United States Department of Agriculture Aerial Application of Forest Service Fire and Aviation Management Washington, DC Fire Retardant

Draft Environmental Impact Statement

May 2011

Cover photo by Kreig Rasmussen, Fishlake National Forest, 2005.

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Fire Retardant DEIS

Fire Retardant DEIS

Contents

Abstract 2

Summary 4

Significant Issues 4

Proposed Action and Alternatives 5 Alternative 1: No Aerial Application of Fire Retardant 5 Alternative 2 (Proposed Action): Continued Aerial Application of Fire Retardant Under the 2000 Guidelines, Including 2008 Reasonable and Prudent Alternatives 5 Alternative 3 (Preferred Alternative): Continued Aerial Application of Fire Retardant, Using 2011 Guidelines and Adopting the 2008 Reasonable and Prudent Alternatives 5

Alternatives Eliminated from Detailed Study 7

Major Conclusions of the Environmental Impact Statement 8 Air Quality 8 Aquatic Vertebrates and Invertebrates 8 Cultural Resources 8 Hydrology 8 Plant Species 9 Public Health and Safety 9 Scenery Management 9 Social and Economic Considerations 10 Soils 10 Wilderness Character 10 Wildland Fire Management 11 Wildlife Species and Habitats 12

Chapter 1. Purpose and Need for Action 16

Document Structure 16

Project Background 16

Fire Management Background 17 Fire Occurrence 17 Threats from Wildfire 18 Fire Suppression Capability 18

Fire Retardant DEIS Contents

Purpose of and Need for Action 19

Scope 19

Proposed Action 20

Decision Framework 20

Public Involvement 20

Issues 21

Chapter 2. Alternatives, Including the Proposed Action 24

Introduction 24

Alternatives Considered in Detail 24 Alternative 1: No Aerial Application of Fire Retardant 24 Alternative 2 (Proposed Action): Continued Aerial Application of Fire Retardant Under the 2000 Guidelines, Including 2008 Reasonable and Prudent Alternatives 24 Alternative 3: Continued Aerial Application of Fire Retardant, Using 2011 Guidelines and Adopting the 2008 Reasonable and Prudent Alternatives 24

Alternatives Considered but Eliminated from Detailed Study 26 Alternative 4: Allow Use of Fire Retardant in an Unrestricted Manner 26 Alternative 5: Prohibit Aerial Application of Retardant in Areas Within One-Quarter Mile from Waterways, in Wilderness and Wilderness Study Areas, and in Other Withdrawn Land Allocation Areas 27 Alternative 6: Use Only Water for Aerial Suppression of Fires 27 Alternative 7: Restrict the Use of Retardant to Those Exceptional Situations Where the Benefits Far Outweigh the Risks 27 Alternative 8: Use Retardant Only Where Proven Safe and Effective 27 Alternative 9: Do Not Use Retardant Until a New, Less Toxic Retardant is Developed 28 Alternative 10: Increase the Size of Protections for Waterways and Increase Protection for Some Specially Designated Areas 28

Comparison of Alternatives 28

Fire Retardant DEIS Contents

Chapter 3. Affected Environment and Environmental 32 Consequences

Introduction 32

Air Quality 33 Affected Environment 33 Environmental Consequences 34

Aquatic Vertebrates and Invertebrates 35 Affected Environment 35 Environmental Consequences 35

Cultural Resources 46 Affected Environment 46 Environmental Consequences 46

Hydrology 50 Introduction 50 Affected Environment 50 Environmental Consequences 55

Plant Species 65 Introduction 65 Affected Environment: Federally Listed Threatened, Endangered, Proposed, Candidate, and Forest Service Sensitive Plant (TEPCS) Species 66 Environmental Consequences: Federally Listed Threatened, Endangered, Proposed, Candidate, and Forest Service Sensitive Plant Species 66 Affected Environment: Noxious and Non-Native Invasive Plant Species 75 Environmental Consequences: Noxious and Non-Native Invasive Plant Species 76 Summary of Effects on Federally Listed TEPCS Plant Species and Noxious and Non-Native Invasive Plant Species 79

Public Health and Safety 80 Affected Environment 80 Environmental Consequences 83

Scenery Management 84 Affected Environment 84 Environmental Consequences 85

Fire Retardant DEIS Contents

Social and Economic Considerations 86 Introduction 86 Affected Environment 86 Environmental Consequences 87 Environmental Justice 95

Soils 97 Introduction 97 Affected Environment 97 Environmental Consequences 98

Wilderness Character 103 Introduction 103 Affected Environment 103 Environmental Consequences 104

Wildland Fire Management 106 Introduction 106 Affected Environment 106 Current Implementation of the 2000 Guidelines 120 Environmental Consequences 121

Wildlife Species and Habitats 127 Introduction 127 Affected Environment 127 Environmental Consequences 128

Chapter 4. Consultation 136

Preparers and Contributors 136

Distribution of the Draft Environmental Impact Statement 136 Agencies 136 Tribes 136 Organizations 146 Businesses 146 State Government Agencies 146 Local and Regional Government Agencies 146 Individuals 147

Fire Retardant DEIS Contents

ID Team Members 147

Others 147

Glossary 150

Literature Cited 156

Appendices 170 Appendix A – 2000 Guidelines for Aerial Delivery of Retardant

or Foam 170 Appendix B – Implementation of the Reasonable and Prudent

Alternatives 174

Appendix C – Fire and Retardant Use Information 180

Appendix D – Misapplication of Fire Retardant Data Analysis 194 Appendix E – National Screen for Federally Listed Species and

Critical Habitat Impacts 197 Appendix F – Fish and Aquatic Invertebrate Species List and

Effects 205

Appendix G – Plants 269

Appendix H – Fire Retardant Soil Risk Rating Indicators 329

Appendix I – Wildlife 332

Appendix J – Suppression Chemicals and Delivery Systems 345

Appendix K – Retardant Avoidance Maps for Alternative 5 350 Appendix L – Forest Service Wildland Fire Chemical Program

and Process 352

Appendix M – Guidance for Pilots 355

Fire Retardant DEIS Contents

List of Tables Table 1 Comparison of Alternatives 28 Table 2 Fish Toxicity to Long-Term Retardant Concentrates 36 Table 3 Peak Fire Seasons by Forest Service Region 41 Table 4 Recorded Misapplication Aerial Fire Retardant Drops in Aquatic Habitats or Buffer Areas 42 Table 5 Miles of Stream and Acres Within 300 Feet of Streams, by Region. Source: Forest Service GIS 51 Table 6 Lakes, Wetlands, and Other Water Features. Source: Forest Service GIS 51 Table 7 Intrusions Into Water or Buffers, by Region 54 Table 8 National Primary Drinking Water Standards 55 Table 9 Fires and Retardant Use by Forest Service Region, 2000–2010 62 Table 10 Comparison of Potential Impacts, by Alternative 64 Table 11 Current Average Suppression and Retardant Costs for Forest Service Fires (2000–2010) (2010$) 86 Table 12 Components of Cost Efficiency 88 Table 13 Annualized Costs, by Alternative (2010$) 89 Table 14 Summary of Direct and Indirect Effects 94 Table 15 Summary of Effects on Soils 102 Table 16 Proportion of total National Forest System acres (excluding Alaska and Puerto Rico) in each fire regime 106 Table 17 Coverage level, fuel models, and flow rate range for fire retardant drops 116 Table 18 Comparison of Effects of the Alternatives on Wildlife Species and Habitats 133 Table C-1. Estimated Area of Fire Retardant Application on USFS Lands. 180 Table C-2. Estimated area of Fire Retardant Application on USFS Lands by Forest. 181 Table C-3. Total Retardant Drops and Fires, 2000–2010. 188 Table C-4. Representative Ecoregions for Retardant Application. 193 Table D-1. Misapplication of Fire Retardant Data, 2008–2010. 194 Table E-1. National Screening Process. 197 Table F-1. Federally Listed Threatened, Endangered and Proposed Aquatic Vertebrate and Invertebrate Species Known or Suspected to Occur on or Near Forest Service Lands with the Potential for Aerial Application of Fire Retardant (Under Both FWS and NOAA Jurisdiction). 205 Table F-2. Likely to Adversely Affect (LAA) Determinations for Fish Species by National Forest Based on Retardant Use (Under Both FWS and NOAA Jurisdiction). 212 Table F-3. No Effect (NE) Determinations for Fish Species by National Forest Based on Retardant Use (Under Both FWS and NOAA Jurisdiction). 222 Table F-4. Likely to Adversely Affect (LAA) Determinations for Invertebrate Species by National Forest Based on Retardant Use. 223

Fire Retardant DEIS Contents

Table F-5. No Effect (NE) Determinations for Invertebrate Species by National Forest Based on Retardant Use. 226 Table F-6. Forest Service Sensitive Aquatic Vertebrate & Invertebrate Species (Including Candidate Species) Known or Suspected to Occur on or Near Forest Service Lands With the Potential for Aerial Application of Fire Retardant. 229 Table F-7. Retardant Effects that May Impact Individuals or Habitat, But Will Not Likely Contribute to a Trend Towards Federal Listing or Loss of Viability to the Population or Species for Sensitive Fish Species by National Forest Based on Retardant Use 244 Table F-8. Findings of No Impact for Sensitive Fish Species by National Forest based on Retardant Use 258 Table F-9. Retardant Effects that May Impact Individuals or Habitat, But Will Not Likely Contribute to a Trend Towards Federal Listing or Loss of Viability to the Population or Species for Sensitive Aquatic Invertebrate Species by National Forest Based on Retardant Use 260 Table F-10. Findings of No Impact for Sensitive Aquatic Invertebrate Species by National Forest based on Retardant Use 266 Table G-1. Federally Listed Plant Species Known or Suspected to Occur on or Near Forest Service Lands with the Potential for Aerial Application of Fire Retardant. 273 Table G-2. Federally Listed Plant Species Likely Adversely Affected From Aerially Applied Fire Retardant. 282 Table G-3. Federally Listed Plant Species Not Likely Adversely Affected From Aerially Applied Fire Retardant. 287 Table G-4. Designated Critical Habitat For Plant Species Impacted From Aerially Applied Fire Retardant. 292 Table G-5. Federally Listed Plant Species Determined To Have No Effect From Aerially Applied Fire Retardant. 294 Table G-6. Federally Listed Species Habitats, Retardant Use, And Effects By Forest Service Region. 296 Table H-1. Soil Risk Rating Indicators and Levels 329 Table I-1. List of USFWS ESA Listed Threatened, Endangered, and Proposed Species Included in this Analysis. 332 List of Figures Figure 1 Map of National Forest System lands. 20 Figure 2 Comparison of Percent of Fires Versus Percent Retardant Drops by Region. 61 Figure 3 Fate of Aerially Applied Fire Retardant. 67 Figure 4 Number of Fires Nationally Reported from 1986 to 2009. Source: National Interagency Fire Center, Fire Information, Wildland Fire Statistics 107 Figure 5 Total Acres Burned Nationally from 1986 to 2009. Source: National Interagency Fire Center, Fire Information, Wildland Fire Statistics 108 Figure 6 National Federal Large Airtanker, MAFFS, SEAT, and Helitanker Bases, May 24 2004. 112 Figure 7 Gallons of Aerially Applied Fire Retardant by Forest Service Region, 2000–2010. 115 Figure 8 Number of Fire Retardant Drops by Forest Service Region, 2000–2010. 115

Fire Retardant DEIS Contents

Fire Retardant DEIS Abstract

Fire Retardant DEIS 1 Abstract

Abstract

Nationwide Aerial Application of Fire Retardant

Draft Environmental Impact Statement

Lead Agency: U.S. Department of Agriculture (USDA), Forest Service

Cooperating Agency: U.S. Department of the Interior (USDI), Bureau of Land Management

Responsible Official: Thomas Tidwell, Chief, USDA Forest Service

For Information Contact: Glen Stein, Fire and Aviation Management, USDA Forest Service, [email protected], (208) 869-5405

Abstract: The USDA Forest Service is proposing to continue the aerial application of fire retardant on National Forest System lands. The Agency is considering three alternatives in detail, including the proposed action. Twenty-seven comments were received in response to the notice of intent to prepare an environmental impact statement. Alternative 2 is the proposed action and Alternative 3 is the preferred alternative. The draft environmental impact statement describes the effects of each alternative with respect to the purpose and need and significant issues. The draft environmental impact statement is available online at http://www.fs.fed.us/fire/retardant. The final environmental impact statement, when completed, will be available on the same website.

While the Agency invites comments on all aspects of this draft environmental impact statement, comments concerning assumptions made in this document and additional information to be considered would be most appreciated. It is important that reviewers provide their comments at such times and in such a way that are useful to the Agency's preparation of the final programmatic environmental impact statement. Therefore, comments should be provided before the close of the comment period and should clearly identify the reviewer's concerns. The submission of timely and specific comments can affect a reviewer's ability to participate in any subsequent judicial review.

Comments received in response to this solicitation, including names and addresses of those who comment, will become part of the public record for this proposed action. Comments submitted anonymously will be accepted and considered.

Send Comments to: Fax to 208-265-6670.

Email to [email protected].

Mail via postal mail to: USDA Forest Service, Attn: Jodi Kramer, 1602 Ontario St., Sandpoint, ID 83864.

Fire Retardant DEIS 2 Summary

Fire Retardant DEIS 3 Summary

Summary

The U.S. Department of Agriculture (USDA), Forest Service, is seeking public comment on a proposal to continue the use nationwide of aerially delivered fire retardant. The proposal and a new alternative would provide guidance for aerial application on National Forest System (NFS) lands.

On July 27, 2010, the United States District Court for the District of Montana invalidated the Forest Service’s 2008 decision to continue using the 2000 guidelines and adopt the Reasonable and Prudent Alternatives (RPA) identified by the U.S. Fish and Wildlife Service (FWS) and the National Oceanographic and Atmospheric Administration (NOAA) Fisheries Service, holding that the guidelines of 2000 were developed in violation of the National Environmental Planning Act (NEPA) and the Endangered Species Act (ESA). The district court vacated the 2008 decision, and remanded it to the USDA, FWS, and NOAA Fisheries for further proceedings (Citizens for Better Forestry v. USDA, 632 F. Supp. 2d 968 (N.D. Cal. 2009)).

The Forest Service published a notice of intent (NOI) to prepare an environmental impact statement in the Federal Register on August 27, 2010, to start the public involvement process. Also, the Forest Service sent electronic and hard copy correspondence to a number of individuals and organizations known to have an interest in the aerial application of fire retardant, giving notice of its intent to prepare an environmental impact statement to analyzeand disclose potential consequences associated with aerial application of fire retardant on NFS lands. Significant Issues

The following significant issues were identified from comments received on the NOI and from the previous NEPA analysis:

Water Quality: In certain rare situations, when retardant comes in contact with water, the retardant chemicals can be toxic to aquatic wildlife and temporarily alter water quality. Under the proposed action, contact of retardant with water from aerial delivery would be avoided, with the exception of those situations described in the 2000 guidelines (see Guidelines, page 8, in Appendix A). The exceptions were established so that incident commanders could balance a potential risk to the environment with potential public and firefighter safety. Also, on rare occasions misapplications may occur, accidentally releasing retardant into a waterway.

Human Health and Safety: Regard for human safety and the management of risk guide all fire management decisions and actions. On every fire, firefighter safety and public safety are the highest priorities. Aerially applied fire retardant reduces wildfire intensity and rate of spread, decreasing risks to firefighters and enabling them to construct fireline safely. In many situations, the use of retardant in concert with firefighters on the ground allows the Forest Service to safely meet its responsibilities to protect landscapes, resources, and people.

Impacts on Threatened and Endangered Species: Consultation with the U.S. Fish and Wildlife Service and NOAA Fisheries Service (the Services) conducted on the 2007 environmental assessment (EA) resulted in 65 jeopardy calls. As a result, the Services provided the Forest Service with reasonable and prudent alternatives to address the jeopardy calls. In a July 27, 2010, decision, the Federal District Court in Montana ruled that the reasonable and prudent alternatives did not adequately address the jeopardy concerns and ordered the Forest Service to again conduct its NEPA analysis. In addition, the 2007 EA did not address retardant effects on terrestrial species.

Fire Retardant DEIS 4 Summary

Cultural Resources: Cultural resources—such as petroglyphs, historic structures, traditional Native American gathering areas, and sacred sites—may be affected by the aerial application of fire retardant. Based on the analysis, it has been determined that potential effects are best addressed at the local incident level. Proposed Action and Alternatives

These issues led the Forest Service to develop a proposed action and two alternatives for detailed study, including a no-action alternative. Alternative 1: No Aerial Application of Fire Retardant

Under this alternative, the Forest Service would discontinue the aerial application of fire retardant for those fires occurring on NFS lands. Ground-based application of long-term fire retardant and water (and also aerial application of water only) would continue to be available for use by incident commanders as fire suppression tools. This alternative would not prohibit the aerial application of fire retardant on lands owned or administered by the various States, private parties, or other Federal agencies. Each Federal agency would make its own decision on the use of aerial applied retardant on its managed lands. Alternative 2 (Proposed Action): Continued Aerial Application of Fire Retardant Under the 2000 Guidelines, Including 2008 Reasonable and Prudent Alternatives

Under the Proposed Action, the Forest Service would continue aerial application of retardant and permanently adopt the 2000 Guidelines for Aerial Delivery of Retardant or Foam Near Waterways (Appendix A). This alternative also adopts the reasonable and prudent alternatives (RPAs) as identified by the Services (Appendix B). Alternative 3 (Preferred Alternative): Continued Aerial Application of Fire Retardant, Using 2011 Guidelines and Adopting the 2008 Reasonable and Prudent Alternatives

Alternative 3 consists of the following components:

Part one replaces the 2000 Guidelines for Aerial Delivery of Retardant of Foam Near Waterways [Appendix A]) with the 2011 Guidelines, to better respond to ESA, cultural resources, and tribal concerns. The 2011 Guidelines include the 2008 RPAs (Appendix B).

Part two provides protocols for mapping avoidance areas at the forest level.

Part three provides direction for consultation should a misapplication occur.

Part four addresses monitoring actions required to evaluate misapplications.

Part One: Draft Proposed 2011 Guidelines for Aerial Delivery of Retardant

Subject to one exception:

Fire Retardant DEIS 5 Summary

Aerial delivery into waterways or avoidance areas may take place when human life or safety is threatened and the use of retardant can be reasonably expected to alleviate the threat.

Incident commanders and pilots are required to avoid aerial application of retardant on mapped avoidance areas for threatened, endangered, proposed, candidate, or locally identified sensitive species (TEPCS) or within 300 feet either side of waterways.

These guidelines do not require the helicopter or airtanker pilots-in-command to fly in a manner that endangers their aircraft, other aircraft, or structures or that compromises ground personnel safety or the public.

Operational Guidance to ensure that retardant drops are not made within 300-foot buffers either side of waterways or mapped avoidance areas for TEPCS species:

Medium/Heavy Airtankers, Single Engine Airtankers, and Helicopters: When approaching mapped avoidance areas for TEPCS species or waterways that are visible to the pilot, the pilot will terminate the application of retardant approximately 300 feet before reaching the mapped avoidance area or waterway. When flying over a mapped avoidance area or waterway, pilots will wait one second after crossing the far border of a mapped avoidance area or bank of a waterway before applying retardant. Pilots will make adjustments for airspeed and ambient conditions such as wind to avoid the application of retardant within the 300-foot buffer zone or mapped avoidance area

Protection of Cultural Resources, including historic properties, traditional cultural resources, and sacred sites: These resources cannot be mapped using a national protocol or addressed with a standard prescription that would apply to all instances. Therefore, they should be given case-by-case consideration when ordering aerial applications of fire retardant. As necessary, incident commanders will consider the effects of aerial applications onknownor suspected historic properties, any identified traditional cultural resources, and sacred sites. Cultural resources specialists, archaeologists, and tribal liaisons will assist in the consideration of effects and alternatives for protection.

Part Two: National Avoidance Areas and Mapping Protocols

The following direction establishes protocols for mapping avoidance areas.

Use FWS and NOAA Fisheries Service-designated critical habitat layers.

Use National Hydrography Dataset (NHD) for mapping water bodies.

Use FWS, NOAA Fisheries, and Forest Service population information for occupied sites when critical habitat has not been designated.

All forests that have listed threatened, endangered, and proposed species will complete and update maps as necessary in cooperation with local offices of FWS and NOAA Fisheries Service.

Use locally identified locations of candidate and sensitive species that require additional protection with avoidance areas.

Maps will be at the appropriate quad-level scale.

Part Three: ConsultationShould a Misapplication Occur

Fire Retardant DEIS 6 Summary

A report of misapplication requires notification by the national forest to FWS and NOAA Fisheries Serviceto determine if future mitigation measures are necessary or if it is necessary to reinitiate consultation that is required when there has been an adverse impact on a listed species or its designated critical habitat.

If a retardant drop occurs on a cultural resource, a traditional cultural property, or a sacred site, then the site condition will be assessed by a qualified archaeologist and reported to the State Historic Preservation Officer. If theaffected resource is a sacred site or a traditional cultural property, then tribal notification and consultation will be required as part of the determination of effects. If the effect is found to be adverse, then the Forest Service will consult with the tribe to determine an appropriate course of action to mitigate or resolve the adverse effect.

Part Four: Monitoring

To determine if the Forest Service is missing retardant drops, the Agency will annually monitor 5 percent of type 4-5 fires (initial attack fires size A-D/fires less than 300 acres) per forest (minimum of one per forest) wherefire retardant has been applied. Generally fires of this size do not have qualified resource personnel to do anevaluation on site at the time of the fire.

If a misapplication is reported, a biologist will determine if adverse effects are present and, in consultation with the national forest administration, FWS, and NOAA Fisheries Service, an appropriate restriction on future aerial application of retardant may be necessary for the area reported.

If consultation results in a recommendation for monitoring of cultural resources, traditional cultural properties, or a sacred site, then a monitoring plan will be developed in consultation with the affected tribe.

The Forest Service/Fire and Aviation Management will revise existing reporting forms for misapplications to ensure consistent collection of data. Alternatives Eliminated from Detailed Study

Several alternatives were suggested during the public scoping process and were examined by the Interdisciplinary Team. The alternatives examined but not evaluated in detail include the following:

Alternative 4: Allow Use of Fire Retardant in an Unrestricted Manner.

Alternative 5: Prohibit Aerial Application of Retardant in Areas Within One-Quarter Mile of Waterways, in Wilderness and Wilderness Study Areas, and in Other Withdrawn Land Allocation Areas.

Alternative 6: Use Only Water for Aerial Suppression of Fires.

Alternative 7: Restrict the Use of Retardant to Those Exceptional Situations in Which the Benefits Far Outweigh the Risks.

Alternative 8: Use Retardant Only Where Proven Safe and Effective.

Alternative 9: Do Not Use Retardant until a New, Less Toxic Retardant is Developed.

Alternative 10: Increase the Size of Protections for Waterways and Increase Protections for Some Specially Designated Areas.

Fire Retardant DEIS 7 Summary

Major Conclusions of the Environmental Impact Statement Air Quality

As there would be no aerial delivery of fire retardant under Alternative 1, there would be no direct, indirect, or cumulative effects on air quality associated with this alternative. Assuming, under this alternative, that more acres are likely to burn, more potential exists for smoke in the air, but any attempt to quantify the increase in smoke would be highly speculative.

Under Alternatives 2 and 3, there would be no measurable direct, indirect, or cumulative effects from the aerial delivery of fire retardant on air quality under either of the action alternatives because retardant does notremainin the air long enough (less than a minute) to be transported outside the immediate affected area. If vegetation that was sprayed with retardant should burn, it could result in the volatilization of nitrogen from the retardant, increasing nitrous oxide emissions. However, these potential increases would likely be offset by vegetation that would not burn as a result of the retardant drop. Aquatic Vertebrates and Invertebrates

The direct, indirect, and cumulative effects on aquatic vertebrates and invertebrates are the same for Alternatives 2 and 3. There will always be a risk of misapplication of fire retardant to waterways under both Alternatives 2and 3, so the determination of effects is very conservative for threatened, endangered, and sensitive species. In general, if a forest has had one or more fire retardant drops in the past 10 years, then the determinations were “likelyto adversely affect” threatened and endangered species and “may impact individuals and habitat, but are not likely to trend towards Federal listing” for sensitive species. Cumulative impacts on threatened, endangered, and sensitive species are expected to be minor and short-term because application of aerial fire retardant occurs on a very small proportion of the land base, avoidance area mapping (the 300-foot buffer on waterways) protects species except when a misapplication occurs, all other fire suppression tools will continue to be used, fire retardant formulations will likely continue to be the same, and Forest Service fire preparedness and suppression budgets are not likely to increase. Cultural Resources

Since there would be no aerial delivery of fire retardant under Alternative 1, there would be no direct, indirect or cumulative effects on cultural resources associated with this alternative. Under Alternatives 2 and 3, cultural resources, including traditional cultural properties, sacred sites, and historic properties may be affected by the aerial application of fire retardant. The effects include direct visual impacts on historic properties caused by the colorand persistence of color associated with the application of retardant; the direct physical impacts caused by the chemical composition of fire retardant (deterioration of artifacts and residues, and exfoliation of rock surfaces); andindirect effects on the human environment when fire retardant is applied to sacred sites or native foods. Hydrology

Fire retardant in water can have adverse impacts on water quality and can have an impact on defined beneficial uses of this water. Generally, impacts are short-term, as dilution occurs when the affected water moves downstream. Eutrophication can occur where retardant affects small bodies of water that do not have the capacity for much dilution.

Fire Retardant DEIS 8 Summary

Alternative 1 does not allow aerial use of fire retardant and therefore has no direct effect from aerially applied fire retardant. Alternative 2 would have occasional impacts either from the use of exceptions or from an accidental drop into water. It is estimated that 0.25 percent of retardant drops impact water or the 300-foot buffer under this alternative. Alternative 3 would have a slight drop in the percentage of drops affecting water as there are fewer exceptions under this alternative. Plant Species

No impact on federally listed sensitive plant species or native plant communities and no increase in noxious or non-native invasive plant species (NNIS) due to the fertilizing effects of aerially applied fire retardant would occur from implementation of Alternative 1. Impacts on specific federally listed species, designated critical habitats, and sensitive and candidate species may occur from implementation of Alternatives 2 or 3. Impacts will vary based on habitat, avoidance area mapping, potential for retardant use based on historical use and land base impacted, potential for unknown occurrences, and potential for misapplication of retardant.

For Alternatives 2 and 3, impacts on federally listed plant species include: 81 species that are not likely to be adversely affected, 62 species that are likely to be adversely affected, and 28 species that are likely to experience no effect. Twenty two designated critical habitats are not likely to be adversely affected, with the remaining 2 not likely to be affected.

For federally listed sensitive species, which include candidate species for Federal listing, all 2,719 species are determined to be impacted but not likely to trend toward listing. Potential for increases in NNIS species may occur with implementation of Alternatives 2 or 3. These potential increases would be (1) dependent on the presence and response of NNIS species in or near retardant application areas; (2) localized to the general areas of retardant application and would be treated using local forest NNIS treatment strategies, if identified by resource specialist on site; and (3) less affected by retardant than by impacts from fire itself and/or other fire fighting tactics. Public Health and Safety

Under Alternative 1, the non-use of retardants will likely have no effect in remote areas on human health. When fires occur on Forest Service land near developed communities, smoke from fires may have a greater impacton human health than retardants applied during firefighting operations. Respiratory problems aggravated by smoke inhalation have potential to affect many more people directly, resulting in respiratory distress, bronchial infections, and hospitalizations; and indirectly, as access to forest lands, outdoor recreation, and employment may be restricted.

The human health effects of Alternatives 2 and 3 are likely to be minimal: primarily skin irritations, based on records of past incidents. The use of retardant has the potential to reduce smoke concentrations in some areas more than the use of water only; however, the greater influence on smoke concentrations is likely to be the presence of wind sufficient to disperse the smoke. There is some potential for application of retardant on private property, including gardens and pets. As discussed above, cleaning property and pets contacted by retardant is unlikely to have health effects, although consumption of garden produce that was coated with retardant is not advised even after removing the retardant. Scenery Management

Under Alternative 1, there would be no direct, indirect, or cumulative effects on scenic resources from the aerial application of fire retardant.

Fire Retardant DEIS 9 Summary

The application of various aerial fire retardants under Alternatives 2 and 3 may have a temporary impact onscenic resources on National Forest System lands. Colored fire retardants can temporarily stain surfaces a reddish color. The duration of this impact varies and depends both on the site conditions (soils, vegetation, and other physical characteristics) and on weather events (rain and snowfall) following the application. The visibility of the residual retardant will last longest in rocky areas and where little precipitation occurs. Areas composed of more porous surfaces and receiving more frequent precipitation will have shorter duration impacts. Most commonly, the effect on the scenic resource is short-lived and of minimal consequence. As the shift is made to the use of fire retardant with fugitive colorant, the effects on scenic resources would diminish. Social and Economic Considerations

Annual Agency-wide compliance costs associated with avoidance area mapping, assessments, consultations, and monitoring are estimated to be only slightly higher for Alternative 3 ($1.4 million) than Alternative 2 ($1.0 million). Compliance costs are relatively small compared to estimated costs for applying retardant ($24 to $36 million per year; similar to Alternatives 2 and 3). Combined annual costs for compliance and retardant use are small percentages of total average annual suppression costs for 2000 to 2010 ($917 million per year). There are no compliance or retardant costs under Alternative 1; however, other suppression costs (e.g., for substitute tools and tactics) and the probability of escaped fires are expected to be higher under Alternative 1. Suppression cost efficiency istherefore projected to be lower under Alternative 1 than Alternatives 2 and 3, recognizing that this proposed action has no direct impact on fire suppression objectives. There may be potential for slight increases in the probability ofescaped fires under Alternative 3 compared to Alternative 2 for some forest units, depending in part on the extentofavoidance area mapped for different units. As a consequence, it is concluded that suppression cost efficiency under Alternative 3 is similar to or slightly lower than Alternative 2 (see summary of fire operation indicators for additional details about suppression efficiency). Soils

Effects on forest soils from retardant resemble a fertilizing response. For nutrient-poor soils (sandy, with low organic matter content), the addition of nitrogen and phosphorus could improve soil productivity in the short term. For already productive soils (clay, with high organic matter content), the additional nutrients could have an acidifying effect and reduce soil pH, making some nutrients unavailable. An indirect effect of fire retardant application is an increase in vegetative growth and potential change in vegetative community structure and composition. Leaching of nitrogen into streams and water bodies could occur in areas of coarse textured soils and for drops occurring within the water body influence zone. The persistence of effects will depend on vegetation type and post-application weather patterns (Adams and Simmons 1999). Wilderness Character

Under Alternative 1, there would be no effects on wilderness characteristics from the use of aerially applied fire retardant, because none would be used.

The effects on wilderness characteristics would be the same under both Alternatives 2 and 3, because there are no differences between these alternatives in the presence of wilderness. These effects are addressed for the identified wilderness characteristics.

Fire Retardant DEIS 10 Summary

Untrammeled. Fire retardant introduces chemicals into the environment that, at the very local level, will affect nutrient loads, nutrient cycling, growth rates, and potentially some toxicity issues. The retardant may affect plant growth, may impact micro-habitats for microorganisms, and may affect use of vegetation that is treated. The presence of fire retardant chemicals could affect ecological processes at the micro scale. The degree of impact dependson the amount and type of retardant.

Natural. The presence of fire retardant dye creates an unnatural appearance, which is another indicator ofthe effects of man and civilization. To the extent that fire retardant chemicals disrupt natural processes or detract from the perception of natural surroundings via coloration of vegetation, it is a negative effect on the natural quality of wilderness. As the use of fugitive colorant in fire retardant increases, these effects are expected to decrease. Retardant loads that are dropped low or fail to disperse may also damage vegetation, leading to an unnatural-appearing localized impact.

Undeveloped. While fire retardant is not a structure or installation, the presence of the dye trace can result invisible presence of the fire retardant in wilderness. When the dye is dropped in highly visible locations, it can detractfrom the scenic qualities of wilderness. As the use of fugitive colorant in fire retardant increases, these effects are expected to decrease.

Primitive Recreation and Solitude. Fire suppression activities, including the application of retardant, are unlikely to adversely affect human use and visitation because most active fire suppression areas are closed to human use. If visitors are in the area, they may be affected by the sights and sounds of aircraft and fire retardant drops, but as these are transient and of short duration, they are not likely to have any long-lasting effect on the visitor experience. Many people find these activities unusual and an enhancement to their experience because these activities arenot readily seen in other locations.

Special Features. Fire retardant drops may adversely affect cultural resources, historic structures, and other features in wilderness. Effects include coloration, application damage, and small changes in nutrient loading. The long-term impacts are slight and are usually mitigated through the guidance of fire resource advisors during active fire events in identifying areas to avoid.

Cumulative Effects. The number and degree of current and projected fire retardant drops are not sufficient to have long-lasting effect on wilderness character. Wildland Fire Management

The effects analysis for wildland fire management is based on several factors, including retardant effectiveness, initial attack success, and exposure of incident responders; partnerships and political consequences; air quality; and public safety. These factors were evaluated relative to the three alternatives with the following consequences. For Alternative 1: significantly reduced effectiveness of aerial resources (primarily air tankers) and reduced success of firefighters on initial attack success (now at about 98 percent), which can lead to more acres burned andstructures lost, increased exposure of incident responders to fireline hazards, inconsistent use of retardant among partners and cooperators, failure to meet public expectations, and decreased air quality. For Alternative 2, as this alternative proposes to continue “business as usual” for the most part, there would be no substantial effects in any specific area of concern. For Alternative 3, even though this alternative will still allow for the use of retardant, it is uncertain how significant the impact of national standard mapping protocols for TESPC will be on its use; inotherwords: currently, very few units have avoidance areas mapped other than waterways, and depending on the extent of mapping and the identification of additional areas unavailable to the use of retardant, there could beincreased

Fire Retardant DEIS 11 Summary

limitations and restrictions as to where retardant can be applied (with the potential subsequent loss of critical public infrastructure). This could have some impacts on several of the consequences listed above under Alternative 1, as more restrictions in the use of retardant could lead to the reduced effectiveness of fire operations and increase the risk and hazard exposure to firefighters and the public; however, such consequences would not be as significant as curtailing the use of retardant altogether (under Alternative 1). Wildlife Species and Habitats

Under the no-action alternative (Alternative 1), there would be no direct, indirect, or cumulative impacts on wildlife species or habitats; conditions for all wildlife species and habitats would remain the same as if no aerial application activities were used during fire suppression activities.

Alternative 2 would provide protection for waterways and some terrestrial areas for some of the listed threatened and endangered species, but it does not provide protection for any of the federally listed sensitive terrestrial species that may be affected by aerial application of fire retardant.

Alternative 3 proposes greater protection for those sensitive terrestrial species than Alternative 2. Only one exception to the guidelines (for human life and safety) is allowed under this alternative, expected to have lesser impacts on habitat and species than Alternative 2, which allows for three exceptions to the guidelines and, thus, the potential for more impacts. In addition, Alternative 3 proposes monitoring of areas were retardant drops have been used within a watershed to determine if impacts on any terrestrial species exceed an established threshold.

For both action alternatives, it is possible that terrestrial species with limited mobility could be directly affected by aerial applications of retardant. Another potential direct effect to animals resulting from retardant drops is disturbance associated with low-flying aircraft. Another possible direct effect on habitat is the breaking off of tree tops/vegetation by low-flying aircraft.

Indirect effects of the use of aerial application of fire retardant may include the coating or covering of vegetation and food sources consumed by species. Ingestion of retardant on vegetation or insects by a species depends on the amount of retardant used (coverage by vegetation/ ecoregion type), timing of ingestions after application, and the ability of an animal to avoid feeding on chemicals.

The use of proposed avoidance mapping may help to minimize direct and indirect impacts caused by disturbance from the aerial delivery of fire retardant in the vicinity of those TES species populations that may be affected during a critical period of their life cycle (such as nesting) if the predominate fire season coincides with this life cycle period.

Direct and indirect impacts from the proposed action are not expected to impede the long-term recovery of a species or the conservation value of its critical habitat. Implementation of the proposed action would allow essential features of critical habitat to remain functional because long-term retardants are not likely to have lasting effects on terrestrial ecosystems. Additionally, the proposed action will prevent wildfires from becoming potentially much larger and consuming most or the entire critical habitat of a species. Lastly, mitigation measures in avoidance mapping for habitat and populations, the establishment of trigger points for restricting the use of retardants within watersheds where retardant previously has caused adverse effects to a species or population, and yearly pre-season operations planning should all help to reduce impacts on species and habitats.

Fire Retardant DEIS 12 Summary

Overall, risks to terrestrial species are expected to be minor; these risks are small in scale and are not likely to affect more than a few individuals or a portion of a population at a time, and the use of retardants is not likely to have a lasting effect on the species.

For Alternatives 2 and 3, impacts on federally listed threatened and endangered species include: 14 species with Likely to Adversely Affect; 39 species with Not Likely to Adversely Affect; and 58 species with No Effect determinations. For designated critical habitat, impacts are estimated at: 17 with No Effect and 4 with Not Likely to Adversely Affect determinations.

For federally listed sensitive species (including candidate species), impacts are estimated at: 174 species with No Impacts expected, and 473 species with May Impact Individuals or Habitat determinations.

Fire Retardant DEIS 13 Summary

Fire Retardant DEIS 14 Chapter 1. Purpose and Need for Action

Fire Retardant DEIS 15 Chapter 1. Purpose and Need for Action

Chapter 1. Purpose and Need for Action Document Structure

The Forest Service has prepared this environmental impact statement (EIS) in compliance with the National Environmental Policy Act (NEPA) and other relevant Federal laws and regulations. This EIS discloses the direct, indirect, and cumulative environmental impacts that would result from the proposed action and alternatives. The document is organized into four chapters:

Chapter 1. Purpose and Need for Action: The chapter includes information on the history of the project proposal, the purpose of and need for the project, and the agency’s proposal for achieving that purpose and need. This section also details how the Forest Service informed the public of the proposal and how the public responded.

Chapter 2. Alternatives, including the Proposed Action: This chapter provides a more detailed description of the agency’s proposed action as well as alternative methods for achieving the stated purpose. These alternatives were developed based on significant issues raised by the public and other agencies. This discussion also includes mitigation measures. Finally, this section provides a summary table of the environmental consequences associated with each alternative.

Chapter 3. Affected Environment and Environmental Consequences: This chapter describes the environmental effects of implementing the proposed action and other alternatives. This analysis is organized by resource area, beginning with the affected environment followed by the environmental consequences.

Chapter 4. Consultation and Coordination: This chapter provides a list of preparers and agencies consulted during the development of the EIS.

Appendices: The appendices provide more detailed information to support the analysis presented in the EIS.

Glossary: The index provides definitions for terms used in the EIS.

Related documentation, including additional detailed analysis of project-area resources, may be found in the project planning record located at the Boise National Forest Headquarters in Boise, Idaho. Project Background

In 2004, the Forest Service (FS) Employees for Environmental Ethics (FSEEE) filed a lawsuit against the FS alleging that the application of fire retardant required the FS prepare an environmental analysis pursuant toNEPA, and consult with the U.S. Fish and Wildlife Service ( and the National Marine Fisheries Service under the Endangered Species Act (ESA).

On October 24, 2005, the Federal district court for the District of Montana held that the FS’s failure to conduct an environmental analysis on the use of long-term chemical fire retardant on National Forest System (NFS) land violated NEPA, and the agency’s failure to consult on this program similarly violated the ESA.

Fire Retardant DEIS 16 Chapter 1. Purpose and Need for Action

On July 28, 2006, the FS published a notice of proposed action to conduct an environmental analysis and prepare an environmental assessment to determine whether the continued nationwide aerial application of fire retardant using the Guidelines for Aerial Application of Retardants and Foams in Aquatic Environments (April 20, 2000) to fight fires on NFS lands would result in any significant environmental impacts within the meaningofNEPA.

In October 2007, the Forest Service issued an environmental assessment and decision notice and finding of no significant impact (DN/FONSI) titled Aerial Application of Fire Retardant. In February 2008, the Forest Service amended the DN/FONSI by incorporating the reasonable and prudent alternatives proposed by the U.S. Fish and Wildlife Service and National Oceanic and Atmospheric Administration (NOAA) Fisheries during the Section 7 consultation process prescribed by the ESA.

On July 27, 2010, the U.S. District Court for the District of Montana issued a decision in Forest Service Employees for Environmental Ethics v. United States Forest Service, 08-43 (D. Mont.) that invalidated the FS's decision based on violations of NEPA. The Court also held that the U.S. Fish and Wildlife Service and NOAA Fisheries' Section 7 consultation with the FS violated the ESA. The Court directed the FS, U.S. Fish and Wildlife Service, and NOAA Fisheries to cure these NEPA and ESA violations and for the FS to issue a new decision no later than December 31, 2011. Fire Management Background Fire Occurrence

Wild land fire activity, as measured by the number of acres impacted, had been increasing consistently sincethe mid-1980s, but since the 2000 fire season total wildfire acreage has been eclipsed by subsequent fire activityfrom 2004 to 2008. Most regions had more ignitions in 1986–1996 than in the 2000–2010 year time frame. This difference represents the seasonal fluctuation in fire that occurs nationally most often due to weather. However, since the2000 fire season, the number of fires nationwide has actually decreased compared to the number of fires from1986–1996, while the number of acres has significantly increased.

Since 1999, there have been 242 recorded large wildfires in the United States exceeding 50,000 acres, compared to 119 in the previous two decades. These fires accounted for 18.9 million acres out of 40.5 million acres, or46.7 percent of all wildfire acres burned reported for the period 2004–2008.

The total number of fires for the 10-year period of 2000–2009 is 785,130, for a total of 69,313,271 acresburned throughout the United States (NIFC Fire Information Wildland Fire Statistics). Wildfire acres nationwide reached a new modern-day record of 9.87 million in 2006 (Figure 1). In fact, fire activity now is being compared in scale to the wildland fire seasons in the early 1900s that burned large acreages in the West and Northern Midwest.The 10-year moving average has now almost doubled, from 3.78 million wildfire acres in the 1990s to 6.93 million acres in the 2000–2009 period.

The continued threat of wild land fire equal to or greater than the past is recognized in the scientific andresearch community. Risk levels will continue to increase because of growth of population and housing in the wild land-urban interface and intermix. Based on these realities it is important to understand the magnitude of initial attack success as compared to large fire growth.

Fire Retardant DEIS 17 Chapter 1. Purpose and Need for Action

The greatest risk to biodiversity and species are disturbance events that occur at a frequency, severity, duration, pattern, or spatial extent that fall outside limits of adaptability (Noss 2001). Historically ecosystems were subjected to disturbances; recurrent disturbances developed a range of variability over time that represented stability. The ability of ecosystems to maintain themselves within this range has been represented by some general concepts of resistance and resilience (Millar et al. 2007, Noss 2001). Resistance is defined as the ability of ecosystems to maintain relatively constant states in the face of disturbance and stress. Resilience is defined as the ability to recover. Currently, many ecosystems have been altered, degraded, or fragmented to a point where they lack adaptive mechanisms for stability. Therefore, additional stressors such as more frequent, severe, or extensive wildfire potentially contribute to decline in ecosystem integrity (Millar et al. 2007, Opdam 2009, Scholze et al. 2006). Threats from Wildfire

Fire has been a natural and integral part of ecosystems for thousands of years. Early in the past century and with rare exception, wildfires on the landscape burned mostly in remote areas and without devastating and widespread effects on homes and citizens. As suppression became a necessary goal, firefighting agencies evolved but remained discrete entities for decades.

The situation today is different. Population growth and urbanization have placed millions of citizens, homes and entire communities in fire-prone environments. Previous decades of aggressive fire suppression resulted in widespread hazardous accumulations of flammable vegetation; furthermore, as the climate began changing, fire seasons grew longer, hotter, and drier. These factors converged with other factors such as increasing insect and disease mortality, creating increasingly explosive and risk-laden conditions. Fire Suppression Capability

Aggressive initial response within a risk-based approach and within the objectives of the land and resource management plans is expected on all wildfires (WO 2010 Fire Season Expectations letter; 5/11/2010). Wildfires must have documented objectives for the protection of life and property with suppression strategies. Additionally, where fires cross boundaries, jurisdictions often have different missions and objectives making it imperative that there is coordination and collaboration involving partners and neighbors. Therefore, every unplanned ignition receives an initial response and assessment to determine the appropriate management strategy(s). The single most important factor in determining strategy is the risk to human life—firefighters and the public—and our first responsibility on every fire is to provide for firefighter and public safety (FSM 5100). All wildfires willhavea protection objective with a commensurate strategy that can range from quickly suppressing the fire on initial attack to developing longer term suppression strategies that can simultaneously achieve land resource management plan (LRMP) objectives.

Nationwide, the average annual initial attack success rate is 95–98 percent, with the FS 10-year average initial attack rate being 98 percent.

In order to continue with this level of initial attack success rate, the use of all effective firefighting tools is critical. Fire managers frequently use retardant to stabilize small remote fires (type 4-5 incidents) before they mature into larger, long-duration incidents. Retardant aircraft are vital to extended attack fires (type 3) for high values at risk including urban interface areas where typically the resistance to control is high and firefighters are at most risk. Tactical use of airtankers during these incidents can help incident commanders establish anchor points for ground resources to work from (a fundamental and proven fire suppression tactic used for decades). Airtankers arealso essential to support the missions of type 1 and 2 incident management teams (IMTs). Often IMTs are given

Fire Retardant DEIS 18 Chapter 1. Purpose and Need for Action

responsibility for fires within or just outside of the urban interface. These incidents are at a scale of complexity and responsibility on the incident management team and responsible line officer that often extend from urban interface to wilderness area values. Purpose of and Need for Action

The use of fire retardant gives the FS the ability to reduce wildfire intensities and rates of spread undercertain circumstances until ground forces can safely take suppression action over the duration of an incident.

In some instances, high fire intensities and rates of spread greatly reduce the ability of ground-based firefighters to safely fight wild land fires. In addition, remote locations and rugged topography can delay the deploymentof ground forces for suppression. In certain situations, the use of aerially applied fire retardant provides firefighters with the ability to quickly reduce rates of spread and intensities of wild land fires until ground forces can safely take suppression action or until a wildfire is contained or controlled.

The FS must provide firefighters with standard guidelines that provide for the use of aerially applied fireretardant when and where incident commanders determine fire retardant is an appropriate fire fighting tool, while providing for public and fire fighter safety and natural resource protection. Scope

Environmental effects have been analyzed on a nationwide, programmatic scale. The information averages and estimates contained in this analysis are derived from the most accurate, readily available data. Quantifications are limited and vary because this analysis is national in scope.

The proposed action and alternatives are limited to NFS lands, which comprise approximately 193 million acres (Figure 1 'Map of National Forest System lands.'). NFS lands include lands near aquatic environments or terrestrial environments containing threatened, endangered, candidate, or FS sensitive species.

Fire Retardant DEIS 19 Chapter 1. Purpose and Need for Action

Figure 1 Map of National Forest System lands.

Proposed Action

The Forest Service proposes to continue using the 2000 Guidelines for Aerial Application of Fire Retardant, with the addition of the reasonable and prudent alternatives as identified by the U.S. Fish and Wildlife Service and NOAA Fisheries. For a more detailed description of the proposed action see alternative 2 in Chapter 2 of this document. Decision Framework

The deciding official for this proposal is the Chief of the U.S. Forest Service. Based in part on thisdraftEISand comments received, the final EIS, and information contained in the project record, the Chief will decide whether to implement the action as proposed, or as modified in an alternative, including any mitigation measures. Public Involvement

Scoping is defined in the NEPA regulations at 40 CFR 1501.7, as “…an early and open process for determining the scope of issues to be addressed…”

Fire Retardant DEIS 20 Chapter 1. Purpose and Need for Action

On August 27, 2010, a Notice of Intent (NOI) was published in the Federal Register indicating the intention of the FS to prepare an EIS and initiating the 45-day scoping period. As a result of this request for comment, 27 letters were received. Letters were received from individuals or representatives of businesses, special interest groups, Native American tribal governments, and Federal and state agencies. These letters were reviewed for issues and comments on the proposed action. All comments received during the scoping comment period are part of the project record.

In order to supplement the comments received during scoping, the FS contracted with a third-party consultant (Enviroissues–Seattle) through the U.S. Institute for Environmental Conflict Resolution (Institute) to conduct a stakeholder assessment. To develop the assessment methods and protocols, an assessment design team was created, consisting of representatives of the FS, U.S. Fish and Wildlife Service, NOAA Fisheries, FSEEE (plaintiffs in the 2010 lawsuit), National Tribal Environmental Council, and the U.S. Institute.

The assessment design team identified a number of questions for interviews. Twenty-four interviews were conducted with stakeholders from a wide spectrum of possible stakeholders. The Institute Stakeholder Assessment Report identified and recommended six objectives for public involvement. To help meet these objectives, theFShas contracted further with the U.S. Institute and the third-party consultant to assist in facilitation of a variety of public involvement activities. These activities have been and will be posted on the project website at: Fire Retardant Project Website.

There will be a 45-day comment period for the draft EIS. Input from that comment period will be considered during the writing of the final EIS. Issues

Issues serve to highlight effects or unintended consequences that may occur from the proposed action and alternatives, giving opportunities during the analysis to reduce adverse effects and compare trade-offs for the decision maker and public to understand. Issues are best identified during scoping early in the process to help set the scopeofthe actions, alternatives, and effects to consider; but, due to the iterative nature of the NEPA process, additional issues may come to light at any time.

The CEQ regulations refer to issues as they relate to environmental impact statements. For example see 40 CFR 1500.4:

Agencies shall reduce excessive paperwork by: (c) Discussing only briefly issues other than significant ones (g) Using the scoping process not only to identify significant environmental issues deserving of study, but also to deemphasize insignificant issues, narrowing the scope of the environmental impact statement process accordingly

For example see 40 CFR 1501.7:

As part of the scoping process the lead agency shall: … (40 CFR 1501.7(a)(2)) Determine the scope … and the significant issues to be analyzed in depth inthe environmental impact statement. Identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (1506.3), narrowing the discussion of these issues in the statement to a

Fire Retardant DEIS 21 Chapter 1. Purpose and Need for Action

brief presentation of why they will not have a significant effect on the human environment or providing a reference to their coverage elsewhere. (40 CFR 1501.7(a)(3)).

After reviewing historical documents and screening the comments raised during scoping, the following issues were identified as significant. The evaluation of issues is documented in the project record (comment analysis).

Water Quality: In certain rare situations, when retardant comes in contact with water, the retardant chemicals can be toxic to aquatic wildlife and temporarily alter the water quality. Under the proposed action, contact of retardant with water from aerial delivery would be avoided, with the exception of those situations described in the 2000 Guidelines (see Guidelines page 8). The exceptions were established so that incident commanders could balance a potential risk to the environment with potential public and firefighter safety. Also, on rare occasions mis-applications may occur accidentally in a waterway. Human Health and Safety: Regard for human safety and the management of risk guide all fire management decisions and actions. On every fire, firefighter and public safety are the highest priorities. Aerially applied fire retardant reduces wildfire intensity and rate of spread, decreasing risks to firefighters, enablingthemto construct fireline safely. In many situations, the use of retardant in concert with firefighters ontheground allows the FS to safely meet its responsibilities to protect landscapes, resources, and people. Impacts to Threatened and Endangered Species: Consultation with the U.S. Fish and Wildlife Service and NOAA Fisheries (the Services) conducted on the 2007 EA resulted in 65 jeopardy calls. As a result the Services provided the FS with reasonable and prudent alternatives to address the jeopardy calls. In a July 27, 2010, decision the Federal District Court in Montana ruled that the reasonable and prudent alternatives did not adequately address the jeopardy concerns and the consultation did not adequately address effects on terrestrial species. The Court also determined the EA violated NEPA and ordered the FS to redo its NEPA analysis. Cultural Resources: Cultural resources—such as petroglyphs, historic structures, traditional Native American gathering areas, and sacred sites—may be affected by the aerial application of fire retardant. Based on the analysis, it has been determined that potential effects are best resolved at the local incident level.

There were numerous concerns raised during scoping that were used to shape the effects analysis in Chapter 3. Briefly, these concerns include:

The cost/benefit of using fire retardant relative to environmental risks; The potential for displacement of native plant communities by retardant use; The potential for increases in invasive plants and aquatic organisms due to the use of fire retardant; Changes in soil chemistry as a result of applying fire retardant; and Concern for the viability of FS-listed sensitive species populations.

Fire Retardant DEIS 22 Chapter 2. Alternatives, Including the Proposed Action

Fire Retardant DEIS 23 Chapter 2. Alternatives, Including the Proposed Action

Chapter 2. Alternatives, Including the Proposed Action Introduction

This chapter provides an overview of the affected environment, including specific resource components that would be affected by the alternatives, to establish a baseline for analysis. Additionally, this chapter presents the scientific and analytic basis for a comparison of the alternatives and describes the probable effects of each alternative on selected environmental resources. Resource specialist reports, contained in the project record, describe the affected environment in detail, and include the programmatic analysis of the environmental effects of both alternatives. The averages, estimates, and other information contained in this DEIS and the project record are derived from the most accurate, readily available data. Because this DEIS is national in scope, the predicted impacts may vary by site-specific factors. Alternatives Considered in Detail Alternative 1: No Aerial Application of Fire Retardant

Under this no action alternative, the Forest Service would discontinue the aerial application of fire retardant for those fires occurring on NFS lands. Ground-based application of foams, water enhancers (gels), and water (including aerial application of water only) would continue to be available for use by Incident Commanders as suppression tools. This alternative would not prohibit the aerial application of fire retardant on lands owned or administered by the various states, private parties, or other Federal agencies. These other jurisdictions would make its own decision on the use of aerial applied retardant on its managed lands. Alternative 2 (Proposed Action): Continued Aerial Application of Fire Retardant Under the 2000 Guidelines, Including 2008 Reasonable and Prudent Alternatives

Under the Proposed Action, the Forest Service would continue aerial application of retardant and permanently adopt the 2000 Guidelines for Aerial Delivery of Retardant or Foam near Waterways (USDA Forest Service et al. 2000; Appendix A). This alternative also adopts the Reasonable and Prudent Alternatives as identified by the U.S. Fish and Wildlife Service and National Oceanic Atmospheric Administration (NOAA) Fisheries (Appendix B). Alternative 3: Continued Aerial Application of Fire Retardant, Using 2011 Guidelines and Adopting the 2008 Reasonable and Prudent Alternatives

Alternative 3 consists of the following (part) components on Forest Service lands:

Part one replaces the 2000 Guidelines for Aerial Delivery of Retardant of Foam near Waterways (Appendix A) with the 2011 Guidelines to better respond to ESA, cultural resource and tribal concerns. The 2011 Guidelines include the 2008 Reasonable and Prudent Alternatives (Appendix B) Part two provides protocols for mapping avoidance areas at the forest level.

Fire Retardant DEIS 24 Chapter 2. Alternatives, Including the Proposed Action

Part three provides direction for consultation should a misapplication occur. Part four addresses monitoring actions required to evaluate misapplications. Part One: Draft Proposed 2011 Guidelines for Aerial Delivery of Retardant Subject to one exception

Aerial delivery into waterways or avoidance areas may only take place when human life or safety is threatened and the use of retardant can be reasonably expected to alleviate the threat.

Incident Commanders and pilots are required to avoid aerial application of retardant on mapped avoidance areas for threatened, endangered, proposed or locally identified sensitive species or within 300 feet either side of waterways.

These guidelines do not require the helicopter or airtanker pilots-in-command to fly in a manner that endangers their aircraft, other aircraft or structures or compromise ground personnel safety or the public. Operational Guidance to ensure retardant drops are not made within 300-foot buffers either side of waterways or mapped avoidance areas for TEPCS species

Medium/Heavy Airtankers, Single Engine Airtankers, and Helicopters: When approaching mapped avoidance areas for TEPCS species or waterways that are visible to the pilot, the pilot will terminate the application of retardant approximately 300 feet before reaching the mapped avoidance area or waterway. When flying over a mapped avoidance area or waterway, pilots will wait one second after crossing the far border of a mapped avoidance area or bank of a waterway before applying retardant. Pilots will make adjustments for airspeed and ambient conditions such as wind to avoid the application of retardant within the 300-foot buffer zone or mapped avoidance area Protection of Cultural Resources including historic properties, traditional cultural resources, and sacred sites

These resources cannot be mapped using a national protocol or addressed with a standard prescription that would apply to all instances. Therefore, they should be given case-by-case consideration when ordering aerial applications of fire retardant. As necessary, Incident commanders will consider the effects of aerial applications onknownor suspected historic properties, any identified traditional cultural resources, and sacred sites. Cultural resources specialists, archaeologists, and tribal liaisons will assist in the consideration of effects and alternatives for protection. Part Two: National Avoidance Areas and Mapping Protocols

The following direction establishes protocols for mapping avoidance areas.

Use U.S. Fish and Wildlife Services and NOAA Fisheries designated critical habitat layers. Use National Hydrography Dataset (NHD) for mapping water bodies. Use U.S. Fish and Wildlife Services, NOAA Fisheries, and USFS population information for occupied sites when critical habitat has not been designated.

Fire Retardant DEIS 25 Chapter 2. Alternatives, Including the Proposed Action

All forests that have threatened, endangered and proposed (TEP) listed species will complete and update maps as necessary in cooperation with local offices of U.S. Fish and Wildlife Services and NOAA Fisheries. Use locally-identified locations of candidate and sensitive species that require additional protection with avoidance areas. Maps will be at the appropriate quad-level scale. Part Three: Consultation Should a Misapplication Occur

A report of misapplication requires notification by the forest to U.S. Fish and Wildlife Services, and NOAA fisheries as appropriate to determine if there are any necessary future mitigation measures or reinitiation of consultation when there has been an adverse impact to a listed species or its designated critical habitat.

If a retardant drop occurs on a cultural resource, a traditional cultural property, or a sacred site, then the site condition will be assessed by a qualified archaeologist and reported to the State Historic Preservation Officer. If theaffected resource is a sacred site, or a traditional cultural property, then tribal notification and consultation will be required as part of the determination of effects. If the effect is found to be adverse, the agency will consult with the appropriate cultural authorities to determine an appropriate course of action to mitigate or resolve the adverse effect. Part Four: Monitoring

To determine if the FS is missing retardant drops the FS will annually monitor 5 percent of type 4-5 fires (initial attack fires size A-D/fires less than 300 acres) per forest (minimum of one per forest) where fire retardant hasbeen applied. Generally fires of this size don’t have qualified resource personnel to do an evaluation on siteatthetime of the fire.

If a misapplication is reported, a biologist will determine if adverse effects are present and in consultation with the forest, Fish and Wildlife Service and NOAA Fisheries an appropriate restriction on future aerial application of retardant may be necessary for the area reported.

If consultation results in a recommendation for monitoring of cultural resources, traditional cultural properties or a sacred site, then a monitoring plan will be developed in consultation with the affected tribe or other appropriate cultural authorities.

The FS/Fire and Aviation Management will revise existing reporting forms for misapplications to ensure consistent collection of data. Alternatives Considered but Eliminated from Detailed Study

Several alternatives were suggested during the public scoping process and were examined by the Interdisciplinary Team. The alternatives examined but not evaluated in detail include the following: Alternative 4: Allow Use of Fire Retardant in an Unrestricted Manner

While this alternative would maintain the ability to rapidly reduce wildfire intensities while slowing the spread of wildfire and protecting firefighters, it would not meet the need to protect aquatic and terrestrial environments.This alternative was not considered for detailed analysis because it would be contrary to FS policy and the 2000 Guidelines established through interagency coordination and agreement.

Fire Retardant DEIS 26 Chapter 2. Alternatives, Including the Proposed Action

Alternative 5: Prohibit Aerial Application of Retardant in Areas Within One-Quarter Mile from Waterways, in Wilderness and Wilderness Study Areas, and in Other Withdrawn Land Allocation Areas

This alternative was not considered for detailed analysis because it would unreasonably limit an Incident Commander’s ability to be responsive to specific situations. An absolute restriction of aerial retardant could prohibit fire managers from responding quickly when a fire is inaccessible to ground-based suppression or other suppression forces are otherwise unavailable. This alternative would not allow Incident Commanders to protect private property or natural resources adjacent to, or within one-quarter mile of waterways. Therefore, this alternative does not meet the purpose and need for the Proposed Action. The IDT completed a GIS analysis of this alternative for two sample national forests - the Boise and San Bernardino National Forests. The results showed that prohibition of retardant as stated would remove over 90 percent of the National Forest land area from fire retardant use. We have determined that this would be so similar to the no action alternative that it does not warrant further consideration as a stand alone alternative.(Appendix K) Alternative 6: Use Only Water for Aerial Suppression of Fires

This alternative was not considered for detailed analysis as a stand-alone alternative, because aerial application of water only is part of the No Action Alternative. As discussed in the Wildland Fire Management section in Chapter 3, water is 50 percent less effective than retardant when wet, is ineffective when dry and air turbulence caused by aircraft causes most of the water to drift and evaporate before reaching the ground. Therefore, this alternative does not meet the purpose and need to reduce wildfire intensities and rate of spread. Alternative 7: Restrict the Use of Retardant to Those Exceptional Situations Where the Benefits Far Outweigh the Risks

This alternative was not considered for detailed analysis as a stand-alone alternative, because it does not meet the purpose and need to reduce wildfire intensities and rate of spread. The 2000 Guidelines were established toaddress the risks of aerial applied retardant near water, and when the benefits of that use outweigh those risks. It wouldbe speculative to determine when benefits would “far” outweigh the risks or the effectiveness of using retardant. As each wildland fire incident is different, it would be impossible to develop detailed site-specific guidancefor evaluating and weighing various risks and effectiveness. What works at one location may be very different at a different set of conditions. Alternative 8: Use Retardant Only Where Proven Safe and Effective

This alternative was not considered for detailed analysis because the Incident Commanders already take into account the risk of using retardant. Alternative 3 was further designed to provide additional protections for natural resources while not further reducing public and firefighter safety. This alternative can not be analyzed effectively duetoits subjective nature and the variability of fire occurrences.

Fire Retardant DEIS 27 Chapter 2. Alternatives, Including the Proposed Action

Alternative 9: Do Not Use Retardant Until a New, Less Toxic Retardant is Developed

In effect, this delay alternative is embodied in the No Action Alternative. The No Action Alternative considers the use of no retardants that are aerially applied. The Proposed Action considers the effects of allowing aerial application of retardants that do not contain sodium ferrocyanide. The effects of Alternatives 2 and 3 are described based on the formulations of fire retardants used currently. Retardants containing sodium ferrocyanide are no longer used by Federal agencies. The environmental analysis in this document and subsequent decision would not prohibit a future decision on the use of new products. New products proposed for use in fire suppression are evaluated using a separate process. For information on qualifying a product for use as a fire retardant, see the evaluation criteria described on the Forest Service Fire website (http://www.fs.fed.us/rm/fire/wfcs/index.htm#qpl). Alternative 10: Increase the Size of Protections for Waterways and Increase Protection for Some Specially Designated Areas

The IDT considered an alternative that would have increased protections to waterways to 600 feet on each side and protections to some specially designated areas such as designated Wilderness and inventoried roadless areas (IRA). The team discussed the 600 foot buffers with the FWS and NOAA and determined that the approach in Alternative 3 that evaluates the need for buffers at the local National Forest and FWS office level provided a better measure of protection then a larger one size fits all buffer. The team also determined that there were no values to IRAsthat were not already protected by the features in Alternative 2 or 3. The effects of aerial application of fire retardant in designated Wilderness were considered in all alternatives. Comparison of Alternatives

This section provides a summary of the effects of implementing each alternative. Information in the table is focused on activities and effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives.

Table 1 Comparison of Alternatives

Effects Table Indicator Alternative 1 Alternative 2 Alternative 3

Public Health and Safety Known health or None from Some minor skin irritation Same as Alternative 2 safety issues retardant may be may occur when retardant some increase in comes in direct contact with smoke in the air. skin

Impact to federally listed # species and CH None impacted More than alternative 3 Less than alternative 2 because species impacted from the use of because of 3 exceptions of 1 exception and avoidance fire retardant. leading to more retardant area mapping plus additional application in waterways or monitoring. May be some habitat effects as a result of increases in fire size or inability to protect critical habitat

Fire Retardant DEIS 28 Chapter 2. Alternatives, Including the Proposed Action

Effects Table Indicator Alternative 1 Alternative 2 Alternative 3

Impacts to FS sensitive # species None impacted More than alternative 3 Less than alternative 2 because species impacted from the use of because of 3 exceptions of 1 exception and additional fire retardant. leading to more retardant avoidance areas designated for application in waterways or certain candidate and sensitive May be some habitat species. effects as a result of increases in fire size or inability to protect important species habitat

Consideration of species # of species None All 387 species listed in the For wildlife: avoidance to be avoidance mapped requiring 2008 FWS Biological mapping of 14 LAA and up to mapping Opinion need to be 39 NLAA; 14 designated considered critical habitats

For plants: avoidance mapping for 62 LAA and all 81 NLAA

23 designated critical habitats for plants. No change for aquatic species

Potential for invasive Increase in None Could increase slightly as a Could increase slightly as a species to increase as a establishment or result of fertilizing effects of result of fertilizing effects of result of fertilizing effect spread retardant retardant of retardant

Contamination of water Potential for None Low due to avoidance Low due to avoidance mapping with fire retardant from accidental mapping of all waterways - of all waterways accidental drop application of fire retardant into water

Exceptions Potential for None Slightly higher than alt 3 due contaminating water exceptions to more exceptions (3)

Contamination of Potential for None Low due to avoidance Slightly lower than alternative drinking water from fire drinking water mapping of all waterways but 2 due to fewer exceptions (1) retardant contamination higher than alternative 3 due from fire to more exceptions (3) retardant

Fertilizing effects of Acres affected None Expect 2,358-4,715 More acres than alternative 2 retardants on soil by retardant acres/annually (or 0.002 due to fewer acres included in productivity percent) of the total NFS the avoidance mapping. landbase to be affected by retardant.

Fire Retardant DEIS 29 Chapter 2. Alternatives, Including the Proposed Action

Effects Table Indicator Alternative 1 Alternative 2 Alternative 3

Leaching or erosion of Number of None Slightly higher than Lower due to fewer exceptions. soil and nutrients into retardant drops alternative 3 due to more streams and waterbodies within 300 foot exceptions. buffer

Effects on Wilderness Change to None from fire Some potential for short term Same as Alternative 2 characteristics wilderness retardant effects character

Effects to air quality Meets local and Yes, however may Yes, the use of aerially Yes, the use of aerially state air quality be increased delivered fire retardant will delivered fire retardant will not standards smoke in the air not effect air quality effect air quality from larger fires.

Visual Quality None from fire Some short term effects due Same as Alternative 2 retardant, to colorant, use of fugitive however there colorant in the future will may be more acres shorten or eliminate this burned and the effect ability to protect areas of high value visuals may be reduced

Fire Retardant DEIS 30 Chapter 3. Affected Environment and Environmental Consequences

Fire Retardant DEIS 31 Chapter 3. Affected Environment and Environmental Consequences

Chapter 3. Affected Environment and Environmental Consequences Introduction

This chapter provides an overview of the affected environment, including specific resource components that would be affected by the alternatives, to establish a baseline for analysis. Additionally, this chapter presents the scientific and analytic basis for a comparison of the alternatives and describes the probable effects of each alternative on selected environmental resources. Resource specialist reports, contained in the project record, describe the affected environment in detail, and include the programmatic analyses of the environmental effects of alternatives selected for analysis. The averages, estimates, and other information contained in this DEIS and the project record are derived from the most accurate, readily available data. Because this DEIS is national in scope, the predicted impacts may vary by site-specific factors.

Fire Retardant DEIS 32 Chapter 3. Affected Environment and Environmental Consequences

Air Quality Affected Environment

National Forest System (NFS) lands managed by the Forest Service included the whole range of air quality, with areas of high air quality to areas with limited to poor air quality.

The Clean Air Act charges the Forest Service to protect air quality related values in class I areas. This protection is specifically enabled through Prevention of Significant Deterioration (PSD) provisions of the Act.The1964 Wilderness Act identified management goals for all wilderness areas whether or not they are class I. State legislation and PSD regulations determine how the air quality regulatory process is actually conducted State by State. Federal class I areas are defined in the Clean Air Act as national parks larger than 6,000 acres and wilderness areasand memorial parks larger than 5,000 acres, established as of 1977. All other Federal land manager (FLM) areas are designated class II.

The Forest Service, along with the Fish and Wildlife Service and the National Park Service, have worked jointly on guidelines to protect air quality, particularly as it relates to class I areas through the Federal Land Managers’ Air Quality Related Values Work Group (FLAG) (USDA Forest Service et al. 2010). The primary—but not sole—focus of FLAG is the New Source Review (NSR) program, especially in the review of PSD of air quality permit applications. The goals of FLAG have been to provide consistent policies and processes both for identifying air quality-related values (AQRVs) and for evaluating the effects of air pollution on AQRVs, primarily in Federal class I air quality areas.

The Clean Air Act states that FLMs have an “affirmative responsibility” to protect AQRVs. In this respect, the FLM role consists of considering whether emissions from a new or modified source may have an adverse impact on AQRVs and providing comments to permitting authorities (States or EPA). FLMs have no permitting authority under the Clean Air Act, and they have no authority under the Clean Air Act to establish air quality-related rules or standards.

The General Conformity Rule of the Clean Air Act ensures that federally funded or supported actions taken by Federal agencies and departments, including the Forest Service, meet national standards for air quality in Federal non-attainment and maintenance areas. Under the Federal Clean Air Act, any area that violates national ambient air quality standards for any of the six criteria pollutants is designated as a “non-attainment area.” These pollutants are sulfur dioxide, fine particulate matter, carbon monoxide, ozone, nitrogen oxides, and lead. Maintenance areas are any non-attainment area that has been re-designated to attainment status and may be more sensitive to maintaining the designation.

Activities that emit significant levels of criteria pollutants in a non-attainment or maintenance area are subjectto the conformity rule. This rule requires the Forest Service or any Federal agency to demonstrate that its actions will not impede the State implementation plans to attain or maintain the ambient air quality standard. A few examples of activities on national forests and grasslands that may require a review for conformity include:

fuel treatments including prescribed fire and harvest activities; road, trail, or building construction; land use and special use permit decisions such as ski or winter sports area, mining, oil and gas development, and landfills.

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In a recent report (National Park Service 2010) that covers the years 1999–2008, 241 National Park Service (NPS) units had enough data on-site or nearby to report on one or more air quality indicators. Of these, 97 percent showed stable or improving trends in visibility, 100 percent showed stable or improving trends in ozone concentrations, and 93 percent showed stable or improving trends in atmospheric deposition of sulfate, nitrate, and ammonium ions. Since many NFS lands are in close proximity to NPS lands, these values may be illustrative of air quality indicators on NFS lands. Environmental Consequences Alternative 1

Since there would be no aerial delivery of fire retardant there would be no direct, indirect, or cumulative effects on air quality associated with this alternative. Assuming under this alternative that more acres are likely to burn from the application of fire retardant, more potential exists for smoke in the air, but any attempt toquantifythe increase in smoke would be highly speculative. Alternatives 2 and 3

There would be no measurable direct, indirect, or cumulative effects from the aerial delivery of fire retardant on air quality under either of the action alternatives because retardant does not remain in the air long enough (less than a minute) to be transported outside the immediate affected area. If vegetation that was sprayed with retardant should burn, it could result in the volatilization of nitrogen from the retardant, increasing NOx emissions. However, these potential increases would likely be offset by vegetation that would not burn as a result of the retardant drop.

Fire Retardant DEIS 34 Chapter 3. Affected Environment and Environmental Consequences

Aquatic Vertebrates and Invertebrates Affected Environment

The potentially affected environment (and analysis area) is limited to National Forest System land, approximately 193 million acres, but may extend beyond National Forest System land to areas downstream, plus a “reasonable buffer” area around Forest Service lands. While most long-term fire retardant is used in the Western United States, all Forest Service regions except Region 10 (Alaska) have used fire retardant in the past 11 years.

This analysis covers aquatic vertebrates and invertebrates. General groups in this analysis are fish, crustaceans, and mollusks that inhabit water at all times (mussels, clams, etc.). There are 59 threatened, endangered and proposed fish species, 7 threatened, endangered and proposed crustaceans, and 56 threatened, endangered andproposed mollusks. At the Forest Service sensitive species level, there are 171 sensitive fish species, 32 sensitive crustaceans, and 78 sensitive mollusks. Regions 3, 5 and 8 have the highest number of threatened, endangered, and sensitive species nationally. Macroinvertebrates are also discussed under general effects because macroinvertebrates are a key food source for fish, mollusk and crustacean species and the loss of numbers and populations will affectthe viability of the food web.

Of primary importance is the 39 percent of the land base in Forest Service Regions 1–9 that lies within 300 feet of a stream and the 4.4 percent that lies within 300 feet of other water features. This does not include unmapped wetlands. These regions have all used fire retardant within the past 11 years. This equates to a total of 43.4 percent of the land base in Regions 1–9 that contains aquatic habitat. Environmental Consequences General Effects on Aquatic Vertebrates and Invertebrates, Including Habitats

Below is a discussion of the general effects with supporting studies of fire retardant and toxicity to aquatic vertebrates and invertebrates. See the hydrology section of chapter 3 for a discussion of chemical responses of fire retardant in water. Fish Response to Retardant Toxicity

Toxicity studies are not available for all aquatic species analyzed, so this section includes what information is available, mostly on salmonid fish species.

Norris et al. (1983) stated that the some of the factors causing fish mortality include free ammonia and in certain instances. The magnitude of mortality and the distance over which it occurs will vary with characteristics of the application, the site, and quantity of streamflow. Other factors can also affect toxicity of some of the retardants such as water chemistry and sunlight.

Current retardant formulations do not contain cyanide, so fish kills associated with that formulation will no longer occur. The revised U.S. Forest Service Specification 5100-304c for Long-Term Retardant, Wildland Firefighting, June 1, 2007, includes the acute fish toxicity testing requirements and established protocols.

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Backer et al. (2004) found the response of fish to fire retardants could be more significant than their responseto fire. Fish response does not depend only on the amount of retardant to hit the water and variables within thestream, but also on interactive effects among the various ingredients in the retardant or on the interaction of retardant effects coupled with the effects of the nearby fire to the stream.

Johnson and Sanders (1977) found that for rainbow trout, most mortality occurs in the first 24 hours. As a result, the 24-hour and 96-hour LC50s (the concentration at which half of the affected population will die in an established time period) were not significantly different, meaning that the values given below represent both the 24-hourand 96-hour LC50s.

For rainbow trout, more is known about their responses to fire retardants than for any other fish species. When exposed to Phos Chek 259, their LC50 was between 94 and 250 mg/l (Johnson and Sanders 1977). Buhl and Hamilton (2000) found the LC50 of rainbow trout to Phos Chek 259-F was 168 mg/l. In research on Phos Chek D75-R, the rainbow trout 96-hour LC50 was 168 mg/l (between 142 and 194 mg/l) (Calfee and Little 2003). Calfee and Little (2003) also showed that Phos Chek D75-F has a 96-hour LC50 of 228 mg/l (between 184 and 271 mg/l). Gaikowski et al. (1996) also tested Phos Chek D75-F and found similar results with a 96-hour LC50 of 218 mg/l (170 to 280 mg/l). Poulton et al. (1993) found that Phos Chek D75-F was twice as toxic to rainbow trout in hard water compared to soft water. Calfee and Little (2003) were also able to show that D75-R is equally toxic in UV light or dark, while D75-F is most toxic in UV light. Even though D75-F is affected by UV light, even in its most toxic environment, it is still less toxic than D75-R. Gaikowski et al. (1996) tested various early life stages of fish and found that in hard water, all early stages were affected the same, and in soft water, there were minor differences in tolerance, but they were not significantly different.

The Forest Service has worked with the U.S. Geological Service (USGS) to develop a fish toxicity test. The work focused on determining the relative sensitivity to wildland fire chemicals. Young rainbow trout were found tobe representative of the most sensitive of this group of aquatic species and as sensitive as the threatened or endangered species that had been studied.

The final test was developed to use 60 days-post-hatch (dph) rainbow trout. The fish were exposed toaseriesof product dilutions for 96 hours, under static conditions to determine the LC50. The LC50 is the concentration of product in water that results in the death of 50 percent of the aquatic test specimens within a specified time frame, 96 hours in this case. The LC50, expressed in milligrams of product in a liter of solution (mg/L), is the value reported in the fish toxicity summary. The reported values are for the product concentrates. Mix ratios must be considered in addition to the LC50 when estimating toxicity in the field. This is especially true when comparing products with very different mix ratios. When comparing values, the lower the LC50 value, the greater the toxicity.It is the goal of the wildland fire agencies to apply these products in a manner that does not allow them to enter waterways.See Table 2 'Fish Toxicity to Long-Term Retardant Concentrates'.

Table 2 Fish Toxicity to Long-Term Retardant Concentrates

LC50 1

Product Soft Water 2 Hard Water 2

Phos-Chek D75-R 1,775 mg/L 472 mg/L

Phos-Chek D75-F 1,558 mg/L 467 mg/L

Phos-Chek 259-F 148 mg/L 168 mg/L

Fire Retardant DEIS 36 Chapter 3. Affected Environment and Environmental Consequences

LC50 1

Product Soft Water 2 Hard Water 2

Phos-Chek LC-95A 435 mg/L 960 mg/L

Phos-Chek P100-F 1494 mg/L 1932 mg/L

In studies by Buhl and Hamilton (1998), there was no difference in the responses of Chinook salmon to Phos Chek D75-F in hard or soft water. Poulton et al. (1993) likewise found no significant difference in the response of Chinook salmon to Phos Chek D75-F in hard and soft water. Buhl and Hamilton (1998) also found that the LC50 of D75-F is approximately 218 mg/l (between 170 and 280 mg/l) for all early life stages from swim up fry to 90 days post hatch. These tolerance numbers are not significantly different from rainbow trout tolerances (also 218 mg/l,but with some differences in effects to life stage, pH level, and UV light). Poulton et al. (1993) also found that there was no significant difference between the LC50s of rainbow trout and Chinook salmon.

In research by Johnson and Sanders (1977), coho salmon were found to have the same LC50s in response to Phos Chek 259 as rainbow trout have, which was between 94 and 250 mg/l. Again, it is assumed that Phos Chek 259, studied by Johnson and Sanders (1977) is comparable to the Phos Chek brands 259-F and 259-R, as seems to be indicated by Buhl and Hamilton’s (2000) research. The coho salmon LC50s in response to Phos Chek D75-R, D75-F, G75-F, G75-W, LV-R, and LC-95A-R have not been researched.

Fontenot et al. (1998) showed that shortnose sturgeon have a 96-hour LC50 of under 150 mg/l for total ammonia. This is less tolerant than rainbow trout, Chinook salmon, or coho salmon, whose minimal tolerance is 168 mg/l. For un-ionized ammonia, the most toxic form to fish, the 96-hour LC50 for shortnose sturgeon was as toxic as0.37 mg/l with a mean of 0.58 mg/l for shortnose sturgeon (Fontenot et al. 1998). The rainbow trout LC50 for un-ionized ammonia is 0.2 mg/l (Alabaster et al. 1983). The response of shortnose sturgeon to total ammonia and un-ionized ammonia is very similar to the response of salmonids. Macroinvertebrates Response to Retardant Toxicity

When fire retardant hits the water and ammonia concentrations increase quickly, macroinvertebrates exhibit highly variable responses. Macroinvertebrates that react similarly to small amounts of ammonia have up to a four-fold difference in their resistance to acute toxicity (Williams et al. 1986). Adams and Simmons (1999) reported that mayflies and stoneflies in Australia were not affected by Phos Chek D75-F. However, McDonald etal.(1997) reported that D75-F 96-hr LC50 for Hyalella azteca, a very tolerant species of macroinvertebrate, was between 53 and 394 mg/l depending on pH, which is not only lethal, but more lethal than for many species of fish. Almost all macroinvertebrates will drift in the presence of elevated ammonia, but even then, many die. It can take years (Minshall et al. 1997) for macroinvertebrates to recolonize a stretch of stream that is negatively impacted during a wildfire. As long as there is depressed individual and species abundance, fish that depend on those macroinvertebrates as a food source will not recolonize.

