Lolo National Forest Integrated Weed Management Project Record of Decision – Table of Contents

I. Brief Description of My Decision...... 1 II. Overview of the Decision Area...... 2 III. Project Background...... 2 IV. Purpose and Need for Action ...... 3 V. Public Involvement and Issue Identification...... 5 VI. Alternatives Considered...... 7 Alternatives Considered But Not Studied in Detail...... 7 Alternatives Considered In Detail...... 9 VII. Decision...... 13 Scope of the Decision ...... 13 Decision ...... 13 VIII. Rationale for the Decision...... 14 Issues Needing Further Analysis and used to develop alternatives that were given further analysis...... 18 IX. Findings Required by Law, Regulation, and Policy...... 23 1. National Forest Management Act of 1976 (NFMA)...... 24 2. NEPA – Environmentally Preferred Alternative ...... 24 3. National Forest Noxious Weed Management Policy (FSM 2080) ...... 25 4. Executive Order 13112, Invasive Species, February 3, 1999...... 25 5. Clean Water Act and State Water Quality Standards ...... 25 6. Clean Air Act ...... 25 7. Endangered Species Act (16 USC 1531 et. seq.)...... 26 8. National Historic Preservation Act, American Indian Religious Freedom Act and Native American Grave Protection and Repatriation Act...... 26 9. Government to Government Relations ...... 26 10. Environmental Justice...... 27 11. Migratory Bird Treaty Act...... 27 12. Administration of the Forest Transportation System...... 27 X. Appeal Provisions and Implementation...... 27

Appendices

Appendix A - Weeds on the Lolo National Forest ...... Page 1 Appendix B - Project Area Maps by District ...... Pages 2-6 Appendix C - Weed Treatment Decision Tree...... Page 7 Appendix D - Monitoring Plan...... Page 8-9 Appendix E - Mitigation Measures...... Page 10-12

Figure 1- Lolo National Forest Vicinity Map

Record of Decision

Lolo National Forest Integrated Weed Management Project

United States Department of Agriculture Forest Service, Northern Region

Lolo National Forest Missoula, Mineral, Sanders, Granite, Powell, Lewis and Clark, Flathead, Ravalli and Lake Counties, Montana I. Brief Description of My Decision After extensive analysis, deliberation and review and consideration of public comments, I have decided to implement Alternative 2 from the Lolo National Forest Integrated Weed Management Project Final Environmental Impact Statement (FEIS), within the decision area defined below. This Record of Decision explains my decision and rationale for selecting this alternative for managing invasive and noxious weeds on the Lolo National Forest (LNF). I have decided to select Alternative 2 to more aggressively and effectively address the weed issue on the LNF and to enable us to more effectively prioritize where we conduct our weed management activities within the decision area. Under Alternative 2, 78,443 weed infested acres were analyzed. This decision allows treatment of a maximum of 15,000 of these 78,443 acres in any one year. Not all 15,000 acres / year will be treated with herbicides. They will be treated with the variety of weed management tools described below. Operationally, my decision will: • Add sheep and goat grazing to our existing integrated pest management • Allow us to better prioritize where we conduct our weed management activities in order to protect high value resources and control new and existing weed infestations when they are small and more easily controlled • Allow us to treat up to 15,000 acres a year with a combination of ground and aerially applied herbicides, goat and sheep grazing, biological control agents, mowing, pulling, seeding and fertilizing • Allow us to more promptly treat new weed species and new weed infestations that are discovered in weed free zones of the forest Aerial application of herbicides for weed control on the LNF is not a new program with this decision. We have conducted over 30 aerial herbicide spray projects since 1992. Our aerial spray program has a proven history and excellent safety record since we started in 1992. This decision allows treatment of up to 15,000 acres/year based on current funding. It is expected that 5,000 to 6,000 acres will be treated each year across the Forest. These treatments will be more effective because we will be able to react quicker and prioritize better. We will also continue our weed education and prevention efforts.

The 78,443 acres of project areas in this decision represents the gross exterior area of all the sites that were identified as needing treatment. There is not 100 percent weed coverage in all the project areas. For example, on an infested area of two acres, only a half acre of ground might actually be occupied by scattered clumps of weeds. Actual, on-the-ground, treatment will be less than gross area because only weed infested areas within the gross project areas will be treated. Roads, trails and linear features, for example, will usually only be spot treated where weeds occur. Treatment sites range in size from a few plants to infestations with a gross exterior boundary of 16,380 acres. My decision will also allow for an adaptive and integrated weed management strategy to include treatment of new weed species, new weed patches, and use of new control methods. This is provided that the environmental impacts are within the scope of those disclosed for Alternative 2 in the FEIS. The impacts of the selected alternative are described in the FEIS for the LNF Integrated Weed Management Project. The selected alternative provides for the use of the most effective tools for controlling weeds while having the greatest resource benefit and minimal impact on the nontarget components of the environment. II. Overview of the Decision Area The decision area covers all lands analyzed for weed treatment in the FEIS within the entire approximately 2.1 million acre LNF (Figure 1). Counties included in the analysis area are all or parts of: Missoula, Mineral, Sanders, Granite, Powell, Lewis and Clark, and Flathead, and are all in Montana. The LNF shares boundaries with eight National Forests, as well as, state and private lands. III. Project Background Weeds pose an increasing threat to native ecosystems, croplands, other plant communities, and human health and are expanding their range throughout the West. While weeds have long been recognized as a problem for agriculture, the potential impact to other plant communities, including wildlands, is receiving greater attention. An estimated 2,000 invasive and noxious weed species are already established in the United States. Twenty one invasive and noxious weed species have been found on the LNF (See Appendix A). Another 10 noxious and invasive species are found nearby but are not yet established on the forest. All types of ecosystems are vulnerable to invasive plants. These weeds can alter ecosystem processes including productivity, decomposition, hydrology, and nutrient cycling. Weed invasion can lead to displacement of native plant species with impacts to both game and nongame animal species. Weeds spread from travel ways such as roads, trails, creeks, and rivers. Airborne dispersal occurs from wind and birds. Weed seeds and plant parts are moved along road and trail systems by vehicles, people, livestock, and wildlife allowing the establishment of weeds into areas previously not infested. As corridors, road, trails and river systems allow weeds to invade both disturbed and undisturbed areas. Through the influences of wind, waterways and wildlife, weeds have been able to occupy undisturbed habitats far removed from road or trail systems.

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Acres infested with invasive and noxious weeds on the LNF are based on known infestations and inventory and estimate techniques, and occupy approximately 350,000 acres. The weed problem has exploded in scale during the last several decades. Weeds impact resources such as water quality, soil productivity, wildlife and natural vegetation diversity. Left unchecked, weeds can: • Negatively affect rare and sensitive native plant species • Degrade habitat for wildlife, especially big game species that depend on winter and summer range • Negatively impact habitat for small mammals and migratory birds • Deteriorate water quality through increased soil erosion • Replace or reduce native plant communities and biological diversity • Decrease a site’s ability to carry prescribed fire as a component of ecological function • Diminish the quality of recreational and wilderness experiences • Increase maintenance costs for roads and utility corridors The LNF Integrated Weed Management Project FEIS Alternative 2 will ensure the LNF has an up-to-date and comprehensive integrated weed control strategy in cooperation with the State of Montana and County Weed Boards to: • Reduce the rate of spread of present infestations • Prevent establishment of new weed species on the Forest. IV. Purpose and Need for Action The overall purpose of this proposal is: • Raise public and agency awareness of weeds • Increase both public and agency use of weed prevention practices • Reduce and control existing weeds • Prevent new weeds from establishing on the LNF • Encourage beneficial vegetation and weed resistant plant communities The purpose of direct weed control on the LNF is to: • Prevent potential invaders from establishing • Eradicate small new infestations and reduce larger infestations of new invaders • Contain and reduce widespread weeds within infested areas • Allow rapid, timely response to new, small or recently discovered infestations before they become well established • Prevent or limit the spread of established weeds to protect weed-free areas • Implement the 2004 Forest Service National Strategy and Implementation Plan for Invasive Species Management On the LNF, we want to focus our weed control efforts on infestations where we can realize the greatest resource benefits; those with the highest risk of further spread and those where we have the best likelihood of success.

