to NEPA.
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If the quantitative data needed to accurately evaluate site-specific impacts of herbicides on soil and water is lacking, NEPA requires disclosure of this fact. 40 C.F.R. § 1502.22. The DSEIS does not disclose this fact, instead analyzing cumulative impacts based on erroneous assumptions in violation of NEPA’s requirement that analytical information must be of high quality. 40 C.F.R. § 1500.1(b).
Concern: The Forest Service has failed to analyze the effects of the design features as required by NEPA.
Response: Table S-11 (final supplemental environmental impact statement pp. 33-38) shows the "design features" and monitoring requirements for all the alternatives. Since these features are built into the proposed alternatives, their effects were analyzed for each resource area (final supplemental environmental impact statement p. 51).
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Associated Comments: It does not analyze the so-called "design features." "'A mere listing of mitigation measures is insufficient to qualify as the reasoned discussion required by NEPA.'" Neighbors of Cuddy Mountain v. United States Forest Service, 137 F.3d 1372, 1380 (9th Cir. 1998) In other words, mitigation measures must be analyzed in detail and must explain their effectiveness in mitigating adverse environmental 10 impacts. Without analytical data to support this analysis and explanation, the mitigation measures/design features amount to nothing more than a “mere listing” of good management practices.
Concern: The Forest Service has not provided adequate rationale for the geographic scope of the project and does not consistently describe its temporal bounds.
Response: The Forest Service has considerable leeway when choosing the locations of its projects. In this case, it made sense for the Carson and Santa Fe National Forests to work together on invasive weed treatment because the forests are adjacent, share management of the Pecos Wilderness, and often share resources and personnel. Also, as described in the final supplemental environmental impact statement (beginning on page 24), the Carson and Santa Fe National Forests simultaneously started considering weed treatments in the mid-1990s and decided to work together in 1998.
The timeframe for the effects analysis (direct, indirect, and cumulative) is 10 years. The actual implementation period could extend beyond 10 years if monitoring shows the results of treatments remain within the expected sideboards. Language in the final supplemental environmental impact statement has been corrected accordingly.
Associated Comments: The Forest Service failed to disclose to the public its reason for establishing the geographic scope of the project as the Santa Fe and Carson National Forests. Why not New Mexico’s three northern National Forests or all five? A rationale for selecting two is never presented. Since the geographic scope of the project is critical to evaluating cumulative impacts, this omission fatally flaws the analysis. In addition, the project’s time frame is presented in some cases as 10 years and others as “approximately 10 years (or more)”. Equivocal time limits and designation of arbitrary project boundaries are actions contrary to NEPA’s requirement that EISs be properly defined. 40 C.F.R. § 1502.4(a).
Concern: Some comments revealed a lack of understanding of the proposal.
Response: We regret any confusion our wording has caused. The distinction between design features and mitigation measures has evolved and become clearer since the writing of the final environmental impact statement in 2005. For this project, these terms are used interchangeably (final supplemental environmental impact statement p. 12).
The only herbicides that would be approved for use are the 13 listed in the final supplemental environmental impact statement (p. 28). As proposed, use is consistent with law, regulation, and policy, including restrictions which apply to on the Santa Fe National Forest (final supplemental environmental impact statement p. 167). Any new herbicides proposed for use would need to undergo analysis as required by the National Environmental Policy Act.
The final supplemental environmental impact statement discloses cumulative actions considered in the effects analysis. Table S-14 (pp. 44-47) lists projects considered as past and present actions. Table S-15 (pp. 47-48) lists projects considered as reasonably foreseeable future actions. A summary of cumulative actions for each key resource is provided in Table S-16 (pp. 49-50). Specific information on past, present, and reasonably future weed control activities are described in appendix 1 of the final supplemental environmental impact statement (pp. 201-211). Because no forest-wide, integrated weed
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treatment strategy exists, any herbicide use proposed for these projects would have been considered on a project-by-project basis in the appropriate National Environmental Policy Act analysis.
Associated Comments: I also note a disturbing change in nomenclature since the FEIS, now referring to “mitigation measures” as “design features”. This appears to be an attempt at linguistic detoxification, to make it sound like there are no hazards that need to be “mitigated”. But this name change will not affect the toxicity of herbicides.
If, based on the Project, new herbicides become available in the future, then they too can be used without further analysis of their impacts.
In the FEIS (p. 64), past and present ongoing weed treatments in the forest are mentioned, but no dates are given, it does not say whether those treatments are ongoing or not, it does not say if the FS violated the ban on herbicide use in the Santa Fe National Forest. And what of the riparian areas?
Concern: Never before have I heard of a USFS line-officer proposing to amend their forest plan to allow more people to be exposed to a carcinogen and then call it “nonsignificant.” Purge this from the final EIS. The New Mexico politicians will have fun with this.
Response: This project's forest plan amendment for the Santa Fe National Forest will be conducted in conformance with the 1982 planning rule provisions as allowed by the 2012 Planning Rule since the amendment process was initiated prior to May 9, 2012 (36 CFR 219.17(b)(3)). Under the 1982 planning rule provisions, a significant amendment results when: 1) the proposal will significantly alter the long-term relationship between multiple-use goods and services originally projected or 2) the proposal will affect land and resources throughout a large portion of the planning area during the planning period (Forest Service Manual 1926.52).
Law, Regulation, Policy Concern: The preferred alternative is a violation of Forest Service Manual 2323.26b (page 133 DSEIS)) because it will have serious adverse impacts on wilderness values, which includes environmental illness and wildlife impacts. The Forest Service needs to re-evaluate the project's impact on wilderness values, perhaps through a health impact assessment or other evaluation of publicly held wilderness values.
Response: Page 135 of the final supplemental environmental impact statement, cited by the commenter, lists the Forest Service manual direction stating the conditions under which weeds may be treated in wilderness. The commenter provides no evidence that treating weeds will adversely affect wilderness values. Pages 135 through 139 describe the predicted effects to the four wilderness characteristics: untrammeled, natural, undeveloped, and solitude/primitive and unconfined recreation. No lasting, significant effects to these characteristics are expected. Visual changes may occur from wilted, dead, or dying plants. Small portions of the wilderness could be closed for 1 to 5 days during treatments, and during this time, Forest Service personnel would be on site treating weeds. None of these are considered to be lasting, significant effects to the wilderness experience.
The potential for effects to human health and safety was identified as an issue to analyze in detail (final supplemental environmental impact statement pp. 33-34 and pp. 149-150). Analysis is provided in chapter 3 of the final supplemental environmental impact statement (pp. 149-161).
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Associated Comments This plan can be classified as a Violation of Forest Service Manual 2323.26b (page 133 DSEIS)) as it can be considered to have "serious adverse impacts on wilderness values" which includes environmental illness, wildlife impacts, etc ....The use of herbicides which causes mortality of natives and non-natives could be argued as an ineffective method of protection of wilderness in comparison with manual alternatives; the opportunities for visitation and recreation would be negatively impacted for those with environmental illness should Alternative C be used; and it can be argued that the use of herbicides is not a "preservation" of nature, nor is it spiritually inspiring. The impact on scenic views may be negligible. The recreational value is further addressed when the USFS admits on p 137 that "Alternative C would not be as effective at controlling newly established weed populations caused by recreational activities." For these reasons we request a re-evaluation of the impact on wilderness values, perhaps through a health impact assessment or other evaluation of what the publicly held wilderness values are that the USFS claims will not be seriously adversely effected. Best Available Science Concern: The Forest Service should provide the dates that data on invasive plants was collected and include it in the maps presented in the DSEIS.
Response: The data presented show invasive plants surveyed as of August 1, 2013 (final supplemental environmental impact statement, p. 20). The final supplemental environmental impact statement has been updated to include this date on the appropriate maps and tables.
Associated Comments We would like to point out that maps in DSEIS are not dated; but they were in FEIS. Why the discrepancy? We request that all maps include dates of data collected. The FEIS maps are dated, and the DSEIS maps are not dated (accidental or deliberate?). The lack of data you provide in the DSEIS does not provide us with enough information to compile thoroughly worthwhile comments within the current time frame.
We request that all maps include dates of data collected.
Concern: The model used to depict how herbicides travel within watersheds after application is inadequate, and therefore the Forest Service's conclusion that no harm will result from using herbicides is incorrect.
Response: The model used in this analysis simulates the potential concentrations of herbicide in a stream draining a watershed subject to weed treatment. The model calculates dilution of herbicide in primary streams of representative watersheds for two time periods – May and September, representing typical time periods when discharge is near the peak (May) and near the minimum (September). Picloram was selected because of its “high risk quotient” for fisheries and aquatic life, and a worst-case scenario was developed that represented the treatment of all weed acres at one time under alternative B.
Modeling assumptions were clearly articulated and disclosed (final environmental impact statement pg. 292). Modeling results are illustrated in Table 66 (final environmental impact statement pp. 293- 294), and two watershed were found to potentially exceed the recommended threshold indicating that some effect to soil and water resources would be expected (loss of fish or aquatic insects). The interdisciplinary team considered these potential risks and developed design features to limit or avoid treatment scenarios in which the impacts would be likely to occur (final supplemental environmental impact statement pp. 33-38). Mitigation measures include limitations on herbicide treatment near streams and water bodies, use of only hand application onto individual weed plants in riparian areas, choice of herbicide method of application documented to be of low risk to aquatic species, prohibiting mixing and loading of herbicides near live water, etc.
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While the commenter(s) may feel the model is inadequate, it meets the requirements of the National Environmental Policy Act to disclose the effects of a proposed action to the public and develop mitigation to address those impacts.
Associated Comments Faced with a persistent gap in its understanding of herbicide behavior, the Forest Service prepared an “Herbicide Model for Watershed Analysis” that purportedly models 11 watersheds to determine the impacts of herbicide application (FEIS, p. 291, unchanged in DSEIS). However, this model is woefully inadequate, in part, because it continues to assume with no discernible basis that herbicides respond in the field as they do in the controlled conditions of a laboratory. [16-11] The FEIS’s appendix 5 (unchanged in the DSEIS) presents a theoretical model of 11 watersheds on the two forests purportedly showing that the project’s use of herbicides will not harm aquatic species or water quality. The results of this modeling exercise are further used to justify the removal of thresholds that would trigger further analysis (FEIS, p. 342). The critical assumptions of this analytical model are: 1) unsubstantiated by appropriate research or practical literature; 2) contain numerous questions which cannot be answered from information presented in the FEIS; 3) lacks the quality necessary for critical examination; and 4) as used in the FEIS, is non-empirical and hence not of high scientific quality. Attachment 8 (project record, original FEIS) is a critique of the watershed model prepared by Dr. Kim Kirkpatrick.
Concern: The Forest Service fails to use the best available science on the effects of herbicides. The risk assessments cited are out of date.
Response: The information included in the risk assessments comes from the most recent studies available at the time the assessments are prepared (final supplemental environmental impact statement p. 185). If some information is dated, it is because no recent studies have superseded the findings. Some commenters provided citations purportedly containing more up-to-date information. Upon review, however, these citations do not apply to the proposal, are not peer-reviewed scientific literature, or are inappropriately applied.
The Environmental Protection Agency developed a methodology to allow the use of the best available science to determine the risk of harm, either short term or long term. The dose-response method developed by the Environmental Protection Agency is widely accepted in the scientific community.
Limitations of the method are described by the Environmental Protection Agency. For example, the reference dose applies to effects that are threshold related (for example, assumed that below some threshold, no effects will occur). The assumptions have been tested over a number of years. Safety factors are incorporated. Assumptions are reasonable and supported by facts. The Environmental Protection Agency states the reference dose is an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily exposure to the human population (included sensitive subgroups) likely to be without an appreciable risk of deleterious effects during a lifetime.
Associated Comments The DSEIS relies on risk assessments and studies that are woefully out-of-date (ranging from mid-90’s to early to 2000’s) to dismiss health concerns from exposure to herbicides. The Forests need to go back to the drawing board and do an updated and more accurate assessment of herbicide impacts, especially to humans. This should include a thorough review of herbicide research by independent sources. Relying on outdated Risk Assessment documents is insufficient. A new analysis also must take into account the broad range of human vulnerability to herbicides, rather than make generalized statements about their harmlessness to the public. Research cited is outdated. New research is not always considered. Sources in the DSEIS come from as far back as 1987 (glyphosate drift), 1989 (2, 4-D) 1990(hexazinone & chlorsulfuron), and 1995 (picloram). The majority of herbicide-safety research cited is from 2003 or prior, though some citations from 2013 are included. However, the body of research emerging within the last 5 years regarding endocrine disruption and cell death based on toxicity of residue rather than over application. New Research For Mobility of Herbicides & the Role
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of Surfactants is not included. We request that new information be considered regarding the mobility of herbicides in soils as outlined on (p. 116) & the impact of surfactants or inert ingredients (165) on toxicity. Research such as those listed below suggest that herbicides, specifically glyphosate is more toxic when used with a surfactant than when used alone. Also of concern is the lack of inability to assess the inert ingredients and surfactants do to their proprietary nature. We therefore request that the USFS consider this new information when considering environmental and health impacts. Public Involvement Concern: The Forest Service is not providing people with the information they need to comment in a timely manner.
Response: In 2012, the Forest Service asked every person (274 individuals and organizations) who commented during the development of the final environmental impact statement or appealed the 2005 decision whether they wanted to receive paper or electronic copies of the draft supplemental environmental impact statement. Seventeen people responded. When the draft supplemental environmental impact statement was ready in 2014, we notified 298 individuals and organizations of its availability, including sending the paper or electronic copies to the 17 people who had responded to our 2012 inquiry. Legal notices were also published in the Albuquerque Journal and The Taos News. Each of the 2014 notifications included information on how to find the documents online, how to calculate the comment period, and the names and contact information for obtaining more information. Anyone who commented on the draft supplemental environmental impact statement will automatically receive notification of the availability of the final supplemental environmental impact statement and draft decision. A limited number of paper copies will be available.
We are appreciative of the comment stating that the Forest Service needs to be clear as to the location of the notices in the Federal Register. We erroneously assumed people knew where to look, so your advice is well-taken.