One study was conducted using the indigenous aquatic invertebrates that would only be found in Arizona in perennial waters. Mayflies (Epeorus (Iron) albertae) were consistently more sensitive to Phos-Chek D75-F than stoneflies (Hesperoperla pacifica) (Poulton et al. 1997). The LC501 for mayflies exposed to Phos-Chek D75-F for 3 hours was 1,033 mg/L (Poulton et al. 1997). This concentration is similar to the field concentration that would result from drift or runoff but is almost 10 times lower than the concentration expected if an accidental drop occurred. Mayflies

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were less sensitive to Phos-Chek D75-F when compared to trout or fathead minnows (Poulton et al. 1997). It is possible that in Arizona’s streams, Phos-Chek D75-F would be more directly toxic to fishes than to the fish food items, such as mayflies. Most toxicity studies have been conducted with Phos-chek D75-F. This formulation is only one of the five formulations being considered in this consultation; wide variation may exist between thetoxicity of the D75-F formulation and the other formulations. Water hardness can alter the toxicity of the Phos-Chek formulations. The toxicity of Phos-Chek D75-F was increased in soft water compared to hard water (McDonald et al. 19965, Poulton et al. 1997). Water hardness (CaCO3) on National Forest System lands in Arizona range from 96–150 mg/L near the Coronado National Forest (USGS gauge on the Santa Cruz near Nogales) to 580–1,200 mg/L near the Kaibab National Forest (USGS gauge at Kanab Creek near Fredonia) (USGS 2008).

The most toxic portion of the long-term retardants like Phos-Chek is ammonia (McDonald et al. 1996). Un-ionized ammonia is more toxic to aquatic organisms than total ammonia (McDonald et al. 1996, Poulton et al. 1997). Nitrates and nitrites could contribute to the toxicity of long-term retardants, but did not appear to influence the toxicity of Phos-Chek D75-F to daphnids. McDonald et al. (1996) found that nitrate-nitrogen concentrations in the Phos-Chek toxicity tests were 75 to 160 times less than those reported to be toxic to freshwater invertebrates. Nitrite-nitrogen concentrations in a Phos-Chek D75-F toxicity study on crayfish were also 30 times less than the crayfish 96-hour LC50 (Gutzmer and Tomasso 1985).

EPA (1986) reported that macroinvertebrates are more tolerant to ammonia than fish. Also, toxicity to ammonia is species-specific for invertebrates. In their toxicity studies with Phos-Chek D75-F, McDonald et al. (1996)found that their un-ionized ammonia concentrations were lower than toxic concentrations reported in other studies. They believed that other constituents (such as some of the proprietary chemicals) contributed to the toxicity they observed.

Phos-Chek D75-F exposures to mayflies, stoneflies, trout, Daphnia, and fathead minnows indicated that mayflies and stoneflies were much less sensitive to Phos-Chek when compared to the trout (Poulton et al. 1997). Thisstudy was conducted using stream water in Nevada in both a mobile laboratory and an artificial channel to more accurately assess real-world conditions. Two in-stream exposures were also conducted. Macroinvertebrate species may respond to disturbance by allowing themselves to enter the water column and “drifting” away from the disturbance. In this study, instream drift response after exposure to Phos-Chek D75-F was measured on five invertebrate taxa. Taxa richness and total number of organisms in the drift was low during the 30 minutes prior to the exposures and increased during the 30 minute period of the dose (Poulton et al. 1997). Drift of Ephemeroptera, Plecoptera, and Trichoptera during the first Phos-Chek D75-F exposure period returned to zero at the lower dose but did notreturn to zero in the second exposure at the higher dose (Poulton et al. 1997). Given these results and the unknown toxicity of the other 7 Phos-Chek formulations, adverse effects are likely to result from 660 mg/L Phos-Chek D75-F in stream systems (Poulton et al. 1997). This dose was comparable to the concentration expected from a surface run-off event. The rate of Phos-Chek degradation in-stream was accelerated in areas with elevated organic matter (Poulton et al. 1997). Half-life for long-term fire retardants in-stream was 14 to 22 days. In the instream test, nitrates were elevated after Phos-Chek D75-F exposure when compared with controls, but not above toxic concentrations and ammonia concentrations were not elevated (Poulton et al. 1997). Overall, Poulton et al. (1997) determined that Phos-Chek D75-F is not highly mobile. Mollusks and Crustaceans Response to Retardant Toxicity

There are no data specific to mollusks and crustaceans; however, assumptions regarding gill absorption ofammonia for fish would also apply to freshwater mollusk and crustacean species (Cole 2011). Unionized ammonia caneasily cross the gill membranes of fish and presumably mussel and crustacean gills as well. A primary function ofthe gills is to rid the body of waste material in the form of ammonia. If enough un-ionized ammonida is in the surrounding

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water, ammonia will diffuse into the organism, creating a build up of ammonia. Ammonia buildup can occur to such as extent that it becomes lethal to the organism. The early life stages of freshwater mussels are sensitive to ammonia exposure (Cole 2011). Sub-lethal Effects on Aquatic Species

The use of lethality endpoints without consideration of potential sub-lethal effects from even short-term or transient exposures fails to acknowledge that sub-lethal and indirect effects on osmoregulation, gamete development, or other endpoints can play an essential role in ensuring the survival and recovery of listed species. The Forest Service is currently working with the USGS on a study to determine the effects of those sub-lethal effects. The Forest Service will adjust its retardant use practices as needed based on the outcomes of the studies.

The hardest to measure, and potentially most significant effects of fire retardant misapplication could be sub-lethal impacts to fish and the duration of the impacts to critical habitat. We expect that the extent of the sub-lethal impacts will extend downstream much farther than the 6.2 miles (the distance shown where lethal impacts could occur), due to the fact that ammonia concentrations below lethal limits will persist beyond the extent of lethal concentrations. The distance and extent of sub-lethal effects from elevated ammonia levels is not known, but may extend for some distance downstream and is an area of research that should be analyzed in the future. Laboratory studies show that rainbow trout exposed to NH3 levels over 0.1 mg/l they developed skin, eye, and gill damage. Other reactions to sub-lethal levels of ammonia are reduced hatching success; reduced growth rate; impaired morphological development; injury to gill tissue, liver, and kidneys; and the development of hyperplasia. Hyperplasia in fingerling salmonids can result from exposure of ammonia levels as low as 0.002 mg/l for 6 weeks (Wells et al. 2004). Considering research in California (Norris et al. 1978) that showed detectable levels of ammonia for an entire year following retardant introduction, it is possible that hyperplasia could be a concern for listed salmonids. The presence of ammonia in the water can also lead to suppression of normal ammonia excretion and a buildup of ammonia on the gills. Fire retardants may also inhibit the upstream movement of spawning salmon (Wells et al. 2004). Ecological Considerations for Retardant Toxicity

Responses of organisms tested in controlled laboratory systems do not necessarily provide reasonable predictors of organisms’ responses to similar chemicals in the wild, although admittedly in many cases this is the only type of data available to us from which to conduct an evaluation. In many cases, the conditions simulated in a laboratory test have almost nothing to do with the environment in which most species live in the wild, and as such are unlikely to resemble “worst-case field conditions.” In laboratory tests, species are generally isolated from confounding factors so that researchers are able to isolate the species responses to the chemical (or stressor) under study. Lab studies do not replicate typical environmental conditions where intraspecific competition for food or shelter occurs. Instead, all the test organisms are about the same size, provided with abundant food, and minimal habitat complexity. Interspecific competition generally does not occur in lab tests either, as most lab environments isolate thespecies under study from typical predators. Physical conditions are maintained at optimal or constant levels (e.g., velocities, water temperature, and dissolved oxygen are not representative of fluctuating conditions in a natural aquatic environment, particularly during a wildfire) and generally, there are no other chemical stressors present.

While there has been a fair amount of research conducted in laboratory environments, the response of aquatic species to an accidental fire retardant drop in the natural environment with additional stressors, such as lowdissolved oxygen (DO), ash, hot water, and other conditions expected as the result of the nearby fire, has not been studied. Most aquatic species are particularly sensitive to elevated temperatures and are not very tolerant of water with low DO; because warm water holds less oxygen, encountering water with low DO is a distinct possibility during a

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wildfire. There have been several studies done on the interactive effects of ammonia and DO, all showing theLC50s of rainbow trout to fall dramatically when DO is low. Alabaster et al. (1983) showed that at 10 ppm DO, rainbow trout did not die until concentrations of un-ionized ammonia reached 0.2 mg/l, but when the DO fell to 3.5 ppm, the lethal concentration of un-ionized ammonia became only 0.08 mg/l. Thurston et al. (1981) showed that when DO dropped from 8.5 ppm to 5 ppm, rainbow trout became 30 percent less tolerant of ammonia.

Gresswell (1999) showed that smoke in the air is absorbed by water and increases the ammonia concentrations in rivers even without an accidental application of retardant. Crouch et al. (2006) showed that in burning watersheds, prior to treatment with retardants, there is increased ammonia, phosphorous, and total cyanide. Since there is a greater background level of ammonia during a fire, the ammonia levels created by an accidental drop may behigher than experienced in a controlled setting, and as the fire retardants are diluted, they may take longer to reach non-toxic levels. Wells et al. (2004) and Little et al. (2006) showed rainbow trout avoided concentrations of 1.3 mg/l (1 percent of LC50), which probably means that fish are likely to swim away from areas of high ammonia concentrations. Wicks et al. (2002) found that rainbow trout and coho salmon swimming through water with elevated ammonia levels experience reduced LC50s, declining from approximately 207 mg/l to 32 mg/l.

Ash and guar gum have both been identified as respiratory inhibitors in the water. Ash has been identified asthe cause of fish kills during wildfires and volcanic eruptions (Newcombe and Jensen 1996), while guargumisan ingredient in fire retardants and would further exacerbate the effects of increased ammonia concentrations. Little et al. (2006) showed spikes in the salinity, as a result of the ammonia salts contained in the aerially applied fire retardants, which would negatively affect all fish living in freshwater environments, even adults. Buhl and Hamilton (1998) stated, “these results indicate that although ammonia is a major toxic component in D75-F, other components in the formulation may have had a significant influence on the toxicity of D75-F to Chinook salmon" (p.1594).

Drift from an accidental retardant drop within the 300-foot buffer (but outside a waterway) is another issue. Several environmental factors such as wind speed and direction, amount of retardant dropped from the aircraft, topography, the type of waterway (pond or stream), and dilution should be considered when analyzing the level of toxicity in a waterway. Indirect Effects

Fire retardants have negative indirect impacts on many resources on which ESA-listed resources depend. Many rivers along the West Coast are nutrient-deficient, whereas many rivers along the East Coast are impaired byexcess nutrients according to EPA 303(d) water quality standards. The fire retardants are nitrogen-based, and when they hit the water and break down, the retardants eventually become nitrogenous nutrients. Eutrophication can be a significant problem in many slack water areas along the course of a river. In rivers with large agricultural orurban development, nutrients are usually already a water quality problem, without having more nutrients accidentally introduced. The most likely places that are affected by eutrophication and the biotic organisms that grow in poor water quality are reservoirs, estuaries, and bays. Eutrophication in those places impairs light penetration, submerged vegetation, and nursery habitat. The application of nutrients into these waters could lead to shifts in phytoplankton composition or provide a competitive advantage to organisms that are not naturally suited for the oligotrophic waters of the West Coast. The additional application of nutrients into rivers along the East Coast, as well as reservoirs and dams in the Pacific Northwest, could further degrade water quality and could also lead to eutrophication. Increased nutrients can also affect food resources, such as macroinvertebrate abundance and macroinvertebrate species composition, both in the area where the retardant hits and downstream all the way to the ocean.

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The influx of nutrients may also favor the spread of aquatic invasive species. Indirect effects on non-native aquatic invasive species from increased nitrogen and phosphorus from fire retardants could result in increases in density of non-native invasive species if present where retardant is applied; many of these species are good competitors and opportunistic. If non-native invasive species are not present in the areas where retardant is applied, yet are nearby, there is also the potential non-native invasive species establishment into the area as a result of disturbance. The potential for establishment into an area not presently occupied by non-native aquatic invasive species is complex and could be species-specific. Timing of Fire Seasons and Aquatic Life Stages

In general, the peak fire seasons by Forest Service region mirror the peak times for reproductive life history needs of aquatic species. Appendix C Table 4 is a complete list of retardant use, ecoregions and peak fire seasons. Table 3 'Peak Fire Seasons by Forest Service Region' specifically shows regions and peak fire seasons..

Table 3 Peak Fire Seasons by Forest Service Region

Region Peak Fire Season

01, Northern June-October

02, Rocky Mountain June-October

03, Southwestern May-July

04, Intermountain June-October

05, Pacific Southwest August-October

06, Pacific Northwest June-October

08, Southern September-July

09, Eastern April-October

10, Alaska June-September

Avoidance Area Mapping

Current mapping of buffers for waterways is intended to avoid waterways and effects on species by not allowing aerial application of fire retardant in those areas. When mapped, the acreage of waterways avoided is significant and expected to prevent the majority of misapplications and effects on listed aquatic species. See Appendix L for a discussion and two examples of avoidance area mapping. Effects of the Alternatives

The spatial extent of this analysis includes all National Forest System (NFS) lands and any additional areas adjacent to NFS lands that have known occurrences or potential habitats for threatened, endangered, or sensitive species. The temporal extent of this document is the next 10–20 years. This time frame encompasses the extent of time in which the fire retardant program would be implemented and the time frame of most forest units.

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Methodology for Effects Analysis

Environmental effects have been analyzed on a nationwide, programmatic scale and the information and estimates contained in this analysis are derived from the most accurate, readily available data. Additional step-down consultations with the U.S. Fish and Wildlife Service (FWS) and National Oceanic and Atmospheric Administration (NOAA) Fisheries at a regional and/or local scale to determine site-specific avoidance areas will be completed based on site conditions.

The occurrence of past fires and retardant drops provides a baseline for considering where retardant maybeused in the future. Quantifications are limited and are in general qualitative because the analysis is national inscopeand future fire retardant application sites are unknown. This effects analysis includes a description of thenatureof potential effects that could occur.

The following information was used to evaluate environmental consequences at a national scale:

Species occurrences; Critical habitat information and general habitat requirements; The following information sources were used to identify species to be considered: Current Forest Service lists of known and suspected occurrences of species occurring on or near NFS lands (Appendix E refers to each section on wildlife, fish, plants); Current Forest Service lists of designated critical habitats occurring on or near NFS lands (refer to each section on wildlife, fish, plants).

Species-specific information included: listing packages, recovery plans, critical habitat designations, range distribution, habitat, threats, five-year reviews, NatureServe, and any petitions, as available for each species. Historical Fire and Aerial Fire Retardant Application Data

Fire retardant drops by each National Forest over the past decade have been quantified and provide estimates of future retardant applications (Appendix C). Between 2,358 and 4,715 acres per year are estimated to be treated with aerial application of fire retardant nationwide. This equates to less than 0.0025 percent of NFS lands, withno single forest with more than 0.025 percent of land base applied annually with retardant. Misapplication Data Analysis

Even though the Forest Service does not intend to drop fire retardant in waterways, there have been instances where misapplications do occur. The agency has recorded those incidents, and the data for aquatic habitats are summarized in Table 4 'Recorded Misapplication Aerial Fire Retardant Drops in Aquatic Habitats or Buffer Areas'.

Table 4 Recorded Misapplication Aerial Fire Retardant Drops in Aquatic Habitats or Buffer Areas

Year Drops direct to Drops within 300-ft Total drops to Total drops Proportions of water buffer water and buffer all drops

2008 9 3 12

2009 9 2 11

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Year Drops direct to Drops within 300-ft Total drops to Total drops Proportions of water buffer water and buffer all drops

2010 14 5 19

Totals (3 yrs) 42 9,853 0.42

Based on the 3 years of misapplication data, a prediction of 0.42 percent chance of hitting water or the buffer, more than one retardant drop per year has a 0.1 percent probability of hitting water. Because each drop carries greater than a 0.01 percent chance of hitting water, we would be unable to identify any low-risk forests. This assumes that all drops will enter waterways and affect aquatic species. As discussed in the previous section, not all drops recorded are delivered to waterways.

There are a number of cases where fish mortality has been documented in recent years due to misapplication of fire retardant to streams so it is important to analyze the effects. Screening Process to Determine Potential Impacts

The number of federally listed and Forest Service sensitive species to be analyzed is very large. The national screens located in Appendix E and associated assumptions were developed and used to identify species that potentially could be affected by future retardant applications. Alternative 1—No Action

If mitigations are followed, no direct, indirect, or cumulative effects would occur to any federally listed species, designated critical habitats, or Forest Service-listed sensitive species because no retardant would be applied. However, without the use of retardant, the probability of a fire burning more acreage is also higher (Lund 2011). The effects of fire on aquatic species and their habitats, in particular, will depend on the intensity of thefire,prior watershed conditions, and ability of local fish communities to repopulate, which depends on life history patterns and overlapping generations.

The effects of wildland fire on aquatic systems can be immediate and direct (for example, fish mortality) aswell as long-term and indirect (for example, sedimentation). Fish deaths due to fire are associated with water temperatures heated to lethal levels (Neary et al. 2005) and with ash effluents, which can obstruct gill membranes causing asphyxiation (Little and Calfee 202). Local fish extirpations have occurred as a result of fire, particularly inareas where populations were isolated in small headwater stream (Dunham et al. 2003). Further studies suggest that other species (amphibians and macroinvertebrates) may not be significantly affected by fire (Pilliod et al. 2003, Rinne 1996, Smith 2000). Other studies show that there are no effects to fisheries as a result of fires. Alternative 2—Proposed Action Direct and Indirect Effects

Avoidance mapping as directed under the 2000 Guidelines for Aerial Delivery of Retardant will reduce direct or indirect effects as previously described in the general effects on fish and aquatic species section in known locations of federally listed species. However, the potential for retardant being applied to these species and critical habitat does exist from invoking of an exception (three for this alternative) or a misapplication of retardant.

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Forests that use more retardant are assumed to have a higher potential for a misapplication or invocation of an exception. Results of the screening process, which takes into account these potential future retardant applications, are displayed in Appendix E. Because of the assumptions that are described in the Methodology of Effects Analysis section above, the determinations are based on the retardant drops by forest, so there may be an adverse effect on a species on one national forest but not on another. These results will be verified at the individual forest level and may change between the draft EIS and the final EIS.

Indirectly, there is the chance of increased nutrients if there is the invocation of an exception (three exceptions under Alternative 2) or a misapplication. This may cause a concern especially on the coast, where many waters are already nutrient-rich. There is the risk of eutrophication in rivers on the East Coast and reservoirs in the Pacific Northwest. There may be a change is macroinvertebrate abundance and species composition, which are food resources for aquatic vertebrates. Additionally, the influx of nutrients may favor the influx of non-native aquatic invasive species and many of these species are good competitors and opportunistic. If non-native invasive species are not present in the areas where retardant is applied yet are nearby non-native invasive species may establish themselves into the area as a result of disturbance.

Sensitive species are not addressed under Alternative 2. However, the effects to sensitive species are likely to be similar to federally listed endangered and threatened species because of the 300-foot buffer for streams and other water bodies. There is potential for retardant being applied to these species, because of exception to the guidelines. There would be no additional avoidance area mapping for specific sensitive species under Alternative 2. Effects to sensitive species are displayed in Appendix F. As with federally listed species, the determinations are based on the retardant drops by national forest, so there may be an adverse affect to species on one forest but not on another. Between the draft and final EISs, each forest will conduct a local review of species for validation of effects,and information adjustments to determination statements may occur. Cumulative Effects

The cumulative impacts on federally listed aquatic vertebrates and invertebrates and associated designated critical habitats and Forest Service sensitive species resulting from the incremental impact of the action added to past, present, and reasonably foreseeable future actions are expected to be minor and short-term based on the following points:

Application of aerial fire retardant consists of a very small proportion of land base nationally. Avoidance area mapping protects species from direct and indirect effects, and impacts on species would only be expected in very rare cases where a misapplication of retardant occur or an exception is used; this incremental addition of a rare event combined with other actions that threaten species viability or critical habitats (loss of quality habitat, fish passage impediments, non-native invasive species, climate change) would be minimal. All other fire suppression tools (Federal and State) will continue to be used. Any activity that causesground disturbance, such as construction of fuel breaks, firelines, and road construction has the potential to affect fish and aquatic habitats, and in turn, the species. Although there is a risk of contamination and lethal/sub-lethal effects on fish and aquatic species from fire retardant entering waterways, the effects on these speciesmay be less compared to other ground-based activities, because less direct habitat degradation would occur. Fire retardant formulations will likely continue to be nitrogen- and phosphorus-based; therefore, similar effects are expected although concentrations of salts may change. Although localized effects may occur to specific

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species in specific areas, added effects from this project are expected to be minor (spatially and temporally) as a result of the small amount of ground affected annually (0.002 percent nationwide). Forest Service fire preparedness and suppression budgets are not likely to increase therefore similar firefighting tactics would remain the same and applied to similar types of environments. Alternative 3 Direct and Indirect Effects

Avoidance mapping will prevent direct or indirect effects previously described in the general effects on fish and aquatic species in known locations of federally listed species as a result of Alternative 3. However, the potential for retardant being applied to these species does exist from invoking the remaining exception (protection of life) or misapplication of retardant. Similar to assumptions in Alternative 2, forests that use more retardant are assumed to have a higher potential for a misapplication or invocation of an exception. Likewise, the indirect effects associated with increased nutrients (risks of euthrophication) and potential for non-native aquatic invasive species spread is present under Alternative 3. Therefore, effects on federally listed species and designated critical habitats would be the same as those identified in Alternative 2.

Forest Service sensitive species trending towards Federal listing would receive more protection via more avoidance mapping than 300-foot buffers compared to Alternative 2. However, the potential for misapplication or exception for retardant use may still have the potential for an effect. Effects on Forest Service sensitive species would be similar to those described in Alternative 2 (but less frequent) due to more protection. Cumulative Effects

Cumulative effects would be the same as those described in Alternative 2.

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Cultural Resources Affected Environment

The term, cultural resources, as used in this EIS, includes all resources referred to as cultural, historical, archaeological, ethnographic, and tribal sacred sites or traditional cultural properties. Cultural resources, which represent past human activities or contemporary uses, are considered irreplaceable and nonrenewable. Cultural resources represent important cultural values and are of special concern to tribal groups, the public, and specific ethnic groups.

As manager of almost 200 million acres of public land, the Forest Service is entrusted with the stewardship of a large share of the nation’s historical and cultural heritage. National forests contain many of the nation's best preserved heritage sites in some of the least disturbed natural settings, with more than 380,000 sites currently inventoried on National Forest System (NFS) lands. Conservative estimates of the number of archaeological and historic sites that may exist on Forest Service holdings range from 1.5 million to 2.0 million sites. The Forest Service currently has more than 3,300 formal listings on the National Register of Historic Places, at least 19 national historic landmarks, and 1 property identified as having potential for listing as a world heritage site. A comprehensive arrayoflaws, executive orders, Federal regulations, and Forest Service policy and direction provides the basis for the protection of cultural resources.

Cultural resources on National Forest System lands are protected by an array of laws, regulations, and executive orders. The following list highlights selected key provisions; see the Cultural Resources Specialist Report in the project record for a full list of relevant protections and regulations.

National Historic Preservation Act of 1966 (NHPA) (16 U.S.C. 470). Directs all Federal agencies to take into account effects of their undertakings (actions, financial support, and authorizations) on properties included in or eligible for the National Register. Native American Graves Protection and Repatriation Act of 1990 (NAGPRA), (25 U.S.C. 3001). Provides a process for Federal agencies to return certain Native American cultural items to lineal descendants and culturally affiliated Indian tribes and Native Hawaiian organizations, with penalties for non-compliance and illegal trafficking. Food, Conservation, and Energy Act of 2008 provides for the reburial of Native American human remains on National Forest System lands, and the closure of National Forest System lands for the privacy of tribal groups engaged in traditional and cultural practices, and provides for the non-disclosure of information about reburial locations as well as traditional and cultural practices. Executive Order 13007–Indian Sacred Sites, issued May 24, 1996. Directs Federal land management agencies to avoid affecting the physical integrity of Indian sacred sites wherever possible. Executive Order 13175–Consultation and Coordination with Indian Tribal Governments, issued November 6, 2000. Directs Federal agencies to establish regular and meaningful consultation and collaboration with tribal officials in the development of Federal policies that have tribal implications. Environmental Consequences

As a general rule, any activity that causes ground disturbance (disturbance to the soil matrix containing the cultural resource) has the potential to adversely affect cultural resources, both directly and indirectly. Ground disturbance may cause changes to the physical attributes of the resource that, in turn, compromise the integrity of the cultural

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resource and its context. Its context (the spatial relationship between the various artifacts, features, and components of the cultural resource) is what is scientifically studied and interpreted and is the basis for determining thesite significance. This effect of ground disturbance is irreparable and considered adverse under the National Historic Preservation Act (U.S. Congress 1966). Even a scientific archaeological excavation has an adverse effect because the integrity and context of the cultural resource are destroyed by removing the artifacts, features, and components.

In the case of sacred sites, effects that are not so easily defined must also be considered. Tribal religious practitioners may hold beliefs that are difficult to reconcile with our usual consideration of effects. The aerial application offire retardant may have no long-term consequences for the salient features of a sacred site, but may have a serious impact on the perceived integrity of the place. Tribal practitioners must be consulted on a case-by-case basis to determine the nature of site and the impacts on both tangible and intangible properties of the site. Alternative 1—No Action

Under the no-action alternative, there would be no aerial application of fire retardant, and therefore, no effects on cultural resources from aerial application of fire retardant.

There is potential for some wildfires to become larger if aerial fire retardant is no longer available (seeWildland Fire Management section in this EIS). Without the ability to reduce wildfire intensities and rates of spread in support of fire suppression forces, the possibility of some cultural resource being burned over would likely increase. High-intensity fires can destroy historic wooden structures and can damage artifacts such as pottery, bone,glass, and stone structures through exposure to intense heat. However, to say how many or what cultural resource sites might be lost without the availability of fire retardant would be highly speculative. Alternative 2—Proposed Action

The aerial application of fire retardants may affect cultural resources. The effects would vary according to thenature and age of the properties. Retardants, including the various chemicals contained in retardants, react in different ways to different materials or types of cultural resources. Cultural resources consist of many materials including, but are not limited to, wood, stone, bone, shell, ceramics, glass, and plants. A comprehensive discussion of how retardant chemicals can react with each of the mentioned materials is contained in the Cultural Resource Specialist Report, available in the project record. What follows is a summary of potential effects to various cultural resources from retardant: Deterioration

Long-term retardants contain fertilizer salts (ammonium phosphate or ammonium sulfate) that can leave a residue when dry. These salts can attract water and can cause the surface that they are in contact with, to swell and contract. Soluble salts crystallize as water evaporates, causing a great increase in volume. When crystallization occurs within a porous material such as wood, bone, shell, or some ceramics, it can cause physical damage, such as the spalling of the object’s surface, resulting in the loss of any detail present (Society for Historic Archaeology n.d.). Additionally, rapid temperature changes caused by application of retardant to hot rocks may cause spalling of stone and degradation of mortar.

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Staining

Retardants containing iron oxide have a high potential for staining raw wood, stone, bone, ceramics, shell, and vegetation. Any applied decoration, pigment ,or other applications (scoring, etching) will be similarly affected. Retardant applications may have very different effects on painted surfaces. In some cases it easily washes off and in others it does not. Materials are a critical consideration—sandstone will absorb the retardant and the ferric oxide will bond to the stone, making removal very difficult. Less porous materials, such as slate, may be more easily cleaned. In the case of rock art, especially pictographs, applied pigment designs may be irreversibly altered. The use of fugitive colorants will minimize these effects. Protein Residues

Aerial retardant applications may present particular problems for the analysis of protein residues on bone and shell tools, ceramics, and ground stone surfaces. Recent analyses indicate that protein residues may survive exposure to high temperatures, but ammonia compounds will cause deterioration of the residues. Discussion

As previously discussed, the physical attributes and spatial relationship among various artifacts constitute a site’s physical context. In the case of sacred sites and some traditional cultural properties, the socio-cultural setting must also be considered. The study of this context contributes to the determination of a sacred site’s significance to a group of tribal practitioners. Aerially applied fire retardant does not disturb the ground, and therefore doesnot affect the spatial relationships between and among artifacts in the physical context of a cultural resource.

The artifacts themselves, including residues from past uses, may be adversely affected by the application of fire retardants. Scientific studies and site interpretations can account for a known site contaminant, such as fireretardant, and provide a legal and regulatory basis for determining site significance regardless of cultural affinity. The significance of a sacred site is primarily established in a belief system that may or may not recognize theaerial application of fire retardant as an impact to the integrity of the site. Only consultation with practitioners candetermine the severity of impacts on sacred sites.

Heritage specialists with local area knowledge are assigned to each large fire incident to ensure compliance with historic preservation laws and local land and resource management plans and fire management plans and to provide incident commanders with information, analysis, and advice on various areas including archeological, historic, and traditional cultural resources, as well as sacred sites and other areas or resources that may be of local concern (National Interagency Fire Center 2007a; National Wildlife Coordinating Group 2004). These resource advisors assist incident commanders in weighing potentially adverse effects of aerial application of fire retardant against potential damage from managing a wildfire without retardant. Cumulative Effects

Given the protection afforded by Federal law, regulation, and executive order, there are no other past, present, or reasonably foreseeable future actions that would contribute cumulatively to the effects of fire retardant on cultural resources.

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Alternative 3

The effects described in under Alternative 2 are equally applicable under Alternative 3. However, Alternative 3 requires assistance from tribes and cultural resource specialists prior to aerial application of fire retardant. The assistance and consideration of effects should create a management context and actions that will not adversely affect the integrity or data potential of any cultural resources.

Alternative 3 addresses the potential for misapplication and directs incident commanders to consult on the effects of a misapplication on cultural resources. It is expected that consultation should result in recommendations for actions to resolve or mitigate any adverse effects. However, the impacts on sacred sites may be irresolvable. Lacking resolution or any agreeable mitigation, the misapplication may result in perceived loss of integrity and, consequently, an irretrievable loss of the resource.

In the event that a misapplication occurs, or that other resource considerations require an application that affects cultural resources, then the effects must be the subject of consultation with tribes and state historic preservation offices (SHPOs) depending on the nature of the affected site. Alternative 3 provides direction for the development of a plan for long-term monitoring in the event that it is determined to be necessary during consultation. Monitoring will allow for data collection and better understanding of effects on a variety of resources.

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Hydrology Introduction

This section addresses the conditions of water resources and riparian areas within National Forest System lands and the effects of using aerial fire retardant on these areas under the alternatives.

Elk find a safety zone in the East Fork, Bitterroot River, Montana Photo by John McColgan, August 2000.

Affected Environment

The affected environment is limited to national forests and grasslands, approximately 193 million acres, and adjacent lands downstream. Of primary importance for analysis is the 39 percent of the land base in Forest Service regions 1–9 that lies within 300 feet of a stream and the 4.4 percent that lies within 300 feet of other water features. This is a total of 43.4 percent of the land base in Regions 1–9.

While most long-term fire retardant is used in the Western United States, all Forest Service regions except Region 10 (Alaska) have used fire retardant in the past 11 years. Puerto Rico is part of Region 8 and has not usedfire retardant in the past 11 years. Surface Water

There are approximately 277,006 miles of perennial stream and 640,843 miles of intermittent or ephemeral streams on National Forest System land in regions 1-9 (Table 5 'Miles of Stream and Acres Within 300 Feet of Streams, by Region. Source: Forest Service GIS'). Because no retardant was used from 2000 through 2010 in Alaska or Puerto Rico, they are not included in the tables below.

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Table 5 Miles of Stream and Acres Within 300 Feet of Streams, by Region. Source: Forest Service GIS

Forest Acres within 300 Acres within 300 Percent land base Service Perennial Intermittent and Total miles of feet of perennial feet of any stream within a 300 foot Region (miles) ephemeral (miles) stream stream type stream buffer

1 41,680 55,820 97,500 3,031,266 7,090,919 28

2 29,258 128,715 157,973 2,127,847 11,488,961 52

3 6,881 82,381 89,262 500,450 6,491,813 31

4 41,782 74,120 115,902 3,038,684 8,429,242 26

5 30,097 127,581 157,678 2,188,882 11,467,525 57

6 55,172 91,487 146,660 4,012,536 10,666,148 43

8 44,467 52,125 96,592 3,233,943 7,024,837 53

9 27,669 28,612 56,281 2,012,306 4,093,197 34

Totals 277,006 640,843 917,849 20,145,913 66,752,642 39

Surface water resources include rivers, streams, lakes, ponds, reservoirs, wetlands, and other water features identified in Table 6 'Lakes, Wetlands, and Other Water Features. Source: Forest Service GIS' There are 2,236,702 acres of reservoirs, ponds, and lakes. Most of the lakes, ponds, and wetlands are in Forest Service Regions 8 and 9. Region 3 to the southwest has the fewest lakes, wetlands, and other water features.

Table 6 Lakes, Wetlands, and Other Water Features. Source: Forest Service GIS

Wetlands Area within (Swamp, 300 foot buffer Region Estuary Ice Mass Lake/Pond Playa Reservoir Marsh) Total Acres

1 0 6,949 210,724 4 62 33,495 251,233 616,398

2 0 12,292 114,855 461 2,546 27,274 157,428 765,023

3 0 0 49,907 550 1,404 6,838 58,698 257,483

4 0 4,824 174,423 1,624 3,435 34,615 218,922 693,646

5 0 6,381 220,617 2,876 303 17,267 247,444 545,126

6 133 48,618 171,876 49 82 44,119 264,877 633,446

8 0 0 408,947 3 823 592,967 1,002,739 2,087,621

9 0 0 873,242 15 3,461 533,012 1,409,729 2,894,462

Totals 133 79,065 2,224,590 5,584 12,114 1,289,585 3,611,072 8,493,203

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Groundwater

Groundwater is found as unconfined shallow aquifers and as deeper aquifers with a confining layer above. Groundwater within shallow unconsolidated sediments is more susceptible to contamination, due to more connection with surface water. Groundwater resources under National Forest System lands have not been assessed at a national or regional scale (Sedell et al. 2000). However, it can be assumed that National Forest System lands act as recharge areas for aquifers, some used for drinking or irrigation water. Municipal Watersheds and Source Water Protection Areas

A municipal supply watershed is one that serves a public water system as defined in Public Law 93-523 (Safe Drinking Water Act) or as defined in State safe drinking water regulations. The 1996 Safe Drinking WaterAct amendments require the identification and management of source water protection areas for public water systems. States are required to develop source water assessments for public drinking water supplies including both surface and groundwater sources. These watersheds are usually in rural settings and do not involve industrial contaminant sources.

Overall 18 percent of the nation’s water supply comes from land managed by the Forest Service. In the Western United States more than half the water originates on National Forest System land (Furniss et al. 2010, Brown et al. 2008). The water from forested land is generally of higher quality than water from urban or agricultural lands (Furniss et al. 2010, Sedell et al. 2000, Brown et al. 2008). An estimated 3,400 public drinking water systems are located in watersheds containing National Forest System lands (USDA Forest Service 2000, Brown et al. 2008). In addition to public water systems, private residences sometimes use springs and streams on or adjacent to National Forest System land for domestic water supplies. Water Quality

Water quality standards are established to protect beneficial uses of a State's waters. Beneficial uses are assigned by each State for water quality. A general definition for water meeting beneficial uses is water that is drinkable, swimmable, and fishable.

Beneficial uses include:

domestic water supply fishing industrial water supply boating irrigation water contact recreation livestock watering aesthetic quality.

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Water Quality Impairment

The top five reasons for water quality impairment on national forests are, in descending order of importance: high temperatures, excessive sediment loads, habitat modification, excessive mercury content, and excessive metal loads (Carlson 2009, Kimball and Brown 2009).

Streams on Forest Service-managed land tend to have good water quality compared to streams in agricultural areas or urban areas; nitrogen and phosphorus are not common pollutants of National Forest System land.

Streams draining agricultural lands in the United States average about nine times greater concentrations of nitrate and phosphate than streams draining forested areas (Binkley et al. 1999). The major contaminants in these areas are from livestock and fertilizers. The concentration of nitrate (N), which is particularly important for water quality, average 0.23 (mg N)/l which is the same as parts per million) for very large forested watersheds in the United States, compared with 3.2 (mg N)/l for streams in large agricultural watersheds (Omernik 1976).

Forest streams typically contain 8 to 12 mg/l of oxygen (Brown and Binkley 1994). High loading of organic matter and nutrients (such as nitrogen or phosphorus), combined with sediment and increased water temperature, can deplete dissolved oxygen particularly in small streams (Ringler and Hall 1975). Nitrogen and phosphorus are the primary causes of eutrophication and resulting algal blooms. Chronic symptoms of over enrichment include low dissolved oxygen, fish kills, cloudy murky water, and depletion of desirable flora andfauna.

The EPA has set a maximum concentration of 10 mg/l for nitrates and 1 mg/l for nitrites for public drinking water systems (US EPA 2010). No maximum concentrations for drinking water have been set for the other ingredients in retardant.

Nutrient concentrations in streams in agricultural areas are directly related to land use and associated fertilizer applications and human and animal wastes in upstream watersheds. Total nitrogen concentrations were higher in agricultural streams than in streams draining urban, mixed land use, or undeveloped areas, with a median concentration of about 4 mg/L—about 6 times greater than background concentrations (Dubrovsky 2010).

Total phosphorus concentrations were also highest in streams in agricultural and urban areas, with a median concentration of about 0.25 mg/L—about 6 times greater than background concentrations (Dubrovsky 2010).

Susceptibility of aquifers to contamination relates to geology, depth to groundwater, infiltration rates, and solubility of contaminants. The shallow unconfined aquifers are at greater risk from surface contamination due torapid infiltration from the surface to the water table. Groundwater-residence times can range from days to tensofthousands of years or more.

A nationwide study by the U.S. Geological Service found that contaminants occur most frequently in shallow groundwater in agricultural and urban areas (Dubrovsky et al. 2010, Dubrovsky and Hamilton 2010). This study found that 7 percent of the private wells surveyed were contaminated with nitrogen; approximately 3 percent of public systems were contaminated. The lower levels for public systems were in part due to greater depths of wells, longer travel times, and locations with fewer nutrient sources (Dubrovsky et al. 2010, Dubrovsky and Hamilton 2010). Other nutrients in groundwater were not higher than background levels. Groundwater typically is not vulnerable to contamination by nutrients, such as phosphorus, that attach to soils (Dubrovsky et al. 2010).

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Fire Retardant Drops Affecting Water

Forty-two drops have occurred into water or the 300-foot buffer within the past 3 years (Table 7 'Intrusions Into Water or Buffers, by Region'). Of these, 32 were at least partially into water and 10 were within the 300-foot buffer required for waterways under the 2000 Guidelines, but did not directly hit a stream or other water body. The majority of the intrusions were accidental, but the five exceptions were all in Forest Service Region 5 (California). Regions 4, 5, and 6 have documented the majority of intrusions into water (see Table 7 'Intrusions Into Water or Buffers, by Region'). There are 42 reported intrusions into water or the buffer within the past 3 years. Using an 11-year average of 3,286 drops per year, approximately 0.4 percent of the retardant drops affect water or the area within the 300-foot buffer.

Table 7 Intrusions Into Water or Buffers, by Region

Year Region Drops Accidental Exceptions Water Buffer only

R42008 3 3 3

R5 3 2 1 1 2

R6 6 6 5 1

2008 Total 12 11 1 9 3

R42009 2 2 2

R5 5 3 2 4 1

R6 4 4 3 1

2009 Total 11 9 2 9 2

R32010 2 2 2

R4 8 8 8

R5 5 3 2 2 3

R6 4 4 2 2

2010 Total 19 17 2 14 5

Grand Total 42 37 5 32 10

Desired Condition

The desired condition is for all water bodies to be able to meet their State-defined beneficial uses. National primary drinking water regulations (NPDWRs or primary standards) (Table 8 'National Primary Drinking Water Standards') are legally enforceable standards that apply to public water systems. Primary standards protect public health by limiting the levels of contaminants in drinking water. Nitrate standards are set primarily for the protection of infants (US EPA 2010).

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Table 8 National Primary Drinking Water Standards

Contaminant MCLG1 MCL or TT1

(mg/L)2 (mg/L)2

Nitrate 10 10

Nitrite 1 1

Phosphorus No national freshwater standard 1 N/A

1. These standards are dependent on State regulations.

National secondary drinking water regulations (NSDWRs or secondary standards) are non-enforceable guidelines regulating contaminants that may cause cosmetic effects (such as skin or tooth discoloration) or aesthetic effects (such as taste, odor, or color) in drinking water. EPA recommends secondary standards to water systems but does not require systems to comply. However, States may choose to adopt them as enforceable standards. EPA water quality recommendations for ammonia for freshwater organisms depend on pH, temperature, and life-stage (US EPA 2009).

The presence of phosphorus in drinking water is not considered a human health hazard, and no Federal drinking water quality standards are established for phosphorus. Nevertheless, phosphorus can affect the water’s color and odor and indicate the presence of other organic pollution. Furthermore, because phosphorus can accelerate the growth of algae and aquatic vegetation, it contributes to the eutrophication and associated deterioration of municipal water supplies (Dissmeyer 2000). Environmental Consequences Methodology

Environmental effects have been analyzed on a nationwide, programmatic scale. The analysis is based on a review of current literature for the effects of fire retardants on water resources and the fire retardant risk assessments. Additional information on the Forest Service present use of retardants was provided by the Forest Service Fire and Aviation program and Forest Service GIS specialists. Incomplete and Unavailable Information

As aerial drops of fire retardants occur when and where wildfires occur, the exact placement and number ofdrops depends on fires and cannot be known ahead of time. Information on fires and fire retardant use was collectedfrom 2000 through 2010 and used as baseline data for the existing condition. Information on intrusions into water was limited to 2008–2010 because more complete information was collected for these years compared to earlier data.

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Spatial and Temporal Context for Effects Analysis

The potentially affected environment (and analysis area) is limited to Forest Service land for direct and indirect effects, approximately 193 million acres. The area of most interest for direct and indirect effects occur where aerial use of fire retardant is applied to water or the 300-foot avoidance buffer required for waterways underthe2000 Guidance.

Impacts from the surrounding land and downstream land is also considered for cumulative effects, which can occur where retardant affects water over a large area in conjunction with other effects or where multiple intrusions into water occurs within the same area over several years’ time. The temporal time frame would be the next 10 to 15 years of the life of this document. General Effects of Fire Retardant on Water Resources

A primary issue for this analysis is the potential for fire retardant to enter streams and impact water quality for domestic water sources and aquatic species. Surface and groundwaters on and adjacent to National Forest System lands are susceptible to contamination from aerially applied fire retardant through direct application (either mishaps or by decision), spill, drift, leaching, and runoff (containing both eroded soil and water); see Routes for Fire Retardant to Impact Water section below for more details. The likelihood and significance of this contamination is influenced by wind, riparian vegetation, type of stream, pH of water, soils, rainfall, fires in the area, and fire behavior.

Commonly used long-term retardants are mixtures of diammonium sulphate, diammonium phosphate, monoammonium phosphate, gum thickeners, iron oxide coloring agent, and preservatives. Long-term fire retardants are typically fertilizer salts that are mixed with water to ensure uniform dispersal. Even after the water has evaporated, the retardant remains effective until removed by rain or erosion. They form a combustion barrier after the evaporation of the water carrier. Their effectiveness depends on the amount of retardant per unit surface area, further varying depending on type of vegetation the retardant is applied to and fire behavior. The ammonium salts chemically combine with cellulose as the fuels are heated, effectively removing the fuel (Hamilton et al. 1998). The active ingredients of the fire retardant break down into nutrients of phosphorus and nitrogen. Routes for Fire Retardant to Impact Water

The routes for aerial fire retardant to get into water include: direct application (either by misapplication orby decision or spills during transport), drift, runoff during storm events, and leaching through soils. Each of these methods will be discussed below. Direct Application

Fire retardant can directly affect water from application to water from either misapplication or from the decision to apply to streams under an exception under the 2000 Guidelines. Spills into water during transport can also occur. The effects of retardant on water quality depend on the size of the stream or water body, the amount of fire retardant that directly get into the water, and how quickly dilution occurs. The application of retardant perpendicular to and across a stream gets less retardant in the stream than an application directly along the stream channel.

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Several characteristics of the application site determine the initial concentration of retardant in the stream. Narrow, deep streams have a much lower initial concentration (therefore a shorter mortality zone for aquatic species) than shallow, wide streams, assuming equivalent flow properties (Norris and Webb 1989). Streams with dense overstory vegetation are less affected by retardant because the vegetation intercepts much of the retardant (Norris et al. 1978). Where less overstory vegetation exists, more retardant gets directly in the water.

Tests using 1,000 gallons of fire retardant applied across four streams occurred in Idaho, Oregon, and California.

A result showed no immediate increase in NH3 concentrations where retardant was applied parallel to the stream

(Norris et al. 1978). Results directly into water showed maximum concentrations of NH3 (un-ionized ammonia) ranging from 0.02 to 0.32 mg/l, approximately 150 feet downstream from the application point at time intervals between 2 and 22 minutes after application (Norris et al. 1978). This is under the 10 mg/l drinking water standards.

Time to dilution to 1 percent of maximum concentration, at 150 feet downstream, ranged from 10 minutes to almost 4 hours. Sampling over all the sites at various time intervals from 10 minutes to 4 hours after application showed a reduction in concentration from 4 to 29 percent at 650 feet downstream of the application points, and 1 to 3 percent at 2,600 feet downstream. The differences in concentrations were due to factors of velocity and mixing turbulence of the stream flows. Some retardant settled on the stream bottom and acted as a continuous source of nitrogenand phosphorus until the nutrients went into solution and were diluted and carried downstream.

The chemical form of ammonia in water consists of two species, the more abundant of which is the ammonium ion + (NH4 ) and the less abundant of which is NH3; the ratio of these species in a given aqueous solution depends on both pH and temperature. In this study the principal chemical species in the stream the first 24 hours after application + were ammonia nitrogen as the gas, NH3, and the cation NH4 and total phosphorus. Un-ionized ammonia (NH3) is + of primary importance because of its potential toxic effects on aquatic species. The amount of NH3 relative to NH4 is dependent primarily on pH of the water (Trussel 1972). As the pH increases, the proportion of ammonia nitrogen present as NH3 increases.

The principal chemical compounds immediately after direct stream application were ammonium nitrogen and total - phosphorus. However, in all cases, the principal remaining compounds after 24 hours were nitrate (NO3 ) and soluble nitrogen, both transformation products of ammonium polyphosphates and with very low toxicity (Norris et al. 1991). Soluble nitrogen and phosphorus are readily taken up by aquatic plants and are of primary interest for nutrient enrichment and possible eutrophication. Soluble nitrogen in stream water following severe wildfire has been shown to be as high as 35 times as comparable and adjacent unburned watersheds (Tiedemann et al. 1978), probably as a result of increased nitrification and reduced uptake from burned vegetation.

- The phosphorus can contribute to downstream eutrophication. After 24 hours, nitrate (NO3 ) and soluble organic nitrogen are the primary retardant components in the stream. These are transformation products of the diammonium phosphate in the retardant mixture (Norris and Webb 1989).

In the past 11 years, three spills into water or riparian areas have been reported, one on National Forest System land. In 2002 on a fire (in Oregon but not on National Forest System land), four bags of retardant fell offatruck and one-and-a-half bags of concentrate mixed into the creek water before containment occurred. In 2005, there was a spill while mixing retardant. In 2010, there was an accident on BLM-administered land where a plane experiencing mechanical problems jettisoned a full load (3,000 gallons) over a dry vernal pool.

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Spills during transportation both on the ground and in aerial accidents have occurred in the past and will continue to occur. A transportation and handling plan is required for moving and using fire retardant. This plan addresses spill prevention and containment. Special precaution must be taken to contain potential spills while air tankers operate on the ground. Retardant loading pits must have containment and treatment systems to handle leaks, spills, and/or wash down water used to wash aircraft that may contain metals from the aircraft, fuel, hydraulic fluid, and oils (NWCG National Wildfire Coordinating Group 2007). As of 2011, liquid bulk tankers will be sealed to prevent leaks or spills (Transportation and Emergency Response Procedures, ICL Performance LP). Drift

How much fire retardant drifts depends on the height of the drop, speed of the drop, and wind direction andspeed. Fire retardants generally include a gum thickening agent to raise the viscosity to between 100 cps and 1800 cps to reduce drift (USDA Forest Service 2005). These products create larger and more cohesive droplets that are less apt to break into small particles that are more apt to drift. Fire retardant mixtures containing clay have particles in the range of 2–3 mm where guar gum-thickened retardant solutions have particles that vary between approximately 3.5 mm and 5 mm depending on the type of gum in the mixture (Gimenez et al. 2004). This is a much larger droplet size compared to micrometer range for aerially applied herbicides, and less suseptible to drift than the micrometer droplets found for aerially applied herbicide.

Generally fire retardant is used at low wind speeds for more precise placement of the retardant. However, drops are allowed in winds up to 30 mph (Fireline Handbook). With higher wind there is more potential for drift of the fire retardant. Runoff and Leaching

Runoff and leaching both occur from precipitation events after application. Run-off is when overland flow occurs carrying water and soils directly to water bodies. Leaching is where water moves through soil, dissolving and removing minerals. After 1,000 gallons of mixed fire retardant were applied parallel to and within 3 meters ofa stream in Oregon, there was no immediate increase in NH3 concentrations where retardant was applied parallel to the stream (Norris et al. 1978). During a year of monitoring after application of the retardant to ground near the stream, soluble nitrogen forms and phosphorus levels in stream water were similar to the un-treated, control watersheds (Norris et al. 1978, 1991).

Post-fire water quality monitoring for streams near four wildfires showed that application of fire retardantnear streams but not into the stream had minimal effects on surface water quality (Crouch et al. 2006). Ammonia and phosphorus were found in streams in burned areas where retardant was not used from burning of wood and other organics, at concentrations similar to those found in areas where retardant was applied due to direct effects from the fire.

The potential for nitrogen leaching is higher in coarse-textured soils with less clay and organic matter to bind the fertilizer (Napper 2011). These soils are also more prone to erosion. In more fine-textured soils, clays and organic matter tend to bind the fertilizer. Leaching of phosphorus from areas without vegetation is higher than where vegetation is available to uptake the nutrient (Pappa et al. 2006).

In soil, nitrogen is converted by microbial processes to forms used by plants (Norris et al. 1978). Some of the nitrogen stays in a form that is typically volatilized and lost to the atmosphere.

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Phosphorus is tightly bound to soil particles and is unlikely to accumulate in water bodies in a significant amount unless there is a rapid rate of soil erosion (Norris et al. 1978). Soils with high clay content strongly attract phosphorus. Erosion of soils (particularly fine soils) could carry phosphorus to water on soil particles. Once it reaches waterit is quickly taken up by aquatic organisms, especially algae (Neary et al. 2005). Polyphosphates are readily soluble in soil water and sequester minerals. In soils, polyphosphates promote vegetative growth by steady hydrolysis, conversion to and spread as orthophosphates, which are taken up by plants.

Runoff of phosphorus from areas applied with retardant is usually in very low concentrations (Labat-Anderson, Inc. 1996), so low in fact that if the limiting nutrient in a water body is phosphorus, which is typical in the Western United States, the risk for eutrophication of streams is very small. In the less likely event that nitrogen is the limiting factor, then an accidental drop or run-off from treated ground may cause an increase in aquatic plant biomass.

Dilution by flow or tributary inflow is generally less effective in lakes. Dilution is partially a function oflakesize, but dilution could be rapid in small lakes with large water-contributing areas. Decreases in fertilizer concentration in lakes, ponds, and other lentic (still) water bodies are a function of chemical and biological degradation processes. The primary pathways fire retardant to enter lakes and other water bodies would be from direct application, drift, or runoff.

Where fire retardant was applied at different rates to constructed seasonal wetlands during the dry season,water quality was degraded for at least 2 years afterward (Angeler and Moreno 2006). The changes in water quality included higher nutrient content, higher electroconductivity, higher turbidity, lower oxygen, and changes to the pH (Angeler and Moreno 2006). The nutrient surplus increased phytoplankton growth, causing lower oxygen levels and higher turbidity found with eutrophication. This environment was similar to the Mediterranean environment of southern California. Changes to water quality were greatest with the highest contamination rates.

While contamination of groundwater by fertilizers is well-studied, effects of fire retardant on groundwater have not been studied because of the comparatively small amount of aerially applied fire retardant used per year and scattered nature of application. From fertilizer studies it is known that shallow groundwater with coarse overlying sediments and low amounts of vegetative matter is most likely to become contaminated. Much of the shallow groundwater would be associated with riparian areas along streams and would be within the 300-foot buffer. Losing reaches of streams act as recharge areas for shallow groundwater. There is potential for some contamination of groundwater from these areas where intrusions occurred. Alternative 1—No Action Direct and Indirect Effects

Because there would be no aerial use of fire retardant, there would be no pathways for aerial fire retardant toimpact water quality. The 2000 Guidelines, avoidance mapping, and monitoring would not be needed. Other firefighting methods would continue to be used.

Presently, 98 percent of fires are kept under 300 acres and 98 percent of retardant used is in initial attack situations on smaller fires. An indirect effect of no aerial use of fire retardant would occur in areas with pooraccessfor firefighters. Without aerial fire retardant to slow the growth of more isolated fires, potential exists formorefires to grow larger before firefighters can safely fight the fires (Henderson and Lund 2011). With more large firesthere

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is more potential for impacts on water quality from fires. The most adverse effects of fires on water quality include increased suspended sediment and turbidity, increased water temperature, and increased nutrients (Landsberg and Tiedemann 2000). Alternative 2—Proposed Action Direct and Indirect Effects

The effect from use of aerial fire retardant on water resources would be similar to that discussed under thesection General Effects of Fire Retardant on Water Resources above. The potential for measurable effects from leaching of fire retardant from outside the 300-foot buffer on surface water is low as discussed above.

Intrusions (either misapplication or by decision) of aerial fire retardant into water are the most likely causeof detrimental effects.

More than 43 percent of the land base would be mapped within the 300-foot buffer protective buffer of water. In the past 3 years, 42 reported intrusions of fire retardant into water or the buffer have occurred. Using an 11-year average of 3,286 drops per year, approximately 0.4 percent of the retardant drops affect water or the area within the 300-foot buffer. It is expected that under this alternative, a similar number of accidents would occur. All listed exceptions to the 2000 Guidelines could still occur under this alternative. In the past 3 years there have been five exceptions that affected water or the area within the 300-foot buffer, out of 42 intrusions into the buffers, which is about 12 percent of the intrusions that affected water. Under this alternative a similar number of exceptions would be expected to occur, primarily in Forest Service Region 5.

If an accident should occur where retardant contaminates a smaller stream, there is a high likelihood of the accident negatively affecting water quality in the short-term. Effects on streams are short-term because dilution occurs as the retardant moves downstream. Contamination of larger streams would be diluted more quickly because of the larger flow.

Application outside the buffer is unlikely to have a measurable impact on stream water quality (Crouch et al. 2006). Intrusions into the buffer but at least 3 m from water are unlikely to have a high impact on water because of uptake by vegetation and adherence of phosphorus to soils (Norris et al. 1978). Areas that are steep and have coarse-textured soils and little vegetation have more potential for movement of fire retardant to water (Napper 2011).

Where retardant is dropped on vernal pools or other small water bodies, there is likely to be negative effects on water quality for at least 2 years because of the lack of flow to dilute the retardant, as occurs in streams (Angeler and Moreno 2006); eutrophication would likely occur. Larger lakes are less likely to have negative effects because dilutions of the contamination would occur more quickly owing to the larger volume of water. Soils that are poorly drained and have high organic carbon content tend to favor denitrification of nitrate to nitrogen gases, soless nitrogen is available to move into water (Dubrovsky 2010). Wetland soils have these characteristics, as do many of the soils in the southern United States.

All waterways are mapped as avoidance areas. Public water supplies protected by source water protection areas tend to be on larger streams and water bodies. These are easier for pilots to see and avoid than the small streams that are more frequently documented in intrusion reports. If an intrusion should occur, it is likely that dilution would quickly bring water quality back to EPA drinking water standards.

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Much of the shallow groundwater recharge areas would be protected by the 300-foot buffer on surface water. The groundwater that has been contaminated with agricultural fertilizers is in areas that have repeated treatments of large areas of land (millions of acres). In contrast, the Forest Service uses retardant on an average of between 2,000 and 5,000 acres a year, scattered across the country. Given that the amounts of nitrogen and phosphorus used in fire retardant are very small compared to agricultural use and are scattered across the landscape, and thatspatial application changes year to year, the likelihood of any aquifer being contaminated is low. Risk by Region

Forest Service Regions 3, 4, 5, and 6 all have more than 10 percent of the fires occurring on NFS land and useat least 10 percent of the fire retardant (Table 9 'Fires and Retardant Use by Forest Service Region, 2000–2010', Figure 2 'Comparison of Percent of Fires Versus Percent Retardant Drops by Region.').

Figure 2 Comparison of Percent of Fires Versus Percent Retardant Drops by Region.

These regions would all be considered higher risk for intrusions due to the number of fires and the amount of retardant used in the past 11 years. All except Region 1 have had documented intrusions within the past 3 years. Regions 2 and 8 would be considered lower risk as they have 7–11 percent of the fires but use 3-4 percent of the retardant. Region 9 has approximately 6 percent of the fires but uses less than 1 percent of the fire retardant and would also be considered low risk.

Region 10 consists of two national forests—the Chugach and Tongass—that are considered coastal rain forests. Lightning is an uncommon occurrence in these forests, and when it does occur it is usually accompanied by rain. Region 10 has not used fire retardant on National Forest System land in the past 11 years so there would beextremely low risk for an intrusion into water from national forest use of fire retardant.

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Table 9 Fires and Retardant Use by Forest Service Region, 2000–2010

Forest Service Number of # Retardant Total Gallons Average # Average % of Total % Retardant Region Fires Drops 2000-2010 Retardant gallons/yr Fires used by each 2000-2010 2000-2010 (11yrs) Drops per region (11yrs) year

01 10,703 4,082 10,203,789 371 927,617 11 11.3

02 6,591 1,101 2,753,524 100 250,320 7.1 3.0

03 18,597 7,550 18,875,476 686 1,715,952 20.0 20.9

04 10,234 4,197 10,493,664 382 953,969 11.0 11.6

05 15,884 11,266 28,165,743 1,024 2,560,522 17.0 31.2

06 14,834 6,165 15,411,352 560 1,401,032 15.9 17.1

08 10,165 1,487 3,716,469 135 337,861 10.9 4.1

09 5,835 300 749,790 27 68,163 6.3 0.8

10 359 0 00 - 0.4 0.0

Totals 93,202 36,148 90,369,807 3,286 8,215,437 100.0 100.0

Alternative 3 Direct and Indirect Effects

The impacts of this alternative are similar to Alternative 2 but the likelihood of accidental contact of the aerial fire retardant and water would be somewhat lower due to the standardized mapping of water resources, where water resources are identified to fire personnel before the need for use of fire retardant occurs. The exception forprotection of property would not be used under this alternative and decision to anchor to a waterway would not occur except when human life was threatened. There have been five exceptions that affected water in the past 3 years, allin Region 5. This is out of a total of 13 intrusions in this region; therefore, approximately 38 percent of the intrusions in Region 5 were exceptions. This number would likely be smaller under this alternative as there are fewer exceptions under the 2011 Guidelines. Overall, 12 percent of the intrusions into water or the 300-foot buffers were exceptions. Because of the changes in exceptions, it is likely that there would be fewer intrusions under this alternative, particularly in Region 5. Risk by Region

Risk by region would be the same as discussed under Alternative 2 above. Cumulative Effects

The following activities may contribute to cumulative effects on water:

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Use of fertilizers on private timberland and agricultural lands, Other State and Federal agencies applying aerial fire retardant, and Effects of fire on nutrient availability to streams.

Other fire suppression tools would continue to be used. Although other fire suppression activities, such asfireline construction, are associated with fires and fire suppression, the relevant actions to cumulative effects arefocused on aerially applied retardant only. These include the areas and quantities of retardant use. Alternative 1

As there are no direct or indirect effects from arial use of fire retardant, there are no cumulative effects. Changes in fire behavior or acres burned under this alternative are too speculative at this point to include incumulative effects. Alternative 2

Cumulative effects are unlikely under Alternative 2 because of (1) mapped avoidance area protecting waterways from direct and indirect effects, and (2) the small amount of area affected by retardant each year, spread widely across the United States. Cumulative effects are unlikely but possible under certain scenarios. Fire can add to local nutrient levels, and these nutrients can affect streams or lakes. Where fire retardant has affected a stream andfire has increased available nitrogen and phosphorus by burning vegetations, there is potential for cumulative effects from nutrients to streams from both pathways. For streams this effect is likely to be short-term because of the movement of the nutrients down stream and the dilution occurring downstream. For an area with small ponds and lakes without large inflows, eutrophication could occur. The effects of fire and retardant could cause eutrophication lasting several years.

Fertilization is uncommon on National Forest System land and unlikely to add to nutrients in areas where fire retardant has been used. However, the private forest industry can and often does use fertilizers within the same watersheds. In addition, fire and fire retardant can be used on other ownerships in the same watershed andatthe same time as retardant is used on National Forest System land. Cumulative effects are unlikely but theoretically possible where accidental intrusions into water occur under these scenarios. As discussed earlier, water quality analysis on a national scale has shown that forested areas tend to have lower nutrient levels and better water quality than other lands (Dubrovsky and Hamilton 2010, Dubrovsky et al. 2010). As fire retardant would continue to occur at the same levels, this scenario is likely to continue. Alternative 3

Cumulative impacts are similar to those discussed Alternative 2.

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Summary of Effects

Impacts by alternative are shown in Table 10 'Comparison of Potential Impacts, by Alternative':

Table 10 Comparison of Potential Impacts, by Alternative

Effect Indicator Alternative 1 Alternative 2 Alternative 3

Contamination of water Potential for accidental None Low due to avoidance Low due to avoidance with fire retardant from application of fire retardant mapping of all mapping of all accidental drop into water waterways waterways

Exceptions contaminating Potential for exceptions None Slightly higher than Lower due to fewer water Alt. 3 due to more exceptions (1) exceptions (3)

Contamination of drinking Potential for drinking water None Low due to avoidance Slightly lower than water from fire retardant contamination from fire mapping of all alternative 2 due to retardant waterways but higher fewer exceptions (1) than Alt. 3 due to more exceptions (3)

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Plant Species Introduction

This section focuses on the effects of aerially applied fire retardant on plants and plant communities, including noxious and non-native invasive plants. The first part analyzes the effects on federally listed threatened, endangered, proposed, and candidate species, associated designated critical habitats, and Forest Service sensitive plant species (collectively, TEPCS). The second part evaluates impacts associated with aerial retardant application and non-native invasive plant species (NNIS). Because of the national scale of effects associated with these alternatives, most are general and qualitative in nature.

The preliminary analyses and results presented represent preliminary biological findings of the Forest Service. The U.S. Fish and Wildlife Service will review these biological findings for those species protected under the ESA. All determinations made in this analysis should be considered preliminary and subject to change between the issuance of the draft and final EIS. Additional peer review by species specialists is also anticipated.

Sidalcea pedata, pedate checker-mallow. Federally listed plant. Photo by Scott Eliason, USDA Forest Service.

Allium munzii, Munz’s onion. Federally listed endangered plant. Photo by Mark W. Skinner USDA

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Affected Environment: Federally Listed Threatened, Endangered, Proposed, Candidate, and Forest Service Sensitive Plant (TEPCS) Species

Aerially applied fire retardant on National Forest System (NFS) lands can occur on various types of vegetation including, but not limited to, annual and perennial grasslands, conifer forests, summer and fall hardwood forests, sagebrush with grass, intermediate brush, southern rough vegetation, and mixed chaparral areas. As a result of these various types of diverse areas, numerous federally listed and forest service sensitive plant species occur in these areas. Plant species considered within this analysis include grasses, forbs, shrubs, mosses, lichens, and other species that occur in numerous types of habitats across NFS lands. Of these species, 171 federally listed plant species, including 2 federally proposed plant species, 24 designated critical habitats, 2,719 Forest Service listed sensitive plant species, and 7 Federal candidate species may have the potential to be impacted. Environmental Consequences: Federally Listed Threatened, Endangered, Proposed, Candidate, and Forest Service Sensitive Plant Species

Fire retardant is composed of ammonium sulphate or ammonium phosphate salts, thickeners, dyes and corrosion inhibitors, which adhere to vegetation and other surfaces, making it effective in reducing the advance of a fire. The retardant slurry acts as a barrier in front of a fire, and, as the fire burns into the areas coated with retardant, thesalts are converted to sulphuric and phosphoric acids with the release of sulphur dioxide, ammonia, and nitrogen oxides. This reaction suppresses the flaming combustion of fuels (Chandler et al. 1983). If aerially applied retardant isused as a method of control, the vegetation and soils in the area may be burned to some extent in some cases, and in other cases vegetation and ground may be covered with retardant and unburned. Please refer to fire section within this DEIS for a complete discussion of retardant use tactics, retardant presently approved for use on Forest Service lands, and effectiveness of retardant use.

Effects on individual plant species or plant communities depend upon various factors, including species characteristics (habitats, physiological and morphological characteristics), soil types, timing of application (active growing season vs. dormant season), and what happens to the retardant after application. Figure 3 'Fate of Aerially Applied Fire Retardant.' shows the fate of aerially applied retardant; no ground activities such as trampling are considered in this effects analysis.

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Figure 3 Fate of Aerially Applied Fire Retardant.

General Effects of Fire Retardant on Plants and Plant Communities

Very little is known about the effect of retardant on plants and their associated plant communities. Most studies evaluating impacts are short-term (2 to 3 years) and represent only a few ecosystems and plant species and communities. Results of these studies indicate that there is the potential for phytotoxic effects to species that may be more sensitive to retardant or occur in an environment that is more susceptible to an impact. Additionally, some studies report changes to plant diversity, including increases in NNIS associated with the fertilizing effect of retardants. Reported effects to plants and their associated plant communities in these studies imply nitrogen and phosphorus components within retardant contribute to effects; no direct or indirect effects to plants or plant communities have been associated with the other constituents of retardants (xanthan thickeners, guar gums, fugitive colorants, attapulgus clay, iron oxide, or performance additives). The studies summarized below provide the best available science and the basis for the effects analysis for the alternatives. Phytotoxicity

In a California foothill annual non-native grassland wildfire, native legumes were shown to decrease in abundance for 2 years after the application of Phos-Check XA fire retardant (Larson and Duncan 1982). Phos-Check XA contains the highest levels of nitrogen and phosphorus and is no longer used by the Forest Service (Johnson 2011). Although the exact amount of retardant applied in this study is unclear, most of the currently used retardants have lower amounts of nitrogen, except for PC259 retardant, which is only used in helicopter delivery systems that consistently are more accurate in the placement of retardant.

Widespread short-term effects (leaf death in tree, shrub, and ground cover species) have been reported in an Australian eucalyptus forest (Bradstock et al. 1987). In this study, the retardant mixture contained ammonium sulfate and an organic polysaccharide. Leaf death occurred within a week after treatment and continued for many

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months in both overstory and understory species. While the overstory recovered rapidly, decreased cover in many understory species persisted at 1 year post application. The results of the associated greenhouse experiments reported in this study indicate that the ammonium sulfate component was the retardant ingredient responsible for foliar damage and that foliar washing did not minimize the adverse effects. Retardant PC-D75 is the only retardant that currently has ammonium sulfate within the formulation, and this retardant is being phased out and will not be used by the Forest Service in the future (Johnson 2010).

In another Australian study, shoot and whole plant death on individual plants were recorded on heathland plant species after experimental application of Phos-Check D75R (Bell 2003, Bell et al. 2005). Depending on the application rate (1.2 to 3.7 GPC), adverse effects to plant species varied. Little change in the visual estimates of percent foliar cover between treated and untreated areas and application of retardant to undisturbed heathland vegetation did not appear to significantly change species composition or projected foliage cover of the major life forms of native vegetation (herbs, mosses, grasses and sedges, woody shrubs).

No phytotoxic effects were observed in field studies examining effects of retardant (PhosCheck G75-F) inaNorth Dakota mixed-grass prairie (Larson and Newton 1996), or a in Great Basin shrub-steppe vegetation (Larson et al. 1999).

Monitoring the effects of retardant (Phoscheck P100) on a federally listed plant species on the San Bernardino National Forest in southern California indicate no foliar burn, phytotoxicity, or mortality to Eriogonum ovalifolium var. vineum (Cushenbury buckwheat) 4 months after application (Eliason 2010a). Critical habitat impacts including effects to primary constituent elements (PCEs) to this species and Lesquerella kingii subsp. Bernardina (San Bernardino Mountains bladderpod), not directly impacted by retardant application, are presently being monitored (Eliason 2010b). No impacts have yet been identified; however, ongoing monitoring will continue in the upcoming seasons to fully evaluate effects (Eliason 2010b).

Results of studies indicate that there is a possibility of phytotoxic effects to species that are more sensitive to retardant or to species that occur in an environment that is more susceptible to impacts. Literature also suggests little or no direct impact 1 to 2 years post retardant application on the species evaluated. It is expected that available propagule seedbank sources or other propagule sources nearby would provide long-term revegetation potential for commonly occurring species that might be impacted in the short term. Based on these results and the small percentage of land expected to have fire retardant applied to it annually (less than 0.025 percent by any individual forestand less than 0.0025 percent nationwide), direct impacts are expected to be minor and short-term. Vegetation Diversity

Retardants serve as a source of plant nutrients (specifically, nitrogen and phosphorus) in the soil whether applied directly to the ground as a retardant or deposited on the ground via rainfall or after being chemically altered during a fire. Individual and plant community responses from changes in nutrient availability are extremely complexand highly site specific. Additionally, changes in availability of nitrogen and phosphorus in the soil as a resultoffire itself may mask effects of retardant application (Napper 2011). The persistence of nitrogen and phosphorus from fire retardant applications and its availability to plants varies depending on retardant concentration and soilquality (Napper 2011). Plant available nitrogen was shown to be short-term (12 months), yet plant available phosphorus was found in the surface soil after 12 months (Hopmans and Bickford 2003). Persistence in the soil and related plant nutrient availability is variable and prediction of short- or long-term availability of nutrient in the soil and associated vegetation responses is highly site-specific. Please refer to Soils section of this EIS for a complete discussion of soil nutrients and retardants.

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Larson et al. (1999) suggest that the effects of ammonium-based retardants on plant and plant communities might be similar to the effects shown in fertilizer studies. If so, the impact to soil quality through the fertilizing effects of retardants could increase the vegetative response and change vegetative community composition. Increases in nutrient inputs might encourage the growth of some plant species, including NNIS, and give them a competitive advantage that would result in changes in community composition and species diversity (Tilman 1987, Wilson and Shay 1990, Bell 2003, Larson and Newton 1996).

The effects of Phos-Check D75 application on species diversity was evaluated in a North Dakota grassland community (Larson and Newton 1996) and in a shrub steppe area in the Great Basin in Nevada (Larson et al. 1999). Community characteristics, including species richness, evenness, diversity, and number of stems of woody and herbaceous plants were measured. The results of these studies indicate the following:

In a North Dakota prairie ecosystem, species richness was reduced in plots exposed to retardant whether the area was burned or unburned. All plots were dominated by the Kentucky bluegrass (Poa pratensis), which gained a competitive advantage from retardant application and crowded out other species.

In a Great Basin shrub steppe ecosystem, species richness declined the first year, but was undetectable after a year, and depression in species richness was most pronounced in the riparian corridors.

Overall, the vegetative community response from retardant was less than burning alone. Larson et al. (1999) suggest that even if fire retardant increases growth rates of non-native plants for a few post-fire years, the impactsmaybe detrimental, allowing more acres to burn unchecked. In both studies, the authors note that each study was short-term, and that results of the long-term ecological responses during several growing seasons are necessary to evaluate effects.

In another study, Phos-Check XA, a retardant no longer used by the Forest Service, applied to a California grassland produced almost twice the yield of forage in the first year after application in both burned and unburned areas, and growth continued into the second year after application in a retardant-treated unburned area (Larson and Duncan 1982). The increases in biomass or quality of forage could attract more herbivores and browsers to retardant application sites (Larson and Duncan 1982).

In 1997, aerially applied retardant (Phos-check D75) applied to the Mount Jumbo Fire near Missoula, MT resulted in increased density and biomass of annual plants including cheat grass (Bromus tectorum) and tumble mustard (Sisymbrium altissimum) (Calloway 2010). Bell et al. (2005) also recorded enhanced weed invasion in an Australian heathland ecosystem, particularly in areas receiving high concentrations of retardant (Phos-Check D75R).

The effect of nutrient additions in the form of fertilizer applications or nutrient additions to native plant communities and impacts on vegetation growth, diversity, and invasiveness by NNIS shows a potential for increase in dominance of NNIS and decrease in diversity of plant communities (Brooks 2003). Understanding and predicting this potential for invasion is complex and may be influenced by numerous factors, such as the number of propagules, the characteristics of the invading species, the susceptibility of the environment to invasion (Williamson and Fitter 1996, Williamson 1996, Lonsdale 1999), and various soil qualities (Napper 2010). For instance, Leishman and Thomson 2005 and Dassonville et al. 2008 show that invasive exotic species might be better competitors than other vegetative communities on nutrient poor sites that have received an increase in nutrients. Yet, Kalkhan et al. (2007) showed nutrient rich soils in Rocky Mountain National Park were more vulnerable to exotic species invasion than less fertile soils. In this study, nitrogen was positively linked to exotic plant species richness. In fertilizer studies conducted in Australia (Heddle and Specht 1975) on nutrient poor sandy soils, phosphorus fertilizer applied for 3

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years was retained in the ecosystem for at least 2 decades. Heedle and Specht also studied heath vegetation for more than 22 years and found change towards a herbaceous grassy area (sward) in response to application of phosphorus fertilizer.

These studies indicate a potential for increased vegetative growth and change in vegetative community composition through the addition of nitrogen and phosphorus, but the magnitude and direction of the change is strongly site-specific. From a broad-scale perspective, because the amount of retardant applied per forest, per region,or nationwide and associated potential for impact is small (less than 0.025 percent annually across National Forest System lands), potential impacts to or changes in plant diversity is expected to be minor from a spatial perspective. Because each forest implements forestwide and species-specific NNIS treatment strategies in combination with other NNIS treatments associated for larger fires, potential impacts from invisibility of NNIS would be expected to be short-term (3 to 15 years). However, these impacts do not preclude impacts to individual species, especially threatened and endangered plant species, designated critical habitat areas, sensitive species that trend towards listing, and plant species that are considered “narrow endemics.” Impacts to threatened and endangered species habitats by invasive species are one of the threats facing many species nationwide (Pimentel et al. 2005, Wilcove and Chen 1998). Treatment of NNIS and protection of federally listed species, associated critical habitats, and Forest Service sensitive species will continue on each forest as directed by national policy and regional and forest level direction (see Botany Report). Pollinators

No known studies exist specifically related to fire retardant impacts to specific plant pollinators. Please refertothe wildlife section for impacts to insects and other plant pollinators. Methodology

Environmental effects have been analyzed on a nationwide, programmatic scale, and the information and estimates contained in this analysis are derived from the most accurate, readily available data. Methodology used to determine effects include: Historical Fire and Aerial Fire Retardant Application Data

Fire retardant drops by each national forest over the past decade have been quantified and provide estimates of future retardant applications. Data are presented in Appendix C. Species Occurrences and General Habitat Requirements

Surveys and inventories for federally listed and U.S. Forest Service sensitive species have been conducted for many years by various individuals, organizations, and government agencies including but not limited to the Forest Service, U.S. Fish and Wildlife Service, universities, and State wildlife and natural resource agencies. Additionally, all Forest Service NEPA proposed projects require analysis of impacts to and in some cases monitoring of federally listed and regional forester's sensitive plant species.

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Components of the Alternatives Providing Plant Protection

1. Preseason coordination, training, reporting, and monitoring are required under Alternatives 2 and 3 (see Chapter 2 for full description of alternatives). 2. Avoidance areas (no retardant application areas) are established for TEPC and certain Forest Service sensitive species, including 300-foot protection buffers for all water bodies. Screening Process to Determine Potential Impacts

National screens (Appendix E) and assumptions were developed and used to identify species that potentially could be impacted from future retardant applications for use in formal consultation with U.S Fish and Wildlife Service for determining impacts associated with Alternative 3. Incomplete and Unavailable Information

Some individual forests may not have migrated their Forest Service sensitive plant species occurrences into the NRIS database; however, all regions actively use this system (Enstrom 2010, Hagland 2010). Although all individual occurrences may not be included in these geospatial databases, generalized effects to plant species and their habitats were used to make national level impact determinations. Spatial and Temporal Context for Effects

The spatial extent of this analysis includes all National Forest System lands and any additional areas adjacent to Forest Service-managed lands that have known occurrences or potential habitats for threatened, endangered, or sensitive species. The temporal extent of this document is the next 10 to 20 years. This time frame encompasses the extent of time in which this fire retardant program would be implemented, the time frame of most forest plans, and the time period in which aerially applied fire retardant could be expected to have an impact. Most studies associated with the effects of fire retardant to plants are 1 to 2 years in length, yet studies exist for similar chemicals applied to native vegetation for up to 22 years (fertilizer studies), therefore this temporal extent is very conservative. Connected Actions; Past, Present, and Foreseeable Activities Relevant to Cumulative Effects

The following activities may contribute to cumulative effects:

Past, present, and foreseeable activities, events, or threats other than application of fire retardant that may impact federally listed or Forest Service sensitive species viability or habitats (i.e., habitat destruction from land development, recreation activities, encroachment of NNIS, or climate change).

Forest Service, other Federal agencies, and State agencies implementing NNIS programs to reduce impacts from and control the spread of these species.