Lolo National Forest Integrated Weed Management ROD Page 3 We need to do more on the LNF to address the impacts and issues associated with weeds because: 1) Weeds are present and spreading. Populations of widespread invaders, such as spotted knapweed, sulfur cinquefoil, houndstongue and Canada thistle, are widespread and continue to expand. Since they became established, in some cases decades ago, they have increased on the LNF. These weeds have also invaded both disturbed and undisturbed areas. New invaders such as the hawkweeds and common toadflax have become established relatively recently. Some of these infestations were first seen on the LNF in the last few years, while others have been here longer but have only recently been discovered. Most new invaders have limited distribution. Potential invaders such as yellow starthistle, purple loosestrife, salt cedar and dyer’s woad have not been found on the LNF yet, but do occur nearby. Based on the extent of the infestations in adjacent areas and states, these weeds have the potential to become established and impact other resources on the LNF. 2) While prevention is an important weed management tool, prevention won’t control the weeds that are already established on the LNF. We need to reduce existing infestations or reduce the rate of weed spread on the Forest. Some small or new infestations can be eradicated. 3) We are already doing a lot of weed management but weeds are still damaging forest resources, so we need to do more. Forest resources are negatively impacted by existing and expanding populations of weeds. Because they are naturally adapted competitors and native biological control agents are absent, weeds can out-compete and crowd out native plants. Only 10,330 weed infested acres on the LNF have existing weed control decisions. We’ve identified another 78,443 acres that have weeds and need attention. 4) We need to be able to respond quickly to new infestations and disturbances such as wildfire. At present, we cannot respond rapidly to new infestations and disturbances. The LNF is receiving more and more requests from the public to control weeds and is not able to respond to those requests. Many recently located infestations or new weed species are not covered under existing decisions and are being allowed to spread unchecked. Implementing treatment methods that protect other resources, like water quality and rare plants and animals, will improve resource benefits, cost effectiveness, and respond better to public requests for weed treatments. 5) We need to have an active weed program so we can implement and follow Federal, State and Forest Service law, regulation, policy and initiatives relating to weed management. Forest plan and agency objectives for biodiversity, our responsibility to health and safety, cooperation with neighboring land owners and consistency with Federal and State laws require an aggressive weed program. The weed laws and policy described in the FEIS direct us to have an aggressive program.

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I want to reduce the impacts of noxious and invasive weeds and restore native plant communities as much as possible in a safe and cost-effective manner. Restoration in this context, means reducing noxious weed competition in order to increase the vigor of existing native plant communities. My intent is not to just kill weeds. I want to encourage beneficial and native vegetation, animals, and weed resistant plant communities. An aggressive treatment program when weed infestations are small is most effective. I recognize that we will never eradicate all the weeds on the LNF, but I feel we need to do a better job than we are doing now. V. Public Involvement and Issue Identification A scoping letter was sent out on July 16, 2004 to 268 people, government agencies, tribal interests, news media, businesses and organizations that have shown interest in similar projects on the LNF. This letter described the Purpose and Need for the project, the Proposed Action, and asked for comments. People were asked to comment within a 30 day period ending August 20, 2004. During the same time frame, the scoping letter was sent as a news release to six local news organizations. In addition, the proposal was the subject of a news article in the Missoulian on August 1, 2004 and an interview on KTMF-TV on August 11, 2004. A Notice of Intent was published in the Federal Register on August 4, 2004. People were asked to comment within a 45 day period, ending September 20, 2004. The Flathead Culture Committee of the Consolidated Salish and Kootenai tribes was also asked for comment. This media and scoping publicized the proposal. Comments received from the public identified specific areas of concern and issues during the early phase of this environmental analysis. Twenty-nine letters, personal comments and phone calls were received and considered by the ID team and the responsible official. These documents are included in the Project Record at the LNF Supervisor’s Office. Issues Issues were identified through scoping, as they were raised by the public, other government agencies and the Forest Service. Important environmental issues were identified to focus the environmental analysis. Potential environmental issues are discussed in proportion to their importance, and issues that don’t pertain to the action were eliminated. The Interdisciplinary (ID) Team’s review of the comments showed that two-thirds agreed weeds are an urgent concern on the LNF and that steps should be taken quickly to reduce or eliminate them. All of these comments supported the use of herbicides as part of the proposal. Another concern was that the maximum annual acres treated would be too small. Some people had questions or concerns about herbicides. They questioned the need for herbicides or expressed concern about the effects of herbicides on resources or human health. The ID team found the primary concerns with the Proposed Action centered on whether there was a need and urgency to control weeds, and whether herbicides should be used as part of the Integrated Pest Management (IPM) strategy. The ID

Lolo National Forest Integrated Weed Management ROD Page 5 team evaluated these concerns and developed mitigation measures to make sure the effects of the Proposed Action will not be significant. Issues were categorized into three groups: • Issues outside the scope of the Proposed Action • Issues considered but not given further analysis • Issues that need further analysis – these are the issues that were used to develop alternatives Issues outside the Scope of the Proposed Action One commenter questioned the adequacy of the process used by the EPA to review and register herbicides for weed control. The decision includes a requirement in that all herbicides will be handled following EPA label guidelines and other state and federal laws governing storage, mixing, application and disposal. The EPA has regulatory responsibility regarding the evaluation, disclosure and registration of herbicides in the United States. This issue is beyond the legal authority of the Forest Service. This issue is outside the scope of the Proposed Action, and was not considered further Issues Considered, But Not Given Further Analysis Why are we proposing a 15,000-acre cap on the area we could treat each year? This seems too small to address the weed infestations found on the 2.1 million acre LNF. While we recognize a need to treat more acres each year, this figure was proposed based on anticipated weed management capacity and to provide an upper limit for effects analysis. Our 10-year budget average has allowed us to treat 5,000 to 6,000 acres/year. The 15,000 acre cap will allow us to do substantially more weed work than we are currently doing. Issues Needing Further Analysis Public and agency comments raised issues that guided the development of alternatives. Each issue is stated below as a question and is followed by a brief discussion of how it is addressed in the FEIS. Why don’t we analyze a prevention alternative? This issue was used to formulate an alternative, but for the reasons discussed in the alternatives section, this alternative was not given detailed analysis. See Alternatives Considered, but Not Studied in Detail. Prevention is however, included as a weed management tool in Alternatives 1 and 2. Why don’t we consider a low herbicide alternative? We developed a low herbicide alternative to respond to this issue, it was considered, but not studied in detail. See the Alternatives Considered, but Not Studied in Detail. What are the effects of weeds on wildlife and other natural resources? Many people described weeds as a very big problem because they have seen the impacts of nonnative plants on vast areas. The effects of weeds on resources are discussed in detail in Chapter 3 of the FEIS.

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How will actions taken to control weeds, especially herbicides, affect wildlife and other resources? Some people expressed concern about the effects of herbicides on wildlife and other natural resources. To respond to this issue, a No Herbicide Alternative is discussed, a Low Herbicide Alternative was considered, but not studied in detail, and the No Action Alternative, which holds herbicide use at current levels, was analyzed. The effects of herbicides on natural resources, as well as models and past experience with herbicide drift from aerial application, are disclosed in Chapter 3 of the FEIS. Effects on terrestrial animals, plants, soil and aquatic organisms are also addressed in the Forest Service Ecological and Human Health Risk Assessments which were incorporated into this analysis by reference. What are the potential effects of herbicides on human health? Some people expressed concern about the effects of herbicides on human health. To respond to this issue, a No Herbicide Alternative was discussed in Alternatives Considered, but Not Studied in Detail. The potential human health effects of herbicides included in this proposal are disclosed in Chapter 3 of the FEIS. Effects on human health are also addressed in the Forest Service Ecological and Human Health Risk Assessments which were incorporated into this analysis by reference. DEIS Comments Fourteen comments were received on the DEIS. These comments can be found verbatim along with responses and specific changes that were made in the FEIS Chapter 5, pages 236-303. VI. Alternatives Considered Alternatives Considered But Not Studied in Detail Prevention Alternative One commenter suggested we consider a Prevention-Only Alternative. This Prevention Alternative did not presuppose any particular amount of the various weed management tools, featuring instead, intensive monitoring. This alternative would act on the logic that preventing weeds and eradicating new infestations would be effective. In this alternative, the commenter said, “that human activity is the major vector of weeds into the Forest” and that by significantly controlling human activity, the Forest Service will be able to stop weeds from spreading. This alternative includes a monitoring program that would measure: • Interaction of invading and native species in various ecological niches • Soil parameters, such as hydrology and nutrients • Impact of human activity on weed introduction and spread • Effects of controlling human activity • Effects of weeds • Effects of herbicide drift • “True impact of poisons to biological systems”