Associated Comments Referencing your “File Code: 1950” from the original FEIS you note: “Staying informed: Those who comment will automatically receive a copy of the final supplemental EIS and draft record of decision, both prepared after we review your comments. The record of decision will include a decision from each forest supervisor.” This did not happen, and thus delayed significantly the time that the original FEIS commenters had to comment on this DSEIS. One commenter received the documents. Most received only a form letter, and some received no letter at all. This delayed the number of days people had to respond.
We found absolutely nothing listed about the Project under the “Forest Service” heading in the Federal Register. We reviewed all the possible dates in the Federal Register and found nothing. The assumption one would have then would be that it had not yet been published in the Federal Register. You told us that the federal register is the only source we should use, and that any other source is not reliable in determining the comment due date. Only later, after one person saw a posting in the legal notice of the Albuquerque Journal, and noted that the EPA was referenced in that posting, did we then go back to the Federal Register and find the Project listed under ENVIRONMENTAL PROTECTION AGENCY. This is a significant communication error on your part, as NOWHERE in the DSEIS or the cover letter is the EPA mentioned as the source of the Project listing. As a result, numerous days were lost by the individual commenters. Your overly burdensome expectation that you put on us caused us lost time....(And in the future, you need to note in the document that the Project is listed under “EPA,” and not “Forest Service.”)
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Proposed Action Concern: The Forest Service has changed the proposed action from the original FEIS.
Response: The regulations at 40 CFR 1502.9 state the purpose of a supplemental environmental impact statement is as follows:
"[The agency shall] prepare supplements to either draft or final environmental impact statements if: (i) The agency makes substantial changes in the proposed action that are relevant to environmental concerns; or (ii) There are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts.
Thus, changes to the proposed action are perfectly acceptable. The commenter does not elaborate on the issues they have with the changes, so no further response is required.
Associated Comments The Forest Service has now let eight years pass, and comes back with almost the same proposal that was already rejected, except that the few protections for the environment that were contained in the first version have now been eliminated.
The preferred alternative in the FEIS only contemplated using herbicides on 22% of the treatment areas, or 1,644 acres. The preferred alternative now contemplates using herbicides on all treatment areas without exception, or 13,256 acres. The Forest Service's response to letters and petitions from well over one thousand people opposing any herbicide use is to increase the area it wants to spray eightfold. The number of different herbicides to be used has increased from 12 to 13. The statement that only 8 of them will be "primarily" used has been deleted. The number of weed species to be eradicated has increased from 32 to 37. The prohibition on using herbicides within the boundary of the known population, or occupied habitat, of threatened, endangered, or sensitive species of plants, has been deleted. This has been changed to not using herbicides within 25 feet of individual plants.
The prohibition on the use of high-risk herbicides within a 1,000-foot buffer around the habitat of sensitive species has been deleted. Now both "low-risk" and "high-risk" herbicides are to be permitted within 25 feet of individual plants.
The requirement to limit the use of herbicides, grazing, fire, and heavy machinery near certain heritage resources has been deleted.
The requirement in the Forest Plan Amendment that only allowed herbicide applications if "effective ground cover is quickly restored" has been deleted.
The phrase "mitigation measures" no longer appears in the document. These are now called "design features."
The absolute prohibition on broadcast burning in riparian areas has been deleted. Now it is only banned if it is "solely for the purpose of treating weeds." If treating weeds is one of the purposes, this is now permitted.
The Forest service has added a provision allowing it to "drive off roads to treat weeds.”
The FEIS specified that treatments were only going to occur "along riparian areas, roads, trails, recreation sites, administrative sites, gas/oil pads (and pipelands) and range improvements" and in "areas of recent disturbance." That limitation has been deleted; the DSEIS permits herbicides everywhere.
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Concern: The Forest Service is proposing to use herbicides in the Gallinas Watershed when no evidence of invasive plants being in the watershed exists.
Response: The Forest Service's intent is to be able to treat weeds using the methods, including the specific herbicides listed, as they are discovered in the future (final supplemental environmental impact statement p. 27). Page 22 of the final supplemental environmental impact statement states, "Weeds proposed for treatment are those listed on the New Mexico Department of Agriculture's noxious weeds list, at the time of this writing or listed in the future."
Naturally, no treatments of any kind would occur where weeds do not exist. No weed treatments would occur in the Gallinas watershed unless officials from the City of Las Vegas approve the treatment (final supplemental environmental impact statement, p. 37, design feature #58).
Associated Comments An article, published in the Las Vegas Optic, on January 19th, 2006, under the headline ‘Council rejects herbicide plan – Forest Service says weeds not a problem now’ continues to confuse our community: EXCERPT: “ Two Forest Service Officials – Joe Reddan and Dolores Maese – were on hand to defend the agency’s plan. They distributed a letter from Clifford Dils, acting forest supervisor for the Santa Fe National Forest. The letter states that the agency has found no noxious weeds or invasive plants in the Gallinas Watershed part of the forest.” (Las Vegas Optic, Jan. 19, 2006). Why then was the Gallinas Watershed on the list for herbicide applications if, as the FS later admitted, they found no invasive plants up there?
Concern: The Forest Service needs to implement a robust monitoring program if it uses herbicides to treat invasive plants.
Response: The cornerstone of this project is monitoring and adaptive management. The Forest Service will be required to monitor for 1) the treatment's effectiveness, 2) the effects on other resources relative to those predicted, and 3) the effectiveness of design features used to minimize adverse impacts (final supplemental environmental impact statement, pp. 23 and 38, design features #59-61). If monitoring shows treatments are failing or causing unacceptable effects, the method of treatment will be adjusted (this is the adaptive part).
Associated Comments Failing to require substantive post-treatment monitoring to accurately determine if the thousands of pounds of herbicides to be applied over the next decade will contaminate water resources or increase soil erosion also flaws the project.
Concern: The Forest Service proposes to treat 12,713 by mechanical methods, even though its own analysis states that "[t]hese methods have not been demonstrated to be effective," and that they "reduce plant and root vigor" by compacting the soil.
Response: It appears that the proximity in the final environmental impact statement of Table S-7 to the text quoted by the commenter may contribute to some confusion. Table S-7 (p. 29) shows the maximum acreage that could be treated by the combination of methods shown. Weed species would be treated by multiple methods, using those that are most effective. For example, spotted knapweed could be treated using herbicides, grazing, and by manually pulling. Appendix 7 (final supplemental environmental impact statement pp. 193-196) displays the treatments expected to be most effective for each species. More than one treatment is listed in alternatives B and C because different species respond to different treatments depending on their ecology and location.
Mechanical methods may include mowing, girdling, or root tilling (final supplemental environmental impact statement p. 28). Mechanical treatments may be a preferred method of control given specific
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site conditions. The conditions under which a given treatment method could be used and limitations are provided in Table S-10 (p. 31).
The full paragraph referenced by the commenter is found on p. 29 of the final supplemental environmental impact statement and discusses mowing and root tilling as types of mechanical controls which may occur incidental to road maintenance actions, and does not propose a presumably ineffective treatment method. In full, the paragraph reads, “Mowing and root tilling employ large mechanized equipment such as tractors with specially designed attachments. These methods have not been demonstrated to be effective in eradicating or substantially reducing weed infestations, and typically require repeat treatments. They do reduce plant and root vigor. Feasibility for these two methods is also quite limited on the two national forests due to the steep slopes and other common terrain features such as tree, boulders, or logs. Thus this method is only likely to be fore minor, incidental use mainly along highways in conjunction with ongoing road maintenance actions. Most mechanical treatment is proposed in combination with another method.”
Associated Comments Mechanical treatment, employing heavy equipment such as tractors, has increased even more spectacularly. The FEIS only proposed to do this on 162 acres. Now the DSEIS proposes to treat 12,713 acres this way, even though, on the same page that it proposes to do this (p. 17), it states that "[t]hese methods have not been demonstrated to be effective," and that they "reduce plant and root vigor" by compacting the soil.
Concern: The Forest Plan amendment should not be "nonsignificant" because it allows the use of herbicides in municipal watersheds, in areas of human habitation, and on soils with low revegetation potential.
Response: This project's forest plan amendment for the Santa Fe National Forest will be conducted in conformance with the 1982 planning rule provisions as allowed by the 2012 Planning Rule since the amendment process was initiated prior to May 9, 2012 (36 CFR 219.17(b)(3)). Under the 1982 planning rule provisions, a significant amendment results when: 1) the proposal will significantly alter the long-term relationship between multiple-use goods and services originally projected or 2) the proposal will affect land and resources throughout a large portion of the planning area during the planning period (Forest Service Manual 1926.52).
Associated Comments The Forest Plan Amendment, now allowing the use of herbicides in municipal watersheds, in areas of human habitation, and on soils with low revegetation potential, is suddenly labeled a "nonsignificant" amendment.
Concern: The Forest Service should not use herbicides to treat weeds because the need to do so has not been proven. The acreage of weeds appears to be holding steady without the use of herbicides. Since most infestations are still small, herbicides are not necessary.
Response: In New Mexico, the occurrence of weed species is increasing. Existing populations are predicted to spread, and new weed infestations are projected to appear each year (Renz 2004). While the number of known weed infestation sites on the two national forests is still relatively small, occupying less than half of 1 percent of the 3 million acres of land in the Carson and Santa Fe National Forests, there are likely more weed infestation sites not yet discovered (final supplemental environmental impact statement, p. 14).
Chapter 1 of the final environmental impact statement (pp. 13-34) and final supplemental impact statement (pp. 13-26) describes the reason the two forests have pursued this project. As noted, the small amount of infestations can be controlled now rather than later, so impacts of treatment would be smaller and the costs lower. The potential impacts of weeds known to exist on the Santa Fe and
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Carson National Forests are provided in appendix 2 (final environmental impact statement pp. 213- 221 and final supplemental environmental impact statement pp. 181-183). The final supplemental environmental impact statement and final environmental impact statement examine three alternatives to controlling current (and newly found) infestations. Comparison of effectiveness of the three alternatives is provided. The project is consistent with law, regulation, and policy, and is consistent with the Santa Fe National Forest Plan (final supplemental environmental impact statement p. 167).
The risk assessments provide a review of the use of herbicides in riparian areas and the potential impact to aquatic plants and animals. Selecting the proper herbicide formulation for the situation and then following label directions assures this risk remains low. Some weed species, such as saltcedar, are most effectively controlled with the use of herbicides; other weeds can be eradicated by manual or mechanical means only.
The final supplemental environmental impact statement discloses cumulative actions considered in the effects analysis. Table S-14 (pp. 44-47) lists projects considered as past and present actions. Table S-15 (pp. 47-48) lists projects considered as reasonably foreseeable future actions. A summary of cumulative actions for each key resource is provided in Table S-16 (pp. 49-50). Specific information on past, present, and reasonably future weed control activities are described in appendix 1 of the final supplemental environmental impact statement (pp. 201-211). Because no forestwide, integrated weed treatment strategy exists, any herbicide use proposed for these projects would have been considered on a project-by-project basis in the appropriate National Environmental Policy Act analysis.
Associated Comments
The Forest Service admits that the Carson and Santa Fe National Forests are not being inundated by weeds, and that the area occupied by weeds is no larger now than it was nine years ago. It now says that 15,260 acres are occupied by weeds, up from 7,260 acres, but the agency states that "the increase in weeds in the project area is mostly explained by more surveys of the locations of weeds," and not by an actual increase. Yet the agency has come back with a plan to spray, in perpetuity, lands throughout the over 3 million acres of these forests, including wilderness areas, inventoried roadless areas, wild and scenic rivers, research natural areas, endangered species habitat, municipal watersheds, highly used developed recreation areas, and areas of human habitation, repeatedly with up to thirteen different toxic herbicides, which do not distinguish between healthy and sick, young and old, and which will render all of our public lands permanently inaccessible to a large disabled population. The DSEIS did not fully disclose under what guidelines the FS has been managing the invasive plants since that time. Specifically what measures have been used in the past 8-10 years since the ROD reversal, and where? If noxious plants were such a problem back in 2004 when the FEIS came out, how and where has the FS been addressing the problem in the meantime while the DSEIS was being written? Was the problem ignored? Was a nonchemical approach used? If so, how successful was it? If successful, why not continue with a non-herbicide approach? Was the herbicide ban lifted without the affected communities being informed, including the City of Las Vegas which passed a resolution in 2006 in strong opposition to the FEIS, including herbicides in the Gallinas Watershed? Though general comments were made (nearly identical to the FEIS), no specific explanation was presented in the DSEIS. The DSEIS states that “[m]ost infestations [of invasive plants] (more than 75 percent) are less than 1 acre” DSEIS at 6. This fact makes it clear that the invasive plant problem on the Carson and Santa Fe forests is still at a point where it can be managed without widespread herbicide use.
Note: The estimated acres occupied by noxious weeds is actually 13,260. There was a typographical error in the draft SEIS that reported the acres as “15,260”. The estimated acres are 13,256 which is rounded to 13,260.
Concern: The design features and monitoring requirements for this project do not include any instruction for monitoring for potential spread or introduction from controlled grazing operations. It is important to include direction for this specific project method in order to ensure that grazing is not inadvertently facilitating the spread of invasive plants to other forest lands or outside forest lands.
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Response: The final supplemental environmental impact statement and final environmental impact statement recognize the potential for controlled grazing to inadvertently disperse weed seeds and proposes counteractive measures through management considerations. Pages 39 - 40 of the final environmental impact statement state,"... sheep and goats will not typically graze the target weed species to the exclusion of native plants. Another consideration is that weed seeds may adhere to the coats of long-haired breeds of goats, or the fleece of sheep, which could contribute to the spread of weed seeds if not addressed in the application of the method (that is, require animals to be sheared prior to entering an infestation). Animals should be confined to a restricted area for an appropriate length of time after moving from an infested area when there is a concern that viable weed seeds may be spread through the animals’ feces."
Further, controlled grazing is proposed as a minor, incidental treatment method requiring evaluation for its effectiveness. A site-specific operation plan, which could include the measures suggested by the commenter, would be developed for each treatment area. The plan would consider the target species, type of livestock, forage preference, planned grazing intensity, herding characteristics, topography, water availability, season of use, and a monitoring program (final environmental impact statement, p. 40).
Finally, the Forest Service recognizes the potential for native plants to be removed causing soil exposure and proposes a mitigation measure for it (final supplemental environmental impact statement, p. 34, design feature #19). Effectiveness monitoring will be incorporated as described at design feature #60 (p. 38).