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Forest Service or other Federal or State agencies implementing conservation and protection measures in management or protection plans or other plans including plans for threatened and endangered plant species, Forest Service sensitive species, and other protected species or areas. Continued use of other fire suppression tools. Although other fire suppression activities, including ground-based activities such as fireline construction and road building, are associated with fires and fire suppression, the relevant actions to cumulative effects are focused on aerially applied retardant only. Alternative 1—No Action

No direct, indirect, or cumulative effects would occur to any federally listed species, designated critical habitats, or Forest Service listed sensitive species because no retardant would be applied. However, without the use of retardant, the probability of a fire burning more acreage is higher (Henderson and Lund 2011). Without the useof aerial retardant, there may be increased potential for some fires to be more intense, resulting in greater potential for severe environmental impacts such as localized soil sterilization, loss of native plants, and loss of viable soil seed banks in specific areas where these types of fires may occur. Significant literature is available relatedtofire effects to plant species and plant communities; the reader is referred to Wildland Fire in Ecosystems, Effects of Fire on Flora (USDA 2000). In general, many plant species require, tolerate, or are not affected by fire. In a classification of the effect of fire on the 186 Federally listed, proposed, and candidate plant speciesknownor suspected to occur on NFS land, only 2 percent of the species were identified to have adverse affects due tofire (USDA, no date). Similar effects would be anticipated on Forest Service sensitive plant species. Alternative 2—Proposed Action

Under this alternative, the Forest Service would continue aerial application of retardant under the 2000 Guidelines for Aerial Delivery of Retardant, with the adoption of the 2008 Reasonable and Prudent Alternatives (RPAs) as identified by the U.S. Fish and Wildlife Service and NOAA Fisheries (see Appendices A and B). Withrespectto impacts from NNIS and potential changes to plant community diversity or habitats related to individual TEPCS species, all national, regional, and forest level programs will continue to occur, as would the removal of all NNIS plant species if retardant application is found to be impact TEPCS species (RPA sub element 4, USFWS, 2008). This alternative allows three exceptions for retardant use in the guidelines (refer to Chapter 2, Alternatives). Although there are more exceptions allowing for retardant use associated with this alternative compared to Alternative 3, no supporting evidence concludes more retardant would be used with Alternative 2 compared to Alternative 3. Direct and Indirect Effects

The adoption of RPA sub element 1, of the 2008 RPAs (see Appendices A and B) will prevent direct or indirect effects, as previously described in the general effects to plants section, except for accidental drops or invoking of an exception on the 20 plant species and 14 designated critical habitats identified for protection (Appendix G). Remaining federally listed and Forest Service sensitive species would not receive retardant avoidance area designations and may be impacted if retardant is dropped on these individuals or populations. Although many forests apply minimal amounts of retardant to their landbases (Appendix C), it is difficult to predict fires or retardant use areas in the future, therefore, a conservative approach to effects analysis is used.

Of the 171 federally listed species impacts are expected to be the following:

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28 federally listed species would not be impacted because they either occur on forests that do not use retardant or occur in habitats where retardants would not be applied (Appendix G). All remaining 143 federally listed species would result in a likely to adversely affect determination based on a conservative approach that if a species is not protected with retardant avoidance areas the potential remains for an effect (phytotoxic or change in vegetation diversity as described above) because it is unknown where retardant may be used in the future. Additionally, for the 20 species identified for avoidance mapping, the potential for an accidental drop or invoking of an exception for retardant remains. These species could be impacted because they either occur on a forest that uses more retardant (0.01% or more of land base applied annually with retardant) and therefore, a greater potential for an accidental drop or invoking of an exception exists. Of the 24 designated critical habitats, 14 would receive avoidance mapping where retardant application would impact primary constituent elements. One misapplication in a designated critical plant habitat has been documented in the past three years (Division Fire, Appendix D). Of the estimated retardant drops nationwide (3,286 drops annually), the probability of occurrence is small and it is predicted these areas are adequately protected from effects and would not likely be adversely affected. One critical habitat would not be impacted because retardant would not impact primary constituent elements (Appendix G). Forest Service sensitive species that occur in the 300-foot water body avoidance areas would be protected from direct and indirect effects unless a misapplication or invoking of an exception would occur. Upland sensitive species occurring on forest land outside the 300-foot water body avoidance area may result in some phytotoxic impacts or vegetation diversity changes similar to those described previously in this section. Effects would likely be species-specific and may depend on other environmental factors such as timing andrateof application, climatic factors, and other site-specific factors. All Forest Service-listed sensitive species and candidate species considered for Federal listing (2,719 species, see Botany Report for complete listing of species) are determined to have a may impact but not likely trend toward listing (MIIH).

These determinations may change as further reviews of species are completed at the local levels and changes to impact calls may occur between the issuance of the draft and the final EIS. Cumulative Effects

The cumulative impacts on federally listed plants, associated designated critical habitats, and Forest Service sensitive species resulting from the incremental impact of the action added to past, present, and reasonably foreseeable future actions are expected to be minor and short-term based on the following points:

Application of aerial fire retardant consists of a very small proportion of land base nationally.

Fire retardant avoidance area mapping for identified federally listed species would protect species from direct and indirect effects, and impacts to species would be expected only in very rare cases where a misapplication of retardant occurs or an exception is used. Remaining species could experience some impacts if retardant would be applied to these species or habitats in the future. Because the amount of retardant is applied to any one forest annually (with an average drop of 50 to 75 ft wide by up to 800 ft long and estimated acres of retardant applied per forest ranging between 367 acres to 1 acre of land or between 0.000002% to 0.025% land base receiving retardant) is small in comparison to the analysis area, this incremental addition combined with other actions that threaten species viability or critical habitats (for example, habitat destruction from land development, recreation, encroachment of NNIS, or climate change) would be minimal.

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All other Federal and State firefighting agencies will continue to use retardant under the 2000 Guidelines. Although quantitative data is not available to predict quantities of retardant that may be applied, it is assumed that similar percentages of land base would be affected (0.002 percent land base affected annually).

All other Federal and State fire suppression tools will continue to be used. Any activity that causes ground disturbance, such as construction of fuel breaks, firelines, road construction, or trampling, has the potential to increase NNIS establishment (Brooks 2008). Although there is an increased nutrient input with fire retardant application, the potential for invasive species establishment and spread may be less compared to other ground-based activities because less ground would be disturbed.

Fire retardant formulations will likely continue to be nitrogen and phosphorus based, therefore similar effects are expected although concentrations of salts may change. Although localized effects may occur to specific species in specific areas, added effects from this project are expected to be minor (spatially and temporally) as a resultofthe small amount of ground impacted annually (0.002 percent nationwide).

Forest Service fire preparedness and suppression budgets are not likely to increase, therefore firefighting tactics would remain similar to those of the past and would be applied to similar types of environments.

Non-native invasive species programs and treatment strategies will continue on each individual forest. Programs and treatment strategies may vary in the future from existing programs. It is expected that these programs would be more comprehensive, include early detection and rapid response strategies, and thus be more successful in the treatment and eradication of invasive species in the future. Alternative 3 Direct and Indirect Effects

Avoidance mapping will designate no-retardant-use areas, preventing direct or indirect effects previously described in the general effects to plants section to known occurrences federally listed species, identified designated critical habitat, or Forest Service sensitive species identified at the local level requiring extra protection. However, the potential for direct and indirect effects from aerially applied retardant dropped onto these plant species does exist from invoking an exception, the misapplication of retardant, or a retardant drop on an undocumented individual or population. Because it is impossible to predict undocumented locations of threatened, endangered, proposed, candidate, or Forest Service sensitive (TEPCS) species, even if forests have mapped potential habitat, worst case scenarios for effects analysis are considered.

Of the 171 federally listed species analyzed for impacts and based on fire retardant use by individual forest the following impacts and reasons for impacts include:

28 federally listed species would not have any direct or indirect effects because they either occur on forests that do not use retardant or occur in habitats where retardants would not be applied (Appendix G). 81 species would not likely to be adversely affected (NLAA), and 62 species would likely be adversely affected (LAA) because all species will receive avoidance mapping as needed to ensure no direct or indirect effects. The amount of retardant use per forest and species specific habitat conditions were considered to determine the differences in effects from accidental drops or invoking of exceptions. Please refer to Appendix E for the screening methods and assumptions for determination calls and Appendix G for individual species determinations and habitats.

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Of the 24 designated critical habitats identified, 23 would receive avoidance mapping where retardant application would impact primary constituent elements. One misapplication in a designated critical plant habitat has been documented in the past three years (Division Fire, Appendix D). Of the estimated retardant drops nationwide (3,286 drops annually), the probability of occurrence is small; it is predicted that these areas are adequately protected from effects and would not likely be adversely affected. One critical habitat would not be impacted because retardant would not impact primary constituent elements (Appendix G). Forest Service sensitive species that occur in the 300-foot water body buffer areas would not be affected by aerially applied retardant unless a misapplication or invoking of an exception occurs; however, upland sensitive species occurring on forest land outside the 300-foot water body avoidance area and not receiving avoidance area mapping may result in some phytotoxic impacts or vegetation diversity changes similar to those described previously in this section. Effects would likely be species-specific and may depend on other environmental factors such as timing and rate of application, climatic factors, and other site-specific factors. Because avoidance areas have not yet been identified at the time of this draft EIS, all Forest Service-listed sensitive species and candidate species considered for Federal listing (2,719 species, see Botany Report for complete listing of species) are determined to have a may impact but not likely trend toward listing (MIIH). Changes to these determinations may change between the draft and final EIS as additional information becomes available. Cumulative Effects

Cumulative effects would be the same as those described in Alternative 2 except that more federally listed and Forest Service listed sensitive species would be protected due to retardant avoidance mapping. All other conditions remain the same. Affected Environment: Noxious and Non-Native Invasive Plant Species

The affected environment analysis areas and general impacts on plants and vegetation apply to this analysis and discussion; please refer to these sections in the TEPCS section of this document.

An estimated 3.5 million acres of National Forest System lands are infested with invasive weeds, according to the 2000 Resources Planning Act (RPA) assessment, which summarized local estimates from individual national forests (USDA Forest Service 2001). Current estimates of infested acres at the forest level vary (Enstrom 2010, Hagland 2010); present estimates indicate approximately 753 non-native invasive species infest 2.0 million acres on 106 national forests (NRIS 2010). Some species of particular concern to Forest Service managers are leafy spurge, knapweeds, starthistles, saltcedar, non-indigenous thistles, purple loosestrife, and cheatgrass in the West, and garlic mustard, kudzu, Japanese knotweed, tree-of-heaven, purple loosestrife, and hydrilla in the East (Mitchell 2000).

Noxious weeds and non-native invasive plant species (NNIS) are currently damaging biological diversity and ecosystem integrity of lands within and outside national forests nationwide. Invasive plants create a host of adverse environmental effects, including: displacement of native plants; reduction in habitat and forage for wildlife and livestock; loss of threatened, endangered, and sensitive species; increased soil erosion and reduced water quality; reduced soil productivity; and changes in the intensity and frequency of fires (USDA 2005). These species spread beyond National Forest System lands to neighboring areas, affecting all land ownerships.

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The Forest Service Chief has recognized the threat that invasive species pose to forest health, the economy, and the mission of the Forest Service. An estimated 3.4–3.5 million acres of National Forest System lands are infested with invasive weeds (816 species), according to the 2000 Renewable Resources Planning Act Assessment, which summarized local estimates from individual national forests (USDA Forest Service 2001) and current geospatial datasets (NRIS October 2010). For a complete discussion of noxious weeds and NNIS as well as Forest Service policies related to management, see the botany resource report, available in the project record.

Fire is a process integral to the function of most temperate wildland ecosystems and lightning-caused and anthropogenic fires have influenced the vegetation of North America profoundly for millennia (Brown andSmith 2000, Pyne 1982). In some cases, fire has been used to manipulate the species composition and structure of ecosystems to meet management objectives, including control of NNIS (DiTomaso et al. 2006, Keeley 2001). Yet, under some conditions, fire can increase abundance of non-native invasive plants (Goodwin et al. 2002), which may subsequently alter fire behavior and fire regimes, sometimes creating new, self sustaining invasive plant/fire cycles (Brooks et al. 2004). These altered fire regimes in and of themselves can reduce native species diversity and alter ecosystem functions. Therefore, in some instances, differentiating the impacts from retardant application and fire itself can be difficult. Environmental Consequences: Noxious and Non-Native Invasive Plant Species

As a general overview, disturbance from wildfire, modifies ecosystem processes and favors early successional plant species (Vitousek et al. 1996). Because of their aggressive nature, many non-native invasive plants exploit the initial decreases in competition (Harrod and Reichard 2001) and the flush of nutrients after fire (Certini 2005), essentially out-competing many native early-seral plants. Given these conditions and other activities associated with fire suppression, including ground-disturbing actions, this effects analysis focuses on those areas wherefire retardant would be applied and only briefly summarizes effects of these other actions related to potential increases in NNIS. Methodology

Because of the national scope of this document, qualitative effects are presented. The following information is used to provide a baseline to analyze effects: phytotoxic effects to individual plants and impacts to vegetation diversity as discussed in the previous section; historical fire and retardant application over the past 10 years; and estimated area of future retardant application (Appendix C).

The the spatial extent of this analysis includes all National Forest System lands (193 million acres) and the temporal extent of this analysis is the next 5 to 20 years, which allots time for non-native invasive species controls to be effective at a forest scale. It is expected that fire retardants application and product constituents will remain similar to those analyzed in this document during this timeframe. Alternative 1—No Action

There would be no direct, indirect, or cumulative effects to native plant communities from the establishment or increased spread of invasive species as a result of fire retardant application because no retardant would be applied. However, without the use of retardant, the probability of a fire becoming burning more acres is also higher (Henderson and Lund 2011). Some studies indicate that conditions following wildland fire favor non-native over native plants

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for some non-native species in some plant communities under some conditions (Zouhar et al. 2008). Post fire invasions can be intense and lead to severe impacts on native plant communities. Therefore, given certain site specific conditions, there is the potential for non-native invasive species to increase with this alternative. Fora complete review of NNIS and fire please refer to USDA 2008 – General Technical Report RMRS-GTR-42-volume 6. Alternative 2—Proposed Action Direct and Indirect Effects

Indirect effects from increased nitrogen and phosphorus from fire retardants may increase density of non-native invasive species and reduce diversity where retardant is applied. Many of these NNIS species are good competitors and opportunistic. Increases in densities of non-native species may also attract more herbivores to these areas as a result of increased forage thus providing additional potential for spread of NNIS from redistribution of propagules into other non-infested areas. Strips of retardant application may additionally provide a pathway for NNIS to establish into non-infested areas given favorable climatic and site-specific conditions.

Most studies conducted on retardant effects to plant communities were short term (1–3 years) and indicate minor short-term effects noting that longer-term studies may be necessary to fully understand or evaluate effects. One longer term study, evaluating effects of phosphorus fertilizer treatment on nutrient deficient sandy soils in Australia, reported potential for changes in plant community diversity after 22 years. These results may indicate that changes to plant diversity within the application zone of retardant may occur under certain circumstances under specific environmental or climatic conditions. Sufficient data does not exist to definitively predict a short- or long-term effect at this programmatic level of analysis. It is important to note however, that, national, regional and forest level NNIS programs as well as those associated with fire to control and eradicate NNIS would continue to be implemented at the local level. Changes in nitrogen and phosphorus inputs into bogs, grasslands, and freshwater wetlands have been shown to promote the invasion of non-native plants (Tomassen et al. 2004, Green and Galatowitsch 2002). The 300-foot buffer (no retardant application) for all waterways would reduce potential for retardant (nitrogen and phosphorus) entering water bodies (see the hydrology section of this EIS, or Thornton 2011). In most cases, except for the use of retardant in an exception for use, this would eliminate impacts on aquatic plant diversity in these areas from invasions of NNIS species.

The spatial extent of potential impact from increases in NNIS from the fertilizing effect from aerially applied retardant swaths depends on presence or proximity of non-native invasive species to retardant application site, the area (size) of application, and the post-application non-native invasive treatment. Aerially applied retardant is typically applied in swaths across the landscape (50–100 feet wide by up to 800 feet long per drop). At the scale of this analysis (193 million acres) and the unknown future application sites of aerially applied retardant, it is only reasonable to conclude that there may be the potential for an increase of NNIS under certain site-specific conditions. It could, however, be hypothesized that the potential effect may be increased in areas where NNIS are more prevalent such as urban interface areas, near roads, or other disturbed areas where NNIS occur compared to more remote areas of NFS lands.

As a result of other NNIS treatment strategies that are ongoing at the local level and the fact that retardant is applied annually to only 0.002 percent of the total National Forest System landbase (2,358 to 4,715 acres annually), the estimated impacted areas are quite small in comparison to other activities that occur across NFS lands (such as recreation, fuel treatments, logging, grazing, and fire).

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Cumulative Effects

The following are assumptions underlying activities that would contribute to cumulative effects: all other fire suppression tools will continue to be used; and all other policies and direction associated with control and treatment of invasive species nationally and locally will continue. The impacts to NNIS and associated changes in vegetation diversity resulting from the incremental impact of the action added to past, present, and reasonably foreseeable future actions are expected to be minor based on the following points:

All other Federal and State fire fighting agencies will continue to use retardant under 2000 Guidelines. Although quantitative data are not available to predict quantities of retardant applied, it is assumed that similar percentages of land base would be affected (0.002 percent of the land base affected annually). All other Federal and State fire suppression tools will continue to be used. Any activity that causes ground disturbance—such as construction of fuel breaks, firelines, road construction, or trampling—has the potential to increase NNIS establishment (Brooks 2008). Although there is an increased nutrient input with fire retardant application, the potential for invasive species establishment and spread may be less compared to other ground-based activities because less ground would be disturbed. Fire retardant formulations will likely continue to be nitrogen- and phosphorus-based; therefore similar affects are expected although concentrations of salts may change. Forest Service fire preparedness and suppression budgets are not likely to increase; therefore, firefighting tactics would remain similar to those of the past and would be applied to similar types of environments. Non-native invasive species programs and treatment strategies will continue on each individual forest. Programs and treatment strategies may vary in the future from existing programs. It is expected that these programs would be more comprehensive, include early detection and rapid response strategies, and thus be more successful in the treatment and eradication of invasive species in the future. Alternative 3 Direct and Indirect Effects

Indirect effects would be similar to those described in Alternative 2. Alternative 3 would reduce the amount of retardant in areas designated as avoidance areas for federally listed and certain forest-identified sensitive species. This additional reduction of areas where retardant could be applied would reduce impacts to individual species as previously described. There is, however, no conclusive evidence that indicates less retardant would be applied with this alternative, therefore similar effects are anticipated as those described in Alternative 2. Cumulative Effects

The impacts to NNIS and associated changes in vegetation diversity resulting from the incremental impact of the action added to past, present, and reasonably foreseeable future actions are expected to be the same as those described in Alternative 2.

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Summary of Effects on Federally Listed TEPCS Plant Species and Noxious and Non-Native Invasive Plant Species

No impact to plants or native plant communities, and no potential increases in NNIS (plants) due to the fertilizing effects of aerially applied fire retardant would occur from implementation of Alternative 1.

Impacts from aerially applied retardant to federally listed species, designated critical habitats, and Forest Service sensitive species are likely to occur from implementation of Alternatives 2 or 3. Impacts vary based on habitats, avoidance area mapping, potential for retardant use and land base impacted, potential for unknown occurrences, and misapplications of retardant. For Alternative 2, impacts to federally listed plant species include: 28 species with no effect (NE), 143 species that are likely to be adversely affected (LAA). 14 designated critical habitats with NLAA, 9 with LAA, and 1 with no effect. For Forest Service-listed sensitive species, 2,719 species are determined to have a may impact but not likely trend toward listing. For Alternative 3, impacts to federally listed plant species include: 28 species with no effect (NE), 81 species not likely to be adversely affected (NLAA), 62 species likely to be adversely affected (LAA). 23 designated critical habitats with NLAA and 1 with no effect. For Forest Service-listed sensitive species, 2,719 species are determined to have a may impact but not likely trend toward listing. Potential for increases in NNIS species may occur with implementation of Alternatives 2 or 3. These potential increases would be (1) dependent on presence and response of NNIS species in or near retardant application areas; (2) would be localized to the general areas of retardant application and would be treated using local forest NNIS treatment strategies, if identified by resource specialist on site; and (3) would be less than impacts from fireitself and/or other firefighting tactics.

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Public Health and Safety Affected Environment

Long-term fire retardants are a mixture of fertilizer salts, thickening and coloring agents, and other ingredients such as corrosion inhibitors and stabilizers. The concentrate, which may be either a liquid or powder, is added to water to produce the retardant used in firefighting operations.

The Forest Service has taken many steps to ensure the long-term retardants used by the field are as safe and effective as possible. Most of these steps occur as part of the product evaluation. Successful completion of this evaluation is required before a product can be placed on the qualified products list (QPL). All long-term fire retardants purchased and used by the Forest Service during firefighting operations must be on the QPL. Evaluation Process

Prior to acceptance of the product for evaluation by the Forest Service, the supplier of the candidate long-term retardant is required to provide the Forest Service with specific information necessary for the initial step of the evaluation process. This information includes:

A confidential disclosure of all raw materials used to make the retardant. The chemical abstract services (CAS) numbers for each of the raw materials. The CAS number is a unique identifier of the raw material in much the same way a Social Security number is the unique identifier forthe person assigned that number. The manufacturer and grade of each raw material. The amount of each raw material in the product concentrate as will be delivered to the Forest Service. The amount of each raw material in the product as prepared for application during firefighting operations. The material safety data sheet (MSDS) for each of the raw materials. The MSDS for the retardant concentrate as it will be delivered to the Forest Service.

The submitted information is reviewed to determine that the product does not contain chemicals of concern:

Chemicals listed in the specification (Forest Service 5100-304c, section 2.2) as unacceptable. Extremely hazardous substances (EHS) as listed at 40 Code of Federal Regulations (CFR) 355 Appendix A–Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), List of Extremely Hazardous Substances and Their Threshold Planning Quantities. Known or suspect carcinogens as determined by the National Toxicology Program’s Annual Report on Carcinogens or the International Agency for Research on Cancer (IARC) monographs for potential carcinogens.

If any of the raw materials appear on any of these regulatory lists, a chemical profile and potentially a product risk assessment (described in more detail below) may be required before further action is taken on the evaluation of the submitted formulation. An assessment of this type is performed by the Forest Service or an approved third party selected by the Forest Service, using accepted methodology described by the National Research Council (NRC) and affirmed as necessary by the Environmental Protection Agency (EPA).

If the hazard potential and amount of the raw material in the product do not change the hazard potential of the retardant, the evaluation may continue. Otherwise the evaluation stops at that point.

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Once the product is accepted for evaluation, specific mammalian toxicity tests as required by the specification are performed on the concentrate and on the mixed retardant. The product samples for all tests are supplied by the Forest Service from the evaluation sample, and all reports are submitted directly to the Forest Service to maintain a chain of custody for evaluation products and test results.

The tests are performed at a toxicity laboratory approved by the Forest Service, using health effects guidelines and test protocols approved by the Environmental Protection Agency, Office of Chemical Safety and Pollution Prevention (OCSPP) (formerly the Office of Prevention), Pesticides and Toxic Substances-OPPTS. The specific tests required by the Forest Service retardant specification are identified below. 1

Acute oral toxicity (OPPTS 870.1100), Acute dermal toxicity (OPPTS 870.1200), Acute eye irritation (OPPTS 870.2400), and Acute dermal irritation (OPPTS 870.2500).

The acceptable performance levels are based on Office of Safety and Health Administration (OSHA) performance standards in place in 1982, when the requirement was added to the retardant specification. These are all pass/fail tests. Retardant Use Policy and Firefighting Operations

Personnel involved in firefighting operations are required to complete specialized training in the safe and appropriate use of long-term retardant. Requirements and information on appropriate use, required personal protective equipment, aerial application, and restrictions on the application of retardant are found in the Interagency Standards for Fire and Fire Aviation Operations, which is updated annually. Programmatic Risk Assessments

Although aerial application of retardant historically was most often done in remote areas, the move toward year-round living in the wildland-urban interface (WUI) has increased the potential for civilian exposure to retardants.

Aerial application frequently occurs in more or less remote areas; however, as more people move in WUI and wildland for at least part of the year and for recreation, the potential for exposure to retardant increases.

A programmatic risk assessment of human health hazards is prepared every 5 to 10 years as the products on the Qualified Products List are modified or new products are added. The most recent document is the HumanHealth Risk Assessment: Wildland Fire-Fighting Chemicals (Labat Environmental 2003). This broad-scope risk assessment is an examination of the potential human health hazards and is performed by recognized professionals in the field under contract to the Forest Service. Several products (Phos-Chek D75-R, Phos-Chek D75-F, Phos-Chek G75-F, and Phos-Chek G75-W) are being phased out but are still in use in 2011 and are included here. Other products (Fire-Tro FTR, Fier-Trol GTS-R, Fire-Trol LCA-R, and Fire-Trol LCG-R) included in the risk assessment are no longer commercially available, have been removed from the QPL, and are not included.

The risk assessment process consists of three steps:

1 The OPPTS designation is shown because it was in effect at the time the tests were performed, but it is anticipated that those numbers will be changed as OCSPP completes the reorganization of this office

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The Hazard Analysis uses the results of product toxicity tests performed during product evaluations to estimate a reference dose or “acceptable daily intake,” that is expected to be safe according to available information. The results of toxicity tests on individual ingredients are also included if they fall into one of these categories: suspected carcinogens, highly toxic, or reportable under the provisions of OSHA or SARA 313. The Exposure Analysis develops estimated doses and estimates the extent and duration of exposures during firefighting operations. These estimates are developed during consultation with firefighters with long experience. The exposures include typical and maximum exposures for workers such as airtanker base personnel (mixers, loaders) and line firefighters (helitack crews, smokejumpers, hotshot crews, type 2 firefighters, engine crews, and overhead workers, male and female workers (different body weights), and adult and child members of the public.

The types of garments that target groups wear will greatly influence the potential for exposure and absorption through the skin.

Firefighters wear boots, long pants, long-sleeved shirts, gloves, hard hats, and sometimes goggles andneck shrouds, all of which offer some level of protection from skin absorption. Publics are more often exposed during cleanup of a structure after the fire and frequently wear light weight clothes (such as shorts and tank tops), increasing the likelihood of absorption through the skin. The Risk Characterization is estimated by calculating the hazard quotient, which is the estimated dose divided by the reference dose. When the hazard quotient is less than or equal to 1.0, the risk of health effects is predicted to be negligible.

No risks to line firefighters, airtanker base personnel, or the public were predicted for routine exposures. Most groups were not predicted to have increased risks from a severe exposure or accidental drench. However, mixers exposed to Phos-Chek G75-W powder concentrate for 8 hours or more were predicted to have some increased risk. This risk can be mitigated by removing the powder residue from clothing and exposed skin by washing with soap and water.

For typical exposure scenarios, all products and individual ingredients resulted in hazard quotients less than 1, indicating negligible risk to firefighting personnel from the retardants under typical conditions of exposure. Estimated cancer risk to workers is less than 1 in 1 million, also indicating a negligible risk. For maximum exposure scenarios, product formulations had hazard quotients greater than 1, indicating a possible health risk for male and female mixmasters exposed to dry powder concentrates, for male and female loaders exposed to mixed Phos-Chek G75-W, and to female loaders exposed to mixed Phos-Chek 259-F. For maximum exposure scenarios with individual ingredients, possible health risks were indicated for male and female mixmasters exposed to a retardant salt in Phos-Chek D75-R, Phos-Chek D75-F, Phos-Chek G75-W, and Phos-Chek G75-F, and for females from a corrosion inhibitor in Phos-Chek 259-F. The hazard index for Phos-Chek G75-F exceeded 1 when the risks from individual ingredients were summed, even though the individual hazard quotients were all less than 1. No risks were predicted for either adult or child members of the public from cleaning a structure that had been treated with retardant. For an accidental drench scenario for workers in the path of an aerial application, no significant risks were predicted. For the same scenario, risks were predicted for both adult and child members of the public exposed to Phos-Chek G75-W. Risks to people reentering the area following a fire such as rehabilitation teams, mushroom and berry harvesters, hunters, and salvage loggers are unlikely.

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Eating produce from home gardens where retardant was applied is not advised. No significant risks are expected from contact with domestic animals having retardant on their skin orcoats.

Phos-Chek G75-W is not used at airtanker bases and is qualified for application from ground engines and helicopter buckets only. These are the most accurate delivery methods.

Phos-Chek G75-W is typically used for portable operations where residual color may be an issue or applied as a fire prevention aid in situations where the likelihood of accidental ignitions is relatively high such as campgrounds or when fireworks displays are planned.

One thousand pounds of Phos-Chek G75-W retardant concentrate, enough to make 955 gallons of mixed retardant, was sold to the Forest Service in the past 10 years and was used in one area to provide protection to natural gas wells during prescribed fire operations. This limited use would also suggest that the exposure to mixers is unlikely to continue long enough to increase the risk.

Fire retardant products have been used for many years. During that time, reports of adverse health effects have been limited to skin and eye irritation and possible allergic reactions. This use history does not appear to warrant additional extensive testing, especially given the transient emergency use of these products. Environmental Consequences Alternative 1—No Action

Based on the available information related to human health effects of retardant, there is likely to be little change in the frequency and severity of these effects. In remote areas, the use or non-use of retardants will likely have no effect on human health. When fires occur on Forest Service land near developed communities, smoke from fires may have a greater impact on human health than retardants applied during firefighting operations. Respiratory problems aggravated by smoke inhalation have potential to affect many more people directly, resulting in respiratory distress, bronchial infections, and hospitalizations, and indirectly as access to forest lands, outdoor recreation, and employment is restricted. Alternative 2—Proposed Action

The human health effects of this alternative are likely to be minimal, primarily skin irritations, based on records of past incidents. The use of retardant has the potential to reduce smoke concentrations in some areas over use of water only; however, the greater influence on smoke concentrations is likely to be the presence of wind sufficient to remove the smoke. There is some potential for application of retardant on private property, including gardens and pets. As discussed above, cleaning property and pets is unlikely to have health effects, although consumption of garden produce that was coated with retardant is not advised, even after removing the retardant. Alternative 3

Based on the overall lack of significant human health hazards from retardant, it is unlikely that this alternative will have significant differences from the other alternatives with regard to human health and safety.

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Scenery Management Affected Environment

The scenic resources of National Forest System lands are valued by local communities and visitors. National forests and grasslands occur in 44 of the 50 states and cover approximately 193 million acres. These landscapes often serve as the backdrop and backyard for local residents and are integral to the quality of life and sense of place for surrounding communities.

Scenic landscapes often draw visitors to National Forest System lands and are a central theme in tourism and marketing efforts across the country. Scenic byways, scenic backways, wild and scenic rivers, scenic areas, and national scenic trails are a few of the agency’s programs that highlight, celebrate, and protect the scenic resources sought by those visiting, and connecting those living nearby.

Maintaining the scenic integrity of these landscapes includes consideration of both biophysical and cultural attributes. Due to the diversity of ecosystems and cultural contexts across which National Forest System lands span, landscape character descriptions serve as the foundation for inventorying, assessing, and establishing objectives for scenic resources at the landscape scale.

Landscape Character is defined as the overall sense of place created by valued physical and cultural attributes contained within a landscape. Ecological units, such as Bailey’s ecoregions (Bailey 1995), are often the starting point for delineating the geographic boundaries of distinct landscapes. The combination of each area’s physical, biological, and cultural attributes is then refined to form the context in which deviations in scenic integrity are analyzed. Regulatory Framework

Visual resources on National Forest System lands are protected by an array of laws, regulations, and executive orders. Highlights of selected key provisions include:

The National Environmental Policy Act of 1969 (42 U.S.C. 4321) directs the Federal Government to “(2) assure for all Americans . . . healthful, productive, and aesthetically and culturally pleasing surroundings; (3) attain the widest range of beneficial uses of the environment without degradation, [or] risk to health . . .; (4) preserve important historic, cultural, and natural aspects” of our environment. It further directs agencies to “insure the integrated use of the natural and social sciences and the environmental design arts in planning and in decision making which may have an impact on man’s environment.” This act directs agencies to develop methods and procedures “which will insure that [scenery and other] unquantified environmental amenities and values may be given appropriate consideration in decision making along with economic and technical considerations.”

The scenic resources of National Forest System lands are regulated by the rules of Title 36 of the Code of Federal Regulations, Part 219, Subpart A, National Forest System Land and Resource Management Planning (36 CFR part 219, subpart A). Requirements include the consideration, treatment, and protection of intangible resources such as scenery and aesthetics.

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Forest Plan Direction

The management of each national forest and grassland must be consistent with its land management plan (LMP). Depending on the year a unit completed its LMP, either the Visual Management System (VMS) or the Scenery Management System (SMS) would have been used to structure plan direction pertaining to scenic resources. These two systems are outlined in the Forest Service directives and referenced below. Forest Service Manual and Handbook Direction

Forest Service Manual (FSM) 2380 outlines policy and direction for the management of scenic resources. Updated in 2003, the manual contains direction on the transition from the Visual Management System (VMS) to the Scenery Management System (SMS).

Forest Service Handbooks (FSH) provide guidance on how to implement agency policy, requirements, and direction. Publications in the Department of Agriculture’s National Forest Landscape Management Series provide technical guidance in managing landscape aesthetics and scenery. The series is organized by volumes and chapters: Volume 1 is issued in Agriculture Handbook (AH) 434, and Volume 2 contains eight chapters issued in eight separate agriculture handbooks.

Forest Service handbooks pertaining to the management of scenic resources include:

USDA Forest Service. 1995. National Forest Landscape Management: Landscape Aesthetics—A Handbook for Scenery Management. Agriculture Handbook 701. Washington DC. 257 pages. USDA Forest Service. 1974. National Forest Landscape Management: Volume 2, Chapter 1. Agriculture Handbook 462. Washington DC. 47 pages. Environmental Consequences Alternative 1—No Action

There would be no direct, indirect or cumulative effects to scenic resources from the aerial application of fire retardant. Alternatives 2 and 3

The application of various aerial fire retardants may have a temporary impact on scenic resources on National Forest System lands. Colored fire retardants can temporarily stain surfaces a reddish color. The duration ofthis impact varies and depends both on the site conditions (soils, vegetation, and other physical characteristics) and on weather events (rain and snow) following the application. The visibility of the residual retardant will last longest in rocky areas and where little precipitation occurs. Areas composed of more porous surfaces and receiving more frequent precipitation will have shorter duration impacts. Most commonly, the effect on the scenic resource is short-lived and of minimal consequence. As the shift is made to the use of fire retardant with fugitive colorant, the effects on scenic resources would diminish.

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Social and Economic Considerations Introduction

The material contained in this section is a summary of information presented in the specialist report on social and economic effects, available in the project record. Multiple statutes, regulations, executive orders, and agency directives identify the general requirements for the application of economic and social evaluation in support of Forest Service decisionmaking. These include, but are not limited to, the National Environmental Policy Act (NEPA) of 1969, Forest Service directives (FSM 1970; FSH 1909.17), and Executive Order 12898 (1984) (i.e., Environmental Justice). Affected Environment

General background information about the history, application, and utility of aerial application of retardant is summarized in the Wildland Fire Management section in Chapter 3 within this EIS. Additional information about recent rates of use and costs of retardant for small and large fires on Forest Service lands is presented below.

The average number of fires on Forest Service land is estimated to be 9,320 per year (Table 11 'Current Average Suppression and Retardant Costs for Forest Service Fires (2000–2010) (2010$)'); average annual Forest Service suppression costs are estimated to be approximately $917 million per year (2010 $).

The average annual Forest Service cost of retardant use (i.e., cost for airtanker flight time and retardant purchase) is estimated to range from approximately $24 million to $36 million per year for 2000 to 2010, which is estimated to be approximately 2.6 percent to 4.0 percent of average total Forest Service Suppression costs per year 2. Tanker flight time accounts for 48 percent of the lower bound retardant cost estimate and 32 percent of theupperbound retardant costs. As noted in Table Current average suppression and retardant costs for Forest Service fires (2000-2010) (2010$) 3, retardant costs do not include general aviation program operation, support, and acquisition costs.

Table 11 Current Average Suppression and Retardant Costs for Forest Service Fires (2000–2010) (2010$)

Annual Average Annual Cost of Retardant Application (000’s) 3 Annual Cost of Retardant Application as Percent of Average Total Suppression Costs Number Suppression of Cost Per Lower-bound Under-bound Lower-bound Upper-bound Wildfires Year 1 ($000s) 2

9320 $916,623 $24,027 $36,350 2.6% 4.0%

1. Estimated from FIRESTAT data for 2000–2010 (USDA Forest Service 2011b). 2. Total cost derived from: FS accounting system, Foundation Financial Information System (FFIS) as adjusted according to Prestemon et al. 2008.

2 Source of total suppression costs: Forest Service accounting system, Foundation Financial Information System (FFIS) as adjusted according to Prestemon et al. 2008 (as summarized in USDA Forest Service 2011a). 3 Source: Data and calculations are summarized in USDA Forest Service 2011a.

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3. Cost of using retardant (i.e., airtanker flight time and retardant material cost) are derived from a range of retardant prices ($1.50 to $3.00 per gallon (2010$), and estimates of airtanker flight time costs obtained from National Interagency Fire Center (NIFC) databases and airtanker and contract data (USDA Forest Service 2011b). Retardant costs do not include acquisition or operation and support costs for the aviation and tanker bases. The aviation program is expected to continue under all alternatives, though some change in fleet composition and base operation may occur under Alternative 1 compared to existing conditions. Little difference in fleets and base operations is expected under Alternatives 2and3. Environmental Consequences Methodology

Existing agency policy and direction characterizes the goals and objectives (i.e., outcome constraints) that are used to help design wildland fire suppression plans and strategies. Those goals and objectives include consideration of a number of values-at-risk (e.g., property, infrastructure, natural resources), including priorities regarding firefighter safety, while accounting for the effectiveness of different suppression strategies and tools to protect those values over a range of environmental and physical/topographic conditions. For example, the Interagency Aerial Supervision Guide (IAS guide) (NWCG 2010) states that strategies (ground and air operations) are based on values-at-risk and resource management objectives, while tactics are based on fuel type, fire intensity, rate of spread, resource availability, and estimated (fire) line production rates (Chapter 8 of IAS guide). The IAS guide (Chapter 8)also states that tactical plans are based on a number of principles and considerations including target priorities, where retardant use is usually prioritized in the following order: (i) human safety, (ii) structure protection, and (iii) natural resources (see Wildland Fire Management section in this document for more information about existing objectives).

Given that the proposed action affects the degree to which fire retardant can be used to contain fires4 and therefore achieve pre-existing suppression goals and objectives (outputs), the economic effects in this analysis will be discussed in the context of increases or decreases in cost efficiency. This indicator is consistent with the goalof the IAS guide (NWCG 2010): “to promote safe, effective, and cost efficient aerial supervision services in support of incident goals and objectives.”

Differences in cost efficiency across alternatives are characterized by comparing potential changes in agency costs to potential changes in capacity to meet fire suppression objectives (see Table 12 'Components of Cost Efficiency'). This analysis makes the following general assumptions:

This analysis focuses on fire management where decisions are made to suppress or control a wildfire. None of the alternatives will directly affect fire management objectives; alternatives to retardant (e.g., water) are expected to be implemented to help meet suppression objectives as specified in pre-existing regulations, policies, and land management plans. While objectives are assumed to remain unchanged, the capacity to meet suppression objectives may change. The frequency or potential of small fires (<300 acres; size categories A, B, C, and D) to become largeor ‘escaped’ fires (i.e., initial attack success rate) can be used as an indicator of that capacity and corresponding risks to resources and services of value (‘values at risk’).

4 See the ‘Wildland Fire Management Specialist report’ (Henderson and Lund 2011) for details about the link between fire retardant use and suppression effectiveness as it relates to this proposed action.

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Table 12 Components of Cost Efficiency

Costs Suppression Objectives

1. Retardant Costs: Volume and flight time as a function of Protection of public and firefighter health and safety: proposed restrictions (e.g., avoidance areas) and exceptions; 2. Compliance Costs: Mapping of avoidance 1. From direct effects of exposure to retardant, and areas,assessments/consultations for misapplication, and 2. From indirect effects of changes in wildfire characteristics. monitoring resource impacts for application to fires <300 acres; and Protection of (or reduced probability of losses/damages 3. Other Wildfire Suppression Costs: Use of other to)Values at Risk: suppression tools (water, additional ground resources) and suppression strategies in the absence of retardant in an 1. Protection of property, structures, facilities from changes effort to maintain capacity to meet existing fire in fire characteristics and conditions, management goals/objectives (e.g., avoid increased 2. Protection of goods and services derived from natural and probability of escaped fires). cultural resources, consistent with existing resource management objectives, as specified in regulations and:

a. from direct effects of exposure to retardant b. from effects of changes in fire characteristics and conditions.

Assumptions Costs

Costs consist of (1) compliance costs (i.e., mapping, monitoring, and assessment/consultation activities); (2) costs of retardant application (i.e., material costs and flight time); and (3) other wildfire suppression costs (i.e., allother suppression costs, excluding cost of retardant use and compliance with retardant guidelines).

Under Alternatives 1 and 3, other suppression costs may be affected by: (1) use of alternative types of suppression tools and tactics used for initial attack and large fires, and (2) additional suppression effort needed to address potential changes in the number of escaped or large fires (i.e., change in initial attack success rates). Quantifying or projecting future suppression costs is difficult due to uncertainty about future fire conditions and characteristics that affect tool selection and strategy design, the relative effectiveness of those tools and tactics, and overall capacity of alternative tools and tactics to maintain initial attack success rates under reasonably foreseeable constraints on interagency fire management resources (e.g., crews, equipment, tankers, etc.). As a consequence, noattemptis made to quantify the incremental or indirect suppression costs associated with Alternatives 1 and 3. (For more details on suppression capacity, see the Wildland Fire Management section of this chapter.) However, changes in suppression costs are discussed qualitatively, and estimates of average suppression costs associated with large fires are discussed to help demonstrate the potential value of retardant in the context of avoided large fire costs.

The aviation program is expected to continue under all alternatives, though some change in fleet composition and base operation may occur under Alternative 1 compared to existing conditions. For the purposes of this analysis, agency costs associated with potential changes in the aviation program are not addressed further and are assumed to remain relatively constant across the alternatives. For details about costing assumptions, see cost results footnotes in Table 13 'Annualized Costs, by Alternative (2010$)'.

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Capacity to Meet Suppression Objectives

Capacity to meet suppression objectives associated with protecting values-at-risk, public health and safety, and firefighter safety is a function of both direct effects from exposure to retardant and indirect effects fromchanges in fire conditions resulting from the use of retardant. Direct effects are discussed in relevant sections ofChapter3 and summary of effects in Chapter 2 of this document and therefore are not reproduced in this section. Potential changes in fire characteristics and conditions depend on a number of unknown site-specific conditions and circumstances associated with future fires and are therefore described in qualitative terms only, as explained inthe Wildland Fire Management section of this chapter. As a consequence of the uncertainty surrounding indirect effects from future changes in fire conditions, no attempt is made to characterize potential changes in capacity tomeet suppression objectives. Instead, increased probability of escaped fire (or decreased initial attack success rate), is referred to in this section as one indicator to represent aggregate effects on capacity to meet suppression objectives and potential for increased threat to values-at-risk. Other indicators for resource effects are described in resource-specific sections within this chapter. For a comparison of costs to a complete list of all direct andindirect effects to resources, see the summary of effects in Chapter 2 of this document. Alternative 1 Direct and Indirect Effects

Compliance, retardant use, and other suppression costs are presented, by alternative, in Table 13 'Annualized Costs, by Alternative (2010$)'. Details about other suppression costs and effects associated with "capacity to meet suppression objectives" are discussed separately for each alternative.

Table 13 Annualized Costs, by Alternative (2010$)

Compliance Costs Annual cost of Other Aerial Annual Total Suppression Annualized Annual Retardant Misapplication Annualized 2 Mapping Monitoring 1 Costs Assessment and Compliance Application Cost 3 Cost 4 Consultation 5 Cost

Alt 1 $0 $0 $0 $0 $0 >Alt 2

Alt 2 $24 to $36 ~ $880 to $830,000 $140,000 $70,000 $1,040,000 million $892 million

Alt 3 $1,020,000 $270,000 $70,000 $1,360,000 ~Alt 2 costs ≥ Alt 2

1. Costs for retardant volumes and flight time. Decreases in retardant use due to new restrictions may be offset byincreases in retardant use in other (non-avoidance) areas under Alternative 3; insufficient evidence exists to conclude that Alternative 3 costs will differ from Alternative 2 costs.

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2. Remaining suppression costs, excluding retardant and compliance costs. Alternative 2 costs derived from total baseline suppression costs in Table 1 ($917 million). Costs for Alternatives 1 and 3 affected by (i) adoption of alternatives to retardant (e.g., water) for small and large fires and (ii) potential increases in numbers of escaped or large firesarenot included. Costs do not include annualized acquisition or operation and support costs for the aviation and tanker bases in general. The aviation program is expected to continue under all alternatives, though some change in fleet composition and base operation may occur under Alternative 1 compared to existing conditions. Little difference in fleets and base operations is expected under Alternatives 2 and 3. 3. Mapping costs are higher during the first or initial year and then constant for subsequent years. A 4 percent discountrate and 15-year period is assumed. Costs include mapping tasks and pre-season coordinated meetings. 4. For Alternative 3, monitoring (8 days per fire) is assumed to occur on an average of one small fire (<300 acres) peryear on 75 forest units; only one forest unit was estimated to apply retardant on more than 30 small fires, on average, per year. No monitoring of small fires occurs under Alternative 2. Costs for Alternatives 2 and 3 assume an averageof23 days per year for monitoring and reporting to comply with effects reporting under RPA sub-element #4. 5. Similar effort assumed for Alternatives 2 and 3 for assessment and consultation for an average of 15 incidents per year, across all forest units. Potential decreases in effort under Alternative 3 are too difficult to project. Costs do not reflect cultural resource assessments and consultation; these costs are not expected to have a substantial effect on overall compliance cost estimates. Compliance and Retardant Costs

Under Alternative 1, there are no direct costs associated with aerial application of retardant. Correspondingly, there will be no compliance costs associated with mapping, monitoring, or misapplication requirements. Other Suppression Costs

There is potential for increases in other suppression costs under Alternative 1 given expectations that alternative suppression tools and tactics will be used in the absence of retardant.

As discussed in the Wildland Fire Management section in this document, water is estimated to be only 50 percent as effective as retardant, implying that twice as many flights may be necessary. However, there are a number of site-specific factors and conditions, as well as fire program constraints that could affect the ability tosubstitute water for retardant and achieve the same level of suppression, as might be represented by initial attack success rate. If overall capacity for suppression is reduced in some situations, then initial attack success rates could decrease, implying potential increases in the costs associated with managing large or escaped fires. For details, see the Wildland Fire Management Specialist Report (Henderson and Lund 2011) and corresponding section in this chapter. Given the uncertainty regarding future fire locations and conditions and corresponding factors affecting theuse and effectiveness of substitute tools and tactics, changes in indirect costs and initial attack success rates are not quantified for this analysis. However, examples of large fire suppression costs are discussed below to helpdemonstrate potential changes in suppression costs associated with escaped fires and the value of retardant in the context of avoided costs.

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The incremental cost of an escaped fire (i.e., value of prevention of a large fire) on National Forest Systemlands has been estimated to be approximately $2.8 million based on large fire (>300 acres) expenditures for 2000 to20095 (as summarized in USDA Forest Service 2011a). As noted in Table 1, current costs associated with retardant application range from $24 to $36 million per year. The number of avoided escaped fires that might justify retardant costs can be obtained by dividing retardant costs by an average of $2.8 million per escaped fire, resulting in 9 to 13 fires per year. These results suggest that the benefits of retardant use would just outweigh the costsofretardant if the number of escaped fires increased by 9 to 13 fires per year in the absence of retardant. There arelikelytobe other indirect costs associated with escaped fires that are not accounted for in the estimate of $2.8 million, suchas loss of property, resources, increased risk of adverse health and safety effects, and rehabilitation, recognizing that indirect costs may be offset by future suppression cost savings. As emphasized above, this is simply an example to demonstrate the potential magnitude of incremental suppression costs that might justify retaining retardant as a suppression option (i.e., value or opportunity cost of retardant) under Alternative 1; actual increases in the number of escaped fires have not been estimated due to the uncertainty stated above.

In general, the costs associated with using alternative suppression tools and strategies under Alternative 1 cannot be quantified; however, there is potential for increases in suppression costs associated with use of alternative tools and tactics on both small and large fires, as well as general suppression effort needed to address potential increases in the number of large fires that escape initial attack. There may also be potential for increased suppression costs for some large fires where suppression efforts may be extended over longer periods of time as a consequence of eliminating retardant application, combined with management constraints imposed by limitations on the availability of crews and equipment as substitutes for retardant. Capacity to Meet Suppression Objectives

For fires where decisions are made to implement suppression, overall risk to public and firefighter health andsafety as well as probability of loss or damage to values-at-risk are expected to increase under Alternative 1 as a consequence of increased probability of escaped or larger fires. For details about increased probability of large fires (i.e., decreased initial attack success rate), see specialist sections related to fire operations and health and safety in Chapters 2and 3 of this document. Cumulative Effects

Cumulative effects under Alternative 1 may occur as a result of interagency fire management operations, where fires may involve multiple agencies and jurisdictions. Retardant use strategies, policies, and trends forotherland management agencies (such as Federal or State) may be such that the elimination of retardant by the Forest Service will create inconsistencies with air operation standards and guides adopted by other agencies, resulting in higher probability for confusion (and safety hazards) among ground and air crews and increased time needed to plan and coordinate strategies (i.e., increased costs) when suppression involves multiple agencies or crosses agency boundaries.

5 The average cost per large fire (>300 acres; categories E–G) is estimated to be approximately $3 million basedona range of $2.9 million (2000–2009) to $3.1 million (2005–2009) per fire derived from expenditure data, by fire p-code, from the Forest Service’s Foundation Financial Information System (FFIS). The average cost is reduced by 5 percent to account for initial attack expenses and retardant costs on some fires.

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Alternative 2 Direct and Indirect Effects Compliance and Retardant Costs

Compliance costs (mapping, monitoring, assessment, and consultation) under Alternative 2 are estimated to be approximately $1 million per year, accounting for only 3 to 4 percent of all direct costs associated with the sum of compliance and retardant costs (see Table 13 'Annualized Costs, by Alternative (2010$)'). Most compliance costs are due to avoidance mapping ($830,000), with assessments, consultation, and monitoring accounting for the remaining $210,000 per year. Costs for retardant use are estimated to range from $24 million to $36 million per year, which is simply the average annual material and flight time costs from 2000 to 2010, as discussed earlier in the Affected Environment section (i.e., retardant costs are assumed not to change from costs incurred over the past decade). Other Suppression Costs

Other costs, as well as aggregate wildfire suppression costs, are assumed to remain unchanged, as availability and use of retardant as a component of overall suppression strategies is assumed to continue at a level similar to operations over the past 10 years. Total suppression costs are assumed to be $917 million per year, based on historical data from 2000 to 2010, implying that costs associated with suppression efforts, excluding retardant and compliance costs, are approximately $880 to $892 million per year. Capacity to Meet Suppression Objectives

For fires where decisions are made to implement suppression, initial attack success rates and risks tofirefighter safety and public health, property, structures, facilities, ecosystem services, and resource conditions, for small and large fires, are expected to remain unchanged under Alternative 2, relative to recent periods of timeoverwhich retardant has been used under the 2000 guidelines. For details about current initial attack success rates (e.g., 95 to 98 percent) and capacity to protect values-at-risk, see specialist sections related to fire operations, health and safety, terrestrial, aquatic, and plant species in Chapters 2 and 3 of this document. Cumulative Effects

Under Alternative 2, the cumulative effects derived from guidance inconsistencies across agencies, as described for Alternative 1, are not expected to occur given that the agency’s capacity to cooperate with other agencies (Federal and State) remains unchanged relative to conditions over the past 10 years.

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Alternative 3 Direct and Indirect Effects Compliance and Retardant Costs

Compliance costs (mapping, monitoring, assessment, and consultation) under Alternative 3 are estimated to be approximately $1.4 million per year, with most compliance costs attributable to avoidance mapping, similar to Alternative 2. The increase in compliance costs relative to Alternative 2 (about $400,000 per year) is due to additional mapping costs associated with sensitive species and terrestrial standards and additional monitoring costs related to small fire monitoring. Assessment and consultation costs are estimated to be similar for Alternatives 2and3,with some unquantified potential for decreases in consultation costs under Alternative 3 due to fewer exceptions and adoption of pre-existing criteria for determining if effects constitute the need for emergency consultation (i.e., analysis of effects and potential for emergency consultation for federally listed species is assumed to occur for all incidents under Alternative 2, but only for those incidents where effects may exceed pre-established consultation determinations under Alternative 3).

Additional assessment and consultation, as well as monitoring effort, may be needed to determine the effects on cultural resources, including historic properties, traditional cultural resources, and sacred sites in the event of misapplication of retardant. It is difficult to estimate misapplication rates for cultural resources, and calculated compliance costs therefore do not reflect cultural resource assessments and monitoring requirements for Alternative 3. However, there is little evidence to indicate that misapplication rates and compliance costs related to cultural resources will have a substantial effect on the relative magnitude of assessment, consultation, and monitoring costs (calculated to be $340,000 per year for resources other than cultural resources), compared to the magnitude of other costs (i.e., $1.02 million per year for mapping; $24 to $36 million per year for retardant use) under Alternative 3.

As noted in the methodology section above, it is not possible to conclude that annual retardant use and costs will be higher or lower under Alternative 3 compared to Alternative 2. Retardant use under Alternative 3 may be lower due to: (1) fewer exceptions, (2) increased acreage of avoidance areas (due to the addition of sensitive species mapping), and (3) possible decisions by some forest units who rarely use retardant to eliminate the use of retardant (due to the perception that the benefits of retardant do not outweigh additional costs and effort required tocomply with the additional requirements under Alternative 3). However, decreases in retardant use in avoidance areas and near water bodies might be offset by increases in retardant use in other areas to compensate for constraints in avoidance areas. As a consequence, there is insufficient evidence to conclude that retardant use under Alternative 3 will be different from the range of costs identified for Alternative 2. Other Suppression Costs

The additional restrictions and constraints imposed on retardant use under Alternative 3 may result in greater use of suppression methods and tools that are less cost effective or greater probability of escaped fire in the event that future fires occur under conditions or locations where restrictions apply. The aggregate costs of wildfire suppression could therefore increase relative to Alternative 2 for some fires. However, it is difficult to predict the relative changes in the degree to which substitute tools and tactics or greater probability of escaped fire will result in higher suppression costs. The direction and magnitude of changes in other suppression costs are therefore uncertain compared to Alternative 2, but still expected to be lower than Alternative 1. For more details about changes in fire operations and fire suppression capacity, see the Wildland Fire Management section in this chapter.

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Capacity to Meet Suppression Objectives

For fires where decisions are made to implement suppression, the additional restrictions and constraints onretardant application under Alternative 3 (see Wildland Fire Management section in this chapter for details about constraints) may result in real time delays in conducting initial attacks in certain situations, thereby creating potential for slight decreases in initial attack success rates and increased risks to firefighter safety and public health, as wellas values-at-risk for some forest units, relative to Alternative 2, but still substantially less than Alternative 1. Potential for incremental decreases in success rates and risks under Alternative 3 may be more evident after mapping of avoidance areas is completed for all units. For additional details about effects on initial attack success and capacity to protect values-at-risk, see other specialist sections in this chapter.

It is not possible to show how new avoidance area requirements (i.e., terrestrial and sensitive species mapping) could potentially affect suppression flexibility and capacity to protect values-at-risk, such as property within the WUI, as those areas have yet to be mapped with the exception of the San Bernardino National Forest. However, the San Bernardino avoidance areas can be used to demonstrate how forest units might evaluate the potential impacts on capacity to address values-at-risk within the WUI. Buffer areas measuring 0.5 to 1.5 miles in width were drawn around all private "developed" land adjacent to National Forest System land6 for the San Bernardino National Forest. It was determined that approximately 1 percent of the total buffer areas overlapped with terrestrial avoidance areas on the San Bernardino (USDA Forest Service 2011f), suggesting for this example that the inclusion of terrestrial avoidance areas may not have a substantial adverse impact on retardant use and capacity to protect values-at-risk within the adjacent developed areas, in the event of wildland fire in these areas. These results arefor demonstration purposes only; results cannot be extrapolated to other forest units. Cumulative Effects

The same cumulative effect described for Alternative 1 may occur under Alternative 3; however, the magnitude of the effect is expected to be less as differences in guidance would be more limited and less likely to create confusion or inconsistency across agencies. Summary of Direct and Indirect Effects

Table 14 'Summary of Direct and Indirect Effects' summarizes cost efficiency results for this section as it relates to capacity to meet suppression objectives as represented by probability of escaped fire. Probability of escaped fire does not capture all potential resource effects resulting from this action, and the reader is referred to Chapter 2 of this document for a more complete comparison of all effects.

Table 14 Summary of Direct and Indirect Effects

Effect Indicator Alternative 1 Alternative 2 Alternative 3

Agency Costs Annualized compliance $0 $1 million/yr $1.4 million/yr costs 1

6 All land within 500 feet of National Forest System land, including inholdings, where the average lot size within census blocks was smaller than 40 acres (USDA Forest Service 2011d).

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Effect Indicator Alternative 1 Alternative 2 Alternative 3

Average annual retardant $0 $24 to $36 million Similar to Alternative 2 costs 2

Greater than Alternative 2 due to (1) use of substitute tools and $880 to $892 tactics for some small and large Similar to or slightly million/yr (i.e., 3 fires and (2) suppression of higher than Alternative 2; Other suppression costs baseline potential increases in the number Lower than Alternative 1 suppression costs) of escaped (large) fires (e.g., $2.8 million per escaped fire)

Capacity to satisfy Capacity similar to or suppression objectives slightly lower than Alternative 2; potential Probability of escaped fire Decreased capacity; increased for slight increase in (for fires where decisions No change probability of escaped fire. probability of escaped fire are made to suppress) for some forest units depending on avoidance area mapping results

Suppression cost Similar to or slightly Lower Unchanged efficiency lower than Alt. 2

1. To comply with avoidance mapping, assessments, consultation for misapplications, and monitoring requirements. 2. Retardant volume and flight time. 3. Total Forest Service suppression costs for all fire sizes, net of compliance and retardant costs. Environmental Justice

Executive Order 12898 (February 11, 1994) directs Federal agencies to focus attention on the human health and environmental conditions in minority communities and low-income communities. The purpose of the executive order is to identify and address, as appropriate, disproportionately high and adverse human health or environmental effects on minority populations and low-income populations. The Council on Environmental Quality (CEQ) (1997) provides the following definitions in order to provide guidance with the compliance of environmental justice requirements:

“Minority population: Minority populations should be identified where either: (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....” “Low-income population: Low-income populations in an affected area should be identified with the annual statistical poverty thresholds from the Bureau of the Census' Current Population Reports, Series P-60 on Income and Poverty. In identifying low-income populations, agencies may consider as a community either a group of individuals living in geographic proximity to one another, or a set of individuals (such as migrant workers or Native Americans), where either type of group experiences common conditions of environmental exposure or effect.”

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The proposed guidelines for aerial application of retardant applies to future unknown wildland fire locations on National Forest System lands in all regions of the country; as such, it is not possible to identify specific populations, demographics, or specific minority populations that might be exposed to retardant. It is also estimated thatretardant has been applied to fewer than 5,000 acres per year, on average, over the past 10 years (as noted in the Wildland Fire Management section in Chapter 3 of this document), suggesting that potential for direct exposure to retardant is low. There is potential for larger and longer duration fires under Alternative 1 (only a slight potential under Alternative 3), translating to increased exposure to risks for firefighters, the public, and values-at-risk; however, there is no evidence indicating that risks will be disproportionately higher for minority or low-income population areas. Based on this evidence, the proposed action is not expected to have a disproportionately high and adverse human health or environmental effect on minority populations or low-income populations.

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Soils Introduction

This section addresses the potential for fire retardant to change soil chemical properties, leach through the soiland enter streams and water bodies, increase vegetative growth, and change vegetative community composition, under the proposed action and alternatives. The fate of fire retardant application and its subsequent effect on soil productivity varies with application rates, vegetation types, fuel models, and inherent soil properties. Current fire retardant formulations in use today are primarily inorganic fertilizers, the active compound being ammonia polyphosphates (Henderson and Lund 2011); as with any nutrient addition to the soil, there is a chemical response that may affect soil fertility. Because soil properties are so unique and vary by ecoregion, a soil risk rating identifies the soil condition (physical, chemical, and biological properties) that affects the movement, uptake, and response of the soil to the fire retardant. See Appendix H for soils risk rating. Affected Environment

The potentially affected environment is limited to National Forest System (NFS) lands, approximately 193 million acres. The estimated area of retardant application annually across all national forests is between 2,538 and 4,715 acres annually (0.002 percent of total Forest Service land base).Soils across the national forests vary based on climate, parent material, topography, and living organisms present. Forest Service land managers are charged with the task of ensuring that soil quality and productivity is maintained. Soil physical, chemical, and biological properties are used to describe existing conditions as they affect soil quality and sustainability (USDA Forest Service 2010). The application of aerial fire retardant across diverse soils and ecosystems may affect soil condition through physical, chemical, and biological changes from the fertilizing effects of retardants or through leaching of nutrients from soils into streams and waterbodies.

Soils contain both nitrogen and phosphorus. The amount of soil nitrogen and phosphorus varies and is related to physical and chemical properties including texture, clay content, soil structure, organic matter content, nutrient availability, and soil pH (Certini 2005, Neary et al. 2005).

Site-specific soil property information is available through the State Soil Geographic (STATSGO) Database, Soil Survey Geographic (SSURGO) database, or from individual forest soil resource inventories. These surveys provide information on physical, chemical, and biological properties of soils. The STATSGO database is the U.S. General Soil Map and provides coverage for the entire United States at a coarser scale than what is commonly available from individual forest soil resource inventories.

Soil quality and productivity vary throughout the national forests. Management activities include forest management, grazing, recreation, access and travel management, prescribed fire, and other disturbances. Each management activity has the potential to affect soil physical, chemical, and biological properties by modifying vegetative cover, increasing soil compaction and erosion, changing soil hydrologic properties, and changing soil nutrient status by the addition or removal of nutrients. Soil contamination occurs from contaminant sources including abandoned mines, illegal dumping, drug labs, spills, atmospheric deposition, and others. Each forest manages activities to reduce potential adverse impacts on soil resources by using regional soil quality standards to maintain and protect soil productivity. The Forest Service Watershed Condition Classification requires each forest to evaluate soil condition on a watershed scale and evaluate indicators for soil productivity, soil erosion, and soil contamination (Potyondy and Geier 2010).

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In order to understand how fire retardants can affect soils it is important to look at nitrogen and phosphorous sources and principal mechanisms of movement from soils to plants or from soils to water bodies. Nitrogen constitutes about 78 percent of the earth’s atmosphere. The primary pathways by which nitrogen is converted to forms usable by higher plants are:

Atmospheric deposition, Biological fixation (plants, soil microorganisms), Synthetic fertilizers, and Organic fertilizers and manures.

Total nitrogen content of soils ranges from less than 0.02 percent in subsoils to more than 2.5 percent in peat soils (Tisdale et al. 1985). Brady (1984) identifies three major forms of nitrogen in mineral soils: organic nitrogen is associated with the soil humus, ammonium nitrogen that is fixed by certain clay minerals, and soluble inorganic ammonium and nitrate compounds. The amount of soluble nitrogen available to plants can be as little as 1–2 percent of the total nitrogen in the soil. The largest pool of nitrogen is in the organic form and tightly held by clay minerals in the subsoil.

Phosphorus is critical for many reactions that maintain plants and animals. Phosphorus is immobile in the soil and is tightly bound to soil particles. Phosphorus, like nitrogen, is found in two different forms in soil: inorganic and organic. Organic forms are in humus and other organic material. Phosphorus in organic materials is released through the mineralization process involving soil organism. Microbial activity is highly dependent on soil moisture and temperature. Inorganic phosphorus is negatively charged in most soils and reacts with positively charged iron, aluminum, and calcium ions to form insoluble substances. Both positively charged iron and aluminum ions are typically found in forest soils, and when these ions react the phosphorus is considered fixed and not available to plant growth. Soil phosphorus is most available for plant uptake at pH values of 6 to 7. When the soil pH is below 6, aluminum phosphates fix the phosphorus. Alternatively, at pH levels above 7, positively charged calcium ions also fix the phosphorus, again making is unavailable to plants. The addition of more phosphorus tothesoilmay not increase the plant uptake of phosphorus. Other soil properties that reduce the solubility of phosphorus include organic matter content, soil texture, and the cation exchange capacity of the soil. Because phosphorus is immobile, it can enter streams and water bodies only through a misapplication or from post-fire erosion where phosphorus laden sediment enters a water body. Environmental Consequences General Effects of Fire Retardant on Soils

The primary effect on soils from retardant is a fertilizing response. For nutrient-poor soils (sandy, low organic matter content), the addition of nitrogen and phosphorus could improve soil productivity in the short term. For already productive soils (clay, high organic matter content), the additional nutrients could have an acidifying affect and reduce soil pH, making some nutrients unavailable. An indirect effect of fire retardant application is an increase in vegetative growth and potential change in vegetative community composition. Leaching of nitrogen into streams and water bodies could occur in areas of coarse-textured soils and for drops occurring within the water body influence zone. The persistence of effects will depend on vegetation type and post-application weather patterns (Adams and Simmons 1999).

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Soil response to long-term fire retardants varies with soil quality, vegetation, application rates, and environmental conditions (temperature, biological activity, and precipitation) during and after the application. (See soil report risk chart – Appendix H.)

Other direct effects include the potential for nutrient leaching. Because phosphorus is not mobile in the soil, the only transport mechanism would be associated with erosion of soil particles that had been coated from a retardant drop. Nitrogen leaching potential is higher in coarse-textured soils because there is less clay and organic matter to bind the fertilizer. Leaching of nitrogen into streams and water bodies could occur in areas of coarse-textured soils when retardant drops occur within the water body influence zone.

The following studies show how variable the soil response can be. A test of Phos-Chek application on mixed grass prairie wetland ecosystem soils shows a fertilizing response with increased herbaceous biomass but decreased species diversity (Poulton et al. 1997). Other studies showed Phos-Chek degrading rapidly in soils with high organic content, suggesting that long-term effects are unlikely (Little and Calfee 2002). Diammonium phosphate retardant application on herbaceous biomass in California oak-savanna rangeland had increased vegetative response the first year but the response was not significant the second season (Larson and Duncan 1982).

Research in two study sites in heathland areas of Victoria, Australia (Hopmans and Bickford 2003) demonstrated the effect of fire retardants on sandy, coarse-textured soils with low accumulations of organic matter. Phos-ChekD 75 R was applied at rates typically used for fire control. The effect of the applications decreased the soil surface pH by 0.5 units. The change in pH was still evident after 12 months. The soil salinity response varied between the two test sites with little to no change at one site compared to a significant increase in the soil salinity on a soil with low background electrical conductivity. The duration of the change in salinity of the surface soil was less than 6 months. Observed levels of plant available nitrogen increased from three-fold at one site to nearly ten-fold at another site. The increase in plant-available nitrogen rapidly declined to background levels after 12 months. Similarly, significant increase (five-fold) in plant-available phosphorus was found in the surface soil after 12months.

Persistence of fire retardants and their availability to the environment varies depending on retardant concentration and soil quality. Little and Caffee (2002) studied the toxicity to aquatic species and persistence of chemicals in fire retardants using different substrates in weathering studies. Toxicity was much lower on soils with high organic content. Conversely, soils with low organic matter or coarse, sandy soils showed significantly higher mortality to aquatic species. Other factors that come into play include soil moisture, temperature, and diurnal temperature changes, which affect microbial processes. Research conducted in Australia identified soil pH, organic matter content, and clay content as important factors affecting fate and persistence of the fertilizer (NRE 2000).

A test of retardant effects on prairie and mountain soils resulted in an increase in biomass, mostly grasses, over the first growing season (Larson and Newton 1996).

Indirect effects on vegetation include: increased biomass production, plant vigor, fertilizer burn, and shifts in species composition. The degree of the response depends on annual and seasonal changes to rainfall, temperature, and microbial activity.

Studies on the effect of fertilizers (nitrogen and phosphorus) on vegetation growth and plant community composition can help to explain how plants use the fertilizers in fire retardants. According to a study by Leishman and Thompson (2005), the invasion of exotic plants is more successful on low quality soils where nutrients, especially phosphorus, have been added.

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In Australia, phosphorus fertilizer applied for 3 years on nutrient-poor sandy soils was retained in the ecosystem for at least 2 decades (Heddle and Specht 1975). The long-term study showed the heath vegetation changed towards an herbaceous sward in response to the phosphorus fertilizer 22 years after application.

Conversely, studies conducted in Australia demonstrated little change in vegetative growth response from one application of Phos-Chek (Bell 2003). These studies indicate a potential for increased vegetative growth is often a quick, short-term response to the application of the fertilizers. However, changes in vegetative community composition through the addition of nitrogen and phosphorus application resulted from repeated applications over many years, which is not typical of aerial fire retardant applications. Alternative 1—No Action Direct and Indirect Effects

In the absence of aerial fire retardants, the effect of fire on soils must be most prominently considered. Firescan increase nitrogen availability as organic nitrogen is volatilized and mineralized ammonium is available to plants and animals. Nitrogen availability lowers to pre-fire levels in a few years (Certini 2005). Fires also convert the organic pool of soil phosphorus to orthophosphate, which is readily available to plants (Debano et al. 1998). Soil erosion and nutrient leaching into streams and water bodies is a common post-fire response (Neary et al. 2005). The fire size and soil burn severity would determine how many acres are affected.

Without the use of aerial fire retardant any indirect effects from retardants on soil would be from ground-based applications, which would most likely occur on limited acreage. The effects of the ground-based applications to soil would most likely be masked by the chemical and physical effects associated with the wildfire.

Nationwide the average annual initial attack success rate is 98 percent (Henderson and Lund 2011). Firefighting strategies are improved with aerial fire retardants because they help slow the rate of spread. Without this toolitis likely that initial attack success rates may be reduced and in some cases fire size could increase, resulting in more acres burning at a high soil burn severity rating. If more acres burn, there could be additional costs in Burned Area Emergency Response (BAER) assessment and potential treatments to reduce the post-fire threat to life, property, and cultural and natural resources due to flooding, landslides, and loss of infrastructure. Without the use ofaerial fire retardants, other firefighting strategies may be used in suitable locations, which could cause greatersoil disturbance and erosion, and reduce soil quality and productivity (Ingalsbee 2004, Backer et al. 2004). Cumulative Effects

No cumulative effects on the soil physical, chemical, or biological properties would occur because no fire retardants would be applied.

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Alternative 2—Proposed Action Direct and Indirect Effects

Under this alternative the acres affected by retardant would be similar to the 10-year average and vary accordingly by ecoregions and Forest Service region. An estimated 2,358 to 4,715 acres annually (0.002 percent of the total Forest Service land base) may receive retardant application. It is difficult to identify which soil types maybe affected, but it is realistic to expect all soil types to potentially be treated. Cumulative Effects

The impacts on soil condition (physical, chemical, and biological properties) resulting from the incremental impact of the action added to past, present, and reasonably foreseeable future actions are expected to be minor based on the following points:

Retardant application rates are based on fire behavior fuel models and fuel descriptions, and retardant is applied in front of an advancing fire. Fuel models are important to soils since they provide information on the amount and size class of live and dead vegetation available to intercept the retardant. When retardant is dropped on grass or brush, it has a greater live plant surface area to adhere to before coming in contact with the soil. For horizontally placed litter and slash, retardant movement to the soil is influenced by the depth and continuity of the material (Tome and Borrego 2002). Of the retardant applied, only a small percentage reaches the soil surface. Fire retardant formulations will likely continue to be nitrogen- and phosphorus-based; therefore, similar effects are expected although concentrations of salts may change. Application of aerial fire retardant consists of a very small proportion of land base nationally. Alternative 3 Direct and indirect effects

The environmental consequences on soils under this alternative would be the same as the proposed action but may occur on slightly more acres since fewer acres are included in the avoidance mapping for Alternative 3.

Indirect effects would be the same as the proposed action. Cumulative Effects

The impacts on soil condition (physical, chemical, and biological properties) resulting from the incremental impact of the action added to past, present, and reasonably foreseeable future actions are expected to be minor based on points presented under Alternative 2. Summary of Effects

Table 15 'Summary of Effects on Soils' summarizes the direct effects of the no-action and action alternatives on soil resources.

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Table 15 Summary of Effects on Soils

Effect Indicator Alt. 1 No Action Alt. 2 Proposed Action Alt. 3 Preferred Action

Fertilizing effects of Acres affected by Expect 2,358-4,715 acres More than Alternative 2 retardants on soil retardant annually or 0.002 percent due to fewer acres being None productivity of the total land base to be included in avoidance affected by retardant mapping

Leaching or erosion of soil Number of retardant Remain at current levels Lower than Alternative 2 and nutrients into streams drops within 300-foot None due to allowable exceptions due to fewer exceptions in and water bodies buffer in fire retardant use fire retardant use

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Wilderness Character Introduction

This section focuses on the potential effects of aerially applied fire retardant on wilderness areas and their characteristics. Affected Environment

The Wilderness Act allows for actions necessary for fire control, which includes application of fire retardant. Use of fire retardant in wilderness or wilderness study areas must be consistent with maintaining the desired qualities of those areas. These include ecological qualities, aesthetic values, and recreational opportunities of the areas. Special features within wilderness areas are considered resources of value for their unique nature alone and merit protection. The nature of each attribute and the potential short-term and long-term impacts of fire retardant use are as follows. Untrammeled

This quality monitors modern human activities that directly control or manipulate the components or processes of ecological systems inside wilderness. Wilderness in untrammeled areas is essentially unhindered and free from modern human control or manipulation. Natural

This quality monitors both intended and unintended effects of modern people on ecological systems inside wilderness since the time the area was designated. Wilderness ecological systems in natural areas are substantially free from the effects of modern civilization. Undeveloped

This quality monitors the presence of structures, construction, habitations, and other evidence of modern human presence or occupation. Wilderness in undeveloped areas is essentially without permanent improvements or modern human occupation. Primitive Recreation and Solitude

This quality monitors conditions that affect the opportunity for people to experience solitude or primitive, unconfined recreation in a wilderness setting, rather than monitoring visitor experiences per se. Wilderness provides outstanding opportunities for people to experience solitude or primitive and unconfined recreation, including the values of inspiration and physical and mental challenge.

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Special Features

A special feature is an attribute that recognizes that wilderness may contain other values of ecological, geologic, scientific, educational, scenic, or historical or cultural significance. Unique fish and wildlife species, uniqueplants or plant communities, potential or existing research natural areas, outstanding landscape features, and significant cultural resource sites should all be considered as types of values that might exist. Environmental Consequences Direct and Indirect Effects Alternative 1 No Action

Under the no-action alternative there would be no effects on wilderness characteristics from the use of aerially applied fire retardant since none would be used. Alternatives 2 and 3

The effects on wilderness characteristics would be the same under both alternatives since there are no differences between these alternatives due to the presence of wilderness. Untrammeled

Fire retardant introduces chemicals into the environment that at the very local level will affect nutrient loads, nutrient cycling, growth rates, and potentially some toxicity issues. The retardant may affect plant growth, may impact micro-habitats for microorganisms, and may affect use of vegetation that is treated. The presence of fire retardant chemicals could affect ecological processes at the micro scale. The degree of impact depends on the amount and type of retardant. Natural

The presence of fire retardant dye creates an unnatural appearance, which is another indicator of the presenceof man and civilization. To the extent that fire retardant chemicals disrupt natural processes or detract from the natural surroundings via coloration of vegetation, it is a negative effect on the natural quality of wilderness. As the use of fugitive colorant in fire retardant increases, these effects are expected to decrease. Retardant loads that aredropped low or fail to disperse may also damage vegetation, leading to an unnatural appearing localized impact. Undeveloped

While fire retardant is not a structure or installation, the presence of the dye trace can result in visible presenceof the fire retardant in wilderness. When the dye is dropped in highly visible locations it can detract fromthescenic qualities of wilderness. As the use of fugitive colorant in fire retardant increases, these effects are expected to decrease.

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Primitive Recreation and Solitude

Fire suppression activities, including the application of retardant, are unlikely to adversely affect human use and visitation because most active fire suppression areas are closed to human use. If visitors are in the area theymay be affected by the sights and sounds of aircraft and fire retardant drops, but since these are transient and ofshort duration they are not likely to have any long-lasting effect on the visitor experience. Many people find these activities unusual and an enhancement to their experience, as they are not readily seen in other locations. Special Features

Fire retardant drops may adversely affect cultural resources, historic structures, and other features in wilderness. Effects include coloration, application damage, and small changes in nutrient loading. The long-term impacts are slight and are usually mitigated through the use of fire resource advisors during active fire events to choose areas to avoid. Cumulative Effects

The number and degree of current and projected fire retardant drops are not sufficient to have long-lasting effect on wilderness character.

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Wildland Fire Management Introduction

This section provides an overview of the affected environment for Wildland Fire Management, including specific resource components that would be affected by the alternatives, to establish a baseline for analysis. Additionally, this section presents the basis for a comparison of the alternatives and describes the probable effects of each alternative on selected wildland fire management elements. The averages, estimates, and other information contained in this section and the project record are derived from the most accurate, readily available data. Because this draft EIS is national in scope, the predicted impacts may vary by site-specific factors. Affected Environment Fire Regimes

Fire regimes characterize interactions between vegetation dynamics, fire spread, fire effects, and spatial context. They provide a basis for articulating the potential severity of fire and subsequent effects to vegetation and ecosystem processes. Fire regimes are intimately tied to climatic regimes, which in turn shape ecosystems. Climate also determines the distribution, frequency, and density of natural ignitions (generally from lightning), and the receptivity of fuels to natural and human-caused ignitions. Following are the fire regime groups as defined by the LANDFIRE project (Schmidt et al. 2002) and revised by Barrett et al. (2010). Table 16 'Proportion of total National Forest System acres (excluding Alaska and Puerto Rico) in each fire regime' includes the distribution of acres for National Forest System lands:

Historically, fire regime groups of the National Forest System conterminous landbase were dominated bylowand mixed severity (70 percent) with much less (18 percent) in replacement regimes.

Table 16 Proportion of total National Forest System acres (excluding Alaska and Puerto Rico) in each fire regime

Fire Regime Fire Regime Description Proportion of Total Acres Group

I 0-35 year frequency, low to mixed severity 41%

II 0-35 year frequency, replacement severity 8%

III 35-100+ year frequency, low to mixed severity 29%

IV 35-100+ year frequency, replacement severity 10%

V 200+ year frequency, low to replacement severity 10%

Ecological impacts are most often evaluated based on the difference between historic (pre-settlement) and current fire regimes. This approach assumes species evolved under the types of disturbances that resulted from thehistoric fire regimes and therefore are most resilient to disturbance regimes closest to those under which theyevolved.The greatest risks to species and habitats occur where current disturbances are much different than historical. Species that evolved under disturbance regimes that were primarily of frequent, low severity are more vulnerable to replacement disturbance than species that evolved within ecosystems with replacement regimes. While replacement

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fires likely occurred at some point in time within ecosystems dominated by low or mixed severity disturbances, current vegetative conditions have increased the frequency and extent of replacement fires in many areas, often resulting in undesirable effects on vegetation, habitats, soils, hydrologic regimes, and other ecosystem functions. Also, modern development and other types of land use have reduced or fragmented ecosystems, changing the way fire operates on the landscape and creating current fire regimes that are different than historic. In addition, non-native plant species have increased fire frequency and fire size by producing fuel beds that are more continuous and flammable than native fuel beds. Fire Occurrence

Wildland fire activity, as measured by acres impacted, had been increasingly consistently since the mid-1980s, but since the 2000 fire season, total wildfire acreage has been eclipsed by subsequent fire activity from 2004to2008. Most regions had more ignitions in 1986–1996 than in the 2000–2010 year timeframe. This difference represents the seasonal fluctuation in fire that occurs nationally, most often due to weather (Figure 4 'Number of Fires Nationally Reported from 1986 to 2009. Source: National Interagency Fire Center, Fire Information, Wildland Fire Statistics').