Lolo National Forest Integrated Weed Management ROD Page 7 This alternative was not given detailed analysis or further consideration because: 1. Although preventing weeds and eradicating new infestations would control some weeds, this approach would not reduce or control existing infestations. As such, this alternative would not meet the Purpose and Need. 2. Changing land use/Forest Plan direction or travel management, road use and forest access are outside the scope of this analysis. No Herbicides Alternative Some people expressed concerns about using herbicides. In response to these concerns the ID team considered an alternative that would respond to the Purpose and Need without using herbicides. A No Herbicides Alternative is different from the No Action Alternative because the No Action Alternative allows the use of herbicides authorized under previous existing NEPA decisions. A No Herbicides Alternative was analyzed in detail in the LNF 2001 Big Game Winter Range and Burned Area Weed Management FEIS. That analysis was incorporated into this one by reference and found the No Herbicide Alternative to be cost prohibitive. That analysis indicated it would cost almost $73,000,000 to treat a maximum of 21,750 acres. It found effective control would require at least one treatment a year and, in most cases, two (e.g. pulling or mowing). In this analysis we are considering a maximum of 15,000 treatment acres/year, smaller maximum annual treatment acreage than considered in the 2001 LNF analysis. Using the 2001 aggregate cost, it would cost more than $50,000,000 to treat a maximum of 15,000 acres/year. Due to the cost a No Herbicide Alternative simply would not allow enough annual treatment to minimally meet the Purpose and Need for this analysis. Furthermore, hand pulling and mowing have not proven effective at containing or reducing large widespread weed infestations. For these reasons, this alternative was not given further consideration. Low Herbicide Alternative Under a Low Herbicide Alternative, herbicides would be used only to eradicate new species or new infestations. There would be no aerial application of herbicides and to minimize herbicide use, prior decisions authorizing herbicides would be withdrawn. New infestations would be defined as infestations smaller than one acre in perimeter. Mechanical weed control (pulling) would be used on about half the projects and herbicides on the other half. This alternative assumes a maximum of 250 acres of small, new infestations would be treated each year (approximately 50 acres/Ranger District). Weed infestations larger than one acre would not be treated with herbicides or by pulling or mowing. Biological controls would be released at current levels. Treated sites would be seeded only if there was not enough native or desirable vegetation to reoccupy the site after weed treatment. Weed education and prevention would continue at current levels. This alternative would include an adaptive approach that would allow managers to learn from the past and improve future effectiveness. It would provide quick,

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effective treatment of small, new infestations before they grow while still addressing other resource concerns. Since not every acre has been inventoried, many small existing sites have yet to be identified. The herbicide treatments assume an average cost halfway between backpack pedestrian ($125/acre) and truck application ($30/acre), for a cost of $77.50/acre. For 125 acres, this would amount to $9,687.50. Pulling would cost an average of $8,370/acre for two pulls – to be effective pulled sites have to be pulled at least twice a year. Pulling costs are estimated at the rates for paid employees. For 125 acres, this would amount to $1,046,250. This alternative would not meet the Purpose and Need, would not address larger infestations and would exceed our present and anticipated capacity to do work. For these reasons, it was not given further consideration. Concentrated Eradication Cells Alternative One ID Team member suggested we focus on eradicating weeds in limited locations, or cells. Under a Concentrated Eradication Cells Alternative, weed management would be concentrated on a limited number of small infestations. Control efforts would not begin in new places until the weeds were eradicated in the first cells. While one of the specific purposes of this proposal is to eradicate small new infestations of new invaders, it is not the purpose of this proposal to eradicate widespread weeds. The Purpose and Need says widespread weeds are to be contained and reduced within infested areas. Concentrating all our efforts on limited areas would reduce our ability to rapidly respond to new infestations and potential invaders. New infestations and potential invaders could become established before we eradicate weeds in previously identified cells. This alternative does not meet the Purpose and Need, and would conflict with the 1991 Amendment 11 to the LNF Plan. For these reasons, it was not given further consideration. No Aerial Application Alternative A No Aerial Application Alternative was analyzed in detail in the LNF 2001 Big Game Winter Range and Burned Area Weed Management EIS. Under this alternative we would not be able to economically or safely treat large, remote winter ranges or other infestations where there are few or no roads, and where pedestrian treatment is inefficient, dangerous or impractical. Because of these limitations and the costs documented in the LNF 2001 EIS, this alternative would not meet the Purpose and Need, nor would it effectively implement the 2004 Forest Service National Strategy and Implementation Plan for Invasive Species Management. For these reasons, it was not given further consideration. Alternatives Considered In Detail The alternatives below include weed education, prevention, mechanical, cultural, biological and herbicide weed management practices.

Lolo National Forest Integrated Weed Management ROD Page 9 Alternative 1, No Action Under the No Action Alternative, no new actions would be taken to respond to the Purpose and Need described in Chapter 1. Weed control would continue to take place at current levels, namely, actions authorized in site-specific decisions since the 1991 LNF Plan Weed Amendment 11. This amounts to about 5,000 to 6,000 acres treated annually. Under current existing NEPA decisions, treatment could occur on 10,330 acres of the LNF. There would be no forest-wide plan to take action on new weed species or new infestations. Actions to control or eradicate new infestations not covered in existing decisions would require further NEPA analysis and documentation. These analyses will take from one to three years to complete if funding were available. Alternative 2, Proposed Action Under Alternative 2, the LNF will implement an adaptive integrated weed management strategy to control weeds as budgets allow. Adaptive Management, as used in this analysis, is defined as, a dynamic approach to resource management in which the effects of treatments and decisions are monitored and used with research results, to modify management on a continuing basis to ensure objectives are met. It will also allow managers to control new and small weed infestations before they can expand. This strategy combines a prevention/education component; a combination of ground and aerially applied herbicides; biological agents, revegetation, mechanical and cultural treatments; and sheep and goat grazing on a maximum of 15,000 acres/year. The desired outcomes of this strategy are to: • Establish beneficial vegetation and weed resistant plant communities • Improve public awareness of weeds • Expand the use of both public and agency weed prevention practices • Protect weed free areas • Reduce or deplete the number of viable weed seeds in the soil Sites treated with herbicides, biological agents, seedings, mechanical controls or sheep or goat grazing will receive follow-up treatments until the viable weed seeds in the soil are depleted or reduced to an acceptable level. Management goals for each weed species on the LNF are listed in Appendix A of this Decision. When treatments or programs are repeated, they could occur either annually or every two or three years until the goals are achieved. Herbicide treatments will typically be repeated once every one to three years, depending on the control method, size of infestation, persistence (if a herbicide is used) and weed species, until the desired goal is achieved. Education and awareness programs will be repeated; one or more per year, in hopes of incorporating them into the way people act and think without being prompted. The weeds listed in Appendix A of this Decision will be treated considering a number of factors, such as funding, invasiveness of the species, potential for the seeds to move off-site, and the ecological importance or rarity of a certain site.