Associated Comments One of the proposed methods for invasive plant removal through this project is “[c]ontrolled grazing using goats and sheep to intensively and repeatedly graze weeds.” DSEIS at vi. The treatment objectives for this project are eradication, control, and containment. DSEIS at vii. The DSEIS asserts that “[p]roperly managed, controlled livestock grazing can work in combination with other methods to reestablish healthy, resilient native plant communities.” DSEIS at 50. While targeted grazing by sheep and goats can successfully control some invasive plant populations, there is also a risk of spread of invasive plants by ungulates through seed dispersal, selective grazing, and soil disturbance. (Vavra et al. 2007). Therefore, this type of invasive control method should be carefully implemented and monitored. However, the design features and monitoring requirements for this project do not include any instruction for monitoring for potential spread or introduction from controlled grazing operations. It is important to include direction for this specific project method in order to ensure that grazing is not inadvertently facilitating the spread of invasive plants to other forest lands or outside forest lands. We recommend including the following restrictions for sheep and goat grazing as part of this project:
• Sheep and goat grazing should be restricted to areas in which seasonal seeding has not yet occurred
• Keep sheep and goats that have grazed on invasive plants in a holding field for 24-48 hours before relocating them
• Maintain intensity and duration of grazing at a level that minimizes disturbance to native plants
Concern: The requirement to reseed or replant after treatment has been deleted. The Forest Service no longer pretends to care whether anything grows back, least of all native plants. The only important purpose of this project is evidently to use as many chemicals as possible regardless of the outcome.
Response: Reseeding after treatment remains an option (final supplemental environmental impact statement, p. 34, design feature #19). The mandatory requirement to reseed has been removed because in some situations, native plants will naturally recolonize.
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Alternatives Concern: The Forest Service fails to consider the reasonable alternative of preventing weeds and educating people about the spread of invasive plants.
Response: The Forest Service considered the alternative of preventing weed infestations (final environmental impact statement p. 36). It is not an alternative analyzed in detail for three reasons: 1) National Environmental Policy Act analysis is not required to implement prevention measures, 2) prevention alone would not meet the purpose and need, and 3) the Carson and Santa Fe National Forests regularly implement prevention measures as part of other projects (for example, requiring vehicles to be washed prior to entering project areas).
As discussed on page 31 of the final environmental impact statement, the scope of this project and decision does not extend to weed prevention and education activities. While the staff on the Carson and Santa Fe National Forests recognizes prevention and education are essential components of an overall integrated weed management strategy, proactive weed prevention and educational activities are already being implemented and do not require additional environmental analysis and decision- making under the National Environmental Policy Act.
As discussed on page 36 of the final environmental impact statement, the "prevention" alternative would not meet the purpose and need because it would not effectively reduce existing weed infestations or address the detrimental impacts of those infestations. It would not reduce the threat from undiscovered weeds that exist now or are expected to invade despite preventative measures. Weed prevention is already being used on both national forests and is often integrated as a mitigation measure during planning for ground-disturbing projects, such as the requirement to wash vehicles prior to use on the two national forests.
Associated Comments The people need to be made aware of the different toxic weeds. I have seen people pick the weeds because they have a pretty bloom not knowing how toxic the weeds are to people and animals. I have also seen hunters just drive their 4 wheelers through the weeds. Which that means they are carrying the weed seeds on the tires and distributing them elsewhere. Also hikers and horseback riders do the same thing....My biggest complaint about the weeds is that everyone just rides, walks and pick them. Those people are not realizing that they are transplanting everywhere. The project fails to consider the reasonable alternative of prevention....The DSEIS fails to consider the reasonable alternative of prevention. The purpose of the project is “controlling invasive plants designated by New Mexico as weeds” (FEIS, p. 13). (“The purpose and need for controlling or eradicating weed infestations on the Forests is to maintain or improve the diversity, function, and sustainability of desired native plant communities on the Forests”; “Controlling the spread of weed species is now a regional and national priority in the Forest Service....”). Prevention is widely acknowledged to be an effective means of controlling weed infestations. Nonetheless, the USFS refused to consider an alternative that contained thorough measures to prevent the spread and establishment of weeds....The DSEIS briefly acknowledges that weed infestations occur along roads and at natural gas wellheads but never discloses or discusses other causes. Having failed to fully and thoroughly disclose the causes of weed infestation, the DSEIS then refuses to consider prevention as a viable alternative. In several places, the DSEIS defines the project’s purpose as weed control. Prevention is an obvious and reasonable approach to achieving that purpose. Prevention reduces the frequency and severity of weed infestations, including reinfestation after treatment....NEPA requires the consideration of all reasonable alternatives; there is no exception, and no apparent basis in the DSEIS, for refusing to evaluate an action that is already being done. Moreover, the claim is not supported by the record. At most, the DSEIS supports a conclusion that the prevention activities are sporadic. For example, the only specific prevention measure mentioned is washing vehicles, and even then, the DSEIS does not say which vehicles, where, when and how. Certainly, the USFS is not monitoring all the roads and trails in the national forests, hoses at the ready. The DSEIS also suggests that some individual projects contain weed prevention measures, but it is not clear which projects, what measures and how
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effective....Because prevention is a reasonable alternative to achieving weed control, both now and in the future, the Forest Service’s failure to consider it violates NEPA. The USFS has a legal duty to evaluate all reasonable alternatives, and the prevention alternative satisfies the project purpose. Other national forests have adopted a wide range of prevention measures to control weeds, including cleaning vehicles entering the national forest, requiring certified weed-free hay for pack animals, designing projects to minimize impacts to weed-suppressing canopy-type vegetation, minimizing soil disturbance and other conditions that promote weed germination and establishment, revising grazing allotment management plans to incorporate invasive plant control measures such as closing infected pasture, designating infected pastures as unsuitable until infestations have been treated, managing the timing, duration, and intensity of grazing to maintain the vigor of native plants and retain live plant cover and litter, and restoring areas of concentrated use such as loafing and watering sites, controlling vehicle traffic through areas of known weed infestation, and enforcing OHV restrictions. The managers of these forests, 8 like many weed experts, understand that these measures are easier, more environmentally desirable,
The Forest Service clearly acknowledges the problem of continued introduction and spread of invasive plants, and concedes that “it appears the overall trend is towards the establishment of new weed populations.” DSEIS at 53. For example, weeds could establish themselves in areas where activities disturb soil, such as thinning, firewood gathering, prescribed burning, dispersed recreation, grazing, road maintenance, road building, and decommissioning even with preventive measures in place. Ongoing, common activities in the Carson and Santa Fe National Forests by weekend recreationists, forest firefighting crews, grazing allotment permittees, or livestock all have the potential to unknowingly spread weeds from one location to another, bring them onto National Forest System lands, or spread them onto other lands. Id. However, this proposed project does nothing to address those sources or reduce the continued introduction of invasive plants. Without including a comprehensive strategy to address introduction and spread of invasive plants, it is impossible for the Forest Service to assert in good faith that carrying out any alternative will result in the eradication and containment of all invasive populations on these forests. See DSEIS at 42.
Concern: The Forest Service should use herbicides only in extreme situations where other methods are found to be ineffective. If the Forest Service makes a decision to retain herbicide use as an allowable action for this project, it should limit such use to areas in which no other methods would be effective, effectively making herbicide use a treatment of last resort.
Response: Through experience with similar Forest Service efforts, we know herbicides are the most effective treatment method for eradicating or controlling the weed species that currently exist on the two national forests, especially when used in conjunction with an integrated treatment effort that improves the effectiveness of nonchemical treatments, either concurrently or as follow-up treatments. Herbicides are being proposed for weed sites where non-herbicide methods do not seem feasible or appropriate, due to ineffectiveness of other treatments, species characteristics, population size, treatment priority and objective, or access or terrain limitations of other methods (final environmental impact statement, p. 37).
Associated Comments According to the Forest Service’s summary of treatments for Alternative B, herbicides could potentially be used on every single affected acre within the Forest. DSEIS at 17, tbl. S-7. As Alternative C demonstrates, herbicides are not necessary to eradicate or control invasive plants. Rather, if implemented properly using an adequate number of Forest Service personnel and volunteers, a variety of other methods can lead to the eradication and control of invasive plant species. Therefore, the Forest Service should use herbicides only in extreme situations where other methods are found to be ineffective. If the Forest Service makes a decision to retain herbicide use as an allowable action for this project, it should limit such use to areas in which no other methods would be effective, effectively making herbicide use a treatment of last resort.
Concern: The Forest Service does not discuss the fact that volunteers and community members would be available to assist in execution of this project, especially if the project does not require the application of
216 Final Supplemental Environmental Impact Statement herbicides requiring special training. The Forest Service should more seriously consider the potential availability of volunteers and how this may facilitate faster and more effective treatment under Alternative C.
Response: The Forest Service relies on volunteers for many types of field work. In 2014, volunteers contributed approximately 13,000 hours of work for the Santa Fe National Forest alone. The types of work performed were clearing and repairing trails, repairing bridges, cleaning up trash, inspecting trails, and installing signs. We expect some people would be interested in treating weeds but anticipate it would be a very small percentage, and even smaller in backcountry locations. We do not anticipate, based on past interest in weed treatment projects, volunteers would be able to treat significant acreages of weeds in a manner that would completely eradicate them; for example, some weed patches would need repeated treatment for up to 10 years before weeds would be eliminated.
Associated Comments The Forest Service relies on the fact that due to funding levels “the acres treated would logically be fewer in alternative C than alternative B,” therefore under Alternative C “it is likely that the rate of weed spread would exceed the rate of weed control.” DSEIS at 51. However, the Forest Service does not discuss the fact that volunteers and community members would be available to assist in execution of this project, especially if the project does not require the application of herbicides requiring special training. The Forest Service should more seriously consider the potential availability of volunteers and how this may facilitate faster and more effective treatment under Alternative C.
Concern: Include information about alternatives to herbicides and why these alternatives were not used in lieu of herbicides to control invasive plants. If the alternatives to herbicides weren’t used because of extra cost, indicate the cost difference between the alternatives and herbicides. If the alternatives are less effective than herbicides include data and information supporting the claim. Purge the EIS of all insane statements describing the false dangers of these methods.
Response: Alternative B (the proposed action) proposes an integrated approach to control invasive plants, recognizing one treatment method alone is not likely to be effective. The integrated approach includes herbicides, biological controls, grazing, manual removal, mechanical treatments, and prescribed fire. A cost-benefit analysis was provided in the final supplemental environmental impact statement (pp. 165-166), which included the treating and monitoring of known and new weed infestations.
Alternative C was developed as an alternative which involves conducting weed treatments over the same acres as Alternative B, except no herbicides would be used. Table S-13 (final supplemental environmental impact statement p. 13) provides a comparison of alternatives based on the significant issues or effects, as well as how well the alternatives meet the purpose and need (objectives) for the project. The comparison table is intended to provide the public and decision makers with a basis for choice between alternatives. Effects Analysis Concern: No scientific consensus on the effects of herbicides to human health exists. Thus, the burden of proof showing that herbicides cause no harm to people is on the Forest Service. Until the agency can prove that no harm will be done, it should abstain from using herbicides.
Response: The precautionary principle has another aspect, which is a lack of scientific evidence does not preclude action if damage would otherwise be serious and irreversible. If there are threats of serious or irreversible environmental damage from not acting, a lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation.
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In its proposal, the Forest Service has undertaken careful measures to avoid, wherever practicable, harm to people, wildlife, and other natural resources when using herbicides. The 58 design features listed on pages 33 through 38 of the final supplemental environmental impact statement ensure the risk of herbicide use is at a minimum. For instance, areas would be closed during application. Further, Environmental Protection Agency registration includes an assessment of risk given the toxicity of a substance and expected use and exposure. The Environmental Protection Agency regulates the use of registered products so the more likely a dose is to exceed the level of concern, the more heavily regulated the use. This provides an overall level of assurance no harm will come to people or animals from the use of the products.
When viewed against the extremely low risk of exposure, the environmental damage posed by not controlling or eradicating weeds is much greater. As described in the final environmental impact statement and final supplemental environmental impact statement, weed invasion and spread results in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability, and water quality. The harmful effects of weeds to ecosystems are described in detail in the final environmental impact statement (pp. 13 - 16) and the final supplemental environmental impact statement (pp. 13- 14). The potential impacts of specific weeds known to exist on the Santa Fe and Carson National Forests are provided in appendix 2 (final environmental impact statement pp. 213-221 and Table S-53 (p. 118) of the final supplemental environmental impact statement.
Associated Comments While concerns about non-native species are justified, it is rarely mentioned that by far the most destructive invasive species in the U.S. are non-native humans. This proposal is a prime example of the human compulsion to meddle in processes largely beyond our control with the likely outcome that many of the actions taken will cause more harm than good. In the case of using herbicides, the hazards are certainly not worth the risks. requested that USFS address the concern of cumulative effects. The DSEIS does include a section with this topic but includes statements such as (P 40)"risk of exposure [to wildlife] is immeasurable" so "cumulate effect cannot be measured" but "unforeseen accidents expected." We propose that this immeasurable risk is too much risk and should either be soundly measured or this alternative should be rejected on the basis of the precautionary principle.
The Forest Service relies on the fact that “risk assessments concluded that potential risks of harm to most wildlife species are low for herbicide formulations proposed for use at the rates and application methods proposed” for the conclusion that “herbicides, when used at the application rates and concentrations listed on the labels, would have a very low risk of causing harm (short or long term) to wildlife species.” DSEIS at 60. However, a risk remains and there is no information available at this time as to the effects on wildlife species from exposure to the combination of herbicides that could potentially be used in this project. Moreover, the herbicides proposed for use, as identified in the DSEIS at pg. 160, table S-64, have been found to have negative impacts on plant and animal species. See DSEIS at Appx. 3. Additionally, numerous other studies have identified negative impacts on plants and animals from these herbicides. Aminopyralid and picloram can negatively impact ponderosa pine. (Wallace et al. 2012). 2,4-D is an endocrine disrupting chemical that has been documented to harm wildlife species through hormone disruption. (Colborn et al. 1993). Dicambia, glycophosate, triclopyr, and 2,4-D can cause animal mortality and other adverse effects. (USDA 2007). While these impacts may be mitigated by the amount of herbicides used in project treatments and through other mitigation measures, it is likely that chemical application throughout forest lands will negatively impact wildlife in some way. Moreover, use of herbicides always involves a risk to human health and safety. The Forest Service should take a precautionary approach to actions that have the potential to negatively impact plant and animal populations on National Forests, especially where the possible effects are uncertain. Due to the wide variety of other methods available to deal with the invasive plant problem on the Carson and Santa Fe National Forests, the Forest Service should avoid using herbicides for this project to minimize risk and prevent unintended or unforeseen negative impacts to plant and animal species.