Figure 4 Number of Fires Nationally Reported from 1986 to 2009. Source: National Interagency Fire Center, Fire Information, Wildland Fire Statistics

The total number of fires for the 10-year period of 2000–2009 is 785,130, with a total of 69,313,271 acresburned throughout the United States (NIFC Fire Information Wildland Fire Statistics). Wildfire acres nationwide reached a new modern day record of 9.87 million in 2006 (Figure 5 'Total Acres Burned Nationally from 1986 to 2009. Source: National Interagency Fire Center, Fire Information, Wildland Fire Statistics'). In fact fire activity now is

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being compared in scale to the wildland fire seasons in the early 1900s that burned large acreages in the Westand Northern Midwest. The 10-year moving average has now almost doubled from 3.78 million wildfire acres in the 1990s to 6.93 million acres in the 2000–2009 period.

Figure 5 Total Acres Burned Nationally from 1986 to 2009. Source: National Interagency Fire Center, Fire Information, Wildland Fire Statistics

The continued threat of wildland fire equal to or greater than the past is being recognized and realized in the scientific and research community. Effects of climate change will certainly vary from year to year and from one geographical area to another, which will create uncertainty in the amount and location of wildfire acres. Risk levels will continue to increase because of growth of population and housing in the wildland-urban interface and intermix. Based on these realities, it is important to understand the magnitude of initial attack success as compared to large fire growth.

Nationwide, the average annual initial attack success rate is 95–98 percent, with the Forest Service 10-year average initial attack rate being 98 percent. Since 1999, there have been 242 recorded large wildfires in the United States exceeding 50,000 acres, compared to 119 in the previous 2 decades. These fires accounted for 18.9 million acres out of 40.5 million acres, or 46.7 percent of all wildfire acres reported for the period 2004–2008. Climate Change

Although there is confidence that temperatures are changing at a global scale, it is difficult to predict the effectof climate change at local and regional scales because the relationship between climate change, and fire frequency, and fire severity is linked to changes in fuel conditions rather than a change in temperature alone (Ballingetal. 1992, Hessl et al. 2004, Simard et al. 2011). Hessl et al. (2004) stated that even though fire occurrence and extent

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in the 20th century show a much weaker association with drought currently than historically, fire suppression and changes in land and human use of the landscape have contributed to current fuel levels that may have elevated average fire risk to a tipping-point where fire extentwill once again become sensitive to changes in climatic variability.

The greatest risks to biodiversity and species persistence are disturbance events that occur at a frequency, severity, duration, pattern, or spatial extent that fall outside the limits of adaptability (Noss 2001). Historically, ecosystems were subjected to disturbances; recurrent disturbances developed a range of variability and variation over time that represented stability. Currently, many ecosystems have been altered, degraded, or fragmented to a point where they lack adaptive mechanisms for stability. Therefore, additional stressors such as more frequent, severe, or extensive wildfire could contribute to a decline in ecosystem integrity (Millar et al. 2007, Opdam 2009, Scholze etal.2006). Threats from Wildfire

Fire has been a natural and integral part of ecosystems for thousands of years. Early in the 1900s, with rare exceptions such as the fires of 1910, wildfires on the landscape burned mostly in remote areas and without devastating and widespread effects on homes and citizens.

Population growth and urbanization have changed this situation, placing millions of citizens, homes, and entire communities in fire-prone environments. Previous decades of aggressive fire suppression have resulted in widespread, hazardous accumulations of flammable vegetation. These and other factors, such as increasing insect and disease mortality, create increasingly explosive and risk-laden conditions.

As these changes continue to evolve, as do the political landscape, public perceptions, fire science, fire costs, and budgeting.

The demand and expectation that land management agencies manage wildfire is ever present. The public is beginning to understand that fire has a role in the wildland; however, they do not expect that it needs to function initsnatural role in their “backyard."

The spread of homes into the wildland-urban interface (WUI) is a widely cited factor contributing to the recent increase in fire suppression costs. The tripling of new housing units between 1940 and 2000 has disproportionately occurred in non-metropolitan counties as suburbs and exurbs have attracted homeowners to the WUI (Hammer et al. 2009). By 2000, Hammer et al. (2009) estimate that in the 48 contiguous states, 38 percent of all housing units and 11 percent of all land area now fall within federally defined WUI areas. Housing growth in the WUI leadsto predictable losses of private homes. In terms of loss of all insured structures, the International Code Council (2008) suggests that between 2000 and 2007, 21,800 structures were lost to wildfires. These lost structures resulted in annual claims of $928 million, or about $340,000 per structure.

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Retardant drop in support of protecting the wildland urban interface.

Wildland firefighting is inherently risky. Nationally, wildland firefighter fatalities continue to occur atarateof approximately 20 per year over the past decade (U.S. Fire Administration report data). Aircraft accidents are among the leading causes of firefighting deaths (National Wildfire Coordinating Group 2007). Over the pastdecade, aviation fatalities averaged 3.7 per year (NWCG). Most of these fatalities have occurred on large wildland fires (National Wildfire Coordinating Group 2007, Large-Cost Fire Independent Review Panel 2009). Fire Management Decision-Making

To understand the role that long-term retardant plays in fire management strategies for all fires of all sizes, itis important to understand policy and decisionmaking standards. Aggressive initial response within a risk-based approach and within the objectives of land management plans is expected on all wildfires (WO 2010 Fire Season Expectations letter; 5/11/2010). Wildfires must have documented objectives for the protection of life and property with suppression strategies. Additionally, jurisdictions often have different missions and objectives, making it imperative that there is coordination and collaboration involving partners and neighbors. Therefore, every unplanned ignition receives an initial response and assessment to determine the appropriate management strategy(s).

The single most important factor in determining strategy is the risk to human life—firefighters and the public. The Forest Service’s first responsibility on every fire is to provide for firefighter and public safety (FSM 5100). Strategies can range from quickly suppressing the fire on initial attack to developing longer term suppression strategies that can simultaneously achieve land management plan objectives. In either of these cases and in examples in between, risk to responders and the public is always the primary consideration and must be within acceptable limits as determined by the responsible line officer.

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Fire strategies include direct, indirect, and flanking attack or point protection methods that contain the key elements of anchoring firelines to existing barriers, such as roads, creeks, burned areas or other natural breaks tocontainthe fire within a defined perimeter. Fire Retardant Operational Use

The use of aircraft (fixed and rotor wing) for the delivery of fire retardant is one of many suppression toolsused by fire managers. Retardant is delivered by airtankers, single engine airtankers (SEATS), and helicopters, andfills an essential link in the overall suppression strategy. The main principle in the use of aerially delivered retardant is to use it early in sufficient quantity, dropped from an effective altitude with absolute minimum time lapse between drops.

Retardant application to build fireline.

Retardant is normally stored and mixed at an airtanker base, or in some instances, on site near a fire incident (Figure 6 'National Federal Large Airtanker, MAFFS, SEAT, and Helitanker Bases, May 24 2004.' Containment and treatment systems are required for retardant loading pits, mixing and pump areas, storage tanks, areas where retardant deliveries are received, aircraft maintenance areas, and where loaded airtankers are staged for dispatch (National Interagency Aviation Council 2009). When retardant is mixed at the incident site (portable retardant base), precautions include establishing reload sites to manage retardant in portable tanks (National Interagency Fire Center 2007b ).

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Figure 6 National Federal Large Airtanker, MAFFS, SEAT, and Helitanker Bases, May 24 2004.

Airtanker types are distinguished by their retardant load: (PMS 410-1 Fireline Handbook):

Type 1 – 3,000 gallons Type 2 – 1,800–2,999 gallons Type 3 – 800–1,799 gallons Type 4 – 799 gallons (SEATS)

Helicopters can deliver retardant either with a bucket (usually on a longline) or with a “fixed tank”—referred to as a “helitanker”. These are usually heavy lift or type 1 helicopters. Occasionally, type 2 helicopters will drop retardant, and on rare occasions, type 3 helicopters can do so. Supplying helicopters is the primary reason for setting up “portable retardant bases.” Helicopters are also distinguished by their loads:

Type 1 – 700–2,500 gallons Type 2 – 300–699 gallons Type 3 – 100–299 gallons

Helitankers (type 1) – have a fixed tank and carry a minimum of 1,100 gallons.

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Retardant aircraft are used in conjunction with other resources, most often in the building and holding of firelines. Retardant is most effective with support from ground resources, but can be used to hold a fire for long duration or even stop the fire if the overall conditions favor this.

Retardant application in conjunction with ground resources.

Incident commanders, fire managers, and line officers evaluate the appropriate response of retardant aircraftto ensure that their use will be effective in meeting incident strategies, is the right tool for the job, and that the exposure is commensurate with the values being protected. There are only 18 large airtankers under contract by the U.S. Forest Service, and not every incident can take advantage of them when there is competition. Fire leadership prioritizes type 1 and 2 incidents daily to ensure large airtankers and other national shared resources are provided to incidents with the highest priority needs. Once an airtanker is assigned to an incident, there is no guarantee how long it will remain on that incident, as during busy times, higher priorities can arise, and the tanker can be diverted accordingly.

Fire managers frequently use retardant to stabilize small remote fires (type 4–5 incidents) before they mature into larger, long duration incidents. Retardant aircraft are vital to extended attack fires (type 3) for high values at risk including urban interface areas where typically the resistance to control is high and firefighters are at most risk. Airtankers are also essential to support the missions of type 1 and 2 incident management teams (IMTs). These incidents are at a scale of complexity and responsibility on the incident management team and responsible line officer that often extend from urban interface to wilderness areas.

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Retardant application to assist in minimizing fire spread.

Fire statistics have been maintained for many years and are a key factor in the distribution of airtankers and other aerial resources during the year. Potential weather events are taken into consideration, as well as fuel moisture indices and whether there are multiple geographic areas experiencing high fire activity. In evaluating fire statistics and fire history, the number of fires successfully controlled at the initial and extended attack stages averages95–98 percent nationwide.

As noted earlier, the 2006 fire season had record-breaking acres burned, totaling 9.87 million, with approximately 31.6 million gallons of retardant applied, covering roughly 26,600 acres or less than 0.003 percent of the 9.87 million acres affected by wildland fires (U.S. Forest Service 2006).

Data derived from Aviation Business System indicates approximately 90 million gallons of retardant (approximately 36,148 drops) were aerially applied to NFS lands in the 2000–2010 decade. It is estimated that the average annual acres of NFS lands that have retardant applied is between 2,358 and 4,715 acres annually, which is approximately 0.002 percent of the total NFS landbase annually. Forest Service Regions 3, 5, and 6 apply higher amounts of retardant compared to other regions (Figure 7 'Gallons of Aerially Applied Fire Retardant by Forest Service Region, 2000–2010.' and Figure 8 'Number of Fire Retardant Drops by Forest Service Region, 2000–2010.'). Please refer to Appendix C for retardant use nationally and by individual forest.

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Figure 7 Gallons of Aerially Applied Fire Retardant by Forest Service Region, 2000–2010.

Figure 8 Number of Fire Retardant Drops by Forest Service Region, 2000–2010.

Applying Retardant

Fuel is one of the three necessary elements for fire (fuel, oxygen, and heat) that can be significantly affected by fire chemicals. Fire retardants interact with fuel and work by fuel coating, fuel combustion modification, andfuel cooling.

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Retardant applications are based on a number of factors, including fuel type, application rates, delivery systems, effectiveness of on-scene resources, winds, proximity to sensitive areas, and other firefighting tactics. Retardant coverage level is a unit of measure used to describe the thickness of retardant on the ground and is expressed in gallons per 100 square feet (gpc). Application rates range between 1 and 8 gpc with the majority of applications between 4 and 8 gpc (Johnson 2010). Usually, the width and length of a retardant drop swath varies based on the type of aircraft used for delivery, drop height, and surface wind speeds and direction. An average drop is 50 to 75 ft wide by up to 800 ft long. Depending on firefighting tactics, retardant drop width and length might be strung together, creating a continuous path of retardant on the ground or used to create a barrier in combination with other naturally occurring barriers to the advancement of fires (i.e., ridgetops, roads, waterways, old burn scars).There are general guidelines for coverage levels according to fuel type, and suggested coverage levels are intended to be used as starting points only. Feedback from crews on the ground is essential in determining the effectiveness of drops and whether the coverage should be lighter or heavier.

Fire scientists (Rothermel and Philpot 1974) used several fuelbed burn tests to develop a mathematical model to help predict retardant coverage levels (Table 17 'Coverage level, fuel models, and flow rate range for fire retardant drops'). The coverage levels range from 0.5 to greater than 8. This is translated into line-building capacity, which is the primary tactic for the potential stopping of an advancing fire.

Table 17 Coverage level, fuel models, and flow rate range for fire retardant drops

Coverage Fuel Models Flow Rate Range

Level NFDRS1 NFFL FB2 Description (gal/sec)

(gal/100ft2)

1 A,L,S 1 Annual Perennial Western Grasses, 100–150

Tundra

2 C 2 Conifer with Grass, Shortneedle Closed 151–250

H,R 8 Conifer, Summer Hardwood.

E,P,U 9 Longneedle Conifer, Fall Hardwood.

3 T 2 Sagebrush with Grass 251–400

N 3 Sawgrass

F 5 Intermediate Brush (green)

K 11 Light Slash

4 G 10 Shortneedle Conifer (heavy dead litter) 401–600

6 O 4 Southern Rough 601–800

F,Q 6 Intermed. Brush (cured), Black Spruce

Greater B,O 4 California Mixed Chaparral; High Greater than 800

Than 6 Pocosin

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Coverage Fuel Models Flow Rate Range

Level NFDRS1 NFFL FB2 Description (gal/sec)

(gal/100ft2)

J 12 Medium Slash

I 13 Heavy Slash

1. National Fire Danger Rating System Fuel Models 2. Northern Forest Fire Laboratory Fuel Models (Anderson 1982)

Retardant application at coverage level 2.

Long-Term Retardant—Background

Large fixed wing airtankers have played an increasingly important role in firefighting since the mid-1950s, when aircraft were first used to deliver retardant. Although research as early as the 1930s was done to looktowards improving the effectiveness of water as a forest fire extinguishing agent, use of retardants did not materialize until the 1950s.

Throughout this time, various chemical formulations have been used, but the focus over recent decades has been toward improving the formulation to be more environmentally friendly while maintaining or improving its current effectiveness.

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Fire retardant, which is approximately 85 percent water, slows the rate of fire spread by cooling and coating the fuels, robbing the fire of oxygen, and slowing the rate of fuel combustion with inorganic salts that change howthe fire burns. Retardant is typically applied to fuels in front of an advancing fire, not directly to thefire.When determined to be an appropriate suppression tactic, retardant may be applied to any type of landscape experiencing wildfire: from low-lying desert ecosystems through oak woodlands and into high alpine forests. Most retardantis applied in the Western United States; it is rarely used in the Northeast, and only occasionally in the Midwest. Retardant is periodically used in the Southeast, depending on the severity of the fire season.

Most retardant delivery occurs on ridge tops and adjacent to human-caused or natural fire breaks, such as roads, meadows, old fire scars, and rock outcrops. Occasionally, retardant is applied adjacent to aquatic environments that are being used as a natural fire break. Applying retardant adjacent to these human-caused or natural firebreaks enhances the effectiveness of fire breaks by widening the fire break, which is especially important when applying adjacent to aquatic environments. Retardant delivery to aquatic systems is limited because aquatic habitats are relatively small linear or polygon shapes and because pilots have been instructed to avoid known bodies of water and maintain communication with resource advisors, scouts, and others through the incident commander on a fire incident, as stated in Guidelines for Aerial Delivery of Retardant or Foam near Waterways (U.S. Forest Service et al. 2000). Retardant may also be applied if firefighters, public safety, or structures are threatened and theuseof retardant is expected to alleviate the threat.

Since fire retardant is another tool for fire managers to utilize, it is imperative that any product used meetsstringent requirements in order to ensure safety is met for equipment, people, and the environment. Current retardant formulations in use today are primarily inorganic fertilizers, the active compound being ammonia polyphosphates (USDA Forest Service Specification 5100-304c Long-Term Retardant, Wildland firefighting, June 1,2007 [amendments inserted into text May 17, 2010]). Although retardant is approximately 85 percent water, the ammonia compounds constitute about 60 to 90 percent of the remainder of the product. The other ingredients include thickeners, such as guar gum; suspending agents, such as clay; dyes; and corrosion inhibitors (Johnson and Sanders 1977; Pattle Delamore Partners 1996). The ammonia salt causes the solution to adhere to vegetation and other surfaces; this stickiness makes the solution effective in retarding the advance of fire (Johansen and Dieterich 1971). Corrosion inhibitors are needed to minimize the deterioration of retardant tank structures and aircraft, which contributes to flight safety (Raybould et al. 1995). Previous retardant formulas contained sodium ferrocyanide7 as a corrosion inhibitor. It was found that under certain conditions, sodium ferrocyanide poses greater toxicity to aquatic species and aquatic environments than retardant solutions without this agent.

A full understanding about how retardant chemical components interacted with various elements of the environment was generally lacking during early use of the materials (pre-1990s). Over the past two decades, wildland firefighting agencies have conducted more monitoring and review of the environmental and safety aspects of retardant use (Labat Environmental April 2007, Labat-Anderson 1994a, Carmichael 1992, Finger 1997, Krehbiel 1992, Van Meter and Hardy 1975). Due to fish kills that occurred when retardant containing sodium ferrocyanide accidentally entered streams and lakes during fire incidents (Carmichael 1992; Krehbiel 1992; Norris and others 1991), the Forest Service contracted with the Columbia Environmental Research Center (CERC) of the U.S. Geological Survey (USGS) to perform additional research on the chemical reaction of sodium ferrocyanide in water solutions exposed to ultraviolet radiation as it pertained to retardant use.

7 Sodium ferrocyanide is a complex cyanide in which cyanide ions are bound to metal ions, such a ferrous iron. The odorless, yellow powder has a slightly toxic hazard rating in Dangerous Properties of Industrial Materials (ERM-New England, Inc. 1987). It has low toxicity to humans, and the Food and Drug Administration has approved it for use as an anti-caking agent in table salt (Food and Drug Administration 2000).

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The CERC report (Little and Calfee 2000) spurred a review of procedures used by the Forest Service, Bureau of Land Management (BLM), National Park Service (NPS), and Fish and Wildlife Service (FWS) during aerial firefighting. As a result of these studies, the Guidelines for Aerial Delivery of Retardant or Foam near Waterways (U.S. Forest Service et al. 2000) were established as interim guidelines in April 2000. Due to the potential increased toxicity, the Forest Service has not accepted for contract or purchased retardants that contain sodium ferrocyanide since 2005 (U.S. Forest Service 2000, 2002). The Forest Service has discontinued the use of retardants containing sodium ferrocyanide since the 2007 fire season.

Besides the ongoing work with outside agencies and environmental entities, the Forest Service’s wildland fire chemical program includes a specification review and revision process. This is applied to all categories ofwildland fire chemicals. The current specification was established in 2007 and includes the move away from productsthat contain ammonia sulfate salts to products with inorganic phosphate salts only. Products with inorganic phosphate salts reduce the level of ammonia from 3.1 percent to 2.2 percent, an overall reduction of 33 percent ammonia content in the retardants. This change not only decreases the toxicity to aquatic organisms, it also provides for increased effectiveness on both flaming and flowing combustion and decreased corrosion to magnesium andsteel.

The evaluation process for any product is funded by the company that is seeking to have a product on the qualified products list (QPL). The Forest Service does not use any wildland fire chemical that has not been through the evaluation and placed on the QPL. The Forest Service establishes formal national retardant contracts in order to ensure that only products on the QPL are purchased and applied to Forest Service lands. These contracts are also used by other Federal and land management agencies through their authorities and policies.

The specification includes requirements for effectiveness, safety and environmental protection, materials protection, stability, and physical properties. The Forest Service developed unique test methods or identified standard test methods for each requirement in the evaluation process.

Burn test of retardant during the evaluation process.

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All of the requirements are important and necessary; however, the effectiveness of retardant has been questioned over time. Studies have been conducted surrounding the effectiveness and the delivery of retardant (Gimenez et al. 2004; Plucinski et al. 2007; USDA Forest Service Standard Burn Test.) Data show that long-term retardant applications show a reduction in fire spread and intensity of about 39 to 45 percent, when compared to water,when the fuels are still wet from application. When the water has evaporated off, the fuels treated with retardant still show a reduction in spread and intensity of 0.53 to 0.57, or a reduction of greater than 50 percent compared to untreated fuels. Data for water-treated fuels show no reduction in spread or intensity (0 reduction factor) after they are dried. (USDA Forest Service Standard Burn Test) Current Implementation of the 2000 Guidelines

The Forest Service is currently operating under the 2000 Guidelines for Aerial Delivery of Retardant Or Foam Near Waterways (Appendix A). These guidelines allow the application of retardant to national forest lands but prohibit their use within a 300-foot buffer of a waterway (and in water), but with exceptions. The reasonable and prudent alternatives (RPAs) adopted by the Forest Service as a result of consultation with the U.S. Fish and Wildlife Service and NOAA Fisheries in 2007 and 2008 restrict the use of aerially applied retardant within the habitat of threatened and endangered species identified through the regulatory agencies process and listed in their biological opinions.

The Forest Service implemented the RPAs through direction to the field in March of 2008, as well as instructing the field that the 2000 Guidelines were to be applied. One of the aspects of this new direction resulted intheforests that had identified listed species within their boundaries to develop maps or provide direction to firefighting resources. The forests are now required to brief the incident commander(s)(IC) where limitations exist in the use of aerially applied fire retardant. The agency administrator/IC does still have the ability to invoke the exceptions under the 2000 Guidelines, if needed. In addition, the agency administrator incorporates any restrictions for the use of retardant in the delegation of authority letter given to the IC.

If retardant is applied within the waterway buffer or habitat of an identified T&E species, reporting is mandatory and formal consultation may be necessary. In addition, depending on the effects to species, monitoring may be required.

Fire operations adjusted tactics in 2000 as part of the development of the 2000 Guidelines. In addition, forests worked with ICs to provide appropriate guidance of where to avoid the use of retardant, and direction was sent to aviation resources so they were aware of the requirements. Policy, manuals, handbooks, and training materials have all been updated to include the 2000 Guidelines and the T&E species habitat limitations.

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Retardant application to assist in the protection of property.

The upward reporting requirements were formalized as a direct impact from the acceptance of the RPAs. This also included the need to report where retardant was misapplied to the habitat of a T&E species. Since the implementation of the 2000 Guidelines and the addition of the RPAs in 2008, 48 reports have been submitted (40 from 2008 to 2010) with four citing exceptions to the guidelines. Environmental Consequences Alternative 1—No Action Direct and Indirect Effects

Under this alternative, there would be no long-term retardant aerially delivered on National Forest System Lands. Ground-based application of retardant, foams, water enhancers (gels), and water (including aerial application of water only) would continue to be available for use by ICs as suppression tools. This alternative would not prohibit the aerial application of fire retardant on lands owned or administered by State, private, or other Federal entities.

Removing fire retardant as a fire suppression tool through aerial application will significantly reduce theoverall effectiveness of aerial resources. Retardant has been shown to be 40–50 percent more effective than plain water in reducing fire spread and intensity (USDA Forest Service Standard Burn Test). Water does not have the“staying power” of retardant on the vegetation, as it evaporates very quickly, having little or no effect in slowing the rate

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of spread or spotting potential on a fire under conditions of low relative humidity and high temperatures. Aerial resources would continue to be used, although they would deliver water only to assist with the tactics for managing the fire.

Reduced effectiveness of aerial resources will place firefighters in more hazardous situations where they are requiring assistance from aerial resources. With reduced effectiveness, firefighters may not be able to tactically engage on the ground in perimeter control or direct attack as in the past due to this limitation. The effect of this would cause firefighters to choose a more ground defensible barrier (natural or man-made) of some sort, which raisesthe probability of more acres burned.

Retardant is primarily an initial attack (IA) tool used to slow the rate of spread until adequate ground resources can arrive. Due to water's decreased residence time and effectiveness in checking fire spread, the fire size may be greater by the time ground resources arrive. The use of retardant in assisting in the control of small fires in steep terrain and poor access would be lost as well. Competition for increased number of drops on a fire may limit the number of fires that typically receive aerial support in the initial stages. The result could be larger fire sizes atcontainment and more fires progressing to extended, long-term, or large fire status. This could be most notable forunitsthat utilize single engine air tankers (SEATs) as a standard aspect of their normal IA response (common practice in rangeland fuel types). In addition, without the use of retardant (which buys firefighters time), the prepositioning of both aerial and ground resources in close proximity to high fire danger areas will become even more critical than usual. The current Forest Service 10-year initial attack success rate is approximately 98 percent, which would be expected to decrease under this alternative.

Fire retardant is used to provide additional safety to firefighters during suppression actions. In rare occasions, the retarding properties of the retardant also allow for the pre-treatment of areas prior to the ignition of prescribed fires. Land managers might also use this tactic if a prescribed fire is near the wildland urban interface and can provide additional firebreak protection. Firefighters are also taught to request retardant drops if they are in ahazardous situation such as a last resort survival. Over the past decades, retardant was used to provide firefighters time and support during entrapments.

The result of using only water instead of the more effective retardant in aerial delivery will result in ground firefighters requiring more loads of water delivered to assist with perimeter management on the ground. Thiswould result in more exposure for flight crews of both fixed wing and rotor wing aircraft. The 10-year average annual flight hours for large airtankers is 5,831; for SEATs it is 845 hours, and for helicopters it is 39,928 hours. Helicopters have the higher frequency rate for accidents over this 10-year period, an average of 2.9 accidents per year. Increased aircraft operations could lead to a much higher probability for additional accidents simply due to increased flight hours. This could also mean more aircraft working in a confined airspace, which again constitutes more exposure and potential for mishap. Additional water dropping aircraft (helicopters, airtankers, SEATs, and scoopers) would be in demand to make up for the lack of long-term retardant capability. However, the availability of aircraft in certain categories (types 1, 2, and 3 helicopters; large airtankers; and water scoopers) has been declining in recent years, which can compromise any potential for minimizing the impacts. In addition, additional aerial supervision aircraft would be necessary to coordinate the increase in tactical aircraft along with additional personnel (such as aircraft managers, aerial supervisors, dispatchers, and aircraft support personnel). All these factors, plus the higher use rates associated with call-when-needed/rental aircraft, will contribute to higher overall aviation and fire costs.

There will be a demand for additional ground suppression resources, including engines, crews, helitack, dozers, and smokejumpers in order to mitigate initial attack capability lost with the elimination of long-term retardant, thus significantly increasing ground crew exposure to hazards and risks from the fire environment.

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The removal of a critical resource that has normally been available could be perceived by the firefighters as placing them at a higher risk. A lowered probability of success for tactical actions could be expected in areas accustomed to fixed wing delivery of retardant on initial attack. Areas that have traditionally depended more on water delivered from rotor wing aircraft may not have the same issue.

If the Forest Service is the only agency to discontinue the use of retardant, and other Federal, State and private agencies decide to continue the use of retardant, the result could be strained relationships with partners and cooperators, due to the cooperative, interagency nature of fire management today, by creating such an inconsistency of air operations standards and guides. Assuming the other agencies continue the use of retardant, there is potential for increased confusion among ground firefighting resources, which can compromise their safety as well asthe safety of aerial resources.

In addition, States are usually mandated by State law to suppress all fires at the smallest possible size. If the Forest Service has lost the capability of using retardant and a fire spreads to lands protected by State jurisdiction, the potential impact to the relationships between the agencies and cooperators is great. The impact would be particularly great if a post-incident review finds that retardant would have assisted in reducing the rate of spread and allowed the Forest Service to contain the fire within their jurisdictional boundary.

Over the past 50 years, aerially delivered retardant has become one of the most important tactical tools for wildland firefighters and has set the stage for public expectations. In fire-prone areas, the public expects anddeservesour best efforts with equipment, technology, and effective and efficient decisionmaking to protect their natural resources, property, and in some cases the lives of both the public and firefighters. Eliminating one of the most important firefighting tools will likely have consequences when critical natural resources, watersheds, or private propertyare in imminent threat of being affected and where there is the perception that retardant could have had a positive effect on the outcome. A worst-case outcome with this alternative is that it could place the Forest Service in a position where circumstances result in increased exposure and confusion, contributing to the fatality of a firefighter or a member of the public. Fires can and have caused mass casualties to the public and firefighters. Cumulative Effects

In dealing with wildland fires, especially in the WUI, there is always a concern that exposure to smoke andsmoke particulate levels will be exceeded. In some cases, inversion layers created by specific geographic and atmospheric conditions can trap great volumes of smoke in an airshed for days, and smoke from numerous fires can cloud over an entire area for days. This has occurred in previous years when extensive lightning storms hit a geographic area. Increasing the potential for larger, longer term fires due to the limitations of using fire retardant could create this type of situation without the same level of lightning activity.

Backing away from known effective control barriers and anchor points that were used in conjunction with the use of retardant, and using less desirable countermeasures (using indirect attack tactics and strategies) would likely increase the area burned. During significant fire events with dense smoke plumes, safety impacts from decreased visibility can also be an issue, which can be a direct result from limiting initial attack tactics if fire retardant cannot be utilized.

In summary, the loss of both natural resources and private property would significantly increase under Alternative 1. Because of the difference in the effectiveness of water compared to retardant on fire behavior there would be:

Greater risk of small fires getting large and moving into populated areas;

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Potential increase in loss of public infrastructure, including utilities corridors, communication sites, and transportation systems; Increase in the cost of fighting fires; and Inconsistencies between agency fire policies if the Forest Service is the only agency that does notusefire retardant to fight fires, which puts both firefighters and the public at greater risk. Alternative 2—Proposed Action Direct and Indirect Effects

Because the Forest Service will continue to use retardant under this alternative as it has done in the past, it is expected that initial attack success will maintain the same success rate that has been stable for many years (98 percent average).

Exposure and risk considerations would remain the same as over the last decade relative to retardant. Considering there would be no significant changes in policies and guidelines for using aerially delivered retardant, itisnot foreseen that there would be any change in political sensitivities or issues regarding retardant. There would be no new issues created with regard to cooperators and partners.

Aerially delivered retardant would still have the potential to be applied adjacent to waterways, within the 300-foot buffer, and in the habitat of TESPC species, as identified, which requires reporting and potential initiation of emergency consultation pursuant to regulations at 50 CFR 402.05 implementing section 7 of the Endangered Species Act of 1973, as amended. As part of the emergency consultation, the Forest Service may need to conduct monitoring, which could include measures to prevent or compensate for population declines due to the application of fire retardant. For areas where aerially applied fire retardant was applied to terrestrial plants and has caused an increase in invasive species, there is the potential to have to remove all non-native plant species from the area.

The implementation of monitoring establishes another level of training and the potential for additional resources, both personnel and funding, in order to mitigate the impacts of using retardant. Due to this, additional emphasis has been placed on the appropriate use of retardant in initial attack responses as well as large fires. The decision of what firefighting tactics to use to best meet the desired outcomes are what drive the use of various firefighting resources, and these may include the use of fire retardant.

Through fire operations planning, initial attack priorities are established with the appropriate firefighting resources being assigned. If fires escape initial attack, a risk-informed initial strategy that considers exposure toincident responders, values-at-risk, stakeholder engagement, and impacts on the lands is developed. This risk assessment would include any potential limitations to the use of retardant due to waterways or presence of TESPC species. This further refines the tactics used in response, which can contribute to minimizing the potential for accidental application of retardant.

It is expected, however, as a direct effect of continuing to use the 2000 Guidelines and the RPA requirements, that there will continue to be misapplications of aerially delivered retardant in waterways and TESPC species habitat. Cumulative Effects

Because there would be no change from current protocols, no additional cumulative effects have been identified.

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Alternative 3 Direct and Indirect Effects

In general, this alternative will be similar to Alternative 2. The change to the exceptions from the 2000 Guidelines to only allowing for exceptions for the protection of life or safety (public and firefighter) could have an impact on the potential loss of private and public property, loss of infrastructure investments within national forests, and fire spread to large communities. Careful consideration will need to take place in the event that retardant may be the only option to protect an investment of public property or property that, if lost, could have an effect on huge population centers (e.g., communication towers) when agency administrators are developing direction for incident commanders, regardless of the management strategy. There could be an increase to the mapping requirement and the consultation needed in the beginning as well as throughout the process. The avoidance area mapping for TEPCS could result in more area that is required to be avoided for retardant application. This means consultations with local regulatory agencies, forest or unit biologists, agency administrators, and Fire and Aviation Management would be completed prior to the fire season.

Preseason readiness reviews will need to incorporate this requirement, include it in preplanned dispatch initial attack response strategies, cooperator agreements, and any meetings where response to fires is a topic. These venues will provide direct forms of communicating the intent of these guidelines and provide a standard practice of reviewing the maps annually to ensure they contain the most up to date avoidance areas.

National standards (a template) for mapping avoidance areas will require coordination annually at sub geographic levels. Firefighters, aviators, and cooperators will be required to understand the tactical limitations ofretardant within the pre-identified avoidance areas.

Fire retardant cannot be used to anchor fires into water ways, steep terrain, or areas of limited accessibility iflocated within pre-indentified avoidance areas. This could lower the probability of success for areas accustomed tofixed wing retardant assistance in initial attack under high fire danger conditions. This could result in a slight decrease in the initial attack success rate in those areas.

The potential for larger, longer duration fires translates to increased exposure to risks for firefighters, aerial resources, and the public. This increase is potentially slightly greater than Alternative 2 but much less than Alternative 1.

Firefighter and public safety is always the first and highest priority in fighting fires (FSM 5100). Theintroduction of potentially increased restrictions relative to where retardant can be applied has the potential to introduce an unintended consequence to safety. Firefighting training, direction, and requirements are for the most part standardized across all Federal wildland firefighting agencies and most States. Implementing a potentially more complex mapping system for ground and aerial resources only on Forest Service fires could lead to confusion and inconsistencies with partners and cooperators. Changes in protection priorities and protocols between the Forest Service and cooperators has the potential to cause confusion for incident commanders and agency administrators when developing intent and priorities, particularly under unified command situations. This could increase risks to some extent.

If significant additional areas are identified as avoidance areas, the overarching benefit of fire retardant wouldbe lost within those areas, potentially increasing the demand for additional ground firefighting and aerial resources in order to mitigate this impact. This could lead to increased exposure to ground resources and pilots, and a higher cost to fighting the fires.

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Limiting the aerial delivery of fire retardant could generate a perception that the Forest Service is not fightinga fire that requires aggressive action to manage the spread and minimize negative impacts fromthefire. Cumulative Effects

In dealing with wildland fires, especially in the wildland urban interface there is always a concern that exposure to smoke and smoke particulate levels will be exceeded. In some cases, inversion layers created by specific geographic and atmospheric conditions can trap great volumes of smoke in an airshed for days, and smoke from numerous fires can cloud over an entire area for days. This has occurred in previous years when extensive lightningstorms hit a geographic area. If the potential for larger, longer duration fires increases due to increased limitations of using fire retardant, it could create this type of situation with even less lightning activity, due to the possibility ofmore fires becoming large.

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Wildlife Species and Habitats Introduction

The Forest Service is responsible for managing diverse landscapes—from grasslands and high deserts to coniferous and deciduous forests and alpine mountaintops. These landscapes provide scenery, wildlife habitats, grazing, timber products, recreation, and other benefits. Under NEPA, Forest Service-proposed projects require analysis of impacts to federally listed threatened and endangered species under the Endangered Species Act, and U.S. Forest Service (FS) regional foresters’ sensitive wildlife species lists. Environmental effects have been analyzed on a nationwide, programmatic scale for all National Forest System (NFS) lands, comprising 193 million acres, covering 155 national forests across 9 regions.

The information on averages and estimates of acres and amounts of retardant use contained in this analysis is derived from the most accurate, readily available data on aerial application of fire retardant use (Appendix C). Quantifications are limited and vary because this analysis is national in scope; relative measurements (less, more, etc.) will be used for comparison of alternatives rather than actual acres since it is impossible to determine when, where, what habitat type, or how big of a wildland fire event will occur.

The endangered Quino checkerspot butterfly, which occurs only in Riverside and San Deigo counties, CA. Photo by J. Zylstra.

Affected Environment

This analysis focuses on federally listed threatened, endangered, and candidate species on NFS lands. Several hundred wildlife species listed as either threatened, endangered, or proposed (TEP) or candidate or sensitive (CS) occur on NFS lands (see Appendix I), in habitats ranging from arid and semi-arid to riparian, upland, forest, rocky areas, and many others.

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Terrestrial habitats include a variety of different ecoregions (Bailey 1995) as well as different wildlife and plant habitat groups. For most of this analysis, the ecoregions are used to determine effects on habitat types; however, because most of the data recorded for aerial retardant use are by national forest or Forest Service region, there may not be a direct correlation to ecoregion type on amounts used by eco-region of habitat type. Refer to Appendix C for a complete description and retardant application rates for each eco-region.

Another indirect correlation to ecoregion or to habitat is fuel model type. Firefighters integrate fuel models and fuel descriptions to determine the appropriate retardant coverage level. Fuel models are classified into four fuel complex groups that include grasses, brush, timber litter, and slash (Anderson 1982). The fire behavior relates to the fuel loading expressed in tons/acre and the fuel bed depth, which relates to the fuels distribution among the fuel size classes. Scott and Burgan (2005) further refined fuel models by including non-burnable fuel types (urban, ice, water, rock), and sub-grouping the fuel complexes by adding moisture climatic condition classes along with the fuel loading and distributions.

Thus, determination of the impacts on wildlife habitats may be better displayed by describing the habitat’s ecological function, rather than ecoregion type or fuel model type. This includes the following wildlife habitat types (Cooperrider et al. 1996):

Wetlands, tidal marshes, bogs, springs (with aquatic associated plant species); Riverine wash and riparian upland (those areas immediate adjacent to streams and waterways discussed under the aquatics section); Arid, semi-arid, or desert; Great Basin, Mojave, Sonoran, and Chihuahuan; Grasslands and meadows and pine-oak savannah; Brush or chaparral (including southern rough and pinyon-juniper-sage); Fossorial or subterranean; Forested (including hardwood, coniferous, and mixed forest as well as various seral stages of development and age groups); Rocky areas (including outcrops, talus, cliffs, and caves); and Arboreal (snags, poles, and other perch sites for birds) Environmental Consequences Methodology

This analysis focuses on the effects of the aerial application of fire retardant on terrestrial wildlife species and their habitats. The amount of fire retardant used depends on the vegetation type, fuel models, and also the ecoregion area in which the fire is occurring. Risks from using aerial application of fire retardant to wildlife include: direct application on individuals and habitat, disturbance to individuals, indirect ingestion through food and prey sources, and change in habitat characteristics due to changes in species composition from the fertilizing effects of the chemicals.

This EIS analyzes the impacts of using or not using the aerial application of fire retardant on wildlife habitat and species using the following indicators:

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Effects on endangered and threatened species, and proposed species and designated critical habitat under the Endangered Species Act (ESA) of 1976 and required consultation under Section 7 with the U.S. Fish and Wildlife Service. Effects on regional foresters’ sensitive species for all Forest Service regions. Screening Process

A draft Terrestrial Screening Process for Wildlife (refer to Appendix E) was developed to help with making effects determination calls for all the species and habitats, based on mobility, disturbance, effects to habitat, potential for use, distribution and size, and duration of event. The biological evaluation (a separate report in the project file) includes: threatened, endangered, or proposed wildlife species (TEP) and/or their designated critical habitats listed under the Endangered Species Act (ESA); and the several hundred Forest Service sensitive species (S), including candidate species (C) listed as part of the regional foresters’ sensitive species list for each of the Forest Service regions (Forest Service Manual 2670).

Similarly, a coarse filter screening process was developed for TEP species to determine the effects basedonthe potential use of aerial application of fire retardant on wildlife, plant, and aquatic species and habitats. ThoseTEP species with a ‘May Affect’ determination were then included further in the wildlife portion of the biological assessment (separate report in the project report) and consulted on under ESA Section 7 consultation with the U.S. Fish and Wildlife Service. All determinations made in this draft report should be considered preliminary and are subject to change between the issuance of the draft and final EIS.

Given the national scale of this project analysis and the existence of several hundred wildlife species listed as either threatened, endangered, or proposed (TEP) or candidate or sensitive (CS) on NFS lands, the analysis uses the following grouping process. Each group (major animal type such as mammal, bird, reptile, etc.) and subgroup (e.g., mammal—rodent, bats, etc.) of species is analyzed, rather than each individual species (refer to Appendix I). Detailed analysis for each species may occur as part of the national forest unit review for the regions to complete prior to the final EIS.

Additional peer review by species specialists, Forest Service regional TES coordinators, Forest level biologists, etc, is also anticipated and will be done as part of the individual forest-level review for input into the consultation process. The biological assessment and evaluation to be completed for the final EIS are also intended to be dynamic and will be amended with additional analyses, if necessary, when any of the following occur:

Additional species are brought under the protection of the ESA after the draft but before the final BA. Additional species are identified as sensitive by the Forest Service for the finalBE.

Due to the proposed aerial application of fire retardants at the national programmatic level, this report doesnot analyze those species requiring NEPA analysis and monitoring of proposed actions under the local land management plans (LMPs); including but not limited to: management indicator species (MIS), special status species for certain regions (such as ‘survey and manage species’ under the Northwest Forest Plan (1994/2001), or any other local species or habitats of concern that usually are incorporated at the local forest level or site-specific NEPA analysis. Those species with protection under the Migratory Bird Treaty Act, Bald Eagle and Golden Eagle Protection Act, or other agreements are analyzed in part by association with those species that are covered under the BE/BA; therefore, some species may not be covered. However, the effects on TEPCS species will serve as surrogates for all other wildlife species since most TEPCS species have habitats common to non-TEPCS species.

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Given the programmatic nature of this environmental analysis and that the Forest Service does not have a sense of when or where future aeiral fire retardant drops will hit the ground, other than based on the historic use ofretardant in the past 10 years, the specific effects resulting from the proposed action and its alternatives that may adversely affect threatened or endangered species and their associated critical habitats and that may impact sensitive species cannot be totally described. Instead, the Forest Service offers the following general discussion.

Fire retardant is used on less than 5 percent of all fire occurrences on NFS lands (T. Henderson, personal communication, 11/2010), usually in the initial attack stages to keep fires small or to protect property. Regardless of whether fire retardant is used, the following assumptions may be made concerning large wildland fires (Geier-Hayes 2011):

Large fires often burn for long durations over a variety of weather and fuel conditions that can producehigher fire severity effects over a greater area. Large fires have more potential to affect a greater proportion of the population of a species or their habitats at one time, particularly for endemics or species whose populations or habitats are limited in distribution or have been affected by fragmentations or changes in land use surrounding them. In areas with high levels of non-native plant species, large fires have the potential to increase the spread of non-natives that favor ground disturbances, thus may reduce the quality of habitat for native species.

In general, fire suppression chemicals do not cause harm to terrestrial wildlife, vegetation, and soils. Theammonium compounds used are considered to have minimal toxicological or ecological effects to terrestrial ecosystems; however, most research has been limited to effects on aquatic species. The analysis of the Ecological Risk Assessment: Wildland Fire-fighting Chemicals (Labat Environmental 2007) was prepared for the Forest Service for a number of chemicals used in retardants, including long-term fire retardants, foams, and water enhancers. The retardant salt is associated with risks to terrestrial species as far as lethal dosage tested for the many products formulated by current chemical retardant manufacturers (Labat Environmental 2007). Representative terrestrial species for mammals were: deer (large herbivore), coyote (carnivore), and deer mouse (omnivore, prey species); representative species for birds were: American kestrel (raptor), red-winged black bird (songbird), and bobwhite quail (ground nester). These species correlate to the subgroups used for mammals and birds in the biological assessment. Aquatic species included tadpoles of frogs or toads. Environmental Consequences Common to All Species Expected Direct Effects Common to All Species

Impacts from the use of long-term retardants are expected to be minor. Effects would be small in scale and should affect only a few individuals at a time, rather than the entire species population, except in the case of a small, endemic population. It is possible that terrestrial species with limited mobility could be affected directly by being hit by aerial applications of long-term retardant.

Another potential direct effect resulting from retardant drops is disturbance associated with low-flying aircraft that could stress animals; disrupt calving, rearing, or nesting; or displace animals to areas of less suitable habitat. Although short in duration, this activity does cause a change in behavior for any wildlife that may be present or within the vicinity of the retardant drops. This may affect an area up to ½-mile from an occupied site, a common accepted distance from raptor and bird nest for most species (northern spotted owl, marbled murrelet, and bald eagle in the Pacific Northwest). Even species with a moderate to high rate of mobility and ability toescapethe wildlife fire area and avoid direct drops of retardant on them (the action causing the disturbance is assumedtobe

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the wildland fire, not the aerial application), some species may still have an impact from the aircraft flyingoverhead or in the vicinity of the individual, if roosting or nesting in close proximity (within 1 mile) to fire suppression activities.

However, given the mobility of most species and their natural survival instinct to avoid a wildfire, direct application of retardants on wildlife species is expected to rarely occur. Instances where direct impacts from the application of retardant may occur more often is if nest trees or breeding sites are occupied at the time of the wildland fire incident or the mobility of the individual species is such that it cannot avoid the area of potential application.

Another possible direct effect to habitat is the breaking off of tree tops/vegetation by a low, fast drop of a large load (2,500 gallons). It is possible that retardant drops could adversely affect components of critical habitat (or required breeding and rearing habitat) either with a direct hit, thus covering vegetation, or by breaking vegetation for nesting, foraging, or perching.

However, the use of fire suppression chemicals is not likely to have a lasting effect on terrestrial ecosystems (Labat Environmental 2011). Since the long-term retardant is water soluble, most is expected to be dissipated and removed during the first wet weather events. Expected Indirect Effects Common to All Species

Impacts of long-term retardant use on the food and water resources of wildlife are likely to be short-term and localized, whereas the effects of uncontrolled wildfire potentially could have long-term adverse effects on thefood and water resources of the entire population. Indirect effects of the use of aerial application of fire retardant may include the coating or covering of vegetation and food sources consumed by species. Again, according to the assessment done by Labat Environmental (2007), ingestion of vegetation or insects by a species depends on the amount of retardant used (coverage by vegetation/ecoregion type), timing of ingestions after application, and ability of the animal to avoid feeding on chemicals. Given the feeding habitats of the species, some “prey burden” may be expected to occur in areas with high use or application rate of fire retardants: toxins ingested by prey species are ingested by the predator that eats that species. However, this is expected to take a long time and may not affect certain types of species in the long term. In the short term, an individual would have to consume excessive amounts of retardant in order to exceed the lethal dose for that species.

A potential risk exists if a sufficient portion of an individual’s diet or water source is contaminated; however, the entire population is not likely to be affected. If contamination of a food base occurs, it may cause avoidance of certain areas by an individual or group. This may have a short-term negative effect on some individuals of a species, but is unlikely to adversely affect the entire population over the long term (Labat Environmental 2007).

Additionally, since fire retardants are composed mostly of fertilizers, long-term use of these chemicals maybenefit some wildlife because of increased tree, plant, and grass (seed) growth. Conversely, if non-native plant species are present in the same area, these species may out-compete native vegetation and may cause a short- and long-term negative impact if not controlled. Additionally, Alternatives 2 and 3 may prevent wildfires from becoming larger and consuming the critical habitat for a listed species. Beneficial effects may include the protection of habitat from burning by the prevention of large scale, stand replacing events. In either case, the effects of an uncontrolled wildfire have a longer term negative effect than retardant use, due to the potential for eliminating habitat and food sources for a species for the lifespan of that species, depending on the severity, duration, and size of the fire.

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The use of proposed avoidance mapping may help to minimize direct and indirect impacts caused by disturbance from the aerial delivery of fire retardant in the vicinity of those TESPC species populations that could be affected during a critical period of their life cycle, such as nesting, if the predominate fire season coincides with this life-cycle period. Expected Cumulative Effects Common to All Species

Direct and indirect impacts from Alternatives 2 and 3 are not expected to impede the long-term recovery of a species or the conservation value of its critical habitat. Implementation of the proposed action would allow essential features of critical habitat to remain functional because long-term retardants are not likely to have lasting effects on terrestrial ecosystems. For species that are wide-ranging and have larger populations, the use of an aerial application retardant drop on a specific fire would occur only on a very small portion or fraction of a population instead ofthewhole population; therefore, cumulative effects would be very minor. As shown in most of the analysis for wildlife, aerial fire retardant use is a short-term effect. Additionally, the proposed action is expected to prevent wildfiresfrom becoming potentially larger and consuming most or all of the critical habitat for a species. Lastly, the mitigation measures of avoidance mapping for habitat and populations, the establishing of trigger points for restricting the use of retardants within watersheds where retardant has caused adverse affects to a species or population, and the yearly pre-season coordination should all help in reducing impacts to species and habitats.

Overall, risks to terrestrial species are expected to be minor. These risks are small in scale and are not likely to affect more than a few individuals or a portion of a population at a time. The use of long-term retardants is not likely to have a lasting effect on the species. Comparison of Alternatives Alternative 1—No Action

Under this alternative, the use of aerial application of fire retardants would not occur. Because aerial application would not occur, there would be no direct, indirect, or cumulative impacts to wildlife species or habitats from this alternative; conditions for all wildlife species and habitats would remain the same as if no aerial application activities were used during fire suppression activities under this alternative. Alternative 2—Proposed Action

Under this alternative, the use of aerial application of fire retardants would continue with no change from the current practice. The 2000 Guidelines with the three exceptions, plus the 2008 reasonable and prudent alternatives, would be implemented and would provide protection for waterways and some terrestrial areas for some of the listed threatened and endangered species, but would not provide protection for any of the Forest Service listed sensitive terrestrial species that may be affected by aerial application of fire retardant.

In addition to the stated effects common to all species in the previous section, this alternative would provide less protection for Forest Service sensitive species in the form of avoidance areas than it does for federally listed threatened or endangered species

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Alternative 3

Under this alternative, the use of aerial application of only fire retardants would continue. This alternative still incorporates the 2000 Guidelines for waterways with the 2008 FWS/NMFS reasonable and prudent alternatives that would provide protection for some terrestrial areas. However, this alternative proposes additional protection for those Forest Service sensitive terrestrial species that may be trending toward listing under the ESA. Also, only one exception to the guidelines, use of retardant for protection of human life and safety, is allowed under this alternative. Thus, Alternative 3 would be expected to have less of an impact to habitat and species than Alternative 2, which allows for three exceptions to the guidelines.

Because this alternative proposes more avoidance area protections for Forest Service sensitive species, it is expected to have less of an impact on some wildlife species and habitats than Alternative 2.

Finally, this alternative proposes monitoring of areas were retardant drops have been used within a watershed to determine if impacts on terrestrial wildlife are exceeding some threshold established for a given species. If exceeded, then the use of aerial application of fire retardant may be restricted for a given time frame until the species/habitat has recovered. Therefore, Alternative 3 provides more protections and fewer impacts than Alternative 2.

Table 18 'Comparison of Effects of the Alternatives on Wildlife Species and Habitats' is a comparison of the potential effects of the three alternatives on wildlife species and habitats.

Table 18 Comparison of Effects of the Alternatives on Wildlife Species and Habitats

Effect Indicator Alternative 1 Alternative 2 Alternative 3

Aerial Application of Use No Yes Yes Retardant

Impacts to species/habitat Relative none More than Alt 3 expected due Less than Alt 2 expected due to to fewer protections in place more protections in place amount

Impacts to Federally Listed # species and 0 More than Alt 3 because of Less than Alt 2 because of only species critical habitats three exceptions leading to one exception for life safety, and impacted retardant use in waterways and additional avoidance areas habitat designations for certain candidate and sensitive species

Impacts to Forest Service # species 0 More than Alt 3 because of Less than Alt 2 because of only Sensitive Species impacted three exceptions leading to one exception for life safety, and retardant use in waterways and additional avoidance areas habitat designations for certain candidate and sensitive species

Direct Impacts Relative None More than Alt 3 due to fewer Less than Alt 2 due to proposed proposed protections additional protections amount

Indirect Impacts Relative none More than Alt 3 due to fewer Less than Alt 2 due to more protections protections

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Effect Indicator Alternative 1 Alternative 2 Alternative 3

amount

Cumulative Impacts Relative none More than Alt 3 due to fewer Less than Alt 2 due to more protections protections amount

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Chapter 4. Consultation Preparers and Contributors Distribution of the Draft Environmental Impact Statement

This draft programmatic environmental impact statement has been distributed to the following Federal, State, and local governments and Tribal agencies; organizations and businesses, and individuals who, through their comments, have contributed to the preparation of this programmatic draft environmental impact statement. Agencies

Susan E. Bromm — Environmental Protection Agency Joe Carriero — USDI National Park Service Roy Irwin — USDI National Park Service Thomas Crews — USDI Fish and Wildlife Service Jeff Ulrich — USDA Forest Service Tribes

Absentee-Shawnee Tribe of Indians of OK Agua Caliente Band of Cahuilla Indians

Ak-Chin Indian Community Council Alabama-Coushatta Tribes of Texas

Alabama-Quassarte Tribal Town Alturas Rancheria

Apache Tribe of Oklahoma Arapaho Tribe of Wind River

Aroostook Band of Micmacs Assiniboine and Sioux Tribes of Fort Peck

Augustine Band of Mission Indians Bad River Band of Lake Superior Chippewa

Barona Band of Mission Indians Battle Mountain Band Council

Bay Mills Indian Community Bear River Band of Rohnerville Rancheria

Berry Creek Rancheria BIA Fort Yuma Agency

Big Lagoon Rancheria Big Pine Paiute Tribe of the Owens Valley

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Big Sandy Rancheria Band of Western Mono Indians Big Valley Rancheria

Blackfeet Tribal Business Council Blue Lake Rancheria

Bodaway/Gap Navajo Chapter Bridgeport Indian Colony

Buena Vista Rancheria Burns Paiute Tribe, General Council

Cabazon Tribal Business Committee Cachil DeHe Band of Wintun Indians

Caddo Nation of Oklahoma Cahto Tribal Executive Committee

Cahuilla Band of Mission Indians National Forest California Valley Miwok Tribe System Land Management Planning Cameron Navajo Chapter Campo Band of Diegueno

Capitan Grande Band of Diegueno Mission Indians Carson Community Council

Catawba Indian Nation Cayuga Nation

Cedarville Rancheria Chemehuevi Tribe

Cher-Ae Heights Indian Community Cherokee Nation

Cheyenne River Sioux Tribe Cheyenne-Arapaho Tribes of Oklahoma

Chickasaw Nation Chicken Ranch Rancheria

Chippewa Cree Business Committee Chitimacha Tribe of Louisiana

Choctaw Nation of Oklahoma Citizen Potawatomi Nation

Cloverdale Rancheria Cocopah Tribal Council

Coeur d'Alene Tribal Council Cold Springs Rancheria

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Colorado River Tribal Council Comanche Nation

Confederated Salish & Kootenai Tribes Confederated Tribes and Bands of the Yakama Nation

Confederated Tribes of Colville Confederated Tribes of Coos, Lower Umpqua and Siuslaw Indians Confederated Tribes of Siletz Indians of Oregon Confederated Tribes of the Chehalis Reservation

Confederated Tribes of the Grand Ronde Confederated Tribes of the Umatilla Indian Reservation

Confederated Tribes of the Warm Springs Reservation, Coquille Indian Tribe Tribal Council Cortina Rancheria Coushatta Indian Tribe

Cow Creek Band of Umpqua Tribe of Indians Cowlitz Indian Tribe

Coyote Valley Reservation Crow Creek Sioux Tribal Council

Crow Tribal Council Death Valley Timbisha Shoshone Tribe

Delaware Nation Delaware Tribe of Indians of Oklahoma

Dry Creek Rancheria Duckwater Tribal Council

Eastern Band of Cherokee Indians Eastern Shawnee Tribe of Oklahoma

Elem Indian Colony Elk Valley Rancheria

Ely Shoshone Tribe Enterprise Rancheria

Ewiiaapaayp Band of Kumeyaay Indians Federated Indians of Graton Rancheria

Flandreau Santee Sioux Tribe Forest County Potawatomi Tribe

Fort Belknap Community Council Fort Bidwell Reservation

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Fort Independence Reservation Fort McDermitt Tribal Council

Fort McDowell Yavapai Tribal Fort Mojave Tribal Council

Fort Sill Apache Tribe of Oklahoma Gila River Indian Community Council

Goshute Indian Tribe Grand Traverse Band of Ottawa and Chippewa Indians

Greenville Rancheria Grindstone Rancheria

Guidiville Rancheria Habematolel Pomo of Upper Lake

Hannahville Indian Community Havasupai Tribal Council

Ho-Chunk Nation Hoh Indian Tribe

Hoopa Valley Tribal Council Hopi Tribal Council

Hopland Reservation Houlton Band of Maliseet Indians

Hualapai Tribal Council Inaja-Cosmit Reservation

Inter Tribal Council of Arizona Ione Band of Miwok Indians

Iowa Tribe of Kansas & Nebraska Iowa Tribe of Oklahoma

Jackson Rancheria Band of Miwuk Indians Jamestown S'Klallam Tribe of Indians

Jamul Indian Village Jena Band of Choctaw Indians

Jicarilla Apache Nation Kaibab Band of Paiute Indians

Kalispel Indian Community of the Kalispel Reservation Karuk Tribe of California

Kashia Band of Pomo Indians Kaw Nation National Forest System Land Management Planning

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Kialegee Tribal Town Kickapoo Traditional Tribe of Texas

Kickapoo Tribe in Kansas Kickapoo Tribe of Oklahoma

Kiowa Indian Tribe of Oklahoma Kootenai Tribal Council

La Jolla Band of Luiseno Indians La Posta Band of Mission Indians

Lac Courte Oreilles Band of Chippewa Indians Lac du Flambeau Band of Lake Superior Chippewa

Lac Vieux Desert Band of Lake Superior Chippewa Las Vegas Tribe of Paiute Indians Tribal Council Indians Leupp Navajo Chapter Little River Band of Ottawa Indians

Little Traverse Bay Bands of Odawa Indians Los Coyotes Reservation

Lovelock Tribal Council Lower Brule Sioux Tribal Council

Lower Elwha Tribal Council Lower Lake Rancheria KOI Nation

Lower Sioux Indian Community of Minnesota Lummi Indian Business Council

Lytton Rancheria Makah Indian Tribal Council

Manchester - Point Arena Band of Pomo Indians Manzanita Band of Mission Indians

Mashantucket Pequot Tribe Mashpee Wampanoag Tribal Council

Match-e-be-nash-she-wish Band of Pottawatomi Indians Mechoopda Indian Tribe of the Chico Rancheria of Michigan Menominee Indian Tribe of Wisconsin Mesa Grande Band of Mission Indians

Mescalero Apache Tribe Miami Tribe of Oklahoma

Miccosukee Indian Tribe Middletown Rancheria

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Minnesota Chippewa Tribe Mississippi Band of Choctaw Indians

Moapa Business Council Modoc Tribe of Oklahoma

Mohegan Indian Tribe Mooretown Rancheria

Morongo Band of Mission Indians Muckleshoot Tribal Council

Muscogee (Creek) Nation Narragansett Indian Tribe

Navajo Nation Nez Perce Indian Tribe

Nisqually Indian Community Council Nooksack Indian Tribal Council

Northern Cheyenne Tribe Northfork Rancheria

Northwestern Band of Shoshone Nation Nottawaseppi Huron Potawatomi, Inc.

Oglala Sioux Tribal Council Ohkay Owingeh Pueblo

Omaha Tribe of Nebraska Oneida Indian Nation

Oneida Tribe of Indians of Wisconsin Onondaga Indian Nation

Osage Nation Otoe-Missouria Tribe of Indians

Ottawa Tribe of Oklahoma Paiute Indian Tribe of Utah Tribal Council

Paiute-Shoshone Indians of the Bishop Community Paiute-Shoshone of the Lone Pine Reservation

Paiute-Shoshone Tribe of the Fallon Reservation Pala Band of Mission Indians

Paskenta Band of Nomlaki Indians Pasqua Yaqui Tribal Council

Passamaquoddy Tribe - Indian Township Pauma/Yuima Band of Mission Indians

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Pawnee Nation of Oklahoma Pechanga Band of Mission Indians

Penobscot Indian Nation Peoria Tribe of Indians of Oklahoma

Picayune Rancheria of Chukchansi Indians Pinoleville Reservation

Pit River Tribal Council Poarch Creek Indians

Pokagon Band of Potawatomi Indians Ponca Tribe of Indians of Oklahoma

Ponca Tribe of Nebraska Port Gamble S'Klallam Tribe

Potter Valley Rancheria Prairie Band of Potawatomi Nation

Prairie Island Indian Community Pueblo of Acoma

Pueblo of Cochiti Pueblo of Isleta

Pueblo of Jemez Pueblo of Laguna

Pueblo of Nambe Pueblo of Picuris

Pueblo of Pojoaque National Forest System Land Pueblo of San Felipe Management Planning Pueblo of San Ildefonso Pueblo of Sandia

Pueblo of Santa Ana Pueblo of Santa Clara

Pueblo of Santo Domingo Pueblo of Taos

Pueblo of Tesuque Pueblo of Zia

Pueblo of Zuni Puyallup Tribe of the Puyallup Reservation of the State of Washington Pyramid Lake Paiute Tribal Council Quapaw Tribal Business Committee

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Quartz Valley Indian Community Reservation Quechan Tribal Council

Quileute Tribe Quinault Indian Nation

Ramona Band of Cahuilla Red Cliff Band of Lake Superior Chippewa Indians of Wisconsin Red Lake Band of Chippewa Indians Redding Rancheria

Redwood Valley Reservation Reno-Sparks Tribal Council

Resighini Rancheria Rincon Band of Mission Indians

Robinson Rancheria Rosebud Sioux Tribal Council

Round Valley Reservation Sac & Fox Tribe of the Mississippi in Iowa

Sac and Fox Nation of Missouri Sac and Fox Nation of Oklahoma

Saginaw Chippewa Indian Tribe of Michigan Saint Croix Chippewa Indians of Wisconsin

Saint Regis Band of Mohawk Indians Salt River Pima-Maricopa Indian Council

Samish Indian Nation San Carlos Apache Tribal Council

San Juan Southern Paiute Council San Manuel Band of Mission Indians

San Pasqual Band of Diegueno Indians Santa Rosa Band of Mission Indians

Santa Rosa Rancheria Santa Ynez Band of Mission Indians

Santa Ysabel Band of Mission Indians (Iipay Nation) Santee Sioux Nation

Sauk-Suiattle Indian Tribe Sault Ste. Marie Tribe of Chippewa Indians of Michigan

Scotts Valley Rancheria Seminole Indian Tribe

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Seminole Nation of Oklahoma Seneca Nation of Indians

Seneca-Cayuga Tribe of Oklahoma Shakopee Mdewakanton Sioux Community of Minnesota Shawnee Tribe Sherwood Valley Rancheria

Shingle Springs Rancheria Shoalwater Bay Indian Tribe of the Shoalwater Bay Indian Reservation Shoshone Business Council Shoshone Fort Hall Business Council

Shoshone-Paiute Business Council Sisseton-Wahpeton Oyate

Skokomish Tribal Council Skull Valley Band of Goshute Indians

Smith River Rancheria Snoqualmie Tribe

Soboba Band of Luiseno Indians Sokaogon Chippewa Community

Southern Ute Tribe Spirit Lake Tribal Council

Squaxin Island Tribe Standing Rock Sioux Tribal Council

Standing Rock Sioux Tribal Council Stillaguamish Tribe of Indians

Stockbridge Munsee Community of Wisconsin Summit Lake Paiute Tribe

Suquamish Tribal Council Susanville Indian Rancheria

Swinomish Indian Tribal Community Sycuan Band of Mission Indians

Table Mountain Rancheria Te-Moak Tribe of Western Shoshone

The Klamath Tribes The Spokane Indian Tribe

The Tulalip Tribes Thlopthlocco Tribal Town

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Three Affiliated Tribes Business Council Tohono O'odham Nation

Tonawanda Band of Seneca Tonkawa Tribe of Indians of Oklahoma

Tonto Apache Tribal Council Torres-Martinez Desert Cahuilla Indians

Tule River Reservation Tunica-Biloxi Tribe

Tuolumne Rancheria Turtle Mountain Band of Chippewa

Tuscarora Nation Twenty-Nine Palms Band of Mission Indians National Forest System Land Management Planning United Auburn Indian Community

United Keetoowah Band of Cherokee Indians Upper Sioux Community of Minnesota

Upper Skagit Tribal Council Ute Indian Tribe

Ute Mountain Ute Tribe Utu Utu Gwaitu Paiute Tribe

Viejas Band of Kumeyaay Indians Walker River Paiute Tribal Council

Wampanoag Tribe of Gay Head/Aquinnah Washoe Tribal Council

White Mesa Administration White Mountain Apache Tribe

Wichita and Affiliated Tribes Wilton Miwok Rancheria

Winnebago Tribal Council Winnemucca Tribal Council

Wiyot Tribe - Table Bluff Reservation Wyandotte Nation

Yankton Sioux Tribe Yavapai-Apache Nation

Yavapai-Prescott Board of Directors Yerington Paiute Tribe

Fire Retardant DEIS 145 Chapter 4. Consultation

Yocha Dehe Wintun Nation Yomba Tribal Council

Ysleta del Sur Pueblo Yurok Tribe

Zuni Pueblo

Organizations

Kimberly Baker — Environmental Protection Information Center Ken Bonner — Newton County Wildlife Association Mike Dubrasich — Western Institute for Study of the Environment Jay Linnger — Center for Biological Diversity Doug Heiken — Oregon Wild Timothy Ingalsbee — Firefighters United for Safety, Ethics and Ecology Jeff Juel — The Lands Council Jim Karels — National Association of State Foresters Charlie Morgan — Southern Group of State Foresters Jonathan Oppenheimer — Idaho Conservation League Duane Short — Biodiversity Conservation Alliance Andy Stahl — Forest Service Employees for Environmental Ethics Allan J. West — National Association of Forest Service Retirees Julia Stephens — Central Sierra Environmental Resource Center Businesses

Stan Bain — President, Cold Fire Enterprise David C. Fredley —Northwest Barricade, LLC Ron Raley — Phos-Chek State Government Agencies

Jill Taylor — Department of Natural Resources, Alaska Coastal Management Program Del Walters — California Department of Forestry & Fire Protection Local and Regional Government Agencies

Ray Boudreaux — City of Fayetteville, Arkansas Alan D. Gardner —Washington County Commission Angie Sturm — Lahontan Regional Water Quality Control Board Jeanne Whalen — Crook County Land Use Planning & Zoning Commission

Fire Retardant DEIS 146 Chapter 4. Consultation

Individuals

Stuart Alan Scott Amos Chris Bryant Bert Conner Paul Friesema Jerry Geissler Lauri Hanauska-Brown Neil Paulson Jean Public Roberta Ulrich ID Team Members

David A. Austin — Wildlife Biologist C. Kenton Call — Public Affairs/Collaboration Mary Carr — Writer/Editor, Publishing Arts Madelyn Dillon — Program Manager, Publishing Arts Kevin Donham — Fire Management Specialist Tory (Victoria) Henderson — Fire Chemicals and Equipment Program Manager Julie Laufmann — Botanist Timothy Love — Sr. Geospatial Applications Coordinator Elizabeth Lund — Deputy Director Fire & Aviation, Intermountain Region Chris J. Miller — Economist Craig Morris — Analyst Carolyn Napper — Soil Scientist Joey Pearson — Project Records Manager Will Reed — Heritage Specialist Glen Stein — Interdisciplinary Team Leader Marry Taylor Stewart — Public Affairs Specialist Carol Thornton — Hydrologist Kate Walker — Fisheries Biologist Jennifer Mickelson – Fisheries Biologist Others

The interdisciplinary team consulted with the following individuals who contributed to the development of this draft programmatic environmental impact statement. Individuals are Forest Service unless otherwise noted.

Louis Brueggeman — Fire Management Liaison, BLM Jon Curd — Fire Management Specialist, BLM Cecelia Johnson — Fire Chemicals Technical Specialist Shirley Zylstra — Wildland Fire Chemical Project Leader

Fire Retardant DEIS 147 Chapter 4. Consultation

Michael Kania – Landscape Architect Ted S. Milesnick — Chief, Fire Planning and Research, BLM Lis Novak – Landscape Architect Thomas Dzomba – Air Quality Terry Svalberg – Air Quality

Fire Retardant DEIS 148 Glossary

Fire Retardant DEIS 149 Glossary

Glossary

Alien Species - With respect to a particular ecosystem, any species, including its seeds, eggs, spores, or other biological material capable of propagating that species, that is not native to that ecosystem (Executive Order 13122, 2/3/99). See exotic, introduced species, and non indigenous species.

Aquatic Invertebrate – An animal, such as a mollusk or crustacean, that lack s a backbone or spinal column that lives wholly or chiefly in or on water.

Aquatic Vertebrate – Animals having a bony or cartilaginous skeleton with segmented spinal column and a large brain enclosed in a skull or cranium that lives wholly or chiefly in or on water.

Aquifer - An underground layer of permeable rock, sediment (usually sand or gravel), or soil that yields water. The pore spaces in aquifers are filled with water and are interconnected, so that water flows through them. Sandstones, unconsolidated gravels, and porous limestone make the best aquifers. They can range from a few square kilometers to thousands of square kilometers in size.

Avoidance Areas – A protection area surrounding a listed species developed to mitigate or avoid possible impacts caused by an action; no-drop zone for aerial retardant use.

Biological Assessment: A document prepared for Fish and Wildlife Service Section 7 consultation process to determine whether a proposed major construction activity under the authority of a Federal action agency is likely to adversely affect listed species, proposed species, or designated critical habitat.

Biological Opinion - A document prepared by the Fish and Wildlife Service that is the product of formal consultation, stating the opinion of the Fish and Wildlife Service on whether or not a Federal action is likely to jeopardize the continued existence of listed species or result in the destruction or adverse modification of critical habitat.

Biological Evaluation – A document prepared by the Forest Service to review planned, funded, executed, or permitted programs and activities for possible effects on endangered, threatened, proposed, or sensitive species (FSM 2672.4)

Biodiversity or biological diversity - The diversity of living things (species) and of life patterns and processes (ecosystem structures and functions). Includes genetic diversity, ecosystem diversity, landscape and regional diversity, and biosphere diversity (USDA Forest Service. “An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins”, Vol. II, 1997).

Candidate species - Plants and animals that have been studied and that the Fish and Wildlife Service has concluded should be proposed for addition to the Federal endangered and threatened species list. These species have formerly been referred to as category 1 candidate species.

Consultation – A requirement of the Endangered Species Act that requires the action agency to enter into discussions with a regulatory agency regarding the potential effects of a project on federally listed threatened or endangered species; occurs when a project “may affect” any species. The agencies work together to mitigated or avoid impacts to the species.

Critical habitat – As defined and used in the Endangered Species Act, is a specific geographic area(s) that contains features essential for the conservation of a threatened or endangered species and that may require special management and protection.

Fire Retardant DEIS 150 Glossary

Cumulative Effects - Impacts on environments that result from the incremental impact of an action when added to other past, present, and reasonably foreseeable future actions. Cumulative effects can result from individually minor but collectively significant actions taking place over a period of time.

Determination – A decision made from analysis of impacts of an action on a species; either No Effect or May Affect, which are further analyzed into adverse or not adverse effects.

Direct Effects – Effect that are caused by the action and occur at the same time and place.

Disturbance - An effect of a human activity or native or exotic agent or event that changes a landscape element, landscape pattern, or regional composition and may cause species behavioral change in response to the event.

An effect of a planned human management activity, or unplanned native or exotic agent or event, which changes the state of a landscape element, landscape pattern, or regional composition” (USDA Forest Service. “An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins”, Vol. II, 1997).

Diversity - The species richness of a community or area, although it provides a more useful measure of community characteristics when it is combined with an assessment of the relative abundance of species present (Allaby, 1996).

DO – Dissolved Oxygen

Ecosystem - The complex of a community of organisms and its environments (Executive Order 13122, 2/3/99).

Ecoregion – A large unit of land or water containing a geographically distinct assemblage of species, natural communities, and environmental conditions.

Ecotype - A locally adapted population of a widespread species. Such populations show minor changes of morphology and/or physiology, which are related to habitat and are genetically induced. Heavy metal-tolerant ecotypes of common grasses, such as Agrostis tenuis, are an example.

Endangered – Any species listed in the Federal Register as being in danger of extinction throughout all or a significant portion of its range.

Endangered Species Act (ESA)- A law passed in 1973 to conserve species of wildlife and plants determined by the Director of the Fish and Wildlife Service or the National Marine Fisheries to be endangered or threatened with extinction in all or a significant portion of its range. Among other measures, ESA requires all federal agenciesto conserve these species and consult with the Fish and Wildlife Service or National Marine Fisheries on federal actions that may affect these species or their designated critical habitat.

EPA - US Environmental Protection Agency

Ephemeral Stream - A stream channel that carries water only during and immediately after periods of rainfall or snowmelt.

Eutrophication - Having waters rich in mineral and organic (frequently nutrients from run-off of animal waste, fertilizers, sewage) that promote a proliferation of plant life, especially algae, which reduces the dissolved oxygen content of the water negatively impacting aquatic life.

Fire Retardant DEIS 151 Glossary

Evapotranspiration - The loss of water from the soil both by evaporation and by transpiration from the plants growing in the soil.

Exotic - Not native; introduced from elsewhere but not completely naturalized (Harris, 1994). See alien, introduced, and non indigenous species.

Federally Listed Species - Formally listed as a threatened or endangered species under the ESA. Designations are made by the Fish and Wildlife Service or National Marine Fisheries Service.

Fire Management Plan - A strategic plan that defines a program to manage wildland and prescribed fires and documents the Fire Management Program in the approved land use plan. The plan is supplemented by operational plans such as preparedness plans, preplanned dispatch plans, prescribed fire plans, and prevention plans (Interagency Implementation Guide, 1998).

FPA - Fire Program Analysis Model

FPU - Fire Planning Unit

Fugitive colorant - A mixed product that contains one or more ingredients that impart a high degree of visibility from the air when first applied to wildland fuels but will lose visibility gradually during the following several months (not noticeably visible 3 months after application).

FWS – U.S. Fish and Wildlife Service

Gamete – A mature sexual reproduction cell, as a sperm or egg, which unites with another cell to form a new organism.

Groundwater - Water beneath the earth's surface, often between saturated soil and rock, which supplies wells and springs.

Habitat - The place where a population (e.g., human, animal, plant, microorganism) lives and its surroundings, both living and non-living.

Hyperplasia – Increased cell production in a normal tissue or organ; abnormal proliferation of cells

IA - Initial Attack

Indirect Effects – Those are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems.

Integrated Weed Management - An interdisciplinary weed management approach for selecting methods to prevent, contain, and control noxious weeds in coordination with other resource management activities to achieve optimum management goals and objectives (FSM 2080.5).

Intermittent Stream - A stream that carries water a considerable portion of the time, but that ceases to flow occasionally or seasonally because bed seepage and evapotranspiration exceed the available water supply.

Fire Retardant DEIS 152 Glossary

Introduced Species - An alien or exotic species that has been intentionally or non-intentionally released into an area as a result of human activity. “Introduced (agricultural crops may fit the definition as well as ‘native’ or ‘introduced’ wildland species) or exotic species whose genetic material originally evolved and developed under different environmental conditions than those of the area in which it was introduced, often in geographically and ecologically distant locations” (Brown, 1997). See alien, exotic, and introduced species.

Introduction - The intentional or unintentional escape, release, dissemination, or placement of a species into an ecosystem as a result of human activity (Executive Order 13122, 2/3/99).

Invasive Plant Species - An alien plant species whose introduction does or is likely to cause economic or environmental harm or harm to human health (Executive Order 13122, 2/3/99).

LC50 – A statistically or graphically estimated concentration that is expected to be lethal to 50% of a group of organisms under specified conditions.

Macroinvertebrate – Animals that have no backbone and are visible without maginification (i.e aquatic worms, larvae of aquatic insects).

Mobility – The ability of a species to move and avoid a situation.

Monitoring - For type 4-5 initial attack fires (those with a small number of people or a single resource assignedin either class size A = 0 – ¼ acre, B = ¼ - 10 acres, C = 10 – 99 acres, or D = 100 – 300) where fire retardant has been applied and resource advisors were not present. Five percent of these are monitored for potential occurrences or impacts to resource values and reported to the Fish and Wildlife Service and National Marine Fisheries.

Native Species - With respect to a particular ecosystem, a species that, other than as a result of an introduction, has historically occurred or currently occurs in that ecosystem (Executive Order 13122, 2/3/99).

Narrow Endemic - Narrow endemic species are native species with restricted geographic distributions, soil affinities and/or habitats. Loss of these populations or their habitat within an area might jeopardize the continued existence or recovery of that species.

Naturalized - Applied to a species that originally was imported from another country but that now behaves like a native in that it maintains itself without further human intervention and has invaded native populations (Allaby, 1996).

NIFC - National Interagency Fire Center

NH3 - ammonia

Non indigenous - Plants and animals that originate elsewhere and migrate or are brought into an area. They may dominate the local species or have other negative impacts on the environment. See alien, exotic, and introduced species.

NOAA – National Oceanic and Atmospheric Administration

NWCG - National Wildfire Coordinating Group

Oligotrophic – Relatively low in plant nutrients and containing abundant oxygen in the deeper parts.

Fire Retardant DEIS 153 Glossary

Osmoregulation – The control of the levels of water and mineral salts in the blood.

Perennial Stream - A stream that contains water at all times except during extreme drought.

Phos-Chek – A brand of long-term fire retardants, class A foams, and gels (water enhancers) that are manufactured as dry powder concentrates or as liquid concentrates and are diluted with water before use.

Phytoplankton – Minute, free-floating aquatic plants.

Primary Constituent Element - Physical and biological features of a landscape that a species needs to survive and reproduce; the critical habitat for a species.

Propagule - A plant part, such as a bud, tuber, root, shoot, or spore, used to propagate an individual plants vegetatively.

RPA - Reasonable and Prudent Alternatives

Salmonid – Of, belonging to, or characteristic of the family Salmonidae, which includes salmon, trout, and whitefish.

Screening process – A logic flow used to help determine the effects of an action on species. The National screening process considers the amount of use of aerial fire retardant for a given area to determine a probability ofrisktoa species. The Wildlife screening process considers a series of flowcharts to help determine effects on critical habitat and species under certain conditions, such as mobility and potential use. There are assumptions that are applied to the processes.

SEAT - Single-Engine Air Tanker

Sensitive Species - Those plant and animal species identified by a [U.S. Forest Service] regional forester forwhich population viability is a concern, as evidenced by:

a. Significant current or predicted downward trends in population numbers or density.

b. Significant current or predicted downward trends in habitat capability that would reduce a species existing distribution (FSM 2670.5).

Threatened - The classification provided to an animal or plant likely to become endangered within the foreseeable future throughout all or a significant portion of its range.

TESPC - Threatened, Endangered, Sensitive, Proposed or Candidate species

Trigger - A report of misapplication, where there is an affect to threatened and endangered species, requires consultation with the forest/Fish and Wildlife Service/National Oceanic Marine Fisheries to determine the appropriate restriction on use of future application in the area (species dependent).