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Other invasive plant species may be added to the list in Table 1-1 as they are discovered and their invasive potential is identified. The 78,443 acres of known weed-infested sites are shown on the maps in Appendix A of this Decision. The treatment priorities for the Proposed Action include the priorities from the 1991 Weed Amendment to the 1986 Lolo Forest Plan, and other sites at risk for weed invasion or spread, as described in Chapter 1 of the FEIS under the Need Section. The priority site types are: 1. Big-game winter ranges which include generally south-facing, dry, relatively open lands under 5,000 feet elevation that support ponderosa pine or Douglas fir habitat types. 2. Weed-free areas, and the roads, trails and trailheads that lead into them. 3. Areas of concentrated public use (since people spread weeds) which includes both developed and dispersed undeveloped campsites; trailheads where system trails join forest roads and serve as a transition point from automobile travel to pedestrian, bicycle, horseback, ski or motorized recreational vehicle travel. 4. Administrative sites, which include Forest Service pastures, Ranger Stations, work centers, lookouts, backcountry cabins and owned or leased airstrips and helibases, and helispots. 5. National Forest lands bordering private lands with active weed-control programs. These areas include Forest Service lands where the neighboring landowner has an active weed control program and lack of weed management on LNF lands is affecting their program; relatively weed free lands where adjacent weed infested LNF lands threaten the adjacent land and/or where adjacent landowners might request treatment on National Forest lands to protect weed management investment on private land. 6. Disturbed areas, which include but are not limited to log landings, fire crew or other crew staging areas and field project camps. 7. Other disturbed areas include: Fire camps which include permanent or occasionally used locations we have used or expect to use for fire camps or helispots in the event of a wildfire; Burned areas which include areas of the forest that have burned in either a wild or prescribed fire and firelines and contingency firelines; Electronic sites which include designated and undesignated high elevation commercial or non commercial sites used for microwave, radio, television, cellular or navigational facilities; Gravel pits, mining and rock operations which include active and inactive mines; sapphire or crystal digging pits; borrow pits; prospecting holes and common rock gathering sites; Linear features which include power and utility corridors and rights of ways; ski areas which include Marshall Mountain and Montana Snowbowl ski areas; range sites which include permitted grazing allotments and other areas impacted by livestock; and roads and trails which include open and closed system and non system roads and trails, cross country ski trails, snowmobile trails, historic roads and trails, National Historic Trails and un-maintained roads. 8. Less or undisturbed areas such as riparian areas, roadless or wilderness areas where weeds are found. Riparian areas are lands adjacent to streams, lakes and wetlands identified as generally flat and where the present vegetation requires large amounts of water normally available from a high water table. Riparian areas are transition zones between aquatic and upland terrestrial environments. Weeds are found in roadless and wilderness areas, and could be considered for treatment as long as such treatments are in compliance with the acts designating each wilderness

Lolo National Forest Integrated Weed Management ROD Page 11 area. There will be no aerial herbicide treatments or sheep or goat grazing for weed control in designated wilderness areas. Alternative 2 will use the same variety of treatment methods as at present except that sheep and goat grazing will be added. Weeds within a gross total area of 78,443 acres have been identified as needing treatment in this alternative. This is the total of all the exterior boundaries of the project areas. Actual, on the ground treatment will be less because only weed infested areas within the gross project areas will be treated and there is not 100% weed coverage in all the project areas. Roads, trails and linear features, for example, will usually only be spot treated where weeds occur. Acres included for treatment on each District are shown in the following table. Acres of treatment by Ranger District

Ranger District Acres Missoula 7,082 Ninemile 31,351 Plains/Thompson Falls 35,949 Seeley Lake 2,292 Superior 1,769 TOTAL 78,443 This alternative includes an adaptive approach that will allow managers to learn from the past and improve future effectiveness. Since every acre on the LNF has not been inventoried, many small existing sites have yet to be identified and it is inevitable that new infestations will be found. They will be screened using the Decision Tree (Appendix C of this Decision) to determine the most appropriate method(s) to use to minimize the risk of adverse environmental effects. Mitigation measures listed in, Appendix E of this Decision will also be used to minimize any adverse effects on human health and other resources. Screening will be documented as shown in Appendix B of the FEIS. These sites could be treated after review by an ID Team and documentation that environmental impacts are within the scope of those disclosed for Alternative 2 in FEIS Chapter 3. This alternative will provide quick, effective treatment of small, new infestations before they grow to unmanageable populations. A maximum of 15,000 acres, less than one percent of the 2.1million acre LNF could be treated annually. Our current capacity allows 5,000 to 6,000 acres to be treated annually. Aerial application will be considered and used according to the mitigation measures described in Appendix E of this Decision, if: • Sensitive resources (such as open water, or neighboring landowners adverse to herbicides) will be effectively protected and buffered • The overstory is open enough that the herbicides will reach the weeds (generally less than 25 percent canopy cover) • The infestation covers a large enough area to make aerial treatment efficient

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Herbicides included in Alternatives 1 and 2

Chemical Selective? Common Product Names Aminopyralid Yes Milestone and ForeFront R & P 2,4-D Yes Formula 40, Hi-Dep, Weedar 64 Chlorsulfuron Yes Telar Clopyralid Yes Transline Dicamba Yes Banvel, Veteran 10-G Glyphosate No Roundup, Rodeo, Accord Imazapic Yes Plateau Imazapyr* Yes Arsenal, Chopper, Contain Metsulfuron methyl Yes Escort, Ally Picloram Yes Tordon Triclopyr* Yes Garlon In Place, LI-700, MSO, Adjuvants N/A Preference, R-11, Stay Put, Syltac Dyes N/A SPI Max, Hi-Light, Dye marker

*Herbicides included in Alternative 2 but not in Alternative 1. VII. Decision Scope of the Decision As Lolo National Forest Supervisor, I am the responsible official for making the decision outlined in this Record of Decision. The FEIS identified that, based on the environmental analysis and public comment, I will decide: 1. Whether to authorize the LNF to expand efforts to control weeds using an adaptive strategy as described in Alternative 2, and 2. What specific monitoring requirements are necessary to ensure that treatments and mitigation measures are implemented Decision It is my decision to select and implement Alternative 2, as described in the LNF Integrated Weed Management FEIS. This decision is being made only for those lands, within the decision area described in Section II of this ROD. 1) Whether to authorize the LNF to expand efforts to control weeds using an adaptive strategy as described as Alternative 2 My decision is to expand current efforts to manage weeds by treating those infestations, locations and acreages within this decision area which were analyzed in Alternative 2 in the FEIS. Weed treatments can occur on a maximum of 15,000 acres annually within the decision area. At our current capacity, I expect 5,000 to 6,000 of the forest acres

Lolo National Forest Integrated Weed Management ROD Page 13 will be treated annually. Actual annual treatment acreage will be determined by available budget, staff, and weed infestations. Most areas will require periodic retreatment to ensure effective control. Treatments will continue until new information indicates the need for additional analysis. 2) What specific monitoring requirements are necessary to ensure that treatments and mitigation measures are implemented? My decision also incorporates education, weed prevention best management practices, and before, during and after treatment monitoring activities described on Pages 32-34 of the FEIS. My decision also includes the mitigation measures described on Pages 28-31 of the FEIS and Appendix E of this Decision. VIII. Rationale for the Decision Meeting the Purpose and Need I evaluated the Alternatives to determine how well they respond to the six items in the Purpose section of the FEIS and the five items in the Need section of the FEIS. I found that Alternative 2 best achieves all aspects of the Purpose and Need of the proposed project (FEIS pages 4-8) for the following reasons: Need Weeds are present and spreading on the LNF. We have identified widespread weeds, new weeds and potential weeds on the LNF. While prevention is an important weed management tool, we need to address existing weed populations on the LNF. The LNF has had active weed prevention and education programs for 15 years, but those programs do not address or provide any control on existing weeds. Direct control is needed to control weeds that are already established on the LNF. We are already doing a lot of weed management but weeds are still damaging forest resources, so we need to do more. Forest resources are being negatively affected by existing and expanding weed populations. Weeds diminish the productivity, biodiversity and appearance of LNF lands. Weeds can cause habitat loss and adversely affect diversity and habitat function in plant communities. We need to be able to respond quickly to new infestations and disturbances such as wildfire. At present, we cannot respond rapidly to new infestations and disturbances. We are receiving more and more requests from the public to control weeds, but we are unable to respond because we have NEPA decisions on only 10,333 acres of the 2.1 million acre LNF. Large wildfires are becoming more common and with them come increased risk of weed establishment and spread. We want to have an active weed program so we can implement and follow Federal and State laws, and Forest Service regulation, policy and initiatives relating to weed management. These laws (summarized on FEIS page 8-10) clearly direct the Forest Service to manage weeds on our lands. Alternative 2 increases the area, emphasis and ability of the LNF to reduce the spread of weeds each year on the LNF by: • Increasing the number of infestations and areas that can be treated