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Concern: The proposal to treat over 15,000 acres with a variety of herbicides will result in decreased viability and the unacceptable death of some native plants.
Response: The Forest Service would treat weeds by the method best suited for eradicating or controlling them. Though herbicides are listed as an option for treating all weed species (final supplemental environmental impact statement, appendix 7 pp. 193-196), they may not be the first choice or most effective method for the species or combination of species present.
The Forest Service expects to treat an average of 600 to 1,600 acres of weeds each year, with a maximum of no more than 3,000 (final supplemental environmental impact statement, p. 52). Protections for native plants are mandated (final supplemental environmental impact statement, pp. 34-35, design features #15-32). By treating smaller acreages, the Forest Service will be able to monitor the effects of treatments on native plants and adjust future treatments accordingly to prevent harmful effects (final supplemental environmental impact statement, p. 38, design features #60-61).
On balance, weeds are more harmful to native plant communities than weed treatments. Weeds threaten the biological diversity of native plant communities, ecosystem processes, and rare or special status plants. Weeds are highly adaptable and adept at usurping available moisture and nutrients, quickly spreading, and supplanting native vegetation. Weed infestations invariably lead to (1) a decline in abundance of native plants that occupy the same or similar habitats as the weeds, (2) undesirable changes in site conditions such as soil pH that may be vital to native plant survival, and (3) an overall loss in the richness and diversity of native plants (final supplemental environmental impact statement p. 52).
The potential effects to vegetation, including native species, and to special status plant species is presented in the final supplemental environmental impact statement (pp. 56-65).
Associated Comments One of the purposes of the project was originally to encourage "culturally important plants such as osha, wild spinach, willow, and purslane" which decline where weeds occur. This purpose has been deleted, perhaps because those culturally important plants will be decimated, not encouraged, by the quantities of herbicides now envisioned. However, as currently proposed, Alternative B and Alternative D would allow the use of herbicide application on every acre needing treatment, either alone or in conjunction with other treatment methods. DSEIS at 47-50. Due to the functionality of herbicides, it is likely that treating over 15,000 acres with a variety of herbicides will result in decreased viability and death of some native plants within both the Carson and Santa Fe National Forests. The Forest Service recognizes those threats in the DSEIS: “Effects [of herbicide use] would be a change in composition of forbs, grasses, and shrubs in treatment areas. Nontarget plants could be damaged by unintentional application, drift, or residual soil activity of herbicides.”
Concern: The Forest Service has not addressed the possibility that invasive plants will become resistant to herbicides, thus requiring treatment with new herbicides and the hazards that go along with them.
Response: The final environmental impact statement addresses the possibility invasive plants will become resistant to herbicides (pp. 37-38). Weeds can potentially develop resistance to herbicides if used repeatedly (final supplemental environmental impact statement, p. 61). To reduce this possibility, herbicides would be used in rotation with other methods (final environmental impact statement, p. 38). Where weeds have demonstrated resistance to herbicides (expected to be a rare occurrence in the two national forests) mixtures could be used (final environmental impact statement, p. 37).
Only those herbicides analyzed for use (final supplemental impact statement, p. 28) can be used under this decision. New herbicides would be subject to additional NEPA analysis.
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Associated Comment Herbicides are not a viable option for use in perpetuity: Page 33 of the DSEIS states that "activities are anticipated to occur over approximately 10 years (or more)…" with activities increasing over the 10 year period (p 34). We wish to raise concerns regarding the development of resistance which is happening in other areas which have been treated with herbicides over a number of years, requiring that they be treated with alternative herbicides....Why are herbicides not used only as a last resort? What steps will be taken to address the possibility of the development of resistance?
Concern: The length of time that herbicides remain in soil is not consistently described in the effects analysis, thereby rendering a sound decision on their effects to resources impossible.
Response: The length of time (half-life) herbicides remain in soil is dependent on many factors. Among these are the method and amount of herbicide actually applied to the soil (surface application of a herbicide directly onto or into the soil, incidental “drip” onto the soil surface from application to weed foliage), and the volatility characteristics of a particular herbicide. This analysis offered a variety of studies examining this question, each with variables that make direct comparison of the results of those studies difficult. Mitigation measures and design features included in the final environmental impact statement and the final supplemental environmental impact statement were developed to minimize the risk of direct application of herbicides to the soil and focus treatment methods directly to the weed species being treated rather than broad scale and indiscriminate application of herbicides that would surely increase the risk and effects to the soil, water, and aquatic life resources. Specific herbicide characteristics, including half-life, is provided in appendix 3 of the final environmental impact statement (pp. 223-285) and final supplemental environmental impact statement (pp. 185-192).
Associated Comments What is the half-life of the herbicides? 24 hours? One year? Three years? More? Does anybody know? The Forest Service seems to use whatever number it needs in order to support the point that it wants to make on a particular page. On page 95 of the DSEIS it claims that "[t]he risk of herbicides leaching through the soil into groundwater is low" because "[t]he half-lives (the time it takes for half the active ingredient to degrade) of most of the herbicides are 24 to 48 hours." Therefore, it says that "[t]he direct and indirect effect to groundwater quality from the action alternatives is minor to immeasurable." (at p. 108). Then a few pages later, it says that "[h]erbicides are expected to have effects on soils for a year." (at p. 115). Then it says that glyphosate has a half-life of up to "several years." (at p. 116). Then it says that picloram "last[s] longer in soil" and is highly leachable. (at p. 118). And the FEIS says that "[p]icloram can be highly leachable in some soils" (at p. 319), that it "maintain[s] toxicity to plants for up to 3 years" and that "[t]he half-life can vary from one month to 3 years." (at p. 273).
Concern: The following statement contained within the DSEIS is misleading and arbitrary and should be removed: By controlling the spread of weeds and protecting native plant communities, habitats and watershed conditions on the two national forests, alternatives B and D would maintain or enhance social or economic conditions, particularly for local rural communities in northern New Mexico who typically rely on the two national forests’ natural resources for their livelihood, traditional culture and quality of life. DSEIS at xii, 29. Alternative C would also maintain social and economic conditions by achieving the same result, albeit through different means. By abstaining from including Alternative C in this paragraph, the Forest Service suggests to readers that it would negatively impact social or economic conditions, which is unsupported by any evidence presented by the Forest Service.
Response: Upon review, we agree with the comment. Any of the action alternatives are expected to maintain or enhance social or economic conditions for local rural communities over the no action alternative. Alternatives B and D would treat more acreage with more success than alternative C in the same period. The statement has been removed from the final supplemental environmental impact statement.
220 Final Supplemental Environmental Impact Statement
Associated Comments Finally, the following statement contained within the DSEIS is misleading and arbitrary and should be removed: By controlling the spread of weeds and protecting native plant communities, habitats and watershed conditions on the two national forests, alternatives B and D would maintain or enhance social or economic conditions, particularly for local rural communities in northern New Mexico who typically rely on the two national forests’ natural resources for their livelihood, traditional culture and quality of life. DSEIS at xii, 29. Alternative C would also maintain social and economic conditions by achieving the same result, albeit through different means. By abstaining from including Alternative C in this paragraph, the Forest Service suggests to readers that it would negatively impact social or economic conditions, which is unsupported by any evidence presented by the Forest Service.
Concern: Herbicide use in areas having low revegetation potential will result in increased rates of soil erosion because studies show that these areas will not revegetate over more than 10 percent of their area within 6 months.
Response: Revegetation potential of a soil is defined by physical characteristics (texture, depth, etc.) of the soil and prevailing climate characteristics of the locale. While there is some risk of soil loss and loss of water quality associated with soils with low revegetation potential, there is far greater risk to soil and water resources from establishment and spread of invasive weeds on these sites. Without treatment to address the establishment and spread of invasive weeds on soils with low revegetation potential, the risk of resource impacts and loss of ecosystem services is far more likely. This project includes a design feature #19 to specifically address the need to revegetate soils (final supplemental environmental impact statement p. 34)
Associated Comments Concerning the clause of the amendment allowing spraying in areas with low re-vegetation potential (P117), we disagree that negative impacts will be overcome within 6 months. Other research has shown areas with low re-vegetation potential may not recover more than 10% of their vegetation cover, which still exposes 90% of the ground to potential erosion by wind and water. Sites with low re vegetation potential tend to already have low hydrologic integrity. (http://age- web.nmsu.edu/saltcedar/Restoration%20in%20the%20Southwest.htm
Response: Additional information concerning white-tailed ptarmigan population trends has been added to the final supplemental environmental impact statement. The effects of all alternatives on the white-tailed ptarmigan were analyzed in the final supplemental environmental impact statement (pp. 65-94). On page 70 of the final supplemental environmental impact statement, Table S-32 shows population and habitats for white-tailed ptarmigan. On page 75 of the final supplemental environmental impact statement, Table S-33 (effects to management indicator species) displays effects of the alternatives to white-tailed ptarmigan as a management indicator species. The weed management alternative B, C, and D would results in “No impacts to population or habitat trend are expected because weeds aren’t expected to thrive at these higher elevation alpine and subalpine habitats, so very little of the ptarmigan habitat would be treated on an annual basis. This means at any time, over 99 percent of the ptarmigan’s habitat would be intact.” On page 83 of the final
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supplemental environmental impact statement, Table S-37 shows the estimated amount of habitat for white-tailed ptarmigan (Forest Service sensitive species) with the estimated acreage of known weed infestations within associated habitat and percent of habitat infested with weeds. On page 87 of the final supplemental environmental impact statement, Table S-41(sensitive species: effects to birds) analyzes and discusses the alternatives and effects to the white-tailed ptarmigan and its habitat. Also, the biological evaluation, page 9, states that there will be no impacts expected to the white-tailed ptarmigan. The proposed action would not be expected to decrease population viability or cause a trend to federal listing of this species.
Associated Comments The status of the white-tailed ptarmigan has not been further investigated....Deciding Officer specifically instructed the Forest Service to do this. Yet the DSEIS retains the identical language that was in the FEIS: "Little is known about this avian species in New Mexico, for it lives on the windswept tundra above 11,000 feet." The only difference between the two documents is that in the DSEIS the Forest Service adds a single unreferenced, unsubstantiated sentence saying "white-tailed ptarmigan habitat and population trend are considered stable"-a statement that is contradicted by the statement that "little is known" and that was clearly added for the sole purpose of addressing the objection of the...Deciding Officer. A statement that addresses the form and not the substance of her objection does not comply with NEPA's requirement for a detailed analysis.
There is still inadequate analysis of the population trend for ptarmigan.
Concern: The Forest Service fails to sufficiently analyze the effects of the project on the American pika.
Response: The effects of all alternatives on the American pika were analyzed in the final supplemental environmental impact statement (pp. 65-94). Page 84, Table S-38 (sensitive species/mammals), shows the estimated amount of habitat for pika with the estimated acreage of known weed infestations in associated habitat and percent of habitat infested with weeds. “The American pika inhabits high elevation rocky slopes in the Sangre de Cristo Mountains at elevations above 10,000 feet (final environmental impact statement, pg. 89, Table S-42)." Page 89, Table S-42 (sensitive species: effects to mammals), analyzes and discusses the alternatives and effects to the pika and its habitat. The American pika was also fully analyzed in the biological evaluation for the final supplemental environmental impact statement. The evaluation, p. 12 states the proposed action will have no impact on the American Pika as no activities would occur in habitat used by this species.
Associated Comments The American Pika has been sighted in areas not previously listed hence need more studies to determine the claim that there will be no disruption to the American Pika....As sightings of American Pika have been confirmed by individuals in areas not currently listed as known habitat. For this reason, intensive surveying will have to be done before herbicides can be allowed in an area, as outlined the USFS plan. Additionally, it is stated on page 81 that American Pika will not be impacted by herbicide spraying as it does not use weeds as a forage. As herbicides are non-specific they will not only kill weeds, but impact other palatable plants to the Pika and will therefore pose a threat to an endangered species. AMERICAN PIKA, Serpent Lake, 2012: 20 And what of the small bodies of water like this – the Pika’s watering hole? How is this species to be protected from ingesting herbicides? “No increase in weeds and therefore no decrease in grasses are expected within [the pika] habitat.” Not only is that not backed up by science, but it’s not even logical. Since their populations are not properly mapped, and since the DSEIS provides no documentation or even logic re: the pika’s proposed food supply, this species is at risk due to the Project’s Alternative B. The same can be said for the Goat Peak Pika. 21 The American Pika is now being seen in areas not previously listed. More studies are needed. Who will fund those studies? In the above recent photos, taken by Cynthia Riley (one of our individual commenters listed here), these American Pika were spotted at Serpent Lake. It is woefully inadequate to simply say, as the DSEIS states on p. 81, “no disturbance to the pika from treatments is expected. Weeds are generally not consumed by the pika.” Also, with 2,4- D consuming all plants as it is
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nonspecific, protection of the Pika food supply will be negatively impacted. And with 2,4-D increasing palatability of plants, and as the normal food supply decreases, this increases the poison risk to the Pika. And in the FS own words: “Analyses suggest that both chronic stresses (average temperature during all of summer, snowpack and growing-season precipitation), acute (hot and cold) temperature stresses, and vegetation productivity may all be playing a role in pika declines in the Basin over the last decades.” (http://www.fs.fed.us/ccrc/topics/wildlife/mammals/) Will there be carcass searches as part of the follow-up protocol, e.g., for at least 14 days depending on the species? Herbicide applications are frequently being delayed now due to decreased assurance of the timing of the hibernation period for multiple species, including the meadow jumping mouse. (e.g., http://www.pesticides.montana.edu/Present/Environmental/Anticoagulants%20training%20A ugust%202013%20[Compatibility%20Mode].pdf)
Concern: The Forest Service fails to sufficiently analyze the cumulative effects on wildlife.