USGS – U.S. Geological Survey

WFDSS - Wildfire Decision Support System

Wildland Urban Interface (WUI) - The line, area, or zone where structures and other human development meet or intermingle with undeveloped wildland or vegetative fuels.

Fire Retardant DEIS 154 Literature Cited

Fire Retardant DEIS 155 Literature Cited

Literature Cited

Adams, Robyn and Dianne Simmons. 1999. Ecological Effects of Fire Fighting Foams and Retardants, Conference Proceedings, Australian Bushfire Conference, Albury, July 1999. 8p.

Alabaster, J.S., D.G. Shurben, and M.J. Mallett. 1983. The acute lethal toxicity of mixtures of cyanide and ammonia to smolts of salmon, Salmo salar, at low concentrations of dissolved oxygen. Journal of Fish Biology 22: 215-222

Anderson, Hal E. 1982. Aids to Determining Fuel Models for Estimating Fire Behavior. General Technical Report INT-122, USDA Forest Service, Intermountain Forest and Range Experimental Station, Ogden, Utah 84401. 22 p.

Angeler, David G. and Jose M. Moreno. 2006. Impact-Recovery patterns of water quality in temporary wetlands after fire retardant pollution, Can. J. Fish. Aquat. Sci. 63: 1617-1626

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Bailey, R.G. 1995. Description of the ecoregions of the United States. 2d ed., Misc. Publ. No. 1391 (rev.). Washington, DC: U.S. Department of Agriculture, Forest Service. 108 p.

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Barrett, S., et al. 2010. Interagency Fire Regime Condition Class (FRCC) Guidebook, Version 3.0.

Bell, T.L. 2003. Effects of fire retardants on vegetation in eastern Australian heathlands – a preliminary investigation. Department of Sustainability and Environment, Research Report No. 68.

Bell, Tina, Kevin Tolhurst, and Michael Wouters. 2005. Effects of the fire retardant Phos-Chek on vegetation in eastern Australian heathlands, International Journal of Wildland Fire, 14: 199-211

Bradstock, R., J. Sanders, and A. Tegart. 1987. Short-term effects on the foliage of a eucalypt forest after an aerial application of a chemical fire retardant, Australian Forestry 50(2): 71-80

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Brooks, Matthew L. 2008. Plant Invasions and Fire Regimes. 2008. In: Zouhar, K. J. Smith, S. Suterh.and, and M. Brooks, eds., Wildland Fire in Ecosystems: Fire and Nonnative Invasive Plants. USDA Forest Service General Technical Report RMRS-GTR-42, Vol. 6, pp 33-45.

Fire Retardant DEIS 156 Literature Cited

Brooks, Matthew L., Carla M. D’Antonio, David M. Richardson, James B. Grace, Jon E. Keeley, Joseph M. DiTomaso, Richard J. Hobbs, Mike Pellant, and David Pyke. 2004, Effects of Invasive Alien Plants on Fire Regimes, BioScience 54(7): 677-688

Brown, James K. and Jane Kapler Smith. 2000. Wildland fire in ecosystems: Effect of fire on flora. Gen.Tech. Rep. RMRS-GRT-42, Vol.2, Ogden, UT. USDA, Forest Service, Rocky Mountain Research Station. 257 p.

Brown, Thomas C. and Dan Binkley. 1994. Effect of Management on Water Quality in North American Forests, Gen. Tech. Rep. RM-248, Rocky Mountain Forest and Range Experiment Station, Fort Collins, Colorado. USDA, Forest Service. 31 p.

Brown, Thomas C., Michael T. Hobbins, and Jorge A. Ramirez. 2008. Spatial Distribution of Water Supply in the Coterminous United States. Journal of the American Water Resources Association. 44(6): 1474-1487

Buhl, K.J. and S.J. Hamilton. 1998. Acute Toxicity of Fire-Control Chemicals to Early Life Stages of Chinook Salmon. Environmental Toxicology and Chemistry, 17(8): 1589-1599

Buhl, K.J. and S.J. Hamilton. 2000. Acute Toxicity of Fire-Control Chemicals, Nitrogenous Chemicals and Surfactants to Rainbow Trout. American Fisheries Society 29: 408-418

Calfee, R.D. and E.E. Little. 2003. The effects of ultraviolet-B radiation on the toxicity of fire-fighting chemicals. Environmental Toxicology and Chemistry 22(7): 1525-1531

Calloway, R. 2010. Research scientist, University of Montana, Missoula, MT. Telephone conversation, December, 9, 2010

Carlson, Joan. 2009. Water Quality Management on National Forest System Lands, USDA Forest Service, Rocky Mountain Region

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Certini, Giacomo. 2005. Effect of fire on properties of forest soils. Oecologia 143: 1-10

Chandler, C., P. Cheney, P. Thomas, L.Trabaud, D.Williams. 1983. Fire in Forestry, Vol. II. Forest Fire Management and Organization. J. Wiley & Sons, Canada, 441 p.

Cooperrider, Allen Y., Raymond J. Boyd, and Hanson R. Stuart Eds. 1986. Inventory and Monitoring of Wildlife Habitat. US Department of the Interior, Bureau of Land Management. Service Center. Denver, CO. 858 p.

Crouch, R.L., H.J. Timmenga, T.R. Barber, and P.C. Fuchsman. 2006. Post-fire surface water quality: comparison of fire retardant versus wildfire-related effects. Chemosphere 62: 874-889

DeBano, Leonard F., Daniel G. Neary, and Peter F. Ffolliott. 1998. Fire's Effects on Ecosystems, John Wiley & Sons, Inc., New York (complete publication on file at National FS Library, St. Paul, MN)

Dissmeyer, George E. 2000. Drinking Water from Forests and Grasslands, A Synthesis of the Scientific Literature, USDA Forest Service, Southern Research Station, GTR-SRS-39. 250 p.

Fire Retardant DEIS 157 Literature Cited

DiTomaso, J., M. Brooks, E. Allen, R. Minnich, P. Rice, G. Kyser. 2006. Control of invasive weeds with prescribed burning. Weed Technology 20: 535-548

Dubrovsky, Neil M. 2010. Nutrients in the Nation's Streams and Groundwater, 1992-2004. Briefing sheet prepared for a congressional briefing in Washington, D.C., Sept. 24, 2010. USDI Geological Survey

Dubrovsky, Neil M. and Pixie A. Hamilton. 2010. Nutrients in the Nation's Streams and Groundwater: National Findings and Implications. Fact Sheet 2010-3078, USDI Geological Survey

Dubrovsky, Neil M., Karen R. Burow, Gregory M. Clark, JoAnn M. Gronberg, Pixie A. Hamilton, Kerie J. Hitt, David K. Mueller, Mark D. Munn, Bernard T. Nolan, Larry J. Puckett, Michael G. Rupert, Terry M. Short, Norman E. Spahr, Lori A. Sprague, and William G. Wilber. 2010. The Quality of Our Nation's Water - Nutrients in the Nation's Streams and Groundwater, 1992-2004, US Geological Survey Circular 1350. 194 p.

Dunham, J.B., M.K. Young, R.E. Gresswell, B.E. Rieman. 2003. Effects of fire on fish populations: landscape perspectives on persistence of native fishes and nonnative fish invasions. Forest Ecology and Management 178: 183–196

Eliason, Scott. 2010. Personal communication re Division Fire endangered plan effects

Eliason, Scott. 2010a. Biological Assessment, Division Incident, for consultation under Section 7 of the Endangered Species Act on the Effects of the Emergency Response and Associated Actions, San Bernardino National Forest

Elliot, William J., Ina Sue Miller, Lisa Audin. Eds. 2010. Cumulative watershed effects of fuel management in the western United States. Gen. Tech. Rep. RMRS-GTR-231. Fort Collins, CO: US Dept of Agriculture, Forest Service, Rocky Mountain Research Station, 299 p.

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Gaikowski, M.P., S.J. Hamilton, K.J. Buhl, S.F. McDonald, and C.H. Summers. 1996. Acute toxicity of three fire-retardant and two fire-suppressant foam formulations to the early life stages of rainbow trout(Oncorhynchus mykiss). Environmental Toxicology and Chemistry 15(8): 1365-1374

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Green, Emily K. and Susan M. Galatowitsch. 2002. Effects of Phalaris arundinacea and nitrate – N addition on the establishment of wetland plant communities. Journal of Applied Ecology 39: 134-144

Gresswell, R.E. 1999. Fire and aquatic ecosystems in forested biomes of North America. Transactions of the American Fisheries Society 128(2): 193-221.

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Hammer, Roger B., Susan I. Stewart, and Volker C. Radeloff. 2009. Demographic Trends, the Wildland-Ruban Interface, and Wildfire Management. Society and Natural Resources, 22: 777-782

Harrod, Richy J. and Sarah Reichard. 2001. Fire and invasive species within the temperate and boreal coniferous forests of western North America. In Galley, Krista E.M: Wildon, Tyrone P. eds Proceedins of the invasive species workshop: The role of fire in the control and spread of invasive species; Fire conference 2000; the firstnationsl congress on fire ecology, prevention and management 2000, November 27-Dec1; San Diego , CA Misc Publication No. 11. Tallahassee, Fl. Tall Timbers Research Station: 95-101

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Hessl, A.E., D. McKenzie, and R. Schellhaas. 2010. Drought and Pacific Decadal Oscillation linked to fire occurrence in the inland Pacific Northwest. Ecological Applications, 14(2): 425-442

Fire Retardant DEIS 159 Literature Cited

Hopmans, Peter and Ross Bickford. 2003. Effects of fire retardant on soils of heathland in Victoria, Research Report No. 70, Forest Science Centre, Heidelberg, Fire Management Department of Sustainability and Environment, Victoria. 29 p.

Ingalsbee, Timothy. 2004. Western Fire Ecology Center - Biscuit Fire Suppression Impacts. Western Fire Ecology Center, American Lands Alliance. 43 p.

Interagency (FRCC). 2008. Fire Regime Condition Class (FRCC) Guidebook, Version 3.0.

International Code Council. 2008. The Blue Ribbon Panel Report on Wildland Urban Interface Fire.

ISG (Independent Science Group). 1996. Return to the river: Restoration of salmonid fishes in the Columbia River ecosystem. ISG Report 96-6, for Northwest Power Planning Council, Portland, OR. 522 p.

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Johnson, Cecilia. 2010. Retardant Composition Application, unpublished report by C. Johnson, Fire Chemicals Technical Specialist, USDA Forest Service MTDC, Missoula, Montana

Johnson, Cecilia. 2011. C. Johnson, Fire Chemicals Technical Specialists, MTCD-Wildland Fire Chemical Systems, Missoula, MT. Email communication with Julie Laufman 1/05/2011

Johnson, W.W. and H.O. Sanders. 1977. Chemical Forest Fire Retardants: Acute Toxicity in Five Freshwater Fishes and a Scud. Technical Papers of the U.S. Fish and Wildlife Service, #91. Washington D.C. 9 p.

Kalkhan, Mohammed A., Evan J. Stafford, Peter J. Woodly, Thomas J Stohlgren. 2007. Assessing exotic plant species invasions and associated soil characteristics: A case study in eastern Rocky Mountain National Park, Colorado, USA, using the pixel nested plot design. Soil Ecology 35: 622-634

Keeley, Jon E. 2001. Fire and invasive species in Mediterranean-climate ecosystems of California. Pages 81-94 in K.E.M. Galley and T.P. Wilson (eds.). Proceedings of the Invasive Species Workshop: the Role of Fire in the Control and Spread of Invasive Species. Fire Conference 2000: the First National Congress on Fire Ecology, Prevention, and Management. Misc Publication No. 11, Tall Timbers Research Station, Tallahassee, FL

Kimbell, Abigail R. and Hutch Brown. 2009. Using Forestry to Secure America's Water Supply, Journal of Forestry, April/May 2009

Krehbiel, R. 1992. The use of Firetrol 931 in British Columbia, 1992 Stoner Fire retardant spill, Memorandum dated November 24, 1992. British Columbia Environmental Protection. 8 p.

Labat Environmental, Inc. 2011. Risk Comparison of Uncontrolled Wildfires and the Use of Fire Suppression Chemicals, prepared for National Interagency Fire Center, USDA Forest Service, Boise ID. 32 p.

Labat Environmental. 2003. Human Health Risk Assessment: Wildland Fire-fighting Chemicals. Prepared for Missoula Technology and Development Center, USDA Forest Service, Missoula, Montana.

Labat Environmental. 2007. Ecological Risk Assessment: Wildland Fire-fighting Chemicals, prepared for Missoula Technology and Development Center, USDA Forest Service, Missoula, MT. 69 p.

Fire Retardant DEIS 160 Literature Cited

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Fire Retardant DEIS 167 Literature Cited

Fire Retardant DEIS 168 Appendices

Fire Retardant DEIS 169 Appendices

Appendices Appendix A – 2000 Guidelines for Aerial Delivery of Retardant or Foam Guidelines for Aerial Delivery of Retardant or Foam Near Waterways

Definition:

Waterway – Any body of water including lakes, rivers, streams and ponds whether or not they contain aquatic life. Guidelines:

Avoid aerial application of retardant or foam within 300 feet of waterways.

These guidelines do not require the helicopter or airtanker pilot-in-command to fly in such a way as to endanger his or her aircraft, other aircraft, or structures or compromise ground personnel safety. Guidance for pilots:

To meet the 300-foot buffer zone guideline, implement the following:

Medium/Heavy Airtankers: When approaching a waterway visible to the pilot, the pilot shall terminate the application of retardant approximately 300 feet before reaching the waterway. When flying over a waterway, pilots shall wait one second after crossing the far bank or shore of a waterway before applying retardant. Pilots shall make adjustments for airspeed and ambient conditions such as wind to avoid the application of retardant within the 300-foot buffer zone. Single Engine Airtankers: When approaching a waterway visible to the pilot, the pilot shall terminate application of retardant or foam approximately 300 feet before reaching the waterway. When flying over a waterway, the pilot shall not begin application of foam or retardant until 300 feet after crossing the far bank or shore. The pilot shall make adjustments for airspeed and ambient conditions such as wind to avoid the application of retardant within the 300-foot buffer zone. Helicopters: When approaching a waterway visible to the pilot, the pilot shall terminate the application of retardant or foams 300 feet before reaching the waterway. When flying over a waterway, pilots shall wait five seconds after crossing the far bank or shore before applying the retardant or foam. Pilots shall make adjustments for airspeed and ambient conditions such as wind to avoid the application of retardant or foam within the 300-foot buffer zone. Exceptions:

When alternative line construction tactics are not available due to terrain constraints, congested area, life and property concerns or lack of ground personnel, it is acceptable to anchor the foam or retardant application to the waterway. When anchoring a retardant or foam line to a waterway, use the most accurate method of delivery in order to minimize placement of retardant or foam in the waterway (e.g., a helicopter rather than a heavy airtanker).

Fire Retardant DEIS 170 Appendices

Deviations from these guidelines are acceptable when life or property is threatened and the use of retardant or foam can be reasonably expected to alleviate the threat. When potential damage to natural resources outweighs possible loss of aquatic life, the unit administrator may approve a deviation from these guidelines. Threatened and Endangered (T&E) Species:

The following provisions are guidance for complying with the emergency section 7 consultation procedures of the ESA with respect to aquatic species. These provisions do not alter or diminish an action agency’s responsibilities under the ESA.

Where aquatic T&E species or their habitats are potentially affected by aerial application of retardant or foam, the following additional procedures apply:

1. As soon as practicable after the aerial application of retardant or foam near waterways, determine whether the aerial application has caused any adverse effects to a T&E species or their habitat. This can be accomplished by the following: a. Aerial application of retardant or foam outside 300 ft of a waterway is presumed to avoid adverse effects to aquatic species and no further consultation for aquatic species is necessary. b. Aerial application of retardant or foam within 300 ft of a waterway requires that the unit administrator determine whether there have been any adverse effects to T&E species within the waterway.

These procedures shall be documented in the initial or subsequent fire reports.

2. If there were no adverse effects to aquatic T&E species or their habitats, there is no additional requirement to consult on aquatic species with Fish and Wildlife Service (FWS) or National Marine Fisheries Service (NMFS).

3. If the action agency determines that there were adverse effects on T&E species or their habitats then the action agency must consult with FWS and NMFS, as required by 50 CFR 402.05 (Emergencies). Procedures for emergency consultation are described in the Interagency Consultation Handbook, Chapter 8 (March, 1998). In the case of a long duration incident, emergency consultation should be initiated as soon as practical during the event. Otherwise, post-event consultation is appropriate. The initiation of the consultation is the responsibility of the unit administrator.

Each agency will be responsible for insuring that the appropriate guides and training manuals reflect these guidelines. National Marine Fisheries Service Reasonable and Prudent Alternatives

1. Provide evaluations on the two fire retardant formulations, LC 95-A and 259R, for which acute toxicity tests have not been conducted, using standard testing protocols. Although direct fish toxicity tests have not been conducted on three additional formulations, G75-W, G75-F, LV-R, studies are not warranted in light of the fact the USFS intends to phase out their use of these formulations by 2010. All formulations expected to be in use beyond 2010 shall be evaluated using, at a minimum, the established protocols to assess acute mortality to fish. Evaluations must be completed and presented to NMFS no later than two years from the date of this Opinion. Depending on the outcome of these evaluations and after conferring with NMFS, the USFS must make appropriate modifications to the program that would minimize the effects on NMFS’ listed resources (e.g., whether a retardant(s) should be withdrawn from use and replaced with an alternative retardant(s)).

Fire Retardant DEIS 171 Appendices

2. Engage in toxicological studies on long-term fire retardants approved for current use in fighting fires, toevaluate acute and sublethal effects of the formulations on NMFS’ listed resources. The toxicological studies will be developed and approved by both the USFS and NMFS. The studies should be designed to explore the effects of fire retardant use on: unique life stages of anadromous fish such as smolts and buried embryo/alevin life stages ranging in development from spawning to yolk sac absorption and the onset of exogenous feeding (approximately 30 days post-hatch); and anadromous fish exposed to fire retardants under multiple stressor conditions expected during wildfires, such as elevated temperature and low DO. Within 12 months of accepting the terms of thisOpinion, USFS provide NMFS with a draft research plan to conduct additional toxicological studies on the acute and sublethal effects of the fire retardant formulations. Depending on the outcome of these studies described per the research plan and after conferring with NMFS, the USFS must make appropriate modifications to the program that would minimize the effects on NMFS’ listed resources (e.g., whether a retardant(s) should be withdrawn from use and replaced with an alternative retardant(s)).

3. Develop guidance that directs the US Forest Service to conduct an assessment of site conditions following wildfire where fire retardants have entered waterways, to evaluate the changes to on site water quality and changesinthe structure of the biological community. The field guidance shall require monitoring of such parameters as macro-invertebrate communities, soil and water chemistry, or other possible surrogates for examining the direct and indirect effects of fire retardants on the biological community within and downstream of the retardant drop area as supplemental to observations for signs of dead or dying fish. The guidance may establish variable protocols based upon the volume of retardants expected to have entered the waterway, but must require site evaluations commensurate with the volume of fire retardants that entered the waterway.

4. Provide policy and guidance to ensure that USFS local unit resource specialist staff provide the local NMFS Regional Office responsible for section 7 consultations with a summary report of the site assessment thatidentifies: (a) the retardant that entered the waterway, (b) an estimate of the area affected by the retardant, (c) a description of whether the retardant was accidentally dropped into the waterway or whether an exception to the 2000 Guidelines was invoked and the reasons for the accident or exception,(d) an assessment of the direct and indirect impacts of the fire retardant drop, (e) the nature and results of the field evaluation that was conducted following controland abatement of the fire, and any on site actions that may have been taken to minimize the effects of the retardanton aquatic communities.

5. Provide NMFS Headquarter’s Office of Protected Resources with a biannual summary (every two years) that evaluates the cumulative impacts (as the Council on Environmental Quality has defined that term pursuant to the National Environmental Policy Act of 1969) of their continued use of long-term fire retardants including: (a) the number of observed retardant drops entering a waterway, in any subwatershed and watershed, (b) whether the observed drops occurred in a watershed inhabited by NMFS’ listed resources, (c) an assessment as to whether listed resources were affected by the misapplication of fire retardants within the waterway, and (d) the USFS’ assessment of cumulative impacts of the fire retardant drops within the subwatershed and watershed and the consequences of those effects on NMFS’ listed 139 resources. The evidence the USFS shall use for this evaluation would include, but is not limited to: (i) the results of consultation with NMFS’ Regional Offices and the outcome of the site assessment described in detail in the previous element of this RPA (Element 4) and (ii) the results of new fish toxicity studies identified within Element 2; and (d) any actions the USFS took or intends to take to supplement the 2000 Guidelines to minimize the exposure of listed fish species to fire retardants, and reduce the severity of their exposure.

Fire Retardant DEIS 172 Appendices

U.S. Fish and Wildlife Service Reasonable and Prudent Alternatives

1. Coordinate with local Fish and Wildlife Service offices each year to the onset of the fire season to ensure that 1) the most up-to-date detailed maps or descriptions of areas on National Forest System lands that are designated critical habitat or occupied by species found in Table 1, 2) this information is incorporated in local planning and distributed to appropriate resources by the local Fire Management Officer, 3) maps and information are made available to incident commanders and fire teams for the purpose of avoiding application of retardants toareas designated critical habitat or occupied by species found Table 1, whenever possible, including the use of best available technologies to avoid areas designated critical habitat or occupied by species found in Table 1, 4) any other appropriate conservation measures are included to avoid the likelihood of jeopardizing species or adversely modifying or destroying critical habitat, such measures may include enhancement of populations or other appropriate contingency measures.

2. Wherever practical, the Forest Service will prioritize fuels reduction projects for lands in the National Forest System that are in close vicinity to areas designated critical habitat or occupied by species listed in Table 1, so as to reduce the need to use aerially applied fire retardants.

3. Whenever practical, the Forest Service will use water or other less toxic fire retardants than those described in the proposed action within areas designated critical habitat or occupied by species in Table 1.

4. If areas designated critical habitat or occupied by species found in Table 1 are exposed to fire retardant, then the Forest Service will initiate Emergency Consultation pursuant to regulations at 50 CFR 402.05 implementing section 7 of the Endangered Species Act of 1973, as amended. As part of the Emergency Consultation, the following measures may apply: a. Conduct monitoring in coordination with the local Fish and Wildlife Service office of the direct, indirect, and cumulative impacts of the fire retardant application on listed species. Fish and Wildlife Service-approved monitoring protocols and reporting frequency will be developed. Monitoring for aquatic species may include water quality. b. If appropriate, and in consultation with the Fish and Wildlife Service, include measures to prevent or compensate for population declines due to application of fire retardant. c. During monitoring, all non-native plant species will be removed from areas of concern as appropriate for the area and listed species affected, as determined in consultation with the appropriate Fish and Wildlife Service office. Appropriate weed control methods will be developed in coordination with the local Fish and Wildlife Service office.

Fire Retardant DEIS 173 Appendices

Appendix B – Implementation of the Reasonable and Prudent Alternatives

The US Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) biological opinions were accepted with reasonable and prudent alternatives (RPAs). The Forest Service immediately began the implementation of the RPAs upon issuing the Decision Notice (February 2008).

The following provides the current status of each RPA accepted by the Forest Service: Fish and Wildlife Service

RPA Sub-Element

Coordinate with local Fish and Wildlife Service offices each year to the onset of the fire season to ensure that1) the most up-to-date detailed maps or descriptions of areas on National Forest System lands that are designated critical habitat or occupied by species found in Table 1, 2) this information is incorporated in local planning and distributed to appropriate resources by the local Fire Management Officer, 3) maps and information are made available to incident commanders and fire teams for the purpose of avoiding application of retardants toareas designated critical habitat or occupied by species found Table 1, whenever possible, including the use of best available technologies to avoid areas designated critical habitat or occupied by species found in Table 1, 4) any other appropriate conservation measures are included to avoid the likelihood of jeopardizing species or adversely modifying or destroying critical habitat, such measures may include enhancement of populations or other appropriate contingency measures.

Status

Each impacted region updated maps, established pre-fire procedures that engage and incorporate USFWS personnel, and identified areas where retardant would not be allowed. This information is provided to Incident Management Teams when teams are assigned. Forest Supervisors/District Rangers continue to assign Resource Advisors to fires to ensure resource protection requirements are known and followed, which includes using water only at times. Where necessary, resource protection requirements would be incorporated into the Delegation of Authority given to the Incident Commander.

Initial information of the RPAs was given to the Regional Foresters, Fire Directors, Threatened and Endangered Species Directors and Forest Supervisors. This direction included the requirement for Forest Supervisors to contact their local FWS and NMFS (if applicable) offices prior to the beginning of fire season. The memo containing this direction was delivered on March 27, 2008. Each following year a memo has been sent to the field reminding them of the requirements with a national standard reporting form. This information has been posted to both the Fire and Aviation’s web page and the Wildland Fire Chemical Systems web page.

In addition the information has been included in the Interagency Fire and Aviation Standards for Operations and the Incident Pocket Response Guide.

Fire Retardant DEIS 174 Appendices

RPA Sub-Element

Wherever practical, the Forest Service will prioritize fuels reduction projects for lands in the National Forest System that are in close vicinity to areas designated critical habitat or occupied by species listed in Table 1, so as to reduce the need to use aerially applied fire retardants.

Status

The Decision Notice and RPAs were shared with the Regional Foresters through the March 27, 2008 letter. The Forest Supervisor has the responsibility to review the planned fuel treatments for prioritization based on the RPA as well as future treatments.

To monitor this nationally the Washington Office collects the information from the forests on what acres were treated in the identified areas through FACTS reporting (Forest Service Activity Tracking System), although adding the TES information in the report is not considered a mandatory field . The Washington Office pulled information from the reporting system from 2009 that provided information of 16,515 acres treated specifically within TES habitat listed, however numerous projects were completed near the TES species habitat. For FY2010 176,181 acres were reported as treated in the TES habitat for those species identified in the biological opinion (BO). It is important to remember that the identified for the TES is not a required reporting element, so the reported acres could actually be underestimated. Also it is important to note that other acres were treated that could be in TES designated habitats they just were not ones identified in the BO. RPA Sub-Element

Whenever practical, the Forest Service will use water or other less toxic fire retardants than those described inthe proposed action within areas designated critical habitat or occupied by species in Table 1.

Status

Included in the direction provided to an Incident Commander are any restrictions of tactics. Some areas did only allow water for aerially delivery, unless the situation of threat to life and property was so high. The direction will come in the form of the Delegation of Authority and the resource advisors direction. RPA Sub-Element

If areas designated critical habitat or occupied by species found in Table 1 are exposed to fire retardant, then the Forest Service will initiate Emergency Consultation pursuant to regulations at 50 CFR 402.05 implementing section 7 of the Endangered Species Act of 1973, as amended. As part of the Emergency Consultation, the following measures may apply: a. Conduct monitoring in coordination with the local Fish and Wildlife Service office of the direct, indirect, and cumulative impacts of the fire retardant application on listed species. Fish and Wildlife Service-approved monitoring protocols and reporting frequency will be developed. Monitoring for aquatic species may include water quality. b. If appropriate, and in consultation with the Fish and Wildlife Service, include measures to prevent or compensate for population declines due to application of fire retardant.

Fire Retardant DEIS 175 Appendices

c. During monitoring, all non-native plant species will be removed from areas of concern as appropriate for the area and listed species affected, as determined in consultation with the appropriate Fish and Wildlife Service office. Appropriate weed control methods will be developed in coordination with the local Fish and Wildlife Service office.

Status

Direction to the field with a national standard form for reporting retardant in waterways, 300 foot buffer, orT&E species habitat has been sent annually beginning in 2008. Any reports generated due to accidents, spills, and exceptions to the Aerial Delivery of Retardant were submitted to our Wildland Fire Chemicals System program for consolidation and summarization. Initial reports submitted included if Section 7 consultation was initiated or not required, as well as monitoring. Forest Supervisors/District Rangers would initiate the monitoring requirements where applicable.

Forests use long-established local procedures for monitoring effects of activities to listed species and critical habitat, and for meeting and communication with their local USFWS personnel when needed to fully evaluate the significance of effects. On June 16-17, 2009 the FS and USGS met to develop the national template for protocols for monitoring in the event it is necessary. These protocols were reviewed by USFWS and direction was sent to the field May 27, 2010 with the national monitoring elements as well as a guide for assessing the impact of an application to a waterway or the TES habitat. In addition, a Dispersal/Toxicity Calculator (developed by the USGS) for field use was included in that direction. The Dispersal/Toxicity Calculator can help the resource advisor or other personnel determine the potential impact of an application in a waterway. This will serve as a basis for initial surveying which may or may not lead to consultation. NMFS

RPA Sub-Element

Provide evaluations on the two fire retardant formulations, LC 95-A and 259R, for which acute toxicity tests have not been conducted, using standard testing protocols. Although direct fish toxicity tests have not been conducted on three additional formulations, G75-W, G75-F, LV-R, studies are not warranted in light of the fact the USFS intends to phase out their use of these formulations by 2010. All formulations expected to be in use beyond 2010 shall be evaluated using, at a minimum, the established protocols to assess acute mortality to fish. Evaluations must be completed and presented to NMFS no later than two years from the date of this Opinion. Depending on the outcome of these evaluations and after conferring with NMFS, the USFS must make appropriate modifications to the program that would minimize the effects on NMFS’ listed resources (e.g., whether a retardant(s) should be withdrawn from use and replaced with an alternative retardant(s)).

Status

USGS completed the acute toxicity testing on LC 95-A and 259R. Results were shared with NMFS and USFWS at the May 29, 2008 joint meeting. No issues or concerns were raised.

The revised USDA Forest Service Specification 5100-304c for Long-Term Retardant, Wildland Firefighting, June 1, 2007 includes the Acute Fish Toxicity testing requirements and established protocols. The process we use was explained to NMFS and accepted. The timing of a company submitting a product for evaluation against this

Fire Retardant DEIS 176 Appendices

specification varies therefore the information provided to NMFS will be dependent upon that timeline whichmay be later than the two years from accepting the Biological Opinion. NMFS recognizes this, as well as the Forest Service does not utilize any product prior to its meeting the requirements of the specification.

Testing was completed for LC 95-A and 259R. There are no additional tasks under this sub-element unless formulations are changed that would require discussions with NMFS prior to adding a product to the QPL.

Testing for P100-F was completed by the end of March 2010. This product is being formulated according to the specification that will be implemented April 2011. The additional acute fish toxicity tests have been completedand the formulation and test results were provided to NMFS. No issues were identified and the product has been added to the QPL. RPA Sub-Element

Engage in toxicological studies on long-term fire retardants approved for current use in fighting fires, toevaluate acute and sublethal effects of the formulations on NMFS’ listed resources. The toxicological studies will be developed and approved by both the USFS and NMFS. The studies should be designed to explore the effects of fire retardant use on: unique life stages of anadromous fish such as smolts and buried embryo/alevin life stages ranging in development from spawning to yolk sac absorption and the onset of exogenous feeding (approximately 30 days post-hatch); and anadromous fish exposed to fire retardants under multiple stressor conditions expected during wildfires, such as elevated temperature and low DO. Within 12 months of accepting the terms of thisOpinion, USFS provide NMFS with a draft research plan to conduct additional toxicological studies on the acute and sublethal effects of the fire retardant formulations. Depending on the outcome of these studies described per the research plan and after conferring with NMFS, the USFS must make appropriate modifications to the program that would minimize the effects on NMFS’ listed resources (e.g., whether a retardant(s) should be withdrawn from use and replaced with an alternative retardant(s)).

Status

Forest Service personnel met with NMFS, USFWS, and USGS on May 29, 2008 and identified key elements for developing a toxicological study. The Forest Service received proposed investigations of the toxicity of long-term retardants on the survival and health of smolting salmonid from NMFS and USGS. The proposal was accepted, an interagency agreement was executed and NMFS performed the work. The report was completed and provided to the Forest Service, USGS, and NMFS Headquarters. The report recommended additional research which was agreed to by the Forest Service. The NMFS recommended examining the temporal lethal and sublethal effects of currently approved fire retardants on oceantype Chinook, as well as characterizing the temporal sublethal effectson streamtype Chinook testing. This work is expected to be completed in 2011. RPA Sub-Element

Develop guidance that directs the US Forest Service to conduct an assessment of site conditions following wildfire where fire retardants have entered waterways, to evaluate the changes to on site water quality and changesinthe structure of the biological community. The field guidance shall require monitoring of such parameters as macro-invertebrate communities, soil and water chemistry, or other possible surrogates for examining the direct and indirect effects of fire retardants on the biological community within and downstream of the retardant drop

Fire Retardant DEIS 177 Appendices

area as supplemental to observations for signs of dead or dying fish. The guidance may establish variable protocols based upon the volume of retardants expected to have entered the waterway, but must require site evaluations commensurate with the volume of fire retardants that entered the waterway.

Status

Received proposal from USGS for assessment of site conditions and worked through the proposal with NMFS and USFWS. The monitoring protocols and data to be collected in order to establish a national sampling and monitoring template was completed and direction sent to the field May 2010. This direction included a dispersal/toxicity calculator that was to be beta tested during the 2010 fire season in order to determine if it meets the needsfor determining area potentially affected and the degree of monitoring required. RPA Sub-Element

Provide policy and guidance to ensure that USFS local unit resource specialist staff provide the local NMFS Regional Office responsible for section 7 consultations with a summary report of the site assessment that identifies: (a)the retardant that entered the waterway, (b) an estimate of the area affected by the retardant, (c) a description of whether the retardant was accidentally dropped into the waterway or whether an exception to the 2000 Guidelines was invoked and the reasons for the accident or exception,(d) an assessment of the direct and indirect impacts of the fire retardant drop, (e) the nature and results of the field evaluation that was conducted following controland abatement of the fire, and any on site actions that may have been taken to minimize the effects of the retardanton aquatic communities.

Status

A memo to Regional Foresters was sent on June 2, 2008 providing direction for reporting requirements for retardant and foam in waterways and T&E species habitats. A form was included with the direction for reporting requirements. All information was posted to the Forest Service web site relative to the Environmental Assessment, Decision notice, and the Biological Opinions. The form included all the elements cited in the RPA sub-element. Subsequent to 2008 memos have been issued annually to the field with the requirements for reporting and entering into consultation. Policy documents have been edited to incorporate these requirements.

The forms are collected by the Wildland Fire Chemical Systems program staff and consolidated in order to provide the NMFS with a summary of accidental or purposeful drops and if consultation was required, as well as if a biological assessment was required and completed. RPA Sub-Element

Provide NMFS Headquarter’s Office of Protected Resources with a biannual summary (every two years) that evaluates the cumulative impacts (as the Council on Environmental Quality has defined that term pursuant to the National Environmental Policy Act of 1969) of their continued use of long-term fire retardants including: (a) the number of observed retardant drops entering a waterway, in any subwatershed and watershed, (b) whether the observed drops occurred in a watershed inhabited by NMFS’ listed resources, (c) an assessment as to whether listed resources were affected by the misapplication of fire retardants within the waterway, and (d) the USFS’ assessment of cumulative impacts of the fire retardant drops within the subwatershed and watershed and the consequences of those effects on NMFS’ listed 139 resources. The evidence the USFS shall use for this evaluation would include, but is not limited to: (i) the results of consultation with NMFS’ Regional Offices and the outcome of the site

Fire Retardant DEIS 178 Appendices

assessment described in detail in the previous element of this RPA (Element 4) and (ii) the results of new fish toxicity studies identified within Element 2; and (d) any actions the USFS took or intends to take to supplement the 2000 Guidelines to minimize the exposure of listed fish species to fire retardants, and reduce the severity of their exposure.

Status

The two year summary report was completed and submitted to NMFS in early 2010. Any need for consultation and biological assessment was identified in the report with the copies of the biological assessments being provided. A three-year report was submitted in early 2011 for their information and use.

Fire Retardant DEIS 179 180 DEIS Retardant Fire Appendices Appendix C – Fire and Retardant Use Information

Table C-1. Estimated Area of Fire Retardant Application on USFS Lands.

FS Region Acres/region1 # fires # Retardant Total Gallons Avg gallons/ Acres of Acres of % USFS Land % USFS Land 2000-2010 Drops 2000-2010 (11 yr 3 impact at 4 gpc impact at 8 w/fire retardant w/fire retardant 2000-20102 yrs) 4 gpc 4 at 4 gpc 4 at 8 gpc 4

R1 25,599,732 10,703 4,082 10,203,789 927,617 532 266 0.00208 0.00104

R2 22,109,098 6,591 1,101 2,753,524 250,320 144 72 0.00065 0.00032

R3 20,808,318 18,597 7,550 18,875,476 1,715,952 985 492 0.00473 0.00237

R4 31,962,282 10,234 4,197 10,493,664 953,969 548 274 0.00171 0.00086

R5 20,218,821 15,884 11,266 28,165,743 2,560,522 1,470 735 0.00727 0.00363

R6 24,774,462 14,834 6,165 15,411,352 1,401,032 804 402 0.00325 0.00162

R8 13,356,285 10,165 1,487 3,716,469 337,861 194 97 0.00145 0.00073

R9 12,124,173 5,835 300 749,790 68,163 39 20 0.00032 0.00016

R10 21,956,250 359 0 0 - - - 0.00000 0.00000

Total 192,909,421 93,202 36,148 90,369,807 8,215,437 4,715 2,358 0.00244 0.00122

1 USFS 2010 Table 2 Lands area report: http://www.fs.fed.usdaland/staff/lar/LAR2010/lar2010index.html

2 Data derived from: NIFC – ABS database 12/08/2010

3Data averaged over 2000–2011

4Calculations: gpc = 100 ft 2 ; 4gal/100sq ft = 1, 740 gal/acre; 8gal/100sqft=3,480 gal/acre - (43,500sqft/acre) Table C-2. Estimated area of Fire Retardant Application on USFS Lands by Forest.

USFS Region Forest Name Total % USFS % USFS Acres of Acres of Number of Avg Avg Land w/fire Land w/fire Acres1 impact at impact at Drops 2000- drop/yr3 gallon/yr retardant at 4 retardant at 8 4 gpc4 8 gpc4 20102 gpc4 gpc4

05 San Bernardino National Forest 823816 1,607 146 365,271 210 105 0.025447 0.012724

05 Angeles National Forest 742693 1,257 114 285,573 164 82 0.022068 0.011034

05 Los Padres National Forest 1963836 2,811 256 638,947 367 183 0.018673 0.009336

Okanogan-Wenatchee National 06 Forests 1535021 1,458 133 331,364 190 95 0.012389 0.006195

05 Sequoia National Forest 1193315 978 89 222,385 128 64 0.010696 0.005348

03 Coronado National Forest 1859807 1,429 130 324,770 186 93 0.010022 0.005011

Fremont-Winema National 06 Forests 1713891 1,218 111 276,773 159 79 0.009268 0.004634

03 Lincoln National Forest 1271064 765 70 173,920 100 50 0.007853 0.003926

Apache-Sitgreaves National 03 Forests 694175 390 35 88,609 51 25 0.007326 0.003663

03 Prescott National Forest 1407611 777 71 176,693 101 51 0.007204 0.003602

05 Cleveland National Forest 568634 314 29 71,358 41 20 0.007202 0.003601

05 Shasta Trinity National Forest 2813997 1,330 121 302,235 173 87 0.006164 0.003082

01 Helena National Forest 1173925 537 49 121,971 70 35 0.005963 0.002982

03 Gila National Forest 2797628 1,276 116 290,078 166 83 0.005951 0.002975 ieRtratDEIS Retardant Fire 05 Mendocino National Forest 1079850 453 41 102,997 59 30 0.005474 0.002737

06 Deschutes National Forest 1853929 772 70 175,394 101 50 0.00543 0.002715 Appendices

04 Payette National Forest 2424840 1,007 92 228,755 131 66 0.005414 0.002707

03 Santa Fe National Forest 1734800 666 61 151,312 87 43 0.005006 0.002503 181 182 DEIS Retardant Fire Appendices USFS Region Forest Name Total % USFS % USFS Acres of Acres of Number of Avg Avg Land w/fire Land w/fire Acres1 impact at impact at Drops 2000- drop/yr3 gallon/yr retardant at 4 retardant at 8 4 gpc4 8 gpc4 20102 gpc4 gpc4

05 Plumas National Forest 1400902 530 48 120,546 69 35 0.004939 0.002469

08 National Forests In Florida 1254269 470 43 106,886 61 31 0.004891 0.002445

08 Cherokee National Forest 1204847 441 40 100,215 58 29 0.004774 0.002387

05 Stanislaus National Forest 1090039 393 36 89,274 51 26 0.0047 0.00235

03 Tonto National Forest 2969543 988 90 224,557 129 64 0.00434 0.00217

03 Cibola National Forest 2103528 699 64 158,826 91 46 0.004333 0.002167

Columbia River Gorge National 06 Scenic Area 72810 24 2 5,375 3 2 0.004237 0.002119

Wallowa-Whitman National 06 Forest 2393645 730 66 165,967 95 48 0.003979 0.00199

04 Wasatch-Cache National Forest 1077033 309 28 70,220 40 20 0.003742 0.001871

Beaverhead-Deerlodge National 01 Forest 1402656 402 37 91,366 52 26 0.003738 0.001869

01 Flathead National Forest 2628720 722 66 164,110 94 47 0.003583 0.001791

02 Pike-San Isabel National Forest 1288379 336 31 76,328 44 22 0.0034 0.0017

06 Umatilla National Forest 1512767 392 36 89,048 51 26 0.003378 0.001689

04 Boise National Forest 2959305 750 68 170,559 98 49 0.003308 0.001654

01 Custer National Forest 1278749 311 28 70,728 41 20 0.003174 0.001587

01 Gallatin National Forest 2151461 499 45 113,513 65 33 0.003028 0.001514

05 Six Rivers National Forest 1118247 234 21 53,292 31 15 0.002735 0.001368

05 Lake Tahoe Basin Mgt Unit 150000 31 3 7,088 4 2 0.002712 0.001356

05 Tahoe National Forest 1239729 235 21 53,380 31 15 0.002471 0.001236 USFS Region Forest Name Total % USFS % USFS Acres of Acres of Number of Avg Avg Land w/fire Land w/fire Acres1 impact at impact at Drops 2000- drop/yr3 gallon/yr retardant at 4 retardant at 8 4 gpc4 8 gpc4 20102 gpc4 gpc4

06 Willamette National Forest 1790946 332 75,394 43 22 0.002416 0.001208

04 Sawtooth National Forest 1894778 338 31 76,718 44 22 0.002324 0.001162

05 Sierra National Forest 1412801 237 22 53,845 31 15 0.002187 0.001094

06 Siuslaw National Forest 835749 135 12 30,662 18 9 0.002106 0.001053

05 Lassen National Forest 1375593 222 20 50,404 29 14 0.002103 0.001051

02 Nebraska National Forest 229926 37 3 8,351 5 2 0.002084 0.001042

03 Coconino National Forest 2013804 311 28 70,662 41 20 0.002014 0.001007

Rogue River-Siskiyou National 06 Forests 1851875 284 26 64,569 37 19 0.002001 0.001001

06 Malheur National Forest 1541723 231 21 52,456 30 15 0.001953 0.000976

06 Mt. Hood National Forest 1117921 167 15 37,899 22 11 0.001946 0.000973

Humboldt-Toiyabe National 04 Forest 2618165 385 35 87,476 50 25 0.001918 0.000959

Idaho Panhandle National 01 Forests 3715976 530 48 120,451 69 35 0.00186 0.00093

06 Colville National Forest 1029618 147 13 33,328 19 10 0.001858 0.000929

05 Klamath National Forest 1913264 271 25 61,496 35 18 0.001845 0.000922

01 Bitterroot National Forest 1655753 233 21 52,974 30 15 0.001836 0.000918 ieRtratDEIS Retardant Fire 04 Dixie National Forest 1967165 261 24 59,234 34 17 0.001728 0.000864

06 Umpqua National Forest 1027370 128 12 29,044 17 8 0.001622 0.000811 Appendices

04 Fishlake National Forest 1539737 189 17 43,029 25 12 0.001604 0.000802

04 Manti-Lasal National Forest 1338015 163 15 36,959 21 11 0.001585 0.000793 183 184 DEIS Retardant Fire Appendices USFS Region Forest Name Total % USFS % USFS Acres of Acres of Number of Avg Avg Land w/fire Land w/fire Acres1 impact at impact at Drops 2000- drop/yr3 gallon/yr retardant at 4 retardant at 8 4 gpc4 8 gpc4 20102 gpc4 gpc4

05 Modoc National Forest 1979327 224 20 51,004 29 15 0.001479 0.000739

01 Lolo National Forest 2637881 297 27 67,589 39 19 0.001471 0.000735

03 Kaibab National Forest 1601066 180 16 40,853 23 12 0.001464 0.000732

01 Lewis and Clark National Forest 1999256 206 19 46,854 27 13 0.001345 0.000673

02 San Juan National Forest 2108313 186 17 42,297 24 12 0.001151 0.000576

04 Salmon-Challis National Forest 4283345 375 34 85,128 49 24 0.001141 0.00057

04 Ashley National Forest 770604 67 6 15,160 9 4 0.001129 0.000565

01 Nez Perce National Forest 2258573 194 18 44,059 25 13 0.00112 0.00056

Medicine Bow-Routt National 02 Forest 1403892 119 11 26,948 15 8 0.001102 0.000551

09 Superior National Forest 3260630 268 24 60,849 35 17 0.001071 0.000536

04 Uinta National Forest 958707 74 7 16,897 10 5 0.001012 0.000506

06 Ochoco National Forest 979089 76 7 17,239 10 5 0.001011 0.000505

Grand Mesa, Uncompahgre and 02 Gunnison National Forests 351715 27 2 6,127 4 2 0.001 0.0005

National Forests In North 08 Carolina 2953501 206 19 46,773 27 13 0.000909 0.000454

02 Black Hills National Forest 1534471 102 9 23,176 13 7 0.000867 0.000433

04 Caribou-Targhee National Forest 2774744 174 16 39,547 23 11 0.000818 0.000409

04 Bridger-Teton National Forest 1744705 107 10 24,287 14 7 0.000799 0.000399

Arapaho and Roosevelt National 02 Forests 1876891 99 9 22,555 13 6 0.00069 0.000345

05 Inyo National Forest 2048459 108 10 24,541 14 7 0.000688 0.000344 USFS Region Forest Name Total % USFS % USFS Acres of Acres of Number of Avg Avg Land w/fire Land w/fire Acres1 impact at impact at Drops 2000- drop/yr3 gallon/yr retardant at 4 retardant at 8 4 gpc4 8 gpc4 20102 gpc4 gpc4

08 Ouachita National Forest 2723874 135 12 30,719 18 9 0.000647 0.000324

03 Carson National Forest 1490468 69 6 15,671 9 4 0.000603 0.000302

08 Ozark-St Francis National Forest 1988799 92 8 20,889 12 6 0.000603 0.000301

06 Gifford Pinchot National Forest 1409966 65 6 14,794 8 4 0.000602 0.000301

02 White River National Forest 2477646 110 10 24,978 14 7 0.000579 0.000289

01 Clearwater National Forest 1722132 70 6 15,798 9 5 0.000526 0.000263

01 Kootenai National Forest 2145268 80 7 18,204 10 5 0.000487 0.000244

05 Eldorado National Forest 887721 30 3 6,887 4 2 0.000445 0.000223

08 Daniel Boone National Forest 1360693 46 4 10,497 6 3 0.000443 0.000221

George Washington & Jefferson 08 National Forest 1795084 51 5 11,698 7 3 0.000374 0.000187

Francis Marion and Sumter 08 National Forests 414700 12 1 2,649 2 1 0.000367 0.000183

02 Shoshone National Forest 2466909 49 4 11,163 6 3 0.00026 0.00013

09 Chippewa National Forest 1599664 30 3 6,841 4 2 0.000245 0.000123

08 Kisatchie National Forest 1022373 19 2 4,210 2 1 0.000236 0.000118

02 Bighorn National Forest 1115160 19 2 4,360 3 1 0.000224 0.000112

ieRtratDEIS Retardant Fire 02 Rio Grande National Forest 1922766 18 2 4,038 2 1 0.000121 6.03E-05

06 Olympic National Forest 697496 4 0 1,021 1 0 8.4E-05 4.2E-05 Appendices 08 National Forests In Texas 1730936 10 1 2,383 1 1 7.9E-05 3.95E-05

08 National Forests In Mississippi 2938248 4 0 941 1 0 1.84E-05 9.19E-06 185 186 DEIS Retardant Fire Appendices USFS Region Forest Name Total % USFS % USFS Acres of Acres of Number of Avg Avg Land w/fire Land w/fire Acres1 impact at impact at Drops 2000- drop/yr3 gallon/yr retardant at 4 retardant at 8 4 gpc4 8 gpc4 20102 gpc4 gpc4

Mt Baker-Snoqualmie National 06 Forest 2900763 3 0 703 0 0 1.39E-05 6.95E-06

09 Huron Manistee National Forest 2025729 1 0 236 0 0 6.69E-06 3.34E-06

09 Mark Twain National Forest 3012464 1 0 236 0 0 4.5E-06 2.25E-06

Chattahoochee-Oconee National 08 Forests 0 0 0 0 0 0 0 0

10 Chugach National Forest 0 0 0 0 0 0 0 0

Land Between the Lakes 08 National Recreation Area 0 0 0 0 0 0 0 0

Midewin National Tallgrass 09 Prairie 0 0 0 0 0 0 0 0

09 Monongahela National Forest 0 0 0 0 0 0 0 0

08 National Forests in Alabama 0 0 0 0 0 0 0 0

09 Ottawa National Forest 0 0 0 0 0 0 0 0

09 Shawnee National Forest 0 0 0 0 0 0 0 0

10 Tongass National Forest 0 0 0 0 0 0 0 0

09 White Mountain National Forest 0 0 0 0 0 0 0 0

09 Allegheny National Forest 0 0 0 0 0 0 0

Chequamegon / Nicolet National 09 Forest 0 0 0 0 0 0 0 0

01 Dakota Prairie Grasslands 0 0 0 0 0 0 0 0

08 El Yunque National Forest 0 0 0 0 0 0 0 0

Green Mountain And Finger 09 Lakes National Forests 0 0 0 0 0 0 0 0 USFS Region Forest Name Total % USFS % USFS Acres of Acres of Number of Avg Avg Land w/fire Land w/fire Acres1 impact at impact at Drops 2000- drop/yr3 gallon/yr retardant at 4 retardant at 8 4 gpc4 8 gpc4 20102 gpc4 gpc4

09 Hiawatha National Forest 0 0 0 0 0 0 0 0

09 Hoosier National Forest 0 0 0 0 0 0 0 0

09 Wayne National Forest 0 0 0 0 0 0 0 0

Totals: 36,148 3,267 8,215,437 4,715 2,358

1 USFS 2010 Table 2 Lands area report: http://www.fs.fed.usdaland/staff/lar/LAR2010/lar2010index.html

2 Data derived from NIFC – ABS database 12/08/2010

3Data averaged over 2000-2011

4Calculations: gpc = 100 ft 2 ; 4gal/100sq ft = 1, 740 gal/acre; 8gal/100sqft=3,480 gal/acre - (43,500sqft/acre) ieRtratDEIS Retardant Fire Appendices 187 Appendices

Table C-3. Total Retardant Drops and Fires, 2000–2010.

FS Region National Forest State(s) Total Number of Total Number of Retardant Drops Fires 2000-2010 2000-2010

01 Beaverhead-Deerlodge National Forest MT 402 575

01 Bitterroot National Forest ID/MT 233 1,016

01 Clearwater National Forest ID 70 814

01 Custer National Forest MT 311 607

01 Dakota Prairie Grasslands SD, ND 0 272

01 Flathead National Forest MT 722 806

01 Gallatin National Forest MT 499 407

01 Helena National Forest MT 537 403

01 Idaho Panhandle National Forests ID 530 1,344

01 Kootenai National Forest MT 80 1,424

01 Lewis and Clark National Forest MT 206 303

01 Lolo National Forest MT 297 1,427

01 Nez Perce National Forest ID/MT 194 1,305

02 Arapaho and Roosevelt National Forests CO 99 573

02 Bighorn National Forest WY 19 156

02 Black Hills National Forest WY/SD 102 1,156

Grand Mesa, Uncompahgre and Gunnison National 02 Forests CO 27 506

02 Medicine Bow-Routt National Forest WY/CO 119 770

02 Nebraska National Forest NE 37 259

02 Pike-San Isabel National Forest CO 336 1,210

02 Rio Grande National Forest CO 18 186

02 San Juan National Forest CO 186 1,037

02 Shoshone National Forest WY 49 289

02 White River National Forest CO 110 449

03 Apache-Sitgreaves National Forests AZ 390 2,475

03 Carson National Forest NM 69 751

Fire Retardant DEIS 188 Appendices

FS Region National Forest State(s) Total Number of Total Number of Retardant Drops Fires 2000-2010 2000-2010

03 Cibola National Forest NM 699 1,090

03 Coconino National Forest AZ 311 4,074

03 Coronado National Forest AZ 1429 1,035

03 Gila National Forest NM 1276 2,077

03 Kaibab National Forest AZ 180 1,909

03 Lincoln National Forest NM 765 505

03 Prescott National Forest AZ 777 835

03 Santa Fe National Forest NM 666 1,395

03 Tonto National Forest AZ 988 2,451

04 Ashley National Forest UT 67 252

04 Boise National Forest ID 750 1,495

04 Bridger-Teton National Forest WY 107 738

04 Caribou-Targhee National Forest ID 174 654

04 Dixie National Forest UT 261 1,062

04 Fishlake National Forest UT 189 575

04 Humboldt-Toiyabe National Forest NV 385 1,609

04 Manti-Lasal National Forest UT/CO 163 699

04 Payette National Forest ID 1007 889

04 Salmon-Challis National Forest ID 375 842

04 Sawtooth National Forest ID 338 398

04 Uinta National Forest UT 74 503

04 Wasatch-Cache National Forest UT 309 518

05 Angeles National Forest CA 1257 1,240

05 Cleveland National Forest CA 314 762

05 Eldorado National Forest CA 30 961

05 Inyo National Forest CA 108 568

05 Klamath National Forest CA 271 1,159

Fire Retardant DEIS 189 Appendices

FS Region National Forest State(s) Total Number of Total Number of Retardant Drops Fires 2000-2010 2000-2010

05 Lake Tahoe Basin Mgt Unit CA/NV 31 435

05 Lassen National Forest CA 222 706

05 Los Padres National Forest CA 2,811 433

05 Mendocino National Forest CA 453 307

05 Modoc National Forest CA 224 1,055

05 Plumas National Forest CA 530 1,093

05 San Bernardino National Forest CA 1,607 1,463

05 Sequoia National Forest CA 978 668

05 Shasta Trinity National Forest CA 1,330 1,597

05 Sierra National Forest CA 237 1,006

05 Six Rivers National Forest CA 234 786

05 Stanislaus National Forest CA 393 767

05 Tahoe National Forest CA 235 878

06 Columbia River Gorge National Scenic Area OR 24 12

06 Colville National Forest WA 147 531

06 Deschutes National Forest OR 772 2,192

06 Fremont-Winema National Forests OR 1,218 1,385

06 Gifford Pinchot National Forest WA 65 357

06 Malheur National Forest OR 231 1,592

06 Mt Baker-Snoqualmie National Forest WA 3 439

06 Mt. Hood National Forest OR 167 694

06 Ochoco National Forest OR 76 921

06 Okanogan-Wenatchee National Forests WA 1,458 1,702

06 Olympic National Forest WA 4 91

06 Rogue River-Siskiyou National Forests OR 284 755

06 Siuslaw National Forest OR 135 95

06 Umatilla National Forest OR 392 992

Fire Retardant DEIS 190 Appendices

FS Region National Forest State(s) Total Number of Total Number of Retardant Drops Fires 2000-2010 2000-2010

06 Umpqua National Forest OR 128 766

06 Wallowa-Whitman National Forest OR 730 1,134

06 Willamette National Forest OR 332 1,176

08 Chattahoochee-Oconee National Forests GA 0 627

08 Cherokee National Forest TN 441 653

08 Daniel Boone National Forest KY 46 894

08 Francis Marion and Sumter National Forests SC 12 796

08 George Washington & Jefferson National Forest VA/WV 51 403

08 Kisatchie National Forest LA 19 663

08 Land Between the Lakes National Recreation Area KY, TN 0 16

08 National Forests in Alabama 0 571

08 National Forests In Florida FL 470 1,383

08 National Forests In Mississippi MS 4 1,197

08 National Forests In North Carolina NC 206 1,168

08 National Forests In Texas TX 10 517

08 Ouachita National Forest AR 135 818

08 Ozark-St Francis National Forest AR 92 459

09 Allegheny National Forest PA 111

09 Chequamegon / Nicolet National Forest WI 0 443

09 Chippewa National Forest MN 30 607

09 Green Mountain And Finger Lakes National Forests VT 0 16

09 Hiawatha National Forest MI 0 129

09 Hoosier National Forest IN 0 286

09 Huron Manistee National Forest MI 1 942

09 Mark Twain National Forest MO 1 1,730

09 Midewin National Tallgrass Prairie IL 0 13

09 Monongahela National Forest WV 0 106

Fire Retardant DEIS 191 Appendices

FS Region National Forest State(s) Total Number of Total Number of Retardant Drops Fires 2000-2010 2000-2010

09 Ottawa National Forest WI 0 60

09 Shawnee National Forest IL 0 234

09 Superior National Forest MN 268 626

09 Wayne National Forest OH 0 482

09 White Mountain National Forest NH 0 50

10 Chugach National Forest AK 0 94

10 Tongass National Forest AK 0 265

TOTAL 36,148 93,202

Fire Retardant DEIS 192 Table C-4. Representative Ecoregions for Retardant Application.

FS Description EcoRegions- Divisionsa Geo # fires Retardant Peak Fire Region Location 2000 – Application Seasonc 2010 Gallons /100 sq ftb

Shrubland, needleleaf forest annual and perennial Prairie; Temperate Desert; Temperate Steppe ; ID, MT, 10703 1 to 3 Apr-Oct grasslands, sagebrush with grass Temperate Steppe Mountains ND, SD, R1 WY

Shrubland, needleleaf forest, annual and perennial Temperate Desert; Temperate Desert Mountains; SD, NE, 6591 1 to 3 Jun-Oct grasslands, sagebrush with grass Temperate Steppe; Temperate Steppe Mountains; CO, WY Tropical/Subtropical Mountains; Tropical/Subtropical R2 Steppe

Shrubland, needleleaf forest, annual and perennial Temperate Steppe; Temperate Steppe Mountains; AZ, NM 18597 1 to 4 May-Jul grasslands, woodlands Tropical/Subtropical Desert; Tropical/Subtropical eastern NM Mountains; Tropical/Subtropical Steppe similar to R3 TX)

Shrubland, needleleaf forest; dry steppe, annual and Mediterranean Mountains; Temperate Desert; NV, UT, 10234 1 to 4 Jun-Oct perennial grasslands, woodlands Temperate Desert Mountains; Temperate Steppe ; WY, ID Temperate Steppe Mountains; Tropical /Subtropical R4 Desert; Tropical/Subtroical Steppe

Mosaic of fire adapted woodland/shrubland, needle Mediterranean; Mediterranean Mountains; Temperate CA 15884 3 to >6 Aug-Oct leaf evergreen and broadleaf woodlands; sagebrush Desert; Tropical/Subtropical Desert R5 with grass

Short needle closed confier; needle leaf evergreen Marine, Marine Mountains: Mediterranean Mountains; OR, WA 14834 3 to 4 Jun-Oct and broadleaf woodlands; sagebrush with grass; short Temperate Desert; Temperate Steppe Mountains R6 needle conifer

Cold-deciduous broadleaf forests; cold-deciduous Hot Continental; Hot Continental Mountains; Prairie; South 10165 2 Sep-Jul broadleaf forests; fall hardwood; southern rough; Savanna Mountains; Subtropical Eastern summer hardwood; herbaceous with broadleaf; U.S. ieRtratDEIS Retardant Fire R8 shrublands

Short and long needle conifer cold-deciduous Hot Continental; Hot Continental Mountains; Prairie; North 5835 2 Apr-Oct

broadleaf forests; summer hardwood; herbaceous Warm Continental Eastern Appendices R9 woodlands; shrublands

R10 Pacific coastal mountains and meadows Marine Mountains; Subartic AK 359 3 to 6 Jun-Sep 193 194 DEIS Retardant Fire Appendices Appendix D – Misapplication of Fire Retardant Data Analysis

Table D-1. Misapplication of Fire Retardant Data, 2008–2010.

Year Region Forest Fire Intrusion Loads Drops Accidental Exception Direct Buffer Terrestrial Gallons Gallons Gallons Notes Reports to Only TES Estimated Estimated Estimated water Water Buffer Terrestrial

Corn R42008 Dixie Creek 2 332 3 1103

R52008 Mendicino Lantz 1 111 1

R52008 Mendicino Mill/soda 1 111 1 1

R52008 San B Slide 1 11 1 1 2700

Royce R62008 Deschutes Butte 1 111 1 2500 wetland*

some in R62008 Malheur Deardorff 1 111 1 1100 water*

R62008 Mt. Hood Barlow 1 111 1 1800

R62008 Mt. Hood Polallie ck 1 111 1 40 400

R62008 Mt. Hood Eliot 1 111 1 20 500

R62008 Willamette Red King 1 111 1 284

2008 Total 11 111211 1 039 3948 6500 0

R32009 Coconino Reservoir 1 131313 13 27817

R42009 Boise Needles 1 221 2 150

R52009 Angeles Station 1 11 1 1 3000

R52009 Los Padres Ponderoso 1 111 1 2 50

R52009 Mendicino Summit 1 111 1 3000

R52009 Plumas Silver 1 111 1 20

R52009 Shasta-T Backbone 1 11 1 1 500 Year Region Forest Fire Intrusion Loads Drops Accidental Exception Direct Buffer Terrestrial Gallons Gallons Gallons Notes Reports to Only TES Estimated Estimated Estimated water Water Buffer Terrestrial

R62009 Malheur 251 1 333 3 10

R62009 Willamette Canal Ck 1 111 1 2082

2009 Total 9 222423 2 1329 6182 2632 27817

R32010 Ap-Sit Boggy 1 222 2 150

R42010 Boise Hurd 5 555 5 664

R42010 Boise Grimes 1 111 1 10

R42010 Sawtooth Deer Park 1 111 1 7

Salmone R42010 Challis Banner 1 111 1 215

R52010 Cleveland Tenaja 2 1 111 1

R52010 Lassen Windy 1 111 1 2.5

R52010 San B Division 1 11 1 1

R52010 Shasta-T Hidden 1 21 2 2

R52010 Sequoia Bull 1 111 1 30

R62010 Deschutes Incident 1 121 2 drift*

R62010 Willamette Scott Mtn 2 222 2 2317

* talked to shirley drops into marginal ieRtratDEIS Retardant Fire spotted owl R62010 Willamette Scott Mtn 1 4848 48 48 habitat

2010 Total 18 166866 51 49514 3395.5 0 0 Appendices 195 Appendices

The 13 drops on the Coconino NF in 2009 were all in terrestrial habitat for the Mexican spotted owl on one fire.

The 48 drops on the Willamette NF in 2010 were all in terrestrial habitat – marginal dispersal habitat, for the northern spotted owl, again all on one fire.

These two incidents would have No Effect on spotted owl habitat since owl habitat consists of mature and old-growth forest conditions; both which would not be changed with the application of fire retardant. Marginal dispersal consists of mixed coniferous forest habitat which is around 11 inches diameter breast height with at least 40 percent canopy closure. Again, fire retardant would not change conditions; for habitat.

Fire Retardant DEIS 196 Appendices

Appendix E – National Screen for Federally Listed Species and Critical Habitat Impacts

Table E-1. National Screening Process.

Impact1 National Screening Factor Aerially Applied Retardant Retardant Application Potential

NE If species/habitat occur in areas with no fires. No fires = no potential for retardant use. None

NE If no fire or retardant recorded in past 10 years on forests where species are suspected oroccur None critical habitat is designated (assumption future fires would be put out without aerial resources).

NE Designated critical habitat areas protected with avoidance mapping or the use of fire retardant does Low not impact or change the Primary Constituent Elements.

Aquatics

LAA If a Forest/Grassland has more than 1 retardant drops a year then the chance of misapplication is greater than 0.1%.

Terrestrial

NLAA If species is not an isolated population2 and aerial application of fire retardant is applied on less than Low 0.01% annually on a specific forest where species occurs or is suspected of occurring (by forest based on past 10 yr data).

NLAA If a species occurs or is suspected of occurring on a forest with more than 0.01% annually, yet occurs Low in habitats with very low likelihood of retardant application.

LAA Aerial application of fire retardant is applied on more than 0.01% annually on NFS lands (basedon Mod-high past 10 yr data).

LAA If species is a small isolated population2 and occurs on any forest where retardant application is likely Low-high to occur (based on past 10 yr data) - recognizing impact to these species from a misapplication or invoking an exception.

1NE = No Effect, NLAA = May Affect, Not Likely to Adversely Affect, LAA = Likely to Adversely Affect

2Isolated population: location where individual(s) or population(s) occur within a small isolated area where the application of retardant could reduce viability or jeopardize the further existence of the species (one watershed, one canyon, etc). Assumptions used for the effects screening process

Historical Fire Season Data: The 2000-2010 fire season statistics provide a reasonable representation ofthe risk of retardant applications in the next 10-15 years relative to the USFS landbase even though past or future decades could have more fires (Geier-Hayes, 2011). Known species occurrences and designated critical habitat areas would be protected from adverse effects by avoidance area designations that direct use of retardant away from these areas. Designated critical habitat

Fire Retardant DEIS 197 Appendices

where the use of aerial application of fire retardant does not affect or change primary constituent elements does not require protection or avoidance mapping. Misapplication of retardant in terrestrial habitats has only been documented for the past three years; reporting misapplications on 1 fire event in 2009, and two fire events in 2010. Use of this data is not adequate atthis time to apply any predictability of when, where or how many misapplications may occur in the future. Assuming that the potential for a misapplication is higher in areas where more retardant is applied, all species that occur in these areas are considered be impacted unless other factors (habitats) determine otherwise. Based on 3 years of misapplication data in aquatic habitats, .001% chance of hitting water or the buffer, then 10 drops of less applied to a Forest/Grassland results in a 99.99% probability of not hitting water or the buffer area. Because each drop carries greater than a 0.01% chance of hitting water (0.09% chance of hitting water), we would be unable to identify any low risk forests.

Elements of the proposed federal action that are providing additional protections or validation

Monitoring will occur on 5% of the unstaffed fires per forest where aerial application of fire retardant wasusedto validate whether the guidelines are providing adequate protection; if found that retardant is affecting T&E species habitat or populations, then thresholds for restricting use of aerial application within that area will be determined at the local level. During monitoring, all non-native plant species will be removed from areas of concern as appropriate for the area and listed species affected, as determined in consultation with the appropriate Service office. Appropriate weed control methods will be developed during local consultation with field offices as needed.

Acknowledge the misapplication of aerial application may occur; however, data reported from 2008-2010 shows this to be less than 0.1 percent of the total loads for a given year. Screening Process for all Federally Listed Threatened & Endangered Species, Terrestrial Wildlife and Amphibian Species

The following flowcharts demonstrate the logic use to make determination of effects for the potential useofaerial application of fire retardant when in the vicinity of Federal Listed T&E Species and Critical Habitat. Thisprocess will analyze T&E Species and Critical Habitat in STEPs 1-3, using the National T&E Species (Table WL –1). Effects Screen for T & E Species Critical Habitat: Screen 1

Potential to Use Aerial Application of Fire Retardant: (based on 10 yr average from retardant drop data)

Effects to Critical Habitat and Primary Constitute Elements (PCEs):

Fire Retardant DEIS 198 Appendices

Fire Retardant DEIS 199 Appendices

Effects Screens for T &E Species: Screens 2 and 3

Effects of the use of aerial application of retardant on individuals species or populations can be influenced by the species ability to avoid areas where fires are burning (mobility), and by the length (term) or timing of theevent.

Mobility may be limited by the given taxon for a species. For instance, birds are very mobile with their ability to fly; however, given nesting and rearing season, may or not flee an area. Also, if a species is highly specializedwith limited habitat, the individual may not flee far from the area.

Similarly with mammals, larger more wide ranging species, such as lynx and grizzly bear, would be less likely to be affect at all by the use of aerial application of retardant. Whereas with a small rodent, such as a kangaroo rat, this species is limited in it’s ability to avoid fire since it is tied to specific habitat type. Amphibians are theleast mobile of all taxon groups due to their direct dependence on specific habitats, and very limited distributions, such as with the mountain yellow-legged frog.

Fire Retardant DEIS 200 Appendices

Length of Effect

Short - term Immediate Expected to last less than a couple of days; no impacts to life cycle

Long - term Substanstial Will last longer; expected to interrupt portion of life cycle

Likelihood of Fire Event -Timing of Effect

During critical time period Fire event likely to occur during reproduction and rearing of offspring

Outside critical time period Fire event not expected to affect species reproductive viability

DISTRIBUTION

Very limited only known for a limited area/pop

Limited known for few small areas/few pops

Moderate covers several areas/populations

Wide covers several states/populations

Fire Retardant DEIS 201 Appendices

Effects Screens for Forest Service Sensitive Species: Screen 4

Screen process for Sensitive Species will follow T&E Step 2 without the critical habitat portion.

Fire Retardant DEIS 202 Appendices

Effects Screens for Forest Service Sensitive Species: Screen 5

Screen process for Sensitive species will follow T&E Step 3.

Fire Retardant DEIS 203 Appendices

Effects Screen for Ingestion of Fire Retardant for all TEPCS Species: Screen 6

Fire Retardant DEIS 204 Appendix F – Fish and Aquatic Invertebrate Species List and Effects Federally Listed Species and Designated Critical Habitats

Table F-1. Federally Listed Threatened, Endangered and Proposed Aquatic Vertebrate and Invertebrate Species Known or Suspected to Occur on or Near Forest Service Lands with the Potential for Aerial Application of Fire Retardant (Under Both FWS and NOAA Jurisdiction).

Forest Service Regions Common Name Federal NatureServe Global Sci. Name Critical Sub-group Status Habitat R10R9R8R6R5R4R3R2R1

5 Conservancy Fairy Shrimp E Branchinecta conservatio Y Crustaceans

5 Longhorn Fairy Shrimp E Branchinecta longiantenna Y Crustaceans

5 Vernal Pool Fairy Shrimp T Branchinecta lynchi Y Crustaceans

8 A Cave Crayfish E Cambarus aculabrum Crustaceans

8 Hell Creek Cavefish E Cambarus zophonastes Crustaceans

5 Vernal Pool Tadpole Shrimp E Lepidurus packardi Y Crustaceans

5 Shasta Crayfish E Pacifastacus fortis Crustaceans

8 Cumberland Elktoe E Alasmidonta atropurpurea Y Mollusks

8 Dwarf Wedgemussel E Alasmidonta heterodon Mollusks

8 Appalachian Elktoe E Alasmidonta raveneliana Y Mollusks

8 Fat Three-Ridge Mussel E Amblema neislerii Y Mollusks

8 Ouachita Rock Pocketbook E Arkansia wheeleri Mollusks

ieRtratDEIS Retardant Fire 98 Fanshell E Cyprogenia stegaria Mollusks

8 Dromedary Pearlymussel E Dromus dromas Mollusks

8 Purple Bankclimber Mussel T Elliptoideus sloatianus Y Mollusks Appendices

8 Cumberlandian Combshell E Epioblasma brevidens Y Mollusks

8 Oyster Mussel E Epioblasma capsaeformis Y Mollusks 205 206 DEIS Retardant Fire Appendices Forest Service Regions Common Name Federal NatureServe Global Sci. Name Critical Sub-group Status Habitat R10R9R8R6R5R4R3R2R1

9 Curtis Pearlymussel E Epioblasma florentina curtisi Y Mollusks

8 Yellow Blossom (Pearlymussel) E Epioblasma florentina florentina Mollusks

8 Tan Riffleshell E Epioblasma florentina walkeri Mollusks

8 Upland Combshell E Epioblasma metastriata Mollusks

8 Purple Cat’s Paw Pearlymussel E Epioblasma obliquata obliquata Mollusks

8 Southern Acornshell E Epioblasma othcaloogensis Y Mollusks

8 Green Blossom (Pearlymussel) E Epioblasma Torulosa gubernaculum Mollusks

98 Northern Riffleshell E Epioblasma torulosa rangiana Y Mollusks

8 Tubercled-blossom Pearlymussel E Epioblasma torulosa torulosa Mollusks

9 Snuffbox PE Epioblasma triquetra Mollusks

8 Turgid Blossom E Epioblasma turgidula Y Mollusks

8 Shiny Pigtoe E Fusconaia cor Mollusks

8 Finerayed Pigtoe E Fusconaia cuneolus Mollusks

8 Cracking Pearlymussel E Hemistena lata Mollusks

98 Pink Mucket E Lampsilis abrupta Y Mollusks

8 Finelined Pocketbook T Lampsilis altilis Y Mollusks

8 Orangenacre Mucket T Lampsilis pervovalis Y Mollusks

8 Arkansas Fatmucket T Lampsilis powellii Mollusks

8 Shinyrayed pocketbook E Lampsilis subangulata Y Mollusks

8 Carolina Heelsplitter E Lasmigona decorata Y Mollusks

8 Birdwing Pearlymussel E Lemiox rimosus Mollusks

98 Scaleshell Mussel E Leptodea leptodon Y Mollusks

8 Louisiana Pearlshell T Margaritifera hembeli Mollusks Forest Service Regions Common Name Federal NatureServe Global Sci. Name Critical Sub-group Status Habitat R10R9R8R6R5R4R3R2R1

8 Alabama Moccasinshell T Medionidus acutissimus Y Mollusks

8 Coosa Moccasinshell E Medionidus parvulus Y Mollusks

8 Ochlockonee Moccasinshell E Medionidus simpsonianus Y Mollusks

8 Ring Pink (Mussel) E Obovaria retusa Mollusks

8 Littlewing Pearlymussel E Pegias fabula Mollusks

9 Orangefoot pimpleback E Plethobasus cooperianus Y Mollusks

8 Clubshell E Pleurobema clava Mollusks

8 James Spinymussel E Pleurobema collina Mollusks

8 Southern Clubshell E Pleurobema decisum Y Mollusks

8 Dark Pigtoe E Pleurobema furvum Y Mollusks

8 Southern Pigtoe E Pleurobema georgianum Y Mollusks

8 Ovate Clubshell E Pleurobema perovatum Y Mollusks

98 Rough Pigtoe E Pleurobema plenum Y Mollusks

8 Oval Pigtoe E Pleurobema pyriforme Y Mollusks

8 Heavy Pigtoe E Pleurobema taitanum Y Mollusks

8 Fat Pocketbook E Potamilus capax Y Mollusks

8 Heavy Pigtoe E Potamilus inflatus Y Mollusks

8 Triangular Kidneyshell E Ptychobranchus greenii Y Mollusks ieRtratDEIS Retardant Fire 8 Rough Rabbitsfoot E Quadrula cylindrica strigillata Y Mollusks

8 Winged Maplefoot E Quadrula fragrosa Mollusks Appendices 8 Cumberland Monkeyface (pearlymussel) E Quadrula intermedia Mollusks

8 Appalachian Monkeyface E Quadrula sparsa Mollusks

207 8 Purple Bean Mussel E Villosa perpurpurea Y Mollusks 208 DEIS Retardant Fire Appendices Forest Service Regions Common Name Federal NatureServe Global Sci. Name Critical Sub-group Status Habitat R10R9R8R6R5R4R3R2R1

8 Cumberland Bean Pearlymussel E Villosa trabalis Mollusks

8 Shortnose Sturgeon E Acipenser brevirostrum Fish

5 Green Sturgeon (Southern DPS) T Acipenser mediosteris Fish

8 Gulf Sturgeon T Acipenser oxyrinchus desotoi Y Fish

1 White Sturgeon (Kootenai R. Pop.) E Acipenser transmontanus Y Fish

65 Modoc sucker E Catostomus microps Y Fish

5 Santa Ana Sucker T Catostomus santaanae Y Fish

6 Warner Sucker T Catostomus warnerensis Y Fish

65 Shortnose Sucker E Chasmistes brevirostris Y Fish

4 June Sucker E Chasmistes liorus Y Fish

8 Pygmy Sculpin T Cottus patulus Fish

4 Railroad Valley Springfish T Crenichthys nevadae Y Fish

8 Blue Shiner T Cyprinella caerulea Fish

3 Desert Pupfish E Cyrinodon macularius Y Fish

65 Lost River Sucker E Deltistes luxatus Y Fish

8 Spotfin Chub T Erimonax monacha Y Fish

8 Slender Chub T Erimystax cahni Y Fish

8 Etowah Darter E Etheostoma etowahae Y Fish

8 Duskytail Darter E Etheostoma percnurum Fish

8 Rush Darter PE Etheostoma phytophilum Fish

8 Cumberland Darter PE Etheostoma susanae Fish

5 Tidewater Goby E Eucyclogobius newberryi Fish Forest Service Regions Common Name Federal NatureServe Global Sci. Name Critical Sub-group Status Habitat R10R9R8R6R5R4R3R2R1

5 Unarmored Threespine Stickleback E Gasterosteus aculeatus williamsoni Fish

5 Owens Tui Chub E Gila bicolor snyderi Fish

2 4 Humpback Chub E Gila cypha Y Fish

3 Sonora Chub T Gila ditaenia Y Fish

2 4 Bonytail Chub E Gila elegans Y Fish

3 Gila Chub E Gila intermedia Y Fish

3 Chihuahua Chub T Gila nigrescens Fish

3 Yaqui Chub E Gila purpurea Y Fish

3 Rio Grande Silveryminnow E Hybognathus amarus Y Fish

5 Delta Smelt T Hypomesus transpacificus Y Fish

3 Yaqui Catfish T Ictalurus pricei Y Fish

3 Little Colorado Spinedace T Lepidomeda vittata Y Fish

3 Spikedace T Meda fulgida Y Fish

8 Palezone Shiner E Notropis albizonatus Fish

8 Cahaba Shiner E Notropis cahabae Y Fish

3 Arkansas River Shiner T Notropis girardi Y Fish

8 Cape Fear Shiner E Notropis mekistocholas Y Fish

Topeka Shiner E Notropis topeka Y Fish ieRtratDEIS Retardant Fire 8 Smoky Madtom E Noturus baileyi Y Fish

8 Yellowfin Madtom T Noturus flavipinnis Y Fish Appendices 5 Little Kern Golden Trout T Oncorhynchus clarki henshawi Y Fish

54 Lahontan Cutthroat Trout T Oncorhynchus clarki seleniris Fish

209 6 Chum Salmon (Columbia River) T Oncorhynchus keta Y Fish 210 DEIS Retardant Fire Appendices Forest Service Regions Common Name Federal NatureServe Global Sci. Name Critical Sub-group Status Habitat R10R9R8R6R5R4R3R2R1

6 Chum Salmon (Hood Canal summer-run) T Y Fish

6 Coho Salmon (Lower Columbia River) T Oncorhynchus kisutch Fish

65 Coho Salmon (Southern Oregon/Northern T Y Fish California)

6 Coho Salmon (Oregon Coast) T Y Fish

1 4 6 Steelhead (Snake River Basin) T Oncorhynchus mykiss Y Fish

6 Steelhead (Lower Columbia River) T Y Fish

6 Steelhead (Middle Columbia River) T Y Fish

6 Steelhead (Upper Columbia River) E Y Fish

6 Steelhead (Puget Sound) T Fish

6 Steelhead (Upper Willamette River) T Y Fish

5 Steelhead (Southern California) E Y Fish

5 Steelhead (Central Valley) T Y Fish

5 Steelhead (South-Central CA Coast) T Y Fish

5 Steelhead (Northern California) T Y Fish

1 4 6 Sockeye Salmon (Snake River) E Oncorhynchus nerka Y Fish

5 Chinook Salmon (Sacramento R., winter E Oncorhynchus tshawystscha Y Fish run)

1 4 6 Chinook Salmon (Snake R., T Y Fish spring/summer run)

1 6 Chinook Salmon (Snake R., fall run) T Y Fish

6 Chinook Salmon (Lower Columbia River) T Y Fish

6 Chinook Salmon (Upper Columbia R. E Fish spring-run)

6 Chinook Salmon (Puget Sound) T Y Fish Forest Service Regions Common Name Federal NatureServe Global Sci. Name Critical Sub-group Status Habitat R10R9R8R6R5R4R3R2R1

6 Chinook Salmon (Upper Willamette T Y Fish River)

5 Chinook Salmon (Central Valley T Y Fish spring-run)

5 Chinook Salmon (California Coastal) T Y Fish

6 Oregon Chub E Oregonichthys crameri Fish

8 Amber Darter E Percina antesella Y Fish

8 Goldline Darter T Percina aurolineata Y Fish

8 Conasauga Logperch E Percina jenkinsi Y Fish

8 Leopard Darter T Percina pantherina Y Fish

8 Roanoke Logperch E Percina rex Fish

8 Snail Darter T Percina tanasi Y Fish

8 Blackside Dace T Phoxinus cumberlandensis Fish

3 Gila Topminnow E Poeciliopsis occidentalis Fish

432 Colorado (=squawfish) Pikeminnow E Ptychocheilus lucius Fish

4 Kendall Warm Springs Dace E Rhinichthys osculus thermalis Fish

1 4 6 Bull Trout T Salvelinus confluentus Y Fish

2 4 98 Pallid Sturgeon E Scaphirhynchus albus Fish

8 Alabama Sturgeon E Scaphirhynchus suttkusi Y Fish

ieRtratDEIS Retardant Fire 3 Loach Minnow T Tiaroga cobitis Y Fish

432 Razorback Sucker E Xyrauchen texanus Y Fish Appendices 211 Appendices

Table F-2. Likely to Adversely Affect (LAA) Determinations for Fish Species by National Forest Based on Retardant Use (Under Both FWS and NOAA Jurisdiction).