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• Adding sheep and goat grazing to our weed management • Allowing us to rapidly respond to recent and new weed infestations and new weed species By doing so we will be able to better comply with and follow the direction and emphasis provided in the Weed Laws and Policy that provide direction and authority for weed management on National Forest System lands (FEIS page 8). The following specific Purposes were developed to address the Need described above. Purpose: Prevent potential invaders from establishing. Potential invaders such as yellow starthistle, purple loosestrife, salt cedar and dyer’s woad have not been found on the LNF yet, but do occur nearby. Based on the extent of the infestations in adjacent areas and states, these weeds have the potential to become established and impact other resources. It is extremely important to prevent or discourage the introduction, establishment, and/or spread of these new and potential invader weed species into areas with few or no infestations on the LNF. This must be done in a rapid and timely manner due to the prolific and highly competitive nature of most of these species. Alternative 2 allows the application of the widest selection of integrated weed management techniques. New invasive species will initially establish either as individuals or small clusters within weed-free sites. Alternative 2 includes an aggressive prevention and education component and allows for the most flexible and most immediate treatment of new infestation sites covering a greater area of the Forest. Alternative 2 also allows an increase in annual allowable acres treated and by doing so allows us the maximum flexibility and ability to prevent weed species not found on the Forest to establish. Mitigation measures included in Appendix E ensure that other resources are protected. Adaptive management provisions in Alternative 2 ensure that we learn from past treatments to improve the efficacy and reduce nontarget impacts of future treatments. Purpose: Eradicate small new infestations and reduce larger infestations of new invaders. New invaders such as the hawkweeds and common toadflax have become established relatively recently. Some of these infestations were first seen on the LNF in the last few years, while others have been here longer but have only recently been discovered. Most new invaders have limited distribution. The most effective and most economical time to control a weed is when an infestation is small and occurrence is not wide spread. Left untended, these new invaders will increase and spread, increasing control complexity, cost and potential resource impact. Rapid and timely attention to new invader species is critical to reducing the impact of weeds on other resources on the LNF. Alternative 2 allows application of the widest selection of integrated weed management techniques on these new invader species. Alternative 2 also allows for the most flexible and rapid treatment of new invader sites over a greater area of the Forest. Alternative 2 also allows an increase in annual allowable acres treated and by doing so allows us the maximum flexibility and ability to prevent new invaders from expanding and becoming widespread weeds on the LNF.

Lolo National Forest Integrated Weed Management ROD Page 15 Mitigation measures included in Alternative 2 also ensure that other resources are protected. Adaptive management provisions in Alternative 2 ensure that we learn from past treatments to improve the efficacy and reduce non target impacts of future treatments. Purpose: Contain and reduce widespread weeds within infested areas. Widespread weeds, such as spotted knapweed, sulfur cinquefoil, houndstongue and Canada thistle, are found throughout the LNF and continue to expand. These weeds are not limited to disturbed areas; they have invaded both disturbed and undisturbed areas. Existing weeds NEPA decisions are out of date with present weed infestation levels and do not allow weed management on enough areas or acreage to deal with the current infestation levels. Alternative 2 is more flexible than the other alternatives to deal with the dynamic nature of the weed problem on the LNF, which includes many different widespread weed species, changing populations and locations, and changing inventory and treatment technologies. Alternative 2 provides for a more complete variety of treatment methods to deal with widespread weed infestations of various sizes from single plants to thousands of acres and to individual weed characteristics. Alternative 2 also allows for more treatment in remote, inaccessible locations adjacent to weed-free areas. While we do not expect to eradicate these widespread weed species, Alternative 2 will allow us to treat these species in high value resource area (such as bunchgrass big game winter ranges and areas with concentrated recreation use) and reduce spread of these widespread weeds to weed-free areas of the LNF. Mitigation measures included in Alternative 2 also ensure that other resources are protected. Adaptive management provisions in Alternative 2 ensure that we learn from past treatments to improve the efficacy and reduce non target impacts of future treatments. Purpose: Allow rapid, timely response to new, small or recently discovered weed infestations before they become well established. Treatment of weed infestations when they are small or only a few plants is the most effective and economical time to control a weed. Treatment at this time has the greatest chance to eradicate an infestation. It also has the least impact to other resources, from both the weed and the weed control. Complexity, cost and impact of weed control increases once a species or infestation becomes well established. Alternative 2 allows the timeliest response with the widest selection of integrated weed management tools on new, small or recently discovered weed infestations over the greatest area of the LNF, and by doing so, has the greatest likelihood of preventing small infestations from becoming well established. Mitigation measures included in Alternative 2 ensure that other resources are protected. Adaptive management provisions in Alternative 2 ensure that we learn from past treatments to improve the efficacy and reduce non target impacts of future treatments.

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Purpose: Prevent or limit the spread of established weeds to protect weed-free areas. While a large number of acres of the LNF have weeds, there are still vast areas of backcountry, wilderness and general forest that are weed-free. Only an estimated 17 percent of the LNF has weeds. That means that approximately 83 percent of the Forest is weed-free. I want to protect these weed-free areas from weed invasion. Alternative 2 will best protect these weed-free areas by treating weeds where they currently are found. Alternative 2 will do this by • Preventing potential invaders from establishing • Eradicating small new infestations • Reducing larger infestation of new invaders • Containing and reducing widespread weeds • Allowing rapid, timely response to newly discovered weed infestations By allowing weed treatment over the a greater number of sites and acres, and including and expanding our weed prevention and education programs, Alternative 2 will do the best we can to ensure that we pass these weed free areas onto future generations as legacies of healthy, native and properly functioning ecosystems. Purpose: Implement the 2004 Forest Service National Strategy and Implementation Plan for Invasive Species Management. The 2004 National Strategy and Implementation Plan for Invasive Species Management identified the Forest Service as one of the lead agencies in the fight against invasive plants. It provides long-term direction to reduce, minimize or eliminate invasive species across all landscapes and ownerships by: • Improving the management of invasive species using science-based technology, emphasizing partnerships • Increasing performance and accountability • Improving communication and education Alternative 2 updates and expands the LNF weed program specifically to more effectively fulfill the Forest Service’s lead agency role in the fight against invasive species. Alternative 2 identifies the specific species of concern and identified management goals for each species (Appendix A of this Decision). Alternative 2 further breaks down the weed problem and provides a specific purpose to each component of the issue: potential invaders, new invaders, widespread weeds, rapid response and protection of weed-free areas. It also includes a strong education and prevention component, expands the area of the forest where weeds can be controlled when encountered and opens the door to new and exciting partnerships with private individuals and local, state and other federal entities. Comprehensive mitigation measures (Appendix E of this Decision) ensure protection of other resources and public health in all weed management activities. The monitoring plan (Appendix D of this Decision) and tracking and documentation tools in the FEIS Appendix ensure accountability.