Response: Cumulative impacts of the alternatives are evaluated on past, present, and reasonably foreseeable future actions whose direct and indirect effects have the potential to overlap with the direct and indirect effects of the alternatives in both time and geographic space.
This analysis uses current environmental conditions as a proxy for the impacts of past actions. This is because existing conditions reflect the aggregate impact of all prior human actions and natural events that have affected the environment and might contribute to cumulative impacts.
The cumulative impacts analysis does not attempt to quantify the effects of past human actions by adding up all prior actions on an action-by-action basis. A catalog and analysis of all past actions would be impractical to compile and unduly costly to obtain. Current conditions are the result of innumerable past actions, and trying to isolate the individual actions that continue to have residual impacts would be nearly impossible.
Providing the details of past actions on an individual basis would not be useful to predict the cumulative impacts of the alternative. Focusing on individual actions would be less accurate than looking at existing conditions. There is limited information on the environmental impacts of individual past actions, and one cannot reasonably identify each and every action that contributed to current conditions. By looking at current conditions, we capture residual effects of past human actions and natural events regardless of which particular action or event contributed to those effects.
The Council on Environmental Quality issued an interpretive memorandum on June 24, 2005, regarding analysis of past actions, which states, “agencies can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into the historical details of individual past actions” (Connaughton, 2005).
“Reasonably foreseeable future actions are those federal or non-federal activities not yet undertaken, for which there are existing decisions, funding, or identified proposals” (36 CFR 220.3). “Identified proposals for Forest Service actions are those for which the Forest Service has a goal and is actively preparing to make a decision on one or more alternative means of accomplishing that goal and the effects can be meaningfully evaluated (40 CFR 1508.23)” (36 CFR 220.4(a)(1)).
On pages 44-47 and 49-51 of the final supplemental environmental impact statement, Tables S-14 and S-16 discuss past and present actions contributing to the cumulative effects baseline and the summary of cumulative actions by key resource, including wildlife and fish.
On pages 65-94 of the final supplemental environmental impact statement, each grouping of wildlife species (management indicator species, threatened and endangered species, Forest Service sensitive species, and migratory birds) has a cumulative effects analysis section. Cumulative effects analysis is
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provided for fish and aquatic resources on pages 94-102 of the final supplemental environmental impact statement.
Associated Comments The Forest Service has still not analyzed the cumulative effects on wildlife....Deciding Officer clearly instructed the agency to "strengthen" and "document" the section on cumulative effects with respect to wildlife. The Forest Service has utterly failed to do this. "Strengthening" does not mean merely repeating the same conclusory sentence four more times. Yet that is exactly what the Forest Service has done, and no more, in the DSEIS. There is still inadequate evaluation and documentation of environmental cumulative effects. For example, there is no mention of piscicides being regularly used by the NM Game & Fish Department in the Carson Forest, and no analysis of the cumulative impact on fish exposed to piscicides along with herbicides applied in or near water.
Concern: The Forest Service has failed to completely analyze the effects of herbicide use on pollinators.
Response: Per Appendix 9 (Response to Comments) 2005 final environmental impact statement. “The DEIS/FEIS, Appendix 3 discusses the known effects to a variety of species. The summary in Appendix 3 reflects knowledge presented in the risk assessments. The most likely known information involves honey bees because the EPA requires tests on bees as part of the product registration process. The risk assessments describe known effects of the proposed herbicides to a variety of other species, where studies have been conducted. Indirect effects of the vegetation treatments have also been included for MIS and TES species as directed. The risk assessments present information about other species, including beneficial invertebrates.”
Furthermore, Table S-47 (p. 98) of the final supplemental environmental impact statement includes discussion and analysis of the alternatives and effects of herbicide to the Nokomis fritillary butterfly as a pollinator.
Associated Comments Please no herbicides - they are killing the bees and our environment - don't make it worse by using more of these poisons. We remain concerned that the DEIS and the previous one that was appealed in 2005 failed to completely analyze the effects of pesticide use. Your species of concern, Including pollinators (bats, bees, butterflies, etc.) and Amphibians (frogs, toads, lizards, etc.)...All the above species are in severe decline both locally and worldwide. The current drought and climate change (warming, increased storms, increased erosion etc.) only further threaten populations and habitat of these species.... Yet The DEIS fails to acknowledge these species, their declines and how 4) With the exception of the Jemez salamander we did not see any discussion of the impact of herbicide use on the vital pollinator species-or upon other frogs, toads and lands,... 5) Because of threats to pollinators world-wide especially 1) colony collapse disorder in bees. 2) White nose syndrome in bats. 3) Chytrid fungus in frogs. These species are threatened with extinction and herbicide use puts them at further risk. Because bees, butterflies and bats rely upon plants for host sites, pollen, and nectar. Plants like these and the invasive (olive, salt cedar) provide housing for these species. So treatments using herbicides on such invasiveness has the potential to harm any bees, bats butterflies, moths and other species. The DEIS supplement failed to address their concern or even analyze it. The airborne species are critical for ecosystem health and pollination. Herbicide use threatens their viability especially with cumulative impacts of airborne diseases, habitat loss and climate change. Also butterflies and moths they visit hundreds of plants both native and non-native (invasive and non-invasive included). Herbicide use would negatively affect (A likely kill) such species, yet no analysis…. A beneficial insect census should accompany these treatments, as bees and butterflies, pollinators especially for which flowers are their habitat and they don't discriminate against "weeds". Removing food supplies by the acre may be the sort of imbalance that effects hives….
Concern: The mitigation of deferring pastures from livestock grazing after herbicide application may protect cattle, but is inadequate for protecting wildlife that might ingest plants sprayed, specifically those sprayed with 2, 4-D.
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Response: Per Appendix 9 (Response to Comments) in the final environmental impact statement, “The DEIS/FEIS, Appendix 3 2,4-D risk assessment describe the toxicity, the likely means of exposure, the dose at which harm occurs, and the risk that use at proposed application rates would reach such a level. The risk assessment concludes that the risk of reaching levels of exposure that would cause harm to people, animals or non-target plants are low. The risk assessment has also concluded that links to cancer have not been established. The risk assessment also notes that 2,4-D does not contain dioxin, that Agent Orange contained 2,4,5-T, which had a form of dioxin as a byproduct of 2,4,5-T manufacture. Herbicides using this active herbicide ingredient are no longer sold for use in the U.S.
The final supplemental environmental impact statement (p. 68, the “Environmental Consequences Common to All Species and under Alternative B (Proposed Action)” section) discusses the herbicide risk assessments used to evaluate herbicide toxicity effects (USDA Forest Service 1992, SERA 2002- 2007). The risk assessments concluded potential risks of harm to most wildlife species are low for herbicide formulations proposed for use at the rates and application methods proposed.
Table S-42 (p. 88) of the final supplemental environmental impact statement includes discussion and analysis of the alternatives and effects of herbicide to Spotted and Pale Townsend’s big-eared bats.
Associated Comments For instance, the FEIS p 167 the statement is made: "The application of the herbicide 2,4-D has been shown to increase the nitrate content of plants and the palatability of the plants, increasing the potential for poisoning. Mitigation measures that defer the use of pastures treated with herbicides would avoid this impact." Deferring pastures may protect livestock but does not prevent exposure to animals. Herbicides are nonspecific, so the argument that endangered species (such as American Pika, p 81) will not be affected because they do not consume weeds is not a valid argument. The USFS itself acknowledges that short-term mortality of natives is expected. Because of this, all wildlife, including endangered species, will be exposed to pastures which have been treated with herbicides, and all plants in that area have the potential for increased levels of herbicides (toxicity) as well as nitrates with could result in methemoglobinemia. Therefore we consider the mitigation proposed by the USFS to be inadequate and request further efforts. While some species are listed (p. 78, 80, exc.) under the affects table s-41, There is no discussion regarding risk to these animals, i.e., Spotted bat lives in caves and no treatments would occur in caves- so it was determined there would be no effect on bats from any treatments. If these plants are sprayed with herbicides how would this effect bats and their reproductions etc.?
Concern: The mitigation of having a biologist in the field when herbicides are being applied for protecting Mexican spotted owls needs to be mandatory, not optional.
Response: The final supplemental environmental impact statement, Table S-11, design feature #37 (p. 36) states: “No prescribed burns will be done within Mexican spotted owl protected activity centers. Treatments will be done by hand pulling, grubbing, or herbicide application during part of the breading season (early June to mid-July) to be effective. Treatments will be short duration, low- disturbance activities that would occur once or twice in a season (depending on size of the treatment area). A biologist can accompany applicators to monitor any owl activity that might occur. A year after treatment, monitoring would be done for any reoccurrence of the weed.”
Analysis presented in Table S-35 (p. 81) of the final supplemental environmental impact statement provides the determination of effects for the Mexican spotted owl and rationale for the statement. It states the proposed action “may effect, but not likely to adversely affect with an overall beneficial effect because treatments would improve the habitat of the prey the owl feeds on. Negligible negative effects would be expected given the design features that avoid disturbing owls during the breeding
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season.” It is the agency’s assessment that the proposed action with design features are sufficient to provide protections for the Mexican spotted owl.
The phrase “or other qualified person” as referenced by the commenter occurs in design feature #38, to evaluate when the ground surface within Jemez Mountain salamander habitat is sufficiently dry enough to permit treatments after receiving 5 consecutive days of rain. There are many types of field- going staff who could be qualified to assess suitable soil moisture conditions, which is why it is not limited to a Forest Service biologist.
Associated Comments We wish to draw attention to page 24 DSEIS where the plan allows that a biologist "can accompany applicators into the field to monitor for any potential owl activity that may occur." Why is the attendance of a biologist not mandated in this section? How will this biologist be funded, and is this...We seek clarification as well on the exact definition of an "other qualified person" who is allowed to substitute for the biologist required to monitor other endangered species. Are they at the training level of a biologist?
Concern: The Forest Service cannot assert that the use of pesticides registered with the EPA will not harm listed species because the EPA has not consulted on the effects of individual pesticide registrations under Section 7 of the Endangered Species Act.
Response: The registration process by the Environmental Protection Agency is outside the scope of this analysis. As background, however, the Environmental Protection Agency provides documents that describe the scientific basis for review and risk analysis of each substance they register. The Environmental Protection Agency is required by law to review based on the science. The Environmental Protection Agency is required to evaluate based on the best evidence available.
Environmental Protection Agency registration includes an assessment of risk, given the toxicity of a substance and expected use/exposure. The Environmental Protection Agency regulates the use of registered products so the more likely a dose is to exceed the level of concern (reference dose), the more heavily regulated the use. This provides an overall level of assurance no harm will come to people or animals from use of the products.
Scientific review of the information provided occurs by the Environmental Protection Agency and it is evaluated for particular herbicide formulations in the risk assessments. Where the conclusions of a study have come into question, the risk assessments note these cases, which is generally when a study proposes a conclusion that is not supported by the data not a case where data is falsified. The Environmental Protection Agency does not make the claim that use of herbicides is risk free or "safe."
Associated Comments ESA consultations on herbicide use are flawed given that the FWS has never consulted over the registration and re-registration of pesticides. In this case, the FWS has de-facto unilaterally permitted the use of toxic pesticides without first ensuring, through the ESA consultation process, that those uses will not jeopardize endangered species’ survival or destroy their critical habitat. This procedural and substantive 12 flaw is a fatal one to the use of any herbicide in the habitat of listed species. Moreover, the limited, cursory analysis provided in the Biological Assessment is not an adequate substitute, even if procedurally the agency chose to substitute it for the required and missing consultation on the registration and general use of each individual herbicide....Herbicide use does not comply with the Endangered Species Act because the EPA has never examined the effects of new and pre-existing herbicide registrations on newly listed species. Only the EPA’s use and registration of picloram has undergone formal ESA consultation. However, as is detailed below, the mandatory directions that were the outcome of that consultation are not being followed and the EPA has never re-consulted to address the effects of picloram on newly listed species....Section 7(a)(2) mandates the EPA to ensure that its actions will not jeopardize the continued existence of listed species. In this particular case, the EPA has
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not adequately discharged its Section 7 obligations because it has not consulted on the effects of individual pesticide registrations on the ESA listed Southwestern willow flycatcher, Mexican spotted owl, Mexican spotted owl critical habitat, Rio Grande silvery minnow, Bald eagle, and the Holy Ghost Ipomopsis. The failure to initiate consultation on pesticide registration is relevant because the EPA pesticide approval and registration process is so heavily politicized that the process often does not even provide the FWS with adequate information upon which to formulate a biological opinion.
We believe that because the current Forest Service action and ESA consultation must necessarily be tiered to, and rest upon the foundation of an adequate consultation on the pesticide registration itself, that the current Forest Service consultation is arbitrary and capricious....What is fundamentally different about the factual circumstances surrounding the proposed application of herbicides on the Carson and Santa Fe national forests that are most relevant to the adequacy of the ESA consultation on the proposed action is that the EPA does not even have partial information on the effects of many of these pesticides on listed species. The EPA simply has never engaged in a formal ESA consultation on these species. Thus, conclusions by the FWS and Forest Service that the proposed use of the various toxic pesticides will not be harmful to listed species are not based on the best available science. In this case, the best available science has never been applied because the ESA Section 7 consultation on the pesticide registration never occurred.
Concern: The Forest Service fails to address the effects of herbicide use to non-listed species such as the American goldfinch, barred owl, and hummingbirds.
Response: In accordance with Presidential Executive Order 13186 (January 2011) multiple migratory birds and their habitat types are discussed and analyzed addressing the effects of herbicide application. The final supplemental environmental impact statement addresses effects of herbicides on non-listed bird species (migratory birds) and their habitats on pages 90-94. American goldfinch, barred owl, and hummingbirds are not listed specifically.