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

Nez Perce National Forest 1801 44,059 LAA LAA Bull Trout

LAA LAA Bull Trout Bitterroot National Forest 2101 52,974 LAA LAA Steelhead (Snake River)

Lolo National Forest 2701 67,589 LAA LAA Bull Trout

Beaverhead-Deerlodge LAA LAA Bull Trout 3701 91,366 National Forest

Idaho Panhandle National LAA LAA Bull Trout 4801 120,451 Forests

Helena National Forest 4901 121,971 LAA LAA Bull Trout

Flathead National Forest 6601 164,110 LAA LAA Bull Trout

Clearwater National LAA LAA Bull Trout 601 15798 Forest

LAA LAA White Sturgeon (Kootenai R. Pop.) Kootenai National Forest 701 18,204 LAA LAA Bull Trout

LAA LAA Humpback chub

LAA LAA Bonytail Chub San Juan National Forest 1702 42,297 LAA LAA Colorado Pikeminnow

LAA LAA Razorback Sucker

LAA LAA Colorado (=squawfish) Pike minnow LAA NONE Pallid Sturgeon Arapaho and Roosevelt 902 22,555 LAA LAA National Forests Bonytail Chub LAA LAA Humpback Chub LAA NONE Greenback Cutthroat Trout

White River National LAA LAA Razorback Sucker 1002 24,978 Forest

Fire Retardant DEIS 212 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA LAA Colorado (=squawfish) Pikeminnow LAA LAA Bonytail Chub LAA LAA Humpback Chub LAA NONE Greeenback Cuttthroat Trout

LAA LAA Spikedace

LAA NONE Apache(Arizona) Trout Kaibab National Forest 1603 40,853 LAA LAA Loach Minnow

LAA LAA Razorback Sucker

LAA LAA Gila Chub

LAA LAA Little Colorado Spinedace

LAA LAA Spikedace Coconino National Forest 2803 70,662 LAA NONE Gila Trout

LAA LAA Loach Minnow

LAA LAA Colorado Pikeminnow

LAA LAA Razorback Sucker

LAA NONE Apache(Arizona) Trout

LAA NONE Gila Trout

Apache-Sitgreaves LAA LAA Spikedace 3503 88,609 National Forests LAA LAA Little Colorado Spinedace

LAA LAA Gila Chub

LAA LAA Loach Minnow

LAA LAA Arkansas River Shiner Cibola National Forest 6403 158,826 LAA LAA Silvery Minnow

Fire Retardant DEIS 213 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA LAA Razorback Sucker

LAA LAA Desert Pupfish

LAA LAA Gila Chub

LAA LAA Spikedace Prescott National Forest 7103 176,693 LAA NONE Gila TopminnoW

LAA LAA Loach Minnow

LAA NONE Colorado Pikeminnow

LAA LAA Razorback Sucker

LAA LAA Desert Pupfish

LAA ALL Gila Chub

LAA LAA Spike Dace Tonto National Forest 9003 224,557 LAA NONE Gila Trout

LAA NONE Gila Topminnow

LAA LAA Loach Minnow

LAA NONE Colorado Pikeminnow

LAA LAA Gila Chub

LAA NONE Chihuahua chub

LAA LAA Little Colorado Spinedace Gila National Forest 03 116 290,078 LAA LAA Spikedace

LAA NONE Gila Trout

LAA LAA Loach Minnow

LAA LAA Sonora Chub

LAA LAA Desert pupfish Coronado National Forest 03 130 324,770 LAA LAA Gila Chub

LAA LAA Yaqui Chub

Fire Retardant DEIS 214 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA LAA Spikedace

LAA NONE Apache (Arizona Trout)

LAA NONE Gila Trout

LAA NONE Gila Topminnow

LAA LAA Razorback

LAA Yaqui Catfish

LAA LAA Humpback chub

LAA NONE Greenback cutthroat trout LAA Manti-Lasal National LAA Razorback Sucker 1504 36,959 Forest LAA LAA Bonytail Chub LAA LAA Colorado Pikeminnow

LAA LAA Humpback chub

LAA LAA Razorback Sucker Fishlake National Forest 1704 43,029 LAA LAA Bonytail Chub

LAA LAA Colorado pikeminnow

LAA LAA Humpback chub Dixie National Forest 2404 59,234 LAA LAA Razorback Sucker

LAA LAA Humpback chub

LAA LAA Razorback Sucker LAA LAA Wasatch-Cache National June Sucker 2804 70,220 Forest LAA LAA Bonytail Chub LAA LAA Colorado Pikeminnow

LAA LAA Bull Trout Sawtooth National Forest 3104 76,718 LAA LAA Sockeye Salmon (Snake River)

Fire Retardant DEIS 215 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA LAA Bull Trout

LAA LAA Sockeye Salmon (Snake River) Salmon-Challis National 3404 85,128 LAA LAA Chinook Salmon (Snake Forest Spring/Summer) LAA LAA Steelhead (Snake River)

LAA LAA Railroad Valley Springfish

Humboldt-Toiyabe LAA NONE Lahontan Cutthroat Trout 3504 87,476 National Forest LAA NONE Paiute Cutthroat Trout

LAA LAA Bull Trout

Steelhead (Snake River) Boise National Forest 6804 170,559 Chinook Salmon (Snake Spring/Summer)

LAA LAA Bull Trout

LAA LAA Steelhead (Snake River) Payette National Forest 9204 228,755 LAA LAA Chinook Salmon (Snake Spring/Summer)

LAA LAA Razorback Sucker

LAA LAA Colorado (=squawfish) Pike minnow Ashely National Forest 604 15,160 LAA LAA Bonytail Chub LAA LAA Humpback Chub

LAA LAA June Sucker

LAA LAA Razorback Sucker

LAA LAA Colorado (=squawfish) Pike Uinta National Forest 704 16,897 minnow LAA LAA Bonytail Chub LAA LAA

Fire Retardant DEIS 216 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

Humpback Chub

LAA NONE Kendall Warm Springs Dace

LAA LAA Razorback Sucker

LAA LAA Colorado (=squawfish) Pike minnow Bridger-Teton National 1004 24,287 LAA NONE Forest Pallid Sturgeon LAA LAA Bonytail Chub LAA LAA Humpback Chub

LAA LAA Modoc sucker

LAA LAA Shortnose Sucker Modoc National Forest 2005 51,004 LAA LAA Lost River Sucker

LAA None Green Sturgeon (Southern DPS)

LAA LAA Coho Salmon (S. Oregon/N. CA Coast) LAA LAA Steelhead (Northern California) Six Rivers National Forest 2105 53,292 LAA LAA Chinook Salmon (California LAA LAA Coastal)

Pacific eulachon

LAA None Lahontan Cutthroat Trout

LAA LAA Chinook Salmon (Sacramento Tahoe National Forest 2105 53,380 Winter Run) LAA LAA Steelhead (Central Valley)

LAA None Lahontan Cutthroat Trout

LAA None Paiute Cutthroat Trout Sierra National Forest 2205 53,845 LAA None Owens Tui Chub

LAA LAA Green Sturgeon

Fire Retardant DEIS 217 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA LAA Shortnose Sucker

LAA LAA Lost River Sucker

Klamath National Forest 2505 61,496 LAA LAA Coho Salmon (S. Oregon/N. CA Coast) LAA LAA Pacific eulachon

LAA NONE Lahontan Cutthroat Trout Stanislaus National Forest 3605 89,274 LAA NONE Paiute Cutthroat Trout

LAA LAA Green Sturgeon (Southern DPS)

LAA LAA Steelhead (Northern California)

LAA LAA Chinook Salmon (Central Valley Spring) LAA LAA Chinook Salmon (California Mendocino National LAA LAA Coastal) 4105 102,997 Forest LAA LAA Chinook Salmon (Sacramento Winter Run) LAA LAA Coho Salmon (S. Oregon/N. CA Coast)

Steelhead (Central Valley)

LAA LAA Chinook Salmon (Sacramento Winter Run) Plumas National Forest 4805 120,546 LAA LAA Steelhead (Central Valley)

Sequoia National Forest 8905 222,385 LAA LAA Little Kern Golden Trout

LAA LAA Santa Ana Sucker Angeles National Forest 05 114 285,573 LAA LAA Steelhead (Southern California)

LAA LAA Shortnose Sucker

Shasta Trinity National LAA LAA Lost River Sucker 05 121 302,235 Forest LAA LAA Coho Salmon (S. Oregon/N. CA Coast)

Fire Retardant DEIS 218 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA LAA Chinook Salmon (Sacramento Winter Run) LAA LAA Steelhead (Central Valley) LAA LAA Chinook Salmon (Central Valley LAA LAA Spring)

LAA LAA Chinook Salmon (California Coastal) LAA NONE Steelhead (Northern California)

Green Sturgeon

LAA LAA Santa Ana Sucker San Bernardino National 05 146 365,271 Forest LAA NONE Shay Creek Stickleback

LAA LAA Santa Ana Sucker

LAA LAA Steelhead (South-Central CA Los Padres National 05 256 638,947 Coast) Forest LAA LAA Steelhead (Southern California)

LAA LAA Lahontan Cutthroat Trout Inyo National Forest 1005 24,541 LAA LAA Paiute Cutthroat Trout

Umpqua National Forest 1206 29,044 LAA NONE Oregon Chub

Colville National Forest 1306 33,328 LAA LAA Bull Trout

Mt. Hood National Forest 1506 37,899 LAA LAA Bull Trout

LAA LAA Bull Trout Malheur National Forest 2106 52,456 LAA LAA Middle Columbia River Steelhead

LAA LAA Green Sturgeon (Southern DPS)

LAA LAA Coho Salmon (S. Oregon/N. CA Rogue River-Siskiyou 2606 64,569 Coast) National Forests LAA Coho Salmon (Oregon Coast)

Fire Retardant DEIS 219 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA NONE Oregon Chub

LAA LAA Bull Trout Willamette National 3006 75,394 LAA LAA Chinook Salmon (Upper Forest Willamette) LAA LAA Steelhead (Upper Willamette)

LAA LAA Bull Trout

LAA LAA Chinook Salmon (Snake Spring/Summer) LAA LAA Chinook Salmon (Snake Fall Run) Umatilla National Forest 3606 89,048 LAA LAA Steelhead (Snake River) LAA LAA Steelhead (Middle Columbia River)

LAA LAA Sockeye Salmon (Snake River)

LAA LAA Chinook Salmon (Snake Spring/Summer) Wallowa-Whitman 6606 165,967 LAA LAA National Forest Chinook Salmon (Snake Fall Run) LAA LAA Steelhead (Snake River)

Deschutes National Forest 7006 175,394 LAA LAA Bull Trout

LAA LAA Chinook Salmon (Upper Columbia River) LAA LAA Okanogan/Wenatchee Steelhead (Middle Columbia 06 133 331,364 National Forests LAA LAA River)

Steelhead (Upper Columbia River)

LAA LAA Bull Trout

LAA LAA Modoc Sucker Fremont-Winema 06 111 276,773 LAA LAA Shortnose Sucker National Forests LAA LAA Lost River Sucker

LAA LAA Warner Sucker

Fire Retardant DEIS 220 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA LAA Chum Salmon (Columbia River)

LAA NONE Coho Salmon (Lower Columbia River) LAA LAA Chinook Salmon (Snake LAA LAA Spring/Summer)

LAA LAA Chinook Salmon (Snake River Fall Run) LAA LAA Chinook Salmon (Lower Columbia Columbia River Gorge 206 5375 LAA LAA River)

LAA LAA Steelhead (Snake River)

LAA LAA Steelhead (Lower Columbia River)

LAA LAA Steelhead (Middle Columbia River)

Steelhead (Upper Columbia River)

Pacific eulachon

LAA NONE Coho Salmon (Lower Columbia River) LAA LAA Gifford Pinchot National Chinook Salmon (Lower Columbia 606 14,794 Forest LAA LAA River)

Steelhead (Lower Columbia River)

LAA LAA Shortnose Sturgeon

National Forests In North LAA LAA Cape Fear Shiner 1908 46,773 Carolina LAA LAA Spotfin Chub

LAA NONE Blue Shiner

LAA NONE Duskytail Darter

LAA LAA Smoky Madtom Cherokee National Forest 4008 100,215 LAA LAA Yellowfin Madtom

LAA LAA Amber Darter

Fire Retardant DEIS 221 Appendices

Determination Determination Species Avg Avg National Forest Region for the Species for Critical drop/year Gal/year Habitat

LAA LAA Conasauga Logperch

LAA LAA Snail Darter

Francis Marion and LAA NONE Shortnose Sturgeon 108 2,649 Sumter National Forests

LAA NONE Duskytail Darter

Daniel Boone National LAA NONE Palezone Shiner 408 10,497 Forest LAA NONE Blackside Dace

LAA LAA Yellowfin Madtom George Washington and 508 11,698 Jefferson National Forest LAA LAA Slender Chub

National Forests in LAA LAA Shortnose Sturgeon 4308 106,886 Florida

Table F-3. No Effect (NE) Determinations for Fish Species by National Forest Based on Retardant Use (Under Both FWS and NOAA Jurisdiction).

Determination for Determination Species Region Avg Avg National Forest the Species for Critical Number drop/yr Gal/yr Habitat

NE NE Blue Shiner

NE NE Amber Darter

NE NE Goldline Darter Chattahoochee-Oconee 08 00 National Forests NE NE Conasuaga Logperch

NE NE Cherokee Darter

NE NE Etowah Darter

NE NE Cahaba Shiner National Forests in 08 00 Alabama NE NE Blue Shiner

Fire Retardant DEIS 222 Appendices

Determination for Determination Species Region Avg Avg National Forest the Species for Critical Number drop/yr Gal/yr Habitat

NE NE Gulf Sturgeon National Forests in 08 00 Mississippi NE NE PalLid Sturgeon

Shawnee National NE NE Pallid Sturgeon 09 00 Forest

Mark Twain NE NE Topeka Shiner 09 00 National Forest

Table F-4. Likely to Adversely Affect (LAA) Determinations for Invertebrate Species by National Forest Based on Retardant Use.

National Forest State Region Avg Avg Determination Determination Species Drop/Yr Gal/Yr for the Species for Critical Habitat

Lassen National CA 05 20 50403 LAA LAA Tadpole Shrimp Forest LAA LAA Vernal Pool Fairy Shrimp

LAA LAA Conservancy Fairy Shrimp

LAA None Shasta Crayfish

Modoc National CA 05 20 51003 LAA None Shasta Crayfish Forest

Klamath National CA 05 24 61496 LAA LAA Vernal Pool Fairy Shrimp Forest LAA LAA Alabama Mocassinshell

LAA LAA Finelined Pocketbook

LAA LAA Upland Combshell

Mendocino CA 05 41 102997 LAA LAA Vernal Pool Fairy Shrimp National Forest LAA None Vernal Pool Tadpole Shrimp

Plumas National CA 05 48 120546 LAA None Conservancy Fairy Shrimp Forest

Shasta Trinity CA 05 120 302235 LAA LAA Vernal Pool Fairy Shrimp National Forest LAA None Shasta Crayfish

Fire Retardant DEIS 223 Appendices

National Forest State Region Avg Avg Determination Determination Species Drop/Yr Gal/Yr for the Species for Critical Habitat

Los Padres CA 05 255 638947 LAA LAA Conservancy Fairy Shrimp

LAA LAA Longhorn Fairy Shrimp

National Forests NC 08 18 46772 LAA NONE Dwarf Wedgemussel in North Carolina LAA LAA Appalachian Elktoe

LAA NONE Littlewing Pearly mussel

Cherokee TN 08 40 100215 LAA LAA Appalachian Elktoe National Forest LAA NONE Tan Riffleshell

LAA LAA Finelined Pocketbook

LAA LAA Southern Pigtoe

LAA NONE Cumberland Bean Pearlymussel

LAA NONE Yellowblossom

LAA LAA Coosa Moccasinshell

National Forests FL 08 43 106886 LAA LAA Fat Three-Ridge Mussel of Florida LAA LAA Purple Bankclimber mussel

National Forests TX 108 2,383 LAA NONE Ouachita Rock Pocketbook in Texas

Kisatchie LA 208 4,210 LAA NONE Louisiana Pearlshell National Forest

Francis Marion SC 108 2,649 LAA LAA Carolina Heelsplitter and Sumter National Forests

Ozark-St Francis AR 808 20,889 LAA NONE A Cave Crayfish National Forest LAA ? Hell Creek Cavefish

LAA NONE Fat pocketbook

Daniel Boone KY 408 10,497 LAA LAA Cumberland Elktoe National Forest LAA NONE Dromedary Pearly Mussell

Fire Retardant DEIS 224 Appendices

National Forest State Region Avg Avg Determination Determination Species Drop/Yr Gal/Yr for the Species for Critical Habitat

LAA LAA Cumberlandian Combshell

LAA LAA Oyster Mussell

LAA NONE Yellow Blossom

LAA NONE Tan Riffleshell

LAA LAA Upland Combshell

LAA NONE Purple Cat's Paw

LAA NONE Tubercled-blossom

LAA NONE Cracking Pearlymussel

LAA NONE Ring Pink (Mussel)

LAA NONE Littlewing Pearlymussel

LAA NONE Clubshell

LAA NONE Cumberland Bean

LAA NONE Fanshell

LAA NONE Northern Riffleshell

LAA NONE Pink Mucket

LAA NONE Rough Pigtoe

George VA/WV 508 11,698 LAA NONE Dromedary Pearlymussel Washington & Jefferson National LAA LAA Cumberlandian Combshell Forest LAA LAA Oyster Mussel

LAA NONE Yellow Blossom

LAA NONE Tan Riffleshell

LAA NONE Green Blossom

LAA NONE Shiny Pigtoe

LAA NONE Finerayed Pigtoe

LAA NONE Cracking Pearlymussel

LAA NONE Birdwing Pearlymussel

Fire Retardant DEIS 225 Appendices

National Forest State Region Avg Avg Determination Determination Species Drop/Yr Gal/Yr for the Species for Critical Habitat

LAA NONE Littlewing Pearlymussel

LAA NONE James Spinymussel

LAA LAA Rough Rabbitsfoot

LAA NONE Cumberland Monkeyface

LAA NONE Appalachian Monkeyface

LAA LAA Purple Bean Mussell

LAA NONE Fanshell

LAA NONE Cumberland Bean Pearlymussel

LAA NONE Pink Mucket

LAA NONE Rough Pigtoe

LAA NONE

Table F-5. No Effect (NE) Determinations for Invertebrate Species by National Forest Based on Retardant Use.

National Forests State Region Avg Avg Determination Determination Species Drop/yr Gal/yr for the Species for Critical Habitat

Chattahoochee-Oconee 08GA 0 0 NE NE Upland Combshell National Forests NE NE Finelined P Alabama Moccasinshell NE NE Pocketbook

NE NE Coosa Moccasinshel

NE NE Southern Clubshell

NE NE Southern Pigtoe

NE NE Ovate Clubshell

NE NE Triangular Kidneyshel

NE NE Scaleshell Mussel

NE NE

Fire Retardant DEIS 226 Appendices

National Forests State Region Avg Avg Determination Determination Species Drop/yr Gal/yr for the Species for Critical Habitat

National Forests in 08AL 0 0 NE Cumberlandian Alabama NE Combshell NE NE Upland Combshell NE NE Southern Acornshell NE NE Turgid Blossom NE NE Finelined Pocketbook NE NE Orangenacre Mucket NE NE Alabama Moccasinshell NE NE Coosa Moccasinshell NE NE Dark Pigtoe NE NE Southern Pigtoe NE NE Ovate Clubshell NE NE Heavy Pigtoe NE NE Triangular Kidneyshell NE NE Pink Mucket NE NE Rough Pigtoe

National Forests in 08MS 0 0 NE NE Southern Clubshell Mississippi

Allegheny 09PA 0 0 NE NE Northern Riffleshell National Forest Clubshell

Hoosier National 09IND 0 0 NE NE Rough Pigtoe Forest Fanshell

Wayne National 09OH 0 0 NE NE Fanshell Forest Pink mucket

Shawnee National 09ILL 0 0 NE NE Fanshell Forest

Fire Retardant DEIS 227 Appendices

National Forests State Region Avg Avg Determination Determination Species Drop/yr Gal/yr for the Species for Critical Habitat

NE NE Orangefoot Pimpleback

NE NE Pink mucket

NE NE Fat pocketbook

Mark Twain 09MO 0 0 NE NE Curtis Pearlymussel National Forest NE NE Northern Riffleshell

NE NE Pink mucket

Fire Retardant DEIS 228 Forest Service Sensitive Fish and Aquatic Species

Table F-6. Forest Service Sensitive Aquatic Vertebrate & Invertebrate Species (Including Candidate Species) Known or Suspected to Occur on or Near Forest Service Lands With the Potential for Aerial Application of Fire Retardant.

R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

Bennett’s Mill Cave water Caecidotea carolinensis 8 Crustacean slater

8 Big South Fork crayfish Cambarus bouchardi Crustacean

8 Oconee stream crayfish Cambarus chaugaensis Crustacean

8 A crayfish Cambarus cymatilis Crustacean

8 A crayfish Cambarus englishi Crustacean

8 Chickamauga crayfish Cambarus extraneus Crustacean

8 Little Tennessee River crayfish Cambarus georgiae Crustacean

8 Rusty Grave Digger crayfish Cambarus miltus Crustacean

8 Hiwassee Headwaters crayfish Cambarus parrishi Crustacean

8 French Broad crayfish Cambarus reburrus Crustacean

8 A crayfish Cambarus speciosus Crustacean

3 Clam shrimp Eulimnadia follisimillis Crustacean

ieRtratDEIS Retardant Fire 8 Speckled burrowing crayfish Fallicambarus danielae Crustacean

Camp Shelby burrowing Fallicambarus gordoni Crustacean 8

crayfish Appendices

8 A crayfish Fallicambarus strawni Crustacean

229 8 Sabine fencing crayfish Faxonella beyeri Crustacean 230 DEIS Retardant Fire Appendices R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Ouachita fencing crayfish Faxonella creaseri Crustacean

8 A crayfish Hobbseus attenuatus Crustacean

8 Calcasieu painted crayfish Orconectes blacki Crustacean

8 Teche painted crayfish Orconectes hathawayi Crustacean

8 Kisatchie painted crayfish Orconectes maletae Crustacean

8 A crayfish Orconectes menae Crustacean

8 A crayfish Orconectes williamsi Crustacean

8 Silver Glen Springs crayfish Procambarus attiguus Crustacean

8 Jackson Prairie crayfish Procambarus barbiger Crustacean

8 Big-cheeked cave crayfish Procambarus delicatus Crustacean

8 Spiny-tailed crayfish Procambarus fitzpatricki Crustacean

8 A crayfish Procambarus kensleyi Crustacean

8 A crayfish Procambarus marthae Crustacean

8 Neches crayfish Procambarus nechesae Crustacean

8 Crayfish Procambarus nigrocintus Crustacean

8 Woodville karst cave crayfish Procambarus orcinus Crustacean

8 Pearl blackwater crayfish Procambarus penni Crustacean

8 A crayfish Procambarus reimeri Crustacean

8 A crayfish Procambarus tenuis Crustacean

3 Fairy shrimp Streptocephalus n. sp. 1 Crustacean R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Carolina seep scud Stygobromus carolinensis Crustacean

9 Elktoe Alasmidonta marginata Mollusk

98 Brook floater Alasmidonta varicosa Mollusk

9 Slippershell mussel Alasmidonta viridis Mollusk

8 Ochlockonee arcmussel Alasmidonta wrightiana Mollusk

9 Threeridge Amblema plicata Mollusk

3 5 California floater Anodonta californiensis Mollusk

8 Apalachicola floater Anodonta heardi Mollusk

8 Cumberland papershell Anodontoides denigratus Mollusk

8 Rayed creekshell Anodontoides radiatus Mollusk

98 Spectacle Case Cumberlandia monodonta Mollusk

98 Western fanshell mussel Cyprogenia aberti Mollusk

3 Lilljeborg’s pea-clam Disidium lilljeborg Mollusk

3 Sangre de Cristo pea-clam Disidium sanguinichristi Mollusk

8 Alabama spike Elliptio arca Mollusk ieRtratDEIS Retardant Fire 9 Spike Elliptio dilatata Mollusk

8 Yellow lance Elliptio lanceolata Mollusk Appendices

8 Roanoke slabshell Elliptio roanokensis Mollusk

231 98 Snuffbox Epioblasma triquetra Mollusk 232 DEIS Retardant Fire Appendices R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Texas pigtoe Fusconaia askewi Mollusk

8 Tennessee pigtoe Fusconaia barnesiana Mollusk

9 Wabash pigtoe Fusconaia flava Mollusk

8 Triangle pigtoe Fusconaia lananensis Mollusk

8 Atlantic pigtoe Fusconaia masoni Mollusk

98 Longsolid Fusconaia subrotunda subrotunda Mollusk

8 Puple pigtoe Fusconaia succissa Mollusk

6 Western ridged mussel Gonidea angulata Mollusk

8 Southern sandshell Lampsilis australis Mollusk

9 Wavyrayed lampmussel Lampsilis fasciola Mollusk

8 Louisiana fatmucket Lampsilis hydiana Mollusk

8 Neosho mucket Lampsilis rafinesqueana Mollusk

8 Sandbank pocketbook Lampsilis satura Mollusk

8 Rayed pink fatmucket Lampsilis splendid Mollusk

9 Yellow sandshell Lampsilis teres Mollusk

9 White heelsplitter Lasmigona complanata Mollusk

Alabama heelsplitter Lasmigona complanata Mollusk 8 alabamensis

9 Creek heelsplitter Lasmigona compressea Mollusk

9 Fluted-shell mussel Lasmigona costata Mollusk R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Tennessee heelsplitter Lasmigona holstonia Mollusk

98 Green floater Lasmigona subviridis Mollusk

8 Slabside pearlymussel Lexingtonia dolabelloides Mollusk

9 Black sandshell Ligumia recta Mollusk

1 Western pearlshell mussel Margaritifera falcata Mollusk

8 Alabama pearshell Margaritifera marrianae Mollusk

8 Southern hickorynut Obovaria jacksoniana Mollusk

9 Round hickorynut Obovaria subrotunda Mollusk

8 Alabama hickorynut Obovaria unicolor Mollusk

Montane peaclam Pisidium (Cyclocalyx) Mollusk 65 ultramontanum

98 Sheepnose Plethobasus cyphyus Mollusk

8 Mississippi pigtoe Pleurobema beadleianum Mollusk

98 Ohio pigtoe Pleurobema cordatum Mollusk

8 Georgia pigtoe Pleurobema hanleyianum Mollusk

8 Tennessee clubshell Pleurobema oviforme Mollusk

ieRtratDEIS Retardant Fire 8 Louisiana pigtoe Pleurobema riddellii Mollusk

98 Pyramid pigtoe Pleurobema rubrum Mollusk Appendices 9 Round pigtoe Pleurobema sintoxia Mollusk

8 Texas heelsplitter Potamilus amphichaenus Mollusk 233 234 DEIS Retardant Fire Appendices R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Southern kidneyshell Ptychobranchus jonesi Mollusk

9 Ouachita kidneyshell Ptychobranchus occidentalis Mollusk

8 Inflated floater Pyganodon gibbosa Mollusk

98 Rabbitsfoot Quadrula cylindrica cylindrica Mollusk

8 Ridged mapleleaf Quadrula rumphiana Mollusk

98 Salamander mussel Simpsonaias ambigua Mollusk

8 Alabama creekmussel Strophitus connasaugaensis Mollusk

8 Southern creekmussel Strophitus subvexus Mollusk

98 Purple liliput Toxolasma lividus Mollusk

9 Liliput Toxolasma parvus Mollusk

8 Savannah lilliput Toxolasma pullus Mollusk

8 Florida floater Utterbackia peggyae Mollusk

9 Ellipse Venustaconcha ellipsiformis Mollusk

8 Ouachita creekshell Villosa arkansasensis Mollusk

8 Choctaw bean Villosa choctawensis Mollusk

9 Rayed bean Villosa fabalis Mollusk

9 Rainbow mussel Villosa iris Mollusk

9 Little spectaclecase Villosa lienosa Mollusk

8 Alabama rainbow Villosa nebulosa Mollusk

8 Coosa combshell Villosa vanuxemensis umbrans Mollusk R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Carolina creekshell Villosa vaughaniana Mollusk

9 Lake sturgeon Acipenser fulvesens Fish

Atlantic sturgeon Acipenser oxyrhinchus Fish 8 oxyrhinchus

3 Longfin dace Agosia chrysogaster Fish

8 Alabama shad Alosa alabamae Fish

9 Northern cavefish Amblyopsis spelaea Fish

8 Spotted bullhead Ameiurus serracanthus Fish

8 Western sand darter Ammocrypta clara Fish

98 Eastern sand darter Ammocrypta pellucida Fish

3 Mexican stoneroller Campostoma ornatum Fish

3 Desert sucker Catostomus clarki Fish

32 Bluehead sucker Catostomus discobolus discobolus Fish

3 Zuni bluehead sucker Catostomus discobolus yarrowi Fish

3 Sonora sucker Catostomus insignis Fish

ieRtratDEIS Retardant Fire 32 Flannelmouth sucker Catostomus latipinnis Fish

Goose Lake sucker Catostomus occidentalis Fish

5 Appendices lacusanserinus

2 Mountain sucker Catostomus platyrhynchus Fish 235 236 DEIS Retardant Fire Appendices R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

32 Rio Grande sucker Catostomus plebeius Fish

3 Little Colorado sucker Catostomus sp. 3 Fish

9 Redside dace Clinostomus elongatus Fish

9 Cisco or Lake Herring Coregonus artedi Fish

9 Shortjaw cisco Coregonus zenithicus Fish

2 Lake chub Couesius plumbeus Fish

8 Black scuplin Cottus baileyi Fish

4 Wood River sculpin Cottus leiopomus Fish

6 Margined sculpin Cottus marginatus Fish

6 Pit sculpin Cottus pitensis Fish

98 Crystal darter Crystallaria asprella Fish

98 Blue sucker Cyclephtus elongatus Fish

8 Ocmulgee shiner Cyprinella callisema Fish

8 Bluestripe shiner Cyprinella callitaenia Fish

8 Altamaha shiner Cyprinella xaenura Fish

9 Gravel chub Erimystax x-punctatus Fish

9 Lake chubsucker Erimyzon sucetta Fish

8 Sharphead darter Etheostoma acuticeps Fish

8 Warrior darter Etheostoma bellator Fish

8 Florida sand darter Etheostoma bifascia Fish R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Holiday darter Etheostoma brevirostrum Fish

9 Bluebreast darter Etheostoma camurum Fish

8 Ashy darter Etheostoma cinereum Fish

8 Carolina darter Etheostoma collis Fish

8 Coldwater darter Etheostoma ditrema Fish

8 Tuskaloosa darter Etheostoma douglasi Fish

3 Greenthroat darter Etheostoma lepidum Fish

98 Spotted darter Etheostoma maculatum Fish

8 Pinewoods darter Etheostoma mariae Fish

8 Smallscale darter Etheostoma microlepidum Fish

9 Least darter Etheostoma microperca Fish

98 Candy darter Etheostoma osburni Fish

8 Paleback darter Etheostoma pallididorsum Fish

8 Rush darter Etheostoma phytophyllum Fish

8 Yazoo darter Etheostoma raneyi Fish

8 Cumberland Johnny darter Etheostoma susanae Fish ieRtratDEIS Retardant Fire 98 Tippecanoe darter Etheostoma tippecanoe Fish

8 Tripsot darter Etheostoma trisella Fish Appendices

8 Tuscumbia darter Etheostoma tuscumbia Fish

237 8 Wounded darter Etheostoma vulneratum Fish 238 DEIS Retardant Fire Appendices R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Blackwater darter Etheostoma zonifer Fish

8 Broadstripe topminnow Fundulus euryzonus Fish

6 Oregon Lakes tui chub Gila bicolor oregonensis Fish

5 Lahontan Lake tui chub Gila bicolor pectinifer Fish

65 Goose Lake tui chub Gila bicolor thallassina Fish

3 Headwater chub Gila nigra Fish

5 Arroyo chub Gila orcutti Fish

Partially armored 3-spine Gasterosteus aculeatus Fish 5 stickleback microcephalus

32 Rio Grande chub Gila pandora Fish

32 Roundtail chub Gila robusta Fish

2 Plains minnow Hybognathus placitus Fish

8 Lined chub Hybopsis lineapunctata Fish

9 Ohio lamprey Ichthyomyzon bdellium Fish

9 Northern brook lamprey Ichthyomyzon fossor Fish

98 Mountain brook lamprey Ichthyomyzon greeleyi Fish

3 Headwater catfish Ictalarus lupus Fish

6 River lamprey Lampetra ayresi Fish

6 Miller Lake lamprey Lampetra minima Fish

1 Pacific lamprey Lampetra tridentata Fish R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

65 Goose Lake lamprey Lampetra tridentata ssp. Fish

5 Clear Lake hitch Lavina exilicauda chi Fish

6 Pit roach Lavina symmetricus mitrulus Fish

4 Southern leatherside chub Lepidomeda aliciae Fish

4 Northern leatherside chub Lepidomeda copei Fish

9 Bantam sunfish Lepomis symmetricus Fish

9 Burbot Lota lota Fish

8 Ouachita shiner Lythrurus snelsoni Fish

2 Sturgeon chub Macrhybopsis gelida Fish

2 9 Pearl dace Margariscus margarita Fish

8 Suwannee bass Micropterus notius Fish

9 River redhorse Moxostoma carinatum Fish

8 Robust redhorse Moxostoma robustum Fish

9 Greater redhorse Moxostoma valenciennesi Fish

5 Hardhead Mylopharodon conocephalus Fish

2 Hornyhead chub Nocomis biguttatus Fish ieRtratDEIS Retardant Fire 9 Pugnose shiner Notropis anogenus Fish

8 Popeye shiner Notropis ariommus Fish Appendices

9 Blacknose shiner Notropis heterolepis Fish

239 8 Bluehead shiner Notropis hubbsi Fish 240 DEIS Retardant Fire Appendices R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

8 Highscale shiner Notropis hypsilepis Fish

8 Blackmouth shiner Notropis melanostomus Fish

8 Kiamichi shiner Notropis ortenburgeri Fish

98 Ozark shiner Notropis ozarcanus Fish

8 Peppered shiner Notropis perpallidus Fish

98 Sabine shiner Notropis sabinae Fish

9 New River shiner Notropis scabriceps Fish

8 Roughhead shiner Notropis semperasper Fish

8 Skygazer shiner Notropis uranoscopus Fish

9 Mountain madtom Noturus eleutherus Fish

8 Carolina madtom Noturus furiosus Fish

8 Orangefin madtom Noturus gilberti Fish

8 Ouachita madtom Noturus lachneri Fish

8 Frecklebelly madtom Noturus munitus Fish

98 Northern madtom Noturus stigmosus Fish

8 Caddo madtom Noturus taylori Fish

6 Olympic mudminnow Novumbra hubbsi Fish

21 4 Yellowstone cutthroat trout Oncorhynchus clarki bouvieri Fish

5 Coastal run cutthroat trout Oncorhynchus clarkii clarkii Fish R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

Coastal cutthroat trout (Puget Oncorhynchus clarkii clarkii (pop Fish 6 Sound) 6)

Coastal cutthroat trout Oncorhynchus clarkii clarkii (pop Fish 6 (Olympic Peninsula) 7)

1 4 6 Westslope cutthroat trout Oncorhynchus clarki lewisi Fish

2 4 Colorado River cutthroat trout Oncorhynchus clarki pleuriticus Fish

4 Bonneville cutthroat trout Oncorhynchus clarki utah Fish

3 Rio Grande cutthroat trout Oncorhynchus clarki virginalis Fish

6 Chum salmon Oncorhynchus keta Fish

6 Coho salmon (Puget Sound) Oncorhynchus kisutch (pop 5) Fish

Steelhead – Klamath Mtn. Prov. Oncorhynchus mykiss (pop 1) Fish 5 ESU

6 Steelhead – Oregon Coast Oncorhynchus mykiss (pop 15) Fish

5 Warner Valley redband trout Oncorhynchus mykiss (pop 4) Fish

5 Goose Lake redband trout Oncorhynchus mykiss (pop 6) Fish

5 McCloud River redband trout Oncorhynchus mykiss (pop 7) Fish

5 Volcano Creek golden trout Oncorhynchus mykiss aguabonita Fish ieRtratDEIS Retardant Fire Eagle Lake rainbow trout Oncorhynchus mykiss aquilarum Fish 5 (pop 5) Appendices 6 Inland redband trout Oncorhynchus mykiss gairdneri Fish

Sockeye salmon – Lake Oncorhynchus nerka (pop 3) Fish 6 241 Pleasant 242 DEIS Retardant Fire Appendices R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

6 Sockeye salmon – Baker River Oncorhynchus nerka (pop 5) Fish

Chinook – Central Valley fall Oncorhynchus tshawystscha (pop Fish 5 & late fall run 13)

Chinook – S. Oregon/N. Oncorhynchus tshawytscha (pop Fish 6 California Coast 25)

Chinook – Upper Oncorhynchus tshawystsch (pop Fish 5 Klamth/Trinity spring run 30)

6 Umpqua chub Oregonichthys kalawatseti Fish

9 Cheat minnow Pararhinichthys bowersi Fish

8 Southern logperch Percina austroperca Fish

8 Coal darter Percina brevicauda Fish

8 Blotchside logperch Percina burtoni Fish

9 Channel darter Percina copelandi Fish

9 Bluestripe darter Percina cymatotaenia Fish

9 Gilt darter Percina evides Fish

9 Appalachian darter Percina gymnocephala Fish

8 Freckled darter Percina lenticula Fish

98 Longhead darter Percina macrocephala Fish

98 Longnose darter Percina nasuta Fish

9 River darter Percina shumardi Fish

8 Olive darter Percina squamata Fish R9R8R6R5R4R3R2R1 Common Name NatureServe Global Sci. Name Sub-group

9 Stargazing darter Percina uranidea Fish

8 Fatlips minnow Phenacobius crassilabrum Fish

3 Suckermouth minnow Phenacobius mirabilis Fish

98 Kanawha minnow Phenacobius teretulus Fish

2 Southern redbelly dace Phoxinus erythrogaster Fish

21 Northern redbelly dace Phoxinus eos Fish

2 Finescale dace Phoxinus neogaeus Fish

8 Tennessee dace Phoxinus tennesseensis Fish

9 Eastern slim minnow Pimephales tenellus parviceps Fish

2 Flathead chub Platygobio gracilis Fish

6 Pygmy whitefish Prosopium coulteri Fish

4 Big Lost River whitefish Prosopium williamsoni Fish

5 Santa Ana speckled dace Rhinichthys osculus spp 8 Fish

6 Umatilla dace Rhinichthys umatilla Fish

8 Sandhills chub Semotilus lumbee Fish

1 Arctic grayling (fluvial) Thymallus arcticus (pop. 2) Fish ieRtratDEIS Retardant Fire 8 Southern cavefish Typhlichthys subterraneus Fish Appendices 243 Appendices

Table F-7. Retardant Effects that May Impact Individuals or Habitat, But Will Not Likely Contribute to a Trend Towards Federal Listing or Loss of Viability to the Population or Species for Sensitive Fish Species by National Forest Based on Retardant Use

Avg Avg National Forest Region Species drop/year Gal/year

Pacific lamprey Bitterroot National Forest 1 21 52,974 Westslope cutthroat trout

Pacific lamprey Clearwater National Forest 1 6 15,798 Westslope cutthroat trout

Pacific lamprey Nez Perce National Forest 1 18 44,059 Westslope cutthroat trout

Northern redbelly dace Custer National Forest 1 28 70,728 Yellowstone cutthroat trout

Yellowstone cutthroat trout

Arctic grayling (fluvial) Gallatin National Forest 1 45 113,513 Westslope cutthroat trout

Arctic grayling (fluvial) Beaverhead-Deerlodge National Forest 1 37 91,366 Westslope cutthroat trout

Arctic grayling (fluvial) Lewis & Clark National Forest 1 19 46,854 Westslope cutthroat trout

Flathead National Forest 1 66 164,110 Westslope cutthroat trout

Helena National Forest 1 49 121,971 Westslope cutthroat trout

Idaho Panhandle National Forests 1 48 120,451 Westslope cutthroat trout

Kootenai National Forest 1 7 18,204 Westslope cutthroat trout

Lolo National Forest 1 27 67,589 Westslope cutthroat trout

Bluehead sucker Medicine Bow-Routt National Forests 2 11 26,948

Fire Retardant DEIS 244 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Flannelmouth sucker

Mountain sucker

Lake chub

Roundtail chub

Plains minnow

Sturgeon chub

Horneyhead chub

Yellowstone cutthroat trout

Colorado River cutthroat trout

Finescale dace

Flathead chub

Bluehead sucker

Flannelmouth sucker

Mountain sucker San Juan National Forest 2 17 42,297 Roundtail chub

Colorado River cutthroat trout

Bluehead sucker

Flannelmouth sucker

Mountain sucker White River National Forest 2 10 24,978 Roundtail chub

Colorado River cutthroat trout

Flannelmouth sucker

Mountain sucker Arapaho-Roosevelt National Forests 2 9 22,555 Lake Chub

Colorado River cutthroat trout

Fire Retardant DEIS 245 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Northern redbelly dace

Mountain sucker Bighorn National Forest 2 2 4,360 Yellowstone cutthroat trout

Mountain sucker

Lake chub

Plains minnow Black Hills National Forest 2 9 23,176 Sturgeon chub

Northern redbelly dace

Finescale dace

Mountain sucker

Roundtail chub

Grand Mesa, Uncompahgre & Gunnison Flannelmouth sucker 2 2 6,127 National Forests Bluehead sucker

Colorado River cutthroat trout

Mountain sucker Shoshone National Forest 2 4 11,163 Yellowstone cutthroat trout

Plains minnow

Sturgeon chub

Pearl dace Nebraska National Forest 2 3 8,351 Northern redbelly dace

Finescale dace

Flathead chub

Rio Grande sucker Rio Grande National Forest 2 2 4,038 Rio Grande chub

Fire Retardant DEIS 246 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Northern redbelly dace

Southern redbelly dace Pike-San Isabel National Forest 2 31 76,328 Flathead chub

Bluehead sucker

Flannelmouth sucker

Rio Grande chub Carson National Forest 3 6 15,761 Rio Grande cutthroat trout

Rio Grande sucker

Roundtail chub

Bluehead sucker

Desert sucker

Little Colorado sucker Apache-Sitegraves National Forest 3 35 88,609 Longfin dace

Roundtail chub

Sonora sucker

Bluehead sucker

Desert sucker

Headwater chub

Little Colorado sucker Coconino National Forest 3 28 70,662 Longfin dace

Roundtail chub

Sonora sucker

Desert sucker

Coronado National Forest 3 130 324,770 Longfin dace Mexican stoneroller

Fire Retardant DEIS 247 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Sonora sucker

Desert sucker

Headwater chub

Longfin dace

Rio Grande cutthroat trout Gila National Forest 3 116 290,078 Rio Grande sucker

Roundtail chub

Sonora sucker

Desert sucker

Longfin dace Prescott National Forest 3 71 176,693 Roundtail chub

Sonora sucker

Desert sucker

Headwater chub

Longfin dace Tonto National Forest 3 90 224,557 Roundtail chub

Sonora sucker

Rio Grande chub

Rio Grande sucker Cibola National Forest 3 64 158,826 Suckermouth minnow

Zuni Bluehead sucker

Greenthroat darter

Headwater catfish Lincoln National Forest 3 70 173,920 Rio Grande chub

Fire Retardant DEIS 248 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Rio Grande cutthroat trout

Rio Grande chub

Rio Grande cutthroat trout Santa Fe National Forest 3 61 151,312 Rio Grande sucker

Ashley National Forest 4 6 15,160 Colorado River cutthroat trout

Boise National Forest 4 68 170,559 Westslope cutthroat trout

Colorado River cutthroat trout

Bonneville cutthroat trout Bridger-Teton National Forest 4 10 24,287 Yellowstone cutthroat trout

Northern Leatherside chub

Bonneville cutthroat trout

Yellowstone cutthroat trout Caribou-Targhee National Forest 4 16 39,547 Northern Leatherside chub

Westslope cutthroat trout Salmon-Challis National Forest 4 34 85,128 Big Lost River whitefish

Colorado River cutthroat trout

Bonneville cutthroat trout Dixie National Forest 4 24 59,234 Southern Leatherside chub

Bonneville cutthroat trout Fishlake National Forest 4 17 43,029 Southern Leatherside chub

Humboldt-Toiyabe National Forest 4 35 87,476 Bonneville cutthroat trout

Colorade River cutthroat trout

Manti-Lasal National Forest 4 15 36,959 Bonneville cutthroat trout

Southern Leatherside chub

Fire Retardant DEIS 249 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Payette National Forest 4 92 228,755 Westslope cutthroat trout

Wood River sculpin

Westslope cutthroat trout Sawtooth National Forest 4 31 76,718 Yellowstone cutthroat trout

Northern Leatherside chub

Colorado River cutthroat trout

Bonneville cutthroat trout Uinta National Forest 4 7 16,897 Southern Leatherside chub

Colorado River cutthroat trout

Bonneville cutthroat trout Wasatch-Cache National Forests 4 28 70,220 Northern Leatherside chub

Arroyo chub Angeles National Forest 5 114 285,573 Santa Ana speckled dace

Arroyo chub Cleveland National Forest 5 29 71,358 Santa Ana speckled dace

Eldorado National Forest 5 3 6,887 Hardhead

Inyo National Forest 5 10 24,541 Volcano Creek golden trout

Steelhead (Klamath Mountain ESU)

Chinook Salmon (Upper Klamath/Trinity ESU Klamath National Forest 5 25 61,496 spring-run)

Chinook Salmon (Upper Trinity River ESU fall run)

Eagle Lake rainbow trout

Lassen National Forest 5 20 50,404 Chinook Salmon (Central Valley fall & late fall ESU)

Los Padres National Forest 5 256 638,947 Arroyo chub

Fire Retardant DEIS 250 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Santa Ana speckled dace

Clear Lake hitch

Hardhead Mendocino National Forest 5 41 102,997 Chinook Salmon (Central Valley fall & late fall ESU)

Goose Lake sucker

Goose Lake tui chub

Goose Lake lamprey Modoc National Forest 5 20 51,004 West Valley redband trout

Goose Lake redband trout

Plumas National Forest 5 48 120,546 Hardhead

Partially armored 3spine stickleback

Arroyo chub San Bernardino National Forest 5 146 365,271 Santa Ana speckled dace

Hardhead Sequoia National Forest 5 89 222,385 Volcano Creek golden trout

Hardhead

McCloud River redband trout

Steelhead (Klamath Mountain ESU) Shasta-Trinity National Forest 5 121 302,235 Chinook Salmon (Upper Klamath/Trinity ESU spring run)

Chinook Salmon (Upper Trinity River ESU fall run)

Sierra National Forest 5 22 53,845 Hardhead

Steelhead (Klamath Mountain ESU) Six Rivers National Forest 5 21 53,292 Coastal run cutthroat trout

Fire Retardant DEIS 251 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Chinook Salmon (Upper Klamath/Trinity ESU spring run)

Chinook Salmon (Upper Trinity River ESU fall run)

Stanislaus National Forest 5 36 89,274 Hardhead

Lahontan Lake tui chub Tahoe National Forest 5 21 53,380 Hardhead

Lake Tahoe Basin 5 3 7,088 Lahontan Lake tui chub

Westslope cutthroat trout

Inland redband trout Colville National Forest 6 13 33,328 Pygmy whitefish

Umatilla dace

Deschutes National Forest 6 70 175,394 Inland redband trout

Pit sculpin

Oregon Lakes tui chub

Goose Lake tui chub

Miller Lake lamprey Fremont-Winema National Forests 6 111 276,773 Goose Lake lamprey

Pit roach

Inland reband trout

Coastal cutthroat trout (Puget Sound)

Coho salmon Gifford Pinchot National Forest 6 6 14,794 Inland redband trout

Pygmy whitefish

Westslope cutthroat trout Malheur National Forest 6 21 52,456 Inland redband trout

Fire Retardant DEIS 252 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Coastal cutthroat trout (Puget Sound)

Mount Baker-Snoqualmie National Coho salmon 6 0 703 Forest Sockeye salmon (Baker River)

Mount Hood National Forest 6 15 37,899 Inland redband trout

Westslope cutthroat trout Ochoco National Forest 6 7 17,239 Inland redband trout

River lamprey

Westslope cutthroat trout

Inland redband trout Okanogan-Wenatchee National Forest 6 133 331,364 Pygmy whitefish

Umatilla dace

Coastal cutthroat trout (Puget Sound)

Coastal cutthroat trout (Olympic Peninsula)

Coho salmon Olympic National Forest 6 0 1,021 Sockeye salmon (Lake Pleasant)

River lamprey

Olympic mudminnow

Chum salmon

Steelhead

Chinook salmon Rogue River-Siskiyou National Forest 6 26 64,569 Pit sculpin

Inland redband trout

Chum salmon Siuslaw National Forest 6 12 30,662 Steelhead

Fire Retardant DEIS 253 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Margined sculpin

Westslope cutthroat trout Umatilla National Forest 6 36 89,048 Inland redband trout

Chum salmon

Steelhead Umpqua National Forest 6 12 29,044 Umpqua chub

Westslope cutthroat trout Wallowa-Whitman National Forest 6 66 165,967 Inland redband trout

Western sand darter

Eastern sand darter

Cumberland Johnny darter

Ashy darter

Spotted darter

Smallscale darter Daniel Boone National Forest 8 4 10,497 Mountain brook lamprey

Northern madtom

Blotchside logperch

Longhead darter

Olive darter

Southern cavefish

Sharphead darter

Holiday darter

Cherokee National Forest 8 40 100,215 Coldwater darter Trispot darter

Lined chub

Fire Retardant DEIS 254 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Frecklebelly madtom

Blotchside logperch

Tennessee dace

Spotted bullhead National Forests in Florida 8 43 106,886 Suwannee bass

Western sand darter

Blue sucker Kisatchie National Forest 8 2 4,210 Bluehead shiner

Sabine shiner

Yazoo darter

Broadstripe topminnow National Forests in Mississippi 8 0 941 Blackmouth shiner

Western sand darter

Black sculpin

Sharphead darter

Candy darter

Tippecanoe darter

Mountain brook lamprey

George Washington & Jefferson 8 5 11,698 Popeye shiner National Forests Roughhead shiner

Orangefin madtom

Blotchside logperch

Longhead darter

Fatlips minnow

Kanawha minnow

Fire Retardant DEIS 255 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Tennessee dace

Bigeye jumprock

Paleback darter

Ouachita shiner

Kiamichi shiner

Peppered shiner Ouachita National Forest 8 12 30,719 Ouachita madtom

Caddo madtom

Longnose darter

Ozark shiner

Longnose darter Ozark & St. Francis National Forests 8 8 20,889 Southern cavefish

Atlantic sturgeon

Sharphead darter

Carolina darter

Pinewoods darter

Wounded darter National Forests in North Carolina 8 19 46,773 Carolina madtom

Blotchside logperch

Longhead darter

Olive darter

Sandhills chub

Francis Marion & Sumter National 8 1 2,649 Atlantic sturgeon Forests

National Forests in Texas 8 1 2,383 Sabine shiner

Fire Retardant DEIS 256 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Crystal darter

Blue sucker

Blacknose shiner

Ozark shiner

Sabine shiner Mark Twain National Forest 9 0 236 Bluestripe darter

Longnose darter

Stargazing darter

Eastern slim minnow

Lake sturgeon

Redside Dace

Cisco or Lake Herring

River redhorse Huron Manistee National Forest 9 0 236 Greater redhorse

Pugnose shiner

Channel darter

River darter

Lake sturgeon

Shortjaw cisco Superior National Forest 9 24 60,849 Northern brook lamprey

Least darter

Greater redhorse Chippewa National Forest 9 3 6,841 Pugnose shiner

Fire Retardant DEIS 257 Appendices

Table F-8. Findings of No Impact for Sensitive Fish Species by National Forest based on Retardant Use

Avg Avg National Forest Region Species drop/year Gal/year

Dakota Prairie Grasslands 1 0 0 Northern redbelly dace

Alabama shad

Crystal darter

Warrior darter

Florida sand darter

Holiday darter

Coldwater darter

Tuskaloosa darter

Rush darter National Forests of Alabama 8 0 0 Tuscumbia darter

Blackwater darter

Skygazer shiner

Freckleberry madtom

Southern logperch

Coal darter

Freckled darter

Longhead darter

Ocmulgee shiner

Bluestripe shiner

Altamaha shiner

Holiday darter Chattahoochee & Oconee National 8 0 0 Forests Coldwater darter

Trispot darter

Wounded darter

Lined chub

Fire Retardant DEIS 258 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Robust redhorse

Popeye shiner

Highscale shiner

Frecklebelly madtom

Freckled darter

Fatlips minnow

Shawnee National Forest 9 0 0 Bantam sunfish

Lake Sturgeon

Northern cavefish Hoosier National Forest 9 0 0 Eastern sand darter

Channel darter

Eastern sand darter

Lake chubsucker Wayne National Forest 9 0 0 Ohio lamprey

Redside dace

Candy darter

Pearl dace

New River shiner Monongahela National Forest 9 0 0 Cheat minnow

Appalachian darter

Kanawha darter

Gravel chub

Bluebreast darter Allegheny National Forest 9 0 0 Spotted darter

Tippecanoe darter

Fire Retardant DEIS 259 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Mountain brook lamprey

Burbot

Mountain madtom

Northern madtom

Channel darter

Gilt darter

Longhead darter

Hiawatha National Forest 9 0 0 Lake sturgeon

Lake sturgeon Ottawa National Forest 9 0 0 Redside dace

Lake sturgeon

Greater redhorse Chequamegon-Nicolet National Forest 9 0 0 Pugnose shiner

Table F-9. Retardant Effects that May Impact Individuals or Habitat, But Will Not Likely Contribute to a Trend Towards Federal Listing or Loss of Viability to the Population or Species for Sensitive Aquatic Invertebrate Species by National Forest Based on Retardant Use

Avg Avg National Forest Region Species drop/year Gal/year

Beaverhead-Deerlodge Nationatl Forest 1 37 91,366 Western Pearlshell Mussel

Bitterroot National Forest 1 21 52,974 Western Pearlshell Mussel

Clearwater National Forest 1 6 15,798 Western Pearlshell Mussel

Flathead National Forest 1 66 164,110 Western Pearlshell Mussel

Gallatin National Forest 1 45 113,513 Western Pearlshell Mussel

Helena National Forest 1 49 121,971 Western Pearlshell Mussel

Idaho Panhandle National Forest 1 48 120,451 Western Pearlshell Mussel

Kootenai National Forest 1 7 18,204 Western Pearlshell Mussel

Lewis and Clark National Forest 1 19 46,854 Western Pearlshell Mussel

Fire Retardant DEIS 260 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Lolo National Forest 1 27 67,589 Western Pearlshell Mussel

Nez Perce National Forest 1 18 44,059 Western Pearlshell Mussel

Apache-Sitegraves National Forest 3 35 88,609 California Floater

Coconino National Forest 3 28 70,662 California Floater

Santa Fe National Forest 3 61 151,312 Lilljeborg’s Pea-Clam

Carson National Forest 3 6 15,671 Sangre de Cristo Pea-Clam

Clam Shrimp Cibola National Forest 3 64 158,826 Fairy Shrimp

Lincoln National Forest 3 70 173,920 Fairy Shrimp

California floater Lassen National Forest 5 20 50,404 Montane peaclam

Modoc National Forest 5 20 51,004 California floater

California floater Shasta Trinity National Forest 5 121 302,235 Montane peaclam

Tahoe National Forest 5 21 53,380 California floater

Columbia River Gorge National Scenic 6 2 5,375 Western ridged mussel Area

Western ridged mussel Fremont-Winema National Forests 6 111 276,773 Montane peaclam

Gifford Pinchot National Forests 6 6 14,794 Western ridged mussel

Malheur National Forest 6 21 52,456 Western ridged mussel

Rogue River-Siskiyou National Forest 6 26 64,569 Western ridged mussel

Umatilla National Forest 6 36 89,048 Western ridged mussel

Umpqua National Forest 6 12 29,044 Western ridged mussel

Wallowa-Whitman National Forest 6 66 165,967 Western ridged mussel

Daniel Boone National Forest 8 4 10,497 Big South Fork crayfish

Fire Retardant DEIS 261 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Cumberland papershell

Spectaclecase

Snuffbox

Long-solid

Sheepnose

Tennessee clubshell

Rabbitsfoot

Salamander mussel

Purple lilliput

Slabside pearlymussel Cherokee National Forest 8 40 100,215 Tennessee clubshell

Silver Glen Springs crayfish

Big-cheeked cave crayfish

Woodville karst cave crayfish

Ochlockonee arcmussel National Forests in Florida 8 43 106,886 Apalachicola floater

Florida floater

Hobb’s cave amphipod

Sabine fencing crayfish

Ouachita fencing crayfish

Calcasieu painted crayfish

Teche painted crayfish Kisatchie National Forest 8 2 4,210 Kisatchie painted crayfish

Sandbank pocketbook

Southern hickorynut

Fire Retardant DEIS 262 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Louisiana pigtoe

Texas heelsplitter

Southern creekmussel

Speckled burrowing crayfish

Rayed creekshell National Forests in Mississippi 8 0 941 Pyramid pigtoe

Brook floater

Spectaclecase

Yellow lance

Snuffbox

Tennessee pigtoe

Atlantic pigtoe

Tennessee Heelsplitter George Washington & Jefferson 8 5 11,698 National Forests Green floater

Slabside pearlymussel

Sheepnose

Ohio river pigtoe

Tennessee clubshell

Pyramid pigtoe

Purple lilliput

A crayfish (Fallcambarus strawni)

A crayfish (Orconectes menae)

A crayfish (Procambarus reimeri) Ouachita National Forest 8 12 30,719 A crayfish (Procambarus tenuis)

Western fanshell mussel

Fire Retardant DEIS 263 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Louisiana fatmucket

Sandbank pocketbook

Southern hickorynut

Rabbitsfoot

Purple lilliput

Ouachita creekshell

A crayfish (Orconectes williamsi) Ozark & St. Francis National Forests 8 8 20,889 Neosho mucket

Bennett’s Mill Cave water slater

Oconee stream crayfish

Little Tennessee River crayfish

Hiwassee Headwaters crayfish

French Broad crayfish

Carolina seep scud

Brook floater National Forests in North Carolina 8 19 46,773 Roanoke slabshell

Tennessee pigtoe

Atlantic pigtoe

Tennessee Heelsplitter

Green floater

Savannah lilliput

Carolina creekshell

Oconee stream crayfish

Francis Marion & Sumter National Brook floater 8 1 2,649 Forests Rayed Pink fatmucket

Fire Retardant DEIS 264 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Sabine fencing crayfish

Neches crayfish

Crayfish (Procambarus nigrocintus)

Texas pigtoe

Triangle pigtoe National Forests in Texas 8 1 2,383 Sandbank pocketbook

Southern hickorynut

Louisiana pigtoe

Texas heelsplitter

Spectaclecase

Western fanshell Mark Twain National Forest 9 0 236 Ouachita kidneyshell

Purple liliput

Elktoe

Slippershell mussel

Spike

Snuffbox

Creek heelsplitter Huron Manistee National Forest 9 0 236 Fluted-shell mussel

Green floater

Black sandshell

Ellipse

Creek heelsplitter Superior National Forest 9 24 60,849 Black sandshell

Chippewa National Forest 9 3 6,841 Creek heelsplitter

Fire Retardant DEIS 265 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Fluted-shell mussel

Black sandshell

Table F-10. Findings of No Impact for Sensitive Aquatic Invertebrate Species by National Forest based on Retardant Use

Avg Avg National Forest Region Species drop/year Gal/year

A crayfish (Cambarus englishi)

Rusty grave digger crayfish

A crayfish (Procambarus marthae)

Rayed creekshell

Alabama spike

Purple pigtoe

Southern sandshell

Alabama heelsplitter

Tennessee heelsplitter

Alabama pearlshell National Forests of Alabama 08 0 Southern hickorynut

Alabama hickorynut

Southern kidneyshell

Ridged mapleleaf

Alabama creekmussel

Southern creekmussel

Choctaw bean

Alabama rainbow

Coosa combshell

Oconee stream crayfish

A crayfish (Cambarus cymatilis) Chattahoochee & Oconee National Forests 08 0 Chickamauga crayfish

Fire Retardant DEIS 266 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Little Tennessee River crayfish

Hiwassee Headwaters crayfish

A crayfish (Cambarus speciosus)

Brook floater

Tennessee Heelsplitter

Georgia pigtoe

Inflated floater

Ridged mapleleaf

Alabama creekmussel

Alabama rainbow

Midewin National Forest 09 0 Ellipse

Spike

Wabash pigtoe

Shawnee National Forest 9 Carinate pillsnail

Purple liliput

Snuffbox

Wavyrayed lampmussel

Yellow sandshell

Black sandshell

Round hickorynut

Sheepnose

Hoosier National Forest 09 0 Ohio pigtoe

Pyramid pigtoe

Rabbitsfoot

Salamander mussel

Purple liliput

Liliput

Wayne National Forest 09 0 Round hickorynut

Fire Retardant DEIS 267 Appendices

Avg Avg National Forest Region Species drop/year Gal/year

Sheepnose

Salamander mussel

Liliput

Little spectaclecase

Elktoe

Monongahela National Forest 09 0 Green floater

Threeridge

Snuffbox

Wabash pigtoe

Longsolid

White Heelsplitter

Creek Heelsplitter Allegheny National Forest 09 0 Sheepnose

Round pigtoe

Rabbitsfoot

Rayed bean

Rainbow mussel

Brook floater

Green Mountain-Finger Lakes National Creek heelsplitter 09 0 Forest Green floater

Ottawa National Forest 09 0 Creek Heelsplitter

Chequamegon-Nicolet National Forests 09 0 Ellipse

Fire Retardant DEIS 268 Appendices

Appendix G – Plants Analysis Framework

Analysis Framework – Statutes, Regulations, and other direction

This section summarizes management direction for Federally listed and Forest Service Sensitive plants, noxious and non-native invasive plants and other botanical resources as it relates to the use of aerially applied fire retardant. Endangered Species Act

Pursuant to Section 7 of the Federal Endangered Species Act (ESA), any federal agency undertaking a federal action that may affect a species listed or proposed as threatened or endangered under the ESA must consult with USFWS. In addition, any federal agency undertaking a federal action that may result in adverse modification of Critical Habitat for a federally-listed species must consult with USFWS.

The Endangered Species Act contains protection for all species federally-listed as endangered or threatened:

Federal agencies shall seek to conserve endangered species and threatened species and shall, in consultation with U.S. Fish and Wildlife Service, utilize their authorities in furthering the purposes of the Endangered Species Act by carrying out programs for the conservation of endangered and threatened species. Regulations for species that are proposed for listing as endangered or threatened are included in the Endangered Species Act Federal agencies shall confer with U.S. Fish and Wildlife Service on any agency action that is likely to jeopardize the continued existence of any species proposed to be listed. Forest Service Manual and Handbooks (FSM/H 2670)

Forest Service Manual and Handbooks (FSM/H 2670) Forest Service Sensitive (FSS) species are plant species identified by the Regional Forester for which population viability is a concern. The Forest Service developsand implements management practices to ensure that rare plants and animals do not become threatened or endangered and ensure their continued viability on national forests. It is Forest Service policy to analyze impacts to sensitive species to ensure management activities do not create a significant trend toward federal listing or loss of viability. The Biological Evaluation (BE) is summarized or referenced in the EIS and includes:

United States Department of Agriculture Regulation 9500-4 directs the Forest Service to avoid actions which may cause a sensitive species to become threatened or endangered (FSM 2670.12). Further, it is a Forest Service objective to "maintain viable populations of all native ... plant species in habitats distributed throughout their geographic range on National Forest System lands" (FSM 2670.22). Sensitive Plant Protection (FSM 2670.32; USDA FS, 1995) requires the Agency to reduce, minimize or alleviate possible adverse effects to Sensitive Plants. Individual forest plans directing management of Federally Listed and Regional Foresters Sensitive Plants. Each individual forest may have forest specific directions that “provide for and manage plant habitats and activities for threatened and endangered species to achieve recover objectives so that special protection measures provided under the Endangered Species Act (ESA) are no longer necessary”. General direction for

Fire Retardant DEIS 269 Appendices

management of Sensitive Plants under specific Forest Plans may provide additional guidance for plants and habitats specific for the region or forest. Executive Order 13112 (1999)

Created the National Invasive Species Council (NISC) co-chaired by the Departments of Agriculture, Commerce and Interior. The executive order recognized the ecological and economic threat posed by invasive species and directed a broad intergovernmental effort to address invasive species problems. An Invasive Species Advisory Committee of non-federal representatives was appointed by NISC to provide advice and information to federal agencies. NISC’s Management Plan, published in 2001, set nine goals including prevention, early detection and rapid response, control and management, restoration, international cooperation, research and education (NISC, 2001). The Federal Noxious Weed Act of 1974, as amended (7 U.S.C. 2801 et. seq.), 36 C.F.R. 222.8, Departmental Regulation 9500-10

The Act provides for the control and management of nonindigenous weeds that injure or have the potential to injure the interests of agriculture and commerce, wildlife resources, or the public health. The Act requires that each federal agency: develop a management program to control undesirable plants on federal lands under the agency's jurisdiction; establish and adequately fund the program; implement cooperative agreements with state agencies to coordinate management of undesirable plants on federal lands; establish integrated management systems to control undesirable plants targeted under cooperative agreements (for additional information see: http://www.fedcenter.gov). Forest Service Manual (FSM) 2080

Directives outline agency responsibilities for noxious weed management. FSM 2080 provides guidance to the National Forest System to address the more narrowly defined “noxious weed management”. FSM 2080 Objectives outline an integrated weed management approach to control and contain the spread of noxious weeds on National Forest System lands and from National Forest System lands to adjacent lands. Achievement of objectives through management include: prevention of introduction and establishment, containment and suppression of existing infestations, formal and informal cooperation with State agencies, local landowners, weed control districts and board and other Federal agencies, and education and awareness of threats to native plant communities and ecosystems. FSM 2080 Policy states : “In consultation with Federal, State, and local government entities and the public, develop and implement a program for noxious weed management on National Forest System lands. Activities implementing the noxious weed management program must be consistent with the goals and objectives identified in Forest Land and Resource Management Plans (FSM 1910, 1920, and 1930). Responsibility of these directives falls on all levels of forest management, from Washington office staff, Regional Foresters, Forest Supervisors and District Rangers.Regional or forest level management direction provide guidance and tools to prevent and manage invasive plants and noxious weeds.

Each National Forest maintains a list of noxious weeds and non-native, invasive pest plants of concern. Inventory and treatment for NNIS are implemented at each forest level. Treatment strategies at local levels in general, include early detection, rapid response and treatment of new invasive plant sites, increased emphasis on protecting and restoring healthy native plant communities, long-term site goals providing mechanisms to link treatment to prevention, revegetation/restoration and monitoring in an integrated and adaptive process.

Fire Retardant DEIS 270 Appendices

Burned Area Emergency Rehabilitation Program and Forest Service Handbook 2509.13

Provides specialized guidance and instruction for carrying out direction within the FSM. Objective of the program is to determine the need for and to prescribe and implement emergency treatments on Federal lands to minimize threats to life or property resulting from effects of a fire or to stabilize and prevent unacceptable degradation to natural and cultural resources. USDA Forest Service Guide to Noxious Weed Prevention Practices, section Fire Management

Contains guides to prevent invasive weed establishment and spread including pre-fire and pre-incident training, planning, and rehabilitation. National Strategy and Implementation Plan for Invasive Species Management (USDA 2004)

This document is intended to identify a strategic direction for Forest Service programs spanning Research and Development, International Programs, State and private Forestry, and the National Forest system. This strategy encompasses four program elements: prevention, early detection and rapid response, control and management, rehabilitation and restoration. In this plan each program element includes a description of success, accountability measures, summary of current program and list of strategic priorities divided into short- and long-term actions. USDA Forest Service Strategic Planning

Over the past years continues to include in their goals and objectives to address impacts of invasive species (USDA-FS 2007, USDA-FS 2004). Monitoring and Consultation Requirements for Retardant and Foam in Waterways and Threatened and Endangered Species (TES) Habitats USDA

Requires that is misapplications of fire retardant chemicals in habitats supporting T&E species requires an evaluation of the site to determine the extent of injury to the species and community and to document the degradation of the fire chemicals. Plant species within the affected area should be identified, photo document to confirmspecies, presence of T&E species, numbers and condition and ammonia concentration in retardant covered soil should be evaluated to determine degradation. Site characterization should be initiated to document spatial extent of the chemical application, terrain, slope and surface soil, site history, weather. For plants it is important to verify the survival through the next growing season and to document that invasive species have not increased as a result of fire retardant chemical misapplication.

Fire Retardant DEIS 271 Appendices

Plant Species List and Effects Determinations

Federally Listed Species and Designated Critical Habitats

Fire Retardant DEIS 272 Table G-1. Federally Listed Plant Species Known or Suspected to Occur on or Near Forest Service Lands with the Potential for Aerial Application of Fire Retardant.

Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

5 San Diego Thorn-mint T Acanthomintha ilicifolia Y

9 Northern Wild Monkshood T Aconitum noveboracense

8 Sensitive Joint-vetch T Aeschynomene virginica

5 Munz's Onion E Allium munzii Y

p Little Amphianthus T Amphianthus pusillus

8 Price's Potato-bean T Apios priceana

65 McDonald's Rock-cress E Arabis macdonaldiana

98 Shale Barren Rock-cress E Arabis serotina

65 Marsh Sandwort E Arenaria paludicola

p Cumberland Sandwort E Arenaria cumberlandensis

5 Bear Valley Sandwort T Arenaria ursina Y

3 Sacramento Prickly-poppy E Argemone pleiacantha ssp. pinnatisecta

9 Mead's Milkweed T Asclepias meadii

Asplenium scolopendrium var. 9 Hart's Tongue Fern T americanum

5 Cushenbury Milk-vetch E Astragalus albens Y ieRtratDEIS Retardant Fire 5 Applegate's Milk-vetch E Astragalus applegatei

5 Braunton's Milk-vetch E Astragalus brauntonii Appendices

4 Desert Milkvetch T Astragalus desereticus

5 Coachella Milk-vetch E Astragalus lentiginosus var. coachellae 273 274 DEIS Retardant Fire Appendices Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

4 Heliotrope Milk-vetch T Astragalus limnocharis var. montii Y

2 Osterhout's Mik-vetch E Astragalus osterhoutii

5 Triplerib Milk-vetch E Astragalus tricarinatus

5 Encinitas Baccharis T Baccharis vanessae

5 Nevin's Barberry E Berberis nevinii Y

8 Virginia Round-leaf Birch T Betula uber

8 Florida Bonamia T Bonamia grandiflora

5 Thread-leaved Brodiaea T Brodiaea filifolia Y

8 Capa Rosa E Callicarpa ampla

5 Mariposa Pussypaws T Calyptridium pulchella

s Fleshy Owl’s Clover T Castilleja campestris ssp. succulenta

Caulanthus californicus (Stanfordia s California jewelflower E californica)

5 Ashgray Paintbrush T Castilleja cinerea Y

5 Vail Lake Ceanothus T Ceanothus ophiochilus Y

5 Purple Amole T Chlorogalum purpureum var. reductum Y

5 La Graciaosa Thistle E Cirsium loncholepis

9 Pitcher's Thistle T Cirsium pitcheri

3 Sacramento Mountain Thistle T Cirsium vinaceum

5 Springville Fairyfan T Clarkia springvillensis

8 Alabama Leather Flower E Clematis socialis

8 Pigeon Wings T Clitoria fragrans Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

8 Apalachicola Rosemary E Conradina glabra

8 Cumberland Rosemary T Conradina verticillata

3 Pima Pineapple Cactus E Coryphantha scheeri var. robustispina

98 Leafy Prairie Clover E Dalea foliosa

5 Slender-horned Spineflower E Dodecahema leptoceras

5 Santa Monica Mountains Dudleya T Dudleya cymosa ssp. ovatifolia

8 Smooth Purple Coneflower E Echinacea laevigata

3 Kuenzler Hedgehog Cactus E Echinocereus fendleri var. kuenzleri

Echinocereus triglchidiatus var. 3 Arizona Hedgehog Cactus E arizonicus

5 Kern Mallow E Eremalche kernensis

5 Giant Woolstar E Eriastrum densifolium ssp. sanctorum

4 Maguire Daisy T Erigeron maguirei

5 Parish's Fleabane T Erigeron parishii Y

3 Zuni Fleabane T Erigeron rhizomatus

Eriogonum kennedyi var. 5 Southern Mountain Buckwheat T austromontanum Y

Eriogonum longifolium var.

ieRtratDEIS Retardant Fire 8 Scrub Buckwheat T gnaphalifolium

5 Cushenbury Buckwheat E Eriogonum ovalifolium var. vineum Y Appendices 8 Uvillo E Eugenia haematocarpa

2 Penland Alpine Fen Mustard T Eutrema penlandii

275 5 Mexican Flannelbush E Fremontodendron mexicanum 276 DEIS Retardant Fire Appendices Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

65 Gentner's fritillary E Fritillaria gentneri

8 Geocarpon T Geocarpon minimum

8 Spreading Avens E Geum radiatum

8 Rock Gnome Lichen E Gymnoderma lineare

6 Showy Stickseed E Hackelia venusta

8 Harper's Beauty E Harperocallis flava

3 Todsen's Pennyroyal E Hedeoma todsenii

98 Virginia Sneezeweed T Helenium virginicum

8 Schweinitz's Sunflower E Helianthus schweinitzii

8 Swamp Pink T Helonias bullata

8 Dwarf-flowered Heartleaf T Hexastylis naniflora

8 Roan Mountain Bluet E Houstonia purpurea var. montana

1 65 Water Howellia T Howellia aquatilis

8 Mountain Golden Heather T Hudsonia montana Y

9 Lakeside Daisy T Hymenoxys herbacea

8 Prairiedawn E Hymenoxys texana

8 Cuero de Sapo E Ilex sintenisii

8 Peter's Mountain-mallow E Iliamna corei

S Pagosa Sky Rocket P Ipomopsis polyanthus

3 Holy Ghost Ipomopsis E Ipomopsis sancti-spiritus

9 Dwarf Lake Iris T Iris lacustris Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

8 Louisiana Quillwort E Isoetes louisianensis

98 Small Whorled Pogonia T Isotria medeoloides

5 San Joaquin Wooly-Threads E Lembertia congdonii

Babyfoot Orchid E Lepanthes eltoroensis

4 Slick spot peppergrass T Lepidium papilliferum

8 Missouri Bladder-pod E Lesquerella filiformis

5 San Bernardino Mountains Bladderpod E Lesquerella kingii ssp. bernardina Y

8 Lyrate Bladderpod T Lesquerella lyrata

8 White Bladderpod E Lesquerella pallida

8 Heller's Blazing Star T Liatris helleri

3 Huaachuca Water Umbel E Lilaeopsis schaffneriana var. recurva Y

6 Western Lily E Lilium occidentale

5 Butte County Meadowfoam E Limnanthes floccosa ssp. californica

8 Pondberry E Lindera melissifolia

6 Cook's Lomatium E Lomatium cookii Y

6 Kincaid's Lupine T Lupinus oreganus var. kincaidii

8 Rough-leaf Loosestrife E Lysimachia asperulifolia ieRtratDEIS Retardant Fire 8 White Bird-in-a-nest T Macbridea alba

8 Mohr's Barbara's Buttons T Marshallia mohrii Appendices

9 Michigan Monkeyflower T Mimulus glabratus var. michiganensis

8 Cumberland Sandwort E Minuartia cumberlandensis 277 278 DEIS Retardant Fire Appendices Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

1 6 Macfarlane's Four-O'Clock T Mirabilis macfarlanei

8 Britton's Beargrass E Nolina brittonia

5 Bakersfield Cactus E Opuntia basilaris var. treleasei

s San Joaquin Valley Orcutt Grass T Orcuttia inaequalis

5 Slender Orcutt Grass T Orcuttia tenuis Y

8 Canby's Dropwort E Oxypolis canbyi

5 Cushenbury Oxytheca E Oxytheca parishii var. goodmaniana Y

9 Fassett's Locoweed T Oxytropis campestris var. chartacea

4 San Rafael Cactus E Pediocactus despainii

4 Winkler Cactus T Pediocactus winkleri

2 Blowout Penstemon E Penstemon haydenii

4 Clay Phacelia E Phacelia argillacea

2 Debeque Phacelia PT Phacelia submutica

5 Yreka phlox E Phlox hirsuta

p Texas Trailing Phlox T Phlox nivalis ssp. texensis

8 Godfrey's Butterwort T Pinguicula ionantha

8 Ruth's Golden-aster E Pityopsis ruthii

6 Rough Popcorn Flower E Plagiobothrys hirtus

9 Eastern Prairie White-fringed Orchid T Platanthera leucophaea

21 Western Prairie Fringed Orchid T Platanthera praeclara

8 Chupacallos E Pleodendron macranthum Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

5 San Bernardino Bluegrass E Poa atropurpurea Y

8 Lewton's Polygala E Polygala lewtonii

P Aleutian Shield Fern E Polystichium aleuticum

4 Maguire Primrose T Primula maguirei

5 San Joaquin Adobe Sunburst T Pseudobahia peirsonii

8 Harperella E Ptilimnium nodosum

3 Arizona Cliffrose E Purshia subintegra

8 Chapman's Rhododendron E Rhododendron minus var. champmanii

8 Miccosukee Gooseberry T Ribes echinellum

5 Gambel's Watercress E Rorippa gambelii

8 Bunched Arrowhead E Sagittaria fasciculata

8 Kral's Water Plantain T Sagittaria secundifolia

8 Green Pitcher Plant E Sarracenia oreophila

8 Alabama Canebrake Pitcher Plant E Sarracenia rubra ssp. alabamensis

8 Mountain Sweet Pitcher Plant E Sarracenia rubra ssp. jonesii

8 American Chaffseed E Schwalbea americana

98 Northeastern Bulrush E Scirpus ancistrochaetus ieRtratDEIS Retardant Fire 2 Unita Basin Hookless Cactus T Sclerocactus glaucus

8 Florida Skullcap T Scutellaria floridana Appendices

8 Large Flowered Skullcap T Scutellaria Montana

3 San Francisco Peaks groundsel T Senecio franciscanus Y 279 280 DEIS Retardant Fire Appendices Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

5 Layne's Butterweed T Senecio layneae

5 Keck's Checker Mallow E Sidalcea keckii

6 Nelson's Checker Mallow T Sidalcea nelsoniana

6 Wenatchee Mountains Checker Mallow E Sidalcea oregana var. calva Y

5 Bird-footed Checkerbloom E Sidalcea pedata

1 6 Spalding's Catchfly T Silene spaldingii

8 White Irisette E Sisyrinchium dichotomum

8 White-Haired Goldenrod T Solidago albopilosa

9 Houghton's Goldenrod T Solidago houghtonii

8 Blue Ridge Goldenrod T Solidago spithamaea

98 Virginia Spiraea T Spiraea virginiana

3 Canelo Hills Ladies Tresses E Spiranthes delitescens

2 4 6 Ute Ladies'-tresses T Spiranthes diluvialis

8 Navasota Ladies'-tresses E Spiranthes parksii

8 Palo de Jazmin E Styrax portoricensis

5 California Dandelion E Taraxacum californicum Y

8 Palo Colorado E Ternstroemia luquillensis

8 Unknown Common Name E Ternstroemia subsessilis

p Howell's Spectacular thelypody T Thelypodium howellii spectabilis

5 Slender-petaled mustard E Thelypodium stenopetalum

8 Alabama Streak-Sorus Fern T Thelypteris pilosa var. alabamensis Forest Service Regions Federal Critical Common Name NatureServe Global Sci. Name Status Habitat R8R6R5R4R3R2R1 R9 R10

4 Last Chance Townsendia T Townsendia aprica

98 Running Buffalo Clover E Trifolium stoloniferum

8 Persistent Trillium E Trillium persistens

8 Relict Trillium E Trillium reliquum

5 Greene's Tuctoria E Tuctoria greenei Y

8 Tennessee Yellow-eyed Grass E Xyris tennesseensis

Total Number of Species = 171 ieRtratDEIS Retardant Fire Appendices 281 Appendices

Table G-2. Federally Listed Plant Species Likely Adversely Affected From Aerially Applied Fire Retardant.