Lolo National Forest Integrated Weed Management ROD Page 17 How the Decision responds to the Issues that needed further analysis and were used to develop alternatives. Issues were determined from public comment and those that needed further analysis were used to develop alternatives that were given detailed analysis in the FEIS (pages 16-18). These issues and an explanation of how each alternative addresses these, and my rationale for selecting Alternative 2 are discussed below. The issues that were raised and used to develop alternatives that were not given detailed analysis are discussed in the FEIS on pages 18-21. Issues Needing Further Analysis and used to develop alternatives that were given further analysis Public and agency comments raised issues that guided the development of alternatives. Each issue is stated below as a question and is followed by a brief discussion of how it is addressed in the FEIS. What are the effects of weeds on wildlife and other natural resources? Many people described weeds as a very big problem because they have seen the impacts of nonnative plants on vast areas. The effects of weeds on natural resources are included in the discussions by resource in FEIS Chapter 3 (pages 35-199). Alternative 2 will reduce the effects of weeds on resources by increasing the area and number of infested sites the LNF can treat each year, by adding sheep and goat grazing to our weed management toolbox and allowing us to rapidly respond to recent and new weed infestations and new weed species. How will actions taken to control weeds, especially herbicides, affect wildlife and other resources? Some people expressed concern about the effects of herbicides on wildlife and other natural resources. To respond to this issue, a No Herbicide Alternative was discussed (FEIS page 19), a Low Herbicide Alternative was considered, but not studied in detail (FEIS page 19 and 20), and the No Action Alternative, which holds herbicide use at current levels and the Proposed Action (Alternative 2) were analyzed. The effects of herbicides on natural resources, (FEIS pages 35-199) as well as models and past experience with herbicide drift from aerial application (FEIS pages 140-146), are disclosed in FEIS Chapter 3. Effects on terrestrial animals, plants, soil and aquatic organisms are also addressed in the Forest Service Ecological and Human Health Risk Assessments (which were incorporated into this analysis by reference). Mitigation Measures (Appendix E of this Decision) were designed in response to this issue and are expected to protect the environment and resources from risks associated with herbicide applications. The analysis indicates that Alternatives 1 and 2 will present a low risk, if any, of herbicides threatening the health of forest vegetation, fish, soils and water, recreation, human health, wilderness and inventoried roadless areas, wild and scenic rivers, heritage resources, roads and wildlife (FEIS pages 35-199). Cumulative effects are also addressed on the same pages in the FEIS.

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There will be compliance with all Montana Water Quality Standards. In addition, Alternative 2 has the ability to effectively treat more acres of infestation and better meets the identified Purpose and Need of the project. What are the potential effects of herbicides on human health? Some people expressed concern about the effects of herbicides on human health. To respond to this issue, No Herbicide and Low Herbicide alternatives were discussed in Alternatives Considered, but Not Studied in Detail (FEIS page 18-21). The FEIS analysis reviewed and considered the scientific information available on risks from exposure to the herbicides we considered for use on the LNF. The potential human health effects of herbicides included in this proposal are discussed and disclosed in the FEIS (pages127-148). Effects on human health are also addressed in the Forest Service Ecological and Human Health Risk Assessments which were incorporated into this analysis by reference. Using routine safety procedures and personal protective equipment for operators all served to lessen the health hazard distinction between the alternatives. The mitigation measures In Appendix E of this Decision were also developed and contain specific provisions to protect human health. The analysis indicates that Alternatives 1 and 2 will present a low risk, if any, of herbicides threatening the health of workers or the general public (FEIS pages 127- 148) I believe that human health will be protected based on the types of herbicides used, application rates, monitoring, and mitigation measures included in Alternative 2. I also know that the Forest will be following EPA requirements, adhering to herbicide label instructions, and using certified herbicide applicators. Other Factors Considered in Making the Decision Noxious and invasive weeds are one of the biggest threats to ecosystem health on the LNF that we face today. While we will never eradicate weeds on the Forest, we can: • Prevent potential invaders such as yellow starthistle and rush skeletonweed from establishing on the Forest • Eradicate small new infestations and reducing larger infestations of new invaders such as hawkweeds and common toadflax • Contain or reduce widespread weeds such as spotted knapweed and Canada thistle within infested areas • Rapidly respond to new, small or recently discovered infestations before they spread and become well established • Prevent or limit the spread of established weeds into weed-free areas Prevention is widely accepted as the most desirable and effective method of weed control. While there are a large number of acres on the LNF infested with weeds, the situation could become much worse and will be much worse without all weed control efforts completed to date. Many new and more difficult weeds than what we already have on the LNF are found nearby. Just preventing any new weed species from establishing on the Forest will be a huge accomplishment, but we can do more. Prompt and decisive action now will prevent difficult to control rhizomatous weeds (such as the leafy spurge) from spreading and establishing in

Lolo National Forest Integrated Weed Management ROD Page 19 weed free or weed limited areas and will prevent the establishment of new species that are not yet present on the Forest. I chose Alternative 2 for the reasons stated above and because it best meets the Purpose and Need and the weed direction in the existing Forest Plan weed amendment and (with a solid and effective monitoring plan) best addresses the issues brought up by the public and planning team in the course of this analysis. The analysis and decision processes for this project are based on the consideration of the best available science. The manner in which best available science is addressed can be found throughout the disclosure of rationale found within the ROD, FEIS, Response to Comments, Biological Assessments, and the project file. Many citizens, scientists, groups, and County, State, and Federal Agencies promote the need to incorporate certain specific features that are essential for the successful treatment of weeds and the protection of native plant communities and other resources. I found that Alternative 2 contains important features (described below) necessary for successful treatment of weeds on the LNF. A. To Be Effective, We Must take Vigorous Action Noxious and invasive weeds are expanding their presence throughout managed and wildlands of the LNF. An inadequate weed control response will fail with severe consequences for two reasons. First, our managed and wildlands have difficulty in resisting some of the more aggressive weeds without human intervention in a variety of ways because native species and communities have little to-no inherent defense mechanisms. Secondly, an inadequate response to the weed threat will contribute to the advance of weeds over the landscape because the more aggressive weed species will not stay put. They will continue to spread over native habitats unless they are controlled by strong, integrated actions of land managers and the general citizenry. The large wildfires of 2000, 2003 and 2007 have added to the susceptibility of the Forest to invasion by certain weed species. People interested in the ecological health of the LNF appreciate the fact that the threat does not end with spotted knapweed. There are invasive plant species even more tenacious and destructive to native habitats, such as, but not limited to, yellow starthistle, rush skeletonweed and common crupina, not to mention woody weeds such as salt cedar and Japanese and giant knotweed. These species occur adjacent to the LNF but have not appeared yet on the Forest. After large scale land and vegetation disturbances such as wildfire they could easily spread and establish on the LNF. Alternative 2 allows the Forest to take the immediate and aggressive action necessary to eradicate new invaders and to reduce the hold of existing weeds on certain key site types. I believe these actions will protect and invigorate the native plant populations that are at risk currently and reduce the chance of weeds being spread by people from areas with heavy recreation use. B. We Need to Look Ahead and Deal with the Problem at the Appropriate Larger Scale The 1991 Noxious Weed Amendment to the LNF Plan, subsequent Ranger District level weed environmental assessments, the 1996 Mormon Ridge Winter Range FEIS

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and our 2001 Big Game Winter Range and Burned Area Weed Management FEIS identified noxious weed control as an important Forest-wide goal. Much good effort has been made against weed infestations since these analyses, but the weed problem on parts of the LNF not addressed in these decisions has increased on many of our roads, trails, key winter range, and other Forest lands. Alternative 2 gives the Forest the variety of tools and covers more areas and acres needed to deal with this growing problem in a more efficient and effective way at a broader scale – the landscape scale at which the weed problem exists. C. Our Neighbors Have Expressed a Growing Interest in the Forest Doing More Weed Control and Cooperating with Them in Controlling Weeds Montana has eight laws dealing with weed management and many statutes. The Forest Service also operates under several legal mandates to control noxious and invasive weeds. This decision allows the LNF to better cooperate and on a wider scale with local citizens, Counties, the State of Montana and other National Forests and federal agencies in a direct and meaningful way to stem the tide of invasive and noxious weeds. We need to be able to cooperate with and support the Counties and adjacent private landowners by controlling weeds on the National Forest side of all boundaries. Alternative 2 also fulfills our obligation to do our share to protect the flanks of other National Forests and Counties around us that have implemented weed control programs. D. Recognize the Importance of an Integrated Weed Management Strategy and Use the Full Toolbox to Combat the Problem of Invasive Weeds The cornerstone of this project is the application of the principles of integrated weed management in an adaptive management approach. The concept was developed to address larger scale threats of weed infestations. There is no standard treatment that will protect or restore landscapes from the damage caused by weeds. However, we do have a number of effective tools that we know can prevent and reduce the domination of our forests, valleys, and mountainsides by weeds. I want our Forest land managers to be able to use all the tools available. Alternative 2 allows them to do that. Integrated weed management is an adaptive management approach that looks at all aspects of the weed control effort. This includes: • Prevention and education with schools and users • Inventory work using Forest Service national databases such as FACTS and TERRA that identify the locations, extent, and species of problem plants • Prioritizing treatment areas for the most control benefit; making all treatment methods available as best fit the situation including: 2 biological controls 2 selecting the appropriate herbicides 2 sheep or goat grazing 2 seeding and planting desirable species 2 hand pulling