Associated Comments Also bird species often dig truffles, burry pinecones, etc. In addition to eating thousands of small insects (ants, spiders, etc.). What about herbicide treatments upon humming birds, songbirds especially blue birds and flycatchers that visit invasive plants to clean insects? If such plants are sprayed with a toxic herbicide, how will this affect these birds? Also of concern are birds of prey such as the Mexican spotted owl, goshawk, bared owl and other species. Many birds' burry pinecones dig truffles and get insects from soil under plants. If invasive are treated with herbicide, how will it affect birds or nomads that dig under these plants? There is no way to keep wildlife away from sprayed areas especially birds and insects as well as small nomads. So even if they may not be directly affected by an herbicide treatment, they are likely to ne indirectly affected by toxic sprays. The indicator species policy seems inadequate to protect the American goldfinch, a beautiful little bird whose survival is dependent on the Bull thistle. If these thistles are invasive, then the American Goldfinch is also invasive and what proof do you have that there were none here before Columbus? What will be the fate of the American Goldfinch if you target Bull Thistles?... Bull thistles are easy to pull, or mow. While Canadian Thistles have crab grass lie root systems and takes years to get out with manual methods. Canadian thistles are more invasive and Bull thistles are usually incidental. Using the same treatment methods on these two species will endanger the American Goldfinch. The issue is not whether herbicides are toxic to the birds and insects, but that certain plant species (which cattle do not like to eat) are vital to the food, nesting and other habitat needs many methods devastate symbiotic life forms.
Concern: Before approving a site-specific project, the Forest Service must gather population data for MIS and analyze MIS population within the project area. This duty to monitor is non-discretionary.
Response: Population monitoring data for management indicator species is gathered at the forest level. In the final supplemental environmental impact statement, Table S-32 (pp. 69-70) displays the two national forests’ management indicator species, the estimated acres of existing habitat, the habitat trend, the population trend, and the acres and percent of weed infestations within those habitats.
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Associated Comment Before approving a site-specific project the Forest Service must gather population data for MIS and analyze MIS population within the project area....Further, the Forest Service cannot rely on habitat availability and habitat trends as a substitute for actual quantitative data....Both the Carson and Santa Fe Forest Plans obligate the Forest Service to monitor the populations1. A viable population is defined as one that has the estimated numbers and distribution of reproductive individuals to ensure its continued existence is well distributed in the planning area. Management indicator species are surrogates for a broad range of other species that have similar needs. 2 This duty to monitor is non- discretionary. “Population trends of management indicator species will be monitored.” 36 C.F.R. 219.19(a)(6) (emphasis added).
Concern: The Forest Service plans on applying herbicides when certain species are hibernating. Hibernation periods, however, are changing due to the effects of climate change. The Forest Service has not accounted for these changes, and thus could apply herbicides at a time when they are harmful to species.
Response: Depending on the level of protection required by law, regulation, and policy, design features and mitigation measures require surveys and/or avoidance and use of seasonal restrictions to reduce impacts to wildlife species. Design features incorporated into the proposed action (final supplemental environmental impact statement Table S-11, p. 33-38) provide for consideration of species whose activity patterns may change, whether as a result of the effects of climate change or other factors, by focusing on when habitat is known or presumed to be occupied by wildlife (design features #33-36, 38, 40, 41) rather than specific dates or time periods.
The adaptive management component of the project further ensures the effects will not extend beyond the scope of the predicted effects at any given location with any given treatment. The Forest Service must monitor the effects of treatments and adjust future treatments to remain within the scope of this environmental impact statement or do additional National Environmental Policy Act analysis (final supplemental environmental impact statement p. 38, design feature #61).
The potential for effects to wildlife species from the proposed action includes consideration of the possibility of exposure to the herbicides proposed for use as discussed under the wildlife risk assessment section of appendix 3 (final environmental impact statement pp. 244-248 and final supplemental environmental impact statement pp. 188-189).
Associated Comments In the DSEIS, the NM meadow jumping mouse “hibernates below ground for nearly 9 months and emerges in July” (DSEIS, p. 82). The FS is counting on this as fact, and will apply herbicides according to this schedule. But this schedule no longer applies due to the effects of climate change. Hibernation periods become shorter and shorter, and there has been no consideration for this or other climate change factors in this DSEIS. This is a significant flaw that must be addressed. “Termination of hibernation is highly sensitive to temperature change. In fact, current global upward trends in ambient temperature are having a measurable effect in shortening the hibernation seasons of a number of species…” (http://labspace.open.ac.uk/file.php/5850/!via/oucontent/course/338/s324_4_bk2_ch4.pdf) (http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3894896/)
Concern: The Forest Service should integrate the information related to specific pesticides with the discussions of the potential impacts to plant and wildlife species, focusing on how specific species’ viability and populations may be affected due to the unique characteristics of the various herbicides. Without concurrence on its BA from the US Fish and Wildlife Service, the Forest Service cannot provide updated or accurate information as to the likely impact on threatened and endangered species from this project.
Response: The wildlife risk assessment section of appendix 3 in the final environmental impact statement (pp. 244-248) describes the effects of herbicides to terrestrial organisms. The final
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environmental impact statement also describes the effects of herbicides to aquatic organisms in the aquatic risk assessment section (pp. 249-250). The final environmental impact statement (pp. 251- 285) and final supplemental environmental impact statement (pp. 191-192) discuss specific herbicides characteristics and environmental effects. The environmental effects include specific herbicide effects to terrestrial and aquatic organisms. Biological assessment concurrence on threatened and endangered species effect determinations was obtained from the U. S. Fish and Wildlife Service on January 9, 2015.
Associated Comments
Within the DSEIS the Forest Service repeatedly emphasizes that the action alternatives are not likely to adversely affect threatened or endangered plant or animal species. See DSEIS at 56 (“Not likely to adversely affect the Holy Ghost ipomopsis”), 72 (“may affect but is not likely to adversely affect, and may be beneficial to the Mexican spotted owl” and “may affect but not likely to adversely affect the Southwestern willow flycatcher”); see Table S-35. However, the Forest Service has not yet completed formal consultation with the FWS for this project. The most recent Biological Assessment (“BA”) completed by the Forest Service has not been reviewed by the FWS, so the information provided in the DSEIS concerning impacts to threatened and endangered species does not represent the most current findings of the FWS. Until such time as the FWS concurs with the Forest Service’s biological assessment or issues a biological opinion, the Forest Service cannot provide updated or accurate information as to the likely impact on threatened and endangered species from this project. The Forest Service needs to supplement this DSEIS once formal consultation with FWS has been completed in order to meet the requirements of the ESA and NEPA. The BAs from 2005 (present in the project record) and the current Forest Service assessment of wildlife impacts, (presented in the DSEIS) fail to include specific information as to the potential impacts of the specific herbicides proposed for use on the specific types of plants and animals present within the project area. While the DSEIS provides “Specific Herbicide Characteristics and Environmental Effects” analysis for all the propose herbicides within Appendix 3 of the DSEIS, these assessments are general in nature and do not address the potential impacts to viability and populations of the wildlife or plant species on the Carson and Santa Fe National Forests that are discussed within other sections of the DSEIS. The Forest Service should integrate the information related to specific pesticides with the discussions of the potential impacts to plant and wildlife species, focusing on how specific species’ viability and populations may be affected due to the unique characteristics of the various herbicides. As currently written, both the DSEIS and the BAs lack adequate information to fully understand the relevant impact of the specific herbicides proposed for use in this project. Merely stating that mitigation measures should prevent negative impacts is insufficient to meet NEPA requirements that all direct and indirect impacts are disclosed and discussed. Water Resources Concern: The Forest Service will purposely or inadvertently cause herbicides to enter waterways, which will contaminate drinking water used by people.
Response: Water quality protection measures are included in the analysis by alternative and treatment criteria, limitations, design criteria and monitoring measures for all alternatives under which herbicide use is proposed. For use of herbicides near water under the proposed action, these are described in the final supplemental environmental impact statement in Table S-10 (pp. 31-32) and Table S-11 (pp. 33- 39). As proposed, no aerial broadcast spray of herbicides is going to occur as part of this project.
The model used in this analysis simulates the potential concentrations of herbicide in a stream draining a watershed subject to weed treatment. The model calculates dilution of herbicide in primary streams of representative watersheds for two time periods – May and September, representing typical time periods when discharge is near the peak (May) and near the minimum (September). Picloram was selected because of its “high risk quotient” for fisheries and aquatic life, and a worst-case
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scenario was developed that represented the treatment of all weed acres at one time under alternative B.
Modeling assumptions were clearly articulated and disclosed (final environmental impact statement pg. 292). Modeling results are illustrated in Table 66 (final environmental impact statement pp. 293- 294), and two watershed were found to potentially exceed the recommended threshold indicating that some effect to soil and water resources would be expected (loss of fish or aquatic insects). The interdisciplinary team considered these potential risks and developed design features to limit or avoid treatment scenarios in which the impacts would be likely to occur (final supplemental environmental impact statement pp. 33-38). Mitigation measures include limitations on herbicide treatment near streams and water bodies, use of only hand application onto individual weed plants in riparian areas, choice of herbicide method of application documented to be of low risk to aquatic species, prohibiting mixing and loading of herbicides near live water, etc.
While the commenter(s) may feel the model is inadequate, it meets the requirements of the National Environmental Policy Act to disclose the effects of a proposed action to the public and develop mitigation to address those impacts.
The potential for effects to human health and safety was identified as an issue to analyze in detail (final supplemental environmental impact statement pp. 33-34 and final supplemental environmental impact statement pp. 149-150). Analysis is provided in chapter 3 of the final supplemental environmental impact statement (pp. 149-161).
Associated Comments The Forest Service now explicitly plans to discharge pesticides into waterways. It intends to obtain three types of permits to do this: (a) a permit under the Clean Water Act for a discharge of pesticides into "Surface Waters of the United States"; (b) a "Pesticide General Permit" under the Clean Water Act; and (c) a permit from the New Mexico Environment Department allowing "short-term degradation to the chemical, physical or biological integrity" of surface waters. If chemical herbicides are applied near the watershed, it cannot be guaranteed that these herbicides will not end up in our water supply. We need to protect our water supply for now and for future generations.
Concerns: Herbicides need to be applied farther from waterways than is currently proposed in order to prevent the chemicals from entering water.
Response: Water quality protection measures are included in the analysis by alternative and treatment criteria, limitations, design criteria and monitoring measures for all alternatives under which herbicide use is proposed. For use of herbicides near water under the proposed action, these are described in the final supplemental environmental impact statement in Table S-10 (pp. 31-32) and Table S-11 (pp. 33- 39). As proposed, no aerial broadcast spray of herbicides is going to occur as part of this project.
The model used in this analysis simulates the potential concentrations of herbicide in a stream draining a watershed subject to weed treatment. The model calculates dilution of herbicide in primary streams of representative watersheds for two time periods – May and September, representing typical time periods when discharge is near the peak (May) and near the minimum (September). Picloram was selected because of its “high risk quotient” for fisheries and aquatic life, and a worst-case scenario was developed that represented the treatment of all weed acres at one time under alternative B.
Modeling assumptions were clearly articulated and disclosed (final environmental impact statement pg. 292). Modeling results are illustrated in Table 66 (final environmental impact statement pp. 293- 294), and two watershed were found to potentially exceed the recommended threshold indicating that some effect to soil and water resources would be expected (loss of fish or aquatic insects). The
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interdisciplinary team considered these potential risks and developed design features to limit or avoid treatment scenarios in which the impacts would be likely to occur (final supplemental environmental impact statement pp. 33-38). Mitigation measures include limitations on herbicide treatment near streams and water bodies, use of only hand application onto individual weed plants in riparian areas, choice of herbicide method of application documented to be of low risk to aquatic species, prohibiting mixing and loading of herbicides near live water, etc.
While the commenter(s) may feel the model is inadequate, it meets the requirements of the National Environmental Policy Act to disclose the effects of a proposed action to the public and develop mitigation to address those impacts.
The potential for effects to human health and safety was identified as an issue to analyze in detail (final supplemental environmental impact statement pp. 33-34 and final supplemental environmental impact statement pp. 149-150). Analysis is provided in chapter 3 of the final supplemental environmental impact statement (pp. 149-161).
Associated Comments
We recommend larger facilities near riparian areas. Wind, soil movements, rain, snowfall all wash herbicides a good distance from where they are sprayed. Any treatments need to be much farther from all riparian areas and springs / wet meadows.
Concern: The Forest Service fails to adequately address the New Mexico Environment Department's concerns about using picloram in municipal watersheds.
Response: In response to the concern of the New Mexico Environment Department to the use of picloram in municipal watersheds (watersheds that supply drinking water to municipalities), additional treatment criteria, limitations of treatment methods, and design features were developed. These are described in the final supplemental environmental impact statement in Table S-10 (pp. 31- 32), Table S-11 (pp. 33-38), and Table S-12 (pp. 38-39).
Table S-10 of the final supplemental environmental impact statement (pp. 31-32) outlines criteria for several weed site conditions applicable to this comment:
• Area where there is a shallow water table (no more than 6 feet deep) and soil with a high permeability rate, where there may be a risk of an herbicide leaching through the soil to the groundwater (final supplemental environmental impact statement p. 31), and • Santa Fe and Gallinas municipal watersheds in the Santa Fe National Forest (final supplemental environmental impact statement p. 32). Table S-10 also indicates herbicide formulations and application methods with the lowest risk of harmful effects to humans would be used and methods of treatment used must be approved by appropriate officials of the cities of Santa Fe and Las Vegas, NM. This also includes non-herbicide methods of treatments in these areas. Table S-11 design feature #46 (p. 36) restricts the use of herbicides containing picloram as their active ingredient within “25 feet of a waterbody…or within the municipal watersheds of the Gallinas and Santa Fe Rivers.” Design feature #58 (p. 37) states “Weed treatments within the Santa Fe and Gallinas municipal watersheds will be agreed to and coordinated with the appropriate officials for the cities of Santa Fe and Las Vegas, respectively. Proposed use of herbicides within these municipal watersheds would occur only upon agreement from officials of these cities.”
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Table S-12 (p. 38) displays the proposed amendment to the Santa Fe National Forest Plan, which would read, in part “Chemical treatments may be applied:…(b) within municipal watersheds only when the municipality concurs with the proposed treatment and design features.”
The specific design features for the Gallinas and Santa Fe municipal watersheds discussed above in addition to those developed for human health and safety (Table S-11, pp. 33-34) address these concerns.