Scientific Name Federal Common Name FS Forest Name or State Populations Retardant Effect Reason2 Status Region with NF or Use Individuals 0.01%2 in Single Isolated Area1

Acanthomintha San Diego Retardant T 5 San B, Cleveland n Y LAA ilicifolia thorn-mint use

Acanthoscyphus Retardant parishii var. use Cushenbury goodmaniana E 5 San B, Cleveland n Y LAA puncturebract (Oxytheca parishii)

Retardant Allium munzii E Munz's onion 5 Cleveland n Y LAA use

N in R6; Retardant Klamath, SixRivers, Arabis McDonald's rock use E 5, 6 RogueRiver-Siskiyou, n LAA macdonaldiana Cress Y in R5 susp. Shasta-Trinity

Bear Valley Retardant Arenaria ursine T 5 San B n Y LAA sandwort use

Argemone Retardant Sacramento pleiacantha spp. E 3 Lincoln n Y LAA use prickly poppy Pinnatisecta

Cushenbury Retardant Astragalus albens E 5 San B n Y LAA milk-vetch use

Astragalus Brauton's Angeles, Cleveland, Retardant E 5 n Y LAA brauntonii milk-vetch* susp on San B use

Astragalus Retardant Coachella Valley lentiginosus var. E 5 susp on San B n Y LAA use milk-vetch* coachellae

Astragalus Triple-ribbed Retardant T 5 San B y Y LAA tricarinatus milk-vetch* use

Angeles, Cleveland, Retardant Berberis nevinii E Nevin's barberry 5 n Y LAA susp on San B use

Virginia Isolated Betula uber T 8 George Wash Jeff y N LAA Round-leaf Birch pop

Bonamia Retardant T Florida Bonamia 8 FL forests n Y LAA grandiflora use

Fire Retardant DEIS 282 Appendices

Scientific Name Federal Common Name FS Forest Name or State Populations Retardant Effect Reason2 Status Region with NF or Use Individuals 0.01%2 in Single Isolated Area1

Thread-leaved Angeles, Cleveland, Retardant Brodiaea filifolia T 5 n Y LAA brodiaea susp on San B use

Calyptridium Mariposa Isolated T 5 Sierra y N LAA pulchellum pussy-paws pop

Ashy-grey Retardant Castilleja cinerea T 5 San B n Y LAA paintbrush use

Sequoia? verify; Retardant Caulanthus California E 5 critical hab on Los n Y LAA use californicus jewelflower Padres

Ceanothus Vail Lake Isolated T 5 Cleveland y Y LAA ophiochilus ceanothus pop

Chlorogalum Retardant Camatta Canyon purpureum var. T 5 Los Padres n Y LAA use amole reductum

Sacramento Mts. Retardant Cirsium vinaceum T 3 Lincoln n Y LAA Thistle use

Clarkia Retardant T Springville clarkia 5 Sequoia n Y LAA springvillensis use

Retardant Clitoria fragrans T Pigeon Wings 8 FL forests n Y LAA use

Apalachicola several sq Retardant Conradina glabra E 8 FL forests Y LAA Rosemary miles use

Dodecahema Slender-horned Retardant E 5 Angeles, Cleveland n Y LAA leptoceras spineflower use

Santa Monica Retardant Dudleya cymosa T Mountains 5 Cleveland n Y LAA use ssp. ovatifolia dudleya

Eriastrum Retardant Santa Ana River densifolium ssp. E 5 susp on San B n Y LAA use woolystar* sanctorum

Retardant Erigeron parishii T Parish's daisy 5 San B n Y LAA use

Eriogonum Southern Retardant kennedyi var. T mountain 5 Los Padres, San B n Y LAA use austromontanum buckwheat

Fire Retardant DEIS 283 Appendices

Scientific Name Federal Common Name FS Forest Name or State Populations Retardant Effect Reason2 Status Region with NF or Use Individuals 0.01%2 in Single Isolated Area1

Eriogonum Retardant longifolium var. T Scrub Buckwheat 8 FL forests n Y LAA use gnaphalifolium

Eriogonum Retardant Cushenbury ovalifolium var. E 5 San B n Y LAA use buckwheat vineum

Fremontodendron Mexican Retardant E 5 susp Cleveland n Y LAA mexicanum Flannelbush use

Retardant Geum radiatum E Spreading Avens 8 Cherokee, NC forests n Y LAA use

Gymnoderma Rock Gnome Chat-Oconee, Retardant E 8 n Y LAA lineare Lichen Cherokee, NC Forests use

Retardant Hackelia venusta E Showy Stickweed 6 Okanogan-Wenatchee y Y LAA use

Harperocallis Retardant E Harper's Beauty 8 FL forests n Y LAA flava use

Todsen's Retardant Hedeoma todsenii E 3 Lincoln n Y LAA pennyroyal use

Houstonia Retardant purpurea var. use Roan Mountain montana also see E 8 NC Forests, Cherokee n Y LAA Bluet Hedyotis purpurea var Montana

Mendocino, Flathead, Retardant susp on: Six Rivers, use Lolo, Kootenei, Idaho Panhandle, Colombia y in r6; y Howellia aquatilis T water howellia 1, 5, 6 River gorge n LAA in r5 (OR&WA), Gifford Pinchot, Okanogan-Wenatchee, Mount Hood

one Isolated Peter's Iliamna corei E 8 George Wash/Jeff watershed N LAA pop Mountain-mallow only

Ipomopsis Holy ghost Retardant E 3 SantaFe y Y LAA sancti-spiritus ipomopsis use

Fire Retardant DEIS 284 Appendices

Scientific Name Federal Common Name FS Forest Name or State Populations Retardant Effect Reason2 Status Region with NF or Use Individuals 0.01%2 in Single Isolated Area1

White Mtn, Retardant Monogahela, susp or use known on Wayne, Isotria Small Whorled Allegheny, T 8 n Y LAA medeoloides Pogonia Chat-Oconee, Cherokee, George Wash/Jeff, NC Forests, Francis-Marion Sumter

Lilaeopsis Retardant Huachuca water schaffneriana spp. E 3 Coronado n Y LAA use umbel Recurva

White Retardant Macbridea alba T 8 FL forests n Y LAA Bird-in-a-nest use

Monolopia Retardant congdonii San Joaquin use E 5 susp on Sequoia n Y LAA (Lembertia woolythreads congdonii)

Britton's Retardant Nolina brittonia E 8 FL forests n Y LAA Beargrass use

Lassen, Modoc, Retardant Slender Orcutt Orcuttia tenuis T 5 Plumas, susp on n Y LAA use Grass ShastaTrinity

Physaria kingii Retardant San Bernardino ssp. Bernardina use E Mountains 5 San B N Y LAA (Lesquerella kingii bladderpod ssp. bernardina)

Pinguicula Godfrey's Retardant T 8 FL forests N Y LAA ionantha Butterwort use

San Bernardino Retardant Poa atropurpurea E 5 Cleveland, San B Y Y LAA bluegrass use

Retardant Polygala lewtonii E Lewton's Polygala 8 FL forests n Y LAA use

Isolated Primula maguirei T Maguire Primrose 4 Wasatch-Cache y N LAA pop

Pseudobahia San Joaquin adobe Retardant T 5 SixR, sus on Stanislaus n Y LAA peirsonii sunburst use

Fire Retardant DEIS 285 Appendices

Scientific Name Federal Common Name FS Forest Name or State Populations Retardant Effect Reason2 Status Region with NF or Use Individuals 0.01%2 in Single Isolated Area1

Rhododendron Retardant Chapman's minus var. E 8 FL forests n Y LAA use Rhododendron champmanii

Scutellaria Retardant T Florida Skullcap 8 FL forests n Y LAA floridana use

Layne's Retardant Senecio layneae T butterweed 5 Eldorado, Plumas n Y LAA use (=ragwort)

Keck's Retardant Sequoia, sus on or near Sidalcea keckii E checker-mallow 5 n Y LAA use Sierra (=checkerbloom)

Bird-foot Retardant Sidalcea pedata E 5 San B n Y LAA checkerbloom use

Solidago Blue Ridge Retardant T 8 Cherokee, NC forests n Y LAA spithamaea Goldenrod use

Daniel Boone, Retardant Spiraea virginiana T Virginia Spiraea 8 Cherokee, George n Y LAA use Wash/Jeff, NC forests

Spiranthes Canelo Hills Retardant E 3 Coronado n Y LAA delitescens Ladies-tresses use

Taraxacum California Retardant E 5 San B n Y LAA californicum taraxacum use

Thelypodium Slender-petaled Retardant E 5 San B n Y LAA stenopetalum thelypodium use

Total No of Species 62

1Isolated populations for plants includes a small isolated area where a T&E single population or multiple populations may occur on a forest where the application of retardant could potentially impact individuals, for instance one population occurring within one watershed or canyon.

2Forests with potential of more than 0.01% of landbase applied with fire retardant use more retardant and havea higher probability of misapplication or implementation of an exception.

Fire Retardant DEIS 286 Appendices

Table G-3. Federally Listed Plant Species Not Likely Adversely Affected From Aerially Applied Fire Retardant.

NatureServe Global Federal Common Name FS Forest Name or Retardant Effect 3 Isolated Reasons Scientific Name Status Region State with NF use population1 0.01%2

Sensitive Habitat Aeschynomene virginica T 8 NC Forests N N NLAA Joint-vetch

pot in pot in states GA, Habitat Amphianthus pusillus T Little Amphianthus N Y NLAA 8 AL, NC

Apios priceana T Price's Potato-bean 8 Mississippi N N NLAA LRUF

George LRUF Shale Barren Arabis serotina E 8, 9 Wash/Jeff, N N NLAA Rock-cress Monongahela

Cumberland pot in Habitat Arenaria cumberlandensis E potential in R8 N Y NLAA Sandwort 8

Habitat; Arenaria paludicola E Marsh Sandwort 5 susp on San B Na Y NLAA suspected only

MarkTwain, LRUF Asclepias meadii T Mead's Milkweed 9 Midewin, N N NLAA Shawnee

Habitat, Applegate's susp on Astragalus applegatei E 5 Na N NLAA LRUF, Milk-vetch Klamanth suspected only

Susp on Suspected only Astragalus desereticus T Desert Milk-vetch 4 Manti-LaSal, N Y NLAA Uinta

Astragalus limnocharis Heliotrope Habitat T 4 Payette N Y NLAA var. montii Milk-vetch

susp on Suspected only (Osterhout Astragalus osterhoutii E 2 Arapahoe, Na N NLAA milkvetch) MedBowRoutt

Baccharis vanessae T Encinitas baccharis 5 Cleveland N Y NLAA Habitat –check

Castilleja campestris ssp. succulent (=fleshy) LRUF T 5 Susp in Sierra N N NLAA succulent owl's-clover

susp on Los Habitat Cirsium loncholepis T La Graciosa thistle 5 N Y NLAA Padres

Cumberland LRUF Conradina verticillata T 8 Daniel Boone N N NLAA Rosemary

Fire Retardant DEIS 287 Appendices

NatureServe Global Federal Common Name FS Forest Name or Retardant Effect 3 Isolated Reasons Scientific Name Status Region State with NF use population1 0.01%2

Coryphantha scheeri var. Pima pineapple Habitat E 3 Coronado N Y NLAA robustispina cactus

Echinocereus LRUF Arizona hedgehog triglochidiatus var. E 3 Tonto N N NLAA cactus arizonicus

Echinocereus fendleri var. Kuenzler hedgehog Habitat E 3 Lincoln N Y NLAA kuenzleri cactus

arid grasslands Suspected, not and scrublands on FS lands of the San Eremalche kernensis Joaquin Valley Y; (Eremalche parryi ssp. E Kern mallow 5 N NLAA and adjacent nearby Kernensis) foothills and valleys – not on FS lands

Erigeron maguirei E Maguire Daisy 4 Fish Lake N N NLAA LRUF

Erigeron rhizomatus T Zuni Fleabane 3 Cibola N N NLAA LRUF

Penland alpine fen Pike San Isabel, LRUF and Eutrema penlandii T 2 N N NLAA mustard White River habitat

Rogue River LRUF Gentner n in r6, n Fritillaria gentneri E 5, 6 Siskiyou, susp N NLAA Mission-bells in r5 Klamath

Ozark-St LRUF and Geocarpon minimum T Geocarpon 8 N N NLAA Francis habitat

Virginia GeorgeWash LRUF and Helenium virginicum T 8,9 N N NLAA Sneezeweed Jeff, MarkTwain habitat

Schweinitz's LRUF Helianthus schweinitzii E 8 NC Forests N N NLAA Sunflower

Chat - Oconee, LRUF George Helonias bullata T Swamp Pink 8 N N NLAA Wash/Jeff, NC Forests

Dwarf-flowered LRUF Hexastylis naniflora T 8 NC Forests N N NLAA Heartleaf

Mountain Golden LRUF Hudsonia Montana T 8 NC Forests N N NLAA Heather

Hymenoxys texana E Prairiedawn 8 TX forests N N NLAA LRUF

Fire Retardant DEIS 288 Appendices

NatureServe Global Federal Common Name FS Forest Name or Retardant Effect 3 Isolated Reasons Scientific Name Status Region State with NF use population1 0.01%2

LRUF and Ipomopsis polyantha P (Pagosa skyrocket) 2 susp on SanJuan Na N NLAA suspected

Louisiana LRUF Isoetes louisianensis E 8,9 MS Forests N N NLAA Quillwort

Slick spot LRUF and Lepidium papilliferum T 4 susp Boise N N NLAA peppergrass suspected

Lesquerella filiformis Missouri Ozark-St LRUF E 8 N N NLAA (Physaria) Bladder-pod Francis

n - 2 LRUF and Lesquerella pallid E White Bladderpod 8 TX forests N NLAA wsheds habitat

Heller's Blazing LRUF Liatris helleri T 8 NC Forests N N NLAA Star

LRUF and Lilium occidentale E Western Lily 6 susp Umatilla Na N NLAA suspected

Butte County LRUF Limnanthes floccosa ssp. E (Shippee) 5 susp in Lassen N N NLAA Californica meadowfoam

MS forests, LRUF Lindera melissifolia E Pondberry 8 Francis-Marion N N NLAA Sumter

susp LRUF, habitat, Lomatium cookii E Cook's Lomatium 6 Na N NLAA RogueRiver-Siskiyou and suspected

Lupinus oreganus var. LRUF T Kincaid's Lupine 6 Umpqua N N NLAA kincaidii

Rough-leaf LRUF Lysimachia asperulifolia E 8 NC Forests N N NLAA Loosestrife

Minuartia LRUF and Cumberland cumberlandensis also E 8 Daniel Boone N N NLAA habitat Sandwort Arenaria cumberlandensis

Nez Perce, LRUF Macfarlane's n in OR Mirabilis macfarlanei T 1,6 Wallowa N NLAA Four-O'Clock n in MT Whitman

Nasturtium gambelii Gambel's Habitat E 5 susp San B N Y NLAA (Rorippa gambellii) watercress*

Opuntia basilaris Var. LRUF E Bakersfield cactus 5 Sequoia, San B N y NLAA trelease

Fire Retardant DEIS 289 Appendices

NatureServe Global Federal Common Name FS Forest Name or Retardant Effect 3 Isolated Reasons Scientific Name Status Region State with NF use population1 0.01%2

Not San Joaquin Valley Orcuttia inaequalis T 5 Statewide N Statewide NLAA documented on Orcutt grass FS lands

Francis Marion LRUF and Oxypolis canbyi E Canby's Dropwort 8 N N NLAA Sumter habitat

Pediocactus despainii E San Rafael Cactus 4 Humbolt-Toiyabe N N NLAA LRUF

susp LRUF Pediocactus winkleri T Winkler Cactus 4 N N NLAA Manti-LaSal

(Blowout NEBR known, LRUF Penstemon haydenii E 2 N N NLAA penstemon) MBR suspect

Uinta, susp on LRUF Phacelia argillacea E Clay Phacelia 4 Introduced N NLAA Manti-LaSal

Phacelia scopulina var. GrandMesa-Umcp, LRUF and P (Debeque phacelia) 2 N N NLAA submutica WhiteRiver habitat

Phlox hirsute E Yreka Phlox 5 Klamath N N NLAA LRUF

not in LRUF and Texas Trailing pot in Phlox nivalis ssp. texensis T potential in R8 N TX NLAA suspected Phlox 8 NForest

Pityopsis ruthii E Ruth's Golden-aster 8 Cherokee 2 wshds Y NLAA Habitat

Rough Popcorn LRUF and Plagiobothrys hirtus E 6 susp on Umpqua Na N NLAA Flower suspected

Western prairie n in r2; n LRUF Platanthera praeclara T 1,2 susp Nebraska N NLAA fringed orchid in r1

AL forests, LRUF and Ptilimnium nodosum E Harperella 8 N N NLAA Ouachita habitat

Coconino, LRUF Purshia subintegra E Arizona cliffrose 3 N N NLAA Tonto

Miccosukee Francis Marion LRUF Ribes echinellum T 8 N N NLAA Gooseberry Sumter

Bunched LRUF and Sagittaria fasciculata E 8 NC Forests N N NLAA Arrowhead habitat

State of AL, LRUF Sarracenia oreophila E Green Pitcher Plant 8 Chat - Oconee, N N NLAA NC Forests

Sarracenia rubra ssp. Mountain Sweet LRUF and E 8,9 NC Forests N N NLAA jonesii Pitcher Plant habitat

Fire Retardant DEIS 290 Appendices

NatureServe Global Federal Common Name FS Forest Name or Retardant Effect 3 Isolated Reasons Scientific Name Status Region State with NF use population1 0.01%2

Daniel Boone, LRUF American Francis Marion Schwalbea americana E 8 N N NLAA Chaffseed Sumter, TX forests

Northeastern George LRUF and Scirpus ancistrochaetus E 8 N N NLAA Bulrush Wash/Jeff habitat

GrandMesa-Ump, LRUF Colorado hookless Sclerocactus glaucus T 2 susp on N N NLAA cactus WhiteRiver

San Fransisco LRUF and Sencio franciscanus T 3 Coconino N N NLAA peaks groundsel habitat

Nelson's Checker LRUF and Sidalcea nelsoniana T 6 susp on Siuslaw Na N NLAA Mallow suspected

Wenatchee Habitat Sidalcea oregana var. E Mountains Checker 6 Okanogan-Wenatchee N Y NLAA calva Mallow

Nez Perce, LRUF Umatilla, Wallowa n in r6, n Silene spaldingii T Spalding's Catchfly 1,6 N NLAA Whitman, susp in r1 on Lolo, Koot, Idaho Panhandle

Sisyrinchium dichotomum E White Irisette 8 NC Forests N N NLAA LRUF

White-Haired LRUF Solidago albopilosa T 8,9 Daniel Boone N N NLAA Goldenrod

Uinta, Targhee, LRUF and susp Medicine habitat Bow - Routt, PikeSan Isabel, White River, y in r4, n Ute ladies’-tresses Okanogan, Spiranthes diluvialis T 2,4, 6 N in r2; n NLAA orchid Boise, in r6; CaribouTarghee, Salmon, Sawtooth, Wasatch Cache, Challis

Navasota LRUF Spiranthes parksii E 8 TX forests N N NLAA Ladies'-tresses

Thelypodium howellii Slender-petaled potential LRUF and T potential in R6 N N NLAA spectabilis Mustard in 6 suspected

Fire Retardant DEIS 291 Appendices

NatureServe Global Federal Common Name FS Forest Name or Retardant Effect 3 Isolated Reasons Scientific Name Status Region State with NF use population1 0.01%2

Last Chance LRUF Townsendia aprica T 4 Dixie, Fishlake N N NLAA Townsendia

Running Buffalo LRUF Trifolium stoloniferum E 8 Daniel Boone N N NLAA Clover

Chat - Oconee, LRUF Trillium persistens E Persistent Trillium 8 Francis Marion N N NLAA Sumter

Chat - Oconee, LRUF Trillium reliquum E Relict Trillium 8 Francis Marion N N NLAA Sumter

Greene's tuctoria LRUF and Tuctoria greenei E 5 Lassen, Modoc N N NLAA (=Orcutt grass) habitat

Total species = 81

1Isolated populations for plants includes a small isolated area where a T&E single population or multiple populations may occur on a forest where the application of retardant could potentially impact individuals, for instance one population occurring within one watershed or canyon .

2Forests with potential of more than 0.01% of landbase applied with fire retardant use more retardant and havea higher probability of misapplication or implementation of an exception

Na= not applicable, species are only presently suspected to occur on these NFS lands

3Low retardant use forest (LRUF) limited use of retardant annually; Habitat: species occurs in habitats not likely to receive fire retardant or protected with 300’ waterbody avoidance areas already. Suspected to occur onFSlands but no documented occurrences.

Table G-4. Designated Critical Habitat For Plant Species Impacted From Aerially Applied Fire Retardant.

NatureServe Global Scientific Federal Common Name FS Forest Retardant Effect2 Name Status Region Names Acres use 0.01%1

Acanthomintha ilicifolia Chab San Diego thorn-mint 5 Cleveland y549 NLAA

Allium munzii Chab Munz's onion 5 Cleveland y176 NLAA

Arenaria ursina Chab Bear Valley sandwort 5 San B y1,309 NLAA

Astragalus albens Chab Cushenbury milk-vetch 5 San B y3,020 NLAA

Astragalus limnocharis var. Chab Heliotrope milk-vetch 4 Manti-LaSal n65 NLAA montii

Fire Retardant DEIS 292 Appendices

NatureServe Global Scientific Federal Common Name FS Forest Retardant Effect2 Name Status Region Names Acres use 0.01%1

Berberis nevinii Chab Nevin's barberry 5 Cleveland y1 NLAA

Angeles, 20 & Brodiaea filifolia Chab Thread-leaved brodiaea 5 y NLAA Cleveland 249

Castilleja cinerea Chab Ashy-grey paintbrush 5 San B y1603 NLAA

Ceanothus ophiochilus Chab Vail lake ceanothus 5 Cleveland y203 NLAA

Chlorogalum purpureum var. Chab Camatta canyon amole 5 Los Padres y4770 NLAA reductum

Erigeron parishii Chab Parish's daisy 5 San B y2320 NLAA

Eriogonum kennedyi Chab La Graciosa thistle 5 San B y872 NLAA austromontanum

Eriogonum ovalifolium var. Chab Cushenbury buckwheat 5 San B y5595 NLAA vineum

Hudsonia montana Chab Butte county meadowfoam 8 Pisgah n22 NLAA

Lesquerella kingii ssp. Chab Cook's komatium 5 San B y1005 NE bernardina

Lilaeopsis schaffneriana spp. Chab Kincaid's kupine 3 Coronado y NLAA Recurva

Rogue River Lomatium cookii Chab Slender orcutt Grass 6 n40 NLAA Siskiyou

Orcuttia tenuis Chab Keck's checker-mallow 5 Lassen n21885 NLAA

Oxytheca parishii var goodmaniana Acanthoscyphus Chab Cushionberry oxythea 5 San B y2590 NLAA parishii var. goodmaniana

Cleveland, 1115 & Poa atropurpurea Chab San Bernardino bluegrass 5 y NLAA San B 804

Sencio franciscanus Chab Greene's tuctoria (=Orcutt grass) 3 Coconino n720 NE

Wenatchee mountains Sidalcea oregana var. calva Chab 6 Wenatchee n2280 NLAA checkermallow

Taraxacum californicum Chab California dandelion San B y1344 NLAA

Tuctoria greenei Chab Greene’s tructoria 5 Lassen n1551 NLAA

Total = 24

1Forests with potential of 0.01% of landbase applied with fire retardant

Fire Retardant DEIS 293 Appendices

2Reason: Many of the primary constituent elements for designated critical habitats associated with this analysis all have some component within their elements that include: space for individual and population growth, reproduction and dispersal, plant communities dominated by native grasses and forbs, or native plant communities associated with the species of protection, or no or negligible presence of competitive or nonnative invasive plant species (refer to next section for description of Designated Critical Habitat Primary Constituent Elements). Because all areas where primary constituent elements within designated critical habitats will be protected with avoidance mapping (no retardant application) no impacts are anticipated except for a misapplication or invoking of a exception, therefore a NLAA determination. For additional information related to critical habitats and primary constituent elements please refer to FWS (http://www.fws.gov/verobeach/images/pdflibrary/Critical%20Habitat%20Fact%20Sheet.pdf, accessed 04/2011). Where primary consitituent elements are clearly defined and retardant use would not affect these elements in combination with very low use of retardant in the designated critical habitat areas (i.e. cinder talus slopes on alpine tundra slopes) no effects (NE) are anticipated.

Table G-5. Federally Listed Plant Species Determined To Have No Effect From Aerially Applied Fire Retardant.

Scientific Name Federal Common Name FS Forest Names or Effect Reason Retardant Status Region State with NF (NR)= No Use past retardant 10 years use

Aconitum noveboracense T Northern Wild 9 Wayne NR N NE Monkshood

Asplenium scolopendrium var. T Hart's Tongue Fern 9 Hiawatha NRNE N americanum

Callicarpa ampla E Capa Rosa 8 Puerto Rico N NRNE

Cirsium pitcheri1 T Pitcher's Thistle 9 Hiawatha, Huron NE 1 Y 1drop Habitat Manistee

Clematis socialis E Alabama Leather Flower 8 Alabama N NRNE

Dalea foliosa E Leafy Prairie Clover 8,9 Alabama N NRNE

Eugenia haematocarpa E Uvillo 8 Puerto Rico N NRNE

Hymenoxys herbacea T Lakeside Daisy 9 Hiawatha N NRNE

Ilex sintenisii E Cuero de Sapo 8 Puerto Rico N NRNE

Iris lacustris T Dwarf Lake Iris 9 Hiawatha N NRNE

Lepanthes eltoroensis E Babyfoot Orchid 8 Puerto Rico N NRNE

Lesquerella lyrata T Lyrate Bladderpod 8 Alabama N NRNE

Marshallia mohrii T Mohr's Barbara's Buttons 8 Alabama N NRNE

Mimulus glabratus var. T Michigan Monkeyflower 9 Hiawatha NRNE N michiganensis

Oxytropis campestris var. T Fassett's Locoweed 9 Chequamegon NRNE N chartacea /Nicolet

Fire Retardant DEIS 294 Appendices

Scientific Name Federal Common Name FS Forest Names or Effect Reason Retardant Status Region State with NF (NR)= No Use past retardant 10 years use

Platanthera leucophaea T Eastern Prairie 9 Midewin NRNE N White-fringed Orchid

Pleodendron macranthum E Chupacallos 8 Puerto Rico N NRNE

Polystichum aleuticum E Aleutian Shield Fern 10 Alaska N NRNE

Sagittaria secundifolia T Kral's Water Plantain 8 Alabama N NRNE

Sarracenia rubra ssp. Alabama Canebrake NRNE N alabamensis E Pitcher Plant 8 Alabama

Scutellaria Montana T Large Flowered Skullcap 8 Chat Oconee N NRNE

Solidago houghtonii T Houghton's Goldenrod 9 Hiawatha N NRNE

Styrax portoricensis E Palo de Jazmin 8 Puerto Rico N NRNE

Ternstroemia luquillensis E Palo Colorado 8 Puerto Rico N NRNE

Ternstroemia subsessilis E 8, 9 Puerto Rico N NRNE

Thelypteris pilosa var. T Alabama Streak-Sorus 8 Alabama NRNE N alabamensis Fern

Thlaspi californicum E Kneeland Prairie 5 Humbolt Six Rivers NE 2 Y Habitat penny-cress California

Xyris tennesseensis E Tennessee Yellow-eyed 8 Alabama NRNE N Grass

Total # of Species 28

1Restricted to dune habitats

2Both the known, current, and historical distribution of Kneeland Prairie pennycress occurs on a single exposure of serpentine rock, confined to a 0.5 square mile area within Kneeland Prairie, Humboldt County. SixRivers National Forest is located approximately 8 miles due east of the site. Jennings,(in CFR http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2002_register&docid=02-25371-filed.pdf) inventoried all suitable habitat for the Kneeland Prairie penny-cress within Six Rivers National Forest, over an area extending 10 miles north, 10 miles south, and 5 miles east of the closest point on the Six Rivers National Forest boundary. That inventory and other past efforts failed to locate any additional populations for the species outside of Kneeland Prairie. Six Rivers National Forest is separated from Kneeland Prairie by the north trending Mad River, which effectively isolates the two locations hydrologically. Therefore, aerial retardant releases on Six Rivers National Forest should have no effect on the Kneeland Prairie penny-cress.

Fire Retardant DEIS 295 296 DEIS Retardant Fire Appendices Table G-6. Federally Listed Species Habitats, Retardant Use, And Effects By Forest Service Region.

NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

San B, Restricted to heavy clay soils in coastal sage scrub, San Diego Acanthomintha ilicifolia 5 Cleveland y grasslands, and chaparral. Often in open areas, clay n thorn-mint T depressions, vernal pool habitats; below 900 meters

Acanthoscyphus parishii San B, Carbonate Plants Cushenbury var. goodmaniana 5 Cleveland y n puncturebract (Oxytheca parishii) E

Sensitive NC Forests Fresh to slightly brackish tidal river shores and Aeschynomene virginica 8 n n T Joint-vetch estuarine-river marsh borders

Allium munzii E Munz's onion 5 Cleveland y grassy openings in coastal sage scrub n

pot in Amphianthus pusillus is totally confined to vernal pools states GA, on granite outcrops of the southeastern Piedmont. About AL, NC 90% of the known populations are in Georgia, with the Little others occurring in Alabama and South Carolina. Rather Amphianthus pusillus pot in 8 y n Amphianthus consistently, the optimal habitat of Amphianthus has been described as a shallow, flat-bottomed pool almost invariably surrounded by a rock rim several centimeters T in height

Mississippi Open, rocky, wooded slopes and floodplain edges. Sites are usually under mixed hardwoods or in associated forest Price's clearings, often where bluffs or ravine slopes meet creek Apios priceana 8 n n Potato-bean or river bottoms. Soils are well-drained and loamy, formed on alluvium or over calcareous boulders. Several T populations extend onto road or powerline rights-of-way.

Klamath, Rocky serpentine areas or reddish soils derived from SixRivers, serpentine. In dry open woods or brushy steep slopes or n in r6; Rogue ledges McDonald's rock Arabis macdonaldiana 5, 6 River - n Cress y in r5, Siskiyou, susp Shasta E - Trinity NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

George An endemic of shale deposits, occurring only on Wash/Jeff, sparsely-vegetated xeric, south or west-facing shale slopes Monongahela (barrens) at elevations from 400 to 600 meters. Populations Shale Barren Arabis serotina 8, 9 n are known from both the shale openings and shale n Rock-cress woodlands adjacent to the shale openings. Shale barren is a general reference to certain mid-Appalachian slopes E supporting sparse, scrubby growth.

potential in Cool, humid, cave-like overhangs called rock houses R8 formed through the differential weathering of sandstone Arenaria Cumberland pot in 8 y strata. Found on the sandy floors of these rock houses and cumberlandensis Sandwort in similar situations such as beneath sandstone ledges. This E unusual habitat is shared with very few other plant species

susp in San Freshwater marshes from close to sea level to 450 m B elevation. Plants have been found in areas with shallow Arenaria paludicola E Marsh Sandwort 5 y n standing water and with no standing water. Substrates are saturated, acidic, organic bog soils.

San B Pebble plains: dense clay soils, usually covered with a cobble pavement of quartzite. These are sparsely vegetated; they occur as openings in the surrounding forest at Bear Valley Arenaria ursina 5 y 1800-2300 m elevation. They support several endemic n sandwort plant species and disjunct occurrences of plants that are more common elsewhere. Occurs with Eriogonum T kennedyi ssp. austromontanum.

Argemone pleiacantha Sacramento Lincoln steep rocky hillsides rocky canyons, riparian or disturbed 3 y n spp. Pinnatisecta E prickly poppy areas, Sacramento mountains 4200-7100ft elevation

Mark tall-grass prairie

ieRtratDEIS Retardant Fire Twain, Asclepias meadii Mead's Milkweed 9 n n Midewin, T Shawnee Appendices San B Primarily found on soils derived directly from decomposing limestone bedrock, especially on ridgetops Cushenbury Astragalus albens 5 y and on open, very rocky, relatively gentle slopes at n milk-vetch 1500-2000 m elevation. Also known from lower elevations 297 E (down to about 1170 m) in rocky washes that receive 298 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

limestone outwash and from granite and granite-quartzite substrates. Plant communities are pinyon-juniper woodland, pinyon woodland, Joshua tree woodland, blackbrush scrub, and creosote bush-blackbrush scrub. Occupied sites tend to have low overstory and shrub canopy cover, high soil pH, and a high percentage of soil

susp Flat seasonally moist remnants of alkaline floodplain Applegate's Klamanth grasslands of the Klamath Basin, at about 1250 meters. Astragalus applegatei 5 n n Milk-vetch The substrate is poorly drained fine silt loam (an E underlying hardpan impedes drainage).

Angeles, Brush/chaparral communities. The seeds germinate after Cleveland, fire or other disturbance and the plants live only 2-3 years Brauton's susp on before senescing or being crowded out by developing Astragalus brauntonii 5 y n milk-vetch* San B vegetation. The natural frequency of fire in the species' habitat is unknown. The plants may be restricted to E limestone substrates.

T Payette juniper-sagebrush communities on open, steep, naturally Astragalus desereticus Desert Milkvetch 4 n disturbed south and west (rarely north) facing slopes of n sandy-gravelly soils of the Moroni Formation

susp on strongly associated with active, stabilized, and shielded San B sandy substrates (Sanders and Thomas Olsen Associates Astragalus lentiginosus Coachella Valley 1996 p. 3). This taxon is primarily found on loose aeolian 5 y n var. coachellae milk-vetch* (i.e., wind transported) or alluvial (i.e., water transported) sands that are located on dunes or flats, and along disturbed E margins of sandy washes

T Payette Subalpine mixed grass-forb cushion plant communities Astragalus limnocharis Heliotrope on level to gently sloping pavement surfaces of limestone 4 y n var. montii Milk-vetch (Flagstaff Limestone). 3231-3338 m elevation. timberline (approximately 3350 m).

susp on Highly seleniferous soils from niobrara shale, moderate (Osterhout Arapahoe, slopes sometimes in sagegrush. Astragalus osterhoutii 2 n na milkvetch) Med Bow E Routt NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Triple-ribbed San B Sandy and gravelly soils of dry washes, or on decomposed Astragalus tricarinatus 5 y y T milk-vetch* granite or gravelly soils at the base of canyon slopes.

Cleveland Steep slopes; sandstone and volcanic (1 site) substrates in Encinitas Baccharis vanessae 5 y fairly open southern maritime chaparral and dense mixed n baccharis T chaparral communities. 60-335 m elevation

Angeles, the margins of dry washes with sandy and gravelly Cleveland, substrates and alluvial shrub communities; and steep slopes Berberis nevinii Nevin's barberry 5 y n SanB with coarse soils and chaparral communities. The presence E potential of groundwater flow may be a habitat requirement.

George The only known natural population was found along the Wash Jeff floodplain of a creek at an elevation of about 1160 m.The Virginia site is within a narrow strip of second-growth forest that Betula uber 8 n y Round-leaf Birch includes many sweet and yellow birches (Betula lenta and B. alleghaniensis). The band of forest is nearly surrounded T by agricultural land.

FL forests Locally abundant on deep, white, dry sands of ancient Bonamia grandiflora Florida Bonamia 8 y dunes and sandy ridges in clearings or openings of scrub n T habitat on the Central Ridge of Florida.

Angeles, Grasslands, often in association with vernal pools and in Thread-leaved Cleveland, floodplains. 90-300 m elevation. Brodiaea filifolia 5 y n brodiaea susp on T San B

Calyptridium Mariposa Sierra Sandy soils of decomposed granite, primarily in foothill 5 n y pulchellum T pussy-paws oak woodlands. 400-1100 m elevation.

ieRtratDEIS Retardant Fire succulent Susp in vernal pool Castilleja campestris (=fleshy) 5 Sierra n n ssp. succulenta t owl's-clover Appendices Ashy-grey San B Pebble Plains Plants Castilleja cinerea 5 y n T paintbrush 299 300 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

potential Slightly alkaline sandy loam in native grassland or shrub- on land. California Sequoia; Caulanthus californicus 5 y n jewelflower critical hab on Los E Padres

Cleveland Dry ridgetops and north to northeast-facing Vail Lake chaparral-covered slopes with phosphorous deficient soils Ceanothus ophiochilus 5 y y ceanothus formed from ultra-basic parent materials or weathered T gabbro

Chlorogalum Los Padres Cismontane woodland, valley and foothill grassland, Camatta Canyon purpureum var. 5 y between 300 and 600 m. C. purpureum var. reductum is n amole reductum T almost always found on serpentine substrates.

susp on Wetlands, mesic coastal dunes, and brackish marshes and Cirsium loncholepis La Graciosa thistle 5 y n T Los Padres swamps

Lincoln Moist banks of streams, wet meadows, and other moist Sacramento Mts. areas above 2440 m. Remaining populations are mostly Cirsium vinaceum 3 y n Thistle in the vicinity of springs flowing out of limestone, where T steep calcium carbonate deposits have formed.

Sequoia Primarily on open sites, including roadbanks, in blue oak Clarkia springvillensis Springville clarkia 5 y n T woodland communities. 360-910 m elevation

FL forests Widely scattered in undisturbed clearings of xeric sandhill Clitoria fragrans Pigeon Wings 8 y n T and scrub communities on well-drained upland soils.

FL forests Formerly occurred in the grassy understory of the upland longleaf pine-wiregrass vegetation, as well as steephead Apalachicola several sq Conradina glabra 8 y edges. Currently found on dry, sandy, well-drained soils Rosemary miles of road edges, in planted pine plantations and along their E cleared edges, and along the edges of ravines

Daniel Restricted to boulder/cobble/gravel-bars, sand bars and Cumberland Conradina verticillata 8 Boone n islands, sandy river banks, flood plains in river gorges, n Rosemary T and similar sunny riparian areas where seasonal flooding NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

minimizes competition (by keeping out out less well-adapted competitors) and creates new gravel-bar habitats for colonization

Coronado Alluvial basins and hillsides in semi-desert grasslands, desert scrub and the transition area between the two. Most Coryphantha scheeri Pima pineapple 3 y commonly found on open areas on flat ridge-tops or slopes n var. robustispina cactus of less than 10-15 percent. Soils range from shallow to E deep and silty to rocky.

Slender-horned Angeles, Old sandy benches or floodplain terraces containing Dodecahema leptoceras 5 y n E spineflower Cleveland alluvial fan scrub just below 2200 feet.

Cleveland canyon bottoms and shaded slopes of canyon walls Santa Monica Dudleya cymosa ssp. consisting of conglomerates of sedimentary rock - adjacent Mountains 5 y n ovatifolia plant communities include coastal scrub and chaparral but dudleya T microhabitat supporting mosses, lichens and clubmosses.

Chat - openings in woods, such as cedar barrens and clear cuts, Oconee, along roadsides and utility line rights-of-way, and on dry George limestone bluffs. Usually found in areas with magnesium- Wash- Jeff, and calcium-rich soils Smooth Purple Echinacea laevigata 8 NC n n Coneflower Forests, Francis- Marion, E Sumter

Echinocereus fendleri Kuenzler Lincoln lower fringes of PJ woodlands 3 y n var. kuenzleri E hedgehog cactus

ieRtratDEIS Retardant Fire Echinocereus Tonto chaparral or evergreen woodland Arizona hedgehog triglochidiatus var. 3 n n cactus arizonicus E Appendices arid Chenopod scrub, valley and foothill grasslands 70-1000m Eremalche kernensis grasslands near Stanislaus and Eldorado NF (Eremalche parryi ssp. Kern mallow 5 and scrub nearby n Kernensis) lands of the 301 E San 302 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Joaquin Valley and adjacent foothills and valleys

Eriastrum densifolium Santa Ana River susp on alluial fan scrub communities on higher floodplain terraces, 5 y n ssp. sanctorum E woolystar* San B juniper, mountain mahogany

T Fish Lake Exposed mesas and steep, narrow canyons cut into Navajo Sandstone; cool, shaded, mesic sites in crevices which collect soil and organice matter and, less frequently, along canyon bottom washes. 1600-2170 m elevation. Cool, Erigeron maguirei Maguire Daisy 4 n mesic wash bottoms and dry, partially shaded slopes of n eroded sandstone cliffs of Wingate, Chinle, and Navajo Sandstone Formations in mountain shrub, Douglas-fir, ponderosa pine, and lower limits of juniper woodland communities between 5,400 and 7,100 feet elevation

San B Usually on substrates derived from limestone or dolomite on dry rocky slopes and outwash plains. Sometimes found on sites underlain by granite, usually with an overlying Erigeron parishii Parish's daisy 5 y wash of limestone materials. 2 populations are have been n found on quartz substrates. 800-2000 m elevation, from blackbrush scrub to pinyon and pinyon-juniper woodland T communities.

Cibola Pinyon-juniper woodlands on steep easily eroded sandstone Erigeron rhizomatus Zuni Fleabane 3 n n T slopes and clay banks

Eriogonum kennedyi Southern mountain Los Padres, Pebble Plains Plants 5 y n var. austromontanum T buckwheat San B

Eriogonum longifolium FL forests Florida scrub vegetation dominated by shrubby evergreen Scrub Buckwheat 8 y n var. gnaphalifolium T oaks and ericoid shrubs with sand pine

Eriogonum ovalifolium Cushenbury San B Carbonate Plants 5 y n var. vineum E buckwheat NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Pike San Alpine tundra above 3700 m elevation and downslope Isabel, from snowfields, which provide melt water all summer. White The plants are usually found on south- and east-facing flat Penland alpine fen Eutrema penlandii 2 River n to gently sloping benches with steep walls that provide n mustard some protection from snow-melting winds. On these wet benches, the plants are found in moss-covered peat fens, T bogs, or marshes.

susp Slopes covered with southern mixed chaparral, closed cone Fremontodendron Mexican 5 Cleveland y coniferous forest dominated by Tecate cypress (Cupressus n mexicanum Flannelbush E forbesii), and canyons. 300-1000 m elevation.

Rogue Open, somewhat dry, low elevation, mixed oak-madrone River woodlands. Also ponderosa pine (Pinus ponderosa) Gentner Fritillaria gentneri 5, 6 Siskiyou, n in r6, n in r5 woodlands and chapparal n Mission-bells susp E Klamath

Ozark - St Sandstone glades and saline prairies. In Missouri, Francis Geocarpon grows on moist, sandy soils on exposed sandstone outcrops or glades, where ledges of fine sandstone, interbedded with shale, are exposed along small streams. The surrounding area, where deeper soils prevail, Geocarpon minimum Geocarpon 8 n n is savannah. Sites in Arkansas and Louisiana are characterized by very thin soils that are high in sodium and magnesium. Woody plants are nearly absent. In these saline prairies, the species occurs mostly in very thinly T vegetated, barren-like areas.

Cherokee, Exposed, high elevation situations in the southern NC forests Appalachians. Primarily in the crevices of northwest-facing

ieRtratDEIS Retardant Fire Geum radiatum Spreading Avens 8 y cliffs. Also at the bases of talus slopes, or, rarely, in n openings in heath balds. Found only at elevations over E 1310 m. Appendices Chat - On shady rock or shady moss-covered rock (Dey 1978). Oconee, Further, it is "found in areas of high humidity, either on Rock Gnome Gymnoderma lineare 8 Cherokee, y high-elevation cliffs, where it is frequently bathed in fog, n Lichen NC Forests or in deep river gorges at lower elevations. It is primarily 303 E limited to vertical rock faces, where seepage water from 304 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

forest soils above flows at (and only at) very wet times, and large stream side boulders, where it receives a moderate amount of light but not high-intensity solar radiation"

Okanogan grows in openings of ponderosa pine (Pinus ponderosa) and Douglas-fir (Pseudotsuga menziesii) forests on loose, Hackelia venusta E Showy Stickweed 6 Wenatchee y well-drained, granitic rocky or sandy soils. It is found on y unstable talus slopes, and ledges or cracks on cliff faces at lower elevations (470-820 meters or 1550-2700 feet).

FL forests Occurring in the long-leaf pine ecosystem, this species occurs in acidic boggy areas in full sun with soils high in sand and peat. Most occurrences are found in open seepage Harperocallis flava Harper's Beauty 8 y bogs dominated by a suite of herbaceous species and n lacking woody vegetation. Some times the species is found growing at the base of woody evergreen shrubs with few E herbaceous species (Walker and Silletti 2005).

Lincoln Steep gravelly north- and east-facing hillsides with Todsen's gypseous limestone soils at about 2000 m elevation. The Hedeoma todsenii 3 y n pennyroyal surrounding plant community is an open pinyon-juniper E woodland (NMNP PAC 1984).

George Virginia: Helenium virginicum is a wetland plant restricted Wash. - to shallow, seasonally inundated ponds (which are in or Jeff, Mark near sinkholes). Ponds supporting Virginia sneezeweed Twain vary in size, basin depth and shape, and length of hydroperiod. While many of the wetlands appear pond-like, consisting of more or less circular water-filled depressions with concentric vegetation zones, others within shallow Virginia basins are more meadow-like in physiognomy with little Helenium virginicum 8,9 n n Sneezeweed well-defined vegetation zonation. The level of disturbance present at the sinkhole ponds includes relatively undisturbed ponds surrounded by forest, more meadow-like habitats around farm ponds actively used by cattle, a backyard seasonal wetland maintained in an open state by the landowner, a seasonally wet mowed lawn, and a seasonal wetland degraded by severe cattle trampling and t an ongoing attempt to fill the site NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

NC Forests Clearings in, and edges of, upland oak-pine-hickory woods Schweinitz's Helianthus schweinitzii 8 n and piedmont longleaf pine forests in moist to dryish sandy n Sunflower E loams

Chat - Restricted to forested wetlands that are groundwater Oconee, influenced and are perennially water-saturated with alow George frequency of inundation. Sutter (1982) described these as Wash/Jeff, sites where the water table is at or very near the surface NC Forests and is stable, fluctuating only slightly during spring and summer. These habitats include emergent portions of hummocks in and along stream channels in Atlantic white cedar (Chamaecyparis thyoides) swamps, headwater seepage wetlands, red maple (Acer rubrum) swamps, mixed hardwood/evergreen swamps, and (rarely) black Helonias bullata Swamp Pink 8 n spruce-tamarack (Picea mariana-Larix laricina) bogs. In n Georgia, the species is found in coldwater Blue Ridge seepage swamps (mountain bogs) with purple pitcherplant (Sarracenia purpurea), red maple, mountain laurel (Kalmia latifolia), Carolina sheep laurel (K. caroliniana), rosebay rhododendron (Rhododendron maximum), and thickets of tag alder (Alnus serrulata) and peat moss (Sphagnum). The species appears to be somewhat shade tolerant and to need enough canopy to minimize competition with other more aggressive species and herbivory by deer. It is often T found at stream sources.

NC Forests Acidic soils on moist to rather dry north-facing slopes of Dwarf-flowered ravines and along bluffs and hillsides in boggy areas next Hexastylis naniflora 8 n n Heartleaf to streams. Vegetation is typically oak-hickory-pine forests T of the Piedmont

ieRtratDEIS Retardant Fire Houstonia purpurea NC high elevation cliffs and rock outcrops in and around var. montana also see Roan Mountain Forests, grassy balds 8 y n Hedyotis purpurea var Bluet Cherokee

montana E Appendices

Mendecino, Small vernal wetlands with firmly consolidated bottoms. Flathead, These include shallow, low-elevation glacial pothole ponds Howellia aquatilis water howellia 1, 5, 6 y in r6; y in r5 n susp on: and former river oxbows with margins of deciduous trees 305 T Six Rivers, and shrubs. These habitats are inundated by spring rains 306 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Lolo, and snowmelt runoff and typically dry out by the end of Kootenei, the growing season. The plants tend to root in the shallow Idaho water at the edges of deeper ponds that are (at lower Panhandle, elevations) surrounded by deciduous trees. Also aquatic Colombia annual that grows submerged, rooted in bottom sediments River of ponds and sloughs - no documented occurrences - gorge avoidance areas around water would further protect (OR&WA), unknown occurrences - LAA call due to potential that Gifford areas may be dried out later in the year Pinchot, Okanogan - Wenatchee, Mount Hood

NC Forests Shallow soils that form over quartzite or mica gneiss rock Mountain Golden Hudsonia montana 8 n ledges. Usually in the sparsely vegetated ecotone between n Heather T bare rock and heath bald

TX forests Poorly drained, sparsely vegetated areas ("slick spots") at Hymenoxys texana Prairiedawn 8 n the bases of small mounds (mima or pimple mounds) in n E open grassland or in almost barren areas.

George Soil-filled pockets and crevices of an exposed sandstone one Peter's Iliamna corei 8 Wash/Jeff n outcrop watershed Mountain-mallow E only

susp on Wide variety of vegetation types. Historically the area SanJuan inhabited by I. polyantha was vegetated by shrubland, woodland, and forests, and it has been documented in all Ipomopsis polyantha (Pagosa skyrocket) 2 n of these vegetation types. Much of the area in and around na Pagosa Springs was historically a Pinus ponderosa (ponderosa pine) forest with an understory of Quercus P gambelii (Gambel’s oak

Ipomopsis Holy ghost Santa Fe Along a roadside and in small woodland clearings beneath 3 y y sancti-spiritus E ipomopsis Ponderosa pine on steep, south- or southwest-facing slopes. NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Louisiana MS Forests aquatic plant growing in and along streams Isoetes louisianensis 8,9 n n E Quillwort

White Mtn, Acidic soils, in dry to mesic second-growth, deciduous or Monogahela, deciduous-coniferous forests; typically with light to susp. or moderate leaf litter, an open herb layer (occasionally dense known on ferns), moderate to light shrub layer, and relatively open Wayne, canopy (Flora of North America 2002). Isotria medeoloides Allegheny, frequently occurs on flats or slope bases near canopy Chat - breaks (Flora of North America 2002). Small Whorled Oconee, Isotria medeoloides 8 y n Pogonia Cherokee, George Wash/Jeff, NC Forests, Francis - Marion T Sumter

T susp Boise Semi-arid, sagebrush-steppe habitats of the Snake River Plain and Owyhee Plateau and adjacent foothills of Slick spot southern Idaho. Occurs only in microsites, variously Lepidium papilliferum 4 n n peppergrass termed slick spots, mini-playas, or natric sites, which have soils much higher in clay content and significantly higher in sodium than adjacent areas.

Ozark - St Open limestone glades, barrens, and outcrops within Lesquerella filiformis Missouri Francis unglaciated prairie areas. Occassionally in dolomitic 8 n n (Physaria) Bladder-pod glades. Often associated with grazed pastures. Cedar E invasion of glade sites is common. ieRtratDEIS Retardant Fire TX forests Open areas associated with exposed calcareous Weches Formation outcrops that are seepy and wet most of the year. Soils are thin, poorly drained, and alkaline. In n - 2 Lesquerella pallida White Bladderpod 8 n Appendices contrast, most of the surrounding soils are acidic and watersheds sandy. The surrounding vegetation type is pine-oak-hickory E woodland 307 308 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

NC Forests Shallow, acidic soils that form on and around exposed Heller's Blazing Liatris helleri 8 n granite ledges, outcrops, and balds at high elevations. In n Star T full sun with grasses, sedges, and other composites

Coronado Requires backwaters, cienegas, springs systems or side channels with perennial flow and gentle gradients in areas that are not subject to frequent or intense floods. Does not Lilaeopsis schaffneriana Huachuca water 3 y tolerate crowding by other plant species, so some flooding n spp. Recurva umbel is needed to keep other vegetation levels low. Generally found along the margins of these habitats, in 5-15 cm of E water and in shaded or unshaded sites

susp Pacific coastal wetlands. Mostly restricted to the edges of Umatilla early successional, wet sphagnum bogs and forest or thicket openings along the margins of ephemeral ponds Lilium occidentale E Western Lily 6 n and small streams. Also in coastal scrub and prairie, and na other poorly drained soils near the ocean where fog is common. No documented occurrences & avoidance areas around water would further protect unknown occurrences

susp in margins of vernal swales and to a lesser extent on the Butte County Lassen margins of vernal pools located on alluvial terraces in Limnanthes floccosa (Shippee) 5 n annual grasslands with mima mound topography. Mima na ssp. Californica meadowfoam mounds are soil mounds of unknonw origina that are a few E feet in height.

MS forests, Can apparently occupy a variety of habitats as long as Francis hydrological requirements are met. Occurs in seasonally -Marion flooded wetlands such as floodplain/bottomland hardwood Sumter forests and forested swales, on the bottoms and edges of Lindera melissifolia Pondberry 8 n shallow seasonal ponds in old dune fields, along the n margins of ponds and depressions in pinelands, around the edges of sinkholes in coastal areas with karst topography, and along the borders of Sphagnum bogs. Usually in shade, E but tolerates full sun.

susp Rogue Grows in vernally wet habitats. Blooms and fruits early Lomatium cookii E Cook's Lomatium 6 River - n in the spring na Siskiyou NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Lupinus oreganus var. Umpqua prairie plant, although, in Douglas County, it also grows T Kincaid's Lupine 6 n n kincaidii in forests and along forest edges

NC Forests Rough-leaf loosestrife occurs most often in ecotones between longleaf pine uplands and pond pine pocosins in moist, sandy or peaty soils with low vegetation that allows for abundant sunlight to the herb layer (USFWS 1993). Fire is primarily responsible for maintaining low vegetation in these ecotones which have been documented to occur Lysimachia Rough-leaf 8 n between the following habitat types: longleaf pine savanna n asperulifolia Loosestrife and pocosin; longleaf pine flatwood and pocosin; longleaf pine savanna and mixed herb; longleaf pine-pond pine and evergreen shrub; longleaf pine/wiregrass savanna and Carolina bay pocosin; Streamhead Pocosin and Pine/Scrub Oak Sandhill; and Sandhill Seep and Pine/Scrub Oak E Sandhill (NCNHP 1993).

FL forests Grassy vegetation on poorly drained, infertile sandy peat soils of the Florida Gulf coastal lowlands near the mouth White Macbridea alba 8 y of the Apalachicola River. Also in seepage bogs and n Bird-in-a-nest savannas and, sparingly, on drier sites with longleaf pine T and runner oaks. (Based on Ward 1979.)

Daniel Cool, humid, cave-like overhangs called rock houses Minuartia Boone formed through the differential weathering of sandstone cumberlandensis also Cumberland 8 n strata. Found on the sandy floors of these rock houses and n Arenaria Sandwort in similar situations such as beneath sandstone ledges. This cumberlandensis E unusual habitat is shared with very few other plant species

T Nez Perce, Gentle to very steep, open river canyon slopes. Aspects Wallowa vary, but are usually southeast to west. Soils are often

ieRtratDEIS Retardant Fire Macfarlane's Whitman sandy and underlain by talus. Associated plants include Mirabilis macfarlanei 1,6 n in OR, n in MT n Four-O'Clock bluebunch wheatgrass (Agropyron spicatum), cheatgrass (Bromus tectorum), sand dropseed (Sporobolus

cryptandrus), and scorpion weed Appendices

Monolopia congdonii San Joaquin susp Chenopod scrub, valley and foothill grassland; sandy soils 5 y na (Lembertia congdonii) E woolythreads Seqioia 309 310 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

susp San B Permanent wetlands, fresh or brackish, in marshes or along Nasturtium gambelii Gambel's 5 y the borders of lakes and slow-flowing streams or ditches. na (Rorippa gambellii) watercress* E Soils are acidic sandy peats. Sea level to 450 m elevation

FL forests Florida scrub vegetation dominated by shrubby evergreen Nolina brittonia Britton's Beargrass 8 y n E oaks and ericoid shrubs with sand pine

Sequoia, Sandy soils or sand of flats and low hills mostly in San B grassland at 120-550 m (Benson 1982; Brown and Cypher Opuntia basilaris Var. Bakersfield cactus 5 y 1997). Characterisic in Sierra-Tehachapi Saltbush Scrub n trelease community, but also in Blue Oak Woodland and a riparian E woodland.

San Joaquin statewide small seasonal pools Orcuttia inaequalis Valley Orcutt 5 statewide n T grass

Lassen, Vernal Pools with a very well developed soil profile. O. Modoc, tenuis prefers clay soils which shrink and swell. As they Slender Orcutt Orcuttia tenuis 5 Plumas, y dry, large cracks develop which allow seeds trapped deeply n Grass susp Shasta in the soil to float to the surface with the first inundation T Trinity

Francis variety of Coastal Plain habitats prone to long periods of Marion inundation, including pond cypress ponds, grass-sedge Sumter dominated Carolina bays, wet pine savannahs, shallow Oxypolis canbyi Canby's Dropwort 8 n pineland ponds and cypress-pine swamps or sloughs. The n largest and most vigorous populations reported occur in open bays or ponds which are flooded throughout most of E the year and which have little or no canopy cover

E Humbolt - Hills, benches and flats, of open, semi-arid grassland with Pediocactus despainii San Rafael Cactus 4 n n Toiyabe scattered junipers and pinyon pines

T susp Manti Alkaline, fine-textured soils, primarily derived from the Pediocactus winkleri Winkler Cactus 4 -LaSal n Dakota Formation. Associated with salt desert shrub na communities at 1450-1600 m elevation. NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

NEBR Nebraska Sand Hill Prairie (Blowout known, Penstemon haydenii 2 n n penstemon) MBR E suspect

E Uinta, susp steep slopes in sparse juniper-pinyon and mountain brush YES, 4 on Manti communities (Welsh 1987). known sites Phacelia argillacea Clay Phacelia 4 n -LaSal probably 2 populations

Grand Barren, raw exposures of the Coalmont Formation, a Mesa - rusty-colored sandy substrate. The species grows most Phacelia scopulina var. (Debeque 2 Umcp, n abundantly on the steepest, most sparsely vegetated, and n submutica phacelia) White most erodible slopes, such as on the sides of deeply cut P River ravines.

Klamath Serpentine talus in lower and upper montain coniferous Phlox hirsuta Yreka Phlox 5 n n E forest communities

Phlox nivalis ssp. Texas Trailing potential in Sandy soils in open pine woodlands - Use of fire retardant pot in 8 not in tx forests n texensis T Phlox R8 is less than 0.01% land base annually.

Physaria kingii ssp. San B single leaf pinyon mountain juniper and white fir forests San Bernardino Bernardina - endemic to the San Bernardino Mountains, CA Mountains 5 y n (Lesquerella kingii ssp. bladderpod bernardina) E

FL forests Open, acidic soils of seepage bogs on gentle slopes, deep Godfrey's quagmire bogs, ditches, and depressions in grassy pine Pinguicula ionantha 8 y n Butterwort flatwoods and grassy savannas, often occurring in shallow T standing water. ieRtratDEIS Retardant Fire Cherokee Soil-filled cracks in phyllite boulders along river banks Ruth's and in rivers. Shade intolerant but adapted to annual high Pityopsis ruthii 8 y 2 wshds Golden-aster water flows; requires periodic flooding and scouring to Appendices E remove competing vegetation

susp on Open, moist, poorly drained clay soils at 100-150 m Rough Popcorn Plagiobothrys hirtus E 6 Umpqua n elevation. Associated vegetation is dominated by tufted na

311 Flower hairgrass (Deschampsia cespitosa), meadow barley 312 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

(Hordeum brachyantherum), and various sedges. Found only in seasonal wetlands that are inundated by water from late fall to early spring (vernal pools) at lower elevations (approximately 300 to 500 ft or 100 to 150 m) (Guerrant, no date).

susp tall grass prairie found in full sun on moist to wet Nebraska calcareous (calcium-rich, or alkaline) tallgrass prairies Western prairie and sedge meadows (many flooded for 1-2 weeks per year). Platanthera praeclara 1,2 n in r2; n in r1 na fringed orchid It most often grows in relatively undisturbed grassland, but can also be found in moderately disturbed sites such T as roadside ditches

San Bernardino Cleveland, Edges of moist meadows at 1500-2300 m elevation. Poa atropurpurea 5 y y E bluegrass San B

FL forests Sandhills characterized by longleaf pine and low scrub oaks, including low turkey oak woods, and transitional Polygala lewtonii Lewton's Polygala 8 y n sandhill/scrub habitats. This species occasionally inhabits E powerline clearings n

T Wasatch - Damp ledges, crevices, and over-hanging rocks along Y, 6 known Cache canyon walls. Almost always on north-facing, moss Primula maguirei Maguire Primrose 4 n locations in covered limestone cliffs at or near the canyon bottom. one county 1350-1700 m elevation.

SixR, sus Non-native grasslands and occassionally grassland-blue in oak woodland community ecotones in the Central Valley Stanislaus of California. The composition of the prehistoric grassland San Joaquin adobe Pseudobahia peirsonii 5 y communities in this area is unknown; the communities n sunburst have long-since become dominated by exotic grasses. P. peirsonii occurs only on heavy adobe clay soils which T retain moisture into the summer dry season.

AL forests, Occurs in three habitat types: rocky/gravelly shoals or Ouachita cracks in bedrock outcrops beneath the water surface in clear, swift-flowing streams (usually in microsites that are Ptilimnium nodosum Harperella 8 n n sheltered from rapidly moving water); edges of intermittent pineland ponds or low, wet savannah meadows on the E Coastal Plain; and granite outcrop seeps NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Coconino - Gravelly clay loams over limestone on rolling hills Purshia subintegra Arizona cliffrose 3 n n E Tonto dominated by creosote bush (Larrea tridentata).

FL forests Acidic, moist to wettish, highly organic sands of ecotones Rhododendron minus Chapman's 8 y between flatwoods and titi bogs in the drainage tributaries n var. champmanii Rhododendron E of the Apalachicola River, Florida

Francis associated with a deciduous, mixed hardwood forest with Miccosukee Ribes echinellum 8 Marion n an overstory canopy dominated by species of oak and n Gooseberry T Sumter hickory (Quercus and Carya).

NC Forests Very gently sloping areas with some standing water refreshed by slow continuous seepage of cool clear water. Appropriate habitat for this species is typically found in a narrow band at the bluff-floodplain ecotone. The seeps originate at the base of the bluffs and Sagittaria fasciculata Bunched is generally found near, but not at, the origin of the seep Sagittaria fasciculata 8 n n Arrowhead (water flow at the seep origin is usually too swift ortoo heavy to allow for colonization). Appropriate habitats often continue along the edge of the bluff downslope from the seep, but generally do not extend far into the floodplain proper because there the seepage tends to spread out and E the water stagnates.

State of Three distinct habitat types have been described for S. AL, Chat - oreophila. They are sandstone streambanks, with 13 extant Oconee, colonies in the Cumberland Plateau; mixed oak or pine Green Pitcher NC Forests flatwoods, with 5 extant colonies in the Cumberland Sarracenia oreophila 8 n n Plant Plateau; and seepage bogs, with 5 extant colonies in the Cumberland, 2 colonies in the Blue Ridge, and 2 colonies in the Ridge and Valley provinces (U.S. Fish and Wildlife

ieRtratDEIS Retardant Fire E Service 1985)

Sarracenia rubra ssp. Mountain Sweet NC Forests bogs and streamsides 8,9 n n jonesii E Pitcher Plant Appendices 313 314 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Daniel Acidic, sandy or peaty soils in open pine flatwoods, pitch Boone, pine lowland forests, seepage bogs, palustrine pine American Francis savannahs, and other grass- and sedge-dominated plant Schwalbea americana 8 n n Chaffseed Marion communities Sumter, E TX forests

George open, tall herb-dominated wetlands. Often it grows at the Wash/Jeff water's edge, or in a few centimeters of water, but it may also be in fairly deep water (0.3-0.9 m) or away from standing water. In the southern part of its range, the most common habitat is sinkhole ponds, usually in sandstone. Northeastern Scirpus ancistrochaetus 8 n Water levels in these ponds tend to vary both with the n Bulrush season and from year to year. At least one site (in Massachusetts) is in a sandplain, where water level fluctuates as well. Two sites in Vermont are influenced to some extent by beaver activity as well as other E hydrological

Grand Mesa - Colorado hookless Sclerocactus glaucus 2 Ump, susp n n cactus on White Exposed, gravel-covered, clay hills, saltbush or sagebrush T River flats, or pinyon-juniper woodlands;

FL forests Dark, humus rich sands of pine-palmetto flatwoods, wet Scutellaria floridana Florida Skullcap 8 y prairies, and savannahs. (Based on Kral 1983) Seepage n T slopes.

Coconino Alpine tundra areas on sparsely vegetated loose talus San Fransisco slopes, at 3350-3750 m; usually just above southwestern Sencio franciscanus 3 n n peaks groundsel montane spruce-fir or bristlecone pine (Pinus aristata) T, CH forests. - Fire potential very low

Layne's Eldorado, Chaparral communities primarily on gabbro-derived soils; Senecio layneae butterweed 5 Plumas y occassionally on serpentine. n T (=ragwort) NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Sequioa, Grassy slopes from 120 to 425 m elevation. The extant Keck's sus in or population is in a sparsely vegetation annual grassland on Sidalcea keckii checker-mallow 5 near Sierra y red or white-colored clay soils with 2-40 percent slopes. n (=checkerbloom) The clay substrates are thought to be derived from E serpentine.

susp on Although sites are generally moist and open, the character Siuslaw of the habitat differs somewhat between the Willamette Valley and Coast Range. In the Willamette Valley, sites Nelson's Checker occur within a mosaic of urban and agricultural areas from Sidalcea nelsoniana T 6 n na Mallow 45-200 m elevation. Sites are usually open or at the edge between open areas and deciduous woodlands, although populations occasionally occur in the understory of woodlands or among woody shrubs

Wenatchee Okanogan fresh water marshes Sidalcea oregana var. E Mountains 6 - y n calva Checker Mallow Wenatchee

Bird-foot SanB Mountain Meadow species Sidalcea pedata 5 y n E checkerbloom

T Nez Perce, Restricted to Palouse Prairies, sometimes extending into Umatilla, areas where the grasslands are intermingled with ponderosa Wallowa pine (Pinus ponderosa) woodlands Spalding's Whitman, Silene spaldingii 1,6 n in r6, no in MT n Catchfly susp on Lolo, Koot, Idaho Panhandle

ieRtratDEIS Retardant Fire Sisyrinchium NC Forests Rich, basic soils in clearings and near the edges of upland White Irisette 8 n n dichotomum E woods

Daniel sandstone cave-like structures called rockhouses and White-Haired Appendices Solidago albopilosa 8,9 Boone n beneath overhanging sandstone ledges where the plants n Goldenrod T root in loose sand and soil-filled crevices 315 316 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Cherokee, Rocky places such as outcrops, ledges, cliffs, and balds at Blue Ridge Solidago spithamaea 8 NC forests y elevations above 1400 m. Sites occupied by the species n Goldenrod T are generally exposed to full sun

Daniel Periodically flood-scoured banks of high-gradient Boone, mountain streams, meander scrolls, point bars, natural Cherokee, levees, and braided features of lower stream reaches, and George occasionally near disturbed rights-of-way (Ogle 1992). Wash/Jeff, Plants often found on geologically active areas with Spiraea virginiana Virginia Spiraea 8 NC forests y erosion, deposition, and slumping, along rivers with n dynamic flooding regimes, sandbars, scoured river shore and flatrock habitat with crevices. These areas also are associated with cobbles, boulders, and massive rock outcrops with sandy or clay soils. The areas can be T periodically xeric

Canelo Hills Coronado mid elevation, wetland communities Spiranthes delitescens 3 y n E Ladies-tresses

Uinta, Adapted to early- to mid-seral, moist to wet conditions, Targhee, where competition for light, space, water, and other susp resources is normally kept low by periodic or recent Medicine disturbance events. Major occupied habitat types include Bow - (1) alluvial banks, point bars, floodplains, or ox-bows Routt, Pike associated with perennial streams, with a high water table San Isabel, and short, perennial graminoid- and forb-dominated White vegetation maintained by grazing, periodic flooding, or River, mowing; (2) river floodplain habitats which experience Okanogan, regular spring flooding and/or frequent large scale floods Ute ladies’-tresses n in r6, n in r2; y in Spiranthes diluvialis 2,4, 6 Boise, but maintain relatively stable, moist to wet soil in summer, n orchid r6; Caribou within moist meadow, riparian woodland, or riparian Targhee, shrubland communities; (3) shores of lakes and reservoirs, Salmon, in mesic meadow-type vegetation maintained by lake level Sawtooth, fluctuations or seasonal flooding of gravel bars; (4) Wasatch groundwater-fed springs, sometimes in desert settings, or Cache, subirrigated meadows where edaphic characteristics (e.g. Challis high water table and calcic soil), fire, and/or grazing are sufficient to prevent invasion of later seral vegetation; and (5) human-influenced habitats, including perennial stream, T river, lakeshore, and spring sites directly associated with NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

human-developed dams, levees, reservoirs, irrigation ditches, reclaimed gravel quarries, roadside barrow pits, and irrigated meadows. More than half of documented populations occur in sites in which natural hydrology has been influenced by dams, reservoirs, or supplemental irrigation, and many populations occur within agricultural or urban settings. 550 - 2100 m. (adapted from Fertig et al. 2005)

TX forests Margins of post oak (Quercus stellata) woodlands in sandy loams along intermittent tributaries of rivers. Often in areas where edaphic or hydrologic factors (such as high levels Navasota of aluminum in the soil or a perched water table) limit Spiranthes parksii 8 n n Ladies'-tresses competing vegetation in the herbaceous layer. Besides post oak, associated species include water oak (Q. nigra), blackjack oak (Q. marilandica), and yaupon (Ilex E vomitoria).

Taraxacum California San B Mountain Meadow species 5 y n californicum E taraxacum

potential in Moist alkaline meadow habiatas in the Baker-Powder River R6 valley bottomlands in northeast Oregon (Baker and Union Thelypodium howellii Slender-petaled potential T n Counties). Forests near Baker and Union county do not n spectabilis Mustard in 6 have forests with land base >0.01% annually applied w/ retardant

Thelypodium Slender-petaled San B Mountain Meadow Species 5 y n stenopetalum E thelypodium

Thlaspi montanum var. Kneeland Prarie sus on Six Serpentine rock outcrops in coastal prairie habitat; 760 m 5 n n ieRtratDEIS Retardant Fire californicum E Grass Rivers in elevation

T Dixie, Pinyon-juniper and salt desert shrub communities on Last Chance Townsendia aprica 4 Fishlake n barren, silty, silty clay, or gravelly clay soils of the Mancos n Townsendia Appendices Shale Formation at 1695-2440 m elevation.

Daniel Running buffalo clover's habitat most commonly is mesic Running Buffalo Trifolium stoloniferum 8 Boone n woodlands in partial to filtered sunlight, where there isa n

317 Clover E pattern of moderate periodic disturbance for a prolonged 318 DEIS Retardant Fire Appendices NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

period, such as mowing, trampling, or grazing. It is most often found in regions underlain with limestone or other calcareous bedrock, but not exclusively. It has been reported from a variety of disturbed woodland habitats, including blue-ash savannahs, floodplains, streambanks, shoals (especially where old trails cross or parallel intermittent streams), grazed woodlots, mowed paths (e.g. cemeteries and lawns), old logging roads, jeep trails, skidder trails, mowed wildlife openings within mature forests, and steep, weedy ravines.

Chat - Mixed hemlock-pine-deciduous forests, typically on steep Oconee, slopes or along streams near rhododendrons Trillium persistens Persistent Trillium 8 Francis n (Rhododendron maximum or R. minus). Occasionally in n Marion lowbush blueberry thickets (Flora of North America E Sumter Editorial Committee 2002; Chafin 2007).

Chat - T. reliquum is a species of mesic hardwood forests. The Oconee, forests can be on slopes of various aspects and inclinations Trillium reliquum Relict Trillium 8 Francis n or on bottomlands and floodplains n Marion E Sumter

Lassen, Grows in the bottom of dried Vernal Pools on the eastern Modoc side of the Sacramento and San Joaquin Valleys.Occurs in Northern Basalt Flow, Northern Claypan, and Northern Hardpan vernal pools (Sawyer and Keeler-Wolf 1995) on both low and high terraces within grassland communities, or, rarely, pine forest (one Shasta Co. occurrence). Plants have been documented on clay, loam, and stony clay loam Greene's tuctoria soils, and pools are underlain by iron-silica cemented Tuctoria greenei 5 n n (=Orcutt grass) hardpan, tuffaceous alluvium, or claypan. Occupied pools range in size from 50 square meters to 3.4 hectares (median size 0.6 hectares). Tends to grow in shallower pools than its relatives (Neostapfia and Orcuttia) or on the shallow margins of deeper pools. Associated species include Eryngium castrense, Marsilea vestita, Eryngium vaseyi, Plagiobothrys stipitatus, Alopecurus saccatus, Chamaesyce E hooveri, Orcuttia pilosa, O. inaequalis, O. tenuis, NatureServe Global Federal Common Name FS Forest On forest with Habitat – notes (data derived from Nature Serve FWS NatureServe Scientific Name Status Region Names or retardant websites, and listing packages or recovery plans). Global Sci. States application more Name with NF than 0.01% land base annually

Neostapfia colusana, and Gratiola heterosepala. 30-135 m in Central Valley; 1100 m in Shasta Co. (one occurrence). ieRtratDEIS Retardant Fire Appendices 319 Appendices

1Isolated populations for plants includes a small isolated area where a T&E single population or multiple populations may occur on a forest where the application of retardant could potentially impact individuals, for instance one population occurring within one watershed or canyon .

2Na= not applicable, species are only presently suspected to occur on these NFS lands. Descriptions of Critical Habitat Primary Constitutive Elements for Federally Listed Plant Species (24 species)

Name: Acanthomintha ilicifolia

Region/Forest/Acres: R5. Cleveland, 549 acres

PCE’s: seedling establishment and space for growth and development of Acanthomintha ilicifolia that are: (a) Within chaparral, grassland, and coastal sage scrub; (b) On gentle slopes ranging from 0 to 25 degrees; (c) Derived from gabbro and soft calcareous sandstone substrates with a loose, crumbly structure and deep fissures approximately 1 to 2 feet (30 to 60 cm); and (d) Characterized by a low density of forbs and geophytes, and a low densityor absence of shrubs (http://www.gpo.gov/fdsys/pkg/FR-2008-08-26/pdf/E8-19194.pdf).

Name:Allium munzii

Region/Forest/Acres: R5, Cleveland, 176 acres

PCE’s: (1) Clay soil series of sedimentary origin (e.g., Altamont, Auld, Bosanko, Claypit, Porterville), or clay lenses (pockets of clay soils) of such that may be found as unmapped inclusions in other soil series, or soil series of sedimentary or igneous origin with a clay subsoil (e.g., Cajalco, Las Posas,Vallecitos), found on level or slightly sloping landscapes; generally between the elevations of 985 ft and 3,500 ft (300 m and 1,068 m) above mean sea level (AMSL), and as part of open native or non-native grassland plant communities and ‘‘clay soil flora’’ which can occur in a mosaic with Riversidean sage scrub, chamise chaparral, scrub oak chaparral, coast live oak woodland, and peninsular juniper woodland and scrub; or (2) Alluvial soil series of sedimentary or igneous origin (e.g., Greenfield, Ramona, Placentia, Temescal) and terrace escarpment soils found as part of alluvial fans underlying open native or non-native grassland plant communities that can occur in a mosaic with Riversidean sage scrub generally between the elevations of 985 ft and 3,500 ft (300 m and 1,068 m) AMSL, or Pyroxenite deposits of igneous origin found on Bachelor Mountain as part of non-native grassland and Riversidean sage scrub generally between the elevations of 985 ft and 3,500 ft (300 m and 1,068 m) AMSL; and (3) Clay soils or other soil substrate as described above with intact, natural surface and subsurface structure that have been minimally altered or unaltered by ground-disturbing activities (e.g., disked, graded, excavated, re-contoured); and, (4) Within areas of suitable clay soils, microhabitats that are moister than surrounding areas because of (A) north or northeast exposure or (B) seasonally available moisture from surface or subsurface runoff.