Lolo National Forest Integrated Weed Management ROD Page 21 For example, to date we have extensively used biological control agents on weeds on the LNF. Since 1978, we have conducted over 400 releases of 34 different biological agents on six weed species on the LNF. Biological control is a valuable tool and a young developing science. I intend to continue to pursue this option as much as possible while considering new science, findings and research on this weed management tool. Since 1992, we have conducted over 30 aerial herbicide spray projects. Aerial herbicide spray for weed control on the LNF is not a new program. Our aerial spray program has a proven history and an excellent safety record since we started 1992. This decision will allow us to continue the use of these and other valuable weed management tools. With this decision we will be able to add sheep and goat weed grazing to our weed control toolbox, subject to the mitigation measures described on Appendix E of this Decision that are designed to protect non target plants and animals, and the public from adverse effects. I recognize also the importance of prevention in the integrated response to the weed threat. Prevention tactics come in many forms. Some of them have been in effect prior to this decision, such as: • LNF longstanding decision to restrict cross-country travel by off-highway vehicles • Standard provision in timber sale contracts that requires the thorough washing down of harvest equipment • Prewashing of fire equipment coming to the Forest during wildfire events and including language in the Wildland Fire Situation Analysis and Delegation of Authority (direction on wildfire suppression) • Using weed-free seed for reclamation and restoration efforts • Weed Prevention and Control Measures 2 Regional Weed Free Feed Order 2 Region 1 Forest Service Manual 2080-2081 On the LNF, we constantly work with specialists, program leaders, and the public to develop additional and more effective ways to prevent weed establishment and spread in all our resource management activities. E. Proceed with Caution and Modify Our Tactics through Adaptive Management to Improve Our Effectiveness I plan to take an aggressive, but very careful approach to weed treatment in terms of implementation of this project. This decision will allow us to adjust our actions as we learn more through implementation. The adaptive management approach in the decision permits us to select from a menu of weed control techniques in order to improve our effectiveness. For example, we can reseed native plants or install emergency road closures in order to better achieve weed containment and control. This decision allows for the proactive ground application of herbicides by backpack, horse or mule mounted equipment, ATV or truck mounted equipment and by helicopter or airplane to eradicate new weeds and push back existing weeds on roads, trails, under the forest canopy and on open sites. This project will tailor the treatment objectives to match the different species, sizes of infestations and geographic location. For example, we will target small, localized

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infestations of new invasive plants for eradication. Large infestations of established noxious weeds are slated for containment so they don’t spread beyond the existing infestation perimeter into uninfested areas. F. Staying Effective through Follow-up Monitoring Through Alternative 2 and the use of adaptive management, the Forest will have a more comprehensive system for tracking our successes and identifying new problems as well as finding, mapping, and prioritizing occurrences of the species of concern. Monitoring is a key element of adaptive management and will provide long-term benefits not only through responding to changes in conditions, but also by providing a record of conditions over time. Geographic Information System (GIS) tracking of weed infestations within the Natural Resource Information System (NRIS) protocol allows for follow-up monitoring of weed locations and effectiveness of specific treatment methods and control agents. G. Summary of Rationale Each of the alternatives considered have benefits and drawbacks relative to the Purpose and Need, issues, and public comments. The Purpose and Need was developed through: • Experience and monitoring • In consideration of public comment • From our past weed analyses • Our Forest Plan • Other National and Regional laws and policies. Alternative 2 best meets the project’s Purpose and Need and also best addresses issues raised during the analysis process because it treats the most acres of noxious weeds, and contains the necessary environmental features, protection measures, and monitoring plans. This assures me that human and environmental health will be protected while weeds are treated across the landscape and while overall forest health is improved. Based on all of the above considerations, I have chosen to implement Alternative 2 for the decision area. I believe it is a reasonable and prudent action that uses the best information available on the effects of integrated weed management tools while using adaptive management to treat weeds in the decision area. My decision is based on a review of the record that shows a thorough review of relevant scientific acknowledgment of incomplete or unavailable information, scientific uncertainty, and risk. I acknowledged and considered that some commenters had opposing views on health effects of herbicides. IX. Findings Required by Law, Regulation, and Policy Numerous laws, regulations, and agency directives require that my decision be consistent with their provisions. After reviewing and evaluating all the evidence presented to me, I have determined that my decision is consistent with all laws, regulations, and agency policy relevant to this project. The following summarizes findings required by major environmental laws.

Lolo National Forest Integrated Weed Management ROD Page 23 1. National Forest Management Act of 1976 (NFMA) The National Forest Management Act (NFMA) and accompanying regulations require that several specific findings be documented at the project level. These are: A. Consistency with the Forest Plan Management activities are to be consistent with the Forest Plan [p16 USC 1604 (i)]. Based on the discussion provided in Chapter 3 of the FEIS, I have concluded that my decision is consistent with the Lolo Forest Plan. Alternative 2 is compatible with this direction. As stated in the FEIS on page 8-10, addressing invasive plant problems on the Forest is consistent with Forest Plan direction on weed management. LNF Plan Amendment 11 directs weed control projects to focus where they will have the greatest effect on preventing the spread of weeds or damage to natural resources and where they will have the greatest benefit to people who are actively trying to control weeds on land adjacent to the LNF. Plan Amendment 11 further says that priority will be given to weed control projects in areas relatively free of weeds, the roads that lead into those areas, and to new infestations and small patches that threaten areas at high or moderate risk of weed invasion. For these goals to be achieved, it is critical for the LNF to maintain and protect native vegetation. Native plants are the foundation upon which the ecosystems of the forest are built. Native plants: • Provide forage and shelter for all native wildlife, bird and insect species • Support the natural processes of the landscape • Provide the context within which the public find recreational and spiritual opportunities All these uses or values of land are hindered or lost by conversion of native vegetation to invasive and noxious weeds. B. Sensitive Species The Forest Service Manual 2670 provides direction applicable to sensitive species. In making my decision, I have reviewed the analysis and projected effects on all sensitive species listed as possibly occurring on the LNF. I concur with the findings documented for these species. This project complies with the standards and guidelines in Northern Rockies Lynx Amendment. 2. NEPA – Environmentally Preferred Alternative The Council on Environmental Quality (CEQ) regulations implementing NEPA require that the ROD specify “the alternative or alternatives which were considered to be environmentally preferable” [40 CFR 1505.2(b)]. This alternative has generally been interpreted to be the alternative that will promote the national environmental policy as expressed in NEPA’s Section 101 (CEQ’s “Forty Most-Asked Questions,” 46 Federal Register, 18026, March 23, 1981). Ordinarily, this means the alternative that causes the least damage to the biological and physical environment; it also means the alternative that best protects, preserves, and enhances historic, cultural, and natural resources.