Associated Comments The New Mexico Environment Department's concern about the use of picloram in watersheds is explicitly rejected. The DSEIS, announcing its intention to ignore the Department, states without further analysis that "[t]he agency believes that retaining flexibility in weed treatments is crucial to the success of this project." The concerns of the NM Environment Department about applying picloram in the municipal watersheds are summarily dismissed in the DSEIS, even though picloram is well known to leach in soil and contaminate water. It strains credulity to understand how anyone could propose putting any herbicides in a watershed (which serves as a drinking water source), but picloram is one of the poorest choices. Health and Safety Concern: The Forest Service has not quantified the risk of herbicide use proposed in this project to people with multiple chemical sensitivities.
Response: For people who have been diagnosed or identified themselves as being sensitive to multiple chemicals, there is no measurable level they find acceptable. Therefore, the design features for human health and safety located in Table S-11 (pp. 33-34) of the final supplemental environmental impact statement provide a notification procedure to let anyone who wishes to avoid all exposure the opportunity to do so.
The review of literature regarding health effects is documented in the risk assessment for each herbicide proposed for use. Appendix 3 of the final environmental impact statement (pp. 223-285) and final supplemental environmental impact statement (pp. 185-192) provides a summary of the risk assessments. The risk assessments include population segments regarded as most vulnerable, such as children. In the risk assessments, the effects to children are evaluated using extreme exposure scenarios (for example, directly spraying them or children drinking water immediately after a spill). These scenarios are not likely to occur in the course of this project.
Associated Comments The Forest Service has not quantified the risk to people with multiple chemical sensitivities. No one with expertise about MCS was consulted in preparing the FEIS, the ROD, or the DSEIS. The so-called "design features" are ineffective in preventing exposure to herbicides to people at risk of injury or death from such exposure. The Forest Service's documents are fatally biased, because the list of sources of information about herbicides identified by the Forest Service reads like a Who's Who of the petrochemical industry. As in the FEIS, the DSEIS makes no mention of range of human vulnerability to herbicides, and no mention of chemically sensitive individuals, many of whom frequent the forests to escape urban and agricultural pollution. The DSEIS makes broad sweeping statements about how the herbicides to be used by the Forests will not hurt anyone. This is just wishful thinking. This project as proposed presents a threat to my life. This threat to me extends into my own home. Moreover, approval of this plan would result in denial of access by me to the Carson and Santa Fe National Forests. Please do not use chemical herbicides in Carson and Santa Fe National Forests. I am disabled with Environmental Illness/Multiple Chemical Sensitivity. Myself and others with this illness are profoundly physically affected by chemical herbicides such as the one being proposed to use in Carson and Santa Fe National Forests. A quick note to state that I'm very concerned about the spraying of herbicides in the National Forest. My wife is extremely chemically sensitive and one of
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her few joys in life is to be able to hike in the Santa Fe National Forest. Please do not approve of any spraying in these forests under review. Both the proposed action and alternative 2, using only herbicides, would be literally life-threatening to me and to others living in these regions. We are ones who have already been so seriously chemically poisoned that usage of herbicides in our areas could seriously injure or even kill us. We are the so-called "chemically sensitive" people. We should be called "previously chemically poisoned" people! I tested in the highest percentiles for pesticide residues, especially DDT, DDE, and so-called inert chemicals mixed with these applications which are not listed in the product literature. Dr. Root informed me that these "inert chemicals" were as dangerous or more so than the pesticides. I learned that such chemical residues remain in our bodies. Our bodies have no natural way to discharge them.
Concern: The proposed action will expose the public to unacceptable levels of herbicides.
Response: The Forest Service has developed and will require the implementation of 14 measures to ensure neither the public, nor its workers, are exposed to unacceptable levels of herbicides (final supplemental environmental impact statement, pp. 33-34, Table S-11, #1 - 14). These measures include not using herbicides in high-use developed recreation areas on the weekends when the public is most likely to be present, posting signs about the use of herbicides, using the appropriate herbicide under the conditions listed on the label, and requiring training and personal protective equipment by applicators.
The commenters present no scientific evidence herbicides will remain in the environment at toxic levels. The risk assessments, on the contrary, take into account the exposure that would occur if someone walked through an area immediately after it was sprayed (which would mean they ignored the signs) when vegetation would still be wet. The risk assessments show that, after the herbicide is dry, exposure is greatly reduced.
The Forest Service acknowledges the use of herbicides presents risks. Based on the risk assessments summarized in appendix 3 of the final environmental impact statement (pp. 223-285) and final supplemental impact statement (pp. 185-192), the Forest Service believes the risk of harmful exposure to the public and workers is exceedingly low. The Environmental Protection Agency's system of assessing risk denotes a reference dose, and then after evaluating plausible exposure scenarios, compares likely exposure with the reference dose. The Environmental Protection Agency then assigns a hazard quotient, which is the dose received under the exposure scenario divided by the reference dose. The smaller the hazard quotient, the less hazard. Any hazard quotient greater than one is an exposure that exceeds the level of concern.
Associated Comments The Forest Plan Amendment has a new provision allowing herbicides to be applied "in areas of human habitation." The use of herbicides "in highly used developed recreation areas" is now specifically planned (during weekdays only!). The claim in the DSEIS that “since the public will not be applying herbicides, their risk of exposure by any application method proposed in this project is zero” is unsubstantiated and wrong. After an herbicide is applied to the environment it does not “go away” even after it is dry or after it is “absorbed by the plant”. Residues remain on the plant, the soil, and target and non-target vegetation. Pets and humans can absorb herbicides through the skin after touching contaminated areas, despite claims in the DSEIS that states, “The likelihood of a member of the public absorbing an herbicide through their skin is virtually zero.” To the contrary, 2,4-D especially is known for its high rate of absorption through the skin....And the expanded plan to use herbicides in “areas of human habitation” and “in highly used developed recreation areas” increases the risk of human exposure to herbicides significantly. Although areas may be restricted or warnings signs placed before herbicide applications, no specific information is given in DSEIS indicating how long these would be in place. In another Santa Fe Forest project, signs would only be left in place a few days, which is not nearly long enough to protect those that are more vulnerable to low levels of herbicides. Another statement in the DSEIS is false at worst and misleading at best. “Studies show that the risk of dermal exposure is higher than the risk of inhalation. Since the risk of dermal exposure
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is below the LD50, the risk of inhalation would be as well.” But inhaling levels “below the LD50” is hardly a safeguard. This just means that half of the test animals that received a particular dose did not die! It does not address other adverse affects that can occur from inhaling lower doses. Whether low doses of EDCs influence certain human disorders is no longer conjecture, because epidemiological studies show that environmental exposures to EDCs are associated with human diseases and disabilities. We conclude that when nonmonotonic dose-response curves occur, the effects of low doses cannot be predicted by the effects observed at high doses. Thus, fundamental changes in chemical testing and safety determination are needed to protect human health. The FEIS admits that some of the impurities could cause cancer at a rate of one in a million, as if that was acceptable. There are, in fact, no safe levels for chemicals that are carcinogenic, mutagenic, or cause reproductive or developmental harm. Some of the proposed herbicides contain such chemicals.
Concern: The Forest Service needs to evaluate the safety of AMPA, a glyphosate byproduct, before using herbicides with this ingredient.
Response: The citation provided by the commenter is not peer-reviewed, scientific literature. It presents no discussion of toxicity, and, as such, does not support the commenter's concern about herbicides disrupting the endocrine system or causing cell death. The only mention of concentrations is the following: "The highest measured concentration of glyphosate was 8.7 micrograms per liter, well below the MCL (700 micrograms per liter). The highest AMPA concentration was 3.6 micrograms per liter (there is no MCL for AMPA)." No conclusions are drawn in the article. The commenter falsely attributes claims to this paper. For example, the paper makes no claim about the length of time AMPA stays in water (forever, according to commenter) or the cost of treatment by municipalities (prohibitive, according to commenters).
The glyphosate risk assessment describes the toxicity, the likely means of exposure, the dose at which harm occurs, and the risk that use at application rates proposed would reach such a level. Glyphosate and its formulations have very low toxicity. No definitive link to cancer was established in dose- response tests.
Associated Comments There are no established standards on glyphosate byproducts when they break down in water, specifically the byproduct aminomethylphosphonic acid (AMPA). AMPA never leaves the water supply except via carbon filtration which is beyond the...ability of many municipalities (see USGS (Dec 2013). "Glyphosate Herbicide Found in Many Midwestern Streams. "USGS Environmental Health - Toxic Substances. http://toxics.usgs.gov/highlights/glyphosate02.html
Concern: The Forest Service should not conduct any prescribed burning because smoke releases fine particulate matter that is harmful to human health.
Response: Use of prescribed fire exclusively to treat weeds is expected to be minimal, about 900 acres (6.8 percent) of the treatment area. For comparison, the Santa Fe National Forest conducted prescribed burning on about 13,000 acres in 2014, which is approximately the footprint of known existing weeds on the Santa Fe and the Carson combined.
All prescribed burning must comply with the New Mexico smoke management requirements (permitting, monitoring, and so forth) to maintain levels of these emissions within State and Federal air quality standards (final supplemental environmental impact statement, p. 36, design feature #43). Use of prescribed fire must adhere to restrictions in the forest plan and Forest Service directives, such as those for using fire within wilderness (Forest Service Manuals 2324.2 and 2324.04(b)), requirements for detailed burn prescriptions, and other requirements intended to avoid unexpected consequences (final supplemental environmental impact statement, p. 34, design feature #24).
234 Final Supplemental Environmental Impact Statement
The potential effects of prescribed burning on air quality is provided in the final supplemental environmental impact statement (pp. 120-128). Under the proposed action, “a large amount of emissions is not expected and would fall well below standards (p. 127).
Associated Comments ban all burning, which releases fine particulte matter which enters human bodies and causes lung cancer, heart attacks, strokes, allergies pneumonia and asthma, among other illnesses and deaths. that fine particulate matter travels hundreds of thousands of miles killing people all along the weather path.
Concern: Some people stated that the use of herbicides would cause harmful effects to people and cited examples that have no relevance to this project.
Response: That glyphosate may be found in sugar, corn, soy, and wheat is not relevant because the Forest Service is not proposing to use herbicides on food crops.
The articles about Sri Lanka are not peer-reviewed, scientific literature, or the conditions described would not occur as a result of this project. The articles discuss Sri Lanka's ban of glyphosate in light of the death of rice paddy farmers, who use it on their crops while drinking hard water over extended periods of time, at least a decade.
The fact sheet states in several places that dicamba is not harmful to humans. Please refer to the analysis of commenters' citations found in the project record.
Associated Comments Glyphosate, the active ingredient in Roundup®, is the most popular herbicide used worldwide. The industry asserts it is minimally toxic to humans, but here we argue otherwise. Residues are found in the main foods of the Western diet, comprised primarily of sugar, corn, soy and wheat. The Sri Lankan Agriculture Ministry banned the import of Roundup and the pesticides Carbaryl, Chlorophyriphos, Carbofuran and Propanil last year due to fears that the chronic kidney disease amongst farmers could be linked to them. However, this latest President’s order now bans all local sales from the stocks that are still available of Roundup, in reaction to the study. A new study published in the International Journal of Environmental Research and Public Health found a link between the weedicide known as Roundup and the fatal Chronic Kidney Disease of Unknown origin (CKDu) affecting mostly, the rice farmers in Sri Lanka and several other countries. Drift is not the only way the public could be exposed to airborne herbicides. Herbicides can also volatilize after application. The FEIS admits that dicamba can volatize, but says the amount is negligible and therefore of no concern. But dicamba is well known for being able to volatilize – that is, re-enter the air after it has dried – in such large amounts that it can cause serious damage to neighbor’s crops. Therefore, the public could inhale significant amounts of dicamba long after its application in the Forests. According to National Pesticide Information Center Technical Fact Sheet on Dicamba (http://npic.orst.edu/factsheets/dicamba_tech.pdf), “Dicamba has volatilized under field conditions and injured non-target crops. In growth chamber experiments, the acid form was most volatile, and the inorganic salts were least volatile. In field experiments with the less volatile forms of dicamba, potted soybeans showed symptoms of injury when exposed to the vapors of treated corn up to 60 meters away. 38”
Concern: In New Mexico's windy climate, herbicides will become airborne during application and present hazards to people even if they aren't in the forest.
Response: During herbicide applications, spray drift is expected to be contained near the application site, due to limitations restricting application under wind conditions that could result in drift. In addition, drift will be limited because the slow vehicle speed and low height of the spray boom would resulting in the herbicide falling to the ground within a few feet of the target weed population (final supplemental environmental impact statement, p. 127).
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The project contains mitigations specifically designed to prevent herbicides from becoming airborne (final supplemental environmental impact statement, p. 33-34, Table S-11, design features #3 and 9) and to keep people away from treated areas (#10-12, 14).
Associated Comment Implementation of the Project as proposed will present a hazardous threat to my life even while inside my own home. The unpredictable nature of our winds here along with the general high wind speeds in northern New Mexico render any decision which allows the release of herbicides or any other neurotoxins into the atmosphere completely irresponsible. If a single ember, per the Forest Service, can travel 4 miles here, how much further can atomized herbicides travel? Herbicides become airborne in New Mexico wind, and so these chemical applications to the forests cannot be properly contained.
Concern: The Forest Service fails to discuss the cumulative and synergistic effects of herbicide use, including the inert ingredients in formulations.
Response: The risk assessments describe the formulations that are registered for use. The Environmental Protection Agency has acknowledged not all of these ingredients are inert and has suggested (but not required) the terminology be changed on labels to describe them as "other" ingredients instead. The Environmental Protection Agency classifies these other ingredients into four levels, from those with known toxicity to those without any known adverse effects. Those with known toxicity that require a material safety data sheet are required to be disclosed. Others are not disclosed because they may be confidential business information. This information is disclosed to the Environmental Protection Agency and to the authors of the risk assessments, but not to the general public. Therefore, the determination of effects has included the products to be used (including inert ingredients), not simply the herbicide.