Name: Arenaria ursina

Region/Forest/Acres: R5, San Bernardino,

PCEs: for Arenaria ursina (also Eriogonum kennedyi var. austromontanum) are:

Fire Retardant DEIS 320 Appendices

(1) Pebble plains in dry meadow-like openings within upper montaneconiferous forest, pinyon-juniper woodlands, or Great Basin sagebrush in the San Bernardino Mountains of San Bernardino County, California; at elevations between 5,900 to 9,800 ft (1,830 to 2,990 m) that provide space for individual and population growth, reproduction and dispersal; and (2) Seasonally wet clay, or sandy clay soils, generally containing quartzite pebbles, subject to natural hydrological processes that include water hydrating the soil and freezing in winter and drying in summer causing lifting and churning of included pebbles, that provide space for individual and population growth, reproduction and dispersal, adequate water, air, minerals, and other nutritional or physiological requirements to the species (http://www.gpo.gov/fdsys/pkg/FR-2007-12-26/pdf/07-6137.pdf)

Name:Astragalus albens

Region/Forest/Acres: R5, San Bernardino, 3020 acres

PCE’s: (1) Soils derived primarily from the upper and middle members of the Bird Spring Formation and Undivided Cambrian parent materials that occur on dry flats and slopes or along rocky washes with limestone outwash/ deposits at elevations between 1,171 and 2,013 m (3,864 and 6,604 ft); (2) Soils with intact, natural surfaces that have not been substantially altered by land use activities (e.g., graded, excavated, re-contoured, or otherwise altered by ground-disturbing equipment); and (3) Associated plant communities that have areas with an open canopy cover and little accumulation of organic material (e.g., leaf litter) on the surface of the soil (http://www.gpo.gov/fdsys/pkg/FR-2002-12-24/pdf/02-31631.pdf).

Name:Astragalus limnocharis var. montii

Region/Forest/Acres: R4, Manti LaSal, 65 acres

PCE’s: White Limestone barrens of the Flagstaff formation

Name:Berberiis nevinii

Region/Forest/Acres: R5, Cleveland, 1 acre

PCE’s: canyon floors, washes and adjacent terraces, and mountain ridge/summits, or eroded, generally northeast- to northwest-facing mountain slopes and banks of dry washes typically of less than 70 percent slope that provide space for plant establishment and growth; (2) Well-drained alluvial soils primarily of non-marine sedimentary origin, such as Temecula or sandy arkose soils; soils of the Cajalco- Temescal-Las Posas soil association formed on gabbro (igneous) or latite (volcanic) bedrock; metasedimentary substrates associated with springs or seeps; and heavy adobe/gabbro-type soils derived from metavolcanic geology (Mesozoic basic intrusive rock) that provide the appropriate nutrients and space for growth and reproduction; and (3) Scrub (chaparral, coastal sage, alluvial, riparian) and woodland (oak, riparian) vegetation communities between 900 and 3,000 ft (275 and 915 m) in elevation that provide the appropriate cover for growth and reproduction (http://www.gpo.gov/fdsys/pkg/FR-2007-02-06/pdf/07-472.pdf).

Name:Brodiaea filifolia

Region/Forest/Acres:

Fire Retardant DEIS 321 Appendices

PCE’s: (1) Appropriate soil series andassociated vegetation at suitable elevations of either: (A) Clay soil series of various origins (e.g., Alo, Altamont, Auld, Diablo), clay lenses found as unmapped inclusions in other soils series, or within loamy soils underlain by a clay subsoil (e.g., Fallbrook, Huerhuero, Las Flores) that generally occur on mesas and gentle to moderate slopes, or in association with vernal pools, between the elevations of 100 ft (30 m) and 2,500 ft (765 m) and support open native or annual grassland communities, within open coastal sage scrub or coastal sage scrub-chaparral communities; or (B) Silty loam soil series underlain by a clay subsoil or caliche that are generally poorly drained, moderately to strongly alkaline, granitic in origin (e.g., Domino, Grangeville, Waukena, Willows), that generally occur in low lying areas and floodplains, often in association with vernal pool or playa complexes, between the elevations of 600 ft (180 m) and 1,800 ft (550 m) and support native, annual, or alkali grassland or scrub communities; or (C) Clay loam soil series (e.g., Murrieta) underlain by heavy clay loams or clays derived from olivine basalt lava flows that generally occur on mesas and gentle to moderate slopes between the elevations of 1,700 ft (520 m) and 2,500 ft (765 m) and support native or annual grassland or oak woodland savannah communities associated with basalt vernal pools; or (D) Sandy loam soils derived from basalt and granodiorite parent materials, deposits of gravel, cobble, and boulders, or hydrologically fractured weathered granite in intermittent streams and seeps that support open riparian and freshwater marsh communities associated with intermittent drainages, floodplains, and seeps generally between 1,800 ft (550 m) and 2,500 ft (765 m). (2)Areas with an intact surface and subsurface structure not permanently altered by anthropogenic land use activities (e.g., deep, repetitive disking; grading). These features as well as associated physical processes (e.g., full sunlight exposure) are essential to maintain those substrate and vegetation types where Brodiaea filifolia is found and to support pollinator assemblages necessary to facilitate gene flow within and among populations of B. filifolia http://www.gpo.gov/fdsys/pkg/FR-2005-12-13/pdf/05-23693.pdf).

Name:Castilleja cinerea

Region/Forest/Acres:

PCE’s: (1) Pebble plains in dry meadow-like openings, or non-pebble plain dry meadow margin areas, within upper montane coniferous forest, pinyon juniper woodlands, or Great Basin sagebrush in the San Bernardino Mountains of San Bernardino County, California; at elevations between 5,900 to 9,800 ft (1,830 to 2,990 m) that provide space for individual and population growth, reproduction and dispersal;(2) Seasonally wet clay, or sandy clay soils, generally containing quartzite pebbles, subject to natural hydrological processes that include water hydrating the soil and freezing in winter and drying in summer causing lifting and churning of included pebbles, or seasonally wet silt or saline clay soils in non-pebble plain dry meadow margin areas that provide space for individual and population growth, reproduction and dispersal, adequate water, air, minerals, and other nutritional or physiological requirements to the species; and (3) The presence of one or more of its known host species, such as Eriogonum kennedyi var. austromontanum, E. kennedyi. var. kennedyi, and E. wrightii var. subscaposumon in pebble plain habitat and species such as Artemisia tridentata, A. nova, and E. wrightii var. subscaposumon in pebble plain and non-pebble plain meadow margin habitat that provide some of the physiological requirements for this species (http://www.gpo.gov/fdsys/pkg/FR-2007-12-26/pdf/07-6137.pdf)

Name:Ceanothus ophiochilus

Region/Forest/Acres:

PCE’s: (1) Flat to gently sloping north to northeast facing ridge tops with slopes in the range of 0 to 40 percent slope that provide the appropriate solar exposure for seedling establishment and growth; (2) Soils formed from metavolcanic and ultra-basic parent materials and deeply weathered gabbro or pyroxeniterich outcrops that provide

Fire Retardant DEIS 322 Appendices

nutrients and space for growth and reproduction. Specifically in the areas that Ceanothus ophiochilus is found, the soils are: (a) Ramona, Cienaba, Las Posas, andVista series in the Agua Tibia Wilderness; and (b) Cajalco series in the vicinity of Vail Lake; and (3) Chamise chaparral or mixed chamise-ceanothus-arctostaphylos chaparral at elevations of 2,000 ft to 3,000 ft (610 m to 914 m) that provide the appropriate canopy cover and elevation requirements for growth and reproduction (http://www.gpo.gov/fdsys/pkg/FR-2007-09-27/pdf/07-4723.pdf).

Name: Chlorogalum purpureum var. reductum

Region/Forest/Acres:

PCE’s: (1) Well-drained, red clay soils with a large component of gravel and pebbles on the upper soil surface; and, (2) Plant communities in functioning ecosystems that support associated plant and animal species (e.g., pollinators, predator-prey species, etc.), including grassland (most similar to the California annual grassland series in Sawyer and Keeler-Wolf (1995) or the pine bluegrass grassland, non-native grassland and wildflower field descriptions in Holland (1986)), blue oak woodland or oak savannahs (Holland 1986), oak woodland, and open areas within shrubland communities (most similar to the Chamise series in Sawyer and Keeler- Wolf (1995), although percent cover of chamise at known Chlorogalum purpureum var. reductum areas is unknown). Within these vegetation communities C. p. var. reductum appears where there is little cover of other species which compete for resources available for growth and reproduction (http://www.gpo.gov/fdsys/pkg/FR-2002-10-24/pdf/02-26768.pdf).

Name:Erigeron parishii

Region/Forest/Acres:

PCE’s: (1) Soils derived primarily from upstream or upslope limestone, dolomite, or quartz monzonite parent materials that occur on dry, rocky hillsides, shallow drainages, or outwash plains at elevations between 1,171 and 1,950 m (3,842 and 6,400 ft); (2) Soils with intact, natural surfaces that have not been substantially altered by land use activities (e.g., graded, excavated, re-contoured, or otherwise altered by ground-disturbing equipment); and (3) Associated plant communities that have areas with an open canopy cover (http://www.gpo.gov/fdsys/pkg/FR-2002-12-24/pdf/02-31631.pdf).

Name: Eriogonum kennedyi austromontanum

Region/Forest/Acres:

PCE’s: (1) Pebble plains in dry meadow-like openings within upper montaneconiferous forest, pinyon-juniper woodlands, or Great Basin sagebrush in the San Bernardino Mountains of San Bernardino County, California; at elevations between 5,900 to 9,800 ft (1,830 to 2,990 m) that provide space for individual and population growth, reproduction and dispersal; and (2) Seasonally wet clay, or sandy clay soils, generally containing quartzite pebbles, subject to natural hydrological processes that include water hydrating the soil and freezing in winter and drying in summer causing lifting and churning of included pebbles, that provide space for individual and population growth, reproduction and dispersal, adequate water, air, minerals, and other nutritional or physiological requirements to the species (http://www.gpo.gov/fdsys/pkg/FR-2007-12-26/pdf/07-6137.pdf)

Name:Eriogonum ovalifolium var. vineum

Region/Forest/Acres:

Fire Retardant DEIS 323 Appendices

PCE’s: (1) Soils derived primarily from the upper and middle members of the Bird Spring Formation and Bonanza King Formation parent materials that occur on hillsides at elevations between 1,400 and 2,400 m (4,600 and 7,900 ft); (2) Soils with intact, natural surfaces that have not been substantially altered by land use activities (e.g., graded, excavated, re-contoured, or otherwise altered by ground-disturbing equipment); and (3) Associated plant communities that have areas with an open canopy cover (generally less than 15 percent cover) and little accumulation of organic material (e.g., leaf litter) on the surface of the soil (http://www.gpo.gov/fdsys/pkg/FR-2002-12-24/pdf/02-31631.pdf).

Name:Hudsonia montana

Region/Forest/Acres: R8, Pisgah (NC), 22 acres

PCE’s: No CPE's identified - any activity which would result in increased trampling or disturbance of fragileareas where species occur would adversely modify Chab. 45 FR 204 - 69362; http://www.gpo.gov/fdsys/pkg/FR-1998-10-13/pdf/98-26861.pdf

Name:Lesquerella kingii ssp. bernardina

Region/Forest/Acres:

PCE’s: (1) Soils derived primarily from Bonanza King Formation and Undivided Cambrian parent materials that occur on hillsides or on large rock outcrops at elevations between 2,098 and 2,700 m (6,883 and 8,800 ft); (2) Soils with intact, natural surfaces that have not been substantially altered by land use activities (e.g., graded, excavated, re-contoured, or otherwise altered by ground-disturbing equipment); and (3) Associated plant communities that have areas with an open canopy cover and little accumulation of organic material (e.g., leaf litter) on the surface of the soil (http://www.gpo.gov/fdsys/pkg/FR-2002-12-24/pdf/02-31631.pdf).

Name:Lilaeopsis schaffneriana ssp. Recurva

Region/Forest/Acres: R3, Coronado, acres unknown

PCE’s: Critical habitat includes the stream courses identified in the legal descriptions below, and includes adjacent areas out to the beginning of upland vegetation. Within these areas, the primary constituent elements include, but are not limited to, the habitat components which provide—(1) Sufficient perennial base flows to provide a permanently or nearly permanently wetted substrate for growth and reproduction of Lilaeopsis; (2) A stream channel that is relatively stable, but subject to periodic flooding that provides for rejuvenation of the riparian plant community and produces open microsites for Lilaeopsis expansion; (3) A riparian plant community that is relatively stable over time and in which nonnative species do not exist or are at a density that has little or no adverse effect on resources available for Lilaeopsis growth and reproduction; and (4) In streams and rivers, refugial sites in each watershed and in each reach, including but not limited to springs or backwaters of mainstem rivers, that allow each population to survive catastrophic floods and recolonize larger areas. (http://www.gpo.gov/fdsys/pkg/CFR-2006-title50-vol4/pdf/CFR-2006-title50-vol4-sec17-96.pdf)

Name:Lomatium cookii

Region/Forest/Acres: R6, Rogue River Siskiyou, 40 acres

Fire Retardant DEIS 324 Appendices

PCE’s: (1) In the Rogue River Valley: (A) Vernal pools and ephemeral wetlands and depths and the adjacent upland margins of these depressions that hold water for a sufficient length of time to sustain Lomatium cookie germination, growth, and reproduction. These vernal pools or ephemeral wetlands support native plant populations and are seasonally inundated during wet years but do not necessarily fill with water every year due to natural variability in rainfall. Areas of sufficient size and quality are likely to have the following characteristics: • Elevations from 372 to 411 m (1,220 to 1,350 ft); • Associated dominant native plants including, but not limited to: Alopecurus saccatus, Achnatherum lemmonii, Deschampsia danthonioides, Eryngium petiolatum, Lasthenia californica, Myosurus minimus, Navarretia leucocephala ssp. leucocephala, Phlox gracilis, Plagiobothrys bracteatus, Trifolium depauperatum, and Triteleia hyacinthina; and • a minimum area of 8 ha (20 ac) to provide intact hydrology and protection from development and weed sources. (B) The hydrologically and ecologically functional system of interconnected pools or ephemeral wetlands or depressions within a matrix of surrounding uplands that together form vernal pool complexes within the greater watershed. The associated features may include the pool basin and ephemeral wetlands; an intact hardpan subsoil underlying the surface soils up to 0.75 m (2.5 ft) in depth; and surrounding uplands, including mound topography and other geographic and edaphic features that support systems of hydrologically interconnected pools and other ephemeral wetlands (which may vary in extent depending on sitespecific characteristics of pool size and depth, soil type, and hardpan depth). (C) Silt, loam, and clay soilsthat are of ultramafic and nonultramafic alluvial origin, with a 0 to 3 percent slope, classified as Agate–Winlo orProvig– Agate soils. (D) No or negligible presence of competitive, nonnative invasive plant species. Negligible is defined for the purpose of this rulemaking as a minimal level of nonnative plant species that will still allow Lomatium cookii to continue to survive and recover.

(2) In the Illinois River Valley: (A) Wet meadows in oak and pine forests, sloped mixed-conifer openings, and shrubby plant communities that are seasonally inundated and support native plant populations. Areas of sufficient size and quality are likely to have the following characteristics: • Elevations from 383 to 488 m (1,256 to 1,600 ft); • Associated dominant native plants including, but not limited to: Achnatherum lemmonii, Arbutus menziesii, Arctostaphylos viscida, Camassia spp., Ceanothus cuneatus, Danthonia californica, Deschampsia cespitosa, Festuca roemeri var. klamathensis, Poa secunda, Ranunculus occidentalis, and Limnanthes gracilis var. gracilis; • Occurrence primarily in bottomland Quercus garryana–Quercus kelloggii–Pinus ponderosa (Oregon white oak–California black oak– ponderosa pine) forest openings along seasonal creeks; and • A minimum area of 8 ha (20 ac) to provide intact hydrology and protection from development and weed sources. (B) The hydrologically and ecologically functional system of streams, slopes, and wooded systems that surround and maintain seasonally wet alluvial meadows underlain by relatively undisturbed ultramafic soils within the greater watershed. (C) Silt, loam, andclay soils that are of ultramafic and nonultramafic alluvial origin, with a 0 to 40 percent slope, classified asAbegg gravelly loam,Brockman clay loam, Copsey clay, Cornutt–Dubakel complex, Dumps, Eightlar extremely stony clay, Evan loam, Foehlin gravelly loam, Josephine gravelly loam, Kerby loam, Newberg fine sandy loam, Pearsoll–Rock outcrop complex, Pollard loam, Riverwash, Speaker–Josephine gravelly loam, Takilma cobbly loam, or Takilma Variant extremely cobbly loam. (D) No or negligible presence of competitive, nonnative invasive plant species. Negligible is defined for the purpose of this rulemaking as a minimal level of nonnative plant speciesthat will still allow Lomatium cookii to continue to survive and recover. The need for space for individual and population growth, germination, seed dispersal, and reproduction is provided by PCEs 1(A), 2(A), 1(D), and 2(D); the need for soil moisture for growth, germination, reproduction, and seed dispersal is provided by PCEs 1(B) and 2(B)(but not necessarily every year); the need for other nutritional or physiological requirements for the species is provided by PCE 1(C) and 2(C); the need for habitat free from disturbance that allows for sufficient reproduction and survival opportunities is provided by PCEs 1(A), 2(A), 1(D), and 2(D). All of the above described PCEs do not have to occur simultaneously within a unit for the unit to constitute critical habitat for Lomatium cookii (http://www.gpo.gov/fdsys/pkg/FR-2010-07-21/pdf/2010-17324.pdf).

Fire Retardant DEIS 325 Appendices

Name:Orcuttia tenuis

Region/Forest/Acres: R5, Lassen, 21,885 acres

PCE’s: Topographic features characterized by isolated mount and intermound complexes, vernal pool habitats, that promote germination, flowering and seed production of predominantly annual native wetland species and typically exclude both native and nonnative upland plant species in all but the driest years. http://www.gpo.gov/fdsys/pkg/FR-2006-02-10/pdf/06-1080.pdf 71FR 28 - 7279

Name:Acanthoscyphus parishii var. goodmaniana (Oxytheca)

Region/Forest/Acres: R5, San Bernardino, 2590 acres

PCE’s: (1) Soils derived primarily from upslope limestone, a mixture of limestone and dolomite, or limestone talus substrates with parent materials that include Bird Spring Formation, Bonanza King Formation, middle and lower members of the Monte Cristo Limestone, and the Crystal Pass member of the Sultan Limestone Formation at elevations between 1,440 and 2,372 m (4,724 and 7,782 ft); (2) Soils with intact, natural surfaces that have not been substantially altered by land use activities (e.g., graded, excavated, re-contoured, or otherwise altered by ground-disturbing equipment); and (3) Associated plant communities that have areas with a moderately open canopy cover (generally between 25 and 53 percent (Neel 2000)). (http://www.gpo.gov/fdsys/pkg/FR-2002-12-24/pdf/02-31631.pdf).

Name:Poa atropurpurea

Region/Forest/Acres: R5, Cleveland, San Bernardino, 115, and 804 acres respectively

PCE’s: (1) Wet meadows subject to flooding during wet years in the San Bernardino Mountains in San Bernardino County at elevations of 6,700 to 8,100 feet (2,000 to 2,469 meters), and in the Laguna and Palomar Mountains of San Diego County at elevations of 6,000 to 7,500 feet (1,800 to 2,300 meters), that provide space for individual and population growth, reproduction, and dispersal; and (2) Well-drained, loamy alluvial to sandy loam soils occurring in the wet meadow system, with a 0 to 16 percent slope, to provide water, air, minerals, and other nutritional or physiological requirements to the species ( http://www.gpo.gov/fdsys/pkg/FR-2008-08-14/pdf/E8-17522.pdf)

Name:Senecio franciscanus

Region/Forest/Acres: R3, Coconino, 720 acres

PCE’s:: loose cinder talus slopes of the alpine tundra system of the San Francisco Peaks and absence of disturbance and damage from hikers (http://www.gpo.gov/fdsys/pkg/CFR-1999-title50-vol1/pdf/CFR-1999-title50-vol1-sec17-96.pdf).

Name:Sidalcea oregano var. calva

Region/Forest/Acres: R6, Wenatchee, 2280 acres

PCE’s: surface water or saturated upper soil profiles; a wetland plant community dominated by native grasses and forbs,

Fire Retardant DEIS 326 Appendices

and generally free of woody shrubs and conifers that would produce shade and competition for Sidalcea oregana var.calva; seeps and springs on fine textured soils (clay loams and silt loams), which contribute to the maintenance of hydrologic processes necessary to support meadows which remain moist into the early summer; and elevations of 488–1,000 m (1,600– 3,300 ft) http://www.gpo.gov/fdsys/pkg/FR-2001-09-06/pdf/01-22341.pdf

Name:Taraxacum californicum

Region/Forest/Acres: R5, San Bernardino, 1344 acres

PCE’s: (1) Wet meadows subject to flooding during wet years and forest openings with seeps, springs, orcreeks in the San Bernardino Mountains in San Bernardino County located at elevations of 6,700 to 9,000 feet (2,000 to 2,800 meters), that provide space for individual and population growth, reproduction, and dispersal; and (2) Well-drained, loamy alluvial to sandy loam soils occurring in the wet meadow system or forest openings with seeps, springs, or creeks, with a 0 to 46 percent slope, to provide water, air, minerals, and other nutritional or physiological requirements to the species http://www.gpo.gov/fdsys/pkg/FR-2008-08-14/pdf/E8-17522.pdf

Name:Tuctoria greenei

Region/Forest/Acres: R5. Lassen, 1551 acres

PCE’s: Topographic features characterized by isolated mount and intermound complexes, vernal pool habitats, that promote germination, flowering and seed production of predominantly annual native wetland species and typically exclude both native and nonnative upland plant species in all but the driest years (http://www.gpo.gov/fdsys/pkg/FR-2005-08-11/pdf/05-15569.pdf 70FR 154 – 46958). Federal Candidate Species and Forest Service Sensitive Plant Species

Table 7. Candidate and Forest Service Sensitive Plant Species (7-Candidates; 2,719 FS Sensitive Plant Species):

Please refer to Botany Report and Biological Evaluation for a complete list by Forest Service Region. Literature Cited

National Invasive Species Council. 2001. Meeting the Invasive Species Challenge: National Invasive Species Management Plan. 80 pp.

USDA Forest Service. 1995. Title 2600 – Wildlife, Fish, and Sensitive Plant Habitat Management, Amendment No. 2600-95-5, effective May 4, 1995. Forest Service Manual 2650

USDA Forest Service. 2004. National Strategy and Implementation Plan for Invasive Species Management. USDA Forest Service, FS-805. 24 p.

USDA Forest Service. 2004. USDA Forest Service Strategic Plan for Fiscal Years 2004-08. USDA Forest Service, FS 810. 40 p.

Fire Retardant DEIS 327 Appendices

USDA Forest Service. 2007. USDA Forest Service Strategic Plan FY 2007-2012. USDA Forest Service, FS-880. 38 p.

USDI Fish and Wildlife Service. 2008. Final Biological and Conference Opinion on the USDA Forest Service's Proposed Guidelines for Aerial Application of Fire Retardant and Foams in Aquatic Environments

Fire Retardant DEIS 328 Appendices

Appendix H – Fire Retardant Soil Risk Rating Indicators

Table H-1. Soil Risk Rating Indicators and Levels

Soil Risk Rating

Soil Property Low Moderate High

Soil Texture Clay, Sandy Clay, Silty Clay, Sandy clay loam, loam, silt Sandy loam, loamy sand, sand Silty Clay Loam, Clay Loam loam, silt

Organic Matter Content 3.7% or > 3.6-1.5% 1.4 % or <

(Labat Environmental 2007)

Soil pH 6.0-7.0 5.0-6.0 or 7.0-8.0 >5 or <8

K- Factor (erodibility) .05-0.24 0.25-0.4 0.4+

(Labat Environmental 2007)

Fire Regime Fire-independent Fire-sensitive Fire-dependent

( Bailey 2010)

Time of Retardant Application Spring Summer Late-fall

Soil Condition Rating (Potyondy and Functioning Properly Functioning at Risk Impaired Geier 2010)

Note: The above table can have several combinations of low, moderate, or high risk. It is important to determine which indicators are most appropriate at the forest or project scale. Assumptions:

Soil texture affects the ability of the soil to adsorb phosphorus and nitrogen anions and cations. Soils with high clay content attract phosphorus.

Organic matter content: soils with high organic matter also attract and retain phosphorus and nitrogen, reducing leaching and movement of these fertilizers.

Soil pH: Phosphorus in the soil is not available to most plants at low or very high soil pH.

Soil pH: Acidifying effects of fertilizers can reduce soil pH.

K-factor: nitrogen and phosphorus can move on soil particles through erosion. Soils with a high k-factor also have a corresponding greater erodibility.

Fire Retardant DEIS 329 Appendices

Fire regime: The Nature Conservancy identified three broad fire regime types. In their analysis they identified fire-loving invasive alien plants moving into areas of fire sensitive and fire dependent ecosystems (Bailey2010).

Time of retardant application: fire retardant containing phosphorus and nitrogen may have short term affects depending on temperatures and microbial activity (Vance 2001).

Soil condition rating is determined on a watershed scale for three attributes, soil productivity, soil erosion, and soil contamination. If any of these attributes were impaired at the watershed scale the fate of fire retardant applied could adversely affect soil, vegetation, and water resources. Consequences of Fire Retardant Application Based on Risk

Low Risk Soils: These soils generally are well–developed soils with both a high clay and organic matter content. The risk of nutrient movement from these soils and leaching to streams is low, the soils are not inherently erodible, and retardant placed in these locations would most likely fall on denser vegetation canopy or a litter layer. The consequence of applying retardant in these areas would have limited fertilizing effects due to the normally high productive soils, increased vegetative response would also be low, and adverse affects to water quality would be unlikely.

Moderate Risk Soils: The soils in the moderate risk category would also be productive. Soil texture classes show lower clay content but may have higher allophone content typical of volcanic soils with andic soil properties and would be effective in adsorbing phosphorus and nitrogen. Inherent soil erodibility is moderate and soil organic matter would also help to adsorb nutrients. Soil cover in the form of both plant and litter would be expected to be uniform. The consequence of applying retardant could show slight increase in fertilizing effects, increased vegetative response, and minor impacts to water quality.

High Risk Soils: The soils in this category are coarser textured with a lower organic matter content. Soils with these physical properties are prone to leaching and erosion. Soil cover in the form of both plant and litter would be expected to be patchy and soils may be more xeric in moisture regime. Fire retardant applied on these soils may show a greater fertilizing effect response to what otherwise is a low nutrient soil. Vegetative response is likely to increase and the change in vegetative community composition is likely since other plants may better utilize the increased nitrogen and phosphorus. Movement of fire retardant into the water could occur from leaching of nitrates. The amount of nitrogen and phosphorus entering waterbodies would depend on the organic matter content, soil cover, and proximity to the stream.

Nutrient movement into waterbodies from fire retardant application can occur from leaching of nitrates in coarse textured soils, or from erosion of fine soil particles. Misapplication of fire retardant into waterbodies andbuffers poses the highest likelihood of nutrient movement. Annual reporting of misapplications in waterways helps to track and document specific locations and environmental effects of the fire chemicals. Current guidelines includea 300-foot buffer around waterbodies, which helps to reduce potential movement of nitrogen or phosphorus into the waterbody. Literature Cited – Appendix H – Soils

Bailey, Robert G. 2010. Fire regimes and ecoregions. Chapter 2, Cumulative watershed effects of fuel management in the western United States. General Technical Report, RMRS-GTR-231. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 18 p.

Fire Retardant DEIS 330 Appendices

Labat Environmental. 2007. Ecological Risk Assessment: Wildland Fire-fighting Chemicals, prepared for Missoula Technology and Development Center, USDA Forest Service, Missoula, MT. 69 p.

Potyondy, John P. and Theodore W. Geier. 2010. Forest Service Watershed Condition Classification Technical Guide. USDA Forest Service. 72 p.

Vance, Carroll P. 2001. Symbiotic Nitrogen Fixation and Phosphorus Acquisition. Plant Nutrition in a World of Declining Renewable Resources. Plant Physiology, 127:390-397

Fire Retardant DEIS 331 Appendices

Appendix I – Wildlife

Table I-1. List of USFWS ESA Listed Threatened, Endangered, and Proposed Species Included in this Analysis.

Federal

Status Effects R10R9R8R6R5R4R3R2R1 Common Name NatureServe Global Scientific Name Determination

MAMMALS

21 4 6 9 Gray Wolf T Canis lupus NLAA

9 Gray Wolf WGL Population T Canis lupus NLAA

3 Gray Wolf, Southwestern pop. Mex. E Canis lupus baileyi NE

8 Red Wolf E Canis rufus NE

8 Ozark Big-eared Bat E Corynorhinus townsendii ingens NE

98 Virginia Big-eared Bat E Corynorhinus townsendii virginianus NE

4 Utah Prairie Dog T Cynomys parvidens NLAA

10 Cook Inlet beluga whale E Delphinapterus leucas NE

5 Giant Kangaroo Rat E Dipodomys ingens NLAA

5 San Bernardino Kangaroo Rat E Dipodomys merriami parvus NLAA

5 Fresno Kangaroo Rat E Dipodomys nitratoides exilis NE

5 Tipton Kangaroo Rat E Dipodomys nitratoides nitratoides NLAA

5 Stephen's Kangaroo Rat E Dipodomys stephensi NLAA

5 Southern Sea Otter T Enhydra lutris nereis NE

5 10 Steller's Sea Lion (eastern) T Eumetopias jubatus NE

10 Steller's Sea Lion (western) E Eumetopias jubatus NE

8 Carolina Northern Flying Squirrel E Glaucomys sabrinus coloratus NLAA

3 Lesser Long-nosed Bat E Leptonycteris curasoae yerbabuenae NE

3 Mexican Long-nosed Bat E Leptonycteris nivalis NE

21 4 6 9 Canada Lynx T Lynx canadensis NLAA

10 Humpback whale E Megaptera novaeangliae NE

2 4 Black-footed Ferret E Mustela nigripes NLAA

98 Gray Bat E Myotis grisescens NE

98 Indiana Bat E Myotis sodalis NE

5 Bighorn Sheep (Peninsular) E Ovis canadensis pop 2 NLAA

Fire Retardant DEIS 332 Appendices

Federal

Status Effects R10R9R8R6R5R4R3R2R1 Common Name NatureServe Global Scientific Name Determination

54 Bighorn Sheep (Sierra Nevada) E Ovis canadensis sierrae NLAA

3 Jaguar E Panthera onca NLAA

8 Florida Panther E Puma concolor coryi NLAA

8 Eastern Cougar E Puma concolor couguar NLAA

1 6 Woodland Caribou E Rangifer tarandus caribou NLAA

4 Northern Idaho Ground Squirrel T Spermophilus brunneus brunneus NLAA

3 Mount Graham Red Squirrel E Tamiasciurus hudsonicus grahamensis NLAA

8 Florida Manatee E Trichechus manatus NE

8 Louisiana Black Bear T Ursus americanus luteolus NLAA

21 4 6 Grizzly Bear (Lower 48) T Ursus arctos horribilis NLAA

5 San Joaquin Kit Fox E Vulpes macrotis mutica NLAA

2 Preble's Meadow Jumping Mouse T Zapus hudsonius preblei NE

BIRDS

8 Puerto Rican Sharp-Shinned Hawk E Accipiter striatus NE

8 Puerto Rican Parrot E Amazona vittata NE

8 Florida Scrub Jay T Aphelocoma coerulescens NLAA

65 Marbled murrelet T Brachyramphus marmoratus NLAA

8 Puerto Rican Broad-winged Hawk E Buteo platypterus brunnescens NE

65 Western Snowy Plover T Charadrius alexandrinus nivosus NE

2 98 Piping Plover T/E Charadrius melodus NE

Mountain Plover PT Charadrius montanus NE

8 White-necked Crow E Corvus leucognaphalus NE

9 Kirtland's Warbler E Dendroica kirtlandii NLAA

5432 Southwestern Willow Flycatcher E Empidonax traillii extimus NLAA

3 Northern Aplomado Falcon E Falco femoralis septentrionalis NLAA

2 4 Whooping Crane E Grus americana NE

8 Mississippi Sandhill Crane E Grus canadensis pulla NE

3 5 California Condor E Gymnogyps californianus NLAA

Fire Retardant DEIS 333 Appendices

Federal

Status Effects R10R9R8R6R5R4R3R2R1 Common Name NatureServe Global Scientific Name Determination

3 Bald Eagle (Sonoran DPS) T Haliaeetus leucocephalus NLAA

8 Wood Stork E Mycteria americana NE

65 Brown Pelican E Pelecanus occidentalis californicus NE

8 Red-cockaded Woodpecker E Picoides borealis NLAA

5 Coastal California Gnatcatcher T Polioptila californica californica NLAA

3 Yuma Clapper Rail E Rallus longirostris yumanensis NE

32 98 Least Tern E Sterna antillarum NE

5 California Least Tern E Sterna antillarum browni NE

65 Northern Spotted Owl T Strix occidentalis caurina NLAA

432 Mexican Spotted Owl T Strix occidentalis lucida NLAA

8 Bachman's Warbler E Vermivora bachmanii NE

8 Black-capped Vireo E Vireo atricapilla NE

5 Least Bell's Vireo E Vireo bellii pusillus NLAA

AMPHIBIANS

California tiger salamander, central 5 population T Ambystoma californiense LAA

8 Frosted Flatwoods Salamander T Ambystoma cingulatum LAA

3 Sonoran Tiger Salamander E Ambystoma tigrinum stebbinsi LAA

2 Wyoming Toad E Bufo baxteri NE

5 Arroyo Southwestern Toad E Bufo californicus LAA

8 Houston Toad E Bufo houstonensis NE

9 Ozark Hellbender PE Cryptobranchus alleganiensis bishopi NE

8 Red hills salamander T Phaeognathus hubrichti NE

9 Cheat Mountain Salamander T Plethodon nettingi NE

8 Shenandoah Salamander E Plethodon shenandoah NE

5 California Red-legged Frog T Rana aurora draytonii LAA

8 Mississippi Gopher Frog E Rana capito servosa NE

3 Chiricahua leopard frog T Rana chiricahuensis LAA

5 Mt. Yellow-legged frog (So. CA DPS) E Rana muscosa pop. 1 LAA

Fire Retardant DEIS 334 Appendices

Federal

Status Effects R10R9R8R6R5R4R3R2R1 Common Name NatureServe Global Scientific Name Determination

REPTILES

3 New Mexico Ridgenose Rattlesnake T Crotalus willardi obscurus NLAA

8 Eastern Indigo Snake T Drymarchon corais couperi NE

8 Puerto Rican Boa E Epicrates inornatus NE

5 Blunt-nosed Leopard Lizard E Gambelia sila NLAA

54 Desert Tortoise (Sonoran pop.) T Gopherus agassizii pop 2 NE

8 Gopher Tortoise T Gopherus polyphemus NE

8 Sand Skink T Neoseps reynoldsi NE

8 Flattened Musk Turtle T Sternotherus depressus NE

5 Giant Garter Snake T Thamnophis gigas NE

INVERTEBRATES

8 Spruce-fir Moss Spider E Microhexura montivaga NLAA

2 Uncompahgre Fritillary Butterfly E Boloria improba acrocnema NE

5 Valley Elderberry Longhorn Beetle T Desmocerus californicus dimorphus NLAA

5 Smith's Blue Butterfly E Euphilotes enoptes smithi NE

5 Quino Checkerspot Butterfly E Euphydryas editha quino LAA

5 Kern Primrose Sphinx Moth T Euproserpinus euterpe NE

2 Pawnee Montane Skipper T Hesperia leonardus montana LAA

9 Karner Blue Butterfly E Lycaeides melissa samuelis NE

8 Mitchell's Satyr E Neonympha mitchelli mitchelli NE

2 98 American Burying Beetle E Nicrophorus americanus NLAA

5 Carson Wandering Skipper E Pseudocopaeodes eunus obscurus LAA

5 Laguna Mountains Skipper E Pyrgus ruralis lagunae LAA

9 Hine's Emerald Dragonfly E Somatochlora hineana NE

6 Oregon Silverspot Butterfly T Speyeria zerene hippolyta NE

9 Tumbling Creek Cave Snail E Antrobia culveri NE

8 Lacy Elimia T Elimia crenatella NE

8 Magazine Mountain Shagreen T Inflectarius magazinensis LAA

Fire Retardant DEIS 335 Appendices

Federal

Status Effects R10R9R8R6R5R4R3R2R1 Common Name NatureServe Global Scientific Name Determination

8 Round rocksnail T Leptoxis ampla NE

8 Painted rocksnail T Leptoxis taeniata NE

8 Flat pebblesnail E Lepyrium showalteri NE

8 Cylindrical lioplax E Lioplax cyclostomaformis NE

8 Noonday Globe T Patera clarki nantahala LAA

3 Alamosa Springsnail E Tryonia alamosae LAA

8 Tulotoma Snail E Tulotoma magnifica NE

Effects Determination Process

The following section is a brief discussion of the effects of both the action alternatives on each of the various Groups (mammals, birds, reptiles, etc) and Subgroups (mammals – rodents, bat, etc) of animals. All Puerto Rico species:

All species which occur in the territory of Puerto Rico on the El Yunque NF will not be affected by the use of aerial application of fire retardant since the use of fire retardant does not occur on the island of Puerto Rico; thereforea No Effect/No Impact determination has been made for these species and no further discussion or analysis will occur for these species since their habitat or populations will not be affected, either directly, indirectly, or cumulatively by the use of aerial application of fire retardant. Group Mammals:

Marine Mammals

The use of aerial application of fire retardant will not occur near or over marine environments, thus thereis No Effect/No Impact determination for all of these species. Therefore, no further discussion or analysis will occur for these species since their habitat or populations will not be affected, either directly, indirectly, or cumulatively by the use of aerial application of fire retardant.

Rodents

These species consists of mice, vole, rats, prairie dogs, and squirrels, may be found in almost all of the terrestrial habitat types and in almost every Eco-Region. Most of the small rodent species in this subgroup are fossorial in nature, spending the majority of their lives in burrows or underground dens.

Fire Retardant DEIS 336 Appendices

Although found through a variety of habitats and across the continent, most of the T&E small mammal species have very limited range, distribution, and ability to avoid aerial application of fire retardant. These species have a higher probability of ingesting fire retardant chemicals since they primarily are herbivores. Impacts may be reduced through avoidance mapping for some species (refer to the Biological Evaluation and Assessment for Wildlife Species).

Bats: The biggest threat to cave roosting bats is disturbance during periods when bats are hibernating or roosting. Most fire activity occurs in the warmer months outside the hibernating period (winter) for bats, thusmostfire fighting activities would not occur inside of caves where bats may roost; an aircraft flying over a roostsideisnot likely to cause disturbance; human disturbance from people entering caves is what affects roosting and hibernating bats. In addition, effects to species from the use of aerial application of fire retardant are not expected since these species are highly mobile and able to avoid areas with wildland fires; they also occur in areas with low to moderate potential for the use of aerial retardant.

All species of bats listed as T&E use caves or mines for roosting and hibernacula. These species are located in Forest Service Regions 8 and 9 which have little or low potential use for aerial application of fire retardant; and any possible use of aerial application of fire retardant is not expected to have effects on caves serving as batroosts and hibernacula: avoidance mapping of occupied roost and hibernacula sites is possible if determined necessary by those National Forests with these known sites.

In addition, effects to species from the use of aerial application of fire retardant; these species are highly mobile and able to avoid areas with wildland fires. All of the listed T&E species occur in areas with very lowor potential for the use of aerial retardant specifically Regions 8 & 9. Due to these factors, no direct or indirect impacts (to prey insects species) are expected to these species with the very little potential use of aerial application of fire retardant in the areas where these species occur, and given that some bats species may forage several miles from their roost sites and prey may also travel in from outside the retardant use area. Further mitigation by avoidance mapping around cave openings may reduce impacts, but is not necessarily needed unless determined to be beneficial by the local forest unit.

Carnivores and Ominvores: Mustelids/Canids/Felines/Bears

All listed carnivore species are highly mobile species that are able to escape from areas with fire activities. The likelihood of a direct application from aerial application is extremely low due to the high rate of mobility and ability to escape the wildlife fire area; thus expecting to avoid direct drops of retardant. However, low flying aircraftmay cause disturbance for a very short term; thus having a small negative effect.

Indirect effects are not expected since these carnivores would likely travel outside of the burned areas to forage on prey species in adjacent unburned areas. An individual would need to consume several contaminated prey items in a relatively short period of time in order to be affected, thus the ingestion of retardant chemicals through the prey burden (Labat Environmental 2011 coyote – carnivore representative) is not expected to occur.

Ungulates: Sheep, Deer and Caribou

All are highly mobile species that are able to escape from areas with fire activities. The direct impact from aerial drops of retardant on individuals is not expected; however impacts caused from a short term disturbance of the individuals due to low-flying aircraft is expected to occur. The likelihood that the bighorn sheep would beinan area where a fire retardant drop would occur is low or none due to they typically inhabit steep, open terrain,where fire retardant would be of little or nouse.

Fire Retardant DEIS 337 Appendices

Indirect effects are not expected to occur, since these species are likely to avoid feeding on plants with fire retardant present; and the effect of retardant chemicals on ruminants is related to length and quantity of exposure. Group Reptiles: Snakes, Lizards, Tortoises

Mobility or ability to avoid a wildland fire for reptilian species is limited due to their small size and smallhome range. These species tend to avoid wildland fires by retreating into their burrows or under rocks, etc. Someare associated with waterways and moist areas, such as garter snakes, eastern indigo snake and most turtles. These semi-aquatic species are not expected to be directly affects due to the protection guidelines in place for waterways.

Direct effects of the fire retardants to individuals that may be hit by a retardant drop and ingestion ofchemical residues on prey items. For example, the New Mexico ridgenose rattlesnake (a listed ESA species) is active only certain periods of the year. The period of May through July is the peak fire season in southern Arizona and New Mexico. Rattlesnakes are active on the surface as early as April and as late as October, with a seasonal peak between July and September. Individuals are known to be active during daylight and crepuscular periods. During those hours, they may be resting under vegetation (bunch grasses, leaf litter, and downed logs) or rocky cover, thermo-regulating in the open, or hunting. Between June and August, young of the year rattlesnakes are also present on the surface as the live-born young disperse from their birth sites (http://www.fws.gov/endangered/species/us-species /recovery plan/newmexicoridgenoserattlesnake). Individuals may also be in sub-surface dens during these hours, and the percentage of the population vulnerable to retardant drops at any given time is unknown.

Most of the listed reptile species occurs in areas with moderate to high potential for aerial retardant use (Regions 3, 4, 5). There may be negative indirect effects of toxicity caused by eating mice that have consumed vegetation covered with retardant; (Labat Environmental 2011 - deer mouse toxicity); however, this build up of toxins through prey burden is a long term process; reptiles were not studied for toxicity by the Labat Environmental Report.

Most of the listed TES species have low distribution and population size, thus terrestrialavoidance mapping should be applied for these sites in order to minimize impacts to this species due to this species occurring on a Forest with moderate to high potential for aerial retardant use. This is a slight likelihood of direct effects since this species mobility is limited due to their small size and small home range, thus may not be able to avoid the area of a retardant drop. Also, since species may be direct application due to the high use of retardant in the area, and negative indirect effects of toxicity caused by consuming insects or vegetation that has been covered with fire retardants; however, this is a very long process. Group Amphibians

Amphibians consist of frogs and salamanders. Some are totally aquatic, some are semi-aquatic and some are terrestrial but live in semi-moist environments. They require a moist or aquatic habitat for reproduction.

For the aquatic dependent species:

Required Avoidance Mapping of aquatic waterways (regardless of which FS Region the species occurs in) should avoid direct and indirect impacts to designated critical habitat consisting of breeding, rearing and shelter sites for all of these species.

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For the terrestrial species: Recommended Avoidance Mapping of aquatic waterways (regardless of which FS Region the species occurs in) will minimize direct and indirect impacts to designated critical habitat consisting of breeding, rearing and shelter sites for all of these species.

Most of the listed PETS species have low distribution and population size, thus terrestrialavoidance mapping should be applied for these sites in order to minimize impacts to this species due to this species occurring on a Forest with moderate to high potential for aerial retardant use. This is a slight likelihood of direct effects since species mobility is limited due to their small size and small home range, thus may not be able to avoid the area of a mis-application of a retardant drop. Group Birds:

For all bird species

All are highly mobile species that are able to escape from areas with wildland fire activities. The likelihood ofa direct application from aerial application is extremely low due to these species high rate of mobility; unless the species is still nesting or with young on the nest. Most impacts are caused with the use of low flying aircraft which is expected to cause disturbance only for a very short time; usually a few minutes for a single day; thus having a small negative effect.

Indirect effects are not expected since most species would need to eat several contaminated prey items in a relatively short period of time in order to be affected, thus the ingestion of retardant chemicals through the prey burden is not expected to occur (Labat Environmental 2011).

Waterfowl, pelagic and shorebirds: included marsh and wetland species: ducks, rails, etc.

This subgroup consists of birds that are dependent on large bodies of water or shorelines for the majority of their life cycle. With a few exceptions, such as the marbled murrelet which nests in old-growth forests, most of these birds species occur in habitats where fire in not present, such as ocean, beaches, lakes, and marshes or wetlands, where the use of aerial application of fire retardant would not be effective, due to the 2000 Guidelines onno application of aerial fire retardants within 300 feet of waterways.

Water/riparian dependent species: flycatchers, herons, etc

This subgroup consists of birds that use riparian areas for breeding, rearing, or foraging habitat. Required Avoidance Area Mapping by the 2000 Guideline within 300 feet of waterways (regardless of which FS Region the species occurs in) should avoid direct and indirect impacts to designated critical habitat consisting of breeding, rearing and shelter sites as well as foraging habitatfor all of these species.

Raptor species: hawks, flacons, birds of prey

Species in this subgroup are known as birds of prey in that they actively hunt animals for food sources, with some feeding on carrion or dead animals. They occur in a variety of habitats including open prairie, mature and old growth forest, and mixed conifer-hardwood forests.

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For all raptor species: all are highly mobile species that are able to escape from areas with fire activities. The likelihood of a direct application from aerial application is extremely low due to high rate of mobility and ability to escape the wildlife fire area and avoid direct drops of retardant; unless the species is still nesting orstillhave young on the nest. Most impacts are caused with the use of low flying aircraft which is expected to cause disturbance only for a very short time; usually a few minutes for a single day; thus having a small negative effect.

Indirect effects are not expected since these raptors would travel outside of the burned areas to forage on prey species (mostly small mammals) in adjacent unburned areas; or would need to eat several contaminated prey items in a relatively short period of time in order to be affected, thus the ingestion of retardant chemicals through the prey burden is not expected to occur.

Critical habitat for the northern spotted owl and Mexican spotted owl consists of mature and old-growth stands; the use of aerial application of fire retardant will not change the primary constituent elements for this critical habitat (mature and old-growth forest). The California condor nesting habitat consists of mountains with open cliffs for nesting and tall, open grown trees for roosting; again the use of aerial application and fire retardant would not change the Primary Constituent Elements for condor critical habitat.

Forest Associated: woodpeckers/songbird species

Species in this subgroup occur in all forested habitat types and Eco-regions. Forested habitats vary from open pine – oak savannah, hardwood, coniferous, or mixed species forests ranging in all seral stage types (seral stage is a function of age and stand structure).

All species are highly mobile species that are able to escape from areas with wildland fire activities. The likelihood of a direct application from aerial application is extremely low due to the high rate of mobility and ability to escape the wildlife fire area and avoid direct drops of retardant; unless the species is still nesting or still haveyoungon the nest. Most impacts are caused with the use of low flying aircraft which is expected to cause disturbance only for a very short time; usually a few minutes for a single day; thus having a small negative effect. Another direct effect is the breaking of tops of trees which may remove nesting structures with a large load of several hundred gallons of retardant dropped at a low attitude and relatively moderate rate of speed.

Indirect effects are not expected since these species would need to eat several contaminated prey items in a relatively short period of time in order to be affected, thus the ingestion of retardant chemicals through the prey burden is not expected to occur.

Upland/grassland associated: gallinaceous, cranes, herons, etc.

Species in this subgroup occur in a variety of habitat types ranging from open grassland/prairies, scrub oak communities, to chaparral and into some forested habitat types and most Eco-regions.

All species are highly mobile species that are able to escape from areas with wildland fire activities. The likelihood of a direct application from aerial application is extremely low due to the high rate of mobility and ability to escape the wildlife fire area and avoid direct drops of retardant on them; unless the species is still nesting orstillhave young on the nest. Most impacts are caused with the use of low flying aircraft which is expected to cause disturbance only for a very short time; usually a few minutes for a single day; thus having a small negative effect.

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This subgroup occurs in the habitat type which has the highest probability for the use of aerial application of fire retardants. Scrub brush, chaparral, and grassland are the highest priority areas for retardant use; since these fuel types are best controlled with the aid of fire retardant due to the lack of over-story canopy closure which allows for the direct application of retardant onto the vegetation, thus increasing the effectiveness of the retardant (see Appendix WL-2 for application rates per eco-region and fuel type).

Indirect effects are not expected since these species would need to eat several contaminated prey items in a relatively short period of time in order to be affected, thus the ingestion of retardant chemicals through the prey burden is not expected to occur.

Desert/arid associated: cactus wren, etc.

Most of the birds species in this subgroup occur in habitats where fire in not present, such as the Mojave and Sonoran deserts which consist mainly of sandy soils with arid plants that are widely spaced, where the use of aerial application of fire retardant would not be as effective. Group Invertebrates:

Arachnids – spiders

The habitats occupied by the species are dependent on high moisture regimes. The effects of a fire in these areas would be devastating to the species. It is possible that the use of fire retardant would be recommended to protect known and suitable habitats for the spruce-fir moss spider to avoid catastrophic loss of either species and/or their habitat. Therefore, while there could be adverse effects to the species from the use of fire retardant (though Phos-Chek’s effects on arachnids has not been studied by the Labat Environmental 2011), the use of retardant (that would only affect a portion of the occupied habitat for a short duration of time) would be justified to protect the remainder of the habitat from the known detrimental effects of fire.

Most National Forests with listed spider species have conservation measures in place for the protection of these species. For example, the spruce fir moss spider occurs on the Nantahala and Pisgah National Forests, whichhave Forest Plan conservation measures to prevent any adverse impacts to the spruce-fir moss spider, no direct impacts are expected (USDI FWS 2008). On the Cherokee National Forest the primary direct effects on the spruce-fir moss spider could include physical injury to or death of spiders resulting from the force of the retardant hitting them, as well as impacts from physical changes in its sensitive habitat (force of retardant hitting the moss and rock) and chemical changes in the environment (pH, phosphorous, nitrogen, etc.) The likelihood of spiders being killed by the force of retardant hitting them or their habitat is probably minimal, as the likelihood of fire retardant use in their habitat is limited. The habitat in which the spider occurs on the Cherokee National Forest has low fire potential, as evidenced by the fact that there were only three fires on Roan Mountain in the past 35 years. The use of aerially applied fire retardant is considered a rare event on the Cherokee National Forest.

Insects: butterflies and beetles, etc.

Most of the species in this subgroup are limited in distribution and occur in habitats where a host plant must be present for the larvae stages of their life cycle. They occur in several Eco-regions and have complex lifecycles that may take up to 2-3 years for larvae to mature to adults, which may live only for a few months.

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For butterflies: represented by Quino checkerspot butterfly (Euphydryas editha quino) and the Laguna Mountain skipper (Pyrgus ruralis lagunae), both ESA listed Endangered, the following impactsare expected for most butterfly species with similar habitat requirements and limited distributions.

Designated critical habitat for both species occurs throughout the southern California area in the form of coastal sage scrub communities with required host plants. The use of aerial application of fire retardant has a high probability of being used due to this habitat type being the largest in the area and the most volatile fuel type. A direct effect to habitat is the application of retardant and the fertilizing ability, thus a flush of new growth can be expected tooccur in the short term after application. Another possible change in habitat condition may occur if non-native invasive plant species are present and may out-compete native species which make up the PCEs for that habitat type.

The effects of the aerial application of fire retardants on butterflies can be manifested as a toxicity issueandas physical hazard issue. Few studies have been conducted to determine the effects of fire retardant chemicals on terrestrial invertebrates.

Direct physical hazards expected from the aerial application of fire retardant may result in some level of misting or coating of individuals, which may potentially kill adults, larvae, and pupae due to the effective sticky covering of the retardant itself rendering the animal immobilized, or possibly suffocating the individual and thus affecting its survival. The effects of fire retardant are likely influenced by the season of use and associated life-stage ofthe insect, canopy cover at the retardant drop site, retardant application rates and coverages, and the population density of the species.

Data on the potential toxicity of fire retardants to larvae of sensitive invertebrates are lacking (Labat Environmental 2007). Indirect effects from the fertilizing affect of retardants on vegetation may have a beneficial effect for host plants, but conversely, may cause the promotion of non-native species into required host plant habitats given the high amount of disturbance within and adjacent to these two species habitats.

On both the Cleveland and San Bernardino NFs, all Quino checkerspot butterfly and laguna Mountain skipper designated critical habitat has been mapped as Avoidance Areas since 2008 as part of the reasonable and prudent alternative measures from the 2008 Environmental Assessment (USDA FS 2008). In addition, several hazardous fuels reduction projects are occurring adjacent to designated critical in an effort to reduce the potential damage caused by a catastrophe fire event happening in this area adjacent to or within designated critical habitat and known occupied sites again in compliance with the 2008 Reasonable and Prudent Alternatives to prioritize fuels projects in proximity to T&E species habitats.

Mollusks: snails and slugs

The subgroup called molluscs is comprised of snails and slugs. Some are totally aquatic, some are semi-aquatic and some are terrestrial but live in semi-moist environments, usually under thick brush or tree canopies and in deep litter layers or under rocks with moss. Most of the listed TES species have low distribution and population size, thus terrestrialAvoidance Area mapping should be applied for these sites in order to minimize impacts to this species due to this species occurring on a Forest with moderate to high potential for aerial retardant use. This is a slight likelihood of direct effects since this species mobility is limited due to their small size and small home range, thus may not be able to avoid the area of a retardant drop.

The habitats occupied by these species are dependent on high moisture regimes and are not typically vulnerable to wildfires. Most occur in riparian or north facing aspects where moisture regimes are higher that thesurrounding areas. However, the effects of a fire in these areas would be devastating to the species. It is possible thattheuseof

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fire retardant would be recommended to protect known and suitable habitats to avoid catastrophic lossofeither species and/or their habitats. Therefore, while there could be adverse effects to the species from the use of fire retardant (though Phos-Chek’s effects on snails has not been studied by the Labat Environmental 2011), the use of retardant (that would only affect a portion of the occupied habitat for a short duration of time) would be justified to protect the remainder of the habitat from the known detrimental effects of fire. Avoidance Area mapping should be applied due to the limited distribution species for those forests that determine this mitigation is appropriate.

For example, the Ozark-St. Francis National Forest has developed a management plan specifically for the Magazine Mountain Special Interest Area that prohibits the use of fire retardants within the area – Required Avoidance Area due to small isolated population with no mobility. The Magazine Mountain shagreen snail (Inflectarius (Mesodon) maganinesis) is known only for one population that lives in wooded talus slopes near the summit of the north and west faces of Magazine Mountain, Logan Co, Arkansas and occurs entirely on the Ozark-St. Francis National Forest. All the species known habitat is designated as part of the Magazine Mountain Special Interest Area on the Ozark-St. Francis National Forest (USDI FWS BO 2008).

The Ozark-St. Francis National Forests have used retardant approximately 92 times between 2000 and 2010, for an average of eight drops per year (moderate to high use)(USDA FS data; Appendix WL-1). Due to this use rate, there is a low potential for a mis-application from aerial retardant if used in the immediate vicinity of the species known occupancy area. Data on the potential toxicity of fire retardants to invertebrates are lacking. However, direct effects from a possible mis-application of an aerial retardant drop in the vicinity of Magazine Mountain could potentially kill adults due to the effective sticky covering of the retardant itself rendering the animal immobilized, or possibly suffocating the individual and thus affecting its survival. Changes in soil pH are also expected, thus the chemicals in the retardant could cause burns or even direct kill due to the small size of the species.

Another example is the Noonday globe snail (Petera (Mesodon) clarki natahala). The noonday globe is endemic only to the southeast side of the Nantahala River Gorge in the Nantahala National Forest, Swain County, North Carolina; the species entire known range is within this forest unit. The steep southeastern side of the gorge is forested with a mix of various species of hardwood trees and hemlock and rich herbaceous undergrowth. The noonday globe appears to be most abundant on and around moist rocky outcrops, often covered with a variety of bryophytes and fungi, along the streams and scattered seeps draining the southeastern slope, but can also be found in thick leaf litter and humus layers around the base of ferns (USDI FWS BO 2008).

The USFS has designated the southeast slope of Nantahala Gorge (the portion of the gorge occupied by the Noonday globe) as a National Forest Special-Interest Management Area (Nantahala Gorge/Bowing Spring Management Area) with restriction on the use of aerial fire retardant; again, this can be categorized asa Required Avoidance Area. Literature Cited – Appendix I – Wildlife

Geier-Hayes, Kathleen. 2011. Fire Ecology Specialist's Report for Draft Environmental Impact Statement, National Aerial Application of Fire Retardant DEIS

Labat Environmental. 2007. Ecological Risk Assessment: Wildland Fire-Fighting Chemicals

Labat Environmental, Inc. 2011. Risk Comparison of Uncontrolled Wildfires and the Use of Fire Suppression Chemicals, prepared for National Interagency Fire Center, USDA Forest Service, Boise ID. 32 p.

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USDA Forest Service. 2008. Decision Notice/Finding of No Significant Impact. Aerial Application of Fire Retardant Environmental Assessment

USDA Forest Service, et al. 2000. Guidelines for Aerial Delivery of Retardant or Foam near Waterways. 2 p.

USDI Fish and Wildlife Service. 2008. Final Biological and Conference Opinion on the USDA Forest Service's Proposed Guidelines for Aerial Application of Fire Retardant and Foams in Aquatic Environments

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Appendix J – Suppression Chemicals and Delivery Systems Redbook Chapter 12: Suppression Chemicals & Delivery Systems, Released Jan. 2010

Policy for Use of Fire Chemicals

Use only products qualified and approved for intended use. Follow safe handling procedures, use personal protective equipment recommended on the product label and Material Safety Data Sheet (MSDS).

A current list of qualified products and approved uses can be found on the Wildland Fire Chemical Systems (WFCS) website:

http://www.fs.fed.us/rm/fire/wfcs/index.htm Link to appropriate Qualified Products List (QPL)

Refer to local jurisdictional policy and guidance related to use of wildland fire chemicals for protection of historic structures.

Products must be blended or mixed at the proper ratio prior to being loaded into the aircraft. Quality control and safety requirements dictate that mixing or blending of wildland fire chemicals be accomplished by approved methods. Types of Fire Chemicals Long-Term Retardant

Long-term retardants contain fertilizer salts that change the way fuels burn. They are effective even after the water has evaporated. Retardants may be applied aerially by large air tanker, single engine airtanker (SEAT) and helicopter bucket. Some products are formulated specifically for delivery from ground sources. See the QPL for specific uses for each product.

Recommended coverage levels and guidelines for use can be found in the Principles of Retardant Application, NFES 2048, PMS 440-2 pocket card. Retardant mixing, blending, testing, and sampling requirements can be found at the WFCS website Lot Acceptance and Quality Assurance page: http://www.fs.fed.us/rm/fire/wfcs/laqa.htm. Fire Suppressant Foam

Fire suppressant foams are combinations of wetting and foaming agents added to water to improve the effectiveness of the water. They are no longer effective once the water has evaporated. Foam may be applied by engines, portable pumps, helicopters and SEATs. Some agencies also allow application of foam from fixed-wing water scoopers. See the QPL for specific uses for each product.

Technical guidelines for equipment operations and general principles of foam application are discussed in Foam vs. Fire; Class A Foam for Wildland Fires, NWCG, PMS 446-1, NFES 2246, 2nd ed., October 1993, and Foam vs. Fire, Aerial Applications, NWCG, PMS 446-3, NFES 1845, October 1995.

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Wet Water

Using foam concentrates at a mix ratio of 0.1 percent will produce a wet water solution. Water Enhancer (Gel)

Water enhancers, such as fire fighting gels, are products added to water to improve one or more of thephysical properties of water. They are not effective once the water has evaporated. These products may be used in structure protection within the wildland interface or on wildland fuels. They are fully approved for use in helicopter bucket and engine application. Many are also approved, at specific mix ratios, for use in SEATs, and fixed tank helicopters. See the QPL for specific uses for each product. Safety Information Personnel Safety

All qualified wildland fire chemicals meet minimum (June 2007) requirements in regard to aquatic andmammalian toxicity, acute oral toxicity, acute dermal toxicity, primary skin irritation, and primary eye irritation. Specifications for long-term retardants, fire suppression foams, and water enhancers, can be found on the WFCS website.

Personnel involved in handling, mixing, and applying fire chemicals or solutions shall be trained in proper procedures to protect their health and safety and the environment. Approved fire chemicals can be irritating to the eyes. Personnel must follow the manufacturer’s recommendations; including use of PPE, as found on the product label and product MSDS. The MSDSs for all approved fire chemicals can be found on the web siteat http://www.fs.fed.us/rm/fire/wfcs/msds.htm.

Human health risk from accidental drench with fire chemicals can be mitigated by washing with water toremove any residue from exposed skin.

Containers of any fire chemical, including backpack pumps and engine tanks, should be labeled to alert personnel that they do not contain only water and the contents are not potable.

Slippery footing is a hazard at storage areas, unloading and mixing sites, and wherever applied. Because all fire chemical concentrates and solutions contribute to slippery conditions, all spills must be cleaned up immediately, preferably with a dry absorbent pad or granules. Firefighters should be aware that fire chemicals can conceal ground hazards. Wildland fire chemicals can penetrate and deteriorate leather boots, resulting in wet feet and potentially ruined leather. Aerial Application Safety

Persons and equipment in the flight path of intended aerial drops should move to a location that will decrease the possibility of being hit with a drop.

Persons near aerial drops should be alert for objects (tree limbs, rocks, etc.) that the drop could dislodge.

During training or briefings, inform all fire personnel of environmental guidelines and requirements for fire chemicals application and avoid contact with waterways.

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Avoid dipping from rivers or lakes with a helicopter bucket containing residual fire chemicals without first cleaning/washing down the bucket.

Consider setting up an adjacent reload site and manage the fire chemicals in portable tanks or terminate the useof chemicals for that application. Policy for Delivery of Wildland Fire Chemicals near Waterways

Avoid aerial application of wildland fire chemicals within 300 feet of waterways and any ground application of wildland fire chemicals into waterways. The policy has been adopted fromthe 2000 Guidelines for Aerial delivery of Retardant or Foam near Waterways which were established and approved by the FS, BLM, NPS, and FWS. It has been expanded to include all wildland fire chemicals, including water enhancers. This policy was updated in 4/09 and can be found at: http://www.fs.fed.us/rm/fire/wfcs/Application_Policy-MultiAgency_042209- UPDATE.pdf Exceptions:

When alternative line construction tactics are not available due to terrain constraints, congested area, life and property concerns or lack of ground personnel. It is acceptable to anchor the wildland fire chemical application to the waterway. When anchoring a wildland fire chemical to a waterway, use the most accurate method of delivery in order to minimize placement of wildland fire chemicals in the waterway (e.g., a helicopter rather than aheavy airtanker).

When potential damage to natural resources outweighs possible loss of aquatic life, the unit administrator may approve a deviation from these guidelines. Definition of Waterway 1

Any body of water including lakes, rivers, streams and ponds whether or not they contain aquatic life. Guidance for Pilots

To meet the 300-foot buffer zone guideline, implement the following:

Medium/Heavy Airtankers: When approaching a waterway visible to the pilot, the pilot shall terminate the application of wildland fire chemical approximately 300 feet before reaching the waterway. When flyingover a waterway, pilots shall wait one second after crossing the far bank or shore of a waterway before applying wildland fire chemical. Pilots shall make adjustments for airspeed and ambient conditions such aswindto avoid the application of wildland fire chemical within the 300-foot buffer zone. Single Engine Airtankers: When approaching a waterway visible to the pilot, the pilot shall terminate application of wildland fire chemical approximately 300 feet before reaching the waterway. When flyingover a 16 waterway, the pilot shall not begin application of wildland fire chemical until 300 feet after crossing the far bank or shore. The pilot shall make adjustments for airspeed and ambient conditions such as wind to avoid the application of retardant within the 300-foot buffer zone. Helicopters: When approaching a waterway visible to the pilot, the pilot shall terminate the application of retardant or foams 300 feet before reaching the waterway. When flying over a waterway, pilots shall wait five

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seconds after crossing the far bank or shore before applying the wildland fire chemical. Pilots shall make adjustments for airspeed and ambient conditions such as wind to avoid the application of wildland fire chemicals within the 300-foot buffer zone.

This policy does not require the helicopter or airtanker pilot-in-command to fly in such a way as to endanger his or her aircraft, other aircraft, structures or compromise ground personnel safety. Reporting Requirements of Wildland Fire Chemicals into Waterways:

Any fire chemicals aerially applied into a waterway or within 300 feet of a waterway require promptupward reporting to incident management and agency administrator. Notifications will also be made for any spills or ground applications of fire chemicals into waterways or with potential to enter the waterway.

If it is believed that fire chemicals have been introduced into a waterway, personnel should immediately inform their supervisor. The incident or host 41 authorities must immediately contact appropriate regulatory agencies and 42 specialists within the local jurisdiction.

Initial notifications of wildland fire chemical mishaps will be reported as soon as possible to theWFCSFire Chemical Project Leader in Missoula, Montana at phone 406-329-4859 (if no answer please leave message) or to individuals listed on website referenced below. Include the date, location, and extent of the introduction.

All information, including reporting form and instructions, are posted on the web site at: http://www.fs.fed.us/rm/fire/wfcs/report.htm.

FS - Additional Reporting Requirements for Threatened and Endangered Species. Reporting is also required for all introductions of wildland fire chemicals into habitat for those Threatened and Endangered species identified by the U.S Fish and Wildlife Service (FWS). The list and other information can be found at . This requirement resulted from the Forest Service’s acceptance of Biological Opinions received from the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (FWS). When wildland fire chemicals adversely affect any threatened, endangered, or proposed species, or designated or proposed critical habitat, regardless of the 300’ waterway buffer zone, the Forest Service Line Officer must initiate emergency consultation with the FWS and/or NMFS. The FS unit should coordinate with the local FWS or NMFS office to monitor, determine significance of effects, and design appropriate responsive measures. The procedures, reporting form and instructions can be found at the same website as listed above.http://www.fs.fed.us/fire/retardant/index.html. This requirement resulted from the Forest Service’sacceptance of Biological Opinions received from the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (FWS). When wildland fire chemicals adversely affect any threatened, endangered, or proposed species, or designated or proposed critical habitat, regardless of the 300’ waterway buffer zone, the Forest Service Line Officer must initiate emergency consultation with the FWS and/or NMFS.The FS unit should coordinate with the local FWS or NMFS office to monitor, determine significance of effects, and design appropriate responsive measures. The procedures, reporting form and instructions can be found at the same website as listed above. Endangered Species Act (ESA) Emergency Consultation

The following provisions are guidance for complying with the emergency section consultation procedures of the ESA with respect to aquatic species. These provisions do not alter or diminish an action agency’s responsibilities under the ESA.

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Where aquatic threatened &endangered (T&E) species or their habitats are potentially affected by aerial application of wildland fire chemical, the following additional procedures apply:

As soon as practicable after the aerial application of wildland fire chemical near waterways, determine whether the aerial application has caused any adverse effects to a T&E species or their habitat. This can be accomplished by the following: Aerial application of wildland fire chemical outside 300 ft of a waterway is presumed to avoid adverse effects to aquatic species and no further consultation for aquatic species is necessary. Aerial application of wildland fire chemical within 300 ft of a waterway requires that the unit administrator determine whether there 41 has been any adverse effects to T&E species within the waterway. These procedures shall be documented in the initial or subsequent fire reports: If there were no adverse effects to aquatic T&E species or their habitats, there is no additional requirement to consult on aquatic species with Fish and Wildlife Service (FWS) or National Marine Fisheries Service (NMFS). If the action agency determines that there were adverse effects on T&E species or their habitats then the action agency must consult with FWS and/or NMFS, as required by 50 CFR 402.05 (Emergencies). Procedures for emergency consultation are described in the Interagency Consultation Handbook, Chapter 8 (March, 1998). In the case of a long duration incident, emergency consultation should be initiated as soon as practical during the event. Otherwise, post-event consultation is appropriate. The initiation of the consultation is the responsibility of the unit administrator.

Ground application of a wildland fire chemical into a waterway also requires determining whether the application has caused any adverse effects to a T&E species or their habitat. The procedures identified above also apply.

Each agency is responsible for ensuring that their appropriate agency specific guides and training manuals reflect these standards.

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Appendix K – Retardant Avoidance Maps for Alternative 5

Figure K-1. Retardant Avoidance Areas, Boise National Forest, Idaho

Retardant Avoidance Areas 1/4 Mile Stream Buffer, Wilderness, & Protected Areas Disallowed Boise National Forest

Boise FSEEE Avoidance Areas

0 5 10 20 30 40 Miles Kilometers 4 0 10 20 40 60 80 December 23, 2010

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Figure K-2. Retardant Avoidance Areas, San Bernadino National Forest, California

Retardant Avoidance Areas 1/4 Mile Stream Buffer, Wilderness, & Protected Areas Disallowed San Bernardino National Forest

San Bernardino FSEEE Avoidance Areas

0 5 10 20 30 40 Miles Kilometers 4 0 5 10 20 30 40 December 23, 2010

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Appendix L – Forest Service Wildland Fire Chemical Program and Process

Forest Service Manual 5100 includes the policy for the use of wildland fire chemicals on National Forest System lands and National Grasslands. The policy includes the requirement that all wildland fire chemicals undergo an evaluation based on the requirements within an established Forest Service specification prior to the product being place on a qualified products list (QPL) which is then used by field units to purchase only evaluated products.

Department of Interior agencies use the Forest Service QPLs through the Interagency Standards for Fire and Fire Aviation Operations. Other fire organizations at all levels from local to international use the QPL by reference as part of their fire chemical procurement processes.

The Forest Service implemented the wildland fire chemical systems program over 40 years ago to ensure that the agency had products available that were environmentally friendly and that would be effective in meeting our firefighting needs. The agency included requirements to ensure the health and safety of the firefighters, thepublic, and the equipment. The Wildland Fire Chemicals Program (WFCS) at the Missoula Technology and Development Center (MTDC) and its predecessors have coordinated and overseen the evaluation program from the beginning.

There are currently three categories of fire chemicals with formal specifications developed to address the needsof firefighters. The fire chemical categories are long-term retardants, class A foams, and water enhancers (gels).Each category has a purpose and specific strengths and weaknesses which are incorporated into the specific specifications. There are separate QPLs for each product type.

Although the specifications and requirements are specific to a product category, each specification hasthesame general categories of required characteristics. Some tests have required performance defined and others provide information used to define a range of performance that may be advantageous for certain firefighting tasks. Additionally all categories have the same requirements when uses or exposures are the same. These broad categories of requirements include:

Effectiveness Fire retarding or suppressing characteristics Consistency and delivery performance Safety and Environmental Protection Review of the product composition for use of unacceptable ingredients or chemicals of concern which can trigger additional requirements such as risk assessments Mammalian toxicity Aquatic toxicity Materials Protection Uniform and intergranular corrosion Nonmetallic effects Pumpability and erosion Stability Concentrates and mixed retardants must maintain performance capabilities for prescribed times Physical Properties Set limits on weight to regulate aircraft loads

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Define stability Set quality and acceptance standards

The Forest Service identified standard test methods or developed unique test methods for use in the evaluation process. The methods are summarized in the specification and detailed in a separate document found on the public internet site, www.fs.fed.us/rm/fire/

The evaluation takes up to 24 months to complete. The cost of the evaluation is paid by the product supplier. A product is place on the QPL only if it meets or exceeds the established requirements defined in the specification and measured in the Forest Service laboratory or approved outside laboratory (for some specialized tests). All tests are performed on a sample of the product which is provided by the supplier, kept under Forest Service control, and disburses by the Forest Service when outside laboratories are used. All reports and findings are sent directly to the Forest Service to maintain a chain of custody throughout the evaluation.

The Forest Service is required to publish the requirements for information to be submitted by the proposed manufacturer/submitter, testing procedures, specifications, and the QPL per Department regulations, the Federal Acquisition Regulations, and the Office of Management and Budget.

The review process for the specifications includes a notification to the existing manufacturers, cooperating agencies, and the general public for submission of suggested changes to the specifications. In addition to this process, which occurs every four to five years, the WFCS program personnel review the Environmental Protection Agency (EPA) listing of known and suspect carcinogens and extremely hazardous substances to ensure no currently formulated wildland fire chemicals contain any of the ingredients. The WFCS personnel also review the websites fortheEPA and other regulatory and standards making organizations to assure that chemical concerns and significant changes in product testing are up to date.

Examples of some of the changes to the use of fire chemicals and the evaluation process include:

1974 – Based on work by Robert Borovicka, BLM, published in Fire Management, firefighters and airtanker pilots were advised to make reasonable efforts to prevent retardant entering waterways. 1982 – Specific requirements for mammalian toxicity testing were included in the long-term retardant specification and all fire chemical specifications since then. 1995 – Forest Service started reporting to EPA in compliance with the Superfund Amendments and Reauthorization Act (SARA) Title III, Section 313 the Emergency Planning and Community Right to Know (EPCRA) - Form R of retardant distribution and use began based on ammonia content. WFCS prepares reports as necessary for all airtanker bases buying retardants under the National Retardant Contract. 1996 – Complies with letter policy from the Director, Fire and Aviation Management regarding use of chemical listed on certain advisory lists from EPA for hazardous chemicals and the National Toxicology Program (NTP) and International Agency for Research on Cancer (IARC) for known and suspect carcinogens. 1992 – Commissioned the first of several Human Health and Ecological Risk Assessments on theuseof Wildland Fire Chemicals. The first assessments were published in 1994 and were most recently updatedin 2003 for human health and 2007 for ecological effects. 1992 – Began working with the staff of the Columbia Environmental Research Center (CERC) of the United States Geological Services (USGS), formerly part of the Fish and Wildlife Service (FWS) research branch to develop testing methods and requirements to assess aquatic toxicity of wildland fire chemicals. 2000 – The Forest Service provided formal guidelines for the use of retardant and avoidance of applications in waterways or sensitive habitat. Reinforced ESA section 7 consultation as required.

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2000 – Aquatic toxicity performance requirements were added to Specification 5100-307 for Class A Foams. The same requirements have been included in all fire chemical specifications for all categories of products since then. 2008 – The Forest Service conducted an Environmental Assessment on the use of Aerially Delivered Fire Retardant. 2008 – Reporting requirements were enhanced as part of the Decision Notice accepting the Reasonable and Prudent Alternatives (RPAs) in the Biological Opinions (BOs) of the National Marine Fisheries Service (NMFS) and FWS. Summaries of the intrusion reports are provided to each of the regulatory agencies and are available to the public through the Forest Service Fire and Aviation Management website. 2009 – The Forest Service worked with NMFS to determine potential effects of fire retardants on anadromous fish during the smoltification state. Exposure to retardant, salt water, and disease challenges occurredina standard succession. Based on preliminary results, additional tests on both spring and summer Chinook salmon are being conducted with all commonly used retardants. 2009 – Forest Service and cooperating agencies began work to develop a monitoring plan to be used as part of the response to misapplication of fire chemicals. A first order calculator to determine amounts of chemical in waterways and a modification of a more sophisticated existing program (ICWater) were developed and initial testing on a small number of incidents was completed. 2010 – The Forest Service began work on a nationwide Environmental Impact Study.

The QPLs are posted on a publicly-accessible Forest Service web site at www.fs.fed.us/rm/fire/. Revisions and/or additions to the QPLs are made on the 5th of each month.

Most long-term retardants are purchased through the National Retardant Bulk or Full-Service Contracts. Additional products are purchased for resupply of mobile bases assigned to fires through blanket purchase agreements. Other fire chemicals are purchases through blanket purchase agreements and local procurements.

Most long-term retardant is applied from aircraft loaded at agency operated airtanker bases. During severe fire seasons, mobile bases can be activated at other available airports capable of supporting the anticipated fire operations and aircraft in use. Remote bases can be activated for helicopter and ground equipment near the fire where water and resupply services are available.

Fire and Dispatch units with help from their TES staffs have/are preparing hazard/avoid maps and briefing packages for pilots in their areas to help minimize applications in sensitive areas.

Shipping of products and support equipment to mobile and remote bases increases the potential for transportation accidents and resulting introduction of products into waterways and sensitive habitat. These incidents are also reportable under the existing agreements.

In 2009 and 2010 awareness training was included in a number of courses and training materials for all firefighters on the ground and the air. Additional materials are being developed and added to NWCG and other local through national courses as supplemental materials now and as part of the basic coursework during revisions.

New risk assessments on the use of fire chemicals are performed every five to ten years to ensure that newly qualified products are included and that the most recent guidelines and information on environmental concerns are included.

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Appendix M – Guidance for Pilots Aerial Application of Long-Term Retardant and Foams: Guidance for Pilots, May 2008

The Chief of the Forest Service announced February 18, 2008 that the Guidelines for Aerial Delivery of Retardant or Foams near Waterways, also known as the 2000 Guidelines, will become permanent. At the same time, the Chief accepted reasonable and prudent alternatives from both the National Marine Fisheries Service (NMFS) and the Fish and Wildlife Service (FWS) in order to avoid potential jeopardy to threatened, endangered or proposed aquatic, plant, animal, and insects.

Using long-term retardant and foams through aerial delivery will continue. What’s different this year is what has to happen on the ground prior to fire season, as well as what happens if long-term retardants or foams endupina place where it will need to be reported.

Forest Service units should already be underway in working with their specialists and the Fish and Wildlife Service specialists in identifying the known areas of any Threatened, Endangered or Proposed (TEP) species and their habitats in order to develop avoidance zones concerning the use of long-term retardant or foams. The 300 foot buffer that was established in 2000 still applies concerning aquatic waterways. Retardant that is dropped in these areas must be reported. What does this mean if you are a pilot?

You will be directed by a fire official as to where to deliver your load of retardant or foam. The fire hostunitwill provide the appropriate individuals with the areas to avoid concerning the use of long-term retardant or foam and this should be taken into consideration as coordinates for delivery of a load are passed on to the pilot. You may also be directed to drop in these areas in an emergency. That is alright, but reporting must be accomplished. What happens if long-term retardant or foam ends up where it isn’t supposed to?

If you know a portion or all of your load ends up within the 300 foot buffer or entered the actual waterway or into the area that was to be avoided due to TEP, the individual directing you is the individual you will immediately report to. Regardless of the reason for the missed delivery, all pilots need to report the incident.

The individual you report this to has the responsibility to report it to the appropriate fire official on the ground or their immediate supervisor. Ultimately, the Agency Administrator for that unit is responsible to ensure the appropriate consultation and reporting requirements are initiated and completed. What else should I be aware of or know if I am a pilot?

In order to be completely informed, you should take time to review some of the materials and guidelines that have been established to date to assist agency personnel with implementing the Chief’s February 18 decision. The information compiled includes which National Forests and Grasslands have been identified with TEP. Becoming familiar with which units are listed will give you a heads-up that some additional information should be shared

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with you prior to taking action on any fire on that piece of land. This information may be shared with youbya variety of different agency officials including airtanker base personnel, lead plane pilots, air attack personnel, or ground personnel.

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