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Alternative 2 is the environmentally preferred alternative because it allows for the use of all available tools for weed control. Consequently, it best protects native species and habitat diversity while having a minimal negative impact on other resources. Concerns of impacts to non target plants, animals and the public have been minimized through effective mitigation measures. See effects analysis contained in Chapter 3 of the FEIS. 3. National Forest Noxious Weed Management Policy (FSM 2080) Alternative 2 is consistent with the National Forest Noxious Weed Management Policy, which requires district rangers to prevent the introduction and establishment of weeds, along with providing for the containment and suppression, of noxious weeds; and to cooperate with state agencies. My decision to implement Alternative 2 will be effective in controlling noxious weeds and cooperating fully with state, county, and Federal officials in implementing 36 CFR 222.8 (regulation directing Forest Service to cooperate with local weed control districts). Noxious weed management will be directed where it will be most effective in preventing or reducing the spread of noxious weeds considered to be the greatest threat to economic, environmental, social, and other values. 4. Executive Order 13112, Invasive Species, February 3, 1999 This Executive Order directs Federal Agencies, whose actions may affect the status of invasive species, to (i) prevent the introduction of invasive species, (ii) detect and respond rapidly to, and control, populations of such species in a cost-effective and environmentally sound manner, as appropriations allow. My decision complies with this order. 5. Clean Water Act and State Water Quality Standards Based on the mitigation measures outlined in the FEIS to protect soil and water resources (Appendix E of this Document) and the Soil and Ground Water analysis in Chapter 3 (FEIS pages 112-123), I have concluded that Alternative 2 is consistent with the Clean Water Act. The mitigation measures cited above are designed to prevent contamination of surface and ground water. Section 313 of the Montana Clean Water Act requires Federal Agencies to comply with all substantive and procedural requirements related to water quality. This decision complies with those requirements as addressed in the FEIS, pages 112-123. 6. Clean Air Act By participating in the Montana and Idaho Interstate Airshed Group, complying with the Memorandum of Understanding with the Montana Air Quality Bureau, and meeting the requirements of the State Implementation Plan and the Smoke Management Plan, the proposed activities will comply with the Forest Plan and the 1977 Clean Air Act. The primary concern with this project in regard to air quality impacts is with the ground and aerial application of herbicides. Since impacts will be distributed across the Forest and over time, concentrations of air contaminants will not accumulate to the point of violating air quality standards.

Lolo National Forest Integrated Weed Management ROD Page 25 7. Endangered Species Act (16 USC 1531 et. seq.) The LNF wildlife biologists, fisheries biologist, and the regional botanist evaluated Alternative 2 with regard to threatened and endangered animal and plant species. The Regional Botanist has reviewed the Biological Evaluation for threatened, endangered and sensitive (TES) plant species and concurs with the effects determinations for TES plant species (FEIS pages 70-102 and for plant Species of Concern and Species of Interest, that are summarized in the FEIS on pages 93-102. The fish Biological Evaluation determination was Not Likely to Adversely Affect for bull trout and May Impact Individuals, but will not lead toward federal listing or loss of viability to the population or species for westslope cutthroat trout. (FEIS pages 111 and 112). Concurrence with these conclusions was received from the US Fish and Wildlife Service on October 30, 2007. Wildlife findings for bald eagle, gray wolf, grizzly bear and lynx were: May Effect but not likely to adversely affect (FEIS pages170, 173, 178, 182). Letter of concurrence with these conclusions was received from US Fish and Wildlife Service on October 31, 2007. Under provisions of the ESA, federal agencies are directed to conserve endangered and threatened species and to ensure that actions are not likely to jeopardize the continued existence of any of these species. Upon review of Chapter 3 of the FEIS, and the biological assessments, I find that my decision complies with ESA. 8. National Historic Preservation Act, American Indian Religious Freedom Act and Native American Grave Protection and Repatriation Act Effects to cultural resources is displayed in the FEIS on pages 154 though 158. Because none of the herbicides proposed for use are corrosive at field rates, herbicide spraying will have no effect to cultural resources. Hand-pulling of weeds has the potential to disturb buried cultural materials. A cultural resource inventory will be completed prior to any large scale hand pulling of weeds to determine whether cultural resources will be impacted. Hand-pulling of weeds will not be completed on eligible cultural sites without concurrence with the Forest Archeologist. 9. Government to Government Relations The Forest Service consulted with the Flathead Culture Committee of the Confederated Salish and Kootenai Tribes (CSKT) during the analysis process. The intent of this consultation has been to remain informed about Tribal concerns regarding the American Indian Religious Freedom Act (AIRFA) and other Tribal issues. The CSKT has reserved rights under the Hellgate Treaty of 1855 (July 16, 1855). These rights include the “right of taking fish at all usual and accustomed places, in common with citizens of the Territory, and of erecting temporary buildings for curing; together with the privilege of hunting, gathering roots and berries, and pasturing their horses and cattle upon open and unclaimed land.” The federal government has trust responsibilities to Tribes under a government-to- government relationship to insure that the Tribes’ reserved rights are protected.

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Consultation with the tribes in the project planning helps insure that these trust responsibilities are met. Effects to traditional cultural harvesting practices are disclosed on FEIS pages 154-158. 10. Environmental Justice I have considered the effects of this project on low income and minority populations and concluded that this project is consistent with the intent of the Environmental Justice Act of 1994 (EO 12898). Representatives from low income and minority populations were notified of this project through the public participation process and no issues with the Proposed Action were identified in regard specific to low income and minority populations. Resource analysis disclosed no disproportionate effects to low income or minority populations. 11. Migratory Bird Treaty Act On January 10, 2001, President Clinton signed an Executive Order outlining responsibilities of federal agencies to protect migratory birds. Upon review of the effects analysis regarding neotropical migratory birds on FEIS pages 194-196, I find that the selected alternative complies with this Executive Order. 12. Administration of the Forest Transportation System No change in the Forest transportation system will result from implementation of the selected alternative. X. Appeal Provisions and Implementation This decision is subject to appeal pursuant to 36 CFR 215.11. A written appeal must be submitted within 45 days following the publication date of the legal notice of this decision in the Missoulian newspaper, Missoula, Montana. It is the responsibility of the appellant to ensure their appeal is received in a timely manner. The publication date of the legal notice of the decision in the newspaper of record is the exclusive means for calculating the time to file an appeal. Appellants should not rely on date or timeframe information provided by any other source. Paper appeals must be submitted to: USDA Forest Service, Northern Region or USDA Forest Service, Northern Region ATTN: Appeal Deciding Officer ATTN: Appeal Deciding Officer PO Box 7669 200 East Broadway Missoula, MT 59807 Missoula, MT 59802 Office hours: 7:30 to 4:00 pm. Electronic appeals must be submitted to: appeals-northern-regional- [email protected] Faxed appeals must be submitted to: FAX: (406) 329-3411 In electronic appeals, the subject line should contain the name of the project being appealed. An automated response will confirm your electronic appeal has been received. Electronic appeals must be submitted in MS Word, Word Perfect, or Rich Text Format (rtf).

Lolo National Forest Integrated Weed Management ROD Page 27 It is the appellant's responsibility to provide sufficient project- or activity-specific evidence and rationale, focusing on the decision, to show why my decision should be reversed. The appeal must be filed with the Appeal Deciding Officer in writing. At a minimum, the appeal must meet the content requirements of 36 CFR 215.14, and include the following information: 1. The appellant’s name and address, with a telephone number, if available; 2. A signature, or other verification of authorship upon request (a scanned signature for electronic mail may be filed with the appeal); 3. When multiple names are listed on an appeal, identification of the lead appellant and verification of the identity of the lead appellant upon request; 4. The name of the project or activity for which the decision was made, the name and title of the Responsible Official, and the date of the decision; 5. The regulation under which the appeal is being filed, when there is an option to appeal under either 36 CFR 215 or 36 CFR 251, subpart C; 6. Any specific change(s) in the decision that the appellant seeks and rationale for those changes; 7. Any portion(s) of the decision with which the appellant disagrees, and explanation for the disagreement; 8. Why the appellant believes the Responsible Official’s decision failed to consider the substantive comments; and 9. How the appellant believes the decision specifically violates law, regulation, or policy. If an appeal is received on this project there may be informal resolution meetings and/or conference calls between the Responsible Official and the appellant. These discussions will take place within 15 days after the closing date for filing an appeal. All such meetings are open to the public. If you are interested in attending any informal resolution discussions, please contact the Responsible Official or monitor the following website for postings about current appeals in the Northern Region of the Forest Service: http://www.fs.fed.us/r1/projects/appeal_index.shtml.” Additional records in support of the environmental analysis are available for public review at the Lolo National Forest Supervisor’s Office, Building 24A Fort Missoula, Missoula, MT 59804. For further information on this decision, contact Andy Kulla, Project Team Leader at (406) 329-3962. If no appeal is received, implementation of this decision may occur on, but not before, five business days from the close of the appeal filing period. If an appeal is received, implementation may not occur for 15 days following the date of appeal disposition.

/s/Deborah L. R. Austin December 11/2007 DEBORAH L. R. AUSTIN Date Forest Supervisor

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