The risk assessments also account for the most likely mixtures permitted by the label (including allowable surfactants and other additives). Only formulations that are considered in risk assessments would be used (final environmental impact statement pp. 38, final supplemental environmental impact statement p. 33, design feature #1). As discussed in the final environmental impact statement and risk assessments, every possible combination is not analyzed or accounted for and so some risk exists that someone would combine products that should not be mixed. Although this is considered a possibility, it is less probable this would happen (given supervision by certified herbicide applicators), than the hazardous mixing of unregistered household products, which have high proven potential for harm. Details about the factors affecting the hazards of herbicides is provided in appendix 3 of the final environmental impact statement (pp. 231-244).
For different products that would be applied on the same area in separate applications, the risk assessments only discuss cumulative effects, the assumption being an application of one after another does not add any measure of risk. This conclusion is based on the low level of active ingredient being left onsite by the time the second application is applied. The final supplemental environmental impact statement contains a mitigation measure to assure that any follow-up application of a second herbicide to an area is conducted after reviewing best available information on compatibility with the previous application (Table S-11, p. 33, design feature #4).
Associated Comments The study found that the kidney disease did not occur without the co-presence of heavy metals, including arsenic, but of note is that New Mexico soil contains high levels of arsenic. This possible cumulative effect of simultaneous exposure to Roundup and arsenic was not analyzed in the DSEIS. The DSEIS also dismisses the possibility of cumulative or synergistic effects of herbicide use, claiming that since herbicides will have no adverse effects, then there cannot be any cumulative or synergistic effects. But since the assumption there cannot be any adverse human effects is incorrect, this dismissal of cumulative or synergistic effects is inaccurate and unacceptable. The DSEIS admits
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there is uncertainty as to what “inert” ingredients are in herbicide products and yet still claims that the impacts of using herbicides are known, and furthermore, are negligible. How is this possible? No one can assess the impact of unknown chemicals, which means the impacts of herbicides are extremely uncertain. In addition, no specific herbicide products (with EPA registration numbers) are listed in the DSEIS, nor does it analyze any specific products. Thus, the environmental and health impacts cannot be determined. This lack of data is a serious omission from a document whose prime objective is to do just that.
Concern: …you cite your outdated information as the basis for your conclusion that herbicides containing glysophate are safe if used according to label directions.
Response: The final supplemental environmental impact statement has been updated to include the most recent risk assessment available for glyphosate (p. 185).
The Forest Service has undertaken careful measures to avoid, wherever practicable, harm to people, wildlife, and other natural resources when using herbicides. The 58 design features listed on pages 33 through 38 of the final supplemental environmental impact statement ensure that the risk of herbicide use is at a minimum. For instance, areas would be closed during application. Further, Environmental Protection Agency registration includes an assessment of risk given the toxicity of a substance and expected use and exposure. The Environmental Protection Agency regulates the use of registered products so the more likely a dose is to exceed the level of concern, the more heavily regulated the use. This provides an overall level of assurance no harm will come to people or animals from the use of the products.
When viewed against the extremely low risk of exposure, the environmental damage posed by not controlling or eradicating weeds is much greater. As described in the final environmental impact statement and final supplemental environmental impact statement, weed invasion and spread results in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability, and water quality. The harmful effects of weeds to ecosystems are described in detail in the final environmental impact statement (pp. 13 - 16) and the final supplemental environmental impact statement (pp. 13 - 14). The potential impacts of weeds known to exist on the Santa Fe and Carson National Forests are provided in appendix 2 (final environmental impact statement pp. 213-221 and final supplemental environmental impact statement pp. 181-183).
Concern: Rewrite the “Affected Environment for Human Health and Safety” section Chapter 3 beginning on page 156. This would include rewriting Table 64 to remove the lies.
Response: Information provided in Table S-64 (final supplemental environmental impact statement pp. 156-157) is based on the most recent risk assessments available (final supplemental impact statement p. 186).
The Forest Service has undertaken careful measures to avoid, wherever practicable, harm to people, wildlife, and other natural resources when using herbicides. The 58 design features listed on pages 33 through 38 of the final supplemental environmental impact statement ensure that the risk of herbicide use is at a minimum. For instance, areas would be closed during application. Further, Environmental Protection Agency registration includes an assessment of risk given the toxicity of a substance and expected use and exposure. The Environmental Protection Agency regulates the use of registered products so the more likely a dose is to exceed the level of concern, the more heavily regulated the use. This provides an overall level of assurance no harm will come to people or animals from the use of the products.
When viewed against the extremely low risk of exposure, the environmental damage posed by not controlling or eradicating weeds is much greater. As described in the final environmental impact
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statement and final supplemental environmental impact statement, weed invasion and spread results in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability, and water quality. The harmful effects of weeds to ecosystems are described in detail in the final environmental impact statement (pp. 13 - 16) and the final supplemental environmental impact statement (pp. 13 - 14). The potential impacts of weeds known to exist on the Santa Fe and Carson National Forests are provided in appendix 2 (final environmental impact statement pp. 213-221 and final supplemental environmental impact statement pp. 181-183).
Concern: While natural vegetation will be harmed if non-native invasive plants are not eradicated, alternatives to herbicides should be implemented because of the potential harm to the public and the environment from their use. Response: The precautionary principle has another aspect, which is a lack of scientific evidence does not preclude action if damage would otherwise be serious and irreversible. If there are threats of serious or irreversible environmental damage from not acting, a lack of full scientific certainty should not be used as rationale for postponing measures to prevent environmental degradation. The wildlife risk assessment section of appendix 3 in the final environmental impact statement (pp. 244-248) describes the effects of herbicides to terrestrial organisms. The final environmental impact statement also describes the effects of herbicides to aquatic organisms in the aquatic risk assessment section (pp. 249-250). The final environmental impact statement (pp. 251-285) and final supplemental environmental impact statement (pp. 191-192) discuss specific herbicides characteristics and environmental effects. The environmental effects include specific herbicide effects to terrestrial and aquatic organisms. Biological assessment concurrence on threatened and endangered species effect determinations was obtained from the U. S. Fish and Wildlife Service on January 9, 2015. The Forest Service has undertaken careful measures to avoid, wherever practicable, harm to people, wildlife, and other natural resources when using herbicides. The 58 design features listed on pages 33 through 38 of the final supplemental environmental impact statement ensure that the risk of herbicide use is at a minimum. For instance, areas would be closed during application. Further, Environmental Protection Agency registration includes an assessment of risk given the toxicity of a substance and expected use and exposure. The Environmental Protection Agency regulates the use of registered products so the more likely a dose is to exceed the level of concern, the more heavily regulated the use. This provides an overall level of assurance no harm will come to people or animals from the use of the products. When viewed against the extremely low risk of exposure, the environmental damage posed by not controlling or eradicating weeds is much greater. As described in the final environmental impact statement and final supplemental environmental impact statement, weed invasion and spread results in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability, and water quality. The harmful effects of weeds to ecosystems are described in detail in the final environmental impact statement (pp. 13 - 16) and the final supplemental environmental impact statement (pp. 13 - 14). Associated Comments … as a retired USFS employee I understand that natural vegetation and the resources that depend on the health of the natural vegetation will be significantly harmed if the non-native invasive plants are not eradicated. I also know there are effective (although more costly) alternatives to killing these plants other than herbicides. If most Americans knew of the tragic results stemming from contact with some herbicides they would insist that the USFS spend the extra money on these safer alternatives. Competent public servants apply the Precautionary Principle to any risky proposed actions see below: The precautionary principle or precautionary approach states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking an action.
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Index adaptive strategy, 5, 31, 38 hairy woodpecker, 73 air quality, i, 40, 51, 123, 130, 159, 179 herbicides, 28 effects to, 129 aminopyralid, 195 emissions, 123 characteristics with soil, iii, 121 national ambient air quality standards dermal (skin) absorption, 159, 162 (NAAQS), 123, 124 effects, 102, 104 alternatives endocrine disruption, 159, 164 alternative A (no action), 5, 27, 56, 67, 112, ingestion, 159 113, 129, 139, 141, 143, 144, 151, 152, 156, inhalation, 159, 162, 167 160, 169 leaching into soil, 102 alternative B (proposed action), 5 length of exposure, 158, 162 alternative C (no herbicides), 5 potential for exposure, 191 alternative D (herbicides only), 5 risk assessments, ii, 189, 195 comparison of, i, 8, 9, 40, 164 risk of overland flow, 103 appeal of 2005 record of decision, 3, 25 synergistic interactions, 163 aquatic macroinvertebrates, 74 toxicity, 159, 162 assumptions of analysis, i, 51, 154, 157, 169, 208 worse-case effects to fish and aquatic resources, Clean Air Act, 123 102 Clean Water Act, 40, 109, 179, 221, 230 heritage resources, i, 7, 37, 130, 132 culturally important forest products, 56, 155, 219 effects to, 132 cumulative effects, i, 43 Hispanic populations, 154 fish and aquatic resources, 103 Holy Ghost ipomopsis, 63 human health and safety, iii, 166 human health and safety, 6, 8, 33, 39, 49, 50, 140, low-income and minority populations, 156 155, 156, 159, 170, 237 past and present actions, 43 incomplete or unavailable information, 171 reasonably foreseeable actions, 44 invasive plants recreation and wilderness, 141 definition, i, 13 sensitive wildlife species, 91 issues, i, 2, 10, 25, 26, 41, 153, 158 soil, 122 juniper (plain) titmouse, 72 summary, ii, 49 livestock grazing, i, 146, 151, 153, 173 threatened and endangered wildlife, 83 effects of weeds, 146, 151, 152 water resources, 113 low income and minority populations, iii, 153, design features, 33 154, 155 economics management indicator species, 66 cost-benefit analysis, 169 effects to, iii, 75 present net value, iii, 169, 170 Mexican spotted owl, 74, 78, 81 environmental justice, 170 monitoring, ii, 6, 7, 33, 38, 52, 103, 133, 134, 139, Environmental Protection Agency, 7, 8, 10, 31, 33, 203 36, 40, 41, 49, 103, 114, 123, 157, 158, 160, mourning dove, 73 161, 162, 164, 166, 167, 171, 172, 174, 183, Native Americans, 132, 154, 155, 173 189, 190, 191, 192, 195, 196, 208, 218, 226, native plants, 6, 34, 37, 49, 61 233, 236, 237, 238 New Mexico Department of Agriculture, 4, 15, 22, fish and aquatic resources, i, 97, 99, 104 27, 30, 34, 40, 171, 211 effects to, iii, 100 New Mexico Environment Department Surface sensitive species, 98 Water Quality Bureau, 37, 40 forest plan amendment, i, 7, 23, 38, 66, 96, 104, New Mexico Pesticide Control Act, 40 114, 122, 130, 132, 142, 146, 153, 170, 210, New Mexico State Historic Preservation Officer, 212, 233 39
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Nokomis fritillary butterfly, 98 visual quality, i, 143, 145, 146 Outstanding National Resource Waters, 113 effects to, 143 pea-clams, 98 visual quality objectives, 143, 144, 145 permits and authorizations, i, 39 water resources, i, ii, 97, 104, 112, 151, 229 piñon jay, 72 effects to surface and groundwater quality, 112 plants surface and groundwater quality, 109, 114 endangered, 63 weed effects sensitive plants, 7, 35, 37, 63, 65, 66 erosion, 1 special status, 63, 65, 66 native plants, 1 proposed action, i, ii, 4, 5, 22, 27, 56, 67, 120, 129, recreation, 2, 14 139, 170, 210, 225 water quality, 14 public involvement, i, ii, 2, 24, 209 wilderness, 14 purpose and need, i, 1, 13 wildlife habitat, 2, 14 recreation, 132, 139, 140, 141 weed locations, iv, 19 effects to, 138 by vegetation types, 52, 53 red squirrel, 74 grasslands, 53 resident trout, 74 grazing allotments, iii, 147, 148 Rio Grande cutthroat trout, 74, 99 piñon-juniper, 54, 71 Rio Grande sucker, 99 ponderosa pine, 54 Rocky Mountain bighorn sheep, 73 recreation sites, iv, 136 Rocky Mountain elk, 73 riparian areas and valley bottoms, iv, 54, 105 social and economic resources, i, 153 sagebrush-shrub, 53 local economy, 155 spruce-fir, 53, 54, 93 soil, 115 wilderness areas, iv, 137 effects to, 119 weed species erosion, iii, 116 characteristics and impacts, ii, 16 southwestern willow flycatcher, 80, 81 cheatgrass, 16, 185 threatened and endangered wildlife species, iii, 79, knapweed, 14, 16, 20, 52, 53, 54, 56, 60, 62, 67, 81 69, 115, 116, 138, 139, 159, 161, 178, 185, threatened, endangered and sensitive species, 35 198, 211 traditional cultural properties, 131 leafy spurge, 2, 14, 20, 21, 53, 54, 161, 198 treatment Russian olive, 2, 20, 46, 48, 53, 54, 115, 133, annual amounts, 22, 52 135, 198 treatment methods saltcedar (tamarisk), 2, 14, 20, 21, 44, 46, 48, alternative B, 29 53, 54, 60, 61, 80, 96, 115, 133, 135, 139, alternative C, ii, 30 150, 185, 198, 213, 221 alternative D, ii, 31 Siberian elm, 2, 20, 28, 46, 48, 53, 54, 115, 133, biological methods, 4, 160 198 controlled grazing, 4 St. John’s Wort, 4, 22 herbicides, 4 tree of heaven, 16, 186 limitations, 31 yellow starthistle, 2, 53, 61, 175, 190, 195 manual methods, 4, 161 weed spread, 51, 62 mechanical, 28, 161 effects from livestock grazing, 147, 151, 152 prescribed burning, 4 white-tailed ptarmigan, 73 summary of treatments proposed for alternatives wilderness B, C, and D, iv, 200 effects to, 140, 141 treatment objectives, 5 wildfires, 44, 62, 146 U.S. Fish and Wildlife Service, 35, 39, 78, 81, Dome Fire, 56 182, 183 Las Conchas Fire, 74, 126, 146, 149 USDA Animal and Plant Health Inspection Wallow Fire, 126 Service, 40 wildlife, i, 66, 139, 174
240 Final Supplemental Environmental Impact Statement amphibian sensitive species, 86, 224 effects to migratory birds, iii, 94 birds, 87, 194 mammal sensitive species, 89, 194 cumulative effects, 69 migratory birds, 92, 93, 96 effects of proposed treatments, 67, 68 sensitive species, 83, 86
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